Arnold Schwarzenegger
Governor 

## RESTORATION SCALING AND THE
HABITAT PRODUCTION FOREGONE
METHOD

Prepared For: 

### California Energy Commission Public Interest Energy Research Program

Prepared By: Stratus Consulting Inc.PIERDRAFTPROJECTREPORT

PUBLICATION #

## Restoration to Offset Environmental Impacts
of Coastal Power Plants

Principal Investigator:

Elizabeth Strange, Managing Scientist Stratus Consulting Inc. Washington, DC

Prepared for:

The California Energy Commission Public Interest Energy Research (PIER) Melinda Dorin, Energy Comm ission Project Manager

California Energy Commission Agreement #500-04-025 Amount of agreement: $235,675 San Jose State University Founda tion Account No. 22-1509-3550-Stratus
Publication Number:

Publication date: Draft: January 29, 2008i 

## Legal Notice

This report was prepared as a result of work sponsored by the California Energy Commission (Energy Commission). It does not necessarily represent the view s of the Energy Commission, its employees, or the State of California. The En ergy Commission, the State of California, its employees, contractors, and subcontractors make no warranty, expressed or implied, and assume no legal liability for the information in this repor t; nor does any party repr esent that the use of this information will not infringe upon privately owned rights. This report has not been approved or disapproved by the Energy Commission nor has the Energy Commission passed upon the accuracy or adequacy of the information in this report.



## Acknowledgements

This report was written by Dr. Elizabeth M. Strange , Principal Investigator (Managing Scientist, Stratus Consulting), Mr. David Allen (Vice Pres ident, Stratus Consulting), Mr. David Mills (Senior Analyst, Stratus Consulting), Mr. Dave Cacela (Senior Advisor), Ms. Colleen Donavan (Associate, Stratus Consulting), and Dr. Jos hua Lipton (Chief Executive Officer, Stratus Consulting).ii 

## Abstract

This report discusses ecol ogical issues in determining the type and amount of restoration needed
to offset losses of fishes from environmental impacts in California’s ne arshore waters, with a focus on fish entrainment at coastal power pl ants that use once-th rough cooling. The report provides an overview of restor ation scaling, evaluates the ha bitat production foregone (HPF)
method that has been used to scale restoration in some power plant cases, and describes the data and methods needed to ensure reliable scaling re sults. Restoration scaling in this context is a quantitative technique, typically based on ecological metrics, for estimating the extent of habitat replacement needed to offset a given environmen tal loss. The scaling e quation seeks to balance losses from an environmental inju ry with environmental gains from restoration. Analysis of the
HPF method indicates that it is not necessarily a valid measure of the increase in fish production (the gain) expected from restor ation, and therefore has important limitations as a scaling method. The report discusses conceptual a nd quantitative shortcomings of the HPF method that invalidate its use for many scaling purposes. The report conc ludes with a discussion of the elements required for a valid and reliable scaling approach, along with th e data and methods used to implement such techniques. An attachment provide s information on restoration actions to benefit particular species and the information needed for developing comprehensive restoration costs. Use of scientifically rigorous methods and target ed restoration monitoring to fill data gaps can greatly improve the ability of practitioners to reliably scale re storation, predict the ecological benefits of restoration, and monitor restoration success.

Keywords : restoration, coastal restora tion, fish restoration, restora tion scaling, impingement and entrainment, cooling water intake stru ctures, Clean Water Act section 316(b)iii 

## Preface

The Public Interest Energy Research (PIER) Pr ogram supports public inte rest energy research and development that will help improve the quality of life in California by bringing environmentally safe, affordable, and reliable en ergy services and products to the marketplace.

The PIER Program, managed by the Energy Comm ission, annually awards up to $62 million to conduct the most promising public interest ener gy research by partnering with Research, Development, and Demonstrati on (RD&D) organizations, incl uding individuals, businesses, utilities, and public or private research institutions.

PIER funding efforts are focused on th e following six RD&D program areas:

` Buildings Energy Efficiency End Use
` Industrial/Agricultural/Water End-Use Energy Efficiency
` Renewable Energy
` Environmentally-Preferre d Advanced Generation
` Energy-Related Environmental Research
` Energy Systems Integration.

What follows is one of two final reports fo r California Energy Commission Agreement #500-04- 025, San Jose State University Foundation Account No. 22-1509-3550-Stratus, conducted by Stratus Consulting Inc. The report is entitled “R estoration to Offset Environmental Impacts of Coastal Power Plants.” This pr oject contributes to the Water Intake Structure Environmental Research (WISER) program and the PIER Ener gy-Related Environmenta l Research program.

For more information on the PIER Program, pleas e visit the Energy Commission’s Web site at http://www.energy.ca.go v/research/index.html or contact the Energy Commission’s Publications
Unit at 916-654-5200.iv 

## Executive Summary

In some cases even the best technology availa ble (BTA) cannot elimin ate all environmental injuries that may result from power plant operation, and California permitting agencies may seek
habitat restoration to offset losses that conti nue to occur even after technology implementation. Because of the continued importance of restorati on in this and other contexts, California will need reliable methods to quantify the production of organisms in restored habitats, both to
estimate the amount of restoration needed to offset losses and to determine restoration success. In this context, restoration s caling is a quantitative technique , typically based on ecological methods, for estimating the restoration gain needed to offset a given magnitude of loss. This report discusses restoration scaling as it applies to entrainment losses at coastal power plants that use once-through cooling. An evaluation of the ha bitat production foregone (HPF) method that
has been used to scale restorati on in some power plant cases indicat es that it often is not a valid measure of the increase in fish production expect ed from restoration (t he restoration gain). Comparison of HPF results with restoration estimates using appropriate scaling techniques
indicate that the HPF method ma y significantly underestimate the amount of habitat restoration needed to offset a given magnitude of entrainmen t loss. This could be a serious problem whether
or not restoration is ac tually implemented, because the cost s associated with HPF restoration estimates are sometimes used in permitting a nd settlement negotiations about required technologies to minimize impingement and entr ainment. This report provides a detailed
discussion of the data and methods needed to co nduct valid and reliable restoration scaling. The rate of fish production is not onl y an appropriate measure of the amount of restoration needed to offset a given loss, but it is also among the most useful me trics for monitoring restoration success. Use of scientifically rigorous methods an d targeted restoration monitoring to fill data gaps can greatly improve the ability of practitioners to reliably scale rest oration projects, predict the ecological benefits of restorati on, and monitor restoration success.

Project objectives were to:

` Provide an overview of restoration scaling

` Evaluate the HPF method as it has been used to scale restorati on in California power plant studies

` Recommend ways to improve the data and met hods used for restoration scaling to offset
entrainment losses

` Provide information on restora tion actions that may benefit California species vulnerable
to entrainment

` Identify the information needed to develop comprehensive estimates of restoration costs

` Discuss the use of restoration cost s in cost-effectiveness analysisv ` Develop recommendations for scientifically rigorous and robust techniques and additional data that can be used to improve the validity and reliability of restoration scaling.

Key findings include:

` When properly applied, restoration scaling can be an objective, quantitative, and transparent approach for determining the amount of restoration needed to offset impingement and entrainment losses. There is a substantial and gr owing literature on appropriate methods for c onducting restoration scaling.

` The HPF is often not a suitable scaling met hod because it typically does not adequately measure or estimate the increase in fish produc tion (the gain) expect ed from restoration. Such a measure or estimate is necessary to reliably estimate the amount of restoration needed to achieve a gain sufficient to offset a given loss.

` Appropriate restoration scaling metr ics for fish include measures of recruitment , the addition of new recruits to the popul ation per unit area per unit time, or productivity , the rate of biomass production per unit area per unit time.

` The HPF often is not a reliable measure or estim ate of recruitment or productivity. It is an
estimate of the amount of habitat within a waterbody that could contain the quantity of
larvae entrained based on the fraction of the larval population lo st to entrainment mortality. For example, the HPF assumes th at if 10% of the larval population is entrained, then these larvae must occupy th e same fraction of the source water area (SWA) (i.e., 10% of the SWA).

` This HPF assumption requires that organisms are uniformly distributed in the SWA and
that the boundaries of the SWA and larval population can be clearly defined. These conditions are unlikely to be met except in closed or semi-enclosed water bodies. HPF estimates for entrainment at ocean power plan ts have significant uncertainty and this uncertainty will be difficult to overcome.

` Comparison of HPF restoration scaling with results using more appropriate scaling metrics indicates that the HPF may significan tly underestimate the sc ale of restoration
needed to offset entrainment losses.

Conclusions

` The HPF method often does not provide an appropriate and reliable measure of the amount of restoration needed to offset a gi ven magnitude of entrainment loss and should be used for this purpose only when site condi tions justify the assumptions required in an HPF analysis.

` Restoration scaling should be based on a measur e or estimate of the increase in numbers or biomass of the species and life stages of concern in the restored habitat.vi ` Despite the appeal, and sometimes need, of rela tively simple methods, more scientifically rigorous and robust restoration techniques are practical and would increase the likelihood
of restoration success.

` If unreliable scaling techniques are used, ther e is a serious risk of underestimating the amount and cost of restoration, resulting in a failure to achieve the expected mitigation of
entrainment losses.

Project recommendations include:

` Limit use of the HPF method to estimating the amount of the SWA that is equivalent to
the fraction of the larv al population entrained.

` Estimate the HPF for power plants located on bays and estuaries only. Estimates for power plants located on open coasts are too un certain and unreliable to be useful, even with extensive analysis of larval dispersal and ocean currents.

` Scale restoration based on a measure of the eco logical benefits expected to result from a given restoration action.

` Use the same metrics for restor ation scaling and monitoring.

` Conduct adaptive management of restoration activ ities to ensure that restoration goals are

met.

` Design restoration monitoring to collect da ta that can reduce scaling uncertainty.

Project benefits

The information provided in this report can be nefit California regulator s, facility operators, environmental stakeholders, and the Energy Commission in several ways.

` Results provide guidelines for objective, scientifically-base d, and transparent restoration scaling to address environmental impacts from power plants and other kinds of facilities, including hydropower f acilities and desalination plants co-located with power plants.

` Scientifically-rigorous rest oration scaling methods, comb ined with ongoing restoration monitoring that will help fill data gaps, w ill greatly increase the likelihood of successful
restoration actions.

` Restoration costs based on valid restoration scaling make it possible to compare the costs to permit applicants of implementing technolog y to minimize losses with the costs to the public to mitigate losses absent the technology, which is directly relevant to licensing and permitting decisions about cost-effectiveness.vii 

## Table of Contents

Abstract....................................................................................................................... .................... ii

Preface........................................................................................................................ .................... iii

Executive Summary.............................................................................................................. ......... iv

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

1.1 Background and Overview ......................................................................................1 1.2 Project Objectives ....................................................................................................3 1.3 Report Organization.................................................................................................3

2. Project Approach ............................................................................................................ .....4

3. Project Outcomes............................................................................................................ .....5

3.1 Background on Restoration Scaling........................................................................ 5 3.2 The HPF Scaling Method........................................................................................ 6 3.3 Evaluation of HPF Assumptions............................................................................. 7 3.3.1 Assumption of habitat limitation ................................................................ 7 3.3.2 Standing stock compared to rate of fish production ................................... 7
3.3.3 Definition of the SWA................................................................................ 8 3.3.4 Interpretation of PM.................................................................................... 9 3.3.5 Habitat equivalency .................................................................................. 10 3.3.6 Scaling based on averages ........................................................................ 11 3.3.7 Discounting............................................................................................... 13 3.4 Evaluation of HPF Analyses................................................................................. 14 3.4.1 Moss Landing Power Plant ....................................................................... 14 3.4.2 Morro Bay Power Plant ............................................................................ 18 3.4.3 Diablo Canyon Power Plant...................................................................... 19 3.4.4 Huntington Beach Generating Station ...................................................... 20 3.4.5 Summary of omissions, biases, and uncertainties in HPF analyses.......... 21
3.5 HPF Alternatives................................................................................................... 22 3.5.1 Alternative scaling approach..................................................................... 22 3.5.2 Developing estimates of fish production .................................................. 23 3.5.3 Restoration monitoring and adaptive management................................... 29 3.5.4 Guidelines for restoration scaling ............................................................. 30 3.5.5 Recommended elements of a restoration proposal ................................... 30 3.5.6 Scaling alternatives when speci es are not habitat-limited ....................... 30
3.6 Use of Restoration Costs in Cost-Eff ectiveness and Cost-Benefit Analyses ....... 31 3.6.1 Cost-effectiveness analysis ....................................................................... 31 3.6.2 Cost-benefit analyses ................................................................................ 31viii 4. Conclusions and Recommendations ..................................................................................33

4.1 Conclusions........................................................................................................... 33
4.2 Recommendations................................................................................................. 34
4.3 Benefits to California............................................................................................ 35

References..................................................................................................................... .................36

Glossary ....................................................................................................................... ..................45

List of Species................................................................................................................ ................47

Attachment I. Restoration Ac tions and Restoration Costs.............................................................48

Endnotes....................................................................................................................... ..................66ix 

## List of Figures

1 The relationship between the size of SWA and the size of the replacement habitat (A

r ) under different hypothetical scenario s in which values are varied for the habitat quality of the replacement habitat before (q b ) and after restoration (q

r ) relative to that of the SWA (q i ) ................................................................ 11 2 Production flows to nekton from net annual marsh primary production.......................... 27



## List of Tables

1 Hypothetical example illustrating vari ation in average PMs resulting from
differences in the estimated size of the source areas used in the averaging ..................... 12
2 Alternative HPF estimates of the scal e of restoration us ing the different averaging scenarios provided in Table 1 .......................................................................... 12 3 Summary of results of HPF analyses for four coastal pow er plants in California............ 15 4 Summary of analysis of HPF assumptions for the MLPP, MBPP, DCPP, and HBGS .... 17 5 Summary of omissions, biases, and uncertainties in HPF scaling.................................... 22 6 Estimates from the published literature of rates of secondary production in
coastal habitats............................................................................................................... ... 291 

## 1. Introduction

1.1 Background and Overview

Ecological restoration is increasi ngly recognized as one of the mo st important ways to protect natural resources from degradati on and species loss as a result of human activities. The CALFED Program, for example, has spent nearly a half bi llion dollars in the past three years alone on habitat restoration actions to help restore the ecological health of the San Francisco Bay/Delta ecosystem ( http://calwater.ca.gov/performancetracking/ ).

Restoration can be particularly important when human activities that are necessary to promote human welfare harm ecological res ources in ways that cannot alwa ys be prevented. For example, in some cases even the best technology avai lable (BTA) cannot eliminate all environmental injuries that may result from power plant c onstruction and operation, and permitting agencies may seek habitat restoration to offset injuries that may continue to occur even after technology implementation.

The use of cooling water intake structures by Ca lifornia’s coastal power plants is a prominent example of a technical feature of power plant operation that ma y include residual impacts even after application of BTA. For the past several years, the U.S. Environmental Protection Agency (EPA) has been developing regulations to mi nimize the adverse environmental impacts of cooling water intake structures, pursuant to Section 316(b) of the federal Clean Water Act (CWA) (33 U.S.C. §1326). The State of Californi a Water Quality Control Board and associated regional boards implement Section 316(b) unde r the federal National Pollutant Discharge Elimination System (NPDES) program. Th e California Energy Commission (Energy Commission) has authority for certifying any ne w or expanded facility with greater than 50 megawatt (MW) capacity, pursuant to the 197 4 Warren-Alquist Act (Public Resources Code Section 25000 et seq.). When these plants are in the coastal zone, the California Coastal Commission (CCC) has an important role in th e review of re-poweri ng projects. The Energy Commission must abide by CCC decisions unless they are infeasible or w ould result in greater
harm to the environment.

Section 316(b) of the federal CWA provides that:

Any standard established pursuant to Section 1311 [CWA §301] or Section 1316 [CWA §306] and applicable to a point source shall require that the location, design, construction, and capacity of cooli ng water intake structures reflect the best technology available for minimi zing adverse environmental impact.

EPA has interpreted Section 316(b) to mean that “adverse aquatic enviro nmental impacts occur whenever there will be entrainment or impinge ment damage as a result of the operation of a specific cooling water intake structure” (U.S. EP A, 1977). As a cooling water intake structure withdraws water from local water bodies, organi sms in the water column are trapped against intake screens (impingement) or drawn into th e power plant’s cooling system (entrainment), resulting in losses of billions of organisms each year, mostly the eggs, larvae, and juveniles of
estuarine and marine fishes.2 Despite the development of a number of mitiga tion technologies, such as screens across the openings of intake pipes, it has proven impossible to eliminate all of the organism losses that may occur as a result of intake structure operation. In partic ular, there are currently few technologies or operational measures for effectiv ely reducing entrainment (U.S. EPA, 2004a). As a result, habitat restoration has been consider ed as a means to offset unavoidable losses.

Although the courts have ruled that restoration is not a technol ogy for the purpose of determining BTA under Section 316(b), both the Californi a Coastal Act (CCA) and the California Environmental Quality Act (CEQA) include provis ions for restoration as a means of protecting
California’s natural resources:

` The CCA requires that marine resources be maintained, enhanced, and, where feasible, restored (Section 30230), and that the biolog ical productivity and the quality of coastal waters, streams, wetlands, estuaries, and lakes be maintained and, where feasible, restored (Section 30231).

` CEQA considers a variety of measures, includi ng avoiding impacts; minimizing impacts; rectifying the impact by repair ing, rehabilitating, or restori ng the impacted environment; reducing or eliminating the impact by pres ervation and maintenance; and compensating for the impact by replacing or providing substitute resources or environments.

In addition, entrainment often o ccurs even with the implementation of BTA. Thus, irrespective of national Section 316(b) regulations, California licensing and permitting agencies may continue to require restoration as a means to offset impingement and entrainment losses that may continue to occur even after implementation of BTA. Furthermore, the cost of sufficient restoration to offset entrainment and impingeme nt that would occur with different technology alternatives can be an important element in evaluating which technology to require at a given facility, where different alternatives may fit within the definition of BTA.

Because of the continued importance of restorati on in this and other contexts, California will need reliable methods to quantify the production of organisms in restored habitats, both to
estimate the amount of restoration needed to offs et losses and to determine restoration success where restoration is actually implemented. Rest oration scaling can use ecological metrics to develop such estimates, and is the focus of this re port. “Scale” refers to the spatial and temporal extent of a restoration action, a nd “restoration scaling” involves the process of determining the scale of restoration by balancing restoration gains with resource losses. Restoration scaling can be used to evaluate the type and amount of harm caused by a given e nvironmental impact, the type and amount of benefit resulting from restor ation, and the equivalency of restoration gains compared to environmental losses.3 

### 1.2 Project Objectives

The overall objective of this project was to cons ider key ecological issu es in determining the type, amount, and cost of restoration needed to of fset losses of estuarine and marine fishes from environmental impacts in California’s nearshore wa ters, with a focus on entrainment losses from the operation of power plant coo ling water intake structures.

Specific objectives were to:

` Provide an overview of restoration scaling

` Evaluate the habitat production foregone (H PF) method as it has been used to scale
restoration in Californi a power plant studies

` Recommend ways to improve the data and met hods used for restoration scaling to offset
entrainment losses

` Provide information on restora tion actions that may benefit California species vulnerable
to entrainment

` Identify the information needed to develop comprehensive estimates of restoration costs

` Discuss the use of restoration cost s in cost-effectiveness analysis

` Develop recommendations for scientifically rigorous and robust techniques and additional data that can be used to improve the validity and reliability of restoration scaling.



### 1.3 Report Organization

This report provides an overview of restorati on scaling and evaluate s the HPF method. Our
review of the HPF method include s an in-depth discussion of sp ecific assumptions of the HPF method, an evaluation of HPF analyses conducte d to date, and ways to develop a more scientifically-rigorous and reliable scaling technique. This material is followed by a discussion of
the use of restoration costs for cost-effectiveness analysis. The re port includes an attachment that provides suggestions for restoration actions for particular species and information needed to develop comprehensive restoration cost estimates. This material is organized into the following
sections:

` Section 2 outlines the project approach

` Section 3 discusses project outcomes, in cluding background on re storation scaling (Section 3.1); a description of the HPF me thod (Section 3.2); an evaluation of the main assumptions of the HPF (Section 3.3) ; a review of HPF studies as of 2007 (Section 3.4); recommendations for wa ys to improve restoration scaling4 (Section 3.5); and the use of restoration costs for cost-effectiveness evaluations (Section 3.6)

` Section 4 provides conclusions and recommendations for how the Energy Commission can use project results to conduct restoration scaling, evaluate restoration proposals, and increase the lik elihood of successful restoration actions.



## 2. Project Approach

Documents on the HPF were assembled and review ed for appropriateness of assumptions, data, methods, and interpretation of results. Ther e is no single document that provides a comprehensive description of the HPF method. For this review, we consid ered information found in parts of several documents and presenta tions, including: Duke Energy (2000); CCRWQCB (2004); CEC (2005); Foster (2005); Raimondi et al. (2005); Appendix C of York and Foster (2005); Raimondi (2005, 2006a, 2006b); Davis et al. (2006a, 2006b); Steinbeck (2006a, 2006b); and Steinbeck et al. (2007).

We also reviewed individual HPF analyses fo r four power plants (Moss Landing, Morro Bay, Diablo Canyon, Huntington Beach) to assess the basis for and validity of their restoration
estimates. The entrainment studie s and modeling results underlying the HPF analyses were also reviewed: Moss Landing (Tenera, 2000b); Morro Bay (Tenera, 2001); Diablo Canyon (Tenera, 2000a) Huntington Beach (MBC App lied Environmental Sciences and Tenera Environmental, 2005). In addition, we examined relevant Ener gy Commission decisions, facility compliance documents, and other unpublished reports. We anal yzed this information by reference to the
scientific literature on restoration scaling.

We also reviewed relevant portions of recent anal yses of the environmental implications of oncethrough cooling by the Energy Commission (York a nd Foster, 2005), fisheries scientists with experience in conducting entrainment studies and H PF analyses (Steinbeck et al., 2007), and the Electric Power Research Institute (EPRI, 2007).

To identify species-specific restoration actio ns, we contacted local biologists for their
recommendations about restorati on activities that could benef it the species of concern and examined the relevant published and unpublished documents on the ecology of the species. For restoration costing information, we contacted local restoration experts for estimates of costs associated with planning, implementing, and mon itoring restoration. All s ources are cited in the main report, with complete citations for all refere nced documents provided in the reference list at the end of the report.5 

## 3. Project Outcomes

3.1 Background on Restoration Scaling

Restoration scaling begins by expressing losses and gains in equivalent units, and then establishes a scaling equation with losses on one side and restoration gains on the other. The scaling exercise adjusts the amount of restoration until the equati on balances future gains with past (and ongoing) losses (NOAA, 1997; Ofiara, 2002; Allen et al., 2005a).

Many restoration scaling techniqu es originated in the context of natural resource damage assessments (NRDAs). They were designed to assi st in the assessment of damages resulting from natural resource injuries that can be difficult to value using a monetary cu rrency of exchange. In economics, value is based on the concepts of pr eferences and tradeoffs. The use of ecological metrics for restoration scaling makes it possible to express preferences and tradeoffs in terms of an ecological rather than a monetary currenc y of exchange (Freeman, 1993; Kopp and Smith, 1993; NOAA, 1997; Ofiara, 2002).

Three categories of scaling techniques that ha ve been devised to ev aluate equivalence among restoration losses and gains include resource-to-resource, service- to-service, and value-to-value scaling. When the number of organisms (or other re source unit) lost and ga ined can be measured, a resource equivalency analysis (REA) can be conducted using resource-to-resource scaling

. Here, the primary challenge is to differentia te organism losses and gains through time from fluctuations in biological populati ons that result from other factor s such as natural environmental variation, immigration, emigration, interactions among species, and other ecological constraints (Allen et al., 2005a).

If the injury is to habitat, and it is possible to measure both the area of hab itat lost and the area of habitat needed to offset the loss, then a habitat equivalency analysis (HEA) is an appropriate scaling technique. In practice, most HEAs invol ve the measurement of one or more natural resource “services” in a process known as service-to-service scaling . NOAA (2006) has distinguished two types of servi ces: human use services, which ar e those services that natural resources provide to people (e.g., surface wate rs provide drinking water); and ecological services, the services that one natural resource provides anothe r natural resource (e.g., wetlands provide nursery habitat for fish) (Allen et al., 2005a), which are assumed to be valued by the public.

Value-to-value scaling focuses on the value (i.e., benefits or satisfaction) that people derive from natural resources, where values can be compared or measured without conve rsion to dollars. This type of analysis, known as value equivalency analys is (VEA), is useful wh en it is not possible to restore exactly the same services as those lost , but it is possible to identify equally valued alternative services for restoration (A llen et al., 2005a; Lazo et al., 2005).6 

### 3.2 The HPF Scaling Method

The first step in an HPF analysis seeks to represent entrainment losses in terms of habitat area. This is accomplished by conducting source water sampling of larvae and using an entrainment assessment method known as the Empirical Tran sport Model (ETM) to estimate the proportional mortality (PM) of larvae in the source water ar ea (SWA) due to entrainment (Steinbeck et al., 2007). 1

For enclosed or semi-enclosed water bodies, the SWA has been determined using methods such as geographic information system (GIS) and ha bitat data layers from the National Wetlands Inventory and other sources.

For open coast species, the approximate boundari es of the SWA and larval populations are difficult to determine. Estimates are develope d by considering the along shore distance over which larvae vulnerable to entrainment may disp erse to the intake. This is determined by considering the period of larval duration and the distance along the coast those larvae could have traveled during that time, which is measured by the net current displacement (i.e., the distance water could have traveled during that time) . The alongshore length of the SWA is then determined by multiplying the period of larval duration by the net current displacement. This length is multiplied by a constant for offshore distance (the width of the area of plankton sampling) to determine the SWA (Steinbeck et al., 2007).

By multiplying the SWA by the PM, the area within the SWA containing the quantity of larvae entrained (the so-called H PF or area production foregone) is determined as follows:

A = PM Η SWA (Equation 1)

where:

A is the estimated area containing the qua ntity of larvae entrained (i.e., the HPF estimate).

For example, if the PM is 25% (i.e., 25% of th e larval population in the SWA is entrained) and the SWA is 2,000 acres, then the HPF assumes that 25% of 2,000 acres is the amount of habitat represented by the entrainment loss. In this example, the estimate is 500 acres. 2

The second part of an HPF analysis assumes that this HPF estimate also gives the amount of replacement habitat needed to pr oduce organisms at a level sufficie nt to offset the entrainment loss. This step is problematic for several reasons, particularly because it implicitly equates larval standing stock in the SWA (i.e., en trained fish per unit area) with fish productivity (i.e., fish production per unit area per unit time). For this to be a valid approximation, a number of important conditions must be met, as discussed in the following section.7 

### 3.3 Evaluation of HPF Assumptions

If the PM is used as a straight multiplier to determine the amount of replacement habitat (i.e., PM × SWA = HPF = area of replacement ha bitat), the SWA must have the following
characteristics in order to serve as a valid estimat e of the area of replacement habitat needed to increase larval production to the level needed to o ffset entrainment losses:

` The replacement habitat and the SWA must have very similar species (and species mix), age distributions, and immigra tion/emigration relationships.

` The replacement habitat must have very sim ilar productive capacity as the SWA (i.e., the rate of larval production in the replacement hab itat, on an aerial basis, must be equivalent to the rate of larval production in the SWA).

` The replacement habitat must be capable of producing an increase in larval production above the baseline production that would be achieved in that habitat absent the restoration actions. (Note that preservation al one will only yield an increase production if
losses of those habitats can be reason ably expected without preservation.)

` The replacement habitat probably must be in a different location from the affected SWA to avoid offsetting any increase by ex posing the larvae to entrainment.

Below we discuss a number of issu es related to these assumptions.

3.3.1 Assumption of habitat limitation

The HPF method implicitly assumes that entr ained species are limited by the production of larvae and that larval production is limited by ha bitat. However, there are numerous factors that can limit fish populations, and the assumption that production is habitat-limited may not hold for all species or life stages. For example, local populations of fishery species may be limited by fishing mortality on adults, or larvae may be limited by food availability. If such factors are limiting populations of entrained species, then restoration of larval habitat may do little to
increase recruitment and offset entrainment losses, even though re storation may be beneficial to the environment in general.

3.3.2 Standing stock compared to rate of fish production

The HPF approach implicitly assumes that there w ill be an increase in the numbers or biomass of entrained fish in a replacement habitat based on knowledge of larval sta nding stock (i.e., the PM and HPF are referenced to larval density in the SWA). However, standing stock is a measure of fish per unit area at a single point of time, not a measure of the rate of change in fish production (fish produced per unit area per un it time). For restoration sca ling, the appropriate unit of comparison includes both ar ea and time (NOAA, 1997).8 Even if habitat limitation is found to be a factor for species of concern, habitat restoration will only augment larval production if baseline cond itions in the replacement habitat are suppressing current production. The goal of restoration is to increase baseline production in a replacement
habitat at a scale that will augment production sufficiently to offset losses. Therefore, restoration scaling requires measures of recruitment (the addition of new recrui ts to the population per unit time) or productivity (the rate of biomass production per unit time). The density of organisms in
the water column is a measure of standing stock, which may not correlate with recruitment or productivity.

Standing stock refers to the abundance or biomass of organisms within a unit area at a single instant in time, and is therefor e not a measure of population cha nge. In fact, species with the same standing stock may have very different rates of production. For ex ample, a population of large, slow-growing individuals with low productiv ity could have the same standing stock as a population of small, fast-growing in dividuals with high productivity.

Standing stock can be used to estimate productivity only if: (1) those individuals observed at the time of abundance sampling are all the individuals of the age sampled that will be produced that year, (2) there is no turnover, and (3) there is no immigration or emigration. Abundance may be less than production if there is immigrati on, multiple spawning bouts not covered by the sampling regime, or sampling inefficiency (includi ng gear inefficiency or failure to adequately sample a patchy habitat). Abundance may be great er than production if there is emigration.

3.3.3 Definition of the SWA

For HPF results to be valid, the SWA must meet the following conditions:

` The SWA must comprise relatively uniform hab itat with organisms evenly distributed in
the SWA

` The larval population in the SWA must be a closed or semi-enclo sed population or the
aerial extent of the SWA and the distance and ti ming of larval dispersal into the area must
be known.

There are realistic circumstances that can viol ate these assumptions. For example, the aerial extent of the SWA may be too difficult to determine reliably if the hydrodynamics of the SWA
and the zone of influence of the intake are too complex to determine larval dispersal, such as
when intakes are located on oceans or waters conn ected to an ocean that are subject to strong
currents or tidal influences (Steinbeck et al., 2007).

A highly variable PM over time could indicate th at larvae in the SWA are fluctuating differently than the larvae being entrained, which c ould indicate inadequate understanding of hydrodynamics or larval dispersal distances.9 3.3.4 Interpretation of PM

The PM is difficult to interpret without knowledge of absolute losses and the extent of the SWA. PM estimates have been found to be very small for wide-ranging species with a large SWA, such as northern anchovy and other small pelagic species, or as high as 50% for larvae spawned near power plants with a smaller SWA (Steinbeck et al., 2007). It is not nece ssarily true, however, that a small PM represents a large impact a nd a high PM represents a high impact. A species with a small PM in a small area will obviously experience a larger impact than a wide-ranging species with the same PM. Likewise, a species with a large PM a nd a large population area relative to the SWA may experien ce a relatively minor impact comp ared to a species with the same PM in a small, confined area that repres ents most of the SWA a nd the area containing the population (Steinbeck et al., 2007).

Where larvae are distributed over long distances, such as along open coasts where the ratio of cooling water volume to source water volume is lo w, proportional losses may appear small even though absolute losses are high (Steinbeck et al., 2007). On the one hand, this could be interpreted as meaning that losses are insignifi cant because a low PM means that only a small fraction of the total larval population is lost. On the other hand, if the permitting focus is to minimize entrainment, then absolute loss is the endpoint of interest, and the fraction of larvae
lost is not as relevant.

More importantly, although the PM indicates the fraction of the la rvae entrained, this loss is to the current generation only. The PM does not prov ide an assessment of the reproductive potential of the adult spawning stock, and therefore it does not inform the question of population sustainability or ecological significance.

Because of difficulties developing and interpre ting fractional loss models like the ETM and population-level assessments, EPA has interpreted Section 316(b) to mean that “adverse aquatic environmental impacts occur whenever there will be entrainment or impingement damage as a result of the operation of a sp ecific cooling water intake stru cture” (U.S. EPA, 1977). EPA has
focused on entrainment loss because it is the most direct measure of impact and is the measure with the least uncertainty.

Entrainment assessments focusing on higher levels of biological organization (such as the ETM fractional loss model) involve si gnificantly more data collecti on, as well as more uncertainty,
than the direct measure of entrainment at th e intake (see EPRI, 1999, for a description of the wide variety of assessment methods available, including data needs and uncertainties).

For example, the following data from the ETM are required to implement the HPF method using PM as a scaling metric:

` Total number of larvae entrained (parameter E in the ETM)
` Larval density and abundance in the affected area (parameters ρ and N in the ETM)
` Proportion of sampled source water to total source water (parameter P
s in the ETM).10 Of these various inputs, only the total number of larvae entrained can be measured directly with relatively minimal uncertainty a nd without ecological assumptions.

3.3.5 Habitat equivalency

The HPF approach does not examine equivalence di rectly, but implicitly assumes that all acres of habitat producing entrained organisms and bei ng restored are equal with a simple one-to-one relationship, on an areal basis, between losses and gains. Howe ver, the method establishes a balancing equation based on different types of habita t, defining losses in units of wetted area and gains in units of nearshore habitats that produce larvae.

Moreover, it is almost never the case that the ecological qual ity of a restored habitat is comparable to that of the origin al habitat (Strange et al., 2002). In fact, a recent review of fish habitat restoration projects in Canada found that even use of a mitigation ratio of 2:1 was not
sufficient to ensure “no net loss” for a ll projects (Quigley and Harper, 2006).

Another complicating factor is th at the habitat targeted for rest oration, regardless of quality, may currently support some “baseline” amount of fish production. In su ch cases, the restoration gains must be assessed as the incremental change in quality, not simply the qu ality after restoration (NOAA, 2006).

The implications of habitat differences for the scale of restoration can be illustrated using a generalization of the basic HPF method that ac counts for quality differences, expressed as:

A
r = (PM × SWA) × q i / (q

r – q b ) (Equation 2)

where:

A
r is the area of restored habitat
PM is the PM in the SWA SWA is the area containing larvae at risk of entrainment

q i is the relative habitat quality within the SWA

q r

is the relative habitat quality of the A

r after restoration

q

b is the relative habitat quality of the A

r before restoration.

Figure 1 is a graphical repres entation of some differen t habitat quality scenarios.

Our formulation allows for the unlikely possibility th at restored habitat is superior to the habitat of the SWA (q

r > q i ). More likely are situations where restor ed habitat is inferior to the habitat of the SWA (q

r < q i ). In such cases, the area needed for restoration will be larger [A

r > (PM × SWA)] than that calculated by the HPF [A

r = (PM × SWA)].11 In one recent case (Huntington Beach), resource ag encies have considered addressing potential inequalities among habitats using so-called “mitigation ratios” or “conversion factors.” Mitigation ratios were originally devised to ensu re that wetland mitigation activities achieved the goal of “no net loss” of wetland area and services. The purpose of mitigation ratios is to help achieve an appropriate scale of restoration when wetland habitats differ in type or quality or when there are significant uncerta inties about habitat productivity. However, if such ratios are selected without a formal analysis using avai lable ecological information, uncertainties about whether proposed restoration will offset entrainment losses will not be resolved. In such cases,
the results of restoration monito ring are necessary to determine appropriate ratios and potential adjustments in the amount of restoration.

3.3.6 Scaling based on averages

The HPF scales restoration based on the average SWA and the average PM for the species of concern. An argument presented in favor of aver aging is that each taxon can be considered an independent sample from the coll ection of all taxa that are entr ained, and therefore the mean of several of these samples can be us ed to represent the loss rate fo r all entrained taxa (Steinbeck et al., 2007). In addition, the a ssumption is made that the estimate of impact becomes more reliable with increasing sample size (i.e., the num ber of species evaluated) (Davis et al., 2006b). 0.00 5.00 10.00 15.00 20.00 25.00 30.00 35.00 40.00

0.00 10.00 20.00 30.00 40.00 50.00 60.00 70.00 80.00

SWA areaAr(area to restore)_ PM = 20%; q r = 0.5 q i ; q b = 0.1 q i

PM = 20%; q r = 0.5 q i ; q b = 0

PM = 20%; q r = q i ; q b = 0.1 q i
PM = 20%; q i = q r ; q b = 0

PM = 20%; q r = 1.5 q i ; q b = 0

Figure 1. The relationship between the size of SWA and the size of the replacement habitat (A
r ) under different hypothetical scenario s in which values are varied for the habitat quality of the replacement habitat before (q b ) and after restoration (q
r ) relative
to that of the SWA (q i )

.12 However, the average PM is difficult to interpret when the size of the SWA differs by species. The situation is analogous to the problem of av eraging several ratios wh en the denominators are different. This kind of averaging strongly influe nces HPF estimates of the area of replacement
habitat needed to offset losses.

This problem is illustrated in Table 1 for a si mple hypothetical example for two species, where the respective populations do not in crease in the same proportion as the size of the SWA, such as when a species depends on a specific habitat th at is not uniformly di stributed in a region.

Table 1. Hypothetical example illustrating variation in average PMs resulting from
differences in the estimated size of the source areas used in the averaging

Fish species Estimated
larvae in a
10 km 2 area Estimated
larvae in a
50 km 2 area Larvae lost to
entrainment in sampling period PM assuming a 10 km 2

source area PM assuming a
50 km 2 source

area
A 1,000 2,000 500 50% 25%

B 2,000 10,000 1,000 50% 10%

PM averaging method Average PM

Average PM assuming a 10 km 2 source area for both Species A and Species B 50.0%

Average PM assuming a 50 km 2 source area for both Species A and Species B 17.5%

Average PM assuming a 50 km 2 source area for Species A and a 10 km 2 area for Species B 37.5%

Average PM assuming a 10 km 2 source area for Species A and a 50 km 2 area for Species B 30.0%

Specifically, assume that Species A and Species B are both entrained by the intakes of power plant Y, and they have different larval population sizes (that vary differen tly between species as SWA size increases) and different entrainment rates. If the PMs for the two species are
calculated on the basis of an estimated source area of 10 km 2 , then the PM for both species is 50% (see Table 2). If these PMs are averaged, then the average PM is also 50%. If instead, the SWA for both species is estimated as 50 km 2 , then the calculated PM for Species A is 25%, while the calculated PM for Species B is 10% (see Table 1). In this case, the average of the PMs is only 17.25%.

Table 2. Alternative HPF estimates of the scale of restoration using the different averaging scenarios provided in Table 1

PM calculation Average

PM Average

source area HPF (average PM × average source area)

Average PM assuming a 10 km 2 source area 50.0% 10 km 2 5.00 km 2

Average PM assuming a 50 km 2 source area 17.5% 50 km 2 8.75 km 2

Average PM assuming a 50 km 2 source area for Species A and a 10 km 2 source area for Species B 37.5% 30 km 2
(average of the 10 km 2 and
50 km 2 source areas) 11.25 km 2

Average PM assuming a 10 km 2 source area for Species A and a 50 km 2 source area for Species B 30.0% 30 km 2
(average of the 10 km 2 and
50 km 2 source areas) 9.00 km 213 Now consider what happens to the average PM when the estimated SWAs for the two species are different. If the PM of Species A is 25% based on an estimated SWA of 50 km 2 , and the PM of Species B is 50% based on an estimated SWA of 10 km 2 , then the average PM is 37.5%. But if the PM of Species A is 50% based on a 10 km 2 SWA, while the PM of Species B is 10% based
on a 50 km 2 SWA, then the average is only 30%.

Thus, the PM calculation is very sensitive to the size of the SWA, and therefore to the assumptions that are used to estimate the SWA. In turn, the effects of the size of the SWA, on the PM and average PM, influences the results of th e restoration scaling. Us ing the information in Table 1, Table 2 shows that the scale of restora tion to offset the entrainment of Species A and Species B will vary from 5 to 11 km 2 depending on estimates of the average PM and the average

SWA.

Another consequence of averaging is that the amount of restorati on may be insufficient to offset the losses of any species requiring more habitat than the average. Th is is one reason that the scale of restoration is often based on the species requiring the maximum amount of restoration (e.g., Strange et al., 2004a, 2004b; Allen et al., 2005b).

In most cases it will be importa nt to account for all species losse s individually, particularly if there is significant variation in their habitat re quirements, life history, or other characteristics such as rarity (e.g., threatened and endangered species ). In fact, it is ofte n argued that all species should be included in loss estimates, particularly when the assessment is part of a cost-benefit analysis (e.g., Suter, 2005).

3.3.7 Discounting

The HPF method does not incorpor ate discounting, which is co mmon practice in restoration scaling and which is required when integrating restorations gains over time for comparison with losses over time. Both the loss and gain side of a scaling equation are discounted to express results in terms of a common year. This makes it possible to compare th e timing and duration of losses with the predicted timing and trajectory of restoration gains (J ulius, 1999; NOAA, 1999).

In addition to accounting for lags between the timing of loss and recovery, discounting converts losses and gains into “present valu e equivalents.” This is done to account for the fact that gains in fish production in the future as a result of restoration are less valuable to the public than fish available now, much in the way a dollar now is worth more than a dollar later.

The discount factor is:

(1 + d ) y (Equation 3)

where:

d is the discount rate and y is the years before or after entrainment

y is the years before or after entrainment, calculated as y = year of entrainment – year of
interest.14 For example, to account for the delay between th e time of entrainment loss and the time that restoration achieves the targeted level of fish production, discounting is used to express the total value of restoration gains ove r all years (TV) in terms of the year of the loss:

y

y d V TV )] 1 ( / 1 [ + = 

# ∑ (Equation 4)

where:

V y is the value y years after the loss. The Na tional Oceanic and Atmospheric Administration (NOAA) and other resource agencies t ypically use a discount rate of 3% for discounting public resources a nd values (Julius, 1999; NOAA, 1999).



### 3.4 Evaluation of HPF Analyses

The HPF method has been used to estimate the scal e of restoration needed to offset entrainment losses at Moss Landing, Morro Bay, Diablo Cany on, and Huntington Beach. Table 3 summarizes the results of HPF analyses for the four power plants, followed by an evaluation of the analyses
in terms of the issues outlined in Section 3.3.

3.4.1 Moss Landing Power Plant

The HPF method was first used for the Moss Landing Power Plant (MLPP) modernization project. The MLPP is located near Moss Landing Harbor, about 12 miles northwest of the Town of Salina on the Central Coast of California, ad jacent to Monterey Bay. In 1999, the facility operator proposed to modernize the facility. Units 1-5 of the facility’s seven generating units were retired in 1995. The proposed moderniza tion added two, 530 MW, natural gas-fired, combined cycle units that utilized the intake system of the retired units and the discharge structure for Units 6 and 7. In addition, Units 6 and 7 were upgraded by 73 MW. Combined, the new units and Units 6 and 7 use about 850 million gallons per day (MGD) of seawater for cooling (Duke Energy, 2000).

The organisms entrained were assumed to use Elkhorn Slough as their pr imary habitat. Elkhorn Slough is a protected area north of the MLPP with tidal marshes, mudflats, and shallow open water habitat. Eight “target taxa” (i.e., the most abundant species/taxa in entrainment samples) included unidentified gobies, bay goby, blackey e goby, longjaw mudsucker, blennies, Pacific herring, white croaker, and Pacific staghorn sculpi n. These species made up 95% of all entrained larvae collected in entrainment sampling, and we re considered “proxy species” for all entrained species (Tenera, 2000b).15Table 3. Summary of results of HPF analysesfor four coastal power plants in CaliforniaPower plantAnnual entrainment of fish speciesincluded in HPF estimate (rounded)PMAVGfor fishspecies included inHPF analysis (%)SWA used forHPF analysisAmount of restorationestimated by HPFEstimated cost ofproposed restorationMoss LandingaAll target species:Unidentified gobies – 2.7 × 108Bay goby – 1.5 × 108Blackeye goby – 1.7 × 107Longjaw mudsucker – 8.0 × 106Blennies – 1.7 × 107Pacific herring – 4.4 × 106White croaker – 8.6 × 106Pacific staghorn sculpin – 8.6 × 10613% 3,000 acres 390 wetland acres $7,000,000Morro BaybBay species only:Unidentified gobies – 3.9 × 108Shadow goby – 1.3 × 107Combtooth blennies – 1.0 × 107Jacksmelt – 6.3 × 106Pacific herring – 3.0 × 10633%2,300 acres759 acres $28,000,000Diablo CanyoncRocky reef fishes only:Smoothhead sculpin – 8.6 × 107Monkeyface prickleback – 7.2 × 107Clinid kelpfishes – 2.4 × 108Blackeye goby – 1.2 × 108Cabezon – 4.4 × 107Snubnose sculpin – 9.7 × 107Painted greenling – 1.7 × 107KGB rockfishes – 2.5 × 108Blue rockfish – 5.9 × 10710.76% Not reported inHPF documentreviewed200-1,000 acresartificial reef$10,000,000-$50,000,00016Table 3. Summary of results of HPF analyses for four coastal power plants in California (cont.)Power plantAnnual entrainment of fish speciesincluded in HPF estimatePMAVGfor fishspecies included inHPF analysis (%)SWA used forHPF analysisAmount of restorationestimated by HPFEstimated cost ofproposed restorationHuntingtonBeachdSoft bottom species only:Spotfin croaker – 7.0 × 106Queenfish – 1.8 × 106White croaker – 1.8 × 106Black croaker – 7.1 × 105Blennies – 7.2 × 105Diamond turbot – 5.4 × 105California halibut – 5.0 × 105Rock crab – 6.4 × 1050.56% Three estimates ofthe SWA reported:0.11 km2,4.47 km2,and an average of1.50 km2. Area usedfor EnergyCommission HPFestimate not givenin documentreviewed.208 wetland acres(all units), 104 acres(Units 3 and 4)$7,956,000(for 104 acres)a. From Table 3 and accompanying text by Dr. Pete Raimondi, University of California at Santa Cruz, in Strange et al. (2004a) based on data in Tenera(2000b). PM and HPF estimates were based on the estimatedaverage period that larvae are at risk of entrainment.b. From CCRWQCB (2004). PM and HPF estimateswere based on estimated maximum period larvae are at risk. Coastal taxa (staghornsculpin,northern lampfish, rockfishes, white croaker, cabezon) had a PMAVGof 3% and were not included in theHPF analysis. Estimated SWA was the MorroBay Estuary. Restoration cost was based on an estimated cost of $37,000 per acre developed by staff of the Central Coast Regional Water QualityControl Board and the Morro Bay National Estuary Program, assuming restoration costs of $26,000 per acre and an average purchase cost for idealfloodplain habitat of $11,000 acre.c. From Raimondi et al. (2005). Restoration cost is based onan estimated cost of $50,000 per acre based on costing informationfor the San ClementeArtificial Reef (SCAR). Entrainment estimates are average of sampling periods 1 (1996-1997) and 2 (1997-1998) from Table 1 of Raimondi et al.(2005). Sampling period 3 overlapped period 2 and therefore was not included in the entrainment estimates.d. HPF estimates are from Biology Table 2 of Davis et al. (2006b), included with California Energy Commission’s Order RequiringPost-LicensingStudies, posted online 10/4/2006 athttp://energy.ca.gov/sitingcases/huntingtonbeach/compliance/index.html. Estimates in table were based on permittedflow of 507 MGD. Restoration cost was based on an estimate of $74,660 per acre for initial restoration costs and $784 per acrefor operation andmaintenance provided by restoration experts working on the Huntington Beach Wetlands. Final Energy Commission decision was based on actualoperational flow of 235.5 MGD for Units 3 and 4, and required 66.8 acres and $5,511,000. Analysts die not include two target taxa, gobies and northernanchovies, in the HPF analysis, because they argued that gobies do not occur near Huntington Beach Generating Station (HBGS) asadults, and northernanchovies occur over a much larger area than the nearshore SWA (Davis et al., 2006b).17 Restoration scaling using the HPF method was based on the PM AVG for the eight target species, which was 13% based on the averag e period that larvae were consider ed at risk of entrainment, and 28% based on the maximum potential period at risk. From GIS mapping, analysts concluded that there were 3,000 acres of relatively encl osed aquatic habitat in Elkhorn Slough that are subject to inundation and therefore could support the organisms subject to entrainment. This area was considered the SWA. Using this SWA estimate and the two PM estimates, the HPF analysis
estimated that the amount of restoration need ed to offset entrainment at MLPP was between 390 acres (13% × 3,000 acres) and 8 40 acres (28% × 3,000 acres).

The final negotiated settlement was for restor ation of 390 acres at an estimated cost of $7,000,000 (Energy Resources and Conservati on and Development Commission, 2000).

As summarized in Table 4, the HPF analysis for the MLPP meets some critical assumptions for HPF validity. Specifically, the SWA of entr ained larvae could be defined relatively unambiguously, and there is eviden ce that the SWA is a source of larval production for at least some entrained species. Longjaw mudsucker and P acific herring, for example, reportedly spawn in Elkhorn Slough (Duke Energy, 2000). There are al so studies indicating that other target species (e.g., gobies) are marsh resi dents (e.g., Yoklavich et al., 1991).

Table 4. Summary of analysis of HPF a ssumptions for the MLPP, MBPP, DCPP, and
HBGS. See text for details.

Power plant SWA used
to estimate

HPF Replacement
habitat Larval production is
habitat-limited Replacement
habitat includes
source of larval

production Aerial
extent of
SWA can be reliably
determined Habitat of
SWA is
uniform and

larvae are evenly
distributed

Moss Landing Elkhorn Slough,
which
contains
open water, marsh mudflats,
tidal creeks Same No evidence provided, but likely for resident species and assumption
is consistent
with efforts to
restore Elkhorn Slough Evidence for longjaw mudsucker, Pacific herring Yes No. SWA
contains diverse habitats, and
larval densities are likely to be greater in marsh, mudflats, and
tidal creeks than in open water.

Morro Bay Open water of bay No replacement
habitat proposed; HPF
estimates used to develop cost
estimates for
sediment
reduction

program No evidence provided, but likely for bay species because
of habitat degradation in the estuary No evidence provided, but
nearshore habitats of bay are likely
areas of larval production for bay species Yes, for the bay SWA No. SWA
contains diverse habitats, and
larval densities are likely to be greater in marsh, mudflats, and
tidal creeks than in open water.18 Table 4. Summary of analysis of HPF a ssumptions for the MLPP, MBPP, DCPP, and
HBGS. See text for details (cont.).

Power plant SWA used
to estimate

HPF Replacement
habitat Larval production is
habitat-limited Replacement
habitat includes
source of larval

production Aerial
extent of
SWA can be reliably
determined Habitat of
SWA is
uniform and

larvae are evenly
distributed

Diablo Canyon Open coast Rocky reef No evidence provided, but unlikely for
open coast species Unknown and
difficult to
determine No No information provided, but likely in coastal

waters.

Huntington
Beach Soft-bottom
habitat Wetlands No evidence provided, but unlikely for
open coast species Unknown and
difficult to
determine No No information provided, but likely in coastal

waters.

However, because the replacement habitat is within the affected area, it may not increase larval production, particularly to the level needed to of fset losses (i.e., as more larvae are produced in Elkhorn Slough, more larvae may be entrained).

Two major shortcomings of the MLPP HPF are common to all HPF analyses. First, the HPF considers only one year of loss and one year of potential gain in the replacement habitat, and therefore does not account of ongoing power plan ts losses nor the tr ajectory of potential restoration gains. In addition, the HPF assumes that the density of larvae in the water column, estimated from ETM modeling, is equivalent to larval productivity and can be taken as an
estimate of the increase in larval production needed to offset entrainment. As discussed previously, for this assumption to be valid it must be shown that (1) thos e individuals observed at the time of abundance sampling are all the individu als of the age sampled that will be produced that year, (2) there is no tu rnover, and (3) there is no immigration or emigration.

3.4.2 Morro Bay Power Plant

The Morro Bay Power Plant (MBPP) is located on the northeastern shore of Morro Bay near the city of Morro Bay in central California. The in take of the MBPP entrains both bay and nearshore coastal taxa, and therefore it was necessary to di vide the SWA into two sub-areas for purposes of ETM modeling, bay water and nearshore coasta l water. Calculation of the SWA was also complicated by the fact that the intake is subject to daily tidal flows. The large tidal exchange in the bay results in rapid turnover of bay waters . The volume of the Morro Bay component of the SWA was estimated as the sum of the bay’s nontid al volume and the twice daily tidal exchange of the bay’s average tidal prism, adjusted for tidal exchange. The area outside of Morro Bay in Estero Bay was treated as a static volume equal to the volume of Morro Bay uncorrected for tidal19 exchange. The size of the SWA beyond these samp led areas was estimated using current data. (Steinbeck et al., 2007).

An HPF analysis for the MBPP was based only on bay species and the bay SWA. As shown in Table 4, the PM was estimated as 33% and th e SWA was estimated as 2,300 acres, resulting in an estimated replacement habitat of 759 acres (33% × 2,300; CCRWQCB , 2004). This analysis assumes, like other HPF analyses, that standing stoc k can be used as a proxy for rates of larval production in the replacement habitat, and also fails to consider power plant losses and restoration gains over time. The facility presente d a proposal for a Habitat Enhancement Program (HEP) that had similar flaws, including the failure to show the nexus between the loss of larvae from entrainment and the gain in larval produc tion as a result of restoration (Duke Energy, 2002). 3 In addition, the HPF analysis incorrectly us ed the cost to purchase and/or restore the estimated amount of replacement habitat as a pr oxy for the value of entrainment losses (see Section 3.8 for discussion of appropriate use of habitat replacement costs). Based on these costs, the Regional Board concluded that the total value of the entrainment losses is $8.5 million (based on the facility’s assumption of a 10% larval loss ) or $28 million (based on the staff’s assumption of a 33% larval loss; CCRWQCB, 2004).

3.4.3 Diablo Canyon Power Plant

The Diablo Canyon Power Plant (DCPP) is a nucle ar-fueled generating f acility located on the open coast in central California, between the cities of Morro Bay and Avila Beach. Local biologists determined that almost all of the fish species lost to entrainment at DCPP are associated with shallow rocky reefs. Ther efore, the HPF analysis for DCPP focused on estimating the amount of rocky reef habitat that w ould be needed to offset entrainment losses of rocky reef fishes (Raimondi et al., 2005).

The amount of rocky reef restoration needed to offset entrainment losses was estimated by multiplying the PM AVG for the rocky reef fishes entrained (10.76%) by the estimated area of rocky reef within the SWA AVG of the nine species. Two al ongshore areas were selected as potential locations of the SWA, one centered at the DCPP and the other with a southern limit near the DCPP. Within each location, the SWA was assumed to be an area 74 kilometers (km) alongshore (the average alongshore di stance traveled by the vulnerabl e larvae of the nine target species) and 3 km offshore (the offshore distan ce of the fish sampling grid). Two PMs were developed for each species based on each of these SWAs, with each SWA a function of the species-specific duration of the di spersing stage of the larvae a nd the oceanographic currents that transport the larvae along the coast (Raimondi et al., 2005).

The area of rocky reef within each of these areas was determined by overlaying each of the potential average SWAs with a map of kelp cove rage in that area, base d on the assumption that most rocky reef along California’s Central Coast that occurs between 5 and 30 m in depth is likely to be covered by kelp. Because the area of offshore rocky reefs not covered by kelp is more difficult to estimate, the analysts applied a multiplier of 2 to this estimate to account for potential offshore reef area (Raimondi et al., 2005).20 Entrainment and HPF estimates are presented in Table 4. Applying the PM AVG (10.76%) to the two estimates of rocky reef area within each SWA AVG resulted in an estimate of the amount of artificial reef needed to compensate for DCPP en trainment of rocky reef fishes that ranged from 200 acres to 1,000 acres (R aimondi et al., 2005).

The HPF estimates are particularly difficult to inte rpret in this case. The effort to define the SWA for this ocean facility involved consider able effort and ingenuity, but there was still significant uncertainty in the resulting estimates. Improving the SWA estimates based on this approach would require even more extensive and costly analysis of ocean currents and larval dispersal, and it is unclear whether the uncertain ty could be reduced sufficiently. The period of larval duration is particularly difficult to determine for pelagic species.

More importantly, whether rocky reefs are a so urce of production or si mply attract larvae remains a subject of debate within the scie ntific community (Bohnsack, 1989; Bohnsack et al., 1994; Grossman et al., 1997). However, even if the reef restoration led to an increase in production, it would be necessary to manage fish ing around the reef to ensure that the expected production was realized (Powers et al., 2003).

3.4.4 Huntington Beach Generating Station

The HBGS is located in Huntington Beach, in Or ange County, California. Marine habitat near the facility is primarily sandy substrate. The Huntington Beach Wetlands, dominated by pickleweed ( Salicornia virginica ), occurs to the southeast and northwest of the facility. The intake of the HBGS is offshore in subtidal, sa nd-bottom habitat, and therefore most of species entrained are soft-bottom species (e.g., croake rs; MBC Applied Environmental Sciences and Tenera Environmental, 2005).

In May 2001, the HBGS received approval from the Energy Commission to restore and restart Units 3 and 4 for operation until September 2011, af ter the units had been retired in 1995. In 2003, Units 3 and 4 became operational, and since that time intake flows for Units 3 and 4 have averaged 235.5 MGD. Total flow for all un its is 507 MGD (MBC Applied Environmental Sciences and Tenera Environmental, 2005).

Entrainment at the HBGS was estimated from pla nkton samples taken just offshore of the intake
and based on the total intake flow of 507 MGD. Sampling iden tified a total of 57 taxa, but subsequent analyses focused on the most abundant taxa (target taxa), including three estuarine fish species (arrow goby, cheekspot goby, and sh adow goby; collectively known as CIQ gobies), seven coastal fish species (white croaker, black croaker, spotfin croake r, queenfish, blennies, diamond turbot, and California halibut), and ro ck crab megalops. Source water populations of larvae were estimated from samples collected at the station and six other stations extending 4 km upcoast, downcoast, and offshore of the in take structure (Dav is et al., 2006b).

Because the refurbishing of Units 3 and 4 is cons idered a new source of entrainment, the impact analysis was for entrainment at these two units onl y. Intake flow and entrainment for Units 3 and
4 is about half of total at HBGS (Davis et al., 2006b).21 Two estimates of the SWA were developed usin g two different alongshore lengths: one based only on alongshore current movement (12.8 km) a nd the other based on both alongshore current and an extrapolation of larval densities offshor e to a distance bounded by either the extrapolated densities or the onshore current (84.9 km). Th e width of the SWA was based on the area of plankton sampling (5 km). On this basis, the two estimates of the SWA were 0.11 km 2 and
4.47 km 2 , or an average of 1.50 km 2 (MBC Applied Environmental Sciences and Tenera Environmental, 2005).

Entrainment and HPF estimates are presented in Table 4 for target species found in soft-bottom habitat. Because there is no practical method to create soft-bottom hab itat, the restoration proposal focused on out-of-kind restorati on, specifically wetland restoration. 4 The HPF estimate,
based on the PM AVG and SWA AVG for the target species, was 104 acres based on entrainment at Units 3 and 4 (Davis et al., 2006b). Two target taxa, gobies and northern anchovies, were not included in this HPF analysis, because gobies do not occur near HBGS as adults, and northern
anchovies occur over a much la rger area than the nearshore SWA (Davis et al., 2006b).

An alternative HPF estimate by facility consulta nts used goby for scaling because most of the entrainment is of goby, which are produced in wetla nds, specifically in m udflat habitat. The HPF estimate for the CIQ goby complex was 15.35 acres (Davis et al., 2006b).

The total cost to restore 104 wetland acres was ba sed on estimates of $74,660 per acre for initial restoration costs and $784 per acre for operation and maintenance, for a total of $75,444. Cost estimates were developed by restoration expe rts working on the Huntington Beach Wetlands (Davis et al., 2006b). Assuming a maintenance period of 10 years (the term of the HBGS license), the cost to restor e the 104 acres was estimated as $7,956,000 (Davis et al., 2006b).

Like the HPF for the DCPP, a significant limitation of the HPF analysis for the HBGS is the difficulty in defining the SWA. As the HBGS entrainment study noted, the larval dispersal
distance used to define the SWA for larvae entrained by coastal intakes has a significant influence on ETM estimates of entrainment and the PM (MBC Applied Environmental Sciences and Tenera Environmental, 2005).

3.4.5 Summary of omissions, biases, and uncertainties in HPF analyses

Table 5 provides a summary of how particular HPF assumptions may affect estimates of the appropriate scale of needed re storation. The potential implications are uncertain for some assumptions. For example, the common inability to reliably convert entrainment losses into a proportion of the SWA, could either under- or over-e stimate actual ra tes of larval production. On the other hand, the directions of some other biases are clear. For instance, the lack of discounting will result in a potentially significant underestimate of the scale of future restoration required to offset past and continuing losses.

Taken together, the biases of the HPF have the potential to significantly underestimate the scale of restoration required to o ffset entrainment losses.22 Table 5. Summary of omissions, biases, and uncertainties in HPF scaling

Issue Comment Effect on estimated
scale of restoration
HPF assumes that ETM sampling of open waters of SWA samples larval
habitats Nearshore habitats such as marshes, tidal creeks, mudflats, and submerged aquatic vegetation (SAV) are not sampled. Potentially large in either
direction

HPF must assign a SWA, even when hydrodynamics, habitat diversity, and entrainment life histories are too complicated to be modeled reliably Few intakes are located where simplifying assumptions will be valid; a highly variable PM over time may indicate issues. Potentially large in either
direction

HPF assumes the density of organisms in SWA at the time of sampling is equal to the rate of larval production Measures of standing stock can only be used as a proxy for rates of production under very limited circumstances (i.e., when all the organisms recruited to the population that year are sampled and there is no immigration or emigration between the time of larval production and the time of sampling). Underestimate

HPF averages PM and SWA for multiple species Average PM and average SWA are not meaningful. Restoration requirements depend on each species’ habitat requirements. Scaling should be based on the species requiring the
maximum. Underestimate

HPF evaluates habitat losses and gains without accounting for time, including discounting Losses and gains occur over time, not in a single instant. Underestimate

HPF assumes SWA habitats produce larvae Local habitats may not be the source of local
larvae. Unknown

HPF assumes SWA and replacement habitat are equivalent in quality Restored habitat rarely functions as well as existing habitat. However, restoration sites may occasionally be available that are better than habitats that happen to be in the SWA. Usually underestimate

HPF assumes larval habitat is limiting for local fish populations The factors that limit affected populations
must be demonstrated. Underestimate if assumption is not met



### 3.5 HPF Alternatives

3.5.1 Alternative scaling approach

A straightforward alternative to the HPF approach would compare directly the measure of larval entrainment with gains in larvae from habitat restor ation. An example of this type of approach is the habitat-based replacement co st (HRC) method described in St range et al. (2004b) and Allen et al. (2005b). 5 An HRC analysis quantifie s the amount of habitat n eeded to produce organisms equivalent to those lost to entrainment (i.e., the same species and life stages). In this sense, it is a hybrid of the REA and HEA scaling approach es often used in NRDA cases (NOAA, 1997). Box 1 compares restoration estimates usi ng the HPF method with the HRC approach.23 Unlike the HPF, this type of approach does not require larval sampling of the water body to determine the size of the larval population of each species and the portion of each larval population at risk of entrainment. Therefore, it does not require modeling of the complexities of SWA-wide hydrodynamics and SWA-wi de larval dispersal, nor does it depend on the special circumstance of relatively uniform habitat in an easily defined SWA for which larval dispersal distances can be reliably estim ated. The main difficulty with the HRC and similar methods is estimating rates of fish production. The following section describes data needs and some of the methods available for estimating production rates.

3.5.2 Developing estimates of fish production

To estimate fish production for habitat scaling pur poses, one could (1) rely on site-specific data (such as the larval data collected for parameter ρ of the ETM), or (2) rely on published
information. Some of the data and methods mo st commonly used for de veloping production rates for scaling purposes are outlined below, followed by a table presenting examples of fish productivity estimates in th e scientific literature.

Box 1. Comparison of acres of restoration ne eded to offset entrainment of CIQ gobies using the HPF and HRC methods

HBGS consultants estimated the amount of replacemen t wetland to offset entrainment of the CIQ goby complex as 15.35 acres using the HPF method. b Using an estimate of the rate of goby production from the scientific literature, it is possible to develop an alternative estimate based on the HRC approach. a Allen (1982) provides data for goby production in the littor al zone in Upper Newport Bay in southern California of 0.2026 grams dry weight per acre per year (g dw m -2 yr -1 ), or 820 g dw ac -1 yr -1 . The present value equivalent of this annual production using a 3% discount rated is 82,820 g dw ac -1 yr -1

. Using the productivity estimate from Allen (1982), th e HRC method calculates the acreage to be restored by dividing the entrainment loss of gobies, expressed as present value dry weight loss of gobies over the 10-year license period (338,315,003), by the present value dry weight gain of gobies per acre over the license period (82,820 g dw ac -1 ). This results in an estimate of 4,085 acres of restoration required to offset annual goby entrainment over the next 10 years. Though based only on goby losses, this HRC estimate, using the rate of production, indicates that the HPF method may substantially underestimate the amount of restoration required to offset power plant entrainment.

The difference in cost using the two methods is also substantial, and determining the best estimate could be particularly important in settlement negotiations , even in cases where rest oration is not actually implemented (e.g., for the Salem facility in Delaware Bay). Based on the cost used for HPF estimates of $75,444 per acre, b and the HRC estimate of the scale of restor ation for CIQ gobies (4,085 acres), the cost would be $308,182,883 – orders of magnitude higher than that based on the HPF estimate for goby of

15.35 b acres by HBGS’s consultant ($75,444 × 15.35 = $1,158,065) or the HPF estimate for all species of

104 b acres by Energy Commission consultants ($75,444 × 104 = $7,846,176).

a. Strange et al. (2004b); Allen et al. (2005b). b. Cited in Davis et al. (2006b). c. Discounting converts losses and gains to “present value equivalents” to account for time lags and to express results in terms of a common year (NOA A, 1997, 1999; U.S. EPA, 2000). NOAA and other resource agencies generally use a 3% discount rate (NOAA, 1997, 1999).24 Techniques for calculating rates of production are di scussed at length in a report for the Energy
Commission entitled Research on Estimating the Environm ental Benefits of Restoration to Mitigate or Avoid Environmental Impacts Caused by California Power Plant Cooling Water
Intake Structures (Strange et al., 2004a). A special issue of the journal Marine Ecology Progress

Series (Volume 264, 2003) provides several exampl es of quantitative methods for scaling restoration, including demographic and growth m odels for single species and trophic transfer modeling to scale restoration across multiple trophic levels. Methods for estimating fish produced by habitats are summarized below.

Annual rate of fish production

Fish productivity is a measure th at integrates the recruitment, growth and survival of the individuals in a cohort or populati on. It is a comprehensive measur e of the ecological benefits of habitat restoration. Productivity estimates for each species allows determination of which species requires the largest amount of rest oration, which ensures that ther e will be sufficient restoration for all species.

A number of methods are availa ble for estimating rates of fish production from field sampling.
Cohort-based methods include (1) removal summation, (2) increment summation, (3) the instantaneous growth rate method, and (4) A llen’s graphical method (Waters, 1977; Newman and Martin, 1983; Wootton, 1990). The removal su mmation method is based on the concept that production by a cohort eventually dies or is ot herwise removed. The method involves assessing
the reduction in numbers in a cohort throughout its lifetime (Waters, 1977).

The increment summation procedure involves taki ng samples of individual weights periodically throughout the life of the cohort. From one sample to the next, the growth increment is estimated as the increase in mean individual weight. Th is estimate is multiplied by cohort numbers during the interval to estimate production during the peri od. The sum of all such estimates gives an estimate of production by the entire cohort (W aters, 1977; Newman and Martin, 1983; Morin et al., 1987).

The instantaneous growth rate method (Ricker, 1975) assumes that the instantaneous rate of growth per unit weight, g , and the instantaneous mortality rate, Z , are constant over the time interval for which production is to be estima ted (Chapman, 1978; Wootton, 1990). In this case:

P = gB 0 (e g-Z – 1) / g – Z (Equation 5)

where:

B 0 is the biomass of the individuals in a cohort at the start of the inte rval. On this basis, production can be calculated from one observation of biomass.

An extension of the Ricker (1975) instantaneous growth rate method is the graphical method of Allen (1971). This method estimates production us ing a curve in which mean individual weight,

w , is plotted agai nst cohort size, N , at particular times and then assessing the area beneath the curve (Chapman, 1978; Wootton, 1990).25 A cohort-free size-frequency approach for estimating secondary pr oductivity (Hynes, 1961; Hynes and Coleman, 1968) is conceptually si milar to removal summation, but it involves summation of losses between successive size gro ups instead of successive times (Hamilton, 1969; Waters, 1977; Menzie, 1980; Cicchetti, 1998).

Production foregone

Production foregone considers the biomass that would have been produced by the organisms lost had they lived their remaining lifetime (Rago, 1984; Dixon, 1999). Restor ation scaling based on production foregone has included the lost production of affected i ndividuals only (e.g., French McCay et al., 2003) or alternat ively, their lost production plus the production of progeny that were not produced because of the deaths of the affected individuals (e.g ., Sperduto et al., 2003).

Production:biomass ratio

A production:biomass (P:B) ratio is an index of th e rate of production of the individuals within an area per unit of biomass (Randall and Minns , 2000). A P:B ratio based on a one-year time frame is the ratio of annual pr oduction of those indi viduals to their mean annual biomass. Multiplication of the P:B ratio by mean bioma ss provides a measure of production when only biomass is known. Based on a review of fish produc tion studies and P:B ratios for tidal marshes, Kneib (2003) recommends a P:B ratio of 2 for marsh fishes. Kneib (2003) notes, however, that ratios may be considerably higher for early lif e stages (e.g., 7.55 for young-of-year fish reported by Allen, 1982).

Use of abundance as a proxy for production

If the P:B ratio is 1, then a bundance estimates can be used as a proxy for annual production if (1) those individuals observed at the time of abundance sampling are all the individuals of the age sampled that will be produced that year, (2 ) there is no turnover, and (3) there is no immigration or emigration. Abundance may be le ss than production if th ere is immigration, multiple spawning bouts not covered by the sa mpling regime, or sampling inefficiency (including gear inefficiency or failure to ade quately sample a patchy habitat). Abundance may be greater than production if there is emigration. These factors must be taken into account in determining if it is appropriate to assume that an estimate of standing stock is a reasonable surrogate for direct estima tes of fish productivity.

Abundance estimates from fish surveys in the habita t types to be restored are sometimes used to estimate rates of production. Typica lly, survey data are reported as catch per unit effort (CPUE), the number or weight of fish taken by a define d unit of sampling effort (e.g., number of fish caught per trawl).

To estimate rates of production for the purpose of scaling restoration, it is necessary to use
CPUE data for the relevant habitat and to convert the data to an equivalent estimate of abundance per unit area, defined by the area sampled. In most cases, CPUE data must also be adjusted to account for the sampling efficiency of the gear used, especially for early life stages. Often, CPUE data are available from peer-reviewed stud ies for specific habitat types (e.g., SAV, tidal26 wetlands). However, broad-based sampling progra ms (e.g., those conducted by state or federal agencies) may record catch information with a site identification numbe r without any habitat description. In such cases, discussions with in dividuals familiar with the sampling locations, and review of supporting documentati on (e.g., annual program summaries ), will enable definition of the habitat categories for sampled locations.

Estimates of sampling efficiency may occasionall y be incorporated in sampling reports, but information is also available for some types of gear in the published lite rature (e.g., Rozas, 1992; Jordan et al., 1997; Rozas and Minello, 1997; Ba yley and Herendeen, 2000) . If there are no other sources of data, those conducting the sampling can be contacted for their professional estimate of the gear efficiency based on the conditions enco untered or informal and unreported assessments (e.g., use of underwater cameras to reco rd field performance of trawls).

Trophic transfer modeling

There is increasing interest in estimating the pr oduction of communities rather than populations of single species. Trophic modeling of energy transfer through the local food web is one approach that has been used for the purposes of restoration scali ng. Trophic transfer models are based on the connection between salt marsh pr imary production and the secondary production of
both resident and transient fish and shellfish (Kneib, 2003).

Kneib (2003) developed a simple trophic transf er model to estimate th e annual production of nekton resulting from the annual production of Spartina marsh. The model is outlined in Figure 2. 6

This type of approach was applied to estimate the marsh area needed to offset impingement and entrainment at the Salem facility in Delawa re Bay (PSE&G, 1999; Teal and Weinstein, 2002). The model estimated the amount of fish pr oduced by a given amount of marsh primary production based on published studies of marsh f ood webs in local areas (e.g., a New Jersey study by Rountree and Able, 1992). See Box 2 for details on this analysis.

Fish production estimates in the scientific literature

There are a number of publishe d studies of fish production rate s that have been used for restoration scaling, and a sample of these is provided in Table 6. In the absence of site-specific and species-specific data, literature values can pr ovide a reasonable first-order approximation for scaling restoration. Once restor ation activities begin, restorati on monitoring can be designed to obtain the data needed to develop estimates for local species and site conditions and the restoration can then be adapted as needed to ensure a more accurate match between entrainment losses and gains from restoration.27 Nekton = 0.2 + 4.0 = 4.2 g dw m -2 Fungi 900 x 0.55 = 495 Bacteria 495 x 0.67 x 0.1 = 33 g Spartina 1,000 g Benthic algae 250 g

Herbivores 1,000 x 0.1 x 0.1 x 0.2 = 2 g Benthic/epibenthic consumers 25 + 3.3 + 16.3 = 44.6 g

Residents 2.8 g Migrants 1.4 g Above-ground net primary production 1,250 g dw m -2

Figure 2. Production flows to nekton from net annual marsh primary production. Based on Kneib (2003).

Box 2. Example of power plant restoration scaling using a trophic modeling approach

A member of one of the agencies involved in the scaling analysis for the Salem facility in Delaware Bay summarized the trophic modeling process as follows a :
Step 1: Determine total annual marsh primary producti on by adding estimates of primary production by marsh plants and by benthic algae:

72,790 lbs/ac/yr (plants) + 7,145 lbs/ac/yr (benthic algae) = 79,935 lbs primary production/ac/yr.

Step 2: Assuming that about 45% of this annual primary pr oduction is transported out of Delaware Bay, primary production within the bay is given as:

79,935/lbs/ac/yr × 0.55 = 43,964 lbs primary production/ac/yr.

Step 3: Most biomass of marsh plants passes through a detrital food web. Assuming that 40% of plant primary production is converted to organic detritus, then:

43,964 lbs/ac/yr × 0.40 = 17,586 lbs/ac/yr detritus.

Step 4: Allocate the detritus among invertebrates (33%) and fish (67%). Then, on this basis, the amount of detritus consumed by fish is:

17,586 lbs/ac/yr × 0.67 = 11,782 lbs/ac/yr detritus.28 Box 2. Example of power plant restoration scaling using a trophic modeling approach (cont.)

Step 5: Assume that this organic matter is converted to fish biomass as follows:

Organic matter → primary consumers (arthropods) → secondary consumers (age 1 fish).

Assuming a 20% conversion efficiency among trophic levels, b then the fish biomass produced is given as:

11,782 lbs/ac/yr × 0.2 × 0.2 = 471 lbs/ac/yr of fish biomass produced.

Step 6: Partition this biomass among the fish species impinged and entrained based on species-specific mortality rates for age 1 fish:

Species Percent of total age 1 impingement and entrainment mortality (col a) Total fish biomass (lbs/ac/yr)

(col b) Species specific production (lbs/ac/yr) (col a × col b)
Bay anchovy 36.4% 471 171

Weakfish 6.1% 471 29
Spot 9.6% 471 45 White perch 10.7% 471 50

Other fish 37.2% 471 175

Totals 100% NA 471

Step 7: Determine the area of salt marsh (acres) needed to offset each species losses by dividing the biomass of each species lost per year (lbs/yr) by the biomass of that species produced per acre of salt marsh per year (lbs/ac/yr):

Bay anchovy: 1,280,304 lbs/yr / 171 lbs/ac/yr = 7,487 ac

Weakfish: 127,463 lbs/yr / 29 lbs/ac/yr = 4,395 ac

Spot: 252,869 lbs/yr / 45 lbs/ac/yr = 5,619 ac

White perch: 62,350 lbs/yr / 50 lbs/ac/yr = 1,247 ac

Step 8: Use the acreage for the species requiring the maximum as the total area to be restored, which in this example is 7,487 acres.

The resulting estimate of the amount of replacement habitat needed to offset entrainment losses was not used directly to determine the scale of restoration, but it did form the basis for settlement negotiations that ultimately determined what restoration would be implemented, taking into consideration cost and the availability of suitable restoration sites.

a. Information provided in a October 16, 2003 memorandum to Liz Strange and Dave Mills of Stratus Consulting by Bruce Freeman of the New Jersey Di vision of Fish and Wildlife, Trenton, New Jersey (Freeman, 2003). Information is also in the Salem 1999 permit application (PSE&G, 1999). b. Conversion efficiency refers to the production of pr edator per unit of production of prey (i.e., production transferred from one trophic level to the other).29 Table 6. Estimates from the published literatu re of rates of secondary production in coastal habitats (in grams dry weight per square meter per year, g dw m -2 yr -1 )

g dw m -2 yr -1 Location Source

9.4 Estuary, Upper Newport Bay, CA Allen (1982)

8.6 Coastal Lagoon, Mexico Warburton (197 9) as cited by Allen et al. (2006)

8.4 Restored Salt Marsh, NJ Teo and Able (2003)

1.6 Great Sippewissett Marsh, MA Valiela et al. (1977) a

7.4-8.0 Marsh, Goodwin Islands, VA Cicchetti (1998) b

8.1 Marsh Creek, DE Meredith and Lotrich (1979) c

4.2-4.6 Marsh Creek, VA Weinstein and Walters (1981), Weinstein (1983)

0.3-7.5 Marsh Creek, NC Currin et al. (1984)

Sources: based on Table 5-9 in Allen et al. (2006) and Table 5 in Strange et al. (2002).

a. Corrected for arithmetic errors in original. b. Estimate is for nekton (fish a nd shrimp) for 150 days, corrected for poorly sampled smaller size classes. c. Wet weights converted to dry weights using a conversion factor of 0.25.

Data sources for scaling metrics and data gaps

Data needed for these scaling metrics incl ude size-frequency data , length and weight measurements for a sample of individuals, and repeated sampling events . ETM studies provide much of this information, including data for multiple sampling events (e.g., Tenera, 2000a, 2000b, 2001; MBC Applied Environmental Scien ces and Tenera Envi ronmental, 2005):

` Abundance of larvae by size class
` Lengths and weights of larvae
` Average age of larvae (estimated using ot olith techniques or from average length by dividing the difference between the averag e and minimum lengths by a daily larval growth rate from the scientific literature).

3.5.3 Restoration monitoring and adaptive management

Even using the best methods and data avai lable for estimating a nnual production rates, uncertainties will remain that can be addressed with ongoing monitoring and adaptive management of restoration actions (Hilborn, 1987; Julius, 1999). In general, there is a lack of data to estimate potential year-to-year variabi lity in fish abundances and production rates. There
is also little information on how production rates may differ in restored compared to unaltered habitats, or how rates may vary over the time horizon of a particular restoration action. Restoration monitoring focused on collecting the data needed to estimate annual rates of production will help fill cr itical data gaps for measuring the success of fish restoration actions.30 3.5.4 Guidelines for restoration scaling

Guidelines for developing more scientifically rigorous and reliable restoration scaling include the following:

` Base scaling on fish produc tivity not standing stock

` If such information is not available in the sc ientific literature or existing larval sampling data, develop a first-order appr oximation of the scale restora tion using a method such as a P:B ratio (Kneib, 2003) or tr ophic modeling (e.g., PSE&G, 1999), and then conduct field studies of the replacement habitat to measure actual rates of growth and survival of the species and life stages of concern

` Based on monitoring results, conduct adaptive management of restoration actions to
rescale restoration as needed.

3.5.5 Recommended elements of a restoration proposal

Restoration proposals shoul d include the following:

` Definition of restoration goals , including identification of the nexus between loss and gain (e.g., losses of larvae from entrainment and gains in habitat needed to produce equivalent larvae)

` Estimates of anticipated restor ation gains and the basis for estimates (e.g., estimated fish production per acre per year)

` Estimated time before ecological benefits will accrue

` Anticipated duration of ecological benefits

` Performance standards (success criteria) for accomplishing rest oration goals and monitoring to ensure performance standards are being met (e.g., actual fish production per acre per year from field sampling)

` Adaptive management process to improve performance as needed

` Clearly substantiated cost estimates.

3.5.6 Scaling alternatives when species are not habitat-limited

When habitat restoration does not offset entrained fish (e.g., for species that are not habitatlimited), restoration can be still scaled based on value equivalence to determine other appropriate trade-offs. For example, VEA can be used to iden tify restoration alternatives of equal value to the public, regardless of their effect on fish pr oduction (Allen et al., 2005a; Lazo et al., 2005).31 

### 3.6 Use of Restoration Costs in Cost-Effectiveness and CostBenefit Analyses

3.6.1 Cost-effectiveness analysis

Understanding the cost to the permit applic ant of implementing technology to reduce impingement and entrainment versus the cost to the public to mitigate losses absent the technology is directly relevant to agency decisions about the cost-effectiveness of various technologies that could be required in an NPDES permit. That is, the cost to the public of enough
habitat restoration to offset en trainment (without an entrainmen t-reducing technology) may be of a similar magnitude as the cost to the permit applicant to install an entrainment-reducing technology. If so, then there is considerable agency justificat ion to require the technology, additional to the statutory requirement to insta ll BTA. EPA has successfully argued this point as part of its justifications for 316(b) technology requirements in the recent Brayton Point, Massachusetts NPDES permit.

Fish replacement costs have also been used at ot her sites to estimate the cost to the public of offsetting impingement and entrainment. However, most estimates of fish replacement costs have been based on the costs of raising and st ocking hatchery fish (AFS, 1993; Southwick and Loftus, 2003). The cost of habitat restoration sufficient to offset entrainment provides an ecologically-based alternative to estimating replacement cost s (Strange et al., 2004b). Although fish stocking has the advantage of quickly rest oring fish that are targ ets of commercial and recreational fishing, hatchery fish are not ecologically equivalent to wild fish and therefore may fail to fully recover a ll lost services (Meffe, 1992; NRC, 1996; White et al., 1997). As the American Fisheries Society (AFS) notes, “Hatchery- raised fish may not be of the same quality in terms of survivability, genetic make-up, or ecolo gical services provided compared to wild fish” (Southwick and Loftus, 2003). As a result, stocking is often rejected as a restoration option in NRDA cases involving fish kills (Reinharz and Burlington, 1996).

The HRC method estimates the cost of restoring habitat to the le vel necessary to offset fish losses through natural production. Natural production ensures that the resulting fish offset fully both ecological and human use services lost because of entrained fish. It is also consistent with the current emphasis on the habitat needed to supp ort self-sustaining fish populations over the long term (NRC, 1996; Myers et al., 2004).

3.6.2 Cost-benefit analyses

For expensive technologies that may be require d in a NPDES permit, applicants and agencies often perform cost-benefit analyses, primarily to ensure that the cost of BTA is not “wholly disproportionate” 7 to its benefits. Although hab itat restoration costs are hi ghly relevant to agency decisions about technology requirements in NPDES permits, restoration costs are not necessarily equivalent to the value of benefits resulting from the restoration. The cost of a natural resource is the sum total of the underlying elem ents required to produce or obt ain the resource. The value of
a natural resource is the maximum amount one is willing to offer in a voluntary exchange for the32 resource, where value can be expressed in eith er ecological or monetary terms (Freeman, 1993; Kopp and Smith, 1993).

Under some circumstances, restoration costs can indicate the value of restoration. For instance, voluntary funding for restoration in the region of the facility could be evidence of economic
demand for those restoration actions. EPA’s Guide lines for Preparing Economic Analyses state that the use of replacement cost as a proxy for value may be justified “...when individuals are proven willing to incur such replacement costs, through either their voluntary purchases or their support for public works projects. If so, the value of the service is at least as much as the replacement cost” (U.S. EPA, 2000, p. 99). Howe ver, even where voluntary restoration has occurred, assumptions about value may require evidence that restorati on decisions were not based on economically inefficient influences, such as agency mandates.

Because restoration costs cannot simply be assu med to equal the value of benefits, additional economic analysis may be needed to determine the relationship between restoration costs and restoration benefits. Unfortunately, analyses by permit applicants have been based on an incomplete accounting of benefits compared to a complete accounting of costs. The potential values of forage fish, the vast majority of entrainment losses, are often omitted altogether. Sometimes the indirect use values of forage fi sh are estimated using simple trophic transfer
models to account for their value as food fo r fishery species (e.g., Bingham et al., 2005). However, there is considerable uncertainty a ssociated with these simple approaches. In particular, results are highly de pendent on the trophic transfer e fficiencies that are used, which can vary substantial among species, locations, and time periods.

No permit applicant, in California or elsewhere, has quantified the nonuse values of forage fish. Nonuse values are the values peop le hold for a resource that are i ndependent of their use of the resource. They include so-called “existence” and “bequest” values, i.e., the values people hold for simply knowing a resource exis ts or for knowing that the res ource will continue to exist for future generations. There are well-established su rvey techniques for evaluating the existence and magnitude of nonuse values, and there is a grow ing literature on the nonuse values for a variety of natural resources (e.g ., Carson et al., 2003).

It is sometimes argued that the nonuse values of forage fishes are unlikely to be significant (e.g., Bingham et al., 2005). However, this is an empirical question that s hould be addressed with research such as stated preference surveys. In fact, EPA conducted a number of focus groups to explore nonuse values for impinged and entrained fish and found that (1) the main motives for reducing impingement and entrainment were exis tence and bequest values (i.e., nonuse values); (2) both users and non-users of the affected resources held these values for reducing impingement and entrainment; and (3) focus group participants agreed that all fish species (including forage fish) play an important role in the affected ecosystems. The focus group results also indicated that the public requires entrainmen t losses expressed in terms of fish (e.g., age one equivalents), not larvae, in or der to express values. The Focu s Group Report provides additional
detail on these and other fi ndings (Besedin et al., 2005).33 

## 4. Conclusions and Recommendations

4.1 Conclusions

Because of the high cost of preventative tec hnologies and the limited options for reducing entrainment, permitting agencies are likely to c ontinue to face difficult decisions about the best way to protect entrainable species. In cases wher e restoration is used to offset unavoidable losses, including losses that remain after implementation of BTA, it is essential to use the
reliable data and methods to estimate the costs and benefits of restorat ion. Unfortunately, most habitat restoration projects, in this and other contexts, are under taken with little understanding of the efficacy of proposed restoration, including th e likely quantity of organisms that will be produced.

Under some circumstances the HPF method can provi de useful information relevant to scaling restoration for entrainment losses. For instance, an HPF can produce a reasonable estimate of the
entrainable larvae within well defined SWAs. Ho wever, the efficacy of the HPF is limited to enclosed or semi-enclosed water bodies, where th e extent of the SWA and larval populations can be reliably determined. For power plants on ope n coasts, where it is extremely difficult to determine the area over which larvae may disp erse, HPF results will have significant, and probably unacceptable, uncertainty. Reducing this uncertainty, requires an understanding of complex coastal hydrodynamics, and the effort and cost do so may not be justified, particularly given the magnitude of uncertain ties that likely would remain.

In addition, the HPF does not relia bly estimate the gain in fish pr oduction that would result from a given habitat restoration. In particular, the HPF equates the ar ea within the SWA containing the standing stock of entrained larvae to the amount of replacement habitat needed to offset entrainment losses. However, restoration scaling requires an estimate of the amount of increase (the rate of change) in fish numbers or bi omass caused by the restoration (either enhanced production or preservation of existing production agai nst foreseeable loss), not an estimate of present standing stock.

Furthermore, HPF estimates do not integrate fish losses and gains through time. The entrainment impact of a power plant is not simply the entrai nment estimated for one year, but rather includes the accumulated losses over all years that the powe r plant operates. Similarly, restoration gains may not reach the anticipated rate of increase d production for several years. Both losses and gains must account for these temporal considerati ons and be expressed in terms of present value equivalents.

Appropriate restoration scaling metrics include species-specific measures of the increase in numbers or biomass of the species and life stages of concern in the restored habitat, quantified in
terms of recruitment , the addition of new recruits to the population per unit area per unit time, or productivity , the rate of fish biomass production per unit area per unit time. These metrics are
also the best measures of restoration success. Therefore, restoration monitoring studies are an important component of productivity estimates that should be require d as part of any restoration required under the terms of an NPDES permit.34 Because estimates of the area to be restored and associated restor ation costs may play a critical role in settlement negotiations, it is imperative that restoration scaling is as rigorous as practical, using or developing the sufficient sc ientific information. If the s cale and costs of restoration are underestimated, permitting conditions may not achieve the goal of resource protection.

Even the most robust scaling techniques currently available include uncertainties that must be accounted for, and any proposal fo r restoration to offset unavoida ble entrainment losses should include a monitoring program to determine actua l rates of fish production. The best way to improve restoration scaling and increase the probab ility of restoration success is to monitor the actual rates of fish production in the replacement habitat. Such monitoring will make it possible to manage the restoration to ensure that the quantity of fish produced will actually offset the entrainment loss. Monitoring will also make it possible to collect data needed to reduce scaling
uncertainties.



### 4.2 Recommendations

` Limit use of the HPF method to estimating the amount of the SWA that is equivalent to
the fraction of the larv al population entrained

` Estimate the HPF for power plants located on bays and estuaries only. Estimates for power plants located on open coasts are curren tly too uncertain and unreliable, even with extensive analysis of larval dispersal and ocean currents

` Scale restoration based on a measure of the eco logical benefits expected to result from a given restoration action

` Use the same metrics for rest oration scaling and monitoring

` Conduct adaptive management of restoration activ ities to ensure that restoration goals are

met

` Design restoration monitoring to collect da ta that can reduce scaling uncertainty.

` When habitat restoration does not offset entrainment losses (e.g., for species that are not habitat-limited), consider using value equivalency to determine appropria te restoration.

` If fish stocking is proposed as a restorati on alternative, require that the facility demonstrate ecological equivalence and the public’s willingness to accept a stocked species in place of the entrained species or in place of the production of wild fish in
natural habitat.35 

### 4.3 Benefits to California

The information provided in this report can be nefit California regulator s, facility operators, environmental stakeholders, and the Energy Co mmission in several ways. Results provide:

` Guidelines for objective, scientifically-bas ed restoration scaling methods to address environmental impacts from power plants and other kinds of facilities, including hydropower facilities and desalination pl ants co-located with power plants

` Scientifically-rigorous rest oration scaling methods, comb ined with ongoing restoration monitoring that will help fill data gaps, w ill greatly increase the likelihood of successful
restoration actions

` Restoration costs based on valid restoration scaling make it possible to compare the costs to permit applicants of implementing technolog y to minimize losses with the costs to the public to mitigate losses absent the technology, which is directly relevant to licensing and permitting decisions about cost-effectiveness.36 

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## Glossary

AFS American Fisheries Society

BMP Best Management Practice BTA best technology available

CCA California Coastal Act
CCC California Coastal Commission CDFG California Department of Fish and Game CEIC California Environmental Information Catalog CEQA California Environmental Quality Act CERPI California Ecological Re storation Projects Inventory CHRPD California Habitat Restoration Project Database CPUE catch per unit effort
CWA Clean Water Act

DCPP Diablo Canyon Power Plant

EPA U.S. Environmental Protection Agency ETM Empirical Transport Model

GIS geographic information system

HBGS Huntington Beach Generating Station HEA habitat equivalency analysis HEP Habitat Enhancement Program HPF habitat production foregone
HRC habitat-based replacement cost

km kilometer

MBPP Morro Bay Power Plant MGD million gallons per day MLPP Moss Landing Power Plant MPA marine protected area MW megawatt

NOAA National Oceanic and At mospheric Administration NPDES National Pollutant Discharge Elimination System NRDA natural resource damage assessment NRPI Natural Resource Projects Inventory46 P:B production:biomass PIER Public Interest Energy Research PM proportional mortality

RD&D Research, Development, and Demonstration REA resource equivalency analysis

SAV submerged aquatic vegetation
SCAR San Clemente Artificial Reef SONGS San Onofre Nuclear Power Generating Station

SWA source water area

VEA value equivalency analysis

WISER Water Intake Structur e Environmental Research47 

## List of Species Scientific Names

Arrow goby ( Clevelandia ios ) Bay goby ( Lepidogobius lepidus ) Black croaker ( Cheilotrema saturnum ) Blackeye goby ( Rhinogobiops nicholsii ) Blue rockfish ( Sebastes mystinus ) Cabezon ( Scorpaenichthys marmoratus ) California halibut ( Paralichthys californicus ) Cheekspot goby ( Ilypnus gilberti ) CIQ gobies – Arrow goby ( Clevelandia ios ), Cheekspot goby ( Ilypnus gilberti ), Shadow goby ( Quietula y-cauda ) Clinid kelpfishes ( Gibbonsia spp.) Combtooth blennies ( Hypsoblennius spp.) Diamond turbot ( Pleuronichthys guttulatus ) KGB rockfishes – Kelp rockfish ( Sebastes atrovirens ), Gopher rockfish ( Sebastes carnatus ), Black-and-yellow rockfish ( Sebastes chrysomelas ) Longjaw mudsucker ( Gillichthys mirabilis ) Monkeyface prickleback ( Cebidichthys violaceus ) Northern anchovy ( Engraulis mordax ) Northern lampfish ( Stenobrachius leucopsarus ) Pacific herring ( Clupea pallasii ) Pacific staghorn sculpin ( Leptocottus armatus ) Painted greenling ( Oxylebius pictus ) Queenfish ( Seriphus politus ) Rock crab ( Cancer spp.) Rockfishes ( Sebastes spp.) Shadow goby ( Quietula y-cauda ) Smoothhead sculpin ( Artedius lateralis ) Snubnose sculpin ( Orthonopias triacis ) Spot ( Leiostomus xanthurus ) Spotfin croaker ( Roncador stearnsii ) Staghorn sculpin ( Leptocottus armatus ) Weakfish ( Cynoscion regalis ) White (sea) perch ( Phanerodon furcatus ) White croaker ( Genyonemus lineatus )48 

## Attachment I. Restoration Ac tions and Restoration Costs

I.2 Restoration Actions for Impinged and Entrained Species

We developed a survey framework to solicit and ev aluate the opinions of California fisheries and aquatic habitat restoration expert s regarding the types of restorat ion actions that could increase the production of specific species. The survey was al so designed to elicit the respondents’ views regarding the relative ability of the different actions to increase the production.

First, this section discusses the criteria that must be met for a given restoration action to increase fish production. Next, we describe the survey de vice developed to elicit the expert opinions, and the motivation for the survey design. Third, we pr ovide a brief description of the reasons each of the habitat restoration options were selected. Finally, we summarize the survey outreach and
solicitation efforts and results.

I.2.1 Conditions needed for habitat restora tion to increase fish production

For an aquatic habitat restorati on project to increase fish prod uction the restored habitat must satisfy at least two critical conditio ns. First, the habitat must play a critical role at some stage in the species life history as either a spawning, nursery, refuge, or forage location. Second, the current combination of the quality and quantity of available habitat must be a limiting factor in the species’ production. When thes e conditions are met, there is a reasonable expectation that the restoration action will increase the species’ production, all else equal.

I.2.2 Survey device for eliciting expert opinion

To evaluate whether it is reasonable to expect that implementing a ha bitat restoration action would increase production of a given species, we surveyed recognized fishery and habitat restoration experts in California . In addition to asking about speci fic habitat restoration actions, we also asked experts to priori tize actions in terms of their relative potential to increase production. To develop this information we deve loped an electronic survey form that allowed respondents to simultaneously indica te whether they believed a habi tat restoration or other action could increase production and to rank those altern atives based on the relative size of the resulting production increases.

Figure I.1 presents an example from the survey form listing the various habitat restoration and other specific actions experts were asked to consider.

Box I.1 below provides a copy of the main set of instructions for completing the survey form.49Alternative actions to increase production of key species entrained by cooling water treatment systems in CaliforniaRank in descending order using 1 for the action you think would provide the greatest increase in production and the last,and largest number, for the action you think is likely to provide the smallest production increase.Leave cells blank if you don’t think the action would increase production.Fishspeciesentrained inCalifornia316bfacilitiesLatinnameRestore orcreatesubmergedaquaticvegetation(SAV)habitatRestoreorcreategiantkelpbedsRestoreor createsaltmarshhabitatRestoreor createestuarineor bayhabitatRestoreorcreatemud flathabitatRestore orcreaterockyintertidalhabitatRestoreorcreatereefhabitatReducecommercialfishingpressureReducerecreationalfishingpressureImprovewaterqualityCreateMarineProtectedAreas(MPAs)Other(1)Other(2)Examplespecies31(bestoption,largestproductionincrease)245(option expectedto provide thesmallestproductionincrease)AmericanshadAlosasapidissimaArrow gobyClevelandiaiosAurorarockfishSebastesauroraBarcheekpipefishSyngnathusexilisFigure I.1. Example from the electronic survey of fisheries and restoration experts on habitat restoration efficacy andpriorities.50 The Example Species row in Figure I.1 indicates how in formation from multiple respondents
could be summarized in terms of the follo wing measures, among other possible options:

` The percentage of respondents who indicated the ha bitat restoration would likely increase the species’ production

` The distribution of responses by habitat restor ation action or other option in terms of a percentage of all responses identifying an option expect ed to increase the species’ production

` A summary of habitat restorati on or other actions that were never identified as having the potential to increase a species’ production.

Collectively, these summary results could be us ed to evaluate whether a consensus habitat
restoration action could be identified for a single species or group of species.

Box I.1. Respondent instructions for co mpleting habitat restoration survey.

The goal of this exercise is to record your personal opinion with respect to the types of habitat enhancement activities or other actions that could increase the production of the listed species and to prioritize those actions based on your belief as to their relative benefit.

For those species you are familiar with we would appr eciate your providing two types of information.

First, we would like you to think about those actions that could conceivably increase the production of the identified species based on your knowledge of its life history including spawning and nursery habitats and current sources of environmental pressure (e.g., habitat loss, commercial fishing). A number of alternatives are provided in the columns below, along with room for additional actions that you can specify in the appropriate cell of the Other (1) and Other (2) columns.

Second, we would like you to rank those actions that you think could increase production of a species by numbering the alternative actions. The numbering will only indicate your views of the relative merits of the alternatives. Number 1 will indicate the option you believe would provide the greatest increase in production, and the largest number will indicate the least effective action.

In the example provided (see the Example Species row), we assume there are five actions that could increase the species production. Of these, salt marsh restoration is the action we assume will provide the greatest production increase for this species. In contrast, we assume quality improvements are likely to increase production, but by the smallest amount from among the available options. Options that are not numbered reflect a belief that their implementation will not increase species’ production.51 I.2.3 Review of the habitat restoration alternat ives and other options presented in the expert survey

We developed the list of restoration alternativ es for the survey using a number of sources, including:

` A review of critical habitats identified for California marine fishes (Montrose Settlements Restoration Program, 20 05; Allen et al., 2006).

` References to the habitat restoration as bei ng beneficial for fish or providing important habitat for fish species (e.g., Montrose Settlements Restoratio n Program, 2005; NOAA, 2007).

` Information indicating the habi tat restoration projects or similar actions were being proposed/implemented in California or other areas with a stated goal of projects being implemented in California or elsewhere w ith the goal of improving fish production or fish stocks in general. In the rest of this section the specific habita t restoration projects.

` A review of the habitat rest oration actions being implemen ted as part of the 316b permit agreement for the San Onofre Nuclear Po wer Generating Station (SONGS; Southern California Edison, 2007).

` Summaries of proposed restoration projects in HPF analyses for select California power plants, e.g., Moss Landing (Table 3 and accompanying text by Dr. Pete Raimondi, University of California at Santa Cruz, in St range et al., 2004a, based on data in Tenera, 2000b, Morro Bay (CCRWQCB, 2004), Diablo (Raimondi et al., 2005); Huntington Beach (Davis et al., 2006b).

These sources helped identify the following speci fic habitat restorati on actions that were included in the expert solicitation survey (see Figure I.1):

` Restore or create SAV habitat
` Restore or create giant kelp beds
` Restore or create salt marsh habitat
` Restore or create estuarine or bay habitat
` Restore or create mud flat habitat
` Restore or create rocky intertidal habitat
` Restore or create reef habitat.

In addition to these options, the expert surv ey included options for reducing commercial or recreational fishing pressure. These options were included because, for some species, reduction in fishing pressures could reduce mortality of spawning females and increase larval supply. For example, a commercial fishing boat buyback pr oject was developed and implemented in the northeast groundfish fishery in an attempt to reduce the mortality pressure from commercial fishing on certain groundfish stoc ks (Kitts and Thunberg, 1998).52 Improving water quality was included in the surv ey in an effort to gauge the perceived importance of water quality as a limiting factor on species production. In most situations, it will not be possible to link and quan tify a particular water quality im provement with increased water quality and increased production of a specific species. However, in some circumstances (e.g., for small water bodies where impaired water quality is the only or primary stressor and affected populations can be defined) it ma y be possible to estab lish these links, at l east in a qualitative

way.

The establishment of marine protected areas (MPAs) was id entified as another possible
alternative for incr easing production of entrained species. Th is option is based on the goals of the California Marine Life Protection Act of 2002, which called for the designation and integrated management of a statewide network of MPAs. Am ong the explicit goals of the MPAs is to “help sustain, conserve, and protect marine life populations, including those of economic value, and
rebuild those that are de pleted” (CDFG, 2007). This goal is cons istent with efforts to increase production of fish species. Conceptually, MPAs are intended to provide a defined refuge area where, within the boundaries of the MPA, fish will be free from commer cial and recreational fishing pressure. If this relief improves spawni ng success and fecundity by allowing females to mature to later life stages, the MPAs may increase overall production. However there are a number of questions concerning the efficacy of MPAs, and their relatively recent adoption means there is currently a limited and inconclusive body of associat ed research to address this question. Finally, the Other (1) and Other (2) options in the survey were included to provide respondents to identify any additional actions they felt should be identified because of their potential to increase species production.

I.2.4 Survey outreach and solicitation efforts

To conduct the survey, we initially contacted individuals with expe rtise in Californi a fisheries or experience with implementing aqua tic habitat restoration projects at a number of agencies and institutions. The organizations thes e individuals represent included:

` California Coastal Conservancy
` California Department of Fish and Game (CDFG)
` Moss Landing Marine Laboratories
` NOAA ` U.S. Fish and Wildlife Service.

These organizations and their staff provide the op portunity to gather information from across the

state.

I.2.5 Results of efforts to identify and prioritize habitat restoration efforts for specific species

Issues with the timing of the survey developmen t and the extensive nature of the information requested have limited responses received to date despite overa ll interest and expressions of willingness to participate in the research. As a result, our current summary of matching potential53 habitat restoration actions to sp ecific species relies on a summary of the literature that provides indications of species preferences for specific habitats or a relianc e on specific habitats at certain life stages. The results of this summary for are pres ented in Figure I.2 for al l species that we have record of having been entrained at a California cooling water in take structures based on past facility studies.

The results in Figure I.2 carry a number of caveats. First, becaus e the results are drawn from a literature review it was not possi ble to develop the relative weighting information that the electronic survey can capture. Further, the li sting of species provide s no indication of the frequency of their entrainment at either a specif ic facility or across facilities in California. Therefore, it is not possible to draw conclusions about the share of the ov erall entrainment loss at California Cooling Water Intake Structures that is covered by the information in this table.



### I.3 Restoration Costs

An aquatic habitat restoration pr oject’s cost estimate should provide a comprehensive summary of all of the elements that will be required to achieve the project’s stated objectives. When available, comprehensive cost estimates can be combined with similarly detailed cost summaries for completed habitat restoration pr ojects to generate a wide range of useful cost information for those considering similar actions (e.g., costs pe r unit of habitat restored, ranges of specific unit costs). However, prospective users of this information face a number of challenges in determining whether available project cost information is truly comprehensive.

This section has two goals. First, to clearly define the elements of a comprehensive cost estimate, along with an approach to help evaluate wh ether available project cost information is comprehensive. Second, the section provides a summary of restoration cost databases for projects that have been proposed or complete d in California. Finally, we provide some conclusions regarding combining cost information from multiple restoration projects.

I.3.1 Overview of a comprehensive cost estimate/summary

A comprehensive cost estimate will include all of the anticipated costs to design, implement, and monitor a project. While available cost information will vary across projects, reflecting differences in the combination of specific activ ities and reporting requi rements, most cost information is organized in terms of a combina tion of specific types of actions. Elements and
activities whose costs sh ould be included are:

1. Habitat acquisition or access

2. Project design, evaluation, and permitting

3. Implementation, including labor, equipment and supplies

4. Allowance for contingencies 8

5. Operations and maintenance

6. Monitoring

7. Oversight and administration.54KeyA.Result developed from the information in the reportAES Huntington Beach L.L.C. Generating StationEntrainment and Impingement Study: Final Report(MBC Applied Environmental Sciences and Tenera Environmental, 2005).E.Result developed from the information inThe Ecology of Marine Fishes(Allen et al., 2006).P.Results initially presented in the 2004 PIER Final Project ReportResearch on Estimating the Environmental Benefits of Restoration to Mitigate or AvoidEnvironmental Impacts Caused by California Power Plant Cooling Water Intake Structures(Strange et al., 2004a) based on responses from area biologists.S.Result developed from the information in the reportSan Diego Bay Integrated Natural Resources Management Plan(Port of San Diego, 2007).Fish speciesfrequently entrainedat Californiapower plantsRestoreor createSAV habitatRestoreorcreategiantkelpbedsRestoreorcreatesaltmarshhabitatRestoreorcreatemud flathabitatRestore orcreaterockyintertidalhabitatRestoreorcreatereefhabitatReducecommercialfishingpressureaReducerecreationalfishingpressureaImprovewaterqualityaCreateMarineProtectedAreas(MPAs)aOther (1)Bay goby1, 6, 7E, P P E, P E, P P P P PBlackeye goby1, 6, 7P E, P P P P E, P P PBlennies E, P P E, P E, P A, E, P, S A, E, P,SPCheekspot goby1, 6, 7E, P P E, P E, P P P P PDrums5, 6, 7P P P P PGiant kelpfish2, 6S E, S E, SNorthern anchovy A, E A, E A, E P P P S (open water)Queenfish2E (surf zone, pelagic)A (open water, soft bottom 10m-70m)S (demersal unconsolidatedsediment)Rockfish (Blue, Gopher,Grass, Kelp)6, 7E, P E, P E, P P P PSmoothhead sculpin3, 6, 7E E P P (hatchery)Spotted kelpfish2, 6E E S (unconsolidated sediment)Striped kelpfish2, 6, 7E EAction Notesa. These actions were not assessed for their relationship to specific species in The Ecology of Marine Fishes, the AES Huntington Beach report, or the SanDiego Bay Integrated Natural Resources Management Plan.Species Notes1. Results from the 2004 PIER report reflect responses for“Gobies”and were not distinguished by species.2. Species not addressed in the 2004 PIER report.3. Results from the 2004 PIER report reflect responses for “Sculpins” and were not distinguished by species.4. Results from the 2004 PIER report reflect responses for “Drums croakers” and were not distinguished by species.5. Species not addressed inThe Ecology of Marine Fishes.6. Species not addressed in The AES Huntington Beach report.7. Species not addressed in theSan Diego Bay Integrated Natural Resources Management Plan.Figure I.2. Indications of habitat requirementsand potentially beneficial habitat restoration actions for select species fromavailable literature.55 Collectively, the above list of co st categories accounts fo r all phases of a restoration project from the design phase through actual implementation and long-term maintenance and monitoring to ensure project performance. Each of thes e cost categories is discussed below.

` Habitat acquisition or access: At a minimum, a restorati on project proponent needs to demonstrate legal control or approved access to a site to undertake habitat restoration activities. Acquiring direct ownership of the habitat (e.g., through a fee-simple purchase) is the most direct and certain expression of th is control. Other options for achieving this control can include obtaining a conservation easement, lease arrangements, or unsecured access guarantees with a willing project sponsor with access to the habitat. The costs for obtaining the habitat and securing access are, for many categories of habitat restoration projects, likely to represent a significant porti on of total expenses and the associated cost needs to be clearly identified in a cost estimate/summary.

` Design and permitting: Most habitat restoration projects will require some sort of permit or regulatory review proce ss prior to implementation (e.g., CEQA review). Both the project and the permitting process are also likel y to require construction, engineering, and or detailed implementation sequencing plan s. Depending on the location, type, and complexity of the project, these costs can be significant. If detailed estimates cannot be developed, these costs can still be accounted for with either a lump sum estimate or an estimate based on a percentage of other id entified costs (e.g., 20% of anticipated construction costs).

` Implementation: This cost element should summarize all costs associat ed with labor, equipment, and materials required for the proj ect. These costs should also incorporate any expenses associated with mobilization and demobilization required to bring equipment and material to a project site or to provide actual site access during the active restoration phase of the project.

` Allowance for contingencies: An allowance for contingencies should be specifically
accounted for. This cost reflects the belief th at project proponents should always count on the unexpected and prepare for such a con tingency with extra funding. Contingencies often are applied as a percentage of total pr oject costs. The percentage may increase as a function of any combination of factors, such as project complexity and duration; use of relatively new techniques, equipment, or mate rials; and number of project partners and required degree of coordination. Guidance on developing contingency allocations is provided in a number of cost estimating references (e.g., U.S. ACE and U.S. EPA, 2000).

` Operations and maintenance: Most habitat restoration proj ects require some level of ongoing effort to ensure antic ipated benefits are reali zed. For some projects these expenses can represent a significant share of lif etime project costs and may be critical to the project’s success (e.g., dredging a waterway to maintain tidal exchange). Because these expenditures are incurred following the “completion” of mo st of the initial restoration work and may require a separate so urce of funding they shou ld be specifically and separately accounted for in a cost estimate.56 ` Monitoring: Monitoring activities may be a critical element of adaptive management of a project and will generally be required to doc ument, qualitatively and/or quantitatively, project performance. Because these expenditures will occur in future periods after project “completion,” and may require separate f unding, they should be specifically and separately accounted for in a cost estimate.

` Oversight and administration: The project proponent canno t effectively implement a habitat restoration project w ithout providing some level of oversight and administration. The resources in terms of labor and any supplies that are required as part of this effort
need to be accounted for.

The value of this cost categoriza tion approach is that key elements of cost estimates are explicit, which helps ensure that all costs are accounted for. A full accounting of costs is critical to project

success.

I.3.2 Evaluating cost estimates for habitat restoration projects

To ensure that all cost elements are included in a cost estimate for a given project, a number of key questions should be addressed:

` Is the project narrative consistent with the available cost information?

Relevance: If the cost estimate is inconsistent w ith the project narrative, it is likely to underestimate true project costs. For example, if a project descripti on notes the need for significant habitat re-grading or re-contouring the cost estimate s hould include costs for actions and equipment consistent with this activity (e.g., soil excavation and/or removal).

` Are donated or discounted goods and/or services accounted for in the cost information?

Relevance: In many cost estimates there is no acc ounting of goods and services that were donated or provided at discount. This is required for an accurate reflection of the actual resource commitments required to achieve the project outcomes. Failing to account for these donated goods or services would result in an underestim ate of cost if simila r discounts or donations cannot be obtained for other projects. For ex ample, many kelp and sub-aquatic vegetation restoration projects rely on scuba divers to harvest and transplant the relevant vegetation. This labor is critical to project im plementation, and is often donated by individuals or organizations (e.g., dive clubs). In developing a comprehensive cost estimate, the fair market value of such
volunteer services should be included.

` Do the available costs reflect only the f unding commitment from one project partner?

Relevance: Many habitat restoration projects are undertaken as cooperative efforts by combinations of public agencies (e.g., CDFG, NOAA) and private indivi duals and organizations. This can create a situation where project summ aries describe the full range of restoration
activities but the cost s reflect only the funding commitment from the partner providing the information. Where this occurs, cost estimat es will understate the ac tual project costs.57 ` Have prior expenditures and resource commit ments associated with habitat acquisitionaccess and project permitting and design been accounted for?

Relevance: Costs and resource commitments associated with habitat acquisition-access and project permitting and design can represent a sign ificant share of the to tal anticipated/realized costs for a restoration project. At the same time, these expenses and resource commitments may be incurred well in advance of the final project implementation. As a result, these costs may be omitted from cost estimates that address remaining actions or summaries that start from the point of physical work to restore the habitat. Failure to account for these prior period expenditures will result in an artificially low project cost estimate.

` Have anticipated future operations and ma intenance expenditures and monitoring costs
been accounted for?

Relevance: Because these expenditures will be incurred in the future, after the restoration project has been “completed,” they may be omitted from some project cost estimates. This omission will understate the true project costs and, in some cases, may omit consideration of costs that are crucial for ongoing project success and the ability of the project to meet stated goals. This issue could also arise if there is an anticipated tran sfer of property rights fo llowing the initial project completion that would involve these future costs be ing borne by an agency or organization that is not part of the project implementation team.

` Does the cost estimate incorporate contingency costs?

Relevance: Incorporating funding to account for unexpect ed events or issues is a well-recognized element of developing a realistic cost estimat e. Provision for contingencies may represent a significant portion of the total cost estimate, especially for more complex projects. A cost summary associated with detailed construction plans that specify quantities of materials and labor, with associated unit costs, may omit a line item for contingencies as all costs are already incurred. Project cost estimates that do not incorporate conti ngency funding in the total will understate anticipated costs compared to a comprehensive cost estimate.

` Are costs for project administra tion and oversight accounted for?

Relevance: The costs associated with the labor and a ny associated goods and services required to administer and oversee a project’s development a nd implementation need to be accounted for to avoid understating true project costs. However, these costs are frequen tly omitted, especially when existing personnel from public agencies pr ovide these services. In these cases, a common view is that these staff are just completing part of their recogni zed job assignment. The importance of accounting for these resources is clear, though, when considering the costs associate with private compared to public sector projects.58 ` Do project costs involve non-ha bitat related expenditures or expenses notable because they are unlikely to be frequently encountered?

It is commonly the case that a project narrativ e provides some descriptio n of project goals and implementation activities, but only provides a simplified cost estimate , such as “the project will
restore X acres of habitat for Y dollars.” In such cases it will be difficult, if not impossible, to assess the completeness of the cost estimate without developing additional information.

The most effective means of addressing omitted cost s from the list above is to contact the current project manager. Often these discussions will clar ify what is not included in the initial cost estimate. Having identified the omission, additional information can be elicited from the project manager, either actual cost estimates or approaches for developing estimates.

I.3.3 Sources of California aquatic habi tat restoration project summaries

Table I.1 provides a summary of databases that contain information for proposed and completed
nearshore habitat restorati on projects in California.

As noted in Table I.1, several of these database s provide cost informati on or include a specific
field where cost information can be included. In general, these cost summaries present values
with little documentation or lis ting of sources. Therefore, we recommend that, in general, all such cost estimates be treated as likely underestimat es of true project costs until more detail is obtained. These inventories genera lly provide contact information that should facilitate the next step of contacting a knowledgeable project ma nager to help better unde rstand the completeness of the cost information presented. For projects of interest that lack cost estimates the project contact information can be used to begin efforts to develop this information.

An additional benefit of these databases is that they can be used to help identify potential restoration projects in a specific area or individua ls in an area that may be familiar with certain types of habitat restoration proj ects. Such individuals may also suggest additional information

sources.

I.3.4 Combining cost information from multiple restoration projects

There is often interest in knowi ng what an “average” cost for rest oring a unit (e.g., an acre) of degraded habitat may be. Extreme caution should be used in developing and applying such
estimates.59Table I.1. Summary of identified aquatic habitat restoration project databases for CaliforniaDatabasenameInternet location(home)General description Information available NotesCaliforniaEnvironmentalInformationCatalog (CEIC)http://gis.ca.gov/catalog/Allows users to designqueries to obtain links to datasources and collections ofinterest.CEIC summary form includes thefollowing fields among others:TitleAbstractTime periodPurposeDate updatedData contactLinks can take you directly tomore detailed information fromthe listed organizationTo access the query options for natural resource datasetsfrom the homepage do the following:1. SelectBy Resource Typein the options forLook forDataon the left of the page.2. At next page selectBy Keywordin theLook for Dataliston the left.3. At next page selectNatural Resources. Search termoptions for types of natural resources that are presentedinclude:Aquatic resourcesEnergy resourcesFishery resourcesForest resourcesGenetic resourcesMineral resourcesNatural resource managementNonrenewable natural resourcesRangelandsRecreationRenewable natural resourcesSoilsWater resourcesWildlife resources.4. Click on resource of interest and additional resourcedescriptors may appear to help refine a query to returnlinks to datasets of interest.Notable project links include access to the projects in theSan Francisco Joint Venture Project Database.60Table I.1. Summary of identified aquatic habitat restoration project databases for California (cont.)DatabasenameInternet location(home)General description Information available NotesCaliforniaEcologicalRestorationProjectsInventory(CERPI) –NaturalResourceProjectsInventory(NRPI)http://www.ice.ucdavis.edu/nrpi/Provides a searchabledatabase with links to over6,000 natural resource-relatedprojects in California.Database has links toinformation in the CEIC,Geofinder, California DigitalAtlas, and Google Maps.Detailed project summary formsfrom database searches provideinformation on the followingareas among others:Project namePurposeAbstractTime periodFunding sources and amountPurposeProject size and methodsDate updatedData contactSearchable field categories presented to the user on the NRPIhomepage include:TitlePurposeAbstractFunding programContact personParticipantProject dateProject typeCountyResource issueWater quality constituentsHabitatSpeciesBest Management Practices (BMPs) photosControl methodMultiple field query (full text search).Drop down lists and follow-up questions, depending on fieldselected, are used to help refine the project search. Examplesof habitat descriptors potentially relevant to 316b restorationproposals includeEstuarine, Marine, Saline EmergentWetland.The response to searches generally provides a text notedescribing the project purpose and a link to a more detailedproject summary.61Table I.1. Summary of identified aquatic habitat restoration project databases for California (cont.)DatabasenameInternet location(home)General description Information available NotesCALFED:EcosystemRestorationProgramProjectDatabasehttp://www.delta.dfg.ca.gov/erpin/dbase_default.aspSeeNotesfield. SeeNotesfield.Website currently under construction. CALFED projectinformation can also be generated using the EcosystemRestoration Program Project Locator found athttp://www.delta.dfg.ca.gov/erpin/displaymap.asp. Thisallows for queries to select types of projects that are thenmapped with information that can be accessed by clicking onmap icons that are generated for the project.62Table I.1. Summary of identified aquatic habitat restoration project databases for California (cont.)DatabasenameInternet location(home)General description Information available NotesCaliforniaHabitatRestorationProjectDatabase(CHRPD)http://www.calfish.org/DesktopDefault.aspx“The CHRPD currentlycontains data from theCDFG’s FisheriesRestoration Grants Program,the CALFED EcosystemRestoration Program, theNational Fish and WildlifeFoundation, the StateCoastal Conservancy, theNOAA Restoration Center,the U.S. Fish and WildlifeService, the CaliforniaConservation Corps, and theCantara Trustee Council.”Quote from the CalFishwebsite text that comes upafter clicking on theRestoration Projectslink onthe left side of thehomepage.The CalFish website describes thefollowing information being availablefrom the CHRPD:General project types included in theCHRPDHabitat improvementWatershed assessment and planningWatershed organization supportMonitoringLand and water right acquisitionEducationHatchery projectsData categoriesData source(s)Project timeframeProject descriptionLimiting factors addressed by the projectParticipants (including role and financialcontribution)Funding sourcesProject costsSite-specific data:Site locationLand coverRestoration goalsTreatment details and quantitiesPost-project monitoringLand ownershipProject performance measuresSpecies affectedFinal analysis and final reportReferencesRequires using a mapping tool that is accessed byclicking on the link on the left side of the homepageforFish Mapsin the section labeledFish Data andMaps.63Table I.1. Summary of identified aquatic habitat restoration project databases for California (cont.)DatabasenameInternet location(home)General description Information available NotesNationalEstuariesRestorationInventoryhttps://neri.noaa.gov/index.htmProvides a listing of habitatrestoration projects invarious estuarine habitats bylocation around the UnitedStates. Search parameterscan be defined to narrow thelist of projects that arereturned.In the most detailed project summary, thefollowing information is available:Detailed project description and summaryProject contact informationSummary of the habitat types and acreagerestoredProject benefitsProject partnersProject fundingTo search the inventory, first click on theSearch theInventorylink on the homepage. The links under theBasic Searchheading on the page to search forprojects (https://neri.noaa.gov/query_main.html) canbe used to search for relevant projects by location,which provides a search by state option, or byhabitat type which pulls up a page with a drop downmenu of habitat types to choose from. If the searchfor projects is made by habitat type the resulting listcan be sorted by state by clicking on theStateheaderin the table that is returned.Clicking on the project name in the table that isreturned moves the user to a more detailed summarythat initially presents an expanded project blurb anda summary of the project type, cost, contacts andproject partners. Clicking on the link at the bottomof this summary forFull Reporttakes the user to themost detailed project summary available.Bay AreaWetlandTrackerhttp://www.wetlandtracker.org/Provides a listing of wetlandrestoration projects in Northand South San FranciscoBay.Accessing the links for the listed projectsprovides a more detailed summary withthe following information:LatitudeLongitudeMapped project areaReported project areaProject type (e.g., restoration)CountiesLand ownerProject contactsLinks to additional filesFrom the homepage, click on the link labeledList allprojectson the top right of the page to pull up all theidentified projects. Clicking on the name of anyproject will open a more detailed summary withinformation beyond the Name, Status, and Total areaprovided in the list.64Table I.1. Summary of identified aquatic habitat restoration project databases for California (cont.)DatabasenameInternet location(home)General description Information available NotesSouthernCaliforniaWetlandsRecoveryProjecthttp://www.scwrp.org/work_plan.htmIn the more detailed summaries projectinformation includes:Date of last project updateProject leads and contactsProject DescriptionEstimated costSummary of fundingThe Wetlands Recovery Project providesinformation on ongoing and completed projects atvarious levels of detail. To access a short textsummary of completed projects click on the link forProject Descriptionsunder the section header forCompleted Projectson the left side of the homepage.For a summary of ongoing projects click on the linkforWork Plan Project Descriptionson the left of thepage in the section titledOverview.For a more detailed summary of projects click onthe link for WRP Information Stationon the left sideof the homepage in the section titledRelated Items.At the next page click on the link for Current andCompleted Projectson the left of the page. In theresulting drop down menu the names of the projectsin the combined completed and ongoing projectdatabases appear.The Wetlands Recovery Project focuses on projectsbetween the U.S. Mexican border in the south toPoint Conception in the north.65 Specifically, cost estimates from multiple projec ts should be combined only when the values reflect comprehensive estimates that, if appropria te, have been adjusted (i.e., discounted) to account for future expenditures. When combining cost estimates to develop summary measures care must also be taken in how the summary measur e is calculated. For example, an average cost per acre of tidal wetland restor ation can be calculated by dividing the sum of all estimated costs by the sum of all acres to be restored in the sele ct project groups. Alternatively, an average cost for each project could be initiall y calculated and then an averag e of the results be calculated. Only in rare cases (i.e., when each project has the same average cost) will the results be the same. In addition, the range of unique opportuniti es, constraints, and requirements that are reflected in comprehensive cost estimates should produce a wide range of “average” costs across restoration projects focused on a specific habi tat with a large enough sa mple. This variability should highlight the sensitivity of restoration cost s to site-specific elements that can only be adequately accounted for when considering a potential project by conducting an initial assessment of the site. Finally, project propone nts should realize cost estimates are only one component of determining cost effectiveness. In the case of restora tion projects focused on improving the production of fish information on exp ected increases in pro duction as a result of the project implementation is needed to calcu late accurate measures of a project’s cost
effectiveness.66 1. The ETM method described in Steinbeck et al. (2007) is based on a model originally developed by Boreman et al. (1978, 1981) for Hudson River entrainment studies and later modified by MacCall et al. (1983) for power plants located on estuaries and open coasts. A similar model was developed by Barnthouse et al. (1979) to address impingement. Because local biologists consider California impingement losses to be insignificant, the HPF only
evaluates entrainment losses.

2. This approach can be modified by first calculating the area of a particular type of habitat in a SWA (e.g., rocky reefs based on aerial photos that identify kelp beds as for the HPF for the Diablo Canyon power plant).

3. The HEP used what it described as a HEA analysis, but in many important respects it was incorrectly designed and implemented, invalidating the HEA results.

4. In southern California, there is a history of restoring co astal wetlands or artificial reef s as mitigation for losses of soft-bottom species (Davis et al., 2006b).

5. Note that in a document on the DCPP Bingham and Desvousges (2005) incorrectly referred to the HPF as the HRC. Bingham and Desvousges (2005) also incorrectly st ated that the EPA rejected the HRC. In fact, EPA’s
comments on the HRC in Response to Public Comment on 316(b) regulations (U.S. EPA, 2004b) clarified that HRC estimates of restoration costs are not benefits estimates. HRC costs are, however, relevant for cost-effectiveness analyses.

6. Note that it is important to use location-specific data for a trophic modeling approach . For example, estimates of primary production for Spartina marshes on the U.S. East Coast may differ, perhaps significantly, from those for
Salicornia marshes on the Pacific Coast.

7. “Wholly disproportionate” was the phrase used in hear ings for the Seabrook, New Hampshire facility to define a
limit on reasonable BTA costs.

8. Contingency costs are unlikely to appear in a costs summary for completed projects.