Economic and Benefits Analysis of 

the Final Vessel General Permit (VGP) 

Developed for: 

Office of Wastewater Management 

U.S. Environmental Protection Agency 

By: 

Abt Associates Inc. 

55 Wheeler Street 

Cambridge, MA 02138 

(617) 492-7100 

December 18, 2008 

Economic and Benefits Analysis of the Final Vessel General Permit 

1 Acknowledgments 

This study was performed under EPA’s contract No. EP-C-07-023. 

List of Preparers: 

Dr. Elena Besedin1

 

Isabelle Morin1

Lauren Tikusis1

Nathan Frey1

Edward Comerford1

 

Dominick Tribone1

Dr. Ryan Albert2 

Christopher L. Moore2

Paul Balserak3

Dr. Sabrina Lovell3

1 Abt Associates 

2 United States Environmental Protection Agency, Office of Water 

3 United States Environmental Protection Agency, Office of Policy, Economics, and Innovation 

EPA would like to thank the United States Coast Guard for its assistance in compiling data on ballast water for 

this report. 

December 18, 2008 Final i
Economic and Benefits Analysis of the Final Vessel General Permit 

Table of Contents 

1 Acknowledgments........................................................................................................................................... i

List of Tables........................................................................................................................................................... vi

Acronyms................................................................................................................................................................. ix

Executive Summary ................................................................................................................................................ xi

2 Introduction ................................................................................................................................................... 1

2.1 Background...................................................................................................................................................... 1

2.2 Organization within the Analysis.................................................................................................................... 2

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

3.1 Domestic Vessel Population............................................................................................................................ 3

3.2 Foreign Vessel Population............................................................................................................................... 5

3.3 Vessels Subject to the Ballast Water Management Requirements.................................................................. 6

3.4 Uncertainties and Limitations.......................................................................................................................... 7

4 Permit Overlap with Existing Regulations.................................................................................................. 8

4.1 Ballast Water and Invasive Species Management........................................................................................... 8

4.2 Graywater ...................................................................................................................................................... 10

4.3 Anti-fouling Hull Coatings............................................................................................................................ 11

4.4 Bilgewater Discharges................................................................................................................................... 11

4.5 Overlap with Existing Clean Water Act Provisions...................................................................................... 11

4.6 Issues and Uncertainties ................................................................................................................................ 12

5 Profile of the Water Transportation, Fishing, and Mining Industries................................................... 13

5.1 Introduction ................................................................................................................................................... 13

5.1.1 Data Sources Used............................................................................................................................ 13

5.1.2 Organization of This Chapter........................................................................................................... 14

5.2 Overview of the Water Transportation, Fishing, and Mining Industries....................................................... 14

5.2.1 Definition of the Water Transportation, Fishing, and Mining Industries......................................... 14

5.2.2 Water Transportation........................................................................................................................ 15

5.2.3 Fishing .............................................................................................................................................. 18

5.2.4 Mining .............................................................................................................................................. 18

5.2.5 Number of Water Transport Vessels by Industry Sector.................................................................. 19

5.3 Recent Trends................................................................................................................................................ 20

5.3.1 Number of Vessels by Industry Sector............................................................................................. 20

December 18, 2008 Final ii
Economic and Benefits Analysis of the Final Vessel General Permit 

5.3.2 Number of Establishments by Industry Sector................................................................................. 21

5.3.3 Establishment and Employment Births and Deaths ......................................................................... 22

5.3.4 Financial Performance...................................................................................................................... 24

5.4 Industry Market Structure.............................................................................................................................. 25

5.4.1 Firms and Revenues ......................................................................................................................... 25

5.4.2 Small Businesses.............................................................................................................................. 27

5.4.3 Employment and Payroll.................................................................................................................. 28

6 Cost of Best Management Practices........................................................................................................... 32

6.1 Summary ....................................................................................................................................................... 32

6.2 Cost of Individual BMPs............................................................................................................................... 32

6.2.1 Discharges of Deck Washdown and Runoff and Above Water Line Hull Cleaning........................ 33

6.2.2 Discharges of Bilgewater ................................................................................................................. 37

6.2.3 Discharges of Ballast Water – Pacific Nearshore Vessels................................................................ 39

6.2.4 Discharges of Ballast Water – Vessels with Empty Tanks............................................................... 45

6.2.5 Anti-fouling Hull Coatings............................................................................................................... 48

6.2.6 Aqueous Film-Forming Foam.......................................................................................................... 49

6.2.7 Boiler/Economizer Blowdown ......................................................................................................... 53

6.2.8 Cathodic Protection .......................................................................................................................... 54

6.2.9 Chain Locker Effluent...................................................................................................................... 56

6.2.10 Controllable Pitch Propeller and Thruster Hydraulic Fluid and other Oil Sea Interfaces including 

Lubrication discharges from Paddle Wheel Propulsion, Stern Tubes, Thruster Bearings, Stabilizers, 

Rudder Bearings, Azimuth Thrusters, Propulsion Pod Lubrication, and Wire Rope and Mechanical 

Equipment Subject to Immersion ..................................................................................................... 59

6.2.11 Distillation and Reverse Osmosis Brine........................................................................................... 62

6.2.12 Elevator Pit Effluent......................................................................................................................... 62

6.2.13 Firemain Systems............................................................................................................................. 63

6.2.14 Freshwater Layup ............................................................................................................................. 64

6.2.15 Gas Turbine Wash Water ................................................................................................................. 64

6.2.16 Graywater......................................................................................................................................... 65

6.2.17 Motor Gasoline and Compensating Discharge................................................................................. 66

6.2.18 Non-Oily Machinery Wastewater..................................................................................................... 67

6.2.19 Refrigeration and Air Condensate Discharge................................................................................... 67

6.2.20 Seawater Cooling Overboard Discharge (including non-contact engine cooling water; hydraulic 

system cooling water, refrigeration cooling water).......................................................................... 68

6.2.21 Seawater Piping Biofouling Prevention ........................................................................................... 68

December 18, 2008 Final iii
Economic and Benefits Analysis of the Final Vessel General Permit 

6.2.22 Boat Engine Wet Exhaust................................................................................................................. 69

6.2.23 Sonar Dome Discharge..................................................................................................................... 69

6.2.24 Underwater Ship Husbandry Discharges.......................................................................................... 70

6.2.25 Welldeck Discharges........................................................................................................................ 71

6.2.26 Graywater Mixed with Sewage from Vessels .................................................................................. 72

6.2.27 Exhaust Gas Scrubber Washwater Discharge................................................................................... 72

6.3 Per-Vessel Costs for Vessel-Specific Requirements..................................................................................... 73

6.3.1 Large and Medium Cruise Ships ...................................................................................................... 73

6.3.2 Large Ferries..................................................................................................................................... 79

6.3.3 Barges (such as hopper barges, chemical barges, tank barges, fuel barges, crane barges, dry bulk 

cargo barges) .................................................................................................................................... 81

6.3.4 Oil Tankers or Petroleum Tankers.................................................................................................... 82

6.3.5 Research Vessels.............................................................................................................................. 83

6.3.6 Emergency Vessels (Fire Boats, Police Boats)................................................................................. 84

6.3.7 Vessels Employing Ballast Water Treatment Systems..................................................................... 85

6.3.8 Cost Estimates for Other Requirements ........................................................................................... 89

6.3.9 Uncertainties and Limitations........................................................................................................... 89

6.4 Permit Paperwork Burden ............................................................................................................................. 89

6.5 Analysis of Total National Costs................................................................................................................... 93

7 Analysis of Impacts on Firm Revenues and Financial Performance ...................................................... 96

7.1 Methodology.................................................................................................................................................. 96

7.1.1 Assign Each Vessel to a NAICS Code ............................................................................................. 96

7.1.2 Estimate the Number of Vessels per Firm........................................................................................ 97

7.1.3 Estimate the Distribution of Costs per Vessel.................................................................................. 97

7.1.4 Compare Costs to Revenues........................................................................................................... 100

7.2 Small Entity Analysis.................................................................................................................................. 100

7.3 Issues and Uncertainties .............................................................................................................................. 108

8 Benefits Analysis........................................................................................................................................ 109

8.1 Ballast Water Exchange and Invasive Species Impacts .............................................................................. 109

8.1.1 Introduction and Background ......................................................................................................... 109

8.1.2 ANS Impacts .................................................................................................................................. 110

8.1.3 Efficacy of Ballast Water Exchange and Saltwater Flushing......................................................... 114

8.1.4 Benefits of Reducing ANS Introductions....................................................................................... 115

8.2 Benefits of Reduced Pollutant Discharges from Vessels ............................................................................ 117

December 18, 2008 Final iv
Economic and Benefits Analysis of the Final Vessel General Permit 

8.2.1 Introduction and Background......................................................................................................... 117

8.2.2 Pollutants Commonly Found in Vessel Discharges ....................................................................... 117

8.2.3 Pollutant Impacts............................................................................................................................ 120

8.2.4 Benefits of Reducing Pollutant Discharges.................................................................................... 123

References............................................................................................................................................................. 126

Appendix A: Survey Questionnaires.................................................................................................................. 137

Individual BMP Survey ......................................................................................................................................... 137

Cruise Ship Survey ................................................................................................................................................ 149

Appendix B: Summary of Survey Responses.................................................................................................... 156

Individual BMP Survey ......................................................................................................................................... 156

Cruise Ship Survey ................................................................................................................................................ 163

 

December 18, 2008 Final v
Economic and Benefits Analysis of the Final Vessel General Permit 

List of Tables 

Table 3-1: Domestic Vessel Population.....................................................................................................................4

Table 3-2: Foreign Vessel Population........................................................................................................................6

Table 3-3: Oceangoing Arrivals.................................................................................................................................6

Table 3-4: Pacific Nearshore Arrivals .......................................................................................................................7

Table 4-1: Summary Crosswalk between Current Ballast Requirements and EPA Permit Requirements................9

Table 4-2: Summary Crosswalk between Current Cruise Ship Requirements and EPA Permit Requirements ......11

Table 5-1: Relevant 2002 NAICS Codes and Descriptions.....................................................................................14

Table 5-2: Number of Vessels and Operators by Industry Sector, 2005..................................................................19

Table 5-3: Number of Vessels in the WTLUS Database, 2001-2005......................................................................21

Table 5-4: Number of Establishments by Industry Sector, 1997 and 2002 .............................................................22

Table 5-5: Establishment Births and Deaths, Five-Year Annual Average: 1998–2003 ..........................................23

Table 5-6: Net Change in Employment: Five-Year Annual Average, 1998-2003...................................................23

Table 5-7: Revenues by Industry Sector, 1997 and 2002 ........................................................................................24

Table 5-8: Firms and Revenues by Employment Size, 2002 ...................................................................................26

Table 5-9: Number of Firms According to Revenue Size........................................................................................27

Table 5-10: Small Businesses by Industry Sector....................................................................................................28

Table 5-11: Employment by Industry Sector, 1997-2002........................................................................................29

Table 5-12: Payroll by Industry Sector, 1997-2002.................................................................................................30

Table 6-1: Vessel Counts for BMPs Applicable to Deck Runoff............................................................................34

Table 6-2: Per-Vessel Costs for BMPs Associated with Deck Runoff....................................................................35

Table 6-3: Deck Runoff Sensitivity Analysis ..........................................................................................................36

Table 6-4: Unit Cost Inputs for Ballast Water Practices - Pacific Nearshore Vessels.............................................41

Table 6-5: Annual Maintenance Cost Estimates for Pacific Nearshore Vessels......................................................42

Table 6-6: Summary of Costs of Ballast Water Exchanges for Vessels Engaged in Pacific Nearshore Voyages: 

Domestic Flag ..................................................................................................................................................43

Table 6-7: Summary of Costs of Ballast Water Exchanges for Vessels Engaged in Pacific Nearshore Voyages: 

Foreign Flag.....................................................................................................................................................44

Table 6-8: Unit Cost Inputs for Ballast Water Practices – Vessels with Empty Ballast Tanks...............................46

Table 6-9: Summary of Costs of Saltwater Flushing for Oceangoing Vessels with Ballast Tanks Empty: Domestic 

Flag ..................................................................................................................................................................47

Table 6-10: Summary of Costs of Saltwater Flushing for Oceangoing Vessels with Ballast Tanks Empty: Foreign 

Flag ..................................................................................................................................................................48

Table 6-11: Vessel Counts for AFFF BMPs............................................................................................................50

December 18, 2008 Final vi
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 6-12: Per-Vessel Costs for BMPs Associated with AFFF ............................................................................. 51

Table 6-13: Aqueous Film-Forming Foam Sensitivity Analysis............................................................................. 53

Table 6-14: Vessel Counts for Cathodic Protectiona BMPs..................................................................................... 54

Table 6-15: Cathodic Protection Installation Cost Estimates .................................................................................. 55

Table 6-16: Cathodic Protection Sensitivity Analysis, Purchase of a Cathodic Protection System ........................ 56

Table 6-17: Vessel Counts for Chain Locker Effluent BMPs.................................................................................. 57

Table 6-18: Per Vessel Costs for BMPs Associated with Chain Locker Effluent ................................................... 58

Table 6-19: Chain Locker Effluent Sensitivity Analysis, Wash Down Anchor Chain............................................ 58

Table 6-20: Vessel Counts for Controllable Pitch Propeller Hydraulic Fluid BMPs .............................................. 59

Table 6-21: Per-Vessel Costs for BMPs Associated with Controllable Pitch Propeller Hydraulic Fluid................ 60

Table 6-22: Controllable Pitch Propeller Hydraulic Fluid Sensitivity Analysis...................................................... 61

Table 6-23: Vessel Counts for Elevator Pit Effluent BMPs .................................................................................... 62

Table 6-24: Vessel Counts for Firemain Systems BMPs......................................................................................... 63

Table 6-25: Vessel Counts for Graywater BMPs..................................................................................................... 65

Table 6-26: Vessel Counts for Underwater Ship Husbandry BMPs........................................................................ 70

Table 6-27: Cruise Ship Counts............................................................................................................................... 73

Table 6-28: Cruise Ship Costs Associated with the Purchase/Operation and Maintenance of a Graywater 

Treatment Systema

........................................................................................................................................... 77

Table 6-29: Cruise Ship Costs Associated with Sampling....................................................................................... 78

Table 6-30: Cruise Ship Costs Associated with Pool and Spa Water Bromine Testing .......................................... 79

Table 6-31: Vessel Counts for BMPs Associated with River Barges...................................................................... 81

Table 6-32: Vessel Counts for BMPs Associated with Oil or Petroleum Tankers.................................................. 82

Table 6-33: Vessel Counts for BMPs Associated with Research Vessels............................................................... 83

Table 6-34: Vessel Counts for BMPs Associated with Vessels Employing Experimental Ballast Water Treatment 

Systems............................................................................................................................................................ 85

Table 6-35: WET Testing/Water Quality Sampling Analysis for Vessels Employing Experimental Ballast Water 

Treatment Systems........................................................................................................................................... 89

Table 6-36: Vessel Class Breakdown ...................................................................................................................... 90

Table 6-37: Recordkeeping Burden ......................................................................................................................... 90

Table 6-38: NOI Burden .......................................................................................................................................... 91

Table 6-39: Routine Inspection Burden................................................................................................................... 91

Table 6-40: Drydock Inspection Burden.................................................................................................................. 92

Table 6-41: Annual Inspection Burden.................................................................................................................... 92

Table 6-42: One-Time Report Burden..................................................................................................................... 93

Table 6-43: Total Annual Compliance Costs for All BMPs by Vessel Type .......................................................... 93

December 18, 2008 Final vii
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 6-44: Total Annual Incremental Cost for Cruise Ships..................................................................................94

Table 6-45: WET Testing/Water Quality Sampling Analysis for Vessels Employing Experimental Ballast Water 

Treatment Systems...........................................................................................................................................94

Table 6-46: Total Permit Recordkeeping Burden Cost............................................................................................94

Table 6-47: Total Annual Incremental Cost.............................................................................................................95

Table 7-1: Estimated Median, 5th, 95th, and 99th Percentile Firm Costs by NAICS Code .....................................101

Table 7-2: Results of the Small Entity Impact Analysis........................................................................................106

Table 8-1: Estimates of Invasive Species in Several Major Water Systems..........................................................110

Table 8-2: Estimates of Invasive Species Damages by Type of Species...............................................................111

Table 8-3: Pollutants Found in Vessel Dischargesa ...............................................................................................118

Table 8-4: Types of Pollutants Found in Graywater Discharges...........................................................................119

Table 8-5: Impairment Status of the Top 20 Ports by Annual Vessel Calls ..........................................................123

Table 8-6: Potential Daily Reduction in Loadings of Pollutants from Graywater Discharges by a Large Cruise 

Ship in U.S. Territorial Waters......................................................................................................................124

Table 8-7: Benefits of Reducing Pollutants Found in Vessel Discharges..............................................................125

Survey Responses Regarding Labor Ratesa ...........................................................................................................156

Survey Responses Regarding Deck Runoff...........................................................................................................157

Survey Responses Regarding AFFF ......................................................................................................................158

Survey Responses Regarding Graywater...............................................................................................................158

Survey Responses Regarding Underwater Hull Husbandry ..................................................................................159

Survey Responses Regarding Cathodic Protection................................................................................................159

Survey Responses Regarding Chain Locker Effluent............................................................................................160

Survey Responses Regarding Controllable Pitch Propeller Hydraulic Fluid.........................................................161

Survey Responses Regarding Elevator Pit Effluent...............................................................................................161

Survey Responses Regarding Firemain Discharges...............................................................................................162

Survey Responses Regarding Cruise Ships ...........................................................................................................163

December 18, 2008 Final viii
Economic and Benefits Analysis of the Final Vessel General Permit 

Acronyms 

ACSI Alaska Cruise Ship Initiative 

ADEC Alaska Department of Environmental Conservation 

AFFF Aqueous film-forming foam 

AMSA Australian Maritime Safety Authority 

ANS Aquatic non-indigenous species 

ANSTF Aquatic Nuisance Species Task Force 

APPS Act to Prevent Pollution from Ships 

BMP Best management practice 

BOD Biochemical oxygen demand 

CCC Criterion Continuous Concentration 

CDC Centers for Disease Control 

CLIA Cruise Line International Association 

CMC Criterion Maximum Concentration 

COTP Captain of the Port 

CPI Consumer Price Index 

CWA Clean Water Act 

DOD Department of Defense 

EEZ Exclusive Economic Zone 

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act 

GESAMP Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection 

GLERL Great Lakes Environmental Research Laboratory 

GSMFC Gulf States Marine Fisheries Commission 

IADC International Association of Drilling Contractors 

ICCP Impressed Current Cathodic Protection 

ICST International Classification of Ships by Type 

IDNR Indiana Department of Natural Resources 

IMO International Maritime Organization 

ISA Infectious salmon anemia 

MARPOL International Convention for the Prevention of Marine Pollution from Ships 

MISLE Marine Information for Safety and Law Enforcement 

MODU Mobile Offshore Drilling Unit 

NAICS North American Industry Classification System 

NANCPA Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990 

NBIC National Ballast Information Clearinghouse 

NDC Navigation Data Center 

NISA National Invasive Species Act 

NMFS National Marine Fisheries Service 

NOAA National Oceanic and Atmospheric Administration 

NoBOB No ballast on board 

NOI Notice of Intent 

NPDES National Pollutant Discharge Elimination System 

NRDC National Resources Defense Council 

NRWQC National recommended water quality criteria 

OTA Office of Technology Assessment 

PAH Polycyclic aromatic hydrocarbon 

December 18, 2008 Final ix
Economic and Benefits Analysis of the Final Vessel General Permit 

PFOA Perfluorooctanoic acid 

PFOS Perfluorooctane sulfonate 

POC Pollutant of concern 

RFA Regulatory Flexibility Act 

RO-RO Roll-on/roll-off 

RTF Ruffe Task Force 

SAB Science Advisory Board 

SBA Small Business Administration 

SBAC Small Business Advocacy Chair 

SBREFA Small Business Regulatory Enforcement and Fairness Act 

SIC Standard Industrial Classification 

TBT Tributyl tin 

USACE U.S. Army Corps of Engineers 

USCG U.S. Coast Guard 

USDA U.S. Department of Agriculture 

USDOI U.S. Department of the Interior 

USGS U.S. Geological Survey 

VDS Vessel Documentation System 

VESDOC Merchant Vessels of the United States 

VHS Viral hemorrhagic septicemia 

VTCC Vessel Type, Construction, and Characteristics 

WCSC Waterborne Commerce Statistics Center 

WHOI Woods Hole Oceanographic Institute 

WTLUS Waterborne Transportation Lines of the United States 

December 18, 2008 Final x
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final xi

Executive Summary 

EPA developed new permitting requirements for discharges incidental to the normal operation of a vessel into 

inland waters or the territorial sea of the United States under the National Pollutant Discharge Elimination System 

(NPDES). 

This report presents EPA’s final economic and benefits analysis of the Vessel General Permit’s impact on all 

affected vessels. Though the issuance of this Permit is not a Federal regulation, EPA is conducting this analysis 

due to the potential impacts of this Permit. The Executive Summary provides an overview of the costs and 

benefits of the regulation. 

The Vessel General Permit for Discharges Incidental to the Normal Operation of Vessels (herein referred to as the 

Vessel General Permit or VGP) covers, with the exception of ballast water discharges, non-recreational vessels 

less than 79 feet in length, including uninspected passenger vessels less than 79 feet in length, and all commercial 

fishing vessels, regardless of length.1

 The Vessel General Permit defines effluent limits for 26 discharge 

categories as well as specifying certain practices and discharges for various vessel categories. 

All vessels operating in a capacity of transportation are eligible for coverage under the Vessel General Permit. 

The types of vessels covered under the Vessel General Permit include commercial fishing vessels (only for ballast 

water requirements), cruise ships, ferries, barges, mobile offshore drilling units (MODUs), oil tankers or 

petroleum tankers, bulk carriers, cargo ships, container ships, other cargo freighters, refrigerant ships, government 

vessels not a part of the armed forces (e.g. NOAA and USACE vessels), research vessels, and emergency 

response vessels, including firefighting and police vessels, and any other vessel operating in a capacity of 

transportation. Vessels of the armed forces of the United States are not eligible for coverage by this Permit. EPA 

estimates that 61,069 domestic flag and 7,927 foreign flag vessels will be affected by the final VGP 

requirements.2

 Chapter 3 of this report, Population of Affected Vessels, presents EPA’s assessment of the numbers 

and types of vessels likely to be impacted by the new permitting requirements. 

Water transportation accounts for a majority of the vessels sailing on U.S. waters and thus affected by VGP. The 

water transportation industry is a $34 billion industry that employs nearly 150,000 people on a payroll of just over 

$6 billion. Overall, the industry has experienced mild growth in the number of establishments, revenues, and 

payroll, but a decline in the number of employees. The fishing industry is responsible for slightly more than a 

quarter of all commercial vessels in the United States. This industry is much smaller, with total revenues of $1.65 

billion, employing just over 6,500 people on a payroll of $253 million. The fishing industry is experiencing more 

of a decline, although it still shows some revenue growth despite declines in the number of establishments and 

employees, and in total payroll. The drilling oil and gas wells sector, a subset of the mining industry (which 

includes the 131 MODUs covered under the VGP), is a $9 billion sector that employs nearly 60,500 people on a 

payroll of approximately $2.5 billion. This sector has experienced relatively strong growth, demonstrating a 

24 percent increase in revenues from 1997 to 2002. On the whole, the three industries contain more than 90 

percent small businesses. Of the 5,037 firms in the water transportation industry, 4,770 (94.3 percent) are small. 

 

1

 Commercial fishing vessels and other non-recreational vessels less than 79 feet may seek permit coverage under this permit for their 

ballast water discharges. If auxiliary vessels or craft, such as lifeboats or rescue boats onboard larger vessels require permit coverage (i.e. 

they are greater than 79 feet in length or they are subject to the current NPDES permit moratorium under S. 3298 but are required to obtain 

an NPDES permit following lapse of that moratorium), they are eligible for coverage under this permit and are covered by submission of 

the Notice of Intent for larger vessels. Recreational vessels as defined in section 502(25) of the Clean Water Act are not subject to this 

permit. Such vessels are not subject to NPDES permitting under Section 402 of the Clean Water Act, and are instead subject to regulation 

under Section 312(o) of the Clean Water Act. 

2

 Due to congressional action that took place during July 2008 (Senate bill S. 2766 and 3298, described in Section 2.1), the estimated vessel 

universe covered by the final VGP decreased from the proposed VGP (and subsequently decreased in the final VGP economic analysis). 
Economic and Benefits Analysis of the Final Vessel General Permit 

In the fishing industry, 1,843 (96.2 percent) of the 1,916 firms are small. In the drilling oil and gas wells sector, 

1,470 (97.7 percent) of the 1,504 firms are small. Chapter 5: Profile of the Water Transportation, Fishing, and 

Mining Industries provides an economic profile of these industries. Though the overwhelming majority of fishing 

vessels need not obtain coverage under the VGP, the profile of the fishing industry remains in this analysis to 

account for potential expenses for the limited number of fishing vessels (as defined in 33 CFR 1342) which may 

need to obtain coverage for ballast water under this permit. 

To estimate the effect of the Permit on an industry as a whole, EPA’s analysis takes into account previous 

conditions and determines how the industry would act in the future in the absence of the Permit. The baseline for 

this analysis is full industry compliance with existing federal and state regulations; and current industry practices 

or standards that exceed current regulations to the extent that they can be empirically observed. In addition, a 

number of laws and associated regulations (including the National Invasive Species Act; the Act to Prevent 

Pollution from Ships; the Comprehensive Environmental Response, Compensation, and Liability Act; the 

Organotin Anti-fouling Paint Control Act; and others) already cover certain discharges that would be subject to 

the new permitting regime. In analyzing economic impacts of the vessel vacatur of the NPDES requirements, 

EPA has assumed that the entities subject to existing regulations will not incur significant incremental costs. 

Chapter 4, Permit Overlap with Existing Regulations, summarizes laws and associated regulations that already 

cover certain discharges that would be subject to the new permitting regime. 

Overall, EPA finds that the Permit has modest economic impacts on the water transportation, fishing, and mining 

industries. The total annual incremental costs for both domestic and foreign vessels range from $8.9 to 

$23 million annually (2007$). This includes the paperwork burden costs and the sum of the ballast water 

management costs, the costs of all other BMPs, the costs to cruise ships, and (for the high end estimate) the cost 

to vessels expected to employ ballast water treatment systems which discharge biocides of monitoring for residual 

biocides or derivatives. The estimated total costs to domestic vessels of the paperwork burden (including 

recordkeeping, Notice of Intent (NOI) filing, routine inspections, drydock inspections, annual inspections, and a 

one-time report) range from $0.6 to $4.5 million. The estimated VGP compliance costs (excluding paperwork 

costs and $1.1 million for ballast water practices for foreign vessels) range from $7.2 to $17.4 million (2007$). 

Chapter 6: Cost of Best Management Practices presents EPA’s analysis of compliance costs to commercial 

vessels associated with each of the BMPs identified and the paperwork burden costs. 

To evaluate economic impacts of VGP requirements on the water transportation, fishing, and mining industries, 

EPA performed the firm-level analysis. The firm-level analysis examines the impact of the introduced BMP costs 

per vessel on model firms that represent the financial conditions of “typical” businesses in each of the examined 

industry sectors. Since more than 90 percent of the firms in the water transportation and fishing industries, and in 

the drilling oil and gas wells segment of the mining industry are small, it is unlikely that firm-level impacts would 

be material among large firms in this industry. Therefore, a firm-level analysis focuses on assessment of impacts 

on small businesses, as required by the Regulatory Flexibility Act and the Small Business Regulatory 

Enforcement and Fairness Act (SBREFA). To evaluate the potential impact of the Vessel General Permit on small 

entities, EPA used a cost-to-revenue test to evaluate the potential severity of economic impact on vessels and 

facilities owned by small entities. The test calculates annualized pre-tax compliance cost as a percentage of total 

revenues and uses a threshold of 1 and 3 percent to identify facilities that would be significantly impacted as a 

result of this Permit. 

The firm-level analysis shows that the “rule is presumed not to have a significant economic impact on a 

substantial number of small entities.” The total number of small entities in the fishing industry that are expected to 

exceed the 1 percent cost-to-revenue threshold is 3 (or 0.01 percent) under the low end and high end cost 

assumptions. The total number of small entities in the water transportation industry sectors that are expected to 

exceed the 1 percent cost-to-revenue threshold is 209 under the low end cost assumptions and 304 under the high 

end cost assumptions. Finally, one small entity in the drilling oil and gas wells sector is expected to exceed the 1 

percent cost-to-revenue threshold under both the low end and high end cost assumptions. Chapter 7 Analysis of 

December 18, 2008 Final xii
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final xiii

Impacts on Firm Revenues and Financial Performance details EPA’s assessment of the cost and economic impact 

of regulatory requirements on firms in the shipping industry, and the implications of the Permit in terms of 

financial viability of shipping industry firms subject to the Permit. 

Although EPA was unable to evaluate the expected benefits of the Permit in dollar terms due to data limitations, 

the Agency collected and developed relevant information to enable qualitative consideration of ecological benefits 

and to assess the importance of the ecological gains from the Permit. EPA expects that reductions in vessel 

discharges will benefit society in two broad categories: (1) enhanced water quality from reduced pollutant 

discharges and (2) reduced risk of invasive species introduction. 

The Permit covers many discharges and contains special provisions for numerous vessel types (see EPA (2008b) 

for information on the affected discharges and provisions by vessel type). Many of the discharges regulated by 

EPA’s Vessel General Permit (2008b) were previously regulated under only certain select circumstances covering 

a small fraction of total discharges, if at all. Nonetheless, several discharges are associated with a wide variety of 

harmful pollutants in substantial concentrations. For example, untreated graywater may contain pathogenic 

bacteria, toxic and carcinogenic organic and inorganic compounds, nutrients, and metals (EPA, 2007a). Because 

many of the nation’s busiest ports are considered to be impaired by a variety of pollutants found in vessel 

discharges, the Permit is expected to have benefits associated with the reduction of concentrations of nutrients, 

metals, oil, grease, and toxics in waters with high levels of vessel traffic. These impacts will be particularly 

significant in those nutrient-impaired areas frequented by cruise ships (e.g., San Francisco Bay and Chesapeake 

Bay), which can discharge large volumes of graywater and are subject to stringent discharge requirements under 

the Permit. 

The ballast water provisions of EPA’s final Vessel General Permit are expected to reduce the number of 

introductions of aquatic non-indigenous species (ANS) and thus may prevent significant future damages to 

fisheries, tourism, recreation, infrastructure, and human health, as well as further stresses on native biodiversity 

and ecosystems. Although estimating the monetary value of benefits from preventing future invasions with a 

reasonable degree of certainty would not be possible due to the lack of data on rates of invasive species 

introduction associated with ballast water releases, the type of species introduced in the future and the range of 

potential economic impacts associated with each species type is very large. The potential benefits of preventing 

the introduction of even one harmful ANS could be substantial. 

Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 1

2 Introduction 

2.1 Background 

On June 17, 2008, EPA proposed new permitting requirements for discharges incidental to the normal operation 

of a vessel into inland waters or the 3 mile territorial sea of the United States under the National Pollutant 

Discharge Elimination System (NPDES) (73 CFR 117). 

On July 29, 2008, Senate bill S. 2766 (“the Clean Boating Act of 2008”) was signed into law (P.L. No. 110-288). 

This law provides that recreational vessels shall not be subject to the requirement to obtain an NPDES permit to 

authorize discharges incidental to their normal operation. It instead directs EPA to evaluate recreational vessel 

discharges, develop management practices for appropriate discharges, and promulgate performance standards for 

those management practices. It then directs the Coast Guard to promulgate regulations for the use of the 

management practices developed by EPA and requires recreational boater compliance with such practices. On 

July 31, 2008, Senate bill S. 3298 was signed into law (P.L. No. 110-299). This law generally imposes a two-year 

moratorium during which time neither EPA nor states can require NPDES permits for discharges incidental to the 

normal operation of vessels of less than 79 feet and commercial fishing vessels of any length. It also directs EPA 

to conduct a study of vessel discharges and issue a report to Congress within 15 months. Among other things, the 

moratorium does not apply to ballast water. EPA has incorporated the permitting requirements into the existing 

NPDES framework. 

The Vessel General Permit for Discharges Incidental to the Normal Operation of Non-Recreational Vessels 

(herein referred to as the Vessel General Permit or VGP) covers non-recreational vessels at least 79 feet long.3

 To 

obtain authorization under the Vessel General Permit: 

3⁄4 Vessel operators must meet the Vessel General Permit eligibility requirements. 

3⁄4 Operators of some vessels will have to submit NOIs. If a vessel weighs at least 300 gross tons or has the 

capacity to discharge more than 8 cubic meters of ballast water, the operator must submit a complete and 

accurate NOI. For operators required to submit NOIs, submission must meet specified submission 

deadlines. If the vessel is not in one of the aforementioned categories, it automatically receives permit 

coverage under the Vessel General Permit and is authorized to discharge in accordance with Permit 

conditions. 

3⁄4 Vessel operators must implement the effluent limits according to the requirements in Part 2 of the Vessel 

General Permit, and document the implementation as part of their recordkeeping documentation. If the 

vessel is equipped to carry ballast water or carries ballast water at any time, it must have a ballast water 

management plan consistent with part 33 CFR 151.2035(a)(7). 

Based on an analysis of several vessel data sources (described in Section 3), EPA estimated the population of 

vessels affected by the NPDES requirements. The total count of the domestic flag vessel population is 61,069.4

The foreign flag vessel population totals 7,927. 

The Vessel General Permit defines effluent limits for 26 discharge categories and specifies certain practices for 

various vessel categories. This report presents EPA’s economic and benefits analyses of the Vessel General 

Permit’s impact on all affected vessels. Though the issuance of this permit is not a Federal regulation, EPA is 

conducting these analyses due to the potential impacts of this permit. These analyses are consistent with the 

 

3

 The descriptions of permitting requirements in this report are based upon the December 17, 2008 Draft Permit provided by EPA. 

4

 This count includes 26 commercial fishing vessels that have ballast water requirements. Although there are 28,875 commercial fishing 

vessels found in the vessel databases, only 26 perform ballast water exchange or flushing. 
Economic and Benefits Analysis of the Final Vessel General Permit 

Regulatory Flexibility Act as amended by the Small Business Regulatory Enforcement Fairness Act of 1996 

(RFA/SBREFA). 

2.2 Organization within the Analysis 

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

Chapter 3: Population of Affected Vessels presents an assessment of the numbers and types of vessels likely to be 

affected by the new permitting requirements. 

Chapter 4: Permit Overlap with Existing Regulations summarizes laws and associated regulations that already 

cover certain discharges that would be subject to the new permitting regime. 

Chapter 5: Profile of the Water Transportation, Fishing, and Mining Industries provides an economic profile of 

the sectors that have vessels subject to the VGP. 

Chapter 6: Cost of Best Management Practices presents EPA’s analysis of compliance costs to commercial 

vessels associated with each of the BMPs identified by EPA in the Permit at the vessel level. This chapter also 

presents an estimation of national-level industry compliance costs. 

Chapter 7: Analysis of Impacts on Firm Revenues and Financial Performance presents EPA’s assessment of the 

cost and economic impact of regulatory requirements on firms in the shipping industry, and the implications of a 

Permit in terms of financial viability of shipping industry firms subject to the Permit. 

Chapter 8: Benefits Analysis presents EPA’s assessment of the environmental effects associated with vessel 

discharges and the benefits of reducing these discharges. 

Appendix A presents the questionnaires sent to the industry representatives. 

Appendix B presents a summary of responses from the industry questionnaires. 

December 18, 2008 Final 2
Economic and Benefits Analysis of the Final Vessel General Permit 

3 Population of Affected Vessels 

The Vessel General Permit is applicable to discharges incidental to the normal operation of a vessel into the 

navigable waters within the meaning of the Clean Water Act (CWA) Section 502(7). All vessels operating in a 

capacity of transportation are eligible for coverage under the Vessel General Permit. The types of vessels covered 

under the Vessel General Permit include commercial fishing vessels (only for ballast water exchange 

requirements), cruise ships, ferries, barges, mobile offshore drilling units, oil tankers or petroleum tankers, bulk 

carriers, cargo ships, container ships, other cargo freighters, refrigerant ships, research vessels, emergency 

response vessels, including firefighting and police vessels, and any other vessel operating in a capacity of 

transportation. Vessels of the armed forces of the United States are not eligible for coverage by this permit. 

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

3⁄4 Domestic flag vessels: The Waterborne Transportation Lines of the United States (WTLUS) and 

Merchant Vessels of the United States (VESDOC) databases provided information on the number and 

type of domestic flag vessels subject to the Vessel General Permit. 

3⁄4 Foreign flag vessels: The Foreign Vessel Traffic Entrance and Clearance records of U.S. Customs and 

Border Protection provided information on the number and type of foreign flag vessels operating in the 

navigable waters of the United States. 

3⁄4 Vessels subject to ballast water management requirements: The National Ballast Information 

Clearinghouse (NBIC) provided data on U.S. port calls, traffic patterns, ballast capacity, whether a vessel 

declared ballast water on board, and whether ballast water exchange was performed. 

In addition, the Cruise Line International Association (CLIA) provided information on the number and size of 

cruise ships operating in U.S. waters. 

3.1 Domestic Vessel Population 

EPA used three data sources to determine the population of domestic flag vessels: (1) the WTLUS data file 

compiled by the Waterborne Commerce Statistics Center (WCSC) of the U.S. Army Corps of Engineers 

(USACE) Navigation Data Center (NDC) (USACE, 2005a, 2005b, and 2005c), (2) the VESDOC data file 

compiled by the U.S. Coast Guard (USCG, 2007), and (3) information submitted from the International 

Association of Drilling Contractors (IADC), which provided a vessel count of 131 MODUs. 

WTLUS is a three-volume annual product that provides both an inventory of vessel companies, along with their 

American flag vessels operating in the transportation of freight and passengers, and a national summary of all 

vessels. The database lists the vessel companies in alphabetical sequence and provides each vessel’s name and 

number; Coast Guard number; net tonnage; Vessel Type, Construction, and Characteristics (VTCC) code and 

International Classification of Ships by Type (ICST) code; register and overall length and breadth; loaded and 

light draft; horsepower; carrying capacity in short tons or units of cargo and number of passengers; height of fixed 

superstructures; cargo handling equipment; operating headquarters; and year built or rebuilt. Detailed vessel 

characteristics may not be available for all vessels included in the total WTLUS vessel inventory (USACE NDC, 

2008). The data files for the WTLUS vessel characteristics and operator names were downloaded directly from 

the USACE NDC website on December 5, 2007, and loaded into a Microsoft® Access file (USACE NDC, 2007). 

The data cover vessels available for operation as of December 31, 2005. 

VESDOC is a data file of merchant and recreational vessels documented under the laws of the United States by 

the U.S. Coast Guard. The source for this file is the U.S. Coast Guard’s Marine Information for Safety and Law 

Enforcement (MISLE) and Vessel Documentation System (VDS) databases, a comprehensive system serving 

December 18, 2008 Final 3
Economic and Benefits Analysis of the Final Vessel General Permit 

many Coast Guard marine safety units, including the National Vessel Documentation Center. The data file of 

merchant vessels has been specifically prepared from several data tables contained in MISLE and VDS. Vessel 

specific data include vessel name, call sign, official number (Coast Guard number), International Maritime 

Organization (IMO) number, hull number, vessel service type, flag, self-propelled indicator, registered gross and 

net tons, length, breadth, depth, measuring organization name, hailing port and state, numerous trade indicators, 

vessel builder and managing owner information, horsepower, propulsion type, and hull construction material and 

configuration. Vessels in this file have a valid Certificate of Documentation (U.S. Bureau of Transportation 

Statistics, 2008). These data were downloaded from the Bureau of Transportation Statistics’ Maritime Data 

Working Group website as a zipped Access file on November 28, 2007 and extracted the same day (U.S. Bureau 

of Transportation Statistics, 2008). The file contains updated data through July 7, 2007. 

To estimate the domestic vessel population subject to the Vessel General Permit, EPA created a master database 

by combining the WTLUS and VESDOC data files. The combined database allowed the Agency to obtain a 

comprehensive estimate of the vessel population and to minimize the number of missing data fields. The Coast 

Guard number, which serves as the unique vessel identifier, was used to merge the two databases. EPA used the 

WTLUS data as the base of the population and, as a general rule, used the majority of the data fields contained 

therein, inputting similar data attributes from VESDOC into this format. As shown in Table 3-1, the estimated 

number of domestic flag vessels subject to the Vessel General Permit is 61,069. The 131 mobile offshore drilling 

units identified by IADC are included among the population of 10,892 utility vessels. 

Table 3-1: Domestic Vessel Population 

Total Domestic Vessels Domestic Vessels Required to Submit NOIa

Vessel Class Count Percentage of Total Count Percentage of Total 

Commercial Fishing 26b <1 26 <1 

Freight Barge 32,842 54 30,961 74 

Freight Ship 697 1 469 1 

Passenger Vessel 11,521 19 1,270 3 

Tank Barge 4,944 8 4,808 11 

Tank Ship 147 <1 117 <1 

Utility Vessel 10,892 18 4,255 10 

Total 61,069 100 41,906 100 

a The count of vessels required to submit an NOI is a conservative estimate since data on gross tonnage are not complete. 

Thus, this count is based on the number of vessels that are either >78’ in length or >299 Gross Tons. 

b 26 commercial fishing vessels conduct either ballast water exchange or saltwater flushing. 

This analysis will examine the following vessel population groups, defined by USACE WTLUS and USCG 

VESDOC categorizations: 

3⁄4 Commercial Fishing. Includes commercial fishing vessels (only for ballast water exchange requirements). 

3⁄4 Freight Barge. Includes open and covered hopper barges, car floats, flat/deck barges, pontoon barges, 

open and covered dry cargo barges, container barges, lash barges, and convertible barges. 

3⁄4 Freight Ship. Includes general cargo freighters, break bulk carriers, roll-on/roll-off (RO-RO) carriers, 

container ships, partial container ships, and vehicle carriers. 

3⁄4 Passenger Vessel. Includes cruise ships, combination passenger and cargo ships, ferries, railroad car 

ferries, excursion and sightseeing vessels, and passenger barges. 

3⁄4 Tank Ship. Includes petroleum, chemical, and liquid gas carriers, and liquid bulk tankers. 

3⁄4 Tank Barge. Includes liquid cargo barges that are single hull, double hull, double sided only, and double 

bottom only. 

December 18, 2008 Final 4
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 5

3⁄4 Utility Vessel. Includes crew boats, mobile offshore drilling units, offshore supply vessels, industrial 

vessels, oil recovery vessels, research vessels, school ships, push boats, and tug/towing vessels. 

As shown in Table 3-1, freight barges (54 percent), passenger vessels (19 percent), and utility vessels (18 percent) 

account for the majority of domestic vessels eligible for coverage under the VGP. Table 3-1 also provides the 

number of vessels required to provide a Notice of Intent (NOI) to EPA (i.e., vessels weighing at least 300 gross 

tons or that have the capacity to hold or discharge more than 8 cubic meters (2113 gallons) of ballast water). Of 

the 61,069 domestic flagged commercial vessels subject to the Vessel General Permit, 41,906 are required to 

submit a NOI. 

3.2 Foreign Vessel Population 

The Foreign Traffic Vessel Entrances and Clearances database provides information on foreign vessels entering or 

clearing U.S. Customs ports in calendar year 2005 (U.S. Customs and Border Protection, 2007). The data are 

collected by U.S. Customs and Border Protection and include entrance/clearance characteristics such as the date a 

vessel made entry into or cleared the U.S. Customs port or waterway, as well as vessel characteristics such as the 

name, type by rig or ICST code, flag of registry, last (for entrances) or next (for clearances) port of call, whether 

foreign or domestic, Net and Gross Registered Tonnage, and draft in feet. The database includes both foreign 

flagged and domestic vessels. However, only foreign flagged vessels are included in the estimate of the foreign 

vessel population. The estimate of the foreign vessel population also excludes several other Permit-exempt boats.5

EPA estimates that 7,927 foreign flagged vessels are subject to the Vessel General Permit requirements.

EPA used ICST codes to group foreign flagged vessels into the classes used in the analysis of the domestic vessel 

population. (This classification scheme is described in the preceding section.) Table 3-2 presents the number of 

foreign flagged vessels by vessel class. As shown in Table 3-2, the majority of foreign flagged vessels entering 

U.S. ports are freight ships (65 percent), followed by tank ships (22 percent). Of the 7,927 foreign flagged vessels, 

7,830 are required to provide an NOI to EPA (i.e., they weigh at least 300 gross registered tons). 

The foreign flagged vessels were excluded from the analysis of the total costs of best management practices 

(BMPs) because the cost to foreign flagged vessels does not have a direct impact on the U.S. firms. There is also 

considerable uncertainty regarding management practices employed by these vessels under the baseline scenario. 

The only exception is ballast water management, for which sufficient data were available to estimate incremental 

costs of the Vessel General Permit to both domestic and foreign flagged vessels (see Sections 6.2.3: Discharges of 

Ballast Water – Pacific Nearshore Vessels and 6.2.4: Discharges of Ballast Water – Vessels with Empty Tanks).

 

5

 The database does not provide vessel length. Therefore, the length limit was not used in analyzing the population of foreign vessels 

subject to the Vessel General Permit. 
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 3-2: Foreign Vessel Population 

Total Foreign Vessels 

Foreign Required to Submit 

NOI 

Vessel Class Count Percentage of Total Count Percentage of Total

Freight Barge 127 2 125 2 

Freight Ship 5,610 71 5,577 71 

Passenger Vessel 146 2 146 2 

Tank Barge 30 <1 30 <1 

Tank Ship 1,896 24 1,891 24 

Utility Vessel 118 1 61 1 

Total 7,927 100 7,830 100 

a The count of vessels required to submit an NOI is based on gross registered tonnage. 

3.3 Vessels Subject to the Ballast Water Management Requirements 

The analysis of national costs and impacts from the ballast water management requirements relies on the USCG 

National Ballast Information Clearinghouse. The database (NBIC, 2005) compiles information from ballast water 

reports submitted to the USCG by all ballast tank-equipped vessels entering U.S. waters. The information 

provided by the NBIC database includes vessel name and type, port, state, arrival date, the last port the vessel 

called at, information on ballast water management practices (i.e., ballast capacity, volume discharged, whether 

ballast water exchange was performed, and treatment methods). This analysis is based on information on foreign 

and domestic flag arrivals to U.S. ports during calendar year 2005. For the purpose of this analysis, NBIC 

provided two data files to EPA: “Oceangoing Arrivals” and “Pacific Nearshore Arrivals.” 

The Vessel General Permit requires that all vessels entering from outside the 200-nautical mile (nm) U.S. 

Exclusive Economic Zone (EEZ) with at least one ballast water tank empty must flush all empty tanks with 

saltwater or seal them off while they remain in the EEZ. The Oceangoing Arrivals dataset captures all arrivals of 

ballast-capable vessels to U.S. ports, where the vessel’s last port of call was foreign (non-Canadian). The dataset 

includes 38,912 arrivals by 6,857 vessels, of which 60 arrivals by 37 vessels entered a Great Lakes or Upper 

Hudson River port. These freshwater arrivals are excluded from costing, however, due to coverage under existing 

regulations in those jurisdictions (70 CFR 168). Table 3-3 summarizes the number of vessels and arrivals by 

water body type (marine or freshwater) and flag (i.e., foreign vs. domestic). 

Table 3-3: Oceangoing Arrivals 

All Saltwater Ports Great Lakes and Upper Hudson Ports 

Vessel Flag Vessel Count Arrival Count Vessel Count Arrival Count 

Domestic 336 3,443 3 3

Foreign 6,484 35,409 34 57

Total 6,820 38,852 37 60

EPA used the Pacific Nearshore Arrivals dataset in analyzing impacts of the Vessel General Permit requirements 

that vessels engaged in Pacific nearshore voyages while operating inside 200 nm from shore must now conduct 

ballast water exchanges at 50 nm from shore before arrival. Prior federal regulations required that exchanges be 

conducted only upon entrance into the U.S. EEZ, and not upon crossing Captain of the Port (COTP) zones. The 

dataset includes all arrivals to ports in California, Oregon, Washington, and Alaska that originated in North, 

Central, or South America or the Caribbean. The total number captured is 11,006 arrivals made by 1,314 vessels. 

Existing state regulations in California and Washington overlap with the Vessel General Permit requirements for 

vessels engaged in Pacific nearshore voyages; thus, arrivals to these states will incur no additional costs. 

Excluding the California and Washington arrivals yields 2,468 arrivals by 328 vessels that are likely to incur 

additional ballast water management cost due to the Vessel General Permit (see Table 3-4).

December 18, 2008 Final 6
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 3-4: Pacific Nearshore Arrivals 

All Pacific Ports Oregon and Alaskan Ports 

Vessel Flag Vessel Count Arrival Count Vessel Count Arrival Count 

Domestic 218 3,350 121 946 

Foreign 1,096 7,656 207 1,522 

Total 1,314 11,006 328 2,468

3.4 Uncertainties and Limitations 

This section discusses limitations and uncertainties in the estimation of the affected vessel population. Whether 

these limitations and uncertainties, taken together, are likely to lead to an understatement or overstatement of the 

estimated vessel population is not known. 

3⁄4 The domestic vessel population was estimated using WTLUS and VESDOC databases, and MODU 

vessel population data submitted by IADC. The main limitations of these data sources are: 

à Missing data fields. Even after merging both databases and using methods to maximize the 

amount of available data, several data fields remained with non-negligible deficiencies. Some but 

not all of these fields were populated using assumptions. 

à Conflicting vessel classifications. A relatively small number of vessels were found to be classified 

by WTLUS and VESDOC differently. In these cases EPA used the WTLUS classification and 

ignored the VESDOC. 

à Estimate of vessels required to submit an NOI: The count of vessels required to submit an NOI is 

a conservative estimate since data on gross tonnage are not complete. Thus, this count is based on 

the number of vessels that are either >78’ in length or >299 Gross Tons. 

3⁄4 The estimated number of vessels affected by the ballast water management requirements is based on the 

NBIC data. The main sources of uncertainty in this analysis are: 

à Self-reporting of ballast management practices. The NBIC system for gathering and organizing 

information on ballast-related activities calls for vessels to self-report with limited oversight. This 

may result in some vessels conducting incomplete reporting or failing to report altogether. The 

exact margin of this uncertainty is unknown, but will likely have a relatively low impact on total 

costs. 

à Vessel classification. The vessels in the NBIC database were coded primarily by IMO number, 

not Coast Guard number as was the case with the WTLUS, VESDOC, and U.S. Customs vessels. 

Although NBIC did provide a vessel class table that corresponded to the Oceangoing and Pacific 

Nearshore Arrivals datasets, the classification scheme was slightly different from the one that was 

used in the domestic and foreign vessel populations. A manual lookup approach was finally 

employed in order to typecast unidentified vessels. This may result in some uncertainty around 

estimated number of vessels by class. 

Finally, the estimate of the population of affected vessels is also subject to the reporting accuracy of the data 

providers. Typographical errors and incorrect entries exist to an unknown extent. Those that were discovered were 

amended. 

December 18, 2008 Final 7
Economic and Benefits Analysis of the Final Vessel General Permit 

4 Permit Overlap with Existing Regulations 

Several categories of best management practices outlined in the Vessel General Permit overlap with existing 

regulations and statutes at the federal and state level. In accordance with these regulations, some vessels have 

adopted BMPs required under the Vessel General Permit. This chapter cross-references existing regulations 

affecting vessel discharges and BMP requirements under the Vessel General Permit. EPA used the analysis of the 

overlap to adjust the number of vessels that are likely to incur incremental costs as a result of the Vessel General 

Permit implementation. 

4.1 Ballast Water and Invasive Species Management 

Certain provisions of the new Permit applying to all vessels with ballast tanks are incorporated from a previous 

U.S. Coast Guard regulation, last revised in the July 2004 Final Rulemaking for the Mandatory Ballast Water 

Management Program for U.S. Waters (codified in 33 CFR 151), issued under the authority of the National 

Invasive Species Act (NISA). Thus, these provisions will not be associated with any additional costs to vessel 

owners or operators, nor will they accrue any additional benefits to society. These requirements specify that 

masters, owners, operators, or persons-in-charge of all vessels equipped with ballast water tanks that operate in 

U.S. waters must: 

3⁄4 Avoid the discharge or uptake of ballast water in areas within or that may directly affect marine 

sanctuaries, marine preserves, marine parks, or coral reefs or in waters listed in Part 12.1 of the Permit. 

3⁄4 Minimize or avoid uptake of ballast water in the following areas and situations: 

à In areas known to have infestations or populations of harmful organisms and pathogens (e.g., 

toxic algal blooms). 

à In areas near sewage outfalls. 

à In areas near dredging operations. 

à In areas where tidal flushing is known to be poor or at times when a tidal stream is known to be 

more turbid. 

à In darkness, when bottom-dwelling organisms may rise up in the water column. 

à In shallow water or where propellers may stir up the sediment. 

à In areas with pods of whales, convergence zones, and boundaries of major currents. 

3⁄4 Clean the ballast tanks regularly to remove sediments. Clean the tanks in mid-ocean, under controlled 

arrangements in port, or at dry dock. Dispose of sediments in accordance with local, state, and federal 

regulations. 

3⁄4 Discharge only the minimal amount of ballast water essential for vessel operations while in the waters of 

the United States. 

3⁄4 Rinse anchors and anchor chains when retrieving the anchor to remove organisms and sediments at their 

place of origin. 

3⁄4 Remove fouling organisms from hull, piping, and tanks on a regular basis and dispose of any removed 

substances in accordance with local, state, and federal regulations. 

December 18, 2008 Final 8
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 9

3⁄4 Maintain a ballast water management plan developed specifically for the vessel that will allow those 

responsible for the plan’s implementation to understand and follow the vessel’s ballast water management 

strategy. 

Provisions of the Vessel General Permit requiring ballast water exchanges for vessels operating outside the U.S. 

EEZ are also preserved from the July 2004 U.S. Coast Guard Mandatory Ballast Water Management Program for 

U.S. Waters, with the exception of the stipulation that exchanges should be conducted as early in the voyage as 

possible (33 CFR 151). Therefore, oceangoing vessels that travel outside of the U.S. EEZ would not incur any 

incremental costs associated with ballast water exchanges. The regulatory specifications did not include small 

vessels that, in their voyage track, were not expected to exceed a distance of 200 nm or vessels that do not carry a 

sufficient amount of ballast water. The U.S. Coast Guard estimates that 7,420 vessels entering U.S. waters would 

conduct a ballast water exchange. 

The new Permit contains several provisions for ballast water management that the Mandatory Ballast Water 

Management Program does not cover. The first specifies that vessels engaged in Pacific nearshore voyages must 

conduct ballast water exchanges at least 50 nm from shore between ballasting events, even if their voyage track is 

not expected to exceed a distance of 200 nm. The second Permit provision requires vessels with empty ballast 

tanks or tanks containing only residual unpumpable ballast water to conduct saltwater flushing. However, there is 

some overlap between these provisions and existing state regulations, summarized in Table 4-1. In addition, the 

Permit specifies that vessels must conduct ballast water exchange as early as possible. The Permit also allows 

vessel operators not to exchange ballast water (or conduct saltwater flushing if applicable) if the vessel uses a 

USCG approved technology to treat ballast water or shore treatment (if readily available). The incremental cost of 

the latter two provisions is expected to be negligible and thus it is not included in subsequent analyses. 

Table 4-1: Summary Crosswalk between Current Ballast Requirements and EPA Permit Requirements 

EPA Permit Requirements Overlap with USCG 

Regulations 

Overlap with State 

Regulationsa

Mandatory BMPs for all vessels taking up or discharging ballast water Yes ------ 

Mandatory ballast exchange for vessels traveling outside the U.S. EEZ Yes ------ 

Mandatory reporting and provisions for ballast water management Yesb ------ 

Mandatory saltwater flushing for vessels declaring empty ballast tanks and no ballast 

on board (NoBOB) No ORc

Mandatory ballast water exchanges for vessels engaged in Pacific nearshore voyages No CA, WA, ORd

Requirements for vessels entering the Great Lakes Yes ------ 

a Though Maryland and Virginia have ballast water regulations, these regulations overlap with the 2004 U.S. Coast Guard rule to such an 

extent that they will not impact this analysis. Michigan’s ballast treatment regulation is also excluded from this table because it sets a 

treatment standard for discharges of ballast, which only affects provisions of the Vessel General Permit already excluded due to overlap with 

USCG regulations. 

b Mandatory reporting and provisions for ballast water management of the 2004 USCG rule did not apply to tankers engaged in Pacific 

nearshore voyages, but will apply to these vessels under the new EPA rule. 

c Current Oregon law prohibits discharge of ballast water mixed with sediments from other regions. 

d State-approved treatment options are also authorized as an alternative to ballast water exchange in the listed states, and while treatment 

options will be authorized under the new Permit, they must first be authorized by USCG, and no such options are yet authorized. Thus, any 

vessels currently opting to treat their ballast water to comply with the regulations of these states will incur additional compliance costs. 

California and Washington’s Ballast Water Management Laws, passed in 2003 and 2004, respectively, mandate 

ballast exchange for vessels engaged in Pacific nearshore voyages (Cal. Pub. Res. Code 71200-71271 and Wash. 

Admin. Code 77-120-030).6

 Thus, vessels engaged in Pacific nearshore voyages that make calls at ports in 

Washington and California will not incur additional costs under this Permit. Oregon’s Ballast Water Management 

Rule, established in 2002, also requires ballast exchange for vessels engaged in Pacific nearshore voyages, but 

 

6

 California’s regulations use only a tonnage criterion (300 gross weight tons) to establish applicability, so vessels longer than 79 feet but 

weighing less than 300 tons will incur incremental costs under the Vessel General Permit. 
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 10

exempts vessels traveling only between 40 and 50 degrees latitude (Or. Admin. R. 340-143-0010). Therefore, 

vessels engaged in Pacific nearshore voyages calling at ports in Oregon traveling within this range but passing 

through more than one COTP zone will incur additional costs; those vessels traveling outside this range will not 

incur additional costs. 

An existing regulation in Oregon prohibits the discharge of ballast water mixed with foreign sediments into its 

territorial waters, so vessels with empty ballast water tanks calling at ports in Oregon will not incur any additional 

costs under the Vessel General Permit (340 OAR 143). 

The Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990 (NANCPA), the predecessor 

regulation to NISA, established mandatory ballast management procedures for the Great Lakes and portions of the 

Hudson River. The only Great Lakes vessels covered by this regulation that will incur additional ballast-related 

costs under the new Permit are those with ballast tanks that are empty or contain only unpumpable residual 

ballast, as detailed above. These vessels, which are estimated to constitute 75–95 percent of the total number of 

vessels entering the Great Lakes and Upper Hudson, are subject to voluntary BMPs under the U.S. Coast Guard’s 

2005 Notice of Policy for Ballast Water Management for Vessels Entering the Great Lakes That Declare No 

Ballast on Board (70 FR 168). These voluntary BMPs are similar to the requirements of the new Permit. 

Additionally, saltwater flushing is already required by Canadian ports on the Great Lakes. Furthermore, a recently 

promulgated regulation from the St. Lawrence Seaway System (33 CFR Part 401.30) requires all oceangoing 

vessels to conduct saltwater flushing of ballast water tanks 200 nautical miles from any shore before entering 

either the U.S. or Canadian waters of the Seaway System, which serves as the gateway to the Great Lakes. 

Therefore, EPA estimates that no Great Lakes NOBOB vessels will incur additional costs under the Vessel 

General Permit, given implementation of voluntary BMPs. 

4.2 Graywater 

Graywater is defined in the Vessel General Permit as the discharge derived from “galley, bath and shower water, 

as well as wastewater from lavatory sinks, laundry, and water fountains” (EPA, 2008b). The new Vessel General 

Permit under NPDES contains a number of special provisions applying to discharges of graywater from cruise 

ships, specifying treatment standards for graywater discharges in port or within 1 nm of shore, and requiring that 

releases between 1 and 3 nm of shore occur only when traveling at a speed of at least 6 knots. These requirements 

are based on the U.S. Coast Guard Limitations on Discharge of Treated Sewage or Graywater in Alaska, 

established in 2001 (33 CFR 159). Cruise ships traveling in the territorial waters of Alaska therefore will not incur 

any additional costs under the new Permit requirements. 

Several other states have existing requirements that will diminish incremental costs associated with these 

provisions of the new Permit: 

3⁄4 Maine has adopted Alaska’s discharge requirements for vessels with passenger capacities of at least 250 

under the 2003 Act to Protect Maine’s Coastal Waters, so vessels traveling in its territorial waters will not 

incur additional costs under the Vessel General Permit (Me. Rev. Stat. Ann. tit. 38, 423D). 

3⁄4 The California Clean Coast Act, enacted in 2004, prohibits cruise ships from discharging any graywater 

into California’s territorial waters; therefore, vessels will not incur any additional costs when making port 

calls in California (Cal. Pub. Res. Code. 72420-72425). 

Several states, including Washington, Hawaii, and Florida, have voluntary memoranda of understanding with the 

cruise ship industry that discourage the discharge of untreated graywater in port or within 4 nm of shore, and 

claim a high level of operator compliance with these provisions.7

 Vessels already in compliance with these 

 

7

 See ICCL (2001), Washington Dept. of Ecology (2007), and Maehara (2004). 
Economic and Benefits Analysis of the Final Vessel General Permit 

memoranda of understanding will not incur additional costs under the Vessel General Permit. Applicable state 

regulations are summarized in Table 4-2.

Table 4-2: Summary Crosswalk between Current Cruise Ship Requirements and EPA Permit 

Requirements 

EPA Permit Requirements Overlap with State-Level 

Regulationsa

Overlap with State 

MOUs 

Treatment standards for graywater discharges AK, ME None 

Limits on discharges within 3 nm of shore AK, ME, CA FL, HI, WA 

a The term “State-Level Regulations” includes both state and federal regulations for Alaska. 

Also relevant to graywater discharges are two other federal regulations. First, under Section 312(a) of the CWA, 

graywater discharges from vessels in the Great Lakes region are currently treated as sewage and thus are excluded 

from the scope of the new Permit. Second, the National Marine Sanctuaries Act authorizes the National Oceanic 

and Atmospheric Administration (NOAA) to designate National Marine Sanctuaries wherein certain discharges, 

including graywater, may be restricted to protect sensitive ecosystems. 

4.3 Anti-fouling Hull Coatings 

The new Vessel General Permit under NPDES prohibits the use of organotin-based anti-fouling hull coatings. The 

Organotin Anti-fouling Paint Control Act of 1988 already prohibits the use of these compounds on vessels under 

25 feet in length; therefore, these vessels will not incur any additional costs under this provision (33 USC 2401–

2410). Furthermore, the United States recently ratified the 2001 International Convention on the Control of 

Harmful Anti-fouling Systems on Ships, which bans the use of all organotin compounds, although it has not 

amended the Act to reflect these new treaty obligations to date. As a result, the long-run costs of the organotin 

provisions of the Vessel General Permit are assumed to be zero since the anti-fouling treaty came into effect on 

September 22, 2008. 

4.4 Bilgewater Discharges 

The new Vessel General Permit under NPDES reinforces several of the requirements of the Act to Prevent 

Pollution from Ships (APPS), the U.S. implementation of the 1973/78 International Convention for the Prevention 

of Marine Pollution from Ships (MARPOL), regarding discharges of oily bilgewater. Additionally, the Vessel 

General Permit prohibits the discharge of bilgewater by vessels weighing more than 400 tons within 1 nm of 

shore except during emergencies (unless vessel owner operators use a oily water separator which discharges 

bilgewater with oil content below 5 ppm), and requires that vessels discharging bilgewater between 1 and 3 nm 

from shore only do so when underway at a speed of at least 6 knots. It also requires vessels weighing less than 

400 tons to minimize discharges of bilgewater. 

These Permit requirements complement current requirements found in the USCG regulations governing Oily 

Mixture (Bilge Slops) Discharges on Oceangoing Ships Over 400 Tons, implemented under the authority of 

APPS and last amended in 1999. These regulations require the use of oily-water separators on discharges of 

bilgewater by vessels larger than 400 tons (33 CFR 155). While the new Permit requirements will be associated 

with additional costs for most subject vessel operators, the requirements consistent with APPS will not. 

4.5 Overlap with Existing Clean Water Act Provisions 

Certain discharges are exempt from the NPDES requirements under the Clean Water Act; the vessel vacatur 

therefore does not apply to them. Discharges occurring more than 3 nm from shore and discharges by Armed 

Forces vessels are exempt from the previous 122.3(a) exclusion, and are therefore excluded from the requirements 

December 18, 2008 Final 11
Economic and Benefits Analysis of the Final Vessel General Permit 

of this permit. Sewage/blackwater is covered by performance standards for sanitation equipment, and is excluded 

from the definition of pollutant contained in Section 502(6)(A) of the CWA and thus is not subject to NPDES 

permitting. These discharges, as well as discharges from vessels not functioning as a means of transportation, are 

outside the scope of this analysis. 

EPA’s 1996 revisions to its Regulations of the Discharge of Oil, implemented under the authority of the CWA, 

prohibit the discharge of bilge slops containing sufficient oil to create a film or sheen in the territorial waters of 

the United States (40 CFR 110). This requirement regarding oil levels in bilgewater for non-MARPOL vessels 

remains the same in the new Permit. 

4.6 Issues and Uncertainties 

There exists some degree of overlap between the Vessel General Permit and the graywater provisions of the 

National Marine Sanctuaries Act. However, since the areas affected by this Act are relatively small, EPA will 

assume that vessels’ graywater discharges were simply retained on board in designated sanctuaries and discharged 

outside these areas, and therefore incremental costs will remain the same. 

December 18, 2008 Final 12
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 13

5 Profile of the Water Transportation, Fishing, and Mining Industries 

5.1 Introduction 

The water transportation, fishing, and mining industries consist of the establishments that own and operate the 

commercial vessels that will be subject to the Vessel General Permit for Discharges Incidental to the Normal 

Operation of Commercial Vessels.8

 

The water transportation industry is a $34 billion industry that employs nearly 150,000 people on a payroll of just 

over $6 billion. The fishing industry is much smaller, with total revenues of $1.65 billion, employing just over 

6,500 people on a payroll of $253 million. The drilling oil and gas wells sector (a subset of the mining industry) is 

a $9 billion sector that employs nearly 60,500 people on a payroll of approximately $2.5 billion. 

Water transportation accounts for a majority of the vessels sailing on U.S. waters and is made up of several 

industry sectors, described in Section 5.2.2: Water Transportation. Overall, the industry has experienced mild 

growth in the number of establishments, revenues, and payroll, but a decline in the number of employees. 

The fishing industry, responsible for slightly more than a quarter of all commercial vessels in the United States, is 

experiencing more of a decline, although it still shows some revenue growth despite declines in the number of 

establishments and employees, and in total payroll. 

The drilling oil and gas wells sector, which covers the 131 MODUs covered by the VGP, has experienced 

relatively strong growth, demonstrating a 24 percent increase in revenues from 1997 to 2002.9

5.1.1 Data Sources Used 

Overviews of the various industry sectors were created using information from industry groups, trade 

associations, and other reference sources. 

Data for numbers of firms, establishments, revenues, and employment were obtained from the U.S. Census 

Bureau, with the exception of data for North American Industry Classification System (NAICS) code 11411-

Fishing, because it is not covered by the Economic Census. In this case, the data come from the U.S. Small 

Business Administration (SBA). 

Data for the number of vessels were extracted from the combined vessel information of WTLUS and VESDOC 

(detailed further in Section 3.1: Domestic Vessel Population) and from information submitted by the IADC on the 

number of MODUs. NAICS codes were assigned to vessels according to the NAICS codes of their 

owner/operators, which were obtained from the Dun & Bradstreet (2006) and ReferenceUSA (2006) databases. 

Where owner/operator information was unavailable or no corresponding company was found in these databases, 

the most likely NAICS code was assigned to a vessel using information on vessel type and area of operation. 

 

8

 Though the overwhelming majority of fishing vessels need not obtain coverage under the VGP, the profile of the fishing industry remains 

in this analysis to account for potential expenses for the limited number of fishing vessels (as defined in 33 CFR 1342) which may need to 

obtain coverage for ballast water under this permit. 

9

 The 131 MODUs only account for a small percentage of establishments reported in the 2002 Economic Census for the drilling oil and gas 

wells sector overall: approximately 7 percent (131 out of 1,926 establishments). Other establishments classified in the drilling oil and gas 

wells sector conduct operations that do not involve the use of MODUs; for example, these firms may drill oil and gas wells on land. 

Note that other vessels that are involved in, or provide support to, oil and gas activities (e.g. offshore supply vessels), are classified within 

NAICS 488310 (Port and Harbor Operations). 
Economic and Benefits Analysis of the Final Vessel General Permit 

5.1.2 Organization of This Chapter 

This chapter presents an overview of the water transportation, fishing, and mining industries. Section 5.2 provides 

definitions and overviews of the industries and their sectors, as well as the number of vessels associated with each 

industry, as classified by NAICS. 

Section 5.3 summarizes recent trends in these industries, including changes in the number of establishments and 

financial performance. 

Section 5.4 describes the industries’ market structures, including details of performance according to employment 

size, numbers and percentages of small businesses, employment trends, and payroll trends. 

5.2 Overview of the Water Transportation, Fishing, and Mining Industries 

5.2.1 Definition of the Water Transportation, Fishing, and Mining Industries 

The water transportation industry, for the purpose of this chapter, includes NAICS codes 483-Water 

Transportation; 4872-Scenic and Sightseeing Transportation, Water; and 4883-Support Activities for Water 

Transportation. 

The fishing industry includes NAICS 11411-Fishing. 

The mining industry includes NAICS 213111-Drilling oil and gas wells 

Table 5-1 lists the relevant NAICS codes for the water transportation, fishing, and mining industries. 

Table 5-1: Relevant 2002 NAICS Codes and Descriptions 

2002 NAICS Code Meaning of 2002 NAICS Code 

Water Transportation Industry 

4831 Deep Sea, Coastal, and Great Lakes Water Transportation 

3⁄4 483111 Deep Sea Freight Transportation 

3⁄4 483112 Deep Sea Passenger Transportation 

3⁄4 483113 Coastal and Great Lakes Freight Transportation 

3⁄4 483114 Coastal and Great Lakes Passenger Transportation 

4832 Inland Water Transportation 

3⁄4 483211 Inland Waterways Freight Transportation 

3⁄4 483212 Inland Waterways Passenger Transportation 

4872 Scenic and Sightseeing Transportation, Water 

4883 Support Activities for Water Transportation 

3⁄4 488310 Port and Harbor Operations 

3⁄4 488320 Marine Cargo Handling 

3⁄4 488330 Navigational Services to Shipping and Salvage 

3⁄4 488390 Other Support Activities for Water Transportation 

Fishing Industry 

1141 Fishing 

Mining Industry 

213111 Drilling Oil and Gas Wells sector 

Source: U.S. Census Bureau, 2002 

December 18, 2008 Final 14
Economic and Benefits Analysis of the Final Vessel General Permit 

5.2.2 Water Transportation 

Establishments in the water transportation industry provide water transportation of passengers and cargo using 

watercraft, such as ships, barges, and boats. The industry is composed of two industry groups: (1) one for deep 

sea, coastal, and Great Lakes water transportation; and (2) one for inland water transportation. This split typically 

reflects the difference in equipment used (U.S. Census Bureau, 2002). 

Scenic and sightseeing water transportation services are also included under this industry heading, as are support 

activities for water transportation. These two industry groups are technically classified under different NAICS 

codes by the Census Bureau, but will be included under water transportation for the purposes of this chapter. 

Total waterborne commerce in the United States has increased rather steadily over the past 50 years, fueled 

mostly by growth in foreign commerce, which overtook domestic shipments (in terms of weight) in the mid1990s. Foreign commerce accounted for nearly 60 percent of total waterborne commerce by weight in 2005 

(USACE, 2005a). 

Deep Sea, Coastal, and Great Lakes Water Transportation 

This industry group comprises establishments primarily engaged in providing deep sea, coastal, and Great Lakes 

water transportation, as well as transportation via the St. Lawrence Seaway. Marine transportation establishments 

using the facilities of the St. Lawrence Seaway Authority Commission are considered to be using the Great Lakes 

Water Transportation System (U.S. Census Bureau, 2002). Firms in this NAICS grouping are further classified 

based on their area of operation (deep sea or coastal/Great Lakes) and payload type (cargo or passengers). 

The Jones Act of 1920 requires that all domestic waterborne trade (between two points in the United States) be 

conducted on vessels built in the United States, documented in the United States, and owned by U.S. citizens or 

companies (Transportation Institute, undated). Thus, many vessels operating in the Coastal and Great Lakes 

Freight Transportation sector are subject to this law. 

Deep Sea Freight Transportation 

The businesses in this industry sector are primarily engaged in providing deep sea transportation of cargo to or 

from foreign ports. This sector encompasses oceangoing barges, oil tankers, and other large freight vessels (U.S. 

Census Bureau, 2002). A large portion of U.S. foreign trade merchandise (1.2 billion metric tons) is transported 

via water, making this sector the cornerstone of U.S. international trade (Transportation Institute, undated). 

Because of its close relationship to international trade, deep sea freight transportation has been increasing steadily 

over the past 20 years, driven by increasing imports to the United States from foreign ports. Outbound freight has 

not grown substantially over this period, now accounting for less than a third of cargo carried between U.S. and 

foreign ports (USACE, 2005a). 

Over the last half-century, the United States’ merchant fleet has declined in number, as increasingly strict 

regulations have prompted the registration of vessels under foreign flags to limit liability. Though the U.S. vessel 

fleet has shrunk, it has also become more efficient, with today’s merchant vessels carrying 40 percent more cargo 

and requiring fewer crew members (Transportation Institute, undated). 

Deep Sea Passenger Transportation 

Establishments in this sector are primarily engaged in providing deep sea transportation of passengers to or from 

foreign ports (U.S. Census Bureau, 2002). The most common type of deep sea passenger transportation is the 

cruise ship. Starting in the 1990s, there has been a reversal to the decline this industry sector had been facing 

since the 1960s, with steady growth in the number of passengers over the last 10 years (Cruise Lines International 

Association, 2006). 

December 18, 2008 Final 15
Economic and Benefits Analysis of the Final Vessel General Permit 

Currently, several cruise line corporations are planning additions to their fleets in anticipation of increased 

demand for cruises in the next decade (Transportation Institute, undated). Cruise Lines International Association 

indicates that 48 million Americans say they intend to take a cruise in the next three years, nearly double the 

number that took a cruise in the three preceding years. This industry is thus one of the strongest sources of growth 

in the water transportation industry, a trend that is expected to continue. 

Coastal and Great Lakes Freight Transportation 

Firms transporting cargo in coastal waters; the Great Lakes System (including the St. Lawrence Seaway); or deep 

seas between ports of the United States, Puerto Rico, and U.S. island possessions or protectorates fall into this 

NAICS code classification (U.S. Census Bureau, 2002). 

The vessels in this sector are similar to those used for deep sea freight transport, though less numerous. The 

majority of the vessels in this sector are barges, though the sector also contains other freight transport vessels, as 

well as tugboats (Transportation Institute, undated). 

Coastal domestic trade to and from Alaska, Hawaii, and U.S. Territories consists mainly of the shipment of 

petroleum and petroleum products, chemicals, and agricultural products. The primary products transported on the 

Great Lakes System are coal, limestone, and iron ore (Transportation Institute, undated). 

Coastal and Great Lakes freight transportation accounts for about 30 percent of all U.S. domestic waterborne 

shipments by weight. Great Lakes freight transportation has remained relatively constant over the past 20 years, 

hovering around 150 million tons per year (approximately two-thirds domestic and one-third foreign cargo). 

Coastal freight transportation has grown over the same period, from around 1.1 billion tons per year to more than 

1.6 billion tons in 2005, as a result of increased foreign shipments (USACE, 2005). 

Coastal and Great Lakes Passenger Transportation 

This industry sector contains establishments primarily engaged in providing water transportation of passengers in 

coastal waters, the Great Lakes System (including the St. Lawrence Seaway), or deep seas between ports of the 

United States, Puerto Rico, and United States island possessions and protectorates. This industry sector includes 

many coastal and Great Lakes ferries used to travel short distances between coastal ports, or from shores to 

nearby islands, as well as larger vessels used on the Alaska Marine Highway, which travels between ports on the 

southern coast of Alaska and northwestern Canada (Reference for Business, 2007c). 

Inland Water Transportation 

Businesses primarily engaged in providing inland water transportation of passengers and cargo on lakes, rivers, or 

intracoastal waterways (except on the Great Lakes System) are classified under this NAICS grouping, and are 

further classified between freight and passenger transportation (U.S. Census Bureau, 2002). 

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

Inland Waterways Freight Transportation 

The companies in this industry sector are primarily engaged in providing inland water transportation of cargo on 

lakes, rivers, or intracoastal waterways (except on the Great Lakes System) (U.S. Census Bureau, 2002). This 

sector contains a large portion of the vessels in the United States, as it encompasses river barges, as well as the tug 

and towboats that propel them. The vast majority of boats in this sector are barges, which outnumber other inland 

freight vessels by about 10 to 1 (Transportation Institute, undated). 

The products carried by this industry sector include more than half of U.S. grain shipments, a quarter of chemical 

and petroleum exports, and a fifth of domestic coal shipments (Transportation Institute, undated). Barges account 

for 79 percent of domestic waterborne freight. 

December 18, 2008 Final 16
Economic and Benefits Analysis of the Final Vessel General Permit 

Inland waterways freight transportation, similar to Great Lakes and coastal water transportation, has remained 

stagnant over the past two decades in terms of total tonnage transported, with a modest increase in the mid-1980s. 

Nevertheless, it accounts for more than 50 percent of all domestic waterborne freight shipments (U.S. Army 

Corps of Engineers, 2005). 

Inland Waterways Passenger Transportation 

This industry sector provides inland water transportation of passengers on lakes, rivers, or intracoastal waterways 

(except on the Great Lakes System) (U.S. Census Bureau, 2002). This sector includes water taxis and ferries 

(except coastal and Great Lakes ferries), usually traveling short distances between inland ports, such as in New 

York harbor or in San Francisco Bay. 

The ferry industry has been rebounding from historic lows in the 1970s, and short-distance ferries in urban areas 

have become alternatives to crowded highways and urban transit systems. In 2000, the 677 ferries operating in the 

United States served 578 destinations along 352 routes, transporting 113 million passengers (these figures include 

coastal and Great Lakes ferries) (Reference for Business, 2007c). 

Scenic and Sightseeing Transportation, Water 

This industry group comprises establishments primarily engaged in providing scenic and sightseeing 

transportation on water. The services provided are usually local and involve same-day return to place of origin 

(U.S. Census Bureau, 2002). 

This sector encompasses a wide variety of vessel types, from small “swamp buggies” used to tour the Florida 

Everglades to chartered dinner cruisers to larger whale-watching boats. The range of services offered has 

continued to expand over the past decade, with gambling boats becoming popular in Indiana and Iowa, and 

similar gaming “cruises-to-nowhere” becoming popular in Florida (Reference for Business, 2007d). 

This leisure-based industry sector is more vulnerable to economic fluctuations, since its revenues draw on 

discretionary consumer spending. 

Support Activities for Water Transportation 

This NAICS grouping includes establishments classified in the following NAICS sectors: 48831, Port and Harbor 

Operations; 48832, Marine Cargo Handling; 48833, Navigational Services to Shipping and Salvage; and 48839, 

Other Support Activities for Water Transportation (U.S. Census Bureau, 2002). 

Businesses in these sectors are the link between a vessel’s load (cargo or passengers) and that load’s final 

destination. This sector provides the highest percentage of employment in the industry, as many of these services 

are labor-intensive. 

Port and Harbor Operations 

Businesses in this industry sector operate ports, harbors (including docking and pier facilities), or canals (U.S. 

Census Bureau, 2002). The vessels in this industry sector are likely to be smaller, auxiliary vessels as opposed to 

the large container ships and barges that they serve. 

Marine Cargo Handling 

This industry comprises establishments primarily engaged in providing stevedoring and other marine cargo 

handling services (except warehousing) (U.S. Census Bureau, 2002). This sector contains only a small number of 

vessels, as most of its business is land-based. 

December 18, 2008 Final 17
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 18

This particular industry sector, along with port and harbor operations, has been growing over the last decade or 

two as a result of the increase in foreign trade, mostly with Asian countries. Marine cargo handling and port and 

harbor operations on the Pacific Coast account for about half of all such operations in the United States 

(Reference for Business, 2007e). 

Despite the increase in volume of shipments handled, employment in marine cargo handling, as well as in port 

and harbor operations, has been on the decline in recent years, due to increased automation of tasks and other 

technological advances that reduce the need for manual labor. The industry’s unions, the International 

Longshoremen’s Association and the International Longshore and Warehouse Union, are nevertheless still strong 

and maintain high membership rates (Reference for Business, 2007e). 

Navigational Services to Shipping and Salvage 

This NAICS classification includes two main types of businesses: navigational services to shipping and marine 

salvage (U.S. Census Bureau, 2002). 

Vessels in this industry do not typically carry passengers or cargo, but rather assist larger vessels in entering and 

leaving port, or in other operations. The salvage subsector of this industry sector includes maintenance vessels 

that prepare ships for salvage and scrap. 

Other Support Activities for Water Transportation 

Other auxiliary services of the water transportation industry are grouped into this category, which includes 

maintenance and repair of vessels, inspections, security, and other operations. The strong growth in this industry 

between 1997 and 2001 may be attributable to the rapid increase in cargo security since the terrorist attacks of 

September 11, 2001 (Reference for Business, 2007f). 

5.2.3 Fishing10

The fishing industry includes commercial catching or taking of finfish, shellfish, or miscellaneous marine 

products from a natural habitat, such as the catching of bluefish, eels, salmon, tuna, clams, crabs, lobsters, 

mussels, oysters, shrimp, frogs, sea urchins, and turtles (U.S. Census Bureau, 2002). 

Since the 1990s, finfish volume has been declining, due to severely depleted fisheries in the Atlantic and loss of 

breeding grounds to pollution, as well as to increasingly strict regulations aimed at preventing these problems 

(Reference for Business, 2007a, b). Demand has not been strong enough to prevent declines in the value of the 

catches. Shellfish volume has remained relatively constant, with the total value of the catch increasing slightly. 

Fish and seafood imports have increased over the same period, intensifying the competition in this industry 

(National Marine Fisheries Service, 2003). 

Alaska leads the nation in both volume and value of fish caught, followed by Louisiana in both measures. 

California ranks third in volume of fish caught, while Massachusetts takes third place in terms of value (National 

Marine Fisheries Service, 2003). 

5.2.4 Mining 

The mining industry comprises establishments that extract naturally occurring mineral solids, such as coal and 

ores; liquid minerals, such as crude petroleum; and gases, such as natural gas. Within the mining industry, the 

drilling oil and gas wells sector (NAICS 213111) operates vessels covered by the VGP (131 MODUs). This sector 

comprises establishments primarily engaged in drilling oil and gas wells for others on a contract or fee basis (U.S. 

Census Bureau, 2002). According to data provided by the IADC, the 131 MODUs covered by the VGP include 5 

 

10 Vessels subject to the ballast water requirements of the Permit include an estimated 26 commercial fishing vessels. 
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 19

drillships, 24 semi-submersible units, 5 submersible units, 40 inland barge units, and 57 jackup units (IADC, 

2007). Note that these MODUs represent only a very small fraction of the total number of establishments reported 

overall in the drilling oil and gas wells sector, as described in Section 5.3.2. 

In the remainder of this report, unless otherwise noted, the term mining industry refers more specifically to the 

drilling oil and gas wells sector within the industry rather than the mining industry as a whole. 

5.2.5 Number of Water Transport Vessels by Industry Sector 

Table 5-2 summarizes the number of vessels, operators, and average number of vessels per operator11 for each 

industry sector in 2005. In this table and in Table 5-3: Number of Vessels in the WTLUS Database, 2001-2005, 

the Deep Sea Freight Transportation and Coastal and Great Lakes Freight Transportation sectors are considered 

together, due to the difficulties of determining which vessels fall under which NAICS code based on the 

information provided by the VESDOC and WTLUS databases. The same is true for the Deep Sea Passenger 

Transportation and Coastal and Great Lakes Passenger Transportation sectors. The distinctions between these 

industry sectors will be maintained for the rest of this analysis. 

There were approximately 90,000 commercial vessels operating in U.S. waters in 2005. Of these, more than 

32,000 were involved in inland water transportation, which includes barges, ferries, and water taxis. The inland 

water transportation industry group, along with the marine cargo handling industry group, contain the highest 

concentration of vessels per operator, approximately 26 and 27, respectively. This may be due to the fact that each 

barge counts as a separate vessel and a single barge company may own a large number of barges. 

In sum, passenger transportation vessels accounted for about 11,000 vessels, freight transportation for about 

38,000, and support activities for the remaining 12,000 vessels classified under the water transportation industry. 

Fishing vessels made up the majority of the remainder of commercial vessels, with nearly 29,000.12 Mobile 

offshore drilling units accounted for 131 vessels. 

Table 5-2: Number of Vessels and Operators by Industry Sector, 2005 

Industry Sector 

Total Number of 

Vessels 

Number of 

Vessels With an 

Operator Name 

Listed 

Number of 

Operators 

Average 

Number of 

Vessels per 

Operator 

Water Transportation Industry 

Deep Sea, Coastal, and Great Lakes Water Transportation 

Deep Sea, Coastal, and Great Lakes Freight 

Transportation 7,768 5,831 1,073 5 

Deep Sea, Coastal, and Great Lakes Passenger 

Transportation 9,128 4,558 3,678 1 

Subtotal-Deep sea, Coastal, and Great Lakes 16,896 10,389 4,751 2 

Inland Water Transportation 

Inland Waterways Freight Transportation 30,482 30,088 1,141 26 

Inland Waterways Passenger Transportation 1,674 948 686 1 

Subtotal-Inland 32,156 31,036 1,827 17 

Scenic and Sightseeing Transportation, Water 

Scenic and Sightseeing Transportation, Water 546 417 146 3 

 

11 The number of operators is based on unique companies that own and operate each vessel, as indicated in the vessels databases. 

12 However, the overwhelming majority of fishing vessels must not obtain coverage under the VGP. Only 26 commercial fishing vessels 

are estimated to potentially need to obtain coverage for ballast water under this permit. 
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 20

Table 5-2: Number of Vessels and Operators by Industry Sector, 2005 

Industry Sector 

Total Number of 

Vessels 

Number of 

Vessels With an 

Operator Name 

Listed 

Number of 

Operators 

Average 

Number of 

Vessels per 

Operator 

Support Activities for Water Transportation 

Port and Harbor Operations 3,402 3,213 1,095 3 

Marine Cargo Handling 182 183 7 27 

Navigational Services to Shipping and Salvage 7,315a 6,468 2,252 3 

Other Support Activities for Water Transportation 1,001a 586 545 1 

Subtotal-Support Activities 11,900 10,867 4,045 3 

TOTAL-Water Transportation 61,498b 52,2 10,623 5 

Fishing Industry 

Fishing 28,867c 6,709 5,833 1 

Mining Industry 

Mobile Offshore Drilling Units 131d 118 35 3 

a One vessel in Navigational Services to Shipping and Salvage sector and 925 vessels in Other Support Activities for Water Transportation 

sector are considered recreational vessels and are not included in the universe of vessels subject to VGP. 

b The total number of vessels reported for the water transportation industry excludes 340 vessels that could not be assigned to a specific 

NAICS sector. 

c While there are 28,867 commercial fishing vessels in total, only 26 conduct either ballast water exchange or saltwater flushing. 

d Number obtained from IADC comments submitted to EPA in August 2007. 

Source: U.S. Army Corps of Engineers, 2005d; U.S. Coast Guard, 2007a 

5.3 Recent Trends 

This section reviews the recent trends in the water transportation and fishing industries in terms of number of 

firms, numbers of vessels, and financial performance. It also highlights trends in the drilling oil and gas wells 

sector of the mining industry. 

Overall, there were slight upward trends in the water transportation industry in terms of number of vessels, firms, 

and total revenues; however, the fishing industry experienced declines in the number of firms and in revenues (no 

data were available for its number of vessels). The drilling oil and gas wells sector experienced relatively strong 

firm, revenue, and employment growth. 

The reference period is from 1997 through 2002, the years of the two most recent Economic Censuses, except for 

the number of vessels. Changes in the number of vessels are measured between 2001 and 2005, the largest range 

of years available for these data. There were no changes to the NAICS codes for these industries between these 

years. 

Employment, establishment, and payroll data for the Fishing Industry are from 1998, as 1997 data was classified 

by SIC code and was not comparable. Where Fishing Industry data was not available from the Census Bureau, it 

was taken from the SBA. 

5.3.1 Number of Vessels by Industry Sector 

Table 5-3 shows changes in the number of vessels in the 2001 and 2005 versions of the WTLUS database.13 Over 

this period, the WTLUS database recorded a loss of 1.1 percent in the total number of vessels. Though most 

sectors of the water transportation industry actually experienced increases in the number of vessels, inland water 

freight transportation, the sector with the largest number of vessels (as it accounts for a large number of barges), 

lost more than 1,000 vessels over this period. 

 

13 These vessel totals only include vessels in the WTLUS database, and do not encompass those vessels listed only in VESDOC. A version of 

VESDOC was not available for 2001. 
Economic and Benefits Analysis of the Final Vessel General Permit 

The number of deep sea, coastal, and great lakes passenger transportation vessels (including cruise ships) grew by 

143, an increase of more than 20 percent. Scenic and sightseeing transportation added 125 new vessels over this 

period, for a nearly 40 percent increase. Port and harbor operations and navigational services to shipping and 

salvage both added more than 350 vessels to their ranks, representing increases of 26 percent and 8 percent, 

respectively. 

Table 5-3: Number of Vessels in the WTLUS Database, 2001-2005 

Industry Sector 2001 2005 % Change 

Water Transportation Industry 

Deep Sea, Coastal, and Great Lakes Water Transportation 

Deep Sea, Coastal, and Great Lakes Freight 

Transportation 4,779 5,083 6.4% 

Deep Sea, Coastal, and Great Lakes Passenger 

Transportation 678 821 21.1% 

Subtotal-Deep Sea, Coastal, and Great Lakes 5,457 5,904 8.2% 

Inland Water Transportation 

Inland Waterways Freight Transportation 28,338 27,239 -3.9% 

Inland Waterways Passenger Transportation 242 267 10.3% 

Subtotal- Inland 28,580 27,506 -3.8% 

Scenic and Sightseeing Transportation, Water 

Scenic and Sightseeing Transportation, Water 333 458 37.5% 

Support Activities for Water Transportation 

Port and Harbor Operations 1,389 1,753 26.2% 

Marine Cargo Handling 73 86 17.8% 

Navigational Services to Shipping and Salvage 4,868 5,251 7.9% 

Other Support Activities for Water Transportation 19 15 -21.1% 

Subtotal-Support Activities 6,349 7,105 11.9% 

TOTAL-Water Transportationa 41,481 41,028 -1.1% 

Source: U.S. Army Corps of Engineers, 2001 and 2005d.

Note: Data for the number of fishing vessels in 2001 were not available. 

a Totals include vessels for which no NAICS code could be determined.

5.3.2 Number of Establishments by Industry Sector 

Table 5-4 summarizes the changes in numbers of establishments for each sector of the water transport, fishing, 

and mining industries between 1997 and 2002. The water transportation industry experienced a slight increase of 

0.2 percent in the number of establishments over this period, though several sectors, notably deep sea freight 

transportation, inland waterways freight transportation, and navigational services to shipping and salvage, saw a 

decline in the number of establishments. The increase is less dramatic than the overall U.S. increase of 4.4 percent 

in the number of establishments over this period (U.S. SBA, 2004). 

The largest increase in the number of establishments was in port and harbor operations, with a nearly 39 percent 

change in the number of establishments over the five-year period. 

Deep sea passenger transportation, which includes cruise ships, also grew by about 9 percent in number of 

establishments, and inland waterways passenger transportation experienced a 17 percent increase in this area. The 

drilling oil and gas wells sector experienced an 18.3 percent increase in the number of establishments. 

Conversely, the fishing industry experienced a decline of 9.3 percent in the number of establishments between 

1998 and 2002. 

December 18, 2008 Final 21
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 22

Table 5-4: Number of Establishments by Industry Sector, 1997 and 2002 

NAICS Description 1997 2002 % Change 

Water Transportation Industry 

Deep Sea, Coastal, and Great Lakes Water Transportation 

Deep Sea Freight Transportation 487 456 -6.4% 

Deep Sea Passenger Transportation 80 87 8.8% 

Coastal and Great Lakes Freight Transportation 616 677 9.9% 

Coastal and Great Lakes Passenger Transportation 125 114 -8.8% 

Subtotal-Deep Sea, Coastal, Great Lakes 1,308 1,334 2.0% 

Inland Water Transportation 

Inland Waterways Freight Transportation 383 321 -16.2% 

Inland Waterways Passenger Transportation 230 269 17.0% 

Subtotal Inland 613 590 -3.8% 

Scenic and Sightseeing Transportation 

Scenic and Sightseeing Transportation, Water 1,692 1,726 2.0% 

Support Activities for Water Transportation 

Port and Harbor Operations 168 233 38.7% 

Marine Cargo Handling 623 567 -9.0% 

Navigational Services to Shipping and Salvage 865 778 -10.1% 

Other Support Activities for Water Transportation 869 924 6.3% 

Subtotal-Support Activities 2,525 2,502 -0.9% 

TOTAL-Water Transportation 6,138 6,152 0.2% 

Fishing Industry 

Fishing 2,113 1,916 -9.3% 

Mining Industry 

Drilling oil & gas wells sector 1,628 1,926 18.3% 

Source: U.S. Census Bureau, 1997, 1998, 2002a, 2002b 

5.3.3 Establishment and Employment Births and Deaths 

Table 5-5 summarizes average establishment birth and death rates for each industry sector for which these data 

were available. The reference period for these trends is 1998–2003, as data before 1998 are classified according to 

the Standard Industry Classification (SIC) system. Average birth and death rates in the water transportation, 

fishing, and mining industries fall between 10 and 15 percent of their total numbers of establishments.14 

In general, deaths outnumber births over this period for all water transportation industry sectors except for inland 

water transportation, where the average net change was close to five establishment births per year. The largest 

average net change came in support activities for water transportation, with an average of nearly 25 establishment 

deaths per year. 

The fishing industry averaged a net change of close to two establishment births per year between 1998 and 2003, 

while the support activities for mining sector averaged a net change of nearly 46 establishment births per year 

between 1998 and 2003. 

 

14 For the mining industry, the fraction is based on births and deaths relative to the 9,104 establishments reported in the 2002 Economic 

Census for NAICS 213 – Support activities for mining. According to the 2002 Economic Census, the drilling oil and gas wells sector 

(NAICS 213111) represented about a fifth (1,926 establishments) of the establishments reported in the support activities for mining sector 

(NAICS 213) that year. 
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 5-5: Establishment Births and Deaths, Five-Year Annual Average: 

1998–2003 

Industry Sector Net Change Births Deaths 

Water Transportation Industry 

Deep Sea, Coastal, and Great Lakes Water 

Transportation -19.0 122.8 141.8 

Inland Water Transportation 4.8 67.7 62.8 

Scenic and Sightseeing Transportation, Water -13.7 171.5 185.2 

Support Activities for Water Transportation -24.5 203.0 227.5 

Water Transportation Industry Average -13.3 141.3 154.3 

Fishing Industry 

Fishing 1.7 227.3 225.7 

Mining Industry 

Support Activities for Mininga 45.5 985.0 939.5 

a Data were only available for NAICS 213 (Support Activities for Mining) and were not available at 

the 6-digit NAICS level. The 2002 Economic Census reports 9,104 establishments in NAICS 213. 

Source: U.S. SBA, 2004 

Table 5-6 summarizes the net change in employment (difference between births and deaths) for each industry 

sector for which these data are available. Specific information on job creation and elimination was not available 

for many industry sectors. 

Of the water transportation industry sectors, deep sea, coastal, and Great Lakes water transportation averaged the 

largest change in employment per year, with an average of 665 jobs eliminated per year. Scenic and sightseeing 

transportation also averaged more than 500 jobs eliminated per year between 1998 and 2003. Inland water 

transportation and support activities for water transportation averaged net job creation rates of 136 and 156 

employees per year, respectively. 

The fishing industry averaged a reduction of 130 jobs per year over the same period whereas the support activities 

for mining sector (NAICS 213) averaged an increase of nearly 3,095 jobs per year. According to the 2002 

Economic Census, the drilling oil and gas wells sector (NAICS 213111) accounts for about a third of paid 

employees reported overall in the support activities for mining sector (NAICS 213) (60,450 paid employees as 

compared to 181,199 paid employees). 

Table 5-6: Net Change in Employment: Five-Year Annual Average, 1998-

2003

Industry Sector Net Change 

Water Transportation Industry 

Deep Sea, Coastal, and Great Lakes Water Transportation -665.0 

Inland Water Transportation 136.4 

Scenic and Sightseeing Transportation, Water -517.0 

Support Activities for Water Transportation 156.2 

Water Transportation Industry Average -222.4 

Fishing Industry 

Fishing -129.4 

Mining Industry 

Support Activities for Mininga 3,094.7 

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

at the 6-digit NAICS level. The number of paid employees reported for NAICS 213 in the 2002 

Economic Census is 181,199. 

Source: U.S. SBA, 2004 

December 18, 2008 Final 23
Economic and Benefits Analysis of the Final Vessel General Permit 

5.3.4 Financial Performance 

Overall, the water transportation industry experienced growth of almost 4 percent over the period 1997–2002 (see 

Table 5-7), which is less robust than the overall U.S. economy’s growth of nearly 25 percent during this period 

(U.S. Bureau of Economic Analysis, 2007). There was much variability in the performance of the various industry 

sectors, with revenues dropping by 41 percent in deep sea freight transportation and by 37 percent in inland 

waterways freight transportation. 

Conversely, deep sea passenger transportation, which encompasses cruise ships, posted the strongest growth 

throughout this period, more than doubling revenues in the five years from 1997 to 2002. Revenues for inland 

waterways passenger transportation also increased by 22 percent over this period. 

Revenues from freight and passenger transportation in the Great Lakes increased by 20 percent and 17 percent, 

respectively. 

In the fishing industry, revenues declined by nearly 5 percent over the same period. Fishing industry data are from 

the U.S. Small Business Administration because they are not included in the Economic Census. 

The drilling oil and gas wells sector experienced an increase of 24.3 percent over the same period. 

Table 5-7: Revenues by Industry Sector, 1997 and 2002 

Industry Sector 

1997 

($ millions) 

2002 

($ millions) 

Percent 

Change 

Water Transportation Industry 

Deep Sea, Coastal, and Great Lakes Water Transportation 

Deep Sea Freight Transportation 11,571 6,731 -41.8% 

Deep Sea Passenger Transportation 3,908 8,081 106.8% 

Coastal and Great Lakes Freight Transportation 4,678 5,607 19.9% 

Coastal and Great Lakes Passenger Transportation 182 212 16.6% 

Subtotal-Deep Sea, Coastal, and Great Lakes 20,339 20,631 1.4% 

Inland Water Transportation 

Inland Waterways Freight Transportation 3,387 2,134 -37.0% 

Inland Waterways Passenger Transportation 293 359 22.3% 

Subtotal-Inland 3,680 2,493 -32.3% 

Scenic and Sightseeing Transportation, Water 

Scenic and Sightseeing Transportation, Water 1,129 964 -14.6% 

Support Activities for Water Transportation 

Port and Harbor Operations 889 1,463 64.5% 

Marine Cargo Handling 4,456 4,748 6.5% 

Navigational Services to Shipping and Salvage 1,513 2,150 42.1% 

Other Support Activities for Water Transportation 656 1,441 119.6% 

Subtotal-Support activities 7,515 9,801 30.4% 

TOTAL-Water Transportation 32,663 33,890 3.8% 

Fishing Industry 

Fishinga 1,739 1,655 -4.8% 

Mining Industry 

Drilling oil & gas wells sector 7,298 9,069 24.3% 

Source: U.S. Census Bureau, 1997, 2002b; U.S. SBA, 1997, 2002b 

a 1997 Fishing revenue data according to SIC code, which also included plant aquaculture. Percent 

change is thus exaggerated.

December 18, 2008 Final 24
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 25

5.4 Industry Market Structure 

The water transportation and fishing industries, and the drilling oil and gas wells segment of the mining industry 

are comprised of a large number of small businesses, whether classified by employment size or by annual 

revenues. The vast majorities of firms in these industries employ fewer than 100 people and earn revenues of less 

than $1 million per year. 

This large concentration of small firms earning relatively low amounts of revenue may make the water 

transportation and fishing industries, and the drilling oil and gas wells segment of the mining industry more 

sensitive to changes in operating costs. 

5.4.1 Firms and Revenues 

Table 5-8 details the number of firms and revenues by employment size in 2002. In the water transportation 

industry, 56 percent of firms employ fewer than 20 people, though these firms only account for 7 percent of the 

industry’s revenue. Large firms employing more than 500 people, on the other hand, account for only 1 percent of 

businesses in the industry, but earn nearly half of its revenue. 

The fishing industry also contains a large percentage of firms employing fewer than 20 people (60 percent), 

though in this industry they account for a larger share of total industry revenue (36 percent). The large firms in the 

fishing industry account for less than 1 percent of total firms, and earn 15 percent of the industry’s revenue. 

The drilling oil and gas wells sector contains an even larger percentage of firms employing fewer than 20 people 

(72 percent) but these firms account for a much smaller share of total industry revenue (11 percent). The large 

firms in this sector account for approximately 2 percent of total firms, and earn 50 percent of the sector’s revenue. 

Firms not operating the entire year do not report employment data, and are classified under “NR” in the table. 

There are large numbers of these in both the water transportation and fishing industries, and about 11 percent in 

the drilling oil and gas wells sector.
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 5-8: Firms and Revenues by Employment Size, 2002

Number of Firms Revenues ($ m

 Number of Employees 1-19 20-99 100-499 500+ NR 1-19 20-99 100-499 Water Transportation Deep Sea, Coastal, and Great Lakes Water Transportation 

Deep Sea Freight Transportation 127 42 20 6 35 $478 $1,492 $2,636 Deep Sea Passenger Transportation 52 8 6 4 13 $63 $57 $461 Coastal and Great Lakes Freight Transportation 274 108 40 8 64 $468 $802 $1,904 Coastal and Great Lakes Passenger Transportation 46 21 5 1 36 $39 $116 $0 Subtotal-Deep Sea, Coastal, Great Lakes 493 174 69 17 148 $959 $2,411 $5,084 

Inland Water Transportation 

Inland Waterways Freight Transportation 148 53 29 6 66 $66 $379 $1,019 Inland Waterways Passenger Transportation 138 24 6 0 63 $304 $88 $0 Subtotal-Inland 286 77 35 6 129 $194 $468 $1,220 

Scenic and Sightseeing Transportation, Water 

Scenic and Sightseeing Transportation, Water 882 112 10 2 708 $304 $332 $103 

Support Activities for Water Transportation 

Port and Harbor Operations 95 29 15 1 26 $141 $296 $0 Marine Cargo Handling 175 85 37 17 55 $202 $623 $890 Navigational Services to Shipping and Salvage 461 85 23 1 117 $396 $588 $299 Other Support Activities for Water Transportation 467 93 14 5 106 $233 $425 $350 Subtotal-Support activities 1,198 292 89 24 304 $937 $1,806 $2,150 

TOTAL-Water Transportation 2,859 655 203 49 1,289 $2,395 $5,016 $8,557 Percentage of Industry 56% 13% 4% 1% 25% 7% 15% 26% Fishing 

Fishing 1145 41 12 7 696 $593 $309 $327 

Percentage of Industry 60% 2% 0.6% 0.4% 37% 36% 19% 20% Mining Industry 

Drilling oil & gas wells sector 1,084 178 44 34 164 554 957 995 

Percentage of Sector 72% 12% 3% 2% 11% 11% 19% 20% Source: U.S. Census Bureau, 2002b; U.S. SBA, 2002a 

December 18, 2008 Final 
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 5-9 details the number of firms according to annual revenue in each sector of the water transportation, 

fishing, and mining industries. In the water transportation industry, firms earning less than $1 million per year 

account for 65 percent of the industry’s firms, and firms earning between $1 and $5 million add another 21 

percent. A large majority (86 percent) of firms are thus earning revenues less than $5 million. 

In the fishing industry, this trait is even more pronounced, with 90 percent of all firms earning less than $1 million 

in revenues, and 99 percent earning less than $5 million. 

In the drilling oil and gas wells segment of the mining industry, 77 percent of all firms earn less then $1 million in 

revenues and approximately 95 percent earn less than $5 million. 

Table 5-9: Number of Firms According to Revenue Size

 Number of Firms 

Revenues (millions of dollars) <1 1-5 5-25 25-100 100+ 

Water Transportation 

Deep Sea, Coastal, and Great Lakes Water Transportation 

Deep Sea Freight Transportation 67 50 36 23 19 

Deep Sea Passenger Transportation 34 22 5 3 6 

Coastal and Great Lakes Freight Transportation 212 108 71 29 10 

Coastal and Great Lakes Passenger Transportation 36 22 14 1 0 

Subtotal-Deep Sea, Coastal, and Great Lakes 349 202 126 56 35 

Inland Water Transportation 

Inland Waterways Freight Transportation 115 59 37 18 7 

Inland Waterways Passenger Transportation 124 33 8 3 0 

Subtotal-Inland 239 92 45 21 7 

Scenic and Sightseeing Transportation, Water 

Scenic and Sightseeing Transportation, Water 851 122 30 3 0 

Support Activities for Water Transportation 

Port and Harbor Operations 61 43 27 6 3 

Marine Cargo Handling 133 96 56 18 11 

Navigational Services to Shipping and Salvage 384 119 53 13 1 

Other Support Activities for Water Transportation 423 108 38 7 3 

Subtotal-Support 1001 366 174 44 18 

TOTAL-Water Transportation 2440 782 375 124 60 

Percentage of Industry 65% 21% 10% 3% 2% 

Fishing Industry 

Fishing 1674 169 26 13 10 

Percentage of Industry 90% 9.0% 1.4% 0.7% 0.5% 

Mining Industry 

Drilling oil & gas wells sector 1,087 251 72 12 32 

Percentage of Sector 77% 18% 5% 1% 2% 

Source: U.S. Census Bureau 2002b; U.S. SBA, 2002b 

5.4.2 Small Businesses 

The U.S. SBA defines small businesses for the various sectors of these industries as follows: 

3⁄4 Deep sea, coastal, and Great Lakes water transportation; inland water transportation – fewer than 500 

employees 

3⁄4 Scenic and sightseeing transportation; navigational services to shipping and salvage; other support 

activities for water transportation – revenues less than $7 million 

3⁄4 Port and harbor operations; marine cargo handling – revenues less than $25.5 million 

December 18, 2008 Final 27
Economic and Benefits Analysis of the Final Vessel General Permit 

3⁄4 Fishing – revenues less than $4 million 

3⁄4 Drilling oil and gas wells sector – fewer than 500 employees (U.S. SBA, 2008). 

Table 5-10 summarizes the number of small businesses in each sector of the water transportation, fishing, and 

mining industries. On the whole, all industries contain more than 90 percent small businesses. Inland waterways 

freight transportation, the industry sector encompassing barges, has the lowest number of small businesses, which 

may also contribute to its high number of vessels per establishment. 

These percentages were calculated based on the number of firms operating the entire year, as employment figures 

are not available for firms operating only part of the year. 

Table 5-10: Small Businesses by Industry Sector 

Industry Sector 

Small Business 

Threshold 

Firms 

Operated 

Entire Year

Small 

Businesses 

Percent 

Small 

Business 

Water Transportation Industry 

Deep Sea, Coastal, and Great Lakes Water Transportation 

Deep Sea Freight Transportation 500 Employees 195 189 96.9% 

Deep Sea Passenger Transportation 500 Employees 70 66 94.3% 

Coastal and Great Lakes Freight Transportation 500 Employees 430 422 98.1% 

Coastal and Great Lakes Passenger Transportation 500 Employees 73 72 98.6% 

Subtotal-Deep Sea, Coastal, and Great Lakes 768 749 97.5% 

Inland Water Transportation 

Inland Waterways Freight Transportation 500 Employees 278 230 82.7% 

Inland Waterways Passenger Transportation 500 Employees 168 168 100.0% 

Subtotal-Inland 446 398 89.2% 

Scenic and Sightseeing Transportation, Water 

Scenic and Sightseeing Transportation, Water $7 million 1006 989 98.3% 

Support Activities for Water Transportation 

Port and Harbor Operations $25.5 million 140 131 93.6% 

Marine Cargo Handling $25.5 million 314 285 90.8% 

Navigational Services to Shipping and Salvage $7 million 570 526 92.3% 

Other Support Activities for Water Transportation $7 million 579 545 94.1% 

Subtotal-Support Activities 1603 1487 92.8% 

TOTAL-Water Transportation 5037 4770 94.3% 

Fishing Industry 

Fishing $4 million 1916 1843 96.2% 

Mining Industry 

Drilling oil & gas wells sector 500 Employees 1504 1470 97.7% 

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

5.4.3 Employment and Payroll 

Employment in the water transportation and fishing industries declined over the period between 1997 and 2002, 

by 8 percent and 9 percent, respectively (see Table 5-11). However, payroll in both industries managed to increase 

despite this decline in employment numbers. The only exception is the marine cargo handling sector, where 

payroll dropped by 25 percent. Employment and payroll in the drilling oil and gas wells sector increased by 

14 percent and 31 percent, respectively, over the same period. 

In all industry sectors where employment and payroll both decreased, changes in payroll were less extreme than 

changes in employment, implying that the employees remaining in the industry saw an increase in the average 

December 18, 2008 Final 28
Economic and Benefits Analysis of the Final Vessel General Permit 

salary. The only exception is the marine cargo handling sector, where payroll dropped by 25 percent while 

employment dropped by 22 percent. 

Total Number of Employees by Industry Sector 

In 2002, the water transportation industry employed about 146,000 people. Nearly half of these people were 

employed by businesses providing support activities for water transportation. Another third worked in the deep 

sea, coastal, and Great Lakes water transportation sector, with the remaining 20 percent being split almost evenly 

between inland water transportation and scenic and sightseeing transportation on water. The fishing industry 

employed about 6,500 people in 2002, while the drilling oil and gas wells employed about 60,500 people. 

Overall, the water transportation industry saw an 8.2 percent decline in its number of employees between 1997 

and 2002. The fishing industry experienced a similar decline in employment of 9.3 percent. This contrasts with 

the increase in employment of 14.4 percent in the drilling oil and gas wells sector and the overall 6.7 percent 

increase in employment in the U.S. economy (U.S. SBA, 2004). 

The largest drops in employment numbers came in deep sea freight transportation and inland waterways freight 

transportation, industry sectors that also experienced revenue declines over this period. Scenic and sightseeing 

transportation on water, which also experienced a decline in revenue, had a milder decrease of 18.5 percent in 

employment. 

Despite its strong performance in terms of revenues, deep sea passenger transportation employed 6.3 percent 

fewer people in 2002 than in 1997. 

The strongest growth in employment came from other support activities for water transportation, which more than 

doubled its number of employees between 1997 and 2002. This sector now accounts for nearly 9 percent of all 

employees in the water transportation industry. 

Table 5-11: Employment by Industry Sector, 1997-2002 

Meaning of 2002 NAICS code 

1997 Number of 

Employees 

2002 Number of 

Employees 

Percent 

Change 

Water Transportation Industry 

Deep Sea, Coastal, and Great Lakes Water Transportation

Deep Sea Freight Transportation 18,542 13,803 -25.6% 

Deep Sea Passenger Transportation 12,266 11,491 -6.3% 

Coastal and Great Lakes Freight Transportation 21,690 24,333 12.2% 

Coastal and Great Lakes Passenger Transportation 1,802 2,382 32.2% 

Subtotal-Deep Sea, Coastal, and Great Lakes 54,300 52,009 -4.2% 

Inland Water Transportation 

Inland Waterways Freight transportation 15,663 10,040 -35.9% 

Inland Waterways Passenger Transportation 2,894 3,277 13.2% 

Subtotal-Inland 18,557 13,317 -28.2% 

Scenic and Sightseeing Transportation, Water 

Scenic and Sightseeing Transportation, Water 14,185 11,557 -18.5% 

Support Activities for Water Transportation 

Port and Harbor Operations 6,802 5,593 -17.8% 

Marine Cargo Handling 48,463 37,707 -22.2% 

Navigational Services to Shipping and Salvage 10,800 13,157 21.8% 

Other Support Activities for Water Transportation 6,415 13,112 104.4% 

Subtotal-Support activities 72,480 69,569 -4.0% 

TOTAL-Water Transportation 159,522 146,452 -8.2% 

December 18, 2008 Final 29
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 30

Table 5-11: Employment by Industry Sector, 1997-2002 

Meaning of 2002 NAICS code 

1997 Number of 

Employees 

2002 Number of 

Employees 

Percent 

Change 

Fishing Industry 

Fishing 7,206 6,537 -9.3% 

Mining Industry 

Drilling oil & gas wells sector 52,858 60,450 14.4% 

Source: U.S. Census Bureau, 1997, 1998, 2002a, 2002b 

 

Payroll by Industry Sector 

Despite the decreases in employment between 1997 and 2002, payroll in the water transportation and fishing 

industries rose by 3 percent and 0.2 percent, respectively, over the same period (see Table 5-12). The drilling oil 

and gas wells sector saw increases in both employment and payroll, with payroll increasing by 31.0 percent. 

In general, those sectors that experienced a decline in employment also saw lower payrolls. Two notable 

exceptions are deep sea passenger transportation, which increased its payroll by 17 percent while having 6 percent 

fewer employees, and port and harbor operations, which saw a mild 2.5 percent increase in payroll while 

employment declined by nearly 18 percent. 

The fishing industry’s payroll rose by a modest 0.2 percent, despite a relatively large 9.3 percent decrease in its 

employment base. 

Table 5-12: Payroll by Industry Sector, 1997-2002 

Industry Sector 

1997 Annual 

Payroll 

($ millions) 

2002 Annual 

Payroll 

($ millions) Percent Change 

Water Transportation Industry 

Deep Sea, Coastal, and Great Lakes Water Transportation 

Deep Sea Freight Transportation $842 $735 -12.7% 

Deep Sea Passenger Transportation $380 $445 16.9% 

Coastal and Great Lakes Freight Transportation $925 $1,189 28.4% 

Coastal and Great Lakes Passenger Transportation $50 $69 37.9% 

Subtotal-Deep sea, Coastal, and Great Lakes $2,198 $2,438 10.9% 

Inland Water Transportation 

Inland Waterways Freight Transportation $552 $482 -12.8% 

Inland Waterways Passenger Transportation $84 $112 33.8% 

Subtotal-Inland $637 $594 -6.6% 

Scenic and Sightseeing Transportation, Water 

Scenic and Sightseeing Transportation, Water $283 $267 -5.7% 

Support Activities for Water Transportation 

Port and Harbor Operations $238 $244 2.5% 

Marine Cargo Handling $1,941 $1,452 -25.2% 

Navigational Services to Shipping and Salvage $377 $577 53.2% 

Other Support Activities for Water Transportation $207 $491 136.9% 

Subtotal-Support activities $2,763 $2,764 0.03% 

TOTAL-Water Transportation $5,880 $6,063 3.1% 
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 31

Table 5-12: Payroll by Industry Sector, 1997-2002 

Industry Sector 

1997 Annual 

Payroll 

($ millions) 

2002 Annual 

Payroll 

($ millions) Percent Change 

Fishing Industry 

Fishing $252 $253 0.2% 

Mining Industry 

Drilling oil & gas wells sector $1,901 $2,491 31.0% 

Source: U.S. Census Bureau, 1997, 1998, 2002a, 2002b 
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 32

6 Cost of Best Management Practices 

6.1 Summary 

The first step in assessing costs of the new NPDES permitting requirements was determining the population of 

vessels that will be affected by the Permit. As detailed in Section 3, the total population of domestic vessels is 

61,06915, and the total population of foreign vessels is 7,927.16 NPDES requirements for discharges incidental to 

the normal operation of a vessel will impact virtually every non-military vessel in use in a capacity of 

transportation entering U.S. territorial waters. However, some vessels will be subject only to certain BMPs 

because some discharges are not applicable to all vessel types. For example, practices associated with graywater 

discharges are not applicable to barges since this vessel class does not produce this type of discharge. Practices 

associated with aqueous film-forming foam (AFFF) discharges are only applicable to some utility vessels and to 

freight and tank ships since other vessel classes do not have a firefighting system. 

To estimate the effect of the Permit on the industry as a whole, a baseline must be identified from which to 

measure this effect. The baseline takes into account previous conditions and determines how the industry would 

act in the future in the absence of the Permit. The baseline for this analysis is full industry compliance with 

existing federal and state regulations; and current industry practices or standards that exceed current regulations to 

the extent that they can be empirically observed. 

A number of laws and associated regulations (including NISA; APPS; the Comprehensive Environmental 

Response, Compensation, and Liability Act; the Organotin Anti-fouling Paint Control Act; and others) already 

cover certain discharges that would be subject to the new permitting regime. In analyzing economic impacts of the 

Vessel Vacatur of the NPDES requirements, EPA has assumed that the entities subject to existing regulations will 

not incur significant incremental costs. 

The second step in assessing costs of the new NPDES permitting requirements is establishing per-vessel (or perfirm) costs for each BMP. The majority of these costs are derived from industry communication and survey 

responses. Additional cost inputs are also derived from manufacturers, field experts, and the NBIC database for 

the ballast water cost analysis. Per-vessel costs are established for the BMP categories in which vessels are 

expected to incur incremental costs. The annual per-vessel cost of each BMP is estimated based on the perinstance cost of performing each practice the number of times per year the BMP needs to be performed. 

Several BMP categories were not analyzed for incremental costs because (1) the industry is already practicing 

these BMPs or (2) the expected cost of the relevant BMP is negligible. 

Finally, the total annual cost per BMP category is estimated by multiplying the BMP cost per vessel by the 

number of vessels expected to incur incremental costs due to the Permit requirements. 

6.2 Cost of Individual BMPs 

Most of the BMPs involve a change in customary operating practices and additional labor hours. For these BMPs, 

EPA has used labor rates and hourly estimates provided by the questionnaire responses to estimate the total cost 

for the specific BMP. If any of the BMPs have more specific requirements (e.g., involving equipment purchase 

 

15 There are 28,875 commercial fishing vessels within the vessel databases. However, only 26 of these vessels actual incur costs due to 

ballast water exchange/flushing requirements. 

16 Due to congressional action that took place in July 2008 (Senate bill S. 2766 and 3298, described in Section 2.1), the estimated vessel 

universe covered by the final VGP decreased from the proposed VGP. This final VGP economic analysis reflects this smaller universe of 

vessels. 
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 33

and use) these costs have also been added to the labor-based cost estimates. Most of the cost estimates for the 

individual BMPs are dependent upon industry communications; some are also derived from outside research as 

well as additional data sources. EPA contacted four industry associations for information regarding population 

estimates, current practices, and estimated costs.17 The four industries contacted represent (1) passenger vessels, 

(2) towing vessels and barges, (3) freight and tank ships, and (4) cruise ships. The population of vessels that are 

subject to each BMP within a discharge category is dependent upon the type of vessel and whether certain vessels 

already practice the BMPs required by the Permit. Personnel from different industry organizations provided 

information regarding which discharge categories were applicable to their member vessel types. Every category of 

vessel is accounted for by an industry representative. Furthermore, survey responses have determined the 

percentage of vessels that already practice a specific BMP requirement within all discharge categories. 

The following analysis of BMP costs (including per vessel cost and the population of vessels expected to incur 

additional costs) relies on industry survey responses and additional information from manufacturers and field 

experts. Appendix A provides a copy of the questionnaire administered to the industry representatives. Appendix 

B summarizes industry responses. 

6.2.1 Discharges of Deck Washdown and Runoff and Above Water Line Hull Cleaning 

Affected Vessel Population 

Based on the description of practices within this discharge category, deck washdown and runoff is potentially 

applicable to 61,043 vessels.18 

Based on review of public comment documents from the June 2007 EPA information request and preliminary 

survey responses sent out for this economic analysis, vessels already generally practice the BMPs listed below. 

The American Waterways Operators, an industry organization representing barges and towing vessels, provided 

information regarding vessel practices within the public comments. All their member tank barges currently use 

drip pans on machinery, and all perform drip pan cleaning and/or draining. Furthermore, towing vessels currently 

clear decks of debris, garbage, residue, and spills before conducting deck washdowns, and all currently use 

environmentally friendly cleaners. Additionally, based on preliminary responses from industry representatives, 

most deck runoff BMPs are already practiced by other vessels: (1) deck cleanup is currently performed prior to 

deck washdowns, and (2) passenger vessels are assumed to practice deck cleanup prior to departing from port. 

However, most towing vessel/barge companies responded that it is not as common to perform deck cleanup prior 

to departing from port. 

The population potentially affected by BMPs applicable to the deck runoff discharge category is shown in Table 

6-1. Note that utility vessels include the 131 MODUs operating within the drilling oil and gas wells sector of the 

mining industry. 

 

17 EPA also contacted the commercial fishing industry for information necessary for the proposal Economic Analysis. However, since 

commercial fishing vessels are not subject to the final Permit (except for ballast water requirements, for which information was gathered 

from the NBIC database and not from industry surveys), the commercial fishing industry responses are not included within this final 

Economic Analysis. 

18 The total excludes the 26 commercial fishing vessels. 
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 6-1: Vessel Counts for BMPs Applicable to Deck Runoff 

Vessel Class Vessel Count 

Freight Barges 32,842 

Freight Ships 697 

Passenger Vessels 11,521 

Tank Barges 4,944 

Tank Ships 147 

Utility Vessels 10,892 

TOTAL 61,043 

Permit Requirements 

Permit Text: 

Vessel owner/operators must minimize the introduction of on-deck debris, garbage, residue and spill into deck 

washdown and runoff discharges. When required by their class societies (e.g., oil tankers),their flag 

Administrations, or the U.S. Coast Guard, vessels must be fitted with and use perimeter spill rails and scuppers to 

collect the runoff for treatment. Where feasible, machinery on deck must have coamings or drip pans to collect 

any oily water from machinery and prevent spills. The drip pans must be drained to a waste container for proper 

disposal and/or periodically wiped and cleaned. The presence of floating solids, visible foam, halogenated phenol 

compounds, and dispersants, or surfactants in deck washdowns must be minimized. Vessel operators must 

minimize deck washdowns while in port. 

Vessel operators must maintain their topside surface and other above water line portions of the vessel to minimize 

the discharge of rust (and other corrosion by-products), cleaning compounds, paint chips, non-skid material 

fragments, and other materials associated with exterior topside surface preservation. Furthermore, vessel 

owner/operators must minimize residual paint droplets from entering waters subject to this permit whenever they 

are conducting touch-up painting. Possible minimization techniques include, but are not limited to, avoiding paint 

spraying in windy conditions or avoiding overapplication of paint. This permit does not authorize the disposal of 

unused paint into waters subject to this permit. 

If deck washdowns or above water line hull cleaning will result in a discharge, they must be conducted with nontoxic and phosphate free cleaners and detergents. Furthermore, cleaners and detergents should not be caustic or 

only minimally caustic and should be biodegradable. 

Estimates of Cost 

Preliminary responses from industry representatives determined that deck cleanup is currently performed prior to 

deck washdowns. Also, based on the survey responses, passenger vessels are assumed to practice deck cleanup 

prior to departing from port, while most towing vessel/barge companies responded that it is not as common to 

perform deck cleanup prior to departing from port. Thus, EPA determined that all vessel classes except passenger 

vessels will incur this cost. However, since this cleanup is practiced but only for a percentage of departures, the 

incremental cost is only incurred for a small percentage of these vessels’ departures from port. The baseline 

assumptions detail the percentages used. 

EPA has assumed that performing cleanup before a deck washdown takes significantly more time as compared to 

performing cleanup prior to departing from port. Cleanup prior to a deck washdown would entail moving all 

pieces of machinery and cargo so as to clean the entire deck. However, cleanup prior to departing from port would 

only require clearing loose items from the deck. Survey responses indicated a wide range of cleanup time 

necessary prior to conducting a deck washdown: from 1 to 6 hours. EPA has estimated that it would only take 30 

minutes to perform cleanup prior to departing from port. In the sensitivity analysis, the Agency estimated a 

December 18, 2008 Final 34
Economic and Benefits Analysis of the Final Vessel General Permit 

potential low and high incremental cost associated with deck cleanup prior to departing from port. These low and 

high estimates are based upon the percentage of departures from port prior to which a vessel performs deck 

cleanup. 

Survey responses also determined that it is common for all vessels to have drip pans installed for every piece of 

machinery on deck. However, there may be a small population of older vessels that need to install drip pans. It is 

also common practice for vessels to perform regular drip pan cleaning and/or draining. However, EPA did receive 

one response from a towing vessel/barge company that stated that it “rarely” performs drip pan cleaning. Thus, 

the Agency performed a sensitivity analysis to examine the potential cost to older vessels that may have to install 

drip pans and for those that may need to perform cleaning and/or draining. 

Furthermore, based upon online research of these products and communication with a manufacturer, EPA has 

found that the incremental cost of purchasing a gallon of non-/low-phosphorus cleaner compared to standard 

cleaners is negligible due to the variability among cleaners. There are varied prices among high- and low-end 

products. However, there is enough variability among prices that a vessel could opt for a standard non-/lowphosphorus cleaner in lieu of a high-end phosphorus cleaner. 

Sensitivity Analysis 

The cost input values are shown in Table 6-2, and the estimates/assumptions derived for each practice are 

described below. 

Table 6-2: Per-Vessel Costs for BMPs Associated with Deck Runoff 

BMP Labor Hours Unit Cost Cost Description 

Performing deck cleanup prior to departing 

from port 0.5 $8.27a Per Instance 

Draining and/or wiping and cleaning the drip 

pans or coamings 1.5 $424.80b Per Instance 

Installing drip pans or coamings for every piece 

of machinery on deck N/A $161.17 

Annualized Cost of a One-time 

Installation 

a Unit cost is estimated by multiplying the labor hours by the average hourly labor rate of $16.53. 

b Includes additional cost of $400 per instance to dispose of drip pan waste. 

3⁄4 Deck Cleanup

à Average Labor Hours: Since most towing vessel/barge companies estimated a per-instance 

cleanup time within the range of 1 to 6 hours, EPA has taken the median of 3.5 hours to estimate 

the time it would take to perform deck cleanup prior to conducting a deck washdown. However, 

the time requirement to perform cleanup prior to departing from port is assumed to be 

significantly less: around 30 minutes. 

à Average Labor Rate: A weighted average labor rate of $16.53 was calculated from the industry 

responses from the towing vessel/barge companies. The same labor rate is applied to all other 

vessel classes except for passenger vessels, which are assumed to already perform cleanup prior 

to departing from port. Appendix B summarizes the industry responses regarding labor rates. 

à Annual Number of Instances: The number of times that a vessel departs from port ranges from 4 

to 30 times per month. EPA has estimated an average of 15 times per month, thus 180 times per 

year. 

à Baseline: 

— Low End Assumption: Deck cleanup prior to departing from port is currently practiced 

100 percent of the time by passenger vessels and 95 percent of the time for all other 

vessel classes. 

December 18, 2008 Final 35
Economic and Benefits Analysis of the Final Vessel General Permit 

— High End Assumption: Deck cleanup prior to departing from port is currently practiced 

100 percent of the time by passenger vessels and 90 percent of the time for all other 

vessel classes. 

3⁄4 Drip Pan Cleaning

à Average Labor Hours: Preliminary industry responses provided an estimate of 1 to 2 hours 

required per instance of cleaning. EPA has taken the average of 1.5 hours. 

à Average Labor Rate: The same weighted average labor rate of $16.53 was calculated from the 

industry responses from the towing vessel/barge companies. The same labor rate is applied to all 

other vessel classes. This BMP is assumed not to be applicable to passenger vessels. Appendix B 

summarizes the industry responses regarding labor rates. 

à Additional Cost: Most survey respondents provided an additional cost for drip pan waste disposal 

ranging from $200 to $1,200 per instance. EPA estimated an additional average cost per instance 

of $400. 

à Annual Number of Instances: The number of times that a vessel cleans and/or drains its drip pans 

ranges from 1 to 4 times per month. EPA estimated an average of 2 times per month, thus 24 

times per year. 

à Baseline: 

— Low End Assumption: Drip pan cleaning is currently practiced 100 percent of the time. 

— High End Assumption: Drip pan cleaning is currently practiced 99 percent of the time. 

3⁄4 Installation of Drip Pans/Coamings

à One-time Installation Cost: Preliminary industry responses provided ranges for the total one-time 

cost per installation estimate for all machinery on deck of $500 to $8,000. EPA has estimated an 

average one-time cost of $2,000. Annualized over 30 years at a 7 percent discount rate, the cost is 

$161.17. 

à Baseline: 

— Low End Assumption: 100 percent of vessels already have drip pans/coamings installed. 

— High End Assumption: 99 percent of vessels already have drip pans/coamings installed. 

EPA is assuming that older vessels may need to install drip pans. Thus, the remaining 1 

percent of vessels may incur this incremental cost. 

The cost per vessel for each BMP and the total cost associated with all vessels is listed in Table 6-3. At the low 

end, approximately $3.7 million is a potential annual incremental cost. At the high end, approximately $12.5 

million is a potential annual incremental cost. 

Table 6-3: Deck Runoff Sensitivity Analysis 

Vessel Class Vessel Count 

% Vessels 

Applicable to BMP 

Annual Cost 

per Vessela Total Annual Cost 

Low End Estimate 

Deck Cleanup 

Freight Barges 32,842 100% $74.40 $2,443,361 

Freight Ships 697 100% $74.40 $51,855 

Passenger Vessels 11,521 0% $0.00 $0 

Tank Barges 4,944 100% $74.40 $367,821 

Tank Ships 147 100% $74.40 $10,936 

Utility Vessels 10,892 100% $74.40 $810,337 

December 18, 2008 Final 36
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 6-3: Deck Runoff Sensitivity Analysis 

Vessel Class Vessel Count 

% Vessels 

Applicable to BMP 

Annual Cost 

per Vessela Total Annual Cost 

Deck Cleanup TOTAL 61,043 $3,684,310 

Drip Pan Cleaning TOTAL 61,043 100% $0.00 $0

Installation of Drip Pans/Coamings TOTAL 61,043 100% $0.00 $0

Low End TOTAL $3,684.310 

High End Estimate 

Deck Cleanup 

Freight Barges 32,842 100% $148.79 $4,886,722 

Freight Ships 697 100% $148.79 $103,710 

Passenger Vessels 11,521 0% $0.00 $0 

Tank Barges 4,944 100% $148.79 $735,642 

Tank Ships 147 100% $148.79 $21,873 

Utility Vessels 10,892 100% $148.79 $1,620,674 

Deck Cleanup TOTAL 61,043 $7,368,620 

Drip Pan Cleaning 

Freight Barges 32,842 100% $101.95 $3,348,301 

Freight Ships 697 100% $101.95 $71,060 

Passenger Vessels 11,521 0% $0.00 $0 

Tank Barges 4,944 100% $101.95 $504,050 

Tank Ships 147 100% $101.95 $14,987 

Utility Vessels 10,892 100% $101.95 $1,110,459 

Drip Pan Cleaning TOTAL 61,043 $5,048,857 

Installation of Drip Pans/Coamings 

Freight Barges 32,842 1% $161.17 $52,932 

Freight Ships 697 1% $161.17 $1,123 

Passenger Vessels 11,521 0% $0.00 $0 

Tank Barges 4,944 1% $161.17 $7,968 

Tank Ships 147 1% $161.17 $237 

Utility Vessels 10,892 1% $161.17 $17,555 

Installation of Drip Pans/Coamings TOTAL 61,043 $79,816 

High End TOTAL $12,497,293 

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

6.2.2 Discharges of Bilgewater 

Affected Vessel Population 

There is overlap in this discharge category between the Permit and existing regulations: the Act to Prevent 

Pollution from Ships (APPS) 33 CFR 155.310-380, 33CFR155.410-440, 33 CFR151.10, and section 311 of the 

Clean Water Act. The vessel population that applies to this Permit is already in compliance since all vessels are 

covered under these existing regulations. Thus, there is no incremental cost under this Permit for these discharge 

category BMPs. 

December 18, 2008 Final 37
Economic and Benefits Analysis of the Final Vessel General Permit 

Permit Requirements 

Permit Text: 

All bilgewater discharges must be in compliance with the regulations in 40 CFR Parts 110 (Discharge of Oil), 

116 (Designation of Hazardous Substances), and 117 (Determination of Reportable Quantities for Hazardous 

Substances) and 33 CFR §151.10 (Control of Oil Discharges). In addition: 

3⁄4 Vessel operators may not use dispersants, detergents, emulsifiers, chemicals or other substances to 

remove the appearance of a visible sheen in their bilgewater discharges. 

3⁄4 Except in the case of flocculants or other required additives (excluding any dispersants or surfactants) 

used to enhance oil/water separation during processing (after bilgewater has been removed from the 

bilge), vessel operators may not add substances that drain to the bilgewater that are not produced in the 

normal operation of a vessel. The use of oil solidifiers, flocculants, or other required additives are 

allowed only as part of an oil water separation system provided they do not alter the chemical make-up of 

the oils being discharged and they are not discharged into waters subject to this permit. Routine cleaning 

and maintenance activities associated with vessel equipment and structures are considered to be normal 

operation of a vessel if those practices fall within normal marine practice. 

3⁄4 All vessels must minimize the discharge of bilgewater into waters subject to this permit. This can be done 

by minimizing the production of bilgewater, disposing of bilgewater on shore where adequate facilities 

exist, or discharging into waters not subject to this permit (i.e., more than 3 nautical miles (nm) from 

shore) for vessels that regularly travel into such waters. Though not regulated under this permit, EPA 

notes that discharges of bilgewater outside waters subject to this permit (i.e. more than 3 nm from shore) 

are regulated under Annex I of the International Convention for the Prevention of Pollution from Ships as 

implemented by the Act to Prevent Pollution from Ships and U.S. Coast Guard regulations found in 33 

CFR 151.09. 

3⁄4 Vessels greater than 400 gross tons shall not discharge untreated oily bilgewater into waters subject to 

this permit. 

3⁄4 Vessels greater than 400 gross tons that regularly sail outside the territorial sea (at least once per month) 

shall not discharge treated bilgewater within 1 nm of shore if technologically feasible (e.g. holding would 

not impact safety and stability, would not contaminate other holds or cargo, would not interfere with 

essential operations of the vessel). Any discharge which is not technologically feasible to avoid must be 

documented as part of the requirements in Part 4.2. 

3⁄4 Vessels greater than 400 gross tons shall not discharge treated bilgewater into waters referenced in Part 

12.1 unless the discharge is necessary to maintain the safety and stability of the ship. Any discharge of 

bilgewater into these waters must be documented as part of the recordkeeping requirements in Part 4.2 

and vessel operators must document whether this bilgewater discharge was made for safety reasons. 

3⁄4 For vessels greater than 400 gross tons that regularly sail outside the territorial sea (at least once per 

month), if treated bilgewater is discharged into waters subject to this permit, it must be discharged when 

vessels are underway (sailing at speeds greater than 6 knots), unless doing so would threaten the safety 

and stability of the ship. EPA notes that vessel operators may also choose to dispose of bilgewater on 

shore where adequate facilities exist. Any discharge which is made for safety reasons must be 

documented as part of the requirements in Part 4.2. 

December 18, 2008 Final 38
Economic and Benefits Analysis of the Final Vessel General Permit 

Estimates of Cost 

No requirements within this discharge category require cost analysis because these practices are already covered 

by the abovementioned regulations or EPA assumes there is no cost associated with holding the vessel’s 

bilgewater in certain waters. 

6.2.3 Discharges of Ballast Water – Pacific Nearshore Vessels 

Affected Vessel Population 

EPA has estimated the population of and cost to vessels engaged in Pacific nearshore voyages that must exchange 

ballast water or flush empty ballast water. The population comes directly from the NBIC database. 

Other regulations, including the National Invasive Species Act (NISA), its predecessor NANCPA, and associated 

regulations (33CFR151 subparts 15, 20) apply to all other vessels. 

Permit Requirements 

Specific Ballast Water Discharge Sections within the Permit: 

All discharges of ballast water must comply with the Coast Guard regulations found in 33 CFR Part 151. Vessels 

that operate solely within one Captain of the Port (COTP) zone are exempt from certain requirements, as 

described in 33 CFR 151.2010(b). Additionally, owner/operators of all vessels subject to coverage under this 

permit which are equipped with Ballast Tanks must comply with any additional BMPs in this section. 

All discharges of ballast water may not contain oil, noxious liquid substances (NLSs), or hazardous substances in 

a manner prohibited by U.S. laws, including section 311 of the Clean Water Act. 

Ballast Water Management Plans

All owner/operators of vessels equipped with ballast water tanks must maintain a ballast water management plan 

that has been developed specifically for the vessel that will allow those responsible for the plan’s implementation 

to understand and follow the vessel’s ballast water management strategy. Owner/operators must make that plan 

available upon request to any EPA representative. Vessel owner/operators must assure that the master and crew 

members who actively take part in the management of the discharge or who may affect the discharge understand 

and follow the management strategy laid out in the plan. 

EPA notes that these plans are being imposed as “conditions to assure compliance” with effluent limitations 

under CWA 402(a)(2) and 40 CFR 122.43(a). 

Pacific nearshore vessel requirements for vessels carrying Ballast Water and for those with Ballast Water Tanks 

but certify No Ballast on Board (NoBOB) or Partial NoBOB

Unless the vessel meets one of the exemptions in Part 2.2.3.11, any vessel engaged in Pacific Nearshore Voyages 

as defined in Part 2.2.3.6 which the owner/operator has reported as having No Ballast on Board in accordance 

with Coast Guard regulations, or which have any ballast water tank that is empty or contains unpumpable 

residual water, must follow the applicable requirements in Part 2.2.3.6 for those tanks with ballast water and 

Part 2.2.3.8.1 for those tanks which are empty or contain unpumpable residual water. 

Unless the vessel meets one of the exemptions in Part 2.2.3.11, any vessel engaged in Pacific nearshore voyages 

that carry ballast water that was taken on in areas less than 50 nautical miles from any shore must carry out an 

exchange of ballast water in accordance with this Part before discharging from any tanks that carry ballast water 

December 18, 2008 Final 39
Economic and Benefits Analysis of the Final Vessel General Permit 

into waters subject to this permit if the vessel travels through more than one COTP zone as listed in 33 CFR Part 

3 or the vessel crosses international boundaries. 

Vessels engaged in Pacific nearshore voyages are: 

3⁄4 Vessels engaged in the Pacific coastwise trade and vessels transiting between Pacific ports that travel 

between more than one Captain of the Port Zone, and 

3⁄4 All other vessels that sail from foreign, non-U.S Pacific, Atlantic (including the Caribbean Sea), or Gulf 

of Mexico ports, which do not sail further than 200 nm from any shore, and that discharge or will 

discharge ballast water into the territorial sea or inland waters of Alaska or off the west coast of the 

continental United States. 

Ballast water exchange for vessels subject to this Part must occur in waters more than 50 nautical miles from any 

shore (US or otherwise), and in waters more than 200 meters deep, prior to discharging ballast water into waters 

subject to this permit. Exchange should occur as far from the shore, major estuary and oceanic river plumes, 

subsurface physical features (e.g. seamounts), and known fishery habitats as practicable. Vessels engaged in 

voyages that take them further than 200 nm from any shore and who will remain outside 200 nm from for a 

sufficient period to conduct exchange, are not allowed to exchange ballast water between 50 and 200 nm from 

shore to meet the requirements of Part 2.2.3.5 (unless the master determines that flushing farther than 200 nm 

from shore would interfere with essential vessel operations or safety of the vessel but the master determines that 

the vessel is able to safely flush more than 50 nm from shore) and instead, must conduct exchange more than 200 

nm from shore in accordance with Part 2.2.3.5 of this permit. For vessels engaged in the coastwise trade who are 

not outside 200 nm for a sufficient period to conduct exchange, they may conduct exchange outside 50 nm (even if 

they voyage beyond 200 nm) to meet the requirements of this permit. 

For those tanks which are empty or contain unpumpable residual water, you must either seal the tank so that 

there is no discharge or uptake and subsequent discharge of ballast water within waters subject to this permit or 

conduct saltwater flushing of such tanks in an area 50 nautical miles from any shore and in waters at least 200 

meters deep prior to the discharge or uptake and subsequent discharge of any ballast water to or from any waters 

subject to this permit. For purposes of Part 2.2.3.8, saltwater flushing means the addition of water from the 

“coastal exchange zone” to empty ballast water tanks; the mixing of the flush water with residual water and 

sediment through the motion of the vessel; and the discharge of the mixed water, such that the resulting residual 

water remaining in the tank has either a salinity greater than or equal to 30 parts per thousand (ppt) or a salinity 

concentration equal to the ambient salinity of the location where the uptake of the added water took place. In 

order to conduct saltwater flushing, the vessel should take on as much coastal exchange zone water into each tank 

as is safe (for the vessel and crew). These requirements apply to all vessels carrying ballast water that will enter 

any US port in the states of Alaska, California, Oregon, or Washington and that travels through more than one 

COTP zone. 

Vessels engaged in voyages that take them further than 200 nm from any shore and who will remain outside 200 

nm from for a sufficient period to flush ballast water, are not allowed to exchange ballast water between 50 and 

200 nm from shore to meet the requirements of Part 2.2.3.7 (unless the master determines that flushing farther 

than 200 nm from shore would interfere with essential vessel operations or safety of the vessel but the master 

determines that the vessel is able to safely flush more than 50 nm from shore) and instead, must conduct flushing 

more than 200 nm from shore in accordance with Part 2.2.3.7 of this permit. For vessels engaged in the coastwise 

trade who are not outside 200 nm for a sufficient period to conduct flushing, they may flush outside 50 nm (even if 

they voyage beyond 200 nm) to meet the requirements of this permit. 

For all vessel owner/operators subject to this section that contain some empty ballast water tanks and some full 

ballast water tanks, if you elect to seal those empty tanks, you must not allow water from the full tanks to 

December 18, 2008 Final 40
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 41

commingle with waters from the empty tanks if it will subsequently be discharged into waters subject to this 

permit. 

Estimates of Cost 

This cost estimate relies on previous estimates of ballast water exchange presented in USCG’s Regulatory 

Evaluation for the Mandatory Ballast Water Management Program for U.S. Waters (USCG, 2004a), NBIC data, 

and WTLUS/VESDOC populations. The USCG’s Regulatory Evaluation provided cost estimates that were 

extrapolated to 2007 dollars and used to estimate exchange and saltwater flushing costs. The cost inputs used to 

determine total ballast water exchange costs to Pacific nearshore vessels are shown in Table 6-4. Saltwater 

flushing costs to Pacific nearshore vessels are estimated in Section 6.2.4: Discharges of Ballast Water – Vessels 

with Empty Tanks.

Table 6-4: Unit Cost Inputs for Ballast Water Practices - Pacific Nearshore 

Vessels 

Unit Cost Input Unit Cost 

Pumping 1 cubic meter of ballast water $0.014/m3

Annual maintenance to the ballast pumps See Table 6-5

Annual addition of saltwater flushing practices to the ballast 

water management plan $109.90a

Recordkeeping per instance of exchange $18.32b

a Based on a labor rate of $109.90 and 1 hour. 

b Based on a labor rate of $109.90 and 10 minutes of labor required per exchange. 

The total annual cost of ballast water exchange for Pacific nearshore vessels is also based on the following data 

and assumptions: 

3⁄4 Population:

19 The population of vessels was determined by the NBIC database. EPA queried the database 

for both domestic and foreign ballast-capable vessels that called at ports in Oregon and Alaska at least 

once during 2005. Vessels calling at Washington and California were excluded due to existing state 

permits that matched or exceeded the NPDES requirements. 

3⁄4 Number of Exchanges: Arrivals data were also produced by the NBIC database. The number of 

exchanges that occur was determined by querying the database for all arrivals where the vessel had at 

least 1 full ballast tank. The previous USCG analysis was used to determine the percentage of time that 

safety and weather claims are made to prevent ballast water exchange. From these data, 61 percent was 

determined as the percentage of time that an exchange would occur. Weather conditions were assumed to 

prevent the other 39 percent of exchanges. 

3⁄4 Ballast Tank Capacity: The average number of full ballast water tanks that vessels are carrying upon 

arrival is multiplied by the average capacity of each tank, yielding an average, per arrival, measure of 

ballast water that is further broken down by vessel class. Expressed in metric tons, this measure represents 

the average volume of water that arriving vessels must exchange. 

3⁄4 Ballast Exchange Method: The method (i.e., sequential or flow-through exchange) is dependent upon 

ship type and determines the water volume multiplier. The flow-through exchange method, used by tank 

and freight ships, requires the pumping of three times the volume of water being exchanged. The 

sequential exchange method, used by all other vessel types, requires the pumping of two times the volume 

of water being exchanged. 

 

19 Ballast water requirements are the only BMP to which commercial fishing vessels are subject. Out of 28,875 commercial fishing vessels, 

twenty-six commercial fishing vessels are estimated to incur cost to comply with the ballast water requirements. 
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 42

3⁄4 Pumping Cost: A uniform cost for pumping 1 cubic meter of ballast water is estimated at ($0.014/m3).20

The USCG analysis developed unit cost estimates of ballast water exchange based on personal 

communication with the industry. 

3⁄4 Maintenance Cost: Annual maintenance costs are equal to 10 percent of the ballast water system’s capital 

cost. These costs were derived from the USCG analysis. Table 6-5 lists the average annual maintenance 

costs for each vessel class. 

Table 6-5: Annual Maintenance Cost Estimates for Pacific Nearshore Vessels 

Vessel Class 

Annual Maintenance 

Cost 

Number of Domestic 

Vessels 

Number of Foreign 

Vessels 

Commercial Fishing $1,500 16 0 

Freight Barges $1,500 16 0 

Freight Ships $2,000 13 9 

Tank Barges $1,500 13 0 

Tank Ships $3,000 12 16 

Utility Vessels $1,500 27 1 

TOTAL 97 26 

3⁄4 Management Plan: A ballast water management plan is already required for all vessels equipped with 

ballast tanks under NISA (33 CFR 151). Thus, there is no incremental cost associated with general 

management plan development. However, EPA is assuming that since vessels are now required to 

conduct saltwater flushing for empty tanks, vessel operators will need to incorporate their saltwater 

flushing plan into the ballast water management plan. EPA has assumed that this will represent a 1-hour 

annual burden for all oceangoing vessels. The hourly labor rate of $100 provided in the previous USCG 

analysis was prorated to 2007 dollars ($109.90) and was verified by industry contacts. The relatively high 

labor rate is due to the level of senior personnel involved in ballast water management decisions and 

activities.

3⁄4 Recordkeeping Costs: The same hourly labor rate of $109.90 was used for the recordkeeping cost 

estimate. EPA assumes that 10 minutes is required to perform recordkeeping per instance of exchange and 

saltwater flushing. 

The annual cost of the ballast water exchange requirements per vessel is a sum of the estimated pumping, 

maintenance, addition to the management plan, and recordkeeping costs. Summary tables for both domestic and 

foreign vessels that represent the cost calculations and the derived total costs are shown in Table 6-6 and Table 

6-7. 

 

20 One cubic meter (m3

) of water = 1 metric ton. 
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 6-6: Summary of Costs of Ballast Water Exchanges for Vessels Engaged in Pacific Nearshore 

Voyages: Domestic Flag 

Vessel Type 

Number of 

Vessels 

Annual Number 

of Ballast Water 

Exchanges/ 

Flushesa,b

Average Cost per 

Exchangec

Records, 

Management 

and Maintenance 

Costd,e Total Annual Cost 

Ballast Water Exchanges 

Commercial Fishing 17 14 $5.99 $24,421 $24,506 

Freight Barges 20 23 $42.60 $24,696 $25,690 

Freight Ships 18 151 $200.98 $30,507 $60,863 

Tank Barges 13 23 $69.75 $20,178 $21,762 

Tank Ships 22 107 $1,482.68 $39,188 $197,591 

Utility Vessels 31 26 $3.69 $41,288 $41,385 

Exchange TOTAL 121 344 $180,278 $371,798 

Saltwater Flushing 

Commercial Fishing 26 28 $0.08 $3,132 $3,135 

Freight Barges 34 217 $0.58 $6,613 $6,739 

Freight Ships 62 569 $0.85 $8,627 $9,112 

Tank Barges 15 271 $1.22 $3,627 $3,957 

Tank Ships 37 628 $5.63 $7,254 $10,790 

Utility Vessels 44 213 $0.04 $7,822 $7,830 

Flushing TOTAL 218 1,925 $37,075 $41,563 

TOTAL 2,269 $217,353 $413,360 

a Only includes Alaska and Oregon arrivals. California and Washington arrivals were excluded due to existing state regulations. 

b A 61% probability of performing saltwater flushing is applied to vessels with empty ballast tanks. This probability is equal to the 

probability of conducting ballast water exchange. 

c The average cost per saltwater flushing is a weighted average of the average cost determined for NoBOB and partial NoBOB vessels. 

d The recordkeeping cost is only applied to full ballast and NoBOB vessels. 

e Management plan and maintenance costs are only applied to non-oceangoing vessels that conduct exchange, or 80% of the exchange 

vessel total. 

December 18, 2008 Final 43
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 6-7: Summary of Costs of Ballast Water Exchanges for Vessels Engaged in Pacific 

Nearshore Voyages: Foreign Flag 

Vessel Type 

Number of 

Vessels 

Annual Number of 

Ballast Water 

Exchanges/ 

Flushesab

Average 

Cost per 

Exchangec

Records, 

Management 

and Maintenance 

Costde

Total Annual 

Cost 

Ballast Water Exchanges 

Freight Ships 160 155 $309.76 $22,617 $70,545 

Passenger Vessels 29 617 $26.74 $18,412 $34,910 

Tank Ships 17 12 $518.50 $3,348 $9,397 

Utility Vessels 1 1 $30.52 $18 $37 

Exchange TOTAL 207 784 $44,395 $114,889 

Saltwater Flushing 

Freight Ships 870 1,765 $1.47 $96,218 $98,805 

Passenger Vessels 36 1,063 $0.55 $7,620 $8,202 

Tank Barges 1 0 $0.00 $110 $110 

Tank Ships 183 449 $4.69 $21,724 $23,828 

Utility Vessels 3 6 $3.27 $421 $442 

Flushing TOTAL 1,093 3,283 $126,093 $131,387 

TOTAL 4,067 $170,488 $246,276 

a Only includes Alaska and Oregon arrivals. California and Washington arrivals were excluded due to existing state regulations. 

b A 61% probability of performing saltwater flushing is applied to vessels with empty ballast tanks. This probability is equal to the 

probability of conducting ballast water exchange. 

c The average cost per saltwater flushing is a weighted average of the average cost determined for NoBOB and partial NoBOB 

vessels. 

d The recordkeeping cost is only applied to full ballast and NoBOB vessels. 

e Management plan and maintenance costs are only applied to non-oceangoing vessels that conduct exchange, or 80% of the 

exchange vessel total. 

To arrive at these estimates, EPA made some critical assumptions and dealt with certain data limitations. These 

are addressed below: 

3⁄4 Due to the nature of the NBIC data, the number of vessels engaged in Pacific nearshore voyages is most 

likely understated. The NBIC system for gathering and organizing information on ballast-related activities 

calls for vessels to self-report with limited oversight. This inevitably results in some vessels conducting 

incomplete reporting or failing to report altogether. The exact margin of this uncertainty is unknown, but 

will likely have a relatively low impact on total costs. 

3⁄4 The probability of ballast water exchange is a flat figure across all vessels. It is calculated by using an 

adjusted average of the USCG Regulatory Evaluation’s weighted probability figures, which are primarily 

for freight and tank ships of varying types and sizes. The USCG’s figures are calculated to estimate the 

likelihood of exchange, taking into account weather, sea state, and the previous requirement that 

exchanges could only take place beyond 200 nm from shore. In our analysis, the vessel population 

includes more vessel types and does not break down by size. Also, the NPDES requirement has 

withdrawn the 200 nm line to 50 nm for Pacific Coast arrivals, making safe exchanges significantly more 

likely. However, no data are available that provide specific probabilities for ballast water exchange within 

the 50 nm zone. With these critical differences, EPA has opted to average the USCG results and adjust 

this average by a multiple of 1.5 to represent the 150 nm reduction in the exchange restriction zone. Thus, 

we assume that vessels are less likely to encounter conditions that lessen the likelihood of exchange. This 

is a conservative assumption and thus may overestimate the number of exchanges that may actually occur. 

3⁄4 Maintenance costs are also based on USCG findings, where yearly upkeep is estimated at 10 percent of 

the total capital cost of the ballast water pump system itself. Again, USCG breakdowns for this cost do 

not correlate directly to EPA’s vessel classification scheme, so the Agency used the mode of all cost 

December 18, 2008 Final 44
Economic and Benefits Analysis of the Final Vessel General Permit 

estimates for each of its vessel classes, except for its freight ships and tank ships vessel groups, where the 

mode of freight ship and tank ship cost estimates was used to obtain greater specificity. 

6.2.4 Discharges of Ballast Water – Vessels with Empty Tanks 

Affected Vessel Population 

EPA has estimated the population of and cost to all oceangoing vessels with empty ballast water tanks that must 

perform saltwater flushing. The population comes directly from the NBIC database. EPA has not estimated the 

cost to all Great Lakes vessels. The cost is negligible for these vessels since only three domestic flag vessels 

subject to the saltwater flushing requirement exist in the ballast water database, and they already perform this 

practice on a voluntary basis. 

Other regulations, including NISA, its predecessor NANCPA, and associated regulations (33 CFR 151 subparts 

15, 20), apply to all other vessels. 

Permit Requirements 

Specific Ballast Water Discharge Sections within the Permit: 

Vessels entering the Great Lakes

In addition to complying with the requirements of this permit, all vessels that are equipped to carry ballast water 

and enter the Great Lakes must comply with 33 CFR Part 151, Subpart C titled: “Ballast Water Management for 

Control of Nonindigenous Species in the Great Lakes and Hudson River.” Vessels that operate outside the EEZ 

and more than 200 nm from any shore and then enter the Great Lakes via the Saint Lawrence Seaway System 

must also comply with 33 CFR Part 401.30, which requires oceangoing vessels to conduct saltwater flushing of 

ballast water tanks 200 nautical miles from any shore before entering either the U.S. or Canadian waters of the 

Seaway System. 

Vessels with any Ballast Water Tanks that are empty or have unpumpable residual water

For vessels that travel between more than one COTP Zone while undertaking voyages described in Part 2.2.3.5 

and which either reported No Ballast on Board in accordance with Coast Guard regulations or which have any 

ballast water tank that is empty or contains unpumpable residual water, you must follow the applicable 

requirements in Part 2.2.3.5 for those tanks with ballast water. For those tanks which are empty or contain 

unpumpable residual water, you must either seal the tank so that there is no discharge or uptake and subsequent 

discharge of ballast water within waters subject to this permit or conduct saltwater flushing of such tanks in an 

area 200 nautical miles from any shore prior to the discharge or uptake and subsequent discharge of any ballast 

water to any U.S. waters subject to this permit, unless you meet one of the exemptions in Part 2.2.3.11. For the 

purposes of Part 2.2.3.7, saltwater flushing means the addition of mid-ocean water to empty ballast water tanks; 

the mixing of the added water with residual ballast water and sediment through the motion of the vessel; and the 

discharge of the mixed water until loss of suction, such that the resulting residual water remaining in the tank has 

either a salinity greater than or equal to 30 parts per thousand (ppt) or a salinity concentration equal to the 

ambient salinity of the location where the uptake of the added water took place. In order to conduct saltwater 

flushing, the vessel should take on as much mid-ocean water into each tank as is safe (for the vessel and crew). 

For all vessel owner/operators subject to this section that contain some empty ballast water tanks and some full 

ballast water tanks, if you elect to seal those empty tanks, you must not allow water that will be discharged into 

waters subject to this permit to commingle with waters from the empty tanks if you have not conducted saltwater 

flushing as specified above. 

December 18, 2008 Final 45
Economic and Benefits Analysis of the Final Vessel General Permit 

Estimates of Cost 

The Permit requires all oceangoing vessels with empty ballast tanks either to seal the tanks or to conduct saltwater 

flushing of such tanks in an area 200 nm from any shore prior to the discharge or uptake of any ballast water to or 

from any U.S. waters. Saltwater flushing costs were the only option estimated within this analysis. Costs of 

saltwater flushing were estimated in a similar manner to ballast water exchange costs. However, because current 

regulations (33 CFR 151.2035 and 33 CFR 151.2045) already require implementation of a management plan for 

all vessels (excluding Pacific nearshore vessels), the only additional cost was the annual 1-hour burden to 

supplement the management plan with saltwater flushing practices. Also, EPA assumes that recordkeeping is 

already performed when the vessel exchanges one or more ballast water tanks. Thus, recordkeeping costs were 

added into the estimates only for NoBOB vessels since partial NoBOB vessels are already assumed to conduct 

recordkeeping during ballast water exchange. Table 6-8 shows the annual cost inputs of saltwater flushing for 

vessels with empty ballast tanks. 

Table 6-8: Unit Cost Inputs for Ballast Water Practices – Vessels 

with Empty Ballast Tanks 

Unit Cost Input Unit Cost 

Pumping 1 cubic meter of ballast water $0.014/m3

Annual addition of saltwater flushing practices 

to the ballast water management plan $109.90a

Recordkeeping per instance of saltwater flushing 

for partial NoBOB vessels $18.32b

a Based on a labor rate of $109.90 and 1 hour. 

b Based on a labor rate of $109.90 and 10 minutes of labor required per exchange. 

The total annual cost of saltwater flushing for all oceangoing and Pacific nearshore vessels is also based on the 

following data and assumptions: 

3⁄4 Population: The population of vessels was determined by the NBIC database. EPA queried the database 

for both domestic and foreign ballast-capable vessels that called at U.S. ports at least once during 2005. 

Vessels calling at Great Lakes and Upper Hudson River ports were excluded due to existing permits that 

matched or exceeded the NPDES requirements. Reporting numbers for these regions were very low (37 

vessels) for 2005, due to the lack of a data exchange program with Canadian St. Lawrence Seaway 

reporting agencies, which was established in 2006. 

3⁄4 Number of Exchanges: The NBIC database also produced arrivals data providing for the number of 

saltwater flushes that should occur. This was done for the two arrival types: vessels arriving with zero 

metric tons of ballast water (NoBOB) and those arriving with at least one tank empty (partial NoBOB). 

Based on personal communication with the USCG, the risk involved in performing saltwater flushing 

based on weather concerns is significantly less than the risk involved in performing ballast water 

exchange (Cummins, 2007). However, no estimates of the percentage of time that safety or weather 

claims prevent saltwater flushing are currently available. Thus, EPA has assumed that it is generally safe 

to conduct saltwater flushing regardless of weather conditions. This assumption may result in an 

overstatement of saltwater flushing costs if weather prevents saltwater flushing. However, for partial 

NoBOB vessels, it was assumed that saltwater flushing occurs only if ballast water exchange is 

performed. EPA used the same probability as was used for ballast water exchange (61 percent). For 

NoBOB vessels, it was assumed that flushing occurs 100 percent of the time. 

3⁄4 Ballast Tank Capacity: Estimates of the ballast capacities that pertain to saltwater flushing for the vessels 

subject to the Permit requirements were derived from additional NBIC data queries. For NoBOB arrivals 

EPA used average total ballast capacity. For partial NoBOB vessel arrivals EPA multiplied the average 

capacity per ballast water tank by the average number of tanks that are reported empty, similar to the 

December 18, 2008 Final 46
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 47

water volume calculation for ballast exchange described above for Pacific nearshore voyages. This 

provides a realistic, per vessel class, average measure of water volume on which to base flushing costs in 

cases where a vessel may not report NoBOB yet still have empty ballast tanks to manage. To estimate the 

cost of saltwater flushing, EPA adjusted the estimated capacity of empty tanks to reflect the capacity that 

would be sufficient for performing saltwater flushing. Based on personal communication with a ship 

expert, an average empty ballast water tank contains approximately 0.5 percent to 1 percent of residual 

water (this may be a crude estimate because of the number of variables that determine the residual 

percentage, e.g., ship age, design, type). However, approximately two times the amount of residual water 

is required in order to complete saltwater flushing. This would produce an estimate of around 1.5 percent 

of average total ballast capacity that would be sufficient for saltwater flushing practices (Jenkins, 2007). 

3⁄4 Pumping Cost: The same uniform cost for pumping 1 cubic meter of ballast water is applied to these 

vessels, estimated at ($0.014/m3

).21

3⁄4 Management Plan: A ballast water management plan is already required for all vessels equipped with 

ballast tanks under NISA (33 CFR 151). Thus, there is no incremental cost associated with general 

management plan development. However, EPA is assuming that since vessels are now required to 

conduct saltwater flushing for empty tanks, vessel operators will need to incorporate their saltwater 

flushing plan into the ballast water management plan. The Agency has assumed that this will represent a 

1-hour annual burden for all oceangoing vessels. The hourly labor rate of $100 provided in the previous 

USCG analysis was prorated to 2007 dollars ($109.90) and was verified by industry contacts. The 

relatively high labor rate is due to the level of senior personnel involved in ballast water management 

decisions and activities.

3⁄4 Recordkeeping Cost: Again, the hourly labor rate of $109.90 was used for the recordkeeping cost 

estimate. EPA assumes that 10 minutes is required to perform recordkeeping per instance of saltwater 

flushing. Recordkeeping costs are only attributed to NoBOB vessels since partial NoBOB vessels already 

perform recordkeeping during exchange. 

The annual cost of the ballast water saltwater flushing requirements per vessel is a sum of the estimated pumping, 

management plan, and recordkeeping costs. Summary tables for both domestic and foreign vessels that represent 

the cost calculations and the derived total costs are shown in Table 6-9 and Table 6-10. 

Table 6-9: Summary of Costs of Saltwater Flushing for Oceangoing Vessels with Ballast Tanks Empty: 

Domestic Flag 

Vessel Type 

Number of 

Vessels 

Annual Number of 

Saltwater Flushingsa

Average Cost Per 

Saltwater Flushingb

Records and 

Management Costc Total Annual Cost 

Freight Barges 36 478 $1.19 $12,090 $12,659 

Freight Ships 167 1,797 $0.71 $18,628 $19,902 

Passenger Vessels 2 1 $0.02 $238 $238 

Tank Barges 17 188 $1.62 $4,781 $5,085 

Tank Ships 40 212 $3.07 $6,155 $6,806 

Utility Vessels 74 303 $0.04 $10,184 $10,197 

TOTAL 336 2,979 $52,077 $54,887 

a A 61% probability of performing saltwater flushing is applied to vessels with some empty ballast tanks. This probability is equal to the 

probability of conducting ballast water exchange.

b The average cost per saltwater flushing is a weighted average of the average cost determined for NoBOB and partial NoBOB vessels.

c The recordkeeping cost is only applied to NoBOB vessels.

 

21 One cubic meter (m3

) of water = 1 metric ton. 
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 6-10: Summary of Costs of Saltwater Flushing for Oceangoing Vessels with Ballast Tanks 

Empty: Foreign Flag 

Vessel Type 

Number of 

Vessels 

Annual Number of 

Saltwater Flushingsa

Average Cost Per 

Saltwater Flushingb

Records and 

Management Costc Total Annual Cost 

Freight Barges 3 4 $4.81 $348 $367 

Freight Ships 4,451 18,277 $1.13 $521,152 $541,839 

Passenger Vessels 166 4,389 $0.53 $24,179 $26,506 

Tank Barges 5 5 $3.10 $604 $620 

Tank Ships 1,824 8,999 $5.31 $271,667 $319,437 

Utility Vessels 33 33 $0.41 $3,810 $3,823 

TOTAL 6,482 31,707 $821,761 $892,592 

a A 61% probability of performing saltwater flushing is applied to vessels with some empty ballast tanks. This probability is equal to the 

probability of conducting ballast water exchange.

b The average cost per saltwater flushing is a weighted average of the average cost determined for NoBOB and partial NoBOB vessels.

c The recordkeeping cost is only applied to NoBOB vessels.

As with the cost estimation of ballast water exchange for Pacific nearshore voyages, some significant data 

shortcomings existed, and some key assumptions were made. These are addressed below: 

3⁄4 Due to the nature of the NBIC data, the number of vessels requiring saltwater flushing of ballast tanks is 

most likely understated. The NBIC system for gathering and organizing information on ballast-related 

activities calls for vessels to self-report with limited oversight. This inevitably results in some vessels 

conducting incomplete reporting or failing to report altogether. The exact margin of this uncertainty is 

unknown, but will likely have a relatively low impact on total costs. 

3⁄4 The probability of saltwater flushing for vessels arriving with any empty tanks, as with an exchange, is a 

flat figure across all vessels. It is calculated by using an adjusted average of the USCG Regulatory 

Evaluation’s weighted probability figures, which are primarily for freight and tank ships of varying types 

and sizes. The USCG’s figures are calculated to estimate the likelihood of exchange, taking into account 

weather, sea state, and the previous requirement that exchange could only take place beyond 200 nm from 

shore. In our analysis, the vessel population includes more vessel types and does not break down by size. 

Also, the NPDES requirement has withdrawn the 200 nm line to 50 nm for Pacific Coast arrivals, making 

safe exchanges and flushing significantly more likely. EPA can presume that for the other coasts where 

the 200 nm line still holds, some vessels will opt to flush their empty tanks, even when safe exchanges are 

not feasible. With these critical differences, the Agency has opted to average the USCG results and adjust 

this average by a multiple of 1.5 to represent the 150 nm reduction in the exchange restriction zone. 

6.2.5 Anti-fouling Hull Coatings 

Affected Vessel Population 

Since the Global Anti-fouling System Treaty came into effect on September 22, 2008, the requirements of the 

TBT restriction on the vessel population that would apply to this Permit are null since all vessels are covered 

under the treaty. Few, if any, vessels still use TBT on their hulls. 

December 18, 2008 Final 48
Economic and Benefits Analysis of the Final Vessel General Permit 

Permit Requirements 

Permit Text: 

3⁄4 All anti-fouling hull coatings subject to registration under FIFRA (see 40 CFR 152.15) must be 

registered, sold or distributed, applied, maintained, and removed in a manner consistent with applicable 

requirements on the coatings’ FIFRA label. 

3⁄4 For anti-fouling hull coatings not subject to FIFRA registration (i.e. not produced for sale and 

distribution in the United States), hull coatings must not contain any biocides or toxic materials banned 

for use in the United States (including those on EPA’s List of Banned or Severely Restricted Pesticides). 

This requirement applies to all vessels, including those registered and painted outside the United States. 

At the time of initial application or scheduled reapplication of anti-fouling coatings, you must give consideration, 

as appropriate for vessel class and vessel operations, to the use of hull coatings with the lowest effective biocide 

release rates, rapidly biodegradable components (once separated from the hull surface), or non-biocidal 

alternatives, such as silicone coatings. 

Some ports and harbors are impaired by copper. These waters include Shelter Island Yacht Basin in San Diego, 

California and waters in and around the ports of Los Angeles/Long Beach. A complete list of such waters may be 

found at www.epa.gov/npdes/vessels. When vessels spend considerable time in these waters (defined as spending 

more than 30 days per year), or use these waters as their home port (i.e. house boats, ferries or rescue vessels), 

vessel owner/operators shall consider using antifouling coatings that rely on a rapidly biodegradable biocide or 

another alternative rather than copper based coatings. If after consideration of alternative biocides, vessel 

operators continue to use copper based antifoulant paints, they must document in their recordkeeping 

documentation how this decision was reached. 

The discharge of Tributyltin (TBT) or any other organotin compound is prohibited by this permit. Therefore, 

vessel operators covered by this permit have a zero discharge standard for TBT or any other organotin 

compound. You may not use an antifoulant coating containing TBT or any other organotin compound. If the 

vessel has previously been covered with a hull coating containing TBT or any other organotin compound, vessels 

must be effectively overcoated so that no TBT or other organotin leaches from the vessel hull or the TBT or other 

organotin coating must have been removed from the vessel’s hull. 

Estimates of Cost 

No requirements within this discharge category for TBT require cost analysis because these practices are under 

the authority of the Global Anti-fouling System Treaty. EPA has assumed that the requirements for other antifouling paints are negligible for this permit. 

6.2.6 Aqueous Film-Forming Foam 

Affected Vessel Population 

Based on the Permit’s description of practices in this discharge category, aqueous film-forming foam (AFFF) 

practices apply only to a subset of the total population of vessels. Freight ships, tank ships, and various utility 

vessels are the only vessel classes to which this discharge category applies. Other vessel classes are not expected 

to have a firefighting system on board. Furthermore, separate population estimates were produced for oceangoing 

and non-oceangoing vessels since separate practices are applicable to each type of vessel. 

The population potentially affected by BMPs applicable to the AFFF discharge category is shown in Table 6-11. 

December 18, 2008 Final 49
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 6-11: Vessel Counts for AFFF BMPs 

Vessel Class Non-Oceangoing 

Vessel Counta

Oceangoing 

Vessel Count 

Total Vessel 

Count 

Freight Barges 0 0 0 

Freight Ships 112 555 667 

Passenger Vessels 0 0 0 

Tank Barges 0 0 0 

Tank Ships 13 129 142 

Utility Vessels 5,697 5,121 10,818 

TOTAL 5,822 5,805 11,627 

a Includes vessels operating on the Great Lakes, Mississippi River, and intracoastal waterways. 

Permit Requirements 

Permit Text: 

Discharges of AFFF are authorized for emergency purposes when needed to ensure the safety and security of the 

vessel and her crew. 

For all vessels that sail outside of the territorial sea more than once per month, maintenance and training 

discharges of fluorinated AFFF are not authorized within waters subject to this permit (Any such discharges 

should be collected and stored for onshore disposal or scheduled when the vessel is outside such waters). 

Discharge volumes associated with regulatory certification and inspection must be minimized and a substitute 

foaming agent (i.e. non-fluorinated) must be used if possible within waters subject to this permit. 

For vessels that do not leave the territorial sea more than once per month, if maintenance and training discharges 

are required, AFFF must be collected and stored for onshore disposal if technologically feasible unless the vessel 

uses non-fluorinated or alternative foaming agent. For those vessels for which it is not technologically feasible to 

collect and store the fluorinated AFFF foam, vessel owner/operators must limit the discharge to that amount 

necessary to conduct legally required tests. Training should be conducted as far from shore as is practicable. 

Maintenance and training discharges are not allowed in port. 

For all vessels, AFFF discharges may not occur in or within 1 nm of a water referenced in Part 12.1 unless they 

are discharged: 

3⁄4 For emergency purposes 

3⁄4 By rescue vessels such as fireboats for firefighting purposes, 

3⁄4 By vessels owned or under contract to do business exclusively in or within 1 nm of those protected areas 

by the United States government or state or local governments. 

If AFFF discharge occurs in waters in Part 12.1 for emergency purposes, a written explanation must be kept in 

the ship’s log or other vessel recordkeeping documentation consistent with Part 4.2 of this permit. 

Estimates of Cost 

Cost estimates of non-fluorinated foams are in the sensitivity analysis section, as these foams are not required for 

vessels. Within the sensitivity analysis EPA has estimated a potential low and high incremental cost associated 

with AFFF practices. These low and high estimates are based upon the percentage of vessels that would purchase 

non-fluorinated foams and a foam aspirating device, and the percentage of time that a vessel documents an 

emergency discharge. 

Other BMPs are not included in the sensitivity analysis since cost estimates and applicable vessel populations are 

not currently known. 

December 18, 2008 Final 50
Economic and Benefits Analysis of the Final Vessel General Permit 

Sensitivity Analysis 

Cost estimates are based upon assumptions and communication with a foam manufacturer as to the incremental 

cost per gallon of non-fluorinated foams and the cost of the non-fluorinated foaming device compared to the 

standard AFFF and device. The cost input values are shown in Table 6-12, and the estimates/assumptions derived 

for each practice are described below. 

Table 6-12: Per-Vessel Costs for BMPs Associated with AFFF 

BMP Labor Hours Unit Cost Cost Description 

Purchase of non-fluorinated foaming agents and 

the aspirating device N/A $3.94 

Annual cost of purchasing foams 

and device 

à Non-fluorinated foams N/A -$125 

Annual cost of purchasing 20 

gallons of foam 

à Non-fluorinated foam aspirating device N/A $128.94 Annual cost of purchasing device 

Documentation of an emergency discharge taking 

place in waters listed in Part 12.1 [waters 

federally protected wholly or in part for 

conservation purposes] in VGP 0.16 $5.06a Assumption of cost per instance 

Collection and storage of maintenance and 

training discharges from non-oceangoing vessels N/A 

Unknown 

Cost One-time installation cost 

a Unit cost is estimated by multiplying the labor hours by the average hourly labor rate of $31.61. 

3⁄4 Purchase of Non-Fluorinated Foams: Foams are typically not changed out of ships any more frequently 

than 5 years (respondents provided a range of 5 to 25 years in which foams may need to be replaced). 

AFFF is by far the most frequent foam used by vessels; some vessels also use protein and polar solvent 

foams. The type of foam that is carried onboard is dependent on the type of cargo. The amount of foam in 

the tanks ranges from 300 to 6,000 gallons, dependent on ship type. We have estimated that an annual 

amount of 100 gallons of foam would regularly be purchased. Furthermore, since non-fluorinated foams 

may be required in a greater volume, we have assumed that an additional 30 gallons of non-fluorinated 

foam would need to be purchased annually. The population of vessels that currently use non-fluorinated 

foams is unknown. However, a cost is determined by estimating an average incremental cost and 

assuming that a low percentage of vessels will purchase the non-fluorinated foams. 

à Gallons of Foam Purchased: An average vessel purchases 100 gallons of AFFF per year. It was 

assumed that an additional 30 gallons of non-fluorinated foam would need to be purchased 

annually. 

à Incremental Cost of Non-Fluorinated Foams: There is a cost savings per gallon achieved from 

purchasing non-fluorinated foams versus the typical AFFF. Based upon communication with a 

foam manufacturer, the average cost of AFFF is approximately $11/gallon, whereas the average 

cost of a non-fluorinated foam is approximately $7.50/gallon, a cost savings of $3.50/gallon. 

à Incremental Cost of Non-Fluorinated System: There is an additional annual cost per vessel of 

$128.94 for the special device that is required for non-fluorinated foam use. This device is 

expected to last for the lifetime of the vessel. The total incremental cost of the device is 

approximately $1,600, annualized at a 7 percent discount rate over 30 years. 

à Baseline: 

— Low End Assumption: 95 percent of vessels already use non-fluorinated foams and have 

the necessary device. 

— High End Assumption: 90 percent of vessels already use non-fluorinated foams and have 

the necessary device. 

December 18, 2008 Final 51
Economic and Benefits Analysis of the Final Vessel General Permit 

3⁄4 Documentation of Emergency AFFF Discharge within 1 nm of in waters listed in Part 12.1 [waters 

federally protected wholly or in part for Conservation Purposes] in the Vessel General Permit: The perinstance cost of this practice as well as the population of vessels that currently document these emergency 

discharges is unknown. However, by estimating an average documentation time and assuming that these 

discharges are infrequent, a low end and high end cost estimate can be determined. 

à Average Labor Hours Assumption: 10 minutes is required for documentation. 

à Average Labor Rate: Since this discharge category is primarily applicable to freight ships, tank 

ships, and utility vessels and these industries have not provided this information, a weighted 

average labor rate of $31.61 was calculated from all the industry responses. Appendix B 

summarizes the industry responses regarding labor rates. 

à Annual Number of Instances Assumption: Emergency discharges of AFFF occur within these 

waters, on average, once every two years. 

à Baseline: 

— Low End Assumption: Vessels document the discharge 95 percent of the time. 

— High End Assumption: Vessels document the discharge 90 percent of the time. 

3⁄4 Collect and Store All AFFF Maintenance and Training Discharges: This requirement is applicable to 

non-oceangoing vessels only. This cost estimate is based upon required technology (i.e., holding tanks 

and a pump system). The one-time installation cost of this system as well as the population of vessels that 

currently have this system installed is unknown until further information is received from industry 

representatives. 

3⁄4 In general, we are aware that it is not standard to have the technology to collect and store 

maintenance/training discharges of foams. It is common practice to wash the foam over the side of the 

ship. However, it is uncommon to perform these maintenance/training discharges while in inland waters. 

Most vessels perform these discharges while at sea. 

The cost per vessel for each BMP and the total cost associated with all vessels is listed in Table 6-13. At the low 

end, approximately $3,800 is a potential annual incremental cost. At the high end, approximately $7,500 is a 

potential annual incremental cost. 

December 18, 2008 Final 52
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 6-13: Aqueous Film-Forming Foam Sensitivity Analysis 

Vessel Class Vessels 

% Vessels 

Applicable to BMP 

Annual Cost per 

Vessela Total Annual Cost 

Low End Estimate 

Purchase Non-Fluorinated Foams and System 

Freight Barges 0 0% $0.00 $0 

Freight Ships 667 5% $3.94 $131 

Passenger Vessels 0 0% $0.00 $0 

Tank Barges 0 0% $0.00 $0 

Tank Ships 142 5% $3.94 $28 

Utility Vessels 10,818 5% $3.94 $2,130 

Foam Purchase TOTAL 11,627 $2,289 

Document Emergency Discharge 

Freight Barges 0 0% $0.00 $0 

Freight Ships 667 100% $0.13 $84 

Passenger Vessels 0 0% $0.00 $0 

Tank Barges 0 0% $0.00 $0 

Tank Ships 142 100% $0.13 $18 

Utility Vessels 10,818 100% $0.13 $1,368 

Documentation TOTAL 11,627 $1,470 

Low End TOTAL $3,760 

High End Estimate 

Purchase Non-Fluorinated Foams and System 

Freight Barges 0 0% $0.00 $0 

Freight Ships 667 10% $3.94 $263 

Passenger Vessels 0 0% $0.00 $0 

Tank Barges 0 0% $0.00 $0 

Tank Ships 142 10% $3.94 $56 

Utility Vessels 10,818 10% $3.94 $4,260 

Foam Purchase TOTAL 11,627 $4,579 

Document Emergency Discharge 

Freight Barges 0 0% $0.00 $0 

Freight Ships 667 100% $0.25 $169 

Passenger Vessels 0 0% $0.00 $0 

Tank Barges 0 0% $0.00 $0 

Tank Ships 142 100% $0.25 $36 

Utility Vessels 10,818 100% $0.25 $2,703 

Documentation TOTAL 11,627 $2,941 

High End TOTAL $7,520 

a Cost for the non-fluorinated foaming system is annualized at a 7% discount rate over 30 years. 

6.2.7 Boiler/Economizer Blowdown 

Affected Vessel Population 

The costs incurred in this discharge category are assumed to be negligible and/or the industry is assumed to 

currently practice the Permit requirements. Thus, the vessel population that would apply to this Permit was not 

estimated since no vessels will experience any cost. 

December 18, 2008 Final 53
Economic and Benefits Analysis of the Final Vessel General Permit 

Permit Requirements 

Permit Text: 

Minimize the discharge of boiler/economizer blowdown in port if chemicals or other additives are used to reduce 

impurities or prevent scale formation. For vessels greater than 400 gross tons which leave the territorial sea at 

least once per week, boiler/economizer blowdown may not be discharged in waters subject to this permit, unless: 

3⁄4 The vessel remains within waters subject to this permit for a longer period than the necessary duration 

between blowdown cycles, 

3⁄4 The vessel needs to conduct blowdown immediately before entering drydock, or 

3⁄4 For safety purposes. 

For all vessels, boiler/economizer blowdown may not be discharged in waters referenced in Part 12.1 except for 

safety purposes. Furthermore, boiler/economizer blowdown should be discharged as far from shore as practical. 

Estimates of Cost 

No requirements in this discharge category require cost analysis because these practices are assumed to have 

negligible costs and/or the industry is assumed to currently practice the Permit requirements. 

6.2.8 Cathodic Protection 

Affected Vessel Population 

Based on the description of practices within this discharge category, all vessel classes are subject to the cathodic 

protection BMPs. However, only vessels that have steel hulls are applicable to this discharge category. Thus, the 

total count of domestic vessels applicable to this discharge category is nearly 80 percent of the total domestic 

count. 

The population potentially affected by BMPs applicable to the cathodic protection discharge category is shown in 

Table 6-14. 

Table 6-14: Vessel Counts for Cathodic Protectiona BMPs 

Vessel Class Vessel Count 

Freight Barges 32,646 

Freight Ships 552 

Passenger Vessels 1,724 

Tank Barges 4,927 

Tank Ships 141 

Utility Vessels 9,184 

TOTAL 49,174 

a Applies to steel hulled vessels only 

Permit Requirements 

Permit Text: 

Cathodic protection must be maintained to prevent the corrosion of the ship’s hull. The discharge of zinc, 

magnesium, and aluminum are expected from properly functioning cathodic protection sacrificial electrodes. 

However, vessel operators must minimize the flaking of large, corroded portions of these anodes. Sacrificial 

December 18, 2008 Final 54
Economic and Benefits Analysis of the Final Vessel General Permit 

anodes must not be used more than necessary to adequately prevent corrosion of the vessel’s hull, sea chest, 

rudder, and other exposed areas of the vessel. Vessel operators must appropriately clean and/or replace these 

anodes in periods of maintenance (such as drydocking), so that release of these metals to waters is minimized. 

Vessel operators should be cognizant that magnesium is less toxic than aluminum, which is less toxic than zinc. If 

vessel operators use sacrificial electrodes, they must use the metals that are less toxic to the extent 

technologically feasible and economically practicable and achievable. 

EPA recommends the use of Impressed Current Cathodic Protection (ICCP) in place of or to reduce the use of 

sacrificial electrodes when technologically feasible (e.g. adequate power sources, appropriate for vessel hull size 

and design), safe, and adequate to protect against corrosion, particularly for new vessels. If vessel operators use 

ICCP, they must maintain dielectric shields to prevent flaking.

Estimates of Cost 

Based upon communication with a maritime engineer from the U.S. Maritime Administration (Ghosh, 2008) as 

well as preliminary industry responses, there is no incremental cost to vessels for these specific BMPs. As a 

baseline, all steel hulled vessels currently have either an ICCP or a sacrificial electrodes system of cathodic 

protection. Furthermore, the cost of either type of cathodic protection system is the same. There is no additional 

cost for using a less toxic metal such as aluminum in lieu of a more toxic metal such as zinc. In addition, in EPA’s 

discussions with a representative from a cathodic protection manufacturing company (Peters, 2008), magnesium 

is not recommended over either of these metals because magnesium has a higher potential and could cause 

damage to the hull paint coating, thus allowing for a faster rate of dissolution. 

A sensitivity analysis was performed to estimate potential costs of cathodic protection installation for vessels that 

will opt to purchase an ICCP system in accordance with the Permit recommendations. In the sensitivity analysis 

EPA has estimated a potential low and high incremental cost associated with cathodic protection installation. 

These low and high estimates are based upon the percentage of vessels that may need to install an updated system. 

BMPs associated with maintenance and replacement of the cathodic protection system will not incur incremental 

costs, and no sensitivity analysis will be performed since these practices are regularly performed when deemed 

necessary. 

Sensitivity Analysis 

Costs of installing either an ICCP or a sacrificial electrodes system of cathodic protection were estimated based 

upon communication with a cathodic protection manufacturing company. 

The cost input values of cathodic protection system installation are shown in Table 6-15, and the 

estimates/assumptions derived for each practice are described below. 

Table 6-15: Cathodic Protection Installation Cost Estimates 

Vessel Class 

Low End 

Installation Cost 

High End 

Installation Cost 

Average 

Installation Cost 

Freight Barges $10,000 $11,000 $10,500 

Freight Ships $15,000 $18,000 $16,500 

Tank Barges $15,000 $18,000 $16,500 

Tank Ships $24,000 $28,000 $26,000 

Utility Vessels $15,000 $18,000 $16,500 

Passenger Vessels $20,000 $25,000 $22,500 

3⁄4 Installation Costs: a representative from a cathodic protection manufacturing company provided cost 

estimates for a system. The figures are dependent upon the area of steel on the hull as well as other minor 

components. The cost estimates that were provided are shown in Table 6-15.

December 18, 2008 Final 55
Economic and Benefits Analysis of the Final Vessel General Permit 

3⁄4 Baseline: 

à Low End Assumption: 2.5 percent of vessels will install an ICCP system due to the Permit 

recommendations. 

à High End Assumption: 5 percent of vessels will need to install an ICCP system due to the Permit 

recommendations. 

The average installation cost was taken for each vessel class. This system is expected to last for the lifetime of the 

vessel. Thus, the total incremental cost of the device is annualized at a 7 percent discount rate over 30 years to 

yield the annual cost per vessel presented in Table 6-16. 

The cost per vessel and the total cost associated with all vessels is listed in Table 6-16. At the low end, if 

2.5 percent of vessels install an ICCP system, approximately $1.3 million is a potential incremental cost. At the 

high end, if 5 percent install an ICCP system, approximately $2.5 million is a potential incremental cost. 

Table 6-16: Cathodic Protection Sensitivity Analysis, Purchase of a Cathodic Protection System 

Vessel Class 

Total Number 

of Vesselsa

% of Vessels Need to 

Purchase System Annual Cost per Vesselb Total Annual Cost 

Low End Estimate 

Freight Barges 32,646 2.5% $846.16 $690,591 

Freight Ships 552 2.5% $1,329.68 $18,350 

Passenger Vessels 1,724 2.5% $1,813.19 $78,149 

Tank Barges 4,927 2.5% $1,329.68 $163,783 

Tank Ships 141 2.5% $2,095.25 $7,386 

Utility Vessels 9,184 2.5% $1,329.68 $305,294 

Low End TOTAL 49,174 $1,263,551 

High End Estimate 

Freight Barges 32,646 5% $846.16 $1,381,182 

Freight Ships 552 5% $1,329.68 $36,699 

Passenger Vessels 1,724 5% $1,813.19 $156,297 

Tank Barges 4,927 5% $1,329.68 $327,566 

Tank Ships 141 5% $2,095.25 $14,771 

Utility Vessels 9,184 5% $1,329.68 $610,587 

High End TOTAL 49,174 $2,527,103 

a Applies to steel hulled vessels only. 

b Annualized at a 7% discount rate over 30 years. 

6.2.9 Chain Locker Effluent 

Affected Vessel Population 

Based on the description of practices within this discharge category, a subset of vessel classes is applicable to the 

chain locker effluent discharge category. Freight ships, tank ships, and various utility vessels are the vessel classes 

that are applicable to this discharge category. Other vessel classes are not applicable to this discharge category 

because their anchors are rarely or never deployed or other equipment is used (e.g., anchor cable). The population 

potentially affected by BMPs applicable to the chain locker effluent discharge category is shown in Table 6-17. 

December 18, 2008 Final 56
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 6-17: Vessel Counts for Chain Locker Effluent BMPs 

Vessel Class Vessel Count 

Freight Barges 0 

Freight Ships 697 

Passenger Vessels 0 

Tank Barges 0 

Tank Ships 147 

Utility Vessels 10,892 

TOTAL 11,736 

Permit Requirements 

Permit Text: 

The anchor chain must be carefully and thoroughly washed down (i.e., more than a cursory rinse) as it is being 

hauled out of the water to remove sediment and marine organisms. In addition, chain lockers must be cleaned 

thoroughly during dry docking to eliminate accumulated sediments and any potential accompanying pollutants. 

For vessels that regularly sail outside waters subject to this permit, if technically feasible, periodically clean, 

rinse, and/or pump out the space beneath the chain locker prior to entering waters subject to this permit 

(preferably mid ocean) if the anchor has been lowered into any nearshore waters. Furthermore, for vessels that 

leave waters subject to this permit at least once per month, chain lockers may not be rinsed or pumped out in 

waters subject to this permit, unless not emptying them would compromise safety. Such a safety claim must be 

documented in the vessel’s recordkeeping documentation consistent with Part 4.2. 

Estimates of Cost 

Based on preliminary survey responses, most BMPs in the chain locker effluent discharge category are already 

practiced by the industry. While in drydock (which occurs very infrequently, e.g., once every two years), the 

chain lockers are always cleaned. Rinsing or pumping of the space beneath the chain locker within 3 nm from 

shore is never performed. Furthermore, while the vessel is being hauled out of the water, the anchor chain is 

nearly always washed down. However, the BMP that is not common practice for any of the vessel classes 

included in the vessel population is inspection, cleaning, and pumping out of the space beneath the chain locker 

prior to entering nearshore waters. An industry representative commented that chain lockers are typically cleaned 

during drydocks and not in the deep sea or in nearshore waters because the locker is full of the anchor chain. The 

potential cost of this BMP was not estimated since this practice is only required if technically feasible. 

EPA has performed a sensitivity analysis only for the potential incremental costs associated with washing down 

the anchor chain as it is being hauled out of the water. In the sensitivity analysis EPA has estimated a potential 

low and high incremental cost associated with washing down the anchor chain. These low and high estimates are 

based upon the percentage of time that a vessel washes down the anchor chain while hauling it out of the water. 

Sensitivity Analysis 

These cost estimates were based upon industry communication (via survey response). The cost input values are 

shown in Table 6-18, and the estimates/assumptions derived for this practice are described below. 

December 18, 2008 Final 57
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 6-18: Per Vessel Costs for BMPs Associated with Chain Locker Effluent 

BMP Labor Hours Unit Cost Cost Description 

Washing down the anchor chain as it is being 

hauled out of the water 0.75 $23.71a Per Instance 

Rinsing out the space beneath the chain locker 

prior to entering nearshore waters Unknown Unknown Per Instance 

a Unit cost is estimated by multiplying the labor hours by the average hourly labor rate of $31.61. 

3⁄4 Washing Down the Anchor Chain: 

à Average Labor Hours Assumption: Since most towing vessel/barge companies estimated a perinstance washdown time within the range of 0.5 to 1 hour, EPA took the average of 0.75 hours to 

estimate the time it would take to wash down the anchor chain as it is being hauled out of the 

water. 

à Average Labor Rate: Since this discharge category is primarily applicable to freight ships, tank 

ships, and utility vessels and these industries have not provided this information, a weighted 

average labor rate of $31.61 was calculated from all the industry responses. Appendix B 

summarizes the industry responses regarding labor rates. 

à Annual Number of Instances Assumption: The number of times that a vessel hauls the anchor 

chain out of the water ranges from 12 to 50 times per year. EPA estimated an average of 20 times 

per year. 

à Baseline: 

— Low End Assumption: The vessel currently washes down the anchor chain as the chain is 

hauled out of the water 100 percent of the time. 

— High End Assumption: The vessel currently washes down the anchor chain as the chain is 

hauled out of the water 99 percent of the time. 

The annual incremental cost per vessel and the total cost associated with all vessels for washing down the anchor 

chain is listed in Table 6-19. 

Table 6-19: Chain Locker Effluent Sensitivity Analysis, Wash Down Anchor Chain 

Vessel Class Vessels 

% Vessels 

Applicable to BMP 

Annual Cost 

per Vessel 

Total Annual 

Cost 

High End Estimate 

Freight Barges 0 0% $0.00 $0 

Freight Ships 697 100% $4.74 $3,305 

Passenger Vessels 0 0% $0.00 $0 

Tank Barges 0 0% $0.00 $0 

Tank Ships 147 100% $4.74 $697 

Utility Vessels 10,892 100% $4.74 $51,652 

Wash Anchor Chain, High End TOTAL 11,736 $55,654 

December 18, 2008 Final 58
Economic and Benefits Analysis of the Final Vessel General Permit 

6.2.10 Controllable Pitch Propeller and Thruster Hydraulic Fluid and other Oil Sea Interfaces 

including Lubrication discharges from Paddle Wheel Propulsion, Stern Tubes, Thruster 

Bearings, Stabilizers, Rudder Bearings, Azimuth Thrusters, Propulsion Pod Lubrication, 

and Wire Rope and Mechanical Equipment Subject to Immersion 

Affected Vessel Population 

Based on the description of practices within this discharge category, a subset of vessel classes is applicable to the 

discharge category of controllable pitch propeller hydraulic fluid. Freight ships, tank ships, and various utility 

vessels have the potential to produce this discharge. No other vessel classes are expected to operate controllable 

pitch propellers. 

The population potentially affected by BMPs applicable to this discharge category is shown in Table 6-20. 

Table 6-20: Vessel Counts for Controllable Pitch Propeller 

Hydraulic Fluid BMPs 

Vessel Class Vessel Count 

Freight Barges 0 

Freight Ships 697 

Passenger Vessels 0 

Tank Barges 0 

Tank Ships 147 

Utility Vessels 10,892 

TOTAL 11,736 

Permit Requirements 

Permit Text: 

The protective seals on controllable pitch propellers, azimuth thrusters, propulsion pods, rudder bearings, or any 

other oil to sea interfaces must be maintained in good operating order to minimize the leaking of hydraulic oil or 

other oils. The vessel owner/operator must not discharge oil in quantities that may be harmful as defined in 40 

CFR Part 110 from any oil to sea interface. If possible, maintenance activities on controllable pitch propellers, 

thrusters and other oil-to-sea interfaces should be conducted when a vessel is in drydock. 

Minimize maintenance activities on stern tube seals when a vessel is outside of drydock. If maintenance or 

emergency repair must occur on stern tubes or other oil-to sea interfaces which have a potential to release oil in 

quantities that may be harmful as defined in 40 CFR Part 110, appropriate spill response resources (e.g. oil 

booms) must be used to contain any oil leakage. Operators of the vessel must have ready access to any spill 

response resources to clean any potential oil spills. 

After applying lubrication to wire rope and mechanical equipment subject to immersion, wire ropes and other 

equipment must be thoroughly wiped-down to remove excess lubricant. 

Owner/operators should use an environmentally preferable lubricant, including vegetable oil, synthetic ester, or 

polyalkylene glycol as a base for these applications when feasible. Use of an environmentally preferable lubricant 

does not authorize the discharge of any lubricant in a quantity that may be harmful as defined in 40 CFR Part 

110. 

December 18, 2008 Final 59
Economic and Benefits Analysis of the Final Vessel General Permit 

Estimates of Cost 

Based upon the preliminary industry responses, maintenance of the controllable pitch propeller is already 

performed when in drydock and, when applicable, oil booms and oil absorbent pads are purchased and are in use. 

However, a sensitivity analysis will be performed to account for the potential incremental cost associated with 

purchasing an oil boom and oil absorbent pads. In the sensitivity analysis EPA has estimated a potential low and 

high incremental cost associated with the purchase of an oil boom and oil absorbent pads. These low and high 

estimates are based upon the percentage of vessels that need to purchase this equipment. 

Sensitivity Analysis 

Cost estimates were based upon communication with an oil boom manufacturer (Dawg, 2008) as to the cost of 

purchasing an oil boom as well as oil absorbent pads. The cost input values are shown in Table 6-21, and the 

estimates/assumptions derived for each practice are described below. 

Table 6-21: Per-Vessel Costs for BMPs Associated with Controllable Pitch Propeller Hydraulic Fluid

Unit Cost 

BMP Low End High End Cost Description 

Purchase (and use) of an oil boom for containing 

any hydraulic oil leakage during underwater 

maintenance of the controllable pitch propeller 

$44.48 for <50 ft width vessels 

$80.67 for >50 ft width vessels 

Annualized Cost of Purchasing an 

Oil Boom 

Purchase of oil absorbent pads to clean any potential 

oil spills $10.24 $16.00 

Annualized Cost of Purchasing Oil 

Absorbent Pads 

3⁄4 Purchase and Use of an Oil Boom: 

à Oil Boom Cost: a representative from a vessel oil boom manufacturer provided the cost estimates 

for an oil boom. From communication with a vessel oil boom manufacturer, a 50-foot oil boom 

can be purchased for $552, and a 100-foot oil boom can be purchased for $1,001. Since the rear 

of the vessel is where the oil boom would be necessary, the length of boom that is required for a 

vessel is dependent upon the width of the vessel. Most vessels classes have an average width less 

than or around 50 feet, thus requiring only the 50-foot purchase. However, tank ships hold an 

average width of 78 feet and would therefore require the 100-foot purchase. The oil boom is 

expected to last for the lifetime of the vessel. The total incremental cost of the device is 

annualized at a 7 percent discount rate over 30 years. 

à Baseline: 

— Low End Assumption: 99 percent of vessels already have and use an oil boom. 

— High End Assumption: 95 percent of vessels already have and use an oil boom. 

3⁄4 Purchase of Oil Absorbent Pads: 

à Cost of Oil Absorbent Pads: a representative from a vessel oil boom manufacturer also provided 

the cost estimates for oil absorbent pads. The cost ranges from $34 to $50 for 100 oil absorbent 

pads. EPA took the average cost of $42 per purchase. The oil absorbent pads are assumed to be 

purchased every three or five years. Thus, for the low end estimate, the total incremental cost of 

the device is annualized at a 7 percent discount rate over five years. For the high end estimate, the 

total incremental cost of the device is annualized at a 7 percent discount rate over three years. 

à Baseline: 

— Low End Assumption: Oil absorbent pads need to be purchased every five years, and 99 

percent of vessels already have oil absorbent pads. 

December 18, 2008 Final 60
Economic and Benefits Analysis of the Final Vessel General Permit 

— High End Assumption: Oil absorbent pads need to be purchased every three years, and 95 

percent of vessels already have oil absorbent pads. 

The cost per vessel for each BMP and the total cost associated with all vessels are provided in Table 6-22. 

Table 6-22: Controllable Pitch Propeller Hydraulic Fluid Sensitivity Analysis 

Vessel Class Vessels 

% Vessels 

Applicable to BMP 

Annual Cost per 

Vessela Total Annual Cost 

Low End Estimate 

Purchase an Oil Boom 

Freight Barges 0 0% $0.00 $0 

Freight Ships 697 1% $44.48 $310 

Passenger Vessels 0 0% $0.00 $0 

Tank Barges 0 0% $0.00 $0 

Tank Ships 147 1% $80.67 $119 

Utility Vessels 10,892 1% $44.48 $4,845 

Oil Boom Purchase TOTAL 11,736 $5,274 

Purchase Oil Absorbent Pads 

Freight Barges 0 0% $0.00 $0 

Freight Ships 697 1% $10.24 $71 

Passenger Vessels 0 0% $0.00 $0 

Tank Barges 0 0% $0.00 $0 

Tank Ships 147 1% $10.24 $15 

Utility Vessels 10,892 1% $10.24 $1,102 

Oil Pads Purchase TOTAL 11,736 $1,202 

Low End TOTAL $6,476 

High End Estimate 

Perform Maintenance on the Controllable Pitch Propeller when Drydocked 

Purchase an Oil Boom 

Freight Barges 0 0% $0.00 $0 

Freight Ships 697 5% $44.48 $1,550 

Passenger Vessels 0 0% $0.00 $0 

Tank Barges 0 0% $0.00 $0 

Tank Ships 147 5% $80.67 $593 

Utility Vessels 10,892 5% $44.48 $24,226 

Oil Boom Purchase TOTAL 11,736 $26,369 

Purchase Oil Absorbent Pads 

Freight Barges 0 0% $0.00 $0 

Freight Ships 697 5% $16.00 $558 

Passenger Vessels 0 0% $0.00 $0 

Tank Barges 0 0% $0.00 $0 

Tank Ships 147 5% $16.00 $118 

Utility Vessels 10,892 5% $16.00 $8,611 

Oil Pads Purchase TOTAL 11,736 $9,391 

High End TOTAL $35,760 

a Cost for the oil boom is annualized at a 7% discount rate over 30 years. Low end cost for oil absorbent pads is annualized at a 7% 

discount rate over five years. High end cost for oil absorbent pads is annualized at a 7% discount rate over three years. 

December 18, 2008 Final 61
Economic and Benefits Analysis of the Final Vessel General Permit 

6.2.11 Distillation and Reverse Osmosis Brine 

Affected Vessel Population 

The costs incurred in this discharge category are assumed to be negligible and/or the industry is assumed to 

currently practice the Permit requirements. Thus, the vessel population that would apply to this Permit was not 

estimated since no vessels will experience any cost. 

Permit Requirements 

Permit Text: 

Brine from the distillation system and reverse osmosis reject water shall not contain or come in contact with 

machinery or industrial equipment (other than that necessary for the production of potable water), toxic or 

hazardous materials, or wastes. 

Estimates of Cost 

No requirements within this discharge category require cost analysis because these practices are assumed to have 

negligible costs and/or the industry is assumed to currently practice the Permit requirements. 

6.2.12 Elevator Pit Effluent 

Affected Vessel Population 

Based on the description of practices within this discharge category, a small subset of vessel classes is applicable 

to the elevator pit effluent discharge category. Only freight ships and tank ships have the potential to produce this 

discharge since no other vessels are expected to have exposed elevators. Passenger vessels do not produce this 

discharge because they are expected to have enclosed elevators. 

The population potentially affected by BMPs applicable to discharges in the elevator pit effluent category is 

shown in Table 6-23. 

Table 6-23: Vessel Counts for Elevator Pit Effluent BMPs 

Vessel Class Vessel Count 

Freight Barges 0 

Freight Ships 697 

Passenger Vessels 0 

Tank Barges 0 

Tank Ships 147 

Utility Vessels 0 

TOTAL 844 

Permit Requirements 

Permit Text: 

Discharges of untreated elevator pit effluent are not authorized within waters subject to this permit except in 

cases of emergency. Elevator pit effluent may be discharged into waters subject to this permit if it is managed 

with the vessel’s bilgewater and meets all the requirements of Part 2.2.2 of this permit or it must otherwise be 

December 18, 2008 Final 62
Economic and Benefits Analysis of the Final Vessel General Permit 

treated with an oily-water separator and discharged with an oil content below 15 ppm as measured by EPA 

Method 1664 or other appropriate method for determination of oil content as accepted by the International 

Maritime Organization (IMO) (e.g. ISO Method 9377) or U.S. Coast Guard. Emergency discharges must be 

documented in the ship’s log or other vessel recordkeeping documentation consistent with Part 4.2. 

Estimates of Cost 

Based on survey responses, discharge of elevator pit effluent never occurs in either normal or emergency 

situations. Thus, there is no incremental cost associated with onshore disposal or for the use of an oily-water 

separator to ensure an oil content of less than 15 parts per million (ppm). No sensitivity analysis will be 

performed. 

6.2.13 Firemain Systems 

Affected Vessel Population 

Based on the description of practices within this discharge category, a subset of vessel classes is applicable to the 

firemain systems discharge category. Only freight ships, passenger vessels, and tank ships have the potential to 

produce this discharge. Other vessel classes do not produce this discharge because it is associated with ballast 

water, and the other vessel classes are not expected to hold ballast. 

The population potentially affected by BMPs applicable to the firemain systems discharge category is shown in 

Table 6-24. 

Table 6-24: Vessel Counts for Firemain Systems BMPs 

Vessel Class Vessel Count 

Freight Barges 0 

Freight Ships 697 

Passenger Vessels 11,521 

Tank Barges 0 

Tank Ships 147 

Utility Vessels 0 

TOTAL 12,365 

Permit Requirements 

Permit Text: 

Discharges from firemain systems are authorized for emergency purposes when needed to ensure the safety and 

security of the vessel and her crew and for testing and inspection purposes as may be required to assure its 

operability in an emergency. Firemain systems may be discharged in port for certification, maintenance, and 

training requirements if the intake comes directly from the surrounding waters or potable water supplies and 

there are no additions to the discharge. Furthermore, firemain discharges may be discharged for deck washdown 

or other secondary uses if the intake comes directly from the surrounding waters or potable water supplies and 

the discharge meets all relevant effluent limitation associated with that activity. When feasible, maintenance and 

training should be conducted outside port and/or outside waters subject to this permit. 

Do not discharge firemain systems in waters listed in Part 12.1 except in emergency situations or when washing 

down the anchor chain to comply with anchor wash down requirements in Part 2.2.8. 

December 18, 2008 Final 63
Economic and Benefits Analysis of the Final Vessel General Permit 

Estimates of Cost 

Based on survey responses, discharges from the firemain system does not occur in normal situation. Though the 

industry responses to EPA’s questionnaire indicate that discharges from firemain systems do not occur in 

emergency situations, EPA assumes that there are occasional discharges from the firemain systems in cases of fire 

emergency, training, or other situations. 

6.2.14 Freshwater Layup 

Affected Vessel Population 

Based on EPA’s survey results, the vessel population that would apply to this Permit may be null since this 

discharge category may not apply to any commercial vessels. EPA included this provision in the permit based on 

information from MARAD marine engineers that these vessel discharges may occur. 

Permit Requirements 

Permit Text: 

Minimize the amount of disinfection agents used in freshwater layup to the minimum required to prevent aquatic 

growth. 

Estimates of Cost 

No requirements within this discharge category require cost analysis because this discharge is not applicable to 

commercial vessels or it is assumed vessel operators currently perform these practices. 

6.2.15 Gas Turbine Wash Water 

Affected Vessel Population 

The vessel population that would apply to this Permit may be null since this discharge category may not apply to 

any commercial vessels. Only CLIA indicated that their vessels may have this vessel discharge type in their 

public comments. 

Permit Requirements 

Permit Text: 

Gas turbine wash water must not be directly discharged within waters subject to this permit. Where feasible, such 

washwater must be prevented from commingling with bilge water that will be discharged in waters subject to this 

permit, for example by collecting it separately and properly disposing of it on-shore. Under no circumstances 

may oils, including oily mixtures, from gas turbine wash water be discharged in waters subject to this permit in 

quantities that may be harmful as determined in accordance with 40 CFR Part 110. 

Estimates of Cost 

No requirements within this discharge category require cost analysis because this discharge may not be applicable 

to commercial vessels and it was assumed that vessel operators could easily comply with these permit terms if 

these requirements are applicable. 

December 18, 2008 Final 64
Economic and Benefits Analysis of the Final Vessel General Permit 

6.2.16 Graywater 

Affected Vessel Population 

Based on the description of practices within this discharge category, graywater discharges are applicable to every 

vessel class except for freight barges and tank barges. However, there is some overlap with the Clean Water Act’s 

existing provisions and with 33 CFR159.309, as well as overlap regarding the number of vessels that currently 

practice specific BMPs. The American Waterways Operators, within the public comments, stated that all towing 

vessels currently use environmentally friendly detergents. 

The population potentially affected by BMPs applicable to the graywater discharge category is shown in Table 

6-25. 

Table 6-25: Vessel Counts for Graywater BMPs 

Vessel Class Non-Oceangoing 

Vessel Counta

Oceangoing 

Vessel Count 

Total Vessel 

Count 

Freight Barges 0 0 0 

Freight Ships 112 555 667 

Passenger Vessels 1,688 9,682 11,370 

Tank Barges 0 0 0 

Tank Ships 13 129 142 

Utility Vessels 5,697 5,121 10,818 

TOTAL 7,510 15,487 22,997 

a Includes vessels operating on the Great Lakes, Mississippi River, and intracoastal waterways. 

Permit Requirements 

Permit Text: 

All vessels must minimize the discharge of graywater while in port. For those vessels that cannot store graywater, 

the owner or operator and their crews should minimize the production of graywater in port. All vessels that have 

the capacity to store graywater shall not discharge that graywater in waters listed in Part 12.1. For vessels that 

cannot store graywater, vessel operators must minimize the production of graywater while in waters listed in Part 

12.1. 

For vessels greater than 400 gross tons that regularly travel more than 1 nm from shore that have the capacity to 

store graywater for a sufficient period, graywater must be discharged greater than 1 nm from shore while the 

vessel is underway, unless the vessel meets the treatment standards and other requirements contained under Parts 

5.1.1 and 5.1.2 or 5.2.1 and 5.2.2 of this permit. Additional specific requirements for Graywater apply to Cruise 

Vessels (Parts 5.1 and 5.2) and Large Ferries (Part 5.3). 

Vessels that do not travel more than 1 nm from shore shall minimize the discharge of graywater and, provided the 

vessel has available graywater storage capacity, must dispose of graywater on shore if appropriate facilities are 

available and such disposal is economically practicable and achievable unless the vessel meets the treatment 

standards and other requirements contained under Parts 5.1.1 and 5.1.2 or 5.2.1 and 5.2.2 of this permit. 

Minimize the discharge of graywater when the vessel is not underway. 

If graywater will be discharged in waters subject to this permit, the introduction of kitchen oils must be minimized 

to the graywater system. When cleaning dishes, you must remove as much food and oil residue as practicable 

before rinsing dishes. Oils used in cooking shall not be added to the graywater system. Oil from the galley and 

scullery shall not be discharged in quantities that may be harmful as defined in 40 CFR Part 110. 

December 18, 2008 Final 65
Economic and Benefits Analysis of the Final Vessel General Permit 

Vessel owner/operators must use phosphate free and non-toxic soaps and detergents for any purpose if they will 

be discharged into waters subject to this permit. These detergents must be free from toxic or bioaccumulative 

compounds and not lead to extreme shifts in receiving water pH. 

If you are underway in a nutrient impaired water, or a water that is impaired as a result of nutrient enrichment 

(such as waters listed as impaired for phosphorus, nitrogen, or for hypoxia or anoxia (low dissolved oxygen 

concentrations)) you must follow these additional steps: 

When the vessel has adequate graywater storage capacity, the vessel owner/operator shall not discharge 

graywater into nutrient impaired waters subject to this permit (e.g., the Chesapeake Bay). A complete list of such 

waters can be found at www.epa.gov/npdes/vessels. Where the vessel does not have adequate storage capacity to 

eliminate such discharges, graywater production and discharge must be minimized in such waters. Any such 

discharge must be conducted while the vessel is underway in areas with significant circulation and depth to the 

extent feasible. Graywater stored while in such waters can later be disposed of on shore or discharged in 

accordance with the other requirements of this permit. 

Estimates of Cost 

Based upon survey responses, practices associated with graywater involve no incremental cost. The majority of 

vessels (excluding passenger vessels) produce little to no graywater. Thus, they are not able to store their 

graywater in appropriate tanks. Instead, they produce and discharge graywater simultaneously. A survey response 

from a ferry company indicated that the company’s vessels discharge all graywater onshore at appropriate 

facilities. 

Furthermore, based upon outside research and communication with a vendor, there is no incremental cost 

associated with the purchase of phosphate free soaps or detergents. There are varied prices among high and low 

end products. However, there is enough variability among prices that a vessel could opt for a standard phosphate 

free product in lieu of a high end non-phosphate free product. 

6.2.17 Motor Gasoline and Compensating Discharge 

Affected Vessel Population 

The costs incurred in this discharge category are assumed to be negligible and/or the industry is assumed to 

currently practice the Permit requirements. Thus, the vessel population that would apply to this Permit was not 

estimated since no vessels are expected to experience any cost. 

Permit Requirements 

Permit Text: 

The discharge of motor gasoline and compensating effluent must not have oil in quantities that may be harmful as 

defined in 40 CFR 110.3, which includes discharges resulting in a visible sheen, or an oil concentration that 

exceeds 15 ppm. Determination of oil concentration may be measured by EPA Method 1664 or other appropriate 

method for determination of oil content as accepted by the International Maritime Organization (IMO) (e.g. ISO 

Method 9377) or U.S. Coast Guard. Compliance with the 15 ppm oil concentration limitation may be established 

with visual monitoring for an oily sheen. Minimize discharge of motor gasoline and compensating discharge in 

port. If an oily sheen is observed, the vessel operator must deploy appropriate oil containment practices. Vessels 

shall not discharge motor gasoline and compensating discharge in waters subject to this permit listed in Part 

12.1. 

December 18, 2008 Final 66
Economic and Benefits Analysis of the Final Vessel General Permit 

Estimates of Cost 

No requirements within this discharge category require cost analysis because these practices are assumed to have 

negligible costs and/or the industry is assumed to currently practice the Permit requirements. 

6.2.18 Non-Oily Machinery Wastewater 

Affected Vessel Population 

The costs incurred in this discharge category are assumed to be negligible and/or the industry is assumed to 

currently practice the Permit requirements. Thus, the vessel population that would apply to this Permit was not 

estimated since no vessels are expected to experience any cost. 

Permit Requirements 

Permit Text: 

If discharged directly overboard, non-oily machinery wastewater must be free from oils and any additives that are 

toxic or bioaccumulative in nature. Non-oily machinery wastewater may also be drained to the bilge. 

Estimates of Cost 

No requirements within this discharge category require cost analysis because these practices are assumed to have 

negligible costs and/or the industry is assumed to currently practice the Permit requirements. 

6.2.19 Refrigeration and Air Condensate Discharge 

Affected Vessel Population 

The costs incurred in this discharge category are assumed to be negligible and/or the industry is assumed to 

currently practice the Permit requirements. Thus, the vessel population that would apply to this Permit was not 

estimated since no vessels are expected to experience any cost. 

Permit Requirements 

Permit Text: 

You must not allow refrigeration and air condensate discharge to come into contact with oily or toxic materials if 

it is discharged directly overboard. Refrigeration and air conditioning condensate that is collected and plumbed 

for internal recycling (e.g. recycled as “technical water”) is allowed to commingle with oily water; however, the 

commingled discharge must meet all requirements of Part 2.1.4 of this permit and Part 2.2.2 of this permit if 

applicable. 

Estimates of Cost 

No requirements within this discharge category require cost analysis because these practices are assumed to have 

negligible costs and/or the industry is assumed to currently practice the Permit requirements. 

December 18, 2008 Final 67
Economic and Benefits Analysis of the Final Vessel General Permit 

6.2.20 Seawater Cooling Overboard Discharge (including non-contact engine cooling water; 

hydraulic system cooling water, refrigeration cooling water) 

Affected Vessel Population 

The costs incurred in this discharge category are assumed to be negligible and/or the industry is assumed to 

currently practice the Permit requirements. Thus, the vessel population that would apply to this Permit was not 

estimated since no vessels are expected to experience any cost. 

Permit Requirements 

Permit Text: 

When possible, seawater cooling overboard should be discharged when the vessel is underway so that any 

thermal impacts are dispersed. 

To reduce the production and discharge of seawater cooling overboard discharge, EPA recommends that vessel 

owner/operators use shore based power when the vessel is in port if: 

3⁄4 Shore power is readily available for vessel owner/operators from utilities or port authorities; 

3⁄4 Shore based power supply systems are capable of providing all needed electricity required for vessel 

operations; and 

3⁄4 The vessel is equipped to connect to shore-based power and such systems are compatible with the 

available shore power. 

Maintenance of all piping and seawater cooling systems must meet the requirements of Part 2.2.20 (SeawaterPiping Biofouling Prevention). 

Estimates of Cost 

No requirements within this discharge category require cost analysis because these practices are assumed to have 

negligible costs and/or the industry is assumed to currently practice the Permit requirements. 

6.2.21 Seawater Piping Biofouling Prevention 

Affected Vessel Population 

The costs incurred in this discharge category are assumed to be negligible and/or the industry is assumed to 

currently practice the Permit requirements. Thus, the vessel population that would apply to this Permit was not 

estimated since no vessels are expected to experience any cost. 

Permit Requirements 

Permit Text: 

Seawater piping biofouling chemicals subject to FIFRA registration (see 40 CFR 152.15) must be used in 

accordance with their FIFRA label. No pesticides or chemicals banned for use in the United States may be 

discharged into waters subject to this permit. 

Vessel owner/operators must use the minimum amount of biofouling chemicals needed to keep fouling under 

control. Discharges containing active agents must contain as little chlorine as possible. 

December 18, 2008 Final 68
Economic and Benefits Analysis of the Final Vessel General Permit 

Vessel owner/operators must remove fouling organisms from seawater piping on a regular basis and dispose of 

removed substances in accordance with local, State, and federal regulations. Removed fouling organisms shall 

not be discharged into waters subject to this permit and EPA recommends that if discharged into waters, should 

be discharged more than 50 nm from shore. Vessel owner/operators should remove any organisms while at sea to 

reduce the risk of invasive species introduction in ports. 

Estimates of Cost 

No requirements within this discharge category require cost analysis because these practices are assumed to have 

negligible costs and/or the industry is assumed to currently practice the Permit requirements. 

6.2.22 Boat Engine Wet Exhaust 

Affected Vessel Population 

The costs incurred in this discharge category are assumed to be negligible and/or the industry is assumed to 

currently practice the Permit requirements. Thus, the vessel population that would apply to this Permit was not 

estimated since no vessels are expected to experience any cost. 

Permit Requirements 

Permit Text: 

Vessels generating wet exhaust must be maintained in good operating order, well tuned, and functioning 

according to manufacturer specifications if available to decrease pollutant contributions to wet exhaust. Vessel 

owner/operators should use low sulfur or alternative fuels for their vessels to reduce the concentration of 

pollutants in their discharge. 

EPA encourages vessel operators to consider four stroke versus two stroke engines for vessels generating wet 

exhaust that are covered under this permit. Use of a four stroke engine may minimize the discharge of pollutants 

to US waters. 

Estimates of Cost 

No requirements within this discharge category require cost analysis because these practices are assumed to have 

negligible costs and/or the industry is assumed to currently practice the Permit requirements. 

6.2.23 Sonar Dome Discharge 

Affected Vessel Population 

The costs incurred in this discharge category are assumed to be negligible and/or the industry is assumed to 

currently practice the Permit requirements. Thus, the vessel population that would apply to this Permit was not 

estimated since no vessels are expected to experience any cost. 

Permit Requirements 

Permit Text: 

December 18, 2008 Final 69
Economic and Benefits Analysis of the Final Vessel General Permit 

The water inside the sonar dome shall not be discharged within waters subject to this permit for maintenance 

purposes. Vessel operators should not use biofouling chemicals that are bioaccumulative for the exterior of sonar 

domes when other viable alternatives are available. 

Estimates of Cost 

No requirements within this discharge category require cost analysis because these practices are assumed to have 

negligible costs and/or the industry is assumed to currently practice the Permit requirements. 

6.2.24 Underwater Ship Husbandry Discharges 

Affected Vessel Population 

Based on the description of practices within this discharge category, the subset of vessels that would apply to 

practices in underwater ship husbandry was determined. The industry is assumed to currently practice the Permit 

requirements. However, the vessel population that would apply to this Permit was estimated since some of these 

vessels may follow the recommendation to use vacuum control technologies. 

The population potentially affected by BMPs applicable to discharges in the underwater ship husbandry category 

is shown in Table 6-26. 

Table 6-26: Vessel Counts for Underwater Ship Husbandry BMPs 

Vessel Class Vessel Count 

Freight Barges 0 

Freight Ships 0 

Passenger Vessels 11,521 

Tank Barges 0 

Tank Ships 0 

Utility Vessels 0 

TOTAL 11,521 

Permit Requirements 

Permit Text: 

Vessel owner/operators must minimize the transport of attached living organisms when they travel into U.S. 

waters from outside the U.S. economic zone or when traveling between COTP zones. 

Whenever possible, rigorous hull-cleaning activities should take place in drydock, or another land-based facility 

where the removal of fouling organisms or spent antifouling coatings paint can be contained. If water-pressure 

based systems are used to clean the hull and remove old paint, use facilities which treat the washwater prior to 

discharge to remove the antifouling compound(s) and fouling growth from the washwater. 

Vessel owner/operators who remove fouling organisms from hulls while the vessel is waterborne must employ 

methods that minimize the discharge of fouling organisms and antifouling hull coatings. These shall include: 

3⁄4 Selection of appropriate cleaning brush or sponge rigidity to minimize removal of antifouling coatings 

and biocide releases into the water column. 

3⁄4 Limiting use of hard brushes and surfaces to the removal of hard growth. 

3⁄4 When available and feasible, use of vacuum control technologies to minimize the release or dispersion of 

antifouling hull coatings and fouling organisms into the water column. 

December 18, 2008 Final 70
Economic and Benefits Analysis of the Final Vessel General Permit 

Vessel owner/operators must minimize the release of copper based antifoulant paint into the water column when 

they clean their vessel. Cleaning of copper based antifoulant paints must not result in any visible cloud or plume 

of paint in the water: if a visible cloud or plume of paint develops, shift to a softer brush or less abrasive cleaning 

technique. A plume or cloud of paint can be noted by the presence of discoloration or other visible indication that 

is distinguishable from hull growth or sediment removal. Production of a plume or cloud of sediment or hull 

growth is normal in some cases during vessel hull cleaning, but this plume or cloud should be substantially paint 

free (e.g. paint should not be clearly identifiable in the plume or cloud). 

Vessels that use copper based anti-fouling paint must not clean the hull in copper impaired waters within the first 

365 days after paint application unless there is a significant visible indication of hull fouling.

Estimates of Cost 

Since practices associated with underwater ship husbandry are contracted to diving companies, information 

gathered from diving companies is most useful. According to communication with a diving company based in 

Florida (Seacor, 2008), it is standard to clean the hull using the appropriate Permit standards. It is also standard to 

use vacuum brushes to clean the hull. However, vacuum control technologies that completely avoid the release of 

hull coatings and organisms into the water column are not readily available to most diving companies because the 

cost of renting this advanced technology is near $1 million per cleaning. Thus, this practice is only recommended, 

not required. 

The additional BMPs within this discharge category are currently practiced by the contracted diving companies. 

Therefore, the costs incurred for the additional BMPs are currently negligible. In general, the BMPs associated 

with underwater hull husbandry are applicable to the diving companies contracted by the vessel company. The 

practices that they perform to clean the hull depend on the hull’s condition. The diving company gave an average 

cost of $25,000 to $35,000 to perform underwater hull cleaning for a large cruise ship. This price is dependent on 

the dive depth as well as other technologies that are necessary for hull cleaning. 

6.2.25 Welldeck Discharges 

Affected Vessel Population 

The costs incurred in this discharge category are assumed to be negligible and/or the industry is assumed to 

currently practice the Permit requirements. Thus, the vessel population that would apply to this Permit was not 

estimated since no vessels are expected to experience any cost. 

Permit Requirements 

Permit Text: 

Welldeck discharges that contain graywater from smaller vessels should not be discharged within waters subject 

to this permit except in cases of emergency. Welldeck discharges from washdown of gas turbine engines may not 

be discharged within waters subject to this permit. Welldeck discharges from equipment and vehicle washdowns 

must be free from garbage and must not contain oil in quantities that may be harmful as defined in 40 CFR Part 

110. 

Estimates of Cost 

No requirements within this discharge category require cost analysis because these practices are assumed to have 

negligible costs and/or the industry is assumed to currently practice the Permit requirements. 

December 18, 2008 Final 71
Economic and Benefits Analysis of the Final Vessel General Permit 

6.2.26 Graywater Mixed with Sewage from Vessels 

Affected Vessel Population 

The costs incurred in this discharge category are assumed to be negligible and/or the industry is assumed to 

currently practice the Permit requirements. Thus, the vessel population that would apply to this Permit was not 

estimated since no vessels are expected to experience any cost. 

Permit Requirements 

Permit Text: 

The commingled discharge of graywater mixed with sewage from vessels must comply with the effluent limits for 

graywater discharge in Part 2 or Part 5 of this permit if applicable. Though not a requirement of this permit, 

vessel owner/operators are advised that all discharges commingled with sewage must meet the requirements set 

forth in section 312 of the Clean Water Act and its implementing regulations found at 40 CFR Part 140 and 33 

CFR Part 159. Hence, discharges of graywater mixed with sewage must meet both standards to be in compliance 

with the Clean Water Act. 

Estimates of Cost 

No requirements within this discharge category require cost analysis because these practices are assumed to have 

negligible costs and/or the industry is assumed to currently practice the Permit requirements. 

6.2.27 Exhaust Gas Scrubber Washwater Discharge 

Affected Vessel Population 

The costs incurred in this discharge category are assumed to be negligible because of the limited number of 

vessels producing this discharge. Thus, the complete vessel population that would apply to this Permit was not 

estimated since a limited number of vessels, if any, are expected to experience any incremental cost. 

Permit Requirements 

Permit Text: 

Exhaust gas scrubber washwater discharge must not contain oil, including oily mixtures, in quantities that may be 

harmful as determined in accordance with 40 CFR Part 110. Sludge generated from exhaust gas scrubber 

washwater discharge must not be discharged in waters subject to this permit. In addition, EPA recommends that 

owner/operators of vessels with exhaust gas cleaning systems that result in washwater discharges follow the 

guidelines set out in section 10 for Exhaust Gas Cleaning Systems (resolution MEPC.170(57)). 

Estimates of Cost 

EPA believes that these limits and BMPs are reasonable for the final Vessel General Permit and do not require 

cost analysis because the current volume of exhaust gas scrubber washwater discharge is low due to the limited 

number of vessels utilizing exhaust gas cleaning systems. At this time, EPA is aware of only one vessel that sails 

in U.S. waters and uses this technology. 

December 18, 2008 Final 72
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 73

6.3 Per-Vessel Costs for Vessel-Specific Requirements 

6.3.1 Large and Medium Cruise Ships 

Affected Vessel Population 

The population estimate shown in Table 6-27 is provided by Cruise Lines International Association (CLIA). 

Large sized cruise ships are in the 500+ passenger/crew capacity classification, and medium sized cruise ships are 

in the 100–499 passenger/crew capacity classification.22 

Table 6-27: Cruise Ship Counts 

Vessel Classa Alaskan Certified 

Cruise Ships 

Non- Alaskan 

Certified Cruise Ships Total Count 

Large Cruise Ships 30 113 143 

Medium Cruise Shipsc 0 32 32 

TOTAL 30 145 175b

a Cruise ships fall within the passenger vessels category. 

b This count is based upon CLIA populations. There may be an additional 5% that are non-CLIA members. 

c The estimated number of medium cruise ships was determined based upon a 250-499 passenger/crew capacity classification 

rather than the 100-499 range. However, based on preliminary data provided by CLIA, there are very few cruise ships within the 

100-249 passenger/crew capacity classification. EPA therefore expects that the estimate is only slightly below the actual universe 

of medium cruise ships. 

Permit Requirements 

Permit Sections Summary: 

Sculleries and Galleys:

Cruise ship owner/operators must use detergents that are phosphate free. Degreasers must be non-toxic if they 

will be discharged as part of any waste stream. 

Hazardous Waste

Waste from mercury containing products, dry cleaners or dry cleaner condensate, photo processing labs, medical 

sinks or floor drains, chemical storage areas, and print shops using traditional or non-soy based inks and 

chlorinated solvents must be prevented from entering the ship’s graywater, blackwater, or bilgewater systems if 

water from these systems will ever be discharged into waters subject to this permit. Preventing these wastes from 

entering these systems can be accomplished by plugging all drains that flow to the graywater, blackwater, or 

bilge systems in areas where these wastes are produced and creating alternate waste receptacles or replumbing 

drains to appropriate holding tanks. 

Vessel owner/operators must not discharge any toxic or hazardous materials, including products containing 

acetone, benzene, or formaldehyde into salon and day spa sinks or floor drains if those sinks or floor drains lead 

to any system which will ever be discharged into waters subject to this permit. This includes using these materials 

on passengers (or crew) and rinsing residuals into these sinks. Alternate waste receptacles or holding tanks must 

be used for these materials. Additions of these materials to any systems which will discharge into waters subject 

to this permit is a permit violation. 

 

22 The estimated number of medium cruise ships in Table 6-27 was determined based upon a 250-499 passenger/crew capacity 

classification rather than the 100-499 range. However, based on preliminary data provided by CLIA, there are very few cruise ships within 

the 100-249 passenger/crew capacity classification. EPA therefore expects that the estimate is only slightly below the actual universe of 

medium cruise ships. 
Economic and Benefits Analysis of the Final Vessel General Permit 

Discharge Standards:

Pierside Limits: While pierside, appropriate reception facilities for graywater must be used, if reasonably 

available unless the vessel treats graywater with a device to meet the standards in Part 5.1.1.1.2. If such facilities 

are not reasonably available, you must treat graywater with a device to meet the standards in Part 5.1.1.1.2 or hold 

the graywater for discharge while the vessel is underway and discharge according to the operational limits below. 

Appropriate reception facilities are those authorized for use by the port authority or municipality and that treat the 

discharge in accordance with its NPDES permit. 

Operational Limits: You must meet the following restrictions: 

3⁄4 While operating within 1 nm from shore, discharges of graywater are prohibited unless they meet the 

effluent standards in Part 5.1.1.1.2. 

3⁄4 If you operate between 1 nm and 3 nm from shore, discharges of graywater must either: (1) meet the 

effluent standards in Part 5.1.1.1.2, or (2) be released while the Cruise Ship is sailing at a speed of at 

least 6 knots in a water that is not listed in Part 12.1. 

Nutrient Impaired Water Limits: If you operate in nutrient impaired waters including the Chesapeake Bay or the 

territorial Sea surrounding the mouth of the Mississippi River in the Gulf of Mexico, you must: 

3⁄4 Not discharge any graywater in nutrient impaired waters subject to this permit unless the length of 

voyage in that water exceeds the vessel’s holding capacity for graywater; and 

3⁄4 Minimize the discharge of any graywater into nutrient impaired waters subject to this permit, which may 

require minimizing the production of graywater; and 

3⁄4 If your vessel’s holding capacity for graywater is exceeded, treat such excess graywater (above the vessel 

holding capacity) by a device meeting the standards in Part 5.1.1.1.2 prior to discharge into nutrient 

impaired waters subject to this permit or 

3⁄4 Dispose of the graywater properly on shore. 

3⁄4 A list of nutrient impaired waters is available at www.epa.gov/npdes/vessels. 

Treatment Standards:

The discharge of treated graywater must meet the following standards: 

1. The discharge must satisfy the minimum level of effluent quality specified in 40 CFR 133.102; 

2. The geometric mean of the samples from the discharge during any 30-day period may not exceed 20 fecal 

coliform/100 milliliters (ml) and not more than 10 percent of the samples exceed 40 fecal coliform/100 ml; 

and 

3. Concentrations of total residual chlorine may not exceed 10.0 micrograms per liter (μg/l). 

Monitoring Requirements: The owner/operator must maintain records estimating all discharges of untreated 

graywater into waters subject to this permit, including date, location and volume discharged and speed of the 

vessel at the time of discharge in their recordkeeping documentation. These records can be maintained as part of 

the vessel’s sewage and graywater discharge record book required under 33 CFR §159.315. 

Prior to entering waters of the U.S., vessel operators must demonstrate that they have an effective treatment 

system that complies with the standards in Part 5.1.1.1.2 if they will discharge graywater: 

3⁄4 within 1 nm of shore, or 

3⁄4 within 3 nm of shore and sailing less than 6 knots 

December 18, 2008 Final 74
Economic and Benefits Analysis of the Final Vessel General Permit 

In order to demonstrate the effectiveness of the treatment system, the vessel operator must take at least five (5) 

samples taken from the vessel on different days over a 30-day period that are representative of the treated effluent 

to be discharged. Initial monitoring must be done within the first 90 days of permit coverage, within 90 days of 

AWTS installation onboard the vessel, or before vessels discharge into waters subject to this permit. Samples 

must be taken for biochemical oxygen demand (BOD), fecal coliform, suspended solids, pH, and total residual 

chlorine. Sampling and testing shall be conducted according to 40 CFR Part 136. If the measured samples meet 

the standards specified in Part 5.1.1.1.2, then the owner/operator has demonstrated the effectiveness of their 

treatment system for controlling their graywater discharge. Records of the sampling and testing results must be 

retained onboard for a period of 3 years in the vessel’s recordkeeping documentation. 

Records of monitoring information shall include: 

3⁄4 The date, exact place, and time of sampling or measurements; 

3⁄4 The individual(s) who performed the sampling or measurements; 

3⁄4 The date(s) analyses were performed; 

3⁄4 The individual(s) who performed the analyses; 

3⁄4 The analytical techniques or methods used; and 

3⁄4 The results of such analyses. 

Analytical results for total residual chlorine below the method detection limit shall be deemed compliant with the 

effluent limits, provided the permittee uses a testing method with a detection limit no higher than 10.0 μg/L under 

ideal conditions. EPA recommends method SM4500-CL G (DPD Colorimetric Method) for these purposes as it is 

able to reach 10 μg/L under ideal conditions and so meets these requirements. SM4500-Cl G is typically the 

method that ADEC/USCG uses for compliance monitoring. 

Testing and reporting for total residual chlorine is not required if chlorine is not used as disinfectant in the 

wastewater treatment works process and no water is drained to the graywater system from water with onboard 

chlorine additions (e.g. swimming pools, spas. . .). 

If a permittee has already received certification for continuous discharges from AWTS by the United States Coast 

Guard to meet the requirements of Section 1411(b) of Title XIV, Pub. L. 106-554 (Dec. 31, 2000, 114 Stat. 2763) 

[Certain Alaska Cruise Ship Operations] (codified at 33 U.S.C. 1901 note), the vessel need not conduct initial 

monitoring and may commence conducting maintenance monitoring. 

After demonstrating the effectiveness of their system, vessel owner/operators must collect and analyze one sample 

per quarter for each of the constituents analyzed in Part 5.1.2.2.1 to demonstrate treatment equipment 

maintenance and compliance with this permit. Records of the sampling and testing results must be retained 

onboard for a period of 3 years in the vessel’s recordkeeping documentation. 

Educational and Training Requirements:

The crews of cruise ships play a key role in minimizing the discharge of pollutants from cruise ship operations 

and passengers. Therefore cruise ship operators are subject to the following requirements: 

3⁄4 The ship’s crew members who actively take part in the management of a discharge or who may affect any 

discharge must receive training regarding shipboard environmental procedures and must be able to 

demonstrate proficiency in implementing these procedures. 

3⁄4 Advanced training in shipboard environmental management procedures must be provided for those 

directly involved in managing specific discharge types or areas of the ship and these crew members must 

be able to demonstrate proficiency in implementing these procedures. 

December 18, 2008 Final 75
Economic and Benefits Analysis of the Final Vessel General Permit 

3⁄4 Appropriate reprimand procedures must be developed for crew whose actions lead to violations of any 

effluent limit set forth in this permit or procedures established by the cruise ship operator to minimize the 

discharge of pollutants. 

Cruise ships must also educate passengers on their potential environmental impacts. The goals of these education 

efforts should include preventing trash from entering any waste stream, eliminating the addition of unused soaps, 

detergents, and pharmaceuticals to the graywater or blackwater systems and minimizing production of graywater. 

This can be accomplished in a variety of ways including, but not limited to posting signage and informational 

material in guestrooms and common areas, incorporating environmental information passenger orientation 

presentations or packages at the start of cruises, incorporating this information into additional lectures and 

seminars, or broadcasting information via loudspeakers. 

Estimates of Cost 

The majority of the BMPs associated with cruise ship graywater management are already practiced by the cruise 

ship industry. The cruise line members (including both large and medium cruise ships) of CLIA—which represent 

approximately 95 percent of the entire cruise line industry—adhere to the CLIA industry standard for certain 

BMPs, including preventing hazardous waste from photo processing labs, dry cleaners or dry cleaner condensate, 

and print shops from entering the ship’s graywater system. Furthermore, according to a CLIA industry 

representative based on survey response, nearly all of the other practices associated with the Permit standards are 

already practiced by the cruise line industry: 

Pierside and Operational Limits: These discharge standards associated with the Permit involve no incremental 

cost because both large and medium cruise ships have sufficient holding capacity to avoid discharging within 

1 nm from shore. Discharges within 3 nm from shore currently undergo graywater treatment or are discharged 

while the ship is sailing at a speed of at least 6 knots. Furthermore, regarding the Permit specifications, according 

to an industry representative, reception facilities for graywater are very rare and are not commonplace even at 

major ports. 

Medium cruise ships will incur no incremental cost associated with this practice since the Permit standards are 

already practiced. Medium cruise ships that are able to voyage more than 1 nm are already complying with 

graywater treatment standards. These ships have the option to discharge graywater in nutrient impaired waters 

while sailing at a speed of at least 6 knots. Since this is already an industry standard, according to the CLIA 

representative, there is no incremental cost associated with this Permit requirement. 

Limits Applicable to Operation in Nutrient Impaired Waters: These limits are applicable to only a subset of large 

cruise ships: those that operate in these waters whose graywater holding capacity is exceeded due to the voyage 

length. These cruise ships will be required to treat the graywater prior to discharge. According to an industry 

representative, all non-Alaskan operating cruise ships that operate in nutrient impaired waters have the capacity to 

hold their graywater until they are allowed to discharge. Therefore, there is no incremental cost for these ships. 

According to estimates provided by an industry representative, there are 30 cruise ships operating in Alaska that 

already have a graywater treatment system installed. These ships are assumed to incur incremental operation and 

maintenance cost. EPA gathered information as part of its evaluation of standards for discharges of sewage and 

graywater from cruise ships operating in Alaska. Based upon these data, EPA estimates the average cost per 

passenger (including crew), per season, for operation and maintenance of a graywater treatment system at $7.09. 

This cost is applied to the preliminary average large cruise ship passenger/crew capacity of 3,211 to derive an 

average annual incremental cost per cruise ship of operating and maintaining a graywater treatment system: 

December 18, 2008 Final 76
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 77

$22,765.99. The total incremental cost for this requirement across the 30 large cruise ships is therefore estimated 

at $683,022.24.23 

Existing medium cruise ships unable to voyage more than 1 nm from shore must not immediately meet graywater 

treatment standards found in Part 5.2.1.1.1 of the VGP. However, medium sized cruise ships that are unable to 

voyage 1 nm from shore must meet the graywater discharge requirements if they are constructed (including major 

conversions) on or after the permit issuance date. Within the Seatrade Cruise Review (December 2007 issue), a 

CLIA representative indicated that no ships within the medium sized cruise ship category and for the particular 

style (i.e. those that are unable to voyage 1 nm from shore) are scheduled to be newly constructed. However, EPA 

assumes that medium sized cruise ships are replaced or undergo a major conversion at a rate of approximately 

once every 30 years. EPA identified four medium sized cruise ships that are unable to voyage 1 nm from shore 

(CLIA). In estimating the costs of this requirement, EPA also assumed that an additional eight medium cruise 

ships during the 30-year period will install graywater treatment systems even if they have the ability to voyage 1 

nm from shore so that they may discharge graywater within 1 nm. This brings the total number of medium cruise 

ships assumed to purchase a graywater treatment system over the 30-year period to twelve, or an average of two 

ships within each 5-year period. The estimate of costs of installing, operating and maintaining a graywater 

treatment system is based upon EPA information gathered as part of its evaluation of standards for discharges of 

sewage and graywater from cruise ships operating in Alaska. Based upon these data, EPA estimated the average 

capital cost of installing a graywater treatment system at $1,150 per passenger (including crew), while the cost of 

operating and maintaining the graywater treatment system is $7.09 per capita and per season. The average capital 

cost is annualized over 30 years using a 7 percent discount rate to derive an annual capital cost of $92.67 per 

passenger (including crew). Assuming an average number of 557 passengers and crew, the total cost per cruise 

ship is approximately $55,589. The total annual cost associated with the medium and large sized cruise ships is 

detailed in Table 6-28. 

Table 6-28: Cruise Ship Costs Associated with the Purchase/Operation and Maintenance of a 

Graywater Treatment Systema

Vessel Class 

Total Number 

of Vessels 

Incremental 

Number of Vessels 

that need to Install 

and/or Operate and 

Maintain a 

Graywater 

Treatment Systema

Annual Cost 

per Passenger 

and Crew 

Average 

Number of 

Passengers and 

Crew Total Annual Cost 

Large Cruise Ships 113 30 $7.09 3,211 $683,022 

Medium Cruise Ships 12 12b $99.76 557 $111,177 

TOTAL 125 42 $794,200 

a Large cruise ships are assumed to incur a cost of $7.09 per passenger and crew for operation and maintenance of the graywater

system.. Medium cruise ships are assumed to incur costs of $92.67 + $7.09 per passenger and crew for the capital expense of installing 

the graywater system, and operating and maintaining the system, respectively. 

b Twelve medium cruise ships are expected to need to install a graywater treatment system over a 30-year period. However, only two 

medium cruise ships are expected to undergo major conversions within each 5-year period (5 years is the scope of this Permit). 

Sculleries and Galleys: Based upon industry communication as well as outside research with a vendor, EPA has 

found that there is no incremental cost of purchasing phosphate free soaps and non-toxic degreasers in lieu of 

standard soaps and degreasers. There are varied prices among high and low end products. However, there is 

enough variability among prices that a ship could opt for a standard phosphate free/non-toxic product in lieu of a 

 

23 Large cruise ships are not anticipated to install a graywater treatement system to comply with the VGP since they either currently have 

such a system in place, or have other compliance options available to them, including holding their graywater until they are allowed to 

discharge. If a graywater treatment system were required, EPA estimates that the capital cost of installing such as system averages $1,050 

per passenger, or approximately $3.4 million for a large cruise ship having the average passenger/crew capacity of 3,211. 
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 78

high end, non-phosphate free/toxic product. Also, the industry representative was not able to provide the 

percentage of large or medium ships that use these phosphate free/non-toxic products or the annual average 

number of gallons that are purchased by a ship. However, since there is no incremental cost associated with 

purchasing the phosphate free/non-toxic products, it is unnecessary to determine the population of ships to which 

this Permit requirement would apply. 

Hazardous Waste: CLIA industry standards, as mentioned previously, already account for the Permit practices 

associated with some of the waste sources. Furthermore, based on communication with a CLIA representative, the 

other source drains (medical, salon, and chemical sources) are currently either replumbed to appropriate holding 

tanks, or are plugged and alternative waste receptacles are used. Thus, there is no incremental cost associated with 

this Permit standard for both large and medium cruise ships. 

Untreated Graywater Documentation: Based on communication with a CLIA representative, documentation of 

these discharges is common practice. Thus, there is no incremental cost associated with this Permit standard for 

both large and medium cruise ships. 

Monitoring: Sampling and analysis cost estimates of treated graywater are based upon communication with a 

CLIA representative and a field expert. The cost associated with one sampling event is approximately $1,000 per 

ship. The actual cost of testing an individual sample, such as for biochemical oxygen demand (BOD), is low 

(approximately $50–$100); however, there is much more cost involved with the administration, setup, quality 

control, reporting, etc., of the actual sampling event.24 Furthermore, most non-Alaskan cruise ships would need to 

perform the samplings and have them sent to labs at foreign ports. Sampling costs at foreign ports are 

considerably higher than at domestic ports. Due to the varied itineraries of cruise ships, there can be wide 

variability among the cost of a sampling event—$1,000 per sampling event is an average provided by the 

industry. 

The sampling event accounts for the testing of each of the four chemicals (i.e., BOD, suspended solids, pH, and 

total residual chlorine). The Permit specifications call for five sampling events over a 30-day period, four times a 

year. Thus, twenty sampling events per ship must occur on an annual basis. Based upon the $1,000 average 

sampling cost, an annual incremental cost per ship of $20,000 is estimated for both large and medium cruise ships 

that have a standard graywater treatment system and do not currently follow the Permit monitoring requirements. 

According to estimates from a CLIA representative, the population of large cruise ships that will incur this 

incremental cost is 40. The population of medium cruise ships was originally estimated to be five; however EPA 

assumes this number to now be seven with the addition of two medium sized cruise ships that are expected to 

undergo major conversions during the 5-year period. Thus, the total annual incremental cost for both large and 

medium cruise ships is $940,000. Table 6-29 details the cost estimates. 

Table 6-29: Cruise Ship Costs Associated with Sampling 

Vessel Class 

Total Number 

of Vessels 

Incremental Number 

of Vessels that need to 

Perform Sampling 

Annual Cost 

per Vessel Total Cost 

Large Cruise Ships 113 40 $20,000 $800,000 

Medium Cruise Ships 0 7 $20,000 $140,000 

TOTAL 113 47 $940,000 

 

24 The proposed VGP did not include fecal coliform in the sampling requirement. After communicating with analytical labs, it was 

determined that the addition of fecal coliform into the sampling event would not pose any substantial incremental cost (McKee, 2008). 

Therefore, the estimate of $1,000 per sampling event has not changed from the proposal analysis. Due to the nature of fecal coliform 

analysis, it is anticipated that cruise ship operators will need to sample at a time close to when they arrive to port since there is a six-hour 

window for analysis of fecal coliform samples. Since cruise ships are frequently close to port, however, EPA does not expect this 

requirement to be burdensome. 
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 79

EPA estimates some additional costs corresponding to pool and spa water testing. According to a CLIA 

representative, cruise ships that use chlorine in pools and spas already conduct testing using methods listed in 40 

CFR Part 136. However, cruise ships that use bromine in pools and spas commonly use a Hach pool and spa 

water colorimetric test, a test not listed in Part 136. This colorimetric test can be purchased for approximately $99 

and has a detection limit of 1 ppm. However, a Bromine, Pocket Colorimeter II Test Kit is available that has an 

estimated detection limit of 0.5 ppm or lower. This more accurate instrument and testing kit can be purchased for 

$370 (Hach, 2008). Although not listed in Part 136, EPA considers the latter test appropriate for this particular 

Permit requirement. Therefore, EPA estimates incremental costs to cruise ships that use bromine in their pools 

and/or spas by assuming that cruise ships will need to purchase this more accurate test kit versus the Pool and Spa 

Water Colorimetric Test Kit they currently use. The exact population of cruise ships that would now need to 

purchase a new test kit is unknown. EPA assumes that no medium cruise ships have a pool and/or spa onboard 

and, therefore, will not incur costs due to this requirement. EPA assumes that 80 percent of large cruise ships have 

a pool and/or spa onboard and equal shares (50 percent each) of these large cruise ships use bromine or chlorine in 

their pools/spas. Therefore, 57 cruise ships ((80%*143)*50%) are expected to incur the $370 cost of purchasing a 

more accurate test kit for bromine.25 Table 6-30 details the cost estimate. 

Table 6-30: Cruise Ship Costs Associated with Pool and Spa Water Bromine 

Testing 

Vessel Class 

Total Number 

of Vessels 

Incremental Number 

of Vessels that need to 

Purchase Bromine 

Test Kit 

Annual Cost 

per Vessel Total Cost 

Large Cruise Ships 143 57 $370 $21,164 

Medium Cruise Ships 32 0 $370 $0 

TOTAL 175 57 $21,164 

Educational and Training Requirements: The required training in environmental procedures and the additional 

requirement to educate passengers is already provided and performed by cruise ships as a CLIA standard. Thus, 

there is no incremental cost. 

6.3.2 Large Ferries 

Affected Vessel Population 

The population of vessels associated with large ferries is currently unknown pending finalization of the large ferry 

definition. 

Permit Requirements 

Permit Text: 

Deck Water: 

Large ferries may not discharge untreated below deck water from parking areas or other storage areas for motor 

vehicles or other motorized equipment into waters subject to this permit without first treating the effluent with an 

oily water separator or other appropriate device. Large ferry operators must use oil absorbent cloths or other 

 

25 EPA assumes that there is no incremental cost to cruise ships for purchasing refills of reagents since these must already be purchased for 

the Pool and Spa Water Colorimetric Test Kit. 
Economic and Benefits Analysis of the Final Vessel General Permit 

appropriate spill response resources to clean oily spills or substances from deck surfaces. Any effluent created by 

washing the decks may not be discharged into the waters subject to this permit listed in Part 12.1. 

Coal ash from coal fired propulsion systems on ferries 

The discharge of coal ash from coal fired propulsion systems on a ferry is authorized in waters subject to this 

permit until December 19, 2012. All coal ash discharges must comply with effluent limits in Part 5.3.2.3 of this 

permit. Vessel owner/operators must minimize the discharge of coal ash into waters subject to this permit. 

Minimization techniques shall include: 

3⁄4 Efficient combustion of coal; 

3⁄4 Minimize the ash content of the coal used onboard, but in no event may the ash content exceed 9.5 % (by 

weight and as received); and 

3⁄4 Limiting discharge quantities to those necessary for the safe and efficient operation of the vessel. 

Vessel owner/operators must minimize the sulfur content of all coal ash discharged into waters subject to this 

permit by using coal with the lowest sulfur concentration technologically feasible and economically practicable 

and achievable, but in no event may the sulfur content of the coal exceed 1.023% (by weight and as received). 

Except in emergency situations, as determined and documented in the ship’s log by the vessel’s master, coal ash 

discharge may only occur when the vessel is: 

3⁄4 If in waters subject to this permit, more than 5 nm from any shore and in waters over 100 feet in depth; 

and 

3⁄4 Underway at a speed of at least 6 knots. 

Pierside Limits – While pierside, appropriate reception facilities for Graywater must be used, if reasonably 

available. If such facilities are not reasonably available, you must hold the graywater if the vessel has the holding 

capacity and discharge the effluent while the vessel is underway. Appropriate reception facilities are those 

authorized for use by the port authority or municipality and that treat the discharge in accordance with its 

NPDES permit. 

Operational Limits – You must also meet the following restriction: 

3⁄4 If you operate within 3 nm from shore, discharges of graywater must be released while the ferry is sailing 

at a speed of at least 6 knots if feasible. 

3⁄4

Educational and Training Requirements: The crews of ferries play a key role in minimizing the discharge of 

pollutants from ferry operations and its passengers. Therefore ferry operators are subject to the following 

requirements: 

3⁄4 The ship’s crew members who actively take part in the management of the discharge or who may affect 

the discharge must receive training regarding shipboard environmental procedures and must be able to 

demonstrate proficiency in implementing these procedures. 

3⁄4 Advanced training in shipboard environmental management procedures must be provided for those 

directly involved in managing specific discharge types or areas of the ship and these crew must be able to 

demonstrate proficiency in implementing these procedures. 

3⁄4 Appropriate reprimand procedures must be developed for crew whose actions lead to violations of any 

effluent limit set forth in this permit or procedures established by the Cruise Ship operator to minimize 

the discharge of pollutants. 

December 18, 2008 Final 80
Economic and Benefits Analysis of the Final Vessel General Permit 

Ferry operators must also educate passengers on their potential environmental impacts. The goals of these 

education efforts should include eliminating the discharge of trash overboard, minimizing the production of trash 

from parking areas or other storage areas, eliminating the addition of unused soaps, detergents, and 

pharmaceuticals to the graywater or blackwater systems, and minimizing production of graywater. This can be 

accomplished in a variety of ways including, but not limited to posting signage and informational material in 

common areas, incorporating environmental information into orientation presentations, or broadcasting 

information via loudspeakers. 

Estimates of Cost 

 Based upon the above Permit requirements, costs were not further analyzed for these BMPs since the costs are 

expected to be negligible. Thus, costs regarding graywater BMPs were not further analyzed in this analysis since 

these costs are also expected to be negligible. 

6.3.3 Barges (such as hopper barges, chemical barges, tank barges, fuel barges, crane 

barges, dry bulk cargo barges) 

Affected Vessel Population 

The population of vessels associated with river barges is shown in Table 6-31. 

Table 6-31: Vessel Counts for BMPs Associated with River Barges 

Vessel Class Vessel Count 

Freight Barges 26,638

Freight Ships 0 

Passenger Vessels 0 

Tank Barges 3,856

Tank Ships 0 

Utility Vessels 0 

TOTAL 30,494

Permit Requirements 

Permit Text: 

Additional Effluent Limits

Barges must minimize the contact of below deck condensation with oily or toxic materials, and any materials 

containing hydrocarbon. Whenever barges are pumping water from below deck, the discharge shall not contain 

oil in quantities that may be harmful as defined in 40 CFR Part 110. If a visible sheen is noted, vessel operators 

must initiate corrective action in accordance with Part 3 and meet recordkeeping requirements in Part 4.2 of this 

permit. 

All tank barges must have spill rails and must plug their scuppers before any cargo operations if required by the 

vessel class society. If any spills result during loading or unloading of cargo, vessel owner/operators must 

completely clean up spills or residue before scuppers are unplugged. Once all spills and residue have been 

cleaned, scuppers may be unplugged. 

Vessel owner/operators must clean out cargo residues such that any remaining residue is minimized before 

washing the cargo compartment or tank and discharging wash water overboard. 

December 18, 2008 Final 81
Economic and Benefits Analysis of the Final Vessel General Permit 

Supplemental Inspection Requirements

After every instance of pumping water from areas below decks, or immediately following washing down the decks, 

you must conduct a visual sheen test. The visual sheen test is used to detect free oil by observing the surface of the 

receiving water for the presence of an oily sheen. The operator should focus the inspection on the area 

surrounding the vessel where discharges from below deck or deck washings are discharged into the receiving 

water. A visible sheen is defined in Part 7 of this permit. If a visible sheen is observed, you must initiate corrective 

actions required in Part 3 of this permit and meet recordkeeping requirements in Part 4.2 of this permit. 

Estimates of Cost 

Costs were not analyzed in this analysis since the costs are expected to be negligible. 

6.3.4 Oil Tankers or Petroleum Tankers 

Affected Vessel Population 

The population of vessels associated with oil or petroleum tankers is shown in Table 6-32. 

Table 6-32: Vessel Counts for BMPs Associated with Oil or Petroleum 

Tankers 

Vessel Class Vessel Count 

Freight Barges 0

Freight Ships 0 

Passenger Vessels 0 

Tank Barges 0

Tank Ships 147 

Utility Vessels 0 

TOTAL 147

Permit Requirements 

Permit Text: 

The requirements in Part 5.5 apply to vessel discharges from Oil Tankers or Petroleum Tankers. 

Additional Authorized Discharges

For vessels which have an inert gas system, the effluent produced from inert gas scrubbers (IGS) may be 

discharged into waters subject to this permit. 

The discharges of water from deck seals are authorized when such seals are installed as an integral part of an 

IGS system. 

Additional Effluent Limits 

Owner/operators of oil tankers must plug scuppers during cargo loading and unloading operations to prevent the 

discharge of oil into waters subject to this permit. Any oil spilled must be cleaned with oil absorbent cloths or 

another appropriate approach. Additionally, owner/operators of oil tankers must comply with applicable 

requirements of 33 CFR 155.310. 

Vessel owner/operators must minimize the discharge of effluent produced from inert gas scrubbers if feasible for 

their vessel design. 

December 18, 2008 Final 82
Economic and Benefits Analysis of the Final Vessel General Permit 

Supplemental Inspection Requirements

After every instance of loading or unloading operations or immediately following washing down the decks, you 

must conduct a visual sheen test. The visual sheen test is used to detect free oil by observing the surface of the 

receiving water for the presence of an oily sheen. The owner/operator should focus the inspection on the area 

surrounding the vessel where effluent from loading operations or deck washings discharge into the receiving 

water. A sheen is defined in Part 7 of this permit. If a visible sheen is observed, you must comply with all 

requirements contained in Part 4.4 of this permit and initiate corrective actions required in Part 3 of this permit. 

Educational and Training Requirements

The crews of oil tankers play a key role in minimizing the discharge of pollutants from vessel operations. 

Therefore oil tanker operators are subject to the following requirements: 

3⁄4 The ship’s crew members who actively take part in the management of the discharge or who may affect 

the discharge must receive training regarding shipboard environmental procedures and must be able to 

demonstrate proficiency in implementing these procedures. 

3⁄4 Advanced training in shipboard environmental management procedures must be provided for those 

directly involved in managing specific discharge types or areas of the ship and these crew must be able to 

demonstrate proficiency in implementing these procedures. 

3⁄4 Appropriate reprimand procedures must be developed for crew actions that lead to violations of any 

effluent limit set forth in this permit or procedures established by the vessel operator to minimize the 

discharge of pollutants. 

Estimates of Cost 

Costs were not analyzed in this analysis since the costs are expected to be negligible. 

6.3.5 Research Vessels 

Affected Vessel Population 

The population of vessels associated with research vessels is shown in Table 6-33. 

Table 6-33: Vessel Counts for BMPs Associated with Research Vessels 

Vessel Class Vessel Count 

Freight Barges 0

Freight Ships 0 

Passenger Vessels 0 

Tank Barges 0

Tank Ships 0 

Utility Vessels 233 

TOTAL 233

Permit Requirements 

Permit Text: 

The requirements in Part 5.6 apply to vessel discharges from research vessels. Research vessels are those that are 

engaged in investigation or experimentation aimed at discovery and interpretation of facts, revision of accepted 

theories or laws in the light of new facts, or practical application of such new or revised theories or laws. 

December 18, 2008 Final 83
Economic and Benefits Analysis of the Final Vessel General Permit 

Supplemental authorized discharges

In addition to the discharges incidental to the normal operation of a vessel authorized elsewhere in this permit, 

owner/operators of research vessels are authorized to discharge tracers (dyes, fluorescent beads, SF6), drifters, 

tracking devices and the like, and expendable bathythermograph (XBT) probes, into waters subject to this permit, 

provided such discharges are for the sole purpose of conducting research on the aquatic environment or its 

natural resources in accordance with generally recognized scientific methods, principles, or techniques. 

Additional Effluent Limits

Owner/operators of research vessels must discharge only the minimal amount of materials referenced in Part 

5.6.1 necessary to conduct research on the aquatic environment or its natural resources in accordance with 

generally recognized scientific methods, principles, or techniques. 

Estimates of Cost 

Costs were not analyzed in this analysis since the costs are expected to be negligible. 

6.3.6 Emergency Vessels (Fire Boats, Police Boats) 

Affected Vessel Population 

The population of vessels associated with rescue boats is currently unknown. 

Permit Requirements 

Permit Text: 

The requirements in Part 5.7 apply to vessel discharges from emergency and rescue boats. 

Supplemental authorized discharges

In addition to the discharges incidental to the normal operation of a vessel authorized elsewhere in this permit, 

vessel owner/operators of emergency vessels are authorized to discharge waste streams in conjunction with 

training, testing, and maintenance operations, provided that they comply with all additional requirements of the 

Clean Water Act (e.g. section 311) and the National Contingency Plan (40 CFR 300). This section does not 

relieve vessel operators of any additional responsibilities under the CWA and the National Contingency Plan 

which prohibits the discharge of oil for research or demonstration purposes without Administrator approval. The 

use of foaming agents for oil or chemical fire response must be implemented in accordance with the National 

Contingency Plan (40 CFR 300). 

Additional Effluent Limits 

Owner/Operators are strongly encouraged to seek alternative formulations of AFFF that are less harmful to the 

aquatic environment, such as non-fluorinated foam, while maintaining their effectiveness in emergency 

operations. Furthermore, operators are encouraged to not use AFFF or discharge toxic substances in areas near 

active commercial or recreational fisheries, near swimmable waters, or in high traffic areas for maintenance or 

training purposes. Emergency vessel owner/operators are also encouraged to perform training, testing, and 

maintenance operations outside of port and as far from shore as possible. The use of foaming agents for oil or 

chemical fire response, and the control of their discharge from a vessel, must be implemented in accordance with 

the National Contingency Plan (40 CFR 300). 

December 18, 2008 Final 84
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 85

Estimates of Cost 

Costs were not analyzed in this analysis since the costs are expected to be negligible. 

6.3.7 Vessels Employing Ballast Water Treatment Systems

Affected Vessel Population 

Vessels that need to meet the requirements of this section are those that have a ballast water treatment system that 

uses or generates biocides and will therefore discharge biocide residuals or derivatives into waters subject to this 

permit.26 There are currently four vessels with applications pending admission to the USCG’s Shipboard 

Technology Evaluation Program (STEP), which is intended to help develop effective alternative ballast water 

treatment technologies (USCG, 2008). In the future, it is conceivable that there will be additional vessels that will 

be accepted into state alternative ballast water treatment technologies programs. For the purpose of this analysis, 

EPA has assumed that the four vessels with applications pending admission to the USCG’s STEP will be accepted 

into the program and, thereafter, an additional 20 vessels per year will employ these new systems under state 

programs which discharge residual biocides.27 These assumptions were used to determine the average annual 

number of vessels that may employ ballast water treatment system. Since the classification of these vessels is 

currently unknown, EPA allocated the vessels into the appropriate vessel classes in proportion to the number of 

vessels in each classes from the total population of 61,069 vessels. The average annual population of vessels (over 

the 5 year permit term) estimated to use ballast water treatment systems is provided in Table 6-34. 

Table 6-34: Vessel Counts for BMPs Associated with Vessels Employing 

Experimental Ballast Water Treatment Systems 

Vessel Class Vessel Counta

Freight Barges 22 

Freight Ships 1 

Passenger Vessels 8 

Tank Barges 3 

Tank Ships 1 

Utility Vessels 7 

TOTAL 42 

a Since the vessel counts are based on the relative distribution among the different vessel classes, 

the vessel counts returned were not whole numbers. EPA rounded the vessel counts up to the 

nearest whole number. 

Permit Requirements 

Permit Text: 

The requirements in Part 5.8 apply to ballast water discharges from vessels employing ballast water treatment 

systems that make use of biocides. 

Authorization of Residual Biocides Associated with Experimental Ballast Water Treatment Systems

 

26 Vessels whose ballast water treatment system does not use or generate biocides (e.g., ballast water system that rely strictly on physical 

removal) do not need to meet requirements of this section. 

27 EPA expects that fewer than 20 vessels will be installing ballast water treatment systems in the first few years of this permit, while more 

vessels will be using such systems during the later years of this permit as additional federal and state requirements require ballast water 

treatment systems. Twenty represents the average annual number of vessels over the five-year period of the permit. 
Economic and Benefits Analysis of the Final Vessel General Permit 

Some experimental ballast water treatment systems produce or use biocides as an agent to reduce living 

organisms present in the ballast water tank. In order to be eligible for coverage under this permit, any ballast 

water technology must not use any biocide that is a “pesticide” within the meaning of the Federal Insecticide, 

Fungicide, Rodenticide Act (7 U.S.C § 136 et seq.) unless that biocide has been registered for use in ballast 

water treatment under such Act. The requirement in the preceding sentence does not apply if such biocide is 

generated solely by the use of a “device,” as that term is defined in the Federal Insecticide, Fungicide, and 

Rodenticide Act, on board the same vessel as the ballast water to be treated by the biocide. In addition, if the 

ballast water treatment system uses or generates biocides and you will discharge ballast water treated with 

biocides into waters subject to this permit, you must meet one of the following conditions to be eligible for permit 

coverage: 

3⁄4 The discharge of Total Residual Chlorine (TRC) as a biocide or derivative may not exceed 100 

micrograms per liter (μg/l) as an instantaneous maximum. Any other biocides or derivatives may not 

exceed acute water quality criteria listed in EPA’s 1986 Quality Criteria for Water [the Gold Book], and 

any subsequent revision, at the point of ballast water discharge. The Gold Book can be found at: 

www.epa.gov/waterscience/criteria/library/goldbook.pdf. Tables summarizing the subsequent revisions 

can be found at: http://www.epa.gov/waterscience/criteria/wqctable/index.html. Discharges of biocide 

residuals or derivatives must also meet monitoring requirements under Part 5.8.2.1, and reporting and 

recordkeeping requirements in Part 5.8.3. 

3⁄4 The permittee shall conduct whole effluent toxicity (WET) testing on samples of the discharges from 

shipboard ballast water treatment systems to establish and annually verify the appropriateness of 

methods for treating ballast water with biocides lacking EPA Water Quality Criteria or known to produce 

chemical biocides or derivatives lacking EPA Water Quality Criteria. The procedures for such WET 

testing are set forth in Part 15 (Appendix J) of this permit. The annual verification testing must 

demonstrate, for each organism tested, that the WET in the ballast water discharges, without allowance 

for mixing, does not exceed a chronic toxicity of 1.6 TUc as a daily maximum or 1.0 TUc as a monthly 

median. If the toxicity of the treatment system results in a discharge which exceeds 1.0 TUc as a monthly 

median or 1.6 TUc as a daily maximum, EPA may require the owner/operator to cease discharging from 

the treatment system until they obtain coverage under an individual NPDES permit. 

Monitoring Requirements

For vessels subject to Part 5.8.1.1, above: you must conduct monitoring of the vessel ballast water discharge for 

any residual biocides or derivatives used in the treatment process to demonstrate compliance with the conditions 

in Part 5.8.1.1. For instance, if chlorine is the biocide used in the ballast water treatment, you must test for 

chlorine in the vessel ballast water discharge to see if it complies with the standards in Part 5.8.1.1. If there are 

no Part 136 test methods for the residual biocide or derivatives of the residual biocide, you must comply with 

Part 5.8.1.2 or seek coverage under an individual NPDES permit pursuant to Part 1.8 of this permit. In order to 

demonstrate that residual biocides or derivatives are in compliance with this permit, the vessel operator initially 

must take at least five (5) samples on different days over a 90-day period that are representative of the treated 

ballast water discharge. Each sample must be tested independently and the individual results must be reported 

and not averaged. Samples must be tested as soon as possible after sampling, and may not be held longer than 

recommended for each tested constituent as given in 40 CFR Part 136. Sampling and testing shall be conducted 

according to 40 CFR Part 136. 

Records of monitoring information shall include: 

3⁄4 The date, exact place, and time of sampling or measurements; 

3⁄4 The individual(s) who performed the sampling or measurements; 

3⁄4 The date(s) analyses were performed; 

December 18, 2008 Final 86
Economic and Benefits Analysis of the Final Vessel General Permit 

3⁄4 The individual(s) who performed the analyses; 

3⁄4 The analytical techniques or methods used; and 

3⁄4 The results of such analyses. 

Thereafter, you must conduct maintenance sampling and analysis at least quarterly (4 times per year) of the 

vessel ballast water discharge in order to demonstrate continued compliance with the standards in Part 5.8.1.1. If 

any of the initial or maintenance samples exceed the standards specified in Part 5.8.1.1, then the owner/operator 

must immediately undertake steps necessary to achieve compliance and take and submit samples demonstrating 

such compliance or cease discharging and seek coverage under an individual permit under Part 1.8 of this 

permit. 

Whole Effluent Toxicity (WET) monitoring 

For vessels subject to 5.8.1.2, above: you must initially conduct whole effluent toxicity (WET) testing consistent 

with Part 15 (Appendix J) of this permit using samples from the ballast water treatment system at the end of pipe 

for assessing the environmental safety of the resulting ballast water discharges. Two sets of WET tests must be 

done as set forth in Part 15 of this permit (Appendix E) using different ballast water discharge events separated 

by at least no less than 14 days, for initial testing followed by annual verification testing for each year of permit 

coverage. Initial WET testing must be done in the first 90 days of permit coverage or the first 90 days of using the 

ballast water treatment system after permit issuance. 

Thereafter, you must conduct maintenance sampling and analysis at least once per year of the vessel ballast 

water discharge in order to demonstrate continued compliance with the standards in Part 5.8.1.2. If any of the 

initial or maintenance samples exceed the standards specified in Part 5.8.1.2, then the owner/operator must 

immediately undertake steps necessary to achieve compliance and take and submit samples demonstrating such 

compliance. 

Additional Recordkeeping and reporting requirements 

Records of the sampling and testing results must be retained onboard for a period of 3 years in the vessel’s 

recordkeeping documentation. 

You must submit your monitoring data to EPA HQ, Attn: Ballast Water Treatment System Test Results -Mail Code 

4203M, 1200 Pennsylvania Ave., Washington DC 20460 at least once per year. For systems already in use as of 

the effective date of this permit, initial sampling data must be submitted within 6 months of this permit’s effective 

date. For systems which are not already in use as of the effective date of this permit, initial sampling data must be 

submitted within 6 months of the system’s first use. Maintenance monitoring data must be submitted at least once 

per year within 30 days of the final sample collection. Data must be submitted on Discharge Monitoring Reports 

available in Appendix I of this permit or submitted to EPA’s e-reporting system available at 

www.epa.gov/npdes/vessels/eNOI, which will be available within two years of finalization of this permit. 

Estimates of Cost 

EPA is uncertain how many vessels may seek permit coverage under this provision. However, due to the 

expectation that some vessels will be employing these systems in the future, some preliminary estimates of the 

number of vessels that expect to use ballast water treatment systems were gathered and a sensitivity analysis was 

performed. The costs are reflected in the high end cost estimate detailed below. Since the population of vessels 

that currently use ballast water treatment systems applicable to this section is currently zero, the low end cost 

estimate is estimated to be zero. 

December 18, 2008 Final 87
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 88

Sensitivity Analysis 

Depending upon the type of biocides used in the vessel’s experimental ballast water treatment system, vessels are 

required to perform either WET testing, TRC sampling, or sampling for parameters that have acute water quality 

criteria. 

Communication with an analytical laboratory that does marine WET testing indicated that a test for acute toxicity 

costs $450 and a test for chronic toxicity costs between $675 and $77528. EPA also assumed that an additional 

$100 would be required for the administration of the WET test (i.e. sending the sample to the lab, etc.), totaling 

$550 per acute toxicity testing event and $825 per chronic toxicity testing event. All vessels that discharge treated 

ballast water containing a residual biocide are required to perform chronic toxicity WET testing on certain 

species. EPA determined that three of the four vessels with applications pending admission to the USCG’s STEP 

are required to perform chronic toxicity WET testing. However, it is unknown what percentage of the additional 

20 vessels per year will be required to perform chronic testing. Therefore, EPA assumed equal probability of the 

two types of costs and averaged the cost of the acute toxicity and chronic toxicity WET tests to derive an estimate 

of $688 per testing. Two sets of WET tests must initially be done using different ballast water discharge events, 

followed thereafter by annual verification testing during the permit period. Therefore, the average annual number 

of samples tested is 1.2 (6 tests/5 years) and the average annual cost for WET testing is $825. 

Cost estimates for sampling TRC or any other parameters with acute water quality criteria were derived based on 

prior EPA estimates of the Cost Impact Analysis for the 2006 Multi-Sector General Permit (MSGP). The MSGP 

assumed that it would take 90 minutes to monitor the first parameter and an additional 15 minutes for each of the 

next three parameters. Since sampling onboard a vessel generally requires more time than onshore sampling, EPA 

has assumed that it would take 4 labor hours to perform sampling for TRC or any other parameter with acute 

water quality criteria. EPA assumes the same average labor rate of $31.61 (calculated from all the industry 

responses) to derive a labor cost of $126. The MSGP also provides average cost estimates for conducting analyses 

for different sampling parameters. These estimates range between $5 and $40 per parameter. Based on these 

ranges, EPA assumed that analytical costs (not including labor costs) will total $100. Therefore, the total cost for 

an acute water quality criteria sampling event is estimated to be $226. Initially, the vessel operator must take at 

least five samples on different days over a 90-day period. Thereafter, the vessel operator must conduct 

maintenance sampling and analysis at least quarterly of the vessel ballast water discharge in order to demonstrate 

continued compliance. Therefore, the average annual number of testing samples is 4.8 (24 tests/5 years) and the 

average annual cost for testing parameters with acute water quality criteria is $1,087. 

Since it is unknown which vessels will perform WET testing and which will perform sampling for TRC or any 

other parameter with acute water quality criteria, EPA assumed equal probability for the two types of costs and 

calculated an average of $956 per test/sampling event. This cost was applied to the average annual population of 

vessels (over the 5-year permit period) that may employ ballast water treatment systems (42 vessels) to derive a 

total annual incremental cost of $40,150. Table 6-35 details the high end cost estimates. 

 

28 The authors note that the permit requirements for WET testing changed slightly from the time the analysis was done to time of permit 

finalization. EPA does not expect the slight change in requirements to significantly impact these cost estimates. 
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 6-35: WET Testing/Water Quality Sampling Analysis for Vessels Employing Experimental 

Ballast Water Treatment Systems 

Vessel Class Vessels 

% Vessels 

Applicable to BMP 

Annual Cost 

per Vessel Total Annual Cost 

High End Estimate 

Freight Barges 22 0.07% $955.96 $21,031 

Freight Ships 1 0.14% $955.96 $956 

Passenger Vessels 8 0.07% $955.96 $7,648 

Tank Barges 3 0.06% $955.96 $2,868 

Tank Ships 1 0.68% $955.96 $956 

Utility Vessels 7 0.07% $955.96 $6,692 

Perform testing/sampling, High End TOTAL 42 $40,150 

6.3.8 Cost Estimates for Other Requirements 

The final Permit states that “discharges of tetrachloroethylene degreasers or other products containing 

tetrachloroethylene are not eligible for coverage under this permit.” To evaluate the impacts of this requirement, 

EPA researched the costs of tetrachloroethylene (TCE) degreasers and cleaners, as compared to the costs of nonTCE containing degreasers and cleaners. Degreasers and cleaners that do not contain TCE are available in a wide 

price range. All-purpose cleaners and detergents may be purchased for less than $15 per gallon, while the costs of 

more specialized industrial degreasers and aerosols can range from $15 to $50 per gallon. An Internet search 

indicated that TCE-containing degreasers are not widely available for purchase; but, for example, laboratorygrade TCE can cost between $138 and $500 per gallon. 

Based on this research, EPA determined that there is enough price variability among the multitude of available 

products for a vessel to opt for a non-TCE degreaser at no incremental cost as compared to a TCE-containing 

degreaser. 

6.3.9 Uncertainties and Limitations 

This analysis relies heavily on data provided by industry representatives in estimating the percentage of vessels 

that are practicing the BMPs required by the Permit under the baseline scenario and in estimating costs of 

individual BMPs. Although EPA believes that the industry representatives provided good faith estimates, their 

responses are based on either expert judgment or communication with selected firms within the industry and thus 

are subject to uncertainty. In addition, there is some incentive for representatives of industry to overstate costs. 

Additional information was obtained from personal communications with the industry experts (e.g., David 

Peters), manufacturers (e.g., Dawg, Inc.) and a diving company (Seacor International). Because EPA made a 

limited number of contacts, the relevant estimates are likely to be subject to uncertainty. 

In estimating the annual cost of ballast water exchange, this analysis assumes that the unit cost of ballast water 

exchange for the vessels with empty ballast tanks and the practices associated with developing a Ballast Water 

Management Plan are no different for the vessels for which it was applied within the USCG analysis. However, 

there may be considerable uncertainty associated with each cost component due to some differences in vessel 

characteristics to which these estimates applied (e.g., oceangoing vessels vs. Pacific nearshore vessels or vessels 

in ballast vs. vessels with empty tanks). 

6.4 Permit Paperwork Burden 

The permit paperwork burden is comprised of six potential cost inputs. Recordkeeping, routine inspections, and 

annual inspections are already required for these vessels. However, based on the introduction of the Permit best 

management practices, additional time for these tasks may be required. Furthermore, drydock inspections, 

including the report preparation, are commonly performed by the industry. However, EPA is assuming that, due 

December 18, 2008 Final 89
Economic and Benefits Analysis of the Final Vessel General Permit 

to the Permit, some vessels may require additional time for inspection and/or report preparation. Therefore, for the 

high end estimates, EPA has estimated an additional amount of time required for these vessels for recordkeeping, 

routine inspections, drydock inspections, and annual inspections. The low end estimates assume that no additional 

time is required for these four practices. The two other components of the permit paperwork burden are the Notice 

of Intent filing (for a subset of vessels) and the one-time report requirement for all vessels. The time required for 

these practices is the same for both the high end and low end estimate since they are new requirements and will 

introduce costs to applicable vessels. 

The additional time required for recordkeeping, routine inspections, drydock inspections, and annual inspections 

varies according to vessel class. EPA is assuming that certain vessel classes are more likely to have a higher 

number of applicable discharge categories, and thus, a potentially higher number of Permit BMPs to perform. 

Thus, in Table 6-36 EPA has assumed that the following are “large” and “small” vessels. For these three 

practices, large vessels have a greater time requirement than do small vessels. Furthermore, to calculate the total 

annual cost per vessel, EPA used the average labor rate provided by the industry survey responses of $31.61. 

Table 6-36: Vessel Class Breakdown 

Large Vessels Small Vessels 

Cruise Ships Freight Barges 

Freight Ships Passenger Vessels 

Tank Ships Utility Vessels 

 Tank Barges 

3⁄4 Recordkeeping: Vessels are already required to keep extensive records. Since there are very few 

additional requirements that vessels must record, EPA is assuming a small incremental number of hours 

required for this practice. For the high end estimate, EPA assumes that 0.5 additional hours is annually 

required of small vessels, and 1 additional hour is annually required of large vessels. This practice is 

performed for five years. The detailed high end cost estimates are shown in Table 6-37. The low end total 

cost estimates are null. 

Table 6-37: Recordkeeping Burden 

Vessel Class 

Vessel 

Count 

Total Burden 

Hours 

Total Annual 

Costa

Large Vessels - 1 Burden Hour 

Cruise Ships 175 175 $5,532 

Freight Ships 697 697 $22,032 

Tank Ships 147 147 $4,647 

Large Vessels TOTAL 1,019 1,019 $32,211 

Small Vessels - 0.5 Burden Hours 

Freight Barges 32,842 16,421 $519,068 

Passenger Vesselsb 11,346 5,673 $179,324 

Utility Vessels 10,892 5,446 $172,148 

Tank Barges 4,944 2,472 $78,140 

Small Vessels TOTAL 60,024 30,012 $948,679 

TOTAL 61,043 31,031 $980,890 

a Incurred every year for the first five years. 

b Cruise ships are in the passenger vessels category. Thus, the 175 cruise ship 

count was subtracted from the normal passenger vessel count of 11,521. 

3⁄4 NOI: The NOI filing requirement is only applicable to vessels that are greater than or equal to 300 gross 

tons or vessels that have the capacity to hold or discharge more than 8 cubic meters (2113 gallons) of 

ballast water. Based on the Information Collection Request for NPDES Permits and the Sewage Sludge 

Management Permits (US EPA, 2006), EPA has found that 1 hour is required to file an NOI for a general 

December 18, 2008 Final 90
Economic and Benefits Analysis of the Final Vessel General Permit 

permit. This is a one-time requirement and does not carry through over multiple years. This cost is 

annualized over five years at a 7 percent discount rate. The detailed low and high end cost estimates are 

shown in Table 6-38. 

Table 6-38: NOI Burden 

Vessel Class 

Vessel 

Counta

Total Burden 

Hours Total Cost 

Total Annual 

Costb

All Vessels - 1 Burden Hour 

Cruise Ships 175 175 $5,532 $1,349 

Freight Ships 469 469 $14,825 $3,616 

Tank Ships 117 117 $3,698 $902 

Commercial Fishing 26 26 $822 $200 

Freight Barges 30,961 30,961 $978,677 $238,690 

Passenger Vesselsc 1,095 1,095 $34,613 $8,442 

Utility Vessels 4,255 4,255 $134,501 $32,803 

Tank Barges 4,808 4,808 $151,981 $37,067 

TOTAL 41,906 41,906 $1,324,649 $323,069 

a The count of vessels required to submit an NOI is a conservative estimate since data on gross 

tonnage are not complete. Thus, this count is based on the number of vessels that are either ≥79’ in 

length or ≥300 gross tons. 

b Total cost annualized over five years at a 7% discount rate. 

c Cruise Ships are within the Passenger Vessels category. Thus, the 175 cruise ship count was 

subtracted from the normal Passenger Vessel count of 1,270. 

3⁄4 Routine Inspections: Vessels are already performing these routine inspections. However, additional time 

may be required based on the introduction of the Permit BMPs. For the high end estimate, EPA assumes 

that 0.5 additional hours are annually required of small vessels and 2 additional hours are annually 

required of large vessels. This practice is performed for five years. The detailed high end cost estimates 

are shown in Table 6-39. The low end total cost estimates are null. 

Table 6-39: Routine Inspection Burden 

Vessel Class 

Vessel 

Count 

Total Burden 

Hours 

Total Annual 

Costa

Large Vessels - 2 Burden Hours 

Cruise Ships 175 350 $11,064 

Freight Ships 697 1,394 $44,064 

Tank Ships 147 294 $9,293 

Large Vessels TOTAL 1,019 2,038 $64,421 

Small Vessels - 0.5 Burden Hours 

Freight Barges 32,842 16,421 $519,068 

Passenger Vesselsb 11,346 5,673 $179,324 

Utility Vessels 10,892 5,446 $172,148 

Tank Barges 4,944 2,472 $78,140 

Small Vessels TOTAL 60,024 30,012 $948,679 

TOTAL 61,043 32,050 $1,013,101 

a Incurred every year for the first five years. 

b Cruise ships are in the passenger vessels category. Thus, the 175 cruise ship 

count was subtracted from the normal passenger vessel count of 11,521. 

3⁄4 Drydock Inspections: Vessels are already performing drydock inspections. However, additional time may 

be required due to the introduction of the Permit BMPs for inspection and/or report preparation. For the 

high end estimate, EPA assumes that 2 additional hours are annually required for small vessels and 4 

additional hours are annually required for large vessels. Drydock inspections are assumed to be performed 

December 18, 2008 Final 91
Economic and Benefits Analysis of the Final Vessel General Permit 

once every five years. This cost is annualized over five years at a 7 percent discount rate. The detailed 

high end cost estimates are shown in Table 6-39. The low end total cost estimates are null. 

Table 6-40: Drydock Inspection Burden 

Vessel Class 

Vessel 

Count 

Total Burden 

Hours Total Cost 

Total Annual 

Costa

Large Vessels - 4 Burden Hours 

Cruise Ships 175 700 $22,127 $5,397 

Freight Ships 697 2,788 $88,129 $21,494 

Tank Ships 147 588 $18,587 $4,533 

Large Vessels TOTAL 1,019 4,076 $128,842 $31,423 

Small Vessels - 2 Burden Hours 

Freight Barges 32,842 65,684 $2,076,271 $506,383 

Passenger Vesselsb 11,346 22,692 $717,294 $174,941 

Utility Vessels 10,892 21,784 $688,592 $167,941 

Tank Barges 4,944 9,888 $312,560 $76,230 

Small Vessels TOTAL 60,024 120,048 $3,794,717 $925,496 

TOTAL 61,043 124,124 $3,923,560 $956,920 

a Total cost annualized over five years at a 7% discount rate. 

b Cruise ships are in the passenger vessels category. Thus, the 175 cruise ship count was subtracted 

from the normal passenger vessel count of 11,521. 

3⁄4 Annual Inspection: Vessels are already performing annual inspections. However, additional time may be 

required based on the introduction of the Permit BMPs. For the high end estimate, EPA is assuming that 

0.5 additional hours is annually required of small vessels and 2 additional hours are annually required of 

large vessels. This practice is performed for five years. The detailed high end cost estimates are shown in 

Table 6-41. The low end total cost estimates are null. 

Table 6-41: Annual Inspection Burden 

Vessel Class 

Vessel 

Count 

Total Burden 

Hours 

Total Annual 

Costa

Large Vessels - 2 Burden Hours 

Cruise Ships 175 350 $11,064 

Freight Ships 697 1,394 $44,064 

Tank Ships 147 294 $9,293 

Large Vessels TOTAL 1,019 2,038 $64,421 

Small Vessels - 0.5 Burden Hours 

Freight Barges 32,842 16,421 $519,068 

Passenger Vesselsb 11,346 5,673 $179,324 

Utility Vessels 10,892 5,446 $172,148 

Tank Barges 4,944 2,472 $78,140 

Small Vessels TOTAL 60,024 30,012 $948,679 

TOTAL 61,043 32,050 $1,013,101 

a Incurred every year for the first five years. 

b Cruise ships are in the passenger vessels category. Thus, the 175 cruise ship 

count was subtracted from the normal passenger vessel count of 11,521. 

3⁄4 One-time Report: Since this is a new Permit requirement, EPA assumes that, for both the low and high 

end estimate, 0.5 hours is required for small and large vessels. This is a one-time requirement and does 

December 18, 2008 Final 92
Economic and Benefits Analysis of the Final Vessel General Permit 

not carry through over multiple years. This cost is annualized over five years at a 7 percent discount rate. 

The detailed low and high end cost estimates are shown in Table 6-42. 

Table 6-42: One-Time Report Burden 

Vessel Class 

Vessel 

Count 

Total Burden 

Hours Total Cost 

Total Annual 

Costa

All Vessels - 0.5 Burden Hours 

Cruise Ships 175 88 $2,766 $675 

Freight Ships 697 349 $11,016 $2,687 

Tank Ships 147 74 $2,323 $567 

Freight Barges 32,842 16,421 $519,068 $126,596 

Passenger Vesselsb 11,346 5,673 $179,324 $43,735 

Utility Vessels 10,892 5,446 $172,148 $41,985 

Tank Barges 4,944 2,472 $78,140 $19,058 

TOTAL 61,043 30,522 $964,785 $235,302 

a Total cost annualized over five years at a 7% discount rate. 

b Cruise ships are in the passenger vessels category. Thus, the 175 cruise ship count was 

subtracted from the normal passenger vessel count of 11,521. 

6.5 Analysis of Total National Costs 

The estimated total compliance costs for all BMPs are provided in Table 6-43. The estimated VGP compliance 

costs, including the $468,248 and $1,138,867 annual incremental costs for ballast water practices for domestic 

and foreign vessels, respectively, vary because of the different assumptions made regarding the populations and 

the number of instances for which incremental costs will be incurred. The total low end estimate is approximately 

$6.6 million, whereas the total high end estimate is approximately $16.7 million. 

Table 6-43: Total Annual Compliance Costs for All BMPs by Vessel Type 

Total Cost 

Vessel Type Domestic Foreigna Total 

Low End Estimates 

Commercial Fishing $27,641 $0 $27,641 

Freight Barges $3,179,041 $367 $3,179,408 

Freight Ships $160,679 $711,189 $871,867 

Passenger Vessels $78,387 $69,617 $148,004 

Tank Barges $562,408 $730 $563,138 

Tank Ships $233,689 $352,662 $586,350 

Utility Vessels $1,184,501 $4,302 $1,188,804 

Low End TOTAL $5,426,345 $1,138,867 $6,565,212 

High End Estimates 

Commercial Fishing $27,641 $0 $27,641 

Freight Barges $9,714,226 $367 $9,714,593 

Freight Ships $308,315 $711,189 $1,019,503 

Passenger Vessels $156,535 $69,617 $226,153 

Tank Barges $1,606,030 $730 $1,606,760 

Tank Ships $268,554 $352,662 $621,216 

Utility Vessels $3,510,277 $4,302 $3,514,579 

High End TOTAL $15,591,578 $1,138,867 $16,730,445 

The total costs to cruise ships are provided in Table 6-44. These ships are in the passenger vessel category. Thus, 

this cost is allocated within the totals for the passenger vessel class. These costs are currently based on 

December 18, 2008 Final 93
Economic and Benefits Analysis of the Final Vessel General Permit 

assumptions made regarding the population of ships that would need to purchase a graywater treatment system 

and those that would need to undergo sampling practices. 

Table 6-44: Total Annual Incremental Cost for Cruise Ships 

Vessel Typea Total Domestic Cost 

Large Cruise Ships $1,504,186 

Medium Cruise Ships $251,177 

TOTAL $1,755,364 

a Cruise ships are in the passenger vessels category.

The total high end cost estimates to vessels expected to employ experimental ballast water treatment systems are 

provided in Table 6-45. 

Table 6-45: WET Testing/Water Quality Sampling Analysis 

for Vessels Employing Experimental Ballast Water 

Treatment Systems 

Vessel Class Total Annual Cost 

High End Estimate 

Freight Barges $21,031 

Freight Ships $956 

Passenger Vessels $7,648 

Tank Barges $2,868 

Tank Ships $956 

Utility Vessels $6,692 

High End TOTAL $40,150 

Total paperwork costs are provided within Table 6-46. The low end estimate total is approximately $560,000, 

whereas the high end estimate is approximately $4.5 million. 

Table 6-46: Total Permit Recordkeeping Burden Cost 

Vessel Type Total Cost to Domestic Vessels 

Low End Estimate 

Cruise Ships $2,024 

Commercial Fishing $200 

Freight Barges $365,286 

Freight Ships $6,302 

Passenger Vessels $52,177 

Tank Barges $56,124 

Tank Ships $1,469 

Utility Vessels $74,789 

Low End TOTAL $558,371 

High End Estimate 

Cruise Ships $35,079 

Commercial Fishing $200 

Freight Barges $2,428,873 

Freight Ships $137,957 

Passenger Vessels $765,089 

Tank Barges $366,774 

Tank Ships $29,235 

Utility Vessels $759,174 

High End TOTAL $4,522,382 

The total annual incremental costs are provided in Table 6-47. This includes the paperwork cost estimates from 

Table 6-46, the sum of the ballast water cost analysis and the sensitivity analysis costs for all other individual 

December 18, 2008 Final 94
Economic and Benefits Analysis of the Final Vessel General Permit 

BMPs (Table 6-43), the costs to cruise ships (Table 6-44), and the high end cost estimates for vessels expected to 

employ ballast water treatment systems which discharge residual biocides or derivatives. The total low end 

estimate is approximately $8.9 million, including a $7.7 million cost to domestic flagged vessels and a $1.1 

million cost for ballast water requirements to foreign flagged vessels. The total high end estimate is approximately 

$23 million, including a $21.9 million cost to domestic flagged vessels and a $1.1 million cost for ballast water 

requirements to foreign flagged vessels. 

Table 6-47: Total Annual Incremental Cost 

Total Cost 

Vessel Type Domestic Foreigna Total 

Low End Estimates 

Commercial Fishing $27,841 $0 $27,841 

Freight Barges $3,544,327 $367 $3,544,694 

Freight Ships $166,981 $711,189 $878,170 

Passenger Vessels $1,887,951 $69,617 $1,957,569 

Tank Barges $618,533 $730 $619,262 

Tank Ships $235,157 $352,662 $587,819 

Utility Vessels $1,259,290 $4,302 $1,263,592 

Low End TOTAL $7,740,080 $1,138,867 $8,878,947 

High End Estimates 

Commercial Fishing $27,841 $0 $27,841 

Freight Barges $12,164,130 $367 $12,164,497 

Freight Ships $447,228 $711,189 $1,158,416 

Passenger Vessels $2,719,715 $69,617 $2,789,332 

Tank Barges $1,975,672 $730 $1,976,402 

Tank Ships $298,745 $352,662 $651,407 

Utility Vessels $4,276,143 $4,302 $4,280,445 

High End TOTAL $21,909,474 $1,138,867 $23,048,341 

a Only includes ballast water exchange/flushing costs. 

December 18, 2008 Final 95
Economic and Benefits Analysis of the Final Vessel General Permit 

7 Analysis of Impacts on Firm Revenues and Financial Performance 

The previous chapters assessed total compliance costs to the water transportation and fishing industries, and to the 

drilling oil and gas wells sector of the mining industry. The firm-level analysis examines the impact of the 

introduced BMP costs per vessel on model firms that represent the financial conditions of “typical” businesses in 

each of the 11 examined NAICS codes. Since approximately 95 percent of the firms in the water transportation, 

and fishing industries, and in the drilling oil and gas wells sector are small (see Section 5.4.2: Small Businesses),

it is unlikely that firm-level impacts would be material among large firms in these industries. Therefore, the firmlevel analysis focuses on assessing impacts on small businesses, as required by the Regulatory Flexibility Act 

(RFA) and the Small Business Regulatory Enforcement and Fairness Act (SBREFA). 

7.1 Methodology 

The analysis establishes baseline financial conditions of the model firms, which are used in combination with the 

introduced BMP costs to examine the firm financial impact. Model-firm impacts provide the basis for estimating 

the number of firms expected to experience financial stress at the national/total industry level. After identifying 

the post-compliance cost-to-revenue ratio, the analysis estimates the total number of firms expected to experience 

potential financial stress. Financial stress may be indicated by a lack of profitability, cash deficiencies, or even 

bankruptcy. Firms expected to experience financial stress may need to change their business operations, including 

potentially downsizing or closing operations. 

The key steps of the analysis involve: (1) assigning each vessel in the vessel database to a North American 

Industry Classification System (NAICS) code, (2) estimating the number of vessels per firm, (3) estimating the 

distribution of costs per vessel, and (4) comparing the costs to the revenues. 

7.1.1 Assign Each Vessel to a NAICS Code 

The framework for the model firms reflects the range of firm types across the major industry groups. Financial 

data for each major industry groups are available in the Economic Census while SBA provides firm data by 

revenue bracket. Since the Economic Census does not have the same vessel categories as compared to other data 

sources (VESDOC/WTLUS, which contain more complete numbers of all potentially regulated vessels and 

firms), each of the vessels and firms from the vessel database was assigned to a NAICS code to correspond to the 

Economic Census industry categories. 

The number of firms likely to incur costs as a result of the Permit was identified using the VESDOC and WTLUS 

databases (and, for the MODU population, from the IADC comment submission, which also identified these 

vessels as within NAICS 213111). Firms identified in the vessel databases were assigned a NAICS code in order 

to determine the number of firms subject to permit requirements for each NAICS code. Industry classification 

information for individual firms listed in the vessel databases was obtained primarily from ReferenceUSA’s 

Business Database (ReferenceUSA, 2006) and Dun & Bradstreet’s Million Dollar Database (Dun & Bradstreet, 

2006), supplemented by company Web sites and industry publications. Both ReferenceUSA and Dun & 

Bradstreet link subsidiaries and branch offices to company headquarters, allowing for an identification of 

domestic parent entities. Dun & Bradstreet’s Million Dollar Database classifies businesses based on eight-digit 

Standard Industrial Classification (SIC) codes. Since both the Census and SBA base their data on NAICS codes, 

EPA matched the first four digits of the SIC codes provided in Dun & Bradstreet to corresponding six-digit 

NAICS codes using the U.S. Census Bureau’s bridge between 1987 SIC and 2002 NAICS codes (U.S. Census 

December 18, 2008 Final 96
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 97

Bureau, 2002b). The Dun & Bradstreet company names were matched to the vessel owner/operator names in the 

VESDOC/WTLUS database to provide a NAICS code classification for most vessels in the vessel database.29

Once the number of firms with vessel permits was estimated for each NAICS code, EPA distributed these firms 

across revenue size categories proportionally to the distribution of firms by revenue size category indicated in 

Economic Census data. This estimated distribution of firms by revenue size category is assumed to be more 

accurate than estimates that could be derived solely from the Economic Census, since the Economic Census 

includes firms that are not expected to be affected by the rule. These totals were used to determine the number and 

percentage of firms experiencing economic impacts. 

7.1.2 Estimate the Number of Vessels per Firm 

To establish the baseline and post-cost financials for each model firm, the per-vessel BMP costs developed from 

Chapter 6 are applied to the firm level. To determine the total BMP costs that a firm could incur, EPA first 

estimated the average number of vessels owned and operated by firms in each NAICS sector using information 

from the VESDOC and WTLUS databases. For each NAICS code, EPA determined the number of vessels that 

were listed with a firm name as well as the number of firms corresponding to these vessels. Based upon the total 

number of firms and vessels within the subset in each NAICS code, the average number of vessels per firm was 

determined for each NAICS code. However, since this value is expected to vary among the different firm sizes, 

this average value was adjusted for each revenue size category so that the average number of vessels in each 

revenue size range is proportional to the midpoint of revenue in a revenue size category. This calculation is 

described in more detail below. 

Data were available from the Economic Census and from the SBA’s Statistics of U.S. Businesses on the total 

number of firms by revenue size. No data were available on the number of vessels by revenue size; however, data 

on the average number of vessels per firm per NAICS sector across all revenue sizes were available from the 

VESDOC and WTLUS databases. Multiplying the number of firms in each NAICS sector by the average number 

of vessels per firm yields an estimate of the number of vessels in the NAICS sector overall. The number of vessels 

in each NAICS sector was then distributed over revenue size categories in such a way that the average number of 

vessels in each revenue size range is proportional to the midpoint of revenue in a revenue size category. This 

calculation maintains the overall estimated average and total number of vessels in each NAICS sector but 

recognizes that the number of vessels owned by firms is likely to be approximately proportional to the revenue 

size of the firm. For example, for an industry with two revenue brackets, $0–$100,000 and $100,000–$200,000, 

two firms in each bracket, and six vessels per firm on average across all brackets, EPA would assume that there 

were three vessels per firm in the first bracket and nine vessels per firm in the second bracket. Thus, since the 

midpoint revenue is three times as high in the second revenue bracket as the midpoint revenue in the first bracket, 

the number of vessels per firm is also assumed to be three times as high in the second revenue bracket. Note that 

EPA did not allow the average number of vessels per firm to be less than one for any revenue bracket. 

7.1.3 Estimate the Distribution of Costs per Vessel 

For each vessel type and BMP, EPA has already estimated in Section 6.20: (1) the total number of vessels, (2) the 

probability of a vessel incurring incremental costs, and (3) the incremental cost of each BMP. By assuming that 

the probability of incurring an incremental cost for a given BMP is independent of incurring costs for any of the 

other BMPs, EPA can estimate the probabilities of incurring costs for all possible combinations of BMPs. 

In the analysis, the low end cost estimate includes 16 possible BMPs, and the high end cost estimate includes 21 

possible BMPs. Treating each BMP cost as an independent, binary “on/off” cost event, this means that there are 

 

29 Of the total 61,069 vessels in the database that are estimated to be potentially subject to VGP, 340 vessels could not be assigned a 

NAICS code. 
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 98

theoretically 216 and 221 possible combinations of BMP cost events for the low end and high end cost estimate, 

respectively. Each combination BMP cost event is defined on the basis of whether or not each of the specific 

BMPs is “on” or “off” (and resulting costs) together with the probability of each specific BMP being “on” or 

“off.” Each BMP is assigned a probability of occurrence for each vessel class by dividing the number of vessels 

estimated to incur a given BMP cost by the total number of vessels, and therefore this is the probability for the 

individual BMP to be “on.” Conversely, the probability of the individual BMP being “off,” is equal to one minus

the probability of the BMPs occurrence. The overall probability of occurrence for a given BMP combination is 

the product of these individual probabilities. As a result, most of the BMP cost combinations are not meaningful 

for the impact analysis because one or more of the BMP “on/off” instances in the combination event have a zero 

probability of occurrence, and thus the overall probability of that particular event, which is calculated as the 

product of the individual “on” or “off” BMP probabilities, is zero. The high occurrence of zero probability 

combination BMP events results from the presence of BMP costs that are always assumed to be incurred, or have 

one hundred percent probability of occurrence. The maximum number of observed BMP combinations for a 

vessel type is therefore only 2,048, which is substantially smaller than the theoretical 2,097,152 possibilities 

(2,097,152 = 221). 

For each of the possible BMP combinations, EPA multiplied the total number of vessels by vessel class by the 

calculated probability of the combination BMP event to estimate the number of vessels incurring costs for a given 

combination of BMPs. Finally, EPA calculated the per-vessel cost by vessel class associated with each 

combination of BMPs by summing the costs of the individual BMPs where costs are incurred. This calculation 

provided the distribution of per-vessel costs. The distribution shows a high probability of occurrence for very low 

cost combination BMP events. The probability of occurrence declines rapidly as the cost of the combination BMP 

events increases. The higher cost combination BMP events—which require a combination of all or nearly all of 

the individual BMPs—have a very low probability of occurrence. 

EPA estimated the distribution of per-firm costs from the distribution of per-vessel costs using the following 

approach. For firms in industries with more than one vessel class, EPA estimated vessel costs corresponding to 

the minimum, maximum and each 10 percentile increment in between these extremes – thereby yielding 11 

possible vessel costs, which are assumed to be equally likely. For firms in industries with two vessel types, EPA 

evaluated the firm costs for 112

 possible combinations of costs. For firms in industries with N vessel types, EPA 

evaluated the firm costs for 11N possible combinations of costs – 11 possible costs for each vessel class. For each 

industry, EPA calculated an average per-vessel cost from the vessel class-specific costs for all 11N possible 

combinations based on the relative number of vessels in each class. This average cost per vessel was then 

multiplied by the number of vessels per firm in each industry for a given revenue size category (see Section 

7.1.2). Thus, for industries with more than one vessel class, EPA estimated a distribution of costs per firm with 

11N equally likely possibilities, where N is the number of vessel classes observed for the industry.30 There were 

three sectors with only one vessel class, three sectors with six vessel classes, and one sector each with two, three, 

four, and five and seven vessel classes., Figure 7-1 illustrates how the firm cost impact is calculated for one 

possible combination of vessel costs and one revenue size bracket in a sector with two vessel classes. 

 

30 For NAICS 483112/483114, EPA performed the analysis using 101 different cost possibilities to account for the small percentage of 

vessels that are expected to incur these costs. 
Economic and Benefits Analysis of the Final Vessel General Permit 

Figure 7-1: Illustration - Calculation of one firm cost possibility for the Inland waterways 

passenger transportation and other water transportation (483212) sector, which 

includes two vessel types (passenger and utility vessels).

December 18, 2008 Final 99
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 100

For firms in industries with only one vessel class, such as commercial fishing, port and harbor operations 

industries, or the drilling oil and gas wells sector, EPA estimated the total vessel costs for all possible 

combinations of the individual practice costs. The likelihood of each possible combination is estimated from the 

likelihoods of incurring each individual practice cost, as described above, which are assumed to be independent. 

The costs per vessel are multiplied by the number of vessels per firm in each industry to estimate all the possible 

firm costs. Thus, for industries with only one vessel class, EPA estimated a distribution of costs per firm with 8, 

2,049, and 2,049 possibilities for the commercial fishing, port and harbor operations, and drilling oil and gas wells 

sectors, respectively. 31 

7.1.4 Compare Costs to Revenues 

Data from the Economic Census as well as from the SBA’s Statistics of U.S. Businesses were used to determine 

the firm-level financial data. These sources provided the distribution of firms across several revenue brackets as 

well as the average revenue value in each revenue bracket. 

To evaluate the potential impact of the Vessel General Permit on small entities, EPA used a cost-to-revenue test to 

evaluate the potential severity of economic impact on vessels and facilities owned by small entities. The test 

calculates annualized pre-tax compliance cost as a percentage of total revenues and uses a threshold of 1 and 

3 percent to identify facilities that would be significantly impacted as a result of this Permit. 

The cost values equivalent to the 1 and 3 percent thresholds were estimated from the average revenue in each 

revenue bracket, or the midpoint of the revenue bracket when average revenue was not reported. Each possibility 

from the distribution of firm costs, described in Section 7.1.3, was compared to the 1 and 3 percent thresholds. 

EPA estimated the percentage of firms that would be significantly impacted as a result of this Permit as the 

percentage of cost possibilities where the firm costs exceeded the revenue thresholds. 

7.2 Small Entity Analysis 

Consistent with the framework and requirements of the Regulatory Flexibility Act, EPA prepared a screening 

analysis that examines the impacts of this Permit on small entities. A small entity may be: 

3⁄4 A small business according to SBA size standards 

3⁄4 A small governmental jurisdiction that is a government of a city, county, town, school district, or special 

district with a population of less than 50,000 

3⁄4 A small organization that is a not-for-profit enterprise that is independently owned and operated and is not 

dominant in its field. 

The SBA defines small businesses based on NAICS codes and size standards expressed by the number of 

employees or annual receipts (13 CFR §121.20). For the water transportation, fishing, and drilling oil and gas 

wells sectors, SBA’s business size standards are based on annual revenues as well as employee size. If the 

revenues or employment were smaller than the corresponding thresholds, EPA classified the entities as small. 

Section 5.4.2: Small Businesses presents the small business thresholds used in this analysis and the number of 

small businesses in each sector of the water transportation and fishing industries, and of the drilling oil and gas 

wells sector within the mining industry. On the whole, the affected industries contain more than 90 percent small 

businesses. Based on data from the U.S. Census Bureau and the SBA, of the 5,037 firms in the water 

transportation industries, 4,770 (94.3 percent) are small. In the fishing industry, 1,843 (96.2 percent) of the 1,916 

firms are small. In the drilling oil and gas wells sector, 1,470 (97.7 percent) of the 1,504 firms are small. 

 

31 The drilling oil and gas wells sector has the same distribution of costs (thus, the same number of cost combinations) as the port and 

harbor operations sector since both only contain utility vessels. 
Economic and Benefits Analysis of the Final Vessel General Permit 

After calculating the distribution of per-firm costs, the number and percentage of firms where costs exceed 

1 percent and 3 percent of revenue was estimated (by NAICS sector and revenue bracket). 

The costs used in the RFA analysis are annualized costs, which reflect the annual equivalent value of first-year 

(one-time) costs and recurring costs. The resulting 2007 annualized costs range from $0 to $61,531per vessel in 

the water transportation industry, from $0 to $1,570 per vessel in the fishing industry, and from $0 to $4,470 per 

vessel in the drilling oil and gas wells sector. 

Table 7-1 lists the median, 5th, 95th, and 99th percentile firm-level costs across all NAICS codes. For NAICS 

category 483112/483114, the 95th percentile of the firm cost is $7.31 and $88.38 per year for the low and high end 

estimates, respectively. EPA analyses, however, show that a very small proportion of firms (e.g., less than one 

percent of cruise ship firms) will have much higher costs, as high as $67,361 and $88,298 for the low and high 

end estimates, respectively, while the next highest percentile of firms (e.g., less than two percent of cruise ship 

firms) have annual costs estimated at $1,906 and $2,015 (low and high end estimates). 

Table 7-1: Estimated Median, 5th, 95th, and 99th Percentile Firm Costs by NAICS Code 

 

5th

Percentile Median 

95th

Percentile 

99th

Percentile 

Low End Cost Estimate 

11411 Finfishing, shellfishing, and other commercial fishing $0 $0 $1,570 $3,921 

483111/483113 Deep sea/coastal and Great Lakes freight $80 $146 $3,662 $17,086 

483112/483114 Deep sea/coastal and Great Lakes passenger $4 $4 $7 $1,906 

483211 

Inland waterways freight transportation and towing 

transportation $82 $393 $13,048 $62,544 

483212 

Inland waterways passenger transportation and other 

water transportation $4 $4 $1,934 $1,950 

487210 Scenic and sightseeing transportation, water $10 $23 $1,956 $9,474 

488310 Port and harbor operations $78 $78 $3,125 $20,310 

488320 Marine cargo handling $82 $795 $20,355 $68,481 

488330 Navigational services to shipping and salvage $77 $81 $3,006 $10,781 

488390 Other support activities for water transportation $1 $1 $136 $148 

213111 Drilling oil and gas wells $78 $78 $3,125 $20,310 

High End Cost Estimate 

11411 Finfishing, shellfishing, and other commercial fishing $0 $0 $1,570 $3,921 

483111/483113 Deep sea/coastal and Great Lakes freight $315 $540 $5,548 $25,792 

483112/483114 Deep sea/coastal and Great Lakes passenger $54 $54 $88 $2,015 

483211 

Inland waterways freight transportation and towing 

transportation $306 $1,445 $22,410 $94,731 

483212 

Inland waterways passenger transportation and other 

water transportation $53 $53 $2,933 $2,955 

487210 Scenic and sightseeing transportation, water $74 $107 $2,965 $14,451 

488310 Port and harbor operations $307 $311 $4,606 $29,094 

488320 Marine cargo handling $306 $1,967 $35,190 $112,349 

488330 Navigational services to shipping and salvage $301 $309 $5,039 $15,456 

488390 Other support activities for water transportation $5 $5 $206 $223 

213111 Drilling oil and gas wells $307 $311 $4,606 $29,094 

a Since NAICS 483211 and 488320 both have a high number of vessels per firm (approximately 26 vessels per firm), the 99th percentile firm 

cost is higher than for other NAICS. 

Figure 7-2 through Figure 7-3 depicts the percentage of firms exceeding specified cost thresholds for two sectors: 

deep sea/coastal and great lakes passenger transportation, and marine cargo handling. Figure 7-2 depicts the 

percentage of firms exceeding specified cost thresholds for the deep sea/coastal and great lakes passenger 

December 18, 2008 Final 101
Economic and Benefits Analysis of the Final Vessel General Permit 

category. As shown in Figure 7-2, the majority of these firms are also expected not to exceed $100 both for the 

low and high end cost estimate. 

December 18, 2008 Final 102
Economic and Benefits Analysis of the Final Vessel General Permit 

Figure 7-2: Percentage of Firms Exceeding Low End and High End Cost Thresholds, 

NAICS 483112/483114 - Deep sea/coastal and Great Lakes passenger 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

<$5

$5<Cost<$50

$50<Cost<$100

$100<Cost<$500

$500<Cost<$1,000

$1,000<Cost<$5,000

$5,000<Cost<$50,000

$50,000<Cost<$70,000

>$70,000

Low End Cost Threshold

Percent

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

<$5

$5<Cost<$50

$50<Cost<$100

$100<Cost<$500

$500<Cost<$1,000

$1,000<Cost<$5,000

$5,000<Cost<$50,000

$50,000<Cost<$70,000

>$70,000

High End Cost Threshold

Percent

Figure 7-3 depicts the percentage of firms exceeding specified cost thresholds for the marine cargo handling 

category. As shown in Figure 7-3, the majority of these firms are expected not to exceed $5,000, both for the low 

and high end cost estimate. This category experiences higher firm level costs since the overall average number of 

vessels per firm is much higher. 

December 18, 2008 Final 103
Economic and Benefits Analysis of the Final Vessel General Permit 

Figure 7-3: Percentage of Firms Exceeding Low End and High End Cost Thresholds, 

NAICS 488320- Marine Cargo Handling

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

<$100

$100<Cost<$500

$500<Cost<$1,000

$1,000<Cost<$5,000

$5,000<Cost<$10,000

$10,000<Cost<$20,000

$20,000<Cost<$50,000

$50,000<Cost<$100,000

>$100,000

Low End Cost Threshold

Percent

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

<$100

$100<Cost<$500

$500<Cost<$1,000

$1,000<Cost<$5,000

$5,000<Cost<$10,000

$10,000<Cost<$20,000

$20,000<Cost<$50,000

$50,000<Cost<$100,000

>$100,000

High End Cost Threshold

Percent

Table 7-2 presents the distribution of the entities’ cost-to-revenue ratios. As shown in Table 7-2, the total number 

of small entities in the fishing industry that are expected to exceed the 1 percent cost-to-revenue threshold is 3 for 

the low end and high end cost assumptions. The total number of small entities in the water transportation industry

that are expected to exceed the 1 percent cost-to-revenue threshold ranges from 209 to 304 under the low and high 

end cost assumptions, respectively. The total number of small entities in the drilling oil and gas wells sector that 

are expected to exceed the 1 percent cost-to-revenue threshold is 1 under both the low and high end cost 

assumptions, respectively. The three industries/sectors combined constitute 213 and 308 entities that are expected 

December 18, 2008 Final 104
Economic and Benefits Analysis of the Final Vessel General Permit 

to exceed the 1 percent cost-to-revenue threshold under the low and high end cost assumptions, respectively. This 

represents less than 1 percent of the total number of firms in the water transportation and fishing industries, and 

the drilling oil and gas wells sector, under both analytic scenarios. 

The critical cost thresholds range depending on revenue range and NAICS code. For example, a fishing firm 

within the revenue range of $0-$100,000 (with an average revenue for firms within the bracket of $54,610) would 

have a 1 percent critical cost threshold of $546. On the other hand, a firm within the marine cargo handling 

industry, within the revenue range of $100 million or more (with an average revenue of over $235 million) would 

have a 1 percent critical cost threshold of nearly $2.4 million. The majority of firms in the fishing industry and the 

drilling oil and gas wells sector fall within the revenue range from $100,000 to $499,999. The majority of firms in 

the water transportation industry fall within the revenue range from $100,000 to $249,999. As shown in Table 

7-2, the percentage of firms expected to exceed the 1 percent threshold under both the low and high end cost 

assumptions ranges from 0 to 4.93 percent depending on the NAICS code. In examining the percentage of entities 

affected, the most impacted entities fall within the inland waterways freight transportation and towing 

transportation, inland waterways passenger transportation and other water transportation, scenic and sightseeing 

transportation, navigational services to shipping and salvage, deep sea coastal and great lakes freight, and marine 

cargo handling sectors. These six sectors all have approximately 2 percent or more entities that exceed the 1 

percent threshold under both the low and high end cost assumptions. 

December 18, 2008 Final 105
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 106

Table 7-2: Results of the Small Entity Impact Analysis 

NAICS Code NAICS Description 

1 Percent or 

greater 

Between 1 

Percent and 3 

Percent 

3 Percent or 

greater 

Low End Cost Estimate 

11411 Finfishing, shellfishing, and other commercial fishing 3 0.01% 3 0.01% 0 0.00%

483111/483113 Deep sea/coastal and Great Lakes freight 29 2.04% 23 1.64% 6 0.41%

483112/483114 Deep sea/coastal and Great Lakes passenger 30 0.41% 21 0.29% 9 0.12%

483211 

Inland waterways freight transportation and towing 

transportation 27 2.34% 25 2.14% 2 0.20%

483212 

Inland waterways passenger transportation and other 

water transportation 42 3.46% 29 2.43% 12 1.03%

487210 Scenic and sightseeing transportation, water 9 4.76% 5 2.45% 4 2.31%

488310 Port and harbor operations 2 0.18% 0 0.00% 2 0.18%

488320 Marine cargo handling 0 1.96% 0 1.80% 0 0.16%

488330 Navigational services to shipping and salvage 70 2.74% 51 1.99% 19 0.75%

488390 Other support activities for water transportation 0 0.00% 0 0.00% 0 0.00%

213111 Drilling oil and gas wells 1 0.44% 0 0.00% 1 0.44% 

 TOTAL 213 0.52% 157 0.38% 55 0.13%

High End Cost Estimate 

11411 Finfishing, shellfishing, and other commercial fishing 3 0.01% 3 0.01% 0 0.00%

483111/483113 Deep sea/coastal and Great Lakes freight 39 2.75% 33 2.34% 6 0.41%

483112/483114 Deep sea/coastal and Great Lakes passenger 30 0.41% 21 0.29% 9 0.12%

483211 

Inland waterways freight transportation and towing 

transportation 51 4.45% 34 2.98% 17 1.47%

483212 

Inland waterways passenger transportation and other 

water transportation 42 3.46% 29 2.43% 12 1.03%

487210 Scenic and sightseeing transportation, water 9 4.93% 5 2.62% 4 2.31%

488310 Port and harbor operations 8 0.72% 4 0.36% 4 0.36%

488320 Marine cargo handling 0 4.46% 0 3.30% 0 1.16%

488330 Navigational services to shipping and salvage 123 4.82% 104 4.07% 19 0.75%

488390 Other support activities for water transportation 0 0.00% 0 0.00% 0 0.00%

213111 Drilling oil and gas wells 1 0.88% 0 0.00% 1 0.88% 

 TOTAL 308 0.75% 235 0.57% 73 0.18% 

Figures do not necessarily add to totals due to rounding. 

The graphs in Figure 7-4 and Figure 7-5 demonstrate the percentage of entities exceeding the 1 percent and 3 

percent cost-to-revenue threshold for the low end cost estimate. The number and percentage of entities exceeding 

the thresholds for the high end estimate are in line with the figures below. Figure 7-4 presents the percentage of 

entities at the 100 percent scale, demonstrating the overall low percentage of entities affected. Figure 7-5 is a 

small scaled version of Figure 7-4, detailing the percentage of entities affected across each NAICS code.
Economic and Benefits Analysis of the Final Vessel General Permit 

Figure 7-4: Distribution of Small Entity Impacts Among the Transportation and Fishing Industries

Gas Wells Sector, 100 Percent Scale 

0.0%

10.0%20.0%30.0%40.0%50.0%60.0%70.0%80.0%90.0%

100.0%

11411

483111/483113 483112/483114 483211 483212 487210 488310 488320 488330 

NAICS Code*

Percent of Entities Exceeding Threshold

1 Percent or greater 3 Percent or greater 

Figure 7-5: Distribution of Small Entity Im

Transportation and Fishing Industries, and 

Wells Sector, 5 Percent S

0.0%1.0%2.0%3.0%4.0%5.0%

1

141

1

1

1/4831

1

3

1

2/4831

14

48321

1

483212 487210 488310 

Percent of Entities Exceeding Threshold 

* The industries/sectors that are attributed to each NAICS code are as follows: 11411 – Fin fishing, shell fishing, and other commercial fishinsea/coastal and Great Lakes freight; 483112/483114 – Deep sea/coastal and Great Lakes passenger; 483211 – Inland waterways freight tratransportation; 483212 – Inland waterways passenger transportation and other water transportation; 487210 – Scenic and sightseeing transPort and harbor operations; 488320 – Marine cargo handling; 488330 – Navigational services to shipping and salvage; 488390 – Other supptransportation; 213111 – Drilling oil and gas wells December 18, 2008 Final 
Economic and Benefits Analysis of the Final Vessel General Permit 

7.3 Issues and Uncertainties 

The number and percentage of firms estimated to incur economic impacts is based upon the firm number 

estimated based on from the VESDOC and WTLUS databases. EPA assumes that the Economic Census 

distribution of firms by revenue size is the same as the VESDOC/WTLUS distribution of firms by revenue size. 

These assumptions may result in a distribution that differs from the actual distribution of affected firms. 

There is uncertainty surrounding EPA’s assumption that the average number of vessels per firm is proportional to 

the midpoint of the revenue bracket. In addition, the constraint that there must be at least one vessel per firm was 

binding for the lower revenue brackets. These assumptions may result in underestimation or overestimation of the 

number of vessels per firm, and the underestimation or overestimation may vary by revenue size category. In 

instances where EPA underestimates the number of vessels per firm, in the aggregate or by revenue size category, 

market impacts may be underestimated. In instances where EPA overestimates the number of vessels per firm, 

market impacts may be overestimated. There is uncertainty surrounding the choice of using only 11 possible costs 

for each vessel class (minimum, maximum, and by 10 percentile increments) and more accurate estimates could 

be obtained by using a greater number of cost possibilities. However, since industries can have up to seven vessel 

types, the number of sampled vessel costs is limited by computational feasibility - with 11 possible vessel-class 

costs and 7 vessel types there are 117

 possible firm costs. In the case of passenger vessels and cruise ships where 

only a small percentage of vessels incur costs, EPA limited the uncertainty in the estimates by using 101 different 

cost possibilities. Because industries with fewer vessel classes are more likely to be sensitive to the sample size, 

EPA evaluated all possible costs for industries with only one vessel class (i.e., all possible combinations of the 

estimated individual practice costs). 

After simulating a sample of vessel class costs, EPA calculated an average cost per vessel across all vessel classes 

within each industry sector. For example, NAICS 483212 include both passenger vessels and utility vessels, and 

on average, firms in the lowest revenue bracket have one vessel. Since 99.5 percent of the firms’ vessels are 

passenger vessels, the firm cost is estimated as the weighted average of vessel costs (99.5% * [Passenger Vessel 

Cost] + 0.5% * [Utility Vessel Cost]) * 1, where the Passenger Vessel Cost and Utility Vessel Cost are sampled as 

described in Section 7.1.3. There is uncertainty associated with this simplifying assumption, because calculating a 

weighted average vessel cost results in less cost variation compared to an alternative approach that simulates a 

distribution of vessel classes for firms. 

For each revenue bracket EPA assumed that firm revenues were equal to the average revenue in the bracket (or 

the midpoint when the average was not available). There is uncertainty associated with this simplifying 

assumption, because calculating an average firm cost results in less variation compared to an alternative approach 

that simulates a distribution of firm revenues within revenue size ranges. 

December 18, 2008 Final 108
Economic and Benefits Analysis of the Final Vessel General Permit 

8 Benefits Analysis 

EPA expects that reductions in vessel discharges will benefit society in two broad categories: (1) reduced risk of 

invasive species introduction and (2) enhanced environmental quality from reduced pollutant discharges. Section 

8.1.2: Benefits Analysis provides a qualitative assessment of the ecological and economic impacts of invasive 

species introductions and the benefits of reducing the occurrence of invasive species. Section 8.2 discusses 

pollutants of concern (POCs) found in vessel discharges, their environmental effects, and the benefits likely to be 

achieved by the requirements of the Vessel General Permit. 

8.1 Ballast Water Exchange and Invasive Species Impacts 

8.1.1 Introduction and Background 

Introductions of non-indigenous species have occurred in the United States for centuries, with more than 50,000 

total non-native species thought to be successfully established with reproducing populations in U.S. territory 

(Pimentel et al., 2005). Scientists and governments have long recognized the economic and ecological damages 

associated with land-based invaders, but attention has only turned toward aquatic non-indigenous species (ANS) 

since the 1980s, when the extent of the zebra mussel invasions in the Great Lakes region first became a serious 

problem (Ruiz and Reid, 2007). ANS invasions have caused tremendous economic and ecological damages to 

critical coastal and inland waters throughout the United States. 

ANS may be introduced through a variety of vectors, including intentional introductions, escape from a confined 

environment, or ballast water and sediment from ballast tanks. One of the major known vectors for ANS 

introduction is through the ballast water tanks of commercial vessels. Ballast water is taken on in or near port to 

provide stability to ships that are not fully loaded. Often, aquatic invertebrates, plants, or microorganisms, as well 

as suspended sediments that may contain invasive species, are unintentionally taken in along with the ballast 

water. 

Two recent studies conducted by NOAA’s Great Lakes Environmental Research Laboratory (GLERL) found that 

a majority of ships and a near-majority of tanks surveyed contained non-indigenous strains of pathogens known to 

cause human health impacts (Johengen et al., 2005; Reid et al., 2007). The Johengen et al. (2005) study also found 

that viable populations of non-native dinoflagellate and invertebrate species were present in a large majority of 

tanks sampled. Glassner-Shwayder refers to ships with ballast water as “biological islands” because they carry 

such a wide variety of organisms in their ballasts (1999). According to some studies, as many as 4,000 species can 

be found in a typical ship’s ballast water at one time. 

When this ballast water is discharged in another port, or when sediments in the ballast tank are mixed with new 

ballast water, these species can be introduced into an exotic environment, and may become established under 

some conditions (Ruiz and Reid, 2007). Several of the most harmful invasive species currently known to exist in 

the United States, including the zebra mussel, the green crab, and the Asian clam, are all thought to have been 

introduced via ballast water. Researchers hypothesize that as international trade, and therefore shipping traffic, 

increases, so does the threat of more ANS introductions (Glassner-Shwayder, 1999). 

The U.S. Coast Guard’s 2004 Rulemaking for Mandatory Ballast Water Management (codified in 33 CFR 151) 

mandated open ocean ballast water exchange for ships traveling outside the 200-nautical mile exclusive economic 

zone (EEZ) of the United States. While promulgation of this Permit is reducing the probability of new 

introductions, it covers neither vessels traveling within the U.S. EEZ nor vessels with empty ballast tanks, both of 

which are potential sources of ANS introductions. 

December 18, 2008 Final 109
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 110

The ballast water provisions of EPA’s new Vessel General Permit will help to address these gaps, further 

reducing the possibility of ANS introductions. Specifically, the Permit requires ballast water exchanges at least 50 

nm from shore for vessels engaged in Pacific nearshore voyages, which were previously exempted from 

mandatory exchange procedures. It also requires saltwater flushing for vessels declaring no ballast on board 

(NoBOB) or for vessels with some proportion of their ballast tanks empty. 

8.1.2 ANS Impacts 

ANS invasions are a persistent problem in U.S. coastal and inland waters. ANS invade U.S. waters through a 

number of dispersal mechanisms including releases from fisheries; research and education facilities; restoration 

efforts; public aquaria and the aquarium pet industry; and by being attached to or within ships, drydocks, 

amphibious planes, floating marine debris, drilling platforms, navigation buoys and marine floats, canals, and 

recreational equipment (Carlton et al., 2003). Each vector has been associated with introductions of highly 

damaging species in the past, although this analysis will focus primarily on the ballast vector described in the 

previous section. 

Though no reliable and comprehensive estimates of total ANS introductions nationwide exist, case studies of 

several major bodies of water across the country, as summarized in Table 8-1, provide a sense of the extent of the 

problem. 

Table 8-1: Estimates of Invasive Species in Several Major Water Systems 

Region Estimated Rate of Invasiona Estimated Total Invasions to Dateb

Great Lakes Once every 28 weeksc 162 

Mississippi River System Unknown 100 

San Francisco Bay Once every 24 weeksd 212 

Lower Columbia River Basin Once every 5 monthse 81 

Gulf of Mexico Unknown 579 

a Ruiz and Reid (2007) suggest that these figures may not reliably represent the true rate of introduction, as they are 

based on discovery data, which may not always track with the underlying rate of introduction. 

b All figures in this column are taken from USCG (2004b). 

c NOAA (2007). 

d Cohen and Carlton (1995). 

e Sytsma et al. (2004). 

The total costs associated with ANS in the United States are staggering. A recent study suggests that expenditures 

on control alone for ANS in the United States total approximately $9 billion annually (Pimentel et al., 2005). A 

broad range of damages are associated with any introduction of a given type of species, summarized in Table 8-2.

Although some species cause no economic damage, others may cause hundreds of millions of dollars in damages. 

The majority of these damages may be broken down into six broad categories of impacts, which are described in 

the subsequent subsections.32

 

32 Portions of a previous analysis of benefits associated with ANS introduction reductions are incorporated into this analysis (Abt 

Associates Inc., 2005). 
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 8-2: Estimates of Invasive Species Damages by Type of Species

Type of Species Range of Potential Damages per Invasion per Year 

(Million 2007$) 

Fish 0 – 153a

Mollusks 0 – 6,100b

Non-Mollusk Invertebrates 0 – 22.6c

Plants 0 – 35.1d

Pathogens 0 – 0.726e

a Based on Ruffe (Leigh, 1998), adjusted to 2007$ using CPI. 

b Based on Zebra Mussel (Pimentel et al., 1999), adjusted to 2007$ using CPI. 

c Based on European Green Crab (EPA, 2008a). 

d Based on hydrilla (OTA, 1993), adjusted to 2007$ using CPI. 

e Based on an outbreak of epidemic cholera (Lovell and Drake, 2007), adjusted to 2007$ using 

CPI.

Commercial and Recreational Fisheries 

As noted above, the introduction of ANS can cause the imbalance of native ecosystems. ANS pose an especially 

serious risk to commercial and recreational fisheries, which like other aquatic resources could be devastated by 

ANS (IDNR, 2003). Several examples of ANS impacts on fisheries are provided below. 

3⁄4 Sea Lamprey: The sea lamprey, which is native to the Atlantic Ocean, was not initially introduced to the 

Great Lakes by ballast water, but has been introduced elsewhere through contaminated ballast water 

(Toledo, 2001). Upon its initial introduction, the sea lamprey caused a massive collapse of the trout 

fisheries in the Great Lakes. If sea lamprey control measures were eliminated, the resulting lost value to 

fisheries would be approximately $500 million annually, according to one estimate (OTA, 1993). Control 

measures that have been introduced to counteract the impacts of sea lampreys cost more than $12 million 

annually (ANSTF, 2007). 

3⁄4 European Green Crab: The most likely mode of the initial European green crab introduction on the East 

Coast of North America was ship fouling (Cohen et al., 1995). Other possible pathways of introduction 

include ballast water and solid ballast. Grosholz (2006) and Cohen (1997) believe that incidental transport 

with commercial fishery products is the most likely vector for the initial introduction of C. maenas to the 

West Coast. The annual estimated economic damages from European green crab predation to commercial 

and recreational shellfisheries and eelgrass restoration efforts range from $18.6 to $22.6 million per year 

in the United States (EPA, 2008a). 

3⁄4 Round Goby: The round goby, native to Eurasia and likely introduced via ballast water, is thought to 

have adverse impacts on fisheries, due to its lack of value as a sport or commercial catch and its 

aggressive tendencies toward baited lines. Fishermen report that they are sometimes able to catch only 

gobies when fishing for the more desirable walleye (Marsden and Jude, 1995). No attempts to quantify 

the value of these impacts have been made to date. 

3⁄4 Zebra Mussel: An invasion of zebra mussels, which are native to the Caspian Sea and were introduced to 

U.S. waters in ballast water, has led to a halt in the $3 billion dollar Mississippi River shelling industry 

(Randall, 2001). 

3⁄4 Pathogens: Pathogens transported in ballast water can also have significant adverse impacts on fisheries. 

infectious salmon anemia (ISA) has been a persistent problem in U.S. Atlantic fisheries’ stocks since 

2001. The original source and vector of this pathogen is unknown. Though there has been no attempt to 

quantify damages to the U.S. economy specifically from ISA, it is estimated that the annual cost in 1999 

was $11 million in Norway, $14 million in Canada and $32 million in Scotland (Cipriano and Miller, 

2002). 

December 18, 2008 Final 111
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 112

Another recent fish pathogen of concern has been viral hemorrhagic septicemia (VHS). VHS has been 

known to exist in the coastal regions since the late 1980s, but only recently migrated into the Great Lakes 

through an unknown vector (USDA, 2006). An unpublished study found that VHS has impacted 6 of 23 

fish species caught commercially in the Great Lakes, including two that account for 76 percent of the 

entire $13.5 million dollar harvest (Lovell and Drake, 2007). In 1991, an exotic strain of Vibrio cholerae

(epidemic cholera) was identified in oysters in Mobile Bay on the Gulf Coast. The estimated economic 

losses due to the closure of oyster harvesting in Mobile Bay for five months in 1991 as a response to 

concerns about epidemic cholera contamination were $726,000 (2007$) (Lovell and Drake, 2007). 

Two non-native pathogens, MSX (Haplosporidium nelsoni) and Dermo (Perkinsus marinus) have caused 

substantial damages to native oyster populations in several U.S. coastal regions. Though the original 

vector of introduction is unknown for both pathogens, ballast water is considered to be one potential 

source of MSX, and Dermo is known to transmit relatively easily between infected and uninfected oysters 

(McKnight, 2007; Ewart and Ford, 1993). 

Other Water-Based Recreation and Tourism 

ANS have also had adverse impacts on recreation and tourism nationwide by damaging water quality and flow. 

Two invasive plants, hydrilla and water lettuce, have caused significant damages in U.S. waters. Both clog the 

water’s surface, blocking boating and swimming, impeding water flow, and disrupting plant and animal 

communities. Florida spends an estimated $1 million or more annually to control water lettuce, and the rest of the 

Eastern U.S. states spend approximately $100,000 annually (Van Driesche et al., 2002). Studies of two lakes in 

Florida affected by hydrilla found that degradation caused by the hydrilla cost the state $11 million in lost 

recreation expenditures (Pimentel et al., 1999).33

Invasive mollusks such as zebra mussels can also adversely affect a number of recreational activities, including 

boating and swimming. Zebra mussels often cover shorelines with sharp-edged shells and rotting mussel flesh, 

which can diminish interest in visiting infested beaches. Biofouling can also be a deterrent to recreational boaters 

who would rather avoid zebra mussel fouling and the resulting necessity of extensive vessel cleaning (USACE, 

2002). A study by Vilaplana and Hushak (1994) estimated that incremental annual costs to boat owners in the 

Great Lakes related to the mussel included $94 for protective anti-fouling paints, $171 for additional maintenance, 

and $207 for insurance. 

Biodiversity and Ecosystems 

Introductions of ANS can drastically alter virtually every characteristic of an aquatic ecosystem. ANS can affect 

the “composition, density, and interactions of native species” that can then cause “significant changes to the 

ecosystem, such as alterations to the food webs, nutrient dynamics and biodiversity” (IDNR, 2003). Ecosystems 

provide a variety of services, including water quality maintenance, detoxification and decomposition of waste, 

climate stabilization, mitigation of natural disaster impacts, and a source of income. Several significant instances 

of adverse ecosystem impact include: 

3⁄4 Zebra Mussel: Zebra mussels have had some of the most dramatic impacts observed to date on 

ecosystems, particularly in the Great Lakes region. The mussels achieved densities as high as 700,000 per 

square meter, which led to a much greater filtration rate of particulate matter, resulting in much lower 

turbidity (Griffiths et al., 1991; MacIsaac et al., 1995). This in turn led to much greater filtration of light 

through the water column, which affected plant viability and substantially increased competition for food 

for indigenous mollusks. 

 

33 This cost may have an adverse impact locally, but because the money is still available to be spent elsewhere, this adverse impact does not 

represent a true net welfare loss. 
Economic and Benefits Analysis of the Final Vessel General Permit 

3⁄4 Round Goby: The round goby was first introduced into the Great Lakes region via ballast water. The 

goby preys on benthic fauna competing with species native to the Great Lakes and takes over prime 

spawning sites of native species, which is changing the balance of the ecosystem. Introduction of the 

round goby adversely affected a number of native species, including mottled sculpin, logperch, and 

darters. Because of this threat, the U.S. Army Corps of Engineers and U.S. EPA have spent $1.2 million 

to erect a dispersal barrier to prevent its further spread down the Chicago Sanitary and Ship Canal to the 

Mississippi River (Glassner-Shwayder, 1999). 

3⁄4 European Ruffe: The European ruffe preys on native fish and competes with them for habitat. It was 

introduced into the Great Lakes via ballast water and poses a serious threat to species like the walleye, 

yellow perch, and whitefish (Leigh, 1998). Populations of spawning European ruffe in the St. Louis River 

went from 200,000 in 1989 to 1.8 million in 1991. At the same time, populations of yellow perch, 

troutperch, emerald shiners, and spottail shiners decreased by 75 percent (RTF, 1992). The expected 

reduction in value of sport and commercial fisheries in the Great Lakes region due to the ruffe invasion is 

$119 million (ANSTF, 2007). 

3⁄4 Snowflake Coral: Carijoa riisei, or snowflake coral, an invasive coral species, is threatening the 

ecosystem stability of the ecologically sensitive Northwestern Hawaiian Islands Coral Reef Ecosystem 

Reserve (NOAA, 2004a; Toonen, 2005). It is also a threat to the native black coral, which a local industry 

valued at $30 million harvests and uses to make jewelry. 

Threatened and Endangered Species 

Invasions have had especially adverse impacts on threatened and endangered species by predation, alteration of 

habitat, or further competition for limited resources. It is estimated that non-indigenous species are a contributing 

factor to the endangered status of 70 percent of listed fish species, and more than half of combined endangered 

and threatened listings (OTA, 1993). They are also estimated to have contributed to 68 percent of fish extinctions 

in the last 100 years (Larson and Sytsma, 2006). 

Damage to Infrastructure 

Industrial facilities, such as those that purify water, generate electricity, and manufacture goods, depend on water 

intake structures to perform their services. These structures can often be adversely affected by ANS. 

So far, zebra mussels have been the most damaging ANS introduced into U.S. fresh waters, causing particularly 

severe problems with water intake structures (USACE, 2002). Zebra mussels attach to surfaces of water intake 

structures, navigation dams, pumping stations, and gears, often making them inoperable, which inconveniences 

the public and costs industry significant financial losses and damages (USACE, 2002). 

Hushak (1996) reports on the results of 398 surveys of Great Lakes users with lake water intake structures from 

1989 to 1994 for private and public utilities, municipal water facilities, and industrial users. Extrapolating the 

results of this survey to all facilities in the Great Lakes yielded total monitoring and control costs of $120 million 

from 1989 to 1994 with an average cost of $30 million annually (Park and Hushak, 1998). Another study done in 

1995 of the economic impact of zebra mussels (O’Neill, 1997) found that the total costs of zebra mussels control 

and monitoring were $69 million, with a mean cost of $205,570 per facility. The study results also showed that 

total annual expenses rose from $234,140 in 1989 to $17,751,000 in 1995 as the range of mussels increased 

(O’Neill, 1997). 

Another invasive bivalve species, the Asian clam, is estimated to have caused fouling damage that cost the 

nuclear industry about $1 billion per year in the early 1980s (OTA, 1993). Two other invasive bivalves, the brown 

mussel and the green mussel, have also caused fouling damages in the Gulf Coast region and Tampa Bay, 

December 18, 2008 Final 113
Economic and Benefits Analysis of the Final Vessel General Permit 

respectively, where each has become established, although the total economic value of the damages is not known 

(Benson et al., 2002; GSMFC, 2003). 

Finally, invasive plant species such as hydrilla and water hyacinth can disrupt water flow in irrigation canals and 

in utility cooling reservoirs. Annual expenditures on aquatic weed control in the United States, much of which is 

spent on ANS weeds specifically, are estimated at $110 million (Pimentel et al., 2005). 

Human Health Impacts 

Most new human pathogens arise by the introduction of organisms from outside the country. Although a 

comprehensive estimate of the monetary cost of exotic pathogens to Americans is not available, but it is certain to 

be considerable. Examples of exotic pathogens that pose a threat to human health in the United States include 

West Nile virus, avian influenza, and human immunodeficiency virus (USDA, 2007). The expansion of trade and 

globalization and human mobility are significant factors in the spread of human pathogens. 

Though the exact nature of the link between human health impacts and ANS invasions through ballast water is 

poorly understood, studies have established that pathogenic invasive species can be transported in ballast water 

(Ruiz and Reid, 2007). Moreover, in the case of epidemic cholera, a serious human pathogen, the presence of nonnative strains has already been confirmed in U.S. waters (CDC, 1993). The potential human health impacts 

associated with ballast water transport are an object of increasing concern. Some pathogenic bacteria identified in 

ballast water known to be associated with adverse human health impacts include E. coli, enterococci, Vibrio 

cholerae, Clostridium perfingens, Salmonella spp. Cryptosporidium spp., and Giardia spp., as well as a variety of 

viruses (Knight et al., 1999; Reynolds et al., 1999; Zo et al., 1999). 

In July 1991, a strain of Vibrio cholerae was identified in oysters in Mobile Bay on the Gulf Coast that was 

indistinguishable from a Latin American strain not endemic to the United States. An investigation indicated that 

the pathogen was most probably introduced from the discharge of contaminated ballast water (CDC, 1993). 

Because oysters are often eaten raw, this is a potential human health threat. Of the 61 cases of cholera in the 

United States between 1995 and 2000, 14 were caused by the consumption of undercooked seafood (Steinberg, 

2001). Though it is unclear whether any of these cases were caused by exotic strains of Vibrio cholerae, this 

evidence clearly indicates that the potential exists for the transport of harmful non-native pathogens in ballast 

water. 

As mentioned in the introduction to this section, a study by NOAA also showed the potential for pathogens to be 

transported in ballast water tanks, even when they are not filled. The study found that virus-like particle 

concentrations in sampled ballast tanks ranged from 107

 to 109 per ml in residual unpumpable ballast water and 

from 107

 to 1011 per ml in sediment porewater. Bacteria concentrations under the same conditions were 105 to 109

per ml and 104

 to 108 per ml, respectively (Johengen et al., 2005). Since a critical component of the new Permit is 

its provisions for saltwater flushing in vessels with empty ballast tanks, removing sediments may reduce the 

potential for pathogen contamination. 

Ballast water is also a vector for the microorganisms associated with the “red tide” or harmful algal bloom 

phenomenon. This phenomenon occurs when certain species of algae release toxins into an aquatic environment, 

which adversely impacts aquatic life and can also impact human health if fish contaminated with the toxin are 

consumed (WHOI, 2007). Although current USCG mandatory BMPs for all vessels with ballast tanks, codified in 

33 CFR 151, require vessels not to take up ballast water in areas known to be contaminated with such organisms, 

the new Permit’s requirements governing ballast exchange may further reduce the spread and impact of these 

organisms. 

8.1.3 Efficacy of Ballast Water Exchange and Saltwater Flushing 

Studies have found that ballast water exchange and saltwater flushing generally reduce the quantity of ANS 

discharged into U.S. waters and therefore the risk of potential invasions (Johengen et al., 2005; Reid et al., 2007). 

December 18, 2008 Final 114
Economic and Benefits Analysis of the Final Vessel General Permit 

Dye tests found that 300 percent flow through exchange and empty tank refill exchange successfully displaced 

80–99 percent of initial water in ballast tanks (Reid et al., 2007). 

A NOAA study of saltwater exchange efficacy found that saltwater flushing results in the resuspension of 30–80 

percent of sediment deposits in a given vessel (Reid et al., 2007). As sediments are one potential vector for 

introductions, reducing sediments in tanks can in turn reduce ANS discharges. One piece of the study found that 

salinity alone reduces populations of several types of potential invaders, including most phytoplankton species, 

rotifers, cladocerans, and some copepods and flatworms. Results were less conclusive for several other important 

types of potential invasive species, including pathogens, bivalves, crabs, barnacles and shrimp (Reid et al., 2007). 

All available studies conclude that mandatory ballast water management practices are a valuable tool in 

combating invasions, and should be extended to vessels with empty tanks and vessels not departing the EEZ, as 

the new EPA Permit will do in some cases. 

8.1.4 Benefits of Reducing ANS Introductions 

The evidence presented in Section 8.1.2: ANS Impacts demonstrates that introductions of ANS through ballast 

water are associated with significant detrimental impacts throughout the United States. The ballast water 

provisions of EPA’s final Vessel General Permit, to the degree that they fill a gap in the existing ballast water 

management practices, can therefore be expected to generate benefits by reducing the risk of such damages in the 

future. Benefits would include the prevention of damages to fisheries, tourism, and recreation, of damages to 

infrastructure, and of adverse human health impacts, as well as prevention of further stresses on native 

biodiversity and ecosystems. 

The issue of ANS invasions and their impacts presents unique challenges for the estimation of the benefits 

associated with this Permit. Although ballast water is one of the major pathways of invasive species introduction, 

estimating changes in risk of introduction of invasive species from the Permit requirements is not feasible due to 

the lack of data on rates of invasive species introduction associated with ballast water releases. Moreover, because 

the type of species introduced in the future is unknown and the range of potential economic impacts associated 

with each species type is very large, estimating the monetary value of benefits from preventing future invasions 

with a reasonable degree of certainty would not be possible. 

Commercial and Recreational Fisheries 

A reduction in the number of ANS introductions due to the final ballast management requirements and other 

Permit requirements may prevent significant future damages to commercial and recreational fisheries that play a 

critical role in the U.S. economy. In 2006, 9.5 billion pounds of commercial landings were made by U.S. 

fishermen at U.S. ports, and were valued at $4 billion (NMFS, 2007). An additional 29.9 million anglers aged 16 

and older spent an average of 17 days fishing in 2006, spending more than $40 billion dollars on trips, equipment, 

licenses, and other costs (USDOI, 2007). Leigh (1998) estimated the annual reduction in value of yellow perch, 

walleye, and whitefish fisheries due to ruffe invasion under moderate scenario assumptions to be $119 million (in 

1998 dollars; $153 million (2007$) inflated using the Consumer Price Index (CPI)). 

Other Water-Based Recreation and Tourism 

Another source of potential benefits from the reduction of ANS introductions under the Permit will be the 

prevention of damages to valuable recreation and tourism sites. A report by NOAA (2004b) estimated the annual 

revenue associated with coastal tourism in the United States to be $54 billion, and found that beaches are the most 

popular tourist destinations in the United States. One invasive plant species alone, hydrilla, is associated with 

$14.5 million annually in control costs, and reduces lake recreation on two Florida lakes alone by $11 million in 

years when hydrilla covers the lakes (Pimentel et al., 1999). Since data are limited on the impacts of invasive 

species on recreation and tourism in ecosystems for which estimated rates of invasion exist, it is not possible to 

December 18, 2008 Final 115
Economic and Benefits Analysis of the Final Vessel General Permit 

calculate the level of expected benefits for other water-based recreation and tourism. However, EPA projects that 

there will be some incremental benefits. 

Biodiversity and Ecosystems 

Additional significant benefits from the Permit will accrue to biodiversity and ecosystems. As detailed in Section 

8.1.2: ANS Impacts, ANS are associated with substantial adverse impacts on the composition of ecosystems and 

the biodiversity therein. The quantification of biodiversity benefits will not be attempted in this analysis due to the 

great deal of uncertainty surrounding the impact of a single ANS introduction on a given ecosystem relative to 

other factors, as well as the difficulty. However, potential benefits in the form of preservation of habitat and 

species are likely. 

Threatened and Endangered Species 

The Permit requirements for ballast water management, by reducing the impacts of invasive species introductions 

on threatened and endangered species, will have benefits in terms of prevention of reduction in species population 

and species extinction. Total federal spending nationwide on programs related to the Endangered Species Act for 

2004, the most recent year for which data are available, was more than $1.2 billion, and state spending was more 

than $200 million (USFWS, 2005). 

As mentioned above, ANS are considered likely contributors to the threatened or endangered status of 70 percent 

of listed fish species (Larson and Sytsma, 2006). Combined federal and state expenditures per listed species of 

fish in 2004 ranged from $25,000 to $1.09 million (USFWS, 2005). It is not possible to calculate a range of 

benefits to threatened and endangered species associated with EPA’s Permit requirements, due to the lack of 

research linking specific invasions with quantifiable impacts on particular species. However, it is likely that some 

proportion of potential future expenditures on endangered and threatened fish, as well as expenditures on other 

aquatic endangered species, would be averted by reduced ANS introductions under the Permit requirements. 

Damage to Infrastructure 

Another benefit of the Permit requirements for ballast management will result from averting damages to 

infrastructure by invasive species of plants and mollusks. Fouling by species such as the Asian clam, zebra 

mussel, and hydrilla has caused substantial economic damage to a variety of municipal and industrial entities in 

the past. Most of this damage takes the form of clogging water intake structures and disrupting the flow of water. 

One study estimated fouling damage to water intake infrastructure by zebra mussels for the year 2000 to be $5 

billion (Khalanski (1997), and cited in Pimentel et al. (1999); $6.1 billion in 2007$ using CPI). 

Human Health 

Estimating expected human health benefits of EPA’s Permit is not feasible due to very limited data on the rates of 

non-endemic pathogen invasions and the human health effects of these pathogens. Nevertheless, the Permit 

provisions are likely to reduce the probability of introduction of harmful exotic pathogens and thus are expected 

to benefit human health. 

Summary of Benefits 

The ballast water management practices established in this Vessel General Permit are designed to directly address 

the likelihood of future ANS invasions. The categories of potential damages from such ANS invasions have been 

discussed above, and studies referenced as to the potential magnitude of these damages for each. To the degree 

that these damage estimates provide an indicator of the likely payback that can be anticipated from reducing ANS 

invasions, EPA believes the benefits of this Permit can be expected to be very significant. However, the 

December 18, 2008 Final 116
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 117

complexity of the ANS issue, the wide range and varied nature of impacts these invasions can cause, and the great 

breadth of the scope of this Permit prohibit EPA from developing a quantified estimate of these benefits. 

8.2 Benefits of Reduced Pollutant Discharges from Vessels 

8.2.1 Introduction and Background 

The Clean Water Act and its associated regulations have greatly improved the quality of the nation’s waters over 

the past 35 years. Nevertheless, large portions of the United States’ fresh and saline waters remain degraded by 

elevated concentrations of harmful pollutants. EPA’s 2007 National Water Quality Inventory Report to Congress 

found that 45 percent of assessed rivers and streams; 47 percent of assessed lakes, ponds, and reservoirs; and 32 

percent of assessed bays and estuaries were classified as impaired for at least one of their designated uses (EPA, 

2007c).34 These impairments are associated with a variety of economic and ecological damages throughout the 

country. 

Many of the discharges regulated by EPA’s Vessel General Permit (2008b) were previously regulated under select 

circumstances. Several discharges are associated with a wide variety of harmful pollutants in substantial 

concentrations. For example, untreated graywater may contain pathogenic bacteria, toxic and carcinogenic 

organic and inorganic compounds, nutrients, and metals (EPA, 2007a). 

The Permit covers many discharges and contains special provisions for numerous vessel types (see EPA (2008b) 

for information on the affected discharges and provisions by vessel type). Because of the breadth of coverage and 

provisions in the Permit, the following discussion does not address all of these provisions individually, but 

focuses on the more important changes in Permit coverage for certain types of vessel discharges. Previous 

sections of this analysis address its most critical provisions, which will close a number of gaps in existing 

coverage of pollutant discharges and will generate significant potential benefits for aquatic ecosystems. These 

benefits will be likely to occur mostly in waterways receiving the greatest amount of vessel traffic. 

8.2.2 Pollutants Commonly Found in Vessel Discharges 

The numerous individual harmful constituents of vessel discharges may be grouped into six broad categories: 

nutrients, pathogens, oil and grease, metals, other pollutants with toxic effects, and other non-toxic pollutants. 

Many of the 26 types of discharges covered by EPA’s Permit are associated with one of these six types of 

pollution. Table 8-3 summarizes pollutant types potentially reduced by Permit requirements.35

 

34 States are responsible for assessing impairment of water bodies. States assessed 19 percent of rivers and streams; 37 percent of lakes, 

ponds, and reservoirs; and 35 percent of bays and estuaries in the reporting cycle summarized in this report. 

35 The effect of ballast water provisions on risk of introduction of ANS is discussed in the preceding section. 
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 8-3: Pollutants Found in Vessel Dischargesa

Type of Discharge Nutrients Pathogens Oil & Grease Metals Other Toxics Other NonToxics 

Deck Runoff x x x x x 

Bilgewater x x x x 

Anti-fouling Hull Coating x x 

AFFF x 

Boiler Blowdown x x 

Cathodic Protection x 

Chain Locker Effluent x x 

Controllable Pitch Propeller Hydraulic 

Fluid x x 

Elevator Pit Effluent x x x 

Firemain Systems x x x x 

Freshwater Layup x 

Gas Turbine Wash Water x x 

Graywater x x x x x x 

Motor Gasoline and Compensating 

Discharge x x 

Non-Oily Machinery Wastewater x x x 

Refrigeration and Air Condensate 

Discharge x x 

Rudder Bearing Lubrication Discharge x 

Seawater Cooling Overboard Discharge x x 

Seawater Piping Biofouling Prevention x 

Small Boat Engine Wet Exhaust x x 

Sonar Dome Discharge x x 

Underwater Ship Husbandry x 

Welldeck Discharges x x x x x x 

Source: Battelle (2007) 

a: Other Permit requirements that could not be firmly linked to one of these six categories of pollutants are excluded from the table.

Several types of discharges covered by EPA’s Permit have particularly significant pollutant constituents and 

therefore also may be associated with substantial incremental benefits. They are described in more detail below. 

Graywater 

Untreated graywater, as defined in Section 4.2: Graywater, contains multiple constituents of concern, including 

pathogenic bacteria, toxic and carcinogenic organic and inorganic compounds, nutrients, and metals (EPA, 

2007a). Table 8-4 summarizes the rates of discharge for major pollutants found in graywater in an EPA survey of 

cruise ships. The same survey found that total graywater discharge volumes ranged from 36 to 119 

gallons/day/person, with a mean value of 67 gallons/day/person. 

December 18, 2008 Final 118
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 8-4: Types of Pollutants Found in Graywater Discharges 

Type of Discharge Average Concentration of Pollutantsa EPA NRWQC Standardb

Ammonia – Nitrogen 2130-2210 μg N/L 2140-15,600 μg N/L CMC, 

321-2960 μg N/L CCC 

Nitrate 0.009-0.0872 mg/L ------ 

Total Kjeldahl Nitrogen 11.1-26.2 mg/L ------ 

Total Phosphorus 3.34-10.1 mg/L ------ 

Fecal Coliform 2,950,000 MPN/100 mL 43 MPN/100 mL 

Enterococci 8920 MPN/100 mL 35 MPN/100 mL 

Hexane Extractable Materialc 78-149 mg/L ------ 

Arsenic 1.22-2.25 μg/L 0.14 μg/L 

Copperd 483-510 μg/L total, 195 μg/L dissolved 74 μg/L CMC, 8.2 μg/L CCC 

Nickel 29.7-48.7 μg/L total, 18.2 μg/L dissolved 4.8 μg/L CMC, 3.1 μg/L CCC 

Thallium 0.93 μg/L total, 0.403 μg/L dissolved 0.47 μg/L (in shellfish) 

Zinc 790-2540 μg/L total, 1610 μg/L dissolved 90 μg/L CMC, 81 μg/L CCC 

Bis(2-ethylhexyl) phthalate 22.4-71.9 μg/L 2.2 μg/L 

Tetrachloroethylene 10.7-11.4 μg/L 3.3 μg/L 

Phenol 1.16-52.5 μg/L ------ 

Total Residual Chlorinee 372 μg/L 13 μg/L CMC, 7.5 μg/L CCC 

Chlorides 125 mg/L ------ 

Source: EPA (2007a) 

Note: Because of the quantity of metals and toxics detected, only pollutants exceeding EPA’s national recommended water 

quality criteria (NRWQC) or pollutants discussed elsewhere in this analysis are listed here. 

a Ranges presented in this table represent differences in reported concentrations between data from the Alaska Cruise Ship 

Initiative of the Alaska Department of Environmental Conservation (ACSI/ADEC), and EPA’s own data, both presented in EPA 

(2007a). 

b EPA has not set NRWQC for all pollutants of interest. CCC is an abbreviation for Criterion Continuous Concentration, a longterm measure of pollutant loading. CMC is Criterion Maximum Concentration, a short-term measure. 

c Hexane extractable material is considered an indicator of level of oil and grease contamination. 

d ACSI/ADEC did not conduct separate sampling for dissolved metals, so a range is not listed for dissolved metals. 

e EPA did not sample total residual chlorine; ACSI/ADEC did not sample chloride.

Previously, discharges of graywater have been largely unregulated at the federal level in the territorial waters of 

the United States, with two exceptions: the Great Lakes, where graywater discharges must be treated similarly to 

sewage discharges under the Clean Water Act; and the territorial waters of Alaska, where graywater discharges by 

cruise ships within the territorial waters are subject to discharge standards. Maine, Washington, Hawaii, and 

Florida also have state-level programs to reduce the impacts of graywater discharges from cruise ships. (See 

Chapter 4: Permit Overlap with Existing Regulations for a detailed breakdown of these requirements.) 

Under the new Permit, all vessels must minimize discharges of graywater in port, and large oceangoing vessels 

must not discharge graywater within 1 nm of shore if they have the capacity to store it. Vessel operators should 

also use biodegradable detergents, and must use non-toxic and phosphate-free soaps and detergents, which will 

reduce harmful constituents of discharges. Phosphate-based soaps and detergents are a source of phosphorus, 

which is a limiting nutrient in freshwater systems. Finally, medium- and large-sized cruise ships, as well as large 

ferries, will be subject to stricter requirements, including effluent standards for discharges within 1 nm of shore 

and requirements to discharge while underway at a speed of 6 knots or greater between 1 and 3 nm from shore. 

Because cruise ships and ferries have the largest numbers of passengers and crew, these requirements will have a 

particularly significant positive impact on receiving waters. 

Bilgewater 

Bilgewater is water from a variety of sources, including wastewater and leakage, which drains into a compartment 

in a vessel’s inner hull. Known pollutant constituents of bilgewater include nutrients, pathogens, oil and grease, 

December 18, 2008 Final 119
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 120

metals, and toxic and/or carcinogenic compounds (EPA and DOD, 1999). It is difficult to assess an average rate 

of bilgewater production, as rates of generation vary widely by vessel size and type. 

The constituents of bilgewater that are of greatest concern from an environmental perspective are oil and grease. 

Current regulations require the use of oily-water separators prior to discharging bilgewater for all vessels 

weighing more than 400 tons. However, this practice does not eliminate all oil and grease from discharges, but 

merely reduces it to a level below 15 ppm (EPA and DOD, 1999). Furthermore, the use of oily-water separators 

does not have any significant impact on concentrations of other pollutants found in bilgewater. 

EPA’s Permit addresses this problem by retaining existing requirements governing untreated bilgewater, and adds 

requirements that “MARPOL” vessels weighing more than 400 tons not discharge any bilgewater within 1 nm of 

shore, and only discharge treated bilgewater between 1 and 3 nm from shore if underway at a speed of at least 6 

knots. It also requires that all vessels reduce bilgewater discharges to the minimum levels required to operate the 

vessel safely (EPA, 2008b). Though these requirements will not eliminate all discharges of harmful pollutants via 

bilgewater, they will reduce the loads in areas with heavy vessel traffic that are in nearshore environments. 

Aqueous Film-Forming Foam 

Aqueous film-forming foam (AFFF) is a relatively rare type of discharge compared to many of the discharges 

covered by EPA’s Permit, but it is associated with potentially substantial adverse impacts to human health and 

ecosystems due to the toxic and carcinogenic constituents of some formulations. The primary constituents of 

concern are perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA), although AFFF discharges 

may be mixed with firemain water, which can contain bis(2-ethylhexyl) phthalate, nutrients, and metals (EPA and 

DOD, 1999; Scheffey and Hanauska, 2002).36 

3M Inc., the largest U.S. manufacturer of PFOS-based AFFF, voluntarily began to phase out production in 2000 

due to suspicion of toxicity and carcinogenicity, and had ceased production altogether by fall 2001 (Scheffey and 

Hanauska, 2002). EPA then published a rule that requires companies to file notice if they intend to manufacture or 

import any of the PFOS-based substances that 3M phased out, effectively ending all manufacture. However, 

remaining stocks of PFOS-based AFFF may still be in use. 

There is still a lack of understanding as to the extent to which PFOA and its telomers enter the environment 

through various discharges, so these chemicals remain legal to manufacture and distribute in the United States, 

including in AFFF. EPA has nonetheless encouraged participation of U.S. businesses in its voluntary 2010/15 

PFOA Stewardship Program, in which businesses agree to eliminate 95 percent of PFOA use by 2010 and 100 

percent by 2015 (EPA, 2007d). 

AFFF discharges were previously not regulated, but under EPA’s Permit, they are heavily restricted. Vessels that 

regularly sail outside the U.S. EEZ may not discharge AFFF within the EEZ except in emergencies, and vessels 

that do not sail outside the EEZ must collect all discharged AFFF and dispose of it onshore. Additionally, nonfluorinated firefighting foams are recommended for use in all vessels. 

8.2.3 Pollutant Impacts 

Vessel discharges contain a wide variety of pollutants with the potential to cause ecological and economic harm to 

aquatic species and their habitat. The relationship between types of pollutants and associated discharges is 

summarized in Table 8-4: Types of Pollutants Found in Graywater Discharges, above. 

 

36 Scheffey and Hanauska’s report discusses AFFF with respect to the aviation industry; however, similar formulations are used onboard 

vessels. 
Economic and Benefits Analysis of the Final Vessel General Permit 

Nutrients 

Nutrient pollution, including nitrogen and phosphorus, is a component of vessel discharges and a major source of 

water quality degradation throughout the United States (USGS, 1999). Though traditionally associated with 

agricultural runoff from fertilizer, sewage treatment facilities, and urban stormwater, a variety of other sources do 

exist, including graywater and bilgewater discharges from ships. 

Nutrient pollution is associated with a variety of negative environmental impacts, the most notable of which is 

eutrophication, which can lead to reduced levels of dissolved oxygen due to increased demand (sometimes to the 

extremes of hypoxia), reduced levels of light penetration and turbidity, and changes in the composition of aquatic 

flora and fauna (National Research Council, 2000). It also helps to fuel the harmful algal blooms described in 

Section 8.1.2: ANS Impacts, which can have devastating impacts on both aquatic life and human health, if affected 

organisms are consumed (WHOI, 2007). The impacts of these water quality reductions on recreation and fishing 

can be significant, particularly in estuaries. For example, a 1989 study found that a hypothetical 20 percent 

reduction in nitrogen and phosphorus loading in the Chesapeake Bay would result in an increase in recreation 

worth $34.6 million (in 1984 dollars) from increased public beach usage (National Research Council, 2000). 

Nutrient pollution has also contributed to the decline of the Chesapeake crab fishery, due to its role in degrading 

underwater vegetation, which serves as an important habitat for post-larval crabs (Maryland DLS, 2005). 

Pathogens 

Pathogens are another important constituent of discharges from vessels, particularly in graywater. EPA’s study of 

graywater discharges from cruise ships found that levels of pathogen indicator bacteria exceeded enterococci 

standards for marine water bathing and fecal coliform standards for harvesting shellfish 66 percent and over 80 

percent of the time, respectively (EPA, 2007a). Specific pathogens of concern found in graywater include 

Salmonella, E. coli, enteroviruses, hepatitis, and pathogenic protists (National Research Council, 1993). Elevated 

levels of these pathogens have increasingly resulted in beach closures in recent years, which in turn have reduced 

the recreational value of impacted beaches (NRDC, 2005). 

Though it is difficult to determine the precise contribution of vessel discharges to infections by these organisms, 

epidemiologists have attempted to quantify the proportion of total infections that are waterborne. For example, 

waterborne infection may account for as many as 60 percent of Giardia infections and 75 percent of pathogenic 

E. coli infections (National Research Council, 1993). Graywater discharges are a significant source of pathogenic 

microorganisms within the regulated waters, and reducing them would likely be associated with non-negligible 

human health benefits. 

Oil and Grease 

Oil and grease are another known component of vessel discharges with potentially harmful impacts to humans 

and to aquatic life. Oil in vessel discharges is required to be discharged in concentrations that may not be harmful, 

consistent with existing regulation. The Group of Experts on the Scientific Aspects of Marine Environmental 

Protection (GESAMP), a United Nations body, found that voluntary vessel discharges account for less than 

1 percent of vessel oil discharges into the marine environment (GESAMP, 2007). However, vessel discharges 

may still contain enough oil to do ecological damage, even if they meet existing concentration requirements and 

account for a small percentage of total oil discharges worldwide. Oils are highly toxic and carcinogenic, and may 

inhibit reproduction and cause organ damage or even mortality (AMSA, 2003). Additionally, oil can taint 

organisms that are consumed by humans, which is a potential source of adverse health impacts. 

Metals 

Metals are a diverse group of pollutants, many of which are toxic to aquatic life and humans. Vessel discharges 

can contain a variety of metal constituents. For example, EPA’s study of cruise ship graywater found a total of 13 

December 18, 2008 Final 121
Economic and Benefits Analysis of the Final Vessel General Permit 

different metals in at least 10 percent of samples, with copper, nickel, and zinc detected in 100 percent of samples 

(EPA, 2007a). Bilgewater also contains these constituents and likely others (Battelle, 2007). 

While some metals, including copper, nickel, and zinc, are known to be essential to organism function, many 

others, including thallium and arsenic, are non-essential or are known to have only adverse impacts. Even 

essential metals can do serious damage to organism function in sufficiently elevated concentrations. Adverse 

impacts can include impaired organ function; impaired reproduction and birth defects; and, at extreme 

concentrations, acute mortality. Additionally, through a process known as bioaccumulation, metals may not be 

fully eliminated removed from blood and tissues by natural processes, and may accumulate in predator organisms 

further up the food chain (EPA, 2007b). This process can result in adverse health impacts for humans, who may 

consume contaminated fish and mollusks. 

However, the impacts of metals on any given ecosystem are difficult to predict, due to the relatively complicated 

circumstances by which they are available to organisms. Bioavailability of metals, and therefore impacts, varies 

by species of organism, as well as by climate and chemistry of a water body (John and Leventhal, 1996). 

Moreover, background levels of metals can vary substantially by location (EPA, 2007b). 

Other Pollutants with Toxic Effects 

The term “other pollutants with toxic effects,” as it applies to constituents of vessel discharges, encompasses a 

variety of chemical compounds known to have a broad array of adverse impacts on aquatic species and human 

health. For example, EPA’s study of cruise ship graywater found a total of 16 different volatile and semi-volatile 

organic compounds in at least 10 percent of samples, for which the most significant rates and levels of detection 

were phthalates, phenol, and tetrachloroethylene. Other notable pollutants with toxic effects detected included free 

residual chlorine and chlorides. 

These compounds can cause a variety of adverse impacts on ecosystems, including fisheries, as well as on human 

health. Phthalates are known to interfere with reproductive health and liver and kidney function in both animals 

and humans (Sekizawa et al., 2003; DiGangi et al., 2002). Chlorine, though toxic to humans at high 

concentrations, is of much greater concern to aquatic species, which can experience respiratory problems, 

hemorrhaging, and acute mortality even at relatively low concentrations (EPA, 2007a). 

PFOS and PFOA, potentially found in AFFF discharges, are persistent, bioaccumulative chemical compounds. A 

United Kingdom study found that PFOS is toxic to humans and wildlife, and carcinogenic in humans (Footitt et 

al., 2004). 3M, the only U.S. manufacturer of PFOS-based AFFF, voluntarily ceased production in 2002, and EPA 

enacted an effective ban on the substance due to concerns about its impacts on human health and wildlife. 

However, existing stocks may still be in use (EPA, 2007d). The health impacts of PFOA and its telomers are not 

as well understood, particularly in aquatic environments, but EPA’s Science Advisory Board has concluded that 

PFOA “is likely to be carcinogenic in humans” (SAB, 2006). 

Other Non-Toxic Pollutants 

The category “other non-toxic pollutants” includes all non-conventional pollutants except fecal coliform 

(discussed in pathogens) as applied to vessel discharges also consists of multiple pollutants with disparate 

impacts. The most important types are pH pollution and thermal pollution, which can be found in several of the 

covered discharges, including graywater and bilgewater. 

Some vessel discharges are more acidic or basic than the receiving waters, which can have a localized effect on 

pH (ADEC, 2007). Though no research has been done linking vessel pollution specifically to pH impacts on 

aquatic ecosystems, extensive literature on the impacts of pH changes in the contexts of aquaculture and acid rain 

does exist. For nearly all fish populations, pH more acidic than 5 or more basic than 10 will cause rapid mortality, 

December 18, 2008 Final 122
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 123

and many individual species are sensitive to more moderate changes in pH (EPA, 2007e; Wurts and Durborrow, 

1992). 

Some vessel discharges may also be warmer or colder than the ambient temperature of the receiving water, which 

can affect temperature locally (Battelle, 2007). Thermal impacts of vessel discharges are generally much smaller 

than those from better-known sources such as dams, power plant cooling water, and runoff, due to scale. 

However, even small temperature changes can impact some sensitive organisms’ growth, reproduction, and even 

survival, which implies that some vessel discharges may have adverse impacts on aquatic ecosystems, and also 

fisheries (Abbaspour et al., 2005; Cairns, 1972; Govorushko, 2007). 

8.2.4 Benefits of Reducing Pollutant Discharges 

Many of the nation’s busiest ports are considered to be impaired by a variety of pollutants found in vessel 

discharges, as is summarized in Table 8-5. The Permit is expected to reduce discharges of nutrients, metals, oil, 

grease, toxics, and other pollutants in waters with high levels of vessel traffic. 

Table 8-5: Impairment Status of the Top 20 Ports by Annual Vessel Calls 

Port Impairments by Pollutants Found in Vessel Discharges 

Houston, TX Bacteria, Nutrientsa

New York City, NY Nitrogen, Oxygen Demand,b Cadmium, Mercury 

Port Everglades, FL Fecal Coliform, Dissolved Oxygen, Nutrients 

Miami, FL None listed 

Los Angeles/Long Beach, CA Polycyclic Aromatic Hydrocarbons (PAHs),c

 Zinc, Copper, Chromium, Lead, 

Mercury, Cadmium, Nickel 

San Juan, PR Ammonia, Fecal Coliform, Dissolved Oxygen 

Savannah, GA Mercury, Dissolved Oxygen 

St. Thomas, Virgin Islands Dissolved Oxygen, Fecal Coliform, Oil and Grease, pH 

Seattle, WA PAHs, Fecal Coliform, pH 

New Orleans, LA Fecal Coliform 

Charleston, SC None listed 

Baltimore, MD Zinc, Chromium 

Elizabeth River, VA Phosphorus, Fecal Coliform 

Oakland, CA Mercury, Selenium 

Bayou Lafourche, LA Dissolved Oxygen, Nutrients, Total and Fecal Coliform 

Galveston, TX Bacteria 

Tacoma, WA Bis(2-ethylhexyl) phthalate, PAHs 

Jacksonville, FL Coliform, Nutrients, Turbidity 

South Louisiana, LA Fecal Coliform 

Source: Battelle (2007) 

a Two of the listed pollutants are found in the areas surrounding the shipping route through the Bay of Galveston to 

Houston, rather than in the Port of Houston itself. 

b Oxygen demand is associated with eutrophication (see the subsection on Nutrient pollution). 

c PAHs are a subset of volatile and semi-volatile organic compounds and are associated with petroleum products.

These impacts will be particularly significant in those nutrient-impaired areas frequented by cruise ships (e.g., San 

Francisco Bay and Chesapeake Bay), which can discharge large volumes of graywater and are subject to stringent 

discharge requirements under the Permit. For example, phosphorus loading could be reduced by 6 lbs to 18.1 lbs, 

and zinc loading could be reduced by 1.42 lbs to 4.56 lbs per day. Table 8-6 summarizes the daily pollutant 

loadings likely to be prevented for an average large cruise ship, as the term is defined in the Permit language.37,38 

 

37 Daily loadings are calculated by taking average passenger capacity for a large cruise ship and multiplying by the average per-person 

discharge rate found in EPA (2007b). This assumes that some vessels currently remain in waters subject to the Permit requirements for 
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 124

Table 8-6: Potential Daily Reduction in Loadings of Pollutants from Graywater 

Discharges by a Large Cruise Ship in U.S. Territorial Waters 

Pollutant Average Graywater 

Generated per Day (L)a

Average Pollutant 

Concentration in 

Untreated Graywater 

Reduction in Pollutant 

Loading per Day (g) 

Ammonia - Nitrogen 814,382 2,130-2,210 μg N/L 1,734-1,800 

Nitrate 814,382 0.009-0.0872 mg/L 7.33-71.01 

Total Kjeldahl 

Nitrogen 814,382 11.1-26.2 mg/L 9,040-21,337 

Total Phosphorus 814,382 3.34-10.1 mg/L 2,720-8,225 

Hexane Extractable 

Material 814,382 78-149 mg/L 63,522-121,343 

Arsenic 814,382 1.22-2.25 μg/L 0.994-1.83 

Copper 814,382 483-510 μg/L 393-415 

Nickel 814,382 29.7-48.7 μg/L 24.2-39.7 

Thallium 814,382 0.93 μg/L 0.757 

Zinc 814,382 790-2540 μg/L 643-2,069 

Bis(2-ethylhexyl) 

phthalate 814,382 22.4-71.9 μg/L 18.2-58.6 

Tetrachloroethylene 814,382 10.7-11.4 μg/L 8.71-9.28 

Phenol 814,382 1.16-52.5 μg/L 0.945-42.8 

Total Residual 

Chlorine 814,382 372 μg/L 303 

Chlorides 814,382 125 mg/L 102 

Sources: EPA (2007a) 

a EPA (2007a) estimates average graywater generated per person per day onboard cruise ships to be 67 

gallons, which was multiplied by 3,211 (the average passenger capacity for the “large cruise ship” Permit 

category) and converted to liters for compatibility with pollutant concentration data. Since crews also generate 

graywater, this number may underestimate actual graywater generation rates. 

The evidence presented in the pollutant impacts section demonstrates that vessel discharges, particularly ANS 

spread by ballast water, are associated with significant detrimental impacts throughout the United States. Controls 

on specific discharges, as well as general housekeeping requirements of the Permit, can be expected to generate 

benefits through reducing the risk of damages in the future and making water quality improvements in alreadyimpaired waters. Monetized benefits will include the prevention of fishery closures and of adverse human health 

impacts, as well as increased opportunities for recreation. Non-monetized benefits will include prevention of 

further stresses on biodiversity and ecosystems. Though the magnitude of benefits is not calculable, Table 8-7

presents a summary of potential benefits resulting from the Permit requirements. 

 

multiple days, and thus discharge graywater equivalent to the generation rate on each subsequent day after maximum storage capacity is 

reached. 

38 E. Coli and enterococci, which are found in Table 8-4, were excluded from Table 8-6 because concentration, rather than total loading, is 

the primary metric of interest for pathogens. 
Economic and Benefits Analysis of the Final Vessel General Permit 

Table 8-7: Benefits of Reducing Pollutants Found in Vessel Discharges 

Type of Benefit Nutrients Pathogens Oil & Grease Metals Other Toxics Other NonToxics 

Human Health x x x x x 

Biodiversity x x x x x 

Ecosystem Function x x x x x 

Improved Fishery 

Conditions x x x x x 

Increased Opportunities for 

Recreation x x x 

December 18, 2008 Final 125
Economic and Benefits Analysis of the Final Vessel General Permit 

References 

33 CFR 121.201. Small Business Size Regulations. Available at http://frwebgate.access.gpo.gov/cgi-bin/getcfr.cgi. Accessed February 21, 2008. 

33 CFR 151. Vessels Carrying Oil, Noxious Liquid Substances, Garbage, Municipal or Commercial Waste, and 

Ballast Water. Available at: http://www.access.gpo.gov/nara/cfr/waisidx_07/33cfr151_07.html. Accessed 

December 4, 2007. 

33 CFR 155. Oil or Hazardous Material Pollution Prevention Regulations for Vessels. Available at: 

http://www.access.gpo.gov/nara/cfr/waisidx_07/33cfr155_07.html. Accessed December 4, 2007. 

33 CFR 159.309. Marine Sanitation Devices: Limitations on Discharge of Treated Sewage or Graywater. 

Available at: 

http://a257.g.akamaitech.net/7/257/2422/11sep20071500/edocket.access.gpo.gov/cfr_2007/julqtr/ 

33cfr159.309.htm. Accessed December 4, 2007. 

40 CFR 122. EPA Administered Permit Programs: The National Pollutant Discharge Elimination System. 

Available at: http://www.access.gpo.gov/nara/cfr/waisidx_07/40cfr122_07.html. Accessed December 4, 2007. 

40 CFR 302. Designation, Reportable Quantities, and Notification. Available at: 

http://www.access.gpo.gov/nara/cfr/waisidx_07/40cfr302_07.html. Accessed December 4, 2007. 

70 CFR 168. Ballast Water Management for Vessels Entering the Great Lakes That Declare No Ballast Onboard. 

Available at: http://www.uscg.mil/hq/g-m/mso/docs/nobob_policy_fr.pdf. Accessed February 14, 2008. 

73 CFR 117. Draft National Pollutant Discharge Elimination System (NPDES) General Permits for Discharges 

Incidental to the Normal Operation of a Vessel. Available at: 

http://www.epa.gov/npdes/regulations/vessel_frnotice.pdf. Accessed October 17, 2008. 

5 USC § 605(b). Regulatory Flexibility Act: Avoidance of Duplicative or Unnecessary Analyses. Accessed 

Available at http://www.archives.gov/federal-register/laws/regulatory-flexibility/605.html. Accessed February 

21, 2008. 

33 USC § 1251 et seq. Federal Water Pollution Control Act. Available at 

http://epa.gov/region5/water/pdf/ecwa.pdf. Accessed December 4, 2007. 

33 USC § 1901 et seq. Act to Prevent Pollution from Ships. Available at 

http://www.access.gpo.gov/uscode/title33/chapter33_.html. Accessed December 4, 2007. 

33 USC § 2401 et seq. Organotin Anti-fouling Paint Control Act. Available at 

http://www.access.gpo.gov/uscode/title33/chapter37_.html. Accessed December 4, 2007. 

42 USC § 9601 et seq. Comprehensive Environmental Response, Compensation and Liability Act. Available 

http://www.access.gpo.gov/uscode/title42/chapter103_.html. Accessed December 4, 2007. 

Abbaspour, M., A.H. Javid, P. Moghimi, and K. Kayhan. 2005. Modeling of Thermal Pollution in Coastal Area 

and its Economical and Environmental Assessment. International Journal of Environmental Science and 

Technology. 2(1): 13-26. 

Abt Associates Inc., 2005. Qualitative Benefits Assessment for Proposed Ballast Water Discharge Standards. 

Memo to U.S. Environmental Protection Agency. 

December 18, 2008 Final 126
Economic and Benefits Analysis of the Final Vessel General Permit 

Alaska Department of Environmental Conservation (ADEC). 2007. Large Commercial Passenger Vessel 

Wastewater Discharge: General Permit Information Sheet. Available at: 

http://www.dec.state.ak.us/water/cruise_ships/pdfs/GP%20Information%20Sheet.pdf. 

Aquatic Nuisance Species Task Force (ANSTF). 2007. ANS Impacts. Available at: 

http://www.anstaskforce.gov/impacts.php. Accessed December 27, 2007. 

Australian Maritime Safety Authority (AMSA). 2003. Effects of Oil on Wildlife. Available at: 

http://www.amsa.gov.au/Marine_Environment_Protection/Educational_resources_and_information/Teachers/

The_Effects_of_Oil_on_Wildlife.asp. 

Battelle. 2007. Technical Support for EPA Development of a Permitting Framework to Address the Vacatur of the 

NPDES Vessel Exclusion. Revised Draft, September 2007. 

Benson, A.J., D.C. Marelli, M. E. Frischer, J.M. Danforth, and J.D. Williams. 2002. Establishment of the green 

mussel, Perna viridis (Linnaeus 1758), (Mollusca: Mytilidae) on the west coast of Florida. Available at: 

http://cars.er.usgs.gov/posters/index.html. Accessed February 14, 2008. 

Boniface, D.E., LCDR. 2004. A Decision Analysis Framework for Evaluating Ballast Water Management 

Strategies. U.S. Coast Guard. 

Bourdeau, P. and M. Treshow. 1978. Ecosystem Response to Pollution. In Butler, G.C. (ed). Principles of 

Ecotoxicology. John Wiley & Sons, Chichester. Available at 

http://globalecology.stanford.edu/DGE/SCOPE/SCOPE%2012/SCOPE%2012.html. Accessed December 21, 

2007. 

Cairns, John Jr. 1972. Environmental Quality and the Thermal Pollution Problem. In Farvar, M.G. and J.P. 

Milton. (eds.) The Careless Technology: Ecology and International Development. The World Conservation 

Union. Garden City, NY: Natural History Press. Available at: 

http://www.iucn.org/themes/ceesp/Publications/SL/CT.htm. Accessed February 14, 2008. 

Cal. Pub. Res. Code. 71200-71271. Ballast Water Management for the Control of Nonindigenous Species. 

Available at: http://www.leginfo.ca.gov/cgi-bin/calawquery?codesection=prc&codebody=&hits=20. 

Accessed February 14, 2008. 

Cal. Pub. Res. Code. 72420-72425. California Clean Coast Act. Available at: http://www.leginfo.ca.gov/cgibin/calawquery?codesection=prc&codebody=&hits=20. Accessed February 14, 2008. 

Centers for Disease Control (CDC). 1993. Isolation of Vibrio Cholera 01 from Oysters – Mobile Bay, 1991, 1992.

Morbidity and Mortality Weekly Report, Feb. 12, 1993, Vol. 42(05); 91-93. 

Cipriano, R.C., and O. Miller. 2002. Infectious Salmon Anemia: The Current State of Our Knowledge, 

proceedings of the symposium ‘International Response to Infectious Salmon Anemia: Prevention, Control, 

and Eradication,’ USDA/USDI/USDC, New Orleans, September 3-4, 2002. 

Cohen, A.N., and J.T. Carlton, 1995. Nonindigenous Aquatic Species in a United States Estuary: A Case Study of 

the Biological Invasions of the San Francisco Bay and Delta, University of California at Berkeley, Williams 

College-Mystic Seaport. 

Cohen, Andrew N., J.T. Carlton, and M.C. Fountain. 1995. Introduction, dispersal and potential impacts of the 

green crab Carcinus maenas in San Francisco Bay, California. Marine Biology 122: 225-237. 

Cohen, Andrew N. 1997. Have Claw, Will Travel. Aquatic Nuisance Species Digest, Volume 2, No. 2, August 

1997. 

Cummins, Tim CDR. U.S. Coast Guard. Personal Communication. December 20, 2007. 

December 18, 2008 Final 127
Economic and Benefits Analysis of the Final Vessel General Permit 

Cruise Lines International Association (CLIA). “Cruise Industry Overview.” 2006. Accessed January 23, 2008. 

Available at http://www.cruising.org/press/overview%202006/ind_overview.cfm. 

Dawg, Inc. Personal Communication with a sales representative. January 14, 2008. 

DiGangi, J., T. Schettler, M. Cobbing, and M. Rossi. 2002. Aggregate Exposures to Phthalate in Humans. Health 

Care Without Harm. Available at: http://www.ecocenter.org/dust/Phthalate_hcwh.pdf. Accessed February 14, 

2008. 

Dun & Bradstreet. 2006. D&B’s Million Dollar Databases. Available at: http://mddi.dnb.com/mddi/. Accessed 

January 2006. 

Dun & Bradstreet. 2007. Industry Norms and Key Business Ratios. 

Eaton, J.G., J.H. McCormick, B.E. Goodno, D.G. O’Brien, H.G. Stefany, M. Hondzo, and R.M. Scheller. 1995. A 

field information-based system for estimating fish temperature tolerances. Fisheries 20:10-18. 

Enujiugha, V.N. and L.C. Nwanna. 2004. Aquatic Oil Pollution Impact Indicators. Journal of Applied Science and 

Environmental Management. 8(2): 71-75. 

Ewart, J.W., and S.E. Ford. 1993. History and Impact of MSX and Dermo diseases on Oyster Stocks in the 

Northeast Region. Northeast Regional Aquaculture Center: Fact Sheet No. 200. 

Footitt, A., T.A. Nwaogu, and D. Brooke. 2004. Risk Reduction Strategy and Analysis of Advantages and 

Drawbacks for Perfluorooctane Sulphonate (PFOS). Prepared for UK Department of Environment, Food and 

Rural Affairs and the Environment Agency for England and Wales by RPA and BRE Environment. 

Ghosh, Sujit. Personal Communication. 16 January 2008. 

Glassner-Shwayder, K. 1999. Great Lakes Nonindigenous Invasive Species. Briefing Paper presented at the Great 

Lakes Nonindigenous Invasive Species Workshop. Chicago, IL. October 20-21, 1999. 

Govorushko, S.M. 2007. Effect of Human Activity on Rivers. International Conference on River Basin 

Management. Organized by the General Directorate of State Hydraulic Works (DSI), Turkey. Available at: 

http://www.dsi.gov.tr/english/congress2007/. 

Griffiths, R.W., D.W. Schloesser, J.H. Leach, W.P. Kovalak. 1991. “Distribution and Dispersal of the Zebra 

Mussel in the Great Lakes Region.” Canadian Journal of Fishery and Aquatic Science. 48:1381. 

Grosholz, Edwin D. 2006. Personal Communication. Department of Environmental Science and Policy, 

University of California, Davis. 

Group of Experts on the Scientific Aspects of Marine Environmental Pollution (GESAMP). 2007. Estimates of 

Oil Entering the Marine Environment from Sea-Based Activities. International Maritime Organization. 

GESAMP No. 75. 

Gulf States Marine Fisheries Commission (GSMFC). 2003. Fact sheet for Perna perna. Available at: 

http://nis.gsmfc.org/nis_factsheet.php?toc_id=149. 

Hach Company. 2008. Available at: http://www.hach.com/. Accessed on October 29, 2008. 

Hushak, Leroy. 1996. “Zebra mussels cost Great Lakes water users an estimated $120 million.” ANS Update. 

Available at: http://www.glc.org/ans/ansupdate/pdf/ansv2n1.html. 

International Association of Drilling Contractors (IADC). 3 August 2007. Comments from Docket ID No. OW2007-0483 

December 18, 2008 Final 128
Economic and Benefits Analysis of the Final Vessel General Permit 

Indiana Department of Natural Resources (IDNR). 2003. Indiana Aquatic Nuisance Species (ANS) Management 

Plan. Phil Seng and Gwen White, Editors. Available at: 

http://www.in.gov/dnr/invasivespecies/inansmanagementplan.html. 

International Council of Cruise Lines (ICCL). 2001. Memorandum of Understanding. Available at: 

http://www.iccl.org/resources/fdep_mou.cfm. Accessed January 21, 2008. 

Jenkins, Phil. Personal Communication. 20 December 2007. 

Johengen, T., D. Reid, G. Fahnenstiel, H. MacIsaac, F. Dobbs, M. Doblin, G. Ruiz and P. Jenkins. 2005. 

Assessment of Transoceanic NOBOB Vessels and Low-Salinity Ballast Water as Vectors for Non-indigenous 

Species Introductions to the Great Lakes. NOAA Great Lakes Environmental Research Laboratory. 

John, D.A. and J.S. Leventhal. 1996. Bioavailability of Metals. In du Bray, E.A. (ed.) Preliminary Compilation of 

Geoenvironmental Mineral Deposit Models. United States Geological Survey. 

Khalanski M. 1997. Industrial and ecological consequences of the introduction of new species in continental 

aquatic ecosystems: the zebra mussel and other invasive species. Bulletin Francais de la Peche et de la 

Pisciculture 0 (344-345): 385-404. 

Knight, I.T., C.S. Wells, B. Wiggins, H. Russell, K.A. Reynolds, and A. Huq. 1999. Detection and Enumeration 

of Fecal Indicators and Pathogens in the Ballast Water of Transoceanic Cargo Vessels Entering the Great 

Lakes. Presented at the General Meeting of the American Society for Microbiology, Chicago, IL, 1999 

Abstract Q-71, p. 546. 

Larson, I., and M. Sytsma. 2006. Ballast Water Management on the Columbia River. Prepared for the Puget 

Sound Action Team, Office of the Governor, State of Washington. Available at: 

http://www.psat.wa.gov/Programs/ANS/ColumbiaRiverBWReportFinal.pdf. 

Leigh, Peter. 1998. Benefits and Costs of the Ruffe Control Program for the Great Lakes Fishery. Journal of 

Great Lakes Resources. 24(2): 351-360. 

Licking, Ellen. 1999. “They’re Here and They’re Taking Over.” Business Week, May 24, 1999. 

Lloyd’s Register. “Ballast Water Management Services, Definition of Acceptable Sea State.” 

Lovell, S.J., and L.A. Drake. 2007. Tiny Stowaways: What are the Potential Economic Consequences of Invasive 

Aquatic Microorganisms Transported by Ships? Unpublished. 

MacIsaac, H.J., C.J. Lonnee, and J.H . Leach. 1995. “Suppression of microzooplankton by zebra mussels: 

Importance of mussel size,” Freshwater Biology 34(2) 379-387. 

Maehara, E. 2004. Water Monitoring: Protecting the Aquatic Environment. Hawaii Legislative Reference Bureau. 

Available at: http://hawaii.gov/lrb/rpts04/watermon.pdf. Accessed February 14, 2008. 

Marsden, J.E. and D.J. Jude. 1995. Round gobies invade North America. Great Lakes Sea Grant Network. 

McKee, Scott. President/CEO of Laboratory Management Partners, Inc. Personal Communication. 21 October 

2008. 

McKnight, J.A. 2007. Invasive Species of Concern in Maryland: MSX. Maryland Department of Natural 

Resources. Available at: http://www.mdinvasivesp.org/archived_invaders/archived_invaders_2007_03.html 

Me. Rev. Stat. Ann. tit. 38, 423D. Graywater and Blackwater Discharges from Commercial Vessels. Available at: 

http://janus.state.me.us/legis/statutes/38/title38sec423-D.html. Accessed February 14, 2008. 

December 18, 2008 Final 129
Economic and Benefits Analysis of the Final Vessel General Permit 

Michigan Department of Environmental Quality. 2006. Ballast Water Control General Permit. Available at: 

http://www.deq.state.mi.us/documents/deq-water-npdes-generalpermit-MIG140000.pdf. Accessed December 

4, 2007. 

Munn, M.D., and P.A. Hamilton. 2003. “New Studies Initiated by US Geological Survey: Effects of Nutrient 

Enrichment on Stream Ecosystems.” U.S. Geological Survey Fact Sheet 118-03. Available at: 

http://pubs.usgs.gov/fs/fs11803/pdf/fs-118-03.pdf. Accessed December 31, 2007. 

National Ballast Information Clearinghouse (NBIC). 2005. NBIC database. 

National Marine Fisheries Service (NMFS). 2007. Fisheries of the United States, 2006. Silver Spring, MD: 

National Oceanic and Atmospheric Administration. 

National Marine Manufacturers Association (NMMA). 2005. 2005 U.S. Recreational Boat Registration Statistics. 

National Marine Manufacturers Association. 

National Oceanic and Atmospheric Administration. September 2003. Accessed January 22, 2008. Available at 

http://www.st.nmfs.noaa.gov/st1/fus/current/2002-fus.pdf. 

National Oceanic and Atmospheric Administration (NOAA). 2004a. Snowflakes Unwelcome in the Tropics! 

Scientists Fight to Eradicate Invasive Coral. Coral Reef News. 1(4). 

National Oceanic and Atmospheric Administration (NOAA). 2004b. International Year of the Ocean Fact Sheets: 

Coastal Tourism. U.S. Department of Commerce. National Oceanic and Atmospheric Administration. 

National Oceanic and Atmospheric Administration (NOAA). 2005. Assessing Environmental Harm: How Toxic 

is Oil? Available at: 

http://response.restoration.noaa.gov/topic_subtopic_entry.php?RECORD_KEY%28entry_subtopic_topic%29

=entry_id,subtopic_id,topic_id&entry_id(entry_subtopic_topic)=243&subtopic_id(entry_subtopic_topic)=13

&topic_id(entry_subtopic_topic)=1. Accessed December 31, 2007. 

National Oceanic and Atmospheric Administration (NOAA). 2007. Aquatic Invasive Species Research Program. 

Great Lakes Environmental Research Laboratory. Available at: http://www.glerl.noaa.gov/res/Programs/ais/. 

Accessed December 27, 2007. 

National Research Council. 1993. Managing Wastewater in Coastal Urban Areas. Water Science and Technology 

Board. 

National Research Council. 2000. Clean Coastal Waters: Understanding and Reducing the Effects of Nutrient 

Pollution. Ocean Studies Board and Water Science and Technology Board. 

Natural Resources Defense Council (NRDC). 2005. Contamination Forces More Beach Closings Nationwide. 

Press Release. Available at: http://www.nrdc.org/media/pressreleases/050728.asp. 

Office of Technology Assessment (OTA) (U.S. Congress). 1993. Harmful Non-Indigenous Species in the United 

States. OTA Publication OTA-F-565. U.S. Government Printing Office, Washington DC. 

O’Neill, Jr., C.R., 1997. Economic Impact of Zebra Mussels – Results of the 1995 National Zebra Mussel 

Information Clearinghouse Study, New York Sea Grant Institute. 

Or. Admin. R. 340-143-0010. Ballast Water Management. Available at 

http://arcweb.sos.state.or.us/rules/OARs_300/OAR_340/340_143.html. Accessed February 14, 2008. 

Park, J. and L.J. Hushak. 1998. Zebra Mussel Control Costs in Surface Water Using Facilities, Technical 

Summary OHSU-TS-028. Ohio Sea Grant College Program, Ohio State University. 

Peters, David. Personal Communication. January 14, 2008. 

December 18, 2008 Final 130
Economic and Benefits Analysis of the Final Vessel General Permit 

Pimentel, D., L. Lach, R. Zuniga, and D. Morrison. 1999. Environmental and Economic Costs Associated with 

Non-indigenous Species in the United States. The College of Agriculture and Life Sciences, Cornell 

University, Ithaca, NY. 

Pimentel, D., L. Lach, R. Zuniga, and D. Morrison. 2000. “Environmental and Economic Costs of Nonindigenous 

Species in the United States.” Bioscience, 50(1): 53-56. 

Pimentel, D., R. Zuniga, and D. Morrison. 2005. Update on the environmental and economic costs associated with 

alien-invasive species in the United States. Ecological Economics. 52: 273-288. 

Rahel, F.J., C.J. Keleher and J.L. Anderson. 1996. Potential habitat loss and population fragmentation for cols 

water fish in the North Platte River drainage of the Rocky Mountains: response to climate warming. Limnol. 

Oceanogr. 41:1116-1123. 

Randall, Alan. 2001. “Dealing with the Analytical Challenges of Valuation: Aquatic Nuisance Species Control.” 

In Revealing the Economic Value of Protecting the Great Lakes. The Northeast-Midwest Institute and The 

National Oceanic and Atmospheric Administration. 

Reference for Business. 2007a. “SIC 0912-Finfish.” Encyclopedia of American Industries. Accessed January 24, 

2008. Available at http://www.referenceforbusiness.com/industries/Agriculture-Forestry-Fishing/Finfish.html. 

Reference for Business. 2007b. “SIC 0913-Shellfish.” Encyclopedia of American Industries. Accessed January 

24, 2008. Available at http://www.referenceforbusiness.com/industries/Agriculture-ForestryFishing/Shellfish.html. 

Reference for Business. 2007c. “SIC 4482-Ferries.” Encyclopedia of American Industries. Accessed January 23, 

2008. Available at http://www.referenceforbusiness.com/industries/Transportation-CommunicationsUtilities/Ferries.html. 

Reference for Business. 2007d. “SIC 4489-Water Transportation of Passengers, not Elsewhere Classified.” 

Encyclopedia of American Industries. Accessed January 23, 2008. Available at 

http://www.referenceforbusiness.com/industries/Transportation-Communications-Utilities/WaterTransportation-Passengers-Elsewhere-Classified.html 

Reference for Business. 2007e. “SIC 4491-Marine Cargo Handling.” Encyclopedia of American Industries. 

Accessed January 23, 2008. Available at http://www.referenceforbusiness.com/industries/TransportationCommunications-Utilities/Marine-Cargo-Handling.html. 

Reference for Business. 2007f. “SIC 4499-Water Transportation Services, not Elsewhere Classified.” 

Encyclopedia of American Industries. Accessed January 23, 2008. Available at 

http://www.referenceforbusiness.com/industries/Transportation-Communications-Utilities/WaterTransportation-Services-Elsewhere-Classified.html. 

ReferenceUSA. 2006. Business Database. Available at: www.referenceusa.com. Accessed Jan./Feb. 2006. 

Reid, D.F., T.H. Johengen, H. MacIsaac, F. Dobbs, M. Doblin, L. Drake, G. Ruiz and P. Jenkins. 2007. 

Identifying and Establishing Options for Best Management Practices for NOBOB Vessels. NOAA Great 

Lakes Environmental Research Laboratory. 

Reynolds, K.A., I.T. Knight, C.S. Wells, I.L. Pepper, and C.P. Gerba. 1999. Detection of Human Pathogenic 

Protozoa and Viruses in Ballast Water Using Conventional and Molecular Methods. Presented at the General 

Meeting of the American Society for Microbiology, Chicago, IL, Abstract Q-318, p. 594. 

Risk Management Association (RMA) eStatement Studies: Annual Statement Studies, Financial Ratios and 

Benchmarks. 2007. 

December 18, 2008 Final 131
Economic and Benefits Analysis of the Final Vessel General Permit 

Rockwell, Jr., H.W. 2003. “Summary of a Survey of the Literature on the Economic Impact of Aquatic Weeds.” 

Report for the Aquatic Ecosystem Restoration Foundation. August. 

http://www.aquatics.org/pubs/economics.htm. 

Ruffe Task Force (RTF). 1992. Ruffe in the Great Lakes: A Threat to North American Fisheries. Great Lakes 

Fishery Commission. Ann Arbor, MI. 

Ruiz, G.M., A.W. Miller, K. Lion, B. Steves, A. Arnwine, E. Collinetti, and E. Wells. 2001. First Biennial Report 

of the National Ballast Information Clearinghouse. Smithsonian Environmental Research Center. Edgewater, 

Maryland. 

Ruiz, G.M., and D.F. Reid. 2007. Current State of Understanding about the Effectiveness of Ballast Water 

Exchange (BWE) in Reducing Aquatic Nonindigenous Species (ANS) Introductions to the Great Lakes Basin 

and Chesapeake Bay, USA: Synthesis and Analysis of Existing Information. National Oceanic and 

Atmospheric Administration. 

St. Lawrence Seaway Management Corporation and St. Lawrence Seaway Development Corporation. 2007. The 

St. Lawrence Seaway 2006 Traffic Report. Available at http://www.greatlakesseaway.com/en/pdf/traffic_report_2006.pdf. Accessed December 17, 2007. 

Seacor International. Personal Communication. January 7, 2008. 

Scheffey, J.L., and C.P. Hanauska. 2002. Status Report on Environmental Concerns Relating to Aqueous Film 

Forming Foam (AFFF). Report to the Federal Aviation Administration Technology Transfer Conference. 

Available at: http://www.airporttech.tc.faa.gov/naptf/att07/2002%20TRACK%20S.pdf/S15.pdf. 

Sekizawa, J., S. Dobson, and R.J. Touch III. 2003. Diethyl Phthalate. World Health Organization, Concise 

International Chemical Assessment Document 52. 

Steinberg, E.B., et al. 2001. Cholera in the United States, 1995-2000: Trends at the End of the Twentieth Century. 

Journal of Infectious Diseases, 2001, Vol. 184, pp.799-802. 

Sytsma, M.D., J.R. Cordell, J.W. Chapman, and R.C. Draheim. 2004. Lower Columbia River Aquatic 

Nonindigenous Species Survey 2001-2004: Final Technical Report. Prepared for the U.S. Coast Guard and 

U.S. Fish and Wildlife Service. Available at: http://www.clr.pdx.edu/docs/LCRANSFinalReport.pdf. 

Accessed December 31, 2007. 

Toledo, D.P. 2001. Sea Lamprey (Petromyzon marinus). Introduced Species Summary Project, Columbia 

University. Available at: http://www.columbia.edu/itc/cerc/danoffburg/invasion_bio/inv_spp_summ/petromyzon_marinus.html. 

Toonen, R. 2005. Reproduction and developmental characteristics of an alien soft coral (Carijoa riisei) in Hawaii. 

Available at: http://www.hawaii.edu/ssri/hcri/research/projects/threats/inv_spec-invert-bio-01.shtml. 

Transportation Institute. “Industry Profile.” Accessed January 23, 2008. Available at http://www.transinst.org/1.html. 

United States Army Corps of Engineers (USACE). 2001. Waterborne Transportation Lines of the United States. 

Volume 3: Vessel Characteristics. United States Army Corps of Engineers, Institute for Water Resources. 

Alexandria, Virginia. 

United States Army Corps of Engineers (USACE). 2002. Zebra Mussel Information System. Available at: 

http://el.erdc.usace.army.mil/zebra/zmis/. Accessed February 14, 2008. 

U.S. Army Corps of Engineers (USACE). 2005a. Waterborne Commerce of the United States, 2005. Institute for 

Water Resources. 2005. Available at http://www.iwr.usace.army.mil/ndc/wcsc/pdf/wcusnatl05.pdf. 

December 18, 2008 Final 132
Economic and Benefits Analysis of the Final Vessel General Permit 

U.S. Army Corps of Engineers (USACE). 2005b. Waterborne Transportation Lines of the United States. Volume 

1: National Summaries. United States Army Corps of Engineers, Institute for Water Resources. Alexandria, 

Virginia. 

U.S. Army Corps of Engineers (USACE). 2005c. Waterborne Transportation Lines of the United States. Volume 

2: Vessel Company Summary. United States Army Corps of Engineers, Institute for Water Resources. 

Alexandria, Virginia. 

U.S. Army Corps of Engineers (USACE). 2005d. Waterborne Transportation Lines of the United States. Volume 

3: Vessel Characteristics. United States Army Corps of Engineers, Institute for Water Resources. Alexandria, 

Virginia. 

U.S. Army Corps of Engineers (USACE), Navigation Data Center (NDC), 2007. Available at: 

http://www.iwr.usace.army.mil/ndc/data/datavess.htm. Accessed 12/5/07. 

U.S. Army Corps of Engineers (USACE), Navigation Data Center (NDC), 2008. Available at: 

http://www.iwr.usace.army.mil/ndc/veslchar/veslchar.htm. Accessed 1/18/08. 

U.S. Bureau of Economic Analysis. 2007. “Current-dollar and ‘real’ GDP.” National Economic Accounts. 

Updated December 20, 2007. Available at http://www.bea.gov/national/index.htm. 

U.S. Census Bureau. 1997. 1997 Economic Census. Available at 

http://www.census.gov/epcd/ec97/us/US000.HTM . 

U.S. Census Bureau. 1998. 1998 County Business Patterns for the United States. Available at 

http://www.census.gov/epcd/cbp/view/us98.txt. 

U.S. Census Bureau. 2002a. 2002 County Business Patterns for the United States. Available at 

http://www.census.gov/epcd/cbp/view/us02.txt. 

U.S. Census Bureau. 2002b. 2002 Economic Census. Available at http://www.census.gov/econ/census02/. 

U.S. Census Bureau. 2005. 2002 Economic Census: Transportation and Warehousing. Various Reports. Available 

online at: http://www.census.gov/econ/census02/guide/INDRPT23.HTM. 

U.S. Coast Guard (USCG), 2004a. Regulatory Evaluation for the Final Rule: Mandatory Ballast Water 

Management Program for U.S. Waters. U.S. Coast Guard, Standards Evaluation and Analysis Division. 

U.S. Coast Guard (USCG). 2004b. Programmatic Environmental Assessment for Mandatory Ballast Water 

Management Program for U.S. Waters. Prepared by Battelle for U.S. Coast Guard. 

U.S. Coast Guard (USCG), 2005. Environmental Assessment for Voluntary Best Management Practices for 

Vessels Declaring No Ballast Onboard That Enter the Great Lakes. 

U.S. Coast Guard (USCG). 2007a. Merchant Vessels of the United States (VESDOC). National Vessel 

Documentation Center. Revised May 5, 2007. Available at: 

http://www.bts.gov/programs/maritime_data_working_group/uscg/merchant_vessels_of_the_united_states/in

dex.html. Accessed December 4, 2007. 

U.S. Coast Guard (USCG). 2007b. Marine Casualty and Pollution Database (MPCD). Marine Safety Information 

and Law Enforcement System. United States Coast Guard. Available at: 

http://transtats.bts.gov/Tables.asp?DB_ID=610&DB_Name=Marine%20Casualty%20And%20Pollution%20

Database&DB_Short_Name=Marine%20Casualty/Pollution. Accessed December 4, 2007. 

U.S. Coast Guard (USCG). 2007c. National Vessel Movement Center (NVMC). Available at: 

http://www.nvmc.uscg.gov/download.aspx. 

December 18, 2008 Final 133
Economic and Benefits Analysis of the Final Vessel General Permit 

U.S. Coast Guard (USCG). 2008. Shipboard Technology Evaluation Program (STEP). Available at: 

http://www.uscg.mil/hq/cg5/cg522/cg5224/step.asp. Accessed October 24, 2008. 

U.S. Customs and Border Protection. 2007. 2005 U.S. Customs Vessels Entrances and Clearances. USACE, 

Navigation Data Center. Available at: http://www.ndc.iwr.usace.army.mil/data/dataclen.htm. Accessed 

December 4, 2007. 

U.S. Department of Agriculture (USDA). 2006. Viral Hemorrhagic Septicemia in the Great Lakes Region. 

Industry Alert, October 2006. 

U.S. Department of the Interior, Fish and Wildlife Service and U.S. Department of Commerce, U.S. Census 

Bureau (USDOI). 2007. 2006 National Survey of Fishing, Hunting, and Wildlife-Associated Recreation. 

U.S. Department of Transportation, Research and Innovative Technology Administration, Bureau of 

Transportation Statistics. 2008. Maritime Data Working Group, Merchant Vessels of the United States. 

Available at: 

http://www.bts.gov/programs/maritime_data_working_group/uscg/merchant_vessels_of_the_united_states/ht

ml/front_matter.html. Accessed January 18, 2008. 

U.S. Environmental Protection Agency and U.S. Department of Defense (EPA and DOD). 1999. Phase I Uniform 

National Discharge Standards for Vessels of the Armed Forces: Technical Development Document. Available 

at: http://www.epa.gov/waterscience/rules/UNDS/vessels.pdf. 

U.S. Environmental Protection Agency and United States Department of Defense (EPA and DOD). 2007. 

Uniform National Discharge Standards Batch Rulemaking Process. Available at: 

http://www.epa.gov/owow/oceans/regulatory/unds/batchruleprocess.html. Accessed December 20, 2007. 

U.S. Environmental Protection Agency (EPA). 1999. Revised Interim Guidance for EPA Rulewriters: Regulatory 

Flexibility Act as amended by the Small Business Regulatory Enforcement Fairness Act. 29 March 1999. 

U.S. Environmental Protection Agency (EPA). 2006. Information Collection Request: Applications for National 

Pollutant Discharge Elimination System Discharge Permits and the Sewage Sludge Management Permits. 

June 2006. 

U.S. Environmental Protection Agency (EPA). 2006a. Multi-Sector General Permit. September 2006. Document 

ID EPA-HQ-OW-2005-0007-0011. Available at : http://www.regulations.gov/search/index.jsp. Accessed on 

October 29, 2008.U.S. Environmental Protection Agency (EPA). 2007a. Draft Cruise Ship Discharge 

Assessment Report. Available at: http://www.epa.gov/owow/oceans/cruise_ships/disch_assess_draft.html. 

Accessed December 21, 2007. 

U.S. Environmental Protection Agency (EPA). 2007b. Framework for Metals Risk Assessment. Available at: 

http://www.epa.gov/osa/metalsframework/. Accessed December 21, 2007. 

U.S. Environmental Protection Agency (EPA). 2007c. National Water Quality Inventory: Report to Congress, 

2002 Reporting Cycle. Available at: http://www.epa.gov/305b/. Accessed December 21, 2007. 

U.S. Environmental Protection Agency (EPA). 2007d. Basic Information on PFOA. Available at: 

http://www.epa.gov/oppt/pfoa/pubs/pfoainfo.htm. 

U.S. Environmental Protection Agency (EPA). 2007e. Effects of Acid Rain – Surface Waters and Aquatic 

Animals. Available at: http://www.epa.gov/acidrain/effects/surface_water.html. 

U.S. Environmental Protection Agency (EPA). 2008a. Ecological and Economic Impacts, and Invasion 

Management Strategies for the European Green Crab. Draft Report prepared for U.S. EPA’s National Center 

for Environmental Economics. Washington DC. March 14, 2008. 

December 18, 2008 Final 134
Economic and Benefits Analysis of the Final Vessel General Permit 

U.S. Environmental Protection Agency (EPA). 2008b. Vessel General Permit for Discharges Incidental to the 

Normal Operation of Non-Recreational Vessels (VGP). Draft, March 19, 2008. U.S. Environmental 

Protection Agency. 

U.S. Environmental Protection Agency, Science Advisory Board (SAB). 2006. SAB Review of EPA’s Draft Risk 

Assessment of Potential Human Health Effects Associated with PFOA and Its Salts. Available at: 

http://yosemite.epa.gov/sab/SABPRODUCT.NSF/A3C83648E77252828525717F004B9099/$File/sab_06_00

6.pdf. 

U.S. Fish and Wildlife Service (USFWS). 2005. Federal and State Endangered and Threatened Species 

Expenditures: Fiscal Year 2004. 

U.S. Geological Survey (USGS). 1999. The Quality of Our Nation’s Waters: Nutrients and Pesticides. USGS 

Circular 1225. Available at: http://pubs.usgs.gov/circ/circ1225/. Accessed December 21, 2007. 

U.S. Maritime Administration (MARAD). 2006. U.S. Domestic Ocean Trades 2004. Available at 

http://www.marad.dot.gov/marad_statistics. Accessed December 17, 2007. 

U.S. Small Business Administration. 1997. U.S. all industries data by receipt size, 1997. Firm Size Data. 

Available at http://www.sba.gov/advo/research/us_rec97.txt. 

U.S. Small Business Administration. 2002a. U.S. data, Classified by Employment size of firm-All Industries, 

1998-2002. Firm Size Data. Available at http://www.sba.gov/advo/research/us98_02n97.txt. 

U.S. Small Business Administration. 2002b. U.S. all industries data by receipt size, 2002. Firm Size Data.

Available at http://www.sba.gov/advo/research/us_rec02.txt. 

U.S. Small Business Administration. 2004. U.S. Dynamic data, by births, deaths, growth, and decline, 1998-2004. 

Firm Size Data. Available at http://www.sba.gov/advo/research/dyn_us_98_04n4.txt. 

U.S. Small Business Administration (SBA). 2006. Table of Small Business Size Standards Matched to the North 

American Industry Classification System (NAICS 2002), Effective July 1, 2007. Available online at: 

http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf. 

U.S. Small Business Administration. Firm Size Data. Available at http://www.sba.gov/advo/research/data.html. 

Van Driesche, R., et al., 2002, Biological Control of Invasive Plants in the Eastern United States, USDA Forest 

Service Publication FHTET-2002-04, p. 413. Available at: http://www.invasive.org/eastern/biocontrol/. 

Accessed February 14, 2008. 

Vilaplana, Jorge V., and Leroy J. Hushak. 1994. “Recreation and the Zebra Mussel in Lake Erie, Ohio.” Technical 

Summary. Ohio Sea Grant College Program, The Ohio State University. 

Wash. Admin. Code 77-120-030. Authorized Ballast Water Discharge – Adoption of Standards by Rule. 

Available at: http://apps.leg.wa.gov/RCW/default.aspx?cite=77.120.030. Accessed February 14, 2008. 

Washington Department of Ecology, 2007. Amendment Number 3 of the Memorandum of Understanding: Cruise 

Ship Operations in Washington State. Available at: 

http://www.ecy.wa.gov/programs/wq/wastewater/cruise_mou/MOU%203rd%20Amendment%205-25-

07%20final.pdf. Accessed February 14, 2008. 

Woods Hole Oceanographic Institute (WHOI). 2007. Harmful Algae: What are Harmful Algal Blooms (HABs)? 

Available at http://www.whoi.edu/redtide/page.do?pid=9257. 

Wurts, W.A. and R.M. Durborrow. 1992. Interactions of pH, Carbon Dioxide, Alkalinity and Hardness in Fish 

Ponds. Southern Regional Aquaculture Center Publication No. 464. 

December 18, 2008 Final 135
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 136

Zo, Y., C. Grimm, M. Matte, G. Matte, I.T. Knight, A. Huq, and R.R. Colwell. 1999. Detection and Enumeration 

of Pathogenic Bacteria in Ballast Water of Transoceanic Vessels Entering the Great Lakes and Resistance to 

Common Antibiotics. General Meeting of the American Society for Microbiology, Chicago, IL, 1999, 

Abstract Q317. 
Economic and Benefits Analysis of the Final Vessel General Permit 

Appendix A: Survey Questionnaires 

Individual BMP Survey 

Why Does EPA need this information? 

The Agency is evaluating the impacts of instituting a General Permit for practices associated with discharges 

incidental to normal operation of cruise ships as part of developing a permitting framework for commercial 

vessels. The Agency will use your responses to estimate any incremental costs that would result from 

implementing best management practices required under this Permit. The discharges that are applicable, unless 

noted otherwise, are those that take place within U.S. waters, i.e. within 12 nm. 

Survey Instructions: 

Please fill out all pieces of information that are relevant and obtainable. Include any comments if any of the 

requested information is not available and/or not relevant. If you are unable to estimate the cost for a piece of 

information in the manner requested but are able to estimate the cost in a separate manner, please do so and mark 

accordingly. 

If any of these discharge categories do not apply to your vessel types, please mark “N/A” within the specific 

section and list which vessel types to which the discharge category does not apply. If a straightforward response 

is not possible, please explain the variances in responses as best as possible. 

Primary contact person: 

Last Name ___________________ First Name ____________________ Title _______ 

Company _____________________________________ 

Telephone Number _______________________________ 

Email _______________________________ 

Date _______________________________ 

December 18, 2008 Final 137
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 138

1. Please provide a general, average labor rate that would be applicable to practices associated with the 9 

discharge categories listed above ________$ per hour.39

2. Please list the total number of vessels that your company has within each vessel category and, if possible, 

how many vessels sail outside of the territorial sea (outside 12 nm) more than once per month (herein 

referred to as “ocean going vessels”) and how many vessels do not sail outside of the territorial sea 

(outside 12 nm) more than once per month (herein referred to as “non-ocean going vessels”). 

Vessel 

ID Vessel Category 

Total Number 

of Vessels 

Ocean Going 

Vessels 

Non-Ocean Going 

Vessels 

Example Example Vessel Category 10 7 3 

1 

General Cargo Freighter (Includes (a) 

freight ships, and (b) public freight ships 

2 Break Bulk/RO-RO Carrier 

3 RO-RO Vessel 

4 Bulk Carrier 

5 Containership 

6 Partial Containership 

7 Container/Vehicle/Trailer (RO-RO) 

8 Vehicle Carrier 

9 Passenger Vessel40 

10 Commercial Fishing 

11 Petroleum/Chemical Carrier 

12 Chemical Carrier 

13 Liquid Bulk Tanker 

14 Other Tanker 

15 Push Boat 

16 Tugboat/Towing Vessel 

17 Open Hopper Barge 

18 Covered Hopper Barge 

19 Car Float (Railroad Car Barge) 

20 Flat/Deck Barge 

21 Pontoon Barge 

22 Open Dry Cargo Barge 

23 Covered Dry Cargo Barge 

24 RO-RO Barge 

25 Container Barge 

26 Lash/Seabee Barge 

27 Liquid Cargo Barge 

28 

Other Liquid Cargo Barge, Not Elsewhere 

Included (Includes tank barge) 

29 Convertible Barge 

30 Passenger Barge 

31 Other Dry Cargo Barge (Includes freight 

 

(Proceed to the relevant sections.) 

 

39 The average labor cost includes the base rate, fringe benefits such as vacation, sick leave, insurance, and allowance for overhead and 

other agency indirect burden. 

40 Includes excursion/sightseeing vessels, ferries, and combined passenger and cargo vessels. 
Economic and Benefits Analysis of the Final Vessel General Permit 

1) DECK RUNOFF 

1. Indicate how many times per month a vessel performs deck cleanup (i.e. removing debris, garbage, and 

other loose materials) prior to conducting deck washdowns or prior to departing from port: ___times 

per month 

a. Estimate the cost involved with performing deck cleanup prior to conducting deck washdowns 

or prior to departing from port: 

à Labor Hours typically required to perform deck cleanup: _______ hours 

 OR 

à Total Cost: $____ per cleanup. 

 OR 

à Check this box if this cost is negligible 

b. Indicate how many deck washdowns a vessel performs per month: _____times per month 

c. Indicate how many times a vessel departs from port per month: _____times per month 

Question d. is specific to Commercial Fishing vessels: 

d. How often do you perform deck cleanup after moving fish to the fish hold? 

 Always_____ Most of the time _____ Sometimes _______ Rarely ______ Never ______ 

2. Indicate the percentage of vessels that have coamings or drip pans to collect any oily water from 

machinery and to prevent spills for all machinery on deck: ______________% of vessels 

e. Estimate a cost of installing these coamings or drip pans for every piece of machinery on deck: 

à Total Cost: $____ per installation. 

f. Estimate how many times per year you need to install these coamings or drip pans for every 

piece of machinery on deck: _______ times per year 

3. Estimate the number of times a vessel’s drip pans/coamings become full, per month: ___times per month 

When drip pans become full from runoff, estimate how often a vessel drains or wipes and cleans the 

drip pans: Always_____ Most of the time _____ Sometimes _______ Rarely ______ Never ______ 

g. Estimate the cost involved with performing this task: 

à Labor Hours typically required to drain/wipe and clean drip pans: _______ hours 

à Additional Cost and Fees: $____ per instance of draining/wiping and cleaning drip pans. 

 OR 

à Total Cost: $____ per instance of draining/wiping and cleaning drip pans. 

 OR 

à Check this box if this cost is negligible 

4. Indicate the percentage of vessels that use non-toxic or other environmentally preferable cleaners (i.e. low 

or no phosphorus content or biodegradable) for the washdown: __________% of vessels 

December 18, 2008 Final 139
Economic and Benefits Analysis of the Final Vessel General Permit 

h. Estimate how many gallons of cleaner are used per month: 

_______per vessel, gallons per month OR ______per company, gallons per month 

2) AQUEOUS FILM FORMING FOAM (AFFF) 

OCEAN GOING VESSELS

5. Indicate the number of times per year a vessel discharges AFFF for maintenance and/or training 

purposes:...for certification purposes: 

(Maintenance/Training)____________times per year 

(Certification)____________________times per year 

 

6. Indicate the percentage of your vessels that use a non-fluorinated foaming agent:_________% of vessels 

i. Estimate the number of gallons of foam a vessel purchases a year: ______ gallons of foam 

purchased per year 

NON-OCEAN GOING VESSELS

7. Indicate the number of times per year a vessel discharges AFFF for maintenance and/or training purposes: 

_________ times per year 

8. Indicate how often a vessel collects and stores this discharge of AFFF for onshore disposal: 

 Always_____ Most of the time _____ Sometimes _______ Rarely ______ Never ______ 

j. Estimate the cost involved with collecting and storing the AFFF discharge for onshore disposal: 

à Labor Hours typically required to collect and store AFFF for onshore disposal: _______ 

hours 

à Additional Cost and Fees: $____ per instance of collecting and storing AFFF for 

onshore disposal.

 OR 

à Total Cost: $____ per instance of collecting and storing AFFF for onshore disposal.

 OR 

à Check this box if this cost is negligible 

9. Indicate the percentage of your vessels use a non-fluorinated foaming agent: ______% of vessels 

k. Estimate the number of gallons of foam a vessel purchases a year: _________ gallons of foam 

purchased per year 

ALL VESSELS

10. Unless 1) for emergency purposes, 2) for discharge by rescue vessels (such as fireboats for firefighting 

purposes), or 3) for vessels owned or under contract to do business exclusively in or within 1 nm of those 

protected areas by the US government or state or local governments, estimate how many of your vessels 

discharge AFFF in or within 1 nm of waters of exceptional value: ___________ vessels

December 18, 2008 Final 140
Economic and Benefits Analysis of the Final Vessel General Permit 

l. Indicate the number of times per year AFFF discharges occur within those waters for emergency 

purposes: ____ times per year. 

i. Indicate how often, on average, a vessel documents the discharge: 

 Always_____ Most of the time _____ Sometimes _______ Rarely ______ Never ______ 

ii. Estimate the typical cost of documenting this discharge: 

1. Labor Hours typically required to document this discharge: _______ hours 

 OR 

2. Total Cost: $____ per instance of documenting this discharge.

m. Not including the above mentioned exceptions, indicate the number of times per year a vessel 

operating within 1 nm of water of exceptional value performs this discharge: ___ times per year 

3) GRAYWATER 

OCEAN GOING VESSELS

11. Indicate what percentage of your ocean going vessels are able to store graywater in order to reach a 

distance greater than 1 nm to discharge: ____________% of vessels 

a. For those vessels that are underway and are able to store graywater by these specifications, 

estimate how often a vessel discharges graywater greater than 1 nm from shore: 

Always_____ Most of the time _____ Sometimes _______ Rarely ______ Never _______ 

n. Estimate the cost involved (for those ocean going vessels able to store graywater) with needing to 

discharge graywater greater than 1 nm from shore: 

à Labor Hours typically required to discharge greater than 1 nm from shore: _______ 

hours 

 OR 

à Check this box if this cost is negligible 

o. Indicate how often a vessel (for those ocean going vessels able to store graywater) that is 

underway needs to discharge graywater:___times per month. 

NON-OCEAN GOING VESSELS 

12. Estimate how many times per month a vessel needs to dispose of graywater:_________ times per month 

p. Estimate how many times per year, on average, a vessel disposes of graywater on shore at the 

appropriate facilities: ______________________ times per year 

a. Estimate the cost involved with disposing of graywater on shore: 

à Labor Hours typically required to dispose of graywater on shore: _______ hours 

à Additional Cost and Fees: $____ per instance of disposing graywater onshore.

 OR 

à Total Cost: $____ per instance of disposing graywater onshore.

q. Estimate the number of times per year appropriate facilities are not available and the vessel needs 

to dispose of graywater: ____________ times per year 

December 18, 2008 Final 141
Economic and Benefits Analysis of the Final Vessel General Permit 

13. If appropriate facilities are not available, estimate how often a vessel discharges graywater into waters 

with an ability to dilute concentrations of detergents, soaps, and pathogens:... discharges graywater while 

the vessel is underway: 

(Certain Waters) Always____ Most of the time _____ Sometimes _____ Rarely _____ Never _____ 

(Underway) Always____ Most of the time _____ Sometimes _______ Rarely ______ Never ______ 

a. Estimate the additional cost of needing to discharge graywater into waters with an ability to dilute 

concentrations of detergents, soaps, and pathogens:...of needing to discharge graywater while the 

vessel is underway: 

Certain Waters 

à Total Cost: $____ per instance of discharging graywater into waters with an ability 

to dilute concentrations of detergents, soaps, and pathogens.

 OR 

à Check this box if this cost is negligible 

Vessel Underway 

à Total Cost: $____ per instance of discharging graywater while the vessel is underway.

 OR 

à Check this box if this cost is negligible 

ALL VESSELS

14. Estimate the percentage of your vessels that are able to store graywater: ___________ % of vessels 

a. For those vessels able to store graywater, while a vessel is underway, how often does a vessel 

avoid discharging graywater in “waters of exceptional value”: 

 Always_____ Most of the time _____ Sometimes ______ Rarely ______ Never ______ 

15. Estimate the percentage of vessels that use non-toxic soaps:...non-toxic detergents: 

(Soaps)_______________________________ % of vessels 

(Detergents)___________________________ % of vessels 

a. Estimate the number of gallons of soap/detergent used per year, per vessel: 

(Soaps)____________________________ gallons per year 

(Detergents)________________________ gallons per year 

4) UNDERWATER SHIP HUSBANDRY 

16. Indicate the number of times per year a vessel cleans the hull underwater: ___________ times per year 

a. Estimate how often a vessel cleans the hull by methods that minimize the discharge of fouling 

organisms and antifouling hull coatings: 

 Always_____ Most of the time _____ Sometimes _______ Rarely ______ Never ______ 

December 18, 2008 Final 142
Economic and Benefits Analysis of the Final Vessel General Permit 

b. Estimate the cost involved with cleaning the hull: 

à Labor Hours typically required to clean the hull: _______ hours 

à Additional Cost and Fees: $____ per instance of cleaning the hull.

 OR 

à Total Cost: $____ per instance of cleaning the hull.

17. Estimate how often a vessel disposes of removed substances in accordance with local, State, and Federal 

regulations: Always____ Most of the time ___ Sometimes _____ Rarely ____ Never ______ 

a. Estimate the cost involved, if any, with disposal of any removed substances from the hull: 

à Labor Hours typically required to dispose of removed substances: _______ hours 

à Additional Cost and Fees: $____ per instance of disposing of the removed substances.

 OR 

à Total Cost: $____ per instance of disposing of removed substances.

 OR 

à Check this box if this cost is negligible 

18. When performing mechanical underwater scrubbing, indicate the percentage of vessels that use vacuum 

control technologies to remove the addition of biocide paints and detached living organisms from the 

waters: _____________ % of vessels 

a. Estimate the cost of purchasing vacuum control technologies: $______________ 

b. Indicate how many times per year a vessel performs mechanical underwater scrubbing: 

_____________ times per year 

5) CATHODIC PROTECTION 

19. Indicate the percentage of your vessels that use ICCP (Impressed Current Cathodic Protection) as the 

method of Cathodic Protection:...sacrificial electrodes as the method of Cathodic Protection: 

(ICCP)__________________________________ % of vessels 

(Sacrificial Electrodes)_____________________ % of vessels 

 

(If all vessels use ICCP, skip question 3) 

20. Indicate how many times per year a vessel performs maintenance ________ times per year 

r. Indicate how often cleaning the anodes, including minimizing the flaking of the large, corroded 

portions of the anodes is done during maintenance periods: 

Always_____ Most of the time _____ Sometimes _______ Rarely ______ Never ______ 

s. Estimate the cost of performing maintenance (i.e. cleaning) to the anodes: 

à Labor Hours typically required to perform maintenance to the anodes: _______ hours 

à Additional Cost and Fees: $____ per instance of performing maintenance to the anodes.

 OR 

à Total Cost: $____ per instance of performing maintenance to the anodes.

December 18, 2008 Final 143
Economic and Benefits Analysis of the Final Vessel General Permit 

21. (With awareness that magnesium is less toxic than aluminum which is less toxic than zinc), when 

economically and physically feasible, estimate the percent of vessels that use the metals that are less toxic 

for sacrificial electrodes: ___________________ % of vessels 

a. Estimate the additional cost per vessel of purchasing these specific types of less toxic metals: 

$_______________________ 

22. Estimate the cost per vessel of installing sacrificial electrodes as the method of Cathodic Protection: 

à Total Cost: $____ per instance of installing sacrificial electrodes as the method of 

Cathodic Protection.

23. Estimate the cost per vessel of installing ICCP as the method of Cathodic Protection: 

à Total Cost: $____ per instance of installing ICCP as the method of Cathodic Protection.

6) CHAIN LOCKER EFFLUENT 

24. Estimate how often a vessel carefully and thoroughly washes down the anchor chain as it is being hauled 

out of the water to remove sediment and marine organisms: 

Always_____ Most of the time _____ Sometimes _______ Rarely ______ Never ______ 

t. Estimate the cost involved with this task: 

à Labor Hours typically required to wash down the anchor chain: ____hours 

à Additional Cost and Fees: $____ per instance of washing down the anchor chain.

 OR 

à Total Cost: $____ per instance of washing down the anchor chain.

 OR 

à Check this box if this cost is negligible 

u. Indicate how many times per year a vessel hauls the anchor chain out of the water: 

 ____times per year 

25. During dry docks, how often does a vessel thoroughly clean chain lockers to eliminate accumulated 

sediments and any potential accompanying pollutants: 

Always_____ Most of the time _____ Sometimes _______ Rarely ______ Never ______ 

a. Estimate the cost involved with this task: 

à Labor Hours typically required to clean chain lockers: ____hours 

à Additional Cost and Fees: $____ per instance of cleaning chain lockers. 

 OR 

à Total Cost: $____ per instance of cleaning the chain lockers.

 OR 

à Check this box if this cost is negligible 

b. Indicate how many times per year a vessel dry docks: _______________ times per year 

26. Estimate how often a vessel inspects, cleans, and pumps out the space beneath the chain locker prior to 

entering nearshore waters: 

December 18, 2008 Final 144
Economic and Benefits Analysis of the Final Vessel General Permit 

Always___ Most of the time ___ Sometimes ___ Rarely ___ Never ___ 

a. Estimate the cost involved with this task: 

à Labor Hours typically required to inspect, clean, and pump out the space beneath the 

chain locker: ____hours 

à Additional Cost and Fees: $____ per instance of inspecting, cleaning, and pumping out 

the space beneath the chain locker. 

 OR 

à Total Cost: $____ per instance to inspect, clean, and pump out this space.

 OR 

à Check this box if this cost is negligible 

b. Estimate the number of times per year a vessel enters nearshore waters: _____________ times per 

year 

27. Unless rinsing/pumping within 3 nm from shore is necessary for safety purposes, how often does a vessel 

rinse or pump this space greater than 3 nm from shore: 

Always_____ Most of the time _____ Sometimes _______ Rarely ______ Never ______ 

v. If rinsing/pumping within 3 nm from shore is necessary, how often is the safety claim is 

documented: Always_____ Most of the time ____ Sometimes ______ Rarely ______ Never ___

i. Estimate the cost involved with the documentation: 

à Labor Hours typically required to document the safety claim: ____hours 

 OR 

à Total Cost: $____ per instance to document the safety claim.

ii. Estimate how many times per year a vessel rinses/pumps within 3 nm from shore if 

necessary for safety purposes: ____________ times per year 

7) CONTROLLABLE PITCH PROPELLER HYDRAULIC FLUID 

28. During dry docks, how often does a vessel perform maintenance activities on controllable pitch 

propellers: Always_____ Most of the time _____ Sometimes _______ Rarely ______ Never _______

a. Estimate the cost involved with this task: 

à Labor Hours typically required to perform maintenance activities on controllable pitch 

propellers: ____hours 

à Additional Cost and Fees: $____ per instance of performing maintenance activities on 

controllable pitch propellers. 

 OR 

à Total Cost: $____ per instance to perform maintenance on controllable pitch propellers.

 OR 

à Check this box if this cost is negligible 

b. Indicate how many times per year a vessel dry docks: _______________ times per year 

29. During instances of maintenance when the vessel is in the water, how often does a vessel use an oil boom 

to contain any hydraulic oil leakage: 

December 18, 2008 Final 145
Economic and Benefits Analysis of the Final Vessel General Permit 

Always_____ Most of the time _____ Sometimes _______ Rarely ______ Never ______

a. Estimate the cost involved with using an oil boom to contain any hydraulic oil leakage: 

à Labor Hours typically required to use an oil boom to contain any hydraulic oil leakage: 

____hours 

à Additional Cost and Fees: $____ per instance of using an oil boom to contain any 

hydraulic oil leakage. 

 OR 

à Total Cost: $____ per instance to use an oil boom.

 OR 

à Check this box if this cost is negligible 

b. Estimate how many times per year a vessel performs this type of maintenance while the vessel is 

in the water: _____________ times per year 

c. Estimate the percentage of vessel operators that have appropriate equipment such as oil absorbent 

pads to clean any potential oil spills: _____________ % of vessel operators 

i. Estimate the additional cost per individual vessel of purchasing the appropriate 

equipment to clean any potential oil spills: $___________________________ 

8) ELEVATOR PIT EFFLUENT 

30. In cases of non-emergency, estimate how many times per year a vessel discharges elevator pit effluent: 

 ____________________ times per year 

a. Estimate the cost involved, if any, to dispose of this effluent onshore: 

à Labor Hours typically required to dispose this effluent onshore: ____hours 

à Additional Cost and Fees: $____ per instance of disposing this effluent onshore. 

 OR 

à Total Cost: $____ per instance to dispose of effluent onshore.

 OR 

à Check this box if this cost is negligible 

31. In cases of emergency, how often does a vessel discharge elevator pit effluent with an oil content below 

15 ppm: Always_____ Most of the time _____ Sometimes _______ Rarely ______ Never ______

a. Estimate the cost involved, if any, to ensure that the elevator pit effluent has an oil content below 

15 ppm: 

à Labor Hours typically required to ensure that the elevator pit effluent has an oil content 

below 15 ppm: ____hours 

à Additional Cost and Fees: $____ per instance of ensuring that the elevator pit effluent 

has an oil content below 15 ppm. 

 OR 

à Total Cost: $____ per instance to ensure the oil level.

 OR 

à Check this box if this cost is negligible 

December 18, 2008 Final 146
Economic and Benefits Analysis of the Final Vessel General Permit 

b. In cases of emergency, estimate how many times per year a vessel discharges elevator pit 

effluent:__________________ times per year 

9) FIREMAIN SYSTEMS 

32. Except in emergency situations or when washing down the anchor chain to comply with anchor wash 

down when pulling the anchor and anchor chain from waters, estimate how many times per year a vessel 

discharges from firemain systems into “waters of exceptional value”: __________ times per year 

w. Estimate the cost involved, if any, to dispose of the firemain system discharge onshore: 

à Labor Hours typically required to dispose of the firemain system discharge onshore: 

____hours 

à Additional Cost and Fees: $____ per instance of disposing of the firemain system 

discharge onshore. 

 OR 

à Total Cost: $____ per instance to dispose of the discharge onshore.

 OR 

à Check this box if this cost is negligible 

December 18, 2008 Final 147
Economic and Benefits Analysis of the Final Vessel General Permit 

DEFINITIONS OF DISCHARGE CATEGORIES 

33. Deck Runoff: the precipitation, washdowns, and seawater falling on the weather deck of a vessel and 

discharged overboard through deck openings. Primarily, we are referring to the runoff caused by deck 

washdowns (unless the question specifies otherwise). 

34. Aqueous Film-Forming Foam: the firefighting foam and seawater mixture discharged during training, 

testing, or maintenance operations. 

35. Graywater: galley, bath, and shower water, as well as wastewater from lavatory sinks, laundry, interior 

deck drains, water fountains, and shop sinks where vapors could accumulate. 

36. Underwater Ship Husbandry: the materials discharged during the inspection, maintenance, cleaning, 

and repair of hulls performed while the vessel is waterborne. 

37. Cathodic Protection: the constituents released into surrounding water from sacrificial anode or 

impressed current cathodic hull corrosion protection systems. 

38. Chain Locker Effluent: the accumulated precipitation and seawater that is emptied from the 

compartment used to store the vessel's anchor chain. 

39. Controllable Pitch Propeller Hydraulic Fluid: the hydraulic fluid that discharges into the surrounding 

seawater from propeller seals as part of normal operation, and the hydraulic fluid released during routine 

maintenance of the propellers. 

40. Elevator Pit Effluent: the liquid that accumulates in, and is discharged from, the sumps of elevator wells 

on vessels. 

41. Firemain Systems: the seawater pumped through the firemain system for firemain testing, maintenance, 

and training, and to supply water for the operation of certain vessel systems. 

December 18, 2008 Final 148
Economic and Benefits Analysis of the Final Vessel General Permit 

Cruise Ship Survey 

WHY DOES EPA NEED THIS INFORMATION? 

The Agency is evaluating the impacts of instituting a General Permit for practices associated with discharges 

incidental to normal operation of cruise ships as part of developing a permitting framework for commercial 

vessels. The Agency will use your responses to estimate any incremental costs that would result from 

implementing best management practices required under this Permit. 

SURVEY INSTRUCTIONS

Please fill out all pieces of information that are relevant and obtainable. Include any comments if any of the 

requested information is not available and/or not relevant. If you are unable to estimate the cost for a piece of 

information in the manner requested but are able to estimate the cost in a separate manner, please do so and mark 

accordingly. 

Please either fill out the survey and email the electronic version to Steve Collins at scollins@cruising.org or print 

out the survey and scan/email and/or fax the hard copy survey to Steve at (fax) 754-224-2250. 

PRIMARY CONTACT PERSON: 

Last Name ___________________ First Name ____________________ Title _______ 

Company _____________________________________ 

QUESTIONS:

1. HOW MANY VESSELS ARE IN YOUR COMPANY? 

 ________________________________ 

2. HOW MANY VESSELS ARE: 

a. Large cruise ships authorized to carry 500 or more passengers? _________ 

b. Medium cruise ships authorized to carry 250 to 499 passengers? _________ 

c. Medium cruise ships authorized to carry 100 to 249 passengers? _________ 

 

Unless otherwise noted, when asking for information regarding medium cruise ships, please include information 

for both medium cruise ship classifications, i.e. those authorized to carry 250-499 passengers and those 

authorized to carry 100-249 passengers. 

3. INDICATE THE NUMBER OF YOUR CRUISE SHIPS THAT HAVE AN ADVANCED WASTEWATER 

PURIFICATION (OR TREATMENT) SYSTEM FOR TREATING BLACKWATER THAT ARE ALSO 

CONFIGURED TO TREAT GRAYWATER THAT MEET THE FOLLOWING DISCHARGE STANDARDS: 

(1) The discharge must satisfy the minimum level of effluent quality specified in 40 

CFR 133.102; 

December 18, 2008 Final 149
Economic and Benefits Analysis of the Final Vessel General Permit 

(2) The geometric mean of the samples from the discharge during any 30-day period 

may not exceed 20 fecal coliform/100 milliliters (ml) and not more than 10 percent of 

the samples exceed 40 fecal coliform/100 ml; and/or 

(3) Concentrations of total residual chlorine may not exceed 10.0 micrograms per liter 

(μg/l); 

____ large cruise ships _____ medium cruise ships 

4. DESCRIBE DISCHARGE SAMPLING ACTIVITIES

a. How many of your cruise ships are certified for use in Alaska? 

 ____ large cruise ships _____ medium cruise ships 

b. Indicate the number of samples all other cruise ships take (not including those cruise ships 

authorized to operate in Alaska)take over a 30 day period: 

 ___ samples from large cruise ships 

 ___ samples from medium cruise ships 

c. Please indicate if test samples are typically taken: 

1. Biological oxygen demand (BOD): ____yes ____ no 

2. Suspended solids: ____yes ____ no 

3. pH: ____yes ____ no 

4. Total residual chlorine: ____yes ____ no 

d. Estimate typical total cost of analyzing water samples: $____ 

(If all cruise ships have graywater treatment systems to meet the standards within question 1 (Alaskan 

standards), skip questions 5, 6, and 7). 

5. INDICATE THE NUMBER OF CRUISE SHIPS THAT DO NOT HAVE A STANDARD GRAYWATER TREATMENT 

SYSTEM AND DO NOT HAVE HOLDING CAPACITY TO DISCHARGE IN WATERS GREATER THAN 1 NM 

FROM SHORE: 

 ____ large cruise ships _____ medium cruise ships 

(If all cruise ships have sufficient holding capacity, skip questions 6 and 7) 

6. INDICATE THE NUMBER OF CRUISE SHIPS THAT DO NOT HAVE SUFFICIENT HOLDING CAPACITY AND 

THUS NEED TO DISCHARGE WHILE PIERSIDE: 

 ____ large cruise ships _____ medium cruise ships 

(If 0, skip all of question 6.) 

a. Estimate the average number of days per year that a cruise ship is pierside: 

 ______ days for large cruise ships _____ day for medium cruise ships 

b. Estimate what percentage of time discharge is necessary while pierside and appropriate reception 

facilities for graywater are available? 

 ____ % for large cruise ships _____ % for medium cruise ships 

December 18, 2008 Final 150
Economic and Benefits Analysis of the Final Vessel General Permit 

c. Estimate what percentage of time discharge is necessary while pierside and appropriate reception 

facilities for graywater are used? 

 ____ % for large cruise ships _____ % for medium cruise ships 

d. Estimate the average amount of labor hours required of discharging graywater at appropriate 

reception facilities, per instance: 

 ____ labor hours per large cruise ships _____ labor hours per medium cruise ships 

7. UNTREATED GRAYWATER DISCHARGES

a. On average, how many times per year do untreated graywater discharges occur? 

_____ times per year per large cruise ship 

_____ times per year per medium cruise ship 

b. How often do vessel operators thoroughly document untreated graywater discharges within their 

recordkeeping books? 

Large Cruise Ships: Always ___ Most of the time ___Sometimes___ Rarely ___

Medium Cruise Ships: Always ___Most of the time ___Sometimes__ Rarely ___

c. Estimate the average amount of labor hours required for documenting untreated graywater 

discharges per instance: 

 ____ labor hours per large cruise ships ___ labor hours per medium cruise ships 

Number of not documented discharges per year: 

____large cruise ships ____ medium cruise ships 

8. CRUISE SHIPS OPERATING IN UNITED STATES NUTRIENT IMPAIRED WATERS 

a. How many of your cruise ships operate in nutrient impaired waters (including, but not limited to, 

Chesapeake Bay, San Francisco Bay, Puget Sound, and the territorial sea surrounding the mouth 

of the Mississippi River in the Gulf of Mexico)? 

 ___large cruise ships ___ medium cruise ships 

 ___unsure if cruise ships operate in nutrient impaired waters 

(If 0 or unsure, skip all of question 8) 

b. How many of these cruise ships have a standard graywater treatment system as noted within 

question 3 (same as Alaskan standards)? 

 ___large cruise ships ___ medium cruise ships 

c. How many of the cruise ships with no standard graywater treatment system have sufficient 

holding capacity for graywater in order to not discharge within these waters? ___large cruise 

ships ___ medium cruise ships 

December 18, 2008 Final 151
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 152

9. DUE TO THE PENDING PERMIT REQUIREMENT, HOW MANY OF YOUR CRUISE SHIPS ARE LIKELY TO 

CONTINUE TO HOLD AND DISCHARGE GRAYWATER ACCORDING TO THE PERMIT STANDARDS VERSUS 

PURCHASING/UPGRADING THE GRAYWATER TREATMENT SYSTEM ACCORDING TO THE STANDARDS 

WITHIN QUESTION 3 (SAME AS ALASKAN STANDARDS) (SEE ATTACHMENT FOR A SUMMARY OF 

DISCHARGE AND TREATMENT STANDARDS)? 

___large cruise ships ___ medium cruise ships 

10. USE OF SOAPS AND DETERGENTS

a. Please indicate the number of gallons of soap/degreaser or number of cruise ships that are 

associated with each section: 

Number of Gallons purchased of all types of 

soaps/degreasers, per fleet per year 

Number of Cruise Ships Using Phosphate 

Free Soaps or Non-Toxic Degreasers 

Large Cruise 

Ships 

Medium 

Cruise Ships 

Total Large Cruise 

Ships 

Medium 

Cruise Ships 

Total 

Soaps41

Degreasers 

b. Estimate the incremental cost of purchasing phosphate free soaps and non-toxic degreasers: 

Incremental Cost per Gallon Incremental Cost per Fleet 

Soaps42

Degreasers 

11. DESCRIBE MANAGEMENT PRACTICES TO PREVENT WASTEWATER DISCHARGES 

a. What practices does a cruise ship typically perform to prevent unintended waste discharge from these 

sources? Check all that apply. Please note if there are any significant differences among large and 

medium cruise ships.

 

41 I.E. shower and hand soaps, laundry detergents, and dishwashing soaps. 

42 I.E. shower and hand soaps, laundry detergents, and dishwashing soaps. 
Economic and Benefits Analysis of the Final Vessel General Permit 

Practice 

Waste discharge 

Plug area drains that 

flow to graywater, 

blackwater, or bilge 

systems 

Create 

alternative 

waste 

receptacles 

Replumbing drains to 

appropriate holding tanks 

and then disposing of these 

wastes 

Medical sinks or floor drains 

Salon/ day spa sinks and floor drains 

Chemical storage areas 

b. Please estimate incremental installation, maintenance, and labor hours that are associated with each of 

these practices: 

Practice 

Cost Plug drains Waste receptacles Replumbing 

Installation Cost 

Maintenance Cost 

Total Labor Hours: 

December 18, 2008 Final 153
Economic and Benefits Analysis of the Final Vessel General Permit 

ATTACHMENT: 

PERMIT SPECIFICATIONS REGARDING DISCHARGE STANDARDS 

AND GRAYWATER TREATMENT STANDARDS

DISCHARGE STANDARDS:

Pierside Limits: 

1) While pierside, appropriate reception facilities for Graywater must be used, if reasonably available. 

Operational Limits: 

1) While operating within 1 nm of shore for large cruise ships or 1000 feet of shore for medium cruise ships, 

discharges of graywater are prohibited. 

3) If you operate within 3 nm of shore, discharges of graywater must either be released while the Cruise Ship is 

sailing at a speed of at least 6 knots and is not in a water of exceptional value. 

Nutrient Impaired Water Limits: 

1) Large Cruise Ships: If you are operating in nutrient impaired waters including, but not limited to, such as the 

Chesapeake Bay or the territorial Sea surrounding the mouth of the Mississippi River in the Gulf of Mexico, you 

must not discharge graywater. 

2) Medium Cruise Ships: If you are operating in nutrient impaired waters including, but not limited to, such as the 

Chesapeake Bay or the territorial Sea surrounding the mouth of the Mississippi River in the Gulf of Mexico, you 

must discharge the Graywater while the Cruise Ship is sailing at a speed of at least 6 knots or dispose of 

graywater properly on shore. 

Monitoring Requirements: 

1) The owner/operator must maintain records estimating all discharges of untreated graywater into waters subject 

to this permit, including date, location and volume discharged in their recordkeeping documentation. These 

records can be maintained as part of the vessel’s sewage and graywater discharge record book 

TREATMENT STANDARDS:

Treatment System Standard: 

The discharge of treated Graywater must meet the following standards: 

(1) The discharge must satisfy the minimum level of effluent quality specified in 40 CFR 133.102; 

(2) The geometric mean of the samples from the discharge during any 30-day period may not exceed 20 fecal 

coliform/100 milliliters (ml) and not more than 10 percent of the samples exceed 40 fecal coliform/100 ml; and 

(3) Concentrations of total residual chlorine may not exceed 10.0 micrograms per liter (μg/l); 

(Based on 33 CFR 159.309 – Alaskan Cruise Ship Regulation) 

Monitoring Requirements: 

1) In order to demonstrate the effectiveness of the treatment system, the vessel operator must take at least five 

samples taken from the vessel on different days over a 30-day period that are representative of the treated effluent 

to be discharged. Samples must be taken for BOD, suspended solids, pH, and total residual chlorine. Sampling 

and testing shall be conducted according to 40 CFR Part 136. 

December 18, 2008 Final 154
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 155

2) After demonstrating the effectiveness of their system, vessel owner/operators must conduct the same sampling 

and analysis twice each year to demonstrate treatment equipment maintenance and compliance. Records of the 

sampling and testing results must be retained onboard for a period of 3 years in the vessels recordkeeping 

documentation. 
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final Appendix B: Summary of Survey Responses Individual BMP Survey The following tables summarize the industry responses to the questionnaires in Appendix A. The Individual BMP Questionnaipractices and cost estimates was sent to three different industry representatives who represent: (1) passenger vessels, (2) towin(3) freight and tank ships. The industry representatives sent this questionnaire to their member companies to obtain informatioindustry received one response from its member companies, which was sent directly to Abt Associates for review. The towing 

industry received nine responses from five different companies. One company among these nine respondents provided informdifferent operational areas. These surveys were also sent directly to Abt Associates for review. Member companies in the freig

did not respond to the full questionnaire. However, the industry representative provided information on more general question

member companies. The Cruise Ship Questionnaire was sent to one industry representative, who sent the survey to member cruise lines. The indusa summary of the responses and has provided further information on request as a supplement to these responses. 

Survey Responses Regarding Labor RatesaPassenger Vessel Company Provided an average labor rate of $35. Towing Vessel and Barge Companies Five companies with a very small number of vessels provided an average labor rate 

of $75. Two other companies with a slightly larger number of vessels provided rates of $32 and $60 per hour. Two other companies with the largest number of vessels provided rates of $14 and $15 per hour. 

Freight and Tank Ship Industry Has not yet provided labor rate information. a Based upon these average labor rates and the corresponding number of vessels associated with each industry response, an average labor rate of $31.61 was calculated among all these industries. The weighted average labor rate used for deck runoff practice cost estimates is $16.53. This labor rate remains lower than the overall average since this calculation does not include the responses from the passenger vessel company. 
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 157

Survey Responses Regarding Deck Runoff 

Deck Cleanup Drip Pan Installation Drip Pan Cleaning Deck Wa

Passenger Vessel Company 

Deck cleanup is regularly performed prior to washdown/departing from port. 

Towing Vessel and Barge Companies 

Three of the nine respondents stated that their vessels do not perform deck washdowns or deck cleanups. The other six respondents provided a range of the number of times that a vessel performs deck cleanup and deck washdown and the number of times a vessel departs from port, per month. The number of times a vessel performs deck cleanup ranges from one to 15 times per month, the number of times a vessel performs deck washdown ranges from one to 20 times per month, 

and the number of times a vessel departs from port ranges from four to 30 times per month. The respondents provided a range of 1 to 6 hours required per cleanup. 

Eight of the nine respondents stated their vessels had drip pans installed. One of the nine respondents stated that drip pans were not installed. The respondents estimated a cost ranging from $2,000 to $8,000 for the onetime installation. 

Seven of the nine respondents stated that they regularly clean drip pans when necessary. The respondents provided a range of the frequency that the drip pans need to be cleaned/drained of once per month to four times per month. They also provided a range of the cost of disposal of $200 to $1,200 per cleaning. The other two respondents did not respond to this question. 

Eight of t

their vessfriendly cwashdowrespondengallons oper monthgallons. Trespond t

Freight and Tank Ship Industry 

Deck cleanup is an ongoing activity on all ship types. Ships do not generally perform deck washdowns. The exception is that inland vessels and dry bulk cargo vessels collect cargo residues and may perform a washdown. 
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 

Survey Responses Regarding AFFF Passenger Vessel Company 

AFFF is not an applicable discharge to passenger vessels. 

Towing Vessel and Barge Companies 

AFFF is not an applicable discharge to these vessels. 

Freight and Tank Ship Industry 

Foams are typically not changed out of ships more frequently than every 5 years. Respondents provided a range of 5 to 25 years in which foams may need to be replaced. AFFF is by far the most frequent foam used by vessels, while some vessels also use protein and polar solvent foams. The type of foam that is carried onboard is dependent on the type of cargo. The amount of foam in the tanks ranges from 300 to 6,000 gallons, dependent on ship type. It is not standard to have the technology to collect and store maintenance/training discharges of foams. It is common practice to wash the foam over the side of the ship. It is uncommon to perform these maintenance/training discharges while in inland waters. Most vessels perform these discharges while at sea. 

Survey Responses Regarding Graywater 

Graywater Discharge Soaps and Detergents 

Passenger Vessel Company 

Graywater is always disposed of onshore at appropriate facilities. The respondent cited a cost of $0.18 per gallon to dispose onshore. 100% of vessels can store graywater in holding tanks. 

The respondent uses non-toapproximately 5 gallons per 

Towing Vessel and Barge Companies 

Six of the nine respondents stated that 0% of their vessels are able to store graywater. One of the other respondents stated that 100% of oceangoing vessels are able to store graywater in order to reach a distance of greater than 1 nm to discharge and, most of the time, they discharge in waters greater than 1 nm from shore. Another of the other respondents stated that 50% of oceangoing vessels are able to store graywater in order to reach a distance of greater than 1 nm to discharge, and they always discharge in waters greater than 1 nm from shore. These vessels need to discharge approximately 10 times per month. Both of these respondents 

stated that all vessels that are able to store graywater avoid discharging in waters of exceptional value and that there is no additional cost of discharging in waters greater than 1 nm from shore. The remaining respondent did not respond to this question. 

Five of the nine respondentvessels use environmentally detergents. The number of granges from 24 to 125 gallogallons of detergent per yearespondents did not respond 

Freight and Tank Ship Industry 

Some vessels are able to retain graywater and some are not. 
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 159

Survey Responses Regarding Underwater Hull Husbandry Passenger Vessel Company 

Does not clean hull underwater. 

Towing Vessel and Barge Companies 

Eight of the nine respondents stated that the hull is always cleaned during drydocks, not while underwater. The other respondent stated that the hull is cleaned during drydock or while underwater every 30 months. If cleaning is performed 

underwater, the hull is always cleaned by methods that minimize the discharge of fouling organisms and anti-fouling hull coatings. Estimates a cost of $70,000 per cleaning. Always disposes of removed substances in accordance with local, state, and federal regulations. 

Freight and Tank Ship Industry 

Hull cleaning is performed based on need. 

Survey Responses Regarding Cathodic Protection 

Cathodic Protection System Metals Used Maintenance/Replacemen

Passenger Vessel Company 

Use sacrificial electrodes (magnesium) as the method of cathodic protection. 

Towing Vessel and Barge Companies 

Seven of the nine respondents stated that 100% of their vessels use sacrificial electrodes as the method of cathodic protection. One of the other respondents stated that 100% of its vessels use an impressed current system as the method of cathodic protection. The other respondent stated that 30% of its vessels use sacrificial electrodes as the method of cathodic protection. Estimates a cost ranging from $4,500 to $30,000 to install a cathodic protection system. 

Two of the nine respondents stated that none of their vessels have magnesium or aluminum anodes. Four of the nine respondents stated that 100% of their vessels use the less toxic metals. The other three respondents did not respond to this question. 

Four of the nine respondenmaintenance to the cathodiis performed during regulamaintenance. The respondrange of the maintenance tmaintenance is performed once in five years. One of respondents stated that anoreplaced, not cleaned. The respondents did not respon

Freight and Tank Ship Industry 

The majority of ships have impressed current systems installed, and some have sacrificial anodes added for increased protection. 
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 

Survey Responses Regarding Chain Locker Effluent 

Wash Anchor Chain as Hauled Out of Water 

Clean Chain Lockers in Drydock 

Clean Space Beneath Chain Locker Prior to Entering Nearshore Water 

DocSpafro

Passenger Vessel Company 

Chain locker effluent does not apply to these vessels. 

Towing Vessel and Barge Companies 

Three of the nine respondents stated that this practice is not applicable to their vessels. Four of the other six respondents stated that the anchor chain is always washed down as it is being hauled out of the water. Two of the other six respondents stated that the anchor chain is rarely washed down as it is being hauled out of the water. These six respondents stated that the number of times that an anchor is hauled out of the water varies depending on the type of vessels. Most provided an average between 12 and 50 times per year and an estimate of 0.5 to 1 hour to perform this cleaning. The other two respondents did not respond to this question. 

Two of the nine respondents stated that this practice is not applicable to their vessels. Six of the other seven respondents stated that, during drydocks, a vessel always thoroughly cleans chain lockers. One of the seven respondents stated that this was done most of the time. These seven respondents estimated a cost ranging from $2,000 to $15,000 per cleaning and that a vessel is drydocked from twice every five years to twice every three years. 

Two of the nine respondents stated that this practice is not applicable to their vessels. The other seven respondents stated that the space beneath the chain locker is rarely inspected, cleaned, and pumped out prior to entering nearshore waters. These seven respondents provided a range of the number of times that a vessel enters nearshore waters ranging from 50 times per year to daily. One of the seven respondents estimated a cost of $2,000 per instance, and another estimated that 40 labor hours are required per instance. 

TwstatappThe statnot from 

Freight and Tank Ship Industry 

It is normal practice to rig a fire hose and wash down the anchor as it is being heaved. Additionally, most new ships have several high-pressure freshwater spray nozzles installed in the hawsepipes that spray the chain and anchor as it is being heaved and thus wash seafloor sediment back into the water. 

Chain lockers are typically cleaned during normal shipyard periods and not operations (since the lockers are full of anchor chain) whether on the deep s
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 161

Survey Responses Regarding Controllable Pitch Propeller Hydraulic Fluid 

Maintenance During Dry Dock 

Use of Oil Boom for Underwater Maintenance Oil Spill Equipment Onboard 

Passenger Vessel Company 

Controllable pitch propeller hydraulic fluid is not applicable to these vessels. 

Towing Vessel and Barge Companies 

Seven out of the nine respondents stated that controllable pitch propeller hydraulic fluid is not applicable to these vessels. The other two respondents stated that, during drydocks, a vessel always performs maintenance on controllable pitch propellers. One of the respondents estimated a $15,000 cost per instance and stated that a vessel drydocks 0.67 times per year. 

The two respondents to whom this question was applicable stated that these vessels never perform this maintenance in the water. One respondent stated that if the maintenance was done in the water, an oil boom would be rigged. The other respondent stated that an oil boom would not be rigged. 

The two respondents to whom this question was applicable stated that 100% of vessel operators have oil spilequipment on hand. Estimates a cost o$1,000 to $2,000 to purchase the equipment. 

Freight and Tank Ship Industry 

Routine maintenance of the controllable pitch propeller occurs during drydocks. 

It is not common to rig an oil boom because the vessel is drydocked. If any maintenance is to be done with the vessel in the water it would be boomed. 

All ships have some supply of absorbent pads and other equipment aboard ship. 

Survey Responses Regarding Elevator Pit Effluent Passenger Vessel Company 

Elevator pit effluent is not applicable to these vessels. 

Towing Vessel and Barge Companies 

Eight respondents stated that this discharge is not applicable to these vessels. Another respondent stated that vessels never 

discharge elevator pit effluent. Estimates a cost of $2,000 per instance to dispose of the effluent onshore. In cases of emergency, a vessel never discharges this effluent with an oil content >15 ppm. However, this emergency discharge never occurs. 

Freight and Tank Ship Industry 

Elevator pit effluent would be pumped to an oily waste tank and either transferred to a slop tank for disposal ashore, or burned in the incinerator. 
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 

Survey Responses Regarding Firemain Discharges Passenger Vessel Company 

Firemain discharge is not applicable to these vessels. 

Towing Vessel and Barge Companies 

Three out of the nine respondents stated that firemain discharge is not 

applicable to these vessels. Another four respondents stated that a vessel never discharges from firemain systems into waters of exceptional value. The last two respondents stated that a vessel may discharge from firemain systems into waters of exceptional value from 12 to 52 times per year. 

Freight and Tank Ship Industry 

Unless in emergency situations, legally required drills and system activation are conducted out of port. Firemain discharges are charged with freshwater, operated with the effluent going over the side through normal deck drainage ports. 
Economic and Benefits Analysis of the Final Vessel General Permit 

December 18, 2008 Final 163Cruise Ship Survey 

Survey Responses Regarding Cruise Ships Pierside and Operational Limits Both large and medium cruise ships have sufficient holding capacity to 

avoid discharging within 1 nm from shore. Discharges within 3 nm from 

shore currently undergo graywater treatment or are discharged while the ship is sailing at a speed of at least 6 knots. Furthermore, regarding the Permit specifications, according to an industry representative, reception facilities for graywater are very rare and are not commonplace even at major ports. 

Limits Applicable to Operation in Nutrient Impaired Waters 

If necessary to discharge, medium cruise ships discharge graywater in 

these waters while sailing at a speed of at least 6 knots. There is a subset 

of large cruise ships that operate in these waters whose graywater holding capacity is exceeded due to the voyage length. 

Sculleries and Galleys The industry representative was not able to provide the percentage of 

large or medium ships that use these phosphate free/non-toxic products or the annual average number of gallons that are purchased by a ship. 

Hazardous Waste Source drains are currently either replumbed to appropriate holding tanks 

or are plugged and alternative waste receptacles are used. 

Untreated Graywater Documentation Documentation of these discharges is common practice. Monitoring The cost associated with one sampling event is approximately $1,000 per 

ship. Sampling is not a current practice for the majority of cruise ships.