Clean Water Act Section 316(b) 

Proposal for Information Collection 

for Scattergood Generating Station 

City of Los Angeles Department of Water and Power 

111 N. Hope Street 

Los Angeles, California 90012-2607 

October 2005 

Prepared by: URS Corporation 

Alden Research Laboratory, Inc. 

EPRI Solutions, Inc. 

MBC Applied Environmental Sciences 

Tenera Environmental, Inc. 
Scattergood Generating Station 

Proposal for Information Collection 

TABLE OF CONTENTS 

Section Page

1.0 EXECUTIVE SUMMARY ........................................................................................ 1-1 

2.0 INTRODUCTION....................................................................................................... 2-1 

3.0 DESCRIPTION OF SCATTERGOOD GENERATING STATION..................... 3-1 

3.1 Location and Physical Description of Cooling Water Intake Structure 

and Cooling System............................................................................................. 3-1 

3.2 Description of Cooling Water Intake Structure ................................................... 3-2 

3.3 Existing Hydraulic Conditions............................................................................. 3-3 

 3.4 Applicable Performance Standards...................................................................... 3-8 

3.5 Conformance with the Calculation Baseline........................................................ 3-8 

4.0 COMPLIANCE ALTERNATIVES TO BE EVALUATED................................... 4-1 

4.1 Taking Credit for Existing Use of Fish Protection Technologies and 

Operational Measures Under the Rule’s Calculation Baseline – Compliance 

 Alternative 2......................................................................................................... 4-1 

 4.1.1 Impingement Mortality Reduction Credits.............................................. 4-1 

 4.1.2 Entrainment Reduction Credit ................................................................. 4-2 

4.2 Use of Restoration Under Compliance Alternative 3 .......................................... 4-2 

4.3 Use of Fish Protection Technologies and/or Operational Measures Under 

Compliance Alternatives 3, 4, and 5.................................................................... 4-3 

 4.3.1 Narrow-Slot Cylindrical Wedgewire Screens.......................................... 4-5 

 4.3.2 Fine-Mesh Ristroph Traveling Water Screens......................................... 4-6 

4.3.3 Use of Pilot Studies................................................................................ 4-10 

4.3.4 Use of Operational Measures................................................................. 4-10 

4.4 Use of an Approved Technology Under Compliance Alternative 4.................. 4-10 

4.5 Use of Site-Specific Standards Under Compliance Alternative 5 ..................... 4-11 

4.5.1 Evaluation of Cost-Cost Test................................................................. 4-11 

4.5.2 Evaluation of Cost-Benefit Test............................................................. 4-12 

5.0 BIOLOGICAL STUDIES .......................................................................................... 5-1 

6.0 SUMMARY OF PAST OR ONGOING CONSULTATIONS WITH 

AGENCIES .................................................................................................................. 6-1 

7.0 SCHEDULE FOR INFORMATION COLLECTION ............................................ 7-1 

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Tables Page

Table 1 Capacity Utilization for Units 1, 2, and 3 ............................................................ 3-2 

Table 2 Applicability of Other Technologies ................................................................... 4-4 

Figures Page

Figure 1 Location of Scattergood Generating Station........................................................ 3-1 

Figure 2 Site Configuration of Scattergood Generating Station ........................................ 3-4 

Figure 3 Plan and Side Views of Scattergood Generating Station Intake Offshore 

 Velocity Cap ........................................................................................................ 3-5 

Figure 4 Plan View of Scattergood Generating Station Onshore Intake Structure ............ 3-6 

Figure 5 Side View of Scattergood Generating Station Onshore Intake Structure ............ 3-7 

Figure 6 Narrow Slot Wedgewire Screens......................................................................... 4-6 

Figure 7 Ristroph Screen Buckets Attached to Bottom of Traveling Screen Panels......... 4-8 

Figure 8 Example of Fine Mesh Screen Panels Used in Test Setup at Alden 

 Research Laboratory ............................................................................................ 4-9 

Appendices

A Summary of Existing Physical and Biological Information and IM&E Characterization 

Study Sampling Plan 

B Velocity Calculations 

C Restoration Measures 

D Proposed Method for Evaluation of Environmental Benefits 

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Acronyms and Abbreviations

AFS American Fisheries Society 

BMP Best Management Practice 

BTA Best Technology Available 

CCRWQCB Central Coast Regional Water Quality Control Board 

CDFG California Department of Fish and Game

CDS Comprehensive Demonstration Study 

cfs Cubic Feet per Second 

CWIS Cooling Water Intake Structure 

CWRP Corporate Wetlands Restoration Project 

El. Elevation 

ft Feet 

ft/s Feet per Second 

GDNR Georgia Department of Natural Resources 

gpm Gallons per Minute 

IM&E Impingement Mortality and Entrainment 

LADWP City of Los Angeles Department of Water and Power 

LARWQCB California Regional Water Quality Control Board, Los Angeles Region 

MBNEP Morro Bay National Estuary Program

mgd Million Gallons per Day 

MLLW Mean Lower Low Water 

mm millimeter 

MW Megawatt 

NGO Non-Governmental Organization 

NMFS National Marine Fisheries Service 

NOAA National Oceanic and Atmospheric Administration 

NPDES National Pollutant Discharge Elimination System

PIC Proposal for Information Collection 

PSEG Public Service Electric & Gas 

psi Pounds per Square Inch 

psig Pounds per Square Inch (gauge) 

QA/QC Quality Assurance/Quality Control 

rpm revolutions per minute 

Rule Clean Water Act Section 316(b) Phase II Final Rule 

RUM Random Utility Model 

SCE Southern California Edison 

SONGS San Onofre Nuclear Generating Station 

USEPA United States Environmental Protection Agency 

USFWS United States Fish and Wildlife Service 

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1.0 EXECUTIVE SUMMARY

This Proposal for Information Collection (PIC) is submitted in compliance with the Clean 

Water Act Section 316(b) Phase II Final Rule (Rule) for existing electric generating stations 

published in the Federal Register on July 9, 2004. This PIC is specific to the City of Los 

Angeles Department of Water and Power’s (LADWP) Scattergood Generating Station and 

provides the California Regional Water Quality Control Board, Los Angeles Region 

(LARWQCB) with LADWP’s plans for: 

• Providing necessary biological information; 

• Evaluating alternative fish protection technologies; 

• Evaluating the Rule’s Compliance Alternatives and options; and 

• Providing information on consultations with fish and wildlife agencies. 

The Rule requires facilities that withdraw cooling water greater than 50 million gallons per 

day (mgd) from waters of the United States and that have a capacity utilization that exceeds 

15% to meet both the Rule’s impingement mortality and entrainment (IM&E) reduction 

standards of 80-95% and 60-90%, respectively. Scattergood Generating Station is subject to 

both reduction standards. 

LADWP believes it is likely to be in compliance with the impingement mortality 

performance standard through use of a submerged offshore intake equipped with a velocity 

cap. LADWP’s preferred means to comply with the Rule’s entrainment performance standard 

is through the use of restoration measures. However, due to some uncertainty regarding use 

of the restoration option as a result of Phase II Rule litigation, technologies and/or 

operational measures as well as site-specific standards will also be evaluated as discussed in 

Section 4 of this PIC. LADWP plans to initiate IM&E studies to establish the IM&E 

characterization baseline in January 2006. Studies to confirm the effectiveness of the velocity 

cap are also planned. This PIC also provides an updated schedule consistent with LADWP’s 

proposed schedule submitted on November 4, 2004, to the LARWQCB. 

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2.0 INTRODUCTION 

The United States Environmental Protection Agency (USEPA) signed into regulation new 

requirements for existing electric power generating facilities for compliance with Section 

316(b) of the Clean Water Act on July 9, 2004. These regulations became effective on 

September 7, 2004, and are based on numeric performance standards1. The Rule at 

125.94(a)(1-5) provides facilities with five Compliance Alternatives as follows: 

1. A facility can demonstrate it has or will reduce cooling water flow commensurate 

with wet closed-cycle cooling to be in compliance with all applicable 

performance standards. A facility can also demonstrate it has or will reduce the 

maximum design through-screen velocity to less than 0.5 ft/s in which case it is in 

compliance with the impingement mortality (IM) performance standard (the 

entrainment standard, if applicable, still applies). 

2. A facility can demonstrate that it already has a combination of technologies, 

operational measures, and restoration measures in place to meet the applicable 

performance standards. 

3. A facility can propose to install a combination of new technologies, operational 

measures, and restoration measures to meet applicable performance standards. 

4. A facility can propose to install, operate and maintain an approved design and 

construction technology. 

5. A facility can request a site-specific determination of best technology available 

(BTA) by demonstrating that the cost of installing technologies, operational 

measures, and restoration measures are either significantly greater than the cost 

for the facility listed in Appendix A of the Rule or significantly greater than the 

benefits of complying with the applicable performance standards. 

All facilities that use Compliance Alternatives 2, 3, and 4 are required to demonstrate a 

minimum reduction in impingement mortality of 80% [125.94(b)(1)]. Facilities with a 

capacity factor that is greater than 15% that are located on oceans, estuaries or the Great 

Lakes, or on rivers and have a design intake flow that exceeds more than 5% of the mean 

annual flow, must also reduce entrainment by a minimum of 60% [125.94(b)(2)]. 

The Rule further requires that facilities using Compliance Alternatives 2, 3, and 5 prepare a 

Comprehensive Demonstration Study (CDS) as described at 125.95(b) of the Rule based on 

each of the seven components of the CDS (as appropriate) for the Compliance Alternative(s) 

selected. Facilities using Compliance Alternative 1 are not required to submit a CDS and 

those using Compliance Alternative 4 are only required to submit the Technology Installation 

and Operation Plan and Verification Monitoring Plan. All facilities that use Compliance 

 1

 Performance standards are found at Federal Register, Vol. 69, 7/9/04, 125.94(b). 

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Alternatives 2, 3, and 5 are required to prepare and submit a PIC, the first component of the 

CDS. 

The Rule at 125.95(b)(1) requires that the PIC include: 

1. A description of the proposed and/or implemented technologies, operational 

measures, and restoration measures to be evaluated. 

2. A list and description of any historical studies characterizing (IM&E), and/or the 

physical and biological conditions in the vicinity of the cooling water intake 

structures and their relevance to this proposed Study. If you propose to use 

existing data, you must demonstrate that the data are representative of current 

conditions and were collected using appropriate quality assurance/quality 

control procedures. 

3. A summary of any past or ongoing consultations with relevant Federal, State, 

and Tribal fish and wildlife agencies and a copy of written comments received as 

a result of each consultation. 

4. A sampling plan for any new studies you plan to conduct in order to ensure that 

you have sufficient data to develop a scientifically valid estimate of IM&E at 

your site. The sampling plan must document all methods and quality 

assurance/quality control procedures for sampling and data analysis. The 

sampling and data analysis methods you propose must be appropriate for a 

quantitative survey and include consideration of the methods used in other 

studies performed in the source waterbody. The sampling plan must include a 

description of the study area (including the area of influence of the Cooling 

Water Intake Structure [CWIS]), and provide a taxonomic identification of the 

sampled or evaluated biological assemblages (including all life stages of fish and 

shellfish). 

The preamble to the Rule on Federal Register Page 41635 states that the PIC should provide 

other information, where available, to the National Pollutant Discharge Elimination System

(NPDES) permitting authority regarding plans for preparing the CDS such as how the facility 

plans to conduct a Benefits Valuation Study or gather additional data to support development 

of a Restoration Plan. 

An important feature of the Rule is use of the calculation baseline. The calculation baseline is 

defined in the rule as follows: 

“Calculation baseline means an estimate of impingement mortality and entrainment 

that would occur at your site assuming that: the cooling water system has been 

designed as a once-through system; the opening of the cooling water intake structure 

is located at, and the face of the standard 3/8-inch mesh traveling screen is oriented 

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parallel to, the shoreline near the surface of the source waterbody; and the baseline 

practices, procedures, and structural configuration are those that your facility would 

maintain in the absence of any structural or operational controls, including flow or 

velocity reductions, implemented in whole or in part for the purposes of reducing 

impingement mortality and entrainment. You may also choose to use the current level 

of impingement mortality and entrainment as the calculation baseline. The 

calculation baseline may be estimated using: historical impingement mortality and 

entrainment data from your facility or from another facility with comparable design, 

operational, and environmental conditions; current biological data collected in the 

waterbody in the vicinity of your cooling water intake structure; or current 

impingement mortality and entrainment data collected at your facility. You may 

request that the calculation baseline be modified to be based on a location of the 

opening of the cooling water intake structure at a depth other than at or near the 

surface if you can demonstrate to the Director that the other depth would correspond 

to a higher baseline level of impingement mortality and/or entrainment.” 

This definition provides existing facilities with a variety of study options to take credit for 

facility features that deviate from the calculation baseline and provide the benefit of fish 

protection. Facilities can also simply develop the baseline by documenting current IM&E. 

This PIC provides a description of Scattergood Generating Station including deviations from

the calculation baseline and applicable performance standards in Section 3. Section 4 

describes the Compliance Alternatives and options to be evaluated including a description of 

alternative fish protection technologies and operational measures. Section 5 provides a brief 

description of existing biological information and plans for new studies with a detailed 

summary of biological information and description of new studies provided in Appendix A. 

Section 6 summarizes voluntary and ongoing discussions with fish and wildlife agencies 

related to Clean Water Act Section 316(b), and Section 7 discusses the schedule for 

completion of studies. 

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3.0 DESCRIPTION OF SCATTERGOOD GENERATING STATION 

3.1 LOCATION AND PHYSICAL DESCRIPTION OF COOLING WATER 

INTAKE STRUCTURE AND COOLING SYSTEM 

Scattergood Generating Station is located on the shore of the Santa Monica Bay in the City of 

Los Angeles, California (Figure 1). Scattergood Generating Station uses a once-through 

cooling water system for all three of its generating units and has a total net generating 

capacity of 818 megawatts (MW). Units 1 and 2 are oil/gas system boilers, each with a net 

output of 179 MW. Unit 3 is a gas-fired boiler with a net output of 460 MW. For the years 

2000 through 2004 the capacity factor of Unit 1 was 25%, Unit 2 had a capacity factor of 

31%, and Unit 3 had a capacity factor of 23%. Capacity utilization for Units 1, 2, and 3 is 

shown in Table 1. 

FIGURE 1 

LOCATION OF SCATTERGOOD GENERATING STATION 

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TABLE 1 

CAPACITY UTILIZATION FOR UNITS 1, 2, AND 3 

Capacity Utilization (%) 

 2000 2001 2002 2003 2004 5-Year Average

Unit 1 10 31 28 27 29 25

Unit 2 41 22 32 29 29 31

Unit 3 33 23 6 34 21 23

3.2 DESCRIPTION OF COOLING WATER INTAKE STRUCTURE 

One CWIS at Scattergood Generating Station serves all three units. The CWIS includes a 

single offshore intake pipe with velocity cap located approximately 1,600 feet (ft) offshore 

(Figure 2). The ocean bottom surrounding the intake is at elevation2 (El.) -29.0 ft (Figure 3). 

The top lip of the intake riser is at a depth of El. -11.0 ft. The concrete pipe extends 13.0 ft 

above the sea floor. A circular velocity cap was installed in 1974 to replace the cap from the 

original 1958 construction, which was severely damaged in a large storm. The concrete cap 

has a radius of 16.3 ft with a 5 ft opening between the bottom of the cap and the top of the 

intake riser. The velocity cap redirects the intake flow from a vertical direction to a 

horizontal direction. Water flows through the velocity cap, down a 17.5 ft internal diameter 

vertical riser pipe, and into a 12.0 ft internal diameter intake pipe that conveys the water to 

the onshore screen structure. 

The intake pipe is connected to an inlet chamber configured in a 68.8 ft long, 60° wide arc 

(Figures 4 and 5). The length of the intake pipe from the velocity cap to the inlet chamber is 

2,100 ft (Figure 2). Water entering the inlet chamber is redirected by guide vanes into the 

eight trash rack bays (Figure 4). These trash racks prevent large debris from reaching the 

traveling screens. Each trash rack bay is 6 ft wide, with a bottom located at El. -23.5 ft, and 

extends to El. 12.0 ft. The trash racks are vertical 3/8-inch by 4-inch steel bars centered 5 

inches apart. 

Traveling water screens are positioned 30 ft downstream of the trash rack (Figures 4 and 5). 

The screens are 6.0 ft wide and have a bottom elevation of El. -23.5 ft. The traveling screens 

have a rectangular 3/8-inch by 3/4-inch mesh pattern and are rotated and washed every eight 

hours. Each screen is washed by internal and external spray nozzles that spray debris from

the descending screen panels into two troughs that lead to debris basket pits located on either 

side of the structure. 

The circulating water pumps are located 25 ft downstream of the traveling screens (Figures 4 

and 5). Units 1 and 2 each have two circulating water pumps, while Unit 3 has four pumps. 

 2

 All elevations refer to mean sea level. 

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The Units 1 and 2 pumps are each rated at 86.9 cubic feet per second (cfs) [39,000 gallons 

per minute (gpm)], while the four pumps for Unit 3 are each rated at 104.7 cfs (47,000 gpm). 

The total circulating water flow for Scattergood Generating Station is 766.5 cfs (344,000 

gpm). 

After passing through the condensers, warmed water is discharged into a 12 ft internal 

diameter pipe that runs 1,200 ft offshore parallel to the intake pipe. The discharged water 

exits through a 7.5 ft diameter vertical riser located 400 ft away from the intake velocity cap. 

The cooling water is heat treated approximately once every eight weeks to prevent condenser 

biofouling. This is done by recirculation of the cooling water through the system. The 

circulated water is maintained at a temperature of 115°F for 1 hour and 40 minutes. Each 

cooling water pipeline is also injected with liquid chlorine for 40 minutes per day per shift. 

Chlorine levels in the discharge water are kept within the limits of the NPDES permit. 

3.3 EXISTING HYDRAULIC CONDITIONS 

Scattergood Generating Station CWIS is located within the near-shore zone of the Pacific 

Ocean (Figure 2). The near-shore zone is defined as the zone between the shoreline and 

1,000 ft from shore or the 30-ft depth contour, whichever is farther. The horizontal velocity 

at the velocity cap opening is approximately 1.5 feet per second (ft/s) assuming uniform flow 

distribution. The velocities in the intake pipe are 6.8 ft/s. The calculated approach velocity to 

the traveling screens is 0.6 ft/s for Units 1 and 2 and 0.7 ft/s for Unit 3. All velocities were 

calculated at full flow conditions (766.5 cfs) and mean lower low water (El. 0.0 ft). Intake 

structure characteristics, formulas, and velocity calculations for Scattergood Generating 

Station are provided in Appendix B. 

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FIGURE 2 

SITE CONFIGURATION OF SCATTERGOOD GENERATING STATION 
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FIGURE 3 

PLAN AND SIDE VIEWS OF SCATTERGOOD GENERATING STATION INTAKE OFFSHORE V
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FIGURE 4 

PLAN VIEW OF SCATTERGOOD GENERATING STATION 

ONSHORE INTAKE STRUCTURE

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FIGURE 5 

SIDE VIEW OF SCATTERGOOD GENERATING STATION ONSHORE INTAKE STRUC
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3.4 APPLICABLE PERFORMANCE STANDARDS 

The Rule requires facilities that withdraw cooling water greater than 50 mgd from waters of

the United States and that have a capacity utilization that exceeds 15% to meet both the 

Rule’s IM&E reduction standards of 80-95% and 60-90%, respectively. Since Scattergood 

Generating Station withdraws more than 50 mgd of cooling water and has a 5-year average 

capacity utilization factors ranging from 23-31% for its three units, it is subject to both the 

IM&E reduction performance standards. 

3.5 CONFORMANCE WITH THE CALCULATION BASELINE 

Scattergood Generating Station CWIS does not conform to the Rule’s calculation baseline. 

Significant deviations from the calculation baseline are: 

• The intake is offshore rather than located at the shoreline; 

• The intake is submerged rather than located at or near the surface; and 

• The intake design includes use of a velocity cap. 

The Rule allows facilities to take credit for deviations from the calculation baseline if it can 

be demonstrated that these deviations provide the benefit of fish protection to impingeable 

sized organisms. Opportunities to take a credit are discussed in the next section. 

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4.0 COMPLIANCE ALTERNATIVES TO BE EVALUATED 

LADWP intends to evaluate the full range of Compliance Alternatives and options available 

in the Rule for potential use in the CDS. However, LADWP also has certain preferences for 

compliance because some options are considered to be more feasible, cost-effective, and 

environmentally beneficial than others. This section of the PIC provides a description of 

specific alternatives and options that will be evaluated for compliance. It also indicates 

LADWP’s preferred Compliance Alternatives and options based on currently available 

information, as well as some of the issues currently identified with these alternatives and 

options. 

4.1 TAKING CREDIT FOR EXISTING USE OF FISH PROTECTION 

TECHNOLOGIES AND OPERATIONAL MEASURES UNDER THE RULE’S 

CALCULATION BASELINE – COMPLIANCE ALTERNATIVE 2 

The Rule specifically entitles facilities to take credit for deviations from the calculation 

baseline (described in Section 2) that provide the benefit of fish protection. As discussed in 

Section 3.5, Scattergood Generating Station has a number of facility design and operational 

deviations from the Rule’s calculation baseline that provide the benefit of fish protection. 

These beneficial deviations include use of a submerged offshore intake with a velocity cap 

and overall low capacity utilization. 

4.1.1 Impingement Mortality Reduction Credits 

The original 1958 velocity cap at Scattergood Generating Station’s CWIS was destroyed by a 

storm in April 1970. Subsequently to the storm, Scattergood Generating Station continued 

operation of the CWIS by reversing flow in the cooling water system. The California 

Department of Fish and Game (CDFG) requested that studies be conducted to estimate the 

fish protection benefit of the velocity cap to compare impingement rates without the velocity 

cap to the impingement rates when the original velocity cap was in place. The result of these 

studies indicated a significant impingement reduction benefit and the CDFG requested that a 

new velocity cap be installed. The new velocity cap installed in 1974 on the submerged 

offshore intake for Scattergood Generating Station resulted in a system very similar to that at 

AES’s Huntington Beach Generating Station. 

Site-specific studies were conducted at Huntington Beach Generating Station in 1979 and 

1980 to evaluate the effectiveness of the velocity cap in reducing impingement. A high level 

of fish protection performance was reported for Huntington Beach Generating Station with 

average effectiveness for the two years exceeding the minimum 80% impingement reduction 

performance standard. LADWP plans to conduct similar studies at Scattergood Generating 

Station to verify site-specific performance and credit towards the performance standards. A 

description of the proposed study is provided in Appendix A. 

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4.1.2 Entrainment Reduction Credit 

In addition, the offshore submerged location of the intake may have the benefit of reducing 

entrainment relative to a surface, on-shore location. An evaluation of the potential for an 

entrainment reduction credit for this calculation baseline deviation may also be considered. 

4.2 USE OF RESTORATION UNDER COMPLIANCE ALTERNATIVE 3 

The Rule provides that applicants may use restoration measures in addition to, or in lieu of, 

technology measures to meet performance standards. The basic philosophy of restoration is 

mitigation of fish losses at a CWIS by either direct supplementation (stocking) of a “species 

of concern” potentially impacted by the CWIS, or provision, protection, and restoration of 

habitat that “produces” fish and thereby, replaces those lost due to IM&E. While the use of 

restoration is dependent upon the outcome of Phase II Rule litigation3, LADWP views 

restoration as a preferred method for meeting the entrainment reduction performance 

standard for a number of reasons. The first reason, as discussed in Section 4.3, is a concern 

with the feasibility and/or cost of the available technologies and operational measures to 

meet the entrainment performance standard. The second reason is that LADWP believes the 

environmental benefits of a restoration project are more directly quantifiable and may be 

more environmentally beneficial than the use of technologies and/or operational measures. 

This is due to the fact that a restoration project, such as wetland habitat creation, can provide 

benefits that go beyond offsetting entrainment losses and can provide those benefits over a 

longer period than technologies and/or operational measures. 

Appendix C provides a summary of restoration measures that will be considered. Project 

examples are listed for the following reasons: (1) their 316(b) application history by other 

power companies, (2) known interest in the local area based on an internet review of state 

programs, and (3) because design and implementation information is readily available. The 

basic categories of considered restoration projects are: 

• Habitat Protection or Creation Program; 

• Fish Stocking; and 

• Waterbody Restoration. 

Other types of projects may be identified in discussions with appropriate state and federal 

agencies. 

 3 The Second Circuit ruled that restoration could not be used for compliance with the Clean Water Act

Section 316(b) Phase I Rule. Based on the Phase I Rule litigation decision, USEPA added significant text to 

the Phase II Rule to support its use in Phase II. LADWP plans to initially limit evaluation of this compliance 

option in 2005 to discussions with the LARWQCB and appropriate state and federal fish and wildlife 

agencies to identify potential projects of interest and methods for scaling and verification monitoring related 

to projects of interest. It is LADWP’s current understanding that the Phase II Rule litigation decision should 

be rendered some time in the second quarter of 2006. 

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LADWP plans to discuss these ideas and consider other restoration alternatives that may be 

suggested and will also consider working with other companies with Phase II facilities 

located on Santa Monica Bay to develop joint projects. As part of the requirement for use of 

restoration, LADWP plans to fully evaluate available technologies and/or operational 

measures to determine if in fact restoration is more feasible, cost-effective, or 

environmentally desirable than meeting the performance standards through use of 

technologies and/or operational measures (see Section 4.3). The analysis of IM&E data 

described in Appendix A will be used in determining the amount of restoration necessary to 

provide a minimum benefit equivalent to an 80% impingement mortality reduction and 60% 

entrainment reduction as required by the Rule. 

4.3 USE OF FISH PROTECTION TECHNOLOGIES AND/OR OPERATIONAL 

MEASURES UNDER COMPLIANCE ALTERNATIVES 3, 4, AND 5 

LADWP plans to evaluate a variety of technologies and operational measures for 

compliance. Generally, the cost of technologies required for compliance with the entrainment 

performance standard is significantly more costly than those required for compliance with the 

impingement reduction performance standard. LADWP is using Alden Research Laboratory 

to assist in evaluating fish protection technologies and operational measures. Based on a site 

visit and review of existing facility information, Alden Research Laboratory has provided the 

recommendations for technologies and/or operational measures to be evaluated in this PIC. 

Table 2 is a list of alternative technologies and the potential factors preventing 

implementation. It should also be noted that the entrainment reduction technologies and 

operational measures proposed for evaluation also provide the benefit of impingement 

mortality reduction as well. 

Since LADWP believes that it is likely that Scattergood Generating Station currently meets 

the impingement mortality reduction performance standard (see Section 1 and Section 4.1.1), 

LADWP plans to focus on the evaluation of entrainment reduction technologies and/or 

operational measures. However, if studies confirm that the current design features fail to 

meet the impingement mortality reduction standard, the PIC will be amended as necessary to 

consider such technologies or to consider the use of other compliance alternatives for 

impingement mortality reduction. 

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TABLE 2 

APPLICABILITY OF OTHER TECHNOLOGIES 

Concept Alternatives Mode of Action 

Potential Factors Preventing 

Implementation 

Further 

Consideration 

Behavioral 

Barriers

Sound, infrasound, strobe 

lights, mercury lights, 

chemicals, electric screens, 

air bubble curtain, water jet 

curtain, visual keys, hybrid 

barriers 

Reduce 

impingement through 

behavioral deterrents 

Ineffective with the species 

present in the source 

waterbody 

No 

Physical 

Barriers

Fixed-panel screens, 

traveling water screens, 

rotary drum screens, barrier 

net, bar rack barrier, 

infiltration intakes, porous 

dike, aquatic filter barrier 

(Gunderboom), cylindrical 

wedgewire screens 

Reduce 

impingement by 

physically excluding 

fish from entering the 

intake 

Potential interference with 

navigation, debris, installation 

spatial requirements (size of 

installation), water depth, 

ocean currents 

Yes. Coarsemesh barrier net; 

wide- and 

narrow-slot 

wedgewire 

screens 

Collection/ 

Handling 

Systems 

Modified traveling (Ristroph) 

screens, fish pumps 

Reduce 

impingement 

mortality by 

collecting and/or 

handling fish and 

returning them to the 

source waterbody 

Installation spatial 

requirements, fish and debris 

transport 

Yes. Fine- and 

coarse-mesh 

Ristroph screens 

Diversion 

Systems 

Louvers and angled bar 

racks, angled screens (fixed 

or traveling), angled rotary 

drum screens, inclined plane 

screens, Eicher screen, 

modular inclined screen, 

submerged traveling water 

screen 

Reduce 

impingement by 

diverting fish that 

enter the intake back 

to the source 

waterbody 

Spatial requirements, 

Fish/debris transport 

No 

The Rule specifically identifies three technologies with the potential to provide an 

entrainment reduction benefit. These include use of an aquatic filter barrier, use of cylindrical 

fine mesh (narrow slot) wedgewire screens, and use of fine mesh traveling screens. Presently, 

the aquatic filter barrier has yet to be successfully deployed in a full-scale manner at any 

generating station and demonstrated to be capable of meeting the performance standard. The 

aquatic filter barrier is currently being tested at Mirant’s Lovett Generating Station on the 

Hudson River. During the first year of deployment at Lovett in 2004, the aquatic filter barrier 

tore. The aquatic filter barrier requires a large amount of surface water and use of an air blast 

system to control debris and fouling buildup on the filter fabric. At this point the technology 

is not considered feasible for deployment in an open ocean environment such as Scattergood 

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Generating Station. Therefore, in the event that use of restoration measures is not available to 

offset entrainment losses, the following technologies and operational measures will be 

evaluated. 

4.3.1 Narrow-Slot Cylindrical Wedgewire Screens 

A schematic of this technology is shown in Figure 6. This technology is designed to work by 

using a low through screen velocity relative to the ambient water current velocity. Protection 

of entrainable organisms is a function of the sweeping velocity of the water current past the 

screens relative to the through screen velocity. These screens would replace the existing 

velocity cap. Based on Scattergood Generating Station cooling water flow of 766.5 cfs, 

Alden has estimated that 23 – T84 (i.e., 84-inch diameter) cylindrical wedgewire screen 

modules would be necessary to provide the necessary cooling water flow to Scattergood 

Generating Station. This number of wedgewire screens is based on use of the typical design 

standard using 0.5 millimeter (mm) slots. However, Scattergood Generating Station 

entrainment data will be reviewed to determine if a larger or smaller size would be 

appropriate. The cost of this technology is a function of slot size, since a smaller slot size 

requires use of more or larger screens to provide the same volume of cooling water. In 

addition, the industry standard design for wedgewire screens is a maximum through slot 

velocity of 0.5 ft/s, which would also allow the use of this Compliance Alternative for 

meeting the impingement performance standard. 

To verify the effectiveness for reducing entrainment, LADWP will need to evaluate current 

velocities in the area where the screens would be deployed to confirm there is sufficient 

sweeping velocity past the screen modules to prevent impingement of entrainable organisms. 

While these screens have been deployed at a number of freshwater facilities, they have not 

yet been deployed in marine environments such as the Pacific Ocean. The higher biofouling 

rates in an ocean environment may present feasibility issues for this technology. The 

technology uses compressed air released in a manner to cause a blast of air through the 

screens to control fouling and debris buildup. However, due to the distance offshore that the 

wedgewire screen modules would be located, use of the compressed air system may not be 

feasible. Also due to the high fouling ocean environment, it will be important to ensure that 

the air blast system is adequate or that other fouling control methods are used to ensure an 

uninterrupted supply of cooling water for Scattergood Generating Station. This may include 

conducting pilot studies in the ocean in the vicinity of the facility. 

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FIGURE 6 

NARROW SLOT WEDGEWIRE SCREENS 

4.3.2 Fine-Mesh Ristroph Traveling Water Screens 

LADWP also plans to evaluate replacing the existing 3/8-inch traveling water screens for 

Units 1, 2, and 3 with new 0.5 mm fine-mesh Ristroph screens. This fish protection 

technology is based on first collecting impinged organisms in a manner to maximize survival 

and then returning them to the source waterbody. The technology employs a combination of 

Ristroph fish buckets attached to the bottom of traveling screen panels (Figure 7) and 

replacing the 3/8-inch stainless steel mesh with a fine mesh fabric (Figure 8). 

A low pressure screenwash spray system [~10 pounds per square inch (psi)] is installed to 

wash impinged fish eggs and larvae gently off the screens into the Ristroph buckets. The 

Ristroph buckets then discharge the fish into a fish return system to transport them back to 

the source waterbody in a location away from the intake to prevent them being drawn back to 

the CWIS. Fine-mesh screens are typically designed with an approach velocity of 0.5 ft/s to 

help maximize survival of fish eggs and larvae. 

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Ristroph screens differ from standard traveling water screens in that they operate 

continuously and have additional spray washes. These features prevent debris from building 

up in front of the screens and reduce debris carryover to the condensers. In addition, the finer 

mesh provides a smoother surface than conventional woven wire mesh, potentially increasing 

the effectiveness of the spray washes. 

There are several issues that will need to be evaluated relative to this technology. First, the 

current approach velocity to the traveling screens exceeds the typical design velocity for this 

technology. Currently, the approach velocities are somewhat higher at 0.6 ft/s for Units 1 and 

2 and 0.7 ft/s for Unit 3. Due to the higher velocities it will be essential to perform

laboratory and/or field studies to verify that the survival of organisms that would otherwise 

be entrained is adequate to meet the entrainment reduction performance standard. If 

impingement survival of entrainable organisms is low at the current velocities, the 

screenhouse would need to be expanded to accommodate additional screens necessary to 

reduce the approach velocity. Such an expansion would require each unit to be shut down for 

a substantial amount of time and would require considerable site work. Second, due to the 

location of the existing traveling screens onshore, impinged and entrainable organisms 

collected will have to be transported a considerable distance to a safe release point. Third, 

results of the entrainment study may indicate that a screen mesh size other than 0.5 mm is 

necessary to meet the entrainment reduction standard. Screen mesh sizes used to prevent 

entrainment can possibly adversaly affect plant operation and reliability. Furthermore, finer 

mesh sizes may affect velocity and cost. Finally, species and associated life stages tend to 

vary considerably in terms of their ability to tolerate the collection and handling associated 

with this option, again emphasizing the need for species and life stage specific testing to 

verify survival rates. For these reasons, and especially if expansion of the intake and 

installing more Ristroph screens are required, this option may not be a cost-effective solution 

under Compliance Alternative 5. 

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FIGURE 7 

RISTROPH SCREEN BUCKETS ATTACHED TO BOTTOM 

OF TRAVELING SCREEN PANELS 

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FIGURE 8 

EXAMPLE OF FINE MESH SCREEN PANELS USED IN 

TEST SETUP AT ALDEN RESEARCH LABORATORY 

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4.3.3 Use of Pilot Studies 

When results of the proposed IM&E sampling are available in early 2007, and if the use of 

restoration measures is not available, LADWP may decide to comply using one or a 

combination of technology and/or operational measures. LADWP may propose pilot studies 

in the 2006/2007 time frame to verify performance. Due to the high cost of pilot studies, they 

would not be implemented unless use of restoration is not available. 

4.3.4 Use of Operational Measures 

If use of restoration measures is not available, LADWP will also consider using reduced flow 

on a diel or seasonal basis. It is important to note that the primary function of Scattergood 

Generating Station is to generate electric power in response to LADWP’s generation needs. 

A reduction in cooling water flow has the potential to affect generation output. However, 

depending on the results of the proposed entrainment study and the primary periods of diel or 

seasonal entrainment, LADWP may consider operational measures. Any flow limitation 

from a permitting standpoint must be limited to a reduction over the term of the permit so as 

to ensure that, at any specific time, Scattegood Generating Station has the flexibility to 

operate at full load in order to meet LADWP’s generation needs. 

4.4 USE OF AN APPROVED TECHNOLOGY UNDER COMPLIANCE 

ALTERNATIVE 4 

Currently, use of wedgewire screens in rivers that meet certain criteria is the only USEPA 

“approved design and construction technology.” However, the Rule provides a process that 

allows additional technologies to become listed as pre-approved technologies. New 

technologies can be so designated by providing information to demonstrate that if installed in 

the waterbody type, the technology would have little trouble meeting the performance 

standard for which they are approved. Now that the Rule is in place, a good deal of interest 

has been generated in developing new fish protection technologies. LADWP is actively 

monitoring the development and testing of new technologies for potential use. If other 

technologies more effective in terms of fish protection efficacy and cost-effectiveness 

become available, LADWP will contact the LARWQCB to recommend it for public review 

and comment as required for the addition of new “approved design and construction 

technologies” (under Compliance Alternative 4), and LADWP will inform the LARWQCB 

that the new technology may be added to the PIC for evaluation at Scattergood Generating 

Station. 

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4.5 USE OF SITE-SPECIFIC STANDARDS UNDER COMPLIANCE 

ALTERNATIVE 5 

LADWP plans to evaluate potential use of both the cost-cost and cost-benefit tests under 

Compliance Alternative 5 for use at Scattergood Generating Station. Use of this alternative is 

provided to allow Phase II facilities to not incur costs that would be considered significantly 

greater than either the costs estimated by USEPA for facilities or the economic value of the 

site-specific environmental benefits that will be achieved. Should the evaluation of the 

current impingement reduction technologies and operational measures determine that the 

impingement performance standard is not met, or if the use of restoration for offsetting 

entrainment losses is not available, these tests will be used in conjunction with the evaluation 

of technologies and operational measures discussed previously in the PIC. 

4.5.1 Evaluation of Cost-Cost Test 

USEPA, in developing the national cost of implementing the Rule, considered the cost for 

each Phase II facility to comply. If the actual cost estimated for a facility to meet the 

performance standard, based on a site-specific analysis, is determined to be significantly 

greater than the cost estimated by USEPA for the facility to comply, the facility can apply for 

a site-specific standard under the cost-cost test using Compliance Alternative 5. The sitespecific standard would be that achieved by the use of the best performing technology (i.e., 

achieve the highest level of protection) or operational measure that would pass the cost-cost 

test. In the Rule, Scattergood Generating Station is identified by the USEPA as facility 

number AUT0068, and assigned a cost of NA. USEPA, in the preamble of the Rule, makes 

the following statement regarding facilities assigned NA: 

“Note that some entries in Appendix A have NA indicated for the EPA assumed 

design intake flow in column 2. These are facilities for which EPA projected that they 

would already meet otherwise applicable performance standards based on existing 

technologies and measures. EPA projected zero compliance costs for these facilities, 

irrespective of design intake flow, so no flow adjustment is needed. These facilities 

should use $0 as their value for the costs considered by EPA for a like facility in 

establishing the applicable performance standards.”4

Consistent with the Rule, LADWP plans to use $0 assigned for the cost of Scattergood 

Generating Station in evaluating the cost-cost test. 

 4 Federal Register, Vol. 69, No. 131, 7/9/04, pg. 41646, column 3, 2nd Paragraph. 

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4.5.2 Evaluation of Cost-Benefit Test 

The economic value of the environmental benefit of meeting the performance standards will 

also be evaluated. This evaluation will include the cost of any additional impingement 

mortality reduction technologies needed to make up any shortfall after taking credit for the 

offshore submerged intake and velocity cap. It will also include evaluation of the costs of

meeting the entrainment performance standard (again after taking any credits as a result of 

baseline deviations that can be demonstrated to provide the benefit of fish protection) and the 

resulting benefit of meeting the entrainment standard. The approach for this analysis is 

discussed in Appendix D. 

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5.0 BIOLOGICAL STUDIES 

The Rule requires that a summary of historical IM&E and/or physical and biological studies 

conducted in the vicinity of the CWIS be provided, as well as plans for any new IM&E 

studies. 

One year of biweekly entrainment sampling was conducted at Scattergood Generating 

Station starting in 1978 and ending in 1979. Most sampling events consisted of both day and 

night samples. The results provided an estimate of equivalent adult losses for target species. 

The species in terms of losses were croakers (that could not be identified to species), 

silversides, queenfish, white croaker, and anchovies. One year of impingement sampling was 

also conducted starting in 1978 and ending in 1979. Queenfish, white croaker, walleye 

surfperch, and white seaperch were the dominant species impinged. 

In 1997, an analysis of heat treatment data from 1989 – 1995 was conducted to update the 

assessment of impingement levels. In fact, heat treatment surveys have been conducted since 

the 1970s. During the last six years there has been an average of six heat treatments per year. 

Since 1990, the fish species primarily affected by the operation of Scattergood Generating 

Station have been nearshore schooling/aggregating species, such as topsmelt (27%), 

queenfish (24%), Pacific sardine (21%), jack mackerel (7%), jacksmelt (6%), white croaker 

(4%), and northern anchovy (3%). These seven species combined accounted for 92% of 

impingement abundance at Scattergood Generating Station. The remaining 94 taxa each 

contributed 2% or less to the 15-year impingement total.

Most recently ichthyoplankton data were collected between mid-May and mid-July of 2004 

in preparation for entrainment studies to be initiated under the Rule. Abundance near the 

Scattergood Generating Station intake was dominated by unidentified gobies (79%), 

combtooth blennies (6%), queenfish (5%), and northern anchovy (5%). A detailed summary 

of all of the historical studies and major findings is presented in Appendix A. 

LADWP plans to initiate a new IM&E study in 2006 to establish the IM&E baseline as 

required for the CDS because no recent IM&E data have been collected over a full year of 

operations. These studies will include a study to quantify the credit toward the performance 

standards as a result of the calculation baseline deviations discussed in Sections 2 and 3. 

Reverse flow studies will be conducted at Scattergood Generating Station and used as the 

basis to estimate credit for the submerged offshore intake and velocity cap in terms of the 

fish protection benefit it provides. In addition, a source waterbody study of entrainable life 

stages is a component of the overall study plan for use in scaling a restoration project to 

offset the estimated proportional loss of marine life since this is currently the preferred 

Compliance Alternative. Should the Phase II Rule litigation court decision determine that use 

of restoration measures not be allowed, the source waterbody study of entrainable life stages 

may be terminated. Final data analysis decisions will be made as appropriate to support the 

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Compliance Alternative(s) and option(s) selected. A detailed description of the existing 

IM&E data, biological and physical information, and plans for new biological studies and 

analytical approaches are also provided in Appendix A. 

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6.0 SUMMARY OF PAST OR ONGOING CONSULTATIONS 

WITH AGENCIES 

The Rule requires that “a summary of any past or ongoing consultations with appropriate 

Federal, State, and Tribal fish and wildlife agencies that are relevant to the CDS and a copy 

of written comments received as a result of such consultations be provided.” 

Subsequent to the consultation with CDFG in the early 1970s regarding the 

repair/replacement of the velocity cap that was destroyed by a storm in April 1970, LADWP 

has had no discussions with state or federal fish and wildlife agencies regarding Clean Water 

Act Section 316(b) issues relative to Scattergood Generating Station. 

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7.0 SCHEDULE FOR INFORMATION COLLECTION 

The Rule allows facilities with NPDES permits that expire within four years of the date of

publication of the Rule in the Federal Register (July 9, 2004), up to three years and six 

months to submit the CDS (125.95(2)(ii)). LADWP submitted a letter to the LARWQCB on 

November 4, 2004, requesting approval of a schedule to prepare and submit the PIC, conduct 

necessary studies, and prepare and submit the CDS. The letter requested approval to submit 

the CDS for Scattergood Generating Station in January 2008, which is consistent with the 

final date for submittal in the Rule. This section provides further discussion in support of the 

rationale for that schedule. 

As noted in Section 4, LADWP is planning to initiate new IM&E studies in 2006. Assuming 

that the LARWQCB provides comments within the 60-day period suggested in the Rule, 

LADWP will make any necessary changes to modify the PIC within 30 days and provide a 

revised PIC to the LARWQCB. The first major task will be to complete the IM&E 

Characterization Study and analyze the data. Completing this analysis is critical in order for 

LADWP to make a final decision on Compliance Alternatives. It is anticipated that after 

sampling has been completed, four months will be required to conduct the analysis (second 

quarter of 2007). Upon PIC approval, LADWP will also initiate work and discussions with 

appropriate state and federal agencies to identify potential restoration projects of interest for 

use under Compliance Alternatives 3 and/or 5. 

It is expected that, based on the final litigation schedule, the Court will issue a decision on 

the ongoing Phase II litigation around the end of the second quarter of 2006. This will allow 

LADWP to reassess available Compliance Alternatives and options based on the Court’s 

decision. If LADWP’s preferred use of restoration is not available for IM&E, it is anticipated 

a more detailed evaluation of alternative technologies, including pilot studies, may be 

initiated in the latter part of 2006. Based on completion of analysis of the biological data in 

2007, if restoration is available, LADWP should be in a position to consider a final 

compliance decision in mid to late 2007 in terms of project details to be incorporated into the 

CDS. If restoration is not available, the CDS is anticipated to focus on technologies and/or 

operational measures under Compliance Alternatives 3, 4, and/or 5. 

Preparation of the CDS will depend on the final Compliance Alternative(s) selected as 

follows: 

• Use of Technologies or Operational Measures – It is anticipated that it will require 

approximately six months after results of any pilot studies to review and complete a 

draft and final CDS based on the technology and compliance assessment information 

(i.e., Design and Construction Technology Plan and Technology Installation and 

Operation Plan). 

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• Use of Restoration – If LADWP’s preferred approach of using restoration measures 

is available, work will be initiated to prepare a restoration plan. It is anticipated that 

preparation of this plan and providing the information necessary to address the 

requirements necessary for this plan will also require six months. It is, therefore, 

likely that a final CDS based on restoration can be submitted by January 2008. 

• Use of Site-Specific Standards – Should use of Compliance Alternative 5 be a 

component of the CDS, it will be necessary to prepare a Comprehensive Cost 

Evaluation Study and, if the Cost-Benefit test is used, a Benefit Valuation Study will 

be required. In addition, if a technology or operational measure is used as part of 

Compliance Alternative 5, the technology and compliance assessment information 

documents will also be required. Thus, the full allowable schedule will be necessary. 

Therefore, the final CDS will be submitted by January 2008. 

The Rule recognizes that the CDS studies are an iterative process5

 and allows facilities to 

modify the PIC based on new information. LADWP may request LARWQCB approval of an 

amendment to this PIC, based on new information relative to technologies and operational 

measures, use of restoration measures, Phase II Rule litigation, or subsequent agency 

guidance. Such information may also require modification of the currently proposed 

schedule. 

 5

 See Rule preamble first column pg 41235 of Federal Register/Vol. 69, No. 131/Fri 7/9/04. 

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APPENDIX A 

SUMMARY OF EXISTING PHYSICAL AND BIOLOGICAL INFORMATION 

AND IM&E CHARACTERIZATION STUDY SAMPLING PLAN
Scattergood Generating Station 

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APPENDIX B 

VELOCITY CALCULATIONS
APPENDIX B 

SCATTERGOOD GENERATING STATION VELOCITY CALCULATIONS 

DATA: 

Flow (Q): 

Units 1 & 2: 173.8 cfs (each) 

Units 3: 418.8 cfs 

Total: 766.5 cfs 

Water Elevation: El. 0.0 ft 

Velocity Cap Diameter: 32.5 ft 

Opening Height: 5.0 ft 

Intake Pipe Internal Diameter: 12.0 ft 

Intake Pipe Area: 113.0 ft2 

Number of Intake Pipes: 1 

Screen Width: 6.0 ft 

Number of Bays: 

Units 1 & 2: 2 per unit 

Unit 3: 4 

Screenhouse Invert: El. -23.5 ft 

FORMULA USED 

( )

( ) ( ) A areaQ flow V velocity =

CALCULATIONS 

1.5 /sec

5 *32.5 *

766.5 ( ) ft ft ftcfs V Velocitycap = = π

6.8 /sec

113.0

766.5 ( ) 2 ft ftcfs V Intakepipes = =

0.6 /sec

2*6 *(0.0 23.5 )

173.8 ( 1& 2 ) ft ft ft ft

cfs V Units screens = + =

0.7 /sec

4*6 *(0.0 23.5 )

418.8 ( 3 ) ft ft ft ft

cfs V Unit screens = + =

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APPENDIX C 

RESTORATION MEASURES 
APPENDIX C 

Restoration Measures to be Evaluated for Clean Water Act Section 316(b) Compliance 

at LADWP’s Scattergood Generating Station 

The Phase II Final Rule provides that applicants may use restoration measures in addition to, 

or in lieu of, technology measures to meet performance standards or in establishing best 

technology available on a site-specific basis. Specifically, USEPA’s Rule states the following 

requirement relative to the use of the restoration approach: 

Facilities that propose to use restoration measures must demonstrate to the 

permitting authority that they evaluated the use of design and construction 

technologies and operational measures and determined that the use of restoration 

measures is appropriate because meeting the applicable performance standards or 

requirements through the use of other technologies is less feasible, less cost-effective, 

or [emphasis added] less environmentally desirable than meeting the standards in 

whole or in part through the use of restoration measures. 

Types of Restoration Applicable to §316(b) 

The Rule does not specify the types of restoration measures that can be used. This lack of 

specification provides flexibility in developing/proposing a restoration approach. Restoration 

measures that have been used at other power stations to meet §316(b) requirements under 

state regulatory programs include: 

• Wetland restoration [e.g., Public Service Electric & Gas (PSEG) Delaware Bay wetland 

restoration program for the Salem Generating Station] (Weinstein et al. 2001). 

• Fish stocking [e.g., Mirant Mid-Atlantic fish hatchery at the Chalk Point Station] (Bailey 

et al. 2000); Exelon’s (formally Commonwealth Edison) walleye hatchery at Quad Cities 

Station on upper Mississippi River (LaJeone and Monzingo 2000); and Southern 

California Edison’s (SCE’s) white sea bass hatchery. 

• Submerged aquatic vegetation restoration [e.g., SCE’s kelp restoration for the San 

Onofre Nuclear Generating Station (SONGS)] (Deysher et al. 2002). 

• Provision of fish passage (e.g., fish ladders or dam removal) at non-hydropower projects 

(e.g., PSEG fish ladders in Delaware Bay tributaries for the Salem Generating Station). 

• Contribution to, or maintenance of, a restoration fund for impacts associated with the 

re-powering of the Moss Landing Station on Elkhorn Slough near Monterey Bay, 

California – see http://www.dukeenergy.com/businesses/plants/own/us/western/morrobay/reports/. 

• Water quality improvements (e.g., riparian area protection or implementation of nonpoint source best management practices) that minimize sediment/pollutant runoff thereby 

resulting in fishery habitat improvements, and practices that increase dissolved oxygen 

content in waterbodies thereby increasing available habitat for fish spawning and 

survival. While this approach is plausible, there are no known existing examples of such 

a §316(a) or §316(b) restoration project. 

Scattergood Generating Station Proposal for Information Collection C-1 
APPENDIX C 

Potential Restoration Measures for LADWP California Facilities 

LADWP may wish to consider the following example restoration projects6 to attain the 

IM&E reduction performance standard or as part of a site-specific standard developed by the 

permit director. These projects are listed because of their known interest to fish and wildlife 

agencies in California and because design and implementation information is readily 

available: 

• Fish Stocking. While forage species (e.g., gobies, anchovies, sardines) are the most 

common species impacted at California power plants, stocking of these species to 

compensate for the losses would likely not be of interest to any of the federal and state 

fish and wildlife agencies. The objective of a supplementation program would be to 

identify a ‘species of concern’, the stocking of which would compensate (‘comparable to, 

or substantially similar to’) for the production foregone as measured by a game fish’s 

consumption (e.g., X northern anchovy are equivalent in energy or food consumption to 

Y white sea bass or other recreational or commercial fishes of concern). This is the 

approach used by Potomac Electric Power Company for estimating annual hatchery 

production of striped bass to compensate for bay anchovy (a forage species) losses at 

their Chalk Point Generating Station on the Patuxent River in Maryland. 

Fish stocking involves the direct supplementation (stocking) of a fish species of concern 

to aid restoration efforts for that species. Restoration stocking (as opposed to recreational 

gamefish stocking) is generally pursued where the species of interest has been completely 

extirpated or where associated habitat restoration is unlikely to contribute to stock 

restoration. For example, the Georgia Department of Natural Resources (GDNR), 

following six years of study, recently initiated a long-term effort to restore lake sturgeon 

to the Coosa River system in Georgia/Alabama. This species is listed as threatened 

throughout the U.S. and has disappeared completely from much of its original range, 

including the Coosa River. Through a collaborative effort between several state and 

federal agencies, GDNR released 1,100 fingerlings to the Coosa River in December 2002 

as the first step towards returning lake sturgeon to a healthy, self-sustained population in 

the river. See http://georgiawildlife.dnr.state.ga.us/content/displaycontent.asp?txt 

Document=305). 

A similar program may be of interest in California, particularly for the southern steelhead 

salmon or coastal rockfishes (Sebastes spp.), both of which are federal and state listed 

endangered and threatened species along the California coast. See http://ecos.fws.gov/ 

tess_public/TESSWebpageUsaLists?state=CA). 

The CDFG and LARWQCB [and United States Fish and Wildlife Service 

(USFWS)/National Marine Fisheries Service (NMFS)] may support LADWP’s 

 6

 Projects listed are examples – opportunities for creative restoration projects are unlimited and depend upon 

corporate interests and negotiations with state and federal resource agencies. 

Scattergood Generating Station Proposal for Information Collection C-2 
APPENDIX C 

participation in a program to restore rare, threatened, and endangered fish to native 

habitat. Mirant Mid-Atlantic Inc. currently raises and stocks Atlantic sturgeon at its Chalk 

Point Hatchery Facility on the Patuxent River for the State of Maryland, Department of

Environmental Protection. American shad restoration to the Susquehanna River basin in 

Maryland/Pennsylvania has been accomplished in part via stocking of juvenile shad and 

via provision of fish passage (St. Pierre 2003; Hendricks 1995). Restoration stocking 

(e.g., for southern steelhead) could also be combined with provision of fish passage (i.e., 

dam removal or fish ladders). This form of restoration is discussed further below. 

Fish stocking program support could be via hatchery operation developed on or off plant 

property (e.g., SCE funds the operation of a fish hatchery in Carlsbad, California for 

culturing and stocking white sea bass). Such a hatchery would be operated and 

maintained under state and federal oversight. Alternatively, LADWP could possibly 

negotiate a direct annual contribution of funds to a state and federal hatchery 

supplementation program or a private foundation. For example, the Hubbs/Sea World 

Research Institute operates the SCE fish hatchery for SONGS mitigation. While hatchery 

or stock supplementation programs can be controversial due to concerns over protection 

of natural genetic integrity, California resource agencies, based on their approval and 

development of SCE’s SONGS Mitigation Project, have supported stocking as 

compensation for fish losses. CDFG and NMFS also have a long-term fish hatchery 

program to support maintenance and restoration of anadromous salmonids in California 

coastal rivers (CDFG/NMFS 2001). California resource agencies’ experience with 

hatchery supplementation may mean that they could be receptive to a hatchery program

established by LADWP as compensation for impingement and entrainment losses at 

LADWP power plants in Southern California. For example, when operating at design 

capacity, the SCE funded hatchery is expected to exceed compensation for the total 

SONGS fish losses estimated by an expert panel created by the California Coastal 

Commission. See http://www.sce.com/sc3/006_about_sce/006b_generation/006b1_ 

songs/006b1c_env_prot/006b1c3_songs_miti/default.htm). 

For approximate cost references, SCE provided $4.7 million in funding for the white sea 

bass hatchery, which began operation in late 1996. Similarly, the Potomac Electric Power 

Company established an aquaculture facility at their Chalk Point Station at a capital cost 

(1990 dollars) of $1 million. Annual operating and maintenance costs have been 

approximately $175,000 to $250,000 depending on the species and number of organisms 

raised and stocked in Maryland waters. 

• Habitat Protection Program Participation. The importance of wetlands, in-stream

habitat, and riparian areas as aquatic habitat for fish and invertebrates, and as habitat for 

wildlife is reviewed in EPRI (2003). Wetland restoration or habitat restoration in general, 

is becoming increasingly popular across the U.S. and there is a growing case history with 

use of habitat restoration as a 316(b) mitigation approach (EPRI 2003). In California, 

over 90% of its historic wetlands and 95% of historic streamside trees, shrubs, and 

Scattergood Generating Station Proposal for Information Collection C-3 
APPENDIX C 

ground vegetation has been lost due to urbanization, agricultural conversion, logging, and 

flood control (USFWS 2001). Habitat restoration, therefore, should be of major interest 

to federal and state resource agencies and non-governmental organizations (NGOs) in 

California. The following identifies federal, state, and private restoration programs that 

provide information which LADWP may consider for establishing their own restoration 

program or offer opportunities to collaborate on potential restoration projects. 

Example programs include: 

 SCE’s SONGS Mitigation. The proximity of SONGS and its ongoing restoration 

program is a key starting point relative to any restoration project initiated by LADWP 

for impacts at its Southern California generating stations. The California resource 

agencies and local NGOs will likely heavily rely on lessons learned during the 

negotiation and development of the SONGS Program. The SONGS Marine 

Mitigation Program is a multi-faceted environmental enhancement program intended 

to mitigate unavoidable impacts to the marine environment resulting from operation 

of the SONGS Units 2&3 cooling water systems. See 

http://www.sce.com/sc3/006_about_sce/006b_generation/006b1_songs/ 

006b1c_env_prot/006b1c3_songs_miti/default.htm.

The program includes: 

 Restoring 150 acres of degraded wetlands at San Dieguito Lagoon to mitigate 

impacts to marine fish populations caused by estimated mortality to fish eggs and 

larvae; 

 Improving the in-plant fish protection systems to increase survival of adult fishes 

which enter the cooling water systems; 

 Constructing an artificial kelp reef to mitigate impacts to the San Onofre Kelp 

Bed (note this was to offset thermal effects); 

 Co-funding a marine fish hatchery program intended as supplementary mitigation 

for kelp impacts; and 

 Funding for Coastal Commission staff oversight and monitoring of these 

mitigation projects. 

SCE is managing the overall mitigation program. Through its Conservation Financing 

Corporation subsidiary, the two largest elements of the mitigation program, the 

wetlands restoration project at San Dieguito Lagoon and the artificial reef at San 

Clemente, are being addressed by an equity alliance with CH2MHILL, an 

environmental management services consulting firm. Conservation Financing 

Corporation finances and oversees implementation of these two mitigation projects. 

Scattergood Generating Station Proposal for Information Collection C-4 
APPENDIX C 

SCE is the plant operator and majority owner of SONGS. SONGS is jointly owned by 

SCE, San Diego Gas and Electric, and the cities of Anaheim and Riverside, which are 

funding the mitigation work. 

SONGS’ owners want to keep interested parties informed about this program, which 

will significantly enhance the region’s marine resources. Through meetings, 

discussions, newsletters, a Web site, and the public hearing process, SCE expects to 

inform and involve the largest possible number of interested parties in the 

development and implementation of the mitigation/enhancement plans. Detailed 

technical progress on implementing and monitoring the SONGS mitigation effort can 

be found in the Proceedings from the Second Annual Public Workshop for the 

SONGS Mitigation Project (Reed et al. 2002). 

Duke Energy’s Morro Bay Modernization Project Habitat Enhancement 

Program. As part of the station modernization, Duke Energy has volunteered to fund 

a program that would reduce sedimentation and the other major factors undermining 

the Bay’s productivity. The concerns for Morro Bay and the target of Duke’s proposal 

are the issues identified by the Morro Bay National Estuary Program’s (MBNEP) 

Comprehensive Conservation Management Plan. Those issues include sedimentation, 

loss of habitat, and nutrient pollution. Duke’s proposal is their preferred alternative to 

CEC staff recommendations for dry cooling. The Central Coast Regional Water 

Quality Control Board (CCRWQCB) staff agrees with Duke’s proposal and believes 

that habitat enhancement would yield greater long-term benefits for the Bay. Duke 

Energy’s proposal would fund habitat enhancement projects authorized by the 

CCRWQCB and managed through professional groups like the MBNEP, which have 

plans and programs to reduce sedimentation and other factors undermining the Bay’s 

productivity. The special value of habitat enhancement is that it not only addresses 

marine biology, but also protects and enhances habitat for birds and other animals and 

sustains important recreational resources for the community. Documents describing 

the program in detail can be downloaded from the noted website. Because of recent 

economic conditions across the U.S., Duke has canceled plans for modernizing the 

Morro Bay Power Station and, as a result, their habitat enhancement project has not 

been implemented. See http://www.duke-energy.com/businesses/plants/own/us/ 

western/morrobay/reports/. 

 PSEG’s Delaware Bay Estuary Enhancement Program. This is the largest 

restoration program the U.S. implemented as compensation for impingement and 

entrainment losses at a power station. Established in 1995, this program was 

negotiated with the New Jersey Department of Environmental Protection as a 

mitigative action for fish losses at the Salem Nuclear Generating Station in lieu of

implementing a closed-cycle cooling system. Principally focused on the restoration of 

approximately 10,000 acres of former salt hay farms to natural estuarine salt marsh in 

the lower Delaware Estuary, the program also includes provision of fish passage in 

Scattergood Generating Station Proposal for Information Collection C-5 
APPENDIX C 

combination with some limited fish stocking to support restoration of anadromous 

(American shad and river herring) fish stocks. Details of the program can be found in 

Weinstein et al. (2001). In a following section, the method used by PSEG to scale 

(i.e., convert fish loss to acres of equivalent wetland habitat) the size of the requisite 

restoration project is demonstrated. The PSEG incurred costs to date for the ongoing 

restoration project, including capital, O&M, and monitoring exceed $100 million or 

$9,350/acre (EPRI 2003). 

 Santa Monica Bay Restoration Commission. In recognition of the need to restore 

and protect the Santa Monica Bay and its resources, the State of California and the 

U.S. Environmental Protection Agency established the Santa Monica Bay Restoration 

Project as a National Estuary Program in December of 1988. The Project was formed 

to develop a plan that would ensure the long-term health of the 266 square mile Bay 

and its 400 square mile watershed, located in the second most populous region in the 

United States. That plan, known as the Santa Monica Bay Restoration Plan, won State 

and Federal approval in 1995. Since then, the primary mission has been to facilitate 

and oversee the implementation of the Plan. See http://www.santamonicabay.org/site/ 

aboutus/layout/index.jsp. 

On January 1, 2003 the Santa Monica Bay Restoration Project formally became an 

independent state organization and is now known as the Santa Monica Bay 

Restoration Commission. The Santa Monica Bay Restoration Commission continues 

the mission of the Bay Restoration Project and the collaborative approach of the 

National Estuary Program but with a greater ability to accelerate the pace and 

effectiveness of Bay restoration efforts. Restoration activities are based on a 

comprehensive plan of action for Bay protection and management, known as the Bay 

Restoration Plan, which was approved by Governor Pete Wilson in December of 

1994 and by USEPA Administrator Carol Browner in 1995. The Plan identifies 

almost 250 actions, including 74 priority actions, that address critical problems such 

as storm water and urban runoff pollution, habitat loss and degradation, and public 

health risks associated with seafood consumption and swimming near storm drain 

outlets. The Plan outlines specific programs to address the environmental problems 

facing the Bay and identifies implementers, timelines, and funding needs. 

Implementation of the Plan is the focus of current efforts. Securing and leveraging 

funding to put solutions into action, building public-private partnerships, promoting 

cutting-edge research and technology, facilitating a stakeholder-driven consensus 

process, and raising public awareness in order to restore and preserve the Bay’s many 

beneficial uses are key objectives of the Santa Monica Bay Restoration Commission. 

 National Oceanic and Atmospheric Administration (NOAA) Community-Based 

Restoration Program. This program applies a grass-roots approach to restoration by 

actively engaging communities in on-the-ground restoration of fishery habitats 

around the nation. The Community-Based Restoration Program emphasizes 

Scattergood Generating Station Proposal for Information Collection C-6 
APPENDIX C 

partnerships and collaborative strategies built around restoring NOAA trust resources 

and improving the environmental quality of local communities. The program is: (1) 

providing seed money and technical expertise to help communities restore degraded 

fishery habitats, (2) developing partnerships to accomplish sound coastal restoration 

projects, and (3) leveraging resources through national, regional, and local 

partnerships. This program is one of the services of the NOAA Restoration Center. 

This Center’s mission is to enhance living marine resources to benefit the nation’s 

fisheries by restoring their habitat. Working with others, the Center achieves its 

mission by (1) restoring degraded habitats, (2) advancing the science of coastal 

habitat restoration, (3) transferring restoration technology to the private sector, the 

public, and other government agencies, and (4) fostering habitat stewardship and a 

conservation ethic. Recently, under the community-based program, NOAA awarded 

$250,000 to the Gulf of Mexico Foundation for habitat restoration in the five states 

bordering the Gulf of Mexico. USEPA, under their Gulf of Mexico Program, 

similarly awarded $90,000 to the Foundation. These awards launch a major new 

effort to reclaim essential fish habitats of the Gulf of Mexico by implementing field 

efforts to restore and improve marine and coastal habitats that have been degraded or 

lost. See: http://www.nmfs.noaa.gov/habitat/restoration/. 

 USFWS Partnership for Fish & Wildlife. This program is supported by funds from

federal and state agencies, private landowners, and NGOs (e.g., Ducks Unlimited, 

The Nature Conservancy). The program is a voluntary partnership program with a 

goal to restore wetlands and other vital habitats on private land with 70% of the 

current funding coming from private sources. The remaining funds, along with 

restoration design and technical assistance, are provided by USFWS. State resource 

agencies, such as CDFG, work with the USFWS to help establish priorities and 

identify focus areas. The restoration of degraded wetlands, native grasslands, streams, 

riparian areas, and other habitat to conditions as close as possible to natural is 

emphasized. The Partnership for Fish and Wildlife Program is important for 

restoration of critical habitats in California (USFWS 2001). LADWP financial 

support to the program and potential in-kind service could potentially be negotiated as 

compensation for impingement mortality and entrainment at their power plants in 

Southern California. See http://partners.fws.gov/index.htm.

 Coastal America’s Corporate Wetlands Restoration Partnership (CWRP). This 

program is designed to foster collaboration between the federal government, state 

agencies, and private corporations. Private corporations that participate in this 

national program will donate funds for either site-specific wetland or other aquatic 

habitat restoration projects or provide matching funds to a national or regional effort 

in support of aquatic ecosystem restoration activities. Projects that will receive funds 

from the CWRP will all be approved Coastal America projects, while federal 

agencies will assist in their proper execution. The Coastal America Partnership will 

coordinate among all of its Regional Implementation Teams to identify the 

Scattergood Generating Station Proposal for Information Collection C-7 
APPENDIX C 

appropriate private foundation or state trust fund that will receive funds from the 

CWRP. This organization will not likely accept support in response to regulatory 

requirements. However, the organization is a source of wetland restoration 

information and unique partnerships may be arranged. 

See http://www.coastalamerica.gov/text/cwrpoperating.html. 

 Alternative Restoration Measures. The above measures have been identified as the 

most likely restoration approaches that would be receptive to the LARWQCB and 

other federal and state resource agencies. Other potential approaches include nonpoint 

source pollutant runoff abatement programs and contaminated sediments restoration. 

While these types of efforts focus on water quality improvements, the long-term

benefit is improved fish and shellfish habitat. Such efforts would have to demonstrate 

a clear linkage between the two as compensation for impingement mortality and 

entrainment losses at LADWP’s Southern California power stations. 

The California Coastal Commission is implementing a statewide Nonpoint Source 

Program. See http://www.coastal.ca.gov/nps/npsndx.html. Elements of the program

include management measures for reducing runoff pollution from agriculture, 

silviculture, urban areas, marinas and recreational boating, and via hydromodification 

(includes modification of stream and river channels, dams and water impoundments, 

and streambank/shoreline erosion). The California Coastal Commission, therefore, is 

a source of information for developing potential nonpoint source runoff abatement 

programs or implementing best management practices (BMPs) to meet the goals of 

the State’s plan in the Los Angeles urban and suburban areas. The LARWQCB may 

welcome direct support by LADWP toward implementing some of the BMPs as 

compensation for the impingement (and entrainment losses) at LADWP power plants. 

REFERENCES 

Bailey, D. E., J. J. Loos, E. S. Perry, R. J. Wood. 2000. A retrospective evaluation of 316(b) 

mitigation options using a decision analysis framework. Pages S25-S36 in D. A. Dixon, 

D. E. Bailey, C. Jordan, J. Wisniewski, J. R. Wright, Jr., and K. D. Zammit (Editors). 

Power Plants & Aquatic Resources: Issues and Assessment. Environmental Science & 

Policy 3(Supplement 1). 

CDFG/NMFS. 2001. Final report on anadromous salmonid fish hatcheries in California. Joint 

Hatchery Review Committee, Sacramento, CA. December 3, 2001. A report can be 

downloaded from: http://www.dfg.ca.gov/lands/fish1.html). 

Deysher, L. E., et al. 2002. Design considerations for an artificial reef to grow giant kelp 

(Macrocystis pyrifera) in Southern California. ICES Journal of Marine Science 59: S201-

S207. 

Scattergood Generating Station Proposal for Information Collection C-8 
APPENDIX C 

Duke Energy Morro Bay LLC. 2002. Morro Bay Power Plant Modernization Project. Habitat 

Enhancement Program. Morro Bay, California. Report can be downloaded at 

http://www.duke-energy.com/businesses/plants/own/us/western/morrobay/reports/. 

EPRI. 2003. Enhancement Strategies for Mitigating Potential Operational Impacts of Cooling 

Water Intake Structures: Final Technical Report. Report 1007454. June 2003. Palo Alto, 

CA. 

EPRI. 2002. Guidelines for Selection of 316(b) Assessment Method or Model. Report 

1005176, May 2002. Palo Alto, CA. 

Fox, D. A., J. E. Hightower, and F. M. Parauka. 2002. Estuarine and nearshore marine habitat 

use by Gulf sturgeon from the Choctawhatchee River System, Florida. Pages 111-126 in 

W. Van Winkle, P. Anders, D. Secor, and D. Dixon, editors. Biology, Management, and 

Protection of North American Sturgeon. American Fisheries Society Symposium 28, 

Bethesda, MD. 

Goodyear, C. P. 1978. Entrainment impact estimates using the equivalent adult approach. 

Report No. FWS/OBS-78/65. U.S. Fish and Wildlife Service, Washington, D.C. 

Hendricks, M. L. 1995. The contribution of hatchery fish to the restoration of American shad 

in the Susquehanna River. Pages 329-336 in H. L. Schramm, Jr. and R. G. Piper, editors. 

Uses and effects of cultured fishes in aquatic ecosystems. American Fisheries Society 

Symposium 15, Bethesda, Maryland, USA. 

Jensen, A. L., R. H. Reider, and W. P. Kovalak. 1988. Estimation of production foregone. 

North American Journal of Fisheries Management 8: 191-198. 

Kneib, R. T. 2003. Bioenergetic and landscape considerations for scaling expectations of 

nekton production from intertidal marshes. Marine Ecology Progress Series 264: 279-

296. 

LaJeone, L. J., and R. G. Monzingo. 2000. 316(b) and Quad Cities Station, Commonwealth 

Edison Company. Pages S313-S322 in D. A. Dixon, D. E. Bailey, C. Jordan, J. 

Wisniewski, J. R. Wright, Jr., and K. D. Zammit (Editors). Power Plants & Aquatic 

Resources: Issues and Assessment. Environmental Science & Policy 3 (Supplement 1). 

McCay, D. P. F., and J. J. Rowe. 2003. Habitat restoration as a mitigation for lost production 

at multiple trophic levels. Marine Ecology Progress Series 264: 233-247. 

Peterson, C. H., and R. N. Lipcius. 2003. Conceptual progress towards predicting 

quantitative ecosystem benefits of ecological restorations. Marine Ecology Progress 

Series 264: 297-307. 

Scattergood Generating Station Proposal for Information Collection C-9 
APPENDIX C 

Mettee, M. F., and P. E. O’Neil. 2003. Status of Alabama shad and skipjack herring in Gulf 

of Mexico drainages. Pages 157-170 in K. E. Limburg and J. R. Waldman (Editors). 

Biodiversity, status, and conservation of the world’s shads. American Fisheries Society 

Symposium 35, Bethesda, Maryland, USA. 

NOAA. 1997. Scaling compensatory restoration actions. U. S. Department of Commerce, 

National Oceanic and Atmospheric Administration – Damage Assessment and 

Restoration Program, Silver Spring, Maryland. See also http://www.nmfs.noaa.gov/ 

habitat/restoration/projects_programs/darp/index.html. 

Pejchar, L., and K. Warner. 2001. A river might run through it again: criteria for 

consideration of dam removal and interim lessons from California. Environmental 

Management 28(5): 561-575. 

Peterson, C. H., R. T. Kneib, and C-A. Manen. 2003. Scaling restoration actions in the 

marine environment to meet quantitative targets of enhanced ecosystem services. Marine 

Ecology Progress Series 264: 173-175. 

Peterson, C. H., J. H. Grabowski, and S. P. Powers. 2003. Estimated enhancement of fish 

production resulting from restoring oyster reef habitat: quantitative valuation. Marine 

Ecology Progress Series 264: 249-264. 

Powers, S. P., J. H. Grabowski, C. H. Peterson, and W. J. Lindberg. 2003. Estimating 

enhancement of fish production by offshore artificial reefs: uncertainty exhibited by 

divergent scenarios. Marine Ecology Progress Series 264: 265-277. 

Rago, P. J. 1984. Production foregone: an alternative method for assessing the consequences 

of fish entrainment and impingement losses at power plants and water intakes. Ecological 

Modeling 24: 79-111. 

Reed, D., S. Schroeter, and M. Page. 2002. Proceedings from the second annual public 

workshop for the SONGS Mitigation Project. San Clemente, CA, February 27, 2002. 

Submitted to the California Coastal Commission by the Marine Science Institute, 

University of California, Santa Barbara. April 3, 2002. 

St. Pierre, R. A. 2003. A case history: American shad restoration on the Susquenhanna River. 

Pages 315-322 in K. E. Limburg and J. R. Waldman (Editors). Biodiversity, status, and 

conservation of the world’s shads. American Fisheries Society Symposium 35, Bethesda, 

Maryland, USA. 

Strange, E., H. Galbraith, S. Bickel, D. Mills, D. Belton, and J. Lipton. 2002. Determining 

ecological equivalence in service-to-service scaling of salt marsh restoration. 

Environmental Management 29(2): 290-300. 

Scattergood Generating Station Proposal for Information Collection C-10 
APPENDIX C 

USFWS. 2001. Partners for Fish and Wildlife: California. Partners for Fish and Wildlife 

Program, Sacramento, CA. 

Weinstein, M. P., et al. 2001. Restoration principles emerging from one of the world’s largest 

tidal marsh restoration projects. Wetlands Ecology and Management 9: 387-407 

Scattergood Generating Station Proposal for Information Collection C-11 
Scattergood Generating Station 

Proposal for Information Collection 

APPENDIX D 

PROPOSED METHOD FOR EVALUATION OF ENVIRONMENTAL BENEFITS
APPENDIX D 

Proposal for Information Collection (PIC): Deriving Economic Benefits of Reduced 

Impingement and Entrainment at Scattergood Generating Station 

D.1 BACKGROUND 

For use of the Cost-Benefit test under the site-specific standards, LADWP is required to have 

a Benefits Valuation Study prepared. The Clean Water Act Section 316(b) Phase II Final 

Rule (herein after referred to as the Rule) requires use of a comprehensive methodology to 

value fully the impacts of IM&E at Scattergood Generating Station. Other requirements for 

use of the test include: 

• A description of the methodology(ies) used to value commercial, recreational, and 

ecological benefits (including non-use benefits, if applicable). 

• Documentation of the basis for any assumptions and quantitative estimates. If the 

valuation includes use of an entrainment survival rate other than zero, a determination of 

entrainment survival at the facility based on a study approved by the NPDES permitting 

authority must be submitted. 

• An analysis of the effects of significant sources of uncertainty on the results of the study. 

• If requested by the NPDES permitting authority, a peer review of the items submitted in 

the Benefits Valuation Study. The peer reviewers must be chosen in consultation with the 

Director who may consult with USEPA and Federal, State, and Tribal fish and wildlife 

management agencies with responsibility for fish and wildlife potentially affected by the 

cooling water intake structure. Peer reviewers must have appropriate qualifications 

depending upon the materials to be reviewed. 

• A narrative description of any non-monetized benefits that would be realized at the site if 

the applicable performance standards were to be met and a qualitative assessment of their 

magnitude and significance. 

All benefits, whether expressed qualitatively or quantitatively, should be addressed in the 

Benefits Valuation Study and considered by the NPDES permitting authority and in 

determining whether compliance costs significantly exceed benefits. 

The benefits assessment begins with an IM&E study that quantifies both the baseline 

mortality as well as the expected deviation from the Rule compliance. Based on the 

information generated by the IM&E studies, the benefits assessment includes a qualitative 

and/or quantitative description of the benefits that would be produced by compliance with the 

applicable performance standards at the facility site. To the extent feasible, dollar estimates 

of all significant benefits categories would be made using well-established and generally 

accepted valuation methodologies. 

Scattergood Generating Station Proposal for Information Collection D-1 
APPENDIX D 

In order to have the appropriate information if the benefit/cost option is chosen, we propose a 

strategy for the collection and analysis of economic information. It should be noted that one 

particular benefit category, benefits accruing to individuals even if they have no plans ever to 

use resources associated with Scattergood Generating Station (non-use benefits), are to be 

estimated only: 

In cases where the impingement or entrainment study identifies substantial harm to 

a threatened or endangered species, to the sustainability of populations of important 

species of fish, shellfish or wildlife, or to the maintenance of community structure 

and function in a facility’s waterbody or watershed. (Final Rule, Federal Register

page 41648). 

“Substantial harm” is a stringent requirement to necessitate estimation of non-use values, and 

thus, non-use values usually would not be included in the final analysis. However, because 

the Final Rule does raise the potential for estimation of non-use values, we do provide some

contingency for their estimation. 

The overall approach proposed for use at Scattergood Generating Station is consistent with 

the approach that USEPA used in developing the assessment of the national benefits of the 

Rule as discussed in the Rule’s preamble7

. The USEPA quantified the economic benefit of 

the Rule based on quantification of recreational and commercial fishing benefits. The 

recreational economic benefit uses a region specific random utility model (RUM) based on 

fisherman behavior combined with a benefit function transfer approach. USEPA estimated 

the commercial fishing benefit using a four-step process as follows: 

1. Estimate IM&E losses under current conditions using a linear stock to harvest 

assumption. The percent harvest is based on historical fishing mortality rate data. 

2. Estimating the gross revenue of the lost commercial catch. This was based on use of 

NOAA 1991-2001 landings and dockside price ($/lb) data. 

3. Estimating the lost economic surplus. USEPA assumed a range of 0-40% of the gross 

revenue losses estimated in Step 2 as a means of estimating the change in producer 

surplus. 

4. Estimating the increase in surplus as a result of the Rule. Based on Steps 2 and 3, USEPA 

estimates the percent reduction in IM&E at a regional level. 

The major changes to the USEPA approach to be used in the Scattergood Generating Station 

analysis will be to use more current or site-specific information wherever possible. 

 7

 Federal Register, Vol 69, No 131, 7/9/04, pg 41657. 

Scattergood Generating Station Proposal for Information Collection D-2 
APPENDIX D 

D.2 DESCRIPTION OF METHODOLOGIES TO DETERMINE BENEFITS 

The Rule defines a performance standard that the USEPA has established for all existing 

power plant facilities to meet. Scattergood Generating Station may be subject to the 

impingement mortality performance standard (requiring a reduction in impingement 

mortality of 80-95%) and the entrainment reduction performance standard (requiring a 

reduction in entrainment of 60-90%). However, the Rule states that facilities do not have to 

meet the IM&E performance standards if it can be shown that the costs of achieving the 

performance standards are significantly greater than the benefits. Therefore we are providing 

a plan to collect information in case it is necessary to determine whether the benefits to be 

provided by the identified technology are significantly less than costs. 

Impingement studies were conducted in 1978-1979 and again in 2002 and 2003 (MBC, 

2003). The early studies indicate that queenfish, jacksmelt, northern anchovy, and white 

croaker had the most individuals impinged. At this point in time it is difficult to say which of

the species will be selected as representative for the benefits analysis. The species chosen 

will be based on the planned IM&E studies. When the IM&E studies are done, we will know 

which species are directly or indirectly (through forage fish changes) affected. For now, we 

will consider the typical recreational and commercial species that are caught in and around 

Santa Monica Bay. When better information is available, more specification will be possible 

and be made. It is possible, although highly unlikely, that non-use values will need to be 

addressed. 

The USEPA examined a technology (closed-cycle cooling) to achieve a national standard for 

IM&E. In determining benefits at a national level, USEPA used certain economic concepts of 

benefits associated with using the assets that cooling water adversely affects and the 

methodologies to estimate the benefits (USEPA, 2004a; USEPA 2004b; USEPA 2004c). In 

order to make the benefits comparable to costs, they presented benefits in a monetary unit 

(i.e., dollars). Their benefit estimates reflected the willingness of individuals to pay to go 

from the current environmental status to one associated with an identified technology. 

More specifically, the benefits analysis will seek to provide a unit value per fish caught 

($/fish) for recreational and commercial species affected. With this information, total 

recreational and commercial benefits can be determined by multiplying the unit value times 

the expected increase in recreational and commercial catch arising from the identified 

technology. In addition, some information will be provided with respect to non-use values. 

Scattergood Generating Station Proposal for Information Collection D-3 
APPENDIX D 

D.3 VALUATION OF RECREATIONAL ANGLING ECONOMIC BENEFITS 

For recreational angling, there are two potential ways to quantify benefits: 

1. Benefit Transfer – the application of benefit estimates provided in other studies to 

Scattergood Generating Station. 

2. Primary Research – collection and/or assemblage of data on recreational fishing in the 

Southern California area and use of the data to derive an estimate of the value per fish for 

the important species. 

While the two approaches initially will be discussed independently (i.e., the benefit transfer 

approach is discussed in Section D.3.1 and the primary research is discussed in Section 

D.3.2), there is a sound reason to consider them in concert with one another. That is, the 

benefit transfer information provides a reality check for any values derived in the primary 

research. Conversely, any primary research effort should contain a thorough literature 

review, a component that would have information very similar in nature to the benefit 

transfer analysis. Also, the benefit transfer approach may provide a fallback position if the 

primary research is unsuccessful in providing benefit estimates. After both have been 

discussed independently, a strategy that integrates them will be developed and proposed (see 

Section D.3.3). 

D.3.1 Benefit Transfer Approach 

The use of benefit transfers requires finding a previous economic study (or studies) that 

considers a comparable situation to fishing near Scattergood Generating Station and contains 

dollar values per unit fish caught or a value function for dollar values per unit fish caught. 

Although there are numerous aspects to the benefit transfer valuation, of particular 

importance is having species similar to the affected species and a population similar to the 

local fishing population. 

In order to identify an appropriate study or studies, it would be essential to visit the site to 

examine first-hand the type of recreational fishing that is occurring. At the same time, contact 

with key people in the area will be made to determine if any relevant studies or data do exist 

(see references for some articles). We would consider it essential that the following sources 

be contacted or examined: 

1. State or federal hearings on previous Scattergood Generating Station permit renewals. 

2. State or federal hearings on previous power plant facilities in the general Southern 

California area. 

3. Authors of USEPA “in-house” studies associated with the Final Rule. In particular, 

USEPA’s RUM analysis of the California region (USEPA. 2004d) should be considered. 

Scattergood Generating Station Proposal for Information Collection D-4 
APPENDIX D 

4. Personnel from CDFG. Drs. Dale Squires, Cynthia Thompson and Sam Herrick are 

experts in fisheries economics and management. 

5. Researchers at universities or other research facilities: 

a. University of California, San Diego: Dr. Richard Carson (Department of Economics) 

is an expert in contingent valuation and non-use valuation. 

b. University of California, Berkeley: Dr. Michael Hanneman (Department of 

Agricultural and Resource Economics) is an expert in economic valuation and has 

studied sportfishing in Southern California. 

c. University of California, Los Angeles: Dr. Trudy Cameron is an expert in 

econometrics and has studied sportfishing in California. 

d. Local Consulting firms: Jones and Stokes Inc. (particularly Thomas Wegge) of 

Sacramento completed numerous sportfishing studies in California. 

6. Existing bibliography sources available by internet: 

a. National Marine Fisheries Service, Southeast Fisheries Center 

b. Sportfishing Values Database 

c. Environmental Valuation Reference Inventory: Canadian based 

d. Beneficial Use Values Database 

e. Regulatory Economic Analysis Inventory, which is maintained by the USEPA 

f. ENVALUE, an environmental value database maintained in Australia 

7. Investigation and Valuation of Fish Kills [American Fisheries Society (AFS), 1992] 

Excerpt: “Chapter 4 (“Monetary and Economic Valuation of Fish Kills”) dates back to 

the Pollution Committee’s Monetary Values of Fish booklets of 1970 and 1975, which 

dealt with southern U.S. species. In 1978, the AFS North Central Division’s Monetary 

Values of Fish Committee published Reimbursement Values for Fish, addressing species 

in 12 northern states and 2 Canadian provinces. To integrate these and other regional 

values, a special AFS Monetary Values of Freshwater Fish Committee collected values 

from 135 federal, state, provincial, and private agencies and hatcheries. These data were 

published in 1982 as Part I of AFS Special Publication 13. For the present book, the 

Socioeconomics Section has repeated the earlier survey to update replacement costs for 

killed fish and summarized procedures for estimating the broader economic losses 

resulting from a fish kill.” 

These potential sources will be used to obtain “off-the-shelf” values that could possibly be 

relevant to the affected species at Scattergood Generating Station. In addition, some of these 

contacts may be useful as researchers, data sources, and/or witnesses for any hearings that 

Scattergood Generating Station Proposal for Information Collection D-5 
APPENDIX D 

may occur. They may also be useful as peer reviewers or as sources to identify peer 

reviewers. 

D.3.2 Primary Research 

There are several other methodologies that could be used to estimate economic values for the 

species considered, but they will require some level of primary research. 

Data and programs could be obtained from the USEPA and examined to see if the results 

reported in USEPA (2004d) are defensible. If they are not, a new RUM model could be 

estimated with the data. The major changes introduced in the research would be to consider: 

• Correcting (if necessary) problems associated with the original analysis; 

• Grouping the representative species individually rather than in a general grouping8

; and 

• Specifying that the Scattergood Generating Station site rather than aggregate sites be used 

in the USEPA study (Southern California counties were used as sites). 

The analysis would also update the angling activity and possibly generalize the RUM model 

in ways that current research is including. 

One of the major problems in San Pedro Bay and Santa Monica Bay is the potential for 

harvest of contaminated fish. California’s Department of Health Services issues seafood 

consumption warnings and it will be necessary to consider the effect of sportfish and seafood 

consumption advisories on the value of recreational fish. This was not done in the USEPA 

study (2004d). 

A number of scientific studies and events brought the PCB and DDT contamination of the 

marine waters around Los Angeles to the attention of the press and subsequently the public. 

Some of the first news appeared in the 1970s when, on several occasions, the Food and Drug 

Administration banned the distribution of several species of commercial fish caught in Los 

Angeles coastal waters because of DDT found in fish tissues (Stull, Dryden and Gregory, 

1987). The 1980s produced studies that brought to the public’s attention the potential danger 

from consuming sport caught fish. A 1983 study by Gossett et al. dealt with the 

contamination of sport fish, specifically white croaker, and focused on the body burden of 

PCB/DDT in fish. Based on an intercept survey of sports anglers, Puffer et al. (1982) were 

able to estimate the quantity of certain species of fish consumed by anglers. The Santa 

Monica Bay Seafood Consumption Study (see MBC Applied Environmental Sciences 1993) 

provides evidence that newspapers are an important source of information about sport fish 

 8

 For example, white croaker and queenfish are considered in the category “bottomfish” in previous studies. If 

there were sufficient anglers targeting them, then a category “queenfish and white croaker” could be 

designated. 

Scattergood Generating Station Proposal for Information Collection D-6 
APPENDIX D 

consumption health warnings. In a 1991-1992 field survey, 1248 individuals fishing in the 

Long Beach-Los Angeles Harbor to Paradise Cove area of Los Angeles County were 

interviewed about their fishing activities. Those interviewed were asked the following 

question: 

“Are you aware of any health warnings about eating fish from Santa Monica Bay?” 

Within the questionnaire, Santa Monica Bay is defined as anywhere from Malibu (or Point 

Dume) to Cabrillo Beach (near Long Beach). Of the 1228 answering this question, 942 

people, or 76.7%, responded yes. 

More recently, the California Department of Health Services advised California residents to 

avoid eating shellfish, crabs, sardines and anchovies caught in Morro Bay because these fish 

and shellfish may be contaminated with domoic acid, a naturally occurring toxin that can 

cause illness or death. Warnings regarding mercury in fish have been a common occurrence 

in the California press. 

The literature suggests that unit values are smaller when water quality is so low that states 

must advise anglers against the consumption of sportfish (Jakus, et al. 1997). Additional 

research suggests that the effects of the advisories vary across different types of anglers [e.g., 

anglers interested only in catch and release may actually gain from the advisories] (Jakus et 

al. 1998). Thus, the USEPA model will likely have to be changed to introduce the potential 

for seafood consumption warnings on species, site, and mode choices. 

D.3.3 Strategy to Obtain Recreational Unit Values per Fish Caught 

The initial portion of the benefit evaluation study would be to complete a benefits transfer 

analysis and determine whether or not the values obtained were reasonable for the purposes 

of the decisions to be made. That is, if the mitigation strategy returned recreational benefits 

that were approximately equal to the costs, it may be unwise and inefficient to move onto 

primary research because, in all likelihood, the estimate of costs would not be “significantly 

larger” than the benefits. If, however, the benefit transfer method suggested that the benefits 

were to be small relative to costs, it may or may not be useful to do one of the primary 

research plans suggested in the previous section. The quality of existing studies would also 

be a determinant. 

Discussions with key informants in the benefit transfer work would determine the availability 

and reliability of data from the previous studies of recreational fishing. In addition, some

notion of the potential improvement in estimates from using new data and a new model 

would be obtained. 

With this information and a better understanding on the costs of doing the primary research 

studies, decisions regarding what combination of benefit transfer and primary research would 

Scattergood Generating Station Proposal for Information Collection D-7 
APPENDIX D 

be most advantageous. The primary research would in all likelihood provide better estimates 

of value, but may be more costly. Given the present information, it is likely that the analysis 

performed by the USEPA in 2004 could be augmented and improved sufficiently to provide 

reliable unit values. 

D.4 VALUATION OF COMMERCIAL FISHING ECONOMIC BENEFITS 

The first determination would be whether commercial fishing is affected by reduced 

mortality to affected species. The CDFG and the NMFS would be consulted regarding 

species that the IM&E studies identified. Both producers and consumers could gain from

increases in commercial catch, but the assessment would likely only estimate the gains to 

direct producers (i.e., commercial fishermen). This is based on the expectation that relatively 

small changes in commercial landings result from reduced IM&E mortalities. This is the 

approach that USEPA took in the 2004 study. 

The approach that USEPA uses for assessing commercial benefits to producers bases the unit 

value on the ex-vessel price (sometimes referred to as dockside price) of the species under 

consideration. One could use the ex-vessel price as the unit value and determine benefits as 

the price times the additional harvest caused by the IM&E reductions. The logic of doing that 

rests on the assumption that the additional harvest does not induce increases in effort (inputs 

used in harvesting) after the reductions of entrained and/or impinged organisms. If this were 

entirely true, then the ex-vessel price times the increase in quantity harvested would represent 

producer surplus. However, USEPA appreciates that this would not likely be true and that 

effort and costs would undoubtedly increase in the long run in response to increased 

commercial profits (i.e., producer surplus). In the absence of property rights to the harvest, 

one would expect the producer surplus to be eliminated. Recognizing this and allowing for 

uncertainty in effort response, the USEPA proposes using a range of 0-40% of the ex-vessel 

price times the increase in harvest as a measure of the increase in producers’ surplus. 

Additional economic information on coastal pelagic species (e.g., sardine, anchovy, squid 

and mackerel) and groundfish may be available through the fisheries management groups. 

For example, anchovy has been managed for some time (Huppert 1981) and more recently a 

management plan for the small coastal pelagic species has been developed (Bargmann et al. 

1998). These plans may contain information that would permit an analysis that is an 

improvement to the USEPA approach. 

In the unlikely event that the change in landings would be relatively large and cause a change 

in commercial fisheries prices, we would need to collect information on commercial harvests 

and prices. There is not a good way to use benefit transfer methods for the consumers’ 

surplus although USEPA is exploring one proposed by Bishop and Holt (2003). Presently, 

this approach does not look promising, and it does not appear that the change in commercial 

landings will be sufficiently large to cause prices changes. 

Scattergood Generating Station Proposal for Information Collection D-8 
APPENDIX D 

However, if additional information suggests price changes, existing data from CDFG and the 

NMFS could be sufficient to estimate an inverse, general equilibrium demand curve (see 

Just, et al. 2004 for a description) for the species in question. With these estimates, the 

benefits to consumers could be calculated. 

D.5 NON-USE BENEFIT VALUATION 

Based on current knowledge, it does not appear necessary to estimate non-use values. That is, 

the criteria USEPA proposed in the final ruling for their estimation does not appear to be 

met.

But, in the unlikely event that non-use values will have to be estimated, we would look to 

using a benefit transfer approach or doing primary research for Scattergood Generating 

Station. However, we do not believe that the magnitude of the non-use values would justify 

undertaking a primary research study for non-use values associated with Scattergood 

Generating Station. 

Thus, if non-use values were needed, we would, in all likelihood, suggest using a benefit 

transfer method. There have not been any studies of non-use values associated with power 

plant activities per se. People have had to rely on studies associated with other types of 

activities. For example, USEPA used a benefit transfer approach in their Proposal for the 

316(b) regulations and in the NODA. USEPA (Tudor et al., 2003) reviewed numerous 

studies of use and non-use values that were associated with surface water improvements 

(their Appendix A). Of those shown, only three address both changes in fish populations and 

non-use values associated with them (Huang, et al. 1997; Whitehead and Groothuis 1992; 

Olsen, et al. 1991). 

We propose considering these three studies in addition to doing a review of the recent 

literature. The recent literature may be important because USEPA has placed some emphasis 

on this ecological valuation recently. For example, a meeting entitled “Improving the 

Valuation of Ecological Benefits, a STAR Progress Review Workshop” was held in 

Washington in October, 2004. The papers presented at that workshop are now available on 

the internet, and one of them is directly related to California. 

The results of this activity would likely be the development of a relationship (specifically a 

ratio) between use values and non-use values. For years, USEPA used the 50% rule, a 

practice that implied that non-use values were 50% of use values. Our approach, just like 

some of their 316(b) efforts (Tudor 2003), would be to refine this ratio for situations more 

similar to the changes associated with power plant operations. 

Scattergood Generating Station Proposal for Information Collection D-9 
APPENDIX D 

REFERENCES 

Bargmann, G., D. Hanan, S. Herrick, K. Hill, L. Jacobson, J. Morgan, R. Parrish, J Spratt and 

J. Walker. 1998. Amendment 8 (To the Anchovy Fishery Management Plan) 

incorporating a name change to: The coastal pelagic species fishery management plan. 

Pacific Fisheries Management Council, Portland, OR. 

Bishop, R. and M. Holt. 2003. “Estimating Post-Harvest Benefits from Increases in 

Commercial Fish Catches with Implication for Remediation of Impingement and 

Entrainment Losses at Power Plants”. Unpublished Xerox. University of WisconsinMadison. 10 pp. 

Dotson, R. and R. Charter. 2003. “Trends in the Southern California Sport Fishery”. 

CalCOFI Rep., Vol. 44: 94-106. 

Gosset, R.W., H.W. Puffer, R.H. Arthur, J.F. Alfara, and D.R. Young. Levels of Trace 

Organic Compounds in Sportfish from Southern California in Southern California 

Coastal Water Research Project biennial report, 29-37, Long Beach, Calif., 1981-1982. 

Hanemann, W. M., T. Wegge, and I. Strand. 1989. Development and Application of a 

Predictive Model to Analyze the Economic Effects of Species Availability. National 

Marine Fisheries Service, Southwest Region, Terminal Island CA. Admin. Rpt. SWR 

89-02. June. 

Huang, J. T. Haab, and J. Whitehead. 1997. “Willingness to Pay for Quality Improvements: 

Should Revealed and Stated Preference Data Be Combined?”, Journal of Environmental 

Economics and Management 34: 240-255. 

Huppert D. 1981. “Economic Analysis for Northern Anchovy Management” in Economic 

Analysis for Fisheries Management Plans, L. Anderson, ed., Ann Arbor Science 

Publishers, Inc. Ann Arbor, MI. 

Jakus, P. M., M. Downing, M. Bevelhimer, and J. Fly. 1997. “Do Sportfish Consumption 

Advisories Affect Reservoir Anglers’ Site Choice?” American J. of Agricultural 

Economics 25(3): 196-204. 

Jakus, P., D. Dadakas, and J. Fly. 1998. “Fish Consumption Advisories: Incorporating 

Angler-specific Knowledge, Habits and Catch Rates in a Site Choice Model”, American 

J. of Agricultural Economics 26(2): 1019-1024. 

Just, R.E., D.L. Hueth, and A. Schmitz. 2004. “The Welfare Economics of Public Policy: A 

Practical Approach to Project and Policy Evaluation .” Edward Elgar, Cheltenham UK. 

688 pp. 

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APPENDIX D 

Kling, C. and C. Thomson. 1996. The Implications of Model Specification for Welfare 

Estimation in Nested Logit Models. Am. J. Agr. Econ. 78 (February):103-114. 

MBC Applied Environmental Sciences. 1993. Santa Monica Bay Seafood Consumption 

Study September 1991 to August 1992 Final Draft Report, July 1993. 

McConnell, K.E., Q. Weninger and I. Strand. “Joint Estimation of Contingent Valuation and 

Truncated Recreation Demands,” Chapter in Valuing the Environment Using Recreation 

Demand Models (Eds. Kling and Herriges).Edward Elgar Publishers, Cheltenham, UK. 199-

216. 1999. 

Olsen, D., J. Richards, and R. Scott. 1991. “Existence and Sport Values for Doubling the 

Size of Columbia River Basin Salmon and Steelhead Runs”, Rivers 2(1): 44-51. 

Puffer, H.W., M. J. Duda, and S. P. Azen “Potential Health Hazards from Consumption of 

Fish Caught in Polluted Coastal Waters of Los Angeles County” North American Journal 

of Fisheries Management 2:74-79, 1982. 

Stull, J.K., K.A. Dryden and P.A. Gregory “A Historical Review of Fisheries Statistics and 

Environmental and Societal Influences off the Palos Verdes Peninsula, California” 

CalCOFI Report, XXVIII: 135-154,1987. 

Thomson, C. and S. Crooke 1991. Results of the Southern California Economic Sportfishing 

Survey. NOAA Technical Memorandum, NMFS, Southwest Fisheries Center, August. 

Tudor, L., R. Wardwell, E. Besedin, and R. Johnston. 2003. Comparison of Non-use and Use 

Values from Surface Water Valuation Studies. Memo to the 316 (b) Record. Office of 

Water, USEPA. Washington, D.C. 

USEPA. 2004a. “§316(b) Phase II Final Rule, Regional Studies, Part A: Evaluation Methods, 

Chapter A9: Benefit Categories and Valuation”. http://www.epa.gov/ 

waterscience/316b/econbenefits/final.htm. 

USEPA. 2004b. “§316(b) Phase II Final Rule, Regional Studies, Part A: Evaluation Methods, 

Chapter A10: Methods for Estimating Commercial Fishing Benefits”, 

http://www.epa.gov/waterscience/316b/econbenefits/final.htm. 

USEPA. 2004c. “§316(b) Phase II Final Rule, Regional Studies, Part A: Evaluation Methods, 

Chapter A11: Estimating Benefits with a Random Utility Model”. 

http://www.epa.gov/waterscience/316b/econbenefits/final.htm. 

USEPA. 2004d. “§316(b) Phase II Final Rule, Regional Studies, Part B: California Region, 

Chapter D4: RUM Analysis”. 

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APPENDIX D 

http://www.epa.gov/waterscience/316b/econbenefits/final.htm. 

USEPA. 2004e. “§316(b) Phase II Final Rule, Regional Studies, Part B: California Region, 

Chapter B3: Commercial Fishing Analysis”. 

http://www.epa.gov/waterscience/316b/econbenefits/final.htm. 

Whitehead, J. and P. Groothuis. 1992. “Economic Benefits of Improved Water Quality: A 

Case Study of North Carolina’s Tar-Pamlico River”, River 3(3): 170-178. 

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