United States

Environmental 

Protection 

Agency

Benefits Analysis for the Final 

Section 316(b) Existing Facilities 

Rule

EPA 821-R-14-005

May 2014
Benefits Analysis for the Final 316(b) Existing Facilities Rule Table of Contents

May 2014 i

Table of Contents

1 Introduction ...................................................................................................................................1-1

1.1 Summary of the Final Rule and Other Options Considered............................................................1-2

1.2 Study Design ...................................................................................................................................1-3

1.2.1 Coastal Regions.....................................................................................................................1-4

1.2.2 Great Lakes Region...............................................................................................................1-5

1.2.3 Inland Region........................................................................................................................1-5

1.3 Organization of the Document ........................................................................................................1-5

2 Baseline Impacts............................................................................................................................2-1

2.1 Introduction .....................................................................................................................................2-1

2.2 Major Anthropogenic Stressors in Aquatic Ecosystems .................................................................2-1

2.2.1 Habitat Loss..........................................................................................................................2-2

2.2.2 Water Quality........................................................................................................................2-3

2.2.3 Overharvesting......................................................................................................................2-7

2.2.4 Invasive Species....................................................................................................................2-8

2.3 CWIS Impacts on Aquatic Ecosystems...........................................................................................2-8

2.3.1 Losses of Fish from IM&E ...................................................................................................2-9

2.3.2 IM&E Effects on T&E species ...........................................................................................2-12

2.3.3 Thermal Effects...................................................................................................................2-12

2.3.4 Chemical Effects.................................................................................................................2-13

2.3.5 Effects of Flow Alteration...................................................................................................2-15

2.4 Community-level or Indirect Effects of CWIS..............................................................................2-15

2.4.1 Altered Community Structure and Patchy Distribution of Species.....................................2-16

2.4.2 Altered Food Webs .............................................................................................................2-16

2.4.3 Reduced Taxa and Genetic Diversity..................................................................................2-17

2.4.4 Nutrient Cycling Effects .....................................................................................................2-17

2.4.5 Reduced Ecological Resistance...........................................................................................2-17

2.5 Cumulative Impacts of Multiple Facilities....................................................................................2-17

2.5.1 Clustering of Facilities and CWIS on Major Rivers...........................................................2-18

2.5.2 Implications of Clustered Facilities for Cumulative Impacts..............................................2-19

2.6 Case Studies of Facility IM&E Impacts........................................................................................2-19

2.6.1 Bay Shore Power Station ....................................................................................................2-20

2.6.2 Indian Point Nuclear Power Plant.......................................................................................2-21

2.6.3 Indian River Power Plant ....................................................................................................2-22

2.7 Conclusions...................................................................................................................................2-23
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3 Assessment of Impingement and Entrainment Mortality..........................................................3-1

3.1 Introduction .....................................................................................................................................3-1

3.2 Methods...........................................................................................................................................3-1

3.2.1 Objectives of IM&E Analysis...............................................................................................3-1

3.2.2 IM&E Loss Metrics ..............................................................................................................3-1

3.2.3 Valuation Approach ..............................................................................................................3-2

3.2.4 Rationale for EPA’s Approach to Valuation of IM&E.........................................................3-3

3.2.5 Extrapolation of IM&E to Develop Regional Estimates.......................................................3-5

3.3 IM&E by Region .............................................................................................................................3-6

3.3.1 California Region..................................................................................................................3-6

3.3.2 North Atlantic Region...........................................................................................................3-7

3.3.3 Mid-Atlantic Region .............................................................................................................3-8

3.3.4 South Atlantic Region...........................................................................................................3-9

3.3.5 Gulf of Mexico Region .......................................................................................................3-10

3.3.6 Great Lakes Region.............................................................................................................3-12

3.3.7 Inland Region......................................................................................................................3-13

3.3.8 National Estimates ..............................................................................................................3-14

3.4 Limitations and Uncertainties........................................................................................................3-15

3.4.1 Data Limitation and Uncertainty.........................................................................................3-15

3.4.2 Structural Uncertainty .........................................................................................................3-16

3.4.3 Parameter Uncertainty.........................................................................................................3-17

3.4.4 Engineering Uncertainty .....................................................................................................3-18

4 Economic Benefit Categories........................................................................................................4-1

4.1 Economic Benefit Categories of the Rule .......................................................................................4-1

4.2 Market and Nonmarket Direct and Indirect Use Benefits from Reduced IM&E ............................4-4

4.2.1 Commercial Fisheries ...........................................................................................................4-5

4.2.2 Recreational Fisheries...........................................................................................................4-5

4.2.3 Subsistence Fishers...............................................................................................................4-6

4.2.4 Benefits from Improved Protection to T&E Species ............................................................4-6

4.3 Nonuse Benefits from Reduced IM&E ...........................................................................................4-7

5 Impacts and Benefits on Threatened and Endangered Species.................................................5-1

5.1 Introduction .....................................................................................................................................5-1

5.2 T&E Species Affected by CWIS.....................................................................................................5-2

5.2.1 T&E Species Identification and Data Collection ..................................................................5-2

5.2.2 Number of T&E Species Affected per Facility.....................................................................5-3

5.2.3 Number of Facilities Affecting Individual T&E Species......................................................5-6

5.2.4 Summary of Overlap between Cooling Water Intake Structures and T&E Species.............5-8
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5.2.5 Summary of Overlap between Cooling Water Intake Structures and Critical Habitat..........5-8

5.2.6 Effect of the Final Rule on Facilities Overlapping T&E Species Habitat.............................5-9

5.2.7 Species with Documented IM&E..........................................................................................5-9

5.3 Societal Values for Preservation of T&E Species Affected by IM&E..........................................5-12

5.4 Assessment of Benefits to T&E Species .......................................................................................5-13

5.4.1 Economic Valuation Methods.............................................................................................5-13

5.4.2 Case Studies........................................................................................................................5-13

5.4.3 Limitation and Uncertainties...............................................................................................5-20

6 Commercial Fishing Benefits........................................................................................................6-1

6.1 Methodology....................................................................................................................................6-1

6.1.1 Estimating Consumer and Producer Surplus.........................................................................6-1

6.2 Benefits Estimates for Regional Commercial Fishing...................................................................6-10

6.2.1 California Region................................................................................................................6-12

6.2.2 North Atlantic Region.........................................................................................................6-13

6.2.3 Mid-Atlantic Region ...........................................................................................................6-14

6.2.4 South Atlantic Region.........................................................................................................6-15

6.2.5 Gulf of Mexico Region .......................................................................................................6-16

6.2.6 Great Lakes Region.............................................................................................................6-16

6.2.7 National Estimates ..............................................................................................................6-17

6.3 Limitations and Uncertainties........................................................................................................6-18

7 Recreational Fishing Benefits.......................................................................................................7-1

7.1 Introduction .....................................................................................................................................7-1

7.2 Methodology....................................................................................................................................7-1

7.2.1 Estimating Marginal Value per Fish .....................................................................................7-2

7.2.2 Calculating Recreational Fishing Benefits............................................................................7-7

7.2.3 Sensitivity Analysis Based on the Krinsky and Robb (1986) Approach ..............................7-7

7.3 Benefits Estimates for Recreational Fishing by Region ..................................................................7-8

7.3.1 California Region..................................................................................................................7-8

7.3.2 North Atlantic Region...........................................................................................................7-9

7.3.3 Mid-Atlantic Region ...........................................................................................................7-10

7.3.4 South Atlantic Region.........................................................................................................7-11

7.3.5 Gulf of Mexico Region .......................................................................................................7-12

7.3.6 Great Lakes Region.............................................................................................................7-13

7.3.7 Inland Region......................................................................................................................7-14

7.3.8 National Estimates ..............................................................................................................7-15

7.4 Limitations and Uncertainties........................................................................................................7-16

8 Nonuse Benefit Transfer Approach .............................................................................................8-1
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8.1 Introduction .....................................................................................................................................8-1

8.2 Public Policy Significance of Ecological Improvements from the Final Rule ................................8-2

8.2.1 Effects on Depleted Fish Populations...................................................................................8-2

8.2.2 Marine Protected Areas.........................................................................................................8-3

8.2.3 Restoration of Freshwater Ecosystems .................................................................................8-5

8.2.4 Summary of Evidence for Nonuse Values of Ecosystems Affected by CWIS .....................8-6

8.3 Benefit Transfer for Nonuse Values in the North Atlantic and Mid-Atlantic Regions...................8-6

8.3.1 Description of the Benefit Transfer Study and BSPV Methods............................................8-7

8.3.2 Benefit Transfer Methodology..............................................................................................8-9

8.4 Benefit Transfer Results for the Final Rule and Options Considered ...........................................8-16

8.5 Habitat-Based Methodology for Estimating Nonuse Values for Fish Production Lost to IM&E.8-17

8.6 Limitations and Uncertainties........................................................................................................8-19

8.6.1 Scale of Fishery Improvements...........................................................................................8-19

8.6.2 Scale and Characteristics of the Affected Population .........................................................8-19

8.6.3 Fish Population Size, Type and Improvement from the Elimination of IM&E..................8-20

9 Assessment of Social Cost of Carbon...........................................................................................9-1

9.1 Analysis Approach and Data Inputs................................................................................................9-1

9.1.1 Electric Generators................................................................................................................9-1

9.1.2 Manufacturers.......................................................................................................................9-6

9.2 Key Findings for Regulatory Options .............................................................................................9-7

9.2.1 Electric Generators................................................................................................................9-7

9.2.2 Manufacturers.......................................................................................................................9-8

10 Summary of Monetized Benefits for Existing Units.................................................................10-1

10.1 Introduction ...................................................................................................................................10-1

10.2 Summary of Methods and Limitations..........................................................................................10-1

10.3 Summary of Baseline Losses and Monetized Benefits for the Final Rule and Options Considered 

for Existing Units ..........................................................................................................................10-1

11 Stated Preference Survey............................................................................................................11-1

11.1 Introduction ...................................................................................................................................11-1

11.2 Survey Design ...............................................................................................................................11-2

11.2.1Survey Format.....................................................................................................................11-2

11.2.2Experimental Design...........................................................................................................11-4

11.2.3Pre-Tests..............................................................................................................................11-6

11.3 Sampling Frame.............................................................................................................................11-7

11.4 Mail Survey Responses .................................................................................................................11-9

11.5 Non-Response Study ...................................................................................................................11-12
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11.5.1Non-Response Sample ......................................................................................................11-13

11.5.2Statistical Testing of Mail Survey and Non-Response Data .............................................11-14

11.6 Random Utility Model.................................................................................................................11-17

11.6.1Model Specification ..........................................................................................................11-18

11.6.2Model Estimation..............................................................................................................11-19

11.6.3Approach for Estimating Weights.....................................................................................11-20

11.6.4Model Results ...................................................................................................................11-21

11.6.5Validity Tests....................................................................................................................11-24

11.7 Estimation of Implicit Prices and WTP.......................................................................................11-26

11.8 Method for Estimating Regional Benefits...................................................................................11-29

11.9 Results for the Final Rule and Regulatory Options Considered..................................................11-30

11.10 Uncertainties................................................................................................................................11-32

12 Analysis of New Units at Existing Facilities..............................................................................12-1

12.1 Introduction ...................................................................................................................................12-1

12.2 Analysis Approach and Benefits for IM&E Reductions at New Units .........................................12-1

12.2.1Flow Reductions at New Units ...........................................................................................12-1

12.2.2IM&E Reductions and Associated Benefits per MGD .......................................................12-2

12.2.3IM&E Reductions and Associated Benefits under the final Rule and Options Considered for 

New Units ...........................................................................................................................12-3

12.2.4Limitations and Uncertainties for the Analysis of IM&E Reductions and Associated Benefits 

for New Units......................................................................................................................12-6

12.3 Analysis of Social Cost of Carbon for New Units.........................................................................12-7

12.3.1Analysis Approach and Data Inputs....................................................................................12-7

12.3.2Key Findings for Regulatory Options.................................................................................12-8

12.4 Monetized Benefits for New Units................................................................................................12-9

13 Summary of National IM&E Reductions and Benefits for Existing and New Units.............13-1

13.1 Introduction ...................................................................................................................................13-1

13.2 Summary of Limitations and Uncertainties...................................................................................13-1

13.3 Summary of Baseline IM&E Losses and IM&E Reductions........................................................13-2

13.4 Summary of National Monetized Benefits....................................................................................13-7

13.5 Results based on the SP Survey...................................................................................................13-11

13.6 Break-Even Analysis...................................................................................................................13-11

14 References ....................................................................................................................................14-1

Appendix A: Extrapolation Methods....................................................................................................A-1

A.1 Introduction ....................................................................................................................................A-1
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A.2 Manufacturing Facilities.................................................................................................................A-1

A.2.1 Traditional Manufacturers (MN Facilities)..........................................................................A-2

A.2.2 Non-Utility Manufacturers (MU Facilities).........................................................................A-5

A.3 Electric Power Generating Facilities..............................................................................................A-6

A.3.1 Defining the Strata and Control Variables...........................................................................A-7

A.3.2 Comparison of Results of the Detailed Questionnaire and Post-Stratified Weighting 

Schemes ...............................................................................................................................A-8

A.4 Adjustment for State Regulations of CWIS ...................................................................................A-9

Appendix B: Consideration of Potential Effects due to Thermal Discharges ...................................B-1

B.1 Introduction ....................................................................................................................................B-1

B.2 General Effects of Thermal Discharges on Aquatic Biota and Ecosystems...................................B-1

B.2.1 Primary Producers................................................................................................................B-2

B.2.2 Primary Heterotrophs...........................................................................................................B-2

B.2.3 Zooplankton .........................................................................................................................B-3

B.2.4 Benthic Community .............................................................................................................B-3

B.2.5 Fish.......................................................................................................................................B-3

B.2.6 Ecosystem Functions and Services......................................................................................B-3

B.3 Influence of Site-Specific Factors and Environmental Setting on Thermal Effects.......................B-4

B.3.1 Geographic Location............................................................................................................B-4

B.3.2 Marine vs. Freshwater Receiving Waters ............................................................................B-5

B.3.3 Receiving Water Volume.....................................................................................................B-5

B.3.4 Rate of Water Exchange.......................................................................................................B-5

B.3.5 Local Land Use ....................................................................................................................B-5

B.3.6 Local Habitats......................................................................................................................B-6

B.4 Uncertainties and Limitations of Assessing Thermal Impacts .......................................................B-6

B.5 Case Studies....................................................................................................................................B-6

B.5.1 Brayton Point Station...........................................................................................................B-7

B.5.2 Quad Cities Nuclear Station............................................................................................... B-10

B.5.3 Point Beach Nuclear Station .............................................................................................. B-12

Appendix C: Details of Regional IM&E ...............................................................................................C-1

C.1 California Region ...........................................................................................................................C-1

C.2 North Atlantic Region ....................................................................................................................C-3

C.3 Mid-Atlantic Region.......................................................................................................................C-6

C.4 South Atlantic Region .................................................................................................................. C-10

C.5 Gulf of Mexico Region................................................................................................................. C-12

C.6 Great Lakes Region ...................................................................................................................... C-14
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C.7 Inland Region ............................................................................................................................... C-17

C.8 National Estimates........................................................................................................................ C-20

Appendix D: Discounting Benefits.........................................................................................................D-1

D.1 Introduction ....................................................................................................................................D-1

D.2 Timing of Benefits..........................................................................................................................D-1

D.3 Discounting and Annualization ......................................................................................................D-3

Appendix E: List of T&E Species Overlapping CWIS........................................................................E-1

Appendix F: Detailed Methodologies for Estimating Benefits to Threatened and Endangered 

Species............................................................................................................................................ F-1

F.1 IM&E of Sea Turtles.......................................................................................................................F-1

F.2 Application of Whitehead’s (1993) Benefit Transfer Approach for Estimating WTP for T&E Sea 

Turtle Species..................................................................................................................................F-3

Appendix G: Estimation of Price Changes for Consumer Surplus....................................................G-1

G.1 Introduction ....................................................................................................................................G-1

G.2 Methodology and Results...............................................................................................................G-1

Appendix H: Details of Regional Commercial Fishing Benefits.........................................................H-1

Appendix I: Details of Regional Recreational Fishing Benefits........................................................... I-1

I.1 California Region .............................................................................................................................I-1

I.2 North Atlantic Region ......................................................................................................................I-5

I.3 Mid-Atlantic Region.........................................................................................................................I-9

I.4 South Atlantic Region ....................................................................................................................I-13

I.5 Gulf of Mexico Region...................................................................................................................I-15

I.6 Great Lakes Region ........................................................................................................................I-19

I.7 Inland Region .................................................................................................................................I-23
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 1: Introduction

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1 Introduction

EPA is issuing the final rule implementing section 316(b) of the Clean Water Act (CWA) to address the 

environmental impacts of cooling water intake structures (CWIS). The withdrawal of cooling water from 

streams, rivers, estuaries and coastal marine waters by CWIS causes adverse environmental impacts 

(AEI) to aquatic biota and communities in these waterbodies. These impacts are caused through several 

means, including impingement mortality (where fish and other aquatic life are trapped on equipment at 

the entrance to the CWIS and entrainment (where aquatic organisms, including eggs and larvae, are 

pulled into the cooling system, passed through the heat exchanger, then discharged back into the source 

body). Additional adverse effects are often associated with CWIS operation, including nonlethal effects of 

impingement, thermal discharges, chemical effluents, flow modifications caused by these facilities, and 

other impacts of variable and unknown magnitudes. 

The final rule would establish national performance requirements for the location, design, construction, 

and capacity of CWIS. It is designed to minimize the AEI caused by CWIS through reduction of volume, 

frequency, and/or seasonality of water withdrawals. The final rule will significantly reduce impingement 

mortality and entrainment (IM&E), as well as reduce the magnitude of other impacts (i.e., thermal, 

chemical, and flow alteration) on aquatic ecosystems. Thus, changes in CWIS design or operation 

resulting from the final rule are likely to result in enhanced ecosystem function and increased ecological 

services provided by affected waterbodies.

The two broad categories of regulated facilities include: (1) electric generators and (2) manufacturers. 

These facilities include existing electric generators and manufacturers with a design intake flow (DIF) of 

at least 2 million gallons per day (mgd) that use at least 25 percent of the water (measured on an average 

annual basis for each calendar year) exclusively for cooling purposes.

EPA is required to conduct a benefit-cost analysis under Executive Orders 12866 and 13563 for 

economically significant rules. This report presents the methods EPA used for the environmental 

assessment and benefits analysis of the regulatory options. EPA had three main objectives: (1) to develop 

a national estimate of the baseline magnitude of IM&E at regulated facilities; (2) to estimate changes in 

IM&E of fish and invertebrates as a result of the rule; and (3) to estimate the national economic benefits 

of reduced IM&E. 

This report describes the regulatory options that EPA considered, and identifies the types of economic 

benefits that are likely to be generated by improved ecosystem functioning under different regulatory 

options. The report also presents the basic concepts involved in analyzing these economic benefits—

including benefit categories and benefit taxonomies associated with market and nonmarket goods and 

changes in ecological services likely to result from reduced IM&E. Specific chapters of the report detail 

the methods used to estimate values for reductions in IM&E. The organization of this analysis is 

described in Section 1.3.

The analysis conducted in support of the final rule and discussed in this report is based on data generated 

or obtained in accordance with EPA’s Quality Policy and Information Quality Guidelines. EPA’s quality 

assurance (QA) and quality control (QC) activities for this rulemaking include the development, approval 

and implementation of Quality Assurance Project Plans for the use of environmental data generated or 

collected from all sampling and analyses, existing databases and literature searches, and for the 

development of any models which used environmental data. Unless otherwise stated within this 

document, the data used and associated data analyses were evaluated as described in these quality 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 1: Introduction

May 2014 1-2

assurance documents to ensure they are of known and documented quality, meet EPA's requirements for 

objectivity, integrity and utility, and are appropriate for the intended use.

1.1 Summary of the Final Rule and Other Options Considered

EPA considered regulatory options for existing units and new units at existing facilities. The options 

apply only to existing facilities with a DIF for cooling water of 2 mgd or greater. EPA considered three 

options for the existing units based on two technologies:

 Proposal Option 4: IM for Facilities > 50 mgd. Establish impingement mortality controls at all 

existing facilities that withdraw over 50 mgd; determine entrainment controls for facilities greater 

than 2 mgd DIF on a site-specific basis.

 Final Rule – Existing Units: IM Everywhere. Establish impingement mortality controls at all 

existing facilities that withdraw over 2 mgd; determine entrainment controls for facilities greater 

than 2 mgd DIF on a site-specific basis.

 Proposal Option 2: IM Everywhere and E for Facilities > 125 mgd. Establish impingement 

mortality controls at all existing facilities that withdraw over 2 mgd DIF; require flow reduction 

commensurate with closed-cycle recirculating systems for entrainment control by facilities 

greater than 125 mgd DIF.

Proposal Options 4 and Proposal Option 2 above correspond to Options 4 and 2 from EPA’s analysis for 

the proposed rule (USEPA 2011) with some modifications. The final rule is Option 1 from the proposed 

rule with the same modifications. The final rule will establish entrainment controls for facility greater 

than 2 mgd DIF on a site-specific basis, as would Proposal Option 4. Findings presented in this document

assume that facilities with impoundments will qualify as having closed-cycle recirculating systems in the 

baseline. As a result, EPA estimated zero IM&E reductions for these facilities under the final rule and 

other options considered; however, these facilities remain subject to today’s rule and are assigned 

administrative costs. To the extent that some of these facilities do not qualify as having closed-cycle 

recirculating systems in the baseline, the monetized benefits reported in this document may be 

underestimates.1

EPA considered four regulatory options for new units at existing facilities. Stand-alone new units are 

newly built units adjacent to existing units and repowered units are existing units that have been wholly or 

partially demolished and rebuilt or upgraded on the same site.

 Option A: Entrainment performance requirements for all standalone new units and all types of 

repowered units.

 Option B: Entrainment performance requirements for all stand-alone new units, and replaced or 

repowered units in which turbine or condenser are newly built or replaced.

 Option C: Entrainment performance requirements for all stand-alone new units, and repowered 

new units where the turbine and condenser are newly built or replaced, but excluding high 

efficiency systems.

 Final Rule – Option D: Entrainment performance requirements for all stand-alone new units 

only.

 

1 EPA notes that the vast majority of these facilities occur in the Inland benefits region. Any underestimation in monetized 

benefits due to the treatment of facilities with impoundments is likely to be minor because commercial fishing benefits and 

nonuse benefits are not estimated for the Inland region.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 1: Introduction

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Refer to Section VI of the preamble for a more complete description of the final rule and other options 

considered for existing and new units.

This report presents EPA’s analysis of environmental and economic benefits for the final rule and the 

other options considered described above. EPA also presents monetized values for baseline IM&E losses 

at existing facilities. The associated benefits estimates equivalent to benefits if all baseline IM&E losses 

were to be eliminated. EPA emphasizes that this not a regulatory option and that it presents baseline 

values for illustration purposes only.

EPA discounted and annualized benefits for the final rule and other options considered following three 

steps. First, EPA developed a time profile of benefits to show when benefits occur. Second, the Agency 

calculated the total discounted present value of the benefits as of the year 2013. Finally, EPA annualized 

the benefits of the final rule and other options considered, over a 51-year time span. Refer to Appendix D 

for additional detail regarding discounting and annualization.

1.2 Study Design

EPA’s analysis of the regulatory options examined CWIS impacts and regulatory benefits in seven study 

regions. EPA defined the study regions on the basis of ecological similarities within regions (e.g., 

freshwater versus marine, similar communities of aquatic species), and on characteristics of commercial 

and recreational fishing activities. The seven study regions are: California2, North Atlantic, Mid Atlantic, 

South Atlantic, Gulf of Mexico, Great Lakes, and Inland. The Great Lakes region includes all facilities 

located on the Great Lakes, the Inland region includes all other freshwater facilities, and the remaining 

five regions include coastal and estuarine facilities. Sections 1.2.1, 1.2.2, and 1.2.3 provide additional 

detail regarding the definition of each region. National estimates are the sum of regional estimates. Table 

1-1 presents the number of regulated facilities that participated in the Section 316(b) Industry Surveys and 

their total actual intake flow by study region. EPA excluded facilities that it classifies as baseline closures 

from all totals and figures presented throughout this document, including Table 1-1. Baselines closures 

are also excluded from all totals and figures presented throughout this document. EPA classifies an 

electric generating facility as a baseline closure if it has retired all steam operations since the 316(b) 

survey was conducted or if EPA expects that it will retire its steam capacity by 2021, according the 2011 

EIA-860 Database published by the Energy Information Administration (EIA) and U.S. Department of 

Energy (DOE). For manufacturers, baseline closures are facilities showing materially inadequate financial 

performance in the baseline. Refer to Appendix H of the Economic Analysis (EA) for additional detail 

regarding baseline closures.

The facility universe includes facilities that are subject to state regulations for CWIS in California and 

New York. The California state regulation requires closed-cycle recirculating systems for coastal electric 

generating facilities while the New York state regulation requires closed-cycle recirculating systems for 

all in-state facilities with DIF greater than or equal to 20 mgd. Fourteen surveyed facilities fall within the 

scope of the California state regulation and 32 surveyed facilities fall within the scope of the New York 

state regulation.3 EPA determined that the state regulations are at least as stringent as the final rule and 

other options considered. Facilities within the scope of the state regulations would be subject to the 

requirements of the final rule, but they may not be required to install additional technologies to reduce 

IM&E under the final rule. Within the benefits analysis for the 316(b) rule, EPA assigns these facilities 

baseline levels of IM&E that are commensurate with compliance with the state regulations. These 

 

2

Includes four regulated facilities in Hawaii.

3 These counts exclude 6 California facilities and 5 New York facilities which EPA classifies as baseline closures. 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 1: Introduction

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facilities do not influence the occurrence and magnitude of benefits under the final rule, similar to other 

facilities which already meet the requirements of the final rule.

EPA has determined that 280 surveyed facilities currently satisfy the IM performance standard 

established by the final rule or use one of several compliant technologies to achieve this goal, including 

all facilities that are subject to the California and New York state regulations described above. Although 

these 280 facilities are subject to the requirements of the final rule, they may not be required to install 

technologies in order to comply with the final rule. Thus, these facilities have not been factored into the 

benefits analysis for the final rule.

Table 1-1: Number of Facilities and Total Mean Operational Flow, by Regiona,b

Region Number of Surveyed 

Facilities

Flow 

(billions of gallons per day)

Non-Recirculating 

Facilitiesc

Recirculating 

Facilities Total Flow

Californiad21 10.65 0.00 10.65

Great Lakes 50 16.24 0.24 16.47

Inlande566 107.56 18.06 125.62

Mid-Atlantic 46 24.69 0.07 24.76

Gulf of Mexico 22 10.14 0.05 10.18

North Atlantic 21 5.93 0.00 5.93

South Atlantic 12 5.91 0.05 5.96

All Regions 738 181.12 18.46 199.58

a This table presents counts of unweighted facility counts and flow for surveyed facilities (excluding baseline closures). The regional 

study design for the benefits analysis weights based on flow rather than facility counts. EPA did not developed weighted facility 

counts by benefits region. The “All Regions” total of 738 surveyed facilities includes 532 electric generating facilities and 206 

manufacturing facilities, excluding baseline closures. The total (weighted) estimated universe of facilities, excluding baseline 

closures, is 1,065 facilities. 

b The facility counts and flow presented in this table include facilities which are subject to state regulations for CWIS in California 

and New York. Within the benefits analysis for the 316(b) rule, EPA assigns these facilities baseline levels of IM&E that are 

commensurate with compliance with the state regulations.

c Recirculating facilities are facilities with closed-cycle recirculating systems or impoundments that qualify as closed-cycle 

recirculating systems. Non-recirculating facilities includes facilities with CWIS classified as once-through.

d The California region includes four facilities in Hawaii. There are no coastal facilities in Oregon and one costal facility in 

Washington is classified as a baseline closure.

e A facility in Texas has intakes located in both the Inland and Gulf of Mexico regions. It is included within the Inland region within 

in the table to prevent the double counting of facilities.

Source: U.S. EPA analysis for this report.

1.2.1 Coastal Regions

The five coastal regions (California, North Atlantic, Mid-Atlantic, South Atlantic, and Gulf of Mexico) 

correspond to regions defined by the National Oceanic and Atmospheric Administration’s (NOAA) 

National Marine Fisheries Service (NMFS). These regions include facilities that withdraw cooling water 

from estuaries, tidal rivers and ocean facilities within the NMFS regions. 

Coastal regions are defined as follows. The California region includes all coastal, estuarine or tidal 

facilities in the state of California, plus four facilities in Hawaii. The North Atlantic region encompasses 

coastal, estuarine, or tidal facilities in Maine, New Hampshire, Massachusetts, Rhode Island, and 

Connecticut. The Mid-Atlantic region includes all coastal, estuarine or tidal facilities in New York, New 

Jersey, Pennsylvania, Delaware, Maryland, the District of Columbia, and Virginia. The South Atlantic 

region includes all coastal, estuarine or tidal facilities in North Carolina, South Carolina, Georgia, and the 
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east coast of Florida. Finally, the Gulf of Mexico region includes coastal, estuarine or tidal facilities in 

Texas, Louisiana, Mississippi, Alabama, and the west coast of Florida. Coastal regions include a total of 

123 facilities.

1.2.2 Great Lakes Region

The Great Lakes region is defined in accordance with the CWA to include facilities withdrawing cooling 

water from Lake Superior, Lake Michigan, Lake Huron (including Lake St. Clair), Lake Erie and Lake 

Ontario, and the connecting channels (Saint Mary’s River, Saint Clair River, Detroit River, Niagara 

River, and Saint Lawrence River to the Canadian border) (Great Lakes 1990). The Great Lakes region is 

comprised of 50 facilities. 

1.2.3 Inland Region

The Inland region includes all regulated facilities that withdraw water from all inland waterbodies such as 

freshwater streams and rivers, lakes, reservoirs (excluding those included within the Great Lakes Region) 

regardless of geographical location. There are 566 such facilities in 39 states (including states with both 

coastal and inland facilities).

1.3 Organization of the Document

Chapter 2 provides information on the baseline conditions of the water bodies affected by regulated 

facilities. To obtain regional IM&E estimates, EPA extrapolated loss rates from facilities for which IM&E

data are available (hereafter, model facilities), to all regulated facilities within the same region. EPA’s 

extrapolation methods for, and results from, regional IM&E models are described in Chapter 3.

EPA provides an overview of all benefits (Chapter 4) and investigates several benefit categories in detail, 

including: benefits from improved protection of threatened and endangered (T&E) species (Chapter 5), 

commercial fishing benefits (Chapter 6), recreational fishing benefits (Chapter 7), and nonuse benefit

transfer (Chapter 8). Chapter 9 presents benefits estimates based on the social cost of carbon. Chapter 10 

summarizes benefits for existing units estimated using the methodologies described in Chapters 5 through 

9. EPA also used the preliminary results of a its 316(b) stated preference study to illustrate potential 

willingness to pay (WTP) for aquatic ecosystem improvements (Chapter 11). Chapter 12 presents benefit 

estimates for new units at existing facilities based on benefits methodologies described in Chapter 5 

through 9. Chapter 13 summarizes total national benefits for existing and new units at regulated facilities.

Additional details regarding EPA’s benefits analysis are presented in Appendix A through Appendix I. 

Appendix A presents the extrapolation methods used by EPA to analyze the benefits from reducing 

IM&E at regulated facilities; Appendix B describes potential ecological effects due to thermal discharges; 

Appendix C presents detailed output from IM&E models; Appendix D discusses economic discounting 

and the expected timing of benefits; Appendix E presents a list of T&E species likely impacted by IM&E; 

Appendix F provides details on the methodologies used to estimate the effects of IM&E on T&E species, 

and the benefits from the section 316(b) rule; Appendix G presents EPA’s analysis of the potential for 

IM&E reductions to impact the market price of commercially fished species; Appendix H presents details 

of the benefits of IM&E on commercial fishing by region; and Appendix I presents detailed regional 

results of the effects of IM&E on recreational fishing benefits. 
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2 Baseline Impacts 

2.1 Introduction

This chapter provides a brief summary of adverse environmental impacts from the IM&E of fish and 

invertebrates in CWIS used by electric power and manufacturing facilities subject to the final rule under 

section 316(b) of the CWA. 

CWIS impacts do not occur in isolation from other ongoing physical, chemical, and biological stressors 

on aquatic habitats and biota in the receiving waterbody. Additional anthropogenic stressors may include, 

but are not limited to: degraded water and sediment quality, low dissolved oxygen (DO), eutrophication, 

fishing pressure, channel or shoreline (habitat) modification, hydrologic regime changes, and invasive 

species. For example, many aquatic organisms subject to the effects of cooling water withdrawals reside 

in impaired (i.e., CWA 303(d) listed) waterbodies. Accordingly, they are potentially more vulnerable to 

cumulative impacts from other anthropogenic stressors (USEPA 2006a). The effect of these 

anthropogenic stressors on local biota may contribute to or compound the local impact of IM&E, 

depending on the influence of location-specific factors. In addition to multiple stressors acting on biota 

near a single CWIS, multiple facilities and CWIS located in close proximity along the same waterbody 

may have additive or cumulative effects on aquatic communities (USEPA 2006a). 

Although it is difficult to measure, an aquatic population's compensatory ability—the capacity for a 

species to increase survival, growth, or reproduction rates in response to decreased population —is likely 

compromised by IM&E and the cumulative impact of other stressors in the environment over extended 

periods of time (USEPA 2006a). These cumulative impacts may lead to subtle, less-easily observed 

changes in aquatic communities and ecosystem function. These secondary impacts are difficult to isolate 

from background variability, partly because of the limited scope and inherent limitations of the data 

available to characterize IM&E.

Since the aquatic habitat quality and health of the biotic community are shaped by the cumulative effect 

of many factors, it is important to characterize the environmental context of baseline impacts. This will 

permit comparisons between the relative influences of CWIS-related stressors and other factors, and result 

in a more accurate estimate of the environmental impact of the final rule.

This chapter provides a qualitative description of baseline IM&E impacts and anthropogenic stressors 

found in aquatic environments affected by CWIS.

2.2 Major Anthropogenic Stressors in Aquatic Ecosystems 

All ecosystems and biota are subject to natural variability in environmental conditions (e.g., seasonal 

perturbations), as well as periodic large-scale disturbances in environmental settings (e.g., drought, flood, 

fire, disease). Indigenous aquatic species and communities are adapted to this natural variability, such that 

large-scale events elicit a predictable loss, response and recovery cycle. Conversely, anthropogenic 

stressors tend to be more chronic in nature and often do not lead to recognizable recovery phases. Instead 

these stressors often lead to long-term environmental degradation associated with lowered biodiversity, 

reduced primary and secondary production, and a lowered capacity or resiliency of the ecosystem to 

recover to its original state in response to natural perturbations (Rapport and Whitford 1999).

Anthropogenic stressors are present to some degree in all major waterbodies of the United States, and are 

the result of many different impacts (Table 2-1). Four of the more important stressors include: (i) habitat 
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loss; (ii) degraded water quality and sediment contamination; (iii) extractive uses of aquatic resources; 

and (iv) invasion by non-indigenous species (Rapport and Whitford 1999). CWIS-related impacts are 

listed here as a separate, fifth category of anthropogenic stress, one with many apparent similarities to 

overharvesting. Other large-scale stressors, such as change in watershed land use and engineering 

diversions, may be present. Thus, the true impact of CWIS on an aquatic community may be partly 

masked, or difficult to detect, due to the influence of other stressors on the receiving water.

The remainder of this section summarizes effects of these four anthropogenic stressors on the waterbodies 

affected by regulated facilities. CWIS impacts on the aquatic ecosystems are summarized in Section 2.3.

Table 2-1: Anthropogenic Stressors Impacting Aquatic Ecosystems Potentially Affected, Both 

Directly and Indirectly, by the Final Rule and Options Considered

Anthropogenic Stressor

Impacted by the Rule

Proposal Scale of Stressor

Option 4 Final Rule Proposal Option 2

CWIS Yes: Direct Yes: Direct Yes: Direct Local/Regional/National

Habitat loss

Development No No No Local

Eutrophication Yes: Indirect Yes: Indirect Yes: Indirect Local/Regional

Climate change No No No Regional/National/Global

Engineering diversions

Re-routing No No No Local/Regional

Flow adjustments/removals/ 

modifications No No Yes: Direct Local/Regional

Water impoundments/damming No No No Local/Regional

Water quality

Eutrophication Yes: Indirect Yes: Indirect Yes: Indirect Local/Regional

Loss of riparian buffer zones No No No Local/Regional

Sedimentation No No Yes: Direct Local/Regional

Chemical pollution (organics, 

heavy metals, etc.) No No Yes: Direct Local/Regional

Non-native / invasive species Yes: Indirect Yes: Indirect Yes: Indirect Local/Regional

Extractive uses (e.g. fishing) Yes: Indirect Yes: Indirect Yes: Indirect Local/Regional

Source: U.S. EPA analysis for this report

2.2.1 Habitat Loss

Structural aquatic habitat is generally recognized as the most significant determinant of the nature and 

composition of aquatic communities. Human occupation and restructuring of shorelines; construction and 

maintenance of harbors; installation of dams, canals, and other navigational infrastructure; draining of 

wetlands for agriculture and residential uses; and degradation of critical fish habitats have all taken a 

heavy toll on the numbers and composition of local fish and shellfisheries. Most regulated facilities have 

been built on shoreline locations where power-generation buildings, roadways, CWIS, canals, 

impoundments, and other water storage or conveyance structures have often been constructed at the cost 

of natural habitat, including terrestrial, aquatic, and wetlands. 

The loss of coastal and estuarine wetlands that serve as important fishery spawning and nursery areas is 

particularly severe, with an estimated historical loss of 100 million acres of wetlands since the late 1700s 

(Bromberg and Bertness 2005; USEPA 2010c). Critical fishery habitat loss is not restricted to nearshore 

environments. Decades of fishing activities have degraded offshore bottom habitats (Auster and Langton 

1999; Turner et al. 1999).
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The main impact of aquatic habitat loss is a reduction in the number of fish in the environment, a 

reduction in fish spawning and nursery areas, shifts in species dominance based on available habitat, and 

local extirpation of historical fish species. Habitat loss in adjacent shoreline areas exacerbates the effect of 

CWIS losses, since many fish species affected by IM&E (e.g., bay anchovy, winter flounder) rely on 

coastal wetlands as nursery areas. 

In riverine environments, the effects of channelization and navigation can also lead to habitat loss. For 

example, Tondreau et al. (1982) conducted a 10-year study of the aquatic ecosystem of the Missouri River 

near the Neal Generating facility in Sioux City, IA. The investigators found that the combined effects of 

channelization, heavy barge traffic, and high river flow rates had resulted in a significant loss of fish 

habitat. As a result, reported IM&E is relatively minor, because local fish populations were already 

greatly diminished. 

2.2.2 Water Quality 

Water quality is a major stressor of aquatic biota and habitats. Degraded surface water and sediment 

contaminants reflect current and historical industrial, agricultural and residential land use as well as 

discharges from wastewater treatment facilities. Poor water quality can limit the numbers, composition, 

and distribution of fish and invertebrates; reduce spawning effort and growth rates; select for pollutiontolerant species; cause periodic fish kills; or result in adverse effects to piscivorous wildlife. 

CWA section 303(d) listings inventory, on a state-by-state basis, the locations of impaired waters not 

meeting designated uses and the known or suspected source(s) of impairment. Figure 2-1 identifies 

regulated facilities, those within two miles of a 303(d)-listed waterbody, and those impaired for 

temperature, using a database of 303(d) waterbodies assembled in October, 2010. The map clearly shows 

that facilities along the coasts, Great Lakes, and major waterways such as the Mississippi, Missouri, and 

Ohio rivers are located in the vicinity of impaired waterbodies.

EPA’s analysis of regulated facilities demonstrated that the majority of facilities (74 percent) are within 

two miles of a 303(d)-listed waterbody. Table 2-2 summarizes the number of regulated facilities on 

waterbodies impaired by any cause, by region. These include impairment due to chemical, physical, and 

biological factors, categorized into biological stressors, nutrients, organic enrichment/loading, 

bioaccumulation, toxics, unknown causes, and general water quality impairment.
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Figure 2-1: Map of Facilities Located on 303(d) Waters and Those 303(d) Waters Listed for 

Temperature in 2010
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The most common causes of impairment for waterbodies serving as 316(b) source waters are 

polychlorinated biphenyls (PCBs), pathogens, mercury, as well as organic enrichment/oxygen 

depletion and nutrients. The entire universe of all 303(d) water quality impairment causes is much 

too diverse to cover fully in this section. However, below is a discussion of some of the more 

common and important physico-chemical impairments in aquatic environment where regulated 

facilities draw cooling water from, and discharge to, 303(d) listed waters.

 An oversupply of nutrients can result in excessive algal production, reduced light clarity, 

more frequent outbreaks of harmful algal blooms (HABs), high internal loads of 

biochemical oxygen demand (BOD), and spatial and temporally variable DO levels. In 

addition, eutrophication can reduce or eliminate habitat-formers such as coral reefs and 

submerged aquatic vegetation (SAV), and create other adverse ecological effects. 

Thermal discharges from regulated facilities can increase receiving water temperature, 

which may favor formation of blue-green algal blooms.

 Low levels of dissolved oxygen (hypoxia) may be present in many estuaries and coastal 

waters (IWG 2010), in the hypolimnia of eutrophic lakes, and in areas of high organic 

loading (e.g., below wastewater treatment plant outfalls). DO concentrations may be 

further decreased in or downstream of thermal plumes arising from cooling water return 

discharges from regulated facilities. Low DO can limit the distribution of fish and 

macroinvertebrates, reduce growth rates, and alter nutrient and carbon recycling.

 Persistent, bioaccumulative and toxic substances (PBTs) such as mercury or PCBs may 

be present in waterbodies near regulated facilities, due to atmospheric deposition of local 

air emissions or from historical uses of PCBs in electrical transformer units, in addition to 

other urban or industrial sources. These PBTs can impair water uses by regulatory 

restrictions or advisories regarding acceptable ingestion of fish consumption (see below), 

as well as affecting higher trophic level predators in the food chain. 

 Toxic pollutants, such as metals, polycyclic aromatic hydrocarbons (PAHs), pesticides, 

biofouling chemicals, or chlorine may be present in the discharge of regulated facilities. 

This could lead to local extirpation of sensitive species, or to greatly altered biological 

communities due to chronic impacts on viability, growth, reproduction, and resistance to 

other stressors.

In addition to the 303(d) listings, many of the waterbodies in which the CWIS are located are 

subject to fish advisories. Fish advisories are issued by States to protect their citizens from the 

risk of eating contaminated fish or wildlife (USEPA 2009a). Fish advisories are recommendations 

and do not carry regulatory authority, but they indicate the presence of bioaccumulative 

chemicals which may pose risk for humans and piscivorous wildlife, and which may also 

interfere with the reproduction and survival of taxa in lower trophic levels.4

 

4 Although fish advisories do not themselves carry regulatory authority, waterbodies may be included on 303(d) 

lists because of persistent fish advisories resulting from the bioaccumulation of specified and unspecified toxics. 
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Table 2-2: Number of Regulated Facilities on 303(d)-listed Waterbodies, by Impairment 

and Regiona

Impairment California Great 

Lakes Inland MidAtlantic

Gulf of 

Mexico

North 

Atlantic

South 

Atlantic Total

Regulated Facilities 21 50 566 46 22 21 12 738

Biological Stressors

Noxious Aquatic Plants 1 1

Nuisance Exotic Species 3 3 6

Pathogens 6 9 85 5 1 9 4 119

Nutrients

Algal Growth 1 1

Nutrients 9 37 3 1 2 6 58

Organic Enrichment / Loading

Organic Enrichment, Oxygen 

Depletion 2 6 43 1 5 3 6 66

Sediment 2 3 15 2 22

Persistent, Bioaccumulative, Toxic (PBTs)

Dioxins 2 13 12 2 29

Fish Consumption Advisory,

Pollutant Unspecified 3 7 1 11

Mercury 3 24 85 3 2 2 119

PCBs 9 45 122 10 2 1 189

Pesticides 10 11 15 36

Physical Alterations

Flow Alteration 4 4

Habitat Alteration 1 7 8

Temperature 6 3 9

Turbidity 21 1 2 24

Toxics

Ammonia 1 1 2

Chlorine 1 1

Metals (Other Than Mercury) 5 4 37 6 1 53

Total Toxicity 7 4 2 1 14

Toxic Inorganics 1 1 2

Toxic Organics 3 8 2 13

Unknown / Other Causes

Cause Unknown 8 8

Cause Unknown - Fish Kills 1 1

Cause Unknown - Impaired

Biota 2 2 12 2 18

Other Cause 3 1 4

Water Quality Use Impairments (General)

Oil And Grease 4 3 7

pH 3 7 10

Salinity, TDS, Sulfates, 

Chlorides 1 1 6 8

Taste, Color And Odor 3 1 4

All Impairment Categories

One or More Impairments 18 46 398 38 12 20 11 543

a Waterbodies may be listed for multiple impairments and facilities may be counted in more than one row.

Source: U.S. EPA analysis for this report
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EPA’s 2008 National Listing of Fish Advisories (NLFA) database indicates that 97 percent of the 

advisories are due (in order of importance) to: mercury, PCBs, chlordane, dioxins, and DDT 

(USEPA 2009a). Fish advisories have been issued for 39 percent of the total river miles 

(approximately 1.4 million river miles) and 100 percent of the Great Lakes and connecting 

waterways (USEPA 2009a). Fish advisories have been steadily increasing over the NLFA period 

of record (1993-2008), but these increases are interpreted to reflect the increase in the number of 

waterbodies being monitored by States and advances in analytical methods rather than increasing 

levels of these problematic chemicals. 

The water quality impacts arising from the combination of operations and/or discharges of 

regulated facilities and other anthropogenic sources (as indicted by the presence of widespread 

fish advisories) could result in highly degraded or altered aquatic communities that may be 

further reduced by IM&E. 

2.2.3 Overharvesting

Overharvesting is a general term which describes the exploitation of an aquatic population (e.g., 

fish, shellfish, and kelp) in an unsustainable fashion to the point of reducing or even eliminating 

much of the population. Stocks of commercial and recreationally important species are reduced as 

a result of fishing, but such fish catches may be sustainable if sufficient recruitment of juveniles 

into the fishery can replace population losses from fishing and other stressors.5 Unfortunately for 

many aquatic species, overharvesting has a long history and in many instances has preceded 

impacts by other competing anthropogenic stressors by several centuries (Jackson et al. 2001). 

Many species (and fishery stocks) subject to IM&E are also subject to overharvesting. For 

example, the 2011 NMFS stock status report indicated that 14 percent of federally monitored fish 

stocks were being fished at rates above the maximum sustainable yield (“overfishing”), while 21 

percent of species are considered over-exploited (“overfished”) (NMFS 2012c); many of these 

fish stocks are also subject to IM&E. Table 2-3 lists 10 groups of species subject to IM&E that 

are overfished or subject to overfishing. Additional detail regarding the status of stocks is 

provided in Chapter 6 on commercial fishing benefits. Notably, this assessment does not include 

many important fishery species not subject to federal regulation that may be subject to high 

IM&E, nor does this assessment consider threatened and endangered (T&E) species.

Severe overfishing can drive species to ecological insignificance, where the overfished 

populations no longer interact meaningfully in the food web with other species in the community, 

or even to extinction (Jackson et al. 2001). The collapse of the Great Lakes whitefish fisheries has 

been shown to be principally due to overfishing, although habitat alteration and introduction of a 

non-indigenous (exotic) invader (sea lamprey) were also contributory (Rapport and Whitford 

1999). 

 

5 Recruitment is the number of young fish that enter into a population. 
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Table 2-3: Depleted Commercial Fish Stocks Subject to IM&E

Stock or Stock Complex Status of StockaStock Region

Surfperches Overfished but not subject to overfishingb California

Atlantic Cod Overfished or subject to overfishing North Atlantic

Windowpane Overfished but not subject to overfishing North Atlantic

Winter Flounder Overfished but not subject to overfishing North Atlantic

Flounders Overfished or subject to overfishing North Atlantic

Atlantic Menhaden Subject to overfishing but not overfished North Atlantic/South Atlantic

American Shad Overfished North Atlantic/Mid-Atlantic

Weakfish Overfished but not subject to overfishing North Atlantic/MidAtlantic/South Atlantic

Alewife Overfished Mid-Atlantic

Tautog Overfished and subject to overfishing Mid-Atlantic

a

Species group may consist of many individual component species with conflicting stock statuses. The most common stock 

status among the component species was designated the Status of Stock for the species group.

b "Perch" species were used as a proxy for Surfperch.

Source: NMFS 2012c and U.S. EPA analysis for this report

2.2.4 Invasive Species

Non-indigenous, invasive species (NIS) are a significant and increasingly prevalent stressor in 

both freshwater and marine environments (Cohen and Carlton 1998; Ruiz et al. 1999). 

Approximately 300 NIS are established in marine and estuarine habitats of the continental United 

States, and that rate of invasion is rapidly increasing (Ruiz et al. 2000). Aquatic NIS are 

taxonomically diverse and include plants, fish, crabs, snails, clams, mussels, bryozoans, and 

nudibranchs. Analysis of freshwater NIS indicated that between 10 to 15 percent are nuisance 

species with undesirable effects (Ruiz et al. 1999). The adverse implications of marine and 

coastal NIS are generally not as well-characterized as those in freshwater settings. 

Interactions between NIS and other anthropogenic stressors are likely to affect the colonization 

and distribution of native species subject to CWIS impacts. Thermal discharges from regulated 

facilities may extend the seasonal duration of non-resident organisms, allowing transient summer 

species to become permanently established in geographic areas beyond their historical range. For 

example, in Mount Hope Bay, increased water temperature due to the Brayton Point Station 

facility led to an increase in abundance of the predacious ctenophore Mneimiopsis leidyi as well 

as increased overwintering in the Bay for this formerly seasonal resident (USEPA 2002b).

2.3 CWIS Impacts on Aquatic Ecosystems

EPA has determined that multiple types of adverse environmental impacts may be associated with 

CWIS operations at regulated facilities, depending on site-specific conditions at an individual 

facility. Many of these facilities employ once-through cooling water systems that impinge fish 

and other aquatic organisms on intake screens if the intake velocity exceeds these organisms’ 

locomotive ability to move away. Impinged organisms may be killed, injured or weakened, 

depending on the nature and capacity of the plant’s filter screen configuration, cleaning and 

backwashing operations, and fish return system used to return organisms to the source water. In 

addition, early life stage fish or planktonic organisms can be entrained by the CWIS and 

subjected to death or injury due to high velocity and pressure, increased temperature, and 
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chemical anti-biofouling agents in the system. This IM&E can act in concert with the other 

stressors identified above.

The magnitude and regional importance of IM&E is generally a function of the operational intake 

volumes and the characteristics of the aquatic community in the region (see Chapter 3 for details). 

IM&E can contribute to: impacts to T&E species (Chapter 4); reductions in ecologically critical 

aquatic organisms, including important elements of an ecosystem’s food chain; diminishment of 

organism populations’ compensatory reserves; population declines, including reductions of 

indigenous species population levels, commercial fisheries (Chapter 6), and recreational fisheries 

(Chapter 7); and stresses to overall communities and ecosystems, as evidenced by reductions in 

diversity or other changes in ecosystem structure or function. In addition, fish and other species 

affected directly and indirectly by CWIS can provide other valuable ecosystem goods and 

services, including nutrient cycling and ecosystem stability.

The impacts of IM&E occur at many levels of ecological organization and across a wide range of 

environmental scales. Table 2-4 presents a summary of direct and indirect impacts of CWIS and 

IM&E. The effects are identified as direct, indirect, or a combination. This table also indicates the 

relative scale (local, regional, national) of the particular effect. In most cases, EPA was unable to 

estimate the magnitude of these effects due to a lack of data. This section discusses a subset of 

these effects. 

2.3.1 Losses of Fish from IM&E

The most visible direct impact of IM&E is the loss of large numbers of aquatic organisms, 

distributed non-uniformly among fish, benthic invertebrates, phytoplankton, zooplankton, and 

other susceptible aquatic taxa (e.g., sea turtles). This has immediate and direct effects on the 

population size and age distribution of affected species, and may cascade through food webs. 

Populations of aquatic organisms decline when recruitment rates are lower than mortality rates. 

Natural sources of mortality for fish species include predation, food availability, injury, climatic 

factors and disease. Anthropogenic sources of fish mortality, both proximate and ultimate, 

include fishing, habitat modification, pollution, and IM&E at CWIS. Reducing IM&E will 

contribute to the health and sustainability of fish populations by lowering the total mortality rate 

for these populations. 

In some cases, IM&E has been shown to be a significant source of anthropogenic mortality to 

depleted stocks of commercially targeted species. For example, IM&E [expressed as age-one

equivalents (A1E)] equal approximately 10 percent of the average annual recruitment to the 

Southern New England/Massachusetts stock of winter flounder (Pseudopleuronectes americanus) 

(IM&E values from Chapter 3; recruitment data from Terceiro (2008)). 
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Table 2-4: CWIS Effects on Ecosystem Functions/Cumulative Impacts Potentially 

Affected, Both Directly and Indirectly, by the 316(b) Rule

Category Direct/Indirect Local/Regional/

National

A. Impingement and Entrainment (direct and indirect effects)

Effects on Individuals

Loss of individuals (direct effects) Direct Local/Regional/National

Phytoplankton Direct Local/Regional/National

Zooplankton (excluding fish larvae/eggs) Direct Local/Regional/National

Invertebrates Direct Local/Regional/National

Fish Direct Local/Regional/National

Non-fish vertebrates Direct Local/Regional/National

Species and Population-Level Effects

Alteration of phenology of system (function of % water 

reduction in stream) Direct Local/Regional/National

Altered distribution of populations Direct Local

Altered niche space Direct Local/Regional

Altered stable age distributions of populations Direct Regional

Loss of keystone species Direct Local

Loss of T&E species Direct Regional

Novel selection pressure (e.g., negatively buoyant or 

stationary eggs) Direct & Indirect Local

Reduced/altered genetic diversity Direct & Indirect Regional/National

Reduced lifetime ecological function of individuals Direct Local/Regional

Community and Trophic Relationships 

Altered competitive interactions Direct & Indirect Local

Disrupted trophic relationships Direct & Indirect Local

Disrupted control of disease-harboring insects (e.g., mosquito 

larvae, etc.) Indirect & Direct Local/Regional

Increased quantity of detritivores Indirect Local

Loss of ecosystem engineers (due to trophic interactions) Indirect & Direct Local

Reduced potential for energy flows (e.g. trophic transfers) Indirect Local/Regional

Species diversity and richness Direct & Indirect Local/Regional/National

Trophic cascades Indirect & Direct Local/Regional

Ecosystem Function

Altered ecosystem succession Indirect & Direct Local/Regional

Decreased ability of ecosystem to control nuisance species 

(algae, macrophytes) Indirect Local

Disrupted cross-ecosystem nutrient exchange (e.g., 

up/downstream, aquatic/terrestrial) Indirect Regional

Disrupted nutrient cycling Indirect & Direct Local/Regional

Reduced compensatory ability to deal with environmental 

stress (resilience) Direct & Indirect Regional

Reduced ecosystem resistance Indirect Local/Regional

Reduced ecosystem stability (alternate states) Indirect Local/Regional

Sediment regulation Indirect Local/Regional

Substrate regulation Indirect Local

B. Thermal Effects (direct and indirect)

Novel selection pressure (e.g., thermal optima, location of 

breeding, etc.) Direct & Indirect Regional/National

Altered phenology Direct Local/Regional

Links between temperature and metabolism

Dissolved oxygen (physical) Direct Local

Dissolved oxygen (bacterial, respiratory rates) Indirect Local
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Table 2-4: CWIS Effects on Ecosystem Functions/Cumulative Impacts Potentially 

Affected, Both Directly and Indirectly, by the 316(b) Rule

Category Direct/Indirect Local/Regional/

National

Ecological energetic demands Indirect Local/Regional

Ecological nutrient demands Indirect Local/Regional

Altered algal productivity Direct & Indirect Local/Regional

Shifted nutrient cycling Indirect & Direct Local/Regional

C. Chemical Effects (anti-foulants, etc.)

Altered survival/growth/production Indirect & Direct Local

Altered food web dynamics Indirect Local

D. Altered Flow Regimes (local and system-wide)

Altered flow velocity Direct & Indirect Local/Regional

Altered turbulence regime Direct & Indirect Local/Regional

E. Cumulative Impacts (as a concentrated number of facilities)

May push systems over the edge of nonlinearities in the 

system Direct/Indirect Local/Regional

Intensified CWIS effects (as above, Section B.) Direct/Indirect Local/Regional

Intensified thermal effects (as above, Section B.) Direct/Indirect Local/Regional

Source: U.S. EPA analysis for this report

In addition to its impact on stocks of marine commercial fish species, IM&E increases the 

pressure on native freshwater species, such as lake whitefish (Coregonus clupeaformi) and yellow 

perch (Perca flavescens), whose populations have seen dramatic declines in recent years (USDOI 

2008; Wisconsin DNR 2003). Although recovery of these species is greatly affected by fisheries 

policy (e.g., NEFSC 2008), IM&E represent an additional source of mortality to fish populations 

being harvested at unsustainable levels. 

Overall, IM&E is likely to contribute to reduction in the population sizes of species targeted by 

commercial and recreational fishers, particularly for stocks that are undergoing rebuilding. 

Although these reductions may be small in magnitude compared to fishing pressure (Lorda et al. 

2000), and often difficult to measure due to the low statistical power of fisheries surveys, a 

reduction in mortality rates on overfished populations is likely to increase the rate of stock 

recovery. Although researchers know less about the population biology of forage fish not targeted 

by fishers, similar benefits are likely to accrue for these species. Overall, reducing IM&E may 

lead to more-rapid stock recovery, a long-term increase in commercial fish catches, increased 

population stability following periods of poor recruitment and, as a consequence of increased 

resource utilization, an increased ability to minimize the invasion of exotic species (Shea and 

Chesson 2002; Stachowicz and Byrnes 2006). 

For many fish species, IM&E may not lead to measurable reductions in adult populations. These 

losses, however, are likely to reduce the compensatory ability of populations to respond to 

environmental variability, including temperature extremes, heavy predation, disease, or years 

with low recruitment. Additionally, because predation rates are often directly related to the 

concentration of available prey, IM&E may lead to indirect population effects, whereby 

reductions in a prey fish may indirectly result in reductions to predator species or increases to 

species in apparent competition (Holt 1977).

Moreover, IM&E represents a novel selective pressure for fish populations. Consequently, 

populations may be selected for resistance to IM&E (through behavioral or physiological 

changes) at the expense of other, more “natural” evolutionary pressures. Although this may help 
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sustain populations in the short term, it may reduce genetic diversity and population stability in 

the long-term.

2.3.2 IM&E Effects on T&E species

T&E species are species vulnerable to future extinction or at risk of extinction in the near future, 

respectively. Due to low population sizes, IM&E from CWIS may represent a substantial portion 

of the annual reproduction of T&E species. Consequently, IM&E may either lengthen population 

recovery time, or hasten the demise of these species. For these reasons, the population-level and 

social values of T&E losses are likely to be more important than the absolute number of losses 

that occur.

Adverse effects on T&E species due to water withdrawals by CWIS may occur in several ways:

 Populations of T&E species may suffer increased mortality as a consequence of IM&E.

 T&E species may suffer indirect harm if the CWIS substantially alters the food web in 

which these species interact.

 T&E species may suffer indirect harm if the CWIS substantially alters habitat that is 

critical to their long-term survival. 

Chapter 5 provides detail on CWIS impacts on T&E species.

2.3.3 Thermal Effects

Once-through cooling water systems release heated effluent as a byproduct. Concerns about the 

impacts of heated effluents are addressed by provisions of CWA section 316(a) rule. Most of the 

facilities subject to 316(b) IM&E concerns have also been required to address the impact of 

thermal pollution in the discharge-receiving waters (Abt Associates 2010b). 

Thermal pollution has long been recognized as having effects upon the structure and function of 

ecosystems (Abt Associates 2009). Numerous studies have shown that thermal discharges may 

substantially alter the structure of the aquatic community by modifying photosynthetic (Bulthuis 

1987; Chuang et al. 2009; Martinez-Arroyo et al. 2000; Poornima et al. 2005), metabolic, and 

growth rates (Leffler 1972), and reducing levels of DO. Thermal pollution may also alter the 

location and timing of fish behavior including spawning (Bartholow et al. 2004), aggregation, and 

migration (USEPA 2002b), and may result in thermal shock-induced mortality for some species

(Ash et al. 1974; Deacutis 1978; Smythe and Sawyko 2000). Thus, thermal pollution is likely to 

alter the ecological services provided by ecosystems surrounding facilities returning heated 

cooling water into nearby waterbodies. 

Adverse temperature effects may also be more pronounced in aquatic ecosystems that are already 

subject to other environmental stressors such as high biochemical oxygen demand (BOD) levels, 

sediment contamination, or pathogens. Thermal discharges may have indirect effects on fish and 

other vertebrate populations through increasing pathogen growth and infection rates. Langford 

(1990) reviewed several studies on disease incidence and temperature, and while he found no 

simple, causal relationship between the two, he did note that it was clear that warmer water 

enhances the growth rates and survival of pathogens, and that infection rates tended to be lower in 

cooler waters.
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The magnitude of thermal effects on ecosystem services is related to facility-specific factors,

including the volume of the waterbody from which cooling water is withdrawn and returned, 

other heat loads, the rate of water exchange, the presence of nearby refugia, and the assemblage 

of nearby fish species. In addition to reducing total IM&E, cooling towers reduce thermal

pollution. Consequently, the installation of closed-system cooling towers could have 

geographically variable effects on ecosystems, ranging from comprehensive changes in 

community structure and habitat type (Schiel et al. 2004), to localized changes in the relative 

proportion of species adapted to warm and cold water (Millstone Environmental Laboratory 

2009). Further information on thermal discharges is provided in Appendix B.

2.3.4 Chemical Effects

One of the environmental impacts associated with operation of electric generators is the release of 

chemicals in the discharge of once-through cooling water. These chemicals include metals from 

internal corrosion of pipes, valves and pumps (e.g., chromium, copper, iron, nickel, and zinc), 

additives (anti-fouling, anti-corrosion, and anti-scaling agents) and their byproducts, and 

materials from boiler blowdown and cleaning cycles. 

EPA used the Discharge Monitoring Report Pollutant Loading Tool (DMR-PLT)6to obtain 

estimated annual pollutant loadings for regulated facilities. EPA extracted data for all regulated 

facilities (excluding those designated as baseline closures) by querying on a facility’s NPDES 

permit identification number. Of the 739 regulated facilities (excluding baseline closures), 569 

have annual loading estimates in DMR-PLT; of these, nearly 75 percent are electric power 

generators. Table 2-5 lists the top 20 pollutants discharged by regulated facilities in 2011, sorted 

by mass. These chemicals represent pollutants generated by the operation and maintenance of the 

facility and other location-specific activities. The most common pollutants include: total 

dissolved solids, calcium carbonate, sulfate, chloride and fecal coliform.

In addition to these pollutants, facilities also discharge anti-fouling agents. Biofouling is a serious 

operational concern for facilities. Microbial biofouling on surfaces in cooling water systems can 

accelerate metal corrosion, increase resistance to heat transfer energy, and increase fluid frictional 

resistance (Cloete et al. 1998). Sessile macrofouling-organisms such as algae, insects, hydroids, 

polychaetes, barnacles, mussels and tunicates can colonize intake pipes, bulkheads, and filter 

screens, and may clog pipes and reduce intake flows or filter-screen effectiveness. Further, some 

of these infestations produce larvae, which can colonize downstream equipment including 

pipelines, valves, and heat exchangers. Severe macrofouling-associated problems can include 

intake flow reduction, increased pressure drop across heat exchangers, and equipment breakdown.

 

6 The Discharge Monitoring Report (DMR) Pollutant Loading Tool calculates pollutant loadings from EPA’s 

Permit Compliance System (PCS) and Integrated Compliance Information System for the National Pollutant 

Discharge Elimination System (ICIS-NPDES) as well as wastewater pollutant discharge data from EPA’s Toxics 

Release Inventory (TRI). Data is currently available for the years 2007 through 2011.
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Table 2-5: Top 20 Pollutants Discharged by Regulated Facilities, by 

Total Annual Loadings (2011)

Parameter Number of

facilities

Total Loading

(million lbs/yr)

1 Solids, total dissolved 42 18,508.3

2 Hardness, total (as CaCO3) 31 1,548.5

3 Solids, total suspended 487 651.0

4 Coliform, fecal general 82 535.3

5 Residue, total filterable (dried at 105 C) 8 524.3

6 Sulfate, total (as SO4) 52 485.1

7 Chloride (as Cl) 53 440.3

8 Nickel, total recoverable 41 395.4

9 Selenium, total recoverable 51 262.6

10 Lead, total recoverable 47 251.2

11 Chromium, total recoverable 27 224.7

12 Chromium, trivalent total recoverable 4 217.7

13 Sulfate 11 178.6

14 Cadmium, total recoverable 32 165.6

15 Solids, total dissolved- 180 deg. C 7 127.7

16 Calcium Chloride 1 106.9

17 Chemical Oxygen Demand (COD) 35 105.9

18 Solids, total dissolved (TDS) 3 102.1

19 Chromium, hexavalent dissolved (as Cr) 14 97.4

20 Antimony, total (as Sb) 12 81.9

Source: Discharge Monitoring Report Pollutant Loading Tool (DMR-PLT)

These anti-fouling and cleaning chemicals potentially pose a risk to organisms downstream of the 

CWIS discharge. Adverse effects to aquatic organisms may include acute and residual effects of 

biocides used as anti-fouling agents in condenser tubes, or from chemicals resulting from 

corrosion or use in cleaning of either stream or cooling cycles (Kelso and Milburn 1979). A 

typical biofouling procedure is continuous low-level chlorination at chronic toxicity levels with 

an occasional high (“shock”) dose. The use of oxidants (chlorine, bromide) can give rise to 

residuals and/or disinfection byproducts (DBPs) such as trihalomethanes, haloacetic acid, 

bromoform, and others (Taylor 2006). Concentrations of released chemicals are variable among 

facilities, and are a function of treatment dose, CWIS design, rates of degradation, and the 

volume and flushing rate of the receiving water.

With the exception of chlorination impacts (Taylor 2006), the potential effects of chemicals in 

facilities’ cooling water discharges on local aquatic ecosystems are not well-characterized. In 

most cases, chemical effects are considered, along with thermal and mechanical effects, as a 

component of the cumulative stress of entrainment on organisms. Little information is available 

on the chronic or low-level effects of these discharge chemicals on local ecosystems or in concert 

with other anthropogenic stressors. 

Review of the effects of chemical treatment and discharge into the environment suggests that 

direct ecotoxicity in discharge plumes is relatively rare beyond the point of discharge or mixing 

zone near the pipe outlet (Poornima et al. 2005; Taylor 2006). However, concentrations of these 

chemicals may be additive to low-level chronic adverse effect with other anthropogenic stressors 

identified above.
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2.3.5 Effects of Flow Alteration

The operation of CWIS and discharge returns significantly alter patterns of flow within receiving 

waters both in the immediate area of the CWIS intake and discharge pipe, and in mainstream 

waterbodies, particularly in inland riverine settings. In ecosystems with strongly delineated 

boundaries (i.e., rivers, lakes, enclosed bays, etc.), CWIS may withdraw and subsequently return 

a substantial proportion of water available to the ecosystem. For example, of the 435 facilities 

that are located on freshwater streams or rivers, 30 percent (132) of these facilities have average 

actual intake flow that is greater than 5 percent of the mean annual flow of the source waters.7

Even in situations where the volume of water downstream of regulated facilities changes 

relatively little, the flow characteristics of the waterbody, including turbulence and water 

velocity, may be significantly altered. This is particularly true in locations with multiple CWIS

located close to each other. 

Altered flow velocities and turbulence may lead to several changes in the physical environment, 

including sediment deposition (Hoyal et al. 1995), sediment transport (Bennett and Best 1995), 

and turbidity (Sumer et al. 1996), each of which play a role in the physical structuring of 

ecosystems. Biologically, flow velocity is a dominant controlling factor in aquatic ecosystems. 

Flow has been shown to alter feeding rates, settlement and recruitment rates (Abelson and Denny 

1997), bioturbation activity (Biles et al. 2003), growth rates (Eckman and Duggins 1993), and 

population dynamics (Sanford et al. 1994).

In addition to flow rates, turbulence plays an important role in the ecology of small organisms, 

including fish eggs and larvae, phytoplankton, and zooplankton. In many cases, the turbulence of 

a waterbody directly affects the behavior of aquatic organisms, including fish, with respect to 

swimming speed (Lupandin 2005), location preference with a waterbody (Liao 2007), predatorprey interactions (Caparroy et al. 1998; MacKenzie and Kiorboe 2000), recruitment rates

(MacKenzie 2000; Mullineaux and Garland 1993), and the metabolic costs of locomotion (Enders 

et al. 2003). The sum of these effects may result in changes to the food web or the location of 

used habitat, and thereby substantially alter the aquatic environment.

Climate change is predicted to have variable effects on future river discharge in different regions 

of the United States, with some rivers expected to have large increases in flood flows while other 

basins will experience water stress. For example, Palmer et al. (2008) predict that mean annual 

river discharge is expected to increase by about 20 percent in the Potomac and Hudson River 

basins but to decrease by about 20 percent in Oregon's Klamath River and California's 

Sacramento River. Thus, the adverse effects of flow alteration may increase or decrease over 

longer periods for larger rivers, depending on their geographic location. 

2.4 Community-level or Indirect Effects of CWIS

In addition to the direct effects of CWIS, IM&E may alter a wide range of aquatic ecosystem 

functions and services at the community-level (Table 2-4). Most of these impacts on aquatic 

community function and service are poorly characterized, given the limited scope of IM&E

studies and an incomplete knowledge of baseline or pre-operational conditions within affected 

waters.

 

7

Facility counts exclude baseline closures.
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For example, fish are essential for energy transfer in aquatic food webs (Summers 1989), and for 

the regulation of food web structure. Fish play important roles in nutrient cycling (Wilson et al. 

2009) and sediment processes, and are known to play key roles in the maintenance of aquatic 

biodiversity (Holmlund and Hammer 1999; Peterson and Lubchenco 1997; Postel and Carpenter 

1997; Wilson and Carpenter 1999).

While IM&E of commercially or recreationally important fish species can be quantified and 

monetized (Chapters 6 and 7), the accompanying loss of other aquatic organisms may be poorly 

characterized (e.g., lumped into broad taxa such as “forage fish” or “other”) or simply not 

reported. In addition, IM&E on species of lower concern may create unrealized ripples of 

ecological effect within the aquatic community. Species may respond to altered ecological 

circumstances such as reduced predation, altered food concentrations, or slower nutrient 

recycling, etc. Therefore, the removal of selected fish species or considerable biomass by IM&E

may substantially affect these processes. 

Several examples of ecological services indirectly affected by IM&E are described below, 

although others listed in Table 2-4 may be of equal importance for individual ecosystems.

2.4.1 Altered Community Structure and Patchy Distribution of Species

The role of some aquatic species may be more critical in shaping the structure and composition of 

the community than that of others. These keystone species are species that have an effect on 

community structure disproportionate to their population (Paine 1966; Paine 1969). 

Consequently, the loss or reduction of keystone species may lead to substantial changes in aquatic 

food webs, and decrease overall ecosystem stability. Thus, the potential for ecosystem impacts 

resulting from, for example, the loss of an important predator fish due to IM&E may not be 

strictly proportional to the number or biomass of lost fish or foregone fish production. 

The operation of CWIS by generating facilities can lead to localized areas of depressed fish and 

shellfish abundance. Facilities (and the intake volume they represent) are distributed in a nonuniform manner along coastlines and rivers, and may be clustered (Section 2.5), such that IM&E

and the populations they affect are geographically heterogeneous. This can result in a highly 

localized and patchy distribution of aquatic organisms in regional areas. A secondary effect is 

increased probability of colonization and establishment by NIS due to niche space availability 

caused by a local reduction in the density of native organisms (Byrnes et al. 2007; Ovaskainen 

and Cornell 2006).

2.4.2 Altered Food Webs

Sources of mortality, including IM&E, may disrupt established predator-prey relationships and 

the niche space available to species through direct pathways (i.e., mortality of the organism) or 

indirectly (i.e., alterations to the food web). The loss of young-of-year (YOY) predators (e.g., 

striped bass) or important forage fish (e.g., menhaden and bay anchovy) is likely to affect trophic 

relationships and alter food webs. These changes may alter the realized species niche and life 

history traits due to alterations in inter- and intra-specific interactions (e.g., predator-prey, 

competition, mate selection, etc.) (Fortier and Harris 1989; Hixon and Jones 2005; Jirotkul 1999). 

These alterations in trophic interactions and food webs, combined with other CWIS-related 

impacts such as thermal pollution (Section 2.2.3) or flow alteration (Section 2.3.5), may lead to 

rapid changes in life history strategies as a consequence of facultative (Ball and Baker 1996) or 

evolutionary changes (Hairston et al. 2005; Reznick and Endler 1982).
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2.4.3 Reduced Taxa and Genetic Diversity

IM&E may lead to reductions in local community biodiversity (due to destruction of selected 

species) or in a loss of genetic diversity in individual fish populations. IM&E represents a novel 

selective pressure on early life stages that may reduce the genetic diversity of resident fish and 

prevent the recovery of depleted stocks (Stockwell et al. 2003; Swain et al. 2007; Walsh et al. 

2006). Because many populations stocks are differentiated by oceanic region and/or timing of 

migratory movements, IM&E could alter the seasonal timing and movement (i.e., phenology) of 

overall fish populations, which could have ramifications for predator species. 

2.4.4 Nutrient Cycling Effects

IM&E impacts may alter the pace of nutrient cycling, and energy transfer through food webs. 

Fish species have been shown to have substantial effects on nitrogen, phosphorous, and carbon 

cycling due to storage effects (i.e., large quantities of nutrients are found within fish biomass) and 

translocation effects (i.e., fish migrate, moving large quantities of nutrients to new ecosystems) 

(Kitchell et al. 1979; Vanni et al. 1997). These alterations in nutrient cycling could lead to 

redirection of nutrient flows to other components of the ecosystem including water column 

phytoplankton, benthic macroalgae and attached epiphytes, with subsequent changes to the 

condition of critical ecosystem habitats, such as submerged aquatic vegetation. Juvenile Atlantic 

menhaden (Brevoortia tyrannus) are capable of significantly grazing down plankton 

concentrations in Chesapeake Bay, leading to more-rapid regeneration of nutrients and enhanced 

primary production. Removal of juvenile menhaden by IM&E would lead to reduced grazing and 

turnover of nutrients and increased algal density in the water column (Gottlieb 1998). The amount 

of nitrogen and phosphorus regenerated in facility discharge water due to nutrient recycling of 

IM&E biota might also lead to areas of localized nutrient enrichment near outfalls (Abt 

Associates 2010a). Additionally, the preferential removal of upper water column species by 

IM&E could increase energy flow to benthic organisms, and thereby increase the relative 

importance of detritivores in bottom communities.

2.4.5 Reduced Ecological Resistance

The effect of long-term or chronic IM&E may lead to a decrease in ecosystem resistance and 

resilience (i.e., ability to resist and recover from disturbance including invasive species) (Folke et 

al. 2004; Gunderson 2000). That is, IM&E is likely to reduce the ability of ecosystems to 

withstand and recover from adverse environmental impacts, whether those impacts are due to 

anthropogenic effects or natural variability. 

2.5 Cumulative Impacts of Multiple Facilities 

Cumulative effects of CWIS are likely to occur if multiple facilities are located in close proximity 

such that they impinge or entrain aquatic organisms within the same source waterbody, watershed 

system, or along a migratory pathway of a specific species (e.g., striped bass in the Hudson River) 

(USEPA 2004a). The cumulative impacts of CWIS may be exacerbated by the presence of other 

anthropogenic stressors discussed above (Section 2.2).

EPA analyses suggest that approximately 20 percent of all regulated facilities are located on 

waterbodies with multiple CWIS (USEPA 2004a). Inspection of geographic locations of 

regulated facilities (approximated by CWIS latitude and longitude) indicates that facilities in 
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inland settings are clustered around rivers to a greater extent than marine and estuarine facilities 

(see Figure 2-1). 

2.5.1 Clustering of Facilities and CWIS on Major Rivers

To illustrate the potential for cumulative impacts, EPA reviewed data from five major U.S. rivers 

with clustered concentrations of facilities. Table 2-6 summarizes average annual river flow and 

facility DIF and actual intake flow (AIF). Based on the non-uniform distribution of facilities, 

locations were noted where the potential for cumulative impacts is high (Abt Associates 2010b). 

Table 2-6: U.S. Rivers with Largest Withdrawals by Regulated Facilities

River Avg. Annuala

Flow (mgd) Facilities CumulativeDIF (mgd)

DIF as % Avg. 

Annual Flow

Cumulative

AIF (mgd)

AIF as % 

Avg. Annual 

Flow

Mississippi 383,266 57 22,436 5.9 13,170 3.4

Ohio 181,615 47 19,315 10.6 13,384 7.4

Missouri 49,249 23 10,718 21.8 6,598 13.4

Illinois 8,079 11 6,259 77.5 1,605 19.9

Delaware 7,562 11 3,585 47.4 1,485 19.6

Sources: USGS 1990 and U.S. EPA analysis for this report

For example, the Mississippi River provides source water for cooling water for 57 facilities along 

its length,8 with 27 facilities located in Louisiana upstream of the Mississippi River delta. Using 

facility intake coordinates as location markers, the relative distances between facilities were 

estimated (Abt Associates 2010b). In upper Louisiana, facilities are typically separated by tens of 

miles; inter-facility distance decreases downstream of Baton Rouge, LA. Several locations along 

the Mississippi River have clusters of facilities:

 Between Ascension and St. James Parishes, a 13-mile span of the river hosts six 

manufacturing facilities, three of which have intakes located within the same mile. These 

facilities have a combined DIF of nearly 270 mgd.

 Fifteen miles downstream, near Garyville, LA, there is a cluster of three facilities within 

six miles of the river stretch.

 Seven miles further downstream near Laplace, LA, six facilities are located on a six-mile 

stretch of the river. Four of these facilities, with a combined DIF exceeding 5 billion 

gallons per day (bgd) (three generators and one manufacturer), are located within a 1.7 

mile section of river.

 Further downstream in Chalmette, LA (just east of New Orleans), three manufacturers, 

capable of withdrawing up to 457 mgd, are clustered within four river miles. 

Therefore, the potential for cumulative impacts is high, and investigating ecosystem effects by 

extrapolating results on a per facility basis is likely to underestimate the true effects.

 

8 This total excludes one facility that EPA projects as baseline closure.
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2.5.2 Implications of Clustered Facilities for Cumulative Impacts

The cumulative impact of clustered facilities may be significant, due to the concentrated IM&E, 

combined intake flows, and the potential for other impacts such as thermal discharges. It should 

also be noted that power generation demand and cooling intake water volume are typically at 

their annual maximum during mid-late summer, which is also a period of seasonal low flows and 

highest in-stream temperatures. The effect of cumulative impacts may be greater in inland or 

Great Lakes waters due to the following factors:

 The majority of national AIF is associated with freshwater CWIS.

 Freshwater facilities use a greater relative volume of available fish habitat than marine or 

estuarine counterparts.

 Seasonal variation in power demand and river flow may increase entrainment potential 

during low-flow periods of the year (NETL 2009). Although low flows are traditionally 

in late summer to early fall, drought conditions and manipulations of water levels may 

lead to low flow during other periods. This may be locally significant if periods of low 

flow overlap with seasonal concentrations of eggs, developing YOY, and migrating 

juveniles.

 Freshwater facilities are more likely to be clustered along a waterbody, and pose a greater 

risk of cumulative impacts. This is exacerbated by the presence of numerous 

impoundments associated with navigational lock and dam structures located on larger 

rivers (e.g., Mississippi, Missouri, Ohio, etc). These impoundments result in slow or 

slack water conditions with a lower effective volume than free-flowing reaches or periods 

of higher flow. 

2.6 Case Studies of Facility IM&E Impacts

While the information provided in this chapter provides a broad overview of potential impacts 

associated with CWIS, it is highly informative to evaluate these impacts in the context of actual 

facilities to see how and to what extent these impacts and IM&E are realized, how site-specific 

factors come into play, the effects of cumulative impacts, and what has been learned with regard 

to community-level effects. Case studies provide useful, detailed information for evaluating 

IM&E and major stressors in the context of a specific waterbody or region.

As part of the Phase II regulations, review and analyses of IM&E data and environmental 

information were presented in comprehensive case studies in EPA’s 2002 Case Study Analysis 

for the Proposed Section 316(b) Phase II Existing Facilities Rule (USEPA 2002a). The document 

provided detailed analyses of CWIS impacts in major regional waterbodies throughout the United 

States. These cases studies included:

 Delaware Estuary Watershed: a regional assessment of the impacts of 7 generating and 6 

manufacturing facilities in the transition zone of the Delaware River Estuary. The 

estuary’s transition zone was chosen due to its biological, recreational, and economic 

importance, and because of the high concentration of CWIS.

 Ohio River Watershed: a detailed assessment of the impacts of 9 (of 29) facilities in a 

500-mile stretch of the Ohio River between the McAlpine and New Cumberland pools, 

this case study is representative of a large industrial river.
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 Tampa Bay Watershed: highlighted as a representative of the Southeast Atlantic and Gulf 

coasts, this case study included four of eight facilities in watersheds draining into Tampa 

Bay.

 San Francisco Bay/Delta Estuary: included as representative of an urban estuary, and a 

waterbody containing several T&E species, this case study highlighted the effects of two 

large generating facilities.

 Brayton Point Facility: a case study of a single facility and its impacts on a confined 

waterbody.

 Seabrook and Pilgrim Facilities: with a pair of facilities located in the same ecological 

region, but with very different CWIS placements, this case study highlights the potential 

effects of CWIS location of IM&E impacts.

 J.R. Whiting Facility: an assessment of the before and after effects of the installation of a 

deterrent net on IM&E for a representative facility on the Great Lakes.

 Monroe Facility: located nearby the J.R. Whiting facility (above), the Monroe facility 

case study provides an estimate of the effects of IM&E on Great Lakes facilities.

These regional case studies provide a set of information describing the variety of CWIS impacts 

under marine, coastal, and riverine environmental settings. The following sections present three 

additional case studies to provide examples of facility-specific CWIS impacts in settings 

including freshwater coastal (Bay Shore, Oregon, OH), estuarine (Indian Point, Buchanan, NY), 

and estuarine-coastal (Indian River, Sussex County, DE) environments. These brief case studies 

also illustrate the quantitative levels of IM&E, the indirect effects of IM&E on local aquatic 

ecosystems, and the cumulative effects of combined effects (IM&E and thermal).

2.6.1 Bay Shore Power Station 

The Bay Shore power station is a 631 megawatt (MW) facility located on the south shore of Lake 

Erie near the confluence of the Maumee River and Maumee Bay, OH. Cooling water for the four 

coal-fired steam-electric units is withdrawn from Maumee River/Maumee Bay via an open intake 

channel of approximately 3,700 ft in length, and enters the facility via a shoreline surface CWIS. 

Approximately 749 million gallons per day (mgd) are withdrawn, including once-through cooling 

water and sluice water used for transporting bottom ash from the boilers to ash settling ponds 

(OEPA 2010). Major environmental concerns for the facility include IM&E and thermal impacts. 

Bay Shore Power Station IM&E: Medium-sized Plant with Large-Scale Impacts:

A comprehensive demonstration study, conducted in 2005-2006, estimated annual impingement 

at greater than 46 million fish per year, the majority of which were forage fish species—emerald 

shiner and gizzard shad. Annual estimates for entrainment were equally impressive—209 million 

fish eggs, 2,247 million fish larvae, and 14 million juvenile fish (OEPA 2010). As noted on the 

NDPES fact sheet, “It is likely that Bay Shore Station impinges and entrains more fish than all 

other power stations in Ohio combined.” Notably, the facility does not currently employ 

technologies to reduce IM&E (OEPA 2010).

In addition to IM&E effects, concerns have also been raised regarding the size and impact of the 

thermal discharge plume—a focus of concern for local residents and commercial fishermen. 

Depending on wind patterns and hydrological factors, the thermal plume extends to the south 
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shore of Maumee Bay (over 1 mile from the facility). The Ohio Environmental Protection 

Agency (OEPA) assessed the results from a 2002 thermal mixing zone study, and concluded that 

the thermal discharge exceeded Ohio water quality standards for temperature within the thermal 

plume (>85oF in Maumee Bay), but that the impacts on aquatic life and designated uses in 

Maumee River/Bay did not justify reduction of the thermal mixing zone. However, it did find that 

the thermal activity could restrict recreational activities in certain areas of the facility and 

required the facility owners to conduct a two-year study of the benthic community within the 

mixing zone (OEPA 2010).

2.6.2 Indian Point Nuclear Power Plant 

The Indian Point nuclear power plant is a 2,045 MW facility located in Buchanan, Westchester 

County, New York, on the east shoreline of the Hudson River. Cooling water (up to 2,500 mgd) 

for the two nuclear-fired steam-electric units (Units 2 and 3) is withdrawn from the estuarine 

portion of the Hudson River through three intake structures on the shoreline (NYSDEC 2003a). 

The heated non-contact cooling water is discharged through sub-surface diffuser ports in a 

discharge canal located downstream of the intake structures. 

Concerns regarding impact to fish, particularly anadromous striped bass populations, as well as a 

high level of involvement and litigation from local stakeholder groups, have made the Indian 

Point power generation plant (along with other Hudson River facilities) particularly wellcharacterized in terms of IM&E impacts. Accordingly, the Hudson River aquatic community has 

been sampled and studied over many decades, with detailed investigation starting in the 1970s. 

Results suggest that IM&E impacts to the local and transient anadramous fish species are 

substantial. For example, studies of fish entrainment in 1980 predicted fish class reductions 

ranging from 6 to 79 percent, depending on fish species (Boreman and Goodyear 1988). 

Subsequent sampling work predicted year-class reductions due to IM&E of 20 percent for striped 

bass, 25 percent for bay anchovy, and 43 percent for Atlantic tomcod. The Final Environmental 

Impact Statement (FEIS) prepared by the New York State Department of Environmental 

Conservation (NYSDEC) concluded these levels of mortality “could seriously deplete any 

resilience or compensatory capacity of the species needed to survive unfavorable environmental 

conditions” (USEPA 2006a).

Indian Point Final Environmental Impact Statement (FEIS) details cumulative effects:

The FEIS estimated, from samples collected between 1981 and 1987 for three facilities (Indian 

Point, Roseton, Bowline Point), that average annual entrainment included 16.9 million American 

shad, 303.4 million striped bass, 409.6 million bay anchovy, 468 million white perch, and 826.2 

million river herring (NYSDEC 2003b). The loss of such large numbers of forage fish species and 

the potential impact on higher level piscivores is of high concern. The FEIS also viewed the 

overall effect of the CWIS impacts on the aquatic community as analogous to habitat degradation 

rather than overfishing. This judgment was based on evidence that the entire aquatic community 

was affected rather than only specimens of higher trophic level species. 

The FEIS considered the role of other major environmental factors currently or historically 

present in the Hudson River. These factors have the capacity to affect fish populations either 

positively (enhancements) or negatively (stressors). Relevant factors include, but are not limited 

to: improvements to water quality due to upgrades to sewage treatment facilities, invasions by 

exotic species (e.g., zebra mussel), chemical contamination by toxins (e.g., PCBs and heavy 
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metals), global climate shifts such as increases in annual mean temperatures and higher 

frequencies of extreme weather events (e.g., the El Nino-Southern Oscillation), and stricter 

management of individual species stocks such as striped bass (USEPA 2006a).

In April 2010, the NYSDEC denied a request by Indian Point for a CWA section 401Water 

Quality Certificate. The CWA requires that, prior to any federal agency issuing a license or 

permit for a particular project (in this case, the approval of the State Discharges Permit 

Elimination System [SPDES] permit), it must certify that the project meets State water quality 

standards. The NYSDEC denial letter cited, among other concerns, continuing concerns over 

IM&E including potential impacts to two species protected under the Endangered Species Act 

(ESA) —the Shortnose Sturgeon (endangered) and the Atlantic Sturgeon (endangered). 

2.6.3 Indian River Power Plant 

The Indian River Generating Station (IRGS) is a 784 MW facility located in Sussex County, 

Delaware, on the south shore of the Indian River. Cooling water for three of the IRGS’s four 

coal-fired steam-electric units is withdrawn upstream from the freshwater portion of Indian River 

via an intake canal at a maximum rate of 411 mgd, or 21 times the average flow rate of Indian 

River. Heated return water is discharged via a canal into the upper reaches of Island Creek, a 

small tributary of Indian River, entering at Ward Cove. Island Creek and Ward Cove are part of a 

large estuarine stretch (approximately 150 acres) of Indian River that provides important fish and 

crab habitat. Its lower salinity and location in the estuary make it attractive to important species 

such as bay anchovy, spot, menhaden larvae, and young blue crabs. 

Indian River Power Plant has impact on important local species:

The 2003 316(b) Comprehensive Demonstration Study for the Indian River Power Plant reported 

IM&E for a number of important species (Entrix 2003, as described in Bason 2008). This IM&E 

has been recalculated by a local stakeholder group as A1E for bay anchovy (1.6 million), blue 

crab (300,000), croaker (270,000), and menhaden (60,000) (Bason 2008). 

Due to the size of the heated discharge relative to the receiving water, thermal effects of the 

facility were also investigated. Based upon monitoring data collected from 1998 to 1999, the 

316(a) report assessed the effects of elevated water temperatures on ecosystem communities with 

a focus on eight important fish species: bay anchovy, menhaden, winter and summer flounder, 

croaker, spot, striped bass, and weakfish. This report determined that juvenile and adult target 

species, although able to avoid areas of high water temperature, were not permanently restricted 

from most stretches of the Indian River, nor did they suffer loss of habitat services associated 

with these segments. The study concluded an overall condition of no adverse effect, or no 

appreciable harm, on the fish and shellfish populations in the Indian River and Delaware Bay 

(Entrix 2001). 

Despite the overall conclusion of no adverse effect, the report documented localized thermal 

impacts of consequence. For example, during warmer months, the thermal discharge reached 

potential adverse levels in Island Creek, often extending downstream to Ware Cove (Entrix 

2001). The mortality associated with sub-adult stages of fish and crabs and the avoidance of the 

area by sub-adult and adult fish were substantial issues. In addition to direct thermal impacts to 

biota, temperature-related reductions in DO were observable (mean reduction = 0.6 mg/l) in the 

discharge canal. These reductions contributed to the amplitude of the day-night (diel) cycle of DO 
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concentrations, already widely fluctuating due to cumulative effects of eutrophication in the river 

(Bason 2008). 

2.7 Conclusions 

Considerable information is available on the direct effects of CWIS and IM&E (Chapter 3) on

commercially (Chapter 6) and recreationally important (Chapter 7) species derived from the 

accumulated data from facility-specific basis 316(b) studies and investigations. This information 

allowed EPA to monetize the potential commercial and recreational fishing benefits for the final 

rule and other options EPA considered. However, as demonstrated in this section, much less 

information and high uncertainty exist regarding the magnitude and importance of indirect and/or 

cumulative impacts of CWIS, particularly effects on lower trophic organisms or ecosystem 

functions. This condition is due to the limitations of 316(b) sampling programs, as well as the 

failure of permitting process to consider the additive or cumulative effects of other major 

anthropogenic stressors. While EPA can identify and hypothesize regarding the direction and 

relative importance of impacts of CWIS on the totality of the aquatic ecosystem (i.e., not just 

focused on selected higher trophic level predator species and common prey), EPA is currently 

unable to connect these effects with quantifiable environmental benefits. Thus, it is highly likely 

that the total environmental and monetary impacts of CWIS are significantly underestimated, and 

that characterization of the fuller spectrum of benefits arising from reducing or eliminating IM&E 

will await future, targeted research efforts.
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3 Assessment of Impingement and Entrainment Mortality

3.1 Introduction

This chapter discusses the methods EPA used to convert results from IM&E sampling studies into metrics 

suitable as inputs for EPA’s section 316(b) benefits analysis.9Section 3.2 provides a brief overview of 

IM&E metrics, and outlines how they were used in the benefits analysis. Section 3.3 presents IM&E, by 

region, under baseline conditions, and the reductions in these losses under alternative regulatory options. 

Section 3.4 discusses limitations and uncertainties in the IM&E analysis. 

EPA’s IM&E assessment methods are discussed in detail in Chapter A-1 of the Regional Benefits 

Analysis for the Final Section 316(b) Phase III Existing Facilities Rule (Regional Benefits Analysis) 

(USEPA 2006b). Changes in methodology since EPA’s Phase III analysis include: (1) the addition of new 

IM&E data for several California facilities, (2) engineering reductions for power generators were 

estimated for sample facilities that received the detailed questionnaire rather than for all regulated

generators, and (3) estimated changes in the proportionate reduction in IM&E under the final rule and 

Proposal Options 2 and 4. Other modifications are identified in relevant portions of Section 3.2.

3.2 Methods

3.2.1 Objectives of IM&E Analysis

EPA’s evaluation of IM&E data had four main objectives:

 To develop regional and national estimates of the magnitude of IM&E;

 To standardize IM&E using common biological metrics that allow comparison across species, 

years, facilities, and geographical regions;

 To provide IM&E metrics suitable for use in national economic benefits analysis; and,

 To estimate changes in metrics as a result of estimated reductions in IM&E under the final rule 

and Proposal Options 2 and 4.

EPA’s use of these methods for national rulemaking does not imply that these methods are the best or 

most suitable for studies of single facilities. In many cases, site-specific details on local fish populations 

and waterbody conditions may make other assessment approaches, such as population or ecosystem 

modeling, possible. 

3.2.2 IM&E Loss Metrics

Three loss metrics were derived from facility IM&E monitoring data available to EPA: (1) age-one

equivalents (A1E), (2) forgone fishery yield, and (3) production forgone. These metrics are described 

 

9

For the purposes of its national analysis, EPA assumed 100 percent entrainment mortality. This assumption is discussed at 

length in Chapter A7 of the Regional Analysis Document for the Final Section 316(b) Existing Facilities Rule (USEPA 

2004a). Briefly, EPA assessed 37 entrainment survival studies and found them variable, unpredictable, unreliable, and not 

defensible. As such, these studies support an assumption of 0 percent survival for entrained organisms in benefits 

assessments.
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briefly below. Equations used to calculate metrics and other details are provided in Chapter A-1 of EPA’s 

Regional Benefits Analysis (USEPA 2006b).

3.2.2.1 Age-One Equivalents

The Equivalent Adult Model (EAM) is a method for converting organisms of different ages (life stages) 

into an equivalent number of individuals in any single age (Goodyear 1978; Horst 1975). For its 316(b) 

analyses, EPA standardized all IM&E into equivalent numbers of 1-year-old fish, a value referred to as

A1Es. This conversion allows losses to be compared among species, years, facilities, and regions.

To conduct EAM calculations requires a life history schedule, for each species, incorporating age-specific 

mortality rates. Using these species-specific survival tables, a conversion rate between all life history 

stages and age 1 is calculated. For life history stages younger than 1 year of age, the conversion rate is 

calculated as the product of all stage-specific survival rates between the stage at which IM&E occurs and 

age 1. Consequently, the loss of an individual younger than age 1 results in a conversion rate less than 1. 

For individuals older than 1 year, the conversion rate is calculated as the quotient of all stage-specific 

survival rates between the stage at which IM&E occurs and age 1. Consequently, the loss of an individual 

older than age 1 results in a conversion rate greater than 1.

Additional details on the EAM calculation are provided in Chapter A-1 of EPA’s Regional Benefits 

Analysis (USEPA 2006b). For the results presented in this chapter, the treatment of early life stages in 

this calculation considers all larval life stages reported in the original IM&E studies.

3.2.2.2 Forgone Fishery Yield of Commercial and Recreational Species Recreational 

Fishery yield is a measure of the biomass harvested from a cohort of fish.10 EPA expressed IM&E of 

harvested species in terms of forgone (lost) fishery yield. To convert losses to forgone fishery yield, EPA 

used the Thompson-Bell equilibrium yield model (Ricker 1975) with the assumptions that 1) IM&E 

reduce the future yield of harvested adults, and 2) reductions in IM&E will lead to an increase in 

harvested biomass. 

The Thompson-Bell model is based on the principles used to estimate the expected yield in any harvested 

fish population (Hilborn and Walters 1992; Quinn and Deriso 1999). The general procedure involves 

multiplying age-specific harvest rates by age-specific weights to calculate an age-specific expected yield. 

The lifetime expected yield for a cohort of fish is the sum of all age-specific expected yields. Details of 

these calculations are provided in Chapter A-1 of EPA’s Regional Benefits Analysis (USEPA 2006b).

3.2.2.3 Production Forgone for All Species Recreational 

Production forgone is an estimate of the biomass that would have been produced had individuals not been 

impinged or entrained (Rago 1984). It is calculated for all forage species from species- and age-specific 

growth rates and survival probabilities. This forgone biomass represents a decrease in prey availability for 

predator species, and is calculated because IM&E for forage species are not included in the forgone 

fishery yield calculations. Additional details regarding the calculation of production forgone are provided 

in Chapter A-1 of EPA’s Regional Benefits Analysis (USEPA 2006b).

3.2.3 Valuation Approach 

EPA’s benefits analysis focused on increased commercial and recreational fishery harvests estimated 

from projected reductions in IM&E. For consistency with reported harvest data, commercial harvest is 

 

10 A cohort of fish refers to fish produced in the same year, also referred to as a year-class of fish.
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reported in pounds and recreational harvest is reported in numbers of fish. To project changes in fishery 

harvests, EPA integrated two components of fishery yield that change as a consequence of IM&E: direct 

contributions of commercially and recreationally harvested species (hereafter fishery species), and 

indirect contributions of forage species consumed by fishery species (Figure 3-1). The direct contribution 

of fishery species to yield (left side of Figure 3-1) is calculated by converting A1E mortality to forgone 

yield as described in Section 3.2.2. The contribution of forage species to fishery yield is measured as a 

biotic transfer of mass through the food web to fishery species that are subsequently harvested (right side 

of Figure 3-1). EPA used a simple trophic transfer model for this purpose (discussed in Chapter A-1 of 

EPA’s Regional Benefits Analysis (USEPA 2006b), assuming a trophic transfer efficiency of 0.10 (Pauly 

and Christensen 1995).

11 Trophic transfer efficiency represents the fraction of forage species biomass 

incorporated into predator (fishery) species biomass. EPA estimated total changes to commercial and 

recreational harvest yield as the sum of the contributions of fishery and forage species. For benefits 

analysis, total yield was separated into commercial and recreational fractions based on the proportion of 

harvest occurring within each type of fishery, and benefits were calculated for harvestable adult fish. 

Details of the commercial and recreational fishing benefits analysis are provided in Chapters 6 and 7 of 

this report, respectively. 

3.2.4 Rationale for EPA’s Approach to Valuation of IM&E

EPA’s approach to estimating changes in fish harvest assumed that IM&E result in a reduction in the 

number of harvestable adults, and that IM&E reductions result in increases to future fish harvests. This 

approach estimates incremental fishery yield forgone because of IM&E and does not require knowledge 

of population size or total yield of a fishery. 

EPA’s forgone fishery yield analysis requires species- and stage-specific schedules of natural mortality 

(M), fishing mortality (F), and weight-at-age. The yield model assumes that these key parameters (F, M, 

and weight-at-age) are independent of IM&E for all species. EPA recognizes that this assumption does 

not fully reflect the dynamic nature of fish populations. However, by conducting benefits analysis using 

estimates of forgone yield, EPA was able to use a simple and direct measure of the potential economic 

value associated with each IM&E-related death. Used of this approach was warranted given: (1) the scope 

and objectives of its analysis of harvested species, (2) data availability, and (3) difficulties in 

distinguishing the causes of population changes. Each of these factors is discussed below.

3.2.4.1 Scope and Objectives of EPA’s Analysis of Harvest Species

EPA’s overall objective was to develop regional- and national-scale estimates of the magnitude of IM&E

at hundreds of facilities subject to the final rule. As a consequence of the large geographic scope and 

multiple ecosystems involved, EPA modeled fishery yield using a relatively simplified approach to 

estimate the vulnerability of dozens of species to IM&E on a national scale. Although sufficient data may 

exist to model the effects of IM&E on population and community-level impacts, sufficient data do not 

exist at the national scale to make such studies feasible.

 

11 EPA notes that its model of trophic transfer is a very simple and idealized representation of trophic dynamics; it is not 

intended to capture the details of trophic transfer in actual aquatic ecosystems. In reality, food webs and trophic dynamics 

are much more complex than EPA’s simple model implies, and include details that are specific to each particular aquatic 

ecosystem. This complexity was beyond the scope of EPA’s analysis and the available data.
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Figure 3-1: General Approach Used to Evaluate IM&E as Forgone Fishery Yield

3.2.4.2 Data Availability and Uncertainties Related to Modeling Fish Harvest

Forgone fishery yield and production forgone models used by EPA required age-specific life history data 

for all species analyzed. EPA acknowledges that many fish population models are available, and that 

these models may produce more accurate population-level impacts of IM&E. EPA did not pursue the 

development of species-specific population models for several reasons:

 Constructing population models requires a large set of parameters and numerous assumptions 

about the nature of stock dynamics for each species, including current stock size, stockrecruitment relationships, changes to growth and mortality rates as a function of stock size, and 

the separation of certain species into geographically based stock units. Because of these 

limitations, fewer than 40 percent of U.S.-managed commercially harvested fish stocks have been 

fully assessed (NMFS 2009; NMFS 2010a). As such, the information necessary to build morecomplex population models is available only for a subset of harvested species, which represent a 

minor fraction of IM&E. 
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 Numerous difficulties exist in the definition of the size and spatial extent of fish stocks. As a 

result, it is often unclear how IM&E at particular cooling water intake structures (CWIS) can be 

related to specific stocks at a regional scale. For example, juvenile Atlantic menhaden 

(Brevoortia tryannus) found in Delaware Bay recruit from both local and long distances (Light 

and Able 2003). As a result, estimating the effects of local IM&E on recruitment rates would not 

be sufficient to understand the stock-recruitment relationship for Delaware Bay menhaden. 

Consequently, issues of data availability and difficulties estimating the effects of localized IM&E on 

regional-scale fish stocks led EPA to determine that the construction of population models for all species 

subject to IM&E was not feasible. The level of uncertainty that would accompany the construction of 

such models (if constructing them were even possible) would be difficult to support with available data at 

both the national and population level for many species.

3.2.4.3 Difficulties Distinguishing Causes of Population Changes

It is fundamentally difficult to demonstrate a causal relationship between a single stressor and changes in 

fish population sizes. Fish populations are affected by multiple nonlinear stressors and are constantly in 

flux. As such, determining whether changes to fish populations are the consequence of an identifiable 

stressor due to natural fluctuation around an equilibrium stock size is difficult. Fish recruitment, the 

number of young fish surviving early life stages (e.g., egg, larvae, juvenile) to join an adult population, is 

a multidimensional process, and identifying and distinguishing the causes of variance in fish recruitment 

remains a fundamental problem in fisheries science, stock management, and impact assessment (Boreman 

2000; Hilborn and Walters 1992; Quinn and Deriso 1999). Consequently, resolving issues of population 

fluctuation was beyond the scope and objectives of EPA’s section 316(b) benefits analysis.

3.2.5 Extrapolation of IM&E to Develop Regional Estimates

EPA examined IM&E and the economic benefits of reducing these losses at a regional scale. EPA then 

aggregated estimated benefits across all regions to produce a national benefits estimate. Regions were 

based on regions used by fisheries management agencies such as the National Marine Fisheries Service 

(NMFS). The geographical scope of all regions is described in Chapter 1 (Section 1.2). 

To obtain regional IM&E estimates, EPA extrapolated losses observed at 98 facilities with IM&E data 

(hereafter model facilities) to all regulated facilities within the same region. Extrapolation of IM&E rates 

was necessary because only a subset of all regulated facilities have conducted IM&E studies. To allow 

extrapolation, EPA assumed that all facilities, regardless of size, have similar IM&E rates after 

normalization by flow. IM&E data were extrapolated on the basis of operational flow, in millions of 

gallons per day (mgd), where mgd is the average operational flow over the period 1996-1998 as reported 

by facilities in response to EPA’s Section 316(b) Detailed Questionnaire and Short Technical 

Questionnaire (USEPA 2000). Operational flow at all facilities was scaled using a multiplicative factor 

that reflected the effectiveness of in-place technologies used to reduce IM&E. During the extrapolation 

procedure, EPA also applied weighting factors to regulated facilities based on questionnaire results. 

Weighting factors for the current analysis were based on results of the Detailed Questionnaire. Additional 

details of EPA’s extrapolation methods are provided in Appendix A.

The assumption that IM&E is proportional to flow is consistent with other published IM&E studies and 

models. Power facilities on the Great Lakes exhibit an increasing relationship (on a log-log scale) 

between facility size (measured as electrical output) and IM&E rates (Kelso and Milburn 1979), and 

Goodyear (1978) predicted entrainment on the basis of the ratio of cooling water flow to source water 

flow. Additionally, the Spawning and Nursery Area of Consequence (SNAC) model, used as a screening 
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tool for assessing potential IM&E impacts at Chesapeake Bay facilities, assumes that entrainment is 

proportional to cooling water withdrawal rates (Polgar et al. 1979). 

EPA recognizes that actual IM&E per mgd may vary substantially, resulting from a variety of time- and 

facility-specific features, such as sampling date, location and type of intake structure, as well as from 

ecological features that affect the abundance and species composition of fish in the vicinity of each 

facility. Consequently, EPA’s extrapolation procedure relies heavily on the assumption that IM&E rates 

recorded at model facilities are representative of IM&E rates at other facilities in the region. Although 

this assumption may not be met in some cases, limiting the extrapolation procedure within regions 

reduces the likelihood that model facilities are unrepresentative. 

This method of extrapolation makes the best use of a limited amount of empirical data, and is the only 

feasible approach for developing a national estimate of IM&E, and the associated benefits of IM&E

reduction. While acknowledging that extrapolation introduces uncertainty into IM&E estimates, EPA has 

not identified information suggesting a systematic bias in regional loss estimates based upon 

extrapolation. 

3.3 IM&E by Region

3.3.1 California Region

Table 3-1 and Table 3-2 present estimated baseline IM&E and reductions in IM&E under the final rule 

and other options considered. Estimated total baseline IM&E in the California region is 51.55 million 

A1Es per year, of which 24.56 million (47.6 percent) are forage fish. Approximately 5.6 percent of total 

baseline A1E mortality is assigned a direct use value from recreational or commercial fishing (Table 3-1). 

Table 1 of Appendix C presents species-specific data on impingement and entrainment under the baseline 

conditions and estimated reductions under all options. Among commercially and recreationally-harvested 

species, the greatest losses occur in crabs, rockfishes, and sea basses (Appendix Table C-1). 

The majority of IM&E in the California region occur due to entrainment (Appendix C Table 1). Because

the final rule and Proposal Option 4 do not reduce entrainment, they each reduce baseline A1E mortality

by only 1.4 percent (0.73/51.55) and 1.3 percent (0.68/51.55), respectively (Table 3-1). Conversely, by 

requiring the installation of closed-cycle recirculating systems, which effectively reduce entrainment 

mortality, Proposal Option 2 reduces A1E mortality by 61.1 percent (31.52/51.55), providing more than

40 times the reduction in A1E mortality (Table 3-1). 

Table 3-1: Summary of Baseline IM&E at All Regulated facilities (Manufacturing 

and Generating) in California, and Reductions Under the Final Rule and Other 

Options Considered

IM&E Loss Metric (per year)

Reductions in Losses Baseline 

Losses Proposal 

Option 4

Final

Rule

Proposal 

Option 2

All Species (million A1E) 0.68 0.73 31.52 51.55

Forage Species (million A1E) 0.17 0.18 15.00 24.56

Commercial & Recreational Species (million A1E) 0.50 0.54 16.52 26.98

Commercial & Recreational Harvest (million fish) 0.05 0.06 1.76 2.88

A1E Losses with Direct Use Value (%) 8.0% 8.0% 5.6% 5.6%

Source: U.S. EPA analysis for this report
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Production forgone due to baseline IM&E is estimated to be 19.65 million pounds of fish, leading to a 

decrease in fishery yield of 4.59 million pounds per year (Table 3-2). The final rule is estimated to result 

in increased fishery yields of 0.02 million pounds per year. Increases in fishery yields under other options 

considered range from 0.02 million pounds per year under Proposal Option 4 to 2.80 million pounds per 

year under Proposal Option 2. Estimated increases in fishery yields under Proposal Option 2 are more 

than 100 times greater than under the final rule and Proposal Option 4 (Table 3-2). 

Table 3-2: Baseline Losses in Fishery Yield, Catch, and Production 

Forgone as a Consequence of IM&E at All Regulated facilities 

(Manufacturing and Generating) in California, and Reductions Under 

the Final Rule and Other Options Considered

IM&E Loss Metric (million per year)

Reductions in Losses Baseline 

Losses Proposal 

Option 4

Final

Rule

Proposal 

Option 2

Forgone Fishery Yield (lbs) 0.02 0.02 2.80 4.59

Forgone Commercial Catch (lbs) <0.01 <0.01 1.18 1.93

Forgone Recreational Catch (fish) 0.04 0.04 0.88 1.43

Production Forgone (lbs) 0.09 0.10 12.00 19.65

Source: U.S. EPA analysis for this report

Raw numbers of IM&E in California can be found in Appendix Table C-2.

3.3.2 North Atlantic Region

Table 3-3 and Table 3-4 present estimated baseline IM&E and reductions in IM&E under the final rule 

and other options considered. Estimated total baseline IM&E in the North Atlantic region is 57.86 million 

A1Es per year, 78.4 percent (45.34 million) of which are forage fish. Approximately 2.1 percent of total 

baseline A1E mortality is assigned a direct use value from recreational or commercial fishing (Table 3-3). 

Table 3 of Appendix C presents species-specific data on impingement and entrainment under the baseline 

conditions and estimated reductions under all options. Briefly, the vast majority (99.0 percent) of all A1E 

mortality in the North Atlantic occur as a consequence of entrainment mortality (Appendix Table C-3). 

Notably, the combined IM&E of winter flounder, cunner, and sculpins account for 96.9 percent of all 

IM&E of commercially and recreationally-harvested species.

Because the final rule and Proposal Option 4 do not reduce entrainment, they reduce baseline IM&E A1E 

mortality by 1.6 percent (0.93/57.86) and 0.7 percent (0.40/57.86), respectively (Table 3-3). Conversely, 

by requiring the installation of closed-cycle recirculating systems, which effectively reduce entrainment 

mortality, Proposal Option 2 reduces A1E mortality by 76.7 percent (44.40/57.86) (Table 3-3). 
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Table 3-3: Baseline IM&E and IM&E Reductions at All Regulated Facilities 

(Manufacturing and Generating) in the North Atlantic, and Reductions Under the 

Final Rule and Other Options Considered

IM&E Loss Metric (per year)

Reductions in Losses Baseline 

Losses Proposal 

Option 4

Final

Rule

Proposal 

Option 2

All Species (million A1E) 0.40 0.93 44.40 57.86

Forage Species (million A1E) 0.35 0.77 34.80 45.34

Commercial & Recreational Species (million A1E) 0.05 0.16 9.60 12.52

Commercial & Recreational Harvest (million fish) <0.01 0.02 0.91 1.19

A1E Losses with Direct Use Value (%) 1.5% 1.8% 2.1% 2.1%

Source: U.S. EPA analysis for this report

Production forgone due to baseline IM&E is estimated to be 26.03 million pounds of fish, leading to a 

decrease in fishery yield of 0.98 million pounds per year (Table 3-4). The final rule will result in 

increased fishery fields of 0.01 million pounds per year. Increases in fishery yields under other options 

considered range from less than 0.01 million pounds under Proposal Option 4 to 0.75 million pounds 

under Proposal Option 2. Estimated increases in fishery yields under Proposal Option 2 are more than 75 

times greater than under the final rule and Proposal Option 4 (Table 3-4). 

Table 3-4: Baseline Losses in Fishery Yield, Catch, and Production 

Forgone as a Consequence of IM&E at All Regulated Facilities 

(Manufacturing and Generating) in the North Atlantic, and Reductions 

Under the Final Rule and Other Options Considered

IM&E Loss Metric (million per year)

Reductions in Losses

Baseline 

Losses Proposal 

Option 4

Final

Rule

Proposal 

Option 2

Forgone Fishery Yield (lbs) <0.01 0.01 0.75 0.98

Forgone Commercial Catch (lbs) <0.01 <0.01 0.33 0.43

Forgone Recreational Catch (fish) <0.01 <0.01 0.56 0.73

Production Forgone (lbs) 0.03 0.26 19.93 26.03

Source: U.S. EPA analysis for this report

Raw numbers of IM&E in the North Atlantic can be found in Appendix Table C-4.

3.3.3 Mid-Atlantic Region

Table 3-5 and Table 3-6 present estimated baseline IM&E and reductions in IM&E under the final rule 

and other options considered. Estimated total baseline IM&E in the Mid-Atlantic region is 630.97 million 

A1Es per year, including 475.89 million A1Es of forage fish (75.4 percent). Approximately 3.3 percent of 

total baseline A1E mortality are assigned a direct use value from recreational or commercial fishing 

(Table 3-5). Table 5 of Appendix C presents species-specific data on impingement and entrainment under 

the baseline conditions and estimated reductions under all options. Briefly, the vast majority (93.8

percent) of all A1E mortality in the Mid-Atlantic occur as a consequence of entrainment mortality. Nearly 

half (44.7 percent) of the IM&E estimated for commercially- and recreationally-harvested species occurs 

in Blue Crab, and substantial IM&E (i.e., greater than 13 million A1E) is estimated for Atlantic Croaker, 

Atlantic Menhaden, Spot, and White Perch.
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Because of the high proportion of IM&E attributed to entrainment mortality, EPA estimates that the final 

rule and Proposal Option 4 reduce A1E mortality by 5.2 percent (32.99/630.97) and 4.8 percent

(30.50/630.97), respectively (Table 3-5). Conversely, by requiring the installation of closed-cycle 

recirculating systems, Proposal Option 2 would reduce A1E mortality by approximately 87.4 percent

(551.90/630.97). 

Table 3-5: Baseline IM&E and IM&E Reductions at All Regulated Facilities 

(Manufacturing and Generating) in the Mid-Atlantic, and Reductions Under the 

Final Rule and Other Options Considered

IM&E Loss Metric (per year)

Reductions in Losses Baseline 

Losses Proposal 

Option 4

Final

Rule

Proposal 

Option 2

All Species (million A1E) 30.50 32.99 551.90 630.97

Forage Species (million A1E) 11.63 12.75 415.46 475.89

Commercial & Recreational Species (million A1E) 18.87 20.25 136.44 155.08

Commercial & Recreational Harvest (million fish) 4.68 5.01 18.20 20.51

A1E Losses with Direct Use Value (%) 15.3% 15.2% 3.3% 3.3%

Source: U.S. EPA analysis for this report

EPA projects that baseline IM&E reduces fishery production by 52.74 million pounds, and decreases 

fishery yield by 15.07 million pounds per year (Table 3-6). The final rule will result in increased fishery 

yields of 3.89 million pounds per year. Increases in fishery yields under other options considered range 

from 3.63 million pounds per year under Proposal Option 4 to 13.38 million pounds per year under 

Proposal Option 2. Estimated increases in fishery yields under Proposal Option 2 are more than three 

times greater than under the final rule and Proposal Option 4 (Table 3-6).

Table 3-6: Baseline Losses in Fishery Yield, Catch, and Production 

Forgone as a Consequence of IM&E at All Regulated Facilities 

(Manufacturing and Generating) in the Mid-Atlantic, and Reductions 

Under the Final Rule and Other Options Considered

IM&E Loss Metric (million per year)

Reductions in Losses Baseline 

Losses Proposal 

Option 4

Final

Rule

Proposal 

Option 2

Forgone Fishery Yield (lbs) 3.63 3.89 13.38 15.07

Forgone Commercial Catch (lbs) 2.87 3.07 7.17 8.00

Forgone Recreational Catch (fish) 0.43 0.46 5.10 5.82

Production Forgone (lbs) 7.83 8.40 46.50 52.74

Source: U.S. EPA analysis for this report

Raw numbers of IM&E in the Mid-Atlantic region can be found in Appendix Table C-6.

3.3.4 South Atlantic Region

Table 3-7 and Table 3-8 present estimated baseline IM&E and reductions in IM&E under the final rule 

and other options considered. Estimated total baseline IM&E in the South Atlantic region is estimated to 

be 26.36 million A1Es per year, including 24.61 million forage fish A1Es. Approximately 1.1 percent of 

total baseline A1E mortality is assigned a direct use value from recreational or commercial fishing (Table 

3-7). Table 7 of Appendix C presents species-specific data on impingement and entrainment under the 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 3: Assessment of IM&E

May 2014 3-10

baseline conditions and estimated reductions under all options. Unlike other regions, the majority (65.0

percent) of all A1E mortality in the South Atlantic occur as a consequence of impingement mortality. 

Among commercially- and recreationally-harvested species, IM&E is greatest in Drums and Croakers and 

Blue Crab.

Due to the high proportion of IM&E lost to impingement, the final rule and Proposal Option 4 are 

projected to reduce A1E mortality by 49.1 percent (12.93/26.36) and 44.0 percent (11.61/26.36), 

respectively. However, because the installation of closed-cycle recirculating systems reduces water usage, 

Proposal Option 2 is projected to reduce A1E mortality by 97.1 percent (25.60/26.36) (Table 3-7). 

Table 3-7: Baseline IM&E and IM&E Reductions at All Regulated Facilities 

(Manufacturing and Generating) in the South Atlantic, and Reductions Under the 

Final Rule and Other Options Considered

IM&E Loss Metric (per year)

Reductions in Losses Baseline 

Losses Proposal 

Option 4

Final

Rule

Proposal 

Option 2

All Species (million A1E) 11.61 12.93 25.60 26.36

Forage Species (million A1E) 10.98 12.21 23.91 24.61

Commercial & Recreational Species (million A1E) 0.63 0.72 1.69 1.75

Commercial & Recreational Harvest (million fish) 0.09 0.10 0.27 0.28

A1E Losses with Direct Use Value (%) 0.7% 0.8% 1.0% 1.1%

Source: U.S. EPA analysis for this report

Production forgone due to baseline IM&E is estimated to be 0.71 million pounds per year, leading to a 

decrease in fishery yield of approximately 0.12 million pounds per year. The final rule will increase 

fishery yields of 0.05 million pounds per year. Increases in fishery yields under other options considered 

range from 0.04 million pounds per year under Proposal Option 4 to 0.12 million pounds per year under 

Proposal Option 2. Estimated increases in fishery yields under Proposal Option 2 are more than two times 

greater than under the final rule and Proposal Option 4 (Table 3-8). 

Table 3-8: Baseline Losses in Fishery Yield, Catch, and Production 

Forgone as a Consequence of IM&E at All Regulated Facilities 

(Manufacturing and Generating) in the South Atlantic, and Reductions 

Under the Final Rule and Other Options Considered

IM&E Loss Metric (million per year)

Reductions in Losses Baseline 

Losses Proposal 

Option 4

Final

Rule

Proposal 

Option 2

Forgone Fishery Yield (lbs) 0.04 0.05 0.12 0.12

Forgone Commercial Catch (lbs) 0.04 0.04 0.08 0.08

Forgone Recreational Catch (fish) 0.01 0.02 0.10 0.11

Production Forgone (lbs) 0.12 0.15 0.67 0.71

Source: U.S. EPA analysis for this report

Raw numbers of IM&E in the South Atlantic region can be found in Appendix Table C-8.

3.3.5 Gulf of Mexico Region

Table 3-9 and Table 3-10 present the estimated baseline IM&E and reductions in IM&E under the final 

rule and other options considered. Estimated total baseline IM&E in the Gulf of Mexico is estimated to be
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 3: Assessment of IM&E

May 2014 3-11

147.01 million A1Es per year, including 50.15 million forage fish A1Es. Approximately 8.8 percent of 

total baseline A1E mortality are assigned a direct use value from recreational or commercial fishing 

(Table 3-9). Table 9 of Appendix C presents species-specific data on impingement and entrainment under 

the baseline conditions and estimated reductions under all options. The majority (63.6 percent) of all A1E 

mortality in the Gulf of Mexico occur as a consequence of entrainment mortality. Among commerciallyand recreationally-harvested species, IM&E is greatest in Blue Crab, and Pink Shrimp, which together 

account for 67.8 percent of A1E mortality with direct use value. Other commercially- or recreationallyharvested fish species with substantial IM&E (i.e., greater than 5 million A1E) include Black Drum, 

Menhaden, and Silver Perch (Appendix Table C-9).

Due to the low proportion of IM&E lost to impingement, the final rule and Proposal Option 4 are 

projected to reduce A1E mortality by 27.4 percent (40.29/147.01) and 26.4 percent (38.82/147.01), 

respectively. In contrast, Proposal Option 2 is estimated to reduce A1E mortality by 70.3 percent

(103.42/147.01) (Table 3-9), nearly triple the estimated reductions of the final rule or Proposal Option 4.

Table 3-9: Baseline IM&E and IM&E Reductions at All Regulated Facilities 

(Manufacturing and Generating) in the Gulf of Mexico, and Reductions Under the 

Final Rule and Other Options Considered

IM&E Loss Metric (per year)

Reductions in Losses Baseline 

Losses Proposal 

Option 4

Final

Rule

Proposal 

Option 2

All Species (million A1E) 38.82 40.29 103.42 147.01

Forage Species (million A1E) 4.88 5.06 31.69 50.15

Commercial & Recreational Species (million A1E) 33.94 35.22 71.73 96.86

Commercial & Recreational Harvest (million fish) 5.15 5.35 9.83 12.92

A1E Losses with Direct Use Value (%) 13.3% 13.3% 9.5% 8.8%

Source: U.S. EPA analysis for this report

Production forgone due to baseline IM&E is estimated to be 79.65 million pounds per year, 43.3 percent 

of which is forgone fishery yield. The final rule will result in increased fishery yields of 3.51 million 

pounds per year. Increases in fishery yields under other options considered range from 3.38 million 

pounds per year under Proposal Option 4 to 21.78 million pounds per year under Proposal Option 2. 

Estimated increases in fishery yields under Proposal Option 2 are more than six times greater than under 

the final rule and Proposal Option 4 (Table 3-10). 

Table 3-10: Baseline Losses in Fishery Yield, Catch, and Production 

Forgone as a Consequence of IM&E at All Regulated Facilities 

(Manufacturing and Generating) in the Gulf of Mexico, and Reductions 

Under the Final Rule and Other Options Considered

IM&E Loss Metric (million per year)

Reductions in Losses Baseline 

Losses Proposal 

Option 4

Final

Rule

Proposal 

Option 2

Forgone Fishery Yield (lbs) 3.38 3.51 21.78 34.45

Forgone Commercial Catch (lbs) 1.64 1.70 4.27 6.03

Forgone Recreational Catch (fish) 0.75 0.78 2.14 3.08

Production Forgone (lbs) 6.54 6.78 49.81 79.65

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 3: Assessment of IM&E

May 2014 3-12

Raw numbers of IM&E in the Gulf of Mexico can be found in Appendix Table C-10.

3.3.6 Great Lakes Region

Table 3-11 and Table 3-12 present estimated baseline IM&E and reductions in IM&E under the final rule 

and other options considered. Estimated total baseline IM&E in the Great Lakes is 261.26 million A1Es 

per year, including 240.01 million A1E of forage fish. Approximately 1.7 percent of total baseline A1E 

mortality is assigned a direct use value from recreational or commercial fishing (Table 3-11). Table 11 of 

Appendix C presents species-specific data on impingement and entrainment under the baseline conditions 

and estimated reductions under all options. Briefly, among commercially and recreationally-harvested 

species, the greatest losses occur in Smelts.

The vast majority (90.6 percent) of IM&E in the Great Lakes occur due to impingement (Appendix Table 

C-11). Accordingly, the final rule and Proposal Option 4 are projected to reduce baseline A1E mortality

by 81.5 percent (202.58/248.47) and 70.4 percent (184.04/261.26), respectively (Table 3-11). By 

requiring the installation of closed-cycle recirculating systems, which reduce the volume of water 

required for cooling purposes, Proposal Option 2 reduces A1E mortality by 95.1 percent (248.47/261.26) 

(Table 3-11). 

Table 3-11: Baseline IM&E and IM&E Reductions at All Regulated Facilities 

(Manufacturing and Generating) in the Great Lakes, and Reductions Under the 

Final Rule and Other Options Considered

IM&E Loss Metric (per year)

Reductions in Losses Baseline 

Losses Proposal 

Option 4

Final

Rule

Proposal 

Option 2

All Species (million A1E) 184.04 202.58 248.47 261.26

Forage Species (million A1E) 175.88 193.58 230.50 240.01

Commercial & Recreational Species (million A1E) 8.16 9.00 17.97 21.25

Commercial & Recreational Harvest (million fish) 2.58 2.84 3.98 4.35

A1E Losses with Direct Use Value (%) 1.4% 1.4% 1.6% 1.7%

Source: U.S. EPA analysis for this report

Production forgone due to baseline IM&E is estimated to be 63.28 million pounds of fish, leading to a 

decrease in fishery yield of 4.14 million pounds per year (Table 3-12). The final rule will result in 

increased fishery yields of 2.69 million pounds per year. Increases in fishery yields under other options 

considered range from 2.44 million pounds per year under Proposal Option 4 to 3.78 million pounds per 

year under Proposal Option 2. Estimated increases in fishery yields under Proposal Option 2 are over 40 

percent greater than under the final rule or Proposal Option 4 (Table 3-12).
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 3: Assessment of IM&E

May 2014 3-13

Table 3-12: Baseline Losses in Fishery Yield, Catch, and Production 

Forgone as a Consequence of IM&E at All Regulated Facilities 

(Manufacturing and Generating) in the Great Lakes, and Reductions 

Under the Final Rule and Other Options Considered

IM&E Loss Metric (million per year)

Reductions in Losses Baseline 

Losses Proposal 

Option 4

Final

Rule

Proposal 

Option 2

Forgone Fishery Yield (lbs) 2.44 2.69 3.78 4.14

Forgone Commercial Catch (lbs) 1.12 1.24 1.70 1.84

Forgone Recreational Catch (fish) 1.33 1.47 2.04 2.23

Production Forgone (lbs) 30.67 33.79 55.61 63.28

Source: U.S. EPA analysis for this report

Raw numbers of IM&E in the Great Lakes region can be found in Appendix Table C-12.

3.3.7 Inland Region

Table 3-13 and Table 3-14 present estimated baseline IM&E and reductions in IM&E under the final rule 

and other options considered. Estimated total baseline IM&E in the Inland region is 755.97 million A1Es 

per year, including 599.13 million A1E of forage fish. Approximately 1.6 percent of total baseline A1E 

mortality is assigned a direct use value from recreational or commercial fishing (Table 3-13). Table 13 of 

Appendix C presents species-specific data on impingement and entrainment under the baseline conditions 

and estimated reductions under all options. Briefly, the majority (63.0 percent) of all A1E mortality in the 

Inland region occur as a consequence of impingement mortality (Appendix Table C-13). Notably, the 

IM&E of sunfish account for 78.4 percent of the IM&E of recreationally-harvested species.

The final rule and Proposal Option 4 are projected to reduce baseline A1E mortality by 47.8 percent 

(361.55/755.97) and 46.0 percent (348.12/755.97), respectively (Table 3-13). The installation of closedcycle recirculating systems under Proposal Option 2 reduces A1E mortality by 83.6 percent

(632.19/755.97), providing a benefit more than 70 percent larger than the benefits of the final rule or 

Proposal Option 4 (Table 3-13). 

Table 3-13: Baseline IM&E and IM&E Reductions at All Regulated Facilities 

(Manufacturing and Generating) in the Inland Region, and Reductions Under the 

Final Rule and Other Options Considered

IM&E Loss Metric (per year)

Reductions in Losses Baseline 

Losses Proposal 

Option 4

Final

Rule

Proposal 

Option 2

All Species (million A1E) 348.12 361.55 632.19 755.97

Forage Species (million A1E) 324.34 336.25 507.31 599.13

Commercial & Recreational Species (million A1E) 23.79 25.31 124.88 156.84

Commercial & Recreational Harvest (million fish) 3.57 3.73 9.70 11.90

A1E Losses with Direct Use Value (%) 1.0% 1.0% 1.5% 1.6%

Source: U.S. EPA analysis for this report

The decrease in production due to baseline IM&E is estimated to be 384.55 million pounds of fish, 

leading to a decrease in fishery yield of 10.41 million pounds per year (Table 3-14). The final rule will 

result in increased fishery yields of 3.25 million pounds per year. Increases in fishery yield under other 

options considered range from 3.11 million pounds per year under Proposal Option 4 to 8.48 million 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 3: Assessment of IM&E

May 2014 3-14

pounds per year under Proposal Option 2. Estimated increases in fishery yields under Proposal Option 2

are over two times greater than under the final rule and Proposal Option 4 (Table 3-14).

Table 3-14: Baseline Losses in Fishery Yield, Catch, and Production 

Forgone as a Consequence of IM&E at All Regulated Facilities 

(Manufacturing and Generating) in the Inland Region, and Reductions 

Under the Final Rule and Other Options Considered

IM&E Loss Metric (million per year)

Reductions in Losses Baseline 

Losses Proposal 

Option 4

Final

Rule

Proposal 

Option 2

Forgone Fishery Yield (lbs) 3.11 3.25 8.48 10.41

Forgone Commercial Catch (lbs) <0.01 <0.01 <0.01 <0.01

Forgone Recreational Catch (fish) 3.57 3.73 9.70 11.90

Production Forgone (lbs) 84.97 89.40 309.65 384.55

Source: U.S. EPA analysis for this report

Raw numbers of IM&E in the Inland region can be found in Appendix Table C-14.

3.3.8 National Estimates

Table 3-15 and Table 3-16 present estimated baseline IM&E and reductions in IM&E under the final rule 

and other options considered. Estimated total baseline IM&E nationally is 1,930.97 million A1Es per 

year, including 1,459.70 million A1E of forage fish. Approximately 2.8 percent of total baseline A1E 

mortality is assigned a direct use value from recreational or commercial fishing (Table 3-15). Table 15 of 

Appendix C presents species-specific data on impingement and entrainment under the baseline conditions 

and estimated reductions under all options. Briefly, the majority (57.3 percent) of all A1E mortality

nationally occur as a consequence of entrainment mortality (Appendix Table C-15). 

The final rule and Proposal Option 4 are projected to reduce baseline A1E mortality by 33.8 percent 

(652.00/1,930.97) and 31.8 percent (614.16/1,930.97), respectively (Table 3-15). The installation of 

closed-cycle recirculating systems under Proposal Option 2 reduces A1E mortality by 84.8 percent

(1,637.49/1,930.97), providing a benefit more than twice as large as the benefits of the final rule or 

Proposal Option 4 (Table 3-15). 

Table 3-15: Baseline IM&E and IM&E Reductions at All Regulated Facilities 

(Manufacturing and Generating) Nationally, and Reductions Under the Final Rule 

and Other Options Considered

IM&E Loss Metric (per year)

Reductions in Losses Baseline 

Losses Proposal 

Option 4

Final

Rule

Proposal 

Option 2

All Species (million A1E) 614.16 652.00 1637.49 1930.97

Forage Species (million A1E) 528.22 560.80 1258.67 1459.70

Commercial & Recreational Species (million A1E) 85.94 91.20 378.82 471.28

Commercial & Recreational Harvest (million fish) 16.13 17.11 44.66 54.02

A1E Losses with Direct Use Value (%) 2.6% 2.6% 2.7% 2.8%

Source: U.S. EPA analysis for this report

The decrease in production due to baseline IM&E is estimated to be 626.60 million pounds of fish, 

leading to a decrease in fishery yield of 69.76 million pounds per year (Table 3-16). The final rule is 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 3: Assessment of IM&E

May 2014 3-15

estimated to result in an increased fishery yield 13.42 million pounds per year. Increases in fishery yields 

under other options considered range from 12.63 million pounds per year under Proposal Option 4 to 

51.11 million pounds per year under Proposal Option 2. Estimated increases in fishery yields under 

Proposal Option 2 are nearly four times greater than under than final rule or Proposal Option 4 (Table 

3-16).

Table 3-16: Baseline Losses in Fishery Yield, Catch, and Production 

Forgone as a Consequence of IM&E at All Regulated Facilities 

(Manufacturing and Generating) Nationally, and Reductions Under the 

Final Rule and Other Options Considered

IM&E Loss Metric (million per year)

Reductions in Losses Baseline 

Losses Proposal 

Option 4

Final

Rule

Proposal 

Option 2

Forgone Fishery Yield (lbs) 12.63 13.42 51.11 69.76

Forgone Commercial Catch (lbs) 5.68 6.07 14.72 18.32

Forgone Recreational Catch (fish) 6.13 6.50 20.53 25.31

Production Forgone (lbs) 130.25 138.89 494.17 626.60

Source: U.S. EPA analysis for this report

Raw numbers of national IM&E can be found in Appendix Table C-16. 

3.4 Limitations and Uncertainties 

Four major kinds of uncertainty may lead to imprecision and bias in EPA’s IM&E analysis: data, 

structural, statistical, and engineering uncertainty. Data limitations and uncertainty refers to uncertainty 

and inconsistency in sampling methodologies used in facility-specific IM&E studies. Structural 

uncertainty reflects the simplification built into any model of a complex natural system. Parameter 

uncertainty refers to uncertainty in the numeric estimates of model parameters. Finally, engineering 

uncertainty refers to the fact that facilities do not operate in the exact same manner on an annual basis. 

3.4.1 Data Limitation and Uncertainty

EPA based its quantification of regional and national IM&E on cumulative data generated by collection at 

individual facilities. In turn, these data are heterogeneous products of location-specific investigations set 

in differing geographic and ecological provinces. Interpretation of the significance and trends of IM&E at 

regional and national scales (and of the accompanying ecological benefits upon mitigation) must consider 

the strengths and weaknesses of this data.

The IM&E data from model facilities constitute a heterogeneous composite of results from many facilityspecific studies. Sampling effort and data quality control vary tremendously among IM&E studies and 

baseline source water characterization programs. There is little uniformity among studies as to the 

intensity, frequency and duration of data collection as well as the scope of target biota collected, 

identified, and enumerated. Sampling regimes may be properly adjusted to ensure that changes in local 

biotic activity associated with diurnal, tidal, and lunar cycles are incorporated; or may reflect regularly 

spaced sampling points with little concern paid to capturing environmental variability. 

In addition to the differences in environmental scope, sampling methods are not uniform among studies 

with regard to the types and meshes of sampling nets, deployment location of sampling nets (e.g., outside 

or within the intake structure), length and weight measurements, observations of field conditions, 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 3: Assessment of IM&E

May 2014 3-16

characterization of reference areas, etc. In addition to different sampling methods and timing, some 

sampling programs are designed primarily to estimate IM&E for a select suite of recreational or 

commercially important aquatic organisms. Studies differ in their taxonomic sorting classes and 

specificity of identification of impinged and entrained organisms (e.g., eggs, ichthyoplankton, 

zooplankton, etc.). Thus, many IM&E studies are poorly suited to provide insight into the direct and 

indirect impacts to forage fish species, non-vertebrate organisms (zooplankton, tunicates, algae, worms, 

etc.), or community/ecosystem impacts. For older facilities, sampling data commonly lack pre-operational 

(i.e., baseline) samples or community surveys to compare to the results of more-current IM&E data. 

Finally, few IM&E studies are designed to allow evaluation of community impacts or ecosystem effects 

(Section 2.4). 

Within regions, studies of IM&E from model facilities are typically composed of data from a relatively 

limited number of facilities. Most facility-specific IM&E studies are limited to one or two years, and are 

rarely replicated within a time period that allows direct comparison of trends without historical 

complications due to fishery stock trends, climatic changes, or shifts in collection methods or water 

quality. Thus, studies within a regional database may not accurately represent average climatic and 

oceanographic conditions (e.g., El Nino years). Additionally, studies within the database may include 

historical (>20 years ago) and recent data, thus incorporating considerable uncertainty due to the annual 

variability of highly dynamic fish stocks. Thus, extrapolation from regional collections of facility-specific 

studies may not provide a true regional estimate because the available data may or may not be fully 

representative of regional trends and/or of associated ecological benefits derived from mitigating IM&E

impacts. 

3.4.2 Structural Uncertainty

The models EPA used to evaluate IM&E simplify complex processes. The degree of simplification is 

substantial, but necessary, because of limited data availability and the need to generate estimates on a 

national scale. Simplification occurs with respect to many processes within the model, to ensure 

computational tractability and national applicability (Table 3-17). 

While EPA recognizes these uncertainties, addressing each of these uncertainties in a defensible way 

would require data that does not currently exist (see Section 3.2.4.2), would be time-consuming and 

resource-intensive to develop, and could lead to greater parameter uncertainty (Section 3.4.3).
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 3: Assessment of IM&E

May 2014 3-17

Table 3-17: Structural Uncertainties

Aspect of Model General Description Specific Treatment in Model

Biological 

submodels

Life history traits are fixed Life history parameters in the models (i.e., growth, survival) are constant 

through time and are thus independent of biological conditions (e.g., fish 

densities, seasonality, weather, recruitment variability, food availability, 

fisheries pressure, etc.).

No trophic effects Indirect food web effects such as trophic cascades, growth and population 

limitations due to a lack of food, etc., are not considered. Trophic transfer 

is treated simplistically.

Outside impacts not addressed IM&E loss rates are affected by a variety of outside influences not included 

in the model (e.g., fisheries pressure, pollution, future development, 

invasive species, climate change, etc.). 

Valuation 

structure

National nonuse benefits Fish species grouped into two categories: harvested or not harvested (i.e., 

forage for harvested species). Harvested fish are assigned use values within 

the national analysis. EPA used benefit transfer to estimate nonuse values 

for the North Atlantic and Mid-Atlantic regions (Chapter 8). Nonuse values 

for other regions are not included in the comparison of benefits and costs 

for the final rule. EPA also conducted a stated preference survey to assess 

total values (Chapter 10). EPA, however, did not include survey estimates 

in its benefits totals for the rule but the estimates illustrate the potential 

magnitude of total values.

Fishing pressure constant The valuation procedure assumes that fisheries harvests will increase 

proportionately to decreases in IM&E, independent of Federal and State 

policies on commercial and recreational fishing (i.e., fisheries quotas, 

closures, bag limits, etc.). 

3.4.3 Parameter Uncertainty

Parameter uncertainty refers to variability in the value of parameters used in biological and economic 

modeling. EPA must estimate all parameters from sampling studies that cannot identify the true values of 

interest due to statistical and logistical limitations. These limitations are broadly driven by three 

processes, including parameter fluctuation through time, geographic location, and sampling. 

The true value of many biological parameters fluctuates on an annual basis, due to changes in weather, 

food availability, indirect food-web effects, and compensatory population dynamics. Consequently, 

parameter values used within biological submodels, despite being based upon the best available data 

obtained from the scientific literature, cannot be without error due to annual variability in fish growth and 

(natural and fisheries) mortality rates. Similarly, because IM&E rates are driven by a combination of 

intake flow and the presence of vulnerable fish, actual IM&E cannot remain constant through time. 

True values of biological parameters and facility IM&E vary geographically. Biological parameters may 

vary substantially within regions due to changes in substrate, water temperature and salinity, etc., while 

facility IM&E data may be strongly connected to local substrates, distance from shore, depth, etc. It 

follows, then, that using biological data and extrapolating facility-specific IM&E rates to the regional 

scale will result in parameter variability based solely on geographic considerations. 

Finally, all model parameters contain uncertainty because they are small samples taken from a much 

larger dataset. Biological parameters such as mortality rates must be estimated using incomplete sampling 

data. Facility-reported IM&E studies necessarily subsample cooling water, and often do not take replicate 

samples across tidal periods, seasons, time of day, and between years. Moreover, these studies often 

present IM&E with limited taxonomic detail (i.e., the identification of eggs, larvae, and juveniles is not 

species-specific), and do not have standard methodologies. As is the case with retrospective data, these 

studies also reflect the biological and physical state of the waterbody when studies were conducted. In 

some cases, the state of the waterbody itself has changed substantially since sampling was conducted.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 3: Assessment of IM&E

May 2014 3-18

EPA recognizes many sources of parameter uncertainty in its models (Table 3-18), all of which lead to 

uncertainty in point estimates of IM&E. The nature of these uncertainties, however, does not inherently 

bias the point estimate. EPA reported all biological and physical parameters in good faith, and as such, 

parameter estimates are unlikely to be biased in aggregate, but distributed both above and below true 

parameter values. Thus, parameter uncertainty has resulted in imprecision rather than inaccuracy in model 

output.12

3.4.4 Engineering Uncertainty

EPA’s evaluation of IM&E was also affected by uncertainty about the engineering and operating 

characteristics of the study facilities. It is unlikely that facility operating characteristics (e.g., seasonal, 

diurnal, or intermittent changes in intake water flow rates) are constant throughout any particular year. As 

such, the timing of sampling, and the annual repeatability of IM&E, may be biased by facility operating 

conditions. EPA assumed that the facilities’ loss estimates were provided in good faith and did not 

include any biases or omissions that significantly modified loss estimates. 

 

12 Accuracy refers to the degree of closeness of model results to the actual value. Precision refers to the reproducibility of model 

output, or the degree to which repeated measurements (or samples, for example from different model facilities) under similar 

conditions will result in the same model output.
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Table 3-18: Parameters Included in EPA’s IM&E Analysis Subject to Uncertainty

Model Aspect Parameter Description

IM&E monitoring 

/loss rate estimates 

Sampling regimes Sampling regimes are subject to numerous facility-specific details. No 

established guidelines or performance standards for how to design and conduct 

sampling regimes. Not all sampling studies measured both impingement and 

entrainment mortality.

Extrapolation 

assumptions

Extrapolation of monitoring data to annual IM&E rates assumes sampling 

occurred under average conditions, and that diurnal/seasonal/annual cycles in 

fish presence and vulnerability and various technical factors (e.g., net 

collection efficiency; hydrological factors affecting IM&E rates) do not play a 

substantial role in the accuracy of extrapolation. No established guidelines or 

consistency in sampling regimes.

Species selection Criteria for the selection of species evaluated in IM&E studies are neither 

well-defined nor uniform across facilities. At many facilities, IM&E data was 

collected for only a subset of species, usually only fish and shellfish.

Sensitivity of fish to 

IM&E

Entrainment mortality was assumed by EPA to be 100 percent. Backcalculations were done in cases where facilities reported entrainment rates that 

assumed <100 percent mortality. These calculations were limited by data 

reporting (i.e., species-specific survival rates were not always provided). 

Impingement survival was included if presented in facility documents.

Biological/life 

history

Natural mortality rates Natural mortality rates (M) difficult to estimate, and vary with time and 

geography. Model results are highly sensitive to M.

Growth rates Simple exponential growth rates or simple size-at-age parameters used, and 

assumed constant across all locations and years.

Geographic 

considerations

Migration patterns; IM&E occurring during spawning runs or larval outmigration; location of harvestable adults; intermingling with other stocks.

Forage valuation Harvested species assumed to be food limited; trophic transfer efficiency to 

harvested species estimated by EPA based on general models; no consideration 

of trophic transfer to species not impinged and entrained.

Fish stock 

characteristics

Fishery yield For most harvested species, only one species-specific value for fishing 

mortality rate (F) was used for all stages subject to harvest. Used stage-specific 

constants for fraction vulnerable to fishery.

Harvest behavior No assumed dynamics among harvesters to alter fishing rates or preferences in 

response to changes in stock size. Recreational access assumed constant (no 

changes in angler preferences or effort).

Stock interactions IM&E assumed to be part of reported fishery yield rates on a statewide basis. 

No consideration of possible substock harvest rates or interactions, no 

unreported catch.

Ecological 

system 

Fish community Long-term trends in fish community composition or abundance were not 

considered (general food webs assumed to be static), nor were indirect trophic 

interactions. Used constant value for trophic transfer efficiency, and specific 

trophic interactions were not considered. Trophic transfer to organisms not 

impinged and entrained is not considered.

Spawning dynamics Sampled years assumed to be typical with respect to choice of spawning areas 

and timing of migrations that could affect vulnerability to IM&E 

(e.g., presence of larvae in vicinity of intake structure).

Hydrology Sampled years assumed to be typical with respect to flow regimes and tidal 

cycles that could affect vulnerability to IM&E (e.g., presence of larvae in 

vicinity of CWIS).

Meteorology Sampled years assumed to be typical with respect to vulnerability to IM&E 

(e.g., presence of larvae in vicinity of intake structure).
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4 Economic Benefit Categories

Changes in CWIS design or operations resulting from the final section 316(b) rule for regulated facilities 

are expected to reduce IM&E of fish, shellfish, and other aquatic organisms, thereby increasing the 

numbers of aquatic organisms and local and regional fishery populations.

The aquatic organisms affected by CWIS provide a wide range of ecosystem services. Ecosystem services 

are the physical, chemical, and biological functions performed by natural resources and the human 

benefits derived from those functions, including both ecological and human use services (Daily 1997; 

Daily et al. 1997). Scientific and public interest in protecting ecosystem services is increasing with the 

recognition that these services are vulnerable to a wide range of human activities and are difficult, if not 

impossible, to replace with human technologies (Meffe 1992). 

In addition to their importance in providing food and other goods of direct use to humans, the organisms 

lost to IM&E are critical to the continued functioning of the ecosystems of which they are a part. Fish are 

essential for energy transfer in aquatic food webs, regulation of food web structure, nutrient cycling, 

maintenance of sediment processes, redistribution of bottom substrates, the regulation of carbon fluxes 

from water to the atmosphere, and the maintenance of aquatic biodiversity (Holmlund and Hammer 1999; 

Peterson and Lubchenco 1997; Postel and Carpenter 1997; Wilson and Carpenter 1999). Many of these 

ecosystem services can be maintained only by the continued presence of all life stages of fish and other 

aquatic species in their natural habitats. Section 2.3 provides detail on potential CWIS impacts on aquatic 

ecosystems, but because of inadequate data, EPA could not evaluate or monetize many of these impacts.

In addition to economic benefits categories associated with the reductions in IM&E, EPA also assessed 

benefits associated with changes in carbon dioxide (CO2) emissions. EPA monetized these benefits based 

on the social cost of carbon. Social cost of carbon is an “estimate of the monetized damages associated 

with an incremental increase in carbon emissions in a given year” and it “is intended to include (but is not 

limited to) changes in net agricultural productivity, human health, property damages from increased flood 

risk, and the value of ecosystem services due to climate change” (Interagency Working Group 2010, p.1). 

The following sub-sections focus on benefits categories associated with IM&E reductions. See Chapter 9 

for additional discussion of benefits from changes in emissions based on the social cost of carbon. 

4.1 Economic Benefit Categories of the Rule

The economic benefits of reducing IM&E at regulated facilities stem from both market and nonmarket 

goods and services that the affected resources provide. These benefits can be divided into the following 

categories (Table 4-1, below).

 Market benefits: Market benefits are positive welfare impacts that can be quantified using 

money-denominated measures of consumer and producer surplus. The most obvious example of 

market benefits from reduced IM&E is benefits to commercial fisheries. Changes in IM&E will 

directly affect the price, quantity, and/or quality of fish harvests. The monetary value of the 

changes can be measured directly through market measures of consumer and producer behavior. 

Market benefits may be further categorized in terms of direct and indirect benefits. By definition, 

all market benefits are use benefits, as they involve either direct or indirect uses of goods or 

services.
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 Market direct use benefits: These benefits are related to goods directly used, and bought 

and sold in markets; for example, fish caught for sale to consumers.

 Market indirect use benefits: These benefits occur through indirect or secondary effects on 

marketed goods and contribute indirectly to an increase in welfare for users of the resource. 

For example, an increase in the number of forage fish may increase the population of 

commercially valuable species, which are marketed to consumers. Thus, reducing IM&E of 

forage species can result in indirect welfare gains for commercial fishers and consumers who 

purchase fish. 

 Nonmarket benefits: Nonmarket benefits consist of goods and services that are not traded in the 

marketplace, but are nonetheless positively affected by reduced IM&E. Higher catch rates for 

recreational fishing are a nonmarket benefit. Anglers place a high value on catching fish during 

their fishing trips, so higher catch rates from reduced IM&E will translate directly to greater 

utility from participation in recreational fishing. Because the monetary value of these 

improvements cannot be established by observing market transactions, nonmarket valuation 

techniques must be employed to estimate such benefits. Nonmarket benefits may be further 

categorized in terms of direct and indirect use benefits, and nonuse benefits. 

 Nonmarket direct use benefits: These benefits consist of goods and services that have direct 

uses, but are not traded in the marketplace. Higher catch rates for recreational fishing provide 

a typical nonmarket direct use benefit. 

 Nonmarket indirect use benefits: These benefits contribute indirectly to an increase the

welfare of those who engage in nonmarketed uses of a resource. For example, positive 

impacts on local fisheries may generate an improvement in the population levels and diversity 

of fish-eating bird species. In turn, bird watchers might obtain greater enjoyment from their 

outings, as they are more likely to see a wider mix or greater numbers of birds. The increased 

welfare of the bird watchers is thus an indirect consequence of the initial impact on fish.

 Nonuse benefits: These benefits occur when individuals value improved environmental 

quality without any past, present, or anticipated future use of the resource in question. 

Individuals may gain utility simply from knowing that a particular good exists (existence 

value), or from knowing that a good is available for others to use now and in the future 

(bequest value). Nonuse, or passive, benefits of reduced IM&E may include increased 

biodiversity, improved conditions for the recovery of T&E species that have no direct or 

indirect uses and welfare gains to nonusers when reduced IM&E to forage species improve 

overall ecosystem function.

Table 4-1 presents the benefit categories EPA considered for regulated facilities. The table also presents

the various data needs, data sources, and estimation approaches associated with each category. A 

complete list of the ecosystem services potentially affected by reduction in IM&E is presented in Chapter 

2 (Table 2-4).

In addition the approaches presented in Table 4-1, EPA developed and implemented an original stated 

preference (SP) study to estimate the total monetary value (use plus nonuse value) of aquatic resource 

improvements from the 316(b) rule.

13 EPA has not accounted for values estimated from the survey in the 

quantitative comparison of costs and benefits. EPA plans to obtain Science Advisory Board (SAB) review 

 

13 SP surveys, in general, ask questions that elicit individuals’ values for carefully specified changes in an environmental 

amenity (Freeman III 2003)
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of the SP survey, and considers the inclusion of benefits based on the survey to be premature prior to the 

completion of the SAB review. Chapter 11 presents preliminary survey results to illustrate the potential 

magnitude of benefits.

Table 4-1: Summary of Benefit Categories, Data Needs, Potential Data Sources, Approaches, 

and Analyses Completed

Benefit Category Basic Data Needs Potential Data Sources/ 

Approaches/Analyses Completed

Market Goods, Direct Use

 Increased commercial landings

 Estimated change in landings of 

specific species

 Estimated change in total economic 

impact

 Based on facility-specific IM&E data 

and ecological modeling.

 Changes in commercial fishery 

landings estimated using a marketbased approach.

 Indirect economic impacts not 

estimated due to data constraints.

Market Goods, Indirect Use

Increase in:

 Equipment sales, rental, and repair

 Bait and tackle sales

 Consumer market choices

 Choices in restaurant meals

 Property values near the water

 Ecotourism (charter trips, festivals, 

other organized activities with fees,

such as riverwalks)

 Estimated change in landings of 

specific species

 Relationship between increased 

fish/shellfish landings and secondary 

markets

 Local activities and participation 

fees

 Estimated numbers of participating 

individuals

 Indirect market impacts not estimated 

due to data constraints such as lack of 

information on the relationship 

between increased fish/shellfish yield 

and secondary impacts.

Nonmarket Goods, Direct Use

 Improved value of a recreational 

fishing trip due to increased catch of 

targeted/preferred species and 

incidental catch

 Improved value of subsistence 

fishing

 Value of additional recreational 

participation and additional fishing 

trips

 Value of an improvement in catch 

rate

 Estimated number of affected 

anglers or estimate of potential 

anglers

 Value of a fishing day

 Changes in the value of a recreational 

fishing trip estimated based on benefit 

transfer (including recreational use 

values of selected T&E species).

 Changes in the value of subsistence 

fishing not estimated.

 Number of affected anglers and 

increase in trips not estimated due to 

data constraints. 
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Table 4-1: Summary of Benefit Categories, Data Needs, Potential Data Sources, Approaches, 

and Analyses Completed

Benefit Category Basic Data Needs Potential Data Sources/ 

Approaches/Analyses Completed

Nonmarket Goods, Indirect Use

 Increase in value of boating, scubadiving, and near-water recreational 

experience from observing fish 

while boating, scuba-diving, hiking, 

or picnicking, and watching aquatic 

birds fish or catch aquatic 

invertebrates

 Increase in boating, scuba-diving, 

and near-water recreation 

participation

 Estimated number of affected nearwater recreationists, divers, and 

boaters

 Value of boating, scuba-diving, and 

near-water recreation experience

 Value of a recreation day

 Increased trip value not estimated due 

to data constraints such as number of 

affected recreational users.

 Changes in recreational participation

were not estimated. They are

expected to be negligible at the 

regional level because fishery yield 

impacts are generally small.

Nonuse Goods

Increase in nonuse values such as:

 Existence (stewardship)

 Altruism (interpersonal concerns)

 Bequest (interpersonal and 

intergenerational equity) motives

 Appreciation of the importance of 

ecological services apart from human 

uses or motives (Table 2-4)

 IM&E estimates

 Primary valuation research using 

stated preference approach 

 Applicable studies upon which to 

conduct benefit transfer

 Location of CWIS and T&E species 

ranges

 Estimate nonuse values for an 

increase in relative fish abundance 

within two benefits regions using 

benefit transfer. Not estimated for 

other regions due to a lack of 

applicable studies.

 Used geographic information system 

(GIS) data to identify T&E species 

potentially impacted by CWIS based 

on the overlap of CWIS locations and 

T&E species ranges.

 EPA used the results of the 316(b) 

stated preference survey to illustrate 

total values for the 316(b) rule,

including nonuse values. However, 

did not include estimates based on the 

316(b) SP survey in its comparison of 

costs and benefits of the rule.

4.2 Market and Nonmarket Direct and Indirect Use Benefits from Reduced IM&E

Direct use benefits from reduced IM&E are the simplest to envision. The welfare of commercial, 

recreational, and subsistence fishers is improved when fish stocks increase, and catch rates rise or effort 

decreases. Higher catch rates increase the revenue and growth of commercial fisheries, the enjoyment of 

recreational fishing trips, and the availability of food for subsistence fishers—all of which are quantifiable 

benefits arising directly from changes in IM&E. Methodologies for estimating use values for recreational 

and commercial species are well developed, and some of the species affected by IM&E have been studied

extensively. As a result, estimation of associated use values is often straightforward.

Indirect use benefits refer to welfare improvements for those individuals whose activities are enhanced as 

an indirect consequence of fishery or habitat improvements. For example, an improvement in the 

population of a forage fish species may be of no direct consequence to recreational or commercial fishers. 

However, the increased presence of forage fish will have an indirect effect on commercial and 

recreational fishing values if it increases food supplies for commercial and recreational predatory species. 

Thus, improvements in forage species populations can result in a greater number (and/or greater 

individual size) of those fish that are targeted directly by recreational or commercial fishers. In such an 

instance, the incremental increase in recreational and commercial fishing benefits would be an indirect 

consequence of the effect on forage fish populations.
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The following sections discuss the benefits estimates presented in each chapter of this report, and 

techniques for estimating benefits of reduced IM&E for each category of benefits.14

4.2.1 Commercial Fisheries

Commercial fishing benefits include both direct and indirect market use values. The social benefits 

derived from increased landings by commercial fishers can be valued by examining the markets through 

which the landed fish are sold. The first step of the analysis involves a fishery-based assessment of 

IM&E-related changes in commercial landings (pounds of commercial species as sold dockside by 

commercial harvesters). The changes in landings are then valued according to market data from relevant 

fish markets (dollars per pound) to derive an estimate of the change in gross revenue to commercial 

fishers. The final steps entail converting the IM&E-related changes in gross revenues into estimates of 

social benefits. These social benefits consist of the sum of the producers’ and consumers’ surpluses that 

are derived as the changes in commercial landings work their way through the multi-market commercial 

fishery sector.

Indirect use values in markets occur through increases in commercial species caused by increased 

numbers of forage fish. An improvement in the population of a forage fish species may be of no direct 

consequence to commercial fishers. However, the increased presence of forage fish will have an indirect 

effect on commercial fishing values if it increases food supplies for commercial predatory species. Thus, 

improvements in forage species populations can result in a greater number (and/or greater individual size) 

of those fish that are targeted directly by commercial fishers. In such an instance, the incremental increase 

in commercial fishing benefits would be an indirect consequence of the final rule’s effect on forage fish 

populations. See Chapter 3 for a discussion on the indirect influence of forage fish on abundance of 

commercial and recreational species.

Chapter 6 provides more detail on EPA’s analysis of commercial fishing benefits from reducing IM&E at 

the regulated facilities’ cooling water intakes. 

4.2.2 Recreational Fisheries

Recreational fishing benefits include both direct and indirect nonmarket use values. Recreational use 

benefits cannot be tracked in the market because much of the recreational activity associated with these 

fisheries occurs as nonmarket events. However, a variety of nonmarket valuation methods exist for 

estimating use value, including both “revealed” and “stated” preference methods (Freeman III 2003). 

These methods use other observable behavior to infer users’ value for environmental goods and services. 

Examples of revealed preference methods include travel cost, hedonic pricing, and random utility models. 

Compared to nonuse values, nonmarket use values are often considered relatively easy to estimate, due to 

their relationship to observable behavior, the variety of revealed preference methods available, and public 

familiarity with the recreational services that surface waterbodies provide.

To evaluate the recreational benefits of the regulatory options for regulated facilities, EPA developed a 

benefit transfer approach based on a meta-analysis of recreational fishing valuation studies. The analysis 

was designed to measure the various factors that determine WTP for catching an additional fish per trip. 

 

14 Many of the fish species affected by IM&E at CWIS sites are harvested both recreationally and commercially. To avoid 

double-counting the economic impacts of IM&E of these species, EPA determined, based on historic NMFS landings data, 

the proportions of total species landings attributable to recreational and commercial fishing, and applied these proportions to 

the total number of affected fish.
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The estimated meta-model allows EPA to calculate the marginal value per fish for different species, based 

on resource and policy context characteristics. 

Indirect use values for forage species occur through increases in recreational species caused by increased 

numbers of forage fish. An improvement in the population of a forage fish species may be of no direct 

consequence to recreational anglers. However, the increased presence of forage fish will have an indirect 

effect on recreational fishing values if it increases food supplies for recreational predatory species. Thus, 

improvements in forage species populations can result in a greater number (and/or greater individual size) 

of those fish that are targeted directly by recreational anglers. In such an instance, the incremental 

increase in recreational fishing benefits would be an indirect consequence of the effect on forage fish 

populations. See Chapter 3 for a discussion on the indirect influence of forage fish on abundance of 

commercial and recreational species.

Chapter 7 provides detail on the application of the meta-regression model EPA used to estimate

recreational fishing benefits of the final rule and regulatory options it considered. 

4.2.3 Subsistence Fishers

Subsistence fisheries benefits include both direct and indirect nonmarket use values. Subsistence use of 

fishery resources can be important in areas where socioeconomic conditions (e.g., the number of lowincome households) or the mix of ethnic backgrounds make such fishing economically or culturally 

significant to a component of the community. In cases of Native American use of affected fisheries, the 

value of an improvement can sometimes be inferred from settlements in legal cases, e.g., compensation 

agreements between affected tribes and various government or other institutions in cases of resource 

acquisitions or resource use restrictions. For the general population, the value of improved subsistence 

fisheries may be estimated from the costs saved in acquiring alternative food sources. This method may 

underestimate the value of a subsistence fishery meal to the extent that the store-bought foods may be less 

preferred by some individuals than consuming a fresh-caught fish. Subsistence fishery benefits are not 

included in EPA’s benefits regional analyses. Impacts on subsistence fishers may constitute an important 

environmental justice consideration, which could result in EPA underestimating the total benefits of the

final rule and regulatory options it considered. EPA’s Environmental Justice analysis is presented in 

Chapter 12 of the economic analysis of the final 316(b) rule (USEPA 2014a).

4.2.4 Benefits from Improved Protection to T&E Species

T&E and other special status species can be adversely affected in several ways by CWIS. T&E species 

can suffer direct harm from IM&E; they can suffer indirect impacts if IM&E at CWIS adversely affects 

another species upon which the T&E species relies within the aquatic ecosystem (e.g., as a food source); 

or they can suffer impacts if the CWIS disrupts their habitat (e.g., via thermal discharges). The loss of 

individuals of listed species from IM&E at CWIS is particularly important because, by definition, these 

species are already rare and at risk of irreversible decline because of other stressors. 

Benefits from improved protection of T&E species can include both direct and indirect nonmarket use 

values, as well as nonuse values. EPA identified nine special status fish species, six in California and 

three in the Inland region, for which IM&E data were available. Due to their special status as well as the 

fact that most of these species have either very limited or no direct uses, the major portions of the value 

for T&E species are nonuse values. However, some of these species have potentially significant 

recreational and commercial use values, for example, sturgeon and paddlefish. EPA applied benefit 

transfer to estimate recreational use values for a subset of T&E species for which limited catch and 
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May 2014 4-7

release fisheries exist. EPA did not estimate potential commercial use values of these species due to the 

lack of market data. 

Chapter 5 provides more detail on EPA’s analysis of T&E species benefits from reducing IM&E at CWIS 

of regulated facilities.

4.3 Nonuse Benefits from Reduced IM&E

Comprehensive estimates of total resource value include both use and nonuse values, such that the 

resulting total value estimates may be compared to total social cost. Recent economic literature provides 

substantial support for the hypothesis that nonuse values, such as option and existence values, are greater 

than zero. In fact, small per capita nonuse values held by a substantial fraction of the population can be 

very large in the aggregate. “Nonuse values, like use values, have their basis in the theory of individual 

preferences and the measurement of welfare changes. According to theory, use values and nonuse values 

are additive” (Freeman III 1993).

15Consequently, both EPA’s own Guidelines for Preparing Economic 

Analysis and the Office of Management and Budget’s (OMB) Circular A-4 governing regulatory analysis, 

support the need to assess nonuse values (USEPA 2010a; USOMB 2003). Excluding nonuse values from 

consideration is likely to understate substantially total social values. 

Reducing IM&E of fish and shellfish may result in both use and nonuse benefits. Of the organisms that 

EPA anticipates will be protected by the section 316(b), only about 3 percent of A1E will eventually be 

harvested by commercial and recreational fishers, and therefore can be valued with direct use valuation 

techniques. The remainder, which were not assigned direct use value in this analysis, constitute the 

majority—97 percent—of the total estimated reductions in IM&E. Table 4-2 summarizes baseline IM&E

and reductions in IM&E by four loss categories: all species, forage species, total commercial and 

recreational species, and harvested commercial and recreational species. Although unlanded forage fish 

contribute to the yield of harvested fish and therefore have an indirect use value that is captured by the 

direct use value of the commercial species, this indirect use value represents only a portion of the total 

value of unlanded fish. Society also values both landed and unlanded fish for reasons unrelated to use—

for example, individual welfare may be affected simply by knowing these fish exist. Additionally, nonuse 

values are likely to be substantial because fish and other species found within aquatic habitats impacted 

directly and indirectly by CWIS provide other valuable ecosystem goods and services. These include 

nutrient cycling and ecosystem stability. Therefore, a comprehensive estimate of the welfare gain from 

reducing IM&E must include an estimate of nonuse benefits. 

In contrast to direct and indirect use values, nonuse values are oftenmore difficult to estimate. SP 

methods, or benefit transfer based on SP studies, are the generally accepted techniques for estimating 

these values (USEPA 2010a; USOMB 2003). SP methods rely on carefully designed surveys, which 

either ask individuals about their WTP for particular ecological improvements, such as increased 

protection of aquatic species or habitats with particular attributes, or to choose among competing 

hypothetical “packages” of ecological improvements and household cost in which the choice implies 

WTP. In either case, values are estimated by statistical analysis of survey responses.

 

15 This additive property holds under traditional conditions related to resource levels and prices for substitute goods in the 

household production model (Freeman III 1993).
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Table 4-2: Summary of Baseline National IM&E and Reductions in IM&E, for the 

Final Rule and Other Options Considered

IM&E Loss Metric (per year)

Reductions in Losses Baseline 

Losses Proposal 

Option 4

Final

Rule

Proposal 

Option 2

All Species (million A1E) 614.16 652.00 1637.49 1930.97

Forage Species (million A1E) 528.22 560.80 1258.67 1459.70

Commercial & Recreational Species (million A1E) 85.94 91.20 378.82 471.28

Commercial & Recreational Harvest (million fish) 16.13 17.11 44.66 54.02

A1E Losses with Direct Use Value (%) 2.6% 2.6% 2.7% 2.8%

Source: U.S. EPA analysis for this report

Nonuse values may be more difficult to assess than use values for several reasons. First, nonuse values 

are not associated with easily observable behavior. Second, nonuse values may be held by both users and 

nonusers of a resource. Because nonusers may be less familiar with particular services provided by a 

resource, they may value the resource differently compared to users of the same resource. Third, the 

development of a defensible SP survey is often a time- and resource-intensive process. Fourth, even 

carefully designed surveys may be subject to certain biases associated with the hypothetical nature of 

survey responses (Mitchell and Carson 1989). Finally, efforts to disaggregate total WTP into its use and 

nonuse components have proved troublesome (Carson et al. 1999).

Although EPA is not always able to estimate changes in nonuse values as part of regulatory development, 

an extensive body of environmental economics literature demonstrates that the public holds significant 

value for service flows from natural resources well beyond those associated with direct uses (Boyd et al. 

2001; Fischman 2001; Heal et al. 2001; Herman et al. 2001; Ruhl and Gregg 2001; Salzman et al. 2001; 

Wainger et al. 2001). Studies have documented public values for the services provided by a variety of 

natural resources potentially affected by environmental impacts, including fish and wildlife (Loomis et al. 

2000; Stevens et al. 1991); wetlands (Woodward and Wui 2001); wilderness (Walsh et al. 1984); critical 

habitat for T&E species (Hagen et al. 1992; Loomis and Ekstrand 1997; Whitehead and Blomquist 1991); 

shoreline quality (Grigalunas et al. 1988); and beaches, shorebirds, and marine mammals (Rowe et al. 

1992), among others. However, given EPA’s regulatory schedule, developing and implementing SP

surveys to elicit total value (i.e., nonuse and use) of environmental quality changes resulting from 

environmental regulations is often not feasible. In this case, EPA designed and implemented an original 

SP survey to estimate total monetary value (including use and nonuse value) of potential aquatic resource 

improvements that might occur as a result of the final 316(b) rule. As described in Section 4.1, EPA does 

not include the benefits it estimated based on the survey in the comparison of costs and benefits for the 

final rule. Chapter 11 provides additional details on the survey, implementation, and presents preliminary 

benefits estimates to illustrate the potential of magnitude of total benefits. EPA also developed a benefit 

transfer based on another existing SP survey to estimate nonuse benefits resulting from the final 316(b) 

rule for the North and Mid-Atlantic regions. The benefit transfer is described in Chapter 8.

Existing SP studies suggest that nonuse benefits of aquatic habitat improvements may be significant. For 

example, results from a study of public values of migratory fish restoration projects in Rhode Island 

showed that nonuse motives such as existence and bequest were rated as “important” or “very important” 

by 62 and 76 percent of survey respondents, respectively. Use motives such as commercial and 

recreational fishing, on the other hand, were rated as “important” or “very important” by only 38 and 43 

percent of the survey respondents, respectively (Johnston et al. 2012, unpublished data). Additional detail 

regarding the Rhode Island study is provided in Chapter 8, Section 8.3.1.
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Many ecosystems affected by CWIS provide goods and services that contribute to societal well-being (see 

Chapter 2), but may be generally unrecognized because of the indirect nature of the effect. As such, even 

valuations based on SP approaches are unlikely to capture the full economic value of the affected 

ecosystem services (Costanza and Folke 1997). Despite these limitations, benefit transfer based on SP 

studies is the generally accepted techniquefor estimating total (use and nonuse) values. EPA was able to 

identify a single existing study that could be used to estimates total values (nonuse and use values) for 

reductions in IM&E in some regions. Chapter 8 provides more detail on EPA’s quantitative analysis of 

nonuse benefits from reducing IM&E at the CWIS of regulated facilities.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 5: Impacts and Benefits on T&E Species

May 2014 5-1

5 Impacts and Benefits on Threatened and Endangered Species

5.1 Introduction

T&E species are species vulnerable to future extinction or at risk of extinction in the near future, 

respectively. These designations may be made because of low or rapidly declining population levels, loss 

of essential habitat, or life history stages that are particularly vulnerable to environmental alteration, 

disturbance, or other human impacts. 

The withdrawal of cooling water from streams, rivers, estuaries and coastal marine waters leads to IM&E 

of a large number of aquatic organisms. For species vulnerable to future extinction, IM&E from CWIS 

may represent a substantial portion of annual reproduction. Consequently, IM&E may either lengthen 

recovery time, or hasten the demise of these species. For these reasons, the population-level and social 

values of T&E losses are likely to be disproportionately higher than the absolute number of losses that 

occur.

Adverse effects of CWIS on T&E species may occur in several ways:

 Populations of T&E species may suffer direct harm as a consequence of IM&E. This direct 

loss of individuals may be particularly important because T&E species have severely 

depressed population levels that are approaching local, national, or global extinction. 

 T&E species may suffer indirect harm if the CWIS substantially alters the food web in which 

these species interact. This might occur as a result of altered populations of predator or prey 

species, the removal of foundation species, or (for species with parasitic life history stages) 

the loss of a host species. 

 CWIS may alter habitat that is critical to the long-term survival of T&E species. This might 

occur as a consequence of changes in the thermal characteristics of local waterbodies, altered 

flow regimes, turbidity, or changes in substrate characteristics as a consequence of any of 

these changes (Chapter 2).

By definition, T&E species are characterized by low population levels. As such, it is unlikely that these 

species will be recorded in IM&E monitoring studies due to the logistical limitations of sampling and 

identification effort, time of day, season, and year. For T&E species to be recorded in monitoring studies, 

1) an individual of a T&E species must be captured during the (often short) sampling window, and 2) the 

organism must be identifiable. Thus, despite the fact that the population impacts of IM&E on T&E 

species may be high, the effects are difficult to ascertain and quantify within a framework designed for 

common, more-abundant species. Thus, EPA identifies spatial overlap between CWIS and T&E species 

habitat ranges to estimate the potential for adverse IM&E impacts.

As noted, T&E species affected by CWIS may have both use and nonuse values. However, despite the 

existence of T&E species with potentially high use values (e.g., Pacific salmonids), the majority of T&E 

species affected by IM&E are relatively unknown, and those that are unidentifiable may not have any 

direct use values (e.g., delta smelt). Given that protecting of T&E species implies value, and that the 

majority of T&E species may not have direct use value, the majority of the economic value for T&E 

species must come from nonuse values. Species-specific estimates of nonuse values held for the 

protection of T&E species can be derived only by primary research using stated preference techniques. 

However, EPA did not have the resources necessary to develop such estimates for T&E species for this 
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rulemaking. As an alternative, EPA used a benefit transfer approach that relies on information from 

existing studies (USEPA 2010a). 

EPA was able to use a benefit transfer approach to estimate changes in recreational use values for a subset 

of T&E species that are highly valued by recreational anglers (i.e., paddlefish16 and sturgeon). 

Commercial and nonuse values are not monetized for any of the affected species. Therefore, benefit 

estimates presented in this chapter are incomplete and highly conservative (i.e., low). 

In this chapter, EPA explores the extent to which CWIS may affect species protected by the Endangered 

Species Act on national and regional scales (Section 5.2), documents the value society places on the 

protection of T&E species (Section 5.3), and applies economic valuation studies of T&E species to case 

studies of sea turtles and finfish in the Inland region (Section 5.4). 

5.2 T&E Species Affected by CWIS

To assess the potential impacts of CWIS on T&E species, EPA constructed a database that identifies 

spatial overlap between CWIS and vulnerable life history stages of all aquatic T&E species for which data 

are available. The database allowed EPA to estimate the potential for adverse IM&E impacts on T&E 

species. 

5.2.1 T&E Species Identification and Data Collection

First, all species currently listed under the Endangered Species Act (as of August 6, 2012) with aquatic 

life history stages were identified using the US Fish and Wildlife Service Environmental Conservation 

Online System (USFWS 2012a). This primary list of all T&E species was filtered to include only species 

with life history stages vulnerable to CWIS mortality according to life history data. Examples of 

vulnerable stages include planktonic egg stages occurring near- or in-shore (e.g., marine species spawning 

offshore were excluded unless other vulnerable stages are found near- or in-shore), free-swimming larval 

stages residing near- or in-shore, and adult life history stages that occur near- or in-shore. Life history 

data used to exclude species from further consideration was obtained from a wide variety of sources 

(AFSC 2010; ASMFC 2012; Froese and Pauly 2009; NatureServe 2012; NEFSC 2010; PIFSC 2010a; 

PIFSC 2010b; SEFSC 2010; SWFSC 2010; USFWS 2012a). After filtering by life history data, the list of 

T&E species potentially affected by IM&E contained 287 species. 

Whenever possible, EPA obtained the geographical distribution of T&E species susceptible to IM&E in 

geographic information system (GIS) format as polygon (shape) files, line files (for inhabitants of small 

creeks and rivers) and as a subset of geodatabase files. Data sources include the US Fish and Wildlife 

Service (USFWS 2010a), including shapefiles for critical habitat designated under the Endangered 

Species Act, NOAA’s Office of Response and Restoration (NOAA 2010), NatureServe (NatureServe 

2012), and NOAA NMFS (NMFS 2010a; NMFS 2010b; NMFS 2010c). For several freshwater species, 

geographic ranges were available only as 6-digit hydrologic unit codes (HUC) (NatureServe 2012; 

USFWS 2010a). For these species, GIS data layers were generated using a GIS HUC database obtained 

from the USGS (Steeves and Nebert 1994). For several species, no GIS data could be acquired. For these 

species, species distribution descriptions were compared with mapped CWIS, and inspected for

geographic overlap. In all such cases (e.g., the “inarticulated brachiopod,” Lingula reevii, endemic to 

 

16 Note: the American Paddlefish is listed on T&E species lists for many states, but is not currently protected nationally under 

the US Endangered Species Act. A review of the species’ status in 1992 revealed that although the species did not then meet 

the requirements to be listed as threatened at the federal level, the US Fish and Wildlife Service expressed its concern for the 

future of the species. 
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Kaneohe Bay, HI) no regulated facilities were located within 10 kilometers, and further inspection was 

not warranted.

5.2.2 Number of T&E Species Affected per Facility

To investigate the potential for individual facilities to affect a wide variety of T&E species, EPA 

calculated the number of T&E species affected on a per-facility basis. This calculation allowed EPA to 

assess the magnitude of differences between regions of CWIS effects on T&E species. 

Nationally, 99 of the 287 aquatic T&E species (34 percent) had vulnerable life history stages that either 

overlapped with CWIS, or records of IM&E (Table 5-1). These species overlapped with 523 of 738 

regulated facilities (71 percent) (Figure 5-1). Among facilities, the variability in the number of T&E 

species potentially affected ranges between 0 and 32 species (Table 5-1), with more than 90 percent of 

facilities affecting fewer than 7 T&E species, and more than 99 percent of facilities affecting fewer than 

12 species (Figure 5-2). 

Excluding facilities whose CWIS that do not overlap with at least one T&E species, the average number 

of species per facility is 4.13 (minimum 1, maximum 32) (Table 5-1). Sea turtles, snails and freshwater 

mussels had the highest overlap rate on a per-facility basis, averaging 4.7, 4.1 and 3.7 species per facility, 

respectively. Anadromous and freshwater fish had lower overlap rates with CWIS, averaging slightly 

higher than one species per interacting facility (Table 5-1).

Driven by the high number of IM&E freshwater mussels overlapping with facility CWIS, the majority of 

all species by facility interactions occur in the inland region. However, the shape of cumulative 

distribution plots is similar among regions after accounting for sample size, suggesting that the overall 

probability of a facility affecting one or more T&E species is not a function of geographic region (Figure 

5-3).
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Figure 5-1: Map of overlap of CWA section 316(b) existing facilities and T&E species habitat ranges (all circles, 523 

facilities) or overlapping with critical habitat (orange circles, 27 facilities). Because critical habitat is a subset of total T&E 

species habitat, a total of 523 facilities overlap the habitat of one or more T&E species. 
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Figure 5-2: Empirical cumulative distribution function plot of the number of T&E species 

potentially affected on a per-facility basis by regulated facilities nationwide. Sample size is 738.

Table 5-1: Number of T&E Species with Geographical Distributions 

Overlapping Regulated Facilities, on a Per-facility Basis

Subset of Affected Speciesa# Species

T&E Species per Facilityc

All Facilities Interacting Facilitiesb

Avg Max Avg Max

All T&E Species 99 2.9 32 4.1 32

T&E Freshwater Mussels 53 1.9 22 3.7 22

T&E Anadromous Fish 12 0.3 5 1.2 5

T&E Freshwater Fish 21 0.1 4 1.4 4

T&E Snails 7 0.3 7 4.1 7

T&E Sea Turtles 6 3.8 5 4.7 5

a T&E species include species listed as threatened or endangered by the US Fish and Wildlife Service (fresh 

water) or NOAA National Marine Fisheries Service (marine)

b

Interacting Facilities = all facilities with CWIS inside the range of at least one T&E species

c Avg = Average, Max = Maximum

Source: U.S. EPA analysis for this report
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Figure 5-3: Cumulative distribution plot of the number of T&E species potentially affected on a 

per-facility basis by regulated facilities nationwide. Sample sizes (i.e., number of regulated 

facilities) are noted in parentheses. The horizontal axis is equivalent in all plots, with the 

exception of the Inland region (noted with an asterisk *).

5.2.3 Number of Facilities Affecting Individual T&E Species 

To investigate the cumulative potential for CWIS to affect individual T&E species, EPA calculated the 

number of facilities affecting each T&E species. There are 2,158 examples of overlaps between species 

and facilities across 99 T&E species nationally, resulting in an average of 21.8 facilities per species 

(Table 5-2). Consequently, many T&E species are likely to be affected by a large number of facilities. 

Thus, even if individual facilities have low IM&E of T&E species, the cumulative effect of regulated 

facilities on these populations may be substantial. The variation among species was large and ranged 

between 1 and 103 facilities per species (Table 5-2). Overall, 10 percent of species are affected by 1 

facility, 53 percent of species are affected by up to 6 facilities 73 percent of species are affected by up to 

25 facilities, and 92 percent are affected by up to 74 facilities (Figure 5-4).
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Table 5-2: Number of Facilities with CWIS Within the Geographical Distribution of 

T&E Species, on a Per-species Basis

Subset of Affected SpeciesaSpecies Overlaps

Facilities per T&E Species

Average Maximum

All T&E Species 99 2158 21.8 103

T&E Freshwater Mussels 53 1176 21.8 103

T&E Anadromous Fish 12 235 19.6 101

T&E Freshwater Fish 21 65 3.1 7

T&E Snails 7 199 28.4 49

Sea Turtles 6 483 80.5 102

a T&E species included species listed as threatened or endangered by the US Fish and Wildlife Service (fresh water) or 

NOAA National Marine Fisheries Service (marine).

Source: U.S. EPA analysis for this report

When subsets of related species were assessed, sea turtles had the highest average number of overlapping 

facilities (80.5) (Table 5-2), a value skewed by these species’ extensive ranges (i.e., entire Atlantic, Gulf 

of Mexico, and/or Pacific coast), and the potential for IM&E impacts at all life stages. Following sea 

turtles, snails and freshwater mussels had the highest average number of overlapping facilities (28.4 and 

21.8 facilities per species, respectively). Excepting turtles, freshwater mussels accounted for 8 of the top 

10 species sorted by the count of CWIS overlap (Figure 5-5). Following freshwater mussels, anadromous 

fish species were most likely to be affected, with an average of 19.6 facilities per species (Table 5-2). 

This average, however, is highly skewed by two species of fish (the pallid sturgeon, Scaphirhynchus 

albus and the shortnose sturgeon, Acipenser brevirostrum) which accounted for 70 percent of all overlap 

between facilities and anadromous fish species (Figure 5-5). Finally, freshwater fish species averaged 3.1

facilities with potential IM&E per species (Table 5-2, Figure 5-5). 

Figure 5-4: Empirical cumulative distribution function plot of the number of facilities that overlap 

geographically with vulnerable life history stages of T&E species. Species represented on the plot 

are those that overlap with a minimum of one regulated facility. Sample size is 99.
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Figure 5-5: Cumulative distribution plots of the number of facilities likely to affect individual 

threatened or endangered species, grouped by species life history trait. Sample sizes (species per 

life history trait) are in parentheses, and represent those species potentially affected by a 

minimum of one regulated facility. The horizontal axis is equivalent in all plots, with the exception 

of Freshwater Fish (noted with an asterisk *).

5.2.4 Summary of Overlap between Cooling Water Intake Structures and T&E Species

Nationally, 34 percent of T&E species with vulnerable life history stages overlap with a minimum of one 

CWIS (Table 5-1), and 71 percent of CWIS overlap with at least one T&E species. This suggests a high 

probability that T&E populations are affected by IM&E. The potential for these impacts is widespread: 

T&E species overlap CWIS in all geographical regions of the country (Figure 5-3), in all waterbody 

types, and across multiple life histories (Figure 5-5). Finally, EPA’s analysis includes only federally listed 

T&E species. Thus, the number of T&E species (including those species defined as threatened or 

endangered under state law) affected by IM&E is likely understated.

5.2.5 Summary of Overlap between Cooling Water Intake Structures and Critical Habitat

At some point following the listing of a species under the ESA, the US Fish and Wildlife Service or 

NOAA will designate critical habitat. Critical habitat is defined as areas occupied by the species at the 

time of listing which either 1) contain physical or biological features essential to conservation which 

require special management considerations or protection, or 2) is essential for conservation. 

To investigate the impact of regulated facilities on critical habitat, EPA assessed the number of facilities 

with CWIS located within critical habitat. Overall, 27 facilities overlapped with critical habitats 

designated for 21 species protected by the ESA (Figure 5-1). Of these 27 facilities, 14 overlapped with 

critical habit for only one species; no facility overlapped with more than 8 species.
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5.2.6 Effect of the Final Rule on Facilities Overlapping T&E Species Habitat

To estimate the potential effect of the final rule on T&E species, EPA estimated the number of regulated 

facilities overlapping the habitat of one or more T&E species. Based upon data from the 316(b) industry 

survey (USEPA 2000), EPA estimates there are 143 facilities likely to be in compliance with the final rule 

(final determination of compliance will be based on site-specific determination of BTA for entrainment), 

and that a minimum of 192 facilities will be required to implement measures to reduce IM&E. There was 

insufficient data for EPA to estimate compliance status for the remaining 188 facilities (Figure 5-6).

5.2.7 Species with Documented IM&E

Although difficult to observe and quantify, EPA identified 14 T&E species with documented IM&E from 

facility IM&E studies (Table 5-3). Notably, several of these IM&E studies were conducted prior to the 

listing of some of the T&E species identified (i.e., delta smelt, longfin smelt). Therefore, current annual 

IM&E may be lower for these species, particularly if species’ populations have decreased or if facilities 

have been required to install additional technologies during the permitting process. Alternatively, IM&E 

may be similar in magnitude at facilities whose operating permits have been administratively continued 

while these new species were listed.

In addition to identifying T&E species reported in IM&E studies, EPA also identified taxa in these studies 

not identified by species but whose genus matched T&E species overlapping with the reporting facility

location (Table 5-3). Although these instances are not confirmed IM&E of T&E species, they provide 

evidence that additional T&E species are likely to be directly affected by IM&E. 

Including only individuals identified by species, EPA identified more than 95,000 baseline losses of T&E 

species (Table 5-3). However, for several reasons, T&E species suffering IM&E are likely to be 

underreported. First, T&E species are found at low population densities, and the volume of water sampled 

by facility-level impingement and entrainment studies is low. Thus, it is likely that many T&E species 

suffered IM&E outside of sampling periods and were never recorded. Second, because a high proportion 

of all IM&E occurs during early life history stages (i.e., egg, larvae) when species identification is more 

challenging, T&E species may not be recognized during sampling. For example, endangered species of 

darter, including the Cherokee and duskytail darters, may be reported as “darter,” or “unidentified darter”. 
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Figure 5-6: Map of 316(b) existing facilities with CWIS overlapping the habitat of one or more T&E species, and these 

facilities’ compliance with the final rule. Overall, EPA estimates that 143 facilities are likely to be in compliance with the 

final rule (green circles), 192 facilities are not yet in compliance with the final rule (red circles), and there is insufficient 

data for EPA to estimate compliance status for the remaining 188 facilities (orange circles). 
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Table 5-3: Documented IM&E of T&E Speciesa

Resolution Common Name Latin Name

Baseline IM&E

Qualitativeb Not Extrapolated Extrapolated Estimated 

IM&Ec

Species

Atlantic Salmon Salmo salar  -

Chinook Salmon Oncorhynchus tshawytscha  5,470

Coho Salmon Oncorhynchus kisutch  -

Delta Smelt Hypomesus transpacificus  62,526

Green Sea Turtle Chelonia mydas  -

Hawksbill Sea Turtle Eretmochelys imbricata  -

Kemp's Ridley Sea Turtle Lepidochelys kempii  -

Leatherback Sea Turtle Dermochelys coriacea  -

Loggerhead Sea Turtle Caretta caretta  5-50

Longfin Smelt Spirinchus thaleichthys  24,919

Olive Ridley Sea Turtle Lepidochelys olivacea  -

Pallid Sturgeon Scaphirhynchus albus  50

Steelhead Trout Oncorhynchus mykiss  5

Topeka Shiner Notropis topeka  15

Genus

Alabama Sturgeon Scaphirhynchus suttkusi  8,174

Atlantic Sturgeon Acipenser oxyrinchus oxyrinchus  785,667

Blackside Dace Phoxinus cumberlandensis  10

Chum Salmon Oncorhynchus keta  22

Green Sturgeon Acipenser medirostris  785,667

Gulf Sturgeon Acipenser oxyrinchus desotoi  785,667

Shortnose Sturgeon Acipenser brevirostrum  785,667

a Species listed as threatened or endangered under state laws, such as the American Paddlefish (Polyodon spathula), are not included in this list.

b

"Qualitative" indicates the species is reported by name from a minimum of one facility, but no loss estimates are provided.

c Baseline IM&E reported for genera reflect IM&E for all species within the genus. Losses are likely dominated by more-common congeners.

Source: U.S. EPA analysis for this report
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5.3 Societal Values for Preservation of T&E Species Affected by IM&E

This section examines governmental spending, policy decisions, and private donations associated 

with the preservation and restoration of T&E species. This section provides evidence of societal 

preferences for T&E preservation and spending related to ensuring sustainability of T&E species. 

The U.S. Fish and Wildlife Service (FWS) reports annual expenditures for the conservation of 

T&E species. Using the report for fiscal year 2011 (USFWS 2012b) EPA calculated total 

government (federal and state) expenditures for the 99 federally listed T&E species with 

vulnerable life history stages that overlap CWIS (Table 5-4). Excluding expenditures on T&E 

species (and distinct population segments) not subject to IM&E, federal and state expenditures on 

T&E species potentially affected by CWIS exceeded $593.2 million during FY 2011, and 

accounted for 68 percent of all governmental spending on fish, marine reptiles, crustaceans, 

corals, clams, aquatic snails and marine mammals listed under the ESA (USFWS 2012b).

In addition to direct governmental spending associated with the protection of T&E species that 

overlap with CWIS, the presence of these species often guides policy discussions, and may 

require the installation of abatement technologies that reduce T&E species mortality and allow 

these species to migrate. For example, the life history of the American paddlefish (Polyodon 

spathula) (listed on many state T&E species lists, but not protected under the ESA) is 

occasionally discussed during Federal Energy Regulatory Commission relicensing of dams, 

because of the animal’s highly migratory life history. In the Wisconsin River, for example, 

Alliant Energy has been required to install a multi-million dollar fishway at the Prairie du Sac 

dam, primarily to allow the passage of paddlefish and lake sturgeon (WPLC v. FERC 2004).

Considerations for T&E species have also been responsible for changes in water diversions on the 

San Joaquin-Sacramento River delta, limiting water for downstream users. Under current 

regulations, the volume of water removed from the San-Joaquin-Sacramento River at the Banks 

Pumping Plant is limited from December to June, to protect delta smelt (NRDC v. Kempthorne 

2007). This restriction limits the volume of water available for consumption as drinking water 

and for use in large-scale irrigation projects. Water restrictions attributable due to the potential for 

negative effects on delta smelt populations, have been estimated to result in the loss of 21,100 

Table 5-4: Federal and State Expenditures for 

T&E Species Overlapping with CWIS

Species Group

Expenditure

(2011$, 

millions)

Anadromous Fish $483.4 

Freshwater Fish $57.6

Freshwater Mussels $13.0

Snails $0.1

Sea Turtles $39.1

All Species Overlapping CWIS $593.2

All Fish, Marine Reptile, Crustaceans, Coral, 

Marine Mammal, Aquatic Snail and Clam 

Species

$869.1

Source: USFWS (2012b)
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farm-related jobs and $703 million in agricultural revenue in 2009 alone (Boxall 2010; Howitt et 

al. 2009).

17

Although government spending and policy decisions made to protect or enhance stocks of T&E 

species are not direct indications of economic benefits, they indicate that society does place a 

significant value on protecting and restoring species at risk of extinction.

5.4 Assessment of Benefits to T&E Species

5.4.1 Economic Valuation Methods

Estimating the benefits of preserving T&E species by reducing IM&E is difficult for several 

reasons. First, the contribution to ecosystem stability, ecosystem function, and life history remain 

relatively unknown for many T&E species. Second, because much of the wildlife economic 

literature focuses on commercial and recreational benefits that are not relevant for many protected 

species (i.e., use values), a paucity of economic data focuses on the benefits of preserving T&E 

species. Consequently, nonuse values comprise the principal source of benefit estimates for most 

T&E species.

To obtain an accurate estimate of the nonuse values of T&E species affected by IM&E, first, 

quantitative IM&E impacts, and the benefits of policy options, must be estimated for T&E 

species. Second, an economic value must be obtained for the value of reducing IM&E as a 

consequence of increased population sizes, extinction avoidance, and, for certain species (e.g., 

Salmonids), the potential for re-establishment of a commercial fishery. 

Benefit transfer involves extrapolating existing estimates of nonmarket values to geographic 

locations or species that differ from the original analytical situation. Thus, the approach transfers 

estimates of values for preserving T&E species in one region to another region, or to a similar 

species. Ideally, the resource (i.e. species), policy variable (e.g., change in species status, 

recovery interval, population size, etc.), and the benefitting population (i.e., defined human 

population) are identical. Such a match rarely occurs. Despite discrepancies in these variables, 

however, a benefit transfer approach can provide useful insights into the social benefits gained by 

reducing IM&E of T&E species.18

5.4.2 Case Studies

EPA attempted to estimate the benefits of the final rule for all T&E species with documented and 

quantified IM&E at CWIS. In most cases, EPA was unable to locate or calculate key components 

of the analysis necessary to apply a benefit transfer approach. However, EPA was able to obtain 

sufficient data to estimate the economic benefits to two categories of T&E species: a subset of 

T&E fish species in the Inland region, and loggerhead sea turtles. The case studies of potential 

economic benefits from a decrease in T&E mortality are discussed below. 

 

17 Water diversion in the San Joaquin-Sacramento River is currently undergoing active litigation. See San Luis & 

Delta-Mendota Water Authority, et al. v. Salazar, et al., USDC Case No. 1:09-CV-407 OWW GSA, and 

consolidated cases.

18 Types of benefit transfer studies are discussed at length in U.S. EPA (2010).
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5.4.2.1 Inland Region

Baseline IM&E of Special Status Species and Reductions in IM&E Under the Final Rule and 

Options Considered

EPA estimated IM&E for three T&E species in the Inland region: pallid sturgeon, American 

paddlefish, and Topeka shiner. However, sufficient data were available to estimate the benefits of 

the final rule for only the pallid sturgeon (Scaphirhynchus albus) and the American paddlefish 

(Polyodon spathula). As such, benefits estimates address only 73 to 83 percent of estimated T&E 

A1E losses in the Inland region (Table 5-5). 

The pallid sturgeon is listed as an endangered species under the ESA; the American paddlefish is 

not listed federally. In the early 1990s, the U.S. FWS conducted a review of the paddlefish for 

threatened status, but ultimately did not list the species (Allardyce 1991). However, the review 

noted that immediate efforts were needed to restore stocks and degraded habitats (Allardyce 

1991). Although not currently protected federally, paddlefish are protected by 11 states.

The American paddlefish is a large species (85 inches length and more than 220 lbs) with roe 

suitable for caviar. The species once supported a large commercial fishery in the Mississippi 

Valley, and currently supports a limited recreational fishery in some states. Likewise, the pallid 

sturgeon is one of the largest (30 to 60 inches) fish found in the Missouri-Mississippi River 

drainage, with specimens weighing up to 85 pounds. Because their large size makes them a 

desirable commercial and trophy sport fish, and because they have roe suitable for caviar, both 

pallid sturgeon and American paddlefish have potentially significant direct use values. All 

extractive uses of the pallid sturgeon, however, are prohibited under the ESA. 

To estimate total baseline IM&E, EPA used the EAM to model A1Es for each of the three T&E 

species (Chapter 3).19 The choice of facilities used to extrapolate IM&E from model facilities was 

based on species’ historic ranges and current distributions. In addition to baseline estimates of 

IM&E for pallid sturgeon, paddlefish, and Topeka shiner, EPA calculated reductions in IM&E

under the final rule and Proposal Options 2 and 4 (Table 5-5).

Table 5-5: Annual Baseline IM&E and Reductions in Baseline IM&E of 

T&E Species at Regulated facilities in the Inland Region, by Regulatory 

Option (A1E)

T&E Species Proposal 

Option 4

Final

Rule

Proposal 

Option 2 Baseline

Paddlefish 7,930 8,245 15,660 18,841

Pallid Sturgeon 65 68 78 90

Topeka Shiner 2,911 3,010 3,472 3,985

Total 10,906 11,323 19,210 22,916

a The IM&E data used to develop regional estimates are from sampling at the Wabash and Cayuga 

facilites in 1976, the only year of sampling data for these facilities.

Source: U.S. EPA analysis for this report

 

19 IM&E of Paddlefish and pallid sturgeon as observed at nine and two model facilities, respectively.
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Benefit Transfer Approach: Estimated WTP for Protection of Inland T&E Species

Nonuse Values

EPA identified two studies that estimated both nonuse and use values for sturgeon. One study 

found that citizens of Maine are willing to pay $38.87 (2011$) as a one-time tax to create a selfsustaining population of shortnose sturgeon (Kotchen and Reiling 2000), a species listed as 

endangered under the ESA (NMFS 2004). A separate study found that lake sturgeon is a popular 

wildlife-viewing species in Wisconsin, and that viewers place a substantial value on protection of 

lake sturgeon populations. The average viewer’s WTP to maintain the current sturgeon 

population of Wisconsin’s Lake Winnebago system was $127.37 (2011$). With an estimated 

3,176l sturgeon viewers in 2002, total WTP for sturgeon-viewing opportunities in the Winnebago 

system was $0.41 million (2011$). Together, the results of these studies indicate that nonuse 

values for preservation of sturgeon are likely to be significant. However, EPA was unable to 

monetize total nonuse benefits from reduced IM&E because reliable population estimates needed 

to transfer the values were unavailable. 

Use Values

 Pallid sturgeon and paddlefish have potentially high commercial use values as

sources of roe. This value has increased dramatically owing to the collapse of 

Caspian Sea sturgeon populations (Speer et al. 2000). Paddlefish roe have been 

reported to sell for more than $300 per pound, and as much as three pounds of roe 

may be harvested from a large female (McKean 2007). Despite these reports, EPA 

was unable to reliably quantify total commercial values for these species due to a 

lack of market data. 

 Recreational use values for sturgeon and paddlefish caught in inland waters or 

paddlefish were not available. Based on a review of literature describing these 

species, EPA determined that sturgeon species (including white, green, and pallid 

sturgeons) and paddlefish share many characteristics, including roe suitable for caviar 

and their value as game fish. Consequently, WTP values for sturgeon obtained in 

California were used to value recreational use of these species in the Inland region. A 

limited recreational fishery (mostly catch and release) exists for paddlefish in several 

states; although harvesting pallid sturgeon is illegal, the species is sometimes caught 

by recreational anglers. 

To estimate recreational use values for paddlefish and pallid sturgeon, EPA applied estimates 

from a random utility model (RUM) analysis conducted to evaluate recreational fishing benefits 

of the 2004 Section 316(b) Phase II Final Rule. Model results indicate that California anglers 

were willing to pay $73.27 (2011$) to catch a sturgeon (USEPA 2004a), a value transferred to 

anglers for pallid sturgeon and paddlefish in the Inland region (Table 5-6).20

The recreational use value from eliminating baseline IM&E of pallid sturgeon and paddlefish is 

approximately $1.2 million using a 3 percent discount rate and $1.1 million using a 7 percent 

discount rate. Annualized benefits for the final rule will be $415,000 using a 3 percent discount 

rate and $320,000 using a 7 percent discount rate. Annualized benefits for other options 

considered range from $399,000 to $664,000 using a 3 percent discount rate and $307,000 to 

 

20 The Phase II analysis did not estimating WTP for catching a sturgeon in other states. Given similarity in species 

characteristics, EPA used WTP for sturgeon caught in California to value sturgeon and paddlefish species in the 

Inland region. 
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May 2014 5-16

$460,000 using a 7 percent discount rate. EPA notes that these are underestimates of the total 

values of reducing IM&E to T&E species in the Inland region because both nonuse and 

commercial values, which are likely to be substantial, are not incorporated. 

Table 5-6: Estimated Annual WTP for Eliminating or Reducing IM&E of Special Status 

Fish Species at Regulated facilities in the Inland Region, for the Final Rule and Other 

Options Considered (2011$)a

T&E Species

Annualized Benefits (2011$, 1,000s)

Proposal Option 4 Final Rule Proposal Option 2 Baseline

Paddlefish $581.0 $604.1 $1,147.4 $1,380.5

Pallid Sturgeon $4.8 $5.0 $5.7 $6.6

Total Undiscounted $585.8 $609.1 $1,153.1 $1,387.0

3% Discount Rate

Annualized Value $399.1 $415.0 $663.9 $1,210.7

7% Discount Rate

Annualized Value $307.2 $319.5 $460.1 $1,116.7

a The IM&E data used to develop regional estimates are from sampling at the Wabash and Cayuga facilities in 1976, the only year 

of sampling data for these facilities.

Source: U.S. EPA analysis for this report

5.4.2.2 Potential Nonuse Values for T&E Species in the Inland Region

To illustrate the potential magnitude of nonuse values for T&E species affected by IM&E in the 

Inland region, EPA applied a WTP meta-analytical model (Richardson and Loomis 2009) to 

hypothetical scenarios. Because EPA currently does not have region-wide IM&E for all T&E 

species, nor population models to estimate the effect of IM&E on population size, EPA presents 

estimates only to assess the range of benefits potentially resulting from the final rule and other 

options considered. The modeled scenarios estimate the WTP for 0.25 percent and 0.5 percent 

increases for all T&E fish populations in the Inland region.

The model EPA used to estimate nonuse values using benefit transfer is a double log specification 

(Model 4 from Richardson and Loomis (2009)), where:

ln WTP (2006$) = -153.231 + 0.870 ln CHANGESIZE + 1.256 VISITOR + 1.020 FISH + 0.772 

MARINE + 0.826 BIRD – 0.603 ln RESPONSERATE+ 2.767 CONJOINT + 1.024 

CHARISMATIC – 0.903 MAIL + 0.078 STUDYYEAR

Model variables are described in Table 5-7. Excepting all policy-relevant variables, EPA used the 

mean values for all model parameters, and converted estimates to 2011$ using the consumer price 

index (USBLS 2011). 

For a 0.25 percent change in T&E fish population size, projected WTP per household per year is 

$1.07. With 59.9 million households21, total WTP for T&E fish in the Inland region is $63.1

million. For a 0.5 percent change in T&E fish populations, WTP per household is $1.94 per year, 

resulting in WTP values of $114.3 million in the Inland region (all values 2011$).

 

21 Household number in the Inland region is calculated for states where at least one T&E species affected by IM&E 

is found. 
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May 2014 5-17

Table 5-7: Variables in the Richardson and Loomis (2008) Meta-Analysis Model and 

Values Used in EPA’s Application

Variable Name Description Value Used in EPA’s Application

ln WTP Natural log of willingness to pay Estimated by model

ln CHANGESIZE Natural log of the percentage change in 

the population of the species of interest

Log of percentage change in fish 

population: ln(.25) and ln(.5) 

VISITOR = 1 if survey respondents are visitors 

rather than full-time residents 0.0

FISH = 1 for fish species 1.0

MARINE = 1 for marine mammals 0.0

BIRD = 1 for bird species 0.0

ln RESPONSERATE Natural log of the survey response rate 4.0

CONJOINT = 1 for conjoint method surveys 0.0

CHARISMATIC = 1 for charismatic species 0.0

MAIL Indicates mail surveys 0.9

STUDY YEAR Year of study 2007

Sources: Richardson and Loomis (2008), U.S. EPA analysis for this report

5.4.2.3 Sea Turtles

Six species of sea turtles live in U.S. waters: green (Chelonia mydas), hawksbill (Eretmochelys 

imbricata), Kemp's Ridley (Lepidochelys kempii), leatherback (Dermochelys coriacea), 

loggerhead (Caretta caretta), and Olive Ridley (Lepidochelys olivacea) sea turtles. All have 

extensive ranges, migrate long distances during their lifetime, and are listed as either threatened 

or endangered (T&E) under the ESA. Because of these large ranges, substantial overlap exists 

between sea turtle habitat and CWIS for regulated power generating and manufacturing facilities.

Additionally, because individuals of all ages and sizes are susceptible to impingement and 

entrainment (Norem 2005), more than 730 potential interactions between species and CWIS may 

result in the injury or death of these T&E species (Table 5-1, details in Appendix F, Section 1). 

Evidence for Public Values for Sea Turtles

In addition to research sponsored by the National Science Foundation and various private 

philanthropic organizations, federal and state governmental spending on sea turtle protection 

under the ESA totaled $33.8 million in FY2008 (Table 5-4). Moreover, dozens of academic, 

nonprofit, and ecotourism organizations recruit thousands of volunteers every year to participate 

in sea turtle conservation and research projects (Appendix Table F-2). Volunteers are often 

required to undergo substantial training at their own expense and commit to spend long hours 

working, often during the night. For example, the nonprofit organization Earthwatch matches 

volunteers with academic researchers working at field stations around the world. By paying to 

spend time working with scientists on research projects, volunteers support sea turtle research and

conservation both financially and logistically, and gain first-hand experience of conservation 

issues. Trips may last from days to several weeks, and often require a commitment of 10 or more 

hours per day. For example, on one 10-day volunteer trip with a cost of $2,450 (plus airfare), 

volunteers spend time tagging, measuring, and weighing leatherback seat turtles in Trinidad, 

patrolling beaches from sundown to the early hours of the morning (Earthwatch Institute 2010). 

Baseline IM&E of Special Status Species and Potential IM&E Reductions Under the Final 

Rule and Options Considered

Several passive-use (e.g., wildlife viewing and photography) and nonuse values are associated 

with U.S. sea turtle populations. Many households express passive use value by participating in 
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May 2014 5-18

ecotourism activities, such as visiting sea turtle nesting areas, or by participating in sea turtle 

conservation activities (Frazer 2005). Additionally, a high proportion of governmental 

expenditures on T&E species are for turtle species (Table 5-4), suggesting that the public values 

the preservation of sea turtle populations. 

Electric generating facilities are known to impinge and entrain all six species of sea turtles found 

in U.S. waters (Norem 2005), with more than 730 occurrences of overlap between species ranges 

and CWIS (Table 5-1). Incidences of mortality have been reported at facilities in California, 

Texas, Florida, South Carolina, North Carolina, and New Jersey (National Research Council 

1990; Plotkin 1995). These facilities span a wide range of intake flows (less than 30 mgd to more 

than 1,400 mgd AIF), suggesting that sea turtle mortality is not limited to large intakes. Although 

quantitative reports are available from a few power stations, high-quality data is available from 

only one source, the St. Lucie Nuclear Power Plant, at Hutchinson Island, FL, where annual 

capture rates range from 350 to 1,000 turtles (Appendix Table F-1). Despite estimates of 

mortality rates due to entrainment of less than 3 percent, approximately 85 percent of entrained

organisms show evidence of injury as a result of entrainment (Norem 2005). As such, true 

mortality rates from CWIS may be higher than reported, particularly for individuals captured 

repeatedly (37 percent of green and 13 percent of loggerhead sea turtles entrained between May 

and December 2000 were recaptured individuals) (Norem 2005).

Although the magnitude of IM&E is small relative to fishing-related mortality, the cumulative 

impact of IM&E is unclear. The only study presenting a quantitative estimate of annual IM&E 

estimated mortality rates to be between 5 and 50 individuals per year (Plotkin 1995). 

Consequently, sufficient data does not exist to estimate baseline sea turtle mortality due to 

entrainment and impingement at regional or national scales. However, the lower population sizes, 

long life-span, and high reproductive potential of adult turtles (Crouse et al. 1987), mean the final 

existing facilities rule is likely to have only a small effect on the long-term viability of turtle 

populations.

Potential Benefits of Protecting Sea Turtle Species

Per-household WTP

EPA identified a study that used a stated preference valuation approach to estimate the total 

economic value (i.e., use and nonuse values) of a management program designed to reduce the 

risk of extinction for loggerhead sea turtles (Whitehead 1993). The mail survey asked North 

Carolina households whether they were willing to pay for a management program that reduces the 

probability that loggerhead sea turtles will be extinct in 25 years. EPA used Whitehead (1993) to 

assess the range of benefits potentially resulting from the final rule and Proposal Options 2 and 4 

(detailed methodology in Appendix F, Section 2). EPA included the resulting benefits estimates 

here as an illustrative example and did not include them its national benefit totals for the final rule 

and options considered.

EPA reviewed the available data sources and biological models to assess the potential impact of 

baseline IM&E and reductions in IM&E on the probability of sea turtle extinction in 25 years. 

Although analyses of sea turtle extinction risk have been conducted (e.g., Conant et al. 2009), 

EPA was unable to identify an existing model or analysis that could be readily used in 

conjunction with available mortality data to estimate the marginal impacts of CWIS on sea turtle 

extinction risk. Estimates from the literature suggest that IM&E is of relatively low importance 

compared to other human-induced mortality such as shrimp trawling and other fisheries (Plotkin 
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May 2014 5-19

1995). However, Crouse et al. (1987) found that mortality at juvenile and subadult life stages can 

have a substantial effect on population growth, which suggests that small changes in survival at 

these age classes could have a measurable impact on extinction risk. For this illustrative example, 

EPA assumed a marginal change in extinction probability of loggerhead sea turtles due to the 

final rule is of 0.01 (i.e., a 1 percent decrease in the probability of extinction in 25 years). EPA 

bases this assessment upon reports that IM&E may result in the loss of more than 100 turtles per 

year (Appendix Table E-1), and because turtle population growth rates are known to be sensitive 

to changes in juvenile and subadult mortality (Crouse et al. 1987).

EPA used a value of 0.01 within Whitehead’s (1993) modeling framework to estimate household 

values for changes in extinction risk for loggerhead sea turtles as a consequence of the final rule

(details of this calculation are in Appendix Section F-2). Although EPA did not base this 

assessment on formal quantitative analysis of extinction risk, it illustrates the magnitude of 

potential benefits associated with reductions in sea turtle IM&E. Using the published mean values 

for all other model parameters, EPA calculated an annual household value of $0.37 (2011$). 

Estimates were converted to 2011dollars using the consumer price index (USBLS 2011). 

Total WTP for all Households

Whitehead’s (1993) study for loggerhead sea turtle management activities was based on a statewide survey of North Carolina residents. However, the large geographic range of sea turtles 

suggests that households of many coastal states through their U.S. range would value activities 

that decrease their extinction risk. There is also the potential for differential values within and 

across states. Households farther away from the resource may value sea turtle survival less than 

households near the ocean because they are less likely to participate in passive uses of the 

resource. Although EPA recognizes that the application of the benefit transfer may overestimate 

household values for states with population centers far from sea turtle habitat, evidence from the 

literature suggests that households may value changes in environmental resource that are 

occurring at great distances. For example, Pate and Loomis (1997) found that respondents were 

willing to ascribe stated preference values to environmental amenity changes in other states. As 

such, by focusing on residents of coastal states only, estimated benefits may undervalue national 

willingness to pay for the preservation of loggerhead sea turtles.

As noted above, EPA includes its calculations for the benefits of protecting sea turtles here as an 

illustrative example. For this example, EPA focused solely on impacts to loggerhead sea turtles 

(one of six T&E sea turtle species in the United States). By focusing only on loggerhead sea 

turtles, EPA notes that estimated benefits are likely to be lower than those held by individuals for 

all T&E turtle species. EPA chose this species of turtles because they are late-maturing, have an 

existing population model (Crouse et al. 1987), an existing valuation study (Whitehead 1993), 

and are the most commonly affected species of turtle (Appendix F). The U.S. range of loggerhead 

sea turtles includes the Gulf of Mexico, South Atlantic, Mid-Atlantic, and North Atlantic 316(b) 

regions (USFWS 2010b). Assuming affected populations include all households within states 

with regulated facilities that potentially have an impact on loggerhead sea turtles, 54.83 million 

households would be willing to pay for improved protection of this species (Table 5-8). EPA 

applied the mean household WTP of $0.37 (2011$) to all four regions because the Whitehead 

(1993) function does not include income or other demographic variables that allow estimation of 

state-specific WTP. The total annual WTP for a 1 percent increase in the survival probability of 

loggerhead sea turtles annualized at a 3 percent discount rate is $19.3 million. Annualized 

benefits for each region are presented in Table 5-8, assuming that benefits begin to accrue in 2014 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 5: Impacts and Benefits on T&E Species

May 2014 5-20

and continue throughout the compliance period. Because EPA does not currently have accurate 

national estimates of IM&E for turtle species, nor are population models available that estimate 

the effect of the existing facilities rule on population size and extinction risk, EPA is presenting 

these estimates only to assess the potential range of benefits, and is not including them in national 

benefits totals for the final rule and options considered. Actual benefits may be higher or lower 

than these estimates, with Proposal Option 2 likely to provide substantially greater benefits than 

the final rule and Proposal Option 4.

Table 5-8: Benefits of a 1 Percent Increase in the Probability that Loggerhead Sea 

Turtles Will Not Be Extinct in 25 Years

Region States Included

Number of 

Households 

(millions)

Annualized Benefits

(2011$, millions)

3% Discount Rate 7% Discount Rate

North Atlantic CT, MA, ME, 

NH, RI 5.41 $1.90 $1.86

Mid-Atlantic DE, MD, NJ, 

NY, PA, VA 21.11 $7.41 $7.25

South Atlantic FL, GA, NC, SC 12.06 $4.24 $4.14

Gulf of MexicoaFL, LA, MS, TX 16.26 $5.71 $5.59

Total - 54.83 $19.26 $18.84

a

Florida households are included in both the South Atlantic and Gulf of Mexico regions. To prevent double-counting, 

Florida households were apportioned between these regions based on relative AIF.

Note: Because of uncertainty in estimates of increased survival probability, and because benefits were not calculated for 

options, these values are not included in national totals.

Source: U.S. EPA analysis for this report

5.4.3 Limitation and Uncertainties

Table 5-9 summarizes the caveats, omissions, biases, and uncertainties known to affect the 

estimated benefits for sea turtles (Section 5.4.2.3), and T&E finfish in the Inland region (Section 

5.4.2.1). 
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May 2014 5-21

Table 5-9: Caveats, Omissions, Biases, and Uncertainties in the T&E Species Benefits 

Estimates

Issue Impact on Benefits 

Estimate Comments

Change in T&E populations 

due to IM&E is uncertain

Estimates 

understated

Projected changes in number of fish affected may be 

underestimated because neither cumulative impacts of 

IM&E over time nor interactions with other stressors are 

considered.

IM&E effects are not 

estimated for all T&E species 

and all regions

Estimates 

understated

EPA was unable to estimate IM&E of T&E species for 

all regions due to lack of data. The large amount of 

overlap between T&E ranges and CWIS suggests that 

many affected species are likely to be missing from 

IM&E reports.

Benefit estimates include 

only a subset of species 

identified as affected

Estimates 

understated

EPA was unable to apply benefit transfer of values for 

all affected species. Benefits estimates address 80 to 84 

percent of documented T&E A1E losses in the Inland 

region.

Benefit estimates used in 

benefit cost analysis include 

only recreational use values

Estimates 

understated

EPA applied recreational use values to estimate benefits 

for the species included in the analysis. Values held for 

T&E species are primarily nonuse values, which were 

not monetized. In addition, some of the affected species 

have commercial use values, which were not estimated.

Benefit transfer introduces 

uncertainties Uncertain

EPA applied a recreational use value for sturgeon in 

California to value sturgeon and paddlefish in the Inland 

region. This value may over- or understate recreational 

values of sturgeon and paddlefish in the Inland region.

Ecological consequences of 

reduced numbers of T&E 

species 

Estimates 

understated

WTP values are unlikely to include damage to foodwebs and ecosystem stability as a consequence of the 

removal or restoration of T&E species.

Effects of thermal impacts 

from CWIS on T&E 

populations is uncertain

Uncertain EPA has few data on the effect of thermal discharge on 

T&E species.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 6: Commercial Fishing Benefits

May 2014 6-1

6 Commercial Fishing Benefits

Commercial fisheries can be adversely affected by IM&E in addition to many other stressors.

Commercially landed fish are exchanged in markets with observable prices and quantities; 

however, estimating the change in economic surplus from increases in the number of 

commercially landed fish requires consideration of various conceptual and empirical issues. This 

chapter provides an overview of these issues, and presents how EPA estimated the change in 

commercial fisheries-related economic surplus associated with the elimination of, and reduction 

in, baseline IM&E under the final rule and regulatory options it considered. 

This chapter includes a review of the concept of economic surplus, and describes economic 

theory and empirical evidence regarding the relationship between readily observable dockside 

prices and quantities and the economic welfare measures of producer and consumer surplus that 

are suitable for benefit-cost estimation.

Section 6.1 describes the methodology used to estimate the commercial fisheries-related benefits, 

including conceptual and empirical discussions of producer and consumer surplus. Section 6.2

presents the commercial fisheries-related benefits by region, and Section 6.3 presents the 

limitations and uncertainties associated with EPA’s analysis.

6.1 Methodology

The methodology EPA employed to estimate the commercial fishing benefits associated with the 

regulatory options for the final rule closely follows the analysis EPA conducted for the Section 

316(b) Phase III Final Rule (USEPA 2006b). Changes from that analysis include updated 

estimates of baseline IM&E and IM&E reductions, and updated dockside prices. EPA estimated 

dockside prices based on the five-year average price between 2007 and 2011, from commercial 

fishing landings data obtained from the National Oceanic and Atmospheric Administration’s 

National Marine Fisheries Service (NMFS) (NMFS 2012a).

EPA measured commercial fishing benefits as changes in producer surplus. Estimated benefits for 

each region are presented in Section 6.2. EPA also considered potential consumer surplus values 

associated with IM&E, but did not estimate changes in consumer surplus for the final rule and 

options considered because it found that dockside prices would not change enough to produce 

measurable shifts in consumer surplus. Appendix H presents the details of EPA’s assessment of 

consumer surplus. 

6.1.1 Estimating Consumer and Producer Surplus

The total loss to the economy from IM&E impacts on commercially harvested fish species is 

determined by the sum of changes in both producer and consumer surplus (Hoagland and Jin 

2006). EPA modeled IM&E using the methods presented in Chapter 3. EPA assumed a linear 

relationship between stock and harvest. That is, if 10 percent of the current commercially targeted 

stock were harvested, EPA assumed that 10 percent of any increase in that species due to lower 

IM&E would be harvested. Thus, EPA assumed that the percentage increase in harvest is the 

same as the percentage increase in the fish population. The percentage of fish harvested is based 

on historical fishing mortality rates. EPA used historical NMFS landings data on commercial and 

recreational catch to determine the proportions of total species landings attributable to 
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May 2014 6-2

recreational and commercial fishing. EPA applied these proportions to the estimated total change 

in harvest to distribute benefits between commercial and recreational fisheries.

Producer surplus provides an estimate of the economic benefits to commercial fishers. Welfare 

changes can also be expected to accrue to final consumers of fish and to commercial consumers,

including processors, wholesalers, retailers, and middlemen, if the projected increase in catch due 

to the rule is accompanied by a decrease in price. These impacts can be expected to flow through 

the tiered commercial fishery market (as described in Holt and Bishop (2002)).

Holt and Bishop (2002) used a fishery market model to estimate changes in welfare as a result of 

changes in the level of the commercial fishing harvest. The market model takes as inputs the 

expected change in harvest and baseline gross revenues, and provides as outputs the expected 

change in producer and consumer surplus. In general, the analysis of market impacts involves the 

following steps (Bishop and Holt (2003)):

1. Assessing the net welfare changes for fish consumers due to changes in fish harvest and 

the corresponding change in fish price.

2. Assessing net welfare changes for fish harvesters due to the change in total revenue, 

which could be positive or negative.

3. Calculating the change in net social benefits when the fish harvest changes.

Figure 6-1 illustrates a simplified fishery market model as shown in Bishop and Holt (2003). For 

simplicity, the authors assume that the fishery is managed on quota basis with the baseline quota 

shown as F

1

and baseline dockside or ex-vessel price as P

1

. They use an inverse demand function, 

P(F), because fish are perishable, with the quantity harvested driving price in the short run. 

Figure 6-1: Fishery Market Model, reproduced from Bishop and Holt (2003)

6.1.1.1 Step 1: Assessing Benefits to Consumers

The downward sloping line labeled P(F), depicted in Figure 6-1, represents a general equilibrium 

demand function that accounts for markets downstream of commercial fishers. As described 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 6: Commercial Fishing Benefits

May 2014 6-3

above, the vertical curve F

1

is the quantity of fish supplied to the market by commercial fishers 

under the baseline conditions. Equilibrium is attained at the point where P(F) equals F

1

. The 

intersection of these two lines gives the price P

1

at which quantity F

1

is sold. In this case the total 

amount paid by consumers for fish is equal to P

1

× F

1

, which is equal to the area of the boxes U + 

V + W in the graph. The consumer surplus, or benefit to consumers, is equal to the area of the 

triangle T.

The measurement of the benefits from reducing IM&E relies on the assumption that a decrease in 

mortality of fish, larvae, and eggs under a scenario of reduced IM&E would increase fish 

populations and the quantity of fish supplied to consumers (i.e., an increase from F

1

to F

2

). If the 

quantity of fish available to the market increases from F

1

to F

2

, this in turn would result in a lower 

market price for fish (i.e., P

2

). The total amount paid by consumers changes to P

2× F2

, which is 

equal to the area of the boxes V + W + Y + Z. This area may be smaller or larger than area U + V 

+ W, but unequivocally increases the consumer surplus so that it is equal to the area of the 

triangle T + U + X. The difference in consumer surplus between the reduced IM&E scenario and 

the current baseline scenario (i.e., U + X) is the measure of benefits to consumers from reducing 

IM&E. 

Estimating the change in the price of fish from changes in commercial fish harvest requires the 

following input data: (1) an estimate of the baseline prices and quantities of the commercial 

fishing harvest, (2) the estimated change in the commercial fishing harvest under the reduced 

IM&E scenario, and (3) an understanding of the price elasticity of demand for fish. The price 

elasticity of demand for fish measures the percentage change in demand in response to a 

percentage point change in fish price. Thus, the inverse elasticity, or price flexibility, measures 

the percent change in price for a given percent change in quantity. 

To properly estimate price changes, it is necessary to consider the contribution of the species to 

the overall market. Because individual demand functions incorporating substitutes are not 

available for most species, EPA estimated price changes in the following way. 

The Agency estimated the total baseline harvest for relevant species (commercial species of 

similar types to those affected by IM&E) using NMFS landings data from 2007 to 2011in three 

categories: finfish, shrimp, and crabs.22 EPA aggregated the species to account for substitution. 

The totals for finfish were summed for the East Coast and Gulf, and for the West Coast, while 

totals for shrimp and crabs were summed across all coastal regions.23 EPA summed estimated 

harvest increases from the elimination of baseline IM&E according to the same species and 

regional categories (column 3 in Table 6-1). 

EPA estimated price elasticity of demand based on a review of the economics literature (Asche et 

al. 2005; Capps Jr. and Labregts 1991; Cheng and Capps Jr. 1988; Davis et al. 2007; Lin et al. 

1988; Tsoa et al. 1982) (column 6 in Table 6-1) . The percentage change in price was calculated 

by dividing percentage change in harvest by elasticity. As shown in Table 6-1, the expected price 

changes resulting from eliminating baseline levels of IM&E are very small, ranging from 0.21

percent to 2.5 percent. EPA expects that price changes would be substantially less for the final 

rule due to much lower reductions in IM&E. Appendix H of this document presents the detailed 

calculations and results.

 

22 For example, offshore species such as tuna and swordfish, baitfish species, and shellfish were not included.

23 Harvests for Alaska and Hawaii were not included in the totals.
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May 2014 6-4

Table 6-1: Estimated Average Percentage Change in Ex-Vessel Price by Region and 

Species Group from the Elimination of Baseline IM&E

Region Species 

Group

Increase in Harvest 

from Elimination of 

Baseline IM&Ea

(lbs)

Total Average 

Annual Harvesta

Percentage 

Change in 

Harvest

Elasticity

Percentage 

Change in 

Priceb

California Finfish 1,920,625 489,705,990 0.39% -1.89 -0.21%

East Coast 

and Gulf Finfish 12,548,060 265,617,830 4.72% -1.89 -2.50%

All Regions Crabs 1,373,553 258,973,619 0.53% -1.31 -0.40%

All Regions Shrimp 369,750 279,365,691 0.13% -0.63 -0.21%

a

Sum of total landings for all relevant species.

b

Percentage changes in price reflect the average across all species within the species group and region.

Sources: U.S. EPA analysis for this report, NMFS (2012a)

EPA did not include estimates of changes in consumer surplus for commercial species. Prices 

must change in order for consumer surplus to change. Most species of fish have numerous close 

substitutes. The literature suggests that when there are plentiful substitute fish products, numerous 

fishers, and a strong ex-vessel market, individual fishers are generally price takers. Although 

there are exceptions, fisheries economics studies often make these assumptions in analyzing 

regional effects from harvest changes (e.g., Herrmann 1996; Thunberg et al. 1995) and 

international markets (e.g., Clarke et al. 1992). Consumer surplus measures that NMFS has 

estimated for past environmental impact statements tend to be quite low. NMFS fisheries analyses 

incorporate price changes for large changes in regional or national harvest, such as stock 

rebuilding. However, for small changes in landings, such as those EPA expects under the final 

rule, it is standard to assume that prices are fixed.24

6.1.1.2 Step 2: Assessing Producer Surplus

In an unregulated fishery, the long-run change in producer surplus due to an increase in fish 

stocks will be zero percent of the change in gross revenues because in open access fisheries, 

excess profits are always driven to zero at the margin. Most fisheries are, however, regulated with

quotas or restrictive permits to prevent overfishing. Thus, lasting economic benefits accrue to 

commercial fishers from reductions in IM&E and the subsequent increase in harvest. Fishery 

regulations seek to create sustainable harvests that maximize resource rents.25 In a regulated 

fishery, IM&E impacts reduce the number of fish available to harvest. This reduction may lead to 

more-stringent regulations and decreases in harvest. In this case, the change in producer surplus 

can be related to the change in harvest and the resulting gross revenue.

In Figure 6-1, the line C represents the cost to the producer of supplying a pound of fish. The 

model assumes that average cost is equal to marginal cost, that is, C is constant for all pounds

produced.26 When the supply of fish is equal to F

1

, the commercial fishers sell F

1

pounds of fish 

at a price of P

1

and earn revenues equal to U + V + W. The area between P

1

and C is the producer 

 

24 Personal communications with NMFS economists Cindy Thomson (2008), Eric Thunberg (2008), Steve Freese 

(2008), and Sabrina Lovell (2013).

25 In addition, even in open access fisheries, intramarginal rents are earned by at least some boats (Thunberg 2008).

26 If marginal costs increase as harvest increases, some of the producer surplus per unit will be lost due to the

increased costs.
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May 2014 6-5

surplus that accrues to producers for each pound of fish. Total producer surplus realized by 

producers is equal to (P

1

- C) × F

1

. In the example, this producer surplus is equal to the area of U 

+ V. The area W is the amount that producers pay for capital and labor and to suppliers if the 

harvest equals F

1

(e.g., fishing gear and the costs of operating in the market).

When supply increases to F

2

, the producers sell F

2

pounds of fish at a price of P

2

. The total cost to 

produce F

2

increases from W to W + Z. The total producer surplus changes from U + V to V + Y.

This change may be either positive or negative, depending on the relative elasticity of demand,

which changes the relative sizes of areas U and Y.

In theory, producer surplus is equal to normal profits (total revenue minus fixed and variable 

costs), minus the opportunity cost of capital. The fixed costs and inputs are incurred 

independently of the expected marginal changes in the level of fish landings (Squires et al. 1998; 

Thunberg and Squires 2005). Total variable costs including labor, fuel, ice, and other supplies, 

however, vary directly with the level of landings. Furthermore, because EPA estimated the 

opportunity cost of capital to be only about 0.4 to 2.6 percent of producer surplus, EPA assumed 

that normal profits are a sufficient proxy for producer surplus (USEPA 2004a). As a result, EPA’s 

assessment of producer surplus is a relatively straightforward calculation in which the change in 

producer surplus is calculated as a species- and region-specific fraction of the change in gross 

revenue due to increased landings.

The change in producer surplus, captured by “normal profits,” is assumed to be equivalent to a 

fixed proportion of the change in gross revenues. EPA estimated gross revenue change from the 

change in the commercial harvest due to reducing IM&E, and the change in prices associated 

with the increased commercial harvest. As discussed above, EPA estimated price changes to be 

negligible, and therefore did not include price changes in the model. EPA estimated species- and 

region-specific Net Benefits Ratios, which represent the fractional share of gross revenue 

associated with net benefits. EPA’s approach for estimating Net Benefits Ratios using available 

data on variable costs from sources such as the NMFS is described in more detail in 

Section A4-10 of US EPA (2006). EPA then applied the Net Benefits Ratio to the estimated 

change in gross revenue under the 316(b) final rule and regulatory options EPA considered to 

estimate the increase in producer surplus.

Table 6-2 to Table 6-7 present the Net Benefit Ratios, which range from 0.15 to 0.85, by regions 

and species.

27,28

 See Chapter 1, Section 1.2 for descriptions of the seven study regions. EPA 

excluded the Inland region from the analysis because of a negligible commercial fishing harvest 

in this region. EPA notes that this approach yields an estimate of benefits to commercial 

fisherman, not benefits to society as a whole because changes in consumer surplus are not 

captured, and because people may also have nonmarket values for commercial fish (e.g., 

recreational and existence values). As described in Section 6.1.1.1, EPA did not estimate changes 

in consumer surplus because the expected changes in consumer surplus due to the final rule will 

 

27 Positive Net Benefits Ratios reflect the assumption that commercial fishers will accrue rents (profits) in regulated 

fisheries. When calculating the Net Benefits Ratios, EPA assumed that the predicted changes in harvest are such 

that fixed costs and variable costs per ton will not change. If costs remain constant, a marginal change in harvest is 

more likely to result in increases in profit and positive producer surplus.

28 In the case of species aggregates (e.g., forage species), EPA assumed that the net benefit ratio is equal to the 

simple average of all empirically estimated net benefit ratios in the region. Species aggregates are listed as “Other” 

in Table 6-2 to Table 6-7.
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be minor. EPA’s analysis of nonmarket benefits for fisheries improvements is presented in 

Chapter 8. 

Table 6-2: California Region, Management Method, Gear Type, Status of Stock, and Net 

Benefits Ratio, by Species

Species Main Management 

Method

Main Gear 

Type Status of Stocka Net Benefits Ratio

Anchovies Annual landings Roundhaul Not subject to 

overfishing 0.64

Cabezon Total allowable catch Hook-and-line Not overfished or subject 

to overfishing 0.52

Crabs Seasonal closures Pots and traps Undefined 0.74

Drum and Croaker Permits Nets Unknown 0.42

Dungeness Crab Size, no females, closed 

during molting season Traps Unknown 0.74

Flounders Quotas Bottom trawl Not overfished or subject 

to overfishing 0.64

California Halibut Total allowable catch Longline Unknown 0.58

Other N/A N/A N/A 0.53

Rockfish Quotas Trawls Not overfished or subject 

to overfishingb 0.62

California 

Scorpionfish Quotas Otter trawl Not overfished 0.47

Sculpin Nonrestrictive permits Trawls Unknown 0.64

Sea Bass Season, size, gear 

restrictions Gillnets Unknown 0.66

Shad, American None Nets Unknown 0

Shrimp Seasonal closures Trawl Unknown 0.15

Smelt Seasonal closures Nets Unknown 0.66

Surfperch Quotas Handlines Overfished but not 

subject to overfishingb,c,d 0.37

N/A = not applicable

a Status of stock designations based on data from the NMFS, Summary of Stock Status, 2nd Quarter 2012 (NMFS 2012b).

b

Species group consists of many individual component species with conflicting stock status. The most common stock status 

among the component species was designated the Status of Stock for the species group.

c "Perch" species were used as a proxy for surfperch.

d

“Overfished but not subject to overfishing” means that the fish stock is at a low level but is expected to rebuild given 

current rates of commercial fishing.
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Table 6-3: North Atlantic Region, Management Method, Gear Type, Status of Stock, and 

Net Benefits Ratio, by Species

Species Main Management 

Method Main Gear Type Status of Stocka Net Benefits Ratio

Bluefish Quotas Gillnets Not overfished or subject 

to overfishing 0.63

Butterfish Quotas NA Not subject to overfishing 0.64

Atlantic Cod Time/area closures Otter trawl Overfished or subject to 

overfishing 0.66

Crab Size, sex, season Traps Unknown 0.57

American Plaice Size Otter trawl Not overfished or subject 

to overfishing 0.63

Windowpane Time/area closures Bottom trawl Overfished but not subject 

to overfishingb,c 0.63

Winter Flounder Quotas Otter trawls Overfished but not subject 

to overfishingb 0.64

Flounder Total allowable landing Bottom trawl Overfished or subject to 

overfishingb 0.63

Red Hake Quotas Otter trawls Not overfished or subject 

to overfishing 0.62

Silver Hake Quotas Otter trawls Not overfished or subject 

to overfishing 0.63

Atlantic Herring Total allowable catch Purse seine Not overfished or subject 

to overfishing 0.76

Atlantic 

Mackerel Annual quota Unknown Not overfished or subject to overfishing 0.77

Atlantic 

Menhaden Not reg. In this area Unknown Subject to overfishing but not overfished 0.68

Other N/A N/A N/A 0.57

White Perch Size limits Unknown Unknown 0.82

Pollock Time/area closures Bottom trawl Not overfished or subject 

to overfishing 0.71

Sculpin Open access Unknown Unknown 0

Scup Quotas Otter trawls Not overfished or subject 

to overfishing 0.69

Searobin Open access (by catch) Unknown Unknown 0

Shad, American Mortality targets Unknown Overfished 0.6

Skate Catch limits Otter trawl Not overfished or subject 

to overfishingb 0.68

Tautog Possession limits Otter trawl Unknown 0.46

Weakfish Size limits Trawls Overfished but not subject 

to overfishing 0.76

N/A = not applicable

a Status of stock designations based on data from the National Marine Fisheries Service, Summary of Stock Status, 2nd Quarter 2012 

(NMFS 2012b). Supplemental stock status designations based on data from the Atlantic States Marine Fisheries Commission 

(ASMFC 2012).

b Species group consists of many individual component species with conflicting stock status. The most common stock status among 

the component species was designated the Status of Stock for the species group.

c

“Overfished but not subject to overfishing” means that the fish stock is at a low level but is expected to rebuild given current rates 

of commercial fishing.
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Table 6-4: Mid-Atlantic Region, Management Method, Gear Type, Status of Stock, and 

Net Benefits Ratio, by Species

Species Main Management 

Method Main Gear Type Status of Stocka Net Benefits Ratio

Alewife Bans, species of concern Fish weirs Overfished 0.85

American Shad Chesapeake fishery 

closed Unknown Overfished 0.84

Atlantic Croaker Gear restrictions Gillnets Not overfished or subject to 

overfishing 0.74

Atlantic 

Menhaden Open access Purse seine, otter trawl, gill net

Not overfished or subject to 

overfishing 0.67

Black Drum Quotas Unknown Unknown 0.7

Blue Crab Limits on female crabs, 

size Pots Unknown 0.57

Bluefish Quotas Gillnets Not overfished or subject to 

overfishing 0.63

Butterfish Quotas Unknown Not subject to overfishing 0.64

Crab Season, size Unknown Unknown 0.57

Drum and 

Croaker Gear restrictions, quotas Nets Not subject to overfishing 0.74

Flounder Quotas Bottom trawl Not overfished or subject to 

overfishing 0.65

Other N/A N/A N/A 0.73

Red Hake Quotas Otter trawls Not overfished or subject to 

overfishingb

0.62

Scup Quotas Otter trawls Not overfished or subject to 

overfishing 0.69

Searobin Open access Unknown Unknown 0

Silver Hake Quotas Otter trawls Not overfished or subject to 

overfishingb

0.63

Spot License Haul seines Unknown 0.84

Striped Bass Quotas Gill nets Not overfished or subject to 

overfishing 0.67

Striped Mullet Gear restrictions Cast nets Unknown 0.7

Tautog Possession limits Otter trawl Overfished and subject to 

overfishing 0.46

Weakfish Size limits Trawls Overfished but not subject 

to overfishingc

0.76

White Perch Size limits Unknown Unknown 0.82

N/A = not applicable

a Status of stock designations based on data from the NMFS, Summary of Stock Status, 2nd Quarter 2012 (NMFS 2012b). 

Supplemental stock status designations based on data from the Atlantic States Marine Fisheries Commission (ASMFC 2012).

b Estimates from the North Atlantic region are presented because red and silver hake stocks were not reported in the Mid-Atlantic 

region.

c

“Overfished but not subject to overfishing” means that the fish stock is at a low level but is expected to rebuild given current rates 

of commercial fishing.
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Table 6-5: South Atlantic Region, Management Method, Gear Type, Status of Stock, and 

Net Benefits Ratio, by Species

Species Main Management 

Method Main Gear Type Status of Stocka Net Benefits Ratio

Blue Crab Size limits Pots Unknown 0.57

Crab Size, sex, season limits Traps Unknown 0.57

Drum and 

Croaker Open access (by catch) Otter trawl bottom, gill nets Not subject to overfishing 0.54

Atlantic 

Menhaden

Five year annual cap on 

reduction fishery in 

Chesapeake

Unknown Subject to overfishing but 

not overfished 0.76

Other N/A N/A N/A 0.59

Spot License Haul seines Unknown 0.7

Stone Crab Size limits Traps Unknown 0.58

Weakfish Size limits Trawls Overfished but not subject 

to overfishingb 0.64

a Status of stock designations based on data from the NMFS, Summary of Stock Status, 2nd Quarter 2012 (NMFS 2012b). 

Supplemental stock status designations based on data from the Atlantic States Marine Fisheries Commission (ASMFC 2012).

b

“Overfished but not subject to overfishing” means that the fish stock is at a low level but is expected to rebuild given current rates 

of commercial fishing.

Table 6-6: Gulf of Mexico Region, Management Method, Gear Type, Status of Stock, and 

Net Benefits Ratio, by Species

Species Main Management 

Method Main Gear Type Status of Stocka Net Benefits Ratio

Blue Crab Limited entry, pot limits Pots Unknown 0.72

Black Drum Limited access permits Hand lines, gill nets Unknown 0.69

Leatherjacket N/A

Rod/reel, hand and 

long lines, pots and 

traps

Unknown 0

Mackerels Quotas Hook-and-line Not overfished or subject to 

overfishing 0.75

Menhaden Seasonal/area closures Purse seines Unknown 0.76

Other N/A N/A N/A 0.46

Sea Basses Quotas Traps Unknown 0.72

Sheepshead Size Cast net Unknown 0.84

Shrimp Same as pink shrimp Unknown Not overfished or subject to 

overfishingb 0.43

Spot License Haul seines Unknown 0.54

Stone Crab Size Traps Not subject to overfishing 0.71

Striped Mullet Gear restrictions Strike nets Unknown 0.79

Striped Mullet Gear restrictions Strike nets Unknown 0.79

a Status of stock designations based on data from the NMFS, Summary of Stock Status, 2nd Quarter 2012 (NMFS 2012b).

b

Species group consists of many individual component species with conflicting stock status. The most common stock status among 

the component species was designated the Status of Stock for the species group.
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Table 6-7: Great Lakes Region, Management Method, Gear Type, Status of Stock, and 

Net Benefits Ratio, by Species

Species Main Management 

Method Main Gear Type Status of Stock Net Benefits Ratio

Bullhead State specific Gill and trap nets Unknown 0.29

Freshwater Drum State specific Gill and trap nets Unknown 0.29

Other State specific Gill and trap nets Unknown 0.29

Smelt State specific Gill and trap nets Unknown 0.29

White Bass State specific Gill and trap nets Unknown 0.29

Whitefish State specific Gill and trap nets Unknown 0.29

Yellow Perch State specific Gill and trap nets Unknown 0.29

6.1.1.3 Step 3: Estimating Net Social Benefits When the Fishing Harvest Increases

EPA estimated the change in net social benefits when the commercial fishing harvest increases 

from F

1

to F

2

by adding the results from Steps 1 and 2. Because area U is a transfer from 

commercial fishers to consumers, it does not affect social benefits. Therefore, the change in net 

social benefits is area X + Y (see Figure 6-1). However, if demand elasticity is such that changes 

in price are negligible, as EPA expects (Section 6.1.1.1), area X will be negligible relative to Y,

and total social benefits will be measured by area Y.

6.2 Benefits Estimates for Regional Commercial Fishing

The first step of the analysis of commercial fishing benefits involves a fishery-based assessment 

of IM&E-related changes in harvested species landings. Many of the fish species affected by 

IM&E at CWIS sites are harvested both recreationally and commercially. As described in Section 

6.1.1, EPA assumed a linear relationship between stock and harvest and used historical NMFS 

landings data on commercial and recreational catch to determine the proportions of total species 

harvest attributable to recreational and commercial fishing. EPA applied these proportions to the 

estimated total change in harvest to distribute benefits between commercial and recreational 

fisheries. EPA then used the estimated change in commercial fishery harvest as a basis for 

estimating changes in producer surplus in the commercial fishing industry. 

EPA assessed whether potential harvest increases under the final rule and options considered are 

reasonable when compared to historic harvest data. For this assessment, EPA compared estimated 

increases in commercial yield from the elimination of baseline IM&E for each species to average 

regional commercial harvest from 2007 to 2011. Table 6-8 summarizes baseline IM&E and 

harvest data for fourteen species for which the potential increase in commercial yield from the 

elimination of baseline IM&E exceeds 10 percent of regional harvest. 

Notably, none of the species identified include major fisheries: many are infrequently targeted, 

and several have historical commercial harvests which vary widely on an annual basis. In many 

cases, the species identified are not subject to a federal fisheries management plan, and the 

overall status of stock is unknown. These uncertainties may increase the error associated with the 

regional-scale effects occurring as a consequence of the extrapolation of IM&E. Moreover, it is 

possible that the regional extrapolation of species-specific results may be biased because 

available IM&E studies are old (and therefore reflect IM&E under substantially different 

populations), or because particularly high IM&E counts at one or more facilities measured during 

an anomalous year may result in erroneous estimates of IM&E. 
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The sixteen species for which the potential increase in commercial yield from the elimination of 

baseline IM&E exceeds 10 percent of regional harvest include cabezon, California halibut, 

rockfish, and sculpin in the California region; sculpin in the North Atlantic region; spot, and 

weakfish in the Mid-Atlantic region; black drum, drum and croaker, leatherjacket, spot, and 

striped mullet in the Gulf of Mexico region; and freshwater drum, smelt, and white bass in the 

Great Lakes region. No increases exceeding 10 percent were found in the South Atlantic region. 

Among these fourteen species, the potential harvest increases range from 12 percent for striped 

mullet in the Gulf of Mexico to 1,512 percent for sculpin in the North Atlantic.

EPA used harvest and fisheries data to develop reasonable caps on increases in commercial 

harvest from the elimination of baseline IM&E and IM&E reductions under the final rule and 

options considered. Economists and biologists with NMFS recommended using either maximum 

sustainable yield (MSY) or historical harvest to assign reasonable caps on projected total harvest

under the post-compliance scenario.29 NMFS biologists provided MSY for three species groups: 

California cabezon, California sculpin, and West Coast rockfishes.

30 While there is no stock 

assessment for halibut, NMFS biologists suggested averaging the most recent four peaks in 

harvest. For other species lacking MSY data, EPA capped post-compliance harvest at the 90th

percentile of annual harvest from 1982 to 2011. This follows recommendations from NMFS 

scientists to use harvest data for 25 years or more.31

North Atlantic sculpin. Mid-Atlantic spot, and Great Lakes freshwater drum and white bass were 

the only four species estimated to reach these caps within EPA’s analysis. Caps for these four 

species are shown in bold type in Table 6-8. Notably, historical commercial catch of both North 

Atlantic sculpin and Mid-Atlantic spot are widely variable. For example, between 1995 and 2011, 

there were several years with no commercial catch of sculpin reported. For spot, commercial 

harvests changed by more than 2 million pounds per year (alternating between increases and 

decreases) for each year between 2006 and 2011. For Northeast Atlantic sculpin and Mid-Atlantic 

spot, these data suggest that commercial catch may not be limited by fish population, and that a 

large and sustained increase in commercial landings beyond the cap due to the reduction of 

IM&E is unreasonable.

The following sections present estimated benefits from commercial harvest changes in six of the 

seven study regions and the total for the six regions. The Inland region is excluded from the 

analysis due to a negligible commercial fishing harvest in this region.

 

29 Cindy Thomson, NMFS, personal communication (2008).

30 NMFS biologists suggested that sculpin in California be evaluated in combination with scorpionfish, as these 

species are grouped when determining the MSY.

31 Many fish populations peaked more than 25 years ago, when virgin, non-exploited populations existed and

maximum harvests were achievable.
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Table 6-8: Potential Harvest Increase from Eliminating IM&E as a Percentage of Total 

Harvest and Potential Harvest Capping Rules Used in EPA’s Analysis

Region and

Species

Baseline 

Harvest

2007-2011

(1,000 lbs.)

Baseline 

IM&E 

(1,000 lbs.)

Potential 

% 

Increase 

in 

Harvest

Maximum 

Harvest

1982-2011 

(1,000 lbs.)

90th 

Percentile 

of Max. 

Harvest 

(1,000 lbs.)

MSY or 

Other 

Capping 

Rule 

(1,000 lbs.)

Cap Used

(1,000 

lbs.)

California 

Cabezon 53.7 76.1 142% 374.2 261.2 207.2a No Cape

California Halibut 495.5 176.9 36% 1,337.1 1.238.4 982.1b No Cap

California Drum 

and Croaker 53.8 6.9 13% 1,491.5 1,288.6 No Cap

California 

Rockfish 2,741.3 1,634.5 60% 58,286.7 42.942.2 77,161.8c No Cap

California Sculpin 3.8 3.7 97% 19.5 7.6 482.8 d No Cap

North Atlantic 

Sculpins 1.6 24.2 1,512% 4.8 4.8 4.8

Mid-Atlantic Spot 3,478.4 1,303.1 37% 4,784.6 4,543.0 4,543.0

Mid-Atlantic 

Weakfish 267.4 503.7 188% 7,023.5 6,714.1 No Cap

Gulf of Mexico 

Black Drum 4,621.9 1,945.0 42% 10,644.4 7,314.6 No Cap

Gulf of Mexico 

Drum and 

Croaker

111.8 47.8 43% 2,934.7 663.8 No Cap

Gulf of Mexico 

Leatherjacket 61.0 107.1 176% 519.7 447.4 No Cap

Gulf of Mexico 

Spot 16.9 46.3 274% 473.4 356.4 No Cap

Gulf of Mexico 

Striped Mullet 10,800.3 1,343.6 12% 30,433.6 27,789.7 No Cap

Great Lakes 

Freshwater Drum 585.9 248.8 42% 905.1 795.0 209.1 795.0

Great Lakes 

Smelt 380.5 92.9 24% 4,105.0 3,672.0 No Cap

Great Lakes 

White Bass 523.6 916.5 175% 1,332.0 771.7 248.1 771.7

a MSY (maximum sustainable yield).

b Average of most recent four peaks in harvest.

c MSY for rockfishes for the West Coast.

d MSY for all scorpionfish and sculpins.

e

“No Cap” indicates that no cap was used during benefit estimation because increases did not result in exceedance of the 90th

percentile of maximum harvest, MSY, or other capping rule.

Sources: U.S. EPA analysis for this report; NMFS data on baseline harvest, historical landings, and MSY.

6.2.1 California Region

Baseline levels of IM&E account for 1.9 million pounds of commercial fishing losses annually in 

the California region, as shown in Table 6-9. Rockfish account for the major portion of overall 

losses in this region. EPA estimated the annual undiscounted commercial fishing benefits of 

eliminating baseline IM&E to be approximately $2.0 million, as shown in Table 6-9. Applying a 
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May 2014 6-13

3 percent discount rate, EPA estimates the annualized benefits of eliminating baseline IM&E to 

be $1.7 million. Applying a 7 percent rate, these annualized benefits are approximately $1.5 

million.

As shown in Table 6-9, EPA estimates that annual commercial harvest will increase by 

approximately 7,000 pounds under the final rule. Annualized benefits to commercial fishers under 

the file rule will be about $3,000 using a 3 percent discount rate and $2,000 using a 7 percent 

discount rate. For other options considered, the annual increase is commercial harvest would 

range from about 7,000 pounds under Proposal Option 4 to 1.2 million pounds under Proposal 

Option 2. The associated annual benefits under other options considered would range from about 

$3,000 to $651,000 using a 3 percent discount rate and $2,000 to $422,000 using a 7 percent 

discount rate (Table 6-9). Appendix H presents species-specific results for the estimated annual 

increase in harvest and monetary benefits to commercial fishers.

Table 6-9: Commercial Fishing Benefits from Eliminating or Reducing Baseline 

IM&E Mortality Losses at Regulated Facilities in the California Region, for the 

Final Rule and Options Considered (2011$)

Regulatory Option

Annual Increase in 

Commercial 

Harvest

(1,000 lbs)

Annualized Benefits from Increase in Commercial 

Harvest

(2011$, 1,000s)

Undiscounted 3% Discount 

Rate

7% Discount 

Rate

Proposal Option 4 7 $5 $3 $2

Final Rule 7 $5 $3 $2

Proposal Option 2 1,177 $1,236 $651 $422

Baseline 1,929 $2,025 $1,698 $1,519

Source: U.S. EPA analysis for this report

6.2.2 North Atlantic Region

Baseline levels of IM&E account for 414,000 pounds of annual commercial fishing losses in the 

North Atlantic region, as shown in Table 6-10, with flounder playing a particularly important 

role. EPA estimated the annual undiscounted benefits to commercial fishers from eliminating 

baseline IM&E to be approximately $476,000, as shown in Table 6-10. EPA estimates the total 

annualized benefits from eliminating baseline IM&E, applying a 3 percent discount rate, to be 

$399,000. Applying a 7 percent rate, these annualized benefits are approximately $357,000.

As shown in Table 6-10, annual commercial harvest will increase by approximately 7,000 pounds 

under the final rule. Annualized benefits to commercial fishers under the final rule will be about 

$4,000 using 3 percent discount rates and $3,000 using 7 percent discount rates. For other options 

considered, the annual increase in commercial harvest ranges from about 3,000 pounds under 

Proposal Option 4 to 318,000 pounds under Proposal Option 2. The associated annual benefits 

under other options considered range from about $1,000 to $202,000 using a 3 percent discount 

rate and $1,000 to $136,000 using a 7 percent discount rate (Table 6-10). Appendix H presents 

species-specific results for the estimated annual increase in harvest and monetary benefits to 

commercial fishers.
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Table 6-10: Commercial Fishing Benefits from Eliminating or Reducing 

Baseline IM&E Mortality Losses at Regulated Facilities in the North Atlantic 

Region, for the Final Rule and Options Considered (2011$)

Regulatory Option

Annual Increase in 

Commercial 

Harvest

(1,000 lbs)

Annualized Benefits from Increase in Commercial 

Harvest

(2011$, 1,000s)

Undiscounted 3% Discount 

Rate

7% Discount 

Rate

Proposal Option 4 3 $2 $1 $1

Final Rule 7 $6 $4 $3

Proposal Option 2 318 $365 $202 $136

Baseline 414 $476 $399 $357

Source: U.S. EPA analysis for this report

6.2.3 Mid-Atlantic Region

Baseline levels of IM&E account for approximately 7.8 million pounds of commercial fishing 

losses annually in the Mid-Atlantic region, as shown in Table 6-11. Atlantic menhaden, blue crab, 

drum and croaker, spot, weakfish, and “other” species32 are the primary drivers of IM&E in the 

Mid-Atlantic region. EPA estimated the annual undiscounted benefits to commercial fishers from 

eliminating baseline IM&E to be $2.6 million, as shown in Table 6-11. Applying a 3 percent 

discount rate, annualized benefits from eliminating baseline IM&E are estimated to be $2.2

million. Applying a 7 percent rate, these annualized benefits are approximately $1.9 million.

As shown in Table 6-11, EPA estimates that annual commercial harvest will increase by 

approximately 3.1 million pounds under the final rule. Annualized benefits to commercial fishers 

under the final rule will be about $260,000 using a 3 percent discount rate and $190,000 using a 7 

percent discount rate. For other options considered, the annual increase in commercial harvest 

ranges from 2.9 million pounds under Proposal Option 4 to 7.1 million pounds under Proposal 

Option 2. The associated annual benefits under other options considered range from about 

$242,000 to $1.2 million using a 3 percent discount rate and $177,000 to $770,000 using a 7 

percent discount rate (Table 6-11). Appendix H presents species-specific results for the estimated 

annual increase in harvest and monetary benefits to commercial fishers.

 

32 The “other” species category includes losses which could not be assigned to a specific species group.
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May 2014 6-15

Table 6-11: Commercial Fishing Benefits from Eliminating or Reducing 

Baseline IM&E Mortality Losses at Regulated Facilities in the Mid-Atlantic 

Region, for the Final Rule and Options Considered (2011$)

Regulatory Option

Annual Increase in 

Commercial 

Harvest

(1,000 lbs)

Annualized Benefits from Increase in Commercial 

Harvest

(2011$, 1,000s)

Undiscounted 3% Discount 

Rate

7% Discount 

Rate

Proposal Option 4 2,873 $383 $242 $177

Final Rule 3,072 $411 $260 $190

Proposal Option 2 7,090 $2,373 $1,206 $770

Baseline 7,758 $2,586 $2,169 $1,939

Source: U.S. EPA analysis for this report

6.2.4 South Atlantic Region

Baseline levels of IM&E account for 78,000 pounds of commercial fishing losses in the South 

Atlantic region, as shown in Table 6-12. The estimated undiscounted annual commercial fishing 

benefits of eliminating baseline IM&E are driven primarily by Atlantic menhaden, spot, and drum 

and croaker and total $20,000, as shown in Table 6-12. Applying a 3 percent discount rate, the 

annualized benefits of eliminating baseline IM&E are estimated to be $17,000. Applying a 7 

percent rate, these annualized benefits are $15,000.

As shown in Table 6-12, EPA estimates that annual commercial harvest will increase by 

approximately 41,000 pounds under the final rule. Annualized benefits to commercial fishers 

under the final rule will be about $6,000 using 3 percent discount rates and $5,000 using 7 

percent discount rates. For other options considered, the annual increase in commercial harvest 

ranges from 37,000 pounds under Proposal Option 4 to 76,000 pounds under Proposal Option 2. 

The associated annual benefits under other options considered range from $6,000 to $10,000 

using a 3 percent discount rate and $4,000 to $7,000 using a 7 percent discount rate (Table 6-12). 

Appendix H presents species-specific results for the estimated annual increase in harvest and 

monetary benefits to commercial fishers.

Table 6-12: Commercial Fishing Benefits from Eliminating or Reducing 

Baseline IM&E Mortality Losses at Regulated Facilities in the South Atlantic 

Region, for the Final Rule and Options Considered (2011$)

Regulatory Option

Annual Increase in 

Commercial 

Harvest

(1,000 lbs)

Annualized Benefits from Increase in Commercial 

Harvest

(2011$, 1,000s)

Undiscounted 3% Discount 

Rate

7% Discount 

Rate

Proposal Option 4 37 $9 $6 $4

Final Rule 41 $10 $6 $5

Proposal Option 2 76 $19 $10 $7

Baseline 78 $20 $17 $15

Source: U.S. EPA analysis for this report
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6.2.5 Gulf of Mexico Region

Baseline levels of IM&E account for more than 6.0 million pounds of commercial fishing losses 

in the Gulf of Mexico region annually, as shown in Table 6-13. These losses are driven by black 

drum, striped mullet, and Atlantic menhaden. The estimated undiscounted annual commercial 

fishing benefits from eliminating baseline IM&E are approximately $3.9 million, as shown in 

Table 6-13. Applying a 3 percent discount rate, estimated commercial fishing benefits from 

eliminating baseline IM&E are estimated to be $3.4 million. Applying a 7 percent rate, these 

annualized losses are approximately $3.2 million.

As shown in Table 6-13, EPA estimates that annual commercial harvest will increase by 

approximately 1.7 million pounds under the final rule. Annualized benefits to commercial fishers 

under the file rule will be about $515,000 using a 3 percent discount rate and $379,000 using a 7 

percent discount rate. For other options considered, the annual increase in commercial harvest 

ranges from 1.6 million pounds under Proposal Option 4 to 4.3 million pounds under Proposal 

Option 2. The associated annual benefits under other options considered range from $497,000 to 

$1.7 million using a 3 percent discount rate and $365,000 to $1.3 million using a 7 percent 

discount rate (Table 6-13). Appendix H presents species-specific results for the estimated annual 

increase in harvest and monetary benefits to commercial fishers.

Table 6-13: Commercial Fishing Benefits from Eliminating or Reducing 

Baseline IM&E Mortality Losses at Regulated Facilities in the Gulf of Mexico 

Region, for the Final Rule and Options Considered (2011$)

Regulatory Option

Annual Increase in 

Commercial 

Harvest

(1,000 lbs)

Annualized Benefits from Increase in Commercial 

Harvest

(2011$, 1,000s)

Undiscounted 3% Discount 

Rate

7% Discount 

Rate

Proposal Option 4 1,642 $779 $497 $365

Final Rule 1,704 $808 $515 $379

Proposal Option 2 4,265 $2,651 $1,702 $1,256

Baseline 6,033 $3,926 $3,427 $3,161

Source: U.S. EPA analysis for this report

6.2.6 Great Lakes Region

Baseline levels of IM&E account for more than 1.1 million pounds of commercial fishing losses 

in the Great Lakes region annually, as shown in Table 6-14. These losses are driven by the white 

bass, freshwater drum, and “other” species. EPA estimated the annual undiscounted commercial 

fishing benefits from eliminating baseline IM&E in this region to be approximately $279,000, as 

shown in Table 6-14. Total annualized commercial benefits from eliminating baseline IM&E, 

applying a 3 percent discount rate, are estimated to be $244,000. Applying a 7 percent rate, these 

annualized losses are $225,000.

As shown in Table 6-14, EPA estimates that annual commercial harvest will increase by 838,000 

pounds under the final rule. Annualized benefits to commercial fishers under the final rule will be 

about $145,000 using a 3 percent discount rate and $110,000 using a 7 percent discount rate. For 

other options considered, the annual increase in commercial harvest ranges from 784,000 pounds 

under Proposal Option 4 to 1.1 million pounds under Proposal Option 2. The associated annual 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 6: Commercial Fishing Benefits

May 2014 6-17

benefits under other options considered range from $135,000 to $162,000 using a 3 percent 

discount rate and $102,000 to $116,000 using a 7 percent discount rate (Table 6-14). Appendix H

presents species-specific results for the estimated annual increase in harvest and monetary 

benefits to commercial fishers.

Table 6-14: Commercial Fishing Benefits from Eliminating or Reducing 

Baseline IM&E Mortality Losses at Regulated Facilities in the Great Lakes 

Region, for the Final Rule and Options Considered (2011$)

Regulatory Option

Annual Increase in 

Commercial 

Harvest

(1,000 lbs)

Annualized Benefits from Increase in Commercial 

Harvest

(2011$, 1,000s)

Undiscounted 3% Discount 

Rate

7% Discount 

Rate

Proposal Option 4 784 $202 $135 $102

Final Rule 838 $217 $145 $110

Proposal Option 2 1,092 $266 $162 $116

Baseline 1,137 $279 $244 $225

Source: U.S. EPA analysis for this report

6.2.7 National Estimates

Nationally, baseline levels of IM&E account for more than 17.3 million pounds of commercial 

fishing losses annually, as shown in Table 6-15. EPA estimated the annual undiscounted 

commercial fishing benefits from eliminating baseline IM&E to be approximately $9.3 million, as 

shown in Table 6-15. Total annualized commercial benefits from eliminating baseline IM&E, 

applying a 3 percent discount rate, are estimated to be $8.0 million. Applying a 7 percent rate, 

these annualized losses are $7.2 million.

As shown in Table 6-15, EPA estimates that annual commercial harvest will increase by 5.7 

million pounds under the final rule. Annualized benefits to commercial fishers under the final rule 

will be about $0.9 million using a 3 percent discount rate and $0.7 million using a 7 percent 

discount rate. For other options considered, the annual increase in commercial harvest ranges 

from 5.3 million pounds under Proposal Option 4 to 14.0 million pounds under Proposal Option 

2. The associated annual benefits under other options considered range from $0.9 to $3.9 million 

using a 3 percent discount rate and $0.7 to $2.7 million using a 7 percent discount rate (Table 6-

15). Appendix H presents species-specific results for the estimated annual increase in harvest and 

monetary benefits to commercial fishers for each region.
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Table 6-15: National Commercial Fishing Benefits from Eliminating or Reducing 

Baseline IM&E Mortality Losses at Regulated Facilities, for the Final Rule and 

Options Considered (2011$)

Regulatory Option

Annual Increase in 

Commercial 

Harvest

(1,000 lbs)

Annualized Benefits from Increase in Commercial 

Harvest

(2011$, 1,000s)

Undiscounted 3% Discount 

Rate

7% Discount 

Rate

Proposal Option 4 5,345 $1,379 $883 $652

Final Rule 5,669 $1,457 $934 $689

Proposal Option 2 14,019 $6,910 $3,935 $2,707

Baseline 17,349 $9,312 $7,953 $7,215

Source: U.S. EPA analysis for this report

6.3 Limitations and Uncertainties

Table 6-16 summarizes the caveats, omissions, biases, and uncertainties known to affect the 

estimates that EPA developed for the benefits analysis. 

Table 6-16: Caveats, Omissions, Biases, and Uncertainties in the Commercial Benefits 

Estimates

Issue

Impact on Benefits 

Estimate Comments

Change in commercial landings due 

to IM&E is uncertain Uncertain

Projected changes in harvest may be underestimated 

because cumulative impacts of IM&E over time,

interactions with other stressors, and population 

changes, are not considered.

Some estimates of commercial 

harvest losses due to IM&E under 

current conditions are not 

region/species-specific

Uncertain

EPA estimated the impact of IM&E in the case 

study analyses based on the most current data 

available data provided by the facilities. However, 

in some cases these data are 20 years old or older. 

Thus, they may not reflect current fish stock and 

waterbody conditions.

Effect of change in stocks on 

landings is not considered Uncertain

EPA assumed a linear stock to harvest relationship, 

so that a 10 percent change in stock would have a 

10 percent change in landings; this may be low or 

high, depending on the condition of the stocks. 

Region-specific fisheries regulations also will affect 

the validity of the linear assumption.

Effect of uncertainty in estimates of 

commercial landings and prices is 

unknown

Uncertain

EPA assumed that NMFS landings data are accurate 

and complete. In some cases prices and/or 

quantities may be reported incorrectly.
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May 2014 7-1

7 Recreational Fishing Benefits

7.1 Introduction

This chapter presents the estimated benefits to recreational anglers from improved recreational 

fishing opportunities due to reductions in IM&E under the final rule and regulatory options EPA 

considered for section 316(b). EPA used a benefit transfer approach based on a meta-analysis of 

economic studies of recreational fishing benefits from improved catch rates. Benefit transfer 

involves adapting research conducted for another purpose to address the policy questions at hand 

(Bergstrom and De Civita 1999). Benefit-cost analysis of environmental regulations rarely affords 

sufficient time to conduct original stated or revealed preference studies specific to policy effects. 

Benefit transfer is a widely used approach which provides information to inform policy decisions 

in benefit-cost analysis of environmental regulations. EPA notes that Smith et al. (2002, p.134)

state that “...nearly all benefit cost analyses rely on benefit transfers...”

Boyle and Bergstrom (1992) define benefit transfer as “the transfer of existing estimates of 

nonmarket values to a new study which is different from the study for which the values were 

originally estimated.” There are four types of benefit transfer studies: point estimate, benefit 

function, meta-analysis, and Bayesian techniques (USEPA 2010a). These types may be 

categorized into three fundamental classes: (1) transfer of an unadjusted fixed value estimate 

generated from a single study site; (2) the use of expert judgment to aggregate or otherwise alter 

benefits to be transferred from a site or set of sites; and (3) estimation of a value estimator model 

derived from study site data, often from multiple sites (Bergstrom and De Civita 1999). Recent 

studies have shown little support for the accuracy or validity of the first method, leading to 

increased attention to, and use of, adjusted values estimated by one of the remaining two 

approaches (Bergstrom and De Civita 1999). The third class of benefit transfer approaches 

includes meta-analysis techniques, which economists have explored increasingly as a potential 

basis of policy analysis conducted by various government agencies charged with the stewardship 

of natural resources. 33

Section 7.2 provides a brief overview of the benefit transfer methodology EPA used for 

estimating the recreational fishing benefits. Chapter A5 of EPA’s Regional Benefits Analysis of 

the Final Section 316(b) Phase III Existing Facilities Rule (USEPA 2006b) provides a detailed 

description of the benefit transfer methodology that EPA employed in this analysis. Section 7.2 

also highlights updates to the Phase III methodology. Section 7.3 presents the recreational fishing 

benefits by region, and Section 7.4 summarizes the limitations and uncertainties inherent in 

EPA’s analysis of recreational fishing benefits.

7.2 Methodology

EPA’s analysis of recreational fishing benefits from reducing IM&E at CWIS at regulated 

facilities includes the following general steps: 

 

33 Meta-analysis is “the statistical analysis of a large collection of results from individual studies for the purposes of 

integrating the findings” (Glass 1976).
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1. Estimate the forgone catch of recreational fish (in number of fish) due to baseline 

IM&E and increases in recreational harvest under regulatory options. EPA modeled 

these losses using the methods presented in Chapter 3. EPA’s estimates of recreational 

fish losses are expressed as the number of harvestable adults because this is the measure 

to which recreational values are attributed.34 Many of the fish species affected by IM&E 

at CWIS sites are harvested both recreationally and commercially. EPA used the 

proportion of total species landings attributable to recreational fishing to estimate 

baseline losses in recreational harvest due to baseline (current) levels of IM&E and 

reductions in recreational harvest losses under the final rule and other options considered. 

2. Estimate the marginal value per fish. EPA used the estimated meta-regression 

described in Chapter A5 of Regional Benefits Analysis of the Final Section 316(b) Phase 

III Rule (USEPA 2006b) to estimate marginal values per fish for the species affected by 

IM&E at all regulated existing facilities. To calculate the marginal value per fish for the 

affected species, EPA chose input values for the independent variables based on the 

affected species characteristics, study regions, and demographic characteristics of the 

affected angling populations. The study design variables were selected based on current 

economic literature. This step is described in more detail in Section 7.2.1.

3. Estimate the value of forgone recreational catch lost to baseline IM&E benefits 

under regulatory options. EPA multiplied the marginal value per fish by the number of 

recreational fish currently lost to baseline IM&E that would otherwise be caught by 

recreational anglers and increases in recreational fishing harvest under policy options, 

respectively.

7.2.1 Estimating Marginal Value per Fish

EPA used a benefit transfer function based on meta-analysis of recreational fishing studies from 

the Section 316(b) Phase III Final Rule to estimate marginal values per fish for the species 

affected by IM&E at regulated facilities. The general approach follows standard methods 

illustrated by Johnston et al. (2006) and Shrestha et al. (2007), among many others (e.g., 

Rosenberger and Phipps 2007). This function allows EPA to forecast willingness to pay (WTP) 

based on assigned values for model variables, chosen to best represent a resource change in the 

316(b) policy context. EPA’s meta-analysis results imply a simple benefit function of the 

following general form:

ln(WTP) = intercept + ∑(coefficienti)(Independent Variable Valuesi) (7-1)

Here, ln(WTP) is the dependent variable in the meta-analysis—the natural log of WTP for

catching an additional fish. The independent variables included in the meta-analysis characterize 

the species being valued, study location, baseline catch rate, elicitation and survey methods, 

demographics of survey respondents, and other specific characteristics of each study.

To calculate the marginal value per fish for the species affected by regulated facilities, EPA chose 

input values for the independent variables based on the characteristics of the affected species, 

study regions, and demographic characteristics of the affected angling populations. The study 

design variables were selected based on current economic literature. Table 7-1 provides the 

 

34 Adult fish of harvestable age means that they are the age at which they can legally be harvested.
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independent variable names, the estimated variable coefficients (coefficienti), and the assigned 

input values for each of the independent variables in the model.

EPA followed Johnston et al. (2006) in assigning values for methodological attributes (i.e., 

variables characterizing the study methodology used in the original source studies), which are set 

at mean values from the metadata except in cases where theoretical considerations dictate 

particular assignments. This approach follows general guidance from Bergstrom and Taylor 

(2006) that meta-analysis benefit transfer should incorporate theoretical expectations and 

structures, at least in a weak form. In this instance, two of the methodology variables, RUM_nest

and high_resp_rate, are included with an assigned value of one. RUM_year represents the year in 

which the study was conducted, converted to an index by subtracting 1976. It was given the value 

of 9.37, corresponding to average study year of 1985, because there was no clear justification for 

selecting a specific year based on the meta-data. In their detailed analysis of methodological 

variable specifications for this meta-analysis model, Stapler and Johnston (2009) found that “the 

additional error associated with an empirical, mean value treatment of methodological covariates 

is relatively modest, on average.”

EPA decided not to include the error term when using the regression equation to predict marginal 

values per fish. Bockstael and Strand (1987) argue that if the econometric error in an equation is 

due primarily to omitted variables, the error term should be included, but if the error is due 

primarily to random preferences or measurement error, it should be excluded. Because the error 

term is positive, the empirical effect of including this term is to increase the predicted marginal 

values. The authors warned against the practice of assuming that all error is associated with 

omitted variables. If the error is due to random preferences or measurement errors, the estimated 

WTP values are likely to be upward biased if the error term is included. EPA decided not to 

include the error term in the estimation of WTP per fish because the source of error in the 

underlying meta-data is unknown. EPA notes that when the error term is excluded, the values 

predicted by the regression equation are more consistent with those from the underlying studies. 

Table 7-2 presents region- and species-specific values for the input variables that vary across 

regions. Table 7-3 presents the estimated marginal value per fish for all species affected by IM&E 

in each region.
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Table 7-1: Independent Variable Assignments for Regression Equation

Variable Coefficient Assigned Value Explanation

Intercept -1.4568 1

The equation intercept was set to one by 

default.

SP_conjoint -1.1672 0 Binary variables denoting the type of stated 

preference, travel cost, or random utility used 

for the study. Current academic literature 

suggests that nested RUM models produce 

the most accurate valuation results, so 

RUM_nest was set to one, and the other 

study methodology variables were set to 

zero.

SP_dichot -0.9958 0

TC_individual 1.1091 0

TC_zonal 2.0480 0

RUM_nest 1.3324 1

RUM_nonnest 1.7892 0

SP_year 0.08754 0 Variables denoting the year that the study 

was conducted by study type (stated 

preference, travel cost, or random utility 

model). SP_year and TC_year were set to 

zero because EPA selected RUM, above. 

RUM_year was set equal to the average 

value across the studies in the analysis, 9.37.

TC_year -0.03965 0

RUM_year -0.00291 9.37

SP_mail 0.5440 0 Sp_mail and sp_phone correspond to mail 

and phone survey methods for stated 

preference studies, Since RUM_nest was the 

model specified above rather than stated 

preference (i.e, SP_conjoint, SP_dichot), 

SP_mail and SP_phone were set to zero.

SP_phone 1.0859 0

high_resp_rate -0.6539 1

Binary variable indicating that the survey 

response rate exceeded 50 percent. EPA set 

high_response_rate to one because high 

response rates may provide more accurate 

estimates.

inc_thou 0.003872 Varies

Household income of survey respondents in 

thousands of dollars. Inc_thou was set to the 

median household income for each study 

region evaluated, based on U.S. Census data.

age42_down 0.9206 0.0972 Binary variables indicating whether the 

average age of respondents was less than 43 

or 43 and greater. Age42_down and 

age43_up were set to their sample means.

age43_up 1.2221 0.2711

trips19_down 0.8392 0.1100 Binary variables indicating whether the mean 

number of fishing trips taken each year by 

sample respondents was less than 20 or 20 

and greater. Trips19_down and trips20_up

were set to their sample means.

trips20_up -1.0112 0.3350

nonlocal 3.2355 0

Binary variable indicating that respondents 

in the sample were not local residents. 

Because the default (zero) value for the 

nonlocal dummy variable represents a 

combination of local and nonlocal anglers, 

nonlocal was set to zero.
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Table 7-1: Independent Variable Assignments for Regression Equation

Variable Coefficient Assigned Value Explanation

big_game_pac 2.2530 Varies

Binary variables indicating the targeted 

species. Species-targeted variables were 

assigned input values based on 

characteristics of the species affected by 

IM&E and the study region. In general, the 

match between the affected species and the 

variables in the meta-analysis equation was 

good.

big_game_natl 1.5323 Varies

big_game_satl 2.3821 Varies

small_game_pac 1.6227 Varies

small_game_atl 1.4099 Varies

flatfish_pac 1.8909 Varies

flatfish_atl 1.3797 Varies

other_sw 0.7339 Varies

musky 3.8671 Varies

pike_walleye 1.0412 Varies

bass_fw 1.7780 Varies

trout_GL 1.8723 Varies

trout_nonGL 0.8632 Varies

salmon_pacific 2.3570 Varies

salmon_atl_morey 5.2689 Varies

salmon_GL 2.2135 Varies

steelhead_pac 2.1904 Varies

steelhead_GL 2.3393 Varies

cr_nonyear -0.08135 Varies Variables describing catch rates. Cr_nonyear

indicates the catch rate for studies presenting 

catch rate per hour, per day, or per trip. It

was assigned species and region-specific 

values for the coastal and Great Lakes 

regions based on catch rates data provided by 

the National Marine Fisheries Service 

(NMFS 2002, 2003) and the Michigan 

Department of Natural Resources (MDNR 

2002). For the Inland region, EPA assigned 

values to the cr_nonyear variable based on 

the average values for each species from the 

studies. Spec_cr is a binary variable 

indicating that the study presents information 

on the baseline catch rate. EPA set spec_cr

to one. Catch_year is a binary variable 

indicating that the study presented catch rates 

on a per year basis and cr_year is the annual 

catch rate from the study. Cr_year and 

catch_year were set to zero because catch 

per trip and catch per day are more common 

measures of angling quality.

cr_year -0.05208 0

catch_year 1.2693 0

spec_cr 0.6862 1

shore -0.1129 Varies

cr_year -0.05208 0

catch_year 1.2693 0

spec_cr 0.6862 1

shore -0.1129 Varies

Binary variable indicating that all 

respondents in the sample fished from shore. 

Shore was assigned values based on NMFS 

(2002, 2003) and U.S. Fish and Wildlife 

Service (USDOI and USDOC 2002) survey 

data indicating the average percentage of 

anglers who fish from shore in each region.

Source: U.S. EPA (2006)
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Table 7-2: Region- and Species-specific Variable Assignments for the Regression 

Equationa

Variable

Region

California North 

Atlantic

MidAtlanticSouth 

Atlantic

Gulf of 

Mexico

Great 

Lakes Inland

inc_thou 54.385 55.000 51.846 40.730 36.641 44.519 58.240

Shore 24.0 24.0 23.1 30.0 25.0 48.0 57.0

Speciesb

Species Type 

Dummy 

Variablec

Baseline Catch Rate, Expressed in Fish per Day (cr_nonyear)

d

Small gamee small_game_atl, 

small_game_pac 2.7 1.6 1.6 2.2 2.2 2.1

Flatfishf

flatfish_atl, 

flatfish_pac 1.3 1.0 1.0 1.5

Other 

saltwater other_sw 1.7 1.7 1.7 1.7 1.7

Salmon Salmon_GL 0.2 0.2

Walleye/pike pike_walleye 0.8 0.8

Bass bass_fw 0.2 0.2

Panfishg4.7 4.7 4.7

Trout 3.2 3.2

Unidentified 1.7 1.7 1.7 1.7 1.9 1.9 3.8

a

See Table 7-1 for information regarding the specification of variables that EPA held fixed across regions.

b The table is restricted to species groups which correspond to species impacted by IM&E at regulated facilities. 

c This column indicates which species type dummy variable was set to one to represent each species.

d Blank cells indicate that IM&E losses are not estimated for the species in that benefits region. 

e

For “small game” fish in the North Atlantic, Mid-Atlantic, South Atlantic, Gulf of Mexico, and Inland regions, small_game_atl was 

set to one. For “small game” fish in the California region, small_game_pac was set to one.

f

For “flatfish” in the North Atlantic, Mid-Atlantic, South Atlantic, Gulf of Mexico, Great Lakes, and Inland regions, flatfish_atl was 

set to one. For flatfish in the California region, flatfish_pac was set to one.

g To indicate that the target species was “panfish,” all species type dummy variables were set to zero.

Source: U.S. EPA (2006)
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Table 7-3: Marginal Recreational Value per Fish, by Region and Species (2011$)a

Species California North 

Atlantic

MidAtlanticSouth 

Atlantic

Gulf of 

Mexico

Great 

Lakes Inland

Small game $7.60 $6.22 $6.17 $5.99 $5.89 $5.61

Flatfish $10.21 $6.24 $5.88 $5.87

Other saltwater $3.09 $3.12 $3.05 $2.98 $2.91

Salmon $13.88 $13.88

Walleye/pike $4.30 $4.29

Bass $8.95 $9.43

Panfish $1.11 $1.39 $1.11

Trout $9.87 $2.96

Unidentified $3.25 $3.15 $3.39 $2.99 $3.83 $6.51 $2.33

a Blank cells indicate that recreational value per fish was not estimated because zero IM&E losses are estimated for the 

species in that benefits region.

Source: U.S. EPA (2006), converted to 2011$ using the Consumer Price Index (USBLS 2011)

7.2.2 Calculating Recreational Fishing Benefits

EPA estimated the recreational welfare gain from eliminating current IM&E and the recreational 

welfare gain from the final rule and other options considered by combining estimates of the 

marginal value per fish with the estimated recreational fishing losses under the baseline level of 

IM&E, and the reduction in recreational fishing losses attributable to the final rule and other 

options considered. To calculate the recreational welfare gain from eliminating baseline IM&E, 

EPA multiplied the marginal value per fish by the number of fish that are lost due to baseline 

IM&E that would otherwise be caught by recreational anglers. To calculate the recreational 

welfare gain from the final rule and other options considered, EPA multiplied the marginal value 

per fish by the estimated additional number of fish caught by recreational anglers that would have 

been impinged or entrained in the absence of the regulation. As explained in Chapter 3, these 

calculations express recreational fish losses as the number of harvestable adults.

7.2.3 Sensitivity Analysis Based on the Krinsky and Robb (1986) Approach

The meta-analysis model briefly described above can be used to predict mean WTP for catching 

an additional fish. However, estimates derived from regression models are subject to some degree 

of error and uncertainty. To better characterize the uncertainty or error bounds around predicted 

WTP, EPA adopted the statistical procedure described by Krinsky and Robb in their 1986 Review 

of Economics and Statistics paper, “Approximating the Statistical Property of Elasticities.” The 

procedure involves sampling from the variance-covariance matrix and means of the estimated 

coefficients. WTP values are then calculated for each drawing from the variance covariance 

matrix, and constructing an empirical distribution of WTP values. By varying the number of 

drawings, it is possible to generate an empirical distribution with a desired degree of accuracy 

(Krinsky and Robb 1986). The lower or upper bound of WTP values can then be identified based 

on the 5th and 95th percentile of WTP values from the empirical distribution. These bounds may 

help decision-makers understand the uncertainty associated with the benefit results.

The results of EPA’s calculations are shown in Table 7-4. The table presents 95th percentile upper 

confidence bounds and 5th percentile lower confidence bounds for the marginal value per fish for 

each species in each region. These bounds can be used to estimate upper and lower confidence 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 7: Recreational Fishing Benefits

May 2014 7-8

bounds for the WTP for improvements in recreational catch rates from eliminating baseline 

IM&E or reducing IM&E under the final rule and other options considered. Refer to EPA (2006)

for more detail on the specific calculations. The 5th percentile values shown in Table 7-4 show 

that, with the exception of panfish, even the lowest estimates of recreational value are well above 

$1.00 per fish. Certainly, all are above zero.

Table 7-4: Confidence Bounds on Marginal Recreational Value per Fish, Based 

on the Krinsky and Robb Approach (2011$)a

Species California North 

Atlantic

MidAtlanticSouth 

Atlantic

Gulf of 

Mexico

Great 

Lakes Inland

5

th Percentile Lower Confidence Boundsb

Small game $4.40 $2.23 $2.37 $2.84 $3.00 $1.68

Flatfish $5.35 $3.98 $3.92 $4.05

Other saltwater $1.87 $1.87 $1.94 $2.24 $2.23

Salmon $8.53 $8.53

Walleye/pike $2.28 $2.07

Bass $4.63 $4.48

Panfish $0.55 $0.73 $0.55

Trout $6.39 $1.59

Unidentified $1.95 $1.88 $2.00 $2.25 $2.47 $3.49 $1.13

95th Percentile Upper Confidence Bounds

Small game $13.01 $17.53 $16.23 $12.59 $1.55 $18.90

Flatfish $19.49 $9.86 $8.92 $8.66

Other saltwater $5.11 $5.20 $4.82 $3.95 $3.78

Salmon $22.61 $22.61

Walleye/pike $8.16 $8.92

Bass $17.38 $19.96

Panfish $2.20 $2.61 $2.20

Trout $15.34 $5.53

Unidentified $5.42 $5.26 $6.00 $3.99 $6.18 $12.25 $4.81

a Blank cells indicate that recreational value per fish was not estimated because IM&E losses are not estimated for the 

species in that benefits region.

b Upper and lower confidence bounds based on results of the Krinsky and Robb (1986) approach.

Source: U.S. EPA (2006), converted to 20011$ using the Consumer Price Index (USBLS 2011).

7.3 Benefits Estimates for Recreational Fishing by Region

7.3.1 California Region

Table 7-5 presents the estimated increase in recreational fishing harvest and associated welfare 

gains from the elimination of baseline IM&E in the California region. EPA estimates an annual 

harvest increase of 1.4 million fish from the elimination of baseline IM&E, the majority 

attributable to reduced entrainment of rockfish and sea bass. The associated mean annual welfare 

gain is $4.0 million and $3.6 million, evaluated at 3 percent and 7 percent discount rates, 

respectively. The majority of the monetized recreational benefits from eliminating baseline IM&E 

is attributable to entrainment of “other saltwater” fish.35

 

35 The “other saltwater” species group includes banded drum, black drum, chubby, cod family, cow cod, croaker, 

grouper, grunion, grunt, high-hat, kingfish, lingcod, other drum, perch, porgy, rockfish, sablefish, sand drum, 

sculpin, sea bass, smelt, snapper, spot, spotted drum, star drum, white sea bass, wreckfish, other bottom species, 

other coastal pelagics, and “no target” saltwater species.
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Table 7-5 also presents the annual recreational harvest increases and welfare gains to California 

anglers under the final rule and other options considered. EPA estimates that the final rule will 

increase annual harvest by 0.04 million fish. The mean annualized welfare gain under final rule 

will be less than $0.1 million using both 3 percent and 7 percent discount rates. Annual harvest 

increases under other options considered range from 0.04 million fish under Proposal Option 4 to 

0.88 million fish under Proposal Option 2. Mean annualized benefits under other options 

considered range from less than $0.1 to $1.5 million using a 3 percent discount rate and less than 

$0.1 to $1.0 million using a 7 percent discount rate. Appendix I presents additional speciesspecific results for final file rule, other options considered, and the elimination of baseline IM&E.

Table 7-5: Recreational Fishing Benefits from Eliminating or Reducing Baseline IM&E 

at Regulated Facilities in the California Region, for the Final Rule and Options 

Considered (2011$)

Regulatory Option

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Annualized Benefits from Increase in Recreational 

Harvest 

(2011$, 1,000s)a

3 % Discount Rate 7 % Discount Rate

5

th Mean 95th 5th Mean 95th

Proposal Option 4 35,420 $42 $69 $114 $30 $50 $83

Final Rule 38,159 $45 $74 $123 $33 $54 $89

Proposal Option 2 877,174 $919 $1,543 $2,595 $592 $994 $1,673

Baseline 1,431,170 $2,408 $4,044 $6,803 $2,153 $3,616 $6,084

a

5th and 95th are the 5th and 95th percentiles based on the results of the Krinsky and Robb (1986) approach.

Source: U.S. EPA analysis for this report

7.3.2 North Atlantic Region

Table 7-6 presents the estimated increase in recreational fishing harvest and associated welfare 

gains from the elimination of baseline IM&E in the North Atlantic region. EPA estimates an 

annual harvest increase of 0.73 million fish from the elimination of baseline IM&E, the majority 

attributable to reduced entrainment of winter flounder, cunner, and sculpin. The associated mean 

annual welfare gain is $2.7 million and $2.4 million, evaluated at 3 percent and 7 percent 

discount rates, respectively. The majority of the monetized recreational benefits from eliminating 

baseline IM&E is attributable to entrainment of “flatfish” and “other saltwater” fish.

36

Table 7-6 also presents the annual recreational harvest increases and welfare gains to North 

Atlantic anglers under the final rule and other options considered. EPA estimates that the final 

rule will increase annual harvest by less than 0.01 million. The mean annualized welfare gain 

under final rule will be less than $0.1 million using both 3 percent and 7 percent discount rates. 

Annual harvest increases under other options considered range from less than 0.01 million fish 

under Proposal Option 4 to 0.56 million fish under Proposal Option 2. Mean annualized benefits 

under other options considered range from less than $0.1 to $1.4 million using a 3 percent 

discount rate and from less than $0.1 to $0.9 million using a 7 percent discount rate. Appendix I

 

36 The “other saltwater” species group includes banded drum, black drum, chubby, cod family, cow cod, croaker, 

grouper, grunion, grunt, high-hat, kingfish, lingcod, other drum, perch, porgy, rockfish, sablefish, sand drum, 

sculpin, sea bass, smelt, snapper, spot, spotted drum, star drum, white sea bass, wreckfish, other bottom species, 

other coastal pelagics, and “no target” saltwater species.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 7: Recreational Fishing Benefits

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presents additional species-specific results for final file rule, other options considered, and the 

elimination of baseline IM&E.

Table 7-6: Recreational Fishing Benefits from Eliminating or Reducing Baseline IM&E 

at Regulated Facilities in the North Atlantic Region, for the Final Rule and Options 

Considered (2011$)

Regulatory Option

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Annualized Benefits from Increase in Recreational 

Harvest 

(2011$, 1,000s)a

3 % Discount Rate 7 % Discount Rate

5

th Mean 95th 5th Mean 95th

Proposal Option 4 1,367 $3 $4 $7 $2 $3 $5

Final Rule 7,975 $14 $23 $36 $10 $16 $27

Proposal Option 2 562,305 $852 $1,371 $2,219 $573 $921 $1,491

Baseline 733,985 $1,682 $2,705 $4,380 $1,504 $2,419 $3,917

a

5th and 95th are the 5th and 95th percentiles based on the results of the Krinsky and Robb (1986) approach.

Source: U.S. EPA analysis for this report

7.3.3 Mid-Atlantic Region

Table 7-7 presents the estimated increase in recreational fishing harvest and associated welfare 

gains from the elimination of baseline IM&E in the Mid-Atlantic region. EPA estimates an 

annual harvest increase of 5.82 million fish from the elimination of baseline IM&E, the majority 

attributable to reduced IM&E of spot and Atlantic croaker. The associated mean annual welfare 

gain is $16.2 million and $14.5 million, evaluated at 3 percent and 7 percent discount rates, 

respectively. The majority of the monetized recreational benefits from eliminating baseline IM&E 

is attributable to the entrainment of “other saltwater” fish.

Table 7-7 also presents the annual recreational harvest increases and welfare gains to MidAtlantic anglers under the final rule and other options considered. EPA estimates that the final 

rule will increase annual harvest by 0.46 million fish. The mean annualized welfare gain under 

final rule will be $1.1 million using a 3 percent rate and $0.8 million using a 7 percent discount 

rate. Annual harvest increases under other options considered range from 0.43 million fish under 

Proposal Option 4 to 5.10 million fish under Proposal Option 2. Mean annualized benefits under 

other options considered range from $1.0 to $8.6 million using a 3 percent discount rate and from 

$0.7 to $5.5 million using a 7 percent discount rate. Appendix I presents additional speciesspecific results for final file rule, other options considered, and the elimination of baseline IM&E.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 7: Recreational Fishing Benefits

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Table 7-7: Recreational Fishing Benefits from Eliminating or Reducing Baseline IM&E 

at Regulated Facilities in the Mid-Atlantic Region, for the Final Rule and Options 

Considered (2011$)

Regulatory Option

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Annualized Benefits from Increase in Recreational 

Harvest 

(2011$, 1,000s)a

3 % Discount Rate 7 % Discount Rate

5

th Mean 95th 5th Mean 95th

Proposal Option 4 427,924 $531 $988 $1,961 $376 $700 $1,389

Final Rule 460,839 $572 $1,063 $2,108 $405 $753 $1,493

Proposal Option 2 5,103,595 $5,132 $8,634 $15,072 $3,273 $5,506 $9,612

Baseline 5,823,189 $9,665 $16,249 $28,341 $8,643 $14,531 $25,343

a

5th and 95th are the 5th and 95th percentiles based on the results of the Krinsky and Robb (1986) approach.

Source: U.S. EPA analysis for this report

7.3.4 South Atlantic Region

Table 7-8 presents the estimated increase in recreational fishing harvest and associated welfare 

gains from the elimination of baseline IM&E in the South Atlantic region. EPA estimates an 

annual harvest increase of 0.11 million fish from the elimination of baseline IM&E, the majority 

attributable to reduced IM&E of “other saltwater” fish, especially spot and croakers. The 

associated mean annual welfare gain is $0.3 million evaluated at both 3 percent and 7 percent 

discount rates. The majority of the monetized recreational benefits from eliminating baseline 

IM&E is attributable to entrainment of “other saltwater” fish.

Table 7-8 also presents the annual recreational harvest increases and welfare gains to South 

Atlantic anglers under the final rule and other options considered. EPA estimates that the final 

rule will increase annual harvest by 0.02 million fish. The mean annualized welfare gain under 

final rule will be less than $0.1 million using both 3 percent and 7 percent discount rates. Annual 

harvest increases under other options considered range from 0.01 million fish under Proposal 

Option 4 to 0.10 million fish under Proposal Option 2. Mean annualized benefits under other 

options considered range from less than $0.1 to $0.2 million using a 3 percent discount rate and 

from less than $0.1 to $0.1 million using a 7 percent discount rate. Appendix I presents additional 

species-specific results for final file rule, other options considered, and the elimination of baseline 

IM&E.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 7: Recreational Fishing Benefits

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Table 7-8: Recreational Fishing Benefits from Eliminating or Reducing Baseline IM&E 

at Regulated Facilities in the South Atlantic Region, for the Final Rule and Options 

Considered (2011$)

Regulatory Option

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Annualized Benefits from Increase in Recreational 

Harvest 

(2011$, 1,000s)a

3 % Discount Rate 7 % Discount Rate

5

th Mean 95th 5th Mean 95th

Proposal Option 4 12,983 $18 $24 $33 $13 $17 $23

Final Rule 18,725 $26 $35 $47 $18 $24 $33

Proposal Option 2 104,943 $129 $173 $234 $86 $115 $156

Baseline 111,075 $211 $284 $385 $189 $254 $344

a

5th and 95th are the 5th and 95th percentiles based on the results of the Krinsky and Robb (1986) approach.

Source: U.S. EPA analysis for this report

7.3.5 Gulf of Mexico Region

Table 7-9 presents the estimated increase in recreational fishing harvest and associated welfare 

gains from the elimination of baseline IM&E in the Gulf of Mexico region. EPA estimates an 

annual harvest increase of 3.08 million fish from the elimination of baseline IM&E, the majority 

attributable the impingement of spotted seatrout and the entrainment of black drum and pinfish. 

The associated mean annual welfare gain is $9.6 million and $8.8 million, evaluated at 3 percent 

and 7 percent discount rates, respectively. The majority of the monetized recreational benefits 

from eliminating baseline IM&E is attributable to both the impingement of “small game” fish and 

the entrainment of “other saltwater” species.

Table 7-9 also presents the annual recreational harvest increases and welfare gains to Gulf of 

Mexico anglers under the final rule and other options considered. EPA estimates that the final 

rule will increase annual harvest by 0.78 million fish. The mean annualized welfare gain under 

final rule will be $2.3 million using a 3 percent discount rate and $1.6 million using a 7 percent 

discount rate. Annual harvest increases under other options considered range from 0.75 million 

fish under Proposal Option 4 to 2.14 million fish under Proposal Option 2. Mean annualized 

benefits under other options considered range from $2.2 to $5.1 million using a 3 percent 

discount rate and from $1.6 to $3.8 million using a 7 percent discount rate. Appendix I presents 

additional species-specific results for final file rule, other options considered, and the elimination 

of baseline IM&E.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 7: Recreational Fishing Benefits

May 2014 7-13

Table 7-9: Recreational Fishing Benefits from Eliminating or Reducing Baseline IM&E 

at Regulated Facilities in the Gulf of Mexico Region, for the Final Rule and Options 

Considered (2011$)

Regulatory Option

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Annualized Benefits from Increase in Recreational 

Harvest 

(2011$, 1,000s)a

3 % Discount Rate 7 % Discount Rate

5

th Mean 95th 5th Mean 95th

Proposal Option 4 749,144 $1,260 $2,183 $3,904 $914 $1,583 $2,831

Final Rule 777,488 $1,308 $2,265 $4,051 $948 $1,643 $2,938

Proposal Option 2 2,137,861 $3,357 $5,116 $8,122 $2,476 $3,774 $5,991

Baseline 3,077,617 $6,457 $9,575 $14,756 $5,955 $8,831 $13,610

a

5th and 95th are the 5th and 95th percentiles based on the results of the Krinsky and Robb (1986) approach.

Source: U.S. EPA analysis for this report

7.3.6 Great Lakes Region

Table 7-10 presents the estimated increase in recreational fishing harvest and associated welfare 

gains from the elimination of baseline IM&E in the Great Lakes region. EPA estimates an annual 

harvest increase of 2.23 million fish from the elimination of baseline IM&E, the majority 

attributable to IM&E of white bass and “unidentified” species. The associated mean annual 

welfare gain is $13.8 million and $12.8 million, evaluated at 3 percent and 7 percent discount 

rates, respectively. The majority of the monetized recreational benefits from eliminating baseline 

IM&E is attributable to the impingement of bass and “unidentified” fish.

Table 7-10 also presents the annual recreational harvest increases and welfare gains to Great 

Lakes anglers under the final rule and other options considered. EPA estimates that the final rule 

will increase annual harvest by 1.47 million fish. The mean annualized welfare gain under final 

rule will be $7.2 million using a 3 percent discount rate and $5.3 million using a 7 percent 

discount rate. Annual harvest increases under other options considered range from 1.33 million 

fish under Proposal Option 4 to 2.04 million fish under Proposal Option 2. Mean annualized 

benefits under other options considered range from $6.5 to $8.9 million using a 3 percent 

discount rate and from $4.8 to $6.4 million using a 7 percent discount rate. Appendix I presents 

additional species-specific results for final file rule, other options considered, and the elimination 

of baseline IM&E.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 7: Recreational Fishing Benefits

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Table 7-10: Recreational Fishing Benefits from Eliminating or Reducing Baseline 

IM&E at Regulated Facilities in the Great Lakes Region, for the Final Rule and

Options Considered (2011$)

Regulatory Option

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Annualized Benefits from Increase in Recreational 

Harvest 

(2011$, 1,000s)a

3 % Discount Rate 7 % Discount Rate

5

th Mean 95th 5th Mean 95th

Proposal Option 4 1,331,956 $3,446 $6,509 $12,385 $2,562 $4,839 $9,208

Final Rule 1,466,650 $3,793 $7,166 $13,636 $2,820 $5,328 $10,138

Proposal Option 2 2,044,018 $4,717 $8,922 $16,993 $3,359 $6,354 $12,102

Baseline 2,232,409 $7,306 $13,825 $26,338 $6,738 $12,751 $24,292

a

5th and 95th are the 5th and 95th percentiles based on the results of the Krinsky and Robb (1986) approach.

Source: U.S. EPA analysis for this report

7.3.7 Inland Region

Table 7-11 presents the estimated increase in recreational fishing harvest and associated welfare 

gains from the elimination of baseline IM&E in the Inland region. EPA estimates an annual 

harvest increase of 11.90 million fish from the elimination of baseline IM&E, the majority 

attributable to IM&E of “bass,” “panfish,” and “unidentified” species groups. The associated 

mean annual welfare gain is $32.1 million and $29.6 million, evaluated at 3 percent and 7 percent 

discount rates, respectively. The majority of the monetized recreational benefits from eliminating 

baseline IM&E is attributable to IM&E of “bass,” “panfish,” and “unidentified” fish.

Table 7-11 also presents the annual recreational harvest increases and welfare gains to Inland 

anglers under the final rule and other options considered. EPA estimates the final rule will 

increase annual harvest by 3.73 million fish. The mean annualized welfare gain under the final 

rule will be $7.6 million using a 3 percent discount rate and $5.7 million using a 7 percent 

discount rate. Annual harvest increases under other options considered range from 3.57 million 

fish under Proposal Option 4 to 9.70 million fish under Proposal Option 2. Mean annualized 

benefits under other options considered range from $7.3 to $17.2 million using a 3 percent 

discount rate and $5.4 to $11.9 million using a 7 percent discount rate. Appendix I presents 

additional species-specific results for final file rule, other options considered, and the elimination 

of baseline IM&E.
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Table 7-11: Recreational Fishing Benefits from Eliminating or Reducing Baseline IM&E 

at Regulated Facilities in the Inland Region, for the Final Rule and Options Considered 

(2011$)

Regulatory Option

Annual Increase in 

Recreational Harvest

(harvestable adult 

fish)

Annualized Benefits from Increase in Recreational Harvest 

(2011$, 1,000s)a

3 % Discount Rate 7 % Discount Rate

5

th Mean 95th 5th Mean 95th

Proposal Option 4 3,570,053 $3,503 $7,284 $15,231 $2,616 $5,440 $11,375

Final Rule 3,731,608 $3,661 $7,613 $15,918 $2,735 $5,686 $11,889

Proposal Option 2 9,704,334 $8,290 $17,204 $35,865 $5,726 $11,883 $24,773

Baseline 11,900,351 $15,471 $32,105 $66,919 $14,270 $29,611 $61,722

a

5th and 95th are the 5th and 95th percentiles based on the results of the Krinsky and Robb (1986) approach.

Source: U.S. EPA analysis for this report

7.3.8 National Estimates

Table 7-12 presents the estimated national increase in recreational fishing harvest and associated 

welfare gains to anglers from eliminating baseline IM&E. EPA estimates an annual harvest 

increase of 25.31 million fish from eliminating baseline IM&E. The associated mean annual 

welfare gain is $78.8 million and $72.0 million, evaluated at 3 percent and 7 percent discount 

rates, respectively.

Table 7-12 also presents the national recreational harvest increases and welfare gains to anglers 

under the final rule and other options considered. EPA estimates the final rule will increase 

annual harvest by 6.50 million fish. The mean annualized welfare gain under final rule will be 

$18.2 million using a 3 percent discount rate and $13.5 million using a 7 percent discount rate. 

Annual harvest increases under other options considered range from 6.13 million fish under 

Proposal Option 4 to 20.53 million fish under Proposal Option 2. Mean annualized benefits under 

other options considered range from $17.1 to $43.0 million using a 3 percent discount rate and 

$12.6 to $29.5 million using a 7 percent discount rate. Appendix I presents additional speciesspecific results for the final rule, other options considered, and the elimination of baseline IM&E.

Table 7-12: National Recreational Fishing Benefits from Eliminating or Reducing 

Baseline IM&E at Regulated Facilities, for the Final Rule and Options Considered (2011$)

Regulatory Option

Annual Increase in 

Recreational Harvest

(harvestable adult 

fish)

Annualized Benefits from Increase in Recreational Harvest 

(2011$, 1,000s)a

3 % Discount Rate 7 % Discount Rate

5

th Mean 95th 5th Mean 95th

Proposal Option 4 6,128,847 $8,803 $17,061 $33,635 $6,513 $12,632 $24,914

Final Rule 6,501,444 $9,419 $18,239 $35,919 $6,969 $13,504 $26,607

Proposal Option 2 20,534,230 $23,396 $42,963 $81,100 $16,085 $29,547 $55,798

Baseline 25,309,796 $43,200 $78,787 $147,922 $39,452 $72,013 $135,312

a

5th and 95th are the 5th and 95th percentiles based on the results of the Krinsky and Robb (1986) approach.

Source: U.S. EPA analysis for this report
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7.4 Limitations and Uncertainties

A number of limitations and uncertainties are common in application of benefit transfer 

approaches to valuing benefits of environmental policies and programs. To better characterize the 

uncertainty or error bounds around predicted WTP, EPA adopted the statistical procedure 

described by Krinsky and Robb in their 1986 Review of Economics and Statistics paper 

“Approximating the Statistical Property of Elasticities,” to generate lower and upper bound WTP 

values identified as the 5th and 95th percentile of values from the empirical distribution. 

Additional detail regarding the Krinsky and Robb approach is provided in Section 7.2.3. These 

bounds may help decision-makers understand the uncertainty associated with the benefit results 

for eliminating baseline IM&E and the 316(b) final rule and regulatory options considered.

Specific limitations and uncertainties associated with the estimated regression model and the 

underlying studies are discussed in Section A5-3.3e of EPA (2006). Additional limitations and 

uncertainties associated with the calculation of per-fish values from the model, and with the use 

of those values to estimate the welfare gain resulting from the final section 316(b) regulation and 

regulatory options considered, are addressed below in Table 7-13.

Table 7-13: Other Caveats, Omissions, Biases, and Uncertainties in the Recreational 

Benefits Estimates

Issue

Impact on 

Benefits 

Estimate

Comments

Exclusion of error term 

from regression 

equation to predict 

marginal values

Estimates 

understated

Because the source of error in the underlying meta-data is unknown EPA 

decided not to include the error term in estimating marginal values per 

fish. EPA notes that if the source of error is due primarily to the omitted 

variables the estimated WTP may be biased downward. See Section 7.2.1

for more a detailed discussion regarding EPA’s treatment of the error 

term.

Validity and reliability 

of benefit transfer Uncertain

The validity and reliability of benefit transfer—including that based on 

meta-analysis—depend on a variety of factors. While benefit transfer can 

provide valid measures of use benefits, tests of its performance have had 

mixed results (e.g. Desvousges et al. 1998; Smith et al. 2002; Vandenberg 

et al. 2001) . Nonetheless, benefit transfers are increasingly applied as a 

core component of benefit-cost analyses conducted by EPA and other 

government agencies (Bergstrom and De Civita 1999; Griffiths undated). 

Smith et al. (2002, p.134) state that “nearly all benefit cost analyses rely 

on benefit transfers, whether they acknowledge it or not.” An important 

factor in any benefit transfer is the ability of the study site or estimated 

valuation equation to approximate the resource and context for which 

benefit estimates are desired. As is common, the meta-analysis model 

presented here provides a close but not perfect match to the context in 

which values are desired.

IM&E estimates Uncertain

Recreational losses due to IM&E may be higher or lower than expected

for a number of reasons. Projected changes in recreational catch may be 

underestimated because cumulative impacts of IM&E over time are not 

considered. In particular, IM&E estimates include only individuals 

directly lost to IM&E, not their progeny. Additionally, the interaction of 

IM&E with other stressors may have either a positive or negative effect 

on recreational catch. Finally, in estimating recreational fishing losses, 

EPA used the most current IM&E data available provided by facilities,

which in some cases may not reflect current conditions.
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May 2014 8-1

8 Nonuse Benefit Transfer Approach

8.1 Introduction

Comprehensive estimates of total social value include both use and nonuse values, and may be compared 

to total social cost. “Non-use values, like use values, have their basis in the theory of individual 

preferences and the measurement of welfare changes. According to theory, use values and non-use values 

are additive” (Freeman III 1993). Consequently, excluding nonuse values from consideration is likely to 

substantially understate total social values. Recent economic literature provides strong support for the 

hypothesis that nonuse values are greater than zero for many types of environmental improvements. 

Moreover, when a substantial fraction of the population holds even small per capita nonuse values, these 

nonuse values can be very large in the aggregate. As stated by Freeman (1993), “there is a real possibility 

that ignoring non-use values could result in serious misallocation of resources.” Both EPA’s own 

Guidelines for Preparing Economic Analysis and OMB’s Circular A-4, governing regulatory analysis, 

support the need to assess nonuse values (USEPA 2010a; USOMB 2003).

The vast majority (97 percent) of current (i.e., baseline) IM&E at CWIS consist of forage species and

unlanded individuals of recreational and commercial species (Chapter 3). Although these forage and 

unlanded fish do not have direct use values, they may be valued by nonusers of fisheries resources (whose 

value for such fish is by definition a nonuse value) and by users separate from their use value. The nonuse 

values are likely to be substantial because fish and other species found within aquatic habitats impacted 

directly and indirectly by CWIS provide other valuable ecosystem goods and services, including nutrient 

cycling and ecosystem stability. Therefore, a comprehensive estimate of the welfare gain from reducing 

IM&E must include an estimate of nonuse benefits. The following sections present EPA’s qualitative 

assessment of nonuse benefits and partial monetized nonuse benefits based on benefit transfer from an 

existing stated preference study. EPA evaluated the public’s nonuse values for aquatic habitats 

qualitatively by considering evidence from existing aquatic restoration and protection programs (Section 

8.2). EPA also provides a quantitative estimate of the numbers of A1E whose benefits are likely to be 

mainly associated with nonuse (Table 3-15; reproduced as Table 8-1). Finally, EPA used benefit transfer 

to generate a partially monetized estimate of nonuse benefits associated with reductions in IM&E of fish, 

shellfish, and other aquatic organisms under the final rule and other options considered in the North 

Atlantic and Mid-Atlantic Regions. The methodology is described in Section 8.3 and Section 8.4 presents 

the results.
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May 2014 8-2

Table 8-1: Baseline IM&E and IM&E Reductions at All Regulated Facilities 

(Manufacturing and Generating) Nationally, and Reductions under the Final Rule 

and Other Options Considered

IM&E Loss Metric (per year)

Reductions in Losses Baseline 

Losses Proposal 

Option 4

Final

Rule

Proposal 

Option 2

All Species (million A1E) 614.16 652.00 1637.49 1930.97

Forage Species (million A1E) 528.22 560.80 1258.67 1459.70

Commercial & Recreational Species (million A1E) 85.94 91.20 378.82 471.28

Commercial & Recreational Harvest (million fish) 16.13 17.11 44.66 54.02

A1E Losses with Direct Use Value (%) 2.6% 2.6% 2.7% 2.8%

Source: U.S. EPA analysis for this report

8.2 Public Policy Significance of Ecological Improvements from the Final Rule

EPA expects that changes to CWIS design and operation resulting from the final existing facilities rule

will reduce IM&E of fish, shellfish, and other aquatic organisms and lead to increases in local and 

regional fishery populations and ecosystem stability. In addition to those direct effects, many indirect 

ecosystem goods and services are affected by IM&E, thermal effects, and flow alteration. Due to the 

wide-ranging nature of these indirect effects, the existing facilities rule is likely to enhance the value of 

ecosystem goods and services provided by aquatic habitats, and will help reduce the overall impact of 

anthropogenic effects on aquatic systems affected by CWIS. Chapter 2 provides a detailed list of 

ecosystem services potentially affected by the rule. 

EPA assessed the potential magnitude of nonuse benefits using information regarding government 

spending on the protection, restoration, and regulation of various aquatic habitats. These habitats include 

Marine Protected Areas (Section 8.2.2) and a subset of freshwater ecosystems undergoing large-scale 

restoration efforts (Section 8.2.3). Although not estimates of benefits of improving aquatic ecosystems, 

these expenditures are still an indication of significant social values for the protection of aquatic 

resources.

8.2.1 Effects on Depleted Fish Populations

Reducing IM&E will contribute to the health and sustainability of the affected fish populations by 

lowering the overall level of mortality for these populations. Fish populations suffer from numerous 

sources of mortality, both natural and anthropogenic. Natural sources include weather, predation by other 

fish, and the availability of food. Human activities besides IM&E include fishing, pollution, and habitat 

alteration. Fish populations decline when they are unable to compensate sufficiently for their overall level 

of mortality. Although it is difficult to measure, the compensatory ability of an aquatic population—the 

capacity for a species to increase survival, growth, or reproduction rates in response to decreased 

population —is likely compromised by IM&E and the cumulative impact of other stressors in the 

environment over extended periods of time (USEPA 2006a).

Lowering the overall mortality level increases the probability that a population will be able to 

compensate for mortality at a level sufficient to maintain long-term health. In some cases, impingement 

and entrainment may be significant source of mortality to already-depleted stocks of commercially 

targeted species (see Chapter 2). Depleted saltwater fish stocks affected by IM&E include winter 

flounder, Atlantic Cod, and rockfish, for example (NMFS 2012). As discussed in Chapter 2, IM&E also 
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increases the pressure on freshwater species native to the Great Lakes, such as lake whitefish and yellow 

perch, the populations of which have declined dramatically in recent years (USDOI 2008; Wisconsin 

DNR 2003).

The federal government and the states have recognized the public importance of maintaining sustainable 

fisheries, achieving recovery of depleted fish stocks, and ensuring that functioning ecosystems are passed 

to future generations. Federal and state government actions have included buying fishing licenses and 

fishing vessels from individual fishers when stocks appear depressed, imposing restrictions on 

commercial and recreational harvests, conducting large-scale ecosystem restoration projects (USDOI 

2008), and President George W. Bush’s executive order creating a national system of marine protected 

areas (Executive Order No. 13158 2001).Together, these governmental actions suggest that the public 

holds substantial nonuse values for aquatic habitats.

8.2.2 Marine Protected Areas

A Marine Protected Area (MPA) is “any area of the marine environment that has been reserved by 

federal, state, tribal, territorial, or local laws or regulations to provide lasting protection for part or all of 

the natural and cultural resources therein” (Executive Order No. 13158 2001). In some states, the majority 

of coastal waters are found within MPAs (e.g., Massachusetts, Hawaii). The ecological importance of 

MPAs varies widely because of the broad focus on the preservation and maintenance of cultural and

natural resources, and/or sustainable production (NMPAC 2006). Consequently, evaluating the impact of 

CWIS on the entire universe of MPAs may overstate the nonuse values for the ecological benefits 

associated with reductions in IM&E: because some MPAs are focused on the preservation of cultural 

resources (including historic shipwrecks, aircraft and other structures, submerged prehistoric remains, and 

sites with traditional cultural properties), they are likely to be less ecologically important than others. 

For this reason, EPA focused on facilities in MPAs within the National Estuary Program (NEP). The NEP 

was established in the 1987 amendments to the CWA because the “Nation’s estuaries are of great 

importance to fish and wildlife resources and recreation and economic opportunity [and because 

maintaining] the health and ecological integrity of these estuaries is in the national interest” (Water 

Quality Act 1987). In addition to the 28 estuaries designated under the NEP (USEPA 2010b), EPA

included facilities found in Chesapeake Bay (which is protected by the Chesapeake Bay Program [CBP]). 

Substantial federal and state resources have been directed to the NEP and CBP to enhance conservation of 

and knowledge about estuaries. Including funds received from federal, state, local and private sources, 

from 2005 to 2013, the NEP spent $3.5 billion to protect and restore aquatic habitat, support land 

acquisitions, conduct outreach and research, upgrade wastewater and stormwater infrastructure, and 

implement other priority actions to benefit the health of the 28 estuaries designated under the NEP. 

Approximately 11.1 percent, or $389 million, was designated for restoration programs (USEPA 2014). 

Between fiscal years 1995 and 2004, direct funding by federal and State governments to restore the 

Chesapeake Bay averaged $366 million annually (GAO 2005), with an additional $131 million in direct 

spending fiscal year 2005 (CBP 2007).. Moreover, recent governmental action is likely to increase 

restoration efforts in the future (Executive Order No. 13508 2009), These expenditures reflect high public 

values for restoring (or protecting) the biological integrity of these ecosystems.

A total of 44 regulated facilities are located on 32 waterbodies within MPAs designed to preserve natural 

resources and/or to ensure sustainable production (NOAA 2012) (Figure 8-1; Table 8-2). Although these 

facilities are located in fresh, brackish, and marine waters, the vast majority located within MPAs are in 

coastal waters and are most highly concentrated in the Northeastern U.S. (i.e. both coastal and inland 
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facilities) (Figure 8-1; Table 8-2). Under the final rule, EPA estimates that 60 percent of regulated 

facilities (15 out of 25 facilities for which data are available) found within MPAs obtain reductions in 

impingement mortality. This estimate is based upon facilities for which sufficient data exist for EPA to 

estimate technology currently in-place. Additionally, although entrainment may be reduced at some 

facilities as a consequence of the final rule, EPA was not able to estimate reductions in entrainment likely 

to occur due to site-specific determination of entrainment BTA for facilities with CWIS inside of MPAs.

Figure 8-1: Regulated Facilities with CWIS Located in Marine Protected Areas
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Table 8-2: 316(b) Facilities in Marine Protected Areas and Improvements in IM&E Tech for 

the Final Rule and Other Options Considered

Region

Number of Facilities with Improved

Technologies by Optiona,b

Baseline Proposal 

Option 4 Final Rule Proposal Option 2

IM E IM E IM E

Number of 

Facilities

Affected 

Waterbodies

Facilities With 

Tech Datab

California 1 0 1 0 1 1 2 2 1

North Atlantic 2 0 2 0 2 2 7 6 6

Mid-Atlantic 8 0 8 0 8 6 24 15 12

South Atlantic 0 0 0 0 0 0 2 1 1

Gulf of Mexico 2 0 2 0 3 3 3 3 3

Great Lakes 0 0 0 0 0 0 0 0 0

Inland 2 0 2 0 2 2 6 5 2

Total 15 0 15 0 16 14 44 32 25

a

IM is impingement mortality and E is entrainment.

b EPA does not have adequate data for all facilities to estimate current compliance with, or the number of facilities installing improved 

technologies because of, the final rule.

Source: U.S. EPA analysis for this report 

8.2.3 Restoration of Freshwater Ecosystems

Reducing the effect of CWIS at regulated facilities is likely to benefit aquatic ecosystems nationwide. 

Due to a high density of facilities, and the potential for cumulative impacts associated with facilities in 

close proximity to each other (see Chapter 2 for additional details), the greatest improvements may occur 

in areas of the Great Lakes Basin and Mississippi River. There are large-scale ecosystem restoration 

efforts for these freshwater bodies that indicate public support for restoring the ecological health of these 

ecosystems (Northeast Midwest Institute 2010; USDOI 2008; USFWS 2011; Upper Mississippi River 

Basin Association 2004).

Nationally, ecosystem restoration efforts focus on many issues, including coastal habitat restoration, 

protection of fish species, and conservation of migratory birds. For example, the federal government 

provided in excess of $1.7 billion for sport fish restoration between fiscal years 2005 and 2009 (USFWS 

2010c), and has initiated a 5-year multi-agency initiative to restore the ecosystems of the Great Lakes, for 

which $1.05 billion of federal funds were appropriated in fiscal years 2010 through 2012 (Great Lakes 

Restoration Initiative 2012). Additionally, the restoration of major inland river ecosystems has been 

recognized as a worthwhile goal, with more than $100 million spent on restoring ecosystems along the 

Mississippi River (Brescia 2002; USEPA 2004b). 

Overall, the federal government spent more than $600 million on major restoration projects in aquatic 

ecosystems in FY2012 (Behrens 2012; USACE 2013). These projects include, but are not limited to, the 

construction of fish ladders, restoration of wetland nursery habitat, and the reduction of pollution. These 

expenditures indicate a high value placed on the maintenance and restoration of ecosystem function and 

the integrity of freshwater ecosystems. 
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8.2.4 Summary of Evidence for Nonuse Values of Ecosystems Affected by CWIS

Overall, the public appears to hold substantial nonuse values for ecosystems and species impacted by 

CWIS. For example, governments at various levels have committed to the designation of MPAs covering 

large areas. Governments also have committed substantial resources to the restoration of degraded aquatic 

ecosystems. 

EPA notes that funding amounts for the protection and restoration of aquatic ecosystems is not an 

appropriate measure of benefits (i.e., willingness to pay (WTP)). As described by Brown (1993)

“economic efficiency involves a balance between demand and supply, whereas restoration cost has 

nothing to do with demand or value” (p.88). Moreover, these costs do not necessarily reflect a costeffective allocation of resources (Kopp and Smith 1993). High costs of restoration or protection may 

overstate benefits, and likewise, while low costs may under-state benefits. 

Although not estimates of benefits of improving aquatic ecosystems, these expenditures are still an 

indication of significant social values for the protection and resource of aquatic resources affected under 

the final rule and options considered. Chapter 2 provides additional qualitative discussion of adverse 

environmental impacts from regulated facilities for which society is like to hold significant nonuse values. 

8.3 Benefit Transfer for Nonuse Values in the North Atlantic and Mid-Atlantic 

Regions

Stated preference (SP) methods and benefit transfers based on SP studies are the generally accepted 

techniques for estimating total social values (including use and nonuse) values. SP methods rely on 

surveys that ask people to state their WTP for particular ecological improvements, such as increased 

protection of aquatic species or habitats with particular attributes. EPA searched the literature for SP 

studies that estimated WTP for ecological improvements similar to those impacted by CWIS of regulated 

facilities. EPA identified a SP survey of Rhode Island residents that is a relatively good match to the 

316(b) policy context and used this study to develop a benefit transfer approach to estimate nonuse 

benefits associated with reduction in IM&E under the final rule and other options considered. EPA was 

only able to use this approach for the North Atlantic and Mid-Atlantic regions. 

The study developed a Bioindicator-Based Stated Preference Valuation (BSPV) method specifically for 

applications to ecological systems,37 and used it to address Rhode Island residents’ preferences for the 

restoration of migratory fish passage over dams in a watershed within Rhode Island (Johnston et al. 

2012). The study results have been published in multiple scientific journals and books including Johnston 

et al. (2012), Johnston et al. (2011a), Johnston et al. (2011b), and Zhao et al. (2013). EPA applied a model 

presented by Zhao et al. (2013).

Similar to the 316(b) regulatory context, the study addressed policy changes affecting individuals of 

forage species but for which ultimate population effects are unknown. The authors estimated total values 

by asking respondents to consider changes in ecological indicators reflecting quantity of habitat, 

abundance of wildlife, ecological condition, and abundance of migratory fish species. The study’s choice 

experiment allows direct estimation of households’ WTP for policies that increase the number of fish in 

watersheds. The benefits transfer involves a translation from reintroducing fish to aquatic habitats to 

reducing IM&E. Within the benefit transfer application, EPA is able to focus on nonuse values by holding 

constant all effects related to identifiable human uses.

 

37 The stated preference survey was funded by the EPA’s Science to Achieve Results (STAR) competitive grant program.
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Section 8.3.1 describes the transfer study and BSPV methods in greater detail. This is followed by a 

description of EPA’s benefit transfer methods (Section 8.3.2) and estimated benefits for the 316(b) final 

rule and other options considered in Section 8.4. EPA also developed an original SP survey to assess 

public values for reductions in IM&E and ecosystem improvements under the final rule. The 316(b) SP 

survey is discussed separately in Chapter 11. However, EPA notes that it would be inappropriate to add 

the benefits from the benefits transfer approach to benefits based on the SP survey, as this would result in 

double-counting of benefits.

8.3.1 Description of the Benefit Transfer Study and BSPV Methods

As described by Johnston et al. (2012), the Rhode Island study developed the BSPV method to promote 

ecological clarity, and closer integration of ecological and economic information within SP studies. The 

study focus on improved ecological valuation is an EPA priority as described in findings of EPA’s 

Science Advisory Board’s Committee on Valuing the Protection of Ecological System and Services 

(USEPA 2009b). In contrast to traditional SP valuation, BSPV employs a more structured and formal use 

of ecological indicators to characterize and communicate welfare-relevant changes. The method begins 

with a formal basis in ecological science, and extends to relationships between attributes in respondents’ 

preference functions and those used to characterize policy outcomes. 

Specific BSPV guidelines ensure that survey scenarios and resulting welfare estimates are characterized 

by (1) a formal basis in established and measurable ecological indicators, (2) a clear structure linking 

these indicators to attributes influencing individuals’ well-being, (3) consistent and meaningful 

interpretation of ecological information, and (4) a consequent ability to link welfare measures to 

measurable and unambiguous policy outcomes. The welfare measures provided by the BSPV method can 

be linked unambiguously to models and indicators of ecosystem function, are based on measurable 

ecological outcomes, and are more easily incorporated into benefit-cost analysis than traditional SP 

valuation studies. The BSPV method also provides a means to estimate values for ecological outcomes 

that individuals might value, even though they may not fully understand all relevant ecological science.

The study developed the BSPV methods for a case study addressing public preferences for the restoration 

of migratory fish passage in the Pawtuxet Watershed. The BSPV survey (Rhode Island River: Migratory 

Fishes and Dams) was designed to estimate WTP of Rhode Island residents for options that would 

provide fish passage over dams, and access to between 225 and 900 acres of historical habitat within the 

Pawtuxet Watershed for which there is currently no fish passage (Johnston et al. 2011a; Johnston et al. 

2011b; Johnston et al. 2012; Zhao et al. 2013). The watershed currently provides no spawning habitat for 

migratory fish; access to all 4,347 acres of potential habitat is blocked by 22 dams and other obstructions 

(Erkan 2002).

The survey was developed and tested over 21⁄2 years through a collaborative process involving 

interactions of economists and ecologists; meetings with resource managers, natural scientists, and 

stakeholder groups. This included 12 focus groups with 105 total participants. In addition to survey 

development and testing in focus groups, individual interviews were conducted with both ecological 

experts and non-experts. Tests included cognitive interviews (Kaplowitz et al. 2004), verbal protocols 

(Schkade and Payne 1994), and other pretests in order to gain additional insight into respondents’ 

understanding and interpretation of the survey. Careful attention to development and testing helped ensure 

that the survey language and format would be easily understood by respondents, that respondents would 

have similar interpretations of survey terminology and scenarios, and that the survey scenarios captured 

restoration outcomes viewed as relevant and realistic by both respondents and natural scientists. In all 
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cases, the authors paid particular attention to the use and interpretation of ecological indicators and related 

information in the survey.

The choice scenarios and restoration options presented within the survey were informed in part by data 

and restoration priorities in the Strategic Plan for the Restoration of Anadromous Fishes to Rhode Island 

Coastal Streams (Erkan 2002). The study authors drew additional information from the ecological 

literature on fish passage restoration, interviews with ecologists and policy experts, and other sources 

described below. Consistent with the strategic plan, the choice experiment within the survey addressed 

restoration methods that neither require dam removal nor would cause appreciable changes in river flows; 

considered options included fish ladders, bypass channels, and fish lifts. The choice experiment addresses 

forage species such as alewife and blueback herring that are neither subject to current recreational or 

commercial harvest in Rhode Island nor are charismatic species. Hence, the species affected are a close 

analog to the forage fish affected in the 316(b) policy context. Moreover, the study’s policy context

involves changes to technologies used within in-water structures (i.e., the use of fish ladders or fish lifts at 

dams), providing another parallel to the 316(b) context, which also involves the use of new technologies 

within in-water structures to mitigate harm to aquatic organisms.

The choice experiment asked respondents to consider alternative options for the restoration of migratory 

fish passage in the Pawtuxet Watershed. Respondents were provided with two multi-attribute restoration 

options, “Restoration Project A” and “Restoration Project B,” as well as a status quo option that would 

result in no policy change and zero household cost. An example of a choice question is presented in 

Figure 8-2. Prior to administration of the choice experiment questions, the survey provided information 

that: (1) described the current status of Rhode Island river ecology and migratory fish compared to 

historical baselines, (2) characterized affected ecological systems and linkages, (3) described the methods 

and details of fish passage restoration, and (4) provided the definitions, derivations, and interpretations of 

ecological indicators used in the survey scenarios, including the reason for their inclusion. All survey 

language and graphics were pretested carefully to ensure respondent comprehension.

Within each choice experiment question, the restoration options are characterized by seven attributes, 

including five ecological indicators, one attribute characterizing public access, and one attribute 

characterizing unavoidable household cost. The study fielded multiple versions of the survey, including 

variations in the definition or set of included ecological indicators. The versions differ in the metric used 

to characterize the impacts of restoration on migratory fish. 

The first uses a Population Viability Analysis (PVA) score that indicates “the probability (in percentage 

terms) that migratory species will still migrate the river in 50 years, as calculated by scientists” (Zhao et 

al. 2013, p.10). The second, uses a migratory fish score, migrants, that indicates “the expected number of 

adults fish that will swim upstream each year”, “[p]resented as a percentage of the reference values for the 

watershed” (Zhao e l. 2013, p.10). Respondents were either sent the PVA or migrants version. The other 

four ecological indicators presented include (1) the quantity of river habitat accessible to migratory fishes 

(acres), (2) the abundance of fish suitable for recreational harvest (catch), (4) the abundance of fishdependent wildlife (wildlife), and (4) overall ecological condition measured by an index of biotic integrity 

score (IBI). EPA used a model variant published by Zhao et al. (2013) which was estimated based on 

combined responses to both survey versions (PVA and migrants). The model specification allows EPA to 

isolate WTP for migrants, which provides a good match to the policy variable (i.e., the number of fish 

saved).

EPA estimated the number of fish saved under the final rule and other options considered using the 

methods described in Chapter 3. Although the PVA score is likely to be affected by the number of fish 
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saved, estimating expected changes in population viability in the 316(b) context is not feasible due to the 

lack of data allowing EPA to relate changes in individual species losses to populations, which is 

particularly the case for forage species.

8.3.2 Benefit Transfer Methodology

The following subsections describe EPA’s benefit transfer methods using the BSPV study. Section 8.3.2.1

describes the estimation of WTP for a percentage increase in fish numbers and Section 8.3.2.2 describes 

the application of BSPV WTP values to IM&E reductions under the final rule and other options 

considered.

8.3.2.1 Estimating WTP for a Percentage Increase in Fish Numbers

Figure 8-2 is a sample choice experiment question from the migrants version of the study as presented in 

Zhao et al. (2013).38 The five ecological attributes (migrants, acres, catch, wildlife, and IBI) are expressed 

as a percentage relative to upper and lower reference conditions (i.e., best and worst possible in the 

Pawtuxet) as defined in the survey information. Relative scores represent percent progress towards the 

upper reference condition (100 percent), starting from the lower reference condition (0 percent). This 

implies bounds on the potential attribute levels that might occur in the choice questions, following 

guidance in the literature to provide visible choice sets (Bateman et al. 2004). Because the survey used 

lower and upper bounds on a percentage point scale, it can be used for benefits transfer if IM&E 

reductions can be translated to the same scale. Hence, EPA based its benefit transfer on estimated WTP 

per percentage increase in fish numbers (migrants, “migratory fish” in Figure 8-2) relative to reference 

conditions. 

EPA notes that the choice experiment question in the survey instrument also presented the increased 

number of fish and the total possible increase in the number of fish (the upper reference condition) 

directly below the percent improvement in migratory fish,. The number of fish affected by the existing 

facilities rule is many times larger than the number of fish corresponding to the maximum reference 

condition within the survey materials, because the Rhode Island survey covers a single watershed, rather 

than a large region. Because of this difference in scale, directly applying values per fish from the study to 

the 316(b) fish reduction estimates would likely overstate benefits of the final rule. Basing the benefit 

transfer on percentage improvement ameliorates this difference in scale, at least partially, because 

improvements are bounded by the 100 percent upper reference condition in all cases. The remainder of 

this section describes EPA’s approach for using the implicit price, or WTP per percentage improvement, 

in migratory fish based on the Rhode Island study. Additional discussion of scale of fisheries 

improvements and the affected population is provided in Section 8.6. 

 

38 In the PVA version, the “migratory fish” (i.e., migrants) attribute is replaced with the PVA attribute.
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Figure 8-2: Example Choice Experiment Question from the Zhao et al. (2013) Study including the 

Migratory Fish Score
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Zhao et al. (2013) estimated a random utility model using simulated likelihood mixed logit accounting for 

correlations in choices from the same respondent.39 Zhao et al. (2013) specified coefficients on all noncost attributes, except catch, as random with a normal distribution within the mixed logit model. The 

study specified the coefficient on annual household cost (cost) with sign-reversed as random with a 

bounded triangular distribution. This cost specification ensures positive marginal utility of income. The 

likelihood simulations use Halton draws, or “intelligent draws”, from the parameter distributions during 

model estimation. Halton draws are “generated number theoretically rather than randomly and so 

successive points at any stage ‘know’ how to fill in the gaps left by earlier points” (Bhat 2001, p. 684). 

This can improve model estimation compared to using purely random draws.

Table 8-3 presents the Zhao et al. (2013) unrestricted mixed logit model. The model was estimated based 

on both the PVA and migrants choice experiments including multiplicative interactions between each 

non-cost attribute and d_mig, a dummy variable identifying observations from the migrants choice 

experiment.40 The model is significant at p<0.0001 with a pseudo-R

2

of 0.31. The coefficients of all 

environmental attributes, expect catch, are significant at p<0.01. The interactions allow for coefficient 

estimates to vary systematically between the PVA and migrants choice experiments. Using this 

specification, the marginal utility of non-cost attribute k is given by ( ̂

 ̂ ) for the migrants

choice experiment.

 

39 Mixed logit is an approach for modeling discrete choices subject to preference heterogeneity, based on the assumption that 

individual’s preferences are randomly distributed and that heterogeneity in population preferences can be captured by 

estimating the mean and variance of the random parameter distributions (Holmes & Adamowicz 2003). As described by 

Hensher and Greene (2003, p. 170), “the mixed logit model offers an extended framework within which to capture a greater 

amount of behavioral choice making. Broadly speaking, the mixed logit model aligns itself much more with reality than 

most discrete choice models with every individual having their own inter-related systematic and random components for 

each alternative in their perceptual choice set(s).”

40 Zhao et al. (2013) present an additional pooled model without interactions. That model is not presented here because it does 

allow for the isolation of WTP for changes in migrants and thus not well suited for benefits transfer to the 316(b) context.
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Table 8-3: Results of the Unrestricted Model from Zhao et al. (2013)

Variable Coefficient Standard Error

Random Parameters

acres 0.0463*** 0.0117

fish (PVA and migrants pooled) 0.0169*** 0.0043

IBI 0.0497*** 0.0168

access 1.1577*** 0.2056

wildlife 0.0267*** 0.0083

neither -4.2235*** 0.4522

cost (bounded triangular, sign reversed) 0.0533*** 0.0058

Non-random Parameters

catch 0.0011 0.0082

acres × d_mig 0.0010 0.0161

fish × d_mig 0.0093 0.0087

IBI × d_mig -0.0345 0.0229

access × d_mig 0.2170 0.2643

wildlife × d_mig -0.0038 0.0113

neither × d_mig -0.1865 0.8233

catch × d_mig -0.0052 0.0114

Random Parameter Distributions

std. dev. acres 0.0679*** 0.0216

std. dev. fish 0.0154 0.0115

std. dev. IBI 0.0816*** 0.0294

std. dev. access 1.5873*** 0.2544

std. dev. wildlife 0.0174 0.0257

std. dev. neither 4.8330*** 0.7627

spread cost (bounded triangular) 0.0533*** 0.0058

Model Statistics

-2 Log likelihood χ 1,127.26*** -

Pseudo-R

2 0.31 -

Observations (N) 1,634 -

Notes:

***, **, * indicates significance at 1%, 5%, 10% levels, respectively.

Parameter Descriptions:

acres – The number of acres of river habitat accessible to migratory fish.

fish – Variable that pools observations on PVA and migrants across the two choice experiments. 

PVA – Population viability analysis (PVA) score. This was described to respondents as “the probability (in percentage terms) 

that migratory species will still migrate the river in 50 years, as calculated by scientists.”

migrants - The percentage point increase in the number of migratory fish able to reach watershed habitat.

catch – The number of catchable-size fish in restored areas.

wildlife – Number of fish-eating wildlife species that are common in restored areas.

IBI – Index of biotic integrity (IBI) score reflecting the similarity of the restored area to the most undisturbed watershed in 

Rhode Island.

access – Indicates whether the restored area is accessible to the public for walking and fishing.

cost – The household annual cost required to implement the restoration program.

neither – Alternative specific constant (ASC) associated with the status quo, or a choice of neither plan.

d-mig – Binary (dummy) variable identifying observations from the choice experiment including migrants to represent effects 

on migratory fish.

Sources: U.S. EPA Analysis for this report, Zhao et al. (2013)

Implicit prices for each attribute are calculated based on the ratio of marginal utility and cost as 

( ̂

 ̂ ) ̂ ⁄ . Because the betas are random for some attributes, simulations are used to 

estimate WTP per percentage improvement for each of the environmental attributes. Zhao et al. (2013) 

estimated WTP using the welfare simulation approach of Johnston and Duke (2007) following Hensher 
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and Greene (2003). “The procedure begins with a parameter simulation following the parametric 

bootstrap of Krinsky and Robb (1986), with R=1000 random draws taken from the mean parameter vector 

and associated covariance matrix. For each draw, the resulting parameters are used to characterize 

asymptotically normal empirical densities for fixed and random coefficients. For each of these R draws, a 

coefficient simulation is then conducted for each random coefficient, with S=1000 draws taken from 

simulated empirical densities (either normal or bounded triangular, depending on the distribution for each 

coefficient). Welfare measures are calculated for each draw, resulting in a combined empirical 

distribution of R×S observations from which summary statistics are derived” (Zhao et al. 2013, p.17-18). 

The resulting empirical distributions accommodate both the sampling variance of parameter estimates and 

the estimated distribution of random parameters.

The welfare simulation approach provides a mean WTP estimate of $0.69 per percentage point increase in 

migratory fish in 2008$ (( ̂

 ̂ ) ̂ ⁄ ), and $0.72 when adjusted to 2011$.41

 Results 

for total household WTP for a series of percentage improvements in fish numbers are shown below in 

Table 8-4. A zero percent improvement would mean no additional fish and 100 percent represents the 

maximum possible number of fish that may be supported by the ecosystem.42 These percentage 

improvements do not represent population increases; rather, they reflect new fish within a specific habitat 

area that may be counted. In context of the 316(b) benefit transfer, the new fish are A1E saved under 

regulatory options. 

EPA transferred the estimate of $0.72 per percentage improvement to estimate nonuse benefits of 316(b) 

regulatory options as described in the next section. The model makes it possible to distinguish benefits 

associated with resource uses from those associated primarily with nonuse motives. Because EPA used 

the implicit price for migratory fish changes for the benefit transfer application, WTP is estimated for 

increases in non-harvested fish alone. The transfer holds constant all effects related to identifiable human 

uses (e.g., effects on catchable fish, public access, observable wildlife, etc.). The remaining welfare 

effects—derived purely from effects on fish with little or no direct human use—may therefore be most 

accurately characterized as a nonuse benefit realized by households for the protection of all fish ( 

including forage fish).

Table 8-4: WTP per Percentage Increase in the Number of Fish (2011$)

Percentage Point Increase 

in Number of Fish

WTP per % Increase in the 

Number of Fish Total WTP per Household

1 $0.72 $0.72

12 $0.72 $1.44

20 $0.72 $14.41

33 $0.72 $23.78

100 $0.72 $72.06

Source: U.S. EPA analysis for this report

 

41 Within the Pawtuxet Watershed study area (the original study location), each percentage point increase in is equivalent to 

12,250 individual fish migrating upstream.

42 EPA converted the implicit price from 2008$ to 2011$ using the consumer price index.
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8.3.2.2 Estimating Total WTP for Eliminating or Reducing IM&E

The BSPV study was developed as a case study for a watershed-level policy in Rhode Island. While it 

provides parameterized benefit functions that require the fewest assumptions to implement for 

extrapolation to the 316(b) case, estimates are more likely to be representative of nonuse values held by 

individuals residing in the Northeast United States. EPA expects that it would provide less accurate 

estimates of nonuse values for residents of other U.S. regions outside the Northeast. EPA was unable to 

identify existing valuation studies conducted in other regions that would provide benefit functions of 

comparable quality and applicability to the 316(b) regulatory context. Although other studies in the 

literature value changes in aquatic resources, they do not provide a good match to the 316(b) policy 

scenario in terms of the expected resource change. The large number of assumptions required for 

developing benefit transfer based on these studies would result in greater uncertainties compared to 

application of the BSPV study. Therefore, EPA restricted the benefit transfer to the North Atlantic and 

Mid-Atlantic EPA 316(b) study regions.

The structure of the transfer study dictates that WTP should be evaluated based on the single species that 

would experience the greatest relative increase in abundance from restoration and that WTP estimates 

from multiple species impacted by IM&E should not be treated as strictly additive. This is related to the 

issue of independent valuation and summation. Species likely act as substitutes in people’s utility. That is, 

if one species population has increased, WTP to increase a second species may be lower if the species are 

viewed as substitutes. If one values a set of species independently through separate application of the 

valuation function, then the individual species estimates do not account for substitution among the species 

in people’s preferences and their summation could lead to misleading results. Johnston et al. (2002a) 

discusses this issue in the context of environmental management and states that “If interactions among 

multiple elements of environmental management programs exist, the use of survey methods such as 

contingent valuation to value single dimensions of these programs in isolation (i.e., relative to the same 

‘initial state of the world’) may provide misleading results” (p. 4-1). 

To match the original valuation scenario to the 316(b) policy scenario, EPA selected the single species in 

the Northeast United States that is most impacted among those species with sufficient stock information 

to conduct the analysis. The selected species is most likely to be a commercially or recreationally 

harvested species because of the availability of stock information. However, as discussed in the previous 

section, EPA is able to focus on nonuse values by using migrants attribute for the benefit transfer. The 

total baseline IM&E in the North-Atlantic and Mid-Atlantic regions were evaluated together to represent 

the Northeast United States. for consistency with the available stock assessments, which include waters 

from Maine to North Carolina. EPA selected winter flounder43 as the species for the benefit transfer after 

considering multiple criteria:

 Stock Assessment Data – EPA defines biomass at maximum sustainable yield (BMSY) as the 

baseline when estimating the percentage increase in fish abundance under the 316(b) regulatory 

options. An estimate of BMSY must be available from a recent stock assessment. BMSY was 

available for winter flounder from a recent stock assessment.

 Current Stock Size – Current biomass of the stock must be less than BMSY; otherwise, a percent 

improvement is not calculable. For example, striped bass and croaker stocks exceed BMSY and 

were removed based on this criterion. The current biomass of winter flounder is less than BMSY.

 

43 Winter flounder are harvested commercially; however fish of commercial species may be forage during early life-stages and 

have nonuse values.
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 Magnitude of IM&E – EPA selected the species with the highest relative magnitude of baseline 

IM&E on a percentage basis when compared to total age-one fish in the stock and BMSY. Baseline 

IM&E for winter flounder (6.2 million) is high when compared total age-one fish in the winter 

flounder stock and BMSY.

44 Various other species, such as butterfish and bluefish, suffer much 

lower baseline IM&E. 

Winter flounder is the only species for which EPA conducts the benefits transfer, due to stock data 

availability and the aforementioned issues related independent valuation, summation, and substitution. 

EPA notes that baseline IM&E of winter flounder represents less than one percent of total baseline 

IM&E. It is difficult to ascertain the upper bound of nonuse benefits if the transfer were able to account 

for multiple species. 

EPA expects that decreasing IM&E will lead to increased fish abundance in affected waterbodies. EPA 

assumed that the total number of fish introduced to local habitats throughout the Northeast under the final 

rule and regulatory options considered would be equivalent to the sum of A1E reductions for the North 

Atlantic and Mid-Atlantic regions. Application of the BSPV model results requires that the increases be 

expressed as a percentage increase over current conditions relative to a maximum number of fish that 

could be supported by the ecosystem. For the benefit transfer, EPA measured IM&E on a normalized 

yardstick based on fishery managed to the maximum sustainable yield. This measure should not be 

interpreted as a population impact. 

To calculate improvements under the final rule and regulatory options considered, EPA compared the 

reduction in A1E lost to IM&E to an estimate of the number of age-1 fish in the winter flounder 

population at BMSY. Available fish stock assessments of winter flounder did not estimate the number of 

eggs or larvae in the population; instead, the youngest fish modeled were of age 1. Additionally, EPA 

used the number of age-1 fish in the population as the basis for comparison in recognition of the fact that 

winter flounder adults migrate seasonally from estuaries to offshore shelf areas. Accordingly, adults are 

less likely to suffer IM&E than young fish. The most recent stock assessment for the Southern New 

England winter flounder conducted by the Northeast Fisheries Science Center (NEFSC 2011) indicates 

that spawning stock biomass (SSBMSY

45) at maximum sustainable yield is 43,661 metric tons. EPA 

calculated the approximate number of age-1 fish per metric ton of spawning stock biomass to be 2,624 

using age-class data for 2005 (NEFSC 2008).

46 EPA multiplied the current SSBMSY of 43,661 metric tons 

by 2,624 to generate an estimate a maximum of 114.6 million age-one fish at maximum sustainable 

yield.47

 

44 EPA used the estimated number of age-one fish in the Southern New England winter flounder stock from Terceiro (2008). 

The most recent stock assessment, released in 2011 (NEFSC 2011), did not provide an estimate of the number of age-one 

fish. 

45 SSBMSY is the standard measure of biomass used by fisheries biologists to set fishing quotas. It includes only fish capable of 

reproduction: for winter flounder, this includes fish age 3 or greater. Accordingly, winter flounder SSBMSY will always be 

lower than BMSY because it excludes fish younger than age 3.

46 This is based on 8.8 million age-one fish for 3,368 metric tons of spawning stock biomass.

47 EPA analysis used data for the Southeast New England winter flounder stock. The Gulf of Maine (GOM) winter flounder 

stock is also within the North Atlantic region, however, estimates of BMSY for the GOM stock are highly variable and a 

consensus estimate is not provided by NMFC. The effect on estimated benefits is relatively minor because the range of BMSY

indicates that the stock would be relatively small (around 10 percent) compared to the Southern New England stock at 

maximum sustainable yield.
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EPA’s calculation of nonuse values from eliminating or reducing IM&E for each regulatory option 

involved the following steps: 

1. Calculate the percent increase of winter flounder relative to total age-1 winter flounder at 

maximum sustainable yield in the Northeast U.S. (the North Atlantic and Mid-Atlantic regions 

combined) by comparing A1E reductions under each regulatory option relative to a baseline of 

114.6 million fish.

2. Multiply the percentage point change by the household WTP of $0.72 per percentage point 

improvement (Table 8-4) to calculate the WTP per household per year for the relative increase in 

winter flounder resulting from the regulatory option.

3. Calculate annual regional WTP for each regulatory option by multiplying WTP per household per 

year by the total number of households within the North Atlantic and Mid-Atlantic regions, 

respectively.

The results from implementing these steps for the final rule and the other options considered are described 

in Section 8.4. Discussion of geographic scale and other uncertainties are provided in Section 8.6. 

8.4 Benefit Transfer Results for the Final Rule and Options Considered

Table 8-5 summarizes EPA’s estimates of WTP for increased fish numbers resulting from the 316(b) final 

rule and options considered in the North Atlantic and Mid-Atlantic regions. EPA estimated that 

elimination of all baseline IM&E would increase the number of winter flounder in the Northeast United 

States by more than 6.2 million fish. This is equivalent to a 5.4 percentage point increase relative to a 

maximum of 114.6 million fish (i.e., 6.2 million divided by 114.6 million). Multiplying the 5.4 percent 

increase by a value of $0.72 per percentage point increase (as presented in Table 8-4) yields a household 

WTP of $3.92 per year. Applying the household WTP values to the number of households in each region 

results in annualized WTP values of $20.2 million and $78.9 million for the North Atlantic and MidAtlantic regions, respectively, using a discount rate of 3 percent. Annualized WTP values are $19.8

million for the North Atlantic and $77.2 million for the Mid-Atlantic using a discount rate of 7 percent.

These numbers represent the nonuse value of eliminating all baseline losses of IM&E based on the benefit 

transfer using the BSPV study. These are thus the maximum possible nonuse values based on this benefits 

transfer covering these two regions.

EPA estimated that the final rule will increase winter flounder numbers by 0.07 percent in the North 

Atlantic and Mid-Atlantic waters. Applying per household WTP to this percent increase in the number of 

winter flounder ($0.05) and to the number of households in each region yields the total WTP for 

improvements in winter flounder abundance. The estimated annualized WTP for the final rule in the 

North Atlantic region will be about $0.2 million using both 3 percent and 7 percent discount rates. For the 

Mid-Atlantic, annualized WTP will be $0.8 million using a 3 percent discount rate and $0.7 million using 

a 7 percent discount rate. Table 8-5 also presents household WTP and annualized WTP for Proposal 

Option 4 and Proposal Option 2.
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Table 8-5: Nonuse Value of Eliminating or Reducing Baseline IM&E for the Final 

Rule and Options Considered for Regulated Facilities in the North Atlantic and 

Mid-Atlantic Regions

Step Proposal 

Option 4

Final 

Rule

Proposal 

Option 2 Baseline

Reduction in Northeast IM&E (millions of A1E) 0.03 0.08 4.78 6.23

Percentage increase in age-1 fish in Northeast waters 

relative to age-1 stock at MSY 0.02% 0.07% 4.18% 5.44%

Household WTP per Household (2011$) $0.02 $0.05 $3.01 $3.92

North Atlantica

Annual WTP (millions of 2011$) $0.09 $0.28 $16.35 $21.29

Annualized WTP (3% discount rate; millions of 

2011$) $0.06 $0.21 $10.43 $20.21

Annualized WTP (7% discount rate; millions of 

2011$) $0.05 $0.17 $7.61 $19.77

Mid-Atlanticb

Annual WTP (millions of 2011$) $0.34 $1.09 $63.80 $83.10

Annualized WTP (3% discount rate; millions of 

2011$) $0.25 $0.81 $40.70 $78.89

Annualized WTP (7% discount rate; millions of 

2011$) $0.20 $0.65 $29.69 $77.17

Total Northeast (North Atlantic plus Mid-Atlantic)

Annual WTP (millions of 2011$) $0.42 $1.37 $80.14 $104.39

Annualized WTP (3% discount rate; millions of 

2011$) $0.31 $1.01 $51.13 $99.10

Annualized WTP (7% discount rate; millions of 

2011$) $0.25 $0.82 $37.30 $96.95

a Based on 5.41 million households.

b Based on 21.11 million households.

Source: U.S. EPA analysis for this report

8.5 Habitat-Based Methodology for Estimating Nonuse Values for Fish 

Production Lost to IM&E

EPA also developed a habitat-based method for estimating nonuse values for fish lost to IM&E for the 

proposed rule (USEPA 2011b).

48 The purpose of the method was to estimate the value of fish losses due 

to IM&E by approximating the area of habitat required to produce and support the number of organisms 

lost to IM&E. Provision of fish habitat and nursery for aquatic species is one of the ecosystem services 

provided by wetlands and submerged aquatic vegetation (SAV). Thus, WTP for fish production services 

associated with wetlands and SAV can provide an indirect basis for estimating the nonuse values of 

increased number of fish. These values may be transferred from available wetlands and SAV valuation 

studies.49 These studies found that survey respondents were aware of the fish production services 

provided by eelgrass (submerged aquatic vegetation, SAV) and wetlands; individuals expressed support 

 

48 EPAfocused on nonuse value of fish production services because use values were estimated using other valuation methods 

described in Chapter 5 through 7.The nonuse values are estimated as the total WTP for fish production services by nonusers 

of these resources.

49 Refer to Chapter 9 of the Environmental and Economic Benefits Analysis (EEBA) for the proposed rule for the list of 

valuation studies used in EPA’s analysis (USEPA 2011b). 
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for programs that include increasing SAV and wetland areas with the expressed goal of restoring depleted 

fish and shellfish populations (Johnston et al. 2002b; Mazzotta 1996; Opaluch et al. 1995; 1998). EPA’s 

habitat-based approach involved estimating the area of habitat required to replace fish and shellfish lost to 

IM&E and calculating public WTP for the estimated habitat area. When combined, these data yield an 

estimate of household values for an increase in fish and shellfish abundance which in turn provides an 

indirect estimate of the benefits of reducing or eliminating IM&E.

The habitat-based benefit transfer approach for the proposed rule involved four general steps:

1. Estimate the area of habitat necessary to produce and support the number of organisms lost to 

IM&E.

2. Develop per acre WTP values for fish production services that support fish species affected by 

IM&E (i.e., SAV and wetlands).

3. Estimate the total nonuse value of baseline IM&E by multiplying WTP values for fish and 

shellfish services by the estimated area of habitat required to offset baseline IM&E.

4. Estimate the nonuse benefits of reduced IM&E by multiplying WTP values for fish and shellfish 

services by the area of habitat required to offset IM&E reduced by regulatory options.

The WTP values used for fish and shellfish habitat services were based on an in-depth search of the 

economic literature to identify valuation studies that estimate WTP for aquatic habitat services using 

methods which are inclusive of nonuse values (e.g., contingent values, conjoint analysis). EPA used 

additional information to isolate the proportion of WTP associated with fish habitat services from other 

services such as bird habitat and mosquito control. The habitat-based benefit transfer method estimates 

only those values related to IM&E of organisms, not any indirect ecosystem effects of IM&E, or chemical 

effects of CWIS (Chapter 2). 

For the proposed rule, EPA estimated national WTP to compensate for baseline IM&E losses under the 

habitat-based approach to be about $3.6 billion and $3.7 billion using 3 percent and 7 percent discount 

rates, respectively. For Proposal Option 1, EPA estimated total national WTP of $513.3 million using a 3 

percent discount rate and $477.2 million using a 7 percent discount rate. National WTP for Proposal 

Options 4 and 2 ranged from $509.9 million to $2.1 billion using a 3 percent discount rate and $474.0 

million to $1.5 billion using a 7 percent discount rate. Refer to Chapter 9 of the EEBA for the proposed 

rule (USEPA 2011b) for additional detail on the habitat-based benefit transfer method, results for the 

proposed regulatory options, and limitations and uncertainties associated with the approach. 

EPA did not consider the habitat-based approach appropriate for primary analysis of nonuse benefits and 

thus did not include habitat-based estimates in the total benefits of eliminating or reducing IM&E under 

the proposed regulatory options. Likewise, EPA does not re-estimate the habitat-based approach for the 

final rule or include benefits based on the habitat-based approach within the comparison of benefits and 

costs for the final rule. Since the proposed rule, EPA has revised its estimates of baseline IM&E, IM&E 

reductions under regulatory options, and revised the compliance schedule. However, if EPA were to reestimate the habitat-based analysis for the final rule, EPA expects that the results for the final rule would 

generally be similar to results described above for Proposal Option 1.50 The habitat-based approach helps 

to illustrate the potential magnitude of nonuse values from the final rule, and provides additional support 

 

50 As described in the Chapter 1, the final rule is Option 1 from EPA’s analysis for the proposed rule (U.S. EPA 2011) with 

some modifications. Proposal Options 4 and Proposal Option 2 correspond to Options 4 and 2 from EPA’s analysis for the 

proposed rule (U.S. EPA 2011) with some modifications. 
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for the benefit transfer results presented in Section 8.4, and the results of EPA’s SP survey described in 

Chapter 10. 

8.6 Limitations and Uncertainties

By designing a survey instrument directly for the context at hand, EPA could use the stated preference 

survey results without the need to transfer benefits. However, EPA did not complete its stated preference 

study in time to have it fully peer reviewed for this analysis. Thus, EPA is relying on this benefits 

transfer to estimate, in part, nonuse values. 

A number of issues are common to all benefit transfers. The technique involves adapting research found 

in the available literature and conducted for one purpose, to another purpose, to address the policy 

questions at hand. Some of the limitations and uncertainties associated with implementing a benefit 

transfer using Johnston et al.(2012) are addressed below. Broader limitations and uncertainties associated 

with benefit transfer in general are discussed by Johnston and Rosenberger (2010).

8.6.1 Scale of Fishery Improvements

Given the scope of the survey upon which benefit transfer results are based (Johnston et al. 2012; Zhao et 

al. 2013), the most reliable results apply within the range of the attributes presented to the respondents in 

the choice experiment. As shown in Figure 8-2, the percentage point increases in the number of fish for 

all analyzed 316(b) regulatory options are less than 33 percent, which is within the range of the fish 

migrants attribute changes presented in the survey instrument. ). 

8.6.2 Scale and Characteristics of the Affected Population

The results of the Rhode Island study (Johnston et al. 2012; Zhao et al. 2013) reflect WTP for 

improvements in nearby watersheds. WTP may decline as policy areas become more distant. The most 

reliable application of these results would be to calculate WTP for IM&E reductions in a single local 

watershed. However, the final rule will reduce IM&E and improve fish populations in multiple 

watersheds within some states. Although it is not unreasonable that households would hold values for 

multiple watersheds, this is a departure from the transfer study context. As noted, EPA assumed that 

households have consistent values for improvements in multiple watersheds within their state or region.

Moreover, for transfers based on absolute fish numbers, EPA assumed that the per household WTP for 

changes in the numbers of fish for all watersheds located within the state, including watersheds that are 

shared by multiple States, would be at least equal to the WTP value for improvements in a single 

watershed. Hence, EPA estimated per household WTP based on the average watershed improvement 

within the state. The transfer study context was a single watershed in Rhode Island (Johnston et al. 2012; 

Zhao et al. 2013). Using the benefit transfer approaches outlined here, the benefit function is applied to all 

states in the North Atlantic and Mid-Atlantic regions without adjustment, based on mean household 

income or local watershed characteristics. Some heterogeneity in WTP would be expected across states 

and regions due to diversity in species and public values. EPA did not extend the benefit transfer beyond 

the North Atlantic and Mid-Atlantic regions because of the potential for substantial differences in 

preferences, demographics, and species characteristics in other regions compared to the original context 

of the transfer study. This likely results in the underestimation of nonuse benefits.
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8.6.3 Fish Population Size, Type and Improvement from the Elimination of IM&E

To conduct the benefit transfer, EPA assumed that the gain in fish abundance would be equal to IM&E 

reductions under the final rule and options considered. These gains are not intended to represent changes 

in fish population, but are merely normalized as percentages of age-one fish at maximum sustainable 

yield.

While both the transfer study and policy contexts involve forage fish, the specific species compositions 

involved differ between transfer study (Johnston et al. 2012; Zhao et al. 2013) and the 316(b) context. For 

example, most of the fish affected within the transfer study are migratory fish such as river herring, while 

such species may account for a smaller proportion of those affected by CWIS subject to the final rule. If 

WTP is sensitive to the specific type of forage fish involved, this could be a potential source of 

generalization error.
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9 Assessment of Social Cost of Carbon

Benefits of regulatory actions include potential effects from estimated changes in greenhouse gas (GHG) 

emissions associated with energy requirements of compliance technology and installation downtime 

under the final rule and other options considered. Decreases in GHG emissions, measured as CO2

equivalents, may reduce the burden of global climate change to society in future years, and thus may 

create a positive benefit to society, while increases in GHG emissions can impose a negative benefit, or 

cost, to society. EPA refers to the costs from increased emissions as the social cost of carbon (SCC). EPA 

estimated the benefit, or cost, to society from changes in GHG emissions expected to result from the final 

rule and other options considered. EPA based this estimate on the SCC concept, which reflects the cost 

(or benefit) to society associated with an incremental change in CO2-equivalent emissions in a given year. 

This chapter presents EPA’s analysis for existing units at Electric Generators and Manufacturers (Section 

9.1). See Chapter 12 for EPA’s analysis for new units.

EPA estimated the change in CO2 emissions resulting from the energy penalty associated with closedcycle recirculating system technology, auxiliary energy requirements for operating compliance 

technology, and technology installation downtime for Electric Generators. Energy penalty effects result 

from reduced energy conversion efficiency of the power generating system. EPA estimated the change in 

CO2 emissions resulting only from the energy penalty and increase in the auxiliary energy requirement for 

Manufacturers. EPA assumed no change in CO2 emissions for compliance technology installation 

downtime at Manufacturers because the short-term replacement of energy by electric power generating 

facilities that would otherwise be produced at Manufacturers could either increase or decrease emissions.

Refer to Appendix I of the Economic Analysis (EA) for the final rule (USEPA 2014a) for additional 

detail on compliance technology effects that impose costs via impact on revenue or energy requirements.

9.1 Analysis Approach and Data Inputs

9.1.1 Electric Generators

As discussed in Chapter 3 and Appendix I of the EA, EPA expects Electric Generators to temporarily 

suspend electricity generation activities to install compliance technology, and to incur annual generation 

losses due to energy penalty and auxiliary energy requirements. In the case of downtime, other electric 

power facilities will have to compensate for these generation losses by generating more electricity to meet 

electricity demand. This may require an increased or decreased energy input, which may lead to increased 

or decreased CO2 emissions, depending on the energy input and generation profile of the generating units 

used to compensate for the generation losses. In the case of the energy penalty and auxiliary energy 

requirements, either the affected Electric Generators or other electric power facilities or both will have to 

compensate for these generation losses by generating more electricity to meet electricity demand. As 

with downtime, this may require an increased or decreased energy input, which may lead to increased or 

decreased CO2 emissions..

EPA estimated the potential increase in CO2 emissions, based on results from the electricity market 

analysis using the Integrated Planning Model (IPM®). For the existing unit provision of the final rule, 

EPA used results for the Electricity Market Analysis - Final Rule option from the IPM analysis (for 

details on that analysis, see Chapter 6 of the EA for the final rule) to estimate changes in CO2 emissions. 

As discussed in Chapter 6 of the EA for the final rule, the IPM analysis accounted only partially for the 
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new unit provision of the final rule. Consequently, to avoid underestimating the effect on CO2 emissions, 

EPA assumed that the IPM-based CO2 emissions effects of the final rule reflect the existing unit provision 

only, and assessed the impact on CO2 emissions from the new unit provision of the final rule in a separate 

analysis discussed in Chapter 12. To the extent that changes in CO2 emissions estimated in IPM also 

reflect the impact of the new unit provision of the final rule, the estimated reductions in CO2 effects and 

associated SCC benefit, which are assigned to the existing unit provision of the final rule, may be undersestimated.

As described in Chapter 6 of the EA for the final rule, EPA did not conduct a separate electricity market 

analysis to assess the regulatory impacts of Proposal Option 2 as analyzed in support of the final rule. 

Instead, the Agency used results from the IPM analysis of Proposal Option 2 (referred to as Market Model 

Analysis Option 2 in the context of IPM analysis) conducted in support of the proposed rule. As described 

in the Chapter 6 of the Economic and Benefits Analysis (EBA) for the proposed rule, that IPM analysis 

used an older IPM platform – IPM V3.02_EISA. 51 For details on that analysis, see the EBA for the 

proposed rule.

EPA calculated the difference in CO2 emissions reported in the baseline (i.e., pre-policy) case and policy 

case of the IPM analysis. Because EPA did not analyze Proposal Option 4 in IPM in support of either the 

proposed rule or the final rule, EPA could not estimate CO2 emissions specifically for that option. 

However, Proposal Option 4 is similar to the existing unit provision of the final rule in that both set 

performance standards based on IM technology. Moreover, compliance costs for Proposal Option 4 are 

slightly lower than those of the existing unit provision of the final rule (see Chapter 3 of the EA for the 

final rule). Therefore, the change in CO2 emissions for Proposal Option 4 is likely to be no larger than the 

emission changes calculated for the Electricity Market Analysis – Final Rule.

To estimate the change in CO2 emissions for the 46-year analysis period of 2014 through 2059, EPA first 

calculated the change in CO2 emissions from baseline to policy option, as estimated in the IPM electricity 

market analyses. As described in Chapter 6 of the EA for the final rule, the IPM V4.10_MATS platform 

embeds three run years – 2015, 2020, and 2030. These run years represent multiple years and specific 

technology-installation years as shown in Table 9-1. 

Table 9-1: IPM V4.10_MATS Run-Year Specification – Final Rulea,b

Run Year Represented Years Regulatory Effects Captured – Final Rule

2015 2014-2016 Operations and financial changes in anticipation of future compliancea

2020 2017-2024 IM technology installation

2030 2025-2034 Steady-state post-compliance period; captures potential permanent 

changes.

a As discussed in Appendix P of the EA for the final rule, IPM reflects an assumption of perfect foresight.

b V4.10_MATS is the IPM version that EPA used to analyze the Final Mercury and Air Toxics Standards (MATS).

 

51 Although Proposal Option 2 analyzed in support of the final rule set impingement mortality and entrainment performance 

standards similar to those analyzed under Market Model Analysis Option 2, the expected compliance responses differ in 

terms of technologies that some facilities will install and the associated costs. In addition, administrative requirements 

considered for Proposal Option 2 differ from those analyzed in IPM for the proposed rule. Also, the current universe of 

regulated facilities is slightly smaller than the universe of regulated facilities analyzed for the proposed rule. Finally, 

compared to Market Model Analysis Option 2, Proposal Option 2 provides facilities with more flexibility and a longer 

window to comply with the regulatory requirements. EPA judges that despite these differences, the electricity market 

analysis results from the proposed rule are sufficient to assess the change in CO2 emissions under Proposal Option 2. 
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As described in Chapter 6 of the economic and benefits analysis for the proposed rule (USEPA 2011a), 

EPA specified four run years for the IPM analysis in accordance with the compliance-technology 

installation schedule considered at that time: 2015, 2020, 2025, and 2028. These run years represent 

multiple years and specific technology-installation years as follows: 

Table 9-2: IPM V3.02_EISA Run-Year Specification – Proposal Option 2a

Run Year Represented Years Regulatory Effects Captured – Proposed Rule

2015 2013-2017 IM technology installation

2020 2018-2022 Entrainment control technology installation – non-nuclear facilities

2025 2023-2027 Entrainment control technology installation – nuclear facilities

2028 2028 Steady-state post-compliance period; captures potential permanent 

changes.

a V3.02_EISA is the IPM version that EPA used to model electric generation for the proposed Transport Rule.

EPA assumed that any observed changes in CO2 emissions between the baseline case and the policy case 

are attributable to the analyzed 316(b) regulatory requirements. For the final rule, EPA assumed that the 

difference in CO2 emissions reported for 2015 is the same as the difference in the other three years 

represented by 2015, i.e., 2014 through 2016. EPA applied the same methodology to the remaining two 

run years, thereby generating the change in CO2 emissions for the 21-year period of 2014 through 2034.52 

EPA used the same methodology for Proposal Option 2, generating a time profile of changes in CO2

emissions for the 16-year period of 2013 through 2028.

In reviewing the estimated changes in CO2 emissions from the IPM runs, EPA observed that for some 

regulatory options and some analysis years, CO2 emissions decline even though EPA would expect the 

options to have effects of replacing and/or providing additional electricity generation, as described above. 

On closer inspection, in these cases, the generation mix between the baseline and the regulatory option 

case changes in such a way that a CO2 emissions decrease is plausible – e.g., increased generation from 

nuclear facilities (which are non-CO2 emitting) and reduced generation from coal or other fossil fuel 

facilities.

The run-year configuration embedded in the IPM V4.10_MATS platform used for the analysis of the final 

rule was set independent of the 316(b) compliance and technology installation schedule. Unlike the case 

with the IPM analysis done in support of the proposed rule, EPA did not change this configuration to 

better reflect the final rule requirements. EPA expects all regulated facilities to install compliance 

technologies during the 5-year period of 2018 through 2022, which is within the range of years 

represented by the 2020 IPM run year. To align year-specific changes in CO2 emissions estimated for the 

Electricity Market Analysis - Final Rule as part of the IPM analysis with technology-installation schedule 

of the final rule and consequently, Proposal Option 4, EPA made the following assumptions:

 As discussed in Chapter 6 of the EA for the final rule, the three years (2014 through 2016) 

represented by the 2015 IPM run year, have the same characteristics as the 2015 year. These three 

years immediately precede the technology-installation period assumed in the IPM analysis. EPA 

assumed that the year-specific changes in CO2 emissions estimated for Electricity Market 

 

52 Even though no compliance technology is installed during the 3-year period represented by the 2015 IPM run year, any 

changes in the market behavior resulting in changes in CO2 emissions are due to anticipated compliance with the 316(b) 

requirements. As discussed in Appendix P of the Final Rule EA report, IPM reflects an assumption of perfect foresight,

which means that market players have complete knowledge of the nature and timing of the constraints, including those 

created by regulatory requirements that will be imposed in future years during the analysis period, and make decisions based 

on this knowledge.
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May 2014 9-4

Analysis - Final Rule for 2014 through 2016 are the same as those that will occur during 2015 

through 2017, i.e., the 3-year period immediately preceding the technology-installation period 

anticipated under the final rule.

 Similar to the 2015 IPM run year , the eight years (2017 through 2024) that are represented by the 

2020 IPM run year have the same characteristics as the 2020 run year. As a result, in the IPM 

analysis, downtime was applied as a single value for each of the eight years. EPA assumed that 

the resulting total difference in CO2 emissions for this eight-year period (CO2 emissions reported 

for the 2020 IPM run year times eight – the number of years that the 2020 run year represents) is 

the same as the total difference in CO2 emissions that would have resulted if all facilities were to 

install IM technologies during the five-year period, 2018 through 2022, when compliance 

technology will be installed under the final rule. EPA converted the eight-year total of CO2

emissions change to a yearly value for each of the five years, 2018 and 2022, by simply dividing 

the total emissions change over the eight years by five. 

 Finally, using the same approach as that used for the 2015 IPM run year, EPA assumed that the 

year-specific changes in CO2 emissions estimated for the 2030 IPM run year and consequently, 

for each of the 10 years it represents – 2025 through 2034 – are the same as those that would 

occur during the 10-year period of 2023 through 2032. In other words, the Agency “moved” the 

emissions changes in the 10-year IPM-analysis period of 2025 through 2034 to the 10-year period 

of 2023-2032, the years following expected completion of technology installation under the final 

rule. The change in CO2 emissions reported for the final rule in 2030 is negative (i.e., CO2

emissions in that year decline from the baseline to the policy case). To avoid understating the 

potential effect of regulatory requirements on CO2 emissions, EPA applied this decrease only to

the 10 years represented by 2030 and assumed zero change in CO2 emissions during the 

remaining years in the social-cost analysis period, i.e., 2033 through 2059.

The technology-installation schedules EPA assumed for the IPM analysis in support of the proposed rule 

differ from those assumed for Proposal Option 2 analyzed in support of the final rule. As shown in Table 

9-2, for the proposed rule, EPA assumed that facilities would install IM technologies during a 5-year 

window of 2013 through 2017. Further, EPA assumed that non-nuclear and nuclear facilities would install 

entrainment control technologies during 2018 through 2022, and 2023 through 2027, respectively. As 

discussed earlier in this chapter, for the existing unit provision of the final rule, these technologyinstallation periods are 2018 to 2022, 2021 to 2025, and 2026 to 2030, respectively. To align year-specific 

changes in CO2 emissions estimated for Market Model Analysis Option 2 with technology-installation 

schedules EPA assumed for Proposal Option 2 analyzed in support of the final rule, EPA made the 

following assumptions:

 Proposal Option 2 and Market Model Analysis Option 2 require both IM and entrainment control 

technologies. To capture differences in energy requirements to install and operate these two sets 

of technologies, EPA aligned year-specific changes in CO2 emissions estimated for Market 

Model Analysis Options 2 with technology-specific installation schedules currently assumed for 

Proposal Option 2. To capture changes in emissions associated with IM technology, EPA 

assumed that the year-specific changes in CO2 emissions estimated for Market Model Analysis 

Option 2 during 2013 through 2017 are the same as those that EPA would have estimated for 

2018 through 2022. For entrainment-control technology installation at non-nuclear facilities, the 

Agency assumed that the changes in emissions it estimated for 2018 through 2022 are the same as 

those it would have estimated for 2021 through 2025. For installation of entrainment control 
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May 2014 9-5

technology at non-nuclear facilities, the Agency assumed that the changes in emissions estimated 

for 2023 through 2027 are the same as those that EPA would have estimated for 2026 through 

2030. Unlike the case of Electricity Market Analysis - Final Rule, under Market Model Analysis 

Option 2, the change in CO2 emissions reported for the steady-state year (2028) is positive (i.e., 

CO2 emissions in that year increase from the baseline to the post-policy case). To avoid 

understating the potential effect of regulatory requirements on CO2 emissions, EPA applied this 

increase in emissions over the remaining years in the social-cost analysis period, i.e., 2031 

through 2059.

To estimate the benefits of changes in CO2 emissions due to the existing unit provision of the final rule 

and Proposal Option 2, EPA used SCC values from Technical Support Document: Technical Update of 

the Social Cost of Carbon for Regulatory Impact Analysis-Under Executive Order 12866 developed by 

the United States Government Interagency Working Group on Social Cost of Carbon, 2013 (Interagency 

Working Group 2013). The Working Group estimated annual unit SCC values ($ per metric ton) for 2010 

through 2050 (Table 9-3). Three of these four sets are based on the average unit SCC values across 

models, and socio-economic and emissions scenarios, for each of three SCC discount rates: 5.0, 3.0, and 

2.5 percent. The Work Group developed a fourth set of unit SCC values as the 95th percentile value of the 

3 percent discount rate-based SCC values; these values represent the potential for higher-than-expected 

impacts from temperature change farther out in the tails of the SCC distribution.53

Table 9-3: Unit Social Cost of Carbon, 2010-2050 ($ per metric ton of CO2; 

2011$)a

Year

Discount Rates

2.5% 3.0% 5.0%

Average SCC 

Value

Average SCC 

Value High SCC Value Average SCC Value

2010 $55.42 $34.15 $94.98 $11.74

2015 $0.83 $39.48 $116.32 $11.74

2020 $68.30 $45.89 $136.59 $12.81

2025 $73.63 $50.16 $152.60 $14.94

2030 $80.04 $55.49 $169.68 $17.07

2035 $85.37 $59.76 $186.75 $20.28

2040 $91.77 $65.10 $203.82 $22.41

2045 $98.18 $70.43 $219.83 $25.61

2050 $103.51 $75.77 $234.77 $27.75

a

SCC values were calculated for 2010 through 2050 and vary by year; this table reports SCC values only for 

every fifth year. 

Sources: Interagency Working Group, 2013; updated to 2011$ for this analysis using the GDP 

deflator.

These unit SCC values represent the present value of the future stream of costs to society from a change 

in GHG emissions in a given year, recognizing that the impact of changes in CO2 in the atmosphere 

occurs not only in the year in which the emissions are generated, but extends over a substantial period 

into the future.54 In the 2013 Technical Support Document (TSD) (Interagency Working Group 2013), 

 

53 For more information on the assumptions and methodology used to develop these SCC values see the 2013 

TSD(Interagency Working Group 2013) available online at: 

http://www.whitehouse.gov/sites/default/files/omb/inforeg/social_cost_of_carbon_for_ria_2013_update.pdf. 

54 The unit SCC values reported in the 2013 TSD and used in the current analysis are global SCC values. The Interagency 

Working Group determined that the use of global measures of benefits for greenhouse gas reductions is preferable to 
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May 2014 9-6

these values are in 2007 dollars; EPA restated these values in 2011 dollars using the GDP deflator series. 

The SCC values published by the Working Group increase in real economic terms from year to year, 

reflecting the increasing marginal cost to society of additional GHG emissions and increasing cumulative 

burden of climate change over time. Because the Working Group published unit SCC values only through 

2050, EPA extended the unit SCC values from 2050 to 2059, assuming that the annual real rate of change

in the future SCC values remained the same as in the period 2049 to 2050. 

EPA calculated the benefits of the year-to-year changes in CO2 emissions as a product of the year-by-year 

unit SCC values and the estimated year-by-year changes in CO2 emissions. The Agency then discounted 

the resulting year-by-year benefit values, summed the discounted values, and annualized them using 

discounts rate of 3 percent and 7 percent.55

9.1.2 Manufacturers

To estimate the change in CO2 emissions due to compliance for Manufacturers, EPA estimated the 

replacement energy required during downtime and as a result of the energy penalty and auxiliary energy 

requirements. For downtime, electricity otherwise produced by Manufacturers will instead be produced 

by the electric power industry. Therefore, electricity generation and associated CO2 emissions of 

Manufacturers decrease during downtime while generation and emissions from the electric power 

industry increase. Depending upon the carbon intensity of generation by the electric power industry 

relative to that of generation by Manufacturers, CO2 emissions may increase or decrease during 

downtime. Given this uncertainty, EPA assumed no net change in CO2 emissions during downtime. If the 

carbon intensity of generation for the electric power industry is greater than that for Manufacturers’, this 

assumption will underestimate the increase in CO2 emissions, and vice versa. 

For a given quantity of energy input56, energy penalty and auxiliary energy requirements reduce the 

amount of electricity that is available to the facility to meet baseline consumption needs and/or for sale.57

EPA assumed that Manufacturers will not be able to increase energy input to offset this loss, with the net 

effect that a facility will need to purchase more electricity from other electric power generators or will 

deliver less electricity for external consumption. EPA assumed that these electricity losses, whether due to 

energy penalty or to auxiliary energy requirements, will be replaced by the electric power industry. This 

means that the facility’s own CO2 emissions will be unchanged but that CO2 emissions may increase as 

other electric power generators make up this loss. EPA calculated the increase in CO2 emissions from the 

generation of replacement electricity by the power industry based on the average CO2 emissions intensity 

for United States. 

EPA first calculated the replacement electricity required to offset the electricity loss from energy penalty 

and auxiliary energy requirements, assuming Manufacturers would incur the these effects from 2010 

 

domestic measures. Refer to the 2013 TSD (Interagency Working Group 2013), and the earlier 2010 TSD (Interagency 

Working Group 2010) for additional discussion of global versus domestic measures.

55 This discounting approach diverges from the discount rate concepts used to develop the SCC values. However, the 3 percent

and 7 percent discount rates are appropriate given that the alternative year-by-year SCC values reflect a range of factors 

including not only discount rates, but also different impact/socio-economic evolution scenarios, modeling 

approach/framework, and damage functions.

56 The energy that is consumed to generate electricity.

57 See Appendix I of the EA for detailed discussion of how energy penalty and auxiliary energy requirements affect electric 

power generation and the supply of electricity otherwise available for consumption at facilities installing compliance 

technology.
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May 2014 9-7

through 2059 (see Appendix I of the EA for the final rule). EPA then calculated the CO2 emissions 

intensity based on projected total electricity generation (USDOE 2013b) and associated CO2 emissions 

(USDOE 2013a) by year. EIA projects these values only to 2040, so EPA assumed no change in carbon 

intensity beyond 2040. EPA multiplied the carbon intensity in each year by the replacement electricity 

required in that year to calculate the CO2 emissions due to the energy penalty of Manufacturers. EPA 

multiplied the estimated CO2 emission values, by year, by the same unit SCC values as those used for 

Electric Generators (Table 9-3).

9.2 Key Findings for Regulatory Options 

9.2.1 Electric Generators

Table 9-3 presents the total reduction in CO2 emissions and associated values of SCC in 2013 for Electric 

Generators, by option and discount rate. The SCC values reported for Proposal Option 4 are the same as 

those reported for existing unit provision of the final rule because EPA assumed that CO2 emissions for 

Proposal Option 4 would be the same as those calculated in the IPM analysis for Market Model Analysis 

1, which aligns most closely with the existing unit provision of the final rule. To the extent that Proposal 

Option 4 is less stringent than Market Model Analysis 1 or the existing unit provision of the final rule, the 

SCC values reported for Proposal Option 4 are overstated. 

As reported in Table 9-4, EPA estimates that the existing unit provision of the final rule (and Proposal 

Option 4) will result in a total reduction of 9.6 million tons of CO2 equivalents (tCO2eq). As discussed 

above, EPA assesses that this reduction is likely the result of changes in generation mix that lead to more 

electricity generated by facilities with lower carbon emissions or none at all, such as nuclear facilities, and 

less electricity generated by coal or other fossil fuel facilities. Using the average SCC values calculated at 

a 3 percent discount rate, EPA estimates that this reduction in carbon emissions will result in average 

annual benefits of $12.4 million at the 3 percent discount rate and $13.4 million at the 7 percent discount 

rate. EPA estimates that under Proposal Option 4, total carbon emissions would increase by 1,471.9

million of tCO2eq. Using the average SCC values calculated at a 3 percent discount rate, EPA estimates 

the average annual (negative) benefit associated with this increase in carbon emissions to be -$1,613.6 

million at the 3 percent discount rate and -$1,197.9 million at the 7 percent discount rate.
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Table 9-4: Total Reduction in Carbon Emissions and Associated Benefits Under the Final Rule 

and Other Options Considered – Electric Generators (SCC Values in 2013; 2011$, millions) 

Option

Total Reduction in 

Emissions 

(tCO2eq, millions)

Discount Rate for Calculating SCC Unit Values

2.5% 3.0% 5.0%

Average SCC 

Value

Average SCC 

Value

High SCC 

Value

Average SCC 

Value

3% Discount Rate for Annualizing Benefits

Proposal Option 4a

9.6 $18.1 $12.4 $37.7 $3.8

Final Rule – Existing Unitsb

9.6 $18.1 $12.4 $37.7 $3.8

Proposal Option 2 -1,471.9 -$2,281.0 -$1,613.6 -$4,988.0 -$536.2

7% Discount Rate for Annualizing Benefits

Proposal Option 4a

9.6 $19.6 $13.4 $40.7 $4.1

Final Rule – Existing Unitsb

9.6 $19.6 $13.4 $40.7 $4.1

Proposal Option 2 -1,471.9 -$1,714.4 -$1,197.9 -$3,693.7 -$388.9

a To the extent that EPA used IPM results for Electricity Market Analysis – Final Rule as a proxy for Proposal Option 4, benefits for Proposal 

Option 4 are likely to be over-stated.

b To the extent that the change in CO2 emissions estimated for the existing unit provision of the final rule partially accounts for the change in 

CO2 emissions due to the new unit provision of the final rule, benefits reported for the existing unit provision of the final rule may be 

overstated.

Source: U.S. EPA analysis for this report

9.2.2 Manufacturers

Table 9-5 presents the total reduction in CO2 emissions and associated benefit values for Manufacturers 

by option. Under the final rule and Proposal Option 4, EPA assessed no reduction in CO2 emissions. 

Under Proposal Option 2, EPA calculated an increase of 25.4 million in tCO2eq. Using the average SCC 

values calculated at a 3 percent discount rate, EPA estimates the benefits associated with the estimated 

increase CO2-equivalent emissions to be -$27.8 million at the 3 percent discount rate and $20.3 million at 

the 7 percent discount rate.

Table 9-5: Total Reduction in Carbon Emissions and Associated Benefits Under the Final Rule 

and Other Options Considered – Manufacturers (SCC Values in 2013; $2011, millions) 

Option Total Emissions 

(tCO2eq, millions)

Discount Rate for Calculating SCC Unit Values

2.5% 3.0% 5.0%

Average SCC 

Value

Average SCC 

Value

High SCC 

Value

Average SCC 

Value

3% Discount Rate for Annualizing Benefits

Proposal Option 4a

0.0 $0.0 $0.0 $0.0 $0.0

Final Rule – Existing Units 0.0 $0.0 $0.0 $0.0 $0.0

Proposal Option 2 -25.4 -$39.2 -$27.8 -$85.8 -$9.6

7% Discount Rate for Annualizing Benefits

Proposal Option 4a

0.0 $0.0 $0.0 $0.0 $0.0

Final Rule – Existing Units 0.0 $0.0 $0.0 $0.0 $0.0

Proposal Option 2 -25.4 -$29.1 -$20.3 -$62.7 -$6.7

a To the extent that EPA used IPM results for Market Model Analysis 1 as a proxy for Proposal Option 4, benefits for Proposal Option 4 are 

likely to be over-stated.

Source: U.S. EPA analysis for this report

Table 9-6, Table 9-7, and Table 9-8 present the change in CO2 emissions and associated undiscounted 

benefits for existing units for Electric Generators and Manufacturers by year for Proposal Option 4, the 

final rule, and Proposal Option 2, respectively.
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May 2014 9-9

Table 9-6: Social Cost of Carbon by Year for Electric Generators and Manufacturers –

Proposal Option 4 ($2011, millions)

Year Emissions 

(tCO2eq, millions)

Discount Rate for Calculating SCC Unit Values

2.5% 3.0% 5.0%

Average SCC 

Value

Average SCC 

Value High SCC Value Average SCC Value

2013 0.0 $0.0 $0.0 $0.0 $0.0

2014 0.0 $0.0 $0.0 $0.0 $0.0

2015 0.2 $13.3 $8.6 $25.5 $2.6

2016 0.2 $13.8 $8.9 $26.2 $2.8

2017 0.2 $14.0 $9.1 $27.1 $2.8

2018 0.0 -$2.8 -$1.9 -$5.6 -$0.6

2019 0.0 -$2.9 -$1.9 -$5.7 -$0.6

2020 0.0 -$3.0 -$2.0 -$5.9 -$0.6

2021 0.0 -$3.0 -$2.0 -$6.1 -$0.6

2022 0.0 -$3.1 -$2.0 -$6.2 -$0.6

2023 0.9 $65.5 $44.0 $134.0 $12.7

2024 0.9 $66.5 $45.0 $137.0 $13.7

2025 0.9 $67.5 $46.0 $139.9 $13.7

2026 0.9 $68.5 $47.0 $142.8 $14.7

2027 0.9 $69.5 $47.9 $145.8 $14.7

2028 0.9 $70.4 $48.9 $148.7 $14.7

2029 0.9 $71.4 $49.9 $151.6 $15.7

2030 0.9 $73.4 $50.9 $155.5 $15.7

2031 0.9 $74.3 $50.9 $158.5 $16.6

2032 0.9 $75.3 $51.8 $161.4 $16.6

2033 0.0 $0.0 $0.0 $0.0 $0.0

2034 0.0 $0.0 $0.0 $0.0 $0.0

2035 0.0 $0.0 $0.0 $0.0 $0.0

2036 0.0 $0.0 $0.0 $0.0 $0.0

2037 0.0 $0.0 $0.0 $0.0 $0.0

2038 0.0 $0.0 $0.0 $0.0 $0.0

2039 0.0 $0.0 $0.0 $0.0 $0.0

2040 0.0 $0.0 $0.0 $0.0 $0.0

2041 0.0 $0.0 $0.0 $0.0 $0.0

2042 0.0 $0.0 $0.0 $0.0 $0.0

2043 0.0 $0.0 $0.0 $0.0 $0.0

2044 0.0 $0.0 $0.0 $0.0 $0.0

2045 0.0 $0.0 $0.0 $0.0 $0.0

2046 0.0 $0.0 $0.0 $0.0 $0.0

2047 0.0 $0.0 $0.0 $0.0 $0.0

2048 0.0 $0.0 $0.0 $0.0 $0.0

2049 0.0 $0.0 $0.0 $0.0 $0.0

2050 0.0 $0.0 $0.0 $0.0 $0.0

2051 0.0 $0.0 $0.0 $0.0 $0.0

2052 0.0 $0.0 $0.0 $0.0 $0.0

2053 0.0 $0.0 $0.0 $0.0 $0.0

2054 0.0 $0.0 $0.0 $0.0 $0.0

2055 0.0 $0.0 $0.0 $0.0 $0.0

2056 0.0 $0.0 $0.0 $0.0 $0.0

2057 0.0 $0.0 $0.0 $0.0 $0.0

2058 0.0 $0.0 $0.0 $0.0 $0.0

2059 0.0 $0.0 $0.0 $0.0 $0.0

2060 0.0 $0.0 $0.0 $0.0 $0.0

2061 0.0 $0.0 $0.0 $0.0 $0.0

2062 0.0 $0.0 $0.0 $0.0 $0.0

2063 0.0 $0.0 $0.0 $0.0 $0.0

2064 0.0 $0.0 $0.0 $0.0 $0.0

Present Value 3% - $483.1 $330.3 $1,007.6 $101.7

Annualized, 3% - $18.1 $12.4 $37.7 $3.8

Present Value 7% - $290.4 $198.0 $603.0 $60.8

Annualized 7% - $19.6 $13.4 $40.7 $4.1

Source: U.S. EPA analysis for this report
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May 2014 9-10

Table 9-7: Social Cost of Carbon by Year for Electric Generators and Manufacturers – Final 

Rule-Existing Units ($2011, millions)

Year

Emissions 

(tCO2eq, 

millions)

Discount Rate for Calculating SCC Unit Values

2.5% 3.0% 5.0%

Average SCC 

Value

Average SCC 

Value High SCC Value Average SCC Value

2013 0.0 $0.0 $0.0 $0.0 $0.0

2014 0.0 $0.0 $0.0 $0.0 $0.0

2015 0.2 $13.3 $8.6 $25.5 $2.6

2016 0.2 $13.8 $8.9 $26.2 $2.8

2017 0.2 $14.0 $9.1 $27.1 $2.8

2018 0.0 -$2.8 -$1.9 -$5.6 -$0.6

2019 0.0 -$2.9 -$1.9 -$5.7 -$0.6

2020 0.0 -$3.0 -$2.0 -$5.9 -$0.6

2021 0.0 -$3.0 -$2.0 -$6.1 -$0.6

2022 0.0 -$3.1 -$2.0 -$6.2 -$0.6

2023 0.9 $65.5 $44.0 $134.0 $12.7

2024 0.9 $66.5 $45.0 $137.0 $13.7

2025 0.9 $67.5 $46.0 $139.9 $13.7

2026 0.9 $68.5 $47.0 $142.8 $14.7

2027 0.9 $69.5 $47.9 $145.8 $14.7

2028 0.9 $70.4 $48.9 $148.7 $14.7

2029 0.9 $71.4 $49.9 $151.6 $15.7

2030 0.9 $73.4 $50.9 $155.5 $15.7

2031 0.9 $74.3 $50.9 $158.5 $16.6

2032 0.9 $75.3 $51.8 $161.4 $16.6

2033 0.0 $0.0 $0.0 $0.0 $0.0

2034 0.0 $0.0 $0.0 $0.0 $0.0

2035 0.0 $0.0 $0.0 $0.0 $0.0

2036 0.0 $0.0 $0.0 $0.0 $0.0

2037 0.0 $0.0 $0.0 $0.0 $0.0

2038 0.0 $0.0 $0.0 $0.0 $0.0

2039 0.0 $0.0 $0.0 $0.0 $0.0

2040 0.0 $0.0 $0.0 $0.0 $0.0

2041 0.0 $0.0 $0.0 $0.0 $0.0

2042 0.0 $0.0 $0.0 $0.0 $0.0

2043 0.0 $0.0 $0.0 $0.0 $0.0

2044 0.0 $0.0 $0.0 $0.0 $0.0

2045 0.0 $0.0 $0.0 $0.0 $0.0

2046 0.0 $0.0 $0.0 $0.0 $0.0

2047 0.0 $0.0 $0.0 $0.0 $0.0

2048 0.0 $0.0 $0.0 $0.0 $0.0

2049 0.0 $0.0 $0.0 $0.0 $0.0

2050 0.0 $0.0 $0.0 $0.0 $0.0

2051 0.0 $0.0 $0.0 $0.0 $0.0

2052 0.0 $0.0 $0.0 $0.0 $0.0

2053 0.0 $0.0 $0.0 $0.0 $0.0

2054 0.0 $0.0 $0.0 $0.0 $0.0

2055 0.0 $0.0 $0.0 $0.0 $0.0

2056 0.0 $0.0 $0.0 $0.0 $0.0

2057 0.0 $0.0 $0.0 $0.0 $0.0

2058 0.0 $0.0 $0.0 $0.0 $0.0

2059 0.0 $0.0 $0.0 $0.0 $0.0

2060 0.0 $0.0 $0.0 $0.0 $0.0

2061 0.0 $0.0 $0.0 $0.0 $0.0

2062 0.0 $0.0 $0.0 $0.0 $0.0

2063 0.0 $0.0 $0.0 $0.0 $0.0

2064 0.0 $0.0 $0.0 $0.0 $0.0

Present Value 3% - $483.1 $330.3 $1,007.6 $101.7

Annualized, 3% - $18.1 $12.4 $37.7 $3.8

Present Value 7% - $290.4 $198.0 $603.0 $60.8

Annualized 7% - $19.6 $13.4 $40.7 $4.1

Source: U.S. EPA analysis for this report
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May 2014 9-11

Table 9-8: Social Cost of Carbon by Year for Electric Generators and Manufacturers – Proposal 

Option 2 ($2011, millions)

Year Emissions 

(tCO2eq, millions)

Discount Rate for Calculating SCC Unit Values

2.5% 3.0% 5.0%

Average SCC 

Value

Average SCC 

Value High SCC Value Average SCC Value

2013 0.0 $0.0 $0.0 $0.0 $0.0

2014 0.0 $0.0 $0.0 $0.0 $0.0

2015 0.0 $0.0 $0.0 $0.0 $0.0

2016 0.0 $0.0 $0.0 $0.0 $0.0

2017 0.0 $0.0 $0.0 $0.0 $0.0

2018 3.2 $210.3 $137.9 $413.7 $41.4

2019 3.2 $213.7 $144.8 $427.5 $41.4

2020 3.2 $220.6 $148.2 $441.3 $41.4

2021 -27.7 -$1,924.4 -$1,273.1 -$3,878.4 -$355.3

2022 -27.8 -$1,956.4 -$1,304.3 -$3,972.1 -$385.4

2023 -31.2 -$2,230.3 -$1,497.9 -$4,560.4 -$432.7

2024 -31.3 -$2,273.4 -$1,537.9 -$4,680.5 -$468.1

2025 -31.3 -$2,307.6 -$1,571.9 -$4,782.4 -$468.2

2026 -51.5 -$3,845.3 -$2,636.8 -$8,020.2 -$824.0

2027 -51.5 -$3,900.1 -$2,691.6 -$8,184.7 -$824.0

2028 -51.5 -$3,954.9 -$2,746.5 -$8,349.3 -$823.9

2029 -51.5 -$4,009.8 -$2,801.4 -$8,514.0 -$878.9

2030 -51.5 -$4,119.7 -$2,856.3 -$8,733.7 -$878.9

2031 -38.0 -$3,078.4 -$2,106.3 -$6,561.8 -$688.6

2032 -38.0 -$3,118.9 -$2,146.7 -$6,683.3 -$688.6

2033 -38.0 -$3,159.3 -$2,187.2 -$6,804.6 -$729.1

2034 -38.0 -$3,199.8 -$2,227.7 -$6,966.6 -$729.1

2035 -38.0 -$3,240.2 -$2,268.2 -$7,088.0 -$769.6

2036 -38.0 -$3,280.6 -$2,308.6 -$7,209.3 -$769.5

2037 -37.9 -$3,361.3 -$2,348.9 -$7,330.0 -$809.9

2038 -37.9 -$3,401.5 -$2,389.1 -$7,491.4 -$809.9

2039 -37.9 -$3,441.5 -$2,429.3 -$7,611.7 -$850.2

2040 -37.9 -$3,481.4 -$2,469.4 -$7,732.0 -$850.1

2041 -37.9 -$3,521.9 -$2,509.9 -$7,853.5 -$890.6

2042 -37.9 -$3,562.4 -$2,550.3 -$7,974.9 -$890.6

2043 -37.9 -$3,602.9 -$2,590.8 -$8,096.3 -$931.1

2044 -37.9 -$3,643.4 -$2,631.3 -$8,217.8 -$931.1

2045 -37.9 -$3,724.3 -$2,671.8 -$8,339.2 -$971.6

2046 -37.9 -$3,764.8 -$2,712.3 -$8,460.7 -$971.6

2047 -37.9 -$3,805.3 -$2,752.8 -$8,541.6 -$1,012.0

2048 -37.9 -$3,845.8 -$2,793.2 -$8,663.1 -$1,012.0

2049 -37.9 -$3,886.2 -$2,833.7 -$8,784.5 -$1,052.5

2050 -37.9 -$3,926.7 -$2,874.2 -$8,906.0 -$1,052.5

2051 -37.9 -$3,967.6 -$2,915.3 -$9,029.1 -$1,053.3

2052 -37.9 -$4,009.0 -$2,956.9 -$9,154.0 -$1,054.0

2053 -37.9 -$4,050.7 -$2,999.2 -$9,280.6 -$1,054.8

2054 -37.9 -$4,092.9 -$3,042.0 -$9,408.9 -$1,055.7

2055 -37.9 -$4,135.6 -$3,085.5 -$9,539.0 -$1,056.5

2056 -37.9 -$4,178.7 -$3,129.6 -$9,670.9 -$1,057.4

2057 -37.9 -$4,222.2 -$3,174.3 -$9,804.7 -$1,058.3

2058 -37.9 -$4,266.2 -$3,219.7 -$9,940.2 -$1,059.3

2059 -37.9 -$4,310.6 -$3,265.7 -$10,077.7 -$1,060.3

2060 0.0 $0.0 $0.0 $0.0 $0.0

2061 0.0 $0.0 $0.0 $0.0 $0.0

2062 0.0 $0.0 $0.0 $0.0 $0.0

2063 0.0 $0.0 $0.0 $0.0 $0.0

2064 0.0 $0.0 $0.0 $0.0 $0.0

Present Value 3% - -$62,019.1 -$43,872.4 -$135,622.3 -$14,589.0

Annualized, 3% - -$2,320.2 -$1,641.3 -$5,073.8 -$545.8

Present Value 7% - -$25,804.9 -$18,030.6 -$55,597.3 -$5,855.4

Annualized 7% - -$1,743.5 -$1,218.2 -$3,756.4 -$395.6

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 10: Summary for Existing Units

May 2014 10-1

10 Summary of Monetized Benefits for Existing Units

10.1 Introduction

This chapter presents a summary of the monetized benefits for existing units under the final rule and 

options considered. Chapters 5 through 9 describe the methods and data EPA used to monetize benefits. 

Refer to Chapter 1 for a description of the requirements of the final rule and other options considered. The 

national benefits estimates presented in this chapter do not include benefits estimated using EPA’s SP 

survey. Refer to Chapter 11 for detail on the SP survey and results. 

10.2 Summary of Methods and Limitations

EPA based its estimates of national monetized benefits for IM&E reductions under the final rule and 

options considered on its regional estimates of monetized benefits by summing over the seven study 

regions. EPA estimated mean national use values, as well as values that include the 5th percentile lower 

bound and 95th percentile upper bound of the recreational benefits estimates.58 EPA’s estimates of 

changes in GHG emissions and associated benefits are at the national level. Monetizing the benefits 

resulting from IM&E reductions and GHG emissions reductions under the final rule and options 

considered is challenging. The preceding chapters discuss specific limitations and uncertainties associated 

with estimating reductions in IM&E and monetized benefits. The national benefits estimates presented in 

Section 10.3 are subject to the same uncertainties inherent in the valuation approaches EPA used for 

assessing regional benefits described in Chapter 5 through 9. The combined effect on estimated use values 

(threatened and endangered species, commercial fishing, and recreational fishing) is of unknown 

magnitude and direction (i.e., the estimates may over- or understate the anticipated national level of use 

benefits). Nevertheless, EPA has no data to indicate that the results for estimated use benefits are atypical 

or unreasonable. EPA was unable to estimate monetized nonuse benefits for IM&E in all regions using 

the benefit transfer approach described in Chapter 8. Therefore, the monetized benefits estimates 

presented in this section do not reflect total benefits associated with reducing IM&E at existing units at 

regulated facilities, and overall national benefits may accordingly be higher.

10.3 Summary of Baseline Losses and Monetized Benefits for the Final Rule and 

Options Considered for Existing Units

Table 10-1 shows that the total annual national value of IM&E losses due to CWIS at existing units of 

regulated facilities. Neither the final rule nor other options considered would eliminate all baseline IM&E 

losses. EPA presents the baseline values for illustration purposes. EPA did not estimate baseline impacts 

related to GHG emissions or associated values.

 Discounted at 3 percent, the total value of baseline IM&E losses is $187.1 million per year

including $78.8 million in recreational fishing losses, $8.0 million in commercial fishing losses, 

$1.2 million in T&E species losses, and $99.1 million in forgone nonuse benefits. The total value 

 

58 The lower estimates of value presented in this chapter are measured by the sum of the 5th percentile lower bound estimates 

of recreational values plus the mean value estimates for all other categories of value. The higher estimates of value presented 

in this chapter are measured by the sum of the 95th percentile upper bound estimates of recreational values plus the mean 

value estimates for all other categories of value.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 10: Summary for Existing Units

May 2014 10-2

of these fishery losses ranges from $151.5 million and $256.2 million based on the 5th percentile 

lower bound and 95th percentile upper bound for recreational values, respectively.

 Discounted at 7 percent, the total value of baseline IM&E losses is $177.3 million per year

including $72.0 million in recreational fishing losses, $7.2 million in commercial fishing losses, 

$1.1 million in T&E species losses, and $96.9 million in forgone nonuse benefits. The total value 

of these fishery losses ranges from $144.7 million and $240.6 million based on the 5th percentile 

lower bound and 95th percentile upper bound for recreational values, respectively.

More detailed discussions of the valuation of impacts under the baseline conditions in each region are 

provided in Chapters 5 through 8.

Table 10-2, Table 10-3, and Table 10-4 present EPA’s estimates of benefits of reducing IM&E under the 

final rule and each of the regulatory options EPA considered for existing units (2011$, discounted at 3

percent and 7 percent). Table 10-5 provides a summary of benefits including the avoided SCC. Monetized 

benefits of reductions in IM&E and reduction in GHG emissions based on 3 percent average SCC values, 

evaluated at a 3 percent discount rate, are as follows:

 Proposal Option 4 results in benefits of $31.0 million per year, with estimates based on the 5th

percentile lower bound and 95th percentile upper bound for recreational values, totaling $22.8

million and $47.6 million.

 The final rule results in benefits of $33.0 million per year, with estimates based on the 5th

percentile lower bound and 95th percentile upper bound for recreational values, totaling $24.1 

million and $50.6 million.

 Proposal Option 2 results in benefits of -$1,542.6 million per year, with estimates based on the 

5

th percentile lower bound and 95th percentile upper bound for recreational values, totaling -

$1,562.2million and -$1,504.5 million.

Evaluated at a 7 percent discount rate, the monetized benefits of the regulatory analysis options are 

somewhat smaller for Proposal Option 4 and the final rule, and greater for Proposal Option 2:

 Proposal Option 4 results in benefits of $27.2 million per year, with estimates based on the 5th

percentile lower bound and 95th percentile upper bound for recreational values, totaling $21.1

million and $39.5 million.

 The final rule results in benefits of $28.7 million per year, with estimates based on the 5th

percentile lower bound and 95th percentile upper bound for recreational values, totaling $22.2

million and $41.8 million.

 Proposal Option 2 results in benefits of -$1,148.2 million per year, with estimates based on the 

5

th percentile lower bound and 95th percentile upper bound for recreational values, totaling -

$1,161.7 million and -$1,122.0 million.

More detailed discussions of benefits under each option are provided in Chapters 5 through 9.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 10: Summary for Existing Units

May 2014 10-3

Table 10-1: Summary of Annualized Benefits from the Elimination of Baseline IM&E at Existing Units of Regulated Facilities 

(2011$, millions)a

Region

Recreational Fishing Benefits Commercial 

Fishing 

Benefitsc

T&E 

Species 

Benefitsd,e

Nonuse 

Benefits

Total Benefitsb

Low Mean High Low Mean High

3% Discount Rate

California $2.4 $4.0 $6.8 $1.7 - - $4.1 $5.7 $8.5 

North Atlantic $1.7 $2.7 $4.4 $0.4 - $20.2 $22.3 $23.3 $25.0 

Mid-Atlantic $9.7 $16.2 $28.3 $2.2 - $78.9 $90.7 $97.3 $109.4 

South Atlantic $0.2 $0.3 $0.4 $0.0 - - $0.2 $0.3 $0.4 

Gulf of Mexico $6.5 $9.6 $14.8 $3.4 - - $9.9 $13.0 $18.2 

Great Lakes $7.3 $13.8 $26.3 $0.2 - - $7.5 $14.1 $26.6 

Inland $15.5 $32.1 $66.9 - $1.2 - $16.7 $33.3 $68.1 

Total $43.2 $78.8 $147.9 $8.0 $1.2 $99.1 $151.5 $187.1 $256.2 

7% Discount Rate

California $2.2 $3.6 $6.1 $1.5 - - $3.7 $5.1 $7.6 

North Atlantic $1.5 $2.4 $3.9 $0.4 - $19.8 $21.6 $22.6 $24.0 

Mid-Atlantic $8.6 $14.5 $25.3 $1.9 - $77.2 $87.8 $93.6 $104.5 

South Atlantic $0.2 $0.3 $0.3 $0.0 - - $0.2 $0.3 $0.4 

Gulf of Mexico $6.0 $8.8 $13.6 $3.2 - - $9.1 $12.0 $16.8 

Great Lakes $6.7 $12.8 $24.3 $0.2 - - $7.0 $13.0 $24.5 

Inland $14.3 $29.6 $61.7 - $1.1 - $15.4 $30.7 $62.8 

Total $39.5 $72.0 $135.3 $7.2 $1.1 $96.9 $144.7 $177.3 $240.6 

"-" = not estimated

a All benefits presented in this table are annualized, i.e., represent the sum of the discounted stream of benefits annualized over 51 years (2014 to 2064). See Appendix D for detail.

b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value per fish predicted by the 

meta-analysis. Commercial fishing benefits are computed based on a region-and species-specific range of gross revenue, as explained in Chapter 6 of this report. EPA estimated 

recreational use benefits for some T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commercial fishing benefits 

and T&E species benefits are added to the respective low, mean, and high values for recreational fishing benefits.

c No significant commercial fishing takes place in the Inland region. Thus, this region is excluded from the commercial fishing analysis.

d Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon). See Chapter 5 of this report 

for more detail on EPA’s analysis of T&E benefits.

e Zeros represent values less than 1,000.

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 10: Summary for Existing Units

May 2014 10-4

Table 10-2: Summary of Annualized Benefits Associated with IM&E Reductions under Proposal Option 4 (2011$, millions)a

Region

Recreational Fishing Benefits Commercial 

Fishing 

Benefitsc

T&E 

Species 

Benefitsd,e

Nonuse 

Benefits

Total Benefitsb

Low Mean High Low Mean High

3% Discount Rate

California $0.0 $0.1 $0.1 $0.0 - - $0.0 $0.1 $0.1 

North Atlantic $0.0 $0.0 $0.0 $0.0 - $0.1 $0.1 $0.1 $0.1 

Mid-Atlantic $0.5 $1.0 $2.0 $0.2 - $0.2 $1.0 $1.5 $2.5 

South Atlantic $0.0 $0.0 $0.0 $0.0 - - $0.0 $0.0 $0.0 

Gulf of Mexico $1.3 $2.2 $3.9 $0.5 - - $1.8 $2.7 $4.4 

Great Lakes $3.4 $6.5 $12.4 $0.1 - - $3.6 $6.6 $12.5 

Inland $3.5 $7.3 $15.2 - $0.4 - $3.9 $7.7 $15.6 

Total $8.8 $17.1 $33.6 $0.9 $0.4 $0.3 $10.4 $18.7 $35.2 

7% Discount Rate

California $0.0 $0.1 $0.1 $0.0 - - $0.0 $0.1 $0.1 

North Atlantic $0.0 $0.0 $0.0 $0.0 - $0.1 $0.1 $0.1 $0.1 

Mid-Atlantic $0.4 $0.7 $1.4 $0.2 - $0.2 $0.8 $1.1 $1.8 

South Atlantic $0.0 $0.0 $0.0 $0.0 - - $0.0 $0.0 $0.0 

Gulf of Mexico $0.9 $1.6 $2.8 $0.4 - - $1.3 $1.9 $3.2 

Great Lakes $2.6 $4.8 $9.2 $0.1 - - $2.7 $4.9 $9.3 

Inland $2.6 $5.4 $11.4 - $0.3 - $2.9 $5.7 $11.7 

Total $6.5 $12.6 $24.9 $0.7 $0.3 $0.3 $7.7 $13.8 $26.1 

"-" = not estimated

a All benefits presented in this table are annualized, i.e., represent the sum of the discounted stream of benefits annualized over 51 years (2014 to 2064). See Appendix D for detail.

b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value per fish predicted by the 

meta-analysis. Commercial fishing benefits are computed based on a region-and species-specific range of gross revenue, as explained in Chapter 6 of this report. EPA estimated 

recreational use benefits for some T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commercial fishing benefits 

and T&E species benefits are added to the respective low, mean, and high values for recreational fishing benefits.

c No significant commercial fishing takes place in the Inland region. Thus, this region is excluded from the commercial fishing analysis.

d Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon). See Chapter 5 of this report 

for more detail on EPA’s analysis of T&E benefits.

e Zeros represent values less than 1,000.

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 10: Summary for Existing Units

May 2014 10-5

Table 10-3: Summary of Annualized Benefits Associated with IM&E Reductions under the Final Rule for Existing Units (2011$, 

millions)a

Region

Recreational Fishing Benefits Commercial 

Fishing 

Benefitsc

T&E 

Species 

Benefitsd,e

Nonuse 

Benefits

Total Benefitsb

Low Mean High Low Mean High

3% Discount Rate

California $0.0 $0.1 $0.1 $0.0 - - $0.0 $0.1 $0.1 

North Atlantic $0.0 $0.0 $0.0 $0.0 - $0.2 $0.2 $0.2 $0.2 

Mid-Atlantic $0.6 $1.1 $2.1 $0.3 - $0.8 $1.6 $2.1 $3.2 

South Atlantic $0.0 $0.0 $0.0 $0.0 - - $0.0 $0.0 $0.1 

Gulf of Mexico $1.3 $2.3 $4.1 $0.5 - - $1.8 $2.8 $4.6 

Great Lakes $3.8 $7.2 $13.6 $0.1 - - $3.9 $7.3 $13.8 

Inland $3.7 $7.6 $15.9 - $0.4 - $4.1 $8.0 $16.3 

Total $9.4 $18.2 $35.9 $0.9 $0.4 $1.0 $11.8 $20.6 $38.3 

7% Discount Rate

California $0.0 $0.1 $0.1 $0.0 - - $0.0 $0.1 $0.1 

North Atlantic $0.0 $0.0 $0.0 $0.0 - $0.2 $0.2 $0.2 $0.2 

Mid-Atlantic $0.4 $0.8 $1.5 $0.2 - $0.7 $1.2 $1.6 $2.3 

South Atlantic $0.0 $0.0 $0.0 $0.0 - - $0.0 $0.0 $0.0 

Gulf of Mexico $0.9 $1.6 $2.9 $0.4 - - $1.3 $2.0 $3.3 

Great Lakes $2.8 $5.3 $10.1 $0.1 - - $2.9 $5.4 $10.2 

Inland $2.7 $5.7 $11.9 - $0.3 - $3.1 $6.0 $12.2 

Total $7.0 $13.5 $26.6 $0.7 $0.3 $0.8 $8.8 $15.3 $28.4 

"-" = not estimated

a All benefits presented in this table are annualized, i.e., represent the sum of the discounted stream of benefits annualized over 51 years (2014 to 2064). See Appendix D for detail.

b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value per fish predicted by the 

meta-analysis. Commercial fishing benefits are computed based on a region-and species-specific range of gross revenue, as explained in Chapter 6 of this report. EPA estimated 

recreational use benefits for some T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commercial fishing benefits 

and T&E species benefits are added to the respective low, mean, and high values for recreational fishing benefits.

c No significant commercial fishing takes place in the Inland region. Thus, this region is excluded from the commercial fishing analysis.

d Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon). See Chapter 5 of this report 

for more detail on EPA’s analysis of T&E benefits.

e Zeros represent values less than 1,000.

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 10: Summary for Existing Units

May 2014 10-6

Table 10-4: Summary of Annualized Benefits Associated with IM&E Reductions under Proposal Option 2 (2011$, millions)a

Region

Recreational Fishing Benefits Commercial 

Fishing 

Benefitsc

T&E 

Species 

Benefitsd,e

Nonuse 

Benefits

Total Benefitsb

Low Mean High Low Mean High

3% Discount Rate

California $0.9 $1.5 $2.6 $0.7 - - $1.6 $2.2 $3.2 

North Atlantic $0.9 $1.4 $2.2 $0.2 - $10.4 $11.5 $12.0 $12.9 

Mid-Atlantic $5.1 $8.6 $15.1 $1.2 - $40.7 $47.0 $50.5 $57.0 

South Atlantic $0.1 $0.2 $0.2 $0.0 - - $0.1 $0.2 $0.2 

Gulf of Mexico $3.4 $5.1 $8.1 $1.7 - - $5.1 $6.8 $9.8 

Great Lakes $4.7 $8.9 $17.0 $0.2 - - $4.9 $9.1 $17.2 

Inland $8.3 $17.2 $35.9 - $0.7 - $9.0 $17.9 $36.5 

Total $23.4 $43.0 $81.1 $3.9 $0.7 $51.1 $79.1 $98.7 $136.8 

7% Discount Rate

California $0.6 $1.0 $1.7 $0.4 - - $1.0 $1.4 $2.1 

North Atlantic $0.6 $0.9 $1.5 $0.1 - $7.6 $8.3 $8.7 $9.2 

Mid-Atlantic $3.3 $5.5 $9.6 $0.8 - $29.7 $33.7 $36.0 $40.1 

South Atlantic $0.1 $0.1 $0.2 $0.0 - - $0.1 $0.1 $0.2 

Gulf of Mexico $2.5 $3.8 $6.0 $1.3 - - $3.7 $5.0 $7.2 

Great Lakes $3.4 $6.4 $12.1 $0.1 - - $3.5 $6.5 $12.2 

Inland $5.7 $11.9 $24.8 - $0.5 - $6.2 $12.3 $25.2 

Total $16.1 $29.5 $55.8 $2.7 $0.5 $37.3 $56.6 $70.0 $96.3 

"-" = not estimated

a All benefits presented in this table are annualized, i.e., represent the sum of the discounted stream of benefits annualized over 51 years (2014 to 2064). See Appendix D for detail.

b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value per fish predicted by the 

meta-analysis. Commercial fishing benefits are computed based on a region-and species-specific range of gross revenue, as explained in Chapter 6 of this report. EPA estimated 

recreational use benefits for some T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commercial fishing benefits 

and T&E species benefits are added to the respective low, mean, and high values for recreational fishing benefits.

c No significant commercial fishing takes place in the Inland region. Thus, this region is excluded from the commercial fishing analysis.

d Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon). See Chapter 5 of this report 

for more detail on EPA’s analysis of T&E benefits.

e Zeros represent values less than 1,000.

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 10: Summary for Existing Units

May 2014 10-7

Table 10-5: Summary of Annualized Benefits by Regulatory Option for Existing Units (2011$, millions)a

Regulatory 

Option

Recreational Fishing Benefits Commercial 

Fishing 

Benefitsc

T&E Species 

Benefitsd,e

Nonuse 

Benefits SCCe Total Benefits

Low Mean High Low Mean High

3% Discount Rate

Proposal Option 4 $8.8 $17.1 $33.6 $0.9 $0.4 $0.3 $12.4 $22.8 $31.0 $47.6

Final Rule $9.4 $18.2 $35.9 $0.9 $0.4 $1.0 $12.4 $24.1 $33.0 $50.6

Proposal Option 2 $23.4 $43.0 $81.1 $3.9 $0.7 $51.1 -$1,641.3 -$1,562.2 -$1,542.6 -$1,504.5

7% Discount Rate

Proposal Option 4 $6.5 $12.6 $24.9 $0.7 $0.3 $0.3 $13.4 $21.1 $27.2 $39.5

Final Rule $7.0 $13.5 $26.6 $0.7 $0.3 $0.8 $13.4 $22.2 $28.7 $41.8

Proposal Option 2 $16.1 $29.5 $55.8 $2.7 $0.5 $37.3 -$1,218.2 -$1,161.7 -$1,148.2 -$1,122.0

a All benefits presented in this table are annualized, i.e., represent the sum of the discounted stream of benefits annualized over 51 years (2014 to 2064). See Appendix D for detail.

b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value per fish predicted by the metaanalysis. Commercial fishing benefits are computed based on a region- and species-specific range of gross revenue, as explained in Chapter 6 of this report. EPA estimated recreational use 

benefits for some T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commercial fishing benefits and T&E species benefits 

are added to the respective low, mean, and high values for recreational fishing benefits.

c No significant commercial fishing takes place in the Inland region. Thus, this region is excluded from the commercial fishing analysis.

d Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon). 

See Chapter 5 of this report for more detail on EPA’s analysis of T&E benefits.

e

SCC results presented here are based on 3 percent average SCC values.

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 11: Stated Preference Survey

May 2014 11-1

11 Stated Preference Survey

11.1 Introduction

EPA developed a stated preference survey to estimate total values (use plus nonuse) for 

improvements to fishery resources and ecosystems affected by IM&E from regulated facilities.59

Understanding total public WTP for resulting changes in fishery resources, including the more 

difficult to estimate nonuse values, is necessary to determine the full range of benefits associated 

with reductions in IM&E, and simplifies the determination of whether the benefits of government 

action to reduce IM&E at existing facilities are commensurate with the costs of such actions.

Because potential nonuse values may be substantial, failure to recognize such values may lead to 

improper inferences regarding benefits and costs, and an inefficient allocation of society’s 

resources. As discussed in Chapter 8, EPA was able to generate only a partial estimate of nonuse 

benefits using benefit transfer with existing SP data. Moreover, estimates from high quality 

primary valuation studies are generally considered superior to those from benefit transfer 

(Johnston & Rosenberger 2010) because primary studies are designed for the specific context of 

the policy case, whereas transferring results from other studies may require assumptions to 

facilitate transfer that may not be completely accurate. EPA developed and implemented the SP 

survey to fill this gap by providing data which could be used to estimate total benefits for all U.S. 

regions.

EPA plans to obtain SAB review of the SP survey EPA conducted. The SAB review would be in 

addition to the external peer review EPA already conducted on the survey. SAB review will 

provide high caliber, independent professional judgment concerning the quality of the survey 

done to date, including possible improvements EPA could make to the analysis. EPA also plans 

to seek SAB input on whether, how and in what circumstances this or similar surveys could be 

used as support for national rulemakings or 316(b) NPDES permitting. EPA expects that while 

this process will add time (it may take a year or more), given the importance of this issue for the 

evaluation of ecological benefits generally, it is worth taking the time to seek this additional 

input. Given the planned SAB review, using the SP survey results prior to completion of the 

review would be premature. EPA is committed to working with the states to support their sitespecific permitting decisions with the benefit of the SAB review once it is completed.

EPA has not accounted for values estimated from the survey in the comparison of monetized 

costs and benefits. This chapter describes the design of the SP survey and presents current, but 

not necessarily final, model estimation results. EPA also describes a method for monetizing 

benefits for the final rule and presents a preliminary estimate of benefits for the final rule and 

options considered to illustrate the potential magnitude of regulatory benefits and demonstrate 

progress towards this effort. Discussion of peer reviewer comments related to their confidence in 

the study results and limitations for policy analysis is presented in Section 11.10. 

 

59 As discussed in Chapter 8, nonuse values are values people may hold for an environmental improvement that are 

not associated with use (e.g., recreation) of the resource.
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11.2 Survey Design

SP surveys, in general, ask questions that elicit individuals’ stated values for carefully specified 

changes in an environmental amenity. This value is typically estimated in terms of WTP, defined 

as the maximum amount of money (or some other commodity) that an individual or household 

would be willing to give up in exchange for a specified environmental change, rather than go 

without that change. EPA designed the SP survey as a choice experiment. Choice experiments, 

also called choice models, are an SP technique in which individuals’ values are estimated based 

on their choices over a set of hypothetical but realistic multi-attribute policy options designed to 

mimic the consumer decision-making that occurs in actual markets, and span the range of 

possible policy options.

60 Choice experiments have been applied in many past studies to assess 

WTP for ecological resource improvements, which is also the context of the main improvement 

in the 316(b) policy case (e.g., Bennett and Blamey 2001; Hanley et al. 2006; Hoehn et al. 2004; 

Johnston et al. 2002a; Johnston et al. 2011b; Johnston et al. 2012; Milon and Scrogin 2006; 

Morrison et al. 2002; Morrison and Bennett 2004; Opaluch et al. 1999).

Advantages of these choice-based methods include similarity to familiar referenda or market 

choice contexts, in which individuals choose among alternative bundles of attributes or 

commodities (for example, attributes of consumer electronics) at different costs (Freeman 2003). 

Among other advantages, such methods are intended to reduce strategic and other survey biases 

that can be associated with alternative ways of using survey questions to elicit values, versus 

assessing WTP through market transactions or referenda. For example, some types of SP surveys 

ask respondents to express their WTP using open-ended questions, payment cards, or bidding 

games. Increasingly, however, these types of SP surveys have been replaced in the literature by 

choice-based methods.61

Choice experiments also allow survey respondents to express WTP for a wide range of different 

potential outcomes, differentiated by their attributes. This enables EPA to isolate the marginal 

effects of different potential policy outcomes on stated choices and hence, on estimated WTP. 

EPA can thereby estimate benefits for a wider range of potential policy outcomes than would be 

possible with alternative SP methods. This is a primary factor distinguishing choice experiments 

from older forms of SP analysis, in which stated WTP is typically contingent upon a single 

specification of ecological and other policy effects.

11.2.1 Survey Format

EPA followed established choice experiment methodology in the developing the format of the 

316(b) SP survey (Adamowicz et al. 1998; Bateman et al. 2002; Bennett and Blamey 2001; 

Louviere et al. 2000). Respondents are presented with two alternative hypothetical policy options 

 

60 In addition to choice experiments, stated preference techniques include as contingent valuation (CV). CV surveys 

typically ask respondents, “What are you willing to pay?” for a particular environmental improvement, or in a 

dichotomous choice form as “are you willing to pay $X?” for a particular environmental improvement. In general, 

CV surveys focus on a comparison between the status quo and a particular environmental improvement (akin to a 

one-time offer). This is different from the consumer decision-making that occurs in actual markets and involves 

comparing status quo to multiple environmental outcomes. Therefore, EPA relied on the choice experiment 

technique that mimics common market situations in its study design.

61 Choice-based methods are also increasingly employed in the marketing research literature to analyze consumer 

preferences. In particular, choice based experiments are a popular in modeling brand choice (Erdem and Keane 

1996) and demand for new products (Brownstone and Train 1996).
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described by multiple attributes. They are asked to choose (or vote for) the policy they prefer, 

much as one would choose a preferred option in a public referendum. Respondents may also

choose to reject both policies and retain the status quo. The underpinning theoretical model is 

adapted from a standard random utility specification in which household h chooses among three 

choice options (j=A,B,N), including two multi-attribute policy options (A, B) and a fixed “No 

Policy” (the status quo) (N) that includes no policy changes and zero cost to the household. Each 

choice option reflects a hypothetical but feasible outcome under various 316(b) regulatory 

alternatives. 

The effects of the policy options are described in terms of a household cost and four 

environmental endpoints, or attributes: (a) commercial fish populations, (b) fish populations (all 

fish), (c) fish saved per year, and (d) condition of aquatic ecosystems. The definition of each 

attribute is presented in Table 11-1. Ecological attributes are expressed relative to upper and 

lower reference conditions; i.e., best and worst possible conditions of the attribute, as defined in 

survey informational materials. Respondents were asked to evaluate changes in fish saved per 

year as a percentage of current estimated mortality, but those changes were also illustrated in 

terms of numbers of A1E fish.62Relative scores represent percent progress towards the upper 

reference condition (100 percent), starting from the lower reference condition (0 percent), both 

keyed to readily understood conditions. Presentation of all ecological attributes was informed by 

input from focus groups and cognitive interviews (Johnston et al. 1995; Kaplowitz et al. 2004)

used to pretest the survey instrument.

Values for “fish saved” in the referendum questions are based on EPA’s estimate of A1E losses 

due to CWIS at baseline. Refer to Chapter 3 for additional description of the A1E metric.

Introductory materials in the survey describe the age classes impacted due to cooling water 

intakes and the “fish saved” metric as “young adult fish (the equivalent of one year old).” Pretesting during focus groups and cognitive interviews suggested that participants understood the 

“fish saved” attribute and the concept of “young fish” as reflecting initial IM&E of eggs and other 

juvenile life stages expressed as in terms of the A1E metric. Page three of the survey booklet 

includes introductory materials that specify the proportion of “fish saved” that are and are not 

commercial or recreational species.

Values are reflected in the survey by individuals’ willingness to “vote” for policies that would 

result in an increase in their cost of living, in exchange for specified changes in the four 

environmental attributes. Other questions in the survey elicit information including whether the 

respondent is a user of the affected aquatic resources, household income, and other respondent 

demographics.63

 

62 A1E, in addition to providing a way to standardize organisms lost to IM&E so that it could be compared among 

species, years, facilities, and regions, is a convenient way to express losses of all life stages, including fish eggs 

and larvae, as numbers of individual age-one equivalent fish.

63 The four environmental attributes were designed based on the Johnston et al. (2011a; 2011b; 2012) BioindicatorBased Stated Preference Valuation (BSPV) method which was developed to promote ecological clarity and closer 

integration of ecological and economic information within SP studies. This methodology was developed in part to 

address the EPA Science Advisory Board’s call, in its May 2009 report, Valuing the Protection of Ecological 

Systems and Services: A Report of the EPA Science Advisory Board (USEPA 2009b), for improved quantitative 

linkages between ecological services and economic valuation of those services.
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Table 11-1: Definitions of Policy Attributes and Baseline (No Policy) Values

Attribute Definition

Commercial Fish 

Populations

A score between 0 and 100 percent showing the overall health of commercial and 

recreational fishing populations. High scores mean more fish and greater fishing potential. 

A score of 100 means that these fish populations are at a size that maximizes long-term 

harvest: 0 means no harvest.

Fish Populations 

(All Fish)

A score between 0 and 100 percent showing the estimated size of all fish populations 

compared to natural levels without human influence. A score of 100 means that 

populations are the largest natural size possible; 0 means no fish.

Fish Saved (per 

Year)

A score between 0 and 100 percent showing the reduction in young fish lost compared to 

current levels. A score of 100 would mean that no fish are lost in cooling water intakes (all 

fish would be saved because of the new policy).

Condition of 

Aquatic 

Ecosystems

A score between 0 and 100 percent showing the ecological condition of affected areas, 

compared to the most natural waters in the region. The score is determined by many 

factors including water quality and temperature, the health of aquatic species, and habitat 

conditions.

Cost per Year How much the policy will cost your household, in unavoidable ongoing price increases for 

products and services you buy, including electricity and common household products.

Source: U.S. EPA analysis for this report

11.2.2 Experimental Design

The experimental design is the plan for varying attribute levels across questions within a survey 

and across survey versions, so that aggregated responses will provide enough data for efficient 

estimation of model parameters and WTP. Respondents were presented with three separate policy 

questions in the survey, each with a specific combination of policy options. The experimental 

design specifies how these attribute levels were “mixed and matched” within choice questions, 

thereby developing an empirical data framework with appropriate statistical properties to allow 

for analysis of respondent’s choices (Louviere et al. 2000). It generates multiple unique 

combinations of policy options for different respondents to compare.

Table 11-2 presents the set of attribute levels that are used across the option pairs. Following 

guidance from the literature, EPA designed the attribute levels to illustrate realistic policy 

scenarios that “span the range over which we expect respondents to have preferences, and/or are 

practically achievable” (Bateman et al. 2002, p. 259; USEPA 2012a; USEPA 2012b).

In interpreting the results, it is useful to keep in mind that three of the attributes spanned a 

relatively narrow range of percentage values reflecting realistic ecological expectations (e.g., 

commercial fish populations differing by no more than six percentage points from the baseline), 

while the “fish saved per year” attribute, which was ultimately used to estimate household WTP 

for the policy options, spanned a much larger range (i.e., up to 95 percentage points). This reflects 

the expected range of potential reductions based on the performance of the technologies consider 

for the regulatory options. Given this realistic distinction in attribute spread, EPA expects that the 

WTP per percentage point will be lower for fish saved than for other attributes because 

respondents “see” most of the possible ranges of fish saved. Allowing the range of variables to 

vary according to realistic ecological and technological expectations is recommended practice in 

SP design (Bateman et al. 2002).

EPA applied a fractional factorial experimental design representing a subset of all possible 

combinations of environmental attributes and household cost. This allows efficient estimation of 

particular effects of interest with a relatively small number of choice questions (Louviere et al. 
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2000), thereby reducing the cognitive burden faced by respondents (i.e., by reducing the number 

of questions that each respondent must answer; Holmes and Adamowicz 2003). EPA generated 

the design using a D-efficiency criterion for main effects estimation (Kuhfeld and Tobias 2005; 

Kuhfeld 2010). This design enables model coefficients, and hence, estimated WTP, to be 

estimated with greater precision, i.e., lower standard errors or variability, for any given number of 

observations. It also minimizes correlation between attributes across survey questions (i.e., 

attributes do not “move together” across different survey questions), so that the unique effect of 

each attribute on respondents’ choices, and ultimately, values, can be isolated.64

The experimental design for the 316(b) survey is characterized by 72 unique Option A vs. Option 

B pairs, each corresponding to a choice question defined by an orthogonal (independent) array of 

attribute levels for the two policy options. It is standard practice to include more than one choice 

question in each survey, thus increasing the information obtained from each respondent (Layton 

2000; Poe et al. 1997). EPA randomly assigned the 72 option pairs to 24 distinct versions for each 

of the four regional surveys and the national survey, with three option pairs (i.e., choice 

questions) per survey booklet. See the ICR supporting statement (USEPA 2011C) for additional 

detail on the experimental design.

 

64 EPA removed dominated pairs where one option is superior to the other in all attributes. Allowing such pairs 

would effectively limit respondents to selecting between the dominant choice option and the No Policy option. 

Focus groups showed that respondents react negatively and often protest when offered dominated pairs. Given that 

such choices provide negligible statistical information compared to choices involving non-dominated pairs, they 

are typically avoided in choice experiment statistical designs.
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Table 11-2: Attribute Levels Assigned Across Policy Options and Survey Versions

Attribute Baseline (No 

Policy)

a

Max 

Change 

Assigned

Attribute Levels Assigned to Option A vs. Option B Pairs

1 2 3 4 5 6

Commercial Fish Populations (Score showing the overall health of commercial and recreational fish populations)

Northeast 42% 6% 43% 45% 48% - - -

Southeast 39% 6% 40% 42% 45% - - -

Pacific 56% 6% 57% 59% 62% - - -

Inland 39% 6% 40% 42% 45% - - -

National 51% 6% 52% 54% 57% - - -

Fish Populations (all fish) (Score showing the estimated size of all fish populations compared to natural levels 

without human influence)

Northeast 26% 4% 27% 28% 30% - - -

Southeast 24% 4% 25% 26% 28% - - -

Pacific 32% 4% 33% 34% 36% - - -

Inland 33% 4% 34% 35% 37% - - -

National 30% 4% 31% 32% 34% - - -

Fish Saved per Year (Score showing the reduction in young fish lost compared to current levels)

Northeast 0% 95% 5% 50% 95% - - -

Southeast 0% 90% 25% 55% 90% - - -

Pacific 0% 95% 2% 50% 95% - - -

Inland 0% 95% 55% 75% 95% - - -

National 0% 95% 25% 55% 95% - - -

Aquatic Ecosystem Condition (Score showing the ecological condition of affected areas, compared to the most 

natural waters in the region)

Northeast 50% 4% 51% 52% 54% - - -

Southeast 68% 4% 69% 70% 72% - - -

Pacific 51% 4% 52% 53% 55% - - -

Inland 42% 4% 43% 44% 46% - - -

National 53% 4% 54% 55% 57% - - -

Household Costs (The increase in annual household cost, in unavoidable price increases)

Northeast $0 $72 $12 $24 $36 $48 $60 $72

Southeast $0 $72 $12 $24 $36 $48 $60 $72

Pacific $0 $72 $12 $24 $36 $48 $60 $72

Inland $0 $72 $12 $24 $36 $48 $60 $72

National $0 $72 $12 $24 $36 $48 $60 $72

a Each question includes a “no policy” option, characterized by the baseline levels for each attribute and a household cost of $0.

Source: U.S. EPA analysis for this report

11.2.3 Pre-Tests

Following recommended methods for SP survey design, EPA used focus groups and cognitive 

interviews to test wording and attribute selection and ensure that respondents understand and are 

not cognitively burdened by the question format (cf. Arrow et al. 1993; Bateman et al. 2002; 

Bennett and Blamey 2001; Kaplowitz et al. 2004; Powe 2007). The survey instrument was pretested extensively in six focus groups, with eight to ten participants each, and a set of eight oneon-one cognitive interviews (USEPA 2010d). Each cognitive interview included only one 

participant. This allowed in-depth exploration of the cognitive processes respondents used to 

answer survey questions, without the potential for interpersonal dynamics to sway respondents’ 
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comments (Kaplowitz et al. 2004). These focus groups and cognitive interviews were in addition 

to ten focus groups and two series of cognitive interviews that were conducted previously by EPA 

in 2004 and 2005 to test an earlier version of the survey developed in anticipation of the Phase III 

benefits analysis. Focus groups and cognitive interviews also included questions following the 

verbal protocol format suggested by Schkade and Payne (1994), in which respondents were asked 

to talk through the process used to answer choice questions. Within focus group and cognitive 

interviews, the moderator first asked the participants to complete a draft survey questionnaire. 

The moderator then led a general conversation which led the group/individual through a series of 

debriefing questions. During debriefing, the moderator asked focus group and cognitive interview 

participants about their reactions to the survey format and content, their interpretations of survey 

materials (including questions and the information provided), whether the survey questions were 

clear, whether the background information presented in the survey or introductory materials was 

sufficient, whether respondents felt like the questions were leading, what went through 

participants’ minds when they read survey information and questions, and response motivations. 

Debriefing questions also explored whether responses were influenced by hypothetical, strategic, 

symbolic and other biases noted in the stated preference literature.

The participants’ comments and feedback provided important information on such concerns as 

whether (1) questions and survey information were readily understood, (2) respondents were 

interpreting questions similarly to how EPA interprets them, (3) responses or survey 

interpretations showed any evidence of heuristics or survey biases, including hypothetical bias, 

(4) respondents were addressing choice questions in a manner commensurate with utility 

maximization and neoclassical WTP estimation, and (5) respondents were following instructions 

provided in the survey instrument and responding to questions accordingly. Focus group 

participants’ responses to the survey choice questions could not be included in model estimation 

because the draft surveys completed during pre-testing represent evolving versions and differed 

somewhat from the final survey. EPA modified the survey several times based on the results of 

these pre-tests to help minimize potential biases and ensure shared and accurate interpretation of 

survey language by the respondents. The amount of pre-testing conducted for SP surveys varies 

within the literature and tends to be related to the complexity of the survey instrument. However, 

the amount of time and number of focus groups the Agency used is significantly greater than 

many academic studies and matches the practice in developing SP surveys for natural resource 

damage assessments.

11.3 Sampling Frame

The sampling frame is the population from which the potential respondents are selected, in this 

case, at random. EPA designed the 316(b) SP study as a household mail survey, because the 

household is the fundamental economic decision-making unit for WTP studies. The mail survey 

approach avoids potential sampling biases in telephone surveys associated with the incomplete 

coverage of landline and cellphone databases. The mail address sample of households in the 

continental U.S. was from drawn from a database which covers 97 percent of residences in the 

United States including city‐style addresses and PO boxes, and covers single‐unit, multi‐unit, and 

other types of housing structures.

EPA stratified households based on the geographic boundaries of four regions: Northeast, 

Southeast, Inland, and Pacific. The SP regions are based on state boundaries and include both 

coastal and freshwater facilities in the Northeast, Southeast, and Pacific regions. These regions 
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differ from the 316(b) benefits regions used elsewhere in this Benefits Analysis which separate 

coastal and freshwater resources. During survey pretesting, EPA found that respondents more 

easily understood regional boundaries based on states than boundaries that distinguished between 

coastal and freshwater facilities.

Table 11-3 presents the States included in each SP region, the total number of households in each 

region, the target number of completed surveys, and the number of surveyed households for each 

survey region. EPA developed target sample sizes for each region to provide statistically robust 

results while minimizing the cost and burden of the survey to individual respondents.

65 The target 

sample sizes refer to completed mail surveys. A larger number of households must be mailed 

surveys because only a portion of households that receive a survey complete and return it. 

EPA selected a total target sample of 2,000 completed surveys across all four regional surveys to 

provide estimates of population percentages with a margin of error ranging from 3.6 to 5.8 

percentage points at the 95 percent confidence level.66 These 2,000 surveys were allocated across 

the four regions based on the number of households in each region relative to the total number of 

household in the continental United States. In addition, a minimum number of completed surveys 

were required for each region to enable model estimation. Monte Carlo experiments indicate that 

approximately 6 to 12 completed responses are required for each profile (unique set of choice 

options) in order to achieve large sample statistical properties for choice experiments (Louviere et 

al. 2000, p. 104, citing Bunch and Batsell 1989). As described previously, the experimental 

design includes 72 option profiles. Following this guidance, the experiment design requires 12 

completed surveys for each of the 72 profiles, for a total of 864 profile responses per region 

(72×12=864). A minimum of 288 completed surveys were hence required for each region 

because each survey version includes three profiles (864÷3=288).

The allocation of the 2,000 completed surveys across the four regions resulted in target sample 

sizes of 417 for the Northeast region, 562 for the Southeast region, 289 for the Pacific region, and 

732 for the Inland region. EPA also conducted a national mail survey with a target sample size of 

288 completed surveys. EPA mailed the survey to 7,840 households in total, anticipating a 

response rate of 30 percent. EPA assumed that it would take respondents an average of 30 

minutes to complete and mail back the questionnaire.

 

65 EPA included three choice questions within each survey, to increase information obtained from each respondent. 

It is standard practice within choice experiment and dichotomous choice contingent valuation surveys to include 

more than one choice question in each survey (Layton 2000; Poe et al. 1997). Including more than three choice 

questions may have negatively affected the response rate by increasing burden on respondents and including fewer 

would have increased survey costs by requiring additional households to be sampled.

66 Margin of error was calculated assuming that the population percentage selecting a specific answer (e.g., “yes”) in 

a binary question is 50 percent (i.e., worst case scenario). This is the worst case scenario because it indicates that 

there is disagreement among people regarding the correct response (i.e., 50 percent select “yes” and 50 percent 

select “no”) and the standard error of the proportion is large (Orme 2010). The range of the margin of error (3.6 to 

5.8 percent) is based on the sample sizes for each region. For example, the sample percentage selecting a specific 

response to a binary question based on a sample of 732 households has a margin of error of plus or minus 3.6 

percent at a 95 percent confidence level whereas the sample percentage selecting a specific response based on a 

sample of 288 households will have a margin of error of plus or minus 5.8 percent.
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Table 11-3: Target Sample Sizes and Number of Mailed Surveys by Survey Region

Survey Region State Included Number of 

Householdsa

Target Sample 

Sizeb,c

Number of 

Surveyed 

Householdsd

Northeast CT, DC, DE, MA, MD, ME, 

NH, NJ, NY, PA, RI, VT 23,281,296 417 1,440

Southeast AL, FL, GA, LA, MS, NC, 

SC, TX, VA 31,378,122 562 1,920

Pacific CA, OR, WA 40,852,983 289 1,040

Inland

AR, AZ, CO, ID, IA, IL, IN, 

KS, KY, MI, MN, MO, MT, 

ND, NE, NM,NV, 

OH,OK,SD,TN, UT, WI, 

WV, WY

16,158,206 732 2,480

Total for Regional 

Surveys

U.S. (excluding AK and HI) 111,670,607 2,000 6,880

National Survey U.S. (excluding AK and HI) 111,670,607 288 960

a The number of households in each region was obtained based on the estimated population size and average household size from 

the 2006-2008 American Community Survey (U.S. Census Bureau 2009).

b Target sample sizes presented here refer to completed mail surveys. 

c The sample is allocated to each region in proportion to the total number of households in that region, with at least 288 completed 

surveys required for each region to estimate the main effects and interactions under an experimental design model.

d The number of intended completed questionnaires for each survey region was rounded up so that the same number of households 

received each of the 24 survey versions.

Source: U.S. EPA analysis for this report

EPA used multiple preview and reminder mailings to promote a high response rate and minimize 

the potential for non-response bias. This approach follows Dillman et al. (2009), which is among 

the most commonly cited sources for survey logistics management. Households were selected 

from the U.S. Postal Service Digital Sequence File (DSF) of residences which, in total, covers 97

percent of residences in the United States. EPA also conducted a follow-up study of households 

that did not return a completed mail survey to determine whether survey non-respondents are 

fundamentally different than survey respondents. The follow-up survey included demographic 

and attitudinal questions. 

11.4 Mail Survey Responses 

Published guidance for SP survey design recommends conducting a pilot study to inform 

potential changes to other survey versions (Arrow et al. 1993; Bateman et al. 2002). Following 

this guidance, EPA undertook the Northeast region of the survey in advance of the other regions 

and national survey, as described in the ICR for the 316(b) SP survey (USEPA 2011c). After 

review of the Northeast survey responses, EPA received approval from the Office of Management 

and Budget (OMB) to implement the remaining survey regions (Inland, Southeast, and Pacific) 

and the national survey. EPA fielded the remaining survey versions in October 2011. EPA 

received a total of 2,313 completed mail surveys. Table 11-4 summarizes the number of 

completed surveys received and the response rate (responses as a percentage of mailed surveys 

minus undeliverable surveys). The average response rate was 32 percent. This response rate is 

comparable to various other recent mail surveys in the SP literature (e.g., Boyle and Özdemir 

2009; Hanley et al. 2006; Johnston and Duke 2009; Johnston and Bergstrom 2011)
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Table 11-4: Completed Survey Received and Response Rates by Survey Version

Survey Region Households 

Surveyed

Completed Surveys 

Received Response Ratea

Northeast 1,440 421 31%

Southeast 1,920 506 29%

Pacific 1,040 311 32%

Inland 2,480 787 35%

National Survey 960 288 34%

Total 7,840 2,313 32%

a The number of undeliverable surveys was subtracted from surveys mailed when calculating the response rate for each 

survey region. Undeliverable surveys are those surveys that were returned to sender.

Source: U.S. EPA analysis for this report

Analysis of the survey data across all four regions and the national survey indicates that 

respondents appear to have been evaluating tradeoffs between costs and benefits of policy options 

presented to them, and that WTP is responsive to scope (i.e., the quantity of environmental 

improvements across different attributes). Respondents appear to have understood and 

distinguished between different types of outcomes from 316(b) regulation. About 90 percent of 

respondents answered the choice experiment questions (questions 4, 5, and 6). Question 8 asked 

respondents to rate the statement that the survey material was easy to understand. Only 14 percent 

disagreed with that statement (see Figure 11-1). Seventy-one percent of respondents strongly 

agreed or agreed when asked in a 5-level Likert scale question whether they were confident in 

their responses to the survey questions. The vast majority indicated that they would answer the 

same way if parallel questions were asked in a binding referendum, with less than three percent of 

respondents indicating otherwise (see Figure 11-2).

About 75 percent of mail survey respondents were under age 65 and the majority of those 

completing the survey (63 percent) were male. About 87 percent of respondents selected “white” 

for racial category. For additional information on the demographic characteristics of respondents 

see EPA’s survey analysis memo to the 316(b) rulemaking record (USEPA 2012). 
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Figure 11-1: Summary of Responses to Regarding Respondent 

Understanding across All Surveys
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Figure 11-2: Summary of Responses Regarding Respondent Confidence 

across All Surveys

11.5 Non-Response Study

EPA conducted a follow-up study of households that did not return a completed mail survey to 

identify whether survey non-respondents are fundamentally different than survey respondents in 

certain attributes. The follow-up study included a set of key attitudinal questions and sociodemographic variables that are most likely to be associated with WTP for reducing fish mortality 

from CWISs and improvements in fish populations and conditions in the affected aquatic 

ecosystems. Section 11.5.1 describes the non-response sample and Section 11.5.2 describes 
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statistical tests that EPA conducted comparing the main mail survey sample and the non-response 

sample. 

11.5.1 Non-Response Sample

EPA implemented the follow-up study using two subsamples: the first subsample received a 

paper questionnaire via U.S. Postal Service Priority Mail®, and the second subsample was 

surveyed by telephone. Both non-response subsamples were asked the same set of attitudinal and 

demographic questions. It took participants approximately five minutes to complete the follow-up 

study.

EPA’s target sample across all regions for the non-response study was 600 completed nonresponse surveys. This is the sample size required for a two-sided test showing a difference of 12 

percentage points to be rejected with statistical power of 80 percent. In total, EPA planned to 

achieve 400 completed surveys in the Priority Mail subsample and 200 completed questionnaires

in the telephone subsample. EPA allocated the initial target non-response completed surveys to 

each survey region in proportion to the mail survey sample size of each region. The priority mail 

subsample was conducted in advance of the telephone subsample. EPA conducted additional 

telephone calls to ensure that it reached targets for the total number of complete non-response 

surveys in each region, if the priority mail response fell short of the target. The number of 

completed non-response surveys is summarized in Table 11-5 by subsample. Overall response 

rates for the non-response study ranged from about 21.5 percent in the Southeast to 29.5 percent

for the national survey.
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11.5.2 Statistical Testing of Mail Survey and Non-Response Data

EPA compared the respondent and non-respondent samples statistically according to eight 

characteristics to evaluate potential for non-response bias:

1. Age: age of the household member completing the survey

2. Gender: gender of the household member completing the survey

3. Education: highest level of education completed by the household member completing 

the survey

4. Employment: whether the survey participant is currently employed (yes/no)

5. Hispanic or Latino origin: whether the participant is of Hispanic or Latino ethnicity 

(yes/no)

6. Race: racial category of the participant

7. Income: annual household income

8. Importance of protecting aquatic ecosystems: attitudinal question asking the participant 

to rate how important he or she considers the protection of aquatic ecosystems.

Table 11-5: Completed Non-Response Surveys Received and Response Rates by 

Survey Region and Survey Mode

Survey Subsample/Survey Region Sample Size Completed Surveys Response Rate

Priority Mail Subsample

Northeast 146 48 32.9%

Southeast 297 71 23.9%

Inland 389 127 32.6%

Pacific 159 58 36.5%

National Survey 146 58 39.7%

Telephone Subsample

Northeast 331 63 19.0%

Southeast 410 81 19.8%

Inland 356 71 19.9%

Pacific 160 20 12.5%

National Survey 125 22 17.6%

Total Non-Response Sample

Northeasta 426 111 26.1%

Southeast 707 152 21.5%

Inland 745 198 26.6%

Pacific 319 78 24.5%

National Survey 271 80 29.5%

a

For the Northeast region, EPA included 51 households which did not return the Priority Mail questionnaire within the 

telephone subsample in order to achieve the target number of completes. As a result, the total sample size for the 

Northeast is less than the sum of the Priority Mail and telephone subsamples.

Source: U.S. EPA analysis for this report
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Table 11-6 summarizes the characteristics of the respondents to the main surveys and nonresponse surveys. 
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Table 11-6: Characteristics of the Main and Non-Response Samples by Survey Regiona

Statistic

Northeast Southeast Inland Pacific National Survey

Main Non-Response Main NonResponse Main NonResponse Main NonResponse Main NonResponse

Age

Average age 54.6 53.7 54.3 56.6 53.7 56.1 52.8 49.7 54.2 53.2

Percent under 65 74.6% 73.9% 74.1% 68.9% 76.3% 67.4% 76.1% 89.6% 72.7% 70.0%

Gender

Percent male respondents 63.9% 44.5% 62.3% 46.7% 64.6% 51.3% 62.7% 55.1% 60.4% 45.6%

Employment

Percent currently employed 63.6% 62.7% 59.2% 57.9% 64.4% 54.4% 65.0% 68.4% 60.2% 57.0%

Percent employed under age 

65 76.9% 79.3% 75.0% 79.4% 76.9% 73.8% 80.3% 74.6% 72.5% 72.7%

Educational Attainment b

Bachelor’s Degree or 

Higher 45.9% 46.4% 44.1% 34.0% 43.1% 30.1% 50.8% 44.2% 46.9% 39.3%

Race and Ethnicity c

Percent white respondents 86.6% 85.7% 82.3% 78.8% 91.0% 93.0% 84.7% 75.7% 83.4% 80.8%

Percent Hispanic or Latino 

Origin 5.1% 5.6% 9.9% 9.9% 3.4% 5.2% 13.3% 13.3% 7.0% 11.4%

Total Household Income d

Average $88,880 $81,480 $75,588 $74,179 $73,567 $59,598 $96,144 $79,306 $79,496 $63,681

Standard Deviation $69,309 $68,486 $62,618 $66,760 $57,261 $54,966 $71,282 $67,757 $60,972 $57,415

Percent >$60,000 55.7% 49.0% 48.1% 44.8% 48.1% 31.0% 57.2% 50.0% 51.9% 37.5%

Importance of Aquatic Ecosystems e

Average Ranking 4.0 4.0 3.9 4.0 3.8 3.9 4.0 4.1 3.9 3.9

a Respondents who did not answer a given demographic question were excluded when calculating percentages.

b The surveys included six categories for educational attainment: (1) less than high school, (2) high school or equivalent, (3) high school + technical school, (4) one or more years of college, (5) 

bachelor’s degree, and (6) graduate degree.

c The surveys include six categories for education attainment: (1) American Indian or Alaskan Native, (2) Black or African American, (3) Native Hawaiian or Other Pacific Islander, (4) Asian, (5) 

White, and (6) Other. Respondents could select more than one racial category. The “Percent white respondents” presented above includes respondents that selected other racial categories in addition 

to white. 

d The survey asked respondents to select one of eight categories for annual household income. The average and standard deviation reported here were calculated using the midpoint of each range. 

The amount of $250,000 was used for the highest income category included in the survey (“$250,000 or more”).

e Respondents were asked to rate the “importance of protecting aquatic ecosystems” on a scale of 1 to 5, 1 being “not important” and 5 being “very important”.

Source: U.S. EPA analysis for this report
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For categorical or ordinal variables (i.e., all variables except age), EPA tested for statistical 

differences between respondents and non-respondents using both the Mann-Whitney U Test and 

χ

2Test of Proportions. EPA used the Student’s t-test for age, the only cardinal variable in the 

group. EPA considered a variable to be statistically different across the two populations if the null 

hypothesis of equality could be rejected at p<0.10. Table 11-7 presents the variables which were 

found to be statistically different for each survey region and the national survey. 

Table 11-7: Variables Found to be Statistically Different Across Respondent and 

Non-Respondent Samples

Survey Region Variables

Northeast Gender, education

Southeast Gender, education

Pacific Importance of aquatic ecosystems, race

Inland Age, gender, education, employmenta, and income

National Survey Gender, income

a Employment was not statistically different for respondents under the age of 65.

Source: U.S. EPA analysis for this report

In general, attitudes towards the protection of aquatic ecosystems tended to be similar across 

samples for most survey regions, with a large majority of respondent rating it as important. No 

statistical difference was found in rating the protection of aquatic ecosystems among respondents 

and non-respondents, the only exception being the Pacific region. The average ranking was 

slightly higher for non-respondents than respondents in the Pacific region. The vast majority of 

participants in the non-response study also indicated that government should be at least somewhat 

involved in environmental protection.67

EPA developed for the weights for those demographic variables which were found to be 

statistically different in each region to account for over- and under- represented groups in the mail 

survey dataset used for model estimation. Section 11.6.3 describes weight development.

11.6 Random Utility Model

EPA’s analysis of the 316(b) survey data is grounded in the random utility model presented by 

Hanemann (1984) and McConnell (1990). The use of the random utility model is standard in the 

SP literature for attribute-based SP data, such as that provided by choice experiments (Bateman et 

al. 2002; Bennett and Blamey 2001). Under the model, “utility is the sum of systematic [or 

observed] and random [or unobserved] components” (Holmes and Adamowicz 2003, p. 189). The 

individual choices are systematic (i.e., deterministic) from the perspective of the individual, while 

the random component reflects preferences which are unobservable to the researcher, among 

other things(Holmes and Adamowicz 2003). The model is applied extensively within SP research, 

and allows for the calculation of well-defined welfare measures (i.e., WTP) from choice 

experiment models (Bennett and Blamey 2001; Louviere et al. 2000). This section describes 

 

67 Multiple questions in the main mail survey asked respondents about their views toward government and 

environmental protection (e.g., questions 1-5 and 1-6 on page 3 of the mail survey). However, the wording of 

these questions differed from the question included in the non-response survey, such that they are not directly 

comparable.
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EPA’s model specification (Section 11.6.1), model estimation (Section 11.6.2), approach for 

estimating weights (Section 11.6.3), and model results (Section 11.6.4).

11.6.1 Model Specification

Table 11-8 lists and defines the variables included in the random utility models. For each choice 

option, the respondent may choose Option A, Option B, or No Policy, where No Policy is 

characterized by zero change in all attributes.

Table 11-8: Summary of Variables Included in the Random Utility Models for the 

Regional and National Surveys 

Variable Variable Definition

CONSTANT Alternative specific constant (ASC) associated with No Policy, or choice of neither 

plan.

COM_FISH Score showing the overall health of commercial and recreational fish populations.

FISH_POP Score showing the estimated size of all fish populations compared to natural levels 

without human influence.

FISH_SAV Score showing the percentage point reduction in young fish lost compared to current 

levels.

AQUATIC Score showing the ecological condition of affected areas, compared to the most natural 

waters in the region.

COST The increase in annual household cost, in unavoidable price increases for products and 

services, including electricity and common household products.

Source: U.S. EPA analysis for this report
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The linear econometric specification of the model of the observable component of utility appears 

as:

v() = 0 + 1(Δfish_sav) + 2(Δcom_fish) + 3(Δfish_pop) (11-1)

+ 4(Δaquatic) + 5(cost)

This specification allows EPA to estimate the relative linear “main effects” of the four 

environmental attributes on utility. The estimated constant (0) represents utility associated with 

the relevant ASC (alternative specific constant). This is a fixed coefficient estimated within 

choice experiments that is designed to capture “systematic but unobserved information about why 

respondents chose a particular option (that is, unrelated to choice set attributes)” (Bennett and 

Blamey 2001). ASCs become statistically significant in choice experiment models when elements 

other than the independent variables, or choice attributes, in the model influence respondents’ 

choices (Kerr and Sharp 2006). Here, EPA included an ASC for No Policy; this variable takes a 

value of 1 for the No Policy option and a value of 0 for either of the two available policy options. 

Hence, 0 in this model represents the fixed utility associated with No Policy (maintaining the 

status quo), holding all other attribute changes at zero. 

Economic theory provides guidance regarding some, but not all, aspects of model specification

for mixed logit models within SP choice experiments. For example, the parameter on program 

cost is expected to have a negative sign, reflecting a positive marginal utility of income. 

Comparison of model output suggested that the greatest robustness of results is achieved when 

cost is modeled as fixed rather than random. This specification also avoids well-known 

challenges for welfare estimation associated with the specification of a random coefficient on 

program cost (Hensher and Greene 2003; Scarpa et al. 2008; Train and Weeks 2005). Coefficients 

on all variables except that on program cost (cost) are specified as random with a normal 

distribution. 

11.6.2 Model Estimation

EPA estimated the random utility models for all four regions and the national survey using 

maximum likelihood mixed logit with Halton draws. As described in Chapter 8, Halton draws, or 

“intelligent draws”, are “generated number theoretically rather than randomly and so successive 

points at any stage ‘know’ how to fill in the gaps left by earlier points” (Bhat 2001, p. 684). The 

mixed logit model is an approach for modeling preference heterogeneity based on the assumption 

that individuals’ preferences are randomly distributed and that heterogeneity in population 

preferences can be captured by estimating the mean and variance of the random parameter 

distributions (Holmes and Adamowicz 2003). As described by Henscher and Greene (2003), “the 

mixed logit model offers an extended framework within which to capture a greater amount of 

behavioral choice making. Broadly speaking, the mixed logit model aligns itself much more 

closely with reality than most discrete choice models. This is because every individual has their 

own inter-related systematic and random components for each alternative in their perceptual 

choice set(s)” (p. 170). It is a highly flexible model that “obviates the three limitations of 

standard logit by allowing for random taste variation, unrestricted substitution patterns, and 

correlation in unobserved factors over time” (Train 2009, p. 134).

The mixed logit model allows for the possibility of preference heterogeneity but cannot attach 

specific parameter values to particular individuals. That is, the model relaxes the assumption of 
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respondents being identical, which is required for multinomial logit estimation, and replaces it 

with a less restrictive assumption that respondents’ preferences follow distribution. The theory 

and methods of mixed logit modeling are well-established (Train 2009), and it has now become 

standard practice in many areas of research (Hensher and Greene 2003). These models allow for 

coefficients on attributes to be distributed across sampled individuals according to a set of 

estimated coefficients and researcher-imposed restrictions. The models are evaluated numerically 

using random draws because choice probabilities take the form of an integral over a mixing 

distribution that does not have a closed form (Train 2009). The likelihood simulation for the 

models estimated by EPA used 300 Halton (random) draws.68 Coefficients on all variables except 

that on program cost (cost) are specified as random with a normal distribution. As discussed in 

the previous section, the greatest model robustness was achieved when cost was specified as 

fixed. 

11.6.3 Approach for Estimating Weights

EPA developed weights for each region to account for the over- and under-representation of 

demographic groups in the mail survey data for each region. As described in Section 11.5.2, EPA 

statistically compared a set of key demographic characteristics across respondent and nonrespondent samples. For those characteristics which were statistically different, EPA developed 

weights such that the weight given to particular subgroup of individuals within the analyzed 

sample (sample proportion) matches the weight for the same subgroup in the overall (population 

proportion).69 EPA used data from Census 2010 and the American Community Survey (ACS) as 

the target for the desired population. 

EPA applied one of two approaches to calculate the weights assigned to each respondent in the 

mail survey dataset: (1) subgroup weighting and (2) raking. The combination of demographic 

characteristics dictated which approach was applied for a given region:

 Subgroup weighting – Applied if the population proportions for each subgroup could be 

calculated directly based on data from ACS and Census 2010. For example, the 2010 

ACS reports educational attainment by gender, the two characteristics which were 

statistically different in the Northeast and Southeast survey regions. Because separate 

proportions for males and females for educational attainment were available according to 

gender, EPA could calculate population proportions directly from the data for these 

regions. EPA also used subgroup weighting for race in the Pacific region.

 Raking – Used when the number and combination of variables are such that EPA could 

not calculate the grid of sample and population proportions directly using Census or ACS 

data. Raking uses an iterative process to match the subpopulations weights to the 

population statistics, using targets for the individual demographic characteristics of 

interest. Additional detail on raking is provided by (Izrael et al. 2004) This approach was 

 

68 EPA also ran the models with 200, 400, and 500 Halton draw to assess model robustness. They indicate that the 

models are relatively robust (stable) across different numbers of draws, for the “fish saved” attribute in particular. 

69 EPA could not develop weights for the importance of aquatic ecosystems in the Pacific region because a statistical 

target (e.g., Census for ACS data) was unavailable (adjusting would have increased WTP). EPA did not weight 

based on employment in the Inland region because employment was not statistically different for respondents 

under the age of 65 and EPA weighted for age.
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used to weight for age, gender, education, and income in the Inland region and for gender 

and income for the national survey.

11.6.4 Model Results

Mixed logit model statistics suggest good statistical fit across the regional survey versions. Table 

11-9 presents results for both linear and weighted linear models for each survey region. The 

following discussion, however, focuses on the weighted model since this model allows to correct 

for differences in demographic characteristics of respondents and general population. For the 

weighted linear models, the χ2values ranged from 483.07 to 1,119.22 (all with d.f. = 21, 

p<0.0001) and pseudo-R

2

ranged from 0.23 to 0.31 for the regional surveys. The national 

weighed linear model has a χ

2

value of 394.0 (d.f. = 21, p<0.0001) and pseudo-R

2

of 0.23. 

The variable for fish saved (fish_sav) is significant in all four regional weighted linear models, 

commercial fish populations (com_fish) is significant in two of the four regional models, and 

aquatic ecological condition (aquatic) is statistically significant in two of the four regional 

models. The significance of these attributes suggests positive implicit prices; that is, positive 

WTP for changes in individual attributes. Analogous outcomes are common in choice 

experiments across the literature addressing aquatic ecological improvements, with the substantial 

majority of choice attributes found to have statistically significant impacts (Carlsson et al. 2003; 

Do and Bennett 2009; Johnston et al. 2011a; Johnston et al. 2011b). The ASC was significant in 

three of the five models. 

As noted above, all variables except cost represent percent progress toward the upper ecological 

reference condition (100 percent). Hence, these coefficients may be directly interpreted as the 

relative marginal utility derived from a one percentage point change in each ecological attribute. 

In the estimated Southeast weighted linear model, for example, marginal utility is greatest (per 

percentage point) for increases in commercial fish populations (com_fish), with lower (but still 

statistically significant) impacts associated with changes in the number of fish saved (fish_sav). 

The percentage differences in environmental attributes across the options presented were much 

larger for the number of fish saved (fish_sav) than for the other variables. Therefore, the 

coefficients on fish_sav tend to be lower than on other environmental attributes. Following 

recommended practice in SP valuation, these variations correspond with realistic ecological and 

policy expectations for regulatory outcomes (Bateman et al. 2002). The lack of significance of 

com_fish, all_fish and aquatic in some models may be related to the relatively small changes in 

these attributes included in the survey, relative to effects on fish saved, which were much larger. 

There are only two coefficients of unexpected sign and neither is significant. 

Direct comparisons of statistical fit measures across different choice experiments in the literature 

can be misleading and should be viewed with extreme caution. Many measures of model fit are 

not directly comparable across different datasets or models. Nonetheless, the overall statistical fit 

of the model appears broadly similar to choice experiments found in the published literature 

addressing environmental improvements both worldwide and in the United States. Johnston et al. 

(2011a,b), in a similar survey of ecological improvements, report a pseudo-R

2

of 0.30. By 

comparison, using a commonly reported measure of model fit (pseudo- or McFadden R

2

), 

Campbell et al. (2009) report a pseudo-R

2

of 0.20; Carlsson et al. (2003) report pseudo-R

2

values 

between 0.12 and 0.27; Do and Bennett (2009) report pseudo-R

2

between 0.07 and 0.18; and 

Colombo and Hanley (2008) report values between 0.16 and 0.36. Other measures of fit are also 
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May 2014 11-22

similar, although again, caution must be exercised when drawing conclusions from any such 

comparisons across models. 

EPA also tested alternative models and conducted various validity tests using the survey data and 

model results. This included investigation of non-linear functional forms, including stepwise 

models and inverse hyperbolic sine (IHS) models, as it is possible that there is diminishing 

marginal WTP for fish saved. However, EPA found that model results did not improve under 

non-linear specifications. For the stepwise models, EPA coded fish saved as a set of binary 

(dummy) variables instead of a continuous variable for each survey region and results are 

intuitive. Resulting WTP across steps seems to suggest a generally linear relationship. EPA 

designed the IHS model for each survey region to capture potential nonlinearities in WTP for fish 

saved. Review of IHS results indicate that the fit and intuitiveness varies somewhat across 

models, but in general, models do not improve upon linear specification. Results for these 

alternative models are included in the 316(b) rulemaking docket. Based on these results, EPA 

used the weighted linear specification as its primary models in this report for preliminary 

assessment of WTP. The Agency also notes that with only three attribute levels (per region), it 

would be difficult to capture non-linearities in the fish saved attribute.
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Table 11-9: Linear and Weighted Linear Model Results

Variable

Coefficient a,b

(Standard Error)

Northeast Southeast Inland Pacific National

Linear Weighted 

Linear Linear Weighted Linear Linear Weighted Linear Linear Weighted Linear Linear Weighted Linear

Random parameters in utility functions

CONSTANT -0.56919 -0.52259 -0.19920 -1.63728*** -3.56478*** -3.53149*** 0.18220 0.18797 -2.09328*** -1.49361***

(0.42972) (0.37095) (0.30806) (0.33244) (0.58123) (0.56418) (0.45022) (0.49719) (0.45875) (0.48000)

COM_FISH 0.13145* 0.21316*** 0.12662*** 0.08871* 0.06082** 0.02335 0.15056** 0.11072 0.08925 0.07350

(0.06765) (0.05180) (0.04660) (0.04991) (0.02946) (0.02773) (0.07282) (0.08606) (0.06077) (0.06015)

FISH_POP 0.13602 0.06502 0.14670** -0.02800 0.02175 0.01007 0.21176* 0.16039 0.02838 0.19524*

(0.10508) (0.09369) (0.06364) (0.07830) (0.04405) (0.04182) (0.11078) (0.12739) (0.10735) (0.11069)

FISH_SAV 0.02852*** 0.02900*** 0.02183*** 0.02596*** 0.01483*** 0.01597*** 0.04389*** 0.03645*** 0.02241*** 0.02116***

(0.00537) (0.00464) (0.00462) (0.00507) (0.00439) (0.00393) (0.00698) (0.00683) (0.00585) (0.00665)

AQUATIC 0.17102 0.20135* 0.24591*** 0.06163 0.04630 0.04864 0.34171*** 0.31963** -0.12105 -0.10694

(0.10955) (0.10306) (0.07741) (0.08284) (0.05036) (0.04478) (0.11007) (0.13338) (0.11085) (0.17007)

Non-random parameters in utility functions 

COST -0.02677*** -0.02106*** -0.03868*** -0.04209*** -0.03356*** -0.03280*** -0.02756*** -0.02177 -0.03739*** -0.03294***

(0.00513) (0.00453) (0.00417) (0.00502) (0.00298) (0.00284) (0.00518) (0.00534) (0.00520) (0.00578)

Derived standard deviations for parameter distributions

sdCONSTANT 0.37257 0.19465 0.00256 0.29835 5.91389*** 5.18984*** 0.09866 0.01702 0.18221 0.08915

(1.01103) (1.01704) (4.10600) (1.20020) (0.97758) (0.89828) (1.0278) (6.00963) (2.51713) (1.29659)

sdCOM_FISH 0.43573*** 0.13635 0.26774*** 0.17567 0.12217* 0.12565** 0.30101 0.32221* 0.27147 0.30494*

(0.12740) (0.16831) (0.09727) (0.12699) (0.06487) (0.06115) (0.30183) (0.18467) (0.41960) (0.17425)

sdFISH_POP 0.51160** 0.58902*** 0.04792 0.34982 0.07409 0.12423 0.22539 0.23578 0.54531 0.64049**

(0.21996) (0.18116) (0.39545) (0.21724) (0.07769) (0.08723) (0.41340) (0.25612) (1.33621) (0.30347)

sdFISH_SAV 0.05755** 0.04375*** 0.05697*** 0.06335** 0.04838*** 0.04359*** 0.05362 0.05332*** 0.05514*** 0.08467***

(0.02241) (0.01269) (0.01339) (0.02852) (0.00615) (0.00554) (0.04330) (0.01546) (0.01773) (0.02698)

sdAQUATIC 0.61933*** 0.64976 0.45656*** 0.77220 0.44593*** 0.33881*** 0.35905 0.29608 0.81244 1.19443*

(0.22791) (0.44299) (0.12343) (0.60628) (0.08826) (0.08224) (0.57884) (0.26966) (0.53981) (0.72258)

Model significance

Model χ2

582.48 538.59 741.92 700.17 1,191.94 1,119.22 578.74 483.07 413.53 394.00

(d.f. = 21, 

p<0.0001)

(d.f. = 21, 

p<0.0001)

(d.f. = 21, 

p<0.0001)

(d.f. = 21, 

p<0.0001)

(d.f. = 21, 

p<0.0001)

(d.f. = 21, 

p<0.0001)

(d.f. = 21, 

p<0.0001)

(d.f. = 21, 

p<0.0001)

(d.f. = 21, 

p<0.0001)

(d.f. = 21, 

p<0.0001)

Pseudo-R

2

0.24 0.23 0.24 0.24 0.25 0.24 0.32 0.31 0.24 0.23

a

For random parameters in utility functions, coefficients represent the estimated means of random parameter distributions.

b

***, **, * indicates significance at 1%, 5%, 10% levels, respectively.

Source: U.S. EPA analysis for this report
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11.6.5 Validity Tests

Generally accepted economic thinking maintains that obtaining greater quantities of a desired 

economic good will lead to higher levels of consumer utility (Heberlein et al. 2005). A scope test 

looks at whether respondents’ WTP is greater for (or not less than) a good that is somehow larger, 

either in a quantitative or qualitative sense. There are two types of scope tests. An internal scope 

(or within-sample) test involves comparing multiple WTP estimates from SP responses collected 

from the same respondents” while an external scope test “employs split-sample designs to 

compare WTP estimates across samples from the sample population” (Lew and Wallmo 2011). A 

major criticism of stated preference studies had been that this relationship – consumers preferring 

greater quantities of a good over lesser quantities of that same good– is sometimes violated when 

valuating environmental amenities. Evidence provided by these early findings prompted the 1993 

NOAA Panel on Contingent Valuation to regard surveys that exhibit insensitivity to scope as 

“unreliable” (Arrow et al. 1993). Compared to tests of scope in contingent valuation, the role of 

external scope tests within choice modeling has received much less attention in the literature (cf., 

Heberlein et al. 2005). 

Unlike open-ended contingent valuation questions, choice experiments provide a direct 

mechanism for respondents to react to the scope and scale of resource changes, by enabling 

respondents to compare policy options with different levels for each attribute. As noted by 

Bennett and Blamey (2001, p. 231), “internal scope tests are automatically available from the 

results of a [choice modeling] exercise.” That is, choice experiments already include “internal” 

scope tests because respondents compare levels across Options A and B. Respondents express 

WTP for incremental improvements in environmental attributes through their selection of No 

Policy, Option A, or Option B within the choice questions and model results indicate that WTP is 

higher for an option with a greater level of goods. Within a choice modeling context, external 

scope tests may also be confounded by differences in the implied choice frame (Bennett and 

Blamey 2001). These caveats aside, an external scope test can provide some additional insight 

into response patterns, and some researchers view these tests as a “stronger” form of validation 

than internal scope tests. EPA therefore implemented a form of external scope tests to evaluate 

this form of validity using the mail survey data for each survey region. As the experimental 

design was not originally conceived to allow formal tests of external scope, the following test is 

illustrated as an alternative approach that is possible given the current experimental design and 

available data.70

EPA used a split sample to look at respondents’ selections for Options A and B separately and 

obtain a more “external” perspective based on the concept that, if all else is orthogonal 

(effectively equal), a choice option with more fish saved should be chosen more often than a 

choice option with fewer fish saved. Splitting out Options A and B provides a more convincing 

test, because it shows that the same patterns apply to both Options A and B. EPA limited the test 

to the fish saved attribute because fish saved is the only attribute that EPA is using at this time to 

estimate WTP for regulatory options. To distinguish this test from the “internal” scope tests 

automatically performed by choice experiments, it is implemented using a split sample of choice 

options viewed in isolation. To implement the test, EPA first created a dataset only of 

 

70 External scope tests were recommended for contingent valuation studies (Arrow et al. 1993). Because scope tests 

are automatically available from the results of a choice modeling exercise (Bennett and Blamey (2001, p. 231), 

accounting for external scope tests in the experimental design was not necessary. 
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observations on Option A for all survey responses, along with a dummy (0-1) variable indicating 

whether that option was chosen.71 EPA then further split this sample into three sub-samples based 

on the three levels of fish saved assigned to each region within the experimental design. Using the 

Pacific region as an example, the three sub-samples are: (1) observations on Option A when 

percent fish saved = 95 percent, (2) observations on Option A when percent fish saved = 50 

percent, and (3) observations on Option A when percent fish saved =2 percent. Because of the 

near orthogonal nature of the experimental design, all other attribute levels should be 

approximately equal across each of these three sub-samples. Given this split sample, EPA 

expected to observe the greatest proportion of respondents choosing Option A in sub-sample (1), 

followed by sub-sample (2) and then (3). This order would establish external sensitivity to scope. 

EPA then repeated the same test for Option B.

The results of the scope sensitivity test are presented in Table 11-10. The results tables illustrate 

means and standard deviations for respondent choices for each observation of Option A and 

Option B. The external scope tests for split samples of both Options A and B demonstrate scope 

sensitivity for all survey regions, as indicated by economic theory. The values of other choice 

attributes (com_fish, fish_pop, aquatic, and cost) are approximately equal over the split samples, 

as one would expect given the experimental design. The proportion of respondents choosing 

Option A declines as the percentage of fish declines for all survey regions. Using the Inland 

region as an example, the proportion of respondents choosing Option A declines from 0.42 to 

0.39 to 0.37 as the percentage of fish saved declines from 95 percent to 75 percent to 55 percent. 

Option B exhibits a similar decline in respondent choice with fish saved all survey regions. EPA 

used the χ2test of proportions to examine whether the proportions were statistically different 

across levels of fish saved for a given option. The null hypothesis of equality in proportions is 

rejected at p<0.10 for all regions and options. This shows that respondent choices were 

statistically different across levels of fish saved.

EPA also conducted further testing with the responses split by survey question as well as option 

to respond to the external peer review. Using this approach, each question/option sample includes 

only one choice from each respondent. The null hypothesis of equality in proportion is rejected at 

p<0,10 or better for 22 of the 30 cases (5 survey versions x 3 questions x 2 options = 30). EPA 

did not generate the survey experimental design with such tests in mind, so the combination of 

other choice attributes (com_fish, fish_pop, aquatic, and cost) vary somewhat across cases when 

split by question and option, which would affect the results of this scope test in a systematic 

fashion. Overall, results indicate sensitivity to scope for fish saved.

 

71 Thus, each respondent is represented up to three times, once for each choice question in their survey booklet.
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Table 11-10: Results of the Split-Sample External Validity Test for Each Survey Region

Region/ Percent Fish Saved

Option A Option B

Mean Std. Dev. Mean Std. Dev.

Northeast

95% 0.4617 0.4992 0.4861 0.5004

50% 0.4274 0.4954 0.4415 0.4973

5% 0.2473 0.4320 0.2345 0.4243

χ

2 Test of Proportionsa 42.43

(d.f.=2; p<0.001)

58.81

(d.f.=2; p<0.001)

Southeast

90% 0.4796 0.5001 0.4000 0.4904

55% 0.3593 0.4803 0.2939 0.4560

25% 0.2922 0.4553 0.2602 0.4392

χ

2 Test of Proportionsa 35.58

(d.f.=2; p<0.001)

23.29

(d.f.=2; p<0.001)

Inland

95% 0.4225 0.4943 0.3679 0.4825

75% 0.3897 0.4880 0.3234 0.4681

55% 0.3652 0.4818 0.2712 0.4449

χ

2 Test of Proportionsa 5.00

(d.f.=2; p<0.082)

15.77

(d.f.=2; p<0.001)

Pacific

95% 0.4929 0.5008 0.5993 0.4909

50% 0.3722 0.4843 0.4118 0.4931

2% 0.1932 0.3955 0.2333 0.4237

χ

2 Test of Proportionsa 53.89

(d.f.=2; p<0.001)

76.63

(d.f.=2; p<0.001)

National

95% 0.4753 0.5003 0.4604 0.4994

55% 0.3571 0.4801 0.3013 0.4598

25% 0.3269 0.4700 0.2737 0.4466

χ

2 Test of Proportionsa 13.60

(d.f.=2; p<0.001)

24.06

(d.f.=2; p<0.001)

a The null hypothesis is that the proportion of respondents choosing an option is equal for all percentage fish saved.

Source: U.S. EPA analysis for this report

11.7 Estimation of Implicit Prices and WTP

EPA used the results of the random utility models presented in Table 11-9 to estimate the implicit 

price or marginal annual WTP for a one percentage point change in each of the four 

environmental attributes within each survey region. This represents WTP per household, per year, 

for a one percentage point change in the corresponding choice model attribute. For example, one 

could calculate the marginal WTP for each additional percentage increase in fish saved, holding 

all else constant. If utility is modeled as a linear function of attributes, implicit prices may be 

calculated as IPa = ⁄ , where βa is the estimated coefficient on an environmental attribute 

(e.g., change in fish saved), and βn is the coefficient on program cost. Assuming a linear 
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May 2014 11-27

preference function as estimated above, compensating surplus (or household WTP) for any given 

policy option may be calculated as:72

WTP =   (11-2)

 

where the delta ( ) represents a change in the attribute in question. That is, total WTP for a policy 

change is calculated as the sum of the product of implicit prices and corresponding attribute 

changes. Once a preference function is estimated, the decision to include or exclude the ASC 

(constant) in subsequent welfare estimation must be made on a case-by-case basis; economic 

theory alone is insufficient to determine this choice.73 In this case, EPA excludes the ASC when 

calculating compensating surplus, because by definition it reflects anticipated utility change 

unrelated to the included model attributes. Section 11.8 includes additional discussion of EPA’s 

treatment of the ASC when analyzing regulatory benefits. 

EPA notes that ecological systems are typically characterized by correlation among many 

processes and outcomes. In the context of IM&E, for example, a reduction in A1E losses 

(fish_sav) may be correlated with changes in fish populations (fish_pop), aquatic ecosystem 

condition (aquatic), and commercial fish populations (com_fish). It would have been difficult to 

determine which attribute(s) caused respondents to choose one scenario over another had the SP 

survey scenarios incorporated the same correlations. For example, if it were the case that large 

reductions in IM&E always accompany large positive effects on fish populations and large 

positive effects on ecosystem condition and these correlations were embedded within survey 

scenarios, it would have been difficult to estimate the specific influence of each attribute on 

respondents’ choices. 

The experimental design used in the SP survey breaks this correlation and allows different survey 

attributes to vary independently. This enables different respondents to view many different 

possible policy outcomes, each with different combinations of fish_sav, fish_pop, aquatic and 

com_fish. While some of the resulting scenarios might be unlikely in actual aquatic systems, they 

are not ecologically impossible. For example, the experimental design allows respondents to 

consider scenarios in which large reductions in fish losses accompany very small changes in fish 

populations and aquatic condition (positive changes in fish_sav in some questions are also paired 

with no change in the population or aquatic condition metrics). Because attributes vary 

independently across the 72 different choice questions presented to respondents in each survey 

region and national survey, it is possible to estimate the unique effects of each attribute on 

individuals’ choices and therefore, values. By breaking the correlation between these attributes 

present in ecosystems, the choice experiment design allows estimation of the independent effect 

of each attribute on choices and WTP. The environmental attributes have almost zero correlation 

in the resulting experimental design. This allows WTP for each ecological effect to be estimated, 

independent from all other effects. Based on recommendations from external peer reviewers, EPA 

is currently conducting additional analysis to assess the robustness of fish saved under alternative 

treatments of the other environmental attributes.

 

72 EPA excluded the ASC when estimating the benefits of regulatory options because there is no clear theoretical 

reason for inclusion. The magnitude and sign of the coefficient on ASC varies across regions. 

73 The treatment of the ASC is discussed by Adamowicz et al. (1998) and Morrison et al. (2002), among others.
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Because the mixed logit model includes random coefficients, EPA estimates implicit prices using 

the welfare simulation approach of Johnston and Duke (2007; 2009) following the framework 

outlined by Hensher and Greene (2003). The procedure begins with a parameter simulation 

following the parametric bootstrap of Krinsky and Robb (1986), with R=1,000 draws taken from 

the mean parameter vector and associated covariance matrix. For each draw, the resulting 

parameters are used to characterize asymptotically normal empirical densities for fixed and 

random coefficients. For each of these R draws, a coefficient simulation is then conducted for 

each random coefficient, with S=1000 draws taken from simulated empirical densities. Here, all 

coefficient simulations draw from a normal distribution except for that on cost, which is fixed.

EPA calculated WTP measures for each draw, resulting in a combined empirical distribution of 

R×S observations from which summary statistics were derived. All implicit prices are modeled as

the WTP for a one percentage point change in the ecological attribute, all else being constant.

The resulting mean implicit prices and 90 percent confidence intervals for the ASC (constant) and 

environmental attributes in each region are presented in Table 11-11. The point estimates for

implicit prices tend to be larger for commercial fish populations, fish populations (all fish), and 

aquatic ecosystem condition than for fish saved, although the statistical significance of these point 

estimates varies. This is not surprising given the relatively narrow range over which these 

attributes vary. Hence, some point estimates that appear large may not be statistically significant, 

and vice versa. In the Pacific for example, households value a one percentage point increase in 

commercial fish populations or aquatic ecosystem condition about three or eight times, 

respectively, the value of a one percentage point increase in fish saved. The mean implicit prices 

for a 1 percent improvement in fish saved under the regional weighted linear models range from 

$0.50 in the Inland region to $1.77 in the Pacific region. The mean implicit price based on the 

national survey is $0.66. Peer reviewers indicated that EPA should focus on the regional over the 

national survey results because of concerns regarding the smaller size and representativeness of 

the national sample. EPA included implicit prices based on the national survey for illustrative 

purposes.

EPA did not use the national survey results in its analysis of regulatory options. EPA found that 

the implicit price for fish saved was relatively robust (stable) across mixed logit models with 200, 

400, and 500 Halton draws. These additional model results are included in the 316(b) rulemaking 

docket. Although the discussion in this section refers to WTP for a percentage point increase in 

fish saved, it is important to note that this variable represents a one percentage point reduction 

relative to the level of baseline mortality (e.g., the Northeast survey booklet indicated a baseline 

loss of 1.1 billion fish). This relationship between the percentage point reduction and cardinal fish 

losses was specified clearly in survey questions, and the same relationship was maintained 

throughout each survey . WTP per percentage point reduction reflects a specific quantity of fish 

saved, rather than a general relative reduction of one percent from an unspecified level of IM&E. 

The regional and national surveys have different baseline fish losses. EPA expected survey 

responses to vary across the regions, because residents might have different values and baseline 

losses differ.
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Table 11-11: Estimated Implicit Prices for a Once Percentage Point Change in Each 

Attribute, WTP per Household, per Year (2011$)a

Survey Version and Environmental 

Attribute 5

th Mean 95th

Northeast

Commercial Fish Populations (COM_FISH) $6.45 $10.30 $14.86

Fish Populations (all fish) (FISH_POP) -$4.53 $3.09 $10.89

Fish Saved (FISH_SAV) $0.95 $1.44 $2.07

Aquatic Ecosystem condition (AQUATIC) $1.44 $9.76 $19.01

Southeast

Commercial Fish Populations (COM_FISH) $0.16 $2.10 $4.11

Fish Populations (all fish) (FISH_POP) -$3.81 -$0.69 $2.48

Fish Saved (FISH_SAV) $0.42 $0.62 $0.83

Aquatic Ecosystem condition (AQUATIC) -$2.01 $1.43 $4.75

Inland

Commercial Fish Populations (COM_FISH) -$0.67 $0.69 $2.08

Fish Populations (all fish) (FISH_POP) -$1.83 $0.28 $2.48

Fish Saved (FISH_SAV) $0.28 $0.50 $0.70

Aquatic Ecosystem condition (AQUATIC) -$0.78 $1.47 $3.68

Pacific

Commercial Fish Populations (COM_FISH) -$1.37 $5.37 $13.60

Fish Populations (all fish) (FISH_POP) -$2.32 $7.71 $18.53

Fish Saved (FISH_SAV) $1.07 $1.77 $2.62

Aquatic Ecosystem condition (AQUATIC) $5.01 $15.32 $27.48

National

Commercial Fish Populations (COM_FISH) -$0.81 $2.22 $5.50

Fish Populations (all fish) (FISH_POP) $0.41 $5.82 $11.28

Fish Saved (FISH_SAV) $0.28 $0.66 $1.07

Aquatic Ecosystem condition (AQUATIC) -$12.30 -$3.52 $5.20

a The implicit prices are per percentage point increase from the specified baseline (reference) levels for each survey. 

Source: U.S. EPA analysis for this report

While 95 percent confidence intervals are rather large for com_fish, fish_pop, and aquatic, and 

sometimes include zero in the range, the confidence intervals are rather narrow for fish saved and 

do not include zero within the 95 percent confidence interval. This highlights a very specific 

result of the stated preference survey, which is that the WTP to protect fish and shellfish from 

impingement and entrainment, even when there are no effects on the other attributes, is greater 

than zero. This is the case despite the vociferous objections of some commenters opposed to the 

stated preference survey. To be clear, these benefit estimates represent an average WTP for 

protecting fish and shellfish from impingement and entrainment and incorporate the responses of 

all respondents, including those who expressed zero WTP .74

11.8 Method for Estimating Regional Benefits

EPA used the implicit prices, or WTP per percentage point change, for fish saved (fish_sav) to 

estimate annual monetized benefits for each survey region under the final rule and regulatory 

options considered. EPA did not estimate changes or potential benefits associated with changes in 

the other three environmental attributes. EPA’s focus on the fish saved attribute for benefits 

estimation is consistent with recommendations from external peer reviewers. Peer reviewers 

 

74 About 17 percent of survey respondents selected No Policy (i.e., zero WTP) for all three choice questions.
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indicated that using fish saved exclusively for benefits estimation helps to alleviate concerns 

regarding overlaps in the definitions of environmental attributes and potential interactions 

between environmental attributes which are not accounted for in the main effects experimental 

design. It also allays concerns with the degree of ecological uncertainty involved in the modeling 

and prediction of effects on fish populations and aquatic ecosystems.

For each survey region, EPA calculated annual household WTP under regulatory options by 

multiplying the estimating percentage change in fish saved by the regional implicit price for fish 

saved from Table 11-11. As noted above, EPA did not include the implicit price on the ASC 

within the benefits calculation. Once a preference function is estimated, the decision to include or 

exclude the ASC in subsequent welfare estimation must be made on a case-by-case basis; 

economic theory alone is insufficient to determine this choice (Adamowicz et al. 1998; Morrison 

et al. 2002). By excluding the ASC here (and other ecological attributes), EPA is presenting a 

clean estimate of WTP for fish saved alone, without other actual or possibly speculated benefits 

associated with reductions in IM&E. This approach is consistent with peer review comment that 

the exclusion of the ASC “...is not a problem for the annual household WTP estimated provided 

in the report for the regulatory options since these are calculated using only the marginal WTP for 

a one unit change in fish saved” (Applied Planning Corporation 2012, p. 34). 

Total annual WTP for fish saved under each regulatory option is calculated by multiplying annual 

household WTP by the number of household in the region from Census 2010. EPA then 

discounted and annualized regional WTP using discount rates of 3 and 7 percent. Refer to 

Appendix D for additional regarding discounting and the compliance schedule. As stated 

previously, the boundaries of the SP survey regions differ slightly from the proposed rule regions. 

Because regional IM&E is a function of operational intake flow, EPA accounted for differences 

in regional boundaries by adjusting the proposed rule compliance schedule based on state-level 

AIF data by waterbody type (i.e., coastal/estuarine or freshwater).

11.9 Results for the Final Rule and Regulatory Options Considered

As noted previously, EPA considers it premature to include the SP survey results in the 

quantitative comparison of costs and benefits prior to completion of the SAB review. This section 

presents preliminary benefits for the final rule and options considered to illustrate the potential 

magnitude of regulatory benefits and demonstrate progress towards this effort. 

Table 11-12 presents IM&E, percent fish saved, and WTP per household by regulatory option. 

Percent fish saved and mean household WTP for the final rule vary across regions, from less than 

one percent and less than $1 in the Pacific region to 56 percent and $28 in the Inland region. 

Percent fish saved and WTP per household are lower than the final rule under Proposal Option 4 

and greater under Proposal Option 2.

Table 11-13 presents annualized benefits by regulatory option using both 3 percent and 7 percent 

discount rates. Total benefits under the final rule for all survey regions are $1.4 billion using a 3 

percent discount rate and $1.1 billion using a 7 percent discount rate. Around half of the total 

benefits under the final rule are from the Inland Survey region. Total benefits under Proposal 

Option 4 are slightly less than the final rule using both 3 percent and 7 percent discount rates. 

Total benefits for Proposal Option 2 are $3.4 billion and $2.3 billion using 3 percent and 7 

percent discount rates, respectively, and are greater than benefits under both Proposal Option 4 

and the final rule.
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Table 11-12: Reduction in A1E Losses, Percent Fish Saved and WTP per Household 

(2011$) by Survey Region for the Final Rule and Options Considered

Survey Version and 

Regulatory Option

IM&E WTP per Household

Reduction in 

A1E Losses 

(in millions)

Fish Saved 

(%)a 5

th Mean 95th

Northeast

Proposal Option 4 45.45 5.61% $5.31 $8.06 $11.62

Final Rule 48.86 6.03% $5.71 $8.66 $12.49

Proposal Option 2 512.53 63.23% $59.91 $90.89 $130.99

Eliminating Baseline IM&Eb594.73 73.37% $69.51 $105.47 $152.00

Southeast

Proposal Option 4 218.96 29.92% $12.49 $18.69 $24.96

Final Rule 228.54 31.23% $13.04 $19.51 $26.06

Proposal Option 2 544.48 74.41% $31.06 $46.47 $62.08

Eliminating Baseline IM&Eb663.79 90.72% $37.87 $56.66 $75.68

Inland

Proposal Option 4 348.47 51.98% $14.53 $25.74 $36.46

Final Rule 373.25 55.68% $15.56 $27.57 $39.05

Proposal Option 2 547.85 81.72% $22.85 $40.46 $57.31

Eliminating Baseline IM&Eb619.58 92.42% $25.84 $45.76 $64.82

Pacificc

Proposal Option 4 1.28 0.37% $0.40 $0.66 $0.97

Final Rule 1.36 0.39% $0.42 $0.69 $1.03

Proposal Option 2 32.63 9.40% $10.03 $16.65 $24.59

Eliminating Baseline IM&Eb52.87 15.23% $16.25 $26.97 $39.84

a When calculating percent fish saved, EPA used a baseline which reflected current technology at regulated facilities 

including those facilities in CA and NY that are subject to state regulations. This differs from the rest of the benefits 

analysis, where EPA assigns these facilities baseline IM&E reductions commensurate with technologies required by the 

state regulations. This approach is consistent with the survey materials which were based on total IM&E. Fish saved under 

the elimination of baseline IM&E can be less than 100 percent because EPA does attribute IM&E reductions at facilities 

subject to state regulations to the existing facilities rule.

b This hypothetical scenario reflects the benefits that would be achieved if all IM&E were eliminated.

c The calculation of Fish Saved (%) for the Pacific survey region includes reductions in A1E losses at Hawaii facilities.

Source: U.S. EPA analysis for this report
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Table 11-13: Annualized Monetized Benefits (millions of 2011$)

Survey Version and 

Regulatory Option

3 % Discount Rate 7 % Discount Rate

5

th Mean 95th 5th Mean 95th

Northeast

Proposal Option 4 $90.6 $137.4 $198.1 $69.8 $105.9 $152.7

Final Rule $97.4 $147.8 $212.9 $75.0 $113.9 $164.1

Proposal Option 2 $824.0 $1,250.1 $1,801.7 $535.6 $812.7 $1,171.2

Eliminating Baseline 

IM&Ea $1,545.1 $2,344.2 $3,378.6 $1,537.4 $2,332.5 $3,361.7

Southeast

Proposal Option 4 $297.1 $444.5 $593.7 $229.6 $343.6 $458.9

Final Rule $310.2 $464.0 $619.8 $239.7 $358.7 $479.1

Proposal Option 2 $634.4 $949.1 $1,267.8 $422.9 $632.8 $845.2

Eliminating Baseline 

IM&Ea $1,167.4 $1,746.6 $2,333.0 $1,161.6 $1,737.8 $2,321.3

Inland

Proposal Option 4 $436.7 $773.4 $1,095.6 $339.5 $601.2 $851.7

Final Rule $468.0 $828.8 $1,174.0 $363.8 $644.2 $912.6

Proposal Option 2 $603.1 $1,068.2 $1,513.1 $414.3 $733.7 $1,039.3

Eliminating Baseline 

IM&Ea $1,006.9 $1,783.3 $2,526.1 $1,001.9 $1,774.3 $2,513.5

Pacificb

Proposal Option 4 $4.7 $7.8 $11.5 $3.7 $6.1 $9.0

Final Rule $5.0 $8.2 $12.1 $3.9 $6.5 $9.5

Proposal Option 2 $98.3 $163.2 $241.0 $69.5 $115.4 $170.4

Eliminating Baseline 

IM&Ea $251.8 $418.0 $617.3 $250.6 $415.9 $614.2

Total for Regional Surveys

Proposal Option 4 $829.1 $1,363.1 $1,898.8 $642.6 $1,056.8 $1,472.2

Final Rule $880.5 $1,448.8 $2,019.0 $682.5 $1,123.2 $1,565.3

Proposal Option 2 $2,159.9 $3,430.7 $4,823.7 $1,442.4 $2,294.5 $3,226.1

Eliminating Baseline 

IM&Ea $3,971.3 $6,292.0 $8,854.9 $3,951.4 $6,260.5 $8,810.6

a This hypothetical scenario reflects the benefits that would be achieved if all IM&E were to be eliminated.

b The calculation of benefits for the Pacific survey region excludes households in Hawaii because Hawaii households were not 

included in the mail survey sample.

Source: U.S. EPA analysis for this report

11.10 Uncertainties

SP methods have “... been tested and validated through years of research and are widely accepted 

by ... government agencies and the U.S. courts as reliable techniques for estimating non-market 

values” (Bergstrom and Ready 2009, p. 26). OMB’s Circular A-4 notes that SP results “have also 

been widely used in regulatory analyses by Federal agencies” (USOMB 2003, p. 22). EPA’s own 

peer-reviewed Guidelines for Preparing Economic Analysis (USEPA 2010a) indicate that the use 

of SP study data, when the study is conducted properly in accord with best current practices, is 

the only potential method for monetizing non-use values. However, EPA recognizes that 

controversy remains over the use of stated preference results in benefit-cost analysis for 

rulemaking, at least in this particular instance. Consistent with established best practices for SP
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surveys, EPA has sought to minimize possible biases by careful and thorough construction and 

testing of the survey instrument.

While in EPA’s view, the study incorporates current best professional practice in the conduct of 

SP studies, EPA acknowledges that the results of any empirical study depend on the methodology 

applied. The Agency recognizes that potential biases may still remain and may influence the 

results of the study. The magnitude and direction of any effects on benefits estimates is unknown. 

Refer to the “Peer Review Report – 316(b) Stated Preference Survey Report Document (Final 

Submission)” (Applied Planning Corporation 2012) in the 316(b) rulemaking docket for 

additional detail on the external peer review process and peer reviewer comments. EPA notes that 

its analysis of the survey data and models is ongoing. EPA plans to obtain SAB review of the SP

survey EPA conducted. SAB review will provide additional high caliber, independent 

professional judgment concerning the quality of the survey done to date, including possible 

improvements EPA could make. EPA is also seeking SAB input on whether, how, and in what 

circumstances this or similar surveys could be used, as support for national rulemakings or 316(b) 

NPDES.
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12 Analysis of New Units at Existing Facilities

12.1 Introduction

In addition to the analysis presented in the preceding chapters for existing units at regulated 

facilities, EPA analyzed benefits for new units at existing facilities. The new unit provision of the 

final rule applies to newly constructed electric power generating units at existing facilities and 

repowering of existing generating units where the turbine and condenser are replaced. Unlike the 

case for the existing unit provision, EPA cannot predict the facilities at which such new or 

repowered units will be constructed, or the number and size of new or repowered units that will 

be constructed. Instead, EPA estimated the potential coverage of the new unit provision of the 

final rule based on the quantity of electric power generating capacity that will be installed and 

subject to the new unit provision in future years. In addition, EPA considered a range of options 

for the final rule’s new unit provision, each of which would cover a different quantity of new 

units capacity.

 Option A: Entrainment performance requirements for all stand-alone new units and all 

types of repowered units.

 Option B: Entrainment performance requirements for all stand-alone new units, and 

replaced or repowered units in which turbine or condenser are newly built or replaced.

 Option C: Entrainment performance requirements for all stand-alone new units, and 

repowered new units where the turbine and condenser are newly built or replaced, but 

excluding high efficiency systems.

 Final Rule – New Units (Option D): Entrainment performance requirements for all 

stand-alone new units only.

This chapter presents EPA’s benefits analysis under the final rule and options considered for new 

units. Section 12.2 presents EPA’s analysis of IM&E reductions and associated benefits. Section 

12.3 presents EPA’s analysis of GHG emissions reductions and associated benefits. Section 12.3 

summarizes monetized benefits for new units including benefits associated with IM&E reductions 

and GHG emissions reductions. Refer to Chapter 8 of the Technical Development Document 

(TDD) for additional information on the engineering analysis for new units.

12.2 Analysis Approach and Benefits for IM&E Reductions at New Units

EPA’s methodology for estimating IM&E reductions at existing units involves extrapolating 

facility-specific data to other existing facilities within the same region. EPA could not apply the 

existing units methodology directly to new units because facility-specific information is 

unavailable for new units. Instead, EPA estimated per mgd IM&E reductions and the monetary 

value of benefits for new units based on the analysis of existing units.

12.2.1 Flow Reductions at New Units

The engineering analysis provided the annual reduction in intake flow at CWIS nationally under 

the final rule and options considered for new units. The annual flow reductions are cumulative 

over the analysis period. For example, an annual flow reduction of 10 mgd would mean a 
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May 2014 12-2

reduction of 10 mgd in year 1, 20 mgd (10 mgd × 2) by year 2, 30 mgd (10 mgd × 3) by year 3, 

and so on. The flow reductions are projected to begin in 2014 and end in 2059, the final year of 

the compliance period. The peak, or maximum, flow reduction is the flow reduction achieved in 

2059. EPA included a declining profile at the end of the compliance period for recreational and 

commercial fishing, nonuse, and T&E species benefits consistent with the analyses for existing 

units. 

Table 12-1 presents the estimated annual and peak flow reductions at new units under the final 

rule and options considered for new units. The final rule will result in an annual flow reduction of 

68 mgd, with a total peak flow reduction of 3,128 mgd nationally in 2059. Refer to Appendix D 

for additional discussion of the compliance schedule.

Table 12-1: Flow Reductions for New Units Under the Final Rule for New Units and 

Options Considered (mgd)

Option Annual Flow Reduction Peak Flow Reduction

Option A 1,282 58,972

Option B 462 21,252

Option C 68 3,128

Final Rule – New Units 7 322

Source: U.S. EPA analysis for this report

12.2.2 IM&E Reductions and Associated Benefits per MGD

EPA calculated the reduction in IM&E per mgd of flow reduction nationally by dividing 

estimated baseline IM&E losses at existing facilities by baseline weighted AIF (in mgd). EPA 

also calculated benefits per mgd by dividing the monetized value of baseline IM&E losses by 

baseline weighted AIF (in mgd). EPA calculated separate per mgd values by loss mode 

(impingement mortality versus entrainment) in order to account for differences in baseline IM 

technology across new and existing units. EPA assumed that, in the absence of the rule for new 

units, baseline best professional judgment requirements imposed by permitting authorities for 

once-through cooling would be equivalent to modified Ristroph screens or intake velocity of 0.5 

feet per second.

Table 12-2 presents the annual IM&E reductions per mgd and Table 12-3 presents annual benefits 

per mgd, both by loss mode. The benefits values underlying Table 11-3 are based on benefits 

estimation methods described in the Chapter 5 through 8. EPA notes that these are partial benefits 

estimates for the final rule and options considered because EPA was unable to estimate nonuse 

benefits for five of seven regions using the benefits transfer approach described in Chapter 8.

Table 12-4 presents annual benefits per mgd by loss mode based on EPA’s SP survey.75 As 

discussed in Chapter 11, EPA does not include benefits estimates based on the SP survey in its 

quantitative comparison of benefits and costs for the final rule. The survey values are presented 

here for illustrative purposes. EPA also notes the SP survey was designed to assess existing, 

rather than new units. All values and maps presented in the survey reflected only existing units.

 

75 Per mgd values for the SP survey were calculated using the sum of regional survey versions.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 12: Analysis of New Units

May 2014 12-3

EPA calculated IM&E reductions and benefits for each year of the analysis period by multiplying 

the IM flow reduction and E flow reduction in that year by the respective “per mgd” values. EPA

summed across loss modes to generate total IM&E reductions and benefits for each year. EPA 

discounted and annualized benefits using 3 percent and 7 percent discount rates.

Table 12-2: Annual IM&E Reductions per MGD of Flow Reduction for New Units 

by Loss Modea

IM&E 

Loss Mode

A1E per mgd Commercial and 

Recreational Harvest 

Forage Species (fish per mgd)

Commercial and 

Recreational Species All Species

IM 4,340 712 5,052 133

E 4,069 1,922 5,991 175

Notes:

IM = impingement mortality; E = entrainment; A1E = age-one equivalent; mgd = millions of gallons per day

aEPA calculated the reduction in IM&E per mgd of flow reduction nationally by dividing estimated baseline IM&E 

losses at existing facilities by baseline weighted AIF (in mgd).

Source: U.S. EPA analysis for this report

Table 12-3: Annual Benefits per MGD of Flow Reduction for New Units by Loss Mode 

(2011$)a

IM&E Loss 

Mode

Recreational

Commercial T&E Nonuse

Low Mean High

IM $112 $216 $426 $11 $5 $4

E $173 $304 $551 $41 $3 $562

Notes:

IM = impingement mortality; E = entrainment

a EPA calculated benefits per mgd by dividing the monetized value of baseline IM&E losses at existing facilities by baseline 

weighted AIF (in mgd).

b Benefits presented in this table do not include benefits associated with changes in greenhouse gas emissions.

Source: U.S. EPA analysis for this report

Table 12-4: Annual Benefits per MGD of Flow Reduction for New Units 

by Loss Mode based on the SP Survey (2011$)a

IM&E Loss 

Mode 5th Percentile Mean 95th Percentile

IM $9,117 $15,042 $20,950

E $15,142 $23,464 $33,214

Notes:

IM = impingement mortality; E = entrainment

a EPA calculated benefits per mgd based on the SP survey by dividing the estimated value of baseline 

IM&E losses at existing facilities by baseline weighted AIF (in mgd).

Source: U.S. EPA analysis for this report

12.2.3 IM&E Reductions and Associated Benefits under the final Rule and Options 

Considered for New Units

Table 12-5 summarizes national IM&E reductions under the final rule for new units and options 

considered. IM&E reductions will increase throughout the compliance period. The values 

presented in Table 12-5 reflect the peak reduction achieved in 2059, the final year of the 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 12: Analysis of New Units

May 2014 12-4

compliance period. The final rule for new units will result in a peak reduction of about 2.3 million 

A1E. 

Table 12-5: National IM&E Reductions under the Final Rule and Options Considered for 

New Unitsa

Regulatory 

Option

A1E (in millions) Commercial and 

Recreational Harvest 

(millions of fish) Forage Species Commercial and 

Recreational Species All Species

Option A 303.94 123.86 427.81 12.28

Option B 109.53 44.64 154.17 4.43

Option C 16.12 6.57 22.69 0.65

Final Rule -

New Units 1.66 0.68 2.34 0.07

Notes:

A1E = age-one equivalent

a The IM&E reductions presented in this table reflect the peak reduction achieved in 2059, the final year of the compliance period.

Source: U.S. EPA analysis for this report

Table 12-6 presents national annualized benefits under the final rule and options considered for 

new units based on the benefits estimation methods described in Chapters 5 through 8. Mean 

annualized benefits under the final rule for new units will be $0.1 million using a 3 percent 

discount rate and less than $0.1 million using a 7 percent discount rate. Annualized benefits under 

other options considered for new units range from $1.1 to $21.4 million using a 3 percent 

discount rate and $0.8 to $14.5 million using a 7 percent discount rate. 

Table 12-7 presents national benefits for new units based on the results of the SP survey. Using 

the SP survey, mean annualized benefits under the final rule for new units would be$3.3 million 

using a 3 percent discount rate and $2.3 million using a 7 percent discount rate. Mean annualized 

benefits under other options considered for new units range from $31.6 to $596.7 million using a 

3 percent discount rate and from $22.4 to $423.1 million using a 7 percent discount rate. As noted 

above, EPA has presented benefits estimates based the SP survey for illustrative purposes and 

does not include values based on the SP survey in its quantitative comparison of costs and 

benefits for the rule.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 12: Analysis of New Units

May 2014 12-5

Table 12-6: National Annualized Benefits for IM&E Reductions under the Final Rule and Options Considered for 

New Units (2011$, 1,000s)

Regulatory Option

Recreational

Commercial T&E Nonuse

Total Benefits

Low Mean High Low Mean High

3% Discount Rate

Option A $4,138.2 $7,370.2 $13,553.0 $893.6 $90.7 $13,077.4 $18,199.9 $21,431.9 $27,614.7

Option B $1,491.3 $2,656.0 $4,884.1 $322.0 $32.7 $4,712.8 $6,558.8 $7,723.5 $9,951.6

Option C $219.5 $390.9 $718.9 $47.4 $4.8 $693.7 $965.4 $1,136.8 $1,464.7

Final Rule-New Units $22.6 $40.2 $74.0 $4.9 $0.5 $71.4 $99.4 $117.0 $150.8

7% Discount Rate

Option A $2,722.0 $4,848.0 $8,914.9 $587.8 $59.7 $8,958.6 $12,328.0 $14,454.0 $18,520.9

Option B $980.9 $1,747.1 $3,212.7 $211.8 $21.5 $3,228.4 $4,442.7 $5,208.9 $6,674.5

Option C $144.4 $257.1 $472.9 $31.2 $3.2 $475.2 $653.9 $766.7 $982.4

Final Rule-New Units $14.9 $26.5 $48.7 $3.2 $0.3 $48.9 $67.3 $78.9 $101.1

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Chapter 12: Analysis of New Units

May 2014 12-6

Table 12-7: National Annualized Benefits for IM&E Reductions 

under the Final Rule and Options Considered for New Units

based on the SP Survey (2011$, millions)

Regulatory Option 5th Percentile Mean 95th Percentile

3 % Discount Rate

Option A $381.8 $596.7 $842.7

Option B $137.6 $215.0 $303.7

Option C $20.3 $31.6 $44.7

Final Rule-New Units $2.1 $3.3 $4.6

7 % Discount Rate

Option A $270.7 $423.1 $597.5

Option B $97.6 $152.5 $215.3

Option C $14.4 $22.4 $31.7

Final Rule-New Units $1.5 $2.3 $3.3

Source: U.S. EPA analysis for this report

12.2.4 Limitations and Uncertainties for the Analysis of IM&E Reductions and 

Associated Benefits for New Units

EPA’s methodology for analyzing benefits from reducing IM&E at new units relies on the 

estimated IM&E reductions and monetary benefits from the analysis of existing units. Thus, it is 

subject to limitations and uncertainties inherent in the EPA’s methodology for existing units. 

Refer to Section 3.4 for a discussion of limitations and uncertainties in EPA’s analysis of IM&E 

for existing units and Chapters 5 through 8 for monetary benefits, and Chapter 11 for the SP 

survey. Additional limitations and uncertainties specific to EPA’s analysis of new units also 

apply. These are addressed below in Table 12-8.
Benefits Analysis for the Final 316(b) Existing Facilities Chapter 12: Analysis of New Units

May 2014 12-7

Table 12-8: Limitations and Uncertainties in EPA’s Analysis of IM&E Reductions and 

Associated Benefits at New Units

Issue

Impact on 

Benefits 

Estimate

Comments

National rather than 

regional flow reductions Uncertain

EPA’s analysis for existing units examined IM&E and the economic 

benefits of reducing these losses at a regional scale. To obtain regional 

IM&E estimates, EPA extrapolated losses observed at model facilities

to existing units at regulated facilities within the same region. Regional 

flow reductions were unavailable for new units; therefore, EPA 

extrapolated per mgd benefits to new units based on national benefits 

and national weighted flow from the analysis for existing units. This 

assumption could lead to the over- or under-estimation of benefits for 

new units depending on their ultimate regional distribution.

Timing of flow 

reductions Uncertain

The annual flow reduction for new units is constant with the total flow 

reduction increasing linearly over the compliance period. As a result, 

peak IM&E is not achieved until the 2059, the final year of the 

compliance period. This assumption would tend to under-estimate 

annualized benefits if the new units come into operation sooner than 

projected and over-estimate benefits if they come into operation later 

than projected.

Engineering uncertainty Uncertain

EPA’s evaluation of IM&E was also affected by uncertainty about the 

engineering and operating characteristics of the new units. Units 

defined as “new” under the rule would be required to meet equivalent 

performance to closed-cycle recirculating systems. EPA expects that 

most new units will install wet cooling towers. EPA may over- or 

under-estimate benefits for new units if the flow at new units and 

percentage flow reduction due to the rule deviate from EPA’s 

assumptions. Refer to Chapter 8 of the TDD for additional information 

on the engineering analysis for new units and potential uncertainties. 

12.3 Analysis of Social Cost of Carbon for New Units

Because EPA does not expect Electric Generators to shut down to install cooling towers at new 

units, for new units, EPA estimated the change in CO2 resulting from the energy penalty only. 

Energy penalty effects result from reduced energy conversion efficiency of the power generating 

system. Refer to Appendix I of the economic analysis for the final rule (USEPA 2014) for

additional detail on compliance technology effects that impose costs via impact on revenue or 

energy requirements.

12.3.1 Analysis Approach and Data Inputs

EPA estimated the monetary value of higher CO2 emissions resulting from auxiliary energy 

requirements associated with operating cooling towers as follows:

 EPA first calculated the amount of additional electricity (in MWh) required to operate 

cooling towers at new units, assuming Electric Generators would incur this additional 

energy requirement beginning in the first year any new generating unit would begin to 

operate a cooling tower, i.e., 2017, through 2059.76

 

76 As discussed in Chapter 3 of the Economic Analysis, EPA estimates that facilities will require four years to install 

cooling towers. EPA assumed that 2014 will be the first year when any Electric Generator will begin installation 

of its cooling tower according to the new unit provision of the final rule.
Benefits Analysis for the Final 316(b) Existing Facilities Chapter 12: Analysis of New Units

May 2014 12-8

 EPA next estimated the amount of fuel required to generate this additional electricity (in 

BTUs). The Agency assumed that existing facilities will be able to generate additional 

electricity onsite, i.e., at new units at those facilities. EPA estimated additional fuel 

requirement for coal and combined cycle natural gas units by multiplying the additional 

energy requirement by heat rates for coal and combined cycle natural gas electric 

generating units, respectively.77

 The Agency then multiplied the resulting fuel usage values by coal or natural gas carbon 

dioxide emissions coefficients published by EIA (USDOE 2013c), depending on the new 

unit type, to estimate an increase in CO2 emissions due to the energy penalty.78

 Finally, EPA multiplied the estimated CO2 emission values, by year, by the same unit 

SCC values as those used for Electric Generators (Table 9-3).

12.3.2 Key Findings for Regulatory Options

Table 12-9 presents the total reduction in CO2 emissions and associated SCC values in 2013 for 

new units at Electric Generators, by option and discount rate. EPA estimates that the new unit

provision of the final rule will result in a total increase of 0.3 million of tCO2eq. Using the 3 

percent average SCC values, EPA estimates the average annual benefit associated with this 

increase in carbon emissions to be -$0.3 million at the 3 percent discount rate and -$0.2 million at 

the 7 percent discount rate. EPA estimates that under the other new units options considered –

Options A, B, and C –total carbon emissions would increase by 22.0, 8.9, and 2.0 million of 

tCO2eq, respectively. Using the 3 percent average SCC values, EPA estimates the average 

annual benefit associated with these increases in carbon emissions to be -$22.5 million, -$9.1 

million, and -$2.1 million at the 3 percent discount rate and -$13.8 million, -$5.6 million, and 

-$1.3 million at the 7 percent discount rate, respectively.

Table 12-9: Reduction in Carbon Emissions and Associated Average Annual Benefits -

New Units (SCC Values in 2013; $2011, millions) 

Option Total Emissions 

(Millions; tCO2eq)

Discount Rate for Calculating SCC Unit Values

2.5% 3% 5%

Average SCC 

Value

Average SCC 

Value High SCC Value Average SCC Value

3% Discount Rate for Annualizing Benefits

Option A -22.0 -$31.3 -$22.5 -$69.7 -$7.7

Option B -8.9 -$12.6 -$9.1 -$28.1 -$3.1

Option C -2.0 -$2.9 -$2.1 -$6.4 -$0.7

Final Rule – New 

Units -0.3 -$0.4 -$0.3 -$0.9 -$0.1 

7% Discount Rate for Annualizing Benefits

Option A -22.0 -$19.5 -$13.8 -$42.8 -$4.6

Option B -8.9 -$7.9 -$5.6 -$17.2 -$1.9

Option C -2.0 -$1.8 -$1.3 -$3.9 -$0.4 

Final Rule – New 

Units -0.3 -$0.3 -$0.2 -$0.6 -$0.1 

Source: U.S. EPA analysis for this report

 

77 EPA used heat rates based on higher heating values (HHV) of fuel.

78 For details see Carbon Dioxide Emissions Coefficients by Fuel published on February 14, 2013 available online at 

http://www.eia.gov/environment/emissions/co2_vol_mass.cfm. 
Benefits Analysis for the Final 316(b) Existing Facilities Chapter 12: Analysis of New Units

May 2014 12-9

12.4 Monetized Benefits for New Units

Table 12-10 summarizes the annual monetized benefits associated with IM&E reductions and 

changes in GHG emissions for new units. Using 3 percent average SCC values, mean annualized 

benefits for the final rule for new units are -$0.2 million using a 3 percent discount rate and -$0.1 

million using a 7 percent discount rate. Benefits for other options considered for new units range 

from -$0.9 to -$1.1 million using a 3 percent discount rate and -$0.5 to $0.6 million using a 7 

percent discount rate.
Benefits Analysis for the Final 316(b) Existing Facilities Chapter 12: Analysis of New Units

May 2014 12-10

Table 12-10: National Annualized Benefits under the Final Rule and Options Considered for New Units (2011$, 

millions)

Regulatory Option

Recreational

Commercial T&E Nonuse

Total Benefits

Low Mean High Low Mean High

3% Discount Rate

Option A $4,138.2 $7,370.2 $13,553.0 $893.6 $90.7 $13,077.4 $18,199.9 $21,431.9 $27,614.7

Option B $1,491.3 $2,656.0 $4,884.1 $322.0 $32.7 $4,712.8 $6,558.8 $7,723.5 $9,951.6

Option C $219.5 $390.9 $718.9 $47.4 $4.8 $693.7 $965.4 $1,136.8 $1,464.7

Final Rule-New Units $22.6 $40.2 $74.0 $4.9 $0.5 $71.4 $99.4 $117.0 $150.8

7% Discount Rate

Option A $2,722.0 $4,848.0 $8,914.9 $587.8 $59.7 $8,958.6 $12,328.0 $14,454.0 $18,520.9

Option B $980.9 $1,747.1 $3,212.7 $211.8 $21.5 $3,228.4 $4,442.7 $5,208.9 $6,674.5

Option C $144.4 $257.1 $472.9 $31.2 $3.2 $475.2 $653.9 $766.7 $982.4

Final Rule-New Units $14.9 $26.5 $48.7 $3.2 $0.3 $48.9 $67.3 $78.9 $101.1

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Chapter 13: National Summary

May 2014 13-1

13 Summary of National IM&E Reductions and Benefits for Existing 

and New Units

13.1 Introduction

This chapter summarizes the results of the seven regional analyses, and presents EPA’s estimates of the 

national benefits of the final rule and options considered for new and existing units at regulated facilities. 

As described in Chapter 1, EPA considered three options for the existing units based on two technologies:

 Proposal Option 4: IM for Facilities > 50 mgd. Establish impingement mortality controls at 

all existing facilities that withdraw over 50 mgd; determine entrainment controls for facilities 

greater than 2 mgd DIF on a site-specific basis.

 Final Rule – Existing Units: IM Everywhere. Establish impingement mortality controls at all 

existing facilities that withdraw over 2 mgd; determine entrainment controls for facilities 

greater than 2 mgd DIF on a site-specific basis.

 Proposal Option 2: IM Everywhere and E for Facilities > 125 mgd. Establish impingement 

mortality controls at all existing facilities that withdraw over 2 mgd DIF; require flow reduction 

commensurate with closed-cycle recirculating system for entrainment control by facilities 

greater than 125 mgd DIF.

The final rule will establish entrainment controls for facility greater than 2 mgd DIF on a site-specific 

basis, as would Proposal Option 4. EPA did not analyze entrainment benefits under the final rule or 

Proposal Option 4 because entrainment requirements are site specific.

EPA considered four regulatory options for new units at existing facilities:

 Option A: Entrainment performance requirements for all stand-alone new units and all types of 

repowered units.

 Option B: Entrainment performance requirements for all stand-alone new units, and replaced 

or repowered units in which the turbine or condenser are newly built or replaced.

 Option C: Entrainment performance requirements for all stand-alone new units, and repowered 

new units where the turbine and condenser are newly built or replaced, but excluding high 

efficiency systems.

 Final Rule – New Units (Option D): Entrainment performance requirements for all standalone new units only.

Refer to Section VI of the preamble for additional description of the final rule and other options 

considered for existing and new units.

Section 13.2 describes EPA’s methodology for aggregating benefits at the national level; Section 13.3

summarizes baseline IM&E and estimated reductions in IM&E under the final rule and options 

considered; Section 13.4 presents national benefits; and Section 13.5 summarizes results of the SP survey, 

and Section 13.6 discusses nonuse benefits and presents a break-even analysis.

13.2 Summary of Limitations and Uncertainties

EPA notes that quantifying and monetizing the benefits that result from reductions in IM&E and GHG 

emissions under the final rule and options considered for the existing facilities rule is challenging. The 
Benefits Analysis for the Final 316(b) Existing Facilities Chapter 13: National Summary

May 2014 13-2

preceding sections discuss specific limitations and uncertainties associated with estimating reductions in 

IM&E and monetized benefits. EPA estimated national-level benefits associated with IM&E reductions 

by summing benefit estimates over the seven study regions. Thus, national benefit estimates are subject to 

the same uncertainties inherent in the valuation approaches EPA used for assessing each of the four

benefit categories associated with IM&E reductions (threatened and endangered species, commercial 

fishing, recreational fishing, and nonuse values). The combined effect of these uncertainties is of 

unknown magnitude and direction (i.e., the estimates may over- or understate the anticipated national 

level of use benefits). Nevertheless, EPA has no data to indicate that the results for any of the benefit 

categories are atypical or unreasonable. EPA’s analysis of changes in GHG emissions and associated 

benefits was conducted at the national level, regional benefits were not estimated. EPA calculated 

national benefits based on the SP survey estimates by summing results for the four SP survey regions. As 

noted above, estimates based on EPA’s SP survey are included to illustrate the potential magnitude of 

total values of ecological improvements resulting from the final rule. 

13.3 Summary of Baseline IM&E Losses and IM&E Reductions

Based on the results of the regional analyses, EPA calculated total IM&E under baseline (i.e., preregulatory) conditions and the total amount by which losses would be reduced under the final rule and 

options considered. The number of fish lost at regulated facilities is presented in terms of A1E losses (i.e., 

the number of individual fish of different ages impinged and entrained by facility intakes, expressed as 

A1E). 

Table 13-1 presents baseline impingement, entrainment, and total IM&E for existing units. The table 

shows that total national annual losses for all regulated facilities are 1.9 billion fish in terms of A1E. EPA 

notes that the count of total lost organisms is larger than values expressed in A1E. This table shows that 

about 39 percent, or 0.8 billion fish of all A1E losses, occur in the Inland region, followed by the MidAtlantic region with 0.6 billion fish lost. Chapter 3 provides a more detailed discussion of IM&E in each 

region.

Table 13-1: Baseline National A1E Losses at All Regulated Facilities (millions of 

A1E)

Region IM E IM&E

California 1.1 50.4 51.5

North Atlantic 0.6 57.2 57.9

Mid-Atlantic 39.1 591.9 631.0

South Atlantic 17.1 9.2 26.4

Gulf of Mexico 53.5 93.5 147.0

Great Lakes 236.7 24.6 261.3

Inland 476.0 279.9 756.0

Total 824.2 1,106.7 1,931.0

Notes:

A1E = age-one equivalent; IM = impingement mortality; E = entrainment; IM&E = impingement mortality and entrainment

Source: U.S. EPA analysis for this report

EPA also calculated the total national IM&E avoided based on the expected reductions in IM&E at each 

facility due to technology installation required by the final rule and under each option considered. Table 

13-2 through Table 13-4 present expected annual reductions at existing units, expressed as A1E, by 

region. The final rule will reduce annual A1E losses by 0.7 billion fish existing units. In comparison, 
Benefits Analysis for the Final 316(b) Existing Facilities Chapter 13: National Summary

May 2014 13-3

Proposal Option 4 would reduce A1E losses by 0.6 billion fish and Proposal Option 2 would reduce 

annual A1E losses by 1.6 billion fish. Table 13-5 presents reductions in A1E losses for the final rule and 

options considered for new units. The final rule, including both new and existing units, will reduce A1E 

losses by 0.7 billion fish (Table 13-6).

Table 13-2: Reductions in National A1E Losses for All Regulated Facilities (millions 

of A1E) under Proposal Option 4

Region IM E IM&E

California 0.7 <0.01 0.7

North Atlantic 0.4 <0.01 0.4

Mid-Atlantic 29.6 0.93 30.5

South Atlantic 11.6 <0.01 11.6

Gulf of Mexico 38.7 0.08 38.8

Great Lakes 184.0 0.02 184.0

Inland 347.7 0.39 348.1

Total 612.8 1.41 614.2

Notes:

A1E = age-one equivalent; IM = impingement mortality; E = entrainment; IM&E = impingement mortality and entrainment

Source: U.S. EPA analysis for this report

Table 13-3: Reductions in National A1E Losses for All Regulated Facilities (millions 

of A1E) under the Final Rule

Region IM E IM&E

California 0.7 <0.01 0.7

North Atlantic 0.4 0.51 0.9

Mid-Atlantic 31.6 1.40 33.0

South Atlantic 12.4 0.48 12.9

Gulf of Mexico 40.2 0.08 40.3

Great Lakes 202.5 0.06 202.6

Inland 359.6 2.00 361.6

Total 647.5 4.53 652.0

Notes:

A1E = age-one equivalent; IM = impingement mortality; E = entrainment; IM&E = impingement mortality and entrainment

Source: U.S. EPA analysis for this report

Table 13-4: Reductions in National A1E Losses for All Regulated Facilities (millions 

of A1E) under Proposal Option 2

Region IM E IM&E

California 0.8 30.8 31.5

North Atlantic 0.6 43.8 44.4

Mid-Atlantic 36.1 515.8 551.9

South Atlantic 17.0 8.6 25.6

Gulf of Mexico 48.2 55.2 103.4

Great Lakes 230.8 17.7 248.5

Inland 414.7 217.4 632.2

Total 748.2 889.3 1,637.5

Notes:

A1E = age-one equivalent; IM = impingement mortality; E = entrainment; IM&E = impingement mortality and entrainment

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Chapter 13: National Summary

May 2014 13-4

Table 13-5: Reductions in National A1E Reductions under the Final Rule and Options 

Considered for New Units (millions of A1E)

Regulatory Option IM E IM&E

Option A 74.5 353.3 427.8

Option B 26.8 127.3 154.2

Option C 4.0 18.7 22.7

Final Rule - New Units 0.4 1.9 2.3

Notes:

A1E = age-one equivalent; IM = impingement mortality; E = entrainment; IM&E = impingement mortality and entrainment

Source: U.S. EPA analysis for this report

Table 13-6: Reductions in National A1E Reductions under the Final Rule – Existing 

and New Units (millions of A1E)

Regulatory Option IM E IM&E

Final Rule-Existing Units 647.5 4.5 652.0

Final Rule-New Units 0.4 1.9 2.3

Final Rule-Existing and 

New Untis 647.9 6.5 654.3

Notes:

A1E = age-one equivalent; IM = impingement mortality; E = entrainment; IM&E = impingement mortality and entrainment

Source: U.S. EPA analysis for this report

Table 13-7 presents EPA’s estimates of the current level of total annual IM&E and the reduction in total 

annual IM&E for the baseline, final rule and other options considered for existing units using the three 

metrics presented in Section 3.2.2. The final rule will provide greater IM&E reductions at existing units 

than Proposal Option 4, but lesser IM&E reductions than Proposal Option 2. Table 13-8 presents IM&E 

reductions under the final rule and other options considered for new units according to the same metrics 

as Table 13-7. The final rule, including both new and existing units, will reduce annual foregone fishery 

yield by 13.5 million pounds and annual biomass prodution foregone by 139.8 million pounds (Table 

13-9).

Table 13-7: Baseline National IM&E and IM&E Reductions for Regulated Facilities for 

the Final Rule and Options Considered

Regulatory Option Millions of A1E

Foregone Fishery 

Yield 

(million lbs)a

Biomass Production Forgone 

(million lbs)

Proposal Option 4 614.2 12.6 130.3

Final Rule-Existing 

Units 652.0 13.4 138.9

Proposal Option 2 1,637.5 51.1 494.2

Baseline 1,931.0 69.8 626.6

Notes:

A1E = age-one equivalents

a The reductions in foregone fishery yield presented here are equal to increases in commercial and recreational harvest. Refer to 

Chapter 3 for additional detail regarding the calculation of foregone fishery yield and biomass production forgone.

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Chapter 13: National Summary

May 2014 13-5

Table 13-8: Reductions in IM&E under the Final Rule and Options Considered for New 

Units

Regulatory Option Millions of A1E

Foregone Fishery 

Yield 

(million lbs)a

Biomass Production Forgone 

(million lbs)

Option A 427.8 18.4 160.0

Option B 154.2 6.6 57.7

Option C 22.7 1.0 8.5

Final Rule-New Units 2.3 0.1 0.9

Notes:

A1E = age-one equivalents

a The reductions in foregone fishery yield presented here are equal to increases in commercial and recreational harvest. Refer to 

Chapter 3 for additional detail regarding the calculation of foregone fishery yield and biomass production forgone.

Source: U.S. EPA analysis for this report

Table 13-9: Reductions in IM&E under the Final Rule – Existing and New Units

Regulatory Option Millions of A1E

Foregone Fishery 

Yield 

(million lbs)a

Biomass Production Forgone 

(million lbs)

Final Rule-Existing 

Units 652.0 13.4 138.9

Final Rule-New Units 2.3 0.1 0.9

Final Rule-Existing and 

New Units 654.3 13.5 139.8

Notes:

A1E = age-one equivalents

a The reductions in foregone fishery yield presented here are equal to increases in commercial and recreational harvest. Refer to 

Chapter 3 for additional detail regarding the calculation of foregone fishery yield and biomass production forgone.

Source: U.S. EPA analysis for this report

As shown for all regions in Table 13-10, Table 13-11, Table 13-12, and by region in Chapter 3, the 

harvested commercial and recreational fish species that have direct use values comprise between 1 and 9

percent of baseline IM&E in each region, resulting in a national average of only 3 percent of IM&E for 

which EPA monetized value based on direct use. The remaining 97 percent of IM&E includes

unharvested recreational and commercial fish and forage fish which are not associated with direct use. 

EPA’s nonuse benefit transfer was limited to two of the seven benefits regions, and EPA did not include 

nonuse values for unharvested fish in its primary benefits analysis for the remaining five regions. Thus, 

EPA has likely understated the total benefits significantly due to the regional limitations of its nonuse 

analysis and the relatively large fraction of IM&E reductions which are not commercially or 

recreationally harvested.
Benefits Analysis for the Final 316(b) Existing Facilities Chapter 13: National Summary

May 2014 13-6

Table 13-10: Distribution of National IM&E Reduction for Existing Units for All 

Regulated Facilities for the Final Rule and Other Regulatory Options Considered

Regulatory Option

All 

Species

(millions 

of A1E)

Forage 

Species

(millions of 

A1E)

Commercial 

and 

Recreational 

Species

(millions of 

A1E)

Commercial 

and 

Recreational 

Harvest

(millions of fish 

harvested)

Percent of Fish 

with Monetized 

Use Valuea

Proposal Option 4 614.2 528.2 85.9 16.1 2.6%

Final Rule - Existing 

Units 652.0 560.8 91.2 17.1 2.6%

Proposal Option 2 1,637.5 1,258.7 378.8 44.7 2.7%

Baseline 1,931.0 1,459.7 471.3 54.0 2.8%

Notes:

A1E = age-one equivalent

a

"Percent of fish with monetized use value" is equal to "commercial and recreational harvest (millions of fish harvested)" divided 

by "all species (millions of A1E)."

Source: U.S. EPA Analysis for this report

Table 13-11: Distribution of National IM&E Reductions under the Final Rule and Options 

Considered for New Units

Regulatory Option

All 

Species

(millions 

of A1E)

Forage 

Species

(millions of 

A1E)

Commercial 

and 

Recreational 

Species

(millions of 

A1E)

Commercial 

and 

Recreational 

Harvest

(millions of fish 

harvested)

Percent of Fish 

with Monetized 

Use Valuea

Option A 427.8 303.9 123.9 12.3 2.9%

Option B 154.2 109.5 44.6 4.4 2.9%

Option C 22.7 16.1 6.6 0.7 2.9%

Final Rule - New Units 2.3 1.7 0.7 0.1 2.9%

Notes:

A1E = age-one equivalent

a

"Percent of fish with monetized use value" is equal to "commercial and recreational harvest (millions of fish harvested)" divided 

by "all species (millions of A1E)."

Source: U.S. EPA Analysis for this report

Table 13-12: Distribution of National IM&E Reductions under the Final Rule – Existing 

and New Units

Regulatory Option

All 

Species

(millions 

of A1E)

Forage 

Species

(millions of 

A1E)

Commercial 

and 

Recreational 

Species

(millions of 

A1E)

Commercial 

and 

Recreational 

Harvest

(millions of fish 

harvested)

Percent of Fish 

with Monetized 

Use Valuea

Final Rule-Existing 

Units 652.0 560.8 91.2 17.1 2.6%

Final Rule-New Units 2.3 1.7 0.7 0.1 2.9%

Final Rule-Existing and 

New Units

654.3 562.5 91.9 17.2 2.9%

Notes:

A1E = age-one equivalent

a

"Percent of fish with monetized use value" is equal to "commercial and recreational harvest (millions of fish harvested)" divided 

by "all species (millions of A1E)."

Source: U.S. EPA Analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Chapter 13: National Summary

May 2014 13-7

13.4 Summary of National Monetized Benefits

EPA based its estimates of total national baseline losses and total national benefits associated with IM&E 

reductions under the final rule and options considered on its estimates of regional monetized baseline 

losses and final rule and regulatory option benefits. To address the differences in the timing of benefits 

and costs, EPA developed a time profile of total benefits from all regulated facilities that reflects when 

benefits from compliance-related changes at each facility will be realized. EPA then discounted and 

annualized benefits using 3 percent and 7 percent discount rates.79 Appendix D of this report provides 

detail on EPA’s development of the timeline of benefits. 

EPA estimated mean national use values, as well as values that include the 5th percentile lower bound and 

95th percentile upper bound of the recreational benefit estimates.

80 Table 13-13 and Table 13-14 present 

these results for each region and for the nation as a whole. The national benefit estimates do not include

benefits based on EPA’s SP survey presented in Chapter 11.

Table 13-13 summarizes EPA’s estimates of the regional and national annualized benefits of reducing 

IM&E and GHG emissions under the final rule and each of the regulatory options EPA considered for 

existing units (discounted at 3 percent and 7 percent). Table 13-14 presents the sum of benefits for the 

final rule for existing units and new units. Refer to Chapter 10 for additional detail regarding benefits for 

existing units and Chapter 12 for additional detail regarding benefits for new units. The national value of 

these reductions in IM&E and GHG emissions, evaluated at a 3 percent discount rate, is as follows:

 Proposal Option 4 results in national benefits of $31.0 million per year, with estimates based on 

the 5th percentile lower bound and 95th percentile upper bound for recreational values, totaling

$22.8 million and $47.6 million (Table 13-13).

 The final rule for existing units results in national benefits of $33.0 million per year, with 

estimates based on the 5th percentile lower bound and 95th percentile upper bound for 

recreational values, totaling $24.1 million and $50.6 million (Table 13-13). Including 

requirements for new units, the final rule results in national benefits of $32.8 million per year, 

with estimates based on the 5th percentile lower bound and 95th percentile upper bound for 

recreational values, totaling $23.9 million and $50.5 million (Table 13-14). 

 Proposal Option 2 results in national benefits of -$1,542.6 million per year, with estimates 

based on the 5th percentile lower bound and 95th percentile upper bound for recreational values, 

totaling -$1,562.2million and -$1,504.5 million (Table 13-13).

Evaluated at a 7 percent discount rate, the national use benefits of the regulatory analysis options are 

somewhat smaller for the final rule and Proposal Option 4, and greater for Proposal Option 2:

 Proposal Option 4 results in national benefits of $27.2 million per year, with estimates based on 

the 5th percentile lower bound and 95th percentile upper bound for recreational values, totaling

$21.1 million and $39.5 million (Table 13-13).

 

79 The 3 percent rate represents a reasonable estimate of the social rate of time preference. The 7 percent rate represents an 

alternative discount rate, recommended by the Office of Management and Budget (OMB) that reflects an estimated 

opportunity cost of capital.

80 The lower estimates of value presented in this chapter are measured by the sum of the 5th percentile lower bound estimates 

of recreational values plus the mean value estimates for all other categories of value. The higher estimates of value presented 

in this chapter are measured by the sum of the 95th percentile upper bound estimates of recreational values plus the mean 

value estimates for all other categories of value.
Benefits Analysis for the Final 316(b) Existing Facilities Chapter 13: National Summary

May 2014 13-8

 The final rule for existing units results in national benefits of $28.7 million per year, with 

estimates based on the 5th percentile lower bound and 95th percentile upper bound for 

recreational values, totaling $22.2 million and $41.8 million (Table 13-13). Including 

requirements for new units, the final rule results in national benefits of $28.6 million per year, 

with estimates based on the 5th percentile lower bound and 95th percentile upper bound for 

recreational values, totaling $22.1 million and $41.7 million (Table 13-14).

 Proposal Option 2 results in national use benefits of -$1,148.2 million per year, with estimates 

based on the 5th percentile lower bound and 95th percentile upper bound for recreational values, 

totaling -$1,161.7 million and -$1,122.0 million (Table 13-13).

More detailed discussions of benefits under each option are provided in Chapters 5 through 9. National 

benefits for new units are discussed in Chapter 12. 
Benefits Analysis for the Final 316(b) Existing Facilities Chapter 13: National Summary

May 2014 13-9

Table 13-13: Summary of National Annualized Benefits for Existing Units for All Regulated Facilities ( (2011$, millions)a

Regulatory 

Option

Recreational Fishing Benefits Commercial 

Fishing 

Benefitsc

T&E Species 

Benefitsd,e

Nonuse 

Benefits SCCe Total Benefits

Low Mean High Low Mean High

3% Discount Rate

Proposal Option 4 $8.8 $17.1 $33.6 $0.9 $0.4 $0.3 $12.4 $22.8 $31.0 $47.6

Final Rule $9.4 $18.2 $35.9 $0.9 $0.4 $1.0 $12.4 $24.1 $33.0 $50.6

Proposal Option 2 $23.4 $43.0 $81.1 $3.9 $0.7 $51.1 -$1,641.3 -$1,562.2 -$1,542.6 -$1,504.5

7% Discount Rate

Proposal Option 4 $6.5 $12.6 $24.9 $0.7 $0.3 $0.3 $13.4 $21.1 $27.2 $39.5

Final Rule $7.0 $13.5 $26.6 $0.7 $0.3 $0.8 $13.4 $22.2 $28.7 $41.8

Proposal Option 2 $16.1 $29.5 $55.8 $2.7 $0.5 $37.3 -$1,218.2 -$1,161.7 -$1,148.2 -$1,122.0

a All benefits presented in this table are annualized, i.e., represent the sum of the discounted stream of benefits annualized over 51 years (2014 to 2064). See Appendix D for detail.

b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value per fish predicted by the metaanalysis. Commercial fishing benefits are computed based on a region- and species-specific range of gross revenue, as explained in Chapter 6 of this report. EPA estimated recreational use 

benefits for some T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commercial fishing benefits and T&E species benefits 

are added to the respective low, mean, and high values for recreational fishing benefits.

c No significant commercial fishing takes place in the Inland region. Thus, this region is excluded from the commercial fishing analysis.

d Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon). 

See Chapter 5 of this report for more detail on EPA’s analysis of T&E benefits.

e

SCC results presented here are based on 3 percent average SCC values.

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Chapter 13: National Summary

May 2014 13-10

Table 13-14: Summary of National Annualized Benefits for the Final Rule for Existing Units and New Units (2011$, millions)a

Regulatory 

Option

Recreational Fishing Benefits Commercial 

Fishing Benefitsc

T&E Species 

Benefitsd,e

Nonuse 

Benefits SCC

Total Benefits

Low Mean High Low Mean High

3% Discount Rate

Final Rule -

Existing Units $9.4 $18.2 $35.9 $0.9 $0.4 $1.0 $12.4 $24.1 $33.0 $50.6

Final Rule - New 

Units $0.0 $0.0 $0.1 $0.0 $0.0 $0.1 -$0.3 -$0.2 -$0.2 -$0.1

Final Rule -

Existing Units + 

New Units

$9.4 $18.3 $36.0 $0.9 $0.4 $1.1 $12.1 $23.9 $32.8 $50.5

7% Discount Rate

Final Rule -

Existing Units $7.0 $13.5 $26.6 $0.7 $0.3 $0.8 $13.4 $22.2 $28.7 $41.8

Final Rule - New 

Units $0.0 $0.0 $0.0 $0.0 $0.0 $0.0 -$0.2 -$0.1 -$0.1 -$0.1

Final Rule -

Existing Units + 

New Units

$7.0 $13.5 $26.7 $0.7 $0.3 $0.9 $13.2 $22.1 $28.6 $41.7

a All benefits presented in this table are annualized, i.e., represent the sum of the discounted stream of benefits annualized over 51 years (2014 to 2064). See Appendix D for detail.

b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value per fish predicted by the metaanalysis. Commercial fishing benefits are computed based on a region- and species-specific range of gross revenue, as explained in Chapter 6 of this report. EPA estimated recreational use 

benefits for some T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commercial fishing benefits and T&E species benefits 

are added to the respective low, mean, and high values for recreational fishing benefits.

c No significant commercial fishing takes place in the Inland region. Thus, this region is excluded from the commercial fishing analysis.

d Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon). 

See Chapter 5 of this report for more detail on EPA’s analysis of T&E benefits.

e

SCC results presented here are based on 3 percent average SCC values.

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Chapter 13: National Summary

May 2014 13-11

13.5 Results based on the SP Survey

Table 13-15 and Table 13-16 summarize national benefit estimates for the final rule and options 

considered for existing and new units based on EPA’s SP survey. The national totals are based on 

the sum of estimates for each survey region. As described in Chapter 12, EPA does not include 

benefit estimates based on the survey in its comparison of benefits and costs for the final rule and 

options considered. However, the magnitude of benefits estimated based on the survey results 

illustrate that total values of ecological improvements may be substantially greater than the partial 

monetized benefits used for the benefit cost comparison (Table 13-13 and Table 13-14).

Table 13-15: Summary of National Benefits for the Final Rule and Options Considered for 

Existing Units based on the SP Survey (2011$, millions)

Regulatory Option 3 % Discount Rate 7 % Discount Rate

5

th Mean 95th 5th Mean 95th

Proposal Option 4 $829.1 $1,363.1 $1,898.8 $642.6 $1,056.8 $1,472.2

Final Rule - Existing Units $880.5 $1,448.8 $2,019.0 $682.5 $1,123.2 $1,565.3

Proposal Option 2 $2,159.9 $3,430.7 $4,823.7 $1,442.4 $2,294.5 $3,226.1

Source: U.S. EPA analysis for this report

Table 13-16: Summary of National Benefits for the Final Rule for Existing and New Units 

based on the SP Survey (2011$, millions)

Regulatory Option 3 % Discount Rate 7 % Discount Rate

5

th Mean 95th 5th Mean 95th

Final Rule - Existing Units $880.5 $1,448.8 $2,019.0 $682.5 $1,123.2 $1,565.3

Final Rule - New Units $2.1 $3.3 $4.6 $1.5 $2.3 $3.3

Final Rule - Existing and 

New Units $882.6 $1,452.1 $2,023.6 $683.9 $1,125.5 $1,568.6

Source: U.S. EPA analysis for this report

13.6 Break-Even Analysis

Comprehensive estimates of total resource value include both use and nonuse values and may be 

compared to total social cost. Recent economic literature provides strong support for the 

hypothesis that mean nonuse values are greater than zero. This is supported by the results of 

EPA’s stated preference survey as described in Section 13.5. The per-capita nonuse values need 

not be large to result in substantial benefits for the final rule. When small per-capita nonuse 

values are held by a substantial fraction of the population, the aggregate value can be very large. 

However, in this specific context, EPA included nonuse values for only two of the seven benefits 

regions within its primary estimates of national benefits for the final rule and other options 

considered. EPA did include benefit estimates based on the SP survey in its comparison of 

benefits and costs for the final rule and options considered.

As shown in Table 13-12 above, nearly all—97 percent—IM&E at cooling water intake 

structures under current conditions (the baseline scenario) consist of either forage species or 

unlanded recreational and commercial species that are not harvested and thus not reflected in 

EPA’s estimated direct use values. Although individuals do not use these resources directly, they 

may value changes in the status or quality of these resources. EPA did not include nonuse values 
Benefits Analysis for the Final 316(b) Existing Facilities Chapter 13: National Summary

May 2014 13-12

for forage and unlanded species occurring in five of the seven benefits regions. Due to the 

uncertainties of providing estimates of the magnitude of nonuse values associated with the 

regulatory options for all regions, this section provides an alternative approach. EPA used an 

alternative “break-even” analysis approach for evaluating the potential relationship between costs

and benefits associated with IM&E reductions. This approach identifies what the unmonetized 

nonuse values would have to be in order for the benefits of the proposed options to equal costs.

To calculate a break-even value, EPA subtracted its estimates of monetized commercial and 

recreational use benefits for the final rule and regulatory options considered from the estimated 

annual compliance costs incurred by facilities subject to the final rule. The resulting “net cost” 

enabled EPA to work backwards to estimate what the nonuse values would need to be (in terms 

of WTP per household per year) in order for total annualized benefits to equal annualized costs. 

Table 13-17 provides this assessment for the final rule and options considered. The table shows

benefit values using a 3 percent or 7 percent discount rate, respectively. 

As shown in Table 13-17, for total annualized benefits to equal total annualized costs, nonuse 

values per household would have to be at least $2.27 for the final rule using a 3 percent discount 

rate and $2.59 using a 7 percent discount rate. 

Table 13-17: Implicit Nonuse Value—Break-Even Analysis (2011$)

Regulatory 

Optiona

Use 

Benefits of 

IM&E 

Reductions 

(2011$, 

millions)a

Annual 

Social Cost 

(2011$, 

millions)b

Annual Nonuse 

Benefits Necessary 

to Break Even 

(2011$) c

Number of 

Households in 

States with 

Regulated 

Facilities 

(millions)d

Annual 

Break-Even 

Nonuse 

WTP per 

Household 

(2011$)e

3% Discount Rate

Proposal Option 4 $19.6 $251.8 $232.2 114.9 $2.02

Final Rule -

Existing and New 

Units

$14.5 $274.9 $260.4 114.9 $2.27

Proposal Option 2 $0.0 $3,643.2 $3,643.2 114.9 $31.72

7% Discount Rate

Proposal Option 4 $14.5 $272.1 $257.6 114.9 $2.24

Final Rule -

Existing and New 

Units

$0.0 $297.3 $297.3 114.9 $2.59

Proposal Option 2 $0.0 $3,583.0 $3,583.0 114.9 $31.19

a Benefits are discounted using a 3% or 7% discount rate, respectively. Use benefits include estimated commercial fishing benefits, 

recreational fishing benefits, and use benefits for T&E species.

b The total social cost of the final rule includes facility compliance costs and administrative costs.

c Annualized compliance costs minus annualized use benefits.

d

Includes households in states with at least one surveyed facility. Household counts are based on Census 2010 (U.S. Census Bureau 

2010).

e Dollars per household per year that, when added to use benefits, would yield a total annualized benefit (use plus nonuse) equal to 

the annualized costs.

Source: U.S. EPA analysis for this report; U.S. Census Bureau, 2010

While this approach of backing out the “break-even” nonuse value per household does not answer 

the question of what nonuse values might actually be for the final rule and regulatory options 

considered, these results do frame what the unknown values would have to be in order for 

benefits to equal or exceed costs. The break-even approach poses the question: “Is the true perhousehold WTP for the nonuse amenities (existence and bequest) associated with an option likely 
Benefits Analysis for the Final 316(b) Existing Facilities Chapter 13: National Summary

May 2014 13-13

to be greater or less than the ‘break-even’ benefit levels displayed in Table 13-17?” The results of 

EPA’s SP survey (Chapter 11) illustrate the potential magnitude of nonuse and total values for 

316(b) regulatory options and suggest that household values may exceed the break-even point for 

the final rule. Mean household WTP for the final rule based on the survey ranges from $0.69 in 

the Pacific region to $27.57 in the Inland region. 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 14: References

May 2014 14-1

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Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix A: Extrapolation Methods

May 2014 A-1

Appendix A: Extrapolation Methods

A.1 Introduction

This appendix provides detail on estimating facility-level weights used in estimating benefits at a 

regional level. EPA built its weighting approach on the sample weights developed for 

manufacturing facilities and electric power generating facilities in the analysis of 316(b) Phase II 

and Phase III regulations (USEPA 2004a; USEPA 2006b). EPA expanded on the existing 

approach by developing new facility-level weights that account for differences between electric 

power facilities that received the Detailed Questionnaire (DQ) and those that received the Short 

Technical Questionnaire (STQ), and to account for facility location, a key parameter in the 

benefits analysis. EPA used this new set of “benefits weights” to estimate baseline IM&E losses 

and reductions in IM&E losses under the final rule and other options considered and to adjust for 

the timing of these reductions and associated benefits. 

A.2 Manufacturing Facilities

The current analysis of manufacturing facilities incorporates a set of weights that EPA developed 

for the 2006 Final Phase III Rule, which EPA refers to as technical weights. The technical 

weights are based on engineering information obtained from the 316(b) Manufacturers 

Questionnaire. The technical weights account for the number of affected facilities and the cost of 

installing new technology, but do not account for facility location or intake flow at a regional 

level. EPA developed additional adjustments to the technical weights because IM&E losses are a 

function of facility location and intake flow. The purpose of the additional adjustments is to 

ensure thatweighted regional mean operational, or actual, intake flow (AIF)for survey facilities is 

consistent with EPA’s best estimates for all regulated manufacturing facilities in each of eight 

regions: North Atlantic, Mid-Atlantic, South Atlantic, Gulf of Mexico, California, Pacific 

Northwest,81 Great Lakes, and Inland regions.82

EPA developed the weight adjustments separately for traditional manufacturers (MN facilities) 

and non-utility manufacturers (MU facilities).83 Data was not available for total regional intake 

flow for MN and MU facilities. Thus, rather than calibrating the weights based on flow, EPA 

calibrated them based on facility counts such that the weighted number of surveyed facilities in 

each region equals the total number of facilities in that region. This approach assumes that the

flow characteristics of the non-surveyed facilities, which are represented by weights, are the same 

as surveyed facilities (DQ facilities). 

 

81 The Pacific Northwest region ultimately is excluded from the benefits analysis because it includes a single DQ 

facility which is projected to close as baseline.

82 See Chapter 1 for additional information regarding regional definitions. 

83 MN facilities include aluminum, steel, chemical, pulp and paper, and petroleum refining manufacturing industries. 

Note that Food and Kindred Products is not included in this list of industries for two reasons: a) this industry was 

not included in the original stratification of manufacturers, and b) all facilities later identified to be in the Food and 

Kindred Product industries were part of the MU universe.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix A: Extrapolation Methods

May 2014 A-2

The following two sections describe development of weight adjustment factors for MN and MU 

facilities, respectively.

A.2.1 Traditional Manufacturers (MN Facilities)

EPA stratified the universe of MN facilities by region and industry category.

84 EPA first 

determined the distribution of regulated facilities by study region, and then calculated adjusted 

benefits weights based on this distribution. 

A.2.1.1 Determining the Distribution of Regulated Facilities by Study Region

The industry survey requested that responding facilities provide Standard Industrial Classification 

(SIC) codes. 85 EPA used PCS (Permit Compliance System) and ICIS-NPDES (Integrated 

Compliance Information System- NPDES) to obtain latitude-longitude coordinates (lat-long) for 

all facilities in relevant SIC codes. Facilities within relevant SIC codes were assigned to a study 

region using lat-long. A map of RF1 reacheswas also used to indicate whether the facility location 

is coastal/estuarine or inland.

86 Table A-1 presents the distribution of the facility universe 

according to region and industry based on the PCS/ICIS data.

The sample frame for the survey screener of manufacturing facilities did not include all facilities 

in the relevant SIC codes. Information on which facilities were included is not available. 

Therefore, EPA used two simplifying assumptions to develop weight adjustment factors: (1) the 

total number regulated facilities in any single industry equals the sum of technical weights,87 and 

(2) the geographic distribution of NPDES permitted facilities in the relevant SIC codes is 

representative of the geographic distribution of regulated facilities. 

For each industry, EPA assumed that the geographic distribution of facilities included in the EPA 

PCS/ICIS database is equivalent to the geographic distribution of the DQ sample frame. To 

implement this assumption, EPA redistributed the weights of DQ facilities in each study region to 

match the geographic distribution of facilities in the PCS/ICIS database. The second and third 

columns in Table A-1 present the estimated distribution of regulated MN facilities based on 

PCS/ICIS data.88

A.2.1.2 Calculating Adjusted Weights for the Benefits Analysis

EPA first compared the regional distribution of DQ facilities to the distribution of facilities 

present in the PCS/ICIS universe. Table A-1 presents the distribution of DQ facilities based on 

technical weights, the weight adjustment factors for MN facilities, and the expected number of 

 

84 EPA did not adjust weights for petroleum refineries because survey screeners were sent to the entire universe and 

DQs were sent to all regulated facilities. EPA assigned a weight of 1 to facilities determined to be in other 

industries after receipt of the DQ. No adjustment was made to these weights. 

85 The SIC code describes the primary activity of the facility. EPA did not convert SIC codes to North American 

Industry Classification codes (NAICS) when developing benefits weights because the industry survey used SIC 

codes and relevant databases were searchable by SIC code.

86 EPA’s reach file (RF1) is a database of interconnected steam segments of “reaches” that comprise the surface 

water drainage system for the United States.

87 As noted in Section A.2, the technical weights account for the number of affected facilities. 

88 EPA used the following databases to obtain information on the number of facilities in each SIC code: FRS 

(Federal Registry System), PCS (Permit Compliance System), ICIS-NPDES (Integrated Compliance Information 

System- NPDES) and TRI (Toxics Release Inventory). None of these databases contains intake flow.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix A: Extrapolation Methods

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DQ facilities for all regions. EPA re-estimated the number of DQ facilities in each region using 

the PCS/ICIS distribution of facilities in that region. This adjustment factor was defined as the 

quotient of the number of DQ facilities within a region and industry divided by the original 

number of weighted DQ facilities assigned to the same stratum. If the PCS/ICIS facilities 

universe indicated that a region had a small number of facilities within a single industry and did 

not have DQ facilities (e.g., the North Atlantic region for the Aluminum sector), EPA assumed 

that no regulated facilities exist within the stratum. 

Because regions without DQ facilities comprised a small fraction of the PCS/ICIS facility 

universe, this assumption is likely to introduce negligible error. If the adjusted weight for a 

sample DQ facility was less than one, EPA used a weight of one to fully count the flow. In the 

economic analysis, EPA estimated that 20 MN facilities will close under baseline conditions.

Accordingly, EPA excluded these facilities from the weights readjustment and benefits analysis. 

The final two columns of Table A-1 present estimated total flow for each sector and region when 

both original DQ and adjusted weights have been applied. In the paper and steel sectors, adjustedweighted AIF is slightly smaller due to the lack of DQ facilities for those combinations of sector 

and region. Conversely, adjusted-weighted AIF in the chemical sector increases slightly due to 

good coverage of DQ facilities, which shifted weights to facilities with above-average flow. 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix A: Extrapolation Methods

May 2014 A-4

Table A-1: MN DQ Distribution and Calculation of Weight Adjustment Factors

Benefits 

Region

Distribution of 

Facilities in 

PCS/ISIS

DQweighted 

Facility 

Counta

Adjustment 

Factorb

Adjusted 

Weight 

Facility 

Count

DQweighted 

AIF

AdjustedWeighted 

AIF Number %

Aluminum

North Atlantic 7 6% 0

c

0 0 0

Mid-Atlantic 11 9% 0 0 0 0

South Atlantic 1 1% 0 0 0 0

Great Lakes 2 2% 3 0.09 0 0 0

Gulf of Mexico 1 1% 0 0 0 0

Pacific 

Northwest 0 0% 0 0 0 0

California 0 0% 0 0 0 0

Inland 95 81% 13 1.01 13 87 88.3

Total 117 100% 16 13 87 88.3

Chemical

North Atlantic 16 1% 0 0 0 0

Mid-Atlantic 75 6% 4 2.14 9 28.7 61.3

South Atlantic 9 1% 4 0.26 1 56.4 14.5

Great Lakes 32 3% 17 0.23 2 80.5 18.7

Gulf of Mexico 100 8% 4 2.85 12 283.9 809.8

Pacific 

Northwest 4 0% 0 0 0 0

California 5 0% 4 0.14 1 1.5 0.4

Inland 951 80% 112 1.04 117 1,782.8 1,860.0

Total 1,192 100% 146 142 2,233.8 2,764.8

Paper

North Atlantic 2 1% 0 0 0 0

Mid-Atlantic 7 2% 0 0 0 0

South Atlantic 8 2% 0 0 0 0

Great Lakes 19 5% 3 1.68 5 6.7 11.2

Gulf of Mexico 2 1% 0 0 0 0

Pacific 

Northwest 3 1% 0 0 0 0

Californiad0 0% 3 1 3 32.2 32.2

Inland 354 90% 91 0.95 84 1,193.3 1,134.30

Total 395 100% 96 91 1,232.2 1,177.7

Steel

North Atlantic 3 1% 0 0 0 0

Mid-Atlantic 5 2% 0 0 0 0

South Atlantic 1 0% 0 0 0 0

Great Lakes 25 10% 6 0.54 3 2,054.3 1,112.1

Gulf of Mexico 3 1% 0 0 0 0

Pacific 

Northwest 1 0% 0 0 0 0

California 2 1% 0 0 0 0

Inland 214 84% 28 1.03 29 519.6 535

Total 254 100% 34 32 2,573.9 1,647.1

Petroleum 

North Atlantic 0 0% 0 0 0 0

Mid-Atlantic 2 11% 2 1 2 203.4 203.4

South Atlantic 0 0% 0 0 0 0

Great Lakes 0 0% 0

e

0 0 0

Gulf of Mexico 1 5% 1 1 1 42.6 42.6
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix A: Extrapolation Methods

May 2014 A-5

Table A-1: MN DQ Distribution and Calculation of Weight Adjustment Factors

Benefits 

Region

Distribution of 

Facilities in 

PCS/ISIS

DQweighted 

Facility 

Counta

Adjustment 

Factorb

Adjusted 

Weight 

Facility 

Count

DQweighted 

AIF

AdjustedWeighted 

AIF Number %

Pacific 

Northwest 0 0% 0 0 0 0

California 1 5% 1 1 1 31.8 31.8

Inland 16 79% 16 1 16 391.2 391.2

Total 20 100% 20 20 668.9 668.9

Other

Inland 2 100% 2 1 2 4.6 4.6

Total 2 100% 2 2 4.6 4.6

Total for All Industries

North Atlantic 28 1% 0 0 0 0

Mid-Atlantic 100 5% 6 11 232 264.7

South Atlantic 19 1% 4 1 56.4 14.5

Great Lakes 78 4% 29 10 2,141.4 1,142.0

Gulf of Mexico 107 5% 5 13 326.5 852.4

Pacific 

Northwest 8 0% 0 0 0 0

California 8 0% 8 5 65.5 64.4

Inland 1,632 82% 261 260 3,978.5 4,013.4

Total 1,980 100% 314 300 6,800.4 6,351.4

a EPA did not adjust weights for petroleum refineries or facilities in “other industries” because they are not in the five SIC codes 

for which EPA developed weights. EPA assumed that these facilities do not represent any other facilities.

b Blank cells indicate that an adjustment factor was not estimated.

c Though these regions account for more than 5 percent of aluminum manufacturers, the average flow for aluminum manufacturers 

is less than 10 mgd. Potential benefits associated with these facilities would be relatively minor. 

d Although the PCS/ICIS data did not identify any paper facilities in the California region, there is 1 facility in this region that 

received a DQ with a weight of 3. This weight was not adjusted.

e There was 1 refinery in the Great Lakes region that received a DQ. However, this facility was assessed as a baseline closure in the 

economic analysis, and thus receives an adjustment factor of 0, and excluded from the benefits analysis.

Sources: U.S. EPA PCS and ICIS-NPDES databases, U.S. EPA analysis for this report

A.2.2 Non-Utility Manufacturers (MU Facilities)

EPA accounted for the geographic distribution of MU facilities using a methodology similar to 

that used for MN facilities. EPA adjusted the weights so that the distribution of the weighted 

number of DQ facilities matched the actual geographic distribution of the facility universe. Under 

this approach, EPA first determined the distribution of regulated facility by study region, and then 

calculated adjusted weights for use in the benefits analysis.

A.2.2.1 Determining the Distribution of Regulated Facilities by Study Region

The entire universe of MU facilities was known based on the survey screener, and the EPA used 

the Online Tracking Information System (OTIS) facility-finder tool was used to obtain facility 

location data.89 EPA distributed the universe of facilities among study regions based on the 

regional distribution of MU facilities with location data from OTIS Facility-finder.

 

89 While the survey screener asked for facilities’ flow, EPA was unable to develop adjustment factors using total 

flow as a control variable.
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A.2.2.2 Calculating Adjusted Weights for the Benefits Analysis

For each study region, EPA compared the estimated number of MU facilities with the DQweighted number of facilities in the region. An adjustment factor was calculated as the quotient of 

the estimated number of facilities in each region divided by the DQ-weighted number of facilities 

in each region. If the adjusted weight for a facility was less than one, EPA assigned a weight of 

one to account fully for the flow of the sampled facility. Accordingly, EPA excluded 9 baseline 

closures from the benefits analysis and weights readjustment.

90 Adjustment factors and adjusted 

flow by benefits region are presented in Table A-2.

Table A-2: MU Adjustment Factors and Adjusted Flow by Benefits Region

Benefits Region

Facility 

Distribution 

from OTIS

DQweighted 

Facilities

Adjustment 

Factora

Total Original 

Weighted Flow 

(mgd)

Total Adjusted 

Weighted Flow 

(mgd)

MU Facilities

North Atlantic 6 5 1.2 220.9 275.3

Mid-Atlantic 4 7 0.5 474.5 384.9

South Atlantic 2 0 No DQs 0.0

Great Lakes 14 12 1.2 1,186.4 1,500.0

Gulf of Mexico 8 6 1.3 577.0 744.0

Pacific Northwest 0 1 0.0 0 0.0

California 2 1 2.0 3.6 7.3

Inland 164 175 0.9 6,841.7 6,615.2

Total 200 207 9,303.7 9,526.7

Non-Utility (NU) Facilities Determined to be Manufacturersb

Inland N/A 12 1.0 386.7 386.7

Total

Grand Total N/A 219 - 9,690.4 9,913.3

Notes:

DQ = detailed questionnaire; mgd = millions of gallons per day; MU = Non-utility manufacturers

a Blank cells indicate that an adjustment factor was not estimated.

b Two facilities that were surveyed as non-utilities were later determined to be non-utility manufacturers, and are analyzed as such 

in the economic and benefits analyses. Their weights were not adjusted because they were not part of the original MU facility 

universe and are both in the inland region. Given that the majority of MU facilities are located in the Inland region, the use of 

original weights is unlikely to bias regional benefit results.

Source: U.S. EPA analysis for this report

A.3 Electric Power Generating Facilities

The benefits analysis for electric power generating facilities uses a combination of weights from 

the 316(b) Phase II and Phase III analyses and new sample weights. Weights from Phase II and 

Phase III accounted for non-sampled facilities and non-respondents to industry surveys and are 

referred to as the original survey weights.

91

When estimating national-level benefits, use of only survey weights based on facility-specific 

(e.g., size and engineering) characteristics can lead to conditional bias. In particular, the original 

survey weights do not not consider factors influencing the occurrence and size of benefits, such as 

 

90 This total includes one facility that would be subject to the New York state regulation of CWIS.

91 In general, the original survey weights are numerically very low, as EPA had either DQ or STQ information for 

621 of the 634 regulated electric generating facilities. For more information on EPA’s Section 316(b) Industry 

Surveys, refer to the Information Collection Request (USEPA 2000).
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix A: Extrapolation Methods

May 2014 A-7

the location of facilities subject to the final rule and regulatory options, AIF, similarities among 

aquatic species affected by these facilities, and characteristics of commercial and recreational 

fishing activities in the area. EPA used a post-stratification weight adjustment to calculate 

benefits weights that account for data dimensions not included in the original sample design. 

These benefits weights re-scale DQ-based weights using additional information from the STQ so 

that total regional flows represented by both weighting systems are equivalent. 

The remainder of this appendix describes the post-stratification weight adjustment for electric 

power generating facilities. Section A.3.1 describes how the strata were defined. Section A.3.2 

presents and discusses the estimates resulting from the post-stratified weighting schemes and 

compares these to the original DQ weights.

A.3.1 Defining the Strata and Control Variables

EPA included six study regions when developing benefits weights for electric power generating 

facilities: North Atlantic, Mid-Atlantic, South Atlantic, Gulf of Mexico, Great Lakes, Inland, and 

California regions. Strata characteristics used to adjust weights are presented in Table A-3.

IM&E is largely a function of mean AIF and characteristics of local fishery resources. Therefore, 

regional, non-recirculated AIF is the most important factor in defining strata for the benefits 

estimation. It is more important to group estimated total benefits by non-recirculated intake flow 

in a study region than by number of facilities. When calculating weights, EPA included a strata 

based on a 125 mgd DIF so that benefit estimates accurately reflect changes in technology under 

the final rule and other options considered under the regulation. 

Table A-3: Matrix of Strata and Control Variables for Adjusting DQ Weights for 

Electric Generating Facilities

Strata

AIF (mgd)

Recirculating Facilitiesa Non-Recirculating Facilitiesb

DIF < 125 mgd DIF > 125 mgd DIF < 125 mgd DIF > 125 mgd

North Atlantic 0 0 238 6,259

Mid-Atlantic 68 0 257 24,203

South Atlantic 46 0 0 5,943

Gulf of Mexico 0 46 0 9,347

Great Lakes 57 181 255 14,774

Inland 1,397 16,060 1,753 98.653

Californiac0 0 62 11,249

Total 1,569 16,286 2,564 170,428

Notes:

DQ = detailed questionnaire; AIF = actual intake flow; DIF = design intake flow; mgd = millions of gallons per day

a Recirculating facilities are facilities with closed-cycle recirculating systems or impoundments that qualify as closedcycle recirculating systems.

b Non-recirculating facilities includes facilities with CWIS classified as once-through.

c The California region includes three facilities in Hawaii.

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix A: Extrapolation Methods

May 2014 A-8

A.3.2 Comparison of Results of the Detailed Questionnaire and Post-Stratified 

Weighting Schemes

EPA assigned post-stratification weights so that tabulations of total mean AIF for each region and 

DIF threshold correspond to the best estimates of AIF. The best estimates, or control totals, for 

each region are calculated using AIF data from the DQ and STQ, and facility-level sample 

weights that account for non-sampled facilities and non-respondents. The DQ total is the total 

AIF of facilities to which weights adjustments are applied. Table A-4 summarizes DQ and control 

totals by region, DIF threshold, and baseline recirculating technology. By design, the poststratification estimate of mean AIF equals the control total estimate (i.e., benefits weights are the 

quotient of the control total divided by the DQ total).

AIF is the most important factor in determining benefits. Therefore,, accounting for flow while 

minimizing the variance of the weights is the best approach. This is accomplished by assigning an 

equal weight to all facilities within a given stratum. One alternative would be to adjust the 

original DQ weight, but that would increase the variance of new weights. The additional variance 

is not likely to reflect the characteristics on which the estimates depend, and therefore these 

weights would be inferior.

Table A-4: Comparison of Results of the DQ and Post-Stratified Weighting Schemesa

Region

AIF for Recirculating Facilitiesb AIF for Non-Recirculating Facilitiesc

DIF < 125 mgd DIF > 125 mgd DIF < 125 mgd DIF > 125 mgd

DQ 

Total 

(mgd)

Control 

Total 

(mgd)d

DQ 

Total 

(mgd)

Control 

Total 

(mgd)d

DQ 

Total 

(mgd)

Control 

Total 

(mgd)d

DQ 

Total 

(mgd)

Control 

Total 

(mgd)d

North Atlantic 0 0 0 0 209 238 3,163 6,259

Mid-Atlantic 58 68 0 0 231 257 7,649 24,203

South Atlantic 0 46 0 0 0 0 2,391 5,943

Gulf of Mexico 0 0 46 46 0 0 5,963 9,347

Great Lakes 0 57 0 181 66 255 4,002 14,774

Inland 615 1,397 3,223 16,060 1,036 1,753 46,235 98.653

Californiae0 0 0 0 62 62 1,205 11,249

Total 673 1,569 3,269 16,286 1,604 2,564 70,609 170,428

Notes:

DQ = detailed questionnaire; AIF= actual intake flow; DIF = design intake flow; mgd = millions of gallons per day

a A limited number of total STQ facilities did not have a DQ facility to represent them within the technology class (recirculating 

versus non-recirculating), region, and DIF strata. Their flow was added to the respective totals for the other technology class when 

calculating benefits weights, and is assigned the same benefits weights as the other technology class within the same region and 

DIF stata.

b Recirculating facilities are facilities with closed-cycle recirculating systems or impoundments that qualify as closed-cycle 

recirculating systems.

c Non-recirculating facilities include facilities with CWIS classified as once-through.

d The control totals are the best estimates for each region are calculated using operational flow data from DQ and STQ, and facilitylevel sample weights that account for non-sampled facilities and non-respondents.

e The California region includes three facilities in Hawaii.

Source: U.S. EPA analysis for this report
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A.4 Adjustment for State Regulations of CWIS

EPA also included an adjustment to account for the California and New York state regulations of 

CWIS. The California state regulation requires closed-cycle recirculating systems for coastal 

electric generating facilities and the New York state regulation requires closed-cycle recirculating 

systems for all in-state facilities with DIF greater than or equal to 20 mgd. Fourteen surveyed

facilities fall within the scope of the California state regulation and 32 surveyed facilities fall 

within the scope of the New York state regulation. EPA’s benefits analysis assigns these facilities 

baseline IM&E commensurate with compliance with the state regulations.

EPA included a weight adjustment to account for the state regulations because the assumed 

technology (i.e., closed-cycle recirculating system) at facilities which are within the scope of the 

state regulations does not accurately represent technology at facilities which are not within the 

scope of the state regulations. Failing to account for state regulations would result in the 

underestimation of baseline IM&E losses and IM&E reductions under the final rule and options 

considered. 

EPA calculated the best estimate of flow for facilities subject to state regulations (i.e., control 

flow) based on the difference between total DQ-weighted flow in each region with these facilities 

included and excluded from the weighting analysis. Table A-5 presents the regional DQ-weighted 

AIF and control AIF totals for facilities subject to state regulations. EPA adjusted the DQweighted total for each region upward to match the respective control total. In the California 

region, EPA only adjusted weights for coastal generators within the state of California; it did not 

adjust weights for California manufacturing facilities and Hawaii facilities which are not subject 

to the state regulation. The Mid-Atlantic, Great Lakes, and Inland regions all include facilities 

which are subject to the New York state regulation. For these regions, EPA grouped generators 

and manufacturers when estimating adjustment factors to ensure that each region had at least one 

DQ facility to represent facilities within the region subject to the New York state regulation. 
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Table A-5: Matrix of Strata and Control Variables for Facilities Subject to State 

Regulations for CWIS

Region

Weighted AIF 

Including Facilities 

Subject to State 

Regulations (mgd)

(a)

Weighted AIF 

Excluding Facilities 

Subject to State 

Regulations (mgd)

(b)

DQ Total 

(mgd)

Control Total 

(mgd)

(a-b)

North Atlantic 6,772 6,772 0 0

Mid-Atlantic 25,199 16,862 1,043 8,337

South Atlantica5,943 5,943 0 0

Gulf of Mexico 10,989 10,989 0 0

Great Lakes 17,639 13,840 281 3,799

Inland 131,291 127,730 3,351 3,561

California –

Coastal Generators 10,175 0 895 10,175

California –

Manufacturers and 

Hawaii Facilities

1,221 1,221 0 0

Total 209,230 183,357 5,569 25,872

Notes:

AIF = actual intake flow; DQ = detailed questionnaire; mgd = millions of gallons per day

Source: U.S. EPA analysis for this report
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May 2014 B-1

Appendix B: Consideration of Potential Effects due to Thermal 

Discharges

B.1 Introduction

Impacts of thermal discharges, along with other stressors, are a relevant consideration when 

assessing the potential impacts of electric power facility cooling water intakes and associated 

discharges. Several studies have demonstrated the adverse effects that increased temperatures or 

altered seasonal thermal regimes have on local biota and fauna. In some cases, studies have 

indicated little or no apparent harm is caused by the thermal discharges. This emphasizes the need 

for NPDES permit writers to consider site-specific factors when assessing the potential ecological 

effects due to thermal discharges. 

This appendix provides information on the general effects of thermal discharges on aquatic biota 

and ecosystems, considers the influence of site-specific factors and environmental settings on 

determining the level (if any) of ecological impacts, and discusses limitation and uncertainty 

associated with thermal studies. This appendix also presents three case studies from power 

facilities in different environmental settings (Brayton Point Station, Quad Cities Nuclear Station, 

and Point Beach Nuclear Plant) which underwent detailed thermal studies under CWA section 

316(a) provisions, and which show the importance of site-specific factors in determining the 

potential for appreciable harm. The section 316(a) demonstrations described in the three case 

studies represent unusually complete and thorough investigations of thermal impacts to receiving 

aquatic ecosystems. Thermal investigations at other power facilities are highly site specific, but 

typically have a much reduced scope and effort compared to those portrayed by the case studies.

It should be noted that even at power facilities where demonstrations of no appreciable harm have 

been made to regulatory authorities under section 316(a), supporting thermal studies nonetheless 

often show periods during which thermal limits are exceeded. Impacts of thermal discharges 

should therefore be revisited on a case-by-case basis as conditions change, for example (i) if 

facilities increase their power capacity (i.e., “uprate”) and increase thermal loads to the receiving 

waterbody; (ii) if the thermal assimilative capacity of the receiving waterbody is otherwise 

compromised; or (iii) in the face of new evidence that cooling water discharges are causing 

appreciable harm to the balanced, indigenous population/community of shellfish, fish, and 

wildlife or fail to ensure the protection or propagation of the population. Such assessments need 

to consider the extent, duration, timing, and frequency of adverse thermal impacts, the target 

threshold temperature for each species, the potential for adverse temperature effects on larger 

ecological processes, and other relevant site-specific factors.

B.2 General Effects of Thermal Discharges on Aquatic Biota and 

Ecosystems

Thermal discharges affect aquatic organisms by elevating water temperatures or altering seasonal 

patterns of temperature change. Temperature is a vitally important variable for aquatic 

ecosystems, affecting virtually all biota and biologically mediated processes, chemical reactions, 

as well as structuring the physical environment of the water column. There is a well-established

scientific literature cataloguing the impacts of elevated or variable temperature on a wide 
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May 2014 B-2

spectrum of aquatic life, including numerous species-specific determinations of thermal tolerance 

limits for growth, survival, reproduction, and behavior (e.g., Beitinger et al. 2000; Leffler 1972; 

McMahon 1975).

Much of the relevant primary research on power plant thermal discharges dates from the 1970's1980's; typically based on laboratory studies, field investigations, or environmental impact 

assessments associated with the siting, permitting, and/or operation of power facilities with 

significant thermal plumes (e.g., Barnett 1972; Coles 1984; Hillman et al. 1977; Langford 1990 

(for review); Squires et al. 1979). These studies found that the thermal discharges may affect 

aquatic species growth, survival, and reproduction, alter community diversity and density, and 

may have led to shifts in ecological habitat. The character and magnitude of the observed impacts 

varies among the studies, however. 

Interest in this topic and relevant studies have also re-emerged in the last decade as part of a 

greater effort associated with the assessment and characterization of potential effects of global 

climate change (e.g., Schiel et al. 2004). The material below provides a representative, exemplary 

mix of studies on thermal effects for organisms and communities in a range of trophic levels or 

ecosystems with some emphasis on more recent research. The majority of the cited studies were 

identified from internet searches and cross-referencing appropriate permitting databases.92

B.2.1 Primary Producers

Thermal discharges affect aquatic primary production through direct effects on photosynthetic 

activity and selection of temperature-tolerant species in phytoplankton, periphyton, macroalgae 

and submerged aquatic vegetation (SAV), and indirectly through temperature-related changes in 

nutrient availability and grazer activities. Several studies reported that thermal discharges 

substantially altered the local abundance and structure of the aquatic community, particularly 

benthos and periphyton (e.g., Chuang et al. 2009; Martinez-Arroyo et al. 2000; Schiel et al. 2004; 

Squires et al. 1979). Studies by Mallin et al. (1994) suggest that indirect effects of discharge 

altered the phytoplankton community taxonomic structure near the outfall and in general, support 

different communities of algae than those present in the background waters. Several authors 

suggest that residual chlorine (anti-fouling agent) may also influence these patterns (Choi et al. 

2002; Moss Landing Marine Laboratories 2006; Poornima et al. 2005). 

B.2.2 Primary Heterotrophs

The bacterial and microbial components of aquatic ecosystems generally have a positive response 

to increasing water temperature – growth rates and bacterially mediated processes are enhanced 

until temperature tolerance limits are approached. Most studies found that the growth rates of 

bacteria and water temperatures are positively correlated. In contrast, Choi et al. (2002) found 

lower rates of bacteria production near outfalls but attributes this effect to residual chlorine in the 

discharge water rather than temperature alone. 

 

92 Abt Associates used several general search engines for preliminary searches for scientific and grey literature 

including Scirus: http://www.scirus.com/; Google Scholar: http://scholar.google.com/; and Dogpile: 

http://www.dogpile.com/, as well as publicly available information from NPDES permits and related section 

316a/316b studies.
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B.2.3 Zooplankton

Zooplankton and other pelagic macroinvertebrates typically increase their grazing activities and 

growth rate in response to increased temperature. Marasse et al. (1992) observed a higher rate of 

bacteria consumption (i.e., bacterivory) by samples of plankton that were incubated at higher 

temperatures. Jiang et al. (2009) suggests that copepod species with larger body sizes are more 

sensitive to thermal increases, and that this water temperature increase induces mortalities of 

copepods. As noted for other organisms, estuarine copepods have more tolerance to thermal stress 

than those from more stenothermal, deepwater environments. 

B.2.4 Benthic Community

Benthic species and communities are often particularly vulnerable to thermal discharge due to 

association with the substrate and limited ability to migrate from impacted areas. Growth rates 

and spawning times are usually accelerated by increased temperature (Barnett 1972). McMahon 

(1975) and Leffler (1972) found that snails and blue crabs, respectively, exhibit more rapid 

growth at higher temperatures, but both studies also observe greater species mortality. The study 

by Coles (1984) found a positive effect with the thermal effluent as both the number of organisms 

and the colonization by coral reef propagules near the outfall were significantly greater than 

background areas. A recent study of benthic communities and associated biota near a nuclear 

power plant discharge show that the thermal pollution alters composition and decreases richness 

in benthic cover (Teixeira et al. 2009). 

B.2.5 Fish

Fish are extremely well-studied with regard to temperature tolerance and thermal limits in both 

the laboratory and field. The thermal habitat requirements of coldwater, coolwater, and 

warmwater fish species are well-characterized (e.g., Beitinger et al. 2000; Sullivan et al. 2000), 

and these may be the basis for regulatory sub-classification of water bodies. Thermal discharges 

can influence the spatial distribution of fish due to direct responses to altered temperature (i.e., 

attraction, avoidance), effect on dissolved oxygen concentrations, and impacts to prey and habitat 

availability (Cooke et al. 2004; Sullivan et al. 2000). Rapid fluctuations and decreases in water 

temperature, usually associated with steep thermal gradients in temperate winter waters, can lead 

to “cold shock” with reduced survival (Ash et al. 1974; Deacutis 1978). 

Smythe and Sawyko (2000) evaluated the effect of “cold shock” on fish and found no effect on 

larger predator species, though a forage species (gizzard shad) had lower survival rates. Some 

studies of thermal discharges have not observed significant effects in local fish communities. 

Hillman et al. (1977) and Krishnamoorthy et al. (2008) found that impacts on shore-zone fish and 

fingerlings from power station discharges were minimal. A study of salmonids by Sullivan et al. 

(2000) maintains that direct mortality from temperature is unlikely since acute lethal temperatures 

are rarely, if ever, observed in the field. Specifically, this study suggests that there is little or no 

risk of mortality if the annual maximum temperature is less than 26°C, but suggests a site-specific 

analysis when annual maximum temperatures exceed 24°C. 

B.2.6 Ecosystem Functions and Services

In addition to the species-specific impacts, investigators have looked at the effects of thermal 

discharges on the structuring of species assemblages and communities, as well as secondary 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix B: Thermal Discharges

May 2014 B-4

ecosystem function and services. Thermal discharges may have both detrimental and beneficial 

effects. For example, the bleaching and destruction of coral reefs by elevated thermal discharges 

is well documented, but Coles (1984) in the Moss Landing study found that the thermal effluent 

may have some beneficial effects, such as enhancing new coral regrowth or providing preferred 

water temperatures for avian birds and mammals. 

Work in seven Southeastern U.S. cooling reservoirs indicated that direct thermal effects on 

phytoplankton communities were generally minimal, but that the smaller reservoirs were more 

prone to algal blooms due to nutrient trapping and elevated temperatures (Mallin et al. 1994). 

Indirect effects of excessive thermal loads in these reservoirs caused ecosystem-wide alterations 

arising from both top-down (higher trophic consumers) and bottom-up (primary producers) 

effects. Martinez-Arroyo et al. (2000) found that phytoplankton subjected to elevated water 

temperature exhibited lowered photosynthetic capacity and light harvesting efficiency, and 

required more light to reach a net oxygen production. Thus, primary production and oxygen 

levels, both critical ecosystem functions, may be decreased as a result of elevated temperatures. 

Teixeira et al. (2009) evaluated the effect of thermal discharge on fish communities and habitat 

structure in rocky substrates near a nuclear power plant in southeastern Brazil. Their studies 

indicate the heated effluents affected habitat structure as well as fish community structure and its 

eco-spatial distribution. Lowered fish species richness was observed in the impacted area, 

attributed to a reduction in benthic cover of a habitat-forming species (Sargassum sp.).

B.3 Influence of Site-Specific Factors and Environmental Setting on 

Thermal Effects

As noted above, the environmental setting (i.e., the nature of the receiving waters) can have a 

pronounced influence on the potential for and the magnitude of adverse thermal impacts on biota. 

While physical features near the discharge and temporal climatic patterns usually dictate the 

observed level of thermal deviations for any given discharge, several environmental factors may 

be important in determining the magnitude of potential impacts, including: geographic location, 

marine vs. freshwater environments, volume of receiving water, rate of water exchange, other 

heat loads, and local habitats. 

B.3.1 Geographic Location

Geographic location determines the duration and intensity of annual solar heating and usually 

dictates the resulting maximum ambient temperatures for the receiving waters. The more 

southerly the facility, the higher the seasonal temperature maxima is likely to be, increasing the 

possibility of reaching upper thermal temperature limits for sensitive organisms. Despite 

acclimation, relatively few North American aquatic organisms will tolerate chronic water 

temperatures in excess of 35-40oC (Brock 1985). 

Northerly receiving waters will have lower maximum ambient temperatures in summer, but will 

also exhibit greater seasonal variation; with a more extreme temperature gradient between 

discharge and surface water during winter. Conversely, sub-tropical water temperatures have less 

seasonal variation, and a more consistent thermal gradient is maintained between discharge and 

ambient conditions. Adverse effects to aquatic organisms are generally most pronounced at the 

acute and chronic high lethal temperatures and/or due to rapid fluctuations (e.g., "cold shock").
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix B: Thermal Discharges

May 2014 B-5

B.3.2 Marine vs. Freshwater Receiving Waters

Adverse thermal impacts have been documented in both freshwater and marine ecosystems, but 

the likelihood of impacts may be considered slightly greater in freshwaters simply due to the 

presumption that marine waters constitute a greater thermal reservoir due to larger volume and 

tidal flushing. However, as noted above, site-specific features will dictate the effective volume 

and the flushing rate, which are likely to be the key to vulnerability of receiving water ecosystem 

to thermal impacts. Clearly, the magnitude of thermal impacts also depends on the composition of 

the local biota and whether such organisms are temperature-sensitive. The sensitivity of 

coldwater freshwater fish (e.g., trout, salmonids, darters) to increased water temperature and 

associated lowering of available dissolved oxygen has been well characterized (Beitinger et al. 

2000; Sullivan et al. 2000). There is less temperature-sensitivity in marine estuarine fish, which 

are often more tolerant than offshore fish, since estuarine fish are subject to regular 

environmental fluctuations.

B.3.3 Receiving Water Volume

The volume of the receiving water is a critical factor since it determines the total amount of heat 

that can be absorbed by a water body while still remaining at an acceptable temperature. The 

effective volume subject to the thermal discharge may be significantly less than that of the entire 

water body if it is constrained physically (e.g., narrow discharge channel, small coastal 

embayment) or can vary in the short term (e.g., low tide, hydropower releases), seasonally (e.g., 

thermally stratified lakes, salinity stratified estuary), or longer (e.g., multi-year droughts). Due to 

the buoyant properties of warm water, the effective mixed volume can be reduced even further if 

the thermal plume is not effectively or rapidly mixed into the receiving waters. 

B.3.4 Rate of Water Exchange

The rate of water exchange is another factor which can compensate for a small effective volume. 

A short hydraulic residence time (HRT) (i.e., rapid flushing) of the receiving water at the point of 

the thermal discharge can rapidly dissipate a high heat load. Large fast rivers, open ocean outfalls, 

and coastal embayments with sweeping longshore currents, etc. can generally better tolerate 

thermal discharges and have limited or highly localized impacts to biota. Poorly flushed systems, 

those with seasonal flow minima, or episodic hydrologic inputs, are more likely to experience 

widespread or persistent thermal impacts. In some cases, the flow or volume of the thermal 

discharge may be very much greater than the receiving water. 

B.3.5 Local Land Use

Local land uses may also be influential in that they can provide additional thermal loads to the 

water body independent of the thermal discharge. Developed urban watersheds with large 

percentages of impervious cover may produce large storm water flows with temperatures that are 

well above ambient temperatures in the receiving waters. Agricultural lands and irrigation return 

water may also increase local thermal loading. Channelization and removal of riparian buffer 

vegetation can increase water temperature through lack of shading, reflective artificial substrates, 

and removal of deep pool habitats. 
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B.3.6 Local Habitats

Benthic biota and/or habitats (e.g., oyster reefs, eelgrass, and mussel beds) found in nearshore 

environments are often subject to greater impact since these largely sessile communities are 

affixed to the substrate. On the other hand, mobile aquatic organisms can track temperature 

change and fine-tune their temporal and spatial distribution (Cooke et al. 2004). Biota can 

sometimes avoid adverse thermal impacts by seeking out localized areas of cooler or better 

aerated waters (e.g., deep pool, tributary stream, bottom waters) for short-term or seasonal 

residence. These areas provide habitat that may allow the temperature-sensitive organisms to 

persist and emigrate back into the affected water body once the thermal stress is reduced. Thermal 

effects could be more severe in homogenous environments (e.g., open water column, unstratified 

reservoir) where the biota does not have access to these refugia. Thermal displacements from 

spawning habitat due to dam construction and operation (e.g., bottom water releases) has also 

been a concern in western rivers and elsewhere (Bartholow et al. 2004; Hayes et al. 2006). 

B.4 Uncertainties and Limitations of Assessing Thermal Impacts

One of the major difficulties in accurately characterizing the influence of thermal discharges on 

aquatic communities is the uncertainty due to the potential influence of other abiotic water quality 

factors. Thermal discharges from power plant cooling systems often contain elevated levels of 

additional constituents including, but not restricted to: residual chlorine, total suspended solids, 

total dissolved solids, cleaning agents and surfactants, metals, and nutrients. The presence of 

these constituents may complicate the interpretation of the environmental factor(s) that are 

responsible for observed changes in biotic communities. 

For example, several of our studies on thermal effects on primary producers noted that residual 

chlorine in the discharge may be responsible for some of the observed effects (Chuang et al. 

2009; Poornima et al. 2005). Interaction of thermal effects and heavy metals was responsible for 

some phytoplankton taxonomic changes in one reservoir investigated by Mallin et al. (1994). 

Looking at the behavior of smallmouth bass, Cooke et al (2004) found that a majority of a local 

radio-tagged population overwintered in the warmest portions of a thermal discharge to Lake 

Erie. However, this area also was high in habitat complexity, had adequate flow velocity refuges, 

and abundant forage, so selection for this habitat may not be a simple thermal preference. 

Adverse temperature effects may also be more pronounced in aquatic ecosystems which are 

already subject to other environmental stressors such as high biochemical oxygen demand (BOD) 

levels, sediment contamination, or pathogens. Thermal discharges may have indirect effects on 

fish and other vertebrate populations through increasing pathogen growth and infection rates. 

Langford (1990) reviewed several studies on disease incidence and temperature, and while he 

found no simple, causal relationship between the two, he did note that it was clear that warmer 

water enhances the growth rates and survival of pathogens, and that infection rates tended to be 

lower in cooler waters.

B.5 Case Studies

Three case studies were selected for large power generating stations from which thermal 

discharges may have a potential impact to the local aquatic community/ecosystem. These three 

case studies provide examples of investigations of thermal impacts in different environmental 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix B: Thermal Discharges

May 2014 B-7

settings (marine coastal embayment, coastal Great Lake, and freshwater river), and at differing 

spatial scales (community, habitat, ecosystem). 

B.5.1 Brayton Point Station

Brayton Point Station (BPS) is a 1538 megawatt (MW) coal and oil-fired electrical generating 

station located in Somerset, MA. This facility takes cooling water from and discharges heated 

effluent to Mount Hope Bay (MHB), a large coastal embayment within Massachusetts and Rhode 

Island. Generation Unit 1 began operating in 1963, Unit 2 in 1964, Unit 3 in 1969, and Unit 4 in 

1974 (Dominion 2011). 

One of the most thorough examinations of the individual and cumulative effects of a power plant 

thermal discharge was conducted as part of the regulatory review of the CWA section 316(a) 

variance request application submitted in May 2001 as part of the NPDES discharge permit 

(Permit No. MA 003654) renewal for BPS. The permitee’s 316(a) variance request application 

sought to keep the existing permit temperature criteria (maximum temperature of 95oF; delta 

(departure from ambient) temperature of 22oF), and to reduce the total heat load from the existing 

permit limits. However, these thermal criteria were still less stringent than what would be 

required by either technology-based or water quality-based discharge limits. 

CWA 316(a) authorizes alternative thermal discharge limits when it is demonstrable that the 

proposed thermal limits “will assure the protection and propagation of a balanced indigenous 

population (BIP) of shellfish, fish, and wildlife in and on that body of water.” To evaluate 

whether the thermal limits proposed in the May 2001 316(a) variance request application would 

meet this protective criterion, EPA, in accordance with the 316(a) Technical Guidance Manual 

(USEPA 1977), conducted a review of the historical and current conditions of MHB biota on a 

community-by-community evaluation, and considered potential thermal impacts to 

phytoplankton, zooplankton, habitat formers, shellfish, finfish, and other vertebrate (i.e., sea 

turtles and mammalian) wildlife. The findings of the community impact analyses are contained in 

the “Clean Water Act NPDES Permitting Determinations for Thermal Discharge and Cooling 

Water Intake from Brayton Point Station in Somerset, MA” (USEPA 2002a) dated July 22, 2002 

(hereafter “Determinations”) and summarized below. 

For each of the community types, the Determinations provides a preliminary consideration of 

whether the community’s nature, estuarine setting, and water column distribution within MHB 

relative to the location and magnitude of the BPS thermal discharge would result in a finding of 

“low potential impact areas” and lessened environmental concerns for the granting of the 316(a) 

variance. For those communities in MHB for which a “low potential impact” conclusion was not 

possible, the severity of the thermal effect was gauged by comparison to a list of a priori decision 

criteria for each community. 

EPA judged that MBH was not a low potential impact area for phytoplankton. As seagrasses and 

salt marshes have historically declined in importance in MHB, the phytoplankton community is 

the dominant primary producer (USEPA 2002a). The recent (2001) occurrence of a nuisance 

blue-green algal bloom (dominated by the cyanophyte Anacystis aeruginosa) in MHB near BPS 

may be due to the high nutrients and warm water temperatures which favor formation of such 

bloom. It was considered likely that thermal plume from BPS was a contributing factor. 

Perhaps of greater importance is the finding that the MHB phytoplankton community does not 

undergo the typical winter-spring phytoplankton bloom cycle (Keller et al. 1999). Extensive work 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix B: Thermal Discharges

May 2014 B-8

was conducted on plankton communities in experimental mesocosms where temperature was 

shifted to mimic the expected thermal conditions in MHB surface waters. Extrapolating these 

changes seen in the mesocosms, such changes in phytoplankton population dynamics could very 

likely lead to significant impacts within the trophic dynamics of the MHB food web. Redirecting 

carbon away from benthic consumers and into pelagic food webs could represent a reduction in 

prey species for benthic-feeding finfish such as winter flounder, windowpane flounder, 

hogchoker, and tautog. 

EPA judged that MHB was not a low potential impact area for zooplankton since it is an estuary 

that serves as a spawning site for numerous fish and invertebrate species (USEPA 2002a). The 

most noticeable thermal effect in this community is the recent increase in abundance of the 

ctenophore Mneimiopsis leidyi, and increased overwintering in MHB for this formerly seasonal 

resident. Dramatic increases in comb jellies (i.e., ctenophores) are usually indicative of stressed 

ecosystems with symptoms of increased water temperatures, increased nutrient levels, and 

depleted fish stocks (Pohl 2002). Since M. leidyi is a voracious consumer of pelagic fish eggs as 

well as zooplankton by which it competes with young-of-year winter flounder, it was concluded 

that BPS was significantly contributing to thermal increases in MHB, and facilitating expansion 

of the range and time of year distribution of the comb jellies.

Eelgrass is a coldwater plant that ranges from North Carolina to Canada and grows well in softbottom, low energy environments. Despite the current lack of eelgrass, the EPA judged that MBH 

was not a low potential impact area for habitat formers since the historic presence of extensive 

eelgrass meadows shows that it is capable of supporting this habitat type (USEPA 2002a). 

Experimental work has shown that optimal temperature ranges for photosynthesis decrease with 

increasing turbidity (Bulthuis 1987) so that in turbid waters, eelgrass growth decreases with 

increased temperature, because photosynthetic rates decrease and respiration rates increase. Based 

on the current lack of eelgrass, it was concluded that the combination of poor water quality and 

increased water temperature result in an “exclusion zone” for eelgrass growth in MHB (USEPA 

2002a). Since BPS helps to elevate the water temperature over significant portions of the bay, it is 

considered a contributory cause to this exclusion.

EPA judged that MBH was not a low potential impact area for shellfish and macroinvertebrates 

due to the presence of commercially important species, the “substantial” densities of these 

species, the spawning and nursery areas in MHB, and the important role in ecosystem function 

that this community provides (USEPA 2002a). Benthic sampling indicated that there have been 

no significant changes in the benthic community between the 1970’s and mid-1990’s or over the 

span of time when BPS has been active and the annual heat flux was increased. The sampling also 

indicates a strong representation in the benthic community of the amphipod Ampelisca which is a 

preferred prey item for juvenile winter flounder. Overall, EPA found no substantial evidence of 

harm to shellfish and macroinvertebrates from the current thermal discharge, and any alternative 

which reduces the thermal discharge would be acceptable.

EPA judged that MHB was not a low potential impact area for finfish due to the presence of 

numerous recreational and commercially important species, the important spawning and nursery 

areas, and the potential for blockage of fish migration (USEPA 2002a). The analysis for finfish 

was specifically targeted at determining the appropriate thermal discharge limits for BPS in order 

to protect finfish populations, and included a retrospective examination of total finfish abundance 

trends in relation to plant operations. The analysis determined an acceptable annual flux of heat 

into MHB that is protective of finfish populations, based on the temperature thresholds for acute 
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May 2014 B-9

and chronic mortality as well as for several sub-lethal effects for some representative important 

species (RIS).

The finfish stocks in MHB have declined precipitously since 1984-1985, a period which marked 

the shift of Unit 4 at BPS from closed-cycle recirculating to once-through cooling operations. 

Further, work by Gibson (2002) suggests that winter flounder have been declining since at least 

the initiation of sampling in 1972. Although BPS had been operational for 9 years at that point, 

no fishery data are available to estimate what the finfish community was like prior to 1972. 

Comparison of the record of annual heat flux to MHB over that last 28 year period to records of 

finfish abundance led EPA to conclude that an annual heat flux of 28 trillion British thermal units 

(tBTU) to MHB, as proposed in the 316(a) variance request application, would be unable to stop 

or reverse a decline in fish populations, and thus would not be protective of the finfish 

community.

The temperature tolerance limits of 16 RIS were reviewed to establish temperature thresholds for 

the more sensitive of these species (winter flounder, striped bass). These thresholds were used to 

establish critical temperatures for three target depth strata (surface, middle, and bottom waters) at 

two key seasonal periods (winter, summer). Winter corresponds to the period (March 1 -31) of 

active winter flounder spawning, and when large numbers of larval planktonic winter flounder are 

present in MHB. The summer index period (July 15 – August 15) corresponds to the warmest 

time of the year. 

Predictive hydrothermal models (CORMIX for near-field effects; WQMAP for far-field effects) 

of MHB provided a means of evaluating the potential thermal impacts caused by the current (i.e., 

existing permit), the proposed (i.e., the requested 316(a) variance), and two alternative reduced 

heat flux options for BPS operations, as well as a “no-plant” condition. During warm summer 

conditions, the proposed operational heat flux would impact 62 percent of the bottom water strata 

as compared to 4 percent under a no-plant scenario, while other alternative operating options

would have reduced impact proportional to their proposed total heat fluxes. Using this method, it 

is possible to show impacts to all target depth strata during summer conditions and impacts to the 

bottom strata during winter. 

The study also considered other heat effects on finfish caused by the thermal discharge. The first 

involved the attractive nuisance nature of the thermal plume (USEPA 2002a). The plume acts as 

an attractant for large numbers of striped bass and bluefish in the fall and winter, and disrupts the 

seasonal migration of these species. The crowding of large numbers of these species into a 

restricted area increases the potential for weakening or disease since the warm temperatures 

increase the metabolism of these fish at the same time there is reduced feeding due to a lack of 

prey. 

Similarly, the trapping of Atlantic menhaden in the thermal plume affects the migration of this 

species, and likely increases impingement mortality and entrainment (IM&E) due to longer 

periods spent in proximity to intake structures, which has been evidenced by several recent large 

winter impingement loss events. Another effect noted was the establishment in MHB of 

smallmouth flounder (Etropus microstomus) which is at the northern limit of its geographic 

distribution range. It is important to note that an increased abundance or distribution shift to a 

warm water species is not indicative of protection of a BIP. 

EPA judged that MBH is a low potential impact area for other vertebrate life since it is not a 

significant habitat for marine mammals or sea turtles (USEPA 2002a). Overall, there is no 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix B: Thermal Discharges

May 2014 B-10

potential for harm from the current thermal discharge, and any alternative which reduces the 

thermal discharge would be acceptable.

A summary of current ecosystem thermal effects and predicted impacts associated with the 

proposed thermal flux was prepared (USEPA 2002a). The current thermal effects for which there 

appears to be no disagreement include:

 Appearance of nuisance algal blooms;

 Absence of normal winter-spring phytoplankton bloom; 

 Overwintering of the ctenophore Mneimiopsis leidyi; 

 Overwintering of striped bass and bluefish in discharge canal;

 Increased abundance of smallmouth flounder in MHB;

 Thermal avoidance of most of MHB by adult winter flounder; and

 Multiple fish kills as a result of large impingement events in the winter.

Evaluating the proposed 316(a) variance request, EPA predicted that, under the proposed thermal 

discharge under the 316(a) variance request, the following would occur:

 Large areas of MHB would be avoided by juvenile winter flounder and striped bass 

during warm summer months;

 Extensive areas of MHB would experience water temperatures resulting in chronic 

toxicity to juvenile winter flounder;

 Reduced winter flounder egg hatching success for the entire MHB for the warmest winter 

months;

 Increased predation on winter flounder eggs and larvae by sand shrimp; and 

 Potential exclusion of eelgrass.

EPA also considered potential impacts from other stressors that could be responsible for mortality 

of finfish in MHB; including overfishing, predators, water quality, brown tides, and IM&E

(USEPA 2002a). Each of these stressors was examined for its potential role in causing or 

contributing to the finfish collapse. Analyses of these other potential stressors indicated that while 

possibly contributory, the adverse effects of each were generally exacerbated by the thermal 

conditions caused by the BPS plume. 

Based on the hydrothermal and ecological analyses conducted and documented in the 

Determinations document, EPA concluded that a BIP has not been maintained in MHB, and that 

the current BPS thermal discharge is a significant contributor to this problem (USEPA 2002a). 

Further, the proposed thermal reductions in annual heat flux contained in the 316(a) variance 

request application would not allow for the recovery of the winter flounder or the wider balanced 

indigenous ecosystem. Accordingly, EPA denied the permitee’s variance request, and reissued the 

NPDES permit in 2003 with the provision for installing closed-cycle recirculating systems in all 

four of the power units.

B.5.2 Quad Cities Nuclear Station

Quad Cities Nuclear Station (QCNS) is a dual-unit nuclear fueled steam electric generating 

facility (SIC 4911) located on a 765-acre site along the Mississippi River in Cordova, Illinois. 

QCNS Units I (866 net megawatts (MW)) and 2 (871 net MW) began commercial production of 

electricity in 1973. QCNS withdraws water from the Mississippi River for non-contact condenser 

cooling and various service water uses. After passing through the condensers, the cooling water 

from Units 1 and 2 mixes and then exits to the River via a discharge canal. QCNS is located on 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix B: Thermal Discharges

May 2014 B-11

Pool 14 of the Mississippi River, at approximate River Mile 506.5 above the confluence of the 

Ohio River.

The thermal discharge is authorized under the Station’s NPDES Permit, issued by the Illinois 

EPA (ILEPA). Thermal limits in the NPDES Permit are based on Illinois environmental 

regulations, and studies and Demonstrations related to the thermal plume are performed under 

CWA section 316(a). During the latest NDPES permit renewal cycle, QCNS requested issuance 

of a 316(a) variance for a proposed alternative thermal standard, specifically relaxation of a 

maximum thermal excursion temperature limits by 2oF during late summer months (JulySeptember), which would increase the predicted frequency of expected thermal excursions from 1 

percent to 3 percent. This variance request was based on a demonstration that future operations 

of QCNS would assure the protection and propagation of a balanced indigenous community 

(BIC) of fish, wildlife, and shellfish, particularly within Pool 14.

To evaluate the potential thermal impacts of QCNS’ discharge on Pool 14, a number of

comprehensive studies were conducted (including thermal plume modeling and field surveys, 

review of current (“prospective analysis”) and historic (“retrospective demonstration”) biota 

monitoring, and water quality assessment. The thermal plume modeling is contained in “River 

temperature predictions downstream of Quad Cities Nuclear Generating Station” (Holly Jr. 

et al. 2004). The elements and findings of the biological and water quality assessments are 

contained in the “Quad Cities Nuclear Station Adjusted Thermal Standard CWA 316(a) 

Demonstration, Final Draft” (HDR 2009) dated November 2009 (hereafter “Demonstration”) and 

summarized below.

The thermal plume model study was able to successfully reproduce temperature field data 

(collected September 2003) without any adjustment of non-physical parameters (Holly Jr. et al. 

2004). The model was used to show compliance of the thermal plume with the proposed 

alternative standard. The model validation revealed the importance of including site-specific 

river-entraining structures such as wing dams and chute closure dams in the model, as these have 

an important influence on the thermal flow patterns in the vicinity of the QCNS and local 

Steamboat Island (Holly Jr. et al. 2004). 

Current and past monitoring efforts have collected data on a variety of aquatic communities, 

including phytoplankton, zooplankton, benthic macroinvertebrates (including freshwater 

mussels), ichthyoplankton, and finfish, which are summarized in the Demonstration (HDR 2009). 

For the prospective assessment, QCNS conducted comprehensive literature surveys, analyzed 

field data, and followed EPA approved protocols for assessing potential thermal impacts on RIS 

of fish. RIS species selected for the QCNS Demonstration included largemouth bass, channel 

catfish, spotfin shiner, and walleye. River and plant operating conditions were selected to provide 

a conservative assessment of potential power plant-related biological effects (i.e., the biothermal 

assessment focused on the months of June, July, August, and September). The results indicate 

that the proposed alternative thermal standard would have a negligible impact on largemouth 

bass, channel catfish, and a slightly positive one for spotfin shiner (i.e., increased growth) (HDR 

2009). Walleye chronic mortality could be increased by 8.5 percent immediately downstream of 

the mixing zone, but placed in the areal relationship of the discharge to Pool 14, this would 

translate to a <1 percent effect on the walleye population in the pool (HDR 2009).

The retrospective assessment indicated some changes in the upper trophic levels (i.e., finfish) in 

Pool 14 since the Station began operating, but concluded that those changes are not attributable to 

the thermal input from QCNS (HDR 2009). In addition, the overall stability and health of upper 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix B: Thermal Discharges

May 2014 B-12

trophic levels over the length of the monitoring period suggests that lower trophic levels (i.e., 

zooplankton, phytoplankton) have remained stable and abundant, providing an adequate food 

supply to allow and sustain growth of the finfish and mussel populations. The retrospective 

assessment also found that neither nuisance species (e.g., zebra mussel) nor heat tolerant species 

of fish have come to predominate in Pool 14 due to QCNS operations (HDR 2009).

In addition, the Demonstration examined the potential for harmful interactions between the 

QCNS thermal discharge and other pollutants, including dissolved organic carbon, total 

phosphorus, total nitrogen, biocides (i.e., anti-fouling chemicals), heavy metals, and other thermal 

discharges located upstream. This analysis indicated that there was no evidence to suggest that 

the small amount of additional heat that would be permitted to be discharged to Pool 14 under the 

proposed alternative standard would have an adverse synergistic effect with other pollutants 

(HDR 2009).

QCNS, based on their interpretation of EPA guidance documents and 316(a) Demonstrations for 

other facilities, maintained that the overall standard of compliance (i.e., protection of the BIC) 

would be demonstrated by meeting a series of functional criteria. Because this is a request for a 

change in the thermal standard, the Demonstration needed to show that these conditions will be 

satisfied in the future if the proposed standard was adopted:

 No substantial increase in abundance or distribution of any nuisance species or heat 

tolerant community;

 No substantial decreases in formerly abundant indigenous species or community structure 

to resemble a simpler successional stage than is natural for the locality and season, other 

than nuisance species;

 No unaesthetic appearance, odor, or taste of the water;

 No elimination of an established or potential economic or recreational use of the waters; 

 No reduction in the successful completion of life cycles of indigenous species, including 

those of migratory species;

 No substantial reduction of community heterogeneity or trophic structure;

 No adverse impact on threatened or endangered species;

 No destruction of unique or rare habitat, without a detailed and convincing justification of 

why the destruction should not constitute a basis of denial; and

 No detrimental interaction with other pollutants, discharges, or water-use activities.

Based on the results of the thermal plume modeling study, the prospective analysis, the 

retrospective assessment, and the successful meeting of the criteria listed above, QCNS

concluded that past or future operations have not caused appreciable harm to the BIC.

B.5.3 Point Beach Nuclear Station

Point Beach Nuclear Plant (PBNP) is located on the western shore of Lake Michigan in Two 

Rivers, Manitowoc County, WI. The facility consists of two nuclear powered steam electric 

generating units with a total net capacity of 1,540 megawatts thermal (MWt) each. Generation 

Unit 1 began commercial operation in December 1970 and Unit 2 in October 1972 (EA 2008). 

The units operate with a once-through cooling water system (EA 2008). Cooling water is 

withdrawn from a deep intake (22 ft. contour) in Lake Michigan, and current pumping capacity is 

estimated to be 680,000 gallons per minute. Each unit discharges the non-contact cooling water to 

Lake Michigan via its own outfall located at a mean temperature increase of 11.5°C (20.7°F) 

above the intake water temperature at the maximum flow rate (EA 2008).
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix B: Thermal Discharges

May 2014 B-13

PBNP planned to implement an extended power uprate (EPU) at both units in the 2010/2011 time 

frame that was expected to increase the existing plant output by approximately 17 percent. The 

proposed EPU does not result in an increase in water being withdrawn from Lake Michigan, nor 

will it result in an increase in the amount of water discharged to Lake Michigan (NRC 2010). 

However, EPU did require modification of the facility’s Wisconsin Discharge Elimination 

System (WPDES) permit for the discharge of a pollutant from a point source into waters of the 

state (which includes the addition of heat from a point source). According to a modeling study 

performed by PBNP in 2008, the temperature of the discharge water was expected to increase by 

a maximum of 3.6 °F (2.0 °C), and the thermal plume expand as a result of the proposed EPU

(NRC 2010). 

In support of the permit modification request, PBNP prepared an assessment of the potential 

impacts of the thermal discharge from the planned EPU (i.e., the “Planned Change”). This 

assessment is summarized in “Point Beach Nuclear Plant Evaluation of the Thermal Effects Due 

to a Planned Extended Power Uprate” (EA 2008). Since there currently are no temperature 

limits in the PBNP WPDES permit or thermal water quality standards for Lake Michigan, this

assessment represented a “good faith effort” by PBNP to demonstrate that the impacts of the EPU 

would not have a significant effect on the fish or shellfish communities in Lake Michigan (EA 

2008).

Evaluation of the potential effects on the Lake Michigan aquatic community in the vicinity of the 

PBNP post-EPU discharge was based on a review of historical and current monitoring data 

collected in the vicinity of the facility and other power facilities that utilize Lake Michigan water 

for once-through cooling (EA 2008). Those study results were compared to expected responses of 

16 Wisconsin Department of Natural Resource (WDNR) selected Representative Important 

Species (RIS) to the projected higher discharge temperatures and larger thermal plume that will 

result from the planned EPU. The evaluation placed emphasis on the RIS, and whether or not the

BIC in the vicinity of the PBNP discharge would continue to be protected.

The assessment relied heavily on the findings of the Type I CWA section 316(a) Demonstration

conducted by the facility in the 1970s as well as the 1976 finding by WDNR that no appreciable 

harm had occurred to the local BIC due to facility operations (EA 2008). The studies involved 

investigations of primary and secondary trophic levels from phytoplankton through fish in both 

reference and thermally affected areas (EA Engineering 2008; Limnetics 1974, as cited in EA 

2008). 

Recent entrainment and impingement monitoring studies at PBNP indicate that the same species 

that were common in the vicinity of the facility during the Type I Demonstration remain common 

near the facility despite lake-wide changes in the Lake Michigan fish community (Kitchell 2007, 

as cited in EA 2008). Recent fisheries data collected from both PBNP and the Kewaunee Nuclear 

Power Plant (KNPP), which is located only five miles north of PBNP, show that the same species 

seasonally occur in nearshore areas in the vicinity of the shoreline discharge structures. These 

findings indicate that the BIC is protected under similar operating conditions as have occurred 

historically at PBNP.

Evaluation of the modeled discharge temperatures and plume configurations under the planned 

EPU indicates that the predicted area, volume, and behavior of the plume will not be substantially 

different than under current PBNP operating conditions and similar to those evaluated during the 

Type 1 Demonstration (EA 2008). Based on the thermal model results using a 0.2 ft./sec alongshore current, the planned EPU would expand the surface area of the 6.0oC contour from 27 to 39 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix B: Thermal Discharges

May 2014 B-14

acres; the 4.0oC contour would increase from 79 to 105 acres; and the 2.0oC contour would

increase from 315 to 390 acres (EA 2008). These projected increases in plume size are relatively 

small compared to the surface area available for mixing. Under critical summer conditions the 

buoyant plume provides an area of safety as well as a zone of passage when discharge 

temperatures approach or exceed upper avoidance temperatures of the RIS fish.

The RIS evaluation showed that the predicted impact of the warmer and larger thermal plume as a 

result of the EPU at PBNP will be negligible (EA 2008). Thermal criteria for some of the 12 RIS 

fish species would be exceeded in the plume, but mainly at the point of discharge or in small 

areas for relatively brief periods of time. Fish readily move into and out of thermal discharge 

plumes, depending on their thermal requirements and the thermal regime of the plume at any 

given time. Cool and coldwater fish species would be somewhat restricted with regard to use of 

the plume area, especially during summer, but these species generally spend the summer well 

offshore. In addition, the warmwater RIS could slightly benefit from the warmer temperatures.

Combining these observations with the size of the PBNP plume relative to available lake habitat, 

it was concluded that the larger and warmer thermal plume resulting from the planned EPU 

would have a minimal and insignificant impact on the fish community in Lake Michigan (EA 

2008). Similar conclusions were reached for the four invertebrate RIS (shellfish and opossum 

shrimp).

Overall, the assessment concluded that the increased heat load to the discharge would not 

endanger the protection and propagation of a BIC of shellfish, fish, and wildlife in and on Lake 

Michigan. This conclusion was based on several lines of evidence including:

 The PBNP Type I Demonstration established that the original thermal plume did not 

cause “prior appreciable harm;” 

 The PBNP thermal plumes resulting from the planned EPU will not be substantially 

larger than the original/existing plumes;

 There have been no changes in the aquatic community attributable to operation of the 

facility that would preclude reliance on the results of the Type I Demonstration for 

PBNP;

 The changes to the Lake Michigan fish community that have occurred during the past 50 

years have occurred on a lake-wide basis;

 The impacts on RIS will be negligible; and

 The conclusion with respect to the effect of the planned EPU is consistent with 

assessments undertaken at other power facilities on Lake Michigan.

While the cooling water thermal plume of PBNP was expected to be larger as a result of the 

proposed EPU, it was not expected to disrupt the local BIC or have a significant impact on RIS of 

Lake Michigan (EA 2008). Recently, as part of the facilities’ operating license renewal, the 

Nuclear Regulatory Commission developed a draft Environmental Assessment (EA) for the 

power uprate. The draft EA was issued in December 2010 with a finding of no significant impact 

(NRC 2010).
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-1

Appendix C: Details of Regional IM&E

C.1 California Region

Table C-1: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the California Region (million A1Es 

per year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species

Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

All forage species 0.17 0.18 0.20 0.29 <0.01 <0.01 14.81 24.28 0.17 0.18 15.00 24.56

All harvested species 0.50 0.54 0.58 0.85 <0.01 <0.01 15.94 26.14 0.50 0.54 16.52 26.98

American shad <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Cabezon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.05 0.08 <0.01 <0.01 0.05 0.08

California halibut <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.20 0.33 <0.01 <0.01 0.20 0.33

California scorpionfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Crabs (other) 0.02 0.02 0.02 0.03 <0.01 <0.01 6.65 10.91 0.02 0.02 6.68 10.94

Sea Basses <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 2.42 3.96 <0.01 <0.01 <0.01 3.96

Shrimp (other) <0.01 <0.01 <0.01 0.01 <0.01 <0.01 0.53 0.88 <0.01 <0.01 0.54 0.89

Drums and croakers 0.04 0.04 0.04 0.07 <0.01 <0.01 0.19 0.32 0.04 0.04 0.24 0.38

Dungeness crab <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 <0.01 <0.01 0.01

Flounders <0.01 <0.01 0.01 0.02 <0.01 <0.01 0.08 0.13 <0.01 <0.01 0.09 0.15

Fish (other) <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 <0.01 <0.01 0.02

Northern anchovy 0.29 0.32 0.33 0.49 <0.01 <0.01 0.03 0.04 0.29 0.32 0.36 0.54

Rockfishes 0.01 0.01 0.02 0.02 <0.01 <0.01 5.40 8.85 0.01 0.01 5.42 8.88

Salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Sculpins 0.01 0.01 0.01 0.02 <0.01 <0.01 0.36 0.60 0.01 0.01 0.38 0.62

Smelts <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Striped bass <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 0.02 <0.01 <0.01 0.01 0.02

Sunfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Surfperches 0.10 0.11 0.11 0.16 <0.01 <0.01 <0.01 <0.01 0.10 0.11 0.11 0.16

Total (all species) 0.68 0.73 0.77 1.13 <0.01 <0.01 30.75 50.42 0.68 0.73 31.52 51.55

Notes:

P4 = Proposal Option 4; F = Final Rule – Existing Units; P2 = Proposal Option 2; and B = Baseline

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-2

Table C-2: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the California Region (million individuals per

year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

American shad <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Blennies <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 390.33 639.92 <0.01 <0.01 390.33 639.92 

Bluegill <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Brown bullhead <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Cabezon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 2.84 4.65 <0.01 <0.01 2.84 4.65 

California halibut <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 3.29 5.40 <0.01 <0.01 3.29 5.40 

California scorpionfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Chinook salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Crabs (other) 0.02 0.02 0.03 0.04 <0.01 <0.01 3,088.48 5,063.36 0.02 0.02 3,088.51 5,063.39 

Delta smelt <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 <0.01 <0.01 0.01 

Drums and croakers 0.18 0.19 0.20 0.30 <0.01 <0.01 390.48 640.16 0.18 0.19 390.68 640.46 

Dungeness crab <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.04 0.06 <0.01 <0.01 0.04 0.06 

Fish (other) 0.04 0.04 0.04 0.06 <0.01 <0.01 554.48 909.03 0.04 0.04 554.52 909.10 

Flounders <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 136.20 223.29 <0.01 <0.01 136.20 223.30 

Gobies <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 673.78 1,104.62 <0.01 <0.01 673.78 1,104.62 

Herrings 0.02 0.03 0.03 0.04 <0.01 <0.01 11.19 18.35 0.02 0.03 11.22 18.39 

Longfin smelt <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Northern anchovy 0.37 0.39 0.42 0.61 <0.01 <0.01 352.68 578.20 0.37 0.39 353.10 578.81 

Pacific herring <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 15.43 25.30 <0.01 <0.01 15.43 25.30 

Rockfishes 0.01 0.01 0.01 0.02 <0.01 <0.01 27.29 44.74 0.01 0.01 27.30 44.76 

Sacramento splittail <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Sculpins <0.01 <0.01 <0.01 0.01 <0.01 <0.01 20.45 33.53 <0.01 <0.01 20.46 33.54 

Sea Basses <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 5.65 9.26 <0.01 <0.01 5.65 9.26 

Shrimp (other) 0.01 0.02 0.02 0.02 <0.01 <0.01 183.13 300.24 0.01 0.02 183.15 300.26 

Silversides 0.05 0.05 0.05 0.08 <0.01 <0.01 51.98 85.22 0.05 0.05 52.04 85.30 

Smallmouth bass <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Smelts <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 1.55 2.54 <0.01 <0.01 1.55 2.54 

Striped bass <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 4.82 7.91 <0.01 <0.01 4.82 7.91 

Sunfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Surfperches 0.06 0.06 0.06 0.09 <0.01 <0.01 <0.01 <0.01 0.06 0.06 0.06 0.09 

Total (all species) 0.77 0.83 0.88 1.30 <0.01 <0.01 5,914.12 9,695.80 0.77 0.83 5,915.00 9,697.09 

Notes:

P4 = Proposal Option 4; F = Final Rule – Existing Units; P2 = Proposal Option 2; and B = Baseline

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-3

C.2 North Atlantic Region

Table C-3: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the North Atlantic (million A1Es per year), and 

Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species

Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

All forage species 0.35 0.37 0.50 0.53 <0.01 0.40 34.30 44.80 0.35 0.77 34.80 45.34

All harvested species 0.05 0.05 0.07 0.08 <0.01 0.11 9.52 12.44 0.05 0.16 9.60 12.52

American plaice <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

American shad <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Atlantic cod <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 <0.01 0.01 0.01

Atlantic herring <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.09 0.12 <0.01 <0.01 0.09 0.12

Atlantic mackerel <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.02 <0.01 <0.01 0.02 0.02

Atlantic menhaden <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 0.04 <0.01 <0.01 0.03 0.04

Bluefish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Butterfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Crabs (other) 0.02 0.02 0.03 0.03 <0.01 <0.01 <0.01 <0.01 0.02 0.02 0.03 0.03

Cunner <0.01 <0.01 <0.01 <0.01 <0.01 0.04 3.14 4.10 <0.01 0.04 3.14 4.11

Fish (other) <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Pollock <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Red hake <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Sculpins <0.01 <0.01 <0.01 <0.01 <0.01 0.02 1.43 1.87 <0.01 0.02 1.44 1.87

Scup <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Searobin <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 <0.01 <0.01 0.01

Silver hake <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Skates <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Striped bass <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Tautog <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.08 0.11 <0.01 <0.01 0.08 0.11

Weakfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

White perch <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Windowpane <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.02 <0.01 <0.01 0.02 0.02

Winter flounder 0.02 0.02 0.02 0.02 <0.01 0.05 4.69 6.13 0.02 0.07 4.71 6.15

Total (all species) 0.40 0.42 0.57 0.61 <0.01 0.51 43.83 57.24 0.40 0.93 44.40 57.86

Notes:

P4 = Proposal Option 4; F = Final Rule – Existing Units; P2 = Proposal Option 2; and B = Baseline

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-4

Table C-4: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the North Atlantic (million individuals per 

year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species

Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

Alewife 0.02 0.02 0.02 0.03 <0.01 0.02 2.13 2.78 0.02 0.04 2.15 2.80 

American plaice <0.01 <0.01 <0.01 <0.01 <0.01 0.86 73.53 96.04 <0.01 0.86 73.53 96.04 

American sand lance 0.05 0.05 0.07 0.08 <0.01 6.31 542.26 708.25 0.05 6.36 542.33 708.33 

American shad <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Atlantic cod <0.01 <0.01 <0.01 <0.01 <0.01 0.50 43.33 56.59 <0.01 0.50 43.33 56.59 

Atlantic herring <0.01 <0.01 0.01 0.01 <0.01 0.37 32.23 42.09 <0.01 0.38 32.24 42.11 

Atlantic mackerel <0.01 <0.01 <0.01 <0.01 <0.01 30.35 2,608.87 3,407.48 <0.01 30.35 2,608.87 3,407.48 

Atlantic menhaden <0.01 <0.01 <0.01 <0.01 <0.01 18.06 1,552.60 2,027.86 <0.01 18.07 1,552.60 2,027.87 

Atlantic silverside 0.04 0.05 0.06 0.07 <0.01 0.41 35.65 4.56 0.04 0.46 35.71 46.63 

Atlantic tomcod <0.01 <0.01 <0.01 <0.01 <0.01 0.03 2.32 3.03 <0.01 0.03 2.32 3.03 

Bay anchovy <0.01 0.01 0.01 0.01 <0.01 239.73 20,604.68 26,912.03 <0.01 239.74 20,604.69 26,912.04 

Blueback herring <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Bluefish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.03 <0.01 <0.01 0.02 0.03 

Butterfish <0.01 <0.01 <0.01 <0.01 <0.01 0.05 4.48 5.86 <0.01 0.05 4.49 5.86 

Crabs (other) 0.01 0.01 0.02 0.02 <0.01 <0.01 <0.01 <0.01 0.01 0.01 0.02 0.02 

Cunner <0.01 <0.01 <0.01 <0.01 <0.01 125.28 10,767.77 14,063.92 <0.01 125.28 10,767.78 14,063.92 

Fish (other) 0.02 0.02 0.03 0.03 <0.01 2.24 192.48 251.40 0.02 2.26 192.51 251.43 

Fourbeard rockling <0.01 <0.01 <0.01 <0.01 <0.01 1.99 171.36 223.81 <0.01 1.99 171.36 223.81 

Grubby <0.01 <0.01 0.01 0.01 <0.01 1.85 159.12 207.83 <0.01 1.86 159.13 207.84 

Hogchoker 0.01 0.01 0.02 0.02 <0.01 2.36 202.71 264.77 0.01 2.37 202.73 264.79 

Lumpfish <0.01 <0.01 <0.01 <0.01 <0.01 0.19 16.57 21.64 <0.01 0.19 16.57 21.64 

Northern pipefish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.42 0.55 <0.01 <0.01 0.43 0.56 

Pollock <0.01 <0.01 <0.01 <0.01 <0.01 0.01 1.28 1.67 <0.01 0.02 1.28 1.67 

Radiated shanny <0.01 <0.01 <0.01 <0.01 <0.01 0.47 40.74 53.21 <0.01 0.47 40.74 53.21 

Rainbow smelt 0.02 0.02 0.02 0.02 <0.01 0.08 6.51 8.51 0.02 0.09 6.54 8.53 

Red hake <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Rock gunnel <0.01 <0.01 <0.01 <0.01 <0.01 1.70 146.13 190.86 <0.01 1.70 146.13 190.86 

Sculpins <0.01 <0.01 <0.01 <0.01 <0.01 0.94 80.72 105.42 <0.01 0.94 80.72 105.43 

Scup <0.01 <0.01 <0.01 <0.01 <0.01 0.07 6.14 8.02 <0.01 0.07 6.14 8.03 

Seaboard goby <0.01 <0.01 <0.01 <0.01 <0.01 10.22 878.37 1,147.25 <0.01 10.22 878.37 1,147.25 

Searobin <0.01 <0.01 <0.01 <0.01 <0.01 0.05 4.24 5.53 <0.01 0.05 4.24 5.53 

Silver hake 0.01 0.01 0.02 0.02 <0.01 2.44 209.93 274.19 0.01 2.45 209.94 274.20 

Skates <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Striped bass <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Striped killifish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.03 <0.01 <0.01 0.02 0.03 

Tautog <0.01 <0.01 <0.01 <0.01 <0.01 125.83 10,815.39 14,126.11 <0.01 125.84 10,815.39 14,126.11 

Threespine stickleback <0.01 <0.01 0.01 0.01 <0.01 <0.01 0.03 0.04 <0.01 <0.01 0.04 0.06 

Weakfish <0.01 <0.01 <0.01 <0.01 <0.01 1.47 126.32 164.99 <0.01 1.47 126.32 164.99 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-5

Table C-4: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the North Atlantic (million individuals per 

year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species

Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

White perch <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.10 0.14 <0.01 <0.01 0.11 0.14 

Windowpane <0.01 <0.01 <0.01 <0.01 <0.01 8.88 762.82 996.32 <0.01 8.88 762.82 996.33 

Winter flounder 0.03 0.03 0.04 0.04 <0.01 28.72 2,468.75 3,224.46 0.03 28.75 2,468.79 3,224.51 

Total (all species) 0.28 0.30 0.40 0.44 <0.01 611.52 52,560.02 68,649.28 0.28 611.82 52,560.42 68,649.72 

Notes:

P4 = Proposal Option 4; F = Final Rule – Existing Units; P2 = Proposal Option 2; and B = Baseline

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-6

C.3 Mid-Atlantic Region

Table C-5: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Mid-Atlantic (million A1Es per year), and 

Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species

Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

All forage species 10.91 11.65 13.32 14.42 0.72 1.09 402.14 461.47 11.63 12.75 415.46 475.89

All harvested species 18.66 19.94 22.79 24.67 0.20 0.31 113.65 130.42 18.87 20.25 136.44 155.08

Alewife 0.02 0.03 0.03 0.03 <0.01 <0.01 <0.01 <0.01 0.02 0.03 0.03 0.04

American shad <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Atlantic croaker 0.18 0.19 0.22 0.24 0.02 0.03 11.85 13.60 0.20 0.23 12.08 13.84

Atlantic herring <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Atlantic menhaden 12.67 13.53 15.47 16.74 <0.01 <0.01 1.73 1.99 12.67 13.54 17.20 18.73

Black crappie <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Black drum <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Blue crab 0.84 0.90 1.03 1.11 0.11 0.16 59.39 68.16 0.95 1.06 60.42 69.27

Bluefish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Bluegill <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Brown bullhead <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 0.01

Bullheads <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Butterfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Channel catfish 0.01 0.01 0.01 0.01 <0.01 <0.01 <0.01 <0.01 0.01 0.01 0.01 0.01

Crabs (other) 0.02 0.02 0.02 0.03 <0.01 <0.01 <0.01 <0.01 0.02 0.02 0.02 0.03

Crappie <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Cunner <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Freshwater drum <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Menhadens <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Muskellunge <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Fish (other) 0.76 0.81 0.92 1.00 0.01 0.02 5.93 6.81 0.77 0.24 0.34 7.81

Red drum <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Red hake <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Scup <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Searobin <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Silver hake <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Silver perch <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Smallmouth bass <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Spot 1.72 1.84 2.10 2.27 0.03 0.05 19.30 22.15 1.75 1.89 21.40 24.42
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-7

Table C-5: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Mid-Atlantic (million A1Es per year), and 

Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species

Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

Spotted seatrout <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Striped bass <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.76 0.88 <0.01 <0.01 0.77 0.88

Striped mullet <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Summer flounder 0.01 0.01 0.02 0.02 <0.01 <0.01 <0.01 <0.01 0.01 0.01 0.02 0.02

Sunfish 0.01 0.01 0.01 0.01 <0.01 <0.01 <0.01 <0.01 0.01 0.01 0.01 0.01

Tautog <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Weakfish 0.84 0.89 1.02 1.11 <0.01 <0.01 1.49 1.70 0.84 0.90 2.51 2.81

White perch 1.55 1.66 1.89 2.05 0.02 0.04 13.11 15.04 1.57 1.69 15.00 17.09

Whitefish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Windowpane <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Winter flounder <0.01 0.01 0.01 0.01 <0.01 <0.01 0.06 0.07 <0.01 0.01 0.07 0.08

Total (all species) 29.57 31.60 36.11 39.08 0.93 1.40 515.78 591.89 30.50 32.99 551.90 630.97

Notes:

P4 = Proposal Option 4; F = Final Rule – Existing Units; P2 = Proposal Option 2; and B = Baseline

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-8

Table C-6: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Mid-Atlantic (million individuals per year), 

and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species

Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

Alewife 0.10 0.10 0.12 0.13 <0.01 <0.01 1.68 1.92 0.10 0.11 1.80 2.05 

American shad 0.02 0.02 0.02 0.02 0.03 0.05 18.41 21.13 0.05 0.07 18.43 21.15 

Atlantic croaker 0.66 0.71 0.81 0.88 0.34 0.51 189.17 217.08 1.01 1.22 189.98 217.96 

Atlantic herring <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Atlantic menhaden 20.54 21.95 25.08 27.15 0.06 0.09 33.65 38.62 20.60 22.04 58.74 65.77 

Atlantic silverside 0.41 0.44 0.50 0.54 0.05 0.08 30.24 34.70 0.46 0.52 30.74 35.24 

Atlantic tomcod 0.04 0.04 0.05 0.05 <0.01 <0.01 <0.01 <0.01 0.04 0.04 0.05 0.05 

Bay anchovy 4.02 4.29 4.91 5.31 48.59 73.22 26,996.15 30,979.52 52.60 77.51 27,001.05 30,984.82 

Black crappie <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Black drum <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Blue crab 0.84 0.89 1.02 1.10 1.68 2.53 932.50 1,070.10 2.51 3.42 933.53 1,071.20 

Blueback herring 0.37 0.39 0.45 0.49 0.01 0.02 6.66 7.65 0.38 0.41 7.11 8.13 

Bluefish <0.01 <0.01 0.01 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 0.01 

Bluegill <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Bluntnose minnow <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Brown bullhead <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 0.03 <0.01 <0.01 0.03 0.04 

Bullheads <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Butterfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Carp <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Chain pipefish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Channel catfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Crabs (other) 0.01 0.01 0.01 0.01 <0.01 <0.01 <0.01 <0.01 0.01 0.01 0.01 0.01 

Crappie <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Cunner <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Darters <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Fish (other) 1.56 1.66 1.90 2.06 1.88 2.83 1,044.61 1,198.74 3.44 4.50 1,046.51 1,200.80 

Freshwater drum <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Gizzard shad 0.10 0.11 0.12 0.13 <0.01 <0.01 <0.01 <0.01 0.10 0.11 0.12 0.13 

Gobies <0.01 <0.01 <0.01 <0.01 0.07 0.11 39.50 45.33 0.07 0.11 39.50 45.33 

Grubby <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Herrings <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Hogchoker 0.15 0.16 0.19 0.20 12.83 19.34 7,129.97 8,182.02 12.99 19.50 7,130.16 8,182.22 

Menhadens <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 0.03 <0.01 <0.01 0.03 0.03 

Muskellunge <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Northern pipefish <0.01 0.01 0.01 0.01 <0.01 <0.01 2.92 3.35 0.01 0.02 2.93 3.37 

Rainbow smelt <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Red drum <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Red hake 0.02 0.02 0.03 0.03 <0.01 <0.01 <0.01 <0.01 0.02 0.02 0.03 0.03 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-9

Table C-6: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Mid-Atlantic (million individuals per year), 

and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species

Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

Scup <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Seaboard goby <0.01 <0.01 <0.01 <0.01 6.76 10.20 3,758.88 4,313.52 6.77 10.20 3,758.89 4,313.52 

Searobin <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Shiners <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.27 0.31 <0.01 <0.01 0.27 0.31 

Silver hake <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Silver perch <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Silversides <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.78 0.90 <0.01 <0.01 0.78 0.90 

Smallmouth bass <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Spot 2.67 2.86 3.26 3.53 0.11 0.17 63.87 73.29 2.79 3.03 67.13 76.82 

Spotted seatrout <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Striped bass 0.01 0.01 0.01 0.01 0.52 0.79 291.01 333.95 0.53 0.80 291.03 333.97 

Striped killifish 0.09 0.10 0.11 0.12 <0.01 <0.01 <0.01 <0.01 0.09 0.10 0.11 0.12 

Striped mullet <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Suckers <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Summer flounder 0.02 0.02 0.03 0.03 <0.01 <0.01 <0.01 <0.01 0.02 0.02 0.03 0.03 

Sunfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Tautog <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Threespine stickleback <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Weakfish 0.96 1.03 1.18 1.27 0.24 0.36 133.56 153.27 1.20 1.39 134.74 154.55 

White perch 0.82 0.87 1.00 1.08 1.15 1.74 641.08 735.68 1.97 2.61 642.08 736.76 

Whitefish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Windowpane <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Winter flounder 0.02 0.02 0.02 0.02 0.05 0.07 25.26 28.99 0.06 0.09 25.28 29.01 

Total (all species) 33.49 35.78 40.90 44.26 74.40 112.13 41,340.26 47,440.14 107.89 147.91 41,381.16 47,484.40 

Notes:

P4 = Proposal Option 4; F = Final Rule – Existing Units; P2 = Proposal Option 2; and B = Baseline

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-10

C.4 South Atlantic Region

Table C-7: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the South Atlantic (million A1Es per year), and 

Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species

Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

All forage species 10.98 11.77 16.05 16.21 <0.01 0.44 7.86 8.41 10.98 12.21 23.91 24.61

All harvested species 0.63 0.68 0.92 0.93 <0.01 0.04 0.76 0.82 0.63 0.72 1.69 1.75

Atlantic menhaden 0.13 0.14 0.19 0.19 <0.01 <0.01 0.02 0.03 0.13 0.14 0.21 0.22

Blue crab 0.23 0.25 0.34 0.34 <0.01 <0.01 <0.01 <0.01 0.23 0.25 0.34 0.34

Crabs (other) <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.02 <0.01 <0.01 0.02 0.02

Drums and croakers 0.01 0.01 0.02 0.02 <0.01 0.04 0.63 0.68 0.01 0.05 0.65 0.70

Flounders <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Fish (other) <0.01 <0.01 0.01 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01

Pinfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Silver perch 0.14 0.15 0.21 0.21 <0.01 <0.01 <0.01 <0.01 0.14 0.15 0.21 0.21

Spot 0.10 0.11 0.15 0.15 <0.01 <0.01 0.08 0.08 0.10 0.11 0.23 0.23

Spotted seatrout <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Stone crab <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Weakfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Total (all species) 11.61 12.44 16.97 17.14 <0.01 0.48 8.62 9.22 11.61 12.93 25.60 26.36

Notes:

P4 = Proposal Option 4; F = Final Rule – Existing Units; P2 = Proposal Option 2; and B = Baseline

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-11

Table C-8: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the South Atlantic (million individuals per 

year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species

Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

Atlantic menhaden 0.21 0.23 0.31 0.31 <0.01 3.48 62.28 66.59 0.21 3.71 62.59 66.90 

Atlantic silverside 0.03 0.03 0.05 0.05 <0.01 <0.01 <0.01 <0.01 0.03 0.03 0.05 0.05 

Bay anchovy 6.59 7.06 9.63 9.73 <0.01 53.13 949.88 1,015.58 6.59 60.19 959.52 1,025.31 

Blue crab 0.23 0.25 0.34 0.34 <0.01 <0.01 <0.01 <0.01 0.23 0.25 0.34 0.34 

Crabs (other) <0.01 <0.01 <0.01 <0.01 <0.01 14.77 264.07 282.33 <0.01 14.77 264.07 282.33 

Drums and croakers 0.06 0.06 0.08 0.08 <0.01 52.55 939.64 1,004.62 0.06 52.61 939.72 1,004.70 

Fish (other) 0.43 0.46 0.63 0.64 <0.01 6.04 107.92 115.39 0.43 6.50 108.55 116.02 

Flounders <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Gobies <0.01 <0.01 <0.01 <0.01 <0.01 79.08 1,413.86 1,511.63 <0.01 79.08 1,413.86 1,511.63 

Herrings <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Pinfish <0.01 <0.01 <0.01 <0.01 <0.01 1.58 28.20 30.15 <0.01 1.58 28.20 30.15 

Scaled sardine <0.01 <0.01 0.01 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 0.01 

Shrimp (other) 2.30 2.46 3.36 3.39 <0.01 23.01 411.34 439.78 2.30 25.47 414.69 443.17 

Silver perch 0.12 0.12 0.17 0.17 <0.01 <0.01 <0.01 <0.01 0.12 0.12 0.17 0.17 

Spot 0.18 0.20 0.27 0.27 <0.01 47.60 851.08 909.94 0.18 47.80 851.35 910.21 

Spotted seatrout <0.01 <0.01 <0.01 <0.01 <0.01 0.78 13.96 14.92 <0.01 0.78 13.96 14.92 

Stone crab <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Weakfish 0.01 0.01 0.02 0.02 <0.01 2.23 39.93 42.69 0.01 2.25 39.94 42.70 

Total (all species) 10.17 10.90 14.87 15.02 <0.01 284.24 5,082.16 5,433.62 10.17 295.15 5,097.03 5,448.64 

Notes:

P4 = Proposal Option 4; F = Final Rule – Existing Units; P2 = Proposal Option 2; and B = Baseline

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-12

C.5 Gulf of Mexico Region

Table C-9: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Gulf of Mexico (million A1Es per year), and 

Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species

Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

All forage species 4.84 5.03 6.03 6.70 0.04 0.04 25.66 43.45 4.88 5.06 31.69 50.15

All harvested species 33.90 35.18 42.20 46.85 0.04 0.04 29.53 50.01 33.94 35.22 71.73 96.86

Atlantic croaker 1.42 1.48 1.77 1.96 <0.01 <0.01 <0.01 <0.01 1.42 1.48 1.77 1.97

Black drum 0.01 0.01 0.01 0.02 <0.01 <0.01 3.61 6.12 0.02 0.02 3.62 6.13

Blue crab 4.86 5.05 6.06 6.72 0.02 0.02 11.59 19.63 4.88 5.06 17.65 26.35

Leatherjacket 0.59 0.62 0.74 0.82 <0.01 <0.01 0.02 0.03 0.59 0.62 0.76 0.85

Mackerels <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Menhadens 4.26 4.42 5.30 5.89 <0.01 <0.01 0.03 0.05 4.26 4.42 5.33 5.94

Fish (other) 1.28 1.32 1.59 1.76 <0.01 <0.01 0.10 0.16 1.28 0.97 1.18 1.93

Pinfish 0.02 0.03 0.03 0.03 <0.01 <0.01 0.65 1.11 0.03 0.03 0.68 1.14

Pink shrimp 18.44 19.14 22.95 25.48 0.01 0.01 8.17 13.83 18.45 19.15 31.12 39.31

Red drum 0.07 0.07 0.09 0.10 <0.01 <0.01 <0.01 0.01 0.07 0.07 0.10 0.11

Sea basses <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Searobin 0.80 0.83 1.00 1.11 <0.01 <0.01 0.22 0.38 0.80 0.84 1.22 1.49

Sheepshead <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.04 <0.01 <0.01 0.02 0.04

Silver perch 0.24 0.25 0.30 0.33 <0.01 <0.01 3.12 5.28 0.25 0.26 3.42 5.61

Spot 0.33 0.34 0.41 0.45 <0.01 <0.01 0.05 0.09 0.33 0.34 0.46 0.54

Spotted seatrout 1.08 1.12 1.35 1.50 <0.01 <0.01 0.09 0.15 1.08 1.12 1.44 1.65

Stone crab 0.16 0.17 0.20 0.22 <0.01 <0.01 0.25 0.43 0.16 0.17 0.45 0.65

Striped mullet 0.32 0.33 0.40 0.44 <0.01 <0.01 1.59 2.70 0.32 0.33 1.99 3.14

Total (all species) 38.74 40.21 48.23 53.55 0.08 0.08 55.19 93.46 38.82 40.29 103.42 147.01

Notes:

P4 = Proposal Option 4; F = Final Rule – Existing Units; P2 = Proposal Option 2; and B = Baseline

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-13

Table C-10: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Gulf of Mexico (million individuals per 

year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species

Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

Atlantic croaker 6.64 6.90 8.27 9.18 0.07 0.07 49.45 83.75 6.71 6.96 57.73 92.93 

Bay anchovy 1.86 1.93 2.32 2.57 126.59 126.59 91,714.39 155,318.87 128.45 128.52 91,716.71 155,321.44

Black drum 0.01 0.01 0.01 0.01 40.50 40.50 29,342.08 49,690.98 40.51 40.51 29,342.09 49,691.00 

Blue crab 4.84 5.03 6.03 6.69 0.12 0.12 85.58 144.93 4.96 5.14 91.61 151.63 

Chain pipefish 0.03 0.03 0.04 0.04 <0.01 <0.01 0.65 1.10 0.03 0.03 0.68 1.14 

Fish (other) 3.19 3.32 3.98 4.42 4.11 4.11 2,980.35 5,047.23 7.31 7.43 2,984.32 5,051.65 

Gobies 0.06 0.06 0.07 0.08 1.43 1.43 1,038.00 1,757.86 1.49 1.49 1,038.07 1,757.94 

Gulf killifish 0.02 0.02 0.02 0.02 <0.01 <0.01 <0.01 <0.01 0.02 0.02 0.02 0.02 

Hogchoker 0.06 0.06 0.08 0.09 0.08 0.08 60.53 102.51 0.15 0.15 60.61 102.60 

Leatherjacket 0.41 0.42 0.51 0.56 0.33 0.33 241.86 409.59 0.74 0.76 242.37 410.16 

Mackerels <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Menhadens 6.91 7.17 8.60 9.54 0.11 0.11 81.98 138.83 7.02 7.28 90.58 148.37 

Pinfish 0.05 0.05 0.06 0.07 0.05 0.05 32.83 55.60 0.10 0.10 32.90 55.68 

Pink shrimp 18.80 19.51 23.41 25.98 0.05 0.05 38.48 65.16 18.85 19.57 61.88 91.15 

Red drum 0.07 0.07 0.08 0.09 <0.01 <0.01 0.33 0.57 0.07 0.07 0.42 0.66 

Scaled sardine 0.14 0.14 0.17 0.19 1.25 1.25 902.35 1,528.14 1.38 1.39 902.52 1,528.33 

Sea basses <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Searobin 0.51 0.52 0.63 0.70 0.03 0.03 20.96 35.50 0.53 0.55 21.59 36.20 

Sheepshead <0.01 <0.01 <0.01 <0.01 0.16 0.16 116.63 197.51 0.16 0.16 116.63 197.51 

Silver perch 0.20 0.20 0.24 0.27 37.41 37.41 27,105.51 45,903.34 37.61 37.62 27,105.75 45,903.61 

Spot 0.60 0.62 0.74 0.82 0.01 0.01 10.59 17.93 0.61 0.63 11.33 18.75 

Spotted seatrout 0.52 0.54 0.64 0.71 2.24 2.24 1,625.98 2,753.61 2.76 2.78 1,626.63 2,754.33 

Stone crab 0.12 0.12 0.15 0.16 12.07 12.07 8,745.52 14,810.59 12.19 12.19 8,745.67 14,810.76 

Striped mullet 0.19 0.20 0.24 0.27 <0.01 <0.01 4.62 7.82 0.20 0.21 4.86 8.09 

Tidewater 

silverside 0.13 0.13 0.16 0.18 0.01 0.01 10.47 17.73 0.14 0.15 10.63 17.90 

Total (all species) 45.35 47.07 56.46 62.68 226.65 226.65 164,209.14 278,089.16 272.00 273.72 164,265.60 278,151.84

Notes:

P4 = Proposal Option 4; F = Final Rule – Existing Units; P2 = Proposal Option 2; and B = Baseline

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-14

C.6 Great Lakes Region

Table C-11: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Great Lakes (million A1Es per 

year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

All forage species 175.87 193.55 220.56 226.20 0.01 0.03 9.94 13.81 175.88 193.58 230.50 240.01

All harvested species 8.15 8.97 10.22 10.49 <0.01 0.03 7.75 10.76 8.16 9.00 17.97 21.25

Black bullhead <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Black crappie <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Bluegill <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Brown bullhead 0.02 0.02 0.02 0.02 <0.01 <0.01 <0.01 <0.01 0.02 0.02 0.02 0.02

Bullheads <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Channel catfish 0.16 0.17 0.19 0.20 <0.01 <0.01 <0.01 <0.01 0.16 0.17 0.20 0.20

Crappie <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.02 <0.01 <0.01 0.02 0.02

Freshwater drum 0.31 0.34 0.38 0.39 <0.01 <0.01 0.46 0.64 0.31 0.34 0.84 1.03

Muskellunge <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Fish (other) 0.03 0.04 0.04 0.04 <0.01 <0.01 <0.01 <0.01 0.03 <0.01 <0.01 0.04

Rainbow smelt 0.35 0.38 0.44 0.45 <0.01 0.02 5.33 7.40 0.35 0.40 5.76 7.85

Salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Sauger <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Sculpins <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 0.02 <0.01 <0.01 0.01 0.02

Smallmouth bass 0.05 0.05 0.06 0.06 <0.01 <0.01 <0.01 <0.01 0.05 0.05 0.06 0.06

Smelts 2.60 2.87 3.27 3.35 <0.01 <0.01 0.01 0.01 2.60 2.87 3.28 3.36

Sunfish 0.06 0.06 0.07 0.07 <0.01 <0.01 0.86 1.19 0.06 0.07 0.93 1.26

Walleye 0.06 0.07 0.08 0.08 <0.01 <0.01 0.24 0.33 0.06 0.07 0.31 0.41

White bass 3.83 4.21 4.80 4.92 <0.01 <0.01 0.76 1.06 3.83 4.21 5.56 5.98

Whitefish 0.13 0.15 0.17 0.17 <0.01 <0.01 <0.01 <0.01 0.13 0.15 0.17 0.17

Yellow perch 0.54 0.60 0.68 0.70 <0.01 <0.01 0.07 0.09 0.54 0.60 0.75 0.79

Total (all species) 184.02 202.52 230.78 236.69 0.02 0.06 17.68 24.57 184.04 202.58 248.47 261.26

Notes:

P4 = Proposal Option 4; F = Final Rule – Existing Units; P2 = Proposal Option 2; and B = Baseline

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-15

Table C-12: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Great Lakes (million individuals per 

year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species

Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

Alewife 9.70 10.68 12.17 12.48 10.31 32.56 10,003.26 3,898.65 20.02 43.24 10,015.44 13,911.13 

Black bullhead <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Black crappie <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Blueback herring <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Bluegill 0.04 0.05 0.06 0.06 <0.01 <0.01 0.05 0.07 0.05 0.05 0.11 0.13 

Bluntnose minnow 0.03 0.03 0.04 0.04 <0.01 0.01 3.42 4.75 0.03 0.04 3.45 4.79 

Brown bullhead 0.01 0.02 0.02 0.02 <0.01 <0.01 <0.01 <0.01 0.01 0.02 0.02 0.02 

Bullheads <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Burbot <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.29 0.40 <0.01 <0.01 0.29 0.40 

Carp 0.03 0.03 0.04 0.04 0.89 2.82 866.66 1,204.14 0.92 2.85 866.69 1,204.18 

Channel catfish 0.10 0.11 0.12 0.12 <0.01 <0.01 0.61 0.85 0.10 0.11 0.74 0.98 

Chinook salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Crappie <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.38 0.53 <0.01 <0.01 0.39 0.54 

Darters <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.75 1.05 <0.01 <0.01 0.76 1.05 

Emerald shiner 26.33 28.98 33.02 33.87 0.04 0.12 36.38 50.55 26.37 29.10 69.40 84.41 

Fish (other) 0.18 0.19 0.22 0.23 11.23 35.46 10,895.22 15,137.95 11.41 35.65 10,895.44 15,138.17 

Freshwater drum 0.59 0.65 0.74 0.76 1.54 4.86 1,494.29 2,076.18 2.13 5.51 1,495.03 2,076.94 

Gizzard shad 28.91 31.81 36.25 37.18 1.04 3.29 1,009.94 1,403.23 29.95 35.10 1,046.20 1,440.41 

Golden redhorse <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Herrings <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 2.93 4.07 <0.01 <0.01 2.93 4.07 

Logperch 0.27 0.30 0.34 0.35 0.03 0.10 31.55 43.83 0.30 0.40 31.88 44.18 

Muskellunge <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.32 0.44 <0.01 <0.01 0.32 0.44 

Rainbow smelt 0.24 0.27 0.31 0.31 0.72 2.28 701.29 974.38 0.97 2.55 701.60 974.70 

Salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 1.62 2.25 <0.01 <0.01 1.62 2.25 

Sauger <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Sculpins <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.92 1.28 <0.01 <0.01 0.92 1.28 

Shiners 0.70 0.77 0.88 0.90 0.04 0.13 39.21 54.47 0.74 0.90 40.08 55.37 

Silversides 0.04 0.04 0.05 0.05 <0.01 <0.01 <0.01 <0.01 0.04 0.04 0.05 0.05 

Smallmouth bass 0.01 0.02 0.02 0.02 <0.01 <0.01 <0.01 <0.01 0.01 0.02 0.02 0.02 

Smelts 1.18 1.30 1.48 1.52 0.04 0.13 39.56 54.97 1.22 1.43 41.04 56.49 

Spotted sucker <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Striped killifish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Suckers <0.01 <0.01 <0.01 <0.01 0.03 0.10 31.48 43.74 0.04 0.11 31.49 43.75 

Sunfish <0.01 0.01 0.01 0.01 <0.01 <0.01 2.54 3.53 0.01 .02 2.55 3.54 

Threespine 

stickleback 0.02 0.02 0.03 0.03 <0.01 <0.01 0.18 0.25 0.02 0.02 0.21 0.28 

Walleye 0.09 0.10 0.11 0.11 <0.01 0.03 9.25 12.86 0.10 0.13 9.36 12.97 

White bass 2.14 2.35 2.68 2.75 0.06 0.19 57.17 79.44 2.20 2.54 59.86 82.19 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-16

Table C-12: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Great Lakes (million individuals per 

year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species

Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

White perch 9.14 10.06 11.46 11.76 0.25 0.80 245.11 340.56 9.39 10.86 256.57 352.31 

Whitefish 0.03 0.03 0.04 0.04 <0.01 <0.01 0.08 0.11 0.03 0.03 0.12 0.15 

Yellow perch 0.74 0.82 0.93 0.96 0.02 0.05 14.81 20.58 0.76 0.87 15.75 21.54 

Total (all species) 80.58 88.68 101.05 103.64 26.28 82.96 25,489.28 35,415.10 106.85 171.64 25,590.33 35,518.74 

Notes:

P4 = Proposal Option 4; F = Final Rule – Existing Units; P2 = Proposal Option 2; and B = Baseline

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-17

C.7 Inland Region

Table C-13: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Inland Region (million A1Es 

per year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

All forage species 324.12 335.14 386.58 443.70 0.21 1.11 120.73 155.43 324.34 336.25 507.31 599.13

All harvested species 23.61 24.42 28.16 32.33 0.17 0.89 96.71 124.51 23.79 25.31 124.88 156.84

American shad 0.04 0.04 0.04 0.05 <0.01 <0.01 <0.01 <0.01 0.04 0.04 0.04 0.05

Black bullhead 0.13 0.13 0.15 0.17 <0.01 <0.01 <0.01 <0.01 0.13 0.13 0.15 0.18

Black crappie 0.05 0.05 0.05 0.06 <0.01 <0.01 0.37 0.48 0.05 0.05 0.42 0.54

Bluegill 1.46 1.51 1.74 2.00 <0.01 <0.01 0.13 0.17 1.46 1.51 1.87 2.17

Brown bullhead 0.02 0.02 0.02 0.03 <0.01 <0.01 0.03 0.04 0.02 0.02 0.05 0.07

Bullheads 0.02 0.02 0.02 0.02 <0.01 <0.01 <0.01 <0.01 0.02 0.02 0.03 0.03

Channel catfish 1.13 1.16 1.34 1.54 <0.01 <0.01 0.74 0.95 1.13 1.17 2.08 2.50

Crappie 0.08 0.08 0.09 0.11 <0.01 <0.01 1.03 1.32 0.08 0.09 1.12 1.43

Freshwater drum 0.82 0.85 0.98 1.13 <0.01 0.04 4.64 5.97 0.83 0.89 5.62 7.10

Menhadens <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Muskellunge <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Fish (other) <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.05 0.06 <0.01 <0.01 0.05 0.07

Rainbow smelt 0.10 0.10 0.11 0.13 <0.01 <0.01 0.15 0.20 0.10 0.10 0.27 0.33

Salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Sauger 0.07 0.07 0.08 0.09 <0.01 0.01 1.29 1.65 0.07 0.08 1.36 1.74

Smallmouth bass 0.16 0.17 0.19 0.22 <0.01 0.03 2.72 3.50 0.17 0.19 2.92 3.73

Smelts <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Striped bass 0.11 0.11 0.13 0.15 <0.01 <0.01 <0.01 <0.01 0.11 0.11 0.13 0.15

Sturgeons <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.02 <0.01 <0.01 0.02 0.02

Sunfish 13.76 14.23 16.41 18.84 0.14 0.75 80.88 104.13 13.91 14.98 97.30 122.97

Walleye 0.04 0.04 0.05 0.05 <0.01 <0.01 0.50 0.65 0.04 0.04 0.55 0.70

White bass 1.62 1.68 1.94 2.22 <0.01 0.02 1.96 2.52 1.63 1.70 3.89 4.74

White perch 1.78 1.84 2.12 2.44 <0.01 <0.01 0.41 0.52 1.78 1.85 2.53 2.96

Whitefish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Yellow perch 2.24 2.31 2.67 3.06 <0.01 0.02 1.79 2.31 2.24 2.33 4.46 5.37

Total (all species) 347.74 359.55 414.75 476.03 0.39 2.00 217.45 279.94 348.12 361.55 632.19 755.97

Notes:

P4 = Proposal Option 4; F = Final Rule – Existing Units; P2 = Proposal Option 2; and B = Baseline

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-18

Table C-14: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Inland Region (million individuals per 

year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species

Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

Alewife 14.78 15.29 17.63 20.24 <0.01 <0.01 0.47 0.61 14.78 15.29 18.10 20.85

American shad 6.58 6.80 7.84 9.00 <0.01 <0.01 <0.01 <0.01 6.58 6.80 7.84 9.00

Bay anchovy 0.01 0.01 0.01 0.01 <0.01 <0.01 <0.01 <0.01 0.01 0.01 0.01 0.01

Bigmouth buffalo 0.01 0.01 0.02 0.02 <0.01 0.02 1.98 2.55 0.02 0.03 1.99 2.56

Black bullhead 0.12 0.12 0.14 0.16 <0.01 <0.01 0.02 0.02 0.12 0.12 0.16 0.18

Black crappie 0.12 0.12 0.14 0.16 0.02 0.08 9.12 11.74 0.14 0.21 9.26 11.90

Blue crab <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Blueback herring 64.16 66.34 76.52 87.83 1.14 5.92 643.06 827.87 65.30 72.26 719.58 915.70

Bluegill 12.29 12.71 14.66 16.82 0.03 0.16 17.65 22.72 12.32 12.87 32.31 39.55

Bluntnose minnow 0.05 0.05 0.06 0.07 3.21 16.65 1,807.24 2,326.63 3.26 16.70 1,807.31 2,326.70

Brown bullhead 0.02 0.02 0.02 0.02 <0.01 <0.01 0.13 0.17 0.02 0.02 0.15 0.19

Bullheads 0.02 0.02 0.02 0.02 <0.01 0.01 1.35 1.74 0.02 0.03 1.37 1.76

Burbot <0.01 <0.01 <0.01 <0.01 0.01 0.05 5.89 7.59 0.01 0.06 5.90 7.59

Carp 0.13 0.13 0.15 0.18 2.74 14.25 1,546.60 1,991.08 2.87 14.38 1,546.75 1,991.25

Channel catfish 0.70 0.73 0.84 0.96 0.14 0.71 77.07 99.22 0.84 1.44 77.91 100.19

Crappie 0.21 0.21 0.24 0.28 0.04 0.23 24.87 32.02 0.25 0.44 25.12 32.30

Darters 0.34 0.36 0.41 0.47 0.11 0.55 59.43 76.51 0.45 0.90 59.84 76.98

Emerald shiner 1.38 1.42 1.64 1.89 0.47 2.45 266.39 342.94 1.85 3.88 268.03 344.83

Fish (other) 28.75 29.73 34.29 39.36 44.39 230.44 25,013.58 32,202.21 73.14 260.17 25,047.88 32,241.57

Freshwater drum 1.58 1.63 1.89 2.16 1.96 10.19 1,106.12 1,424.00 3.54 11.83 1,108.00 1,426.17

Gizzard shad 107.49 111.14 128.20 147.15 12.43 64.55 7,007.01 9,020.74 119.93 175.70 7,135.21 9,167.89

Gobies <0.01 <0.01 <0.01 <0.01 0.05 0.27 29.82 38.39 0.05 0.27 29.82 38.39

Golden redhorse 0.02 0.02 0.03 0.03 <0.01 <0.01 1.05 1.35 0.02 0.03 1.08 1.38

Hogchoker <0.01 <0.01 0.01 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 0.01

Logperch 0.34 0.36 0.41 0.47 0.02 0.11 11.87 15.28 0.37 0.47 12.28 15.75

Menhadens <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Muskellunge <0.01 <0.01 <0.01 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 0.01

Rainbow smelt 0.07 0.07 0.08 0.09 0.04 0.20 21.76 28.02 0.11 0.27 21.84 28.11

River carpsucker 0.01 0.01 0.01 0.02 <0.01 0.02 1.89 2.44 0.01 0.03 1.91 2.45

Salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Sauger 0.08 0.08 0.09 0.11 0.20 1.06 115.46 148.65 0.28 1.14 115.56 148.75

Shiners 1.18 1.22 1.40 1.61 0.19 1.00 108.94 140.25 1.37 2.22 110.35 141.86 

Silversides 0.01 0.01 0.02 0.02 0.03 0.16 17.09 22.00 0.04 0.17 17.11 22.02

Skipjack herring 0.53 0.54 0.63 0.72 <0.01 <0.01 0.20 0.25 0.53 0.55 0.83 0.97 

Smallmouth bass 0.05 0.05 0.06 0.07 0.04 0.18 20.03 25.79 0.08 0.24 20.09 25.85 

Smelts <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Spotted sucker <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Striped bass 0.57 0.59 0.68 0.78 <0.01 <0.01 <0.01 <0.01 0.57 0.59 0.68 0.78 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-19

Table C-14: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Inland Region (million individuals per 

year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species

Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

Striped killifish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Sturgeons <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.54 0.69 <0.01 <0.01 0.54 0.69 

Suckers 0.06 0.06 0.07 0.08 2.83 14.70 1,595.57 2,054.12 2.89 14.76 1,595.63 2,054.19 

Sunfish 2.21 2.28 2.63 3.02 0.42 2.19 238.12 306.55 2.63 4.47 240.75 309.57 

Threespine 

stickleback <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Walleye 0.05 0.05 0.06 0.07 0.11 0.57 62.39 80.32 0.16 0.63 62.45 80.39 

White bass 0.91 0.94 1.08 1.24 0.70 3.61 392.34 505.10 1.60 4.55 393.42 506.34

White perch 1.34 1.38 1.60 1.83 0.43 2.24 242.75 312.51 1.77 3.62 244.34 314.34 

Whitefish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.28 0.36 <0.01 <0.01 0.28 0.36 

Yellow perch 3.07 3.17 3.66 4.20 0.72 3.72 404.19 520.35 3.78 6.89 407.85 524.55 

Total (all species) 249.27 257.74 297.30 341.23 72.49 376.37 40,852.60 52,593.18 321.76 634.10 41,149.89 52,934.41 

Notes:

P4 = Proposal Option 4; F = Final Rule – Existing Units; P2 = Proposal Option 2; and B = Baseline

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-20

C.8 National Estimates

Table C-15: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) Nationally (million A1Es per year), 

and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

All forage species 527.24 557.69 643.23 708.05 0.98 3.11 615.44 751.65 528.22 560.80 1258.67 1459.70

All harvested species 85.51 89.79 104.95 116.18 0.42 1.42 273.87 355.09 85.94 91.20 378.82 471.28

Alewife 0.02 0.03 0.03 0.03 <0.01 <0.01 <0.01 <0.01 0.02 0.03 0.03 0.04

American plaice <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

American shad 0.04 0.04 0.04 0.05 <0.01 <0.01 <0.01 <0.01 0.04 0.04 0.05 0.05

Atlantic cod <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 <0.01 0.01 0.01

Atlantic croaker 1.60 1.67 1.99 2.21 0.02 0.03 11.86 13.61 1.63 1.70 13.85 15.81

Atlantic herring <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.09 0.12 <0.01 <0.01 0.10 0.12

Atlantic mackerel <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.02 <0.01 <0.01 0.02 0.02

Atlantic menhaden 12.80 13.67 15.66 16.93 <0.01 <0.01 1.79 2.05 12.80 13.68 17.44 18.99

Black bullhead 0.13 0.13 0.15 0.17 <0.01 <0.01 <0.01 <0.01 0.13 0.13 0.16 0.18

Black crappie 0.05 0.05 0.05 0.06 <0.01 <0.01 0.37 0.48 0.05 0.05 0.42 0.54

Black drum 0.01 0.01 0.01 0.02 <0.01 <0.01 3.61 6.12 0.02 0.02 3.63 6.13

Blue crab 5.94 6.20 7.42 8.18 0.12 0.18 70.99 87.79 6.06 6.37 78.41 95.97

Bluefish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Bluegill 1.46 1.51 1.75 2.00 <0.01 <0.01 0.13 0.17 1.46 1.51 1.88 2.17

Brown bullhead 0.04 0.04 0.04 0.05 <0.01 <0.01 0.04 0.05 0.04 0.04 0.08 0.10

Bullheads 0.02 0.02 0.03 0.03 <0.01 <0.01 <0.01 <0.01 0.02 0.02 0.03 0.04

Butterfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Cabezon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.05 0.08 <0.01 <0.01 0.05 0.08

California halibut <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.20 0.33 <0.01 <0.01 0.20 0.33

California 

scorpionfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Channel catfish 1.29 1.35 1.55 1.75 <0.01 <0.01 0.74 0.96 1.29 1.35 2.29 2.71

Crabs (other) 0.06 0.06 0.08 0.09 <0.01 <0.01 6.67 10.93 0.06 0.07 6.75 11.02

Sea Basses <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 2.42 3.96 <0.01 <0.01 <0.01 3.96

Shrimp (other) <0.01 <0.01 <0.01 0.01 <0.01 <0.01 0.53 0.88 <0.01 <0.01 0.54 0.89

Crappie 0.08 0.08 0.09 0.11 <0.01 <0.01 1.04 1.35 0.08 0.09 1.14 1.45

Cunner <0.01 <0.01 <0.01 <0.01 <0.01 0.04 3.14 4.10 <0.01 0.04 3.14 4.11

Drums and croakers 0.05 0.06 0.06 0.08 <0.01 0.04 0.83 1.00 0.05 0.09 0.89 1.08

Dungeness crab <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 <0.01 <0.01 0.01

Flounders 0.01 0.01 0.01 0.02 <0.01 <0.01 0.08 0.13 0.01 0.01 0.09 0.15

Freshwater drum 1.13 1.19 1.37 1.52 <0.01 0.04 5.10 6.61 1.14 1.23 6.47 8.13
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-21

Table C-15: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) Nationally (million A1Es per year), 

and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

Leatherjacket 0.59 0.62 0.74 0.82 <0.01 <0.01 0.02 0.03 0.59 0.62 0.76 0.85

Mackerels <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Menhadens 4.26 4.42 5.30 5.89 <0.01 <0.01 0.03 0.05 4.26 4.42 5.34 5.94

Muskellunge <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Fish (other) 2.08 2.19 2.58 2.83 0.01 0.02 6.08 7.04 2.09 1.21 1.53 9.87

Northern anchovy 0.29 0.32 0.33 0.49 <0.01 <0.01 0.03 0.04 0.29 0.32 0.36 0.54

Pinfish 0.02 0.03 0.03 0.03 <0.01 <0.01 0.66 1.11 0.03 0.03 0.69 1.15

Pink shrimp 18.44 19.14 22.95 25.48 0.01 0.01 8.17 13.83 18.45 19.15 31.12 39.31

Pollock <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Rainbow smelt 0.44 0.48 0.55 0.58 <0.01 0.02 5.48 7.60 0.45 0.50 6.03 8.18

Red drum 0.08 0.08 0.09 0.10 <0.01 <0.01 <0.01 0.01 0.08 0.08 0.10 0.12

Red hake <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Rockfishes 0.01 0.01 0.02 0.02 <0.01 <0.01 5.40 8.85 0.01 0.01 5.42 8.88

Salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Sauger 0.07 0.07 0.08 0.09 <0.01 0.01 1.29 1.65 0.07 0.08 1.36 1.75

Sculpins 0.02 0.02 0.02 0.03 <0.01 0.02 1.81 2.48 0.02 0.03 1.83 2.51

Scup <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Sea basses <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Searobin 0.81 0.84 1.00 1.11 <0.01 <0.01 0.23 0.39 0.81 0.84 1.23 1.50

Sheepshead <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.04 <0.01 <0.01 0.02 0.04

Silver hake <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Silver perch 0.39 0.41 0.51 0.55 <0.01 <0.01 3.12 5.28 0.39 0.41 3.63 5.83

Skates <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Smallmouth bass 0.21 0.22 0.26 0.29 <0.01 0.03 2.72 3.50 0.22 0.25 2.98 3.79

Smelts 2.61 2.87 3.27 3.36 <0.01 <0.01 0.01 0.02 2.61 2.87 3.28 3.37

Spot 2.15 2.28 2.65 2.87 0.03 0.06 19.43 22.32 2.18 2.34 22.09 25.20

Spotted seatrout 1.09 1.13 1.35 1.50 <0.01 <0.01 0.09 0.16 1.09 1.13 1.44 1.66

Stone crab 0.16 0.17 0.20 0.22 <0.01 <0.01 0.25 0.43 0.16 0.17 0.45 0.65

Striped bass 0.11 0.12 0.14 0.16 <0.01 <0.01 0.77 0.89 0.12 0.12 0.91 1.05

Striped mullet 0.32 0.33 0.40 0.44 <0.01 <0.01 1.59 2.70 0.32 0.33 1.99 3.14

Sturgeons <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.02 <0.01 <0.01 0.02 0.02

Summer flounder 0.01 0.01 0.02 0.02 <0.01 <0.01 <0.01 <0.01 0.01 0.01 0.02 0.02

Sunfish 13.83 14.31 16.50 18.93 0.14 0.75 81.74 105.32 13.98 15.05 98.24 124.24

Surfperches 0.10 0.11 0.11 0.16 <0.01 <0.01 <0.01 <0.01 0.10 0.11 0.11 0.16

Tautog <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.08 0.11 <0.01 <0.01 0.08 0.11
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-22

Table C-15: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) Nationally (million A1Es per year), 

and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

Walleye 0.10 0.11 0.13 0.13 <0.01 <0.01 0.74 0.97 0.10 0.11 0.86 1.11

Weakfish 0.84 0.90 1.02 1.11 <0.01 <0.01 1.49 1.71 0.84 0.90 2.51 2.81

White bass 5.45 5.89 6.74 7.15 <0.01 0.02 2.72 3.58 5.46 5.91 9.46 10.72

White perch 3.33 3.50 4.02 4.49 0.02 0.04 13.52 15.57 3.36 3.54 17.53 20.06

Whitefish 0.14 0.15 0.17 0.17 <0.01 <0.01 <0.01 <0.01 0.14 0.15 0.17 0.17

Windowpane <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.02 <0.01 <0.01 0.02 0.02

Winter flounder 0.03 0.03 0.03 0.04 <0.01 0.05 4.75 6.19 0.03 0.08 4.78 6.23

Yellow perch 2.78 2.91 3.35 3.76 <0.01 0.02 1.86 2.40 2.78 2.93 5.20 6.16

Total (all species) 612.75 647.47 748.19 824.23 1.41 4.53 889.31 1106.74 614.16 652.00 1637.49 1930.97

Notes:

P4 = Proposal Option 4; F = Final Rule – Existing Units; P2 = Proposal Option 2; and B = Baseline

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-23

Table C-16: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) Nationally (million individuals per year), and 

Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

Alewife 24.60 26.09 29.95 32.87 10.32 32.59 10,007.54 13,903.96 34.92 58.68 10,037.49 13,936.83

American plaice <0.01 <0.01 <0.01 <0.01 <0.01 0.86 73.53 96.04 <0.01 0.86 73.53 96.04 

American sand lance 0.05 0.05 0.07 0.08 <0.01 6.31 542.26 708.25 0.05 6.36 542.33 708.33 

American shad 6.59 6.82 7.86 9.03 0.03 0.05 18.42 21.14 6.63 6.87 26.28 30.16 

Atlantic cod <0.01 <0.01 <0.01 <0.01 <0.01 0.50 43.33 56.59 <0.01 0.50 43.33 56.59 

Atlantic croaker 7.31 7.61 9.08 10.06 0.41 0.58 238.62 300.83 7.72 8.19 247.71 310.89 

Atlantic herring 0.01 0.01 0.02 0.02 <0.01 0.37 32.23 42.09 0.01 0.39 32.24 42.11 

Atlantic mackerel <0.01 <0.01 <0.01 <0.01 <0.01 30.35 2,608.87 3,407.48 <0.01 30.35 2,608.87 3,407.48 

Atlantic menhaden 20.76 22.18 25.40 27.47 0.06 21.64 1,648.53 2,133.07 20.82 43.82 1,673.93 2,160.54 

Atlantic silverside 0.48 0.52 0.61 0.65 0.05 0.50 65.89 81.26 0.54 1.01 66.50 81.92 

Atlantic tomcod 0.04 0.04 0.05 0.06 <0.01 0.03 2.32 3.03 0.04 0.07 2.37 3.08 

Bay anchovy 12.49 13.31 16.89 17.64 175.17 492.67 140,265.10 214,225.98 187.66 505.98 140,281.99 214,243.63

Bigmouth buffalo 0.01 0.01 0.02 0.02 <0.01 0.02 1.98 2.55 0.02 0.03 1.99 2.56

Black bullhead 0.12 0.12 0.14 0.16 <0.01 <0.01 0.02 0.02 0.12 0.12 0.16 0.18 

Black crappie 0.12 0.13 0.14 0.17 0.02 0.08 9.12 11.74 0.14 0.21 9.26 11.90

Black drum 0.01 0.01 0.01 0.02 40.50 40.50 29,342.08 49,690.98 40.51 40.51 29,342.09 49,691.00 

Blennies <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 390.33 639.92 <0.01 <0.01 390.33 639.92 

Blue crab 5.91 6.17 7.39 8.14 1.80 2.65 1,018.09 1,215.03 7.71 8.82 1,025.48 1,223.17 

Blueback herring 64.53 66.74 76.98 88.32 1.15 5.94 649.73 835.52 65.68 72.68 726.70 923.84 

Bluefish <0.01 <0.01 0.01 0.01 <0.01 <0.01 0.02 0.03 <0.01 <0.01 0.03 0.04

Bluegill 12.33 12.76 14.71 16.88 0.03 0.16 17.70 22.79 12.37 12.92 32.41 39.67 

Bluntnose minnow 0.08 0.09 0.10 0.11 3.21 16.66 1,810.66 2,331.37 3.29 16.75 1,810.76 2,331.48 

Brown bullhead 0.03 0.04 0.04 0.05 <0.01 <0.01 0.16 0.20 0.03 0.04 0.20 0.25 

Bullheads 0.02 0.02 0.02 0.03 <0.01 0.01 1.35 1.74 0.02 0.03 1.38 1.77 

Burbot <0.01 <0.01 <0.01 <0.01 0.01 0.06 6.18 7.99 0.01 0.06 6.19 7.99 

Butterfish <0.01 <0.01 <0.01 <0.01 <0.01 0.05 4.48 5.86 <0.01 0.06 4.49 5.86 

Cabezon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 2.84 4.65 <0.01 <0.01 2.84 4.65

California halibut <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 3.29 5.40 <0.01 <0.01 3.29 5.40 

California scorpionfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Carp 0.16 0.17 0.19 0.21 3.64 17.07 2,413.26 3,195.22 3.80 17.24 2,413.45 3,195.43 

Chain pipefish 0.03 0.03 0.04 0.04 <0.01 <0.01 0.65 1.10 0.03 0.03 0.68 1.14 

Channel catfish 0.81 0.84 0.97 1.09 0.14 0.71 77.69 100.08 0.94 1.55 78.65 101.17 

Chinook salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Crabs (other) 0.04 0.05 0.05 0.07 <0.01 14.77 3,352.55 5,345.69 0.04 14.82 3,352.61 5,345.76 

Crappie 0.21 0.22 0.25 0.29 0.04 0.23 25.25 32.55 0.25 0.45 25.50 32.84

Cunner <0.01 <0.01 <0.01 <0.01 <0.01 125.28 10,767.77 14,063.92 <0.01 125.28 10,767.78 14,063.92 

Darters 0.35 0.36 0.42 0.48 0.11 0.55 60.18 77.56 0.45 0.91 60.60 78.03 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-24

Table C-16: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) Nationally (million individuals per year), and 

Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

Delta smelt <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 <0.01 <0.01 0.01 

Drums and croakers 0.23 0.25 0.28 0.38 <0.01 52.55 1,330.12 1,644.78 0.23 52.80 1,330.40 1,645.16 

Dungeness crab <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.04 0.06 <0.01 <0.01 0.04 0.06 

Emerald shiner 27.71 30.40 34.66 35.75 0.51 2.57 302.77 393.49 28.22 32.97 337.43 429.24

Fish (other) 34.17 35.42 41.09 46.79 61.61 281.13 40,788.65 54,861.96 95.78 316.55 40,829.74 54,908.74 

Flounders <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 136.20 223.29 <0.01 <0.01 136.20 223.30 

Fourbeard rockling <0.01 <0.01 <0.01 <0.01 <0.01 1.99 171.36 223.81 <0.01 1.99 171.36 223.81 

Freshwater drum 2.17 2.28 2.62 2.92 3.50 15.05 2,600.41 3,500.19 5.67 17.33 2,603.03 3,503.11 

Gizzard shad 136.50 143.06 164.58 184.46 13.48 67.84 8,016.95 10,423.97 149.97 210.90 8,181.53 10,608.43

Gobies 0.06 0.06 0.07 0.08 1.56 80.89 3,194.95 4,457.82 1.62 80.95 3,195.03 4,457.91 

Golden redhorse 0.03 0.03 0.04 0.04 <0.01 <0.01 1.05 1.35 0.03 0.04 1.09 1.39 

Grubby <0.01 <0.01 0.01 0.01 <0.01 1.85 159.13 207.84 <0.01 1.86 159.14 207.85

Gulf killifish 0.02 0.02 0.02 0.02 <0.01 <0.01 <0.01 <0.01 0.02 0.02 0.02 0.02 

Herrings 0.03 0.03 0.03 0.04 <0.01 <0.01 14.12 22.41 0.03 0.04 14.15 22.46 

Hogchoker 0.24 0.25 0.30 0.32 12.92 21.78 7,393.21 8,549.29 13.15 22.03 7,393.51 8,549.62

Leatherjacket 0.41 0.42 0.51 0.56 0.33 0.33 241.86 409.59 0.74 0.76 242.37 410.16 

Logperch 0.61 0.65 0.75 0.82 0.05 0.21 43.41 59.11 0.67 0.87 44.16 59.93 

Longfin smelt <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Lumpfish <0.01 <0.01 <0.01 <0.01 <0.01 0.19 16.57 21.64 <0.01 0.19 16.57 21.64 

Mackerels <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Menhadens 6.91 7.17 8.60 9.55 0.11 0.11 82.01 138.87 7.02 7.28 90.61 148.41

Muskellunge <0.01 <0.01 0.01 0.01 <0.01 <0.01 0.32 0.45 <0.01 <0.01 0.33 0.46 

Northern anchovy 0.37 0.39 0.42 0.61 <0.01 <0.01 352.68 578.20 0.37 0.39 353.10 578.81 

Northern pipefish 0.01 0.01 0.01 0.02 <0.01 0.01 3.35 3.91 0.02 0.03 3.36 3.92 

Pacific herring <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 15.43 25.30 <0.01 <0.01 15.43 25.30

Pinfish 0.05 0.05 0.06 0.07 0.05 1.62 61.04 85.76 0.10 1.68 61.10 85.83 

Pink shrimp 18.80 19.51 23.41 25.98 0.05 0.05 38.48 65.16 18.85 19.57 61.88 91.15

Pollock <0.01 <0.01 <0.01 <0.01 <0.01 0.01 1.28 1.67 <0.01 0.02 1.28 1.67

Radiated shanny <0.01 <0.01 <0.01 <0.01 <0.01 0.47 40.74 53.21 <0.01 0.47 40.74 53.21

Rainbow smelt 0.33 0.35 0.41 0.43 0.76 2.56 729.57 1,010.91 1.09 2.91 729.98 1,011.34

Red drum 0.07 0.08 0.09 0.10 <0.01 <0.01 0.33 0.57 0.07 0.08 0.43 0.67 

Red hake 0.02 0.02 0.03 0.03 <0.01 <0.01 <0.01 <0.01 0.02 0.02 0.03 0.03

River carpsucker 0.01 0.01 0.01 0.02 <0.01 0.02 1.89 2.44 0.01 0.03 1.91 2.45 

Rock gunnel <0.01 <0.01 <0.01 <0.01 <0.01 1.70 146.13 190.86 <0.01 1.70 146.13 190.86 

Rockfishes 0.01 0.01 0.01 0.02 <0.01 <0.01 27.29 44.74 0.01 0.01 27.30 44.76

Sacramento splittail <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 1.62 2.25 <0.01 <0.01 1.62 2.25 

Sauger 0.08 0.08 0.09 0.11 0.20 1.06 115.46 148.65 0.28 1.14 115.56 148.75 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-25

Table C-16: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) Nationally (million individuals per year), and 

Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

Scaled sardine 0.15 0.15 0.18 0.20 1.25 1.25 902.35 1,528.14 1.39 1.40 902.54 1,528.34 

Sculpins <0.01 0.01 0.01 0.02 <0.01 0.94 102.09 140.23 0.01 0.95 102.10 140.25 

Scup <0.01 <0.01 <0.01 <0.01 <0.01 0.07 6.14 8.02 <0.01 0.07 6.14 8.03 

Sea Basses <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 5.65 9.26 <0.01 <0.01 5.65 9.26 

Seaboard goby <0.01 <0.01 <0.01 <0.01 6.76 20.41 4,637.25 5,460.76 6.77 20.42 4,637.26 5,460.77 

Searobin 0.51 0.53 0.63 0.70 0.03 0.08 25.20 41.04 0.54 0.60 25.83 41.74

Sheepshead <0.01 <0.01 <0.01 <0.01 0.16 0.16 116.63 197.51 0.16 0.16 116.63 197.51 

Shiners 1.88 1.99 2.28 2.51 0.23 1.13 148.42 195.04 2.11 3.12 150.70 197.55

Shrimp (other) 2.31 2.48 3.37 3.41 <0.01 23.01 594.47 740.02 2.31 25.48 597.84 743.43 

Silver hake 0.02 0.02 0.02 0.02 <0.01 2.44 209.93 274.19 0.02 2.46 209.95 274.21 

Silver perch 0.31 0.33 0.42 0.44 37.41 37.41 27,105.51 45,903.34 37.73 37.74 27,105.92 45,903.78 

Silversides 0.10 0.11 0.12 0.15 0.03 0.16 69.85 108.12 0.13 0.27 69.97 108.27 

Skates <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Skipjack herring 0.53 0.54 0.63 0.72 <0.01 <0.01 0.20 0.25 0.53 0.55 0.83 0.97 

Smallmouth bass 0.06 0.07 0.08 0.09 0.04 0.18 20.03 25.79 0.10 0.25 20.11 25.87 

Smelts 1.18 1.30 1.48 1.52 0.04 0.13 41.11 57.51 1.22 1.43 42.59 59.03 

Spot 3.45 3.67 4.28 4.63 0.13 47.79 925.53 1,001.16 3.58 51.46 929.81 1,005.79 

Spotted seatrout 0.52 0.54 0.64 0.72 2.24 3.02 1,639.94 2,768.53 2.76 3.56 1,640.58 2,769.25 

Spotted sucker <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Stone crab 0.12 0.12 0.15 0.16 12.07 12.07 8,745.52 14,810.59 12.19 12.19 8,745.67 14,810.76

Striped bass 0.58 0.60 0.69 0.79 0.52 0.79 295.84 341.86 1.10 1.39 296.52 342.65

Striped killifish 0.09 0.10 0.12 0.13 <0.01 <0.01 0.02 0.03 0.09 0.10 0.14 0.16 

Striped mullet 0.19 0.20 0.24 0.27 <0.01 <0.01 4.62 7.82 0.20 0.21 4.86 8.09 

Sturgeons <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.54 0.69 <0.01 <0.01 0.54 0.69 

Suckers 0.06 0.07 0.08 0.09 2.86 14.80 1,627.05 2,097.86 2.93 14.87 1,627.12 2,097.94 

Summer flounder 0.02 0.02 0.03 0.03 <0.01 <0.01 <0.01 <0.01 0.02 0.02 0.03 0.03

Sunfish 2.22 2.29 2.64 3.03 0.43 2.20 240.66 310.09 2.64 4.49 243.31 313.12 

Surfperches 0.06 0.06 0.06 0.09 <0.01 <0.01 <0.01 <0.01 0.06 0.06 0.06 0.09 

Tautog <0.01 <0.01 <0.01 <0.01 <0.01 125.83 10,815.39 14,126.11 <0.01 125.84 10,815.39 14,126.11 

Threespine stickleback 0.03 0.04 0.04 0.05 <0.01 <0.01 0.21 0.29 0.03 0.04 0.26 0.34 

Tidewater silverside 0.13 0.13 0.16 0.18 0.01 0.01 10.47 17.73 0.14 0.15 10.63 17.90 

Walleye 0.14 0.15 0.17 0.18 0.12 0.60 71.64 93.18 0.26 0.75 71.81 93.36 

Weakfish 0.98 1.04 1.20 1.29 0.24 4.06 299.81 360.95 1.22 5.11 301.01 362.24 

White bass 3.05 3.29 3.77 4.00 0.76 3.80 449.52 584.53 3.80 7.09 453.28 588.53 

White perch 11.30 12.32 14.06 14.67 1.84 4.77 1,129.04 1,388.88 13.14 17.09 1,143.10 1,403.55 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix C: Details of Regional IM&E

May 2014 C-26

Table C-16: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) Nationally (million individuals per year), and 

Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality

Species Impingement Entrainment IM&E

P4 F P2 B P4 F P2 B P4 F P2 B

Whitefish 0.03 0.03 0.04 0.04 <0.01 <0.01 0.36 0.47 0.03 0.04 0.39 0.51 

Windowpane <0.01 <0.01 <0.01 0.01 <0.01 8.88 762.82 996.32 <0.01 8.88 762.83 996.33

Winter flounder 0.05 0.05 0.06 0.07 0.05 28.79 2,494.01 3,253.45 0.09 28.84 2,494.07 3,253.52

Yellow perch 3.81 3.99 4.59 5.15 0.73 3.77 419.01 540.94 4.54 7.76 423.60 546.09 

Total (all species) 419.91 441.30 511.87 568.56 399.82 1,693.86 335,447.57 497,316.28 819.74 2,135.17 335,959.44 497,884.85

Notes:

P4 = Proposal Option 4; F = Final Rule – Existing Units; P2 = Proposal Option 2; and B = Baseline

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix D: Discounting Benefits

July 8, 2014 D-1

Appendix D: Discounting Benefits

D.1 Introduction

Discounting refers to the economic conversion of future benefits and costs to present values, accounting 

for the fact that individuals tend to value future outcomes less than comparable near-term outcomes. 

Annualization refers to the conversion of a series of annual costs or benefits of differing amounts to an 

equivalent annual series of constant costs or benefits. Discounting and annualization are important 

techniques which allow the comparison of benefits and/or costs that occur in different time periods.

EPA’s discounting and annualization methodology for the benefits analysis of the final rule and options 

considered, included three steps. First, EPA developed a time profile of benefits to show when benefits 

occur. Second, the Agency calculated the total discounted present value of the benefits as of the year 

2013. Finally, EPA annualized the benefits of the final rule and other options considered, over a 51-year 

time span. The following sections explain these steps in detail.

D.2 Timing of Benefits

To calculate the annualized value of the potential welfare gains, EPA first calculated the undiscounted 

welfare gain from the expected annual regional reductions in IM&E under the final rule and other options 

considered assuming all facilities have installed required technology. Then, EPA created a time profile of

benefits that takes into account the regulatory and biological time lags between the potential promulgation 

of the final rule and each regulatory option considered, and the realization of benefits.

EPA assigned each facility a technology installation year which varies across facilities and regulatory 

options based on facility characteristics and type of technology being installed. Facilities installing 

impingement only technology have technology installation years ranging from 2018 to 2022, non-nuclear 

electric generating facilities and manufacturing facilities installing towers have technology installation 

years ranging from 2020 to 2024, and nuclear generating facilities installing towers have technology 

installation years ranging from 2026 to 2030. EPA estimates that a small number of manufacturers could 

be required to install both IM&E technology and towers. EPA assumed that these facilities would install 

both technologies at the same time, during the 5-year window of 2021 through 2025. Compliance is 

assumed to continue until the year 2059 for all facilities. See Chapter 3 of the EA report for more detail.

A biological time lag occurs between installation of technologies to reduce IM&E and realization of 

commercial and recreational angling benefits because these fish may require several years to grow and 

mature before commercial and recreational anglers can harvest them. For example, a larval fish spared 

from entrainment (in effect, at age zero) may be caught by a recreational angler at age three. A three-year 

time lag then arises between the installation of technologies to reduce IM&E and the realization of the 

estimated recreational benefit. Likewise, if a one-year-old fish is spared from impingement and is then 

harvested by a commercial fisherman at age two, there is a one-year lag between the installation of 

technologies to reduce IM&E and the subsequent commercial fishery benefit. In general, there will be

relatively short time lags between implementation of technologies to reduce IM&E and the subsequent 

timing of changes in catch for fish that tend to be harvested at young ages. In contrast, for long-lived fish 

that tend to be caught at relatively older ages, there would be longer time lags and, hence, the effects of 

discounting would be larger, resulting in lower present values.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix D: Discounting Benefits

July 8, 2014 D-2

To model the biological time lags, EPA collected species-specific information on ages of fish at harvest to 

estimate the average time required for a fish spared from IM&E, to reach a harvestable age. The estimated 

time lags vary, depending on the life history of each fish species affected. EPA used this information, 

along with information about the estimated age and species composition of IM&E in each study region, to 

develop a benefits schedule for facilities in each region.93 EPA used these lags in analyses for both 

existing and new units.

EPA assumes that once facilities have installed technology, commercial and recreational fishing benefits 

from facilities in most regions (the California, North Atlantic, Mid-Atlantic, and South Atlantic regions) 

increase over a seven-year period to a long-term, steady-state average. This average is equal to the 

approximated per-facility benefit value discussed above, according to a numerical profile of <0.0, 0.1, 

0.2, 0.8, 0.9, 0.95, 1.0>. This profile is the fraction of the steady-state benefit value (i.e., the percentage of 

commercial and recreational fish spared from IM&E that reach a harvestable age) that is realized in each 

of the first seven years following a facility installing technology. 

For regions with a relatively high contribution of impingement to total IM&E (the Inland, Great Lakes, 

and Gulf of Mexico regions), EPA used an adjusted profile of <0.1, 0.2, 0.8, 0.9, 0.95, 1.0> for 

commercial and recreational fishing benefits. This adjusted profile reflects the fact that impinged fish are 

usually larger and older than entrained fish, and thus benefits will be realized sooner in these three 

regions. These profile values are approximations based on a review of the age-specific fishing mortality 

rates that EPA used in the IM&E analysis and best professional judgment.94

In all regions, this fraction remains 1.0 until the final year of compliance, 2059. The commercial and 

recreational fishing benefits profile declines at the end of the compliance period in the same fashion that it 

increases after technology installation. This reflects the fact that the fish saved by technology would 

survive and could still be harvested beyond the end of the compliance period. Specifically, at the end of

the compliance period, benefit values decline following a profile of <0.9, 0.8, 0.2, 0.1, 0.05, 0.0>, with 

the last benefits occurring in 2064. Therefore, the benefits analysis encompasses a 51-year period from 

rule promulgation and first incidence of compliance-related costs in 2014, until the final benefits are 

realized in 2064. The number of years when benefits do not equal zero varies among the regulated 

facilities, depending on the year that it installs technology. 

EPA assumes no initial biological lag for nonuse benefits (including benefit transfer and preliminary 

benefits based on the 316(b) SP survey) at the start of the compliance period because nonuse benefits are 

not based on the harvest of fish spared from IM&E. EPA assumes that benefits begin accruing 

immediately when a facility installs technology, and continue being generated in full until the year 2059. 

The nonuse benefit transfer includes a linear decline in benefits starting at the end of the compliance 

period following a profile of <1.0, 0.82, 0.62, 0.37, 0.20, 0.06, 0.0> with the last benefits occurring in 

2064. This profile reflects NMFS estimates of age-specific and fisheries-related mortality. For the 

analysis for the 316(b) SP survey, EPA assumes that benefits end in 2059, the final year of the 

compliance period, and does not include a declining profile beyond this year. This is consistent with the 

definition of the fish saved attribute which was used to generate preliminary benefits estimates based on 

 

93 The benefits profile aggregated across all facilities in a region or nationwide was calculated using facility-level sample 

weights. These facility-level sample weights were designed so that the weighted actual regional intake flow for the sample 

facilities is the same as the estimated actual regional intake flow for the entire universe of facilities. These sample weights 

are described in more detail in Appendix A.

94 EPA applied biological lags consistent with the Inland, Great Lakes, and Gulf Mexico regions when estimating commercial, 

recreational, and T&E species benefits for new units because these regions account for the majority of national benefits for 

these categories.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix D: Discounting Benefits

July 8, 2014 D-3

the 316(b) SP survey. EPA does not include any lags in its analysis of benefits associated with changes in 

GHG emissions. 

D.3 Discounting and Annualization

Using the time profile of benefits discussed above, EPA discounted the total benefits generated in each 

year of the analysis to 2013 using the following formula:

 





t

t

t

r

2013 (1 )

Benefits

Present Value

(D-1)

where:

Benefitst = benefits in year t

r = discount rate (3 percent and 7 percent)

t = year in which benefits are incurred

After calculating the present value (PV) of these benefit streams, EPA calculated a constant annual 

equivalent value (annualized value) using the annualization formula presented below, again using two 

discount rates, 3 percent and 7 percent.

95 Although the analysis period extends further, EPA annualized 

benefits over the assumed period of compliance for regulated facilities. EPA followed this same 

annualization concept and period of annualization in the cost analysis, although the time horizon for 

calculating the present value is shorter than for benefits. Using the same annualization period for both 

benefits and social costs allows EPA to compare constant annual equivalent values of benefits and costs 

that have been calculated on a mathematically consistent basis. The annualization formula is as follows:

















 







(1 ) 1

*(1 )

Annualized Benefit PV of Benefit * 

( 1)

n

n

r

r r

(D-2)

where:

r = discount rate (3 percent and 7 percent)

n = annualization period, 51 years for the benefits analysis

Table D-1 presents a summary of the time profile of benefits discounted at the 3 percent and 7 percent 

rates for the final rule and the regulatory options considered, on the national scale. The table also presents 

the total and annualized values that are equivalent to this stream of benefits.

 

95 The three percent rate represents an estimate of the social rate of time preference. 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix D: Discounting Benefits

July 8, 2014 D-4

Table D-1: Time Profile of Discounted National Mean Benefits at Regulated Facilities by Regulatory Option using 3% and 7% 

Discount Rates (2011$, millions)a

Year Proposal Option 4 Final Rule – Existing Units Proposal Option 2 Final Rule –New Units Final Rule -Existing Units 

and New Units

3% 7% 3% 7% 3% 7% 3% 7% 3% 7% 

2013 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000

2014 $0.000 $0.000 $0.000 $0.000 $0.000 $0.000 $0.004 $0.004 $0.004 $0.004

2015 $8.147 $7.550 $8.147 $7.550 $0.000 $0.000 $0.008 $0.008 $8.156 $7.557

2016 $8.124 $7.246 $8.124 $7.246 $0.000 $0.000 $0.014 $0.012 $8.138 $7.259

2017 $8.095 $6.951 $8.095 $6.951 $0.000 $0.000 $0.008 $0.007 $8.103 $6.957

2018 -$1.517 -$1.254 -$1.334 -$1.103 $118.959 $98.325 $0.002 $0.002 -$1.332 -$1.101

2019 -$1.488 -$1.184 -$1.302 -$1.036 $121.271 $96.489 -$0.005 -$0.004 -$1.307 -$1.040

2020 -$0.670 -$0.513 -$0.158 -$0.121 $121.582 $93.120 -$0.011 -$0.009 -$0.170 -$0.130

2021 $0.542 $0.399 $1.236 $0.911 -$999.546 -$736.937 -$0.017 -$0.012 $1.219 $0.899

2022 $5.572 $3.955 $6.772 $4.806 -$974.242 -$691.429 -$0.023 -$0.016 $6.749 $4.790

2023 $43.850 $29.958 $45.283 $30.936 -$1,079.211 -$737.294 -$0.029 -$0.020 $45.253 $30.916

2024 $49.786 $32.741 $51.603 $33.936 -$1,052.143 -$691.931 -$0.036 -$0.024 $51.567 $33.913

2025 $51.111 $32.356 $53.031 $33.571 -$1,031.582 -$653.048 -$0.043 -$0.027 $52.988 $33.544

2026 $51.040 $31.103 $52.955 $32.270 -$1,709.258 -$1,041.604 -$0.049 -$0.030 $52.905 $32.240

2027 $50.690 $29.735 $52.582 $30.845 -$1,689.775 -$991.236 -$0.056 -$0.033 $52.526 $30.812

2028 $49.896 $28.175 $51.737 $29.215 -$1,671.154 -$943.666 -$0.063 -$0.035 $51.675 $29.180

2029 $49.052 $26.663 $50.840 $27.635 -$1,651.425 -$897.664 -$0.069 -$0.038 $50.771 $27.597

2030 $48.215 $25.229 $49.951 $26.137 -$1,634.747 -$855.380 -$0.076 -$0.040 $49.875 $26.097

2031 $46.811 $23.578 $48.496 $24.427 -$1,143.475 -$575.955 -$0.079 -$0.040 $48.417 $24.387

2032 $46.005 $22.306 $47.642 $23.099 -$1,131.655 -$548.693 -$0.086 -$0.042 $47.556 $23.058

2033 $15.959 $7.448 $17.547 $8.190 -$1,120.741 -$523.087 -$0.092 -$0.043 $17.455 $8.147

2034 $15.494 $6.961 $17.036 $7.654 -$1,109.610 -$498.532 -$0.098 -$0.044 $16.938 $7.610

2035 $15.043 $6.506 $16.540 $7.153 -$1,098.347 -$475.024 -$0.104 -$0.045 $16.436 $7.108

2036 $14.604 $6.080 $16.058 $6.685 -$1,086.843 -$452.477 -$0.110 -$0.046 $15.948 $6.640

2037 $14.179 $5.682 $15.591 $6.248 -$1,074.992 -$430.812 -$0.116 -$0.046 $15.475 $6.202

2038 $13.766 $5.311 $15.136 $5.839 -$1,062.923 -$410.051 -$0.122 -$0.047 $15.015 $5.792

2039 $13.365 $4.963 $14.696 $5.457 -$1,050.571 -$390.135 -$0.127 -$0.047 $14.568 $5.410

2040 $12.976 $4.639 $14.268 $5.100 -$1,038.033 -$371.068 -$0.133 -$0.047 $14.135 $5.053

2041 $12.598 $4.335 $13.852 $4.767 -$1,025.492 -$352.881 -$0.138 -$0.047 $13.714 $4.719

2042 $12.231 $4.051 $13.449 $4.455 -$1,012.802 -$335.486 -$0.143 -$0.047 $13.305 $4.407

2043 $11.875 $3.786 $13.057 $4.163 -$999.981 -$318.856 -$0.148 -$0.047 $12.909 $4.116

2044 $11.529 $3.539 $12.677 $3.891 -$987.047 -$302.967 -$0.153 -$0.047 $12.524 $3.844

2045 $11.193 $3.307 $12.307 $3.636 -$974.019 -$287.791 -$0.158 -$0.047 $12.150 $3.590

2046 $10.867 $3.091 $11.949 $3.399 -$960.912 -$273.305 -$0.162 -$0.046 $11.787 $3.352

2047 $10.551 $2.889 $11.601 $3.176 -$947.742 -$259.482 -$0.167 -$0.046 $11.434 $3.131
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix D: Discounting Benefits

July 8, 2014 D-5

Table D-1: Time Profile of Discounted National Mean Benefits at Regulated Facilities by Regulatory Option using 3% and 7% 

Discount Rates (2011$, millions)a

Year Proposal Option 4 Final Rule – Existing Units Proposal Option 2 Final Rule –New Units Final Rule -Existing Units 

and New Units

3% 7% 3% 7% 3% 7% 3% 7% 3% 7% 

2048 $10.243 $2.700 $11.263 $2.968 -$934.525 -$246.298 -$0.171 -$0.045 $11.092 $2.923

2049 $9.945 $2.523 $10.935 $2.774 -$921.273 -$233.729 -$0.175 -$0.044 $10.760 $2.730

2050 $9.655 $2.358 $10.616 $2.593 -$908.001 -$221.750 -$0.179 -$0.044 $10.438 $2.549

2051 $9.374 $2.204 $10.307 $2.423 -$894.911 -$210.383 -$0.182 -$0.043 $10.125 $2.380

2052 $9.101 $2.060 $10.007 $2.265 -$881.999 -$199.596 -$0.186 -$0.042 $9.821 $2.222

2053 $8.836 $1.925 $9.715 $2.116 -$869.263 -$189.360 -$0.190 -$0.041 $9.526 $2.075

2054 $8.579 $1.799 $9.433 $1.978 -$856.700 -$179.647 -$0.193 -$0.040 $9.240 $1.937

2055 $8.329 $1.681 $9.158 $1.849 -$844.308 -$170.430 -$0.196 -$0.040 $8.961 $1.809

2056 $8.086 $1.571 $8.891 $1.728 -$832.085 -$161.684 -$0.200 -$0.039 $8.692 $1.689

2057 $7.851 $1.468 $8.632 $1.615 -$820.030 -$153.385 -$0.203 -$0.038 $8.429 $1.577

2058 $7.622 $1.372 $8.381 $1.509 -$808.141 -$145.510 -$0.206 -$0.037 $8.175 $1.472

2059 $7.400 $1.283 $8.137 $1.410 -$796.414 -$138.038 -$0.209 -$0.036 $7.928 $1.374

2060 $6.459 $1.078 $7.086 $1.182 $35.306 $5.891 $0.065 $0.011 $7.151 $1.193

2061 $5.567 $0.894 $6.093 $0.979 $29.154 $4.682 $0.054 $0.009 $6.146 $0.987

2062 $1.384 $0.214 $1.586 $0.245 $13.337 $2.062 $0.027 $0.004 $1.613 $0.249

2063 $0.680 $0.101 $0.795 $0.118 $7.937 $1.181 $0.016 $0.002 $0.811 $0.121

2064 $0.330 $0.047 $0.387 $0.055 $3.942 $0.565 $0.008 $0.001 $0.395 $0.057

Total Present Valueb

- $828.931 $402.860 $880.882 $424.898 -$41,234.429 -$16,994.287 -$4.694 -$1.492 $876.188 $423.406

Annualized Valuec

- $31.012 $27.219 $32.955 $28.708 -$1,542.641 -$1,148.205 -$0.176 -$0.101 $32.779 $28.607

a Values presented here are based on 3 percent average SCC values.

b The total present value is equal to the sum of the values of the benefits realized in all years of the analysis, discounted to 2013.

c The annualized value represents the total present value of the benefits of the rule, distributed over a 51-year period.

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix E: List of T&E Species Overlapping CWIS

July 8, 2014 E-1

Appendix E: List of T&E Species Overlapping CWIS

Table E-1: List of 99 T&E Species Overlapping One or More Regulated CWIS

Latin Name Common Name

Acipenser brevirostrum Shortnose Sturgeon

Acipenser medirostris Green Sturgeon

Acipenser oxyrinchus desotoi Gulf Sturgeon

Acipenser oxyrinchus oxyrinchus Atlantic Sturgeon

Alasmidonta heterodon Dwarf Wedgemussel

Amblema neislerii Fat Threeridge

Amblyopsis rosae Ozark Cavefish

Arkansia wheeleri Ouachita Rock Pocketbook

Athearnia anthonyi Anthony's Riversnail

Campeloma decampi Slender Campeloma

Caretta caretta Loggerhead Sea Turtle

Chelonia mydas Green Sea Turtle

Cottus Paulus Pygmy Sculpin

Cyprinella caerulea Blue Shiner

Cyprogenia stegaria Fanshell

Dermochelys coriacea Leatherback Sea Turtle

Dromus dromas Dromedary Pearlymussel

Elliptio chipolaensis Chipola Slabshell

Elliptio spinosa Altamaha Spinymussel

Elliptio steinstansana Tar River Spinymussel

Elliptoideus sloatianus Purple Bankclimber

Epioblasma brevidens Cumberlandian Combshell

Epioblasma capsaeformis Oyster Mussel

Epioblasma florentina florentina Yellow (Pearlymussel) Blossom

Epioblasma florentina walkeri Tan Riffleshell

Epioblasma obliquata obliquata Catspaw (Purple Cat's Paw Pearlymussel)

Epioblasma obliquata perobliqua White (Pearlymussel) Catspaw

Epioblasma torulosa gubernaculum Green (Pearlymussel) Blossom

Epioblasma torulosa rangiana Northern Riffleshell

Epioblasma torulosa torulosa Tubercled (Pearlymussel) Blossom

Epioblasma turgidula Turgid (Pearlymussel) Blossom

Eretmochelys imbricata Hawksbill Sea Turtle

Etheostoma etowahae Etowah Darter

Etheostoma percnurum Duskytail Darter

Etheostoma scotti Cherokee Darter

Etheostoma wapiti Boulder Darter

Fusconaia cor Shiny Pigtoe

Fusconaia cuneolus Finerayed Pigtoe

Gasterosteus aculeatus williamsoni Unarmored Threespine Stickleback

Gila bicolor mohavensis Mohave Tui Chub

Hemistena lata Cracking Pearlymussel

Hypomesus transpacificus Delta Smelt

Lampsilis abrupta Pink (Pearlymussel) Mucket
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix E: List of T&E Species Overlapping CWIS

July 8, 2014 E-2

Table E-1: List of 99 T&E Species Overlapping One or More Regulated CWIS

Latin Name Common Name

Lampsilis higginsii Higgins Eye (Pearlymussel)

Lampsilis powellii Arkansas Fatmucket

Lampsilis subangulata Shinyrayed Pocketbook

Lampsilis virescens Alabama Lampmussel

Lepidochelys kempii Kemp's Ridley Sea Turtle

Lepidochelys olivacea Olive Ridley Sea Turtle

Leptodea leptodon Scaleshell Mussel

Leptoxis ampla Round Rocksnail

Leptoxis foreman Interrupted (Georgia) Rocksnail

Leptoxis plicata Plicate Rocksnail

Leptoxis taeniata Painted Rocksnail

Margaritifera hembeli Louisiana Pearlshell

Medionidus penicillatus Gulf Moccasinshell

Medionidus simpsonianus Ochlockonee Moccasinshell

Notropis albizonatus Palezone Shiner

Noturus placidus Neosho Madtom

Noturus stanauli Pygmy Madtom

Obovaria retusa Ring Pink (Mussel)

Oncorhynchus clarki stomias Greenback Cutthroat

Oncorhynchus keta Chum Salmon

Oncorhynchus kisutch Coho Salmon

Oncorhynchus mykiss Steelhead Trout

Oncorhynchus tshawytscha Chinook Salmon

Oregonichthys crameri Oregon Chub

Pegias fabula Littlewing Pearlymussel

Percina rex Roanoke Logperch

Percina tanasi Snail Darter

Phoxinus cumberlandensis Blackside Dace

Plethobasus cicatricosus White (Pearlymussel) Wartyback

Plethobasus cooperianus Orangefoot (Pearlymussel) Pimpleback

Pleurobema clava Clubshell

Pleurobema collina James Spinymussel

Pleurobema curtum Black Clubshell

Pleurobema hanleyianum Georgia Pigtoe

Pleurobema marshalli Flat Pigtoe

Pleurobema plenum Rough Pigtoe

Pleurobema pyriforme Oval Pigtoe

Pleurobema taitianum Heavy Pigtoe

Pleurocera foremani Rough Hornsnail

Potamilus capax Fat Pocketbook

Potamilus inflatus Alabama (Inflated) Heelsplitter

Ptychocheilus lucius Colorado Pikeminnow (Squawfish)

Quadrula cylindrica strigillata Rough Rabbitsfoot

Quadrula fragosa Winged Mapleleaf

Quadrula intermedia Cumberland (Pearlymussel) Monkeyface

Quadrula sparsa Appalachian (Pearlymussel) Monkeyface

Quadrula stapes Stirrupshell
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix E: List of T&E Species Overlapping CWIS

July 8, 2014 E-3

Table E-1: List of 99 T&E Species Overlapping One or More Regulated CWIS

Latin Name Common Name

Salmo salar Atlantic Salmon

Salvelinus confluentus Bull Trout

Scaphirhynchus albus Pallid Sturgeon

Scaphirhynchus suttkusi Alabama Sturgeon

Speoplatyrhinus poulsoni Alabama Cavefish

Toxolasma cylindrellus Pale (Pearlymussel) Lilliput

Villosa perpurpurea Purple Bean

Villosa trabalis Cumberland (Pearlymussel) Bean

Xyrauchen texanus Razorback Sucker

Source: U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix F: Methods for T&E Species Benefits

July 8, 2014 F-1

Appendix F: Detailed Methodologies for Estimating Benefits to 

Threatened and Endangered Species

F.1 IM&E of Sea Turtles

Six species of sea turtles are found in waters of the United States: Green, Hawksbill, Kemp's Ridley, 

Leatherback, Loggerhead, and Olive Ridley sea turtles. All have extensive ranges, migrate long distances 

during their lifetime, and are listed as either T&E under the ESA. Because of these large ranges, there is 

substantial overlap between sea turtle habitat and CWIS for regulated facilities. Moreover, because 

individuals of all ages and sizes are susceptible to impingement and entrainment (Norem 2005), there are 

more than 730 locations of potential interactions between species ranges and CWIS that may result in the 

injury or death of these T&E species.

Power plants are known to entrain and impinge all species of sea turtles, with individual incidences of 

mortality reported from California, Texas, Florida, South Carolina, North Carolina, and New Jersey 

(Plotkin 1995). Although the cumulative impact of this mortality is unclear, it may be relatively small 

compared to fishing mortality. Although quantitative reports are available from a few power stations 

(Table F-1), high-quality data is available from only one source, the St. Lucie Nuclear Power Plant, at 

Hutchinson Island, Florida, where annual capture rates range from 350 to 1,000 turtles. Although 

estimated mortality rates due to entrainment are < 3 percent, approximately 85 percent of entrained 

organisms show evidence of injury as a result of entrainment (Norem 2005). As such, true mortality rates

from CWIS may be higher than reported, particularly for individuals who are recaptured repeatedly (37

percent of Green and 13 percent of Loggerhead sea turtles entrained between May and December 2000 

were recaptured individuals) (Norem 2005).

In addition to research sponsored by the National Science Foundation, federal and state governmental

spending on sea turtles under the ESA totaled $33.8 million in FY2008 (USFWS 2009). Moreover, the 

number of volunteer organizations dedicated to sea turtle recovery (Table F-2) provides further evidence 

of the high nonuse values placed upon the survival of these animals by the public. 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix F: Methods for T&E Species Benefits

July 8, 2014 F-2

Table F-1: Reported Numbers of Sea Turtle Entrainment Incidences

Facility(s) Species

Takes

Dates

Takes / yr

Source

Non-lethal Lethal Non-lethal Lethal

Crystal River, FL Kemp's Ridley, Loggerhead 40 5 1998 40 5 TEWG (2000)

Brunswick, NC Loggerhead, Kemp's Ridley, Green 50 11 2000 50 11 NMFS (2001)

Oyster Creek, NJ; Salem, NJ; 

and Hope, NJ

Loggerhead 40 8 1999 40 8

Kemp's Ridley 7 3 1999 7 3 NMFS (2001)

Green 8 2 1999 8 2

Salem, NJ Loggerhead, Kemp's Ridley, Green 23 2 1991 23 2 Eggers (2001)

Salem, NJ Loggerhead 18 8 1980-1988 2.25 1

Eggers (1989)

Salem, NJ Kemp's Ridley 6 6 1980-1988 0.75 0.75

St. Lucie, FL Loggerhead 6313 169 1976-2005 225.5 6 NMFS (2009)

San Diego, Edison Olive Ridley QR QR QR QR QR (NMFS and USFWS 

1998b)

San Diego, Encina, Edison Green QR QR QR QR QR (NMFS and USFWS 

1998a)

St. Lucie, FL Leatherback 20 1976-1998 0.95 Bresette et al (1998)

St. Lucie, FL Hawksbill 19 1976-1998 0.90 Bresette et al (1998)

St. Lucie, FL Green 2297 1976-1998 109.38 Ernest et al (1988)

St. Lucie, FL Kemp's Ridley 34 1976-1998 1.62 Bresette et al (1998)

All US Waters Loggerhead - 5-50 Annual 

Estimate - 5-50 Plotkin (1995)

Notes:

QR = qualitative resports only

“-“ = value not available
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix F: Methods for T&E Species Benefits

July 8, 2014 F-3

Table F-2: Subset of Nongovernmental Organizations Based in the United States Dedicated to 

Sea Turtle Research and Conservation

Name Group Type Web Address

Amelia Island Sea Turtle Watch, Inc. Volunteer www.ameliaislandseaturtlewatch.com/

Archie Carr Center for Sea Turtle Research Academic accstr.ufl.edu/

Bald Head Island Conservancy Volunteer www.bhic.org/STPP.shtml

California Turtle & Tortoise Club Volunteer www.tortoise.org/

Caribbean Conservation Corporation Nonprofit www.helpingseaturtles.org/

Chelonian Research Foundation Academic www.chelonian.org/

Clearwater Marine Aquarium Nonprofit/Volunteer www.seewinter.com/what-we-do/nesting

Coastal Research and Education Society of 

Long Island, Inc., New York State Sea 

Turtle Program

Nonprofit/Volunteer www.cresli.org/cresli/turtles/turtpage.html

Conservation International Sea Turtle 

Flagship Program Nonprofit www.conservation.org/discover/centers_programs/sea_turtles/Pages/seaturtles.aspx

Earthwatch Nonprofit/Ecotourism www.earthwatch.org

Gulf Coast Turtle and Tortoise Society Volunteer www.gctts.org/

Hawksbill Sea Turtle Recovery Project Government/Volunteer www.fpir.noaa.gov/PRD/prd_volunteer_opps.html

Malama na Honu Nonprofit/Volunteer malamanahonu.org/

Marine Turtle Specialist Group Academic www.iucn-mtsg.org/

Maryland Marine Mammal and Sea Turtle 

Stranding Network Government/Volunteer www.dnr.state.md.us/fisheries/oxford/research/fwh/strandingprogram.html

National Aquarium in Baltimore, Marine 

Animal Rescue Program Nonprofit/Volunteer www.aqua.org/oceanhealth_marp.html

National Save the Sea Turtle Foundation Nonprofit savetheseaturtle.org/

Network for Endangered Seaturtles Volunteer www.nestonline.org/

Ocean Conservancy Nonprofit www.oceanconservancy.org/

Riverhead Foundation for Marine Research 

and Preservation Nonprofit/Volunteer www.riverheadfoundation.org/index.asp

Sanibel-Captiva Conservation Foundation Nonprofit/Volunteer www.sccf.org/

Sea Turtle Restoration Project Nonprofit www.seaturtles.org

Share the Beach, Sea Turtle Volunteering 

Program Volunteer www.alabamaseaturtles.com/

The Leatherback Trust Nonprofit leatherback.org/

The Turtle Foundation Nonprofit www.turtle-foundation.org

Source: U.S. EPA analysis for this report

F.2 Application of Whitehead’s (1993) Benefit Transfer Approach for Estimating 

WTP for T&E Sea Turtle Species

EPA identified a study that used a stated preference valuation approach to estimate the total economic 

value (i.e. use and nonuse values) of a management program designed to reduce the risk of extinction for 

loggerhead sea turtles (Whitehead 1993). The mail survey asked North Carolina households whether they 

were willing to pay a bid amount for a management program which reduces the probability that 

loggerhead sea turtles would be extinct in 25 years. Within the model framework, the baseline extinction 

risk and change from the management program are expressed in terms of a supply probability. Supply 

probability reflects the probability that “the wildlife resource will continue to exist so it can be enjoyed by 

recreational users and nonusers (p.121)” (Whitehead 1993). 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix F: Methods for T&E Species Benefits

July 8, 2014 F-4

The household value is expressed as the option price, or WTP to pay under conditions of future supply 

and demand uncertainty. The option price is estimated by solving for the dollar amount which would 

make the respondent indifferent to utility with and without the management program. The function used 

to estimate the option price (Model B from Whitehead (1993)) is:

OP (1991$) = 1.272 [p2(r2-q2)] / 0.029 Equation F-1

Variable definitions for the parameters in the function are described in Table F-3. 

EPA used Whitehead (1993) to assess the range of benefits potentially resulting from the final rule and 

regulatory options considered. EPA reviewed available data sources and biological models to assess the 

potential impact of baseline losses and reductions on sea turtle supply probability (r2-q2). While analyses 

of sea turtle extinction risk have been conducted (e.g., Conant et al. 2009), EPA was unable to identify an 

existing model or analysis which could be readily used in conjunction with available mortality data to 

estimate the marginal impacts of CWIS on sea turtle extinction risk. 

Estimates from the literature suggest that IM&E is of relatively low importance compared to other 

human-induced mortality such as shrimp trawling and other fisheries (Plotkin 1995). However, Crouse et 

al. (1987) found that mortality at juvenile and subadult life stages can have a substantial effect on 

population growth, suggesting that small changes in survival at these age classes could have a measurable 

impact on extinction risk. As such, the marginal change in supply probability of loggerhead sea turtles 

due to the final rule and proposed options is unlikely to be lower than 0.01 (i.e., a 1 percent decrease in 

the probability of extinction over 25 years). 

EPA specified a marginal improvement of 0.01 within Whitehead’s (1993) modeling framework to bound 

household values for changes in extinction risk for loggerhead sea turtles as a consequence of the final 

rule. Although this assessment is not based on formal quantitative analysis of extinction risk, EPA intends 

it to illustrate the range of potential benefits associated with reductions in sea turtle losses. Using the 

author’s mean values for demand probability (p2) and supply probability without the management 

program (q2) (Table F-3), EPA calculated an annual household value of $0.37 (2011$). Estimates were 

converted to 2011 dollars using the consumer price index (USBLS 2011).
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix F: Methods for T&E Species Benefits

July 8, 2014 F-5

Table F-3: Variable Descriptions and Values used for EPA’s Benefits Transfer Application

Variable Description Value Used in EPA’s 

Application

OP Option Price - the amount a household would be willing to pay 

under conditions of supply and demand uncertainty.

Estimated by the model

p2

Demand Probability - for wildlife users, demand uncertainty 

occurs when it is indeterminate whether recreational use of the 

wildlife resource will be pursued because of uncertain travel 

costs, income, and tastes. For nonusers, demand uncertainty 

depends on uncertain tastes.

0.51

q2

a

Supply Probability without the Management Program -

probability that the resource will continue to exist in 25 years 

without implementation of the management program.

0.43

r2

Supply Probability with the Management Program - probability 

that the resource will continue to exist in 25 years with 

implementation of the management program.

0.44

(r2-q2)

b Marginal increase in supply probability resulting from the 

management program.

0.01

a The model results are linear for marginal improvements in supply probability.

b EPA notes that a marginal change in supply probability of 0.01 is substantially less than changes used by Whitehead (1993) for model 

estimation. Whitehead (1993) estimated an annual household willingness to pay value of $10.98 (1991$) for a mean increase in supply 

probability of 0.47 in 25 years.

Sources: Whitehead (1993), U.S. EPA analysis for this report
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix G: Consumer Surplus

July 8, 2014 G-1

Appendix G: Estimation of Price Changes for Consumer Surplus

G.1 Introduction

EPA considered estimating consumer surplus values associated with reductions in IM&E, but found that 

dockside prices would change too little to produce measurable shifts in consumer surplus. This Appendix 

presents the details of this analysis and the estimated price changes by region and species.

G.2 Methodology and Results

To properly estimate price changes, it is necessary to consider the contribution of the species to the 

overall market. Because individual demand functions incorporating substitutes are not available for most 

species, EPA estimated price changes in the following way. . The Agency estimated the total baseline 

harvest for relevant species (commercial species of similar types to those affected by IM&E) using 

National Marine Fisheries Service (NMFS) landings data from 2007 to 2011(NMFS 2012) in three 

categories: finfish, shrimp, and crabs.96, The totals for finfish were summed for the East Coast and Gulf, 

and for the West Coast, while totals for shrimp and crabs were summed across all coastal regions.97 EPA 

summed estimated harvest increases from the elimination of baseline IM&E according to the same 

species and regional categories. Next, EPA calculated the percentage change in harvest if baseline IM&E 

were to be eliminated, by dividing the total increase in harvest from elimination of baseline IM&E, by the 

total harvest. EPA then estimated the percentage change in price for each region and species by dividing 

the percentage change in harvest by the elasticity for the species group (finfish, shrimp, or crabs). 

This last step requires estimates of elasticities. The price elasticity of demand for fish measures the 

percentage change in demand in response to a percentage change in fish price. Thus, the inverse elasticity, 

or price flexibility, measures the percentage change in price for a given percentage change in quantity. 

EPA’s review of the economics literature identified several potentially relevant studies, including Asche, 

Bjorndal, and Gordon (2005); Capps and Lambrgets (1991); Cheng and Capps (1988); Tsoa, Schrank, and 

Roy (1982); Davis, Yen, and Hwan-Lin (2007); and Lin, Richards, and Terry (1988). 

Table G-1 presents the own-price elasticities identified in the literature review for those commercial 

species where IM&E was estimated. Because elasticities can vary by species, the Agency grouped the 

own-price elasticities found in the literature review into three categories: (1) saltwater fish, (2) shrimp, 

and (3) crabs. The median elasticities within each of these groups, presented in the fourth column of 

Table G-1, are the elasticities used in this analysis. Table G-1 shows that there is a substantial amount of 

variation in the elasticity estimates, so by selecting the median elasticity rather than taking an average, the 

influence of the more extreme estimates is reduced.98g

 

96 For example, offshore species such as tuna and swordfish, baitfish species, and shellfish were not included.

97 Harvests for Alaska and Hawaii were not included in the totals.

98 Only two studies were available for crabs, so EPA used the mean elasticity for crabs. The Agency did not distinguish 

between finfish elasticities for the East and West Coast, because some sources provide elasticities based on models that 

include both regions.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix G: Consumer Surplus

July 8, 2014 G-2

Table G-1: Own-Price Elasticity Estimates from Literature Review

Species 

Group Species Study Elasticity

Median Species 

Group Elasticity Study Notes

Saltwater Cod -0.54 -1.89 Cheng and Capps (1988)

Saltwater Cod -3.15 -1.89 Bell (1986) as cited in Asche, 

Bjorndal and Gordon (2005)

Saltwater Cod(Blocks) -3.16 -1.89

Mazany, Roy and Schrank (1996) as 

cited in Asche, Bjorndal and Gordon 

(2005)

Saltwater Cod(Fillets) -0.46 -1.89 Tsoa, Schrank and Roy (1982) Long run estimate.

Saltwater Cod(Fillets) -1.89 -1.89 Asche, Bjorndal and Gordon (2005)

Saltwater Flounder -1.63 -1.89

Mazany, Roy and Schrank (1996) as 

cited in Asche, Bjorndal and Gordon 

(2005)

Saltwater Flounder/Sole -0.45 -1.89 Cheng and Capps (1988)

Saltwater Flounder/Sole -1.04 -1.89 Tsoa, Schrank and Roy (1982) Long run estimate.

Saltwater Halibut -5.56 -1.89

Lin, Richards and Terry (1988) as 

cited in Asche, Bjorndal and Gordon 

(2005)

Saltwater Perch -0.70 -1.89 Cheng and Capps (1988)

Saltwater Perch -3.09 -1.89 Capps and Lambrgets (1991)

Saltwater Perch -0.60 -1.89 Tsoa, Schrank and Roy (1982) Long run estimate.

Saltwater Perch -215.00 -1.89 Bell (1986) as cited in Asche, 

Bjorndal and Gordon (2005)

Saltwater Rockfish -3.55 -1.89 Capps and Lambrgets (1991)

Saltwater Whitefish -5.24 -1.89 Capps and Lambrgets (1991)

Shrimp Shrimp -0.70 -0.63 Cheng and Capps (1988)

Shrimp Shrimp -1.08 -0.63 Davis, Yen and Hwan-Lin (2007) Low income estimate.

Shrimp Shrimp -0.30 -0.63 Davis, Yen and Hwan-Lin (2007) High income estimate.

Shrimp Shrimp -2.84 -0.63 Capps and Lambrgets (1991)

Shrimp Shrimp -0.63 -0.63 Doll (1972) as cited in Cheng and 

Capps (1988)

Shrimp Shrimp 0.28 -0.63 Cleary (1969) as cited in Cheng and 

Capps (1988)

Shrimp Shrimp -0.57 -0.63 Sun (1995) as cited in Asche, 

Bjorndal and Gordon (2005)

Crabs Crabs -0.77 -1.31 Cheng and Capps (1988)

Crabs Crabs -1.84 -1.31 Capps and Lambrgets (1991)

Table G-2 shows the results of the calculations of percentage changes in price. EPA applied these 

percentage changes to the baseline prices to develop estimates of prices for the increased harvests that 

would result from eliminating baseline IM&E. For example, the table shows that a 0.39 percent change in 

total harvest in California is predicted to lead to a 0.21 percent change in finfish prices. These prices 

changes translate into very small changes (generally one to two cents) in ex-vessel prices per pound for 

the species affected by IM&E. Tables G-3 to G-7 show the projected prices after eliminating baseline 

IM&E.

EPA did not include estimates of changes in consumer surplus for commercial species. Prices must 

change in order for consumer surplus to change. Most species of fish have numerous close substitutes. 

The literature suggests that when there are plentiful substitute fish products, lots of fishers, and a strong 

ex-vessel market, individual fishers are generally price takers. Although there are exceptions, fisheries 

economics studies often make these assumptions in analyzing regional effects from harvest changes (e.g., 

Herrmann 1996; Thunberg et al. 1995) and international markets (e.g., Clarke et al. 1992) . Consumer 
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix G: Consumer Surplus

July 8, 2014 G-3

surplus measures that have been estimated by NMFS for past environmental impact statements tend to be 

quite low. NMFS fisheries analyses incorporate price changes for large changes in regional or national 

harvest, such as stock rebuilding. However, for small changes in landings, such as those expected under 

the final rule, it is standard to assume that prices are fixed. 99

Table G-2: Estimated Average Percentage Change in Ex-Vessel Price by Region and 

Species Group from the Elimination of Baseline IM&E

Region Species 

Group

Increase in Harvest 

from Elimination of 

Baseline IM&Ea

(lbs)

Total Average 

Annual Harvesta

Percentage 

Change in 

Harvest

Elasticity

Percentage 

Change in 

Priceb

California Finfish 1,920,625 489,705,990 0.39% -1.89 -0.21%

East Coast 

and Gulf Finfish 12,548,060 265,617,830 4.72% -1.89 -2.50%

All Regions Crabs 1,373,553 258,973,619 0.53% -1.31 -0.40%

All Regions Shrimp 369,750 279,365,691 0.13% -0.63 -0.21%

a

Sum of total landings for all relevant species.

b

Percentage changes in price reflect the average across all species within the species group and region.

Sources: U.S. EPA analysis for this report, NMFS (2012a)

Table G-3: Estimated Price Changes for the California Region

Species

Average Annual 

Harvest 2007-

2011 (thousand 

lbs)

Price Per 

Pound 

(2011$)

Increase in Harvest 

from Elimination of 

Baseline IM&E 

(thousand lbs)a

Percentage 

Change in 

Price

New Price 

Per Pound 

(2011$)

American Shad 57.9 $1.07 0.0 -0.21% $1.07

Anchovies 13,637.3 $0.06 0.9 -0.21% $0.06

Cabezon 53.7 $5.89 76.1 -0.21% $5.88

California Halibut 495.5 $4.73 176.9 -0.21% $4.72

California Scorpionfish 7.9 $3.83 0.0 -0.21% $3.82

Commercial Crabs 1,386.3 $1.37 2.2 -0.40% $1.36

Commercial Shrimp 4,272.1 $1.40 0.0 -0.21% $1.39

Drums and Croakers 53.8 $0.56 6.9 -0.21% $0.55

Dungeness Crabs 15,495.5 $2.31 6.1 -0.40% $2.30

Flounders 381.3 $0.42 14.2 -0.21% $0.42

Other 47,410.9 $1.16 6.6 -0.21% $1.16

Rockfishes 2,741.3 $1.25 1,634.5 -0.21% $1.25

Sculpins 3.8 $3.53 3.7 -0.21% $3.52

Sea Basses 6.4 $2.76 0.0 -0.21% $2.75

Smelts 323.0 $0.41 0.2 -0.21% $0.41

Surfperches 17.5 $1.90 0.7 -0.21% $1.90

Total 86,344.2 . 1,928.9 . .

a Values of 0.0 for increased harvest from elimination of baseline IM&E may include increases less than 0.1 thousand lbs.

Sources: U.S. EPA analysis for this report, NMFS (2012c)

 

99 Personal communications with NMFS economists Cindy Thomson (2008), Eric Thunberg (2008), Steve Freese (2008), and 

Sabrina Lovell (2013).
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix G: Consumer Surplus

July 8, 2014 G-4

Table G-4: Estimated Price Changes for the North Atlantic Region

Species

Average Annual 

Harvest 2007-

2011 (thousand 

lbs)

Price Per 

Pound 

(2011$)

Increase in Harvest 

from Elimination of 

Baseline IM&E 

(thousand lbs)a

Percentage 

Change in 

Price

New Price 

Per Pound 

(2011$)

American Shad 30.3 $0.86 0.0 -2.50% $0.84

Atlantic Cod 18,152.5 $1.64 2.3 -2.50% $1.60

Atlantic Herring 168,023.6 $0.13 17.4 -2.50% $0.13

Atlantic Menhaden 7,346.1 $0.12 4.8 -2.50% $0.12

Bluefish 1,038.3 $0.57 0.0 -2.50% $0.56

Butterfish 784.5 $0.68 0.2 -2.50% $0.66

Commercial Crabs 16,083.4 $0.62 0.3 -2.50% $0.61

Flounders 16,026.1 $1.95 373.1 -2.50% $1.91

Mackerels 29,268.6 $0.17 2.2 -0.40% $0.16

Other 332,156.1 $0.42 3.8 -2.50% $0.41

Pollock 16,818.4 $0.64 0.0 -2.50% $0.62

Red Hake 926.7 $0.39 0.0 -2.50% $0.38

Sculpins 1.0 $0.11 3.2 -2.50% $0.11

Scup 5,362.2 $0.75 0.1 -2.50% $0.73

Searobin 53.3 $0.17 0.1 -2.50% $0.16

Silver Hake 11,108.1 $0.59 0.6 -2.50% $0.58

Skate Species 35,198.9 $0.22 0.5 -2.50% $0.21

Tautog 142.6 $2.43 4.7 -2.50% $2.37

Weakfish 11.1 $1.67 0.2 -2.50% $1.63

White Perch 4.8 $1.20 0.0 -2.50% $1.17

Total 658,536.4 . 413.6 . .

a Values of 0.0 for increased harvest from elimination of baseline IM&E may include increases less than 0.1 thousand lbs.

Sources: U.S. EPA analysis for this report, NMFS (2012c)
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix G: Consumer Surplus

July 8, 2014 G-5

Table G-5: Estimated Price Changes for the Mid-Atlantic Region

Species

Average Annual 

Harvest 2007-

2011 (thousand 

lbs)

Price Per 

Pound 

(2011$)

Increase in Harvest 

from Elimination of 

Baseline IM&E 

(thousand lbs)a

Percentage 

Change in 

Price

New Price 

Per Pound 

(2011$)

Alewife 343.8 $0.29 0.3 -2.50% $0.28

American Shad 57.5 $0.83 0.9 -2.50% $0.81

Atlantic Herring 6,658.6 $0.12 0.1 -2.50% $0.11

Atlantic Menhaden 452,353.9 $0.07 3,700.8 -2.50% $0.07

Black Drum 89.8 $2.20 0.2 -2.50% $2.14

Blue Crab 85,836.4 $1.11 640.9 -0.40% $1.10

Bluefish 2,996.3 $0.49 0.1 -2.50% $0.48

Butterfish 494.1 $0.84 0.0 -2.50% $0.82

Commercial Crabs 2,490.9 $0.54 0.3 -0.40% $0.54

Drums and Croakers 10,159.5 $0.64 960.3 -2.50% $0.63

Flounders 6,308.5 $2.08 6.1 -2.50% $2.03

Other 602,868.9 $0.31 820.1 -2.50% $0.30

Red Hake 360.0 $0.46 0.6 -2.50% $0.44

Scup 4,121.8 $0.81 0.0 -2.50% $0.79

Searobin 37.3 $0.21 0.0 -2.50% $0.21

Silver Hake 4,877.3 $0.64 0.1 -2.50% $0.63

Spot 3,478.4 $0.85 1,064.6 -2.50% $0.82

Striped Bass 5,609.6 $2.12 55.9 -2.50% $2.07

Striped Mullet 26.2 $0.45 0.2 -2.50% $0.44

Tautog 135.3 $2.98 0.0 -2.50% $2.90

Weakfish 267.4 $1.32 503.7 -2.50% $1.29

White Perch 1,588.5 $0.79 2.6 -2.50% $0.77

Total 1,191,159.9 . 7,757.9 . .

a Values of 0.0 for increased harvest from elimination of baseline IM&E may include increases less than 0.1 thousand lbs.

Sources: U.S. EPA analysis for this report, NMFS (2012c)

Table G-6: Estimated Price Changes for the South Atlantic Region

Species

Average Annual 

Harvest 2007-

2011 (thousand 

lbs)

Price Per 

Pound 

(2011$)

Increase in Harvest 

from Elimination of 

Baseline IM&E 

(thousand lbs)a

Percentage 

Change in 

Price

New Price 

Per Pound 

(2011$)

Atlantic Menhaden 1,828.1 $0.12 42.9 -2.50% $0.11

Blue Crab 39,786.5 $0.95 3.2 -0.40% $0.95

Commercial Crabs 583.7 $1.65 0.0 -0.40% $1.65

Drums and Croakers 6,347.6 $0.51 12.5 -2.50% $0.50

Other 94,277.5 $1.28 2.3 -2.50% $1.25

Spot 854.3 $0.70 16.1 -2.50% $0.68

Stone Crab 145.2 $4.01 0.4 -0.40% $3.99

Weakfish 144.6 $1.02 0.6 -2.50% $0.99

Total 143,967.5 . 78.1 . .

a Values of 0.0 for increased harvest from elimination of baseline IM&E may include increases less than 0.1 thousand lbs.

Sources: U.S. EPA analysis for this report, NMFS (2012c)
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix G: Consumer Surplus

July 8, 2014 G-6

Table G-7: Estimated Price Changes for the Gulf of Mexico Region

Species

Average Annual 

Harvest 2007-

2011 (thousand 

lbs)

Price Per 

Pound 

(2011$)

Increase in Harvest 

from Elimination of 

Baseline IM&E 

(thousand lbs)a

Percentage 

Change in 

Price

New Price 

Per Pound

(2011$)

Atlantic Menhaden 1,088,022.8 $0.07 1,173.2 -2.50% $0.07

Black Drum 4,621.9 $0.83 1,945.0 -2.50% $0.81

Blue Crab 53,055.9 $0.87 244.0 -0.40% $0.87

Drums and Croakers 111.8 $5.19 47.8 -2.50% $5.06

Leatherjacket 61.0 $1.51 107.1 -2.50% $1.47

Mackerels 3,898.1 $1.16 0.4 -2.50% $1.13

Other 1,384,185.9 $0.39 281.9 -2.50% $0.38

Pink Shrimp 6,973.0 $2.00 369.7 -0.21% $2.00

Sea Basses 179.4 $0.97 0.0 -2.50% $0.95

Sheepshead 1,393.0 $0.44 0.0 -2.50% $0.43

Spot 16.9 $0.51 46.3 -2.50% $0.50

Stone Crab 5,587.9 $4.13 474.4 -0.40% $4.11

Striped Mullet 10,800.3 $0.64 1,343.6 -2.50% $0.62

Total 2,558,908.0 . 6,033.5 . .

a Values of 0.0 for increased harvest from elimination of baseline IM&E may include increases less than 0.1 thousand lbs.

Sources: U.S. EPA analysis for this report, NMFS (2012c)
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix H: Details of Commercial Fishing Benefits

July 8, 2014 H-1

Appendix H: Details of Regional Commercial Fishing Benefits

Table H-1: Commercial Fishing Benefits from Eliminating or Reducing Baseline IM&E at Regulated Facilities in the 

California Region, by Species and Regulatory Option (2011$)

Species Name

Average 

Annual 

Harvest 

2007-2011

(1,000 lbs)

Price 

per 

Pound

Annual Increase in Commercial Harvest

(1,000 lbs)

Annual Benefits from Increase in 

Commercial Harvest

(2011$, 1,000s)

Proposal 

Option 4

Final 

Rule

Proposal 

Option 2 Baseline Proposal Option 4

Final 

Rule

Proposal 

Option 2 Baseline

American Shad 57.9 $1.07 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Anchovies 13,637.3 $0.06 0.5 0.5 0.6 0.9 0.0 0.0 0.0 0.0

Cabezon 53.7 $5.89 0.1 0.1 46.4 76.1 0.2 0.3 143.6 235.4

California Halibut 495.5 $4.73 0.2 0.2 107.9 176.9 0.6 0.7 297.2 487.1

California Scorpionfish 7.9 $3.83 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.1

Commercial Crabs 1,386.3 $1.37 0.0 0.0 1.3 2.2 0.0 0.0 1.4 2.2

Commercial Shrimp 4,272.1 $1.40 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Drums and Croakers 53.8 $0.56 0.7 0.8 4.3 6.9 0.2 0.2 1.0 1.6

Dungeness Crabs 15,495.5 $2.31 0.4 0.4 3.8 6.1 0.6 0.7 6.4 10.3

Flounders 381.3 $0.42 0.9 0.9 8.7 14.2 0.2 0.2 2.3 3.8

Other 47,410.9 $1.16 0.6 0.7 4.1 6.6 0.4 0.4 2.5 4.0

Rockfishes 2,741.3 $1.25 2.5 2.7 997.3 1,634.5 2.0 2.1 775.9 1,271.7

Sculpins 3.8 $3.53 0.1 0.1 2.2 3.7 0.2 0.2 5.1 8.3

Sea Basses 6.4 $2.76 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Smelts 323.0 $0.41 0.1 0.1 0.1 0.2 0.0 0.0 0.0 0.1

Surfperches 17.5 $1.90 0.4 0.5 0.5 0.7 0.3 0.3 0.4 0.5

Total (Undiscounted) 86,344.2 . 6.5 7.0 1,177.4 1,928.9 4.8 5.2 1,235.8 2,025.1

Total (3% Discount Rate) . . . . . . 3.0 3.3 650.8 1,698.4

Total (7% Discount Rate) . . . . . . 2.2 2.4 422.5 1,518.8

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix H: Details of Commercial Fishing Benefits

July 8, 2014 H-2

Table H-2: Commercial Fishing Benefits from Eliminating or Reducing Baseline IM&E at Regulated Facilities in the 

North Atlantic Region, by Species and Regulatory Option (2011$)

Species Name

Average 

Annual 

Harvest 

2007-2011

(1,000 lbs)

Price 

per 

Pound

Annual Increase in Commercial Harvest

(1,000 lbs)

Annual Benefits from Increase in 

Commercial Harvest

(2011$, 1,000s)

Proposal 

Option 4

Final 

Rule

Proposal 

Option 2 Baseline Proposal Option 4

Final 

Rule

Proposal 

Option 2 Baseline

American Shad 30.3 $0.86 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Atlantic Cod 18,152.5 $1.64 0.1 0.1 1.8 2.3 0.1 0.1 2.0 2.5

Atlantic Herring 168,023.6 $0.13 0.4 0.5 13.4 17.4 0.0 0.1 1.4 1.8

Atlantic Menhaden 7,346.1 $0.12 0.0 0.1 3.7 4.8 0.0 0.0 0.3 0.4

Bluefish 1,038.3 $0.57 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Butterfish 784.5 $0.68 0.1 0.1 0.2 0.2 0.0 0.0 0.1 0.1

Commercial Crabs 16,083.4 $0.62 0.2 0.2 0.3 0.3 0.1 0.1 0.1 0.1

Flounders 16,026.1 $1.95 1.2 4.6 286.0 373.1 1.5 5.7 355.5 463.8

Mackerels 29,268.6 $0.17 0.0 0.0 1.7 2.2 0.0 0.0 0.2 0.3

Other 332,156.1 $0.42 0.2 0.2 2.9 3.8 0.0 0.1 0.7 0.9

Pollock 16,818.4 $0.64 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Red Hake 926.7 $0.39 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Sculpins 1.0 $0.11 0.0 0.2 3.2 3.2 0.0 0.0 0.0 0.0

Scup 5,362.2 $0.75 0.0 0.0 0.1 0.1 0.0 0.0 0.1 0.1

Searobin 53.3 $0.17 0.0 0.0 0.1 0.1 0.0 0.0 0.0 0.0

Silver Hake 11,108.1 $0.59 0.1 0.1 0.5 0.6 0.0 0.1 0.2 0.2

Skate Species 35,198.9 $0.22 0.3 0.3 0.5 0.5 0.0 0.1 0.1 0.1

Tautog 142.6 $2.43 0.0 0.0 3.6 4.7 0.0 0.1 4.0 5.2

Weakfish 11.1 $1.67 0.0 0.0 0.2 0.2 0.0 0.0 0.2 0.3

White Perch 4.8 $1.20 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Total (Undiscounted) 658,536.4 . 2.7 6.7 318.0 413.6 1.9 6.2 364.7 475.8

Total (3% Discount Rate) . . . . . . 1.2 4.0 202.3 399.0

Total (7% Discount Rate) . . . . . . 0.9 3.0 135.9 356.8

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix H: Details of Commercial Fishing Benefits

July 8, 2014 H-3

Table H-3: Commercial Fishing Benefits from Eliminating or Reducing Baseline IM&E at Regulated Facilities in the MidAtlantic Region, by Species and Regulatory Option (2011$)

Species Name

Average 

Annual 

Harvest 

2007-2011

(1,000 lbs)

Price 

per 

Pound

Annual Increase in Commercial Harvest

(1,000 lbs)

Annual Benefits from Increase in 

Commercial Harvest

(2011$, 1,000s)

Proposal 

Option 4

Final 

Rule

Proposal 

Option 2

Baseline Proposal 

Option 4

Final 

Rule

Proposal 

Option 2 Baseline

Alewife 343.8 $0.29 0.2 0.2 0.3 0.3 0.1 0.1 0.1 0.1

American Shad 57.5 $0.83 0.0 0.0 0.8 0.9 0.0 0.0 0.6 0.6

Atlantic Herring 6,658.6 $0.12 0.1 0.1 0.1 0.1 0.0 0.0 0.0 0.0

Atlantic Menhaden 452,353.9 $0.07 2,503.2 2,674.8 3,398.8 3,700.8 126.4 135.0 171.6 186.8

Black Drum 89.8 $2.20 0.2 0.2 0.2 0.2 0.3 0.3 0.3 0.4

Blue Crab 85,836.4 $1.11 8.8 9.8 559.0 640.9 5.6 6.2 354.4 406.3

Bluefish 2,996.3 $0.49 0.1 0.1 0.1 0.1 0.0 0.0 0.0 0.0

Butterfish 494.1 $0.84 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Commercial Crabs 2,490.9 $0.54 0.2 0.2 0.3 0.3 0.1 0.1 0.1 0.1

Drums and Croakers 10,159.5 $0.64 14.1 15.7 837.7 960.3 6.7 7.5 398.8 457.1

Flounders 6,308.5 $2.08 2.6 2.8 5.5 6.1 3.6 3.8 7.8 8.6

Other 602,868.9 $0.31 98.1 105.3 721.4 820.1 21.9 23.5 160.7 182.7

Red Hake 360.0 $0.46 0.5 0.5 0.6 0.6 0.1 0.1 0.2 0.2

Scup 4,121.8 $0.81 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Searobin 37.3 $0.21 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Silver Hake 4,877.3 $0.64 0.1 0.1 0.1 0.1 0.0 0.0 0.0 0.0

Spot 3,478.4 $0.85 93.6 100.8 1,064.6 1,064.6 66.5 71.7 756.9 756.9

Striped Bass 5,609.6 $2.12 0.4 0.5 48.7 55.9 0.6 0.7 68.8 78.9

Striped Mullet 26.2 $0.45 0.2 0.2 0.2 0.2 0.1 0.1 0.1 0.1

Tautog 135.3 $2.98 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Weakfish 267.4 $1.32 150.4 160.9 449.3 503.7 150.9 161.4 450.8 505.3

White Perch 1,588.5 $0.79 0.2 0.3 2.2 2.6 0.2 0.2 1.5 1.7

Total (Undiscounted) 1,191,159.9 . 2,872.9 3,072.5 7,090.1 7,757.9 382.9 410.7 2,372.6 2,586.0

Total (3% Discount Rate) . . . . . . 242.1 259.7 1,206.2 2,168.8

Total (7% Discount Rate) . . . . . . 177.1 190.1 769.7 1,939.4

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix H: Details of Commercial Fishing Benefits

July 8, 2014 H-4

Table H-4: Commercial Fishing Benefits from Eliminating or Reducing Baseline IM&E at Regulated Facilities in the 

South Atlantic Region, by Species and Regulatory Option (2011$)

Species Name

Average 

Annual 

Harvest 

2007-2011

(1,000 lbs)

Price 

per 

Pound

Annual Increase in Commercial Harvest

(1,000 lbs)

Annual Benefits from Increase in 

Commercial Harvest

(2011$, 1,000s)

Proposal 

Option 4

Final 

Rule

Proposal 

Option 2 Baseline Proposal Option 4

Final 

Rule

Proposal 

Option 2 Baseline

Atlantic Menhaden 1,828.1 $0.12 25.7 27.5 42.2 42.9 2.2 2.4 3.7 3.8

Blue Crab 39,786.5 $0.95 2.2 2.3 3.2 3.2 1.2 1.3 1.7 1.7

Commercial Crabs 583.7 $1.65 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Drums and Croakers 6,347.6 $0.51 0.2 0.2 11.7 12.5 0.1 0.2 3.2 3.4

Other 94,277.5 $1.28 1.3 1.3 2.3 2.3 1.0 1.0 1.7 1.8

Spot 854.3 $0.70 7.0 7.5 15.6 16.1 3.4 3.8 7.6 7.9

Stone Crab 145.2 $4.01 0.3 0.3 0.4 0.4 0.6 0.7 0.9 1.0

Weakfish 144.6 $1.02 0.3 0.3 0.6 0.6 0.2 0.2 0.4 0.4

Total (Undiscounted) 143,967.5 . 36.9 39.6 76.0 78.1 8.7 9.7 19.3 19.9

Total (3% Discount Rate) . . . . . . 5.8 6.4 10.4 16.7

Total (7% Discount Rate) . . . . . . 4.4 4.9 7.0 14.9

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix H: Details of Commercial Fishing Benefits

July 8, 2014 H-5

Table H-5: Commercial Fishing Benefits from Eliminating or Reducing Baseline IM&E at Regulated Facilities in the Gulf 

of Mexico Region, by Species and Regulatory Option (2011$)

Species Name

Average 

Annual 

Harvest 

2007-2011

(1,000 lbs)

Price 

per 

Pound

Annual Increase in Commercial Harvest

(1,000 lbs)

Annual Benefits from Increase in 

Commercial Harvest

(2011$, 1,000s)

Proposal 

Option 4

Final 

Rule

Proposal 

Option 2

Baseline Proposal 

Option 4

Final 

Rule

Proposal 

Option 2 Baseline

Atlantic Menhaden 1,088,022.8 $0.07 841.3 873.2 1,053.6 1,173.2 44.7 46.3 55.9 62.3

Black Drum 4,621.9 $0.83 5.1 5.2 1,150.0 1,945.0 2.9 3.0 662.9 1,121.1

Blue Crab 53,055.9 $0.87 45.3 47.0 163.4 244.0 28.1 29.2 101.6 151.7

Drums and Croakers 111.8 $5.19 34.6 35.9 43.1 47.8 97.0 100.7 120.8 134.2

Leatherjacket 61.0 $1.51 74.3 77.2 95.1 107.1 0.0 0.0 0.0 0.0

Mackerels 3,898.1 $1.16 0.3 0.3 0.3 0.4 0.2 0.2 0.3 0.3

Other 1,384,185.9 $0.39 185.1 192.1 245.8 281.9 33.6 34.9 44.6 51.2

Pink Shrimp 6,973.0 $2.00 173.5 180.1 292.7 369.7 150.7 156.4 254.2 321.1

Sea Basses 179.4 $0.97 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Sheepshead 1,393.0 $0.44 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Spot 16.9 $0.51 27.8 28.9 39.3 46.3 7.7 7.9 10.8 12.7

Stone Crab 5,587.9 $4.13 117.2 121.6 330.2 474.4 344.9 358.0 972.0 1,396.2

Striped Mullet 10,800.3 $0.64 137.3 142.5 851.9 1,343.6 69.0 71.6 428.1 675.3

Total (Undiscounted) 2,558,908.0 . 1,641.8 1,704.0 4,265.5 6,033.5 778.9 808.3 2,651.3 3,926.1

Total (3% Discount Rate) . . . . . . 496.8 515.5 1,702.5 3,426.9

Total (7% Discount Rate) . . . . . . 365.2 378.9 1,255.7 3,160.8

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix H: Details of Commercial Fishing Benefits

July 8, 2014 H-6

Table H-6: Commercial Fishing Benefits from Eliminating or Reducing Baseline IM&E at Regulated Facilities in the 

Great Lakes Region, by Species and Regulatory Option (2011$)

Species Name

Average 

Annual 

Harvest 

2007-2011

(1,000 lbs)

Price 

per 

Pound

Annual Increase in Commercial Harvest

(1,000 lbs)

Annual Benefits from Increase in 

Commercial Harvest

(2011$, 1,000s)

Proposal 

Option 4

Final 

Rule

Proposal 

Option 2 Baseline Proposal Option 4

Final 

Rule

Proposal 

Option 2 Baseline

Bullhead 679.1 $0.40 17.9 19.7 22.8 23.5 2.1 2.3 2.6 2.7

Freshwater Drum 585.9 $0.18 73.8 81.4 203.3 209.1 3.9 4.3 10.8 11.2

Other 14,356.7 $1.03 320.0 352.2 451.4 481.3 95.8 105.5 135.2 144.1

Sculpins 14,356.7 $1.03 0.0 0.0 0.1 0.1 0.0 0.0 0.0 0.0

Smelts 380.5 $1.60 61.3 67.5 87.0 92.9 28.4 31.3 40.4 43.1

White Bass 523.6 $0.73 248.1 248.1 248.1 248.1 52.6 52.6 52.6 52.6

Whitefish 9,785.3 $0.99 59.4 65.4 74.5 76.4 17.1 18.8 21.4 22.0

Yellow Perch 1,543.6 $2.14 3.8 4.1 5.2 5.5 2.3 2.6 3.2 3.4

Total (Undiscounted) 42,211.3 . 784.2 838.5 1,092.4 1,136.9 202.2 217.3 266.2 279.0

Total (3% Discount Rate) . . . . . . 134.6 144.9 162.5 243.6

Total (7% Discount Rate) . . . . . . 101.9 109.8 116.2 224.6

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-1

Appendix I: Details of Regional Recreational Fishing Benefits

I.1 California Region

Table I-1: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under Proposal Option 4 in the California Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

California halibut 69.0 $5.35 $10.21 $19.49 0.0 0.8 1.5

Flounders 21.0 $5.35 $10.21 $19.49 0.0 0.2 0.5

Total (Flatfish) 90.0 $5.35 $10.21 $19.49 0.0 1.0 2.0

Striped bass 0.0 $4.40 $7.60 $13.01 0.0 0.0 0.0

Total (Small Game) 0.0 $4.40 $7.60 $13.01 0.0 0.0 0.0

Cabezon 10.0 $1.87 $3.09 $5.11 0.0 0.0 0.1

California scorpionfish 49.0 $1.87 $3.09 $5.11 0.1 0.2 0.3

Croakers 4,564.0 $1.87 $3.09 $5.11 8.5 14.1 23.4

Rockfish 618.0 $1.87 $3.09 $5.11 1.2 1.9 3.2

Sculpin 3,192.0 $1.87 $3.09 $5.11 5.9 9.8 16.3

Sea bass 276.0 $1.87 $3.09 $5.11 0.5 0.9 1.4

Smelts 16.0 $1.87 $3.09 $5.11 0.0 0.0 0.1

Sunfish 1.0 $1.87 $3.09 $5.11 0.0 0.0 0.0

Surfperch 25,654.0 $1.87 $3.09 $5.11 47.8 79.1 131.3

Total (Other Saltwater) 34,381.0 $1.87 $3.09 $5.11 64.0 106.0 176.0

Total (Unidentified) 949.0 $1.95 $3.25 $5.42 2.0 3.0 5.0

Total (Undiscounted) 35,420.0 . . . 67.0 110.0 183.0

Total (3% discount rate) . . . . 42.0 69.0 114.0

Total (7% discount rate) . . . . 30.0 50.0 83.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-2

Table I-2: Recreational Fishing Benefits from Reducing at Regulated Facilities under 

the Final Rule in the California Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

California halibut 74.0 $5.35 $10.21 $19.49 0.8 0.8 1.5

Flounders 23.0 $5.35 $10.21 $19.49 0.2 0.2 0.5

Total (Flatfish) 97.0 $5.35 $10.21 $19.49 1.0 1.0 2.0

Striped bass 0.0 $4.40 $7.60 $13.01 0.0 0.0 0.0

Total (Small Game) 0.0 $4.40 $7.60 $13.01 0.0 0.0 0.0

Cabezon 11.0 $1.87 $3.09 $5.11 0.0 0.0 0.1

California scorpionfish 53.0 $1.87 $3.09 $5.11 0.1 0.2 0.3

Croakers 4,917.0 $1.87 $3.09 $5.11 9.2 15.3 25.1

Rockfish 665.0 $1.87 $3.09 $5.11 1.2 2.1 3.4

Sculpin 3,439.0 $1.87 $3.09 $5.11 6.4 10.7 17.5

Sea bass 297.0 $1.87 $3.09 $5.11 0.6 0.9 1.5

Smelts 18.0 $1.87 $3.09 $5.11 0.0 0.1 0.1

Sunfish 1.0 $1.87 $3.09 $5.11 0.0 0.0 0.0

Surfperch 27,638.0 $1.87 $3.09 $5.11 51.5 85.8 141.0

Total (Other Saltwater) 37,040.0 $1.87 $3.09 $5.11 69.0 115.0 189.0

Total (Unidentified) 1,022.0 $1.95 $3.25 $5.42 2.0 3.0 6.0

Total (Undiscounted) 38,159.0 . . . 72.0 119.0 197.0

Total (3% discount rate) . . . . 45.0 74.0 123.0

Total (7% discount rate) . . . . 33.0 54.0 89.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-3

Table I-3: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under Proposal Option 2 in the California Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

California halibut 32,791.0 $5.35 $10.21 $19.49 175.9 334.8 638.9

Flounders 213.0 $5.35 $10.21 $19.49 1.1 2.2 4.1

Total (Flatfish) 33,004.0 $5.35 $10.21 $19.49 177.0 337.0 643.0

Striped bass 1,032.0 $4.40 $7.60 $13.01 5.0 8.0 13.0

Total (Small Game) 1,032.0 $4.40 $7.60 $13.01 5.0 8.0 13.0

Cabezon 6,110.0 $1.87 $3.09 $5.11 11.4 18.9 31.3

California scorpionfish 56.0 $1.87 $3.09 $5.11 0.1 0.2 0.3

Croakers 28,043.0 $1.87 $3.09 $5.11 52.5 86.8 143.4

Rockfish 243,212.0 $1.87 $3.09 $5.11 455.2 752.6 1,244.0

Sculpin 95,822.0 $1.87 $3.09 $5.11 179.3 296.5 490.1

Sea bass 437,354.0 $1.87 $3.09 $5.11 818.6 1,353.3 2,237.0

Smelts 20.0 $1.87 $3.09 $5.11 0.0 0.1 0.1

Sunfish 12.0 $1.87 $3.09 $5.11 0.0 0.0 0.1

Surfperch 29,282.0 $1.87 $3.09 $5.11 54.8 90.6 149.8

Total (Other Saltwater) 839,911.0 $1.87 $3.09 $5.11 1,572.0 2,599.0 4,296.0

Total (Unidentified) 3,227.0 $1.95 $3.25 $5.42 6.0 10.0 17.0

Total (Undiscounted) 877,174.0 . . . 1,759.0 2,954.0 4,970.0

Total (3% discount rate) . . . . 919.0 1,543.0 2,595.0

Total (7% discount rate) . . . . 592.0 994.0 1,673.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-4

Table I-4: Recreational Fishing Benefits from Eliminating Baseline IM&E at Regulated 

Facilities in the California Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

California halibut 53,746.0 $5.35 $10.21 $19.49 287.2 548.5 1,047.3

Flounders 345.0 $5.35 $10.21 $19.49 1.8 3.5 6.7

Total (Flatfish) 54,091.0 $5.35 $10.21 $19.49 289.0 552.0 1,054.0

Striped bass 1,692.0 $4.40 $7.60 $13.01 7.0 13.0 22.0

Total (Small Game) 1,692.0 $4.40 $7.60 $13.01 7.0 13.0 22.0

Cabezon 10,015.0 $1.87 $3.09 $5.11 18.7 31.0 51.2

California scorpionfish 82.0 $1.87 $3.09 $5.11 0.2 0.3 0.4

Croakers 45,086.0 $1.87 $3.09 $5.11 84.4 139.5 230.6

Rockfish 398,609.0 $1.87 $3.09 $5.11 745.9 1,233.4 2,038.6

Sculpin 156,471.0 $1.87 $3.09 $5.11 292.8 484.2 800.2

Sea bass 716,959.0 $1.87 $3.09 $5.11 1,341.5 2,218.5 3,666.7

Smelts 30.0 $1.87 $3.09 $5.11 0.1 0.1 0.2

Sunfish 19.0 $1.87 $3.09 $5.11 0.0 0.1 0.1

Surfperch 43,011.0 $1.87 $3.09 $5.11 80.5 133.1 220.0

Total (Other Saltwater) 1,370,282.0 $1.87 $3.09 $5.11 2,564.0 4,240.0 7,008.0

Total (Unidentified) 5,106.0 $1.95 $3.25 $5.42 10.0 17.0 28.0

Total (Undiscounted) 1,431,170.0 . . . 2,871.0 4,822.0 8,112.0

Total (3% discount rate) . . . . 2,408.0 4,044.0 6,803.0

Total (7% discount rate) . . . . 2,153.0 3,616.0 6,084.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-5

I.2 North Atlantic Region

Table I-5: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under Proposal Option 4 in the North Atlantic Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Winter flounder 765.0 $3.98 $6.24 $9.86 3.0 5.0 8.0

Total (flatfish) 765.0 $3.98 $6.24 $9.86 3.0 5.0 8.0

Atlantic mackerel 0.0 $2.23 $6.22 $17.53 0.0 0.0 0.0

Bluefish 1.0 $2.23 $6.22 $17.53 0.0 0.0 0.0

Striped bass 0.0 $2.23 $6.22 $17.53 0.0 0.0 0.0

Weakfish 0.0 $2.23 $6.22 $17.53 0.0 0.0 0.0

Total (small game) 1.0 $2.23 $6.22 $17.53 0.0 0.0 0.0

Atlantic Cod 37.0 $1.87 $3.12 $5.20 0.1 0.1 0.2

Cunner 18.0 $1.87 $3.12 $5.20 0.0 0.0 0.1

Pollock 1.0 $1.87 $3.12 $5.20 0.0 0.0 0.0

Sculpin 316.0 $1.87 $3.12 $5.20 0.7 0.7 1.4

Scup 8.0 $1.87 $3.12 $5.20 0.0 0.0 0.0

Searobin 41.0 $1.87 $3.12 $5.20 0.1 0.1 0.2

Tautog 15.0 $1.87 $3.12 $5.20 0.0 0.0 0.1

White Perch 0.0 $1.87 $3.12 $5.20 0.0 0.0 0.0

Total (other saltwater) 436.0 $1.87 $3.12 $5.20 1.0 1.0 2.0

Total (unidentified) 166.0 $1.88 $3.15 $5.26 0.0 1.0 1.0

Total (Undiscounted) 1,367.0 . . . 4.0 7.0 11.0

Total (3% discount rate) . . . . 3.0 4.0 7.0

Total (7% discount rate) . . . . 2.0 3.0 5.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-6

Table I-6: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under the Final Rule in the North Atlantic Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Winter flounder 3,471.0 $3.98 $6.24 $9.86 14.0 22.0 34.0

Total (flatfish) 3,471.0 $3.98 $6.24 $9.86 14.0 22.0 34.0

Atlantic mackerel 8.0 $2.23 $6.22 $17.53 0.0 0.0 0.0

Bluefish 1.0 $2.23 $6.22 $17.53 0.0 0.0 0.0

Striped bass 0.0 $2.23 $6.22 $17.53 0.0 0.0 0.0

Weakfish 0.0 $2.23 $6.22 $17.53 0.0 0.0 0.0

Total (small game) 9.0 $2.23 $6.22 $17.53 0.0 0.0 0.0

Atlantic Cod 50.0 $1.87 $3.12 $5.20 0.1 0.2 0.3

Cunner 941.0 $1.87 $3.12 $5.20 1.8 2.8 4.8

Pollock 1.0 $1.87 $3.12 $5.20 0.0 0.0 0.0

Sculpin 3,107.0 $1.87 $3.12 $5.20 5.8 9.4 15.9

Scup 9.0 $1.87 $3.12 $5.20 0.0 0.0 0.0

Searobin 51.0 $1.87 $3.12 $5.20 0.1 0.2 0.3

Tautog 139.0 $1.87 $3.12 $5.20 0.3 0.4 0.7

White Perch 0.0 $1.87 $3.12 $5.20 0.0 0.0 0.0

Total (other saltwater) 4,298.0 $1.87 $3.12 $5.20 8.0 13.0 22.0

Total (unidentified) 198.0 $1.88 $3.15 $5.26 0.0 1.0 1.0

Total (Undiscounted) 7,975.0 . . . 22.0 36.0 58.0

Total (3% discount rate) . . . . 14.0 23.0 36.0

Total (7% discount rate) . . . . 10.0 16.0 27.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-7

Table I-7: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under Proposal Option 2 in the North Atlantic Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Winter flounder 229,386.0 $3.98 $6.24 $9.86 914.0 1,430.0 2,261.0

Total (flatfish) 229,386.0 $3.98 $6.24 $9.86 914.0 1,430.0 2,261.0

Atlantic mackerel 666.0 $2.23 $6.22 $17.53 1.9 3.8 11.5

Bluefish 1.0 $2.23 $6.22 $17.53 0.0 0.0 0.0

Striped bass 0.0 $2.23 $6.22 $17.53 0.0 0.0 0.0

Weakfish 25.0 $2.23 $6.22 $17.53 0.1 0.1 0.4

Total (small game) 692.0 $2.23 $6.22 $17.53 2.0 4.0 12.0

Atlantic Cod 955.0 $1.87 $3.12 $5.20 1.8 3.0 5.0

Cunner 79,272.0 $1.87 $3.12 $5.20 148.2 247.3 412.3

Pollock 3.0 $1.87 $3.12 $5.20 0.0 0.0 0.0

Sculpin 238,602.0 $1.87 $3.12 $5.20 445.9 744.4 1,241.0

Scup 96.0 $1.87 $3.12 $5.20 0.2 0.3 0.5

Searobin 618.0 $1.87 $3.12 $5.20 1.2 1.9 3.2

Tautog 10,583.0 $1.87 $3.12 $5.20 19.8 33.0 55.0

White Perch 0.0 $1.87 $3.12 $5.20 0.0 0.0 0.0

Total (other saltwater) 330,130.0 $1.87 $3.12 $5.20 617.0 1,030.0 1,717.0

Total (unidentified) 2,098.0 $1.88 $3.15 $5.26 4.0 7.0 11.0

Total (Undiscounted) 562,305.0 . . . 1,537.0 2,471.0 4,001.0

Total (3% discount rate) . . . . 852.0 1,371.0 2,219.0

Total (7% discount rate) . . . . 573.0 921.0 1,491.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-8

Table I-8: Recreational Fishing Benefits from Eliminating Baseline IM&E at Regulated 

Facilities in the North Atlantic Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Winter flounder 299,352.0 $3.98 $6.24 $9.86 1,192.0 1,867.0 2,951.0

Total (flatfish) 299,352.0 $3.98 $6.24 $9.86 1,192.0 1,867.0 2,951.0

Atlantic mackerel 870.0 $2.23 $6.22 $17.53 1.9 5.8 15.4

Bluefish 1.0 $2.23 $6.22 $17.53 0.0 0.0 0.0

Striped bass 0.0 $2.23 $6.22 $17.53 0.0 0.0 0.0

Weakfish 32.0 $2.23 $6.22 $17.53 0.1 0.2 0.6

Total (small game) 903.0 $2.23 $6.22 $17.53 2.0 6.0 16.0

Atlantic Cod 1,235.0 $1.87 $3.12 $5.20 2.3 3.9 6.4

Cunner 103,533.0 $1.87 $3.12 $5.20 193.6 323.1 538.5

Pollock 4.0 $1.87 $3.12 $5.20 0.0 0.0 0.0

Sculpin 311,537.0 $1.87 $3.12 $5.20 582.5 972.1 1,620.4

Scup 123.0 $1.87 $3.12 $5.20 0.2 0.4 0.6

Searobin 794.0 $1.87 $3.12 $5.20 1.5 2.5 4.1

Tautog 13,817.0 $1.87 $3.12 $5.20 25.8 43.1 71.9

White Perch 0.0 $1.87 $3.12 $5.20 0.0 0.0 0.0

Total (other saltwater) 431,044.0 $1.87 $3.12 $5.20 806.0 1,345.0 2,242.0

Total (unidentified) 2,686.0 $1.88 $3.15 $5.26 5.0 8.0 14.0

Total (Undiscounted) 733,985.0 . . . 2,006.0 3,226.0 5,223.0

Total (3% discount rate) . . . . 1,682.0 2,705.0 4,380.0

Total (7% discount rate) . . . . 1,504.0 2,419.0 3,917.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-9

I.3 Mid-Atlantic Region

Table I-9: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under Proposal Option 4 in the Mid-Atlantic Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Summer Flounder 3,096.0 $3.92 $5.88 $8.92 12.4 17.8 27.6

Winter Flounder 386.0 $3.92 $5.88 $8.92 1.6 2.2 3.4

Total (Flatfish) 3,482.0 $3.92 $5.88 $8.92 14.0 20.0 31.0

Black Crappie 2.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Bluegill 9.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Brown bullhead 604.0 $0.55 $1.11 $2.20 0.2 0.7 1.2

Bullhead 6.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Channel catfish 1,686.0 $0.55 $1.11 $2.20 0.7 2.1 3.5

Crappie 1.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Menhaden 1.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Sunfish 129.0 $0.55 $1.11 $2.20 0.1 0.2 0.3

Total (Panfish) 2,438.0 $0.55 $1.11 $2.20 1.0 3.0 5.0

Bluefish 74.0 $2.37 $6.17 $16.23 0.2 0.5 1.2

Red drum 1,555.0 $2.37 $6.17 $16.23 3.7 9.6 25.2

Spotted seatrout 1,031.0 $2.37 $6.17 $16.23 2.4 6.4 16.7

Striped bass 773.0 $2.37 $6.17 $16.23 1.8 4.8 12.6

Weakfish 93,196.0 $2.37 $6.17 $16.23 220.9 575.8 1,513.3

Total (Small Game) 96,628.0 $2.37 $6.17 $16.23 229.0 597.0 1,569.0

Atlantic croaker 16,563.0 $1.94 $3.05 $4.82 32.1 50.6 79.8

Atlantic herring 33.0 $1.94 $3.05 $4.82 0.1 0.1 0.2

Black drum 149.0 $1.94 $3.05 $4.82 0.3 0.5 0.7

Cunner 0.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Scup 1.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Searobin 4.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Silver perch 1.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Smallmouth bass 34.0 $1.94 $3.05 $4.82 0.1 0.1 0.2

Spot 248,039.0 $1.94 $3.05 $4.82 481.1 757.9 1,194.5

Striped mullet 7.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Tautog 0.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

White perch 1,972.0 $1.94 $3.05 $4.82 3.8 6.0 9.5

Whitefish 248.0 $1.94 $3.05 $4.82 0.5 0.8 1.2

Total (Other Saltwater) 267,049.0 $1.94 $3.05 $4.82 518.0 816.0 1,286.0

Total (Unidentified) 58,327.0 $2.00 $3.39 $6.00 117.0 198.0 350.0

Total (Undiscounted) 427,924.0 . . . 878.0 1,633.0 3,241.0

Total (3% discount rate) . . . . 531.0 988.0 1,961.0

Total (7% discount rate) . . . . 376.0 700.0 1,389.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-10

Table I-10: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under the Final Rule in the Mid-Atlantic Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Summer Flounder 3,308.0 $3.92 $5.88 $8.92 13.3 19.5 29.3

Winter Flounder 414.0 $3.92 $5.88 $8.92 1.7 2.4 3.7

Total (Flatfish) 3,723.0 $3.92 $5.88 $8.92 15.0 22.0 33.0

Black Crappie 2.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Bluegill 10.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Brown bullhead 647.0 $0.55 $1.11 $2.20 0.2 0.7 1.5

Bullhead 7.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Channel catfish 1,801.0 $0.55 $1.11 $2.20 0.7 2.1 4.1

Crappie 1.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Menhaden 1.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Sunfish 138.0 $0.55 $1.11 $2.20 0.1 0.2 0.3

Total (Panfish) 2,607.0 $0.55 $1.11 $2.20 1.0 3.0 6.0

Bluefish 79.0 $2.37 $6.17 $16.23 0.2 0.5 1.3

Red drum 1,661.0 $2.37 $6.17 $16.23 3.9 10.3 27.0

Spotted seatrout 1,101.0 $2.37 $6.17 $16.23 2.6 6.8 17.9

Striped bass 897.0 $2.37 $6.17 $16.23 2.1 5.5 14.6

Weakfish 99,705.0 $2.37 $6.17 $16.23 236.1 615.9 1,618.3

Total (Small Game) 103,444.0 $2.37 $6.17 $16.23 245.0 639.0 1,679.0

Atlantic croaker 18,458.0 $1.94 $3.05 $4.82 35.8 56.3 88.9

Atlantic herring 35.0 $1.94 $3.05 $4.82 0.1 0.1 0.2

Black drum 159.0 $1.94 $3.05 $4.82 0.3 0.5 0.8

Cunner 0.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Scup 1.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Searobin 4.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Silver perch 1.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Smallmouth bass 36.0 $1.94 $3.05 $4.82 0.1 0.1 0.2

Spot 267,172.0 $1.94 $3.05 $4.82 518.1 815.6 1,286.5

Striped mullet 8.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Tautog 0.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

White perch 2,119.0 $1.94 $3.05 $4.82 4.1 6.5 10.2

Whitefish 265.0 $1.94 $3.05 $4.82 0.5 0.8 1.3

Total (Other Saltwater) 288,258.0 $1.94 $3.05 $4.82 559.0 880.0 1,388.0

Total (Unidentified) 62,808.0 $2.00 $3.39 $6.00 126.0 213.0 377.0

Total (Undiscounted) 460,839.0 . . . 945.0 1,757.0 3,483.0

Total (3% discount rate) . . . . 572.0 1,063.0 2,108.0

Total (7% discount rate) . . . . 405.0 753.0 1,493.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-11

Table I-11: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under Proposal Option 2 in the Mid-Atlantic Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Summer Flounder 3,781.0 $3.92 $5.88 $8.92 14.9 22.3 33.8

Winter Flounder 2,823.0 $3.92 $5.88 $8.92 11.1 16.7 25.2

Total (Flatfish) 6,604.0 $3.92 $5.88 $8.92 26.0 39.0 59.0

Black Crappie 2.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Bluegill 11.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Brown bullhead 2,281.0 $0.55 $1.11 $2.20 1.4 2.7 5.0

Bullhead 8.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Channel catfish 2,059.0 $0.55 $1.11 $2.20 1.2 2.4 4.5

Crappie 1.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Menhaden 530.0 $0.55 $1.11 $2.20 0.3 0.6 1.2

Sunfish 157.0 $0.55 $1.11 $2.20 0.1 0.2 0.3

Total (Panfish) 5,049.0 $0.55 $1.11 $2.20 3.0 6.0 11.0

Bluefish 90.0 $2.37 $6.17 $16.23 0.2 0.6 1.5

Red drum 1,899.0 $2.37 $6.17 $16.23 4.5 11.7 30.8

Spotted seatrout 1,259.0 $2.37 $6.17 $16.23 3.0 7.8 20.4

Striped bass 91,823.0 $2.37 $6.17 $16.23 217.3 566.9 1,490.6

Weakfish 278,408.0 $2.37 $6.17 $16.23 659.0 1,719.0 4,519.6

Total (Small Game) 373,479.0 $2.37 $6.17 $16.23 884.0 2,306.0 6,063.0

Atlantic croaker 983,158.0 $1.94 $3.05 $4.82 1,906.3 3,003.0 4,733.8

Atlantic herring 40.0 $1.94 $3.05 $4.82 0.1 0.1 0.2

Black drum 182.0 $1.94 $3.05 $4.82 0.4 0.6 0.9

Cunner 0.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Scup 1.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Searobin 5.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Silver perch 1.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Smallmouth bass 41.0 $1.94 $3.05 $4.82 0.1 0.1 0.2

Spot 3,026,406.0 $1.94 $3.05 $4.82 5,868.1 9,243.9 14,571.9

Striped mullet 9.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Tautog 0.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

White perch 18,793.0 $1.94 $3.05 $4.82 36.4 57.4 90.5

Whitefish 303.0 $1.94 $3.05 $4.82 0.6 0.9 1.5

Total (Other Saltwater) 4,028,939.0 $1.94 $3.05 $4.82 7,812.0 12,306.0 19,399.0

Total (Unidentified) 689,524.0 $2.00 $3.39 $6.00 1,378.0 2,340.0 4,138.0

Total (Undiscounted) 5,103,595.0 . . . 10,102.0 16,996.0 29,670.0

Total (3% discount rate) . . . . 5,132.0 8,634.0 15,072.0

Total (7% discount rate) . . . . 3,273.0 5,506.0 9,612.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-12

Table I-12: Recreational Fishing Benefits from Eliminating Baseline IM&E at Regulated 

Facilities in the Mid-Atlantic Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Summer Flounder 4,092.0 $3.92 $5.88 $8.92 16.3 24.1 36.4

Winter Flounder 3,209.0 $3.92 $5.88 $8.92 12.7 18.9 28.6

Total (Flatfish) 7,301.0 $3.92 $5.88 $8.92 29.0 43.0 65.0

Black Crappie 3.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Bluegill 12.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Brown bullhead 2,569.0 $0.55 $1.11 $2.20 1.4 2.8 5.5

Bullhead 8.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Channel catfish 2,228.0 $0.55 $1.11 $2.20 1.2 2.4 4.8

Crappie 1.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Menhaden 609.0 $0.55 $1.11 $2.20 0.3 0.7 1.3

Sunfish 170.0 $0.55 $1.11 $2.20 0.1 0.2 0.4

Total (Panfish) 5,600.0 $0.55 $1.11 $2.20 3.0 6.0 12.0

Bluefish 97.0 $2.37 $6.17 $16.23 0.2 0.6 1.6

Red drum 2,055.0 $2.37 $6.17 $16.23 4.9 12.7 33.4

Spotted seatrout 1,362.0 $2.37 $6.17 $16.23 3.2 8.4 22.1

Striped bass 105,323.0 $2.37 $6.17 $16.23 249.2 650.3 1,709.8

Weakfish 312,082.0 $2.37 $6.17 $16.23 738.5 1,927.0 5,066.2

Total (Small Game) 420,920.0 $2.37 $6.17 $16.23 996.0 2,599.0 6,833.0

Atlantic croaker 1,127,044.0 $1.94 $3.05 $4.82 2,185.2 3,442.4 5,426.8

Atlantic herring 44.0 $1.94 $3.05 $4.82 0.1 0.1 0.2

Black drum 197.0 $1.94 $3.05 $4.82 0.4 0.6 0.9

Cunner 0.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Scup 1.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Searobin 6.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Silver perch 1.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Smallmouth bass 44.0 $1.94 $3.05 $4.82 0.1 0.1 0.2

Spot 3,453,578.0 $1.94 $3.05 $4.82 6,696.1 10,548.3 16,629.1

Striped mullet 9.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

Tautog 0.0 $1.94 $3.05 $4.82 0.0 0.0 0.0

White perch 21,411.0 $1.94 $3.05 $4.82 41.5 65.4 103.1

Whitefish 328.0 $1.94 $3.05 $4.82 0.6 1.0 1.6

Total (Other Saltwater) 4,602,664.0 $1.94 $3.05 $4.82 8,924.0 14,058.0 22,162.0

Total (Unidentified) 786,704.0 $2.00 $3.39 $6.00 1,573.0 2,669.0 4,721.0

Total (Undiscounted) 5,823,189.0 . . . 11,524.0 19,375.0 33,793.0

Total (3% discount rate) . . . . 9,665.0 16,249.0 28,341.0

Total (7% discount rate) . . . . 8,643.0 14,531.0 25,343.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-13

I.4 South Atlantic Region

Table I-13: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under Proposal Option 4 in the South Atlantic Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Flounders 402.0 $4.05 $5.87 $8.66 2.0 2.0 3.0

Total (Flatfish) 402.0 $4.05 $5.87 $8.66 2.0 2.0 3.0

Spotted seatrout 0.0 $2.84 $5.99 $12.59 0.0 0.0 0.0

Weakfish 183.0 $2.84 $5.99 $12.59 1.0 1.0 2.0

Total (Small Game) 183.0 $2.84 $5.99 $12.59 1.0 1.0 2.0

Croakers 1,440.0 $2.24 $2.98 $3.95 3.3 4.2 5.7

Pinfish 0.0 $2.24 $2.98 $3.95 0.0 0.0 0.0

Silver perch 39.0 $2.24 $2.98 $3.95 0.1 0.1 0.2

Spot 10,409.0 $2.24 $2.98 $3.95 23.6 30.6 41.2

Total (Other Saltwater) 11,888.0 $2.24 $2.98 $3.95 27.0 35.0 47.0

Total (Unidentified) 510.0 $2.25 $2.99 $3.99 1.0 2.0 2.0

Total (Undiscounted) 12,983.0 . . . 30.0 40.0 55.0

Total (3% discount rate) . . . . 18.0 24.0 33.0

Total (7% discount rate) . . . . 13.0 17.0 23.0

Source: U.S. EPA analysis for this report.

Table I-14: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under the Final Rule (IM Everywhere) in the South Atlantic Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Flounders 430.0 $4.05 $5.87 $8.66 2.0 3.0 4.0

Total (Flatfish) 430.0 $4.05 $5.87 $8.66 2.0 3.0 4.0

Spotted seatrout 84.0 $2.84 $5.99 $12.59 0.3 0.6 1.2

Weakfish 201.0 $2.84 $5.99 $12.59 0.7 1.4 2.8

Total (Small Game) 284.0 $2.84 $5.99 $12.59 1.0 2.0 4.0

Croakers 5,705.0 $2.24 $2.98 $3.95 12.8 17.0 22.6

Pinfish 67.0 $2.24 $2.98 $3.95 0.1 0.2 0.3

Silver perch 42.0 $2.24 $2.98 $3.95 0.1 0.1 0.2

Spot 11,607.0 $2.24 $2.98 $3.95 26.0 34.6 46.0

Total (Other Saltwater) 17,421.0 $2.24 $2.98 $3.95 39.0 52.0 69.0

Total (Unidentified) 589.0 $2.25 $2.99 $3.99 1.0 2.0 2.0

Total (Undiscounted) 18,725.0 . . . 43.0 58.0 78.0

Total (3% discount rate) . . . . 26.0 35.0 47.0

Total (7% discount rate) . . . . 18.0 24.0 33.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-14

Table I-15: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under Proposal Option 2 in the South Atlantic Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Flounders 587.0 $4.05 $5.87 $8.66 2.0 3.0 5.0

Total (Flatfish) 587.0 $4.05 $5.87 $8.66 2.0 3.0 5.0

Spotted seatrout 1,501.0 $2.84 $5.99 $12.59 4.1 8.9 18.7

Weakfish 347.0 $2.84 $5.99 $12.59 0.9 2.1 4.3

Total (Small Game) 1,848.0 $2.84 $5.99 $12.59 5.0 11.0 23.0

Croakers 76,510.0 $2.24 $2.98 $3.95 171.9 228.0 302.2

Pinfish 1,200.0 $2.24 $2.98 $3.95 2.7 3.6 4.7

Silver perch 58.0 $2.24 $2.98 $3.95 0.1 0.2 0.2

Spot 23,237.0 $2.24 $2.98 $3.95 52.2 69.2 91.8

Total (Other Saltwater) 101,006.0 $2.24 $2.98 $3.95 227.0 301.0 399.0

Total (Unidentified) 1,502.0 $2.25 $2.99 $3.99 3.0 4.0 6.0

Total (Undiscounted) 104,943.0 . . . 238.0 320.0 433.0

Total (3% discount rate) . . . . 129.0 173.0 234.0

Total (7% discount rate) . . . . 86.0 115.0 156.0

Source: U.S. EPA analysis for this report.

Table I-16: Recreational Fishing Benefits from Eliminating Baseline IM&E at Regulated 

Facilities in the South Atlantic Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Flounders 593.0 $4.05 $5.87 $8.66 2.0 3.0 5.0

Total (Flatfish) 593.0 $4.05 $5.87 $8.66 2.0 3.0 5.0

Spotted seatrout 1,604.0 $2.84 $5.99 $12.59 4.9 9.8 20.5

Weakfish 355.0 $2.84 $5.99 $12.59 1.1 2.2 4.5

Total (Small Game) 1,960.0 $2.84 $5.99 $12.59 6.0 12.0 25.0

Croakers 81,677.0 $2.24 $2.98 $3.95 183.3 243.6 323.0

Pinfish 1,283.0 $2.24 $2.98 $3.95 2.9 3.8 5.1

Silver perch 58.0 $2.24 $2.98 $3.95 0.1 0.2 0.2

Spot 23,943.0 $2.24 $2.98 $3.95 53.7 71.4 94.7

Total (Other Saltwater) 106,961.0 $2.24 $2.98 $3.95 240.0 319.0 423.0

Total (Unidentified) 1,562.0 $2.25 $2.99 $3.99 4.0 5.0 6.0

Total (Undiscounted) 111,075.0 . . . 251.0 338.0 459.0

Total (3% discount rate) . . . . 211.0 284.0 385.0

Total (7% discount rate) . . . . 189.0 254.0 344.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-15

I.5 Gulf of Mexico Region

Table I-17: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under Proposal Option 4 in the Gulf of Mexico Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Mackerels 994.0 $3.00 $5.89 $11.55 3.0 5.9 11.5

Red drum 19,500.0 $3.00 $5.89 $11.55 58.6 114.9 225.2

Spotted seatrout 394,780.0 $3.00 $5.89 $11.55 1,185.5 2,325.3 4,558.4

Total (Small Game) 415,274.0 $3.00 $5.89 $11.55 1,247.0 2,446.0 4,795.0

Atlantic croaker 153,811.0 $2.23 $2.91 $3.78 343.5 446.7 581.4

Black drum 4,185.0 $2.23 $2.91 $3.78 9.3 12.2 15.8

Pinfish 6,006.0 $2.23 $2.91 $3.78 13.4 17.4 22.7

Sea bass 103.0 $2.23 $2.91 $3.78 0.2 0.3 0.4

Searobin 73,120.0 $2.23 $2.91 $3.78 163.3 212.4 276.4

Sheepshead 1.0 $2.23 $2.91 $3.78 0.0 0.0 0.0

Silver perch 67.0 $2.23 $2.91 $3.78 0.1 0.2 0.3

Spot 21,098.0 $2.23 $2.91 $3.78 47.1 61.3 79.8

Striped mullet 5,350.0 $2.23 $2.91 $3.78 11.9 15.5 20.2

Total (Other Saltwater) 263,742.0 $2.23 $2.91 $3.78 589.0 766.0 997.0

Total (Unidentified) 70,129.0 $2.47 $3.83 $6.18 173.0 269.0 434.0

Total (Undiscounted) 749,144.0 . . . 2,009.0 3,481.0 6,225.0

Total (3% discount rate) . . . . 1,260.0 2,183.0 3,904.0

Total (7% discount rate) . . . . 914.0 1,583.0 2,831.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-16

Table I-18: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under the Final Rule in the Gulf of Mexico Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Mackerels 1,032.0 $3.00 $5.89 $11.55 3.1 6.1 11.9

Red drum 20,239.0 $3.00 $5.89 $11.55 60.8 119.2 233.7

Spotted seatrout 409,748.0 $3.00 $5.89 $11.55 1,230.1 2,413.7 4,731.4

Total (Small Game) 431,019.0 $3.00 $5.89 $11.55 1,294.0 2,539.0 4,977.0

Atlantic croaker 159,643.0 $2.23 $2.91 $3.78 356.4 463.7 603.1

Black drum 4,295.0 $2.23 $2.91 $3.78 9.6 12.5 16.2

Pinfish 6,226.0 $2.23 $2.91 $3.78 13.9 18.1 23.5

Sea bass 107.0 $2.23 $2.91 $3.78 0.2 0.3 0.4

Searobin 75,892.0 $2.23 $2.91 $3.78 169.4 220.5 286.7

Sheepshead 1.0 $2.23 $2.91 $3.78 0.0 0.0 0.0

Silver perch 70.0 $2.23 $2.91 $3.78 0.2 0.2 0.3

Spot 21,898.0 $2.23 $2.91 $3.78 48.9 63.6 82.7

Striped mullet 5,552.0 $2.23 $2.91 $3.78 12.4 16.1 21.0

Total (Other Saltwater) 273,683.0 $2.23 $2.91 $3.78 611.0 795.0 1,034.0

Total (Unidentified) 72,787.0 $2.47 $3.83 $6.18 180.0 279.0 450.0

Total (Undiscounted) 777,488.0 . . . 2,085.0 3,613.0 6,461.0

Total (3% discount rate) . . . . 1,308.0 2,265.0 4,051.0

Total (7% discount rate) . . . . 948.0 1,643.0 2,938.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-17

Table I-19: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under Proposal Option 2 in the Gulf of Mexico Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Mackerels 1,237.0 $3.00 $5.89 $11.55 3.7 7.3 14.3

Red drum 26,734.0 $3.00 $5.89 $11.55 80.3 157.5 308.7

Spotted seatrout 524,007.0 $3.00 $5.89 $11.55 1,573.0 3,086.3 6,050.1

Total (Small Game) 551,978.0 $3.00 $5.89 $11.55 1,657.0 3,251.0 6,373.0

Atlantic croaker 191,598.0 $2.23 $2.91 $3.78 428.1 556.8 723.9

Black drum 941,083.0 $2.23 $2.91 $3.78 2,102.6 2,734.6 3,555.8

Pinfish 160,133.0 $2.23 $2.91 $3.78 357.8 465.3 605.0

Sea bass 128.0 $2.23 $2.91 $3.78 0.3 0.4 0.5

Searobin 111,200.0 $2.23 $2.91 $3.78 248.4 323.1 420.2

Sheepshead 28.0 $2.23 $2.91 $3.78 0.1 0.1 0.1

Silver perch 933.0 $2.23 $2.91 $3.78 2.1 2.7 3.5

Spot 29,782.0 $2.23 $2.91 $3.78 66.5 86.5 112.5

Striped mullet 33,192.0 $2.23 $2.91 $3.78 74.2 96.5 125.4

Total (Other Saltwater) 1,468,076.0 $2.23 $2.91 $3.78 3,280.0 4,266.0 5,547.0

Total (Unidentified) 117,807.0 $2.47 $3.83 $6.18 291.0 451.0 729.0

Total (Undiscounted) 2,137,861.0 . . . 5,228.0 7,968.0 12,649.0

Total (3% discount rate) . . . . 3,357.0 5,116.0 8,122.0

Total (7% discount rate) . . . . 2,476.0 3,774.0 5,991.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-18

Table I-20: Recreational Fishing Benefits from Eliminating Baseline IM&E at Regulated 

Facilities in the Gulf of Mexico Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Mackerels 1,374.0 $3.00 $5.89 $11.55 4.1 8.1 15.9

Red drum 31,114.0 $3.00 $5.89 $11.55 93.4 183.2 359.3

Spotted seatrout 600,729.0 $3.00 $5.89 $11.55 1,803.5 3,537.7 6,936.8

Total (Small Game) 633,217.0 $3.00 $5.89 $11.55 1,901.0 3,729.0 7,312.0

Atlantic croaker 212,766.0 $2.23 $2.91 $3.78 475.3 618.2 804.0

Black drum 1,591,629.0 $2.23 $2.91 $3.78 3,555.8 4,624.9 6,014.2

Pinfish 266,978.0 $2.23 $2.91 $3.78 596.5 775.8 1,008.8

Sea bass 142.0 $2.23 $2.91 $3.78 0.3 0.4 0.5

Searobin 135,234.0 $2.23 $2.91 $3.78 302.1 393.0 511.0

Sheepshead 47.0 $2.23 $2.91 $3.78 0.1 0.1 0.2

Silver perch 1,532.0 $2.23 $2.91 $3.78 3.4 4.5 5.8

Spot 35,116.0 $2.23 $2.91 $3.78 78.5 102.0 132.7

Striped mullet 52,351.0 $2.23 $2.91 $3.78 117.0 152.1 197.8

Total (Other Saltwater) 2,295,795.0 $2.23 $2.91 $3.78 5,129.0 6,671.0 8,675.0

Total (Unidentified) 148,605.0 $2.47 $3.83 $6.18 367.0 569.0 919.0

Total (Undiscounted) 3,077,617.0 . . . 7,397.0 10,969.0 16,905.0

Total (3% discount rate) . . . . 6,457.0 9,575.0 14,756.0

Total (7% discount rate) . . . . 5,955.0 8,831.0 13,610.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-19

I.6 Great Lakes Region

Table I-21: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under Proposal Option 4 in the Great Lakes Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Smallmouth bass 2,314.0 $4.63 $8.95 $17.38 16.7 8,870.0 17,216.0

White bass 632,325.0 $4.63 $8.95 $17.38 4,567.3 8,870.0 17,216.0

Total (Bass) 634,639.0 $4.63 $8.95 $17.38 4,584.0 8,870.0 17,216.0

Whitefish 40,464.0 $6.39 $9.87 $15.34 332.0 514.0 799.0

Total (Other Trout) 40,464.0 $6.39 $9.87 $15.34 332.0 514.0 799.0

Black crappie 107.0 $0.73 $1.39 $2.61 0.3 0.5 1.0

Bluegill 1,010.0 $0.73 $1.39 $2.61 2.6 4.9 9.2

Channel catfish 12,995.0 $0.73 $1.39 $2.61 32.9 62.7 117.9

Crappie 321.0 $0.73 $1.39 $2.61 0.8 1.5 2.9

Rainbow smelt 4,722.0 $0.73 $1.39 $2.61 12.0 22.8 42.8

Sculpin 197.0 $0.73 $1.39 $2.61 0.5 1.0 1.8

Smelts 8,453.0 $0.73 $1.39 $2.61 21.4 40.8 76.7

Sunfish 676.0 $0.73 $1.39 $2.61 1.7 3.3 6.1

Yellow perch 29,926.0 $0.73 $1.39 $2.61 75.8 144.5 271.6

Total (Panfish) 58,408.0 $0.73 $1.39 $2.61 148.0 282.0 530.0

Salmon 609.0 $8.53 $13.88 $22.61 8.0 14.0 22.0

Total (Salmon) 609.0 $8.53 $13.88 $22.61 8.0 14.0 22.0

Northern Pike 3.0 $2.28 $4.30 $8.16 0.0 0.0 0.0

Walleye 18,082.0 $2.28 $4.30 $8.16 264.0 497.9 945.8

Total (Walleye/Pike) 18,085.0 $2.28 $4.30 $8.16 264.0 498.0 946.0

Total (Unidentified) 579,751.0 $3.49 $6.51 $12.25 3,032.0 5,661.0 10,661.0

Total (Undiscounted) 1,331,956.0 . . . 8,370.0 15,838.0 30,174.0

Total (3% discount rate) . . . . 7,306.0 13,825.0 26,338.0

Total (7% discount rate) . . . . 6,738.0 12,751.0 24,292.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-20

Table I-22: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under the Final Rule in the Great Lakes Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Smallmouth bass 2,546.0 $4.63 $8.95 $17.38 11.8 6,257.0 12,144.0

White bass 696,159.0 $4.63 $8.95 $17.38 3,222.2 6,257.0 12,144.0

Total (Bass) 698,705.0 $4.63 $8.95 $17.38 3,234.0 6,257.0 12,144.0

Whitefish 44,532.0 $6.39 $9.87 $15.34 284.0 440.0 683.0

Total (Other Trout) 44,532.0 $6.39 $9.87 $15.34 284.0 440.0 683.0

Black crappie 118.0 $0.73 $1.39 $2.61 0.1 0.2 0.3

Bluegill 1,112.0 $0.73 $1.39 $2.61 0.8 1.6 2.9

Channel catfish 14,302.0 $0.73 $1.39 $2.61 10.4 20.0 37.3

Crappie 362.0 $0.73 $1.39 $2.61 0.3 0.5 0.9

Rainbow smelt 5,347.0 $0.73 $1.39 $2.61 3.9 7.5 13.9

Sculpin 224.0 $0.73 $1.39 $2.61 0.2 0.3 0.6

Smelts 9,303.0 $0.73 $1.39 $2.61 6.8 13.0 24.2

Sunfish 766.0 $0.73 $1.39 $2.61 0.6 1.1 2.0

Yellow perch 32,942.0 $0.73 $1.39 $2.61 24.0 46.0 85.8

Total (Panfish) 64,475.0 $0.73 $1.39 $2.61 47.0 90.0 168.0

Salmon 671.0 $8.53 $13.88 $22.61 6.0 9.0 15.0

Total (Salmon) 671.0 $8.53 $13.88 $22.61 6.0 9.0 15.0

Northern Pike 3.0 $2.28 $4.30 $8.16 0.0 0.0 0.0

Walleye 20,041.0 $2.28 $4.30 $8.16 46.0 86.0 164.0

Total (Walleye/Pike) 20,044.0 $2.28 $4.30 $8.16 46.0 86.0 164.0

Total (Unidentified) 638,223.0 $3.49 $6.51 $12.25 2,224.0 4,153.0 7,821.0

Total (Undiscounted) 1,466,650.0 . . . 5,841.0 11,034.0 20,995.0

Total (3% discount rate) . . . . 3,793.0 7,166.0 13,636.0

Total (7% discount rate) . . . . 2,820.0 5,328.0 10,138.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-21

Table I-23: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under Proposal Option 2 in the Great Lakes Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Smallmouth bass 2,902.0 $4.63 $8.95 $17.38 13.4 8,250.0 16,013.0

White bass 918,361.0 $4.63 $8.95 $17.38 4,250.6 8,250.0 16,013.0

Total (Bass) 921,263.0 $4.63 $8.95 $17.38 4,264.0 8,250.0 16,013.0

Whitefish 50,757.0 $6.39 $9.87 $15.34 324.0 501.0 779.0

Total (Other Trout) 50,757.0 $6.39 $9.87 $15.34 324.0 501.0 779.0

Black crappie 135.0 $0.73 $1.39 $2.61 0.1 0.2 0.4

Bluegill 1,334.0 $0.73 $1.39 $2.61 1.0 1.8 3.5

Channel catfish 16,552.0 $0.73 $1.39 $2.61 12.1 22.9 43.3

Crappie 4,373.0 $0.73 $1.39 $2.61 3.2 6.1 11.4

Rainbow smelt 76,779.0 $0.73 $1.39 $2.61 56.2 106.4 200.7

Sculpin 3,489.0 $0.73 $1.39 $2.61 2.6 4.8 9.1

Smelts 10,636.0 $0.73 $1.39 $2.61 7.8 14.7 27.8

Sunfish 10,788.0 $0.73 $1.39 $2.61 7.9 15.0 28.2

Yellow perch 41,148.0 $0.73 $1.39 $2.61 30.1 57.0 107.6

Total (Panfish) 165,234.0 $0.73 $1.39 $2.61 121.0 229.0 432.0

Salmon 910.0 $8.53 $13.88 $22.61 8.0 13.0 21.0

Total (Salmon) 910.0 $8.53 $13.88 $22.61 8.0 13.0 21.0

Northern Pike 5.0 $2.28 $4.30 $8.16 0.0 0.0 0.0

Walleye 89,320.0 $2.28 $4.30 $8.16 204.0 384.0 729.0

Total (Walleye/Pike) 89,325.0 $2.28 $4.30 $8.16 204.0 384.0 729.0

Total (Unidentified) 816,530.0 $3.49 $6.51 $12.25 2,846.0 5,313.0 10,006.0

Total (Undiscounted) 2,044,018.0 . . . 7,766.0 14,690.0 27,978.0

Total (3% discount rate) . . . . 4,717.0 8,922.0 16,993.0

Total (7% discount rate) . . . . 3,359.0 6,354.0 12,102.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-22

Table I-24: Recreational Fishing Benefits from Eliminating Baseline IM&E at Regulated 

Facilities in the Great Lakes Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Smallmouth bass 2,976.0 $4.63 $8.95 $17.38 13.8 8,870.0 17,216.0

White bass 987,522.0 $4.63 $8.95 $17.38 4,570.2 8,870.0 17,216.0

Total (Bass) 990,498.0 $4.63 $8.95 $17.38 4,584.0 8,870.0 17,216.0

Whitefish 52,059.0 $6.39 $9.87 $15.34 332.0 514.0 799.0

Total (Other Trout) 52,059.0 $6.39 $9.87 $15.34 332.0 514.0 799.0

Black crappie 138.0 $0.73 $1.39 $2.61 0.1 0.2 0.4

Bluegill 1,393.0 $0.73 $1.39 $2.61 1.0 1.9 3.6

Channel catfish 17,068.0 $0.73 $1.39 $2.61 12.4 23.7 44.6

Crappie 5,932.0 $0.73 $1.39 $2.61 4.3 8.2 15.5

Rainbow smelt 104,556.0 $0.73 $1.39 $2.61 76.2 145.3 273.0

Sculpin 4,759.0 $0.73 $1.39 $2.61 3.5 6.6 12.4

Smelts 10,921.0 $0.73 $1.39 $2.61 8.0 15.2 28.5

Sunfish 14,686.0 $0.73 $1.39 $2.61 10.7 20.4 38.3

Yellow perch 43,518.0 $0.73 $1.39 $2.61 31.7 60.5 113.6

Total (Panfish) 202,970.0 $0.73 $1.39 $2.61 148.0 282.0 530.0

Salmon 986.0 $8.53 $13.88 $22.61 8.0 14.0 22.0

Total (Salmon) 986.0 $8.53 $13.88 $22.61 8.0 14.0 22.0

Northern Pike 5.0 $2.28 $4.30 $8.16 0.0 0.0 0.0

Walleye 115,883.0 $2.28 $4.30 $8.16 264.0 498.0 946.0

Total (Walleye/Pike) 115,889.0 $2.28 $4.30 $8.16 264.0 498.0 946.0

Total (Unidentified) 870,008.0 $3.49 $6.51 $12.25 3,032.0 5,661.0 10,661.0

Total (Undiscounted) 2,232,409.0 . . . 8,370.0 15,838.0 30,174.0

Total (3% discount rate) . . . . 7,306.0 13,825.0 26,338.0

Total (7% discount rate) . . . . 6,738.0 12,751.0 24,292.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-23

I.7 Inland Region

Table I-25: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under Proposal Option 4 in the Inland Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Smallmouth bass 8,142.0 $4.48 $9.43 $19.96 36.5 76.8 162.5

White bass 537,712.0 $4.48 $9.43 $19.96 2,410.5 5,070.2 10,731.5

Total (Bass) 545,853.0 $4.48 $9.43 $19.96 2,447.0 5,147.0 10,894.0

Whitefish 1,355.0 $1.59 $2.96 $5.53 2.0 4.0 7.0

Total (Other Trout) 1,355.0 $1.59 $2.96 $5.53 2.0 4.0 7.0

Black bullhead 20,797.0 $0.55 $1.11 $2.20 11.5 23.0 45.8

Black crappie 11,790.0 $0.55 $1.11 $2.20 6.5 13.0 25.9

Bluegill 276,051.0 $0.55 $1.11 $2.20 152.5 305.3 607.4

Brown bullhead 3,953.0 $0.55 $1.11 $2.20 2.2 4.4 8.7

Bullhead 2,682.0 $0.55 $1.11 $2.20 1.5 3.0 5.9

Channel catfish 188,768.0 $0.55 $1.11 $2.20 104.3 208.8 415.4

Crappie 20,410.0 $0.55 $1.11 $2.20 11.3 22.6 44.9

Menhaden 213.0 $0.55 $1.11 $2.20 0.1 0.2 0.5

Rainbow smelt 2,565.0 $0.55 $1.11 $2.20 1.4 2.8 5.6

Smelts 1.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Sunfish 161,748.0 $0.55 $1.11 $2.20 89.4 178.9 355.9

White Perch 3,360.0 $0.55 $1.11 $2.20 1.9 3.7 7.4

Yellow perch 247,054.0 $0.55 $1.11 $2.20 136.5 273.3 543.6

Total (Panfish) 939,390.0 $0.55 $1.11 $2.20 519.0 1,039.0 2,067.0

Salmon 4.0 $8.53 $13.88 $22.61 0.0 0.0 0.0

Total (Salmon) 4.0 $8.53 $13.88 $22.61 0.0 0.0 0.0

American shad 2,122.0 $1.68 $5.61 $18.90 3.6 11.8 40.2

Striped bass 13,681.0 $1.68 $5.61 $18.90 23.1 76.3 258.9

Sturgeon 154.0 $1.68 $5.61 $18.90 0.3 0.9 2.9

Total (Small Game) 15,957.0 $1.68 $5.61 $18.90 27.0 89.0 302.0

Northern pike 25.0 $2.07 $4.29 $8.92 0.1 0.1 0.2

Sauger 6,672.0 $2.07 $4.29 $8.92 13.9 28.5 59.6

Walleye 11,116.0 $2.07 $4.29 $8.92 23.1 47.4 99.2

Total (Walleye/Pike) 17,812.0 $2.07 $4.29 $8.92 37.0 76.0 159.0

Total (Unidentified) 2,049,682.0 $1.13 $2.33 $4.81 2,325.0 4,784.0 9,865.0

Total (Undiscounted) 3,570,053.0 . . . 5,357.0 11,140.0 23,295.0

Total (3% discount rate) . . . . 3,503.0 7,284.0 15,231.0

Total (7% discount rate) . . . . 2,616.0 5,440.0 11,375.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-24

Table I-26: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under the Final Rule in the Inland Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Smallmouth bass 9,392.0 $4.48 $9.43 $19.96 42.1 88.6 187.4

White bass 560,751.0 $4.48 $9.43 $19.96 2,513.9 5,287.5 11,191.6

Total (Bass) 570,143.0 $4.48 $9.43 $19.96 2,556.0 5,376.0 11,379.0

Whitefish 1,401.0 $1.59 $2.96 $5.53 2.0 4.0 8.0

Total (Other Trout) 1,401.0 $1.59 $2.96 $5.53 2.0 4.0 8.0

Black bullhead 21,509.0 $0.55 $1.11 $2.20 11.9 23.8 47.3

Black crappie 12,888.0 $0.55 $1.11 $2.20 7.1 14.2 28.4

Bluegill 285,614.0 $0.55 $1.11 $2.20 158.0 315.7 628.4

Brown bullhead 4,136.0 $0.55 $1.11 $2.20 2.3 4.6 9.1

Bullhead 2,781.0 $0.55 $1.11 $2.20 1.5 3.1 6.1

Channel catfish 196,096.0 $0.55 $1.11 $2.20 108.5 216.7 431.5

Crappie 23,044.0 $0.55 $1.11 $2.20 12.7 25.5 50.7

Menhaden 220.0 $0.55 $1.11 $2.20 0.1 0.2 0.5

Rainbow smelt 2,683.0 $0.55 $1.11 $2.20 1.5 3.0 5.9

Smelts 1.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Sunfish 174,183.0 $0.55 $1.11 $2.20 96.3 192.5 383.2

White Perch 3,477.0 $0.55 $1.11 $2.20 1.9 3.8 7.7

Yellow perch 256,905.0 $0.55 $1.11 $2.20 142.1 283.9 565.2

Total (Panfish) 983,538.0 $0.55 $1.11 $2.20 544.0 1,087.0 2,164.0

Salmon 4.0 $8.53 $13.88 $22.61 0.0 0.0 0.0

Total (Salmon) 4.0 $8.53 $13.88 $22.61 0.0 0.0 0.0

American shad 2,194.0 $1.68 $5.61 $18.90 3.7 12.4 41.5

Striped bass 14,146.0 $1.68 $5.61 $18.90 24.0 79.7 267.4

Sturgeon 167.0 $1.68 $5.61 $18.90 0.3 0.9 3.2

Total (Small Game) 16,507.0 $1.68 $5.61 $18.90 28.0 93.0 312.0

Northern pike 26.0 $2.07 $4.29 $8.92 0.1 0.1 0.2

Sauger 7,825.0 $2.07 $4.29 $8.92 16.1 33.8 69.8

Walleye 12,546.0 $2.07 $4.29 $8.92 25.8 54.1 112.0

Total (Walleye/Pike) 20,396.0 $2.07 $4.29 $8.92 42.0 88.0 182.0

Total (Unidentified) 2,139,619.0 $1.13 $2.33 $4.81 2,427.0 4,994.0 10,298.0

Total (Undiscounted) 3,731,608.0 . . . 5,599.0 11,642.0 24,343.0

Total (3% discount rate) . . . . 3,661.0 7,613.0 15,918.0

Total (7% discount rate) . . . . 2,735.0 5,686.0 11,889.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-25

Table I-27: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities 

under Proposal Option 2 in the Inland Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Smallmouth bass 141,379.0 $4.48 $9.43 $19.96 633.7 633.7 633.7

White bass 1,286,644.0 $4.48 $9.43 $19.96 5,767.3 12,132.1 5,767.3

Total (Bass) 1,428,023.0 $4.48 $9.43 $19.96 6,401.0 6,401.0 6,401.0

Whitefish 1,688.0 $1.59 $2.96 $5.53 3.0 3.0 3.0

Total (Other Trout) 1,688.0 $1.59 $2.96 $5.53 3.0 3.0 3.0

Black bullhead 25,487.0 $0.55 $1.11 $2.20 14.1 14.1 14.1

Black crappie 108,409.0 $0.55 $1.11 $2.20 59.9 59.9 59.9

Bluegill 354,207.0 $0.55 $1.11 $2.20 195.8 195.8 195.8

Brown bullhead 11,390.0 $0.55 $1.11 $2.20 6.3 6.3 6.3

Bullhead 4,307.0 $0.55 $1.11 $2.20 2.4 2.4 2.4

Channel catfish 348,937.0 $0.55 $1.11 $2.20 192.9 192.9 192.9

Crappie 286,830.0 $0.55 $1.11 $2.20 158.6 158.6 158.6

Menhaden 254.0 $0.55 $1.11 $2.20 0.1 0.1 0.1

Rainbow smelt 7,121.0 $0.55 $1.11 $2.20 3.9 3.9 3.9

Smelts 1.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Sunfish 1,131,661.0 $0.55 $1.11 $2.20 625.6 625.6 625.6

White Perch 4,461.0 $0.55 $1.11 $2.20 2.5 2.5 2.5

Yellow perch 491,893.0 $0.55 $1.11 $2.20 271.9 271.9 271.9

Total (Panfish) 2,774,958.0 $0.55 $1.11 $2.20 1,534.0 1,534.0 1,534.0

Salmon 4.0 $8.53 $13.88 $22.61 0.0 0.0 0.0

Total (Salmon) 4.0 $8.53 $13.88 $22.61 0.0 0.0 0.0

American shad 2,531.0 $1.68 $5.61 $18.90 4.3 14.2 47.9

Striped bass 16,318.0 $1.68 $5.61 $18.90 27.5 91.5 308.7

Sturgeon 1,294.0 $1.68 $5.61 $18.90 2.2 7.3 24.5

Total (Small Game) 20,143.0 $1.68 $5.61 $18.90 34.0 113.0 381.0

Northern pike 29.0 $2.07 $4.29 $8.92 0.1 0.1 0.3

Sauger 133,280.0 $2.07 $4.29 $8.92 276.3 572.0 1,188.8

Walleye 155,606.0 $2.07 $4.29 $8.92 322.6 667.8 1,387.9

Total (Walleye/Pike) 288,916.0 $2.07 $4.29 $8.92 599.0 1,240.0 2,577.0

Total (Unidentified) 5,190,603.0 $1.13 $2.33 $4.81 5,889.0 12,116.0 24,981.0

Total (Undiscounted) 9,704,334.0 . . . 14,459.0 30,007.0 62,557.0

Total (3% discount rate) . . . . 8,290.0 17,204.0 35,865.0

Total (7% discount rate) . . . . 5,726.0 11,883.0 24,773.0

Source: U.S. EPA analysis for this report.
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix I: Details of Recreational Fishing Benefits

July 8, 2014 I-26

Table I-28: Recreational Fishing Benefits from Eliminating Baseline IM&E at Regulated 

Facilities in the Inland Region, by Species (2011$)

Species

Annual 

Increase in 

Recreational 

Harvest

(harvestable 

adult fish)

Value per Fish

Annual Benefits from Increase 

in Recreational Harvest

(2011$, thousands)

5

th Mean 95th 5th Mean 95th

Smallmouth bass 180,693.0 $4.48 $9.43 $19.96 810.0 1,703.8 3,606.4

White bass 1,567,058.0 $4.48 $9.43 $19.96 7,025.0 14,776.2 31,276.6

Total (Bass) 1,747,751.0 $4.48 $9.43 $19.96 7,835.0 16,480.0 34,883.0

Whitefish 1,947.0 $1.59 $2.96 $5.53 3.0 6.0 11.0

Total (Other Trout) 1,947.0 $1.59 $2.96 $5.53 3.0 6.0 11.0

Black bullhead 29,349.0 $0.55 $1.11 $2.20 16.2 32.4 64.6

Black crappie 137,629.0 $0.55 $1.11 $2.20 76.1 152.2 302.9

Bluegill 410,040.0 $0.55 $1.11 $2.20 226.7 453.3 902.4

Brown bullhead 14,007.0 $0.55 $1.11 $2.20 7.7 15.5 30.8

Bullhead 5,099.0 $0.55 $1.11 $2.20 2.8 5.6 11.2

Channel catfish 417,819.0 $0.55 $1.11 $2.20 231.0 461.9 919.5

Crappie 365,941.0 $0.55 $1.11 $2.20 202.3 404.6 805.4

Menhaden 291.0 $0.55 $1.11 $2.20 0.2 0.3 0.6

Rainbow smelt 8,741.0 $0.55 $1.11 $2.20 4.8 9.7 19.2

Smelts 1.0 $0.55 $1.11 $2.20 0.0 0.0 0.0

Sunfish 1,430,230.0 $0.55 $1.11 $2.20 790.8 1,581.1 3,147.6

White Perch 5,183.0 $0.55 $1.11 $2.20 2.9 5.7 11.4

Yellow perch 592,175.0 $0.55 $1.11 $2.20 327.4 654.7 1,303.3

Total (Panfish) 3,416,505.0 $0.55 $1.11 $2.20 1,889.0 3,777.0 7,519.0

Salmon 5.0 $8.53 $13.88 $22.61 0.0 0.0 0.0

Total (Salmon) 5.0 $8.53 $13.88 $22.61 0.0 0.0 0.0

American shad 2,905.0 $1.68 $5.61 $18.90 4.9 16.2 54.9

Striped bass 18,729.0 $1.68 $5.61 $18.90 31.4 104.6 354.1

Sturgeon 1,640.0 $1.68 $5.61 $18.90 2.7 9.2 31.0

Total (Small Game) 23,274.0 $1.68 $5.61 $18.90 39.0 130.0 440.0

Northern pike 34.0 $2.07 $4.29 $8.92 0.1 0.1 0.3

Sauger 170,509.0 $2.07 $4.29 $8.92 353.4 731.8 1,520.9

Walleye 198,517.0 $2.07 $4.29 $8.92 411.5 852.0 1,770.8

Total (Walleye/Pike) 369,060.0 $2.07 $4.29 $8.92 765.0 1,584.0 3,292.0

Total (Unidentified) 6,341,808.0 $1.13 $2.33 $4.81 7,195.0 14,803.0 30,522.0

Total (Undiscounted) 11,900,351.0 . . . 17,725.0 36,781.0 76,666.0

Total (3% discount rate) . . . . 15,471.0 32,105.0 66,919.0

Total (7% discount rate) . . . . 14,270.0 29,611.0 61,722.0

Source: U.S. EPA analysis for this report.