United States

Environmental Protection

Agency

Environmental and Economic Benefits

Analysis for Proposed Section 316(b)

Existing Facilities Rule

EPA 821-R-11-002

March 28, 2011

March 28, 2011 i

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Contents

1 INTRODUCTION .......................................................................................................................................... 1-1

1.1 SUMMARY OF THE PROPOSED REGULATION AND OTHER EVALUATED OPTIONS ...............................1-2

1.2 STUDY DESIGN..................................................................................................................................1-2

1.2.1 Coastal Regions.......................................................................................................................... 1-3

1.2.2 Great Lakes Region .................................................................................................................... 1-3

1.2.3 Inland Region ............................................................................................................................. 1-4

1.3 ORGANIZATION OF THE DOCUMENT..................................................................................................1-4

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.......................................................................................................................... 2-7

2.3 CWIS IMPACTS TO AQUATIC ECOSYSTEMS ......................................................................................2-8

2.3.1 Losses of Fish from I&E Mortality............................................................................................. 2-9

2.3.2 I&E Mortality 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 CWISS ...................................................................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........................................................................................ 2-16

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 CWISs on Major Rivers ............................................................... 2-17

2.5.2 Implications of Clustered Facilities for Cumulative Impacts ................................................... 2-18

2.6 CASE STUDIES OF FACILITY I&E MORTALITY IMPACTS..................................................................2-19

2.6.1 Bay Shore Power Station.......................................................................................................... 2-19

2.6.2 Indian Point Nuclear Power Plant ........................................................................................... 2-20

2.6.3 Indian River Power Plant ......................................................................................................... 2-21

2.7 CONCLUSIONS .................................................................................................................................2-22

3 ASSESSMENT OF IMPINGEMENT AND ENTRAINMENT MORTALITY ........................................ 3-1

3.1 INTRODUCTION..................................................................................................................................3-1

3.2 METHODS..........................................................................................................................................3-1

3.2.1 Objectives of I&E Mortality Analysis......................................................................................... 3-1

3.2.2 I&E Mortality Loss Metrics........................................................................................................ 3-2

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

3.2.4 Rationale for EPA’s Approach for Valuation of I&E mortality losses ....................................... 3-3

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

3.3 I&E MORTALITY LOSSES BY REGION ...............................................................................................3-6

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

3.3.2 North Atlantic Region................................................................................................................. 3-7
March 28, 2011 ii

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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

3.3.4 South Atlantic Region ............................................................................................................... 3-10

3.3.5 Gulf of Mexico .......................................................................................................................... 3-11

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 ASSOCIATED WITH I&E MORTALITY

REDUCTION ............................................................................................................................................... 4-20

4.1 ECONOMIC BENEFIT CATEGORIES APPLICABLE TO THE REGULATORY OPTIONS FOR IN-SCOPE

FACILITIES ......................................................................................................................................4-20

4.2 MARKET AND NONMARKET DIRECT AND INDIRECT USE BENEFITS FROM REDUCED I&E

MORTALITY ....................................................................................................................................4-23

4.2.1 Commercial Fisheries............................................................................................................... 4-23

4.2.2 Recreational Fisheries.............................................................................................................. 4-24

4.2.3 Subsistence Fishers................................................................................................................... 4-24

4.2.4 Benefits from Improved Protection to T&E Species ................................................................. 4-25

4.3 NONUSE BENEFITS FROM REDUCED I&E MORTALITY ....................................................................4-25

5 IMPACTS AND BENEFITS ON THREATENED AND ENDANGERED SPECIES.............................. 5-1

5.1 INTRODUCTION..................................................................................................................................5-1

5.2 T&E SPECIES AFFECTED BY CWISS .................................................................................................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............................................................. 5-5

5.2.4 Summary of Overlap Between Cooling Water Intake Structures and T&E Species ................... 5-7

5.2.5 Species with Documented I&E Mortality ................................................................................... 5-8

5.3 SOCIETAL VALUES FOR PRESERVATION OF T&E SPECIES AFFECTED BY I&E MORTALITY ..............5-8

5.4 ASSESSMENT OF BENEFITS TO T&E SPECIES...................................................................................5-10

5.4.1 Economic Valuation Methods................................................................................................... 5-10

5.4.2 Case Studies.............................................................................................................................. 5-11

5.4.3 Limitations and Uncertainties .................................................................................................. 5-17

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...........................................................6-9

6.2.1 California ................................................................................................................................. 6-11

6.2.2 North Atlantic ........................................................................................................................... 6-12

6.2.3 Mid-Atlantic.............................................................................................................................. 6-12

6.2.4 South Atlantic ........................................................................................................................... 6-13

6.2.5 Gulf of Mexico .......................................................................................................................... 6-14

6.2.6 The Great Lakes........................................................................................................................ 6-15

6.3 LIMITATIONS AND UNCERTAINTIES.................................................................................................6-16
March 28, 2011 iii

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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................................................................................. 7-5

7.2.3 Sensitivity Analysis Based on the Krinsky and Robb (1986) Approach...................................... 7-6

7.3 BENEFITS ESTIMATES FOR RECREATIONAL FISHING BY REGION.......................................................7-7

7.3.1 California ................................................................................................................................... 7-7

7.3.2 North Atlantic Region................................................................................................................. 7-8

7.3.3 Mid-Atlantic Region ................................................................................................................... 7-9

7.3.4 South Atlantic Region ............................................................................................................... 7-10

7.3.5 Gulf of Mexico .......................................................................................................................... 7-10

7.3.6 Great Lakes Region .................................................................................................................. 7-11

7.3.7 Inland Region ........................................................................................................................... 7-12

7.4 LIMITATIONS AND UNCERTAINTIES.................................................................................................7-13

7.4.1 Variable Assignments for Independent Regressors .................................................................. 7-13

7.4.2 Exclusion of Error Term from Regression Equation to Predict Marginal Values.................... 7-13

7.4.3 Other Limitations and Uncertainties ........................................................................................ 7-14

8 NONUSE BENEFITS OF REDUCING I&E MORTALITY...................................................................... 8-1

8.1 INTRODUCTION..................................................................................................................................8-1

8.2 PUBLIC POLICY SIGNIFICANCE OF ECOLOGICAL IMPROVEMENTS FROM THE PROPOSED 316(B)

REGULATION FOR EXISTING FACILITIES............................................................................................8-1

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

8.2.2 Marine Protected Areas.............................................................................................................. 8-2

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

8.2.4 Summary of Evidence for Nonuse Values of Ecosystems Impacted by CWISs ........................... 8-5

8.3 QUANTITATIVE ASSESSMENT OF ECOLOGICAL NONUSE BENEFITS ...................................................8-6

8.3.1 Description of Johnston et al. (2009) and BSPV Methods.......................................................... 8-6

8.3.2 Benefits Transfer Methodology................................................................................................... 8-8

8.4 ESTIMATES OF TOTAL WTP BY OPTION AND REGION.....................................................................8-13

8.5 LIMITATIONS AND UNCERTAINTIES.................................................................................................8-14

8.5.1 Scale of Fishery Improvements................................................................................................. 8-15

8.5.2 Scale and Characteristics of the Affected Population .............................................................. 8-15

8.5.3 Fish Population Size, Type and Improvement from the Elimination of I&E Mortality ............ 8-15

9 HABITAT BASED METHODOLOGY FOR ESTIMATING NONUSE VALUES OF FISH

PRODUCTION LOST TO I&E MORTALITY ............................................................................................ 9-1

9.1 INTRODUCTION..................................................................................................................................9-1

9.2 ESTIMATING THE AMOUNT OF HABITAT NEEDED TO OFFSET I&E MORTALITY................................9-2

9.2.1 Quantify the Mass of Production Lost to I&E Mortality ............................................................ 9-2

9.2.2 Production per Unit of Habitat................................................................................................... 9-3

9.2.3 Select Preferred Restoration Habitat ......................................................................................... 9-7

9.2.4 Scaling Habitat Restoration Alternatives to Offset I&E Mortality............................................. 9-8

9.3 DEVELOPMENT OF WTP VALUES FOR FISH PRODUCTION SERVICES OF HABITAT...........................9-10

9.3.1 Estimating the Importance of Fish Habitat as a Proportion of Habitat WTP Values: Salt

Marshes. ................................................................................................................................... 9-11

9.3.2 Estimating the Importance of Fish Habitat as a Proportion of Habitat WTP Values:

Freshwater Wetlands................................................................................................................ 9-12
March 28, 2011 iv

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

9.3.3 Estimated Proportion of Household WTP Estimates Attributed to Fish Production

Services..................................................................................................................................... 9-13

9.4 ESTIMATING THE VALUE OF HABITAT NEEDED TO OFFSET I&E MORTALITY.................................9-13

9.4.1 Determining the Extent of Nonuse Values ................................................................................ 9-13

9.4.2 Estimating Aggregate Values ................................................................................................... 9-14

9.5 WTP RESULTS ................................................................................................................................9-15

9.6 LIMITATIONS AND UNCERTAINTIES.................................................................................................9-17

9.6.1 Estimating the Extent of the Affected Population ..................................................................... 9-17

9.6.2 Not All Species and Losses Are Compensated.......................................................................... 9-17

9.6.3 Timing of Losses and Restoration............................................................................................. 9-17

9.6.4 Application of the Approach to Large Geographic Areas ........................................................ 9-17

9.6.5 Specification of Parameter Assumptions .................................................................................. 9-18

10 NATIONAL BENEFITS.......................................................................................................................... 10-1

10.1 INTRODUCTION................................................................................................................................10-1

10.2 METHODOLOGY ..............................................................................................................................10-1

10.3 SUMMARY OF BASELINE LOSSES AND EXPECTED REDUCTIONS IN I&E MORTALITY ......................10-2

10.4 NATIONAL MONETIZED BENEFITS FROM ELIMINATING AND REDUCING I&E MORTALITY

LOSSES............................................................................................................................................10-4

10.5 BREAK-EVEN ANALYSIS ...............................................................................................................10-12

11 OPTION 4 RESULTS .............................................................................................................................. 11-1

10.1 INTRODUCTION................................................................................................................................11-1

10.2 EXPECTED REDUCTIONS IN I&E MORTALITY UNDER OPTION 4 ......................................................11-1

10.3 MONETIZED BENEFITS UDER OPTION 4 ...........................................................................................11-2

12 REFERENCES ......................................................................................................................................... 12-1

APPENDIX A : EXTRAPOLATION METHODS...............................................................................................A-1

A.1 INTRODUCTION.................................................................................................................................A-1

A.2 MANUFACTURING FACILITIES ..........................................................................................................A-1

A.2.1 Traditional Manufacturers (MN Facilities)................................................................................ A-1

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-7

APPENDIX B : CONSIDERATION OF POTENTIAL ECOLOGICAL 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.3 INFLUENCE OF SITE-SPECIFIC FACTORS AND ENVIRONMENTAL SETTING ON THERMAL

EFFECTS ...........................................................................................................................................B-4

B.4 UNCERTAINTIES AND LIMITATIONS OF ASSESSING THERMAL IMPACTS ...........................................B-5

B.5 CASE STUDIES..................................................................................................................................B-6

B.5.1 Brayton Point Station ................................................................................................................. B-6

B.5.2 Quad Cities Nuclear Station (QCNS) ....................................................................................... B-10

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

APPENDIX C : DETAILS OF REGIONAL I&E MORTALITY LOSSES ......................................................C-1

C.1 CALIFORNIA .....................................................................................................................................C-1
March 28, 2011 v

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

C.2 NORTH ATLANTIC ............................................................................................................................C-3

C.3 MID-ATLANTIC ................................................................................................................................C-6

C.4 SOUTH ATLANTIC ..........................................................................................................................C-10

C.5 GULF OF MEXICO ...........................................................................................................................C-12

C.6 GREAT LAKES ................................................................................................................................C-14

C.7 INLAND ..........................................................................................................................................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 OF CWIS, AND ESTIMATED BENEFITS OF

REGULATION ON, THREATENED AND ENDANGERED SPECIES.................................................... F-1

F.1 I&E MORTALITY OF SEA TURTLES .................................................................................................. F-1

F.2 APPLICATION OF WHITEHEAD (1993)’S BENEFIT TRANSFER APPROACH FOR ESTIMATING

WTP FOR T&E SEA TURTLE SPECIES .............................................................................................. F-3

F.3 APPLICATION OF RICHARDSON & LOOMIS’ (2008) WTP MODEL..................................................... F-5

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 ...................................................................................................................................... I-1

I.2 NORTH ATLANTIC ............................................................................................................................. I-6

I.3 MID-ATLANTIC ............................................................................................................................... I-11

I.4 SOUTH ATLANTIC ........................................................................................................................... I-16

I.5 GULF OF MEXICO ............................................................................................................................ I-18

I.6 GREAT LAKES ................................................................................................................................. I-22

I.7 INLAND ........................................................................................................................................... I-27

APPENDIX J : METHODS USED IN THE HABITAT BASED METHODOLOGY FOR

ESTIMATING NONUSE VALUES ............................................................................................................... J-1

J.1 EQUATIONS FOR ESTIMATING NONUSE VALUES USING A HABITAT BASED METHODOLOGY ................J-1

J.2 ESTIMATED PRIMARY PRODUCTIVITY AND CARBON EXPORT IN MARINE AND AQUATIC

HABITATS .........................................................................................................................................J-3

J.3 REGIONAL DETERMINATION OF PREFERRED HABITAT ......................................................................J-4

J.4 WILLINGNESS TO PAY FOR FISH PRODUCTION AND OTHER AQUATIC HABITAT GOODS AND

SERVICES ..........................................................................................................................................J-6

J.5 NARRAGANSETT BAY WETLAND RESTORATION STUDY ...................................................................J-8

J.5.1 Survey Development and Data Collection...................................................................................J-8

J.5.2 Results..........................................................................................................................................J-9

J.6 DETERMINING THE AFFECTED POPULATION AND ESTIMATING AGGREGATE VALUES.....................J-14
March 28, 2011 vi

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Tables

TABLE 1-1: IN-SCOPE FACILITIES AND ACTUAL INTAKE FLOW (AIF) BY REGION (BILLIONS OF GALLONS PER DAY). 1-3

TABLE 2-1: ANTHROPOGENIC STRESSORS IMPACTING AQUATIC ECOSYSTEMS POTENTIALLY AFFECTED, BOTH

DIRECTLY AND INDIRECTLY, BY 316(B) OPTION SCENARIOS............................................................................. 2-2

TABLE 2-2: NUMBER OF 316(B) FACILITIES ON 303(D)-LISTED WATERBODIES, BY IMPAIRMENT AND REGION.......... 2-6

TABLE 2-3: DEPLETED COMMERCIAL FISH STOCKS SUBJECT TO I&E MORTALITY.................................................... 2-8

TABLE 2-4: CWIS EFFECTS ON ECOSYSTEM FUNCTIONS/CUMULATIVE IMPACTS POTENTIALLY AFFECTED, BOTH

DIRECTLY AND INDIRECTLY, BY 316(B) REGULATIONS ................................................................................... 2-10

TABLE 2-5. TOP 20 POLLUTANTS DISCHARGED BY 316(B) FACILITIES, BY TOTAL ANNUAL LOADINGS IN 2007......... 2-14

TABLE 2-6: U.S. RIVERS WITH LARGEST WITHDRAWALS BY IN-SCOPE FACILITIES ................................................. 2-18

TABLE 3-1: SUMMARY OF BASELINE I&E MORTALITY LOSSES AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND

GENERATING) IN CALIFORNIA, AND REDUCTIONS UNDER OPTION SCENARIOS................................................. 3-7

TABLE 3-2: BASELINE LOSSES IN FISHERY YIELD, CATCH, AND PRODUCTION FORGONE AS A CONSEQUENCE OF I&E

MORTALITY AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING) IN CALIFORNIA, AND

REDUCTIONS UNDER OPTION SCENARIOS ......................................................................................................... 3-7

TABLE 3-3: BASELINE I&E MORTALITY LOSSES AND I&E MORTALITY REDUCTIONS AT ALL IN-SCOPE FACILITIES

(MANUFACTURING AND GENERATING) IN THE NORTH ATLANTIC, AND REDUCTIONS UNDER OPTION SCENARIOS

.......................................................................................................................................................................... 3-8

TABLE 3-4: BASELINE LOSSES IN FISHERY YIELD, CATCH, AND PRODUCTION FORGONE AS A CONSEQUENCE OF I&E

MORTALITY AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING) IN THE NORTH ATLANTIC, AND

REDUCTIONS UNDER OPTION SCENARIOS ......................................................................................................... 3-8

TABLE 3-5: BASELINE I&E MORTALITY LOSSES AND I&E MORTALITY REDUCTIONS AT ALL IN-SCOPE FACILITIES

(MANUFACTURING AND GENERATING) IN THE MID-ATLANTIC, AND REDUCTIONS UNDER OPTION SCENARIOS3-9

TABLE 3-6: BASELINE LOSSES IN FISHERY YIELD, CATCH, AND PRODUCTION FORGONE AS A CONSEQUENCE OF I&E

MORTALITY AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING) IN THE MID-ATLANTIC, AND

REDUCTIONS UNDER OPTION SCENARIOS ......................................................................................................... 3-9

TABLE 3-7: BASELINE I&E MORTALITY LOSSES AND I&E MORTALITY REDUCTIONS AT ALL IN-SCOPE FACILITIES

(MANUFACTURING AND GENERATING) IN THE SOUTH ATLANTIC, AND REDUCTIONS UNDER OPTION SCENARIOS

........................................................................................................................................................................ 3-10

TABLE 3-8: BASELINE LOSSES IN FISHERY YIELD, CATCH, AND PRODUCTION FORGONE AS A CONSEQUENCE OF I&E

MORTALITY AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING) IN THE SOUTH ATLANTIC, AND

REDUCTIONS UNDER OPTION SCENARIOS ....................................................................................................... 3-10

TABLE 3-9: BASELINE I&E MORTALITY LOSSES AND I&E MORTALITY REDUCTIONS AT ALL IN-SCOPE FACILITIES

(MANUFACTURING AND GENERATING) IN THE GULF OF MEXICO, AND REDUCTIONS UNDER OPTION SCENARIOS

........................................................................................................................................................................ 3-11

TABLE 3-10: BASELINE LOSSES IN FISHERY YIELD, CATCH, AND PRODUCTION FORGONE AS A CONSEQUENCE OF I&E

MORTALITY AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING) IN THE GULF OF MEXICO, AND

REDUCTIONS UNDER OPTION SCENARIOS ....................................................................................................... 3-12

TABLE 3-11: BASELINE I&E MORTALITY LOSSES AND I&E MORTALITY REDUCTIONS AT ALL IN-SCOPE FACILITIES

(MANUFACTURING AND GENERATING) IN THE GREAT LAKES, AND REDUCTIONS UNDER OPTION SCENARIOS3-12

TABLE 3-12: BASELINE LOSSES IN FISHERY YIELD, CATCH, AND PRODUCTION FORGONE AS A CONSEQUENCE OF I&E

MORTALITY AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING) IN THE GREAT LAKES, AND

REDUCTIONS UNDER OPTION SCENARIOS ....................................................................................................... 3-13

TABLE 3-13: BASELINE I&E MORTALITY LOSSES AND I&E MORTALITY REDUCTIONS AT ALL IN-SCOPE FACILITIES

(MANUFACTURING AND GENERATING) IN THE INLAND REGION, AND REDUCTIONS UNDER OPTION SCENARIOS 3-

13
March 28, 2011 vii

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

TABLE 3-14: BASELINE LOSSES IN FISHERY YIELD, CATCH, AND PRODUCTION FORGONE AS A CONSEQUENCE OF I&E

MORTALITY AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING) IN THE INLAND REGION, AND

REDUCTIONS UNDER OPTION SCENARIOS ....................................................................................................... 3-14

TABLE 3-15: BASELINE I&E MORTALITY LOSSES AND I&E MORTALITY REDUCTIONS AT ALL IN-SCOPE FACILITIES

(MANUFACTURING AND GENERATING) NATIONALLY, AND REDUCTIONS UNDER OPTION SCENARIOS ........... 3-15

TABLE 3-16: BASELINE LOSSES IN FISHERY YIELD, CATCH, AND PRODUCTION FORGONE AS A CONSEQUENCE OF I&E

MORTALITY AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING) NATIONALLY, AND

REDUCTIONS UNDER OPTION SCENARIOS ....................................................................................................... 3-15

TABLE 3-17: STRUCTURAL UNCERTAINTIES............................................................................................................. 3-17

TABLE 3-18: PARAMETERS INCLUDED IN EPA’S I&E MORTALITY ANALYSIS SUBJECT TO UNCERTAINTY.............. 3-19

TABLE 4-1: SUMMARY OF BENEFIT CATEGORIES’ DATA NEEDS, POTENTIAL DATA SOURCES, APPROACHES, AND

ANALYSES COMPLETED..................................................................................................................................... 4-3

TABLE 4-2: SUMMARY OF BASELINE NATIONAL I&E MORTALITY LOSSES AND REDUCTIONS IN I&E MORTALITY

LOSSES, BY REGULATORY OPTION .................................................................................................................... 4-7

TABLE 5-1: NUMBER OF T&E SPECIES WITH GEOGRAPHICAL DISTRIBUTIONS OVERLAPPING IN-SCOPE CWISS, ON A

PER-FACILITY BASIS.......................................................................................................................................... 5-4

TABLE 5-2: NUMBER OF FACILITIES WITH CWISS WITHIN THE GEOGRAPHICAL DISTRIBUTION OF T&E SPECIES, ON A

PER-SPECIES BASIS ............................................................................................................................................ 5-6

TABLE 5-3: T&E SPECIES WITH DOCUMENTED I&E MORTALITY. SPECIES ARE SEPARATED BY THE TAXONOMIC

RESOLUTION REPORTED FOR THE I&E MORTALITY LOSS.................................................................................... 5-9

TABLE 5-4: FEDERAL AND STATE EXPENDITURES FOR T&E SPECIES OVERLAPPING WITH CWIS ........................... 5-10

TABLE 5-5: ANNUAL BASELINE I&E MORTALITY AND REDUCTIONS IN BASELINE I&E MORTALITY OF T&E SPECIES

AT IN-SCOPE FACILITIES IN THE INLAND REGION, BY REGULATORY OPTION (A1E)........................................ 5-12

TABLE 5-6: ESTIMATED ANNUAL WTP FOR ELIMINATING OR REDUCING I&E MORTALITY OF SPECIAL STATUS FISH

SPECIES AT IN-SCOPE FACILITIES IN THE INLAND REGION, BY REGULATORY OPTION (2009$)........................ 5-13

TABLE 5-7: MONETIZED BENEFITS OF A 1 PERCENT INCREASE IN THE PROBABILITY THAT LOGGERHEAD SEA TURTLES

WILL NOT BE EXTINCT IN 25 YEARS............................................................................................................... 5-17

TABLE 5-8: CAVEATS, OMISSIONS, BIASES, AND UNCERTAINTIES IN THE T&E SPECIES BENEFITS ESTIMATES....... 5-17

TABLE 6-1: CALIFORNIA REGION, SPECIES-SPECIFIC GEAR TYPE, STATUS OF STOCK, AND NET BENEFITS RATIO.... 6-5

TABLE 6-2: NORTH ATLANTIC REGION, SPECIES-SPECIFIC GEAR TYPE, STATUS OF STOCK, AND NET BENEFITS RATIO

.......................................................................................................................................................................... 6-6

TABLE 6-3: MID-ATLANTIC REGION, SPECIES-SPECIFIC GEAR TYPE, STATUS OF STOCK, AND NET BENEFITS RATIO6-7

TABLE 6-4: SOUTH ATLANTIC REGION, SPECIES-SPECIFIC GEAR TYPE, STATUS OF STOCK, AND NET BENEFITS RATIO

.......................................................................................................................................................................... 6-8

TABLE 6-5: GULF OF MEXICO REGION, SPECIES-SPECIFIC GEAR TYPE, STATUS OF STOCK, AND NET BENEFITS RATIO

.......................................................................................................................................................................... 6-8

TABLE 6-6: GREAT LAKES REGION, SPECIES-SPECIFIC GEAR TYPE, STATUS OF STOCK, AND NET BENEFITS RATIO . 6-9

TABLE 6-7: POTENTIAL HARVEST INCREASE FROM ELIMINATING I&E MORTALITY LOSSES AS A PERCENTAGE OF

TOTAL HARVEST AND POTENTIAL HARVEST CAPPING RULES USED IN EPA’S ANALYSIS .............................. 6-10

TABLE 6-8: COMMERCIAL FISHING BENEFITS FROM ELIMINATING OR REDUCING BASELINE I&E MORTALITY LOSSES

AT IN-SCOPE FACILITIES IN THE CALIFORNIA REGION, BY REGULATORY OPTION (2009$) ............................. 6-11

TABLE 6-9: COMMERCIAL FISHING BENEFITS FROM ELIMINATING OR REDUCING BASELINE I&E MORTALITY LOSSES

AT IN-SCOPE FACILITIES IN THE NORTH ATLANTIC REGION, BY REGULATORY OPTION (2009$) .................... 6-12

TABLE 6-10: COMMERCIAL FISHING BENEFITS FROM ELIMINATING OR REDUCING BASELINE I&E MORTALITY LOSSES

AT IN-SCOPE FACILITIES IN THE MID-ATLANTIC REGION, BY REGULATORY OPTION (2009$)......................... 6-13

TABLE 6-11: COMMERCIAL FISHING BENEFITS FROM ELIMINATING OR REDUCING BASELINE I&E MORTALITY LOSSES

AT IN-SCOPE FACILITIES IN THE SOUTH ATLANTIC REGION, BY REGULATORY OPTION (2009$)..................... 6-14

TABLE 6-12: COMMERCIAL FISHING BENEFITS FROM ELIMINATING OR REDUCING BASELINE I&E MORTALITY LOSSES

AT IN-SCOPE FACILITIES IN THE GULF OF MEXICO REGION, BY REGULATORY OPTION (2009$) ..................... 6-14

TABLE 6-13: COMMERCIAL FISHING BENEFITS FROM ELIMINATING OR REDUCING BASELINE I&E MORTALITY LOSSES

AT IN-SCOPE FACILITIES IN THE GREAT LAKES REGION, BY REGULATORY OPTION (2009$)........................... 6-15
March 28, 2011 viii

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

TABLE 6-14: CAVEATS, OMISSIONS, BIASES, AND UNCERTAINTIES IN THE COMMERCIAL BENEFITS ESTIMATES .... 6-16

TABLE 7-1: INDEPENDENT VARIABLE ASSIGNMENTS FOR REGRESSION EQUATION ................................................... 7-3

TABLE 7-2: REGION- AND SPECIES-SPECIFIC VARIABLE ASSIGNMENTS FOR THE REGRESSION EQUATION................. 7-5

TABLE 7-3: MARGINAL RECREATIONAL VALUE PER FISH, BY REGION AND SPECIESA................................................ 7-5

TABLE 7-4: CONFIDENCE BOUNDS ON MARGINAL RECREATIONAL VALUE PER FISH, BASED ON THE KRINSKY AND

ROBB APPROACHA............................................................................................................................................. 7-7

TABLE 7-5: RECREATIONAL FISHING BENEFITS FROM ELIMINATING OR REDUCING BASELINE I&E MORTALITY LOSSES

AT IN-SCOPE FACILITIES IN THE CALIFORNIA REGION, BY REGULATORY OPTION (2009$) ............................... 7-8

TABLE 7-6: RECREATIONAL FISHING BENEFITS FROM ELIMINATING OR REDUCING BASELINE I&E MORTALITY LOSSES

AT IN-SCOPE FACILITIES IN THE NORTH ATLANTIC REGION, BY REGULATORY OPTION (2009$) ...................... 7-9

TABLE 7-7: RECREATIONAL FISHING BENEFITS FROM ELIMINATING OR REDUCING BASELINE I&E MORTALITY LOSSES

AT IN-SCOPE FACILITIES IN THE MID-ATLANTIC REGION, BY REGULATORY OPTION (2009$)........................... 7-9

TABLE 7-8: RECREATIONAL FISHING BENEFITS FROM ELIMINATING OR REDUCING BASELINE I&E MORTALITY LOSSES

AT IN-SCOPE FACILITIES IN THE SOUTH ATLANTIC REGION, BY REGULATORY OPTION (2009$)..................... 7-10

TABLE 7-9: RECREATIONAL FISHING BENEFITS FROM ELIMINATING OR REDUCING BASELINE I&E MORTALITY LOSSES

AT IN-SCOPE FACILITIES IN THE GULF OF MEXICO REGION, BY REGULATORY OPTION (2009$) ..................... 7-11

TABLE 7-10: RECREATIONAL FISHING BENEFITS FROM ELIMINATING OR REDUCING BASELINE I&E MORTALITY

LOSSES AT IN-SCOPE FACILITIES IN THE GREAT LAKES REGION, BY REGULATORY OPTION (2009$).............. 7-12

TABLE 7-11: RECREATIONAL FISHING BENEFITS FROM ELIMINATING OR REDUCING BASELINE I&E MORTALITY

LOSSES AT IN-SCOPE FACILITIES IN THE INLAND REGION, BY REGULATORY OPTION (2009$)........................ 7-13

TABLE 8-1: 316(B) FACILITIES IN MARINE PROTECTED AREAS, AND IMPROVEMENTS IN I&E MORTALITY

TECHNOLOGIES BY REGULATORY OPTION......................................................................................................... 8-5

TABLE 8-2: RESULTS OF MIXED LOGIT MAXIMUM LIKELIHOOD ESTIMATION (BOUNDED TRIANGULAR COST) ...... 8-11

TABLE 8-3: WTP PER PERCENTAGE INCREASE IN THE NUMBER OF FISH.................................................................. 8-12

TABLE 8-4: BASELINE I&E MORTALITY LOSSES AND ESTIMATED FISH NUMBERS FOR THE NORTHEAST U.S. (NORTH

ATLANTIC AND MID-ATLANTIC REGIONS) ...................................................................................................... 8-13

TABLE 8-5: NONUSE VALUE OF ELIMINATING OR REDUCING BASELINE I&E MORTALITY LOSSES BY REGULATORY

OPTION FOR ALL IN-SCOPE FACILITIES IN THE NORTH ATLANTIC AND MID-ATLANTIC REGIONS................... 8-14

TABLE 9-1: SUMMARY OF PRODUCTIVITY VALUES OF PREFERRED SCALING HABITATS BY REGION (KG DRY MASS

ACRE-1 YR-1)....................................................................................................................................................... 9-7

TABLE 9-2: BASELINE I&E MORTALITY (METRIC TONS A1E YEAR-1) AND HABITAT RESTORATION AREA (ACRES)

EQUIVALENT TO BASELINE I&E MORTALITY, AND I&E MORTALITY REDUCTIONS (METRIC TONS A1E YEAR-1)

AND HABITAT RESTORATION AREA (ACRES) EQUIVALENT TO THESE REDUCTIONS, BY REGION AND

REGULATORY OPTION ....................................................................................................................................... 9-9

TABLE 9-3: TOTAL ANNUAL HOUSEHOLD WTP PER ACRE OF AQUATIC HABITAT ................................................. 9-11

TABLE 9-4: HOUSEHOLD WTP PER ACRE PER YEAR FOR FISH PRODUCTION SERVICES .......................................... 9-13

TABLE 9-5: WEIGHTED WTP FOR HABITAT RESTORATION AREA EQUIVALENT TO BASELINE I&E MORTALITY, AND

WEIGHTED WTP FOR HABITAT RESTORATION AREA EQUIVALENT TO I&E MORTALITY REDUCTIONS BY REGION

AND REGULATORY OPTION.............................................................................................................................. 9-16

TABLE 10-1: BASELINE NATIONAL A1E LOSSES AT ALL IN-SCOPE FACILITIES (MILLIONS OF A1ES) ...................... 10-2

TABLE 10-2: REDUCTIONS IN NATIONAL A1E LOSSES FOR ALL IN-SCOPE FACILITIES (MILLIONS OF A1ES) UNDER

OPTION 1 (I EVERYWHERE) ............................................................................................................................. 10-2

TABLE 10-3: REDUCTIONS IN NATIONAL A1E LOSSES FOR ALL IN-SCOPE FACILITIES (MILLION A1ES) UNDER OPTION

2 (I EVERYWHERE AND E FOR FACILITIES > 125 MGD) .................................................................................. 10-3

TABLE 10-4: REDUCTIONS IN NATIONAL A1E LOSSES FOR ALL IN-SCOPE FACILITIES (MILLIONS OF A1ES) UNDER

OPTION 3 (I&E MORTALITY EVERYWHERE).................................................................................................... 10-3

TABLE 10-5: BASELINE NATIONAL I&E MORTALITY AND I&E MORTALITY REDUCTIONS FOR ALL IN-SCOPE

FACILITIES BY REGULATORY OPTION.............................................................................................................. 10-3

TABLE 10-6: DISTRIBUTION OF NATIONAL I&E MORTALITY FOR ALL IN-SCOPE FACILITIES BY REGULATORY OPTION

........................................................................................................................................................................ 10-4
March 28, 2011 ix

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

TABLE 10-7: SUMMARY OF NATIONAL BENEFITS FROM ELIMINATING BASELINE I&E MORTALITY LOSSES FOR ALL

IN-SCOPE FACILITIES (2009$).......................................................................................................................... 10-7

TABLE 10-8: SUMMARY OF NATIONAL BENEFITS OF OPTION 1 (I EVERYWHERE) FOR ALL IN-SCOPE FACILITIES

(2009$)............................................................................................................................................................ 10-8

TABLE 10-9: SUMMARY OF NATIONAL BENEFITS OF OPTION 2 (I EVERYWHERE AND E FOR FACILITIES > 125 MGD)

FOR ALL IN-SCOPE FACILITIES (2009$) ........................................................................................................... 10-9

TABLE 10-10: SUMMARY OF NATIONAL BENEFITS OF OPTION 3 (I&E MORTALITY EVERYWHERE) FOR ALL IN-SCOPE

FACILITIES (2009$)........................................................................................................................................ 10-10

TABLE 10-11: SUMMARY OF NATIONAL BENEFITS BY REGULATORY OPTION FOR ALL IN-SCOPE FACILITIES (2009$)

...................................................................................................................................................................... 10-11

TABLE 10-12: IMPLICIT NONUSE VALUE—BREAK-EVEN ANALYSIS, 3 PERCENT AND 7 PERCENT DISCOUNT RATES

(2009$).......................................................................................................................................................... 10-13

TABLE 11-1: DISTRIBUTION OF I&E MORTALITY FOR ALL IN-SCOPE FACILITIES BY REGION UNDER OPTION 4 (I

EVERYWHERE WITHOUT NEW UNITS REQUIREMENTS).................................................................................... 11-1

TABLE 11-2: ANNUAL INCREASE IN RECREATIONAL AND COMMERCIAL HARVEST UNDER OPTION 4 (I EVERYWHERE

WITHOUT NEW UNITS REQUIREMENTS)........................................................................................................... 11-2

TABLE 11-3: SUMMARY OF NATIONAL BENEFITS OF OPTION 4 (I EVERYWHERE WITHOUT NEW UNITS REQUIREMENTS)

(2009$)............................................................................................................................................................ 11-3

TABLE 11-4: WEIGHTED WTP FOR HABITAT RESTORATION AREA EQUIVALENT TO I&E MORTALITY REDUCTIONS BY

REGION UNDER OPTION 4 ((I EVERYWHERE WITHOUT NEW UNITS REQUIREMENTS) ...................................... 11-4

TABLE A-1: MN DQ DISTRIBUTION AND CALCULATION OF WEIGHT ADJUSTMENT FACTORS.................................. A-4

TABLE A-2: MU ADJUSTMENT FACTORS AND ADJUSTED FLOW BY BENEFITS REGION ............................................ A-6

TABLE A-3: MATRIX OF STRATA AND CONTROL VARIABLES FOR ADJUSTING DQ WEIGHTS ................................... A-7

TABLE A-4: MEAN OPERATIONAL FLOW BY BENEFITS REGION: POST-STRATIFICATION BY MEAN REGIONAL

OPERATIONAL FLOW FOR FACILITIES WITHOUT RECIRCULATION (MGD) ....................................................... A-8

TABLE C-1: BASELINE I&E MORTALITY LOSSES AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING)

IN THE CALIFORNIA REGION (MILLION A1ES PER YEAR), AND I&E MORTALITY REDUCTIONS FOR OPTION

SCENARIOS ESTIMATED FOR ALL SOURCES OF MORTALITY..............................................................................C-1

TABLE C-2: BASELINE I&E MORTALITY LOSSES AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING)

IN THE CALIFORNIA REGION (MILLION INDIVIDUALS PER YEAR), AND I&E MORTALITY REDUCTIONS FOR OPTION

SCENARIOS ESTIMATED FOR ALL SOURCES OF MORTALITY..............................................................................C-2

TABLE C-3: BASELINE I&E MORTALITY LOSSES AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING)

IN THE NORTH ATLANTIC (MILLION A1ES PER YEAR), AND I&E MORTALITY REDUCTIONS FOR OPTION

SCENARIOS ESTIMATED FOR ALL SOURCES OF MORTALITY..............................................................................C-3

TABLE C-4: BASELINE I&E MORTALITY LOSSES AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING)

IN THE NORTH ATLANTIC (MILLION INDIVIDUALS PER YEAR), AND I&E MORTALITY REDUCTIONS FOR OPTION

SCENARIOS ESTIMATED FOR ALL SOURCES OF MORTALITY..............................................................................C-4

TABLE C-5: BASELINE I&E MORTALITY LOSSES AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING)

IN THE MID-ATLANTIC (MILLION A1ES PER YEAR), AND I&E MORTALITY REDUCTIONS FOR OPTION SCENARIOS

ESTIMATED FOR ALL SOURCES OF MORTALITY.................................................................................................C-6

TABLE C-6: BASELINE I&E MORTALITY LOSSES AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING)

IN THE MID-ATLANTIC (MILLION INDIVIDUALS PER YEAR), AND I&E MORTALITY REDUCTIONS FOR OPTION

SCENARIOS ESTIMATED FOR ALL SOURCES OF MORTALITY..............................................................................C-8

TABLE C-6: BASELINE I&E MORTALITY LOSSES AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING)

IN THE MID-ATLANTIC (MILLION INDIVIDUALS PER YEAR), AND I&E MORTALITY REDUCTIONS FOR OPTION

SCENARIOS ESTIMATED FOR ALL SOURCES OF MORTALITY, CONTINUED..........................................................C-9

TABLE C-7: BASELINE I&E MORTALITY LOSSES AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING)

IN THE SOUTH ATLANTIC (MILLION A1ES PER YEAR), AND I&E MORTALITY REDUCTIONS FOR OPTION

SCENARIOS ESTIMATED FOR ALL SOURCES OF MORTALITY............................................................................C-10
March 28, 2011 x

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

TABLE C-8: BASELINE I&E MORTALITY LOSSES AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING)

IN THE SOUTH ATLANTIC (MILLION INDIVIDUALS PER YEAR), AND I&E MORTALITY REDUCTIONS FOR OPTION

SCENARIOS ESTIMATED FOR ALL SOURCES OF MORTALITY............................................................................C-11

TABLE C-9: BASELINE I&E MORTALITY LOSSES AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING)

IN THE GULF OF MEXICO (MILLION A1ES PER YEAR), AND I&E MORTALITY REDUCTIONS FOR OPTION

SCENARIOS ESTIMATED FOR ALL SOURCES OF MORTALITY............................................................................C-12

TABLE C-10: BASELINE I&E MORTALITY LOSSES AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING)

IN THE GULF OF MEXICO (MILLION INDIVIDUALS PER YEAR), AND I&E MORTALITY REDUCTIONS FOR OPTION

SCENARIOS ESTIMATED FOR ALL SOURCES OF MORTALITY............................................................................C-13

TABLE C-11: BASELINE I&E MORTALITY LOSSES AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING)

IN THE GREAT LAKES (MILLION A1ES PER YEAR), AND I&E MORTALITY REDUCTIONS FOR OPTION SCENARIOS

ESTIMATED FOR ALL SOURCES OF MORTALITY...............................................................................................C-14

TABLE C-12: BASELINE I&E MORTALITY LOSSES AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING)

IN THE GREAT LAKES (MILLION INDIVIDUALS PER YEAR), AND I&E MORTALITY REDUCTIONS FOR OPTION

SCENARIOS ESTIMATED FOR ALL SOURCES OF MORTALITY............................................................................C-15

TABLE C-13: BASELINE I&E MORTALITY LOSSES AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING)

IN THE INLAND REGION (MILLION A1ES PER YEAR), AND I&E MORTALITY REDUCTIONS FOR OPTION SCENARIOS

ESTIMATED FOR ALL SOURCES OF MORTALITY...............................................................................................C-17

TABLE C-14: BASELINE I&E MORTALITY LOSSES AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING)

IN THE INLAND REGION (MILLION INDIVIDUALS PER YEAR), AND I&E MORTALITY REDUCTIONS FOR OPTION

SCENARIOS ESTIMATED FOR ALL SOURCES OF MORTALITY............................................................................C-18

TABLE C-15: BASELINE I&E MORTALITY LOSSES AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING)

NATIONALLY (MILLION A1ES PER YEAR), AND I&E MORTALITY REDUCTIONS FOR OPTION SCENARIOS

ESTIMATED FOR ALL SOURCES OF MORTALITY...............................................................................................C-20

TABLE C-16: BASELINE I&E MORTALITY LOSSES AT ALL IN-SCOPE FACILITIES (MANUFACTURING AND GENERATING)

NATIONALLY (MILLION INDIVIDUALS PER YEAR), AND I&E MORTALITY REDUCTIONS FOR OPTION SCENARIOS

ESTIMATED FOR ALL SOURCES OF MORTALITY...............................................................................................C-24

TABLE D-1: TIME PROFILE OF NATIONAL MEAN TOTAL BENEFITS AT IN-SCOPE FACILITIES BY REGULATORY OPTION

(2009$, THOUSANDS)........................................................................................................................................ D-4

TABLE E-1: LIST OF T&E SPECIES OVERLAPPING ONE OR MORE IN-SCOPE 316(B) COOLING WATER INTAKE

STRUCTURE .......................................................................................................................................................E-1

TABLE F-1: REPORTED VALUES OF SEA TURTLE ENTRAINMENT ............................................................................... F-2

TABLE F-2: A SUBSET OF US-BASED NONGOVERNMENTAL ORGANIZATIONS DEDICATED TO SEA TURTLE RESEARCH

AND CONSERVATION.......................................................................................................................................... F-3

TABLE F-3: VARIABLE DESCRIPTIONS AND VALUES USED FOR EPA’S BENEFITS TRANSFER APPLICATION............... F-5

TABLE F-4: VARIABLES IN THE META-ANALYSIS MODEL AND VALUES USED IN EPA’S APPLICATION..................... F-6

TABLE G-1: OWN-PRICE ELASTICITY ESTIMATES FROM LITERATURE REVIEW......................................................... G-2

TABLE G-2: ESTIMATED PERCENTAGE CHANGE IN EX-VESSEL PRICE BY REGION AND SPECIES GROUP .................. G-3

TABLE G-3: ESTIMATED PRICE CHANGES FOR THE CALIFORNIA REGION.................................................................. G-3

TABLE G-4: ESTIMATED PRICE CHANGES FOR THE NORTH ATLANTIC REGION......................................................... G-4

TABLE G-5: ESTIMATED PRICE CHANGES FOR THE MID-ATLANTIC REGION............................................................. G-5

TABLE G-6: ESTIMATED PRICE CHANGES FOR THE SOUTH ATLANTIC REGION ......................................................... G-5

TABLE G-7: ESTIMATED PRICE CHANGES FOR THE GULF OF MEXICO REGION.......................................................... G-6

TABLE H-1: COMMERCIAL FISHING BENEFITS FROM ELIMINATING OR REDUCING BASELINE I&E MORTALITY LOSSES

AT IN-SCOPE FACILITIES IN THE CALIFORNIA REGION, BY SPECIES AND REGULATORY OPTION (2009$) ......... H-1

TABLE H-2: COMMERCIAL FISHING BENEFITS FROM ELIMINATING OR REDUCING BASELINE I&E MORTALITY LOSSES

AT IN-SCOPE FACILITIES IN THE NORTH ATLANTIC REGION, BY SPECIES AND REGULATORY OPTION (2009$) H-2

TABLE H-3: COMMERCIAL FISHING BENEFITS FROM ELIMINATING OR REDUCING BASELINE I&E MORTALITY LOSSES

AT IN-SCOPE FACILITIES IN THE MID-ATLANTIC REGION, BY SPECIES AND REGULATORY OPTION (2009$) .... H-3

TABLE H-4: COMMERCIAL FISHING BENEFITS FROM ELIMINATING OR REDUCING BASELINE I&E MORTALITY LOSSES

AT IN-SCOPE FACILITIES IN THE SOUTH ATLANTIC REGION, BY SPECIES AND REGULATORY OPTION (2009$). H-4
March 28, 2011 xi

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

TABLE H-5: COMMERCIAL FISHING BENEFITS FROM ELIMINATING OR REDUCING BASELINE I&E MORTALITY LOSSES

AT IN-SCOPE FACILITIES IN THE GULF OF MEXICO REGION, BY SPECIES AND REGULATORY OPTION (2009$) . H-5

TABLE H-6: COMMERCIAL FISHING BENEFITS FROM ELIMINATING OR REDUCING BASELINE I&E MORTALITY LOSSES

AT IN-SCOPE FACILITIES IN THE GREAT LAKES REGION, BY SPECIES AND REGULATORY OPTION (2009$) ...... H-6

TABLE I-1: RECREATIONAL FISHING BENEFITS FROM ELIMINATING BASELINE I&E MORTALITY LOSSES AT IN-SCOPE

FACILITIES IN THE CALIFORNIA REGION, BY SPECIES (2009$)............................................................................I-1

TABLE I-2: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 1 (I EVERYWHERE) IN THE CALIFORNIA REGION, BY SPECIES (2009$)......................................I-2

TABLE I-3: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 2 (I EVERYWHERE AND E FOR FACILITIES > 125 MGD) IN THE CALIFORNIA REGION, BY SPECIES

(2009$)...............................................................................................................................................................I-3

TABLE I-4: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 3 (I&E MORTALITY EVERYWHERE) IN THE CALIFORNIA REGION, BY SPECIES (2009$) ............I-4

TABLE I-5: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 4 (I EVERYWHERE WITHOUT NEW UNITS REQUIREMENTS) IN THE CALIFORNIA REGION, BY

SPECIES (2009$) .................................................................................................................................................I-5

TABLE I-6: RECREATIONAL FISHING BENEFITS FROM ELIMINATING BASELINE I&E MORTALITY LOSSES AT IN-SCOPE

FACILITIES IN THE NORTH ATLANTIC REGION, BY SPECIES (2009$)...................................................................I-6

TABLE I-7: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 1 (I EVERYWHERE) IN THE NORTH ATLANTIC REGION, BY SPECIES (2009$).............................I-7

TABLE I-8: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 2 (I EVERYWHERE AND E FOR FACILITIES > 125 MGD) IN THE NORTH ATLANTIC REGION, BY

SPECIES (2009$) .................................................................................................................................................I-8

TABLE I-9: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 3 (I&E MORTALITY EVERYWHERE) IN THE NORTH ATLANTIC REGION, BY SPECIES (2009$) ...I-9

TABLE I-10: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 4 (I EVERYWHERE WITHOUT NEW UNITS REQUIREMENTS) IN THE NORTH ATLANTIC REGION, BY

SPECIES (2009$) ...............................................................................................................................................I-10

TABLE I-11: RECREATIONAL FISHING BENEFITS FROM ELIMINATING BASELINE I&E MORTALITY LOSSES AT IN-SCOPE

FACILITIES IN THE MID-ATLANTIC REGION, BY SPECIES (2009$).....................................................................I-11

TABLE I-12: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 1 (I EVERYWHERE) IN THE MID-ATLANTIC REGION, BY SPECIES (2009$) ...............................I-12

TABLE I-13: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 2 (I EVERYWHERE AND E FOR FACILITIES > 125 MGD) IN THE MID-ATLANTIC REGION, BY

SPECIES (2009$) ...............................................................................................................................................I-13

TABLE I-14: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 3 (I&E MORTALITY EVERYWHERE) IN THE MID-ATLANTIC REGION, BY SPECIES (2009$) .....I-14

TABLE I-15: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 4 (I EVERYWHERE WITHOUT NEW UNITS REQUIREMENTS) IN THE MID-ATLANTIC REGION, BY

SPECIES (2009$) ...............................................................................................................................................I-15

TABLE I-16: RECREATIONAL FISHING BENEFITS FROM ELIMINATING BASELINE I&E MORTALITY LOSSES AT IN-SCOPE

FACILITIES IN THE SOUTH ATLANTIC REGION, BY SPECIES (2009$) .................................................................I-16

TABLE I-17: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 1 (I EVERYWHERE) IN THE SOUTH ATLANTIC REGION, BY SPECIES (2009$) ...........................I-16

TABLE I-18: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 2 (I EVERYWHERE AND E FOR FACILITIES > 125 MGD) IN THE SOUTH ATLANTIC REGION, BY

SPECIES (2009$) ...............................................................................................................................................I-17

TABLE I-19: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 3 (I&E MORTALITY EVERYWHERE) IN THE SOUTH ATLANTIC REGION, BY SPECIES (2009$)..I-17
March 28, 2011 xii

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

TABLE I-20: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 4 (I EVERYWHERE WITHOUT NEW UNITS REQUIREMENTS) IN THE SOUTH ATLANTIC REGION, BY

SPECIES (2009$) ...............................................................................................................................................I-18

TABLE I-21: RECREATIONAL FISHING BENEFITS FROM ELIMINATING BASELINE I&E MORTALITY LOSSES AT IN-SCOPE

FACILITIES IN THE GULF OF MEXICO REGION, BY SPECIES (2009$)..................................................................I-18

TABLE I-22: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 1 (I EVERYWHERE) IN THE GULF OF MEXICO REGION, BY SPECIES (2009$)............................I-19

TABLE I-23: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 2 (I EVERYWHERE AND E FOR FACILITIES > 125 MGD) IN THE GULF OF MEXICO REGION, BY

SPECIES (2009$) ...............................................................................................................................................I-20

TABLE I-24: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 3 (I&E MORTALITY EVERYWHERE) IN THE GULF OF MEXICO REGION, BY SPECIES (2009$) ..I-21

TABLE I-25: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 4 (I EVERYWHERE WITHOUT NEW UNITS REQUIREMENTS) IN THE GULF OF MEXICO REGION, BY

SPECIES (2009$) ...............................................................................................................................................I-22

TABLE I-26: RECREATIONAL FISHING BENEFITS FROM ELIMINATING BASELINE I&E MORTALITY LOSSES AT IN-SCOPE

FACILITIES IN THE GREAT LAKES REGION, BY SPECIES (2009$).......................................................................I-23

TABLE I-27: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 1 (I EVERYWHERE) IN THE GREAT LAKES REGION, BY SPECIES (2009$).................................I-24

TABLE I-28: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 2 (I EVERYWHERE AND E FOR FACILITIES > 125 MGD) IN THE GREAT LAKES REGION, BY

SPECIES (2009$) ...............................................................................................................................................I-25

TABLE I-29: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 3 (I&E MORTALITY EVERYWHERE) IN THE GREAT LAKES REGION, BY SPECIES (2009$) .......I-26

TABLE I-30: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 4 (I EVERYWHERE WITHOUT NEW UNITS REQUIREMENTS) IN THE GREAT LAKES REGION, BY

SPECIES (2009$) ...............................................................................................................................................I-27

TABLE I-31: RECREATIONAL FISHING BENEFITS FROM ELIMINATING BASELINE I&E MORTALITY LOSSES AT IN-SCOPE

FACILITIES IN THE INLAND REGION, BY SPECIES (2009$).................................................................................I-28

TABLE I-32: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 1 (I EVERYWHERE) IN THE INLAND REGION, BY SPECIES (2009$) ...........................................I-29

TABLE I-33: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 2 (I EVERYWHERE AND E FOR FACILITIES > 125 MGD) IN THE INLAND REGION, BY SPECIES

(2009$).............................................................................................................................................................I-30

TABLE I-34: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 3 (I&E MORTALITY EVERYWHERE) IN THE INLAND REGION, BY SPECIES (2009$)..................I-31

TABLE I-35: RECREATIONAL FISHING BENEFITS FROM REDUCING I&E MORTALITY LOSSES AT IN-SCOPE FACILITIES

UNDER OPTION 4 (I EVERYWHERE WITHOUT NEW UNITS REQUIREMENTS) IN THE INLAND REGION, BY SPECIES

(2009$).............................................................................................................................................................I-32

TABLE J-1: SUMMARY OF ABOVEGROUND PRIMARY PRODUCTIVITY (MEASURED IN KG DRY MASS ACRE-1 YR-1)........J-3

TABLE J-2: ESTIMATES OF CARBON EXPORT FROM SALT MARSHES ...........................................................................J-4

TABLE J-3: STUDIES USED TO ESTIMATE WTP VALUES FOR FISH PRODUCTION SERVICES AND HABITAT .................J-6

TABLE J-4: DEFINITIONS AND SUMMARY STATISTICS FOR MODEL VARIABLES FOR NARRAGANSETT BAY WETLAND

RESTORATION STUDY.......................................................................................................................................J-10

TABLE J-5: CONDITIONAL LOGIT RESULTS FOR NARRAGANSETT BAY WETLAND RESTORATION STUDY.................J-12

TABLE J-6: PROPORTIONS OF RESTORED WETLAND VALUE ASSOCIATE WITH VARIOUS SERVICE CATEGORIES......J-13

TABLE J-7: NUMBER OF HOUSEHOLDS BY STATE AND PERCENTAGE OF REGIONAL HABITAT ACRES ASSIGNED TO

EACH STATE. ....................................................................................................................................................J-14
March 28, 2011 xiii

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Figures

FIGURE 2-1: MAP OF FACILITIES LOCATED ON 303(D) WATERS AND THOSE LISTED FOR TEMPERATURE .................. 2-4

FIGURE 3-1: GENERAL APPROACH USED TO EVALUATE I&E MORTALITY LOSSES AS FORGONE FISHERY YIELD...... 3-4

FIGURE 5-2: CUMULATIVE DISTRIBUTION PLOT OF THE NUMBER OF T&E SPECIES POTENTIALLY AFFECTED ON A PERFACILITY BASIS BY IN-SCOPE FACILITIES NATIONWIDE. SAMPLE SIZES (I.E., NUMBER OF IN-SCOPE FACILITIES) ARE

NOTED IN PARENTHESES. THE HORIZONTAL AXIS IS EQUIVALENT IN ALL PLOTS, WITH THE EXCEPTION OF THE

INLAND REGION (NOTED WITH AN ASTERISK *).................................................................................................. 5-5

FIGURE 6-1: FISHERY MARKET MODEL, REPRODUCED FROM BISHOP AND HOLT (2003) ........................................... 6-2

FIGURE 8-2: IN-SCOPE FACILITIES WITH CWISS LOCATED IN MARINE PROTECTED AREAS....................................... 8-4

FIGURE 8-3: EXAMPLE CHOICE EXPERIMENT QUESTION FROM JOHNSTON ET AL. (2009) .......................................... 8-9

FIGURE 9-1: IMPLEMENTATION OF THE TROPHIC TRANSFER APPROACH.................................................................... 9-3

FIGURE 9-2: TROPHIC LEVELS AND PROCESSES CALCULATED WITH THE SIMPLIFIED, FOUR LEVEL TROPHIC TRANSFER

MODEL .............................................................................................................................................................. 9-4
March 28, 2011 1-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

1 Introduction

EPA is proposing regulations implementing Section 316(b) of the Clean Water Act (CWA) to address the

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

streams, rivers, estuaries and coastal marine waters by CWISs 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 mortality (where aquatic organisms, including eggs, and

larvae are taken 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

plants, and other impacts of variable and unknown magnitudes.

The Proposed Section 316(b) Regulation would establish national performance requirements for the

location, design, construction, and capacity of CWISs (Clean Water Act 1972). This regulation is

designed to minimize the adverse environmental impacts caused by CWIS through reduction of volume,

frequency, and/or seasonality of water withdrawals. The proposed regulations will significantly reduce

impingement and entrainment (I&E) mortality, 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 Section 316(b) regulation are likely to result in enhanced ecosystem function and

increased ecological services provided by affected waterbodies.

The two broad categories of existing facilities are considered to be within the Proposed rule’s scope

include: (1) electric generators and (2) manufacturers. In-scope 316(b) 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 they withdraw (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 Order 12866 for economically

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

benefits analysis of the regulatory options. EPA’s analysis had three main objectives: (1) to develop a

national estimate of the baseline magnitude of I&E mortality at in-scope facilities; (2) to estimate changes

in the I&E mortality of fish and invertebrates as a result of regulation; and (3) to estimate the national

economic benefits of reduced I&E mortality.

This report describes the regulatory options that EPA considered, and the study design. It identifies the

types of economic benefits that are likely to be generated by improved ecosystem functioning under

different regulatory options for in-scope facilities. 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 services likely to flow from reduced I&E mortality. Specific chapters of

the report detail the methods used to estimate values for reductions in I&E mortality.

The organization of this report is described in Section 1.3.
March 28, 2011 1-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

1.1 Summary of the Proposed Regulation and Other Evaluated Options

EPA is considering three regulatory options for existing facilities based on two technologies. The three

options would regulate only existing facilities with a DIF for cooling water of 2 MGD or greater. Each

option evaluated in developing this proposed regulation is described below.

 Option 1: I 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.

 Option 2: I 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 Cooling By Facilities Greater Than 125 MGD DIF.

 Option 3: I&E Mortality Everywhere. Establish Impingement Mortality Controls at All

Existing Facilities that Withdraw over 2 MGD DIF; Require Flow Reduction Commensurate with

Closed-Cycle Cooling at All Existing Facilities over 2 MGD DIF.

1.2 Study Design

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

regions (California,1 North Atlantic, Mid-Atlantic, South Atlantic, Gulf of Mexico, Great Lakes, and

Inland). The study regions were chosen based on regional similarities within ecosystems, aquatic species,

and characteristics of commercial and recreational fishing activities. Regional results were then combined

to develop national estimates. The geographical extent of the seven regions, and the water body types

within each region, are described below in Section 1-3. Table 1-1 presents the number of in-scope

facilities and total actual intake flow by study region.

EPA has determined that 158 in-scope facilities currently use closed-cycle cooling water systems that

minimize entrainment losses by greatly reducing the total volume of cooling water withdrawn from

nearby waterbodies. Of these facilities, 59 also meet water intake velocity requirements that minimize

impingement mortality. Although these 59 facilities would be subject to the requirements of the Proposed

Rule, they would not be required to install additional technologies to reduce I&E mortality under the

Proposed Rule. Thus, these facilities do not influence the occurrence and magnitude of benefits.

1

Includes four in-scope facilities in Hawaii.
March 28, 2011 1-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 1-1: In-Scope Facilities and Actual Intake Flow (AIF) by Region (billions of gallons per

day)

Region

Number of In-Scope

Facilitiesa

Flow Without

Recirculation Recirculated Flow Total Flow

Californiab 8 1.19 0.00 1.2

Great Lakes 67 18.81 0.24 19.0

Inlandc 669 134.87 3.89 138.8

Mid-Atlantic 54 28.10 0.07 28.2

Gulf of Mexico 30 12.89 0.00 12.9

North Atlantic 26 7.04 0.00 7.0

South Atlantic 17 7.42 0.05 7.5

All Regions 871 210.30 4.25 214.5

a

This table presents the unweighted number of facilities because weighted facilities counts are

not estimated separately by benefits region. The estimated total weighted number of potentially regulated facilities is 1152 (including

baseline closures).

b

The California region includes manufacturing facilities in the state of California and four facilities in Hawaii. It excludes coastal

electric generating facilities in the state of California due to state regulation of cooling water intakes for these facilities. There are no

coastal facilities in Oregon and a single facility in Washington classified as a baseline closure.

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

current 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 those of 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. All facilities that withdraw cooling water from

non-coastal waterbodies, such as lakes, rivers, and reservoirs, regardless of geographical location, are

included in the Inland Region (Section 1.2.3)

Coastal regions are defined as follows: the California region includes all estuary/tidal river and ocean

manufacturing facilities in California.2plus four facilities in Hawaii. The North Atlantic region

encompasses coastal facilities in Maine, New Hampshire, Massachusetts, Rhode Island, and Connecticut.

The Mid-Atlantic region includes coastal facilities in New York, New Jersey, Pennsylvania, Delaware,

Maryland, the District of Columbia, and Virginia. The South Atlantic region includes coastal facilities in

North Carolina, South Carolina, Georgia, and the east coast of Florida. Finally, the Gulf of Mexico region

includes coastal facilities in Texas, Louisiana, Mississippi, Alabama, and the west coast of Florida.

Coastal regions include a total of 152 facilities.

1.2.2 Great Lakes Region

The Great Lakes region is defined in accordance with the Clean Water Act 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

2 The California region includes manufacturing facilities in the state of California and four facilities in Hawaii, It excludes coastal

electric generating facilities in the state of California due to state regulation of cooling water intakes for these facilities.

There are no coastal facilities in Oregon and a single facility in Washington classified as a baseline closure.
March 28, 2011 1-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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

Lakes region is comprised of 67 facilities.

1.2.3 Inland Region

The Inland region includes all in-scope facilities that withdraw water from all inland waterbodies

(excluding those included within the Great Lakes Region) regardless of geographical location. There are

669 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 in-scope

facilities. To obtain regional I&E mortality estimates, EPA extrapolated loss rates from facilities for

which I&E mortality data are available (hereafter model facilities), to all in-scope facilities within the

same region. EPA’s methods for, and results from, regional I&E mortality models are described in

Chapter 3.

Chapters 4 through 9 describe EPA’s analysis of the regional economic benefits of Section 316(b)

regulatory options. 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),

nonuse benefits (Chapter 8), EPA also assesses I&E mortality losses and benefits using habitat

equivalency analyses (Chapter 9), and summarizes total national benefits for in-scope facilities based on

the results of the regional analyses (Chapter 10). Chapter 11 presents results for a fourth regulatory option

not documented in previous chapters.

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

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

mortality at in-scope facilities; Appendix 2.1.1.1AB describes potential ecological effects due to thermal

discharges; Appendix C presents detailed output from I&E mortality models; Appendix D discusses

economic discounting and the expected timing of benefits; Appendix E presents a list of T&E species

likely impacted by I&E mortality; Appendix F provides extra details on the methodologies used to

estimate the effects of I&E mortality on T&E species, and the benefits from proposed 316(b) regulation;

Appendix G presents EPA’s analysis of the potential for I&E mortality reductions to impact the market

price of commercially fished species; Appendix H presents details of the benefits of I&E mortality on

commercial fishing by region; Appendix I presents detailed regional results of the effects of I&E

mortality on recreational fishing benefits; and Appendix J presents extra details on the habitat based

methodology for estimating nonuse values of I&E mortality.
March 28, 2011 2-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

2 Baseline Impacts

2.1 Introduction

This chapter provides a brief summary of adverse environmental impacts from the impingement and

entrainment (I&E) mortality of fish and invertebrates in cooling water intake structures (CWISs) used by

electric power plants and manufacturing facilities subject to regulation under Section 316(b) of the Clean

Water Act (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 activities, channel or shoreline (habitat) modification, hydrologic regime changes, invasive

species, etc. 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 I&E mortality,

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

near a single CWIS, multiple facilities and CWISs 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, EPA believes that 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 impingement and entrainment (I&E) mortality losses 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 I&E mortality.

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 Section 316(b) regulation.

This chapter provides a qualitative description of baseline I&E mortality impacts and anthropogenic

stressors found in aquatic environments affected by CWISs.

2.2 Major Anthropogenic Stressors in Aquatic Ecosystems

All ecosystems and their 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).
March 28, 2011 2-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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

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

considered 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 CWISs 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 in-scope 316(b) 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 316(b) Option Scenarios

Impacted by Regulation

Anthropogenic Stressor Option 1 Option 2 Option 3 Scale of Stressor

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 (below) No Yes: Direct Yes: Direct Local/Regional

Engineering diversions

Re-routing No No No Local/Regional

Flow adjustments/removals/

modifications No Yes: Direct 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 Yes: Direct Yes: Direct Local/Regional

Chemical pollution (organics,

heavy metals, etc.) No Yes: Direct 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

Note: Option 1 is I Everywhere, Option 2 is I Everywhere and E for Facilities > 125 MGD, and Option 3 is I&E Mortality

Everywhere.

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 316(b) facilities have

been built on shoreline locations where power-generation buildings, roadways, CWISs, canals,
March 28, 2011 2-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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 2010b). 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).

The main impact of aquatic habitat loss is a reduction in the number of fish in the environment, a

concentration of fishery spawning and nursery areas to fewer locations, 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 I&E mortality (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, 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 I&E mortality losses were 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 plants. 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 fishkills; 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 316(b)

facilities that are within two miles of a 303(d)-listed waterbody (blue shapes), as well as those that are

impaired for temperature (red shapes). 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.
March 28, 2011 2-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Figure 2-1: Map of Facilities Located on 303(d) Waters and Those Listed for Temperature
March 28, 2011 2-5

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

EPA’s analysis of the 316(b) facilities location demonstrated that the majority of facilities, including 71

percent of generators and 79 percent of sampled manufacturing facilities, are within two miles of a

303(d)-listed waterbody (Abt Associates 2010b). Table 2-2 summarizes the number of 316(b) 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.

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 we discuss some of the more common and important physicochemical impairments in aquatic environment where 316(b) facilities potentially 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 316(b) 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 316(b)

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 316(b) 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 316(b) 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 reproduction and survival of lower

taxa as well.
March 28, 2011 2-6

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 2-2: Number of 316(b) Facilities on 303(d)-listed Waterbodies, by Impairment and Region

Impairment California

Great

Lakes Inland

MidAtlanticGulf of

Mexico

North

Atlantic

South

Atlantic Total

Biological Stressors

Noxious Aquatic Plants 2 2

Nuisance Exotic Species 2 9 11

Pathogens 1 15 99 5 1 12 6 139

Nutrients

Algal Growth 1 1

Nutrients 15 47 3 1 2 9 77

Organic Enrichment / Loading

Organic Enrichment/Oxygen Depletion 7 56 1 5 4 9 82

Sediment 9 18 2 29

Persistent, Bioaccumulative, Toxic (PBTs)

Dioxins 1 14 13 2 30

Fish Consumption Advisory - Pollutant

Unspecified 8 1 9

Mercury 2 28 96 4 2 3 135

PCBs 3 57 142 13 2 1 218

Pesticides 8 12 16 36

Physical Alterations

Flow Alteration 7 7

Habitat Alteration 6 12 18

Temperature 9 3 12

Turbidity 27 1 3 31

Toxics

Ammonia 3 1 4

Chlorine 2 2

Metals (Other Than Mercury) 3 4 43 7 1 58

Total Toxicity 2 5 2 1 15

Toxic Inorganics 1 1 2

Toxic Organics 3 12 3 18

Unknown / Other Causes

Cause Unknown 11 1 12

Cause Unknown - Fish Kills 1 1

Cause Unknown - Impaired Biota 1 3 14 2 20

Other Cause 1 1

Water Quality Use Impairments (General)

Oil And Grease 6 3 9

pH 3 8 11

Salinity/TDS/Sulfates/Chlorides 1 1 7 9

Taste, Color And Odor 4 1 5
March 28, 2011 2-7

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

EPA’s 2008 National Listing of Fish Advisories (NLFA) database indicates that 97% 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 in increasing levels of these problematic chemicals.

The water quality impacts arising from the combination of operations and/or discharges of 316(b)

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 I&E

mortality.

2.2.3 Overharvesting

Overharvesting is a general term given to describe 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. 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).

Given that many fisheries are being overfished on a continual basis, overharvesting continues to be a

problem when considering stocks subject to I&E mortality. For example, the NMFS 2009 status report

indicated that 15 percent of federally monitored fish stocks were being fished at rates above the maximum

sustainable yield (“overfishing”), while 23 percent of species are considered over-exploited

(“overfished”) (NMFS 2010a). Table 2-3 lists 21 groups of overfished, depleted, or rebuilding

commercial fish stocks occurring in I&E mortality data reported from a subset of in-scope facilities

(NMFS 2010a). Further, this assessment does not include many important fishery species not subject to

federal regulation that may be subject to high I&E mortality such as shad, menhaden, and American

lobster. Moreover, this assessment does not consider any 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).

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 U.S., 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

10-15 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.
March 28, 2011 2-8

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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 316(b) 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 to Aquatic Ecosystems

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

operations at 316(b) regulated facilities, depending on site-specific conditions at an individual facility’s

site. Many of these facilities employ once-through cooling water systems that impinge fishes 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 back to the source water. In addition, early life stage fish or planktonic

Table 2-3: Depleted Commercial Fish Stocks Subject to I&E Mortality

Stock or Stock

Complex Overfishing a Overfished b

Approaching

Overfishedc Rebuilding Stock Region

American Plaice No Yes Yes North/Mid-Atlantic

Atlantic Cod Yes Yes Yes North/Mid-Atlantic

Atlantic Sturgeon No Yes Yes Atlantic

Black Sea Bass Yes Yes Yes South Atlantic

Boccacio No No No Yes California

Butterfish No Yes Yes Mid-Atlantic

Gag Yes No Yes No South Atlantic/Gulf of Mexico

Grouper species Yes Yes Yes Gulf of Mexico

Haddock No Yes Yes North/Mid-Atlantic

Ocean Pout No Yes Yes North/Mid-Atlantic

Pink Shrimp No Yes No South Atlantic

Pollock No No No Yes North/Mid-Atlantic

Porgy No Yes Yes South Atlantic

Rockfish species Yes Yes Yes California

Skate species No Yes Yes North/Mid-Atlantic

Spiny Dogfish No No No Yes North/Mid-Atlantic

Summer Flounder No No No Yes Mid-Atlantic

Tautog Yes Unknown Unknown N/A Atlantic

White Hake Yes Yes Yes North/Mid-Atlantic

Windowpane No Yes Yes North/Mid-Atlantic

Winter Flounder Yes Yes Yes North/Mid-Atlantic

Yellowtail Flounder Yes Yes Yes North/Mid-Atlantic

a

Fishing mortality exceeds sustainable levels.

b

Stock size is below a sustainable biomass threshold.

c Estimated that the stock will be in an overfished condition by the 4th quarter of 2010.

d

Stock is rebuilding to attain a level consistent with maximum sustainable yield (MSY).

Source: National Marine Fisheries Service (NMFS) (2010a).
March 28, 2011 2-9

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

organisms can be entrained by the CWIS and subjected to death or damage due to high velocity and

pressure, increased temperature, and chemical anti-biofouling agents in the system. This I&E mortality

can act in concert with the other stressors identified above.

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

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

mortality can contribute to: impacts to T&E species (Chapter 5); reductions in ecologically critical aquatic

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

populations’ compensatory reserves; losses to populations, 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 I&E mortality 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 CWISs and I&E

mortality. 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. In this section, we discuss a subset of these effects.

2.3.1 Losses of Fish from I&E Mortality

The most visible direct impact of I&E mortality 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. The direct impacts on

populations and age structure are described for commercially (Chapter 6) and recreationally important

fish species (Chapter 7).

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 I&E mortality at CWISs. EPA believes that reducing I&E mortality will

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

populations.

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

depleted stocks of commercially targeted species (see Table 2-2). For example, I&E mortality (expressed

as age-1 equivalents) equal approximately 10 percent of the average annual recruitment to the Southern

New England/Massachusetts stock of winter flounder (Pseudopleuronectes americanus) (I&E mortality

values from Chapter 3; recruitment data from Terceiro (2008)).
March 28, 2011 2-10

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 2-4: CWIS Effects on Ecosystem Functions/Cumulative Impacts Potentially Affected, Both

Directly and Indirectly, by 316(b) Regulations

Category Direct/Indirect Local/Regional/National

A. Impingement and Entrainment (direct and indirect effects)

Effects on Individuals

Loss of billions of individuals (direct effects) Direct 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
March 28, 2011 2-11

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 2-4: CWIS Effects on Ecosystem Functions/Cumulative Impacts Potentially Affected, Both

Directly and Indirectly, by 316(b) Regulations

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

In addition to its impact on stocks of marine commercial fish species, I&E mortality 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.,

NFSC 2008), I&E mortality represent an additional source of mortality to fish populations being

harvested at unsustainable levels.

Overall, EPA believes that I&E mortality 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. Thus, reducing

I&E mortality 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 species3(Shea and Chesson

2002; Stachowicz and Byrnes 2006).

For many fish species, I&E mortality 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, since predation rates are often directly related to the concentration of available prey, I&E

mortality 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).

3

For the last response, there is evidence to support the theory that biodiversity deceases the probability of invasion by an NIS,

particularly in resource-limited environments (Stachowicz and Byrnes 2006).
March 28, 2011 2-12

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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

populations may be selected for resistance to I&E mortality (through behavioral or physiological changes)

at the expense of other, more “natural” evolutionary pressures. Although this may help sustain

populations in the short term, it may reduce genetic diversity and population stability in the long-term.

2.3.2 I&E Mortality 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, I&E mortality from CWISs may represent a substantial portion

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

recovery time, or hasten the demise of these species. For this reason, 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 CWISs may occur in several ways:

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

 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

One byproduct of once-through cooling water systems is a release of a heated effluent. Concerns about

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

the facilities subject to 316(b) I&E mortality 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 2009a). 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 1982), 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.

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
March 28, 2011 2-13

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

rate of water exchange, the presence of nearby refugia, and the assemblage of nearby fish species. In

addition to reducing total I&E mortality, 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

12.1.1.1B1.

2.3.4 Chemical Effects

One of the environmental impacts associated with power plant operations is the release of chemicals in

the discharge of once-through cooling waters. These chemicals include metals from internal corrosion of

pipes, valves and pumps (e.g., chromium, copper, iron, nickel, and zinc), additives (anti-fouling, anticorrosion, and anti-scaling agents) and their byproducts, and materials from boiler blowdown and

cleaning cycles.

EPA used the beta version of the Discharge Monitoring Report Pollutant Loading Tool (DMR-PLT)4to

obtain estimated annual pollutant loadings for facilities regulated under Section 316(b). EPA extracted

data for all facilities in selected Standard Industry Classification (SIC) codes: manufacturing (SIC 20

through 39), electric power generation (SIC 4911), and selected other sectors to which 316(b) facilities

have been assigned. Of the 871 facilities in the 316(b) master list, 707 have annual loading estimates in

DMR-PLT; of these, nearly 85 percent are electric power generators. A summary table was generated of

total annual loads for all in-scope facilities. Table 2-5 lists the top 20 pollutants discharged by 316(b)

facilities in 2007, 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 suspended solids, oil & grease, BOD5, total iron and fecal coliform.

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

operational concern for power plants. 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.

4

http://app6.erg.com/icisloader/dmrLoadingsAdvSearch.cfm. Note that DMR-PLT is currently in beta testing and there is

only limited documentation on how the loading estimation methodology is implemented in the tool. This tool does not

currently provide discharge estimates categorized by the North American Industry Classification System (NAICS).
March 28, 2011 2-14

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 2-5. Top 20 pollutants discharged by 316(b) facilities, by total

annual loadings in 2007.

Parameter Number of

facilities

Total Loading

(‘000 pounds/yr)

1 Solids, total dissolved 46 5,416.4

2 Hardness, total (as CaCO3) 48 2,842.6

3 Solids, total suspended 619 1,100.6

4 Solids, total dissolved (at 180 deg. C) 13 922.5

5 Residue, total filterable (at 105 C) 6 527.8

6 Sulfate, total (as SO4) 54 416.2

7 Chloride (as Cl) 47 403.5

8 Calcium Chloride 1 175.8

9 BOD, 5-day, 20 deg. C 227 111.6

10 Chemical Oxygen Demand (COD) 33 105.6

11 Oil & grease 274 84.5

12 Carbon, total organic (TOC) 76 45.1

13 Oxygen demand, chem. (high level) (COD) 45 44.7

14 Oil and grease, hexane extraction method 80 42.0

15 Sulfate (as S) 11 41.1

16 Iron, total (as Fe) 220 33.9

17 Fluoride, total (as F) 34 29.9

18 Coliform, fecal MF, MFC broth, 44.5 C 19 26.0

19 Oxygen demand, chem. (low level) (COD) 11 25.5

20 Coliform, fecal general 108 21.2

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 power

plants’ 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.
March 28, 2011 2-15

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

2.3.5 Effects of Flow Alteration

The operation of CWISs 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.), CWISs may withdraw and subsequently return a substantial proportion of

water available to the ecosystem. For example, of the 521 facilities that are located on freshwater streams

or rivers, 31 percent (164) of these facilities have average intake greater than 5 percent of the mean

annual flow of the source waters. Even in situations when the volume of water downstream of in-scope

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 CWISs

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), predator-prey 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

national location.

2.4 Community-level or Indirect Effects of CWISs

In addition to the direct effects of CWISs, I&E mortality may alter a wide range of aquatic ecosystem

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

function and service are poorly characterized, given the limited scope of I&E mortality studies and an

incomplete knowledge of baseline or pre-operational conditions within affected waters.

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).
March 28, 2011 2-16

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

While I&E mortality losses of commercially or recreationally important fish species can be quantified and

monetized (Chapters 3, 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, I&E mortality 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 I&E mortality may substantially affect these processes.

Several examples of ecological services indirectly affected by I&E mortality 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 I&E mortality may not be strictly proportional to the number or biomass of

lost fish or foregone fish production.

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

abundance. Power plants (and the intake volume they represent) are distributed in a non-uniform manner

along coastlines and rivers, and may be clustered (Section 2.5), such that I&E mortality 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 I&E mortality, 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).

2.4.3 Reduced Taxa and Genetic Diversity

I&E mortality 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. I&E mortality 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). Since many
March 28, 2011 2-17

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

populations stocks are differentiated by oceanic region and/or timing of migratory movements, I&E

mortality 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

I&E mortality 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 (age-0) 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 the age-0 menhaden by I&E mortality 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 I&E mortality 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 I&E

mortality 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 I&E mortality 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, I&E mortality 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 CWISs 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 2004c).

The cumulative impacts of CWISs may be exacerbated by the presence of other anthropogenic stressors

discussed above (Section 2.2).

EPA analyses suggest that approximately 20 percent of all in-scope facilities are located on waterbodies

with multiple CWISs (USEPA 2004c). Inspection of geographic locations of 316(b) facilities

(approximated by CWIS latitude and longitude) indicates that facilities in 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 CWISs on Major Rivers

To illustrate the potential for cumulative impacts, data from five major U.S. rivers with clustered

concentrations of facilities were reviewed (Table 2-6). Based on the non-uniform distribution of

facilities, locations were noted where the potential for cumulative impacts is high (Abt Associates 2010b).
March 28, 2011 2-18

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 2-6: U.S. Rivers with Largest Withdrawals by In-scope Facilities

River

Avg. Annual*

Flow (MGD) Facilities

Cumulative

DIF (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

* Source: (USGS 1990)

For example, the Mississippi River provides source water for cooling water for 57 facilities along its

length, 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 occur on a six-mile stretch of the

river. Four of these facilities, with a combined DIF exceeding 5 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 may likely underestimate the true effects.

2.5.2 Implications of Clustered Facilities for Cumulative Impacts

The cumulative impact of clustered facilities may be significant, due to the concentrated I&E mortality,

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 is typically at its 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 CWISs.

 Freshwater plants 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
March 28, 2011 2-19

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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 river (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 I&E Mortality Impacts

While the information provided in this chapter provides a broad overview of potential impacts associated

with CWISs, it is highly informative to evaluate these impacts in the context of actual facilities to see how

and to what extent these impacts and I&E mortality 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 I&E mortality and major stressors in the

context of a specific waterbody or region.

As part of the Phase II regulations, review and analyses of I&E mortality data and environmental

information was presented in case studies in EPA’s 2002 Case Study Analysis for the Proposed Section

316(b) Phase II Existing Facilities Rule. The document provided detailed analyses of CWIS impacts in

major regional waterbodies throughout the U.S. These cases studies included:

 Delaware Estuary Watershed

 Ohio River Watershed

 Tampa Bay Watershed

 San Francisco Bay/Delta Estuary

 Brayton Point Facility

 Seabrook and Pilgrim Facilities

 J.R. Whiting Facility

 Monroe Facility

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 I&E

mortality, the indirect effects of I&E mortality on local aquatic ecosystems, and the cumulative effects of

combined effects (I&E mortality and thermal). Additional information is available each of these

examples.

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
March 28, 2011 2-20

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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 plant via a shoreline surface CWIS. Approximately 749

million gallons per day (MGD) is 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 I&E mortality and thermal impacts.

In addition to I&E mortality 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 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 plant and required the plant 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.

Due to concerns regarding impact to fish, particularly anadromous striped bass populations, as well as a

high level of involvement and litigation from local stakeholder groups, the Indian Point power generation

plant (along with other Hudson River power plants) has been particularly well-characterized in terms of

I&E mortality 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 I&E mortality 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 I&E mortality 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

Bay Shore Power Station I&E Mortality Losses: 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 plant does not currently employ any technologies to

reduced I&E mortality (OEPA 2010).
March 28, 2011 2-21

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

levels of mortality “could seriously deplete any resilience or compensatory capacity of the species needed

to survive unfavorable environmental conditions” (USEPA 2004a).

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 plants, invasions by exotic species (e.g., zebra mussel), chemical

contamination by toxins (e.g., PCBs and heavy 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 2004a).

Recently (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 I&E mortality including potential impacts to two

sensitive species—the Shortnose Sturgeon (currently listed as endangered) and the Atlantic Sturgeon

(under consideration for endangered species status).

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 steamelectric 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 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 the average annual entrainment losses from these plants 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.

Indian River Power Plant has impact on important local species:

The 2003 316(b) Comprehensive Demonstration Study for the Indian River Power Plant reported

I&E mortality for a number of important species (Entrix 2003, as described in Bason 2008). This

I&E mortality has been recalculated by a local stakeholder group as age-1 equivalents for bay

anchovy (1.6 million), blue crab (300,000), croaker (270,000), and menhaden (60,000) (Bason 2008).
March 28, 2011 2-22

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Due to the size of the heated discharge relative to the receiving water, thermal effects of the plant were

also investigated. Based upon monitoring data collected from 1998-1999, 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, there were 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 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 CWISs and I&E mortality (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 has allowed EPA to monetize the

potential environmental benefits that would arise as reduction in water withdrawals occur based of future

316(b) regulations.

However, as demonstrated in this section, there is much less information and high uncertainty regarding

the magnitude and importance of indirect and/or cumulative impacts of CWISs, 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 CWISs 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 CWISs are significantly underestimated, and that characterization

of the fuller spectrum of benefits arising from reducing or eliminating I&E mortality will await future,

targeted research efforts.
March 28, 2011 3-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

3 Assessment of Impingement and Entrainment Mortality

3.1 Introduction

This chapter discusses the methods EPA used to convert results from impingement and entrainment

mortality (I&E mortality) sampling studies into metrics suitable as inputs for EPA’s Section 316(b)

benefits analysis.5Section 3.2 provides a brief overview of impingement and entrainment (I&E) loss

metrics, and outlines how they were used in benefits analysis. Section 3.3 presents I&E mortality losses,

by region, under baseline conditions, and the reductions in these losses under alternative regulatory

options. Section 3.4 discusses limitations and uncertainties in the I&E mortality analysis.

EPA’s I&E mortality 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

I&E mortality 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 in-scope

generators, and (3) changes in the proportionate reduction in I&E mortality under new regulatory options

were estimated. Other modifications are identified in relevant portions of Section 3.2.

3.2 Methods

3.2.1 Objectives of I&E Mortality Analysis

EPA’s evaluation of I&E mortality data had four main objectives:

 To develop regional and national estimates of the magnitude of I&E mortality

 To standardize I&E mortality rates using common biological metrics that allow comparison

across species, years, facilities, and geographical regions

 To provide I&E mortality metrics suitable for use in national economic benefits analysis

 To estimate changes in metrics as a result of estimated reductions in I&E mortality under

alternative regulatory options.

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.

5

For the purposes of its national analysis, EPA assumed 100 percent impingement mortality and 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 2004b). 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.
March 28, 2011 3-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

3.2.2 I&E Mortality Loss Metrics

Three loss metrics were derived from facility I&E mortality monitoring data available to EPA: (1) age-1

equivalents, (2) forgone fishery yield, and (3) production forgone. These metrics are described 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-1 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 I&E mortality losses into equivalent numbers of 1-year-old fish, a value

termed age-1 equivalents (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 I&E mortality

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 stagespecific survival rates between the stage at which I&E mortality 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 I&E mortality studies.

3.2.2.2 Forgone Fishery Yield of Commercial and Recreational Species

Fishery yield is a measure of the biomass harvested from a cohort of fish.6 EPA expressed I&E mortality

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). EPA’s application of the

Thompson-Bell model assumed that 1) I&E mortality losses reduce the future yield of harvested adults,

and 2) reductions in I&E mortality rates 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

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 I&E mortality losses 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).

6 A cohort of fish refers to fish produced in the same year, also referred to as a year-class of fish.
March 28, 2011 3-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

3.2.3 Valuation Approach

EPA’s benefits analysis focused on increased commercial and recreational fishery harvests estimated

from projected reductions in I&E mortality losses. For consistency with reported harvest data,

commercial harvest is 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 I&E mortality: 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 losses 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).7 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 for Valuation of I&E mortality losses

EPA’s approach to estimating changes in fish harvest assumed that I&E mortality losses result in a

reduction in the number of harvestable adults, and that I&E mortality reductions result in increases to

future fish harvests. This approach estimates incremental fishery yield forgone because of I&E mortality

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 I&E mortality rates 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 foregone yield, EPA was able to use a simple and direct measure of the

potential economic value associated with each I&E-related death. EPA believes that 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 Harvested Species

EPA’s overall objective was to develop regional- and national-scale estimates of the magnitude of I&E

mortality at hundreds of facilities that are in the scope of the proposed rule nationwide. 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 I&E mortality on a

7 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.
March 28, 2011 3-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

national scale. Although sufficient data may exist to model the effects of I&E mortality on population and

community-level impacts, sufficient data do not exist at the national scale to make such studies feasible.

Figure 3-1: General Approach Used to Evaluate I&E Mortality Losses 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 I&E mortality. 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, stockI&E Mortality

Losses

Convert to

Age-1

Equivalents

Convert to

Production

Forgone

Convert to

Forgone Fishery

Yield

Convert to

Forgone Fishery

Yield

Total

Forgone Fishery

Yield

Commercial

Harvest

(pounds)

Recreational

Harvest

(# of fish)

Fishery

Species

Forage

Species

Trophic

Transfer

Sum

Monetize

(Chapter 6)

Monetize

(Chapter 7)

Commercial

Fraction

Recreational

Fraction
March 28, 2011 3-5

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

recruitment 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 2010b). 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 I&E mortality.

 Numerous difficulties exist in the definition of the size and spatial extent of fish stocks. As a

result, it is often unclear how I&E mortality losses at particular cooling water intake structures

(CWISs) 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 I&E mortality on

recruitment rates would not be sufficient to understand the stock-recruitment relationship for

Delaware Bay menhaden.

Consequently, due to issues of data availability and difficulties estimating the effects of localized I&E

mortality on regional-scale fish stocks, EPA determined that the construction of population models for all

species subject to I&E mortality 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 defend 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 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 I&E Mortality to Develop Regional Estimates

EPA examined I&E mortality losses and the economic benefits of reducing these losses at a regional

scale. Estimated benefits were then aggregated 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 I&E mortality estimates, EPA extrapolated losses observed at 97 facilities with I&E

mortality data (hereafter model facilities) to all in-scope facilities within the same region. Extrapolation of

I&E mortality rates was necessary because only a subset of all in-scope facilities have conducted I&E

mortality studies. To allow extrapolation, EPA assumed that all facilities, regardless of size, have similar

I&E mortality rates after normalization by flow. I&E mortality 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. Operational flow at all facilities was scaled using a

multiplicative factor that reflected the effectiveness of in-place technologies used to reduce I&E

mortality. During the extrapolation procedure, EPA also applied weighting factors to in-scope facilities
March 28, 2011 3-6

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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 I&E mortality is proportional to flow is consistent with other published I&E

mortality studies and models. Power plants on the Great Lakes exhibit an increasing relationship (on a

log-log scale) between plant size (measured as electrical output) and I&E mortality 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 tool for assessing potential I&E mortality impacts at Chesapeake Bay facilities, assumes

that entrainment is proportional to cooling water withdrawal rates (Polgar et al. 1979).

EPA recognizes that there may be substantial variability in actual I&E mortality losses per MGD 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 I&E mortality rates recorded at model facilities are representative of I&E mortality 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.

EPA believes that its 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 I&E mortality, and the associated

benefits of I&E mortality reduction. While acknowledging that extrapolation introduces uncertainty into

I&E mortality estimates, EPA has not identified information suggesting a systematic bias in regional loss

estimates based upon extrapolation.

3.3 I&E Mortality Losses By Region

3.3.1 California Region

Estimated baseline I&E mortality, and estimated reductions to I&E mortality under the three regulatory

options are presented in Table 3-1 and Table 3-2. Estimated total baseline I&E mortality losses in the

California region are 36.83 million A1Es per year, of which 17.56 million (47 percent) are forage fish.

Approximately 5.59 percent of total baseline A1E losses are assigned a direct use value from recreational

or commercial fishing (Table 3-1). Table C-1of Appendix C presents species-specific data on

impingement and entrainment losses 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 I&E mortality in the California region occur due to entrainment (Appendix Table C-1).

Because Option 1 does not reduce entrainment losses in the majority of facilities, it reduces baseline I&E

mortality of A1E by only 1.9 percent (Table 3-1). Conversely, by requiring the installation of closed-cycle

cooling towers, which effectively reduce entrainment mortality, Options 2 and 3 reduce A1E losses by

85.5 and 89.4 percent, respectively, providing over 40 times the reduction in A1E losses (Table 3-1).
March 28, 2011 3-7

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 3-1: Summary of Baseline I&E Mortality Losses at All In-scope Facilities

(Manufacturing and Generating) in California, and Reductions Under Option

Scenarios

IM&EM Loss Metric (per year) Option 1 Option 2 Option 3

All Species (million A1E) 36.83 0.69 31.50 32.92

Forage Species (million A1E) 17.56 0.18 14.99 15.67

Commercial & Recreational Species (million A1E) 19.28 0.52 16.51 17.25

Commercial & Recreational Harvest (million fish) 2.06 0.06 1.76 1.84

A1E Losses with Direct Use Value (%) 5.59 7.96 5.60 5.60

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Production foregone due to baseline I&E mortality is estimated to be 14.05 million pounds of fish,

leading to a decrease in fishery yield of more than 3.28 million pounds per year (Table 3-2). Option 1 is

estimated to result in increased fishery yields of 0.02 million pounds per year. Under Options 2 and 3,

however, estimated increases to fishery yields are more than 100 times greater, at 2.80 and 2.93 million

pounds per year, respectively (Table 3-2).

Table 3-2: Baseline Losses in Fishery Yield, Catch, and Production

Forgone as a Consequence of I&E Mortality at All In-scope Facilities

(Manufacturing and Generating) in California, and Reductions Under

Option Scenarios

IM&E Loss Metric (million per year) Option 1 Option 2 Option 3

Foregone Fishery Yield (lbs) 3.28 0.02 2.80 2.93

Foregone Commercial Catch (lbs) 1.38 <0.01 1.18 1.23

Foregone Recreational Catch (fish) 1.02 0.04 0.88 0.92

Production Foregone (lbs) 14.05 0.10 11.99 12.54

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I

Everywhere and E for Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Raw numbers of I&E mortality losses in California can be found in Appendix Table C-2.

3.3.2 North Atlantic Region

Estimated baseline I&E mortality, and estimated reductions to I&E mortality under the three regulatory

options are presented in Table 3-3 and Table 3-4. Estimated total baseline I&E mortality losses in the

North Atlantic region are 60.00 million A1Es per year, 78 percent of which are forage fish.

Approximately 2.06 percent of total baseline A1E losses are assigned a direct use value from recreational

or commercial fishing (Table 3-3). Table C-3 of Appendix C presents species-specific data on

impingement and entrainment losses under the baseline conditions and estimated reductions under all

options. Briefly, the vast majority (99 percent) of all A1E losses in the North Atlantic occur as a

consequence of entrainment mortality (Appendix Table C-3). Notably, the combined I&E mortality of

winter flounder, cunner, and sculpins account for 97 percent of all I&E mortality of commercially and

recreationally-harvested species.
March 28, 2011 3-8

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Because Option 1 does not reduce entrainment losses, it reduces baseline I&E mortality A1E losses by

less than 1 percent (Table 3-3). Conversely, by requiring the installation of closed-cycle cooling towers,

which effectively reduce entrainment mortality, Options 2 and 3 reduce A1E losses by 81.7 and 85.7

percent, respectively, providing more than 100 times the benefits of Option 1 by A1E (Table 3-3).

Table 3-3: Baseline I&E Mortality Losses and I&E Mortality Reductions at All Inscope Facilities (Manufacturing and Generating) in the North Atlantic, and

Reductions Under Option Scenarios

IM&EM Loss Metric (per year) Option 1 Option 2 Option 3

All Species (million A1E) 60.00 0.43 49.02 51.40

Forage Species (million A1E) 47.02 0.38 38.42 40.29

Commercial & Recreational Species (million A1E) 12.98 0.06 10.60 11.11

Commercial & Recreational Harvest (million fish) 1.23 <0.01 1.01 1.06

A1E Losses with Direct Use Value (%) 2.06 1.52 2.06 2.06

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Production foregone due to baseline I&E mortality is estimated to be 26.99 million pounds of fish,

leading to a decrease in fishery yield of 1.02 million pounds per year (Table 3-4). Option 1 is estimated to

result in increased fishery yields of less than 0.01 million pounds per year. Under Options 2 and 3,

however, estimated increases to fishery yields are more than 100 times greater, at 0.83 and 0.87 million

pounds per year, respectively (Table 3-4).

Table 3-4: Baseline Losses in Fishery Yield, Catch, and Production

Forgone as a Consequence of I&E Mortality at All In-scope Facilities

(Manufacturing and Generating) in the North Atlantic, and Reductions

Under Option Scenarios

IM&E Loss Metric (million per year) Option 1 Option 2 Option 3

Foregone Fishery Yield (lbs) 1.02 <0.01 0.83 0.87

Foregone Commercial Catch (lbs) 0.45 <0.01 0.37 0.39

Foregone Recreational Catch (fish) 0.76 <0.01 0.62 0.65

Production Foregone (lbs) 26.99 0.03 22.01 23.09

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I

Everywhere and E for Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Raw numbers of I&E mortality losses in the North Atlantic can be found in Appendix Table C-4.

3.3.3 Mid-Atlantic

Estimated baseline I&E mortality, and estimated reductions to I&E mortality under the three regulatory

options are presented in Table 3-5 and Table 3-6. Estimated total baseline I&E mortality losses in the

Mid-Atlantic region are 990.06 million A1Es per year, including 751.07 million A1Es of forage fish (75.9

percent). Approximately 3.11 percent of total baseline A1E losses are assigned a direct use value from

recreational or commercial fishing (Table 3-5). Table C-5 of Appendix C presents species-specific data
March 28, 2011 3-9

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

on impingement and entrainment losses under the baseline conditions and estimated reductions under all

options. Briefly, the vast majority (95 percent) of all A1E losses in the Mid-Atlantic occur as a

consequence of entrainment mortality. Nearly half (45.9 percent) of the I&E mortality estimated for

commercially- and recreationally-harvested species occurs in Blue Crab, and substantial I&E mortality

(i.e., greater than 20 million A1E) is estimated for Atlantic Croaker, Atlantic Menhaden, Spot, and White

Perch.

Because of the high proportion of I&E mortality losses attributed to entrainment mortality, it is estimated

that Options 2 and 3 will reduce I&E mortality by 91.9 and 93.0 percent, respectively (Table 3-5).

Conversely, Option 1 is projected to reduce I&E mortality by approximately 3.9 percent, more than 20

times smaller than the reductions estimated to occur under Options 2 and 3.

Table 3-5: Baseline I&E Mortality Losses and I&E Mortality Reductions at All Inscope Facilities (Manufacturing and Generating) in the Mid-Atlantic, and

Reductions Under Option Scenarios

IM&EM Loss Metric (per year) Option 1 Option 2 Option 3

All Species (million A1E) 990.06 38.69 909.74 920.90

Forage Species (million A1E) 751.07 14.27 688.96 697.59

Commercial & Recreational Species (million A1E) 238.98 24.42 220.78 223.31

Commercial & Recreational Harvest (million fish) 30.77 6.09 28.66 28.95

A1E Losses with Direct Use Value (%) 3.11 15.75 3.15 3.14

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

The I&E mortality model projects that baseline I&E mortality results in 80.73 million pounds of foregone

production, and decreases fishery yield by 22.53 million pounds per year (Table 3-6). Option 1 is

estimated to result in increased fishery yields of 5.40 million pounds per year. Under Options 2 and 3,

increased fishery yields are 21.01 and 21.22 million pounds per year, respectively (Table 3-6).

Table 3-6: Baseline Losses in Fishery Yield, Catch, and Production

Forgone as a Consequence of I&E Mortality at All In-scope Facilities

(Manufacturing and Generating) in the Mid-Atlantic, and Reductions

Under Option Scenarios

IM&E Loss Metric (million per year) Option 1 Option 2 Option 3

Foregone Fishery Yield (lbs) 22.53 4.73 21.01 21.22

Foregone Commercial Catch (lbs) 11.59 3.75 10.91 11.01

Foregone Recreational Catch (fish) 9.08 0.55 8.36 8.46

Production Foregone (lbs) 80.73 10.16 74.73 75.56

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I

Everywhere and E for Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Raw numbers of I&E mortality losses in the Mid-Atlantic region can be found in Appendix Table C-6.
March 28, 2011 3-10

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

3.3.4 South Atlantic Region

Estimated baseline I&E mortality, and estimated reductions to I&E mortality under the three regulatory

options are presented in Table 3-7 and Table 3-8. Estimated total baseline I&E mortality losses in the

South Atlantic region are estimated to be 33.40 million A1Es per year, including 31.22 million forage fish

A1Es. Approximately 1.03 percent of total baseline A1E losses are assigned a direct use value from

recreational or commercial fishing (Table 3-7). Table C-7 of Appendix C presents species-specific data

on impingement and entrainment losses under the baseline conditions and estimated reductions under all

options. Unlike other regions, the majority (67 percent) of all A1E losses in the South Atlantic occur as a

consequence of impingement mortality. Among commercially- and recreationally-harvested species, I&E

mortality is greatest in Drums and Croakers and Blue Crab.

Due to the high proportion of I&E mortality lost to impingement, Option 1 is projected to reduce I&E

mortality by 42.5 percent. However, because the installation of closed-cycle cooling towers reduces water

usage, Options 2 and 3 are projected to reduce I&E mortality by approximately 84.6 and 84.7 percent

(Table 3-7), approximately double the estimated reductions of Option 1.

Table 3-7: Baseline I&E Mortality Losses and I&E Mortality Reductions at All Inscope Facilities (Manufacturing and Generating) in the South Atlantic, and

Reductions Under Option Scenarios

IM&EM Loss Metric (per year) Option 1 Option 2 Option 3

All Species (million A1E) 33.40 14.20 28.28 28.30

Forage Species (million A1E) 31.22 13.43 26.43 26.45

Commercial & Recreational Species (million A1E) 2.19 0.77 1.85 1.85

Commercial & Recreational Harvest (million fish) 0.35 0.11 0.29 0.29

A1E Losses with Direct Use Value (%) 1.03 0.75 1.03 1.03

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Production foregone due to baseline I&E mortality is estimated to be 0.86 million pounds per year,

leading to a decrease in fishery yield of approximately 0.16 million pounds per year. Option 1 is

estimated to result in increased fishery yields of 0.05 million pounds per year. Under Options 2 and 3,

however, estimated increases to fishery yields are more than 2 times greater, at 0.13 and 0.13 million

pounds per year, respectively (Table 3-8).

Table 3-8: Baseline Losses in Fishery Yield, Catch, and Production

Forgone as a Consequence of I&E Mortality at All In-scope Facilities

(Manufacturing and Generating) in the South Atlantic, and Reductions

Under Option Scenarios

IM&E Loss Metric (million per year) Option 1 Option 2 Option 3

Foregone Fishery Yield (lbs) 0.16 0.05 0.13 0.13

Foregone Commercial Catch (lbs) 0.10 0.05 0.08 0.08

Foregone Recreational Catch (fish) 0.13 0.02 0.11 0.11

Production Foregone (lbs) 0.86 0.14 0.72 0.72

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I

Everywhere and E for Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses
March 28, 2011 3-11

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Raw numbers of I&E mortality losses in the South Atlantic region can be found in Appendix Table C-8.

3.3.5 Gulf of Mexico

Estimated baseline I&E mortality, and estimated reductions to I&E mortality under the three regulatory

options are presented in Table 3-9 and Table 3-10. Estimated total baseline I&E mortality losses in the

Gulf of Mexico are estimated to be 135.64 million A1Es per year, including 47.75 million forage fish

A1Es. Approximately 8.56 percent of total baseline A1E losses are assigned a direct use value from

recreational or commercial fishing (Table 3-9). Table C-9 of Appendix C presents species-specific data

on impingement and entrainment losses under the baseline conditions and estimated reductions under all

options. The majority (67 percent) of all A1E losses in the Gulf of Mexico occur as a consequence of

entrainment mortality. Among commercially- and recreationally-harvested species, I&E mortality is

greatest in Blue Crab, and Pink Shrimp, which together account for 68 percent of A1E losses with direct

use value. Other fish species with substantial I&E mortality (i.e., greater than 5 million A1E) include

Black Drum, Menhaden, and Silver Perch (Appendix Table C-9).

Due to the low proportion of I&E mortality lost to impingement, Option 1 is projected to reduce I&E

mortality by only 25.4 percent. In contrast, Options 2 and 3 are projected to reduce I&E mortality by 78.2

and 78.3 percent, respectively (Table 3-9), approximately triple the estimated reductions of Option 1.

Table 3-9: Baseline I&E Mortality Losses and I&E Mortality Reductions at All Inscope Facilities (Manufacturing and Generating) in the Gulf of Mexico, and

Reductions Under Option Scenarios

IM&EM Loss Metric (per year) Option 1 Option 2 Option 3

All Species (million A1E) 135.64 34.50 106.02 106.21

Forage Species (million A1E) 47.75 4.31 34.09 34.16

Commercial & Recreational Species (million A1E) 87.89 30.19 71.94 72.05

Commercial & Recreational Harvest (million fish) 11.61 4.59 9.75 9.76

A1E Losses with Direct Use Value (%) 8.56 13.29 9.20 9.19

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Production foregone due to baseline I&E mortality is estimated to be 76.06 million pounds per year, 43

percent of which is foregone fishery yield. Option 1 is estimated to reduce foregone fishery yields by 2.99

million pounds, while Options 2 and 3 are estimated to reduce foregone fishery yields by 23.43 and 23.48

million pounds, respectively (Table 3-10).

Raw numbers of I&E mortality losses in the Gulf of Mexico can be found in Appendix Table C-10.
March 28, 2011 3-12

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 3-10: Baseline Losses in Fishery Yield, Catch, and Production

Forgone as a Consequence of I&E Mortality at All In-scope Facilities

(Manufacturing and Generating) in the Gulf of Mexico, and

Reductions Under Option Scenarios

IM&E Loss Metric (million per year) Option 1 Option 2 Option 3

Foregone Fishery Yield (lbs) 32.81 2.99 23.43 23.48

Foregone Commercial Catch (lbs) 5.56 1.46 4.36 4.37

Foregone Recreational Catch (fish) 2.85 0.67 2.20 2.21

Production Foregone (lbs) 76.06 5.77 53.84 53.96

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I

Everywhere and E for Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

3.3.6 Great Lakes Region

Estimated baseline I&E mortality, and estimated reductions to I&E mortality under the three regulatory

options are presented in Table 3-11 and Table 3-12. Estimated total baseline I&E mortality losses in the

Great Lakes are 53.50 million A1Es per year, including 46.46 million A1E of forage fish. Approximately

1.50 percent of total baseline A1E losses are assigned a direct use value from recreational or commercial

fishing (Table 3-11). Table C-11 of Appendix C presents species-specific data on impingement and

entrainment losses under the baseline conditions and estimated reductions under all options. Briefly,

among commercially and recreationally-harvested species, the greatest losses occur in Smelts and

Sunfish.

The vast majority (83 percent) of I&E mortality losses in the Great Lakes occur due to impingement

(Appendix Table C-11). Accordingly, Option 1 reduces baseline A1E I&E mortality by 71.5 percent

(Table 3-11). By requiring the installation of closed-cycle cooling towers, which reduce the volume of

water required for cooling purposes, Options 2 and 3 reduce A1E losses by 95.7 and 96.0 percent,

respectively (Table 3-11).

Table 3-11: Baseline I&E Mortality Losses and I&E Mortality Reductions at All Inscope Facilities (Manufacturing and Generating) in the Great Lakes, and

Reductions Under Option Scenarios

IM&EM Loss Metric (per year) Option 1 Option 2 Option 3

All Species (million A1E) 53.50 38.23 51.13 51.35

Forage Species (million A1E) 46.46 33.46 44.46 44.64

Commercial & Recreational Species (million A1E) 7.04 4.77 6.67 6.70

Commercial & Recreational Harvest (million fish) 0.80 0.49 0.75 0.75

A1E Losses with Direct Use Value (%) 1.50 1.28 1.47 1.47

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Production foregone due to baseline I&E mortality is estimated to be 32.02 million lbs of fish, leading to

a decrease in fishery yield of 0.70 million pounds per year (Table 3-12). Option 1 is estimated to result in

increased fishery yields of 0.42 million pounds per year. Under Options 2 and 3, however, estimated
March 28, 2011 3-13

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

increases to fishery yields are approximately 50 percent greater, at 0.65 and 0.65 million pounds per year,

respectively (Table 3-12).

Table 3-12: Baseline Losses in Fishery Yield, Catch, and Production

Forgone as a Consequence of I&E Mortality at All In-scope Facilities

(Manufacturing and Generating) in the Great Lakes, and Reductions

Under Option Scenarios

IM&E Loss Metric (million per year) Option 1 Option 2 Option 3

Foregone Fishery Yield (lbs) 0.70 0.42 0.65 0.65

Foregone Commercial Catch (lbs) 0.35 0.23 0.33 0.33

Foregone Recreational Catch (fish) 0.35 0.18 0.32 0.32

Production Foregone (lbs) 32.02 7.34 27.19 27.49

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I

Everywhere and E for Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Raw numbers of I&E mortality losses in the Great Lakes region can be found in Appendix Table C-12.

3.3.7 Inland Region

Estimated baseline I&E mortality, and estimated reductions to I&E mortality under the three regulatory

options are presented in Table 3-13 and Table 3-14. Estimated total baseline I&E mortality losses in the

Inland region are 879.49 million A1Es per year, including 713.71 million A1E of forage fish.

Approximately 1.43 percent of total baseline A1E losses are assigned a direct use value from recreational

or commercial fishing (Table 3-13). Table C-13 of Appendix C presents species-specific data on

impingement and entrainment losses under the baseline conditions and estimated reductions under all

options. Briefly, the majority (66.4 percent) of all A1E losses in the Inland region occur as a consequence

of impingement mortality (Appendix Table C-13). Notably, the I&E mortality of sunfish account for 78.4

percent of the I&E mortality of commercially and recreationally-harvested species.

Option 1 reduces baseline I&E mortality A1E losses by 55.5 percent (Table 3-13). The installation of

closed-cycle cooling towers under Options 2 and 3 reduce A1E losses by 91.6 and 93.5 percent,

respectively, providing a benefit more than 60 percent larger than the benefits of Option 1 (Table 3-13).

Table 3-13: Baseline I&E Mortality Losses and I&E Mortality Reductions at All Inscope Facilities (Manufacturing and Generating) in the Inland Region, and

Reductions Under Option Scenarios

IM&EM Loss Metric (per year) Option 1 Option 2 Option 3

All Species (million A1E) 879.49 488.22 805.86 822.46

Forage Species (million A1E) 713.71 459.64 665.29 676.63

Commercial & Recreational Species (million A1E) 165.78 28.59 140.57 145.83

Commercial & Recreational Harvest (million fish) 12.59 4.32 11.06 11.39

A1E Losses with Direct Use Value (%) 1.43 0.89 1.37 1.38

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses
March 28, 2011 3-14

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

The decrease in production due to baseline I&E mortality is estimated to be 407.08 million pounds of

fish, leading to a decrease in fishery yield of 11.01 million pounds per year (Table 3-14). Option 1 is

estimated to result in increased fishery yields of 3.77 million pounds per year. Under Options 2 and 3,

however, estimated increases to fishery yields are more than two times greater, at 9.67 and 9.96 million

pounds per year, respectively (Table 3-14).

Table 3-14: Baseline Losses in Fishery Yield, Catch, and Production

Forgone as a Consequence of I&E Mortality at All In-scope Facilities

(Manufacturing and Generating) in the Inland Region, and Reductions

Under Option Scenarios

IM&E Loss Metric (million per year) Option 1 Option 2 Option 3

Foregone Fishery Yield (lbs) 11.01 3.77 9.67 9.96

Foregone Commercial Catch (lbs) <0.01 <0.01 <0.01 <0.01

Foregone Recreational Catch (fish) 12.59 4.32 11.06 11.39

Production Foregone (lbs) 407.08 102.90 351.01 362.84

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I

Everywhere and E for Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Raw numbers of I&E mortality losses in the Inland region can be found in Appendix Table C-14.

3.3.8 National Estimates

Estimated baseline I&E mortality, and estimated reductions to I&E mortality under the three regulatory

options are presented in Table 3-15 and Table 3-16. Estimated total baseline I&E mortality losses

nationally are 2,188.92 million A1Es per year, including 1,654.78 million A1E of forage fish.

Approximately 2.71 percent of total baseline A1E losses are assigned a direct use value from recreational

or commercial fishing (Table 3-15). Table C-13 of Appendix C presents species-specific data on

impingement and entrainment losses under the baseline conditions and estimated reductions under all

options. Briefly, the majority (65.8 percent) of all A1E losses nationally occur as a consequence of

entrainment mortality (Appendix Table C-13).

Option 1 reduces baseline I&E mortality A1E losses by 28.1 percent (Table 3-15). The installation of

closed-cycle cooling towers under Options 2 and 3 reduce A1E losses by 90.5 and 92.0 percent,

respectively, providing a benefit approximately three times larger than the benefits of Option 1 (Table

3-15).
March 28, 2011 3-15

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 3-15: Baseline I&E Mortality Losses and I&E Mortality Reductions at All Inscope Facilities (Manufacturing and Generating) Nationally, and Reductions

Under Option Scenarios

IM&EM Loss Metric (per year) Option 1 Option 2 Option 3

All Species (million A1E) 2188.92 614.97 1981.55 2013.55

Forage Species (million A1E) 1654.78 525.66 1512.64 1535.44

Commercial & Recreational Species (million A1E) 534.15 89.31 468.91 478.11

Commercial & Recreational Harvest (million fish) 59.41 15.66 53.28 54.05

A1E Losses with Direct Use Value (%) 2.71 2.55 2.69 2.68

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

The decrease in production due to baseline I&E mortality is estimated to be 637.78 million pounds of

fish, leading to a decrease in fishery yield of 71.50 million pounds per year (Table 3-16). Option 1 is

estimated to result in increased fishery yields of 11.99 million pounds per year. Under Options 2 and 3,

however, estimated increases to fishery yields are more than four times greater, at 58.52 and 59.24 million

pounds per year, respectively (Table 3-16).

Table 3-16: Baseline Losses in Fishery Yield, Catch, and Production

Forgone as a Consequence of I&E Mortality at All In-scope Facilities

(Manufacturing and Generating) Nationally, and Reductions Under

Option Scenarios

IM&E Loss Metric (million per year) Option 1 Option 2 Option 3

Foregone Fishery Yield (lbs) 71.50 11.99 58.52 59.24

Foregone Commercial Catch (lbs) 19.43 5.49 17.23 17.41

Foregone Recreational Catch (fish) 26.79 5.77 23.55 24.06

Production Foregone (lbs) 637.78 126.44 541.48 556.20

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I

Everywhere and E for Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Raw numbers of national I&E mortality losses can be found in Appendix Table C-16.

3.4 Limitations and Uncertainties

There are four major kinds of uncertainty that may lead to imprecision and bias in EPA’s I&E mortality

analysis: data, structural, statistical, and engineering uncertainty. Data limitations and uncertainty refers to

uncertainty and inconsistency in sampling methodologies used in facility-specific I&E mortality 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 identically on an annual basis.

3.4.1 Data Limitation and Uncertainty

Quantification of regional and national I&E mortality losses is based 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
March 28, 2011 3-16

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

trends of I&E mortality at regional and national scales (and of the accompanying ecological benefits upon

mitigation) must consider the strengths and weaknesses of this data.

The I&E mortality data from model facilities constitute a heterogeneous composite of results from many

facility-specific studies. Sampling effort and data quality control vary tremendously among I&E mortality

studies and baseline source water characterization programs. While there is broad EPA guidance as to the

overall objectives and requirements for facility-specific data collection, 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,

characterization of reference areas, etc. In addition to different sampling methods and timing, some

sampling programs are designed primarily to estimate I&E mortality losses 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 I&E mortality 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 preoperational (i.e., baseline) samples or community surveys to compare to the results of more-current I&E

mortality data. Finally, few I&E mortality studies are designed to allow evaluation of community impacts

or ecosystem effects (Section 2.4).

Within regions, studies of I&E mortality from model facilities are typically composed of data from a

relatively limited number of facilities. Most facility-specific I&E mortality 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) 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 I&E

mortality impacts.

3.4.2 Structural Uncertainty

The models EPA used to evaluate I&E mortality 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).

EPA recognizes these uncertainties, but believes that 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 timeconsuming and resource-intensive to develop, and would lead to greater parameter uncertainty (Section

3.4.3).
March 28, 2011 3-17

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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 I&E mortality 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 not

addressed

Fish species grouped into two categories: harvested or not harvested (i.e.,

forage for harvested species). Only commercial and recreational harvests

are assigned monetary values at the national level. Nonuse values of I&E

mortality is estimated for the North Atlantic and Mid-Atlantic regions only.

Fishing pressure constant The valuation procedure assumes that fisheries harvests will increase

proportionately to decreases in I&E mortality losses, 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. All parameters must be estimated 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 I&E mortality rates are driven by a combination

of intake flow and the presence of vulnerable fish, actual I&E mortality cannot remain constant through

time.

True values of biological parameters and facility I&E mortality vary geographically. Biological

parameters may vary substantially within regions due to changes in substrate, water temperature and

salinity, etc., while facility I&E mortality data may be strongly connected to local substrates, distance

from shore, depth, etc. It follows, then, that using biological data and extrapolating facility-specific I&E

mortality 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 from a much larger

dataset. Biological parameters such as mortality rates must be estimated using incomplete sampling data.

Facility-reported I&E mortality 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 I&E mortality 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
March 28, 2011 3-18

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

studies were conducted. In some cases, the state of the waterbody itself has changed substantially since

sampling was conducted.

EPA recognizes many sources of parameter uncertainty in its models (Table 3-18), all of which lead to

uncertainty in point estimates of I&E mortality losses. The nature of these uncertainties, however, does

not inherently bias the point estimate. EPA believes that all biological and physical parameters were

reported 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, EPA believes that parameter uncertainty

has resulted in imprecision rather than inaccuracy in model output.8

3.4.4 Engineering Uncertainty

EPA’s evaluation of I&E mortality was also affected by uncertainty about the engineering and operating

characteristics of the study facilities. It is unlikely that plant 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 I&E mortality, 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.

8

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.
March 28, 2011 3-19

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 3-18: Parameters Included in EPA’s I&E Mortality Analysis Subject to Uncertainty

Model Aspect Parameter Description

Sampling regimes Sampling regimes are subject to numerous plant-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 I&E mortality 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 I&E mortality 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 I&E mortality studies are not

well-defined nor uniform across facilities. At many facilities, I&E mortality

data was collected for only a subset of species, usually only fish and shellfish.

I&E mortality

monitoring /loss rate

estimates

Sensitivity of fish to

I&E mortality

Entrainment mortality was assumed by EPA to be 100%. Back-calculations

were done in cases where facilities reported entrainment rates that assumed

<100% 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.

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; I&E mortality occurring during spawning runs or larval

out-migration; location of harvestable adults; intermingling with other stocks.

Biological/life

history

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.

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).

Fish stock

characteristics

Stock interactions I&E mortality losses 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.

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 I&E mortality

(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 I&E mortality (e.g., presence of larvae

in vicinity of CWIS).

Ecological

system

Meteorology Sampled years assumed to be typical with respect to vulnerability to I&E

mortality (e.g., presence of larvae in vicinity of intake structure).
March 28, 2011 4-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

4 Economic Benefit Categories Associated with I&E Mortality

Reduction

Changes in CWIS design or operations resulting from the regulatory options for the proposed Section

316(b) regulation for in-scope facilities are expected to increase the numbers of aquatic organisms present

and increase local and regional fishery populations. They will do this by reducing impingement and

entrainment (I&E) mortality of fish, shellfish, and other aquatic organisms.

The aquatic organisms affected by CWISs 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 impingement and entrainment mortality (I&E mortality) 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

provided detail on potential CWIS impacts on aquatic ecosystems. Due to a lack of data, many of these

impacts could not be successfully evaluated or monetized.

4.1 Economic Benefit Categories Applicable to the Regulatory Options for InScope Facilities

The economic benefits of reducing I&E mortality at in-scope 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 I&E mortality is benefits to commercial fisheries. Changes in I&E

mortality will directly affect the price, quantity, and/or quality of fish harvests; and 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.

 Market direct use benefits: Market direct use benefits are benefits related to goods directly

used, and bought and sold in markets; for example, fish caught for sale to consumers.

 Market indirect use benefits: Indirect use benefits are those that contribute indirectly to an

increase in welfare for users of the resource. Market indirect use benefits are benefits that
March 28, 2011 4-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

occur through indirect or secondary effects on marketed goods. 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 I&E mortality of forage species can

indirectly result in 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 I&E mortality. Higher catch rates

for recreational fishing are an obvious nonmarket benefit. Anglers place a high value on catching

fish during their fishing trips, so higher catch rates from reduced I&E mortality 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: Nonmarket direct use 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: Nonmarket indirect use benefits contribute indirectly to

an increase in welfare for nonmarketed uses of a resource. For example, the options’ positive

impacts on local fisheries may generate an improvement in the population levels and diversity

of fish-eating bird species. In turn, avid 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 regulatory

options’ initial impact on fish..

 Nonuse benefits: Nonuse, or passive, 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 benefits of reduced I&E mortality 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 I&E mortality to forage species

improve overall ecosystem function.

Table 4-1 displays the benefit categories expected to be affected by the regulatory options considered for

the Section 316(b) regulation for in-scope facilities. The table also reveals the various data needs, data

sources, and estimation approaches associated with each category. Many ecosystem services with

potential nonuse values could not be quantified or monetized due to a lack of sufficient data. A complete

list of the ecosystem services potentially affect by reduction in I&E mortality is presented in Chapter 2

(Table 2-4).
March 28, 2011 4-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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 I&E

mortality data and ecological

modeling.

 Changes in commercial fishery

landings are estimated using a

market-based approach.

 Indirect economic impacts are 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 are 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

 Estimated number of affected anglers

 Value of an improvement in catch rate

 Changes in the value of a

recreational fishing trip are estimated

based on benefit transfer (including

recreational use values of selected

T&E species).

 Changes in the value of subsistence

fishing is not estimated.

 Increase in recreational fishing

participation

 Estimated number of affected anglers or

estimate of potential anglers

 Value of a fishing day

 Not estimated due to data

constraints.

Nonmarket Goods, Indirect Use

Increase in value of boating, scuba-diving,

and near-water recreational experience

from:

 Enjoying observing fish while boating,

scuba-diving, hiking, or picnicking

 Watching aquatic birds fish or catch

aquatic invertebrates

 Estimated number of affected nearwater recreationists, divers, and boaters

 Value of boating, scuba-diving, and

near-water recreation experience

 Not estimated due to data

constraints such as number of

affected recreational users.

 Increase in boating, scuba-diving, and

near-water recreation participation

 Estimated number of affected boating,

scuba-diving, and near-water

recreationists

 Value of a recreation day

 Not estimated. Changes in

recreational participation 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)

 I&E mortality estimates

 Primary valuation research using stated

preference approach

 Applicable studies upon which to

conduct benefit transfer

 Location of CWISs and T&E species

ranges

 Estimate nonuse values for an

increase in relative fish abundance

within two benefits regions using

benefits 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

CWISs based on the overlap of

CWIS locations and T&E species

ranges.
March 28, 2011 4-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

4.2 Market and Nonmarket Direct and Indirect Use Benefits from Reduced

I&E Mortality

Direct use benefits are the simplest to envision. The welfare of commercial, recreational, and subsistence

fishers is improved when fish stocks increase and their 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 I&E mortality. Methodologies for estimating use values for recreational and commercial

species are well developed, and some of the species affected by I&E mortality have been extensively

studied. As a result, estimation of associated use values is often considered to be straightforward.

Indirect use benefits refer to welfare improvements for those individuals whose activities are enhanced as

an indirect consequence of fishery or habitat improvements generated by the regulatory options for inscope facilities. For example,an improvement in the population of a forage fish species may not be of any

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 regulatory options’ effect on forage

fish populations.

The following sections discuss the benefits estimates presented in each chapter of this report, and

techniques for estimating benefits of reduced I&E mortality for each category of benefits.9

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 I&E

mortality-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 I&E mortality-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 not be of any

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

9 Many of the fish species affected by I&E mortality at CWIS sites are harvested both recreationally and commercially. To

avoid double-counting the economic impacts of I&E mortality 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.
March 28, 2011 4-5

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

incremental increase in commercial fishing benefits would be an indirect consequence of the regulatory

options’ 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 of this report provides more detail on EPA’s analysis of commercial fishing benefits from

reducing I&E mortality at the in-scope facilities’ cooling water intakes.

4.2.2 Recreational Fisheries

Recreational fishing benefits include both direct and indirect nonmarket use values. The benefits of

recreational use cannot be tracked in the market, since 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 in-scope 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 willingness to pay (WTP) for catching an

additional fish per trip. The estimated meta-model allows calculation of 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 not be of any

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 regulatory

options’ 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 of this report provides detail on the application of the meta-regression model to estimating

recreational fishing benefits from the alternative regulatory options.

4.2.3 Subsistence Fishers

Subsistence fisheries benefits include both direct and indirect nonmarket use values. Subsistence use of

fishery resources can be an important issue in areas where socioeconomic conditions (e.g., the number of

low-income households) or the mix of ethnic backgrounds make such fishing economically or culturally

important 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 more-general populations, the value of improved

subsistence fisheries may be estimated from the costs saved in acquiring alternative food sources

(assuming the meals are replaced rather than foregone). 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
March 28, 2011 4-6

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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, leading to underestimation of the total benefits of the regulatory options. EPA’s

analysis of the regulation’s impacts on low-income populations and subsistence fishers is presented in

Chapter 9 of the Economic Analysis of the Proposed 316(b) Regulation.

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 CWISs. T&E species

can suffer direct harm from I&E mortality; they can suffer indirect impacts if I&E mortality at CWISs

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 critical habitat (e.g., via thermal

discharges). The loss of individuals of listed species from CWISs 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 I&E mortality 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 portion of the

values for T&E species are nonuse values. However, some of these species have potentially significant

recreational and commercial use values (e.g., sturgeon and paddlefish). EPA applied benefit transfer to

estimate recreational use values for a subset of T&E species for which limited catch and release fisheries

exist. EPA did not estimate potential commercial use values of these species due to the lack of market

data.

Chapter 5 of this report provides more detail on EPA’s analysis of T&E species benefits from reducing

I&E mortality at in-scope facilities’ cooling water intakes.

4.3 Nonuse Benefits from Reduced I&E Mortality

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).10 Consequently, 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 2000a; USOMB 2003). Excluding nonuse values from consideration is likely to

substantially understate total social values.

Reducing I&E mortality of fish and shellfish may result in both use and nonuse benefits. Of the

organisms that are anticipated to be protected by the regulatory options for the Section 316(b) regulation

for in-scope facilities, only a tiny fraction will eventually be harvested by commercial and recreational

fishers and therefore can be valued with direct use valuation techniques. Unharvested fish, which were

not assigned direct use value in this analysis, constitute the majority—97 percent—of the total loss, as

10 This additive property holds under traditional conditions related to resource levels and prices for substitute goods in the

household production model (Freeman III 1993).
March 28, 2011 4-7

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

summarized in Table 4-2 which reports total I&E mortality losses and reduction in I&E mortality losses

by four loss categories: all species, forage species, total commercial and recreational species, 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 their use value—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 CWISs provide other valuable ecosystem goods and services. These include nutrient cycling and

ecosystem stability. Therefore, a comprehensive estimate of the welfare gain from reducing I&E mortality

must include an estimate of nonuse benefits.

In contrast to direct and indirect use values, nonuse values are often considered more difficult to estimate.

Stated preference methods, or benefit transfer based on stated preference studies, are the generally

accepted techniques for estimating these values (USEPA 2000a; USOMB 2003). Stated preference

methods rely on carefully designed surveys, which either (1) ask people about their WTP for particular

ecological improvements, such as increased protection of aquatic species or habitats with particular

attributes, or (2) ask people to choose between competing hypothetical “packages” of ecological

improvements and household cost where their choice implies a WTP value. In either case, values are

estimated by statistical analysis of survey responses.

Table 4-2: Summary of Baseline National I&E Mortality Losses and Reductions in

I&E Mortality Losses, by Regulatory Option

IM&EM Loss Metric (per year) Option 1 Option 2 Option 3

All Species (million A1E) 2188.92 614.97 1981.55 2013.55

Forage Species (million A1E) 1654.78 525.66 1512.64 1535.44

Commercial & Recreational Species (million A1E) 534.15 89.31 468.91 478.11

Commercial & Recreational Harvest (million fish) 59.41 15.66 53.28 54.05

A1E Losses with Direct Use Value (%) 2.71 2.55 2.69 2.68

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

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, their values may be different from the nonuse values for users of the same resource. Third, the

development of a defensible stated preference 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 affected resources’ nonuse service values as part

of regulatory development, an extensive body of environmental economics literature reveals 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 nonuse
March 28, 2011 4-8

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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 stated preference surveys to elicit total value (i.e., nonuse and

use) of environmental quality changes resulting from environmental regulations is often not feasible.11

Existing stated preference 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 values 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. 2009, unpublished data).

Additional detail regarding Johnston et al. (2009) is provided in Chapter 8, Section 8.3.1.

Many ecosystems impacted by CWISs provide goods and services that contribute to well-being (see

Chapter 2), but may be generally unrecognized because of their indirect nature. As such, valuations based

on stated preferences are unlikely to capture the full complement of ecologically-based services with

economic value (Costanza and Folke 1997). Despite these limitations, benefit transfers based on stated

preference studies are the generally accepted techniques for estimating nonuse values. EPA was able to

identify a single study that could be used to estimates total values (nonuse and use values) for reductions

in I&E mortality in some regions. Chapter 8 of this report provides more detail on EPA’s quantitative

analysis of nonuse benefits from reducing I&E mortality at the in-scope facilities’ cooling water intakes.

11 EPA designed a stated preference survey to separately estimate total value (including use and nonuse value) of potential

aquatic resource improvements that might occur because of the proposed 316(b) regulation. However EPA did not have

sufficient time to fully develop and deploy this survey and derive reliable quantitative estimates of the monetary value of

reducing those impacts at the national level. Benefit transfer of values from existing stated preference studies was used by

EPA in the absence of an original study. For more details on development of the survey, see the Information Collection

Request entitled “Development of Willingness to Pay Survey Instrument for Section 316(b) Cooling Water Intake

Structures”.
March 28, 2011 5-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

5 Impacts and Benefits on Threatened and Endangered Species

5.1 Introduction

Threatened and endangered (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. In addition to T&E labels, the designation “species of concern” includes

species that warrant special protection due to inherent vulnerabilities to habitat modification, disturbance,

or other human impacts. Together, these stressors may result in the species becoming threatened or

endangered in the foreseeable future.12

The withdrawal of cooling water from streams, rivers, estuaries and coastal marine waters leads to the

impingement and entrainment (I&E) of a large number of aquatic organisms. For species vulnerable to

future extinction, impingement and entrainment mortality (I&E mortality) from cooling water intake

structures (CWISs) may represent a substantial portion of annual reproduction. Consequently, I&E

mortality may either lengthen recovery time, or hasten the demise of these species. For this reason, 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 CWISs on T&E species may occur in several ways:

 Populations of T&E species may suffer direct harm as a consequence of I&E mortality. 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.

 CWISs 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 I&E mortality 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 by a CWIS during the (often short) sampling

window, and 2) the organism must be identifiable. Thus, despite the fact that the population impacts of

I&E mortality on T&E species may be high, they are difficult to ascertain and quantify within a

framework designed for common, more-abundant species. Thus, EPA identifies spatial overlap between

CWISs and T&E species to estimate the potential for adverse I&E mortality impacts on T&E species.

12 To simplify the discussion, in this chapter EPA uses the terms “T&E species” and “special status species” interchangeably

to mean all species that are specifically listed as threatened or endangered, plus other species with special status designation

at the state or federal level.
March 28, 2011 5-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

From an economic perspective, T&E species affected by CWISs 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 I&E mortality are obscure, relatively unknown, and may not

have any direct uses (e.g., delta smelt). Given the protected nature of T&E species and the fact that the

majority of T&E species do not have direct uses, the majority of the economic value for T&E species

must come from nonuse values. Strictly speaking, 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, the cost, administrative burden, and time required to develop primary research estimates to

value effects of the 316(b) regulation on T&E species are beyond the schedule and resources available to

EPA for this rulemaking. As an alternative, EPA considered a benefit transfer approach that relies on

information from existing studies (USEPA 2000a).

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., paddlefish13 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 likely to be highly conservative (i.e., low).

In this chapter, EPA explores the extent to which CWISs 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 CWISs

To assess the potential impacts of CWISs on T&E species, EPA constructed a database that identifies

spatial overlap between CWISs 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 I&E mortality impacts

on T&E species.

5.2.1 T&E Species Identification and Data Collection

First, all species currently listed or in consideration for listing under the Endangered Species Act (as of

January 16, 2010) with aquatic life history stages were identified using the US Fish and Wildlife Service

Environmental Conservation Online System (USFWS 2010b). 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, free-swimming larval stages,

and adult life history stages that occur near shore. Life history data used to exclude species from further

consideration was obtained from a wide variety of sources (AFSC 2010; ASMFC 2010; Froese and Pauly

2009; NatureServe 2009; NEFSC 2010; PIFSC 2010a; PIFSC 2010b; SEFSC 2010; SWFSC 2010;

USFWS 2010b). After filtering by life history data, the list of T&E species potentially affected by I&E

mortality contained 247 species.

Whenever possible, the geographical distribution of T&E species susceptible to I&E mortality was

obtained in geographic information system (GIS) format as polygon (shape) files, line files (for

13 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.
March 28, 2011 5-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

inhabitants of small creeks and rivers) and as a subset of geodatabase files. Data sources include the US

Fish and Wildlife Service (USFWS 2010a), NOAA’s Office of Response and Restoration (NOAA

2010a), NatureServe (NatureServe 2009), and NOAA NMFS (NMFS 2010b; NMFS 2010c; NMFS

2010d). For several freshwater species, geographic ranges were available only as 6-digit hydrologic unit

codes (HUC) (NatureServe 2009; 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 CWISs, and inspected for geographic overlap. In all such cases (e.g., the “inarticulated

brachiopod,” Lingula reevii, endemic to Kaneohe Bay, HI) there were no in-scope CWISs 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, 88 of the 247 aquatic T&E species assessed or 36 percent had vulnerable life history stages

that either overlapped with CWISs, or had records of entrainment or impingement mortality (Appendix

E). These species overlapped with 446 of 871 in-scope facilities (51 percent). Among facilities, the

variability in the number of T&E species potentially affected ranges between 0 and 26 species (Table

5-1), with more than 90 percent of facilities affecting fewer than 5 T&E species, and more than 99 percent

of facilities affecting fewer than 12 species (Figure 5-1).

Excluding facilities whose CWISs do not overlap with at least one T&E species, the average number of

species per facility is 3.89 (minimum 0, maximum 26) (Table 5-1). Sea turtles and freshwater mussels had

the highest overlap rate on a per-facility basis, averaging 4.83 and 3.53 species per facility, respectively.

Anadromous, freshwater, and marine fish had lower overlap rates with facility CWISs, averaging slightly

higher than 1 species per interacting facility (Table 5-1).

Driven by the high number of I&E mortality freshwater mussels overlapping with facility CWISs, 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 is not a function of geographic region

(Figure 5-2).
March 28, 2011 5-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 5-1: Number of T&E Species with Geographical Distributions Overlapping Inscope CWISs, on a Per-facility Basis

Subset of Affected Species1# Species Avg Max Avg Max

All T&E Species 88 1.99 26 3.89 26

T&E Freshwater Mussels 43 1.14 22 3.53 22

T&E Sea Turtles 6 4.83 5 4.83 5

T&E Anadromous Fish 13 0.13 3 1.08 3

Other T&E Freshwater Fish 21 0.09 4 1.33 4

Other T&E Marine Fish 3 0.13 2 1.42 2

1

T&E species included species of concern and species under review for listing by the US Fish and Wildlife Service

(freshwater) or NOAA National Marine Fisheries Service (marine). Only species overlapping with a minimum of one CWIS

are included.

2

Interacting Facilities = all facilities with CWIS inside the range of at least one T&E species

3 Avg = average, Max = maximum

All Facilities Interacting Facilities2

T&E Species per Facility3

Figure 5-1: Empirical cumulative distribution function plot of the number of T&E species

potentially affected on a per-facility basis by in-scope facilities nationwide.
March 28, 2011 5-5

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Figure 5-2: Cumulative distribution plot of the number of T&E species potentially affected on a

per-facility basis by in-scope facilities nationwide. Sample sizes (i.e., number of in-scope 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 CWISs to affect individual T&E species, EPA calculated the

number of facilities affecting each T&E species. There are 1,734 examples of species by facility

interactions across 88 T&E species nationally, resulting in an average of 19.7 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 I&E mortality of T&E species, the cumulative effect of in-scope

316(b) facilities on these populations may be substantial. The variation among species was large and

ranged between 1 and 135 facilities per species (Table 5-2). Overall, 19 percent of species are affected by

1 facility, 50 percent of species affected by fewer than 6 facilities, 80 percent of species affected by fewer

than 24 facilities, and 90 percent affected by fewer than 44 facilities (Figure 5-3).
March 28, 2011 5-6

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 5-2: Number of Facilities with CWISs Within the Geographical

Distribution of T&E Species, on a Per-species Basis

Subset of Affected Species1,2 Species Interactions Avg Max

All T&E Species 88 1734 19.70 135

T&E Sea Turtles 6 652 108.67 135

T&E Freshwater Mussels 43 836 19.44 85

T&E Anadromous Fish 13 115 8.85 64

Other T&E Freshwater Fish 21 64 3.05 7

Other T&E Marine Fish 3 17 5.67 11

1

T&E species included species of concern and species under review for listing by the US Fish and Wildlife

Service (freshwater) or NOAA National Marine Fisheries Service (marine). Only species overlapping with a

minimum of one CWIS are included.

2

Two species of coral are included in the 'All Species' category, and not in any subcategory

3 Avg = average, SD = standard deviation, Med = median, Max = maximum

Facilities per T&E Species3

When species were analyzed within life history trait, sea turtles had the highest average number of

overlapping facilities (108.7) (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 I&E mortality impacts at all life

stages. The six sea turtle species examined were the six species with the highest number of overlapping

CWISs. Following sea turtles, freshwater mussels had the highest average number of overlapping

facilities (19.4 facilities per species). Excepting turtles, freshwater mussels accounted for 9 of the top 10

species sorted by the count of CWISs affecting them (Figure 5-4). Following freshwater mussels,

anadromous fish species were most likely to be affected, with an average of 8.9 facilities per species

(Table 5-2). This average, however, is highly skewed by a single species of fish (the pallid sturgeon,

Figure 5-3: 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 in-scope facility. Sample size is 88.
March 28, 2011 5-7

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Scaphirhynchus albus) which accounted for 54 percent of all overlap between facilities and anadromous

fish species (Figure 5-4). Excepting the pallid sturgeon, anadromous fish had a similar level of potential

exposure to I&E mortality as non-diadromous fish: freshwater and marine fish species averaged

approximately 3.5 facilities with potential I&E mortality per species (Table 5-2, Figure 5-4). In addition

to finfish and shellfish, elkhorn and staghorn corals (Acropora palmata and A. cervicornis) also have the

potential for I&E mortality impacts: both species have the potential to be affected by 25 facilities.

5.2.4 Summary of Overlap Between Cooling Water Intake Structures and T&E Species

Nationally, 36 percent of T&E species assessed have vulnerable life history stages that overlap with a

minimum of one CWIS (Table 5-1), suggesting a high probability of T&E populations’ being affected by

I&E mortality. The potential for these impacts is widespread: T&E species overlap CWISs in all

geographical regions of the country (Figure 5-2), in all waterbody types, and across multiple life histories

(Figure 5-4). Overall, 51 percent of in-scope facilities overlap with at least one T&E species (Table 5-1),

while 36 percent of aquatic endangered species overlap with at least one CWIS. Finally, our 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 I&E mortality is understated.

Figure 5-4: 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 in-scope facility.
March 28, 2011 5-8

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

5.2.5 Species with Documented I&E Mortality

EPA identified several T&E species with documented I&E mortality (Table 5-3). In addition to

documented instances of T&E mortality, EPA identified I&E mortality not identified to species but whose

genus matched T&E species overlapping with the reporting facility’s CWIS (Table 5-3). Although these

are not confirmed I&E mortality of T&E species, they provide evidence that additional T&E species are

likely to be directly affected by I&E mortality.

Including only individuals identified to species, EPA identified more than 130,000 baseline losses of

T&E species (Table 5-3). However, for several reasons, T&E species suffering I&E mortality 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 I&E mortality outside of sampling periods and are never recorded. Second, because a

high proportion of all I&E mortality occur during early life history stages (i.e., egg, larvae) when species

identification is more challenging, T&E species may not be recognized during sampling (e.g., endangered

species of darter, including the Cherokee and duskytail darters, may be reported as “darter,” or

“unidentified darter”).

5.3 Societal Values for Preservation of T&E Species Affected by I&E Mortality

This section examines governmental spending, policy decisions, and private donations on the preservation

and restoration of T&E species. It 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) annually reports expenditures for the conservation of T&E

species. Using the report for fiscal year 2008 (USFWS 2009) EPA calculated total government (federal

and state) expenditures for the 88 federally listed T&E species with vulnerable life history stages that

overlap CWISs (Table 5-4). Excluding expenditures on T&E species not subject to I&E mortality,

expenditures on T&E species potentially affected by CWISs exceeded $465 million, and accounted for 86

percent of all governmental spending on Fish, Marine Reptiles, Crustaceans, Corals and Clams listed

under the Endangered Species Act (ESA) during FY 2008 (USFWS 2009).

In addition to direct governmental spending associated with the protection of T&E species that overlap

with CWISs, 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).
March 28, 2011 5-9

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 5-3: T&E species with documented I&E mortality. Species are separated by the taxonomic

resolution reported for the I&E mortality loss.

Resolution Common Name Latin Name Baseline I&E Mortality

Species Atlantic Salmon Salmo salar Qualitative

Chinook Salmon Oncorhynchus tshawytscha 5,470b

Coho Salmon Oncorhynchus kisutch Qualitative

Delta Smelt Hypomesus transpacificus 62,526b

Green Sea Turtle Chelonia mydas Qualitative

Hawksbill Sea Turtle Eretmochelys imbricata Qualitative

Kemp's Ridley Sea Turtle Lepidochelys kempii Qualitative

Leatherback Sea Turtle Dermochelys coriacea Qualitative

Loggerhead Sea Turtle Caretta caretta 5-50b

Longfin Smelt Spirinchus thaleichthysa24,919b

Olive Ridley Sea Turtle Lepidochelys olivacea Qualitative

Pallid Sturgeon Scaphirhynchus albus 50

Sacramento Splittail Pogonichthy macrolepidotusa45,188b

Steelhead Trout Oncorhynchus mykiss 5

b

Topeka Shiner Notropis Topeka 15b

Genus Alabama Sturgeon Scaphirhynchus suttkusi 8,174b

Atlantic Sturgeon Acipenser oxyrinchus oxyrinchus 785,667

Blackside Dace Phoxinus cumberlandensis 10b

Blue Shiner Cyprinella caerulea 94,608,786

Boulder Darter Etheostoma wapiti 3,529,746

Cherokee Darter Etheostoma scotti 3,529,746

Chum Salmon Oncorhynchus keta 22

Duskytail Darter Etheostoma percnurum 3,529,746

Etowah Darter Etheostoma etowahae 3,529,746

Green Sturgeon Acipenser medirostris 785,667

Gulf Sturgeon Acipenser oxyrinchus desotoi 785,667

Neosho Madtom Noturus placidus 41,021b

Palezone Shiner Notropis albizonatus 19,421,686b

Pygmy Madtom Noturus stanauli 41,021b

Scioto Madtom Noturus trautmani 41,021b

Shortnose Sturgeon Acipenser brevirostrum 785,667

Snail Darter Percina tanasi 259,500b

Unarmored Threespine Stickleback Gasterosteus aculeatus williamsoni 2,922b

Notes: Species listed as threatened or endangered under state laws, such as the American Paddlefish (Polyodon spathula), are not

included in this list.

"Qualitative" indicates the species is reported by name from a minimum of one facility, but no loss estimates are provided.

Baseline losses reported for genera reflect losses for all species within the genus. Losses are likely dominated by more-common

congeners.

a This species is under review for listing under the Endangered Species Act

b This estimate is not derived using extrapolation procedures
March 28, 2011 5-10

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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, due to the potential for negative effects on Delta Smelt populations, have been

estimated to result in the loss of 21,100 farm-related jobs and $703 million in agricultural revenue in 2009

alone (Boxall 2010; Howitt et al. 2009).14

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 of concern.

5.4 Assessment of Benefits to T&E Species

5.4.1 Economic Valuation Methods

For several reasons, it is difficult to estimate the benefits of preserving T&E species by reducing I&E

mortality. 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), there is a paucity of economic data focused 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 I&E mortality, 1)

quantitative I&E mortality impacts, and the benefits of policy options, must be estimated for T&E

species; and 2) an economic value must be obtained for the value of reducing I&E mortality 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.

14 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.

Table 5-4: Federal and State Expenditures for T&E

Species Overlapping with CWIS

Life History

Expenditure

(2009$, millions)

Anadromous Fish $ 383.2

Corals $ 0.3

Freshwater Fish $ 44.4

Freshwater Mussels $ 5.6

Marine and Estuarine Fish $ 0.2

Sea Turtles $ 33.9

All Species Overlapping CWIS $ 467.6

All Fish, Marine Reptile, Crustacean,

Coral, and Clam Species $ 541.7
March 28, 2011 5-11

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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 benefits transfer approach can provide useful insights

into the social benefits gained by reducing I&E mortality of T&E species.15

5.4.2 Case Studies

EPA attempted to estimate the benefits of regulation for all T&E species with documented and quantified

losses at CWIS. In most cases, EPA was unable to locate or calculate key components of the analysis

necessary to apply a benefits 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.

5.4.2.1 Inland Region

Baseline Losses of Special Status Species and Reductions in Losses Due to Regulatory Options

EPA estimated losses 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 regulation for only

the pallid sturgeon (Scaphirhynchus albus), and the American paddlefish (Polyodon spathula). As such,

benefits estimates address only 80–84 percent of documented 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 (85 inches length and more than 220 lbs) species 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

(30-60 inches) fishe 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 losses due to I&E mortality, EPA used the EAM to model A1Es for each of the

three T&E species (Chapter 3).16 The choice of facilities used to extrapolate I&E mortality from model

facilities was based on species’ historic ranges and current distributions. In addition to baseline estimates

of I&E mortality for pallid sturgeon, paddlefish, and Topeka shiner, EPA calculated reductions in losses

under three regulatory options (Table 5-5).

15 Types of benefit transfer studies are discussed at length in U.S. EPA (2000a).

16 Paddlefish and pallid sturgeon losses were observed at nine and two model facilities, respectively.
March 28, 2011 5-12

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 5-5: Annual Baseline I&E Mortality and Reductions in Baseline I&E Mortality

of T&E Species at In-scope Facilities in the Inland Region, by Regulatory Option

(A1E)

Species Value Type Baselinea Option 1 Option 2 Option 3

Pallid Sturgeon Nonuse 17,628 8,631 15,946 16,317

Paddlefish Use and Nonuse 88 73 85 86

Topeka Shiner Nonuse 3,669 3,069 3,546 3,581

Total 21,384 11,773 19,577 19,984

a

The I&E mortality 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.

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Benefit Transfer Approach: Estimated WTP for Protection of Inland T&E Species

A 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 $37.02 (2009$) as a one-time tax to create a self-sustaining

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 $121.30 (2009$). Since the estimated number of sturgeon viewers in 2002 was 3,176

individuals, total WTP for sturgeon-viewing opportunities in the Winnebago system was $0.39 million

(2009$). 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 I&E

mortality, because reliable population estimates needed to transfer the values were unavailable.

B 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 3 lbs 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
March 28, 2011 5-13

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

$69.88 (2009$) to catch a sturgeon (USEPA 2004b), a value transferred to anglers for pallid sturgeon and

paddlefish in the Inland region (Table 5-6).17

The undiscounted recreational use value from eliminating baseline I&E mortality is approximately $1,238

thousand, while use values from reducing pallid sturgeon and paddlefish I&E mortality range from $608

thousand to $1,146 thousand for the three regulatory options considered. Annualized benefits range from

$498 to $719 thousand at a 3 percent discount rate, and from $454 to $561 thousand at a 7 percent

discount rate. EPA notes that these value estimates underestimate total values of reducing I&E mortality

to T&E species in the Inland region, because both nonuse and commercial values, likely to be substantial,

are not incorporated.

Table 5-6: Estimated Annual WTP for Eliminating or Reducing I&E Mortality of Special

Status Fish Species at In-scope Facilities in the Inland Region, by Regulatory Option

(2009$)

Baseline Option 1 Option 2 Option 3

Pallid Sturgeon $1,231.8 $603.1 $1,114.3 $1,140.3

Paddlefish $6.1 $5.1 $5.9 $6.0

Total Undiscounted $1,238.0 $608.2 $1,120.2 $1,146.2

Annualized Value $1,144.3 $498.0 $719.0 $717.8

Annualized Value $1,140.0 $454.3 $560.7 $549.7

a

The I&E mortality 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.

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities

> 125 MGD; Option 3 = I&E Mortality Everywhere.

3% Discount Rate

7% Discount Rate

T&E Species

Annual Benefits (2009$, thousands)

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 I&E mortality in the

Inland region, EPA applied a WTP meta-analytical model (Richardson and Loomis 2009) to hypothetical

scenarios. Because EPA does not currently have region-wide I&E mortality for all T&E species, nor

population models to estimate the effect of I&E mortality on population size, estimates are presented only

to assess the range of benefits potentially resulting from 316(b) regulatory options. 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.

EPA estimated nonuse values using benefit transfer according to Richard and Loomis (2009) (details in

Appendix F, Section F.3). Excepting all policy-relevant variables, EPA used the mean values for all

model parameters, and converted estimates to 2009$ using the Consumer Price Index (USBLS 2010).

For a 0.25 percent change in T&E fish population size, projected WTP per household per year is $1.02

(2009$). With 59.6 million households18, total WTP for T&E fish in the Inland region is $60.31 million.

17 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.

18 Household number in the Inland region is calculated for states where at least T&E species affected by I&E mortality is

found.
March 28, 2011 5-14

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

For a 0.5 percent change in T&E fish populations, WTP per household is $1.85 per year, resulting in

WTP values of $110.25 million in the Inland region (all values 2009$).

5.4.2.3 Sea Turtles

Six species of sea turtles are found 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, there is substantial overlap between sea turtle habitat and CWISs for

in-phase power generating and manufacturing facilities. Additionally, since individuals of all ages and

sizes are susceptible to impingement and entrainment (Norem 2005), there are more than 730 potential

species x CWIS interactions that may result in the injury or death of these T&E species (Table 5-1, details

in Appendix Section F.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, there are dozens of academic, nonprofit, and ecotourism

organizations that 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 long hours (often during the night). For example, the nonprofit group

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, working to 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

work 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 Losses of Special Status Species and Reductions in Losses Due to Regulatory Options

There are several passive-use (e.g., wildlife viewing and photography) and nonuse values associated with

U.S. sea turtle populations. Many households express passive use value by participating in 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.

Power plants are known to entrain and impinge all six species of sea turtles found in U.S. waters (Norem

2005), with more than 730 occurrences of overlap between species ranges and CWISs (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 (fewer than 30 to more than 1,400 million gallons per day average intake

flow), 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 the fact that mortality rates due to entrainment are estimated to be <

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 CWISs may be higher than reported,
March 28, 2011 5-15

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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).

Although the magnitude of I&E mortality is believed to be small relative to fishing-related mortality, the

cumulative impact of I&E mortality is unclear. The only study presenting a quantitative estimate of

annual I&E mortality estimated mortality rates to be between 5 and 50 individuals per year (Plotkin

1995). Consequently, EPA does not believe sufficient data exist to estimate baseline sea turtle mortality

due to entrainment and impingement at regional or national scales. However, due to lower population

sizes, long life-span, and high reproductive potential of adult turtles (Crouse et al. 1987), EPA believes

the effect of 316(b) regulation is likely to have a small effect on the long-term viability of turtle

populations.

Benefit Transfer Approach: Potential WTP for Protection of Sea Turtle Species

A 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 a bid amount 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 316(b) regulatory

options (detailed methodology in Appendix Section F.2). Available data sources and biological models

were reviewed to assess the potential impact of baseline losses and reductions on the probability of sea

turtle extinction over 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 CWISs on sea turtle

extinction risk. Estimates from the literature suggest that I&E mortality 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 survivorship at these age classes

could have a measurable impact on extinction risk. EPA believes that the marginal change in extinction

probability of loggerhead sea turtles due to 316(b) regulatory options is unlikely to be lower than 0.01

(i.e., a 1 percent decrease in the probability over 25 years). This assessment is based upon reports that

I&E mortality 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 bound household values for

changes in extinction risk for loggerhead sea turtles as a consequence of 316(b) regulation (details of this

calculation are in Appendix Section F.2). Although this assessment is not based on formal quantitative

analysis of extinction risk, it is intended to illustrate the range of potential benefits associated with

reductions in sea turtle losses. Using the published mean values for all other model parameters, EPA

calculated an annual household value of $0.35 (2009$). Estimates were converted to 2009 dollars using

the consumer price index (USBLS 2010).
March 28, 2011 5-16

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

B Total WTP for all Households

Whitehead’s (1993) study for loggerhead sea turtle management activities was based on a state-wide

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 from the resource may value sea turtle survival less than households near the ocean, due to lower

likelihood of participation 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.

For the purposes of assessing potential benefits from improvements to a sea turtle population, EPA

focused solely on impacts to loggerhead sea turtles (one of six T&E sea turtle species in the US). 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. This species of turtles was chosen 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 Table F-1). The U.S.

range of loggerhead sea turtles includes the Gulf of Mexico, South Atlantic, Mid-Atlantic, and North

Atlantic 316(b) regions (USFWS 2010c). Assuming affected populations include all households within

states with 316(b) existing facilities that potentially have an impact loggerhead sea turtles, 53.35 million

households would be willing to pay for improved protection of this species (Table 5-7). By applying the

mean household value of $0.35 (2009$) across all four regions, the total annual WTP for a 1 percent

increase in the survival probability of loggerhead sea turtles annualized at a 3% discount rate over 25

years is $16.6 million. Annualized benefits for each region are presented in Table 5-7, assuming that

benefits begin to accrue in 2012 and continue throughout the compliance period. Because EPA does not

currently have accurate national estimates of I&E mortality for turtle species, nor are population models

available that estimate the effect of 316(b) regulation on population size and extinction risk, estimates are

presented only to assess the potential range of benefits, and are not included in national totals. Actual

benefits may be higher or lower than these estimates, with Option 2 and Option 3 likely to provide

substantially greater benefits than Option 1.
March 28, 2011 5-17

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 5-7: Monetized Benefits of a 1 Percent Increase in the Probability that Loggerhead

Sea Turtles Will Not Be Extinct in 25 Years

3% Discount Rate 7 % Discount Rate

North Atlantic CT, MA, ME, NH,

RI

5.40 $1.67 $1.62

Mid-Atlantic DE, MD, NJ, NY,

PA, VA

20.97 $6.51 $6.31

South Atlantic FL, GA, NC, SC 11.85 $3.67 $3.56

Gulf of Mexicoa FL, LA, MS, TX 15.13 $4.69 $4.40

Total - 53.35 $16.55 $16.04

Annualized Benefits

(2009$, millions)

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.

Number of

Households

(millions)Region States Included

5.4.3 Limitations and Uncertainties

Table 5-8 summarizes the caveats, omissions, biases, and uncertainties known to affect the estimates

developed for the benefits analysis of sea turtles (Section 5.4.2.3), and T&E finfish in the Inland (Section

5.4.2.1) region.

Table 5-8: 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

I&E mortality is uncertain Uncertain

Projected changes in number of fish affected may be

underestimated because neither cumulative impacts of

I&E mortality over time nor interactions with other

stressors are considered.

I&E mortality effects are not

estimated for all T&E species and

all regions

Estimates understated

EPA was unable to estimate I&E mortality 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 I&E mortality 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 80–84

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. T&E species

have 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 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 no data with respect to the effect of thermal

discharge on T&E species.
March 28, 2011 6-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

6 Commercial Fishing Benefits

Commercial fisheries can be adversely affected by impingement and entrainment mortality (I&E

mortality) 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 indicates how EPA estimated the change in

commercial fisheries-related economic surplus associated with the elimination of baseline I&E mortality

and reduction in baseline I&E mortality under the regulatory options considered for the Section 316(b)

regulation. The 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 employed to estimate the commercial fishing benefits associated with the regulatory

options for the proposed Section 316(b) regulation closely follows the analysis conducted for the Section

316(b) Phase III Final Rule (USEPA 2006b). Changes from that analysis include updated estimates of

I&E mortality losses and reductions, and updated dockside prices. The dockside prices are now estimated

based on the 5-year average price between 2005 and 2009, from commercial fishing landings data

obtained from the National Oceanic and Atmospheric Administration’s National Marine Fisheries Service

(NMFS).

EPA measured commercial fishing benefits as changes in producer surplus. EPA considered estimating

consumer surplus values associated with reductions in I&E mortality, but found that dockside prices

would not change enough to produce measurable shifts in consumer surplus. The details of this analysis

and the estimated price changes are presented in Section 6.2 and in Appendix G.

6.1.1 Estimating Consumer and Producer Surplus

The total loss to the economy from I&E mortality 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 I&E mortality losses using the methods presented in Chapter 3 of this document. EPA assumed a

linear relationship between stock and harvest. That is, if 10 percent of the current commercially targeted

stock were harvested, EPA assumes that 10 percent of any increase in that species due to lower I&E

mortality losses would be harvested. Thus, the percentage increase in harvest is assumed to be the same as

the percentage increase in fish. 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 recreational and commercial fishing. EPA applied

these proportions to the estimated total change in harvest to distribute benefits between commercial and

recreational fisheries.
March 28, 2011 6-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Producer surplus provides an estimate of the economic benefits to commercial fishers, but 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 decrease in catch is

accompanied by an increase in price. These impacts can be expected to flow through the tiered

commercial fishery market (as described in Holt and Bishop (2002)).

This study 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 increase 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 model assumes 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

. It uses 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 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
March 28, 2011 6-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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 I&E mortality relies on the assumption that a decrease in

mortality of fish, larvae, and eggs under a scenario of reduced I&E mortality 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

). This changes the total amount paid by consumers to P

2× F2

, which is equal to the area of

the boxes V + W + Y + Z. This may be less than or greater 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 I&E mortality scenario and the current baseline scenario (i.e., U

+ X) is the measure of benefits to consumers from reducing I&E mortality.

Estimating the change in 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 I&E mortality scenario, and (3) an

understanding of the price elasticity of demand for fish. The baseline commercial fishing prices and

harvest quantities were estimated from NMFS landings data from 2005 to 2009 for regional markets for

relevant species. Chapter 3 describes the methods and data used in estimating baseline I&E mortality

losses and reductions under the regulatory options.19 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.

EPA did not include estimates of changes in consumer surplus for commercial species. Prices must

change in order for consumer surplus to change. EPA estimated the expected price changes from

eliminating baseline levels of I&E mortality losses, and found them to small, ranging from 0.13 percent to

2.1 percent. Appendix G of this document presents the detailed calculations and results. Consumer

surplus measures that have been estimated by NMFS for past environmental impact statements tend to be

quite low. 20 Most species of fish have numerous close substitutes, and most fisheries are price-takers in

the world market. Therefore, if harvest of one or several species increases, prices are unlikely to change

by a significant amount.

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, there are lasting economic benefits to commercial fishers from reductions in

I&E mortality and the subsequent increase in harvest. Fishery regulations seek to create sustainable

harvests that maximize resource rents.21 In a regulated fishery, I&E mortality impacts reduce the number

of fish available to harvest. This may lead to more-stringent regulations and decreases in harvest. In this

19 For several species, the predicted changes in harvest were quite large. EPA increased scrutiny on results for species with 10

percent or greater predicted change in harvest, to determine whether such increases were in fact reasonable estimates. In

some cases, EPA capped the predicted harvest increases. The methods used and caps are described in Section 6.2.

20 Personal communications with NMFS economists Cindy Thomson (2008), Eric Thunberg (2008), and Steve Freese (2008).

21 In addition, even in open access fisheries, inframarginal rents are earned by at least some boats (personal communication,

Thunberg 2008).
March 28, 2011 6-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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.22 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 surplus that accrues to

producers for each pound of fish. Total producer surplus realized by producers is equal to (P1- 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, since the opportunity cost of capital is estimated to be only about 0.4 to 2.6

percent of producer surplus, normal profits are assumed to be a sufficient proxy for producer surplus

(USEPA 2004b). As a result, assessment of producer surplus is reduced to 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, as estimated from the change in the commercial harvest due to

reducing I&E mortality 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 National Marine Fisheries

Service is described in more detail in Section A4-10 of US EPA (2006b). EPA then applied the Net

Benefits Ratio to the estimated change in gross revenue under the 316(b) regulatory options to estimate

the increase in producer surplus. The Net Benefits Ratios are shown by region and species in Table 6-1

through Table 6-6; they range from 0.15 to 0.85.23,24 See Chapter 1, Section 1.2 for a definition of the

seven study regions. The Inland region is excluded from the analysis due to a negligible commercial

fishing harvest in this region. EPA notes that this approach yields an estimate of benefits to commercial

22 If marginal cost increases as harvest increases, some of the producer surplus per unit will be lost due to the increased costs.

23 Positive Net Benefits Ratios reflect the assumption that there will be rents (profits) to commercial fishers 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.

24 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 6-1 to Table 6-6.
March 28, 2011 6-5

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

fisherman, not benefits to society as a whole. As described in Section 6.1.1.1, EPA did not estimate

changes in consumer surplus.

Table 6-1: California Region, Species-Specific Gear Type, Status of Stock, and Net Benefits Ratio

Species Main Management

Method

Main Gear

Type Status of Stock

Net Benefits as a

Ratio of Gross

Revenue (NBRatio)

Anchovies Annual landings Roundhaul Unknown 0.64

Cabezon Total allowable catch Hook-and-line Not overfished or subject

to overfishing 0.52

Crabs Seasonal closures Pots and traps Unknown 0.74

Drums and Croakers 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 Not overfished or subject

to overfishing 0.58

Other N/A N/A N/A 0.53

Rockfishes Quotas Trawls Overfished or subject to

overfishing 0.62

California Scorpionfish Quotas Otter trawl Unknown 0.47

Sculpins Nonrestrictive permits Trawls Unknown 0.64

Sea Basses Season, size, gear

restrictions Gillnets Unknown 0.66

Shad, American None Nets Not overfished or subject

to overfishing 0.00

Shrimp Seasonal closures Trawl Unknown 0.15

Smelts Seasonal closures Nets Overfished or subject to

overfishing 0.66

Surfperches Quotas Handlines Unknown 0.37
March 28, 2011 6-6

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 6-2: North Atlantic Region, Species-Specific Gear Type, Status of Stock, and Net Benefits

Ratio

Species Main Management

Method

Main Gear

Type Status of Stock

Net Benefits as a

Ratio of Gross

Revenue (NBRatio)

Bluefish Quotas Gillnets Not overfished or subject

to overfishing 0.63

Butterfish Quotas NA Unknown 0.64

Atlantic Cod Time/area closures Otter trawl Overfished or subject to

overfishing 0.66

Crabs Size, sex, season Traps Not overfished or subject

to overfishing 0.57

American Plaice Size Otter trawl Overfished or subject to

overfishing 0.63

Windowpane Time/area closures Bottom trawl Overfished or subject to

overfishing 0.63

Winter Flounder Quotas Otter trawls Overfished or subject to

overfishing 0.64

Flounders Total allowable landing Bottom trawl Overfished or subject to

overfishing 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 Not overfished or subject

to overfishing 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

Sculpins Open access Unknown Unknown 0.00

Scup Quotas Otter trawls Overfished or subject to

overfishing 0.69

Searobin Open access (by catch) Unknown Unknown 0.00

Shad, American Mortality targets Unknown Fully exploited 0.60

Skates Catch limits Otter trawl Overfished or subject to

overfishing 0.68

Tautog Possession limits Otter trawl Overfished or subject to

overfishing 0.46

Weakfish Size limits Trawls Not overfished or subject

to overfishing 0.76
March 28, 2011 6-7

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 6-3: Mid-Atlantic Region, Species-Specific Gear Type, Status of Stock, and Net Benefits Ratio

Species Main Management

Method

Main Gear

Type Status of Stock

Net Benefits as a Ratio

of Gross Revenue

(NBRatio)

Alewife Bans, species of concern Fish weirs Overfished or subject to

overfishing 0.85

American Shad Chesapeake fishery

closed Unknown

Overfished or subject to

overfishing except for

small by-catch allowance

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

Unknown

0.67

Black Drum Quotas Unknown Unknown 0.70

Blue Crab Limits on female crabs,

size Pots Overfished or subject tooverfishing 0.57

Bluefish Quotas Gillnets Not overfished or subject

to overfishing 0.63

Butterfish Quotas Unknown Overfished or subject to

overfishing 0.64

Crabs Season, size Unknown Unknown 0.57

Drums and Croakers Gear restrictions, quotas Nets Unknown 0.74

Flounders Quotas Bottom trawl 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 overfishing 0.62

Scup Quotas Otter trawls Overfished or subject to

overfishing 0.69

Searobin Open access Unknown Unknown 0.00

Silver Hake Quotas Otter trawls Not overfished or subject

to overfishing 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 Not overfished or subject

to overfishing 0.70

Tautog Possession limits Otter trawl Overfished or subject to

overfishing 0.46

Weakfish Size limits Trawls Not overfished or subject

to overfishing 0.76

White Perch Size limits Unknown Unknown 0.82
March 28, 2011 6-8

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 6-4: South Atlantic Region, Species-Specific Gear Type, Status of Stock, and Net Benefits

Ratio

Species Main Management

Method

Main Gear

Type Status of Stock

Net Benefits as a Ratio

of Gross Revenue

(NBRatio)

Blue Crab Size limits Pots Overfished or subject to

overfishing 0.57

Crabs Size, sex, season Traps Not overfished or subject

to overfishing 0.57

Drums and Croakers Open access (by catch) Otter trawl

bottom, gill nets Overfished 0.54

Atlantic Menhaden

Five year annual cap on

reduction fishery in

Chesapeake

Unknown Unknown 0.76

Other N/A N/A N/A 0.59

Spot License Haul seines Unknown 0.70

Stone Crab Size Traps Not overfished or subject

to overfishing 0.58

Weakfish Size limits Trawls Not overfished or subject

to overfishing 0.64

Table 6-5: Gulf of Mexico Region, Species-Specific Gear Type, Status of Stock, and Net Benefits

Ratio

Species Main Management

Method

Main Gear

Type Status of Stock

Net Benefits as a Ratio

of Gross Revenue

(NBRatio)

Blue Crab Limited entry, pot limits Pots Overfished or subject to

overfishing 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

0.00

Mackerels Quotas Hook-and-line Not overfished or subject

to overfishing 0.75

Menhaden Seasonal/area closures Purse seines Fully exploited 0.76

Other N/A N/A N/A 0.46

Sea Basses Quotas Traps Overfished or subject to

overfishing 0.72

Sheepshead Size Cast net Not overfished or subject

to overfishing 0.84

Shrimp Same as pink shrimp Unknown Not overfished or subject

to overfishing 0.43

Spot License Haul seines Unknown 0.54

Stone Crab Size Traps Not overfished or subject

to overfishing 0.71

Striped Mullet Gear restrictions Strike nets Not overfished or subject

to overfishing 0.79
March 28, 2011 6-9

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 6-6: Great Lakes Region, Species-Specific Gear Type, Status of Stock, and Net Benefits Ratio

Species Main Management

Method Main Gear Type Status of Stock

Net Benefits as a Ratio

of Gross Revenue

(NBRatio)

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

The change in net social benefits when the commercial fishing harvest increases from F

1

to F

2

is

estimated 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.25 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, area X will be

negligible relative to Y, and total social benefits will be measured by area Y. See Appendix G on EPA’s

analysis of the estimated price changes due to reducing I&E mortality losses at CWIS sites by region and

species.

6.2 Benefits Estimates for Regional Commercial Fishing

The first step of the analysis of commercial fishing benefits involves a fishery-based assessment of I&E

mortality-related changes in harvested species landings. Many of the fish species affected by I&E

mortality 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. The estimated

change in commercial fishery harvest was then used as a basis for estimating changes in producer surplus

in the commercial fishing industry.

EPA further assessed species with estimated harvest increases from the elimination of I&E mortality

exceeding10 percent of baseline harvest from 2005 to 2009. This was done to evaluate whether potential

harvest increases under 316(b) regulatory options are reasonable when compared to historic harvest data.

Table 6-7 lists the species and potential percent increases in harvest over baseline harvest from

eliminating baseline I&E mortality losses for the fourteen species found to exceed 10 percent. The species

of concern are cabezon, California halibut, rockfishes, and sculpins in the California region; sculpins in

the North Atlantic region; drums and croakers, spot, and weakfish in the Mid-Atlantic region; black drum,

drums and croakers, leatherjacket, spot, and striped mullet in the Gulf of Mexico region; and smelt in the

Great Lakes region. No species with 10 percent or greater potential change in harvest were found in the

South Atlantic region. The increases range from 12 percent for striped mullet in the Gulf of Mexico to

25,110 percent for sculpins in the North Atlantic.

25 Note that in the model shown in Figure 6-1, X + Y = U + X + [(V + Y) – (U + V)] = U + X + (Y – U)
March 28, 2011 6-10

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 6-7: Potential Harvest Increase from Eliminating I&E Mortality Losses as a Percentage of Total

Harvest and Potential Harvest Capping Rules Used in EPA’s Analysis

Region and

Species

Baseline

Harvest

(thousand

lbs)

Baseline

I&E Losses

(thousand

lbs)

Potential

% Increase

in Harvest

Maximum

Harvest

1979-2009

(thousand

lbs)

90th

Percentile of

Max.

Harvest

(thousand

lbs)

MSY or

Other

Capping

Rule

(thousand

lbs)

Cap Used

California Cabezon 55.6 54.4 98% 374.2 256.7 207.2a Don’t cap

California Halibut 629.9 126.4 20% 1,337.1 1,256.3 1,158.5b Don’t cap

California Rockfishes 2,668.4 1,168.7 44% 58,189.5 43,216.7 77,161.8c Don’t cap

California Sculpins 3.5 2.6 74% 19.5 7.1 482.8 d Don’t cap

North Atlantic Sculpins <0.1 25.1 25,110% 4.8 4.0 Cap at 90th

Mid-Atlantic Drums and

Croakers 11,430.1 1,519.2 13% 16,575.2 16,252.9 Don’t cap

Mid-Atlantic Spot 3,286.9 2,033.0 62% 4,766.2 4,398.3 Cap at 90th

Mid-Atlantic Weakfish 497.0 741.9 149% 15,389.6 7,023.5 Don’t cap

Gulf of Mexico Black

Drum 4,397.3 1,885.2 43% 10,347.2 6,977.2 Don’t cap

Gulf of Mexico Drums and

Croakers 81.0 40.3 50% 1,787.4 1,193.3 Don’t cap

Gulf of Mexico

Leatherjacket 65.6 90.7 138% 509.3 437.5 Don’t cap

Gulf of Mexico Spot 18.1 40.0 221% 442.8 299.1 Don’t cap

Gulf of Mexico Striped

Mullet 10,347.7 1,278.3 12% 33,141.6 27,395.6 Don’t cap

Great Lakes Smelts 522.2 105.9 20% 4,107 3,520 Don’t cap

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.

Sources: EPA estimates of I&E mortality losses; NMFS data on baseline harvest, historical landings, and MSY.

Economists and biologists with NMFS recommended using either maximum sustainable yield (MSY),

allowable biological catch (ABC), or historical harvest to determine reasonable caps on projected total

harvest under the post-compliance scenario.26 NMFS scientists recommended using 25 years or more of

historical catch, because many populations peaked around 25 years ago—at that time there were virgin,

non-exploited populations, so that maximum harvests were achievable. Using historical catch data from

NMFS, EPA determined the maximum landings for the years 1979 through 2009, and calculated the 90th

percentile of landings for those years. NMFS biologists provided MSY where available (for California

cabezon and all West Coast rockfishes). NMFS biologists suggested that sculpins in California be

evaluated in combination with scorpionfish, as these species are grouped when determining the MSY.

They also noted that halibut harvests fluctuate greatly, as the stock is highly variable. There is no stock

assessment for halibut, so NMFS biologists suggested averaging the most recent four peaks in harvest.27

26 Cindy Thomson, NMFS, personal communication (2008).

27 Cindy Thomson, NMFS, personal communication (2008).
March 28, 2011 6-11

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

MSY or ABC data were not available for the species of interest in the other regions.28 Therefore, EPA

capped potential harvest increase at the 90th percentile of annual harvest from 1979 to 2009. The only

species for Based on this criteria and the NMFS scientists’ recommendations, EPA capped estimated

harvest increases for two species when estimated commercial fishing benefits, sculpins in the North

Atlantic and spot in the Mid-Atlantic.

The following sections present estimated benefits from commercial harvest changes in six of the seven

study regions. The Inland region is excluded from the analysis due to a negligible commercial fishing

harvest in this region.

6.2.1 California

Baseline levels of I&E mortality account for 1,379 thousand pounds of commercial fishing losses

annually in the California region, as shown in Table 6-8. Rockfishes account for the major portion of

overall losses in this region. The annual undiscounted commercial fishing benefits of eliminating baseline

I&E mortality losses are estimated to be approximately $1,394 thousand, as shown in Table 6-8.

Applying a 3 percent discount rate, the annualized benefits of eliminating baseline I&E mortality losses

are estimated to be $1,236 thousand. Applying a 7 percent rate, these annualized benefits are

approximately $1,195 thousand.

As shown in Table 6-8, annual commercial harvest is estimated to increase by approximately 7 thousand

pounds under Options 1, 1,176 thousand pounds under Option 2, and 1,230 thousand pounds under

Option 3. Discounted at 3 percent, the estimated annualized benefits to commercial fishers are

approximately $4 thousand under Option 1, $751 thousand under Option 2, and $776 thousand under

Option 3. Discounted at 7 percent, the estimated annualized benefits to commercial fishers are

approximately $3 thousand under Option 1, $573 thousand under Option 2, and $589 thousand under

Option 3. (Table 6-8). Appendix Table H-1 presents species-specific results for the estimated annual

increase in harvest and monetary benefits to commercial fishers.

Table 6-8: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E

Mortality Losses at In-Scope Facilities in the California Region, by Regulatory Option

(2009$)

Undiscounted 3% Discount Rate 7% Discount Rate

Baseline 1,379 1,394 1,236 1,195

Option 1 7 5 4 3

Option 2 1,176 1,189 751 573

Option 3 1,230 1,243 776 589

Regulatory Option

Annual Increase in

Commercial Harvest

(thousand lbs)

Annualized Benefits from Increase in Commercial Harvest

(2009$, thousands)

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere

28 Based on information from NMFS and other Web sites, and personal communication with Nichola Meserve of the Atlantic

States Marine Fisheries Commission (2008).
March 28, 2011 6-12

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

6.2.2 North Atlantic

Baseline levels of I&E mortality account for 430 thousand pounds of annual commercial fishing losses in

the North Atlantic region, as shown in Table 6-9, with flounders playing a particularly important role.

EPA estimated the annual undiscounted benefits to commercial fishers from eliminating baseline I&E

mortality losses to be approximately $471 thousand, as shown in Table 6-9. Total annualized benefits

from eliminating baseline I&E mortality losses, applying a 3 percent discount rate, are estimated to be

$418 thousand. Applying a 7 percent rate, these annualized benefits are approximately $404 thousand.

As shown in Table 6-9, annual commercial harvest is estimated to increase by approximately 3 thousand

pounds under Option 1, 352 thousand pounds under Option 2, and 369 thousand pounds under Option 3.

Discounted at 3 percent, the estimated annualized benefits to commercial fishers are approximately $2

thousand under Options 1, $231 thousand under Option 2, and $242 thousand under Option 3. Discounted

at 7 percent, the estimated annualized benefits to commercial fishers are approximately $1 thousand under

Option 1, $171 thousand under Option 2, and $179 thousand under Option 3 (Table 6-9). Appendix Table

H-2 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 I&E

Mortality Losses at In-Scope Facilities in the North Atlantic Region, by Regulatory

Option (2009$)

Undiscounted 3% Discount Rate 7% Discount Rate

Baseline 430 471 418 404

Option 1 3 2 2 1

Option 2 352 385 231 171

Option 3 369 403 242 179

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere

Regulatory Option

Annual Increase in

Commercial Harvest

(thousand lbs)

Annualized Benefits from Increase in Commercial Harvest

(2009$, thousands)

6.2.3 Mid-Atlantic

Baseline levels of I&E mortality account for approximately 10,672 thousand pounds of commercial

fishing losses annually in the Mid-Atlantic region, as shown in Table 6-10. Atlantic menhaden, blue crab,

drums and croakers, spot, and weakfish are the primary drivers of I&E mortality losses in the MidAtlantic region. The annual undiscounted benefits to commercial fishers from eliminating baseline I&E

mortality losses are estimated to be $3,192 thousand, as shown in Table 6-10. Applying a 3 percent

discount rate, annualized benefits from eliminating baseline I&E mortality losses are estimated to be

$2,831 thousand. Applying a 7 percent rate, these annualized benefits are approximately $2,737 thousand.

As shown in Table 6-10, annual commercial harvest is estimated to increase by approximately 3,750

thousand pounds under Option 1, 10,152 thousand pounds under Option 2, and 10,224 thousand pounds

under Option 3. Discounted at 3 percent, the estimated annualized benefits to commercial fishers are $342

thousand under Options 1, $1,615 thousand under Option 2, and $1,629 thousand under Option 3.

Discounted at 7 percent, the estimated annualized benefits to commercial fishers are approximately $303
March 28, 2011 6-13

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

thousand under Option 1, $1,124 thousand under Option 2, and $1,134 thousand under Option 3 (Table

6-10). Appendix Table H-3 presents species-specific results for the estimated annual increase in harvest

and monetary benefits to commercial fishers.

Table 6-10: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E

Mortality Losses at In-Scope Facilities in the Mid-Atlantic Region, by Regulatory Option

(2009$)

Undiscounted 3% Discount Rate 7% Discount Rate

Baseline 10,672 3,192 2,831 2,737

Option 1 3,750 436 342 303

Option 2 10,152 3,010 1,615 1,124

Option 3 10,224 3,035 1,629 1,134

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere

Regulatory Option

Annual Increase in

Commercial Harvest

(thousand lbs)

Annualized Benefits from Increase in Commercial Harvest

(2009$, thousands)

6.2.4 South Atlantic

Baseline levels of I&E mortality account for more than 99 thousand pounds of commercial fishing losses

in the South Atlantic region, as shown in Table 6-11. The estimated undiscounted annual commercial

fishing benefits of eliminating baseline I&E mortality losses are driven primarily by spot, followed by

Atlantic menhaden, blue crab, and stone crab, and total $23 thousand, as shown in Table 6-11. Applying a

3 percent discount rate, the annualized benefits of eliminating baseline I&E mortality losses are estimated

to be $21 thousand. Applying a 7 percent rate, these annualized benefits are $20 thousand.

As shown in Table 6-11, annual commercial harvest is estimated to increase by approximately 84

thousand pounds under Options 2 and 3 and 45 thousand pounds under Option 1. Discounted at 3 percent,

the estimated annualized benefits to commercial fishers are $12 thousand under Options 2 and 3, and $8

thousand under Option 1. Discounted at 7 percent, the estimated annualized benefits to commercial

fishers are approximately $8 thousand under Options 2 and 3, and $7 thousand under Option 1 (Table

6-11). Appendix Table H-4 presents species-specific results for the estimated annual increase in harvest

and monetary benefits to commercial fishers.
March 28, 2011 6-14

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 6-11: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E

Mortality Losses at In-Scope Facilities in the South Atlantic Region, by Regulatory

Option (2009$)

Undiscounted 3% Discount Rate 7% Discount Rate

Baseline 99 23 21 20

Option 1 45 10 8 7

Option 2 84 20 12 8

Option 3 84 20 12 8

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere

Regulatory Option

Annual Increase in

Commercial Harvest

(thousand lbs)

Annualized Benefits from Increase in Commercial Harvest

(2009$, thousands)

6.2.5 Gulf of Mexico

Baseline levels of I&E mortality account for more than 5,559 thousand pounds of commercial fishing

losses in the Gulf of Mexico region annually, as shown in Table 6-12. These losses are driven by black

drum, Atlantic menhaden, and striped mullet. The estimated undiscounted annual commercial fishing

benefits from eliminating baseline I&E mortality losses are approximately $3,747 thousand, as shown in

Table 6-12. Applying a 3 percent discount rate, estimated commercial fishing benefits from eliminating

baseline I&E mortality losses are estimated to be $3,463 thousand. Applying a 7 percent rate, these

annualized losses are approximately $3,450 thousand.

As shown in Table 6-12, annual commercial harvest is estimated to increase by approximately 4,400

thousand pounds under Options 2 and 3, and 1,500 thousand pounds under Option 1. Discounted at 3

percent, the estimated annualized benefits to commercial fishers are approximately $588 thousand under

Option 1 and $1,800 under Options 2 and 3. Discounted at 7 percent, the annualized benefits to

commercial fishers are estimated to be approximately $1,400 thousand under Options 2 and 3, and $537

thousand under Option 1 (Table 6-12). Appendix Table H-5 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 I&E

Mortality Losses at In-Scope Facilities in the Gulf of Mexico Region, by Regulatory

Option (2009$)

Undiscounted 3% Discount Rate 7% Discount Rate

Baseline 5,559 3,747 3,463 3,450

Option 1 1,459 719 588 537

Option 2 4,364 2,832 1,806 1,394

Option 3 4,371 2,837 1,804 1,390

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere

Regulatory Option

Annual Increase in

Commercial Harvest

(thousand lbs)

Annualized Benefits from Increase in Commercial Harvest

(2009$, thousands)
March 28, 2011 6-15

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

6.2.6 The Great Lakes

Baseline levels of I&E mortality account for more than 346 thousand pounds of commercial fishing losses

in the Great Lakes region annually, as shown in Table 6-13. These losses are driven by the impingement

of smelts and whitefish. The annual undiscounted commercial fishing benefits from eliminating baseline

I&E mortality losses in this region are estimated to be approximately $87 thousand, as shown in Table

6-13. Total annualized commercial benefits from eliminating baseline I&E mortality losses, applying a 3

percent discount rate, are estimated to be $80 thousand. Applying a 7 percent rate, these annualized losses

are approximately $80 thousand as well.

As shown in Table 6-13, annual commercial harvest is estimated to increase by approximately 330

thousand pounds under Options 2 and 3, and 227 thousand pounds under Option 1. The increase in

commercial harvest under Option 1 is relatively close to Options 2 and 3 due to the relative importance of

impingement mortality compared to total I&E mortality in the Great Lakes region. Discounted at 3

percent, the estimated annualized benefits to commercial fishers are approximately $53 thousand under

Options 2 and 3 and by $48 thousand under Option 1. Discounted at 7 percent, the annualized benefits to

commercial fishers are estimated to be approximately $44 thousand under Option 1 and $41 thousand

under Options 2 and 3 (Table 6-13). Appendix Table H-6 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 I&E

Mortality Losses at In-Scope Facilities in the Great Lakes Region, by Regulatory Option

(2009$)

Undiscounted 3% Discount Rate 7% Discount Rate

Baseline 346 87 80 80

Option 1 227 58 48 44

Option 2 326 82 53 41

Option 3 328 83 53 41

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere

Regulatory Option

Annual Increase in

Commercial Harvest

(thousand lbs)

Annualized Benefits from Increase in Commercial Harvest

(2009$, thousands)
March 28, 2011 6-16

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

6.3 Limitations and Uncertainties

Table 6-14 summarizes the caveats, omissions, biases, and uncertainties known to affect the estimates that

were developed for the benefits analysis.

Table 6-14: Caveats, Omissions, Biases, and Uncertainties in the Commercial Benefits Estimates

Issue Impact on Benefits Estimate Comments

Change in commercial landings due to

I&E mortality is uncertain Uncertain

Projected changes in harvest may be

underestimated because cumulative

impacts of I&E mortality over time,

interactions with other stressors, and

population changes are not considered.

Some estimates of commercial harvest

losses due to I&E mortality under current

conditions are not region/species-specific

Uncertain

EPA estimated the impact of I&E

mortality in the case study analyses

based on data provided by the facilities.

The most current data available were

used. However, in some cases these data

are 20 years old or older. Thus, they may

not reflect current conditions.

Effect of change in stocks on landings is

not considered Uncertain

EPA assumed a linear stock to harvest

relationship, so that a 10% change in

stock would have a 10% 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 assumes that NMFS landings data

are accurate and complete. In some cases

prices and/or quantities may be reported

incorrectly.
March 28, 2011 7-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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 impingement and entrainment mortality (I&E mortality) under the

regulatory options considered for the Section 316(b) regulation. For this analysis, 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). Because 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 often the only remaining option for providing

information to inform policy decisions. 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 2000a). These 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 have been increasingly explored by economists as a potential basis of

policy analysis conducted by various government agencies charged with the stewardship of natural

resources. 29

Section 7.2 provides a brief overview of the benefit transfer methodology used for estimating the

recreational fishing benefits, and highlights the updates to methodology. 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 is employed in this analysis. 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 I&E mortality at cooling water intake

structures (CWISs) at the in-scope facilities includes the following general steps:

1. Estimate the forgone catch of recreational fish (in number of fish) attributable to I&E

mortality under current conditions. EPA modeled these losses using the methods presented in

29 Meta-analysis is “the statistical analysis of a large collection of results from individual studies for the purposes of integrating

the findings” (Glass 1976).
March 28, 2011 7-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Chapter 3 of this document. EPA’s estimates of recreational fish losses are expressed as the

number of harvestable adults, rather than age-1 equivalents (A1Es), so as to not overstate the

increases in catch resulting from 316(b) regulatory options.30 Many of the fish species affected by

I&E mortality at CWIS sites are harvested both recreationally and commercially. EPA used the

proportion of total species landings attributable to recreational fishing to estimate baseline

welfare losses to recreational anglers from current levels of I&E mortality and benefits from

reducing I&E mortality under alternative policy options.

2. Estimate the marginal value per fish. EPA used the estimated meta-regression described in

Chapter A5 of EPA (USEPA 2006b) to estimate marginal values per fish for the species affected

by I&E mortality at Phase II 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 I&E mortality under the baseline

scenario by multiplying the marginal value per fish by the number of recreational fish currently

lost to I&E mortality that would otherwise be caught by recreational anglers.

4. Estimate recreational fishing benefits from reducing I&E mortality losses at the in-scope

facilities’ CWISs by multiplying the marginal value per fish by the reduction in recreational

fishing losses under the alternative policy options.

7.2.1 Estimating Marginal Value per Fish

To estimate marginal values per fish for the species affected by I&E mortality at in-scope facilities, EPA

used a benefit transfer function based on meta-analysis of recreational fishing studies from the Section

316(b) Phase III Final Rule. The general approach follows standard methods illustrated by Johnston et al.

(2006) and Shrestha et al. (2007), among many others (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) (Eq. 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 in-scope facilities, 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. Table 7-1 provides the independent variable names, the estimated

variable coefficients (coefficienti), and the assigned input values for each of the independent variables in

the model.

30 Adult fish of harvestable age means that they are the age at which they can legally be harvested.
March 28, 2011 7-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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 alternative specifications. This

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 is given the value of 9.37, which corresponds to the average study year, 1985.

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 primarily due to

omitted variables, the error term should be included, but if the error is primarily due to random

preferences, it should be excluded. EPA did not conclude whether the error is primarily due to omitted

variables or random preferences. Because the error term is positive, the empirical effect of including this

term is to increase the predicted marginal values. Therefore, EPA excluded the error term in order to

result in more- conservative estimates. EPA also 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 and

Table 7-3 presents the estimated marginal value per fish for all species affected by I&E mortality in each

region.

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

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

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_year 0.08754 0

tc_year -0.03965 0

RUM_year -0.00291 9.37

RUM_year was set equal to the average value across the studies in

the analysis, 9.37.

sp_mail 0.5440 0

sp_phone 1.0859 0

Since RUM_nest was the model specified above, sp_mail and

sp_phone were set to zero.

high_resp_rate -0.6539 1 High survey response rates are desirable because they may provide

more-accurate estimates, so high_response_rate was set to one.

inc_thou 0.003872 Varies 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

age43_up 1.2221 0.2711

Age42_down and age43_up were set to their sample means.

trips19_down 0.8392 0.1100

trips20_up -1.0112 0.3350

Trips19_down and trips20_up were set to their sample means.

nonlocal 3.2355 0

Because the default (zero) value for the nonlocal dummy variable

represents a combination of local and nonlocal anglers, nonlocal

was set to zero.
March 28, 2011 7-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 7-1: Independent Variable Assignments for Regression Equation

Variable Coefficient Assigned Value Explanation

big_game_pac 2.2530 Varies

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_more

y

5.2689 Varies

salmon_GL 2.2135 Varies

steelhead_pac 2.1904 Varies

steelhead_GL 2.3393 Varies

Species-targeted variables were assigned input values based on

characteristics of the species affected by I&E mortality and the

study region. In general, the match between the affected species

and the variables in the meta-analysis equation was good.

cr_nonyear -0.08135 Varies

cr_year -0.05208 0

catch_year 1.2693 0

spec_cr 0.6862 1

The variable cr_nonyear 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. The variable spec_cr was set to one. Cr_year and

catch_year were set to zero, since catch per trip and catch per day

are more common measures of angling quality.

shore -0.1129 Varies

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 (2006b)
March 28, 2011 7-5

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 7-2: Region- and Species-specific Variable Assignments for the Regression Equation

Region

Variable 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

Species Species Type

Dummy Variablea Baseline Catch Rate, Expressed in Fish per Day (cr_nonyear)

Small gameb

small_game_atl,

small_game_pac

2.7 1.6 1.6 2.2 2.2 2.1

Flatfishc

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

Panfishd4.7 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 This column indicates which species type dummy variable was set to one to represent each species.

b

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.

c

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.

d To indicate that the target species was “panfish,” all species type dummy variables were set to zero.

Source: U.S. EPA (2006b)

Table 7-3: Marginal Recreational Value per Fish, by Region and Speciesa

Species California North Atlantic Mid-Atlantic South

Atlantic

Gulf of

Mexico Great Lakes Inland

Small game $7.23 $5.92 $5.88 $5.70 $5.61 $5.34

Flatfish $9.73 $5.94 $5.60 $5.60

Other saltwater $2.95 $2.97 $2.91 $2.84 $2.76

Salmon $13.22 $13.22

Walleye/pike $4.10 $4.09

Bass $8.53 $8.98

Panfish $1.06 $1.32 $1.06

Trout $9.41 $2.81

Unidentified $3.09 $3.00 $3.23 $2.86 $3.65 $6.20 $2.22

a All values are in 2009$.

Source: U.S. EPA (2006b), converted to 2009$ using the Consumer Price Index (USBLS 2010),

7.2.2 Calculating Recreational Fishing Benefits

EPA estimated the recreational welfare gain from eliminating current I&E mortality losses and the

recreational welfare gain from the regulatory options by combining estimates of the marginal value per

fish with the estimated recreational fishing losses under the baseline level of I&E mortality and the

reduction in recreational fishing losses attributable to each regulatory option. To calculate the recreational
March 28, 2011 7-6

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

welfare gain from eliminating baseline I&E mortality losses, EPA multiplied the marginal value per fish

by the number of fish that are lost due to baseline I&E mortality that would otherwise be caught by

recreational anglers. To calculate the recreational welfare gain from each analyzed option, 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 of this report, 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 an empirical distribution of WTP

values is constructed. 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 bounds for the

WTP for improvements in recreational catch rates from eliminating baseline I&E mortality losses or

reducing I&E mortality losses under each regulatory analysis option. Refer to EPA (2006b) 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 greater than $1 per fish.
March 28, 2011 7-7

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 7-4: Confidence Bounds on Marginal Recreational Value per Fish, Based on the

Krinsky and Robb Approacha

Species California North

Atlantic

MidAtlanticSouth

Atlantic

Gulf of

Mexico

Great

Lakes Inland

5

th Percentile Lower Confidence Boundsb

Small game $4.19 $2.12 $2.26 $2.71 $2.86 $1.60

Flatfish $5.10 $3.80 $3.74 $3.86

Other saltwater $1.78 $1.78 $1.84 $2.14 $2.13

Salmon $8.40 $8.12 $8.12

Walleye/pike $2.17 $11.98

Bass $4.41 $4.27

Panfish $0.53 $0.69 $0.53

Trout $6.08 $1.51

Unidentified $1.85 $1.80 $1.90 $2.14 $2.36 $3.32 $1.08

95th Percentile Upper Confidence Boundsb

Small game $12.40 $16.70 $15.46 $11.99 $11.00 $18.00

Flatfish $18.56 $9.40 $8.49 $8.25

Other saltwater $4.87 $4.96 $4.58 $3.77 $3.60

Salmon $28.70 $21.53 $21.53

Walleye/pike $7.77 $8.49

Bass $16.56 $19.01

Panfish $2.10 $2.48 $2.10

Trout $14.61 $5.27

Unidentified $5.16 $5.01 $5.71 $3.81 $5.89 $11.67 $4.58

a All values are in 2009$.

b Upper and lower confidence bounds based on results of the Krinsky and Robb (1986) approach.

Source: U.S. EPA (2006b), converted to 2009$ using the Consumer Price Index (USBLS 2010).

7.3 Benefits Estimates for Recreational Fishing by Region

7.3.1 California

Table 7-5 shows the results of EPA’s analysis of the recreational fishing losses from I&E mortality under

the baseline conditions at in-scope facilities in California. Baseline recreational fishing losses from I&E

mortality in the California region amount to 1.0 million fish per year. The majority of recreational losses

from I&E mortality under baseline conditions are attributable to entrainment of rockfish and sea bass.

Table 7-5 shows the results of EPA’s analysis of the potential welfare gain to recreational anglers from

eliminating baseline recreational fishing losses at in-scope facilities in California. The estimated mean

annual welfare gain to California anglers from eliminating all of these losses is $2.9 million and $2.8

million evaluated at 3 percent and 7 percent discount rates, respectively. The majority of the monetized

recreational benefits from eliminating baseline I&E mortality are attributable to eliminating entrainment

of “other saltwater” fish31. Appendix I presents additional species-specific results.

31 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.
March 28, 2011 7-8

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

As shown in Table 7-5, the estimated reduction in I&E mortality leads to an estimated annual increase in

recreational fishery harvest of less than 0.1 million fish under Option 1 and approximately 0.9 million fish

per year under Options 2 and 3. Discounted at 3 percent, the estimated mean annualized welfare gain to

California anglers is approximately $0.1 million under Option 1, $1.7 million under Option 2, $1.8

million under Option 3. Discounted at 7 percent, the estimated mean annualized welfare gain is $1.3

million and $1.4 million under Options 2 and 3, and $0.1 million under Option 1 (Table 7-5). Appendix I

presents additional species-specific results.

Table 7-5: Recreational Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality

Losses at In-Scope Facilities in the California Region, by Regulatory Option (2009$)

5

th Mean 95th 5th Mean 95th

Baseline 1,022,339 $1,740 $2,923 $4,917 $1,681 $2,823 $4,750

Option 1 36,438 $51 $85 $141 $46 $75 $125

Option 2 876,841 $1,037 $1,741 $2,929 $792 $1,330 $2,237

Option 3 915,750 $1,096 $1,840 $3,095 $832 $1,396 $2,349

Annual Increase in

Recreational Harvest

(harvestable adult fish)

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere; Option 4 = I for Facilities > 50 MGD

Regulatory

Option 3 % Discount Rate 7 % Discount Rate

Annualized Benefits from Increase in Recreational Harvest

(2009$, thousands)

7.3.2 North Atlantic Region

Table 7-6 shows the results of EPA’s analysis of the recreational fishing losses from I&E mortality under

the baseline conditions at in-scope facilities in the North Atlantic region. Baseline recreational fishing

losses from I&E mortality in the North Atlantic region amount to 0.8 million fish per year. The majority

of recreational losses from I&E mortality under baseline conditions are attributable to entrainment of

winter flounder, cunner, and sculpin. Table 7-6 shows the results of EPA’s analysis of the potential

welfare gain to recreational anglers from eliminating baseline recreational fishing losses at in-scope

facilities in the North Atlantic. The estimated mean annual welfare gain to North Atlantic anglers from

eliminating all of these losses is $2.8 million and $2.7 million evaluated at 3 percent and 7 percent

discount rates, respectively. The majority of the monetized recreational benefits from eliminating baseline

I&E mortality are attributable to eliminating the entrainment of “flatfish” and “other saltwater” fish.

Appendix I presents additional species-specific results.

As shown in Table 7-6, the estimated reduction in I&E mortality leads to an estimated annual increase in

recreational fishery harvest of less than 0.1 million fish under Option 1, 0.6 million fish under Option 2,

and 0.7 million fish under Option 3. Discounted at 3 percent, the estimated mean annualized welfare gain

to North Atlantic anglers is less than $0.1 million under Option 1, $1.5 million under Option 2, and $1.6

million under Option 3. Discounted at 7 percent, the estimated mean annualized welfare gain is less than

$0.1 million under Option 1, $1.1 million under Option 2, and $1.2 million under Option 3 (Table 7-6).

Appendix I presents additional species-specific results.
March 28, 2011 7-9

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 7-6: Recreational Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality

Losses at In-Scope Facilities in the North Atlantic Region, by Regulatory Option (2009$)

5

th Mean 95th 5th Mean 95th

Baseline 761,183 $1,765 $2,838 $4,596 $1,705 $2,742 $4,440

Option 1 1,495 $3 $5 $9 $3 $5 $8

Option 2 620,929 $939 $1,510 $2,446 $698 $1,122 $1,817

Option 3 651,307 $1,018 $1,638 $2,652 $756 $1,216 $1,969

Annual Increase in

Recreational Harvest

(harvestable adult fish)

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere; Option 4 = I for Facilities > 50 MGD

Regulatory

Option

Annualized Benefits from Increase in Recreational Harvest

(2009$, thousands)

3 % Discount Rate 7 % Discount Rate

7.3.3 Mid-Atlantic Region

Table 7-7 shows the results of EPA’s analysis of the recreational fishing losses from I&E mortality under

the baseline conditions at in-scope facilities in the Mid-Atlantic region. Baseline recreational fishing

losses from I&E mortality in the Mid-Atlantic region amount to 9.1 million fish per year. The majority of

recreational losses from I&E mortality under baseline conditions are attributable to I&E mortality of spot,

Atlantic croaker, and “other saltwater” fish. Table 7-7 shows the results of EPA’s analysis of the potential

welfare gain to recreational anglers from eliminating baseline recreational fishing losses at in-scope

facilities in the Mid-Atlantic. The estimated mean annual welfare gain to Mid-Atlantic anglers from

eliminating all of these losses is $25.6 million and $24.7 million evaluated at 3 percent and 7 percent

discount rates, respectively. The majority of the monetized recreational benefits from eliminating baseline

I&E mortality are attributable to eliminating the entrainment of other saltwater fish. Appendix I presents

additional species-specific results.

As shown in Table 7-7, the estimated reduction in I&E mortality leads to an estimated annual increase in

recreational fishery harvest of approximately 0.6 million fish under Option 1, 8.4 million fish under

Option 2, and 8.5 million fish under Option 3. Discounted at 3 percent, the estimated mean annualized

welfare gain to Mid-Atlantic anglers is $14.1 million and $14.4 million under Options 2 and 3, and $1.6

million under Option 1. Discounted at 7 percent, the estimated mean annualized welfare gain is $9.8

million and $10.0 million under Options 2 and 3, and $1.4 million under Option 1 (Table 7-7). Appendix

I presents additional species-specific results.

Table 7-7: Recreational Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality

Losses at In-Scope Facilities in the Mid-Atlantic Region, by Regulatory Option (2009$)

5

th Mean 95th 5th Mean 95th

Baseline 9,081,061 $15,239 $25,569 $44,467 $14,721 $24,701 $42,958

Option 1 549,015 $846 $1,577 $3,136 $749 $1,396 $2,776

Option 2 8,359,591 $8,381 $14,073 $24,501 $5,831 $9,792 $17,049

Option 3 8,459,880 $8,584 $14,410 $25,078 $5,975 $10,030 $17,456

Annual Increase in

Recreational Harvest

(harvestable adult fish)

Regulatory

Option

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere; Option 4 = I for Facilities > 50 MGD

Annualized Benefits from Increase in Recreational Harvest

(2009$, thousands)

3 % Discount Rate 7 % Discount Rate
March 28, 2011 7-10

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

7.3.4 South Atlantic Region

Table 7-8 shows the results of EPA’s analysis of the recreational fishing losses from I&E mortality under

the baseline conditions at in-scope facilities in the South Atlantic region. Baseline recreational fishing

losses from I&E mortality in the South Atlantic region amount to 0.1 million fish per year. The majority

of recreational losses from I&E mortality under baseline conditions are attributable to I&E mortality of

“other saltwater” fish, especially spot and croakers. Table 7-8 shows the results of EPA’s analysis of the

potential welfare gain to recreational anglers from eliminating baseline recreational fishing losses at inscope facilities in the South Atlantic. The estimated mean annual welfare gain to South Atlantic anglers

from eliminating all of these losses is approximately $0.3 million evaluated at both 3 percent and 7

percent discount rates. The majority of the monetized recreational benefits from eliminating baseline I&E

mortality are attributable to eliminating impingement of “other saltwater” fish. Appendix I presents

additional species-specific results.

As shown in Table 7-8, the estimated reduction in I&E mortality leads to an estimated annual increase in

recreational fishery harvest of approximately 0.1 million fish under Options 2 and 3, and less than 0.1

million fish per year under Option 1. Discounted at 3 percent, the estimated mean annualized welfare gain

to South Atlantic anglers is $0.2 million under Options 2 and 3, and less than $0.1 million under Option 1.

Discounted at 7 percent, the estimated mean annualized welfare gain is $0.1 million under Options 2 and

3, and less than $0.1 million under Option 1 (Table 7-8). Appendix I presents additional species-specific

results.

Table 7-8: Recreational Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality

Losses at In-Scope Facilities in the South Atlantic Region, by Regulatory Option (2009$)

5

th Mean 95th 5th Mean 95th

Baseline 133,897 $257 $346 $469 $249 $335 $453

Option 1 15,882 $28 $37 $50 $24 $33 $45

Option 2 112,139 $141 $190 $257 $103 $139 $188

Option 3 112,301 $141 $190 $257 $103 $139 $188

Annual Increase in

Recreational Harvest

(harvestable adult fish)

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere; Option 4 = I for Facilities > 50 MGD

Regulatory

Option

Annualized Benefits from Increase in Recreational Harvest

(2009$, thousands)

3 % Discount Rate 7 % Discount Rate

7.3.5 Gulf of Mexico

Table 7-9 shows the results of EPA’s analysis of the recreational fishing losses from I&E mortality under

the baseline conditions at in-scope facilities in the Gulf of Mexico region. Baseline recreational fishing

losses from I&E mortality in the Gulf of Mexico region amount to 2.9 million fish per year. The majority

of recreational losses from I&E mortality under baseline conditions are attributable to the impingement of

spotted seatrout and the entrainment of black drum and “other saltwater” fish. Table 7-9 shows the results

of EPA’s analysis of the potential welfare gain to recreational anglers from eliminating baseline

recreational fishing losses at in-scope facilities in the Gulf of Mexico. The estimated mean annual welfare

gain to Gulf of Mexico anglers from eliminating all of these losses is $8.9 million and $8.8 million

evaluated at 3 percent and 7 percent discount rates, repectively. The majority of the monetized

recreational benefits from eliminating baseline I&E mortality are attributable to both the impingement of
March 28, 2011 7-11

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

“small game” fish and the entrainment of “other saltwater” species. Appendix I presents additional

species-specific results.

As shown in Table 7-9, the estimated reduction in I&E mortality leads to an estimated annual increase in

recreational fishery harvest of approximately 2.2 million fish under Options 2 and 3, and 0.7 million fish

per year under Option 1. Discounted at 3 percent, the estimated mean annualized welfare gain to Gulf of

Mexico anglers is $2.4 million under Option 1, and $4.9 million under Options 2 and 3. Discounted at 7

percent, the estimated mean annualized welfare gain is $2.2 million under Option 1, and $3.8 million

under Options 2 and 3 (Table 7-9). Appendix I presents additional species-specific results.

Table 7-9: Recreational Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality

Losses at In-Scope Facilities in the Gulf of Mexico Region, by Regulatory Option (2009$)

5

th Mean 95th 5th Mean 95th

Baseline 2,851,347 $6,022 $8,852 $13,506 $5,999 $8,818 $13,456

Option 1 665,697 $1,398 $2,422 $4,334 $1,275 $2,210 $3,953

Option 2 2,204,063 $3,225 $4,866 $7,642 $2,491 $3,760 $5,908

Option 3 2,208,009 $3,258 $4,906 $7,690 $2,510 $3,781 $5,926

Annual Increase in

Recreational Harvest

(harvestable adult fish)

Regulatory

Option

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere; Option 4 = I for Facilities > 50 MGD

3 % Discount Rate

Annualized Benefits from Increase in Recreational Harvest

(2009$, thousands)

7 % Discount Rate

7.3.6 Great Lakes Region

Table 7-10 shows the results of EPA’s analysis of the recreational fishing losses from I&E mortality

under the baseline conditions at in-scope facilities in the Great Lakes region. Baseline recreational fishing

losses from I&E mortality in the Great Lakes region amount to 0.3 million fish per year. The majority of

recreational losses from I&E mortality under baseline conditions are attributable to impingement of

whitefish and entrainment of “unidentified” species. Table 7-10 shows the results of EPA’s analysis of the

potential welfare gain to recreational anglers from eliminating baseline recreational fishing losses at inscope facilities in the Great Lakes. The estimated mean annual welfare gain to Great Lakes anglers from

eliminating all of these losses is $2.0 million evaluated at both 3 percent and 7 percent discount rates. The

majority of the monetized recreational benefits from eliminating baseline I&E mortality are attributable to

eliminating the impingement of “other trout” and “unidentified” fish. Appendix I presents additional

species-specific results.

As shown in Table 7-10, the estimated reduction in I&E mortality leads to an estimated annual increase in

recreational fishery harvest of approximately 0.2 million fish per year under Option 1, and 0.3 million fish

under Options 2 and 3. Discounted at 3 percent, the estimated mean annualized welfare gain to Great

Lakes anglers is $1.3 million under Options 2 and 3, and $1.0 million under Option 1. Discounted at 7

percent, the estimated mean annualized welfare gain is $1.0 million under Options 2 and 3, and $0.9

million under Option 1 (Table 7-10). Appendix I presents additional species-specific results.
March 28, 2011 7-12

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 7-10: Recreational Fishing Benefits from Eliminating or Reducing Baseline I&E

Mortality Losses at In-Scope Facilities in the Great Lakes Region, by Regulatory Option

(2009$)

5

th Mean 95th 5th Mean 95th

Baseline 349,648 $1,127 $1,984 $3,544 $1,123 $1,977 $3,530

Option 1 176,089 $561 $951 $1,638 $511 $867 $1,495

Option 2 317,974 $720 $1,261 $2,241 $559 $979 $1,739

Option 3 320,196 $725 $1,271 $2,261 $561 $984 $1,750

Annual Increase in

Recreational Harvest

(harvestable adult fish)

Regulatory

Option

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere; Option 4 = I for Facilities > 50 MGD

Annualized Benefits from Increase in Recreational Harvest

(2009$, thousands)

3 % Discount Rate 7 % Discount Rate

7.3.7 Inland Region

Table 7-11 shows the results of EPA’s analysis of the recreational fishing losses from I&E mortality

under the baseline conditions at in-scope facilities in the Inland region. Baseline recreational fishing

losses from I&E mortality in the Inland region amount to 12.6 million fish per year. The majority of

recreational losses from I&E mortality under baseline conditions are attributable to I&E mortality of

“bass,” “panfish,” and “unidentified” species groups. Table 7-11 shows the results of EPA’s analysis of

the potential welfare gain to recreational anglers from eliminating baseline recreational fishing losses at

in-scope facilities in the Inland region. The estimated mean annual welfare gain to Inland anglers from

eliminating all of these losses is $34.4 million and $34.2 million evaluated at 3 percent and 7 percent

discount rates, respectively. The majority of the monetized recreational benefits from eliminating baseline

I&E mortality are attributable to eliminating I&E mortality of “bass,” “panfish,” and “unidentified” fish.

Appendix I presents additional species-specific results.

As shown in Table 7-11, the estimated reduction in I&E mortality leads to an estimated annual increase in

recreational fishery harvest of approximately 11.1 million fish and 11.4 million fish under Options 2 and

3, and 4.7 million fish per year under Option 1. Discounted at 3 percent, the estimated mean annualized

welfare gain to Inland anglers is $19.9 million and $20.7 million under Options 2 and 3, and $10.5

million under Option 1. Discounted at 7 percent, the estimated mean annualized welfare gain is $9.6

million under Option 1, $15.3 million under Option 2, and $15.8 million under Option 3 (Table 7-11).

Appendix I presents additional species-specific results.
March 28, 2011 7-13

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 7-11: Recreational Fishing Benefits from Eliminating or Reducing Baseline I&E

Mortality Losses at In-Scope Facilities in the Inland Region, by Regulatory Option (2009$)

5

th Mean 95th 5th Mean 95th

Baseline 12,592,464 $16,566 $34,376 $71,653 $16,504 $34,247 $71,384

Option 1 4,321,037 $5,071 $10,545 $22,049 $4,626 $9,619 $20,115

Option 2 11,061,370 $9,578 $19,879 $41,449 $7,361 $15,277 $31,856

Option 3 11,389,049 $9,966 $20,684 $43,122 $7,592 $15,755 $32,847

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere; Option 4 = I for Facilities > 50 MGD

Annual Increase in

Recreational Harvest

(harvestable adult fish)

Regulatory

Option

Annualized Benefits from Increase in Recreational Harvest

(2009$, thousands)

3 % Discount Rate 7 % Discount Rate

7.4 Limitations and Uncertainties

A number of limitations and uncertainties are common to all WTP values predicted using benefit transfer.

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.” This procedure was used 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

the elimination of baseline I&E mortality losses and 316(b) regulatory options.

Specific limitations and uncertainties associated with the estimated regression model and the underlying

studies are discussed in Section A5-3.3 of EPA (2006b). Additional limitations and uncertainties

associated with implementation of the meta-analysis approach are addressed below.

7.4.1 Variable Assignments for Independent Regressors

The per-fish values estimated from the model depend on the values of the input variables in the metaanalysis. EPA assigned values to the input variables based on established economic theory and

characteristics of the affected species and regions. However, because the input values for some variables

are uncertain, the resulting per-fish values and benefits estimates also include some degree of uncertainty.

7.4.2 Exclusion of Error Term from Regression Equation to Predict Marginal Values

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 source of econometric error in an equation is

primarily due to omitted variables, the error term should be included, but if the error is primarily due to

random preferences, it should be excluded. EPA did not conclude whether the error is primarily due to

omitted variables or random preferences. Because the error term is positive, the empirical effect of

including this term is to increase the predicted marginal values. Therefore, EPA excluded the error term in

order to result in more- conservative estimates. EPA also notes that when the error term is excluded, the

values predicted by the regression equation are more consistent with those from the underlying studies.

This indicates that convergent validity is greater when the error term is excluded.
March 28, 2011 7-14

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

7.4.3 Other Limitations and Uncertainties

In addition to the limitations and uncertainties involved with the study data and model estimation, which

are discussed in Section A5-3.3e of EPA (2006b), there are limitations and uncertainties involved 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 regulatory options considered for the final Section 316(b) regulation for existing

Phase II facilities.

The validity and reliability of benefit transfer—including that based on meta-analysis—depends on a

variety of factors. While benefit transfer can provide valid measures of use benefits, tests of its

performance have provided 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 metaanalysis model presented here provides a close but not perfect match to the context in which values are

desired.

The final area of uncertainty related to the use of the regression results to calculate regulatory benefits is

uncertainty in the estimates of I&E mortality. There are a number of reasons why recreational losses due

to I&E mortality may be higher or lower than expected. Projected changes in recreational catch may be

underestimated because cumulative impacts of I&E mortality over time are not considered. In particular,

I&E mortality estimates include only individuals directly lost to I&E mortality, not their progeny.

Additionally, the interaction of I&E mortality 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

I&E mortality data available provided by facilities, which in some cases may not reflect current

conditions.
March 28, 2011 8-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

8 Nonuse Benefits of Reducing I&E Mortality

8.1 Introduction

Comprehensive estimates of total resource value include both use and nonuse values, such that the

resulting total value estimate 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 substantial 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.” Consequently, 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 2000a; USOMB 2003).

The vast majority (97 percent) of current (i.e., baseline) impingement and entrainment mortality (I&E

mortality) losses at cooling water intake structures (CWISs) consist of forage species or unlanded

individuals of recreational and commercial species (Chapter 3). Although these forage fish and unlanded

fish do not have direct use values, they may be valued by users (commercial fishers and recreational

anglers) and nonusers of fisheries resources. Additionally, the nonuse values are likely to be substantial,

because fish and other species found within aquatic habitats impacted directly and indirectly by CWISs

provide other valuable ecosystem goods and services, including nutrient cycling and ecosystem stability.

Therefore, a comprehensive estimate of the welfare gain from reducing I&E mortality losses must include

an estimate of nonuse benefits.

The following sections present EPA’s qualitative and quantitative assessments of nonuse benefits. EPA

qualitatively evaluated the public’s nonuse values for aquatic habitats by considering evidence from

existing aquatic restoration and protection programs (Section 8.2). This chapter also presents EPA’s

benefit transfer approach for the quantification of nonuse benefits associated with reductions in I&E

mortality of fish, shellfish, and other aquatic organisms under the 316(b) regulatory options in the North

Atlantic and Mid-Atlantic Regions (Section 8.3). Section 8.4 presents estimated nonuse benefits under the

316(b) regulatory options.

8.2 Public Policy Significance of Ecological Improvements from the

Proposed 316(b) Regulation for Existing Facilities

Changes to CWIS design and operation resulting from 316(b) regulation of existing facilities is expected

to reduce I&E mortality losses of fish, shellfish, and other aquatic organisms. These direct benefits are

believed to lead to increases in local and regional fishery populations and ecosystem stability. Moreover,

many indirect ecosystem goods and services are affected by I&E mortality, thermal effects, and flow

alteration. Due to the wide-ranging nature of these indirect effects, EPA believes that regulation is likely

to enhance the value of ecosystem goods and services provided by aquatic habitats, and that regulation

will help reduce the overall impact of anthropogenic effects on aquatic systems affected by CWISs. Table

2-4 provides a detailed list of ecosystem services potentially affected by the proposed 316(b) regulation.
March 28, 2011 8-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

EPA assessed the potential magnitude of nonuse benefits that are quantified, but not monetized using

information regarding government spending on the protection, restoration, and regulation of various

aquatic habitats. This included Marine Protected Areas (Section 8.2.2) and a subset of freshwater

ecosystems undergoing large-scale restoration efforts (Section 8.2.3). This spending serves as a lower

bound of nonuse values in a subset of geographical locations

8.2.1 Effects on Depleted Fish Populations

EPA believes that reducing fish mortality from impingement and entrainment (I&E) would 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 impacts that affect fish populations include fishing, pollution, habitat changes, and I&E mortality

losses at CWISs. Fish populations decline when they are unable to sufficiently compensate for their

overall level of mortality. Although it is difficult to measure, EPA believes that 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 impingement and entrainment mortality

(I&E mortality) losses 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 its long-term health.

In some cases, I&E mortality losses may be a significant source of anthropogenic mortality to alreadydepleted stocks of commercially targeted species (see Table 2-3). Depleted saltwater fish stocks affected

by I&E mortality include winter flounder, Atlantic Cod, and rockfishes, for example (NMFS 2010a). As

discussed in Section 2.3.1, I&E mortality also increases the pressure on freshwater species native to the

Great Lakes, such as lake whitefish and yellow perch, whose populations have dramatically declined 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. Actions these governments have taken include 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 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.

To summarize, EPA believes that reducing fish mortality from I&E mortality along with other measures

would contribute to the recovery of damaged fish populations.

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 their broad focus on the preservation and maintenance of cultural and

natural resources, and/or sustainable production (NMPAC 2006). Consequently, evaluating the impact of

CWISs on the entire universe of MPAs may overstate the nonuse values for the ecological benefits

associated with reductions in I&E mortality. For this reason, EPA focused on MPAs within the National
March 28, 2011 8-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Estuary Program (NEP). The NEP was established in the 1987 amendments to the Clean Water Act

(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 2010a), EPA included facilities found in Chesapeake Bay (itself

protected by the Chesapeake Bay Program [CBP]).

Substantial federal and state resources have been directed to the NEP and Chesapeake Bay Program to

enhance conservation of and knowledge about estuaries. From 2005 to 2007, NEP budgeted $965 million

to protect and restore aquatic habitat, conduct outreach and research, upgrade stormwater infrastructure,

and implement other priority actions to benefit the health of the 28 constituent estuaries. Approximately

$130 million (13.5 percent) of the funding was designated for restoration programs (USEPA 2008).

Between fiscal years 1995 and 2004, direct funding by federal and state governments to restore

Chesapeake Bay averaged $366 million (GAO 2005), with an additional $131 million in direct spending

in fiscal year 2005 (CBP 2007). Moreover, recent governmental action is likely to increase federal

spending on restoration efforts in the future (Executive Order No. 13508 2009). All told, these

expenditures reflect high public values for restoring (or protecting) the biological integrity of these

ecosystems.

A total of 116 Section 316(b) facilities exist on 75 waterbodies within MPAs designed to preserve natural

resources and/or to ensure sustainable production (NOAA 2010b) (Figure 8-2; Table 8-1). Although these

facilities are found in fresh, brackish, and marine waters, and in all regions of the country except

California, the vast majority of 316(b) facilities occurring within MPAs occur in coastal waters, and are

most highly concentrated in the Northeastern United States (i.e. both coastal and inland facilities) (Figure

8-2; Table 8-1). Under Option 1, 87 percent of in-scope facilities found within MPAs obtain reductions in

impingement mortality (IM), while entrainment mortality (EM) is not reduced at any facilities (Table

8-1). Under Options 2 and 3, impingement mortality is reduced at 92 and 97 percent of 316(b) facilities in

MPAs, while the addition of closed-cycle cooling results in reduced entrainment mortality at 72 and 92

percent of in-scope facilities found in MPAs, respectively (Table 8-1).
March 28, 2011 8-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Figure 8-2: In-scope Facilities with CWISs Located In Marine Protected Areas.
March 28, 2011 8-5

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 8-1: 316(b) Facilities in Marine Protected Areas, and Improvements in I&E Mortality

Technologies by Regulatory Option

I

Mortality

E

Mortality

I

Mortality

E

Mortality

I

Mortality

E

Mortality

California 0 0 0 0 0 0 0 0

North Atlantic 18 9 17 0 19 16 20 20

Mid-Atlantic 24 10 40 0 41 31 43 40

South Atlantic 5 23 10 0 10 9 10 9

Gulf of Mexico 9 44 8 0 10 10 10 10

Great Lakes 3 20 8 0 9 8 9 9

Inland 14 10 18 0 18 9 20 18

Total 73 116 101 0 107 83 112 106

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for Facilities >

125 MGD; Option 3 = I&E Mortality Everywhere.

Option 2 Option 3

Number of Facilities with Improved Technologies by Policy Option

Benefits Region

Affected

Waterbodies

Baseline

316(b)

Facilitiesa

Option 1

8.2.3 Restoration of Freshwater Ecosystems

Reducing the effect of CWISs at 316(b) facilities is likely to benefit aquatic ecosystems nationwide, but

the largest magnitude of improvements may occur in areas of the Great Lakes Basin and Mississippi

River, with their high density of facilities. These freshwater bodies are subject to large-scale ecosystem

restoration efforts 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 2005-2009 (USFWS

2010d), and has initiated a 5-year multi-agency initiative to restore the ecosystems of the Great Lakes, for

which $475 million was appropriated in fiscal year 2010 (CEQ et al. 2010). 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 2004c). Additionally, substantial

federal funding for river restoration has been proposed for FY2011, with more than $730 million

requested for major projects in the Missouri, Mississippi, Columbia, and Kissimmee rivers (USOMB

2010a; USOMB 2010b). These projects include 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.

8.2.4 Summary of Evidence for Nonuse Values of Ecosystems Impacted by CWISs

Overall, the public appears to hold substantial nonuse values for ecosystems and species impacted by

CWISs. For example, governments at various levels have committed to the designation of MPAs at large

scales. Governments also have committed substantial resources to the restoration of degraded aquatic

ecosystems. This evidence suggests that the nonuse benefits of 316(b) regulation, although unquantified,

are substantial. Additional discussion of nonuse impacts occurring under baseline conditions is provided

in Chapter 2.
March 28, 2011 8-6

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

8.3 Quantitative Assessment of Ecological Nonuse Benefits

Stated preference (SP) methods and benefit transfers based on SP studies are the generally accepted

techniques for estimating nonuse values. SP methods rely on surveys that ask people to state their

willingness to pay (WTP) for particular ecological improvements, such as increased protection of aquatic

species or habitats with particular attributes. As mentioned above, EPA is in the process of developing a

SP survey to estimate total WTP for improvements to fishery resources affected by I&E mortality from

in-scope 316(b) facilities. This survey will provide estimates of total WTP which includes both use and

nonuse values, will allow estimates of value associated with specific choice attributes (following standard

methods for choice experiments), and will provide insight into the relative importance of use versus

nonuse values in the 316(b) context. EPA did not have sufficient time before this notice of proposed

rulemaking to fully develop and deploy this survey and thus derive estimates of the monetary value of

reducing I&E mortality impacts at the national level. In the absence of original study values, EPA

identified a recent SP study conducted by Johnston et al. (2009) that is closely related to the 316(b) policy

context. Johnston et al. (2009) developed a Bioindicator-Based Stated Preference Valuation (BSPV)

method specifically for applications to ecological systems.32 Like EPA’s planned survey, this study

addresses policy changes that introduce forage fish to aquatic habitat but for which ultimate population

effects are unknown. The study was originally developed to address Rhode Island residents’ preferences

for the restoration of migratory fish passage over dams within an in-state watershed. It estimates nonuse

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.

EPA used Johnston et al. (2009) to conduct a benefits transfer to quantify nonuse benefits associated with

reductions in I&E mortality under the 316(b) regulatory options for the North Atlantic and Mid-Atlantic

benefits regions. The study’s choice experiment allows direct estimation of households’ WTP for policies

that increase the number of fish in watersheds by changing human industrial uses of aquatic ecosystems.

Section 8.3.1 describes Johnston et al. (2009) and BSPV methods in greater detail. This is followed by a

description of EPA’s benefits transfer methods using Johnston et al. (2009) (Section 8.3.2) and estimated

benefits for 316(b) regulatory options (Section 8.4).

8.3.1 Description of Johnston et al. (2009) and BSPV Methods

Johnston et al. (2009) developed the BSPV method to promote ecological clarity and closer integration of

ecological and economic information within SP studies. The study’s focus on improved ecological

valuation is an EPA priority as described in findings of EPA’s Science Advisory Board 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. It 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 unambiguously linked to models and indicators of ecosystem function, are based on measurable

32 The study was funded by the EPA’s Science to Achieve Results (STAR) competitive grant program.
March 28, 2011 8-7

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

ecological outcomes, and are more easily incorporated into benefit cost analysis. It 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.

Johnston et al. (2009) developed the BSPV methods for a case study addressing public preferences for the

restoration of migratory fish passage in Rhode Island’s 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 to which there is currently no fish passage. 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; and 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 nonexperts. These included cognitive interviews (Kaplowitz et al. 2004), verbal protocols (Schkade and

Payne 1994) and other pretests conducted 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 cases, survey

development 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). Additional information was drawn 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 neither are 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 policy context of Johnston et al. (2009) 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 multiattribute 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 choice question is presented in Figure 8-

3. Prior to administration of the choice experiment questions, the survey provided information: (1)

describing the current status of Rhode Island river ecology and migratory fish compared to historical

baselines, (2) characterizing affected ecological systems and linkages, (3) describing the methods and

details of fish passage restoration, and (4) providing the definitions, derivations and interpretations of
March 28, 2011 8-8

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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.

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

included ecological indicators characterize: (1) the quantity of river habitat accessible to migratory fishes,

(2) the number of fish migrating to upstream habitat, (3) the abundance of fish suitable for recreational

harvest, (4) the abundance of fish-dependent wildlife, (5) and overall ecological condition.

8.3.2 Benefits Transfer Methodology

The following subsections describe EPA’s benefits transfer methods using the BSPV study. Section

8.3.2.1 describes the estimation of WTP for a percentage increase in fish numbers using the BSPV study,

and Section 8.3.2.2 describes the application of BSPV WTP values to I&E mortality reductions under

316(b) regulatory options.

8.3.2.1 Estimating WTP for a Percentage Increase in Fish Numbers

As shown in Figure 8-3, within Johnston et al. (2009)’s choice scenarios each ecological attribute is

expressed in relative terms with regard to upper and lower reference conditions (i.e., best and worst

possible in the Pawtuxet) as defined in survey informational materials. Relative scores represent percent

progress towards the upper reference condition (100 percent), starting from the lower reference condition

(0 percent). This also 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). The

number of fish affected by 316(b) regulations is many times larger than that considered by Johnston et al.

(2009) — therefore it would be inappropriate to apply the Johnston et al. (2009) values per fish to the

316(b) fish reduction estimates (which exceed the maximum reference condition for Johnston et al.

(2009)) to obtain a WTP value for this rulemaking. In order to conduct a benefit transfer that closely

follows Johnston et al. (2009)’s study design for the Pawtuxet Watershed, resource improvements should

be expressed as a percentage improvement relative to the existing resource condition. A variant of

Johnston et al.’s (2009) model was hence used to conduct a benefit transfer predicated on percentage

improvements in the fish condition, relative to the reference condition for each ecosystem. As

improvements are bounded by the 100 percent reference condition in all cases, this at least partially

ameliorates the scale concern described above. The remainder of this section describes EPA approach for

estimating WTP per percentage improvement based on Johnston et al. (2009).
March 28, 2011 8-9

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Figure 8-3: Example Choice Experiment Question from Johnston et al. (2009)
March 28, 2011 8-10

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

When specifying mixed logit models for SP choice experiments, economic theory provides guidance

regarding certain aspects of model specification. For example, the parameter on program cost is expected

to have a negative sign, reflecting a positive marginal utility of income. To ensure an appropriate sign for

this parameter within mixed logit models, a common solution is to specify a lognormal distribution on the

sign-reversed cost parameter. This solution, however, leads to well-known ambiguities for WTP

estimation related to the long right-hand tail of the lognormal distribution, and often unrealistic mean

WTP estimates over the entire distribution (Hensher and Greene 2003; Johnston and Duke 2007). As a

result of this well-established problem, Hensher and Greene (2003, p. 148) recommend alternatives

including the bounded triangular distribution for the program cost parameter.

Here, following Hensher and Greene (2003), the random utility model is estimated using maximum

likelihood ML with Halton draws in the likelihood simulation. Coefficients on program cost (cost) and

migrants (the percentage point increase in the number of migratory fish able to reach watershed habitat)

are important for estimating WTP for a percentage increase in fish numbers. Coefficients on all variables

except that on program cost (cost) are specified as random with a normal distribution. This includes the

variable migrants. The coefficient on annual household cost (cost) is specified as random with a bounded

triangular distribution as specified above with the mean equal to the spread (m=s), ensuring a positive

marginal utility of income. Sign-reversal is applied to the cost variable prior to estimation, so that the

expected parameter sign is positive (Hensher and Greene 2003).33 Table 8-2 presents model results.

Because the mixed logit model includes random coefficients, EPA estimated WTP using the welfare

simulation approach of Johnston and Duke (2007; 2009) following Hensher and Greene (2003). The

procedure begins with a parameter simulation following the parametric bootstrap of Krinsky and Robb

(1986), with R=1000 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 draws from a

bounded triangular distribution with m=s=0.05148015. Because the use of a triangular distribution on

program cost ameliorates the “long tails” problem of the lognormal distribution, and also due to

differences in the estimated functional form, these results provide lower WTP estimates, particularly for

relatively small increases in fish numbers. Welfare measures are calculated for each draw, resulting in a

combined empirical distribution of R×S observations from which summary statistics are derived. The

resulting empirical distributions accommodate both the sampling variance of parameter estimates and the

estimated distribution of random parameters. Here, we follow Hu et al. (2005) and simulate welfare

estimates as the mean over the parameter simulation of mean WTP calculated over the coefficient

simulation (i.e., mean of mean WTP).

33 Because the mixed logit model includes random coefficients, we estimate WTP using the welfare simulation approach of

Johnston and Duke (2007; 2009) following Hensher and Greene (2003). The resulting empirical distributions accommodate

both the sampling variance of parameter estimates and the estimated distribution of random parameters. We follow Hu et al.

(2005) and simulate welfare estimates as the mean over the parameter simulation of mean WTP calculated over the

coefficient simulation (i.e., mean of mean WTP).
March 28, 2011 8-11

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 8-2: Results of Mixed Logit Maximum Likelihood Estimation (Bounded Triangular

Cost)

Variable Coefficient Standard Error b/ St. Er. P[|Z|>z]

Random parameters in utility functions

NEITHER -5.412 1.489 -3.635 0.000

ACRES 0.047 0.013 3.637 0.000

MIGRANT 0.028 0.009 3.266 0.001

ACCESS 1.538 0.274 5.609 0.000

CATCH -0.004 0.008 -0.474 0.635

WILD 0.024 0.009 2.755 0.006

IBI 0.016 0.017 0.957 0.338

COST 0.051 0.009 5.998 0.000

Derived standard deviations of parameter distributions

NsNEITHER 5.424 1.140 4.760 0.000

NsACRES 0.076 0.028 2.686 0.007

NsMIGRANT 0.004 0.017 0.214 0.831

NsACCESS 1.950 0.372 5.239 0.000

NsCATCH 0.030 0.031 0.981 0.326

NsWILD 0.031 0.024 1.279 0.201

NsIBI 0.043 0.036 1.181 0.238

TsCOST 0.051 0.009 5.998 0.000

Parameter Descriptions:

neither – Alternative specific constant (ASC) associated with the status quo, or a choice of neither plan.

acres – The number of acres of river habitat accessible to migratory fish.

migrant - The percentage point increase in the number of migratory fish able to reach watershed habitat.

access – Indicates whether the restored area is accessible to the public for walking and fishing.

catch – The number of catchable-size fish in restored areas.

wild – 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.

cost – The household annual cost required to implement the restoration program.

Estimated benefit functions from the EPA/STAR choice experiment survey allow one to distinguish

benefits associated with resource uses from those associated primarily with nonuse motives. Within the

benefit transfer application, WTP is quantified for increases in non-harvested fish alone based on the

implicit price for migratory fish changes. This 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 forage fish with little or no direct human use—may

therefore be most accurately characterized as a nonuse benefit realized by households.

The above simulation provides a WTP estimate of $0.76 per percentage point increase in migratory fish,

where zero represents no fish and 100 percent represents the maximum possible number of fish that may

be supported by the ecosystem, following Johnston et al. (2009). Results for total household WTP for a

series of percentage improvements in fish numbers are shown below in Table 8-3.34 These percentage

improvements do not represent population increases; rather, they reflect new fish within a specific habitat

34 Within the Pawtuxet Watershed study area (the original study location), each percentage point increase in migratory fish is

equivalent to 12,250 individual fish.
March 28, 2011 8-12

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

area that may be counted. EPA transferred this estimate of $0.76 per percentage improvement to estimate

nonuse benefits of 316(b) regulatory options.

Table 8-3: WTP per Percentage Increase in the Number of Fish

Percentage Point Increase

in Number of Fish

WTP per % Increase in the

Number of Fish Total WTP per Household

1 $0.76 $0.76

12 $0.76 $9.13

20 $0.76 $15.21

33 $0.76 $25.10

100 $0.76 $76.05

8.3.2.2 Estimating Total WTP for Eliminating or Reducing I&E Mortality at CWISs

The BSPV study was developed as a case study is for a watershed-level policy in Rhode Island. While it

provides parameterized benefit functions that require the fewest assumptions to implement for benefit

extrapolation to the 316(b) case, estimates are likely to be representative of nonuse values held by

individuals residing in the Northeast U.S. 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

valuation studies conducted in other regions which 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 don’t 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 benefits transfer based on

these studies would result in greater uncertainties compared to application of the BSPV study. Therefore,

EPA restricted the benefits transfer to the North Atlantic and Mid-Atlantic EPA 316(b) study regions.

The structure of the BVSP choice experiment dictates that WTP estimates for each species are not

additive. Rather the overall WTP should be evaluated based on the single species that would experience

the greatest relative increase in abundance from restoration. To match the original valuation scenario to

the 316(b)policy scenario , EPA evaluated model results and available biological data to determine the

species for which relative abundance is most affected by I&E mortality. By comparing baseline age-1

equivalent losses to an estimate of total baseline fish abundance. EPA identified winter flounder as the

species suffering the greatest from baseline I&E mortality in the Northeast U.S. (i.e., North Atlantic and

Mid-Atlantic regions). EPA’s analysis was limited to species with readily available estimates of spawning

stock biomass for the Northeast U.S. from stock assessments conducted by the NOAA Northeast

Fisheries Science Center. This included a review of four species:winter flounder, striped bass, bluefish,

and Atlantic butterfish. (Table 8-4). All four species are harvested commercially, however fish of

commercial species may be forage during early life-stages and have nonuse values. The total baseline

I&E mortality in the North-Atlantic and Mid-Atlantic regions were evaluated together to represent the

Northeast U.S. for consistency with the available stock assessments, which include waters from Maine

south to North Carolina.
March 28, 2011 8-13

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 8-4: Baseline I&E Mortality Losses and Estimated Fish Numbers for the

Northeast U.S. (North Atlantic and Mid-Atlantic Regions)

Species Baseline I&E Losses

(millions of A1E)

Estimated Fish Numbers

(millions)a

Winter Flounder 6.502 21.1

Striped Bass 1.399 14.3

Bluefish 0.001 116.1

Atlantic Butterfish 0.008 28.9

a

Estimated population size was calculated by applying a conversion factor (lbs per fish) to an

esitmate of spawning stock biomass.

EPA expects that decreasing I&E mortality will lead to increased fish abundance in affected waterbodies.

EPA assumes that the total number of fish introduced to local habitats throughout the Northeast under

each regulatory option would be equivalent to the sum of age-1 equivalent reductions for the North

Atlantic and Mid-Atlantic regions. Application of the BSPV model results requires that the increases be

expressed as a percentage improvement from current conditions relative to a maximum number of fish

that could be supported by the ecosystem. EPA assumed a maximum of 99 million fish based on the

estimated biomass maximum sustainable yield from the Northeast Fisheries Science Center assessment of

the Southern New England stock (NOAA 2006) and a conversion factor of 1.2 lbs pounds per fish.

EPA’s calculation of nonuse values from eliminating or reducing I&E mortality losses for each regulatory

option involved the following steps:

1. Calculate the percent change increase in total winter flounder numbers in the Northeast U.S. (the

North Atlantic and Mid-Atlantic regions combined) by comparing age-1 equivalent reductions

under each regulatory option relative to a baseline of 99 million fish.

2. Multiply the percentage change in fish numbers by $0.76 (Table 8-3) to calculate the WTP per

household per year for the relative increase in winter flounder numbers resulting from the

regulatory option.

3. Calculate regional WTP for each regulatory option by multiplying WTP per household by the

total number of households within the North Atlantic and Mid-Atlantic regions, respectively.

The results from implementing these steps for each of the 316(b) regulatory options are described in

Section 8.4.

8.4 Estimates of Total WTP by Option and Region

Table 8-5 summarizes EPA’s estimates of WTP for increased fish numbers resulting from the 316(b)

regulatory options in the North Atlantic and Mid-Atlantic regions. EPA estimates that elimination of

baseline losses would increase the number of winter flounder in the Northeast U.S. by more than 6.5

million fish. This is equivalent to a 6.6 percent increase in winter flounder relative to a maximum of 99

million fish (i.e., 6.5 million divided by 99.0 million). Multiplying the 6.6 percent increase by a value of

$0.76 per percentage increase (as presented in Table 8-3) yields a household WTP of $4.99 per year.

Applying the household WTP values to the number of households in each region results in annualized

WTP values of $26.3 million and $102.3 million for the North Atlantic and Mid-Atlantic regions,

respectively, using a discount rate of 3 percent. Annualized WTP values are $26.8 million for the North

Atlantic and $104.0 million for the Mid-Atlantic using a discount rate of 7 percent.
March 28, 2011 8-14

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

EPA estimates that Option 1 would increase winter flounder numbers by less than 0.1 percent in the

North Atlantic and Mid-Atlantic waters. Applying per household WTP to this percent increase in the

number of winter flounder ($0.02) to the number of households in each region yields the total WTP for

improvements in winter flounder abundance. The estimated annualized WTP values are approximately

$0.1 million and $0.4 million for the North Atlantic and Mid-Atlantic regions, respectively, using both 3

percent and 7 percent discount rates (Table 8-5). Table 8-5 also presents household WTP and annualized

WTP for Option 2 and Option 3.

Table 8-5: Nonuse Value of Eliminating or Reducing Baseline I&E Mortality Losses by

Regulatory Option for All In-scope Facilities in the North Atlantic and Mid-Atlantic Regions

Baseline Option 1 Option 2 Option 3

Reduction in Northeast IM&EM (millions of age-1

equivalents) 6.50 0.03 5.32 5.57

Maximum Population (millions of fish) 99.0 99.0 99.0 99.0

Percentage Increase in Fish within Northeast

Waters 6.56% 0.03% 5.37% 5.63%

Household WTP per Percent Increase in Fish

Numbers (2009$) $0.76 $0.76 $0.76 $0.76

Annual WTP per Household (2009$) $4.99 $0.02 $4.08 $4.28

Number of Households (millions) 5.4 5.4 5.4 5.4

Annual WTP (millions of 2009$) $26.9 $0.1 $22.0 $23.1

Annualized WTP (3% discount rate; millions

of 2009$) $26.3 $0.1 $14.8 $15.5

Annualized WTP (7% discount rate; millions

of 2009$) $26.8 $0.1 $11.5 $12.0

Number of Households (millions) 21.0 21.0 21.0 21.0

Annual WTP (millions of 2009$) $104.6 $0.5 $85.6 $89.7

Annualized WTP (3% discount rate; millions

of 2009$) $102.3 $0.4 $57.3 $60.0

Annualized WTP (7% discount rate; millions

of 2009$) $104.0 $0.4 $44.5 $46.5

North Atlantic

Mid-Atlantic

Scenarios: Baseline = Elimination of Baseline I&E Mortality losses; Option 1 = I Everywhere; Option 2 = I

Everywhere and E for Facilities with > 125 MGD; Option 3 = I&E Mortality Everywhere

8.5 Limitations and Uncertainties

A number of issues are common to all benefit transfers. Benefit transfer involves adapting research

conducted for another purpose in the available literature to address the policy questions at hand. Because

benefits analysis of environmental regulations rarely affords enough time to develop original SP surveys

that are specific to the policy effects, benefit transfer is often the only option to inform a policy decision.

Some of the limitations and uncertainties associated with implementing a benefits transfer using Johnston

et al. (2009) are addressed below. Broader limitations and uncertainties associated with benefit transfer in

general are discussed by Johnston and Rosenberger (2010).
March 28, 2011 8-15

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

8.5.1 Scale of Fishery Improvements

Given the scale of the Johnston et al. (2009) survey upon which these results are based, the most reliable

results apply within the range of the choice experiment data (e.g., fish percentage point increases < 33

percent). Again, the maximum possible increase within the Pawtuxet policy context, 100 percent, is

defined as the maximum number of fish that can be supported by the Pawtuxet Watershed with fish

passage. Transfer to increases in fish below this magnitude may introduce uncertainty in the WTP

estimate per percentage increase in fish numbers.

8.5.2 Scale and Characteristics of the Affected Population

The results of Johnston et al. (2009) reflect WTP for improvements in nearby watersheds, and there may

be a decline in WTP as policy areas become more distant. The most reliable application of these results

would be to calculate WTP for I&E mortality reductions in a single local watershed. However, the 316(b)

regulation would reduce I&E mortality losses and would improve fish populations in multiple watersheds

within some states. As noted, it was assumed for these purposes that households have consistent values

for improvements in multiple watersheds within their state or region. Moreover, for transfers based on

absolute fish numbers, it is assumed that the per household WTP for changes in the numbers of fish for all

watersheds located within their 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, estimated per household

WTP is based on the average watershed improvement within the state—an approach to scale effects that

likely provides conservative welfare estimates.

The Johnston et al. (2009) study context was a single watershed in Rhode Island. Using the benefits

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 benefits transfer beyond the North Atlantic and MidAtlantic regions because of the potential for substantial differences in preferences, demographics, and

species characteristics in other regions compared to the original context of Johnston et al. (2009).

8.5.3 Fish Population Size, Type and Improvement from the Elimination of I&E Mortality

For the purposes of the benefit transfer it was assumed that the number of fish gained by eliminating I&E

mortality would be equal to baseline I&E mortality losses and reductions under each option. These

increases are not intended to represent changes in fish population.

There is some uncertainty regarding the geographic range of species included in the analysis. Based on

information from NOAA Northeast Fisheries Science Center, the range of species included here extends

south of the Mid-Atlantic region to North Carolina. The lack of adjustment based on the additional

geographic range factor leads to more-conservative estimates of benefits to the North Atlantic and MidAtlantic regions.

Finally, while both the study and policy contexts involve forage fish, the specific species compositions

involved differ between Johnston et al. (2009) and 316(b). For example, most of the fish affected within

Johnston et al. (2009) are migratory fish such as river herring, while such species may make up a smaller

proportion of those affected by CWISs. If WTP is sensitive to the specific type of forage fish involved,

this could be a potential source of generalization error.
March 28, 2011 9-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

9 Habitat Based Methodology for Estimating Nonuse Values of Fish

Production Lost to I&E Mortality

9.1 Introduction

The loss of commercially- or recreationally-important aquatic species due to impingement and

entrainment mortality (I&E mortality) at CWISs is typically valued as a direct use loss (e.g., commercial

and recreational harvest). However, aquatic species without any direct uses account for 97.3 percent of

I&E mortality at cooling water intake structures (CWIS) (Chapter 3). Therefore, estimating the total

(inclusive of nonuse) value of these losses is important when determining the benefits of reducing

impingement and entrainment (I&E) mortality.

One way to estimate the value of direct I&E mortality is to approximate the area of habitat required to

produce and support these organisms. Because fish habitat has been valued by many existing studies,

habitat provides an indirect basis for valuing the nonuse values of fish. These values may be transferred

because members of the general public are aware of the fish production services provided by eelgrass

(submerged aquatic vegetation, SAV) and wetlands; individuals express support for programs that include

increasing SAV and wetland areas with the expressed goal of restoring depleted fish and shellfish

populations (Mazzotta 1996; Opaluch et al. 1995; 1998).

Thus, the habitat-based method for estimating nonuse values of fish lost to I&E mortality is a two-step

process. First, the area of habitat required to replace fish and shellfish lost to I&E mortality is estimated.

The public’s WTP for this habitat is then assessed. When combined, these data yield an estimate of

household values for improvements in fish and shellfish habitat, which in turn provides an indirect

estimate of the benefits of reducing or eliminating I&E mortality.

This benefit transfer approach involves four general steps:

1. Estimate the area of habitat necessary to support the number of organisms lost to I&E mortality.

2. Develop WTP values for fish production services of habitat ecosystems.

3. Estimate the total value of baseline nonuse I&E mortality by multiplying WTP values for fish and

shellfish services by the area of habitat required to offset I&E mortality.

4. Estimate the direct nonuse benefits of proposed regulatory options, in terms of the value of

decreased I&E mortality, by multiplying WTP values for fish and shellfish services by the area of

habitat required to offset I&E mortality.

This methodology estimates only those nonuse values related to I&E mortality of organisms, and not any

indirect ecosystem effects of I&E mortality, or or chemical effects of CWISs (Chapter 2). EPA does not

include values generated using this habitat based approach within its estimates of total benefits for

eliminating or reducing I&E mortality under the 316(b) regulatory options. While they illustrate the

potential magnitude of nonuse values, EPA does not consider HEA appropriate for a primary analysis of

nonuse benefits. The remainder of this chapter describes the methodology and estimates of total WTP

values for lost aquatic organisms, using a habitat equivalency analysis in conjunction with a benefit

transfer of habitat values. It also includes a description of limitations and uncertainties of this approach.
March 28, 2011 9-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

9.2 Estimating the Amount of Habitat Needed to Offset I&E Mortality

The first step in the habitat-based method for valuing nonuse I&E mortality values is estimating the area

of habitat needed to offset I&E mortality. The process of quantitatively adjusting the size of the

restoration action such that the services that it provides equal those that were lost due to I&E mortality of

aquatic organisms is referred to as restoration scaling (NOAA 2006; Strange et al. 2002). A restoration

project is correctly “scaled” when it achieves ecological equivalence. Ecological equivalence is met when

the magnitude of a restoration reproduces the ecological services provided by a resource prior to injury.

Restoration scaling approaches are based on the principles of Habitat Equivalency Analysis (HEA). HEA

was developed by the National Oceanic and Atmospheric Administration (NOAA) to determine public

compensation for natural resource losses following natural resource damage assessments (NRDAs) that

occur under the auspices of the Oil Pollution Act (OPA). HEA is a service-to-service scaling approach: it

does not assume a one-to-one trade-off in resources, but instead in the natural resource services that these

resources provide (NOAA 2006). In order to fully compensate for natural resource damages, restoration

action must provide services of the same type and quality as those lost. Discounting is used to account for

time lags between the loss of services and their restoration.35

To estimate the impact of I&E mortality and the benefits of regulation using a habitat-based methodology,

EPA selected a trophic transfer approach to scale restoration. The trophic transfer approach is based on

food-web connectivity that occurs between primary producers and the production of resident and transient

fish (French McCay and Rowe 2003; Kneib 2003). Using this approach, the area of habitat necessary to

provide fish and shellfish lost due to I&E mortality is calculated through food-web interactions to

estimate the area of habitat necessary to compensate for these losses. Such an approach has been used to

scale restoration to compensate for injuries to aquatic resources under various NRDAs as well as for

estimating restoration necessary to compensate for I&E mortality under the National Pollutant Discharge

Elimination System (NPDES) permitting process (Balletto et al. 2005; French McCay et al. 2002; NOAA

2009; Penn and Tomasi 2002; PSEG 2006; Teal and Weinstein 2002). The trophic transfer approach

requires four basic steps to estimate the area of habitat restoration necessary to compensate for I&E

mortality (Figure 9-1).

EPA estimated values in each region using a single habitat characteristic of the region. Although the

Agency recognizes that many species lost to I&E mortality rely upon more than one habitat during their

life history, a single habitat was chosen as most representative for each region to ensure data availability,

ensure calculation simplicity, and provide a representative habitat required by many species in the region.

9.2.1 Quantify the Mass of Production Lost to I&E Mortality

The first step in application of the trophic transfer is estimating the mass of production lost to I&E

mortality. This calculation requires estimating the number of organisms lost to I&E mortality on an

annual basis (Chapter 3) as well as determining the annual reduction of productivity as a consequence of

these losses. Additionally, this step requires estimating the benefits projected to accrue as a result of

regulation.

35 “The discount rate incorporates the standard economic assumptions that people place a greater value on having resources

available in the present than on having their availability delayed until the future” (p.7) (NOAA 2006). For the methods

discussed, the standard discount rate is 3%.
March 28, 2011 9-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Within the trophic transfer framework, losses are calculated as the annual biomass production associated

with organisms lost to I&E mortality. The vast majority of organisms lost to I&E mortality are less than 1

year of age at the time of loss (numerically, the greatest losses occur for eggs and larvae, as discussed in

Chapter 3). For this reason and to simplify computation, EPA converted all I&E mortality to age-1

equivalents. These losses were then multiplied by the mass of age-1 equivalents and the ratio of dry to

wet mass to estimate the dry mass of lost productivity on an annual basis (Appendix Equation J-1).

Quantify regional I&E Mortality as

a measure of lost productivity

Select a restoration habitat

for all benefits regions

Quantify expected

productivity increases

from habitat restoration

Scale habitat restoration

to offset I&E Mortality and estimate

benefits under regulatory options

Step 1:

Step 2:

Step 3:

Step 4:

Figure 9-1: Implementation of the Trophic Transfer Approach

9.2.2 Production per Unit of Habitat

The second step for implementation of the trophic transfer is the calculation of production per unit of

habitat. Each acre of restored habitat generates some quantity of primary productivity per year, measured

here as the annual accumulation rate of dry biomass (i.e., kg dry mass per acre per year). Some proportion

of this productivity is exported from the ecosystem due to factors such as water movement; this

productivity is not available to the ecosystem. Remaining primary productivity is then converted to

secondary productivity using trophic conversion based on a highly simplified four-level food chain

(Figure 9-2). Trophic conversion efficiencies (or trophic transfers) refer to the inefficiency of energy

exchange between trophic levels. They can be thought of as the production rate of biomass of predatory

organisms per unit biomass of food (Penn and Tomasi 2002; Strange 2008). EPA assumed that all

consumers in the simplified food chain model are food-limited, and that the production of consumers is

proportional to gains in prey abundance based on trophic conversion efficiencies (French McCay and

Rowe 2003).

EPA specified all I&E mortality species as secondary consumers when scaling restoration.36 Thus, to

compare fish production lost to I&E mortality to production gained through habitat restoration, primary

productivity from habitat must to be converted to an equivalent amount of production of secondary

36 EPA’s assumption that I&E mortality species are secondary consumers is consistent with PSEG’s assumptions when scaling

restoration for the Salem facility (e.g., Balletto et al. 2005; PSEG 2006) and assumptions in multiple NRDAs when scaling

restoration to compensate for fish losses due to oil spills (e.g., French McCay et al. 2002; Penn and Tomasi 2002).
March 28, 2011 9-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

consumer. This calculation requires estimated values for primary production, carbon export, and

conversion efficiencies from primary production to detritus, detritus to primary consumers, and primary

consumers to secondary consumers (Appendix Equation J-2). The remainder of this section describes

these parameters in detail, and how EPA obtained estimates of these values.

Primary Productivity

Accumulation of energy

and nutrients by autotrophs

Detritus

Freshly dead or partially

decomposed organic matter

Primary Consumers

Organisms that consume detritus

and/or primary production. Includes

macroinvertebrates and plankton.

Secondary Consumers

Consumers of primary consumers,

including young-of-year fish

Carbon Export

Loss of productivity by

water movement

Trophic Conversion

Loss of energy due

to metabolic processes

Trophic Conversion

Trophic Conversion

Figure 9-2: Trophic Levels and Processes Calculated with the Simplified,

Four Level Trophic Transfer Model

9.2.2.1 Primary Production per Acre

EPA identified five habitat types for scaling regional I&E mortality losses based on (1) importance as

foundation species (i.e., species involved in habitat formation) with trophic linkages to secondary

production, (2) regional geographic distribution, and (3) the availability of published values of primary

productivity (Section 9.2.3). These habitats include: eelgrass (Zostera marina) meadows in the North

Atlantic; saltmarsh dominated by smooth cordgrass (Spartina alterniflora) in the Mid-Atlantic, South

Atlantic and Gulf of Mexico; giant kelp (Macrocystis pyrifera) forests in California; and wetlands

dominated by broadleaf cattail (Typha latifolia) in the Inland and Great Lakes regions.

Although estimates of primary productivity (PP) are best generated through site-specific study, it is

common for analysts to use estimates from the literature when scaling restoration (e.g., French McCay et

al. 2002; Penn and Tomasi 2002). EPA identified peer-reviewed sources for each habitat type used to

scale I&E mortality. For each of the seven 316(b) regions, EPA compiled net primary productivity (NPP)

values from the primary scientific literature as well as reviews or past compilations of primary

productivity values. EPA standardized these values to the metric of kg dry mass per acre per year. In

cases when multiple sites were measured within an investigation, EPA used the average value.

Primary production depends on several factors, including but not limited to the conditions and

characteristics of the study site and study methodology. Due to geographic variations in growing season

and climate, primary productivity of species may differ substantially both within and among regions

(Appendix Table J-1). For example, regional productivity estimates used in past salt marsh scaling
March 28, 2011 9-5

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

applications include 2,204 kg dry mass acre-1 in Rhode Island (French McCay and Rowe 2003), 6,636 kg

dry mass acre-1 yr-1 in New Jersey, (PSEG 2006; Strange 2008), and 11,716 kg dry mass acre-1 in

Louisiana (Penn and Tomasi 2002) (Appendix Table J-1).37 To obtain regionally-applicable values for

primary productivity, EPA used an average of habitat-specific productivity values from a minimum of

four published values in all calculations (Appendix Table J-1).

The NPP fraction most easily converted to detritus (freshly dead or partially decomposed organic matter

(Ricklefs 2001)), and therefore available for secondary production, is above-substrate primary production.

Consequently, EPA included above-substrate primary production in its calculations. This includes all

emergent stems and leaf tissue in cordgrass and cattail, and leaf tissue for eelgrass and turtle grass. For

giant kelp, which uses a benthic holdfast, all biomass production in the water column was included in

estimates of NPP.38 Estimates of NPP also include primary production of epiphytic periphyton or

macroalgae (e.g., attached to root stalks in wetland and saltmarsh, or to submerged leaves of eelgrass or

kelp). Additionally, EPA included algal productivity in NPP estimates. In the North and Mid-Atlantic

regions, NPP estimates include 533 kg dry mass acre-1 yr-1 of algal productivity [based on scaling

assessments conducted in Rhode Island, New Jersey and Delaware salt marshes (French McCay and

Rowe 2003; PSEG 2006; Strange 2008)]. This is equivalent to 16 percent of average mean aboveground

macrophyte productivity within the North Atlantic and Mid-Atlantic regions (Appendix Table J-1).39

For all other habitats, the contribution of epiphytes and algae was set to 10 percent of annual aboveground

NPP of the foundation species.

9.2.2.2 Trophic Conversion Efficiencies

Trophic conversion efficiencies (or trophic transfer) account for the relative inefficiency of energy

transfer between trophic levels (Penn and Tomasi 2002; Strange 2008). Trophic conversion efficiency is

normally described as the production of predator per unit of prey or food item. Using a highly simplified

trophic structure, trophic conversion efficiencies were applied to three trophic steps:

 Primary productivity to detritus

 Detritus to primary consumers

 Primary consumers to secondary consumers

There is evidence that algae and vascular plant detritus40 is important for production at higher trophic

levels (Kneib 2003). However, there is substantial uncertainty regarding the most appropriate

specification of the trophic conversion efficiency from primary productivity to detritus. For example, the

trophic conversion efficiency of smooth cordgrass (S. alterniflora) biomass to detrital material has been

estimated to be between 0.50 and 0.60. EPA conservatively assigned a transfer efficiency of 0.40 from

37 Estimates of NPP were converted to kg dry mass/acre/year. Measurements reported as g carbon (C)/area/time were converted

using a species-specific organic carbon content and appropriate adjustment for areal and time increments. Although EPA

recognizes that the proportion of organic carbon in vascular plants is seasonally dynamic, this variability was not considered

critical for estimation.

38 This assumption is likely to underestimate NPP for some species, since it does not consider conversion of roots and rhizomes

to the organic detritus pool that may be used by the secondary consumers.

39 French McCay and Rowe (2003) assumed 429 kg dry mass acre-1 yr-1 when scaling salt marsh in Rhode Island, while PSEG

assumed 636 kg dry mass acre-1 yr-1 while scaling salt marsh in New Jersey and Delaware (PSEG 2006; Strange 2008).

40 Vascular plant detritus includes dead organic material from plants having a vascular system of xylem and phloem (Walker

1995) such as S. alterniflora.
March 28, 2011 9-6

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

primary productivity to detritus to account for uncertainty regarding the importance of detritus for nekton

production.41 Some past NRDAs have not explicitly included this trophic step (e.g., French McCay et al.

2002; Penn and Tomasi 2002), but have included a low efficiency from primary productivity to primary

consumers, reflecting the fact that a high percentage of primary productivity is broken down by

decomposers such as bacteria, molds and fungi (French McCay and Rowe 2003).

In its simplified trophic model, EPA assumed that primary consumers subsist off the detrital complex,

which includes macroinvertebrates and zooplankton. A trophic conversion efficiency of 0.2 is assumed in

the transfer of detritus material to primary consumers. Conversion efficiencies for fish and invertebrate

consumers in freshwater and marine environments range from 0.1 to 0.3 (French et al. 1996). EPA used a

value of 0.2, the mid-point of the range commonly used for scaling injuries (e.g., Balletto et al. 2005;

French McCay et al. 2002; Penn and Tomasi 2002).

Secondary consumers are assumed to include fish in their first year (i.e., young-of-year; defined as age-0

fish). EPA assumed a trophic conversion efficiency of 0.2 from primary to secondary consumers,

consistent with past scaling assessments (e.g., Balletto et al. 2005; French McCay et al. 2002; Penn and

Tomasi 2002).42

9.2.2.3 Carbon Export

Although quantifying local production is necessary to develop estimates of restoration area, it is not

realistic to assume that all NPP remains within the local ecosystem. Export from aquatic ecosystems may

be substantial, particularly in open or semi-enclosed ecosystems with substantial riverine or tidal flux. In

these systems, tidal exchange and flushing may remove a large proportion of the local productivity before

it is consumed and assimilated by local consumers (e.g., Cebrian 2002; Teal 1962). Consequently, if NPP

export is not considered in trophic transfer models, the amount of habitat restoration required to

compensate for lost ecosystem goods and services is likely to be underestimated. Although some scaling

calculations conducted as part of NRDAs do not explicitly include an export adjustment (e.g., French

McCay et al. 2002; Penn and Tomasi 2002), others acknowledge that productivity many be transported

out of the area (French McCay and Rowe 2003).43

The rate at which net primary productivity is exported (E) depends on site-specific characteristics

including marsh height, tidal flushing dynamics, and species mix. An examination of annual NPP from a

variety of U.S. and international studies in wetlands had a median value of 22 percent NPP export

(Appendix Table J-2). The uncertainty inherent in estimating carbon flux from ecosystems is large

(Cebrian 2002) and variability in carbon export high. Accordingly, estimating trophic transfer values for

habitats with unknown nutrient dynamics is fraught with uncertainty. EPA recognizes that the amount of

NPP exported from the habitats (1) is not available locally to sponsor trophic transfer and secondary

production, and (2) will be highly variable from site to site, depending on several factors including tidal

or riverine flushing, droughts, storm events, and year-to-year variability in plant production. Recognizing

41 The assumed value of 0.40 is consistent with the trophic transfer model that PSEG used to scale habitat restoration for the

Salem facility. PSEG refers to its trophic model as the “Aggregate Food Chain Model” (PSEG 2006; Strange 2008).

42 The trophic steps outlined match those used by PSEG for the Aggregate Food Chain Model (Balletto et al. 2005; PSEG 2006),

and are generally consistent with those used in miscellaneous NRDAs (e.g., French McCay et al. 2002; Penn and Tomasi

2002).

43 The PSEG AFCM assumed that 45% of primary productivity is lost to the ocean and was not converted to fish and invertebrate

secondary productivity (PSEG 2006; Strange 2008), based on values from a Georgia salt marsh (Teal 1962).
March 28, 2011 9-7

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

these limitations, EPA assumed, in all habitats, that 25 percent of net primary production is exported from

the system and is not transferred to higher trophic levels.

9.2.3 Select Preferred Restoration Habitat

To best compensate for I&E mortality, restored habitats should produce the full complement of impacted

species in each region. However, uncertainties regarding the species-specific benefits of restoration

actions make scaling habitat loss on a per-species basis impractical. EPA’s application of the trophic

transfer approach treats the production of secondary consumers as a proxy for the provision of food and

nutrient cycling considered to be important ecological services (French McCay and Rowe 2003). Under

this assumption, services are considered to be restored when production of secondary consumers due to

restoration is equivalent to that lost annually due to I&E mortality. It is unnecessary for restored habitats

to compensate for losses on a species-by-species basis.44 This approach underestimates restoration to the

extent that the public has higher total nonuse values for individual species that may have commercial,

recreational or nonuse values.

To simplify analysis, one habitat type was chosen in each region as the basis for scaling I&E mortality.

To select the most appropriate habitat type within each region, a subset of species, broader taxonomic, or

functional groupings that accounted for 50-90 percent of the biomass lost to I&E mortality (typically, the

top 5-6 species/groupings) for each 316(b) region were identified. Nursery habitat and life history traits

for young-of-year fish were obtained (Fishbase 2009), and a habitat type that benefitted the greatest

percentage of A1E losses was selected in each region (Appendix Section J.3). Because many aquatic

organisms experience I&E mortality early in their life history (e.g., eggs, larvae, and juveniles), this step

directly addresses the life stages most at risk of I&E mortality. Where available information for ecological

habitat and nursery characteristics did not indicate a preferred habitat, ecosystems characterized with

higher primary productivity per acre were favored.

Table 9-1: Summary of Productivity Values of Preferred Scaling Habitats by Region (kg

dry mass acre-1 yr-1)

Region Species Sample Size

Macrophyte

NPP Algal NPP Total NPP

California Giant kelp

Macrocystis pyrifera

4 7,300 730 8,030

North Atlantic Eelgrass

Zostera marina

6 3,750 375 4,125

Mid-Atlantic Smooth cordgrass Spartina

alterniflora

10 3,350 533 3,880

South Atlantic Smooth cordgrass Spartina

alterniflora

13 6,350 533 6,883

Gulf of Mexico Smooth cordgrass Spartina

alterniflora

13 6,350 533 6,883

Great Lakes Broadleaf cattail

Typha latifolia

14 6,200 620 6,820

Inland Broadleaf cattail

Typha latifolia

14 6,200 620 6,820

For ease of calculation, the mean values were rounded to the nearest 50 kg dry mass per acre-1 yr-1.

44 EPA’s treatment of productivity as a proxy for important ecosystem services is consistent with the implicit assumptions of

various past scaling assessments conducted as part of NRDAs (e.g., French McCay et al. 2002; French McCay and Rowe

2003; Penn and Tomasi 2002).
March 28, 2011 9-8

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

9.2.4 Scaling Habitat Restoration Alternatives to Offset I&E Mortality

Calculating the area required to compensate for annual I&E mortality combines estimates in increased

biomass production of secondary consumers (Section 9.2.2) from preferred restoration habitats (Section

9.2.3) with quantified I&E mortality (Chapter 3; Section 3.3 ).

The scale of restoration required to compensate for I&E mortality is the quotient of annual I&E mortality

divided by the expected increase in secondary production associated with a unit area of habitat (Appendix

Equation J-3). Thus, a CWIS causing I&E mortality of 20,000 kg dry mass per year (across all species)

would have to restore 200 acres of habitat that produced 100 kg dry mass of secondary production per

acre per year. Conversely, if a regulatory option reduces I&E mortality by 5,000 kg dry mass per year,

then its annual benefit is equivalent to 50 acres of similarly-productive habitat.

Table 9-2 presents the I&E mortality reductions and equivalent habitat restoration area for each region

under the proposed regulatory options. Among regions, habitat restoration area equivalent to baseline I&E

mortality ranged from 410 acres in the South Atlantic region, to 76,432 acres in the Inland region. The

total habitat area equivalent to I&E mortality reductions for all regions is approximately 54,000 acres

under Option 1, 127,000 acres under Option 2, and 129,000 acres under Option 3. The rank order of

regions by area of habitat equivalent to estimated I&E mortality reductions due to policy options differed

among options, due to differences in the effectiveness of 316(b) regulatory options. Notably, however, the

equivalent habitat restoration area was always greatest in the Inland region (Table 9-2).
March 28, 2011 9-9

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 9-2: Baseline I&E Mortality (metric tons A1E year-1) and Habitat Restoration Area (acres) Equivalent to Baseline I&E Mortality, and I&E

Mortality Reductions (metric tons A1E year-1) and Habitat Restoration Area (acres) Equivalent to These Reductions, by Region and

Regulatory Option

I&E

Losses

(metric

tons A1E,

dry

weight)

Equivalent

Restoration

Area (acres)

I&E

Losses

(metric

tons A1E,

dry

weight)

Equivalent

Restoration

Area (acres)

I&E

Losses

(metric

tons A1E,

dry

weight)

Equivalent

Restoration

Area (acres)

I&E

Losses

(metric

tons A1E,

dry

weight)

Equivalent

Restoration

Area (acres)

California Giant kelp

Macrocystis

pyrifera

96 282 2,930 3 36 241 2,503 252 2,617

North Atlantic Eelgrass

Zostera marina

50 158 3,183 1 23 129 2,601 135 2,727

Mid-Atlantic Smooth cordgrass

Spartina

alterniflora

47 1,735 37,242 240 5,150 1,608 34,511 1,626 34,890

South Atlantic Smooth cordgrass

Spartina

alterniflora

83 34 410 13 159 29 346 29 347

Gulf of Mexico Smooth cordgrass

Spartina

alterniflora

83 1,252 15,158 340 4,122 988 11,958 989 11,978

Great Lakes Broadleaf cattail

Typha latifolia

82 463 5,654 253 3,091 425 5,195 428 5,229

Inland Broadleaf cattail

Typha latifolia

82 6,255 76,432 3,424 41,834 5,723 69,927 5,843 71,390

Total

(All Regions)

- - 10,179 141,009 4,275 54,415 9,142 127,041 9,301 129,178

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 DIF MGD; Option 3 = I&E

Mortality Everywhere

Secondary

Productivity

(kg acre-1

year-1)

Option 2 Option 3

Region Habitat

Baseline Option 1
March 28, 2011 9-10

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

9.3 Development of WTP Values for Fish Production Services of Habitat

The approach EPA used to develop WTP values for fish production services is to 1) estimate the number

of acres of habitat required to produce fish equivalent to those lost due to I&E mortality; and 2) evaluate

citizens’ WTP for this habitat—not for the fish produced by the habitat. This method is consistent with

NOAA’s preferred methods for NRDA under the Oil Pollution Act (OPA), since NOAA’s NRDA

regulations focus on restoration of injured resources, rather than monetary compensation for damages. For

lost interim values pending restoration, additional habitat may be restored in lieu of monetary

compensation. NOAA refers to this as “compensatory restoration” (NOAA 1997). EPA calculated the

amount of “service-to-service” compensatory restoration—in the form of restored habitat—required to

offset losses, and then evaluated WTP for restoring this area of habitat. Whereas NOAA recommends

restoring such acreage to compensate for I&E mortality, EPA does not suggest that the restoration be

carried out. Instead, EPA quantifies the benefits, in the form of fish production, that the restored habitat

would provide. This value provides a proxy for the nonuse values not otherwise estimated in this

document.

EPA performed an in-depth search of the economic literature to identify valuation studies that estimate

WTP for aquatic habitat services. From this review, EPA identified seven studies relevant for its analysis

(Appendix Section J.4). For inclusion in this list, studies were required to meet the following criteria:

 Specific Amenity Valued: Environmental quality change being valued affects habitat similar to

those habitat types included in the trophic transfer model.45

 U.S. Studies: Studies surveyed U.S. populations to value domestic resources.

 Research Methods: Valuation methods were supported by journal literature and inclusive of

nonuse values (e.g., contingent valuation, conjoint analysis).

EPA applied values from seven studies for all 316(b) regions, based on consideration of the study

location, habitat type, and services provided relative to biological scaling assumptions (i.e., Section 9.2).

If a study was not applicable in a region, EPA transferred values from studies conducted in other 316(b)

regions for the same habitat type. Reported WTP values per acre of habitat restored represent the average

of mean values from individual valuation studies (Table 9-3).

Eelgrass habitat was selected for restoration scaling in the North Atlantic region. The Peconic Estuary

study (Johnston et al. 2002a; Johnston et al. 2001; Mazzotta 1996; Opaluch et al. 1995; Opaluch et al.

1998), conducted on the East End of Long Island, NY within the Mid-Atlantic region, was the only study

identified by EPA that estimates WTP per acre of eelgrass habitat. Although EPA recognizes that there is

uncertainty when applying WTP values to external 316(b) regions, substantial differences in values are

unlikely in this case due to the close proximity of the study area to the North Atlantic region and

similarity in resource characteristics including assemblage of species supported by eelgrass habitat.

45 Valuation studies were excluded from consideration if the habitat services provided by the study habitat were substantially

different, or provided in drastically different ratios, than the restoration habitat used for scaling (e.g., Dillman et al. 1993;

Roberts and Leitch 1997).
March 28, 2011 9-11

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

EPA was unable to identify studies estimating the value of saltmarsh habitat in the South Atlantic and

Gulf of Mexico regions. Therefore, it was necessary to apply wetland values from valuation studies

conducted in other 316(b) regions: EPA identified two applicable saltmarsh habitat values, from Rhode

Island (Bauer et al. 2004) and New York (Johnston et al. 2002a; Johnston et al. 2001; Mazzotta 1996;

Opaluch et al. 1995; Opaluch et al. 1998). EPA recognizes that substantial uncertainty may occur when

applying wetland values outside the region from which they were obtained, due to variation in habitat

condition and resident preferences. However, it is not clear that application of these results will

overestimate or underestimate WTP for wetland habitats.

Only one study was identified that estimated WTP for wetland restoration in the Great Lakes region

(Bishop et al. 2000). However, riverine wetlands inland of the Great Lakes provide fish production, which

contributes to fish populations in the Great Lakes. Consequently, EPA also applied studies that estimated

WTP for riverine wetland habitat in states adjacent to the Great Lakes (de Zyosa 1995; Mullarkey 1997;

Mullarkey 1999). These studies were also applied to the Inland 316(b) region.

9.3.1 Estimating the Importance of Fish Habitat as a Proportion of Habitat WTP Values:

Salt Marshes

To estimate the proportion of value associated with fish habitat, EPA used data from the 2001 Survey of

Rhode Island Residents. The survey instrument, Rhode Island Salt Marsh Restoration: 2001 Survey of

Rhode Island Residents, was designed to assess tradeoffs among attributes of salt marsh restoration plans

in Narragansett Bay, Rhode Island (Johnston et al. 2002b). Development involved extensive background

research, interviews with experts in salt marsh ecology and restoration, and 16 focus groups with more

than 100 residents (details on survey development are in Appendix Section J.5.1).

Survey data indicate that respondents favored plans that restored larger areas of salt marsh. Comparisons

among specific improvements to habitat and mosquito control revealed that respondents placed the

greatest weight on mosquito control, followed by habitat improvements for shellfish, fish, and birds,

respectively (Johnston et al. 2002b).

From the survey data, EPA calculated the proportion of wetland restoration value associated with

different wetland services. Across all scenarios presented in the survey, the proportion of WTP values

Table 9-3: Total Annual Household WTP Per Acre of Aquatic Habitat

316(b) Region WTP acre-1 yr-1 (2009$) Valuation Studies Applied

California - -

North Atlantic 0.0761 Peconic Estuary Study (Johnston et al. 2002a; Johnston et al.

2001; Mazzotta 1996; Opaluch et al. 1995; Opaluch et al. 1998)

Mid-Atlantic 0.0672 Peconic Estuary Study (Johnston et al. 2002a; Johnston et al.

2001; Mazzotta 1996; Opaluch et al. 1995; Opaluch et al. 1998)

South Atlantic 0.0431 Bauer, Cyr, and Swallow (2004), Peconic Estuary Study

(Johnston et al. 2002a; Johnston et al. 2001; Mazzotta 1996;

Opaluch et al. 1995; Opaluch et al. 1998)

Gulf of Mexico 0.0431 Bauer, Cyr, and Swallow (2004), Peconic Estuary Study

(Johnston et al. 2002a; Johnston et al. 2001; Mazzotta 1996;

Opaluch et al. 1995; Opaluch et al. 1998)

Great Lakes 0.0131 de Zoysa (1995), Mullarky (1997), Mullarky (1999), Bishop et

al. (2000)

Inland 0.0118 de Zoysa (1995), Mullarky (1997), Mullarky (1999), Blomquist

and Whitehead (1998), Whitehead and Blomquist (1991)

EPA was unable to identify an applicable valuation study for kelp habitat, the preferred scaling habitat for the California region.
March 28, 2011 9-12

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

associated with fish habitat, bird habitat, shellfish habitat, mosquito control, and other services were

0.256, 0.198, 0.278, 0.121, and 0.147, respectively. (Additional results and discussion are in Appendix

Section J.5.2.)

EPA assumed that 25.6 percent of WTP per acre of salt marsh is associated with fish production services

for all regions based on these data. EPA recognizes that the findings of the Johnston et al. (2002b) study

are best applied to areas within or near the North Atlantic region for which coastal populations (i.e.,

preferences) are similar and salt marsh services are most similar. However, EPA was unable to identify

comparable stated preference studies conducted within the Mid-Atlantic, South Atlantic, and Gulf of

Mexico regions.

There is general consensus that marine tidal wetlands and seagrasses provide good to excellent fish

production function for many important commercial, recreational and forage species (Graff and

Middleton 2003; Street et al. 2005), by providing favorable conditions for the growth and survival of

juveniles and young-of-year (Deegan et al. 2000). It is true that the precise role of such habitats as

nurseries for juvenile fish has recently been critically re-examined, suggesting the need for better

quantification of the precise role of nearshore ecosystems in producing more adult fish (Beck et al. 2003).

However, the fish production function of tidal wetlands would be considered high. By applying survey

findings from Rhode Island across these regions, EPA assumes that preferences for salt marsh restoration

and salt marsh services are not substantially different among regions. However, true regional WTP values

may be higher or lower than those estimated within Narragansett Bay.

9.3.2 Estimating the Importance of Fish Habitat as a Proportion of Habitat WTP Values:

Freshwater Wetlands

EPA was unable to identify any studies that permitted the apportionment of WTP for freshwater wetlands

among habitat services. However, EPA reviewed the published literature to identify and estimate the

proportion of WTP value that is associated with fish production.

Tidal freshwater wetlands are located inland of estuaries. They experience tidal fluctuations, but are not

regularly exposed to water with substantial salinity. As such, these communities are dominated by

freshwater plants (e.g., cattails, bulrushes, etc). These wetlands are commonly used by freshwater,

estuarine, marine and migratory fish: their dense vegetation provides refuges for juveniles, and protected

spawning areas. Additionally, because nutrient cycling in these marshes is rapid, food is readily available

(Graff and Middleton 2003). As described by Mitchell et al. (2009b) and consistent with the findings of

Johnston et al. (2002b), EPA assumed that 25 percent of WTP per tidal marsh acre is associated with fish

production services.

Non-tidal freshwater wetlands connected to large bodies of water (including the Great Lakes) may also

have enhanced fish production function. For example, it has been estimated that 75 percent of fish species

in the Great Lakes use coastal marshes during some part of their life cycle (Jude and Pappas 1992;

Meixler et al. 2005; Stephenson 1990). Moreover, Lake Erie is reported to support the best fishery of the

Great Lakes, in terms of diversity and number, partly because of its extensive system of adjoining coastal

marshes (Graff and Middleton 2003). Consequently, EPA assumed that 20 percent of WTP per acre for

freshwater marshes in the Great Lakes is associated with fish production services based on the generallyrecognized importance of this habitat to fisheries. EPA used a value lower than recognized for marine

marshes to reflect the absence of a regular tidal cycle that can provide habitat diversity within the

ecosystem.
March 28, 2011 9-13

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

The importance of fish production in isolated non-tidal freshwater wetlands, forested wetlands (i.e.,

seasonally flooded areas), swamps, bogs, etc., has not been well-quantified. Although wetlands attached

to lakes or fringing marshes on rivers may be locally productive, isolated shallow depressions, headwater

swamps, or seepage-derived wetlands may have poor or non-existent fish production (Graff and

Middleton 2003). Consequently, EPA believes the average importance of isolated non-tidal freshwater

marshes is far lower than similarly-sized marshes in marine systems or freshwater marshes connected to

significant water bodies. Thus, EPA conservatively assumed that 10 percent of the WTP per acre is

associated with fish production services.

9.3.3 Estimated Proportion of Household WTP Estimates Attributed to Fish Production

Services

EPA assumed that 25.6 percent of household WTP values for salt marsh restoration are attributable to fish

production services (Section 9.3.1). Similarly, EPA assumed values of 20 percent for freshwater marshes

in the Great Lakes Region, and 10 percent for wetlands in the Inland region (Section 9.3.2). Finally,

because the Peconic surveys used to estimate WTP for eelgrass habitat were described specifically as fish

and shellfish habitat, EPA assigned 100 percent of the estimated WTP for eelgrass restoration to fish

production services. Consequently, by multiplying total WTP per acre restored habitat per year (Table

9-3) by estimates of the proportional contribution of fish production services, EPA obtained WTP per acre

per year for fish production services in preferred habitats for all 316(b) regions with the exception of

California (Table 9-4).

Table 9-4: Household WTP per Acre per Year for Fish Production Services

316(b) Region

Total WTP acre-1 yr-1

(2009$)

% Attributed to Fish

Production Services

WTP acre-1 yr-1 for Fish

Production Services (2009$)

California - - -

North Atlantic10.0761 100.0% 0.0761

Mid-Atlantic 0.0672 25.6% 0.0172

South Atlantic 0.0431 25.6% 0.0110

Gulf of Mexico 0.0431 25.6% 0.0110

Great Lakes 0.0131 20.0% 0.0026

Inland 0.0118 10.0% 0.0012

Note: EPA was unable to identify an applicable valuation study for kelp habitat, the preferred scaling habitat for the California

region.

9.4 Estimating the Value of Habitat Needed to Offset I&E Mortality

9.4.1 Determining the Extent of Nonuse Values

Evaluating the total regional WTP value per acre of wetlands or eelgrass requires estimating the extent of

the population holding nonuse values for these resources. EPA defined the population as the total number

of households in the state following the methods used by several published studies (e.g., Bauer et al.

2004; Blomquist and Whitehead 1998; Mullarkey 1997; Whitehead and Blomquist 1991).

Households in close proximity are likely to value gains of fish in affected waterbodies, as will households

in counties that do not directly abut affected water bodies. Evidence from Johnston et al. (2002b)

indicates that this value can extend to the statewide level. Analysis of data from the Rhode Island Salt
March 28, 2011 9-14

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Marsh Restoration Survey (Johnston et al. 2002b) reveals that values ascribed to even relatively smallscale salt marsh restoration actions (i.e., 3-12 acres) were stated by respondents from various parts of the

state. A study by Pate and Loomis (1997) found that respondents outside the state in which a study site is

located were also willing to ascribe stated preference values to the amenity being studied. It compared

WTP values for environmental programs designed to improve wetland habitat in the San Joaquin Valley,

CA across households in the Valley, California households outside the Valley, and households in

Washington State, Oregon, and Nevada. They found that CA households outside the San Joaquin Valley

expressed similar WTP compared to residents of the Valley, with households outside the state even

holding positive WTP for the environmental programs. Thus, it is reasonable to assume in the context of

316(b) analysis that residents within an affected state would have positive values for fish habitat

improvements within state waters.

The magnitude of habitat restoration efforts sufficient to compensate for I&E mortality would require a

large geographical footprint. EPA recognized that, if implemented, this footprint would be divided into

many sites dispersed throughout each region. To estimate WTP for fish production services that best

reflect compensation for I&E mortality, EPA assigned habitat restoration based on the estimated

distribution of I&E mortality throughout each 316(b) region based on the proportion of total AIF of instate facilities relative to total regional AIF. The proportional breakdown of restoration area by state and

region is presented in Appendix Table J-7.

9.4.2 Estimating Aggregate Values

EPA calculated aggregate WTP for each 316(b) region as follows based on the area of habitat required to

compensate for I&E mortality (Table 9-2), estimates of household WTP per acre per year for fish

production services (Table 9-4), and the size of the affected population (Appendix Table J-7).

1. Multiply the number of regional habitat acres needed to offset I&E mortality under the baseline

condition or equivalent to I&E mortality reduction effect on fish production under the proposed

316(b) regulation (Table 9-2) by the percentage of area attributed to each state within the 316(b)

region (Appendix Table J-7) to obtain the magnitude of habitat restoration by state.

2. Multiply regional household value per acre of restored habitat (Table 9-4) by the estimated

number of habitat acres within 316(b) region (from 1, above) to obtain total household WTP for

improved fish production in the waters affected by the 316(b) regulation by state for each region.

3. For each region, multiply total WTP per household for each state (Step 2) by the number of

households within the state, and sum across all states within the region to obtain unadjusted WTP

for habitat restoration within the 316(b) region.

EPA recognizes that WTP per household per acre is likely to be marginally decreasing as the scale of

restoration increases (e.g., Bishop et al. 2000), particularly if all statewide households are simultaneously

valuing fish production services provided by large-scale restoration of multiple habitat types. Household

values for policy changes may not be additive, and the sum of WTP values when policies are assessed

separately may exceed the total value of policies when assessed simultaneously. Simply summing the

statewide values for multiple 316(b) regions may overestimate the value of fish production services from

additional habitat acreage.

Based on this assessment, EPA incorporated a weighting adjustment in order to limit the potential for

overestimation of total WTP in cases where households within a given state are assigned values for
March 28, 2011 9-15

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

multiple 316(b) benefits regions (e.g., Mid-Atlantic and Inland). State-level WTP values within a 316(b)

region were adjusted based on the relative magnitude of regional restoration area compared to total

restoration area assigned to the state. For example, if a state were to be assigned 100 acres from the MidAtlantic region and 300 acres from the Inland region, the statewide WTP for the Mid-Atlantic and Inland

regions would be multiplied by factors of 0.25 (100 acres/400 acres) and 0.75 (300 acres/400 acres),

respectively. In the final step of estimating aggregating values for each region, weighted WTP values

were summed across all states to calculate the total annual WTP associated with each 316(b) region.

9.5 WTP Results

Table 9-5 presents the estimated WTP for habitat restoration area necessary to compensate for I&E

mortality under baseline conditions, as well as estimated WTP for habitat restoration area equivalent to

I&E mortality reductions under proposed regulatory options. EPA was unable to identify household WTP

for the preferred scaling habitat (giant kelp) in the California region (Table 9-3). As such, national

estimates of WTP are understated.

National WTP for habitat restoration to compensate for baseline I&E mortality is approximately $3.6

billion and $3.7 billion using 3 percent and 7 percent discount rates, respectively (Table 9-5). Under both

discount rates, WTP for habitat restoration in the Mid-Atlantic region represents 61 percent of the

national total. Despite representing 54 percent of the national area of restoration necessary to compensate

for baseline I&E mortality (Table 9-2), WTP for habitat restoration in the Inland region represented only

7 percent of national WTP. This difference is in large part due to lower household WTP values for habitat

restoration than values found in other regions.

At a 3 percent discount rate, total national WTP for habitat restoration equivalent to I&E mortality

reductions under Option 1 is $513.3 million (Table 9-5). Because they reduce entrainment losses in the

majority of facilities, and because 66 percent of national I&E mortality occurs due to entrainment

mortality (Chapter 3), WTP for Options 2 and 3 is about four times greater than WTP for Option 1.

Assuming a 3 percent discount rate, national WTP for both Options 2 and 3 is approximately $2.1 billion

(Table 9-5).
March 28, 2011 9-16

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 9-5: Weighted WTP for Habitat Restoration Area Equivalent to Baseline I&E Mortality, and Weighted WTP for Habitat

Restoration Area Equivalent to I&E Mortality Reductions by Region and Regulatory Option

Baseline Option 1 Option 2 Option 3 Baseline Option 1 Option 2 Option 3

California Giant kelp

Macrocystis

- - - - - - - - -

North Atlantic Eelgrass

Zostera marina

0.076 388.7 0.5 216.2 226.9 395.2 0.4 168.0 176.2

Mid-Atlantic Smooth cordgrass

Spartina

0.017 2,234.2 210.3 1,280.4 1,295.4 2,271.5 195.5 929.1 940.7

South Atlantic Smooth cordgrass

Spartina

0.011 0.8 0.4 0.5 0.5 0.8 0.3 0.4 0.4

Gulf of Mexico Smooth cordgrass

Spartina

0.011 732.2 153.4 390.6 389.6 744.4 142.6 305.9 305.0

Great Lakes Broadleaf cattail

Typha latifolia

0.003 18.9 10.4 12.2 12.2 19.2 9.7 9.6 9.6

Inland Broadleaf cattail

Typha latifolia

0.001 264.3 138.5 167.8 170.6 268.7 128.7 130.0 131.6

Total

(All Regions)

- - 3,639.0 513.3 2,067.6 2,095.1 3,699.8 477.2 1,542.8 1,563.4

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 DIF MGD; Option 3 =

I&E Mortality Everywhere

7% Discount Rate

Weighted WTP for Regulatory Options (2009$, millions)

Region Habitat

Household

WTP acre-1

year

-1

3% Discount Rate
March 28, 2011 9-17

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

9.6 Limitations and Uncertainties

Benefit transfer involves adapting research conducted for another purpose in the available literature to

address the policy questions at hand. Because benefits analysis of environmental regulations rarely

affords sufficient time to develop original stated preference surveys that are specific to the policy effects,

benefit transfer is often the only option to inform a policy decision. Consequently, there are several

limitations and uncertainties to this approach.

9.6.1 Estimating the Extent of the Affected Population

The magnitude of the affected population has a multiplicative effect on total WTP values for I&E

mortality. EPA acknowledges that I&E mortality can have impacts not restricted to state boundaries, due

to the migratory nature of fish populations, and the fact that multiple states may share impacted

watersheds. EPA’s approach underestimates WTP if members of a population value I&E mortality

occurring in different states.

9.6.2 Not All Species and Losses Are Compensated

EPA scaled restoration to compensate total production lost annually in each region rather than on a

species-specific basis. This assumes that secondary production is a proxy for important ecosystem

services such as food provision and nutrient cycling. This approach is likely to underestimate needed

restoration to the extent that the public has higher nonuse values for specific species (for example,

threatened and endangered species) that are under-compensated when habitat restoration is scaled based

on total losses.

9.6.3 Timing of Losses and Restoration

Fish production services provided by a restored habitat may increase over time as the habitat undergoes

natural successional processes, or conversely, fish production services may decline or cease if habitat

restoration is not successful. EPA scaled restoration using primary productivity values reflective of

mature habitat: scaling based on mature habitat is consistent with valuation studies that provide WTP for

marginal habitat acres. EPA is not suggesting that restoration of habitat area estimated by the described

approaches actually be implemented. If restoration were implemented, primary productivity values used

in the calculation would likely overestimate marginal gains of restored habitats and would therefore

underestimate WTP. If available, the inclusion of site-specific information regarding the trajectory and

duration of restoration benefits would improve the accuracy of scaling estimates.

9.6.4 Application of the Approach to Large Geographic Areas

Application of the habitat-based approach for compensating I&E mortality on a regional scale is uncertain

because of the diversity of habitats and species within a region. Many species of fish require more than

one habitat: the non-restored habitat may represent the limiting factor for fish populations. Moreover, due

to site-specific effects, species losses due to I&E mortality are likely to vary both among and within

regions. Similarly, people may have diverse values for habitats across a state. Although such effects exist,

EPA assigned ecological parameter values based on average values for a region. Also, most valuation

studies included in the analysis used statewide survey populations. Consequently, mean values reflect the

diversity of valuation that occurs throughout a state.
March 28, 2011 9-18

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Valuation studies were not available for all habitats and regions. Primary WTP values were applied in

regions when a reasonable value for the restored habitat was unavailable. Valuation studies are most

accurately applied to areas near the original study location, and may underestimate or overestimate values

in other states or regions.

Uncertainty also exists in estimates of proportionate habitat value associated with fish production

services. Application of the Johnston et al. (2002b) study may lead to overestimation or underestimation

of WTP for fish habitat services of wetlands outside Rhode Island: the study is most appropriately

transferred within southern New England and nearby areas where coastal populations (i.e., preferences)

and coastal wetland conditions (i.e., ecology) are similar. In the absence of comparable studies conducted

within individual regions, however, the estimate of Johnston et al. (2002b) was applied across regions for

saltmarsh habitat.

9.6.5 Specification of Parameter Assumptions

EPA’s implementation of a trophic transfer approach required the estimation of several parameter inputs

(e.g., primary productivity values, carbon export, trophic conversion efficiencies). These values represent

extrapolations from different scales, regions, or ecosystems, and are dependent on many simplifying

assumptions. Scaling results may exhibit substantial sensitivity to these assumptions. For example, EPA

applied a simple four-level food chain to all fish species, and used mean value for trophic transfer

efficiencies across all habitats (French et al. 1996). The scientific literature indicates substantial

uncertainty in values estimated in local habitats, and fish species vary greatly in their position in natural

food webs. Additionally, natural variability will impact production and consumption in all habitats.

Consequently, productivity estimates cannot be viewed as representing anything more than a simplified

average value.
March 28, 2011 10-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

10 National Benefits

10.1 Introduction

This chapter summarizes the results of the seven regional analyses, and presents EPA’s estimates of the

national benefits of the regulatory options for in-scope 316(b) facilities:

 Option 1: I Everywhere. Establish Impingement Mortality Controls at All Existing Facilities

that Withdraw over 2 MGD DIF; Determine Entrainment Controls for Facilities Greater than 2

MGD DIF On a Site-specific Basis.

 Option 2: I 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 Cooling By Facilities Greater Than 125 MGD DIF.

 Option 3: I&E Mortality Everywhere. Establish Impingement Mortality Controls at All

Existing Facilities that Withdraw over 2 MGD DIF; Require Flow Reduction Commensurate with

Closed-Ccycle Cooling at All Existing Facilities over 2 MGD DIF.

Greater detail on the methods and data used in the regional analyses is provided in the previous chapters

of this report. See Chapter 3 for a discussion of the methods used to estimate impingement mortality and

entrainment (I&E mortality), and a summary of the estimated baseline I&E mortality losses and

reductions in I&E mortality under the proposed 316(b) regulatory options. See Chapters 5 through 8 for a

discussion of the methods used to estimate the value of I&E mortality losses and the benefits of the

alternative policy options.

EPA was unable to estimate monetized nonuse benefits for I&E mortality losses in all regions. Therefore,

the benefits estimates presented in this section do not reflect total benefits associated with reducing I&E

mortality at in-scope facilities, and overall national benefits may accordingly be higher. Section 10.2

describes EPA’s methodology for aggregating benefits at the national level; Section 10.3 summarizes

baseline losses and expected reductions in I&E mortality; Section 10.4 presents national benefits; and

Section 10.5 discusses nonuse benefits and presents a break-even analysis.

10.2 Methodology

EPA notes that quantifying and monetizing the benefits that result from reductions in I&E mortality under

the regulatory options considered for the Section 316(b) facilities rulemaking is challenging. The

preceding sections of this report discuss specific limitations and uncertainties associated with estimating

reductions in I&E mortality losses and monetized benefits. EPA estimated national-level benefits by

summing benefit estimates over the seven study regions. Thus, national benefit estimates are subject to

the same uncertainties inherent in the valuation approaches used for assessing each of the four benefit

categories (threatened and endangered species, commercial fishing, recreational fishing, and nonuse

values). The national benefits estimates do not include habitat-based values presented in Chapter 9; the

habitat-based analysis was conducted for illustrative purposes to demonstrate the potential magnitude of

total value inclusive of 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.
March 28, 2011 10-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

10.3 Summary of Baseline Losses and Expected Reductions in I&E Mortality

Based on the results of the regional analyses, EPA calculated total I&E mortality losses under baseline

(i.e., pre- regulatory) conditions and the total amount by which losses would be reduced under each of the

regulatory options. The number of fish lost at in-scope facilities is presented in terms of age-1 equivalent

(A1E) losses (i.e., the number of individual fish of different ages impinged and entrained by facility

intakes, expressed as A1Es).

Table 10-1 presents baseline impingement, entrainment, and total I&E mortality losses. The table shows

that total national losses for all in-scope facilities are 2.2 billion fish in terms of A1Es. EPA notes that the

count of total lost organisms is larger than values expressed in A1Es. This table shows that about 46

percent of all A1E losses, or 1.0 billion fish, occur in the Mid-Atlantic region, followed by the Inland

region with 0.9 billion fish lost. More-detailed discussions of the I&E mortality losses in each region are

provided in Chapter 3 of this report.

Table 10-1: Baseline National A1E Losses at All In-scope Facilities (millions of A1Es)

Region Impingement Mortality Entrainment Mortality I&E Mortality

California 0.8 36.0 36.8

North Atlantic 0.6 59.4 60.0

Mid-Atlantic 50.7 939.4 990.1

South Atlantic 22.5 10.9 33.4

Gulf of Mexico 45.1 90.6 135.6

Great Lakes 44.1 9.4 53.5

Inland 583.6 295.9 879.5

National Total 747.4 1,441.5 2,188.9

EPA also calculated the total national I&E mortality losses prevented by each of the regulatory options.

These prevented losses are based on the expected reductions in I&E mortality at each facility due to

technology installation required under each option. Table 10-2 through Table 10-4 present expected

reductions in I&E mortality, expressed as A1Es, by region, under regulatory options considered in EPA’s

analysis. The tables show that at in-scope facilities, Option 1 reduces A1E losses by 0.6 billion fish. In

comparison, Option 2 and Option 3 both reduce A1E losses by approximately 2.0 billion fish.

Table 10-2: Reductions in National A1E Losses for All In-scope Facilities (millions of

A1Es) Under Option 1 (I Everywhere)

Region Impingement Mortality Entrainment Mortality I&E Mortality

California 0.7 0.0 0.7

North Atlantic 0.4 0.0 0.4

Mid-Atlantic 38.7 0.0 38.7

South Atlantic 14.2 0.0 14.2

Gulf of Mexico 34.5 0.0 34.5

Great Lakes 38.2 0.0 38.2

Inland 488.2 0.0 488.2

National Total 615.0 0.0 615.0
March 28, 2011 10-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 10-3: Reductions in National A1E Losses for All In-scope Facilities (million A1Es)

Under Option 2 (I Everywhere and E for Facilities > 125 MGD)

Region Impingement Mortality Entrainment Mortality I&E Mortality

California 0.8 30.7 31.5

North Atlantic 0.6 48.4 49.0

Mid-Atlantic 49.5 860.3 909.7

South Atlantic 19.2 9.1 28.3

Gulf of Mexico 44.7 61.3 106.0

Great Lakes 43.7 7.5 51.1

Inland 564.1 241.8 805.9

National Total 722.5 1,259.0 1,981.6

Table 10-4: Reductions in National A1E Losses for All In-scope Facilities (millions of A1Es)

Under Option 3 (I&E Mortality Everywhere)

Region Impingement Mortality Entrainment Mortality I&E Mortality

California 0.8 32.1 32.9

North Atlantic 0.6 50.8 51.4

Mid-Atlantic 49.6 871.3 920.9

South Atlantic 19.2 9.1 28.3

Gulf of Mexico 44.8 61.4 106.2

Great Lakes 43.8 7.6 51.3

Inland 569.6 252.9 822.5

National Total 728.3 1,285.2 2,013.5

Table 10-5 presents EPA’s estimates of the current level of total annual I&E mortality losses and the

reduction in total annual I&E mortality by option for the three metrics presented in Section 3.2.2. Option

3 (I&E Mortality Everywhere) results in the greatest reduction in I&E mortality, followed by Option 2 (I

Everywhere and E for Facilities > 125 MGD) and Option 1 (I Everywhere), respectively, for all of the

metrics.

Table 10-5: Baseline National I&E Mortality and I&E Mortality Reductions for All Inscope Facilities by Regulatory Option

Regulatory Option Millions of A1Es Forgone Fishery Yield

(million lbs)

Biomass Production Forgone

(million lbs)

Baseline 2,188.9 71.5 637.8

Option 1 615.0 13.3 137.6

Option 2 1,981.6 58.6 542.2

Option 3 2,013.5 59.2 556.2

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E

for Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere

As shown for all regions in Table 10-6, and by region in Chapter 3 of this report, the harvested

commercial and recreational fish species that have direct use values comprise between 1 and 9 percent of

baseline I&E mortality losses in each region, resulting in a national average of only 3 percent of I&E

mortality losses receiving a monetary value based on direct use. The remaining 97 percent of I&E

mortality losses include unharvested recreational and commercial fish and forage fish which do not have
March 28, 2011 10-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

direct use values. EPA’s nonuse analysis was limited two of the seven benefits regions and nonuse values

were not estimated for unharvested fish in the remaining five benefits regions. The total estimated

benefits are likely to be significantly understated due to the regional limitations of EPA’s nonuse analysis

and the relatively large fraction of I&E mortality reductions which are not commercially or recreationally

harvested.

Table 10-6: Distribution of National I&E Mortality for All In-scope Facilities by Regulatory

Option

Baseline 2,188.9 1,654.8 534.1 59.4 2.7%

Option 1 615.0 525.7 89.3 15.7 2.5%

Option 2 1,981.6 1,512.6 468.9 53.3 2.7%

Option 3 2,013.5 1,535.4 478.1 54.0 2.7%

Regulatory Option

a Harvestable fish are adult fish of the age at which they can legally be harvested.

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere

(a)

All Species

(millions of

A1Es)

(b)

Forage Species

(millions of

A1Es)

(c)

Commercial and

Recreational

Species

(millions of A1Es)

(d)

Harvested

Commercial and

Recreational

Species

(millions of fish

harvested)a

A1E Fish Assigned

a Direct Use Value

as Percentage of

Total

(column d /

column a)

10.4 National Monetized Benefits from Eliminating and Reducing I&E Mortality

Losses

EPA’s estimates of total national baseline losses and total national benefits under each option are based

on EPA’s regional estimates of monetized baseline losses 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 inscope facilities that reflects when benefits from compliance-related changes at each facility would be

realized. The methodology that EPA used to develop this time profile is detailed in Appendix D. For each

study region, EPA first calculated the undiscounted benefits (i.e., commercial and recreational fishing

benefits, including recreational fishing benefits from an increased abundance of T&E species) from the

expected annual I&E mortality reductions under the regulatory options, based on the assumptions that all

facilities in each region would achieve compliance and that benefits would be realized immediately

following compliance. Then, since there would be regulatory and biological time lags between

promulgation of the regulatory options and the realization of benefits, EPA created a time profile of

benefits that takes into account the fact that benefits do not begin immediately. Using this time profile of

benefits, EPA discounted the total benefits generated in each year of the analysis to 2012, the year when

the rule becomes effective, using discount rates of 3 percent and 7 percent.46 Appendix D of this report

provides detail on EPA’s development of the time profile of benefits.

46 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.
March 28, 2011 10-5

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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.47 Table 10-9 through Table 10-11

present these results for each region and for the nation as a whole. As described in above, the national

benefits estimates do not include habitat-based values presented in Chapter 9.

Table 10-7 shows that the total annual national value of losses due to CWIS at in-scope facilities,

discounted at 3 percent, includes $76.9 million in recreational fishing losses, $8.0 million in commercial

fishing losses, $1.1 million in T&E species losses, and $128.6 million in forgone nonuse benefits. The

total benefits of elimination of baseline CWIS, discounted at 3 percent, are $214.7 million per year, with

estimates based on the 5th percentile lower bound and 95th percentile upper bound for recreational values,

totaling $180.5 million and $281.0 million, respectively.

Discounted at 7 percent, the total annual national value of losses due to CWIS includes $75.6 million in

recreational fishing losses, $7.9 million in commercial fishing losses, $1.1 million in T&E species losses,

and $130.8 million in forgone nonuse benefits. The total use value of fishery resources lost, discounted at

7 percent, is $215.5 million per year, with estimates based on the 5th percentile lower bound and 95th

percentile upper bound for recreational values, totaling $181.8 million and $280.8 million, respectively.

Total monetized losses are greatest in the Mid-Atlantic region. More-detailed discussions of the valuation

of impacts under the baseline conditions in each region are provided in Chapters 5 through 8 of this

document.

Table 10-8, Table 10-9, and Table 10-10 present EPA’s estimates of the regional and national benefits of

reducing I&E mortality under each of the regulatory options (2009$, discounted at 3 percent and 7

percent). The national value of these reductions in I&E mortality losses, evaluated at a 3 percent discount

rate, is as follows:

 Option 1 (I Everywhere) results in national benefits of $17.6 million per year, with estimates

based on the 5th percentile lower bound and 95th percentile upper bound for recreational values,

totaling $10.0 million and $30.3 million (Table 10-8).

 Option 2 (I Everywhere and E for Facilities > 125 MGD) results in national benefits of $120.8

million per year, with estimates based on the 5th percentile lower bound and 95th percentile

upper bound for recreational values, totaling $101.3 million and $158.7 million (Table 10-9).

 Option 3 (I&E Mortality Everywhere) results in national benefits of $125.6 million per year,

with estimates based on the 5th percentile lower bound and 95th percentile upper bound for

recreational values, totaling $105.5 million and $164.9 million (Table 10-10).

Evaluated at a 7 percent discount rate, the national use benefits of the regulatory analysis options are

somewhat smaller:

 Option 1 (I Everywhere) results in national benefits of $16.0 million per year, with estimates

based on the 5th percentile lower bound and 95th percentile upper bound for recreational values,

totaling $9.1 million and $30.3 million (Table 10-8).

 Option 2 (I Everywhere and E for Facilities with > 125 MGD) results in national benefits of

$92.2 million per year, with estimates based on the 5th percentile lower bound and 95th

47 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.
March 28, 2011 10-6

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

percentile upper bound for recreational values, totaling $77.6 million and $120.6 million (Table

10-9).

 Option 3 (I&E Mortality Everywhere) results in national use benefits of $95.7 million per year,

with estimates based on the 5th percentile lower bound and 95th percentile upper bound for

recreational values, totaling $80.7 million and $124.9 million (Table 10-10).

The majority of benefit values are attributable to recreational fishing and nonuse benefits. Table 10-11

provides a convenient summary of benefits for the three regulatory options. More detailed discussions of

regional benefits under each option are provided in Chapters 5 through 8 of this report.
March 28, 2011 10-7

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 10-7: Summary of National Benefits from Eliminating Baseline I&E Mortality Losses for All In-scope Facilities (2009$)

Low Mean High Low Mean High

California $1.7 $2.9 $4.9 $1.2 - - $3.0 $4.2 $6.2

North Atlantic $1.8 $2.8 $4.6 $0.4 - $26.3 $28.5 $29.6 $31.3

Mid-Atlantic $15.2 $25.6 $44.5 $2.8 - $102.3 $120.4 $130.7 $149.6

South Atlantic $0.3 $0.3 $0.5 $0.0 - - $0.3 $0.4 $0.5

Gulf of Mexico $6.0 $8.9 $13.5 $3.5 - - $9.5 $12.3 $17.0

Great Lakes $1.1 $2.0 $3.5 $0.1 - - $1.2 $2.1 $3.6

Inland $16.6 $34.4 $71.7 - $1.1 - $17.7 $35.5 $72.8

Total $42.7 $76.9 $143.2 $8.0 $1.1 $128.6 $180.5 $214.7 $281.0

California $1.7 $2.8 $4.8 $1.2 - - $2.9 $4.0 $5.9

North Atlantic $1.7 $2.7 $4.4 $0.4 - $26.8 $28.9 $29.9 $31.6

Mid-Atlantic $14.7 $24.7 $43.0 $2.7 - $104.0 $121.5 $131.5 $149.7

South Atlantic $0.2 $0.3 $0.5 $0.0 - - $0.3 $0.4 $0.5

Gulf of Mexico $6.0 $8.8 $13.5 $3.4 - - $9.4 $12.3 $16.9

Great Lakes $1.1 $2.0 $3.5 $0.1 - - $1.2 $2.1 $3.6

Inland $16.5 $34.2 $71.4 - $1.1 - $17.6 $35.4 $72.5

Total $42.0 $75.6 $141.0 $7.9 $1.1 $130.8 $181.8 $215.5 $280.8

a All benefits presented in this table are annualized, i.e., equal to the value of all benefits generated over the time frame of the analysis, discounted to 2012, and then annualized over the entire period

of this analysis (2012 to 2062). 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

Zeros represent values less than 1,000.

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

3% Discount Rate

7% Discount Rate

Region

Annualized Benefitsa(2009$, millions)

Recreational Fishing Benefits

Commercial

Fishing

Benefitsc

T&E Species

Benefitsd,e

Total Benefitsb

Nonuse

Benefits
March 28, 2011 10-8

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 10-8: Summary of National Benefits of Option 1 (I Everywhere) for All In-scope Facilities (2009$)

Low Mean High Low Mean High

California $0.1 $0.1 $0.1 $0.0 - - $0.1 $0.1 $0.1

North Atlantic $0.0 $0.0 $0.0 $0.0 - $0.1 $0.1 $0.1 $0.1

Mid-Atlantic $0.8 $1.6 $3.1 $0.3 - $0.4 $1.6 $2.3 $3.9

South Atlantic $0.0 $0.0 $0.1 $0.0 - - $0.0 $0.0 $0.1

Gulf of Mexico $1.4 $2.4 $4.3 $0.6 - - $2.0 $3.0 $4.9

Great Lakes $0.6 $1.0 $1.6 $0.0 - - $0.6 $1.0 $1.7

Inland $5.1 $10.5 $22.0 - $0.5 - $5.6 $11.0 $22.5

Total $8.0 $15.6 $31.4 $1.0 $0.5 $0.5 $10.0 $17.6 $33.4

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 $0.7 $1.4 $2.8 $0.3 - $0.4 $1.4 $2.1 $3.5

South Atlantic $0.0 $0.0 $0.0 $0.0 - - $0.0 $0.0 $0.1

Gulf of Mexico $1.3 $2.2 $4.0 $0.5 - - $1.8 $2.7 $4.5

Great Lakes $0.5 $0.9 $1.5 $0.0 - - $0.6 $0.9 $1.5

Inland $4.6 $9.6 $20.1 - $0.5 - $5.1 $10.1 $20.6

Total $7.2 $14.2 $28.5 $0.9 $0.5 $0.5 $9.1 $16.0 $30.3

Nonuse

Benefits

a All benefits presented in this table are annualized, i.e., equal to the value of all benefits generated over the time frame of the analysis, discounted to 2012, and then annualized over the entire period

of this analysis (2012 to 2062). 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

Zeros represent values less than 1,000.

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

3% Discount Rate

7% Discount Rate

Region

Annualized Benefitsa(2009$, millions)

Recreational Fishing Benefits Commercial

Fishing

Benefitsc

T&E Species

Benefitsd,e

Total Benefitsb
March 28, 2011 10-9

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 10-9: Summary of National Benefits of Option 2 (I Everywhere and E for Facilities > 125 MGD) for All In-scope Facilities (2009$)

Low Mean High Low Mean High

California $1.0 $1.7 $2.9 $0.8 - - $1.8 $2.5 $3.7

North Atlantic $0.9 $1.5 $2.4 $0.2 - $14.8 $15.9 $16.5 $17.4

Mid-Atlantic $8.4 $14.1 $24.5 $1.6 - $57.3 $67.3 $73.0 $83.5

South Atlantic $0.1 $0.2 $0.3 $0.0 - - $0.2 $0.2 $0.3

Gulf of Mexico $3.2 $4.9 $7.6 $1.8 - - $5.0 $6.7 $9.4

Great Lakes $0.7 $1.3 $2.2 $0.1 - - $0.8 $1.3 $2.3

Inland $9.6 $19.9 $41.4 - $0.7 - $10.3 $20.6 $42.2

Total $24.0 $43.5 $81.5 $4.5 $0.7 $72.1 $101.3 $120.8 $158.7

California $0.8 $1.3 $2.2 $0.6 - - $1.4 $1.9 $2.8

North Atlantic $0.7 $1.1 $1.8 $0.2 - $11.5 $12.3 $12.7 $13.4

Mid-Atlantic $5.8 $9.8 $17.0 $1.1 - $44.5 $51.4 $55.4 $62.7

South Atlantic $0.1 $0.1 $0.2 $0.0 - - $0.1 $0.1 $0.2

Gulf of Mexico $2.5 $3.8 $5.9 $1.4 - - $3.9 $5.2 $7.3

Great Lakes $0.6 $1.0 $1.7 $0.0 - - $0.6 $1.0 $1.8

Inland $7.4 $15.3 $31.9 - $0.6 - $7.9 $15.8 $32.4

Total $17.8 $32.4 $60.8 $3.3 $0.6 $55.9 $77.6 $92.2 $120.6

a All benefits presented in this table are annualized, i.e., equal to the value of all benefits generated over the time frame of the analysis, discounted to 2012, and then annualized over the entire period

of this analysis (2012 to 2062). 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

Zeros represent values less than 1,000.

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

3% Discount Rate

7% Discount Rate

Region

Annualized Benefits a(2009$, millions)

Recreational Fishing Benefits

Nonuse

Benefits

Commercial

Fishing

Benefitsc

T&E Species

Benefitsd,e

Total Benefitsb
March 28, 2011 10-10

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 10-10: Summary of National Benefits of Option 3 (I&E Mortality Everywhere) for All In-scope Facilities (2009$)

Low Mean High Low Mean High

California $1.1 $1.8 $3.1 $0.8 - - $1.9 $2.6 $3.9

North Atlantic $1.0 $1.6 $2.7 $0.2 - $15.5 $16.7 $17.3 $18.3

Mid-Atlantic $8.6 $14.4 $25.1 $1.6 - $60.0 $70.2 $76.1 $86.7

South Atlantic $0.1 $0.2 $0.3 $0.0 - - $0.2 $0.2 $0.3

Gulf of Mexico $3.3 $4.9 $7.7 $1.8 - - $5.1 $6.7 $9.5

Great Lakes $0.7 $1.3 $2.3 $0.1 - - $0.8 $1.3 $2.3

Inland $10.0 $20.7 $43.1 - $0.7 - $10.7 $21.4 $43.8

Total $24.8 $44.9 $84.2 $4.5 $0.7 $75.5 $105.5 $125.6 $164.9

California $0.8 $1.4 $2.3 $0.6 - - $1.4 $2.0 $2.9

North Atlantic $0.8 $1.2 $2.0 $0.2 - $12.0 $12.9 $13.4 $14.1

Mid-Atlantic $6.0 $10.0 $17.5 $1.1 - $46.5 $53.6 $57.7 $65.1

South Atlantic $0.1 $0.1 $0.2 $0.0 - - $0.1 $0.1 $0.2

Gulf of Mexico $2.5 $3.8 $5.9 $1.4 - - $3.9 $5.2 $7.3

Great Lakes $0.6 $1.0 $1.8 $0.0 - - $0.6 $1.0 $1.8

Inland $7.6 $15.8 $32.8 - $0.5 - $8.1 $16.3 $33.4

Total $18.3 $33.3 $62.5 $3.3 $0.5 $58.5 $80.7 $95.7 $124.9

a All benefits presented in this table are annualized, i.e., equal to the value of all benefits generated over the time frame of the analysis, discounted to 2012, and then annualized over the entire period

of this analysis (2012 to 2062). 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

Zeros represent values less than 1,000.

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

3% Discount Rate

7% Discount Rate

Nonuse

BenefitsRegion

Annualized Benefitsa(2009$, millions)

Recreational Fishing Benefits Commercial

Fishing

Benefitsc

T&E Species

Benefitsd,e

Total Benefitsb
March 28, 2011 10-11

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 10-11: Summary of National Benefits by Regulatory Option for All In-scope Facilities (2009$)

Low Mean High Low Mean High

Baseline $42.7 $76.89 $143.2 $8.05 $1.14 $128.64 $180.5 $214.72 $281.0

Option 1 $8.0 $15.62 $31.4 $0.99 $0.50 $0.52 $10.0 $17.63 $33.4

Option 2 $24.0 $43.52 $81.5 $4.47 $0.72 $72.10 $101.3 $120.80 $158.7

Option 3 $24.8 $44.94 $84.2 $4.52 $0.72 $75.48 $105.5 $125.65 $164.9

Baseline $42.0 $75.64 $141.0 $7.89 $1.14 $130.78 $181.8 $215.45 $280.8

Option 1 $7.2 $14.21 $28.5 $0.89 $0.45 $0.48 $9.1 $16.04 $30.3

Option 2 $17.8 $32.40 $60.8 $3.31 $0.56 $55.94 $77.6 $92.21 $120.6

Option 3 $18.3 $33.30 $62.5 $3.34 $0.55 $58.52 $80.7 $95.71 $124.9

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 MGD; Option 3 = I&E Mortality

Everywhere

a All benefits presented in this table are annualized, i.e., equal to the value of all benefits generated over the time frame of the analysis, discounted to 2012, and then annualized over the

entire period of this analysis (2012 through 2062). 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.

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

3% Discount Rate

7% Discount Rate

Regulatory Option

Annualized Benefitsa(2009$, millions)

Recreational Fishing Benefits Commercial Fishing

Benefitsc

T&E Species

Benefitsd,e

Nonuse Total Benefits

Benefits
March 28, 2011 10-12

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

10.5 Break-Even Analysis

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 mean nonuse values are greater than zero. Moreover, when

small per-capita nonuse values are held by a substantial fraction of the population, they can be very large

in the aggregate. While the general proposition is true, in this specific context we have been able to

estimate nonuse values for only two of the seven benefits regions.

As shown in Table 10-6 above, nearly all—97 percent—I&E mortality losses 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 were not assigned 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 estimate nonuse values 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

for evaluating the potential relationship between benefits and costs. The approach used here applies a

“break-even” analysis to identify what the unmonetized nonuse values would have to be in order for the

proposed options to have benefits that are equal to costs.

The break-even approach uses EPA’s estimates of monetized commercial and recreational use benefits for

the regulatory options, and subtracts them from the estimated annual compliance costs incurred by

facilities subject to the options. The resulting “net cost” enables one to work backwards to estimate what

the nonuse values would need to be (in terms of willingness to pay per household per year) in order for

total annualized benefits to equal annualized costs. Table 10-12 provides this assessment for the proposed

options. The table shows benefit values using a 3 percent or 7 percent discount rate, respectively.

As shown in Table 10-12, for total annualized benefits to equal total annualized costs, nonuse values per

household would have to be at least $3, but may be as great as $40 under the 3 percent discount rate,

depending on the regulatory option. The 7 percent discount estimates show that nonuse values per

household would have to be $4 to $42, depending on the regulatory option.
March 28, 2011 10-13

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 10-12: Implicit Nonuse Value—Break-Even Analysis, 3 Percent and 7 Percent Discount

Rates (2009$)

Regulatory Optiona

Use Benefits

(2009$,

millions)a

Annual Social

Cost (2009$,

millions)b

Annual Nonuse

Benefits Necessary to

Break Even (2009$) c, d

Number of Households

in States with In-scope

316(b) Facilities

(millions)e

Annual BreakEven Nonuse WTP

per Household

(2009$)f

Option 1 $17.11 $383.80 $366.69 114.5 $3.20

Option 2 $48.71 $4,462.90 $4,414.19 114.5 $38.54

Option 3 $50.17 $4,631.62 $4,581.45 114.5 $40.00

Option 1 $15.55 $458.81 $443.26 114.5 $3.87

Option 2 $36.27 $4,699.35 $4,663.08 114.5 $40.71

Option 3 $37.19 $4,862.05 $4,824.86 114.5 $42.12

Scenarios: Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 MGD; Option 3 = I&E Mortality Everywhere

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 Nonuse benefits may also include unmonetized use benefits, i.e., improvements in bird watching.

e

From U.S. Census 2000 (BLS): http://factfinder.census.gov.

f 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.

3% Discount Rate

7% Discount Rate

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 regulatory options, 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 per-household willingness to pay for the nonuse amenities

(existence and bequest) associated with an option likely to be greater or less than the ‘break-even’ benefit

levels displayed in Table 10-12?” The results of EPA’s Habitat Equivalency Analysis (HEA) (Chapter 9)

illustrate the potential magnitude of nonuse values for 316(b) regulatory options. However, EPA does not

consider HEA appropriate for a primary analysis of nonuse benefits due to limitations of the approach and

assumptions required for its application to 316(b) regulatory options.
March 28, 2011 11-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

11 Option 4 Results

11.1 Introduction

In addition to the three regulatory options presented in the preceding chapters of this report, i.e., Options

1, 2, and 3, EPA analyzed an additional regulatory option – Option 4: I for Facilities > 50 MGD – in

developing the Proposed 316(b) Existing Facilities Regulation. Option 4 is the same as Option 1: I

Everywhere, in all respects except for not requiring I mortality control for facilities less than 50 MGD.

Because EPA analyzed Option 4 after completing the analysis and documentation of the three main

regulatory options, the analysis results for Option 4 are presented separately in this chapter. The

methodology used to estimate the benefits of Option 4 are identical to those used for Options 1, 2, 3. See

Chapters 3 through 9 for additional detail regarding EPA’s methodology. This chapter presents the results

for Option 4 in two parts:

 The expected reductions in I&E Mortality under Option 4; and

 The monetized benefits under Option 4, including recreational fishing, commercial fishing, T&E

species, and nonuse benefits.

11.2 Expected Reductions in I&E Mortality under Option 4

Based on the results of the regional analyses, EPA calculated the total amount by which I&E mortality

losses would be reduced under Option 4. The number of fish lost at in-scope facilities is presented in

terms of age-1 equivalent (A1E) losses within Table 11-1. All reductions in I&E mortality under Option 4

are associated with reduced impingement. The reduction in national A1E losses is 602 million, or

approximately 98 percent of the reductions under Option 1 (I Everywhere). The percentage of national

A1E losses assigned a direct use value is 2.6 percent, slightly higher than the percentage observed under

Option 1. The remaining 97 percent of I&E mortality losses include unharvested recreational and

commercial fish and forage fish which are not assigned direct use values. Reductions in I&E mortality for

T&E species are slightly less than Option 1 (Table 5-5). Appendix C provides additional detail regarding

reductions in I&E mortality losses under Option 4.

Table 11-1: Distribution of I&E Mortality for All In-scope Facilities by Region Under Option 4 (I

Everywhere without New Units Requirements)

Region

All Species

(million A1E)

Forage Species

(million A1E)

Commercial &

Recreational Species

(million A1E)

Commercial &

Recreational Harvest

(million fish)

A1E Losses

with Direct Use

Value (%)

California 0.7 0.2 0.5 0.1 8.0%

North Atlantic 0.4 0.4 0.1 <0.1 1.5%

Mid-Atlantic 38.6 14.3 24.4 6.1 15.8%

South Atlantic 14.2 13.4 0.8 0.1 0.7%

Gulf of Mexico 34.2 4.3 30.0 4.6 13.3%

Great Lakes 37.9 33.2 4.7 0.5 1.3%

Inland 476.3 448.4 27.9 4.2 0.9%

Total 602.4 514.1 88.3 15.5 2.6%
March 28, 2011 11-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

11.3 Monetized Benefits Under Option 4

EPA’s estimation of regional and national benefits under Option 4 are based on EPA’s regional estimates

of reductions in I&E mortality losses. Option 4 would result in an estimated increase of approximately 5.7

million harvestable recreational fish and an estimated annual increase of 5.5 million pounds of

commercial harvest (Table 11-2Error! Reference source not found.). Monetized nonuse benefits are

based on estimated increase in winter flounder abundance of 0.03 percent, calculated using the approach

described in Chapter 8. Under Option 4, recreational fishing benefits account for the majority of the

national benefits similar to Option 1 (I Everywhere). As described in Chapter 10, EPA estimated mean

values, as well as values that include the 5th percentile lower bound and 95th percentile upper bound of the

recreational benefits estimates.

Table 11-2: Annual Increase in Recreational and Commercial Harvest Under

Option 4 (I Everywhere without New Units Requirements)

Region

Annual Increase in Recreational

Harvest

(harvestable adult fish)

Annual Increase in Commercial

Harvest

(thousand lbs)

California 35,421 6.5

North Atlantic 1,495 2.9

Mid-Atlantic 548,496 3746.3

South Atlantic 15,882 45.1

Gulf of Mexico 660,672 1448.4

Great Lakes 174,601 225.1

Inland 4,215,546 -

Total 5,652,113 5474.3

Overall, monetized benefits under Option 4 are slightly less than those estimated for Option 1:

 Using a 3% discount rate, Option 4 results in national benefits of $17.3 million per year, with

estimates based on the 5th percentile lower bound and 95th percentile upper bound for

recreational values, totaling $9.8 million and $32.8 million (Table 11-3). Use benefits are

estimated to be $16.8 million with an annual break-even nonuse WTP of $2.70 per household

based on total social costs of $326.6 million.

 Using a 7% discount rate, Option 4 results in national benefits of $15.8 million per year, with

estimates based on the 5th percentile lower bound and 95th percentile upper bound for

recreational values, totaling $8.9 million and $29.8 million (Table 11-3). Use benefits are

estimated to be $15.3 million with an annual break-even nonuse WTP of $3.21 per household

based on total social costs of $383.1 million.

Table 11-4 summarizes results from applying the habitat-based approach described in Chapter 9. Similar

to other options, the Inland region accounts for the majority of habitat acres. National weighted WTP is

estimated to be $510 million and $474 million using discount rates of 3% and 7%, respectively. As

described in previous chapters, EPA did not include values estimated using the habitat-based approach

within its estimate of national benefits as presented in Table 11-3.
March 28, 2011 11-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 11-3: Summary of National Benefits of Option 4 (I for Facilities > 50 MGD) (2009$)

Low Mean High Low Mean High

California $0.1 $0.1 $0.1 $0.0 - - $0.1 $0.1 $0.1

North Atlantic $0.0 $0.0 $0.0 $0.0 - $0.1 $0.1 $0.1 $0.1

Mid-Atlantic $0.8 $1.6 $3.1 $0.3 - $0.4 $1.6 $2.3 $3.9

South Atlantic $0.0 $0.0 $0.1 $0.0 - - $0.0 $0.0 $0.1

Gulf of Mexico $1.4 $2.4 $4.3 $0.6 - - $2.0 $3.0 $4.9

Great Lakes $0.6 $0.9 $1.6 $0.0 - - $0.6 $1.0 $1.7

Inland $4.9 $10.3 $21.5 - $0.5 - $5.4 $10.8 $22.0

Total $7.8 $15.3 $30.8 $1.0 $0.5 $0.5 $9.8 $17.3 $32.8

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 $0.7 $1.4 $2.8 $0.3 - $0.4 $1.4 $2.1 $3.5

South Atlantic $0.0 $0.0 $0.0 $0.0 - - $0.0 $0.0 $0.1

Gulf of Mexico $1.3 $2.2 $3.9 $0.5 - - $1.8 $2.7 $4.5

Great Lakes $0.5 $0.9 $1.5 $0.0 - - $0.6 $0.9 $1.5

Inland $4.5 $9.4 $19.6 - $0.4 - $5.0 $9.8 $20.1

Total $7.1 $13.9 $28.0 $0.9 $0.4 $0.5 $8.9 $15.8 $29.8

Region

Annualized Benefitsa(2009$, millions)

Recreational Fishing Benefits

Commercial Fishing

Benefitsc

T&E Species

Benefitsd,e

Nonuse

Benefits

Total Benefitsb

3% Discount Rate

7% Discount Rate

a All benefits presented in this table are annualized, i.e., equal to the value of all benefits generated over the time frame of the analysis, discounted to 2012, and then annualized over the entire period of

this analysis (2012 to 2062). 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

Zeros represent values less than 1,000.
March 28, 2011 11-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table 11-4: Weighted WTP for Habitat Restoration Area Equivalent to I&E Mortality Reductions by

Region under Option 4 (I for Facilities > 50 MGD)

3%

Discount

Rate

7%

Discount

Rate

California 96 3 35 - 0.0 0.0

North Atlantic 50 1 23 0.076 0.5 0.4

Mid-Atlantic 47 240 5,145 0.017 211.1 196.3

South Atlantic 83 13 159 0.011 0.4 0.3

Gulf of Mexico 83 338 4,091 0.011 152.7 142.0

Great Lakes 82 251 3,065 0.003 10.4 9.6

Inland 82 3,340 40,813 0.001 134.8 125.4

Total

(All Regions) - 4,186 53,331 - 509.9 474.0

Region

Household

WTP acre-1

year

-1

(2009$)

Weighted WTP (2009$,

Secondary millions)

Productivity

(kg acre-1 year-1)

I&E Losses

(metric tons

A1E, dry

weight)

Equivalent

Restoration

Area (acres)
March 28, 2011 12-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

12 References

Abelson, A. and M. Denny (1997). "Settlement of Marine Organisms in Flow." Annual Review of

Ecology & Systematics 28: 317.

Abt Associates, Inc. (2009a). Summary of Ecological Effects of Thermal Discharge. Cambridge, MA.

Memorandum to EPA dated October 28, 2009. 28.

Abt Associates, Inc. (2009b). Wetland Fish Production Memo to EPA, WA 02-9 Task 4. December 24,

2009.

Abt Associates, Inc. (2010a). Estimates of the amount of TN and TP regenerated by I&E losses (Under

Work Assignment 2-09, Task 4) Cambridge, MA. Memorandum to EPA dated January 21, 2010.

3.

Abt Associates, Inc. (2010b). Source Water Body Comparisons (Under Work Assignment 2-09, Task 4).

Memorandum to EPA dated February 23, 2010. 13.

Alaska Fisheries Science Center (AFSC) of the NOAA National Marine Fisheries Service (2010). Alaska

Fisheries Science Center Publications Database. Available at

http://access.afsc.noaa.gov/pubs/search.cfm.

Allardyce, D. A. (1991). Endangered and threatened wildlife and plants: notice of findings on petition to

list the paddlefish. U.S. Fish and Wildlife Service. Pierre, South Dakota.

Anonymous (1997). "Tidal Wetlands in New York State." New York Conservationist 51(psupp 4-5).

Asche, F., T. Bjorndal, et al. (2005). Demand Structure for Fish. Institute for Research in Economics and

Business Administration. Bergen, Norway. SNF Project No. 5256: SIP Resource Management.

Ash, G. R., N. R. Chymko, et al. (1974). "Fish kill due to 'cold shock' in Lake Wabamun, Alberta."

Journal of the Fisheries Research Board of Canada 11: 1822-1824.

Atlantic States Marine Fisheries Commission (ASMFC) (2010). "Managed Species." Available at

http://www.asmfc.org/managedspecies.htm.

Auster, P. J. and R. W. Langton (1999). "The effects of fishing on fishery habitat." American Fishery

Society Symposium 22.

Axelrad, D. M., K. A. Moore, et al. (1976). Nitrogen, phosphorus and carbon flux in Chesapeake Bay

marshes. In Virginia Water Research Bulletin 79. Virginia Water Resources Research Center,

Virginia Polytechnic Institute and State University. Blacksburg, VA. Virginia Water Research

Bulletin 79.

Bach, S. D., G. W. Thayer, et al. (1986). "Export of Detritus from Eelgrass (Zostera-Marina) Beds near

Beaufort, North-Carolina, USA." Marine Ecology - Progress Series 28: 265-278.

Ball, S. L. and R. L. Baker (1996). "Predator--Induced Life History Changes: Antipredator Behavior

Costs or Facultative Life History Shifts?" Ecology 77(4): 1116-1124.

Balletto, J. H., M. V. Heimbuch, et al. (2005). "Delaware Bay salt marsh restoration: Mitigation for a

power plant cooling water system in New Jersey, USA." Ecological Engineering 25(3): 204-213.

Barnett, P. R. O. (1972). "Effects of Warm Water Effluents from Power Stations on Marine Life."

Proceedings of the Royal Society B: Biological Sciences 180(1061): 497-509.

Bartholow, J. M., S. G. Campbell, et al. (2004). "Predicting the thermal effects of dam removal on the

Klamath River." Environmental Management 34(6): 856-874.

Bason, C. (2008). Comments on the National Pollutant Discharge Elimination System Draft Permit for

the Indian River Generating Station. Delaware Center for the Inland Bays. April 4, 2008.

Bateman, I. J., M. Cole, et al. (2004). "On visible choice sets and scope sensitivity." Journal of

Environmental Economics and Management 47(1): 71-93.

Bauer, D. M., N. E. Cyr, et al. (2004). "Public Preferences for Compensatory Mitigation of Salt Marsh

Losses: a Contingent Choice of Alternatives." Conservation Biology 18(2): 401-411.
March 28, 2011 12-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Beal, B. F., R. L. Vadas Sr., et al. (2004). "Annual Aboveground Biomass and Productivity Estimates for

Intertidal Eelgrass (Zostera marina L.) in Cobscook Bay, Maine." Northeastern Naturalist

11(Special Issue 2): 197-224.

Beck, M. W., K. L. Heck Jr., et al. (2003). "The Role of Nearshore Ecosystems as Fish and Shellfish

Nurseries." Issues in Ecology 11: 1-12.

Beitinger, T. L., W. A. Bennett, et al. (2000). "Temperature Tolerances of North American Freshwater

Fishes Exposed to Dynamic Changes in Temperature." Environmental Biology of Fishes 58(3):

237-275.

Bell, F. W. (1986). "Competition from Fish Farming in Influencing Rent Dissipation: The Crawfish

Fishery." American Journal of Agricultural Economics 68(1): 95-101.

Bennett, S. J. and J. L. Best (1995). "Mean flow and turbulence structure over fixed, two-dimensional

dunes: implications for sediment transport and bedorm stability." Sedimentology 42(3): 491-513.

Bergstrom, J. C. and P. De Civita (1999). "Status of Benefits Transfer in the United States and Canada: A

Review." Canadian Journal of Agricultural Economics 47(1): 79-87.

Bergstrom, J. C. and L. O. Taylor (2006). "Using meta-analysis for benefits transfer: Theory and

practice." Ecological Economics 60(2): 351-360.

Biles, C. L., M. Solan, et al. (2003). "Flow modifies the effect of biodiversity on ecosystem functioning:

an in situ study of estuarine sediments." Journal of Experimental Marine Biology and Ecology

285-286: 165-177.

Bishop, R. C., W. S. Breffle, et al. (2000). Restoration Scaling Based on Total Value Equivalency: Green

Bay Natural Resource Damage Assessment: Final Report. Prepared by Stratus Consulting, Inc.

Prepared for U.S. Fish and Wildlife Service, U.S. Department of the Interior, and U.S.

Department of Justice. October 25, 2000.

Bishop, R. C. and M. Holt (2003). Estimating Post-harvest Benefits from Increases in Commercial Fish

Catches with Implications for Remediation of Impingement and Entrainment Losses at Power

Plants. In Agricultural & Applied Economics Staff Paper Series. University of WisconsinMadison, Department of Agricultural & Applied Economics. Staff Paper No. 458. Available at

http://www.aae.wisc.edu/pubs/sps/pdf/stpap458.pdf.

Blomquist, G. C. and J. C. Whitehead (1998). "Resource quality information and validity of willingness

to pay in contingent valuation." Resources and Energy Economics 20(2): 179-196.

Bockstael, N. E. and I. E. Strand Jr. (1987). "The Effect of Common Sources of Regression Error on

Benefit Estimates." Land Economics 63(1): 11-20.

Boreman, J. (2000). "Surplus production, compensation, and impact assessments of power plants."

Environmental Science & Policy 3(Supplement 1): 445-449.

Boreman, J. and P. Goodyear (1988). "Estimates of Entrainment Mortality for Striped Bass and Other

Fish Species Inhabiting the Hudson River Estuary." American Fisheries Society Monograph 4:

152-160.

Borey, R. B., P. A. Harcombe, et al. (1983). "Water and organic carbon fluxes from an irregularly flooded

brackish marsh on the upper Texas coast, U.S.A." Estuarine, Coastal and Shelf Science 16(4):

379-402.

Boxall, B. (2010). "Despite dire predictions, California farm jobs aren't disappearing." Los Angeles

Times. February 22, 2010.

Boyd, J., D. King, et al. (2001). "Compensation for Lost Ecosystem Services: The Need for BenefitBased Transfer Ratios and Restoration Criteria." Stanford Environmental Law Journal 20(2):

393-412.

Boyle, K. J. and J. C. Bergstrom (1992). "Benefit transfer studies: Myths, pragmatism, and idealism."

Water Resources Research 28(3): 657-663.

Brescia, C. J. (2002). Testimony of Christopher J. Brescia, President of Midwest Area River Coalition

2000, on Proposals for a Water Resources Development Act of 2002, before the Committee on

Environment and Public Works, United States Senate. June 18, 2002.
March 28, 2011 12-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Bresette, M., J. Gorham, et al. (1998). "Site Fidelity and Size Frequencies of Juvenile Green Turtles

(Chelonia mydas) Utilizing Near Shore Reefs in St. Lucie County, Florida." Marine Turtle

Newsletter 82: 5-7.

Brock, T. D. (1985). "Life at High Temperatures." Science 230: 132-138.

Bromberg, K. D. and M. D. Bertness (2005). "Reconstructing New England salt marsh losses using

historical maps." Estuaries 28(6): 823-832.

Bulthuis, D. A. (1987). "Effects of temperature on photosynthesis and growth of seagrasses." Aquatic

Botany 27(1): 27-40.

Byrnes, J. E., P. L. Reynolds, et al. (2007). "Invasions and Extinctions Reshape Coastal Marine Food

Webs." PLoS ONE 2(3): e295.

Cahoon, D. R. (1975). "Net productivity of emergent vegetation at Horn Point Salt Marsh," Thesis, MS.

University of Maryland.

Caparroy, P., M. T. Pérez, et al. (1998). "Feeding behaviour of Centropages typicus in calm and turbulent

conditions." Marine Ecology - Progress Series 168: 109-118.

Capps Jr., O. and J. A. Labregts (1991). "Assessing Effects of Prices and Advertising on Purchases of

Finfish and Shellfish in a Local Market in Texas." Southern Journal of Agricultural Economics

July: 181-194.

Carson, R. T., N. E. Flores, et al. (1999). The Theory and Measurement of Passive-Use Value. In Valuing

Environmental Preferences: Theory and Practice of the Contingent Valuation Method in the US,

EU, and Developing Countries. Bateman, I. J. and K. G. Willis. New York, Oxford University

Press: 97-130.

Cebrian, J. (2002). "Variability and control of carbon consumption, export, and accumulation in marine

communities." Limnol. Oceanogr. 47(1): 11-22.

Cheng, H.-t. and O. Capps Jr. (1988). "Demand Analysis of Fresh and Frozen Finfish and Shellfish in the

United States." American Journal of Agricultural Economics 70(3): 533.

Chesapeake Bay Program (CBP) (2007). Chesapeake Bay Watershed Assistance Network Access to

Federal Funds: A Collaborative Effort of the Chesapeake Bay Federal Agencies Committee and

the Chesapeake Bay Watershed Assistance Network. Chesapeake Bay Program. Annapolis,

Maryland. 101.

Choi, D. H., J. S. Park, et al. (2002). "Effects of thermal effluents from a power station on bacteria and

heterotrophic nanoflagellates in coastal waters." Marine Ecology Progress Series 229: 1-10.

Chuang, Y.-L., H.-H. Yang, et al. (2009). "Effects of a thermal discharge from a nuclear power plant on

phytoplankton and periphyton in subtropical coastal waters." Journal of Sea Research 61(4): 197-

205.

Clean Water Act (1972). 33 U.S.C. 1326(b).

Cleary, D. (1969). Demand and Prices for Shrimp. U.S. Department of Commerce, Bureau of

Commercial Fisheries, Division of Economic Research. Working Paper No. 15.

Cloete, T. E., L. Jacobs, et al. (1998). "The chemical control of biofouling in industrial water systems."

Biodegradation 9(1): 23-37.

Cohen, A. N. and J. T. Carlton (1998). "Accelerating invasion rate in a highly invaded estuary." Science

279(5350): 555.

Coles, S. L. (1984). "Colonization of Hawaiian reef corals on new and denuded substrata in the vicinity of

a Hawaiian power station." Coral Reefs 3(3): 123-130.

Conant, T. A., P. H. Dutton, et al. (2009). Loggerhead Sea Turtle (Caretta Caretta) 2009 Status Review

Under the U.S. Endangered Species Act. Report of the Loggerhead Biological Review Team to

the National Marine Fisheries Service. August 2009. 222.

Cooke, S. J., C. M. Bunt, et al. (2004). "Understanding fish behavior, distribution, and survival in thermal

effluents using fixed telemetry arrays: a case study of smallmouth bass in a discharge canal

during winter." Environmental Management 33(1): 140-150.
March 28, 2011 12-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Costanza, R. and C. Folke (1997). Valuing Ecosystem Services with Efficiency, Fairness, and

Sustainability as Goals. In Nature's services: Societal dependence on natural ecosystems. Daily,

G. Washington, D.C., Island Press.

Crouse, D. T., L. B. Crowder, et al. (1987). "A Stage-Based Population Model for Loggerhead Sea

Turtles and Implications for Conservation." Ecology 68(5): 1412-1423.

Daily, G. C., Ed. (1997). Nature’s Services: Societal Dependence on Natural Ecosystems. Washington,

D.C., Island Press.

Daily, G. C., S. Alexander, et al. (1997). Ecosystem Services: Benefits Supplied to Human Societies by

Natural Ecosystems. Washington, DC, Ecological Society of America.

Dame, R., T. H. Chrzanowski, et al. (1986). "The Outwelling Hypothesis and North Inlet, SouthCarolina." Marine Ecology - Progress Series 33: 217-229.

Dame, R. F., J. D. Spurrier, et al. (1991). "Annual Material Processing by a Salt-Marsh Estuarine Basin in

South Carolina, USA." Marine Ecology - Progress Series 72: 153-166.

Dankers, N., M. Binsbergen, et al. (1984). "Transportation of water, particulate and dissolved organic and

inorganic matter between a salt marsh and the Ems-Dollard estuary, The Netherlands." Estuarine,

Coastal and Shelf Science 19(2): 143-165.

Davis, C., S. Yen, et al. (2007). Consumer Demand for Meat Cuts and Seafood, Selected Paper. Presented

at the Annual Meeting of the American Agricultural Economics Association, July 29-August 1,

Portland, OR.

Day, J., W. Smith, et al. (1973). Community structure and carbon budget of a salt marsh and shallow bay

estuarine system in Louisiana. Center for Wetland Resources, Louisiana State University. Baton

Rouge, LA. Publication No. LSU-SG-72-04.

Dayton, P. K. (1985). "Ecology of Kelp Communities." Annual Review of Ecology & Systematics 16:

215-245.

de La Cruz, A. A. (1974). "Primary productivity of coastal marshes in Mississippi." Gulf Research

Reports 4: 351-356.

de Zyosa, A. D. N. (1995). "A Benefit Evaluation of Programs to Enhance Groundwater Quality, Surface

Water Quality and Wetland Habitat in Northwest Ohio," Dissertation, Doctor of Philosophy. Ohio

State University.

Deacutis, C. F. (1978). "Effect of Thermal Shock on Predator Avoidance by Larvae of Two Fish

Species." Transactions of the American Fisheries Society 107(4): 632-635.

Deegan, L. A., J. E. Hughes, et al. (2000). Salt Marsh Ecosystem Support of Marine Transient Species. In

Concepts and Controversies in Tidal Marsh Ecology. Weinstein, M. P. and D. A. Kreeger,

Springer Netherlands: 333-365.

Desvousges, W. H., F. R. Johnson, et al. (1998). Environmental Policy Analysis with Limited

Information: Principles and Applications of the Transfer Method. Northampton, MA, Edward

Elgar Publishers.

Dillman, B. L., L. J. Beran, et al. (1993). Nonmarket valuation of freshwater wetlands: The Francis

Beidler forest. South Carolina Water Resources Research Institute, Clemson University. 53.

Doll, J. P. (1972). "An Economic Analysis of Shrimp Ex-Vessel Prices, 1950-1968." American Journal of

Agricultural Economics 54(3): 431-440.

Dominion (2011). "Brayton Point Power Station." Available at

http://www.dom.com/about/stations/fossil/brayton-point-power-station.jsp.

EA Engineering, Science, and Technology (2008). Point Beach Nuclear Plant Evaluation of the Thermal

Effects Due to a Planned Extended Power Uprate. Prepared for FPL Energy Point Beach, LLC.

August 2008.

Earthwatch Institute (2010). "Trinidad's Leatherback Sea Turtles." Available at

http://www.earthwatch.org/exped/sammy.html. Accessed May 25, 2010.

Eckman, J. E. and D. O. Duggins (1993). "Effects of Flow Speed on Growth of Benthic Suspension

Feeders." Biology Bulletin 185(1): 28-41.
March 28, 2011 12-5

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Eggers, J. M. (1989). Incidental capture of sea turtles at Salem Generating Station, Delaware Bay, New

Jersey. Proceedings of the Ninth Annual Workshop on Sea Turtle Conservation and Biology.

NOAA Tech. Memo. NMFS-SEFC-232, Jekyll Island, Georgia, U. S. Dept. of Commerce.

Eggers, J. M., M. W. Haberland, et al. (2001). "Growth of Juvenile Loggerhead Sea Turtles Near

PSE&G's Salem Generating Station, Delaware Bay, New Jersey." Marine Turtle Newsletter 59:

5-7.

Enders, E. C., D. Boisclair, et al. (2003). "The effect of turbulence on the cost of swimming for juvenile

Atlantic salmon (Salmo salar)." Canadian Journal of Fisheries & Aquatic Sciences 60(9): 1149-

1160.

Entrix, Inc. (2001). "An ecological risk-based 316(a) demonstration for the Indian River power plant:

report prepared for Conectiv Energy."

Entrix, Inc. (2003). An ecological risk-based 316(b) demonstration for the Indian River power plant:

report prepared for NRG Energy, Inc. Wilmington, DE.

Erkan, D. E. (2002). Strategic Plan for the Restoration of Anadromous Fishes to Rhode Island Coastal

Streams. Rhode Island Department of Environmental Management, Division of Fish and Wildlife.

Wakefield, RI.

Ernest, R. G., R. E. Martin, et al. (1988). Sea turtle entrapment at a coastal power plant. Proceedings of

the Southeastern Workshop on Aquatic Ecological Effects of Power Generation, December 1986,

Mote Technical Report No. 124, Sarasota, FL, Mote Marine Laboratory.

Esteves, B. S., A. Enrich-Prast, et al. (2008). "Allometric relations for Typha domingensis natural

populations." Acta Limnologica Brasiliensia 20(4): 305-311.

Executive Order No. 13158 (2001). Marine Protected Areas, 3 CFR (2001, comp). p. 273.

Executive Order No. 13508 (2009). Chesapeake Bay Protection and Restoration. 74 Federal Register

23099 (May 14, 2009).

Feijtel, T. C., R. D. Delaune, et al. (1985). "Carbon Flow in Coastal Louisiana." Marine Ecology -

Progress Series 24: 255-260.

Fischman, R. L. (2001). "The EPA’s NEPA Duties and Ecosystem Services." Stanford Environmental

Law Journal 20(2): 497-536.

Fishbase (2009). Fishbase: A Global Information System on Fishes. Available at

http://www.fishbase.org/home.htm.

Folke, C., S. Carpenter, et al. (2004). "Regime Shifts, Resilience, and Biodiversity in Ecosystem

Management." Annual Review of Ecology, Evolution, & Systematics 35(1): 557-581.

Fortier, L. and R. P. Harris (1989). "Optimal foraging and density-dependent competition in marine fish

larvae." Marine Ecology - Progress Series 51: 19-33.

Fourqurean, J. W. and J. C. Zieman (2002). "Nutrient content of the seagrass Thalassia testudinum

reveals regional patterns of relative availability of nitrogen and phosphorus in the Florida Keys

USA." Biogeochemistry 61(3): 229-245.

Frazer, N. B. (2005). Conflicting Views of Sea Turtles: How many do we need, how much are they

worth? Presented at the Centre for Maritime Reserach Conference, People and the Sea II, July 7-

9.

Freeman III, A. M. (1993). Non-use values in natural resource damage assessment. In Valuing Natural

Assets. Kopp, R. J. and V. K. Smith. Washington, D.C., Resources for the Future.

Freeman III, A. M. (2003). The Measurement of Environmental and Resource Values: Theory and

Methods. Washington, D.C., Resources for the Future.

Freese, S., Northwest Region, National Marine Fisheries Service, Sustainable Fisheries Division (2008).

Seattle, WA. August 14, 2008.

French, D., M. Reed, et al. (1996). The CERCLA type A natural resource damage assessment model for

coastal and marine environments (SIMAP), Technical Documentation, Vol. I - Model

Description. Final Report, submitted to the Office of Environmental Policy and Compliance,

United States Department of the Interior. Washington, D.C. April. Contract No. 14-0001-91-C11.
March 28, 2011 12-6

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

French McCay, D., P. Peterson, et al. (2002). Restoration scaling of benthic, aquatic and bird injuries to

oyster reef and marsh restoration projects. Administrative Record Document I.D. Number 2049.

Available at http://www.darrp.noaa.gov/northeast/chalk_point/pdf/cpar2049.pdf.

French McCay, D. P. and J. J. Rowe (2003). "Habitat restoration as mitigation for lost production at

multiple trophic levels: Restoration scaling in the marine environment." Marine Ecology -

Progress Series 264: 233-247.

Froese, R. and D. Pauly (2009). "Fishbase (version 07/2009)." Fisheries Centre, University of British

Columbia. Available at www.fishbase.org.

Gallagher, J. L. (1975). "Effect of an Ammonium Nitrate Pulse on the Growth and Elemental

Composition of Natural Stands of Spartina alterniflora and Juncus roemerianus." American

Journal of Botany 62(6): 644-648.

Gibson, M. R. (2002). Winter flounder abundance near Brayton Point Station, Mt. Hope Bay revisited:

separating local from regional impacts using long-term abundance data. Rhode Island Division of

Fish and Wildlife Research. Research Reference Document 2/1.

Glass, G. V. (1976). "Primary, Secondary, and Meta-Analysis of Research." Educational Researcher

5(10): 3-8.

Goodyear, C. (1978). Entrainment Impact Estimates Using the Equivalent Adult Approach, FWS/OBS78/65. U.S. Department of the Interior, Fish and Wildlife Service. Washington, D.C. July.

Gottlieb, S. J. (1998). "Nutrient removal by age-0 Atlantic menhaden (Brevoortia tyrranus) in Chesapeake

Bay and implications for seasonal management of the fishery." Ecological Modelling 112(2-3):

111-130.

Government Accountability Office (GAO) (2005). Chesapeake Bay Program: Improved strategies are

needed to better assess, report, and manage restoration progress. Washington, D.C. GAO-06-06.

94.

Grace, J. B. and R. G. Wetzel (1982). "Variations in growth and reproduction within populations of two

rhizomatous plant species: Typha latifolia and Typha angustifolia." Oecologia 53(2): 258-263.

Graff, L. and J. Middleton (2003). Wetlands and Fish: Catch the Link. National Oceanic and Atmospheric

Administration and National Marine Fisheries Service. Silver Springs, MD. 48.

Great Lakes (1990). 33 U.S.C 1268(a)(3)(b).

Griffiths, C. (undated). The Use of Benefit-Cost Analysis in Environmental Policy Making. In Working

Paper. National Center for Environmental Economics, U.S. Environmental Protection Agency.

Washington, DC.

Grigalunas, T. A., J. J. Opaluch, et al. (1988). "Measuring Damages to Marine Natural Resources from

Pollution Incidents under CERCLA: Application of an Integrated Ocean Systems/Economic

Model." Marine Resource Economics 5(1): 1-21.

Gunderson, L. H. (2000). "Ecological Resilience - In Theory and Application." Annual Review of

Ecology & Systematics 31: 425.

Gustafson, T. D. (1976). "Production, Photosynthesis, and the Storage and Utilization of Reserves in a

Natural Stand of Typha latifolia," Dissertation, University of Wisconsin.

Hagen, D. A., J. W. Vincent, et al. (1992). "Benefits of Preserving Old-Growth Forests and the Spotted

Owl." Contemporary Economic Policy 10(2): 13-26.

Hairston, N. G., S. P. Ellner, et al. (2005). "Rapid evolution and the convergence of ecological and

evolutionary time." Ecology Letters 8(10): 1114-1127.

Hanemann, W. M. (1984). "Welfare evaluations in contingent valuation experiments with discrete

responses." American Journal of Agricultural Economics 66(3): 332-341.

Hayes, D. B., H. R. Dodd, et al. (2006). "Effects of small dams on cold water stream fish communities."

American Fisheries Society Symposium: 587-601.

HDR Engineering, Inc. (2009). Quad Cities Nuclear Station Adjusted Thermal Standard CWA 316(a)

Demonstration. Final Draft. Prepared for Exelon Nuclear. November, 2009.

Heal, G., G. C. Daily, et al. (2001). "Protecting Natural Capital through Ecosystem Service Districts."

Stanford Environmental Law Journal 20(2): 333-364.
March 28, 2011 12-7

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Hensher, D. and W. Greene (2003). "The Mixed Logit model: The state of practice." Transportation

30(2): 133-176.

Herman, J. S., D. C. Culver, et al. (2001). "Groundwater Ecosystems and the Service of Water." Stanford

Environmental Law Journal 20(2): 479-496.

Hilborn, R. and C. J. Walters (1992). Quantitative Fisheries Stock Assessment: Choice, Dynamics and

Uncertainty. New York, Chapman and Hall. 570.

Hillman, R. E., N. W. Davis, et al. (1977). "Abundance, diversity, and stability in shore-zone fish

communities in an area of Long Island Sound affected by the thermal discharge of a nuclear

power station." Estuarine and Coastal Marine Science 5(3): 355-381.

Hixon, M. A. and G. P. Jones (2005). "Competition, predation, and density-dependent mortality in

demersal marine fishes." Ecology 86(11): 2847-2859.

Hoagland, P. and D. Jin (2006). "Science and Economics in the Management of an Invasive Species."

BioScience 56(11): 931-935.

Holly Jr., F. M., S. Li, et al. (2004). River temperature predictions downstream of Quad Cities Nuclear

Generating Station. Preliminary Draft. Submitted to Exelon Generation. Iowa Institute of

Hydroscience & Engineering (IIHR), University of Iowa. Iowa City, IA. April, 2004.

Holmlund, C. M. and M. Hammer (1999). "Ecosystem services generated by fish populations."

Ecological Economics 29(2): 253-268.

Holt, M. T. and R. C. Bishop (2002). "A semiflexible normalized quadratic inverse demand system: an

application to the price formation of fish." Empirical Economics 27(1): 23-47.

Holt, R. D. (1977). "Predation, apparent competition, and the structure of prey communities." Theoretical

Population Biology 12(2): 197-229.

Hopkinson, C. S., J. G. Gosselink, et al. (1978). "Aboveground Production of Seven Marsh Plant Species

in Coastal Louisiana." Ecology 59(4): 760-769.

Horst, T. J. (1975). The Assessment of Impact Due to Entrainment of Ichthyoplankton. In Fisheries and

Energy Production: A Symposium. Saila, S. B. Lexington, D.C. Heath.

Howes, B. L., J. W. H. Dacey, et al. (1985). "Annual Carbon Mineralization and Belowground Production

of Spartina Alterniflora in a New England Salt Marsh." Ecology 66(2): 595-605.

Howitt, R. E., D. MacEwan, et al. (2009). "Economic Impacts of Reductions in Delta Exports on Central

Valley Agriculture." ARE Update 12(3): 1-4.

Hoyal, D. C. J. D., J. F. Atkinson, et al. (1995). "The effect of turbulence on sediment deposition."

Journal of Hydraulic Research 33(3): 349-360.

Hu, W., M. M. Veeman, et al. (2005). "Labelling Genetically Modified Food: Heterogeneous Consumer

Preferences and the Value of Information." Canadian Journal of Agricultural Economics 53(1):

83-102.

Interagency Working Group (IWG) (2010). Scientific Assessment of Hypoxia in U.S. Coastal Waters.

National Centers for Coastal Ocean Science. May 2010.

Jackson, J. B., M. X. Kirby, et al. (2001). "Historical overfishing and the recent collapse of coastal

ecosystems." Science 293(5530): 629-637.

Jiang, Z.-B., J.-N. Zeng, et al. (2009). "Potential impact of rising seawater temperature on copepods due

to coastal power plants in subtropical areas." Journal of Experimental Marine Biology and

Ecology 368(2): 196-201.

Jirotkul, M. (1999). "Population density influences male-male competition in guppies." Animal

Behaviour 58(6): 1169-1175.

Johnson, M. (1970). Preliminary report on species composition, chemical composition, biomass, and

production of marsh vegetation in the upper Patuxent Estuary, Maryland. Chesapeake Biological

Laboratory. Solomons, MD. Ref. No. 70-130.

Johnston, R. J. and J. M. Duke (2007). "Willingness to Pay for Agricultural Land Preservation and Policy

Process Attributes: Does the Method Matter?" American Journal of Agricultural Economics

89(4): 1098-1115.
March 28, 2011 12-8

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Johnston, R. J. and J. M. Duke (2009). "Willingness to Pay for Land Preservation across States and

Jurisdictional Scale: Implications for Benefit Transfer." Land Economics 85(2): 217-237.

Johnston, R. J., T. A. Grigalunas, et al. (2002a). "Valuing Estuarine Resource Services Using Economic

and Ecological Models: The Peconic Estuary System Study." Coastal Management 30(1): 47.

Johnston, R. J., G. Magnusson, et al. (2002b). "Combining Economic and Ecological Indicators to

Prioritize Salt Marsh Restoration Actions." American Journal of Agricultural Economics 84(5):

1362-1370.

Johnston, R. J., J. J. Opaluch, et al. (2001). "Estimating Amenity Benefits of Coastal Farmland." Growth

& Change 32(3): 305-325.

Johnston, R. J., M. H. Ranson, et al. (2006). "What Determines Willingness to Pay per Fish? A MetaAnalysis of Recreational Fishing Values." Marine Resource Economics 21(1): 1-32.

Johnston, R. J. and R. S. Rosenberger (2010). "Methods, Trends and Controversies in Contemporary

Benefit Transfer." Journal of Economic Surveys 24(3): 479-510.

Johnston, R. J., E. T. Schultz, et al. (2009). Improving the Ecological Validity of Non-Market Valuation:

Development and Application of Bioindicator-Based Stated Preference Valuation for Aquatic

Restoration. Presented at the AERE Sessions at the American Agricultural Economics

Association (AAEA) Annual Meeting, Milwaukee, WI, July 26-28.

Johnston, R. J., S. K. Swallow, et al. (1999). "Estimating Willingness to Pay and Resource Tradeoffs with

Different Payment Mechanisms: An Evaluation of a Funding Guarantee for Watershed

Management." Journal of Environmental Economics and Management 38(1): 97-120.

Johnston, R. J., T. F. Weaver, et al. (1995). "Contingent valuation focus groups: insights from

ethnographic interview techniques." Agricultural and Resource Economics Review 24(1): 56-69.

Jude, D. J. and J. Pappas (1992). "Fish Utilization of Great Lakes Coastal Wetlands." Journal of Great

Lakes Research 18(4): 651-672.

Kaldy, J. E. and K. H. Dunton (2000). "Above- and below-ground production, biomass and reproductive

ecology of Thalassia testudinum (turtle grass) in a subtropical coastal lagoon." Marine Ecology -

Progress Series 193: 271-283.

Kaplowitz, M. D., F. Lupi, et al. (2004). Multiple Methods for Developing and Evaluating a StatedChoice Questionnaire to Value Wetlands. In Methods for Testing and Evaluating Survey

Questionnaires. Presser, S., J. M. Rothget, M. P. Couperet al. New York, John Wiley and Sons.

Keefe, W. (1972). "Marsh Production: A Summary of the Literature." Contributions in Marine Science

16: 163-181.

Keller, A. A., C. A. Oviatt, et al. (1999). "Predicted Impacts of Elevated Temperature on the Magnitude

of the Winter- Spring Phytoplankton Bloom in Temperate Coastal Waters: A Mescosm Study."

Limnology and Oceanography 44(2): 344-356.

Kelso, J. R. M. and G. S. Milburn (1979). "Entrainment and Impingement of Fish by Power Plants in the

Great Lakes which use the Once-Through Cooling Process." Journal of Great Lakes Research

5(2): 182-194.

Kennish, M. J. (2001). "Coastal Salt Marsh Systems in the U.S.: A Review of Anthropogenic Impacts."

Journal of Coastal Research 17(3): 731-748.

Kirby, C. J. (1972). "The Annual net primary production and decomposition of salt-marsh grass Spartina

alterniflora in Baratuna Bay estuary of LA," Thesis, PhD. Louisiana State University.

Kirby, C. J. and J. G. Gosselink (1976). "Primary Production in a Louisiana Golf Coast Spartina

Alterniflora Marsh." Ecology 57(5): 1052-1059.

Kitchell, J. F. (2007). The ecology of Lake Michigan: past, present, and future. Prepared for Wisconsin

Electric Power Company, Oak Creek Facility.

Kitchell, J. F., R. V. O'Neill, et al. (1979). "Consumer Regulation of Nutrient Cycling." Bioscience 29(1):

28-34.

Kneib, R. T. (2003). "Bioenergetic and landscape considerations for scaling expectations of nekton

production from intertidal marshes." Marine Ecology - Progress Series 264.
March 28, 2011 12-9

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Kotchen, M. J. and S. D. Reiling (2000). "Environmental attitudes, motivations, and contingent valuation

of nonuse values: a case study involving endangered species." Ecological Economics 32(1): 93-

107.

Krinsky, I. and A. L. Robb (1986). "On Approximating the Statistical Properties of Elasticities." Review

of Economics & Statistics 68(4): 715.

Krishnamoorthy, R., H. E. S. Mohmed, et al. (2008). "Temperature effect on behavior, oxygen

consumption, ammonia excretion and tolerance limit of the fish fingerlings Alepes djidaba."

Journal of Environmental Science and Engineering 50: 169-174.

Langford, T. E. L. (1990). Ecological effects of thermal discharges. Barking, Essex, Elsevier Applied

Science Publishers Ltd.

Lee, S. Y. (1990). "Net Aerial Primary Productivity, Litter Production and Decomposition of the Reed

Phragmites-Communis in a Nature-Reserve in Hong-Kong - Management Implications." Marine

Ecology - Progress Series 66: 161-173.

Leffler, C. W. (1972). "Some effects of temperature on the growth and metabolic rate of juvenile blue

crabs, Callinectes sapidus, in the laboratory." Marine Biology 14(2): 104-110.

Liao, J. C. (2007). "A review of fish swimming mechanics and behaviour in altered flows." Philosophical

Transactions of the Royal Society B: Biological Sciences 362: 1973-1993.

Light, P. R. and K. W. Able (2003). "Juvenile atlantic menhaden (Brevoortia tyrannus) in Delaware Bay,

USA are the result of local and long-distance recruitment." Estuarine, Coastal and Shelf Science

57(5-6): 1007-1014.

Limnetics, Inc. (1974). An environmental study of the ecological effects of the thermal discharges from

Point Beach, Oak Creek, and Lakeside Power Plants on Lake Michigan. Study conducted for

Wisconsin Electric Power Company by Limnetics, Inc. Milwaukee, WI.

Lin, B.-h., H. S. Richards, et al. (1988). "An Analysis of the Exvessel Demand for Pacific Halibut."

Marine Resource Economics 4: 305-314.

Loomis, J. and E. Ekstrand (1997). "Economic Benefits of Critical Habitat for the Mexican Spotted Owl:

A Scope Test Using a Multiple-Bounded Contingent Valuation Survey." Journal of Agricultural

and Resource Economics 22(2): 356-366.

Loomis, J., P. Kent, et al. (2000). "Measuring the total economic value of restoring ecosystem services in

an impaired river basin: results from a contingent valuation survey." Ecological Economics 33(1):

103-117.

Lorda, E., D. J. Danila, et al. (2000). "Application of a population dynamics model to the probabilistic

assessment of cooling water intake effects of Millstone Nuclear Power Station (Waterford, CT)

on a nearby winter flounder spawning stock." Environmental Science & Policy 3(Supplement 1):

471-482.

Lupandin, A. I. (2005). "Effect of Flow Turbulence on Swimming Speed of Fish." Biology Bulletin 32(5):

461-466.

MacKenzie, B. R. (2000). "Turbulence, larval fish ecology and fisheries recruitment: a review of field

studies." Oceanologica Acta 23(4): 357-375.

MacKenzie, B. R. and T. Kiorboe (2000). "Larval Fish Feeding and Turbulence: A Case for the

Downside." Limnology and Oceanography 45(1): 1-10.

Mallin, M. A., K. L. Stone, et al. (1994). "Phytoplankton community assessments of seven southeast U.S.

cooling reservoirs." Water Research 28(3): 665-673.

Marrasse, C., E. Lim, et al. (1992). "Seasonal and daily changes in bacterivory in a coastal plankton

community." Marine Ecology - Progress Series 82(3): 281-289.

Marshall, D. E. Odum, H. T. and A. F. Chestnut (1970). Characteristics of a Spartina Marsh Which is

Receiving Treated Municipal Sewage Wastes. In Studies of Marine and Estuanne Ecosystems

Developing with Treated Sewage Wastes, Institute of Marine Science, University of North

Carolina Annual Report 1969-1970. Odum, H. T. and A. F. Chestnut. 317-358.
March 28, 2011 12-10

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Martinez-Arroyo, A., S. Abundes, et al. (2000). "On the Influence of Hot-Water Discharges on

Phytoplankton Communities from a Coastal Zone of the Gulf of Mexico." Water, Air & Soil

Pollution 119(1-4): 209-230.

Mazany, L., N. Roy, et al. (1996). "Multi-product allocation under imperfect raw material supply

conditions: the case of fish products." Applied Economics 28(3): 387-396.

Mazzotta, M. J. (1996). "Measuring Public Values and Priorities for Natural Resources: An Application

to the Peconic Estuary System," Dissertation, PhD. University of Rhode Island.

McKean, A. (2007). "$50 an Ounce: Can Montana’s paddlefish survive the growing international demand

for their eggs?" Montana Outdoors. May–June 2007.

McLusky, D. S. (1981). The estuarine ecosystem. New York, NY, Wiley.

McMahon, R. F. (1975). "Effects of Artificially Elevated Water Temperatures on the Growth,

Reproduction and Life Cycle of a Natural Population of Physa Virgata Gould." Ecology 56(5):

1167-1175.

Meffe, G. K. (1992). "Techno-Arrogance and Halfway Technologies: Salmon Hatcheries on the Pacific

Coast of North America." Conservation Biology 6(3): 350-354.

Meixler, M. S., K. K. Arend, et al. (2005). Fish Community Support in Wetlands within Protected

Embayments of Lake Ontario. Center for the Environment, Cornell University. 0380-1330.

Available at http://www.sciencedirect.com/science/article/B984D-4VT136FF/2/f80b2fb5a0075204ec24390533ec789c.

Mendelssohn, I. and K. Marcellus (1976). "Angiosperm production of three Virginia marshes in various

salinity and soil nutrient regimes." Chesapeake Science 17(1): 15-23.

Meserve, N., National Fisheries Management Plan Coordinator, Atlantic States Marine Fisheries

Commission. (2008). Washington, D.C. August 15, 2008.

Michigan Department of Natural Resources (MDNR) (2002). Data from the 2001 Recreational Angler

Survey. Charlevoix Fisheries Research Station. Received from David Clapp, Charlevoix Great

Lakes Research Station. Charlevoix, MI.

Millstone Environmental Laboratory (2009). Annual Report 2008: Monitoring the Marine Environment

of Long Island Sound at Millstone Power Station, Waterford, Connecticut. Millstone

Environmental Laboratory. Millstone, CT.

Mitchell, R. C. and R. T. Carson (1989). Using Surveys to Value Public Goods: The Contingent

Valuation Method. Washington, D.C., Resources for the Future.

Mitsch, W. J., C. J. Anderson, et al. (2002). Net primary productivity of macrophyte communities after

nine growing seasons in experimental planted and unplanted marshes. Annual Report. Olentangy

River Wetland Research Park.

Moss Landing Marine Laboratories (2006). Ecological Effects of the Moss Landing Power Plant Thermal

Discharge. A report submitted to the Monterey Bay National Marine Sanctuary Integrated

Monitoring Network (SIMoN) and Monterey Bay Sanctuary Foundation.

Mullarkey, D. J. (1997). "Contingent Valuation of Wetlands: Testing Sensitivity to Scope," Dissertation,

University of Wisconsin-Madison.

Mullarkey, D. J. (1999). Sensitivity to Scope: Evidence from a CVM Study of Wetlands. Presented at the

American Agricultural Economics Association Annual Meeting, Nashville, TN, August 8-11,

1999.

Mullineaux, L. S. and E. D. Garland (1993). "Larval Recruitment in Response to Manipulated Field

Flows." Marine Biology 116(4): 667-683.

Murray, L. and R. L. Wetzel (1987). "Oxygen production and consumption associated with the major

autotrophic components in two temperate seagrass communities." Marine Ecology - Progress

Series 38: 231-239.

National Energy Testing Laboratory (NETL) (2009). Impact of Drought on United States Steam Electric

Power Plant Cooling Water Intakes and Related Water Management Issues. DOE/NETL2009/1364. April 2009.
March 28, 2011 12-11

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

National Marine Fisheries Service (NMFS) and U.S. Fish and Wildlife Service (USFWS) (1998a).

Recovery Plan for U.S. Pacific Populations of the East Pacific Green Turtle (Chelonia mydas).

National Marine Fisheries Service. Silver Spring, MD.

National Marine Fisheries Service (NMFS) and U.S. Fish and Wildlife Service (USFWS) (1998b).

Recovery Plan for U.S. Pacific Populations of the Olive Ridley Turtle (Lepidochelys olivacea).

National Marine Fisheries Service. Silver Spring, MD.

National Marine Fisheries Service (NMFS) and U.S. Fish and Wildlife Service (USFWS) (2009).

Recovery Plan for the Northwest Atlantic Population of the Loggerhead Sea Turtle (Caretta

caretta), Second Revision. National Marine Fisheries Service. Silver Spring, MD.

National Marine Fisheries Service (NMFS) of the National Oceanic and Atmospheric Administration

(NOAA) (2001). Endangered Species Act – Section 7 Consultation Biological Opinion, the

NMFS Highly Migratory Species Division Office of Sustainable Fisheries’ proposal to authorize

fisheries under the Fishery Management Plan for Atlantic Tunas, Swordfish, and Sharks (HMS

FMP).

National Marine Fisheries Service (NMFS) of the National Oceanic and Atmospheric Administration

(NOAA) (2002). "Marine Recreational Fisheries Statistics Survey (MRFSS), Snapshot Query."

National Marine Fisheries Service. Available at

http://www.st.nmfs.noaa.gov/st1/recreational/queries/catch/snapshot.html.

National Marine Fisheries Service (NMFS) of the National Oceanic and Atmospheric Administration

(NOAA) (2003). "Marine Recreational Fisheries Statistics Intercept Survey." National Marine

Fisheries Service. Available at http://www.st.nmfs.gov/recreational/the_mrfss.html.

National Marine Fisheries Service (NMFS) of the National Oceanic and Atmospheric Administration

(NOAA) (2004). "Shortnose Sturgeon (Acipenser brevirostrum)." Available at

http://www.nmfs.noaa.gov/prot_res/species/fish/Shortnose_sturgeon.html. Accessed October 14,

2004.

National Marine Fisheries Service (NMFS) of the National Oceanic and Atmospheric Administration

(NOAA) (2009). 2008 Report to Congress: The Status of U.S. Fisheries. Silver Spring, MD. 23.

National Marine Fisheries Service (NMFS) of the National Oceanic and Atmospheric Administration

(NOAA) (2010a). 2009 Report to Congress: The Status of U.S. Fisheries. Office of Sustainable

Fisheries, National Oceanic and Atmospheric Administration (NOAA). Available at

http://www.nmfs.noaa.gov/sfa/statusoffisheries/SOSmain.htm.

National Marine Fisheries Service (NMFS) of the National Oceanic and Atmospheric Administration

(NOAA) (2010b). Fish Stock Sustainability Index: 2009 Quarter 4 Update Through December 31,

2009. U.S. Department of Commerce, NOAA, National Marine Fisheries Service. Silver Spring,

Maryland. 3.

National Marine Fisheries Service (NMFS) of the National Oceanic and Atmospheric Administration

(NOAA) (2010c). NOAA Fisheries Geographic Information Systems, Fisheries Data: Critical

Habitat. Available at http://www.nmfs.noaa.gov/gis/data/critical.htm.

National Marine Fisheries Service (NMFS) of the National Oceanic and Atmospheric Administration

(NOAA) (2010d). "NOAA National Marine Fisheries Service Southwest Regional Office, GIS

Data." Available at http://swr.nmfs.noaa.gov/salmon/layers/finalgis.htm.

National Marine Protected Areas Center (NMPAC) (2006). A classification system for Marine Protected

Areas in the United States. Silver Spring, MD.

National Oceanic and Atmospheric Administration (NOAA) (1997). Scaling Compensatory Restoration

Actions: Guidance Document for Natural Resource Damage Assessment Under the Oil Pollution

Act of 1990. Damage Assessment and Restoration Program, NOAA, Department of Commerce.

December 1997.

National Oceanic and Atmospheric Administration (NOAA) (2006). Habitat Equivalency Analysis: An

Overview. Damage Assessment and Restoration Program, NOAA, Department of Commerce.

March 21, 1995 (Revised October 4, 2000 and May 23, 2006).
March 28, 2011 12-12

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

National Oceanic and Atmospheric Administration (NOAA) (2010a). Environmental Sensitivity Index

(ESI) Maps. Office of Response and Restoration. Available at

http://response.restoration.noaa.gov/topic_subtopic_entry.php?RECORD_KEY(entry_subtopic_t

opic)=entry_id,subtopic_id,topic_id&entry_id(entry_subtopic_topic)=463&subtopic_id(entry_su

btopic_topic)=8&topic_id(entry_subtopic_topic)=1 (in GIS Geodatabase Format).

National Oceanic and Atmospheric Administration (NOAA) (2010b). National Marine Protected Areas

Center: The Marine Protected Areas Inventory. Available at

http://mpa.gov/dataanalysis/mpainventory/.

National Oceanic and Atmospheric Administration (NOAA), New Jersey Department of Environmental

Protection, et al. (2009). Draft Damage Assessment and Restoration Plan and Environmental

Assessment. For the November 26, 2004 M/T Athos I Oil Spill on the Delaware River near the

Citgo Oil Refinery in Paulsboro, New Jersey.

National Research Council (1990). Decline of the Sea Turtles: Causes and Prevention. Washington, D.C.,

National Academies Press.

Natural Resources Defense Council (NRDC) v. Kempthorne. 2007. 506 F. Supp. 2d 322. (E.D. Cal.

2007).

NatureServe (2009). "NatureServe Explorer: An Online Encyclopedia of Life." Available at

http://www.natureserve.org/explorer/.

New York State Department of Environmental Conservation (NYSDEC) (2003a). Fact Sheet: New York

State Pollutant Discharge Elimination System (SPDES) Draft Permit Renewal with Modification,

Indian Point Electric Generating Station. Buchanan, NY. November 2003.

New York State Department of Environmental Conservation (NYSDEC) (2003b). Final Environmental

Impact Statement: Concerning the Applications to Renew NYSPDES Permits for the Roseton 1

& 2 and Indian Point 2 & 3 Steam Electric Generating Stations, Orange, Rockland and

Westchester Counties.

Nixon, S. W. and C. A. Oviatt (1972). "Preliminary Measurements of Midsummer Metabolism in Beds of

Eelgrass, Zostera Marina." Ecology 53(1): 150-153.

Norem, A. D. (2005). "Injury assessment of Sea Turtles utilizing the neritic zone of the Southeastern

United States," Thesis, Master of Science. University of Florida.

Northeast Fisheries Science Center (NEFSC) of the NOAA National Marine Fisheries Service (2008).

Assessment of 19 Northeast Groundfish Stocks through 2007: Report of the 3rd Groundfish

Assessment Review Meeting (GARM III), Northeast Fisheries Science Center, Woods Hole,

Massachusetts, August 4-8, 2008. U.S. Department of Commerce, NOAA Fisheries. Northeast

Fisheries Science Center Reference Document 08-15. 884.

Northeast Fisheries Science Center (NEFSC) of the NOAA National Marine Fisheries Service (2010).

"Northeast Fisheries Science Center Publications." Available at

http://www.nefsc.noaa.gov/publications/.

Northeast Fisheries Science Center (NEFSC) of the NOAA National Marine Fisheries Service, L.

Hendrickson, et al. (2006). "Status of Fishery Resources off the Northeastern US." Available at

http://www.nefsc.noaa.gov/sos/spsyn/fldrs/winter/.

Northeast Midwest Institute (2010). "Upper Mississippi River Basin." Available at

http://www.nemw.org/index.php/policy-areas/water-and-watersheds/upper-mississippi-riverbasin. Accessed March 7, 2010.

Nuclear Regulatory Commission (NRC) (2010). Notice: Nextera Energy Point Beach, LLC; Point Beach

Nuclear Plant, Units 1 and 2, Draft Environmental Assessment and Draft Finding of No

Significant Impact Related to the Proposed License Amendment To Increase the Maximum

Reactor Power. December 10, 2010. 75 Federal Register 237: 77010-77017.

Odum, E. P. and M. E. Fanning (1972). "Comparison of the productivity of Spartina alterniflora and

Spartina cynosuroides in Georgia coastal marshes." Bulletin of the Georgia Academy of Science

31: 1-12.
March 28, 2011 12-13

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Ohio Environmental Protection Agency (OEPA) (2010). Fact Sheet: National Pollution Discharge

Elimination System (DPDES) Permitting Program. Bayshore Station. Oregon, OH. March 2010.

Opaluch, J. J., T. Grigalunas, et al. (1995). "Environmental Economics in Estuary Management: The

Peconic Estuary Program." Maritimes 38(3): 21-23.

Opaluch, J. J., T. Grigalunas, et al. (1998). Resource and Recreational Economic Values for the Peconic

Estuary. Report prepared for Peconic Estuary Program, Suffolk County Department of Health

Services, Riverhead, NY, by Economic Analysis, Inc., Peace Dale, RI.

Ovaskainen, O. and S. J. Cornell (2006). "Space and Stochasticity in population dynamics." Proceedings

of the National Academy of Sciences of the United States of America 103: 12781-12786.

Pacific Islands Fisheries Science Center (PIFSC) of the NOAA National Marine Fisheries Service

(2010a). "Fishery Biology and Stock Assessment Division." Available at

http://www.pifsc.noaa.gov/fbsad/index.php.

Pacific Islands Fisheries Science Center (PIFSC) of the NOAA National Marine Fisheries Service

(2010b). Pacific Islands Fisheries Science Center Staff Publications Database. Available at

http://www.pifsc.noaa.gov/library/publication_search.php.

Paine, R. T. (1966). "Food web complexity and species diversity." American Naturalist 100: 65-75.

Paine, R. T. (1969). "A Note on Trophic Complexity and Community Stability." The American Naturalist

103(929): 91-93.

Palmer, M. A., C. A. Reidy Liermann, et al. (2008). "Climate change and the world's river basins:

anticipating management options." Frontiers in Ecology and the Environment 6(2): 81-89.

Pate, J. and J. Loomis (1997). "The effect of distance on willingness to pay values: a case study of

wetlands and salmon in California." Ecological Economics 20(3): 199-207.

Pauly, D. and V. Christensen (1995). "Primary Production Required to Sustain Global Fisheries." Nature

374(6519): 255-257.

Penko, J. M. and D. C. Pratt (1986). "Growth and Mortality of Shoots in Three Populations of Typha

glauca Godr." Journal of the Minnesota Academy of Science 52(3): 25-28.

Penn, T. and T. Tomasi (2002). "Calculating resource restoration for an oil discharge in Lake Barre,

Louisiana, USA." Environmental Management 29(5): 691-702.

Peterson, C. H. and J. Lubchenco (1997). Marine Ecosystem Services. In Nature’s Services, Societal

Dependence on Natural Ecosystems. Daily, G. C. Washington, D.C., Island Press: 177-194.

Plotkin, P. T., (Ed) (1995). National Marine Fisheries Service and U. S. Fish and Wildlife Service Status

Reviews for Sea Turtles Listed under the Endangered Species Act of 1973. National Marine

Fisheries Service. Silver Spring, MD.

Pohl, O. (2002). New jellyfish problem means jellyfish are not the only problem. New York Times. May

21, 2002.

Polgar, T. T., J. K. Summers, et al. (1979). Evaluation of the effects of the Morgantown SES cooling

system on spawning and nursery areas of representative important species. Final report. PB-80-

111743. 149.

Poornima, E. H., M. Rajadurai, et al. (2005). "Impact of thermal discharge from a tropical coastal power

plant on phytoplankton." Journal of Thermal Biology 30(4): 307-316.

Postel, S. and S. Carpenter (1997). Freshwater Ecosystem Services. In Nature’s Services, Societal

Dependence on Natural Ecosystems. Daily, G. C. Washington, DC, Island Press: 195-214.

PSEG (2006). Salem Generating Station NJPDES Permit No. NJ 0005622 Application for Renewal.

Quinn, T. J. and R. B. Deriso (1999). Quantitative Fish Dynamics. New York, Oxford University Press.

560.

Rago, P. J. (1984). "Production forgone: An alternative method for assessing the consequences of fish

entrainment and impingement losses at power plants and other water intakes." Ecological

Modelling 24(1-2): 79-111.

Rapport, D. J. and W. G. Whitford (1999). "How Ecosystems Respond to Stress." BioScience 49(3): 193-

203.
March 28, 2011 12-14

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Rassweiler, A., K. K. Arkema, et al. (2008). "Net Primary Production, Growth, and Standing Crop of

Macrocystis Pyrifera in Southern California." Ecology 89(7): 2068-2068.

Reimold, R. J. and R. A. Linthurst (1977). Primary Productivity of Minor Marsh Plants in Delaware,

Georgia, and Maine. US Army Corps of Engineers, Waterways Experiment Station. Vicksburg,

MS. Technical Report D-77-36. 104.

Reznick, D. and J. A. Endler (1982). "The Impact of Predation on Life History Evolution in Trinidadian

Guppies (Poecilia reticulata)." Evolution 36(1): 160-177.

Richardson, L. and J. Loomis (2009). "The total economic value of threatened, endangered and rare

species: An updated meta-analysis." Ecological Economics 68(5): 1535-1548.

Ricker, W. E. (1975). Computation and interpretation of biological statistics of fish populations. Fisheries

Research Board of Canada, Bulletin 191.

Ricklefs, R. E. (2001). The Economy of Nature. New York, W.H. Freeman and Company.

Rizzo, W. and R. Wetzel (1985). "Intertidal and shoal benthic community metabolism in a temperate

estuary: Studies of spatial and temporal scales of variability." Estuaries and Coasts 8(4): 342-351.

Roberts, L. A. and J. A. Leitch (1997). Economic Valuation of Some Wetland Outputs of Mud Lake,

Minnesota-South Dakota. North Dakota State University, Department of Agricultural Economics,

North Dakota Agricultural Experiment Station. Agricultural Economics Report No. 381.

Rocha, A. V. and M. L. Goulden (2009). "Why is marsh productivity so high? New insights from eddy

covariance and biomass measurements in a Typha marsh." Agricultural and Forest Meteorology

149(1): 159-168.

Roman, C. T. and F. C. Daiber (1989). "Organic-Carbon Flux through a Delaware Bay Salt-Marsh - Tidal

Exchange, Particle-Size Distribution, and Storms." Marine Ecology - Progress Series 54: 149-

156.

Rosenberger, R. and T. Phipps (2007). Correspondence and Convergence in Benefit Transfer Accuracy:

Meta-Analytic Review of the Literature. In Environmental Value Transfer: Issues and Methods.

Navrud, S. and R. Ready, Springer Netherlands. 9: 23-43.

Rowe, R. D., W. D. Shaw, et al. (1992). Nestucca Oil Spill. In Natural Resource Damages. Ward, K. and

J. Duffield. New York, Wiley and Sons: 527-554.

Ruhl, J. B. and R. J. Gregg (2001). "Integrating Ecosystem Services into Environmental Law: A Case

Study of Wetlands Mitigation Banking." Stanford Environmental Law Journal 20(2): 365-392.

Ruiz, G. M., P. Fofonoff, et al. (1999). "Non-Indigenous Species as Stressors in Estuarine and Marine

Communities: Assessing Invasion Impacts and Interactions." Limnology and Oceanography

44(3): 950-972.

Ruiz, G. M., P. W. Fofonoff, et al. (2000). "Invasion of Coastal Marine Communities in North America:

Apparent Patterns, Processes, and Biases." Annual Review of Ecology & Systematics 31: 481-

531.

Salzman, J., B. H. Thompson Jr., et al. (2001). "Protecting Ecosystem Services: Science, Economics, and

Law." Stanford Environmental Law Journal 20(2): 309-332.

Sanford, E. B., D. Bertness, et al. (1994). "Flow, food supply and acorn barnacle population dynamics."

Marine Ecology - Progress Series 104: 49-62.

Schiel, D. R., J. R. Steinbeck, et al. (2004). "Ten Years of Induced Ocean Warming Causes

Comprehensive Changes in Marine Benthic Communities." Ecology 85(7): 1833-1839.

Schkade, D. A. and J. W. Payne (1994). "How People Respond to Contingent Valuation Questions: A

Verbal Protocol Analysis of Willingness to Pay for an Environmental Regulation." Journal of

Environmental Economics and Management 26(1): 88-109.

Schlesinger, W. H. (1997). Biogeochemistry: an analysis of global change. San Diego, CA, Academic

Press.

Schulze, W. D., R. D. Rowe, et al. (1995). Contingent Valuation of Natural Resource Damages due to

Injuries to the Upper Clark Fork River Basin State of Montana Natural Resource Damage

Litigation Program, prepared by RCG/Hagler Bailly. Boulder, CO.
March 28, 2011 12-15

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Shea, K. and P. Chesson (2002). "Community ecology theory as a framework for biological invasions."

Trends in Ecology & Evolution 17(4): 170-176.

Shrestha, R., R. Rosenberger, et al. (2007). Benefit Transfer Using Meta-Analysis in Recreation

Economic Valuation, in Benefit Transfer Accuracy: Meta-Analytic Review of the Literature. In

Environmental Value Transfer: Issues and Methods. Navrud, S. and R. Ready. Dordrecht, The

Netherlands, Kluwer Academic Publishers: 161-177.

Smith, L. M. and J. A. Kadlec (1985). "Fire and Herbivory in a Great Salt Lake Marsh." Ecology 66(1):

259-265.

Smith, V. K., G. Van Houtven, et al. (2002). "Benefit Transfer via Preference Calibration: 'Prudential

Algebra' for Policy." Land Economics 78(1): 132.

Smythe, A. G. and P. M. Sawyko (2000). "Field and laboratory evaluations of the effects of 'cold shock'

on fish resident in and around a thermal discharge: an overview." Environmental Science &

Policy 3(Supplement 1): 225-232.

Southeast Fisheries Science Center (SEFC) of the NOAA National Marine Fisheries Service (2010).

SouthEast Data, Assessment and Review (SEDAR). Available at

http://www.sefsc.noaa.gov/sedar/.

Southwest Fisheries Science Center (SWFSC) of the NOAA National Marine Fisheries Service (2010).

"Southwest Fisheries Science Center Fisheries Ecology Publications Database." Available at

http://swfsc.noaa.gov//publications/fedbin/qrypublications.asp?ParentMenuId=54.

Speer, L., L. Lauck, et al. (2000). Roe to Ruin: The Decline of Sturgeon in the Caspian Sea and the Road

to Recovery. Available at http://www.caviaremptor.org/roe_to_ruin.PDF.

Squires, D., S. Freese, et al. (1998). Cost-Benefit Analysis of Pacific Whiting Allocation. National

Marine Fisheries Service, Southwest Fisheries Science Center. Administrative Report LJ-97-05.

Squires, L. E., S. R. Rushforth, et al. (1979). "Algal response to a thermal effluent: study of a power

station on the Provo River, Utah, USA." Hydrobiologia 63(1): 17-32.

Stachowicz, J. J. and J. E. Byrnes (2006). "Species Diversity, invasion success, and ecosystem

functioning: disentangling the influence of resource competition, facilitation, and extrinsic

factors." Marine Ecology - Progress Series 311: 251-262.

Steever, E. Z. (1972). "Productivity and vegetations studies of tidal saltmarsh in Stonington Connecticut:

Cottrell marsh," Thesis, Masters of Science. Connecticut College.

Steeves, P. and D. Nebert (1994). 1:250,000-scale Hydrologic Units of the United States. U.S. Geological

Survey, Reston, VA. Vector Digital Data file. Available at

http://water.usgs.gov/GIS/metadata/usgswrd/XML/huc250k.xml.

Stephenson, T. D. (1990). "Fish Reproductive Utilization of Coastal Marshes of Lake Ontario Near

Toronto." Journal of Great Lakes Research 16(1): 71-81.

Stevens, T. H., J. Echeverria, et al. (1991). "Measuring the Existence Value of Wildlife: What Do CVM

Estimates Really Show?" Land Economics 67(4): 390-400.

Stockwell, C. A., A. P. Hendry, et al. (2003). "Contemporary evolution meets conservation biology."

Trends in Ecology & Evolution 18(2): 94-101.

Strange, E., H. Galbraith, et al. (2002). "Determining Ecological Equivalence in Service-to-Service

Scaling of Salt Marsh Restoration." Environmental Management 29(2): 290-300.

Strange, E. M. (2008). Restoration to Offset Environmental Impacts of Coastal Power Plants. Prepared for

the California Energy Commission, Agreement #500-04-025.

Street, M. W., A. S. Deaton, et al. (2005). "Wetlands." In North Carolina Coastal Habitat Protection Plan.

North Carolina Department of Environment and Natural Resources, Division of Marine Fisheries.

Morehead City, NC. Available at http://www.ncfisheries.net/habitat/chppdocs/F_Wetlands.pdf.

656.

Stroud, L. M. and A. W. Cooper (1968). Color-infrared Aerial Photographic Interpretation and Net

Primary Production of a Regularly-flooded North Carolina Salt marsh. University of North

Carolina Water Resources Research Institute. Report 14. 86.
March 28, 2011 12-16

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Sullivan, K., D. J. Martin, et al. (2000). An analysis of the effects of temperature on salmonids of the

Pacific Northwest with implications for selecting temperature criteria. Sustainable Ecosystems

Institute. Portland, OR.

Sumer, B. M., A. Kozakiewicz, et al. (1996). "Velocity and Concentration Profiles in Sheet-Flow Layer

of Movable Bed." Journal of Hydraulic Engineering 122(10): 549-558.

Summers, J. K. (1989). "Simulating the indirect effects of power plant entrainment losses on an estuarine

ecosystem." Ecological Modelling 49(1-2): 31-47.

Sun, J. F. (1995). Understanding the US Demand for Shrimp Imports and Welfare Distributions.

International Cooperation for Fisheries and Aquaculture Development: Proceedings of the 7th

Biennial Conference of the International Institute of Fisheries Economics and Trade, 3.

Swain, D. P., A. F. Sinclair, et al. (2007). "Evolutionary response to size-selective mortality in an

exploited fish population." Proceedings of the Royal Society B: Biological Sciences 274(1613):

1015-1022.

Taylor, C. J. L. (2006). "The effects of biological fouling control at coastal and estuarine power stations."

Marine Pollution Bulletin 53(1-4): 30-48.

Taylor, D. I. and B. R. Allanson (1995). "Organic-Carbon Fluxes between a High Marsh and Estuary, and

the Inapplicability of the Outwelling Hypothesis." Marine Ecology - Progress Series 120: 263-

270.

Teal, J. M. (1962). "Energy Flow in the Salt Marsh Ecosystem of Georgia." Ecology 43(4): 614-624.

Teal, J. M. and M. P. Weinstein (2002). "Ecological engineering, design, and construction considerations

for marsh restorations in Delaware Bay, USA." Ecological Engineering 18(5): 607-618.

Teixeira, T. P., L. M. Neves, et al. (2009). "Effects of a nuclear power plant thermal discharge on habitat

complexity and fish community structure in Ilha Grande Bay, Brazil." Marine Environmental

Research 68(4): 188-195.

Terceiro, M. Northeast Fisheries Science Center (2008). Southern New England/Mid-Atlantic winter

flounder. In Assessment of 19 Northeast Groundfish Stock through 2007: Report of the 3rd

Groundfish Assessment Review Meeting (GARM III). Northeast Fisheries Science Center.

Northeast Fisheries Science Center, U.S. Department of Commerce. Woods Hole, MA. Reference

Document 08-15. 2.457-452.528.

Thom, R. M. (1988). Benthic Primary Production in the Eelgrass Meadow at the Padilla Bay National

Estuarine Research Reserve, Washington. NOAA Technical Report Series OCRM/MEMD FRIUW-8808. February 1988.

Thomson, C., Economist, National Marine Fisheries Service, Southwest Fisheries Science Center (2008).

Santa Cruz, CA. August 12 and 18, 2008.

Thunberg, E., Natural Resource Management Economist, U.S. National Marine Fisheries Service, Social

Science Branch. (2008). Woods Hole, MA. August 8 and 22, 2008.

Thunberg, E. and E. Squires, Economists, U.S. National Fisheries Service, Social Science Branch (2005).

Woods Hole, MA. February 18, 2005.

Tomasko, D., C. Dawes, et al. (1996). "The effects of anthropogenic nutrient enrichment on turtle grass

(Thalassia testudinum) in Sarasota Bay, Florida." Estuaries and Coasts 19(2): 448-456.

Tondreau, R., J. Hey, et al. (1982). Missouri River Aquatic Ecology Studies: Ten Year Summary (1972-

1982). Prepared for Iowa Public Service Company. Sioux City, IA.

Tsoa, E., W. E. Schrank, et al. (1982). "U.S. Demand for Selected Groundfish Products, 1967-80."

American Journal of Agricultural Economics 64(3): 483-489.

Turner, S. J., S. F. Thrush, et al. (1999). "Fishing impacts and the degradation or loss of habitat structure."

Fisheries Management & Ecology 6(5): 401-420.

Turtle Expert Working Group (TEWG) (2000). Assessment Update for the Kemp’s Ridley and

Loggerhead Sea Turtle Populations in the Western North Atlantic. U.S. Department of

Commerce. NOAA Technical Memorandum NMFS-SEFSC-444. 115.

U.S. Bureau of Labor Statistics (USBLS) (2010). "Consumer Price Index." Available at

http://www.bls.gov/cpi/data.htm. Accessed October 3, 2010.
March 28, 2011 12-17

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

U.S. Census Bureau (2000). "American Factfinder." Available at http://factfinder.census.gov.

U.S. Department of the Interior (USDOI) (2008). "Fisheries: Aquatic and Endangered Resources." Great

Lakes Science Center, U.S. Geologoical Survey, U.S. Department of the Interior. Available at

http://www.glsc.usgs.gov/main.php?content=research_risk&title=Species%20at%20Risk0&menu

=research. Accessed June 23, 2004.

U.S. Department of the Interior Fish and Wildlife Service (USFWS), U.S. Department of Commerce

(USDOC) Economics and Statistics Administration, et al. (2002). 2001 National Survey of

Fishing, Hunting, and Wildlife-Associated Recreation. Available at

http://fa.r9.fws.gov/surveys/surveys.html#survey_reports.

U.S. Environmental Protection Agency (USEPA) (1977). Interagency 316(a) Technical Guidance Manual

and Guide for Thermal Effects Sections of Nuclear Facilities’ Environmental Impact Statements.

Office of Water, Enforcement Permits Division, Industrial Permits Branch. Washington, D.C.

U.S. Environmental Protection Agency (USEPA) (1980). Field Guide to Evaluate Net Primary Production

of Wetlands. Environmental Research Laboratory. Corvallis, OR. EPA-600/8-80-037.

U.S. Environmental Protection Agency (USEPA) (2000a). Guidelines for Preparing Economic Analyses.

EPA 240-R-00-003. September.

U.S. Environmental Protection Agency (USEPA) (2000b). Section 316(b) Industry Survey. Detailed

Industry Questionnaire: Phase II Cooling Water Intake Structures and Industry Short Technical

Questionnaire: Phase II Cooling Water Intake Structures, January 2000 (OMB Control Number

2040-0213). Industry Screener Questionnaire: Phase I Cooling Water Intake Structures, January,

1999 (OMB Control Number 2040-0203).

U.S. Environmental Protection Agency (USEPA) (2002a). Case Study Analysis for the Proposed Section

316(b) Phase II Existing Facilities Rule. Office of Water. EPA-821-R-02-002. February 2002.

Available at http://www.epa.gov/waterscience/316b/phase2/casestudy/.

U.S. Environmental Protection Agency (USEPA) (2002b). Clean Water Act NPDES Permitting

Determination for Thermal Discharge and Cooling Water Intake from Brayton Point Station in

Somerset, MA. United States Environmental Protection Agency Region 1: New England. NPDES

Permit No. MA0003654.

U.S. Environmental Protection Agency (USEPA) (2004a). National Pollutant Discharge Elimination

System - Final Regulations to Establish Requirements for Cooling Water Intake Structures at

Phase II Existing Facilities. 40 CFR Parts 9, 122, 123, 124, and 125.

U.S. Environmental Protection Agency (USEPA) (2004b). Regional Analysis Document for the Final

Section 316(b) Phase II Existing Facilities Rule. Office of Science and Technology, Engineering

and Analysis Division. EPA-821-R-02-003. February 12. Available at

http://www.epa.gov/waterscience/316b/phase2/casestudy/final.htm. Accessed October 2008.

U.S. Environmental Protection Agency (USEPA) (2004c). Technical Development Document for the

Proposed Section 316(b) Rule for Phase III Facilities. Office of Water. EPA-821-R-04-015.

November 1.

U.S. Environmental Protection Agency (USEPA) (2006a). National Pollutant Discharge Elimination

System - Final Regulations to Establish Requirements for Cooling Water Intake Structures and

Phase III Facilities. 40 CFR Parts 9, 122, 123, 124, and 125.

U.S. Environmental Protection Agency (USEPA) (2006b). Regional Benefits Analysis of the Final

Section 316(b) Phase III Existing Facilities Rule. Office of Water. EPA-821-R-04-007. Available

at http://www.epa.gov/waterscience/316b/phase3/index.html#finalrba. Accessed October 2008.

U.S. Environmental Protection Agency (USEPA) (2008). "Sustainable Financing Strategies." National

Estuary Program. Available at http://water.epa.gov/type/oceb/nep/fund.cfm. Accessed September

30, 2008.

U.S. Environmental Protection Agency (USEPA) (2009a). National Fish Advisory Listings 2008:

Technical Fact Sheet. EPA-823-F-09-007. September 2009.
March 28, 2011 12-18

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

U.S. Environmental Protection Agency (USEPA) (2009b). Valuing the Protection of Ecological Systems

and Services: A Report of the EPA Science Advisory Board. Office of the Administrator, Science

Advisory Board. EPA-SAB-09-012.

U.S. Environmental Protection Agency (USEPA) (2010a). National Estuary Program Booklet.

U.S. Environmental Protection Agency (USEPA) (2010b). "Office of Wetlands website." Available at

http://www.epa.gov/wetlands/awm.

U.S. Fish and Wildlife Service (USFWS) (2009). Federal and State Endangered and Threatened Species

Expenditures: Fiscal Year 2008. US Fish and Wildlife Service Endangered Species Program.

252.

U.S. Fish and Wildlife Service (USFWS) (2010a). "Critical Habitat Portal." Available at

http://crithab.fws.gov/.

U.S. Fish and Wildlife Service (USFWS) (2010b). "Environmental Conservation Online System."

Available at http://ecos.fws.gov/tess_public/.

U.S. Fish and Wildlife Service (USFWS) (2010c). "North Florida Ecological Services Office: Loggerhead

Sea Turtle (Caretta caretta)." Available at

http://www.fws.gov/northflorida/seaturtles/turtle%20factsheets/loggerhead-sea-turtle.htm.

U.S. Fish and Wildlife Service (USFWS) (2010d). Sport Fish Restoration Program Final Apportionments

(1952-2010). United States Fish and Wildlife Service, Wildlife and Sport Fish Restoration

Program. Arlington, VA. 12.

U.S. Fish and Wildlife Service (USFWS) (2011). "Native Species Conservation." U.S. FWS, Great Lakes

- Big Rivers. Available at http://www.fws.gov/midwest/Fisheries/topic-nativespecies.htm.

Accessed March 7, 2011.

U.S. Geological Survey (USGS) (1990). Water Fact Sheet: Largest Rivers in the United States. U.S.

Geological Survey, U.S. Department of the Interior. Reston, VA. Open-File Report 87-242.

U.S. Office of Management and Budget (USOMB) (2003). Circular A-4, September 17. Available at

http://www.whitehouse.gov/OMB/circulars/a004/a-4.pdf.

U.S. Office of Management and Budget (USOMB) (2010a). Appendix of the Budget of the United States

Government, Fiscal Year 2011. Office of Management and Budget, United States Government

Printing Office. Washington, D.C. 1413 pp.

U.S. Office of Management and Budget (USOMB) (2010b). Budget of the United States Government,

Fiscal Year 2011. Office of Management and Budget, United States Government Printing Office.

Washington, D.C. 184 pp.

Upper Mississippi River Basin Association (2004). "River and Basin Facts." Available at

http://www.umrba.org/facts.htm. Accessed June 23, 2004.

Valiela, I., J. M. Teal, et al. (1975). "Production and Dynamics of Salt Marsh Vegetation and the Effects

of Experimental Treatment with Sewage Sludge. Biomass, Production and Speies Composition."

Journal of Applied Ecology 12(3): 973-981.

van der Valk, A. G. and C. B. Davis (1978). Primary Production of Prairie Glacial Marshes. In

Freshwater Wetlands, Ecological Processes and Management Potential. Good, R. E., D. F.

Whigham and R. L. Simpson. New York, Academic Press.

Vandenberg, T. P., G. L. Poe, et al. (2001). Accessing the Accuracy of Benefits Transfer: Evidence from

a Multi-Site Contingent Valuation Study of Groundwater Quality. In The Economic Value of

Water Quality. Bergstrom, J. C., K. J. Boyle and G. L. Poe. Cheltenham, UK, Edward Elgar: 101-

120.

Vanni, M. J., C. D. Layne, et al. (1997). ""Top-down" trophic interactions in lakes: effects of fish on

nutrient dynamics." Ecology 78(1): 1-20.

Wainger, L. A., D. King, et al. (2001). "Wetland Value Indicators for Scoring Mitigation Trades."

Stanford Environmental Law Journal 20(2): 413-478.

Walker, P. M. B. (1995). The Woodsworth Dictionary of Biology. Edinburgh, W&R Chambers Ltd.

Walsh, M. R., S. B. Munch, et al. (2006). "Maladaptive changes in multiple traits caused by fishing:

impediments to population recovery." Ecology Letters 9: 142-148.
March 28, 2011 12-19

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Walsh, R. G., J. B. Loomis, et al. (1984). "Valuing Option, Existence, and Bequest Demands for

Wilderness." Land Economics 60(1): 14-29.

Walton, T. E. (1972). "Primary Productivity, Succession and Management of a New Jersey Coastal

Marsh," Thesis, Master of Regional Planning. University of Pennsylvania.

Wang, Z. A. and W. J. Cai (2004). "Carbon Dioxide Degassing and Inorganic Carbon Export from a

Marsh-Dominated Estuary (The Duplin River): A Marsh CO2 Pump." Limnology and

Oceanography 49(2): 341-354.

Water Quality Act (1987). (P.L. 100-4), §317(a)(1)(A) and (B) adding §320 to the CWA, 33, US.C.

§1330. 33 U.S.C. 1326(b), 33 USC 1268, Sec. 118(a)(3)(b).

Whigham, D. F. and R. L. Simpson (1975). Ecological studies of the Hamilton Marshes, Progress Report

for the period June 1974 - January 1975. Biology Department, Rider College. Lawrenceville, NJ.

185.

White House Council on Environmental Quality (CEQ), U.S. Department of Agriculture, et al. (2010).

Great Lakes Restoration Initiative Action Plan: FY2010-FY2014. February 21.

Whitehead, J. C. (1993). "Total Economic Values for Coastal and Marine Wildlife: Specification,

Validity, and Valuation Issues." Marine Resource Economics 8(2): 119-132.

Whitehead, J. C. and G. C. Blomquist (1991). "Measuring Contingent Values for Wetlands: Effects of

Information About Related Environmental Goods." Water Resources Research 27(10): 2523-

2531.

Williams, T. M., T. G. Wolaver, et al. (1992). "The Bly Creek ecosystem study -- organic carbon

transport within a euhaline salt marsh basin, North Inlet, South Carolina." Journal of

Experimental Marine Biology and Ecology 163(1): 125-139.

Wilson, M. A. and S. R. Carpenter (1999). "Economic Valuation of Freshwater Ecosystem Services in the

United States: 1971–1997." Ecological Applications 9(3): 772-783.

Wilson, R. W., F. J. Millero, et al. (2009). "Contribution of Fish to the Marine Inorganic Carbon Cycle."

Science 323(5912): 359-362.

Wisconsin Department of Natural Resources (Wisconsin DNR) (2003). "Adrift on the sea of life."

Wisconsin Natural Resources June: 17-21.

Wisconsin Power & Light Company (WPLC) v. Federal Energy Regulatory Commission (FERC). 2004.

363 F.3d 453. (DC Circ. 2004).

Woodward, R. T. and Y.-S. Wui (2001). "The economic value of wetland services: a meta-analysis."

Ecological Economics 37(2): 257-270.

Woodwell, G. M., D. E. Whitney, et al. (1977). "The Flax Pond Ecosystem Study: Exchanges of Carbon

in Water Between a Salt Marsh and Long Island Sound." Limnology and Oceanography 22(5):

833-838.
March 28, 2011 A-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Appendix A: Extrapolation Methods

A.1 Introduction

Survey sample weights for manufacturing facilities and electric power generating facilities were used in

the analysis of 316(b) Phase II and Phase III regulations (USEPA 2004b; USEPA 2006b). To account for

differences between electric power facilities that received the DQ and those that received the Short

Technical Questionnaire (STQ), and to account for 316(b) study regions, new weights were developed.

These weights are referred to as new benefits weights. This appendix explains the development of these

facility-level weights and their use in the benefits analysis for the proposed 316(b) regulation.

A.2 Manufacturing Facilities

The current analysis of manufacturing facilities incorporates a set of technical weights developed for the

2006 Final Phase III Rule. These technical weights are based on engineering information obtained from

the 316(b) Manufacturers Questionnaire, including an estimate of the number of affected facilities and the

cost of installing new technology. However, because technical weights do not account for facility location

or intake flow, they cannot be used to directly estimate intake flow at a regional level, a key parameter for

the benefits analysis. This section presents new benefits weights developed by EPA for in-scope

manufacturing facilities.

New benefits weights were developed by adjusting technical weights for traditional manufacturers (MN

facilities)48 and non-utility manufacturers (MU facilities) such that estimates of regional mean operational

flow are consistent with EPA’s best estimates for manufacturing facilities. EPA chose this characteristic

because operational intake flow is the most important factor in the benefits analysis: I&E mortality losses

as a function of mean operational intake flow. EPA included eight regions when developing weights for

MN and MU facilities: North Atlantic, Mid-Atlantic, South Atlantic, Gulf of Mexico, California, Pacific

Northwest,49 Great Lakes, and Inland regions.50

Information on total regional flow was not available for MN and MU facilities. Thus, EPA used the

number of facilities present in any single region as a control variable. This presumes that the flow

characteristics of these represented facilities are the same as the DQ facilities. 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 study region and industry category so that the regional

distribution of in-scope MN facilities corresponds to the actual geographic distribution of all MN facilities

48 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.

49 The Pacific Northwest region is ultimately excluded from the benefits analysis because it includes a single DQ facility which is

projected to close as baseline.

50 See Chapter 1 for additional information regarding regional definitions.
March 28, 2011 A-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

in a given industry.51 Under this approach, EPA first determined the distribution of in-scope facilities by

study region, and then calculated adjusted benefits weights based on this distribution.

Determining the Distribution of In-scope Facilities by Study Region

EPA obtained latitude-longitude coordinates (lat-long) for all facilities in relevant Standard Industrial

Classification (SIC) codes52 that have NPDES permits within PCS (Permit Compliance System) and

ICIS-NPDES (Integrated Compliance Information System- NPDES). Facilities within relevant SIC codes

were assigned to a study region using lat-long. A map of RF1 reaches53 was also used to indicate whether

the facility location is coastal/estuarine or inland. 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 in the sample frame for the screener is

not available. Therefore, EPA used two simplifying assumptions to develop weight adjustment factors:

(1) the universe of in-scope facilities in any single industry equals the sum of DQ facilities weights and

(2) the geographic distribution of NPDES permitted facilities in the relevant SIC codes is representative

of the geographic distribution of in-scope facilities.

For each industry, EPA assumed that the geographic distribution of facilities included in the EPA

PCS/ICIS database was equivalent to the geographic distribution of the DQ frame. To meet this

assumption, EPA redistributed the weights of in-scope 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 in-scope MN facilities based on PCS/ICIS data.54

Calculating Adjusted Weights for Benefits Analysis

EPA first compared the regional distribution of weighted of in-scope 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 DQ

facilities for all regions. The number of DQ facilities in each region was re-estimated 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 in-scope facilities existed 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, it was assigned a weight of one so that its actual flow would be fully counted. The cost analysis

51Weights were not adjusted for petroleum refineries because survey screeners were sent to the entire universe and DQs were sent

to all in-scope facilities. Weights for facilities determined to be in other industries after receipt of the DQ were given

weights of 1, which were not adjusted.

52The SIC code describes the primary activity of the facility.

53EPA’s reach file (RF1) is a database of interconnected steam segments of “reaches” that comprise the surface water drainage

system for the United States.

54EPA 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 records intake flow.
March 28, 2011 A-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

estimates 32 facilities to close under baseline conditions. Accordingly, EPA excluded the baseline

closures and their weights from the benefits analysis and weights readjustment.

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 many sectors, estimated flow is slightly smaller

due to the lack of DQ facilities combinations of region and industry. Conversely, weight-adjusted flow in

the chemical sector increases slightly due to good coverage of DQ facilities which shifted weights to

facilities with above-average flow.
March 28, 2011 A-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table A-1: MN DQ Distribution and Calculation of Weight Adjustment Factors

Distribution of

Facilities in

PCS/ICIS

Databases

Number of

Regional Mean

Operational Flow

(MGD) Benefits Region

Number %

DQweighted

Facilities1

Adjustment

Factor

Adjusted

Weight

Estimates

DQweighted

Adjusted

Weight

Estimates

Aluminum

North Atlantic 7 6% No DQs20 No DQs 0.0

Mid-Atlantic 11 9% No DQs20 No DQs 0.0

South Atlantic 1 1% No DQs 0 No DQs 0.0

Great Lakes 2 2% 3 0.09 1 30.3 9.7

Gulf of Mexico 1 1% No DQs 0 No DQs 0.0

Pacific Northwest 0 0% No DQs 0 No DQs 0.0

California 0 0% No DQs 0 No DQs 0.0

Inland 95 81% 13 1.01 13 87.0 88.3

Total 117 100% 16 14 117.3 98.0

Chemical

North Atlantic 16 1% No DQs 0 No DQs 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 4 331.0 77.1

Gulf of Mexico 100 8% 4 2.85 12 283.9 809.8

Pacific Northwest 4 0% No DQs 0 No DQs 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% 146 144 2,484.3 2,823.1

Paper

North Atlantic 2 1% No DQs 0 No DQs 0.0

Mid-Atlantic 7 2% No DQs 0 No DQs 0.0

South Atlantic 8 2% No DQs 0 No DQs 0.0

Great Lakes 19 5% 3 1.684 5 6.7 11.2

Gulf of Mexico 2 1% No DQs 0 No DQs 0.0

Pacific Northwest 3 1% No DQs 0 No DQs 0.0

California30 0% 3 1.00 3 32.2 32.2

Inland 354 90% 91 0.95 86 1,242.9 1,181.4

Total 395 100% 96 94 1,281.8 1,224.8

Steel

North Atlantic 3 1% No DQs 0 No DQs 0.0

Mid-Atlantic 5 2% No DQs 0 No DQs 0.0

South Atlantic 1 0% No DQs 0 No DQs 0.0

Great Lakes 25 10% 6 0.54 3 2,054.3 1,112.1

Gulf of Mexico 3 1% No DQs 0 No DQs 0.0

Pacific Northwest 1 0% No DQs 0 No DQs 0.0

California 2 1% No DQs 0 No DQs 0.0

Inland 214 84% 28 1.03 29 519.6 535.0

Total 254 100% 34 32 2,573.9 1,647.1

Petroleum

North Atlantic 0 0% No DQs 0 No DQs 0.0

Mid-Atlantic 2 11% 2 1.00 2 203.4 203.4

South Atlantic 0 0% No DQs 0 No DQs 0.0

Great Lakes 0 0% No DQs40 No DQs 0.0

Gulf of Mexico 1 6% 1 1.00 1 42.6 42.6

Pacific Northwest 0 0% No DQs 0 No DQs 0.0

California 1 6% 1 1.00 1 31.8 31.8

Inland 15 78% 15 1.00 15 250.7 250.7

Total 19 100% 19 19 528.4 528.4
March 28, 2011 A-5

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table A-1: MN DQ Distribution and Calculation of Weight Adjustment Factors

Distribution of

Facilities in

PCS/ICIS

Databases

Number of

Regional Mean

Operational Flow

(MGD) Benefits Region

Number %

DQweighted

Facilities1

Adjustment

Factor

Adjusted

Weight

Estimates

DQweighted

Adjusted

Weight

Estimates

Other

Inland 1 100% 1 1.00 1 4.1 4.1

Total 1 100% 1 1 4.1 4.1

Total for All Industries

North Atlantic 28 1% No DQs 0 No DQs 0.0

Mid-Atlantic 100 5% 6 11 232.0 264.7

South Atlantic 19 1% 4 1 56.4 14.5

Great Lakes 78 4% 29 13 2,422.3 1,210.0

Gulf of Mexico 107 5% 5 13 326.5 852.4

Pacific Northwest 8 0% No DQs 0 No DQs 0.0

California 8 0% 8 5 65.5 64.4

Inland 1,630 82% 259 260 3,887.0 3,919.5

Total 1,978 100% 312 304 6,989.8 6,325.5

1EPA did not adjust weights for petroleum refineries because the DQ was a census of in-scope facilities, nor for facilities in “other”

industries because they were outside the five SIC codes for which weights were developed and are not assumed to represent any

other facilities.

2Though these regions account for more than 5% of Aluminum manufacturers but have no DQs, the average flow for Aluminum

manufacturers is less than 10 MGD. Potential benefits associated with these facilities would be relatively minor.

3While the PCS/ICIS data did not identify any Paper facilities in the California Region, there was 1 DQ facility in this region with a

weight of 3. This weight was not adjusted.

4There was 1 DQ refinery in the Great Lakes region. However this facility was assessed as a baseline closure in the economic

analysis and thus receives an adjustment factor of 0.

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. Weights were adjusted 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 in-scope facility by study region, and then calculated adjusted weights for

use in the benefits analysis.

Determining the Distribution of In-scope Facilities by Study Region

The entire universe of MU facilities was known based on the survey screener and the OTIS Facility-finder

tool was used to obtain facility location data.55 EPA distributed the universe of facilities among study

regions based on the regional distribution of MU facilities with location data from OTIS Facility-finder.

Calculating Adjusted Weights for Benefits Analysis

For each study region, EPA compared the estimated number of MU facilities with the DQ-weighted

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, it was assigned a weight of one to fully account for the

55 While the survey screener asked for facilities’ flow, EPA was unable to develop adjustment factors using total flow as a control

variable.
March 28, 2011 A-6

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

flow of the sampled facility. 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

Estimated

Facilities

from In-scope

Distribution

DQweighted

Facilities

Adjustment

Factor

Total Original

Weighted Flow

(MGD)

Total Adjusted

Weighted Flow

(MGD)

MU Facilities

North Atlantic 6 5 1.2 220.9 275.3

Mid-Atlantic 3 6 0.5 440.8 369.0

South Atlantic 2 No DQs No DQs 0.0

Great Lakes 14 12 1.2 1,186.4 1,400.0

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 163 174 0.9 9,464.7 8,880.9

Total 198 205 11,893.5 11,676.6

NU Facilities Determined to be Manufacturers1

Inland N/A 12 16 392.9 392.9

Paper

Grand Total N/A 217 12,286.4 12,069.5

1Two facilities that were surveyed as non-utilities (NU) were later determined to be non-utility manufacturers and are analyzed as such in

the cost analysis. 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

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 sample weights developed to support the 2010 analysis.

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.

56

When estimating national-level benefits, sample weights based on facility-specific (e.g., size and

engineering) characteristics can lead to conditional bias. In particular, this approach does not consider

factors influencing the occurrence and size of benefits such as the location of facilities subject to the

regulatory options, actual intake flow, 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.

56In general, the original survey weights are numerically very low, as EPA had either DQ or STQ information for 621 out of the

634 electric generating facilities presumed to be in scope of the regulation. For more information on EPA’s Section 316(b)

Industry Surveys, please refer to the Information Collection Request (USEPA 2000b).
March 28, 2011 A-7

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

AA

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.

I&E mortality losses are largely a function of mean operational intake flow and characteristics of local

fishery resources. Therefore, regional non-recirculated operational flow is the most important factor in

defining strata for the benefits estimation, and 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 options analyzed under the regulation.

Table A-3: Matrix of Strata and Control Variables for Adjusting DQ Weights

Mean Operational Flow (GPD)

Facilities with Recirculation

Technology1

Facilities without Recirculation

Technology Strata

DIF < 125

MGD

DIF > 125

MGD

DIF < 125

MGD

DIF > 125

MGD

North Atlantic 0 0 238 6,510

Mid-Atlantic 68 0 257 26,518

South Atlantic 46 0 0 7,033

Gulf of Mexico 0 0 0 9,049

Great Lakes 57 181c

343 15,428

Inland 1,258 2,221 1,900 117,989

California2

0 0 0 1,135

Total 1,429 2,402 2,738 183,663

1

Includes all electric generating facilities with recirculating technology regardless of intake velocity.

2Generators in the state of California were excluded from the analysis; however, the California region includes

three facilities in Hawaii.

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

Weighting Schemes

EPA assigned post-stratification weights (Table A-3) so that tabulations of total mean operational flow by

region and DIF threshold correspond to the best estimates of operational flow based on information

provided by both DQ and STQ questionnaires. Estimated mean operational flow under various weighting

procedures are presented in Table A-4. Regional control total is calculated using operational flow data

from DQ and STQ and facility-level original sample weights that account for non-sampled facilities and

non-respondents. The DQ total is the total operational flow of facilities to which weights are applied. By

design, the post-stratification estimate of mean operational flow equals the control total estimate. Benefits

weights are determined as the quotient of the control total divided by the DQ total. The number of
March 28, 2011 A-8

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

facilities estimated using these weights may not match the control estimate of the population of facilities.

For example, when average mean operational flow in the DQ sample of facilities is lower than the total

operational flow of all facilities in a given region, larger sample weights must be assigned to ensure the

estimated sample-weighted operational flow is equivalent to the control total. Thus, although total

operational flow is equivalent, the number of facilities estimated using these weights may be an

overestimate of facilities within the region. This shortcoming is not important, however, because DQ

weights are not used to estimate the number of facilities.

During the weight development process, EPA assessed the variance of the new weights to examine their

reasonableness. Weights with smaller variance generally lead to estimates with smaller variance unless

the larger variance of the weights reflects the characteristics on which the estimates depend. Since mean

operational flow is the most important factor in determining benefits, EPA believes that accounting for

this factor 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. However, adjusting original DQ weights increases the variance of new weights. The

additional variance is not likely to reflect the characteristics on which the estimates depend, and therefore

these weights are inferior.

Table A-4: Mean Operational Flow by Benefits Region: Post-Stratification by Mean

Regional Operational Flow for Facilities Without Recirculation (MGD)

Recirculating Flow Non-recirculating Flow

< 125 DIF (MGD) > 125 DIF (MGD) < 125 DIF (MGD) > 125 DIF (MGD) Region

DQ

Total

Control

Total

DQ

Total

Control

Total

DQ

Total

Control

Total

DQ

Total

Control

Total

North Atlantic 0 0 0 0 209 238 2,978 6,510

Mid-Atlantic 58 68 0 0 231 257 8,743 26,518

South

Atlantic1a 0 46 0 0 0 0 3,481 7,033

Gulf of

Mexico 0 0 0 0 0 0 6,751 9,049

Great Lakes 0 57 0 181c120 343 5,199 15,428

Inland 528 1,258 620 2,221 1,003 1,900 51,560 117,989

Total 587 1,429 620 2,402 1,625 2,799 80,631 194,997

1A total of five STQ facilities with baseline (one in the South Atlantic and four in the Great Lakes) did not have a DQ facility to

represent them within the region and DIF strata. Their flow was added to the respective non-recirculating totals when calculating

benefits weights, and are assigned the same benefits weights as non-recirculating facilities within the same region and DIF category.
March 28, 2011 B-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

B

Appendix B: Consideration of Potential Ecological 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 plant cooling water intakes (CWIS) 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 sitespecific 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. It also presents three case studies from power plants in different environmental settings (Brayton

Point Station, Quad Cities Nuclear Station, and Point Beach Nuclear Plant) which underwent detailed

thermal studies under Clean Water Act (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

plants 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 plants 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 plants 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 considered a master environmental 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 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).
March 28, 2011 B-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Much of the relevant primary research on power plant thermal discharges dates from the 1970's-1980's;

typically based on laboratory studies, field investigations, or environmental impact assessments

associated with the siting, permitting, and/or operation of power plants 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, altered 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 crossreferencing appropriate permitting databases57

.

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).

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.

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,

57 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.
March 28, 2011 B-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

estuarine copepods have more tolerance to thermal stress than those from more stenothermal, deepwater

environments.

Benthic Community

Benthic species and communities are often particularly vulnerable to thermal discharge due to their

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).

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.

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 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
March 28, 2011 B-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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 the habitat structure as well as fish community structure and its eco-spatial distribution.

Lowered fish species richness was observed in the impacted area and this was attributed to effects to

differences in benthic cover of a habitat former (i.e., reduced abundance of Sargassum weed).

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.

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").

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 they are subject to regular

environmental fluctuations.

Receiving Water Volume

The volume of the receiving water is a critical factor since it determines the total amount of heat that can
March 28, 2011 B-5

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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.

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.

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 areas having 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.

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 temperaturesensitive 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
March 28, 2011 B-6

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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 whose 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 settings (marine coastal embayment,

coastal Great Lake, and freshwater river) and with potential effects investigated 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 whose waters lie 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 looked 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
March 28, 2011 B-7

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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 2002b) 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 2002b). 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 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 2002b). 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 soft-bottom,

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 2002b). 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 2002b). Since BPS helps to elevate the water temperature over

significant portions of the bay, it is considered a contributory cause to this exclusion.
March 28, 2011 B-8

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

EPA judged that MBH was not a low potential impact area for shellfish and macroinvertebrates due to the

presence of commercially important species, their “substantial” densities, the spawning and nursery areas

in MHB, and the important role in ecosystem function that this community provides (USEPA 2002b).

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 2002b). 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 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 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. While

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% of the bottom water strata as compared to 4% 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 2002b). The plume acts as an attractant for

large numbers of striped bass and bluefish in the fall and winter and disrupts their seasonal migration. The

crowding of large numbers of these species into a restricted area increases the potential for weakening or
March 28, 2011 B-9

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

diseases to occur since the warm temperatures increase their metabolism 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

their migration and likely increases I&E losses due to longer periods spent in proximity to intake

structures and 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 2002b). Overall, there is no 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 2002b). 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 I&E (USEPA 2002b).

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 2002b). 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 cooling in all four of the power units.
March 28, 2011 B-10

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

B.5.2 Quad Cities Nuclear Station (QCNS)

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 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 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 (July-September), which would increase the predicted frequency of expected

thermal excursions from 1% to 3%. 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 they 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 Representative Important Species (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%
March 28, 2011 B-11

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

immediately downstream of the mixing zone, but placed in the areal relationship of the discharge to Pool

14, this would translate to a <1% 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 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
March 28, 2011 B-12

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

operation in December 1970 and Unit 2 in October 1972 (EA 2008). The units operate with a oncethrough 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).

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 plants 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 plant in the 1970s as well as the 1976 finding by WDNR that no appreciable harm had

occurred to the local BIC due to plant 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 plant

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
March 28, 2011 B-13

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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 along-shore current, the

planned EPU would expand the surface area of the 6.0oC contour from 27 to 39 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 they

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 plants 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 signficant impact on RIS of Lake Michigan

(EA 2008). Recently, as part of the plant’s 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).
March 28, 2011 C-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

C:

Appendix C: Details of Regional I&E Mortality Losses C

C.1 California

Table C-1: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the California Region (million A1Es

per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

All forage species 0.20 0.18 0.20 0.20 0.17 17.35 <0.01 14.79 15.47 <0.01 17.56 0.18 14.99 15.67 0.17

All harvested species 0.59 0.52 0.58 0.59 0.50 18.69 <0.01 15.93 16.66 <0.01 19.28 0.52 16.51 17.25 0.50

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 <0.01 <0.01 <0.01

Cabezon <0.01 <0.01 <0.01 <0.01 <0.01 0.06 <0.01 0.05 0.05 <0.01 0.06 <0.01 0.05 0.05 <0.01

California halibut <0.01 <0.01 <0.01 <0.01 <0.01 0.23 <0.01 0.20 0.21 <0.01 0.23 <0.01 0.20 0.21 <0.01

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 <0.01 <0.01 <0.01

Crabs (other) 0.02 0.02 0.02 0.02 0.02 7.80 <0.01 6.65 6.95 <0.01 7.82 0.02 6.67 6.98 0.02

Sea Basses <0.01 <0.01 <0.01 <0.01 <0.01 2.83 <0.01 2.41 2.52 <0.01 2.83 <0.01 2.41 2.53 <0.01

Shrimp (other) <0.01 <0.01 <0.01 <0.01 <0.01 0.63 <0.01 0.53 0.56 <0.01 0.63 <0.01 0.54 0.57 <0.01

Drums and croakers 0.05 0.04 0.05 0.05 0.04 0.23 <0.01 0.19 0.20 <0.01 0.27 0.04 0.24 0.25 0.04

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 <0.01 <0.01 <0.01

Flounders 0.01 <0.01 0.01 0.01 <0.01 0.10 <0.01 0.08 0.09 <0.01 0.11 <0.01 0.09 0.10 <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 0.01 0.01 <0.01

Northern anchovy 0.34 0.30 0.34 0.34 0.29 0.03 <0.01 0.03 0.03 <0.01 0.38 0.30 0.37 0.37 0.29

Rockfishes 0.02 0.01 0.02 0.02 0.01 6.33 <0.01 5.39 5.64 <0.01 6.34 0.01 5.41 5.66 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 <0.01 <0.01 <0.01

Sculpins 0.01 0.01 0.01 0.01 0.01 0.43 <0.01 0.36 0.38 <0.01 0.44 0.01 0.38 0.39 0.01

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 <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 0.01 0.01 <0.01

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 <0.01 <0.01 <0.01

Surfperches 0.11 0.10 0.11 0.11 0.10 <0.01 <0.01 <0.01 <0.01 <0.01 0.11 0.10 0.11 0.11 0.10

Total (all species) 0.79 0.69 0.78 0.79 0.68 36.04 <0.01 30.72 32.13 <0.01 36.83 0.69 31.50 32.92 0.68

Scenarios: B = Baseline I&E Mortality losses, 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Option 4 (I for

Facilities > 50 MGD)

I&EEntrainmentImpingement
March 28, 2011 C-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table C-2: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the California Region (million

individuals per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

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 <0.01 <0.01 <0.01

Blennies <0.01 <0.01 <0.01 <0.01 <0.01 914.88 <0.01 389.87 407.84 <0.01 914.88 <0.01 389.87 407.84 <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 <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 <0.01 <0.01 <0.01

Cabezon <0.01 <0.01 <0.01 <0.01 <0.01 6.65 <0.01 2.83 2.96 <0.01 6.65 <0.01 2.83 2.96 <0.01

California halibut <0.01 <0.01 <0.01 <0.01 <0.01 7.71 <0.01 3.29 3.44 <0.01 7.72 <0.01 3.29 3.44 <0.01

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 <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 <0.01 <0.01 <0.01

Crabs (other) 0.05 0.02 0.03 0.03 0.02 7,238.91 <0.01 3,084.81 3,227.00 <0.01 7,238.96 0.02 3,084.83 3,227.03 0.02

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 <0.01 <0.01 <0.01

Drums and croakers 0.41 0.18 0.20 0.21 0.18 915.22 <0.01 390.01 407.99 <0.01 915.63 0.18 390.22 408.20 0.18

Dungeness crab <0.01 <0.01 <0.01 <0.01 <0.01 0.09 <0.01 0.04 0.04 <0.01 0.09 <0.01 0.04 0.04 <0.01

Fish (other) 0.09 0.04 0.04 0.04 0.04 1,299.61 <0.01 553.82 579.35 <0.01 1,299.70 0.04 553.86 579.39 0.04

Flounders 0.01 <0.01 <0.01 <0.01 <0.01 319.23 <0.01 136.04 142.31 <0.01 319.24 <0.01 136.04 142.31 <0.01

Gobies <0.01 <0.01 <0.01 <0.01 <0.01 1,579.24 <0.01 672.98 704.00 <0.01 1,579.24 <0.01 672.98 704.00 <0.01

Herrings 0.06 0.02 0.03 0.03 0.02 26.23 <0.01 11.18 11.69 <0.01 26.28 0.02 11.20 11.72 0.02

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 <0.01 <0.01 <0.01

Northern anchovy 0.86 0.38 0.42 0.43 0.37 826.63 <0.01 352.26 368.50 <0.01 827.49 0.38 352.68 368.93 0.37

Pacific herring <0.01 <0.01 <0.01 <0.01 <0.01 36.16 <0.01 15.41 16.12 <0.01 36.17 <0.01 15.41 16.12 <0.01

Rockfishes 0.03 0.01 0.01 0.01 0.01 63.96 <0.01 27.26 28.51 <0.01 63.99 0.01 27.27 28.53 0.01

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 <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 <0.01 <0.01 <0.01

Sculpins 0.02 <0.01 <0.01 <0.01 <0.01 47.94 <0.01 20.43 21.37 <0.01 47.96 <0.01 20.44 21.38 <0.01

Sea Basses <0.01 <0.01 <0.01 <0.01 <0.01 13.24 <0.01 5.64 5.90 <0.01 13.24 <0.01 5.64 5.90 <0.01

Shrimp (other) 0.03 0.01 0.02 0.02 0.01 429.24 <0.01 182.92 191.35 <0.01 429.27 0.01 182.93 191.36 0.01

Silversides 0.11 0.05 0.05 0.06 0.05 121.84 <0.01 51.92 54.31 <0.01 121.95 0.05 51.97 54.37 0.05

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 <0.01 <0.01 <0.01

Smelts <0.01 <0.01 <0.01 <0.01 <0.01 3.63 <0.01 1.55 1.62 <0.01 3.63 <0.01 1.55 1.62 <0.01

Striped bass <0.01 <0.01 <0.01 <0.01 <0.01 11.31 <0.01 4.82 5.04 <0.01 11.31 <0.01 4.82 5.04 <0.01

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 <0.01 <0.01 <0.01

Surfperches 0.13 0.06 0.06 0.06 0.06 <0.01 <0.01 <0.01 <0.01 <0.01 0.13 0.06 0.06 0.06 0.06

Total (all species) 1.82 0.80 0.90 0.90 0.77 13,861.76 <0.01 5,907.09 6,179.38 <0.01 13,863.58 0.80 5,907.98 6,180.28 0.77

Scenarios: B = Baseline I&E Mortality losses. 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Option 4 (I for Facilities > 50 MGD).

Values for all options reflect reductions in losses.

Impingement Entrainment I&E

A
March 28, 2011 C-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

C.2 North Atlantic

Table C-3: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the North Atlantic

(million A1Es per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

All forage species 0.55 0.38 0.54 0.55 0.38 46.46 <0.01 37.88 39.74 <0.01 47.02 0.38 38.42 40.29 0.38

All harvested species 0.08 0.06 0.08 0.08 0.06 12.90 <0.01 10.52 11.03 <0.01 12.98 0.06 10.60 11.11 0.06

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 <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 <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 0.01 0.01 <0.01

Atlantic herring <0.01 <0.01 <0.01 <0.01 <0.01 0.12 <0.01 0.10 0.11 <0.01 0.13 <0.01 0.10 0.11 <0.01

Atlantic mackerel <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 0.02 0.02 <0.01 0.02 <0.01 0.02 0.02 <0.01

Atlantic menhaden <0.01 <0.01 <0.01 <0.01 <0.01 0.04 <0.01 0.03 0.03 <0.01 0.04 <0.01 0.03 0.03 <0.01

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 <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 <0.01 <0.01 <0.01

Crabs (other) 0.03 0.02 0.03 0.03 0.02 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 0.02 0.03 0.03 0.02

Cunner <0.01 <0.01 <0.01 <0.01 <0.01 4.26 <0.01 3.47 3.64 <0.01 4.26 <0.01 3.47 3.64 <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 <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 <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 <0.01 <0.01 <0.01

Sculpins <0.01 <0.01 <0.01 <0.01 <0.01 1.94 <0.01 1.58 1.66 <0.01 1.94 <0.01 1.59 1.66 <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 <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 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 <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 <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 <0.01 <0.01 <0.01

Tautog <0.01 <0.01 <0.01 <0.01 <0.01 0.11 <0.01 0.09 0.10 <0.01 0.11 <0.01 0.09 0.10 <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 <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 <0.01 <0.01 <0.01

Windowpane <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 0.02 0.02 <0.01 0.02 <0.01 0.02 0.02 <0.01

Winter flounder 0.03 0.02 0.02 0.02 0.02 6.35 <0.01 5.18 5.43 <0.01 6.38 0.02 5.20 5.46 0.02

Total (all species) 0.63 0.43 0.62 0.63 0.43 59.37 <0.01 48.40 50.77 <0.01 60.00 0.43 49.02 51.40 0.43

Impingement Entrainment I&E

Scenarios: B = Baseline I&E Mortality losses, 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere),

4 = Option 4 (I for Facilities > 50 MGD)
March 28, 2011 C-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table C-4: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the North Atlantic (million

individuals per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

Alewife 0.05 0.02 0.03 0.03 0.02 5.76 <0.01 2.35 2.46 <0.01 5.81 0.02 2.37 2.49 0.02

American plaice <0.01 <0.01 <0.01 <0.01 <0.01 199.21 <0.01 81.20 85.19 <0.01 199.21 <0.01 81.20 85.19 <0.01

American sand

lance 0.16 0.06 0.08 0.08 0.06 1,469.03 <0.01 598.82 628.20 <0.01 1,469.20 0.06 598.90 628.28 0.06

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 <0.01 <0.01 <0.01

Atlantic cod <0.01 <0.01 <0.01 <0.01 <0.01 117.38 <0.01 47.85 50.19 <0.01 117.38 <0.01 47.85 50.19 <0.01

Atlantic herring 0.03 0.01 0.01 0.01 0.01 87.31 <0.01 35.59 37.33 <0.01 87.34 0.01 35.60 37.35 0.01

Atlantic

mackerel <0.01 <0.01 <0.01 <0.01 <0.01 7,067.69 <0.01 2,880.99 3,022.33 <0.01 7,067.69 <0.01 2,880.99 3,022.33 <0.01

Atlantic

menhaden 0.02 <0.01 <0.01 <0.01 <0.01 4,206.13 <0.01 1,714.54 1,798.65 <0.01 4,206.15 <0.01 1,714.55 1,798.66 <0.01

Atlantic

silverside 0.14 0.05 0.07 0.07 0.05 96.58 <0.01 39.37 41.30 <0.01 96.71 0.05 39.43 41.37 0.05

Atlantic tomcod <0.01 <0.01 <0.01 <0.01 <0.01 6.28 <0.01 2.56 2.68 <0.01 6.28 <0.01 2.56 2.69 <0.01

Bay anchovy 0.03 0.01 0.02 0.02 0.01 55,820.08 <0.01 22,753.85 23,870.13 <0.01 55,820.11 0.01 22,753.86 23,870.15 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 <0.01 <0.01 <0.01

Bluefish <0.01 <0.01 <0.01 <0.01 <0.01 0.06 <0.01 0.02 0.02 <0.01 0.06 <0.01 0.02 0.02 <0.01

Butterfish <0.01 <0.01 <0.01 <0.01 <0.01 12.15 <0.01 4.95 5.20 <0.01 12.16 <0.01 4.96 5.20 <0.01

Crabs (other) 0.04 0.01 0.02 0.02 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.04 0.01 0.02 0.02 0.01

Cunner <0.01 <0.01 <0.01 <0.01 <0.01 29,170.94 <0.01 11,890.91 12,474.26 <0.01 29,170.95 <0.01 11,890.91 12,474.27 <0.01

Fish (other) 0.06 0.02 0.03 0.03 0.02 521.45 <0.01 212.56 222.99 <0.01 521.51 0.02 212.59 223.02 0.02

Fourbeard

rockling <0.01 <0.01 <0.01 <0.01 <0.01 464.23 <0.01 189.23 198.52 <0.01 464.23 <0.01 189.23 198.52 <0.01

Grubby 0.02 <0.01 0.01 0.01 <0.01 431.08 <0.01 175.72 184.34 <0.01 431.10 <0.01 175.73 184.35 <0.01

Hogchoker 0.04 0.01 0.02 0.02 0.01 549.17 <0.01 223.86 234.84 <0.01 549.22 0.01 223.88 234.86 0.01

Lumpfish <0.01 <0.01 <0.01 <0.01 <0.01 44.89 <0.01 18.30 19.20 <0.01 44.89 <0.01 18.30 19.20 <0.01

Northern

pipefish <0.01 <0.01 <0.01 <0.01 <0.01 1.15 <0.01 0.47 0.49 <0.01 1.16 <0.01 0.47 0.49 <0.01

Pollock <0.01 <0.01 <0.01 <0.01 <0.01 3.46 <0.01 1.41 1.48 <0.01 3.47 <0.01 1.41 1.48 <0.01

Radiated shanny <0.01 <0.01 <0.01 <0.01 <0.01 110.36 <0.01 44.99 47.19 <0.01 110.36 <0.01 44.99 47.19 <0.01

Rainbow smelt 0.05 0.02 0.03 0.03 0.02 17.65 <0.01 7.19 7.55 <0.01 17.70 0.02 7.22 7.57 0.02

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 <0.01 <0.01 <0.01

Rock gunnel <0.01 <0.01 <0.01 <0.01 <0.01 395.87 <0.01 161.37 169.29 <0.01 395.88 <0.01 161.37 169.29 <0.01

Sculpins <0.01 <0.01 <0.01 <0.01 <0.01 218.67 <0.01 89.13 93.51 <0.01 218.67 <0.01 89.14 93.51 <0.01

Scup <0.01 <0.01 <0.01 <0.01 <0.01 16.64 <0.01 6.78 7.12 <0.01 16.65 <0.01 6.79 7.12 <0.01

Impingement Entrainment I&E
March 28, 2011 C-5

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table C-4: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the North Atlantic (million A1Es per

year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality, continued

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

Seaboard goby <0.01 <0.01 <0.01 <0.01 <0.01 2,379.58 <0.01 969.99 1,017.57 <0.01 2,379.58 <0.01 969.99 1,017.57 <0.01

Searobin <0.01 <0.01 <0.01 <0.01 <0.01 11.48 <0.01 4.68 4.91 <0.01 11.48 <0.01 4.68 4.91 <0.01

Silver hake 0.03 0.01 0.02 0.02 0.01 568.71 <0.01 231.82 243.20 <0.01 568.75 0.01 231.84 243.21 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 <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 <0.01 <0.01 <0.01

Striped killifish <0.01 <0.01 <0.01 <0.01 <0.01 0.06 <0.01 0.03 0.03 <0.01 0.07 <0.01 0.03 0.03 <0.01

Tautog <0.01 <0.01 <0.01 <0.01 <0.01 29,299.93 <0.01 11,943.48 12,529.42 <0.01 29,299.94 <0.01 11,943.49 12,529.42 <0.01

Threespine

stickleback 0.03 <0.01 0.01 0.01 <0.01 0.09 <0.01 0.04 0.04 <0.01 0.11 <0.01 0.05 0.05 <0.01

Weakfish <0.01 <0.01 <0.01 <0.01 <0.01 342.21 <0.01 139.49 146.34 <0.01 342.21 <0.01 139.50 146.34 <0.01

White perch 0.01 <0.01 <0.01 <0.01 <0.01 0.28 <0.01 0.12 0.12 <0.01 0.30 <0.01 0.12 0.13 <0.01

Windowpane 0.01 <0.01 <0.01 <0.01 <0.01 2,066.54 <0.01 842.38 883.71 <0.01 2,066.55 <0.01 842.39 883.71 <0.01

Winter flounder 0.09 0.03 0.05 0.05 0.03 6,688.08 <0.01 2,726.25 2,860.00 <0.01 6,688.17 0.03 2,726.30 2,860.04 0.03

Total (all

species) 0.90 0.31 0.44 0.45 0.31 142,390.18 <0.01 58,042.28 60,889.79 <0.01 142,391.08 0.31 58,042.72 60,890.23 0.31

Scenarios: B = Baseline I&E Mortality losses. 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Option 4 (I for Facilities >

50 MGD). Values for all options reflect reductions in losses.

Impingement Entrainment I&E
March 28, 2011 C-6

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

C.3 Mid-Atlantic

Table C-5: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Mid-Atlantic (million A1Es

per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

All forage species 18.71 14.27 18.25 18.31 14.26 732.37 <0.01 670.71 679.28 <0.01 751.07 14.27 688.96 697.59 14.26

All harvested species 32.00 24.42 31.22 31.33 24.39 206.98 <0.01 189.56 191.98 <0.01 238.98 24.42 220.78 223.31 24.39

Alewife 0.04 0.03 0.04 0.04 0.03 <0.01 <0.01 <0.01 <0.01 <0.01 0.05 0.03 0.04 0.05 0.03

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 <0.01 <0.01 <0.01

Atlantic croaker 0.31 0.24 0.30 0.31 0.24 21.59 <0.01 19.77 20.03 <0.01 21.90 0.24 20.08 20.33 0.24

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 <0.01 <0.01 <0.01

Atlantic menhaden 21.72 16.57 21.19 21.26 16.55 3.16 <0.01 2.89 2.93 <0.01 24.88 16.57 24.08 24.19 16.55

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 <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 <0.01 <0.01 <0.01

Blue crab 1.44 1.10 1.40 1.41 1.10 108.17 <0.01 99.07 100.33 <0.01 109.61 1.10 100.47 101.74 1.10

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 <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 <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 0.02 <0.01 0.02 0.02 <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 <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 <0.01 <0.01 <0.01

Channel catfish 0.02 0.01 0.02 0.02 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.01 0.02 0.02 0.01

Crabs (other) 0.03 0.02 0.03 0.03 0.02 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 0.02 0.03 0.03 0.02

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 <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 <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 <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 <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 <0.01 <0.01 <0.01

Fish (other) 1.30 0.99 1.27 1.27 0.99 10.81 <0.01 9.90 10.02 <0.01 12.10 0.99 11.16 11.29 0.99

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 <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 <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 <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 <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 <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 <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 <0.01 <0.01 <0.01

Impingement Entrainment I&E
March 28, 2011 C-7

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table C-5: I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Mid-Atlantic Region (million

A1Es) Estimated Under Baseline and Option Scenarios for All Sources of Mortality, continued

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

Spot 2.95 2.25 2.88 2.89 2.25 35.15 <0.01 32.19 32.60 <0.01 38.10 2.25 35.07 35.49 2.25

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 <0.01 <0.01 <0.01

Striped bass <0.01 <0.01 <0.01 <0.01 <0.01 1.39 <0.01 1.27 1.29 <0.01 1.40 <0.01 1.28 1.30 <0.01

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 <0.01 <0.01 <0.01

Summer flounder 0.02 0.02 0.02 0.02 0.02 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.02 0.02 0.02 0.02

Sunfish 0.02 0.01 0.02 0.02 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.01 0.02 0.02 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 <0.01 <0.01 <0.01

Weakfish 1.43 1.09 1.40 1.40 1.09 2.71 <0.01 2.48 2.51 <0.01 4.14 1.09 3.88 3.91 1.09

White perch 2.66 2.03 2.59 2.60 2.03 23.88 <0.01 21.87 22.15 <0.01 26.53 2.03 24.46 24.75 2.03

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 <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 <0.01 <0.01 <0.01

Winter flounder 0.02 0.01 0.02 0.02 0.01 0.11 <0.01 0.10 0.10 <0.01 0.12 0.01 0.11 0.11 0.01

Total (all species) 50.71 38.69 49.47 49.64 38.65 939.35 <0.01 860.27 871.26 <0.01 990.06 38.69 909.74 920.90 38.65

Scenarios: B = Baseline I&E Mortality losses, 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Option 4 (I for

Facilities > 50 MGD)

Impingement Entrainment I&E
March 28, 2011 C-8

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table C-6: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Mid-Atlantic (million individuals

per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

Alewife 0.33 0.13 0.16 0.16 0.13 6.10 <0.01 2.80 2.83 <0.01 6.44 0.13 2.96 2.99 0.13

American shad 0.06 0.02 0.03 0.03 0.02 67.07 <0.01 30.71 31.11 <0.01 67.13 0.02 30.74 31.13 0.02

Atlantic croaker 2.28 0.87 1.11 1.12 0.87 689.03 <0.01 315.51 319.54 <0.01 691.31 0.87 316.62 320.66 0.87

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 <0.01 <0.01 <0.01

Atlantic

menhaden 70.44 26.87 34.36 34.48 26.85 122.59 <0.01 56.13 56.85 <0.01 193.03 26.87 90.50 91.33 26.85

Atlantic silverside 1.40 0.53 0.68 0.69 0.53 110.15 <0.01 50.44 51.08 <0.01 111.55 0.53 51.12 51.77 0.53

Atlantic tomcod 0.13 0.05 0.06 0.07 0.05 <0.01 <0.01 <0.01 <0.01 <0.01 0.13 0.05 0.06 0.07 0.05

Bay anchovy 13.78 5.25 6.72 6.74 5.25 98,332.37 <0.01 45,026.92 45,602.31 <0.01 98,346.15 5.25 45,033.64 45,609.05 5.25

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 <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 <0.01 <0.01 <0.01

Blue crab 2.87 1.09 1.40 1.40 1.09 3,396.61 <0.01 1,555.33 1,575.20 <0.01 3,399.48 1.09 1,556.72 1,576.60 1.09

Blueback herring 1.27 0.48 0.62 0.62 0.48 24.27 <0.01 11.11 11.26 <0.01 25.54 0.48 11.73 11.88 0.48

Bluefish 0.03 0.01 0.01 0.01 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 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 <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 <0.01 <0.01 <0.01

Brown bullhead <0.01 <0.01 <0.01 <0.01 <0.01 0.11 <0.01 0.05 0.05 <0.01 0.12 <0.01 0.05 0.05 <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 <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 <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 <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 <0.01 <0.01 <0.01

Channel catfish 0.02 <0.01 0.01 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 0.01 0.01 <0.01

Crabs (other) 0.04 0.01 0.02 0.02 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.04 0.01 0.02 0.02 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 <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 <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 <0.01 <0.01 <0.01

Fish (other) 5.34 2.04 2.60 2.61 2.03 3,804.94 <0.01 1,742.30 1,764.57 <0.01 3,810.28 2.04 1,744.91 1,767.18 2.03

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 <0.01 <0.01 <0.01

Gizzard shad 0.34 0.13 0.17 0.17 0.13 <0.01 <0.01 <0.01 <0.01 <0.01 0.34 0.13 0.17 0.17 0.13

Gobies <0.01 <0.01 <0.01 <0.01 <0.01 143.88 <0.01 65.88 66.72 <0.01 143.88 <0.01 65.88 66.72 <0.01

Grubby <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 <0.01 <0.01 <0.01 0.02 <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 <0.01 <0.01 <0.01

Hogchoker 0.53 0.20 0.26 0.26 0.20 25,970.61 <0.01 11,892.08 12,044.05 <0.01 25,971.14 0.20 11,892.34 12,044.31 0.20

Impingement Entrainment I&E
March 28, 2011 C-9

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table C-6: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Mid-Atlantic (million individuals

per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality, continued

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

Menhadens <0.01 <0.01 <0.01 <0.01 <0.01 0.11 <0.01 0.05 0.05 <0.01 0.11 <0.01 0.05 0.05 <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 <0.01 <0.01 <0.01

Northern pipefish 0.03 0.01 0.02 0.02 0.01 10.64 <0.01 4.87 4.93 <0.01 10.67 0.01 4.89 4.95 0.01

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 <0.01 <0.01 <0.01

Red drum 0.02 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 <0.01 <0.01 <0.01

Red hake 0.07 0.03 0.04 0.04 0.03 <0.01 <0.01 <0.01 <0.01 <0.01 0.07 0.03 0.04 0.04 0.03

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 <0.01 <0.01 <0.01

Seaboard goby 0.02 <0.01 <0.01 <0.01 <0.01 13,691.58 <0.01 6,269.45 6,349.56 <0.01 13,691.59 <0.01 6,269.46 6,349.57 <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 <0.01 <0.01 <0.01

Shiners <0.01 <0.01 <0.01 <0.01 <0.01 1.00 <0.01 0.46 0.46 <0.01 1.00 <0.01 0.46 0.46 <0.01

Silver hake 0.02 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <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 <0.01 <0.01 <0.01

Silversides <0.01 <0.01 <0.01 <0.01 <0.01 2.84 <0.01 1.30 1.32 <0.01 2.85 <0.01 1.30 1.32 <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 <0.01 <0.01 <0.01

Spot 9.17 3.50 4.47 4.49 3.49 232.64 <0.01 106.53 107.89 <0.01 241.80 3.50 111.00 112.37 3.49

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 <0.01 <0.01 <0.01

Striped bass 0.04 0.01 0.02 0.02 0.01 1,060.00 <0.01 485.38 491.58 <0.01 1,060.04 0.01 485.40 491.60 0.01

Striped killifish 0.32 0.12 0.16 0.16 0.12 <0.01 <0.01 <0.01 <0.01 <0.01 0.32 0.12 0.16 0.16 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 <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 <0.01 <0.01 <0.01

Summer flounder 0.08 0.03 0.04 0.04 0.03 <0.01 <0.01 <0.01 <0.01 <0.01 0.08 0.03 0.04 0.04 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 <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 <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 <0.01 <0.01 <0.01

Weakfish 3.31 1.26 1.61 1.62 1.26 486.50 <0.01 222.77 225.62 <0.01 489.81 1.26 224.39 227.24 1.26

White perch 2.81 1.07 1.37 1.37 1.07 2,335.12 <0.01 1,069.26 1,082.93 <0.01 2,337.92 1.07 1,070.63 1,084.30 1.07

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 <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 <0.01 <0.01 <0.01

Winter flounder 0.06 0.02 0.03 0.03 0.02 92.01 <0.01 42.13 42.67 <0.01 92.07 0.02 42.16 42.70 0.02

Total (all

species) 114.86 43.81 56.03 56.22 43.77 150,580.20 <0.01 68,951.48 69,832.59 <0.01 150,695.05 43.81 69,007.51 69,888.82 43.77

Scenarios: B = Baseline I&E Mortality losses. 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Option 4 (I for Facilities > 50 MGD). Values for all options

reflect reductions in losses.

Impingement Entrainment I&E
March 28, 2011 C-10

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

C.4 South Atlantic

Table C-7: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the South Atlantic

(million A1Es per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

All forage species 21.27 13.43 18.13 18.14 13.43 9.94 <0.01 8.29 8.31 <0.01 31.22 13.43 26.43 26.45 13.43

All harvested species 1.22 0.77 1.04 1.04 0.77 0.96 <0.01 0.80 0.81 <0.01 2.19 0.77 1.85 1.85 0.77

Atlantic menhaden 0.25 0.16 0.21 0.21 0.16 0.03 <0.01 0.02 0.03 <0.01 0.28 0.16 0.24 0.24 0.16

Blue crab 0.45 0.29 0.39 0.39 0.29 <0.01 <0.01 <0.01 <0.01 <0.01 0.45 0.29 0.39 0.39 0.29

Crabs (other) <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 0.02 0.02 <0.01 0.02 <0.01 0.02 0.02 <0.01

Drums and croakers 0.02 0.01 0.02 0.02 0.01 0.80 <0.01 0.67 0.67 <0.01 0.82 0.01 0.69 0.69 0.01

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 <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 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 <0.01 <0.01 <0.01

Silver perch 0.28 0.18 0.24 0.24 0.18 <0.01 <0.01 <0.01 <0.01 <0.01 0.28 0.18 0.24 0.24 0.18

Spot 0.20 0.12 0.17 0.17 0.12 0.10 <0.01 0.08 0.08 <0.01 0.29 0.12 0.25 0.25 0.12

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 <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 <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 <0.01 <0.01 <0.01

Total (all species) 22.50 14.20 19.18 19.19 14.20 10.91 <0.01 9.10 9.11 <0.01 33.40 14.20 28.28 28.30 14.20

Scenarios: B = Baseline I&E Mortality losses, 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 =

Option 4 (I for Facilities > 50 MGD)

Impingement Entrainment I&E
March 28, 2011 C-11

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table C-8: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the South Atlantic (million

individuals per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

Atlantic

menhaden 0.82 0.26 0.35 0.35 0.26 157.54 <0.01 65.70 65.81 <0.01 158.36 0.26 66.05 66.15 0.26

Atlantic

silverside 0.13 0.04 0.05 0.05 0.04 <0.01 <0.01 <0.01 <0.01 <0.01 0.13 0.04 0.05 0.05 0.04

Bay anchovy 25.54 8.06 10.89 10.89 8.06 2,402.75 <0.01 1,002.00 1,003.65 <0.01 2,428.30 8.06 1,012.88 1,014.54 8.06

Blue crab 0.90 0.28 0.38 0.38 0.28 <0.01 <0.01 <0.01 <0.01 <0.01 0.90 0.28 0.38 0.38 0.28

Crabs (other) <0.01 <0.01 <0.01 <0.01 <0.01 667.97 <0.01 278.56 279.02 <0.01 667.97 <0.01 278.56 279.02 <0.01

Drums and

croakers 0.22 0.07 0.09 0.09 0.07 2,376.84 <0.01 991.19 992.83 <0.01 2,377.05 0.07 991.28 992.92 0.07

Fish (other) 1.67 0.53 0.71 0.71 0.53 272.99 <0.01 113.84 114.03 <0.01 274.66 0.53 114.55 114.74 0.53

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 <0.01 <0.01 <0.01

Gobies <0.01 <0.01 <0.01 <0.01 <0.01 3,576.38 <0.01 1,491.43 1,493.89 <0.01 3,576.38 <0.01 1,491.43 1,493.89 <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 <0.01 <0.01 <0.01

Pinfish <0.01 <0.01 <0.01 <0.01 <0.01 71.34 <0.01 29.75 29.80 <0.01 71.34 <0.01 29.75 29.80 <0.01

Scaled sardine 0.03 <0.01 0.01 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 <0.01 0.01 0.01 <0.01

Shrimp (other) 8.90 2.81 3.79 3.79 2.81 1,040.49 <0.01 433.91 434.62 <0.01 1,049.39 2.81 437.70 438.42 2.81

Silver perch 0.45 0.14 0.19 0.19 0.14 <0.01 <0.01 <0.01 <0.01 <0.01 0.45 0.14 0.19 0.19 0.14

Spot 0.72 0.23 0.31 0.31 0.23 2,152.83 <0.01 897.77 899.25 <0.01 2,153.54 0.23 898.08 899.56 0.23

Spotted seatrout <0.01 <0.01 <0.01 <0.01 <0.01 35.30 <0.01 14.72 14.75 <0.01 35.30 <0.01 14.72 14.75 <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 <0.01 <0.01 <0.01

Weakfish 0.04 0.01 0.02 0.02 0.01 100.99 <0.01 42.12 42.19 <0.01 101.04 0.01 42.14 42.20 0.01

Total (all

species) 39.42 12.44 16.80 16.81 12.44 12,855.43 <0.01 5,360.98 5,369.82 <0.01 12,894.86 12.44 5,377.79 5,386.64 12.44

Scenarios: B = Baseline I&E Mortality losses. 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Option 4 (I for Facilities > 50 MGD). Values for all

options reflect reductions in losses.

Impingement Entrainment I&E
March 28, 2011 C-12

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

C.5 Gulf of Mexico

Table C-9: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Gulf of Mexico (million

A1Es per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

All forage species 5.63 4.31 5.59 5.60 4.28 42.12 <0.01 28.49 28.56 <0.01 47.75 4.31 34.09 34.16 4.28

All harvested species 39.42 30.19 39.15 39.18 29.96 48.47 <0.01 32.79 32.87 <0.01 87.89 30.19 71.94 72.05 29.96

Atlantic croaker 1.65 1.27 1.64 1.64 1.26 <0.01 <0.01 <0.01 <0.01 <0.01 1.65 1.27 1.64 1.64 1.26

Black drum 0.01 <0.01 0.01 0.01 <0.01 5.93 <0.01 4.01 4.02 <0.01 5.94 <0.01 4.02 4.03 <0.01

Blue crab 5.66 4.33 5.62 5.62 4.30 19.03 <0.01 12.87 12.90 <0.01 24.68 4.33 18.49 18.53 4.30

Leatherjacket 0.69 0.53 0.68 0.69 0.52 0.03 <0.01 0.02 0.02 <0.01 0.72 0.53 0.71 0.71 0.52

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 <0.01 <0.01 <0.01

Menhadens 4.95 3.79 4.92 4.92 3.76 0.05 <0.01 0.03 0.03 <0.01 5.00 3.79 4.95 4.96 3.76

Fish (other) 1.48 1.14 1.47 1.47 1.13 0.16 <0.01 0.11 0.11 <0.01 1.64 1.14 1.58 1.58 1.13

Pinfish 0.03 0.02 0.03 0.03 0.02 1.07 <0.01 0.72 0.73 <0.01 1.10 0.02 0.75 0.76 0.02

Pink shrimp 21.44 16.42 21.29 21.31 16.30 13.40 <0.01 9.07 9.09 <0.01 34.84 16.42 30.36 30.40 16.30

Red drum 0.08 0.06 0.08 0.08 0.06 0.01 <0.01 <0.01 <0.01 <0.01 0.10 0.06 0.09 0.09 0.06

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 <0.01 <0.01 <0.01

Searobin 0.94 0.72 0.93 0.93 0.71 0.36 <0.01 0.25 0.25 <0.01 1.30 0.72 1.18 1.18 0.71

Sheepshead <0.01 <0.01 <0.01 <0.01 <0.01 0.03 <0.01 0.02 0.02 <0.01 0.04 <0.01 0.02 0.02 <0.01

Silver perch 0.28 0.22 0.28 0.28 0.21 5.11 <0.01 3.46 3.47 <0.01 5.40 0.22 3.74 3.75 0.21

Spot 0.38 0.29 0.38 0.38 0.29 0.09 <0.01 0.06 0.06 <0.01 0.47 0.29 0.44 0.44 0.29

Spotted seatrout 1.26 0.96 1.25 1.25 0.96 0.15 <0.01 0.10 0.10 <0.01 1.41 0.96 1.35 1.35 0.96

Stone crab 0.19 0.14 0.18 0.19 0.14 0.41 <0.01 0.28 0.28 <0.01 0.60 0.14 0.47 0.47 0.14

Striped mullet 0.37 0.28 0.37 0.37 0.28 2.62 <0.01 1.77 1.78 <0.01 2.99 0.28 2.14 2.14 0.28

Total (all species) 45.05 34.50 44.74 44.78 34.24 90.59 <0.01 61.28 61.43 <0.01 135.64 34.50 106.02 106.21 34.24

Scenarios: B = Baseline I&E Mortality losses, 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 =

Option 4 (I for Facilities > 50 MGD)

I&EEntrainmentImpingement
March 28, 2011 C-13

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table C-10: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Gulf of Mexico (million

individuals per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

Atlantic croaker 15.45 5.92 7.67 7.68 5.87 162.35 <0.01 54.91 55.05 <0.01 177.81 5.92 62.59 62.73 5.87

Bay anchovy 4.33 1.66 2.15 2.15 1.65 301,092.72 <0.01 101,837.44 102,087.75 <0.01 301,097.05 1.66 101,839.59 102,089.90 1.65

Black drum 0.02 <0.01 0.01 0.01 <0.01 96,328.24 <0.01 32,580.73 32,660.81 <0.01 96,328.26 <0.01 32,580.74 32,660.83 <0.01

Blue crab 11.26 4.31 5.59 5.60 4.28 280.96 <0.01 95.03 95.26 <0.01 292.22 4.31 100.62 100.86 4.28

Chain pipefish 0.07 0.03 0.03 0.03 0.03 2.13 <0.01 0.72 0.72 <0.01 2.19 0.03 0.75 0.75 0.03

Fish (other) 7.43 2.85 3.69 3.69 2.82 9,784.29 <0.01 3,309.30 3,317.44 <0.01 9,791.72 2.85 3,312.99 3,321.13 2.82

Gobies 0.14 0.05 0.07 0.07 0.05 3,407.68 <0.01 1,152.57 1,155.40 <0.01 3,407.82 0.05 1,152.64 1,155.47 0.05

Gulf killifish 0.04 0.01 0.02 0.02 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.04 0.01 0.02 0.02 0.01

Hogchoker 0.15 0.06 0.07 0.07 0.06 198.72 <0.01 67.21 67.38 <0.01 198.87 0.06 67.28 67.45 0.06

Leatherjacket 0.95 0.36 0.47 0.47 0.36 794.02 <0.01 268.56 269.22 <0.01 794.97 0.36 269.03 269.69 0.36

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 <0.01 <0.01 <0.01

Menhadens 16.06 6.15 7.98 7.98 6.10 269.13 <0.01 91.03 91.25 <0.01 285.19 6.15 99.00 99.23 6.10

Pinfish 0.12 0.05 0.06 0.06 0.04 107.79 <0.01 36.46 36.55 <0.01 107.91 0.05 36.52 36.61 0.04

Pink shrimp 43.73 16.74 21.71 21.73 16.62 126.32 <0.01 42.73 42.83 <0.01 170.05 16.74 64.44 64.56 16.62

Red drum 0.16 0.06 0.08 0.08 0.06 1.10 <0.01 0.37 0.37 <0.01 1.26 0.06 0.45 0.45 0.06

Scaled sardine 0.32 0.12 0.16 0.16 0.12 2,962.36 <0.01 1,001.95 1,004.41 <0.01 2,962.69 0.12 1,002.11 1,004.57 0.12

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 <0.01 <0.01 <0.01

Searobin 1.18 0.45 0.58 0.58 0.45 68.82 <0.01 23.28 23.33 <0.01 70.00 0.45 23.86 23.92 0.45

Sheepshead <0.01 <0.01 <0.01 <0.01 <0.01 382.88 <0.01 129.50 129.82 <0.01 382.88 <0.01 129.50 129.82 <0.01

Silver perch 0.45 0.17 0.23 0.23 0.17 88,985.72 <0.01 30,097.30 30,171.28 <0.01 88,986.17 0.17 30,097.53 30,171.50 0.17

Spot 1.39 0.53 0.69 0.69 0.53 34.75 <0.01 11.75 11.78 <0.01 36.14 0.53 12.44 12.47 0.53

Spotted

seatrout 1.20 0.46 0.60 0.60 0.46 5,338.00 <0.01 1,805.45 1,809.89 <0.01 5,339.20 0.46 1,806.05 1,810.49 0.46

Stone crab 0.27 0.10 0.14 0.14 0.10 28,711.01 <0.01 9,710.82 9,734.68 <0.01 28,711.29 0.10 9,710.95 9,734.82 0.10

Striped mullet 0.45 0.17 0.22 0.23 0.17 15.17 <0.01 5.13 5.14 <0.01 15.62 0.17 5.36 5.37 0.17

Tidewater

silverside 0.30 0.11 0.15 0.15 0.11 34.36 <0.01 11.62 11.65 <0.01 34.66 0.11 11.77 11.80 0.11

Total (all

species) 105.48 40.39 52.38 52.42 40.09 539,088.54 <0.01 182,333.86 182,782.02 <0.01 539,194.01 40.39 182,386.23 182,834.44 40.09

Scenarios: B = Baseline I&E Mortality losses. 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Option 4 (I for Facilities > 50 MGD). Values for all options

reflect reductions in losses.

Impingement Entrainment I&E
March 28, 2011 C-14

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

C.6 Great Lakes

Table C-11: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Great Lakes

(million A1Es per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

All forage species 38.62 33.46 38.20 38.29 33.17 7.84 <0.01 6.26 6.36 <0.01 46.46 33.46 44.46 44.64 33.17

All harvested species 5.51 4.77 5.45 5.46 4.73 1.53 <0.01 1.22 1.24 <0.01 7.04 4.77 6.67 6.70 4.73

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 <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 <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 <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 <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 <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 <0.01 <0.01 <0.01

Crappie <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 0.01 0.01 <0.01 0.02 <0.01 0.02 0.02 <0.01

Freshwater drum 0.02 0.02 0.02 0.02 0.02 0.05 <0.01 0.04 0.04 <0.01 0.07 0.02 0.06 0.06 0.02

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 <0.01 <0.01 <0.01

Fish (other) 0.06 0.05 0.06 0.06 0.05 <0.01 <0.01 <0.01 <0.01 <0.01 0.06 0.05 0.06 0.06 0.05

Rainbow smelt 0.37 0.32 0.36 0.36 0.32 0.07 <0.01 0.05 0.05 <0.01 0.44 0.32 0.42 0.42 0.32

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 <0.01 <0.01 <0.01

Sculpins <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 0.02 0.02 <0.01 0.03 <0.01 0.02 0.02 <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 <0.01 <0.01 <0.01

Smelts 4.49 3.89 4.45 4.46 3.86 0.02 <0.01 0.02 0.02 <0.01 4.52 3.89 4.46 4.47 3.86

Sunfish 0.02 0.02 0.02 0.02 0.02 1.18 <0.01 0.95 0.96 <0.01 1.20 0.02 0.96 0.98 0.02

Walleye <0.01 <0.01 <0.01 <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 bass 0.05 0.04 0.05 0.05 0.04 0.09 <0.01 0.08 0.08 <0.01 0.14 0.04 0.12 0.13 0.04

Whitefish 0.23 0.20 0.22 0.23 0.20 <0.01 <0.01 <0.01 <0.01 <0.01 0.23 0.20 0.22 0.23 0.20

Yellow perch 0.26 0.23 0.26 0.26 0.22 0.07 <0.01 0.05 0.05 <0.01 0.33 0.23 0.31 0.31 0.22

Total (all species) 44.13 38.23 43.65 43.75 37.91 9.37 <0.01 7.48 7.60 <0.01 53.50 38.23 51.13 51.35 37.91

Impingement Entrainment I&E

Scenarios: B = Baseline I&E Mortality losses, 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4

= Option 4 (I for Facilities > 50 MGD)
March 28, 2011 C-15

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table C-12: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Great Lakes (million

individuals per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

Alewife 28.95 12.54 14.32 14.35 12.44 38,098.88 <0.01 15,213.50 15,443.27 <0.01 38,127.84 12.54 15,227.82 15,457.62 12.44

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 <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 <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 <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 <0.01 <0.01 <0.01

Bluntnose minnow 0.01 <0.01 <0.01 <0.01 <0.01 13.01 <0.01 5.20 5.27 <0.01 13.02 <0.01 5.20 5.28 <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 <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 <0.01 <0.01 <0.01

Burbot <0.01 <0.01 <0.01 <0.01 <0.01 0.53 <0.01 0.21 0.21 <0.01 0.53 <0.01 0.21 0.22 <0.01

Carp 0.04 0.02 0.02 0.02 0.02 3,239.89 <0.01 1,293.74 1,313.28 <0.01 3,239.94 0.02 1,293.76 1,313.30 0.02

Channel catfish <0.01 <0.01 <0.01 <0.01 <0.01 0.20 <0.01 0.08 0.08 <0.01 0.20 <0.01 0.08 0.08 <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 <0.01 <0.01 <0.01

Crappie <0.01 <0.01 <0.01 <0.01 <0.01 0.90 <0.01 0.36 0.36 <0.01 0.90 <0.01 0.36 0.37 <0.01

Darters 0.01 <0.01 <0.01 <0.01 <0.01 2.87 <0.01 1.15 1.16 <0.01 2.88 <0.01 1.15 1.17 <0.01

Emerald shiner 0.40 0.17 0.20 0.20 0.17 47.50 <0.01 18.97 19.25 <0.01 47.90 0.17 19.17 19.45 0.17

Fish (other) 0.19 0.08 0.09 0.10 0.08 40,037.77 <0.01 15,987.73 16,229.19 <0.01 40,037.96 0.08 15,987.82 16,229.28 0.08

Freshwater drum 0.07 0.03 0.03 0.03 0.03 221.20 <0.01 88.33 89.66 <0.01 221.27 0.03 88.36 89.70 0.03

Gizzard shad 14.94 6.47 7.39 7.40 6.42 3,846.52 <0.01 1,535.98 1,559.17 <0.01 3,861.45 6.47 1,543.36 1,566.58 6.42

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 <0.01 <0.01 <0.01

Herrings <0.01 <0.01 <0.01 <0.01 <0.01 11.15 <0.01 4.45 4.52 <0.01 11.15 <0.01 4.45 4.52 <0.01

Logperch 0.22 0.10 0.11 0.11 0.09 10.26 <0.01 4.10 4.16 <0.01 10.48 0.10 4.20 4.27 0.09

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 <0.01 <0.01 <0.01

Rainbow smelt 0.51 0.22 0.25 0.25 0.22 74.33 <0.01 29.68 30.13 <0.01 74.84 0.22 29.93 30.38 0.22

Salmon <0.01 <0.01 <0.01 <0.01 <0.01 6.16 <0.01 2.46 2.50 <0.01 6.16 <0.01 2.46 2.50 <0.01

Sculpins <0.01 <0.01 <0.01 <0.01 <0.01 3.50 <0.01 1.40 1.42 <0.01 3.50 <0.01 1.40 1.42 <0.01

Shiners 0.57 0.25 0.28 0.28 0.24 132.24 <0.01 52.80 53.60 <0.01 132.81 0.25 53.09 53.88 0.24

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 <0.01 <0.01 <0.01

Smelts 4.07 1.76 2.01 2.02 1.75 150.69 <0.01 60.17 61.08 <0.01 154.75 1.76 62.18 63.10 1.75

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 <0.01 <0.01 <0.01

Impingement Entrainment I&E
March 28, 2011 C-16

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table C-12: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Great Lakes (million

individuals per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality, continued

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

Suckers <0.01 <0.01 <0.01 <0.01 <0.01 2.31 <0.01 0.92 0.94 <0.01 2.32 <0.01 0.93 0.94 <0.01

Sunfish <0.01 <0.01 <0.01 <0.01 <0.01 7.03 <0.01 2.81 2.85 <0.01 7.03 <0.01 2.81 2.85 <0.01

Threespine

stickleback 0.07 0.03 0.04 0.04 0.03 0.69 <0.01 0.28 0.28 <0.01 0.76 0.03 0.31 0.32 0.03

Walleye <0.01 <0.01 <0.01 <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 bass 0.05 0.02 0.03 0.03 0.02 38.35 <0.01 15.31 15.54 <0.01 38.40 0.02 15.34 15.57 0.02

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 <0.01 <0.01 <0.01

Whitefish 0.10 0.04 0.05 0.05 0.04 0.17 <0.01 0.07 0.07 <0.01 0.27 0.04 0.12 0.12 0.04

Yellow perch 0.71 0.31 0.35 0.35 0.31 30.26 <0.01 12.08 12.27 <0.01 30.98 0.31 12.44 12.62 0.31

Total (all species) 50.99 22.09 25.22 25.28 21.90 85,976.38 <0.01 34,331.75 34,850.27 <0.01 86,027.37 22.09 34,356.97 34,875.54 21.90

Scenarios: B = Baseline I&E Mortality losses. 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Option 4 (I for Facilities > 50 MGD). Values

for all options reflect reductions in losses.

Impingement Entrainment I&E
March 28, 2011 C-17

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

C.7 Inland

Table C-13: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Inland Region (million

A1Es per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

All forage species 549.42 459.64 531.05 536.22 448.42 164.29 <0.01 134.24 140.41 <0.01 713.71 459.64 665.29 676.63 448.42

All harvested species 34.17 28.59 33.03 33.35 27.89 131.61 <0.01 107.54 112.48 <0.01 165.78 28.59 140.57 145.83 27.89

American shad 0.05 0.04 0.05 0.05 0.04 <0.01 <0.01 <0.01 <0.01 <0.01 0.05 0.04 0.05 0.05 0.04

Black bullhead 0.18 0.15 0.18 0.18 0.15 <0.01 <0.01 <0.01 <0.01 <0.01 0.19 0.15 0.18 0.18 0.15

Black crappie 0.07 0.06 0.06 0.06 0.05 0.50 <0.01 0.41 0.43 <0.01 0.57 0.06 0.47 0.49 0.05

Bluegill 2.11 1.76 2.04 2.06 1.72 0.18 <0.01 0.15 0.15 <0.01 2.29 1.76 2.19 2.21 1.72

Brown bullhead 0.03 0.02 0.03 0.03 0.02 0.04 <0.01 0.04 0.04 <0.01 0.07 0.02 0.06 0.06 0.02

Bullheads 0.02 0.02 0.02 0.02 0.02 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 0.02 0.03 0.03 0.02

Channel catfish 1.63 1.36 1.58 1.59 1.33 1.01 <0.01 0.82 0.86 <0.01 2.64 1.36 2.40 2.45 1.33

Crappie 0.11 0.09 0.11 0.11 0.09 1.40 <0.01 1.14 1.20 <0.01 1.51 0.09 1.25 1.31 0.09

Freshwater drum 1.19 1.00 1.15 1.16 0.97 6.31 <0.01 5.16 5.40 <0.01 7.51 1.00 6.31 6.56 0.97

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 <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 <0.01 <0.01 <0.01

Fish (other) <0.01 <0.01 <0.01 <0.01 <0.01 0.06 <0.01 0.05 0.05 <0.01 0.07 <0.01 0.06 0.06 <0.01

Rainbow smelt 0.14 0.12 0.13 0.14 0.11 0.21 <0.01 0.17 0.18 <0.01 0.35 0.12 0.30 0.31 0.11

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 <0.01 <0.01 <0.01

Sauger 0.10 0.08 0.09 0.09 0.08 1.75 <0.01 1.43 1.49 <0.01 1.84 0.08 1.52 1.59 0.08

Smallmouth bass 0.24 0.20 0.23 0.23 0.19 3.70 <0.01 3.03 3.16 <0.01 3.94 0.20 3.25 3.39 0.19

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 <0.01 <0.01 <0.01

Striped bass 0.16 0.13 0.15 0.15 0.13 <0.01 <0.01 <0.01 <0.01 <0.01 0.16 0.13 0.15 0.15 0.13

Sturgeons <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 0.02 0.02 <0.01 0.03 <0.01 0.02 0.02 <0.01

Sunfish 19.92 16.66 19.25 19.44 16.25 110.06 <0.01 89.93 94.07 <0.01 129.98 16.66 109.18 113.51 16.25

Walleye 0.06 0.05 0.05 0.05 0.05 0.68 <0.01 0.56 0.58 <0.01 0.74 0.05 0.61 0.64 0.05

White bass 2.35 1.97 2.27 2.29 1.92 2.66 <0.01 2.18 2.28 <0.01 5.01 1.97 4.45 4.57 1.92

White perch 2.58 2.16 2.49 2.52 2.10 0.55 <0.01 0.45 0.47 <0.01 3.13 2.16 2.94 2.99 2.10

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 <0.01 <0.01 <0.01

Yellow perch 3.24 2.71 3.13 3.16 2.64 2.44 <0.01 1.99 2.08 <0.01 5.67 2.71 5.12 5.24 2.64

Total (all species) 583.59 488.22 564.08 569.57 476.31 295.89 <0.01 241.78 252.90 <0.01 879.49 488.22 805.86 822.46 476.31

Scenarios: B = Baseline I&E Mortality losses, 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Option 4 (I for

Facilities > 50 MGD)

I&EEntrainmentImpingement
March 28, 2011 C-18

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table C-14: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Inland Region (million

individuals per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

Alewife 42.79 17.90 20.68 20.88 17.46 1.29 <0.01 0.53 0.55 <0.01 44.07 17.90 21.20 21.43 17.46

American shad 19.04 7.96 9.20 9.29 7.77 <0.01 <0.01 <0.01 <0.01 <0.01 19.04 7.96 9.20 9.29 7.77

Bay anchovy 0.03 0.01 0.01 0.02 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 0.01 0.01 0.02 0.01

Bigmouth buffalo 0.04 0.02 0.02 0.02 0.02 5.38 <0.01 2.20 2.30 <0.01 5.42 0.02 2.22 2.32 0.02

Black bullhead 0.34 0.14 0.16 0.16 0.14 0.04 <0.01 0.02 0.02 <0.01 0.38 0.14 0.18 0.18 0.14

Black crappie 0.35 0.14 0.17 0.17 0.14 24.81 <0.01 10.14 10.60 <0.01 25.16 0.14 10.30 10.77 0.14

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 <0.01 <0.01 <0.01

Blueback herring 185.69 77.67 89.74 90.62 75.78 1,750.15 <0.01 715.03 747.92 <0.01 1,935.85 77.67 804.77 838.53 75.78

Bluegill 35.57 14.88 17.19 17.36 14.51 48.04 <0.01 19.63 20.53 <0.01 83.61 14.88 36.82 37.89 14.51

Bluntnose

minnow 0.15 0.06 0.07 0.07 0.06 4,918.57 <0.01 2,009.49 2,101.92 <0.01 4,918.72 0.06 2,009.57 2,101.99 0.06

Brown bullhead 0.05 0.02 0.02 0.02 0.02 0.35 <0.01 0.14 0.15 <0.01 0.40 0.02 0.17 0.17 0.02

Bullheads 0.04 0.02 0.02 0.02 0.02 3.68 <0.01 1.50 1.57 <0.01 3.72 0.02 1.52 1.59 0.02

Burbot <0.01 <0.01 <0.01 <0.01 <0.01 16.04 <0.01 6.55 6.85 <0.01 16.04 <0.01 6.55 6.86 <0.01

Carp 0.37 0.15 0.18 0.18 0.15 4,209.21 <0.01 1,719.68 1,798.78 <0.01 4,209.58 0.15 1,719.86 1,798.96 0.15

Channel catfish 2.03 0.85 0.98 0.99 0.83 209.76 <0.01 85.70 89.64 <0.01 211.80 0.85 86.68 90.63 0.83

Crappie 0.59 0.25 0.29 0.29 0.24 67.69 <0.01 27.66 28.93 <0.01 68.28 0.25 27.94 29.22 0.24

Darters 0.99 0.42 0.48 0.49 0.41 161.74 <0.01 66.08 69.12 <0.01 162.74 0.42 66.56 69.60 0.41

Emerald shiner 3.99 1.67 1.93 1.95 1.63 724.99 <0.01 296.20 309.82 <0.01 728.98 1.67 298.12 311.77 1.63

Fish (other) 83.22 34.81 40.22 40.61 33.96 68,076.66 <0.01 27,812.84 29,092.11 <0.01 68,159.89 34.81 27,853.06 29,132.72 33.96

Freshwater drum 4.58 1.91 2.21 2.23 1.87 3,010.39 <0.01 1,229.90 1,286.47 <0.01 3,014.97 1.91 1,232.11 1,288.70 1.87

Gizzard shad 311.11 130.14 150.36 151.82 126.96 19,070.18 <0.01 7,791.16 8,149.52 <0.01 19,381.30 130.14 7,941.52 8,301.34 126.96

Gobies <0.01 <0.01 <0.01 <0.01 <0.01 81.15 <0.01 33.15 34.68 <0.01 81.15 <0.01 33.15 34.68 <0.01

Golden redhorse 0.07 0.03 0.03 0.03 0.03 2.86 <0.01 1.17 1.22 <0.01 2.92 0.03 1.20 1.25 0.03

Hogchoker 0.03 0.01 0.01 0.01 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 0.01 0.01 0.01 0.01

Logperch 1.00 0.42 0.48 0.49 0.41 32.30 <0.01 13.20 13.80 <0.01 33.30 0.42 13.68 14.29 0.41

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 <0.01 <0.01 <0.01

Muskellunge 0.02 <0.01 0.01 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 <0.01 0.01 0.01 <0.01

Rainbow smelt 0.19 0.08 0.09 0.09 0.08 59.23 <0.01 24.20 25.31 <0.01 59.43 0.08 24.29 25.41 0.08

River carpsucker 0.03 0.01 0.02 0.02 0.01 5.15 <0.01 2.10 2.20 <0.01 5.18 0.01 2.12 2.22 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 <0.01 <0.01 <0.01

Sauger 0.23 0.09 0.11 0.11 0.09 314.24 <0.01 128.39 134.29 <0.01 314.47 0.09 128.49 134.40 0.09

Impingement Entrainment I&E
March 28, 2011 C-19

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table C-14: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Inland Region (million

individuals per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality, continued

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

Shiners 3.41 1.43 1.65 1.66 1.39 296.49 <0.01 121.13 126.70 <0.01 299.90 1.43 122.78 128.37 1.39

Silversides 0.04 0.02 0.02 0.02 0.02 46.52 <0.01 19.00 19.88 <0.01 46.56 0.02 19.02 19.90 0.02

Skipjack herring 1.52 0.64 0.74 0.74 0.62 0.54 <0.01 0.22 0.23 <0.01 2.06 0.64 0.96 0.97 0.62

Smallmouth bass 0.14 0.06 0.07 0.07 0.06 54.51 <0.01 22.27 23.30 <0.01 54.65 0.06 22.34 23.36 0.06

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 <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 <0.01 <0.01 <0.01

Striped bass 1.64 0.69 0.79 0.80 0.67 <0.01 <0.01 <0.01 <0.01 <0.01 1.64 0.69 0.79 0.80 0.67

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 <0.01 <0.01 <0.01

Sturgeons <0.01 <0.01 <0.01 <0.01 <0.01 1.46 <0.01 0.59 0.62 <0.01 1.46 <0.01 0.60 0.62 <0.01

Suckers 0.16 0.07 0.08 0.08 0.07 4,342.48 <0.01 1,774.13 1,855.73 <0.01 4,342.64 0.07 1,774.21 1,855.81 0.07

Sunfish 6.38 2.67 3.08 3.11 2.60 648.07 <0.01 264.77 276.95 <0.01 654.45 2.67 267.85 280.06 2.60

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 <0.01 <0.01 <0.01

Walleye 0.15 0.06 0.07 0.07 0.06 169.80 <0.01 69.37 72.56 <0.01 169.95 0.06 69.45 72.64 0.06

White bass 2.63 1.10 1.27 1.28 1.07 1,067.79 <0.01 436.25 456.31 <0.01 1,070.42 1.10 437.52 457.60 1.07

White perch 3.87 1.62 1.87 1.89 1.58 660.65 <0.01 269.91 282.33 <0.01 664.53 1.62 271.78 284.22 1.58

Whitefish <0.01 <0.01 <0.01 <0.01 <0.01 0.75 <0.01 0.31 0.32 <0.01 0.75 <0.01 0.31 0.32 <0.01

Yellow Perch 8.88 3.71 4.29 4.33 3.62 1,100.04 <0.01 449.42 470.10 <0.01 1,108.92 3.71 453.71 474.43 3.62

Total (all

species) 721.46 301.78 348.67 352.06 294.41 111,183.92 <0.01 45,424.39 47,513.71 <0.01 111,905.38 301.78 45,773.07 47,865.77 294.41

Scenarios: B = Baseline I&E Mortality losses. 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Option 4 (I for Facilities > 50 MGD). Values for all options reflect

reductions in losses.

Impingement Entrainment I&E
March 28, 2011 C-20

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

C.8 National Estimates

Table C-15: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) Nationally (million A1Es per year),

and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

All forage species 634.40 525.66 611.97 617.31 514.11 1020.37 <0.01 900.67 918.13 <0.01 1654.78 525.66 1512.64 1535.44 514.11

All harvested species 113.00 89.31 110.56 111.04 88.31 421.14 <0.01 358.35 367.07 <0.01 534.15 89.31 468.91 478.11 88.31

Alewife 0.04 0.03 0.04 0.04 0.03 <0.01 <0.01 <0.01 <0.01 <0.01 0.05 0.03 0.04 0.05 0.03

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 <0.01 <0.01 <0.01

American shad 0.05 0.04 0.05 0.05 0.04 <0.01 <0.01 <0.01 <0.01 <0.01 0.06 0.04 0.06 0.06 0.04

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 0.01 0.01 <0.01

Atlantic croaker 1.97 1.50 1.95 1.95 1.49 21.59 <0.01 19.77 20.03 <0.01 23.56 1.50 21.72 21.98 1.49

Atlantic herring <0.01 <0.01 <0.01 <0.01 <0.01 0.12 <0.01 0.10 0.11 <0.01 0.13 <0.01 0.11 0.11 <0.01

Atlantic mackerel <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 0.02 0.02 <0.01 0.02 <0.01 0.02 0.02 <0.01

Atlantic menhaden 21.97 16.73 21.40 21.48 16.71 3.23 <0.01 2.95 2.99 <0.01 25.20 16.73 24.35 24.47 16.71

Black bullhead 0.18 0.15 0.18 0.18 0.15 <0.01 <0.01 <0.01 <0.01 <0.01 0.19 0.15 0.18 0.18 0.15

Black crappie 0.07 0.06 0.06 0.06 0.05 0.50 <0.01 0.41 0.43 <0.01 0.57 0.06 0.47 0.49 0.05

Black drum 0.01 0.01 0.01 0.01 0.01 5.93 <0.01 4.01 4.02 <0.01 5.94 0.01 4.02 4.03 0.01

Blue crab 7.55 5.72 7.41 7.42 5.68 127.20 <0.01 111.94 113.23 <0.01 134.75 5.72 119.34 120.65 5.68

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 <0.01 <0.01 <0.01

Bluegill 2.11 1.76 2.04 2.06 1.72 0.18 <0.01 0.15 0.15 <0.01 2.29 1.76 2.19 2.21 1.72

Brown bullhead 0.03 0.03 0.03 0.03 0.03 0.06 <0.01 0.05 0.05 <0.01 0.09 0.03 0.08 0.08 0.03

Bullheads 0.02 0.02 0.02 0.02 0.02 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 0.02 0.03 0.03 0.02

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 <0.01 <0.01 <0.01

Cabezon <0.01 <0.01 <0.01 <0.01 <0.01 0.06 <0.01 0.05 0.05 <0.01 0.06 <0.01 0.05 0.05 <0.01

California halibut <0.01 <0.01 <0.01 <0.01 <0.01 0.23 <0.01 0.20 0.21 <0.01 0.23 <0.01 0.20 0.21 <0.01

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 <0.01 <0.01 <0.01

Channel catfish 1.65 1.38 1.60 1.61 1.35 1.01 <0.01 0.82 0.86 <0.01 2.66 1.38 2.42 2.48 1.35

Crabs (other) 0.09 0.07 0.09 0.09 0.07 7.82 <0.01 6.66 6.97 <0.01 7.91 0.07 6.75 7.06 0.07

Sea Basses <0.01 <0.01 <0.01 <0.01 <0.01 2.83 <0.01 2.41 2.52 <0.01 2.83 <0.01 2.41 2.53 <0.01

Shrimp (other) <0.01 <0.01 <0.01 <0.01 <0.01 0.63 <0.01 0.53 0.56 <0.01 0.63 <0.01 0.54 0.57 <0.01

Crappie 0.11 0.09 0.11 0.11 0.09 1.42 <0.01 1.16 1.21 <0.01 1.53 0.09 1.27 1.32 0.09

Cunner <0.01 <0.01 <0.01 <0.01 <0.01 4.26 <0.01 3.47 3.64 <0.01 4.26 <0.01 3.47 3.64 <0.01

I&EEntrainmentImpingement
March 28, 2011 C-21

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table C-15: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) Nationally (million A1Es per year),

and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality, continued

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

Drums and croakers 0.07 0.05 0.07 0.07 0.05 1.03 <0.01 0.86 0.87 <0.01 1.10 0.05 0.93 0.94 0.05

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 <0.01 <0.01 <0.01

Flounders 0.01 0.01 0.01 0.01 0.01 0.10 <0.01 0.08 0.09 <0.01 0.11 0.01 0.10 0.10 0.01

Freshwater drum 1.21 1.01 1.17 1.18 0.99 6.36 <0.01 5.20 5.44 <0.01 7.57 1.01 6.37 6.62 0.99

Leatherjacket 0.69 0.53 0.68 0.69 0.52 0.03 <0.01 0.02 0.02 <0.01 0.72 0.53 0.71 0.71 0.52

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 <0.01 <0.01 <0.01

Menhadens 4.95 3.79 4.92 4.92 3.76 0.05 <0.01 0.04 0.04 <0.01 5.01 3.79 4.96 4.96 3.76

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 <0.01 <0.01 <0.01

Fish (other) 2.87 2.20 2.82 2.83 2.19 11.04 <0.01 10.06 10.19 <0.01 13.90 2.20 12.88 13.02 2.19

Northern anchovy 0.34 0.30 0.34 0.34 0.29 0.03 <0.01 0.03 0.03 <0.01 0.38 0.30 0.37 0.37 0.29

Pinfish 0.03 0.02 0.03 0.03 0.02 1.08 <0.01 0.73 0.73 <0.01 1.11 0.02 0.76 0.76 0.02

Pink shrimp 21.44 16.42 21.29 21.31 16.30 13.40 <0.01 9.07 9.09 <0.01 34.84 16.42 30.36 30.40 16.30

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 <0.01 <0.01 <0.01

Rainbow smelt 0.51 0.44 0.50 0.50 0.43 0.28 <0.01 0.22 0.23 <0.01 0.78 0.44 0.72 0.73 0.43

Red drum 0.09 0.07 0.09 0.09 0.07 0.01 <0.01 <0.01 <0.01 <0.01 0.11 0.07 0.10 0.10 0.07

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 <0.01 <0.01 <0.01

Rockfishes 0.02 0.01 0.02 0.02 0.01 6.33 <0.01 5.39 5.64 <0.01 6.34 0.01 5.41 5.66 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 <0.01 <0.01 <0.01

Sauger 0.10 0.08 0.09 0.09 0.08 1.75 <0.01 1.43 1.49 <0.01 1.84 0.08 1.52 1.59 0.08

Sculpins 0.02 0.02 0.02 0.02 0.02 2.39 <0.01 1.96 2.06 <0.01 2.41 0.02 1.98 2.08 0.02

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 <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 <0.01 <0.01 <0.01

Searobin 0.94 0.72 0.93 0.93 0.71 0.38 <0.01 0.26 0.26 <0.01 1.31 0.72 1.19 1.19 0.71

Sheepshead <0.01 <0.01 <0.01 <0.01 <0.01 0.03 <0.01 0.02 0.02 <0.01 0.04 <0.01 0.02 0.02 <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 <0.01 <0.01 <0.01

Silver perch 0.56 0.39 0.52 0.52 0.39 5.11 <0.01 3.46 3.47 <0.01 5.68 0.39 3.98 3.99 0.39

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 <0.01 <0.01 <0.01

Impingement Entrainment I&E
March 28, 2011 C-22

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table C-15: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) Nationally (million A1Es per year),

and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality, continued

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

Smallmouth bass 0.24 0.20 0.23 0.23 0.19 3.70 <0.01 3.03 3.16 <0.01 3.94 0.20 3.26 3.40 0.19

Smelts 4.50 3.90 4.45 4.46 3.87 0.02 <0.01 0.02 0.02 <0.01 4.52 3.90 4.47 4.48 3.87

Spot 3.52 2.66 3.42 3.43 2.66 35.34 <0.01 32.33 32.75 <0.01 38.86 2.66 35.75 36.18 2.66

Spotted seatrout 1.26 0.97 1.26 1.26 0.96 0.15 <0.01 0.10 0.10 <0.01 1.42 0.97 1.36 1.36 0.96

Stone crab 0.19 0.14 0.19 0.19 0.14 0.41 <0.01 0.28 0.28 <0.01 0.60 0.14 0.47 0.47 0.14

Striped bass 0.17 0.14 0.16 0.16 0.14 1.40 <0.01 1.28 1.30 <0.01 1.57 0.14 1.44 1.46 0.14

Striped mullet 0.37 0.28 0.37 0.37 0.28 2.62 <0.01 1.77 1.78 <0.01 2.99 0.28 2.14 2.14 0.28

Sturgeons <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 0.02 0.02 <0.01 0.03 <0.01 0.02 0.02 <0.01

Summer flounder 0.02 0.02 0.02 0.02 0.02 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.02 0.02 0.02 0.02

Sunfish 19.95 16.69 19.29 19.47 16.29 111.25 <0.01 90.88 95.03 <0.01 131.20 16.69 110.17 114.50 16.29

Surfperches 0.11 0.10 0.11 0.11 0.10 <0.01 <0.01 <0.01 <0.01 <0.01 0.11 0.10 0.11 0.11 0.10

Tautog <0.01 <0.01 <0.01 <0.01 <0.01 0.11 <0.01 0.09 0.10 <0.01 0.11 <0.01 0.09 0.10 <0.01

Walleye 0.06 0.05 0.05 0.05 0.05 0.68 <0.01 0.56 0.58 <0.01 0.74 0.05 0.61 0.64 0.05

Weakfish 1.44 1.10 1.40 1.41 1.10 2.71 <0.01 2.48 2.51 <0.01 4.14 1.10 3.88 3.92 1.10

White bass 2.40 2.01 2.32 2.34 1.96 2.76 <0.01 2.25 2.35 <0.01 5.16 2.01 4.57 4.70 1.96

White perch 5.24 4.18 5.08 5.12 4.13 24.43 <0.01 22.32 22.62 <0.01 29.67 4.18 27.40 27.74 4.13

Whitefish 0.23 0.20 0.23 0.23 0.20 <0.01 <0.01 <0.01 <0.01 <0.01 0.23 0.20 0.23 0.23 0.20

Windowpane <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 0.02 0.02 <0.01 0.03 <0.01 0.02 0.02 <0.01

Winter flounder 0.04 0.03 0.04 0.04 0.03 6.46 <0.01 5.28 5.53 <0.01 6.50 0.03 5.32 5.57 0.03

Yellow perch 3.50 2.93 3.39 3.42 2.86 2.50 <0.01 2.05 2.14 <0.01 6.00 2.93 5.43 5.55 2.86

Total (all species) 747.40 614.97 722.53 728.35 602.42 1441.52 <0.01 1259.02 1285.20 <0.01 2188.92 614.97 1981.55 2013.55 602.42

Impingement Entrainment I&E

Scenarios: B = Baseline I&E Mortality losses, 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Option 4 (I for Facilities > 50 MGD)
March 28, 2011 C-23

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation
March 28, 2011 C-24

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table C-16: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) Nationally (million individuals per

year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

Alewife 72.13 30.59 35.19 35.42 30.04 38,112.03 <0.01 15,219.17 15,449.11 <0.01 38,184.16 30.59 15,254.35 15,484.53 30.04

American plaice <0.01 <0.01 <0.01 <0.01 <0.01 199.21 <0.01 81.20 85.19 <0.01 199.21 <0.01 81.20 85.19 <0.01

American sand

lance 0.16 0.06 0.08 0.08 0.06 1,469.03 <0.01 598.82 628.20 <0.01 1,469.20 0.06 598.90 628.28 0.06

American shad 19.09 7.98 9.23 9.32 7.79 67.08 <0.01 30.72 31.11 <0.01 86.17 7.98 39.94 40.43 7.79

Atlantic cod <0.01 <0.01 <0.01 <0.01 <0.01 117.38 <0.01 47.85 50.19 <0.01 117.38 <0.01 47.85 50.19 <0.01

Atlantic croaker 17.73 6.79 8.79 8.80 6.74 851.39 <0.01 370.43 374.59 <0.01 869.12 6.79 379.21 383.39 6.74

Atlantic herring 0.04 0.01 0.02 0.02 0.01 87.31 <0.01 35.59 37.34 <0.01 87.34 0.01 35.61 37.35 0.01

Atlantic

mackerel <0.01 <0.01 <0.01 <0.01 <0.01 7,067.69 <0.01 2,880.99 3,022.33 <0.01 7,067.69 <0.01 2,880.99 3,022.33 <0.01

Atlantic

menhaden 71.28 27.14 34.72 34.84 27.11 4,486.26 <0.01 1,836.37 1,921.31 <0.01 4,557.54 27.14 1,871.09 1,956.15 27.11

Atlantic

silverside 1.66 0.62 0.80 0.81 0.62 206.73 <0.01 89.81 92.38 <0.01 208.39 0.62 90.61 93.19 0.62

Atlantic tomcod 0.14 0.05 0.07 0.07 0.05 6.28 <0.01 2.56 2.68 <0.01 6.42 0.05 2.63 2.75 0.05

Bay anchovy 43.71 15.00 19.79 19.82 14.98 457,647.92 <0.01 170,620.21 172,563.84 <0.01 457,691.63 15.00 170,640.00 172,583.66 14.98

Bigmouth

buffalo 0.04 0.02 0.02 0.02 0.02 5.38 <0.01 2.20 2.30 <0.01 5.42 0.02 2.22 2.32 0.02

Black bullhead 0.34 0.14 0.16 0.17 0.14 0.04 <0.01 0.02 0.02 <0.01 0.38 0.14 0.18 0.18 0.14

Black crappie 0.35 0.15 0.17 0.17 0.14 24.81 <0.01 10.14 10.60 <0.01 25.16 0.15 10.30 10.77 0.14

Black drum 0.03 0.01 0.01 0.01 0.01 96,328.24 <0.01 32,580.73 32,660.81 <0.01 96,328.27 0.01 32,580.75 32,660.83 0.01

Blennies <0.01 <0.01 <0.01 <0.01 <0.01 914.88 <0.01 389.87 407.84 <0.01 914.88 <0.01 389.87 407.84 <0.01

Blue crab 15.03 5.69 7.37 7.38 5.66 3,677.57 <0.01 1,650.35 1,670.46 <0.01 3,692.60 5.69 1,657.73 1,677.85 5.66

Blueback herring 186.97 78.16 90.37 91.24 76.26 1,774.42 <0.01 726.14 759.17 <0.01 1,961.39 78.16 816.51 850.41 76.26

Bluefish 0.03 0.01 0.01 0.01 0.01 0.06 <0.01 0.02 0.02 <0.01 0.09 0.01 0.04 0.04 0.01

Bluegill 35.57 14.88 17.19 17.36 14.52 48.04 <0.01 19.63 20.53 <0.01 83.61 14.88 36.82 37.89 14.52

Bluntnose

minnow 0.16 0.07 0.08 0.08 0.07 4,931.58 <0.01 2,014.69 2,107.19 <0.01 4,931.75 0.07 2,014.77 2,107.27 0.07

Brown bullhead 0.06 0.02 0.03 0.03 0.02 0.46 <0.01 0.19 0.20 <0.01 0.52 0.02 0.22 0.23 0.02

Bullheads 0.04 0.02 0.02 0.02 0.02 3.68 <0.01 1.50 1.57 <0.01 3.72 0.02 1.52 1.59 0.02

Burbot <0.01 <0.01 <0.01 <0.01 <0.01 16.57 <0.01 6.76 7.07 <0.01 16.58 <0.01 6.77 7.07 <0.01

Butterfish <0.01 <0.01 <0.01 <0.01 <0.01 12.15 <0.01 4.95 5.20 <0.01 12.16 <0.01 4.96 5.20 <0.01

Cabezon <0.01 <0.01 <0.01 <0.01 <0.01 6.65 <0.01 2.83 2.96 <0.01 6.65 <0.01 2.83 2.96 <0.01

California

halibut <0.01 <0.01 <0.01 <0.01 <0.01 7.71 <0.01 3.29 3.44 <0.01 7.72 <0.01 3.29 3.44 <0.01

Impingement Entrainment I&E
March 28, 2011 C-25

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table C-16: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) Nationally (million individuals per

year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality, continued

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

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 <0.01 <0.01 <0.01

Carp 0.41 0.17 0.20 0.20 0.17 7,449.10 <0.01 3,013.42 3,112.06 <0.01 7,449.51 0.17 3,013.62 3,112.26 0.17

Chain pipefish 0.07 0.03 0.04 0.04 0.03 2.13 <0.01 0.72 0.72 <0.01 2.20 0.03 0.75 0.76 0.03

Channel catfish 2.06 0.86 1.00 1.01 0.84 209.96 <0.01 85.78 89.72 <0.01 212.02 0.86 86.77 90.73 0.84

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 <0.01 <0.01 <0.01

Crabs (other) 0.12 0.05 0.06 0.06 0.05 7,906.88 <0.01 3,363.37 3,506.02 <0.01 7,907.01 0.05 3,363.43 3,506.08 0.05

Crappie 0.60 0.25 0.29 0.29 0.24 68.59 <0.01 28.01 29.29 <0.01 69.19 0.25 28.30 29.58 0.24

Cunner <0.01 <0.01 <0.01 <0.01 <0.01 29,170.94 <0.01 11,890.91 12,474.26 <0.01 29,170.95 <0.01 11,890.91 12,474.27 <0.01

Darters 1.01 0.42 0.49 0.49 0.41 164.61 <0.01 67.23 70.28 <0.01 165.62 0.42 67.71 70.77 0.41

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 <0.01 <0.01 <0.01

Drums and

croakers 0.63 0.25 0.30 0.30 0.24 3,292.06 <0.01 1,381.20 1,400.82 <0.01 3,292.68 0.25 1,381.50 1,401.11 0.24

Dungeness crab <0.01 <0.01 <0.01 <0.01 <0.01 0.09 <0.01 0.04 0.04 <0.01 0.09 <0.01 0.04 0.04 <0.01

Emerald shiner 4.39 1.84 2.13 2.14 1.80 772.49 <0.01 315.16 329.07 <0.01 776.88 1.84 317.29 331.22 1.80

Fish (other) 98.00 40.36 47.39 47.80 39.49 123,797.72 <0.01 49,732.40 51,319.67 <0.01 123,895.72 40.36 49,779.79 51,367.47 39.49

Flounders 0.01 <0.01 <0.01 <0.01 <0.01 319.23 <0.01 136.04 142.31 <0.01 319.24 <0.01 136.04 142.31 <0.01

Fourbeard

rockling <0.01 <0.01 <0.01 <0.01 <0.01 464.23 <0.01 189.23 198.52 <0.01 464.23 <0.01 189.23 198.52 <0.01

Freshwater drum 4.65 1.94 2.25 2.27 1.90 3,231.60 <0.01 1,318.23 1,376.14 <0.01 3,236.24 1.94 1,320.48 1,378.40 1.90

Gizzard shad 326.39 136.74 157.91 159.39 133.51 22,916.70 <0.01 9,327.13 9,708.69 <0.01 23,243.09 136.74 9,485.04 9,868.08 133.51

Gobies 0.14 0.05 0.07 0.07 0.05 8,788.33 <0.01 3,416.01 3,454.69 <0.01 8,788.47 0.05 3,416.08 3,454.76 0.05

Golden redhorse 0.07 0.03 0.03 0.03 0.03 2.86 <0.01 1.17 1.22 <0.01 2.92 0.03 1.20 1.25 0.03

Grubby 0.02 <0.01 0.01 0.01 <0.01 431.10 <0.01 175.73 184.35 <0.01 431.12 <0.01 175.74 184.36 <0.01

Gulf killifish 0.04 0.01 0.02 0.02 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.04 0.01 0.02 0.02 0.01

Herrings 0.07 0.03 0.03 0.03 0.03 37.37 <0.01 15.63 16.21 <0.01 37.44 0.03 15.66 16.24 0.03

Hogchoker 0.74 0.28 0.36 0.36 0.28 26,718.51 <0.01 12,183.16 12,346.27 <0.01 26,719.25 0.28 12,183.52 12,346.63 0.28

Leatherjacket 0.95 0.36 0.47 0.47 0.36 794.02 <0.01 268.56 269.22 <0.01 794.97 0.36 269.03 269.69 0.36

Logperch 1.22 0.51 0.59 0.60 0.50 42.56 <0.01 17.29 17.96 <0.01 43.77 0.51 17.88 18.56 0.50

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 <0.01 <0.01 <0.01

Lumpfish <0.01 <0.01 <0.01 <0.01 <0.01 44.89 <0.01 18.30 19.20 <0.01 44.89 <0.01 18.30 19.20 <0.01

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 <0.01 <0.01 <0.01

Menhadens 16.06 6.15 7.98 7.98 6.10 269.24 <0.01 91.08 91.30 <0.01 285.30 6.15 99.05 99.28 6.10

Muskellunge 0.02 <0.01 0.01 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 <0.01 0.01 0.01 <0.01

Northern

anchovy 0.86 0.38 0.42 0.43 0.37 826.63 <0.01 352.26 368.50 <0.01 827.49 0.38 352.68 368.93 0.37

Impingement Entrainment I&E
March 28, 2011 C-26

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table C-16: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) Nationally (million individuals per

year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality, continued

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

Northern

pipefish 0.04 0.01 0.02 0.02 0.01 11.79 <0.01 5.34 5.43 <0.01 11.83 0.01 5.36 5.45 0.01

Pacific herring <0.01 <0.01 <0.01 <0.01 <0.01 36.16 <0.01 15.41 16.12 <0.01 36.17 <0.01 15.41 16.12 <0.01

Pinfish 0.12 0.05 0.06 0.06 0.04 179.13 <0.01 66.21 66.35 <0.01 179.25 0.05 66.27 66.40 0.04

Pink shrimp 43.73 16.74 21.71 21.73 16.62 126.32 <0.01 42.73 42.83 <0.01 170.05 16.74 64.44 64.56 16.62

Pollock <0.01 <0.01 <0.01 <0.01 <0.01 3.46 <0.01 1.41 1.48 <0.01 3.47 <0.01 1.41 1.48 <0.01

Radiated shanny <0.01 <0.01 <0.01 <0.01 <0.01 110.36 <0.01 44.99 47.19 <0.01 110.36 <0.01 44.99 47.19 <0.01

Rainbow smelt 0.76 0.32 0.37 0.37 0.32 151.21 <0.01 61.07 62.99 <0.01 151.97 0.32 61.45 63.36 0.32

Red drum 0.18 0.07 0.09 0.09 0.07 1.10 <0.01 0.37 0.37 <0.01 1.27 0.07 0.46 0.46 0.07

Red hake 0.08 0.03 0.04 0.04 0.03 <0.01 <0.01 <0.01 <0.01 <0.01 0.08 0.03 0.04 0.04 0.03

River carpsucker 0.03 0.01 0.02 0.02 0.01 5.15 <0.01 2.10 2.20 <0.01 5.18 0.01 2.12 2.22 0.01

Rock gunnel <0.01 <0.01 <0.01 <0.01 <0.01 395.87 <0.01 161.37 169.29 <0.01 395.88 <0.01 161.37 169.29 <0.01

Rockfishes 0.03 0.01 0.01 0.01 0.01 63.96 <0.01 27.26 28.51 <0.01 63.99 0.01 27.27 28.53 0.01

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 <0.01 <0.01 <0.01

Salmon <0.01 <0.01 <0.01 <0.01 <0.01 6.16 <0.01 2.46 2.50 <0.01 6.16 <0.01 2.46 2.50 <0.01

Sauger 0.23 0.09 0.11 0.11 0.09 314.24 <0.01 128.39 134.29 <0.01 314.47 0.09 128.49 134.40 0.09

Scaled sardine 0.35 0.13 0.17 0.17 0.13 2,962.36 <0.01 1,001.95 1,004.41 <0.01 2,962.72 0.13 1,002.12 1,004.59 0.13

Sculpins 0.02 0.01 0.01 0.01 <0.01 270.10 <0.01 110.96 116.30 <0.01 270.13 0.01 110.97 116.31 <0.01

Scup <0.01 <0.01 <0.01 <0.01 <0.01 16.64 <0.01 6.78 7.12 <0.01 16.65 <0.01 6.79 7.12 <0.01

Sea Basses <0.01 <0.01 <0.01 <0.01 <0.01 13.24 <0.01 5.64 5.90 <0.01 13.24 <0.01 5.64 5.90 <0.01

Seaboard goby 0.02 <0.01 <0.01 <0.01 <0.01 16,071.16 <0.01 7,239.43 7,367.13 <0.01 16,071.18 <0.01 7,239.44 7,367.14 <0.01

Searobin 1.18 0.45 0.58 0.59 0.45 80.30 <0.01 27.96 28.24 <0.01 81.48 0.45 28.54 28.83 0.45

Sheepshead <0.01 <0.01 <0.01 <0.01 <0.01 382.88 <0.01 129.50 129.82 <0.01 382.88 <0.01 129.50 129.82 <0.01

Shiners 3.98 1.67 1.93 1.95 1.64 429.73 <0.01 174.39 180.77 <0.01 433.71 1.67 176.32 182.71 1.64

Shrimp (other) 8.93 2.82 3.81 3.81 2.82 1,469.73 <0.01 616.82 625.97 <0.01 1,478.66 2.82 620.63 629.78 2.82

Silver hake 0.05 0.02 0.03 0.03 0.02 568.71 <0.01 231.82 243.20 <0.01 568.76 0.02 231.85 243.22 0.02

Silver perch 0.91 0.32 0.42 0.42 0.32 88,985.72 <0.01 30,097.30 30,171.28 <0.01 88,986.63 0.32 30,097.72 30,171.70 0.32

Silversides 0.16 0.07 0.08 0.08 0.07 171.19 <0.01 72.23 75.51 <0.01 171.35 0.07 72.30 75.59 0.07

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 <0.01 <0.01 <0.01

Skipjack herring 1.52 0.64 0.74 0.74 0.62 0.54 <0.01 0.22 0.23 <0.01 2.06 0.64 0.96 0.97 0.62

Smallmouth bass 0.14 0.06 0.07 0.07 0.06 54.51 <0.01 22.27 23.30 <0.01 54.66 0.06 22.34 23.37 0.06

Impingement Entrainment I&E
March 28, 2011 C-27

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table C-16: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) Nationally (million individuals per

year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality, continued

Species B 1 2 3 4 B 1 2 3 4 B 1 2 3 4

Smelts 4.07 1.76 2.01 2.02 1.75 154.31 <0.01 61.72 62.70 <0.01 158.39 1.76 63.73 64.72 1.75

Spot 11.27 4.25 5.47 5.48 4.25 2,420.22 <0.01 1,016.05 1,018.92 <0.01 2,431.49 4.25 1,021.52 1,024.41 4.25

Spotted seatrout 1.21 0.46 0.60 0.60 0.46 5,373.31 <0.01 1,820.18 1,824.64 <0.01 5,374.51 0.46 1,820.77 1,825.24 0.46

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 <0.01 <0.01 <0.01

Stone crab 0.27 0.11 0.14 0.14 0.10 28,711.01 <0.01 9,710.82 9,734.68 <0.01 28,711.29 0.11 9,710.95 9,734.82 0.10

Striped bass 1.68 0.70 0.81 0.82 0.68 1,071.31 <0.01 490.20 496.62 <0.01 1,072.98 0.70 491.01 497.44 0.68

Striped killifish 0.32 0.12 0.16 0.16 0.12 0.06 <0.01 0.03 0.03 <0.01 0.38 0.12 0.18 0.18 0.12

Striped mullet 0.45 0.17 0.23 0.23 0.17 15.17 <0.01 5.13 5.14 <0.01 15.62 0.17 5.36 5.37 0.17

Sturgeons <0.01 <0.01 <0.01 <0.01 <0.01 1.46 <0.01 0.59 0.62 <0.01 1.46 <0.01 0.60 0.62 <0.01

Suckers 0.17 0.07 0.08 0.08 0.07 4,344.79 <0.01 1,775.05 1,856.67 <0.01 4,344.96 0.07 1,775.13 1,856.75 0.07

Summer

flounder 0.08 0.03 0.04 0.04 0.03 <0.01 <0.01 <0.01 <0.01 <0.01 0.08 0.03 0.04 0.04 0.03

Sunfish 6.40 2.67 3.09 3.12 2.61 655.10 <0.01 267.58 279.80 <0.01 661.50 2.67 270.67 282.92 2.61

Surfperches 0.13 0.06 0.06 0.06 0.06 <0.01 <0.01 <0.01 <0.01 <0.01 0.13 0.06 0.06 0.06 0.06

Tautog <0.01 <0.01 <0.01 <0.01 <0.01 29,299.93 <0.01 11,943.48 12,529.42 <0.01 29,299.94 <0.01 11,943.49 12,529.42 <0.01

Threespine

stickleback 0.11 0.05 0.06 0.06 0.05 0.78 <0.01 0.31 0.32 <0.01 0.89 0.05 0.37 0.37 0.05

Tidewater

silverside 0.30 0.11 0.15 0.15 0.11 34.36 <0.01 11.62 11.65 <0.01 34.66 0.11 11.77 11.80 0.11

Walleye 0.15 0.06 0.07 0.08 0.06 169.80 <0.01 69.37 72.56 <0.01 169.96 0.06 69.45 72.64 0.06

Weakfish 3.35 1.28 1.63 1.64 1.28 929.71 <0.01 404.38 414.14 <0.01 933.06 1.28 406.02 415.78 1.28

White bass 2.68 1.12 1.30 1.31 1.10 1,106.14 <0.01 451.56 471.86 <0.01 1,108.82 1.12 452.86 473.17 1.10

White perch 6.70 2.70 3.25 3.27 2.66 2,996.05 <0.01 1,339.29 1,365.37 <0.01 3,002.75 2.70 1,342.54 1,368.65 2.66

Whitefish 0.10 0.04 0.05 0.05 0.04 0.92 <0.01 0.37 0.39 <0.01 1.02 0.04 0.42 0.44 0.04

Windowpane 0.02 <0.01 0.01 0.01 <0.01 2,066.54 <0.01 842.38 883.71 <0.01 2,066.57 <0.01 842.39 883.72 <0.01

Winter flounder 0.15 0.06 0.08 0.08 0.06 6,780.09 <0.01 2,768.38 2,902.67 <0.01 6,780.24 0.06 2,768.46 2,902.75 0.06

Yellow perch 9.59 4.02 4.64 4.68 3.93 1,130.30 <0.01 461.51 482.36 <0.01 1,139.89 4.02 466.15 487.05 3.93

Total (all

species) 1,034.92 421.62 500.44 504.14 413.70 1,055,936.41 <0.01 400,351.83 407,417.58 <0.01 1,056,971.34 421.62 400,852.27 407,921.72 413.70

Scenarios: B = Baseline I&E Mortality losses. 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Option 4 (I for Facilities > 50 MGD). Values for all options reflect reductions in

losses.

Impingement Entrainment I&E
March 28, 2011 D-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Appendix D: Discounting Benefits

D.1 Introduction

Discounting refers to the economic conversion of future benefits and costs to their 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 because these techniques allow for the comparison of benefits and/or costs that occur in

different time periods.

For the benefits analysis of the regulatory options for the proposed Section 316(b) Rule, EPA’s

discounting and annualization methodology included three steps. First, EPA developed a time profile of

benefits to show when benefits occur. Second, the Agency calculated the total discounted value of the

benefits as of the year 2012. Finally, EPA annualized the benefits of the regulatory options over a 50-year

time span. The following sections explain these steps in detail.

D.2 Timing of Benefits

In order to calculate the annualized value of the welfare gain from the regulatory analysis options

considered for the proposed Section 316(b) Rule, EPA developed a time profile of total benefits from all

facilities that reflects when benefits from each facility will be realized. EPA first calculated the

undiscounted welfare gain from the expected annual regional reductions in impingement and entrainment

mortality (I&E mortality) under each option, based on the assumptions that all facilities in each region

would achieved compliance and that benefits are realized immediately following compliance. Then, since

there are regulatory and biological time lags between the potential promulgation of each respective

regulatory option and the realization of benefits, EPA created a time profile of benefits that takes into

account the fact that benefits do not begin immediately.

Regulatory-related time lags occur because facilities will not always achieve compliance in the same year

that costs are incurred. Facilities will face regulatory requirements once the rule takes effect, but it will

take time to make the required changes. For this analysis, EPA assumed that facilities, in the aggregate,

would achieve compliance on a uniform schedule over the 5-year periods 2013-2017, 2018-2022, or

2023-2027 with all activities associated with the achievement of compliance estimated to occur uniformly

over this period. Facilities required to comply with impingement mortality limits are assumed to achieve

compliance on a uniform schedule over the 5-year period 2013-2017. Non-nuclear electric generating

facilities required to reduce intake flow commensurate with closed cycle cooling are assumed to achieve

compliance on a uniform schedule over the 5-year period 2018-2022. Nuclear electric generating facilities

and manufacturing facilities required to reduce intake flow commensurate with closed cycle cooling are

assumed to achieve compliance on a uniform schedule over the 5-year period 2023-2027. Following the

achievement of compliance, all operational effects of compliance (i.e., reduction in I&E mortality losses)

are also assumed to occur as though they originated from a compliance schedule that is uniformly spread

over the 5-year window. Compliance is assumed to continue until the year 2056 for all facilities. See

Chapter11 of the EA report for more detail.

D
March 28, 2011 D-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

The biological time lags that affect the timing of commercial and recreational fishing benefits (including

recreational use of threatened and endangered species) occur because most fish that would be spared from

I&E mortality would be in larval or juvenile stages. Since these fish may require several years to grow

and mature before commercial and recreational anglers can harvest them, there would be a lag between

installation of technologies to reduce I&E mortality and realization of commercial and recreational

angling benefits. For example, a larval fish spared from entrainment (in effect, at age zero) may be caught

by a recreational angler at age three, meaning that a three-year time lag arises between the installation of

technologies to reduce I&E mortality 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 I&E mortality and the

subsequent commercial fishery benefit. In general, fish that tend to be harvested at young ages will have

relatively short time lags between implementation of technologies to reduce I&E mortality and the

subsequent timing of changes in catch. In contrast, long-lived fish that tend to be caught at relatively older

ages would tend to have longer time lags (and, hence, the effects of discounting would be larger, resulting

in lower present values).

In order to model the biological lags between installation of technologies to reduce I&E mortality and

realization of commercial and recreational benefits, EPA collected species-specific information on ages of

fish at harvest to estimate the average time required for a fish spared from I&E mortality 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

I&E mortality losses in each study region, to develop a benefits recognition schedule for facilities in each

region.58

Following achievement of compliance, commercial and recreational fishing benefits from facilities in

most regions (the California, North Atlantic, Mid-Atlantic, and South Atlantic regions) are assumed to

increase over a seven-year period to a long-term, steady-state average, equal to the approximated perfacility 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 indicates the fraction of the steady-state benefit value (i.e., the percentage of

commercial and recreational fish spared from I&E mortality that reach a harvestable age) that is realized

in each of the first seven years following the achievement of compliance at a facility.

For regions with a relatively high contribution of impingement to total I&E mortality (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 regions.

These profile values are approximations based on a review of the age-specific fishing mortality rates that

were used in the I&E mortality analysis and best professional judgment.

In all regions, this fraction remains 1.0 until the final year of compliance, 2056. The commercial and

recreational fishing benefits profile declines at the end of the compliance period in the same fashion that it

increases at the beginning of compliance. . Specifically, at the end of the compliance period, benefit

values follow a profile of <1.0, 0.9, 0.8, 0.2, 0.1, 0.05, 0.0> with the last benefits occurring in 2061.

Therefore, the analysis of benefits encompasses a 50-year period from rule promulgation and first

58 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

and their derivation are described in more detail in Appendix A.
March 28, 2011 D-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

occurrence of compliance-related costs in 2012 until the final benefits in 2061. The number of years when

benefits do not equal zero varies among the in-scope facilities depending on the year that it initially

achieves compliance.

For nonuse benefits and the HEA analysis, EPA assumes that there is no initial biological lag at the start

of the compliance period because benefits are not based on the harvest of fish spared from I&E mortality.

Benefits are assumed to begin accruing immediately when a facility comes into compliance and to

continue in full (i.e., fraction of 1.0) until the year 2056.

The nonuse and HEA analysis include a linear decline in benefits starting at the end of the compliance

period following a profile of <1.0, 0.83, 0.67, 0.50, 0.33, 0.17, 0.0> with the last benefits occurring in

2061. This profile reflects the fact that increases in fish abundance and biological production resulting

from reductions in I&E mortality will return to baseline over time. The duration of the profile is

consistent with analyses for commercial and recreational fishing benefits and its trajectory is based on

best professional judgment.

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 2012 using the following formula:

 





t

t

t

r

2012 )1(

Benefits ValuePresent Equation 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 their constant annual

equivalent value (annualized value) using the annualization formula presented below, again using two

discount rates, 3 percent and 7 percent.59 Although the analysis period extends further, EPA annualized

benefits over the assumed period of compliance for in-scope facilities. This same annualization concept

and period of annualization were also followed in the analysis of costs, although for costs the time

horizon of analysis for calculating the present value is shorter than for benefits. Using the same

annualization period for both benefits and social costs allows comparison of 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*

*BenefitofPVBenefitAnnualized

n

n

r

rr

Equation D-2

where:

r = discount rate (3 percent and 7 percent)

n = annualization period, 50 years for the benefits analysis

59 The three percent rate represents an estimate of the social rate of time preference.
March 28, 2011 D-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table D-1 presents a summary of the time profile of benefits discounted at the 3 percent and 7 percent

rates for each of the regulatory options on the national scale. The table also presents the total value and

annualized value that are equivalent to this stream of benefits.

Table D-1: Time Profile of National Mean Total Benefits at In-scope Facilities by

Regulatory Option (2009$, thousands)

Option 1: I Everywhere

Option 2: I Everywhere

and E for Facilities with

DIF > 125 MGD

Option 3: I&E

Mortality Everywhere

Option 4: I for

Facilities with DIF >

50 MGD Year 3%

Discount

Rate

7%

Discount

Rate

3%

Discount

Rate

7%

Discount

Rate

3%

Discount

Rate

7%

Discount

Rate

3%

Discount

Rate

7%

Discount

Rate

2010 0 0 0 0 0 0 $0 $0

2011 0 0 0 0 0 0 $0 $0

2012 $0 $0 $0 $0 $0 $0 $0 $0

2013 $470 $448 $32 $30 $7 $7 $463 $441

2014 $1,309 $1,205 $85 $78 $20 $19 $1,288 $1,186

2015 $4,165 $3,705 $264 $235 $72 $64 $4,091 $3,638

2016 $7,461 $6,393 $458 $392 $126 $109 $7,329 $6,280

2017 $10,765 $8,882 $652 $538 $181 $150 $10,576 $8,726

2018 $13,640 $10,838 $14,443 $11,102 $14,415 $11,064 $13,400 $10,647

2019 $16,019 $12,255 $28,190 $20,863 $28,616 $21,160 $15,737 $12,040

2020 $16,464 $12,126 $44,411 $31,724 $45,435 $32,437 $16,179 $11,915

2021 $16,347 $11,590 $61,484 $42,366 $63,150 $43,496 $16,064 $11,389

2022 $16,047 $10,952 $77,979 $51,791 $80,270 $53,294 $15,769 $10,762

2023 $15,598 $10,248 $86,028 $55,095 $88,729 $56,808 $15,329 $10,070

2024 $15,144 $9,577 $93,426 $57,672 $96,529 $59,571 $14,882 $9,412

2025 $14,703 $8,951 $98,547 $58,596 $102,101 $60,695 $14,449 $8,796

2026 $14,274 $8,365 $103,581 $59,322 $107,577 $61,599 $14,028 $8,220

2027 $13,859 $7,818 $108,187 $59,674 $112,604 $62,100 $13,619 $7,683

2028 $13,455 $7,306 $108,905 $57,873 $113,471 $60,292 $13,223 $7,180

2029 $13,063 $6,828 $109,142 $55,871 $113,816 $58,257 $12,837 $6,710

2030 $12,683 $6,382 $108,273 $53,379 $112,912 $55,661 $12,464 $6,271

2031 $12,313 $5,964 $105,740 $50,188 $110,279 $52,337 $12,101 $5,861

2032 $11,955 $5,574 $102,961 $47,045 $107,385 $49,062 $11,748 $5,478

2033 $11,606 $5,209 $100,080 $44,021 $104,379 $45,906 $11,406 $5,119

2034 $11,268 $4,869 $97,165 $41,141 $101,339 $42,903 $11,074 $4,784

2035 $10,940 $4,550 $94,335 $38,449 $98,387 $40,096 $10,751 $4,471

2036 $10,622 $4,252 $91,588 $35,934 $95,522 $37,473 $10,438 $4,179

2037 $10,312 $3,974 $88,920 $33,583 $92,739 $35,022 $10,134 $3,905

2038 $10,012 $3,714 $86,330 $31,386 $90,038 $32,731 $9,839 $3,650

2039 $9,720 $3,471 $83,816 $29,333 $87,416 $30,589 $9,552 $3,411

2040 $9,437 $3,244 $81,374 $27,414 $84,870 $28,588 $9,274 $3,188

2041 $9,162 $3,032 $79,004 $25,620 $82,398 $26,718 $9,004 $2,979

2042 $8,895 $2,834 $76,703 $23,944 $79,998 $24,970 $8,742 $2,785

2043 $8,636 $2,648 $74,469 $22,378 $77,668 $23,337 $8,487 $2,602

2044 $8,385 $2,475 $72,300 $20,914 $75,406 $21,810 $8,240 $2,432

2045 $8,141 $2,313 $70,194 $19,546 $73,209 $20,383 $8,000 $2,273

2046 $7,903 $2,162 $68,150 $18,267 $71,077 $19,050 $7,767 $2,124

2047 $7,673 $2,020 $66,165 $17,072 $69,007 $17,803 $7,541 $1,985

2048 $7,450 $1,888 $64,238 $15,955 $66,997 $16,639 $7,321 $1,855

2049 $7,233 $1,765 $62,367 $14,911 $65,046 $15,550 $7,108 $1,734

2050 $7,022 $1,649 $60,550 $13,936 $63,151 $14,533 $6,901 $1,621
March 28, 2011 D-5

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table D-1: Time Profile of National Mean Total Benefits at In-scope Facilities by

Regulatory Option (2009$, thousands)

Option 1: I Everywhere

Option 2: I Everywhere

and E for Facilities with

DIF > 125 MGD

Option 3: I&E

Mortality Everywhere

Option 4: I for

Facilities with DIF >

50 MGD Year 3%

Discount

Rate

7%

Discount

Rate

3%

Discount

Rate

7%

Discount

Rate

3%

Discount

Rate

7%

Discount

Rate

3%

Discount

Rate

7%

Discount

Rate

2051 $6,818 $1,541 $58,787 $13,024 $61,312 $13,582 $6,700 $1,515

2052 $6,619 $1,440 $57,074 $12,172 $59,526 $12,694 $6,505 $1,416

2053 $6,426 $1,346 $55,412 $11,376 $57,792 $11,863 $6,315 $1,323

2054 $6,239 $1,258 $53,798 $10,632 $56,109 $11,087 $6,131 $1,236

2055 $6,057 $1,176 $52,231 $9,936 $54,475 $10,362 $5,953 $1,155

2056 $5,881 $1,099 $50,710 $9,286 $52,888 $9,684 $5,779 $1,080

2057 $5,128 $922 $42,374 $7,475 $44,184 $7,794 $5,039 $906

2058 $4,415 $765 $34,749 $5,906 $36,224 $6,156 $4,339 $751

2059 $1,120 $186 $17,101 $2,772 $17,875 $2,897 $1,101 $183

2060 $555 $89 $10,326 $1,608 $10,799 $1,682 $546 $87

2061 $270 $42 $5,135 $770 $5,371 $805 $266 $41

2062 $0 $0 $0 $0 $0 $0 $0 $0

2063 0 0 0 0 0 0 $0 $0

2064 0 0 0 0 0 0 $0 $0

2065 0 0 0 0 0 0 $0 $0

Total

Present

Valuea

$453,679 $221,341 $3,108,232 $1,272,593 $3,232,893 $1,320,887 $445,825 $217,499

Annualized

Valueb

$17,632 $16,038 $120,794 $92,200 $125,649 $95,711 $17,327 $15,760

a The total present value is equal to the sum of the values of the benefits realized in all years of the analysis, discounted to 2012.

b The annualized value represents the total present value of the benefits of the regulation, distributed over a 50-year period.

Source: U.S. EPA analysis for this report.
March 28, 2011 E-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Appendix E: List of T&E Species Overlapping CWIS

E

Table E-1: List of T&E Species Overlapping One or More In-Scope 316(b) Cooling Water Intake

Structure

Latin Name Common Name

Acipenser brevirostrum Shortnose Sturgeon

Acipenser medirostris Green Sturgeon

Acipenser oxyrinchus desotoi Gulf Sturgeon

Acipenser oxyrinchus oxyrinchus Atlantic Sturgeon

Acropora cervicornis Staghorn Coral

Acropora palmata Elkhorn Coral

Alasmidonta heterodon Dwarf Wedgemussel

Amblyopsis rosae Ozark Cavefish

Arkansia wheeleri Ouachita Rock Pocketbook

Caretta caretta Loggerhead Sea Turtle

Chelonia mydas Green Sea Turtle

Conradilla caelata Birdwing Pearlymussel

Cottus paulus (=pygmaeus) Pygmy Sculpin

Cyprinella caerulea Blue Shiner

Cyprogenia stegaria Fanshell

Dermochelys coriacea Leatherback Sea Turtle

Dromus dromas Dromedary Pearlymussel

Elliptio steinstansana Tar River Spinymussel

Epioblasma brevidens Cumberlandian Combshell

Epioblasma florentina florentina Yellow (Pearlymussel) Blossom

Epioblasma florentina walkeri (=E. walkeri) Tan Riffleshell

Epioblasma obliquata obliquata Catspaw (Purple Cat's Paw Pearlymussel)

Epioblasma obliquata perobliqua White (Pearlymussel) Catspaw

Epioblasma penita Southern Combshell

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

Lampsilis higginsii Higgins Eye (Pearlymussel)

Lampsilis powellii Arkansas Fatmucket

Lampsilis virescens Alabama Lampmussel

Lepidochelys kempii Kemp's Ridley Sea Turtle
March 28, 2011 E-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table E-1: List of T&E Species Overlapping One or More In-Scope 316(b) Cooling Water Intake

Structure

Latin Name Common Name

Lepidochelys olivacea Olive Ridley Sea Turtle

Leptodea leptodon Scaleshell Mussel

Margaritifera hembeli Louisiana Pearlshell

Microphis brachyurus lineatus Opossum Pipefish

Notropis albizonatus Palezone Shiner

Notropis Topeka Topeka Shiner

Noturus placidus Neosho Madtom

Noturus stanauli Pygmy Madtom

Noturus trautmani Scioto Madtom

Obovaria retusa Ring Pink (Mussel)

Oncorhynchus clarkii 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 marshalli Flat Pigtoe

Pleurobema plenum Rough Pigtoe

Pleurobema taitianum Heavy Pigtoe

Potamilus capax Fat Pocketbook

Potamilus inflatus Alabama (=Inflated) Heelsplitter

Pristis pectinata Smalltooth Sawfish

Ptychocheilus lucius Colorado Pikeminnow (=Squawfish)

Quadrula fragosa Winged Mapleleaf

Quadrula intermedia Cumberland (Pearlymussel) Monkeyface

Quadrula sparsa Appalachian (Pearlymussel) Monkeyface

Quadrula stapes Stirrupshell

Rivulus marmoratus Mangrove Rivulus

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
March 28, 2011 F-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

F

Appendix F: Detailed Methodologies of CWIS, and Estimated Benefits

of Regulation on, Threatened and Endangered Species

F.1 I&E Mortality of Sea Turtles

Six species of sea turtles are found in U.S. waters: 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 threatened or endangered (T&E) under the Endangered Species Act

(ESA). Because of these large ranges, there is substantial overlap between sea turtle habitat and cooling

water intake structures (CWIS) for in-phase power generating and manufacturing 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 species x CWIS interactions 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 is believed to be relatively

small considered 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, FL, where annual capture rates range from 350-1000 turtles. Although

estimated mortality rates due to entrainment are < 3%, approximately 85% 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% of Green and

13% 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 non-use values placed upon the survival of these animals by the public.
March 28, 2011 F-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table F-1: Reported Values of Sea Turtle Entrainment

Takes Takes / yr

Facility Species Non-lethal Lethal Dates Non-lethal Lethal Source

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)

Loggerhead 40 8 1999 40 8

Kemp's Ridley 7 3 1999 7 3

Oyster Creek, NJ,

Salem, NJ,

Hope NJ Green 8 2 1999 8 2

NMFS (2001)

Salem, NJ Loggerhead, Kemp's Ridley,

Green 23 2 1991 23 2 Eggers (2001)

Salem, NJ Loggerhead 18 8 1980-1988 2.25 1

Salem, NJ Kemp's Ridley 6 6 1980-1988 0.75 0.75

Eggers (1989)

St. Lucie, FL Loggerhead 6313 169 1976-2005 225.5 6 NMFS (2009)

San Diego, Edison Olive Ridley

(NMFS and USFWS

1998b)

San Diego, Encina, Edison Green

Qualitative Reports Only

(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)
March 28, 2011 F-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table F-2: A subset of US-based nongovernmental organizations 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_pr

ograms/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_op

ps.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/resea

rch/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

F.2 Application of Whitehead (1993)’s 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 non-use 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
March 28, 2011 F-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

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 non users (p.121)” (Whitehead 1993). The household value is expressed as option

price, or willingness to pay under conditions of future supply and demand uncertainty. The option price is

estimated by solving for the dollar amount which would make respondent indifferent to utility with and

without the management program. The function used to estimate option price (Model B from Whitehead

(1993)) is:

OP (1991$) = 1.272 [p2(r2-q2)] / 0.029 Equation F-3

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 316(b) regulatory

options. Available data sources and biological models were reviewed 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

impingement and entrainment mortality 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 survivorship at these age classes could have a measurable impact on

extinction risk. As such, EPA believes that marginal change in supply probability of loggerhead sea

turtles due to 316(b) regulatory options is unlikely to be lower than 0.01 (i.e., a 1% increase in 25 year

survival probability).

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 316(b)

regulation. Although this assessment is not based on formal quantitative analysis of extinction risk, it is

intended 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 $0.35 (2009$). Estimates were

converted to 2009 dollars using the consumer price index (USBLS 2010).
March 28, 2011 F-5

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table F-3: Variable Descriptions and Values used for EPA’s Benefits Transfer Application

Variable Name Description

Value Used in EPA's

Applications

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 payvalue of $10.98 (1991$) for a mean increase in supply

probability of 0.47 in 25 years.

F.3 Application of Richardson & Loomis’ (2008) WTP Model

To illustrate the potential magnitude of nonuse values for T&E species affected by I&E mortality in the

California and Inland regions, EPA applied a WTP meta-analytical model (Richardson and Loomis 2009)

to hypothetical scenarios. Because EPA does not currently have region-wide I&E mortality losses for all

T&E species, nor population models to estimate the effect of I&E mortality on population size, estimates

are presented only to assess the range of benefits potentially resulting from 316(b) regulatory options. The

modeled scenarios estimate the WTP for 0.25% and 0.5% increases for all T&E fish populations in the

California and Inland regions.

The model used by EPA 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 Equation F-4

Model variables are described in Table F-4. Excepting all policy-relevant variables, EPA used the mean

values for all model parameters, and converted estimates to 2009$ using the consumer price index

(USBLS 2010).
March 28, 2011 F-6

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table F-4: Variables in the 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
March 28, 2011 G-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

G

Appendix G: Estimation of Price Changes for Consumer Surplus

G.1 Introduction

EPA considered estimating consumer surplus values associated with reductions in impingement and

entrainment mortality (I&E mortality), but found that dockside prices would not change enough 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. First, the Agency estimated the total baseline

harvest for relevant species (commercial species of similar types to those affected by I&E mortality), in

three categories: finfish, shrimp, and crabs.60, 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.61

Next, EPA calculated the percentage change in harvest if baseline I&E mortality losses were to be

eliminated, by dividing the total increase in harvest from elimination of baseline I&E mortality by the

total harvest. The percentage change in price for each region and species was then estimated 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 I&E mortality losses were estimated. Since 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.62g

60 For example, offshore species such as tuna and swordfish, baitfish species, and shellfish were not included.

61 Harvests for Alaska and Hawaii were not included in the totals.

62 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.
March 28, 2011 G-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table G-1: Own-Price Elasticity Estimates from Literature Review

Species

Group Species StudyElasticity

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. These percentage changes

were applied to the baseline prices to develop estimates of prices for the increased harvests that would

result from eliminating baseline I&E mortality losses. Table G-3 to Table G-7 show the projected prices

after eliminating baseline I&E mortality losses.63 For a 0.27 percent change in total harvest in California,

63 Values of 0.0 for increased harvest from elimination of baseline I&E mortality losses may include increases less than 0.1

thousand lbs.
March 28, 2011 G-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

finfish prices are predicted to change by 0.14 percent; for a 5.52 percent change in harvest for the East

Coast and Gulf, finfish prices are predicted to change by 2.92 percent; for a 0.11 percent change in

harvest of shrimp, prices are predicted to change by 0.17 percent; and for a 0.26 percent change in harvest

for crabs, prices are predicted to change by 0.20 percent. This translates into very small changes

(generally one to two cents) in ex-vessel prices per pound for the species affected by I&E mortality.

Because of the negligible effects on prices, EPA did not include measures of changes in consumer surplus

in the commercial fishing benefits estimates.

Table G-2: Estimated Percentage Change in Ex-Vessel Price by Region and Species Group

Region Species

Group

Baseline

Increase in

Harvesta

(lbs)

Total Average

Annual Harvestb

(lbs)

Percentage

Change in

Harvest

Elasticity

Percentage

Change in

Price

California Finfish 1,373,100 546,791,850 0.25% -1.89 -0.13%

East Coast and Gulf Finfish 15,758,900 397,297,400 3.97% -1.89 -2.10%

All Regions Crabs 678,900 315,657,146 0.22% -1.31 -0.16%

All Regions Shrimp 327,700 289,878,937 0.11% -0.63 -0.18%

a. Estimated increase in harvest due to elimination of baseline I&E mortality.

b. Sum of total landings for all relevant species; source – NMFS landings data.

Table G-3: Estimated Price Changes for the California Region

Species Average Annual Harvest

2005-2009 (thousand lbs)

Price Per Pound

(2009$)a

Increase in Harvest from

Elimination of Baseline

I&E Losses (thousand

lbs)

New Price

Per Pound

(2009$)a

American Shad 75.1 $0.98 0.0 $0.98

Anchovies 22,607.2 $0.05 0.6 $0.05

Cabezon 55.6 $5.83 54.4 $5.82

California Halibut 629.9 $4.06 126.4 $4.05

California Scorpionfish 7.9 $3.40 0.0 $3.40

Commercial Crabs 1,290.8 $1.33 1.6 $1.33

Commercial Shrimp 2,552.2 $1.93 0.0 $1.93

Drums and Croakers 77.0 $0.63 4.9 $0.63

Dungeness Crabs 14,370.0 $2.07 4.3 $2.07

Flounders 474.8 $0.45 10.1 $0.45

Other 57,125.4 $0.89 4.7 $0.89

Rockfishes 2,668.4 $1.25 1,168.7 $1.25

Sculpins 3.5 $3.43 2.6 $3.43

Sea Basses 6.5 $2.39 0.0 $2.39

Smelts 319.5 $0.38 0.2 $0.38

Surfperches 30.9 $1.92 0.5 $1.92

Total 102,294.7 . 1,379.0 .
March 28, 2011 G-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table G-4: Estimated Price Changes for the North Atlantic Region

Species Average Annual Harvest

2005-2009 (thousand lbs)

Price Per Pound

(2009$)a

Increase in Harvest from

Elimination of Baseline

I&E Losses (thousand lbs)

New Price

Per Pound

(2009$)a

American Shad 38.1 $0.69 0.0 $0.68

Atlantic Cod 15,427.3 $1.55 2.4 $1.52

Atlantic Herring 106,047.1 $0.12 18.0 $0.12

Atlantic Menhaden 5,548.6 $0.10 5.0 $0.10

Bluefish 1,077.2 $0.47 0.0 $0.46

Butterfish 550.9 $0.66 0.2 $0.65

Commercial Crabs 15,107.8 $0.58 0.4 $0.58

Flounders 17,675.4 $1.87 386.9 $1.83

Mackerels 38,896.8 $0.14 2.3 $0.14

Other 270,552.6 $0.44 3.9 $0.43

Pollock 14,567.6 $0.55 0.0 $0.54

Red Hake 576.9 $0.45 0.0 $0.44

Sculpins <0.1 $0.25 4.0 $0.24

Scup 4531 $0.86 0.1 $0.84

Searobin 23.9 $0.12 0.1 $0.12

Silver Hake 9,613.2 $0.53 0.6 $0.52

Skate Species 31,638.4 $0.20 0.5 $0.20

Tautog 147.1 $2.03 4.9 $1.99

Weakfish 28.2 $1.48 0.2 $1.45

White Perch 6.6 $1.45 0.0 $1.42

Total 53,2054.6 . 429.6 .
March 28, 2011 G-5

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table G-5: Estimated Price Changes for the Mid-Atlantic Region

Species Average Annual Harvest

2005-2009 (thousand lbs)

Price Per Pound

(2009$)a

Increase in Harvest from

Elimination of Baseline

I&E Losses (thousand lbs)

New Price

Per Pound

(2009$)a

Alewife 173.3 $0.21 0.4 $0.21

American Shad 111.4 $0.92 1.5 $0.90

Atlantic Herring 1,284.2 $0.11 0.1 $0.11

Atlantic Menhaden 338,097.3 $0.07 4,915.4 $0.07

Black Drum 93.8 $1.26 0.3 $1.23

Blue Crab 62,874.0 $1.17 1,014.2 $1.15

Bluefish 2,906.3 $0.43 0.1 $0.42

Butterfish 501.3 $0.85 0.0 $0.83

Commercial Crabs 2,240.2 $0.60 0.4 $0.60

Drums and Croakers 11,430.1 $0.49 1,519.2 $0.48

Flounders 6,468.0 $2.01 8.7 $1.97

Other 462,429.6 $0.32 1,264.4 $0.31

Red Hake 150.7 $0.52 0.8 $0.51

Scup 3,225.6 $0.98 0.0 $0.96

Searobin 12.0 $0.22 0.0 $0.22

Silver Hake 3,867.0 $0.67 0.1 $0.66

Spot 3,286.9 $0.74 1,111.4 $0.72

Striped Bass 5,413.8 $2.02 88.6 $1.98

Striped Mullet 20.3 $0.53 0.3 $0.52

Tautog 135.9 $2.64 0.0 $2.58

Weakfish 497.0 $1.10 741.9 $1.08

White Perch 1,190.0 $0.76 4.0 $0.74

Total 906,408.6 . 10,671.9 .

Table G-6: Estimated Price Changes for the South Atlantic Region

Species

Average Annual

Harvest 2005-2009

(thousand lbs)

Price Per Pound

(2009$)a

Increase in Harvest

from Elimination of

Baseline I&E Losses

(thousand lbs)

New Price

Per Pound

(2009$)a

Atlantic Menhaden 3,726.8 $0.11 55.7 $0.11

Blue Crab 36,414.4 $0.91 4.2 $0.91

Commercial Crabs 518 $1.51 0.0 $1.51

Drums and Croakers 8,333.3 $0.40 14.9 $0.39

Other 93,761.3 $1.17 3.0 $1.15

Spot 1,167.6 $0.65 20.4 $0.64

Stone Crab 101.1 $4.56 0.5 $4.55

Weakfish 266.5 $0.93 0.7 $0.91

Total 144,289.1 . 99.4
March 28, 2011 G-6

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table G-7: Estimated Price Changes for the Gulf of Mexico Region

Species

Average Annual

Harvest 2005-2009

(thousand lbs)

Price Per Pound

(2009$)a

Increase in Harvest from

Elimination of Baseline

I&E Losses (thousand

lbs)

New Price

Per Pound

(2009$)a

Atlantic Menhaden 930,460.2 $0.06 988.4 $0.06

Black Drum 4,397.3 $0.83 1,885.2 $0.81

Blue Crab 56,804.0 $0.77 228.5 $0.77

Drums and Croakers 81.0 $6.47 40.3 $6.33

Leatherjacket 65.6 $1.40 90.7 $1.37

Mackerels 3,967.4 $1.04 0.3 $1.02

Other 1,250,334.1 $0.41 240.5 $0.40

Pink Shrimp 8,696.5 $2.06 327.7 $2.06

Sea Basses 66.6 $0.97 0 $0.95

Sheepshead 1,366.3 $0.41 0 $0.40

Spot 18.1 $0.43 40.0 $0.42

Stone Crab 5,313.9 $4.23 439.0 $4.22

Striped Mullet 10,347.7 $0.67 1,278.3 $0.66

Total 2,271,918.70 . 5,558.9 .
March 28, 2011 H-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

H

Appendix H: Details of Regional Commercial Fishing Benefits

Table H-1: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality Losses at In-Scope Facilities in the

California Region, by Species and Regulatory Option (2009$)

Baseline Option 1 Option 2 Option 3 Option 4 Baseline Option 1 Option 2 Option 3 Option 4

American Shad 75.1 $0.98 0.0 0.0 0.0 0.0 0.0 . . . . .

Anchovies 22,607.2 $0.05 0.6 0.5 0.6 0.6 0.5 0.0 0.0 0.0 0.0 0.0

Cabezon 55.6 $5.83 54.4 0.1 46.4 48.5 0.1 166.5 0.2 142.0 148.5 0.2

California Halibut 629.9 $4.06 126.4 0.2 107.8 112.8 0.2 298.8 0.6 254.8 266.5 0.5

California Scorpionfish 7.9 $3.40 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Commercial Crabs 1,290.8 $1.33 1.6 0.0 1.3 1.4 0.0 1.5 0.0 1.3 1.4 0.0

Commercial Shrimp 2,552.2 $1.93 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Drums and Croakers 77.0 $0.63 4.9 0.7 4.3 4.5 0.7 1.3 0.2 1.1 1.2 0.2

Dungeness Crabs 14,370.0 $2.07 4.3 0.4 3.8 3.9 0.4 6.6 0.6 5.7 6.0 0.6

Flounders 474.8 $0.45 10.1 0.9 8.8 9.1 0.9 2.9 0.3 2.5 2.6 0.2

Other 57,125.4 $0.89 4.7 0.6 4.1 4.2 0.6 2.2 0.3 1.9 2.0 0.3

Rockfishes 2,668.4 $1.25 1,168.7 2.6 996.4 1,042.2 2.5 907.7 2.0 774.0 809.6 2.0

Sculpins 3.5 $3.43 2.6 0.1 2.2 2.3 0.1 5.7 0.2 4.9 5.1 0.2

Sea Basses 6.5 $2.39 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Smelts 319.5 $0.38 0.2 0.1 0.1 0.1 0.1 0.0 0.0 0.0 0.0 0.0

Surfperches 30.9 $1.92 0.5 0.5 0.5 0.5 0.4 0.4 0.3 0.4 0.4 0.3

Total (undiscounted) 102,294.7 . 1,379.0 6.7 1,176.4 1,230.3 6.5 1,393.9 4.7 1,188.7 1,243.3 4.6

Total (3% Discount Rate) . . . . . . . 1,236.0 3.7 750.8 776.0 3.6

Total (7% Discount Rate) . . . . . . . 1,195.0 3.3 573.3 589.0 3.2

Annual Benefits from Increase in Commercial Harvest

(2009$, thousands)

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 MGD; Option 3 = I&E Mortality

Everywhere; Option 4 = I for Facilities > 50 MGD

Species Name

Average

Annual

Harvest 2006-

2009

(thousand lbs)

Price per

Pound

Annual Increase in Commercial Harvest

(thousand lbs)
March 28, 2011 H-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table H-2: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality Losses at In-Scope Facilities in the North

Atlantic Region, by Species and Regulatory Option (2009$)

Baseline Option 1 Option 2 Option 3 Option 4 Baseline Option 1 Option 2 Option 3 Option 4

American Shad 38.1 $0.69 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Atlantic Cod 15,427.3 $1.55 2.4 0.1 2.0 2.1 0.1 2.5 0.1 2.0 2.1 0.1

Atlantic Herring 106,047.1 $0.12 18.0 0.4 14.8 15.5 0.4 1.7 0.0 1.4 1.4 0.0

Atlantic Menhaden 5,548.6 $0.10 5.0 0.0 4.1 4.3 0.0 0.4 0.0 0.3 0.3 0.0

Bluefish 1,077.2 $0.47 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Butterfish 550.9 $0.66 0.2 0.1 0.2 0.2 0.1 0.1 0.0 0.1 0.1 0.0

Commercial Crabs 15,107.8 $0.58 0.4 0.2 0.4 0.4 0.2 0.1 0.1 0.1 0.1 0.1

Flounders 17,675.4 $1.87 386.9 1.3 315.8 331.2 1.3 460.2 1.5 375.5 393.9 1.5

Mackerels 38,896.8 $0.14 2.3 0.0 1.8 1.9 0.0 0.3 0.0 0.2 0.2 0.0

Other 270,552.6 $0.44 3.9 0.2 3.2 3.4 0.2 1.0 0.0 0.8 0.8 0.0

Pollock 14,567.6 $0.55 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Red Hake 576.9 $0.45 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Sculpins 0.0 $0.25 4.0 0.0 4.0 4.0 0.0 . . . . .

Scup 4,531.0 $0.86 0.1 0.0 0.1 0.1 0.0 0.1 0.0 0.1 0.1 0.0

Searobin 23.9 $0.12 0.1 0.0 0.1 0.1 0.0 . . . . .

Silver Hake 9,613.2 $0.53 0.6 0.1 0.5 0.6 0.1 0.2 0.0 0.2 0.2 0.0

Skate Species 31,638.4 $0.20 0.5 0.4 0.5 0.5 0.4 0.1 0.0 0.1 0.1 0.0

Tautog 147.1 $2.03 4.9 0.0 4.0 4.2 0.0 4.5 0.0 3.7 3.8 0.0

Weakfish 28.2 $1.48 0.2 0.0 0.2 0.2 0.0 0.3 0.0 0.2 0.2 0.0

White Perch 6.6 $1.45 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Total (undiscounted) 532,054.6 . 429.6 2.9 351.7 368.6 2.9 471.2 1.9 384.6 403.4 1.9

Total (3% Discount Rate) . . . . . . . 417.9 1.5 230.6 241.5 1.5

Total (7% Discount Rate) . . . . . . . 404.0 1.3 171.3 179.3 1.3

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 MGD; Option 3 = I&E Mortality

Everywhere; Option 4 = I for Facilities > 50 MGD

Annual Benefits from Increase in Commercial Harvest

(2009$, thousands)

Species Name

Average

Annual

Harvest 2006-

2009

(thousand lbs)

Price per

Pound

Annual Increase in Commercial Harvest

(thousand lbs)
March 28, 2011 H-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table H-3: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality Losses at In-Scope Facilities in the MidAtlantic Region, by Species and Regulatory Option (2009$)

Baseline Option 1 Option 2 Option 3 Option 4 Baseline Option 1 Option 2 Option 3 Option 4

Alewife 173.3 $0.21 0.4 0.3 0.4 0.4 0.3 0.1 0.1 0.1 0.1 0.1

American Shad 111.4 $0.92 1.5 0.0 1.3 1.4 0.0 1.1 0.0 1.0 1.0 0.0

Atlantic Herring 1,284.2 $0.11 0.1 0.1 0.1 0.1 0.1 0.0 0.0 0.0 0.0 0.0

Atlantic Menhaden 338,097.3 $0.07 4,915.4 3,273.9 4,758.3 4,780.2 3,270.8 223.3 148.7 216.1 217.1 148.6

Black Drum 93.8 $1.26 0.3 0.2 0.3 0.3 0.2 0.3 0.2 0.3 0.3 0.2

Blue Crab 62,874.0 $1.17 1,014.2 10.2 929.6 941.4 10.2 678.0 6.8 621.5 629.3 6.8

Bluefish 2,906.3 $0.43 0.1 0.1 0.1 0.1 0.1 0.0 0.0 0.0 0.0 0.0

Butterfish 501.3 $0.85 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Commercial Crabs 2,240.2 $0.60 0.4 0.3 0.3 0.3 0.3 0.1 0.1 0.1 0.1 0.1

Drums and Croakers 11,430.1 $0.49 1,519.2 16.5 1,392.6 1,410.2 16.5 549.3 6.0 503.5 509.9 6.0

Flounders 6,468.0 $2.01 8.7 3.4 8.3 8.3 3.4 11.9 4.5 11.2 11.3 4.5

Other 462,429.6 $0.32 1,264.4 126.9 1,167.9 1,181.3 126.8 293.0 29.4 270.6 273.7 29.4

Red Hake 150.7 $0.52 0.8 0.6 0.8 0.8 0.6 0.3 0.2 0.3 0.3 0.2

Scup 3,225.6 $0.98 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Searobin 12.0 $0.22 0.0 0.0 0.0 0.0 0.0 . . . . .

Silver Hake 3,867.0 $0.67 0.1 0.1 0.1 0.1 0.1 0.0 0.0 0.0 0.0 0.0

Spot 3,286.9 $0.74 1,111.4 120.0 1,111.4 1,111.4 119.9 693.6 74.9 693.6 693.6 74.8

Striped Bass 5,413.8 $2.02 88.6 0.4 81.2 82.2 0.4 119.2 0.6 109.2 110.6 0.6

Striped Mullet 20.3 $0.53 0.3 0.2 0.3 0.3 0.2 0.1 0.1 0.1 0.1 0.1

Tautog 135.9 $2.64 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Weakfish 497.0 $1.10 741.9 196.1 694.9 701.4 196.0 619.3 163.7 580.0 585.5 163.6

White Perch 1,190.0 $0.76 4.0 0.3 3.7 3.7 0.3 2.5 0.2 2.3 2.3 0.2

Total (undiscounted) 906,408.6 . 10,671.9 3,749.8 10,151.6 10,224.0 3,746.3 3,192.2 435.5 3,010.1 3,035.4 435.1

Total (3% Discount Rate) . . . . . . . 2,831.2 342.0 1,614.8 1,629.0 341.6

Total (7% Discount Rate) . . . . . . . 2,736.8 302.7 1,124.0 1,133.9 302.4

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 MGD; Option 3 = I&E Mortality

Everywhere; Option 4 = I for Facilities > 50 MGD

Annual Benefits from Increase in Commercial Harvest

(2009$, thousands)

Species Name

Average

Annual

Harvest 2006-

2009

(thousand lbs)

Price per

Pound

Annual Increase in Commercial Harvest

(thousand lbs)
March 28, 2011 H-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table H-4: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality Losses at In-Scope Facilities in the South

Atlantic Region, by Species and Regulatory Option (2009$)

Baseline Option 1 Option 2 Option 3 Option 4 Baseline Option 1 Option 2 Option 3 Option 4

Atlantic Menhaden 3,726.8 $0.11 55.7 31.4 47.4 47.4 31.4 4.7 2.7 4.0 4.0 2.7

Blue Crab 36,414.4 $0.91 4.2 2.6 3.6 3.6 2.6 2.2 1.4 1.9 1.9 1.4

Commercial Crabs 518.0 $1.51 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Drums and Croakers 8,333.3 $0.40 14.9 0.3 12.4 12.4 0.3 3.2 0.1 2.7 2.7 0.1

Other 93,761.3 $1.17 3.0 1.5 2.5 2.5 1.5 2.1 1.1 1.8 1.8 1.1

Spot 1,167.6 $0.65 20.4 8.6 17.3 17.3 8.6 9.3 3.9 7.9 7.9 3.9

Stone Crab 101.1 $4.56 0.5 0.3 0.5 0.5 0.3 1.4 0.9 1.2 1.2 0.9

Weakfish 266.5 $0.93 0.7 0.4 0.6 0.6 0.4 0.4 0.2 0.4 0.4 0.2

Total (undiscounted) 144,289.1 . 99.4 45.1 84.2 84.3 45.1 23.3 10.2 19.8 19.8 10.2

Total (3% Discount Rate) . . . . . . . 20.7 8.0 11.5 11.5 8.0

Total (7% Discount Rate) . . . . . . . 20.0 7.1 8.4 8.4 7.1

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 MGD; Option 3 = I&E Mortality

Everywhere; Option 4 = I for Facilities > 50 MGD

Annual Benefits from Increase in Commercial Harvest

(2009$, thousands)

Species Name

Average

Annual

Harvest 2006-

2009

(thousand lbs)

Price per

Pound

Annual Increase in Commercial Harvest

(thousand lbs)
March 28, 2011 H-5

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table H-5: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality Losses at In-Scope Facilities in the Gulf of

Mexico Region, by Species and Regulatory Option (2009$)

Baseline Option 1 Option 2 Option 3 Option 4 Baseline Option 1 Option 2 Option 3 Option 4

Atlantic Menhaden 930,460.2 $0.06 988.4 749.3 978.5 979.2 743.6 44.1 33.5 43.7 43.7 33.2

Black Drum 4,397.3 $0.83 1,885.2 3.1 1,276.5 1,279.7 3.1 1,087.6 1.8 736.5 738.3 1.8

Blue Crab 56,804.0 $0.77 228.5 40.2 171.2 171.5 39.9 126.3 22.2 94.6 94.8 22.0

Drums and Croakers 81.0 $6.47 40.3 30.8 40.0 40.0 30.6 140.7 107.7 139.7 139.8 106.8

Leatherjacket 65.6 $1.40 90.7 66.2 88.7 88.8 65.7 . . . . .

Mackerels 3,967.4 $1.04 0.3 0.2 0.3 0.3 0.2 0.2 0.2 0.2 0.2 0.2

Other 1,250,334.1 $0.41 240.5 164.8 230.8 231.0 163.6 45.7 31.3 43.8 43.9 31.1

Pink Shrimp 8,696.5 $2.06 327.7 154.4 285.5 285.9 153.3 293.4 138.3 255.7 256.0 137.2

Sea Basses 66.6 $0.97 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Sheepshead 1,366.3 $0.41 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Spot 18.1 $0.43 40.0 24.8 37.3 37.3 24.6 9.3 5.8 8.7 8.7 5.7

Stone Crab 5,313.9 $4.23 439.0 104.1 340.1 340.7 103.3 1,323.1 313.8 1,024.7 1,026.6 311.4

Striped Mullet 10,347.7 $0.67 1,278.3 121.5 914.9 916.9 120.5 676.0 64.2 483.9 484.9 63.7

Total (undiscounted) 2,271,918.7 . 5,558.9 1,459.4 4,363.8 4,371.3 1,448.4 3,746.5 718.7 2,831.5 2,836.9 713.3

Total (3% Discount Rate) . . . . . . . 3,462.9 588.4 1,805.7 1,804.3 584.0

Total (7% Discount Rate) . . . . . . . 3,449.9 536.8 1,394.2 1,390.4 532.7

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 MGD; Option 3 = I&E Mortality

Everywhere; Option 4 = I for Facilities > 50 MGD

Species Name

Average

Annual

Harvest 2006-

2009

(thousand lbs)

Price per

Pound

Annual Benefits from Increase in Commercial Harvest

(2009$, thousands)

Annual Increase in Commercial Harvest

(thousand lbs)
March 28, 2011 H-6

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table H-6: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality Losses at In-Scope Facilities in the Great

Lakes Region, by Species and Regulatory Option (2009$)

Baseline Option 1 Option 2 Option 3 Option 4 Baseline Option 1 Option 2 Option 3 Option 4

Bullhead 569.7 $0.41 0.8 0.7 0.8 0.8 0.7 0.1 0.1 0.1 0.1 0.1

Freshwater Drum 497.5 $0.16 16.1 3.8 13.7 13.8 3.8 0.8 0.2 0.6 0.6 0.2

Other 13,819.0 $0.94 97.2 35.0 85.3 86.1 34.7 26.6 9.6 23.3 23.6 9.5

Smelts 522.2 $0.91 105.9 91.2 104.6 104.9 90.5 27.8 24.0 27.5 27.6 23.8

White Bass 432.2 $0.68 22.0 6.4 19.0 19.2 6.4 4.3 1.3 3.7 3.8 1.3

Whitefish 9,406.5 $0.87 101.9 88.3 100.8 101.1 87.6 25.9 22.4 25.6 25.6 22.2

Yellow Perch 1,609.7 $2.08 2.3 1.6 2.2 2.2 1.6 1.4 0.9 1.3 1.3 0.9

Total (undiscounted) 40,675.8 . 346.2 227.0 326.4 328.0 225.1 86.8 58.4 82.2 82.6 57.9

Total (3% Discount Rate) . . . . . . . 80.3 47.8 52.9 53.0 47.4

Total (7% Discount Rate) . . . . . . . 80.0 43.6 41.1 41.0 43.3

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 MGD; Option 3 = I&E Mortality

Everywhere; Option 4 = I for Facilities > 50 MGD

Species Name

Average

Annual

Harvest 2006-

2009

(thousand lbs)

Price per

Pound

Annual Benefits from Increase in Commercial Harvest

(2009$, thousands)

Annual Increase in Commercial Harvest

(thousand lbs)
March 28, 2011 I-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

I

Appendix I: Details of Regional Recreational Fishing Benefits

I.1 California

Table I-1: Recreational Fishing Benefits from Eliminating Baseline I&E Mortality Losses at Inscope Facilities in the California Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

California halibut 38,418.0 $5.11 $9.76 $18.62 196.7 374.6 715.4

Flounders 246.0 $5.11 $9.76 $18.62 1.3 2.4 4.6

Total (Flatfish) 38,664.0 $5.11 $9.76 $18.62 198.0 377.0 720.0

Striped bass 1,209.0 $4.21 $7.26 $12.43 5.0 9.0 15.0

Total (Small Game) 1,209.0 $4.21 $7.26 $12.43 5.0 9.0 15.0

Cabezon 7,158.0 $1.79 $2.96 $4.89 12.8 21.2 35.0

California scorpionfish 58.0 $1.79 $2.96 $4.89 0.1 0.2 0.3

Croakers 32,132.0 $1.79 $2.96 $4.89 57.5 95.0 157.1

Rockfish 285,002.0 $1.79 $2.96 $4.89 509.8 842.9 1,393.2

Sculpin 111,780.0 $1.79 $2.96 $4.89 200.0 330.6 546.4

Sea bass 512,501.0 $1.79 $2.96 $4.89 916.8 1,515.8 2,505.3

Smelts 21.0 $1.79 $2.96 $4.89 0.0 0.1 0.1

Sunfish 13.0 $1.79 $2.96 $4.89 0.0 0.0 0.1

Surfperch 30,172.0 $1.79 $2.96 $4.89 54.0 89.2 147.5

Total (Other Saltwater) 978,837.0 $1.79 $2.96 $4.89 1,751.0 2,895.0 4,785.0

Total (Unidentified) 3,629.0 $1.86 $3.10 $5.18 7.0 11.0 19.0

Total (Undiscounted) 1,022,339.0 . . . 1,960.0 3,292.0 5,539.0

Total (3% discount rate) . . . . 1,740.0 2,923.0 4,917.0

Total (7% discount rate) . . . . 1,681.0 2,823.0 4,750.0

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands) Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish
March 28, 2011 I-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-2: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 1 (I Everywhere) in the California Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

California halibut 71.0 $5.11 $9.76 $18.62 0.0 0.8 1.5

Flounders 22.0 $5.11 $9.76 $18.62 0.0 0.2 0.5

Total (Flatfish) 92.0 $5.11 $9.76 $18.62 0.0 1.0 2.0

Striped bass 0.0 $4.21 $7.26 $12.43 0.0 0.0 0.0

Total (Small Game) 0.0 $4.21 $7.26 $12.43 0.0 0.0 0.0

Cabezon 10.0 $1.79 $2.96 $4.89 0.0 0.0 0.0

California scorpionfish 50.0 $1.79 $2.96 $4.89 0.1 0.1 0.2

Croakers 4,696.0 $1.79 $2.96 $4.89 8.4 13.9 23.0

Rockfish 636.0 $1.79 $2.96 $4.89 1.1 1.9 3.1

Sculpin 3,284.0 $1.79 $2.96 $4.89 5.8 9.7 16.1

Sea bass 284.0 $1.79 $2.96 $4.89 0.5 0.8 1.4

Smelts 17.0 $1.79 $2.96 $4.89 0.0 0.1 0.1

Sunfish 1.0 $1.79 $2.96 $4.89 0.0 0.0 0.0

Surfperch 26,391.0 $1.79 $2.96 $4.89 47.0 78.3 129.1

Total (Other Saltwater) 35,369.0 $1.79 $2.96 $4.89 63.0 105.0 173.0

Total (Unidentified) 976.0 $1.86 $3.10 $5.18 2.0 3.0 5.0

Total (Undiscounted) 36,438.0 . . . 66.0 109.0 180.0

Total (3% discount rate) . . . . 51.0 85.0 141.0

Total (7% discount rate) . . . . 46.0 75.0 125.0

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands) Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish
March 28, 2011 I-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-3: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 2 (I Everywhere and E for Facilities > 125 MGD) in the California

Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

California halibut 32,753.0 $5.11 $9.76 $18.62 167.9 319.9 610.0

Flounders 213.0 $5.11 $9.76 $18.62 1.1 2.1 4.0

Total (Flatfish) 32,967.0 $5.11 $9.76 $18.62 169.0 322.0 614.0

Striped bass 1,031.0 $4.21 $7.26 $12.43 4.0 7.0 13.0

Total (Small Game) 1,031.0 $4.21 $7.26 $12.43 4.0 7.0 13.0

Cabezon 6,103.0 $1.79 $2.96 $4.89 10.9 18.0 29.8

California scorpionfish 57.0 $1.79 $2.96 $4.89 0.1 0.2 0.3

Croakers 28,097.0 $1.79 $2.96 $4.89 50.3 83.1 137.3

Rockfish 242,999.0 $1.79 $2.96 $4.89 434.7 718.6 1,187.8

Sculpin 95,765.0 $1.79 $2.96 $4.89 171.3 283.2 468.1

Sea bass 436,840.0 $1.79 $2.96 $4.89 781.5 1,291.9 2,135.3

Smelts 20.0 $1.79 $2.96 $4.89 0.0 0.1 0.1

Sunfish 12.0 $1.79 $2.96 $4.89 0.0 0.0 0.1

Surfperch 29,711.0 $1.79 $2.96 $4.89 53.2 87.9 145.2

Total (Other Saltwater) 839,604.0 $1.79 $2.96 $4.89 1,502.0 2,483.0 4,104.0

Total (Unidentified) 3,240.0 $1.86 $3.10 $5.18 6.0 10.0 17.0

Total (Undiscounted) 876,841.0 . . . 1,681.0 2,822.0 4,748.0

Total (3% discount rate) . . . . 1,037.0 1,741.0 2,929.0

Total (7% discount rate) . . . . 792.0 1,330.0 2,237.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-4: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 3 (I&E Mortality Everywhere) in the California Region, by Species

(2009$)

5

th Mean 95th 5th Mean 95th

California halibut 34,260.0 $5.11 $9.76 $18.62 174.9 333.8 637.9

Flounders 222.0 $5.11 $9.76 $18.62 1.1 2.2 4.1

Total (Flatfish) 34,482.0 $5.11 $9.76 $18.62 176.0 336.0 642.0

Striped bass 1,078.0 $4.21 $7.26 $12.43 5.0 8.0 13.0

Total (Small Game) 1,078.0 $4.21 $7.26 $12.43 5.0 8.0 13.0

Cabezon 6,383.0 $1.79 $2.96 $4.89 11.4 18.9 31.2

California scorpionfish 57.0 $1.79 $2.96 $4.89 0.1 0.2 0.3

Croakers 29,198.0 $1.79 $2.96 $4.89 52.2 86.3 142.7

Rockfish 254,174.0 $1.79 $2.96 $4.89 454.5 751.6 1,242.4

Sculpin 100,044.0 $1.79 $2.96 $4.89 178.9 295.9 489.0

Sea bass 456,964.0 $1.79 $2.96 $4.89 817.2 1,351.3 2,233.6

Smelts 21.0 $1.79 $2.96 $4.89 0.0 0.1 0.1

Sunfish 12.0 $1.79 $2.96 $4.89 0.0 0.0 0.1

Surfperch 29,987.0 $1.79 $2.96 $4.89 53.6 88.7 146.6

Total (Other Saltwater) 876,840.0 $1.79 $2.96 $4.89 1,568.0 2,593.0 4,286.0

Total (Unidentified) 3,349.0 $1.86 $3.10 $5.18 6.0 10.0 17.0

Total (Undiscounted) 915,750.0 . . . 1,755.0 2,948.0 4,959.0

Total (3% discount rate) . . . . 1,096.0 1,840.0 3,095.0

Total (7% discount rate) . . . . 832.0 1,396.0 2,349.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-5

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-5: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 4 (I for Facilities > 50 MGD) in the California Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

California halibut 69.0 $5.11 $9.76 $18.62 0.0 0.8 1.5

Flounders 21.0 $5.11 $9.76 $18.62 0.0 0.2 0.5

Total (Flatfish) 90.0 $5.11 $9.76 $18.62 0.0 1.0 2.0

Striped bass 0.0 $4.21 $7.26 $12.43 0.0 0.0 0.0

Total (Small Game) 0.0 $4.21 $7.26 $12.43 0.0 0.0 0.0

Cabezon 10.0 $1.79 $2.96 $4.89 0.0 0.0 0.0

California scorpionfish 49.0 $1.79 $2.96 $4.89 0.1 0.1 0.2

Croakers 4,565.0 $1.79 $2.96 $4.89 8.1 13.5 22.3

Rockfish 618.0 $1.79 $2.96 $4.89 1.1 1.8 3.0

Sculpin 3,192.0 $1.79 $2.96 $4.89 5.7 9.5 15.6

Sea bass 276.0 $1.79 $2.96 $4.89 0.5 0.8 1.3

Smelts 16.0 $1.79 $2.96 $4.89 0.0 0.0 0.1

Sunfish 1.0 $1.79 $2.96 $4.89 0.0 0.0 0.0

Surfperch 25,654.0 $1.79 $2.96 $4.89 45.5 76.1 125.4

Total (Other Saltwater) 34,382.0 $1.79 $2.96 $4.89 61.0 102.0 168.0

Total (Unidentified) 949.0 $1.86 $3.10 $5.18 2.0 3.0 5.0

Total (Undiscounted) 35,421.0 . . . 64.0 106.0 175.0

Total (3% discount rate) . . . . 50.0 83.0 137.0

Total (7% discount rate) . . . . 44.0 73.0 121.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-6

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

I.2 North Atlantic

Table I-6: Recreational Fishing Benefits from Eliminating Baseline I&E Mortality Losses at Inscope Facilities in the North Atlantic Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Winter flounder 310,442.0 $3.81 $5.96 $9.42 1,182.0 1,850.0 2,925.0

Total (flatfish) 310,442.0 $3.81 $5.96 $9.42 1,182.0 1,850.0 2,925.0

Atlantic mackerel 903.0 $2.13 $5.94 $16.76 1.9 5.8 15.4

Bluefish 1.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Striped bass 0.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Weakfish 33.0 $2.13 $5.94 $16.76 0.1 0.2 0.6

Total (small game) 937.0 $2.13 $5.94 $16.76 2.0 6.0 16.0

Atlantic Cod 1,281.0 $1.79 $2.98 $4.97 2.3 3.8 6.4

Cunner 107,374.0 $1.79 $2.98 $4.97 191.9 320.2 533.7

Pollock 4.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Sculpin 323,088.0 $1.79 $2.98 $4.97 577.5 963.4 1,606.0

Scup 128.0 $1.79 $2.98 $4.97 0.2 0.4 0.6

Searobin 823.0 $1.79 $2.98 $4.97 1.5 2.5 4.1

Tautog 14,323.0 $1.79 $2.98 $4.97 25.6 42.7 71.2

White Perch 0.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Total (other saltwater) 447,021.0 $1.79 $2.98 $4.97 799.0 1,333.0 2,222.0

Total (unidentified) 2,783.0 $1.80 $3.01 $5.03 5.0 8.0 14.0

Total (Undiscounted) 761,183.0 . . . 1,988.0 3,197.0 5,177.0

Total (3% discount rate) . . . . 1,765.0 2,838.0 4,596.0

Total (7% discount rate) . . . . 1,705.0 2,742.0 4,440.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-7

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-7: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 1 (I Everywhere) in the North Atlantic Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Winter flounder 836.0 $3.81 $5.96 $9.42 3.0 5.0 8.0

Total (flatfish) 836.0 $3.81 $5.96 $9.42 3.0 5.0 8.0

Atlantic mackerel 0.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Bluefish 1.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Striped bass 0.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Weakfish 0.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Total (small game) 1.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Atlantic Cod 40.0 $1.79 $2.98 $4.97 0.1 0.1 0.2

Cunner 19.0 $1.79 $2.98 $4.97 0.0 0.0 0.1

Pollock 1.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Sculpin 345.0 $1.79 $2.98 $4.97 0.7 0.7 1.4

Scup 8.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Searobin 45.0 $1.79 $2.98 $4.97 0.1 0.1 0.2

Tautog 17.0 $1.79 $2.98 $4.97 0.0 0.0 0.1

White Perch 0.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Total (other saltwater) 476.0 $1.79 $2.98 $4.97 1.0 1.0 2.0

Total (unidentified) 181.0 $1.80 $3.01 $5.03 0.0 1.0 1.0

Total (Undiscounted) 1,495.0 . . . 4.0 7.0 11.0

Total (3% discount rate) . . . . 3.0 5.0 9.0

Total (7% discount rate) . . . . 3.0 5.0 8.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-8

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-8: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 2 (I Everywhere and E for Facilities > 125 MGD) in the North Atlantic

Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Winter flounder 253,297.0 $3.81 $5.96 $9.42 964.0 1,510.0 2,387.0

Total (flatfish) 253,297.0 $3.81 $5.96 $9.42 964.0 1,510.0 2,387.0

Atlantic mackerel 736.0 $2.13 $5.94 $16.76 1.9 4.8 12.5

Bluefish 1.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Striped bass 0.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Weakfish 27.0 $2.13 $5.94 $16.76 0.1 0.2 0.5

Total (small game) 764.0 $2.13 $5.94 $16.76 2.0 5.0 13.0

Atlantic Cod 1,054.0 $1.79 $2.98 $4.97 1.9 3.1 5.2

Cunner 87,542.0 $1.79 $2.98 $4.97 156.6 261.0 435.1

Pollock 3.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Sculpin 263,485.0 $1.79 $2.98 $4.97 471.2 785.6 1,309.6

Scup 106.0 $1.79 $2.98 $4.97 0.2 0.3 0.5

Searobin 682.0 $1.79 $2.98 $4.97 1.2 2.0 3.4

Tautog 11,681.0 $1.79 $2.98 $4.97 20.9 34.8 58.1

White Perch 0.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Total (other saltwater) 364,555.0 $1.79 $2.98 $4.97 652.0 1,087.0 1,812.0

Total (unidentified) 2,313.0 $1.80 $3.01 $5.03 4.0 7.0 12.0

Total (Undiscounted) 620,929.0 . . . 1,622.0 2,608.0 4,223.0

Total (3% discount rate) . . . . 939.0 1,510.0 2,446.0

Total (7% discount rate) . . . . 698.0 1,122.0 1,817.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-9

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-9: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 3 (I&E Mortality Everywhere) in the North Atlantic Region, by Species

(2009$)

5

th Mean 95th 5th Mean 95th

Winter flounder 265,676.0 $3.81 $5.96 $9.42 1,012.0 1,583.0 2,503.0

Total (flatfish) 265,676.0 $3.81 $5.96 $9.42 1,012.0 1,583.0 2,503.0

Atlantic mackerel 772.0 $2.13 $5.94 $16.76 1.9 4.8 12.5

Bluefish 1.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Striped bass 0.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Weakfish 29.0 $2.13 $5.94 $16.76 0.1 0.2 0.5

Total (small game) 801.0 $2.13 $5.94 $16.76 2.0 5.0 13.0

Atlantic Cod 1,104.0 $1.79 $2.98 $4.97 2.0 3.3 5.5

Cunner 91,836.0 $1.79 $2.98 $4.97 164.3 273.8 456.5

Pollock 3.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Sculpin 276,392.0 $1.79 $2.98 $4.97 494.4 823.9 1,374.0

Scup 111.0 $1.79 $2.98 $4.97 0.2 0.3 0.6

Searobin 713.0 $1.79 $2.98 $4.97 1.3 2.1 3.5

Tautog 12,253.0 $1.79 $2.98 $4.97 21.9 36.5 60.9

White Perch 0.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Total (other saltwater) 382,413.0 $1.79 $2.98 $4.97 684.0 1,140.0 1,901.0

Total (unidentified) 2,417.0 $1.80 $3.01 $5.03 4.0 7.0 12.0

Total (Undiscounted) 651,307.0 . . . 1,701.0 2,736.0 4,430.0

Total (3% discount rate) . . . . 1,018.0 1,638.0 2,652.0

Total (7% discount rate) . . . . 756.0 1,216.0 1,969.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-10

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-10: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 4 (I for Facilities > 50 MGD) in the North Atlantic Region, by Species

(2009$)

5

th Mean 95th 5th Mean 95th

Winter flounder 836.0 $3.81 $5.96 $9.42 3.0 5.0 8.0

Total (flatfish) 836.0 $3.81 $5.96 $9.42 3.0 5.0 8.0

Atlantic mackerel 0.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Bluefish 1.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Striped bass 0.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Weakfish 0.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Total (small game) 1.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Atlantic Cod 40.0 $1.79 $2.98 $4.97 0.1 0.1 0.2

Cunner 19.0 $1.79 $2.98 $4.97 0.0 0.0 0.1

Pollock 1.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Sculpin 345.0 $1.79 $2.98 $4.97 0.7 0.7 1.4

Scup 8.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Searobin 45.0 $1.79 $2.98 $4.97 0.1 0.1 0.2

Tautog 17.0 $1.79 $2.98 $4.97 0.0 0.0 0.1

White Perch 0.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Total (other saltwater) 476.0 $1.79 $2.98 $4.97 1.0 1.0 2.0

Total (unidentified) 181.0 $1.80 $3.01 $5.03 0.0 1.0 1.0

Total (Undiscounted) 1,495.0 . . . 4.0 7.0 11.0

Total (3% discount rate) . . . . 3.0 5.0 9.0

Total (7% discount rate) . . . . 3.0 5.0 8.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-11

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

I.3 Mid-Atlantic

Table I-11: Recreational Fishing Benefits from Eliminating Baseline I&E Mortality Losses at Inscope Facilities in the Mid-Atlantic Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Summer Flounder 5,310.0 $3.74 $5.62 $8.52 19.7 30.0 45.0

Winter Flounder 4,946.0 $3.74 $5.62 $8.52 18.3 28.0 42.0

Total (Flatfish) 10,256.0 $3.74 $5.62 $8.52 38.0 58.0 87.0

Black Crappie 3.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Bluegill 16.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Brown bullhead 3,847.0 $0.53 $1.06 $2.10 1.9 3.9 8.2

Bullhead 11.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Channel catfish 2,891.0 $0.53 $1.06 $2.10 1.5 2.9 6.2

Crappie 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Menhaden 966.0 $0.53 $1.06 $2.10 0.5 1.0 2.1

Sunfish 221.0 $0.53 $1.06 $2.10 0.1 0.2 0.5

Total (Panfish) 7,956.0 $0.53 $1.06 $2.10 4.0 8.0 17.0

Bluefish 126.0 $2.26 $5.90 $15.52 0.3 0.7 2.0

Red drum 2,667.0 $2.26 $5.90 $15.52 6.0 15.7 41.4

Spotted seatrout 1,768.0 $2.26 $5.90 $15.52 4.0 10.4 27.4

Striped bass 166,917.0 $2.26 $5.90 $15.52 377.4 985.1 2,589.8

Weakfish 459,710.0 $2.26 $5.90 $15.52 1,039.3 2,713.0 7,132.5

Total (Small Game) 631,187.0 $2.26 $5.90 $15.52 1,427.0 3,725.0 9,793.0

Northern pike 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Total (Walleye/Pike) 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Atlantic croaker 1,782,932.0 $1.85 $2.92 $4.60 3,304.3 5,205.0 8,205.4

Atlantic herring 57.0 $1.85 $2.92 $4.60 0.1 0.2 0.3

Black drum 255.0 $1.85 $2.92 $4.60 0.5 0.7 1.2

Cunner 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Scup 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Searobin 8.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Silver perch 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Smallmouth bass 57.0 $1.85 $2.92 $4.60 0.1 0.2 0.3

Spot 5,388,053.0 $1.85 $2.92 $4.60 9,985.6 15,729.6 24,796.9

Striped mullet 12.0 $1.85 $2.92 $4.60 0.0 0.0 0.1

Tautog 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

White perch 33,237.0 $1.85 $2.92 $4.60 61.6 97.0 153.0

Whitefish 426.0 $1.85 $2.92 $4.60 0.8 1.2 2.0

Total (Other Saltwater) 7,205,039.0 $1.85 $2.92 $4.60 13,353.0 21,034.0 33,159.0

Total (Unidentified) 1,226,622.0 $1.91 $3.24 $5.74 2,344.0 3,978.0 7,036.0

Total (Undiscounted) 9,081,061.0 . . . 17,166.0 28,803.0 50,092.0

Total (3% discount rate) . . . . 15,239.0 25,569.0 44,467.0

Total (7% discount rate) . . . . 14,721.0 24,701.0 42,958.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-12

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-12: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 1 (I Everywhere) in the Mid-Atlantic Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Summer Flounder 4,051.0 $3.74 $5.62 $8.52 15.1 23.1 34.7

Winter Flounder 499.0 $3.74 $5.62 $8.52 1.9 2.9 4.3

Total (Flatfish) 4,550.0 $3.74 $5.62 $8.52 17.0 26.0 39.0

Black Crappie 3.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Bluegill 12.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Brown bullhead 787.0 $0.53 $1.06 $2.10 0.5 0.7 1.7

Bullhead 8.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Channel catfish 2,205.0 $0.53 $1.06 $2.10 1.4 2.1 4.8

Crappie 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Menhaden 0.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Sunfish 169.0 $0.53 $1.06 $2.10 0.1 0.2 0.4

Total (Panfish) 3,185.0 $0.53 $1.06 $2.10 2.0 3.0 7.0

Bluefish 96.0 $2.26 $5.90 $15.52 0.2 0.6 1.5

Red drum 2,035.0 $2.26 $5.90 $15.52 4.6 12.0 31.6

Spotted seatrout 1,349.0 $2.26 $5.90 $15.52 3.0 8.0 20.9

Striped bass 796.0 $2.26 $5.90 $15.52 1.8 4.7 12.4

Weakfish 121,529.0 $2.26 $5.90 $15.52 274.3 716.8 1,885.7

Total (Small Game) 125,805.0 $2.26 $5.90 $15.52 284.0 742.0 1,952.0

Northern pike 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Total (Walleye/Pike) 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Atlantic croaker 19,396.0 $1.85 $2.92 $4.60 35.9 56.6 89.3

Atlantic herring 43.0 $1.85 $2.92 $4.60 0.1 0.1 0.2

Black drum 195.0 $1.85 $2.92 $4.60 0.4 0.6 0.9

Cunner 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Scup 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Searobin 5.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Silver perch 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Smallmouth bass 44.0 $1.85 $2.92 $4.60 0.1 0.1 0.2

Spot 318,070.0 $1.85 $2.92 $4.60 589.2 928.2 1,464.2

Striped mullet 9.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Tautog 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

White perch 2,541.0 $1.85 $2.92 $4.60 4.7 7.4 11.7

Whitefish 325.0 $1.85 $2.92 $4.60 0.6 0.9 1.5

Total (Other Saltwater) 340,629.0 $1.85 $2.92 $4.60 631.0 994.0 1,568.0

Total (Unidentified) 74,846.0 $1.91 $3.24 $5.74 143.0 243.0 429.0

Total (Undiscounted) 549,015.0 . . . 1,077.0 2,009.0 3,994.0

Total (3% discount rate) . . . . 846.0 1,577.0 3,136.0

Total (7% discount rate) . . . . 749.0 1,396.0 2,776.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-13

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-13: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 2 (I Everywhere and E for Facilities > 125 MGD) in the Mid-Atlantic

Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Summer Flounder 5,180.0 $3.74 $5.62 $8.52 19.1 29.2 44.1

Winter Flounder 4,569.0 $3.74 $5.62 $8.52 16.9 25.8 38.9

Total (Flatfish) 9,749.0 $3.74 $5.62 $8.52 36.0 55.0 83.0

Black Crappie 3.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Bluegill 16.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Brown bullhead 3,585.0 $0.53 $1.06 $2.10 1.9 3.8 7.6

Bullhead 10.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Channel catfish 2,820.0 $0.53 $1.06 $2.10 1.5 3.0 6.0

Crappie 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Menhaden 885.0 $0.53 $1.06 $2.10 0.5 0.9 1.9

Sunfish 216.0 $0.53 $1.06 $2.10 0.1 0.2 0.5

Total (Panfish) 7,536.0 $0.53 $1.06 $2.10 4.0 8.0 16.0

Bluefish 123.0 $2.26 $5.90 $15.52 0.3 0.7 1.9

Red drum 2,602.0 $2.26 $5.90 $15.52 5.9 15.4 40.4

Spotted seatrout 1,724.0 $2.26 $5.90 $15.52 3.9 10.2 26.7

Striped bass 152,927.0 $2.26 $5.90 $15.52 345.7 902.6 2,372.8

Weakfish 430,538.0 $2.26 $5.90 $15.52 973.2 2,541.1 6,680.2

Total (Small Game) 587,915.0 $2.26 $5.90 $15.52 1,329.0 3,470.0 9,122.0

Northern pike 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Total (Walleye/Pike) 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Atlantic croaker 1,634,350.0 $1.85 $2.92 $4.60 3,028.8 4,771.2 7,521.5

Atlantic herring 55.0 $1.85 $2.92 $4.60 0.1 0.2 0.3

Black drum 249.0 $1.85 $2.92 $4.60 0.5 0.7 1.1

Cunner 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Scup 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Searobin 8.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Silver perch 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Smallmouth bass 56.0 $1.85 $2.92 $4.60 0.1 0.2 0.3

Spot 4,959,382.0 $1.85 $2.92 $4.60 9,190.9 14,478.0 22,823.8

Striped mullet 12.0 $1.85 $2.92 $4.60 0.0 0.0 0.1

Tautog 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

White perch 30,638.0 $1.85 $2.92 $4.60 56.8 89.4 141.0

Whitefish 415.0 $1.85 $2.92 $4.60 0.8 1.2 1.9

Total (Other Saltwater) 6,625,167.0 $1.85 $2.92 $4.60 12,278.0 19,341.0 30,490.0

Total (Unidentified) 1,129,224.0 $1.91 $3.24 $5.74 2,158.0 3,662.0 6,477.0

Total (Undiscounted) 8,359,591.0 . . . 15,805.0 26,536.0 46,188.0

Total (3% discount rate) . . . . 8,381.0 14,073.0 24,501.0

Total (7% discount rate) . . . . 5,831.0 9,792.0 17,049.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-14

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-14: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 3 (I&E Mortality Everywhere) in the Mid-Atlantic Region, by Species

(2009$)

5

th Mean 95th 5th Mean 95th

Summer Flounder 5,198.0 $3.74 $5.62 $8.52 19.6 29.1 44.5

Winter Flounder 4,622.0 $3.74 $5.62 $8.52 17.4 25.9 39.5

Total (Flatfish) 9,820.0 $3.74 $5.62 $8.52 37.0 55.0 84.0

Black Crappie 3.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Bluegill 16.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Brown bullhead 3,622.0 $0.53 $1.06 $2.10 1.9 3.8 7.6

Bullhead 10.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Channel catfish 2,830.0 $0.53 $1.06 $2.10 1.5 3.0 6.0

Crappie 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Menhaden 896.0 $0.53 $1.06 $2.10 0.5 0.9 1.9

Sunfish 216.0 $0.53 $1.06 $2.10 0.1 0.2 0.5

Total (Panfish) 7,595.0 $0.53 $1.06 $2.10 4.0 8.0 16.0

Bluefish 123.0 $2.26 $5.90 $15.52 0.3 0.7 1.9

Red drum 2,611.0 $2.26 $5.90 $15.52 5.9 15.4 40.5

Spotted seatrout 1,730.0 $2.26 $5.90 $15.52 3.9 10.2 26.8

Striped bass 154,871.0 $2.26 $5.90 $15.52 350.2 914.0 2,402.9

Weakfish 434,593.0 $2.26 $5.90 $15.52 982.7 2,564.7 6,742.8

Total (Small Game) 593,930.0 $2.26 $5.90 $15.52 1,343.0 3,505.0 9,215.0

Northern pike 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Total (Walleye/Pike) 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Atlantic croaker 1,655,004.0 $1.85 $2.92 $4.60 3,067.0 4,831.4 7,616.6

Atlantic herring 55.0 $1.85 $2.92 $4.60 0.1 0.2 0.3

Black drum 250.0 $1.85 $2.92 $4.60 0.5 0.7 1.2

Cunner 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Scup 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Searobin 8.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Silver perch 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Smallmouth bass 56.0 $1.85 $2.92 $4.60 0.1 0.2 0.3

Spot 5,018,970.0 $1.85 $2.92 $4.60 9,301.1 14,651.8 23,098.1

Striped mullet 12.0 $1.85 $2.92 $4.60 0.0 0.0 0.1

Tautog 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

White perch 30,999.0 $1.85 $2.92 $4.60 57.4 90.5 142.7

Whitefish 417.0 $1.85 $2.92 $4.60 0.8 1.2 1.9

Total (Other Saltwater) 6,705,773.0 $1.85 $2.92 $4.60 12,427.0 19,576.0 30,861.0

Total (Unidentified) 1,142,763.0 $1.91 $3.24 $5.74 2,183.0 3,706.0 6,555.0

Total (Undiscounted) 8,459,880.0 . . . 15,995.0 26,851.0 46,731.0

Total (3% discount rate) . . . . 8,584.0 14,410.0 25,078.0

Total (7% discount rate) . . . . 5,975.0 10,030.0 17,456.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-15

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-15: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 4 (I for Facilities > 50 MGD) in the Mid-Atlantic Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Summer Flounder 4,047.0 $3.74 $5.62 $8.52 15.1 23.1 34.7

Winter Flounder 499.0 $3.74 $5.62 $8.52 1.9 2.9 4.3

Total (Flatfish) 4,546.0 $3.74 $5.62 $8.52 17.0 26.0 39.0

Black Crappie 3.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Bluegill 12.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Brown bullhead 786.0 $0.53 $1.06 $2.10 0.5 0.7 1.7

Bullhead 8.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Channel catfish 2,203.0 $0.53 $1.06 $2.10 1.4 2.1 4.8

Crappie 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Menhaden 0.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Sunfish 169.0 $0.53 $1.06 $2.10 0.1 0.2 0.4

Total (Panfish) 3,182.0 $0.53 $1.06 $2.10 2.0 3.0 7.0

Bluefish 96.0 $2.26 $5.90 $15.52 0.2 0.6 1.5

Red drum 2,033.0 $2.26 $5.90 $15.52 4.6 12.0 31.5

Spotted seatrout 1,347.0 $2.26 $5.90 $15.52 3.0 8.0 20.9

Striped bass 796.0 $2.26 $5.90 $15.52 1.8 4.7 12.3

Weakfish 121,415.0 $2.26 $5.90 $15.52 274.3 716.8 1,883.7

Total (Small Game) 125,687.0 $2.26 $5.90 $15.52 284.0 742.0 1,950.0

Northern pike 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Total (Walleye/Pike) 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Atlantic croaker 19,377.0 $1.85 $2.92 $4.60 35.9 56.5 89.2

Atlantic herring 43.0 $1.85 $2.92 $4.60 0.1 0.1 0.2

Black drum 195.0 $1.85 $2.92 $4.60 0.4 0.6 0.9

Cunner 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Scup 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Searobin 5.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Silver perch 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Smallmouth bass 44.0 $1.85 $2.92 $4.60 0.1 0.1 0.2

Spot 317,770.0 $1.85 $2.92 $4.60 589.2 927.2 1,462.3

Striped mullet 9.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Tautog 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

White perch 2,538.0 $1.85 $2.92 $4.60 4.7 7.4 11.7

Whitefish 324.0 $1.85 $2.92 $4.60 0.6 0.9 1.5

Total (Other Saltwater) 340,307.0 $1.85 $2.92 $4.60 631.0 993.0 1,566.0

Total (Unidentified) 74,775.0 $1.91 $3.24 $5.74 143.0 243.0 429.0

Total (Undiscounted) 548,496.0 . . . 1,076.0 2,007.0 3,991.0

Total (3% discount rate) . . . . 845.0 1,576.0 3,133.0

Total (7% discount rate) . . . . 748.0 1,395.0 2,773.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-16

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

I.4 South Atlantic

Table I-16: Recreational Fishing Benefits from Eliminating Baseline I&E Mortality Losses at Inscope Facilities in the South Atlantic Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Flounders 778.0 $3.87 $5.61 $8.28 3.0 4.0 6.0

Total (Flatfish) 778.0 $3.87 $5.61 $8.28 3.0 4.0 6.0

Spotted seatrout 1,898.0 $2.72 $5.72 $12.04 4.8 10.5 22.6

Weakfish 455.0 $2.72 $5.72 $12.04 1.2 2.5 5.4

Total (Small Game) 2,353.0 $2.72 $5.72 $12.04 6.0 13.0 28.0

Croakers 96,913.0 $2.14 $2.85 $3.78 207.6 276.1 365.6

Pinfish 1,518.0 $2.14 $2.85 $3.78 3.3 4.3 5.7

Silver perch 76.0 $2.14 $2.85 $3.78 0.2 0.2 0.3

Spot 30,313.0 $2.14 $2.85 $3.78 64.9 86.4 114.4

Total (Other Saltwater) 128,820.0 $2.14 $2.85 $3.78 276.0 367.0 486.0

Total (Unidentified) 1,945.0 $2.15 $2.86 $3.82 4.0 6.0 7.0

Total (Undiscounted) 133,897.0 . . . 290.0 390.0 529.0

Total (3% discount rate) . . . . 257.0 346.0 469.0

Total (7% discount rate) . . . . 249.0 335.0 453.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)

Table I-17: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 1 (I Everywhere) in the South Atlantic Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Flounders 491.0 $3.87 $5.61 $8.28 2.0 3.0 4.0

Total (Flatfish) 491.0 $3.87 $5.61 $8.28 2.0 3.0 4.0

Spotted seatrout 0.0 $2.72 $5.72 $12.04 0.0 0.0 0.0

Weakfish 224.0 $2.72 $5.72 $12.04 1.0 1.0 3.0

Total (Small Game) 224.0 $2.72 $5.72 $12.04 1.0 1.0 3.0

Croakers 1,762.0 $2.14 $2.85 $3.78 3.8 5.0 6.7

Pinfish 0.0 $2.14 $2.85 $3.78 0.0 0.0 0.0

Silver perch 48.0 $2.14 $2.85 $3.78 0.1 0.1 0.2

Spot 12,733.0 $2.14 $2.85 $3.78 27.1 35.9 48.2

Total (Other Saltwater) 14,543.0 $2.14 $2.85 $3.78 31.0 41.0 55.0

Total (Unidentified) 624.0 $2.15 $2.86 $3.82 1.0 2.0 2.0

Total (Undiscounted) 15,882.0 . . . 35.0 47.0 64.0

Total (3% discount rate) . . . . 28.0 37.0 50.0

Total (7% discount rate) . . . . 24.0 33.0 45.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-17

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-18: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 2 (I Everywhere and E for Facilities > 125 MGD) in the South Atlantic

Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Flounders 663.0 $3.87 $5.61 $8.28 3.0 4.0 5.0

Total (Flatfish) 663.0 $3.87 $5.61 $8.28 3.0 4.0 5.0

Spotted seatrout 1,583.0 $2.72 $5.72 $12.04 4.0 8.8 19.3

Weakfish 386.0 $2.72 $5.72 $12.04 1.0 2.2 4.7

Total (Small Game) 1,969.0 $2.72 $5.72 $12.04 5.0 11.0 24.0

Croakers 80,881.0 $2.14 $2.85 $3.78 173.2 230.2 305.2

Pinfish 1,266.0 $2.14 $2.85 $3.78 2.7 3.6 4.8

Silver perch 65.0 $2.14 $2.85 $3.78 0.1 0.2 0.2

Spot 25,654.0 $2.14 $2.85 $3.78 54.9 73.0 96.8

Total (Other Saltwater) 107,866.0 $2.14 $2.85 $3.78 231.0 307.0 407.0

Total (Unidentified) 1,641.0 $2.15 $2.86 $3.82 4.0 5.0 6.0

Total (Undiscounted) 112,139.0 . . . 243.0 327.0 443.0

Total (3% discount rate) . . . . 141.0 190.0 257.0

Total (7% discount rate) . . . . 103.0 139.0 188.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)

Table I-19: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 3 (I&E Mortality Everywhere) in the South Atlantic Region, by Species

(2009$)

5

th Mean 95th 5th Mean 95th

Flounders 663.0 $3.87 $5.61 $8.28 3.0 4.0 5.0

Total (Flatfish) 663.0 $3.87 $5.61 $8.28 3.0 4.0 5.0

Spotted seatrout 1,586.0 $2.72 $5.72 $12.04 4.0 8.8 19.3

Weakfish 387.0 $2.72 $5.72 $12.04 1.0 2.2 4.7

Total (Small Game) 1,972.0 $2.72 $5.72 $12.04 5.0 11.0 24.0

Croakers 81,012.0 $2.14 $2.85 $3.78 174.0 231.0 306.0

Pinfish 1,268.0 $2.14 $2.85 $3.78 2.7 3.6 4.8

Silver perch 65.0 $2.14 $2.85 $3.78 0.1 0.2 0.2

Spot 25,677.0 $2.14 $2.85 $3.78 55.1 73.2 97.0

Total (Other Saltwater) 108,023.0 $2.14 $2.85 $3.78 232.0 308.0 408.0

Total (Unidentified) 1,642.0 $2.15 $2.86 $3.82 4.0 5.0 6.0

Total (Undiscounted) 112,301.0 . . . 243.0 327.0 443.0

Total (3% discount rate) . . . . 141.0 190.0 257.0

Total (7% discount rate) . . . . 103.0 139.0 188.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-18

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-20: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 4 (I for Facilities > 50 MGD) in the South Atlantic Region, by Species

(2009$)

5

th Mean 95th 5th Mean 95th

Flounders 491.0 $3.87 $5.61 $8.28 2.0 3.0 4.0

Total (Flatfish) 491.0 $3.87 $5.61 $8.28 2.0 3.0 4.0

Spotted seatrout 0.0 $2.72 $5.72 $12.04 0.0 0.0 0.0

Weakfish 224.0 $2.72 $5.72 $12.04 1.0 1.0 3.0

Total (Small Game) 224.0 $2.72 $5.72 $12.04 1.0 1.0 3.0

Croakers 1,762.0 $2.14 $2.85 $3.78 3.8 5.0 6.7

Pinfish 0.0 $2.14 $2.85 $3.78 0.0 0.0 0.0

Silver perch 48.0 $2.14 $2.85 $3.78 0.1 0.1 0.2

Spot 12,733.0 $2.14 $2.85 $3.78 27.1 35.9 48.2

Total (Other Saltwater) 14,543.0 $2.14 $2.85 $3.78 31.0 41.0 55.0

Total (Unidentified) 624.0 $2.15 $2.86 $3.82 1.0 2.0 2.0

Total (Undiscounted) 15,882.0 . . . 35.0 47.0 64.0

Total (3% discount rate) . . . . 28.0 37.0 50.0

Total (7% discount rate) . . . . 24.0 33.0 45.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)

Gulf of Mexico

Table I-21: Recreational Fishing Benefits from Eliminating Baseline I&E Mortality Losses at Inscope Facilities in the Gulf of Mexico Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Mackerels 1,156.0 $2.87 $5.63 $11.04 3.3 6.5 12.8

Red drum 26,719.0 $2.87 $5.63 $11.04 76.6 150.4 294.9

Spotted seatrout 512,503.0 $2.87 $5.63 $11.04 1,470.0 2,885.1 5,656.4

Total (Small Game) 540,378.0 $2.87 $5.63 $11.04 1,550.0 3,042.0 5,964.0

Atlantic croaker 179,036.0 $2.14 $2.78 $3.61 382.3 497.3 646.6

Black drum 1,542,661.0 $2.14 $2.78 $3.61 3,294.3 4,284.6 5,571.5

Pinfish 257,750.0 $2.14 $2.78 $3.61 550.4 715.9 930.9

Sea bass 119.0 $2.14 $2.78 $3.61 0.3 0.3 0.4

Searobin 118,160.0 $2.14 $2.78 $3.61 252.3 328.2 426.7

Sheepshead 46.0 $2.14 $2.78 $3.61 0.1 0.1 0.2

Silver perch 1,474.0 $2.14 $2.78 $3.61 3.1 4.1 5.3

Spot 30,308.0 $2.14 $2.78 $3.61 64.7 84.2 109.5

Striped mullet 49,804.0 $2.14 $2.78 $3.61 106.4 138.3 179.9

Total (Other Saltwater) 2,179,358.0 $2.14 $2.78 $3.61 4,654.0 6,053.0 7,871.0

Total (Unidentified) 131,612.0 $2.36 $3.66 $5.91 311.0 482.0 778.0

Total (Undiscounted) 2,851,347.0 . . . 6,515.0 9,576.0 14,612.0

Total (3% discount rate) . . . . 6,022.0 8,852.0 13,506.0

Total (7% discount rate) . . . . 5,999.0 8,818.0 13,456.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-19

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-22: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 1 (I Everywhere) in the Gulf of Mexico Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Mackerels 885.0 $2.87 $5.63 $11.04 2.5 5.0 9.8

Red drum 17,368.0 $2.87 $5.63 $11.04 49.8 97.8 191.7

Spotted seatrout 351,547.0 $2.87 $5.63 $11.04 1,008.6 1,979.2 3,879.6

Total (Small Game) 369,800.0 $2.87 $5.63 $11.04 1,061.0 2,082.0 4,081.0

Atlantic croaker 136,979.0 $2.14 $2.78 $3.61 292.8 380.2 494.6

Black drum 2,576.0 $2.14 $2.78 $3.61 5.5 7.1 9.3

Pinfish 5,161.0 $2.14 $2.78 $3.61 11.0 14.3 18.6

Sea bass 91.0 $2.14 $2.78 $3.61 0.2 0.3 0.3

Searobin 65,096.0 $2.14 $2.78 $3.61 139.1 180.7 235.0

Sheepshead 0.0 $2.14 $2.78 $3.61 0.0 0.0 0.0

Silver perch 59.0 $2.14 $2.78 $3.61 0.1 0.2 0.2

Spot 18,785.0 $2.14 $2.78 $3.61 40.1 52.1 67.8

Striped mullet 4,732.0 $2.14 $2.78 $3.61 10.1 13.1 17.1

Total (Other Saltwater) 233,480.0 $2.14 $2.78 $3.61 499.0 648.0 843.0

Total (Unidentified) 62,417.0 $2.36 $3.66 $5.91 147.0 228.0 369.0

Total (Undiscounted) 665,697.0 . . . 1,707.0 2,959.0 5,293.0

Total (3% discount rate) . . . . 1,398.0 2,422.0 4,334.0

Total (7% discount rate) . . . . 1,275.0 2,210.0 3,953.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-20

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-23: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 2 (I Everywhere and E for Facilities > 125 MGD) in the Gulf of Mexico

Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Mackerels 1,148.0 $2.87 $5.63 $11.04 3.3 6.5 12.7

Red drum 25,256.0 $2.87 $5.63 $11.04 72.5 142.2 278.7

Spotted seatrout 492,047.0 $2.87 $5.63 $11.04 1,412.2 2,770.3 5,430.6

Total (Small Game) 518,450.0 $2.87 $5.63 $11.04 1,488.0 2,919.0 5,722.0

Atlantic croaker 177,750.0 $2.14 $2.78 $3.61 379.5 493.6 642.0

Black drum 1,044,602.0 $2.14 $2.78 $3.61 2,230.5 2,900.8 3,772.7

Pinfish 176,490.0 $2.14 $2.78 $3.61 376.9 490.1 637.4

Sea bass 119.0 $2.14 $2.78 $3.61 0.3 0.3 0.4

Searobin 106,846.0 $2.14 $2.78 $3.61 228.1 296.7 385.9

Sheepshead 31.0 $2.14 $2.78 $3.61 0.1 0.1 0.1

Silver perch 1,021.0 $2.14 $2.78 $3.61 2.2 2.8 3.7

Spot 28,270.0 $2.14 $2.78 $3.61 60.4 78.5 102.1

Striped mullet 35,647.0 $2.14 $2.78 $3.61 76.1 99.0 128.7

Total (Other Saltwater) 1,570,775.0 $2.14 $2.78 $3.61 3,354.0 4,362.0 5,673.0

Total (Unidentified) 114,838.0 $2.36 $3.66 $5.91 271.0 420.0 679.0

Total (Undiscounted) 2,204,063.0 . . . 5,113.0 7,701.0 12,073.0

Total (3% discount rate) . . . . 3,225.0 4,866.0 7,642.0

Total (7% discount rate) . . . . 2,491.0 3,760.0 5,908.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-21

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-24: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 3 (I&E Mortality Everywhere) in the Gulf of Mexico Region, by Species

(2009$)

5

th Mean 95th 5th Mean 95th

Mackerels 1,149.0 $2.87 $5.63 $11.04 3.3 6.5 12.7

Red drum 25,279.0 $2.87 $5.63 $11.04 72.5 142.3 279.0

Spotted seatrout 492,479.0 $2.87 $5.63 $11.04 1,413.2 2,772.2 5,435.3

Total (Small Game) 518,907.0 $2.87 $5.63 $11.04 1,489.0 2,921.0 5,727.0

Atlantic croaker 177,884.0 $2.14 $2.78 $3.61 379.8 494.1 642.4

Black drum 1,047,164.0 $2.14 $2.78 $3.61 2,235.9 2,908.4 3,781.9

Pinfish 176,912.0 $2.14 $2.78 $3.61 377.7 491.4 638.9

Sea bass 119.0 $2.14 $2.78 $3.61 0.3 0.3 0.4

Searobin 106,965.0 $2.14 $2.78 $3.61 228.4 297.1 386.3

Sheepshead 31.0 $2.14 $2.78 $3.61 0.1 0.1 0.1

Silver perch 1,024.0 $2.14 $2.78 $3.61 2.2 2.8 3.7

Spot 28,298.0 $2.14 $2.78 $3.61 60.4 78.6 102.2

Striped mullet 35,724.0 $2.14 $2.78 $3.61 76.3 99.2 129.0

Total (Other Saltwater) 1,574,119.0 $2.14 $2.78 $3.61 3,361.0 4,372.0 5,685.0

Total (Unidentified) 114,982.0 $2.36 $3.66 $5.91 272.0 421.0 680.0

Total (Undiscounted) 2,208,009.0 . . . 5,122.0 7,714.0 12,091.0

Total (3% discount rate) . . . . 3,258.0 4,906.0 7,690.0

Total (7% discount rate) . . . . 2,510.0 3,781.0 5,926.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-22

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-25: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 4 (I for Facilities > 50 MGD) in the Gulf of Mexico Region, by Species

(2009$)

5

th Mean 95th 5th Mean 95th

Mackerels 878.0 $2.87 $5.63 $11.04 2.5 4.9 9.7

Red drum 17,237.0 $2.87 $5.63 $11.04 49.5 97.0 190.2

Spotted seatrout 348,894.0 $2.87 $5.63 $11.04 1,001.0 1,964.0 3,850.1

Total (Small Game) 367,009.0 $2.87 $5.63 $11.04 1,053.0 2,066.0 4,050.0

Atlantic croaker 135,945.0 $2.14 $2.78 $3.61 290.4 377.8 491.1

Black drum 2,556.0 $2.14 $2.78 $3.61 5.5 7.1 9.2

Pinfish 5,122.0 $2.14 $2.78 $3.61 10.9 14.2 18.5

Sea bass 91.0 $2.14 $2.78 $3.61 0.2 0.3 0.3

Searobin 64,604.0 $2.14 $2.78 $3.61 138.0 179.6 233.4

Sheepshead 0.0 $2.14 $2.78 $3.61 0.0 0.0 0.0

Silver perch 58.0 $2.14 $2.78 $3.61 0.1 0.2 0.2

Spot 18,644.0 $2.14 $2.78 $3.61 39.8 51.8 67.3

Striped mullet 4,696.0 $2.14 $2.78 $3.61 10.0 13.1 17.0

Total (Other Saltwater) 231,717.0 $2.14 $2.78 $3.61 495.0 644.0 837.0

Total (Unidentified) 61,946.0 $2.36 $3.66 $5.91 146.0 227.0 366.0

Total (Undiscounted) 660,672.0 . . . 1,694.0 2,936.0 5,253.0

Total (3% discount rate) . . . . 1,387.0 2,404.0 4,301.0

Total (7% discount rate) . . . . 1,265.0 2,193.0 3,923.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-23

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

I.5 Great Lakes

Table I-26: Recreational Fishing Benefits from Eliminating Baseline I&E Mortality Losses at Inscope Facilities in the Great Lakes Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Smallmouth bass 23.0 $4.42 $8.56 $16.61 0.1 203.0 394.0

White bass 23,688.0 $4.42 $8.56 $16.61 104.9 203.0 394.0

Total (Bass) 23,710.0 $4.42 $8.56 $16.61 105.0 203.0 394.0

Whitefish 69,428.0 $6.10 $9.43 $14.66 424.0 655.0 1,018.0

Total (Other Trout) 69,428.0 $6.10 $9.43 $14.66 424.0 655.0 1,018.0

Black crappie 11.0 $0.70 $1.33 $2.50 0.0 0.0 0.0

Bluegill 27.0 $0.70 $1.33 $2.50 0.0 0.0 0.1

Channel catfish 571.0 $0.70 $1.33 $2.50 0.4 0.8 1.4

Crappie 4,785.0 $0.70 $1.33 $2.50 3.3 6.3 12.0

Rainbow smelt 5,802.0 $0.70 $1.33 $2.50 4.1 7.7 14.5

Sculpin 6,516.0 $0.70 $1.33 $2.50 4.6 8.6 16.3

Smelts 14,657.0 $0.70 $1.33 $2.50 10.2 19.3 36.6

Sunfish 13,996.0 $0.70 $1.33 $2.50 9.8 18.5 35.0

Yellow perch 18,055.0 $0.70 $1.33 $2.50 12.6 23.8 45.1

Total (Panfish) 64,420.0 $0.70 $1.33 $2.50 45.0 85.0 161.0

Salmon 1,253.0 $8.16 $13.27 $21.61 10.0 17.0 27.0

Total (Salmon) 1,253.0 $8.16 $13.27 $21.61 10.0 17.0 27.0

Northern Pike 0.0 $2.18 $4.11 $7.80 0.0 0.0 0.0

Walleye 250.0 $2.18 $4.11 $7.80 1.0 1.0 2.0

Total (Walleye/Pike) 250.0 $2.18 $4.11 $7.80 1.0 1.0 2.0

Total (Unidentified) 190,587.0 $3.33 $6.22 $11.71 635.0 1,185.0 2,232.0

Total (Undiscounted) 349,648.0 . . . 1,219.0 2,146.0 3,834.0

Total (3% discount rate) . . . . 1,127.0 1,984.0 3,544.0

Total (7% discount rate) . . . . 1,123.0 1,977.0 3,530.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-24

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-27: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 1 (I Everywhere) in the Great Lakes Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Smallmouth bass 19.0 $4.42 $8.56 $16.61 0.1 60.0 116.0

White bass 6,939.0 $4.42 $8.56 $16.61 30.9 60.0 116.0

Total (Bass) 6,958.0 $4.42 $8.56 $16.61 31.0 60.0 116.0

Whitefish 60,141.0 $6.10 $9.43 $14.66 367.0 567.0 882.0

Total (Other Trout) 60,141.0 $6.10 $9.43 $14.66 367.0 567.0 882.0

Black crappie 9.0 $0.70 $1.33 $2.50 0.0 0.0 0.0

Bluegill 23.0 $0.70 $1.33 $2.50 0.0 0.0 0.1

Channel catfish 460.0 $0.70 $1.33 $2.50 0.3 0.6 1.1

Crappie 112.0 $0.70 $1.33 $2.50 0.1 0.1 0.3

Rainbow smelt 4,248.0 $0.70 $1.33 $2.50 2.9 5.6 10.6

Sculpin 290.0 $0.70 $1.33 $2.50 0.2 0.4 0.7

Smelts 12,641.0 $0.70 $1.33 $2.50 8.7 16.6 31.6

Sunfish 192.0 $0.70 $1.33 $2.50 0.1 0.3 0.5

Yellow perch 12,437.0 $0.70 $1.33 $2.50 8.6 16.4 31.1

Total (Panfish) 30,413.0 $0.70 $1.33 $2.50 21.0 40.0 76.0

Salmon 845.0 $8.16 $13.27 $21.61 7.0 11.0 18.0

Total (Salmon) 845.0 $8.16 $13.27 $21.61 7.0 11.0 18.0

Northern Pike 0.0 $2.18 $4.11 $7.80 0.0 0.0 0.0

Walleye 217.0 $2.18 $4.11 $7.80 0.0 1.0 2.0

Total (Walleye/Pike) 217.0 $2.18 $4.11 $7.80 0.0 1.0 2.0

Total (Unidentified) 77,515.0 $3.33 $6.22 $11.71 258.0 482.0 908.0

Total (Undiscounted) 176,089.0 . . . 685.0 1,162.0 2,001.0

Total (3% discount rate) . . . . 561.0 951.0 1,638.0

Total (7% discount rate) . . . . 511.0 867.0 1,495.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-25

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-28: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 2 (I Everywhere and E for Facilities > 125 MGD) in the Great Lakes

Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Smallmouth bass 22.0 $4.42 $8.56 $16.61 0.1 175.0 340.0

White bass 20,444.0 $4.42 $8.56 $16.61 90.9 175.0 340.0

Total (Bass) 20,466.0 $4.42 $8.56 $16.61 91.0 175.0 340.0

Whitefish 68,676.0 $6.10 $9.43 $14.66 419.0 648.0 1,007.0

Total (Other Trout) 68,676.0 $6.10 $9.43 $14.66 419.0 648.0 1,007.0

Black crappie 10.0 $0.70 $1.33 $2.50 0.0 0.0 0.0

Bluegill 27.0 $0.70 $1.33 $2.50 0.0 0.0 0.1

Channel catfish 557.0 $0.70 $1.33 $2.50 0.4 0.7 1.4

Crappie 3,846.0 $0.70 $1.33 $2.50 2.7 5.1 9.6

Rainbow smelt 5,568.0 $0.70 $1.33 $2.50 3.9 7.4 13.9

Sculpin 5,267.0 $0.70 $1.33 $2.50 3.7 7.0 13.1

Smelts 14,487.0 $0.70 $1.33 $2.50 10.2 19.2 36.1

Sunfish 11,220.0 $0.70 $1.33 $2.50 7.9 14.9 28.0

Yellow perch 17,155.0 $0.70 $1.33 $2.50 12.1 22.7 42.8

Total (Panfish) 58,137.0 $0.70 $1.33 $2.50 41.0 77.0 145.0

Salmon 1,187.0 $8.16 $13.27 $21.61 10.0 16.0 26.0

Total (Salmon) 1,187.0 $8.16 $13.27 $21.61 10.0 16.0 26.0

Northern Pike 0.0 $2.18 $4.11 $7.80 0.0 0.0 0.0

Walleye 247.0 $2.18 $4.11 $7.80 1.0 1.0 2.0

Total (Walleye/Pike) 248.0 $2.18 $4.11 $7.80 1.0 1.0 2.0

Total (Unidentified) 169,259.0 $3.33 $6.22 $11.71 564.0 1,053.0 1,982.0

Total (Undiscounted) 317,974.0 . . . 1,124.0 1,970.0 3,502.0

Total (3% discount rate) . . . . 720.0 1,261.0 2,241.0

Total (7% discount rate) . . . . 559.0 979.0 1,739.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-26

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-29: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 3 (I&E Mortality Everywhere) in the Great Lakes Region, by Species

(2009$)

5

th Mean 95th 5th Mean 95th

Smallmouth bass 23.0 $4.42 $8.56 $16.61 0.1 177.0 343.0

White bass 20,651.0 $4.42 $8.56 $16.61 90.9 177.0 343.0

Total (Bass) 20,674.0 $4.42 $8.56 $16.61 91.0 177.0 343.0

Whitefish 68,832.0 $6.10 $9.43 $14.66 420.0 649.0 1,009.0

Total (Other Trout) 68,832.0 $6.10 $9.43 $14.66 420.0 649.0 1,009.0

Black crappie 10.0 $0.70 $1.33 $2.50 0.0 0.0 0.0

Bluegill 27.0 $0.70 $1.33 $2.50 0.0 0.0 0.1

Channel catfish 559.0 $0.70 $1.33 $2.50 0.4 0.7 1.4

Crappie 3,902.0 $0.70 $1.33 $2.50 2.7 5.2 9.7

Rainbow smelt 5,590.0 $0.70 $1.33 $2.50 3.9 7.4 13.9

Sculpin 5,343.0 $0.70 $1.33 $2.50 3.7 7.1 13.3

Smelts 14,520.0 $0.70 $1.33 $2.50 10.2 19.3 36.2

Sunfish 11,386.0 $0.70 $1.33 $2.50 8.0 15.2 28.4

Yellow perch 17,232.0 $0.70 $1.33 $2.50 12.1 22.9 43.0

Total (Panfish) 58,570.0 $0.70 $1.33 $2.50 41.0 78.0 146.0

Salmon 1,192.0 $8.16 $13.27 $21.61 10.0 16.0 26.0

Total (Salmon) 1,192.0 $8.16 $13.27 $21.61 10.0 16.0 26.0

Northern Pike 0.0 $2.18 $4.11 $7.80 0.0 0.0 0.0

Walleye 248.0 $2.18 $4.11 $7.80 1.0 1.0 2.0

Total (Walleye/Pike) 248.0 $2.18 $4.11 $7.80 1.0 1.0 2.0

Total (Unidentified) 170,680.0 $3.33 $6.22 $11.71 569.0 1,062.0 1,999.0

Total (Undiscounted) 320,196.0 . . . 1,131.0 1,982.0 3,526.0

Total (3% discount rate) . . . . 725.0 1,271.0 2,261.0

Total (7% discount rate) . . . . 561.0 984.0 1,750.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-27

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-30: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 4 (I for Facilities > 50 <MGD) in the Great Lakes Region, by Species

(2009$)

5

th Mean 95th 5th Mean 95th

Smallmouth bass 19.0 $4.42 $8.56 $16.61 0.1 59.0 115.0

White bass 6,880.0 $4.42 $8.56 $16.61 30.9 59.0 115.0

Total (Bass) 6,900.0 $4.42 $8.56 $16.61 31.0 59.0 115.0

Whitefish 59,632.0 $6.10 $9.43 $14.66 364.0 563.0 874.0

Total (Other Trout) 59,632.0 $6.10 $9.43 $14.66 364.0 563.0 874.0

Black crappie 9.0 $0.70 $1.33 $2.50 0.0 0.0 0.0

Bluegill 23.0 $0.70 $1.33 $2.50 0.0 0.0 0.1

Channel catfish 456.0 $0.70 $1.33 $2.50 0.3 0.6 1.1

Crappie 111.0 $0.70 $1.33 $2.50 0.1 0.1 0.3

Rainbow smelt 4,212.0 $0.70 $1.33 $2.50 2.9 5.6 10.5

Sculpin 287.0 $0.70 $1.33 $2.50 0.2 0.4 0.7

Smelts 12,534.0 $0.70 $1.33 $2.50 8.7 16.6 31.2

Sunfish 190.0 $0.70 $1.33 $2.50 0.1 0.3 0.5

Yellow perch 12,332.0 $0.70 $1.33 $2.50 8.6 16.4 30.7

Total (Panfish) 30,156.0 $0.70 $1.33 $2.50 21.0 40.0 75.0

Salmon 838.0 $8.16 $13.27 $21.61 7.0 11.0 18.0

Total (Salmon) 838.0 $8.16 $13.27 $21.61 7.0 11.0 18.0

Northern Pike 0.0 $2.18 $4.11 $7.80 0.0 0.0 0.0

Walleye 215.0 $2.18 $4.11 $7.80 0.0 1.0 2.0

Total (Walleye/Pike) 215.0 $2.18 $4.11 $7.80 0.0 1.0 2.0

Total (Unidentified) 76,860.0 $3.33 $6.22 $11.71 256.0 478.0 900.0

Total (Undiscounted) 174,601.0 . . . 679.0 1,152.0 1,984.0

Total (3% discount rate) . . . . 556.0 943.0 1,624.0

Total (7% discount rate) . . . . 507.0 860.0 1,482.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-28

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

I.6 Inland

Table I-31: Recreational Fishing Benefits from Eliminating Baseline I&E Mortality Losses at Inscope Facilities in the Inland Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Smallmouth bass 190,994.0 $4.28 $9.01 $19.08 818.3 1,721.3 3,643.5

White bass 1,656,537.0 $4.28 $9.01 $19.08 7,097.7 14,929.7 31,600.6

Total (Bass) 1,847,530.0 $4.28 $9.01 $19.08 7,916.0 16,651.0 35,244.0

Whitefish 2,061.0 $1.52 $2.83 $5.29 3.0 6.0 11.0

Total (Other Trout) 2,061.0 $1.52 $2.83 $5.29 3.0 6.0 11.0

Black bullhead 31,025.0 $0.53 $1.06 $2.10 16.4 32.8 65.3

Black crappie 145,478.0 $0.53 $1.06 $2.10 76.9 153.7 306.0

Bluegill 433,471.0 $0.53 $1.06 $2.10 229.0 458.0 911.7

Brown bullhead 14,807.0 $0.53 $1.06 $2.10 7.8 15.6 31.1

Bullhead 5,390.0 $0.53 $1.06 $2.10 2.8 5.7 11.3

Channel catfish 441,689.0 $0.53 $1.06 $2.10 233.4 466.7 929.0

Crappie 386,810.0 $0.53 $1.06 $2.10 204.4 408.7 813.6

Menhaden 308.0 $0.53 $1.06 $2.10 0.2 0.3 0.6

Rainbow smelt 9,240.0 $0.53 $1.06 $2.10 4.9 9.8 19.4

Smelts 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Sunfish 1,511,686.0 $0.53 $1.06 $2.10 798.7 1,597.3 3,179.6

White Perch 5,479.0 $0.53 $1.06 $2.10 2.9 5.8 11.5

Yellow perch 625,983.0 $0.53 $1.06 $2.10 330.7 661.5 1,316.7

Total (Panfish) 3,611,368.0 $0.53 $1.06 $2.10 1,908.0 3,816.0 7,596.0

Salmon 5.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

Total (Salmon) 5.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

American shad 3,070.0 $1.61 $5.36 $18.07 5.0 16.5 55.4

Striped bass 19,797.0 $1.61 $5.36 $18.07 32.2 106.2 357.3

Sturgeon 1,735.0 $1.61 $5.36 $18.07 2.8 9.3 31.3

Total (Small Game) 24,603.0 $1.61 $5.36 $18.07 40.0 132.0 444.0

Northern pike 36.0 $1.98 $4.10 $8.53 0.1 0.1 0.3

Sauger 180,270.0 $1.98 $4.10 $8.53 357.2 739.7 1,537.2

Walleye 209,854.0 $1.98 $4.10 $8.53 415.8 861.1 1,789.5

Total (Walleye/Pike) 390,160.0 $1.98 $4.10 $8.53 773.0 1,601.0 3,327.0

Total (Unidentified) 6,716,737.0 $1.08 $2.23 $4.60 7,283.0 14,985.0 30,898.0

Total (Undiscounted) 12,592,464.0 . . . 17,923.0 37,191.0 77,520.0

Total (3% discount rate) . . . . 16,566.0 34,376.0 71,653.0

Total (7% discount rate) . . . . 16,504.0 34,247.0 71,384.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-29

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-32: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 1 (I Everywhere) in the Inland Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Smallmouth bass 9,573.0 $4.28 $9.01 $19.08 41.0 86.3 182.6

White bass 649,610.0 $4.28 $9.01 $19.08 2,783.0 5,854.7 12,392.4

Total (Bass) 659,182.0 $4.28 $9.01 $19.08 2,824.0 5,941.0 12,575.0

Whitefish 1,642.0 $1.52 $2.83 $5.29 2.0 5.0 9.0

Total (Other Trout) 1,642.0 $1.52 $2.83 $5.29 2.0 5.0 9.0

Black bullhead 25,176.0 $0.53 $1.06 $2.10 13.3 26.6 53.0

Black crappie 14,071.0 $0.53 $1.06 $2.10 7.4 14.9 29.6

Bluegill 334,160.0 $0.53 $1.06 $2.10 176.6 353.1 703.0

Brown bullhead 4,771.0 $0.53 $1.06 $2.10 2.5 5.0 10.0

Bullhead 3,245.0 $0.53 $1.06 $2.10 1.7 3.4 6.8

Channel catfish 228,275.0 $0.53 $1.06 $2.10 120.6 241.2 480.2

Crappie 24,144.0 $0.53 $1.06 $2.10 12.8 25.5 50.8

Menhaden 258.0 $0.53 $1.06 $2.10 0.1 0.3 0.5

Rainbow smelt 3,097.0 $0.53 $1.06 $2.10 1.6 3.3 6.5

Smelts 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Sunfish 193,777.0 $0.53 $1.06 $2.10 102.4 204.8 407.6

White Perch 4,067.0 $0.53 $1.06 $2.10 2.1 4.3 8.6

Yellow perch 298,679.0 $0.53 $1.06 $2.10 157.8 315.6 628.3

Total (Panfish) 1,133,719.0 $0.53 $1.06 $2.10 599.0 1,198.0 2,385.0

Salmon 4.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

Total (Salmon) 4.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

American shad 2,569.0 $1.61 $5.36 $18.07 4.1 13.7 46.4

Striped bass 16,562.0 $1.61 $5.36 $18.07 26.6 88.3 299.3

Sturgeon 184.0 $1.61 $5.36 $18.07 0.3 1.0 3.3

Total (Small Game) 19,315.0 $1.61 $5.36 $18.07 31.0 103.0 349.0

Northern pike 30.0 $1.98 $4.10 $8.53 0.1 0.1 0.3

Sauger 7,809.0 $1.98 $4.10 $8.53 15.6 32.0 66.6

Walleye 13,152.0 $1.98 $4.10 $8.53 26.3 53.9 112.2

Total (Walleye/Pike) 20,991.0 $1.98 $4.10 $8.53 42.0 86.0 179.0

Total (Unidentified) 2,486,184.0 $1.08 $2.23 $4.60 2,696.0 5,547.0 11,437.0

Total (Undiscounted) 4,321,037.0 . . . 6,194.0 12,880.0 26,933.0

Total (3% discount rate) . . . . 5,071.0 10,545.0 22,049.0

Total (7% discount rate) . . . . 4,626.0 9,619.0 20,115.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-30

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-33: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 2 (I Everywhere and E for Facilities > 125 MGD) in the Inland Region, by

Species (2009$)

5

th Mean 95th 5th Mean 95th

Smallmouth bass 157,772.0 $4.28 $9.01 $19.08 676.0 1,421.9 3,009.7

White bass 1,469,625.0 $4.28 $9.01 $19.08 6,297.0 13,245.1 28,035.3

Total (Bass) 1,627,397.0 $4.28 $9.01 $19.08 6,973.0 14,667.0 31,045.0

Whitefish 1,977.0 $1.52 $2.83 $5.29 3.0 6.0 10.0

Total (Other Trout) 1,977.0 $1.52 $2.83 $5.29 3.0 6.0 10.0

Black bullhead 29,849.0 $0.53 $1.06 $2.10 15.8 31.5 62.8

Black crappie 121,385.0 $0.53 $1.06 $2.10 64.1 128.3 255.3

Bluegill 413,894.0 $0.53 $1.06 $2.10 218.7 437.3 870.6

Brown bullhead 12,951.0 $0.53 $1.06 $2.10 6.8 13.7 27.2

Bullhead 4,984.0 $0.53 $1.06 $2.10 2.6 5.3 10.5

Channel catfish 401,691.0 $0.53 $1.06 $2.10 212.2 424.4 844.9

Crappie 320,377.0 $0.53 $1.06 $2.10 169.3 338.5 673.9

Menhaden 298.0 $0.53 $1.06 $2.10 0.2 0.3 0.6

Rainbow smelt 8,104.0 $0.53 $1.06 $2.10 4.3 8.6 17.0

Smelts 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Sunfish 1,269,826.0 $0.53 $1.06 $2.10 670.9 1,341.7 2,671.0

White Perch 5,204.0 $0.53 $1.06 $2.10 2.7 5.5 10.9

Yellow perch 564,857.0 $0.53 $1.06 $2.10 298.4 596.8 1,188.1

Total (Panfish) 3,153,418.0 $0.53 $1.06 $2.10 1,666.0 3,332.0 6,633.0

Salmon 5.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

Total (Salmon) 5.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

American shad 2,968.0 $1.61 $5.36 $18.07 4.8 15.9 53.7

Striped bass 19,136.0 $1.61 $5.36 $18.07 30.9 102.4 346.1

Sturgeon 1,450.0 $1.61 $5.36 $18.07 2.3 7.8 26.2

Total (Small Game) 23,554.0 $1.61 $5.36 $18.07 38.0 126.0 426.0

Northern pike 35.0 $1.98 $4.10 $8.53 0.1 0.1 0.3

Sauger 148,695.0 $1.98 $4.10 $8.53 294.6 609.9 1,267.7

Walleye 173,822.0 $1.98 $4.10 $8.53 344.4 713.0 1,482.0

Total (Walleye/Pike) 322,552.0 $1.98 $4.10 $8.53 639.0 1,323.0 2,750.0

Total (Unidentified) 5,932,467.0 $1.08 $2.23 $4.60 6,433.0 13,236.0 27,290.0

Total (Undiscounted) 11,061,370.0 . . . 15,751.0 32,690.0 68,154.0

Total (3% discount rate) . . . . 9,578.0 19,879.0 41,449.0

Total (7% discount rate) . . . . 7,361.0 15,277.0 31,856.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-31

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-34: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 3 (I&E Mortality Everywhere) in the Inland Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Smallmouth bass 164,627.0 $4.28 $9.01 $19.08 705.4 1,483.6 3,140.5

White bass 1,509,996.0 $4.28 $9.01 $19.08 6,469.6 13,609.0 28,805.5

Total (Bass) 1,674,624.0 $4.28 $9.01 $19.08 7,175.0 15,092.0 31,946.0

Whitefish 1,999.0 $1.52 $2.83 $5.29 3.0 6.0 11.0

Total (Other Trout) 1,999.0 $1.52 $2.83 $5.29 3.0 6.0 11.0

Black bullhead 30,167.0 $0.53 $1.06 $2.10 15.9 31.9 63.5

Black crappie 126,378.0 $0.53 $1.06 $2.10 66.8 133.6 265.8

Bluegill 418,926.0 $0.53 $1.06 $2.10 221.4 442.8 881.2

Brown bullhead 13,347.0 $0.53 $1.06 $2.10 7.1 14.1 28.1

Bullhead 5,077.0 $0.53 $1.06 $2.10 2.7 5.4 10.7

Channel catfish 410,600.0 $0.53 $1.06 $2.10 217.0 434.0 863.7

Crappie 334,101.0 $0.53 $1.06 $2.10 176.6 353.1 702.7

Menhaden 300.0 $0.53 $1.06 $2.10 0.2 0.3 0.6

Rainbow smelt 8,347.0 $0.53 $1.06 $2.10 4.4 8.8 17.6

Smelts 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Sunfish 1,320,111.0 $0.53 $1.06 $2.10 697.6 1,395.3 2,776.7

White Perch 5,273.0 $0.53 $1.06 $2.10 2.8 5.6 11.1

Yellow perch 578,320.0 $0.53 $1.06 $2.10 305.6 611.2 1,216.4

Total (Panfish) 3,250,948.0 $0.53 $1.06 $2.10 1,718.0 3,436.0 6,838.0

Salmon 5.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

Total (Salmon) 5.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

American shad 2,997.0 $1.61 $5.36 $18.07 4.8 16.1 54.1

Striped bass 19,322.0 $1.61 $5.36 $18.07 30.8 103.8 348.7

Sturgeon 1,509.0 $1.61 $5.36 $18.07 2.4 8.1 27.2

Total (Small Game) 23,828.0 $1.61 $5.36 $18.07 38.0 128.0 430.0

Northern pike 35.0 $1.98 $4.10 $8.53 0.1 0.1 0.3

Sauger 155,207.0 $1.98 $4.10 $8.53 307.2 637.0 1,323.3

Walleye 181,266.0 $1.98 $4.10 $8.53 358.8 743.9 1,545.4

Total (Walleye/Pike) 336,508.0 $1.98 $4.10 $8.53 666.0 1,381.0 2,869.0

Total (Unidentified) 6,101,138.0 $1.08 $2.23 $4.60 6,616.0 13,612.0 28,066.0

Total (Undiscounted) 11,389,049.0 . . . 16,216.0 33,654.0 70,160.0

Total (3% discount rate) . . . . 9,966.0 20,684.0 43,122.0

Total (7% discount rate) . . . . 7,592.0 15,755.0 32,847.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-32

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table I-35: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope

Facilities Under Option 4 (I for Facilities > 50 MGD) in the Inland Region, by Species (2009$)

5

th Mean 95th 5th Mean 95th

Smallmouth bass 9,339.0 $4.28 $9.01 $19.08 40.0 84.2 178.2

White bass 633,751.0 $4.28 $9.01 $19.08 2,715.0 5,711.7 12,089.8

Total (Bass) 643,090.0 $4.28 $9.01 $19.08 2,755.0 5,796.0 12,268.0

Whitefish 1,602.0 $1.52 $2.83 $5.29 2.0 5.0 8.0

Total (Other Trout) 1,602.0 $1.52 $2.83 $5.29 2.0 5.0 8.0

Black bullhead 24,562.0 $0.53 $1.06 $2.10 13.0 26.0 51.7

Black crappie 13,727.0 $0.53 $1.06 $2.10 7.2 14.5 28.9

Bluegill 326,002.0 $0.53 $1.06 $2.10 172.1 344.6 685.6

Brown bullhead 4,655.0 $0.53 $1.06 $2.10 2.5 4.9 9.8

Bullhead 3,165.0 $0.53 $1.06 $2.10 1.7 3.3 6.7

Channel catfish 222,702.0 $0.53 $1.06 $2.10 117.6 235.4 468.3

Crappie 23,555.0 $0.53 $1.06 $2.10 12.4 24.9 49.5

Menhaden 251.0 $0.53 $1.06 $2.10 0.1 0.3 0.5

Rainbow smelt 3,021.0 $0.53 $1.06 $2.10 1.6 3.2 6.4

Smelts 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Sunfish 189,046.0 $0.53 $1.06 $2.10 99.8 199.8 397.6

White Perch 3,967.0 $0.53 $1.06 $2.10 2.1 4.2 8.3

Yellow perch 291,387.0 $0.53 $1.06 $2.10 153.9 308.0 612.8

Total (Panfish) 1,106,041.0 $0.53 $1.06 $2.10 584.0 1,169.0 2,326.0

Salmon 4.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

Total (Salmon) 4.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

American shad 2,506.0 $1.61 $5.36 $18.07 4.0 13.4 45.2

Striped bass 16,158.0 $1.61 $5.36 $18.07 25.7 86.6 291.6

Sturgeon 179.0 $1.61 $5.36 $18.07 0.3 1.0 3.2

Total (Small Game) 18,843.0 $1.61 $5.36 $18.07 30.0 101.0 340.0

Northern pike 29.0 $1.98 $4.10 $8.53 0.1 0.1 0.2

Sauger 7,619.0 $1.98 $4.10 $8.53 15.3 31.3 65.1

Walleye 12,831.0 $1.98 $4.10 $8.53 25.7 52.6 109.6

Total (Walleye/Pike) 20,479.0 $1.98 $4.10 $8.53 41.0 84.0 175.0

Total (Unidentified) 2,425,487.0 $1.08 $2.23 $4.60 2,630.0 5,411.0 11,157.0

Total (Undiscounted) 4,215,546.0 . . . 6,043.0 12,566.0 26,275.0

Total (3% discount rate) . . . . 4,947.0 10,287.0 21,511.0

Total (7% discount rate) . . . . 4,513.0 9,384.0 19,623.0

Species

Annual Increase in

Recreational

Harvest

(harvestable adult

fish)

Value per Fish

Annual Benefits from Increase in

Recreational Harvest

(2009$, thousands)
March 28, 2011 J-1

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

J

Appendix J: Methods Used in the Habitat Based Methodology for

Estimating Nonuse Values

J.1 Equations for estimating nonuse values using a habitat based

methodology

Equation J-1: estimating lost production from I&E mortality on an annual basis.

Productivity loss due to I&E mortality is calculated as:

i

n

i

k

j

    ijixjitotx  DMMCLSP

1 1

,,,, Equation J-1

where:

 SPx,tot is the estimated loss in regional production for all I&E mortality species under regulatory

option x, measured in kg dry mass per year.

 Li,x is the number of individuals of species i (with n species in the region) at life history stage j

(with k life history stages) lost to I&E mortality under regulatory option x. Measured in organisms

per year.

 Ci,j is the ratio used to convert losses of species i and life history stage j into age-1 equivalents.

 Miis the mass of an individual of species i at age 1. Measured in kg.

 DMiis the ratio of dry mass to wet mass for species i.

Equation J-2: Estimating habitat-based fish production

The calculation of secondary productivity per acre (SPrest) is as follows:

321 rest    )1(   TCTCTCEPPSP Equation J-2

where:

 PP is primary productivity per acre of restoration

 E is the rate of productivity export, the portion of primary productivity excluded from transfer to

higher trophic levels

 TC1 the trophic conversion efficiency from primary productivity to detritus

 TC2 the trophic conversion efficiency from detritus to first level consumers

 TC3 the trophic conversion efficiency from first level consumers to second level consumers

B1
March 28, 2011 J-2

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Equation J-3: Estimating habitat-based fish production

The number of habitat acres (A) estimated to generate annual productivity equivalent to reduction in I&E

mortality achieved by regulatory option x is calculated for each region as:

rest

n

i

xix

 SPSPA











 1

, Equation J-3

where:

 Axis the number needed to achieve ecological equivalence with option x

 SPi,x is the total increase in secondary productivity per year for species i under option x

 SPrest is the total secondary productivity gained per year per acre or restoration
March 28, 2011 J-3

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

J.2 Estimated Primary Productivity and Carbon Export in Marine and Aquatic Habitats

Table J-1: Summary of Aboveground Primary Productivity (measured in kg dry mass acre-1 yr-1)

Species Study Region(s)

Sample

Size Min Max Mean Sources

Eelgrass

Zostera marina

North Atlantic, MidAtlantic, and South

Atlantic

6 934 7,561 3,745 Beal et al. (2004), Nixon and Oviatt (1972), Murray and Wetzel (1987),

Rizzo and Wetzel (1985), Bach et al. (1986)

Smooth cordgrass

Spartina alterniflora

North Atlantic and MidAtlantic10 1,416 6,520 3,332 Reimold and Linthurst (1977)*, Valiela, Teal, and Sass (1975)*, Steever

(1972)*, Walton (1972)*, Cahoon (1975)*, Mendelssohn and Marcellus

(1976)*

Smooth cordgrass

Spartina alterniflora

South Atlantic and Gulf

of Mexico

13 1,331 16,148 6,372 Stroud and Cooper (1968)*, Marshall (1970)*, Odum and Fanning

(1972)*, de la Cruz (1974)*, Kirby (1972)*, Kirby and Gooselink (1976)*

Turtle grass

Thalassia testudinum

Gulf of Mexico 5 1,329 3,570 2,417 Tomasko et al. (1996), Kaldy and Dunton (2000)

Giant Kelp

Macrocystis pyrifera

California 4 1,472 11,344 7,312 Dayton (1985), Rassweiler (2008)

Broadleaf cattail

Typha latifolia

Great Lakes and Inland 14 2,024 12,971 6,199 Gustafson (1976)*, Penko and Pratt (1986), Grace and Wetzel (1982),

Mitsch et al (2002), Smith and Kadlec (1985), Rocha and Goulden (2009),

van der Valk and Davis (1978)*, Keefe (1972)*, Whigham and Simpson

(1975)*, Johnson (1970)*

Sample size is the number of estimates included in calculation of the mean value. The sample size differs from the number of sources because several studies provide multiple productivity values from

different sites.

Values reported in units of g C m-2 day-1 were converted using specifes-specific factors.

 Eelgrass – carbon accounts for 38% of dry weight biomass (Thom 1988).

 Smooth cordgrass - carbon accounts for 45% of dry weight biomass (French McCay and Rowe 2003; Gallagher 1975).

 Turtle grass - carbon accounts for 36.4% of dry weight biomass (Fourqurean and Zieman 2002).

 Kelp – carbon accounts for 33% of dry weight biomass (Dayton 1985).

 Broadleaf cattail - carbon accounts for 40.2% of dry weight biomass (Esteves et al. 2008).

* Indicates values were taken from USEPA (1980).
March 28, 2011 J-4

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table J-2: Estimates of Carbon Export from Salt Marshes

Location

C Export

(g C m-2 yr-1)

ANPP

(g C m-2 yr-1)

Export as

% of NPP Dominant Species Source

Cape Cod, MA 3 67.5 4.4% Spartina alternaflora Howes et al (1985)1

Flax Pond, NY -53 372 -14.2% Spartina alterniflora Woodwell et al (1977)

Canary Creek, DE 159 252 63.1% Spartina alterniflora Roman & Daiber (1989)

Ware Creek, VA 115 599 19.2% Spartina alterniflora Axelrad et al. (1976)

Carter Creek, VA 142 599 23.7% Spartina alterniflora Axelrad et al. (1976)

Beaufort, NC 40 548 7.3% Spartina alterniflora Bach et al. (1986)*

Beaufort, NC 124 568 21.9% Spartina alterniflora Bach et al. (1986)*

Beaufort, NC 32 837 3.9% Spartina alterniflora Bach et al. (1986)*

Bly Creek, SC 252 1080 23.3% Spartina alterniflora Williams et al. (1992)*

Bly Creek, SC 493 1080 45.6% Spartina alterniflora Williams et al. (1992)*

North Inlet, SC 456 1059 43.1% Spartina alterniflora Dame et al (1986)

Bly Creek, SC 242 1028 23.5% Spartina alterniflora Dame et al. (1991)

Duplin River, GA 1090 2025 12.8-53.8% Spartina alterniflora Wang and Cai (2004)

Sapelo Island, GA 393 878 44.8% Spartina alterniflora Teal (1962)

Sapelo Island, GA 365 992 36.8% Spartina alterniflora Teal (1962)* 2

Barataria Basin, LA 224 600 37.3%

Panicum hemitomo

Eleocharis sp Feijtel et al (1985)

Barataria Basin, LA 296 550 53.8%

Spartina patens

Distichlis spicata Feijtel et al (1985)

Barataria Basin, LA 183 860 21.3% Spartina alterniflora Feijtel et al (1985)

LA 226 1147 19.7% Day et al. (1973)*

LA 47 926 5.1% Hopkinson et al. (1978)*

LA 55 1267 4.3% Hopkinson et al. (1978)*

LA 161 599 26.8% Hopkinson et al. (1978)*

LA 821 2416 34.0% Hopkinson et al. (1978)*

LA 80 540 14.9% Hopkinson et al. (1978)*

LA 26 518 5.0% White et al. (1978)*

Coon Creek, TX 25 559-900 2.7-4.5%

Spartina patens

Distichlis spicata Borey et al. (1983)

EMS-Dollard Marsh

Netherlands -125 500 -25.00%

Puccinellietum maritime

Spartina anglica Dankers et al (1984)

Kariega Marsh,

South Africa 16 200-300 5.0-8.0%

Spartina perennis,

Chenolea diffusa Taylor & Allanson (1995)

Hong Kong 0 880 0.0% Phragmites communis Lee (1990)*

Unknown 58 105 55.8% McLusky (1981)*

Unknown 51 181 28.2% McLusky (1981)*

Unknown 142 1080 13.2% Schlesinger (1997)*

Unknown 431 1080 39.9% Schlesinger (1997)*

Unknown 117 1080 10.8% Schlesinger (1997)*

Unknown 99 1080 9.1% Schlesinger (1997)*

Unknown 164 1080 15.2% Schlesinger (1997)*

* Indicates values taken from Cebrian (2002).

1 Carbon export for Howes et al. (1985) was calculated based on annual sediment budget in mol m-2 yr-1

.

2 These values were calculated directly based on Teal (1962) and differ from values included in the meta-data of Cebrian (2002).

J.3 Regional Determination of Preferred Habitat

In the North Atlantic region, species accounting for the greatest proportion of I&E mortality [rock gunnel

(42% of regional I&E mortality), winter founder (11%), radiated shanny (7%), cunner (7%), American

sand lance (7%) and seaboard goby (7%)] are generally found in estuarine, sandy or nearshore rocky reef

areas, and are not strongly associated with coastal wetlands (Fishbase 2009). Therefore, eelgrass was

selected for scaling I&E mortality losses in the North Atlantic.
March 28, 2011 J-5

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

In the Mid-Atlantic region, species with the greatest I&E mortality by mass [bay anchovy (65% of the

regional I&E mortality losses), blue crab (10%), Atlantic menhaden (5%) and spot (4%)] are commonly

found in tidal salt marshes (Fishbase 2009). Consequently, the preferred habitat for restoration projects is

smooth cordgrass, the dominant foundation species in Atlantic salt marshes.

Similarly, in the South Atlantic, important I&E mortality species [bay anchovy (71%), forage shrimp

(13%), gobies (4%) and other forage fish (4%)] are associated with salt marshes dominated by cordgrass.

Thus, saltmarsh is the preferred habitat choice for this region.

In the Gulf Coast region, there is less dominance by a single species in I&E mortality results [pink shrimp

(30%) blue crab (15%) bay anchovy (14%) and other forage fish (11%)], and there is no strong ecological

argument for preferring turtle grass or saltmarsh. Consequently, due to its higher productivity, smooth

cordgrass was chosen as the preferred habitat type for regional restoration calculations.

In California, the preferred habitat choice is the highly productive giant kelp (M. pyrifera), known to be a

nursery habitat for many fish species.

In the Great Lakes and Inland regions, the freshwater macrophyte broadleaf cattail (T. latifolia) was

selected for restoration calculations.
March 28, 2011 J-6

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

J.4 Willingness to Pay for Fish Production and Other Aquatic Habitat Goods and Services

Table J-3: Studies Used to Estimate WTP Values for Fish Production Services and Habitat

Study

Survey

Year

Location

(State) Habitat

WTP acre-1 yr-1

(2009$)1

Population

(Sample Size) Change Valued Survey Methods

Peconic Estuary Study

(Johnston et al. 2002a;

Johnston et al. 2001;

Mazzotta 1996; Opaluch

et al. 1995; Opaluch et al.

1998)

1995 New York Eelgrass and

Salt marsh

Eelgrass -

$0.07608

Saltmarsh-

$0.0672

East End Long

Island Households

(968 completed

surveys)

Eelgrass presented at current

level of 9,000 acres, “no action”

level of 8,000 acres, and with

restoration level of 11,000 acres.

Wetlands presented at their

current level of 16,000 acres,

“no action” level of 12,000

acres, and with restoration level

of 17,500 acres.

Used an original contingent

choice study to estimate

relative preferences of

residents for preserving key

natural and environmental

resources.

Bauer, Cyr, and Swallow

(2004)

2004 Rhode Island Salt marsh $0.0190 Rhode Island

Households (320 inperson surveys

administered)

Survey level included four levels

of wetland preservation or

restoration; 33, 64, 101, or 135

acres. One-time payment

converted to annual value

assuming 3% discount rate.

Stated-preference survey

designed to elicit public

preferences for salt marsh

mitigation projects and to

determine public willingness

to trade off mitigation-site

attributes such as cost, size,

public access, and presence of

endangered species.

De Zoysa (1995) 1994 Ohio Freshwater

wetlands

$0.0299 Residents of

Maumee, Ohio (476

responses)

Wetlands program description

indicated that the proposed

program would restore and

protect 3,000 acres of wetlands

from a baseline of 10,000

existing acres that were

declining.

The study used the contingent

valuation method with seven

versions of the survey, each

of which described a different

resource conservation

program involving

groundwater, surface water,

wetlands, or some

combination thereof.

Bishop et al. (2000) 1999 Wisconsin Freshwater

wetlands

$0.00125 Households within a

ten county area

around Green Bay

(470 responses)

Restoration level ranging up to a

11,600 acre increase in wetlands

within five miles of Green Bay,

WI to support birds, fish, and

other wildlife equivalent to a

20% increase from the 58,000

baseline acres. WTP reported

here is the mid-point of marginal

values for 5% and 20% changes.

Total Value Equivalency

(TVE) study conducted to

support restoration planning

conducted as part of the

Lower Fox River/Green Bay

NRDA.
March 28, 2011 J-7

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table J-3: Studies Used to Estimate WTP Values for Fish Production Services and Habitat

Study

Survey

Year

Location

(State) Habitat

WTP acre-1 yr-1

(2009$)1

Population

(Sample Size) Change Valued Survey Methods

Mullarky (1997; 1999) 1994 Wisconsin Freshwater

wetlands

$0.00822 Wisconsin residents

(239 complete

surveys)

Case study of a highway

expansion project in Northwest

Wisconsin which would require

filling of 110 acres of wetlands.

One-time payment converted to

annual value assuming 3%

discount rate.

Contingent valuation study of

Wisconsin wetlands. Losses

would be mitigated by the

creation of 220 acres of

isolated basin along the

highway; WTP reported here

is based on a mean from the

“scope group” which was not

informed that mitigation was

being conducted.

Blomquist and Whitehead

(1998)

1990 Kentucky Freshwater

wetlands

$0.0056 Kentucky residents

(379 responses)

WTP to purchase and manage

500 acres which if not purchased

would be mined and reclaimed

after ten years.

Contingent valuation study

resulting in WTP values for

four separate wetland types.

WTP reported here is for the

Flat creek persistent emergent

wetland, which is most

consistent with scaled habitat.

Whitehead and Blomquist

(1991)

1989 Kentucky Freshwater

wetlands

$0.0037 Kentucky residents

(215 responses)

WTP for purchase and

management of the

approximately 5,000 acres Clear

Creek wetland which would be

mined if not purchased.

Contingent valuation study

with three groups with each

presented different

information about related

environmental resources.

Smaller sample than

Blomquist and Whitehead

(1998)

1 WTP values were converted to 2009$ based on the Consumer Price Index (CPI).

2 Mullarky (1997; 1999) present multiple WTP estimates based on the survey group used for the estimate (“base group” or “scope group”) and certainty level treatment of

the polychotomous choice format. The reported value is based for the “scope group”, which was not informed regarding mitigation, and the highest certainty level for

responses.
March 28, 2011 J-8

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

J.5 Narragansett Bay Wetland Restoration Study

J.5.1 Survey Development and Data Collection

EPA designed a survey instrument, entitled Rhode Island Salt Marsh Restoration: 2001 Survey of Rhode

Island Residents to assess tradeoffs among attributes of salt marsh restoration plans. Development of this

survey required more than 16 months and involved extensive background research, interviews with

experts in salt marsh ecology and restoration, and 16 focus groups with more than 100 Rhode Island

residents. Numerous pretests, including verbal protocol analysis (Schkade and Payne 1994) ensured that

the survey language and format would be easily understood by respondents, and that respondents would

have a common understanding of survey scenarios (cf. Johnston et al. 1995).

Johnston et al. (2002b) chose attributes distinguishing restoration plans based on background research,

expert interviews, and focus groups. The authors tailored these attributes to reflect primary salt marsh

services in the northeast United States that would be influenced by restoration activities, and

characterized each wetland by the size of the marsh, together with effects of restoration, on (1) habitat for

birds, (2) habitat for fish, (3) habitat for shellfish, (4) potential to control mosquito nuisance, (5)

recreational access, and (6) household cost.64 Based on the results of focus groups and expert interviews,

habitat and mosquito control services were presented from a standardized, statewide perspective. For

example, improvements to fish habitat were characterized as “ecological improvements to RI fish

populations...[resulting from a particular restoration project]...as judged by wetlands experts, compared

to all other potential salt marsh restoration projects in Rhode Island.”

Following the general approach of Johnston et al. (1999), the conjoint (or multi-attribute choice) survey

presented respondents with four sets of discrete choices, each involving two alternative, multi-attribute

restoration plans. The authors used fractional factorial design to construct a range of survey questions

with an orthogonal array of attribute levels, resulting in 80 contingent choice questions divided among 20

unique booklets. Attributes distinguishing plans were selected based on background research, expert

interviews, and focus groups. All attributes were free to vary over their full range for both restoration

plans presented in each question, with no imposed ordering of attribute levels between the two plans.

Based on these attributes, respondents chose one of the two plans, or chose “Neither Plan.”

The survey was conducted from September through December, 2001. Respondents were intercepted in

person at Rhode Island Department of Motor Vehicle offices, public libraries, and other survey sites.

Interviewers did not tell respondents that the survey concerned salt marsh restoration. Rather,

interviewers asked respondents to participate in an important survey regarding “environmental issues in

Rhode Island,” to reduce the potential for topic-related nonresponse. Following the general approach of

Johnston et al. (1999), the survey presented respondents with four sets of discrete choices, each involving

two alternative, multi-attribute restoration plans. Attributes included in the survey included the size of salt

marsh restoration, and the importance of (1) habitat for birds, (2) habitat for fish, (3) habitat for shellfish,

64Additional, non-habitat services that may be provided by salt water wetlands include, among others, nutrient transformation,

storm buffering, and coastal erosion control. Interviews with experts on salt water wetland functions in New England (and

Rhode Island in particular) indicated, however, that wetland restoration would provide negligible impacts on these nonhabitat functions in the majority of cases. They based this assessment on the small size of most New England coastal

wetlands, and on the fact that restoration may not always increase substantially the ability of a wetland to provide such

functions as storm buffering or erosion control. Based on this advice, the survey focused mainly on wetland habitat

functions.
March 28, 2011 J-9

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

(4) the potential for mosquito control, (5) recreational access, and (6) household cost. Based on variations

in the presented attributes of conservation plans, respondents either chose either one of two plans

presented, or chose “Neither Plan.” In total, interviewers collected 661 completed surveys, providing

complete and usable responses to 2,341 individual contingent choice questions (89% of a potential 2,644).

J.5.2 Results

Table J-4 presents variables incorporated in the analysis of salt marsh restoration choices. These variables

include: (1) a dummy variable identifying the “neither” option, (2) quadratic interactions between this

dummy and certain demographic characteristics, and (3) variables for the restored salt marsh attributes.

Mean values for salt marsh attributes (Table 9-5) indicate the mean values of these attributes over all

completed surveys included in the analysis. The final column of the table calculates these mean values

with "neither plan" data rows excluded. (As noted above, each wetland restoration choice included the

option of choosing neither plan. In the multinomial logit data, these options are presented as a "plan" with

zeros for all wetland attributes.)

Table J-5 presents results for a conditional logit model of survey data. The model is significant at p

<0.0001 (-2LnL P2=1157.56, df = 13); all individual parameter estimates are significant at p <0.05, with

most significant at p <0.01.

The signs of parameter estimates correspond with prior expectations derived from focus groups, where

prior expectations exist. Respondents favor plans that restore larger salt marshes; improve bird, fish, and

shellfish habitat; control mosquitoes; provide public access; and result in lower costs to the household.

Comparing preferences for habitat improvements and mosquito control (all measured on a ten-point

scale), respondents placed the greatest weight on mosquito control, followed by habitat improvements for

shellfish, fish, and birds, respectively. The likelihood of rejecting restoration outright (i.e., choosing

neither plan) was smaller for members of environmental organizations, and larger for members of

taxpayers organizations, lower income individuals, and more highly educated individuals (Johnston et al.

2002b). Changes in education and income do not influence the marginal utility of fish and shellfish

habitat, or that of other wetland attributes.

Results of the conjoint analysis (i.e., the public survey results) presented by Johnston et al. (2002b) allow

policy makers to rank restoration projects based on their estimated influence on residents’ welfare. These

results also allow assessment of residents’ willingness to trade off elements of wetland restoration plans,

or WTP for particular wetland attributes. Finally, for any specified restoration plan, provided that

incremental gains or losses in wetland services are known, it allows the calculation of the proportion of

the total gain in social value attributable to a particular service (e.g., fish habitat).

To estimate the proportion of value associated with fish habitat, in a representative, conservative scenario,

EPA began with the average wetland restoration scenario considered by the Rhode Island survey sample.

The mean values of wetland attributes presented to survey respondents provide the most representative set

of results from which value proportions may be estimated, and forecast the value proportions that would

result from an average survey respondent confronted with an average wetland restoration scenario, as

characterized by the Rhode Island Salt Marsh Restoration Survey data. Excluding all “Neither Plan”

scenarios, which offered zero restoration, Table J-4 summarizes the mean values for services considered

by the Rhode Island sample.
March 28, 2011 J-10

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table J-4: Definitions and Summary Statistics for Model Variables for Narragansett Bay Wetland

Restoration Study

Variable

Name Description

Whole Sample

Mean (Std. Dev.)

Mean, Excluding

“Neither Plan”

Scenariosa

Neither Neither=1 identifies “neither plan” options 0.333

(0.471)

0.000

Environ Dummy variable identifying respondents with membership in

environmental organizations

0.190

(0.392)

0.190

Taxgrp Dummy variable identifying respondents with membership in taxpayer

associations

0.023

(0.151)

0.023

Loincome Dummy variable identifying respondents with household income less than

$35,000/year

0.245)

(0.430)

0.245

Hiedu Dummy variable identifying respondents with greater than a four-year

college degree

0.182

(0.386)

0.182

Birds Ecological improvement to statewide bird populations resulting from

specified salt marsh restoration plan, compared to all other potential salt

marsh restoration plans in Rhode Island (0-10 scale)

2.761

(2.607)

4.141

Fish Ecological improvement to statewide fish populations resulting from

specified salt marsh restoration plan, compared to all other potential salt

marsh restoration plans in Rhode Island (0-10 scale)

2.908

(2.653)

4.361

Shellfish Ecological improvement to statewide shellfish populations resulting from

specified salt marsh restoration plan, compared to all other potential salt

marsh restoration plans in Rhode Island (0-10 scale)

2.907

(2.652)

4.362

Mosquito Increased ability to control statewide mosquito nuisance resulting from

specified salt marsh restoration plan, compared to all other potential salt

marsh restoration plans in Rhode Island (0-10 scale)

2.908

(2.651)

4.362

Size Size of restored salt marsh (minimum 3 acres; maximum 12 acres) 4.889

(4.397)

7.334

Pro-access Dummy variable indicating that respondent feels that access to salt

marshes should be “somewhat limited” or “unlimited”

0.837

(0.370)

0.837

Con-access Dummy variable indicating that respondent feels that access to salt

marshes should be “severely limited” or “prohibited”

0.227

(0.419)

0.163

Platform Dummy variable indicating that restoration provides “viewing platforms”

but no “trails”

0.222

(0.415)

0.340

Both Dummy variable indicating that restoration provides both “viewing

platforms” and “trails”

0.222

(0.415)

0.332

Cost Annual cost of restoration plan in increased taxes (minimum $0; maximum

$200)

63.169

(70.782)

94.754

a

Each wetland restoration choice included the option of choosing neither plan. In the multinomial logit data, this option is presented as a “plan” with

zeros for all wetland attributes. The final column of the table calculates means with the “neither plan” zeros excluded.

Although mean values are used for most attributes (i.e., wetland attributes or services considered by

survey respondents in choice scenarios), changes in certain attributes are set to zero to correspond more

closely with the policy scenario and with the Peconic study (because the purpose of this analysis is to

assess the proportion of the Peconic wetland values that may reasonably be attributed to fish habitat

services). For example, because the Peconic study survey did not specify or discuss the provision of

viewing platforms or trails at preserved wetlands, EPA assumed that survey respondents to the Peconic

study did not consider such provisions when making survey choices. Accordingly, in calculating value

proportions in this analysis using the Rhode Island data, EPA assumed that viewing platforms and trails

are not provided.

EPA also assumed that any wetland created or restored to provide fish habitat will likely not provide a

great degree of additional mosquito control, because a large proportion of existing salt marshes have
March 28, 2011 J-11

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

already been modified to minimize mosquito production.65 For this reason, modern marsh restoration

typically does not provide a significant increase in mosquito control. Rather, it often replaces older, more

detrimental (to marsh function and habitat) forms of mosquito control with Open Marsh Water

Management (OMWM), in which open water and natural fish predation is used to control mosquito

nuisance (Kennish 2001). OMWM has not been an “unqualified success” at eliminating the mosquito

nuisance (New York Conservationist 1997). Accordingly, for many salt marshes, the positive net effect of

restoration on mosquito nuisance, if any, is often minimal. To generate the most conservative estimates,

however, and in recognition of the fact that some salt marsh restoration projects may provide significant

mosquito control, EPA also estimated value proportions assuming that significant additional mosquito

control is provided. For all other wetland attributes included in the Rhode Island survey, EPA used the

mean values shown in the final column of Table J-4.

Estimation of value proportions is based on the estimated utility function v(.), which specifies the utility

provided by a wetland restoration plan as a function of the attributes or services provided by that plan

(Johnston et al. 2002b). That is, following the standard random utility model of Hanemann (1984), the

underlying model specifies respondents’ choices using the conditional logit specification, in which the

probability (Pi) of choosing any wetland restoration plan i (plan A, plan B, or neither plan) over the two

remaining options (j or k) is given by:

)](exp[)](exp[)](exp[

)](exp[

    





kji

i

i

vvv

v

P Equation J-4

where v(.) represents the relative benefits or utility resulting from each restoration option, including the

“neither plan” option. The function v(.) is typically estimated as a simple function of program attributes

(in this case wetland restoration); in practice linear, functional forms are often used (Johnston et al.

2002b).

From the assumptions and model noted above, the attribute definitions given in Table J-4, and the model

results of Table J-5, the estimated utility function used to calculate value proportions is specified as

)(0510.0)(1611.0

)(1587.0)(1465.0)(1191.0(.)

sizemosquito

shellfishfishbirdsv



   

Equation J-5

If mosquito control is not provided, then mosquito=0. Given this linear specification, the proportion of

wetland restoration value provided by the gain in fish habitat services is given by

)(

)()(

0



  



fish

fishfish

v

vv

Equation J-6

where v(.)fish represents the value of v(.) with the gain in fish habitat services set to its mean value (as

described above), and v(.)fish=0 represents the value of the function with the gain in fish habitat services

set to zero.

65The mosquito control variable was included in the survey in response to the strong concern of Rhode Island residents over the

impact of restoration on mosquitoes and related illnesses for which mosquitoes are the primary vector. Wetlands experts

indicated, however, that salt marsh restoration had limited impact on mosquito populations in most cases.
March 28, 2011 J-12

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table J-5: Conditional Logit Results for Narragansett Bay Wetland

restoration Study

Parameter Estimate Std. Error z P>|z|

Neither 1.157 0.193 5.98 0.0001

Neither x Environ -1.182 0.223 -5.30 0.0001

Neither x Tax 0.868 0.365 2.38 0.0170

Neither x Loincome 0.310 0.144 2.16 0.0310

Neither x Hiedu 0.415 0.169 2.46 0.0140

Birds 0.119 0.015 7.78 0.0001

Fish 0.147 0.016 9.36 0.0001

Shellfish 0.159 0.016 9.78 0.0001

Mosquito 0.161 0.016 9.95 0.0001

Size 0.051 0.010 5.22 0.0001

Pro-access x Platform 0.168 0.083 2.03 0.0420

Pro-access x Both 0.431 0.084 5.11 0.0001

Cost -0.007 0.001 -14.23 0.0001

-2LnL P

2

1157.56 Prob>P

2

0.0001

Table J-6 shows the resulting value proportions, in which EPA calculated the proportion of wetland

restoration value associated with different wetland services based on mean values of wetland attributes

presented to survey respondents, as discussed above. Analogous methods were used to assess value

proportions associated with shellfish and other habitat services; Table J-6 shows these results for

comparison. The table also illustrates the results of a sensitivity analysis in which EPA calculated

analogous value proportions for wetland habitat services, but allow wetland size to vary. Wetland size

was allowed to vary from its minimum value in the Rhode Island survey data (3 acres) to its maximum

value (12 acres), while holding habitat service changes constant. EPA chose these size values to be

representative of unrestored salt water wetlands currently existing in Narragansett Bay, which are

typically quite small (i.e., less than five acres). The three estimates of acreage are therefore likely closer

to the “average” Rhode Island wetland than estimates based on larger acreages. (In actual wetlands,

changes in restored acres are typically correlated with larger gains in habitat services (Johnston et al.

2002b). To illustrate even more conservative estimates, however, Table J-6 contains cases in which

restored wetland size increases from the mean, without any resultant increase in habitat services.)

Across scenarios the proportion of value associated with fish habitat ranges from 0.2035 to 0.3231, with a

mean value over all scenarios of 0.2564 (Table J-6). Scenario 1a is perhaps the most representative

scenario for estimating value proportions for two reasons: (1) restored wetlands are not expected to

provide additional mosquito control and (2) other wetland attributes are set to their mean values. Its

results are somewhat higher than those of scenario 3a, which represents the mean value over all scenarios

presented. To be conservative (i.e. low) in its estimates, EPA used the proportion calculated in scenario 3a

(0.2564) as an estimate of the proportion of total wetland restoration value attributable to gains in fish

habitat services, given representative, mean values for other wetland services.
March 28, 2011 J-13

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

Table J-6: Proportions of Restored Wetland Value Associate with Various Service

Categories

Percentage of Value Associated with Service:

Restoration Scenario Fish Habitat Bird Habitat Shellfish

Habitat

Mosquito

Control

Otherb

1a: No additional mosquito

control; mean values for all other

attributes

0.291 0.224 0.315 0.000 0.170

1b: No additional mosquito

control; mean values for habitat

gains; Size=3 acres

0.323 0.249 0.350 0.000 0.077

1c: No additional mosquito

control; mean values for habitat

gains; size=12 acres

0.262 0.202 0.284 0.000 0.251

2a: Mosquito control at mean

value; mean values for all other

attributes

0.220 0.170 0.239 0.242 0.129

2b: Mosquito control at mean

value; mean values for habitat

gains; size=3 acres

0.238 0.184 0.258 0.262 0.057

2c: Mosquito control at mean

value; mean values for habitat

gains; size=12 acres

0.204 0.157 0.220 0.224 0.195

3a: Mean over all scenarios 0.256 0.198 0.278 0.121 0.147

aResults assume that restoration does not provide viewing platforms or hiking trails.

b Other services may include, among others, nutrient transformations, storm buffering, and coastal erosion control.

Although these numbers are not directly comparable to other results found in the literature, they appear to

be reasonable and conservative compared to similar proportions generated for freshwater habitats. For

example, Schulze et al. (1995) estimate that between 32.98 percent and 33.44 percent of WTP for

resource cleanup in the Clark Fork River Basin was associated with “aquatic resources and riparian

habitat” (p. 5-13).

EPA also considered directly the parametric results of Table J-5 for further support of the soundness of

the proposed value proportions. Estimates presented in Table J-5 indicate that the parametric weights are

similar among the dominant wetland services in Narragansett Bay (i.e., bird habitat services, fish habitat

services, shellfish habitat services, and mosquito control). In other words, the parameter estimates are

very similar among these four variables. This correspondence suggests that restoration providing similar

scale improvements for each of these services should produce a roughly equivalent increment to utility.

Given the four habitat services considered in the survey (including mosquito control), each service

provides roughly 1/4 (or 25 percent) of the total marginal utility associated with the combination of

habitat improvements and mosquito control. For wetlands that do not provide substantial access

provisions (e.g., boardwalks) and that are of moderate or small size, it would be highly improbable for the

proportion of value associated with fish habitat to fall significantly below the 25.64 percent

approximation estimated here.
March 28, 2011 J-14

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation

J.6 Determining the Affected Population and Estimating Aggregate Values

Table J-7: Number of Households by State and Percentage of Regional Habitat Acres Assigned to

Each State.

State

No. of

Households California

North

Atlantic Mid-Atlantic

South

Atlantic

Gulf of

Mexico Great Lakes Inland

AL 1,836,096 - - - - - - 5.90%

AR 1,132,706 - - - - - - 1.53%

AZ 2,266,797 - - - - - - 0.21%

CA 12,371,970 100.00% - - - - - <0.01%

CO 1,891,368 - - - - - - 0.22%

CT 1,365,529 - 29.83% - - - - 0.14%

DC 268,559 - - - - - - <0.01%

DE 329,246 - - 5.08% - - - 0.02%

FL 7,252,011 - - - 70.27% 53.26% - 0.54%

GA 3,472,892 - - - 2.66% - - 2.36%

IA 1,248,977 - - - - - - 1.73%

IL 4,821,525 - - - - - 3.76% 7.30%

IN 2,501,050 - - - - - 11.63% 4.58%

KS 1,120,251 - - - - - - 1.56%

KY 1,695,340 - - - - - - 2.53%

LA 1,595,221 - - - - 7.44% - 5.02%

MA 2,533,224 - 49.80% - - - - 0.11%

MD 2,138,174 - - 24.02% - - - 0.34%

ME 561,927 - 3.54% - - - - 0.08%

MI 3,977,292 - - - - - 35.46% 1.62%

MN 2,095,360 - - - - - 1.27% 1.56%

MO 2,373,024 - - - - - - 4.51%

MS 1,106,531 - - - - 2.28% - 0.66%

MT 383,318 - - - - - - 0.13%

NC 3,562,025 - - - 19.12% - - 6.24%

ND 285,857 - - - - - - 0.65%

NE 719,904 - - - - - - 2.17%

NH 518,506 - 12.92% - - - - 0.17%

NJ 3,186,057 - - 22.20% - - - 0.08%

NM 735,720 - - - - - - 0.03%

NV 947,691 - - - - - - 0.05%

NY 7,303,783 - - 31.93% - - 19.52% 1.85%

OH 4,622,384 - - - - - 11.95% 4.92%

OK 1,431,014 - - - - - - 1.36%

OR 1,476,434 - - - - - - 0.04%

PA 5,021,383 - - 0.17% - - 0.20% 4.77%

RI 419,621 - 3.91% - - - - -

SC 1,718,297 - - - 7.94% - - 4.36%

SD 327,165 - - - - - - 0.01%

TN 2,449,562 - - - - - - 6.81%

TX 8,271,247 - - - - 37.02% - 17.89%

UT 837,511 - - - - - - 0.03%

VA 2,996,176 - - 16.60% - - - 1.32%

VT 260,831 - - - - - - 0.23%

WA 2,519,727 - - - - - - 0.18%

WI 2,302,752 - - - - - 16.21% 1.23%

WV 756,778 - - - - - - 2.80%

WY 211,883 - - - - - - 0.16%