# ECONOMIC AND BENEFIT S ANALYSIS OF

THE PROPOSED 2013 VESSEL GENERAL PERMI T (VGP)

Office of Wastewater Management

U.S. Environmental Protection Agency

November 30, 2011Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 ii 

## Table of Contents

1 Introduction ................................................................................................................................................... 1

1.1 Background ...................................................................................................................................................... 1

1.2 Report Organization ........................................................................................................................................ 2

2 Population of Affected Vessels ...................................................................................................................... 3

2.1 Domestic Vessel Population ............................................................................................................................ 3

2.2 Foreign Vessel Population ............................................................................................................................... 6

2.3 Vessels Subject to NOI Requirements ............................................................................................................. 7

2.4 Vessels Subject to the Bilge water Treatment Requirements .......................................................................... 8

2.5 Vessels Subject to the Ballast Water Management Requirements .................................................................. 9

2.6 Uncertainties and Limitations ........................................................................................................................ 12

3 Profile of the Water Transportation, Fishing, and Mining Industries ................................................... 14

3.1 Introduction ................................................................................................................................................... 14

3.1.1 Data Sources Used ............................................................................................................................ 15

3.1.2 Organization Of This Chapter .......................................................................................................... 15

3.2 Overview of the Water Transportation, Fishing, and Mining Industries ....................................................... 16

3.2.1 Definition of the Water Transportation, Fishing, and Mining Industries ......................................... 16

3.2.2 Water Transportation ........................................................................................................................ 16

3.2.3 Fishing .............................................................................................................................................. 21

3.2.4 Mining .............................................................................................................................................. 21

3.3 Recent Trends ................................................................................................................................................ 22

3.3.1 Numb er of Vessels by Industry Sector ............................................................................................. 22

3.3.2 Number of Establishments by Industry Sector ................................................................................. 23

3.3.3 Establishment and Employment Births and Deaths.......................................................................... 24

3.3.4 Financial Performance ...................................................................................................................... 26

3.4 Industry Market Structure .............................................................................................................................. 27

3.4.1 Firms and Revenues ......................................................................................................................... 27

3.4.2 Reve nue by Vessel ........................................................................................................................... 30

3.4.3 S m all Businesses .............................................................................................................................. 31

3.4.4 Employment and Payroll .................................................................................................................. 32

4 Cost of Best Management Practices ........................................................................................................... 36November 30, 2011 iii 4.1 Technology- Based Effluent limits and related requirements applicable to All Vessels ................................ 37

4.2 effluent limits and related requirements Related to Specific Discharge Categories ...................................... 38

4.2.1 Discharges of Deck Washdown and Runoff and Above Water Lin e Hull Cleaning ........................ 39

4.2.2 Discharges of Bilge Water ................................................................................................................ 42

4.2.3 Discharges of Ballast Water ............................................................................................................. 55

4.2.4 Anti -Fouling Hull Coatings .............................................................................................................. 72

4.2.5 Aqueous Film- Forming Foam .......................................................................................................... 74

4.2.6 Boiler/Economizer Blowdown ......................................................................................................... 74

4.2.7 Cathodic Protection .......................................................................................................................... 74

4.2.8 Chain Locker Effluent ...................................................................................................................... 77

4.2.9 Controllable Pitch Propeller and Thruster Hydraulic Fluid and Other Oil Sea Interfaces Including Lubrication Discharges from Paddle Wheel Propulsion, Stern Tubes, Thruster Bearings,
Stabil izers, Rudder Bearings, Azimuth Thrusters, Propulsion Pod Lubrication, and Wire Rope and Mecahnical Equipment Subject to Immersion .................................................................................. 78

4.2.10 Distillation and Reverse Osmosis Brine ........................................................................................... 83

4.2.11 Elevator Pit Effluent ......................................................................................................................... 83

4.2.12 Firemain Systems ............................................................................................................................. 84

4.2.13 Freshwater Layup ............................................................................................................................. 84

4.2.14 Gas Turbine Wash Water ................................................................................................................. 84

4.2.15 Graywater ......................................................................................................................................... 84

4.2.16 Motor Gasoline and Compensating Discharge ................................................................................. 90

4.2.17 Non

- Oily Machinery Wastewater ..................................................................................................... 90

4.2.18 Refrigeration and Air Condensate Discharge ................................................................................... 91

4.2.19 Seawater Cooling Overboard Discharge (Including Non -Contact Engine Cooling Water, Hydraulic System Cooling Water, Refrigeration Cooling Wat er) ..................................................................... 91

4.2.20 Seawater Piping Biofouling Prevention ........................................................................................... 91

4.2.21 Small Boat Engine Wet Exhaust ...................................................................................................... 91

4.2.22 Sonar Dome Discharge ..................................................................................................................... 92

4.2.23 Underwater Ship Husbandry Discharges .......................................................................................... 93

4.2.24 Welldeck Discharges ........................................................................................................................ 94

4.2.25 Graywater Mixed with Sewage from Vessels .................................................................................. 95

4.2.26 Ex haust Gas Scrubber Washwater Discharge .................................................................................. 95

4.2.27 Fish Hold Effluent ............................................................................................................................ 99

4.3 Costs of Ves sel

- Specific Requirements ....................................................................................................... 101Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 iv 4.3.1 Large and Medium Cruise Ships .................................................................................................... 101

4.3.2 Large Ferries ................................................................................................................................... 105

4.3.3 Unmanned Barges (Such As Hopper Barges, Chemical Barges, Tank Barges, Fuel Barges, Crane Barges, Dry Bulk Cargo Barges) .................................................................................................... 105

4.3.4 Oil Tankers, Petroleum Tankers or Bulk Chemical Carriers .......................................................... 106

4.3.5 Research Vessels ............................................................................................................................ 106

4.3.6 Emergency Vessels (Fire Boats, Police Boats) .............................................................................. 106

4.4 General inspection and Permit Paperwork Burden ...................................................................................... 107

4.4.1 Revised Paperwork Requirements .................................................................................................. 108

4.4.2 Paperwork Requirement Burden for Newly Covered Commercial Fishing Vessels ...................... 110

4.5 Analysis of Total National Costs ................................................................................................................. 110

4.6 Uncertainties and Limitations ...................................................................................................................... 113

5 Analysis of Impacts on Firm Revenues and Financial Performance .................................................... 115

5.1 Methodology ................................................................................................................................................ 115

5.1.1 Assign Each Vessel to a Naics Code .............................................................................................. 115

5.1.2 Estimate the Number of Vessels Per Firm ...................................................................................... 116

5.1.3 Estimate the Distribution of Costs Per Vessel ................................................................................ 117

5.1.4 Compare Firm- Level Costs to Firm

- Level Revenues ..................................................................... 121

5.2 Small Entity Analysis .................................................................................................................................. 121

5.3 Uncertainties and Limitations ...................................................................................................................... 126

6 Benefits Analysis ........................................................................................................................................ 128

6.1 Ballast Water and Invasive Species Impacts ............................................................................................... 128

6.1.1 Introduction and Background ......................................................................................................... 128

6.1.2 ANS Impacts .................................................................................................................................. 129

6.1.3 Efficacy of VGP Ballast Water Management Practices ................................................................. 135

6.1.4 Benefits of Reducing ANS Introductions ....................................................................................... 135

6.2 Benefits of Reduced Pollutant Discharges from Vessels ............................................................................ 137

6.2.1 Introduction and Background ......................................................................................................... 137

6.2.2 P ollutants Commonly Found in Vessel Discharges ....................................................................... 138

6.2.3 P ollutant Impacts ............................................................................................................................ 142

6.2.4 Benefits of Reducing Pollutant Discharges .................................................................................... 144

References ............................................................................................................................................................. 147November 30, 2011 v 

## List of Tables

Table 2 -1. Domestic Vessel Population ..................................................................................................................... 5

Table 2 -2. Foreign Vessel Population. ....................................................................................................................... 6

Table 2 -3: Population of Vessels Required to Submit an NOI. ................................................................................. 8

Table 2 -4: Population of Vessels Greater than 400 Gross Tons. ............................................................................... 9

Table 2

- 5: Population of Vessels Subject to Ballast Water Requirements. ............................................................. 11

Table 3 -1. Principal 2007 NAICS Codes and Descriptions Relevant to Vessels Covered by the VGP. ................. 16

Table 3

- 2. Number of Vessels in the WTLUS Database, 2000 -2008. ..................................................................... 23

Table 3 -3. Number of Establishments by Industry Sector, 2002 and 2007. ............................................................ 24

Table 3 -4. Establishment Births and Deaths, Five- Year Annual Avera ge: 2002 -2007. .......................................... 25

Table 3 -5. Net Change in Employment: Five-Year Annual Average, 2002-2007. .................................................. 26

Table 3 -6: Revenues by Industry Sector, 2002 and 2007. ....................................................................................... 27

Table 3 -7. Firms and Revenues by Employment Size, 2007. .................................................................................. 29

Table 3 -8. Number of Firms According to Revenue Size, 2007. ............................................................................. 30

Table 3 -9: Small Businesses by Industry Sector. ..................................................................................................... 32

Table 3 -10. Employment by Industry Sector, 2002-2007. ....................................................................................... 34

Table 3 -11. Payroll by Industry Sector, 2002-2007. ................................................................................................ 35

Table 4 -1. Vessel Counts for Practice Applicable to Deck Runoff. ........................................................................ 39

Table 4 -2. Per- Vessel Costs for Practice s Associated with Deck Runoff ................................................................ 40

Table 4 -3. Deck Runoff Sensitivity Analysis. ......................................................................................................... 42

Table 4

- 4. Summary of the Potential Implications of Revised Bilge Water Discharge Requirements under
Consideration ................................................................................................................................................... 46

Table 4

- 5. Vessel Counts for Practices Applicable to Option to Authorize Discharge of Treated Bilge Water (to 5 ppm). ................................................................................................................................................................ 48

Table 4

- 6. Bilge Water Treatment Sensitivity Analysis. ......................................................................................... 54

Table 4 -7. USCG Phase One and IMO D- 2 Ballast Water Discharge Standards. ................................................... 62

Table 4 -8. Vessel Counts for Practices Applicable to Ballast Water Treatment. .................................................... 63

Table 4

- 9. Vessel Counts for Practices Applicable to Ballast Water Treatment for Vessels Entering the Great
Lakes. ............................................................................................................................................................... 64

Table 4 -10. Discharge Sampling and Testing Requirements. .................................................................................. 66

Table 4 -11. Annual per vessel cost of ballast water requirements. .......................................................................... 67

Tab le 4

- 12. Ballast Water Treatment and Exchange Costs. ..................................................................................... 68Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 vi Table 4

- 13. Ballast Water Treatment Sensitivity Analysis. ..................................................................................... 71

Table 4 -14. Vessel Counts for Cathodic P rotection Practices. ................................................................................ 75

Table 4 -15. Cathodic Protection Installation Cost Estimates (2010$). .................................................................... 76

Table 4

- 16. Cathodic Protection Sensitivity Analysis, Purchase of a Cathodic Protection System. ....................... 77

Table 4

- 17. Vessel Counts for General Oil

- to

- Sea Interface and Controllable Pitch Propeller Hydraulic Fluid
Practices. .......................................................................................................................................................... 80

Table 4 -18: Lubricant Consumption Rates by Vessel Class. ................................................................................... 82

Table 4

- 19. Environmentally Acceptable Lubricants Sensitivity Analysis. ............................................................ 83

Table 4 -20. Vessel Counts for Graywater Practices. ............................................................................................... 89

Table 4

- 21. Graywater Monitoring Sensitivity Analysis. ........................................................................................ 90

Table 4 -22. Vessel Counts for Underwater Ship Husbandry Practices.................................................................... 94

Table 4 -23. Exhaust Gas Scrubber Washwater Discharge Monitoring Sensitivity Analysis. ................................. 99

Table 4 -24. Vessel Counts for Fish Hold Effluent Practices ................................................................................. 100

Table 4 -25. Cruise Ship Counts. ............................................................................................................................ 104

Table 4

- 26. Vessel Class Breakdown. ................................................................................................................... 108

Table 4 -27. Incremental Burden Assumptions for General Inspection and Paperwork Requirements. ................. 109

Table 4 -28. Incremental Burden (Reduction) for Combined Barge Annual Reports. ........................................... 109

Table 4 -29. Incremental Burden Assumptions for General Inspection and Paperwork Requirements for Commercial Fishing Vessels. ......................................................................................................................... 110

Table 4 -30. Total Annual Compliance Costs, by Practice Category and Vessel Class ......................................... 112

Table 4

- 31. Total Annual Compliance Costs for All Practices, by Vessel Type, Including Paperwork Costs. ..... 113

Table 5 -1: Number of Vessels by Firm in Each Industry Sector. .......................................................................... 117

Table 5 -2. Estimated 1% and 3% R evenue Thresholds by NAICS Code for Firms in Smallest Revenue Category.

....................................................................................................................................................................... 123

Table 5

- 3. Results of the Small Entity Impact Analysis. ....................................................................................... 125

Table 6

- 1: Estimates of Invasive Species in Several Major Water Systems. ......................................................... 130

Table 6

- 2: Estimates of Invasive Species Damages by Type of Species. .............................................................. 130

Table 6 -3. Pollutants Found in Vessel Discharges a . .............................................................................................. 138

Table 6 -4. Types of Pollutants Found in Gr aywater Discharges ........................................................................... 139

Table 6 -5. Impairment Status of the Top 20 Ports by Annual Vessel Calls. ......................................................... 145

Table 6 -6. Benefits of Reducing Pollutants Found in Vessel Discharges. ............................................................. 146November 30, 2011 vii 

## Acronyms

ACSI Alaska Cruise Ship Initiative
ADEC Alaska Department of Environmental Conservation

AFFF Aqueous film

- forming foam

AMSA Australian Maritime Safety Authority

ANS Aquatic non

- indigenous species

ANSTF Aquatic Nuisance Species Task Force

APPS Act to Prevent Pollution from Ships

BWTS Ballast Water Treatment System

BMP Best management practice
BOD Biochemical oxygen demand

CCC Criterion Continuous Concentration
CDC Centers for Disease Control

CLIA Cruise Line International Association

CMC Criterion Maximum Concentratio n COTP Captain of the Port

CPI Consumer Price Index

CWA Clean Water Act

DOD Department of Defense

EEZ Exclusive Economic Zone

eNOI Electronic Notice of Intent

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

GESAMP Joint Group of Experts o n the Scientific Aspects of Marine Environmental Protection

GLERL Great Lakes Environmental Research Laboratory

GSMFC Gulf States Marine Fisheries Commission

IADC International Association of Drilling Contractors

ICCP Impressed Current Cathodic Protect ion
ICST International Classification of Ships by Type

IDNR Indiana Department of Natural Resources

IMO International Maritime Organization

ISA Infectious salmon anemia

MARPOL 1973/78 International Convention for the Prevention of Marine Pollution from Ships

MISLE Marine Information for Safety and Law Enforcement

MODU Mobile Offshore Drilling Unit

NAICS North American Industry Classification System

NANCPA Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990

NBIC National Ballast Information Clearinghouse

NDC Navigation Data Center
NISA National Invasive Species Act

NMFS National Marine Fisheries Service

NOAA National Oceanic and Atmospheric Administration

NoBOB No ballast on board

NOI Notice of Intent

NPDE S National Pollutant Discharge Elimination System

NRDC National Resources Defense Council
NRWQC National recommended water quality criteria

OTA Office of Technology Assessment

PAH Polycyclic aromatic hydrocarbon

PARI Permit Authorization and Record o f Inspection

PFOA Perfluorooctanoic acid

PFOS Perfluorooctane sulfonateEconomic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 viii POC Pollutant of concern

RFA Regulatory Flexibility Act

RO

- RO Roll

- on/roll

- off

RTF Ruffe Task Force

SAB Science Advisory Board

SBA Small Business Administration

SBAC Small Bus iness Advocacy Chair

SBREFA Small Business Regulatory Enforcement and Fairness Act

SIC Standard Industrial Classification

TBT Tributyl tin
UNDS Uniform National Discharge Standards

USACE U.S. Army Corps of Engineers

USCG U.S. Coast Guard

USDA U.S. Department of Agriculture

USDOI U.S. Department of the Interior

USGS U.S. Geological Survey

VDS Vessel Documentation System

VESDOC Merchant Vessels of the United States

VHS Viral hemorrhagic septicemia

VTCC Vessel Type, Construction, and Characterist ics
WCSC Waterborne Commerce Statistics Center

WHOI Woods Hole Oceanographic Institute

WTLUS Waterborne Transportation Lines of the United StatesNovember 30, 2011 ix 

### EXECUTIVE SUMMARY

EPA is revising permitting requirements for discharges incidental to the normal opera tion of non -recreational,

non- military vessel s into inland waters or the territorial sea of the United States under the National Pollutant Discharge Elimination System (NPDES).

This report presents EPA’s economic and benefits analysis of impacts of revisio ns to the Vessel General Permit

on all affected vessels. Though the issuance of this Permit is not a Federal regulation, EPA is conducting this analysis to evaluate potential impacts of th e VGP . The Executive Summary provides an overview of the costs and
b enefits of VGP revisions

. The Vessel General Permit for Discharges Incidental to the Normal Operation of Vessels (herein referred to as the Vessel General Permit or VGP) covers non -r ecreational and non- military vessels 79 feet or more in length

. 1 The

VGP defines effluent limits for 27 discharge categories as well as specifying certain practices and discharges for selected vessel categories. 2

All vessels operating in a capacity of transportation are eligible for coverage under the VGP . The types of vessels covered under the Permit include commercial fishing vessels, cruise ships, ferries, barges, mobile offshore drilling units (MODUs), oil tankers or petroleum tankers, bulk carriers, cargo ships, container ships, other cargo freighters, refrigerant ships, government vessels not a part of the armed forces (e.g. NOAA and USACE vessels), research vessels, and emergency response vessels, including firefighting and police vessels, and any other vessel operating in a capacity of transportation. Vessels of the arme d forces of the United States are not eligible for coverage by this Permit. EPA estimates that is 58,602 domestic flag and 12 ,429 foreign flag vessels will be
covered under the VGP , but only a subset of these vessels will incur incremental costs as a resul t of the revised requirements

. Chapter 2 : Population of Affected Vessels of this report presents EPA’s assessment of the numbers and types of vessels likely to be impacted by the revised permitting requirements.

Water transportation accounts for a majority of the vessels sailing on U.S. waters an d covered by the VGP. As of 2007, the water transportation industry was a $48 billion industry that employ ed over 157,000 people on a payroll of over $8 billion. 3 Overall, the industry has experienced growth in the revenues, payroll and number of employees, but a decline in the number of establishments. The global economic crisis and U.S. recession

, post 2007, likely impacted the water transportation as a reduced overall flow of goods reduced shipping volume and other leisure water transportation activities decreased, it also likely also affected the fishing and mining industries. The fishing industry is responsible for slightly more than a quarter of all commercial vessels in the United States

. The fishing industry is much smaller, with total reven ues of $1.66 billion, employing 5,600 people on a payroll of $302 million. It has experienced a slight increase in number of establishments and payroll, although it has also experienced a decline in the number of employees. The drilling oil and gas wells s ector, a subset of the mining industry (which includes the 131 MODUs covered under the VGP), is a $9 billion sector that employs nearly

1 If auxiliary vessels or craft, such as lifeboats or rescue boats less than 79 feet onboard larger vessels require permit coverage, they are eligible for coverage under this permit and are covered by submission of the Notice of Intent for larger vessels. Recreational vessels as defined in section 502(25) of the Clean Water Act are not subject to this permit

.

2 Vessel categories with specific permit requirements include: large cruise ships; medium cruise ships; large ferries; barges; oil tankers or petroleum tankers; research vessels; emergency vessels; and vessels employing experiment al ballast treatment systems.

3 T he 2007 Economic Census provides the most recent revenue, employment and establishment data

.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 x 60,500 people on a payroll of approximately $2.5 billion. This sector has experienced strong growth with a

115 percent i ncrease in revenue from 2002 to 2007. On the whole, the three industries are composed of about

93 percent small businesses. Of the 3,907 firms in the water transportation industry, 3,637 (9 3.1 percent) are small. In the fishing industry, 1,843 (96.2 percent) of the 1,916 firms are small. In the drilling oil and gas wells sector, 1, 893 (89.9 percent) of the 2,109 firms are small

. Chapter 3: Profile of Water Transportation, Fishing and Mining Industries provides an eco nomic profile of these industries.

To estimate the effect of revised Permit requirements on an industry as a whole, EPA’s analysis takes into account previous conditions and determines how the industry would act in the future in the absence of revised Permit requirements. The baseline for this analysis is full industry compliance with existing federal and state regulations

, including the 2008 VGP in the case of vessels currently covered by the permit ; and existing industry practices or
standards that ex ceed current regulations to the extent that they can be empirically observed. In addition, a number of laws and associated regulations (including the National Invasive Species Act; the Act to Prevent Pollution from Ships; the Comprehensive Environmental Response, Compensation, and Liability Act; the Organotin Anti- fouling Paint Control Act; and others) already cover certain discharges that would be covered by
the VGP

. The overlap between revised permit requirements and existing regulations and practices is discussed at greater length in the sections of the report that address each revised requirement.

Chapter 4 : Cost of Best Management Practices presents EPA’s analysis of compliance costs to commercial vessels associated with each of the practices and discharge categories identified and the paperwork burden costs

. Incremental costs are understood to result from the inclusion of all commercial fishing vessels 79 feet or larger
unde r the VGP (these vessels were largely not covered by the 2008 VGP) , and from revised, more stringent requirements for certain discharge categories and practices. Changes in compliance costs also result from streamlining selected requirements, which is expected reduce compliance costs for owners of certain vessels. Overall, EPA finds that revisions in the VGP requirements could result in aggregate annual incremental costs for
domestic vessels rang ing between $6.5 and $20.9 million (in 2010 $) . This includes the paperwork burden costs and the sum of practice cost s for applicable discharge categories for all vessels estimated to be covered by the
revised VGP . Per vessel incremental compliance costs range between $0 to about $8,400 per year , depending on
the num ber of applicable discharge categories and baseline practices

. The maximum value in that range is for a large ship assumed to incur the maximum cost for each and all relevant practices. Most vessels covered by the VGP incur compliance costs that are much l ower, however, as average compliance costs range between $ 26 and $3,933 per vessel. The largest share of the incremental cost s is generally associated with requirements mandating the use of environmentally acceptable lubricants. As discussed in Section 4, there is considerable uncertainty in the assumptions used for several practices and discharge categories and these estimates therefore provide illustrative ranges of the costs potentially associated with the 2013 VG P rather than incremental costs incurred by any given vessel owner

. Nevertheless, the estimated compliance costs generally represent a small share of per vessel operating revenue. Hence, EPA finds that meeting the 2013 VGP permit requirements is economically practicable and achievable for permittees.

To evaluate the potential economic impacts of revised VGP requirements on the water transportation, fishing, and mining industries, EPA performed a firm

- level analysis. The firm

- level analysis examine s the impact of any incremental cost per vessel to comply with the revised VGP requirements on model firms that represent the financial conditions of “typical” businesses in each of the examined indu stry sectors. Since more than ninety percent of the firms in the water transportation and fishing industries, and in the drilling oil and gas wells segment of the mining industry are small, it is unlikely that firm

- level impacts would be material among large firms in this industry. Therefore, the firm

- level analysis focuses on assessment of impacts on small businesses. To evaluate the potential impact of the VGP on small entities, EPA used a cost

- to

- revenue test to evaluate the potential severity of economic impact on vessels owned by small entities. The test cal culates annualized pre- tax compliance cost as aNovember 30, 2011 xi percentage of total revenues and uses a threshold of 1 and 3 percent to identify entities that would be significantly impacted as a result of this Permit. Chapter 5 : Analysis of Impacts on Firm Revenues and Financial Performance details EPA’s assessment of the cost and economic impact of regulatory requirements on firms in the shipping industry, and the implications of the Permit in terms of financ ial viability of shipping industry firms subject to the Permit. According to the firm

- level analysis, the total number of small entities in the fishing industry that are expected to exceed the one percent cost

- to

- revenue threshold ranges between 0 and 189 for the low end and high end cost assumptions, respectively. EPA believes the analysis overstates impacts to smaller firms due to modeling assumptions. 4 The total number of small entities in the water transportation industry that are expected to exceed the one percent cost- to -revenue threshold ranges from 52 to 171 under the low and high end cost assumptions, respectively. Overall, less than 7 percent of firms have costs estimated to exceed the one percent cost

- to -revenue threshold and less than one percent of firms have costs estimated to exceed the three percent cost

- to

- revenue threshold, based on high end cost estimates. As discussed in the Chapter, the methodology used to distribute compliance costs to vessel and firms of different sizes is likely to overstate impacts on small firms.

Although EPA was unable to evaluate the expected benefits of the Permit in dollar terms due to data limitations, the Agency collected and considered relevant information to enable qualitative consideration of ecological benefits and to assess the importance of the ecological gains from revisions to the VGP . EPA expects that reductions in vessel discharges will benefit society in two broad categories: (1) enhanced water qua lity from reduced pollutant discharges and (2) reduced risk of invasive species introduction. These effects are discussed in Chapter 6 : Benefits Analysis

.
The VGP covers many discharges and contains special provisions for numerous vessel types (see EPA ( 2011 ) for information on the affected discharges and provisions by vessel type). Many of the discharges regulated by EPA’s

VGP are associated with a wide variety of harmful pollutants in substantial concentrations. For example, untreated graywater may contain pathogenic bacteria, toxic and carcinogenic organic and inorganic compounds, nutrients, and metals (EPA, 2007a). Because many of the nation’s busiest ports are considered to be impaired by a variety of pollutants found in vessel discharges, strengthening t he requirements contained in the VGP, as accomplished by the 2013 VGP revisions, is expected to have benefits associated with the reduction of concentrations of nutrients, metals, oil, grease, and toxics in waters with high vessel traffic.

4 The distributional analysis model is likely overstates impacts to firms in this sector due methodology limitations discussed lat er in this
Section and in Section 5.3 , notably EPA’s conservative assumptions regarding the distribution of vessels to firms across size categories and relatively uniform characteristics of vessels assigned to firms with very different annual revenue.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 1 

### 1 INTRODUCTION

1.1 BACKGROUND

On December 18, 2008, EPA finalized new permitting requirements for discharges incidental to the normal operation of a vessel into inland waters or the 3 mile territorial sea of the United States under the National Pollutant Discharge Elimination System (NPDES) ( 73 CFR 117 ) . The 2008
Vessel General Permit for Discharges Incidental to the Normal Operation of Non- Recreational Vessels (herein referred to as the Vessel General Permit or VGP) covers all non

- recreational non

military vessels of 79 feet or greater, and any non- recreational vessel le ss than 79 feet in length or commercial fishing vessel of any size discharging ballast water

. With the expiration of the 2008 period of coverage, EPA is proposing changes to the VGP for the

next five -year Permit period that will extend from 2013 through 2018.

To obtain authorization under the VGP :

 Vessel operators must meet the VGP eligibility requirements.

 Vessel operators must implement the effluent limits according to the requirements in Part
2 of the VGP , and document the implementation as part of their recordkeeping documentation. If the vessel is equipped to carry ballast water or carries ballast water at any time, it must have a ballast water management plan consistent with part 33 CFR 151.2035(a)(7).

 Operators of some vessels will have to submit NOIs. If a vessel weighs at least 300 gross tons or has the capacity to discharge more than 8 cubic meters of ballast water, the operator must submit a complete and accurate NOI. For operators required to submit NOIs, submission must meet specified submission deadlines. If the vessel is not in one of the aforementioned categories, it automatically receives permit coverage under the VGP and is authorized to discharge in accordance with Permit conditions. The owner of a vessel not subject to NOI requirements must instead maintain a Permit Authorization and Record of Inspection (PARI) form documenting coverage and annual inspections.

Based on an analysis of several vessel data sources (described in Section 2 ), EPA estimated the population of vessels affected by the NPDES requirements. The total count of the domestic flag
vessel population is 58,602. The foreign flag vessel population totals 12,429.

The VGP defines general effluent limits applicable to all discharges; general effluent limits applicable to 27 specific discharge streams; narrative water

- quality based effluent limits; inspection, monitoring, recordkeeping, and reporting requirements; and additional requ irements applicable to certain vessel types

. This report presents EPA’s economic and benefits analyses of
the 2013 VGP

. The economic analysis is being conducted to evaluate the costs that may be incurred by vessel owners in complying with additional requirements of the 2013 VGP and
inform EPA’s assessment of the practicality of the technologies and practices specified in theEconomic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 2 permit. 5 The analyses focus on changes to the VGP requirements, relative to requirements
contained in the 2008 Permit

, which may result in incremental cost (positive or negative) for
vessel owners. The cost estimates for the 2008 VGP were documented in the Economic and Benefits Analysis of the Proposed Final Vessel General Permi t (EPA, 2008). Though the issuance of this permit is no t a Federal regulation, EPA is conducting these analyses to analyze the
associated burden of this permit on all entities, and in particular small entities

.

1.2 REPORT ORGANIZATION

This report is organized in seven sections and two appendices, as follows:

Sec tion 2 : Population of Affected Vessels presents an assessment of the numbers and types of vessels likely to be affected by the new permitting requirements.

Section 3 : Profile of the Water Transportation, Fishing, and Mining Industries provides an economic profile of the sectors that have vessels subject to the VGP.

Section 4 : Cost of Best Management Practices presents EPA’s analysis of compliance costs to
commercial vessels associated with each of the practices identified by EPA in the 2013 VGP at
the vessel level . This chapter also presents an estimation of national

- level industry compliance

costs.

Section 5 : Analysis of Impacts on Firm Revenues and Financial Performance presents EPA’s assessment of the cost and economic impact of regulatory requirements on firms that own or operate vessels covered by the VGP , and the implications of the Permit in terms of the financial viability of these firms

.
Section 6 : Benefits Analysis presents EPA’s assessment of the environmental effects associated with vessel discharges and the benefits of reducing these discharges.

5 In developing the VGP, EPA evaluated best practicable technologies currently available (BPT) . Cost is one of several considerations in determining practicability

.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 3 

### 2 POPULATION OF AFFECT ED VESSELS

The VGP is applicable to discharges incidental to the normal operation of a vessel into the navigable waters within the meaning of the Clean Water Act (CWA) Section 502(7). V essels operating in a capacity of transportation are eligible for coverage under the VGP . The types of
vessels covered under the VGP include commercial fishing vessels, cruise ships, ferries, barges, mobile offshore drilling units, oil tankers or petroleum tankers, bulk carriers, cargo ships, container ships, other cargo freighters, refrigera nt ships, research vessels, emergency response vessels, including firefighting and police vessels, and other vessel s operating in a capacity of transportation. Vessels of the armed forces of the United States are not eligible for coverage by this permit as they are subject to Uniform National Discharge Standards (UNDS) under Section 312(n) of the CWA

. While all non -recreational, non- military vessels may seek coverage under this permit, the permit requirements are generally targeted to vessels that are at least 79 feet in length . A separate, streamlined permit is available for vessels less than 79 feet (Small Vessel General Permit for Discharges Incidental to the Normal Operation of Vessels Less Than 79 Feet ). Consequently, the analysis of the impacts of the VGP considers the population of vessels 79 feet or greater in length only

. EPA used the following data sources to estimate the population of affected vessels:

 Domestic flag vessels : The Marine Information for Safety and Law Enforcement (MISLE) and Waterbo rne Transportation Lines of the United States (WTLUS) databases provided information on the number and type of domestic flag vessels subject to the
Vessel General Permit.

 Foreign flag vessels : The Foreign Vessel Traffic Entrance and Clearance records of U .S. Customs and Border Protection provided information on the number and type of foreign flag vessels operating in the navigable waters of the United States.

 Vessels subject to ballast water management requirements : USCG estimated the number
of domestic a nd foreign vessels that potentially subject to ballast water requirements (USCG, 2008). Additional data were obtained from the National Ballast Information Clearinghouse (NBIC) on U.S. port calls, traffic patterns, ballast capacity, whether a
vessel declar ed ballast water on board, and whether ballast water exchange was performed for calendar years 2009 and 2010 (January 1, 2009 through December 31, 2010).

EPA also used information that was previously compiled for the analysis of the 2008 VGP. This includes information provided by the Cruise Line International Association (CLIA) on the number and size of cruise ships operating in U.S. waters.

2.1 DOMESTIC VESSEL POPULATION

EPA used three data sources to determine the population of domestic flag vessels: (1) the MISLE database compiled by the U.S. Coast Guard (USCG, 2009), (2) the WTLUS data file compiled by the Waterborne Commerce Statistics Center (WCSC) of the U.S. Army Co rps of Engineers (USACE) Navigation Data Center (NDC) (USACE, 2009), and (3) information submitted by theEconomic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 4 International Association of Drilling Contractors (IADC), which provided a vessel count of 131

MODUs as part of EPA’s analysis of the 2008 VGP.

MISLE provides a wide range of information regarding vessel and facility characteristics, accidents, marine pollution incidents, and other information pertinent to U.S. Coast Guard operations . MISLE includes data for a total of nearly 1 million vessels that oper ate in U.S. waters. The database covers a wide ensemble of vessels (e.g., recreational vessels, commercial fishing vessels, freight barges, tank barges, tank ships, passenger vessels, utility vessels), and provides
data on various characteristics for each individual vessel. These data include: Identification number(s); Vessel category (e.g., class, type, subtype, service); Size (e.g., tonnage, length, breadth, depth); Area of operation (e.g., hailing port, route type); Passenger and crew capacity; Propulsion (i.e., method, engine type, and horsepower) ; Construction material and design (e.g., hull material, design type, hull configuration/shape) ; Year built or age

.
WTLUS is a three -volume annual product that provides both an inventory of vessel companies, along with their American flag vessels operating in the transportation of freight and passengers, and a national summary of all vessels. The database lists the vessel companies in alphabetical sequence and provides each vessel’s name and number; Coast Guard number; net tonnage; Vessel Type, Construction, and Characteristics (VTCC) code and International Classification of Ships by Type (ICST) code; register and overall length and breadth; loaded and light draft; horsepower; carrying capacity in short tons or units of cargo and number of passengers; height of fixed superstructures; cargo handling equipment; operating headquarters; and year built or rebuilt.

To estimate the domestic vessel population subject to the VGP , EPA created a master database by combining the MISLE and WTLUS data files. The combined database allows the Agency to obtain a comprehensive estimate of the vessel population and to minimize the number of missing
data fields for any given vessel

. 6 The Coast Guard number, which serves as the unique vessel identifier, was used to merge the databases. EPA used the MISLE data as the base of the population and, as a general rule, used the majority of the data fields contained therein, inputting
similar data attributes from WTLUS into this format. As sho wn in Table 2-1, the estimated number of domestic flag vessels subject to the Vessel General Permit is 58,602.

6 For example, EPA used values reported in WTLUS to fill in missing MISLE information regarding vessel type, length, and gross tonnage for vessels reported in both databases.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 5 Table 2-1. Domestic Vessel Population

Vessel Type Total Domestic Vessels

Count a Percentage of Vessels Commercial Fishing b 2,326 4% Freight Barge 39,760 68% Freight Ship 812 1% Passenger Vessel 1,970 3% Tank Barge 7,144 12% Tank Ship 332 1% Utility Vessel 6,258 11%
Total 58,602 100%

Source: D etermined from data compiled by the U. S. Coast Guard, MISLE database, 2009 and by USACE, WTLUS 2009

. a I ncludes vessels 79 feet or greater with status noted as “active”, “unknown”, “laid up” or without

status . Excludes vessels identified as dupl icate records in the vessel name field . Vessels with unspecified type were assigned to a vessel type based on relative shares of vessel types.

b A separate estimate provided by U.S. Coast Guard personnel suggests that commercial fishing
vessels 79 feet lo ng or greater number approximately 1,800 to 1,900 vessels. 7

This analysis examine s the following vessel population groups, defined by MISLE and WTLUS categorizations:

 Commercial Fishing . Includes fish catching, fish processing, and other fishing vessels.

 Freight Barge . Includes open and covered hopper barges, car floats, flat/deck barges, pontoon barges, open and covered dry cargo barges, container barges, lash barges, and convertible barges.

 Freight Ship . Includes general cargo freighters, break bulk car riers, roll -on/roll- off (RO

RO) carriers, container ships, partial container ships, refrigerated ships (reefer), and
vehicle carriers.

 Passenger Vessel . Includes cruise ships, combination passenger and cargo ships, ferries, railroad car ferries, excursion and sightseeing vessels, and passenger barges.

 Tank Ship . Includes petroleum, chemical, and liquid gas carriers, and liquid bulk tankers.

 Tank Barge. Includes liquid cargo barges that are single hull, double hull, double sided only, and double bottom only.

 Utility Vessel . Includes crew boats, mobile offshore drilling units, offshore supply vessels, industrial vessels, oil recovery vessels, research vessels, school ships, push boats, and tug/towing vessels.

As shown in Table 2-1

, freight barges ( 68 percent), tank barges (12 percent), and utility vessels (11 percent ) account for the majority of domestic vessels eligible for coverage under the VGP.

7 Personal communication with Jack Kemerer, Fishing Vessel Safety Program, May 26 , 2009

.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 6 2.2 FOREIGN VESSEL POPULATION

The Foreign Traffic Vessel Entrances and Clearances (FTVEC) database provides information on foreign vessels entering or clearing U.S. Customs ports in calendar year 2008, the most recent year for which data are published (U.S. Army Corps of Engineers, 2010). The data are compiled by the U.S. Army Corps of Engineers from information originally collected by U.S. Customs and
Border Protection. They include entrance/clearance characteristics such as the date a vessel made entry into or clear ed the U.S. Customs port or waterway, as well as vessel characteristics such as the name, type by rig or ICST code, flag of registry, last (for entrances) or next (for clearances) port of call, whether foreign or domestic, Net and Gross Registered Tonnage, and draft in feet. The database includes both foreign flagged and domestic vessels. However, only foreign flagged vessels are included in the estimate of the foreign vessel population. The estimate of the foreign vessel population also excludes several other Permit

- exempt boats. EPA estimates that 12,429 foreign flagged vessels are subject to the VGP requirements

. EPA used ICST codes to group foreign flagged vessels into the classes used in the analysis of the domestic vessel population (i.e., commercial f ishing, freight barge, freight ship, passenger vessel, tank barge, tank ship, and utility vessel). Table 2-2 presents the number of foreign flagged vessels by vessel class. As shown in Table 2-2

, the majority of foreign flagged vessels entering U.S. ports are freight ships ( 66 percent), followed by tank ships (27 percent). Of the 12,429 foreign flagged
vessels that entered U.S. waters in 2008, 12,351 weigh more than 300 gross registered tons and therefore needed to submit an NOI to EPA based on this applicability criterion. This number appears generally consistent with the number of NOIs that were actually submitted in the following year. For instance, eNOI data as of August 2010 show that 13,832 foreign vessels submitted an NOI electronically in the 13 months during which the NOI system had been in place. Since vessel owners do not need to re -submit an NOI upon returning to the United States from an overseas voyage , the number of NOI submitted in any given year is expected to be only a fraction of the number of vessels that enter U.S. waters during the year

.

Table 2-2. Foreign Vessel Population.

Vessel Type Total Foreign Vessels

Count Percentage of Foreign Vessels
Commercial Fishing 47 <1% Freight Barge 149 1% Freight Ships 8,218 66% Passenger Vessel 225 2% Tank Barge 25 <1%

Tank Ships 3,375 27% Utility Vessel 389 3%
Total 12,429 100%

a The count of vessels required to submit an NOI is based on data reported in the Foreign Traffic Vessel Entrances and Clearances database. Only vessels greater than 300 gross tons are assumed to be required to submit an NOI

. Data from EPA’s eNOI system indi cate that 13,832 vessels had submitted an NOI through August 5, 2010.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 7 The foreign flagged vessels are excluded from the analysis of the total costs of implementing pollution prevention and control practices for the relevant discharge categories because t he cost to foreign flagged vessels does not have a direct impact on U.S. firms.

2.3 VESSELS SUBJECT TO N OI REQUIREMENTS

The VGP requires owners of vessels meeting the requirements under Part 1.5.1.1 (300 gross tons or greater or has the capacity to hold or discharge more than 8 cubic meters of ballast water) to
submit an NOI to EPA to receive permit coverage. In the case of vessels that were authorized to discharge under the 2008 VGP, the NOI must be submi tted within 6 months of the effective date of the revised VGP, while vessels not previously covered must submit an NOI at least 30 days before discharging into waters subject to the permit.

EPA estimated the number of vessels required to submit an NOI (e.g ., vessels greater than

300 gross tons) using the data sources described above for domestic and foreign vessels and
information available from the vessels that submitted an NOI under the 2008 VGP.

As of August 2010, EPA had received 43,110 NOIs for active vessels, including 29,278 domestic and 13,832 f oreign vessels. These numbers are generally consistent with foreign vessels
characterized in the FTVEC databases

, which show vessels greater than 300 gross tons numbering 12,351 . The number of NOI s received i s lower than the 48,502 vessels

MISLE /WTLUS identifies as 300 gross tons or greater

. The difference may be due to inactive vessels being included in MISLE. 8 Table 2-3 summarizes the counts of domestic and foreign vessels that may be required to submit an NOI to obtain coverage under the 2013 VGP.

8 MISLE does not report the status of 29,736 vessels. EPA conservatively assumed that these vessels are active and may potentially seek coverage under the 2013 VGP.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 8 Table 2-3 : Population of Vessels Required to Submit an NOI.

Vessel Type Domestic Vessels Required to
Submit NOI a Foreign Vessels Required to Submit

NOI b

Count Percentage of
NOIs for
Domestic Vessels Count Percentage of
NOIs for Foreign
Vessels Commercial Fishing 463 1% 42 <1% Freight Barge 37,516 77% 147 1% Freight Ships 668 1% 8,202 66% Passenger Vessel 301 1% 225 2% Tank Barge 6,466 13% 24 <1% Tank Ships 283 1% 3,374 27% Utility Vessel 2,805 6% 336 3%
Total 48,502 100% 12,351 100%

Source: Determined from data compiled by the U. S. Coast Guard, MISLE database, 2009 ; USACE, WTLUS 2009 ; and
USACE FTVEC 2008

. Estimates are based on the number of vessel 300 gross tons or greater

.

a Count based on the number of vessels 300 gross tons or greater

. Data from EPA’s eNOI system indicate that 29,278 domestic vessels had submitted an NOI through August 5, 2010.

b The count of vessels required to submit an NOI is based on data reported in the Foreign Traffic Vessel Entrances and Clearances database. Only vessels 300 gross tons or greater are assumed to be required to submit an NOI. Data from EPA’s eNOI system indicate that 13,832 foreign vessels had submitted an NOI through August 5, 2010.

2.4 VESSELS SUBJECT TO T HE BILGE WATER TREATMENT REQUIREMEN TS

The VGP contains requirements to limit the discharge of oily bilge water . For vessels greater than 400 gross tons, the P ermit authorizes the discharge of oily bilge water provided that these discharges meet specified conditions for maximum oil content, monitoring, and alarms.

EPA estimated the number of vessels greater than 400 gross tons using the data sources described

a bove for domestic and foreign vessels. The data are summarized in Table 2-4

.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 9 Table 2-4 : Population of Ve ssels Greater than 400 Gross Tons

.

Vessel Type Domestic Vessels Greater than 400

Gross Tons Foreign Vessels Greater than 400

Gross Tons
Count Percentage of
Domestic Vessels Count Percentage of Foreign Vessels Commercial Fishing 405 1% 41 0% Freight Barge 36,764 78% 145 1% Freight Ships 663 1% 8,198 67% Passenger Vessel 275 1% 223 2% Tank Barge 6,286 13% 24 0% Tank Ships 281 1% 3,374 27% Utility Vessel 2,474 5% 312 3%
Total 47,148 100% 12,318 100%
Source: Determined from data compiled by the U. S. Coast Guard, MISLE database, 2009 ; USACE, WTLUS 2009 ; and
USACE FTVEC 2008

.

2.5 VESSELS SUBJECT TO T HE BALLAST WATER MAN AGEMENT REQUIREMENTS

The VGP contains requirements to minimize the risk of introducing invasive species into waters
of the U.S. from ballast water discharges . The performance requirements are similar to those proposed by the U.S. Coast Guard for the “Phase I discharge standard” , which follow the International Maritime Organization (IMO ) “Reg ulation D- 2” standard of the Ballast Water Management Convention (USCG, 2009). These standards are described later in this report (Section 4.2.3 ). 9 The 2013 VGP als o specifies additional monitoring, sampling, testing, and reporting requirements for vessels with ballast water treatment systems (BW T S).

The USCG National Ballast Information Clearinghouse provides data from ballast water reports submitted to the USCG by all ballast tank

- equipped vessels bound for ports or places of the U.S., in accordance with the National Invasive Species Act of 1996, P.L. 104-332 (NBIC, 2011). This includes those ships that declare no ballast onboard (NOBOB) and ships not discharging ba llast

water . The NBIC database provides information on each arrival, including vessel name and type, port, state, arrival date, the vessel’s last port of call

, and information on ballast water management practices (i.e., ballast capacity, volume discharged, whether ballast water exchange was performed, and treatment methods). For calendar years 2009 and 2010, the database has data for 164,235 arrivals by 8,610 vessel s. No ballast water discharge was reported for a pproximately 70 percent of arrivals (112,841 arrivals by 3,27 9 vessels ). For vessels that reported discharging

9 The standards specify the following maximum discharge limits: (1) For organisms greater than or equal to 50 micrometers in minimum dimension: discharge must include fewer than 10 living organisms per cubic meter of ballast
water; (2) For organisms less than 50 micrometers and greater than or equal to 10 micrometers: discharge must

inc lude fewer than 10 living organisms per m illiliter (mL) of ballast water; (3) Indicator microorganisms must not
exceed: (i) For Toxicogenic Vibrio cholerae (serotypes O1 and O139): a concentration of less than 1 colony forming unit (cfu) per 100 mL (ii) Fo r Escherichia coli: a concentration of fewer than 250 cfu per 100 mL (iii) For intestinal enterococci: a concentration of fewer than 100 cfu per 100 mL.

.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 10 ballast water (5,331 vessels), about 4,012 vessels conducted ballast water exchang e by emptying

a nd refilling their tanks (3,443 vessels) and/or using a flow -through exchange method (1,857 vessels). Finally, 76 vessels reported using an alternative ballast management system approved
under the USCG Shipboard Technology Evaluation Program (STEP). While the NBIC database provides a unique identifier ( IMO Number ) for each vessel that submitted ballast water management reports, the corresponding field in the MISLE/WTLUS database is often empty (these databases generally use the Coast Guard vessel number to uniquely identify each vessel). Because of these data gaps, EPA was able to match only a small subset of the NBIC records (approximately 800 domestic vessels) to corresponding records in MISLE/WTLUS.

Instead, EPA used estimates developed by USCG for the number of vessels potentially affected by ballast water discharge standards, by type of vessel (USCG, 2008). These estimates exclude vessels that are unlikely to have ballast water tanks, namely those vessels less than 100 feet in length and certain vessel types (e.g., towing vessels, river vessels, crew boats , barges ). 10 Since these estimates were developed in 2007, we applied net growth rates assumed in the USCG analysis for each vessel type to estimate the vessel population in 20 09, consistent with the dat a provided in the MISLE/WLUS database

. As shown in Table 2-5

, a total of 8,148 vessels as estimated to be potentially subject to the VGP ballast water requirements, including 2,878 domestic vessels and 5,269 foreign vessels . The estimate is consistent with the number of unique vessels that submitted ballast water management reports to NBIC in calendar years 2009 and 2010: 8,609 vessels

.
The 2,878 domes tic vessels potentially subject to the ballast water requirements represent approximately 5 percent of the total number of vessels covered by the 2013 VGP, but account for essentially all freight ships and significant shares of commercial fishing vessels ( 35 percent), tank ships ( 19 percent) and passenger vessels (9 percent)

.

10 This is reflected in the NBIC data for 2009 and 2010. Bulker and tanker vessels represented 57 percent of vessels that submitted ballast water management reports to NBIC. General cargo and container vessels accounted for another 24 percent. Other vessels included RoRo (6 percent of vessels), reefer (3 percent), passenger (2 percent) and other/unspecifie d vessels (8 percent).Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 11 Table 2-5 : Population of Vessels Subject to Ballast Water Requirements

.

Vessel Type Domestic Vessels Subject to Ballast

Water Requirements Foreign Vessels Subject to Ballast Water Requirements
Count Percentage of
Domestic Vessels Count Percentage of Foreign Vessels Commercial Fishing 819 28% 18 0%
Freight Barge Freight Ships a 1,672 58% 1,560 30%
Passenger Vessel 185 6% 144 3%
Tank Barge Tank Ships b 102 4% 3,491 66%
Utility Vessel c 101 3% 57 1%

Total 2,878 100% 5,269 100%

Source: USCG (2008). See Table 2.2. The number of vessel was projected from the 2007 estimates using growth and replacement rates provided in Table 2.3.
a Category includes container ships, RoRo, combination vessels, and general cargo vessels. The number of freight ships estimated to be potentially subject to the ballast water requirements exceeds the total number of freight ships in
the MISLE/WTLUS database

. b Category includes bulk carriers, tank ships, gas carriers, and chemical carriers.
C Category includes offshore supply vessels.

Because the 2013 VGP provides several ballast water management options in addit ion to onboard treatment ( use onshore treatment, carry freshwater ballast, hold while in regulated waters) , it is likely that only a subset of the 8,148 vessels subject to the requirements will choose to install a

BWTS. At present , not all ballast tank -equipped vessels required to submit a report to the USCG actually discharge ballast water in U.S. waters. The number of vessels that reported any ballast water discharge to the NBIC in 2009 and 2010 ( 5,331 vessels ) wa s significantly less than the total
number of ballast tank- equipped vessels that submitted reports. USCG’s estimates of the number of vessels subject to ballast water requirements therefore likely overestimate s the number of vessels that would ultimately need to install a BWTS or chose this approach to manage their ballast water discharge . According to an analysis conducted by King et al. (2010), only about 1,239 U.S. flag vessel would be subject to the ballast water treatment standards, or less than half
the number of vessels estimated using USCG (2008) figures

. In developing these estimates, King
et al. considered factors such as the subtypes of vessels that carry ballast water, ballast water capacity, and area of operation. 11

11 For example, King et al. (2010) excluded commercial fishing vessels less than 300 gross tons and vessels that operate within one captain of the port zone. They also excluded vessels that routinely treat less than 70,000 metric

tons of ballast water annually as these vessels were determined to be more likely to use another method to comply with discharge regulation (exchange where allowed, take on freshwater, or foregoing discharge when in regulated waters). Similarly, commercial fis hing vessels less than 300 gross tons were determined to be unlikely to use onboard ballast water treatment and more likely to use some other method to comply with discharge regulations.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 12 2.6 UNCERTAINTIES AND LI MITATIONS

This section discusses limitations and uncertainties in the estimation of the affected vessel population. Whether these limitations and uncertainties, taken together, are likely to lead to an understatement or overstatement of the estimated vessel population is not known.

The domestic vess el populatio n was estimated using the MISLE database, supplemented with
data from WTLUS . The main limitations of the MISLE data include: 12

 Incomplete data

. While MISLE represents the most comprehensive national dataset currently available, it does not captu re the entire universe of vessels operated on U.S.

waters. O nly limited information is available for certain classes of vessels due to the way in which vessel data are gathered since these vessels are not subject to documentation or regular inspection requ irements. In compiling MISLE data, the U.S. Coast Guard largely relies on documents submitted by vessel owners or operators in accordance with vessel documentation requirements (e.g., certificate of documentation) or on information gathered by U.S. Coast Guard staff directly (e.g., during inspections, vessel boardings, or accident investigations). 13 T he scope of the MISLE database is not limited to a certain size or class of vessel, but the content of the database is nonetheless driven in part by the regulatory requirements to which different types of vessels are subject or by activities conducted by Coast Guard offices. MISLE therefore, is generally considered to be most comprehensive for those vessels that are documented, state registered, and/or subject to inspection requirements. Data omissions are believed to affect primarily recreational and
smaller commercial vessels

. Since the VGP is targeted to larger, non

- recreational vessels 79 feet or greater in length, EPA believes that the MISLE data limitations are not consequential for this analysis.

 Missing or outdated data. While MISLE captures a wide range of characteristics for each vessel it records, the information is at times incomplete (e.g., length may be missing or
recorded as zero) or may be outdated (e.g., a vessel may no longer be operating while its status in the database may not have been updated). Even after merging databases and using methods to maximize the amount of available data, several data fields remained with non-negligible deficiencies. Some but not all of these fields were populated using assumptions. For example, EPA conservatively included in the potentially affected vessel population a proportional share of vessels for which the length was unknown and all

ves sels that met the VGP applicability criteria. By including all vessels in MISLE even when these vessels were not also reported in WTLUS, EPA generally erred on the side of a more inclusive VGP population. It is likely, however, that some vessels recorded i n MISLE are no longer active and therefore the vessel population may be overestimated.

12 See EPA (2010) for a more detailed discussion of the limitations of MISLE data

.

13 Th e MISLE database incorporates data reported separately in VESDOC for documented vessels

. VESDOC is a data file of merchant and recreational vessels documented under the laws of the United States by the U.S. Coast Guard.
That dataset was us ed for the economic analysis of the 2008 VGP (Abt Associates, 2008).Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 13  Conflicting vessel classifications. A relatively small number of vessels were found to be classified by MISLE and WTLUS differently. In these cases EPA used the WTLUS
cl assification and ignored the classification provided in MISLE since the WTLUS data are published and therefore assumed to have been subjected to closer accuracy review

.  Estimate of vessels required to submit an NOI: The count of vessels required to submit an NOI is a conservative estimate since data on gross tonnage are not complete. Thus, this count is based on the number of vessels that are either >78’ in length or >299 Gross

Tons.

The estimated number of f oreign vessels affected by the VGP was estimated using vessel
entrances and clearances data for 2008 . The data source does not include vessel length. EPA imputed the vessel length based on a relationship previously derived between tonnage (as gross registered ton) and length (in feet) for different class es of vessels , based on NOI data (see EPA, 2010b) . It is possible that some vessels are larger or smaller than estimated using the relationship.

The estimated number of vessels affected by the ballast water management requirements is based

on estimates dev eloped by the USCG (2008), complemented by information from NBIC (2011). NBIC identifies vessels by their IMO number as compared to the Coast Guard identifier used in
the MISLE/WTLUS databases. Because of the different identifiers, EPA was not able to matc h a significant fraction of the NBIC records to MISLE/WTLUS and therefore used USCG estimates as the primary information source. While the number of vessels estimated to be potentially subject to ballast water requirements is generally similar to vessels t hat submitted reports to the NBIC in 2009 or 2010, the number is greater than the number of vessels that reported any ballast water discharge during the two years . Therefore, the number possibly overestimates the vessels
that would need to implement additional practices to comply with ballast water requirements in
the 2013 VGP. Further, only a subset of vessels that presently discharge ballast water will install ballast water treatment systems and would have to implement the related permit practices.

Finally, the estimate of the population of affected vessels is also subject to the reporting accuracy of the data providers. Typographical errors and incorrect entries (including potential duplicate entries) exist to an unknown extent. Those that were discovered were corrected

.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 14 

### 3 P ROFILE OF THE W ATER T RANSPORTATION, F ISHING, AND MINING

I NDUSTRIES

3.1 I NTRODUCTION

The water transportation, fishing, and mining industries consist of the establishments that own and operate the commercial vessels subject to the revised VGP

. This section describes the characteristics of these industries that may be relevant to evaluating the economic impacts of revised permit requirements.

According to the Bureau of Transportation Statistics (BTS), maritime transportation carries over three quarters of the weight of all U.S. international freight, and 14 percent of all commercial freight in the United States. While domestic waterborne ton -miles and tonnage declined in the period of the early 1990s through 2003, the value, tons, and ton- miles as international trade grew during this period.

As of 2007, the water transportation industry was a $34 billion industry that employ ed nearly 150,000 people on a payroll of just over $6 billion. The fishing industry was much smaller, with total revenues of $1.65 billion, employing just over 6,500 people on a payroll of $253 million. The drilling oil an d gas wells sector (a subset of the mining industry) was a $9 billion sector that employs nearly 60,500 people on a payroll of approximately $2.5 billion.

Water transportation accounts for a majority of the vessels sailing on U.S. waters and is made up
of several industry sectors, described in Section 3.2.2 : Water Transportation . Overall, the industry has experienced mild growth in the number of establishments, revenues, and payroll, but a decline in the number of employees.

The fishing industry is responsible for slightly more than a quarter of all commercial vessels in
the United States , although a relatively small fraction of these vessels are greater than 79 feet and would therefore be covered under the VGP. The industry has experienced a declin e in the number of establishments, employees , and payroll, although it s revenue grew

. The drilling oil and gas wells sector, which covers the 131 MODUs covered by the VGP, has experienced robust growth, demonstrating a 15 per cent increase in revenues from 2002 to 200 7. 14

The number of domestic vessels operating in U.S. waters has remained relatively constant over the last few years, with the total number of documented vessels going from 39, 641 vessels in 2000, to 41,354 in 2005, and 40,301 in 2008, the most recent year with published statistics (USACE, 2009).

14 The 131 MODUs only account for a small percentage of establishments reported in the 2007 Economic Census for the drilling oil and gas wells sector overall: 131 out of 2,109 establishmen ts. Other establishments classified in the drilling oil and gas wells sector conduct operations that do not involve the use of MODUs; for example, these firms may drill oil and gas wells on land.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 15 3.1.1 D ATA S OURCES U SED

EPA developed overviews of the various industry sectors using information from industry groups, trade associations, and other reference sources.

Data for the number of vessels were ext racted from the combined vessel information of MISLE
and WTLUS (detailed further in Section 2 : Population of Affected Vess els ) and from information submitted by the IADC on the number of MODUs

. NAICS codes were assigned to vessels according to the NAICS codes of their owner/operators, which were obtained from the Dun & Bradstreet (2006) , ReferenceUSA (2006) or manta.com databases. In selected instances where it was not possible to match a vessel owner or operator to a record in these other databases , EPA assigned the most likely NAICS code based on key words in the reported name of the vessel
owner where it could do so with reasonable confidence. 15 In cases where owner/operator information was unavailable, no corresponding entry could be found in the business databases, or the name of the owner was not descriptive enough to assign a NAICS sector, the most likely NAICS code was assigned to a vessel using information on vessel type and area of operat ion. Finally, any remaining unassigned vessels were distributed to the NAICS sectors proportionally to the population analyzed for the 2008 VGP (EPA, 2008).

Overviews of the various industry sectors were developed using information from industry
groups, tr ade associations, and other reference sources. Data for numbers of firms, establishments, revenues, and employment were obtained from the U.S. Census Bureau and are current as of 2007, with the exception of data for NAICS code 11411: Fishing which is not

c overed by the Economic Census. In this case, the data come from the U.S. Small Business Administration (SBA).

3.1.2 ORGANIZATION O F T HIS C HAPTER

This chapter presents an overview of the water transportation, fishing, and mining industries.

Section 3.2 provides definitions and overviews of the industries and their sectors, as well as the number of vessels associated with each industry, as classified by NAICS.

Section 3.3 summarizes recent trends in these industries, including changes in the number of establishments and financial performance.

Section 3.4 describes the industries’ market structures, including details of performance according to employment size, numbers and percentages of small businesses, employment trends, and payroll trends.

15 For example, companies whose name contained the terms “charter”, “tour”, or “adventure” were associated with establishments operating in the sector NAICS 487210: Scenic and S ightseeing T ransportation, W ater

.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 16 3.2 O VERVIEW OF THE W ATER T RANSPORTATION, F ISHING, AND M INING

I NDUS TRIES

3.2.1 D EFINITION OF THE W ATER T RANSPORTATION, F ISHING, AND M INING

I NDUSTRIES

The water transportation industry, for the purpose of this chapter, includes NAICS codes 483 : Water Transportation; 4872 : Scenic and Sightseeing Transportation, Water; and 4883 : Support Activities for Water Transportation. The fishing industry includes NAICS 1141 : Fishing. The mining industry includes NAICS 213111 : Drilling oil and gas wells

. Table 3 -1 lists the relevant NAICS codes for the water transportation, fishing, and mining industries.

Table 3-1

. Principal 200 7 NAICS Codes and Descriptions Relevant to Vessels Covered by the

VGP

.

Industry Group/NAICS Code Description Fishing

1141 Fishing

114111 Finfish Fishing

114112 Shellfish Fishing

114119 Other Marine Fishing Water Transportation

4831 Deep Sea, Coastal, and Great Lakes Water Transportation

483111 Deep Sea Freight Transportation

483112 Deep Sea Passenger Transportation

483113 Coastal and Great Lakes Freight Transportation

483114 Coastal and Great Lakes Passenger Transportation

4832 Inland Water Transportation

483211 Inland Waterways Freight Transportation

4832 12 Inland Waterways Passenger Transportation

4872 Scenic and Sightseeing Transportation, Water

4883 Support Activities for Water Transportation

488310 Port and Harbor Operations

488320 Marine Cargo Handling

488330 Navigational Services to Shipping and Salvage

488390 Other Support Activities for Water Transportation Support Activities for Mining

2131 Support Activities for Mining

213111 Drilling Oil and Gas Wells sector

213112 Support Activities for Oil and Gas Operations

Source: U.S. Census Bureau, 2007

3.2.2 W ATER T RANSPORTATION

Establishments in the water transportation industry provide water transportation of passengers and cargo using watercraft, such as ships, barges, and boats. The industry is composed of two industry groups: (1) one for de ep sea, coastal, and Great Lakes water transportation; and (2) oneEconomic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 17 for inland water transportation. This split typically reflects the difference in equipment used (U.S. Census Bureau, 2007a ).

Scenic and sightseeing water transportation services are also in cluded under this industry heading, as are support activities for water transportation. These two industry groups are technically classified outside of Water Transportation (NAICS 483) by the Census Bureau, but

are included under water transportation for t he purposes of this chapter.

Total waterborne commerce in the United States has increased steadily over the past 50 years, fueled mostly by growth in foreign commerce, which overtook domestic shipments (in terms of weight) in the mid -1990s. Foreign commerce accounted for over 60 percent of total waterborne commerce by weight in 2009, amounting to 1.4 billion short tons out of total U.S. waterborne
commerce of 2. 2 billion short tons (USACE, 2009)

.

DEEP SEA, COASTAL, A ND GREAT LAKES WATER TRANSPORTATION
This industry group comprises establishments primarily engaged in providing deep sea, coastal, and Great Lakes water transportation, as well as transportation via the St. Lawrence Seaway. Marine transportation establishments using the facilities of the St. Lawrence Seaway Authority Commission are considered to be using the Great Lakes Water Transportation System (U.S. Census Bureau, 200 7a ). Firms in this NAICS grouping are further classified based on their area of operation (deep sea or coastal/Great Lakes) and payload type (cargo or passengers).

Deep Sea Freight Transportation
The businesses in this industry sector are primarily engaged in providing deep sea transportation of cargo to or from foreign ports. This sector encompasses oceangoing barges, oil tan kers, and other large freight vessels (U.S. Census Bureau, 2007a). A large portion of U.S. foreign trade merchandise (1 .4 billion metric tons) is transported via water, making this sector the cornerstone
of U.S. international trade.

Because of its close relationship to international trade, deep sea freight transportation has been increasing steadily over the past 20 years, driven by increasing imports to the United States from foreign ports.

Over the last half -century, the United Sta tes’ merchant fleet has declined in number . Though the U.S. vessel fleet has shrunk, it has also become more efficient, with today’s merchant vessels carrying 40 percent more cargo and requiring fewer crew members (Transportation Institute, undated).

Deep Sea Passenger Transportation
Establishments in this sector are primarily engaged in providing deep sea transportation of passengers to or from foreign ports (U.S. Census Bureau, 200 7a ). The most common type of deep sea passenger transportation is the cruis e ship.

This leisure

- based industry sector is more vulnerable to economic fluctuations, since its revenues draw on discretionary consumer spending. The global economic crisis and recession greatly reduced consumers’ disposable income and thus their leisure spending (U.S. BEA, 2011a). It is likely that the scenic and sightseeing transportation sector was impacted by the recession

.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 18 Coastal and Great Lakes Freight Transportation
Firms transporting cargo in coastal waters; the Great Lakes System (including t he St. Lawrence Seaway); or deep seas between ports of the United States, Puerto Rico, and U.S. island possessions or protectorates fall into this NAICS code classification (U.S. Census Bureau, 2007a).

The Jones Act of 1920 requires that all domestic water borne trade (between two points in the United States) be conducted on vessels built in the United States, documented in the United States, and owned by U.S. citizens or companies (Transportation Institute, undated). V essels operating in the Coastal and Gre at Lakes Freight Transportation sector are subject to this law.

The majority of the vessels in this sector are barges, though the sector is also characterized by its use of other freight transport vessels, as well as tugboats (Transportation Institute, un dated). In the Great Lakes, the transportation system comprises bulk cargo carriers, ocean going vessels and smaller cruise ships

. Coastal domestic trade to and from Alaska, Hawaii, and U.S. Territories consists mainly of the shipment of petroleum and petroleum products, chemicals, and agricultural products. The primary products transported on the Great Lakes System are coal, limestone, and iron ore (Transportation Institute, undated; Quinn, 2002). A relatively large share of these vessels is expected to be greater than 79 feet in length and therefore subject to the VGP.

Coastal and Great Lakes freight transportation accounts for nearly 30 percent of all U.S. domestic waterborne shipments by weight in 2009, or 857 million short tons. Coastal and Great Lakes freight transport accounts for almost 90 percent of all self-propelled traffic, but only 13% of barge traffic by weight (USACE, 2009). Great Lakes freight transportation (domestic and foreign) was relatively constant from 1990 to 2005, ranging between 150 and 200 million short tons per year

. Tonnage decreased below 150 million tons in 200 7 and was significantly less in 2009, at about 100 million tons (USACE, 2009). Generally, approximately two- thirds of Great Lakes tonnage is
domestic freight and one-third is foreign (this pattern remained even after the decline in tonnage) (USACE, 2009).

Coastal freight transportation experienced the same post -2005 decline with 1. 4 billion tons shipped in 2009, down from 1.6 billion shipped in 2006. This reversed the growing trend
observed between 1990 and 2005 when coastal freight transportation increased from around 1.1 billion tons per year to more than 1.6 billion tons, as a result of increased foreign shipments (USACE, 2009).

Coastal and Great Lakes Passenger Transportation
This industry sector contains establishments primarily engaged in providing water transportation of passengers in coastal waters, the Great Lakes System (including the St. Lawrence Seaway), or deep seas between ports of the United States, Puerto Rico, and United States island possessions and protectorates. This industry sector includes many coastal and Great Lakes ferries used to travel short distances between coastal ports, or from shores to nearby islands, as well as larger
vessels used on the Alaska Marine Highway, which travels between ports on the southern coast of Alaska and northwestern Canada (Reference for Business, 2007c).Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 19 INLAND WATER TRANSPO RTATION
Businesses primarily engaged in providing inland water transportation of passengers and cargo on lakes, rivers, or intracoastal waterways (except on the Great Lakes System) are classified under this NAICS grouping, and are further classified between freight and passenger transportation (U.S. Census Bureau, 2007a).

As required by t he Jones Act, all vessels in this industry sector are domestic flagged and owned.

Inland Waterways Freight Transportation
The companies in this industry sector are primarily engaged in providing inland water transportation of cargo on lakes, rivers, or int racoastal waterways (except on the Great Lakes System) (U.S. Census Bureau, 200 7a ) . This sector contains a large portion of the vessels in the United States, as it encompasses river barges, as well as the tug and towboats that propel them. The vast majorit y of boats in this sector are barges, which outnumber other inland freight vessels by about 10 to 1 (Transportation Institute, undated).

The products carried by this industry sector include more than half of U.S. grain shipments, a quarter of chemical and petroleum exports, and a fifth of domestic coal shipments (Transportation Institute, undated). Barges account for 79 percent of domestic waterborne freight.

Inland waterways freight transportation, similar to Great Lakes and coastal water transportation has experienced a decrease in cargo tonnage since 2006, although prior to this the total tonnage transported had remained constant over the past two decades (USACE, 2009). Nevertheless, inland waterways transport accounts for over 50 percent of all domestic waterborne freight shipments (USACE, 2009).

Inland Waterways Passenger Transportation
This industry sector provides inland water transportation of passengers on lakes, rivers, or intracoastal waterways (except on the Great Lakes System) (U.S. Census Bureau , 200 7a) . This sector includes water taxis and ferries (except coastal and Great Lakes ferries), usually traveling short distances between inland ports, such as in New York harbor or in San Francisco Bay.

The ferry industry has been rebounding from historic lows in the 1970s, and short- distance ferries in urban areas have become alternatives to crowded highways and urban transit systems. In 2000, the 677 ferries operating in the United States served 578 destinations along 352 routes, transporting 113 millio n passengers (these figures include coastal and Great Lakes ferries) (Reference for Business, 2007c).

SCENIC AND SIGHTSEEI NG TRANSPORTATION, W ATER
This industry group comprises establishments primarily engaged in providing scenic and sightseeing transportation on water. The services provided are usually local and involve same- day return to place of origin (U.S. Census Bureau, 2007a).

This sector enc ompasses a wide variety of vessel types, from small “swamp buggies” used to tour the Florida Everglades to chartered dinner cruisers to larger whale -watching boats. The range of services offered has continued to expand over the past decade, with gambling boats becoming popular in Indiana and Iowa, and similar gaming “cruises- to -nowhere” becoming popular in Florida (Reference for Business, 2007d).Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 20 This leisure

- based industry sector is more vulnerable to economic fluctuations, since its revenues draw on discretionary consumer spending. The global economic crisis and recession greatly reduced consumers’ disposable income and thus their leisure spending (U.S. BEA, 2011a). It is likely that the scenic and sightseeing transportation sector was impacted by the recession

.

SUPPORT ACTIVITIES F OR WATER TRANSPORTAT ION
This NAICS grouping includes establishments classified in the following NAICS sectors: 48831, Port and Harbor Operations; 48832, Marine Cargo Handling; 48833, Navigational Services to Shipping and Salvage; and 48839, Other Support Activities for Water Transportation (U.S. Census Bureau, 2002).

Businesses in these sectors are the link between a vessel’s load (cargo or passengers) and that load’s final destination. This sector provides the highest perc entage of employment in the water transportation industry, as many of these services are labor

- intensive.

Port and Harbor Operations
Businesses in this industry sector operate ports, harbors (including docking, pier and waterfront terminal facilities), or canals (U.S. Census Bureau, 200 7a ). Vessels in port and harbor operations may be involved in maintaining upkeep of harbor via dredging silt, clearing foreign debris, or assisting with construction projects (Reference for Business, 2007f)

. Vessels, such as tugboats, may also be responsible for assisting larger vessels in docking maneuvers in harbors and towing
vessels. As of 2008 , there were 5, 425 towboats in the U.S. fleet (USACE, 2009). The private tugboat industry experienced a boon in late 1990s when the U.S. Navy began chartering tugs instead of replacing its fleet (Reference for Business, 2007g)

. The vessels in this industry sector are likely to be smaller, auxiliary vessels as opposed to the large container ships and barges that they serve.

Marine Carg o Handling
This industry comprises establishments primarily engaged in providing stevedoring and other marine cargo handling services (except warehousing) (U.S. Census Bureau, 2007). This sector contains only a small number of vessels, as most of its busin ess is land -based.

This particular industry sector, along with port and harbor operations, has been growing over the
last decade s as a result of the increase in foreign trade, mostly with Asian countries. Marine cargo handling and port and harbor operations on the Pacific Coast account for about half of all such operations in the United States (Reference for Business, 2007e).

Despite the increase in volume of shipments handled, employment in marine cargo handling, as well as in port and harbor operations, has been on the decline in recent years, due to increased automation of tasks and other technological advances that reduce the need for manual labor. The industry’s unions, the International Longshoremen’s Association and the International Longshore
and Wa rehouse Union, are nevertheless still strong and maintain high membership rates (Reference for Business, 2007e). Nevertheless , the decline in volume of shipments due to the recession undoubtedly impacted employment in these indi rect industries.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 21 Navigation al Services to Shipping and Salvage
This NAICS classification includes two main types of businesses: navigational services to shipping and marine salvage (U.S. Census Bureau, 2002).

Vessels in this industry do not typically carry passengers or cargo, but rather assist larger vessels in entering and leaving port, or in other operations. The salvage subsector of this industry sector includes maintenance vessels that prepare ships for salvage and scrap.

Other Support Activities for Water Transportation

Other auxiliary services of the water transportation industry are grouped into this category, which includes maintenance, repair and salvaging of vessels, inspections, security, and other operations. In recent years, many ship repair companies have been hesitant to work on vessels due to liability concerns, and underwriters have been cautious of paying claims that are the result of poor maintenance; these uncertainties have kept the industry from expanding (Reference for Business, 2007f). Additionally, traditiona l salvage jobs decreased in the 2000s, potentially due to environmental concerns (Reference for Business, 2007f). However, after the terrorist attacks of

2001 , there was a growth in the marine and cargo security industry (Reference for Business, 2007f).

3.2.3 F ISHING

The fishing industry includes commercial catching or taking of finfish, shellfish, or miscellaneous marine products from a natural habitat, such as the catching of bluefish, eels, salmon, tuna, clams, crabs, lobsters, mussels, oysters, shrimp, frogs , sea urchins, and turtles (U.S. Census Bureau,

2007a ).

Since the 1990s, finfish volume has been declining, due to severely depleted fisheries in the Atlantic and loss of breeding grounds to pollution, as well as to increasingly strict regulations
aimed at preventing these problems (Reference for Business, 2007a, b). Demand has not been strong enough to prevent declines in the value of the catches. Shellfish volume has remained relatively constant, with the total value of the catch increasing slightly. Fish and seafood imports have increased over the same period, intensifying the competition in this industry (National Marine Fisheries Service, 2003).

In 2009, Alaska led the nation in both volume and value of fish caught. Louisiana and Virginia
were second an d third respectively in volume of fish caught, while Massachusetts and Maine were second and third in terms of value of fish landings (National Marine Fisheries Service, 2011).

While the overall fishing industry counts over 65,000 vessels, only an estimat ed 4 percent of the commercial fishing vessels operating domestically are greater than 79 feet in length

, according to data from MISLE (see Section 2 ), and are the refore covered by the VGP

.

3.2.4 M INING

The mining industry comprises establishments that extract naturally occurring mineral solids, such as coal and ores; liquid minerals, such as crude petroleum; and gases, such as natural gas. Within the mining industry, th e drilling oil and gas wells sector (NAICS 213111) operates vesselsEconomic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 22 covered by the VGP , including 131 MODUs. This sector comprises establishments primarily engaged in drilling oil and gas wells for others on a contract or fee basis (U.S. Census Bureau,

2007a ). According to data provided by the IADC, the 131 MODUs covered by the VGP include 5 drillships, 24 semi-submersible units, 5 submersible units, 40 inland barge units, and 57 jackup units (IADC, 2007). Note that these MODUs represent only a very small f raction of the total number of establishments reported overall in the drilling oil and gas wells sector, as described in

Section 3.3.2

. In the remainder of this report, unless otherwise noted, the term mining industry refers more specifically to the drilling oil and gas wells sector within the industry rather than the mining industry as a whole.

3.3 R ECENT T RENDS

This section reviews the recent trends in the water transportation and fishing industries in terms of number of firms, numbers of vessels, and financial performance. It also highlights trends in the drilling oil and gas wells sector of the mining industry.

The reference period is from 2002 through 2007, the years of the two most recent Economic Censuses, except for the number of vessels which is measured between 2007 and 2008.

Overall, the water transportation and fishing industries saw a decline in the number of firms and
total revenues

. In contrast, t he drilling oil and gas wells sector experienced relatively strong firm, revenue, and employment growth. The number of vessels was generally unchanged in the most recent years for which statistics are availabl e and relative to the universe of vessels that was considered by EPA during the development of the 2008 VGP.

Employment, establishment, and payroll data for the Fishing Industry for 2007 are from the County Business Patterns dataset because the fishing ind ustry is not included in the Economic

Census. In cases where Fishing Industry data were not available from the Census Bureau, they
were obtained from the Small Business Administration.

3.3.1 NUMBER OF VESSELS BY INDUSTRY SECTOR

Table 3-2 shows changes in the number of vessels between 2000 and 2008, according to the
WTLUS database (USACE, 2009). 16 Over this period, the WTLUS database recorded a loss of

one per cent in the total number of non fishing vessels , although some vessel types (e.g., towboats, tank barges) saw their counts increase slightly.

16 These vessel totals only include vessels in t he WTLUS database, and do not encompass those vessels listed only in MISLE as the MISLE database was only available for one year.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 23 Table 3-2 . Number of Vessels in the WTLUS Database, 2000

- 2008

.

Vessel Type 200 0 2005 2007 2008 % Change ( 2007

- 08)

Self

- Propelled Dry Cargo and/or Passenger, Offshore Support 2,780 2,967 3,001 2,985

- 1%
Vehicular Ferries and Railroad Cars 292 619 604 578

- 4%
Tankers 135 100 80 76

- 5%
Towboats 4,995 5,290 5

, 356 5,424 1%
Total

– Self

- Propelled 8,202 8,976 9

, 041 9,063 0%

Non

- Self

- Propelled Barges, Dry Cargo 27,342 29,107 27,162 26,652

- 2% Barges, Tanker 3

, 985 4

, 011 4,467 4

, 560 2%
Railroad Car Floats 33 34 25 26 4%
Subtotal

- non Self

- Propelled 31

, 360 33

, 152 31,654 31

, 238

- 1%

TOTAL

- Vessels a 39
, 641 41
, 354 40,695 40
, 301

- 1% Source: U.S. Army Corps of Engineers, 2009

. Note: Timeseries d ata on the number of fishing vessels could not be found

.

3.3.2 N UMBER OF E STABLISHMENTS BY I NDUSTRY S ECTOR

Table 3-3 summarizes the changes in numbers of establishments for each sector of the water
transport ation , fishing, and mining industries between 2002 an d 2007. The water transportation industry experienced a decrease of 4.1 percent in the number of establishments over this period, although deep sea, coastal and great lakes water transportation experienced a much greater decline. Conversely, inland water t ransportation and scenic and sightseeing transportation both experienced a marginal increase in the number of establishments . The m ining industry also experienced an increase in number of establishments.

The largest increase in the number of establishments was in coastal and Great Lakes passenger transportation for which Census reports a 61 percent change in the number of establishments over
the five -year period. Inland waterways freight transportation grew 9 percent in number of establishments, and port a nd harbor operations and navigational servic es to shipping and salvage both grew by 11 to 12 percent. The fishing industry and the drilling oil and gas wells sector experienced 10 and 8 percent increase s in the number of establishments , respectively, betwe en 2002 and 2007.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 24 Table 3-3 . Number of Establishments by Industry Sector, 2002 and 2007.

NAICS Description 2002 2007 % Change Water Transportation Industry Deep Sea, Coastal, and Great Lakes Water Transportation

Deep Sea Freight Transportation 456 360

- 21.1% Deep Sea Passenger Transportation 87 55

- 36.8% Coastal and Great Lakes Freight Transportation 677 527

- 22.2% Coastal and Great Lakes Passenger Transportation 114 184 61.4%
Subtotal

- Deep Sea, Coastal, Great Lakes 1,334 1,126

- 15.6% Inland Water Transportation

Inland Waterways Freight Transportation 321 351 9.3% Inland Waterways Passenger Transportation 269 244

- 9.3%
Subtotal Inland 590 595 0.8% Scenic and Sightseeing Transportation

Scenic and Sightseeing Transportation, Water 1,726 1,740 0.8% Support Activities for Water Transportation

Port and Harbor Operations 233 262 12.4% Marine Cargo Handling 567 495

- 12.7% Navigational Services to Shipping and Salvage 778 864 11.1% Other Support Activities for Water Transportation 924 819

- 11.4%
Subtotal

- Support Activities 2,502 2,440

- 2.5%

TOTAL

- Water Transportation 6,152 5,901

- 4.1% Fishing Industry

Fishing 1,916 2,062 a 7.6% Mining Industry

Drilling oil & gas wells sector 1,926 2,109 9.5%
Source: U.S. Census Bureau, 2002a, 2002b, 2007a, 2007b; a Based on reporting requirements for the data source, the number of establishments only includes

firms with full

- time employees

.

3.3.3 E STABLISHMENT AND E MPLOYMENT B IRTHS AND D EATHS

Table 3-4 summarizes average establishment birth and death rates for each industry sector for
which these data were available. The reference period for these trends is 2002 –2007. Birth and death rates in the water transportation and fishing industries average between about 5 and

15 percent of their total numbers of establishments. 17

For deep sea, costal and great lakes water transportation and support activities for water transportation, deaths outnumber births. However, for inland water transportation and scenic and sightseeing transportation births outnumber deaths. The largest average net change occurred in scenic and sightseeing water transp ortation, with an average of 28 establishment births per year.

17 For the mining industry, the fraction is based on births and deaths relative to the 9,935 establishments reported in
the 20 07 Economic Census for NAICS 213 – Support activities for mining. According to the 2007 Economic Census, the drilling oil and gas wells sector (NAICS 213111) represented about a fifth (2,109 establishments) of the establishments reported in the support act ivities for mining sector (NAICS 213) that year.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 25 The fishing industry averaged a net change of eight establishment births per year between 2002 and 2007, while the support activities for mining sector averaged a net change of over 450 births per year between 2002 and 2007.

Table 3-4 . Establishment Births and Deaths, Five

- Year Annual Average: 2002

- 2007.

Industry Sector Net Change Births Deaths Water Transportation Industry

Deep Sea, Coastal, and Great Lakes Water Transportation - 9.8 133.8 143.6

Inland Water Transportation 9.6 90.0 80.4 Scenic and Sightseeing Transportation, Water 27.6 192.0 164.4 Support Activities for Water Transportation

- 5.6 182.0 187.6 Water Transportation Industry Average 6.7 184.7 178.0 Fishing Industry

Fishing 8.0 228.8 220.8 Mining Industry

Support Activities for Mining a 458.6 1,155.6 697.0 a Data were only available for NAICS 213 (Support Activities for Mining) and were not

available at the 6

- digit NAICS level. The 2002 Economic Census reports 9,104

establishments in NAICS 213.
Source: U.S. SBA, 2007a

Table 3-5 summarizes the net change in employment (difference between births and deaths) for each industry sector for which these data are available. Specific information on job creation and
eliminatio n was not available for many industry sectors.

All the water transportation sectors had an average net gain of jobs over the five years. Support activities for water transportation averaged the largest change in employment per year, with an average of 2,11 1 jobs created per year. Scenic and sightseeing transportation also averaged more than 1,000 jobs created per year between 2002 and 2007. Inland water transportation and deep sea, coastal and Great Lakes water transportation averaged net job creation rates of 573 and 510 employees per year, respectively.

The fishing industry averaged a decline of 149 jobs per year over the same period whereas the support activities for mining sector (NAICS 213) averaged an increase of nearly 33,115 jobs per

year . According to the 2007 Economic Census, the drilling oil and gas wells sector (NAICS 213111) accounts for a little under a third of the paid employees reported overall in the support activities for mining sector (NAICS 213) (106,859 paid employees as compared to 368 ,613 paid employees).Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 26 Table 3-5

. Net Change in Employment: Five

- Year Annual Average, 2002

- 2007.

Industry Sector Net Change Water Transportation Industry

Deep Sea, Coastal, and Great Lakes Water Transportation 509.8 Inland Water Transportation 573.2 Scenic and Sightseeing Transportation, Water 1,058.8 Support Activities for Water Transportation 2,111.6 Water Transportation Industry Average 983.9 Fishing Industry

Fishing

- 149.2 Mining Industry

Support Activities for Mining a 33,115.0 a Data were only available for NAICS 213 (Support Activities for Mining) and were not

available at the 6

- digit NAICS level. The 2002 Economic Census reports 9,104

establishments in NAICS 213.

Source: U.S. SBA, 2007a

3.3.4 FINANCIAL PERFORMANC E

Table 3-6 presents changes in revenue or receipts by industry, in constant dollars. Overall, the water transportation industry experienced robust growth of 22 percent over the period 2002– 2007, which i s more robust than the overall U. S. economy’s growth of 15 percent during this period (U.S. BEA, 2011b). There was significant variability in the performance of the various industry sectors, with revenues increasing 106 percent in inland water transportation and 20 percent in deep sea, coastal and Great Lakes water transportation sectors

. Port and harbor operations saw a 27 percent decline in revenue, while navigational services to shipping and salvage had a 25 percent increase in revenue over the same peri od. Coastal and Great Lakes passenger transportation and inland waterways freight transportation saw huge growth, with

rev enues increasing over 100 percent.

The drilling oil and gas wells sector experienced an increase of almost 115 percent over the same period.

No revenue data were available for the fishing industry in 2007. Instead EPA found data on total value of commercial fish landings in 2007 and used these data as proxy for revenues. Other industry data—employment, payroll—are from the U.S. Small Bus iness Administration and the Census’ County Business Patterns dataset because fishing is not included in the Economic

Census.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 27 Table 3-6 : Revenues by Industry Sector, 2002 and 2007.

Industry Sector 2002 ($ millions) a 2007 ($ millions) Percent Change Water Transportation Industry Deep Sea, Coastal, and Great Lakes Water Transportation $ 23,778 $ 28,513 19.9% Inland Water Transportation $ 2,873 $ 5,934 106.5% Scenic and Sightseeing Transportation, Water $ 1,111 $ 1,271 14.4% Support Activities for Water Transportation $ 11,296 $ 12,128 7.4%

TOTAL

- Water Transportation $ 39,058 $ 47,845 22.5% Fishing Industry Fishing b $3,646 $4,199 15.2% Mining Industry Drilling oil & gas wells sector $10,450 $22,512 115.4%

Source: U.S. Census Bureau, 2002b, 2007 a ; U.S. SBA, 2002b; NOAA, 2011 a

a 2002 Economic Census revenue data updated to $2007 by using Consumer Price Index (CPI) deflator (US BLS, 2011). All data are in 2007 dollars

.
b No revenue data are available for the commercial fishing industry in the Economic Census 2007. The 2007 value of fish landing is used as a proxy of revenue for that industry

. For consistency, revenue s for 2002 are also based on the value of fish landing.

3.4 INDUSTRY MARKET STRUCTURE

The water tr ansportation and fishing industries, and the drilling oil and gas wells segment of the mining industry are comprised of a large number of small businesses, whether classified by employment size or by annual revenues. The vast majorities of firms in these i ndustries employ fewer than 100 people and earn revenues of less than $1 million per year.

This large concentration of small firms earning relatively low amounts of revenue may make the water transportation and fishing industries, and the drilling oil and gas wells segment of the mining industry more sensitive to changes in operating costs.

3.4.1 FIRMS AND R EVENUES

Table 3-7 details the number of firms and revenues by employment size in 2007. Firms not operating the entire year do not report employment data, and are classified under “NR” in the
table.

In the water transportation industry, 59 percent of firms employ fewer than 20 people, though these firms only account for 13 percent of the industry’s revenue. Large firms employing more than 500 people, on the other hand, account for only 2 percent of businesses in the industry, but

earn a sim ilar share (13 percent) of its revenue.

In the fishing industry, the vast majority of firms (98 percent) employ fewer than 20 people. Less than 0.1 percent of fishing firms employ over 500 people. The share of small firms may be even greater, however, since nonemployer statistics suggest that firms without employees outnumber those with at least one paid employee by a ratio of over 30 to 1 (about 65,000 compared to 2,000).

The drilling oil and gas wells sector also contains a larger percentage of firms employing fewer
than 2 0 people ( 72 percent), and these firms account for only a small share of total industryEconomic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 28 revenue ( 11 percent). The large firms in this sector account for approximately 2 percent of total firms, but earn half of the sector’s revenue

.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 29 Table 3-7. Firms and Revenues by Employment Size, 2007.

Number of Firms Revenues ($1,000 ) 2
Number of Employees 1

- 19 20

- 99 100

- 499 500+ NR 1 1

- 19 20

- 99 100

- 499 500+ NR

Water Transportation Deep Sea, Coastal, Great Lakes Water Transportation Deep Sea Freight Transportation 125 31 27 5 29 509,454 806,482 3,443,618 1,495,150 37,871 Deep Sea Passenger Transportation 30 3 5 3 7 29,514

- 918,024 11,363,598 1,114 Coastal and Great Lakes Freight Transportation 223 73 40 8 49 696,938 1,139,877 3,565,401 2,787,529 90,748 Coastal and Great Lakes Passenger Transportation 90 27 5 1 41 60,623 255,766 96,847

- 33,615 Inland Water Transportation Inland Waterways Freight Transportation 175 55 29 5 52 185912 537,463 1,894,812 1,475,344 70,925 Inland Waterways Passenger Transportation 147 23 6 0 57 96,531 139,284 127,179 D 19,888 Scenic and Sightseeing Transportation, Water Scenic and Sightseeing Transportation, Water 933 103 8 2 656 410,068 378,698 D D 217,917 Support Activities for Water Transportation Port and Harbor Operations 150 38 8 1 23 235,284 236,246 288,638 D 16,305 Marine Cargo Handling 129 74 40 19 27 193,590 1,129,606 1,000,772 3,888,876 33,727 Navigational Services to Shipping and Salvage 523 91 24 2 104 541,853 917,516 431,609 D 59,809 Other Support Activities for Water Transportation 534 123 29 45 88 85,910 175,465 101,170 D 21,668
TOTAL

- Water Transportation 3,059 641 221 91 1,133 3,045,677 5,716,403 11,868,070 3,045,677 603,587 Percentage of Industry 59% 12% 4% 2% 22% 13% 24% 49% 13% 2% Fishing Fishing 4 2,002 37 11 3

-- -- -- -- -- -- Percentage of Industry 9 8 % 2 % 0.5% 0%

-- -- -- -- -- -- Mining Drilling oil & gas wells sector 5 1,084 178 44 34 164 554,065 957,281 995,244 2,543,388 36,798 Percentage of Sector 72% 12% 3% 2% 11% 11% 19% 20% 50% 1%

Source: U.S. Census Bureau, 2007; U.S. SBA, 2007b

Notes: 1. NR = Firms that do not report revenue or employment data because they do not operate the entire year. 2. Revenue data are not complete; some revenue data was not included in
data set due to disclosure concerns. 3. D = data withheld to avoid disclosing data for individual companies. 4. Data only include firms with employees, which represent only a small subset of fishing industry establishments. 5. Revenue data for NAICS code 213111 taken from “total value of shipments and receipts for services” representing gross sale s.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 30 Table 3-8 details the number of firms according to annual revenue in each sector of the water transportation, fishing, and mining industries. In the water transportation industry, firms earning less than $1 million per year account for 60 percent of the industry’s firms, and firms earning between $1 and $5 million account for another 23 percent. A large majority (8 3 percent) of firms earn revenues less than $5 million.

Table 3-8. Number of Firms According to Revenue Siz e , 2007.

Number of Firms Revenues (millions of dollars) <1 a 1

- 5 5

- 25 25

- 100 100+

Water Transportation Deep Sea, Coastal, Great Lakes Water Transp

. Deep Sea Freight Transportation 65 45 35 25 18 Deep Sea Passenger Transportation 23 5 3 3 7 Coastal and Great Lakes Freight Transportation 126 103 60 30 25 Coastal and Great Lakes Passenger Transportation 71 28 19 5

- Subtotal

- Deep Sea, Coastal, Great Lakes 285 181 117 63 50 Inland Water Transportation Inland Waterways Freight Transportation 104 87 43 18 12 Inland Waterways Passenger Transportation 124 33 16 3

- Subtotal Inland 228 120 59 21 12 Scenic and Sightseeing Transportation, Water Scenic and Sightseeing Transportation, Water 834 178 31 3 0 Support Activities for Water Transportation Port and Harbor Operations 86 81 22 6 2 Marine Cargo Handling 76 77 69 28 12 Navigational Services to Shipping and Salvage 403 142 67 23 5 Other Support Activities for Water Transportation 446 126 46 7 1
Subtotal

- Support Activities 1,011 426 204 64 20
TOTAL

- Water Transportation 2,358 905 411 151 82 Percentage of Industry 60% 23% 11% 4% 2% Fishing Fishing 4 1,773 217 47 11 5 Percentage of Industry 86% 11% 2% 1% 0% Mining Industry Drilling oil & gas wells sector 5 1,396 310 225 78 50 Percentage of Sector 68% 15% 11% 4% 2%

Source: U.S. Census Bureau 2007b

a The Economic Census breaks down this category further into firms with revenue less than $100,000; $100,000 to $249,999; $250,000 to $499,999; and $500,000 to $999,999.

ND : No data available on distribution of establishments by revenue size

3.4.2 REVENUE BY V ESSEL

Data on revenue by vessel are not generally published in national- level data sets. Some s tatistics are available from public sources , however, regarding per vessel revenue to commercial
fishermen in different regions by type of catch or operational configuration. For example, data for California salmon and Dungeness crab fisheries suggest average revenue per vessel ranging from $23,142 for small vessels to $75,715 for medium and large vessels ($25,031 to $81,897 in 2010Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 31 dollars) (Hackett and Hansen, 2008). Permit data for Alaska fisheries show similarly wide variability in average revenue per active permit, with larger vessels (60 feet or greater in length) having higher revenue than smaller vessels. Average revenues for 2010 ranged from less than $2,000 for the lower quartile of permits holders for halibut fishing by hand troll, to nearly $2.5 million for the upper quartile of permits holders for king crab fishing (Alaska Commercial Fisheries Entry Commission, 2011). Within each type of Alaskan fishery (catch, type of equipment, or region), the ratios of revenues earned by the top quartile permit holders and those earned by the bottom quartile permit holders can be as high as twenty to one. Revenue to Northeast fishermen using vessels 75 feet and above averaged $790,779 per vessel in 2010 (NOAA, 2011 b ). The commercial fishing vessels covered by the 2013 VGP are those greater than
79 feet.

Historical data of per vessel revenue for other industry sectors are available from trade publications and industry analysts . For example, Clarkson’s ClarkSea Index represents weighted average shipping rates across vessel types for oil tankers (VLCC, Suezmax, Aframax and clean product carriers), dry bulk carriers (Capesize, Panamax, Handymax and Handysize, gas carriers (VLGC) and fully cellular containerships . The index provides an indicator of earnings for principal commercial vessel types. The average index value in 2010 was $15,179 per day per voyage. Historical daily charter rates for the period of 1980 -2000 ranged b etween $5,000 and $22,500 per day (Kite- Powell (2001), cited in USCG (2008)

, 18 Rates reported in 2006 were about
twice these 20

- year average values, ranging from $17,000 to $37,500 per day (USCG, 2008).

3.4.3 S MALL B USINESSES

The U.S. Small Business Administrati on (SBA) defines small businesses for the various sectors
of these industries as follows (U.S. SBA, 2010):

 Deep sea, coastal, and Great Lakes water transportation; inland water transportation
– fewer than 500 employees

 Scenic and sightseeing transportation; navigational services to shipping and salvage; other support activities for water transportation – revenues less than $7 million

 Port and harbor operations; marine cargo handling – revenues less than $25.5 million

 Fishing
– revenues less t han $4 million

 Drilling oil and gas wells sector
– fewer than 500 employees.

Table 3-9 summarizes the number of small businesses in each sector of the water transportation, fishing, and mining industries. On the whole, all major industries consist of at least 8 5 percent small businesses. Inland waterways passenger transportation and coastal and Great Lakes passenger transportation have the highest percentage small businesses with 99 to 100 percent
small businesses.

These percentages were calculated based on the number of firms operating the entire year, as employment figures are not available for firms operating only part of the year.

18 The dollar year is not specified.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 32 Table 3-9 : Small Businesses by Industry Sector.

Industry Sector Small Business
Threshold Firms Opera ted
Entire Year Small
Businesses Percent
Small
Business Water Transportation Industry Deep Sea, Coastal, and Great Lakes Water Transp

. Deep Sea Freight Transportation 500 Employees 188 183 97.3% Deep Sea Passenger Transportation 500 Employees 41 38 92.7% Coastal and Great Lakes Freight Transportation 500 Employees 344 336 97.7% Coastal and Great Lakes Passenger Transportation 500 Employees 123 122 99.2%
Subtotal

- Deep Sea, Coastal, and Great Lakes 696 679 97.6% Inland Water Transportation
Inland Waterways Freight Transportation 500 Employees 264 259 98 .1 % Inland Waterways Passenger Transportation 500 Employees 176 176 100.0 %
Subtotal

- Inland 440 435 9 8.9 % Scenic and Sightseeing Transportation, Water Scenic and Sightseeing Transportation, Water $7 million 1,046 1,0 20 9 7.5 % Support Activities for Water Transportation Port and Harbor Operations $25.5 million 197 189 95.9% Marine Cargo Handling $25.5 million 262 222 84.7% Navigational Services to Shipping and Salvage $7 million 640 560 87.5% Other Support Activities for Water Transportation $7 million 626 581 92.8%
Subtotal

- Support Activities 1,725 1,511 87.6%

TOTAL

- Water Transportation 3,907 3, 645 93.3% Fishing Industry Fishing a $4 million 1,916 1,843 96 .2 % Mining Industry Drilling oil & gas wells sector 500 Employees 2,109 1,893 89.8 %

Source: U.S. Census Bureau, 2007

a Includes only employer firms. Nonemployer statistics suggest that the vast majority of firms in the fishing industry earn significantly less than $4 million annually.

3.4.4 E MPLOYMENT AND P AYROLL

Employment in the water transportation increased by seven percent while employment in the fishing industr ies declined by 14 percent over the period between 2002 and 2007 ( Table 3-10 ). However, payroll in both industries increased despite the decline in fishing employment numbers. In fact, almost all sectors within the water transportation industry saw an increase in payroll coastal including Great Lakes freight t ransportation which had a decrease in employment ( Table

3-11 )

. Employment and payroll in the drilling oil and gas wells sector increased by 76 percent and 108 percent, respectively, over the same period.

Note that these figures, and those dis cussed in the rest of this section, reflect the detailed data available from the most recent Economic Census. They do not capture the impact of the subsequent recession which likely reduced employment and payroll in these sectors, as in many
other sectors of the U.S. economy.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 33 TOTAL NUMBER OF EMPL OYEE S BY INDUSTRY SECTOR
In 2007, the water transportation industry employed about 157,000 people. Over 40 percent of these people were employed by businesses providing support activities for water transportation.
Another third worked in the deep sea, coastal, and Great Lakes water transportation sector, with the remaining 20 percent being split between inland water transportation and scenic and sightseeing transportation on water. The fishing industry employed about 5 ,6 00 people in 2007, while the drilling oil and gas wells employed over 106,000 people.

Overall, the water transportation industry saw a 7.3 percent increase in its number of employees between 2002 and 2007. The drilling oil and gas wells sector saw a la rge (77 percent) increase in employment. The only industry to experience a decline was the fishing industry which had a 14.3 percent decline in employment. Overall, the U.S. unemployment rate decreased from 6.0 percent to 5.0 percent between 2002 and 2007 (U.S. BLS, 2011). 19

Deep, sea passenger transportation, coastal and Great Lakes passenger transportation, inland waterways freight transportation all experienced large increas es in employment, growing by

40 percent or more. These industries also experienced strong growth in revenue, in some cases increasing by over 100 percent from 2002 to 2007. Deep sea freight transportation and inland waterways passenger transportation, other support activities for water transportation and fishing industry had the largest decreases in employment, declining by about 14 percent. All these
industries – except for fishing – also experienced declines in revenue, ranging anywhere from 6 to almost 10 percent.

19 Note that these statistics represent changes between 2002 and 2007, the latest year for which detailed Economic Census data are available. The data pre

- date the recessi on and therefore do not reflect the subsequent drop in overall employment across most sectors of the U.S. economy.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 34 Table 3- 10

. Employment by Industry Sector, 2002

- 2007.

NAICS Description 2002
Number of Employees 2007
Number of Employees % Change Water Transportation Industry Deep Sea, Coastal, and Great Lakes Water Transportation

Deep Sea Freight Transportation 13,083 11,896

- 13.8% Deep Sea Passenger Transportation 11.491 18,210 58.5 % Coastal and Great Lakes Freight Transportation 24,333 22,989

- 5.5 % Coastal and Great Lakes Passenger Transportation 2 ,382 3,303 38.7 %
Subtotal

- Deep Sea, Coastal, Great Lakes 52,009 56,389 8.4 % Inland Water Transportation

Inland Waterways Freight Transportation 10,040 16,775 67.1 % Inland Waterways Passenger Transportation 3,277 2,824

- 13.8 %
Subtotal Inland 13,317 19,599 47.2 % Scenic and Sightseeing Transportation

Scenic and Sightseeing Transportation, Water 1 1,557 1 2,692 9.8 % Support Activities for Water Transportation

Port and Harbor Operations 5,593 5,987 7.0 % Marine Cargo Handling 37,707 37,358

- 0.9 % Navigational Services to Shipping and Salvage 13,157 13,538 2.9% Other Support Activities for Water Transportation 1 3,112 1 1,513

- 12.2 %
Subtotal

- Support Activities 69,569 68,396

- 1.7 %

TOTAL

- Water Transportation 146,452 157,085 7.3 % Fishing Industry

Fishing 6,537 5,600

- 14.3% Mining Industry

Drilling oil & gas wells sector 60,450 106,859 76.8 %

Source: U.S. Census Bureau, 2002a, 2002b, 2007a, 2007b

PAYROLL BY INDUSTRY SECTOR

The 7 percent increase in employment in the water transportation industry as a whole was accompanied by an 18 percent increase in payroll from 2002 to 2007 ( Table 3 -11 )

. L arge increases were seen in deep sea passenger transportation and inland waterways freight transportation which also had large gains in employment. Within the water transportation industry, only inland waterways passenger transportation and other support activities for water transportation had decreases in payroll. These sectors both had some o f the largest decreases in employment as well.

The fishing industry’s payroll rose by about 4 percent, despite a relatively large 14 percent decrease in its employment base.

The payroll for drilling oil and gas sector increased substantially (over 100 percent ), reflecting a 76 percent increase in employment in that sector.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 35 Table 3- 11

. Payroll by Industry Sector, 2002

- 2007.

NAICS Description 2002 Annual Payroll ($millions) a 2007 Annual Payroll ($millions) % Change Water Transportation Industry Deep Sea, Coastal, and Great Lakes Water Transportation

Deep Sea Freight Transportation 847 847 0.0% Deep Sea Passenger Transportation 513 838 63.4% Coastal and Great Lakes Freight Transportation 1,370 1,667 21.7% Coastal and Great Lakes Passenger Transportation 80 135 68.9%
Subtotal

- Deep Sea, Coastal, Great Lakes 2,809 3,486 24.1% Inland Water Transportation

Inland Waterways Freight Transportation 555 947 70.5% Inland Waterways Passenger Transportation 130 112

- 13.9 %
Subtotal Inland 685 1,059 54.5% Scenic and Sightseeing Transportation

Scenic and Sightseeing Transportation, Water 307 350 13.8% Support Activities for Water Transportation

Port and Harbor Operations 281 289 3.1% Marine Cargo Handling 1,674 1,741 4.0% Navigational Services to Shipping and Salvage 665 796 19.6% Other Support Activities for Water Transportation 566 513

- 9.5%
Subtotal

- Support Activities 3,186 3,338 4.8%

TOTAL

- Water Transportation 6,987 8,233 17.8% Fishing Industry

Fishing 291 302 3.8% Mining Industry

Drilling oil & gas wells sector 2,871 5,984 108.4%

Source: U.S. Census Bureau, 2002a, 2002b, 2007; U.S. SBA, 2007b a 2002 Economic Census revenue data updated to $2007 by using Consumer Price Index (CPI) deflator (US BLS, 2011)

. All data in $2007.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 36 

### 4 C OST O F B EST M ANAGEMENT P RACTICES

The first step in assessing costs of the revised VGP permitting requirements consists of determining the population of vessels that will be affected by the Permit. As detailed in Section

2.1 : Domestic Vessel Population the total population of domestic vessels is 58,602 , and the total population of foreign vessels is 12, 429

. Permit requirements for discharges incidental to the normal operation of a vessel will impact virtually every non

- military , non- recreational vessel 79 feet or greater use d in a capacity of transporta tion and entering U.S. territorial waters. However, some vessels will implement only a subset of practices because certain discharges are not applicable to all vessel types. For example, practices associated with graywater discharges are not applicable to barges since this vessel class does not produce this type of discharge. Practices associated with aqueous film

- forming foam (AFFF) discharges are only applicable to some utility vessels and to freight and tank ships since other vessel classes do not have a firefighting system. Practices applicable to ballast water management systems are only applicable to the subset of vessels equipped with ballast water tanks. Further, this analysis is concerned exclusively with the
incremental costs (positive or negative) associated with revisio ns to the 2008 VGP requirements

. R evisions that have the potential to result in incremental costs consist of (1) changes in the universe of vessels covered by the VGP and (2) changes in the practices needing to be implemented by ves sel owners to ensure compliance with the Permit.

To estimate the effect of the revised Permit requirements , a baseline must be identified from which to measure this effect. The baseline takes into account previous conditions and determines
how the industr y would act in the future in the absence of revised Permit requirements. Given that
this Permit is not entirely new but instead is revising an existing permit issued in 2008, the baseline for this analysis assume s that all vessels are in full compliance wi th the 2008 VGP requirements

. Accordingly, t he baseline for this analysis is full industry compliance with the 2008
Permit as well as with existing federal and state regulations and with current industry practices or
standards that exceed current regulations to the extent that they can be empirically observed.

As noted above, one source of incremental cost relates to changes in the universe of vessels covered by the VGP. An important consideration concerns any expansion to the scope of the VGP

to v essel categories. Vessels newly covered by the VGP would have to implement practices to address general categories of discharges, along with any vessel

- specific requirement. As the 2013 VGP covers all commercial fishing vessels 79 feet or greater in length (instead of only those commercial fishing vessels that have ballast water discharges, as was the case for the 2008 VGP), these vessels are newly subject to all applicable practices. Except for cases where the requirements have been revised as part of the 2013 VGP, the costs to owners of the commercial fishing vessels of implementing practices are estimated based on EPA’s analysis of the 2008 VGP, but with unit costs restated in 2010 dollars.

A second component of incremental cost relates to substantive changes in effluent limits and related requirements (applicable to all vessels or selected vessel types) or in the recordkeeping, monitoring, reporting, and other general requirements. EPA estimated the impact of the revised requirements per vessel based a review of the changes in vessel practices that may be needed to comply with the revised requirement, industry communications, and research of publicly
available information . Additional cost inputs are also derived from conversations withEconomic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 37 manufacturers and f ield experts

. For each discharge category, EPA estimated the annual pervessel compliance cost s based on the per- instance cost of performing each practice and the number of times per year the practice needs to be performed. Several discharge categories were not analyzed for incremental costs because (1) the industry is already implementing the practices specified in the 2013 VGP or (2) the expected cost of the relevant practice (s) is negligible.

Finally, the total annual cost per discharge category is estim ated by multiplying the practice cost per vessel by the number of vessels expected to incur incremental costs due to the revised Permit requirements.

The remainder of this section is organized as follows:

 Section 4.1 discusses the incremental costs of technology

- based effluent limits and related requirements applicable to all vessels. These requirements are contained in
Section 2.1 of the VGP.

 Secti on 4.2 discusses the incremental costs of practices related to effluent limits and requirements related to 2 7 discharge categories. These requirements are contained in
Section 2.2 of the VGP.

 Sectio n 4.3 discusses the incremental costs associated with practices applicable to specific vessel types. These requirements are contained in Section 5 of the VGP.

 Section 4.4 discusses the incremental costs associated with general inspection, monitoring, reporting, and recordkeeping requirements a pplicable across vessel types. These requirements are contained in Sections 1 and 4 of the VGP.

4.1 TECHNOLOGY

- BASED EFFLUENT LIMITS AND RELATED REQUIR EMENTS

APPLICABLE TO ALL VE SSELS

Part 2.1 of the VGP provides general effluent limits designed to apply to al l covered vessels for all covered discharge types present on a particular vessel. The practices described in this section are broadly applicable and generally constitute common industry practices for all vessels. They
relate to material storag e, toxic and hazardous material , fuel spills and overflows, discharges of oil, compliance with other regulations applicable to vessel discharge, and training. With the exception of new general training requirements, the practices contained in the 2013 VGP are unchanged from the 2008 VGP. The new training requirements outlines the responsibilities of the vessel owner to ensure that their crew are adequately trained to implement the terms of the VGP and operate all pollution prevention equipment on board the vessel. The P ermit does not require specific, formal training but instead provides flexibility to owners to integrate the necessary information within their existing training program and EPA expects that training on the applicable pollution prevention procedures is alr eady being conducted by all vessels subject to the VGP. Accordingly, this requirement is not expected to represent an incremental burden on vessel

owners.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 38 4.2 EFFLUENT LIMITS AND RELATED REQUIREMENTS RELATED TO SPECIFIC

DISCHARGE CATEGORIES

The following anal ysis of practice costs (including per vessel cost and the population of vessels expected to incur additional costs) relies on information collected in support of the 2008 VGP (EPA, 2008) and additional information from manufacturers and field experts on th e incremental costs of revised requirements.

Several of the revised requirements involve a change in customary operating practices that potentially involve additional labor hours and equipment . For practices involving additional labor
hours , EPA has used labor rates 20 and hourly estimates developed as part of the 2008 VGP analyses, based on communication with industry representatives, outside research, and other data sources (see EPA, 2008). Cost estimates for additional capital and maintenance expenditures necessary to comply with revised requirements were obtained from manufacturers of relevant equipment. As necessary, one

- time costs are annualized using a 7 percent discount rate.

The population of vessels to which each practice applies was determined base d on information collected in support of the 2008 VGP, EPA’s Report to Congress summarizing findings from analyses of discharges incidental to the operation of certain vessel s (EPA, 2010b ), information submitted to EPA in Notice of Intents (NOIs) received under the 2008 VGP, and other available
information on common practices applied by different types of vessels

. The following sections discuss the revised permit requirements, provides estimates of the number of vessels that may incur incremental costs, an d summarizes the estimated costs of implementing the practices. The discussion follows the order of the VGP for the 27 discharge categories

. For completeness, the discussion covers all 27 discharge categories, even those for which EPA does
not expect incre mental costs (e.g., applicable vessels are already implementing and/or the cost of the practice is negligible) ; discharge categories for which no incremental cost s are expected are
noted.

20 Except where otherwise noted, the analysis uses a labor rate of $ 33.72 when estimating the costs of incremental
labor hours. This rate is b ased on the average labor rate used in the 2008 VGP analysis, which reflects the average across industry sectors based on input from industry representatives (EPA, 2008). We escalated the labor rate from 2007 to 2010 dollars using the Bureau of Labor Statistics Employment Cost Index (ECI) of 1.067.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 39 4.2.1 D ISCHARGES OF D ECK W ASHDOWN AND R UNOFF AND A BOVE W ATER L INE

H ULL C LEANING

PERMIT REQUIREMENTS
The 2013 VGP requirements for discharge of deck washdown and runoff are fundamentally
similar to the 2008 VGP requirements. The revised permit language clarifies that exposed decks must be broom cleaned ( or comparable management measures ) and all existing debris removed
before deck washdown.

AFFECTED VESSEL POPU LATION
Based on the description of practices within this discharge category, deck washdown and runoff is potentially applicable to all 58,602 vessels. However , 56,276 of t he vessels ( all vessel s with the exception of the newly covered commercial fishing vessels ) are already covered by the 2008 VGP and are therefore assumed to be in compliance with the existing requirement s. Therefore, only commercial fishing vessels will po tentially incur incremental costs as a result of the requirement to implement these practices

. The population potentially affected by practices applicable to the deck runoff discharge category
is shown in Table 4-1

.

Table 4-1. Vessel Counts for Practice Applicable to Deck Runoff.

Vessel Class Total Vessel Count

Commercial Fishing 2, 326 Freight Barges 0 Freight Ships 0 Passenger Vessels 0 Tank Barges 0 Tank Ships 0 Utility Vessels 0

TOTAL 2, 326

COST ESTIMATES
Input from industry representatives on the 2008 VGP requirements suggested that deck cleanup is commonly performed prior to deck washdowns. Also, based on the survey responses, commercial fishing vessels are assumed to already practice deck cleanup as part of standard sanitary practices (e.g., after moving fish to the fish hold). 21

21 In the 2008 VGP analysis, EPA assumed that performing cleanup before a deck washdown takes significantly more time as compared to performing cleanup prior to departing from port. Cleanup prior to a deck washdown would entail moving all pieces of machinery and cargo so as to clean the entire deck. However, cleanup prior to departing from port would only require clearing loose items from the deck. Survey responses indicated a wide range of cleanup time necessary p rior to conducting a deck washdown: from 1 to 6 hours. EPA estimated that it would take 30 minutes to perform cleanup prior to departing from port. (see EPA, 2008)Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 40 Industry input provided on the 2008 VGP also indicated that it is common for all vessels to have drip pans installed for every piece of machinery on deck. The VGP requires that drip pans be onboard the vessel, if feasible, to collect any oily water from machinery and prevent spills. If vessels have drip pans, it is c ommon practice for vessels to perform regular drip pan cleaning and/or draining. However, to capture potential costs to older vessels where such pans are not already provided, EPA performed a sensitivity analysis to examine the potential cost to older

comm ercial fishing vessels that may have to install drip pans and for those that may need to perform cleaning and/or draining.

To evaluate whether the use of phosphate- free cleaners have the potential to impose incremental costs on vessel owners, EPA gathered information on the cost difference between “green” and conventional cleaning products; in particular the cost of phosphate- free and safer/clean products that carry third -party certification, compared to the cost of conventional cleaning products
without su ch third

- party certification

. EPA found that there was no systematic cost difference between soaps certified by third parties as more “environmentally friendly” and conventional products; in fact, the certified “green products” were often less expensive . B ased on a review of retail prices for 32 unique boat soaps , EPA found that the average per-unit cost of certified cleaners ($20.27/gallon) was slightly less than the average per -unit cost of non-certified, conventional cleaners ($20.98/gallon) (prices tak en from West Marine, Jamestown Distributors, Amazon.com and Greenboatstuff.com). Based on these findings, EPA assumes that the VGP requirement to use non-toxic, phosphate- free cleaners does not result in an incremental cost

.

SENSITIVITY ANALYSIS

The cost input values are shown in Table 4-2

, and the estimates/assumptions derived for each practice are described below.

Table 4-2. Per

- Vessel Costs for Practices Associated with Deck Runoff

Practice Labor Hours Unit Cost Cost Description Performing deck cleanup prior to departing from port 0.5 $ 16

. 86 a Per Instance

Draining and/or wiping and cleaning the drip pans or coamings 1.5 $ 50

. 58 a Per Instance

Drip pan waste disposal N/A $ 441.98 Per Instance Installing drip pans or coamings for every piece of machinery on deck N/A $ 178

. 09 Annualized c ost of a One

time Installation
a Unit cost is estimated by multiplying the labor hours by the average hourly labor rate of $ 33

. 72

. b Includes cost of $ 442 per instance to dispose of drip pan waste.

Deck Cleanup
 Average Labor Hours: EPA has taken the median of 3.5 hours to estimate the time it would take to perform deck cleanup prior to conducting a deck washdown. However, the time requirement to perform cleanup prior to departing from port is assumed to be significantly less: around 30 minutes.

 Average Labor Rate: An average labor rate of $ 33.72 was used

. Note that t his is greater
than the average wage for workers in the commercial fishing industry (based on BLS dataEconomic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 41 for from BLS Occupational and Employment Statistics for code 45 -301 1 “Fishers and Related Fishing Workers” ) and may therefore overstate the cost of this practice.

 Annual Number of Instances: The number of times that a commercial fishing vessel departs from port is assumed to range from 3 to 6 times per month or more , wit h an assumed average of 4.5 times per month or 54 times per year

. This is based on an average length of fishing trips of 5 to 8 days and is consistent with data from Northeast fisheriesthat show average trip durations of 7.9 days for groundfish trips and 4.7 days for nongroundfish trips ( NOAA , 2011b ).

 Baseline: Based on industry input during the development of the 2008 VGP, EPA assumes that deck cleanup is currently conducted prior to departing from port by all commercial fishing vessels

.

Drip Pan Cleaning
 Average Labor Hours: Industry input on the 2008 VGP provided an estimate of 1 to 2 hours required per instance of cleaning , or 1.5 hours on average.

 Average Labor Rate: A labor rate of $ 33.72 was assumed

.  Additional Cost: EPA assumes an average cost of $ 442 per drip pan waste disposal, consistent with the cost estimate developed in support of the 2008 VGP ( in 2008 dollars,
the average costs are $400 with a range of $200 to $1,200 per instance).

 Annual Number of Instances: The number of times that a vessel cleans and/or drains its drip pans ranges from 1 to 4 times per month. Given the fact that commercial fishing vessels often only operate part of the year, EPA estimated an average of once per month

or 12 times per year.

 Baseline: For the low end estimate , EPA assumes that drip pan cleaning is currently practiced 100 percent of the time (or does not apply)

. For the high end estimate , EPA assumes that cleaning is currently practiced 99 percent of the time (or does not apply)

.

Installation of Drip P ans/Coamings
 One

- time Installation Cost: The 2008 VGP analysis assumed an average one- time cost per installation estimate for all machinery on deck of $ $2,000 in 2008 dollars ($2,210 in 2010 dollars). Annualized over 30 years at a 7 percent discount rate, the cost is $ 178.09.

 Baseline: For the low end estimate , EPA assumes that 100 percent of commercial fishing vessels already have drip pans/coamings installed (or does not apply) . For the high end,
EPA assumes that 99 percent of vessels already have drip p ans/coamings installed or the requirement does not apply . EPA is assuming that older vessels may need to install drip pans. Thus, the remaining 1 percent of vessels may incur this incremental cost.

The cost per commercial fishing vessel for each practice and the total cost associated with all commercial fishing vessels are presented in Table 4-3

. As presented in the table, the total annual
incremental co st s estimated across the population of commercial fishing vessels newly subject to the permit requirements ranges from $0 to $ 160 ,593.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 42 Table 4-3. Deck Runoff Sensitivity Analysis.

Practice and Vessel Class Vessel Count % Vessels
Assumed to Incur
Incremental Cost Annual Cost

per Vessel a ,b Total Annual

Cost

Low End Estimate Deck Cleanup 2,326 0 % $ 0.00 $ 0 Drip Pan Cleaning 2,326 0 % $ 0.00 $0 Installation of Drip Pans/Coamings 2,326 0 % $0.00 $0

Low End Total $ 0 High End Estimate Deck Cleanup 2,326 0 % $ 0.00 $ 0 Drip Pan Cleaning 2,326 1 % $ 59.11 $ 137,484 Installation of Drip Pans/Coamings 2,326 1% $ 178.09 $ 4,142 High End TOTAL $ 141,627

a Drip pan cleaning is assumed to occur 99% or 100% of the time (high and low end estimates, respectively).

b Cost for the installation of drip pans/coamings is annualized at a 7 percent discount rate over 30 years.

4.2.2 D ISCHARGES OF BILGE WATER

The VGP reinforces several of the requirements of the Act to Prevent Pollution from Ships (APPS), the U.S. implementation of the 1973/78 International Convention for the Prevention of Marine Pollution from Ships (MARPOL), regarding discharges of oily bilge water . Additionally,
the VGP prohibits the discharge of bilge water by vessels weighing more than 400 tons within 1 nm of shore except during emergencies. These Permit requirements complement current requirements found in the USCG regulations governing Oi ly Mixture (Bilge Slops) Discharges on Oceangoing Ships Over 400 Tons, implemented under the authority of APPS and last amended in 1999. These regulations require the use of oily- water separators on discharges of bilge water by vessels larger than 400 tons (33 CFR 155).

VGP requirements consistent with APPS do not impose any additional costs on subject operators.

EPA is considering authorizing the discharge of bilge water by vessels weighing more than 400
tons within 1 nm of shore if the discharge meets sp ecified requirements. The requirements would include the following three conditions: The discharge must have an oil content at or below 5 ppm; the vessel must be equipped with an oily-water bilge alarm that is capable of detecting to 5 ppm;
and the vessel’ s oil discharge monitoring system must meet the monitoring conditions found in Part 2.2.2.1.1 of the permit. EPA is seeking comments on this option; it is not currently included in the proposed 2013 VGP.

Accordingly, the cost of this option is not include d in the cost of the proposed 2013 VGP. EPA nonetheless estimated the potential cost, were EPA to finalize the 2013 VGP to authorize the discharge of treated bilgewater meeting specified criteria, of the practice. These costs are
discussed below.

DESCRIPTI ON OF PERMIT OPTION

The 2013 VGP bilge water permit requirements build upon the 2008 VGP requirements by retaining general practices related to the minimization of bilge water discharges. In addition,Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 43 however, EPA is seeking comments on an option to author ize the discharge of treated bilge water by certain vessels greater than 400 tons provided that vessels utilize an oil discharge monitoring system and an overboard discharge control unit and alarm, and also perform maintenance, monitoring, and sampling according to a specified schedule. Thus, if EPA were to finalize the option, the revised permit requirements would stipulate that existing vessels greater than 400 gross tons for which holding the bilge water is not technically feasible and all new vessels (constructed on or after December 19, 2013) greater than 400 gross tons may discharge bilge

water in waters subject to this permit if they meet specified conditions on which EPA is seeking

comments.

Potential Permit Text (Excerpt):

Vessels subject to th is Part may discharge treated bilgewater only if their discharge meets the following conditions:

 The oil content of that discharge must be at or below 5 ppm.

 The vessel must be equipped with an oily-water bilge alarm that is capable of detecting to 5 ppm. This alarm must prevent the discharge of any bilgewater with an oil content of greater than 5 ppm

The vessel’s oil discharge monitoring system must meet the monitoring conditions found in Part 2.2.2.1.1 of this permit.

Bilgewater Monitoring

All vessels to which Part 2.2.2.1 applies (see above) must be equipped with an oil discharge monitoring system that monitors the discharge of oily bilge water into waters subject to this permit. These vessels must also be equipped with an overboard dischar ge control unit that automatically initiates the sequence to stop the overboard discharge of the effluent in alarm conditions and prevents the discharge throughout the period the alarm condition prevails. The overboard discharge control unit must be designed to receive automatic signals of oil content of the effluent, measured as ppm, from the oil content meter.

Each oil content meter and each control section of an oil discharge monitoring system must be subjected to a functional test that includes the operations listed in 33 CFR § 157.12f and is conducted as outlined in 46 CFR § subpart 162.050 on a suitable test bench prior to delivery. The detailed program for a functional test of such equipment must be developed by the manufacturer, taking into account the features and functions of the specific design of equipment and the types of oils that will be monitored. A completed workshop certificate, including the delivery functional test protocol, must be received with each unit delivered. A copy of the certif icate must be carried
aboard the vessel at all times.

Routine maintenance of the monitoring system and troubleshooting procedures must be clearly defined in the oil discharge monitoring system’s Operating and Maintenance Manual kept
onboard the vessel. Al l maintenance activities related to the bilge water monitoring system and overboard discharge control unit must be recorded and the information must remain on board for inspection purposes. In addition, vessel staff training must include familiarization with the operation and maintenance of the bilgewater overboard discharge control and oil discharge monitoring equipment.

Initial Analytical MonitoringEconomic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 44 To demonstrate the effectiveness of the oil discharge monitoring system, the vessel owner/operator must tak e at least five (5) samples from the vessel on different days over a 90

- day period that are representative of the treated effluent to be discharged. A vessel which has an oil discharge monitoring system that has been type approved by any flag administration to a 5 ppm standard and has an alarm which prevents the discharge of any bilgewater with an oil content of greater than 5 ppm may instead immediately commence maintenance monitoring.

Initial monitoring must be done within the first 120 days of permit coverage (or before), within 90 days of oil discharge monitoring system installation onboard the vessel, or before the vessel discharges into waters subject to this permit, whichever is later. Samples will be analyzed for oil by Method ISO 9377-2 (2000) Water Quality–Determination of hydrocarbon oil index– Part 2: Method Using Solvent Extraction and Gas Chromatography (incorporation by reference, see 46 CFR § 162.050–4) or EPA Method 1664. If the measured samples meet the 5 ppm standard specified in Part 2.2.2. 1, then the vessel owner/operator has demonstrated the effectiveness of their oil discharge monitoring system for controlling their bilgewater discharge. Records of the sampling and testing results must be retained onboard for a period of 3 years in the ve ssel’s recordkeeping documentation. Records of monitoring information shall include:

 The date, exact place, and time of sampling or measurements;

 The individual(s) who performed the sampling or measurements;

 The date(s) analyses were performed;

 The individ ual(s) and laboratory(ies) who performed the analyses;

 The analytical techniques or methods used; and

 The results of such analyses.

Maintenance Analytical Monitoring

Annually, vessels to which Part 2.2.2.1 applies must collect a sample of the bilgewater e ffluent for analysis of oil by Method ISO 9377-2 (2000) Water Quality– Determination of hydrocarbon
oil index –Part 2: Method Using Solvent Extraction and Gas Chromatography (incorporation by reference, see 46 CFR § 162.050–4) or EPA Method 1664 to demonstra te treatment equipment maintenance and compliance with this permit. At the time of sample collection, the reading on the oil content meter will be recorded so the oil concentration measured by the laboratory can be compared to the oil content meter. If there is a difference between the laboratory result and the oil content meter that is greater than 100 percent, then the vessel must recalibrate the oil content meter. Alternatively, vessels can annually detach the oil content meter and send the meter to the manufacturer for service and calibration. Following manufacturer service and calibration, the meter must be reattached to the bilgewater effluent monitoring location. While the oil content meter is being serviced by the manufacturer, the vessel cannot discharge bilgewater effluent
under the conditions in Part 2.2.2.1.

In addition, an annual test of the oil discharge monitoring system alarm functions and the
electronic -valve switching function must also be performed onboard the vessel to verify they will activate when the oil concentration measured by the oil content meter is greater than 5 ppm.

Records of the sampling and testing results must be retained onboard for a period of 3 years in the vessel’s recordkeeping documentation. Records of monitoring i nformation shall include:Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 45  The date, exact place, and time of sampling or measurements, and any meter recalibration;

 The individual(s) who performed the sampling or measurements, and any meter recalibration;

 The date(s) analyses and any meter recalibration were performed;

 The individual(s) who performed the analyses and any meter recalibration;

 The techniques or methods used for sample analyses and any meter recalibration; and

 The results of such analyses and any meter recalibration.

Monitoring Reporting

Th e vessel owner/operator must submit data showing that the bilgewater standards are achieved by their oil discharge monitoring system to EPA’s e

- reporting system, unless they meet one of the exceptions to electronic reporting found in Part 1.14 of this permit. Monitoring data must be submitted at least once per calendar year no later than February 28 of the year after the data are collected. Data may be submitted as part of the vessel’s annual report.

Current regulation of oily bilge water discharge s from v essels is based on Annex I of the International Convention for the Prevention of Pollution From Ships, 1973 as modified by the Protocol of 1978 (MARPOL 73/78). Under MARPOL, all ships over 400 gross tons are required to have equipment installed onboard tha t limits the discharge of oil into the oceans to 15 ppm when a ship is en route. All vessels over 400 GT are also required to have an oil content monitor (OCM), including a bilge alarm, integrated into the piping system to detect whether the treated bilge water that is being discharged from the bilge separator meets the discharge requirements. Some countries have bilge discharge requirements that are stricter than the international 15 ppm standard. For example, the Canadian Regulations for the Prevention of Pollution from Ships and for Dangerous Chemicals requires 5 ppm bilge alarms for Canadian- flagged vessels which discharge treated bilge water i n the Great Lakes.

Bilge separators, oil content meters and bilge alarms are certified by the Coast Guard to meet 46 CFR 162 (MARPOL Annex I implementing regulations). Type approval is based on testing of
manufacturer -supplied oil pollution control equipment by an independen t laboratory, in accordance with test conditions prescribed by the Coast Guard (33 CFR 155 and 157 and 46 CFR 162). In conformance with IMO resolution MEPC.108(49), the measurement of oil (petroleum products or hydrocarbon, HC) in bilge separator effluent must be analyzed using ISO method

9377-2:2000 22 or equivalent.

If finalized by EPA in the 2013 VGP, the 5 ppm bilge water discharge standard could result in
incremental costs to existing vessels greater than 400 gross tons that currently discharge treated
b ilge water outside 1 nm from shore, and to new vessels greater than 400 gross tons that will

22 This analytical method is “ Water quality

-- Determination of hydrocarbon oil index

-- Part 2: Method using solvent extraction and gas chromatography ”.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 46 discharge treated bilge water rather than holding it . V essels would not be required to modify their current practices if they hold their bilge water

. Table 4-4 summarizes the changes in requirements applicable to different categories of vessels and their potential cost implications. Note that all
vessels would c ontinue to have the option to hold their bilge water , if they have the requisite storage capacity.

Table 4-4. Summary of the Potential Implications of Revised Bilge Water Discharge
Requirements under Consideration

Vessel / 2008 VGP Conditions 2013 VGP Potential Cost implications a

Within 1 nm Existing vessels

• Hold • Hold • None

• Discharge treated bilge water only if

not technologically feasible to hold • Discharge treated bilge water if not technologically feasible to hold, or • None

• Treat to 5 ppm, monitor using

oil content monitor, and conduct annual monitoring • Treatment system retrofit (unless vessel has existing system capable of reaching 5 ppm) and monitoring
New vessels

• Hold • Hold • None

• Discharge treated bilge water

(treated to 15 ppm) only if not technologically feasible to hold • Discharge bilge water treated to 5ppm • Incremental cost of more advanced

t reatment system and monitoring

Within 1

- 3 nm Existing vessels

• Hold • Hold • None

• ≥ 6 knots: Treat to 15 ppm and

monitor using oil content monitor

• < 6 knots: Discharge bilge water

(treated to 15 ppm) only if threatens safety and stability • ≥ 6 knots: Treat to 15 ppm and monitor using oil content
monitor

• < 6 knots: Discharge bilge

water (treated to 15 ppm) only if threatens safety and stability

• Regardless of speed: Treat to 5

ppm, monitor using oil content monitor, and conduct annual monitoring • None

• None

• Treatment system retrofit (unless

vessel has existing system capable of reaching 5 ppm) and monitoring

New vessels

• Hold • Hold • None

• ≥ 6 knots: Treat to 15 ppm and

monitor using oil content monitor • Treat to 5 ppm, monitor using oil content monitor, and conduct annual monitoring • Incremental cost of more advanced
treatment system capable of meeting 5 ppm limit and monitoring • < 6 knots: Discharge bilge water

(treated to 15 ppm) only if threatens safety and stability

a Not all potential cost implications are attributable to this Permit. Owners of existing vessels are not required to retrofit their vessel to discharge within 1 nm but may instead continue to hold their bilge water

.

VESSEL POPULATION POTENTIALLY AFFECTED BY OPTION
For the purpose of estimating the number of vessels that may elect to implement bilge water

treatment (if the option were to be finalized as part of the 2013 VGP), EPA used information contained in the NOI for existing vessel and assumptions on the number of new vessels greater than 400 gross tons that may become operational during the period of the permit. Estimates we re developed separately for existing and new vessels.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 47 Existing Vessels

The MISLE database indicates that a total of 47,556 vessels weigh more than 400 gross tons. Data from NOIs submitted to EPA as of August 2010 show that about 4 percent of vessels larger than 300 gross tons use an onboard bilge water treatment system (the fraction of vessels vary among the vessel classes with a majority of oil and gas tankers and medium and large cruise ships
report ing the use of an onboard treatment system for their oily water or bilge water discharges). 23 These vessels are currently expected to hold their bilge water while within 1 nm from shore, but could potentially have the capability to discharge treated bilge water provided that they comply with the specified effluent limits and monitoring, maintenance, and reporting requirements of the 2013 VGP. EPA assumes that existing vessels are unlikely to change their practice (i.e., they will
continue to hold bilge water ) unless they already meet the revised limits and associated requirements and/or find economically beneficial to do so (i.e., treatment and monitoring cost s are lower than those of holding the bilge water ). Vessels that currently have onboard treatment systems may either decide to treat their bilge water to meet the discharge limits of 5 ppm, or may
continue to hold the bilge water

.
There is evidence that at least some vessels and inst alled bilge separators are capable of meeting the 5 ppm limit proposed in the 2013 VGP. The Canadian Regulations for the Prevention of Pollution from Ships and for Dangerous Chemicals requires 5 ppm bilge alarms on inland

waters 24 ( Great Lakes), and t he Canadian Arctic Waters Pollution Prevention Act requires zero discharge in Arctic waters (all Canadian waters north of 60°). As of February 2011, Lloyd’s Register Clean Shipping Index Verification provides certification of bilge water treatment systems meeting a 5 ppm discharge standard. This is a verification service to shipowners and operators wishing to demonstrate their success in reducing the environmental impact of their activities beyond the requirements of classification or statutory rules and regulations. Additionally, Det Norske Veritas (DNV) of Norway requires bilge separators to be equipped with a 5 ppm bilge alarm to fulfill the DNV Guidance for Clean Design (DNV, 2005).

All vessels ove r 400 GT are required to have an oil content monitor (OCM), including a bilge alarm, integrated into the piping system to detect whether the treated bilge water that is being discharged from the bilge separator meets the discharge requirements. Standards f or approval of OCMs are defined under 46 CFR 162.050 or MARPOL 73/78 Annex I. Under MARPOL, the limit for discharge into the oceans is 15 ppm when a ship is en route ( IMO MEPC 107(49)). Any bilge water found to contain oil or oil residues with an oil conten t greater than the 15 ppm limit

23 The NOI data are self

- reported and may under represent the number of vessels that have a bilge water treatment system onboard.

24 Part 2, Subdivision 4 ( Oil and Oily Mixture Discharges ) of the Regulations for the Prevention of Pollution from Ships and for Dangerous Chemicals states the following under Authorized Discharge — Section I Waters: The discharge of an oily mixture from machinery spaces is authorized from any ship in Section I waters if

... (c ) the discharge is processed through oil filtering equipment that (i) produces an undiluted effluent that has an oil content of no more than 15 ppm, and (ii) triggers an alarm and a discharge

- stopping device as soon as the oil content in th e effluent exceeds (A) 5 ppm, where discharged in inland waters of Canada, or (B) 15 ppm, where discharged in fishing zone 1, 2 or 3 or in those internal waters of Canada that do not include inland waters of Canada; (end of citation)Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 48 must be retained onboard or discharged to a designated reception facility or treated with the bilge

water separator until the oil concentration falls below its allowable discharge concentration

. When the oil content in the effluent is detected to exceed these limits, an alarm and discharge stopping device (typically a valve that diverts the noncompliant effluent back to the bilge separator to be reprocessed) is activated.

New Vessels

A total of 47,148 vessels greater than 400 gross tons are estimated to be covered by the VGP. As
summarized in Section 3.3 : Recent Trends , the number of vessels in the domestic fleet has been relatively flat in recent years, or has even seen declines in certain types of vessels. For the purpose of this analysis, EPA assumes that the future vessel population will remain relatively unchanged over the permit period. Using an assumed life of 30 years, approximately 1/30 th of the
vessel fleet may be replaced in any given year, or 1,572 vessels per year. Based on NOI data for the 2008 VGP, EPA further assumes that 4 percent of the new vessels constructed on or after December 19, 2013 will opt to treat their bilge water to the required effluent limits, with the fraction of vessels ranging by vessel types from less than 1 percent for barges to over 70 percent
for tank ship s , consistent with characteristics of existing vessels.

The population of existing and vessels potentially affected by practices applicable to bilge water discharge category is shown in Table 4-5

. The table includes the estimated number of new vessels coming into service each year. As these new vessels enter service, they may potentially incur higher costs as a result of the revised VGP requirements , if EPA finalizes the option in the 2013

VGP . The number of vessels that may potentially incur higher costs as a result of the revised VGP is assumed to grow at a constant rate over the period of analysis.

Table 4-5. Vessel Counts for Practices Applicable to Option to Authorize Discharge of Treated Bilge W ater ( to 5 ppm ).

Vessel Class Percentage of
Vessels with
Onboard Bilge

W ater
Treatment a Total Existing
Vessels with
Onboard Bilge

W ater Treatment New Vessels with
Onboard Bilge

W ater Treatment (per Year) b New Vessels with
Onboard Bilge

W ater Treatment (at Year 5)

Commercial Fishing 2 7 % 111 4 19 Freight Barges 0 % 31 1 5 Freight Ships 71% 470 16 78 Passenger Vessels 40 % 109 4 18 Tank Barges 1% 63 2 10 Tank Ships 71% 199 7 33 Utility Vessels 2 9 % 728 24 121

TOTAL 1,711 57 285

a Based on NOI data on onboard treatment systems and waste streams generated aboard vessels.

b The U.S. Coast Guard estimates that there are approximately 86 new oceangoing vessels built per year (70 FR 67066).Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 49 COST ESTIMATES FOR OPTION
In the case of existing vessels that currently treat their bilge water , the cost of complying with the bilge water requirements include s costs for oil discharge monitoring system, overboard discharge control system, monitoring, sampling, maintenance, and reporting. 25 Since EPA assumes that existing vessels will continue to use current practices (treat or hold, depend ing on the vessel), these costs are not incremental costs of complying with the revised VGP.

For new vessels, incremental costs for the option include any higher costs associated with installing and operating a treatment system capable of meeting the 5 ppm effluent limit , as compared to the cost of a system capable of treating the effluent to 15 ppm, along with the costs of the oil discharge monitoring system, overboard discharge control system, monitoring, sampling, maintenance, and reporting

. Other requir ements pertaining to personnel training and equipment maintenance are the same for high performance systems as for systems only capable of treating effluent to 15 ppm and
therefore do not represent incremental costs attributable to the VGP

.

Treatment Syste ms and Oil Content Monitors

Cost estimates for bilge water treatment systems and oil content monitors (OCMs) were obtained from equipment manufacturers. Information obtained by EPA for treatment systems capable of meeting the 5 ppm limit suggests that the cost of these systems vary widely (from $11 to $234 per 1,000 gallons treated), depending upon the flow rate, volume of bilge water treated, and the cost of residual disposal. Labor also seems to be an important cost differential for some of the higher
flo w systems.

Capital costs were based on the purchase price of bilge separator treatment systems sized to treat a bilge water flow rate of 1 m 3 /hr (6,300 gal/day), co nsidered to be an average bilge water flow rate for a ship (Ghidossi et al., 2009). Other s our ces indicate that average bilge water flow rates
for ocean -going vessels are considerably lower, on the order of 1 m 3 /day, and that only the largest vessels would generate as much as 1 m 3 /hr. The amount of bilge water that accumulates onboard

can vary, and depends on a number of factors including the size of the ship, engine room design, preventative maintenance, and the age of the components. Although there could be a proportional relationship between ship tonnage and bilge water produced, many variable s exist that can easily cause a smaller vessel to produce more bilge wastes than a larger vessel (EPA, 2008). To address this variability, EPA estimated treatment costs for each system using different assumptions about how often the system was operated (i. e., batch mode or continuous operation).

Operation and maintenance costs were based on systems operating at two different flow rates,

1 m 3 /day and 1 m 3 /hr, as described above. Costs were estimated for the following categories of

25 Representatives from equipment manufacturers suggested that treatment systems can be retrofitted onto existing vessels. They described the process as straightforward and requiring only minimal input from engineers

. However, they also noted that the retrofit can be time

- intens ive

. The process involves a site survey and usually requires the vessel owner to contract an electrician, pipe

- fitter, and welder

. More experts may be required depending on the vessel, and often coordinating their efforts can be difficult

. The American Bureau of Shipping (ABS) must approve the
final installation

. One representative suggested that the process can take anywhere from 1.5 to 3 weeks, though
another noted that, with efficient coordination of labor, the process can take as little as two days.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 50 expenses: chemicals, filte r and sorbent media, maintenance and replacement parts, labor for operation and maintenance (O&M) , and disposal of recovered oil and sludge. It was assumed that
all bilge water treatment systems would require 0.5 to 2 hours per day of crew labor, because

E PA could not resolve conflicting claims regarding which systems required more or less labor to operate and maintain. Cost of labor was assumed to range between $32 and $ 50 per hour, based on Bureau of Labor Statistics data and other cost estimates. Recurring costs of supplies, chemicals, replacement media and parts were provided by the vendor. These costs were estimated based upon experience with treating a “r epresentative” bilg e water (i.e., 200 ppm free oil, 100 ppm emulsified oil, 300 ppm suspended solids). In rea lity, the treatability of bilge water varies considerably between vessels and over time, and so these costs will also vary. 26 Due to a lack of reliable information, ho wever, EPA was unable to consider this variability in these cost estimates. Energy costs to operate the bilge separators were not included, because energy (electricity and heat) is not considered expensive on many vessels (Ghidossi et al., 2009). The

cost of disposing of residual oil and sludge retained in the vessel’s holding tank was based upon contract hauling by a certified waste hauler, and drum disposal of solid oily residuals (i.e., spent filters and sorbent media) was assumed. EPA did not consider t he alternative of incinerating residual oil and sludge aboard ship, although this disposal method is used on some vessels. All costs were expressed in 2010 dollars, with purchase costs of foreign equipment based on currency exchange rates in effect in Augu st 2010. Capital costs were amortized over 20 years using a
discount rate of 7 percent . Tables in Appendix A compare the cost of the various systems reviewed by EPA for the two system flow rates

. These systems commonly include OCMs and
alarm and automated shut

- off designed to prevent the discharge of bilge water exceeding the set
limit . Because the amount of bilge water generated varies across vessels depending on the size, age, and service conditions, among other factors, it is difficult to develop average estimates for any given vessel type.

Fluorescent detection OCMs have a reported capital cost of $12,500, which manufacturers indicated may be higher than that of conventional OCMs although no precise estimates of the conventional systems could be obtaine d. Some of the manufacturer r epresentatives EPA
consulted believe that the fluorescent detection monitor is not necessary to accurately measure
effluent with oil content below 15 ppm and down to near 0 ppm, even though some manufacturers point to testing b y the U.S. Navy and by other major commercial ship operators that suggests that a fluorescent detection OCM measures effluent below 15 ppm with greater accuracy than a more commonly used conventional light scattering OCM

. 27 Since OCMs are

26 A . Chan, personal communication, September 22, 2010; L. Mazzarone, personal communication, September 1,

2010.

27 Communication with representatives from GMG Systems and Ecologix suggested that OCMs that do not use
fluorescent detection can detect below 15 ppm. This is different from findings reported in by NAG Marine ( http://www.td107.com/compare_oil_content_monitor.php ) which claim that fluorescent detection monitors are generally more accurate. This is attributed to differences in how the two types of systems detect the presence of oil. As the name suggests, light scatter OCMs estimate the oil content based on the amount of light that gets scattered in a sample stream , and often cannot discriminate between oil and other particles. Fluorescent detection OCMs detect only oil molecules based on the unique wavelength signatures when the molecules are irradiated with UV light. EPA expressed an interest in the difference in cost between the two types of OCMs in cases where fluorescent detection would be necessary to ensure discharges below 5 ppm oil content.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 51 included within th e costs of the bilge water treatment systems obtained from equipment
manufacturers , EPA expects that the included monitor is capable of accurately detecting the specified concentration limits

.
It should be noted that despite its cost, treatment is less expensive than the cost of onshore oily waste disposal by certified waste haulers in the US, estimated to cost from $300 to $2,000 per 1,000 gallons (New Logic Research, 2010; Lou Mazzarone, personal communication, September 1, 2010). Therefore, ev en where vessels have the capacity to hold their bilge water , they may find
onboard treatment to be more cost effective. EPA did not account for potential cost savings in estimating the impact of the revised bilge water requirements.

Further, the costs pr esented above are the actual costs of the specified systems. Limited information on the costs of systems capable of meeting a 15 ppm limit, but not 5 ppm suggest s that these systems may not be significantly more expensive. For example, in estimating the co st of implementing bilge water treatment to the 15 ppm limit, the U.S. Coast Guard cited annual costs for these systems ranging between $9,000 and $19,000 (in 2009 dollars). This is generally comparable to the annualized costs obtained by EPA for systems c apable of reaching limits of

5 ppm, particularly smaller systems sized to treat effluent rates up to 1 m 3 /day that have costs ranging between $6,312 and $22,550.

Testing
The Permit specifications under consideration call for initial monitoring consisting o f five sampling events over a 60 -day period, followed by maintenance monitoring conducted once a year. The cost associated with these sampling events was estimated by assuming sample preparation and administrative activities associated with the collection and processing of the sample ranging between 2 and 3 hours for each sampling event that is part of the initial monitoring . Laboratory costs and incidentals such as shipping were assumed to be $ 300 per sampling event

. 28

The cost of follow up maintenance monitoring was assumed to be similar but to require an additional 0.5 hour of labor to conduct the testing of the oil monitoring system alarm functions and switching functions. The assignment of additional time for these tests is likely to
overestimate the incremental burden since testing of control equipment is part of regular maintenance practices for vessel ow n ers. R ecalibration of the oil content meter, if necessary, is expected to be part of the baseline maintenance of the vessel and this practice is t herefore assumed to impose no incremental cost. For instance, interviews with representatives of OCM manufacturing companies indicate that they generally recommend having the monitors calibrated
every two years . Good operating practice and compliance with IMO policy requires vessel

owners to follow the maintenance requirements stipulated by equipment manufacturer

, at
minimum. But companies often have a corporate policy of calibrating the monitors annually. The

cost s of re -calibration were estimated at $250 to $500 per monitor . As this calibration is expected

28 We contacted laboratories to get quotes for conducting testing using method ISO 9377

- 2(2000) Water Quality

Determinat ion of hydrocarbon oil

— Part 2: Method using solvent extraction and gas chromatography. While we were able to obtain information on reactant costs (about $100/analysis), these costs do not include the technician rates or overhead. For the purpose of this an alysis, we assumed that each analysis costs $250.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 52 to be conducted in the baseline, no incremental cost is attributed to the revised VGP requirements.

Reporting
Under the option under consideration, vessel owners must submit data on their compliance with bilge water treatment standards as part of their annual reporting to EPA. The incremental burden of adding this information to the existing annual report is assumed to be negligible.

SENSITIVITY ANALYSIS
EPA estimated the potential incremental costs to ve ssel owners using the cost input values presented above and the following assumptions.

Bilge water Treatment Costs
 Bilge water Flow Rate: EPA assumed that larger vessels (freight ships and tanker ships) have flow rates ranging between 8 and 16 m 3 /day for the low and high end estimates, respectively, while other vessels have flow rates ranging between 0.25 and 0.75 m 3 /day, respectively. Costs for the larger vessels are based on systems capable of treating

1 m 3 /hour while those for smaller vessels are based on systems capable of treating

1 m 3 /hour.

 Incremental Costs: The cost estimates presented above are the total costs of systems capable of meeting effluent concentrations of 5 ppm. There is insufficient information to assess the share of this cost that is incremental to the cost of systems capable only of meeting limits of 15 ppm. For the purpose of this analysis, EPA conservatively assumed that the higher performing systems are up to twice as expensive than the less performing systems (i.e., the incremental cost represents between 0 and 50 percent of the bilge water treatment system cost). 29 The 50 percent incremental cost estimate is likely to be a conservative assumption since some of the systems readily achieve 15 ppm and require only a polishing step to m eet the 5 ppm limit.

 Baseline: EPA assume d that the fraction of new vessels that will install bilge water treatment systems capable of meeting effluent concentrations of 5 ppm is similar to the fraction of vessels that currently have onboard bilge water tr eatment, based on the 2008

VGP NOIs . The fraction ranges from 0 percent for barges, to over 70 percent for tank ships. EPA assumes that all of these vessels would potentially incur incremental costs for installing systems capable of meeting the 5 ppm limit . This assumption may overestimate
the number of vessels incurring incremental costs due to the revised requirement since several companies are already meeting the lower limit voluntarily. 30

29 For example, in the case of a 5 ppm system that costs $20,000 and is twice as expensive as a less effective system capable of meeting a 15 ppm limit, the incremental cost is $10,000, or 50 percent.

30 In a ddition to the programs mentioned earlier in this section, other companies describe their policy to discharge only bilge water with an oil content of 5 ppm of less in public documents. For example, Royal Caribbean has adopted as its corporate policy the di scharge of “treated bilge water beyond 12 nm, less than 5 ppm oil to water and at speed
of 6 knots or greater .” (Waste Stream Operational Controls, Royal Caribbean, undated)Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 53 Testing Costs
 Implementation rate : All vessels assumed to use a bilge water treatment system will have to conduct 5 rounds of initial monitoring within the first 60 days of permit coverage followed by an annual maintenance monitoring round.

 Baseline: Vessel owners are assumed to comply with manufacturers’ recommendatio n concerning calibration of oil content monitors. No incremental cost is therefore assumed
for re -calibration, when needed.

The estimated cost per vessel for each practice and the total cost associated with all vessels are summarized in Table 4-3

. As discussed in the introduction to this section, practices resulting in incremental costs to vessel owners are under consideration only and are not currently included in the proposed 2013 VGP. Consequently, these costs are not counted in the total cost for the proposed 2013 VGP but are being provided here for information only.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 54 Table 4-6. Bilge W ater Treatment Sensitivity Analysis.

Vessel Class Number of New
Vessels with Bilge

water Treatment Annual Cost per
Vessel a Total Annual Cost

Low End Estimate Bilge water Treatment Commercial Fishing 11 $ 0 $ 0 Freight Barges 3 $ 0 $0 Freight Ships 47 $ 0 $0 Passenger Vessels 11 $ 0 $0 Tank Barges 6 $ 0 $0 Tank Ships 20 $ 0 $0 Utility Vessels 73 $ 0 $ 0

Bilge water Treatment TOTAL 171 $ 0 Testing a Commercial Fishing 11 $832.39 $9,156 Freight Barges 3 $832.39 $2,497 Freight Ships 47 $832.39 $39,122 Passenger Vessels 11 $832.39 $9,156 Tank Barges 6 $832.39 $4,994 Tank Ships 20 $832.39 $16,648 Utility Vessels 73 $832.39 $60,764
Testing TOTAL 171 $142,338

Low End Total $142,338 High End Estimate Bilge water Treatment Commercial Fishing 11 $8,461 $92,607 Freight Barges 3 $8,461 $25,205 Freight Ships 47 $91,023 $4,153,806 Passenger Vessels 11 $8,461 $90,368 Tank Barges 6 $8,461 $50,410 Tank Ships 20 $91,023 $1,795,178 Utility Vessels 73 $8,461 $610,049

Bilge water Treatment TOTAL 171 $6,817,623
Testing a Commercial Fishing 11 $907.23 $9,980 Freight Barges 3 $907.23 $2,722 Freight Ships 47 $907.23 $42,640
Passenger Vessels 11 $907.23 $9,980 Tank Barges 6 $907.23 $5,443 Tank Ships 20 $907.23 $18,145 Utility Vessels 73 $907.23 $66,228
Testing TOTAL 171 $155,137
High End Total $6,972,760

a Initial and maintenance monitoring is assumed to apply to all vessels that will install a bilge water treatment system

.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 55 4.2.3 DISCHARGES OF BALLAS T WATER

The 2013 VGP complements USCG requirements under the Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990 (NANPCA), as reauthorized and amended by the National Invasive Species Act of 1996 (NISA), regarding the impacts of discharges from ballast water

treatment systems (BW T S).

The 2013 VGP specifies performance standards for BWTS , along with associated monitoring, sampling, testing, and recordkeeping. The requirements are applicable to all vessels that operate in U.S. waters and are equipped with ballast water tanks, unless they are in innocent passage, with the exception of crude oil tanke rs engaged in coastwise trade, vessels of the armed forces 31 , and vessels that operate exclusively in one Captain of the Port Zone.

The BWTS p erformance standards are the same as the “Phase One” standards proposed by USCG in 2009 under 33 CFR part 151 and 46 CFR part 162 (74 FR 44632), which EPA expects to be finalized and promulgated by the time the 2013 VGP comes into effect.

Technologies to meet these limits have been shown to be available: several studies and publicati ons discuss current treatment technologies, their effic acy and performance, and their availability for shipboard installation (see EPA SAB, 2011; ABS , 2010; Albert et al., 2010; CSLC, 2010; GLBWC, 2010; WDNR 2010). For a description of how EPA developed th ese limits for the 2013 iteration of the VGP, please see the proposed permit fact sheet (EPA, 2011b).
The VGP -specific monitoring and recordkeeping include sampling and analytical testing of the

BWTS effluent twice per year and reporting of the results of these tests in a n annual report to EPA. While the additional monitoring and testing requirements will impose additional costs on most subject vessel operators, the requirements consistent with BWTS under USCG regulations
will not.

PERMIT REQUIREMENTS

The 2013 VGP ballast water requirements build upon the 2008 VGP requirements and USCG regulations expected to be in place by the time the 2013 VGP takes effect. The 2013 VGP identifies four ballast management methods available to vessels: (1) on -board treatment, (2) onshore treatment; (3) use of public water supply; and (4) no discharge in regulated waters

. It also provides for specific requirements for vessels that treat their ballast water and enter the Great
Lakes.

Permit Text ( Excerpt ):

2.2.3.5.1 Ballast W ater Management Measures

In addition to the other requirements of this permit, owner/operators of vessels with the capacity to carry greater than or equal to 8 cubic meters of ballast water may use one of the four following ballast water management methods to meet the numeric discharge limits in Part

2.2.3.5:

31 Vessels of the armed forces are subject to the Uniform National Discharge Standards for Vessels of the Armed Forces (33 U.S.C. 1322(n))Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 56 2.2.3.5.1.1 Ballast Water Management using a Ballast Water Treatment System

Vessel owner/operators utilizing a ballast water treatment system (BWTS) must use a system which has been shown to be effective by testing in accordance with the EPA- ETV protocol for the verification of ballast water treatment technology conducted by an independent third party laboratory, test facility or test organization. Once the effluent limits in Part 2.2.3.5 become applic able to a vessel (see part 2.2.3.5.2 for applicability timeframes for specified categories of vessels), owners/operators of vessels utilizing a ballast water treatment system to meet the requirements of Part 2.2.3.5 of this permit must meet those limits as an instantaneous maximum.

Additionally, following installation of a BWTS, the master, owner, operator, agent, or person in charge of the vessel must maintain the BWTS in accordance with all manufacturer specifications. Furthermore, all treatment must be c onducted in accordance with the BWTS manufacturer’s instructions. The BWTS must be used prior to any discharge of ballast water to waters of the U.S.

2.2.3.5.1.1.1 Monitoring From Vessels Using Ballast Water Treatment Systems

The monitoring requirements in Part 2.2.3.5.1.1 apply to ballast water discharges from vessels employing ballast water treatment systems that are required to achieve the effluent limitations of Part 2.2.3.5. The monitoring is divided into three components. The first, in Part 2.2.3.5.1.1.2, is required of all vessels and generally requires monitoring equipment performance to assure the system is fully functional. Vessels conducting this monitoring also must adequately calibrate their equipment as required in Part 2.2.3.5.1.1.3. The se cond component, in Part 2.2.3.5.1.1.4 requires monitoring from all ballast water systems for selected biological indicators. The third component, in part 2.2.3.5.1.1.5 requires monitoring of the ballast water discharge itself for biocides and residuals to assure compliance with the effluent limitations established in part 2.2.3.5 of the permit, as applicable.

2.2.3.5.1.1.2 Ballast Water System Functionality Monitoring

Ballast water treatment systems use physical and/or chemical processes, or a combinat ion thereof, to achieve reductions in living organisms. The use of physical/chemical indicators of treatment performance verifies that the ballast water treatment system is operating according to the manufacturers’ operating specifications. To assess the BWTS functionality, monitoring indicators of the BWTS functionality is required at least once per month for specific parameters that are applicable to your system. The required parameters to be monitored, with appropriate monitoring approaches are contain ed in Appendix J. For example, if your system uses a filter and chlorine dioxide, you must meet the requirements for systems using both filters and chlorine dioxide. If your system uses cavitation, UV, and hypochlorite generation, you must monitor
condit ions for all three treatment units. EPA expects that most ballast water treatment systems will make use of at least two physical and/or chemical processes.

Most ballast water treatment systems have control and self diagnostic equipment such as sensors that continuously measure treatment parameters to verify performance. The metrics to be monitored are based on common approaches used in ballast water treatment systems. As new approaches become commonly available, EPA will develop new monitoring paramete rs as appropriate.

2.2.3.5.1.1.3 Ballast Water monitoring equipment calibrationEconomic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 57 At a minimum, all applicable sensors and other equipment must be calibrated annually. Additionally, all applicable sensors and other control equipment must be calibrated no le ss frequently than recommended by the sensor or other equipment manufacturer, or by the ballast water treatment system manufacturer or when warranted based on device drift from a standard or calibrated setting. EPA expects many sensor types (e.g., pH prob es, TRO sensors, turbidity sensors) will need to be calibrated on a more frequent basis. Calibration of the sensors and equipment can be conducted on -board the vessel or they can be removed and shipped to the manufacturer or other vendor for calibration. D uring the period when the sensors are not installed (or otherwise inoperable thus significantly compromising the performance of the ballast water treatment system), the vessel must not discharge ballast water.

2.2.3.5.1.1.4 Effluent Biological Organism Mon itoring

Once a ballast water treatment system is required to be installed onboard a vessel (see part 2.2.3.5.2 for applicability and timeframe for installation of such vessels), any ballast water discharges from such vessels will be subject to the effluent limitations in Part 2.2.3.5 of this permit. To ascertain compliance with the effluent limitation in that section, EPA is establishing the following biological indicator compliance monitoring. These samples can be taken by collecting a small volume sample from the ballast water discharge (consistent with the sampling guidance found in EPA’s Generic Protocol for the Verification of Ballast Water Treatment Technology) and analyzing the sample for concentrations of certain biological indicator parameters. Ana lysis of concentrations of indicator organisms must include monitoring for the parameters in Table 2 below utilizing the methods in that table, or other EPA Part 136 methods as applicable.

[Table 2: Indicator Organism Monitoring Parameters]

Biological indi cator compliance monitoring sampling of ballast water effluent must be conducted 2 times per year for vessels with type approved devices for which high quality type approval data are available, and 4 times per year for non- type approved devices or type approved devices for which high quality data are not available. Each sample must be tested independently and the individual results must be reported and not averaged. Monitoring must be conducted at least 14 days apart from different discharge events.

Typ e approved devices for which high quality type approval data are available means either:

a) any ballast water treatment system type approved by the United States federal
government; or
b) any ballast water treatment system:

i. type approved by a foreign a dministration;

ii. for which efficacy testing was conducted by an independent 3rd party testing organization, either in accordance with the ETV protocol or in a manner consistent with the ETV protocol with respect to QA/QC procedures, the use of validated methods including appropriate volumes of representative samples, and full description and documentation of test procedures, results and analyses; and

iii. all active substance data (e.g., the full data package submitted to the flag administration for typ e approval) have all been made available to the US EPA.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 58 2.2.3.5.1.1.5 Requirements and Effluent Limitations for BWTS that use Active Substances (e.g., biocides)

2.2.3.5.1.1.5.1 Authorization of Residual Biocides Associated with Ballast Water Treatment

S

ystems
Many ballast water treatment systems produce or use biocides as an agent to reduce living organisms present in the ballast water tank. In order to be eligible for coverage under this permit, any ballast water treatment system must not use any biocid e that is a “pesticide” within the meaning of the Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C § 136 et seq.) unless that biocide has been registered for use in ballast water treatment under such Act. The requirement in the preceding sente nce does not apply if such biocide is generated solely by the use of a “device” on board the same vessel as the ballast water to be treated by the biocide, as the term “device” is defined in the Federal Insecticide, Fungicide, and Rodenticide Act. In
addi tion, if the ballast water treatment system uses or generates biocides and you will discharge ballast water treated with biocides into waters subject to this permit, you must meet one of the following conditions to be eligible for permit coverage.

The discharge of biocides or residuals may not exceed the following instantaneous maximum limits expressed as micrograms per liter (μg/l).

[Table 3. Maximum Ballast Water Effluent Limits for Residual Biocides]

Any other biocides or derivatives may not exceed acut e water quality criteria listed in EPA’s 1986 Quality Criteria for Water [the Gold Book], and any subsequent revision, at the point of ballast water discharge. The Gold Book can be found at: www.epa.gov/waterscience/criteria/library/goldbook.pdf. Tables summarizing the subsequent revisions can be found at: http://www.epa.gov/waterscience/criteria/wqctable/index.html. Discharges of biocide residuals or derivatives must also meet monitoring requirements under Part 2.2.3.5.1.1.1, and reporting and recordkeeping requirements in Part 2.2.3.5.1.1.6.

If the biocide used or produced by your system and its derivatives is not listed in the previous table or found in EPA’s Gold Book, you must notify EPA at least 120 days in advance of its use and provide any associated aquatic toxicity data for that biocide or its derivatives of which you are aware. EPA may impose additional limitations on a treatment system- specific basis, or require you to obtain coverage under an individual permit, if necessary. EPA may inform the

v essel owner/operator of specific requirements. You may also seek coverage under an individual NPDES permit pursuant to Part 1.8.2 of this permit. You may not discharge the biocide at issue until you receive a response from EPA to your notification.

2.2.3.5.1.1.5.2 Residual Biocide and Derivative Monitoring

For vessels subject to Part 2.2.3.5.1.1.1, you must conduct monitoring of the vessel ballast water discharge for any residual biocides or derivatives used in the treatment process, in part to demonstrate compliance with the conditions in Part 2.2.3.5.1.1.5.1. For instance, if chlorine is the biocide used in the ballast water treatment, you must test for residual chlorine in the vessel ballast water discharge to see if it complies with the standards in Par t 2.2.3.5.1.1.5.1.

In order to demonstrate that residual biocides or derivatives are in compliance with this permit, that substantial quantities of harmful byproducts are not produced, and provide EPA with neededEconomic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 59 information about system functionality, th e vessel operator initially must take samples according to the following:

[Table 4: Monitoring Schedule for Residual Biocides or Derivatives of the Residual Biocide]

Type approved devices for which high quality type approval data are available means either:

a) any ballast water treatment system type approved by the United States federal
government; or
b) any ballast water treatment system: i) type approved by a foreign administration; ii) for which efficacy testing was conducted by an independent 3rd party testing organization, either in accordance with the ETV protocol or in a manner consistent with the ETV protocol with respect to QA/QC procedures, the use of validated methods including appropriate volumes of representative samples, and full description and documentation of test procedures, results and analyses; and iii) all active substance data (e.g., the full data package submitted to the flag administration for type approval)
have all been made available to the US EPA.

Each sample must be tested independently and the individual results must be reported and not averaged. Samples must be tested as soon as possible after sampling, and may not be held longer than recommended for each tested constituent as given in 40 CFR Part 136. Sampling and testing shall be conducted using a sufficiently sensitive method according to 40 CFR Part 136 or may use an alternate method if allowed in Table 5 below.

[Table 5. Residual Biocides and Biocide Derivative Monitoring Requirements]

2.2.3.5.1.1.6 Ballast Water Treat ment System Recordkeeping and Reporting

Records of sampling and testing results required under Part 2.2.3.5.1.1 must be retained onboard for a period of three years in the vessel’s recordkeeping documentation. Vessels must also submit the testing results t o EPA using EPA’s e

- reporting system as part of the vessel’s annual report (unless you are eligible to submit a hard copy of the annual report).

Records of monitoring information shall include:

 The ballast water treatment system used, its type approval cer tificate, and records of whether the system is a vessel with type approved devices for which all type approval data have been made available;

 The individual(s) who performed the sampling, measurements, and/or inspections;

 The date(s) analyses and/or inspec tions were performed;

 Any sensor or other control equipment calibration and functional tests conducted during the inspection as applicable;

 The techniques or methods used for any sensor or other control equipment calibration and functional tests as applica ble;

 The date and time of all monitoring results (monitoring in Parts 2.2.3.5.1.1.2, 2.2.3.5.1.1.4, and 2.2.3.5.1.1.5, as applicable);

 The analytical techniques or methods used as applicable, and

 The results of such analyses.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 60 You must submit your monitoring data as part of your annual report. For systems already in use as of the effective date of this permit, initial sampling data must be submitted with the first annual report. For systems which are not already in use as of the effective date of this permi t, initial sampling data must be submitted on the annual report following the calendar year of the system’s first use. Data must be submitted on the Ballast Water Treatment System Report form attached to the annual report available in Appendix H of this pe rmit or submitted to EPA’s e -reporting system available at www.epa.gov/npdes/vessels/eNOI

. [2.2.3.5.1.2 Onshore Treatment of Ballast Water ]

[2.2.3.5.1.3 Use of Public Water Supply Water]

[2.2.3.5.1.4 No Discharge of Ballast Water ]

[2.2.3.5.2 Schedule for when Ballast Water Treatment Becomes BAT (and Therefore Required)]

[2.2.3.5.3 Vessels Not Required to Meet Part 2.2.3.5 Treatment Standards]

[2.2.3.6 2.2.3.6 Interim requirements for vessels not meeting the ballast water management measures in Part 2.2.3.5]

2.2.3.7 Vessels Entering the Great Lakes

In addition to complying with the requirements of this permit, all vessels that are equipped to carry ballast water and enter the Great Lakes must comply with 33 CFR Part 151, Subpart C titled: “Ballast Water Management for Control of Nonindigenous Species in the Great Lakes and Hudson River.” Vessels that operate outside the EEZ and more than 200 nm from any shore and
then enter the Great Lakes via the Saint Lawrence Seaway System must also comply with 33 CFR Part 401.30. Vessels that are unable, due to weather, equipment failure, or other extraordinary condition, to effect a BWE before entering the EEZ prior to entering the Great Lakes, must employ another m ethod of ballast water management listed in 33 CFR 151.1510 or otherwise comply with the provision of 33 CFR 151.1514.

Additionally, vessels utilizing a ballast water treatment system (see Part 2.2.3.5.1.1 of the permit)
must also conduct ballast water e xchange or saltwater flushing (as applicable) in addition to treating their ballast water if they meet the following requirements:

 The vessel operates outside the EEZ and more than 200 nm from any shore and then enters the Great Lakes via the Saint Lawrence Seaway System, and

 The vessel has taken on ballast water that has a salinity of less than 18 ppt from a coastal, estuarine, or freshwater ecosystem within the previous month.

If a vessel affected by these requirements has not taken on ballast water with a salinity of less than 18 ppt in the previous month, the master of the vessel must certify to this effect in their ballast water recordkeeping requirements before entering the Great Lakes

.

Among the options available to owners of ballast tank-equipped vessels in the 2013 VGP, the provisions related to on- board treatment of ballast water are substantively different from requirements that were contained in the 2008 VGP. This analysis therefore focuses mostEconomic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 61 specifically on these provisions. As outlined in the 2013 VGP, onboard treatment requirements
consist of t hree main components. First the VGP sets performance criteria for BWTS in terms of allowable limits on living organisms that may be discharged with ballast water. Second, the VGP
contains limits on t he amount of residual biocides or their derivatives that may be discharged into waters subject to the permit

. Third, the VGP outlines required monitoring, sampling, testing, and reporting activities aimed at ensuring that the BWTS performs as specified and that the ballast water discharged meets the standards

. The VGP also specifies additional requirements for vessels
that treat their ballast water and enter the Great Lakes.

The BWTS performance criteria contained in the 2013 VGP are generally similar to the IMO and USCG standards. According to the compliance schedule announced by USCG in its proposed rule (74 FR 44632), all newly built vessels constructed on or after January 1, 2012 will have to comply with the discharge standards summarized in Table 4-7 upon their delivery, while vessels constructed before January 1, 2012 will have to comply with the discharge standards as early as their first drydocking after January 1, 2014 or January 1, 2016, depending on their ballast water capacity. 32 This compliance schedule is roughly the same as that specified by the IMO Ballast Water Management Convention , which is set to enter into force 12 months after ratification by 30

States , representing 35 per cent of world merchant shipping tonnage. As of July 31, 2011, 28

States had ratified the Convention, representing 25.43% of world’s merchant shipping tonnage.

EPA therefore expects that the IMO convention will enter into force and/or the US Coast Guard rulemaking will be finalized by the time this permit becomes effective on December 19, 2013.

Note that some jurisdictions have different standards. For example, the State of California promulgated performance standards for ballast water discharges in that State’s water that are structured differently than the IMO D

- 2 or USCG Phase One standard as they are based on a “no detectable living organism” standard for the large r size class. The other size classes contained in the California standards are similar (but not identical) to the “Phase Two” proposed by USCG in 2009, but set a final implementation date of January 1, 2020 by which date vessels must have
zero detectable living organisms in their ballast water discharge. California also provides explicit guidelines for sampling points and methods. The States of Michigan, Minnesota, and Wisconsin
also have state

- specific ballast water discharge standards

. Other states, such as New York, Illinois, Indiana and Ohio have previousl y required ballast water treatment as part of their VGP 401 certification requirements.

Given these existing USCG, IMO, and State requirements which are generally equivalent to, or even more stringent than the 2013 VGP , EPA does not expect the performance standards stipulated in the 2013 VGP to impose an incremental cost to vessel owners, as vessels will

a lready be required to comply with IMO, USCG , and state standards.

32 Existing vessels with ballast water capacity between 1,500 and 5,000 m 3 must comply starting January 1, 2014 while existing vessels with ballast water capacity less than 1500 m 3 or greater th an 5,000 m 3 must comply starting January 1, 2016.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 62 Table 4-7. USCG Phase One and IMO D

- 2 Ba llast Water Discharge Standards.

Organism Size Class Discharge Standard

>50 μ m <10/m 3

> 10 μ m and ≤ 50 μ m <10/ml

≤ 10 μ m N/A

E. coli <250 cfu/100 ml

Intestinal enterococci <100 cfu/100 ml Toxicogenic Vibrio cholera e (human cholera) <1 cfu/100 ml

c fu = colony forming unit

In addition to the se discharge standards, the 2013 VGP also stipulates monitoring, sampling, testing, and reporting activities th at vessel owners must complete.

The purpose of the se activities is two -fold: First, to monitor the operation of the BWTS to ensure that it functions as expected and as designed by the manufacturer , and second, to characterize the discharge at the discharge point into waters subject to the permit

. Specific requirements include:

 Functionality monitoring : Physical/chemical indicators of treatment performance verify that the ballast water treatment system is operating according to the manufacturers’ requirements. Most ballast water treatment systems have control and self -diagnostic equipment that continuously measure treatment parameters to verify performance. Sensors commonly incorporated into the most frequently installed systems include flow meters, pH sensors, dissolved oxygen sensors, OPR and amperometric (TRO) sensors,
and on- line chlorine a nalyzers. Other ballast water treatment systems are provided with testing meters or kits, such as portable chlorine and dissolved ozone monitors, to verify adequate levels of treatment chemicals are being maintained within the ballast tanks. Vessel operato rs monitor and record this data and make adjustments, maintenance, or repairs to the ballast water treatment system to ensure the equipment is functioning properly.

 Monitoring equipment calibration : This requirement is meant to ensure that a ll applicable sensors and other control equipment are calibrated

, when warranted , based on device drift and as recommended by sensor and equipment manufacturers, or by ballast water treatment system manufacturers.

 Effluent biological organism monitoring : This requiremen t is i ntended to verify that the treatment system is operating properly by collecting a small volume sample and analyzing the sample for concentrations of certain indicator parameters.

 Residual biocide and derivative monitoring : While ballast water treatment technologies reduce the probability of invasion, such treatment may introduce other water quality impacts, such as toxicity. For example, the addition or in-process generation of disinfecting chemicals may result in an effluen t with some residual toxicity. Therefore,
f or vessels having ballast water treatment systems that either add or generate biocides for treatment (e.g., chlorine, chlorine dioxide, ozone, etc.) the VGP 2013 requires that owners conduct monitoring of the vess el ballast water discharge for any residual biocides to demonstrate compliance with specified action levels

.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 63 AFFECTED VESSEL POPU LATION
The total population of vessels potentially affected by practices applicable to the ballast water discharge category wa s described in Section 2.5 of this report. Table 4-7 summarizes estimates of
the total number of domestic vessels potentially subject to ballast water standards, ba sed on figures from the USCG (USCG, 2008) . Not all vessels, however

, will use onboard treatment to comply with discharge requirements. Estimates developed by King et al. (2010) suggest that less
than half of the vessels with ballast water discharge are lik ely to install onboard BWTS. The fraction varies across vessel types. Other vessels are more likely to use an alternative compliance
method such as not discharging ballast water while in regulated waters, using onshore facilities, or using freshwater as ba llast.

Further, only a subset of the BWTS installed use biocides as disinfection methods and would have the potential to discharge residual biocides and therefore be subject to the related 2013 VGP requirements. According to Lloy d’s Register (2011), about half of the 200 BWTS installed as of June 2011 use chemical disinfection methods that have the potential to discharge residual
biocides. 33

Table 4-8 . Vessel Counts for Practices Applicable to Ballast Water Treatment.

Vessel Class Vessels with Ballast

Water Tanks a Vessels Assumed to use
Onboard BWTS b BWTS with Potential to Discharge Residual
Biocides c
Commercial Fishing 819 334 167 Freight Barges

- - - Freight Ships 1,711 404 202 Passenger Vessels 185 185 93 Tank Barges

- - - Tank Ships 63 63 31 Utility Vessels 101 101 50

TOTAL 2,878 1,086 543

a Based on USCG estimates

. b Based on estimates by King et al. (2010)

. c Half of the BWTS installed are assumed to use chemical disinfection methods.

Finally, vessels that use a BWTS and enter the Great Lakes are subject to additional flushing requirements if: (1) they operate outside the EEZ and more than 200 nm from any shore and then
enter the Great Lakes via the Saint Lawrence Seaway System, and (2) they have taken on ballast water that has a salinity of less than 18 ppt from a coastal, estuarine, or freshwater ecosystem within the previous month.

EPA could not find data on the exact number of vessels that meet the two criteria above. Data on ballast water discharges in the Great Lakes and Saint

- Lawrence Seaway System (GLSLSS) by transoceanic ships in 2002 suggests that there were 46 vessel visits that year from ships with

33 These methods include ozonation, chlorination, electrolysis/electrochlorination, or most other chemical/biological

treatment.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 64 ballast on board, each discharging 10,000 m 3 , and an additional 531 visits from unballasted vessels (Cangelosi and Mays, 2006), for a total of 566,200 m 3 discharged. More recent NBIC data for 2009 show 188 vessels discharging a total of 1,050,920 m 3 of ballast water in states b ordering
the Great Lakes . This is equivalent to about a quarter of non- commercial fishing vessels assumed
to use onboard BWTS. For the purpose of this analysis, EPA distributed the vessels assumed to enter the Great Lakes according to the previously estimated number of vessels assumed to use onboard BWTS, as shown in Table 4-9

.

Table 4-9 . Vessel Counts for Practices Appli cable to Ballast Water Treatment for Vessels Entering the Great Lakes.

Vessel Class Vessels with Ballast

Water Tanks a Vessels Assumed to use
Onboard BWTS b Vessels Assumed to
Enter the Great Lakes c
Commercial Fishing 819 334

- Freight Barges

- - - Freight Ships 1,711 404 101 Passenger Vessels 185 185 46 Tank Barges

- - - Tank Ships 63 63 16 Utility Vessels 101 101 25

TOTAL 2,878 1,086 188

a Based on USCG estimates.

b Based on estimates by King et al. (2010).

c 25% of the BWTS installed are assumed to be on vessels that enter the Great Lakes

.

COST ESTIMATES

There are three main categories of c osts for complying with the ballast water treatment requirements: 1) costs associated with the pu rchase, installation , and operation of the treatment system; 2) costs associated with BWTS functionality monitoring and equipment calibration; and 3) costs associated with discharge monitoring.

For vessels that enter the Great Lakes, potential additional costs are associated with the requirement to conduct ballast water exchange.

These costs are discussed below.

Capital and O&M Costs
The USCG estimated the costs of installing and operating a BWTS compliant with its Phase One performance standards ( USCG , 2008). Capital costs range from less than $300,000 to more than $2.5 million depending on the vessel characteristics (type and size) and the type of treatment system installed

. 34 Annual operation and maintenance costs (for electricity, chemicals, crew labor, periodic maintenance, parts, training, and other logistics) are estimated to be comparatively

34 Cost estimates ranged between $258,000 for chemical treatment in offshore s u pply vessel, to more than $2.5 million to retrofit Very Large Crude Carriers (VLCCs) with ozone generating systems

.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 65 low; they amount to approximately 1/200 of the annualized capital costs, or $$1,708 per vessel

per year , on average. USCG estimated the total annualized costs to owners of the 4,758 U.S. flagged vessels that would need to install BWTS to comply with Phase One regulations at $167.5
million (2007 dollars)

. 35 These cost estimates may be higher than actual costs given the broader availability of treatment systems since the estimates were developed. Since the VGP performance standards are the same as those expected to be in effect under the USCG regulations, vessels are assumed to already have to comply with the se requirements in the baseline and the cost of installing BW TS is not an incremental cost attributable to the 2013 VGP.

Functionality Monitoring and Calibration
The second potential cost component relates to monitoring the BWT S to ensure that it is functioning properly, and as necessary, calibrating sensors and probes

. For example, this practice may involve monitoring filter s , chemical injection

, and dosage equipment, tracking energy usage of the UV system, and inspecting any other necessary components of the system to ensur e that they are working as designed and specified by the manufacturer

. Since all ballast water treatment systems are expected to come equipped with the necessary sensors and monitoring equipment, capital costs are expected to be minimal. In the unlikely ev ent that sensors and monitoring equipment need to be installed, their costs would need to be accounted for when estimating VGP compliance costs. For example, upfront capital costs for installing additional monitoring equipment for a filtration and chlorine dioxide system are approximately $10,000, or about $920 per year (annualized using a discount rate of 7 percent and life of 20 years). 36

EPA estimates that each inspection or monitoring event may require about 1.15 hour to complete (1 hour to conduct an inspection and 9 minutes to record findings) and that these events are conducted monthly . EPA further assumes that re

- calibration may be needed annually, with each calibration event requiring 8 hours of staff time and 15 minutes in recordkeeping time. The t otal annual burden of these two activities amounts to about 22 hours per year. Since compliance with
the IMO , USCG or other applicable discharge standards already implies that the vessel owner
monitors the BWTS and recalibrates sensors and probes as needed, costs specifically attributed to
the 2013 VGP are limited to any additional recordkeeping that is specific to the VGP. 37 For the purpose of this analysis, EPA estimated the additional VGP

- specific recordkeeping burden at
2 hours per year (9 minutes each month for ongoing inspections, plus 15 minutes for documenting annual calibration) . Based on an average labor rate of $ 33.72 per hour, costs for this requirement

average about $67 per vessel per year.

35 Present value costs discounted at 7 percent.

36 This is based on the purchase of a turbidity meter ($2,350) and chlorine dioxide sensor ($984) and installed costs equal to three times the equipment cost. The total installed capital cost is estimated at $9,732 (3 x $2,350 + 3 x 984).

37 California regulations ( Public Resources Code Section 71205(g)) require that the vessel owner maintain a b allast water treatment performance log on board the vessel. At a minimum, this treatment performance log must include: The dates, times, and locations of the starting and stopping of the system for the purpose of treating ballast water ; Dates, time and des criptions of any system malfunctions, including problem resolution ; Dates, times and locations of both scheduled and unscheduled maintenance of the system ; All relevant measures of system performance recorded during system operation (f or example - UV transmittance, residual chemical concentration ).Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 66 Discharge Monitoring for Biological Indica tors and Residual Biocides
The third potential cost component relates to the testing of ballast water effluent from the BWTS for the presence of bacterial indicators and residual biocides, if applicable

. While some vessel owners may already test their effl uent to ensure the proper performance of the BWTS

, this testing is not generally required to comply with the IMO or USCG discharge standards and EPA
therefore assume s that all vessels equipped with a BWTS would need to conduct additional sampling and testi ng to comply with the 2013 VGP. 38

The 2013 VGP stipulates two types of discharge monitoring: biological indicators and residual biocides (if applicable for the type of BWTS). In both instances, the VGP specifies the parameters to be analyzed and the freque ncy of monitoring, depending on the type of treatment
system installed.

The r equired b iological indicator compliance testing of ballast water effluent must be conducted

2 times per year for vessels with type approved devices for which all type approval data are available, and 4 times per year for non

- type approved devices or type approved devices for which
data are not available

. The 2013 VGP requires d ischarge testing for the presence of residual biocides, if applicable, several times during the initial 90 days of permit coverage , followed by maintenance monitoring
thereafter . The number of sampling events needed during the first 90 days (3 to 5 events ) and the frequency of subsequent monitoring events (2 or 4 events per year) is dependent on the type of system, as summarized in Table 4-10 below.

Table 4- 10 . Discharge Sampling and Testing Requirements.

Type of Monitoring Type approved devices for which all type approval data
are available Type approved devices for
which data are not available

Biological Indicato rs 2 times per year 4 times per year
Residual Biocides
Initial Monitoring a 3 times during first 90 days 5 times during first 90 days Maintenance Monitoring 2 times per year 4 times per year

a The initial monitoring is conducted only once during the period of the Permit

.

E ach sampling event involves c ollect ing ballast water effluent samples and e ither analyzing these

s amples on-board the vessel or sending the samples to an onshore laboratory for analysis. The
cost of each event consist s of labor hou rs for vessel staff and laboratory costs (including sample shipping and handling). 39

38 The State of California encourages owners to conduct regular performance testing to ensure that the treatment system is working properly, but system performance verification is not specifically required under P ublic Resources Code Section 71205(g)

.

39 While vessel owners may decide to do some analyses onboard the vessel, the use of outside laboratories is used as an upper bound on compliance costs.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 67 EPA estimated that each sampling event will require 2 hours to complete and 0.5 hour to record. Additional sampling for biocide, in the case of vessels equipped with systems that have the potential to discharge residual biocide, is estimated to require 1 hour to complete, and 0.5 hour to
record. Table 4-11 presents assumed incremental burden and cost estimates for discharge sampling and analytical testing of ballast water discharges.

Table 4- 11

. Annual per vessel cost of ballast water requirements

.

Practice Incremental
Burden (hours) Lab and
Incidental

Costs Frequency (# /year) Annual

Cost a e

Capital and O&M costs Not applicable (no incremental cost)

BWTS monitoring b 0.15 None 12 $60.70

BWTS calibration c 0.25 None 1 $8.43 If Using Type approved devices for which all type approval data are available Biological sampling and testing d 2.50 $150 2 $ 468.61 Initial biocide sampling and testing e 1.50 $150 3 $97.84

Maintenance b iocide sampling and testing f 1.50 $150 2 $ 401

. 17 If Using Type approved devices for which data are not available Biological sampling and testing d 2.50 $150 4 $937. 22 Initial biocide sampling and testing e 1.50 $150 5 $ 195

. 68
Maintenance biocide sampling and testing f 1.50 $150 4 $802. 33

a Annual cost calculated as burden hours times the average labor rate of $ 33.72/hour plus lab and incidental costs times the frequency

. b Burden associated with the additional recordkeeping that may be needed under the VGP.
c Burden associated with the additional recordkeeping that may be needed under the VGP.
d Testing for E. coli, enterococci, and total live bacteria.

e Annual cost of the initial biocide sampling and testing represents one

- time costs of initial testing annualized over 5

years (at 7% discount rate) of the VGP and assumes that the initial round of biocide sampling and testing replaces one periodic monitoring event.

f Based on testing for trihalomethanes or bromoform.

Note that EPA generally assumed that vessels will test for the presence of residual biocides and their corresponding derivatives and analytes listed in Table 5 of the 2013 VGP, namely: alkylamines, chlorine or chlorine dioxide, methadione, ozone, peracetic acid. In instances where the biocide used or produced by the BWTS and its derivatives is not one listed in the 2013 VGP, the vessel owner will have to conduct whole effluent toxicity (WET) testing. The requirements for such testing are similar to requirem ents that were contained in the 2008 VGP, and relatively few vessels are expected to conduct WET testing. Therefore, EPA assumed that this provision does not represent an incremental cost.

Additional Operating Costs for Vessels Entering the Great Lakes

Ce rtain vessels that use an onboard BWTS and enter the Great Lakes must conduct ballast water exchange or saltwater flushing (as applicable) in addition to treating their ballast water. This requirement has the potential to increase operating costs for these vessels by increasing the volume of water exchanged and treated. To estimate the incremental costs, EPA relied on estimates of the operating cost for ballast water treatment and exchange developed by the U.S.
Coast Guard (USCG, 2008), summarized in Table 4-12

.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 68 Table 4- 12 . Ballast Water Treatment and Exchange Costs.

Practice Unit Cost ($/m 3 ) c

Treatment a $0.259 Exchange b $0.035

a Based on costs in Table 3.6 of USCG (2008). Represents the average cost across different treatment systems (chlorine generate, chemical apply, filter and radiate, deoxygenate, and ozone generate) for Handy bulk carriers

, escalat ed to 2010 dollars using CCI

. b Based on costs in Table B

- 3 of USCG (2008). Represents the average cost of systems capable of treating 750 m 3 /h our and 2,000 m 3 /h our, escalated to 2010 dollars using CCI

. c Cost originally stated in 2007 dollars were e scalat ed to 2010 dollars using CCI ( adjustment factor = 1.1049)

.

Reporting
Vessel owners must submit data on their compliance with ballast water treatment standards as part of their annual reporting to EPA. The incremental burden of compiling the information collected during each inspection or sampling event for use in the existing annual report is assumed to be negligible relative to the estimated burden of each event and of the annual report

.

SENSITIVITY ANALYSIS
EPA estimated the potential incremental costs to vessel owners using the cost input values presented above and the following assumptions.

Ballast Water Treatment Costs

Given existing requirements assumed in the baseline, EPA assumed that no additional vessel will
install a BWTS to comply specifically with the VGP discharge standards. Therefore, no incremental capital and operation costs are attributable to the 2013 VGP.

Performance Monitoring Costs
 Vessel population : EPA estimated the population of vessels potentially subjec t to the discharge standard based on figures presented in USCG (2008). Only a fraction of these vessels, however, may ultimately install a BTWS to comply with the discharge requirements. Based on estimates presented in King et al. (2010), EPA assumed that about 40 percent of vessels will install a BTWS in the low end estimate , and 60 percent in the high end estimate. This subset of vessel is assumed to conduct performance monitoring.

 Baseline and Incremental Costs: BWTS already include the necessary instru ments to monitor performance. Further, vessel owners are assumed to already comply with manufacturers’ recommendation concerning the monitoring and calibration of monitors and probes as part of their existing operations. Incremental costs are assumed to co nsist of recordkeeping requirements specific to the 2013 VGP and are the same in the low and high end estimates ( Table 4-11 ).Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 69 Effluent Sampling and T esting Costs
 Vessel population : The types of tests needing to be performed for each vessel depends on the type of system used to disinfect the effluent . All vessels that use a BWTS will have to conduct sampling and testing for biological parameters (E. coli, enterococci, etc.). O nly some systems have the potential to discharge residual biocide , however, and would have to test for the presence of biocides in the effluent

. Systems that have the potential to discharge residual biocides are those that disi nfect using chemical inactivation (using chlorine or other biocide such as menadione). Systems that use physical disinfection (UV, deoxygenation, cavitation, heat) do not have the potential to discharge residual biocides and vessels equipped with these sys tems would not incur the related testing cost. Based
on information available from Ll oy d’s Register , about half of the BWTS installed on
vessels will use some form of chemical disinfection with the potential to discharge
residual biocide. EPA therefore ass umes that 100 percent of vessels using a BWTS will conduct sampling and testing for biological indicators , whereas between 50 percent (low end) and 75 percent (high end) of the vessels with BWTS incur incremental costs for biocide sampling and testing.

 Sampling frequency: The frequency of biocide testing depends on the type of BTWS installed, and in particular, whether the device is type -approved in the U.S. (or data have been made available to EPA). In general, EPA assumes that BTWS manufacturers will
wil lingly share their data to gain approval in the U.S. as they have market incentives to do so. Nevertheless, EPA conservatively assumed that some vessels may use BTWS that have not been type approved in the U.S. For the low end estimate, EPA assumes that 1p ercent of vessels use BWTS that are not type -approved in the U.S. and would be subject to the more frequent testing requirements. This fraction is assumed to be 5 percent in the high end estimate.

 Baseline: None of the vessels subject to the sampling and testing requirement are assumed to conduct sampling and testing in the baseline. Therefore, the costs of conducting biological sampling and testing (and biocide sampling and testing, if applicable) are assumed to be incremental costs attributable to the 2013 VGP

.  Unit Costs: Assumed unit costs are the same in the low end and high end estimates ( Table 4-11 ). Costs per vessel depend on the type of BWTS used. As described above, EPA assumes that 1 percent and 5 percent of vessels may use type approved devices for
which data are not available in the low and high end estimates, respectively. The costs per vessel are then calculate d as the weighted average annual frequency of monitoring events multiplied by the cost of each monitoring event. For example, for biological monitoring, this cost is $473.30 per vessel per year for the low end estimate (0.99 x 2 + (1 -0.99) x 4) x $234.31)

Vessels Entering the Great Lakes
 Vessel population : EPA estimated the population of vessels potentially subject to the
Great Lakes

- specific requirements based on NBIC data on the number of unique vesselsEconomic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 70 (188 vessels) that discharged ballast water in states adjoining the Great Lakes in 2009 (NBIC, 2011). 40 Only a fraction of these discharges, however, are applicable discharges, i.e., took place within the Great Lakes , would meet the VGP applicability criteria (i.e.,
vessel operates outside the EEZ and more than 200 nm from shore and has taken on ballast with a salinity of less than 18 ppt), and involved vessels that use an onboard

BWTS. The data is not sufficiently detailed to estimate the exact number of vessels and associated discharges subject to the Great Lakes

- specific VGP requirement. For the purpose of this analysis, EPA assumed that half the discharged volume reported in states adjoining the Great Lakes would be subject to the Great Lakes

- specific exchange requirements.

 Volume Exchanged and Treated: Based on NBIC data for 2009, vessels discharged a total of 1,050,779 m 3 of ballast water that year, or an average of 5,590 m 3 per discharging vessel per year. Some vessels use a flow -through exchang e method involving the pumping of three times the ballast tank capacity while other vessels simply empty and
refill their tank . The volume exchanged affects operational costs by increasing pumping
and treatment costs. In the absence of information on the v olume of water exchanged using each of these two methods , EPA assumed that 0 to 50 percent of vessels conduct flow through exchange for the low and high end estimate s, respectively

. This assumption
is combined with the assumption regarding the fraction of vessel visits involving applicable discharges discussed in the previous paragraph (50 percent) to estimate the volume exchanged and treated . Thus, for the low end estimate, EPA assumed that 525,460 m 3 of ballast water of water must be exchanged and treated (0.5 × 1,050,920 m 3 ). For the high end estimate, EPA assumed that 262,730 m 3 are exchanged using the emptyre fill method (half of the volume calculated above) , and 788,190 m 3 are exchanged using
the flow -through method (three times the remaining volume)

.  Baseline: EPA assumed that all exchanges and treatment costs are attributable to this requirement.

The estimated cost per vessel for each practice and the total cost associated with all vessels are summarized in Table 4-13

.

40 Another 751 vessels reported no discharge.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 71 Table 4- 13

. Ballast W ater Treatment Sensitivity Analysis.

Vessel Class Number of Vessels Annual Cost per
Vessel Total Annual Cost

Low End Estimate BWTS Monitoring Commercial Fishing 327 $69.13 $22,633 Freight Barges

- - - Freight Ships 685 $69.13 $47,321 Passenger Vessels 74 $69.13 $5,122 Tank Barges

- - - Tank Ships 25 $69.13 $1,733 Utility Vessels 40 $69.13 $2,780
Monitoring TOTAL 1,151 $79,589 Sampling and Testing (biological) Commercial Fishing 327 $ 473.30 $154,964 Freight Barges

- - $

- Freight Ships 685 $ 473.30 $324,004 Passenger Vessels 74 $ 473.30 $35,068 Tank Barges

- - $

- Tank Ships 25 $ 473.30 $11,868 Utility Vessels 40 $ 473.30 $19,032 Biological Sampling TOTAL 1,151 $544,935
Sampling and Testing (biocides) Commercial Fishing 164 $802.32 $82,508 Freight Barges

- - $

- Freight Ships 342 $802.32 $172,510 Passenger Vessels 37 $802.32 $18,671 Tank Barges

- - $

- Tank Ships 13 $802.32 $6,319 Utility Vessels 20 $802.32 $10,133 Biocides Sampling TOTAL 576 $290,141

Great Lakes

- Specific Requirements Commercial Fishing

- - $

- Freight Barges

- - $

- Freight Ships 101 $819.47 $82,766 Passenger Vessels 46 $819.47 $37,948 Tank Barges

- - $

- Tank Ships 16 $819.47 $12,842 Utility Vessels 2 5 $819.47 $20,594 Biocides Sampling TOTAL 188 $154,151

Low End Total $ 1,068,820Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 72 Vessel Class Number of Vessels Annual Cost per
Vessel Total Annual Cost High End Estimate BWTS Monitoring Commercial Fishing 491 $69.13 $33,951 Freight Barges

- - $

- Freight Ships 1,027 $69.13 $70,987 Passenger Vessels 111 $69.13 $7,683 Tank Barges

- - $

- Tank Ships 38 $69.13 $2,600 Utility Vessels 60 $69.13 $4,170
Monitoring TOTAL 1,727 $119,391 Sampling and Testing (biological) a Commercial Fishing 491 $937.20 $241,651 Freight Barges

- - $

- Freight Ships 1,027 $937.20 $505,253 Passenger Vessels 111 $937.20 $54,685 Tank Barges

- - $

- Tank Ships 38 $937.20 $18,507 Utility Vessels 60 $937.20 $29,678 Biological Sampling TOTAL 1,727 $849,774
Sampling and Testing (biocides) a Commercial Fishing 368 $802.32 $277,508 Freight Barges

- - $

- Freight Ships 770 $802.32 $580,224 Passenger Vessels 83 $802.32 $62,799 Tank Barges

- - $

- Tank Ships 28 $802.32 $21,253 Utility Vessels 45 $802.32 $34,082 Biocides Sampling TOTAL 1,295 $975,866

Great Lakes

- Specific Requirements Commercial Fishing

- - $

- Freight Barges

- - $

- Freight Ships 101 $1,638.93 $165,532 Passenger Vessels 46 $1,638.93 $75,895 Tank Barges

- - $

- Tank Ships 16 $1,638.93 $25,685 Utility Vessels 2 5 $1,638.93 $41,189 Biocides Sampling TOTAL 188 $308,301 High End Total $2, 253
, 333

Total may not add up due to rounding.

4.2.4 A NTI -F OULING HULL C OATINGS

PERMIT REQUIREMENTS
The 2013 VGP clarifies the 2008 VGP requirements regarding the use of TBT, whether or not used as a biocide, as well as the use of other non-TBT organotin compounds used as catalysts.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 73 AFFECTED VESSEL POPU LATION

Since the Global Anti -fouling System Treaty came into effect on September 22, 2008 and the 2008 VGP prohibited the use of TBT on all vessels, few vessels are expected to still use TBT on
their hulls.

Permit Text :

2.2.4 Anti -Fouling Hull Coatings/ Hull Coating Leachate

 Al l anti -fouling hull coatings subject to registration under FIFRA (see 40 CFR § 152.15) must be registered, sold or distributed, applied, maintained, and removed in a manner consistent with applicable requirements on the coatings’ FIFRA label.

 For anti-fouling hull coatings not subject to FIFRA registration (i.e., not produced for sale and distribution in the United States), hull coatings must not contain any biocides or toxic materials banned for use in the United States (including those on EPA’s List of

B anned or Severely Restricted Pesticides). This requirement applies to all vessels, including those registered and painted outside the United States.

At the time of initial application or scheduled reapplication of anti-fouling coatings, you must give cons ideration, as appropriate for vessel class and vessel operations, to the use of hull coatings with the lowest effective biocide release rates, rapidly biodegradable components (once separated from the hull surface), or non- biocidal alternatives, such as si licone coatings.

Some ports and harbors are impaired by copper, a biocide used commonly in anti-foulant paints. These waters include Shelter Island Yacht Basin in San Diego, California, and waters in and around the ports of Los Angeles/Long Beach. A comple te list of such waters may be found at www.epa.gov/npdes/vessels. When vessels spend considerable time in these waters (defined as spending more than 30 days per year), or use these waters as their home port (i.e., house boats, ferries or rescue vessels), vessel owners/operators shall consider using anti-fouling coatings that rely on a rapidly biodegradable biocide or another alternative rather than copper-basedcoatings. If after consideration of alternative biocides, vessel operators continue to use copperbased antifoulant paints, they must document in their recordkeeping documentation how this
decision was reached.

The discharge of Tributyltin (TBT) from any source (whether used as a biocide or not) or any other organotin compound used as a biocide is pr ohibited by this permit. Therefore, vessel owners/operators covered by this permit have a zero discharge standard for TBT (whether or not used as a biocide) or any other organotin compound used as a biocide. You may not use an antifoulant coating containing TBT or any other organotin compound used as a biocide. If the vessel has previously been covered with a hull coating containing TBT (whether or not used as a biocide) or any other organotin compound used as a biocide, vessels must be effectively overcoated so that no TBT or other organotin leaches from the vessel hull or the TBT or other organotin coating must have been removed from the vessel’s hull.

When used as a catalyst, an organotin compound other than TBT (e.g., dibutyltin) is not to be present ab ove 2500 mg total tin per kilogram of dry paint. Furthermore, the coating shall not be designed to slough or otherwise peel from the vessel hull. Incidental amounts of coating discharged by abrasion during cleaning or after contact with other hard surfaces (e.g., moorings) are not prohibited.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 74 COST ESTIMATES
No requirements within this discharge category for TBT require cost analysis because these requirements already apply in the baseline . EPA assume s that the requirements for other anti

fouling paints ha ve negligible cost implications . Finally, while v essel owners that decide, after
consideration of alternative biocides , to continue to use copper based antifoulant paints will have
to document the basis of their decision , these documentation requirements are anticipated to represent a minimal additional burden for these vessel owners relative to the annual paperwork
burden discussed in Section 4.4

.

4.2.5 A QUEOUS F ILM -F ORMING F OAM

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only vessels that potentially incur incremental costs for these requirements are commercial fishing
vessels as all other vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements . However, EPA has determined that commercial fishing vessels typically do not have firefighting systems that require regular AFFF discharge. T his dis charge category is
assumed to have zero incremental cost

.

4.2.6 B OILER/ E CONOMIZER B LOWDOWN

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only
vessels that potentially incur incremental costs for these requirements are comme rcial fishing vessels as all other vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. However, EPA has determined that practices applicable to
boiler/economizer blowdown discharges have negligible costs and/or the industry is assumed to currently practice the Permit requirements. This discharge category is assumed to have zero
incremental cost.

4.2.7 CATHODIC PROTECTION

PERMIT REQUIREMENTS
The 2013 VGP retains the requirements present in the 2008 VGP but adds specific practices to prevent the growth of fouling organisms at the sacrificial anode location, when feasible

.
Permit Text [Emphasis added to highlight additional requirement of the 2013 VGP]:

Cathodic protection must be maintained to prevent the corrosion of the ship’s hull. The discharge of zinc, magnesium, and aluminum are expected from properly functioning cathodic protection sacrificial electrodes. However, vessel operators must minimize the flaking of large, corroded portions of these anodes. Sacrifi cial anodes must not be used more than necessary to adequately prevent corrosion of the vessel’s hull, sea chest, rudder, and other exposed areas of the vessel. Vessel operators must appropriately clean and/or replace these anodes during periods of

mainten ance (such as drydocking), so that release of these metals to waters is minimized. Furthermore, when feasible, sacrificial anodes should be flush

- fitted to the hull, or vessel operators must fill the space between the anode and hull backing to remove the p otential for hotspots for fouling organisms

.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 75 Vessel operators should note that magnesium is less toxic than aluminum and aluminum is less toxic than zinc. If vessel operators use sacrificial electrodes, they must select electrode devices
with metals that a re less toxic to the extent technologically feasible and economically practicable
and achievable. If a vessel selects aluminum, they must document in their recordkeeping documentation why they made this selection, and why use of magnesium is not appropriate. Likewise, if a vessel selects zinc, they must document why they did not select magnesium or
aluminum

. EPA recommends the use of Impressed Current Cathodic Protection (ICCP) in place of or to reduce the use of sacrificial electrodes when technologically feasible (e.g., adequate power sources, appropriate for vessel hull size and design), safe, and adequate to protect against corrosion, particularly for new vessels. If vessel operators use ICCP, they must maintain dielectric shields to prevent flaking

.

AF FECTED VESSEL POPULA TION
Based on the description of practices within this discharge category, all vessel s with steel hulls
within each of the vessel classes are potentially subject to the cathodic protection practices

. Data
from MISLE and WTLUS indicates that approximately 93 percent of vessels overall have steel hulls, although the fraction of steel hulled vessels varies by vessel type from 51 percent of passenger vessels to over 95 percent of freight barges and tank barges . C ommercial fishing
vessels , 79 percent of which are steel hulled, are newly covered by the VGP and therefore potentially incur incremental costs for this discharge category, while other types of vessels only potentially incur incremental costs from the additional requirements pertaining to fouling organisms. The population potentially affected by practices applicable to the cathodic protection discharge category is shown in Table 4-14.

Table 4- 14

. Vessel Counts for Cathodic Protection Practices

.

Vessel Class Vessel Count a

Commercial Fishing 1,967 Freight Barges 38,834 Freight Ships 730 Passenger Vessels 1,018 Tank Barges 6,941 Tank Ships 276 Utility Vessels 5,235

TOTAL 55,002

a Includes steel hulled vessels only

.

COST ESTIMATES

Consistent with information obtained while developing the 2008 VGP, EPA assumes that there

are no incremental cost s to vessels for implementing cathodic protection on applicable vessels
since steel hulled vessels generally have either an ICCP or a sacrificial electrodes system of cathodic protection (EPA, 2008)

. EPA expects that this is also the case for steel hulled
commercial fishin g vessels newly covered by the 2013 VGP.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 76 Practices aimed at preventing potential hotspots for fouling organisms (anodes to be flush- fitted to the hull or a backing to be inserted in the space between the anode and the hull) are assumed to already be imple mented and therefore do not represent incremental costs on vessel owners.

A sensitivity analysis was performed to estimate potential costs of cathodic protection installation for vessels that will opt to purchase an ICCP system in accordance with the Permi t recommendations. In the sensitivity analysis EPA has estimated a potential low and high incremental cost associated with cathodic protection installation. These low and high estimates are based upon the percentage of vessels that may need to install an u pdated system.

Practices associated with maintenance and replacement of the cathodic protection system will not incur incremental costs, and no sensitivity analysis is performed since these practices are regularly performed when deemed necessary.

Finally, documentation of the anode selection is anticipated to represent a minimal additional burden for the subset of vessel owners that use aluminum or zinc, relative to the annual paperwork burden discussed in Section 4.4

.

SENSITIVITY ANALYSIS
Costs of installing either an ICCP or a sacrificial electrodes system of cathodic protection were estimated based upon communication with a cathodic protection manufacturing company (see EPA, 2008) . The cost input values of cathodic protection system installation are shown in Table

4-15 (escalated to 2010 doll ars)

, and the estimates/assumptions derived for each practice are
described below.

Table 4- 15

. Cathodic Protection Installation Cost Estimates (2010$)

.

Vessel Class Low End
Installation Cost High End
Installat ion Cost Average Installation

Cost Commercial Fishing $16,574 $19,889 $18,232

 Installation Costs: Cost estimates were obtained from a representative from a cathodic protection manufacturing company. The figures are dependent upon the area of steel on the hull as well as other minor components. Commercial fishing vessels are assumed to have costs similar to those of freight ships. The c ost estimates shown in Table 4- 15 were originally provided in 2008 dollars and escalated to 2010 dollars using the consumer cost
index from the Bureau of Labor Statistics

.  Baseline: For the l ow end estimate, EPA assumes that no commercial fishing vessel will install an ICCP system due to the Permit recommendations. For the high end estimate, the
fraction is assumed to be 5 percent.

 Equipment Life : The ICCP system is expected to last for the lifetime of the vessel. Thus, the total incremental cost of the device is annualized at a 7 percent discount rate over
30 years to estimate the annual cost per vessel pres ented in Table 4-16

. The cost per vessel and the total cost associated with all vessels are presented in Table 4-16

. At the low end, there is no incremental cost . At the high end, if 5 percent install an ICCP system, the potential incremental cost is approximately $144,500.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 77 Table 4- 16

. Cathodic Protection Sensitivity Analysis, Purchase of a Cathodic Protection System.

Vessel Class Vessel

Count a % Vessels
Need ing to Purchase System Annual Cost per
Vessel b Total
Annual Cost

Low End Estimate
Commercial Fishing 1,967 0 % $1,469.22 $ 0
Low End TOTAL 1,967 $ 0 High End Estimate Commercial Fishing 1,967 5% $1,469.22 $144,496 High End TOTAL 1,967 $144,496

a Applies to steel hulled vessels only.
b Annualized at a 7% discount rate over 30 years.

4.2.8 C HAIN L OCKER E FFLUENT

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only vessels that are potentially impacted by this section are commercial fishing vessels as all other vessels currently covered by the 2008 VGP are a ssumed to comply with applicable requirements. However, EPA has determined that practices applicable to chain locker effluent discharges are found in only a subset of vessel classes. The practices in this category are applicable to freight ships, tank ship s, and various utility vessels; they do not apply to the other vessel classes because their anchors are rarely or never deployed or other equipment is used (e.g., anchor cable). Since the 2013 VGP requirements are unchanged from current practices and since chain locker effluent discharges are not applicable to newly covered commercial fishing vessels, no vessel is assumed to incur incremental cost as a result of the 2013 permit

. Furthermore, EPA’s analysis of the 2008 VGP had found that most practices in the chain locker effluent discharge category were already implemented by the industry even before the VGP was promulgated (EPA, 2008). For vessel types to which the discharge category applies, EPA had performed a sensitivity analysis only for the potential incremental costs associated with washing down the anchor chain as it is being hauled out of the water. In the sensitivity analysis EPA estimated a potential low and high incremental cost associated with washing down the anchor
chain ranging from 0 to $4.74 per vessel per year (in 2008$).Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 78 4.2.9 C ONTROLLABLE P ITCH P ROPELLER AND T HRUSTER H YDRAULIC F LUID AND

O THER O IL S EA I NTERFACES I NCLUDING L UBRICATION D ISCHARGES F ROM

P ADDLE W HEEL P ROPULSION, S TERN T UBES, T HRUSTER B EARINGS,

S TABILIZERS, R UDDER B EARINGS, A ZIM UTH T HRUSTERS, P ROPULSION P OD

L UBRICATION, AND W IRE R OPE AND M ECAHNICAL E QUIPMENT S UBJECT TO

I MMERSION

PERMIT REQUIREMENTS
The Permit requirements to minimize the discharge of oil are generally unchanged. The 2013 VGP, however, introduces requirements for new build vessels (those constructed after December 19, 2013) to use environmentally acceptable lubricants (EALs) in all oil

- to

- sea interfaces. 41 An existing vessel (one constructed before December 19, 2013) must use EALs in their oil

- to

- sea interfaces unless it is technically infeasible

. If an existing vessel finds it is technically infeasible to use an environmentally acceptable lubricant for their vessel, the owner/operator must explainwhy they cannot do so in their recordkeeping documentation, and must note the use of a nonenvironmentally acceptable lubricant in the vessel’s Annual Report.

Permit Text [Emphasis added to highlight new requirements of the 2013 VGP .] :
2.2.9 Controllable Pitch Propeller and Thruster Hydraulic Fluid and Other Oil- to

- Sea Interfaces Including Lubrication Discharges from Paddle Wheel Propulsion, Stern Tubes, Thruster Bearings, Stabilizers, Rudder Bearings, Azimuth Thrusters, Propulsion Pod Lubrication, and Wire Rope and Mechanical Equipment Subject to Immersion

The protective se als on controllable pitch propellers, azimuth thrusters, propulsion pods, rudder bearings, or any other oil- to -sea interfaces must be maintained in good operating order to minimize the leaking of hydraulic oil or other oils. The vessel owner/operator must not discharge oil in quantities that may be harmful as defined in 40 CFR Part 110 from any oil- to

- sea interface. If possible, maintenance activities on controllable pitch propellers, thrusters, and other oil- to

- sea interfaces should be conducted when a ves sel is in drydock.

Minimize maintenance activities on stern tube seals when a vessel is outside of drydock. If maintenance or emergency repair must occur on stern tubes or other oil- to

- sea interfaces which have a potential to release oil in quantities tha t may be harmful as defined in 40 CFR Part 110, appropriate spill response equipment (e.g., oil booms) must be used to contain any oil leakage. Operators of the vessel must have ready access to spill response resources to clean up any oil spills.

After applying lubrication to wire rope and mechanical equipment subject to immersion, wire ropes, and other equipment must be thoroughly wiped down to remove excess lubricant.

All vessels constructed on or after December 19, 2013 must use an environmentally accept able

lubricant in all oil

- to

- sea interfaces. “Environmentally acceptable lubricants” means

41 Part 7 of the permit defines environmentally acceptable lubricants to denote a lubricant that is biodegradable, exhibits low toxicity to aquatic organisms and has a low potential for bioaccumulation.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 79 lubricants that are “biodegradable” and “non-toxic” and are not “bioaccumulative” as defined
in Appendix A of this permit.

For all vessels built before December 19, 2013, unless technically infeasible, owners/operators must use an environmentally acceptable lubricant in all oil to sea interfaces. If a vessel is unable to use an environmentally acceptable lubricant, you must document in your recordkeeping documentation consistent with Part 4.2 why you are unable to do so, and must report the use of a non- environmentally acceptable lubricant to EPA in your Annual Report. Use of an environmentally acceptable lubricant does not authorize the discharge of any
lubricant in a quantity that may be harmful as defined in 40 CFR Part 110.

AFFECTED VESSEL POPU LATION
As for other discharge categories, commercial fishing vessels which are newly covered under the 2013 VGP may incur incremental costs of all practices contained under this category, while other vessel types are already complying with the 2008 VGP and only incur incremental costs, if any, associated with the revised requirements to use environmentally acceptable lubricants.

Based on the description of practices within this discharge category, all vessels have the potential to discharge oil due to oil- to

- sea interface and a subset of vessel classes , including c ommercial fishing vessels, freight ships, tank ships, and various utility vessels have the potential to discharge controllable pitch propeller hydraulic fluid . No other vessel classes are expected to operate controllable pitch propellers.

In establishing the different requirements for new build vessels versus existing vessels, EPA considered the processes employed and potential changes which might be necessary by some existing vessel s to use EALs. M any existing vessels can use EALs which are compatible with their existing equipment. However, the requirement is specified as to be only required where
technicall y feasible. This recognizes the possibility that while it is technically feasible for many existing vessels to use EALs, it might not be technically feasible for these vessels to use EALs
with all existing equipment. In contrast, n ew build vessels can sele ct equipment during design and construction which is compatible with EALs. Furthermore, they can design additional onboard storage area for EALs if they choose to use traditional mineral based oil for engine lubrication (thereby needing two types of oils o n-hand).

The population potentially affected by practices applicable to this discharge category is shown in
Table 4-17

.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 80 Table 4- 17

. Vessel Counts for General Oil

- to

- Sea Interface and Controllable Pitch Propeller Hydraulic Fluid Practices

.

Vessel Class Vessel Count (oil to sea interface) Vessel Count (controllable pitch propeller) Commercial Fishing 2,326 2,326 Freight Barges 39,760

- Freight Ships 812 812 Passenger Vessels 1,970

- Tank Barges 7,144

- Tank Ships 332 332 Utility Vessels 6,258 6,258

TOTAL 58,602 9,728

COST ESTIMATES
Based upon the industry input to the 2008 VGP, maintenance of the controllable pitch propeller is already performed when in drydock and, when applicable, oil booms and oil absorbent pads are purchased and are in use. Therefore, requirements present in the 2008 VGP are assumed to impose no incremental costs on commercial fishing vessels newly covered by the 2013 VGP.

The use of environmentally preferred lubricants may impose incremental costs on all covered
vessels to the degree that these products are more (or less) expensive than the con ventional products.

For environmentally acceptable lubricants, EPA obtained cost data from retailers of marine
lubricants. Pricing data suggest a wide variability in the cost of different types of lubricants, depending on their use and formulation. On average, EPA found that EALs are 38 percent more expensive than conventional (e.g., mineral-based lubricants) although this difference is not always present and some EALs appear to be priced similarly as synthetic lubricants. These findings appear to be consi stent with input from industry representatives EPA interviewed who indicated that EALs from vegetable sources are 10 percent to 50 percent more expensive than conventional lubricants but also noted that synthetic -based lubricants tend to be significantly more expensive than mineral- based lubricants (twice to four times more expensive). 42

Publicly available information on the price of EALs tends to be for retail purchases of relatively small quantities of lubricants by recreational boaters. These prices are likely to be significantly higher than the price paid by the owner of a larger vessel such as those covered by the VGP. EPA
contacted several manufacturers and distributors of EALs to get information on large quantity pricing, but representatives contacted were generally unable to provide average price s or price differences between the pr oducts, noting that this type of information is proprietary. One industry representative offered an illustrative example of the price difference between EALs and

42 Anecdotal estimates on cost differences between EALs and conventional lubricants varied widely. Industry representatives generally noted that EALs are more expensive than mineral

- based lubricants with one industry representative offering an approximate ratio at 3 to 1.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 81 conventional lubricants with the unit price for a standard lubricant ($7.80/gallon) being half that
of the equivalent biodegradable, vegetable

- based product ($15.40/gallon). 43

Information on average consumption of lubricants by different types of vessels was similarly difficult to obtain from published sources or directly from vessel owners with i ndustry representative noting that the quantities vary widely across vessels.

In one published study, Etkin (2010) estimated the volume of oil leaks from vessels based on prior studies and five years of data of in

- port lubricant replacement rates from a lu bricant supplier. S ources of operational discharges discussed in the study include deck machinery and in

water (submerged) machinery such as stern tube bearing s , thruster gearboxes, and horizontal
stabilizers. The d ata show leak rates that vary by vessel t ype, condition, age, and maintenance. The average daily stern tube lubricant consumption rate across vessel types is reported as 2.6 liters per day, but range s from less than 1 liter per day to 20 liters per day. The highest average

rate is associated with barge carrier s while several utility vessels (e.g., patrol vessel, dredger) and fishing vessels had rates in the lower end of the range. In addition to stern tube leakage, Etkin (2010) also provides estimates of lubricant leakage from deck machinery and i n- water submerged machinery . Consumption of oil used as lubricant in- water submerged applications is estimated to range between 1 and 29 liters per port visit, depending on the type of vessel. Values derived from Etkin (2010) are within the range of annual consumption estimates EPA was gathered anecdotally from industry representative for different types of vessels

. For the sensitivity analysis presented below, EPA used the illustrative average oil consumption

rates due to leakage and illustrative incremental costs to estimate potential incremental costs to
vessel owners for replacing conventional lubricants with EALs in all oil

- to

- sea interfaces.

SENSITIVITY ANALYSIS
Consumption estimates are based on values presented in Etki n (2010) as summarized in Table

4-18

. These estimates represent consumption of lubricants due to leakage. To the degree that they
do not account for r eplacement of oil remaining in the various systems, these values may underestimate total lubricant consumption.

43 The products are considered to offer similar perform ance and characteristics. Note that EALs may offer performance advantages over mineral

- based oils: i nformation obtained from another manufacturing company representative suggests that EALs may provide measurable performance advantages, including an extende d life (50 to 100 percent increase is reported) when compared to conventional mineral

- based oils.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 82 Table 4- 18 : Lubricant Consumption Rates by Vessel Class

.

Vessel Class Consumption
rate for stern tube bearing (liters/day) Consumption
rate for all

other submerged equipment (liters/day) Total (liters/day) Total (gal lons /day) Total (gal lons /year) a

Commercial Fishing 2.0 3.0 5.0 1.3 121 Freight Barges

- 1.0 1.0 0.3 24 Freight Ships 7.0 7.0 14.0 3.7 337 Passenger Vessels 2.0 3.3 5.3 1.4 128 Tank Barges

- 1.0 1.0 0.3 24 Tank Ships 5.0 1.5 6.5 1.7 157 Utility Vessels 1.5 6.0 7.5 2.0 181

Source: Etkin (2010) . C onsumption rates are attributed to each vessel class based on the average rates for corresponding types of vessel presented in Etkin (2010)

. a Assumes that consumption while in port covers days when vessels are traveling between ports. Vessels are assumed to spend 3 days in travel for each day in port.

The sensitivity analysis also uses the following assumptions.

 Lubricant Cost s: A wide range of lubricants are used in marine applications with very diverse prices and quantities used. EPA was not able to obtain specific data on the relative consumption rates of different categories of lubricants by vessels covered by the

VGP . As an upper bound estimate of the potential incremental cost, EPA assumed a price difference of 120 percent, based on the illustrative example provided by one industry representative ($15.40 per gallon vs. $7.80 per gallon). For the lower bound estimate,
EPA assumed a 5 0 percent difference in price, based on EPA’s review of retail prices for different types of lubricants marketed for marine application, which found an average price difference of 38 percent. The same baseline price of $7.80 per gallon was assumed for both the low and high bound estimates , based on the illustrative example discussed
earlier in this sec tion. The incremental cost incurred by a vessel owner is therefore assumed to range between $4 and $8 per gallon.

 Baseline: As low end estimate, EPA assumed that 5 percent of existing and 15 percent of new vessels use EALs (or alternatively, EALs represent 2.5 percent and 5 percent of
lubricant uses) in the baseline . As high end estimate, EPA assumed that only 2.5 percent of existing vessels and 5 percent of new vessels use EALs.

 Implementation Rate: As low end estimate, EPA assumed that all new vessels and

50 percent of existing vessels would replace their existing lubricants with EALs while for the high end estimate, EPA assumed that all new vessels and 75 percent of existing
vessels would do so.

The cost per vessel for each practice and the total cost associated with all vessels are provided in
Table 4-19

. The annual incremental costs for all vessels range from approximately $6.0 million to $18.3 million.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 83 Table 4- 19

. Environmentally Acceptable Lubricants Sensitivity Analysis

.

Vessel Class Vessel Count a % Vessels
where
Practice is Applicable b Annual Cost

per Vessel Total Annual

Cost
Low End Estimate (Average Incremental Cost $ 4 /gallon)

Use EAL Commercial Fishing 2,315 49% $482 $534,654 Freight Barges 39,757 48% $96 $1,821,140 Freight Ships 765 50% $1,350 $544,316 Passenger Vessels 1,959 4 8 % $514 $483,069 Tank Barges 7,138 48% $96 $327,422 Tank Ships 312 50% $627 $103,580 Utility Vessels 6,185 4 8 % $723 $2,169,474

Low End TOTAL 58,431 $5,983,656
High End Estimate (Average Incremental Cost $ 8 /gallon)

Use EAL Commercial Fishing 2,315 7 3 % $964 $1,642,369 Freight Barges 39,757 73% $19 3 $5,606,986 Freight Ships 765 7 4 % $2, 700 $1,630,424 Passenger Vessels 1,959 7 3 % $1,02 8 $1,483,289 Tank Barges 7,138 73% $19 3 $1,007,702 Tank Ships 312 7 4 % $1,25 4 $309,930 Utility Vessels 6,185 7 3 % $1,446 $6,641,840 High End TOTAL 58,431 $18,322,539

a Existing and new vessels, assuming that vessels are replaced at the rate of 1/30 th of the population each year.
b Fraction represents the combination of assumptions on the fraction of new and existing vessels that implement the practice in the baseline and those anticipated to use EALs under the 2013 VGP.

4.2.10 D ISTILLATION AND R EVERSE O SMOSIS B RINE

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only vessels that are potentially impacted by this section are commercial fishing vessels as all other vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. However, EPA has determined that practices applicable to discharges of distillation and reverse osmosis brine have negligible costs and/or the industry is assumed to currently practice the Permit requirements. This discharge category is assumed to have zero incremental cost.

4.2.11 E LEVATOR P IT E FFLUENT

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only vessels that are potentially impacted by this section are commercial fishing vessels as all other vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. However, EPA has determined that these vessels typically do not have elevator pit effluent. They do not incur an incremental cost as a result of their VGP coverage and this discharge category
therefore is assumed to ha ve zero incremental cost.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 84 4.2.12 F IREMAIN S YSTEMS

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only vessels that are potentially impacted by this section are commercial fishing vessels as all other vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. However, EPA has determined that firemain systems are uncommon on commercial fishing
vessels and these vessels therefore do not incur an incremental cost as a result of their VGP coverage. This discharge category is assumed to have zero incremental cost.

4.2.13 F RESHWATER L AYUP

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only vessels that are potentially impacted by this section are commercial fishing vessels as all other vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements.

H owever, EPA has determined that freshwater layup discharges are uncommon to commercial fishing vessels and these vessels therefore do not incur an incremental cost as a result of their VGP coverage. This discharge category is assumed to have zero incremental cost.

4.2.14 G AS T URBINE W ASH W ATER

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only vessels that are potentially impacted by this section are commercial fishing vessels as all other vessels currently covered by the 200 8 VGP are assumed to comply with applicable requirements. However, EPA has determined that gas turbine wash water discharges are generally not present on commercial fishing vessels and these vessels therefore do not incur an incremental cost as a
result of their VGP coverage. This discharge category is assumed to have zero incremental cost.

4.2.15 G RAYWATER

Graywater is defined in the Vessel General Permit as the discharge derived from “galley, bath and shower water, as well as wastewater from lavatory sinks, laun dry, and water fountains” (EPA, 2010a). The 2008 VGP contains a number of special provisions applying to discharges of graywater from cruise ships, specifying treatment standards for graywater discharges in port or within 1 nm of shore, and requiring that releases between 1 and 3 nm of shore occur only when traveling at a speed of at least 6 knots. These requirements were established based on the U.S. Coast Guard Limitations on Discharge of Treated Sewage or Graywater in Alaska, promulgated in 2001 (33 CFR 159). Even before the 2008 VGP was finalized, s everal other states had existing requirements for graywater discharges. For example, Maine adopted Alaska’s discharge requirements for vessels with passenger capacities of at least 250 under the 2003 Act to Pr otect
Maine’s Coastal Waters and the California Clean Coast Act, enacted in 2004, prohibits cruise ships from discharging any graywater into California’s territorial waters. Additionally, s everal states, including Washington, Hawaii, and Florida, had voluntary memoranda of understandingEconomic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 85 with the cruise ship industry that discourage the discharge of untreated graywater in port or
within 4 nm of shore. 44

Also relevant to graywater discharges are two other federal regulations. First, under Section 312(a) of the CWA, graywater discharges from commercial vessels in the Great Lakes region are currently treated as sewage and thus are excluded from the scope of the VGP . Second, the National Marine Sanctuaries Act authorizes the National Oceanic and Atmospheric Administration (NOAA) to designate National Marine Sanctuaries wherein certain discharges, including graywater, may be restricted to protect sensitive ecosystems.

PERMIT REQUIREMENTS
The 2013 VGP generally maintains graywater requirements contained in the 2008 VGP but additionally requires that any vessel constructed on or after December 19, 2013 which provide overnight accommodation to at least 10 crew and any vessel operating on the Great Lakes that is not a “commercial vessel” comply with additional requirements. If they discharge graywater, these vessels must conduct monitoring . Effluent limits for n on “commercial vessels” (as defined
in CWA Section 312 ( a)(10)) operating on the Great Lakes are specified as no more than 200 cfu/100 ml fecal coliform and no more than 150 mg/l of suspended solids

Part 2.2.15.2 of the 2013 VGP states that samples must be taken for BOD, fecal coliform, suspended solids, pH, and total residual chlorine, and that sampling must be conducted in accordance with the 40 CFR Part 136 methods. Samples taken from non- commercial vessels operating on the Great Lakes must meet the standards specified in Part 2.2.15.1 of the permit, which pe rtain to fecal coliform and suspended solids . Records of monitoring information must include the date, exact place, and time of sampling/measurements, the individual(s) who performed the sampling/measurements, the date(s) the analyses were performed, the i ndividual(s) who performed the analyses, the analytical techniques/methods used, and the results of such analyses.

All records of the sampling and testing results must be retained onboard in the vessel’s recordkeeping documentation for 3 years.

Permit Text [emphasis added to highlight principal revisions and new requirements of the 2013

VGP ]:

2.2.15 Graywater

All vessels must minimize the discharge of graywater while in port. For those vessels that cannot store graywater, the owner or operator and their cre ws must minimize the production of graywater in port. Examples of ways to minimize production of graywater include delaying laundry, scullery activities, and restricting length of showers while in port, and using high efficiency faucets and showerheads. Al l vessels that have the capacity to store graywater shallEconomic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 86 not discharge it in waters listed in Appendix G. For vessels that cannot store graywater, vessel operators must minimize the production of graywater while in waters listed in Appendix G.

For vessels greater than 400 gross tons that regularly travel more than 1 nm from shore that have the capacity to store graywater for a sufficient period, graywater must be discharged greater than 1 nm from shore while the vessel is underway, unless the vessel meets the treatment standards and other requirements contained under Parts 5.1.1 and 5.1.2 or 5.2.1 and 5.2.2 of this permit. Additional specific requirements for graywater apply to cruise ships (Parts 5.1 and 5.2) and large ferries (Part 5.3).

Vessels that do n ot travel more than 1 nm from shore shall minimize the discharge of graywater and, provided the vessel has available graywater storage capacity, must dispose of graywater onshore if appropriate facilities are available and such disposal is economically pra cticable and achievable unless the vessel meets the treatment standards and other requirements contained under Parts 5.1.1 and 5.1.2 or 5.2.1 and 5.2.2 of this permit. You must also minimize the discharge of graywater when the vessel is not underway

. If g raywater will be discharged in waters subject to this permit, the introduction of kitchen oils to the graywater system must be minimized. When cleaning dishes, you must remove as much food and oil residue as practicable before rinsing dishes. Excess oils u sed in cooking, including animal fats and vegetable oils, shall not be added to the graywater system. Under no circumstances may oil from the galley and scullery be discharged in quantities that may be harmful as defined in 40 CFR Part 110.

Vessel owners/o perators must use phosphate- free and non -toxic soaps and detergents, as defined

in Appendix A of this permit, for any purpose if graywater will be discharged into waters subject to this permit. Soaps and detergents must be free from toxic or bioaccumulative compounds and not lead to extreme shifts in receiving water pH. For purposes of this part, extreme shifts means causing pH to fall below 6.0 or rise above 9.0 as a direct result of the discharge.

If your vessel is underway in a nutrient -impaired water, or a water that is impaired as a result of nutrient enrichment (such as waters listed as impaired for phosphorus, nitrogen, or for hypoxia or anoxia [low dissolved oxygen concentrations]), you must follow these additional requirements:

 When the vessel has adequate graywater storage capacity, the vessel owner/operator shall not discharge graywater into nutrient- impaired waters subject to this permit (e.g., the Chesapeake Bay). A complete list of such waters can be found at www.epa.gov/npdes/vessels.

 Where the vessel does not have adequate storage capacity to eliminate such discharges, graywater production and discharge must be minimized in such waters. Any such discharge must be conducted while the vessel is underway in areas with significant
circulation an d depth to the extent feasible. Graywater stored while in such waters can later be disposed of onshore or discharged in accordance with the other requirements of this permit

.
2.2.15.1 Additional Graywater Requirements for Certain VGP Vessels Operating in the
Great LakesEconomic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 87 Any vessel operating on the Great Lakes that is not a “commercial vessel” as defined in CWA section 312(a)(10) must meet one of the following requirements for graywater management:

(i) The vessel must hold all graywater for onshore discharge to an appropriate shoreside facility; or

(ii) The graywater discharge must not exceed 200 fecal coliforms per 100 milliliters and contain no more than 150 milligrams per liter of suspended solids.

Vessels subject to this part must conduct monitoring required under Part 2.2.15.2 to demonstrate treatment equipment maintenance and compliance with the limits of this part. Records of the sampling and testing results must be retained onboard for a period of 3 years in the vessel’s recordkeeping documentatio n consistent with Part 4.2 of this permit.

2.2.15.2 Graywater Monitoring

The following monitoring requirements are applicable to vessels which discharge graywater into waters subject to this permit and meet one of the following conditions:

 The vessel is a new build vessel constructed on or after December 19, 2013, has a maximum crew capacity greater or equal to 10, and provides overnight accommodations to those crew; or

 The vessel is subject to Part 2.2.15.1 of this permit.

Vessel owners/operators must co nduct and analyze two samples per year, at least 14 days apart, and report the results of those samples as part of their Annual Report. Samples must be taken for Biochemical Oxygen Demand (BOD), fecal coliform, suspended solids, pH, and total
residual chlo rine. Sampling and testing shall be conducted according to 40 CFR Part 136. If the vessel is subject to Part 2.2.15.1, measured samples must meet the standards specified in that part.

Records of monitoring information shall include:

 The date, exact place, and time of sampling or measurements;

 The individual(s) who performed the sampling or measurements;

 The date(s) analyses were performed;

 The individual(s) who performed the analyses;

 The analytical techniques or methods used; and

 The results of such analyses.

Vessels subject to this part must note whether the graywater effluent is treated or untreated, and also note whether the effluent is graywater alone or if it is mixed with another effluent type (e.g., graywater mixed with sewage). Records of the sampli ng and testing results must be retained onboard for a period of 3 years in the vessel’s recordkeeping documentation
consistent with Part 4.2.

Vessels which do not enter waters subject to this permit for the calendar year need not conduct monitoring for th at year, but must clearly indicate on their Annual Report that they did not enter waters subject to this permit during that year

.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 88 AFFECTED VESSEL POPU LATION
Practices related to graywater discharges are potentially applicable to every vessel class except for freight barges and tank barges (as those vessels do not produce graywater)

. All applicable vessels with the exception of commercial fishing vessels are assumed to currently implement the 2008 VGP requirements ; unchanged 2013 VGP requirements potentiall y re present an incremental

cost for owners of commercial fishing vessels.

Additional graywater monitoring requirements apply to certain vessels. NOI s received by EPA to date show that 1 percent of vessels overall use onboard treatment for their graywater, with the largest share of vessels using graywater treatment being large and medium cruise ships , followed by large ferries. The revised requirements are not expected to change current practices, as vessels that currently hold their graywater are expected to continue doing so. C haracteristics of vessels
that had submitted an NOI as of August 2010 suggest that 10 percent of existing passenger vessels use graywater treatment . Smaller fractions of tank ships and freight ships (2 percent) and commercial fishing vessels and utility vessels (1 percent) have graywater treatment onboard

. In the aggregate, an estimated 11,698 vessels are assumed to implement onboard graywater

treatment in the baseline.

In addition, the 2013 VGP requires certain new build vessels that discharge graywater to comply with monitoring requirements. New build vessels subject to the monitoring requirements are those constructed on or after December 19, 2013, with maximum crew capacity greater or equal to 10, and overnight accommodations for those crew . Except for barges which provide no crew accommodation, and utility vessels where EPA assumed that about a quarter meet the criteria, all

ne w vessels are assumed to potentially be subject to the graywater monitoring requirements. The
number of new vessels in each class was estimated at 1/30 th of the vessel population, based on an assumed vessel life of 30 years.

New r equirements for non “comm ercial vessels” (as defined in CWA Section 312 (a)(10)) that travel in the Great Lakes are applicable to any vessel that is not “used in the business of transporting property for compensation or hire, or in transporting property in the business of the owner, lessee, or operator of the vessel.” (33 U.S.C. 1322 (a)(10)). EPA has included the requirement so that there is no ambiguity that any non

- recreational , non- military vessel greater than 79 feet is expected to treat or hold their graywater when operating o n the Great Lakes

. Numerous vessels are considered “commercial vessels” under Section 312 (a)(10) of the Clean Water Act and currently either hold their graywater for onshore disposal at a sewage treatment plant or treat that graywater using an existing Marine Sanitation Device. Hence, holding capacity is present on some vessels or treatment devices are available and used for managing graywater from vessels operating on the Great Lakes and EPA believes most, if not all, VGP eligible vessels operating on the Great Lakes should already be meeting these conditions

. The population potentially affected by revisions to requirements applicable to the graywater discharge category is shown in Table 4-20

.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 89 Table 4- 20

. Vessel Counts for Graywater Practices

.

Vessel Class Number of Existing
Vessels Fraction of Existing
vessels a Total Existing
Vessel Count Total New
Vessel Count (low estimate) b Total New
Vessel Count (high estimate) c
Commercial Fishing 2,326 1% 33 98 195 Freight Barges 39,760 0 %

- - - Freight Ships 812 2% 13 51 68 Passenger Vessels 1,970 1 0 % 205 149 165 Tank Barges 7,144 0 %

- - - Tank Ships 332 2% 5 21 28 Utility Vessels 6,258 1 % 63 52 131

TOTAL 58,602 319 370 586

a Fractions are based on characteristics of vessels that submitted an NOI.

b Average number of new vessels subject to the requirements is estimated based on replacement of 1/30 th of the vessel population each year during over the 5

- year permit. 75% of commercial fishing, freight ships, tank ships, and passenger vessels are assumed to potentially discharge graywater, while 10% of utility vessels are assumed to provide overnight accommodation for at least 10 crews

.

c Average number of new vessels subject to the requirements is estimated based on replacement of 1/30 th of the vessel population each year during over the 5

- year permit. All commercial fishing, freight ships, tank ships, a nd passenger vessels are assumed to potentially discharge graywater, while a quarter of utility vessels are assumed to provide overnight accommodation for at least 10 crews.

d The number of passenger vessels is adjusted to account for the 113 passenger vessels (cruise ships) previously estimated to comply with the treatment requirements in the 2008 VGP analysis (see EPA, 2008)

COST ESTIMATES
Additional monitoring requirements for vessels that discharge treated graywater have the potential to impose incre mental compliance cost on the owners of these vessels. Monitoring requirements are similar to those contained in the 2008 VGP for medium and large cruise ships, except for their lower annual frequency . Costs for implementing the monitoring requirements are estimated at $ 201 per monitoring event, which covers analytical testing ($137 for all four parameters), sampling, administration, and reporting (one labor hour at an assumed average hourly rate of $33.72), and incidental expense s such as shipping ($30).

SENSITIVITY ANALYSIS
The sensitivity analysis uses the following assumptions.

 Monitoring Costs: Per event costs are assumed to be $ 201 , inclusive of all labor and
material.

 Baseline: EPA assumed that all cruise ships for which the requirement applies curr ently comply with the vessel type specific requirements in the 2008 VGP and therefore will not incur incremental costs as a result of the revised graywater requirements for all vessel types. The fraction of vessels that may treat rather than hold their graywater is assumed based on vessel characteristics from NOIs received by EPA as of August 2010

.  Implementation Rate: EPA assumed that 100 percent of applicable vessels will need to conduct the additional monitoring.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 90 The cost per vessel for each practice and the total cost associated with all vessels are provided in
Table 4-19

. The annual incremental costs range from approximately $ 231,000 to $ 318,000.

Table 4- 21

. Graywater Monitoring Sensitivity Analysis.

Vessel Class Existing
Vessel Count a New Vessel

Count Annual Cost per Vessel Total Annual

Cost
Low End Estimate Monitor Graywater Commercial Fishing 33 98 $402 $52,414 Freight Barges

- - $402 $0 Freight Ships 13 51 $402 $25,554 Passenger Vessels 92 149 $402 $96,594 Tank Barges

- - $402 $0 Tank Ships 5 21 $402 $10,292 Utility Vessels 63 52 $402 $46,289

Low End TOTAL 206 370 $231,144
High End Estimate Monitor Graywater Commercial Fishing 33 195 $402 $91,574 Freight Barges

- - $402 $0 Freight Ships 13 68 $402 $32,332 Passenger Vessels 92 165 $402 $103,221

Tank Barges

- - $402 $0 Tank Ships 5 28 $402 $13,053 Utility Vessels 63 131 $402 $77,768 High End TOTAL 206 586 $317,948

a For passenger vessels, the number of vessels that have incremental cost is further adjusted by removing the large and medium cruise ships assumed to already be implementing monitoring requirements under the 2008 VGP

.

4.2.16 M OTOR G ASOLINE A ND C OMPENSATING D ISCHARGE

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only
vessels that are potentially impacted by this section are commercial fishing vessels as all other vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. However, EPA has determined that practices applicable to motor gasoline and compensating discharges have negligible costs and/or the industry is assumed to currently practice the Permit requirements (e.g., in compliance with the oil discharge prohibition in 40 CFR part 110) . This discharge category is assumed to have zero incremental cost.

4.2.17 N ON -O ILY M ACHINERY W ASTEWATER

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only vessels that are potentially impacted by this section are commercial fishing vessels as all other vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. However, EPA has determined that practices applicable to non

- oily machinery wastewater discharges have negligible costs and/or the industry is assumed to currently practice the PermitEconomic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 91 requirements (e.g., in compliance with the oil discharge prohibition in 40 CFR part 110) . This discharge category is assumed to have zero incremental cost.

4.2.18 R EFRIGERATION AND A IR C ONDENSATE D ISCHARGE

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only vessels that are potentially impacted by this section are commercial fishing vesse ls as all other vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. However, EPA has determined that practices applicable to refrigeration and air condensate discharges have negligible costs and/or the industry is assumed to currently practice the Permit requirements (e.g., in compliance with the oil discharge prohibition in 40 CFR part 110) . This discharge category is assumed to have zero incremental cost.

4.2.19 S EAWATER C OOLING O VERBOARD D ISCHARGE ( I NCLUDING N ON -C ONTACT

E NGINE C OOLING W ATER, H YDRAULIC S YSTEM C OOLING W ATER,

R EFRIGERATION C OOLING W ATER)

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only vessels that are potentially impacted by this section are commercial fishing vesse ls as all other vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. However, EPA has determined that practices applicable to seawater cooling overboard discharges have negligible costs and/or the industry is assume d to currently practice the Permit requirements (e.g., in compliance with the oil discharge prohibition in 40 CFR part 110) . This discharge category is assumed to have zero incremental cost.

4.2.20 S EAWATER P IPING B IOFOULING P REVENTION

The 2013 VGP requirements f or this discharge category are fundamentally similar to the 2008 VGP requirements. Therefore, the only vessels that are potentially impacted by this section are commercial fishing vessels as all other vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. However, EPA has determined that practices applicable to seawater piping biofouling prevention discharges have negligible costs and/or the industry is assumed to currently practice the Permit requirements (e.g., in compliance with the oil discharge prohibition in 40 CFR part 110) . This discharge category is assumed to have zero incremental

cost.

4.2.21 S MALL B OAT E NGINE W ET E XHAUST

The Permit updates the 2008 VGP to require that vessels with two- stroke engines use environmentally acceptable lubricants.

Permit Text [Emphasis highlights new requirements of t he 2013 VGP ]:

2.2.21 Boat Engine Wet Exhaust

Vessel engines generating wet exhaust must be maintained in good operating order, well tuned, and function according to manufacturer specifications to decrease pollutant contributions to wetEconomic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 92 exhaust. Vessel own er/operators should use low sulfur or alternative fuels for their vessels to reduce the concentration of pollutants in discharges from boat engine wet exhaust.

EPA encourages vessel operators to consider four stroke engines instead of two stroke engines fo r vessels generating wet exhaust that are covered under this permit. Use of a four stroke engine may minimize the discharge of pollutants to waters subject to this permit. Where vessels utilize two stroke engines, environmentally acceptable lubricants (as defined in Appendix A of this permit) must be used unless technologically infeasible. If technologically infeasible, the vessel owner/operator must document in their recordkeeping documentation why they are not using environmentally acceptable lubricants

.

AFFECTED VESSEL POPU LATION

No information is available from the combined MISLE/WTLUS database to determine the number of vessels that currently use two -stroke engines. Newly covered commercial fishing vessels are potentially impacted by the requirements pe rtaining to small boat engine wet exhaust; certain existing vessels that use two strokes engines may be affected by the additional requirements to use environmentally acceptable lubricants . However, a s discussed in the next section, neither the baseline no r the revised requirement s are expected to represent incremental costs for these vessels. EPA therefore did not determine the size of the relevant vessel population.

COST ESTIMATES
General practices relating to equipment maintenance and low sulfur fuels are assumed to already be implemented by vessel owners, including those in the fishing industry. EPA reviewed prices for different types of engine lubricants including EALs and mineral -based products and found no systematic difference in the unit cost of t hese products that would suggest that using EALs would
result in additional costs for vessel owners ; in fact some EAL products were less expensive than petroleum-based lubricants. 45 Accordingly, EPA estimates that revisions of requirements for this discharge category have no incremental cost.

4.2.22 S ONAR D OME D ISCHARGE

The 2013 VGP requirements are fundamentally identical to the 2008 VGP requirements. Therefore, the only vessels that are p otentially impacted by this section are commercial fishing vessels as all other vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. However, EPA has determined that practices applicable to sonar dome discharges hav e negligible costs and/or the industry is assumed to currently practice the Permit requirements. This discharge category is assumed to have zero incremental cost.

45 The average cost per gallon for environmentally acceptable two

- stroke engine oil was approximately $23 as compared to average cost of $32 for non

- EAL pro ducts.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 93 4.2.23 UNDERWATER SHIP HUSB ANDRY DISCHARGES

PERMIT REQUIREMENTS
The 2013 VGP retains the requirements of the 2008VGP with minor clarifications on practices to minimize the impacts of ship husbandry.

Permit Text [ Emphasis highlights new requirements of the 2013 VGP]:

2.2.23 Underwater Ship Husbandry Discharges

Vessel owners/operators must minimize the transport of attached living organisms when traveling into U.S. waters from outside the U.S. economic zone or between Captain of the Port (COTP)

zones.
Whenever possible, rigorous hull

- cleaning activities should take place in drydock, or at a land

based fa cility where the removal of fouling organisms or spent antifouling coatings paint can be contained. If water- pressure -based systems are used to clean the hull and remove old paint, you must use facilities which treat the washwater prior to discharging to w aters subject to this permit in order to remove the antifouling compound(s) and fouling growth from the washwater. If mechanical means (scraping, etc.) are used to clean the hull and remove old paint, the materials removed from the hull during that process must be collected and disposed of properly (e.g., onshore). These materials must not be allowed to contaminate nearby waters

. Vessel owners/operators who remove fouling organisms from hulls while the vessel is waterborne must employ methods that minimize the discharge of fouling organisms and antifouling hull coatings. These shall include:

 Use of appropriate cleaning brush or sponge rigidity to minimize removal of antifouling coatings and biocide releases into the water column;

 Limiting use of hard brushes and surfaces to the removal of hard growth; and

 When available and feasible, use of vacuum or other control technologies to minimize the release or dispersion of antifouling hull coatings and fouling organisms into the water
column.

Vessel owners/operat ors must minimize the release of copper -based antifoulant paints during vessel cleaning operations. Cleaning of hull surfaces coated with copper- based antifoulant paint must not result in any visible cloud or plume of paint in the water; if a visible cloud or plume of paint develops, shift to a softer brush or less abrasive cleaning technique. A plume or cloud of paint can be noted by the presence of discoloration or other visible indication that is distinguishable from hull growth or sediment removal. Production of a plume or cloud of sediment or hull growth is normal in some cases during vessel hull cleaning, but this plume or cloud must be substantially paint free (e.g., paint should not be clearly identifiable in the plume or cloud). When feasible, attem pts must be made to minimize the release of fouling organisms and antifouling systems (including copper- based coatings) into surrounding waters

. Vessels that use copper -based anti-fouling paint must not clean the hull in copper-impaired waters within the first 365 days after paint application unless there is a significant visible indication of hull fouling. EPA maintains a list of copper -impaired waters on its webpage atEconomic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 94 www.epa.gov/npdes/vessels. If you clean before 365 days in copper-impaired waters, you must document in your recordkeeping documentation why this early cleaning was necessary

AFFECTED VESSEL POPU LATION
The discharge category is potentially applicable to all vessels covered by the VGP. All vessels except commercial fishing vessels are already complying with existing requirements under the 2008 VGP and would only incur incremental costs, if any, from revis ed requirements. The newly covered commercial fishing vessels have the potential to incur incremental costs if the practices required by the Permit differ from current industry practices.

The population potentially affected by practices applicable to discharges in the underwater ship husbandry category is shown in Table 4-22

.

Table 4- 22 . Vessel Counts for U nderwater Ship Husbandry Practices

.

Vessel Class Vessel Count

Commercial Fishing 2,326 Freight Barges 39,760 Freight Ships 812 Passenger Vessels 1,970 Tank Barges 7,144 Tank Ships 332 Utility Vessels 6,258

TOTAL 58,602

COST ESTIMATES
Since practices associated with underwater ship husbandry are generally contracted to diving companies, information gathered from diving companies is most useful. In estimating the impacts of the 2008 VGP, EPA found that the requirements contain ed in the 2008 VGP were consistent with existing standard practices and therefore the requirements did not represent incremental costs for vessel owners. Revisions to the requirements in the 2013 VGP similarly highlight practices that EPA believes are alre ady common, such as minimizing contamination from paint scrapings, fouling organisms or antifouling systems.

Because the circumstances are anticipated to be infrequent, documentation of cleanings conducted in copper -impaired waters within 365 days of paint application likely represents only a
minimal additional burden for the subset of vessel owners affected, rel ative to the annual paperwork burden discussed in Section 4.4

. Accordingly, revisions to requirements under this discharge category are not expect ed to impose
incremental costs on vessel owners.

4.2.24 W ELLDECK D ISCHARGES

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only vessels that are potentially impacted by this section are commercial fishing vessels as all other vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 95 However, EPA has determined that practices applicable to welldeck discharges have negligible costs and/or the industry is assumed to currently practice the Permit requirements . This discharge category is assumed to have zero incremental cost.

4.2.25 G RAYWATER M IXED WITH S EWAGE FROM V ESSELS

The 2013 VGP requirements are identical to the 2008 VGP requirements. Therefore, the only vessels that are potentially impacted by this section are commercial fishing vessels as all other vessels currently covered by the 2008 VGP are assumed to comply with applicable requirements. However, EPA has determined that practices applicable to discharges of graywater mixed with sewage have neg ligible costs and/or the industry is assumed to currently practice the Permit requirements. This discharge category is assumed to have zero incremental cost.

4.2.26 E XHAUST G AS S CRUBBER W ASHWATER D ISCHARGE

In the 2013 VGP, is proposing several monitoring requirem ents for those vessels which use exhaust gas scrubber systems. These requirements are similar to those contained in the International Maritime Organization (IMO) guidelines for exhaust gas cleaning systems in resolution Marine Environmental Protection Committee (MEPC) 184(579). In addition to continuous monitoring of the washwater, vessel owners must analyze the effluent for several pollutants on a quarterly basis. The results of the monitoring must be submitted to EPA annually. Additionally, the VGP contains other requirements to assure that exhaust gas scrubber discharges are consistent with existing US law

.

PERMIT REQUIREMENTS

Permit Text:

2.2.26 Exhaust Gas Scrubber Washwater Discharge

Exhaust gas scrubber washwater discharge must not contain oil, including oily mixtures, in quantities that may be harmful as determined in accordance with 40 CFR Part 110. Sludge or residues generated in treating exhaust gas scrubber washwater discharge must not be discharged in waters subject to this permit and must be delivered ashore to adequate reception facilities.

In addition, owner/operators of vessels with exhaust gas cleaning systems that result in washwater discharges must meet the numeric effluent limits found in Part 2.2.26.1 and the monitoring requiremen ts found in Part 2.2.26.2 this permit. These limits are consistent with the IMO guidelines set forth in section 10 for Exhaust Gas Cleaning (EGC) Systems (resolution MEPC.184(59)). Among other things, these guidelines recommend the establishment of limits for concentrations of pollutants in the effluent.

[2.2.26.1 Exhaust Gas Scrubber Treatment Standards]

2.2.26.2 Exhaust Gas Scrubber Analytical Monitoring Requirements

2.2.26.2.1 Continuous Monitoring

The data recording system must comply with the guidelines in sections 7 and 8 of MEPC.184(59) and must continuously record pH, PAH, and turbidity.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 96 When the EGC system is operated in waters subject to this permit, the washwater monitoring and recording must be continuous. The values monitored and recorded must include pH, PAH, turbidity, and temperature.

The pH electrode and pH meter must have a resolution of 0.1 pH units and temperature compensation. The electrode must comply with the requirements defined in BS 2586 or of equivalent or better performance and the meter should meet or exceed BS EN ISO 60746-2:2003.

The PAH monitoring equipment must be capable of monitoring PAH in water in a range of at least twice the discharge concentration limit given in the table above. A demonstration must be made that the equipment operates correctly and does not deviate more than 5 percent in washwater with turbidity within the working range of the application. For those applications discharging at lower flow rates and higher PAH concentrations, ultraviolet light monitoring technology or equivalent should be used due to its reliable operating range.

The turbidity monitoring equipment must meet requirements defined in ISO 7027:1999 or USEPA

180.1.

All continuous monitoring equipment must be calibrated as recommended by probe manufacturers or Exhaust Gas scrubber manufacturers. At a minimum, all probes must be calibrated at least annually. EPA expects many probe types (e.g., turbidity probes) will need to be calibrated on a more frequent basis.

2.2.26.2.2 Quarterly Analytical Monitoring.

In addition to the continuous monitoring found in Part 2.2.26.2.1 of this permit, vessel owner/operators must collect and analyze one sample per quarter for each of the constituents analyzed in Part 2.2.26.2.3 to demonstrate treatment equipment maintenance, probe accuracy, and compliance with this permit. Records of the sampling and testing results must be retained onboard for a period of 3 years in the vessel’s recordkeeping documentation consistent with Part

4.2.

2.2.26.2.3 Analytes for Quarterly Analytical Monitoring

Vessels conducting monitoring as required by Part 2.2.26.2.2 must monitor for the following parameters, choosing either sufficiently sensitive EPA Part 136 methods or other methods if specifically allowed:

 Dissolved and Part iculate Metals, including Aluminum, Antimony, Arsenic, Cadmium, Chromium, Copper, Lead, Manganese, Nickel, Selenium, Thallium, and Zinc (recommend using EPA Methods 200.8 or 200.9);

 PAHs including Acenaphthylene, Acenaphthene, Anthracene Benz[a]anthracene, Benzo[ghi]perylene, Benzo[a]pyrene, Benzo[b]fluoranthene +, benzo[k]fluoranthene, Chrysene, Dibenz[a,h]anthracene, Fluoranthene, Fluorene, Indeno[1,2,3,c,d]pyrene, Naphthalene, Phenanthrene, and Pyrene (recommend using EPA Methods 550.1, 610, 625, 8100, 8 270c, 8310);

 Nitrates (recommend using EPA Method 353.2);

 pH (using Standard Methods (SM) 4500- H B);

 Turbidity (using SM 2130 B);Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 97  Temperature (using SM 2550); and

 Dissolved Oxygen (using SM 4500- O G).

2.2.26.2.4 Monitoring Reporting

Vessel owners/operators must submit all monitoring data to EPA’s e- reporting system, unless exempted from electronic reporting consistent with Part 1.14 of this permit. Monitoring data must be submitted at least once per calendar year no later than February 28 of the following year on the vessel annual report. Data must be submitted on or attached to a DMR available in Appendix I of this permit or submitted to EPA’s e- reporting system available at www.epa.gov/vessels/eNOI. Data may be submitted as part of the vessel’s annual report.

AFFECTED VESSEL POPU LATION
Vessels potentially affected by this requirement are those equipped with a marine diesel engine that use wet scrubbers or hybrid scrubbers to reduce air pollution from their gas exhaust 46 to comply International, Federal, or regional requirements, and that discharge the washwater into waters subject to the permit.

At present, only a handful of vessels use exhaust gas cleaning systems (EGCS). With tighter air pollution regulations coming into effect and the growing availability of EGCS, however, a greater
number of vessels may use EGCS in the future to reduce their SO X emissions. No estimate could be found on the projected number of vessels that will install EGCS in coming years , and of those, the number of wet or hybrid systems that may discharge washwater . For the purpose of this analysis, EPA assumed that the number of vessels will be relatively small in the first year of the permit (i.e., 0.5 percent of freight or tank ships ) but will increase to up to 10 percent of these

ves sels by the end of the permit period. 47

COST ESTIMATES
In the 2013 VGP, EPA is establishing numeric BAT limit s which are consistent with the international guidelines established by the IMO. Though marine gas exhaust systems are in the early stages of development, EPA has found that all marine manufacturers are designing systems with these IMO guidelines in mind and that testing of these systems onboard vessels. Furthermore, these systems are generally based on technologies that have been used in land based applications, and these technologies generally transfer well to ship-based applications. Because
the limits set in the VGP are fundamentally similar to an existing international standard

, treatment manufacturers are currently designing their equipment to meet this standard

. By reinforcing existing limits, EPA is imposing no additional burden. 48

46 Other approaches to reducing air emissions include fuel conversion or switching to low

- sulfur fuel.

47 A guide developed by Ship Operations Cooperative Program (SOCP) suggests that vessels burning more than about 4,000 metric tons of fuel oil annua lly within emissions controls area may see cost advantages to using a EGCS instead of switching to low

- sulfur fuel, depending on the cost difference between high and low

- sulfur fuels and vessel

- specific characteristics (space constraints, stability, areas of operation, etc.) ( SOCP , 2011).

48 Additionally, vessel owner/operators may realize cost savings when using lower grade fuel (which requires use of a scrubber) compared to the higher grade, lower sulfur content fuels.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 98 While the numeric effluent limits are not expected to impose any incremental costs on vessel owners, EPA’s requirement that vessel owners conduct analytical sam pling quarterly and report
the results of their continuous and quarterly monitoring as part of the annual report are specific to the 2013 VGP and may represent an incremental costs.

Vessel owners are assumed to conduct continuous monitoring in accordance with IMO requirements. This includes reviewing equipment readings and calibrating probes as specified by the equipment manufacturer. No incremental cost is therefore calculated for the conduct of these activities. However, EPA assumes that vessel owners ma y incur up to 2 hours in additional recordkeeping burden in compiling the information as part of their annual report for each applicable vessel.

Costs for implementing the quarterly monitoring requirements are estimated at $ 437 per monitoring event . This c ost includes analytical testing ($ 303), sampling, administration, and reporting ( 2.5 labor hours at an assumed average hourly rate of $33.72), and incidental expenses such as shipping ($50).

SENSITIVITY ANALYSIS
The sensitivity analysis uses the following assumptions.

 Monitoring Costs: Per event costs are assumed to be $ 437 , inclusive of all labor and
material. Four monitoring events are conducted each year.

 Baseline: EPA assumed that none of the vessels equipped with EGCS would otherwise
conduct the quarterly analytical sampling and testing (but would be conducting continuous monitoring). In the low end estimate, EPA assumed that up to 5 percent of freight and tank ships use an EGCS by the end of the permit period (0% in year 1; 0.5% in year 2, 1% in year 3; 2% in year 4, and 5% in year 5). For the high end estimate, EPA
assumed that up to 10 percent of freight and tank ships use an EGCS by the end of the permit period (0.5% in year 1; 1% in year 2, 2% in year 3; 5% in year 4, and 10% in year 5).

 Imple mentation Rate: EPA assumed that 100 percent of applicable vessels will need to conduct the additional monitoring and recordkeeping, each year

. The cost per vessel for each practice and the total cost associated with all vessels are provided in
Table 4-19

. The annual ized incremental costs range from approximately $ 34,000 to $ 75,500.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 99 Table 4- 23

. Exhaust Gas Scrubber Washwater Discharge Monitoring Sensitivity Analysis.

Vessel Class Vessel Count a Annual Cost per
Vessel b Total Annual ized

Cost c

Low End Estimate Monitor Graywater Commercial Fishing

- $ 0 $ 0 Freight Barges

- $ 0 $0 Freight Ships 41 $ 1,817 $24,418 Passenger Vessels

- $ 0 $ 0 Tank Barges

- $ 0 $0 Tank Ships 17 $ 1,817 $9,990 Utility Vessels

- $ 0 $ 0
Low End TOTAL 57 $ 34,408 High End Estimate Monitor Graywater Commercial Fishing

- $ 0 $ 0 Freight Barges

- $ 0 $0 Freight Ships 81 $ 1,817 $53,570 Passenger Vessels

- $ 0 $ 0 Tank Barges

- $ 0 $0 Tank Ships 33 $ 1,817 $21,918 Utility Vessels

- $ 0 $ 0 High End TOTAL 114 $75,488

Total may not add up due to rounding.

a Represents the n umber of vessels that are assumed to use a EGCS by the last year of the VGP

. Not all vessels incur the annual cost for each of the 5 years of the permit.
b Annual monitoring costs for a vessel that uses a wet or hybrid EGCS, including sampling, analytical tests, and
incidentals.

c Costs are annualized over the 5

- year permit period , accounting for the distribution of costs over time. They are

c alculated by annualizing (at 7 percent discount rate) the present value of estimated compliance costs for each year
based on the number of domestic vessels assumed to use a wet or hybrid EGCS.

4.2.27 FISH HOLD EFFLUENT

PERMIT REQUIREMENTS
The 2013 VGP adds requirements for discharges of fish hold effluent as follows:

Permit Text:

You must minimize the discharge of fish hold water and/or ice while in port. All reasonable steps must be taken to prevent the discharge of excess fish hold water and ice while the vessel is stationary at the pier. If fish waste is contained in the fish hold effluent, the fish hold effluent may not be discharged while in port, unless a physical separation method is used (e.g., filters or removal of residuals).

 The discharge of fish hold effluent (including dirty ice) is prohibited if you are unloading your catch at a land-based seafood processing faci lity or pier. If a shore

- based dischargeEconomic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 100 facility is otherwise available to receive your effluent, then discharge of fish hold effluent (including dirty ice) is prohibited if the facility meets the following:

– Its use is economically achievable, and

– The facility has a valid NPDES permit, or

– That facility discharges to an NPDES

- permitted sewage treatment facility.

 The discharge of unused bait overboard is prohibited, unless you caught that bait in the same water body or watershed. Unused bait purchased from a bait shop or dealer may not be discharged overboard.

AFFECTED VESSEL POPU LATION
Based on the description of practices within this discharge category, o nly commercial fishing vessels have the potential to produce this discharge since no other vess els are expected to have fish holds. The population potentially affected by practices applicable to discharges in the fish hold effluent category is shown in Table 4-24

. Note that the vessel count presented in the table may overestimate the number of vessels to which the practice would apply since not all fishing
vessels have fish holds.

Table 4- 24 . Vessel Counts for Fish Hold Effluent Practices

Vessel Class Vessel Count

Commercial Fishing 2, 326 Fishing Vessels 0 Freight Barges 0 Freight Ships 0 Passenger Vessels 0 Tank Barges 0 Tank Ships 0 Utility Vessels 0

TOTAL 2, 326

COST ESTIMATES

The 2013 VGP requires that vessel operators use a physical separation method to remove excess
fish waste and residuals from the water prior to discharging fish hold effluent. Based upon EPA research, this practice is consistent with existing vessel practice: for example, most vessels have coarse filters to keep solid fish waste from being discharged with liquid effluent

. Codex
Alimentarius provides a recommended International Code of Practice for Fresh Fish, includi ng technological guidelines for the handling and processing of fresh fish intended for human consumption (FAO, 1976). The Codex specifies that vessels should use coarse filters for their fish
hold effluent. When present, these coarse filters should help ensure that no excess fish debris is discharged, consistent with the VGP requirements.

EPA has also prohibited the discharge of fish hold effluent pierside where shore based facilities are available: where they are available, vessels must utilize these facil ities

. .Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 101 According to a review of available information, at least two dockside facilities currently offer the option to discharge fish hold effluent to a shore-based facility instead of discharging to surrounding waters. These two facilities are in San Fr ancisco, CA and Sitka, AK.

EPA assumes that there are no costs associated with not discarding any unused bait overboard, given that the vessel owners or operators can readily wait and discard the bait at an appropriate
shore- based facility.

Therefore, non e of the requirements described in this section are expected to represent an incremental cost to owners of commercial fishing vessels

.

4.3 C OSTS OF V ESSEL -S PECIFIC R EQUIREMENTS

Part 5 of the VGP stipulates additional requirements applicable to selected vessel classes. The cost implication s of these requirements are discussed below, focusing on requirements revised in
the 2013 VGP. Similar to the discussion of costs applicable across vessel types, the discussion follows the order of the sections in the VGP. For completeness, all sections are included, with notes on whether the VGP revisions are expected to represent incremental costs on vessel owners.

4.3.1 L ARGE AND M EDIUM C RUISE S HIPS

PERMIT REQUIREMENTS
The 2013 VGP generally maintains the requirements specific to c ruise ships contained in the

2008 VGP but makes minor clarifications (e.g., prohibition of discharges of toxic materials) and a
few substantive changes to the requirements.

Revisions having the potential to impose incremental costs include those related t o graywater discharges (i.e., treatment and monitoring), for which requirements applicable to large and medium cruise ships are more stringent than those applicable to other vessel types. The 2013 VGP requires large cruise ships to either hold their untreated graywater or treat it to meet the
effluent limitations prior to discharging when within 3 nm from shore. The 2013 VGP thus extends the zone within which untreated graywater can never be discharged from 1nm to 3 nm. Cruise ship owners must also monitor for additional parameters not previously included in the 2008 VGP: e. coli, total phosphorus, ammonia, nitrate/nitrite, and t otal k jeldahl nitrogen (TKN).

Other changes merely clarify the graywater requirements and are not expected to impose
incremental c osts on vessel owners. These include:

 Clarifications that requirements for initial monitoring of the graywater treatment system may be met through monitoring conducted under the 2008 VGP. This clarification removes potential duplicate monitoring.

 Clarifica tions that the schedule for submitting the annual monitoring report follows a calendar year schedule. This clarification does not affect the scope or frequency of reporting.

 Clarifications that the annual monitoring report is part of the NPDES annual reporting requirement. This separates the reporting requirement from reporting of the information to the COTP for cruise ships operating in Alaska waters.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 102 Relevant excerpts of the permit text a re included below.

Permit Text :
Discharge Standards:

Pierside Limits
– While pierside, appropriate onshore reception facilities for graywater must be used unless the vessel treats graywater with a device to meet the standards in Part 5.1.1.1.2. If such facilities are not reasonably available and you do not have the capacity to treat graywater to meet the standards in Part 5.1.1.1.2, you must hold the graywater until the vessel is underway and not in waters subject to this permit. Appropriate reception facilities are those authorized for use by the port authority or local municipality and that treat the discharge in accordance with its NPDES permit

. Operational Limits: You must meet the following restrictions:

• While operating within 3 nm from shore

, discharges of graywater are prohibited unless they meet the effluent standards in Part 5.1.1.1.2.

[

Limits Applicable to Operation in Nutrient Impaired Waters (unchanged from 2008 VGP)]

[Graywater Treatment Standard (unchanged from 2008 VGP)]

Monitoring Requirements [Part 5.1.2]

Untreated Graywater [Part 5.1.2.1]

The discharge of untreated graywater by large cruise ships is not authorized in waters subject to this permit. Any discharge of untreated graywater within waters subject to this permit must
be reported to EPA as an incidence of noncompliance on the vessel’s Annual Report

. Treated Graywater [Part 5.1.2.2]

Prior to entering waters of the United States, vessel operators must demonstrate that they have an effective treatment system that complies wit h the standards in Part 5.1.1.1.2 if they will discharge graywater within 3 nm of shore.

Initial Monitoring [Part 5.1.2.2.1]

In order to demonstrate the effectiveness of the treatment system, the vessel operator must take at least five (5) samples from the vessel on different days over a 30

- day period that are representative of the treated effluent to be discharged. A vessel owner/operator that submitted data to EPA for a vessel’s discharge from an AWTS under the 2008 VGP requirements or
submitted such data to the U.S. Coast Guard to meet the requirements of Section 1411(b) of Title XIV, Pub. L. 106-554 (Dec. 31, 2000, 114 Stat. 2763) [Certain Alaska Cruise Ship Operations] (codified at 33 USC 1901 note) does not need to conduct initial monitoring, and may i nstead immediately commence maintenance monitoring consistent with Part 5.1.2.2.2 of this permit

. Initial monitoring must be done within the first 90 days of permit coverage, within 90 days of AWTS installation onboard the vessel, or before vessels dischar ge into waters subject to this permit, whichever is later. Samples must be taken for BOD, fecal coliform, suspended solids, pH,
and total residual chlorine. Furthermore, samples must be taken for E. coli, total phosphorus (TP), ammonia, nitrate/nitrite, an d Total Kjeldahl Nitrogen (TKN) . Sampling and testing shall be conducted according to 40 CFR Part 136. If the measured samples meet the standardsEconomic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 103 specified in Part 5.1.1.1.2, then the owner/operator has demonstrated the effectiveness of their
treatment sys tem for controlling their graywater discharge. Records of the sampling and testing results must be retained onboard for a period of 3 years in the vessel’s recordkeeping
documentation.

Records of monitoring information shall include:

 The date, exact place, and time of sampling or measurements;

 The individual(s) who performed the sampling or measurements;

 The date(s) analyses were performed;

 The individual(s) who performed the analyses;

 The analytical techniques or methods used; and

 The results of such anal yses.
Analytical results for total residual chlorine below the method detection limit shall be deemed compliant with the effluent limits, provided the permittee uses a testing method with a detection limit no higher than 10.0 μg/L under ideal conditions. EPA recommends Method SM4500- CL G (DPD Colorimetric Method) for these purposes as it is able to reach 10 μg/L under ideal conditions and so meets these requirements. SM4500- Cl G is typically the method that Alaska Department of Environmental Conservation (ADEC)/U.S. Coast Guard uses for compliance monitoring.

Testing and reporting for total residual chlorine is not required if chlorine is not used as disinfectant in the wastewater treatment works process and no water is drained to the graywater system from water with onboard chlorine additions (e.g., swimming pools, spas).

If a permittee has already received certification for continuous discharges from an AWTS by the U.S. Coast Guard to meet the requirements of Title XIV, Pub. L. 106-554 (Dec. 31, 2000, 114 Stat. 2763) [Certain Alaska Cruise Ship Operations] (codified at 33 USC 1901 note), the vessel need not conduct initial monitoring and may commence conducting maintenance monitoring.

Maintenance Reporting [Part 5.1.2.2.2]

After demonstrating the effectiven ess of their system, vessel owners/operators must collect and analyze one sample per quarter for each of the constituents listed in Part 5.1.2.2.1 to demonstrate treatment equipment maintenance and compliance with this permit. Furthermore, samples must be taken for E. coli, total phosphorus (TP), ammonia, nitrate/nitrite, and Total Kjeldahl Nitrogen (TKN). Records of the sampling and testing results must be retained onboard for a period of 3 years in the vessel’s recordkeeping documentation

. Monitoring Repo rting [Part 5.1.2.2.3]

The owner/operator must submit data showing that the graywater standards are achieved by their treatment system to EPA’s e

- reporting system or to EPA, ATTN: VGP Cruise Ship Monitoring Results, 1200 Pennsylvania Ave., MC 4203M, Washington, DC 20460. Initial sampling data must be submitted at least 7 days before entering waters subject to this permit, within 90 days of obtaining permit coverage, or within 90 days of AWTS installation onboard the vessel, whichever is later. Maintenance monitoring data must be submitted at least once per calendar year no later than February 28 of the following year (e.g., 2014 data must be submitted by February 28,Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 104 2015). Data must be submitted on DMRs available in Appendix I of this permit or submitted to

EPA’s e

- reporting system available at www.epa.gov/vessels/eNOI. Data may be submitted as part of the vessel’s annual report

.

AFFECTED VESSEL POPU LATION
The population estimate shown in Table 4-25 was provided by Cruise Lines International Association (CLIA) in support to EPA’s analysis of the 2008 VGP . Large sized cruise ships are in the 500+ passenger/crew capacity classification, and medium sized cruise ships are in the 100 to 499 passenger/crew capacity classification. 49

Table 4- 25 . Cruise Ship Counts.

Vessel Class a Alaskan Certified Cruise Ships Non

- Alaskan Certified Cruise Ships Total Count

Large Cruise Ships 30 113 143 Medium Cruise Ships c 0 32 32

TOTAL 30 145 b 175

a Cruise ships fall within the passenger vessels category.
b This count is based upon CLIA populations. There may be an additional 5% that are non

- CLIA members.

c The estimated number of medium cruise ships was determined based upon a 250

- 499 passenger/crew capacity
classification rather than the 100

- 499 range. However, based on preliminary data provided by CLIA, there are very few cruise ships within the 100

- 249 passenger/crew capacity classification. EPA therefore expects that the estimate is only slightly below the actual universe of medium cruise ships.

COST ESTIMATES
The majority of the practices associated with cruise ship graywater management are already
pract iced by the cruise ship industry. Changes to pierside and operational limits for large cruise ships would require vessels to treat their graywater to the specified standards, or hold graywater while pierside for later discharge beyond 3 nm from shore. C ruise ships already have the capacity to hold graywater for extended periods of time or are operating the necessary treatment systems to generate effluent that meets the limits specified in the 2013 VGP . Large cruise ships have the capacity to hold graywater for a minimum of 1 to 2 days, as evidenced by their ability to hold all wastewaters while sailing in areas such as Glacier Bay in Southeast Alaska, where discharges are generally prohibited under their concession contracts with the National Park Service. According to responses to EPA’s 2004 cruise ship survey of large cruise ships operating in Alaskan waters, graywater holding capacity ranged from 5 to 90 hours, with an average holding capacity of 56
hours.

Medium cruise ships will incur no incremental cost associated with this practice since the Permit standards are already practiced. Medium cruise ships that are able to voyage more than 1 nm are

49 The estimated number of medium crui se ships in Table 4-25 was determined based upon a 250 -499 passenger/crew capacity classification rather than the 100

- 499 range. However, based on data provided by CL IA, there are very few cruise ships within the 100

- 249 passenger/crew capacity classification. EPA therefore expects that the estimate is only slightly below the actual universe of medium cruise ships.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 105 already complying with graywater treatment standards. These ships have the option to discharge graywater in nutrient impaired waters while sailing at a speed of at least 6 knots. Since this is already an industry standard, according to the economic analysis of the 2008 VGP (EPA, 2008), there is no incremental cost associated with this Permit requirement.

Requir ements pertaining to operation in nutrient impaired waters, sculleries and galleys, hazardous waste, untreated graywater documentation, and monitoring have not changed substantively and therefore no incremental cost is associated with the 2013 VGP revisions.

Requirements to include additional parameters as part of initial and maintenance monitoring are not expected to add a significant cost to vessel owners beyond the cost previously estimated as part of the 2008 VGP analysis (EPA, 2008). This is because pr eviously estimated cost s for conducting the monitoring ($1000 per event, in 2 008 dollars) already represent a very conservative estimate of the cost of collecting samples, performing the laboratory analyses, administering and keeping records, and covering all other incidentals associated with a monitoring event. The new parameters are not expected to add costs that would not already fit
within this conservative estimate.

4.3.2 L ARGE F ERRIES

The 2013 VGP generally retains vessel

- specific requirements applicable to large ferries. One exception is the removal of requirements applicable to the discharge of coal ash from coal fired propulsion systems. Under the 2013 VG P , the discharge of coal ash slurry from coal fired propulsion systems from ferries is no longer authorized under the permit. This is consistent with EPA’s suspension of the authorization for these discharges in December 2012. Either coal ash discharges must cease into waters subject to this permit or they must be authorized under an individual NPDES permit. The change in permit language is made to be consistent with the existing requirements and this revision therefore is not e xpected to impose incremental costs on large ferries.

4.3.3 UNMANNED B ARGES ( S UCH A S H OPPER B ARGES, C HEMICAL B ARGES, T ANK

B ARGES, FUEL B ARGES, C RANE B ARGES, D RY B ULK C ARGO B ARGES)

The 2013 VG P retains the vessel

- specific requirements applicable to barges contai ned in the 2008 VGP with limited revisions to clarify the applicability of the requirements to unmanned barges and to barges used to transport petroleum and oil products. As these barges were originally included in the analysis of the 2008 VGP, the revisio ns are not expected to result in incremental costs. Other revisions include clarification on practices to prevent discharges of oily or toxic
materials ; the practices described in the revisions are already implemented by vessels and/or represent a negligible incremental cost on vessels that have the relevant equipment (scuppers)

.
Permit Text:

5.4.1 Additional Effluent Limits

Barges must minimize the contact of below deck condensation with oily or toxic materials and any materials containing hydrocarbon. W henever barges are pumping water from below deck, the discharge shall not contain oil in quantities that may be harmful as defined in 40 CFR Part 110. If a visible sheen, as defined in Appendix A of this permit , is noted, vessel operators mustEconomic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 106 initiate corrective action in accordance with Part 3 and meet recordkeeping requirements in Part 4.2 of this permit.

All tank barges must have spill rails and must mechanically plug their scuppers before any cargo operations if required by vessel class society and /or 33 CFR Parts 155 and/or 156. Additionally, scuppers, when available, must be mechanically plugged during fueling of ancillary equipment (e.g., generators and compressors) located on the deck of the barge. If scuppers are unavailable, other types of sec ondary containment should be employed . If any spills result during loading or unloading of cargo, or other ancillary equipment fueling operations , vessel owners/operators must completely clean up spills or residue before scuppers are unplugged.

Vessel own ers/operators must clean out cargo residues (i.e., broom clean) such that any remaining residue is minimized before washing the cargo compartment or tank and discharging
washwater overboard.

Vessel owners/operators must clean out cargo residues (i.e., broom clean) such that any remaining residue is minimized before washing the cargo compartment or tank and discharging
washwater overboard.

5.4.2 Supplemental Inspection Requirements

After every instance of pumping water from areas below decks, or immediately following washing down the decks, you must conduct a visual sheen test. The visual sheen test is used to detect free oil by observing the surface of the receiving water for the presence of an oily sheen. The operator should focus the inspection on the are a surrounding the vessel where discharges from below deck or deck washings are discharges into the receiving water. A visible sheen is defined in Appendix A of this permit. If a visible sheen is observed, you must initiate corrective actions required in

Pa rt 3 of this permit and meet recordkeeping and notification (reporting) requirements in Part 4.2 of this permit.

4.3.4 O IL T ANKERS, P ETROLEUM T ANKERS OR BULK CHEMICAL CAR RIERS

The 2013 VGP retains the vessel

- specific requirements applicable to oil tankers, petro leum tankers, or bulk chemical carriers contained in the 2008 VGP with limited revisions to clarify the applicability of the requirements to bulk chemical carriers. As these vessels were originally included in the analysis of the 2008 VGP, the revisions ar e not expected to result in incremental

costs.

4.3.5 R ESEARCH V ESSELS

The 2013 VGP vessel- specific requirements applicable to research vessels are identical to those contained in the 2008 VGP. No incremental cost is therefore anticipated.

4.3.6 E MERGENCY V ESSELS ( F IRE B OATS, P OLICE B OATS)

The 2013 VGP vessel- specific requirements applicable to emergency vessels are identical to those contained in the 2008 VGP. No incremental cost is therefore anticipated.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 107 4.4 GENERAL INSPECTION A ND P ERMIT P APERWORK B URDEN

The permit paperwork burden is comprised of five potential cost inputs:

 Recordkeeping

 Routine inspections

 Annual report

 Notice of Intent filing

 Annual reporting requirement

Some of the practices necessary to comply with these requirements are already implemented by
vessel owners in accordance with business practices and to comply with the 2008 VGP requirements. However, commercial fishing vessels may incur incremental burden as a result of their coverage under the VGP. Additionally, for previously covered vessels, re visions to certain
Permit requirements may require additional time for these tasks.

The 2013 VGP makes several modifications to the general inspection and paperwork requirements. The revisions generally aim to clarify the requirements or reduce the burden on covered vessels by streamlining the process of submitting information to EPA, following comments EPA received from regulated entities. The principal revisions to permit requirements
include:

 The addition of the Permit Authorization and Record of Inspection (PARI) Form to be completed for vessels for which an NOI is not required. The short form (1 page) must be maintained onboard the vessel and used to document the conduct of annual inspections.

 For routine visual inspections, the 2013 VGP clarifies the frequency of inspections as once per week or per voyage and conducted on a schedule that coincides with other routine inspections, if feasible. The text changes do not modify the frequency of inspections required under the 2008 VGP. Other changes include removing the requirement to sample discharge streams otherwise not readily visually inspected on a quarterly basis.

 Changes to the requirements for vessels that are unmanned for an extended period of time (13 days or greater). The requirements specify the scope of the inspections and the frequency, both of which are meant to be less extensive than the regular routine visual inspection. This change may result in cost savings for owners of affected vessels.

 For recordkeeping, the revisions clarify that vessel owners may keep either paper or electronic records, provided that the format can be read in a similar manner as a paper record, is dependable, and is accessible during an inspection. This change improves the efficiency of recordkeeping.

 For annual reports , the revisions clarify the timing of the report according to calendar year with preference for electronic reporting. In the case of unmanned, unpowered barges, the revisions allow owners to submit a single annual report for all their barges, provided that certain conditions are met (no analytical monitoring data are included, there were no instances of noncompliance, etc.). This change may result in cost savings for owners of unmanned, unpowered barges.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 108 The i mplications of the revised permit requirements f or currently covered vessels and of extending the scope of the permit to commercial fishing vessels are discussed below. Note that changes in the inspection and reporting burden associated with specific discharge categories (e.g., ballast water treatment systems, bilge water treatment systems) are discussed within each discharge

- specific section of this report. For example, incremental burden due to BWTS monitoring, sampling, testing, and recordkeeping requirements is discussed in Section 4.2.3

.

4.4.1 REVISED PAPERWORK RE QUIREMENTS

In analyzing the impacts of the 2008 VGP, EPA had developed high end estimates that assumed
the time required for vessels for recordkeeping, routine inspections, drydock inspections, and annual inspections. The estimates varied from no additional time to addition al time that varied according to the size of the vessels. This was based on the assumption that certain vessel classes are more likely to have a higher number of applicable discharge categories, and thus, a potentially higher number of practices to perform and report upon. EPA divided vessel classes according to two categories (“Large” and “Small”)

, where the categories reflect not only the average size of a vessel, but also its relative complexity. In determining inspection and recordkeeping burden,
“l arge ” vessels were assumed to have greater time requirement than “ small ” vessels. Table 4- 26
presents the crosswalk of vessel classes to the two categories

.

Table 4- 26

. Vessel Class Breakdown.

“Large” Vessels ” Small ” Vessels

Cruise Ships Commercial Fishing Freight Barges Freight Ships Passenger Vessels Tank Ships Utility Vessels Tank Barges

Most of the revisions to the general inspection and paperwork requirements are not expected to result in significant incremental costs to vessel owners as they generally either clarify the requirements or recognize existing practices. For example, revision s to the routine inspection requirements do not change the expected frequency of such inspections, nor its scope; NOIs and annual reports are already being submitted electronically by the large majority of vessel owners.
The addition of the PARI Form is as sumed to represents minimal burden for vessels as the very short form (1 page) consists of information that is readily available to the owner and is used to document activities (annual inspections) that are already occurring under the baseline.

B ased on f eedback from the industry on the 2008 VGP which indicated that EPA may have underestimated the paperwork burden associated with complying with the 2008 VGP, however, EPA is increasing the estimated burden assumed to be involved in submitting an NOI (if

app licable), maintaining the relevant records (including the PARI Form, if applicable), and preparing the annual report under the 2013 VGP, all else being equal. Table 4-27 presents the inspection and recordkeeping burden assumptions for the 2013 VGP , by vessel category.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 109 Table 4- 27

. Incremental Burden Assumptions for General Inspection and Paperwork
Requirements.

Requirement Burden Hours for Small
Vessels Burden Hours for Large
Vessels Frequency

NOI 1.0 1.0 Once every 5 years Routine inspections a 1.5 2.5 Annually Recordkeeping 0.5 1.0 Annually Drydock inspection 2.0 4.0 Once every 5 years Annual report b 1.5 3.0 Annually

Source: EPA, 2008, unless otherwise noted. The assumed burden for routine inspection and annual report has been revised to reflect comments received from industry representatives that estimates presented in EPA, 2008 were too low.
a The burden for routine inspections has been revised from 1.0 and 2.0 hours.
b The burden for preparation of the annual report has been revised from 0.5 and 2.0 hours.

Two revi sions to the VGP requirements have the potential to reduce compliance costs for certain
vessel owners in non

- negligible ways: the submittal of combined annual reports for barges and the reduced frequency of routine inspections for vessels that are unmanned for an extended period
of time

. The effects of these two changes are discussed below.

To estimate the effect of reducing the number of annual reports needing to be submitted for barges, EPA used data on the average number of barges operated by the same ow ner (see Section
3.3 ). According to MISLE data, barge operators have, on average, 13 barges. Some operators, however, have significantly more barges under their name (up to a maximum of nearly 4,000) and

37 companies have more than 100 barges each. Savings associated with a single annual submittal for all barges may therefore be significant. Table 4-28 presents savings calculated across all barge based on MISLE data, assuming that companies with more than three barges will submit a single annual report to EPA and that submitting a combined report takes about a quarter of the time necessary to prepare a single report

.

Table 4- 28

. Incremental Burden (Reduction) for Combined Barge Annual Reports.

Scenario Number of Individual Annual Reports Submitted Total Annual Report Costs d
Individual Reports (Baseline) a 45

, 58 2 $2,305,697
Combined Single Report Submitted b 1 9

, 320 $1,396,142 Change c ( 2 6
, 262 ) ( $909,554 )

a Assumes that one report per barge is submitted to EPA

. b Companies with more than 3 barges are assumed to submit a single combined report for all of their barges

. c Negative value represents a reduction (saving) relative to baseline requirements.
d. Costs are estimated assuming 1.5 hour per baseline individual report (see above for burden assumption based on EPA, 2008). For combined report, each barge included in the report after the first one is assumed to require 1/4 of the burden of an individual report. Costs associated with the burden hours are calculated using a labor rate of $33.72/hour.

Estimating the effects of the revised requirements for unmanned vessels is complicated by the lack of data on the number of vessels that are unmanned for extended periods of time. Reductions in the burden may be significant particularly in cases where the VGP requirements are the sole reason for conducting an inspection. Under the 2008 VGP, a vessel owner may be conducting aEconomic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 110 weekly inspection of the vessel with VGP

- related recordkeeping representing only a small component of the inspection. Conducting routine inspections on a bi- weekly basis only while the vessel is unmanned for an extended period of time, for example during a six month period, reduces the annual burden associated with VGP compliance by 25 percent (for this particular example). The reduction in burden may be even larger, however, than suggested by the VGP burden alone, since the VGP burden is expressed as incremental burden beyond existing inspections and an owner may not need to perform a weekly inspection during this period other
than to co mply with the 2008 VGP routine inspection requirement.

4.4.2 PAPERWORK REQUIREMENT BURDEN FOR NEWLY COVERED COMMERCIAL

FISHING VESSELS

As shown previously in Table 4-26 , commercial fishing vessels are assumed to have costs that are similar to those of other “small” vessels such as passenger vessels (except cruise ships), utility vessels, and barges.

Based on the burden assumptions presented in the previous s ection , the commercial fishing vessels newly covered under the 2013 VGP are estimated to incur incremental costs from general inspection and paperwork requirements of about $36 1,000 for the high end estimate. Details of
this estimate are shown in Table 4-29

. For the low end estimate, the vessels are assumed to already implement all general inspection and recordkeeping practices as part of their existing business practices, except for the Permit

- specific NOI submission and annual report and the total cost is estimated at $137,296

.

Table 4- 29

. Incremental Burden Assumptions for General Inspection and Paperwork
Requirements for Commercial Fishing Vessels

.

Requirement Number of Vessels a Cost per Vessel b Total Costs

NOI 321 $8.22 $2,640 Routine inspections c 2, 184 $ 50

. 58 $110,475 Recordkeeping c 2,184 $16.86 $36,825 Drydock inspection c 2,184 $16. 86 $35,925 Annual report 2,184 $ 50

. 58 $110,475

Total ( Low End Estimate) $113,115 Total ( High End Estimate) $296,339

a The count excludes 142 commercial fishing vessels that submitted an NOI as of August 2010. The burden for these
vessels is already included in the baseline for this rule. b The costs are calculated assuming a labor rate of $33.72.

c Cost is excluded from low end estimate

4.5 A NALYSIS OF T OTAL N ATIONAL C OSTS

The estimated total compliance costs for each of the practices that have the potential to represent
an incremental cost to vessel owners are provided in Table 4-30

. The estimated VGP compliance costs vary between the low and high end estimates because of the different assumptions made regarding the vessel populations and the number of instances for which incremental costs will beEconomic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 111 incurred. As shown in the table, the largest share of incrementa l costs is associated with practices
related to the oil- to

- sea interface discharge category , followed by those in the ballast water and graywater discharge categories. Various changes to streamline the paperwork requirements for certain types of vessels ar e expected to result in a n aggregate reduction in inspection and recordkeeping burden and associated costs.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 112 Table 4- 30

. Total Annual Compliance Costs
, by Practice Cate gory and Vessel Class

Vessel Class Total Annual Cost s (2010$)

Deck
Washdown Bilge Water a Ballast

Water Cathodic
Protection Oil to Sea
Interfaces Graywater Exhaust Gas
Scrubber
Washwater General Inspection
and Paperwork
Low End Estimate
Commercial Fishing $0 $ 0 a $260,106 $0 $534,654 $52,414 $0 $113,115 Freight Barges $0 $ 0 a $0 $0 $1,821,140 $0 $0

- $771,017 Freight Ships $0 $ 0 a $626,605 $0 $544,316 $25,554 $24,418 $0 Passenger Vessels $0 $ 0 a $96,809 $0 $483,069 $96,594 $0 $0 Tank Barges $0 $ 0 a $0 $0 $327,422 $0 $0

- $138,537 Tank Ships $0 $ 0 a $32,762 $0 $103,580 $10,292 $9,990 $0 Utility Vessels $0 $ 0 a $52,539 $0 $2,169,474 $46,289 $0 $0

Low End Total $0 $0 a $1,068,820 $0 $5,983,656 $231,144 $34,408

- $796,440
High End Estimate

Commercial Fishing $141,627 $ 0 a $626,994 $144,496 $1,642,369 $91,574 $0 $296,339 Freight Barges $0 $ 0 a $0 $0 $5,606,986 $0 $0

- $771,017 Freight Ships $0 $ 0 a $1,476,474 $0 $1,630,424 $32,332 $53,570 $0 Passenger Vessels $0 $ 0 a $217,782 $0 $1,483,289 $103,221 $0 $0 Tank Barges $0 $ 0 a $0 $0 $1,007,702 $0 $0

- $138,537 Tank Ships $0 $ 0 a $73,702 $0 $309,930 $13,053 $21,918 $0 Utility Vessels $0 $ 0 a $118,192 $0 $6,641,840 $77,768 $0 $0 High End Total $141,627 $0 a $2,513,144 $144,496 $18,322,539 $317,948 $75,488

- $613,215

a EPA is considering optional bilge water practices. Since the practices are not included in the proposed 2013 Permit, however, potential incremental costs to vessel owners are not included in the cost of the proposed Permit.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 113 Table 4-31 summarizes the total estimated costs to each vessel class across the discharge categories. As shown in the table, total annual costs range between $6.5 million and $20.9 million , depending on the set of assumptions used.

Table 4- 31

. Total Annual Compliance Costs for All Practices, by Vessel Type
, Including Paperwork Costs.

Vessel Type Total Cost (2010$) a

Low End Estimate Commercial Fishing $960,288 Freight Barges $1,050,123 Freight Ships $1,220,893 Passenger Vessels $676,472 Tank Barges $188,885 Tank Ships $156,625 Utility Vessels $2,268,302

Low End Total $6,521,588 High End Estimate Commercial Fishing $2,943,399 Freight Barges $4,835,969 Freight Ships $3,192,800 Passenger Vessels $1,804,293 Tank Barges $869,164 Tank Ships $418,603 Utility Vessels $6,837,800 High End Total $20,902,027 a Only includes U.S. flagged vessels

.

4.6 UNCERTAINTIES AND LI MITATIONS

There is significant uncertainty in several assumptions that affect the costs discussed in this section, including:

 The number of vessels expected to implement practices to comply with new requirements is uncertain. In addition to uncertainty regarding the number of vessels operating in U.S. waters (see Section 2.6 ), there is also uncertainty regarding practices currently implemented by active vessels. For practices that are included in (or were considered for)
the 2008 VGP for at least some vessels , EPA used information obtained from industry representatives during the development of the 2008 VGP. The information reflected conditions before promulgation of the VGP and therefore may differ from baseline practices currently being implemented. EPA also relied on infor mation compiled from NOIs received through August 2010. The NOI information is self-reported and not always reported across all vessels. Nonetheless, it likely provides the most relevant indicator of practices implemented by the subset of NOI vessels for the analysis baseline. To account for uncertainty in the number of vessels that implement practices, EPA used ranges wherever possible to indicate the sensitivity of the results to varying assumptions.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 114  Cost information was obtained from industry during the development of the 2008 VGP. EPA complemented this information with additional research of public data and personal communications with industry experts. For example, the costs of bilge water treatment systems were developed by reviewing manufacturer speci fication , published literature, and through interviews with industry representative s. Costs for laboratory tests, soaps and cleaners, and other practice components were obtained using similar methods. Because EPA made a limited number of contacts, the relevant estimates are likely to be subject to uncertainty regarding their applicability to different vessels considering the diversity of
vessel characteristics and operations

. Wherever possible, EPA used ranges to reflect the diversity in costs.

 For certain practices
– most notably the use of environmentally acceptable lubricants
– EPA was unable to obtain detailed information on either product costs or quantities likely to be purchased for different types of vessels, despite numerous attempts to obtain the information from various industry representatives including from lubricant manufacturers, vessel owners, or ship maintenance companies. Industry representatives
we contacted could not provide the requested cost information either because they

co nsidered the data confidential business information

, because they did not feel that their
data were sufficiently representative , or because they felt that any estimate they may be able to develop would not appropriately capture variability across vessels o r locations.
The anecdotal information EPA was able to obtain regarding EAL prices or volumes were not sufficiently detailed to be used in the analysis . For the purpose of this preliminary analysis , EPA relied on pricing information obtained from retail ve ndors and on an illustrative example provided by one industry representative. The assumed prices for conventional and EALs may be higher or lower than prices actually paid by vessel owners for different products and vessel types. EPA estimated quantities of lubricants for different vessel classes based on leakage rates reported for different types of vessels in Edkin (2010). The amount of lubricant purchased by vessel owners would have to be at least enough to make up for leaks and leakage rates may therefo re represent a lower bound for the amount of lubricant purchased. Anecdotal information EPA compiled from industry representatives suggests, however, that these volumes are generally within the range of annual consumption of lubricants used in oil- to

- sea i nterfaces for different
classes of vessels

.  T here is uncertainty about the number of vessels to which some practices apply , either because of a lack of detailed information about individual vessels or because of evolving technologies that may change the character of vessel discharges

. Requirements applicable

to discharges from exhaust gas cleaning systems (EGCS) apply to a subset of vessels that use such systems (see Section 4.2.26 ). A present, only a handful of vessels use EGCS and projections on the number of domestic vessels that may be equipped with EGCS in the future are highly speculative. To reflect the uncertain ty, EPA used ranging assumptions on the number of vessels to which the different requirements may apply.

Given the se important areas of uncertainty, the cost estimates discussed throughout this report
should be interpreted as illustrative of the range of incremental costs that may result from complying with the revised VGP requirements, and not as a precise account of costs that a vessel owner may incur for any specific vessel.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 115 

### 5 A NALYSIS OF I MPACTS ON F IRM R EVENUES AND F INANCIAL

P ERFORMANCE

The previous cha pters assessed total compliance costs to vessels of revisions to the VGO requirements. As summarized in Section 3

, most of these vessels are associated with firms in the fishing and water transportation industries. Section 4 presents the ranges of incremental costs that may be incurred by each vessel covered by the VGP, depending on the assumed unit costs of each required practice, which may vary by vessel type, size, and operating characteristics

. To determine the economic impacts of revisions to the VGP, EPA examine d the incremental compli ance costs relative to the financial conditions of “typical” businesses associated with the
affected vessels

. Since over 9 5 percent of the firms in the water transportation and fishing
industries and in the drilling oil and gas wells sector are small (see Section 3.4.3 ), it is unlikely that a significant number of large firms would incur material impacts. Large firms are also more likely to operate larger or a great er number of vessels. Because the relative impact of VGP compliance and the number of affected entities are expected to be much greater for small
entiti es, 50 the firm

- level analysis focuses on assessing impacts on small businesses,.

5.1 M ETHODOLOGY

The analysi s involves combining the estimated incremental operating costs att ributed to compliance with the 2013 VGP with information about baseline financial conditions of model firms in each industry to examine the potential financial impacts on firms

. Cost

- to

- revenue ratios are used as metrics for potential financial stress, where financial stress may reveal itself as a lack of profitability, cash deficiencies, or even bankruptcy. Firms expected to experience financial stress may need to change their bu siness operations, including potentially downsizing or closing operations.

The key steps of the analysis involve: (1) assigning each vessel in the vessel database to a NAICS code, (2) estimating the number of vessels per firm in each industry, (3) estimat ing the distribution of compliance costs per vessel and per firm, and (4) comparing the costs to the firm

revenues

. These steps are described below.

5.1.1 A SSIGN E ACH V ESSEL TO A N AICS C ODE

The framework for the model firms reflects the range of firm types acros s the major industry groups. Financial data for each major industry groups are available in the Economic Census while SBA provides firm data by revenue bracket. Since the Economic Census does not have the same vessel categories as compared to other data sources ( notably the MISLE / WTLUS database , which

50 Small entities are defined as one of the following: A small business according to SBA size standards; a small governmental jurisdiction that is a government of a city, county, town, school district, or special district with a population of less than 50,000; or a small organization that is a not

- for

- profit enterprise that is independently owned and operated and is not dominant in its field.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 116 contains more complete numbers of all potentially regulated vessels and firms), each of the vessels and firms from the vessel database was assigned to a NAICS code to correspond to the Economic Census industry categories. The number of firms likely to incur costs as a result of the Permit was identified using the MISLE data based on the number of uniquely named managing owners for vessels expected to be covered by the VGP. The number of firms likely to incur co sts as a result of the Permit was identified using the MISLE and WTLUS databases. Firms identified in the vessel databases were assigned a NAICS code in order to determine the number of firms subject to permit requirements for each NAICS code. Industry cla ssification information for individual firms listed in the vessel databases was obtained primarily from ReferenceUSA’s Business Database (ReferenceUSA, 2006)

, Dun & Bradstreet’s Million Dollar Database (Dun & Bradstreet, 2006) and manta.com , supplemented by company Web sites and industry publications. Both ReferenceUSA and Dun & Bradstreet link subsidiaries and branch offices to company headquarters, allowing for an identification of domestic parent entities. Dun &
Bradstreet’s Million Dollar Database class ifies businesses based on eight -digit Standard Industrial Classification (SIC) codes. Since both the Census and SBA base their data on NAICS codes, EPAmatched the first four digits of the SIC codes provided in Dun & Bradstreet to corresponding sixdigit N AICS codes using the U.S. Census Bureau’s bridge between 1987 SIC and 2002 NAICS codes (U.S. Census Bureau, 2002b). 2007 NAICS codes for the affected industries are unchanged
from their 2002 definitions . The Dun & Bradstreet company names were matched to the vessel owner/operator names in the MISLE / WTLUS database to provide a NAICS code classification
for most vessels in the vessel database. Vessels that could not be matched to a NAICS code based on their owner/operator were allocated to the NAICS sectors u sing the relative distribution of vessels across the sectors, by vessel type.

Once the number of firms with vessel permits was estimated for each NAICS code, EPA distributed these firms across revenue size categories proportionally to the distribution of f irms by revenue size category indicated in Economic Census data. This estimated distribution of firms by revenue size category is assumed to be more accurate than estimates that could be derived solely from the Economic Census, since the Economic Census includes firms that are not expected to be affected by the rule. These totals were used to determine the number and percentage of firms experiencing economic impacts.

5.1.2 E STIMATE THE N UMBER OF V ESSELS P ER F IRM

To establish the baseline and post

- cost financials for each model firm, the per- vessel practice costs developed in Section 4 are applied to the firm level. To determine the total incremental costs that a firm could incur, EPA first estimated the average number of vessels owned and operated by
firms in each NAICS se ctor using information from the combined MISLE/ WTLUS database.

As shown in Table 5-1 , the average number of vessels varies across the NAICS sectors fr om about one vessel per owner in the fishing industry, to nearly four vessels per owner in the support activities for water transportation sector.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 117 Table 5-1 : Number of Vessels by Firm in Each Industry Sector.

Number of Vessels Listed Under the Same Managing Owner NAICS Description Minimum Maximum Average Water Transportation Industry Deep Sea, Coastal, and Great Lakes Water Transportation 1 32 1.8 Inland Water Transportation 1 72 2.0
Scenic and Sightseeing Transportation, Water 1 24 1.3 Support Activities for Water Transportation 1 74 3.7 Fishing Industry Fishing a 1 96 1.1 Mining Industry Drilling oil & gas wells sector 1 34 3.1

Source: EPA analysis of MISLE data (USCG, 2009).

For each NAICS code, EPA determined the number of vessels that were listed with a firm name as well as the number of firms corresponding to these vessels. Based upon the total number of firms and vessels within the subset in each NAICS code, the average number of vessels per firm was determined for each NAICS code. However, since this value is expected to vary among the different firm sizes, this average value was adjusted for each revenue size category so that the average number of vessels in each revenue size range is proportional to the midpoint of revenue in a revenue size category and the total number of vessels obtained when multiplying the number of firms by the number of vessel is equal to the total vessel population.

EPA expects that some firms, partic ularly those in the smallest revenue category (annual revenue less than $100,000), may not operate vessels subject to the 2013 VGP. For example, they may use vessels less than 79 feet that are instead covered by the sVGP. This is consistent with reported

r evenue per vessel discussed in Section 3.4.2

, which indicate revenue for the larger vessels that are often greater than the average revenue of firms in the smallest revenue category (approximately $50,000). For example, revenue of commercial fishing firms using medium and large vessels ranged between $82,000 and nearly $2.5 million, with average revenue to Northeast fishermen using vessels 75 feet and averaging $790,779 per vessel in 2010 (NOAA, 2011b). Historical data of per vessel reve nue for other industry sectors suggest earnings in the $10,000 to $40,000 per day (USCG, 2008). While these represent averages for certain types of vessels and operations and variability is expected, the figures nonetheless suggest that larger vessels such as those covered by the VGP are perhaps less likely to be operated by firms in the lowest revenue category. Accordingly, EPA allowed the average number of vessels for firms in the lowest revenue category to be less than one ( 0.5 vessels per firm), reflect ing the fact that no t all of the smallest of firms operate vessels subject to the 2013 VGP and/or the vessels they operate tend to
be at the lower end of the size range and have lower compliance costs (e.g., less likely to use onboard ballast water treatment, consume less lubricants, require less complex inspections)

.

5.1.3 E STIMATE THE D ISTRIBUTION OF C OSTS P ER V ESSEL

For each vessel type and discharge category, EPA has already estimated in Section 4 : (1) the total number of vessels, (2) the probability of a vessel incurring incremental costs, and (3) theEconomic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 118 incremental cost of each practice . By assuming that the probability of incurring an incremental cost for a given practice is independent of incurring costs for any of the other practices , EPA can estimate the probabilities of incurring costs for all possible combinations of practices

.

In the analysis, the low end cost estimate includes up to five possible practices , and the high end
cost estimate includes up to six possible practices. Treating each practice cost as an independent, binary “on/off” cost event, this means that there are theo retically 2 5 and 2 6 possible combinations of cost events for the low end and high end cost estimate, respectively. Each combination cost event is defined on the basis of whether or not each of the specific practices is “on” or “off” (and
the resulting cost s) together with the probability of each practice being “on” or “off.” Each practice is assigned a probability of occurrence for each vessel class by dividing the number of vessels estimated to incur a given practice cost by the total number of vessels, an d therefore this is the probability for the individual practice to be “on.” Conversely, the probability of the
individual practice being “off,” is equal to one minus the probability of the practice occurrence. The overall probability of occurrence for a gi ven practice combination is the product of these individual probabilities. As a result, most of the cost combinations are not meaningful for the impact analysis because one or more of the practice “on/off” instances in the combination event have a zero probability of occurrence, and thus the overall probability of that particular event, which is calculated as the product of the individual “on” or “off” practice probabilities, is zero. The high occurrence of zero probability combination practice events results from the presence of practice costs that are always assumed to be incurred, or have one hundred percent probability of
occurrence. The maximum number of observed practice combinations for a vessel type is
therefore smaller than the theoretical 64 possib ilities ( 64 = 2 6 ).

For each of the possible practice combinations, EPA multiplied the total number of vessels by vessel class by the calculated probability of the combination practice event to estimate the number of vessels incurring costs for a given com bination of practices . Finally, EPA calculated the per

- vessel cost by vessel class associated with each combination of practices by summing the
costs of the individual practices where costs are incurred. This calculation provided the distribution of per

- vessel costs. The distribution shows a high probability of occurrence for very
low cost combination practice events. The probability of occurrence declines rapidly as the cost
of the combination practice events increases. The higher cost combination practice events

— which require a combination of all or nearly all of the individual practices

— have a very low probability of occurrence.

EPA estimated the distribution of per- firm costs f rom the distribution of per- vessel costs using the following approach. For firms in industries with more than one vessel class, EPA estimated vessel costs corresponding to the minimum, maximum and each 10 percentile increment in between
these extremes
– th ereby yielding 6 possible vessel costs, which are assumed to be equally likely. For firms in industries with two vessel types, EPA evaluated the firm costs for 6 2 possible combinations of costs. For firms in industries with N vessel types, EPA evaluated th e firm costs
for 6 N possible combinations of costs – 6 possible costs for each vessel class. For each industry, EPA calculated an average per

- vessel cost from the vessel class

- specific costs for all 6 N possible
combinations based on the relative number of vessels in each class. This average cost per vessel was then multiplied by the number of vessels per firm in each industry for a given revenue size category. Thus, for industries with more than one vessel class, EPA estimated a distribution of costs per fi rm with 6 N equally likely possibilities, where N is the number of vessel classes observed for the industry

. There were three sectors with only one vessel class, three sectors withEconomic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 119 six vessel classes , and one sector each with two, three, four, and five and seven vessel classes

. Figure 5-1 illustrates the calculation of firm cost impact for one possible combination of vessel

costs and one revenue size bra cket in a sector with two vessel classes.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 120 Figure 5-1 : Illustrative calculation potential firm cost for one sector with two vessel types

.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 121 5.1.4 COMPARE FIRM

- LEVEL COSTS TO FIRM

- LEVEL REVENUES

Data from the Economic Census as well as from the SBA’s Statistics of U.S. Businesses were
used to determine the firm -level financial data for the transportation and mining industries. These sources provided the distribution of firms across several revenue brackets as well as the average revenue value in each revenue bracket. For firms associated with commercial fishing vessels, we combined Census information with statistics from NOAA and other sources on revenue per vessel (see Section 3.4 ) to characterize the distribution of revenue among firms of different sizes.

To evaluate the potential impact of the revised VGP on small entities, EPA used a cost

- to

- revenue

test to evaluate the potential severity of economic impact on vessels and facilities owned by small entities. The test calculates annualized pre

- tax compliance cost as a percentage of total revenues
and uses a threshold of 1 and 3 percent to identify facilities that would be significantly impacted
as a result of this Permit.

The cost values equivalent to the 1 and 3 percent thresholds were estimated from the average revenue in each revenue bracket, or the midpoint of the revenue bracket when average revenue

wa s not reported. EPA estimated the percentage of firms that would be significantly impacted as a result of the VGP revisions as the percentage of firm for which the estimated firm

- level costs (number of vessels times the per vessel compliance costs) exceede d the 1 percent or 3 percent
revenue thresholds.

5.2 S MALL E NTITY A NALYSIS

As described , EPA prepared an analysis that examines the impacts of this Permit on small entities. A small entity may be:

 A small business according to SBA size standards ;

 A small governmental jurisdiction that is a government of a city, county, town, school district, or special district with a population of less than 50,000; or

 A small organization that is a not-for- profit enterprise that is independently owned and operated and is not dominant in its field.

The SBA defines small businesses based on NAICS codes and size standards expressed by the number of employees or annual receipts (13 CFR §121.20). For the water transportation, fishing, and drilling oil and gas wells sectors, SBA ’s business size standards are based on annual revenues as well as employee size. The thresholds are as follows:

 Deep sea, coastal, and Great Lakes water transportation; inland water transportation
– fewer than 500 employees

 Scenic and sightseeing transpor tation; navigational services to shipping and salvage; other support activities for water transportation – revenues less than $7 million

 Port and harbor operations; marine cargo handling – revenues less than $25.5 million

 Fishing – revenues less than $4 million

 Drilling oil and gas wells sector – fewer than 500 employees (U.S. SBA, 2010).Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 122 If the revenues or employment were smaller than the corresponding thresholds, EPA classified
the entities as small. Section 3.4.3 presents the number of small businesses in each sector of the water transportation and fishing industries, and of the drilling oil and gas wells sector within the mining industry. On the whole, the affec ted industries consist of more than 90 percent small businesses. Based on data from the U.S. Census Bureau and the SBA, of the 4, 603 firms in the water transportation industries, 4, 365 (95 percent) are small. In th e fishing industry, 1,973 (96 percent) of the 2,053 firms are small. In the drilling oil and gas wells sector, 2,073 (98 percent) of the 2,109 firms are small.

After calculating the distribution of per

- firm costs, the number and percentage of firms where
costs exceed 1 percent and 3 pe rcent of revenue was estimated (by NAICS sector and revenue bracket).

The costs used in th is economic analysis are annualized costs, which reflect the annual equivalent
value of first

- year (one

- time) costs and recurring costs . The resulting 2010 annualized costs for implementing practices to address relevant discharges range from $0 to about $6,700 per vessel

, with the upper value for a freight ship assumed to incur the maximum of each applicable practice

cost

. Maximum compliance costs vary depending on the vessel type . For example, the maximum
annual cost for a barge assumed to incur the maximum of each and every applicable practice is
less than $500 , with most of this cost associated with oil

- to

- sea interface practices

. Across all vessel categories, r elati vely few vessels incur the maximum compliance costs and average annual costs are significantly lower: between $26 and $3,933, depending on the vessel type.

After calculating the distribution of per

- firm costs, the number of firms where costs exceed

1 percent and 3 percent of revenue was estimated (by NAICS sector and revenue bracket). The costs used in the economic analysis are annualized costs, which reflect the annual equivalent
value of first

- year (one

- time) costs and recurring costs.

Table 5-2 summarizes the average firm

- level revenue , number of firms, and cost thresholds

across industry sectors for the 1 percent and 3 percent cost

- to

- revenue tests. The cost thresholds indicate the compliance costs that would correspond to 1 percent and 3 percent of revenue, and yield a significant impact based on the c ost

- to

- revenue test. Because the impact of VGP compliance is likely to be most significant for firms at the lower end of the firm size spectrum

, the table focuses on firms in the smallest revenue category in each industry. T his category
includes firms earn ing less than $100,000 each year.

As shown in the table, compliance cost thresholds range between $330 and $2,040 per year for
the 1 percent and 3 percent levels, respectively, depending on the industry.

.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 123 Table 5-2

. Estimated 1% and 3% Revenue Thresholds by NAICS Code for Firms in Smallest Revenue Category

.

NAICS Industry Average
Revenue of

Firms in Category a Number of
Firms in

Revenue Category Compliance Cost

at 1% Revenue

Threshold Compliance Cost at
3% Revenue

Threshold

Water Transportation b

483111 Deep sea freight transportation $33,143 7 $331 $994

483112 Deep sea passenger transportation $49,417 12 $494 $1,483

483113 Coastal/Great Lakes freight transportation $56,765 17 $568 $1,703

483114 Coastal/Great Lakes passenger transportation $53,154 13 $532 $1,595

483211 Inland waterways freight transportation and towing transportation $3 3,0 00 1 6 $3 30 $1,056

483212 Inland waterways passenger transportation and other water transportation c $50,000 34 $500 $ 990

487210 Scenic and sightseeing transportation, water $48,283 247 $483 $1,448

488310 Port and harbor operations $60,636 11 $606 $1,819

488320 Marine cargo handling $68,000 11 $680 $2,040

488330 Navigational services to shipping and salvage $55,661 56 $557 $1,670

488390 Other support activities for water transportation $59,742 120 $597 $1,792 Fishing d

1141 C ommercial fishing $ 53,079 505 $ 531 $1, 592 Mining d

213111 Drilling oil and gas wells $ 48,316 237 $ 483 $1, 449

213112 Support activities for oil and gas operations $46,890 826 $469 $1,407

a Category includes all firms with receipts less than $100,000.

b Source: U.S. Census: Transportation and Warehousing: Subject Series - Estab lishment & Firm Size: Summary Statistics by Revenue Size of Firms for the United States: 2007

c No average revenue per firm is available. The value reflects the mid

- point of the revenue size category.

d Source: SBA: U.S. All Industry Data by Receipt Size: 2007.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 124 Table 5-3 presents the distribution of the entities’ cost

- to

- revenue ratios. As summarized in Table

5-3

, the model results suggest that the total number of entities in the fishing industry that are expected to exceed the one percent cost

- to -revenue threshold ranges between 0 and 189 for the low end and high end cost assumptions , respectively

. 51 If we assume that all these entities are small, this number represents about 10 percent of small firms. The total number of entities in the water transportation industry that are expected to exceed the one percent cost

- to

- revenue threshold ranges from 52 t o 171 under the low and high end cost assumptions, respectively

, representing up to 6 percent of small firms, if we assume that all affected entities are small
firms

. 52 Overall, up to 7 percent of firms have costs estimated to exceed the one percent cost

- to

revenue threshold and less than 1 percent of firms are estimated to exceed the three percent cost

to -revenue threshold, based on high end cost estimates. 53

The critical cost thresholds range depending on revenue range and NAICS code. For example, a
firm i n the commercial fishing industry within the revenue range of $0- $100,000 (with average revenue for firms within the bracket of $ 53,079) would have a one percent critical cost threshold of $531. On the other hand, a firm within the marine cargo handling industry within the revenue range of $100 million or more (with average revenue of over $235 million) would have a one percent critical cost threshold of nearly $2.4 million. The majority of firms in the water transportation, fishing industry

, and the drilli ng oil and gas wells sector have revenue ranging between $100,000 and $499,999. As shown in Table 5-3

, the percentage of firms expected to exceed the 1 percent threshold under both the low and high end cost assumptions ranges from 0 to 21 percent depending on the NAICS code. In examining the percentage of entities affected, the most impacted entities fall within the navigational service and inland waterways transportation
sectors. These two sectors both have over 15 percent of entities that exceed the 1 percent threshold under the high end cost assumptions, but both have fewer than 100 entities (and less
than 10 percent) estimated to exceed the 3 percent threshold . Under the low end cost assumption,
less than 10 entities exceed the 3 percent threshold in the two sectors combined.

As discussed l ater in Section 5.3

, there is uncertainty in the estimated impacts of the revised VGP requirements on small entities , due to the way costs are allocated to vessels and to firms. In the absence of more detailed information on the characteristics of vessels and their respective owning firms, the analysis is meant to illustrate the potential magnitude of impacts to firms of different sizes. Considering per vessel revenue described earlier in this section and in Section 3.4.2 , EPA believes that the analysis may overestimate impacts on the smaller f irms by overstating their compliance costs.

51 The distributional analysis model is likely overstates impacts to firms in this sector due methodology limitations
discussed later in this Section and in Section 5.3 , notably EPA’s conservative assumptions regarding the distribution of vessels to firms across size categories and relatively uniform characteristics of vessels assigned to firms with very
different annual revenue.

52 Idem.

53 Idem.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 125 Table 5-3

. Results of the Small Entity Impact Analysis

.

NAICS Code NAICS Description 1 Percent of greater Between 1 and 3

Percent 3 Percent or greater

#
Firms % All

Firms %
Small

Firms #
Firms % All

Firms %
Small

Firms #
Firms % All

Firms %
Small

Firms
Low End Cost Estimate

11411 Finfishing, shellfishing, and other commercial fishing 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0% 483111/483113 Deep sea/coastal and Great Lakes freight 2 0.4% 0.4% 2 0.4% 0.4% 0 0.0% 0.0% 483112/483114 Deep sea/coastal and Great Lakes passenger 5 2.8% 2.9% 5 2.8% 2.9% 0 0.0% 0.0%

483211 Inland waterways freight transportation and towing transportation 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0%

483212 Inland waterways passenger transportation and other water transportation 6 3.5% 3.5% 6 3.5% 3.5% 0 0.0% 0.0%

487210 Scenic and sightseeing transportation, water 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0%

488310 Port and harbor operations 3 1.3% 1.5% 3 1.3% 1.5% 0 0.0% 0.0%

488320 Marine cargo handling 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0%

488330 Navigational services to shipping and salvage 37 5.7% 6.7% 37 5.7% 6.7% 0 0.0% 0.0%

488390 Other support activities for water transportation 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0%

TOTAL 52 0.9% 1.0% 52 0.9% 1.0% 0 0.0% 0.0% High End Cost Estimate

11411 Finfishing, shellfishing, and other commercial fishing 189 9.2% 10.2% 189 9.2% 10.2% 0 0.0% 0.0% 483111/483113 Deep sea/coastal and Great Lakes freight 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0% 483112/483114 Deep sea/coastal and Great Lakes passenger 17 10.6% 10.9% 15 9.2% 9.4% 2 1.4% 1.4%

483211 Inland waterways freight transportation and towing transportation 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0%

483212 Inland waterways passenger transportation and other water transportation 37 21.0% 21.0% 34 19.2% 19.2% 3 1.8% 1.8%

487210 Scenic and sightseeing transportation, water 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0%

488310 Port and harbor operations 27 13.5% 15.4% 26 13.0% 14.9% 1 0.5% 0.6%

488320 Marine cargo handling 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0%

488330 Navigational services to shipping and salvage 90 14.1% 16.6% 85 13.3% 15.6% 5 0.8% 0.9%

488390 Other support activities for water transportation 0 0.0% 0.0% 0 0.0% 0.0% 0 0.0% 0.0%

TOTAL 360 6.0% 6.6% 348 5.8% 6.4% 11 0.2% 0.2% Figures do not necessarily add to totals due to rounding.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 126 5.3 UNCERTAINTIES AND LIMITATIONS

In addition to uncertainty previously discussed in Section 4.6 relating to the compliance cost estimates for the various discharge categories, the distributional analysis discussed in this section involves additional uncertainties related to how these costs are allocated to firms in each industry

sector.

For example, there is uncertainty surrounding the assignment of vessels to firm s of different sizes. The VGP applies to non- recreational and non

- military vessels 79 feet or more in length only.
Vessel and f irm

- level data are not sufficiently detailed, however, to assign vessels of different
sizes to firms in different revenue categor ies

. Yes, the results of the distributional analysis are sensitive to this assumption. For the purpose of this analysis, EPA assumed that firms in the smallest revenue category potentially own and operate vessels covered by the VGP , and, further,
that thes e firms are as likely as larger firms to own and operate a ny of the vessels covered by the VGP, regardless of its size or complexity . Instead, firms in the smallest revenue category possibly own and operate smaller vessels not covered by the VGP but instea d covered separately under the

sVGP . These firms would incur no incremental costs due to the revised VGP requirements

. Even
in cases where small firms own vessels covered by the VGP, these vessels may be smaller and less complex than the vessels owned by l arger firms. As was discussed in Section 3.4.2 , per vessel revenue generally increases with vessel size, suggesting that firms with lower revenue generally operate smaller vessels. Because of this distribution and because compliance costs tend to increase with vessel size and complexity, the analysis may overstate impacts on small firms. EPA adjusted the distribution to account for this to some degree by allowing firms in the smallest of the revenue categories (firms with annual revenue le ss than $100,000) to be assigned costs for
less than one VGP vessel.

In conducting the distributional analysis, EPA did not include cost savings associated with streamlining of the inspection, recordkeeping, and paperwork requirements. This is due to the difficulty of assigning these cost savings to any specific vessel since the savings will depend on the number of vessels owned by any given firm. As discussed in Section 4.4 , however, these cost savings could be significant for firms with multiple freight or tank barges or with unmanned
vessels

. For each revenue bracket, EPA assumed that firm revenues were equal to the average revenue in
the bracket (or the midpoint when the average was not available). There is uncertainty associated with this simplifying assumption, because calculating an average firm cost results in less variation compared to an alternative approach that simulates a distribution of firm revenues within revenue size ranges.

There is uncertainty surrounding EPA’s assumption that the average number of vessels per firm is proportional to the midpoint of the revenue bracket. These assumptions may result in
underestimation or overestimat ion of the number of vessels per firm, and the underestimation or overestimation may vary by revenue size category. In general, EPA believes that it is reasonable
to assume that the smalle r firms are likely to own or operate fewer vessel s, or may own or op erate
a vessel that is smaller than the VGP size threshold of 79 feet

. There is uncertainty surrounding the choice of using only 11 possible costs for each vessel class (mini mum, maximum, and by 10 percentile increments) and more accurate estimates could beEconomic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 127 obtained by using a greater number of cost possibilities. However, since industries can have up to seven vessel types, the number of sampled vessel costs is limited by computational feasibility - with up to 6 possible vessel

- class costs and 7 vessel types there are 6 7 possible firm costs.

After simulating a sample of vessel class costs, EPA calculated an average cost per vessel across all vessel classes within each industry sector. For example, NAICS 483212 include both passenger vessels and utility vessels, and on average, firms in the lowest revenue bracket have
one vessel. Since 98 percent of the firms’ vessels are passenger vessels, the firm cost is estimated as the weighted average of vessel costs ( 0.98 * [Passenger Vessel Cost] + 0.02 * [Utility Vessel

Cost ])

. There is uncertainty associated with this simplifying assumption, because calculating a weighted average vessel cost results in less cost variation compared to an alternative approach
that simulates a distribution of vessel class es for firms.

Finally, there is uncertainty associated with the simplifying modeling assumption that practices are cost events with independent probabilities of being assigned to any one vessel. Instead, EPA expects that larger vessels are more likely to i ncur costs for more of the applicable practices, i.e., a vessel that is large enough to use a BWTS to comply with the ballast water requirements could also be more likely to employ bilgewater treatment.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 128 

### 6 BENEFIT S ANALYSIS

EPA expects that reductions in ves sel discharges resulting from revisions to the VGP will benefit society in two broad categories: (1) reduced risk of invasive species introduction and (2) enhanced environmental quality from reduced pollutant discharges. Section 6.1 : Ballast Water and Invasive Species Impacts provides a qualitative assessment of the ecological and economic impacts of invasive species introductions and the benefits of reducing the occurrence of invasive species

. Section 6.2 : Benefits of Reduced Pollutant Discharges from Vessels discusses poll utants of concern (POCs) found in vessel discharges, their environmental effects, and the benefits likely to be achieved by the revised VGP requirements.

6.1 BALLAST WATER AND INVASIVE SPECIES IMPAC TS

6.1.1 INTRODUCTION AND BAC KGROUND

Introductions of non- indigenous species have occurred in the United States for centuries, with more than 50,000 total non-native species thought to be successfully established with reproducing populations in U.S. territory (Pimentel et al., 2005). Scientists and governments have long recognized the economic and ecological damages associated with land

- based invaders, but attention has only turned toward aquatic non-indigenous species (ANS) since the 1980s, when the extent of the zebra mussel invasions in the Great Lakes region first became a serious problem (Ruiz and Reid, 2007). ANS invasions have caused tremendous economic and ecological damages to critical coastal and inland waters throughout the United States.

ANS may be introduced through a variety of vectors, including intentional introductions, escape from a confined environment, or ballast water and sediment from ballast tanks. One of the major known vectors for ANS introduction is through the ballast water tanks of commercial vessels. Ballast water is taken on in or near port to provide stability to ships that are not fully loaded. Often, aquatic invertebrates, plants, or microorganisms, as well as suspended sediments that may contain invasive species, are u nintentionally taken in along with the ballast water.

Studies conducted by NOAA’s Great Lakes Environmental Research Laboratory (GLERL) found that a majority of ships and a near-majority of tanks surveyed contained non-indigenous strains of pathogens known to cause human health impacts (Johengen et al., 2005; Reid et al., 2007). The Johengen et al. (2005) study also found that viable populations of non- native dinoflagellate and invertebrate species were present in a large majority of tanks sampled. Glassne r-Shwayder (1999) refers to ships with ballast water as “biological islands” because they carry such a wide variety of organisms in their ballasts. According to some studies, as many as 4,000 species can be found in a typical ship’s untreated ballast water at one time.

When this ballast water is discharged in another port, or when sediments in the ballast tank are mixed with new ballast water, these species can be introduced into an exotic environment, and may become established under some conditions (Ruiz and Reid, 2007). Several of the most harmful invasive species currently known to exist in the United States, including the zebra mussel, the green crab, and the Asian clam, are all thought to have been introduced via ballastEconomic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 129 water. Researchers hypothesize that as international trade, and therefore shipping traffic, increases, so does the threat of more ANS introductions (Glassner -Shwayder, 1999).

The U.S. Coast Guard’s 2004 Rulemaking for Mandatory Ballast Water Management (codified in 33 CFR 151) mandated open ocean ballast water exchange for ships traveling outside the 200- nautical mile exclusive economic zone (EEZ) of the United States. While promulgation of the

USCG regulation is reducing the probability of new introductions, it covers neither vessels

tr aveling within the U.S. EEZ nor vessels with empty ballast tanks, both of which are potential sources of ANS introductions. The ballast water provisions of EPA’s 2008 VGP aimed to address these gaps where possible, further reducing the possibility of ANS i ntroductions. Specifically, the 2008 VGP required ballast water exchanges at least 50 nm from shore for vessels engaged in Pacific nearshore voyages, which were previously exempted from mandatory exchange procedures. It also required saltwater flushing for vessels declaring no ballast on board (NoBOB) or for vessels with some proportion of their ballast tanks empty. Several states have promulgated regulations that complement or strengthen national ballast water management requirements specified in the 2008 VGP

. While useful in reducing the presence of potentially invasive organisms in ballast water, ballast water exchange and saltwater flushing have variable effectiveness and may not always be feasible due to vessel safety concerns ( EPA SAB, 2011). On August 28, 2009, the U.S. Coast Guard proposed new ballast water management standards to revise rules at 33 CFR 151 (74 FR 44632).
These standards were proposed to be implemented in phases , with “Phase One” standards specifying limits on the discharge of living organisms that are similar to IMO’s Regulation D -2. 54 Since the Phase One standards are expected to be in effect by the time vessels must obtain coverage under the 2013 VGP , EPA incorporated the USCG Phase One/IMO D -2 requirements in
its new Permit

. The 2013 VGP also includes monitoring, sampling, testing, and reporting requirements to verify the efficacy of ballast water treatment systems used onboard vessels. Stricter limits on ballast water discharges and the confirmatory monitoring and testing wil l contribute to reducing the risk of ANS invasions and their consequences.

6.1.2 ANS IMPACTS

ANS invasions are a persistent problem in U.S. coastal and inland waters. ANS invade U.S. waters through a number of dispersal mechanisms including releases from fisheries; research and education facilities; restoration efforts; public aquaria and the aquarium pet industry; and by being attached to or within ships, drydocks, amphibious planes, floating marine debris, drilling platforms, navigation buoys and marine floats, canals, and recreational equipment (Carlton et al., 2003). Each vector has been associated with introductions of highly damaging species in the past, although this analysis will focus primarily on the ballast vector described in the previous section.

54 If practicability review shows that it is feasible, this Phase One standard would be followed by a “Phase Two” standard that set concentration limits at 1,000 times more stringent than Phase One standards for viable organisms greater than 10 microns and for bacteria and viruses.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 130 Though no reliable and comprehensive estimates of total ANS introductions nationwide exist, case studies of several major bodies of water across the country, as summarized in Table 6-1

, provide a sense of the extent of the problem.

Table 6-1 : Estimates of Invasive Species in Several Major Water Systems.

Region Estimated Rate of Invasion a Estimated Total Invasi ons to
Date b

Great Lakes Once every 28 weeks c 162 Mississippi River System Unknown 100 San Francisco Bay Once every 24 weeks d 212
Lower Columbia River Basin Once every 5 months e 81
Gulf of Mexico Unknown 579

a Ruiz and Reid (2007) suggest that these figures may not reliably represent the true rate of introduction, as they are based on discovery data, which may not always track with the underlying rate of i ntroduction.
b All figures in this column are taken from USCG (2004b).
c NOAA (2007).
d Cohen and Carlton (1995).
e Sytsma et al. (2004).

The total costs associated with ANS in the United States are staggering. A recent study suggests that expenditures on control alone for ANS in the United States total approximately $9 billion annually (Pimentel et al., 2005). A broad range of damages are associated with any introduction of a given type of species, summarized in Table 6-2

. Although some species cause no economic damage, others may cause hundreds of millions of dollars in damages. The majority of these damages may be broken down into six broad categories of impacts, which are described in the
sub sequent subsections.

Table 6-2 : Estimates of Invasive Species Damages by Type of Species.

Type of Species Range of Potential Damages per Invasion per Year (Million 2010 $ )
Fish 0

– 161 a

Mollusks 0

– 6,415 b

Non

- Mollusk Invertebrates 0

– 23.8 c

Plants 0

– 36.9 d
Pathogens 0

– 0.764 e

a Based on Ruffe (Leigh, 1998), adjusted to 2007$ using CPI.
b Based on Zebra Mussel (Pimentel et al., 1999), adjusted to 2007$ using CPI.
c Based on European Green Crab (EPA, 2008a). d Based on hydrilla (OTA, 1993), adjusted to 2007$ using CPI.
e Based on an outbreak of epidemic cholera (Lovell and Drake, 2007), adjusted to 2007$ using
CPI.

COMMERCIAL AND RECRE ATIONAL FISHERIES
As noted above, the introduction of ANS can cause the imbalance of native ecosystems. ANS pose an especially serious risk to commercial and recreational fisheries, which like other aquaticEconomic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 131 resources could be devastated by ANS (IDNR, 2003). Several examples of ANS impacts on fisheries are provided below (reported dollars are for the publication year)

.  Sea Lamprey: The sea lamprey, which is native to the Atlantic Ocean, was not initially introduced to the Great Lakes by ballast water, but has been introduced elsewhere through contaminated ballast water (Toledo, 2001). Upon its initial introduction, the sea lamprey caused a massive collapse of the trout fisheries in the Great Lakes. If sea lamprey control measures were eliminated, the resulting lost value to fi sheries would be approximately $500 million annually, according to one estimate (OTA, 1993). Control measures that have been introduced to counteract the impacts of sea lampreys cost more than $12 million annually (ANSTF, 2007).

 European Green Crab: The mo st likely mode of the initial European green crab introduction on the East Coast of North America was ship fouling (Cohen et al., 1995). Other possible pathways of introduction include ballast water and solid ballast. Grosholz (2006) and Cohen (1997) belie ve that incidental transport with commercial fishery products is the most likely vector for the initial introduction of C. maenas to the West Coast. The annual estimated economic damages from European green crab predation to
commercial and recreational she llfisheries and eelgrass restoration efforts range from $18.6 to $22.6 million per year in the United States (EPA, 2008a).

 Round Goby: The round goby, native to Eurasia and likely introduced via ballast water, is thought to have adverse impacts on fisherie s, due to its lack of value as a sport or commercial catch and its aggressive tendencies toward baited lines. Fishermen report that they are sometimes able to catch only gobies when fishing for the more desirable walleye (Marsden and Jude, 1995). No attemp ts to quantify the value of these impacts have been
made to date.

 Zebra Mussel: An invasion of zebra mussels, which are native to the Caspian Sea and were introduced to U.S. waters in ballast water, has led to a halt in the $3 billion dollar Mississippi River shell fish ing industry (Randall, 2001).

 Pathogens: Pathogens transported in ballast water can also have significant adverse impacts on fisheries. Infectious salmon anemia (ISA) has been a persistent problem in
U.S. Atlantic fisheries’ stocks since 200 1. The original source and vector of this pathogen is unknown. Though there has been no attempt to quantify damages to the U.S. economy specifically from ISA, it is estimated that the annual cost in 1999 was $11 million in Norway, $14 million in Canada and $32 million in Scotland (Cipriano and Miller, 2002).

Another recent fish pathogen of concern has been viral hemorrhagic septicemia (VHS). VHS has been known to exist in the coastal regions since the late 1980s, but only recently migrated into the Great Lakes through an unknown vector (USDA, 2006). An unpublished study found that VHS has impacted 6 of 23 fish species caught commercially in the Great Lakes, including two that account for 76 percent of the entire $13.5 million dollar harvest (Lovell and Drake, 2007). In 1991, an exotic strain of Vibrio
cholerae (epidemic cholera) was identified in oysters in Mobile Bay on the Gulf Coast. The estimated economic losses due to the closure of oyster harvesting in Mobile Bay for five months in 1991 as a response to concerns about epidemic cholera contamination were $726,000 (2007$) (Lovell and Drake, 2007).Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 132 Two non- native pathogens, MSX ( Haplosporidium nelsoni ) and Dermo ( Perkinsus marinus) have caused substantial damages to native oyster populations in several U .S. coastal regions. Though the original vector of introduction is unknown for both pathogens, ballast water is considered to be one potential source of MSX, and Dermo is known to transmit relatively easily between infected and uninfected oysters (McKnight

, 2007; Ewart and Ford, 1993).

OTHER WATER

- BASED RECREATION AND TOURISM
ANS have also had adverse impacts on recreation and tourism nationwide by damaging water quality and flow. Two invasive plants, hydrilla and water lettuce, have caused significant damages in U.S. waters. Both clog the water’s surface, blocking boating and swimming, impeding water flow, and disrupting plant and animal communities. Florida spends an estimated $1 million or more annually to control water lettuce, and the rest of the Eastern U.S. states spend approximately $100,000 annually (Van Driesche et al., 2002). Studies of two lakes in Florida affected by hydrilla found that degradation caused by the hydrilla cost the state $11 million in lost recreation expenditures (Pimentel et al. , 1999). 55

Invasive mollusks such as zebra mussels can also adversely affect a number of recreationalactivities, including boating and swimming. Zebra mussels often cover shorelines with sharpedged shells and rotting mussel flesh, which can diminish interest in visiting infested beaches. Biofouling can also be a deterrent to recreational boaters who would rather avoid zebra mussel fouling and the resulting necessity of extensive vessel cleaning (USACE, 2002). A study by Vilaplana and Hushak (1994) estimated that incremental annual costs to boat owners in the Great Lakes related to the mussel included $94 for protective anti

- fouling paints, $171 for additional maintenance, and $207 for insurance.

BIODIVERSITY AND ECO SYSTEMS

Introductions of ANS can drastical ly alter virtually every characteristic of an aquatic ecosystem. ANS can affect the “composition, density, and interactions of native species” that can then cause “significant changes to the ecosystem, such as alterations to the food webs, nutrient dynamic s and biodiversity” (IDNR, 2003). Ecosystems provide a variety of services, including water quality maintenance, detoxification and decomposition of waste, climate stabilization, mitigation of natural disaster impacts, and a source of income. Several significant instances of adverse ecosystem impact include:

 Zebra Mussel: Zebra mussels have had some of the most dramatic impacts observed to date on ecosystems, particularly in the Great Lakes region. The mussels achieved densities as high as 700,000 per squar e meter, which led to a much greater filtration rate of particulate matter, resulting in much lower turbidity (Griffiths et al., 1991; MacIsaac et al., 1995). This in turn led to much greater filtration of light through the water column,

55 This cost may have an adverse impact locally, but because the money is still available to be spent elsewhere, this adverse impact does not represent a true net welfare loss.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 133 which affected pla nt viability and substantially increased competition for food for indigenous mollusks.

 Round Goby: The round goby was first introduced into the Great Lakes region via ballast water. The goby preys on benthic fauna competing with species native to the Grea t Lakes and takes over prime spawning sites of native species, which is changing the balance of the ecosystem. Introduction of the round goby adversely affected a number of native species, including mottled sculpin, logperch, and darters. Due in part to th e threat posed by the Round Goby and the Asian Carp, the U.S. Army Corps of Engineers and U.S. EPA have spent $1.2 million to erect a dispersal barrier to prevent its further spread down the Chicago Sanitary and Ship Canal to the Mississippi River (Glassne r-Shwayder, 1999).

 European Ruffe: The European ruffe preys on native fish and competes with them for
habitat. It was introduced into the Great Lakes via ballast water and poses a serious threat to species like the walleye, yellow perch, and whitefish (Leigh, 1998). Populations of spawning European ruffe in the St. Louis River went from 200,000 in 1989 to 1.8 million in 1991. At the same time, populations of yellow perch, troutperch, emerald shiners, and spottail shiners decreased by 75 percent (RTF, 1992). The expected reduction in value of sport and commercial fisheries in the Great Lakes region due to the ruffe invasion is $119 million (ANSTF, 2007).

 Snowflake Coral: Carijoa riisei , or snowflake coral, an invasive coral species, is threatening the ecosystem stability of the ecologically sensitive Northwestern Hawaiian Islands Coral Reef Ecosystem Reserve (NOAA, 2004a; Toonen, 2005). It is also a threa t to the native black coral, which a local industry valued at $30 million harvests and uses to make jewelry.

THREATENED AND ENDANGERED SPECIES
Invasions have had especially adverse impacts on threatened and endangered species by predation, alteration of h abitat, or further competition for limited resources. It is estimated that non-indigenous species are a contributing factor to the endangered status of 70 percent of listed fish species, and more than half of combined endangered and threatened listings (OTA, 1993). They are also estimated to have contributed to 68 percent of fish extinctions in the last 100 years (Larson and Sytsma, 2006).

DAMAGE TO INFRASTRUC TURE
Industrial facilities, such as those that purify water, generate electricity, and manufacture goods, depend on water intake structures to perform their services. These structures can often be adversely affected by ANS.

So far, zebra mussels have been the most damaging ANS introduced into U.S. fresh waters, causing particularly severe problems with water intake structures (USACE, 2002). Zebra mussels attach to surfaces of water intake structures, navigation dams, pumping stations, and gears, often making them inoperable, which inconveniences the public and costs industry significant financial
losse s and damages (USACE, 2002).

Hushak (1996) reports on the results of 398 surveys of Great Lakes users with lake water intake structures from 1989 to 1994 for private and public utilities, municipal water facilities, andEconomic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 134 industrial users. Extrapolating the results of this survey to all facilities in the Great Lakes yielded total monitoring and control costs of $120 million from 1989 to 1994 with an average cost of $30 million annually (Park and Hushak, 1998). Another study done in 1995 of the economic impact of zebra mussels (O’Neill, 1997) found that the total costs of zebra mussels control and monitoring were $69 million, with a mean cost of $205,570 per facility. The study results also showed that total annual expenses rose from $234,140 in 1989 to $17,751,000 in 1995 as the range of mussels increased (O’Neill, 1997).

Another invasive bivalve species, the Asian clam, is estimated to have caused fouling damage that cost the nuclear industry about $1 billion per year in the early 1980s (OTA, 1993). Two other invasive bivalves, the brown mussel and the green mussel, have also caused fouling damages in the Gulf Coast region and Tampa Bay, respectively, where each has become established, although the total economic value of the damages is not known (Benson et al., 2002; GSMFC, 2003).

Finally, invasive plant species such as hydrilla and water hyacinth can disrupt water flow in irrigation canals and in utility cooling reservoirs. Annual expenditures on aquatic weed control in the United States, much of which is sp ent on ANS weeds specifically, are estimated at $110 million (Pimentel et al., 2005).

HUMAN HEALTH IMPACTS
Though the exact nature of the link between human health impacts and ANS invasions through ballast water is poorly understood, studies have established that pathogenic invasive species can be transported in ballast water (Ruiz and Reid, 2007). Moreover, in the case of epidemic cholera, a serious human pathogen, the presence of non- native strains was previously confirmed in U.S. waters (CDC, 1993). The potential human health impacts associated with ballast water transport are an object of increasing concern. Some pathogenic bacteria identified in ballast water known to be associated with adverse human health impacts include E. coli , enterococci, Vibrio c holerae

, Clostridium perfingens

, Salmonella spp

. Cryptosporidium spp ., and Giardia spp. , as well as a variety of viruses (Knight et al., 1999; Reynolds et al., 1999; Zo et al., 1999).

In July 1991, a strain of Vibrio cholerae was identified in oysters in Mobile Bay on the Gulf Coast that was indistinguishable from a Latin American strain not endemic to the United States. An investigation indicated that the pathogen was most probably introduced from the discharge of contaminated ballast water (CDC, 1993). B ecause oysters are often eaten raw, this is a potential human health threat. Of the 61 cases of cholera in the United States between 1995 and 2000, 14 were caused by the consumption of undercooked seafood (Steinberg, 2001). Though it is unclear whether any of these cases were caused by exotic strains of Vibrio cholerae , this evidence clearly indicates that the potential exists for the transport of harmful non

- native pathogens in ballast

water.

As mentioned in the introduction to this section, a study by NOAA also showed the potential for pathogens to be transported in ballast water tanks, even when they are not filled. The study found
that virus -like particle concentrations in sampled ballast tanks ranged from 10 7 to 10 9 per ml in residual unpumpable ballast water and from 10 7 to 10 11 per ml in sediment porewater. Bacteria
concentrations under the same conditions were 10 5 to 10 9 per ml and 10 4 to 10 8 per ml, respectively (Johengen et al., 2005). As in the 2008 VGP, and as an interim requirement in the

2013 VGP (to be phased out as treatment is required), saltwater flushing in vessels with emptyEconomic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 135 ballast tanks will assist in reducing these risks by removing sediments may reduce the potential for pathogen contamination.

Ballast water is also a vector for the microorganisms associated with the “red tide” or harmful algal bloom phenomenon. This phenomenon occurs when certain species of algae release toxins into an aquatic environment, which adversely impacts aquatic life and can also impact human
health if fish contaminated with the toxin are consumed (WHOI, 2007). Although current USCG mandatory BMPs for all vessels with ballast tanks, codified in 33 CFR 151, require vessels not to take up ballast water in areas known to be contaminated with such organisms, the new Permit’s requirements governing ballast exchange may further reduce the spread and impact of these organisms.

6.1.3 EFFICACY OF VGP BALLAST WATER MANAGEMENT PRACTICES

The incorporation of ballast water discharge standards in the 2013 VGP is expected to provide benefits through a reduction in the concentration of living organisms, leading to lower numbers of these organisms being introduced per discharge. Additional monitoring, sampling, testing, and reporting requirements will help further this benefit by verifying that BWTS perform according to their design specifications and meet the discharge limits. This overall strategy should reduce the
number of new invasions because the likelihood of establishment increases with the number of organisms introduced per discharge or inoculation (Ruiz et al. 2000a, Minton et al. 2005).

6.1.4 BENEFITS OF REDUCING ANS INTRODUCTIONS

The evidence presented in Section 6.1.2 : ANS Impacts demonstrates that introductions of ANS through ballast water are associated with significant detrimental impacts throughout the United States. The ballast water provisions of EPA’s final Vessel General Permit, to the degree that they fill a gap in the existing ballast water management practices, can therefore be expected to generate benefits by reducing the risk of such damages in the future. B enefits would include the prevention of damages to fisheries, tourism, and recreation, of damages to infrastructure, and of adverse human health impacts, as well as prevention of further stresses on native biodiversity and
ecosystems.

The issue of ANS inv asions and their impacts presents unique challenges for the estimation of the benefits associated with this Permit. Although ballast water is one of the major pathways of invasive species introduction, estimating changes in risk of introduction of invasive species from the Permit requirements is not feasible due to the lack of data on rates of invasive species introduction associated with ballast water releases. Moreover, because the type of species introduced in the future is unknown and the range of poten tial economic impacts associated with each species type is very large, estimating the monetary value of benefits from preventing future invasions with a reasonable degree of certainty would not be possible.

COMMERCIAL AND RECREATIONAL FISHERIES
A reduction in the number of ANS introductions due to the final ballast management requirements and other Permit requirements may prevent significant future damages to commercial and recreational fisheries that play a critical role in the U.S. economy. In 2009,
7.9 b illion pounds of fish and shellfish were landed by U.S. commercial fishermen at U.S. ports,Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 136 and were valued at $3.9 billion (NMFS, 2010). An additional 29.9 million anglers aged 16 and older spent an average of 17 days fishing in 2006, spending more than $40 billion dollars on trips, equipment, licenses, and other costs (USDOI, 2007). Leigh (1998) estimated the annual reduction in value of yellow perch, walleye, and whitefish fisheries due to ruffe invasion under moderate scenario assumptions to be $119 million (in 1998 dollars; $159 million (2010$) inflated using the Consumer Price Index (CPI)).

OTHER WATER

- BASED RECREATION AND TOURISM

An other source of potential benefits from the reduction of ANS introductions under the Permit will be the prevention of damages to valuable recreation and tourism sites. A report by NOAA (2004b) estimated the annual revenue associated with coastal tourism in the United States to be $54 billion, and found that beaches are the most popular tourist destinations in the United States. One invasive plant species alone, hydrilla, is associated with $14.5 million annually in control costs, and reduces lake recreation on two Florida lakes alone by $11 million in years when hydrilla covers the lakes (Pimentel et al., 1999). Since data are limited on the impacts of invasive species on recreation and tourism in ecosystems for which estimated rates of invasion exist, it is not possible to calculate the level of expected benefits for other water

- based recreation and tourism. However, EPA projects that there will be some incremental benefits.

BIODIVERSITY AND ECO SYSTEMS
Additional significant benefits from the Permit will accrue to biodiversity and ecosystems. As
detailed in Section 6.1.2 : ANS Impacts

, ANS are associated with substantial adverse impacts on the composition of ecosystems and the biodiversity therein. The quantification of biodiversity benefits will not be attempted in this analysis due to the great deal of uncertainty surrounding the impact of a single ANS introduction on a given ecosystem relative to other factors, as well as the difficulty of predicting the rate of ANS introduction. However, potential benefits in the form of preservation of habitat and species are likely.

THREATENED AND ENDANGERED SPECIES
The Permit requirements for ballast water management, by reducing the impacts of invasive species introductions on threatened and endangered spec ies, will have benefits in terms of prevention of reduction in species population and species extinction. Total federal spending nationwide on programs related to the Endangered Species Act for 2004, the most recent year for which data are available, was m ore than $1.2 billion, and state spending was more than $200 million (USFWS, 2005).

As mentioned above, ANS are considered likely contributors to the threatened or endangered status of 70 percent of listed fish species (Larson and Sytsma, 2006). Combined f ederal and state expenditures per listed species of fish in 2004 ranged from $25,000 to $1.09 million (USFWS, 2005). It is not possible to calculate a range of benefits to threatened and endangered species associated with EPA’s Permit requirements, due to the lack of research linking specific invasions with quantifiable impacts on particular species. However, it is likely that some proportion of potential future expenditures on endangered and threatened fish, as well as expenditures on other aquatic endange red species, would be averted by reduced ANS introductions under the Permit requirements.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 137 DAMAGE TO INFRASTRUC TURE
Another benefit of the Permit requirements for ballast management will result from averting damages to infrastructure by invasive species of plants and mollusks. Fouling by species such as the Asian clam, zebra mussel, and hydrilla has caused substantial economic damage to a variety of municipal and industrial entities in the past. Most of this damage takes the form of clogging
water intake st ructures and disrupting the flow of water. One study estimated fouling damage to water intake infrastructure by zebra mussels for the year 2000 to be $5 billion (Khalanski (1997), and cited in Pimentel et al. (1999); $6.1 billion in 2007$ using CPI).

HUMAN HEALTH
Estimating expected human health benefits of EPA’s Permit is not feasible due to very limited
data on the rates of non

- endemic pathogen invasions and the human health effects of these pathogens. Nevertheless, the Permit provisions are likely to re duce the probability of introduction of harmful exotic pathogens and thus are expected to benefit human health.

SUMMARY OF BENEFITS
The ballast water discharge standard and management practices established in the 2013 VGP are designed to directly address the likelihood of future ANS invasions. The categories of potential damages from such ANS invasions have been discussed above, and studies referenced as to the potential magnitude of these damages for each. To the degree that these damage estimates provide an indicator of the likely payback that can be anticipated from reducing ANS invasions, EPA believes the benefits of this Permit can be expected to be very significant

. However, the complexity of analyzing the probability of ANS introduction and spread, the wide range and varied nature of impacts ANS invasions can cause, and the great breadth of the scope of this Permit prohibit EPA from developing a quantified estimate of these benefits.

6.2 BENEFITS OF REDUCED POLLUTANT DISCHARGES FROM VESSELS

6.2.1 INTRODUCTION A ND BACKGROUND

The Clean Water Act and its associated regulations have greatly improved the quality of the nation’s waters over the past 40 years. Nevertheless, large portions of the United States’ fresh and saline waters remain degraded by elevated concent rations of harmful pollutants. As summarized by EPA, 50 percent of assessed rivers and streams; 66 percent of assessed lakes, ponds, and reservoirs; 64 percent of assessed bays and estuaries; and 38 percent of coastal shorelines were classified as impaired for at least one of their designated uses (EPA, 2011). 56 Impairments of designated uses – the protection and propagation of fish, shellfish, and wildlife and the harvesting of aquatic life, among others – are associated with a variety of economic and ecological damages.

56 States are responsible for assessing impairment of water bodies. States assessed 26 percent of rivers and streams; 42 percent of lakes, ponds, and reservoirs; 21 percent of bays and estuaries; and 4 percent of coastal shorelines in the reporting cycle summarized in this report (generally ranging from 2002 an d 2010, depending on the state, with data for most states reflecting assessments completed as of 2008).Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 138 The causes of impairment vary by waterbody, but commonly include pathogens, oxygen enrichment/oxygen depletion, nutrients, metals, turbidity, oil and grease, and nuisance exotic species. 57

As detailed in EPA’s 2010 study, several of these causes have associated pollutants that have be found in discharges incidental to the normal operation of vessels. For example, EPA found significant concentration of nutrients in deck runoff, graywater, bilge water , and fish hold tanks.

The 2013 VGP contain several new provisions aimed at reducing pollutant loadings incidental to vessel operation, either by minimizing the introduction of pollutants in the vessel effluents (e.g., use of environmental preferred cleaners or lubricants), employing treatment techn ologies to decrease pollutant loadings in the discharges, and by requiring regular inspection and monitoring to identify and address potential problems. In the section below, we describe the types of pollutants that may be found in vessel discharges and di scuss how the 2013 VGP revisions may help reduce loadings of these pollutants to waters of the U.S. and therefore generate potential benefits for aquatic ecosystems. These benefits will be likely to occur mostly in waterways receiving the greatest amount of vessel traffic.

The Permit covers many discharges and contains special provisions for numerous vessel types. Because of the breadth of coverage and provisions in the Permit, the following discussion does not address all of these provisions individually, but focuses on the more important changes in
Permit requirements for certain types of vessel discharges.

6.2.2 POLLUTANTS COMMONLY FOUND IN VESSEL DISC HARGES

The numerous individual harmful constituents of vessel discharges may be grouped into six broad
catego ries: nutrients, pathogens, oil and grease, metals, other pollutants with toxic effects, and
other non- toxic pollutants. Many of the 27 types of discharges covered by EPA’s Permit are associated with one of these six types of pollution. Table 6-3 summarizes pollutant types potentially reduced by Permit requirements. 58

Table 6-3. Pollutants Found in Vessel Discharges a

.

Type of Discharge Nutrients Pathogens Oil &

Grease Metals Other
Toxics Other

Non

Toxics

Deck Runoff X X X X X Bilge water X X X X

Anti

- fouling Hull Coating X X

AFFF X
Boiler Blowdown X X
Cathodic Protection X
Chain Locker Effluent X X

57 The risk of introduction of ANS is discussed in the next section.

58 The effect of ballast water provisions on risk of introduction of ANS is discusse d in the preceding section.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 139 Type of Discharge Nutrients Pathogens Oil &

Grease Metals Other
Toxics Other

Non

Toxics
Controllable Pitch Propeller Hydraulic Fluid X X

Elevator Pit Effluent X X X Firemain Systems X X X X Freshwater Layup X
Gas Turbine Wash Water X X Graywater X X X X X X
Motor Gasoline and Compensating Discharge X X

Non

- Oily Machinery Wastewater X X X Refrigeration and Air Condensate Discharge X X

Rudder Bearing Lubrication Discharge X

Seawater Cooling Overboard Discharge X X

Seawater Piping Biofouling
Prevention X

Small Boat Engine Wet Exhaust X X

Sonar Dome Discharge X X Underwater Ship Husbandry X Welldeck Discharges X X X X X X
Fish hold effluent X X X X X X
Source: Battelle (2007) a. Other Permit requirements that could not be firmly linked to one of these six categories of pollutants are excluded from the table

Several types of discharges address by revisions to the VGP have particularly significant pollutant constituents and therefore also may be associated with substantial incremental benefits. They are described in more detail below.

GRAYWATER
Untreated graywater contains multiple constituents of concern, including pathogenic bacteria, toxic and carcinogenic organic and inorganic compounds, nutrients, and metals (EPA, 2007a ; EPA, 2010b ). Table 6-4 summarizes the rates of discharge for major pollutants found in graywater in an EPA survey of cruise ships. The same survey found that total graywater discharge volumes ranged from 36 to 119 gallons/day/person, with a mean value of 67 gallons/day/person.

Table 6-4. Types of Pollutants Found in Graywater Discharges

Type of Discharge Average Concentrations of
Pollutants a EPA NRWQC Standard b

Ammonia – Nitrogen 2130

- 2210 μg N/L 2140

- 15,600 μg N/L CMC,

321

- 2960 μg N/L CCC

Nitrate 0.009

- 0.0872 mg/L

------ Total Kjeldahl Nitrogen 11.1

- 26.2 mg/L

------ Total Phosphorus 3.34

- 10.1 mg/L

------Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 140 Type of Discharge Average Concentrations of
Pollutants a EPA NRWQC Standard b

Fecal Coliform 2,950,000 MPN/100 mL 43 MPN/100 mL

Enterococci 8920 MPN/100 mL 35 MPN/100 mL
Hexane Extractable Material c 78

- 149 mg/L

------ Arsenic 1.22

- 2.25 μg/L 0.14 μg/L

Copper d 483

- 510 μg/L total, 195 μg/L
dissolved 74 μg/L CMC, 8.2 μg/L CCC

Nickel 29.7

- 48.7 μg/L total, 18.2 μg/L
dissolved 4.8 μg /L CMC, 3.1 μg/L

CCC
Thallium 0.93 μg/L total, 0.403 μg/L dissolved 0.47 μg/L (in shellfish)

Zinc 790

- 2540 μg/L total, 1610 μg/L
dissolved 90 μg/L CMC, 81 μg/L CCC

Bis(2

- ethylhexyl) phthalate 22.4

- 71.9 μg/L 2.2 μg/L Tetrachloroethylene 10.7

- 11.4 μg/L 3.3 μg/L

Phenol 1.16

- 52.5 μg/L

------ Total Residual Chlorine e 372 μg/L 13 μg/L CMC, 7.5 μg/L CCC

Chlorides 125 mg/L

------ Source: EPA (2007a)

Note: Because of the quantity of metals and toxics detected, only pollutants exceeding EPA’s national recommended water quality criteria (NRWQC) or pollutants discussed elsewhere in this analysis are listed here. a Ranges presented in this table represent differences in reported concentrations between data from the Alaska Cruise Ship Initiative of the Alaska Department of Environmental Conservation (ACSI/ADEC), and EPA’s own data, both presented in EPA (2007a). b EPA has not set NRWQC for all pollutants of interest. CCC is an abbreviation for Criterion Continuous Concentration, a long

- term measure of pollutant loading. CMC is Criterion Maximum Concentration, a short

- term

measure. c Hexane extractable material is considered an indicator of level of oil and grease contamination. d ACSI/ADEC did not conduct separate sampling for dissolved metals, so a range is not listed for dissolved metals. e EPA did not sample total residual chlorine; ACSI/ADEC did not sample chloride.

Prior to the promulgation of the 2008 VGP , discharges of graywater had been largely unregulated at the federal level in the territorial waters of the United States, with two exceptions: the Great Lakes, where graywater discharges must be treated similarly to sewage discharges under the
Clean Wate r Act; and the territorial waters of Alaska, where graywater discharges by cruise ships within the territorial waters are subject to discharge standards. Maine, Washington, Hawaii, and
Florida also have state

- level programs to reduce the impacts of graywater discharges from cruise ships.

Under the revised VGP

, vessels that discharge treated graywater within 1 nm of shore will have to comply with new monitoring requirements to help ensure the proper functioning of their
treatment system

. Releasing large vol umes of untreated graywater in nearshore environments, estuarine environments, or in waters with limited circulation is more likely to cause negative environmental impacts. This is because these environments are likely to have higher vessel traffic and, th erefore, greater graywater generation and discharge, are more likely to be stressed by other anthropogenic forces, and are likely to have less ability for dilution and assimilative capacity. The revised VGP clarifies that the graywater requirements also ap ply to v essels operating on the Great Lakes that are not commercial vessels, as defined in CWA section 312(a)(10) , which will help protect the ecosystem of the Great Lakes.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 141 BILGE WATER
Bilge water is water from a variety of sources, including wastewater and leakage, which drains into a compartment in a vessel’s inner hull. While its composition and physical- chemical characteristics can vary widely, both over time and between different vessels, bilge water typically contain s various hydrocarbons and fuels, g rease, antifreeze, hydraulic fluids, cleaning and degreasing solvents, detergents, metals ( arsenic, copper, cadmium, chromium, lead, mercury, selenium and zinc), catalytic fines, soot, and other solid particles (sludge) (EPA, 2008).

Among the constituents of bilge water, oils and greases are a primary concern

. Oil is present in free form, dispersed, or emulsified. Oil/hydrocarbon concentrations in vessel bilges commonly fall in the 100 to 400 ppm range (US Navy 1999-2000). Ghidossi et al., (2009) reported a somewhat higher 500 ppm oil concentration in the bilge water of a ferry. Water accumulating in a vessel’s bilge spaces is periodically pumped to a holding tank to maintain vessel stability and prevent hazardous conditions resulting from its accumulation. The bilge water can then be managed either by retaining it onboard and later discharging it to a reception facility on shore, or treating it onboard with a bilge separator to meet applicable standards and regulations. Existing regulations are based on Annex I of the MARPOL 73/78 and require all vessels weighing more than 400 tons to have equipment that limit the discharge of oil into the oceans to 15 ppm when the vessel is en route. However, this practice does not eliminate all oil and grease from discharges, but merely reduces it to a level below 15 ppm

.
EPA’s VGP revisions address this gap by retaining existing requirements governing untreated bilge water but reducing the oil and grease concentration limit for discharges of treated bilge

water to 5 ppm. Though these requirements will not eliminate all discharges of harmful pollutants
via bilge water , they will reduce the loads in areas with heavy vessel traffic that are in nearshore
environments. Several of the more advanced treatment systems that can red uce effluent concentrations to below 5 ppm also reduce concentrations of other pollutants. For example biological treatment systems degrade oils while also removing other organic pollutants such as glycols, solvents, detergents, nitrogen, and phosphate. Us e of these systems may therefore be beneficial beyond their ability to reduce oil pollution into receiving waters.

ENVIRONMENTALLY

- ACCEPTABLE LUBRICANT S
The 2013 VGP mandates the use of environmentally- acceptable lubricants (EALs) in oil

- to

- sea interface a pplications for existing vessels (subject to technical feasibility) and for all new build vessels. While use of EALs has been increasing in the last decade, revisions to the VGP will further increase the use of these products, and result in decreased envir onmental impact from the operational discharges of oil. Because the majority of a lubricant is composed of the base oil, the base oil used in an EAL must be biodegradable. The three most common categories of biodegradable base oils are: 1) vegetable oils, 2) synthetic esters, and 3) polyalkylene glycols. Traditional mineral oils have a small biodegradation rate, a high potential for bioaccumulation and a measurable toxicity towards marine organisms. In contrast, the base oils derived from oleochemicals (vegetable oils and synthetic esters) degrade faster and have a smaller residual, do not bioaccumulate appreciably and have a lower toxicity to marine organisms. Polyalkylene glycol

- based lubricants are also generally biodegradable and do not bioaccumulate; however, some PAGs are more toxic due to their solubility. Lower environmental impacts will occur when a greater proportion of base oils are manufactured from non- mineral based oils

.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 142 6.2.3 POLLUTANT IMPACTS

Vessel discharges contain a wide variety of pollutants w ith the potential to cause ecological and economic harm to aquatic species and their habitat. The relationship between types of pollutants and associated discharges wa s summarized in Table 6-3, above.

OIL AND GREASE
Oil and grease are a component of vessel discharges with potentially harmful impacts to humans and to aquatic life. Oil in vessel discharges is required to be discharged in concentrations that may not be harmful, consistent with existing regulation under 40 CFR part 110. The Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP), a United Nations body, found that voluntary vessel discharges account for less than 1 percent of vessel oil discharges into the marine environment ( GESAMP, 2007). However, vessel discharges may still contain enough oil to do ecological damage, even if they meet existing concentration requirements and account for a small percentage of total oil discharges worldwide. Oils are highly toxic and carcinogen ic, and may inhibit reproduction and cause organ damage or even mortality (AMSA, 2003). Additionally, oil can taint organisms that are consumed by humans, which is a potential source of adverse health impacts.

The 2013 VGP strengthens requirements applica ble to several oil discharge categories to minimize and reduce discharges of oil and grease from several sources, including during bilge

water and oil- to

- sea interfaces. For bilge water, for example, the permit sets strict requirements for the monitoring o f any treatment system present onboard a vessel. The 2013 VGP also mandates the use of environmentally acceptable to reduce loading of harmful compounds into the aquatic environment.

NUTRIENTS
Nutrient pollution, including nitrogen and phosphorus, is a component of vessel discharges and a major source of water quality degradation throughout the United States (USGS, 1999). Though traditionally associated with agricultural runoff from fertilizer, sewage treatment facilities, and urban stormwater, a variety of other sources do exist, including graywater and bilge water discharges from ships. Revisions to the VGP requirements applicable to these types of discharges are expected to reduce loadings of nutrients to receiving waters.

Nutrient pollution is associated with a variety of negative environmental impacts, the most notable of which is eutrophication, which can lead to reduced levels of dissolved oxygen due to increased demand (sometimes to the ex tremes of hypoxia), reduced levels of light penetration and turbidity, and changes in the composition of aquatic flora and fauna (National Research Council, 2000). It also helps to fuel harmful algal blooms that can have devastating impacts on both aquatic life and human health, if affected organisms are consumed (WHOI, 2007). The impacts of these water quality reductions on recreation and fishing can be significant, particularly in estuaries. For example, a 1989 study found that a hypothetical 20 percent reduction in nitrogen and phosphorus loading in the Chesapeake Bay would result in an increase in recreation worth $34.6 million (in 1984 dollars) from increased public beach usage (National Research Council, 2000). Nutrient pollution has also contributed t o the decline of the Chesapeake crab fishery, due to its role in degrading underwater vegetation, which serves as an important habitat for post

- larval crabs (Maryland DLS, 2005).Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 143 PATHOGENS Pathogens are another important constituent of discharges from ves sels, particularly in graywater. EPA’s study of graywater discharges from cruise ships found that levels of pathogen indicator bacteria exceeded enterococci standards for marine water bathing and fecal coliform standards for harvesting shellfish 66 percent and over 80 percent of the time, respectively (EPA, 2007a). Specific pathogens of concern found in graywater include Salmonella

, E. coli , enteroviruses, hepatitis, and pathogenic protists (National Research Council, 1993). Elevated levels of these pathoge ns have increasingly resulted in beach closures in recent years, which in turn have reduced the recreational value of impacted beaches (NRDC, 2005).

Though it is difficult to determine the precise contribution of vessel discharges to infections by
these o rganisms, epidemiologists have attempted to quantify the proportion of total infections that are waterborne. For example, waterborne infection may account for as many as 60 percent of
Giardia infections and 75 percent of pathogenic E. coli infections (Nati onal Research Council, 1993). Graywater discharges are a significant source of pathogenic microorganisms within the regulated waters, and reducing them , for example through strengthening VGP graywater treatment requirements, will likely provide non- negligi ble human health benefits.

METALS Metals are a diverse group of pollutants, many of which are toxic to aquatic life and humans. Vessel discharges can contain a variety of metal constituents. For example, EPA’s study of cruise ship graywater found a total of 13 different metals in at least 10 percent of samples, with copper, nickel, and zinc detected in 100 percent of samples (EPA, 2007a). Bilge water also contains these constituents and likely others (Battelle, 2007).

While some metals, including copper, ni ckel, and zinc, are known to be essential to organism function, many others, including thallium and arsenic, are non- essential or are known to have only adverse impacts. Even essential metals can do serious damage to organism function in sufficiently eleva ted concentrations. Adverse impacts can include impaired organ function; impaired reproduction and birth defects; and, at extreme concentrations, acute mortality. Additionally, through a process known as bioaccumulation, metals may not be fully eliminated removed from blood and tissues by natural processes, and may accumulate in predator organisms further up the food chain (EPA, 2007b). This process can result in adverse health impacts for humans, who may consume contaminated fish and mollusks.

However, th e impacts of metals on any given ecosystem are difficult to predict, due to the relatively complicated circumstances by which they are available to organisms. Bioavailability of metals, and therefore impacts, varies by species of organism, as well as by cl imate and chemistry of a water body (John and Leventhal, 1996). Moreover, background levels of metals can vary substantially by location (EPA, 2007b).

OTHER POLLUTANTS WITH TOXIC EFFECTS The term “other pollutants with toxic effects,” as it applies to constituents of vessel discharges, encompasses a variety of chemical compounds known to have a broad array of adverse impacts on aquatic species and human health. For example, EPA’s study of cruise ship graywater found a total of 16 different volatile and semi-volatile organic compounds in at least 10 percent of samples, for which the most significant rates and levels of detection were phthalates, phenol, andEconomic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 144 tetrachloroethylene. Other notable pollutants with toxic effects detected included free residual
chlor ine and chlorides.

These compounds can cause a variety of adverse impacts on ecosystems, including fisheries, as
well as on human health. Phthalates are known to interfere with reproductive health and liver and kidney function in both animals and humans (Sekizawa et al., 2003; DiGangi et al., 2002). Chlorine, though toxic to humans at high concentrations, is of much greater concern to aquatic species, which can experience respiratory problems, hemorrhaging, and acute mortality even at relatively low concent rations (EPA, 2007a).

OTHER NON

- TOXIC POLLUTANTS The category “other non

- toxic pollutants” includes all non -conventional pollutants except fecal coliform (discussed in pathogens) as applied to vessel discharges also consists of multiple pollutants with disparate impacts. The most important types are pH pollution and thermal pollution, which can be found in several of the discharges that will be reduced a as a result of
VGP revisions , including graywater and bilge water

. Some vessel discharges are more acidic or basic than the receiving waters, which can have a localized effect on pH (ADEC, 2007). Though no research has been done linking vessel pollution specifically to pH impacts on aquatic ecosystems, extensive literature on the impacts of pH changes in th e contexts of aquaculture and acid rain does exist. For nearly all fish populations, pH more acidic than 5 or more basic than 10 will cause rapid mortality, and many individual species are sensitive to more moderate changes in pH (EPA, 2007e; Wurts and Durborrow, 1992).

Some vessel discharges may also be warmer or colder than the ambient temperature of the receiving water, which can affect temperature locally (Battelle, 2007). Thermal impacts of vessel discharges are generally much smaller than those from better -known sources such as dams, power plant cooling water, and runoff, due to scale. However, even small temperature changes can impact some sensitive organisms’ growth, reproduction, and even survival, which implies that some vessel discharges may have adverse impacts on aquatic ecosystems, and also fisheries (Abbaspour et al., 2005; Cairns, 1972; Govorushko, 2007).

6.2.4 BENEFITS OF REDUCING POLLUTANT DISCHARGES

Many of the nation’s busiest ports are considered to be impaired by a variety of pollutants found in vessel discharges, as is summarized in Table 6-5. The Permit is expected to reduce discharges of nutrients, metals, oil, grease, toxics, and other pollutants in waters with high levels of vessel
traffic.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 145 Table 6-5

. Impairment Status of the Top 20 Ports by Annual Vessel Calls.

Port Impairments by Pollutants Found in Vessel Discharges
Houston, TX Bacteria, Nutrients a New York City, NY Nitrogen, Oxygen Demand, b Cadmium, Mercury Port Everglades, FL Fecal Coliform, Dissolved Oxygen, Nutrients Miami, FL None listed

Los Angeles/Long Beach, CA Polycyclic Aromatic Hydrocarbons (PAHs), c Zinc, Copper, Chromium, Lead, Mercury, Cadmium, Nickel San Juan, PR Ammonia, Fecal Coliform, Dissolved Oxygen Savannah, GA Mercury, Dissolved Oxygen St. Thomas, Virgin Islands Dissolved Oxygen, Fecal Coliform, Oil and Grease, pH Seattle, WA PAHs, Fecal Coliform, pH New Orleans, LA Fecal Coliform Charleston, SC None listed Baltimore, MD Zinc, Chromium Elizabeth River, VA Phosphorus, Fecal Coliform Oakland, CA Mercury, Selenium Bayou Lafourche, LA Dissolved Oxygen, Nutrients, Total and Fecal Coliform Galveston, TX Bacteria Tacoma, WA Bis(2

- ethylhexyl) phthalate, PAHs Jacksonville, FL Coliform, Nutrients, Turbidity South Louisiana, LA Fecal Coliform

Source: Battelle (2007)
a Two of the listed pollutants are found in the areas surrounding the shipping route through the Bay of Galveston to Houston, rather than in the Port of Houston itself.
b Oxygen demand is associated with eutrophication (see the subsection on Nutrient poll ution).

c PAHs are a subset of volatile and semi

- volatile organic compounds and are associated with petroleum products

The evidence presented in the pollutant impacts section demonstrates that vessel discharges are associated with significant detrimental impacts throughout the United States. Stronger controls on specific discharges contained in 2013 VGP , as well as general housekeeping requirements of the Permit, can be expected to generate benefits through reducing the risk of damages in the future and making water quality improvements in already- impaired waters. Monetized benefits will include the prevention of fishery closures and of adverse human health impacts, as well as increased opportunities for recreation. Non

- monetized benefits will include prevention of further stresses on biodiversity and ecosystems. Though the magnitude of benefits is not calculable,
Table 6-6 presents a summary of potential benefits resulting from 2013 VGP revisions

.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 146 Table 6-6. Benefits of Reducing Pollutants Found in Vessel Discharges.

Type of Benefit ANS Nutrients Pathogens Oil &

Grease Metals Other
Toxics Other

Non

Toxics

Human Health X X X X X X Biodiversity X X X X X X Ecosystem
Function X X X X X X

Improved Fishery
Conditions X X X X X X

Increased
Recreational Opportunities X X X

X

Source: Battelle (2007)
a. Other Permit requirements that could not be firmly linked to one of these six categories of pollutants are excluded from
the tableEconomic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 147 

### REFERENCES

33 CFR 121.201. Small Business Size Regulations. Available at http://frwebgate.access.gpo.gov/cgi-bin/get-cfr.cgi. Accessed 4 May 2011.

33 CFR 151. Vessels Carrying Oil, Noxious Liquid Substances, Garbage, Municipal or Commercial Waste, and Ballast Water. Available at: http://www.access.gpo.gov/nara/cfr/waisidx_07/33cfr151_07.html. Accessed 4 May 2011.

33 CFR 155. Oil or Hazardous Material Pollution Prevention Regulations for Vessels. Available

at: http://www.access.gpo.gov/nara/cfr/waisidx_07/33cfr155_07.html. Accessed 4 May 2011.

33 CFR 159.309. Marine Sanitation Devices: Limitations on Discharge of Treated Sewage or Graywater. Available at: http://a257.g.akamaitech.net/7/257/2422/11sep20071500/edocket.access.gpo.gov/cfr_2007/ju lqtr/ 33cfr159.309.htm. Accessed 4 May 2011.

40 CFR 122. EPA Administered Permit Programs: The National Pollutant Discharge Elimination System. Available at: http://www.access.gpo.gov/nara/cfr/waisidx_07/40cfr122_07.html. Accessed December 4, 200 7.

40 CFR 110. Discharge of Oil. Available at http://www.epa.gov/oem/docs/oil/spcc/guidance/B_40CFR110.pdf . Accessed 4 May 2011.

40 CFR 122. EPA Administered Permit Programs: The National Pollutant Discharge Elimination System. Available at: http://www.access.gpo.gov/nara/cfr/waisidx_07/40cfr122_07.html. Accessed 4 May 2011.

70 CFR 168. Ballast Water Management for Vessels Entering the Great Lakes That Declare No Ballast Onboard. Available at: http://www.uscg.mil/hq/g -m/mso/docs/nobob_policy_fr.pdf.
Accessed 4 May 2011.

5 USC § 605(b). Regulatory Flexibility Act: Avoidance of Duplicative or Unnecessary Analyses

. Accessed Available at http://www.arc hives.gov/federal- register/laws/regulatory

flexibility/605.html. Accessed 4 May 2011.

33 U.S.C. §§ 1321 Oil and Hazardous Substance Liability. Available athttp://frwebgate.access.gpo.gov/cgibin/getdoc.cgi?dbname=browse_usc&docid=Cite:+33USC1321

33 USC § 2401 et seq. Organotin Anti-fouling Paint Control Act. Available at http://www.access.gpo.gov/uscode/title33/chapter37_.html. Accessed 4 May 2011.

ABS. 2010 . Ballast Water Treatment Advisory.

Abbaspour, M., A.H. Javid, P. Moghimi, and K. Kayhan. 2005. Modeling of Thermal Pollution in
Coastal Area and its Economical and Environmental Assessment. International Journal of Environmental Science and Technology . 2(1): 13 -26.

Alaska Commercial Fisheries Entry Commission . 2011. Quartile Downloadable Data. Available

at http://www.cfec.state.ak.us/fishery_statistics/earnings.htm . AccessedMay 23, 2011.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 148 Alaska Department of Environmental Conservation (ADEC). 2007. Large Commercial Pas senger Vessel Wastewater Discharge: General Permit Information Sheet. Available at: http://www.dec.state.ak.us/water/cruise_ships/pdfs/GP%20Information%20Sheet.pdf.

Albert, R., Everett, R., Lishman, J., & Smith, D. 2010 . Availability and efficacy of balla st watertreatment technology: background and issue paper. White paper published by the U.S. Environmental Protection Agency, Washington D.C.

Alfa Laval. 2010. The PureBilge system for bilge water treatment . Accessed August 10, 2010. ( 

### http://www.alfalaval.com/solution -finder/products/PureBilge/Pages/PureBilge.aspx ).

Australian Maritime Safety Authority (AMSA). 2003. Effects of Oil on Wildlife. Available at: http: //www.amsa.gov.au/Marine_Environment_Protection/Educational_resources_and_infor mation/Teachers/The_Effects_of_Oil_on_Wildlife.asp.

Battelle. 2007. Technical Support for EPA Development of a Permitting Framework to Address
the Vacatur of the NPDES Vessel E xclusion. Revised Draft, September 2007.

Bourdeau, P. and M. Treshow. 1978. Ecosystem Response to Pollution. In Butler, G.C. (ed). Principles of Ecotoxicology . John Wiley & Sons, Chichester. Available at http://globalecology.stanford.edu/DGE/SCOPE/SCOPE%2012/SCOPE%2012.html. Accessed December 21, 2007.

Cairns, John Jr. 1972. Environmental Quality and the Thermal Pollution Problem. In Farvar, M.G. and J.P. Milton. (eds.) The Careless Technology: Ecology and International Development . The World Conservation Union. Garden City, NY: Natural History Press. Available at: http://www.iucn.org/themes/ceesp/Publications/SL/CT.htm. Accessed February 14, 2008.

Cal. Pub. Res. Code. 72420-72425. California Clean Coast Act. Available at: http://www.leginfo.ca.gov/cgi -bin/calawquery?codesection=prc&codebody=&hits=20. Accessed February 14, 2008.

California State Lands Commission (CSLC) . 2010. 2010 Assessment of the Efficacy, Availability and Environmental Impacts of Ballast Water Treatment Systems for Use in California

Waters . Report produced for the California State Legislature. August 2010.

Cangelosi, A. and Mays N., 2006. Great Ships for the Great Lakes? Commercial Vessels Free of Invasive Species in the Great Lakes

- St. Lawrence Seaway System: A Scoping Report for the Great Ships Initiative. Northeast -Midwest Institute. May 2006.

Centers for Disease Control (CDC). 1993. Isolation of Vibrio Cholera 01 from Oysters – Mobile Bay, 1991, 1992. Morbidity and Mortality Weekly Report, Feb. 12, 1993, Vol. 42(05); 91-93.

Ciprian o, R.C., and O. Miller. 2002. Infectious Salmon Anemia: The Current State of Our Knowledge, proceedings of the symposium ‘International Response to Infectious Salmon Anemia: Prevention, Control, and Eradication,’ USDA/USDI/USDC, New Orleans, September 3 -4, 2002.

Congressional Research Service. 2010. The Endangered Species Act (ESA) in the 111th Congress: Conflicting Values and Difficult Choices. 7-5700. July 23, 2010.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 149 Dun & Bradstreet. 2006. D&B’s Million Dollar Databases. Available at: http://mddi.dnb.com/m ddi/. Accessed January 2006.

Cummins, Tim CDR. U.S. Coast Guard. Personal Communication. December 20, 2007.

Cruise Lines International Association (CLIA). “Cruise Industry Overview.” 2006. Accessed January 23, 2008. Available at http://www.cruising.org/pre ss/overview%202006/ind_overview.cfm.

Dawg, Inc. Personal Communication with a sales representative. January 14, 2008.

Det Norske Veritas (DNV) . 2005. Guidance for the Environmental Class Notations: Clean and Clean Design. Classification Notes No. 62.1. October 2005.

DiGangi, J., T. Schettler, M. Cobbing, and M. Rossi. 2002. Aggregate Exposures to Phthalate in
Humans. Health Care Without Harm. Available at: http://www.ecocenter.org/dust/Phthalate_hcwh.pdf. Accessed February 14, 2008.

Dun & Bradstreet. 200 6. D&B’s Million Dollar Databases. Available at: http://mddi.dnb.com/mddi/. Accessed January 2006.

Dun & Bradstreet. 2007. Industry Norms and Key Business Ratios.

Eaton, J.G., J.H. McCormick, B.E. Goodno, D.G. O’Brien, H.G. Stefany, M. Hondzo, and R.M.
Scheller. 1995. A field information- based system for estimating fish temperature tolerances.
Fisheries 20:10-18.

Etkin, D. S. 2010. Worldwide Analysis of In

- Port Vessel Operational Lubricant Discharges and Leakages

. 33rd AMOP Technical Seminar on Environmental Contamination and Response

, June 7 -9, 2010. Halifax, Nova Scotia.

Enujiugha, V.N. and L.C. Nwanna. 2004. Aquatic Oil Pollution Impact Indicators. Journal of Applied Science and Environmental Management . 8(2): 71 -75.

EnSolve. 2010. PetroLiminator OWS . Accessed August 10, 2010. (http://www.ensolve.com/userfiles/file/Products/EnSolve%20PetroLiminator%20Brochure.pd f)

Ewart, J.W., and S.E. Ford. 1993. History and Impact of MSX and Dermo diseases on Oyster Stocks in the Northeast Region. Northeast Regional Aquaculture Center: Fact Sheet No. 200.

Food and Agriculture Organization. 1976. Codex Alimentarius, Volume 9, Recommended
International Code of Practice for Fresh Fish. CAC/RCP 9-1976.

Ghidossi, R., Veyret, D., Scotto, J.L., Jalabert, T . and P. Moulin. 2009. Ferry oily wastewater treatment. Separation and Purification Technology, Vol. 64, Issue 3, 12 January 2009, p. 296-

303.

Ghosh, Sujit. Personal Communication. 16 January 2008.

Govorushko, S.M. 2007. Effect of Human Activity on Rivers. International Conference on River Basin Management. Organized by the General Directorate of State Hydraulic Works (DSI), Turkey. Available at: http://www.dsi.gov.tr/english/congress2007/.

Great Lakes Ballast Water Collaborative (GLBWC). 2010. Report fro m the Great Lakes Ballast Water Collaborative Meeting: Duluth. July 20-21, 2010 . Available at: http://www.greatlakes

-Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 150 seaway.com/en/pdf/Ballast_Collaborative_Report_and_WGReports_Duluth(Final).pdf

. Accessed on 8/03/11

Grosholz, Edwin D. 2006. Personal Communication. Department of Environmental Science and Policy, University of California, Davis.

Group of Experts on the Scientific Aspects of Marine Environmental Pollution (GESAMP). 2007. Estimates of Oil Entering the Marine Environment from Sea

- Based Activit ies. International Maritime Organization. GESAMP No. 75.

Gulf States Marine Fisheries Commission (GSMFC). 2003. Fact sheet for Perna perna . Available at: http://nis.gsmfc.org/nis_factsheet.php?toc_id=149.

Hackett, S.C., and M. D. Hansen. 2008. Cost and R evenue Characteristics of the Salmon Fisheries in California and Oregon . A Report in Fulfillment of Subcontract 8404-S-004, National Marine Fisheries Service. October 3, 2008

International Association of Drilling Contractors (IADC). 3 August 2007. Comments from
Docket ID No. OW -2007-0483

International Council of Cruise Lines (ICCL). 2001. Memorandum of Understanding. Available

at: http://www.iccl.org/resources/fdep_mou.cfm. Accessed January 21, 2008.

Jenkins, Phil. Personal Communication. 20 December 2007.

John, D.A. and J.S. Leventhal. 1996. Bioavailability of Metals. In du Bray, E.A. (ed.) Preliminary Compilation of Geoenvironmental Mineral Deposit Models . United States Geological Survey.

Karakulski, K., Kozlowski, A. and A. W. Morawski. 1995. Purification of oily wastewater by
ultrafiltration. Sep. Technol. , 5, (1995), p. 197.

King. D.M., M. Riggio., and P.T. Hagan. 2010. Preliminary Overview of Global Ballast Water Treatment Markets. Discussion Paper No. 2, Marine Environmental Resourc e Center, Ref. No. [UMCES]CBL 10 -30. June 10, 2010.

Kite -Powell, 2001. Marine Policy: Shipping and Ports. Encyclopedia of Marine Sciences . Eds. J. Steele et al.: 2768-76. Academic Press (cited in USCG, 2008).

Koss, L. 1996. Technology development for environmentally sound ships of the 21st century: an international perspective. Journal of Marine Science and Technology , Vol. 1, No. 3, June

1996.

Lee, S.H., Chung, K.C., Shin, M.C., Dong, J.I., Lee, H.S. and K.H. Auh. 2002. Preparation of ceramic membrane and application to the crossflow microfiltration of soluble waste oil.

Mater. Lett . 52 (2002), p. 266.

Lysyj, I. and E.C. Russell. 1979. Effectiveness of Centralized Bilge Water Treatment - A Field Study. Environment International . 2;177 -182.

Lloyd’s Register. 2011. Ballast Water Treatment Technology: Current Status. June 2011.

Maehara, E. 2004. Water Monitoring: Protecting the Aquatic Environment. Hawaii Legislative Reference Bureau. Available at: http://hawaii.gov/lr b/rpts04/watermon.pdf. Accessed February 14, 2008.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 151 Me. Rev. Stat. Ann. tit. 38, 423D. Graywater and Blackwater Discharges from Commercial Vessels. Available at: http://janus.state.me.us/legis/statutes/38/title38sec423 -D.html. Accessed February 14, 2008.

Mu nn, M.D., and P.A. Hamilton. 2003. “New Studies Initiated by US Geological Survey: Effects of Nutrient Enrichment on Stream Ecosystems.” U.S. Geological Survey Fact Sheet 118 -03. Available at: http://pubs.usgs.gov/fs/fs11803/pdf/fs-118-03.pdf. Accessed December 31,

2007.

NAG Marine. 2010. Accessed February 7, 2011. (http://www.nagmarine.com/products/ocm/oilcontentmonitor.html).

National Ballast Information Clearinghouse (NBIC). 2011. http://invasions.si.edu/nbi c/ Accessed September 6 -7, 2011.

National Oceanic and Atmospheric Administration (NOAA). 2008. Fisheries of the United

States: 2007 . National Marine Fisheries Service, Office of Science and Technology. Silver Spring, Maryland, July 2006. Available at: http://www.st.nmfs.noaa.gov/st1/fus/fus07/01_intro2007.pdf

National Oceanic and Atmospheric Administration (NOAA). 2010. Fisheries of the United States,

2009 . Silver Spring, MD: Nationa l Marine Fisheries Service (NMFS). http://www.st.nmfs.noaa.gov/st1/fus/fus09/highlight2009.pdf

National Oceanic and Atmospheric Administration (NOAA). 2011a. Annual Commercial Landing Statistics: 2009 All States by State . Silver Spring, MD: National Marine Fisheries Service (NMFS) . Updated 6 August 2007. Accessed 4 May 2011. http://www.st.nmfs.noaa.gov/st1/commercial/landings/annual_landings.html

National Oceanic and Atmospheric Administration (NOAA). 2011b. Interim Report for Fishing Year 2010 on the Performance of the Northeast Multispecies (Groundfish) Fishery (May 2010 – January 2011)

. Northeast Fisheries Science Center Reference Document 11 -07

National Oceanic and Atmospheric Administration (NOAA). 2005. Assessing Environmental
Harm: How Toxic is Oil? Available at: http://response.restoration.noaa.gov/topic_subtopic_entry.php?RECORD_KEY%28entry_sub topic_topic%29=entry_id,subtopic_id,topic_id&entry_id(entry_subtopic_topic)=243&subtop ic_id(entry_subtopic_topic)=13&topic_id(entry_subtopic_topic)=1. Accessed December 31,

2007.

National Research Council. 1993. Managing Wastewater in Coastal Urban Areas. Water Science and Technology Board.

National R esearch Council. 2000. Clean Coastal Waters: Understanding and Reducing the Effects of Nutrient Pollution. Ocean Studies Board and Water Science and Technology Board.

Natural Resources Defense Council (NRDC). 2005. Contamination Forces More Beach Closings
Nationwide. Press Release. Available at: http://www.nrdc.org/media/pressreleases/050728.asp.

New Logic Research. 2010. Using Vibrating Membranes to Treat Oily Wastewater from a Waste Hauling Facility. http://www.vsep.com/pdf/OilyWastewater.pdf.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 152 Office of Technology Assessment (OTA) (U.S. Congress). 1993. Harmful Non -Indigenous Species in the United States . OTA Publication OTA-F-565. U.S. Government Printing Office, Washington DC.

Peters, David. Personal Communication. January 14, 2008.

Rahel, F.J., C.J. Keleher and J.L. Anderson. 1996. Potential habitat loss and population fragmentation for cols water fish in the North Platte River drainage of the Rocky Mountains: response to climate warming. Limnol. Oceanogr . 41:1116-1123.

Reference for Business. 2007a. “SIC 0912-Finfish.” Encyclopedia of American Industries. Accessed January 24, 2008. Available at http://www.referenceforbusiness.com/industries/Agriculture- Forestry

- Fishing/Finfish.html.

Reference for Business. 2007b. “SIC 0913- Shellfish.” Encyclopedia of American Industries. Accessed January 24, 2008. Available at http://www.referenceforbusiness.com/industries/Agriculture- Forestry

- Fishing/Shellfish.html.

Reference for Business. 2007c. “SIC 4482- Ferries.” Encyclopedia of American Industries. Accessed January 23, 2008. Available athttp://www.referenceforbusiness.com/industries/Transportation-CommunicationsUtilities/Ferries.html.

Reference for Business. 2007d. “SIC 4489- Water Transportation of Passengers, not Elsewhere
Classified.” Encyclopedia of American Industries . Accessed January 23, 2008. Available athttp://www.referenceforbusiness.com/industries/Transportation-CommunicationsUtilities/Water

- Transportation

- Passengers

- Elsewhere

- Classified.html

Reference for Busine ss. 2007e. “SIC 4491- Marine Cargo Handling.” Encyclopedia of American Industries. Accessed January 23, 2008. Available athttp://www.referenceforbusiness.com/industries/Transportation-CommunicationsUtilities/Marine

- Cargo -Handling.html.

Reference for Busin ess. 2007f. “SIC 4499- Water Transportation Services, not Elsewhere Classified.” Encyclopedia of American Industries. Accessed January 23, 2008. Available athttp://www.referenceforbusiness.com/industries/Transportation-CommunicationsUtilities/Water

- Transp ortation

- Services

- Elsewhere

- Classified.html.

ReferenceUSA. 2006. Business Database. Available at: www.referenceusa.com. Accessed
Jan./Feb. 2006.

Reid, D.F., T.H. Johengen, H. MacIsaac, F. Dobbs, M. Doblin, L. Drake, G. Ruiz and P. Jenkins. 2007. Identifyin g and Establishing Options for Best Management Practices for NOBOB Vessels. NOAA Great Lakes Environmental Research Laboratory.

Reynolds, K.A., I.T. Knight, C.S. Wells, I.L. Pepper, and C.P. Gerba. 1999. Detection of Human Pathogenic Protozoa and Viruses in Ballast Water Using Conventional and Molecular
Methods. Presented at the General Meeting of the American Society for Microbiology, Chicago, IL, Abstract Q-318, p. 594.

Risk Management Association (RMA) eStatement Studies: Annual Statement Studies, Financ ial
Ratios and Benchmarks. 2007.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 153 Rockwell, Jr., H.W. 2003. “Summary of a Survey of the Literature on the Economic Impact of Aquatic Weeds.” Report for the Aquatic Ecosystem Restoration Foundation. August. http://www.aquatics.org/pubs/economics.htm.

Ruffe T ask Force (RTF). 1992. Ruffe in the Great Lakes: A Threat to North American Fisheries. Great Lakes Fishery Commission. Ann Arbor, MI.

Ruiz, G.M., A.W. Miller, K. Lion, B. Steves, A. Arnwine, E. Collinetti, and E. Wells. 2001. First Biennial Report of the National Ballast Information Clearinghouse . Smithsonian Environmental Research Center. Edgewater, Maryland.

Ruiz, G.M., and D.F. Reid. 2007. Current State of Understanding about the Effectiveness of Ballast Water Exchange (BWE) in Reducing Aquatic Nonindigenous Species (ANS) Introductions to the Great Lakes Basin and Chesapeake Bay, USA: Synthesis and Analysis of Existing Information. National Oceanic and Atmospheric Administration.

St. Lawrence Seaway Management Corporation and St. Lawrence Seaway Develop ment Corporation. 2007. The St. Lawrence Seaway 2006 Traffic Report . Available at http://www.greatlakes -seaway.com/en/pdf/traffic_report_2006.pdf. Accessed December 17,

2007.

Seacor International. Personal Communication. January 7, 2008.

Scheffey, J.L., an d C.P. Hanauska. 2002. Status Report on Environmental Concerns Relating to Aqueous Film Forming Foam (AFFF). Report to the Federal Aviation Administration Technology Transfer Conference. Available at: http://www.airporttech.tc.faa.gov/naptf/att07/2002%20TRACK%20S.pdf/S15.pdf.

Sekizawa, J., S. Dobson, and R.J. Touch III. 2003. Diethyl Phthalate. World Health Organization,
Concise International Chemical Assessment Document 52.

Steinberg, E.B., et al. 2001. Cholera in the United States, 1995- 2000: Trends at the End of the Twentieth Century

. Journal of Infectious Diseases, 2001, Vol. 184, pp.799-802.

Sytsma, M.D., J.R. Cordell, J.W. Chapman, and R.C. Draheim. 2004. Lower Columbia River Aquatic Nonindigenous Species Survey 2001-2004: Final Technical Report. Pre pared for the
U.S. Coast Guard and U.S. Fish and Wildlife Service. Available at: http://www.clr.pdx.edu/docs/LCRANSFinalReport.pdf. Accessed December 31, 2007.

Toledo, D.P. 2001. Sea Lamprey (Petromyzon marinus). Introduced Species Summary Project,
Columb ia University. Available at: http://www.columbia.edu/itc/cerc/danoff

burg/invasion_bio/inv_spp_summ/petromyzon_marinus.html.

Toonen, R. 2005. Reproduction and developmental characteristics of an alien soft coral (Carijoa riisei) in Hawaii. Available at:
h ttp://www.hawaii.edu/ssri/hcri/research/projects/threats/inv_spec

- invert -bio-01.shtml.

Transportation Institute. “Industry Profile.” Accessed January 23, 2008. Available at http://www.trans

- inst.org/1.html.

U.S. Army Corps of Engineers (USACE). 2009. Waterborne Commerce of the United States, 2009, Part 5 National Summaries. Institute for Water Resources. 2009. Available at http://www.ndc.iwr.usace.army.mil//wcsc/pdf/wcusnatl09.pdfEconomic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 154 U.S. Bureau of Economic Analysis (US BEA). 2011a. Table 2.1. Personal Income and Its Disposition. Accessed 10 May 2011. Updated 28 April 2011. <http://www.bea.gov/national/nipaweb/TableView.asp?SelectedTable=58&Freq=Qtr&FirstY

ear=2009&LastYear=2011>

U.S. Bureau of Economic Analysis (US BEA). 2011b. GDP and the National Income and Product Account (NIPA) Historical Tables. Available electronically at: http://bea.gov/national/index.htm#gdp

U.S. Bureau of Labor Statistics (U.S. BLS). 2011. Employment Cost Index: Historical Listing

Current

- dollar: March 2001 -March 2011. Available at:
ft p://ftp.bls.gov/pub/suppl/ECI.ECHISTRYNAICS.TXTAvailable at: ftp://ftp.bls.gov/pub/suppl/ECI.ECHISTRYNAICS.TXT

U.S. Census Bureau. 2002a. 2002 County Business Patterns for the United States. Available at http://www.census.gov/epcd/cbp/view/us02.txt.

U.S. Census Bureau. 2002b. 2002 Economic Census. Available at http://www.census.gov/econ/census02/.

U.S. Census Bureau. 2007a. 2007 Economic Census. Available at http://www.census.gov/econ/census07/

U.S. Census Bureau 2007b. County Business Patterns for the Uni ted States. Available at http://www.census.gov/econ/cbp/.

U.S. Census Bureau, 2010. Nonemployer Statistics for 2008. Available at http://www.census.gov/econ/nonemployer/ (accessed May 24, 2011).

U.S. Coast Guard (USCG). 2008. Standards for Living Organisms in Ships' Ballast Water Discharged in U.S. Waters: Notice of Proposed Rulemaking. Preliminary Regulatory Analysis and Initial Regulatory Flexibility Analysis, USCG -2001- 10486, June 2008.

U.S. Coast Guard (USCG) . 2009. Marine Information for Safety and Law Enforcement (MISLE)

. Available at http://www.uscg.mil/hq/cg5/msl/

U.S. Commission on Ocean Policy. 2004. An Ocean Blue Print for the 21st Century, Chapter 13: Supporting Marine Commerce and Transportation , Final Report of the U.S. Commission on
Ocean Pol icy
– Pre -Publication Copy. Washington, D.C., 2004 ISBN#0-9769462-0-X.
Available at http://www.oceancommission.gov/documents/prepub_report/chapter13.pdf

U.S. Customs and Border Protection. 2010. 2008 U.S. Customs Vessels Entrances and Clearances. USACE, Navigation Data Center. Available at: http://www.ndc.iwr.usace.army.mil/data/dataclen.htm..

U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of Commerce, U.S. Census Bureau (USDOI). 2007. 2006 National Survey of Fishing, Hunting, and WildlifeAssociated Recreation

. U.S. Department of Transportation, Research and Innovative Technology Administration, Bureau of Transportation St atistics. 2008. Maritime Data Working Group, Merchant Vessels of the
United States . Available at:Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 155 http://www.bts.gov/programs/maritime_data_working_group/uscg/merchant_vessels_of_the_ united_states/html/front_matter.html. Accessed January 18, 2008.

U.S. Environmental Protection Agency and U.S. Department of Defense (EPA and DOD). 1999. Phase I Uniform National Discharge Standards for Vessels of the Armed Forces: Technical Development Document. Available at: http://www.epa.gov/waterscience/rules/UNDS/vessels. pdf.

U.S. Environmental Protection Agency and United States Department of Defense (EPA and DOD). 2007. Uniform National Discharge Standards Batch Rulemaking Process. Available at: http://www.epa.gov/owow/oceans/regulatory/unds/batchruleprocess.html. Acces sed December 20, 2007.

U.S. Environmental Protection Agency (EPA). 2006. Information Collection Request: Applications for National Pollutant Discharge Elimination System Discharge Permits and the Sewage Sludge Management Permits. June 2006.

U.S. Environmental Protection Agency (EPA). 2006a. Multi- Sector General Permit. September

2006. Document ID EPA- HQ

- OW -2005-0007-0011. Available at : http://www.regulations.gov/search/index.jsp . Accessed on Octob er 29, 2008.U.S. Environmental Protection Agency (EPA). 2007a. Draft Cruise Ship Discharge Assessment Report. Available at: http://www.epa.gov/owow/oceans/cruise_ships/disch_assess_draft.html. Accessed December 21, 2007.

U.S. Environmental Protection Agen cy (EPA). 2007b. Framework for Metals Risk Assessment. Available at: http://www.epa.gov/osa/metalsframework/. Accessed December 21, 2007.

U.S. Environmental Protection Agency (EPA). 2007c. National Water Quality Inventory: Report to Congress, 2002 Reporting Cycle. Available at: http://www.epa.gov/305b/. Accessed December 21, 2007.

U.S. Environmental Protection Agency (EPA). 2007d. Basic Information on PFOA. Available at: http://www.epa.gov/oppt/pfoa/pubs/pfoainfo.htm.

U.S. Environmental Protection Agency (EPA). 2007e. Effects of Acid Rain – Surface Waters and Aquatic Animals. Available at: http://www.epa.gov/acidrain/effects/surface_water.html.

U.S. Environmental Protection Agency (EPA). 2008. Economic and Benefits Analysis of the
Final Vessel General Per mit . Washington DC. December 2008.

U.S. Environmental Protection Agency (U.S. EPA). 2010a. Vessel General Permit f or Discharges Incidental to the Normal Operation o f Vessels ( VGP ), Version November 2010.

U.S. Environmental Protection Agency (U.S. EPA). 2010b. Report to Congress: Study of Discharges Incidental to the Normal Operation of Commercial Fishing Vessels and Other

Non

- Recreational Vessels Less than 79 Feet. Office of Water, Washington, D.C. August
2010. EPA 833-R-10-005. Available at http://www.epa.gov/npdes/pubs/vesselsreporttocongress_all_final.pdf

U.S. Environmental Protection Agency Science Advisory Board (US EPA SAB). 2011. Efficacy of Ballast Water Treatment Systems . Report published by the U. S. Environmental Protection Agency Science Advisory Board. Ecological Processes and Effects Committee

.Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 156 U.S. Fish and Wildlife Service (USFWS). 2005. Federal and State Endangered and Threatened Species Expenditures: Fiscal Year 2004.

U.S. Geological Survey (USGS). 1999. The Quality of Our Nation’s Waters: Nutrients and Pesticides. USGS Circular 1225. Available at: http://pubs.usgs.gov/circ/circ1225/. Accessed December 21, 2007.

U.S. Maritime Administration (MARAD). 2006. U.S. Domestic Ocean Trades 2004. Ava ilable at http://www.marad.dot.gov/marad_statistics. Accessed December 17, 2007.

U.S. Small Business Administration. 2007a. U.S. Dynamic data, by births, deaths, growth, and decline, 1998 -2006. Firm Size Data. Available at: http://archive.sba.gov/advo/research/dyn_us_n4.txt

U.S. Small Business Administration. 2007b. Statistics of Small Businesses, Classified by Employment Size of the Firm, 2003-2007. Available at: http://archive.sba.gov/advo/research/us03_07n02.txt

U.S. Small Business Administration. 2010. Tables of Small Business Size Standards Matched to North American Industry Classification System Codes. Available at http://www.sba.gov/sites/default/files/Size_Standards_Table.pdf

Washington Department of Ecology, 2007. Amendment Number 3 of the Memorandum of Understanding: Cruise Ship Operations in Washington State. Available at: http://www.ecy.wa.gov/programs/wq/wastewater/cruise_mou/MOU%203rd%20Amendment %205-25-07%20final.pdf. Accessed February 14, 2008.

Wisconsin Department of Natural Resources (WDNR ). 2010. Wisconsin Ballast Water Treatment Feasibility Determination . Prepared by Wisconsin Department of Natural Resources. Available at: http://www.greatlakes

seaway.com/en/pdf/WI_DNR_2010_BW_Feasibility_Report_12-21-10.pdf. Accessed on
9/6/2011

Woods Ho le Oceanographic Institute (WHOI). 2007. Harmful Algae: What are Harmful Algal Blooms (HABs)? Available at http://www.whoi.edu/redtide/page.do?pid=9257.

Wurts, W.A. and R.M. Durborrow. 1992. Interactions of pH, Carbon Dioxide, Alkalinity and Hardness in Fish Ponds. Southern Regional Aquaculture Center Publication No. 464.Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 157 APPENDIX A – BILGE WATER TREATMENT SYSTEM COST ESTIMATESEconomic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 158 Table A

- 1. Bilge water Treatment System Cost Estimates - Low Flow (1 m 3 /day)

Bilge wate r Treatment System System A System B System D System E b System F System G System H f System I System J
Purchase cost $13,350 $2,024/yr a $21,270 $95,000 $38,400 $100,380 $16,300 g $5,000 j $10,000 j
Replacement media & parts $2,090/yr (see footnote a) $1,780/yr $143/yr c $1,550/yr d $1,095/yr e (see footnote h) (see footnote h) $1,814/yr k

Labor $5,840

- 9,125/yr $7,990/yr $5,840

- 9,125/yr $5,840

- 9,125/yr $5,840

- 9,125/yr $5,840

- 9,125/yr $5,840

- 9,125/yr $5,840

- 9,125/yr $5,840

- 9,125/yr

Residual Disposal l $127

- 253/yr $31

- 63/yr $4,820

- 9,640/yr $23

- 46/yr $127

- 253/yr $130

- 260/yr (see footnote i) (see footnote i) (see footnote i)

Total annual cost $9,320

- 12,730/yr $10,050

- 10,080/yr $14,440

- 22,550/yr $14,970

- 18,280/yr $11,140

- 14,550/yr $16,540

- 19,960/yr $7,379

- 10,664/yr $6,312

- 9,597/yr $8,598

- 11,883/yr Cost per 1,000 gallons treated $97

- 132 $104

- 105 $150

- 234 $155

- 190 $116

- 151 $172

- 207 $77

- 111 $66

- 100 $89

- 123

Note: Total annual costs were amortized over 20 years using a 7% discount rate.
a Cost of operating equipment includes capital outlay, consumables (nutrient and pH chemicals, starter/booster microbial cultures, and chemical analysis supplies), spare parts, electrical usage, labor, disposal quantities
and cost

. b This system does not use chemic als or absorption filters to clean the water from oil and particles, only Gravitational

- force, then uses a filter to polish to below 5ppm

. The cost of the separator is the same for the
2.5 m3/hr and 5 m3/hr systems

. The cost of the filter is $925 and is replaced, at most, every 100 days.

c Replacement media and parts costs include replacement of O

- ring seals and gaskets every 83 days of operation, and replacement of bearings every 333 days

. The operating cost of this system is only the service required for the centrifugal separator

-- every 2,000 running hours an Intermediate Service is made and every 8,000 a Major Service is made.
d Maintenance only includes replacing the filters

. Replacement costs have three components: 1. Coalescer Element filter, replace d annually on new ships (bi

- annually on older ships); 2. Advance Granular Media filter, usually replaced annually; 3. Gasket set, also replaced annually.
e Operating costs includes replacement parts, chemicals, and media

. Filter media and Granular Activated Carbon (GAC) are steam regenerated and require annual replacement, at most.
f This system comes equipped with a fluorescent detection OCM.
g This system treats 2.4 m3/day, which is the lowest flow rate treated by this manufacturer's OWS systems.

h No replacement media and parts costs were provided

. i Abt Associates was unable to estimate the residual disposal cost.
j This system treats 10.9 m3/day, which is the lowest flow rate treated by manufacturer's OWS systems.
k Includes replacement cost and labor of Stage II filter every 14 months

. Filter costs $2,000 and requires two hours of labor to replace.

l Abt Associates was unable to verify estimates of the residual disposal cost reported in GLEC (2011).Economic and Benefits Ana lysis of the Proposed 2013 Vessel General Permit

November 30, 2011 159 Table A -2 Bilge water Treatment System Cost Estimates - High Flow (1 m 3 /hr)

Bilge Water Treatment System System A System B System D System E b System F System G System H f System I System J
Purchase cost $13,350 $7,025/yr a $21,270 $95,000 $38,400 $100,380 $19,500 $14,000 i $22,000 i
Replacement media & parts $27,190/yr (see footnote a) $2,200/yr $3,420/yr c $6,166/yr d $26,280/yr e (see footnote g) (see footnote g) $1,814/yr j

Labor $23,360

- 36,500/yr $49,400/yr $23,360

- 36,500/yr $23,360

- 36,500/yr $23,360

- 36,500/yr $23,360

- 36,500/yr $23,360

- 36,500/yr $23,360

- 36,500/yr $23,360

- 36,500/yr

Residual Disposal l $1,640

- 3,270/yr $750

- 1,500/yr $115,630

- 231,260/yr $550

- 1,100/yr $1,140

- 2,270/yr $860

- 1,710/yr (see footnote h) (see footnote h) (see footnote h)

Total annual cost $53,450

- 68,220/yr $57,190

- 57,940/yr $143,200

- 271,970/yr $36,300

- 49,980/yr $34,290

- 48,5600/yr $59,970

- 73,970/yr $25,201

- 38,341/yr $24,682

- 37,822/yr $27,251

- 40,391/yr Cost per 1,000 gallons treated $23

- 30 $25 $62

- 118 $16

- 22 $15

- 21 $26

- 32 $11

- 17 $11

- 16 $12

- 17

Note: Total annual costs were amortized over 20 years using a 7% discount rate.
a Cost of operating equipment includes capital outlay, consumables (nutrient and pH chemicals, starter/booster microbial cultures, and chemical analysis supplies), spare parts, electrical usage, labor, disposal quantities
and cost

. b This system does not use chemicals or absorption filters to clean the water from oil and particles, only Gravitational

- force, then uses a filter to polish to below 5ppm

. The cost is the same for the the 2.5 m 3 /hr and 5

m 3 /hr systems.
c Replacement media and parts costs include replacement of O

- ring seals and gaskets every 83 days of operation, and replacement of bearings every 333 days

. The operating cost of this system is only the service required for the centrifugal separator

-- every 2,000 running hours an Intermediate Service is made and every 8,000 a Major Service is made.
d Maintenance only includes replacing the filters

. Replacement costs have three components: 1. Coalescer Element filter, replaced annually on new ships (bi

- annually on older ships); 2. Advance Granular Media filter, usually replaced annually; 3. Gasket set, also replaced annually.
e Operating costs includes replacement parts, chemicals, and media

. Fil ter media and Granular Activated Carbon (GAC) are steam regenerated and require annual replacement, at most.
f This system comes equipped with a fluorescent detection OCM.
g No replacement media and parts costs were provided

. h Unable to verify the residual disposal cost.
i This system treats 5.68 m 3 /hr, which is the flow rate closest to 1m 3 /hr that this company's OWS systems treat.
j Includes replacement cost and labor of Stage II filter every 14 months

. Filter costs $2,000 and requires two hours of labor to replace.
l Abt Associates was unable to verify estimates of the residual disposal cost reported in GLEC (2011).Economic and Benefits Analysis of the Proposed 2013 Vessel General Permit

November 30, 2011 160