2013 VGP and sVGP BE 

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The primary technical contact for this document is: 

Dr. Ryan Albert 

(202) 564-0763 

U.S. Environmental Protection Agency 

Office of Water (Mail Code: 4203M) 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

(202) 564-6392 (fax) 
2013 VGP and sVGP BE Table of Contents 

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TABLE OF CONTENTS 

Page 

SECTION 1 BACKGROUND AND PURPOSE OF CONSULTATION ........................... 1-1

SECTION 2 SCOPE OF PROPOSED ACTIONS ................................................................ 2-1

2.1 Legal and Procedural Background ....................................................................... 2-1

2.1.1 VGP.......................................................................................................... 2-2

2.1.2 sVGP ........................................................................................................ 2-3

2.2 Affected Vessels .................................................................................................. 2-3

2.2.1 Vessels Covered by the VGP ................................................................... 2-4

2.2.2 Vessels Covered by the sVGP ................................................................. 2-6

2.2.2.1 Commercial Fishing Vessels.................................................. 2-7

2.2.2.2 Other Non-recreational Vessels ............................................. 2-8

2.3 Summary Descriptions of the Proposed Permit Actions ...................................... 2-8

2.3.1 2013 VGP................................................................................................. 2-9

2.3.1.1 Vessel Discharges Eligible for Coverage Under the VGP ..... 2-9

2.3.1.2 Effluent Limitations Specified in the VGP .......................... 2-11

2.3.1.3 Inspections, Monitoring, Reporting, and Recordkeeping .... 2-14

2.3.1.4 Summary of Most Significant Changes from 2008 VGP .... 2-14

2.3.2 2013 sVGP Detailed Summary Description .......................................... 2-16

2.3.2.1 Vessel Discharges Eligible for Coverage under the sVGP .. 2-16

2.3.2.2 Effluent Limitations Specified in the sVGP ........................ 2-17

2.3.2.3 Additional Water Quality-Based Effluent Limitations ........ 2-23

2.3.2.4 Recordkeeping and Quarterly Inspections ........................... 2-23 

2.3.3 Summary of Findings from Other Legal Requirements Relevant to the 

Permit Actions in this BE ...................................................................... 2-24

2.3.3.1 Ocean Discharge Criteria ..................................................... 2-24

2.3.3.2 Essential Fish Habitat Consultations ................................... 2-25

2.4 References .......................................................................................................... 2-26

SECTION 3 BIOLOGICAL EVALUATION APPROACH................................................ 3-1 

3.1 Vessel Types Requiring Detailed Analysis.......................................................... 3-3 

3.1.1 VGP Vessels ............................................................................................ 3-3 

3.1.1.1 Barges .................................................................................... 3-4 

3.1.1.2 Oil and Gas Tankers ............................................................... 3-5 

3.1.1.3 Large Commercial Fishing Vessels ....................................... 3-5 

3.1.1.4 Large Cruise Ships ................................................................. 3-5 

3.1.1.5 Medium Cruise Ships ............................................................. 3-6 

3.1.1.6 Large Ferries .......................................................................... 3-6 

3.1.1.7 Cargo [Bulk] and Other Carriers ............................................ 3-6 

3.1.1.8 Emergency and Research Vessels .......................................... 3-6 

3.1.2 sVGP Vessels ........................................................................................... 3-7 

3.2 Vessel Discharges Meriting Detailed Analysis .................................................... 3-9 

3.2.1 Vessel Discharge Selection ...................................................................... 3-9 

3.2.2 Estimated Flow Rates for Discharges Selected for Detailed 

Analysis.................................................................................................. 3-24 
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3.2.2.1 Ballast Water ........................................................................ 3-24 

3.2.2.2 Bilgewater ............................................................................ 3-25 

3.2.2.3 Deck Washdown .................................................................. 3-26 

3.2.2.4 Engine Wet Exhaust Effluent ............................................... 3-27 

3.2.2.5 Exhaust Gas Scrubber Washwater ....................................... 3-28 

3.2.2.6 Fish Hold and Fish Hold Cleaning Effluent ........................ 3-29 

3.2.2.7 Graywater ............................................................................. 3-30 

3.2.2.8 Stern Tube Packing Gland Effluent and Discharges from 

 Other Oil/Water Interfaces ................................................... 3-31 

3.2.3 Pollutants Requiring Detailed Analysis in Selected Vessel 

Discharges .............................................................................................. 3-33 

3.2.3.1 Aquatic Nuisance Species .................................................... 3-33 

3.2.3.2 Nutrients ............................................................................... 3-35 

3.2.3.3 Pathogens ............................................................................. 3-36 

3.2.3.4 Oil and Grease ...................................................................... 3-36 

3.2.3.5 Metals ................................................................................... 3-37 

3.2.3.6 Toxic and Non-Conventional Pollutants with Toxic 

 Effects .................................................................................. 3-40 

3.2.3.7 Conventional and Non-Conventional Pollutants. ................ 3-42 

3.2.4 Summary of Vessel Types, Discharges, and Corresponding 

Pollutants/Constituents Selected for Detailed Evaluation in this BE .... 3-43 

3.3 Selection of Reference Action Areas (RAAs) ................................................... 3-45 

3.4 Listed Species and their Critical Habitats within RAAs .................................... 3-46 

3.4.1 Listed Species That May Be Affected ................................................... 3-46 

3.4.2 Description of Species Within RAAs Used to Support the Effects 

Analysis.................................................................................................. 3-47 

3.5 References .......................................................................................................... 3-50 

SECTION 4 ENVIRONMENTAL BASELINE .................................................................... 4-1 

4.1 Ecosystem Status within RAAs ........................................................................... 4-2 

4.1.1 Ecosystem Status of Puget Sound/ Seattle, WA RAA ............................. 4-2 

4.1.1.1 Ecosystem Description of Puget Sound /Seattle, WA ........... 4-3 

4.1.1.2 Major Land Uses Near Puget Sound/ Seattle, WA ................ 4-3 

4.1.1.3 Vessel Populations Present in Puget Sound/ 

 Seattle, WA ............................................................................ 4-6 

4.1.1.4 Habitat Modification and Restoration in Puget Sound/ 

 Seattle, WA ............................................................................ 4-6 

4.1.1.5 Water Quality Impairments in Puget Sound/Seattle, WA ..... 4-7 

4.1.1.6 Historic ANS Introductions and Impacts in Puget Sound/ 

Seattle, WA ............................................................................ 4-9 

4.1.2 Ecosystem Status of Upper and Lower Bay/New York, NY RAA ....... 4-10 

4.1.2.1 Ecosystem Description of Upper and Lower Bay 

 /New York, NY .................................................................... 4-11 

4.1.2.2 Major Land Uses Near Upper and Lower Bay/ 

 New York, NY ..................................................................... 4-11 

4.1.2.3 Vessel Populations Present in Upper and Lower Bay/New 

York, NY.............................................................................. 4-13 
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4.1.2.4 Habitat Modification and Restoration Near Upper and Lower 

Bay/New York, NY ............................................................. 4-13 

4.1.2.5 Water Quality Impairments in Upper and Lower Bay/New 

York, NY.............................................................................. 4-14 

4.1.2.6 Historic ANS Introductions and Impacts in Upper and Lower 

Bay/New York, NY ............................................................. 4-15 

4.1.3 Ecosystem Status of Galveston Bay/Houston, TX RAA ....................... 4-16 

4.1.3.1 Ecosystem Description of Galveston Bay/ Houston, TX ..... 4-16 

4.1.3.2 Major Land Uses Near Galveston Bay/ Houston, TX ......... 4-18 

4.1.3.3 Vessel Populations Present in Galveston Bay/ 

 Houston, TX ......................................................................... 4-18 

4.1.3.4 Habitat Modification and Restoration of Galveston Bay/ 

Houston, TX ......................................................................... 4-18 

4.1.3.5 Water Quality Impairments in Galveston Bay/ 

 Houston, TX ......................................................................... 4-19 

4.1.3.6 Historic ANS Introductions and Impacts in Galveston 

Bay/Houston, TX ................................................................. 4-21 

4.1.4 Ecosystem Status of Upper Mississippi River at St. Louis, 

 MO RAA ................................................................................................ 4-21 

4.1.4.1 Ecosystem Description of Upper Mississippi River at 

 St. Louis, MO ....................................................................... 4-22 

4.1.4.2 Major Land Uses Near Upper Mississippi River at 

 St. Louis, MO ....................................................................... 4-24 

4.1.4.3 Vessel Populations Present in Upper Mississippi River at 

 St. Louis, MO ....................................................................... 4-25 

4.1.4.4 Habitat Modification and Restoration in Upper Mississippi 

River at St. Louis, MO ......................................................... 4-25 

4.1.4.5 Water Quality Impairments in Upper Mississippi River at 

 St. Louis, MO ....................................................................... 4-26 

4.1.4.6 Historic ANS Introductions and Impacts in Upper Mississippi 

River at St. Louis, MO ......................................................... 4-28 

4.1.5 Ecosystem Status of St. Louis River Estuary/Duluth, MN RAA .......... 4-28 

4.1.5.1 Ecosystem Description of St. Louis River Estuary/ 

 Duluth, MN .......................................................................... 4-30 

4.1.5.2 Major Land Uses Near St. Louis River Estuary/ 

 Duluth, MN .......................................................................... 4-32 

4.1.5.3 Vessel Populations Present in St. Louis River Estuary/Duluth, 

MN ....................................................................................... 4-33 

4.1.5.4 Habitat Modification and Restoration of St. Louis River 

Estuary/ Duluth, MN ............................................................ 4-33 

4.1.5.5 Water Quality Impairments in St. Louis River Estuary/ 

 Duluth, MN .......................................................................... 4-34 

4.1.5.6 Historic ANS Introduction and Impacts in St. Louis River 

Estuary/ Duluth, MN ............................................................ 4-36 

4.1.6 Ecosystem Status of San Francisco Bay Estuary/ 

 San Francisco, CA RAA ........................................................................ 4-37 
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4.1.6.1 Ecosystem Description of San Francisco Bay Estuary 

 San Francisco, CA ............................................................... 4-38 

4.1.6.2 Major Land Uses Near San Francisco Bay Estuary/ 

 San Francisco, CA ............................................................... 4-40 

4.1.6.3 Vessel Populations Present in San Francisco Bay Estuary/ 

 San Francisco, CA ............................................................... 4-41 

4.1.6.4 Habitat Modification and Restoration in San Francisco Bay 

Estuary/ San Francisco, CA ................................................. 4-41 

4.1.6.5 Water Quality Impairments in San Francisco Bay Estuary/ 

 San Francisco, CA ............................................................... 4-42 

4.1.6.6 Historic ANS Introductions and Impacts in San Francisco 

 Bay Estuary/ San Francisco, CA .......................................... 4-46 

4.1.7 Ecosystem Status of Biscayne Bay, Miami, FL RAA ........................... 4-46 

4.1.7.1 Ecosystem Description of Biscayne Bay/ 

 Miami, FL ............................................................................ 4-48 

4.1.7.2 Major Land Uses Near Biscayne Bay/ 

 Miami, FL ............................................................................ 4-49 

4.1.7.3 Vessel Populations Present in Biscayne Bay/ 

 Miami, FL ............................................................................ 4-50 

4.1.7.4 Habitat Modification and Restoration in Biscayne Bay/ 

 Miami, FL ............................................................................ 4-50 

4.1.7.5 Water Quality Impairments in Biscayne Bay/ 

 Miami, FL ............................................................................ 4-51 

4.1.7.6 Historic ANS Introductions and Impacts in Biscayne Bay/ 

Miami, FL ............................................................................ 4-52 

4.2 Factors Affecting Current Status of Listed Species in RAAs ............................ 4-54 

4.3 References .......................................................................................................... 4-90 

SECTION 5 EFFECTS ANALYSIS ...................................................................................... 5-1

5.1 Qualitative Effects Analysis on Pollutants Lacking Specific 

Concentration-Response Related Toxic Effect Thresholds ................................. 5-1

5.1.1 ANS.......................................................................................................... 5-1

5.1.1.1 What are ANS? ...................................................................... 5-2

5.1.1.2 Vessels as a Vector for ANS Introduction ............................. 5-4

5.1.1.3 Ballast Water Discharge ........................................................ 5-4

5.1.1.4 Vessel Biofouling................................................................... 5-8

5.1.1.5 Other Vessel Discharges Potentially Harboring ANS ......... 5-14

5.1.1.6 Mechanisms of Vessel-Mediated ANS Invasions ................ 5-14

5.1.1.7 Examples of ANS Invasions in the U.S. .............................. 5-18

5.1.1.8 Documented Impacts of ANS on Listed Species ................. 5-25

5.1.1.9 Conclusion Regarding Risk of ANS in Vessel Discharge 

Vectors ................................................................................. 5-26

5.1.2 Pathogens ............................................................................................... 5-27

5.1.3 Oil and Grease ........................................................................................ 5-27

5.1.4 Biochemical Oxygen Demand (BOD) ................................................... 5-28

5.2 Methodology for the Quantitative Effects Analysis of Toxic and Nonconventional Pollutants with Toxic Effects ....................................................... 5-28
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5.2.1 Hypothetical Harbor and Estimation of Exposure Concentrations ........ 5-29

5.2.1.1 Hypothetical Harbor Scenarios ............................................ 5-30

5.2.1.2 RAA Loading Scenarios ...................................................... 5-32

5.2.1.3 Receiving Water Model Scenarios ....................................... 5-33

5.2.1.4 Exposure Concentrations ..................................................... 5-34

5.2.2 Effects Data and Estimation of Chronic Toxicity Effect Thresholds 

and Representative RQs ......................................................................... 5-38

5.2.3 Direct Effects Analysis .......................................................................... 5-39

5.2.3.1 Basis of CTET Used to Support Direct Effects to Aquatic 

Listed Species from Water-only Exposure .......................... 5-41

5.2.3.2 Basis of CTET Used to Support Direct Effects to Aquatic 

Listed Species from Multiple Routes of Exposure .............. 5-42

5.2.3.3 Basis of CTET Used to Support Direct Effects to Aquaticdependent Listed Species ..................................................... 5-44

5.2.4 Indirect Effects Analysis ........................................................................ 5-46

5.2.5 Risk Conclusions for All Listed Species ............................................... 5-46

5.2.6 Uncertainties and Limitations in the Effects Analysis ........................... 5-49

5.2.6.1 Estimation of Exposure Concentrations Used to Support 

Effects Analysis ................................................................... 5-49

5.2.6.2 Selection of Chronic Toxicity Values Representative of the 

Sensitivity of Aquatic Organisms ........................................ 5-52

5.2.6.3 Use of Surrogate Species Effects Information for Listed 

Species ................................................................................. 5-53

5.2.6.4 Estimation of Risk for Aquatic-dependent Birds 

 and Mammals ....................................................................... 5-55

5.2.6.5 Representativeness of Results to Other Listed Species ....... 5-56

5.3 Pollutant-Specific Risk Summaries ................................................................... 5-56

5.3.1 Classical Pollutants ................................................................................ 5-57

5.3.1.1 Total Residual Chlorine (TRC) ............................................ 5-57

5.3.1.2 Total Suspended Solids (TSS) ............................................. 5-62

5.3.2 Metals ..................................................................................................... 5-66

5.3.2.1 Aluminum (Total) ................................................................ 5-67

5.3.2.2 Arsenic (Dissolved and Total) ............................................. 5-73

5.3.2.3 Cadmium (Dissolved) .......................................................... 5-79

5.3.2.4 Chromium (Dissolved)......................................................... 5-85

5.3.2.5 Copper (Dissolved) .............................................................. 5-91

5.3.2.6 Lead (Dissolved) .................................................................. 5-98

5.3.2.7 Nickel (Dissolved) ............................................................. 5-104

5.3.2.8 Selenium (Dissolved and Total) ......................................... 5-110

5.3.2.9 Zinc (Dissolved) ................................................................. 5-116

5.3.3 Nutrient and Nutrient-related Toxicity ................................................ 5-122

5.3.3.1 Total Phosphorus ............................................................... 5-123

5.3.3.2 Total Ammonia Nitrogen ................................................... 5-126

5.3.4 VOCs and SVOCs................................................................................ 5-131

5.3.4.1 MAHs and PAHs ............................................................... 5-132

5.3.4.2 Bis(2-ethylhexyl) phthalate and 2,4,6-Trichlorophenol ..... 5-138
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5.4 Uncertainties in the Quantitative Effects Analysis .......................................... 5-139

5.4.1 Uncertainty Variation Associated with Estimation of 

 Chronic Toxicity .................................................................................. 5-140

5.4.2 Uncertainty and Evaluation of Risk from Possible Exposure to 

Pollutant Mixtures ................................................................................ 5-142

5.5 Summary of Risk Conclusions for Listed Aquatic and Aquatic-Dependent 

Species and their Critical Habitats Represented within RAAs ........................ 5-145

5.6 References ........................................................................................................ 5-152

SECTION 6 ANTICIPATED EFFECT OF PROPOSED ACTIONS ON 

 MITIGATING IMPACT TO LISTED SPECIES ........................................... 6-1 

6.1 Mitigation of Risk to Listed Species from the VGP’s Control of ANS in 

Vessel Discharges ................................................................................................ 6-2 

6.1.1 Mitigating Risk of ANS by Reducing Propagule Pressure ...................... 6-2

6.1.1.1 Predicting the Relationship Between Propagule Pressure and 

Risk of ANS Invasion and Establishment .............................. 6-3 

6.1.1.2 Population Viability Analysis (PVA) Models ....................... 6-4 

6.1.1.3 Use of PVA Models in the USCG Draft Programmatic 

Environmental Impact Statement ........................................... 6-4 

6.1.1.4 Recommendations from the National Academy of Science 

Regarding the Use of Risk-Release Models .......................... 6-5 

6.1.2 Reducing Propagule Pressure by Ballast Water Management ................. 6-6

6.1.2.1 No Management of Ballast Water (Unmitigated discharge) .. 6-7 

6.1.2.2 Interim Management Pre-2006 (Mandatory Ballast Water 

Exchange on the Great Lakes and Voluntary Exchange 

Nationwide)............................................................................ 6-7 

6.1.2.3 Interim Management post-2006 (Mandatory Ballast Water 

Exchange and Flushing on the Great Lakes and Mandatory 

Ballast Water Exchange Nationwide) .................................... 6-8 

6.1.2.4 IMO/USCG Ballast Water Management (Numerical Discharge 

Standards) ............................................................................ 6-10 

6.1.2.5 2013 VGP............................................................................. 6-12 

6.1.2.6 Feasibility of More Stringent Numerical Discharge Limits for 

the 2013 issuance of the VGP .............................................. 6-13 

6.1.2.7 Evidence Supporting Effectiveness of Ballast Water 

Management ......................................................................... 6-14 

6.1.2.8 Effectiveness of Ballast Water Exchange and Flushing to 

Reduce Propagule Pressure in Fresh Waters vs. Coastal Waters 

(no osmotic shock benefit) ................................................... 6-15 

6.1.3 Reducing Propagule Pressure by Biofouling Management ................... 6-16

6.1.3.1 Reducing the Biofouling Vector by Selection of 

 Appropriate AFCs ................................................................ 6-18 

6.1.3.2 Reducing Propagule Pressure from Underwater 

 Cleaning ............................................................................... 6-19 

6.1.3.3 Management of Biofouling in Seawater 

 Cooling Systems .................................................................. 6-21 
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6.1.4 Control of ANS Discharges in Chain Locker Effluent and 

 Fish Hold Effluent.................................................................................. 6-21

6.1.5 Inspection, Monitoring, Reporting and Recordkeeping ......................... 6-22

6.1.6 Measures in the sVGP to Reduce Risk from ANS ................................ 6-23

6.1.7 Specific Examples of Anticipated Mitigation of Risk in Ballast 

Water by Permits .................................................................................... 6-23

6.1.7.1 Mitigation of Risk to Listed Species from a Freshwater 

Macroinvertebrate: Case of the Bloody Red Shrimp ........... 6-24 

6.1.7.2 Mitigation of Risk to Listed Species from a Saltwater 

Macroinvertebrate: Case of the European Green Crab ........ 6-25 

6.2 Mitigation of Risk to Listed Species from Discharge of Pollutants Lacking 

Specific Concentration-Response Toxic Effect Thresholds .............................. 6-27 

6.2.1 Pathogens ............................................................................................... 6-27

6.2.2 Oil and Grease ........................................................................................ 6-28

6.2.3 BOD ....................................................................................................... 6-29

6.3 Mitigating Risk to Listed Species from Vessel Discharges of Toxic and 

Non-Conventional Pollutants with Toxic Effects .............................................. 6-29 

6.4 Mitigating Risk to Listed Species from Coal Ash from Coal Fired 

Propulsion Systems on Ferries ........................................................................... 6-32 

6.5 References .......................................................................................................... 6-32

SECTION 7 EFFECTS SUMMARY AND DETERMINATION ......................................... 7-1

7.1 Methodology for Effects Determinations for ANS .............................................. 7-1 

7.1.1 Example “Not Likely to Adversely Affect” With Low Potential 

Exposure: Valley Elderberry Long Beetle ............................................... 7-2 

7.1.2 Example “Not Likely to Adversly Affect” With Very Low 

Potential Exposure: Marbled Murrelet ..................................................... 7-3 

7.1.3 Example “May Affect” Determination for ANS for an Aquaticdependent Species: California clapper rail .............................................. 7-4 

7.2 Methodology for Effects Determinations for Pollutants Selected for 

Detailed Evaluation .............................................................................................. 7-4 

7.3 Effects Determination for All Species ................................................................. 7-7 

SECTION 8 CUMULATIVE EFFECTS ................................................................................. 8-1

SECTION 9 INTERRELATED AND INTERDEPENDENT ACTIONS ............................ 9-1

Appendix A. Discharge-Specific Technology-based Effluent Limits, Except Ballast Water, 

Required by the VGP for All Covered Vessels 

Appendix B. Vessel Class-Specific Technology-based Effluent Limits Required by the 

VGP for Select Permitted Vessels 

Appendix C. Ballast Water Technology-based Effluent Limits Required by the VGP for 

All Covered Vessels 
2013 VGP and sVGP BE Table of Contents 

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Appendix D. Water Quality and Other Benchmark Values Used to Screen the Vessel 

Discharge Data 

Appendix E. Methodology for Determining the Aquatic and Aquatic-Dependent Species 

that May Be Affected by the 2013 VGP and sVGP 

Appendix F. Species Descriptions for Listed Aquatic and Aquatic-dependent Species from 

One of Seven RAAs Selected to Support Effects Analysis 

Appendix G. Methodology for Hypothetical Harbor Modeling 

Appendix H. Summary of RQs for Aquatic Multiple Routes of Exposure and Oral 

Ingestion by Aquatic and Aquatic-Dependent Wildlife Species 

Appendix I. Basis of Critical Body Burden Calculations for Benzo(a)pyrene and Benzene 

Used as CTET to Calculate RQA,M in Quantitative Effects Analysis 
2013 VGP and sVGP BE List of Tables 

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LIST OF TABLES 

Page 

Table 2-1. Population of Operational, Domestic MISLE Vessels Potentially less than 

79 Feet in Length by General Vessel Type ............................................................. 2-6 

Table 3-1. Summary of VGP Vessel Attributes by Vessel Type ............................................. 3-4 

Table 3-2. Number of Vessels <79 feet in Length by Vessel Type ......................................... 3-8 

Table 3-3. Screening Analysis to Select Vessel Discharges for Detailed Analysis for 

the BE.................................................................................................................... 3-11

Table 3-4. Ballast Water Capacity for Vessels Selected for Detailed Analysis ..................... 3-25 

Table 3-5. Estimated Bilgewater Discharge Rates for the Vessels Selected for Detailed 

Analysis................................................................................................................. 3-25 

Table 3-6. Estimated Deck Washdown Discharge Rates for Vessels Selected for 

Detailed Analysis .................................................................................................. 3-26 

Table 3-7. Estimated Propulsion and Generator Engine Wet Exhaust Discharge Rates 

for Vessels Selected for Detailed Analysis ........................................................... 3-27 

Table 3-8. Estimated Exhaust Gas Scrubber Washwater Discharge Rates for the 

Vessels Selected for Detailed Analysis ................................................................. 3-29 

Table 3-9. Estimated Fish Hold Effluent Discharge Rates by Type of Fishing Vessel ......... 3-30 

Table 3-10. Estimated Fish Hold Cleaning Effluent Discharge Rates by Type of Fishing 

Vessel .................................................................................................................... 3-30 

Table 3-11. Estimated Graywater Discharge Rates for Vessels Selected for Detailed 

Analysis................................................................................................................. 3-31 

Table 3-12. Estimated Volume of Stern Tube Packing Gland Effluent Discharge Rates 

for Vessels Selected for Detailed Analysis ........................................................... 3-32 

Table 3-13. Pollutant Categories Associated with Vessel Discharges Selected for 

Detailed Analysis .................................................................................................. 3-33 

Table 3-14. Average Nutrient Concentrations in Vessel Discharges at Levels Above 

Screening Level Benchmarks ............................................................................... 3-35 

Table 3-15. Oil and Grease Concentrations Measured in Vessel Discharges Requiring 

Detailed Analysis .................................................................................................. 3-37 

Table 3-16. Average Concentrations of Total Metals in Vessel Discharges at Levels 

Above Screening Level Benchmarks .................................................................... 3-38 

Table 3-17. Average Concentrations of Dissolved Metals in Vessel Discharges at 

Levels Above Screening Level Benchmarks ........................................................ 3-39 

Table 3-18. Estimated Amount of Copper Leached from Anti-fouling Coatings Applied 

to Various Vessel Types ....................................................................................... 3-40 
2013 VGP and sVGP BE List of Tables 

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Table 3-19. Average Concentrations of VOCs and Total Residual Chlorine in Vessel 

Discharges at Levels Above Screening Level Benchmarks ................................ 3-41 

Table 3-20. Average Concentration of sVOCs and PAHs in Vessel Discharges at Levels 

Above Screening Level Benchmarks .................................................................... 3-42 

Table 3-21. Average BOD and TSS Concentrations in Vessel Discharges at Levels 

Above the Screening Level Benchmarks .............................................................. 3-43 

Table 3-22. RAAs Selected to Support the BE Analysis and Water bodies and 

Ecosystems Represented ....................................................................................... 3-45 

Table 3-23. Listed Aquatic and Aquatic-dependent Species in Respective RAAs .................. 3-47 

Table 4-1. Area of Land Use Categories Within the Puget Sound Basin ................................ 4-5 

Table 4-2. Causes for Impairment in Puget Sound Action Areas – 2008 ................................ 4-7 

Table 4-3. Pollutants of Concern in Puget Sound .................................................................... 4-9 

Table 4-4. Causes for Impairment in Upper and Lower New York Bay RAA – 2010 .......... 4-14 

Table 4-5. Aquatic Nuisance Species in the New York/New Jersey Harbors ....................... 4-15 

Table 4-6. Causes for Impairment in Galveston Bay Area – 2008 ........................................ 4-20 

Table 4-7. Aquatic Nuisance Species in the Galveston Bay .................................................. 4-21 

Table 4-8. Area of Land Use Categories within Upper Mississippi River Reach 3 ............... 4-24 

Table 4-9. Approximate Concentration (mg/L) of Contaminants near the Mouths of 

Select Upper Mississippi River Tributaries – 1993 to 1996 ................................. 4-26 

Table 4-10. St. Louis River Habitat Plan Habitat Type Descriptions ...................................... 4-30 

Table 4-11. Major Land Uses of the SLRE .............................................................................. 4-32 

Table 4-12. Wisconsin 303(d) list for the St. Louis River Area of Concern ............................ 4-34 

Table 4-13. Minnesota 303(d) List for the St. Louis River Area of Concern .......................... 4-35 

Table 4-14. Aquatic Nuisance Species Currently in the St. Louis River Estuary .................... 4-36 

Table 4-15. California San Francisco Bay Regional Water Quality Control Board 2010 

303(d) List ............................................................................................................. 4-43 

Table 4-16. Sources of Select Pollutants of Concern in SFBE ................................................ 4-45 

Table 4-17. Major Land Use of the South Miami-Dade Watershed ........................................ 4-49 

Table 4-18. Verified List of Impaired Waters in the Biscayne Bay-Southeast Coast Basin .... 4-51 

Table 4-19. Factors Affecting Current Status of Listed Species in RAAs ............................... 4-56 

Table 5-1. Estimates of Invasive Species in Several Major Water Systems ............................ 5-3 

Table 5-2. Concentration of Various Organism Types Reported in Unexchanged 

Ballast Water Sampled Upon Arrival of Ships to Particular Regions .................... 5-5 

Table 5-3. River and Estuary Harbors Selected for Model Input Parameter 

Development ......................................................................................................... 5-30 
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Table 5-4. Hypothetical Estuary Harbor Scenarios and Input Values ................................... 5-31 

Table 5-5. Hypothetical River Harbor Scenarios and Input Values ....................................... 5-31 

Table 5-6. Average Daily Vessel Population Equivalents in the RAAs ................................ 5-33 

Table 5-7. Receiving Water Model Scenarios ........................................................................ 5-33 

Table 5-8. Estimated Receiving Water Concentrations in a Hypothetical Estuary 

Harbor ................................................................................................................... 5-35

Table 5-9. Estimated Receiving Water Concentrations in a Hypothetical River Harbor ....... 5-36 

Table 5-10. RQ Scale for Risk Conclusion and Overall Health Concern Determination ........ 5-40 

Table 5-11. Listed Species Taxonomic Groupings Based on Listed Aquatic and Aquaticdependent Species within the Seven RAAs .......................................................... 5-47 

Table 5-12. Crosswalk for Surrogate Species Type to Listed Species Taxonomic Group ...... 5-53 

Table 5-13. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Total Residual Chlorine (freshwater) and 

Chlorine-produced Oxidants (saltwater) ............................................................... 5-59 

Table 5-14. Risk Quotients Based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative 

Surrogate Taxa to TRC/CPO ................................................................................ 5-60 

Table 5-15. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to TRC ........................................................................................................ 5-61 

Table 5-16. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Total Suspended Solids (TSS) ........................ 5-64 

Table 5-17. Risk Quotients Based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative 

Surrogate Taxa for Total Suspended Solids (TSS) ............................................... 5-64 

Table 5-18. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to TSS......................................................................................................... 5-65 

Table 5-19. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Total Aluminum ............................................. 5-69 

Table 5-20. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative 

Surrogate Taxa to Total Aluminum ...................................................................... 5-70 

Table 5-21. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Total Aluminum ..................................................................................... 5-72 

Table 5-22. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Dissolved Arsenic .......................................... 5-75 

Table 5-23. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Thresholds of Representative Surrogate 

Taxa to Arsenic ..................................................................................................... 5-77 
2013 VGP and sVGP BE List of Tables 

xiii

Table 5-24. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Arsenic .................................................................................. 5-78 

Table 5-25. Summary of Chronic Toxicity Values for Aquatic and Aquatic-dependent 

Organisms Exposed to Dissolved Cadmium ......................................................... 5-81 

Table 5-26. Risk Quotients Based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Thresholds of Representative Surrogate 

Taxa to Dissolved Cadmium ................................................................................. 5-82 

Table 5-27. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Cadmium ............................................................................... 5-84 

Table 5-28. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Dissolved Chromium ...................................... 5-87 

Table 5-29. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative 

Surrogate Taxa to Dissolved Chromium............................................................... 5-89 

Table 5-30. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Chromium ............................................................................. 5-90 

Table 5-31. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Dissolved Copper ........................................... 5-94 

Table 5-32. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative 

Surrogate Taxa to Dissolved Copper .................................................................... 5-95 

Table 5-33. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Copper ................................................................................... 5-96 

Table 5-34. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Dissolved Lead ............................................. 5-100 

Table 5-35. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative 

Surrogate Taxa to Dissolved Lead ...................................................................... 5-101 

Table 5-36. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Lead .................................................................................... 5-103 

Table 5-37. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Dissolved Nickel .......................................... 5-106 

Table 5-38. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative 

Surrogate Taxa to Dissolved Nickel ................................................................... 5-107 

Table 5-39. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Nickel .................................................................................. 5-109 

Table 5-40. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Total Selenium ............................................. 5-112 
2013 VGP and sVGP BE List of Tables 

xiv

Table 5-41. Risk Quotients Based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative 

Surrogate Taxa to Total Selenium ...................................................................... 5-114 

Table 5-42. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Total Selenium ..................................................................................... 5-115 

Table 5-43. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Dissolved Zinc .............................................. 5-118 

Table 5-44. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative 

Surrogate Taxa to Dissolved Zinc....................................................................... 5-119 

Table 5-45. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Zinc ..................................................................................... 5-121 

Table 5-46. Summary of Statewide and Site-specific (waterbody) Approved Water 

Quality Standards for Total Phosphorus across the United States ...................... 5-124 

Table 5-47. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Lowest Water Quality Criteria for Total Phosphorus ........... 5-125 

Table 5-48. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Total Phosphorus ................................................................................. 5-126 

Table 5-49. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Total Ammonia Nitrogen ............................. 5-128 

Table 5-50. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative 

Surrogate Taxa to Total Ammonia Nitrogen ...................................................... 5-129 

Table 5-51. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Total Ammonia Nitrogen ..................................................................... 5-130 

Table 5-52. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to MAHs and PAHs .......................................... 5-134 

Table 5-53. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative 

Surrogate Taxa to MAHs and PAHs ................................................................... 5-136 

Table 5-54. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative 

Surrogate Taxa to Bis(2-ethylhexyl) phthalate ................................................... 5-138 

Table 5-55. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to 2,4,6-Trichlorphenol ..................................... 5-139 

Table 5-56. Summary of Species-Specific Risk Conclusions for Listed Aquatic and 

Aquatic-dependent Species in RAAs .................................................................. 5-141 

Table 5-57. Sum of RQs for Metals Under Pre- and Post-Permit Conditions ....................... 5-144 

Table 5-58. Sum of RQs for PAHs Under Post-Permit Conditions ....................................... 5-144 
2013 VGP and sVGP BE List of Tables 

xv

Table 5-59. Summary of Species-Specific Risk Conclusions for Listed Aquatic and 

Aquatic-dependent Species in RAAs .................................................................. 5-147 

Table 6-1. Estimated Percent Reduction in Pollutant Load Following Issuance of the 

2013 VGP and sVGP ............................................................................................ 6-31 

Table 7-1. Effects Determinations by Taxonomic Group for Pollutants Selected for 

Detailed Evaluation ................................................................................................. 7-6 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May 

Be Affected by the 2013 VGP and sVGP ............................................................... 7-8 
2013 VGP and sVGP BE List of Figures 

xvi

LIST OF FIGURES 

Page 

Figure 2-1. NOI Vessels by Vessel Type .................................................................................. 2-5

Figure 2-2. Estimated Number of Commercial Fishing and Non-Recreational Vessels 

Potentially Less than 79 Feet in Length Recorded in MISLE, by Vessel 

Service (Category) .................................................................................................. 2-7

Figure 4-1. Land Use and Physical Feature Map of Puget Sound/ Seattle, WA RAA .............. 4-4

Figure 4-2. Land Use and Physical Feature Map of Upper and Lower Bay/ New York, 

NY RAA ............................................................................................................... 4-12

Figure 4-3. Land Use and Physical Feature Map of Galveston Bay/ Houston, TX RAA ....... 4-17

Figure 4-4. Land Use and Physical Feature Map of UMR at St. Louis, MO RAA ................. 4-23

Figure 4-5. Land Use and Physical Feature Map of St. Louis River Estuary/ 

 Duluth, MN RAA.................................................................................................. 4-29 

Figure 4-6. Land Use and Physical Feature Map of San Francisco Bay Estuary, CA 

RAA ...................................................................................................................... 4-39

Figure 4-7. Land Use and Physical Feature Map of Miami/ Biscayne Bay, FL RAA ............ 4-47 

Figure 5-1. Variables Altering the Probability of Establishment of ANS Released in 

Ballast Water and Sediments. Processes in the Right-hand Column Impact 

the Outcome of Survival, Reproduction and Establishment ................................. 5-15
2013 VGP and sVGP BE Section 1- Background and Purpose of Consultation

1-1 

SECTION 1 

BACKGROUND AND PURPOSE OF CONSULTATION 

In accordance with the Endangered Species Act (ESA), federal agencies are required to 

“insure that any action authorized, funded, or carried out by such agency is not likely to 

jeopardize the continued existence of any endangered or threatened species or result in the 

destruction or adverse modification of any habitat of such species determined to be critical unless 

an exemption has been granted.” 16 U.S.C. § 1536(a)(2). If the agency determines that the 

proposed actions may affect listed species or critical habitats, consultation with the United States 

Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) 

(collectively “the Services”) is required. 

To comply with Section 7 of the ESA under regulation (50 CFR §402.14(c)), EPA must 

submit, with this request for formal consultation, the following: 

 a description of the actions being considered; 

 a description of the specific area that may be affected by the actions; 

 a description of any listed species or critical habitats that may be affected by the 

actions; 

 a description of the manner in which the actions may affect any listed species or 

critical habitats, and an analysis of any cumulative effects; 

 relevant reports, including any environmental impact statements, environmental 

assessments, biological assessment or other analyses prepared on the proposal; and 

 any other relevant studies or other information available on the actions, the affected 

listed species, or critical habitats. 

EPA has prepared and is submitting this biological evaluation (BE) in support of the 

Agency’s obligations under ESA Section 7 consultation. The BE was prepared using the best 

scientific and commercial information available for pollutant discharges from vessels proposed 

to be regulated under two separate permit actions: the 2013 re-issuance of the Vessel General 

Permit (VGP) and a new (2013) Small Vessel General Permit (sVGP). The information was used 

by the Agency to determine whether the actions of issuing the two general permits is likely to: 

(1) adversely affect listed species or designated critical habitats; (2) jeopardize the continued 

existence of species that are proposed for listing; or (3) adversely modify proposed critical 

habitats or (4) result in no effect to listed species where applicable. EPA commenced informal 

consultation with both FWS and NMFS in early December 2011 on this issuance of the VGP. 

This BE is intended to support the initiation of formal consultation, where appropriate. 

This document has been substantially updated from a May 2008 draft BE to support the 

initiation of formal consultation to reflect the Agency’s actions of the 2013 re-issuance of the 

VGP, as well as the new permit action of the proposed sVGP. In addition, this BE uses new 

information found since completion of the 2008 BE, and includes revisions that respond to 

concerns expressed in written comments provided by FWS in their July 22, 2008 letter addressed 

to James Hanlon, Director of the USEPA Office of Wastewater Management, regarding the May 

2008 Draft BE and related correspondence. Additionally, this BE uses new peer reviewed 

literature, government reports, and other information. 
2013 VGP and sVGP BE Section 2- Scope of Proposed Actions

2-1 

SECTION 2 

SCOPE OF PROPOSED ACTIONS 

This section presents an overview of the actions that are the subject of this BE, consisting 

of two parts: 

 The 2013 re-issuance of the Vessel General Permit (VGP) for Discharges Incidental 

to the Normal Operation of Vessels.1

 

 The new proposed Small Vessel General Permit (sVGP) for Discharges Incidental to 

the Normal Operation of Vessels Less than 79 Feet. 

2.1 LEGAL AND PROCEDURAL BACKGROUND

Section 301(a) of the Clean Water Act (CWA) provides that “the discharge of any 

pollutant by any person shall be unlawful” unless the discharge is in compliance with certain 

other sections of the Act. 33 U.S.C. 1311(a). The CWA defines “discharge of a pollutant” as 

“(A) any addition of any pollutant to navigable waters from any point source, (B) any addition of 

any pollutant to the waters of the contiguous zone or ocean from any point source other than a 

vessel or other floating craft.” 33 U.S.C. 1362(12). A “point source” is a “discernible, confined 

and discrete conveyance” and includes a “vessel or other floating craft.” 33 U.S.C. 1362(14). 

The term “pollutant” includes among other things, “garbage...chemical wastes...and 

industrial, municipal, and agricultural waste discharged into water.” The Act’s definition of 

“pollutant” specifically excludes “sewage from vessels or a discharge incidental to the normal 

operation of a vessel of the Armed Forces” within the meaning of CWA §312. 33 U.S.C. 

1362(b). 

One way a person may discharge a pollutant without violating the Section 301 

prohibition is by obtaining authorization to discharge (referred to herein as “coverage”) under a 

Section 402 NPDES permit (33 U.S.C. 1342). Under section 402(a), EPA may “issue a permit 

for the discharge of any pollutant, or combination of pollutants, not withstanding section 

1311(a)” upon certain conditions required by the CWA. 

An NPDES permit authorizes the discharge of a specified amount of a pollutant or 

pollutants into a receiving water under certain conditions. The two basic types of NPDES 

permits are individual and general permits. The actions that are the subject of this BE are general 

permits. Under 40 CFR § 122.28, general permits may be written to cover categories of point 

sources having common elements, such as facilities that involve the same or substantially similar 

types of operations, that discharge the same types of wastes, or that are more appropriately 

regulated by a general permit than by individual permits. Courts have approved of the use of 

general permits. See e.g., Natural Res. Def. Council v. Costle, 568 F.2d 1369 (D.C. Cir. 1977); 

EDC v. USEPA, 344 F.3d 832, 853 (9th Cir. 2003). A general permit is developed and issued by a 

permitting authority (in this case, EPA) and is subject to public comment. A general permit 

covers multiple facilities within a specific category for a specific period of time (not to exceed 

 

1

 The first VGP (2008 VGP) expires on December 19, 2013. This second issuance of the VGP (2013 VGP) will 

replace that permit at that time, but will be issued as a final permit in November 2012. 
2013 VGP and sVGP BE Section 2- Scope of Proposed Actions

2-2 

5 years), after which the permit expires. General permits may be re-issued. As with any permit, 

the CWA requires the general permit to contain technology-based effluent limits, as well as any 

more stringent limits when necessary to meet applicable state water quality standards. 

2.1.1 VGP

In December 2003, a long-standing exclusion of discharges incidental to the normal 

operation of vessels from the NPDES program became the subject of a lawsuit in the U.S. 

District Court for the Northern District of California. On March 30, 2005, that court determined 

that the exclusion exceeded EPA’s authority under the CWA. Following submission of briefs and 

oral argument by parties and intervenors on the issue of a proper remedy, the District Court 

issued a final order in September 2006 providing that: 

The blanket exemption for discharges incidental to the normal operation of a vessel, 

contained in 40 CFR 122.3(a), shall be vacated as of September 30, 2008 [see Northwest 

Envtl. Advocates et al. v. United States EPA, 2006 U.S. Dist. LEXIS 69476 (N.D. Cal. 

2006)]. 

EPA appealed the District Court’s decision to the Ninth Circuit, and on July 23, 2008, the 

Circuit Court upheld the decision [see Northwest Envtl. Advocates v. EPA, 537 F.3d 1006 (9th 

Cir. 2008)]. 

This meant that, effective December 19, 2008, except for those vessels exempted from 

NPDES permitting by Congressional legislation (vessel exemptions discussed in Section 2.1.2), 

discharges incidental to the normal operation of vessels which were excluded from NPDES 

permitting by 40 CFR 122.3(a) were subject to CWA Section 301’s prohibition against 

discharging, unless authorized by an NPDES permit. The CWA authorizes civil and criminal 

enforcement for violations of that prohibition and allows for citizen suits against violators. 

In response to the court decisions, EPA issued the VGP in December 2008.2

 Given the 

large number of vessels requiring NPDES permit coverage and the discharges common to these 

vessels, EPA believed that it made administrative sense to issue the general permit, rather than 

issuing individual permits to each vessel. The use of the general permit approach here allowed 

EPA to allocate resources in an efficient manner and to provide more timely coverage, 

particularly in light of the time constraints imposed by the Court’s vacatur. 

The 2008 VGP went into effect in December of 2008 with an expiration date of 

December 2013. The renewal of the VGP in 2013 includes improvements to the control 

measures implemented in the earlier 2008 VGP by making recommended changes and including 

additions based on information gathered during the previous permit action. Section 2.3.1.4 of this 

document provides a brief summary of some of the key provisions included the 2013 VGP that 

differ from the current (2008) VGP. 

 

2

 Due to a subsequent extension of the vacatur date by the district court, NPDES permits were not required for 

incidental discharges from VGP vessels until February 6, 2009. 
2013 VGP and sVGP BE Section 2- Scope of Proposed Actions

2-3 

2.1.2 sVGP

In late July 2008, Congress enacted two pieces of legislation to exempt discharges 

incidental to the normal operation of certain types of vessels from the need to obtain an NPDES 

permit. The first of these, entitled the Clean Boating Act of 2008, amended the CWA to provide 

that discharges incidental to the normal operation of recreational vessels were not subject to 

NPDES permitting, and instead, created a new regulatory regime to be implemented by EPA and 

the U.S. Coast Guard under new § 312(o) of the CWA. S. 2766, Pub. L. 110-188 (July 29, 2008). 

As defined in § 3 of that law, recreational vessels are defined as any vessel that is manufactured 

or used primarily for pleasure or leased, rented, or chartered to a person for the pleasure of that 

person, but does not include a vessel that is subject to Coast Guard inspection and that is engaged 

in commercial use or carries paying passengers. As a result of this legislation, discharges 

incidental to the normal operation of recreational vessels are not subject to NPDES permitting. 

EPA is currently developing regulations as directed under the Clean Boating Act for recreational 

vessels. For more information on this action, please see: 

http://water.epa.gov/lawsregs/lawsguidance/cwa/vessel/CBA/about.cfm. 

The second piece of legislation, P.L.110-299, provided for a temporary moratorium on 

NPDES permitting for discharges subject to the 40 CFR 122.3(a) exclusion from (1) commercial 

fishing vessels (as defined in 46 U.S.C. § 2101 and regardless of size) and (2) those other nonrecreational vessels less than 79 feet in length. (July 31, 2008). The statute’s NPDES permitting 

moratorium ran for a two-year period beginning on its July 31, 2008 enactment date and was 

subsequently extended to December 18, 2013 by P.L. 111-215. 

During the period of the moratorium, EPA studied the relevant discharges and issued a 

Report to Congress, entitled “Study of Discharges Incidental to Normal Operation of 

Commercial Fishing Vessels and Other Non-Recreational Vessels Less Than 79 Feet” in August 

2010 (EPA, 2010). That report is available at 

http://cfpub.epa.gov/npdes/vessels/reportcongress.cfm. To ensure that permit coverage is 

available to commercial fishing vessels and other non-recreational vessels less than 79 feet in 

length in the event the moratorium expires, EPA has proposed the sVGP. 

2.2 AFFECTED VESSELS

The re-issuance of the VGP provides a mechanism for controlling the discharge of 

pollutants incidental to the normal operation of non-military, non-recreational vessels generally 

greater than 79 feet. The new sVGP provides a mechanism for controlling the discharge of 

pollutants incidental to the normal operation of non-military, non-recreational vessels 79 feet or 

less. The combination of vessels subject to the two permits operate on all “waters of the United 

States,” as defined in 40 C.F.R. § 122.2 as certain inland waters and the territorial sea, which 

generally extends three nautical miles (nm) from shore3

. Note that the CWA does not require 

NPDES permits for vessels or other floating craft operating beyond the territorial seas, i.e., in the 

contiguous zone or ocean for their discharges incidental to the normal operation of the vessel. 

See CWA Section 502(12)(B) and 40 C.F.R. § 122.2 (definition of “discharge of a pollutant”). 

 

3

 More specifically, CWA section 502(8) defines “territorial seas” as “the belt of the seas measured from the line of 

the ordinary low water along that portion of the coast which is in direct contact with the open sea and the line 

marking the seaward limit of inland waters, and extending seaward a distance of three (nautical) miles.” 
2013 VGP and sVGP BE Section 2- Scope of Proposed Actions

2-4 

2.2.1 Vessels Covered by the VGP

The types of vessels covered under the 2013 VGP are expanded from the 2008 VGP to 

include the approximately 2,000 large commercial fishing vessels greater than 79 feet included in 

the P.L. 110-299 permitting moratorium. Almost all of the newly covered large commercial 

fishing vessels are less than 300 gross tons4

. Vessels currently covered under the 2008 VGP 

include: cruise ships, ferries, barges, mobile offshore drilling units, oil tankers or petroleum 

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

research vessels, emergency response vessels, including firefighting and police vessels, and any 

other vessels operating in a capacity as a means of transportation. Vessels of the Armed Forces 

of the United States are not eligible for coverage by this permit. While all non-recreational, nonmilitary vessels may seek coverage under this permit, the permit requirements are tailored for 

vessels that are at least 79 feet in length. A separate, streamlined permit (the sVGP) is available 

for vessels less than 79 feet. See Section 2.2.2 for discussion of vessels covered under the sVGP. 

EPA used two existing databases (the Marine Information for Safety and Law 

Enforcement (MISLE) and Waterborne Transportation Lines of the United States (WTLUS) 

databases) to create a master database to estimate the population (number and type) of 

domestically-flagged vessels subject to the VGP. EPA used the master database to obtain a 

comprehensive estimate of the domestic vessel population of approximately 60,000 vessels 

subject to the VGP. Using the Foreign Traffic Vessel Entrances and Clearances (FTVEC) 

database5

, EPA estimates another approximately 12,400 foreign-flagged vessels are also subject 

to the VGP requirements. 

EPA compared this estimated vessel population to the 43,431 active Notices of Intent 

(NOIs) submitted under the 2008 VGP as of August 2010 to fact check the accuracy of these 

estimates. The NOI database is useful to generally identify covered vessels by major vessel type, 

although the NOI database cannot be used alone to estimate the number of vessels covered by the 

permit. This is because only vessels greater than 300 gross tons or with the capacity to carry 

more than 8 cubic meters (m3) of ballast water were required to submit NOIs under the 2008 

VGP. Therefore, there are vessels that were covered under 2008 VGP that were not required to 

fill out and submit NOIs. 

The NOI form listed nine types of vessels under which the vessel owners/operators could 

classify their vessel. Of the 36,642 vessels for which EPA has more complete information (see 

Figure 2-1), 24,241 correspond with one of the following eight types of vessels (in declining 

order of number of vessels represented): barges (of all types); oil or gas tankers; commercial 

fishing vessel (with ballast water); large cruise ships (500+ passengers); large ferries (250+ 

passengers or more than 100 tons of cargo, e.g., cars, trucks, trains, or other land-based 

transportation); research vessels; emergency vessels; and medium cruise ships (100 to 

499 passengers). Respondents for the remaining 12,401 vessels that provided vessel 

 

4

 Only those vessels greater than 300 gross tons or with the capacity to carry more than 8 cubic meters of ballast 

water were required to complete an Notice of Intent (NOI) for permit coverage under the VGP. Only 146 

commercial fishing vessels submitted NOIs (see Figure 2-1). Note that both the proposed 2013 VGP and sVGP 

mandate that vessels owner/operators not required to submit an NOI to complete a Permit Authorization and Record 

of Inspection Form and keep it onboard their vessel. 

5

 The FTVEC database provides information on foreign vessels entering or clearing U.S. Customs ports in calendar 

year 2008, the most recent year for which data are published (USACE, 2010). 
2013 VGP and sVGP BE Section 2- Scope of Proposed Actions

2-5 

tonnage/ballast water capacity selected “Other” as a vessel type and wrote in the specific type. 

Of the 12,401 “Other” vessels for which respondents submitted information, the 

owners/operators of 2,562 (21 percent) wrote in a designated type as requested by EPA, whereas 

the majority (9,839 owners/operators or 79 percent) did not. Cargo carriers (of all sorts, e.g., bulk 

carrier, roll-on/roll-off) comprised the vast majority of the “Other” vessels sub-classified as 

requested (2,044 vessels), followed by much fewer tugs/tow boats (143), crew/supply/support 

vessels (115), chemical/oil tankers (83), barges (34), and passenger vessels (18). The specific 

subtypes of cargo carriers were dominated by: general cargo/not otherwise specified (91 

percent); car/truck carrier (3.6 percent); refrigerated cargo (2.3 percent); log/lumber/woodchip 

carrier (1.2 percent); and roll-on roll-off cargo, cement, grain/ore and ore/oil (cumulatively less 

than one percent) (USEPA, 2012). See EPA’s VGP NOI Vessel Universe Summary Report 

(USEPA, 2012) and economic analysis for the VGP (USEPA, 2011) for more information about 

the 2013 VGP vessel universe. 

Figure 2-1. NOI Vessels by Vessel Type6

 

6

 Source: EPA NOI database, August 5, 2010. Note: Percentages are based on the total number of vessels within a 

given type out of the total 43,431 uniquely identified vessels in the NOI database. The rather large subset of 

6,468 vessels within the “Uncertain” group and identified as “Lacking Information” consist of those for which the 

information reported in the NOI database regarding vessel tonnage or ballast water capacity was missing. These 

vessels were discussed further in Section 2.3 of the VGP NOI Vessel Universe Summary Report (USEPA, 2012), 

and have been excluded from the more detailed data summary and analysis included in Section 2.2 of that report. 

The 321 vessels identified as “Not Applicable” were not analyzed in that report because the tonnage and ballast 

water capacity reported in the NOI for these particular vessels are less than 300 gross tons and/or 8 m3

, respectively. 

However, EPA noted that these vessels may have chosen to submit a NOI despite being smaller than these 

thresholds, or if the vessel is below 79 feet, may be seeking coverage for the ballast water discharges only as 

authorized in Part 1.2.1 of the 2008 VGP.

Research Vessel, 82, 0.2%

Oil or Gas Tanker, 3,280, 7.6%

Medium Cruise Ship, 22, 0.1%

Large Cruise Ship, 127, 0.3%

Barge, 20,410, 47.0%

Large Ferry,

118, 0.3%

Emergency Vessel,

56, 0.1%

Commercial Fishing Vessel,

146, 0.3% Other, 12,401, 28.6%

Lacking Info,

6,468, 14.9%

Not Applicable, 321, 0.7%

Uncertain,

6,789, 15.6%

Number of Vessels
2013 VGP and sVGP BE Section 2- Scope of Proposed Actions

2-6 

2.2.2 Vessels Covered by the sVGP

The sVGP addresses all vessels less than 79 feet in length, except recreational and 

military vessels, operating in a capacity as a means of transportation, that have discharges 

incidental to their normal operation. 

As they did for the VGP, EPA also estimated the population (number and type) of vessels 

subject to the sVGP. EPA estimates that there are between 118,000 to 140,000 vessels in the 

United States subject to the permitting moratorium established by P.L. 110-2997. Approximately 

115,000 to 138,000 of these vessels are less than 79 feet and subject to the sVGP. Approximately 

half of these vessels are commercial fishing vessels involved in such activities as catching fish 

(e.g., longliner, shrimper, and trawler), fish processing8

, fishing tenders, and charter fishing. The 

other half are distributed among a variety of vessel classes, including passenger vessels (e.g., 

water taxis, tour boats, harbor cruise ships, dive boats), utility vessels (e.g., tug/tow boats, 

research vessels, offshore supply boats), and freight barges. 

Table 2-1 characterizes the population of vessels potentially less than 79 feet in length 

recorded in the U.S. Coast Guard’s MISLE database in terms of general vessel type: commercial 

fishing, other non-recreational, and unspecified. According to the MISLE database, and the total 

number of small vessels tabulated in Table 2-1, there are 137,583 domestic vessels potentially 

eligible for coverage under the sVGP. Figure 2-2 presents the MISLE population of operational, 

domestic commercial vessels less than 79 feet in length according to several specific vessel 

service categories. 

Table 2-1. Population of Operational, Domestic MISLE Vessels Potentially less than 

79 Feet in Length by General Vessel Type 

Category Commercial 

Fishing 

Other 

Non-Recreational Unspecified Totalb

Less than 79 ft 54,176 32,799 15,011 

Zero or Nulla 13,537 9,696 12,364 

Total (lower bound estimate)c 67,178 32,806 15,012 114,996 

Total (upper bound estimate)d 67,713 42,495 27,375 137,583 

Source: USEPA. 2011b. 

a) MISLE indicates a length of zero or the vessel length field is blank. 

b) Range indicates number of vessels when excluding (lower bound) vs. including (higher bound) vessels with 

zero or unknown length. Note that the estimates may include some vessels that are used in non-recreational 

service (e.g., commercial fishing or law enforcement) but that were manufactured as pleasure vessels. 

c) Includes a fraction of vessels with length reported as zero or null in the MISLE database, based on the share of 

vessels in the overall vessel population for each vessel type that are reported to be less than 79 feet (96% of 

commercial fishing vessels, 0.1% of other non-recreational vessels, and 0.0% of vessels of unspecified type). 

d) Assumes all vessels with length reported as zero or null in the MISLE database are less than 79 ft. 

 

7

 This range accounts for the exclusion and inclusion, respectively, of commercial fishing, other non-recreational 

and unspecified vessels for which U.S. Coast Guard’s MISLE database does not record the length or for which the 

recorded length is zero. Note: under P.L. 110-299, the moratorium applied to all commercial fishing vessels 

regardless of length (approximately 69,944 vessels). 

8

 Seafood processing vessel discharges are an industrial activity; therefore, seafood processing activities are not 

eligible for coverage under this permit (or the VGP). EPA or state NPDES permitting authorities (as appropriate) 

issue separate NPDES permits for seafood processing vessels when they are engaged in this industrial activity. 
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Figure 2-2. Estimated Number of Commercial Fishing and Non-Recreational Vessels 

Potentially Less than 79 Feet in Length Recorded in MISLE, by Vessel Service (Category)9

The remainder of this section gives additional detail about vessels eligible for coverage 

under the sVGP. For additional discussion about these vessels, please see EPA’s 2010 Vessels 

Report to Congress (USEPA, 2010). 

2.2.2.1 Commercial Fishing Vessels 

The approximately 54,000 to 68,000 commercial fishing vessels less than 79 feet in 

length represent the largest category of vessels potentially covered by the sVGP. According to 

the vessel service categories used by the U.S. Coast Guard in MISLE, “commercial fishing 

 

9 This figure is based on operational, U.S.-flagged commercial fishing vessels and other non-recreational vessels 

less than 79 feet in length reported in the U.S. Coast Guard’s MISLE database (2009). All information is compiled 

and presented in EPA’s 2010 Vessels Report to Congress (USEPA, 2010) on the study of discharges incidental to 

the normal operation of commercial fishing vessels and other non-recreational vessels less than 79 feet. Note: 

Commercial fishing vessels also include fish processing vessels and fishing vessels. Passenger vessels include 

passenger (inspected), passenger (uninspected), passenger barge (inspected), passenger barge (uninspected), and

passenger ships. Public vessel, unclassified includes military and other public service vessels. EPA notes that 

military vessels are specifically excluded from NPDES permitting. Utility vessels include towing vessels (i.e., tugs), 

school ships, research vessels/ships, mobile offshore drilling units, offshore vessels, offshore supply vessels, oil 

recovery vessels, and industrial vessels. Some vessel service categories did not fall into one of the listed categories. 

Therefore, based on the other classification fields (class, type, subtype), EPA determined an appropriate service 

category. 
2013 VGP and sVGP BE Section 2- Scope of Proposed Actions

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vessels” includes vessels involved in such activities as fish catching (e.g., longliner, shrimper, 

trawler), and charter fishing. 

For purposes of the MISLE database, the U.S. Coast Guard generally describes 

commercial fishing vessels as including fishing vessels, fish tender vessels, and fish processing 

vessels as follows: 

 Fish processing vessel10 means a vessel that commercially prepares fish or fish 

products other than by gutting, decapitating, gilling, skinning, shucking, icing, 

freezing, or brine chilling. 

 Fish tender vessel means a vessel that commercially supplies, stores, refrigerates, or 

transports fish, fish products, or materials directly related to fishing or the preparation 

of fish to and from a fishing, fish processing, or fish tender vessel or a fish processing 

facility. 

 Fishing vessel means a vessel that commercially engages in the catching, taking, or 

harvesting of fish or an activity that can reasonably be expected to result in the 

catching, taking, or harvesting of fish. 

While there is some overlap in service use for commercial fishing vessels and other 

vessel categories, such as passenger vessels (e.g., charter fishing), EPA assumed that the 

categorization used in MISLE generally follows the U.S. Coast Guard definition of commercial 

fishing vessels (USEPA, 2010). 

2.2.2.2 Other Non-recreational Vessels 

The approximately 21,000 “passenger vessels” represent the second highest number of 

vessels less than 79 feet in length. These vessels are further divided into subtypes according to 

the types of activities in which they are involved (e.g., diving vessels, charter fishing vessels, 

ferries, harbor cruise vessels, and sailing vessels). The service category labeled “public vessel, 

unclassified” accounts for only approximately 700 vessels including lighthouse tender vessels, 

hospital ships, law enforcement vessels, and ice breakers. The “utility vessels” category covers 

the remaining types of vessels, including tug/tow boats, school ships, research vessels/ships, 

mobile offshore drilling units, offshore vessels, offshore supply vessels, oil recovery vessels, and 

industrial vessels. More than 11,000 vessels are classified as utility vessels in MISLE.11 Freight 

barges (8,016 vessels), freight ships (768 vessels), tank barges (925 vessels), and tank ships 

(179 vessels) account for the remaining non-recreational vessels covered under this permit. 

2.3 SUMMARY DESCRIPTIONS OF THE PROPOSED PERMIT ACTIONS

The requirements of the VGP and the sVGP are summarized in Sections 2.3.1 and 2.3.2. 

The information summarized and presented in these sections is from the 2013 VGP and sVGP 

proposed permits and corresponding fact sheets. In addition, specific mention of some of the key 

differences between the 2008 VGP and the reissuance of the VGP in 2013 is included in 

Section 2.3.1.4. 

 

10 Please see footnote number # 8 discussing the applicability of the sVGP versus other NPDES permits to fish 

processing vessels. 

11 Some vessel service categories did not fall into one of the listed categories. EPA determined an appropriate 

service category based on information provided in other vessel classification fields (class, type, subtype). 
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2.3.1 2013 VGP

This general permit provides a mechanism for controlling the discharge of pollutants 

incidental to the normal operation of non-military, non-recreational vessels generally greater than 

79 feet, that are operated as a means of transportation on inland waters and the territorial seas of 

the United States. The VGP establishes effluent limitations to control a variety of pollutants and 

constituents of concern which, for the purposes of this BE, have been classified into major 

groups: aquatic nuisance species (ANS), nutrients, pathogens (including E. coli and fecal 

coliform), oil and grease, metals, most conventional pollutants (e.g., biochemical oxygen 

demand (BOD), pH, and total suspended solids (TSS)), and other toxic and non-conventional 

pollutants with toxic effects. Such materials are, depending on the particular vessel, constituents 

in the industrial waste, chemical waste and/or garbage “pollutant” discharge resulting from the 

activities of these vessels. Upon permit coverage, the permittee is responsible for complying with 

all effluent limits, inspection, monitoring, reporting, documentation and other requirements 

specified in the VGP (summarized in Section 2.3.1.3 of this BE). 

Vessel owner/operators are required to meet the effluent limits applicable in Part 2 of the 

permit, as well as conduct corrective actions to remedy deficiencies and violations in Part 3. 

Part 4 of the permit lists visual monitoring, self-inspection, and recordkeeping and reporting 

requirements. Part 5 of the permit has additional requirements for certain vessel types (e.g., large 

and medium cruise ships, large ferries). States, territories, and certain tribes have the authority to 

require additional requirements under Section 401 of the CWA, which are incorporated into 

Part 6 of the 2008 permit. Like the 2008 VGP, EPA will incorporate State specific 401 

certification requirements into the 2013 VGP. 

The summary below highlights the VGP’s various control measures, which are designed 

to reduce or control discharges from regulated vessels so that both positive environmental 

impacts are realized and potential undesirable environmental effects (including effects to 

Federally-listed species and their critical habitats) from the seven major pollutant groups are 

minimized to the maximum extent. 

2.3.1.1 Vessel Discharges Eligible for Coverage Under the VGP 

The discharges eligible for coverage under the permit are those discharges incidental to 

the normal operation of a vessel covered by the exclusion in 40 CFR 122.3(a) prior to vacatur of 

that exclusion. Examples of discharges eligible for coverage under the VGP include deck runoff, 

bilgewater, and ballast water (a full list of eligible discharges is provided below). Some potential 

discharges are not incidental to the normal operation of a vessel and are not authorized under this 

permit. For example, intentionally adding used motor oil to the bilge tank would result in a 

bilgewater discharge that is not incidental to the normal operation of a vessel and thus is 

prohibited by the permit. Furthermore, any discharge that results from a failure to properly 

maintain the vessel and equipment, even if the discharge is of a type that is otherwise covered by 

the permit, is not eligible for permit coverage and constitutes a violation of the CWA. Discharges 

that are not covered by this permit or are exempt from Section 402 of the CWA must be covered 

under a separate individual or general permit. 
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The 27 effluent streams listed below are discharges incidental to the normal operation of 

a vessel eligible for coverage under the VGP. These effluent streams are described in detail in 

Section 3.2.1 of this document (Vessel Discharge Selection): 

 Deck Washdown and Runoff and Above Water Line Hull Cleaning 

 Bilgewater/Oily Water Separator Effluent 

 Ballast Water 

 Anti-Fouling Hull Coatings/Hull Coating Leachate 

 Aqueous Film Forming Foam (AFFF) 

 Boiler/Economizer Blowdown 

 Cathodic Protection 

 Chain Locker Effluent 

 Controllable Pitch Propeller and Thruster Hydraulic Fluid and Other Oil-to-Sea 

Interfaces Including Lubrication Discharges from Paddle Wheel Propulsion, Stern 

Tubes, Thruster Bearings, Stabilizers, Rudder Bearings, Azimuth Thrusters, 

Propulsion Pod Lubrication, and Wire Rope and Mechanical Equipment Subject to 

Immersion. 

 Distillation and Reverse Osmosis Brine 

 Elevator Pit Effluent 

 Firemain Systems 

 Freshwater Layup 

 Gas Turbine Washwater 

 Graywater 

 Motor Gasoline and Compensating Discharge 

 Non-Oily Machinery Wastewater 

 Refrigeration and Air Condensate Discharge 

 Seawater Cooling Overboard Discharge (Including Non-Contact Engine Cooling 

Water, Hydraulic System Cooling Water, Refrigeration Cooling Water) 

 Seawater Piping Biofouling Prevention 

 Boat Engine Wet Exhaust 

 Sonar Dome Discharge 

 Underwater Ship Husbandry Discharges 

 Welldeck Discharges 

 Graywater Mixed with Sewage from Vessels 

 Exhaust Gas Scrubber Washwater Discharge 

 Fish Hold Effluent 

Below are several discharge types that are not authorized by this permit. Hence, there is 

no risk associated with these discharges associated with this permit as they are not regulated by 

the VGP. The discharges are not authorized because, among other things, the discharge is not 

within the scope of the current 40 CFR 122.3(a) exclusion and/or not within the scope of EPA’s 

NPDES permitting authority: 

 Discharges not Subject to Former NPDES Permit Exclusion Including Vessels Being 

Operated in a Capacity other than as a Means of Transportation 

 Sewage from Vessels 
2013 VGP and sVGP BE Section 2- Scope of Proposed Actions

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 Used or Spent Oil 

 Rubbish, Trash, Garbage or Other Materials Discharged Overboard 

 Photo-Processing Waste 

 Effluent from Dry Cleaning Operations 

 Discharges of Medical Waste and Related Materials 

 Discharges of Noxious Liquid Substance (NLS) Residues 

 Tetrachloroethylene (Perchloroethylene) Degreasers 

 Discharges Currently or Previously Covered by Another Permit 

2.3.1.2 Effluent Limitations Specified in the VGP12

The CWA requires that all point source discharges must meet technology-based effluent 

limitations (TBELs) representing the applicable levels of technology-based control. Water 

quality-based effluent limitations (WQBELs) are required as necessary where the technologybased limitations are not sufficient to meet applicable water quality standards (WQS). The use of 

these two kinds of effluent limitations in the VGP– technology-based and water quality-based 

are briefly summarized in the following Subsections, 2.3.1.2.1 and 2.3.1.2.4. 

2.3.1.2.1 Technology-Based Effluent Limits 

EPA has determined that the non-numeric and numeric TBELs in this permit, taken as a 

whole, facilitate the reduction and/or elimination (to the extent achievable) of many of the 

pollutants in the permitted discharges. For all of the discharges in this permit, the TBELs are 

based on best professional judgment, as authorized under CWA Section 402(a)(1) and 40 CFR 

125.3. The TBELs are expressed as (1) general requirements applicable to all vessels, 

(2) discharge-specific requirements applicable to all covered vessels that discharge them, and 

(3) vessel class-specific requirements applicable to all covered vessels in those vessel classes. 

For convenience, the discharge- and vessel class-specific TBELs are summarized in 

Appendices A and B of this BE, respectively, except for ballast water, which are summarized 

separately in Appendix C. 

2.3.1.2.2 Non-numeric TBELs 

The general requirements applicable to all vessels include (see Parts 2.1.1 through 2.1.6 

in the VGP): 

 Material Storage (Part 2.1.1)

 Toxic and Hazardous Materials (Part 2.1.2)

 Fuel Spills/Overflows (Part 2.1.3) 

 Discharges of Oil, Including Oily Mixtures (Part 2.1.4) 

 Compliance with Other Statutes and Regulations Applicable to Vessel Discharges 

(Part 2.1.5)

 General Training (Part 2.1.6) 

 

12 EPA has summarized the requirements of the VGP for purposes of the BE. However, please note that the VGP 

and the VGP fact sheet should be referenced to see the requirements in full. If the summary presented in this section 

and the requirements of the VGP differ in any way from these summaries, the permit is the governing 

implementable document. 
2013 VGP and sVGP BE Section 2- Scope of Proposed Actions

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In addition to these general requirements, many other non-numeric TBELs require 

permittees to utilize specific best management practices (BMPs). Specifically, the VGP includes 

such non-numeric effluent limits developed for discharges for which the development and/or 

calculation of numeric effluent limits is infeasible at this time. These non-numeric TBELs are 

generally expressed in the VGP as the following: 

 Specific behavioral practices for minimizing or eliminating the pollutants or 

constituents of concern in the discharge. 

 Specific pollution prevention practices for minimizing or eliminating the pollutants or 

constituents of concern in the discharge. 

 Narrative requirements to minimize pollutants or constituents of concern in 

discharges or the discharges themselves.13

 Limiting or eliminating discharges at certain times in protected waters for discharge 

types that can be limited or eliminated for short periods due to technology available 

on board the vessel and the vessel design (i.e., if the vessel can hold the discharge 

type for limited periods or reduce production of the effluent). 

2.3.1.2.3 Numeric TBELs 

In some cases, such as with discharges of oil, including oily mixtures, and graywater 

discharges from cruise ships (under certain circumstances), numeric effluent limits have been 

established for the 2013 VGP to effectively reduce or eliminate specific pollutant constituents of 

concern (e.g., oil and grease, total residual chlorine). Additionally, the 2013 VGP proposes new, 

more stringent numeric TBELs to replace the non-numeric limitations in the 2008 VGP for living 

organisms in ballast water14 (see Appendix C). EPA has set the numeric effluent limit for ballast 

water as numbers of living organisms per cubic meter of ballast water discharged (i.e., as a 

maximum acceptable concentration) because reducing the concentration of living organisms will 

reduce inoculum densities of potential invasive species discharged in a vessel’s ballast water 

(NAS, 2011). As part of the permit reissuance, EPA has also established discharge limitations for 

biocides and residuals in ballast water discharges (see also Appendix C). 

Owner/operators of vessels subject to the concentration-based numeric TBELs for ballast 

water may meet the TBELs in one of four ways: 

 Discharge treated ballast water meeting the applicable numeric limits (Part 2.2.3.5.5 

of the VGP); 

 Transfer of the ship’s ballast water to a third party for treatment at an NPDES 

permitted facility (which may be onshore or on another vessel such as a treatment 

barge); 

 Use treated municipal/potable water as ballast water; or 

 Not discharging ballast water. 

 

13 These types of effluent limits allow owner/operators to use control measures appropriate for their vessels to meet 

these limits. 

14 EPA’s proposed effluent limits for the discharge of living organisms is equivalent to the U.S. Coast Guard Phase 1 

proposed discharge standard (USCG, 2009), which is roughly equivalent to the standard set forth in Regulation D-2 

of the International Ballast Water Convention (IMO, 2008) (henceforth referred to as the International Maritime 

Organization (IMO) standard). These numerical limitations represent the most current and stringent standards that 

ballast water management systems can safely, effectively, credibly, and reliably meet (EPA SAB, 2011). 
2013 VGP and sVGP BE Section 2- Scope of Proposed Actions

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In addition, vessels enrolled in, and meeting the requirements of the U.S. Coast Guard’s 

Shipboard Technology Evaluation Program (STEP)15, are deemed to be compliant with the 

permit requirements for ballast water treatment. 

2.3.1.2.4 Additional Water Quality-Based Effluent Limits 

EPA generally expects that vessels that achieve the technology-based limits through the 

careful implementation of effective pollution control measures and BMPs included in the VGP 

are likely controlling their vessel discharges to a degree that would make additional water 

quality-based controls unnecessary. To ensure that this is the case, however, the permit includes 

water quality-based effluent limits (WQBELs) to control discharges as stringently as necessary 

to meet applicable water quality standards where the implementation of the technology-based 

requirements in the permit are not sufficient to meet the applicable receiving water’s water 

quality standards. 

The WQBELs included in this permit are non-numeric. EPA relies on a narrative 

expression of the need to control discharges as necessary to meet applicable water quality 

standards, and to employ additional controls where necessary to be consistent with applicable 

Waste Load Allocations (WLAs) in an approved or established Total Maximum Daily Load 

(TMDL) for impaired waters16, or to comply with a state or tribe’s anti-degradation policies. 

EPA believes this a reasonable approach for the VGP because it has determined that it is 

infeasible to calculate numeric WQBELs limits for most vessel discharges at this time. EPA 

made every effort to identify generally applicable BMPs beyond those already imposed on a 

technology basis for ballast water discharges; however, EPA was unable to do so with the 

exception of imposing a site-specific narrative WQBEL on ballast water discharges for the Great 

Lakes. Additionally, vessels utilizing a ballast water treatment system must also conduct ballast 

water exchange or saltwater flushing (as applicable) in addition to treating their ballast water if 

they meet the following requirements: 

 The vessel operates outside the EEZ and more than 200 nm from any shore and then 

enters the Great Lakes via the Saint Lawrence Seaway System, and 

 The vessel has taken on ballast water that has a salinity of less than 18 ppt from a 

coastal, estuarine, or freshwater ecosystem within the previous month. 

If a vessel affected by these requirements has not taken on ballast water with a salinity of 

less than 18 ppt in the previous month, the master of the vessel must certify to this effect in their 

ballast water recordkeeping requirements before entering the Great Lakes. 

 

15 The STEP program has encouraged pioneering vessel owner/operators to install ballast water treatment systems, 

has contributed to the development of effective sampling methods, and allowed for the collection of valuable 

shipboard ballast water treatment data needed to evaluate the efficacy of ballast water treatment systems. EPA 

believes that, as systems are developed and refined, the STEP program will play a valuable role in supporting the 

development of technologies which exceed the performance of the IMO standard, and thus, will play a key role in 

the development of a greater range of systems which can meet the limits in the 2013 VGP. 16 Impaired waters or “water quality limited segment[s]” are those identified by a state or EPA pursuant to Section 

303(d) of the CWA as not meeting applicable state water quality standards. Impaired waters may include both 

waters with EPA-approved or EPA-established TMDLs, and those for which EPA has not yet approved or 

established a TMDL. 
2013 VGP and sVGP BE Section 2- Scope of Proposed Actions

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2.3.1.3 Inspections, Monitoring, Reporting, and Recordkeeping 

Other permit requirements include vessel inspections, discharge monitoring, and 

information reporting and recordkeeping. 

Under Part 4.1.1 of the VGP, all permittees are required to conduct routine visual 

inspections, including collecting and analyzing a quarterly sample of discharge streams for 

visible materials of concern, including discoloration, visible sheens, suspended solids, floating 

solids, foam, or changes to clarity. Permittees are also required to conduct an annual 

comprehensive inspection of the vessel under Part 4.1.3 of the VGP, with specific emphasis on 

those areas most likely to result in a discharge likely to cause or contribute to exceedences of 

water quality standards or violations of effluent limits established in the VGP. As required by 

Part 4.2 of the proposed VGP, owner/operators must maintain records of findings from these 

inspections, as well as any required analytical monitoring results, effluent limit violations or 

other noncompliance, and corrective actions taken. Additional recordkeeping requirements apply 

if the vessel is equipped with ballast water tanks (see VGP Part 4.3). In addition, permittees must 

report to EPA once per year any instances of noncompliance (see VGP Part 4.4.1). 

EPA is also proposing that certain types of vessels must conduct targeted analytical 

monitoring. For instance, in order to demonstrate treatment system effectiveness and continued 

maintenance and compliance with the permit, large and medium-sized cruise ships (as defined in 

the permit) must analyze treated graywater for specific constituents (i.e., E. coli, total 

phosphorus, ammonia, nitrate/nitrite, and total kjeldahl nitrogen (TKN), BOD, fecal coliform, 

suspended solids, pH, and total residual chlorine) (see Part 5.1 and 5.2 of the VGP). Similar 

analytical monitoring of treated graywater discharges is also required for any vessel that is 

constructed on or after December 19, 2013 and has a maximum crew capacity greater or equal to 

10 and provides overnight accommodations to those crew or operates on the Great Lakes and is 

not a “commercial vessel” as defined in CWA Section 3.12(a)(10) (see Part 2.2.15 of the VGP 

for details). 

Analytical monitoring requirements also apply to vessels required to achieve other 

numeric effluent limitations of the proposed VGP, such as those employing ballast water 

treatment (see Part 2.2.3.5) or exhaust gas scrubber (see Part 2.2.26.1) systems that result in 

washwater discharges, as well as those covered vessels that discharge treated bilgewater within 

3 nm of shore (Part 2.2.2). 

2.3.1.4 Summary of Most Significant Changes from 2008 VGP 

The reissuance of the VGP in 2013 affords EPA the opportunity to expand the control 

measures implemented in the current 2008 VGP by making a variety of improvements based on 

information gathered during the previous permit action. In response to a notice seeking public 

input on potential improvements for the 2013 VGP (prior to the VGP’s proposal), EPA received 

written comments from more than 4,500 stakeholders. All comments submitted by the public are 

available at www.regulations.gov and can be found under docket number "EPA-HQ- OW-2010-

0828". 

In addition to the several changes based on comments garnered from stakeholders, EPA, 

through additional information gathering and via information gleaned from implementation of 

the 2008 VGP, has made the specific changes listed below to better reduce and control pollutant 
2013 VGP and sVGP BE Section 2- Scope of Proposed Actions

2-15 

constituents from the following regulated discharges. Note that the specific changes highlighted 

below are meant only to present major aspects of the new provisions, and do not encompass the 

entire scope of each control measure and its applicability to the various vessel types, discharges, 

and other aspects of coverage as stated in the VGP. For more specific details regarding these 

provisions, see Appendices A through C in this BE. 

2.3.1.4.1 Ballast Water 

 Under the 2013 permit revision, certain vessels will have to meet numeric treatment 

limits, whereas vessels did not have numeric treatment requirements in the 2008 VGP. See 

Appendix C for further information. 

2.3.1.4.2 Oil to Sea Interfaces 

 All new vessels constructed after 19 December 2013 must use environmentally 

acceptable lubricants (EALs) for relevant equipment and, if feasible, existing vessels constructed 

prior to that date must also use EALs. 

2.3.1.4.3 Graywater 

 The 2013 VGP revision includes new monitoring requirements for new vessels 

constructed after 19 December 2013 and for all vessels with a crew of 10 or greater that provide 

overnight accommodations. The permit also provides further clarification of requirements for 

“commercial vessels” operating on the Great Lakes. Additionally, soaps and detergents that will 

be discharged in graywater must now be both phosphate free and non-toxic and biodegradable. 

Finally, new monitoring requirements for E coli, total phosphorus, ammonia, and nitrate, nitrite 

and TKN have been added in addition to the previous monitoring requirements for BOD, fecal 

coliform, TSS, pH, total residual chlorine. 

2.3.1.4.4 Small Boat Engine Wet Exhaust 

 Vessels with two-stroke engines must now use environmentally acceptable lubricants if 

feasible. 

2.3.1.4.5 Exhaust Gas Scrubber Washwater Discharge 

 Washwater from exhaust gas scrubbers must meet new numeric discharge limits, and 

vessels must comply with new monitoring requirements. 

2.3.1.4.6 Fish Hold Effluent 

 Effluent from fish holds is a newly authorized discharge under the 2013 VGP revision. 

Best management practices include minimizing discharge of fish hold water and ice slurry while 

in port, using physical separation methods prior to discharge, and specific prohibitions for 

discharge of unused bait and for land-based seafood processors. 
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2.3.1.4.7 Coal Ash Slurry 

 The discharge of coal ash slurry from coal fired propulsion systems on large ferries is no 

longer an authorized discharge. 

2.3.2 2013 sVGP Detailed Summary Description17

This general permit controls the discharge of pollutants incidental to the normal operation 

of non-military, non-recreational vessels less than 79 feet in length (see Section 2.2.2 of this BE). 

Like the VGP, the sVGP is also establishes effluent limitations to control the variety of 

pollutants and constituents of concern, classified into the seven major groups: ANS, nutrients, 

pathogens, oil and grease, metals, most conventional pollutants, and other toxic and nonconventional pollutants with toxic effects. 

All vessels authorized under the sVGP are required to meet the effluent limits applicable 

in Part 2 of the permit. Part 3 of the permit lists recordkeeping and annual inspection 

requirements. Additional permit requirements such as the need for alternative permits, permit 

compliance, duty to provide information, inspection and entry are located in Part 4 of the permit. 

2.3.2.1 Vessel Discharges Eligible for Coverage under the sVGP 

The discharges eligible for coverage under the sVGP are those discharges incidental to 

the normal operation of a vessel covered by the exclusion in 40 CFR 122.3(a) prior to vacatur of 

that exclusion and the moratorium on NPDES permitting enacted by Congress in P.L.110-299 

and extended under P.L. 111-215 (see Section 2.2.2 in this BE). Any discharge not subject to that 

exclusion as of December 18, 2008 is not authorized under the permit. 

Discharges covered under this permit include: ballast water (for vessels with less than 

8 cubic meters of ballast water capacity), graywater, bilgewater, deck runoff and fish hold 

effluent. For the purposes of this permit, not all vessel discharges are not authorized under this 

permit. These non-incidental discharges are described in 40 CFR 122.3 and include discharges 

from industrial operations (e.g., seafood processing), medical waste as defined in 33 § U.S.C. 

1362(20), and noxious liquid substance residues subject to 33 CFR Part 151, Subpart A. 

In the sVGP, permit requirements are organized by management group rather than 

specifically to each discharge stream, as the VGP is organized. Recognizing that small 

commercial vessels are substantially different in how they operate than their larger counterparts, 

the draft sVGP is shorter and simpler. The full list of discharges eligible for coverage under this 

permit fall into one of the eight discharge management groups below: 

 Fuel Management 

 Engine and Oil Control 

 Solid and Liquid Waste Management 

 Deck Washdown and Runoff and Above Water Line Hull Cleaning 

 Vessel Hull Maintenance 

 

17 EPA has summarized the requirements of the sVGP for purposes of the BE. However, if the summary presented in 

this section and the requirements of the sVGP differ in any way from these summaries, the permit is the governing 

implementable document. 
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 Graywater 

 Fish Hold Effluent 

 Ballast Water 

Descriptions of these discharge management groups are provided in Section 4 of the 

sVGP Fact Sheet. 

2.3.2.2 Effluent Limitations Specified in the sVGP 

For the purposes of the sVGP and consistent with the technology-based requirements of 

the CWA, EPA prescribes BMPs to reduce and/or eliminate, to the extent achievable, pollutants 

(e.g., ANS, nutrients, metals, toxics) in light of best marine practice. EPA believes that for most 

small vessel discharges, minimization of pollutants in those discharges can be achieved without 

using highly engineered, complex treatment systems. For other vessel discharges, highly 

engineered, complex, treatments systems that are reliable and approved for use on vessels are not 

currently available. The specific limits included in Part 2 of the sVGP emphasize effective 

pollution prevention controls. For example, the sVGP requires that all cleaners must be 

phosphate free, non-toxic and biodegradable. EPA believes that simple product substitution of a 

more environmentally-friendly cleaner will result in improving the quality of the vessel 

discharges with little to no cost to the vessel owner/operator. A second example of a general 

requirement requires that vessel owner/operators minimize the discharge of any antifreeze into 

waters subject to the permit, and prohibits the discharge of antifreeze with toxic or known 

carcinogenic additives. In other cases, they require more complex behavioral practices such as 

avoiding or minimizing ballast water uptake in areas with a high potential to contain harmful 

organisms and only discharging the minimal amounts of ballast water necessary in coastal and 

internal waters. In yet other cases, more advanced treatment may be necessary. These controls 

are summarized below according to level of complexity. 

The following technology-based effluent limits (TBELs) apply to covered vessels 

according to each permitted discharge management group. 

2.3.2.2.1 Fuel Management 

Vessels conduct fueling operations on a routine basis (see Section 4.2 of the sVGP Fact 

Sheet). The required best management practices for fuel management in Part 2.2 of the sVGP are 

designed to minimize the amount of fuel released to receiving waters by requiring preventive 

maintenance that minimizes the occurrence of leaks and spills and by preventing any spills and 

leaks from entering receiving waters. Thus, owner/operators of permitted small vessels must: 

(a) prevent overfilling and not top off fuel tanks; 

(b) if the permitted vessel does not have a functioning fuel-air separator or a fuel tank 

vent, use an oil absorbent material or other appropriate device while fueling the vessel 

to prevent any oil from entering waters subject to the permit; 

(c) regularly inspect the fuel and hydraulic systems for any damage or leaks; and 

(d) unless impracticable, fill portable tanks onshore, instead of on the dock or on the 

vessel. 

The sVGP also includes a requirement for any new motorized vessels (constructed on or 

after 19 December 2013) to have a functioning fuel-air separator or a fuel tank vent to prevent a 
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fuel spill. EPA has included this requirement for new vessels because the Agency found it 

economically practicable and achievable (BPT/BAT) for these vessels. 

2.3.2.2.2 Engine and Oil Control 

Routine maintenance of engines and generators includes periodic inspection of the engine 

for leaks or other damage; repair and replacement of engine parts; changing the oil in the engine, 

generators, and gear boxes; lubricating bearings on the steering components; and flushing the 

cooling systems. It also includes inspection and maintenance of bilge pumps, oily water 

separators, and any areas of segregated bilge on board a vessel. In addition, the water that 

collects in the bilge must be pumped out periodically, and some external surfaces on vessels are 

lubricated and submerged in, partially submerged in, or directly exposed to water (see 

Section 4.3 of the sVGP Fact Sheet). The lubricants on these machinery and equipment come 

into contact with water by design and can contaminate ambient water. 

The required BMPs for engine and oil content in Part 2.3 of the sVGP are designed to 

minimize the amount spills, leaks, or overflows of oil and other engine fluids released to 

receiving waters using practices that are simple and inexpensive to implement. Owner/operators 

of permitted small vessels must: 

(a) periodically inspect the engine for any loose or leaking hoses, gaskets, and/or seals 

and if needed, repair or replace damaged parts as soon as possible; 

(b) place oil absorbent material or other spill response equipment under the vessel engine 

or use other preventative practices to minimize oil entering the bilgewater; 

(c) clean up any spill or overflow of oil or other engine fluids immediately via absorbent 

pads, pillows, or other materials kept onboard as appropriate for use in addressing or 

remediating any such spills or overflows. Supplies should be checked quarterly and 

restocked as necessary; 

(d) dispose of used oil-absorbent materials onshore in containers designed for oily waste 

disposal; 

(e) if the vessel has a bilge oily water separator, periodically check for the presence of a 

visible sheen in surrounding waters while discharging. If a visible sheen is observed 

as a result of this discharge, suspend discharge until the problem is corrected and 

clean up immediately; 

(f) if the vessel does not use a U.S. Coast Guard type-approved bilge oily water 

separator, use an oil-absorbent material to remove any oil from the bilge before 

discharging; 

(g) not discharge packing gland or stuffing box effluent containing oil, including oily 

materials, in quantities that may be harmful, i.e., produce a visible sheen of oil or oily 

materials. Also, check daily for the presence of a visible sheen while the vessel is 

operational and manned segregated water which contains drips from packing gland 

effluent or stuffing box effluent, if accessible. If not accessible while the vessel is 

operational and manned, check the surrounding water for the presence of a visible 

sheen (while operating). If a visible sheen is observed, appropriate measures such as 

the use of oil absorbent materials must be used to remove the presence of oil before 

the effluent may be discharged. (Note: Dispersants or emulsifiers that remove the 

appearance of a visible sheen cannot be used). If a visible sheen in observed in 
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surrounding waters as a result of this discharge, suspend the discharge until the 

problem is corrected and clean up immediately; 

(h) use environmentally acceptable lubricants (as defined in Part 6 of this permit) in all 

machinery and equipment, including but not limited to stern tubes, wires, and twostroke engines, where discharges of oil to surrounding waters are likely to occur, 

unless technically infeasible; and 

(i) inspect the bilgewater for an oily sheen prior to pumping the bilge, unless infeasible. 

While pumping the bilge, examine the surrounding water for the presence of a visible 

sheen. If a visible sheen is observed as a result of this bilge pumping, suspend the 

discharge until the problem is corrected and clean up immediately. Dispersants, 

detergents, emulsifiers, chemicals or other substances that remove the appearance of a 

visible sheen may not be added to the bilge. 

2.3.2.2.3 Solid and Liquid Waste Management 

Solid and liquid wastes such as trash or garbage, fishing waste, loose items on the deck, 

and toxic materials such as used antifreeze, paint, and out-of-date flares, can enter receiving 

waters by intentional disposal or by accidental disposal due to vessel movement, wind, or rain. 

Such wastes may contain oil and grease, petroleum hydrocarbons, surfactants, detergents, 

glycols, solvents, and general debris. The required BMPs for solid and liquid waste management 

in Part 2.4 of the sVGP will eliminate the release of these materials by preventing their entry into 

any permitted wastestream. Therefore, owner/operators of permitted small vessels must: 

(a) prevent trash or garbage, including food waste, cigarette butts, bottles, and caps from 

entering any waste stream covered by this permit. This can be accomplished in part, 

by maintaining a tidy deck; 

(b) have appropriate receptacles for retaining trash or garbage onboard the vessel. 

Examples of appropriate receptacles include secured trash bags or coolers, bins, or 

trash cans with secure lids; 

(c) store any used antifreeze, paint, out-of-date flares, or other toxics in secure containers 

and dispose of them properly at onshore disposal facilities; 

(d) secure or otherwise prevent loose items on deck from entering any waste stream 

covered by the permit; 

(e) prevent monofilament line, fishing nets, lines, lures, rope, bait boxes, and hooks from 

entering any waste stream covered by the permit. 

2.3.2.2.4 Deck Washdown and Runoff and Above the Water Line Hull Cleaning 

Deck and above the water line hull cleaning are conducted on a routine basis on vessels 

(see Section 4.5 of the sVGP Fact Sheet). The required BMPs for deck washdown, deck runoff 

and above the water line hull cleaning in Part 2.5 of the sVGP are designed to minimize the 

amounts of soaps and cleaners, garbage, debris, spills, residue, and paint chips released to 

receiving waters. Owner/operators of permitted small vessels must: 

(a) use all soaps and cleaners as directed by the label; 

(b) any soaps, detergents, or cleaners used on the vessel must be non-toxic, phosphatefree, and biodegradable. The use of soaps that are labeled toxic or highly toxic is 

prohibited; 
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(c) prevent the introduction of on-deck debris, garbage, residue, and spills into deck 

washdown and runoff discharges; and 

(d) minimize the discharge of paint chips and residue, especially during cleaning, 

maintenance, paint application, and reapplication by collecting and then disposing of 

chips and residues onshore in accordance with applicable requirements for the facility 

where operations are performed. 

2.3.2.2.5 Vessel Hull Maintenance 

Vessel hull maintenance includes the repair, inspection, cleaning, or other maintenance of 

the underwater portions of the vessel hull (see Section 4.6 of the sVGP Fact Sheet). The required 

BMPs for vessel hull maintenance in Part 2.6 of the sVGP are designed to reduce or eliminate 

discharges from anti-fouling coatings (AFCs) and to prevent the spread or dispersal of 

potentially invasive species. In order to comply with provisions in the sVGP for vessel hull 

maintenance, owner/operators of permitted small vessels must: 

(a) if the vessel is equipped with an anti-foulant system, minimize the impact of that 

system or the discharges resulting from anti-foulant paints on the aquatic 

environment: 

(i) consider whether the use of non-copper based paints adequately meets the 

vessel’s anti-foulant needs and uses less toxic alternatives to the extent 

practicable and available; 

(ii) where drying or hull cleaning at hull-out is adequate for managing fouling (e.g., 

for vessels that are hauled frequently or for over-winter storage), do not use 

anti-fouling coating if not needed. 

(iii) since there is a zero-discharge standard for tributyltin (TBT) in the permit, 

either have no TBT coatings, or, have an effective overcoating that completely 

eliminates TBT discharges; 

(b) not clean anti-foulant paint which releases biocides for the first 90 days after 

application; 

(c) if the anti-foulant paint requires cleaning, gently clean hulls on a regular basis (this 

minimizes the need for stronger cleaners and more abrasive brushes); 

(d) use only soft sponges when cleaning hulls coated with anti-fouling paint while the 

vessel is in the water. Examine the water while cleaning to assure that the practice is 

not causing a plume of paint to form. Stop immediately if any visible plume of paint 

appears in the water. Consider hiring a qualified, professional hull cleaner to do the 

work, and ensure they follow environmental guidelines; 

(e) when cleaning hulls coated with anti-fouling paint while the vessel is out of the water, 

ensure work always occurs away from the water in a location where paint chips and 

dust will not be washed into the water. Also, place a tarp under the area to catch loose 

particles, and properly dispose of paint chips, dust, and other particles, and, if 

working in an area that is covered by an NPDES permit (e.g. marina or drydock), 

follow the cleaning requirements of that permit; 

(f) periodically inspect vessel hulls, and if necessary, clean to prevent the spread or 

dispersal of potentially invasive species; 

(g) minimize the transport of any visible living aquatic organisms from one waterbody to 

another by regularly cleaning and maintaining the hull; and 
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(h) prior to transporting the vessel from one waterbody to another overland, inspect the 

visible areas of the vessel for any attached or visible stowaway living organisms. If 

organisms are found, remove and appropriately discard onshore. Removed organisms 

may not be discharged into waters subject to the permit. 

2.3.2.2.6 Graywater 

Graywater is water from showers, baths, sinks, and laundry facilities (see Section 4.7 of 

the sVGP Fact Sheet). The primary sources of graywater on vessels are sinks. Larger vessels 

may have additional graywater sources such as clothes washers, dishwashing machines, water 

fountains, showers, and tubs. The largest vessels may have wastewater from additional sources, 

such as floor drains, ice machines, food garbage grinders, interior deck drains, hot tubs, and 

pools. 

The required BMPs for graywater in Part 2.7 of the sVGP are designed to reduce the 

amount of graywater generated, reduce the amount of graywater discharged into sensitive water 

bodies, and lessen the environmental impacts of any graywater that is discharged. To comply 

with the provisions in this permit, owner/operators of small permitted vessels must: 

(a) minimize graywater discharges in areas that have heavy vessel traffic or heavy 

recreational use and in marine sanctuaries, national wildlife refuges, national wild and 

scenic rivers, and national wilderness areas, and, if the vessel has the capacity to store 

graywater in these waters, it should be stored and later discharged in other waters or 

onshore; 

(b) minimize the production of graywater while the vessel is stationary in confined 

waters (e.g., marinas, harbors), and, if the vessel has the capacity to store graywater, 

it should be stored and discharged at an appropriately equipped onshore facility or 

discharged while the vessel is underway; 

(c) use soaps, detergents and cleaners that are phosphate free, non-toxic and 

biodegradable for any activities that may result in their introduction into graywater; 

and 

(d) not add excess oils, including animal fats and vegetable oils, used during cooking to 

the graywater system or into any other discharge covered by the permit. 

2.3.2.2.7 Fish Hold Effluent 

Commercial fishing vessels use different methods to keep seafood fresh after it is caught. 

Most seafood is either dead when brought onboard or is killed shortly thereafter, before being 

stored in a refrigerated seawater holding tank, with the exception of certain shellfish (e.g., crab, 

lobster), which must be kept alive. The two most common methods of cooling seawater are by 

mechanical refrigeration or by adding ice. Mechanical refrigeration is common on tenders, purse 

seiners, and trawlers, while chipped and slurry ice tanks are more common on trollers, longliners, 

gillnetters, and some trawlers. See Section 4.8 of the sVGP Fact Sheet for additional information. 

The required BMPs for fish hold effluent in Part 2.8 of the sVGP are common practices 

that are easily implemented by vessel owner/operators, and are designed to reduce the amount of 

fish hold effluent discharged into sensitive water bodies and to lessen the environmental impact 

fish hold effluent that is discharged. The owner/operators of permitted fishing vessels must: 
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(a) if unloading catch at a shore-based seafood processor or other pier and a shore-based 

discharge facility is available and economically achievable, discharge effluent 

(including dirty ice) to that shore-based facility instead of discharging to surrounding 

waters; 

(b) not discard any unused bait overboard, unless that bait was caught in that waterbody 

or watershed; 

(c) not discharge unused bait purchased from a bait shop or dealer overboard; 

(d) minimize the discharge of fish hold water or ice while in port; all reasonable steps 

must be taken to prevent the discharge of excess fish hold water and ice while the 

vessel is stationary at the pier. If solid fish waste is contained in the fish hold effluent, 

the fish hold effluent may not be discharged while in port, unless a physical 

separation method is used (e.g., filters or removal of residuals); 

(e) when cleaning the fish hold, use non-toxic, phosphate-free, and biodegradable soaps 

and cleaners; and 

(f) while pierside and stationary, not wash any residual solids into surrounding waters. 

2.3.2.2.8 Ballast Water 

Vessels with a ballast water capacity of 8 cubic meters or greater are not authorized to 

discharge under the sVGP, and must instead seek coverage under the VGP. EPA believes that it 

is not practicable and economically achievable (BPT/BAT) for vessels with less than 8 cubic 

meters or greater ballast water capacity that discharge ballast water to install a ballast water 

treatment system (BWTS) and therefore, those vessels are more appropriately controlled by the 

technology-based requirements outlined in Part 2.9 of the sVGP, which requires owner/operators 

of small vessels with ballast water to: 

(a) avoid the discharge or uptake of ballast water in areas within, or that may directly 

affect, marine sanctuaries, marine preserves, marine parks, shellfish beds, or coral 

reefs; 

(b) minimize or avoid uptake of ballast water in the following areas and situations: 

(i) areas known to have infestations or populations of harmful organisms and 

pathogens (e.g., toxic algal blooms), 

(ii) areas near sewage outfalls, 

(iii) areas near dredging operations, 

(iv) areas where tidal flushing is known to be poor or times when a tidal stream is 

known to be turbid, 

(v) in darkness, when bottom-dwelling organisms may rise up in the water column, 

(vi) where propellers may stir up the sediment, 

(vii) areas with pods of whales, convergence zones, and boundaries of major 

currents; 

(c) discharge only the minimal amount of ballast water essential for vessel operations if 

discharge of ballast water into waters covered by this permit is necessary; 

(d) when feasible, use one of the following measures to reduce the potential for transfer 

or introduction of organisms to waters of the U.S.: 

(i) use potable water for ballasting. 

(ii) utilize onshore treatment or disposal methods for ballast water. 

(iii) for vessels that conduct fixed routes, capture and reuse ballast water in each 

port. 
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2.3.2.3 Additional Water Quality-Based Effluent Limitations 

The sVGP includes water quality-based effluent limits (WQBELs) to control discharges 

as stringently as necessary to meet applicable water quality standards. The provisions of 

Part 4.11 of the sVGP constitute the WQBELs for this permit, and supplement the permit’s 

technology-based effluent limits in Part 2. Where the implementation of the technology-based 

requirements in this permit are not sufficient to meet the applicable receiving water’s water 

quality standards, the permittee may be subject to further WQBELs. Prior to or after permit 

issuance and authorization to discharge, EPA may require additional WQBELs on a site-specific 

basis, or require the permittee to obtain coverage under an individual permit. Additional 

WQEBLs may be required if information in the NOI, required reports, or from other sources 

indicates that, after meeting the technology-based limits in Parts 2 and the WQBELs in Part 4.11, 

the facility is causing or contributing to an excursion above water quality standards.18

2.3.2.4 Recordkeeping and Quarterly Inspections 

Pursuant to CWA section 308 and 402(a)(2), 40 § CFR 122.43(a), and other applicable 

implementing regulations, the sVGP requires recordkeeping and an quarterly inspection 

(Parts 3.1 and 3.2). For the recordkeeping requirement, vessel owner/operators must maintain a 

signed paper copy of the Permit Authorization and Record of Inspection Form (PARI)19 onboard 

the vessel. EPA, or EPA’s authorized representative, may use this form to determine basic 

compliance with the permit, including whether the owner/operator has read the terms of the 

permit and whether the owner/operator has conducted annual inspections as required by the 

permit. The form must be produced for EPA or EPA’s authorized representative upon request 

(see Part 4.5 of the sVGP). 

For the quarterly inspection requirements, vessel owner/operators must include a detailed, 

thorough inspection of areas of the vessel that are difficult to inspect on a more regular basis, 

such as the vessel hull. The sVGP also requires that vessel owner/operators conduct an 

inspection on areas, which if not properly maintained or if damaged, are more likely to result in 

environmental degradation (e.g., protective seals, machinery). The quarterly inspection does not 

require the vessel be placed out of the water or into a drydock. The quarterly visual inspection of 

the vessel is intended to highlight problem areas of the vessel that may need additional attention. 

This allows the Master, owner, or operator to establish and implement additional procedures 

applicable to problem areas to reduce future problems. To this end, the routine quarterly 

inspection requires that all pollution control equipment be inspected to ensure it is functioning 

properly. This requirement provides a reminder and opportunity to complete maintenance 

activities on onboard equipment. The owner/operator is responsible for conducting a thorough 

inspection and taking corrective actions based on that inspection. To aid in determining permit 

compliance, each quarterly visual inspection must be recorded on the PARI Form. The form must 

be signed by the person conducting the inspection and must include basic information relating to 

the inspection and any corrective actions taken as a result of inspection findings. 

 

18 See footnote #16. 

19 A PARI is a Permit Authorization and Record of Inspection Form (PARI) for vessels which need not complete 

NOIs, i.e., vessels less than 300 gross tons and do not have the capacity to hold or discharge more than 8 cubic 

meters (2,113 gallons) of ballast water. 
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2.3.3 Summary of Findings from Other Legal Requirements Relevant to the Permit 

Actions in this BE

As part of preparing the VGP and sVGP, EPA conducted additional evaluations of the 

impact of vessel discharges regulated under the VGP and sVGP on aquatic ecosystems. The most 

relevant of those evaluations were conducted to fulfill requirements under the NPDES 

regulation’s Ocean Discharge Criteria and the Magnuson-Stevens Fishery Conservation and 

Management Act, respectively. EPA’s found that the issuance of the new sVGP and vessels’ 

applications for renewed coverage under the 2013 VGP are not expected to result in the lowering 

of water quality. In fact, EPA’s expectation for the water bodies evaluated ((i.e., the territorial 

seas, the contiguous zone, and the ocean and essential fish habitat, respectively) is that the 

issuance of the two permits should improve water quality as vessels carry out the permit’s 

technology-based requirements. 

2.3.3.1 Ocean Discharge Criteria 

The Ocean Discharge Criteria (40 CFR Part 125, Subpart M) establish regulations for 

issuance of NPDES permits for discharges into the territorial seas, the contiguous zone and the 

ocean as these terms are defined in the CWA. Under 40 CFR 125.123(a), if EPA, on the basis of 

available information determines prior to permit issuance that the discharges authorized will not 

cause unreasonable degradation of the marine environment, EPA may issue an NPDES permit, 

which may be conditioned as necessary to assure that the discharge will not cause unreasonable 

degradation. After consideration of the Ocean Discharge Criteria, EPA has determined that the 

discharges authorized by the NPDES permit into the territorial seas in accordance with permit 

requirements will not cause unreasonable degradation of the receiving waters for the following 

reasons (as provided in the VGP Fact Sheet): 

1) The discharges authorized by the permit are limited to those discharges incidental to 

the normal operation the vessel, and except for ballast water and graywater from 

cruise ships, typically will be of limited volumes. In addition, because vessels in the 

territorial seas are likely to be underway as part of their voyage, any discharges 

incidental to their normal operation would typically be well-mixed upon discharge 

before they are subject to further dispersal and transport beyond the area of the 

vessel’s operation. 

2) In the case of ballast water, the VGP contains interim conditions (Part 2.2.3 of the 

VGP) related to exchange of ballast water and saltwater flushing of empty ballast 

tanks beyond the outer limits of the territorial seas to reduce the risk of introduction 

of invasive species resulting from vessel discharges to water of the United States 

within territorial seas. EPA believes that these controls will prevent unreasonable 

degradation of the marine environment. 

3) With respect to graywater from cruise ships, the permit also includes (Parts 5.1 and 

5.2 of the VGP) additional conditions to reduce the impacts of graywater discharges 

to acceptable levels. EPA believes that these provisions will prevent unreasonable 

degradation of the marine environment. 
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4) In developing the permits, the Agency has taken into consideration that discharges 

incidental to the normal operation of vessels subject to the permits have the potential 

to be contaminated with oil or other potentially persistent or bioaccumulative 

pollutants. The permits therefore contains a number of BMPs intended to avoid or 

reduce the potential for such contamination (e.g., Section 2.1 in the VGP and 2.2 and 

2.3 in the sVGP). In addition, the permits require compliance with all federal 

environmental laws that establish controls on oily or hazardous discharges, including 

among others, CWA section 311 (33 U.S.C. 1321), the Act to Prevent Pollution from 

Ships (33 U.S.C. 190-1915), the Federal Insecticide, Fungicide, and Rodenticide Act 

(7 U.S.C. 136 et seq.), and the Oil Pollution Control Act , 33 U.S.C. 2701-2761. EPA 

believes that these controls will prevent unreasonable degradation of the marine 

environment. 

5) The Agency also has taken into account the biological communities and receiving 

waters that would be exposed to the discharges incidental to the normal operation of 

vessels that will be authorized by the permits. This consideration has necessarily been 

complicated by the fact that vessels have the potential to traverse vast distances in the 

territorial sea while discharging. The Agency has taken an approach of identifying 

potentially sensitive areas in which vessels may operate and providing for additional 

controls when discharges occur in such areas. In addition to requiring compliance 

with marine sanctuaries provisions of the National Marine Sanctuaries Act (16 U.S.C. 

1431 et seq.) and implementing regulations found at 15 C.F.R. Part 922 and 50 C.F.R. 

Part 404 (Part 2.1.5), the permits include other conditions to impose additional 

controls and requirements on covered discharges in sensitive receiving waters. 

6) These permits apply to discharges to the outer limit of the three mile territorial sea. 

State water quality standards also apply within these waters and the permit thus 

contains effluent limitations as necessary to meet those applicable water quality 

standards. In addition, EPA has requested states’ certifications under section 401 of 

the CWA, and requested concurrence on EPA’s consistency determination for this 

permit from state coastal management agencies, in accordance with section 307(c) of 

the Coastal Zone Management Act (CZMA). Additional conditions have been 

incorporated into Part 6 of the VGP and Part 5 of the sVGP, pursuant to CWA section 

401, CZMA section 307(c), and implementing regulations. Under 40 C.F.R. 

125.122(b), EPA presumes that discharges in compliance with state water quality 

standards will not to cause unreasonable degradation of the marine environment with 

respect to specific pollutants or conditions specified in such standards. 

2.3.3.2 Essential Fish Habitat Consultations 

The Magnuson-Stevens Fishery Conservation and Management Act, as amended by the 

Sustainable Fisheries Act of 1996 (Public Law 104-267), established procedures to identify, 

conserve, and enhance essential fish habitat (EFH); that is, essential habitat for species regulated 

under a federal fisheries management plan (FMP). The Act requires federal agencies to consult 

with NMFS on all actions, or proposed actions, authorized, funded, or undertaken by the agency 

that might adversely affect EFH. Upon review, EPA has determined that issuance of this final 

permit will have no adverse effect on EFH because the VGP and sVGP will impose, CWA 
2013 VGP and sVGP BE Section 2- Scope of Proposed Actions

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effluent limitations on discharges incidental to the normal operation of the vessel universe 

subject to the permits. 

2.4 REFERENCES

National Academy of Sciences National Research Council (NAS). 2011. Assessing the 

Relationship Between Propagule Pressure and Invasion Risk in Ballast Water. Committee 

on Assessing Numeric Limits for Living Organisms in Ballast Water, National Research 

Council. National Academies Press. 

USEPA. 2010. Report to Congress: Study of Discharges Incidental to Normal Operation of 

Commercial Fishing Vessels and Other Non Recreational Vessels less than 79 feet. EPA 

833-R-10-005, U.S. Environmental Protection Agency, Washington, DC. 

USEPA. 2011. Economic and Benefits Analysis of the 2013 Vessel General Permit (VGP). U.S. 

Environmental Protection Agency, Washington, DC. 

USEPA. 2012. Summary of the VGP Vessel Universe: Information Submitted by Vessel 

Owner/Operators for Coverage under the Vessel General Permit (VGP). U.S. 

Environmental Protection Agency, Washington, DC. 
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SECTION 3 

BIOLOGICAL EVALUATION APPROACH 

Barring statutory changes, the VGP and sVGP will regulate incidental discharges from 

tens of thousands of vessels that operate and discharge in a variety of water bodies across the 

U.S. and its territories. The objective of the BE is to provide a robust assessment of the potential 

effects vessel discharges permitted by the VGP and sVGP may have on aquatic and aquaticdependent threatened and endangered species present in all U.S. waters. EPA’s overall approach, 

developed in coordination with the Services, is to evaluate in detail the risk posed by vessel 

discharges on an informative subset of listed aquatic and aquatic-dependent species in 

representative areas. EPA will use the risk conclusions from the representative areas to inform 

risk determinations for these species and their critical habitats, as well as the remaining listed 

aquatic and aquatic-dependent species and critical habitats present in U.S. waters that may be 

affected by the proposed actions. EPA’s general approach for the BE includes the following 

steps: 

1) An initial focus on the most predominant vessel types for detailed analysis in the BE; 

2) Determining the most significant discharges from these vessels and their associated 

pollutants; 

3) Identifying representative aquatic ecosystems across the United States where an 

informative range of vessel types are likely to discharge; 

4) Assess the risk to the listed aquatic and aquatic-dependent species and critical habitats 

that occur in those ecosystems posed by a range of assumed pollutant loads from 

incidental vessel discharges covered under the VGP and sVGP; and 

5) Use the risk analysis and conclusions from those ecosystems and vessel types to 

inform effects determinations for other listed aquatic and aquatic-dependent species 

and critical habitat that may be affected under the VGP and sVGP. 

EPA used the following criteria to select the most analytically useful vessel types (see 

Section 3.1) for the BE: 

 Number of vessels in each type; 

 Vessel tonnage; 

 Ballast water capacity; 

 Number of crew and passengers onboard; 

 Use on on-board treatment system(s); and 

 Use of anti-fouling hull coatings. 

These criteria inform the potential of incidental discharges from vessels to impact the 

aquatic environment. Based on the results from this assessment, EPA identified the following 

vessel types for detailed analysis: barges, bulk cargo carriers, commercial fishing vessels, large 

ferries, medium and large cruise ships, oil and gas tankers, passenger vessels such as tour boats 

and water taxis, and utility vessels such as tug and tow boats and supply ships. 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

3-2 

EPA’s selection criteria included the volume of the discharge, the concentration of 

pollutants in the discharge, and the number of vessels discharging that discharge. In general, 

large volume discharges containing pollutants or other constituents of concern with toxic or other 

environmental effects, such as ballast water containing aquatic nuisance species (ANS), are of 

much greater concern for risk assessment purposes than small volume discharges containing 

relatively low levels of pollutants with toxic or other effects, such as distillation concentrate. 

This is because large volume discharges with higher pollutant concentrations have the potential 

to discharge greater amounts of pollutants with the potential to cause environmental effects into a 

water body. EPA believes discharges that generally have combinations of low volume, low 

pollutant concentrations, and that are generated by relatively few vessels are expected to generate 

insignificant or discountable risks, if any. 

EPA selected specific pollutant categories1

 in vessel discharges for detailed analysis in 

the BE to span a wide range of possible types (e.g., toxics, nutrients, ANS) and modes of 

environmental effects. Therefore, EPA believes the pollutant categories provide an insightful, 

broad representation of the entirety of materials present in vessel discharges regulated by the 

proposed permits (see Section 3.2.3). The pollutants and pollutant categories include: ANS, 

nutrients, pathogens, oil and grease, metals, toxic organics, and most conventional pollutants. 

After considering pollutant categories and information regarding discharge volumes, EPA 

determined that the BE should focus on anti-fouling leachate from hull coatings, ballast water, 

graywater, bilgewater, deck washdown, exhaust gas scrubber washwater, fish hold effluent, 

graywater, stern tube discharges, and engine effluent. 

EPA used the following criteria for selecting the representative geographical locations 

(see Section 3.3), referred to as reference action areas (RAAs): 

 Each RAA should be geographically distinct from each other; 

 Combined, the RAAs incorporate a comprehensive range of fresh- and saltwater 

habitat types; 

 The RAAs should harbor a significant number of aquatic and aquatic-dependent listed 

species spanning a comprehensive range of trophic levels, biological taxa (plants, 

invertebrates, vertebrates), and ecological niches; and 

 Each RAA has a “Home Port” or “Port of Call” involving numerous large and small 

commercial vessels in unique combinations that provide a comprehensive range of 

pollutant discharge profiles. 

In addition to meeting these factors above, two additional, complementary RAA locations were 

suggested by Services staff during the informal consultation phase of this consultation and 

incorporated into the BE analysis (i.e., San Francisco and Miami). 

Based on these criteria, EPA selected the following seven geographical locations for the 

BE analysis: 

 Duluth, Minnesota (Lake Superior harbor); 

 Houston, Texas (Galveston Bay); 

 

1 When used in this analysis, pollutant categories also include ANS, which for purposes of the VGP and sVGP, EPA considers a 

constituent of concern. 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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 Miami, Florida (Biscayne Bay); 

 New York, New York (Upper and Lower bay); 

 San Francisco, California (San Francisco Bay); 

 Seattle, Washington (Puget Sound); and 

 St. Louis, Missouri (Mississippi River). 

EPA then determined the listed aquatic and aquatic-dependent species and their 

designated critical habitats present in each of these locations (see Section 3.4). 

The remainder of this section details the selection approach for vessel types, discharges, 

RAAs and listed species/critical habitats. 

3.1 VESSEL TYPES REQUIRING DETAILED ANALYSIS

This section describes EPA’s rationale for selecting vessel types for the BE analysis. 

VGP vessels and sVGP vessels are discussed separately. Vessel selection criteria include 

primarily the number of vessels within a type, vessel size, the number of persons on board, 

treatment systems on board, and hull husbandry activities. 

3.1.1 VGP Vessels

EPA estimates that there are approximately 58,600 domestically flagged vessels that 

would be covered by the VGP; additionally, EPA estimates that approximately 12,400 foreign 

flagged vessels would be covered by the VGP (USEPA, 2011a). The primary source of 

information used to characterize these vessels and their discharges is EPA’s Notice of Intent 

(NOI) database. Part 1.5.1.1 of the VGP requires owners or operators of vessels that are greater 

than or equal to 300 gross tons, or that have the capacity to hold or discharge more than 8 cubic 

meters (m3) (2,113 gallons) of ballast water, to submit a complete and accurate NOI.2,3 The NOIs 

provide EPA useful information about the vessels and the characteristics and conditions of their 

discharges. The information provided in the NOIs (as submitted by owners/operators who 

applied for coverage under the VGP during the period of June 1, 2009) is relevant to this BE, and 

as such, is used throughout the remainder of this subsection to generally describe the attributes of 

the VGP vessels in the context of their significance to the later effects analysis (Section 5.0). 

 

2

 A NOI is not required for vessels less than 300 gross tons that do not have the capacity to hold or discharge more than 8 m3 of 

ballast water; these vessels that are VGP eligible receive coverage under the permit and are authorized to discharge in accordance 

with the conditions set forth within the VGP when they complete the Permit Authorization and Record of Inspection (PARI) form 

and retain it onboard. In evaluating the universe of covered vessels, EPA identified a logical distinction between larger and 

smaller vessels. The limited range of discharge types from smaller vessels and the reduced likelihood for the introduction of 

significant quantities of toxic and conventional pollutants make requiring an NOI for the smaller vessels to be of little value at 

this time. In addition, EPA has access to other sources of data available for identifying discharges from vessels covered by the 

permit, including state registration information, MARAD vessel calls, U.S. Coast Guard registration and customs records, and 

data from the National Ballast Water Information Clearinghouse. See Section 3 of the VGP fact sheet for additional discussion. 3 Additional information for these vessels not submitting NOIs was obtained from the U.S. Coast Guard’s Marine Information for 

Safety and Law Enforcement (MISLE) database (USCG, 2009), and EPA’s 2010 Report to Congress: Study of Discharges 

Incidental to Normal Operation of Commercial Fishing Vessels and Other Non-Recreational Vessels Less than 79 Feet. 

(Currently, a Congressional moratorium initiated by Public Law 110-299 and subsequently extended by Public Law 111-215 

exempts all incidental discharges, with the exception of ballast water, from commercial fishing vessels and non-recreational, nonmilitary vessels less than 79 feet in length from having to obtain a Clean Water Act permit until December 18, 2013.) 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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NOI Respondents were required to provide detailed information for each uniquely 

identified vessel according to the following four subcategories of vessel characteristics data: 

 Vessel General Characteristics and Voyage Related Information – vessel 

subtypes; tonnage, length, and age; date of last dry dock; home/most frequented port; 

and crew/passenger size. 

 Ballast Water and Treatment Related Information – ballast water capacity; ballast 

water management plan, tank cleaning and sediment disposal; and experimental 

ballast water treatment systems and associated discharge of residual biocides. 

 Vessel Discharge and Treatment System Related Information – applicable 

discharges and onboard treatment systems and the wastestreams they are designed to 

treat. 

 Anti-fouling Hull Coatings and Related Information – type of coating, interval 

since last application, and hull husbandry practices, including the frequency with 

which the practices are implemented. 

Table 3-1 summarizes key attributes for the various vessel types covered under the VGP. 

Each of these vessel types is described in greater detail below. 

Table 3-1. Summary of VGP Vessel Attributes by Vessel Type 

Vessel Attribute 

Barges Oil and Gas Tankers Large Commercial FishingaLarge Cruise Ships Large Ferries Medium Cruise Ships Bulk Cargo and Other Carriers Research Vessels Emergency Vessels 

Estimated Number of Vessels 20,410 3,280 2,326b 127 118 22 2,044 82 56 

Median Vessel Tonnage 

(gross tons) 705 24,908 1,997 53,526 1,451 4,584 15,939 1,780 563 

Median Ballast Capacity (m3) 206 23,893 1,388 3,136 404 364 10,198 425 332 

Median Maximum Persons 

Aboard 4 22 29 3,455 559 315 25 41 16 

Percentage of Vessels with 

On-board Treatment Systems 

(%) 

1 78 41 79 45 50 61 78 43 

Percentage of Vessels Using 

Anti-fouling Hull Coatings 

(%) 

4 80 85 84 86 82 65 95 96 

Source: EPA’s NOI Report (USEPA, 2011e), unless otherwise specified. 

a) Large commercial fishing vessels are those greater than 79 feet in length. 

b) Source is USCG MISLE database, 2009. 

3.1.1.1 Barges 

Barges represent the greatest number of vessels permitted under the VGP, with 20,410 

uniquely identified vessels. Barges are large, flat-bottomed boats typically used to move cargo in 

inland waterways. There are many types of barges, including hopper barges, chemical barges, 

fuel barges, crane barges, dry bulk cargo barges, etc. Barges are usually not powered vessels, but 

are instead pushed or pulled by tugboats. Because of their relatively small size (vessel tonnage), 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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ballast capacity, and maximum persons aboard, most discharges incidental to the normal 

operation of these vessels are of limited concern. Due to the relatively large number of barges, 

however, detailed consideration of permitted discharges from barges is warranted for this 

analysis. 

3.1.1.2 Oil and Gas Tankers 

Oil and gas tankers represent the second greatest number of vessels permitted under the 

VGP, with 3,280 uniquely identified vessels. Oil tankers are designed to carry oil and other 

petroleum products in bulk tanks. Oil and gas tankers are large utility vessels, second only to 

large cruise ships in size (median tonnage equal to approximately 25,000 gross tons). Moreover, 

the median ballast water capacity of these vessels is very relatively large (24,000 m3). Nearly all 

oil and gas tankers also use anti foulant coatings to reduce attachment of organisms to the vessel 

hull. Because of the prevalence of oil and gas tankers at certain ports, their overall size, their 

large ballast water capacity and likelihood they are engaged in long distance voyages, and their 

use of AFCs, this particular category of vessels warrants detailed analysis. 

3.1.1.3 Large Commercial Fishing Vessels 

Large commercial fishing vessels are those greater than 79 feet in length that are engaged 

in the catching, taking, or harvesting of fish, crabs, lobster, shrimp, or other aquatic organisms 

for commercial sale. The MISLE database (USCG, 2009) indicates there are 2,326 commercial 

fishing vessels larger than 79 feet in length that are eligible for coverage under the VGP.4

 The 

median ballast water capacity of these vessels is moderately high (1,388 m3), as is the number of 

crew/passengers aboard. Commercial fishing vessels generate fish hold and fish hold cleaning 

waste streams that are unique to commercial fishing vessels, and these waste streams have been 

shown to contain relatively high concentrations of conventional pollutants and nutrients 

(USEPA, 2010). Since most large commercial fishing vessels are concentrated in a limited 

number of home ports, and since fish holds are frequently discharged and cleaned by vessel 

crews between catches, large commercial fishing vessels also warrant detailed analysis for this 

BE. (Note that industrial operations from vessels used as seafood processing facilities are not 

subject to the VGP because these operations are not incidental to the normal operation of a vessel 

engaged in a capacity of transportation). 

3.1.1.4 Large Cruise Ships 

Large cruise ships are the largest vessels (by size) covered under the VGP. Median vessel 

tonnage (53,526 gross tons) is approximately twice that of even the large oil and gas tankers. 

While the actual number of large cruise ships seeking coverage under the 2008 VGP is low (only 

127 vessels), the number of crew and passengers aboard is relatively high - approximately 

3,500 per vessel. Because of the large number of crew and passengers living on-board cruise 

ships, graywater generation can average nearly 600 m3

/day (158,500 gal/day). Median ballast 

water capacity of large cruise ships vessels is moderate (3,136 m3

). A high percentage of large 

 

4 Public Law 110-299 subsequently extended by Public Law 111-215 provided for a temporary moratorium on NPDES 

permitting for all commercial fishing vessels. The moratorium on NPDES permitting for commercial fishing vessels expires on 

December 18, 2013 and therefore all commercial fishing vessels larger than 79 feet will be required to obtain permit coverage 

under the VGP in the event the moratorium is not extended. 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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cruise ships also use AFC. Moreover, since aesthetics are important to the industry, deck 

washdowns may be performed more frequently on cruise ships than other types of vessels. All of 

these factors support detailed consideration of large cruise ships in this BE. 

3.1.1.5 Medium Cruise Ships 

Medium cruise ships are those ships authorized to carry 100 to 499 passengers for hire 

and provide overnight accommodations to those passengers. Although only 22 medium cruise 

ships are included in EPA’s NOI database, these vessels are relatively large, ranging in size from 

approximately 1,500 gross tons up to 5,000 gross tons, and have ballast capacities ranging from 

approximately 350 to 400 m3

. With passenger and crew capacities up to 499 persons, medium 

cruise ships have the potential to generate more than 20,000 gallons/day of graywater. Untreated 

graywater from medium cruise ships has been shown to contain similar pollutants to those in 

untreated graywater discharges from large cruise ships (ADEC, 2006 and ADEC, 2007a). In 

addition, most medium cruise ships use AFC to prevent biofouling of the vessel hull. Because of 

these issues, medium cruise ships warrant detailed consideration in this BE. 

3.1.1.6 Large Ferries 

Large ferries are vessels for hire that are designed to carry passengers and/or vehicles 

between two ports, usually in inland, coastal, or nearshore waters. For purposes of the VGP, 

large ferries are those ferries authorized to carry a) more than 100 tons of cars, trucks, trains, or 

other land-based transportation or b) 250 or more people. Large ferries usually travel the same 

route several times a day but do not provide overnight accommodations to their passengers. 

Because many ferries can travel the same route several times per day, they can discharge 

pollutants from a variety of sources (e.g., graywater, bilgewater, and seawater engine and 

exhaust cooling) to same water body. Because of these potential discharges, large ferries warrant 

detailed analysis in this BE. 

3.1.1.7 Cargo [Bulk] and Other Carriers 

Cargo carriers (e.g., bulk carrier, freighters, roll-on/roll-off, container ships) comprise the 

majority of the “Other” vessels classified in the NOI database. The attributes of this group of 

vessels are similar to those of the oil and gas tankers in terms of vessel size (median tonnage 

equal to approximately 16,000 gross tons) and median ballast water capacity (10,198 m3

). 

Approximately 61 percent of the owners/operators of these vessels reported using on-board 

treatment systems to treat the various waste streams aboard the vessels, and fewer use AFC. 

Their ballast water capacity and prevalence at certain ports warrant detailed analysis of these 

vessels in the BE. 

3.1.1.8 Emergency and Research Vessels 

The emergency and research vessels types include relatively few numbers of vessels and 

are relatively small in size, ballast capacity, and number of passengers/crew. Additionally, these 

vessels do not tend to engage on longer voyages where they can serve as a vector for invasive 

species (exceptions on voyage movements include large research vessels such as those operated 

by NOAA and the maritime services industry). Furthermore, the areas of operation for these 

vessels are not centrally located in any one home port or region. For these reasons, EPA 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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considers discharges from these vessels to be discountable for purposes of the Endangered 

Species Act and does not consider that these vessel types warrant extensive analysis in the BE. 

3.1.2 sVGP Vessels

EPA estimates that between 115,000 and 138,000 vessels may be covered by the sVGP. 

Approximately half of these vessels are commercial fishing vessels involved in such activities as 

fish catching (e.g., longliner, shrimper, and trawler), fish processing, fishing tenders, and charter 

fishing. The other half are distributed among a variety of vessel types, including passenger 

vessels (e.g., water taxis, tour boats, harbor cruise ships, dive boats), utility vessels (e.g., tug/tow 

boats, research vessels, offshore supply boats), and freight barges (USEPA, 2011b). The primary 

source of information used to characterize these vessels and their discharges is EPA’s Study 

Report to Congress: Study of Discharges Incidental to Normal Operation of Commercial Fishing 

Vessels and Other Non-recreational Vessels Less than 79 Feet (USEPA, 2010). In conducting 

this study, EPA sampled discharges from a total of 61 vessels in nine vessel types. To select 

vessel types for evaluation, EPA first developed a list of commercial vessel types based on 

published information and the EPA team’s existing understanding of vessels. Next, EPA 

narrowed the sampling scope to focus largely on those vessel types believed to consist primarily 

of vessels less than 79 feet in length. Some examples of vessel types on which EPA did not 

focus, due to their size, include cable laying ships, cruise ships, large ferries, oil and petroleum 

tankers, and freight ships/barges (because most vessels in these types are typically greater than 

79 feet in length). Next, EPA eliminated vessel types outside the scope of study vessels, 

including stationary seafood processing vessels and vessels that can be secured to the ocean floor 

for mineral or oil exploration (because the industrial discharges from these vessels were outside 

the scope of the previous 40 CFR Part 122.3(a) exclusion). After eliminating these vessels, the 

following common vessel types were selected for evaluation: 

 Commercial fishing vessels and tenders (all major types, e.g., seiners, trawler, 

trollers), 

 Tugs/towing vessels, 

 Water taxis/small ferries, and 

 Tour boats. 

Table 3-2 summarizes key attributes from USCG’s MISLE5

 database for the following 

three types of sVGP vessels, which encompass the priority vessel types listed above: 

 Commercial fishing (seiners, trawlers, trollers) 

 Passenger (excursion/tour boats, water taxis) 

 Utility (tow/salvage boats, tugboats, supply boats) 

The fourth type of sVGP vessels, public vessels, generate similar discharges as other sVGP 

vessels but are relatively few in number. Like Emergency and Research vessels covered under 

the VGP, the areas of operation for these vessels are not centrally located in any one home port 

 

5

 The U.S. Coast Guard’s Marine Information for Safety and Law Enforcement (MISLE) database provides a wide range of 

information regarding vessel and facility characteristics, accidents, marine pollution incidents, and other pertinent information 

tracked by the U.S. Coast Guard. The USCG MISLE database provides information on a wide ensemble of vessels, including 

identification numbers, vessel category, size, area of operation, passenger and crew capacity, propulsion method, construction 

material and design, and year built or age. 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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or region and the smaller public vessels do not generally undertake long voyages. For these 

reasons, EPA considers discharges from these vessel types to be discountable for purposes of the 

Endangered Species Act and does not consider that public vessels warrant extensive analysis in 

the BE.

While VGP and sVGP vessels have similar vessel operations and processes and generate 

similar incidental discharges, VGP discharges greatly exceed those of sVGP vessels on a per 

vessel basis due to their larger size and greater likelihood for generating a larger range of 

discharge types. For example, Section 3.2.2 below compares VGP and sVGP vessel discharge 

flow rates on a per vessel basis. However, the significantly greater number of sVGP vessels 

(between 115,000 and 138,000 vessels) as compared to the number of VGP vessels (71,000 

domestically and foreign flagged vessels) warrant selection of sVGP vessels for detailed analysis 

for this BE. Appendix D of the Report to Congress presents additional vessel characterization 

information, including summaries of vessel subtypes, the hailing port of domestically flagged 

vessels, and information on construction and propulsion of these vessels, including the vessel 

age, hull material type, propulsion method and type, and horsepower ahead (rated power of a 

vessel’s engine). Vessel age generally indicates the type and performance of equipment used 

onboard and the characteristics of discharges from this equipment. Type of hull material affects 

the type of AFCs that are applied and has implications on vessel discharges. For example, steelhulled vessels often have an anti-corrosive as well as anti-foulant coating. Self-propelled vessels 

that use mechanical propulsion methods have one or more engines, propeller shafts, and 

propulsion fuel tanks, all of which would affect the characteristics of discharges under normal 

operations. Finally, engine power may determine the amount and characteristics of discharges 

from operating vessels by affecting the size, type, and complexity of onboard propulsion 

equipment. 

Table 3-2. Number of Vessels <79 feet in Length by Vessel Type 

Vessel Type Other Primary Type Description Number of Vessels 

Commercial Fishing Vessel 

Fish Catching Vessela

 67,090 

Fishing Catching/Processing Vessel 178 

General 174 

Motor Propelled Vessels 155 

Fishing Support Vessel 116 

Passenger Vessel 

General 12,559 

Charter Fishing Vessel 2,053 

Excursion/Tour Vessel 1,233 

Diving Vessel (Recreational) 305 

Water Taxi 298 

Public Vessel, Unclassified 

General 145 

Law Enforcement (Non-military) Vessel 47 

Buoy/Lighthouse Tender 16 

Search and Rescue Vessel 14 

Patrol Ship 10 
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Table 3-2. Number of Vessels <79 feet in Length by Vessel Type 

Vessel Type Other Primary Type Description Number of Vessels 

Utility Vessel 

Towing Vessel (includes tugboats) 7,372 

Offshore Supply 650 

Research Ship 488 

Barge 396 

School Ship 60 

Source: Modified from Table B.1 in Report to Congress (USEPA, 2010) based on U.S. Coast Guard MISLE 

database, 2009. 

a) Fish catching vessel numbers from sVGP Fact Sheet and include those from MISLE database that indicated a 

length of zero or the vessel length field is blank. Fish catching vessels do not include processing vessels, 

general, motor propelled vessels and fishing support vessels. 

3.2 VESSEL DISCHARGES MERITING DETAILED ANALYSIS

This section describes EPA’s rationale for selecting for detailed evaluation various 

discharges incidental to the normal operation of the VGP and sVGP vessels. The section also 

provides estimated discharge volume by discharge for use in calculating pollutant discharge 

loadings. 

3.2.1 Vessel Discharge Selection 

EPA used the following three general criteria to select the subset of discharges incidental 

to the normal operation of VGP and sVGP vessels of greatest significance to the BE: 

1) Number and types of vessels discharging; 

2) Discharge volume and frequency; and 

3) Types of pollutants and their concentrations in vessel discharges. 

EPA used a “high” (or in the case of pollutants “potentially high”) or “low” screening 

level classification scheme in evaluating vessel discharges based on the best available data and 

information including scientific literature, government publications, and direct experience with 

vessel discharges. EPA used the “potentially high” classification for pollutants so that the 

Agency could take a more conservative approach with this category (i.e., determine types of 

pollutants could be considered “potentially high” based upon empirical evidence, limited data 

sets, or in the face of uncertainty). Using this approach, EPA conducted a case-by-case analysis, 

where we used best professional judgment, significantly informed by this screening level rating 

system to evaluate whether the discharge should be selected for detailed analysis for the BE. The 

examples below describe the analysis. 

Example 1: Stern Tube Packing Gland Effluent and Other Oil/Water Interfaces– Stern 

tube packing gland effluent and effluent from oil/water interfaces are generated on many vessels 

having inboard engines and propeller shafts that protrude through the bases of the stern below 

the water line or have rudders, rudder bearings and lubricated equipment below the water line 

(Number of Vessels Discharging = High). Although the stern tube effluent volume (2 to 4 

gallons per day) is low, it is generated nearly continuously while the vessel is operating 

(Discharge Volume and Frequency = High). Stern tube packing gland effluent , together with the 
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discharge associated with oil/water interfaces, may contain metals, oil and greases, suspended 

solids and phthalates (Amount and Types of Pollutants Present in the Discharge = Potentially 

High). The stern tube packing gland effluent and discharges from other oil/water interfaces were 

selected as a discharge that warrants detailed analysis in the BE because it received a “high” or 

“potentially high” score for all three screening categories. 

Example 2: Firemain Discharges - Firemain systems are available on most vessels 

covered by the VGP and sVGP (Number of Vessels Discharging = High). While firemain 

systems can generate large volumes of water during use, these systems are seldom used for 

fighting fires or even testing (Discharge Volume and Frequency = Low). In addition, firemain 

systems use ambient water (e.g., seawater) for fighting fires, and most of the pollutants measured 

in the firemain discharge can be attributed to the ambient water (Amount and Types of Pollutants 

Present in the Discharge = Low) (USEPA, 2010). Therefore, firemain discharge was not be 

selected as a discharge that warrants detailed analysis for the BE because it received a “high” or 

“potentially high” score for only one of the three screening categories and that category was the 

number of vessels discharging – EPA expects both the pollutants contained within the discharge 

and the volume of the discharge to both be discountable for purposes of the Endangered Species 

Act. (Note that firemain discharges resulting from use of the firemain for deck washing as 

considered deckwash.) 

Table 3-3 lists each of the incidental vessel discharges and screening level information 

used to select discharges for detailed analysis. As shown in Table 3-3, EPA selected the 

following nine discharges as warranting detailed analysis. Accordingly, these discharges will 

serve as the basis for determining the pollutants/constituents upon which the effects analysis and 

effects determinations in this BE will be primarily based. 

 Anti-Fouling Leachate from Anti-Fouling Hull Coatings 

 Ballast water 

 Bilgewater 

 Chair locker effluent 

 Deck washdown 

 Engine wet exhaust effluent 

 Exhaust gas scrubber washwater 

 Fish hold and fish hold cleaning effluent 

 Graywater 

 Stern tube packing gland effluent and discharges from other oil/water interfaces 

 Underwater ship husbandry discharges 
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Table 3-3. Screening Analysis to Select Vessel Discharges for Detailed Analysis for the BE 

Vessel Discharge Description

Screening Level Classification

Number of 

Vessels 

Discharginga

Discharge Volume and Frequency

Amou

Typ

Pollu

Presen

Disch

Anti-Fouling Leachate from Anti-Fouling Hull Coatings 

Anti-fouling coatings are applied to the vessel hull and sea water piping systems to limit attachment of aquatic species. Virtually all vessels that are permanently kept in saltwater use anti-fouling coatings. Biocides such as copper contained in anti-fouling coatings continuously leach into surrounding waters. 

High Highb Potential

Aqueous Film Forming Foam (AFFF) 

Firefighting agent added to fire suppression systems on some vessels to create foam. Used infrequently (annually or semiannually) to test equipment for maintenance, certification, or training. Constituents include fluorosurfactants and/or fluoroproteins. 

Low Lowc Potential

Ballast Water Ballast water is water taken onboard in large volumes on 

large numbers of commercial vessels to assist with vessel draft, buoyancy, and stability. Ballast capacities vary by vessel type, for example more than 20 million gallons for container ships. Ballast water is a known transport vector for ANS and can also contain metals and suspended solids. 

High Highe Potential

Bilgewater Bilgewater is generated by all vessels and consists of water 

and other residue that accumulates in a compartment of the vessel’s hull. The source of bilgewater is typically drainage from interior machinery, engine rooms, and from deck drainage. Bilgewater typically contains seawater, oil, grease, 

nutrients, volatile and semi-volatile organic compounds, inorganic salts, and metals. 

High Highf Potential
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Table 3-3. Screening Analysis to Select Vessel Discharges for Detailed Analysis for the BE 

Vessel Discharge Description

Screening Level Classification

Number of 

Vessels 

Discharginga

Discharge Volume and Frequency

Amou

Typ

Pollu

Presen

Disch

Boiler/Economizer Blowdown 

Boiler blowdown occurs on vessels with steam propulsion or a steam generator and is used to control the concentration of scaling constituents in boiler systems. Boiler blowdown are infrequent, of short duration (seconds), in small volumes, and at high pressure. The blowdown can contain water and steam or sludge-bearing water at elevated temperatures (above 325°F). The discharge can contain metals or boiler water treatment chemicals. 

Low Lowg Lowg 

Cathodic Protection Nearly all vessels having steel hulls or metal hull appendages 

use cathodic protection systems to prevent corrosion. Based on underwater hull inspections and maintenance records, one-half of anodes are consumed after three years. The primary pollutant released from cathodic protection is zinc. Average pierside and underway zinc generation rates are 1.3 x 10-6 and 5.1 x 10-6 (lb zinc/square foot of underwater 

surface area)/hr, respectively. 

High Lowi Lowi 

Chain Locker Effluent Chain locker effluent is water that drips from the anchor 

chain and anchor during anchor retrieval. Discharge volumes are small and chain locker effluent is expected to contain 

zinc, rust, paint, grease, and any constituents from the firemain water. The small volume of chain locker effluent results in small mass loadings and provides opportunity for the transfer of non-indigenous species. 

High Lowk Lowk 
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Table 3-3. Screening Analysis to Select Vessel Discharges for Detailed Analysis for the BE 

Vessel Discharge Description

Screening Level Classification

Number of 

Vessels 

Discharginga

Discharge Volume and Frequency

Amou

Typ

Pollu

Presen

Disch

Coal Ash from Coal Fired Propulsion Systems on Ferries 

Combusting coal in boilers produces a residue of combustible flue constituents known as ash. Some of the ash consists of very fine particles that are entrained in the flue gas and carries out of the furnace (fly ash), while heavier ash settles at the bottom of the boiler (bottom ash). Bottom ash may be hydraulically conveyed (i.e., sluiced with water). The 

discharge of coal ash slurry from coal fired propulsion systems on a ferry is authorized by the 2008 VGP until December 19, 2012. 

Low

m High

m Potential

Deck Washdowno Deck washdown occurs from all vessels as a result of deck 

cleaning. Constituents in the discharge can include detergent, soap, deck surface components (e.g., rust, paint chips) and anything dropped, spilled, dripped, or scattered onto the deck surface. 

High Highp Potential

Distillation and Reverse Osmosis Brine 

Discharges of brine can occur on vessels that do not bunker potable water but instead use onboard plants to distill seawater or desalinate seawater using reverse osmosis (RO) to generate fresh water. Distillation units generate brine at a rate of 17 gallons of brine for every gallon of fresh water produced. Reverse osmosis units generate approximately 4 gallons of brine for every gallon of fresh water produced. The three sources of the constituents of brine discharge are: 1) influent seawater; 2) anti-scaling treatment chemicals; and 3) the purification plant components, including heat exchangers, casings, pumps, piping and fittings. The primary constituents of the brine discharge are identical to those in seawater; however, they are more concentrated due to volume reduction. 

Low Highq,r Lowq,r 
2013 VGP and sVGP BE Section 3– Biologica

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Table 3-3. Screening Analysis to Select Vessel Discharges for Detailed Analysis for the BE 

Vessel Discharge Description

Screening Level Classification

Number of 

Vessels 

Discharginga

Discharge Volume and Frequency

Amou

Typ

Pollu

Presen

Disch

Elevator Pit Effluent Large vessels with multiple decks are equipped with 

elevators to facilitate the transportation of maintenance equipment, people, and cargo between decks. A pit at the bottom of the elevator shaft collects small amounts of liquids and debris from elevator operations and deck washdown and runoff depending on the elevator configuration. Water entering the elevator pit can contain materials that were on the deck, including fuel, hydraulic fluid, lubricating oil, residual water, and AFFF. The runoff may also contain lubricant applied to the elevator doors, door tracks, and other moving elevator parts. Residue in the elevator car from the transport of materials may also be washed into the elevator pit. The cleaning solvent used during maintenance cleaning operations, as well as liquid wastes generated by the cleaning process, can also drain into the elevator pit sump. 

Low Lowt Potential

Engine Wet Exhaust Effluent 

Engine wet exhaust effluent is generated when gasoline or diesel engine cooling water is injected into the engine exhaust. The engine cooling water decreases the exhaust temperature, reduces engine noise and reduces exhaust emissions. Engine wet exhaust discharge rates can range from 5 to 10 gallons per minute for electrical generators to more than 100 gallons per minute on larger diesel engines operating at high inputs. Most passenger vessels, a large number of fishing vessels, and utility vessels use engines that generate wet engine exhaust. Large commercial vessels occasionally operate small auxiliary craft that discharge engine wet exhaust (e.g., life boats on cruise ships); however, discharge volumes for these vessels are negligible. Pollutants in the engine wet exhaust can include oil and grease, metals, volatile organic compounds and semi volatile organic compounds. 

High Highv Potential
2013 VGP and sVGP BE Section 3– Biologica

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Table 3-3. Screening Analysis to Select Vessel Discharges for Detailed Analysis for the BE 

Vessel Discharge Description

Screening Level Classification

Number of 

Vessels 

Discharginga

Discharge Volume and Frequency

Amou

Typ

Pollu

Presen

Disch

Exhaust Gas Scrubber Washwater Effluent 

Exhaust gas scrubber washwater discharge occurs as a result of cleaning the exhaust gas system on marine diesel engines. The washwater discharge can be highly acidic, and can also contain traces of oil, polycyclic aromatic hydrocarbons (PAHs), heavy metals and nitrogen. Washwater volumes of 

2.8 million gallons per day are estimated from a 10 MWh engine. 

Loww Highx Potential

Firemain Systems Firemain systems are found on a large number of vessels and 

draw in water through the sea chest to supply water for fire hose stations and sprinkler systems. Systems are activated during testing or during an actual fire. Small amounts of metals may be added to the fire water from vessel piping system. 

High Lowy Lowz 

Fish Hold and Fish Hold Cleaning Effluent 

All fishing vessels generate some form of fish hold effluent. Fish hold effluent is composed of seawater, ice-melt, or ice slurry collected inside fish hold tanks. Fish hold effluent contains pollutants which result from seafood catch and other onboard vessel sources. These pollutants can include biological wastes, metals, and nutrients, as well as wastewater resulting from fish hold cleaning activities. The volume of fish hold effluent can vary from less than 100 gallons during off-loading to tens of thousands of gallons for large fish tenders. 

High Highbb Potential
2013 VGP and sVGP BE Section 3– Biologica

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Table 3-3. Screening Analysis to Select Vessel Discharges for Detailed Analysis for the BE 

Vessel Discharge Description

Screening Level Classification

Number of 

Vessels 

Discharginga

Discharge Volume and Frequency

Amou

Typ

Pollu

Presen

Disch

Freshwater Layup Freshwater layup is generated when a vessel is pier side or in 

port for more than a few days, the main steam plant is shut down, and the condensers do not circulate. A freshwater layup includes replacing the seawater in the system with 

potable or surrounding freshwater (e.g., lake water). Freshwater layup discharges can be as large as 6,000 gallons per evolution and can contain residual saltwater, freshwater, tap water, and possibly metals leached from the pipes or machinery. 

Low Lowcc Lowcc 

Gas Turbine Water Wash 

Gas turbines are used for propulsion and electricity generation on some vessels. Occasionally, they must be cleaned to remove byproducts that can accumulate and affect 

their operation. Although not subject to the VGP but similar in operation to VGP vessels regarding this discharge, large naval vessels can generate up to 244 gallons of washwater per day. Wash water can include salts, lubricants, and combustion residuals. 

Low Lowee Potential

Graywater and Graywater Mixed with Sewage 

Nearly all VGP/sVGP vessels generate some form of graywater. Graywater is water from showers, baths, sinks, galleys, and laundry facilities. Graywater volumes vary depending on the number of passengers on board and can range from a few gallons per day on small fishing vessels to tens of thousands of gallons per day on large cruise ships. Graywater can contain high levels of pathogens, nutrients, soaps and detergents, and organics. 

High Highgg Potential
2013 VGP and sVGP BE Section 3– Biologica

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Table 3-3. Screening Analysis to Select Vessel Discharges for Detailed Analysis for the BE 

Vessel Discharge Description

Screening Level Classification

Number of 

Vessels 

Discharginga

Discharge Volume and Frequency

Amou

Typ

Pollu

Presen

Disch

Motor Gasoline and Compensating Discharge 

Motor gasoline is transported on vessels to operate vehicles and other machinery. As the fuel is used, ambient water is added to the fuel tanks to replace the weight. This ambient water is discharged when the vessel refills the tanks with gasoline or when performing maintenance. Most vessels are designed not to have motor gasoline and compensating discharge. The volume of the compensating discharge is expected to range from less than 50 gallons to up a few hundred gallons. The discharge can contain small amounts of fuel and other fuel-related pollutants. 

Low Lowhh Potential

Non-oily Machinery Wastewater 

Some larger vessels are expected to have some non-oily machinery discharges, such as distilling plants start-up discharge, chilled water condensate drains, fresh- and saltwater pump drains, and potable water tank overflows. These flows are generally low in volume and are not expected to contain significant amounts of pollutants. 

Low Lowjj Lowjj 

Refrigeration and Air Condensate Discharge 

Condensation from cold refrigeration or evaporator coils of 

air conditioning systems drips from the coils and collects in 

drip troughs which typically empty to a drainage system. Large numbers of vessels are equipped with refrigeration systems to keep food and other perishable items from spoiling. Air conditioning systems are also used for passenger and crew comfort. Condensates may contain very small amounts of pollutants such as metals derived from vessel piping systems. 

High Lowll Lowll 
2013 VGP and sVGP BE Section 3– Biologica

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Table 3-3. Screening Analysis to Select Vessel Discharges for Detailed Analysis for the BE 

Vessel Discharge Description

Screening Level Classification

Number of 

Vessels 

Discharginga

Discharge Volume and Frequency

Amou

Typ

Pollu

Presen

Disch

Seawater Cooling Overboard Dischargenn

Seawater cooling systems use ambient water to absorb the heat from heat exchangers, propulsion systems, and mechanical auxiliary systems. The water is typically circulated through an enclosed system that does not come in direct contact with machinery, but still may contain sediment from water intake, traces of hydraulic or lubricating oils, and trace metals leached or eroded from the piping within the system. Additionally, because it is used for cooling, the effluent will have an increased temperature. 

High Low Lowoo 

Seawater Piping Biofoulingqq

Some vessels that use seawater cooling systems introduce anti-fouling compounds (e.g., sodium hypochlorite) in their interior piping and component surfaces to inhibit the growth 

of fouling organisms. These anti-fouling compounds are then typically discharged overboard. Most vessels that have seawater piping systems are expected to use piping materials such as copper to prevent biofouling rather than injecting high concentrations of anti-fouling compounds into their piping systems. 

Low Low Potential

Sonar Dome Discharge Water is used to maintain the shape and pressure of domes 

that house sonar detection, navigation, and ranging equipment on large vessels. Discharges occasionally occur when the water must be drained for maintenance or repair or from the exterior of the sonar dome. Although not subject to the VGP but similar in operation to VGP vessels regarding this discharge, sonar dome discharge volumes on naval vessels can range from 300 gallons per event up to 74,000 gallons per event. Pollutant levels are expected to be low due to the ban on the use of tributyl tin. 

Low Lowtt Lowtt 
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Table 3-3. Screening Analysis to Select Vessel Discharges for Detailed Analysis for the BE 

Vessel Discharge Description

Screening Level Classification

Number of 

Vessels 

Discharginga

Discharge Volume and Frequency

Amou

Typ

Pollu

Presen

Disch

Stern Tube Packing Gland Effluent and Other Oil/Water Interfaces 

Nearly all commercial vessels with in-board engines have stern tube packing gland(s) surrounding the propeller shaft(s). The stern tube packing gland is designed to leak a few drops per minute of ambient water (4 to 8 gallons per day) to the cool the gland when the vessel is underway. Pollutants in the stern tube packing gland effluent include metals, oil and grease, suspended solids, organics, and phthalates. Oil to sea interfaces include any mechanical or other equipment where seals or surfaces may release small quantities of oil and grease into the sea. Examples include controllable pitch propellers, rudder bearings and wire ropes and cables that have lubricated (greased) surfaces which are submerged in seawater during use. 

High Highvv Potential

Underwater Ship Husbandry Discharges 

Underwater ship husbandry is grooming, maintenance, and repair activities of hulls or hull appendages performed while the vessel is located in the water. Underwater ship husbandry discharges can contain aquatic organisms and residue such as rust and biocide from AFC. Underwater ship husbandry is typically performed only when excessive biological growth is causing vessel drag and excessive fuel consumption outside of regular dry dock inspections. 

Low Lowww Potential
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Table 3-3. Screening Analysis to Select Vessel Discharges for Detailed Analysis for the BE 

Vessel Discharge Description

Screening Level Classification

Number of 

Vessels 

Discharginga

Discharge Volume and Frequency

Amou

Typ

Pollu

Presen

Disch

Well Deck Discharges The welldeck is a floodable platform used for launching or 

loading small satellite vessels, vehicles, and cargo from select vessels. Welldeck discharges may include water from precipitation, welldeck and storage area washdowns, equipment and engine washdowns, and leaks and spills from stored machinery. Potential constituents of welldeck discharges include fresh water, distilled water, firemain water, graywater, air-conditioning condensate, sea-salt residues, paint chips, wood splinters, dirt, sand, organic debris and marine organisms, oil, grease, fuel, detergents, combustion by-products, and lumber treatment chemicals. 

Low High Lowzz 

a) USEPA, Summary of the VGP Vessel Universe: Information Submitted by Vessel Owner/Operators for Coverage Under the Vessel General Permit (V

K-11-102 (USEPA, 2011e). Sources for vessels that do not need to submit NOIs include the USCG MISLE database and USEPA, Report to Congress

Incidental to Normal Operation of Commercial Fishing Vessels and Other Non-Recreational Vessels Less than 79 Feet, EPA-833-R-10-005, August 2

b) USEPA, Technical Development Document (TDD): Underwater Ship Husbandry Discharges, EPA-800-R-11-004, November 2011 (USEPA, 2011f). 

classified as high, based on consideration of the volume of water potentially influenced by anti-fouling coatings as the vessel floats on and moves thro

c) USEPA, National Pollutant Discharge Elimination System (NPDES) Vessel General Permit (VGP) for Discharges Incidental to the Normal Operation 

November 2011 (USEPA, 2011a). 

d) Firefighting agent added to fire suppression systems on some vessels to create foam. While large quantities of fire fighting foam can be generated duri

used infrequently (annually or semi-annually) and often outside waters of the U.S. to test equipment for maintenance, certification, or training. AFFFs 

and/or fluoroproteins, such as perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA), which are persistent bioaccumulative and toxic crequirements to collect and store AFFF for onshore disposal, or to use a substitute foaming agent (i.e., non-fluorinated), for discharges associated with 

inspection will significantly reduce the amount and types of pollutants present in the discharge. For these reasons, EPA did not select AFFF discharge BE. 

e) USEPA, Technical Development Document (TDD): Ballast Water Discharges from Vessels, EPA-800-R-11-003, November 2011 (USEPA, 2011g). 

f) USEPA, Technical Development Document (TDD): Oily Bilgewater Separators, EPA-800-R-11-007, November 2011 (USEPA, 2011h). g) USEPA, Technical Development Document (TDD): Phase I Uniform National Discharge Standards (UNDS) for Vessels of the Armed Forces, Nature 

Blowdown. EPA 821-R-99-001, April 1999 (USEPA, 1999). 

h) EPA did not select boiler/economizer blowdown for detailed analysis in this BE because all three screening categories were assessed a “low” score. i) USEPA, Technical Development Document (TDD): Phase I Uniform National Discharge Standards (UNDS) for Vessels of the Armed Forces, Nature 

Cathodic Protection. EPA 821-R-99-001, April 1999 (USEPA, 1999). 

j) While nearly all VGP and sVGP vessels having steel hulls or metal hull appendages are expected to use cathodic protection, the cathode release rates 

While zinc is a toxic metal, it is not a persistent bioaccumulative and toxic chemical. Furthermore, permit requirements, including use of impressed cu
2013 VGP and sVGP BE Section 3– Biologica

3-21 

(ICCP) in place of or to reduce the use of sacrificial electrodes when technologically feasible, will minimize the release of cathode metals to water. Fo

select AFFF discharge for detailed analysis in this BE. 

k) USEPA, Technical Development Document (TDD): Phase I Uniform National Discharge Standards (UNDS) for Vessels of the Armed Forces, Nature 

Locker Effluent. EPA 821-R-99-001, April 1999 (USEPA, 1999). 

l) While chain locker effluent discharge is infrequent with relatively low discharge volumes, EPA selected this discharge for detailed analysis in this BE 

transfer of ANS. 

m) The S.S. Badger (a Great Lakes ferry) is believed to be the only coal-fired vessel operating in the U.S. (all other coal-fired vessels are either no longer 

to other forms of propulsion). Lake Michigan Car Ferry, Inc., SS Badger Petition for Individual NPDES Permit. November 2, 2011 (LMC, 2011). 

n) EPA did not select coal ash from coal fired propulsion systems on ferries for detailed analysis because the discharge is not authorized by the 2013 VG

o) Deck runoff resulting from precipitation was not included because the discharge volume is highly variable and is not expected to result in the same ext

removal and discharge as deck washdown. 

p) USEPA, Report to Congress: Study of Discharges Incidental to Normal Operation of Commercial Fishing Vessels and Other Non Recreational Vessel

R-10-005, August 2010 (USEPA, 2010). 

q) USEPA, Technical Development Document (TDD): Phase I Uniform National Discharge Standards (UNDS) for Vessels of the Armed Forces, Nature 

Distillation and Reverse Osmosis Brine. EPA 821-R-99-001, April 1999 (USEPA, 1999). 

r) Although the concentrations of constituents measured in distillation and reverse osmosis brine may be high, they are similar in concentration to those 

distillation and reverse osmosis systems do not add pollutants, but rather increase pollutant concentrations due to water removal. 

s) Distillation and reverse osmosis brine discharges are applicable for only those vessels that use onboard plants to generate fresh water. While brine disc

significant during water production, pollutants in the brine can be attributed to the ambient water. Therefore, distillation and reverse osmosis brine discdischarge that warrants detailed analysis for the BE because EPA assessed a “high” score for only one screening category (discharge volume and frequconsiders the pollutants contained in the discharge to be discountable for purposes of the Endangered Species Act. 

t) USEPA, Technical Development Document (TDD): Phase I Uniform National Discharge Standards (UNDS) for Vessels of the Armed Forces, Nature 

Elevator Pit Effluent. EPA 821-R-99-001, April 1999 (USEPA, 1999). 

u) Large vessels with multiple decks may be equipped with exposed elevators that generate relatively small volumes of elevator pit effluent that is discha

elevator pit effluent may contain toxic and hazardous pollutants, such as lubricants and cleaning solvents, permit requirements authorizing discharge owill minimize the release of these pollutants. For these reasons, EPA did not select elevator pit effluent discharge for detailed analysis in this BE. 

v) Flows and pollutant concentrations from USEPA, Report to Congress: Study of Discharges Incidental to Normal Operation of Commercial Fishing Ve

Recreational Vessels less than 79 Feet, EPA-833-R-10-005, August 2010 (USEPA, 2010). 

w) Currently, no vessels currently use exhaust gas scrubbers on their marine diesel engines (prototype SOx scrubbers have been installed onboard three la

USEPA, 2009); however, these numbers may increase significantly with future International Maritime Organization requirements. 

x) USEPA, Technical Development Document (TDD): Exhaust Gas Scrubber Washwater Effluent, EPA-800-R-11-006, November 2011 (USEPA, 2011c

y) Wet-type firemain systems are frequently used as a water source for deck washing; however, the volume of water and any associated pollutants are ac

washdown discharge category. 

z) Pollutant concentrations from USEPA, Report to Congress: Study of Discharges Incidental to Normal Operation of Commercial Fishing Vessels and O

Vessels less than 79 Feet, EPA-833-R-10-005, August 2010 (USEPA, 2010). 

aa) Firemain systems are available on most vessels covered by the VGP and sVGP. While firemain systems can generate large volumes of water during us

used for fighting fires or even testing. In addition, firemain systems use ambient water for fighting fires, and most of the pollutants measured in the fir

attributed to the ambient water. Therefore, firemain discharge was not selected for detailed analysis for the BE because EPA assessed a “high” score focategory (number of vessels discharging) and because EPA considers both the volume of the discharge and the pollutants contained in the discharge to 

of the Endangered Species Act 

bb) Flows and pollutant concentrations in fish hold and fish hold cleaning wastewaters from USEPA, Report to Congress: Study of Discharges Incidental 

Commercial Fishing Vessels and Other Non Recreational Vessels less than 79 Feet, EPA-833-R-10-005, August 2010 (USEPA, 2010). 

cc) USEPA, Technical Development Document (TDD): Phase I Uniform National Discharge Standards (UNDS) for Vessels of the Armed Forces, Nature 

Freshwater Layup. EPA 821-R-99-001, April 1999 (USEPA, 1999). 

dd) EPA did not select freshwater layup for detailed analysis in this BE because all three screening categories were assessed a “low” score. 
2013 VGP and sVGP BE Section 3– Biologica

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ee) USEPA, Technical Development Document (TDD): Phase I Uniform National Discharge Standards (UNDS) for Vessels of the Armed Forces, Nature 

Turbine Wash Water. EPA 821-R-99-001, April 1999 (USEPA, 1999). 

ff) Gas turbine water wash discharges are applicable for only those vessels that use gas turbines. While discharges may contain lubricants and combustion 

are relatively small. Furthermore, permit requirements prohibit the discharge of gas turbine water wash into waters of the U.S. For these reasons, EPA 

discharge for detailed analysis in this BE. 

gg) USEPA, Cruise Ship Discharge Assessment Report. EPA 842-R-07-005, December 2008 (USEPA, 2008). 

hh) USEPA, Technical Development Document (TDD): Phase I Uniform National Discharge Standards (UNDS) for Vessels of the Armed Forces, Nature 

Gasoline (MOGAS) Compensating Discharge. EPA 821-R-99-001, April 1999 (USEPA, 1999). 

ii) Motor gasoline compensating discharges are applicable for only those vessels that transport motor gasoline to operate vehicles and other machinery; m

to have motor gasoline and compensating discharges. While discharges may contain fuel, discharge volumes are relatively small. Furthermore, permit discharge of motor gasoline and compensating effluent must not have oil in quantities that may be harmful as defined in 40 CFR 110.3, which includevisible sheen, or an oil concentration that exceeds 15 ppm. For these reasons, EPA did not select AFFF discharge for detailed analysis in this BE. 

jj) USEPA, Technical Development Document (TDD): Phase I Uniform National Discharge Standards (UNDS) for Vessels of the Armed Forces, Nature 

Oily Machinery Discharge. EPA 821-R-99-001, April 1999 (USEPA, 1999). 

kk) EPA did not select non-oily machinery wastewater for detailed analysis in this BE because all three screening categories were assessed a “low” score. ll) USEPA, Technical Development Document (TDD): Phase I Uniform National Discharge Standards (UNDS) for Vessels of the Armed Forces, Nature 

Refrigeration/Air Conditioning Condensate. EPA 821-R-99-001, April 1999 (USEPA, 1999). 

mm)Large numbers of VGP and sVGP vessels are equipped with refrigeration systems to keep food and other perishable items from spoiling. Air condition

passenger and crew comfort. Refrigeration and air condensate discharge was not selected for detailed analysis for the BE because EPA assessed a “higscreening category (number of vessels discharging) and because EPA considers both the volume of the discharge and the pollutants contained in the di

for purposes of the Endangered Species Act. 

nn) Discharge is for non-contact cooling only and does not include engine wet exhaust. oo) USEPA, Technical Development Document (TDD): Phase I Uniform National Discharge Standards (UNDS) for Vessels of the Armed Forces, Nature 

Seawater Cooling Overboard Discharge. EPA 821-R-99-001, April 1999 (USEPA, 1999). 

pp) Large numbers of VGP and sVGP vessels use ambient water for non-contact cooling of propulsion systems and other machinery and equipment. Seaw

discharge was not selected for detailed analysis for the BE because EPA assessed a “high” score for only one screening category (number of vessels diconsiders both the volume of the discharge and the pollutants contained in the discharge to be discountable for purposes of the Endangered Species Ac

qq) Discharge does not include anti-fouling coatings used to inhibit biogrowth on vessel hulls; such discharges are considered anti-fouling leachate. 

rr) Chlorine is typically dosed at a concentration in the mg/L range to prevent biological growth. ss) Some vessels introduce anti-fouling compounds (e.g., sodium hypochorite) in their interior piping and component surfaces to inhibit the growth of fou

chlorine is toxic it is not it is not a persistent bioaccumulative and toxic chemical. Furthermore, permit requirements, including minimizing the amoun

needed to keep fouling under control, will reduce the release of chlorine to water. For these reasons, EPA did not select seawater piping biofouling dis

in this BE. 

tt) USEPA, Technical Development Document (TDD): Phase I Uniform National Discharge Standards (UNDS) for Vessels of the Armed Forces, Nature 

Dome Discharge. EPA 821-R-99-001, April 1999 (USEPA, 1999). 

uu) EPA did not select sonar dome discharge for detailed analysis in this BE because all three screening categories were assessed a “low” score. 

vv) Flows and pollutant concentrations from USEPA, Report to Congress: Study of Discharges Incidental to Normal Operation of Commercial Fishing Ve

Recreational Vessels less than 79 Feet, EPA-833-R-10-005, August 2010 (USEPA, 2010). 

ww) Vessel cleaning is typically performed during scheduled dry docking. Source: USEPA, Technical Development Document (TDD): Underwater Hull H

004, November 2011 (USEPA, 2011f). 

xx) The biological growth and paint potentially released during underwater husbandry may contain significant amounts of pollutants (Schiff, 2003). yy) While underwater ship husbandry is typically performed only when excessive biological growth is cause vessel drag and excessive fuel consumption o

inspections, EPA selected this discharge for detailed analysis in this BE based on the potential for transfer of ANS. 

zz) Pollutants in well deck discharges are accounted for in other discharges, including deck washdown, refrigeration condensates, and oil/sea interfaces. 
2013 VGP and sVGP BE Section 3– Biologica

3-23 

aaa) Some vessels are equipped with well decks for launching or loading small satellite vessels, vehicles and cargo. Discharge volume and frequency are co

platforms are floodable; however, pollutants in well deck discharges are accounted for in other discharges, including deck washdown, refrigeration co

interfaces. For these reasons, EPA did not select well deck discharges for detailed analysis in this BE. 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

3-24 

3.2.2 Estimated Flow Rates for Discharges Selected for Detailed Analysis

One important component of the BE is to estimate the flow rate of the selected discharges 

from each vessel type analyzed in detail for the purpose of calculating pollutant discharge 

loadings to receiving waters. To estimate the discharge flow rates, EPA used information 

published in sources such as EPA’s Report to Congress on vessels less than 79 feet in length and 

commercial fishing vessels (USEPA, 2010), the Vessel General Permit Fact Sheet (USEPA, 

2011a), the Small Vessel General Permit Fact Sheet (USEPA, 2011b), EPA’s Cruise Ship 

Discharge Assessment Report (USEPA, 2008), EPA’s NOI database (USEPA, 2011e), and 

International Maritime Organization’s Marine Environment Protection Committee (MEPC, 

2008). Where flow rate data were not available for a specific discharge, or where available flow 

rate data were not applicable for all sizes and types of vessel, EPA used information from similar 

vessel discharge types, equipment vendor data, or used best professional judgment to estimate 

flow rates. 

The subsections below provide estimates of flow for 8 of the 11 discharges selected for 

detailed analysis for each selected vessel type. Anti-fouling leachate does not require a volume 

estimate to calculate pollutant loadings because the biocide loading to the surrounding surface 

water depends upon exposed vessel surface area rather than discharge flow rate. Chain locker 

effluent and underwater ship husbandry discharges volumes were not estimated because EPA has 

not found available data to accurately estimate volume of these discharges. Furthermore, the 

Agency is taking a qualitative rather than quantitative approach to assessing the risk of ANS to 

native species for the reasons discussed in Sections 5.1.1 and so volume data are not as 

analytically important as they are for the modeling conducted for the other discharge types. 

3.2.2.1 Ballast Water 

Ballast water is water taken onboard into ballast water tanks, and assists with vessel draft, 

buoyancy, and stability. Ballast water is taken from coastal port areas and transported with the 

ship to the next port of call where the water may be discharged or exchanged. If a ship is 

receiving or delivering cargo to a number of ports, it may release or take on a portion of ballast 

water at each port. Large commercial vessels (e.g., container ships, bulk carriers, other cargo 

vessels, tankers, and passenger vessels) normally have ballast tanks dedicated to this purpose, 

and some vessels may also ballast empty cargo holds. The discharge volume varies by vessel 

type, ballast tank capacity, and type of deballasting equipment. 

Table 3-4 provides estimates of ballast water discharge volumes based on median ballast 

water capacity for those vessels that have ballast tanks (USEPA, 2011e). Commercial fishing 

vessels less than 79 feet, passenger vessels, and utility vessels are not expected to have ballast 

water tanks greater than 8 cubic meters.6

 

 

6

 The U.S. Coast indicates that vessels less than 100 feet “typically operate in more sheltered environments and do not load and

discharge ballast. Their stability characteristics generally accommodate the amount and type of cargo they carry, precluding the 

need to use ballast as a stability enhancer.” (USCG, 2008) 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

3-25 

Table 3-4. Ballast Water Capacity for Vessels Selected for Detailed Analysis 

Vessel Type Median Ballast Water 

Capacity (m3) 

Median Ballast Water Capacity 

(gallons) 

Barges 206 54,400 

Cargo/Bulk Carriers 10,198 2,694,300 

Large Commercial Fishing 1,388 366,700 

Large Cruise Ships 3,136 828,500 

Medium Cruise Ships 364 96,200 

Large Ferries 404 106,700 

Oil and Gas Tankers 23,893 6,312,600 

Commercial Fishing (except large) <8 <2,100 

Passenger Vessels (e.g., water taxis, 

tour boats) 

<8 <2,100 

Utility Boats (tugs and tow boats) <8 <2,100 

Source: USEPA, 2011e. 

3.2.2.2 Bilgewater 

Bilgewater consists of water and other residue that accumulates in a compartment of the 

vessel’s hull. The source of bilgewater is typically drainage from interior machinery, engine 

rooms, and the weather deck. The amount of bilgewater generated by a vessel varies based on 

vessel size, age, and the amount below-deck mechanical systems; discharges typically occur 

several times per week. Cruise ship bilgewater volumes are estimated at 25,000 gallons per week 

(3,570 gal/day) (USEPA, 2008). Bilgewater discharges from fishing vessels are estimated to 

range from a few gallons per day up to 750 gallons/day (USEPA, 2010). Bilgewater water 

discharges rates for tour boats are approximately 11 gallons/day (0.04 m3

/day) and for water 

taxis are approximately 34 gallons/day (0.13 m3/day). Tow and salvage boats discharge 

approximately 37 gallons/day (0.139 m3/day) of bilgewater (USEPA, 2010). 

To estimate bilgewater flow rates for medium cruise ships, large ferries, barges, 

cargo/bulk carriers, and oil tankers, EPA compared the vessel gross tons (see Table 3-1) to large 

cruise ships and multiplied by the bilgewater generation rate for large cruise ships. The example 

below shows how daily bilgewater discharge was estimated for cargo/bulk carriers using 

information for large cruise ships. 

Example: 15,939 gross tons (cargo/bulk carrier)/53,526 gross tons (large cruise ship) x 3,570 

gal/day = 1,063 gal/day 

Table 3-5 provides the estimated bilgewater flow rates for each of the vessel types 

selected for detailed analysis. 

Table 3-5. Estimated Bilgewater Discharge Rates for the Vessels Selected for Detailed 

Analysis 

Vessel Type 

Estimated Bilgewater Discharge 

Rates (m3/day) 

Estimated Bilgewater Discharge 

Rates (gallons/day) 

Barges 0.18 47

Cargo/Bulk Carriers 4.0 1,063

Commercial Fishing 1.4 375

Large Cruise Ships 13.5 3,570
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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Table 3-5. Estimated Bilgewater Discharge Rates for the Vessels Selected for Detailed 

Analysis 

Vessel Type 

Estimated Bilgewater Discharge 

Rates (m3/day) 

Estimated Bilgewater Discharge 

Rates (gallons/day) 

Medium Cruise Ships 2.0 305

Large Ferries 2.0 97

Oil and Gas Tankers 6.3 1,661

Passenger Vessels (e.g., water 

taxis, tour boats) 0.08 22

Utility Boats (tugs and tow 

boats) 0.14 37

Source: USEPA, 2008 and USEPA, 2010. 

3.2.2.3 Deck Washdown 

Deck washdown occurs from all vessels because of deck cleaning. Deck washdown 

volumes vary widely and are highly dependent on a vessel’s purpose, service, and practices. To 

estimate deck washdown volumes, EPA used information for commercial fishing vessels, 

passenger vessels and utility boats (USEPA, 2010). For barges, cargo/bulk carriers, and oil and 

gas tankers, EPA estimated the deck washdown volumes by comparing vessel gross tons for 

these vessels (see Table 3-1) with the gross tons of a typical utility vessel. EPA estimated utility 

vessels are 80 gross tons based on 50% of the utility vessels being approximately 65 feet long 

(USEPA, 2010). For medium and large cruise ships and large ferries, EPA estimated deck 

washdown volumes by comparing vessel gross tons for these vessels with that of a typical 

passenger vessel. EPA estimated passenger vessels are 35 gross tons based on 50% of passenger 

vessels being 45 feet long (USEPA, 2010). The example below shows how EPA used the vessel 

gross tons and deck washdown discharge volume for passenger vessels to estimate the deck 

washdown flow for large ferries. 

Example: 1,451 gross tons (large ferry)/35 gross tons (passenger vessel) x 27 gal/day = 

1,083 gal/day

Table 3-6 shows the estimated daily volume of deck washdown water discharged from 

the vessels selected for detailed analysis. 

Table 3-6. Estimated Deck Washdown Discharge Rates for Vessels Selected for 

Detailed Analysis 

Vessel Type 

Estimated Deck Washdown 

Discharge Rate (m3/day) 

Estimated Deck Washdown 

Discharge Rate (gallons/day) 

Barges 0.88 232

Cargo/Bulk Carriers 19.9 5,259

Commercial Fishinga 0.39 103

Large Cruise Ships 152.9 40,396

Medium Cruise Ships 13.1 3,461

Large Ferries 4.1 1,083

Oil and Gas Tankers 31.1 8,216

Passenger Vessels (e.g., water 

taxis, tour boats)b 0.10 27
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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Table 3-6. Estimated Deck Washdown Discharge Rates for Vessels Selected for 

Detailed Analysis 

Vessel Type 

Estimated Deck Washdown 

Discharge Rate (m3/day) 

Estimated Deck Washdown 

Discharge Rate (gallons/day) 

Utility Boats (tugs and tow 

boats)c 0.05 14

Source: USEPA, 2010. 

a) Average discharge rate for a shrimper, trawler and troller. 

b) Average discharge rate for a tour boat and water taxi. 

c) Average discharge rate for a fire boat, supply boat, tow boat and tug boat. 

3.2.2.4 Engine Wet Exhaust Effluent 

Engines used on some commercial fishing vessels, passenger vessels and utility boats 

have inboard marine engines that use ambient water to cool their engines and quiet their exhaust. 

These include both propulsion engines and generator engines used to generate electricity on the 

vessel. Seawater, or freshwater, passes through portions of the engine (e.g., heat exchanger and 

gear oil cooler) and is then injected into the engines’ exhaust stream. When ejected from the 

engine, the water contains some of the gaseous and particulate (solid) components of the exhaust 

stream. Large engines, like those found on large ferries, medium and large cruise ships, tankers 

and cargo/bulk container ships use dry engine exhaust systems and therefore do not generate 

engine wet exhaust effluent. Barges do not have engines and therefore do not generate engine 

wet exhaust effluent. 

Table 3-7 shows the estimated volume of wet engine exhaust discharged from the vessels 

selected for detailed analysis (USEPA, 2010). 

Table 3-7. Estimated Propulsion and Generator Engine Wet Exhaust Discharge Rates 

for Vessels Selected for Detailed Analysis 

Vessel Type 

Estimated 

Propulsion Engine 

Wet Exhaust 

Discharge Rate 

(m3/day) 

Estimated 

Propulsion Engine 

Wet Exhaust 

Discharge Rate 

(gallons/day) 

Estimated 

Generator Engine 

Wet Exhaust 

Discharge Rate 

(m3/day) 

Estimated Generator 

Engine Wet Exhaust 

Discharge Rate 

(gallons/day) 

Barges NA NA NA NA 

Cargo/Bulk 

Carriers NA NA NA NA 

Commercial 

Fishinga 15.8 4,161 1.41 372 

Large Cruise 

Ships NA NA NA NA 

Medium Cruise 

Ships NA NA NA NA 

Large Ferries NA NA NA NA 

Oil and Gas 

Tankers NA NA NA NA 

Passenger 

Vessels (e.g., 

water taxis, tour 

boats)b

41 10,832 6.45 1,704 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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Table 3-7. Estimated Propulsion and Generator Engine Wet Exhaust Discharge Rates 

for Vessels Selected for Detailed Analysis 

Vessel Type 

Estimated 

Propulsion Engine 

Wet Exhaust 

Discharge Rate 

(m3/day) 

Estimated 

Propulsion Engine 

Wet Exhaust 

Discharge Rate 

(gallons/day) 

Estimated 

Generator Engine 

Wet Exhaust 

Discharge Rate 

(m3/day) 

Estimated Generator 

Engine Wet Exhaust 

Discharge Rate 

(gallons/day) 

Utility Boats 

(fire boat, tugs)c 36.3 9,590 1.80 475 

Source: USEPA, 2010. 

NA: Vessel does not have an engine or is expected to have dry engine exhaust. 

a) Average propulsion and generator engine wet exhaust discharge rate for a gillnetter and purse seiner (USEPA, 

2010). 

b) Average propulsion and generator engine wet exhaust discharge rate for a tour boat and water taxi (USEPA, 

2010). 

c) Propulsion and generator engine wet exhaust discharge rate for a fire boat (USEPA, 2010). 

3.2.2.5 Exhaust Gas Scrubber Washwater 

Exhaust gas scrubbers would be used on large vessels such as oil and gas tankers, 

cargo/bulk carriers, large ferries and medium and large cruise ships burning high-sulfur bunker 

oil (USEPA, 2011c). The exhaust gas scrubbers remove sulfur dioxide generated by the vessel 

engines during combustion of the bunker oil. Exhaust gas scrubber systems using seawater 

typically generate 45 m3

 (11,900 gallons) of washwater per megawatt-hour (MWh) for scrubbing 

(MEPC, 2008). Closed freshwater exhaust gas scrubber systems have much smaller discharge 

rates than seawater scrubbers. Freshwater closed loop scrubbers generate 0.1 to 0.3 m3/MWh (26 

to 79 gallons/MWh) of scrubber washwater (MEPC, 2008). 

To estimate exhaust gas scrubber washwater flows for vessels like tankers, cargo/bulk 

carriers, ferries and cruise ships, EPA used information on the engine sizes for each type of 

vessel. Table 3-8 shows the range of engine sizes by vessel type and the estimated seawater and 

freshwater exhaust gas scrubber washwater flow rates based on engine size. The size of the 

propulsion engines for large cruise ships and large ferries was obtained from EPA’s Technical 

Development Document for Exhaust Gas Scrubber Washwater Effluent (USEPA, 2011c). EPA 

assumed that the power requirements for propulsion engines on large ferries are similar to those 

for medium cruise ships. For oil and gas tankers and cargo/bulk carriers, EPA used information 

for the 80 MW (109,000 HP) engine onboard the Emma Maersk large container ship (Ship 

Technology, 2011). EPA assumed that for smaller vessels such as tour boats, water taxis, fishing 

boats and tug boats using low sulfur fuels will be a less expensive compliance alternative than 

installing and operating exhaust gas scrubbers; therefore, exhaust gas scrubber washwater flows 

for these vessel types were not estimated. 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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Table 3-8. Estimated Exhaust Gas Scrubber Washwater Discharge Rates 

for the Vessels Selected for Detailed Analysis 

Vessel Type 

Average 

Propulsion 

Power 

(MW) 

Estimated 

Saltwater 

Exhaust Gas 

Scrubber 

Washwater 

Discharge 

Rate(m3/hr) 

Estimated 

Saltwater 

Exhaust Gas 

Scrubber 

Washwater 

Discharge Rate 

(gallons/hr) 

Estimated 

Freshwater 

Exhaust Gas 

Scrubber 

Washwater 

Discharge Rate 

(m3/hr) 

Estimated 

Freshwater 

Exhaust Gas 

Scrubber 

Washwater 

Discharge Rate 

(gallons/hr) 

Barges NA NA NA NA NA 

Cargo/Bulk 

Carriersaa 80 3,600 951,000 16 4,227 

Commercial 

Fishing NA NA NA NA NA 

Large Cruise 

Shipsb 45 2,025 535,000 9 2,377 

Medium 

Cruise Shipsc 4.8 216 57,000 1 264 

Large Ferriesc 4.8 216 57,000 1 264 

Oil and Gas 

Tankersa 80 3,600 951,000 16 4,227 

Passenger 

Vessels (e.g., 

water taxis, 

tour boats) 

NA NA NA NA NA 

Utility Boats 

(fire boat, 

tugs) 

NA NA NA NA NA 

NA: Vessels do not have propulsion engines or are unlikely to install exhaust gas scrubbers. 

a) Representative propulsion engine size based on Emma Maersk large container ship (Ship Technology, 2011). 

b) Representative propulsion engine size based on the MS Zaandam, Holland America Line (USEPA, 2011c). 

c) Representative propulsion engine size based on Pride of Kent, P&O Lines (USEPA, 2011c). 

3.2.2.6 Fish Hold and Fish Hold Cleaning Effluent 

Fish hold effluent is composed of seawater, ice-melt, or ice slurry collected inside fish 

hold tanks. The volume of fish hold effluent generated by commercial fishing vessels varies by 

the type and size of vessel, and the methods used to preserve the catch. For example, some 

commercial fishing vessels preserve fish using chipped or slurry wet ice, while others have 

refrigerated seawater tanks. Vessels that use chipped or slurry ice generally remove the seafood 

and then discharge the spent ice overboard. Vessels with refrigerated seawater tanks typically 

extract the fish using a vacuum system that removes both the fish and refrigerated seawater 

simultaneously. Any excess refrigerated seawater that is not required to assist in fish extraction is 

typically pumped overboard. Tanks used to keep lobster and crab alive pump surrounding water 

into the tank constantly to maintain the highest water quality possible. The flow rate through 

these systems results in a nearly continuous discharge of fish hold effluent. 

Table 3-9 lists various types of commercial fishing vessels and the estimated daily 

volume of fish hold effluent discharge (USEPA, 2010). As indicated in Table 3-9, fish hold 

effluent discharge rates can range from as low as 211 gal/day for a gillnetter to as high as 

5,090 gallons per day for a tender vessel. 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

3-30 

Table 3-9. Estimated Fish Hold Effluent Discharge Rates by Type of Fishing Vessel 

Commercial Fishing 

Vessel Type 

Estimated Fish Hold Effluent 

Discharge Rate (m3/day) 

Estimated Fish Hold Effluent 

Discharge Rate (gal/day) 

Gillnetter 0.80 211 

Lobster Boat 2.83 748 

Longliner 2.83 748 

Purse Seiner 16.3 4,306 

Shrimper 1.25 330 

Tender 19.3 5,099 

Trawler 1.25 330 

Troller 3.04 803 

Source: USEPA, 2010. 

Fish holds are also often cleaned or disinfected by vessel crews between catches. To rinse 

the tank, vessel crews use either municipal water from the pier or dock, or they pump 

surrounding ambient water. Cleaning may involve simply rinsing the tanks with this water or a 

thorough scrub down with the addition of detergents or disinfectants to maximize the removal of 

organic material. As a result, the effluent from fish hold cleaning contains a combination of 

residual fish hold water and ambient or municipal water and often contains soaps or detergents. 

Table 3-10 shows the volume of water discharged from various commercial fishing vessels 

during fish holding tank cleaning. Cleaning volumes range from 283 gal/day for purse seiners to 

58 gallons per day for trawlers. 

Table 3-10. Estimated Fish Hold Cleaning Effluent Discharge Rates by Type of 

Fishing Vessel

Commercial Fishing 

Vessel Type 

Estimated Fish Hold Cleaning Effluent 

Discharge Rate (m3/day) 

Estimated Fish Hold Cleaning Effluent 

Discharge Rate (gal/day) 

Purse Seiner 1.07 283 

Tender 0.66 174 

Trawler 0.22 58 

Troller 0.66 174 

Source: USEPA, 2010.

3.2.2.7 Graywater 

Graywater means galley, bath, and shower water, as well as wastewater from lavatory 

sinks, laundry, and water fountains generated on board vessels (USEPA, 2011d). The volume of 

graywater generated depends primarily on the type of vessel and the number of passengers and 

crew onboard. For example, cruise ships generate more graywater than cargo ships since they 

have many more passengers and crew. Further, cruise ships also generate higher graywater 

volumes per capita than cargo ships because passengers and crew on these vessels use galleys 

and accommodations (sinks and showers) to a greater extent than crew on cargo ships. Estimated 

graywater generation rates reported in response to EPA’s 2004 cruise ship survey ranged from 36 

to 119 gallons/day/person, with an average of 67 gallons/day/person (USEPA, 2008) for large 

cruise ships. Finland’s Ministry of the Environment estimated cruise ship grey water generation 

at 120 liters per day (32 gallons/day/person) (BMEPC, 2007). During EPA’s 2004 Alaskan 

cruise ship sampling program, graywater generation on one ship was 45 gallons/day/person 

(USEPA, 2006).
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

3-31 

Table 3-11 shows the estimated daily volume of graywater generated by each of the 

vessel types selected for detailed analysis for this BE. To calculate daily graywater generation, 

EPA multiplied the number of passengers and crew on the vessel by the 45 gallons/day/person 

graywater generation rate from a cruise ship. Because the graywater generation rate for cruise 

ships may be larger than the actual graywater generation rates for vessels such as cargo/bulk 

carriers, tankers and utility vessels, the estimated rate may be biased high. 

Table 3-11. Estimated Graywater Discharge Rates for Vessels Selected for Detailed 

Analysis 

Vessel Type 

Number of 

Passengers and 

Crewa

Estimated Graywater 

Generation Rate 

(gal/day/person)d

Estimated 

Graywater 

Discharge Rate 

(m3/day) 

Estimated 

Graywater 

Discharge Rate 

(gal/day) 

Barges 4 45 0.23 61e

Cargo/Bulk 

Carriers 25 45 4.2 1,125 

Commercial 

Fishing Vessels 29 45 4.9 1,305 

Large Cruise Ships 3,455 45 588 155,475 

Medium Cruise 

Ships 315 45 53.6 14,175 

Large Ferries 559 45 95.2 25,155 

Oil and Gas 

Tankers 22 45 3.7 990 

Passenger Vessels 

(tour boats, water 

taxis, etc.) 

282b

45 48 12,690 

Utility Vessels (tug 

boats, off-shore 

vessels, etc.) 

6c

 45 1 270 

a) Number of crew and passengers from EPA’s NOI Report (USEPA, 2011e) unless otherwise specified. 

b) Average number of passengers and crew calculated based on information gathered from both personnel communication with 

operators and web site marketing data for tour boats, dinner cruise vessels, wedding party boats, whale watching tours, and 

shuttle service vessels. Vessels do not provide overnight accommodations. 

c) Based on personal contact with AEP River Operations. 

d) Generation rate based on USEPA, Sampling Episode Report for Holland America Veendam (Sampling Episode 6503). 

Washington, DC (USEPA. 2006). 

e) Average flow adjusted based on an estimated 33.8% of barges are manned and would therefore generate graywater (USEPA, 

2011e, Section 2.2.1.5 and Figure 2.1-1). 

3.2.2.8 Stern Tube Packing Gland Effluent and Discharges from Other Oil/Water 

Interfaces 

The packing gland or stuffing box surrounds the propeller shaft at the point it exits a 

boat’s hull underwater. The packing gland allows the propeller shaft to turn while preventing 

water from entering the hull. A stuffing box packed with greased flax rings is designed to leak a 

few drops per minute of ambient water to cool the gland when a vessel is underway. Stuffing 

boxes are also used to seal rudder stocks that penetrate the hull below the waterline. The packing 

gland effluent water is often collected in a segregated section of the bilge that contains an 

automatic bilge pump. 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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EPA has estimated the stern tube effluent generation rate is between 4 and 8 gallons per 

day for a tugboat having two propeller shafts (USEPA, 2010). To estimate stern tube effluent 

discharge rates for the other vessel types requiring detailed analysis for this BE, EPA used the 

size of a utility vessel (measured as gross tons), compared this vessel size to the other vessel 

types, and applied an average stern tube packing gland discharge rate of 6 gallons per day as 

shown in the example calculation below. 

Example: 25 gross tons (fishing vessel)/80 gross tons (utility vessel) x 6 gal/day = 2 

gal/day 

Table 3-12 shows the vessel sizes and the estimated stern tube packing gland discharge 

rates for the vessel types requiring detailed analysis. Flows range from as little as 2 gal/day for 

commercial fishing vessels to as great as 4,000 gal/day for large cruise ships. 

Table 3-12. Estimated Volume of Stern Tube Packing Gland Effluent Discharge Rates 

for Vessels Selected for Detailed Analysis 

Vessel Type 

Vessel Size 

(gross tons)a

Estimate Stern Tube Packing 

Gland Effluent Discharge 

Rate (m3/day) 

Estimated Stern Tube 

Packing Gland Effluent 

Discharge Rate 

(gallons/day) 

Barges 705 0e 0e

Cargo/Bulk Carriers 15,939 4.5 1,195 

Commercial Fishing 25b 0.008 2 

Large Cruise Ships 53,526 15.1 4,014 

Medium Cruise Ships 4,584 1.3 343 

Large Ferries 1,451 0.4 108 

Oil and Gas Tankers 24,908 7.1 1,868 

Passenger Vessels 

(e.g., water taxis, tour boats) 35c

 0.01 2.6 

Utility Boats (tugs and tow 

boats) 80d

 0.02 6 

a) Vessel size from EPA’s NOI Report (USEPA, 2011e) unless otherwise specified. 

b) Vessel gross tons estimated assuming 50% of commercial fishing vessels are 40 feet long (USEPA, 2010). 

c) Vessel gross tons estimated assuming 50% of passenger vessels are 45 feet long (USEPA, 2010). 

d) Vessel gross tons estimated assuming 50% of utility vessels are 65 feet long (USEPA, 2010). 

e) Barges do not have propeller shafts and associated stern tube packing glands. 

To limit the environmental impacts caused by the passive release of oil and grease from 

oil/water interfaces like those associated with rudder bearings, the 2013 VGP mandates the use 

of environmentally-acceptable lubricants (EALs) for existing vessels (subject to technical 

feasibility) and for all new build vessels. EALs such as those derived from vegetable oils and 

synthetic esters are biodegradable and generally have a lower toxicity to marine organisms than 

traditional mineral oil based lubricants. 

The rates that either mineral or oil based lubricants or EALs are passively released into 

the surrounding ambient water from vessels is not easily quantifiable. The Navy has estimated 

that approximately 5 percent of the grease associated with rudder bearings “washes out” between 

each 2-week lubrication cycle (USEPA, 1999). A loss of 5 percent equates to approximately 

0.05 lbs of grease per week from rudder bearings. Oil losses from other submerged equipment 

has been estimated at 1.5 liters/day for utility vessels, 2 liters/day for commercial fishing vessels 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

3-33 

and passenger vessels, 5 liters/day for tank ships, and 7 liters/day for cargo/bulk carriers (Edkin, 

2010). EPA will use these oil and grease loss rates to estimate the amounts discharged to ambient 

waters from submerged equipment on the vessels of concern. 

3.2.3 Pollutants Requiring Detailed Analysis in Selected Vessel Discharges 

Table 3-13 lists the categories of pollutants associated with each of the nine discharges 

selected for detailed evaluation. Pollutant categories include ANS, conventional pollutants, 

metals, nutrients, oil and grease, pathogens, and toxics and non-conventional pollutants with 

toxic effects. 

Table 3-13. Pollutant Categories Associated with Vessel Discharges Selected for Detailed 

Analysis 

Vessel Discharge Pollutant Categories 

Anti-fouling Leachate from Anti-fouling Hull Coatings Metals (copper) 

Ballast Water ANS, metals, TSS 

Bilgewater Metals, oil and grease, VOCs/SVOCs, nutrients 

Chain Locker Effluent ANS 

Deck Washdown Oil and grease, metals, soaps and detergents 

Engine Wet Exhaust Effluent Oil and grease, metals, VOCs/SVOCs 

Exhaust Gas Scrubber Washwater 

Low pH, oil and grease, polycyclic aromatic 

hydrocarbons (PAHs), metals, nutrients 

Fish hold and fish hold cleaning effluent 

Pathogens, metals, nutrients, soaps and detergents, 

classical pollutants such as BOD5, TDS, TSS, sulfide 

Graywater Pathogens, oil and grease, nutrients, metals 

Stern Tube Packing Gland Effluent Oil and grease, metals, TSS, VOCs/SVOCs 

Underwater Ship Husbandry Discharges ANS 

The individual pollutants analyzed in detail, and their concentrations in the vessel 

discharges, are discussed in the subsections below. In general, EPA examined pollutant 

concentration data from specific vessel discharges and considered for detailed evaluation only 

those pollutants having levels that exceeded the screening level benchmarks in EPA’s Report to 

Congress (USEPA 2010) or in other published literature such as EPA’s Cruise Ship Discharge 

Assessment Report (USEPA, 2008) and EPA’s Uniform National Discharge Standards (UNDS) 

for Vessels of the Armed Forces (USEPA, 1999). The screening level benchmarks, provided in 

Appendix D of this BE, are preliminary measures used to determine if the pollutant 

concentrations in a discharge have the potential to cause or contribute to the nonattainment of a 

water quality standard in a receiving water body and, therefore, is generally protective of aquatic 

life. For those discharges that EPA did not monitor for the Report to Congress (i.e., anti-fouling 

hull coatings and scrubber wash water), EPA used published information to select pollutants for 

detailed evaluation. 

3.2.3.1 Aquatic Nuisance Species 

Aquatic Nuisance Species (ANS), also known as invasive species, are a persistent 

problem in U.S. coastal and inland waters. ANS may be introduced through a variety of vectors, 

including ballast water and sediment from ballast tanks as well as fouled vessel hulls. ANS pose 

several dangers to aquatic ecosystems, including outcompeting native species, damaging habitat, 

changing food webs, and altering the chemical and physical aquatic environment. Furthermore, 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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ANS have been documented to damage recreational and commercial fisheries, infrastructure, and 

water based recreation and tourism. 

Ballast water discharges have been cited as one of the primary sources or vectors for the 

spread of ANS (Carlton, 1995). Depending on where ships take on ballast water, virtually all 

organisms in the water column, either swimming or stirred up from bottom sediments, can be 

taken into ships’ ballast tanks. These organisms include holoplakton (free-floating), meroplakton 

(larval stages of bottom dwelling organisms), upper water column nekton (active swimming), 

and demersal (near bottom dwelling nekton) organisms (California EPA, 2002). Because of the 

global shipping network, it is possible that new ANS could arrive in areas such as the Great 

Lakes from virtually any freshwater port world-wide (Keller, 2011). 

On any given day, approximately 7,000 individual species may be “in motion” in ballast 

tanks (Carlton, 2001), and there is no evidence that ships age, seasonal timing, or age of ballast 

water affects the abundance of individuals or species in the ballast tanks (Drake, 2007). When 

species in ballast tanks are transported between water bodies and discharged, they have the 

potential for establishing new, non-indigenous populations that can cause severe economic and 

ecological impacts. The rate that which ANS can establish viable populations ranges from one 

every 20 weeks in the Lower Columbia River Basin (Sytsma, 2004) to one every 28 weeks in the 

Great Lakes (USEPA, 2011a). Attempting to quantitatively assess the number and type of ANS 

that have the ability to establish a viable population from the 7,000 individual species currently 

being carried in ballast tanks is not possible (NAS, 2011). 

Under current US laws, regulations, and permitting requirements, existing best 

management practices are required to help reduce the potential impacts of ANS from ballast 

water discharges. These include ballast water exchange7 and saltwater flushing8 for certain 

vessels/voyages. These practices have been shown to offer some protection in mitigating the 

transfer and potential introduction of invasive species. While useful in reducing the presence of 

potentially invasive organisms in ballast water, ballast water exchange is not feasible for all 

vessels (e.g., vessels that cannot voyage offshore), can have variable effectiveness, and in some 

circumstances may not be feasible due to vessel safety concerns (Albert, 2010). 

One way to address these limitations associated with ballast water exchange is to require 

treatment of ballast water prior to discharge to meet an established standard for the concentration 

of living organisms. On March 23, 2012, the US Coast Guard published final regulations which 

phase in ballast water treatment requirements which became effective on June 21 of that year. 

 

7

 “Ballast Water Exchange” means to replace the water in a ballast tank using either “Flow through exchange” or “Empty/refill 

exchange”. “Flow through exchange” means to flush out “ballast water” by pumping in water from the “mid-ocean” or “coastal 

exchange zone” (as applicable) into the bottom of the tank and continuously overflowing the tank from the top until three full 

volumes of water has been changed to minimize the number of original organisms remaining in the tank. “Empty/refill exchange” 

means to pump out the “ballast water” taken on in ports, estuarine, or territorial waters until the tank is empty, then refilling it 

with water from the “mid-ocean” or “coastal exchange zone” (as applicable); when conducting empty/refill exchange, 

masters/operators should pump out as close to 100 percent of the “ballast water” as is safe to do so (adapted from 33 C.F.R 

151.2025(b) (definition of “exchange”)). 

8

 “Saltwater flushing” means the addition of “mid-ocean” or “coastal exchange zone” water to empty ballast water tanks; the 

mixing of the added water with residual ballast water and sediment through the motion of the vessel; and the discharge of the 

mixed water until loss of suction, such that the resulting residual water remaining in the tank has either a salinity greater than or 

equal to 30 parts per thousand (ppt) or a salinity concentration equal to the ambient salinity of the location where the uptake of 

the added water took place (adapted from 33 C.F.R. 401.30(f)(1)). 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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These regulations established a standard for the allowable concentration of living organisms 

contained in ships’ ballast water discharges. The Coast Guard’s numeric ballast water discharge 

standards for living organisms (USCG, 2012) are consistent with those proposed by EPA in 

November 2011 in the VGP. 

3.2.3.2 Nutrients 

Nutrients, particularly ammonia nitrogen and total phosphorus, are constituents 

commonly found in bilgewater, deck washdown, fish hold and fish hold cleaning effluent, and 

graywater. These nutrients are associated with eutrophication, which can lead to reduced levels 

of dissolved oxygen due to increased oxygen demand (sometimes to the extremes of hypoxia), 

reduced levels of light penetration and increased turbidity, and changes in the composition of 

aquatic flora and fauna. The process helps to fuel harmful algal blooms, which can have 

devastating impacts on both aquatic life and human health (National Science and Technology 

Council, 2000). 

Studies of pollutants in vessel discharges found that average ammonia nitrogen 

concentrations were above the screening level benchmark of 1.2 mg/L in both fish hold effluent 

and fish hold cleaning effluent (USEPA, 2010) (see Appendix D of this BE for more information 

regarding screening level benchmarks). Protein, free amino acids, and nucleotides from fish and 

fish by-products are all potential sources of nitrogen in the fish hold effluent and fish hold 

cleaning effluent. Ammonia nitrogen concentrations can also be above screening level 

benchmarks in graywater. EPA found the average ammonia nitrogen concentration from all 

graywater sources on cruise ships was 2.1 mg/L (USEPA, 2008) Average phosphorous 

concentrations were above the screening level benchmark of 0.1 mg/L in bilgewater, graywater, 

deck washdown discharges, fish hold effluent, and fish hold cleaning effluent. The likely source 

of phosphorous in bilgewater and deck washdown water is liquid detergents used on board for 

deck washing. Sources of phosphorous in graywater and fish hold effluent may reflect food or 

other wastes. Table 3-14 shows the average concentrations of ammonia nitrogen and total 

phosphorous in the various vessel discharges requiring detailed analysis. 

Table 3-14. Average Nutrient Concentrations in Vessel Discharges 

at Levels Above Screening Level Benchmarks 

Vessel Discharge Requiring Detailed 

Analysis 

Average Ammonia Nitrogen 

(mg/L) 

Average Total Phosphorous 

(mg/L) 

Bilgewater 1.7 3.0 

Deck Washdown NA 1.7 

Fish Hold Effluent 12 13 

Fish Hold Cleaning Effluent 16 8.5 

Graywater 1.3 

2.1a

1.4 

10a

Stern Tube Packing Gland Effluent NA 0.13 

Source: USEPA, 2010, unless otherwise specified. 

NA: Pollutant does not exceed the screening level benchmark for this vessel discharge (see Appendix D of this BE for more 

information regarding screening level benchmarks). 

a) Average concentration in graywater from large cruise ships (USEPA, 2008, EPA sampling data). 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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3.2.3.3 Pathogens 

Pathogens are another constituent found in vessel discharges from vessels, particularly in 

graywater, bilgewater and possibly in ballast water. EPA’s study of graywater discharges from 

cruise ships found that levels of pathogen indicator bacteria exceeded enterococci standards for 

marine water bathing and fecal coliform standards for harvesting shellfish 66 percent and over 80 

percent of the time, respectively (USEPA, 2008). EPA’s study of bilgewater discharges from 

commercial fishing vessels found that for each of the pathogen indicator parameters, the 

benchmark screening levels were exceeded in one half of the collected samples (USEPA, 2010) 

(see Appendix D of this BE for more information regarding screening level benchmarks). 

Additional pathogens have been associated with ballast water discharges, including E. coli, 

enterococci, Vibrio cholerae, Clostridium perfingens, Salmonella spp. Cryptosporidium spp., 

and Giardia spp., as well as a variety of viruses (Knight et al. 1999; Reynolds et al. 1999; Zo et 

al. 1999). Note that although these pathogens are harmful to humans, they are generally not 

harmful to aquatic or aquatic dependent organisms. 

3.2.3.4 Oil and Grease 

Oil and grease are another known component of vessel discharges that may impact 

aquatic life. Certain constituents in oil are toxic and potentially carcinogenic, and can taint 

organisms that are consumed by wildlife and humans. Vessels discharge a variety of oils 

including lubricating oils, hydraulic oils, and vegetable or organic oils in every day operations. 

Bilgewater contains drainage from interior machinery, engine rooms, and from decks, which 

may contain oils and greases. Graywater may contain vegetable or organic oils mainly from 

galley operations, while lubricating oils and hydraulic oil (primarily mineral oil) are associated 

with stern tube effluent and on-deck and underwater (submerged) machinery. Another potential 

source of oil and grease discharges is engine wet exhaust effluent. The impact of oil and grease 

discharges (not accidental spills) to the marine ecosystem could be substantial. For example, 

losses of lubricating oils to marine waters from stern tubes alone have been estimated to be as 

high as 2.6 million gallons per year world-wide (Carter, 2011). As stated by the Urban Harbors 

Institute (2000), “while overall concentrations of oil toxins from chronic sources might be lower 

compared to concentrations following a catastrophic spill in the marine environment, chronic 

pollution can be equally toxic to marine life if sustained over extended periods of time.” 

Table 3-15 shows oil and grease data9

 measured by EPA from sources such as stern tube 

packing gland effluent, bilgewater, deck washdown, engine wet exhaust effluent, fish hold 

effluent, fish hold cleaning effluent, and graywater from smaller vessels (e.g., those less than 

79 feet). Oil and grease from each of the vessel discharges shown in Table 3-15 will be 

considered in detail in this BE. 

 

9

 Oil and grease is measured as both hexane extractable material (HEM) and silica gel treated HEM (SGT-HEM). HEM measures 

the relatively non-volatile hydrocarbons, vegetable oils, animal fats, waxes, soaps, and greases. SGT-HEM measures non-polar 

oil and greases such as mineral oils. 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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Table 3-15. Oil and Grease Concentrations Measured in Vessel Discharges Requiring 

Detailed Analysis 

Vessel Discharge Requiring 

Detailed Analysis 

Average Oil and Grease 

Concentrationa

(mg/L) 

Average Oil and Grease 

Concentrationb

(mg/L) 

Bilgewater 9.3 (44) 4.4 (18) 

Deck Washdown 14 (130) 7.0 (84) 

Fish Hold Effluent 3.2 (16) 3.4 (4.4) 

Fish Hold Cleaning Effluent 5.4 (28) 4.9 (12) 

Graywater 39 (100) 

149c

8.1 (35) 

36.6 c

Stern Tube Packing Gland 14 (67) 13 (56) 

Source: USEPA 2010. 

( ) Maximum measured concentration. 

a) Oil and grease measured as hexane extractable material. 

b) Oil and grease measured as silica gel treated hexane extractable material. 

c) Average concentration in graywater from large cruise ships (USEPA, 2008, EPA sampling data). 

3.2.3.5 Metals 

Metals are a diverse group of pollutants, many of which are toxic to aquatic life and 

humans. Vessel discharges can contain a variety of metal constituents that can come from a 

variety of on-board sources. For example, EPA’s study of cruise ship graywater found a total of 

13 different metals in at least 10 percent of samples, with copper, nickel and zinc detected in 

100 percent of samples (USEPA, 2008). Bilgewater has also been shown to contain numerous 

metals, the exact constituents of which vary dependent upon onboard activities on the vessel and 

the materials used in the construction of the vessel. Certain metals, such as copper, are known to 

leach from vessel hulls containing anti-fouling coatings (California Regional Water Quality 

Control Board, 2006). 

EPA found that dissolved copper was the metal analyte detected in vessel discharges at 

concentrations that consistently posed the greatest potential risk for local impacts (USEPA, 

2010). In the study, concentrations of dissolved copper were found to exceed benchmark 

screening levels in at least some samples for every sampled discharge type, except for outboard 

engine and generator engine effluents (see Appendix D of this BE for more information 

regarding screening level benchmarks). The highest concentrations of dissolved copper were 

detected in the deck washdown, graywater, fish hold, and bilgewater discharges from most vessel 

types (in this case, small commercial vessels), but particularly utility vessels (e.g., towboats, 

supply boats). In addition to dissolved copper, total aluminum was found at concentrations 

exceeding screening level benchmarks in at least some samples for all discharge types, 

particularly from deck washdown discharges, followed by fish hold discharges, and then stern 

tube packing gland discharges. Likewise, concentrations of other metals such as dissolved 

cadmium, lead and zinc were also found to be elevated, particularly in the deck washdown 

discharges from utility vessels. 

Table 3-16 lists the concentrations of total metals selected for detailed analysis for the BE 

in the various vessel discharges requiring detailed evaluation. As indicated previously, these total 

metals were selected because their concentrations in certain vessel discharges were above EPA’s 

screening level benchmarks (USEPA, 2010). Only four total metals were measured at 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

3-38 

concentrations that were above the screening benchmark levels and were not attributed to the 

ambient water. 

Table 3-16. Average Concentrations of Total Metals in Vessel Discharges at Levels Above 

Screening Level Benchmarksa 

Vessel Discharge Requiring Detailed 

Analysis 

Aluminum 

(μg/L) 

Arsenic 

(μg/L) 

Nickel (μg/L) Selenium 

(μg/L) 

Bilgewater 370 NA NA NA 

Deck Washdown 3,400 NA NA NA 

Exhaust Gas Scrubber Washwaterb NA 81 NA 100 

Fish Hold Effluent 827 40 NA NA 

Fish Hold Cleaning Effluent 1,100 35 NA NA 

Graywater 380 2 NA NA 

Stern Tube Packing Gland Effluent NA NA 610 NA 

Source: USEPA 2010 unless otherwise specified. 

NA: Metal is not selected as a pollutant requiring detailed evaluation in this discharge (see Appendix D of this BE for more 

information regarding screening level benchmarks). 

a) Includes only those metals whose concentrations are not influenced by the surrounding ambient water. 

b) USEPA Exhaust Gas Scrubber Washwater Effluent, EPA 800-R-11-006, November 2011. Effluent concentrations for 

saltwater exhaust gas scrubber washwater discharge; effluent concentrations for freshwater exhaust gas scrubber washwater 

discharge are not available. 

Table 3-17 lists the concentrations of dissolved metals selected for detailed analysis for 

the BE in various discharges warranting detailed evaluation. These dissolved metals were 

selected because their concentrations in certain discharges were above the screening level 

benchmarks (USEPA, 2010). Dissolved copper was consistently above the screening level 

benchmark concentration of 3.1 μg/L for all vessel discharges selected for detailed evaluation. 

Another source of copper is from anti-fouling coatings applied to the vessel hull to 

prevent biofouling. Copper can leach from anti-fouling coatings at rates ranging from 4 to 17 

μg/cm2/day (USEPA, 2011f). To estimate the amount of copper leached from anti-fouling 

coatings on the various types of VGP vessels the average vessel length and draft (i.e., depth 

below the water line) was estimated and an average copper leaching rate applied. Table 3-18 

shows the estimated daily amount of copper leached from VGP vessel types. Copper leaching 

rates range from 0.075 lbs/day for barges up to 2.6 lbs/day for large oil and gas tankers. 
2013 VGP and sVGP BE Section 3– Biological 

3-39 

Table 3-17. Average Concentrations of Dissolved Metals in Vessel Discharges at Levels Above Screening 

Benchmarksa 

Vessel Discharge Requiring 

Detailed Analysis 

Arsenic 

(μg/L) 

Cadmium 

(μg/L) 

Chromium 

(μg/L) 

Copper 

(μg/L) 

Lead 

(μg/L) 

Nickel 

(μg/L) 

Se

(

Bilgewater NA 1.9 12 100 NA 9.2 Deck Washdown NA 1.3 NA 42 6 NA Engine Wet Exhaust Effluentb NA NA NA 16 NA NA Exhaust Gas Scrubber Washwaterc 81 NA NA 15 NA 12 Fish Hold Effluent 31 0.77 NA 96 NA NA Fish Hold Cleaning Effluent 22 NA NA 34 2.7 NA Graywater NA NA NA 55 2.5 NA Stern Tube Packing Gland Effluent NA NA 19 22 NA 210 

Source: USEPA 2010 unless otherwise specified. NA: Metal not selected as a pollutant requiring detailed evaluation in this discharge (see Appendix D of this BE for more information regarding screena) Includes only those metals whose concentrations are not influenced by the surrounding ambient water. b) Includes only inboard diesel engines used for propulsion having wet exhaust. 

c) USEPA Exhaust Gas Scrubber Washwater Effluent, Table 2, EPA 800-R-11-006, November 2011. Effluent concentrations for saltwater exhaust 

discharge; effluent concentrations for freshwater exhaust gas scrubber washwater discharge are not available. 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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Table 3-18. Estimated Amount of Copper Leached from Anti-fouling Coatings Applied 

to Various Vessel Types 

Vessel Type 

Average 

Vessel 

Length (ft) 

Estimated 

Vessel Draft 

(ft) 

Wetted 

Hull Area 

(ft2) 

Average Copper 

Leaching Rate 

(ug/cm2/day) j

Estimated Copper 

Leaching Rate 

(lbs/day/vessel) 

Barges 175a 10d 3,500 10.5 0.075 

Oil and Gas 

Tankers 797b

 75e 120,257 10.5 2.6 

Large 

Commercial 

Fishing 

250a

 17f 8,500 10.5 0.18 

Large Cruise 

Ships 995c

 28g 55,706 10.5 1.2 

Large Ferries 200a 15.5h 6,200 10.5 0.13 

Medium Cruise 

Ships 325a

 15.5h 10,075 10.5 0.22 

Bulk Cargo and 

Other Carriers 663b

 38i 50,355 10.5 1.1 

a) Average length estimated from Figure 1.3 of USEPA’s Report to Congress (USEPA, 2010). 

b) Average length for oil tankers and bulk cargo carriers from Chamber of Shipping of America, MSD Survey, 2010. 

c) Average cruise ship length calculated from the following cruise ships: Carnival Freedom, Disney Magic, Golden Princess 

and Freedom of the Sea. 

d) Estimated draft for barges based on Barge Number 4727, Ingram, Nashville, TN. 

e) Estimated draft for oil and gas tankers based on a Suezmax tanker, 

http://people.hofstra.edu/geotrans/eng/ch5en/appl5en/tankers.html

f) Estimated draft for large commercial fishing boats based on trawlers, http://maritimesales.com/fishing%20vessels.htm

g) Estimated draft for large cruise ships based on Royal Caribbean Freedom of the Seas. 

h) Estimated draft for large ferries and medium cruise ships based on Washington State Department of Transportation’s M/V 

Sealth, passenger/auto ferry. 

i) Estimated draft for bulk cargo vessels based on Golden Pegasus Navigation S.A High Glow vessel.

j) Average copper leaching rate from USEPA Underwater Ship Husbandry Discharges, (USEPA, 2011f).

3.2.3.6 Toxic and Non-Conventional Pollutants with Toxic Effects 

The term “toxic and non-conventional pollutants with toxic effects,” as it applies to 

constituents of vessel discharges, encompasses a variety of chemical compounds known to have 

a broad array of adverse impacts on aquatic species. These pollutants include chlorine, volatile 

organic compounds (VOCs) and semi-volatile organic compounds (SVOCs), and polyaromatic 

hydrocarbons (PAHs). For example, EPA’s study of cruise ship graywater found a total of 

17 different volatile and semi-volatile organic compounds in at least 10 percent of samples, for 

which the most significant rates and levels of detection were phthalates, phenol, and 

tetrachloroethylene. EPA also found elevated pththalates (bis(2-ethylhexyl)phthalate) in a few 

bilgewater and stern tube packing gland effluent samples, as well as benzene in bilgewater 

(USEPA, 2010). Other notable toxics detected in incidental discharges from vessels include free 

residual chlorine in bilgewater, deck washdown, and graywater (USEPA, 2008 and USEPA, 

2010). 

These compounds can cause a variety of adverse impacts on ecosystems and living 

marine resources, including fisheries. Phthalates are known to interfere with reproductive health, 

liver and kidney function in both animals and humans (Sekizawa et al. 2003, DiGangi et al. 

2002). Chlorine, though toxic to humans at high concentrations, is of greater concern to aquatic 

species, which can experience respiratory problems, hemorrhaging, and acute mortality even at 

relatively low concentrations (USEPA, 2008). 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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Table 3-19 shows the average concentrations of VOCs and total residual chlorine 

measured in vessel discharges at levels above the screening level benchmarks (see Appendix D 

of this BE for more information regarding screening level benchmarks). For nearly all vessel 

discharges selected for detailed evaluation, total residual chlorine was measured at levels above 

the 0.0075 mg/L screening level. Average concentrations of various VOCs were measured in a 

variety of discharges, with bilgewater containing the largest number of VOCs at levels above 

their screening level benchmarks. 

Table 3-20 shows the average concentrations of sVOCs, including PAHs, measured in 

vessel discharges at levels above the screening level benchmarks (for those discharges for which 

data were available). As expected, sVOCs and PAHs at elevated levels are associated with fuel 

and fuel combustion. One sVOC, bis(2-ethylhexyl)phthalate, was measured in four out of five 

discharges associated with fuels and fuel combustion. Engine wet exhaust effluent from inboard 

diesel engines contained the broadest range of sVOCs and PAHs as compared to the other vessel 

discharges. 

Table 3-19. Average Concentrations of VOCs and Total Residual Chlorine in Vessel 

Discharges at Levels Above Screening Level Benchmarksa 

Vessel Discharge Requiring Detailed Analysis 

Benzene (μg/L) Bromodichloro-methane (μg/L) Total Residual Chlorine (μg/L) Dibromochloro-methane(μg/L) Tetrachloroethene (μg/L) Trichloroethene (μg/L) 

Bilgewater 61 NA 0.077 NA NA 2.6 

Deck Washdown 13 13 0.12 13 NA NA 

Engine Wet Exhaust Effluentb 12 NA NA NA NA NA 

Fish Hold Effluent NA NA 0.096 NA NA NA 

Fish Hold Cleaning Effluent NA NA 0.29 NA NA NA 

Graywater NA NA 0.12 NA NA NA 

Stern Tube Packing Gland Effluent NA NA NA NA 1.4 NA 

Source: USEPA, 2010 unless otherwise specified. 

NA: Not a pollutant selected for detailed evaluation in this discharge (see Appendix D of this BE for more information regarding 

screening level benchmarks). 

a) Includes only those VOCs whose concentrations are not influenced by the surrounding ambient water. 

b) Includes only inboard diesel engines used for propulsion having wet exhaust. 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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Table 3-20. Average Concentration of sVOCs and PAHs in Vessel Discharges at Levels 

Above Screening Level Benchmarksa 

Vessel Discharge Requiring Detailed 

Analysis 

Benzo(a)-anthracene (μg/L) Benzo(a)-pyrene (μg/L) Benzo(b)-fluoranthene (μg/L) Benzo(k)-fluoranthene (μg/L) Bis(2-ethylhexyl)-phthalate (μg/L) Chrysene (μg/L) Indeno(1,2,3-cd) pyrene (μg/L) 2,4,6-Trichlorophenol (μg/L) 

Bilgewater NA NA NA NA 15 NA NA 7.0 

Deck Washdown NA NA NA NA 4.7 NA NA NA 

Engine Wet Exhaust Effluentb 3.3 3.2 2.8 3.1 1.7 3.3 2.5 NA 

Exhaust Gas Scrubber Washwaterc 0.262 0.136 NA NA NA 0.373 NA NA 

Stern Tube Packing Gland Effluent NA NA NA NA 4.7 NA NA NA 

Source: USEPA, 2010 unless otherwise specified. 

NA: Not a pollutant selected for detailed evaluation in this discharge (see Appendix D of this BE for more information regarding 

screening level benchmarks). 

a) Includes only those sVOCs/PAHs whose concentrations are not influenced by the surrounding ambient water 

b) Includes only inboard diesel engines used for propulsion having wet exhaust. 

c) USEPA Exhaust Gas Scrubber Washwater Effluent, Table 3, EPA 800-R-11-006, November 2011. Effluent concentrations 

for saltwater exhaust gas scrubber washwater discharge; effluent concentrations for freshwater exhaust gas scrubber 

washwater discharge are not available. 

3.2.3.7 Conventional and Non-Conventional Pollutants. 

Conventional pollutants discharged from vessels include BOD5, TSS, oil and grease, and 

fecal coliform bacteria. Oil and grease and fecal coliform (a pathogen) are discussed in previous 

subsections. Other non-conventional pollutants affect pH, add heat, and/or increase turbidity or 

suspended sediment. 

Elevated concentrations of conventional pollutants like BOD5 and TSS are expected in 

bilgewater, deck washdown effluent and graywater. Other discharges such as ballast water can 

contain sediments and have elevated turbidity levels and TSS. Excessive levels of both BOD5

and TSS in receiving waters can lead to reduced dissolved oxygen levels, impacting both aquatic 

and aquatic-dependent organisms. Table 3-21 shows the average concentrations of BOD5 and 

TSS in vessel discharges selected for detailed evaluation that exceed the screening level 

benchmark of 30 mg/L (see Appendix D of this BE for more information regarding screening 

level benchmarks). Both BOD5 and TSS were selected for detailed evaluation in the BE with 

regard to depressed dissolved oxygen levels in receiving waters. Engine wet exhaust effluent and 

 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

3-43 

exhaust gas scrubber washwater vessel discharges are not included in Table 3-21 because they 

are not expected to contain appreciable levels of BOD5 and TSS.10

Table 3-21. Average BOD and TSS Concentrations in Vessel Discharges at Levels Above 

the Screening Level Benchmarks 

Vessel Discharge Requiring Detailed Analysis BOD5 (mg/L) TSS (mg/L) 

Bilgewater 190 39 

Deck Washdown 110 170 

Fish Hold Effluent 840 210 

Fish Hold Cleaning Effluent 470 190 

Graywater 430 52 

Stern Tube Packing Gland Effluent NA 59 

Source: USEPA, 2010. 

NA: Pollutant not selected for detailed evaluation in this vessel discharge (see Appendix D of this BE for more information 

regarding screening level benchmarks). 

Some vessel discharges are more acidic or basic than the receiving waters, which can 

have a localized effect on pH (ADEC, 2007b). For nearly all fish populations, pH more acidic 

than 5 or more basic than 10 will cause rapid mortality. In addition, many individual species are 

sensitive to more moderate changes in pH (Wurts and Durborrow 1992). For the vessel 

discharges requiring detailed analysis, exhaust gas scrubber washwater has the greatest potential 

to depress pH values in receiving waters because the discharge can have pH values as low as 3 

(USEPA, 2011c). 

Some vessel discharges may also affect temperature locally (Battelle, 2007). Thermal 

impacts of vessel discharges are generally much smaller than those from better known sources 

such as dams, power plant cooling water, and runoff; however, even small temperature changes 

can impact some sensitive organisms’ growth, reproduction, and even survival, which implies 

that some vessel discharges may have localized adverse impacts on aquatic organisms 

(Abbaspour et al. 2005, Govorushko 2007). Vessel discharges requiring detailed analysis with 

the potential to cause localized temperature changes in receiving waters include engine wet 

exhaust effluent and exhaust gas scrubber washwater. Engine wet exhaust discharges are 

generally at temperatures that are less than 5o

C above surrounding ambient water; however, 

engines operating at full power can discharge at temperatures as much as 27o

C above the 

surrounding ambient water (USEPA, 2010). Temperature increases in ambient water used as 

source water for exhaust gas scrubbers range from 11.9 to 16.9o

C (USEPA, 2011c). 

3.2.4 Summary of Vessel Types, Discharges, and Corresponding Pollutants/Constituents 

Selected for Detailed Evaluation in this BE

Considering the key attributes noted above, six categories of VGP vessels were selected 

for detailed evaluation in this BE: 

 

10 Both engine wet exhaust effluent and exhaust gas scrubber washwater discharges are generated by combustion processes. In 

combustion processes, fuel is oxidized generating carbon dioxide, water and other common oxides; none of these combustion 

products are expected to exert an additional oxygen demand (i.e., BOD5). TSS in these discharges result primarily from TSS 

concentrations in background ambient water and small quantities of particulate matter emissions at close to background 

concentrations (USEPA, 2010). Furthermore, in the case of exhaust gas scrubber washwater, TSS is removed by the exhaust gas 

scrubber washwater treatment system prior to discharge.
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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 Barges 

 Oil and Gas Tankers 

 Large Commercial Fishing Vessels 

 Large Cruise Ships 

 Medium Cruise Ships and Large Ferries 

 Bulk Cargo and Other Carriers 

In addition, the following three categories of sVGP vessels were selected for detailed 

evaluation in this BE due to high number of these types of vessels: 

 Commercial fishing vessels (seiners, trawlers, trollers) 

 Passenger vessels (excursion/tour boats, water taxis) 

 Utility (tow/salvage boats, tugboats) 

After analyzing all the possible discharges incidental to normal vessel operations, EPA 

selected the discharges listed below to analyze in detail in this BE. As discussed in Section 3.2.1, 

these discharges were selected based on the number of vessels having the discharge, the volume 

of the discharge and the amount of pollutants expected in the discharge. 

 Anti-Fouling Leachate from Anti-Fouling Hull Coatings 

 Ballast water 

 Bilgewater 

 Chain locker effluent 

 Deck washdown 

 Engine wet exhaust effluent 

 Exhaust gas scrubber washwater 

 Fish hold and fish hold cleaning effluent 

 Graywater 

 Stern tube packing gland effluent and discharge from other oil/water interfaces 

 Underwater ship husbandry discharges 

Specific pollutants associated with each discharge and the discharge volume are used to 

estimate the amount of pollutants being discharged to hypothetical water bodies (see 

Section 5.2.1). The information used to estimate analyte loading rates expected before and 

anticipated after implementation of the permit conditions for the specific pollutants, discharges, 

and vessel types stem from the same reference materials cited in the preceding sections (e.g., 

EPA’s Cruise Ship Discharge Assessment Report, Vessel Report to Congress, Phase I UNDS, 

vessel discharge technical support documents, and the vessel general permits and fact sheets). 

These data represent the best scientific and commercial data available for characterizing the 

covered vessels and permitted discharges. Additional details regarding pollutant loading 

estimation and water quality modeling, and how these estimates are used to support the effects 

analysis, are the primary subject of Section 5.0 (Effects Analysis) in this BE document. 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

3-45 

3.3 SELECTION OF REFERENCE ACTION AREAS (RAAS) 

EPA selected multiple RAAs to evaluate the potential effects of the permit actions on 

listed aquatic and aquatic-dependent species, as well as their designated critical habitats. EPA 

used the following selection criteria to identify the RAAs evaluated in the BE: 

 High density of vessels covered under the VGP and sVGP to capture a reasonable 

“worst case” scenario; 

 Varying percentages of vessel types present to capture the variability in pollutant 

loading rates; 

 Selection of RAAs that provide broad coverage of diverse ecosystem types and broad 

geographical representation; and 

 Selection of “special interest” locations with known or expected sensitivities for 

specific taxa and their critical habitats (i.e., Pacific coast salmonid populations, sea 

turtles in Gulf of Mexico, etc.) and/or specific vulnerabilities (e.g., historic 

introduction and spread of ANS in the Great Lakes). 

Using information primarily from EPA’s NOI Summary Report (Section 2.2.1.4, 

Home/Most Frequented Port and Geographical Area of Operation) and EPA’s Report to 

Congress on Vessel Discharges (Section 4.3.3, Number of Vessels Present in the Harbor), EPA 

identified the top Home/Hailing Ports for each vessel type identified for detailed evaluation in 

the BE (see Section 3.2.4). For both groups of covered vessels (large and small), New York, NY; 

Houston, TX, and Seattle, WA were consistently among the top 10 port cities, as well as other 

ports such New Orleans, LA; Miami, FL; Los Angeles, CA; Norfolk, VA; Pittsburgh, PA; and 

St. Louis, MO (to name a few). Among these port cities, nearly all are representative of 

marine/estuarine ecosystems, except for inland port cities such as Jeffersonville (Indiana), 

Pittsburgh, St. Louis and Cincinnati (top port cities for barges on large inland rivers). Port cities 

on a large freshwater lake (Great Lakes) system do not appear to be among the most heavily 

trafficked. 

From this initial list of port cities, EPA selected seven RAAs for detailed evaluation in 

the BE that were both ecologically and geographically diverse and captured several special 

interest locations identified during preliminary informal consultation meetings with the Services. 

Table 3-22 presents the seven RAAs and provides a brief explanation justifying the selection of 

each area. 

Table 3-22. RAAs Selected to Support the BE Analysis and Water bodies and Ecosystems 

Represented 

Reference 

Port/Harbor 

Waterbody 

Represented 

Ecosystem 

Represented Justification 

Duluth, MN Lake Superior 

Harbor 

Freshwater [Great] 

Lake 

Major port in sensitive “cold-water” Great Lakes 

area with known ANS issues. 

Houston, TX Galveston Bay Estuarine/Marine 

RAA with large population of oil and gas tankers, 

barges, and cargo carriers. Area also encompasses 

nesting ground of listed sea turtles. 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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Table 3-22. RAAs Selected to Support the BE Analysis and Water bodies and Ecosystems 

Represented 

Reference 

Port/Harbor 

Waterbody 

Represented 

Ecosystem 

Represented Justification 

Miami, FL Biscayne Bay Estuarine/Marine 

RAA with significant populations of cargo/bulk 

carriers and large population of cruise ships. Area 

encompasses extensive listed Johnson’s seagrass 

beds and represents a portion of Florida’s coral 

reef tract. In addition, Miami was requested to be 

an additional RAA during informal consultation 

with Services, in light of the presence of 

endangered species and their critical habitats with 

unique characteristics not found in other RAAs 

New York, NY 

Upper and 

Lower New 

York Bay 

Estuarine/Marine 

RAA with significant presence of all major vessel 

types, and in proximity to listed short nose 

sturgeon population along the Hudson River. RAA 

includes multiple critical habitat areas. 

San Francisco, 

CA 

San Francisco 

Bay Estuary Estuarine/Marine 

RAA with significant populations of cargo bulk 

carriers, utility boats, and commercial fishing 

vessels. Estuary is emblematic of one subjected to 

heavy ANS invasion. In addition, San Francisco 

was requested to be an additional RAA during 

informal consultation with Services due to the 

presence of a significant number of endangered 

and threatened species from a broad range of taxa 

and critical habitat areas. 

St. Louis, MO 

Upper 

Mississippi 

River 

Large Freshwater 

River 

RAA with large barge and supporting utility vessel 

presence. The upper Mississippi River near St. 

Louis also represents a large freshwater river 

ecosystem home to a sensitive listed freshwater 

unionid mussel species. 

Seattle, WA Puget Sound Marine/Estuarine 

RAA with significant large and small commercial 

fishing vessel presence. Puget Sound near Seattle 

is home to several Pacific Northwest salmonid 

populations. RAA includes multiple critical habitat 

areas. 

3.4 LISTED SPECIES AND THEIR CRITICAL HABITATS WITHIN RAAS

The purpose of this section is to identify the listed aquatic and aquatic-dependent species 

and their critical habitats that may be affected by the permits, and to identify the subset of listed 

species from the RAAs for the detailed risk analysis that EPA intends to use to inform the effect 

determinations in this BE. 

3.4.1 Listed Species That May Be Affected 

For the purpose of this BE, EPA assessed all federally-listed aquatic or aquatic-dependent 

species and critical habitats that have more than limited exposure to “waters of the United 

States.” From an initial list of over 1,900 federally-listed species identified by the Services11, 

 

11 The Environmental Conservation Online System (ECOS) geographical information dataset provided by the 

Services included 1,973 unique species polygon ranges for listed species in the United States and its territories. 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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EPA identified 612 aquatic and aquatic-dependent animal and plant species12 that have more 

than limited exposure to “waters of the United States” that may be affected by ANS from vessel 

discharges covered under the proposed actions. Appendix E presents the methodology for 

identifying the 612 aquatic and aquatic-dependent animal and plant species and their critical 

habitats and provides a complete list of the species. This list includes 44 mammals, 4 birds, 

24 reptiles, 27 amphibians, 135 fish, 27 crustaceans, 34 snails, 93 bivalve mollusks (clams and 

abalone), 25 insects, 2 corals, 157 sea grasses and aquatic and wetland plants and 217 designated 

critical habitats that may be affected by the permits. 

From the list of 612 aquatic and aquatic-dependent animal and plant species identified in 

Appendix E, EPA identified 454 aquatic and aquatic-dependent animal and plant species whose 

range is concurrent with waters generally navigable by vessels covered under the VGP and 

sVGP. The list of 454 aquatic and aquatic-dependent animal and plant species identified in 

EPA’s analysis constitute the full range of species and their designated critical habitats that may 

be affected by both ANS and traditional pollutants from the permit actions. Appendix E presents 

the methodology for selecting the 454 aquatic and aquatic-dependent animal and plant species 

and their critical habitats which might be exposed to traditional pollutants from covered vessel 

discharges. 

3.4.2 Description of Species Within RAAs Used to Support the Effects Analysis

EPA identified 82 listed species and 39 critical habitats in the seven RAAs described in 

Section 3.3 for detailed evaluation in the BE. EPA performed a thorough analysis of the potential 

direct and indirect risks posed by ANS and traditional pollutants in incidental discharges from 

vessels covered under the VGP and sVGP (see Section 5.3) on the 82 RAA listed species and 

their critical habitats. EPA used the risk conclusion results from the RAA listed species, in 

combination with our individual species review, to inform the effects determinations for all 612 

listed species and their critical habitats that may be affected by ANS and the 454 listed species 

and their critical habitats that may be affected by traditional pollutants from vessel discharges 

covered by the permits (see Section 7 for additional discussion). Table 3-23 presents the 82 listed 

aquatic and aquatic-dependent species within each RAA. Appendix F provides a description of 

each of the 82 listed species organized by RAA which includes a discussion of the following: 

species critical habitat (if designated), life history, population dynamics, and current status and 

distribution (range-wide, not just within the RAAs). 

Table 3-23. Listed Aquatic and Aquatic-dependent Species in Respective RAAs 

Status Species Scientific Name 

Puget Sound, Seattle, WA

T Marbled Murrelet Brachyramphus marmoratus 

E,T Green Sea Turtle Chelonia mydas 

E Leatherback Sea Turtle Dermochelys coriacea 

E,T Steller Sea-Lion Eumetopias jubatus 

T Water Howellia Howellia aquatilis 

E Humpback Whale Megaptera novaeangliae 

T Chum Salmon (Hood Canal summer-run) Oncorhynchus keta 

 

12 For the purpose of this BE, EPA considered all possible status categories for aquatic and aquatic-dependent 

species (i.e., candidate, endangered, experimental, proposed endangered, proposed threatened, species of concern, 

and threatened.) 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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Table 3-23. Listed Aquatic and Aquatic-dependent Species in Respective RAAs 

Status Species Scientific Name 

E,T Steelhead Salmon (Puget Sound) Oncorhynchus mykiss 

E,T Chinook Salmon (Puget Sound) Oncorhynchus tshawytscha 

E Killer Whale Orcinus orca 

E Short-Tailed Albatross Phoebastria albatrus 

T Bull Trout Salvelinus confluentus 

T Ute Ladies’-Tresses Spiranthes diluvialis 

T Grizzly Bear Ursus arctos horribilis 

Upper and Lower Bay, New York, NY

E Shortnose Sturgeon Acipenser brevirostrum

T Seabeach Amaranth Amaranthus pumilus

E Finback Whale Balaenoptera physalus 

T Loggerhead Sea Turtle Caretta caretta 

E,T Piping Plover Charadrius melodus 

E,T Green Sea Turtle Chelonia mydas 

T Bog Turtle Clemmys muhlenbergii 

E Leatherback Sea Turtle Dermochelys coriacea 

E Hawksbill Sea Turtle Eretmochelys imbricata 

E North Atlantic Right Whale Eubalaena glacialis 

E Kemps’s Ridley Sea Turtle Lepidochelys kempii 

E Humpback Whale Megaptera novaeangliae 

E Indiana Bat Myotis sodalis 

E Roseate Tern Sterna dougallii dougallii 

Galveston Bay, Houston, TX

E Finback Whale Balaenoptera physalus 

T Loggerhead Sea Turtle Caretta caretta 

E,T Piping Plover Charadrius melodus 

E,T Green Sea Turtle Chelonia mydas 

E Leatherback Sea Turtle Dermochelys coriacea 

E Hawksbill Sea Turtle Eretmochelys imbricata 

E Whooping Crane Grus americana 

E Kemps’s Ridley Sea Turtle Lepidochelys kempii 

E Humpback Whale Megaptera novaeangliae 

E Smalltooth Sawfish Pristis pectinata 

E West Indian Manatee Trichechus manatus 

Mississippi River, Saint Louis, MO

T Decurrent False Aster Boltonia decurrens 

E Pink Mucket Lampsilis abrupta 

E Scaleshell Mussel Leptodea leptodon 

E Gray Bat Myotis grisescens 

E Indiana Bat Myotis sodalis 

T Eastern Prairie Fringed Orchid Platanthera leucophaea 

E Pallid Sturgeon Scaphirhynchus albus 

E Least Tern Sterna antillarum 

Saint Louis Estuary, Duluth, MN

E,T Piping Plover Charadrius melodus 

San Francisco Bay Estuary, San Francisco, CA

T Sturgeon, North American green Acipenser medirostris 

E Alopecurus, Sonoma Alopecurus aequalis var. sonomensis 

E,T Salamander, California tiger Ambystoma californiense 

T Seal, Guadalupe fur Arctocephalus townsendi 

E Sunshine, Sonoma Blennosperma bakeri 

T Murrelet, marbled Brachyramphus marmoratus 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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Table 3-23. Listed Aquatic and Aquatic-dependent Species in Respective RAAs 

Status Species Scientific Name 

E Fairy shrimp, conservancy Branchinecta conservatio 

E Fairy shrimp, longhorn Branchinecta longiantenna 

T Sea turtle, loggerhead Caretta caretta 

E Sedge, white Carex albida 

T Spurge, Hoover's Chamaesyce hooveri 

T Plover, western snowy Charadrius alexandrinus nivosus 

T Sea turtle, green Chelonia mydas 

E Thistle, fountain Cirsium fontinale var. fontinale 

E Thistle, Suisun Cirsium hydrophilum var. hydrophilum 

E Bird's-beak, soft Cordylanthus mollis ssp. Mollis 

E Bird's beak, palmate-bracted Cordylanthus palmatus 

E Sea turtle, leatherback Dermochelys coriacea 

T Beetle, valley elderberry longhorn Desmocerus californicus dimorphus 

T Beetle, delta green ground Elaphrus viridis 

T Otter, southern sea Enhydra lutris nereis 

E Goby, tidewater Eucyclogobius newberryi 

T Sea-lion, Steller Eumetopias jubatus 

E Abalone, White Haliotis sorenseni 

T Smelt, delta Hypomesus transpacificus 

T Sea turtle, Olive Ridley Lepidochelys olivacea 

E Tadpole shrimp, vernal pool Lepidurus packardi 

T Whipsnake (=striped racer), Alameda Masticophis lateralis euryxanthus 

T Grass, Colusa Neostapfia colusana 

E Woodrat, riparian Neotoma fuscipes riparia 

E,T Steelhead (Central and South Central CA) Oncorhynchus (=Salmo) mykiss 

E Whale, killer (Southern Resident DPS) Orcinus orca 

E Orcutt grass, hairy Orcuttia pilosa 

E Allocarya, Calistoga Plagiobothrys strictus 

E Bluegrass, Napa Poa napensis 

T Frog, California red-legged Entire Rana draytonii 

E Mouse, salt marsh harvest Reithrodontomys raviventris 

E Shrimp, California freshwater Syncaris pacifica 

T Snake, giant garter Thamnophis gigas 

E Grass, Solano Tuctoria mucronata 

Biscayne Bay, Miami, FL

E Sturgeon, shortnose Acipenser brevirostrum 

T Sturgeon, gulf Acipenser oxyrinchus desotoi 

T Coral, staghorn Acropora cervicornis 

T Coral, elkhorn Acropora palmata 

E Sparrow, Cape Sable seaside Ammodramus maritimus mirabilis 

E Whale, finback Balaenoptera physalus 

E Bellflower, Brooksville Campanula robinsiae 

E Wolf, red Canis rufus 

T Sea turtle, loggerhead Caretta caretta 

E,T Sea turtle, green Chelonia mydas 

T Crocodile, American Crocodylus acutus 

E Sea turtle, leatherback Dermochelys coriacea 

T Snake, eastern indigo Drymarchon corais couperi 

E Sea turtle, hawksbill Eretmochelys imbricata 

E Whale, North Atlantic Right Eubalaena glacialis 

T Seagrass, Johnson's Halophila johnsonii 

E Whale, humpback Megaptera novaeangliae 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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Table 3-23. Listed Aquatic and Aquatic-dependent Species in Respective RAAs 

Status Species Scientific Name 

E Stork, wood Mycteria americana 

E Bat, gray Myotis grisescens 

E Bat, Indiana Myotis sodalis 

T Caracara, Audubon's crested Polyborus plancus audubonii 

E Sawfish, smalltooth Pristis pectinata 

E Panther, Florida Puma (=Felis) concolor coryi 

E Kite, Everglade snail Rostrhamus sociabilis plumbeus 

E Chaffseed, American Schwalbea americana 

T Tern, roseate Sterna dougallii dougallii 

E Manatee, West Indian Trichechus manatus 

3.5 REFERENCES

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coastal areas and its economical and environmental assessment. International Journal of 

Environmental Science and Technology, 2: 13-26. 

Alaska Department of Environmental Conservation (ADEC). 2006. Commercial Passenger 

Vessel Compliance Program 2006 Small Ship Wastewater Sampling Results. 

Alaska Department of Environmental Conservation (ADEC). 2007a. Commercial Passenger 

Vessel Compliance Program 2007 Small Ship Wastewater Sampling Results. 

Alaska Department of Environmental Conservation (ADEC). 2007b. Large Commercial 

Passenger Vessel Wastewater Discharge: General Permit Information Sheet. Retrieved 

from 

http://www.dec.state.ak.us/water/cruise_ships/pdfs/GP%20Information%20Sheet.pdf. 

Albert, R., Everett, R., Lishman, J., and Smith, D. 2010. Availability and Efficacy of Ballast 

Water Treatment Technology: Background and Issue Paper. Prepared for Science 

Advisory Board. 

Battelle. 2007. Technical support for EPA development of a permitting framework to address the 

vacatur of the NPDES vessel exclusion. Revised Draft, September 2007. 

Baltic Marine Environment Protection Commission (BMEPC), 28th Meeting. 2007. Estimated 

Nutrient Load from Ship Originated Waste Waters in the Baltic Sea Area. Helsenki 

Commission, 7-8 March 2007. 

California Environmental Protection Agency. 2002. Evaluation of Ballast Water Treatment 

Technology for Control of Nonindigenous Aquatic Organisms, December 2002. 

California Regional Water Quality Control Board, San Diego Region. 2006. Shelter Island Yacht 

Basin TMDL for Dissolved Copper. Retrieved from 

http://www.waterboards.ca.gov/sandiego/tmdls/shelter%20island.html. 

Carlton, J.T., D.M. Reid, and H. van Leeuwen. 1995. Shipping Study: The Role of Shipping in 

the Introduction of Nonindigenous Aquatic Organisms to the Coastal Waters of the 
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United States (other than the Great Lakes) and an Analysis of Control Options. USCG 

Report No. CG-D-11-95. 

Carlton, J.T. 2001. The Scale of Ecological Consequences of Biological Invasions in the Worlds 

Oceans. Invasive Species and Biodiversity Management, Kluwer Academic Publishers. 

Carter, C. 2011. What Ship Owners Need to Know About Stern Tube Lubricating Oil 

Discharges. Shipping and Environmental Issues in 2011. Retrieved from 

www.compartevents.com/MasterMariners/PDF/Carter.pdf. 

DiGangi, J., Schettler, T., Cobbing, M., & Rossi, M. 2002. Aggregate Exposures to Phthalate in 

Humans. Health Care Without Harm. 

Drake, J.M., and Lodge, D.M. 2007. Rate of Species Introductions in the Great Lakes via Ships 

BallastWater and Sediments. Canadian Journal of Fisheries and Aquatic Sciences, 

64:(3), 530 – 538. 

Edkin, D.S. 2010. Worldwide Analysis of In-Port Vessel Operational Lubricant Discharges and 

Leakages. 33rd AMOP Technical Seminar on Environmental Contamination and 

Response, June 7-9, 2010. Halifax, Nova Scotia. 

Govorushko, S.M. 2007. Effect of Human Activity on Rivers. International Conference on River 

Basin Management. Organized by the General Directorate of State Hydraulic Works 

(DSI), Turkey. Retrieved from http://www.dsi.gov.tr/english/congress2007/. 

Kasyan, V. 2010. Holoplankton of Ship Ballast Water in the Port of Vladivostok. Russian 

Journal of Marine Biology, 36(3): 167-165. 

Keller, R.P. and Drake, J.M. 2011. Linking Environmental Conditions and Ship Movements To 

Estimate Invasive Species Transport Across the Global Shipping Network. Journal of 

Conservation Biogeography, 17(1). 

Knight, I.T., Wells, C.S., Wiggins, B., Russell, H., Reynolds, K.A., & Huq., A. 1999. Detection 

and enumeration of fecal indicators and pathogens in the ballast water of transoceanic 

cargo vessels entering the Great Lakes. In General Meeting of the American Society for 

Microbiology, pp. 546, Chicago, IL, Abstract Q71. 

LMC. 2011. Letter to EPA Region 5 Regarding SS Badger Petition for Individual NPDES 

Permit. November 2. Retrieved from 

http://www.epa.gov/r5water/npdestek/badger/pdfs/petition.pdf. 

MEPC. 2008. 58/23 Annex 16, Report of the Marine Environment Protection Committee on its 

fifty eighth session. International Maritime Organization, 2008. 

National Academy of Sciences National Research Council (NAS). 2011. Assessing the 

Relationship Between Propagule Pressure and Invasion Risk in Ballast Water. Committee 

on Assessing Numeric Limits for Living Organisms in Ballast Water, National Research 

Council. National Academies Press. 
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National Science and Technology Council. 2000. National Assessment of Harmful Algal Blooms 

in US Waters. October 2000 

Reynolds, K., Knight, I., Wells, C., Pepper, I., & Gerba, C. 1999. Detection of human pathogenic 

protozoa and viruses in ballast water using conventional and molecular methods. In 

General Meeting of the American Society for Microbiology, pp. 594, Chicago, IL, 

Abstract Q318. 

Schiff, K, D. Diehl, and A. Valkirs. 2003. Copper Emissions from Antifouling Paint on 

Recreational Vessels. Technical Report 405. Prepared for the Southern California Coastal 

Water Research Project. (June). Retrieved from 

http://www.sccwrp.org/pub/download/DOCUMENTS/TechnicalReports/405_recreationa

l.pdf. 

Ship Technology. 2011. Emma Maersk – Container Ship Fact Sheet. Retrieved from www.shiptechnology.com/projects/emmamaerskcontiners/.

Sytsma, M.D., J.R. Cordell, J.W. Chapman, and R.C. Draheim. 2004. Lower Columbia River 

Aquatic Nonindigenous Species Survey 2001-2004: Final Technical Report. Prepared for 

the U.S. Coast Guard and U.S. Fish and Wildlife Service. Retrieved from 

www.clr.pdx.edu/docs/LCRANSFinalReport.pdf. 

USEPA. 1999. Phase I Uniform National Discharge Standards (UNDS) for Vessels of the Armed 

Forces, Technical Development Document. EPA 821-R-99-001, April 1999. 

USEPA. 2006. Sampling Episode Report for Holland America Veendam (Sampling Episode 

6503). Washington, DC. 

USEPA. 2008. Cruise Ship Discharge Assessment Report. EPA 842-R-07-005, December 29, 

2008. 

USEPA. 2009. Regulatory Impact Analysis: Control of Emissions of Air Pollution from 

Category 3 Marine Diesel Engines. EPA 420-R-09-19. Assessment and Standards 

Division, Office of Transportation and Air Quality, U.S. Environmental Protection 

Agency. December, 2009. 

USEPA. 2010. Report to Congress: Study of Discharges Incidental to Normal Operation of 

Commercial Fishing Vessels and Other Non Recreational Vessels less than 79 Feet. EPA 

833-R-10-005. U.S. Environmental Protection Agency, Washington, DC. 

USEPA. 2011a. National Pollutant Discharge Elimination System (NPDES) Vessel General 

Permit (VGP) for Discharges Incidental to the Normal Operation of Vessels Fact Sheet. 

Retrieved from www.epa.gov/npdes/vessels. 

USEPA. 2011b. National Pollutant Discharge Elimination System (NPDES) Small Vessel 

General Permit (sVGP) for Discharges Incidental to the Normal Operation of Vessels 

Less than 79 Feet Fact Sheet. Retrieved from www.epa.gov/npdes/vessels. 

USEPA. 2011c. Exhaust Gas Scrubber Washwater Effluent. EPA 800-R-11-006, November 

2011. 
2013 VGP and sVGP BE Section 3- Biological Evaluation Approach 

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USEPA. 2011d. Graywater Discharges from Vessels. EPA 800-R-11-001, November 2011. 

USEPA. 2011e. Summary of the VGP Vessel Universe: Information Submitted by Vessel 

Owner/Operators for Coverage Under the Vessel General Permit (VGP). EPA 833-K-11-

102, April, 2011. 

USEPA. 2011f. Underwater Ship Husbandry Discharges. EPA 800-R-11-004, November 2011. 

USEPA. 2011g. Ballast Water Discharges from Vessels. EPA 800-R-11-003. November 2011. 

USEPA. 2011h. Oily Bilgewater Separators. EPA 800-R-11-007, November 2011. 

USCG. 2012. Standards for Living Organisms in Ships’ Ballast Water Discharged in U.S. 

Waters. Department of Homeland Security, Coast Guard. 33 CFR Part 151; 46 CFR Part 

162 [Docket No. USCG–2001–10486] RIN 1625–AA32. Federal Register, Vol. 77, No. 

57. Friday, March 23, 2012. 

USCG. 2009. Marine Information for Safety and Law Enforcement (MISLE) Database. U.S. 

Coast Guard, Washington DC. 

USCG. 2008. Standards for Living Organisms in Ships’ Ballast Water Discharged in U.S. 

Waters Preliminary Regulatory Analysis and Internal Regulatory Flexibility Analysis. 

USCG-2001-10486, June 2008. 

Urban Harbors Institute. 2000. Green Ports: Environmental Management and Technology at US 

Ports. University of Massachusetts, Boston, MA. 

Wurts, W.A. and R.M. Durborrow. 1992. Interactions of pH, Carbon Dioxide, Alkalinity and 

Hardness in Fish Ponds. Southern Regional Aquaculture Center Publication No. 464. 

Zo, Y., Grimm, C., Matte, M., Matte, G., Knight, I.T., Huq, A., & Colwell, R.R. 1999. Detection 

and Enumeration of Pathogenic Bacteria in Ballast Water of Transoceanic Vessels 

Entering the Great Lakes and Resistance to Common Antibiotics. In General Meeting of 

the American Society for Microbiology, Chicago, IL, Abstract Q317. 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

4-1

SECTION 4 

ENVIRONMENTAL BASELINE 

The environmental baseline considers all natural and anthropogenic constraints that affect 

the abundance and distribution of listed species. The environmental baseline includes “the past 

and present impacts of all federal, state, or private actions and other human activities in the 

action area, the anticipated impacts of all proposed Federal projects in the action area that have 

already undergone formal or early Section 7 consultation, and the impact of state or private 

actions which are contemporaneous with the consultation in process.” (50 CFR §402.02). It is 

meant to present a "snapshot" of the species' health at the present point in time. 

The environmental baseline complements the information provided in Sections 3.3 and 

3.4 of this BE and is intended to provide the context with which to interpret the results of the risk 

conclusions in Section 5. The BE evaluates effects identified in Sections 5.1 and 5.2 in 

combination with the baseline to determine the likelihood of adverse effects (Section 7) and 

cumulative effects (Section 8) to listed species or designated critical habitats due to EPA’s 

proposed permit actions. 

Collectively, the two permit actions impact many waters in the United States, as 

described in Section 3.3 of this BE. The focus of this discussion is on listed species in seven 

representative RAAs. As previously discussed (see Table 3-22 – RAA selection and 

corresponding justification), these seven areas are among areas which have the highest vessel 

densities and, hence, highest potential for risk to aquatic and aquatic-dependent wildlife. 

Moreover, the subset of 82 species (see list in Table 3-23 and corresponding descriptions in 

Appendix F) residing in these areas are generally representative of the broad range of aquatic or 

aquatic-dependent listed species and their habitats across the U.S., The risk estimated for this 

subset of 82 listed aquatic and aquatic-dependent species and their critical habitats from seven 

RAAs is used later in this document to inform effects findings for the full range of 454 (for 

conventional toxics and non-conventional pollutants with toxic effects) or 612 (for ANS and 

other pollutants lacking specific toxic effects) listed species and the waters [all waters of the U.S. 

and its Territories] that might be affected by the permit actions. Again, EPA employed this 

approach because to the Agency believes this is a reasonable way to estimate the exposure 

potential for all listed species in all applicable waters. 

As part of the baseline, anthropogenic factors are described largely on the basis of 

predominant land and water uses within each RAA because land use patterns often suggest 

certain habitat and water quality conditions due to potential stressors associated with a particular 

human land use. Background information on pollutants in the aquatic environment is also 

provided, which, in addition to natural factors, describes the physical and chemical quality of 

waters in each RAA and the impact human activities have contributed to the current status of 

listed resources in the seven geographically distinct areas. Finally, documented invasion by 

aquatic nuisance species (ANS) is also noted to provide context and support qualitative analysis 

and determinations in the ensuing sections of this document. 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

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This section describes the current ecosystem status of each respective RAA and 

summarizes the current major and minor threats identified by the Services to each of the listed 

species subject to the effects analysis in this BE. 

4.1 ECOSYSTEM STATUS WITHIN RAAS

The following subsections provide overviews of the status of the ecosystem within each 

RAA, including a description of the: 

 Ecosystem, 

 Major Land Uses, 

 Vessel Populations Present, 

 Habitat Modification and Restoration, 

 Water Quality Impairments, and 

 Aquatic Nuisance Species (ANS). 

As demonstrated by the following discussions, baseline for the seven RAAs and their list 

of threatened and endangered species are affected by a broad range of anthropogenic and natural 

impacts that are common to many other listed species in the U.S., and except for introduction of 

ANS, there is little evidence to suggest that managed vessel discharges are a major contributing 

factor. 

4.1.1 Ecosystem Status of Puget Sound/Seattle, WA RAA

Puget Sound is an estuary of the Pacific Ocean in northwestern Washington. While the 

entire body of water that extends northward from Olympia, WA to the Canadian border and on 

either side of Vancouver Island is often referred to as Puget Sound, in actuality, this area is 

comprised of several separate and distinct water bodies, including the Strait of Juan de Fuca, the 

Strait of Georgia, the waters surrounding the San Juan Islands, Hood Canal, and Puget Sound 

(Figure 4-1). For the purposes of this document, the areas related to this RAA will be Puget 

Sound itself as well as the major channels that connect Puget Sound to the Atlantic Ocean (i.e., 

Strait of Juan de Fuca and Admiralty Inlet). 

The Strait of Juan de Fuca is a 92 mile long, narrow body of water that passes between 

Vancouver Island and the north end of Washington State’s Olympic Peninsula (US Navy, 1996). 

It serves as the primary oceanic access to Puget Sound. 

Puget Sound, a bay with numerous channels and branches, extends approximately 81 

miles south from the eastern end of the Strait of Juan de Fuca to the City of Olympia, WA. Puget 

Sound includes the water area south from the northeast part of the Olympic Peninsula to the 

western extremity of Whidbey Island, and eastward from the north end of Whidbey Island (US 

Navy, 1996). It has about 2,140 miles of shoreline and contains several ports and harbors, 

including the cities of Olympia, Tacoma and Seattle, as well as several U.S. Navy installations. 

Admiralty Inlet is a narrow body of water passing between Whidbey Island on the east 

and the northeast part of the Olympic Peninsula on the west (Figure 4-1). Included within the 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

4-3

limits of Puget Sound, Admiralty Inlet begins at the east end of the Strait of Juan de Fuca and 

extends southward along the west coast of Whidbey Island for approximately 18 miles. All deep 

draft vessels entering or leaving Puget Sound must pass through Admiralty Inlet (US Navy, 

1996). Consequently, it is a busy traffic area for large vessels. 

The Puget Sound watershed (including northern Puget Sound) covers 13,500 square miles 

and consists of over ten thousand rivers and streams that drain into the Sound (Figure 4-1). Over 

80 percent of surface water flowing into Puget Sound comes from the following major river 

drainages: Cedar/Lake Washington canal, Duwamish/Green, Elwha, Nisqually, Nooksack, 

Puyallup, Skagit, Skokomish, Snohomish, and Stillaguamish. 

4.1.1.1 Ecosystem Description of Puget Sound/Seattle, WA 

Habitat types that occur within the nearshore environment of Puget Sound include 

eelgrass meadows, kelp forest, mud flats, tidal marshes, sub-estuaries (tidally influenced portions 

of river and stream mouths), sand spits, beaches and backshore, banks and bluffs, and marine 

riparian vegetation. These habitats provide critical functions such as primary food production 

and support habitat for invertebrates, fish, birds, and other wildlife (NMFS, 2009). 

The Puget Sound basin is home to more than 200 fish and 140 mammalian species. 

Salmonids within the region include coho, Chinook, sockeye, chum, and pink salmon, kokanee, 

steelhead, rainbow, cutthroat, and bull trout (Wydoski and Whitney, 1979; Kruckeberg, 1991). 

Important commercial fishes include the five Pacific salmon and several rockfish species. A 

number of introduced species occur within the region, including brown and brook trout, Atlantic 

salmon, bass, tunicates (sea squirts), and a salt marsh grass (Spartina spp.). Estimates suggest 

that over 90 species have been intentionally or accidentally introduced in the region 

(Ruckelshaus and McClure, 2007). At present, over 40 species in the region are listed as 

threatened and endangered under the ESA, 14 of which were selected for detailed evaluation in 

this BE (see Section 3.4). 

4.1.1.2 Major Land Uses Near Puget Sound/Seattle, WA 

Land use in the Puget Sound Lowland (the watershed roughly west of the Cascade Range 

and east of the Olympic Mountains) is composed of agricultural areas (including forests for 

timber production), urban areas (industrial and residential use), and rural areas (low density 

residential with some agricultural activity). Table 4-1 shows the types and areas of land use 

within the Puget Sound Basin. 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

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Figure 4-1. Land Use and Physical Feature Map of Puget Sound/Seattle, WA RAA 

   
2013 VGP and sVGP BE Section 4- Environmental Baseline 

4-5

Table 4-1. Area of Land Use Categories Within 

the Puget Sound Basin 

Land Use Type Area (mi2) 

Open Water 2,383 

Perennial Snow/Ice 121 

Developed, Open Space 618 

Developed, Low Intensity 654 

Developed, Medium Intensity 258 

Developed, High Intensity 103 

Barren Land 402 

Deciduous Forest 386 

Evergreen Forest 5,576 

Mixed Forest 975 

Shrub/Scrub 932 

Herbaceous 369 

Hay/Pasture 459 

Cultivated Crops 100 

Woody Wetlands 250 

Emergent Herbaceous Wetlands 190 

Source: NMFS, 2009. 

In the 1930s, all of western Washington contained about 15.5 million acres of harvestable 

forestland. By 2004, the total acreage was nearly half that originally surveyed (PSAT, 2007). 

Forest cover in Puget Sound alone was about 5.4 million acres in the early 1990s. About a 

decade later, the region had lost about 200,000 acres of forest cover with some watersheds losing 

more than half the total forested acreage. Projected land cover changes indicate that trends are 

likely to continue over the next several decades as the population continues to increase 

(Ruckelshaus and McClure, 2007). 

The Puget Sound Lowland contains the most densely populated area of Washington. The 

regional population in 2003 was an estimated 3.8 million people, with 86 percent residing in 

King, Pierce, and Snohomish counties (Snohomish, Cedar-Sammamish Basin, GreenDuwamish, and Puyallup River watersheds). The area is expected to attract 4 to 6 million new 

residents in the next 20 years (Ruckelshaus and McClure, 2007). The population of the 

Snohomish River watershed is one of the fastest growing watersheds in the region. 

Although urban areas occupy only 2 percent of the Pacific Northwest land base, the 

impacts of urbanization on aquatic ecosystems are severe and long lasting (Spence et al., 1996). 

According to the 2001 State of the Sound report (PSAT, 2007), impervious surfaces covered 3.3 

percent of the region, with 7.3 percent of lowland areas (below 1,000 feet elevation) covered by 

impervious surfaces. From 1991 to 2001, the amount of impervious surfaces increased 10.4 

percent region wide. The increase in impervious surfaces changes the rainfall delivery to streams 

altering stream flow regimes. Peak flows are increased and subsequent base flows are decreased. 

Stream channels are widened and deepened, and riparian vegetation is typically removed which 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

4-6

can cause increases in water temperature and reduce the amounts of woody debris and organic 

matter to the stream system. 

Industries in this area include aerospace, military, biotechnology, fishing, electronics, 

computers, forest products, marine industries, telecommunications, transportation and other 

commerce industries (WSDC, 2010). More than 100 years of industrial pollution and urban 

development have affected water quality and sediments in Puget Sound. These issues are further 

addressed in the next section. 

4.1.1.3 Vessel Populations Present in Puget Sound/Seattle, WA 

The Port of Seattle (Figure 4-1) is the largest port in this RAA and represents the primary 

harbor area of focus in this assessment. It plays a key role in bringing international trade, 

transportation and travel to the Pacific Northwest, as well as supporting a diversity of industries 

such as tourism and commercial fishing (Port of Seattle, 2012). Passenger cruise terminals in the 

port handled 195 ship calls and an estimated 855,000 passengers during the 2011 season (Port of 

Seattle, 2012). State-of-the-art cargo handling facilities helped rank Seattle as the nation’s sixth 

busiest U.S. seaport in 2010, serving 22 international steamship lines moving more than 2.1 

million TEUs (20-foot equivalent unit containers) (Port of Seattle, 2012). The Port of Tacoma is 

a separate seaport located south of the Port of Seattle. Its proximity to the Port of Seattle suggests 

that vessels bound for Tacoma may transit through the Puget Sound/Seattle, WA RAA. 

4.1.1.4 Habitat Modification and Restoration in Puget Sound/Seattle, WA 

Much of the region’s estuarine wetlands have been heavily modified, primarily from 

agricultural land conversion and urban development (NRC, 1996). Although most estuarine 

wetland losses result from conversions to agricultural land by ditching, draining, or diking, these 

wetlands also experience increasing effects from industrial and urban causes. By 1980, an 

estimated 27,180 acres of intertidal or shore wetlands have been lost at 11 deltas in Puget Sound 

(Bortleson et al., 1980). Only about 18 percent of the historical extent of tidal wetlands remains 

in Puget Sound (Collins and Sheikh, 2005). Coastal marshes close to seaports and population 

centers have been especially vulnerable to conversion with losses of 50 to 90 percent. These land 

conversions and losses of Pacific Northwest wetlands constitute a major impact on native species 

including salmonids. 

Urbanization has directly caused loss of riparian vegetation and soils and significantly 

altered hydrologic and erosion rates. About 800 miles of Puget Sound’s shorelines are hardened 

or dredged (PSAT, 2005; Ruckelshaus and McClure, 2007). The area most intensely modified is 

the urban corridor, along the eastern shores of Puget Sound from Mukilteo to Tacoma. Here, 

nearly 80 percent of the shoreline has been altered, mostly from shoreline armoring associated 

with railroad tracks (Ruckelshaus and McClure, 2007). Large areas of the lower rivers have been 

channelized and diked for flood control and to protect agricultural, industrial, and residential 

development. Levee development within the rivers and their deltas has isolated significant 

portions of former floodplain habitat that was historically used by salmon and trout during rising 

flood waters. 
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Watershed development and associated urbanization throughout the Puget Sound, Hood 

Canal, and Strait of Juan de Fuca regions have increased sedimentation, raised water 

temperatures, decreased large woody debris and gravel recruitment, reduced river pools and 

spawning areas, and dredged and filled estuarine rearing areas (Bishop and Morgan, 1996). 

4.1.1.5 Water Quality Impairments in Puget Sound/Seattle, WA 

Section 303(d) of the federal Clean Water Act requires that a state must identify its 

polluted water bodies and submit this list to EPA every two years. The state of Washington 

identified a total of 576 different waterbodies within seven Puget Sound action areas as Category 

5 (impaired) waters on their 2008 303(d) list (WDOE, 2008). A total of 43 different pollutants 

were identified as contributing to the impairments within these listed waters in the RAA (Table 

4-2). While fecal coliform, dissolved oxygen and temperature were the major causes of 

impairments, persistent organic contaminants (PCBs, TCDD, PAHs), nutrients (phosphorus), 

heavy metals, and pesticides were also noted. 

Table 4-2. Causes for Impairment in Puget Sound Action Areas – 2008 

Parameter

Puget Sound Action Area 

Grand 

Total

Hood 

Canal 

Juan 

de 

Fuca 

North 

Central 

Puget 

Sound 

South 

Central 

Puget 

Sound 

South 

Puget 

Sound 

Whidbey 

Island 

2,3,7,8-TCDD 1 6 2 1 10 

4,4'-DDD 2 2 

4,4'-DDE 3 3 

4,4'-DDT 1 1 

Aldrin 1 1 

Alpha-BHC 1 1 2 

Ammonia-N 1 1 2 

Benzo[a]anthracene 1 1 2 4 

Benzo[a]pyrene 1 1 

Benzo[b]fluoranthene 1 1 

Benzo[b]fluorene 1 1 

Benzo[k]fluoranthene 1 1 

Benzo[k]fluorene 1 1 

Bioassessment 8 2 1 11 

Bis(2-Ethylhexyl) 

Phthalate 1 1 

Chlordane 1 1 

Chlorinated Pesticides 1 1 

Chrysene 1 1 3 5 

Copper 10 10 

DDT 1 1 

Dibenzo[a,h]anthracene 1 1 
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Table 4-2. Causes for Impairment in Puget Sound Action Areas – 2008 

Parameter

Puget Sound Action Area 

Grand 

Total

Hood 

Canal 

Juan 

de 

Fuca 

North 

Central 

Puget 

Sound 

South 

Central 

Puget 

Sound 

South 

Puget 

Sound 

Whidbey 

Island 

Dieldrin 3 1 4 

Dioxin 3 3 

Dissolved Oxygen 46 20 62 94 60 98 380 

Fecal Coliform 32 30 74 158 96 83 473 

Fine Sediment 3 1 4 

Hexachlorobenzene 1 1 2 

High MW PAH 2 2 

Indeno(1,2,3-cd)pyrene 1 1 

Lead 1 1 2 

Mercury 1 1 3 1 6 

PCB 2 1 2 23 15 5 48 

pH 4 2 2 11 12 34 65 

Sediment Bioassay 1 1 

Temperature 34 68 7 74 64 24 271 

Total Chlordane 2 2 

Total Dioxins 1 1 

Total Furans 1 1 

Total Nitrogen 1 1 

Total Phosphorus 1 1 11 9 8 30 

Toxaphene 1 1 

Turbidity 5 5 

Zinc 2 2 

Grand Total 122 132 156 419 268 269 1366 

Source: WDOE, 2008. 

Studies of rivers and streams in the Puget Sound basin performed by the United States 

Geological Survey (USGS) from 1996 to 1998 indicated that federal and state water quality 

guidelines were met by many of the waterbodies, and in general, large rivers were more likely to 

meet guidelines than were small streams (USGS, 2000). Concentrations of fecal coliform 

indicator bacteria frequently exceeded EPA recreational criteria and state standards protecting 

beneficial uses of surface water, and insecticide concentrations were occasionally higher than 

guidelines recommended to protect aquatic life. A total of 74 manmade organic chemicals were 

detected in streams and rivers, with different mixtures of chemicals linked to agricultural and 

urban settings (USGS, 2000). 

Many different kinds of activities and substances release pollution into Puget Sound and 

the contributing waters. In 2004, the Puget Sound Action Team (PSAT) identified the primary 

pollutants of concern in Puget Sound and their sources as listed below in Table 4-3. 
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Table 4-3. Pollutants of Concern in Puget Sound 

Pollutant Sources 

Heavy Metals: 

Pb, Hg, Cu, and others 

Vehicles, batteries, paints, dyes, stormwater 

runoff, spills, pipes. 

Organic Compounds: 

Polycyclic aromatic hydrocarbons (PAHs) Burning of petroleum, coal, oil spills, leaking 

Polychlorinated biphenyls (PCBs) Underground fuel tanks, creosote, asphalt. 

Dioxins, Furans Byproducts of industrial processes. 

Dichloro-diphenyl-trichloroethane (DDTs) Chlorinated pesticides. 

Phthalates 

Plastic materials, soaps, and other personal care 

products. Many of these compounds are in 

wastewater from sewage treatment plants. 

Polybrominated diphenyl ethers (PBDEs) 

PBDEs are added to a wide range of textiles and 

plastics as a flame retardant. They easily leach 

from these materials and have been found 

throughout the environment and in human breast 

milk. 

Source: PSAT, 2005. 

In addition, 27 Superfund sites are currently listed within the Puget Sound watershed. Of 

those, six are described as significantly polluting surface waters and/or sediments in or 

immediately adjacent to Puget Sound (USEPA, 2011). 

Puget Sound is unique among the nation’s estuaries as it is a deep fjord-like structure 

containing many urban areas within its drainage basin (Collier et al., 2007). Because of the 

several sills that limit entry of oceanic water into Puget Sound, it is relatively poorly flushed 

compared to other urbanized estuaries of North America. Thus, toxic chemicals that enter Puget 

Sound have longer residence times within the system. This entrainment of toxics can increase 

biota exposure to contaminant concentrations when compared to other large estuaries. This 

hydrologic isolation also puts the Puget Sound ecosystem at higher risk from other types of 

pollutants that enter the system, such as nutrients and pathogens. 

Because Puget Sound is a deep, almost oceanic habitat, the tendency of a number of 

species to migrate outside of Puget Sound is limited relative to similar species in other large 

urban estuaries. This high degree of residency for many marine species, combined with the poor 

flushing of Puget Sound, results in greater exposure of these species to contaminants. The 

combination of hydrologic and biological isolation makes the Puget Sound ecosystem highly 

susceptible to inputs of toxic chemicals (Collier et al., 2007). 

4.1.1.6 Historic ANS Introductions and Impacts in Puget Sound/Seattle, WA 

In 2004, a study commissioned by the Puget Sound Partnership reported that 54 nonnative species (both plants and animals) have established themselves permanently, and an 

additional 22 others have been sighted in the Puget Sound region but may not be established nor 

are reproducing (Cohen, 2004). This study incorporated data from a number of previous invasive 
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species surveys, and attributed the introduction of numerous nuisance species to vessels 

operating within Puget Sound. The study indicated that 33 established invasive plant and animal 

species were potentially introduced via ballast water or hull fouling. Ballast water was implicated 

in the introduction of 17 of these invasive species including the purple varnish clam, the Pacific 

transparent sea squirt, common sea grape, and club tunicate, as well several other crustaceans 

and polychaete worms (Cohen, 2004). 

Regional analysis of four major Northeast Pacific Ocean (NEP) estuaries in 2005 showed 

that Puget Sound and the contiguous Straits had the most introduced species, followed by 

Humboldt Bay, Coos Bay and Willapa Bay (Wonham and Carlton, 2005). The authors’ review of 

literature and field surveys, documented 123 introduced invertebrate, algal, fish, and vascular 

plant species in the NEP. Major invasion pathways were shipping (hull fouling and solid and 

water ballast) from the 1500s to the present, and shellfish (particularly oysters) and finfish 

imports, most common from the 1870s to mid-1900s (Wonham and Carlton, 2005). 

4.1.2 Ecosystem Status of Upper and Lower Bay/New York, NY RAA

The New York/New Jersey Estuary connects the Hudson River to the Atlantic Ocean. 

Located between the states of New York and New Jersey, its main components are the Upper 

and Lower New York Bays, connected by the Narrows (Figure 4-2). Upper New York Bay, also 

known as New York Harbor, is located along the western shore of Long Island, extending from 

the confluence of the Hudson and East Rivers in the north to Lower New York Bay in the south. 

The New Jersey ports of Perth Amboy, Port Elizabeth, Port Newark, Bayonne and others are 

accessible through tributaries that empty into Upper New York Bay (US Navy, 2009). Lower 

New York Bay includes Jamaica Bay to the east and Sandy Hook Bay to the south. Other waters 

of the New York Bay estuary include the Hudson River below Troy Dam, Newark Bay, Jamaica 

Bay, Raritan Bay, East River, Kill van Kull, and Arthur Kull. For the purposes of this report, the 

areas related to this RAA include Upper and Lower New York Bay, Raritan Bay, and Kill van 

Kull. 

The urban core of the New York City metropolitan area is centered around the Upper and 

Lower New York Bays. The urban core includes all the land area within a 25 mile radius of 

Central Park, Manhattan, NY; this 1,963 square mile area encompasses most of the urban 

developed land in the greater metropolitan New York City region (USFWS, 1997). The Upper 

Bay, surrounding the Statue of Liberty, Ellis Island and Governor’s Island, is closely tied to 

portions of Manhattan, Brooklyn, and Staten Island, NY, as well as Hudson County, NJ 

(USACE, 2009). 

The immediate New York Bay watershed consists of all rivers and waterways draining 

directly into it. Dominating the hydrology of this system is the 320 mile Hudson River. The 

entire Hudson drains a watershed of 13,400 square miles, and has an average flow of 21,000 

cubic feet/second, with large seasonal variations in fresh water inflow and inversely related 

levels of salt water intrusion (USFWS, 1997). 
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4.1.2.1 Ecosystem Description of Upper and Lower Bay/New York, NY 

The convergence of three physiographic provinces (the sand, gravels, and clays of the Atlantic 

Coastal Plain; the sandstones, shales, and igneous intrusions of the Piedmont Province; and the 

metamorphic crystalline rock ridges of the New York/New Jersey Highlands and Manhattan 

Hills extensions of the New England Province) provides a great diversity of landforms, bedrock 

types, and vegetational communities within the urban core. Overlaying this complex base is 

glacial till, glacial lake sediments, and glacial outwash sediments. Much of the glaciated region 

tends to have complex surface drainage patterns, resulting in numerous freshwater wetlands that 

have developed in closed basins or kettles. Particularly significant in this area were two glacial 

lakes that persisted in the area for several thousand years after the glacial retreat and now contain 

the extensive wetland systems of Hackensack Meadowlands and Passaic Meadows (Great 

Swamp/Troy Meadows). The complex geologic history of the metropolitan region results in a 

wide range of aquatic and terrestrial habitat types available in a relatively small area (USFWS, 

1997). 

In the area surrounding New York Bay, there are 1,538 hectares of salt marsh in New 

York City and 2,034 hectares of tidal wetlands in between New York City and the Troy Dam on 

the Hudson River. These serve as a natural means of flood control and water quality 

improvement (Montalto and Steenhuis, 2004). 

At present, over 30 species in the region are listed as threatened and endangered under 

the ESA, 14 of which were selected for detailed evaluation in this BE (see Section 3.4). 

4.1.2.2 Major Land Uses Near Upper and Lower Bay/New York, NY 

New York is the most populous city in the United States and the center of the New York 

Metropolitan Area, one of the most populous metropolitan areas in the world. In 2010, New 

York City had a population of 8,175,133 in an area of just 305 square miles of land (U.S. Census 

Bureau, March 24, 2011 Press Release). New York City is composed of five boroughs: 

Manhattan, the Bronx, Brooklyn, Queens and Staten Island. Located on one of the world's largest 

natural harbors, New York exerts a significant impact upon global commerce. 

The city's land has been altered substantially by human intervention, with considerable 

land reclamation along the waterfronts since Dutch colonial times. Because so much of the land 

around the New York Bay is developed, open spaces are important to wildlife. Currently, open 

spaces (public parks, playgrounds and nature preserves, cemeteries, amusement areas, beaches, 

stadiums and golf courses) comprise 27% of the lot area in New York City. The New York City 

Park System alone contains more than 10,500 hectares (26,000 acres) and occupies 13 percent of 

the city's total area (NYCDCP, 2010). Although much of this parkland is developed for 

recreation, the park system also includes 2,830 hectares (7,000 acres) of undeveloped forest, tidal 

and freshwater wetlands, and meadows (USFWS, 1997). 
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Figure 4-2. Land Use and Physical Feature Map of Upper and Lower Bay/New York, NY 

RAA 

   
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4.1.2.3 Vessel Populations Present in Upper and Lower Bay/New York, NY 

The Port of New York and New Jersey (Figure 4-2) is the largest oil importing port and 

third largest container port in the nation. Since the 1950s, the New York and Brooklyn 

commercial port has been almost completely eclipsed by the container ship facility at nearby Port 

Newark-Elizabeth Marine Terminal in Newark Bay, which handled the third largest amount of 

shipping of all ports as measured in tonnage in the U.S. in 2004 and is the largest such port on 

the Eastern Seaboard. The New York harbor area in general is still serviced by several cruise 

lines, commuter ferries, and tourist excursion boats (Port of New York and New Jersey, 2012 

and U.S. Department of Transportation, 2011). 

4.1.2.4 Habitat Modification and Restoration Near Upper and Lower Bay/New 

York, NY 

Starting in the 1700s, the New York shoreline began to be significantly modified, 

channels were dredged, and wetlands filled or fragmented due to trade increases, population 

growth, transportation needs and urbanization. Many wetlands were also impaired through 

hydrologic alteration. It is estimated that within the New York/New Jersey Estuary, which 

includes the Upper and Lower New York Bays, 75 percent of wetlands have been lost in the last 

century (Montalto and Steenhuis, 2004). LaGuardia, John F. Kennedy, and Newark International 

Airports were constructed on filled wetlands (USACE, 2009). The Port of New York and New 

Jersey occupy 755 miles of shoreline. These facilities require shoreside support, mooring 

facilities, and adequate channel depth. Of the estimated 90,653 hectares (224,000 acres) of 

freshwater wetlands that existed in New York City prior to the American Revolution, only small 

areas remain. As of 2004, 26.3 hectares of wetlands had been restored in the New York part of 

Long Island Sound (Montalto and Steenhuis, 2004). 

Dredging, dredged material disposal, filling aquatic habitat to create land for port 

improvement or expansion, and degradation of water quality are the most serious port-related 

threats and have been well recognized for their deleterious effects on living marine resources and 

habitats (USFWS, 1997). Bulkheads, piers, and shoreline fill have reduced the near-shore zone 

of shallow, soft-bottom habitats, rocky outcroppings, wetlands, and sand beaches. These areas 

were ideal for fish nurseries. With the replacement of these waters, the quality of spawning and 

nursery areas was reduced (USACE, 2009). 

The tidal waters of the Hudson River have been changed since the 1800s via dredging for 

navigation, shoreline wetland alteration (often for railroad construction), and the construction of 

dams, which restrict water flow and fish movement through the watershed (Daniels et al., 2005). 

Sediment carried from the Hudson River to the New York Bay requires dredging the bay and 

upriver areas to maintain a 29.5 to 36 feet deep shipping channel (Daniels et al., 2005). 

According to Montalto and Steenhuis (2004), no wetlands have been restored along the Hudson 

River. 

Habitat alteration in Upper and Lower New York Bays has led to changes in species 

populations in the estuary. For example, the Eastern oyster’s numbers have declined 

significantly, due to sedimentation smothering the oyster beds, overharvesting, and poor water 

quality (USACE, 2009). 
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4.1.2.5 Water Quality Impairments in Upper and Lower Bay/New York, NY 

A total of six different pollutants were identified in the 2010 New York 303(d) list and an 

additional twelve pollutants were included in the 2010 New Jersey 303(d) list as contributing to 

the impairments within the listed waters of the Upper and Lower New York Bay RAA (Table 

4-4). PCBs and other toxics were the most common causes of impairments. The New York 

303(d) list describes “other toxics” as mercury, dioxins/furans, PAHs, pesticides and other heavy 

metals. Many of the “other toxics” on New York’s 303(d) list are counted as separate parameters 

in the New Jersey 303(d) list. Pathogens, floatable debris, cadmium, nitrogen, chlordane, DDT, 

DDD, DDE, and dissolved oxygen were also noted as causes of impairment (NYSDEC, 2010; 

NJDEP, 2007). 

Table 4-4. Causes for Impairment in Upper and Lower New York Bay RAA – 2010 

Parameter

Upper New 

York Bay 

Lower New 

York Bay 

Kill van 

Kull 

Raritan 

Bay 

Grand 

Total 

NY NJ NY NJ NY NJ NY NJ 

Pathogens 1 1 

Floatables 1 1 

PCBs 1 1 2 1 2 3 2 14 

Other Toxics 1 2 1 3 7 

Cadmium 1 1 3 5 

Total Coliform 1 1 

Enterococcus 1 1 

Dioxins (including 2,3,7,8-

TCDD) 1 1 2 2 6 

Mercury 1 1 1 3 

Chlordane 1 2 2 5 

Dieldrin 1 2 2 5 

Heptachlor Epoxide 1 2 3 

Hexachlorobenzene 1 2 3 

DDT 1 2 2 5 

DDD 1 2 2 5 

DDE 1 2 2 5 

Dissolved Oxygen 2 2 

Benzo(a)pyrene (PAHs) 1 2 2 5 

Cause Unknown 1 2 3 

Source: NYSDEC, 2010. 

The causes for these impairments include combined sewer overflows, toxic/contaminated 

sediment, urban storm runoff, on-site/septic systems (illegal connections), sediment mounds, 

other sanitary discharges, and industrial sources. Other sources are suspected, but not confirmed 

(NYSDEC, 2011). 

New York Bay receives high loadings of nutrients and organic matter that originate 

mainly from sewage treatment plants but also from a variety of other point and nonpoint sources. 
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These loadings result in low dissolved oxygen concentrations in many parts of the Bay. Recently 

there have been significant increases in dissolved oxygen in some of the more degraded areas, 

such as the Upper New York Bay, but there have also been significant decreases in the Lower 

New York Bay. Low dissolved oxygen has acute and chronic effects on various life stages of 

benthic species and limits the use of the area by pelagic species. 

Another water quality problem, low levels of light penetration, results from high 

suspended solids and phytoplankton biomass that can reduce the amount of light reaching the 

bottom to levels below those necessary to support submerged aquatic vegetation, especially 

eelgrass (Zostera marina). A recent attempt to restore eelgrass beds in Raritan Bay failed, 

apparently due to a combination of wave action, turbidity, shading and smothering by sea lettuce, 

fouling of eelgrass blades by invertebrates and epiphytic algae, and nitrate enrichment (USFWS, 

1997). 

4.1.2.6 Historic ANS Introductions and Impacts in Upper and Lower Bay/New 

York, NY 

Many of New York’s plants and animals are non-native. Twenty-one macrophyte species, 

67 fish species, and 4 species of amphibians and reptiles have been introduced to the waters of 

New York (Benson et al., 2004). In a survey done in 2003, the National Estuary Program 

sampled three sites in the New York/New Jersey Estuary. A total of 98 introduced species were 

found in New York City waters. This survey only included the floating dock communities, and 

not other habitats within these waters (Pederson et al., 2005). Some common aquatic nuisance 

species in the New York/New Jersey Harbor are found in Table 4-5. 

Table 4-5. Aquatic Nuisance Species in the New York/New Jersey Harbors 

Aquatic Nuisance Species Type or organism Reason of Concern 

Common reed, 

Phragmite australis 

Aquatic wetland 

plant 

Crowds out native species 

Bartsch shipworm, 

Teredi bartschi 

Mollusk-Bivalve Bore into wooden structures (piers, bulkheads, 

and boat hulls) 

Wood boring gribble, 

Limnoria tripunctata 

Crutacean-Isopod Bore into wooden structures (piers, bulkheads, 

and boat hulls) 

Gizzard shad, 

Dorosoma cepedianum 

Fish Competition for food resources with native 

species 

Channel catfish, 

Ictalurus punctatus 

Fish Competition with native species 

Chinese mitten crab, 

Eriocheir sinensis 

Crustacean-Crab Competition with native blue crab; promote 

erosion an habitat loss with burrowing habits 

Water chestnut, 

Trapa natans 

Aquatic plant Compeition with native species; reduce 

dissolved oxygen levels; creates nearly 

impenetrable mats 

Zebra mussel, 

Dreissena polymorpha 

Mollusk-Bivalve Competition with native species; biofouling 

capabilities; colonize pipe; reduce biomass of 

phytoplankton 

Source: NYSISTF, 2005. 
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4.1.3 Ecosystem Status of Galveston Bay/Houston, TX RAA

Galveston Bay is an estuary located in southeastern Texas, near the Houston-Galveston 

area. It is the largest estuary along the Texas Gulf coast, with a total area of 384,000 acres. In 

this estuary, freshwater from the Trinity and San Jacinto Rivers mix with the Gulf of Mexico. 

Galveston Bay is comprised of four major sub-bays: Galveston, Trinity, East, and West Bays. 

Overall, the bay extends 30 miles north-south and 17 miles east-west (Figure 4-3). 

Galveston Bay contains several ports, including the cities of Houston, Galveston, and 

Texas City. The ports of Houston and Galveston are located adjacent to Galveston Bay on the 

northwest coast of the Gulf of Mexico. The entrance to Galveston Bay passes between Galveston 

Island and Bolivar Peninsula. The Port of Houston is the larger of the two ports. It is situated on 

Buffalo Bayou at the northwest end of a long shipping channel (Houston Ship Channel) that 

begins in the Gulf of Mexico. The shipping channel crosses the western portion of Galveston 

Bay for approximately 22 nautical miles before entering the natural drainage paths of the San 

Jacinto River and Buffalo Bayou. Buffalo Bayou is one of the drainage basins for the City of 

Houston (PHA, 1996). Extensive petrochemical installations, including refineries and storage 

tanks, are located along the Houston Ship Channel from the turning basin to Atkinson Island, and 

at Texas City. In addition to the large industrial facilities, Galveston Bay has several smaller 

bays and harbors that are used for recreational boating (US Navy, 2009). 

The Galveston Bay watershed covers 33,000 square miles of water and land (Figure 4-3). 

Upper Galveston Bay receives the outflow of the San Jacinto River and drainage from Houston 

through the Houston Ship Channel. Trinity Bay receives the outflow from the Trinity River. East 

Bay receives the inflow from Oyster Bayou and runoff from Chambers County. West Bay 

receives runoff from Chocolate Bayou, Mustang Bayou, and other local bayous. 

4.1.3.1 Ecosystem Description of Galveston Bay/Houston, TX 

Habitat types that occur within the nearshore environment of Galveston Bay include 

marshes, mud and sand flats, seagrass beds, oyster reefs, open bay bottoms and open bay water 

(Sage and Gallaway, 2002). These habitats provide critical functions such as primary food 

production and support habitat for invertebrates, fish, birds, and other wildlife. Seagrass 

meadows are the preferred habitat for many juvenile fish and shellfish and provide food for 

threatened and endangered species of sea turtles. 

Galveston Bay is home to a population of more than 162 species of finfish. While some 

species spend their entire life in the Bay, others migrate to the Gulf as newly hatched young until 

maturation. The Bay is also home to many migratory birds for at least part of the year, such as 

brown pelicans, egrets, pelicans, white-faced ibises, bald eagles and piping plovers. 

At present, over 50 species in the region are listed as threatened and endangered under 

the ESA, 13 of which were selected for detailed evaluation in this BE (see Section 3.4). 
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Figure 4-3. Land Use and Physical Feature Map of Galveston Bay/Houston, TX RAA 

   
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4.1.3.2 Major Land Uses Near Galveston Bay/Houston, TX 

Major land uses in and around Galveston Bay include industrial activities, especially 

refining and petro-chemical industries, suburban development, and rural uses including livestock 

grazing and crop production. Growth of the petroleum industry has led to major changes of land 

use in and around Galveston Bay. Industrial activities, especially refining and petro-chemical 

industries, are most prominent in the eastern part of Harris County, near the Houston Ship 

Channel. Highly industrialized areas are located in several municipalities, including Houston, 

Pasadena, Baytown, Deer Park, and La Porte. Galveston County includes the urbanized eastern 

portion of Galveston Island and the industrialized Texas City-La Marque area. Further 

development in Galveston County is limited due to existing development, natural barriers, and 

lack of transportation access. Chambers County has some petrochemical plants near the Harris 

County-border. 

Suburban development exists in Dickinson, League City, and Friendswood in Galveston 

County. Two suburban areas of Brazoria County provide residences for commuters to Houston 

and the major petrochemical complexes. Rural areas include Chambers County, Brazoria 

County, and Liberty County, which is the fastest growing county in the area. Brazoria and 

Chambers Counties have large areas of land set aside for conservation and recreation. 

While the western side of Galveston Bay is urbanized, the lands east of Trinity Bay and 

north of West Bay have more rural uses. Livestock grazing and crop production are the primary 

agricultural land uses. Impacts on the bay from rural land uses include nonpoint pollution 

sources of fecal coliform bacteria from livestock waste and the introduction of nutrients, 

herbicides and pesticides from crop management (Sage and Gallaway, 2002). 

4.1.3.3 Vessel Populations Present in Galveston Bay/Houston, TX 

The Port of Houston (Figure 4-3), the primary harbor in this RAA, is made up of the 

public terminals owned, managed and leased by the Port of Houston Authority, and the 150-plus 

private industrial companies along the 52-mile long Houston Ship Channel (Port of Houston 

Authority, 2012). Each year, more than 200 million tons of cargo move through the Port of 

Houston, carried by more than 7,700 vessels and 150,000 barge calls (Port of Houston Authority, 

2012). As one of the world’s busiest ports, the Port of Houston has played a key role for the City 

of Houston's development as a center of international trade. It is home to a $15 billion 

petrochemical complex, the largest in the nation and second largest in the world. Approximately 

100 steamship lines offer service linking Houston with 1,053 ports in 203 countries (Port of 

Houston Authority, 2012). The ship channel also intersects a very busy barge traffic lane, the 

Gulf Intracoastal Waterway (Port of Houston Authority, 2012). 

4.1.3.4 Habitat Modification and Restoration of Galveston Bay/Houston, TX 

Wetlands and seagrass meadows are two habitats that have been heavily modified in 

Galveston Bay. Causes of wetland losses in the Galveston Bay since the 1950s include land 

subsidence and relative sea-level rise; land use conversion for agricultural, urban, industrial, and 

transportation purposes; dredge-and-fill activities; and isolation projects. While sea-level rise and 

subsidence has resulted in new wetlands being created upland, there has been an overall loss of 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

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wetlands. Draining of wetlands led to the loss of 365,000 acres of wetlands between 1950 and 

1993 (Sage and Gallaway, 2002). While changes in the shoreline causing wetland and bay 

isolation have not directly destroyed wetlands, it has decreased the amount of estuarine wetlands 

in the Bay. The closure of the area near the mouth of the Trinity River, for example, eliminated 

6,000 acres of shallow bay bottom and 10,000 acres of marshland (Ward, 1993). Another source 

of wetland destruction is through dredging. It is estimated that 7,070 acres of marsh land was 

dredged between 1900 and 1990 (Ward, 1993). The Galveston Bay Plan, a comprehensive 

conservation and management plan for the Galveston Bay ecosystem developed as a part of 

EPA’s National Estuary Program, considers the bay’s lost or degraded aquatic habitats as its top 

priority. As of 2000, approximately 1,440 acres of the Galveston Bay Plan’s goal of 8,600 acres 

of wetland restoration has been achieved. 

Seagrass meadows, which serve as nursery, feeding, and sheltering grounds for many 

marine species, have been heavily reduced. Historically, seagrass meadows flourished in the 

Trinity River Delta, along the western shoreline of Galveston Bay from Seabrook to San Leon, 

along the southern shoreline of West Bay, and in Christmas Bay. Seagrass has been reduced to a 

mere 280 acres in Christmas Bay, with some widgeongrass scattered near the Trinity River 

mouth, in Galveston Bay tributaries, and in isolated ponds (Sage and Gallaway, 2002). 

Approximately 80 percent of the Bay’s submerged aquatic vegetation has been lost since the 

1950s (GBEP, 2003). While the factors leading to the disappearance are not entirely understood, 

it is estimated that subsidence, hurricane Cala, decrease in light attenuation, and anthropogenic 

causes are among the contributing factors. Dredging has both a direct and immediate effect on 

seagrass mortality due to burial. In addition, there are indirect losses resulting from the 

disturbance of sediments attributed to lowered light conditions. Dredging may also create a 

hypoxic environment. It has also been suggested that seagrass meadows can also undergo erosion 

as a result of changes in hydrologic conditions occurring from the dredging of navigational 

channels (TPW, 1999). 

State agencies approved a Seagrass Conservation Plan for Texas (SCPT) in 1999. The 

SCPT focuses on regulatory, management, and education goals. Further protection for seagrass 

beds is provided through the CWA Section 401 and 404 permitting process, which emphasizes 

seagrass bed avoidance. Thanks to improved water quality, slowed development in some areas, 

and the ceasing of open bay disposal of dredged material, seagrass restoration is possible. 

Terraces in Galveston Island State Park have been repopulated with a seagrass ecosystem. 

4.1.3.5 Water Quality Impairments in Galveston Bay/Houston, TX 

A total of 10 different pollutants were identified by Texas in 2008 as contributing to the 

impairments within the 303(d) listed waters in the Galveston Bay area (Table 4-6). While fecal 

coliform bacteria, dioxins, and PCBs were the major causes of impairments, sulfate, dissolved 

oxygen, pH, toxic sediment and mercury contamination were also noted as causes (TCEQ, 

2008). The San Jacinto and Trinity Rivers have the most impairments, followed by the Houston 

Ship Channel and Galveston Bay. 
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Table 4-6. Causes for Impairment in Galveston Bay Area – 2008 

Parameter 

Galveston Bay Area Impairments 

Grand 

Total 

Galveston 

Bay 

Trinity 

Bay 

East 

Bay 

West 

Bay 

San 

Jacinto 

River 

Houston 

Ship 

Channel

Trinity 

River 

Bacteria 4 1 1 2 15 9 11 43 

Sulfate 13 13 

Chloride 3 3 

TDS 3 3 

Dioxin 2 11 8 21 

Dissolved 

Oxygen 

 2 7 9 

Mercury 1 1 

PCB 2 10 8 10 30 

pH 2 2 

Sediment 

Bioassay 

 1 1 2 

Grand 

Total 

8 1 1 2 40 26 49 127 

Source: TCEQ, 2008. 

Contaminated stormwater runoff from non-point sources is a significant problem for 

Galveston Bay. As human population and urbanization increases, so does pollution from 

stormwater runoff. Point sources of pollution include sewage leaks, sewage bypasses, and 

sanitary sewer overflows from corroding wastewater collection systems; improperly treated 

discharges from some small utility districts' wastewater treatment plants; and illicit connections 

to storm sewers. The combined point and non-point source pollution problems lead to low 

dissolved oxygen levels due to nutrients, contamination of water by metals and organic 

pollutants, and closure of shellfish harvesting areas due to fecal coliform bacteria contamination 

(GBEP, 2003). 

Eutrophication caused by nutrient enrichment from point and non-point sources promotes 

the deterioration of seagrass meadows, which are a major habitat for many of Galveston Bay’s 

species. Eutrophication can cause the growth of epiphytic and drift microalgae, which inhibit the 

growth of seagrass. Nitrate toxicity can also inhibit seagrass health (TPW, 1999). Seagrass beds 

are critical coastal nursery habitat for estuarine fisheries and wildlife and are a direct food 

sources for fish, birds, and sea turtles. They contribute organic matter to estuarine and marine 

food webs, participate in nutrient cycling processes, and can help stabilize coastal sedimentation 

and erosion processes (TPW, 1999). 

Spills of oil and other materials affect both aesthetics and ecological functions of 

Galveston Bay. The concentration of industry, shipping operations and urban development in the 

watershed increases the risk of spills in the bay. Estuarine debris is concentrated along the bay's 

and tributaries' shorelines, where it accumulates due to the actions of winds, currents, and waves. 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

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There are 21 Superfund sites listed in the Galveston Bay-San Jacinto Watershed. These 

facilities contributed legacy pollutants to the Bay area from industries such as oil and gas 

refining, wood preserving, chemical manufacturing, industrial waste collection and recycling, 

sand mining, dry cleaning, metal casting foundry, and copper and tin smelting. Pollutants from 

these sources include: petrochemicals, wood preservatives, herbicides, organic and inorganic 

sludges, liquids and solids, oils, chromium, copper, lead mercury, nickel, selenium, zinc, PCBs 

and PAHs (USEPA, 2011). 

4.1.3.6 Historic ANS Introductions and Impacts in Galveston Bay/Houston, TX 

Based upon a comparative risk assessment performed for the Galveston Bay Estuary 

Program in 2003 (see Gossett et al., 2004), it is estimated that 145 non-indigenous aquatic 

species and 67 mammals have been introduced to the Galveston Bay area. Of the aquatic species, 

2 are crustacean, 7 are molluscs, 107 are fish, 4 are amphibian, 1 is an aquatic mammal, 3 are 

reptiles, and 21 are plants. As noted in the final report, the Texas Parks and Wildlife Department 

also maintains a list of 33 exotic finfish, seven shellfish, and 11 plants that cannot be imported, 

possessed, sold, or introduced to Texas waters without a permit (Gosset et al., 2004). In addition, 

the Texas Department of Agriculture developed a list of 27 aquatic and terrestrial plants that are 

prohibited in the State of Texas (Gosset et al., 2004). Some of the more common aquatic 

nuisance species found in Galveston Bay are listed in Table 4-7. 

Table 4-7. Aquatic Nuisance Species in the Galveston Bay 

Aquatic Nuisance 

Species Type or organism Reason of Concern 

Nutria, 

Myocastor coypus Mammal Overgrazing of wetland vegetation; 

increase erosion 

Grass carp, 

Ctenopharyngodon 

idella 

Fish Feed on emergent vegetation, destruction 

of habitat 

Blue tilapia, 

Oreochromis aureus Fish 

Competition with native species, consume 

large amounts of vegetation; potential to 

hybridize 

Nile tilapia, 

Oreochromis niloticus Fish 

Competition with native species, consume 

large amounts of vegetation; potential to 

hybridize 

Armored catfish, 

Pterygoplichthys 

multiradiatus 

Fish Increase erosion from burrowing 

activities, competition with native species 

Source: GBEP, 2010. 

The Galveston Bay Estuary Program has listed aquatic nuisance species among their 

priority problems (see Gosset et al., 2004). 

4.1.4 Ecosystem Status of Upper Mississippi River at St. Louis, MO RAA
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The Upper Mississippi River (UMR) is the portion of the Mississippi River upstream of Cairo, 

IL where it is joined by the Ohio River (at River mile 0). From its headwaters at Lake Itasca, 

MN, the UMR flows approximately 1,250 miles to Cairo. The city of St. Louis, MO is located 

along the west side of the UMR in the vicinity of river mile 180 (Figure 4-4), south of the 

confluence with the Missouri River. The areas related to this RAA include this segment of the 

UMR. This is the widest point on the Mississippi River (nearly 1 mile across). The river here 

forms the border between the states of Missouri and Illinois. The Illinois River joins with the 

UMR 23 miles upstream from St. Louis. 

The UMR below St. Louis drains over 189,000 square miles (nearly 121 million acres) of 

land in the upper Midwest and encompasses portions of eight different states. The basin has 

30,700 miles of streams with 12 major tributaries to the UMR, including the Missouri, Illinois, 

Wisconsin, and Iowa Rivers (UMBRA, 2011). Because of the size of its drainage area, the 

Missouri and its tributaries are considered a separate river region, but because the Missouri River 

enters the UMR a few miles above St. Louis, water from the Missouri River also influences 

hydrology, water quality and habitat parameters within this RAA. 

Along the Minnesota-Wisconsin border, the Mississippi River and its floodplain are 

between 1 and 3 miles wide. Further downriver, in the alluvial lowlands south of St. Louis, the 

width of the floodplain is much greater, about 50 miles wide (UMBRA, 2011). The average 

annual discharge on the UMR increases from 9,180 cubic feet per second (cfs) near St. Paul, MN 

to 204,800 cfs at Thebes, IL. From St. Louis to the Ohio River confluence, the Mississippi drops 

in elevation a total of 220 feet over a distance of 180 miles for an average rate of 1.2 feet per 

mile. At its confluence with the Ohio River, the river is 315 feet above sea level. 

4.1.4.1 Ecosystem Description of Upper Mississippi River at St. Louis, MO 

The St. Louis RAA is within what is known as Reach 3 of the UMR. This reach is 

considered “open river”, meaning the reach is downstream from the navigational dams and is 

unimpounded from the Melvin Price Lock and Dam at river mile 200 downstream to the 

confluence with the Ohio River and beyond. The open river of the UMR is unimpounded and 

relatively free-flowing. It is constrained by naturally high banks west of the channel and by flood 

levees east of the channel. In its natural state, the river corridor here was physically complex 

with main and side channels, open and isolated channels, islands and deep pools, erosional and 

depositional areas, and backwaters and floodplains. Across this natural template, the two most 

common substrates supporting benthic fauna were fine substrates such as gravel, sand, silt, or 

clay and plant material such as tree trunks, branches, roots, and aquatic macrophytes (Battle et 

al., 2007). Anthropogenic activities modified the physical structure of the channel here and 

throughout most of the UMR. Installment of dams created lakes and widened the channel in 

some locations while flood-control levees and dredging narrowed the channel and isolated the 

floodplain in other locations. Sediments were also redistributed by dams and dredging, and by 

lateral wing dikes (a.k.a., wing dams) that redirect flow toward the navigation channel and 

increased lateral sediment deposition. The riverbanks, which were formerly clay, silt and snags 

are now covered with erosion protection materials such as limestone rocks or articulated concrete 

mattresses. Woody debris is now scarce or absent in the main channel (Battle et al., 2007). The 

river at this location now contains almost no aquatic vegetation, a high proportion of the water is 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

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Figure 4-4. Land Use and Physical Feature Map of UMR at St. Louis, MO RAA 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

4-24

in channel habitats, and 82 percent of the floodplain is located behind agricultural levees (USGS, 

2011). 

The UMR near Reach 3 supports at least 164 fish species from 29 families (Janvrin et al., 

2010). Sixty-four of those fish species are considered common to abundant in at least one pool or 

river reach. In addition to the fish species, the river supports 30 species of freshwater unionid 

mussels. Nearly 300 species of birds migrate through the river valley in spring and fall. This 

“Mississippi Flyway” is used by more than 40 percent of the migratory waterfowl traversing the 

U.S. At present, over 30 species in the region are listed as threatened and endangered under the 

ESA, 8 of which were selected for detailed evaluation in this BE (see Section 3.4). 

4.1.4.2 Major Land Uses Near Upper Mississippi River at St. Louis, MO 

Over two-thirds of the land in the UMR region is used for agricultural production. 

However, urban areas are expanding at a rate of 80,000 acres each year, generally spreading out 

over adjacent farmland (USACE, 2011). Land use changes have been significant in the region 

over the past 200 years. Much of the presettlement forest vegetation was converted to other land 

uses as land was drained, protected from flooding, or cleared to provide for agricultural 

production (MMRP, 2009). Table 4-8 outlines both the major land uses and recent land use 

changes in Reach 3. Overall, the past two decades have seen the losses in agricultural land uses 

offset by other uses: forest, wetland, and urban/suburban development, and sediment 

accumulation. Conservation programs have also had an impact over the past twenty years in 

shaping land use patterns. For example, the percentage of agricultural land cover in Reach 3 has 

decreased by 8%, while forested cover has increased by 3%, marsh 2%, and grass and forbs 

approximately 1% (see Table 4-8; net land cover change 1989 to 2000). 

Table 4-8. Area of Land Use Categories within Upper Mississippi 

River Reach 3 

Land Cover Type Acres in 2000 

Net Land Cover Change 

1989 to 2000 (acres) 

Agriculture 81,015 -9,475 

Grasses/Forbs 3,160 +820 

Forest 14,278 +3,703 

Wetlands/Marsh 1,921 +1,901 

Sand/Mud 1,648 +1,290 

Water 10,480 -697 

Developed 1,845 +1,330 

Unknown 995 - 

Total 115,342 - 

Source: MMRP, 2009. 

Approximately 850 miles of the UMR, extending from Minneapolis-St. Paul to the Ohio 

River, is commercially navigable. On the northern 670 miles, this is made possible by a series of 

29 locks and dams, most built in the 1930s, which create a “stairway” of water. In addition, the 

river is dredged to maintain a minimum main channel depth of 9 feet (UMBRA, 2011). In 2000, 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

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barges transported 122 million tons of commodities on the Upper Mississippi River, over half of 

which was grain for world export (UMBRA, 2011). 

Recreational boating visits to the UMR region exceeded 11 million trips in 2000, more 

than the number of annual visits to most national parks, including Yellowstone (UMBRA, 2011). 

There are approximately 500 boat access points and marinas along the UMR between the 

headwaters in Minnesota and the confluence with the Ohio River in southern Illinois. 

Over 7 billion gallons of water are withdrawn from surface water sources each day in the 

60 counties that border the navigable UMR. Over 80 percent of this water is used as cooling 

water for energy production and thus returned to rivers and streams. There are 29 power plants 

that use water from the 1,300 mile long UMR. From St. Cloud, MN in the north to Cape 

Girardeau, MO in the south, the UMR provides water to 23 public water suppliers serving a 

combined population of approximately 2.8 million people (UMBRA, 2011). Approximately 278 

facilities discharge wastewater to the UMR, including industrial facilities and municipal sewage 

treatment plants. 

4.1.4.3 Vessel Populations Present in Upper Mississippi River at St. Louis, MO 

The Port of Metropolitan St. Louis (PMSL) (Figure 4-4) is located on the Mississippi 

River between river mile 171.9 and 191.2 AOR (Above Ohio River), and represents 19.3 miles 

of riverbank at the heart of the Inland Waterway (Missouri Port Authorities, 2005). It handles 

more than 32 million tons of freight each year and is a major shipper of grain, coal, petroleum 

products, scrap metals, aggregates, and chemicals (Missouri Port Authorities, 2005). PMSL is 

the second largest inland port by trip-ton miles and third largest by tonnage (Missouri Port 

Authorities, 2005). It has over 130 piers, wharves, docks, fleeting, and other facilities with 16 

public terminals (Missouri Port Authorities, 2005). 

4.1.4.4 Habitat Modification and Restoration in Upper Mississippi River at St. 

Louis, MO 

Generally, both the quantity and quality of aquatic habitat(s) in the majority of pools on 

the UMR are diminishing (Janvrin et al., 2010). These changes are due to the inevitable aging 

(i.e., sedimentation) of the manmade navigation pools and the environmental impacts associated 

with the numerous human uses of the system. Navigation related activities, flooding regimes, 

sedimentation, and land and recreational use have major effects on the river's ecosystem. The 

resulting physical changes impact the abundance, distribution and diversity of all aquatic 

inhabitants including fish (Janvrin et al., 2010). 

Sedimentation has been identified as one of the largest problems facing the Mississippi 

River (Janvrin et al., 2010). Sediment input occurs primarily through non-point source pollution 

attributable to agricultural and urban land use practices. The improvements to commercial 

navigation (including the construction of the 29 navigation dams and other human activities) 

have increased sedimentation in the system, diminishing the quantity and quality of riverine 

habitat. Pooled areas of the UMR, especially backwaters, are most susceptible to sedimentation. 

It is estimated that sediments are accumulating at an average of one inch per year in UMR 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

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backwaters. Thus Mississippi River backwaters, which are the most productive habitat for fish 

and wildlife, may be lost within 50 to 100 years. 

Both natural forces and anthropogenic activities are responsible for the erosion and 

sedimentation problems impacting the UMR System. Sedimentation degrades habitat by 

destroying fish spawning areas, decreasing light penetration to aquatic plants, and filling in 

shallow areas. Fine sediment accumulating in backwaters, low-flow areas, and isolated side 

channels has already caused significant habitat loss (USACE, 2004). 

Habitat restoration projects have been implementing measures to restore and preserve 

high value fish and wildlife habitat areas. These projects typically involve the use of dredging to 

remove sediment from selected backwater and side channels to restore flow and/or provide deep 

water habitat; levee construction to keep silt-laden water out of prime habitat areas or to control 

water levels; and/or island construction to reduce the effects of wind fetch and waves (USACE, 

2004). 

4.1.4.5 Water Quality Impairments in Upper Mississippi River at St. Louis, MO 

Three pollutants, E. coli, lead and zinc, were identified in the proposed 2012 Missouri 

303(d) list1

. Eight pollutants were included in the 2010 Illinois 303(d) list as contributing to the 

impairments of the Mississippi River: mercury (10 times), PCB (10 times), iron (1 time), TSS (1 

time), pH (1 time), manganese (8 times), fecal coliform (5 times), and TDS (1 time). 

The tributaries that drain into the Upper Mississippi differ in their physical and chemical 

characteristics and have distinct effects on the water quality of the river (USGS, 1999). 

Concentrations of suspended sediments and nutrients in each of the major tributaries are 

summarized in 

Table 4‐9. The Missouri River is by far the largest tributary to the UMR and greatly alters 

the Mississippi River downstream of St. Louis. The Missouri River drainage area is more than 

double and its flow is about two-thirds that of the UMR above St. Louis (USGS, 1999). It also 

carries a suspended sediment load more than twice that of the UMR (Meade, 1995 in USGS, 

1999) but a relatively low nitrogen concentration (Antweiler et al., 1995 in USGS, 1999). 

Table 4-9. Approximate Concentration (mg/L) of Contaminants near the Mouths of Select 

Upper Mississippi River Tributaries – 1993 to 1996 

Tributary or location 

Suspended 

solids 

(mg/L) 

Total 

nitrogen 

(mg/L) 

Nitrate+nitrite 

nitrogen 

(mg/L) 

Total 

phosphorus

(mg/L) 

Mississippi River above Lake Pepin 40 3 2.0 0.2 

Cannon River, MN 40 4 4.0 0.2 

Chippewa River, WI 20 2 0.7 0.1 

Black River, WI 10 2 0.8 0.2 

                                                           

1

 Note: the Mississippi River was not identified in the 2010 Missouri 303(d) list. 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

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Table 4-9. Approximate Concentration (mg/L) of Contaminants near the Mouths of Select 

Upper Mississippi River Tributaries – 1993 to 1996 

Tributary or location 

Suspended 

solids 

(mg/L) 

Total 

nitrogen 

(mg/L) 

Nitrate+nitrite 

nitrogen 

(mg/L) 

Total 

phosphorus

(mg/L) 

Wisconsin River, WI 20 2 0.6 0.2 

Makquoketa River, IA 200 7 6.0 0.4 

Wapsipinicon River, IA 200 5 4.0 0.3 

Illinois River, IL 80 5 4.0 0.3 

Missouri, River, MO 300 3 1.0 0.3 

Headwaters Diversion, MO 40 1 0.5 0.2 

Mississippi River near Cape 

Girardeau, MO 

200 3 2.0 0.4 

Source: USGS, 1999. 

In reaches of the river upstream of St. Louis, dissolved oxygen concentrations, 

particularly in the main channel, are close to saturation (defined as the maximum concentration 

in equilibrium with the atmosphere). In the main channel below the Missouri River confluence, 

dissolved oxygen concentrations are much lower, although still higher than the 5 mg/L level 

generally considered adequate for most aquatic biota (USGS, 1999). 

Water and sediments in the UMR contain organic and inorganic contaminants that have 

originated from agricultural, industrial, municipal, and residential sources (Meade, 1995). These 

contaminants include heavy metals (such as cadmium, lead, and mercury), pesticides, 

(herbicides, insecticides, and fungicides), synthetic organic compounds including PCBs, and 

numerous other chemicals (Meade, 1995). Bottom sediments in extensive reaches of the UMR 

are contaminated with cadmium, copper, chromium, lead, mercury, zinc, and PCBs (USGS, 

1999). 

Fish tissue contaminant data were also summarized by USEPA Region 5 in 2002. PCB 

levels in fish appeared to be highest in upper reaches of the Mississippi River, while levels of 

chlordane, a pesticide that was manufactured between 1948 and 1988 and commonly used for the 

control of termites and corn crop pests, was found to be highest in the lower portion of the UMR 

(USEPA, 2002). As was noted for PCBs, there appeared to be a reduction in chlordane 

contaminations in carp fillets over the period 1980 to 1999 that probably reflects chlordane use 

restrictions and decreased inputs. 

Two Superfund sites are located within the immediate area of the Mississippi River near 

St. Louis, both in the village of Sauget near Cahokia, IL. These sites were waste disposal areas 

and landfills including old lagoons (USEPA, 2010). A variety of industrial and municipal wastes 

and contaminated soil are present in the closed landfills. Contaminants include a variety of 

volative and semi-volatile organic compounds such as chlorobenzene and 1,4-dichlorobenzene; 

herbicides such as pentachlorophenol; PCBs, and metals (USEPA, 2010). 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

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4.1.4.6 Historic ANS Introductions and Impacts in Upper Mississippi River at St. 

Louis, MO 

One of the first known introductions of ANS to the UMR dates to before 1883 when 

common carp were introduced (Rasmussen and Pitlo, 2004). More recently, several additional 

species of Asian carp have been introduced into the UMR (Rasmussen and Pitlo, 2004), 

including grass, bighead, silver and black carp. All these species have either been introduced 

intentionally or accidentally (via non-vessel vectors), and all have expanded their numbers and 

range. Asian carp species are capable of growing to a very large size (up to 110 pounds), and 

they compete for food at some trophic levels with native fishes. According to the Long-Term 

Resource Monitoring Program (LTRMP) fish collections, these species presently account for an 

annual proportion of native to non-native biomass of approximately 23 to 68 percent of the catch, 

with the common carp contributing the majority (72-98 percent) (Johnson and Hagerty, 2008). 

Though LTRMP data from 1993-2004 indicates that common carp have been declining in the 

upper pools, it also indicates that silver and bighead carp numbers have increased in the lower 

pools and are moving upstream (Johnson and Hagerty, 2008). 

One of the most recent and devastating ANS introductions is the zebra mussel. It is 

believed that zebra mussels were transported by and released from ocean-going ship ballast and 

introduced into the Great Lakes in 1988. By the early 1990’s, they were established in all the 

Great Lakes, transported down the Illinois River and spread throughout the UMR (Rasmussen 

and Pitlo, 2004). Their populations rapidly exploded, and their ability to attach to hard substrate 

has caused millions of dollars’ worth of damage and destruction to other aquatic fauna and their 

habitat. The zebra mussels’ presence and distribution in the Mississippi River Basin alone covers 

approximately 1.2 million square miles representing about 17 percent of the continental U.S. 

(Rasmussen and Pitlo, 2004). 

4.1.5 Ecosystem Status of St. Louis River Estuary/Duluth, MN RAA

The mouth of the St. Louis River is a harbor and freshwater estuary, approximately 

12,000 acres large, characterized by numerous backwater areas, bays and islands (MPCA and 

WDNR, 1992). It is nestled between the cities of Superior, WI and Duluth, MN on the 

southwestern shore of Lake Superior. The St. Louis River Estuary (SLRE) is comprised of three 

major bays: St. Louis Bay, Superior Bay and Allouez Bay, which are protected from the wave 

action of Lake Superior by a baymouth sand bar (known locally as Minnesota Point and 

Wisconsin Point) (See Figure 4-5). 

The SLRE was created when the level of Lake Superior rose following the retreat of the 

glaciers. The rising waters gradually drowned the mouth of the St. Louis River along with its 

lower tributaries. The SLRE is fed by the St. Louis River and the Nemadji River. The St. Louis 

River is the second largest tributary to Lake Superior, with an annual discharge of 2,331 cubic 

feet per second. The watershed consists of 3,634 square miles in northeastern Minnesota and 263 

square miles in northwestern Wisconsin. It flows through various counties, the largest being St. 

Louis County in Minnesota (Figure 4-5). The lower 23 miles of the St. Louis River forms the 

state border between Minnesota and Wisconsin. 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

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In 1987, the International Joint Commission, an advisory commission on U.S-Canadian 

border water issues, designated the lower St. Louis River as one of the 43 Great Lakes Areas of 

Concern (AOCs) because of concerns over environmental quality in the area. The St. Louis River 

System AOC is the area being addressed by the St. Louis River System Remedial Action Plan 

(RAP) and the Lower St. Louis River Habitat Plan. While system-wide in its approach, the St. 

Louis River AOC focuses primarily on the 39 miles of the St. Louis River below Cloquet, MN 

and the entire Nemadji River watershed. This area is also the main area of focus for the purposes 

of this BE. 

Figure 4-5. Land Use and Physical Feature Map of St. Louis River Estuary/Duluth, MN 

RAA 

   
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4.1.5.1 Ecosystem Description of St. Louis River Estuary/Duluth, MN 

The circulation of water in the SLRE is impacted by seiches2 from Lake Superior as well 

as flow from the St. Louis River. The seiches act like a tidal force, reversing the circulation of 

water throughout the SLRE, and mixing water from Lake Superior with water from the lower St. 

Louis River. 

There is a wide variety of habitat types in the St. Louis River watershed, as identified in 

the Lower St. Louis River Habitat Plan and described in Table 4-10. 

Table 4-10. St. Louis River Habitat Plan Habitat Type Descriptions 

Habitat 

Types 

Physical 

Characteristics Ecological Characteristics 

Ecological 

Condition / 

Health 

Large 

Riverine 

Reach 

High water velocity. 

Riffle-pool run structure. 

No seiche effect. 

Little emergent of submergent 

vegetation. Prime spawning habitat 

for walleye, lake sturgeon, and other 

fish needing high water velocity. 

Fairly good 

Upper 

Estuarine 

(Undredged) 

River 

Channel 

Upper extent of seiche 

effect. Formerly 

dredged. Some 

hydrological 

modification. 

Rich in fish species. Home to high 

number of native mussels. 

Important wintering habitat for fish. 

Fair to good 

Lower 

Estuarine 

(Dredged 

Channel) 

Dredged regularly (to 27 

feet). Disturbed deepwater. 

Fish wintering habitat. Feeding area 

for fish-eating birds. 

Poor 

Upper 

Estuary Flats 

Unmodified shoreline. 

Low water velocity. 

Lake fluctuation is 

highly influential. 

Support submergent and emergent 

marshes. Support high abundance of 

forage fish, panfish and waterfowl. 

Fair 

Sheltered 

Bays 

Pulse-stable community 

(sediment and water 

movement from seiches).

Highest quality wetlands (extensive 

areas of submergent and emergent 

vegetation). Highest diversity of 

plant and animal species. Spawning 

areas for fish. Provide resources to 

waterfowl and wading birds. 

Supports wild rice. 

Varies upon 

location 

                                                           

2

 A seiche is the back and forth movement of water in a lake that results in the fluctuation of water levels in the 

waterbody. Weather fronts and wind drive the seiches in Lake Superior which have a period of 7.9 hours (Stortz and 

Sydor, 1980). 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

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Table 4-10. St. Louis River Habitat Plan Habitat Type Descriptions 

Habitat 

Types 

Physical 

Characteristics Ecological Characteristics 

Ecological 

Condition / 

Health 

ClayInfluenced 

River Mouths 

Long, narrow drowned 

river mouths. Siech and 

tributary influenced. 

Steep, erodible, 

shoreline. High turbidity. 

Limited emergent and submergent 

vegetation. High fish species 

diversity but low abundance. 

Fair to poor 

IndustriallyInfluenced 

Bays 

Four to five feet deep. 

Highest influence by 

lake fluctuations. 

Contains industrial 

debris and contaminated 

sediments. 

Varying occurrences of emergent 

and submergent vegetation. 

Very poor 

Industrial 

Slips 

Regular ship movement. 

Frequently disturbed and 

turbid water. Sandy, 

scoured silty sediment. 

Little vegetation. Used by fish and 

wildlife despite human activities. 

Poor 

Lower 

Estuary 

(Industrial 

Harbor) Flats 

Heavily altered by 

industrial and 

commercial activity. 

Modified shoreline. 

Seiche effect prevalent. 

Little vegetation remains. Native 

mussels present. 

Poor 

ClayInfluenced 

Bay 

Shallow water. Protected 

bay with little water 

exchange. Surface runoff dominated tributaries 

empty into it. 

Abundant emergent and submergent 

vegetation. High quality habitat for 

fish and waterfowl. Mudflats 

present. Fish spawning area. 

Fair to good 

ClayInfluenced 

Tributaries 

1st or 2nd order streams. 

Medium to low gradient. 

Flow through clay 

deposits. Altered by 

ditches, wetland draining 

and other hydrological 

modification. 

Provide habitat for fish. Varies 

BedrockInfluenced 

Tributaries 

1st or 2nd order streams. 

Medium to low gradient. 

Flow over bedrock. 

Altered by ditches, 

wetland draining and 

other hydrological 

modification. 

Provide habitat for fish. Varies 

Source: SLRCAC, 2002. 
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 Although some of the habitats described above have been highly altered by human 

impacts, all areas of open water and wetland habitat in the lower St. Louis River are important 

because of the variety of fish and bird species that utilize each type, depending on the individual 

species and its preferences. Approximately 45 native fish species have been documented in the 

St. Louis River Estuary, including fish-eating species such as yellow perch, white bass, muskie, 

walleye, and northern pike, and prey species including emerald shiner, spottail shiner, blacknose 

dace, and fathead minnow. Over 230 species of birds have been documented in the estuary, too. 

This area is both an important breeding area and a critical migratory stopover location. Common 

terns and other colonial nesting birds use sandy beaches and other sparsely vegetated areas in the 

estuary. Piping plovers once nested on the beaches as well, but they are not known to have 

nested in the Lower St. Louis River area since 1985. A wide range of species nest in the 

emergent marshes, including sedge wren, marsh wren, Virginia rail, and sora rail, although 

several marsh-nesting species appear to have disappeared from the estuary over the last 30 or so 

years. Black tern colonies were historically present in the marshes, but they are not known to 

have nested there in recent years. The estuary supports a rich variety of plants, insects, mollusks, 

crustaceans, fish, and other food sources for birds. 

Wild rice (Zizania aquatica), a vital food resource for migratory waterfowl, is also 

present in wetland plant communities of the SLRE. Although the species is not rare, it has 

experienced long-term declines in abundance in most wetlands where it occurs, and it has 

disappeared from some wetlands altogether. 

At present, over 10 species in the region are listed as threatened and endangered under 

the ESA, only one of which was selected for detailed evaluation in this BE (see Section 3.4). 

4.1.5.2 Major Land Uses Near St. Louis River Estuary/Duluth, MN 

The SLRE is characterized as having wilderness-like areas in its upper reaches while the 

lower estuary is comprised of urban development, an industrial harbor, and a major port. 

According to the 2001 National Land Cover Dataset, the watershed is dominated (65 percent) by 

forests (Table 4-11). 

Table 4-11. Major Land Uses of the SLRE 

Land Use Type Percentage Cover 

Forest 65 

Wetland 11 

Agriculture 9 

Open Water & Open Space 8 

Urban 2 

Suburban 3 

Grassland 2 

Barren <1 

Source: WDNR, 2010. 
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4.1.5.3 Vessel Populations Present in St. Louis River Estuary/Duluth, MN 

Portions of the SLRE serve as the Duluth-Superior Harbor (Figure 4-5), the largest harbor 

and international port on the Great Lakes (SLRCAC, 2002). Approximately 1,100 vessels enter 

the Duluth-Superior Harbor each year, transporting 40 million metric tons of material. Principal 

cargoes include iron ore (40 %), coal (40 %), and grain (10 %) (SLRCAC, 2002). 

4.1.5.4 Habitat Modification and Restoration of St. Louis River Estuary/Duluth, MN 

Human activities in the estuary from the last two hundred years have had a significant 

negative impact on fish and wildlife habitat. Historical habitat losses in the Lower St. Louis 

River include the elimination of much of the Great Lakes coastal wetland complexes and 

estuarine aquatic habitats, which were filled to create land for various developments in the 

estuary or dredged for shipping. The St. Louis River System Remedial Action Plan Stage One 

(MPCA and WDNR, 1992) summarizes these losses, stating that approximately 3,000 acres of 

marsh and open water were filled in the lower estuary and roughly 4,000 acres of river bottom 

dredged. This left 5,000 acres which have not been drastically altered, mostly in the upper 

estuary (MIC, 1985). 

These losses represent roughly 60 percent of the total area of the SLRE (DeVore, 1978). 

Dredging had significant effects on both the shoreline and the riverbed. Since dredging began in 

the late 1800s, over 69,500,000 cubic yards of clay and mud mixed with sand have been dredged 

from the river bottom and used as fill to create docks, to replenish eroded areas on Minnesota 

and Wisconsin Points, and to form new islands (SLRCAC, 2002). Although ongoing 

maintenance dredging and industrial and commercial activities still result in changes to the river, 

the major dredging and shoreline reconstruction activities took place within a relatively short 

period of time, between 1870 and 1920. The harbor had 17 miles of shipping channels excavated 

to a standard depth of 20 feet, and by 1960, most channels had been dredged to a depth of 27 feet 

(a very significant change to this once-shallow freshwater estuary). 

Future or proposed commercial, industrial, and residential development projects have the 

potential to cause further losses of Great Lakes coastal wetlands and estuarine aquatic habitats, 

as well as inland wetlands. Forested habitats have also been lost to development and other land 

use changes. The development of the Duluth-Superior metropolitan area resulted in the loss of 

spruce-fir forests, northern conifer-hardwood forests, and white pine-red pine forests. The loss of 

the unique dune pine forests on Minnesota and Wisconsin Points is also significant; those forests 

and associated communities will likely not be replaced, nor are they represented elsewhere in the 

region. 

The four most critical sources of stress to the Lower St. Louis River AOC ecosystem 

cited in the 2002 Habitat Plan include: 

 Residential, commercial, and industrial development within the watershed and 

immediate harbor area result in the direct loss of upland and wetland habitat, 

increased erosion and sedimentation, degradation of water quality, and the 

introduction and spread of ANS. 
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 Commercial shipping results in the need for dredging and filling, thereby contributing 

to direct loss of habitat; shipping also contributes to increased erosion as well as the 

introduction and spread of many ANS. 

 Contaminated sediments from a variety of historical industrial and commercial 

sources expose native species to toxins that may increase mortality and decrease 

reproduction. 

 Forest management practices contribute to increased peak flows, which result in 

increased erosion and sedimentation and degraded water quality. 

4.1.5.5 Water Quality Impairments in St. Louis River Estuary/Duluth, MN 

The Wisconsin Department of Natural Resources identified six impaired waterbodies 

(Table 4-12) within the SLRE AOC in their proposed 2010 303(d) list to USEPA (WDNR, 

2011b). All of these impairments are categorized as 5A water/pollutant combinations, meaning 

they require development of total maximum daily loads (TMDLs). 

Table 4-12. Wisconsin 303(d) list for the St. Louis River Area of Concern 

Water 

Body 

Pollutant(s) Impairment(s) Source(s) 

Lake 

Superior 

E. coli; Mercury; PCBs Recreational 

Restrictions - 

Pathogens; 

Contaminated Fish 

Tissue 

Contaminated Sediments; 

Atmospheric Deposition - 

Toxics; Other Factors 

Superior 

Bay 

Foam/Flocs/Scum/ Oil 

Slicks; PAHs; 

Unspecified Metals 

Chronic Aquatic 

Toxicity 

Contaminated Sediments 

Crawford 

Creek 

Creosote; PAHs Chronic Aquatic 

Toxicity 

Contaminated Sediments; 

Industrial Point Source 

Discharge 

Nemadji 

River 

Sediment/Total 

Suspended Solids 

Degraded Habitat Non-Point Source 

Newton 

Creek 

Foam/Flocs/Scum/ Oil 

Slicks; PAHs; 

Unspecified Metals 

Chronic Aquatic 

Toxicity 

Contaminated Sediments, 

Petroleum/natural Gas 

Production Activities 

(Permitted) 

Saint 

Louis 

River 

PCBs; 2,3,7,8-

Tetrachlorodibenzopdioxin; 

Dieldrin; PAHs; 

DDT; Unspecified 

Metals; Mercury; 

Lead 

Contaminated Fish 

Tissue; 

Chronic Aquatic 

Toxicity; Contaminated

Sediment 

Contaminated Sediments, 

Source Unknown, 

Atmospheric 

Deposition - Toxics, 

Historic Point Sources 

- Legacy Pollutants 

Source: WDNR, 2011b. 
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The Minnesota Pollution Control Agency identified 8 impaired waterbodies (Table 4-13) 

within the St. Louis River AOC estuary in their draft 2010 303(d) list (MPCA, 2011). While the 

list does not include the sources of the pollutants, they are most likely similar to those listed in 

Table 4-12 for Wisconsin. 

Table 4-13. Minnesota 303(d) List for the St. Louis River Area of Concern 

Water Body Pollutant(s) Impairment(s) 

St. Louis Bay 

DDT; Dieldrin; Dioxin (including 2,3,7,8-

TCDD); Mercury (water column and fish 

tissue); PCB (water column & fish tissue); 

Toxaphene; Fecal Coliform 

Aquatic 

consumption; 

Aquatic recreation

St. Louis River (Fond 

du Lac Dam to St. 

Louis Bay) 

DDT; Dieldrin; Mercury (water column 

and fish tissue); PCB (water column & 

fish tissue) 

Aquatic 

consumption 

Thomson Reservoir Mercury (fish tissue); PCB (fish tissue) Aquatic 

consumption 

Chub (Lake or 

Reservoir) Mercury (fish tissue) Aquatic consumption 

Sand (Lake or 

Reservoir) Mercury (fish tissue) Aquatic consumption 

Nemadji River Turbidity Aquatic life 

Deer Creek Turbidity Aquatic life 

Rock Creek Turbidity Aquatic life 

Miller Creek Chloride; Lack of coldwater assemblage; 

Water temperature Aquatic life 

Source: MPCA, 2011. 

Water quality in the SLRE continues to improve, due to pollution prevention efforts, 

better pre-treatment programs and new stormwater management activities, including efforts to 

control storm-related "inflow and infiltration," which has caused sewage bypasses in Duluth, 

resulting in untreated sewage flowing directly into Lake Superior. However, the estuary still 

suffers from legacy contaminated sediments in several locations. Industrial activity such as steel 

mills, oil refining, coal tar and coking operations, paper mills and other wood products 

manufacturing, as well as the shipping of coal, grain, iron ore, and taconite, have significantly 

contributed to the contamination of the SLRE. Two Superfund sites, U.S. Steel and St. Louis 

River-Interlake Duluth Tar sites, on the Minnesota shore of the river are polluted with toxic 

organic chemicals and metals. Toxic contamination has impaired several uses in the St. Louis 

River and its watershed, including degradation of bottom-feeding invertebrate communities, 

increased incidence of fish tumors and other abnormalities, fish consumption advisories, and 

restrictions on dredging. Some sediment-derived contaminants also appear to be carried by the 

water column to Lake Superior. 

With the recent increased emphasis on Great Lakes AOCs at a federal level, the states 

have been able to pursue several projects to clean up contaminated sediments and to evaluate the 

extent of contaminants in bottom sediments. Specific projects include the Hog Island Inlet and 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

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Newton Creek remediation project (with nearly 55,000 tons of contaminated sediment being 

removed). 

The St. Louis River Watershed TMDL Partnership is currently developing a TMDL for 

mercury. The TMDL process is designed to improve impaired waters such as the St. Louis River, 

where all facilities with discharge permits are operating within their permitted limits, yet 

pollutant levels exceed state standards. The TMDL process will complement mercury reduction 

work that is already taking place in the watershed. 

4.1.5.6 Historic ANS Introduction and Impacts in St. Louis River Estuary/Duluth, 

MN 

ANS are a potential threat to the Lower St. Louis River ecosystem. By competing for 

habitat, food, and breeding areas, ANS can cause localized eradication of native species, impact 

fisheries, spread disease, and reduce species biodiversity. Since the early 1800s, over 160 nonnative species have been introduced into the Great Lakes (Ricciardi and MacIsaac, 2000), many 

through unmanaged or untreated ballast water discharges. At least 31 species currently found in 

Lake Superior are non-native, including 16 fish, 5 invertebrates, 4 pathogens and parasites, and 6 

wetland and aquatic plants (Mills et al., 1993). These non-native species have been introduced 

via several pathways, and over 60 percent have arrived since 1960, following the opening of the 

St. Lawrence Seaway. The Duluth-Superior Harbor is an international port with annual traffic of 

approximately 1,100 vessels. Therefore, if ballast water were to remain unmanaged, the Harbor 

would remain a likely site for additional introductions of ANS. 

Table 4-14 lists several ANS that are currently found in or around the estuary and have 

known or likely impacts on the native biota of the Lower St. Louis River. 

Table 4-14. Aquatic Nuisance Species Currently in the St. Louis River Estuary 

Aquatic Nuisance 

Species 

Type or organism Reason of Concern 

Zebra mussel, 

Dreissena 

polymorpha 

Mollusk-Bivalve 

Competition with native species; biofouling 

capabilities; colonize pipe; reduce biomass 

of phytoplankton; habitat destruction 

Eurasian ruffe, 

Gymnocephalus 

cernuus 

Fish Competition with native species; predation 

of native species eggs 

Round goby, 

Neogobius 

melanostomus 

Fish Competition with native species; predation 

on native species eggs 

Rainbow smelt, 

Osmerus morax Fish Predation on native species eggs 

Sea lamprey, 

Petromyzon marinus Fish 

Parasitic to native fish species; virtually 

eliminated lake trout populations in Lake 

Superior 
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Table 4-14. Aquatic Nuisance Species Currently in the St. Louis River Estuary 

Aquatic Nuisance 

Species 

Type or organism Reason of Concern 

Rusty crayfish, 

Orconectes rusticus Crustacean-Crayfish 

Competition with native species; predation 

on native species eggs; decrease abundance 

and diversity of aquatic plants 

Purple loosestrife, 

Lythrum salicaria 

Aquatic wetland 

plant 

Crowds out native species; decrease food 

resources for other animal species 

Common reed, 

Phragmite australis

Aquatic wetland 

plant 

Crowds out native species; decrease food 

resources for other animal species 

Reed canarygrass, 

Phalarus 

arundinacea 

Aquatic wetland 

plant 

Crowds out native species; decrease food 

resources for other animal species 

Hybrid cattail, 

Typha x glauca 

Aquatic wetland 

plant 

Crowds out native species; decrease food 

resources for other animal species 

Source: MDNR, Aquatic Invasive Species in Minnesota website: 

(http://www.dnr.state.mn.us/invasives/index_aquatic.html) 

4.1.6 Ecosystem Status of San Francisco Bay Estuary/San Francisco, CA RAA

The San Francisco Bay Estuary (SFBE) (Figure 4-6), at the confluence of the Sacramento and 

San Joaquin Rivers in central California, is renowned for its natural beauty, international 

commerce, recreation, and sports fishing. Along with being home to seven million people, the 

nine-county San Francisco Bay Area (SFBA) is home to a diversity of wildlife and habitats, 

world-class recreational opportunities, and working farms and ranches. The SFBE is 1,600 

square miles large, drains 40% of California’s land, and connects to the Pacific Ocean at the 

Golden Gate Bridge (SCCC, 2010). The estuary’s edges are a mix of development for 

transportation, housing, and industry that also includes tidal wetlands and mudflats used by 

endangered species and migratory birds. The estuary has been greatly modified by 150 years of 

intensifying human activity (Nichols et al., 1986). 

The Estuary’s watershed covers about 60,000 square miles (SFEP, 2010). This is the 

largest estuary in western North America and a biological resource of tremendous importance, 

providing critical winter feeding for over a million migratory birds, a productive nursery for 

juvenile fish and crabs, and a full-time home for many other plants and animals. Roughly half of 

California’s surface water supply falls as rain or snow within this region, and about half of that is 

diverted for use by farms, factories or households (SFEP, 2010). The San Joaquin-Sacramento 

River Delta, the upstream section of the Estuary, is a thousand-square-mile triangle of diked and 

drained wetland. Before it was diked and drained, the Delta gathered in the fresh waters of the 

Sacramento, San Joaquin, Mokelumne, and Cosumnes rivers, and moved them all downstream, 

through a complex array of tidally influenced channels, into salty San Francisco Bay. 

The numerous rivers that flow into the Sacramento and San Joaquin Rivers and form the 

Delta are the estuary’s primary source of freshwater. The Sacramento River is the largest river 

and watershed system in California. This 27,000-square-mile basin drains the eastern slopes of 

the Coast Range, Mount Shasta, the western slopes of the southernmost region of the Cascades, 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

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and the northern portion of the Sierra Nevada (SRWP, 2010). The Sacramento River carries 31% 

of the state’s total surface water runoff. Primary tributaries to the Sacramento River are the Pit, 

Feather, and American Rivers (SRWP, 2010). The San Joaquin River is about 300 miles long 

beginning in the Sierra Nevada mountain range on California’s eastern border (SJRGA, 2006). 

The river runs down the western slope of the Sierra and flows roughly northwest through the 

Central Valley, to where it meets the Sacramento River at the Sacramento-San Joaquin Delta, a 

1,000-square-mile maze of channels and islands (SJRGA, 2006). In addition, numerous creeks 

and rivers surround the San Francisco Bay estuary, such as Alameda Creek, San Francisquito 

Creek, Coyote Creek, the Guadalupe River, Suisun Creek, the Napa River, and Sonoma Creek 

that are of importance for steelhead trout and other wildlife that depend on riparian habitat 

(SFEP, 2010). 

As the mixing zone where fresh and salt water meet moves up and down the SFBE, 

salinity increases and decreases in Bay segments (SFEP, 2010). San Francisco Bay includes four 

smaller bays. Suisun Bay and the diked wetlands of Suisun Marsh are the least salty of these, just 

downstream of the Delta. Saltier San Pablo Bay is west of Carquinez Strait (see Figure 4-6). The 

saltiest basins are the Central Bay, which connects with the ocean through the Golden Gate 

Bridge, and the South Bay, a large, shallow lobe extending south of Central Bay to Dumbarton 

Narrows (SFEP, 2010). 

The San Francisco Estuary Partnership was established by the State of California and the 

EPA to better protect and restore the San Francisco Bay Delta Estuary (SFEP, 2011). The 

Partnership created and oversees implementation of the Comprehensive Conservation and 

Management Plan, completed in 1993, that describes over 200 actions aimed at improving the 

Estuary’s chemical, physical, and biological health. The project area for the Partnership includes 

San Francisco Bay, the tributary watersheds of the Bay from the Golden Gate up to the Delta, 

and the Delta (SFEP, 2011). The San Francisco Estuary Partnership Study Area is also the main 

area of focus for the purposes of this BE. 

4.1.6.1 Ecosystem Description of San Francisco Bay Estuary San Francisco, CA 

The physical habitats of the SFBE include tidal marshes and tidal flats (baylands), 

estuarine open water, and subtidal habitat (SFEP, 2011). Estuarine open water habitat in the 

estuary is formed by the fresh water inflow from the Sacramento and San Joaquin rivers, creating 

a mixing zone with the Pacific Ocean of brackish (low salinity) habitat. The amount of 

freshwater inflow determines where the this zone will occur from year to year in the estuary (i.e., 

when inflows are high, brackish water habitat is found further downstream, closer to the Golden 

Gate bridge) (SFEP, 2011). 

Baylands are the tidal flat and marshes that are subject to inundation from the Bay’s tides. 

Whereas tidal marshes support abundant vegetation, tidal flats are intertidal areas that lack rooted 

vegetation (SFEP, 2011). Tidal flats and tidal marshes form in relatively calm areas along the 

margins of the Bay where fine sediments carried by the Bay currents and waves tend to 

accumulate. Both of these habitat areas provide critical ecological and hydrological functions 

contributing to the overall health of the estuary. Tidal flats support dense colonies of shellfish 

and other invertebrates which serve as a source of food fish, birds and other wildlife (SFEP, 
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Figure 4-6. Land Use and Physical Feature Map of San Francisco Bay Estuary, CA RAA 

   
2013 VGP and sVGP BE Section 4- Environmental Baseline 

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2011). Tidal marshes support many species of fish and waterfowl, while also acting as filters that 

trap fine sediment and break down some of the contaminants that enter the estuary (SFEP, 2011). 

The ability to trap and store fine sediment reduces the need for dredging of ports and shipping 

channels. 

Subtidal habitat is a critical piece of the estuary ecosystem and includes all of the 

submerged area beneath the bay’s water surface: mud, shell, sand, rocks, artificial structures, 

shellfish beds, eelgrass beds, macroalgal beds, and the water column above the bay bottom 

(SCC, 2010). This unique habitat provides diverse three-dimensional structures, including: sand 

waves more than three meters high; eelgrass and shellfish beds that act as ecosystem engineers 

and provide substrate for reproduction and food resources for species such as herring and 

salmon; rocky outcrops that offer substrate for seaweeds and invertebrates; and mixed sediments 

in shoals and channel banks that are used by a variety of other species (SCC, 2010). Many 

shellfish, invertebrates, fish, marine mammals, diving ducks, and other wildlife feed, rest, hide, 

and reproduce in subtidal areas. Large populations of shorebirds feed on the estuary’s subtidal 

and intertidal mudflats. The subtidal habitat also supports a variety of indirect ecosystem 

services, including nutrient cycling, climate regulation, flood protection, water quality 

maintenance, and sediment transport (SCC, 2010). 

Herring and Dungeness crab, among many other species of fish and shellfish, rear in the 

estuary, while sturgeon, salmon, and steelhead feed and rest in the bay during their migrations to 

and from its rivers and streams and the ocean (SCC, 2010). The vast open water, sloughs, rivers, 

streams, and baylands in the SFBE host millions of migratory birds every year as they move up 

and down the Pacific Flyway, as well as provide habitat for numerous resident water and shore 

birds. The bay also provides important habitat for marine mammals, shellfish, and aquatic 

invertebrates (SCC, 2010). At present, over 149 species in the region are listed as threatened and 

endangered under the ESA, 58 of which were selected for detailed evaluation in this BE (see 

Section 3.4). 

4.1.6.2 Major Land Uses Near San Francisco Bay Estuary/San Francisco, CA 

The SFBA consists of nine counties, 101 cities, and comprises 7,000 square miles, with 

7.1 million residents. It represents the fifth most populous metropolitan area in the United States 

(FOCUS, 2012). The SFBA is projected to increase to 8 million residents in 2030 (CADF, 2012). 

The SFBA has a land area of 4.4 million acres (excluding bay waters and large lakes). In 2000, 

approximately 16 percent (or about 700,000 acres) of the region's total acreage was developed 

for urban use. Of those developed acres, 61 percent are residential and 42 percent are nonresidential (e.g., employment, government, schools, and major infrastructure) (FOCUS, 2012). 

San Francisco County is the most urbanized county in the SFBA with 82 percent of its 

land developed, while Napa is the most rural county with less than 4 percent of its land area 

developed. The remaining counties have developed land areas ranging from 7 percent to 28 

percent (FOCUS, 2012). Like many large urban centers, the SFBA will continue to grow over 

the foreseeable future. Over the next 25 years, most people will live in San Francisco, the East 

Bay (including eastern Contra Costa County), and the South Bay (in both San Mateo and Santa 

Clara counties) (FOCUS, 2012). 
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State, local, and federal water projects divert fresh water from the rivers flowing into the 

SFBE to serve drinking water to some 30 million people and irrigate four million acres of 

agricultural land (SFEP, 2011). At the same time, SFBA residents rely on the Bay to absorb over 

500 million gallons of treated wastewater each day, as well as vast quantities of urban 

floodwaters during rainstorms. Each year, two million tons of sand for construction and 65,000 

cubic yards of oyster shell deposits for calcium supplements are mined from the Bay. The Bay 

has many recreational opportunities for residents, and supports a $34 billion maritime industry 

including a commercial fishery for Pacific herring (SFEP, 2011). 

Aggressive efforts by local land trusts and open-space acquisition agencies have helped 

bring the current total of permanently protected lands to about 1 million acres (almost 25 percent 

of the region's total acreage) (Greenbelt Alliance, 2012). The acreage already protected ranges 

from 5,831 acres in San Francisco to about 172,000 acres in Marin. 

4.1.6.3 Vessel Populations Present in San Francisco Bay Estuary/San Francisco, CA 

The Port of San Francisco (Figure 4-6) manages the 7.5 miles of San Francisco Bay 

shoreline stretching from Hyde Street Pier in the north to India Basin in the south (Port of San 

Francisco, 2012). The Port hosts 60-80 cruise ship calls and 200,000 passengers annually (Port 

of San Francisco, 2012). All types of cargo cross the terminals at the Port of San Francisco with 

approximately 1,000,000 metric revenue tons of total cargo from only 37 vessel calls in 2011 

(Port of San Francisco, 2012). The RAA also includes a second independent seaport of the Port 

of Oakland, located directly across San Francisco Bay from the Port of San Francisco. The Port 

of Oakland, with 7 container terminals covering 771 acres, is the fifth busiest container port in 

the nation, receiving 1,973 vessels in 2010 (Port of Oakland, 2011). 

4.1.6.4 Habitat Modification and Restoration in San Francisco Bay Estuary/San 

Francisco, CA 

In the 1830s, San Francisco Bay covered almost 700 square miles, with almost a million 

fish passing through the estuary and 69 million acres of water flowing down from mountain 

headwaters toward the sea (San Francisco Estuary Project, 1997). But in 1848, the Gold Rush 

began, and hydraulic mining plugged the rivers and bays with more than one billion cubic yards 

of sediments. Over time, farmers and city builders filled up more than 750 square miles of tidal 

marsh, and engineers built dams to block and store the rush of water from the mountains into the 

SFBE, as well as massive pumps and canals to convey this water to cities and farms throughout 

the state (San Francisco Estuary Project, 1997). 

More than 95% of the historic tidal marshes have been leveed and filled, leading to 

subsequent losses in fish and wildlife habitat. Harbor and channel dredging has altered water 

flow patterns and salinity. Beginning in the early 1900s, water development for flood control, 

agricultural and municipal uses altered the volume and timing of freshwater inflows (San 

Francisco Estuary Project, 1997). For a number of the estuary’s fish and invertebrate species, it 

was estimated that a 10 km upstream shift in the location of the mixing zone in the spring around 

this time period corresponded to a two- to five-fold decrease in abundance or survival. The 

freshwater inflow can vary significantly from year to year from natural conditions. However 

since the 1940s, large dams on the estuary’s tributary rivers have captured and stored the 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

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majority of fresh water, resulting in less input to the estuary. Analyses of the spring time mixing 

zone location benchmarks reveal a steady decline in open water habitat (SFEP, 2011). Diversions 

to cities, farms and other uses remove an average of more than half the water that would 

otherwise reach the SFBE. Though about 70% of the state's available water supply is carried by 

Northern California rivers and streams, 80% of the present demand for water comes from the San 

Joaquin Valley and south of the Tehachapi Mountains (the Los Angeles area) (San Francisco 

Estuary Project, 1997). 

Additionally, the amount and quality of the fresh water entering into the SFBE from 

nearby watersheds can have a significant impact on the overall health of the system. The local 

watersheds surrounding San Francisco Bay have been dramatically altered due to development, 

water diversions, and urban runoff. This has caused erosion and sedimentation and negatively 

impacted water quality, hydrology, and habitat for fish and other aquatic species (SCCC, 2010). 

There have been numerous projects that have improved the conditions in the SFBE over 

the last 20 to 25 years, including, but not limited to: wetland restoration and enhancement; the 

development of an integrated Regional Water Management Plan; and the implementation of 

several invasive species prevention control and eradication programs. One particularly 

noteworthy program is the Long Term Management Strategy for the Placement of Dredged 

Material. Until the late 1980s most of the dredged material from shipping lanes was disposed of 

in one of three areas in the Bay (SFEP, 2011). As a result of this management plan and 

subsequent actions, there has been a significant decrease in the amount of in-Bay disposal of 

dredged material with nearly 20 million cubic yards of dredged material being reused for 

beneficial purposes. Currently the program is on track to meet its long-term goal to reduce inBay disposal to 1.25 million cubic yards of material per year (SFEP, 2011). 

4.1.6.5 Water Quality Impairments in San Francisco Bay Estuary/San Francisco, 

CA 

The California San Francisco Bay Regional Water Quality Control Board 2010 303(d) 

list includes more than 270 listings in 88 water bodies. Table 4-15 provides a subset of these 

listings for the bays and major tributaries of the Estuary (CEPA, 2012). 

TMDL projects are currently being developed to address more than 160 of the 270 303(d) 

listings; however, one TMDL may address multiple listings. For example, the Diazinon/Pesticide 

Toxicity TMDL for urban creeks addressed more than 30 impaired creeks or creek segments. 

Table 4-16 below highlights the primary sources of the subset of pollutants listed above. (Note: 

while some sources may be specific for a waterbody segment, most pollutants have similar 

sources across waterbodies.) 

 
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Table 4-15. California San Francisco Bay Regional Water Quality Control Board 2010 

303(d) List 

Pollutant 

Carquinez Strait (5657 acres) Central Basin, San Francisco (part of SF Bay, Lower) (40 acres) Coyote Creek (Santa Clara Co.) (55 miles) Guadalupe River (18 miles) Napa River (65 miles) Oakland Inner Harbor (Fruitvale Site, part of SF Bay, Lower) (0.93 acres)Oakland Inner Harbor (Pacific Dry-dock Yard 1 Site, part of SF Bay, Lower) (1.8 acres)Richardson Bay (2439 acres) Sacramento San Joaquin Delta (41736 acres) San Francisco Bay, Central (70992 acres) San Francisco Bay, Lower (92274 acres) San Francisco Bay, South (9204 acres) San Francisquito Creek (12 miles) San Leandro Bay (part of SF Bay, Lower) (588 acres) San Pablo Bay (68349 acres) Sonoma Creek (30 miles) Suisun Bay (25335 acres) Suisun Creek (19 miles) Suisun Marsh Wetlands (66339 acres) Tomales Bay (8545 acres) 

Chlordane a a a a a a a a a a a a 

Chlordane (sediment) a a 

Coliform Bacteria a 

Copper (sediment) a 

DDT (Dichlorodiphenyltrichloroethane) a a a a a a a a a a a 

Diazinon b b b 

Dieldrin a a a a a a a a a a a a 

Dieldrin (sediment) a 

Dioxin compounds (including 

2,3,7,8-TCDD) a a a a a a a a a a a a 

Furan Compounds a a a a a a a a a a a a 

Invasive Species a a a a a a a a a a a a 

Lead (sediment) a a 

Low Dissolved Oxygen a 

Mercury b b a b b b b b b b b b b a a 

Mercury (sediment) b b b 

Nutrients a a a a 

Organic Enrichment/Low 

Dissolved Oxygen a 

PAHs (Polycyclic Aromatic 

Hydrocarbons) (sediment) a a a 

Pathogens b b b 
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Table 4-15. California San Francisco Bay Regional Water Quality Control Board 2010 

303(d) List 

Pollutant 

Carquinez Strait (5657 acres) Central Basin, San Francisco (part of SF Bay, Lower) (40 acres) Coyote Creek (Santa Clara Co.) (55 miles) Guadalupe River (18 miles) Napa River (65 miles) Oakland Inner Harbor (Fruitvale Site, part of SF Bay, Lower) (0.93 acres)Oakland Inner Harbor (Pacific Dry-dock Yard 1 Site, part of SF Bay, Lower) (1.8 acres)Richardson Bay (2439 acres) Sacramento San Joaquin Delta (41736 acres) San Francisco Bay, Central (70992 acres) San Francisco Bay, Lower (92274 acres) San Francisco Bay, South (9204 acres) San Francisquito Creek (12 miles) San Leandro Bay (part of SF Bay, Lower) (588 acres) San Pablo Bay (68349 acres) Sonoma Creek (30 miles) Suisun Bay (25335 acres) Suisun Creek (19 miles) Suisun Marsh Wetlands (66339 acres) Tomales Bay (8545 acres) 

PCBs (Polychlorinated 

biphenyls) a a a a a a a a a a a 

PCBs (Polychlorinated 

biphenyls) (dioxin-like) a a a a a a a a a a a 

PCBs (Polychlorinated 

biphenyls) (sediment) a a 

Pesticides (sediment) a 

Salinity/TDS/Chlorides a 

Sedimentation/Siltation a a a a 

Sediment Toxicity a 

Selenium a a a a a a a a 

Temperature, water a 

Trash a a a a a 

Zinc (sediment) a a 

Source: CEPA, 2012 

a) A water segment where standards are not met and a TMDL is required, but not yet completed, for at least one of 

the pollutants being listed for this segment. 

b) A water segment where standards are not met and a TMDL is required, and has been completed and approved 

by US EPA for the pollutants listed for this segment. 
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Table 4-16. Sources of Select Pollutants of Concern in SFBE 

Pollutant Listed Pollutant Sources 

Chlordane Nonpoint Source 

Chlordane (sediment) Source Unknown 

Coliform Bacteria Boat Discharges/Vessel Wastes; Septage Disposal; Urban 

Runoff/Storm Sewers 

Copper (sediment) Source Unknown 

DDT (Dichlorodiphenyltrichloroethane) Nonpoint Source 

Diazinon Urban Runoff/Storm Sewers 

Dieldrin Nonpoint Source; Unknown Nonpoint Source 

Dieldrin (sediment) Source Unknown 

Dioxin compounds (including 2,3,7,8-TCDD) Atmospheric Deposition 

Furan Compounds Atmospheric Deposition 

Invasive Species Ballast Water 

Lead (sediment) Source Unknown 

Low Dissolved Oxygen Habitat Modification; Removal of Riparian Vegetation; 

Streambank Modification/Destabilization 

Mercury 

Atmospheric Deposition; Flow Regulation/Modification; 

Industrial Point Sources; Mine Tailings; Minor Industrial 

Point Source; Municipal Point Sources; Natural Sources; 

Nonpoint Source; Resource Extraction; Urban 

Runoff/Storm Sewers 

Mercury (sediment) Point Source; Source Unknown; Urban Runoff/Storm 

Sewers 

Nutrients 

Agriculture; Construction/Land Development; Flow 

Regulation/Modification; Land Development; Urban 

Runoff/Storm Sewers 

Organic Enrichment/Low Dissolved Oxygen Flow Regulation/Modification; Urban Runoff/Storm 

Sewers 

PAHs (Polycyclic Aromatic Hydrocarbons) 

(sediment) 

Point Source; Source Unknown; Urban Runoff/Storm 

Sewers 

Pathogens 

Construction/Land Development; Intensive Animal 

Feeding Operations; Land Development; Septage Disposal; 

Urban Runoff/Storm Sewers 

PCBs (Polychlorinated biphenyls) Unknown Nonpoint Source; Unknown Point Source 

PCBs (Polychlorinated biphenyls) (dioxin-like) Unknown Nonpoint Source 

PCBs (Polychlorinated biphenyls) (sediment) Source Unknown 

Salinity/TDS/Chlorides Flow Regulation/Modification; Urban Runoff/Storm 

Sewers 

Sediment Toxicity Source Unknown 

Sedimentation/Siltation 

Construction/Land Development; Land Development; 

Nonpoint Source; Upstream Impoundment; Urban 

Runoff/Storm Sewers 

Selenium Industrial Point Sources 

Selenium Domestic Use of Ground Water; Exotic Species; Industrial 

Point Sources; Natural Sources 
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Table 4-16. Sources of Select Pollutants of Concern in SFBE 

Pollutant Listed Pollutant Sources 

Temperature, water Habitat Modification; Removal of Riparian Vegetation 

Trash Illegal dumping; Urban Runoff/Storm Sewers 

Zinc (sediment) Source Unknown 

Source: CEPA, 2012. 

Toxic contaminant inputs from industrial, agricultural, and commercial activities are a 

high-priority concern in the changing SFBE. San Francisco Bay receives effluents from 46 

publicly owned wastewater-treatment plants and 65 large industrial discharges, which, together 

with a significant contribution of chemicals applied for agricultural purposes, combine to add as 

much as 40,000 tons of at least 65 contaminants into the SFBE each year. Many of these 

contaminants are toxic to plants or animals or pose threats to human health (Cloern et al., 1997). 

4.1.6.6 Historic ANS Introductions and Impacts in San Francisco Bay Estuary/San 

Francisco, CA 

ANS have been introduced in California waters via transoceanic ships, aquaculture, the 

aquarium trade, the bait industry, recreational activities, biological research, environmental 

restoration projects, and freshwater deliveries up and down the state (SCDFG, 2008). However, 

in the San Francisco Bay Estuary, unmanaged or untreated ballast water from international ships 

has been cited as the principal cause of invasive species (SCDFG, 2008). Statewide, researchers 

have now identified 607 introduced, or likely introduced, species in California’s estuarine 

waters. In San Francisco Bay, the rate at which ANS were becoming established increased from 

an average of one new species every 55 weeks prior to 1960, to one new species every 14 weeks 

between 1961 and 1995 (Cohen and Carlton, 1998). 

More than 250 non-native species have been found in the San Francisco Bay-Delta 

Estuary (SCDFG, 2008). Some of the most problematic ANS that have become established in 

California include the European green crab (Carcinus maenas), the Chinese mitten crab 

(Eriocheir sinensis), the Asian overbite clam (Corbula amurensis), as well as a plethora of 

aquatic plants with origins as far away as Brazil and Japan (SCFDG, 2008). 

These ANS cause major impacts: disrupting agriculture, shipping, water delivery, 

recreational and commercial fishing; undermining levees, docks and environmental restoration 

activities; impeding navigation and enjoyment of the state’s waterways; and damaging native 

habitats and the species that depend on them (SCDFG, 2008). 

4.1.7 Ecosystem Status of Biscayne Bay, Miami, FL RAA

Biscayne Bay (Figure 4-7) is a shallow subtropical estuary located along the southeastern 

coast of the state of Florida. The bay is a nationally significant marine ecosystem, comprised of 

mangrove shorelines, scattered islands, living coral reefs, and a large diversity of marine, 

terrestrial, and amphibious life (Bialczak et al., 2000). It is home to ten federally-listed 

endangered species, including the West Indian Manatee and the American Crocodile, and four 
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threatened species, such as the American Alligator. As a source of recreation, Biscayne Bay 

serves an impressive 16 percent of the State’s population, annually. Known as an excellent place 

to boat, sail, fish, snorkel, and dive, it is also home to Biscayne National Park, the largest marine 

Figure 4-7. Land Use and Physical Feature Map of Miami/Biscayne Bay, FL RAA 
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park in the National Park System; Oleta River and Bill Baggs State Parks; and the Biscayne Bay 

Aquatic Preserve. Also located in the bay is one of the world’s largest passenger and commercial 

ports, as well as important sport and commercial fisheries. 

Biscayne Bay consists of three sections: north, central, and south (BBRRCT, 2001). 

North Bay extends from Dumfoundling Bay south to the Rickenbacker Causeway. Two new 

inlets created after 1926 through south and north Miami Beach altered circulation in northern 

Biscayne Bay (BBRRCT, 2001). Central Biscayne Bay extends from the Rickenbacker 

Causeway south to Black Point, and is bordered mainly by Coral Gables and Coconut Grove on 

the west and Key Biscayne on the east. Much of this part of the bay is included as part of 

Biscayne National Park. It is the most well mixed area, achieving direct ocean exchange. South 

Biscayne Bay is usually subdivided into two parts. The south bay section extends from Black 

Point to Mangrove Point, and encompasses the lower portion of Biscayne National Park 

(BBRRCT, 2001). It is bordered by an intact mangrove shoreline that forms a narrow band along 

much of its coast. The extreme south bay stretches from Mangrove Point to Jewfish Creek, and 

includes Card Sound and Barnes Sound (BBRRCT, 2001). For the purposes of this analysis all 

three sections of the Biscayne Bay are part of this RAA (see Figure 4-7). 

The South Miami-Dade Watershed is located in the southeastern portion of Miami-Dade 

County between two national treasures: Biscayne National Park and Everglades National Park 

(Keith and Schnars, 2007). It is for this reason that this area is recognized as one of the most 

critical watersheds in Florida. The watershed, which comprises 371 square miles (237,440 acres), 

plays a vital role in the health of Biscayne Bay as well as providing for the urban and agriculture 

needs of the surrounding area (Keith and Schnars, 2007). It includes eight municipalities and 20 

percent of the total land area in Miami-Dade County. 

4.1.7.1 Ecosystem Description of Biscayne Bay/Miami, FL 

Prior to development, the Biscayne Bay watershed was a diverse landscape of freshwater 

marshes, sloughs, pine flatwoods and rockland, hardwood hammocks, scrub, sandhills, and 

coastal mangrove swamps (Keith and Schnars, 2007). In the Everglades, a 60-mile wide "river of 

grass" slowly moved water primarily from Lake Okeechobee to Florida Bay. A coastal ridge 

within the watershed area kept most of the water west, but some water flowed through rivers, 

sloughs, and groundwater and discharged to the east into Biscayne Bay. The natural system's 

storage capacity was so enormous that rainfall from wet seasons and from wet years provided 

ample supply to maintain the ecosystem through dry seasons and dry years. The extent and 

natural flows of the water limited the development of the region (Keith and Schnars, 2007). 

Biscayne Bay is a subtropical estuary that is 55 miles long and varies from 1 to 10 miles 

in width and 1 to 10 feet in depth. In some areas, where dredging has occurred, the depth ranges 

from 30 to 40 feet (FDEP, 2006). Biscayne Bay is a naturally clear-water bay historically 

bounded by mangrove and herbaceous wetlands. Its shallow depths and clear waters lead to 

productivity that is largely benthic-based. The benthic communities both filter particulates and 

stabilize sediments (Alleman et al., 2002). Biscayne Bay provides habitat for all kinds of sea life 

such as: pink shrimp, stone crabs, seagrasses, manatees, dolphins and a variety of wading birds. 

The lush seagrass beds found throughout Biscayne Bay is a major part of the food chain. The 

Florida spiny lobster depends on this environment and shrimp, fish, sea turtles, and manatees 
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also use these productive underwater pastures. Mangroves, with their complex system of prop 

roots, help stabilize the shoreline and provide shelter for animals, birds and marine life. Their 

leaves become a vital part of the food chain when they fall into the water. 

The coastal marine waters off southeast Florida support an extensive reef ecosystem that 

anchors highly diverse biological communities (FDEP, 2006). The reef ecosystems consist of 

distinct habitat types: near shore patch reefs, mid-channel reefs, offshore patch reefs, seagrass 

beds, back reefs/reef flats, bank or transitional reefs, intermediate reefs, deep reefs, outlier reefs, 

and sand/soft-bottom areas (FDEP, 2006). These reefs provide habitat for many ecologically and 

economically significant organisms, including numerous threatened or endangered species. Hard 

corals, soft corals, sponges, fish, and algae, along with a multitude of invertebrate species, make 

up the complex and fragile reef ecosystem. Multiple commercial and recreational fisheries (e.g., 

spiny lobster, grouper, snapper, grunt, and hogfish) are present in the near shore waters (FDEP, 

2006). At present, over 61 species in the region are listed as threatened and endangered under the 

ESA, 28 of which were selected for detailed evaluation in this BE (see Section 3.4). 

4.1.7.2 Major Land Uses Near Biscayne Bay/Miami, FL 

The coastal areas of Broward and Miami-Dade Counties, constituting a band that extends 

from the northern Broward County line to south Miami, remain the most densely developed in 

the Biscayne Bay–Southeast Coast Basins. As coastal areas were built out, development was 

forced to spread eastward and southward. Over the years, drainage improvements made land to 

the west of the coastal ridge suitable for development. Much of the land to the west of the urban 

coastal area is now covered by urban development, which depends on a network of canals to 

make the region habitable (FDEP, 2006). Eastern Broward County and northeastern and eastcentral Miami-Dade County include the most heavily developed urban areas of these counties 

and contain some of the more heavily urbanized areas in the state. According to the 2000 U.S. 

Census, Miami-Dade County had an average population density of 1,157.9 people per square 

mile, and Broward County averaged 1,346.5 people per square mile. Over the 1990–2000 Census 

period, the population of Broward County grew by approximately 29 percent, and Miami-Dade 

County by approximately 16 percent (FDEP, 2006). The major land use (Table 4-17) in the 

South Miami-Dade watershed is the built (urban) environment. 

Table 4-17. Major Land Use of the South Miami-Dade 

Watershed

Land Use Type Percent Cover 

Built Environment 50% 

Other Lands - Agriculture 

(Tree Ornamentals & Row Crops) 21% 

Freshwater Wetlands 

(Freshwater Marsh) 13% 

Coastal Wetlands 

(Coastal Mangrove) 9% 

Transitional Lands 

(Australian Pine-Exotic & Brazilian 

Pepper-Exotic) 

6% 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

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Table 4-17. Major Land Use of the South Miami-Dade 

Watershed

Land Use Type Percent Cover 

Remnant Natural Forest 

(Pine Rockland & Oak Hammock) 1% 

Source: Adapted from Keith and Schnars 2004. Near shore marine 

systems not included. 

Nearly 90 percent of all municipal water supply withdrawals in the basins are from the 

Biscayne aquifer, which also supplies 200 million gallons per day (mgd) for agriculture, 

irrigation, industry, mining, and recreational purposes. Municipal withdrawals in Broward, Dade, 

and Palm Beach Counties have increased 700 percent over 45 years (FDEP, 2006). By the year 

2020, municipal water demands are projected to reach 1,200 mgd and municipal water systems 

will serve 6 million people. Increased withdrawals from the Biscayne aquifer have combined 

with substantial land use changes to affect the balance between fresh and salt water in the ground 

water flow system (FDEP, 2006). Flow induced changes in salt balance may have implications 

on native flora and fauna within the coastal wetland ecosystem (Erwin, 2009). 

Much of the southern bay, despite substantial development in the watershed, has 

relatively pristine habitats, good water quality, and supports significant production of fish and 

shellfish. Changes in freshwater input, however, have altered its estuarine character. In addition, 

vessel traffic, along with canals, rivers, and other factors, has contributed to elevated turbidity 

levels and is causing increasing damage to the benthic communities (BBRRCT, 2001). 

4.1.7.3 Vessel Populations Present in Biscayne Bay/Miami, FL 

The Port of Miami (Figure 4-7), also known as “Cargo Gateway of the Americas”, had 

4.3 million passengers travel through the Port, and more than 7.4 million cargo tons and 850,000 

TEUs (twenty-foot equivalent units) of cargo transited through the harbor in fiscal year 2010 

(Port Miami, 2010). This commercial trade combined with the cruise ship business supported 

approximately 176,000 jobs and had an economic impact in the region of approximately $17 

billion (Port Miami, 2010). The Port of Miami serves approximately 20 shipping lines that call 

on more than 100 countries and 250 ports across the world (Port Miami, 2010). 

4.1.7.4 Habitat Modification and Restoration in Biscayne Bay/Miami, FL 

The Biscayne Bay watershed is contiguous to the Everglades, and receives water from the 

Everglades that flows directly into the bay. Beginning in the late 1800s and early 1900s, 

extensive drainage projects began to make vast areas of land usable for agriculture and housing 

(Keith and Schnars, 2007). By 1927, the Everglades Drainage District had put in place 440 miles 

of canals, levees, locks, and dams. By the 1970s, a massive water management project called the 

Central and Southern Florida Project (CSFP) was completed which resulted in about 1,000 miles 

of levees and canals, 150 gates and other water control structures, and 16 major pump stations 

installed throughout South Florida (Keith and Schnars, 2007). The CSFP was highly successful 

at regulating the water resources for flood protection and water supply, but the natural flows 

through the Everglades, through the coastal ridge, and into Biscayne Bay were substantially 

changed. The coastal areas of Broward and Miami-Dade Counties were the first to be developed 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

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because of the natural coastal ridge, which historically existed as well-drained, habitable land 

(FDEP, 2006). The completion of these projects and extent of urban development has changed 

the natural timing, quantity, quality, and distribution of freshwater into Biscayne Bay and other 

natural areas (Keith and Schnars, 2007). Moreover, agricultural practices and the urbanization of 

the area have contributed to alteration of lands in the watershed. The population of this area is 

expected to increase, which will exacerbate the impacts to the watershed and the resulting threat 

to the vitality of the bay (BBRRCT, 2001). 

The mangrove margins north of Coconut Grove and Key Biscayne (northern Biscayne 

Bay) were largely covered by fill, and bulkheads were constructed in order to develop the 

shoreline. The dredging of areas to supply this fill material left 10-20 foot deep troughs in much 

of northern Biscayne Bay. New dredged islands, port facilities, and six cross-bay causeways 

further segmented northern Biscayne Bay. Construction of infrastructure items such as 

causeways and sewage treatment plants, which empty into the Bay, have resulted in 

approximately 40% of north Biscayne Bay being either too deep or too turbid for benthic 

communities. Nevertheless, some parts of this bay area remain highly productive (BBRRCT, 

2001). 

Over the years, management plans and activities in the Biscayne Bay–Southeast Coast 

Basins have been implemented to eliminate wastewater discharges; reduce the discharges of 

polluted stormwater from urban and agricultural areas; and protect, preserve, and restore 

important ecological areas. Some projects and groups that address water quality and quantity 

problems include the Everglades Construction Project, Comprehensive Everglades Restoration 

Plan, Biscayne Bay Surface Water Improvement and Management Plan, Biscayne Bay 

Partnership Initiative, Biscayne Bay Restoration Coordination Team, South Miami-Dade 

Watershed Study and Plan, and the U.S. Coral Reef Task Force (FDEP, 2006). 

4.1.7.5 Water Quality Impairments in Biscayne Bay/Miami, FL 

Of the 113 water segments in the Biscayne Bay–Southeast Coast Basins, 69 waters are 

impaired for at least one parameter, and a TMDL is required for these waters (FDEP, 2006). To 

identify impaired waters in each of the state’s river basins, the Florida Department of 

Environmental Protection evaluated water quality data using the science-based methodology in 

the Identification of Impaired Surface Waters Rule (IWR) (Rule 62-303, Florida Administrative 

Code [F.A.C.]) (FDEP, 2006). The rule established specific criteria and thresholds for 

impairment, in addition to data sufficiency and data quality requirements. The methodology 

described in the rule is based on a statistical approach designed to provide greater confidence 

that the outcome of the water quality assessment is correct. Table 4-18 lists impaired waters in 

the Biscayne Bay-Southeast Coast Basin verified using this approach. 

Table 4-18. Verified List of Impaired Waters in the Biscayne Bay-Southeast Coast Basin

Waterbody Segment Name (WBID #) Waterbody 

Type Pollutant(s) causing impairment 

ICWW Dade County (3226H) Estuary Fecal Coliforms 

Pompano Canal (3271) Stream Dissolved Oxygen; Nutrients 

C-13 East/Middle River (3274) Estuary Fecal Coliforms; Nutrient (historical chlorophyll) 
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Table 4-18. Verified List of Impaired Waters in the Biscayne Bay-Southeast Coast Basin

Waterbody Segment Name (WBID #) Waterbody 

Type Pollutant(s) causing impairment 

Los Olas Isles Finger Canal System 

(3226G4) Estuary Fecal Coliforms 

North Fork New River (3276A) Estuary Dissolved Oxygen; Fecal Coliforms; Nutrients 

(chlorophyll a); Total coliforms 

South New River Canal (3277A) Estuary Fecal Coliforms; Nutrients (historical chlorophyll); 

Snake Creek Canal East (3283) Stream Fecal Coliforms; Nutrients (historical chlorophyll); 

C-8/Biscayne Canal (3285) Stream Fecal coliforms; Total coliforms 

C-7/Little River (3287) Stream Fecal coliforms; Total coliforms 

C-6/Miami River (3288) Estuary Copper; Fecal coliforms; Total coliforms 

C-6/Miami Canal (3290) Estuary Fecal coliforms 

Coral Gables Canal (3292) Stream Fecal coliforms; Total coliforms 

Upper Arch Creek (3226M2) Stream Fecal coliforms; Total coliforms 

Wagner Creek (3288A) Estuary Dioxin; Fecal coliforms; Total coliforms 

C-6/Lower Miami River (3288B) Estuary Fecal coliforms; Total coliforms 

C-111 Canal (3303) Stream Nutrient (historical chlorophyll) 

Florida Atlantic Coast (8998) Coastal Mercury in Fish 

Source: FDEP 2006. 

There are 113 permitted wastewater treatment facilities in the Biscayne Bay-Southeast 

Coast Basin, 68 of which have federal National Pollution Discharge and Elimination System 

(NPDES) permits for discharge to surface water (FDEP, 2006). Six of the NPDES facilities are 

domestic wastewater treatment plants and there are 19 permitted landfills, 21 brownfield 

redevelopment areas, and five federal Superfund sites (FDEP, 2006). 

According to the Biscayne Bay Partnership Initiative, the most important challenges 

today regarding water and sediment quality are the loss of wetland and seagrass communities due 

to physical and ecological water quality changes. These changes include increased turbidity and 

inputs of dissolved nutrients, trace metals, organic chemicals, and particulates through 

stormwater runoff from agricultural and urban areas, canal discharges, and discharges from 

industrial facilities or vessels (FDEP, 2006). Marinas also can be sources of pollution because of 

the solid waste dumping, fuel and oil pollution, and heavy metals that accumulate in the 

sediments there. In addition, construction and coastal development as well as dredging have put 

stress on the bay. Land use has a significant impact on surface water quality. In many of the 

coastal areas in the region, the infrastructure to convey storm water and sewage is outdated and 

not environmentally protective (FDEP, 2006). Despite these impacts, Biscayne Bay overall 

remains highly productive. It supports extensive seagrass beds and diverse fisheries resources 

(FDEP, 2006). 

4.1.7.6 Historic ANS Introductions and Impacts in Biscayne Bay/Miami, FL 

The U.S. Congress Office of Technology Assessment (1993) reported that the large 

influx of exotic plants entering the U.S. through various routes has set the stage for potential 

escapes and unintentional and intentional releases of ANS. Eighty-five percent of all plant 

shipments into the U.S. passed through the Miami Inspection Station (U.S. Congress Office of 

Technology Assessment, 1993). Florida’s woody ornamental industry, worth $1 billion, 
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continues to import large numbers of plants for the nursery and landscaping trades (U.S. 

Congress Office of Technology Assessment, 1993). Florida’s aquaculture industry is the largest 

in the U.S. The aquarium trade industry was responsible for introducing hydrilla into canals in 

central Florida around 1950 and later into Miami canals (U.S. Congress Office of Technology 

Assessment, 1993). These industries will continue to threaten native ecosystems if import 

regulations are not developed, especially for the importation of potentially invasive plants. 

Without early identification and importation restrictions, the number of invasive species 

introduced into Florida will continue to rise. 

Invasive animal species are a rapidly increasing environmental and economic problem in 

south Florida. Florida has been said to be second only to Hawaii in the severity of the threat 

posed by invasive species. The state is particularly vulnerable to the introduction and spread of 

ANS because of its subtropical climate, numerous major ports of entry, and its plethora of pet, 

aquarium, and ornamental plant industries. Of the known and thriving animal species introduced 

into south Florida, 4 are amphibians, 32 are fish, 12 are birds, 46 are reptiles, 17 are mammals, 

and approximately 79 are invertebrates, according to the South Florida Water Management 

District (SFWMD, 2008; SFERTF 2010). 

Some ANS present include the giant toad (Bufo marinus), Cuban brown treefrog 

(Osteopilus septentrionallis), green iguana (Iguana iguana), monk parakeet (Myiopsitta 

monachus), Burmese python (Python molurus bivittatus), Mayan cichlid (Cichlasoma 

urophthalmus) and feral dog (Canis familiaris). Non-native invasive vegetation species present 

include melaleuca (Melaleuca quinquenervia), Australian pine (Casuarina spp.), and Brazilian 

pepper (Schinus terebinthifolius), among others (Ferriter et al., 2008). The heaviest impacts from 

invasive plant species tend to occur in disturbed areas, such as abandoned farmland and lands in 

the immediate vicinity of roads and berms. These species cause significant ecological harm by 

crowding out and displacing native vegetation upon which native fish and wildlife depend for 

food and shelter (Ferriter et al., 2008). Other negative impacts of ANS can include alteration of 

soil types and soil and water chemistry, alteration of ecosystem functions such as carbon 

sequestration and nutrient cycling, attenuation of gene pools and genetic diversity, reduction of 

native species diversity, and alteration of community composition (Ferriter et al., 2008). 

Additionally, according to Ferriter et al. (2008), most exotic plants provide little or no habitat 

value for native wildlife, yet they can change hydrology and soil composition, degrade water 

quality, and decrease the biodiversity of an entire ecosystem. 
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4.2 FACTORS AFFECTING CURRENT STATUS OF LISTED SPECIES IN RAAS

Table 4-19 summarizes the known major and other threats contributing to the current 

status of each of the subset of 82 unique species (see Table 3-22 in Section 3.4.2) within the 

seven RAAs (and constituent elements3

 in the case of its critical habitat 4) to which the ensuing 

effects analysis applies. As mentioned at the beginning of this section, the risk estimated to this 

subset of species from anticipated exposure to a select set of pollutants (see Section 3.2.3) is used 

to inform determinations for the full list of aquatic and aquatic-dependent species and their 

critical habitats (Appendix E). The information provided in this table is meant to be considered 

in the context of the preceding section on ecosystem status within each RAA, and is used to 

support the effects determinations made in Section 7 of this BE. 

Identifying the primary past and on-going threats to the listed species present within each 

of the RAAs allows for consideration of whether (and how) the most significant threats (i.e., the 

primary reasons a particular species is considered threatened or endangered) may (or may not) be 

related to the Federal permit actions that are the subject of this BE. Furthermore, when viewed in 

the context of the actions under consideration, conclusions may be drawn as to whether the 

issuance of the VGP and sVGP would likely cause or contribute to a change to the threats of any 

of the listed species. 

The known and existing threats to the listed species range from human-created threats 

such as dredging, construction, fishing, and logging to natural threats such as predation, weather, 

disease and hybridization or other genetic threats. Many of the threats are physical in nature, 

such as destruction of habitat, shoreline development, landscape alteration due to mining, and 

erosion, while others are more chemical in nature such as general pollution (of both aquatic and 

terrestrial origin). 

By far the most prevalent threat among the listed species is habitat change. This category 

of threat can occur through activities such as construction and development of shoreline and 

wetland areas, channel dredging and channel alterations, urban and agricultural development, 

and surface mining (gravel, strip, etc.). One or more of these types of activities were listed as a 

threat to 76 of the 82 listed species specifically evaluated in this BE. In fact, the various forms of 

habitat change are listed as a threat 253 times in the table below. Since threatened and 

endangered species often have specific habitat requirements, small changes or relatively small 

                                                           

3

 Per ESA §3(5)(A)(i), 50 CFR §424.12(b), constituent elements are physical and biological features of designated 

or proposed critical habitat essential to the conservation of the species, including, but not limited to: (1) space for 

individual and population growth, and for normal behavior; (2) food, water, air, light, minerals, or other nutritional 

or physiological requirements; (3) cover or shelter; (4) sites for breeding, reproduction, rearing of offspring, 

germination, or seed dispersal; and (5) habitats that are protected from disturbance or are representative of the 

historic geographic and ecological distributions of a species. 

4

 Per ESA §3(5)(A)(i), critical habitat for listed species consists of: (1) the specific areas within the geographical 

area occupied by the species, at the time it is listed in accordance with the provisions of section 4 of the Act, on 

which are found those physical or biological features (constituent elements) (a) essential to the conservation of the 

species and (b) which may require special management considerations or protection; and (2) specific areas outside 

the geographical area occupied by the species at the time it is listed in accordance with the provisions of section 4 of 

the Act, upon a determination by the Secretary that such areas are essential for the conservation of the species. 

Designated critical habitats are described in 50 CFR §17 and 226. 
2013 VGP and sVGP BE Section 4- Environmental Baseline 

4-55

losses to their habitat can have negative impacts. None of the threats in this class are directly 

attributable to discharges incidental to the normal operation of vessels. 

The second most commonly listed threat category is biological and natural threats such as 

weather, competition, predation, disease, invasive species and genetic threats. These threats 

accounted for 137 occurrences in the table below. These types of threats were noted for 67 of the 

82 listed species specifically evaluated in this BE. Many of these threats can result in direct or 

indirect impacts that can occur immediately, or over the course of several generations. 

Introduction of invasive species is largely a result of human activity and many cases are 

attributable to vessel discharges such as unmanaged or untreated ballast water. Some of these 

threats, however, are naturally occurring and may not be directly related to human activity of any 

kind. 

Direct disturbance by humans is the third most commonly listed threat category. Direct 

disturbance by humans was listed as a threat to 59 of the 82 listed species and occurred 123 times 

in Table 4-19. This threat category covers such activities as fishing and hunting, disturbance by 

or collisions with boats or other vehicles, and recreational activities (e.g., beach combing). Direct 

human disturbance has the potential for injury/death to the animal (through collisions, 

entanglement, harvest, etc.) or disturbance of their natural behaviors leading to changes in their 

feeding, nesting, or breeding activities. While some of the threats in this category are directly 

related to the physical movement of watercraft (i.e., vessel traffic), none of them are attributable 

to discharges incidental to the normal operation of vessels. 

Another threat category relevant to the effects analysis of this BE is pollution and other 

related water quality problems, the fourth most commonly listed threat category. While none of 

the known threats in the table below specifically identify pollutants from vessel discharges as a 

concern (i.e., most of the listings are very general such as pollution, contaminants, oil 

contamination, etc.), incidental vessel discharges could potentially contribute to some of the 

threat from pollutants. Various types of pollution were listed as known threats for 47 of the 82 

species in this BE and occurred 74 times in the table below. Pollution can act upon the listed 

species in many ways, including directly causing a decrease in breeding success, increasing 

susceptibility to disease, or inducing sickness and death. 

The threat category noted as primary threat the fewest number of times to the various 

listed species in the RAAs regards changes from such anthropogenic activities as forest removal, 

mowing, livestock grazing, and vegetation encroachment, as well as other significant changes to 

vegetative structure. These threats accounted for 20 occurrences in the table below and were 

listed as primary threat to the status of 19 of the 82 species listed in this BE. Changes in 

vegetation create loss in habitat, such as areas used for foraging or nesting, as well as result in 

increased predation due to the loss of hiding areas. 

Overall, most of the past and on-going threats to the listed species in this BE are directly 

related to habitat destruction and disturbance, non-specific pollutant effects, and other natural 

and anthropogenic activities not specifically related to vessels or vessel discharges. 
2013 VGP and sVGP BE Section 4- 

4-56

Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThShortnose sturgeon, Acipenser brevirostrum 

Upper/Lower New York Bay (New York, NY) Biscayne Bay (Miami, FL) 

No critical habitat 

Major:

• Commercial and re• Bridge construction• Contaminants • Nutrient pollution • Dams • Reduced dissolved • Dredging • Cooling water intak• Alteration of natura• Loss or manipulatioOther threats:

• Introduced species, 

viruses 

North American green sturgeon, Acipenser medirostris 

San Francisco Bay Estuary (San Francisco, CA) 

No critical habitat 

Major:

• Harvest bycatch Other threats:

Modification of spaw

result of logging, aconstruction, and ucoastal watersheds)

Entrainment in water Pollution
2013 VGP and sVGP BE Section 4- 

4-57

Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThGulf sturgeon, Acipenser oxyrinchus desotoi 

Biscayne Bay (Miami, FL) 

(1) abundant food items, such as detritus, aquatic insects, worms, and/or molluscs, within riverine habitats for larval and juvenile life stages and abundant prey items, such as amphipods, lancelets, polychaetes, gastropods, ghost shrimp, isopods, molluscs and/or crustaceans, within estuarine and marine habitats and substrates for subadult and adult life stages; (2) riverine spawning sites with substrates suitable for egg deposition and development, such as limestone outcrops and cut limestone banks, bedrock, large gravel or cobble beds, marl, soapstone, or hard clay; (3) riverine aggregation areas, also referred to as resting, holding, and staging areas, used by adult, subadult, and/or juveniles, generally, but not always, located in holes below normal riverbed depths, believed necessary for minimizing energy expenditures during fresh water residency and possibly for osmoregulatory functions; (4) a flow regime (i.e., the magnitude, frequency, duration, seasonality, and rate-of-change of fresh water discharge over time) necessary for normal behavior, growth, and survival of all life stages in the riverine environment, including migration, breeding site selection, courtship, egg fertilization, resting, and staging, and for maintaining spawning sites in suitable condition for egg attachment, egg sheltering, resting, and larval staging; (5) water quality, including temperature, salinity, pH, hardness, turbidity, oxygen content, and other chemical characteristics, necessary for normal behavior, growth, and viability of all life stages; (6) sediment quality, including texture and other chemical characteristics, necessary for normal behavior, growth, and viability of all life stages; (7) safe and unobstructed migratory pathways necessary for passage within and between riverine, estuarine, and marine habitats (e.g., an unobstructed river or a dammed river that still allows for passage). 

Major:

Overfishing Habitat loss due to wOther threats:

Dredge material dispTree removal Incidental take Aquaculture and intrSlow growth and maPoor water quality Pesticide use Heavy metals Industrial contaminan
2013 VGP and sVGP BE Section 4- 

4-58

Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThStaghorn coral, Acropora cervicornis 

Biscayne Bay (Miami, FL) 

Substrate of suitable quality and availability to support successful larval settlement and recruitment, and reattachment and recruitment of fragments. 

Major:

Thermal events Anchor damage Diseases Other threats:

Hurricanes Predation Bleaching Algae overgrowth Human impacts Sedimentation Salinity and temperat

Elkhorn coral, Acropora palmata 

Biscayne Bay (Miami, FL) 

Substrate of suitable quality and availability to support successful larval settlement and recruitment, and reattachment and recruitment of fragments. 

Major:

Thermal events Hurricanes Diseases Bleaching Predation Other threats:

Sedimentation Salinity and temperat

Sonoma alopercurus, Alopecurus aequalis var. sonomensis 

San Francisco Bay Estuary (San Francisco, CA) 

No critical habitat 

Major:

Habitat destruction/m

urbanization 

Land use changes Alterations in hydrolOther threats:

Global climate chang
2013 VGP and sVGP BE Section 4- 

4-59

Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThSeabeach Amaranth, Amaranthus pumilus 

Upper/Lower New York Bay (New York, NY) 

No critical habitat 

Major:

• Beach stabilization • Beach erosion • Tidal inundation • Beach grooming • Predation by insect• Urban developmenOther threats:

• Off-road vehicles

California tiger salamander, Ambystoma californiense 

San Francisco Bay Estuary (San Francisco, CA) 

(1) standing bodies of fresh water which typically support inundation during winter rains and hold water for a minimum of 12 weeks in a year of average rainfall; (2) upland habitats adjacent and accessible to and from breeding ponds that contain small mammal burrows or other underground habitat; (3) accessible upland dispersal habitat between occupied locations that allow for movement between such sites. 

Major:

Land use patterns and 

events 

Land use changes Conversion and isola

to agriculture and u

Lowering of the grouMortality of juvenile 

vehicles on roads 

Introduction of non-n

mosquitofish, bullfbreeding habitats 

The widespread pois

squirrels and other 

Interbreeding with in

originally brought i
2013 VGP and sVGP BE Section 4- 

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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThCape Sable seaside sparrow, Ammodramus maritimus mirabilis 

Biscayne Bay (Miami, FL) 

(1) calcitic marl soils characteristic of the short-hydroperiod freshwater marl prairies of the southern Everglades with soils that support the unique vegetation community and probably many of the food items upon which sparrows depend; (2) herbaceous vegetation that includes greater than 15 percent combined cover of live and standing dead vegetation of one or more of the following species (when measured across an area of greater than 100 ft2 (9.3 m2)): Muhly grass (Muhlenbergia filipes), Florida little bluestem (Schizachyrium rhizomatum), blacktopped sedge (Schoenus nigricans), and cordgrass (Spartina bakeri), which act as cover and substrate for foraging, nesting, and normal behavior for sparrows during a variety of environmental conditions; (3) large, expansive, contiguous habitat patches with few or sparse woody shrubs or trees with space for population and individual growth; (4) hydrologic regime such that the water depth, as measured from the water surface down to the soil surface, does not exceed 7.9 inches (20 cm) for more than 30 days during the period from March 15 to June 30 at a frequency of more than 2 out of every 10 years. 

Major:

Agriculture Wildfires Hurricanes Hydroperiod alteratioInvasion by brush anIncrease in soil salini

Guadalupe fur seal, Arctocephalus townsendi 

San Francisco Bay Estuary (San Francisco, CA) 

No critical habitat 

Major:

Oil spills and offshorOther threats:

Sonic booms Incidental bycatch an

Finback whale, Balaenoptera physalus 

Galveston Bay (Houston, Texas) Upper/Lower New York Bay (New York, NY) Biscayne Bay (Miami, FL) 

No critical habitat 

Major:

• Boat collisions • Entanglement in fis• Reduced prey abun• Low-frequency noi• Legal and illegal hu• Habitat degradation 
2013 VGP and sVGP BE Section 4- 

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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThSonoma sunshine, Blennosperma bakeri 

San Francisco Bay Estuary (San Francisco, CA) 

No critical habitat 

Major:

• Habitat destruction

fragmentation 

Other threats:

Off-road vehicles Erosion 

Decurrent false aster, Boltonia decurrens 

Mississippi River (St. Louis, MO) No critical habitat 

Major:

• Habitat degradation • Siltation • Intensive agricultur• Marina constructio• Levee construction • Wetland draining 

Marbled murrelet, Brachyramphus marmoratusor Brachyramphus marmoratus marmoratus

Puget Sound (Seattle, WA) San Francisco Bay Estuary (San Francisco, CA) 

(1) individual trees with potential nesting platforms; (2) forested areas within 0.8 kilometers (0.5 miles) of individual trees with potential nesting platforms, and with a canopy height of at least one-half the site-potential tree height. This includes all such forest, regardless of contiguity. 

Major:

• Genetic threats • Disease • Habitat destruction 
2013 VGP and sVGP BE Section 4- 

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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThConservancy fairy shrimp, Branchinecta conservation 

San Francisco Bay Estuary (San Francisco, CA) 

(1) mounds and swales and depressions within a matrix of surrounding uplands that result in complexes of continuously, or intermittently, flowing surface water in the swales connecting pools; (2) depressional features including isolated vernal pools with underlying restrictive soil layers that become inundated during winter rains and that continuously hold water for a minimum of 19 days, in all but the driest years, thereby providing adequate water for incubation, maturation, and reproduction; (3) sources of food, expected to be detritus occurring in the pools, contributed by overland flow from the pools’ watershed, or the results of biological processes within the pools themselves, such as single-celled bacteria, algae, and dead organic matter, to provide for feeding; (4) structure within the pools, consisting of organic and inorganic materials, such as living and dead plants from plant species adapted to seasonally inundated environments, rocks, and other inorganic debris that may be washed, blown, or otherwise transported into the pools, that provide shelter. 

Major:

Loss of habitat due to 

conversion to agric

Other threats:

Habitat reduction due Pesticide use Invasive weeds 
2013 VGP and sVGP BE Section 4- 

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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThLonghorn fairy shrimp, Branchinecta longiantenna 

San Francisco Bay Estuary (San Francisco, CA) 

(1) mounds and swales and depressions within a matrix of surrounding uplands that result in complexes of continuously, or intermittently, flowing surface water in the swales connecting pools, (2) depressional features including isolated vernal pools with underlying restrictive soil layers that become inundated during winter rains and that continuously hold water for a minimum of 23 days, in all but the driest years; thereby providing adequate water for incubation, maturation, and reproduction; (3) sources of food, expected to be detritus occurring in the pools, contributed by overland flow from the pools’ watershed, or the results of biological processes within the pools themselves, such as single-celled bacteria, algae, and dead organic matter, to provide for feeding; (4) structure within the pools, consisting of organic and inorganic materials, such as living and dead plants from plant species adapted to seasonally inundated environments, rocks, and other inorganic debris that may be washed, blown, or otherwise transported into the pools, that provide shelter. 

Major:

Loss of habitat due to 

conversion to agric

Other threats:

Local extirpations fro

because of the smapopulations for this 

Severe drought Degradation of habit

plant species 

Inappropriate grazing 

Brooksville bellflower, Campanula robinsiae 

Biscayne Bay (Miami, FL) No critical habitat 

Major:

Residential and agricRunoff Other threats:

Collecting Vandalism 

Red wolf, Canis rufus 

Biscayne Bay (Miami, FL) No critical habitat 

Major:

Diseases Parasites Poor nutrition Predation Hybridization 
2013 VGP and sVGP BE Section 4- 

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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThLoggerhead sea turtle, Caretta caretta 

Galveston Bay (Houston, Texas) Upper/Lower New York Bay (New York, NY) San Francisco Bay Estuary (San Francisco, CA) Biscayne Bay (Miami, FL) 

Critical habitat was designated but constituent elements could not be specified 

Major (nesting):

Habitat destruction/dCoastal developmentBeachfront lighting Human disturbance Predation (native and Major (marine):Entanglement/IngestCommercial fishing oHabitat degradation Boat collisions Sedimentation/SiltatiAgricultural/IndustriChannel dredging Commercial harvest 

White sedge, Carex albida 

San Francisco Bay Estuary (San Francisco, CA) 

No critical habitat 

Major:

Habitat encroachmenOther threats:

Surrounding resident

the upper slopes of threat on the hydro

Hoover’s spurge, Chamaesyce hooveri 

San Francisco Bay Estuary (San Francisco, CA) 

(1) isolated mound and intermound complex within a matrix of surrounding uplands that result in continuously, or intermittently, flowing surface water in the depressional features including swales connecting pools, providing for dispersal and promoting hydroperiods of adequate length in the pools; (2) depressional features including isolated vernal pools with underlying restrictive soil layers that become inundated during winter rains and that continuously hold water or whose soils are saturated for a period long enough to promote germination, flowering, and seed production of predominantly annual native wetland species and typically exclude both native and nonnative upland plant species in all but the driest years. 

Major:

Habitat loss by agricuHabitat degradation Extirpation and threa

projects 

Inadequate regulatory Invasive weeds Other threats:

Drought Climate change Small population size 
2013 VGP and sVGP BE Section 4- 

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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThWestern snowy plover (Pacific coastal pop.), Charadrius alexandrines nivosus 

San Francisco Bay Estuary (San Francisco, CA) 

(1) sparsely vegetated areas above daily high tides (such as sandy beaches, dune systems immediately inland of an active beach face, salt flats, seasonally exposed gravel bars, dredge spoil sites, artificial salt ponds and adjoining levees) that are relatively undisturbed by the presence of humans, pets, vehicles or human-attracted predators; (2) sparsely vegetated sandy beach, mud flats, gravel bars or 

artificial salt ponds subject to daily tidal inundation, but not currently under water, that support small invertebrates; (3) surf or tide-cast organic debris such as seaweed or driftwood. 

Major:

Poor reproductive su

disturbance 

Habitat loss due to deLimited nesting habitNative and introduce

Piping plover, Charadrius melodus 

Galveston Bay (Houston, Texas) Saint Louis/Superior Bay (Lake Superior) (Duluth, MN) Upper/Lower New York Bay (New York, NY) 

(1) Gulf and Atlantic coasts along margins of sparsely vegetated interior bays, inlets, and lagoons; (2) prairie alkali wetlands and surrounding shoreline, including 200ft of uplands above the high water mark; (3) river channels and associated sandbars and islands; and reservoirs and their sparsely vegetated shorelines; (4) peninsulas, and islands; and inland lakes and their sparsely vegetated shorelines. 

Major:

Habitat destruction/dUrban/Industrial devReservoir constructioChannel excavation Hydrology alteration Increased predation Human disturbance Other threats:

Oil pollution Disease, parasites, anPesticides 
2013 VGP and sVGP BE Section 4- 

4-66

Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThGreen sea turtle, Chelonia mydas

Galveston Bay (Houston, Texas) Puget Sound (Seattle, WA) Upper/Lower New York Bay (New York, NY) Biscayne Bay (Miami, FL) 

Critical habitat was designated but constituent elements could not be specified 

Major (nesting):

Habitat destruction/dCoastal developmentBeachfront lighting Human disturbance Predation (native and Major (marine):Entanglement/IngestCommercial fishing oHabitat degradation Boat collisions Sedimentation/SiltatiAgricultural/IndustriChannel dredging Other threats:

Disease (FibropapilloCommercial harvest 

Fountain thistle, Cirsium fontinale var. fontinale 

San Francisco Bay Estuary (San Francisco, CA) 

No critical habitat 

Major:

Loss of major pollinaOther threats:

Habitat loss due to huNon-native plant speSeed predation Road widening Fire Dumping of garden d

Suisun thistle, Cirsium hydrophilum var. hydrophilum 

San Francisco Bay Estuary (San Francisco, CA) 

(1) persistent emergent, intertidal, estuarine wetland at or above the mean high-water line (as extended directly across any intersecting channels); (2) open channels that periodically contain moving water with ocean-derived salts in excess of 0.5 percent; (3) gaps in surrounding vegetation to allow for seed germination and growth. 

Major:

Habitat modification Changes to natural tiFeral pigs Mosquito abatement Plant invasion Insects Extirpation of small pOther threats:

Global climate chang
2013 VGP and sVGP BE Section 4- 

4-67

Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThBog turtle, Clemmys (Glptemys) muhlenbergii 

Upper/Lower New York Bay (New York, NY) 

No critical habitat 

Major:

Habitat destruction/d

fragmentation 

Wetland alteration Development Dredging Water diversion Hydrological alteratiOther threats:

Pollution Invasive species Natural vegetation suHeavy grazing Illegal wildlife trade Pesticides High raccoon populaHuman impacts/deve

Soft bird’s-beak, Cordylanthus mollis ssp. mollis 

San Francisco Bay Estuary (San Francisco, CA) 

(1) persistent emergent, intertidal, estuarine wetland at or above the mean high-water line (as extended directly across any intersecting channels); (2) rarity or absence of plants that naturally die in late spring (winter annuals); (3) partially open spring canopy cover (approximately 790 nMol/m2/s) at ground level, with many small openings to facilitate seedling germination. 

Major:

Marsh alteration and Muting of tides and sInvasive species Mosquito abatement Seed predation Sea level rise/global Oil spills Other threats:

Random events 
2013 VGP and sVGP BE Section 4- 

4-68

Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThPalmate-bracted bird’s beak, Cordylanthus palmatus 

San Francisco Bay Estuary (San Francisco, CA) 

No critical habitat 

Major:

Habitat loss Urban expansion Changes in hydrologRandom/catastrophic Road maintenance Wetland filling Exotic plant encroachOff-road vehicle use Lifestock wallowing Other threats:

Ozone Excessive dust Climate change 

American crocodile, Crocodylus acutus 

Biscayne Bay (Miami, FL) 

Critical habitat was designated but constituent elements could not be specified 

Major:

Poaching Habitat loss Other threats:

Natural disasters Road kill 
2013 VGP and sVGP BE Section 4- 

4-69

Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThLeatherback sea turtle, Dermochelys coriacea 

Galveston Bay (Houston, Texas) Puget Sound (Seattle, WA) Upper/Lower New York Bay (New York, NY) San Francisco Bay Estuary (San Francisco, CA) Biscayne Bay (Miami, FL) 

Critical habitat was designated but constituent elements could not be specified 

Major (nesting):

Habitat destruction/dCoastal developmentBeachfront lighting Human disturbance Predation (native and Major (marine):Entanglement/IngestCommercial fishing oHabitat degradation Boat collisions Sedimentation/SiltatiAgricultural/IndustriChannel dredging Other threats:

Commercial harvest 

Valley elderberry longhorn beetle, Desmocerus californicus dimorphus 

San Francisco Bay Estuary (San Francisco, CA) 

Critical habitat was designated but constituent elements could not be specified 

Major:

Invasive species 

Eastern indigo snake, Drymarchon corais couperi 

Biscayne Bay (Miami, FL) No critical habitat 

Major:

Habitat loss, degradaOther threats:

Fire suppression Collection Persecution 

Delta green ground beetle, Elaphrus viridis 

San Francisco Bay Estuary (San Francisco, CA) 

No critical habitat 

Major:

Habitat loss due to coOther threats:

Bug collectors 
2013 VGP and sVGP BE Section 4- 

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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThSouthern sea otter, Enhydra lutris nereis 

San Francisco Bay Estuary (San Francisco, CA) 

No critical habitat 

Major:

Habitat degradation Human take Oil spills Other threats:

Infectious disease Commercial fishing aFood resource limitat

Hawksbill sea turtle, Eretmochelys imbricate 

Galveston Bay (Houston, Texas) Upper/Lower New York Bay (New York, NY) Biscayne Bay (Miami, FL) 

(1) pristine coral reefs with high sponge density for foraging; (2) reef ledges and caves for shelter and refuge from predators; (3) undeveloped beach habitat, both insular and mainland for nesting. -Critical habitat areas include Mona and Monita Islands, Puerto Rico. 

Major (nesting):

Habitat destruction/dCoastal developmentBeachfront lighting Human disturbance Predation (native and Major (marine):Commercial harvest Entanglement/IngestCommercial fishing oHabitat degradation Boat collisions Sedimentation/SiltatiAgricultural/IndustriChannel dredging 

North Atlantic right whale, Eubalaena glacialis 

Upper/Lower New York Bay (New York, NY) Biscayne Bay (Miami, FL) 

(1) spring/early summer feeding area and nursery in the Great South Channel, NE; (2) late winter/spring feeding and nursery area in Cape Cod Bay, MA; (3) winter calving ground and nursery area in the coastal waters of the southeastern US. 

Major:

Boat collisions Noise contaminants Pollution Habitat degradation Climate change Fishing gear entangle
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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThTidewater goby,Eucyclogobius newberryi 

San Francisco Bay Estuary (San Francisco, CA) 

No critical habitat 

Major:

Habitat degradation Diversion of water Dredging Pollution from agricuSiltation Urban development Coastal road construcOther threats:

Drought Introduced predatory Pedestrians 

Steller sea-lion, Eumetopias jubatus 

Puget Sound (Seattle, WA) San Francisco Bay Estuary (San Francisco, CA) 

Constituent elements are not described in the Federal Regulation designating critical habitat for this species. 

Major:

Boat collisions Pollution Habitat degradation Illegal hunting Subsistence harvest Offshore oil and gas Fisheries Gear entanglement Competition for food 

Whooping crane, Grus americana 

Galveston Bay (Houston, Texas) 

(1) brackish bays, marshes, salt flats and barrier islands in southern US. Cropland and riverine habitat is preferred in northern US, as well as available wetland mosaics; (2) additional upland areas for alternate food sources and roosting; (3) due to territoriality, large expanses of undisturbed wetland/marsh habitat is a key element. 

Major (wild popula

Collision with manm

o (power lines and 

Illegal shooting Chemical spills along Predators Disease Habitat destruction Severe weather Loss of genetic mateMajor (captive popu

Disease Accidents In-breeding 
2013 VGP and sVGP BE Section 4- 

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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThWhite abalone, Haliotis sorenseni 

San Francisco Bay Estuary (San Francisco, CA) 

No critical habitat 

Major:

Poor reproductive su

fragmentation of ex

Other threats:

Withering syndrome 

Johnson’s seagrass, Halophila johnsonii 

Biscayne Bay (Miami, FL) 

(1) locations with populations that have persisted for 10 years; (2) locations with persistent flowering populations; (3) locations at the northern and southern range limits of the species; (4) locations with unique genetic diversity; (5) locations with a documented high abundance of Johnson’s seagrass compared to other areas in the species’ range. 

Major:

Habitat loss, degradaDredging and filling Construction and shaProp scarring Altered water quality Siltation Other threats:

Stochastic storm eve

Water howellia, Howellia aquatilis 

Puget Sound (Seattle, WA) No critical habitat 

Major:

Habitat destruction/dUrban development Channelization and dAgricultural developOther threats:

Timber harvest Wetland succession Non-native species e

Delta smelt,Hypomesus transpacificus 

San Francisco Bay Estuary (San Francisco, CA) 

(1) shallow, fresh or slightly brackish backwater sloughs and edgewaters and substrates for egg attachment for spawning; (2) rivers and channels free from physical disturbance and flow disruption; (3) 2 ppt isohaline, shallow, protective, food-rich waters for larvae and juveniles to mature; (4) adequate flow and water quality to attract migrating adults to the Sacramento and San Joaquin Rivers and tributaries. 

Major:

Low fecundity and 1Reduction or increasEntrainment losses o

water diversion 

Changes in food resoOther threats:

Hybridization of the 
2013 VGP and sVGP BE Section 4- 

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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThPink mucket, Lampsilis abrupta 

Mississippi River (St. Louis, MO) No critical habitat 

Major:

Habitat destruction/dFlood control Navigation Hydroelectric power Recreation Siltation Strip mining Coal washing Dredging Farming Logging Road construction Pollution Agricultural waste Invasive species Dams 

Kemp’s Ridley sea turtle, Lepidochelys kempii 

Galveston Bay (Houston, Texas) Upper/Lower New York Bay (New York, NY) 

No critical habitat 

Major (nesting):

Habitat destruction/dCoastal developmentBeachfront lighting Human disturbance Dredging Predation (native and Major (marine):Entanglement/IngestCommercial fishing oHabitat degradation Boat collisions Sedimentation/SiltatiAgricultural/IndustriChannel dredging 
2013 VGP and sVGP BE Section 4- 

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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThOlive Ridley sea turtle, Lepidochelys olivacea 

San Francisco Bay Estuary (San Francisco, CA) 

No critical habitat 

Major:

Egg collection and adShrimp trawling Other threats:

Incidental captures 

Vernal pool tadpole shrimp, Lepidurus packardi 

San Francisco Bay Estuary (San Francisco, CA) 

(1) mounds and swales and depressions within a matrix of surrounding uplands that result in complexes of continuously, or intermittently, flowing surface water in the swales connecting pools, providing for dispersal and promoting hydroperiods of adequate length in the pools; (2) depressional features including isolated vernal pools with underlying restrictive soil layers that become inundated during winter rains and that continuously hold water for a minimum of 41 days, in all but the driest years, for incubation, maturation, and reproduction; (3) sources of food, expected to be detritus occurring in the pools, contributed by overland flow from the pools’ watershed, or the results of biological processes within the pools themselves, such as single-celled bacteria, algae, and dead organic matter, to provide for feeding; (4) structure within the pools, consisting of organic and inorganic materials that provide shelter. 

Major:

Habitat degradation a

and urban developm

Other threats:

Grazing Off-road vehicle Hydrological modificParasites 
2013 VGP and sVGP BE Section 4- 

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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThScaleshell mussel, Leptodea leptodon 

Mississippi River (St. Louis, MO) No critical habitat 

Major:

Habitat destruction/dFlood control Navigation Hydroelectric power Recreation Siltation Strip mining Coal washing Dredging Farming Logging Road construction Pollution Agricultural waste Invasive species Dams 

Alameda whipsnake, Masticophis lateralis euryxanthus 

San Francisco Bay Estuary (San Francisco, CA) 

(1) scrub/shrub communities with a mosaic of open and closed canopy as characterized by the chamise, chamiseeastwood manzanita, chaparral whitethorn, and interior live oak shrub vegetation series, occurring at elevations from sea level to approximately 3,850 ft (1,170 m); (2) woodland or annual grassland plant communities contiguous to the above, comprised of one or more of the following: Blue oak, coast live oak, California bay, California buckeye, and California annual grassland vegetation series; (3) lands containing rock outcrops, talus, and small mammal burrows within or adjacent to the above, essential for retreats (shelter), hibernacula, foraging, and dispersal, and provide additional prey population support functions. 

Major:

Residential and comm

habitat 

Overgrazing and rem

cover 

Other threats:

Wildfire 
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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThHumpback whale, Megaptera novaeangliae 

Galveston Bay (Houston, Texas) Puget Sound (Seattle, WA) Upper/Lower New York Bay (New York, NY) Biscayne Bay (Miami, FL) 

No critical habitat 

Major:

Entanglement with dCommercial fishing oBoat collision Whale watching vessShipping channels Fisheries Habitat displacement Recreational/IndustriOther threats:

Acoustic equipment 

Wood stork, Mycteria americana 

Biscayne Bay (Miami, FL) No critical habitat 

Major:

Habitat loss, degradaUtilization of the speDisease Predation Other threats:

Contaminants Electrocution Road kill Invasion of exotic spDisturbance Stochastic events 

Gray bat, Myotis grisescens 

Mississippi River (St. Louis, MO) Biscayne Bay (Miami, FL) 

No critical habitat 

Major:

Modifications to cav

areas 

Human disturbance aHabitat destruction/dWhite-nose syndromOther threats:

Forest insecticides anDeforestationWaterway impoundm
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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThIndiana bat, Myotis sodalist 

Mississippi River (St. Louis, MO) Upper/Lower New York Bay (New York, NY) Biscayne Bay (Miami, FL) 

(1) Shelter provided by caves and mines during winter months. -additional constituent elements could not be specified 

Major:

Modifications to cav

areas 

Human disturbance aHabitat destruction/dNatural catastrophes 

Colusa grass, Neostapfia colusana 

San Francisco Bay Estuary (San Francisco, CA) 

(1) topographic features characterized by isolated mound and intermound complex within a matrix of surrounding uplands that result in continuously, or intermittently, flowing surface water in the depressional features including swales connecting pools, providing for dispersal and promoting hydroperiods of adequate length in the pools; (2) depressional features including isolated vernal pools with underlying restrictive soil layers that become inundated during winter rains and that continuously hold water or whose soils are saturated for a period long enough to promote germination, flowering, and seed production of predominantly annual native wetland species and typically exclude both native and nonnative upland plant species in all but the driest years. 

Major:

Land conversion to u

irrigated cropland 

Impacts from surrounNon-native plants Changes to hydrologOther threats:

Human activities Extirpation 

Riparian woodrat, Neotoma fuscipes riparia 

San Francisco Bay Estuary (San Francisco, CA) 

No critical habitat 

Major:

Genetic, demographi

events due to small habitat 

Inbreeding depressioOther threats:

Flooding (to woodrat 
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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThChum salmon, Oncorhynchus keta (Hood Canal summerrun) 

Puget Sound (Seattle, WA) 

(1) freshwater spawning; (2) freshwater rearing; (3) freshwater migration; (4) estuarine areas free of obstruction; (5) nearshore marine areas free of obstructions; (6) offshore marine areas with good water quality. The physical or biological features that characterize these sites include water quality and quantity, natural cover, forage, adequate passage conditions, and floodplain connectivity. 

Major:

Overharvest in fisherCompetition with nat

hatchery raised spe

Dams (alteration of rGravel mining Water diversions Habitat destruction/dIncrease water tempeLand use practices Agriculture Logging Urbanization Pollution 
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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThSteelhead salmon, Oncorhynchus mykiss (Puget Sound, Central CA Coast, South Central CA Coast, and Southern CA Coast) 

Puget Sound (Seattle, WA) San Francisco Bay Estuary (San Francisco, CA) 

No critical habitat for the Puget Sound steelhead trout Critical Habitat for CA Coast Populations: (1) freshwater spawning sites with water quantity and quality conditions and substrate supporting spawning, incubation and larval development; (2) freshwater rearing sites with: (i) water quantity and floodplain connectivity to form and maintain physical habitat conditions and support juvenile growth and mobility; (ii) water quality and forage supporting juvenile development; and (iii) natural cover such as shade, submerged and overhanging large wood, log jams and beaver dams, aquatic vegetation, large rocks and boulders, side channels, and undercut banks; (3) freshwater migration corridors free of obstruction and excessive predation with water quantity and quality conditions and natural cover such as submerged and overhanging large wood, aquatic vegetation, large rocks and boulders, side channels, and undercut banks supporting juvenile and adult mobility and survival; (4) estuarine areas free of obstruction and excessive predation with: (i) water quality, water quantity, and salinity conditions supporting juvenile and adult physiological transitions between fresh- and saltwater; (ii) natural cover such as submerged and overhanging large wood, aquatic vegetation, large rocks and boulders, side channels; and (iii) juvenile and adult forage, including aquatic invertebrates and fishes, supporting growth and maturation. 

Major:

Deterioration of mariPredation by marine Entanglement with dCommercial fishing oOverharvest in fisherCompetition with nat

hatchery raised spe

Water diversions Habitat destruction/dLand use practices Agriculture Logging Urbanization Disease Pollution 
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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThChinook salmon, Oncorhynchus tshawytscha (Puget Sound) 

Puget Sound (Seattle, WA) 

(1) freshwater spawning sites with water quantity and quality conditions and substrate supporting spawning, incubation and larval development; (2) freshwater rearing sites with: (i) water quantity and floodplain connectivity to form and maintain physical habitat conditions and support juvenile growth and mobility; (ii) water quality and forage supporting juvenile development; and (iii) Natural cover such as shade, submerged and overhanging large wood, log jams and beaver dams, aquatic vegetation, large rocks and boulders, side channels, and undercut banks; (3) freshwater migration corridors free of obstruction and excessive predation with water quantity and quality conditions and natural cover such as submerged and overhanging large wood, aquatic vegetation, large rocks and boulders, side channels, and undercut banks supporting juvenile and adult mobility and survival; (4) estuarine areas free of obstruction and excessive predation with: (i) water quality, water quantity, and salinity conditions supporting juvenile and adult physiological transitions between fresh- and saltwater; (ii) natural cover such as submerged and overhanging large wood, aquatic vegetation, large rocks and boulders, side channels; and (iii) juvenile and adult forage, including aquatic invertebrates and fishes, supporting growth and maturation; (5) nearshore marine areas free of obstruction and excessive predation with: (i) water quality and quantity conditions and forage, including aquatic invertebrates and fishes, supporting growth and maturation; and 

Major:

Competition with nat

hatchery raised spe

Dams (alteration of rGravel mining Water diversions Habitat destruction/dIncrease water tempeLand use practices Agriculture Logging Urbanization Pollution
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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing Th

(ii) natural cover such as submerged and overhanging large wood, aquatic vegetation, large rocks and boulders, and side channels.; (6) offshore marine areas with water quality conditions and forage, including aquatic invertebrates and fishes, supporting growth and maturation. 

Killer whale, Orcinus orca 

Puget Sound (Seattle, WA) San Francisco Bay Estuary (San Francisco, CA) 

Critical habitat was designated but constituent elements could not be specified 

Major:

Pollution Depletion of prey (ovHabitat degradation Ship collisions Other threats:

Acoustic equipment Entanglement in fish Whale watching vessIllegal hunting 

Hairy orcutt grass,Orcuttia pilosa 

San Francisco Bay Estuary (San Francisco, CA) 

(1) topographic features characterized by isolated mound and intermound complex within a matrix of surrounding uplands that result in continuously, or intermittently, flowing surface water in the depressional features including swales connecting pools, providing for dispersal and promoting hydroperiods of adequate length in the pools; (2) depressional features including isolated vernal pools with underlying restrictive soil layers that become inundated during winter rains and that continuously hold water or whose soils are saturated for a period long enough to promote germination, flowering, and seed production of predominantly annual native wetland species and typically exclude both native and nonnative upland plant species in all but the driest years. 

Major:

Changes in natural hyHabitat loss Other threats:

Agriculture Urbanization Overgrazing Non-native plants Trampling 
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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThShort-tailed albatross, Phoebastria albatrus 

Puget Sound (Seattle, WA) No critical habitat 

Major:

Natural environmentSmall population size Limited number of bOther threats:

Long-line fishing Plastic pollution Oil contamination Airplane strikes 

Calistoga allocarya, Plagiobothrys strictus 

San Francisco Bay Estuary (San Francisco, CA) 

No critical habitat 

Major:

Habitat loss due to deAlteration of hot spriRestricted range, numInadequate regulatory Other threats:

Climate change Non-native plants 

Eastern prairie fringed orchid, Platanthera leucophaea 

Mississippi River (St. Louis, MO) No critical habitat 

Major:

Habitat destruction/dUrban development Invasive species comGrazing Cutting hay in midsuOver-collection 

Napa bluegrass, Poa napensis 

San Francisco Bay Estuary (San Francisco, CA) 

No critical habitat 

Major:

Habitat loss due to deAlteration of hot spriRestricted range, numInadequate regulatory Other threats:

Climate change Non-native plants 
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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThAudubon’s crested caracara, Polyborus plancus audubonii 

Biscayne Bay (Miami, FL) No critical habitat 

Major:

Habitat conversion to Residential developmShooting and trappinRoad kill Deforestation Invasion of woody spPredation 

Smalltooth sawfish, Pristis pectinata 

Galveston Bay (Houston, Texas) Biscayne Bay (Miami, FL) 

(1) dense red mangrove habitat; (2) shallow, euryhaline habitat characterized by water depths between the mean high water line and 3 ft (0.9m) measured at mean lower low water. 

Major:

Entanglement with dCommercial fishing oHabitat destruction/dInjury from saw remoPollution Human disturbance Divers and other mar

Florida panther, Puma concolor coryi 

Biscayne Bay (Miami, FL) No critical habitat 

Major:

Habitat loss and alterLogging Drainage Oil field activity Housing developmenCitrus agriculture Road construction Mercury contaminatiVehicle collisions Other threats:

Genetic variability Loss of food due to h
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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThCalifornia red-legged frog,Rana draytonii 

San Francisco Bay Estuary (San Francisco, CA) 

(1) standing bodies of fresh water (with salinities less than 4.5 ppt) for aquatic breeding habitat, including natural and manmade ponds, slow-moving streams or pools within streams, and other ephemeral or permanent water bodies that typically become inundated during winter rains and hold water for a minimum of 20 weeks in all but the driest of years; (2) freshwater pond and stream habitats, as described above, for non-breeding habitat, that provide for shelter, foraging, predator avoidance, and aquatic dispersal of juvenile and adult California red-legged frogs, including, but are not limited to plunge pools within intermittent creeks, seeps, quiet water refugia within streams during high water flows, and springs of sufficient flow to withstand short-term dry periods; (3) upland areas adjacent to or surrounding breeding and nonbreeding aquatic and riparian habitat up to a distance of 1 mi (1.6 km) in most cases (i.e., depending on surrounding landscape and dispersal barriers) including various vegetational types such as grassland, woodland, forest, wetland, or riparian areas that provide shelter, forage, and predator avoidance for the California red-legged frog, maintaining the hydrologic, geographic, topographic, ecological, and edaphic features that support and surround the aquatic, wetland, or riparian habitat; (4) accessible upland or riparian habitat within and between occupied or previously occupied sites that are located within 1 mi (1.6 km) of each other, and that support movement between such sites as dispersal habitat, including various natural habitats, and altered habitats such as agricultural fields, that do not contain barriers (e.g., heavily traveled roads without bridges or culverts) to dispersal. 

Major:

Wetland destruction, 

degradation 

Urbanization Residential developmReservoir constructioStream channelizatioLivestock grazing Off-road vehicle use Drought Overharvesting Exotic species Conversion of habitaOther threats:

Climate change UV-B radiation Airborne contaminanDisease 

Salt marsh harvest mouse, Reithrodontomys raviventris 

San Francisco Bay Estuary (San Francisco, CA) 

No critical habitat 

Major:

Filling Diking Subsidence Salinity changes 
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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThEverglade snail kite, Rostrhamus sociabilis plumbeus 

Biscayne Bay (Miami, FL) 

Critical habitat was designated but constituent elements could not be specified 

Major:

Habitat destruction th

and agriculture con

Agriculture runoff Introduction of exotiOther threats:

Illegal shootings 

Bull trout, Salvelinus confluentus 

Puget Sound (Seattle, WA) 

(1) cold water temperature; (2) streams and rivers with riffles, deep pools, undercut banks and large amounts of large woody debris; (3) water bodies connecting to headwater streams for spawning and feeding migration routes. 

Major:

Overharvest in fisherCompetition with nat

hatchery raised spe

Hybridization Dams (alteration of rGravel mining Water diversions Habitat destruction/dIncrease water tempeLand use practices Agriculture Logging Urbanization Pollution 

Pallid sturgeon, Scaphirhynchus albus 

Mississippi River (St. Louis, MO) No critical habitat 

Major:

Construction/operatio

channelization 

Habitat degradation Illegal commercial hPollution Hybridization 
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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThAmerican chaffseed, Schwalbea americana 

Biscayne Bay (Miami, FL) No critical habitat 

Major:

Habitat development Fire suppression Other threats:

Trampling Herbicide application Road maintenance Herbivory 

Ute ladies’-tresses, Spiranthes diluvialis 

Puget Sound (Seattle, WA) No critical habitat 

Major:

Habitat destruction/dUrban development Channelization and dAgricultural developOvercollection Competition with noHerbicides Other threats:

Recreation Mowing from hay prGrazing Hydrology changes Reduction in pollinat

Least tern, Sterna antillarum (athalassos) (Interior population) 

Mississippi River (St. Louis, MO) No critical habitat 

Major:

Habitat destruction/dUrban development Channelization and dRecreational activitieOther threats:

Predation Vegetation encroachmHuman disturbance 
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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThRoseate tern, Sterna dougallii dougallii 

Upper/Lower New York Bay (New York, NY) Biscayne Bay (Miami, FL) 

No critical habitat 

Major:

Habitat destruction/dUrban development Human disturbance Increased predation w

attracts predators 

Other threats:

Pollution 

California freshwater shrimp,Syncaris pacifica 

San Francisco Bay Estuary (San Francisco, CA) 

No critical habitat 

Major:

Habitat loss/degradatAgricultural develop

grazing 

Pollutants and contamWater development 

Giant garter snake, Thamnophis gigas 

San Francisco Bay Estuary (San Francisco, CA) 

No critical habitat 

Major:

Wetland loss, fragmeMaintenance of flood Weed abatement Rodent control Contaminants Overgrazing Other threats:

Introduced species Parasites Road kills 
2013 VGP and sVGP BE Section 4- 

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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThWest Indian manatee, Trichechus manatus 

Galveston Bay (Houston, Texas) Biscayne Bay (Miami, FL) 

Critical habitat was designated but constituent elements could not be specified 

Major:

Boat collisions Loss of natural springWater diversions Power plant shutdowFlood gates and canaOther threats:

Fishing gear and trasCold wintersRed tide bloomsHuman disturbanceDisease

Solano grass, Tuctoria mucronata 

San Francisco Bay Estuary (San Francisco, CA) 

(1) topographic features characterized by isolated mound and intermound complex within a matrix of surrounding uplands that result in continuously, or intermittently, flowing surface water in the depressional features including swales connecting pools, providing for dispersal and promoting hydroperiods of adequate length in the pools; (2) depressional features including isolated vernal pools with underlying restrictive soil layers that become inundated during winter rains and that continuously hold water or whose soils are saturated for a period long enough to promote germination, flowering, and seed production of predominantly annual native wetland species and typically exclude both native and nonnative upland plant species in all but the driest years. 

Major:

Habitat modification

and fragmentation 

Altered site hydrologInappropriate grazing  Invasive plants Thatch build up Contaminant run off Drought Climate change Other threats:

Small population size 
2013 VGP and sVGP BE Section 4- 

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Table 4-19. Factors Affecting Current Status of Listed Species in RAAs (Organized Alphabetically by ScieSpecies Applicable RAA(s) Designation of Critical Habitat and/or Constituent Elements Known/Existing ThGrizzly bear, Ursus arctos horribilis 

Puget Sound (Seattle, WA) No critical habitat 

Major:

Habitat destruction/d

fragmentation 

Increase human-bear Hunting (legal and ilOther threats:

Non-native species thDisplacement of natiForestry Mining Road building

Sources: Information sources identified on a species-specific basis in Appendix F. 
2013 VGP and sVGP BE Section 4- Environmental Baseline

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SECTION 5 

EFFECTS ANALYSIS 

 There are two types of analyses (quantitative and qualitative) used in this BE to evaluate 

the potential effects that pollutants may exert on either aquatic and aquatic-dependent threatened 

or endangered species or their critical habitat. The pollutants requiring detailed analysis 

identified in Section 3.2.3 of this document fall into one of seven different pollutant categories. 

The categories include ANS, conventional pollutants, metals, nutrients, oil and grease, 

pathogens, and toxics and non-conventional pollutants with toxic effects. The majority of 

pollutants covered in this BE are subjected to quantitative analysis as described below in Section 

5.2. However, the lack of species-specific chronic response data for ANS, pathogens and a small 

number of other pollutants (e.g., oil and grease, BOD) precludes calculation of a risk quotient to 

support the quantitative effects analysis; therefore, a qualitative analysis is presented instead for 

these few pollutants based on a multiple lines of evidence approach (Section 5.1). Together, this 

information is used to support the effects determinations made in Section 7 of this BE document. 

5.1 QUALITATIVE EFFECTS ANALYSIS ON POLLUTANTS LACKING SPECIFIC 

CONCENTRATION-RESPONSE RELATED TOXIC EFFECT THRESHOLDS

 In cases where a risk quotient cannot be calculated to support the quantitative effects 

analysis and subsequent effects determinations to be made in this BE, a qualitative approach is 

used instead. The qualitative approach considers both potential for exposure and likelihood of 

adverse effects. Per above, this includes ANS, [human] pathogens and certain other pollutants 

(e.g., oil and grease, BOD). The qualitative analysis discusses the impacts of these pollutants and 

ANS and the mitigative effects provided by the issuance of the VGP and sVGP (see Section 6.0). 

Therefore, the issuance of these two permits not only improves water quality but also minimizes 

potential harm to listed species. The basis for this conclusion is supported by the best scientific 

and commercial data available for the various biological and other pollutants as follows. 

5.1.1 ANS

ANS refers to aquatic organisms found outside of their native or historical range. In 

coastal environments, commercial shipping is the most important means of introducing ANS 

(Ruiz et al., 2000), in one study accounting for one-half to three-quarters of ANS introductions to 

North America (Fofonoff et al., 2003). Accordingly, the nature of this threat to listed species, as 

well as the measures in the VGP and sVGP for control of ANS in vessel discharges, are 

important issues to address in this BE. This section of the BE presents a literature review and 

discussion of the relationship between ANS exposure (propogule pressure) and the likelihood of 

effects (invasion success and risks to listed species), including the factors and variables that 

influence this relationship. Sections 5.1.1.1 and 5.1.1.2 introduce ANS and the vessel “vector.” 

Sections 5.1.1.3 and 5.1.1.4 consider the most important vessel discharge vectors: ballast water 

and vessel biofouling. Other vessel discharge vectors for ANS are described in Section 5.1.1.5. 

Section 5.1.1.6 reviews the literature regarding mechanisms of vessel-mediated ANS invasions, 

including both ballast water discharge and biofouling vectors. Section 5.1.1.7 provides examples 

of ANS invasions in the U.S. for which vessels may have been the invasion pathway. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Section 5.1.1.7.4 addresses how ANS impact native species, and Section 5.1.1.8 reviews 

documented impacts of ANS on listed species. 

 As previously mentioned, EPA has taken a qualitative approach to assessing the risk of 

ANS to native species because the lack of available data and information prevents a precise 

quantification of this risk. The current state of science does not allow a quantitative evaluation of 

the relative merits of various numeric discharge standards in terms of invasion probability. 

However, numerous studies have concluded that the reduced discharge of viable organisms 

capable of establishing viable populations of organisms in U.S. waters reduces the risk of 

invasions (NAS, 2011). In its 2011 report, Assessing the Relationship Between Propagule 

Pressure and Invasion Risk in Ballast Water, the NAS concluded, “it is abundantly clear that 

reducing propagule pressure (i.e., the quality, quantity, and frequency with which living 

organisms are introduced into a given location) will reduce the probability of invasions, when 

controlling for all other variables,” noting that “there is both strong theoretical and empirical 

support for this, across a diverse range of habitats, geographic regions, and types of organisms.” 

5.1.1.1 What are ANS? 

 ANS, also known as invasive species, are one of the largest threats to coastal and 

freshwater ecosystems, as well as being a major global concern. ANS are now generally 

recognized as one of the greatest threats to biodiversity globally and represent a major force of 

global change, resulting in significant ecological, economic, and human health impacts 

(Candries, 2009). Non-native species have invaded over 80% of the world’s 232 marine 

ecoregions, including remote Antarctica (Williams, 2011), with particularly high levels of 

invasion in Northern California, the Hawaiian Islands, the North Sea, and the Eastern 

Mediterranean (Molnar et al., 2008). In marine and coastal environments, invasive species have 

been identified as one of the four greatest threats to the world’s oceans (GISP, 2008). ANS affect 

biodiversity by displacing native species and by altering community structure, food webs and 

ecological processes. 

 Invasive species are a persistent problem in U.S. coastal and inland waters. Although 

introductions of ANS into waters of the U.S. have occurred for more than 400 years, numerous 

studies have shown that the rate of ANS introductions to waters of the United States is increasing 

(USCG, 2012). ANS in marine, estuarine and freshwater environments may be transported to 

new regions through numerous human activities (Takata et al., 2006). Intentional and 

unintentional releases of fish and shellfish, aquaculture escapes, releases from the aquarium and 

pet industries, floating marine debris, bait shipping, and accidental release by research 

institutions are some of the mechanisms, or “vectors,” by which organisms are transferred (U.S. 

Commission on Ocean Policy, 2004). However, the predominant vector for the human transport 

of invasive species in marine environments is known to be shipping (Ruiz and Carleton, 2003). 

 ANS may be introduced through a variety of vessel discharges, including ballast water 

and sediment discharged from ballast tanks, biofouling, anchor chains and chain lockers. Of the 

vessel discharges, ballast water and biofouling are the primary mechanisms for the transport and 

introduction of ANS in the U.S. in the modern shipping era (i.e., steel vessels utilizing water 

ballast) (Ruiz et al., 2000; Takata et al, 2011). It is generally agreed that the rate, and thus the 

risk, of species invasions has increased significantly during recent decades, as well as the number 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-3 

and diversity of species being moved (McNeely et al., 2001). One of the primary factors leading 

to this increase has been the expansion of global trade, which has lead to significantly more 

ballast water, fouled hulls, and associated organisms moving around the world (Minchin and 

Gollasch, 2003). 

 Although no reliable and comprehensive estimates of total ANS introductions nationwide 

exist, case studies of several major bodies of water across the country, as summarized in Table

5-1, provide a sense of the extent of the problem. 

Table 5-1. Estimates of Invasive Species in Several Major Water Systems 

Region Estimated Historic Rate of 

Invasiona

Estimated Total Invasions to 

Date

Great Lakes Once every 28 weeks

b

182b

Mississippi River System Unknown 100c

San Francisco Bay Once every 14 weeks

d 234d

Lower Columbia River Basin Once every 22 weekse 81e

Gulf of Mexico Unknown 704f

a) Ruiz and Reid (2007) suggest that these figures may not reliably represent the true rate of 

introduction, as they are based on discovery data, which may not always track with the underlying rate 

of introduction. 

b) Ricciardi , 2006. 

c) USCG, 2009. 

d) Cohen and Carlton, 1998. 

e) Sytsma et al., 2004. 

f) Battelle, 2000. 

ANS pose several dangers to aquatic ecosystems, including outcompeting native species, 

damaging habitat, changing food webs, and altering the chemical and physical aquatic 

environment. ANS have been cited as the second largest threat to endangered species after 

habitat loss (Wilcove and Chen, 1998). However, as understanding of bioinvasions has grown, 

some scientists have come to believe that invasive species have an even greater impact on 

biodiversity than habitat loss (Johnson et al., 2007). 

 One of the most well-known examples of ANS is the zebra mussel. Zebra mussels are 

native to Eurasia, near the Black and Caspian Seas, and were first discovered in U.S. waters in 

1988. They were most likely introduced via the discharge of ballast water. Populations of zebra 

mussels were established in the Great Lakes and are now found throughout most of the eastern 

United States and in some western states. Zebra mussels have profoundly altered biotic function 

and abiotic processes in many of the waters in which they have proliferated. Further discussions 

of zebra mussels and other ANS that have successfully invaded the U.S. are presented in Section 

5.1.1.7, and Section 5.1.1.8 addresses how ANS impact native species. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-4 

5.1.1.2 Vessels as a Vector for ANS Introduction 

 In the U.S., large commercial vessels (those displacing greater than 300 metric tons) 

arrive over 90,000 times per year in hundreds of different ports in U.S. coastal waters including 

the Great Lakes (Miller et al., 2010). Approximately half of these arrivals are from ports of call 

outside the U.S. and Canada; the remainder arrive directly from another port within North 

America. In the period 2006-07, commercial vessels reported discharging 196 million metric 

tons of ballast water in U.S. coastal waters (Miller et al., 2010). This is a minimum annual 

estimate of ballast water discharge since data were not available for all of the vessel arrivals to 

U.S. ports (NAS, 2011). If this quantity of ballast water (equivalent to 2,300 cubic meters per 

second) was the annual discharge of a river, it would qualify as one of the 20 largest rivers in the 

U.S. according to the U.S. Geological Survey1. Thirty percent of this ballast water originated 

from outside of North America (i.e., it was taken on from a foreign source port), and the 

remainder came from other ports or locations within the U.S. and Canada. 

 Biofouling on the hulls of commercial vessels is also a significant vector for the transport 

and introduction of ANS. According to Miller et al. (2007), about 800 million square meters (800 

square kilometers) of commercial shipping hull area arrives in the U.S. from other bioregions 

each year. To put this in perspective, this annual hull area is somewhat smaller than the area of 

San Francisco Bay (1,000 to 4,100 square kilometers). 

 While these figures quickly convey the scope of commercial shipping arriving from 

overseas, several other key points are noteworthy, according to the NAS (2011). First, there is 

tremendous variation among U.S. ports in the numbers of vessel arrivals and ballast water 

discharges. Second, the number of vessel arrivals does not correlate with the ballast water 

discharges for these ports. As a consequence, the number of vessel arrivals is not a good 

predictor or proxy for the volume of ballast water discharged in a port. Likewise, the number of 

vessel arrivals may be a poor proxy for relative ballast volumes transported from other source 

regions (NAS, 2011). Similar analyses of the relationship between numbers of vessel arrivals in 

U.S. ports, commercial shipping hull area, and origin from other source regions are underway 

(Miller et al., 2007). 

5.1.1.3 Ballast Water Discharge 

 Ballast water is necessary for the safe operation of the vast majority of larger vessels to 

assist with vessel draft, trim, and stability. Almost all large commercial vessels have ballast 

tanks, pumps, piping and other equipment dedicated to this purpose. In lieu of or in addition to 

such dedicated systems, some vessels may also carry ballast water in otherwise empty cargo 

holds. Ballast water is typically drawn in from, and discharged directly to, ambient waters. 

Ballast water often contains sediment as well, which may accumulate in the bottom of ballast 

tanks. 

 Aquatic organisms may be taken up with ballast water and associated sediment prior to 

vessel embarkment or during the voyage. These organisms may be discharged when the vessel 

 

1 U.S. Geological Survey. Largest Rivers in the United States. Available at http://pubs.usgs.gov/of/1987/ofr87-242/

Accessed April 2012. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-5 

discharges ballast tanks that contain such species, or when the vessel adds ballast water to tanks 

that contain such organisms in the residual water or sediment in the tank, and later discharges 

that mixture. When such organisms in ballast tanks are transported between waterbodies and 

discharged, the organisms may have the potential to establish viable new populations of species 

in waterbodies to which they are not native. 

5.1.1.3.1 Volume and Discharge of Ballast Water 

Ballast water discharge volumes vary by vessel type, ballast tank capacity, and type of 

deballasting equipment. The volume of ballast water discharge is also expected to vary 

proportionately to the size of the vessel. Volumes of ballast water discharged from large vessels 

are significant and can range from several hundred to many thousands of cubic meters of water. 

For instance, ultra-large crude carriers (ULCCs) have a representative ballast capacity of about 

95,000 cubic meters (about 25 million gallons), while large passenger vessels (cruise ships) have 

a representative ballast capacity of about 3,000 cubic meters (about 790,000 gallons) (ABS, 

2010). Some vessels, such as small water ferries, may have as little as 5 cubic meters (about 

1,300 gallons) of ballast water. 

 The discharge rate of ballast water is generally proportional to the size of the ballast 

tanks, although there are notable exceptions (e.g., bulk carriers on the Great Lakes are often 

designed to load and unload cargo and ballast water quickly). The ballast water discharge rate 

and quality vary by vessel type, ballast tank capacity, type of deballasting equipment, the quality 

of the ambient water from which the ballast water is drawn, the amount and quality of residual 

water or sediment in the tank, the efficacy of any ballast water management practices and/or 

ballast water treatment employed. The types and quantities of aquatic organisms in bilge water 

are discussed below. 

5.1.1.3.2 Abundance and Diversity of Organisms in Ballast Water 

 The concentration of organisms present within a ship’s ballast water varies considerably 

due to tremendous temporal and spatial variation in organism abundance among sources and 

seasons, particular voyage conditions, characteristics of the ships themselves, and the nature of 

ballast water management practices, among other factors (NAS, 2011). For example, as many as 

300 million cysts of toxic dinoflagellates have been detected in a single tank. Past studies 

provide some estimates of abundances for various types of organisms in ballast tanks. Table 5-2 

indicates concentrations of particular organism types found in the ballast water of vessels that 

were sampled upon arrival to various ports (in the regions indicated). 

Table 5-2. Concentration of Various Organism Types Reported in Unexchanged Ballast 

Water Sampled Upon Arrival of Ships to Particular Regions 

Average Standard Error Number 

Zooplankton (organisms/m3) 

Chesapeake Bay (overseas) 1.94 x 103 10 x 101 113 

Chesapeake Bay (domestic) 1.75 x 104 1.5 x 103 37 

Prince William Sound, Alaska 1.26 x 104 5.53 x 103 169 
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Table 5-2. Concentration of Various Organism Types Reported in Unexchanged Ballast 

Water Sampled Upon Arrival of Ships to Particular Regions 

Average Standard Error Number 

Phytoplankton (cells/liter) 

Europe 2.99 x 105 1.84 x 105 273 

Bacteria (cells/liter) 

Chesapeake Bay 8.3 x 108 1.7 x 108 9 

Chesapeake Bay 8.03 x 108 1.88x108(sd) 53 

Virus-like Particles (vlp/liter) 

Chesapeake Bay 7.4x 109 2.3 x 109 7 

Chesapeake Bay 1.39 x 1010 1.57x1010 (sd) 31 

Source: NAS, 2011. 

 Thousands of species may be transported across and between oceans in ballast water on a 

daily basis (Carlton, 1999), and the cumulative number of species transported over years to 

decades is undoubtedly enormous (NAS, 2011). This understanding comes from studies which 

have sampled ballast tanks of ships arriving to a particular port, providing a snapshot of diversity 

for a small fraction of discharged ballast water. Examples cited in NAS (2011) include: 

 Over 400 species were found in about 150 Japanese wood chip cargo vessels arriving 

in the Port of Coos Bay, Oregon (Carlton and Geller, 1993); 

 342 phytoplankton taxa reported from only nine ships arriving from a variety of 

overseas and domestic ports in the Port of Morehead City, North Carolina (McCarthy 

and Crowder, 2000); 

 One vessel from Europe had over 130 species of diatoms alone (McCarthy and 

Crowder, 2000); 

 More than 221 species were found in 60 vessels sampled in the Chesapeake Bay 

(Smith et al., 1999); and 

 147 species were gathered from 38 ships’ samples in the Great Lakes (Duggan et al., 

2005). 

 The organisms collected from unexchanged and untreated ballast water and sediments 

span orders of magnitude in size, ranging from fishes (30 cm) down to diapausing eggs (~100 

μm) and microorganisms (protists, bacteria, and viruses; ~20 nm). Over 15 animal phyla have 

been detected in ballast (especially common are mollusks, crustaceans, worms, hydromedusae, 

and flatworms), as well as algae, seagrasses, viruses, and bacteria. Many of the animals in ballast 

water are in planktonic stages (from larvae to adult), while those in ballast sediments may be 

adults as well as their diapause (resting) forms (NAS, 2011). 

 Benthic (bottom-dwelling) communities can develop within ballast tanks that can include 

a diverse range of biota, including adults, larvae, eggs, and resting stages (NAS, 2011). Very 

high densities of resting stages can accumulate within ballast tanks. For example, Hallegraeff 

and Bolch (1992) found that 65% of 343 vessels in Australia had sediments, all of which 

contained diatom resting spores. Based on this research and further studies of resting stages for a 

variety of taxa in the Great Lakes and elsewhere, it is clear that such bottom sediments serve as 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-7 

“seed banks” with viable organisms that can be released from ballast tanks during operations 

(NAS, 2011). 

5.1.1.3.3 Variability of Propagule Pressure from Ballast Water 

 Propagule pressure is a general term expressing the quantity, quality, and frequency with 

which propagules are introduced to a given location (NAS, 2011). Propagules are any living 

biological material (such as particles, cells, spores, eggs, larvae, and mature organisms) 

transported from one location to another. In the case of ballast water discharge, the propogule 

pressure is the product of the ballast water discharge volume and the inoculum density. Inoculum 

density is usually reported as the number of organisms (propagules) per cubic meter of water, 

representing the number of individuals that could be released upon discharge. Inoculum density 

in ballast water, and therefore propoagule pressure, can vary tremendously (Section 5.1.1.3.2). 

As noted in NAS (2011), ballast systems can also have attached fouling organisms on tank walls 

that form transient or permanent communities, as well as benthic assemblages. These fouling and 

benthic communities could contribute propagules (larvae) to the water, such that ballast systems 

would then be essentially self-seeded and could conceivably be released as well during ballast 

water discharge. 

 Inoculum frequency—the rate of propagule delivery per a given cohort of vessels over a 

given time period—can vary widely. Thus, combining the concepts of inoculum density with 

propagule source and frequency, an enormous range of scenarios can potentially strongly 

influence invasion outcomes. Patterns can range from one inoculum of ballast water being 

released from one source at one time into one location, to multiple inoculations from multiple 

sources released at multiple times in multiple locations. As noted in NAS (2011), multiple 

inocula can act as a “rescue” effect to sustain a nonindigenous population that might otherwise 

not have become established. Small releases occurring close together in space and time can 

approximate a single large release with a correspondingly higher establishment probability. 

 The species composition of ballast water loaded from different sources can vary widely. 

ANS from distinct biogeographic zones are thought to experience differences in the capacity of 

their species to colonize a particular target location, assuming equal opportunity and similar 

habitat types, such as the intertidal mudflat of a bay (NAS, 2011). The underlying mechanisms 

may include differences in physiological tolerance, competitive ability, and life history. Biota 

from some geographic regions may be more successful in invading, compared to others, due to 

competitive superiority or particular traits that have evolved in those regions (NAS, 2011). 

 A number of other variables can influence the propagule pressure of ANS in ballast 

water. These include progagule history (e.g., the residence time in a ballast tank) and other 

conditions that can affect propogule quality during transport. For example, ballasted 

communities are often closed systems that change over time, such that the organisms present 

experience changes in temperature, water chemistry, and food that affect both physiological 

condition and survivorship. Due to these variables, the relationship between propagule supply 

and probability of establishment may differ greatly among individual discharge events, even 

when controlling for inoculation density (NAS, 2011).
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-8 

5.1.1.4 Vessel Biofouling 

 Biofouling organisms attach to submerged hard surfaces of both naturally occurring and 

man-made structures (Railkin, 2004), and the hulls and other underwater surfaces of vessels are 

no exception. Species that foul vessels are typical of natural, marine intertidal and subtidal 

fouling communities: arthropods (barnacles, amphipods, and crabs), molluscs (mussels, clams, 

and sea slugs), sponges, bryozoans, coelenterates (hydroids and anemones), protozoans, annelids 

(marine worms), and chordates (sea squirts and fish), as well as macroalgae (seaweed). If these 

fouling communities become highly developed, they can also provide micro-habitats for mobile 

organisms such as fish. 

 Typically, there is a progression of attachment of marine organisms to a vessel’s hull 

(Floerl et al., 2010). Primary biofouling begins as soon as the surface of a vessel is submerged in 

seawater, with the formation of a slime layer consisting of bacteria and microscopic algae. If the 

hull is coated with an anti-fouling coating (AFC) containing a biocide, the toxicant will act to 

deter the attachment of higher forms such as barnacles and tubeworms, but will usually allow 

primary biofouling within days or weeks of launching with fresh AFC. 

 As the vessel remains submerged in seawater, the AFC “ages” and begins to lose 

effectiveness, allowing secondary biofouling processes to occur as organisms settle on top of the 

primary biofouling layer. Secondary biofouling usually includes hard encrusting animals such as 

acorn barnacles, bryozoans and serpulid worms, but may also include soft algal tufts and mobile 

amphipods. This is then followed by a more general infestation, spreading beyond edges onto the 

flats of the ship hull. If allowed to progress, tertiary biofouling then follows, generally consisting 

of larger organisms, such as sponges, sea squirts, mussels, oysters and seaweeds that build up on 

the secondary biofouling layer, and mobile animals such as crabs and sea stars that can live in 

this growth. 

 Although biofouling progresses in a predictable manner as described above, it is not a 

uniform process. Biofouling is not evenly distributed on the submerged portion of a vessel, 

because a vessel's hull is not a uniform surface. Fouling tends to be especially predominant in 

locations that either protrude from, or are recessed into, the hull (“niche” areas). The presence of 

niche areas varies with vessel type. Though much of the outer surface of vessel hulls are treated 

with AFCs designed to discourage fouling growth, niche areas are particularly prone to 

biofouling because they are often not coated with AFCs (e.g., propellers, rudder stocks), are 

protected from water flow and turbulence (e.g., thruster tunnels), or are exposed to high water 

flow and turbulence (e.g., sea chest gratings). These areas on a vessel have been noted to have 

higher numbers and/or diversity of fouling organisms, even in cases where main portions of the 

hull are clean. Notably, these niches or biofouling “hot spots” are also harder to clean. 

5.1.1.4.1 Extent of Fouling on Commercial Vessels 

 As previously noted, about 800 million square meters of commercial shipping hull area 

arrives in the U.S. from other bioregions each year (Miller et al., 2007), indicating the significant 

potential for the vessel-mediated biofouling vector to transport fouling organisms and potentially 

introduce ANS. Less well understood is the nature and extent of biofouling on the majority of 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-9 

vessels entering U.S. ports. Miller et al. (2007) investigated the extent of biofouling on 21 

commercial vessels and found that even the best-maintained commercial vessels could have 

biofouling on up to 5% of their wetted surface, while 10 drydocked ships were covered over 5 to 

>90% of their wetted surface. In 2009, Davidson et al. studied biofouling on 22 in-service 

container ships at the Port of Oakland, and found that the extent of macroorganisms 

(invertebrates and algae) was very low, especially across the large surface areas of the hull. Less 

than 1% of the exposed hull was colonized for all except one of these vessels2

. The low extent of 

fouling on container ships, compared to other vessel types (bulk and general cargo vessels), is 

apparently due to their relatively fast speeds and short port durations. Despite limited fouling, 

however, taxonomic richness was high among these container ships. A wide range of organisms 

were concentrated at more protected niche areas, including rudders, stern tubes and intake 

gratings. Green algae and barnacles were most frequently sampled among vessels, but hydroids, 

bryozoans, bivalves and ascidians were also recorded. One vessel had 20 different species in its 

fouling assemblage, including non-native species (already established in San Francisco Bay) and 

mobile species. 

 The hull husbandry practices currently used by commercial vessels are not completely 

effective, and ANS are still being transported by this means (Johnson et al., 2007). Although the 

IMO adopted Guidelines for the Control and Management of Ships' Biofouling to Minimize the 

Transfer of Invasive Aquatic Species in 2011 (Annex 26 Resolution MEPC.207(62), the risk of 

ANS transport and release by the biofouling on the universe of commercial vessels (as well as 

military and recreational vessels) is also still poorly understood. There is relatively little 

information on the ANS transport and release potential posed by the majority of the commercial 

vessel fleet that conducts regular vessel maintenance, spends relatively little time in port, and 

travels at normal speeds. There is also little information on how well the current hull 

maintenance practices of the majority of the commercial vessel fleet limit the transport and 

release of ANS. 

 Takata et al. (2011) analyzed data from Hull Husbandry Reporting Forms (HHRFs) 

submitted in 2008 and 2009 by all commercial vessels of 300 gross tons or more operating in 

California waters. The HHRF includes information about each vessel’s hull husbandry practices 

and voyage characteristics. The hull husbandry practices employed by the fleet of commercial 

vessels operating in California indicated that vessels were complying with current California law 

and were attempting to limit the amount of fouling organisms that can accumulate. The HHRF 

data indicate that the fleet was relatively young. One third of the California fleet in 2009 were 

newly built and delivered within the past five years, and over 70% of these new builds were 

delivered within the past three years. Therefore the majority have had comparatively less time to 

accumulate fouling organisms. The remainder of the vessels (67% of the fleet) appeared to be 

physically removing fouling organisms regularly. 

 Voyage characteristics examined from the California HHRFs suggested a gradient of risk 

associated with different vessel types. Elevated traveling speed and shorter sedentary periods 

were associated with lower levels of fouling accumulation. Auto, container and passenger vessels 

that visit California exhibited these characteristics (travel at elevated speeds in excess of 16 knots 

 

2

 The outlying vessel was smaller and had an estimated coverage of 90% on the hull and also differed substantially 

from the other ships in terms of its recent voyage history, shorter voyage range and slower speeds. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-10 

and spend a day or less in port). In comparison, bulk vessels and the "other" vessel type category 

travel at slower speeds and typically spend over three days in port. 

5.1.1.4.2 The Relationship of Biofouling to Underwater Ship Husbandry 

 Mariners have long been aware of fouling as a nuisance to vessel operations as it relates 

to vessel performance, fuel efficiency, and anti-fouling efficiencies. Fouling on the hull can 

create drag, increase fuel consumption and potentially cause engine strain. In pipes, fouling can 

block inflowing seawater used to cool machinery. To prevent such problems, vessel operators 

periodically clean underwater vessel parts, and use anti-fouling paints and anti-fouling systems. 

Underwater hull cleaning (as well as the related cleaning of niche areas, propellers, rudders, etc.) 

is a ship husbandry practice that has multiple impacts upon the biofouling vector and the 

potential for ANS introduction. 

 Underwater hull cleaning can be viewed as a hull husbandry practice that helps control 

the biofouling vector for ANS by reducing the density and diversity of fouling organisms on 

vessel hulls. Even vessels with AFCs that are highly effective in preventing and controlling 

biofouling will succumb over time, particularly if the vessels are not operated frequently. 

Underwater hull cleaning can be highly effective in removing fouling organisms from a vessel’s 

hull and other niche areas, especially if performed regularly based upon monitoring of the 

fouling extent. Removing biofouling prior to a voyage also effectively reduces the risk of 

fouling-related ANS being transported to another location. 

 However, underwater hull cleaning using currently-available methods can also discharge 

(release) viable fouling organisms into receiving waters where the cleaning takes place. If these 

fouling organisms were accumulated on the vessel from different ports, then this discharge may 

include ANS. The appropriate use of underwater hull cleaning, to reduce and not promote the 

fouling-related ANS vector, is an important consideration. The VGP includes BMPs to minimize 

discharges from hull husbandry, which are also consistent with the 2011 IMO biofouling 

Guidelines. See Section 6.1 for a full discussion of mitigating effects of the VGP/sVGP on ANS 

in vessel discharges. 

5.1.1.4.3 Abundance and Diversity of Organisms Entering U.S. Coastal Waters on 

Vessel Hulls 

 Hull fouling may be the most underestimated pathway for non-native species 

introductions (Takata et al., 2006). For example, 90% of the 343 marine aquatic invasive species 

in Hawaii are thought to have arrived through hull fouling (Carlton, 2001), while 36% of the 

nonnative coastal marine species established in continental North America could be attributed to 

hull fouling (Bax et al., 2003). Ballast water, by itself, only accounted for 20% (Carlton, 2001). 

Over the last decade, the possible transfer of species by hull fouling has received growing 

attention and it is now recognized as one of the most important pathways of ANS translocation 

(Candries, 2009). 

 Biofouling primarily transports species that have attached sedentary or sessile, benthic 

habits, or species associated with these communities (i.e., living in, between or on other 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-11 

organisms; Minchin and Gollasch, 2003). Analysis of global data indicated that more species 

have life history characteristics associated with biofouling (55 percent) than any other vector 

(Hewitt and Campbell, 2010). The second highest association was with ballast water (31 

percent). However, it is difficult to establish a firm link between an already-established 

introduced species and the vector (or sub-vector) by which it arrived in the new location. 

 In a recent study, Sylvester and MacIsaac (2010) reported that hull biofouling appeared to 

pose a low risk of introducing ANS capable of surviving in the Great Lakes. The exterior 

surfaces of 20 commercial transoceanic vessels were sampled and inspected for invertebrates 

shortly after their arrival in Great Lakes’ ports in 2007 and 2008. The total estimated abundance 

averaged > 170,000 invertebrates per ship belonging to 109 taxa. Abundance was dominated by 

barnacles (51%), cladocerans (19%), bivalves (12%) and amphipods (11%). Sea-chest grating 

and the rudder were hot-spots for biofouling on these ships. Invertebrate diversity and total 

abundance were positively associated with total time spent in port during the prior year as well as 

time spent in Pacific South American ports. Diversity and total abundance were negatively 

related to time spent in high latitudes and sailing speed. Although some live, established invaders 

such as Gammarus tigrinus and Dreissena rostriformis bugensis were found among the 

biofouling organisms, only one individual of a freshwater ANS not yet reported in the Great 

Lakes was detected. This animal’s poor condition and seemingly low population abundance 

indicated the risk of live introduction by this vector was likely quite low. The authors concluded 

that hull fouling associated with international shipping did not appear to be a strong vector for 

ANS introduction into freshwater ecosystems, and was not a management priority in the Great 

Lakes. 

 This same research group sampled and inspected the hulls of 40 transoceanic vessels to 

assess biofouling propagule pressure in Vancouver and Halifax, two dominant coastal ports in 

Canada (Sylvester et al., 2011). Total abundance averaged up to 600,000 invertebrates per ship 

belonging to 156 species. The results varied significantly between the ports, with Vancouver 

receiving much higher abundances and diversity of potential invaders. Propagule pressure was 

related to time spent in previous ports-of-call as well as the time since last AFC application, 

whereas colonization pressure increased with time since last AFC application and with the 

number of regions visited by the ship. Both propagule and colonization pressure were negatively 

related to the time spent at sea and the latitude of ports visited. Hull fouling was found to have a 

strong potential for introduction of many species to coastal marine habitats (unlike fresh water). 

5.1.1.4.4 Variability of Propagule Pressure from Fouling Organisms 

 Defining propogule pressure from fouling organism discharge is complex and must 

consider factors including the origin of the biofouling, organism viability following the voyage, 

hull husbandry practices, the presence and abundance of ANS among the fouling assemblage on 

the hull of a vessel and whether the invasive organisms can be transferred from the vessel to the 

recipient port. 

 Although biofouling progresses in a predictable manner, it is not a uniform process. 

Biofouling is not evenly distributed on submerged portions of vessels, because a vessel's hull is 

not a uniform surface. Certain movement patterns and vessel maintenance practices have been 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-12 

observed to affect the diversity (variety of species) and the quantity of biofouling observed on 

commercial vessels. The factors likely to affect the rate of biofouling, which are also factors 

associated with the risk of ANS transport and introduction, include the following: 

 Immobile periods - It has long been known that ships on active duty tend to be less 

fouled than those which spend much of their time stationary. This is primarily 

because fouling organisms will only attach to slowly moving surfaces, but also 

because vessels with short port residency times generally invest in better anti-fouling 

measures (Candries, 2009). 

 Vessel speed - Vessel speed influences the quantity and diversity of fouling species 

observed on vessels. At high speeds, many organisms are unable to remain attached 

to vessel hulls, or are less able to endure forceful water moving past the surface. Less 

robust organisms may be dislodged or may be unable to survive. Slow speeds are less 

stressful, allowing many fouling organisms to remain attached or continue settling on 

the vessel surface (Takata et al., 2011). Thus, slower moving vessels have been 

observed to accumulate thicker fouling as compared to faster vessels that travel over 

18-20 knots (Minchin and Gollasch, 2003). 

 Voyage duration - Shorter voyages have been observed to be more advantageous for 

the survival of coastal fouling organisms and communities than longer voyages. The 

prolonged exposure to harsh physical conditions of the open ocean during a long 

voyage may be detrimental to fouling organisms, or they may be deprived of food for 

an untenable length of time (Coutts, 1999). Ships with effective AFCs tend to lack 

fouling if the vessel has traveled for 10 days or more in open waters (Johnson et al., 

2007). 

 Anti-fouling system - Commercial vessels regularly use anti-fouling coatings to 

discourage hull growth that can create drag. The age of AFC is strongly related to the 

diversity and amount of fouling organisms on both commercial vessels (Coutts, 1999; 

Floerl et al., 2005). Older coatings have been observed to be less effective, 

presumably because the activity of the biocidal toxins decreases with time. 

 Hull husbandry (defouling) - The amount of time passed since the last hull cleaning 

may be the most important factor contributing to fouling on hulls (Cordell et al., 

2009). Coutts and Taylor (2004) hypothesized that the relatively high levels of 

fouling they observed in archived maintenance videos was because the vessels 

sampled were all near the end of their maintenance cycles. 

 Sea chests, propellers, and other sheltered or irregular underwater ‘niche’ areas - 

Areas that have either higher complexity like heterogeneous surfaces or areas of 

uneven paint, or areas of low water velocity create conditions that encourage fouling 

organisms. In particular, recent research has documented extensive fouling 

communities in the sea chests of some vessels (Dodgshun and Coutts, 2002; Coutts et 

al., 2003). Larger mobile organisms, such as crabs, snails, and shrimp have been 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-13 

found in sea chests, in addition to immobile, attached fouling organisms (Takata et 

al., 2006). 

 Voyage movement patterns - Large estuaries with international shipping serve as 

sources for species that become invasive in other geographic regions. In other words, 

larger ships likely accomplish most of the long-distance transport (primary 

introduction) while commercial fishing and recreational boats likely contribute to the 

transport of invasive species along the coast (secondary introduction) (Johnson et al., 

2007) 

 Environmental factors (salinity, temperature and nutrients) - The accretion of marine 

fouling can be highly variable, depending on geographical location, time of year, and 

seasonal variations in weather. In general, fouling flourishes during warmer months 

and diminishes in cooler months. There are many additional variables, such as the 

availability of nutrients to support the fouling communities. Classic (Woods Hole 

Oceanographic Institution, 1952) and modern (Hellio and Yebra, 2009) reviews of 

marine fouling are available.

 Several other factors contribute to ANS risk from the point of a vessel’s arrival. Because 

fouling communities consist of organisms that are either physically attached or that associate 

with vessel surfaces, ANS must be transferred from the vessel to a recipient port for possibility 

of introduction. This may occur through different mechanisms (Takata et al., 2006): 

 Spawning or Egg Release - Spawning or egg release can expose a recipient site to the 

young of fouling organisms even if the adults are otherwise unable to detach from a 

vessel (Takata et al., 2006).

 Detachment (Drop-off) - Transfer to a recipient port may be accomplished by simply 

dropping off a vessel. Organisms capable of independent detachment associated with 

fouling communities include crabs, fishes, sea stars, shrimp, snails and plankton 

(Foster and Willan, 1979; Dodgshun and Coutts, 2002; Coutts et al., 2003).

 Mechanical Removal (Hull Husbandry) - Hull-fouling organisms or viable fragments 

are dislodged during the process of out-of-water or underwater cleanings. Out-ofwater cleanings during dry dock allow for the containment of materials, including 

fouling organisms that are removed from the vessel hull. Underwater c1eanings, 

however, may allow organisms to enter the water column and to be deposited on the 

seabed. Underwater cleaning, therefore, has increasingly come under scrutiny due to 

concerns about ANS introductions (Takata et al., 2011). 

 Given a suitable habitat, the risks of ANS introduction from hull fouling primarily arise 

when competent organisms are released into a recipient region in the form of adult life stages or 

planktonic propagules. For some species (e.g., certain macroalgae, colonial bryozoans, 

compound ascidians, sponges), dispersal of organism fragments may also be a path to ANS 

establishment in a new habitat (Valentine et al., 2007 cited in Hopkins and Forrest, 2008). 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-14 

5.1.1.5 Other Vessel Discharges Potentially Harboring ANS 

 Several other discharges incidental to the normal operation of a vessel can potentially 

serve as vectors for ANS. These include effluents from chain lockers, seawater cooling systems, 

and use and disposal of live bait. Less is known about these discharges and their potential to 

serve as ANS vectors; however, they are generally considered to be significantly less important 

than ballast water and biofouling. 

 Chain locker effluent is water that collects in the below-deck storage area during anchor 

retrieval. A sump collects the liquids and materials that enter the chain locker and discharges it 

overboard or into the bilge. Chain locker effluent can contain marine organisms including ANS. 

 The surfaces of seawater cooling systems, especially sea chest intakes, can support the 

growth of fouling organisms including ANS. Sea chest intakes have been identified as a niche 

area on vessel hulls that are “hot spots” for biofouling (Section 5.1.1.4.4). 

5.1.1.6 Mechanisms of Vessel-Mediated ANS Invasions 

 The introduction and establishment of organisms into a new environment is far more 

complex than a simple cause-effect relationship, and is so full of variability and uncertainty that 

Carlton and Geller (1993) compared species invasion to a game of ecological roulette. Predicting 

which organisms arrive; their origin; the time of their arrival; and whether they survive, persist, 

spread, and proliferate is exceptionally challenging. Furthermore, predicting the ecological or 

economic impacts of ANS is even more difficult since cause and effect relationships would need 

to be established and well-defined (Carlton, 2001). The difficulty lies in the prediction of which 

organisms will be released, will become established, and what the associated impacts may be, 

even if the likelihood of organisms being released is considerable (USCG, 2012). 

5.1.1.6.1 General Stages/Mechanisms of Species Invasions 

 In terms of ecological processes, invasion proceeds as a series of stages. ANS 

introduction occurs when an organism survives transport by a vector and is released into a new 

environment. Establishment occurs when the introduced organism initially thrives. The 

establishment is successful when the organism is introduced, reproduces, and spreads in its new 

environment (USCG, 2012). Many factors affect the survival, spread, and proliferation of 

introduced organisms, including basic climatic factors, food resources, the nature of the 

reproductive biology of an organism, and the presence or absence of competitors, predators, and 

parasites (Carlton, 1996). Impacts occur when an introduced organism alters the ecology, food 

web, or fisheries, or otherwise disrupts the natural ecosystem or socioeconomics of an 

environment or region. If an introduced species establishes a reproductively viable population, 

those impacts may be amplified (USCG, 2012). ANS that are able to establish reproductively 

viable populations are of particular concern because they are capable of expanding their 

population size and spreading to new locations without further human activity. 

Figure 5-1 summarizes the sources of variation that are likely to influence the 

relationship between propagule supply and invasion outcome (NAS, 2011). Introduction 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-15 

Figure 5-1. Variables Altering the Probability of Establishment of ANS Released in Ballast 

Water and Sediments. Processes in the Right-Hand Column Impact the Outcome of 

Survival, Reproduction and Establishment (NAS, 2011). 

 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-16 

commences at the release or discharge of ballast water. At this stage, critical variables include 

various aspects of propagule pressure: (1) inoculum abundance, density, and frequency, (2) the 

identity, diversity, source and history of the inoculating propagules, and (3) propagule quality. 

Although this figure makes specific reference to introduction via ballast water discharge, similar 

variables are relevant for biofouling and other ANS introductions. The fate of the released 

propagules then becomes influenced by post-discharge processes. Critical variables for postdischarge include both species and environmental traits; both these traits cover a very broad 

range of biological and ecological phenomena. 

5.1.1.6.2 Discharge (Release and Inoculation): Propagule Pressure 

 It is a long-standing presumption in invasion biology that an increase in propagule 

pressure (inoculums abundance, density, and frequency) will increase the probability of a species 

establishing a population in a new region (NAS, 2011; SAB, 2011). Conversely, when propagule 

pressure decreases, the probability of species becoming established should also decrease. This 

assumption regarding risk is supported by a wide body of empirical, theoretical, and 

experimental evidence showing that invasion success increases with an increase in propagule 

pressure, either by a higher concentration of organisms in an inoculation and/or by an increase in 

the frequency of inoculations (e.g., Simberloff, 1989, 2009; Ruiz et al., 2000; Kolar and Lodge, 

2001, Ruiz and Carlton, 2003; Lockwood et al., 2005; Johnston et al., 2008). 

5.1.1.6.3 Post Discharge Processes: Survival, Reproduction and Establishment 

Further influencing the outcome of propagule release is a host of factors that include both 

species traits and the recipient region’s environmental traits. 

Species Traits 

Species traits can profoundly influence the survival, reproduction and establishment of 

invading organisms. These include genetics, life history characteristics, population density and 

abundance, habitat breadth, dispersal and mobility, and environmental matching. Successful 

ANS tend to have specific traits or specific combinations of traits that allow them to outcompete 

native species. In some cases the competition is about rates of growth and reproduction. In other 

cases species interact with each other more directly. Common invasive species traits include: 

 Parthenogenetic (asexual) and sexual reproduction, 

 Fast growth, 

 Rapid reproduction, 

 High dispersal ability (e.g., lecithotrophic or planktonic-dispersing larva that live off 

yolk supplied via the egg), 

 Tolerance of a wide range of environmental conditions, 

 Ability to forage on wide range of food types, 

 Lack of pathogens or predators. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Environmental Traits 

Environmental traits also play a significant role in determining the invasion success of 

ANS. These include biotic characteristics (e.g., biological interactions with resident species) as 

well as abiotic traits such as habitat landscape (scale of habitat fragmentation/connectivity) and 

propagule retention in habitable environments. 

5.1.1.6.4 Modeling the Invasion Process 

Predicting the rate of invasion into specific water bodies from ballast water and/or other 

vectors with a high degree of accuracy is one of the most complex problems in applied ecology. 

NAS (2011) presented the theory underlying the relationship between ballast water organism 

concentration and the risk (probability) of ANS establishment (the risk–release relationship), 

which is focused on the role of propagule pressure. They evaluated several descriptive and 

mechanistic mathematical models that have been developed to express this relationship, 

discussing their data needs as well as other strengths and weaknesses. The models are 

distinguished by whether they consider a single species vs. multiple species. Three of the 

methods discussed are the reaction-diffusion approach, the population viability analysis (PVA), 

and the per capita invasion probability approach. In principle, a well-supported model of the 

relationship between invasion risk and organism release could be used to inform a ballast water 

discharge standard. For a given discharge standard, the corresponding invasion risk could be 

predicted, or, for a given target invasion risk, the corresponding target release level could be 

obtained. 

 Lee et al. (2010) reviewed these same three modeling approaches for evaluating the risk 

of invasion associated with ballast water discharges. All of the models indicate that reduction of 

inoculum densities should significantly reduce the risk (either relative or absolute) of invasion 

from ballast water discharges. The U.S. Coast Guard used PVA to predict effectiveness of 5 

ballast water management/treatment alternatives in their 2012 Ballast Water Discharge Standard 

Final Programmatic Environmental Impact Statement. These models, including their strengths 

and limitations, are discussed in greater detail in Section 6.1.1.1 of this BE. 

 NAS (2011) recommended that discharge standards should be based on models and be 

explicitly expressed in an adaptive framework to allow the models to be updated in the future 

with new information. In the short term, NAS recommended mechanistic single-species models 

to examine risk-release relationships for best case (for invasion)-scenario species (those with life 

histories that would favor establishment with the smallest inoculum density, including fastgrowth, parthenogenetic or other asexual reproductive abilities, and lecithotrophic larvae). The 

greatest challenge in this approach would be converting the results of small-scale studies to an 

operational discharge standard. 

 NAS also recommended development of a robust statistical model of the risk-release 

relationship. The greatest challenge in this approach is the insufficient scope and scale of the 

available data3

. Since long-term historical data on ballast-organism density are limited, the 

 

3

 EPA, in partnership with other federal agencies and others, is currently working within the Aquatic Nuisance 

Species Task Force to develop strategies to fill in key data gaps. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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committee recommends an extremely careful analysis and validation of any proxy variables. 

Models of any kind are only as informative as their input data. In the case of ballast water, both 

invasion risk and organism density discharged from ballast are characterized by considerable and 

largely unquantified uncertainty. 

 At the multi-species scale in particular, the existing data (historical invasion records vs. 

recent ballast surveys) are substantially mismatched in time, and patchy in time, space, and 

taxonomy; current statistical relationships with these or proxy variables are of dubious value. 

5.1.1.7 Examples of ANS Invasions in the U.S. 

Well known examples of ANS or pathogens that have been introduced to U.S. waters 

include Chinese mitten crab, European green crab, hydrilla, European loosestrife, Eurasian water 

milfoil, round goby, melaluca, salt cedar, Viral Hemorrhagic Septicemia (VHS), and zebra 

mussels. In the subsections that follow, specific attention is given to ecosystems and 

environments that have been especially impacted by ANS. 

 Much of the data used to characterize the history of ANS invasion of North American 

waters is highly uncertain. NAS (2001) reviewed a diverse range of such studies, examining the 

patterns in terms of date of first detection, mechanisms of introduction (or vector), native region, 

and source region. These analyses generally involved synthesis of occurrence records, which are 

gleaned from the literature and a diverse range of research programs, instead of an organized 

field-based monitoring program designed explicitly to detect invasions as they occur. 

Consequently, the resulting knowledge about invasions represents an underestimate of the total 

number of ANS that have colonized. Furthermore, the lag-time from invasion to detection is 

unknown; only the date of detection is certain (Ruiz et al., 2000; Solow and Costello, 2004). 

 Although NAS (2011) focused on ANS introduction via ballast water and sediment 

discharge, they note that ballast water is one of many potential vectors that now transport marine, 

estuarine, and freshwater species between continents and oceans. These additional vectors form 

what is known as a polyvectic world (Carlton and Ruiz, 2005) and include vessel fouling (on and 

in many regions of a ship), aquaculture, live bait industries, aquarium and pet industries, the live 

seafood industry, and the availability of hundreds if not thousands of species on the Internet for 

unregulated purchase and distribution to the public at large (Lodge et al., 2006). As a result, it is 

often a challenge to determine which vector or vectors, from a variety of dispersal mechanisms, 

has led to a particular invasion (NAS, 2011). 

5.1.1.7.1 Pelagic Environment 

Microorganisms may constitute a majority of the species found in ballast water (USCG, 

2012). Phytoplankton, particularly diatoms and dinoflagellates, can be especially abundant and 

may cause the harmful algal bloom (HAB) known as “red tides” (Carlton and Geller, 1993; 

Hallegraeff, 1993; NRC, 1996) or produce toxic compounds. Toxins can bioaccumulate in high 

trophic level marine animals, which can accumulate relatively large amounts of the toxin and 

show symptoms of contamination (Bushaw-Newton and Sellner, 1999). ANS introduced via 
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ballast water discharge and other sources may have contributed to the increase in the frequency, 

intensity, and duration of HAB events in waters of the United States (Hallegraeff, 1993). 

5.1.1.7.2 Estuarine Ecosystems 

 A large number of estuarine systems have been highly invaded by ANS. For example, in 

San Francisco Bay over two hundred ANS have been identified, such as the Chinese mitten crab 

(Cohen and Carlton, 1995). Additionally, non-indigenous microorganisms have become 

established in many estuarine waters. The introduction of nonnative pathogens, such as VHS, 

which negatively impact native organisms through parasite or disease transmission, can be 

particularly destructive to the estuarine ecosystem (USEPA, 2008a). 

 For coastal marine ecosystems, California and western North America have received the 

most in-depth analyses of aquatic invasions, with over 250 nonindigenous species of 

invertebrates, algae, and microorganisms having become established in tidal (marine and 

estuarine) waters of California alone. Of these, only about 10% are attributed solely to ballast 

water as a vector, but greater than 50% include ballast water as a possible vector among others 

(NAS, 2011). 

 There have also been extensive introductions of nonindigenous mollusks in estuarine 

ecosystems throughout North America since the early 19th century. Thirty species have become 

established on the Pacific Coast, eight on the Atlantic Coast and one on the Gulf Coast. Nineteen 

of the 30 Pacific Coast ANS occur in San Francisco Bay alone (Carlton, 1992). There, the Asian 

clam has reached high densities at the expense of native biota (Carlton, 1992). The overbite clam 

(Corbula amurensis) spread throughout the waterways surrounding San Francisco Bay within 

two years of being detected in 1986. The clam accounts for up to 95 % of the living biomass in 

some shallow portions of the bay floor. It is believed to be a major contributor to the decline of 

several pelagic fish species in the Sacramento-San Joaquin River Delta, including the threatened 

delta smelt, by reducing the planktonic food base of the ecosystem (Takata et al., 2011). 

 Invertebrate ANS have had severe ecological impacts in many regions of the U.S. The 

elevated densities of Asian clams and other introduced invertebrates have become the primary 

mechanism controlling phytoplankton biomass in portions of the San Francisco Bay. This has 

impacted native zooplankton, shrimp, and fish populations (Cohen and Carlton, 1995). Such 

breakdowns of established ecosystems can result in alterations of physical processes, such as 

sedimentation rates and nutrient cycling. The physical environment may experience elevated 

erosion rates due to burrowing by invertebrate ANS (e.g., isopods, crayfish, and crabs) (Cohen 

and Carlton, 1995). 

 There is relatively little research published on ballast water transport of plant species. 

However, it is known that floating and detached seaweeds and seagrasses may be entrained in 

ballast water (NRC, 1996). It is well established that the consequences of nonindigenous aquatic 

plants have been extensive. The introduction of ANS can have deleterious effects on native 

aquatic plants as well as serious implications beyond the aquatic ecosystem level. In the San 

Francisco Bay estuary, more than 20 nonindigenous plant species have been identified (Cohen 

and Carlton, 1995). The potential adverse impacts of these species include competitive 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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replacement of native cordgrass; altered habitat for wetland plants and animals; altered sediment 

dynamics; and loss of shorebird foraging habitat (USCG, 2012). 

 Estuarine wetlands have been invaded and adversely affected by animal and plant ANS 

from ballast water and other sources (USEPA, 2004a). For example, the Chinese mitten crab, 

potentially introduced via ballast water discharge, has affected native invertebrates and the 

ecological structure of estuarine wetland communities in California. It disrupts fishing operations 

by competing with and preying on native species, damaging native habitats, and reducing 

biodiversity (Cohen and Carlton, 1997). The current species composition of U.S. estuarine plants 

includes many ANS that have become widely established over time. In the waters of Florida 

alone, 23 nonindigenous aquatic plant species have become established (USCG, 2012). 

5.1.1.7.3 Freshwater Ecosystems 

U.S. freshwater ecosystem species have been significantly affected by ANS 

introductions. For example, ANS have become a significant component of the food web in the 

Great Lakes with 162 ANS identified by 2001 (NOAA, 2004). Transoceanic shipping activities 

are attributed with 55% to 70% of an estimated 56 aquatic ANS invasions recorded in the Great 

Lakes since 1959 (Bailey et al., 2011). They assembled data on dates of discovery of shipmediated aquatic ANS reported in the Great Lakes after the opening of the modern St. Lawrence 

Seaway in 1959. Their analysis revealed 34 aquatic ship-mediated ANS reported from the Great 

Lakes after that date. The rate of aquatic ANS discovery was relatively linear between 1959 and 

the mid-1980s, after which time it began to increase. The peak number of discoveries occurred in 

1992 when six ANS were reported, including five parasitic species associated with the Eurasion 

ruffe; the discovery rate begins to decline rapidly after the peak. The authors note that this 

decline in ANS discovery corresponds with two to six-year time lags following the inception of 

ballast water management practices. Since 2000, shipping activities have been responsible for 

three of eight (37.5%) aquatic ANS introductions and no new species have been reported since 

2006; this is the first time there has been a four-year gap in ship-mediated aquatic ANS 

discoveries since 1974-1977 (Bailey et al., 2011). 

 In the Mississippi River, more than 100 ANS have been identified across at least nine 

taxonomic groups (USGS, 2004). In the lower and middle Columbia River alone, 134 

nonindigenous species have been identified (USGS, 2009). North America's rivers and stream 

species are being extirpated five times faster than animals living on land and three times faster 

than marine mammals (American Rivers, 2005). This is due in great measure to the threat posed 

by ANS to such fauna and the ease with which they spread in freshwater ecosystems (USCG, 

2012). 

 Perhaps the best-known example of freshwater invasion is the zebra mussel in the Great 

Lakes and Mississippi River. This mollusk attaches itself to surfaces in such high densities that it 

can clog pipes and foul other important structures, such as boat hulls or buoy bases. Zebra 

mussels also have the capacity to crowd out native mollusk species or interfere with such basic 

functions as respiration, reproduction, feeding, growth, and movement. Zebra mussels are filter 

feeders and can remove algae from the water column that other native species depend on as a 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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food source and, therefore, zebra mussels outcompete native (and sometimes endangered) 

mollusks and other filter feeders. 

 Native mollusk communities have been affected by ANS – one estimate is that another 

127 freshwater mussel species will become extinct in the next 100 years if no conservation 

efforts are initiated (Ricciardi and Rasmussen, 1999; Williams and Neves, 2003). The Eurasian 

zebra mussel and the Asiatic clam, two alien nonunionoid species, have caused significant harm 

to North American unionoids (Lydeard et al., 2004). By attaching to native mussels such as the 

northern riffleshell in great numbers, zebra mussels make it difficult for the mussel to move and 

feed properly, thereby suffocating and killing the native species (USFWS, 1997). Studies of 

zebra mussels on unionids in Great Lakes waterways have confirmed that unionid mortality may 

approach 100% when unionids are heavily encrusted with zebra mussels (Schloesser et al., 

1998). 

 Other non-native species may also impact unionid survival through the reduction or 

redistribution of native fishes, of which the larval (glochidia) life-stage is parasitic. Nonnative 

fish species such as the Eurasian ruffe (Gymnocephalus cernuus) and round goby (Neogobius 

melanostomus) can completely displace native fish, thus causing the functional extirpation of 

local unionid populations (USEPA, 2007a). Glochidia of freshwater mussels generally display 

varying degrees of host specificity. Closely related mollusks have been shown to use banded 

sculpin, as well as dusky, redline, and spotted darters (Yeager, 1986). Other possible hosts 

include: banded sculpin, greenside darter, logperch, redline darter, snubnose darter, and spotted 

darter (Yeager and Saylor, 1995). 

 In 2005, a freshwater strain of VHS was discovered in freshwater drum from Lake 

Ontario, and subsequently it was found in numerous freshwater species throughout much of the 

Great Lakes. It has also been found in preserved samples from as far back as 2003. Since 1988 

the virus, a finfish pathogen, was only known to exist in marine fish off both coasts (USDA, 

2006). Genetic studies have determined that the strain in the Great Lakes is most closely related 

to the North Atlantic strain (Gagné et al., 2007). Ballast water is a plausible vector; however, 

there is no way to definitivelydetermine how this pathogen arrived in the Great Lakes. (USCG, 

2012). 

 Eurasian watermilfoil (Myriophyllum spicatum) is a stringy and submerged plant that is 

highly invasive and aggressively competes with native plant communities, reducing biodiversity. 

Dense mats of watermilfoil have less value as a food source for waterfowl than the native plants 

it replaces (Aiken et al., 1979). Although fish may initially experience a favorable edge effect, 

overabundant growth of watermilfoil negates any short-term benefits that it may provide fish in 

healthy waters, because its high densities cause a lower abundance and diversity of invertebrates 

that serve as fish food (Keast, 1984). The growth and aging of the thick watermilfoil vegetation 

also degrades water quality and depletes dissolved oxygen levels (Engel, 1995; Honnell et al., 

1992). 

 The common reed (Phragmites australis) is is another vigorous plant competitor. It can 

grow up to more than four meters tall and form dense monospecific stands. Common reed is 

native to the United States, but more invasive European strains may have been unintentionally 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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introduced in ships’ ballast (Saltonstall, 2008). Involuntary transport of Phragmites seeds and 

rhizome fragments by commercial and recreational vessels can promote the spread of this weed. 

Other aquatic nuisance species that pose a similar threat include the purple loosestrife (Lythrum 

salicaria) and the yellow iris (Iris pseudacorus). Both taxa can out-compete native plants and 

spread through transport of seeds and propagules by vessels. 

 Once established in a new environment, fish can spread over broad geographic areas. A 

classic example is the Eurasian ruffe (Gymnocephalus cernuus), which was introduced via 

ballast water to the St. Lawrence River in the mid-1980s. Since its introduction, it has spread 

rapidly through rivers, bays, and lakes in the Great Lakes area. Furthermore, the ecological and 

geographical expansion of the ruffe has injured native fish populations (OTA, 1993). Other 

nonindigenous fish, such as the round goby (Neogobius melanostomus), the common carp 

(Cyprinus carpio), the alewife (Alosa pseudoharengus), the white perch (Morone americana), 

and the sea lamprey (Petromyzon marinus) have spread rapidly and caused major environmental 

and economic problems (USCG, 2012). 

 Competition and predation by introduced non-native species may have been factors that 

contributed to the decline of the Rio Grande silvery minnow within its historic range (USFWS, 

2007), and their survival continues to be threatened by interactions with non-native fishes 

(NatureServe, assessed April 2008). The intentional or accidental introductions and transfers of 

indigenous and non-indigenous minnows, e.g., live minnows from other drainages, may threaten 

wild Rio Grande silvery minnow populations by imposing genetic threats, increasing competition 

for food or habitat, or spreading diseases. It is also possible that rapid increases in abundance of 

other non-indigenous species (e.g., guppy Poecilia reticulata, goldfish Carassius auratus) may 

affect Rio Grande silvery minnow food sources (e.g., diatoms, algae) and/or introduce new 

predators to compete for resources of Rio Grande silvery minnow. 

5.1.1.7.4 Mechanisms by which ANS Impact Native Species 

ANS threaten the diversity or abundance of native species and the ecological stability of 

the aquatic ecosystems they infest. They can permanently reduce biodiversity by preying on, 

parasitizing, out-competing, causing or carrying diseases, or altering habitats of native species 

(Convention on Biological Diversity, 2005). Marine ANS can change food webs and disrupt 

ecosystem services provided by marine wetland plants (salt marshes, sea grasses). Many of these 

impacts were noted above in the examples of ANS invasions. This section describes specific 

mechanisms by which ANS impact native species. 

5.1.1.7.5 Competition 

An introduced species might become invasive if it can outcompete native species for resources, 

such as nutrients, light, physical space or food. If the introduced species evolved under great 

competition or predation, the new environment may host fewer able competitors, allowing the 

invader to proliferate quickly. For example, zebra mussels are capable of reaching such high 

densities that they crowd out or encrust native mollusk species; furthermore, their filtration rates 

are so high that they outcompete native filter feeders for available phytoplankton.As an 

additional example, a variety of coral species have been introduced into United States waters via 
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ballast water discharge and other sources. Nonindigenous coral species can harm native coral 

species by colonizing the native species’ habitat. This is a competition between invasive and 

native species over limited, overlapping resource needs, with the invaders ultimately replacing 

native species within the ecosystem. 

5.1.1.7.6 Infection 

 Introduction of nonnative pathogens, such as viral hemorrhagic septicemia (VHS), can 

negatively impact native organisms through parasite or disease transmission. VHS is caused by 

the Viral hemorrhagic septicemia virus, a finfish pathogen. It afflicts over 50 species of 

freshwater and marine fish in several parts of the northern hemisphere (Disease Factsheets: Viral 

Hemorrhagic Septicemia. Iowa State University, The Center for Food Security & Public Health. 

(http://www.cfsph.iastate.edu/Factsheets/pdfs/viral_hemorrhagic_septicemia.pdf, accessed June 

15, 2012). In 2005, a freshwater strain of VHS was discovered in freshwater drum from Lake 

Ontario, and subsequently it was found in numerous freshwater species throughout much of the 

Great Lakes. It has also been found in preserved samples from as far back as 2003. Since 2005, 

massive die-offs have occurred amongst a wide variety of freshwater species in the Great Lakes 

region. 

As another example, sturgeon species appear to be susceptible to viruses enzootic to the 

west coast of the U.S., and fish introductions could further spread these diseases (NatureServe, 

accessed April 2008). 

5.1.1.7.7 Toxicity 

HAB can produce toxic compounds, including brevetoxin, saxitoxin and microcystins. 

Toxins can bioaccumulate in high trophic level marine animals, which can accumulate relatively 

large amounts of the toxin and show symptoms of contamination (Bushaw-Newton and Sellner, 

1999). The adverse effects of HAB on marine mammals can range from cell and tissue damage 

to organism mortality. Immune system responses have been affected by brevetoxin exposure in 

the endangered Loggerhead sea turtle. 

Additional marine mammal species, like the endangered North Atlantic Right Whale, 

have been exposed to neurotoxins by preying on highly contaminated zooplankton (Durbin et al. 

2002). The summertime habitat of the North Atlantic Right Whale overlaps with seasonal 

blooms of the toxic dinoflagellate Alexandrium fundyense. Foraging right whales will ingest 

large concentrations of contaminated copepods, resulting in affects on respiratory capabilities, 

feeding behavior, and ultimately the reproductive condition of the population (Durbin et al. 

2002). 

5.1.1.7.8 Altered Food Web 

Many of the negative affects of ANS are related to changes in community structure. 

Species invasion causes a breakdown in structure and rapid reorganization (Sanders et al. 2003). 

ANS can exert bottom-up or top-down controls. Many ANS are filter feeders which, upon 

reaching high densities, can deplete phytoplankton that serve as the diet for many native species 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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(native zooplankton, shrimp, and fish populations), including their juvenile life stages. These 

effects may continue through the food web to fish, for example reducing the biomass of 

planktivorous fish. 

 Invasive species may be an inferior food. An example is the invasive diatom Melosira, 

which at certain times in the year can be the most abundant species of phytoplankton. This 

diatom grows in long chains and is very difficult for zooplankton to graze on; thus the change in 

composition and abundance of zooplankton may also be tied to the increased importance of this 

diatom. Bythotrephes longimanus, the spiny water flea, is another invasive species that may be 

an inferior food for planktivores in the Great Lakes.

5.1.1.7.9 Predation 

Invasive species may be highly effective predators capable of reducing the abundance of 

various life history stages of native species. For example, the endangered Columbia spotted frog 

is particularly susceptible to displacement or predation by introduced species. For example, 

various studies have documented the vulnerability of Columbia spotted frogs to nonnative 

salmonid and Centrarchid (e.g., bass) species (Bull and Marx, 2002; Pilliod and Peterson, 2001; 

Werner et al., 1998). Other non-native fishes thought to be potentially important predators of 

Columbia spotted frogs include char and goldfish (Carrasius auratus) (Amphibiaweb.org 

website, accessed April 17, 2008). Invasive crayfish and American bullfrogs (R. catesbeiana) 

might also be aggressive predators of various life history stages of spotted frogs, including eggs 

and tadpoles (Reaser, 1997). 

 The effects of introduced species on the listed California Freshwater Shrimp are mainly 

associated with predation. The shrimp is prey for native fish species at all life stages. The 

riparian habitat protects the shrimp from many native species, as do the intermittent pools that 

the shrimp also inhabit. Introduced species are a threat to the populations of S. pacifica 

particularly in areas where native fish species are not abundant. These pools sometimes are of 

lesser water quality which protects the shrimp from many native species. However, the nonnative fish species, green sunfish (Lepomis cyanellus), is capable of surviving at extreme 

conditions, including high temperatures, low oxygen, and high alkalinities (USFWS, 1998). 

5.1.1.7.10 Altered Biogeochemistry and Physical Habitat 

 Invasive species can affect water quality (negatively or positively) in marine, estuarine, 

and riverine freshwater environments by altering processes such as sedimentation rates and 

nutrient cycling. Introduced non-native algal species from ballast water (as well as other sources) 

combined with nutrient overloading may increase the intensity and frequency of algal blooms. 

An overabundance of algae can degrade water quality upon bacterial decomposition, which 

depletes oxygen levels in an ecosystem. Oxygen depletion can result in “dead zones,” murky 

water, seagrass and coral habitat degradation, and large-scale fish kills (Deegan and Buchsbaum, 

2005). 

 Breakdowns of established ecosystems can result in alterations of physical habitat. The 

physical environment may experience elevated erosion rates due to burrowing by invertebrate 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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ANS. ANS can also alter the environment to favor introductions of additional nonnative species. 

Simberloff and Von Holle (1999) referred to this positive feedback loop as “invasional 

meltdown.” A recent series of invasions by euryhaline organisms from the Black and Caspian 

seas might be the start of an invasional meltdown in the North American Great Lakes (Rahel, 

2002). It seems likely that zebra mussels have altered the benthic environment of the Great Lakes 

so as to facilitate invasions by additional exotic species. Zebra mussels have also increased the 

habitat complexity on lake floors, providing crevices in which invertebrates live. This increase in 

complexity, together with the nutrition provided by the waste products of mussel filter-feeding, 

increases the density and diversity of benthic invertebrate communities. 

5.1.1.8 Documented Impacts of ANS on Listed Species 

Some endangered species face threat from the combined impact of ANS introduction and 

the existing environmental circumstances (USCG, 2012). For example, almost 40 native mussel 

species occur in the Mississippi River, some of which are federally listed as threatened or 

endangered (USFWS, 2003). The zebra mussel threatens some of these indigenous species of 

mussel with extinction (USCG, 2012). 

 ANS have been identified as a contributing factor in the listing as threatened or 

endangered of more than 50% of fish species and 33% of invertebrates, which includes mollusks 

and crustaceans (USCG, 2012). Shortnose sturgeon (Acipenser brevirostrum), which are 

endangered and under many threats, amongst them habitat degradation and dredging operations. 

It is also anticipated that rapid increases in abundance of other non-indigenous species (e.g., 

Asian clams, zebra mussels, blue and flathead catfish) in some rivers will affect sturgeon prey 

and/or introduce new predators to compete for resources of shortnose sturgeon (NMFS and 

USFWS, 1998). 

 Over 145 nonnative species have become established in the North American Great Lakes 

(Mills et al., 1993). Especially noteworthy is that since 1985, 70% of the invading species are 

native to fresh and brackish waters of the Ponto-Caspian region (Black, Caspian, and Azov seas) 

(Ricciardi and Maclsaac, 2000). Some of these species have achieved high abundance and now 

play a major role in Great Lakes food webs. Examples include ruffe Gymnocephalus cemuus, 

round goby Neogobius melanostomus, tubenose goby Proterorhinus marmoratus, zebra mussel, 

quagga mussel Dreissena bugensis, and the amphipod Echinogammarus ischnus. Most of the 

invasions resulted from ship ballast water release (Rahel, 2002). 

5.1.1.8.1 Zebra Mussel Impacts on Native Mussels in Great Lakes and Mississippi 

River 

 Freshwater mussels in the families Margaritiferidae and Unionidae are worldwide in 

distribution but reach their greatest diversity in North America with 281 species and 16 

subspecies (Williams et al., 1993). They are the most imperiled freshwater fauna with 12% of the 

taxa listed as probably extinct and 60% considered endangered, threatened, or of special concern 

(Ricciardi et al., 1998). During the twentieth century, the most important source of imperilment 

was destruction of habitat by damming, dredging, and channelization of rivers, especially in the 

southeastern United States (Rahel, 2002). 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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 In the 1990s, a significant new threat was added with the establishment of the zebra 

mussel that smothered the shells of other mollusks and competed with them for food (Nalepa et 

al., 1996). The biological impacts of zebra mussels have the potential to harm native mussels in 

North America by interfering with their feeding, growth, movement, respiration, and 

reproduction. This species has rapidly spread throughout the Great Lakes and the Mississippi 

River basin, often reaching densities in excess of 3,000 individuals per square meter and 

extirpating native mussel species within 4 to 8 years. Ricciardi et al. (1998) projected that if the 

current rate (as of 1998) of spread continues, the zebra mussel will accelerate the regional 

extinction rates of North American freshwater mussels by ten-fold and will threaten the existence 

of over 60 endemic species in the Mississippi River basin. 

 Researchers are observing some of these effects as they study interactions between zebra 

mussels and native mussels in the Great Lakes. In one study, biologists found that where zebra 

mussel densities were highest, in Lake St. Clair and in the western basin of Lake Erie, native 

mussels had declined after only two years of zebra mussel colonization (Bensen, 2012) and other 

studies have shown an inverse correlation between zebra mussel biomass and the density of 

native mussels. 

5.1.1.8.2 Negative Effect of Zebra Mussel on Foraging and Habitat Use by Lake 

Sturgeon 

 Zebra mussels are also believed to negatively impact native fish populations. Among 

benthic-feeding fish, lake sturgeon (Acipenser fulvescens) are of particular concern. Lake 

sturgeon are threatened or endangered throughout much of their range. This species is native to 

lakes and large rivers in the Atlantic watershed of North America including the Hudson Bay, 

Laurentian, and Gulf of Mexico catchments (Lee et al., 1980). Through much of this range, lake 

sturgeon populations have been reduced from viable populations to threatened or endangered 

status owing to overfishing and habitat destruction (Auer, 1999). Zebra mussels now co-occur 

with lake sturgeon over much of their range, including the Laurentian Great Lakes and portions 

of the Mississippi and Hudson Bay catchments, and may represent a novel threat to lake 

sturgeon. Juvenile sturgeon use sandy and silty habitats extensively during their growth. Invasive 

zebra mussels change the nature of these sandy and silty habitats because they settle on and coat 

the habitat with the shells of living and dead individuals. McCabe et al. (2006) assessed juvenile 

lake sturgeon habitat choice in laboratory experiments, and zebra mussel impact on the foraging 

success of juvenile lake sturgeon on three different prey species was measured. Sturgeon avoided 

the zebra-mussel covered habitat more than 90% of the time. This combination of zebra mussel 

avoidance and reduced foraging in the presence of zebra mussels was suggested to be detrimental 

to sturgeon restocking programs utilizing smaller sturgeon in zebra-mussel-infested waterways. 

5.1.1.9 Conclusion Regarding Risk of ANS in Vessel Discharge Vectors 

Existing ANS are a persistent problem in U.S. coastal and inland waters. In coastal 

environments, commercial shipping is the most important means of introducing new ANS, and 

unmanaged ballast water discharge and biofouling are the vectors responsible for the 

introduction of the majority of ANS in the U.S. ANS pose several dangers to aquatic ecosystems, 

including outcompeting native species, damaging habitat, changing food webs, and altering the 

chemical and physical aquatic environment. Numerous studies have concluded that the reduced 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-27 

discharge of viable organisms capable of establishing a viable population of the organism in U.S. 

waters reduces the risk of invasions. While it is presently not possible to calculate the risk of 

ANS invasion associated with specific ANS concentrations in ballast water discharges, EPA 

believes that the two permits (VGP/sVGP) will reduce the propagule pressure substantially 

associated with vessel discharges, which will significantly reduce the risk that new ANS 

introductions pose to listed species. See Section 6.1 for a full discussion of mitigating effects of 

the VGP/sVGP on ANS in vessel discharges. 

5.1.2 Pathogens

Several [human] pathogens (E. coli, enterococci, fecal coliform) are found at levels 

exceeding screening level benchmarks in permitted discharges from covered vessels, particularly 

in graywater and bilgewater (see Section 3.2.3.3). These and other pathogens (Vibrio cholerae, 

Clostridium perfingens, Salmonella spp. Cryptosporidium spp., and Giardia spp.) as well as a 

variety of viruses have also been associated with ballast water discharges (Knight et al., 1999; 

Reynolds et al., 1999; Zo et al., 1999). 

Although pathogens can be harmful to humans via ingestion at relatively low 

concentrations, if and at what level these pathogens may affect aquatic and aquatic-dependent 

organisms is unknown at this time. EPA is not aware of any outbreak of pathogenic disease 

among aquatic or aquatic-dependent species from vessel discharges. Fish and shellfish are 

known vectors of pathogens resulting in human impacts when consumed, but appear to be 

largely unaffected themselves. Since it is currently not possible to separate infections in aquatic 

and aquatic-dependent animals due to [human] or any other pathogens contributed from vessel 

discharges versus infection from existing natural background conditions within a waterbody, and 

since it is highly improbable that any infection could occur at the levels detected in vessel 

discharges, EPA discounts any risk to pathogens in this BE to the listed species for which the 

analysis applies (Appendix E). 

5.1.3 Oil and Grease

 Concentrations of oil and grease in stern tube packing gland effluent, bilgewater, deck 

washdown, engine wet exhaust effluent, fish hold effluent, fish hold cleaning effluent, and 

graywater have the potential to exceed the current 15 mg/L U.S. Coast Guard discharge standard 

screening level benchmark. Oil and grease is measured as hexane extractable material (HEM) 

while petroleum hydrocarbons are measured as silica gel treated hexane extractable material 

(SGT-HEM). Within the oil and grease component measured by SGT-HEM are toxic petroleum 

and gasoline constituents as well as degradates such as polycyclic aromatic hydrocarbons 

(PAHs) and benzene, ethylene, toluene, and xylene (BETX). The analysis of possible effects 

from these toxic constituents of oil and grease are addressed quantitatively in Section 5.3.4.1 

below. This subsection provides a brief qualitative analysis of the possible effects from the nontoxic components of oil and grease (e.g., vegetable oils and “organic” grease). 

 Both petroleum and non-petroleum oils have similar properties that can harm wildlife 

when spilled into the environment (USEPA, 1997). Ingested oil or inhaled fumes [generally from 

petroleum] can be detrimental to seabirds; however, most mortality is caused by oiled feathers. 

Oil that sticks to fur or feathers can cause a multitude of problems (AMSA, accessed April 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-28 

2008). Oil in general readily adheres to the plumage of seabirds and can reduce the insulation 

and waterproofing properties of their feathers, often leading to hypothermia. Birds may become 

easy prey, as their oil matted feathers often inhibit their ability to fly away. Birds can also 

become dehydrated and can starve as they give up or reduce drinking and foraging for food. 

While some of the adverse effects on sea birds, marine mammals and turtles can be caused by 

crude petroleum oil or bunker fuel, they are more commonly caused by refined oil products 

(AMSA, accessed April 2008). 

 In general, because the non-petroleum based oil and grease (i.e., non-volatile 

hydrocarbons, vegetable oils, animal fats, waxes, and greases) nominally represented by HEM 

minus SGT-HEM is both biodegradable and far less toxic to aquatic and aquatic-dependent 

wildlife (USEPA, 2011a), EPA presumes any risk to listed species considered in this BE from 

these oil and grease components to be “remote”4

 (see also Section 6.2.2). 

5.1.4 Biochemical Oxygen Demand (BOD)

BOD is a measure of the oxygen used by microorganisms to oxidize the organic matter 

present in the water. Organic matter in wastewater exerts an oxygen demand in receiving waters, 

thereby depressing dissolved oxygen concentrations. Low dissolved oxygen levels (hypoxia) can 

impair animal growth or reproduction, and the complete lack of oxygen (anoxia) will kill aquatic 

organisms. If there is a large quantity of organic waste in water, there will also be substantial 

bacteria present working to decompose this waste. In this case, the demand for oxygen will be 

high (due to all the bacteria) so the BOD level will be high. As the waste is consumed or 

dispersed through the water, BOD levels will begin to decline. Vessel discharges that exert 

relatively high oxygen demand and the associated potential to depress DO concentrations in 

receiving waters include fish hold effluent, bilgewater, and graywater. Excessive levels of BOD 

in these discharges exceed the screening level benchmark of 30 mg/L,5

 but due to the substantial 

reduction in BOD that will be achieved via issuance of the two permits (see Section 6.2.3), EPA 

presumes any risk to listed species considered in this BE from BOD (and subsequent low DO in 

receiving water) to be “remote”. 

5.2 METHODOLOGY FOR THE QUANTITATIVE EFFECTS ANALYSIS OF TOXIC AND NONCONVENTIONAL POLLUTANTS WITH TOXIC EFFECTS

 A quantitative analysis is used in this BE to evaluate the potential for select pollutants 

(i.e., pollutants with toxic effects) to adversely affect aquatic and aquatic-dependent listed 

species and their critical habitats. This analysis is driven largely by EPA’s ability to calculate and 

compare risk quotients for specific pollutants before (pre-) and after (post-) issuance of the 2013 

VGP and sVGP. Risk quotients provide a means for evaluating the level of risk to a species from 

either individual pollutants or certain mixtures of pollutants where toxicity is additive (i.e., 

metals and PAHs). Calculating risk quotients on a pre- and post-permit basis is used to illustrate 

 

4

 For the purpose of this BE, EPA established a sliding scale to describe the risk conclusion and overall health 

concern from a given pollutant. EPA uses the term “remote” to describe the lowest possible risk level above no 

effect and presumes that the pollutant does not present a health risk to listed species, See Section 5.2.3 for further 

discussion of the risk scale and how it is applied in the quantitative pollutant analysis. 

5

 The screening level benchmark for BOD is based on the 1984 secondary treatment limit for publically owned 

treatment works (see 49 FR 37006, Sept. 20, 1984). 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-29 

if and by how much the specific control measures implemented as part of the permits reduce 

pollution from permitted discharges. EPA fully expects any mitigation of pollutants from the 

various discharges realized via the issuance of the permits to improve water quality, and at the 

same time, minimize harm to listed species and their critical habitats (see Section 6). 

The general risk paradigm used to support the quantitative effects analysis in this BE is one 

where the risk quotient (RQ) is defined as: 

ൌ ࡽࡾ

࡯ࡱ

ࢀࡱࢀ࡯

Equation 5-1 

Where: 

RQ = Pollutant- and species-specific risk quotient. 

EC = Modeled pollutant-specific exposure concentration before (pre-) and after 

(post-) issuance of the 2013 VGP and sVGP. 

CTET = Chronic toxicity effect threshold for a given species/taxon (or representative 

surrogate species/taxon) exposed to that pollutant. 

As described in Section 5.2.1 and Appendix G, EPA estimated pre- and post-permit exposure 

concentrations (ECs) for hypothetical estuary and river harbors that contain RAA-specific vessel 

populations and receive their associated total discharge pollutant loads. The estimated pollutantspecific concentrations within the hypothetical estuary and river harbors are used in the risk 

equation (in comparison with CTETs) to estimate risk and support both the direct and indirect 

effects analysis of individual pollutants on the 82 RAA aquatic and aquatic-dependent listed 

species and their critical habitats (see Section 5.3 – Pollutant-Specific Risk Summaries, below). 

These species were identified in Section 3.4 and described in detail in Appendix F. The results of 

the analysis is then used to inform EPA’s effects determination for all listed aquatic and aquaticdependent species and their critical habitats that may be affected by the VGP and sVGP 

(Appendix E). For aquatic species, risk is estimated based on laboratory-based chronic toxicity 

test data from water column-only exposure and, when applicable, from exposure to additional 

routes which may result in greater toxic effects (e.g., combination of waterborne and dietary 

toxicity as measured via pollutant residues in whole body tissue). For aquatic-dependent bird and 

mammal species, risk is estimated from both dietary (prey) and waterborne (drinking water) 

toxicity in fresh water, and from dietary-only exposure in salt water, assuming that aquaticdependent birds and mammals do not drink salt water. 

 The methodology used to support the quantitative analysis described herein is predicated 

on principles established in EPA’s Draft Methodology for Conducting Biological Evaluations of 

Aquatic Life Criteria; Methods Manual, dated March 2005 (USEPA, 2005a). Additional details 

regarding estimation of exposure concentrations (ECs) and chronic toxicity effect thresholds 

(CTETs) are as follows. 

5.2.1 Hypothetical Harbor and Estimation of Exposure Concentrations

For the purpose of the BE, EPA selected simple screening-level models to provide a “big 

picture” assessment of the overall potential for pollutants in vessel discharges to impact listed 

species in estuarine and inland waters. EPA used the models to estimate exposure concentrations 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-30 

in the receiving water from vessel discharges covered under the VGP and sVGP to support the 

quantitative effects analysis described in Sections 5.2.2 to 5.2.4 below. 

EPA selected the “fraction of freshwater model” to calculate receiving water 

concentrations in a hypothetical estuarine harbor and a dilution equation to estimate receiving 

water concentrations in a hypothetical river harbor. Appendix G provides detailed descriptions of 

the model selection process for the BE and the equations used in the identified models. EPA 

chose to model a hypothetical harbor environment6

 to evaluate the range of potential receiving 

water concentrations (i.e., exposure concentrations) that may occur given varying assumptions 

for receiving water characteristics (e.g., flow, salinity, flushing time) and vessel populations 

present. EPA used a range of water body flow, salinity, vessel populations, and loading 

assumptions to explore different “likely” and “worst-case” scenarios pollutant exposure 

concentrations resulting from vessel discharges covered under the VGP and sVGP. 

As inputs to the model, EPA developed a vessel population scenario for each RAA 

considered in the BE and collected receiving water characteristic data from a variety of estuaries 

and rivers where vessels covered under VGP and sVGP are known to travel. EPA then modeled 

numerous scenarios combining the different vessel populations in different hypothetical harbors 

to represent a range of environmental conditions potentially observed within the action area 

applicable to this BE. 

5.2.1.1 Hypothetical Harbor Scenarios 

Given the wide variety of coastal and river harbor environments present in the action area, 

EPA developed several hypothetical harbors to represent the range of environmental conditions 

where threatened and endangered species may be impacted by vessel discharges covered under the 

VGP and sVGP. To develop model input values that represented realistic environmental conditions, 

EPA identified and collected environmental data on 11 estuarine harbors and 9 river harbors (Table 

5-3) that represented a geographically and environmentally diverse group of water bodies and had 

the potential for a high density of vessels covered under VGP and sVGP. 

Table 5-3. River and Estuary Harbors Selected for Model Input Parameter Development 

RAA City Name State Estuary Name River Name

Estuary 

Harbor 

 Boston Massachusetts Boston Inner 

Harbor Charles River and Mystic River 

 Charleston South Carolina Charleston Harbor Cooper River and Ashley River 

 Coos Bay Oregon Coos Bay Coos River 

 Houston Texas Galveston Bay San Jacinto River and Buffalo Bayou 

 Juneau Alaska Auke Bay Mendenhall River and Indian River 

 Miami Florida Biscayne Bay Miami River and Little River 

Mobile Alabama Mobile Bay Mobile River 

 New York New York Upper and Lower 

New York Harbor Hudson River 

 

6 For this analysis, the “harbor environment” refers to a large body of water that could potentially have upto 370 

VGP vessels present and up to 1000 sVGP vessels simultaneously discharging. EPA assumed that the harbor area 

included the immediate port area and surrounding waters within two to seven miles from the port depending on the 

RAA. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Table 5-3. River and Estuary Harbors Selected for Model Input Parameter Development 

RAA City Name State Estuary Name River Name

Norfolk Virginia Craford Bay Elizabeth River and James River 

 San 

Francisco California San Francisco Bay 

Sacramento River and San Joaquin 

River 



Seattle California Puget Sound 

Duwamish Waterway and Dunguess 

River 

River 

Harbor 

Cincinnati Ohio Ohio River 

Decatur Alabama Tennessee River 

 Duluth Minnesota St. Louis River 

Lewiston Idaho Snake River 

Memphis Tennessee Mississippi River 

Peoria Illinois Illinois River 

Pittsburgh Pennsylvania Ohio River 

 St. Louis Missouri Mississippi River 

St. Paul Minnesota Mississippi River 

Using water body characteristic data from the 11 estuarine harbors identified in Table 

5-3, EPA identified two types of estuarine systems in commonly found in the port areas: 

 Estuaries where tidal influence is the primary driver for mixing in the estuary as 

indicated by a lower river flow and higher salinity value; and 

 Estuaries where the freshwater inflow is the primary driver for mixing in the estuary 

as indicated by a higher river flow and lower salinity value. 

Based on this analysis, EPA developed the two hypothetical estuary harbor scenarios 

presented in Table 5-4 for the BE effects analysis. 

Table 5-4. Hypothetical Estuary Harbor Scenarios and Input Values 

Hypothetical Estuary 

 Harbor Scenario

Harbor Salinity, Sx

(PSU)

Ocean Salinity, Ss

(PSU)

River Flow into Estuary, Qfw

(m3/day)

Estuary Harbor Scenario 1 31.1 35 1,160,000 

Estuary Harbor Scenario 2 13.4 35 49,100,000 

For the river harbor model, the dilution equation requires the average annual river flow 

rate (Qriver) to calculate a receiving water concentration. EPA selected the minimum and 

maximum river flow rates from the nine river harbors identified in Table 5-3 to represent the 

bounding conditions for the hypothetical river harbors, resulting in two hypothetical river harbor 

scenarios for the BE effects analysis (Table 5-5). 

Table 5-5. Hypothetical River Harbor Scenarios and Input Values 

Hypothetical River 

Harbor Scenario Model Parameter Model Input Value Units

River Harbor Scenario 1 River Flow (Qriver) Minimum 9,000,000 m3/day 

River Harbor Scenario 2 River Flow (Qriver) Maximum 1,400,000,000 m3/day 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Appendix G provides detailed descriptions of the harbor characteristics used to develop the 

hypothetical estuary and river harbors used in the effects analysis. 

5.2.1.2 RAA Loading Scenarios 

Based on the vessel types, discharges, and corresponding pollutants selected for detailed 

evaluation in the BE (see Section 3.2.4), EPA identified 32 pollutants to include in the modeling 

analysis. Sections 3.2.2 and 3.2.3 present EPA’s assumptions for vessel discharge flow rates and 

pollutant concentrations expected under pre-permit conditions. Next, EPA estimated reductions 

in vessel discharge pollutant concentrations and flow rates anticipated to occur as the result of 

issuance of the VGP and sVGP for the specific pollutants, discharges and vessel types identified 

for detailed evaluation. The following tables in Appendix G present EPA’s assumptions for 

vessel discharge flow and pollutant reductions estimated to result from the issuance of the VGP 

and sVGP, together with the estimated discharge-specific pollutant loads for each vessel class 

under pre- and post- VGP and sVGP conditions: 

 Table G-3 -EPA’s assumptions for pollutant concentration and flow reductions for 

VGP vessel classes following issuance of the permit. 

 Table G-4 -EPA’s assumptions for pollutant concentration and flow reductions for 

sVGP vessel classes following issuance of the permit. 

 Table G-5- Pre and post-permit vessel-specific pollutant loads for each wastestream, 

vessel type, and pollutant considered under the VGP. 

 Table G-6- Pre and post-permit vessel-specific pollutant loads for each wastestream, 

vessel type, and pollutant considered under the sVGP. 

Next, EPA developed a loading scenario for each of the seven RAAs by multiplying the 

vessel-specific pollutant loads in Tables G-5 and G-6 by the number of vessel equivalents7

present in the RAA harbors (Table G-7). EPA developed the vessel populations by contacting the 

RAA port authorities, using available Department of Transportation port call data, and other 

vessel related literature to characterize the average daily vessel equivalents present in the RAA 

by vessel class. Table 5-6 presents EPA’s assumptions for vessels populations present in each of 

the seven RAAs. Appendix G provides detailed descriptions of the data sources and assumptions 

used to develop the vessel population for each RAA. Tables G-8 and G-9 presents the total 

pollutant loads under pre and post-permit conditions for the seven loading scenarios used to 

calculate the exposure concentrations in the effects analysis. 

 

7

 Vessel populations presented are expressed as vessel equivalents where a vessel equivalent represents a single 

vessel discharging 24-hours per day in the harbor. For example, 1 vessel equivalent could represent 24 vessels that 

each operate (and discharge) for 1 hour in the harbor environment each day. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Table 5-6. Average Daily Vessel Population Equivalents7 in the RAAs 

Number of Vessels Present in Estuary RAA Harbors 

Number of Vessels 

Present in River 

RAA Harbors 

Vessel Type Seattle, 

WA 

Houston, 

TX 

New 

York, 

NY 

San 

Francisco, 

CA 

Miami, 

FL 

St Louis, 

MO 

Duluth, 

MN 

VGP Vessel Types 

Barges 12.8 340 62.4 2.77 2.88 60.1 0.00 

Oil/Gas Tankers 0.09 18.3 5.39 2.92 0.00 0.00 0.00 

Large Cruise Ships 4.00 1.00 5.00 3.00 7.00 0.00 0.00 

Large Commercial 

Fishing 24.5 0.00 1.00 0.00 0.00 0.00 0.00 

Medium Cruise Ships 1.00 0.00 1.00 1.00 1.00 1.00 0.54 

Bulk Cargo Carrier 2.86 9.99 17.1 12.3 9.11 0.00 2.08 

Large Ferry 4.00 0.00 50.0 4.11 4.11 0.00 0.00 

sVGP Vessel Types 

Commercial Fishing 1000 0.00 33.3 53.8 0.00 0.00 1.00 

Passenger Vessel 15.0 0.10 10.0 4.43 4.94 2.00 1.64 

Utility Boats 6.00 42.7 28.9 16.3 7.67 16.3 16.4 

Total Number of Vessels 

Equivalents Assumed in 

RAA Harbor 

1070 412 214 101 36.7 79.4 21.7 

5.2.1.3 Receiving Water Model Scenarios 

EPA modeled a total of 14 receiving water concentration scenarios based on combinations of the 

hypothetical harbor scenarios and the RAA loading scenarios discussed in Sections 5.2.1.1 and 

5.2.1.2, respectively. EPA developed 10 model scenarios (Scenarios 1 to 10) for the hypothetical 

estuary harbor that evaluated the combination of the two estuary harbor scenarios with the 

pollutant loading scenarios for the five estuarine RAAs (i.e., Seattle, Houston, New York, San 

Francisco, and Miami). EPA developed four model scenarios (Scenarios 11 to 14) for the 

hypothetical river harbor that evaluated the evaluated the combination of the two river harbor 

scenarios with the pollutant loading scenarios for the two freshwater RAAs (i.e., St. Louis and 

Duluth). Table 5-7 lists the combinations of hypothetical harbor and RAA loading scenarios used 

in calculating the receiving water concentrations evaluated in the effects analysis. 

Table 5-7. Receiving Water Model Scenarios 

Model Scenario Number Hypothetical Harbor Scenario RAA Loading Scenario 

Scenario 1 Estuary Harbor Scenario 1 Seattle Pollutant Load 

Scenario 2 Estuary Harbor Scenario 1 Houston Pollutant Load 

Scenario 3 Estuary Harbor Scenario 1 New York Pollutant Load 

Scenario 4 Estuary Harbor Scenario 1 San Francisco Pollutant Load 

Scenario 5 Estuary Harbor Scenario 1 Miami Pollutant Load 

Scenario 6 Estuary Harbor Scenario 2 Seattle Pollutant Load 

Scenario 7 Estuary Harbor Scenario 2 Houston Pollutant Load 

Scenario 8 Estuary Harbor Scenario 2 New York Pollutant Load 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Table 5-7. Receiving Water Model Scenarios 

Model Scenario Number Hypothetical Harbor Scenario RAA Loading Scenario 

Scenario 9 Estuary Harbor Scenario 2 San Francisco Pollutant Load 

Scenario 10 Estuary Harbor Scenario 2 Miami Pollutant Load 

Scenario 11 River Harbor Scenario 1 St. Louis Pollutant Load 

Scenario 12 River Harbor Scenario 1 Duluth Pollutant Load 

Scenario 13 River Harbor Scenario 2 St. Louis Pollutant Load 

Scenario 14 River Harbor Scenario 2 Duluth Pollutant Load 

 EPA believes that the four harbor scenarios described in Section 5.2.1.1 are 

representative of the types of water bodies where VGP and sVGP vessels likely operate based on 

the wide geographical range of waterbodies used to develop the input values. By selecting the 

minimum water characteristic values for the harbor scenarios, and evaluating the maximum 

pollutant loading values from the seven RAAs, EPA also believes that the model scenarios 

reasonably capture a “worst case” scenario within the action area applicable to this BE. See 

Section 5.2.6.1 for further discussion of the uncertainties and limitations of the modeling 

methodology used to estimate the exposure concentrations in the effects analysis. 

5.2.1.4 Exposure Concentrations 

 Using the modeling results from the modeled scenarios listed in Section 5.2.1.3, EPA 

determined the estimated minimum, maximum, and average receiving water concentrations for a 

hypothetical estuary harbor and a hypothetical river harbor under both pre- and post VGP and 

sVGP conditions (Table 5-8 and Table 5-9, respectively). In the quantitative effects analysis 

presented in Section 5.3, EPA uses the pre- and post VGP and sVGP exposure concentrations to 

assess the reduction in risk to listed species from the issuance of the permits. EPA evaluated the 

reduction in risk from the estimated maximum exposure concentrations only in the effects 

analysis. This approach allows EPA to assess the risk from what are likely “worst case” 

scnenarios from incidental discharges from vessels covered under the VGP and sVGP. 
2013 VGP and sVGP BE Secti

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Table 5-8. Estimated Receiving Water Concentrations from Vessel Incidental Discharge Loadings in a HyHarbor 

Class Analyte Units 

Pre VGP and sVGP Receiving Water 

Concentrations 

Post VGP and s

Con

Min Max Average Min 

Classicals 

Biochemical Oxygen Demand (BOD) mg/L 0.00629 0.915 0.195 0.0053 

Classicals 

Hexane Extractable Material (HEM) mg/L 0.00146 0.0656 0.0264 0.000701 

Classicals 

Silica Gel Treated HEM (SGTHEM) mg/L 0.000438 0.0169 0.00684 0.000215 

Classicals Total Residual Chlorine mg/L 0.0000032 0.00214 0.000281 0.00000238 0Classicals Total Suspended Solids (TSS) mg/L 0.00335 0.202 0.0435 0.0015 Metals Aluminum, Total μg/L 0.0542 1.28 0.405 0.0357 Metals Arsenic, Dissolved μg/L 0.0483 1.94 0.681 0.0476 Metals Arsenic, Total μg/L 0.0493 1.94 0.682 0.0484 Metals Cadmium, Dissolved μg/L 0.0000215 0.000867 0.000189 0.0000123 0Metals Chromium, Dissolved μg/L 0.0000565 0.00191 0.000463 0.0000465 0Metals Copper, Dissolved μg/L 0.0256 0.374 0.158 0.0252 Metals Lead, Dissolved μg/L 0.000116 0.00295 0.0011 0.00008 0Metals Nickel, Dissolved μg/L 0.00718 0.291 0.102 0.00701 Metals Nickel, Total μg/L 0.000654 0.0125 0.00507 0.000654 Metals Selenium, Dissolved μg/L 0.0538 2.25 0.788 0.0536 Metals Selenium, Total μg/L 0.0565 2.39 0.837 0.0565 Metals Zinc, Dissolved μg/L 0.00813 0.493 0.145 0.00635 Nutrients Ammonia As Nitrogen (NH3-N) mg/L 0.0000232 0.00954 0.00149 0.0000209 0Nutrients Total Phosphorus mg/L 0.000112 0.0119 0.00267 0.00000632 0SVOC 2,4,6-Trichlorophenol μg/L 0.000012 0.00103 0.000178 0.00000607 0SVOC Benzo(a)anthracene μg/L 0.000393 0.00685 0.00306 0.000393 0SVOC Benzo(a)pyrene μg/L 0.000214 0.00614 0.00198 0.000214 0SVOC Benzo(b)fluoranthene μg/L 0.0000185 0.00486 0.000733 0.0000185 0SVOC Benzo(k)fluoranthene μg/L 0.0000205 0.00538 0.000812 0.0000205 0SVOC Bis(2-ethylhexyl) phthalate μg/L 0.000122 0.00569 0.00117 0.000048 0
2013 VGP and sVGP BE Secti

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Table 5-8. Estimated Receiving Water Concentrations from Vessel Incidental Discharge Loadings in a HyHarbor 

Class Analyte Units 

Pre VGP and sVGP Receiving Water 

Concentrations 

Post VGP and s

Con

Min Max Average Min 

SVOC Chrysene μg/L 0.00055 0.00943 0.00399 0.00055 0SVOC Ideno(1,2,3-cd)pyrene μg/L 0.0000165 0.00434 0.000655 0.0000165 0VOC Benzene μg/L 0.000393 0.0311 0.00554 0.000186 VOC Bromodichloromethane μg/L 0.000139 0.00195 0.00085 0.0000364 0VOC Dibromochloromethane μg/L 0.000139 0.00195 0.00085 0.0000364 0VOC Tetrachloroethene μg/L 0.0000015 0.0000288 0.0000116 0.00000075 0VOC Trichloroethene μg/L 0.00122 1.14 0.159 0.00000225 0See Appendix G for the assumptions and equations used to estimate exposure concentrations under pre- and post- VGP and sVGP condTable 5-9. Estimated Receiving Water Concentrations in a Hypothetical River Harbor 

Class Analyte Units 

Pre VGP and sVGP Receiving Water 

Concentrations 

Post VGP and sV

Conc

Min Max Average Min 

Classicals Biochemical Oxygen Demand (BOD) μg/L 0.0506 9.2 4.38 0.0459 Classicals Hexane Extractable Material (HEM) μg/L 0.00445 0.855 0.396 0.00173 Classicals Silica Gel Treated HEM (SGT-HEM) μg/L 0.00117 0.214 0.102 0.00049 Classicals Total Residual Chlorine μg/L 0.0000169 0.00328 0.00152 0.0000144 Classicals Total Suspended Solids (TSS) μg/L 0.0126 2.33 1.1 0.00764 Metals Aluminum, Total μg/L 0.000162 0.0334 0.015 0.000102 Metals Arsenic, Dissolved μg/L 0 0.164 0.0413 0 Metals Arsenic, Total μg/L 0.000000231 0.164 0.0413 0.000000231 Metals Cadmium, Dissolved μg/L 0.0000000653 0.0000129 0.0000059 0.0000000366 Metals Chromium, Dissolved μg/L 0.000000142 0.0000399 0.0000158 0.000000137 Metals Copper, Dissolved μg/L 0.0000173 0.033 0.00902 0.0000171 Metals Lead, Dissolved μg/L 0.00000045 0.0000922 0.0000416 0.000000345 
2013 VGP and sVGP BE Secti

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Table 5-9. Estimated Receiving Water Concentrations in a Hypothetical River Harbor 

Class Analyte Units 

Pre VGP and sVGP Receiving Water 

Concentrations 

Post VGP and sV

Conc

Min Max Average Min 

Metals Nickel, Dissolved μg/L 0.000000338 0.0246 0.0062 0.000000334 Metals Nickel, Total μg/L 0.000000716 0.000723 0.000211 0.000000716 Metals Selenium, Dissolved μg/L 0 0.191 0.0479 0 Metals Selenium, Total μg/L 0 0.203 0.051 0 Metals Zinc, Dissolved μg/L 0.0000496 0.00968 0.00446 0.0000439 Nutrients Ammonia As Nitrogen (NH3-N) μg/L 0.000167 0.032 0.0149 0.000167 Nutrients Total Phosphorus μg/L 0.000271 0.0453 0.0225 0.0000242 SVOC 2,4,6-Trichlorophenol μg/L 0.0000000626 0.0000113 0.00000539 0.0000000313 0SVOC Benzo(a)anthracene μg/L 0.00000164 0.0008 0.000268 0.00000164 SVOC Benzo(a)pyrene μg/L 0.00000159 0.000536 0.0002 0.00000159 SVOC Benzo(b)fluoranthene μg/L 0.00000139 0.000228 0.000114 0.00000139 SVOC Benzo(k)fluoranthene μg/L 0.00000154 0.000252 0.000126 0.00000154 SVOC Bis(2-ethylhexyl) phthalate μg/L 0.00000118 0.000198 0.0000981 0.000000979 SVOC Chrysene μg/L 0.00000164 0.00102 0.000325 0.00000164 SVOC Ideno(1,2,3-cd)pyrene μg/L 0.00000124 0.000203 0.000102 0.00000124 VOC Benzene μg/L 0.00000701 0.00117 0.000579 0.00000641 VOC Bromodichloromethane μg/L 0.000000451 0.0000981 0.0000431 0.000000116 VOC Dibromochloromethane μg/L 0.000000451 0.0000981 0.0000431 0.000000116 VOC Tetrachloroethene μg/L 0.00000000164 0.00000166 0.000000484 0.000000000821 0VOC Trichloroethene μg/L 0.0000000232 0.237 0.0595 0.0000000116 0See Appendix G for the assumptions and equations used to estimate exposure concentrations under pre- and post- VGP and sVGP cond
2013 VGP and sVGP BE Section 5- Effects Analysis 

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5.2.2 Effects Data and Estimation of Chronic Toxicity Effect Thresholds and 

Representative RQs

This section includes a brief discussion of the pollutant-specific ecotoxicological effects 

data used as chronic toxicity effect thresholds (CTETs) within the risk equation (Equation 5-1), 

as well as the specific toxicological effects assessment endpoints (effect measures) from which 

these values were derived and used to calculate RQs. 

Ecotoxicological effects data from studies included in EPA’s aquatic life ambient water 

quality criteria (ALC) documents (see 

http://water.epa.gov/scitech/swguidance/standards/criteria/aqlife/index.cfm) serve as the primary 

source of aquatic toxicity data used to support the risk analysis for the toxic and nonconventional pollutants with toxic effects selected for detailed evaluation in this BE (Section 

3.2.3). These data have been reviewed following the strict data quality objectives and secondary 

data acceptance criteria as defined in EPA’s: Guidelines for Deriving Numerical National Water 

Quality Criteria for the Protection of Aquatic Organisms and their Uses (Stephan et al., 1985) 

hereafter referred to as the 1985 Guidelines. The framework provided by the 1985 Guidelines

has been instrumental in establishing uniformity in the derivation methodology for aquatic 

pollutants and for achieving technically rigorous and protective criteria for the last 27 years. In 

the event that no such data were available for aquatic organisms, data gleaned from EPA’s 

ECOTOX database (http://cfpub.epa.gov/ecotox/) were utilized as a secondary data source, or, 

limited web-based literature searches were conducted to fill key information data gaps. In the 

case of the need for and use of secondary sources of information, EPA reviewed the information 

following the same data quality and acceptance criteria established via the 1985 Guidelines in 

order to assure the same consistency and integrity needed to support the effects analysis 

described below. 

Additionally, the same standard ecotoxicological effects assessment endpoints used in the 

1985 Guidelines were adopted in this BE, which include direct toxic effects on survival, growth, 

or reproduction of aquatic species (whichever is lower). The lowest (most conservative) CTET 

from a long-term chronic test (water-only and/or dietary chronic exposure) with a representative 

surrogate species (or lowest related taxon of that species) was preferentially used to calculate 

RQs in support of the quantitative effects analysis. In a select few cases where only acute (lethal, 

short-term) toxicity data were available for a species, an acute-to-chronic ratio (ACR8

) was used 

to estimate a CTET from acute lethal toxicity test data for a target or surrogate species. When 

appropriate toxicity test specific or ACR derived chronic aquatic data were not available for a 

given taxonomic group of interest for a specific pollutant, but where a draft or final chronic 

criterion value (i.e., continuous criterion concentration or CCC) was available from EPA, then 

the chronic criterion value was used to calculate the RQ. All CTETs used to calculate the RQ 

(and their sources or bases for derivation) are provided in the pollutant-specific tables included in 

support of the pollutant-specific risk summaries provided in Section 5.3 below. 

 

8

 Application of ACRs is one methodology used by the EPA to derive chronic criteria in ALC documents when 

insufficient aquatic chronic toxicity data exist to do so (see 1985 Guidelines- Stephan et al., 1985). The ACR is 

computed from paired acute and chronic toxicity data from toxicity tests with a particular pollutant to specific test 

organism where the concentrations are in the same units. Since the ACR represents an empirical method for 

estimating chronic toxicity from acute toxicity, the toxic mode of action is not necessarily the same for the 

expression of acute and chronic toxicity. For chronic toxicity especially, the mechanisms can be diverse. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-39 

The sources of CTETs used to calculate RQs for listed aquatic-dependent species 

exposed via oral ingestion of contaminated food (prey items) and drinking water (fresh water 

only) are also presented in the pollutant-specific tables supporting each risk summary provided 

in Section 5.3 below. These particular CTETs were calculated using the maximum exposure 

concentrations (ECs) based on pre- and post-permit conditions from Section 5.2.1. All aquaticdependent wildlife CTETs provided in the corresponding pollutant-specific tables in Section 5.3 

are based on chronic no observed adverse effect levels (NOAELs) from laboratory exposure of 

surrogate birds and mammals to oral ingestion of contaminated food and drinking water. Only 

NOAELs based on growth or reproduction are used as CTETs in this BE. The CTETs are largely 

the same as what was used to support similar analyses in EPA’s Biological Evaluation of 

Oregon’s Water Quality Criteria for Toxics, dated January 2008 (USEPA, 2008b). The primary 

source for these values was Sample et al. (1996) - Toxicological Benchmarks for Wildlife: 1996 

Revision (Appendix A). NOAELs were selected as the basis for CTETs in this case as an extra 

measure of conservatism because so few ecotoxicological data exist for wildlife species in 

general (ecotoxicological data generally exist for only rodents and select bird species, i.e., 

domestic chickens and mallard ducks). 

Bioconcentration factors (BCFs) or bioaccumulation factors (BAFs) are used in the 

analysis to calculate the concentration (mg/kg) of pollutant expected in tissue (whole body) of an 

aquatic organism exposed to the maximum concentration (mg/L) of pollutant modeled in a 

receiving water of interest in this BE. In situations where lower trophic level (trophic levels 1 

and 2) organisms are exposed to the pollutant via water only, the use of BCFs is the appropriate 

method of predicting pollutant concentrations in the tissues of aquatic species. Use of BCFs is 

also appropriate for predicting tissue residues in higher trophic level (trophic levels 3 and 4) 

aquatic organisms from the concentration in water for many metals (e.g., aluminum, copper, 

cadmium, lead, nickel and zinc) and for organics with low octanol-water partition coefficients 

(e.g., benzene) because the tissue concentrations of these pollutants do not increase (biomagnify) 

from lower trophic levels to higher trophic levels (see USEPA, 2003a). Conversely, use of BAFs 

is the appropriate method for predicting pollutant concentrations in the tissues of higher trophic 

level aquatic organisms in situations where the organism is exposed to the pollutant through all 

routes of exposure (i.e., water, diet, cutaneous), and where concentrations in tissue biomagnify 

up the food chain. The source of BCFs used for the analysis in this BE was also EPA’s 

Biological Evaluation of Oregon’s Water Quality Criteria for Toxics, dated January 2008 

(USEPA, 2008b), except for arsenic and selenium (see Appendix H for the BAF values used for 

these metalloids and their corresponding sources). BAFs for bioaccumulative organic pollutants 

(e.g., benzo(a)pyrene) were based on various sources and calculated using guidance described in 

USEPA (2003a) – Methodology for Deriving Ambient Water Quality Criteria for the Protection 

of Human Health (2000): Technical Support Document, Volume 2: Development of National 

Bioaccumulation Factors (see also, Appendix H for additional information). 

5.2.3 Direct Effects Analysis

Direct effects to listed aquatic (from water only and water + dietary exposure) and 

aquatic-dependent species (from oral ingestion of contaminated food and drinking water) were 

interpreted using RQs as generally described using Equation 5-1 above. As a conservative 

measure EPA selected the lowest CTET from a test with a listed (e.g., rainbow or steelhead 

trout) or surrogate (e.g., fathead minnow) species representing an entire taxonomic group of 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-40 

listed species (e.g., freshwater aquatic vertebrates) exposed to a given pollutant. EPA 

quantitatively compared the lowest CTET value with the maximum expected pre-permit and 

post-permit exposure concentrations derived for the pollutant based on conservative assumptions 

of loading rates from varying vessel class and discharge combintations and various hypothetical 

harbor modeling scenarios. By using the maximum EC estimated for a given pollutant in the 

hypothetical estuary or river harbors evaluated in Section 5.2.1, EPA assumes that the results of 

the effects analysis can be conveyed or extrapolated to the larger Action Area of interest in this 

BE. EPA designed the hypothetical harbors to capture a wide variety of environmental 

conditions and pollutant loading scenarios to help bound the potential pollutant EC for a 

multitude of areas. Therefore, EPA also expects that the maximum ECs estimated for a given 

pollutant in the hypothetical estuary or river harbors represent reasonable “worst case” exposure 

scenarios for the direct effects analysis. 

Under this risk paradigm, the higher the RQ, the higher the risk to the species. EPA 

acknowledges that different taxa will elicit different risks to any particular pollutant based on the 

differences in chronic sensitivity among different taxa; however, in general EPA assumes that 

the higher the RQ the greater the possible risk. Again, only CTETs were used to develop RQs in 

this BE to assess direct effects of a particular pollutant from exposure. For the purpose of this 

BE, EPA established a sliding scale to identify the risk conclusion based on the RQ value and 

establish the overall health concern from a given pollutant. As presented in Table 5-10, if the RQ 

is less than one, EPA presumes no risk from that pollutant, and a risk conclusion of “remote” or 

“negligible” is recorded for that species. If the RQ is greater than one, EPA presumes a low level 

for potential risk from that pollutant, and a risk conclusion of potentially significant isrecorded 

for that species. If the RQ is greater than 10, the potential for risk is much more notable, and a 

risk conclusion of “potentially significant” is recorded for that species. 

Table 5-10. RQ Scale for Risk Conclusion and Overall Health Concern Determination 

RQ Scale Risk Conclusion Overall Health Concern 

RQ < 0.1 Remote 

No risk from pollutant. Risk conclusion 

clearly indicates the pollutant is not 

likely to adversely affect a listed 

species. 

0.1 < RQ < 1.0 Negligible 

No risk from pollutant. Risk conclusion 

indicates the pollutant is not likely to 

adversely affect a listed species. 

1.0 < RQ < 10 Potentially Significant 

Low level potential for risk from 

pollutant. Risk conclusion indicates a 

situation where EPA is reasonably 

confident a pollutant would not likely 

adversely affect a listed species. 

RQ > 10 Likely Significant 

Potential risk from pollutant. Risk 

conclusion indicates a pollutant may 

affect a listed species, with a conclusion 

of likely to adversely affect probable in 

many cases. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-41 

5.2.3.1 Basis of CTET Used to Support Direct Effects to Aquatic Listed Species from 

Water-only Exposure 

The appropriate definitive9 chronic toxicity data are lacking for nearly all of the listed 

aquatic species considered in this BE; and therefore, CTETs are from tests with listed or 

surrogate species that gave the lowest (most sensitive) value for that entire species group. 

The risk paradigm used to support the quantitative effects analysis on aquatic listed 

species from water-only exposure to a pollutant is calculated by: 

ܴܳ஺,ௐ ൌ ܥܧௐ

ௐ,஺ܶܧܶܥ

Equation 5-2 

Where: 

RQAW = Pollutant- and species-specific risk quotient for aquatic organisms (basis 

for letter A designation) based on water-only exposure (basis for letter W 

designation). 

ECW = Modeled pollutant-specific exposure concentration in the receiving water 

before (pre-) and after (post-) issuance of the 2013 VGP and sVGP. 

CTETA,W = Chronic toxicity effect threshold for a given aquatic listed (or 

representative surrogate) species from water-only chronic exposure to a 

pollutant. 

In this analysis, the lowest chronic value from an acceptable water-only laboratory 

chronic toxicity test with a biologically important endpoint (mortality, growth or reproduction) is 

used as the basis for CTETA,W to estimate effects on aquatic plants, invertebrates, and vertebrates 

(fish and amphibians). The lowest CTETA,W is used here because EPA believes that this 

approach adds an appropriate measure of conservatism when determining effects to the listed 

aquatic species considered in this BE. For example, for Chinook salmon listed in Oregon, the 

most sensitive vertebrate CTET (or CTETA,W in this case) may not necessarily be the CTET for 

another salmonid species (e.g., rainbow trout), but rather, a fish species in another family that 

was reported to be more sensitive to the pollutant. 

The three chronic test endpoints (i.e., mortality, growth and reproduction) are considered 

to be biologically important endpoints because they have ecological significance in a risk 

assessment context, as do population level endpoints. The two purposes of the ESA are to 

conserve the ecosystems on which endangered species depend, and to provide a program for the 

 

9

 Definitive chronic toxicity data in this BE is defined as having come from a test that satisfied one of the definitions 

given in the 1985 Guidelines for a life-cycle, partial life-cycle, or early life-stage test, including the requirement of 

having been based on measured concentrations of the pollutant in the exposure (test) water, and, where the exposure 

was based on flow-through (as opposed to state or static renewal) test conditions (single exception being for chronic 

tests with cladocerans). A final requirement was whether the pollutant used in the test caused an unacceptable 

reduction in (a) survival (if over any period of at least seven days), or (b) growth (if the duration of the test is judged 

sufficiently long to capture growth reductions that are not temporary - as determined on a species-specific basis) of 

the control organism population such that health of the test organisms was called into question. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-42 

conservation of endangered species. “Conserve” is defined under the ESA as “methods and 

procedures necessary to bring any endangered species to a point at which measures provided 

within ESA are no longer necessary”. 

All CTETs used to support the analysis in this BE are derived using the test acceptability 

and data quality criteria given by the 1985 Guidelines, as stated above (see Stephan et al., 1985). 

Definitive CTETs in EPA ALC documents are calculated as either (a) the geometric mean of the 

highest no-observed-effect concentration (NOEC) and lowest observed effect concentration 

(LOEC) for effects on survival, growth, or reproduction in aquatic animal chronic tests, or (b) the 

10 or 20% Effect Concentration (EC10 or EC20) from such tests. As in the 1985 Guidelines, 

chronic tests for invertebrate species are required to include the entire life-cycle, but for fish, 

partial life-cycle and early life-stage (ELS) testing protocols are accepted, the latter not including 

reproductive endpoints and not used if life-cycle or partial life-cycle tests are available and show 

more sensitive adverse chronic effects. In contrast, all tests with aquatic algae and plants are 

considered chronic tests, but only those chronic values from tests with aquatic rooted vascular 

plants (macrophytes) and where the endpoint measured was biologically significant (e.g., 

vegetative growth or reproduction) are considered relevant and meaningful (either in ALC 

development or in this BE). The focus on aquatic macrophytes, as opposed to algae and diatoms, 

is due largely to the fact that the rapid recovery rate of phytoplankton exposed to many toxic and 

non-conventional pollutants with toxic effects precludes risk analysis as defined in this BE. 

Phytoplankton (algae and diatoms) and vascular plants in general are rarely as sensitive as fish 

and macroinvertebrates to pollutants with toxic effects. 

All CTETs for aquatic organisms considered in this BE must have been conducted under 

flow-through test conditions (or renewal tests for cladocerans) in the laboratory where test 

concentrations were measured throughout the test and water quality characteristics were well 

defined – to ensure validity and defensibility of CTETA,W. 

5.2.3.2 Basis of CTET Used to Support Direct Effects to Aquatic Listed Species from 

Multiple Routes of Exposure 

Studies that expose aquatic species to pollutants only in water exclude other potentially 

important exposure routes (i.e., sediment, diet), which eliminates the possibility that 

simultaneous exposure of aquatic species through multiple routes may result in greater toxic 

effects than might be predicted from water column toxicity tests alone. Unfortunately, 

investigations of the effects of other routes of exposure such as ingestion from diet are much less 

common than water-column only toxicity tests, and also do not have well standardized methods. 

Although the processes controlling waterborne and dietary pollutant uptake in aquatic 

species are generally independent of each other, whole body pollutant concentrations are 

integrators of tissue residues resulting from waterborne and dietary contaminant uptake. 

Numerous investigators have presented evidence and now recognize that whole body residues 

are a reasonable surrogate for the pollutant concentration at the site of toxic action (Landrum et 

al. 1991; Cook et al. 1992; McCarty and Mackay 1993 in EPA 2008 OR Toxics BE); thus, whole 

body pollutant residue is considered here as useful for making screening-level risk predictions 

from exposure to pollutants. If the tissue residue (whole body burden) of a pollutant in an aquatic 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-43 

organism reflects its integrated exposure to that pollutant from a specific pollutant concentration 

in water, the potential risk from the adverse effects of that pollutant can be evaluated by 

comparing the amount of that pollutant bioaccumulated in the tissues of that organism in relation 

to the manifestation of adverse chronic toxicity effects such as reduced growth or reproduction. 

The risk paradigm used to support the quantitative effects analysis on aquatic listed 

species from multiple routes of exposure to a pollutant is calculated by: 

ܴܳ஺,ெ ൌ ܥܧ்

,்஺ܶܧܶܥ

Equation 5-3

Where: 

RQA,M = Pollutant- and species-specific risk quotient for aquatic organisms (basis 

for letter A designation) from multiple routes of exposure (basis for letter 

M designation). 

ECT = Estimated pollutant-specific exposure concentration in whole body tissue 

(basis for letter T designation; wet weight basis) of an aquatic organism 

that has accumulated that pollutant from modeled receiving water 

concentrations before (pre-) and after (post-) issuance of the 2013 VGP 

and sVGP. 

CTETA,T = Chronic toxicity effect threshold of a pollutant measured in tissue (mg/kg 

wet wt.) for an aquatic listed (or representative surrogate) species 

associated with adverse chronic effects on reproduction and growth. 

The approach used to evaluate toxicity to aquatic species from multiple concurrent routes 

of exposure in this BE is based on similar rationale as described in EPA’s Biological Evaluation 

of Oregon’s Water Quality Criteria for Toxics, dated January 2008 (USEPA, 2008b), hereafter 

referred to as the Oregon Toxics BE. In this analysis, however, estimations of whole body tissue 

pollutant concentrations accumulated from exposure to the modeled maximum concentrations 

predicted in receiving water were derived simply as: 

ECT = (BCF or BAF) x ECW 

Equation 5-4 

Where: 

ECT = Estimated pollutant-specific exposure concentration in whole body tissue 

(basis for letter T designation; wet weight basis) of an aquatic organism 

that has accumulated that pollutant from modeled receiving water 

concentrations before (pre-) and after (post-) issuance of the 2013 VGP 

and sVGP. 

BCF = Bioconcentration factor: the ratio (L/kg of wet tissue weight) of the 

concentration of a pollutant in the tissue of an aquatic organism to its 

concentration in water in situations where the organism is exposed 

through the water only (used in this analysis for all metals, except arsenic 

and selenium, and organic pollutants with low octanol:water partition 

coefficient or KOW; e.g., benzene). 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-44 

BAF = Bioaccumulation factor: the ratio (L/kg of fresh tissue) of the 

concentration of a pollutant in the tissue of an aquatic organism to its 

concentration in water in situations where the organism is exposed 

through all routes of exposure (water, diet, sediment) – used for arsenic, 

selenium and organic pollutants that biomagnify (e.g., some polynuclear 

aromatic hydrocarbons). 

ECW = Modeled pollutant-specific exposure concentration in the receiving water 

before (pre-) and after (post-) issuance of the 2013 VGP and sVGP. 

All whole body tissue pollutant concentrations in this BE are presented as mg/kg whole 

body, wet weight. 

Risk comparison using ECT was made for all toxic and non-conventional pollutants with 

toxic effects selected for detailed evaluation in this BE except those that do not bioconcentrate or 

bioaccumulate (e.g., ammonia, total residual chlorine, total phosphorous, total suspended solids). 

Again, all BCF and BAF values used to calculate ECT in this BE are provided in Appendix H. 

Whole body tissue pollutant concentrations associated with adverse effects on growth or 

reproduction (i.e., CTETA,T) were as provided in the Oregon Toxics BE from literature available 

in Jarvinen and Ankley (1999), the Environmental Residue Effects Database (ERED, available 

at: http://el.erdc.usace.army.mil/ered/), and other sources identified in the primary literature (see 

also, Appendix H). As noted above in Section 5.2.3.1, the lowest observed effect residue on 

growth or reproduction for each species (or representative surrogate species) for which 

information is available was used as the basis for CTETA,T. 

5.2.3.3 Basis of CTET Used to Support Direct Effects to Aquatic-dependent Listed 

Species 

Aquatic-dependent wildlife species are reptiles, birds, and mammals whose diet contains 

an appreciable proportion of aquatic organisms. To evaluate whether aquatic-dependent wildlife 

are at risk to ingestion of pollutants from drinking water and consuming aquatic prey organisms, 

an oral ingestion exposure concentration (ECO) based on exposure of wildlife to prey and/or 

drinking water at the maximum modeled concentration of that pollutant in a receiving water is 

used. The wildlife ECO combines the ingested dose of a pollutant from both drinking surface 

water (presumed fresh water only) and ingesting aquatic prey that have also accumulated target 

pollutants from the same surface water, expressed as a combined oral dose for a surrogate bird or 

mammal. Since there were no data readily available to calculate ECO for reptiles in the analysis, 

EPA used data from birds (as the closest related surrogate). If the calculated ECO is lower than 

the chronic toxicity effect threshold (CTETO) estimated for that pollutant based on the oral dose 

administered to a bird or mammal species in a chronic toxicity study, then the modeled pollutant 

concentration in surface water is not high enough to result in an ingested oral dose sufficient to 

elicit adverse effects in aquatic-dependent wildlife. 

The risk paradigm used to support the quantitative effects analysis on aquatic-dependent 

listed species from oral ingestion of a pollutant via ingestion of prey and/or drinking water (fresh 

water) is calculated by: 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-45 

ܴܳௐ௜௟ௗ ൌ ܥܧை

ைܶܧܶܥ

Equation 5-5 

Where: 

RQWild = Pollutant- and species-specific risk quotient for aquatic-dependent 

(wildlife) species from oral ingestion of a pollutant via ingestion of prey 

and/or drinking water (fresh water).

ECO = Combined oral dose (basis for letter O designation) of pollutant ingested 

by an aquatic-dependent bird or mammal from consuming prey or 

drinking water from a surface water with the modeled receiving water 

concentrations before (pre-) and after (post-) issuance of the 2013 VGP 

and sVGP. 

CTETO = Chronic toxicity effect threshold (in this case, a No Observed Adverse 

Effect Level or NOAEL) for a given surrogate aquatic-dependent 

(wildlife) species based on the measured concentration of that pollutant 

administered orally (food and/or water) from studies examining chronic 

effects on growth or reproduction. 

In this analysis, the pollutant exposure is based solely on the oral ingestion pathway 

because pollutant exposure experienced by wildlife through both the dermal and inhalation 

pathways is “negligible” (Sample et al., 1997). Furthermore, sediment ingestion rates of many 

wildlife species are low, generally 2% or less of the total food ingestion rate (Beyer et al., 1994). 

Thus, for the purposes of this BE, EPA assumes that the oral ingestion of a pollutant in water by 

an aquatic-dependent species can be described simply as the sum of its ingestion of the pollutant 

in drinking water and aquatic prey items at predicted concentrations of that pollutant in a 

receiving water. If the aquatic-dependent wildlife species under evaluation is known to feed on 

aquatic biota10 , it follows that the oral dose of the pollutant from consumption of contaminated 

prey (Eprey) can be estimated from the product of the predicted concentration of that pollutant in 

water and a BCF or BAF (see Equation 5-4). If the food and water ingestion rates for a wildlife 

species are known or can be estimated, and assuming the concentration of the pollutant in prey is 

proportional to its concentration in water as above, it is possible to calculate the exposure of 

aquatic-dependent wildlife to a pollutant from its consumption of prey and water. Such 

information can then be used to calculate the oral dose exposure concentration (ECO) that can be 

compared to CTETO to assess risk to wildlife from the combined ingestion of contaminated food 

and water (Sample et al., 1997; USEPA, 2008b). Here, 

ECO = (IRD x ECW) + (IRF x ECT) 

Equation 5-6 

Where: 

ECO = As defined in Equation 5-5 above (in mg/kg/day)

IRD = Ingestion rate of drinking water calculated as the quotient of the water 

intake rate and body weight of a surrogate species (L/kg fresh body 

weight/day) 

ECW = As defined under Equation 5-2above (in mg/L) 

 

10 The animal does not have to feed exclusively on aquatic species for this estimate to be valid. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-46 

IRF = Ingestion rate of food calculated as the quotient of the food intake rate and 

body weight of a surrogate species (kg/kg fresh body weight/day) 

ECT = As defined under Equation 5-3 and calculated in Equation 5-4 above 

(mg/kg wet tissue) 

Again, for the purposes of this BE, EPA uses a wildlife no observed adverse effect level 

(NOAEL) as CTETO. Calculations ECO in this BE are provided in Appendix H. 

5.2.4 Indirect Effects Analysis

EPA assessed indirect effects of pollutant exposure to listed species semi-quantitatively, 

based on the value (level of significance) of the RQs calculated above. EPA assumes that the 

potential impact of indirect effects on water quality, shelter, prey/forage items, etc. either 

required or important for the health and well being for each species is proportional to the direct 

effect RQs. The indirect effects assessment follows the logic that the greater the risk of potential 

direct effects of a pollutant on a listed species’ food source or its habitat, the greater the 

likelihood of potential indirect effects on the species as well. A pollutant may be assumed to 

pose no significant indirect effect to a listed species if risk from direct toxicity is not determined 

for an important prey item or constituent element of its critical habitat, and, if other information 

used to support the direct effects analysis are supportable (e.g., valid BCF or BAF is available 

for a pollutant). 

As part of the indirect effects analysis, EPA also considered the potential for indirect 

exposure pathways to affect vital ecological characteristics (e.g., feeding habits, life history, 

geographic distribution, preferred habitat) for each of the 82 RAA listed species. 

5.2.5 Risk Conclusions for All Listed Species 

The purpose of the risk conclusion analysis is to inform for the effects determinations 

presented in Section 7 for all 612 (or 454 species for pollutants other than ANS) aquatic and 

aquatic-dependent species and their critical habitats that may be affected by the VGP and sVGP 

(Appendix E). EPA chose to evaluate the potential risk to listed aquatic and aquatic-dependent 

species and their critical habitats in a subset of representative geographical areas (referred to as 

reference action areas, RAAs) selected to reflect the major ports of call and types of ecosystems 

potentially impacted by vessel discharges covered by the VGP and sVGP. Section 3.3 identified 

the seven RAAs selected for the BE analysis, and Section 3.4.2 identified the 82 aquatic and 

aquatic-dependent species and their critical habitats present in the RAAs to be considered in the 

risk analysis described above (Sections 5.2.1 to Section 5.2.4). For the qualitative and 

quantitative risk analyses for pollutants selected for detailed evaluation, EPA intends to use the 

species-specific risk conclusions for the 82 RAA listed species to inform effects determinations 

for the full list of 612 listed species and their critical habitats that may be affected by the VGP 

and sVGP. The approach is performed by first grouping the 82 RAA listed species into 

appropriate taxonomic groups; called listed species taxonomic groups (see Table 5-11). EPA 

established 18 listed species taxonomic groups based on the 82 RAA listed species for the risk 

conclusion analysis. Next, EPA categorized each of the 612 listed species evaluated in the BE 

into one of the 18 listed species taxonomic groups (see Appendix E). Therefore, the listed 

species taxonomic group serves as the key link between the risk conclusions from the 82 RAA 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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species and effects determinations for the 612 listed species that may be affected by the VGP and 

sVGP. Finally, for each pollutant evaluated in the quantitative analysis (Section 5.3), EPA 

presents a risk conclusion for each of the established 18 listed species taxonomic groups, taking 

into consideration both direct and indirect effects from the pollutant to all of the RAA listed 

species captured within each taxonomic group.11 

Table 5-11. Listed Species Taxonomic Groupings Based on Listed Aquatic and Aquaticdependent Species within the Seven RAAs 

Major 

Taxonomic 

Grouping 

Listed Species 

Taxonomic 

Groupa

Listed Species/ Taxa RAA(s)b Potential Relevant 

Exposure Pathway 

Mammals Terrestrial 

Mammal 

Salt Marsh Harvest Mouse SFBE Water + Diet 

Riparian Woodrat SFBE Water + Diet 

Gray Bat UMR, BB Water + Diet 

Indiana Bat ULB, UMR, 

BB 

Water + Diet 

Grizzly Bear PS Water + Diet 

Red Wolf BB Water + Diet 

Florida Panther BB Water + Diet 

Marine Mammal West Indian Manatee GB, BB Water + Diet 

Southern Sea Otter SFBE Diet Only 

Guadalupe Fur Seal SFBE Diet Only 

Steller Sea-Lion PS, SFBE Diet Only 

Finback Whale ULB, GB Diet Only 

Humpback Whale PS, ULB, GB, 

BB 

Diet Only 

North Atlantic Right Whale ULB, BB Diet Only 

Killer Whale PS, SFBE Diet Only 

Birds Coastal/Marine 

Bird 

Cape Sable Seaside Sparrow BB Diet Only 

Piping Plover ULB, GB, 

SLE 

Diet Only 

Western Snowy Pacific Plover SFBE Diet Only 

Marbled Murrelet PS, SFBE Diet Only 

Least Tern UMR Diet Only 

Roseate Tern ULB, BB Diet Only 

Short-Tailed Albatross PS Diet Only 

Whooping Crane GB Diet Only 

Wood Stork BB Diet Only 

Audubon's Crested Caracara BB Diet Only 

Everglade Snail Kite BB Diet Only 

 

11 Risk conclusions for ANS for the 82 RAA listed species are considered in the effects determinations for all 612 

listed species that may be affected by the permit actions and are heavily informed based on the listed species 

taxonomic grouping; however, EPA conducted additional species-specific life history analyses to further support the 

effects determinations for ANS. Section 7.1 outlines the methodology for assessing the life history data for all 612 

listed species to support the effects determination for ANS. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Table 5-11. Listed Species Taxonomic Groupings Based on Listed Aquatic and Aquaticdependent Species within the Seven RAAs 

Major 

Taxonomic 

Grouping 

Listed Species 

Taxonomic 

Groupa

Listed Species/ Taxa RAA(s)b Potential Relevant 

Exposure Pathway 

Reptiles Snake and Other 

Reptiles 

Bog Turtle ULB Water + Diet 

American Crocodile BB Water + Diet 

Eastern Indigo Snake BB Water + Diet 

Giant garter Snake SFBE Water + Diet 

Alameda Whipsnake SFBE Water + Diet 

Sea Turtle Green Sea Turtle PS, ULB, GB, 

BB, SFBE 

Diet Only 

Hawksbill Sea Turtle ULB, GB, BB Diet Only 

Kemps’s Ridley Sea Turtle ULB, GB Diet Only 

Leatherback Sea Turtle PS, ULB, GB, 

BB, SFBE 

Diet Only 

Loggerhead Sea Turtle ULB, GB, BB Diet Only 

Olive Ridley Sea Turtle SFBE Diet Only 

Insects Beetle and 

Aquatic Insects 

Valley Elderberry Longhorn 

Beetle 

SFBE Water + Diet 

Delta Green Ground Beetle SFBE Water + Diet 

Freshwater 

Aquatic 

Vertebrates 

Amphibian California Red-legged Frog SFBE Water + Diet 

California Tiger Salamander SFBE Water + Diet 

Freshwater 

Fish/Inland 

Salmonid 

Bull Trout 

PS Water + Diet 

Freshwater 

Fish/Inland 

Sturgeon 

Pallid Sturgeon 

UMR Water + Diet 

 Anadromous 

Salmonid 

Chinook Salmon (Puget Sound) PS Water + Diet 

Chum Salmon (Hood Canal 

summer-run) 

PS Water + Diet 

Steelhead Salmon (Puget Sound 

and CA Coast) 

PS, SFBE Water + Diet 

Anadromous 

Sturgeon 

Shortnose Sturgeon ULB, BB Water + Diet 

Gulf Sturgeon BB Water + Diet 

North American Green Sturgeon SFBE Water + Diet 

Freshwater 

Aquatic 

Invertebrates 

Unionid Mussel Pink Mucket UMR Water Only 

Scaleshell Mussel UMR Water Only 

Freshwater 

Shrimp/ 

Crustacean 

Conservancy Fairy shrimp SFBE Water + Diet 

Longhorn Fairy shrimp SFBE Water + Diet 

Vernal Pool Tadpole Shrimp SFBE Water + Diet 

California Freshwater Shrimp SFBE Water + Diet 

Estuarine/ 

Marine 

Aquatic 

Vertebrates 

Estuarine/Marine 

Fish 

Tidewater Goby SFBE Water + Diet 

Delta Smelt SFBE Water + Diet 

Smalltooth Sawfish BB, GB Water + Diet 

Estuarine/ 

Marine 

Aquatic 

Invertebrates 

Saltwater Corals Elkhorn Coral BB Water Only 

Staghorn Coral BB Water Only 

Saltwater Bivalve 

Mollusk White Abalone SFBE Water Only 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Table 5-11. Listed Species Taxonomic Groupings Based on Listed Aquatic and Aquaticdependent Species within the Seven RAAs 

Major 

Taxonomic 

Grouping 

Listed Species 

Taxonomic 

Groupa

Listed Species/ Taxa RAA(s)b Potential Relevant 

Exposure Pathway 

Plants FreshwaterSaltwater Aquatic 

and Wetland 

Plants 

Sonoma Sunshine SFBE Water Only 

Colusa Grass SFBE Water Only 

Hairy Orcutt Grass SFBE Water Only 

Solano Grass SFBE Water Only 

Hoover's Spurge SFBE Water Only 

Sonoma Alopecurus SFBE Water Only 

White Sedge SFBE Water Only 

American Chaffseed BB Water Only 

Fountain Thistle SFBE Water Only 

Palmate-bracted Bird's Beak SFBE Water Only 

Calistoga Allocarya SFBE Water Only 

Napa Bluegrass SFBE Water Only 

Ute Ladies’-Tresses PS Water Only 

Water Howellia PS, SFBE Water Only 

Decurrent False Aster UMR Water Only 

Eastern Prairie Fringed Orchid UMR Water Only 

Brooksville Bellflower BB Water Only 

Seabeach Amaranth ULB Water Only 

Suisun Thistle SFBE Water Only 

Soft Bird's Beak SFBE Water Only 

Seagrass Johnson's Seagrass BB Water Only 

a) Listed species taxonomic groupings are meant to roughly coincide with the Species Group provided in USFWS 

Environmental Conservation Online System (ECOS), but with further delineation according to life history 

information and attributes to demonstrate the strong representation given by the subset of 82 RAAs listed 

species to the 612 aquatic and aquatic-dependent species and their critical habitats that may be affected by the 

VGP and sVGP. 

b) BB = Biscayne Bay, GB = Galveston Bay, PS = Puget Sound, SFBE = San Francisco Bay Estuary, SLE = Saint 

Louis River Estuary, UMR = Upper Mississippi River, ULB = Upper and Lower [New York] Bay. 

5.2.6 Uncertainties and Limitations in the Effects Analysis

 This section highlights the primary uncertainties and limitations associated with the 

approach and effects analyses undertaken in the BE. There are five major categories of 

uncertainty in this BE potentially limiting the interpretation of results and corresponding 

conclusions, including: (1) estimation of “expected” and “anticipated” water exposure 

concentrations used to support the effects analysis; (2) selection of chronic toxicity values 

representative of the sensitivity of aquatic organisms; (3) use of surrogate species effects 

information for listed species; (4) estimation of risk for aquatic-dependent birds and mammals; 

and (5) representativeness of results to listed species in other action areas. Pollutant-specific 

limitations and uncertainties are addressed on a pollutant-by-pollutant basis in Section 5.4. 

5.2.6.1 Estimation of Exposure Concentrations Used to Support Effects Analysis 

 The action area applicable to the evaluation of pollutants identified for detailed 

consideration includes all U.S. waters navigable by vessels covered under the VGP and sVGP 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-50 

(Appendix E). EPA selected two screening-level models to represent the estuarine and river 

water bodies included within the scope of the applicable action area and to estimate the exposure 

concentrations evaluated in the risk analysis. The purpose of the screening-level water quality 

models are to identify major water quality issues, provide valuable information on potential 

pollutants of concern, and identify data gaps. Known limitations and uncertainties associated 

with the screening-level model approach used by EPA include: 

 Model pollutant load inputs reflect the data limitations in available vessel discharge 

data (discharge flow, discharge concentrations, and vessel populations); 

 Model inputs assume no background concentrations of pollutants are present in the 

receiving water; and 

 Model is not designed to evaluate localized impacts or stressors. 

 EPA used the best scientific and commercial data available to develop the pollutant loads 

used in the modeling analysis; however, data gaps exist for the various combinations of vessel 

types, discharges, pollutants, and vessel populations. Although EPA used best professional 

judgment to extrapolate the pollutant concentrations and flow information among the different 

vessel types and vessel populations, the extrapolation of information represents a source of 

uncertainty in the analysis. Data collected as part of the monitoring requirements proposed in 

VGP and sVGP will improve the quality of information used for EPA’s future analyses. For 

example, EPA requires monitoring of ballast water treatment system metrics and certain 

discharge parameters. EPA can later use these results to evaluate the whether ballast water 

treatment systems continue to perform after installation, and whether EPA continunes to meet its 

objectives for reducing risk from ballast water discharges. 

 For purposes of the model, EPA assumed that the background concentration for all 

pollutants in the hypothetical harbor was zero. Although this assumption is likely unrealistic, 

removing other loading considerations from model calculations allowed EPA to evaluate 

whether incidental discharges from vessels covered under the VGP and sVGP alone have the 

potential to cause exposure concentrations in the receiving waters that exceed the pollutantspecific effects thresholds presented in Section 5.3. Therefore, the model output used to inform 

the effects analysis does not directly evaluate the potential for vessels to contribute to pollutant 

impairments or quantify if vessel pollutant loads serve as the “tipping point” between exceeding 

and not exceeding a given effect threshold. However, by looking at the risk quotent number, 

EPA can get a sense as to whether incidental vessel discharges covered under the VGP and 

sVGP would make notable or sizable contributions to exposure concentrations which exceed 

pollutant specific thresholds. 

Both the fraction of freshwater estuary model and the river dilution model assume 

instantaneous and universal mixing within the hypothetical harbor. The screening models are not 

designed to examine impacts on a local scale such as stagnant side embayments or coves within 

the larger water bodies evaluated to support the effects analysis. EPA selected model input 

values to represent the range of conditions likely to occur within the broader action area, and 

when appropriate, identified model parameters to bound in the analysis and reflect a “worst case” 

scenario (e.g., minimum river flow from the nine rivers considered in the analysis). EPA assumes 

that within the context of the broader water bodies potentially receiving vessel discharge loads 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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equivalent to 3 to 370 VGP vessels and 12 to 1,000 sVGP vessels discharging continuously the 

screening-level models appropriately characterizes the range of potential exposure 

concentrations and subsequent pollutant risk. EPA believes that the analysis also represents 

vessel discharges to intracoastal waterways for two primary reasons: 

 Several of the major water bodies (e.g., Elizabeth River, Charleston Harbor, Biscayne 

Bay) that are part of the Atlantic and Gulf intracoastal waterway were considered in 

developing the receiving characteristics for the estuary model; and 

 EPA assumes that the daily vessel equivalent population is likely significantly lower 

in these waters than in a harbor environment even though a significant amount of 

vessel traffic travels these waters on a daily basis. 

Although listed species present in intracoastal waterways may be directly exposed to a 

vessel discharge plume, EPA expects the exposure duration to be brief such that the chronic 

effects thresholds considered in the BE are not of concern. 

Although the ECs calculated for the effects analysis do not specficially account for 

localized effects, EPA considered the potential risk posed by vessel discharges in other unique 

environments and determined vessel discharges are unlikely a concern. For example, in the case 

of localized changes in buffering capacity due to climate change, exhaust gas scrubber 

discharges have the greatest potential to depress pH values in receiving waters as the discharge 

can have pH values as low as 3 (USEPA, 2011b). As discussed in EPA’s economic and benefit 

analysis for the 2013 VGP, EPA believes that a maximum of 5 to 10 percent of affected vessels 

would install this treatment by the end of the permit period. EPA assumes that the concurrence of 

site-specific changes in buffering capacity with a significant population of vessels discharging 

exhaust gas scrubber water is highly unlikely to occur. Similar to the assessment of intracoastal 

waterways, EPA assumes that any localized effects caused by direct exposure to an exhaust gas 

scrubber discharge plume will be brief such that risk effects to listed species considered in the 

BE are not of concern. 

Lakes and reservoirs isolated from the major rivers navigable by vessels covered under 

the VGP and sVGP represent another unique environment that was not specifically modeled in 

the EC analysis; however, EPA believes that the maximum exposure concentrations estimated in 

the hypothetical river harbor can be used to inform effects determinations for species identified 

in the lake environment. As described in Appendix E, EPA conducted internet searches to assess 

the potential vessel populations that operate on lakes and reservoirs greater than 0.5 square mile. 

EPA determined that vessel populations operating on lakes and reservoirs are significantly 

smaller than vessel populations operating in river harbors, and that the vessels also operate (and 

discharge) for limited periods of time (e.g., a two hour dinner cruise several times per week). 

Therefore, EPA concluded that the permitted vessel equivalents in lake environments are very 

likely to be significantly lower than the vessel equivalents estimated in the two river RAAs 

included in the effects analysis, which would result in lower estimated pollutant concentrations 

in a lake environment than the maximum exposure concentration calculated for the hypothetical 

river harbor. Given this assumption, EPA believes that the calculated river EC values and 

subsequent risk conclusions for freshwater species adequately capture the potential “worst case” 

scenario pollutant concentrations and risks in a lake environment. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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5.2.6.2 Selection of Chronic Toxicity Values Representative of the Sensitivity of Aquatic 

Organisms 

The consideration and selection of appropriate chronic values from empirical laboratory 

toxicity test data from which risk to aquatic organisms is assessed is similar to that of EPA ALC 

development, in that the quality and acceptability of the data depend on the test conditions and 

the care with which tests were conducted. Chronic toxicity tests in general encompass a variety 

of specific test types, each with their own associated uncertainties. For example, full and partial 

life cycle tests contain the lowest uncertainty, but due to time and associated costs, these tests are 

rarely conducted. In contrast, early life-stage (ELS) tests are far more common, but because 

these tests exclude certain life stages (e.g., adult) they cannot be used to quantify effects on 

reproduction. With all chronic tests, using wild-caught test organisms introduces greater 

uncertainty than using test organisms reared in the laboratory, although certain species cannot be 

reared under laboratory conditions. Uncertainty is also associated with the selection of chronic 

endpoints. Nearly all chronic tests measure growth and survival, whereas reproduction endpoints 

can only be measured in full and partial life cycle tests. The specific selection of endpoints used 

to measure growth and reproduction can also introduce test uncertainty. For example, measures 

of fish reproduction can include different combinations of egg production, viability and 

hatchability. Many reproductive endpoints are known to be highly variable; however, reduced 

reproduction may be one of the most ecologically significant toxicological responses pertinent to 

listed species (Mount et al., 2003). Growth can be measured as mean individual wet or dry 

weight (or wet or dry weight gain); standard body, fork or total length; or biomass (total wet or 

dry weight of survivors). Finally, the statistical method by which chronic toxicity is quantified 

can introduce uncertainty. Historically, most chronic toxicity data were evaluated using 

hypothesis testing to derive a no observed effect concentration (NOEC) and lowest observed 

effect concentration (LOEC) (and resultant maximum acceptable toxicant concentration or 

MATC) from the test concentration series. The resulting values are highly dependent on the test 

concentrations selected, and the number of replicates at each treatment level. In many cases, the 

level of protection afforded by the NOEC-LOEC approach is driven more by study design and 

data precision than ecological significance (see Mount et al., 2003 for more discussion). In 

contrast, the use of point estimates of chronic toxicity, such as the EC10 or EC20, overcome many 

of the shortcomings of the NOEC-LOEC approach, although the reporting of point estimates 

associated with a chronic effect is historically less common, and debate continues with regards to 

the significance to the individual organism (and population) of an estimated 10% reduction in 

chronic response, such as growth. 

In addition to survival, growth and reproduction, there are many more biological 

responses that have been observed in response to chronic toxicant exposure, both at the whole 

organism level (e.g., behavior) and at lower levels of biological organization (e.g., biochemical 

or histological changes). For many of these endpoints, the relationship to the assessment goal 

(for this analysis) of “protection of listed aquatic organisms” is less direct. Although 

consideration of endpoints not proscribed by the 1985 Guidelines is an option under any 

approach, the applicability of the endpoint to the assessment goal, and the level of uncertainty 

surrounding the endpoint, requires careful consideration. As a general rule, the use of alternative 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-53 

endpoints is discouraged unless a compelling argument can be made that inclusion would reduce 

the overall level of uncertainty in the analysis towards achieving the assessment goal. 

EPA broadly classifies the uncertainty regarding estimation of chronic toxicity in this 

analysis into three areas: 

 Degree of data availability (e.g., species versus genus versus family); 

 Test and endpoint uncertainty (e.g., full or partial life cycle versus ELS test; selection 

of endpoint); and 

 Method of effect quantification (NOEC-LOEC versus point estimate). 

All of these issues strongly influence evaluation of the potential risk of a given exposure 

concentration. Given the potential uncertainty surrounding these considerations for even the 

“best” data used in this approach, it is no surprise that chronic values obtained using lower tiered 

data can exhibit high variability. 

EPA relies on the 1985 Guidelines data requirements and data selection process as the 

process by which information is fully-vetted for its utility and applicability in this BE analysis. 

5.2.6.3 Use of Surrogate Species Effects Information for Listed Species 

For listed aquatic and aquatic-dependent species, appropriate chronic toxicity data are 

simply non-existent with only a few exceptions (e.g., ammonia toxicity to listed unionid mussel 

species). Considering that adequate chronic toxicity data are limited for nearly all pollutants 

selected for detailed evaluation in this BE, particularly for saltwater organisms, use of surrogate 

data from other representative species is required in order to facilitate acceptable risk assessment. 

For each pollutant evaluated in Section 5.3, EPA presents the surrogate species data used to 

calculate the RQ values to support the risk conclusions for the 18 listed species taxonomic 

groups. EPA established the surrogate species types in Table 5-12 to classify the chronic toxicity 

data and to provide a consistent presentation of the RQ values in the quantitative analysis. Table 

5-12 presents the crosswalk for how surrogate species data and the resulting RQs were used to 

inform the pollutant-specific risk conclusions for the 18 listed species taxonomic groups at the 

end of each pollutant discussion. 

Table 5-12. Crosswalk for Surrogate Species Type to Listed Species Taxonomic 

Group

Listed Species Taxonomic Group a Surrogate Species Type 

Terrestrial Mammal Mammals (Freshwater) 

Marine Mammal Mammals (Saltwater) 

Coastal/Marine Bird Birds (Saltwater) 

Snake and Other Reptiles Birds (Freshwater) b

Sea Turtle Birds (Saltwater) b 

Beetle and Aquatic Insects Freshwater Invertebrate 

Amphibian Freshwater Vertebrate 

Freshwater Fish/Inland Salmonid Freshwater Vertebrate 

Freshwater Fish/Inland Sturgeon Freshwater Vertebrate 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Table 5-12. Crosswalk for Surrogate Species Type to Listed Species Taxonomic 

Group

Listed Species Taxonomic Group a Surrogate Species Type 

Anadromous Salmonid (Juvenile life-stages only) Freshwater Vertebrate 

Anadromous Salmonid (Adults) Estuarine/Marine Vertebrate 

Anadromous Sturgeon (Juvenile life-stages only) Freshwater Vertebrate 

Anadromous Sturgeon (Adults) Estuarine/Marine Vertebrate 

Unionid Mussel Freshwater Invertebrate 

Freshwater Shrimp/Crustacean Freshwater Invertebrate 

Freshwater-Saltwater Aquatic and Wetland Plants Freshwater Plant (Vascular) and Saltwater Plant 

(Vascular) 

Estuarine/Marine Fish Estuarine/Marine Vertebrate 

Saltwater Corals Estuarine/Marine Invertebrate 

Saltwater Bivalve Mollusk Estuarine/Marine Invertebrate 

Seagrass Saltwater plant (Vascular) 

a) Listed species taxonomic groupings are meant to roughly coincide with the Species Group provided 

in USFWS Environmental Conservation Online System (ECOS), but with further delineation 

according to life history information and attributes to demonstrate the strong representation given by 

the subset of 82 RAAs listed species to the 612 aquatic and aquatic-dependent species and their 

critical habitats that may be affected by the VGP and sVGP. 

b) No data are readily available to calculate exposure concentrations for reptiles; therefore, EPA used 

data from birds as the closest related surrogate. 

There are two primary areas of uncertainty associated with the use of chronic effects data 

gleaned from tests with surrogate species. First, the surrogate species selected for use in this BE 

were not necessarily the taxonomically closest related organism for which information was 

available. Instead, the most sensitive surrogate species was selected, which provides an added 

measure of conservatism in the risk analysis. From a taxonomic perspective, the best surrogates 

would be those that are most closely related (within same Genus or Family), live in the same 

environment, and consume the same food as the listed species of interest. However, there may be 

relatively little toxicity data for such closely-aligned surrogates, and other surrogate species may 

be considerably more sensitive to a given pollutant. Both of these considerations 

(quantity/representativeness of toxicity data and sensitivity) influenced EPA’s selection of 

surrogate species, with preference given toward selecting the most sensitive surrogate species. 

For example, fewer data exist describing the effects of toxic pollutants on chinook and sockeye 

salmon, but a wealth of information exists describing the effects of toxic pollutants on rainbow 

trout. Thus, the approach taken here was designed to be appropriately conservative rather than 

eliminate some of the potential uncertainty of the extrapolation of surrogate data to listed 

species. 

The second area of uncertainty has to do with the assumption that listed species may be 

uniquely sensitive to pollutants compared to surrogate species. EPA is currently not aware of any 

one factor that could be applied universally to surrogate data to ensure protection to listed 

aquatic species. However, comparative analysis of the extreme chronic sensitivity of the darter 

species, Etheostoma fonticola, and the generally-sensitive surrogate species rainbow trout, to 

copper (Besser et al., 2005a) suggests that a factor of 2.0 may be a reasonable safety factor. In 

addition to the Besser study, related studies (e.g., Dwyer et al. 2005; Gensemer et al. 2007; 

Mayer et al. 2008) have shown that derivation of an appropriate safety adjustment factor of 2.0 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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may be applicable with the use of taxonomically-representative and pollutant-sensitive surrogate 

taxa. Ecotoxicological data from aquatic toxicity tests with four pollutants with different mode of 

action were used, as well as readily available predictive tools and other scientifically-accepted 

conventions (e.g., acute-chronic ratios). Combined, these studies suggest that: 1) listed aquatic 

vertebrate species are not universally more sensitive to contaminant exposure than other aquatic 

vertebrates on a toxicological basis, and, perhaps equally important, 2) surrogate fish species 

appear to represent other listed fish species toxicologically. For example, with regard to acute 

toxicity, it has already been established that rainbow trout (Oncorhynchus mykiss), a sensitive 

surrogate freshwater fish species, is equal to or more sensitive than listed and related aquatic 

vertebrate species 80 percent of the time (Dwyer et al., 2005; Mayer et al., 2008). For this BE, 

application of a risk adjustment factor of 2.0 to EPA’s chronic criterion for a pollutant (i.e., 

CCC) is used as a final “ground-truthing” measure to evaluate overall level of potential risk to 

listed aquatic species (or taxa). A risk adjustment factor of 2.0 has recently been recommended 

for use on listed freshwater fish species (Mayer et al., 2008). 

5.2.6.4 Estimation of Risk for Aquatic-dependent Birds and Mammals 

Estimation of risk for aquatic-dependent birds and mammals from direct exposure to a 

pollutant in water is complicated because the exposure pathway of primary concern is via the 

oral [ingestion] route. Proper risk analysis would consider potential food web effects (e.g., 

biomagnification), which would require consideration of a pollutant’s fate properties (e.g., water 

solubility, persistence, octanol: water partition coefficient or log Kow, etc.). 

The risk analysis performed by EPA in this BE as described in Section 5.2.3 and 

conveyed in Section 5.3 below incorporates food and water ingestion data for the wildlife species 

available from the literature to estimate an ingested dose for wildlife based on a maximum water 

[exposure] concentration. This oral dose was then compared to an oral dose (NOAEL) from the 

literature that would likely be protective of listed wildlife species. However, very few wildlife 

species ingest only one type of prey species. Prey of wildlife species may come from different 

trophic levels, which in turn may exhibit BAFs that differ from each other. This is particularly 

true for organic pollutants with large Kow values, which also tend to be the pollutants with the 

greatest potential for biomagnification. EPA has incorporated the use of different BAFs for prey 

from only two trophic levels (macroinvertebrates indicative of trophic level 2 secondary 

consumers and vertebrates indicative of trophic level 3 and 4 fishes) to estimate potential 

pollutant concentrations in prey during the calculation of the ingested dose to wildlife from 

exposure to maximum concentrations in water. With the exception of benzo(a)pyrene, it was 

determined that such consideration of bioaccumulation in different trophic levels is largely 

unwarranted. 

As noted above in Section 5.2.6.3, due to limited chronic toxicity data available for 

wildlife species, data from surrogate wildlife species were used, but in this case, selection was 

not always based on the surrogate species with the lowest NOAEL just because it was the only 

species for which an NOAEL exists. The ramification for the effects analysis is that adequacy of 

surrogacy is uncertain. For example, while many of the test species may be grainivoruous (seed 

eating) birds , such as domestic chickens and doves, the listed species may be more piscivorous 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-56 

(fish eating) birds. However, data on differences in dietary absorption of the pollutants in this BE 

were not available for specific dietary differences between the listed and surrogate species. 

5.2.6.5 Representativeness of Results to Other Listed Species 

As discussed in Section 5.2.5, EPA uses the risk conclusions for the 82 RAA listed 

species to inform its effects determinations for the 612 aquatic and aquatic-dependent species 

and their crticial habitats that may be affected by the VGP and sVGP by establishing 18 listed 

species taxonomic groups as the link between the two lists (Table 5-11). In general, the listed 

species taxonomic groupings determined by the subset of 82 RAA species are representative of 

all the listed species evaluated in this BE (Appendix E). Numerically, the 82 RAA listed species 

represents approximately 13 percent of the full list of 612 species to which the effects 

determinations for ANS apply, and approximately 18 percent of the 454 species to which the 

effects determinations for pollutants identified for detailed evaluation apply. 

In terms of overall taxonomic representation, EPA estimates that the subset of 82 RAA 

listed species represents the vast majority of the types of threats, critical life stages, and habitats 

associated with the full listed of 612 listed species that may be affected by the VGP and sVGP. 

The 18 listed species taxonomic groups established by the RAA listed species adequately 

captures several potentially sensitive groups such as unionid mussels and inland and anadromous 

fishes, freshwater planktonic crustaceans, amphibians, seagrasses (Johnson’s), saltwater corals 

and bivalve mollusks, coastal/marine birds, and marine and terrestrial mammals. The list of 82 

RAA listed species spans nearly the full range of critical life stages (e.g., aquatic developmental 

in the case of amphibians) and habitats (e.g., near shore coastal for manatee and nesting piping 

plover) representative of the entire action area, species, critical habitats that may be affected by 

the VGP and sVGP. Absent among the 82 RAA listed species are several listed freshwater snails 

and benthic crustaceans where major threats and critical life stages and/or habitat may not be 

adequately represented. However, in these particular cases EPA believes that the current list of 

82 RAA listed species provides adequate overall coverage even among taxa that are only 

distantly related. Existing and current literature (Mayer and Ellerseick, 1986; Mayer et al., 2008) 

indicates that freshwater unionid mussels are good ecotoxicologically-sensitive surrogates for 

gill-bearing snails, planktonic crustaceans are good sensitive surrogates for all other crustaceans, 

and salmonids are good surrogates for other fresh- and saltwater fish. 

5.3 POLLUTANT-SPECIFIC RISK SUMMARIES

The following text and corresponding tables are used to identify and describe all pertinent 

information considered in summarizing risk to listed aquatic and aquatic-dependent species and 

their critical habitats based on the approach described in Section 5.2. The subsections below are 

subdivided by pollutant category (classical, metals, moncyclic and polycyclic aromatic 

hydrocarbons) and further subdivided by individual pollutant. Each pollutant-specific subsection 

includes a summary of direct and indirect effects data used to support the analysis and 

corresponding data tables with the various RQs that have been calculated. Risk from direct 

exposure is evaluated according to major taxonomic group separated according to fresh-and 

saltwater habitat (i.e., Freshwater Aquatic Vertebrates, Freshwater Aquatic Invertebrates, 

Freshwater Aquatic Plants, etc.) as described in Section 5.2.5. Each pollutant-specific subsection 

is followed by the semi-quantitative analysis of risk from indirect effects, which is then followed 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-57 

by a final table summarizing risk conclusions made for the major listed species taxonomic 

groupings provided in Table 5-11. Collectively, the risk conclusions conveyed in this subsection 

are used with other information to inform EPA’s effects determination presented in Section 7 of 

this BE. 

5.3.1 Classical Pollutants

Classical pollutants combine several standard water quality parameters such as 

conductivity, salinity, temperature, pH, etc. with other parameters EPA defines as conventional 

pollutants (e.g., total suspended solids). For convenience, this group also includes another 

common pollutant, total residual chlorine. Of this diverse group of classical pollutants, only 

those pollutants with toxic effects to aquatic and aquatic-dependent species lend themselves to 

analysis of quantitative effects. Within the list of pollutants selected for detailed analysis (see 

Section 3.2.3 of this document), these are limited to just total residual chlorine and total 

suspended solids. 

5.3.1.1 Total Residual Chlorine (TRC) 

Total residual chlorine is detected in bilgewater, deck washdown, and graywater 

discharges from covered vessels (see Section 3.2.3.6). Because of the low boiling point of 

chlorine (-34.04°C), chlorine is a gas under environmental conditions (HSDB, 2009). Chlorine 

gas released into water first dissolves and then undergoes immediate conversion into two forms 

of free chlorine: hypochlorous acid (HOCl) and the hypochlorite ion (OCl-). If the water contains 

ammonia, the solution will likely also contain two forms of combined chlorine: monochloramine 

and dichloramine. Because all four of these forms of chlorine can be toxic to aquatic organisms, 

the term “total residual chlorine or TRC” is used to refer to the sum of free chlorine and 

combined chlorine in fresh water. However, because salt water contains bromide, addition of 

chlorine also produces hypobromous acid (HOBr), hypobromous ion (OBr-), and bromamines 

(USEPA, 1984a); hence, the term “chlorine-produced oxidants or CPO” is used to refer to the 

sum of these oxidative products in salt water. Both terms, TRC (fresh water) and CPO (salt 

water), are intended to refer to the sum of free and combined chlorine and bromine as measured 

by standard methods. 

Chlorine is not expected to bioaccumulate in plants or animals since it reacts with the 

moist tissues of living systems (Compton, 1987; Schreuder and Brewer, 2001; Schmittinger et 

al., 2006). Also, chlorine is toxic to microbial communities; therefore, biodegradation is not 

considered to be a relevant fate process (Vetrano, 2001). In general, the hypochlorous acid 

formed during the dissolution of chlorine in natural waters reacts with organic and inorganic 

materials, ultimately forming chloride ion, oxidized inorganics, chloramines, trihalomethanes, 

oxygen, and nitrogen. Consequently, chlorine (as well as CPO and TRC) does not persist in the 

aquatic environment. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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5.3.1.1.1 Direct Effects from TRC 

Table 5-13 summarizes the chronic toxicity data available for calculating RQA,W for 

aquatic listed species exposed to predicted concentrations of TRC in water receiving permitted 

discharges from covered vessels. Table 5-14 presents the maximum exposure concentrations 

estimated in the hypothetical estuary and river harbor under pre- and post-permit conditions, as 

well as the corresponding RQA,Ws calculated for each taxonomic group based on the various 

chronic toxicity threshold values (in this case, CTETA,W) readily available for representative 

surrogate taxa. 

Risk to Freshwater Aquatic Animal and Plant Species - TRC

The overall risk to freshwater aquatic organisms from maximum exposure to TRC from 

permitted vessels is low. All RQA,Ws are below a value of 0.01, particularly for freshwater 

vascular plants. The highest RQ is 0.000877 estimated for freshwater invertebrates under the prepermit condition. Control measures implemented as part of the issuance of the permits is 

anticipated to lower the risk to all freshwater species exposed to TRC from permitted vessel 

discharges by approximately 3 percent. 

Risk to Saltwater (Estuarine/Marine) Aquatic Animal and Plant Species - TRC 

The risk to saltwater aquatic organisms from maximum exposure to TRC (or equivalent 

CPO) from permitted vessels is also low. The RQs for saltwater vertebrate and invertebrate 

species are substantially below a RQA,W of 0.01. The highest RQ calculated from toxicity studies 

is 0.0983 estimated for saltwater invertebrates under the pre-permit condition using an acute 

toxicity value divided by an appropriate ACR. No appropriate data are available for saltwater 

vascular plants exposed to TRC, however calculating pre- and post-permit RQs using the CCC 

indicates “negligible” to “remote”12 risk, with RQA,Ws of 0.286 and 0.088, respectively. Control 

measures implemented as part of the issuance of the permits is anticipated to lower the risk to all 

saltwater species exposed to TRC from permitted vessel discharges by approximately 69 percent. 

Risk to Birds and Mammals - TRC 

The risk of exposure to aquatic-dependent birds and mammals from TRC found in 

permitted vessel discharges is via drinking of [fresh] surface water alone, because TRC does not 

bioaccumulate in the tissues of prey [food] organisms. Furthermore, as noted above, TRC has a 

short half-life in water, and therefore, does not remain readily available to the organism for 

uptake. The chronic [oral ingestion] toxicity threshold value (in this case, CTETO) for rodents is 

15 mg/kg of body weight per day based on the absence of toxicity in rodents that received 

chlorine as hypochlorite in drinking water for up to 2 years (equivalent to a tolerable daily intake 

or TDI of 5 mg/L) – WHO (2003). No such data are available for birds, but CTETO is not 

expected to be different. 

 

12 In this BE, EPA defined the terms “negligible” and “remote” as the pollutant presents no risk to listed species 

(Table 5-10). See Section 5.2.3 for additional discussion of the risk scale established in this BE. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-59 

Table 5-13. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Total Residual Chlorine (freshwater) and Chlorineproduced Oxidants (saltwater) 

Surrogate 

Aquatic Species 

Type 

Surrogate Species 

Exposure/ 

Effect 

Endpoint 

NOEC - 

LOEC 

(μg/L) 

CTETA,W 

(μg/L) Study (source) 

Freshwater 

Vertebrate 

Fathead minnow, 

Pimephales 

promelas 

LC Test – 

Growth and 

Survival on 

progeny 

6 - 21 11.22 Arthur et al. 1975 

(1984 ALC doc.) 

Freshwater 

Invertebrate 

Cladoceran, 

Daphnia magna 

LC Test – 

Survival 2 - 7 3.742 Arthur et al. 1975 (1984 ALC doc.) 

Freshwater Plant 

(Vascular) 

Eurasian 

watermilfoil, 

Myriophyllum 

spicatum 

4-d Test – 

Reduced 

weight gain of 

total plant and 

shoots 

- 50 

Watkins and 

Hammerschlag 

1984 

(1984 ALC doc.) 

Estuarine/Marine 

Vertebrate 

Tidewater 

silverside, 

Menidia 

ELS Test – 

Growth and 

Survival 

40 - 54 46.48 

Goodman et al. 

1983 

(1984 ALC doc.) 

Estuarine/Marine 

Invertebrate 

Eastern oyster, 

Crassostrea 

virginica 

Acute LC50 = 

26 / Estuarine 

ACR 

(ACR=1.192) 

- 21.81 

(estimated) 

Goodman et al. 

1983 (estuarine 

ACR); Roberts and 

Gleeson 1978 

(LC50) 

Estuarine/Marine 

Plant (Vascular) Not Available - - 7.5 (CCC) 

USEPA 1984 ALC 

Document 

Surrogate 

AquaticDependent 

Species Type 

Surrogate Species Exposure 

Type Effect CTETO (mg/kg bw/d) Study (source) 

Mammals Rodents 2yr Drinking 

water 

NOAEL - 

growth 15 WHO 2003 

Birds Not Available - - - - 

LC = Life cycle, ELS = Early-life stage 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-60 

Table 5-14. Risk Quotients Based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative Surrogate Taxa to 

TRC/CPO 

Taxa 

ECW

(Pre-Permit 

Condition); 

(μg/L) 

ECW

(Post-Permit 

Condition); 

(μg/L) 

CTETA,W 

(μg/L) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Freshwater Vertebrate 

0.00328 0.00319 

11.22 0.000292 0.000284 

Freshwater Invertebrate 3.742 0.000877 0.000852 

Freshwater plant 

(Vascular) 50.00 <0.0001 <0.0001 

Estuarine/Marine 

Vertebrate 

2.14 0.66 

46.48 0.0461 0.0142 

Estuarine/Marine 

Invertebrate 21.81 0.0983 0.0303 

Saltwater plant (Vascular) 7.5 0.286 0.088 

Taxa 

ECW

(Pre-Permit 

Condition); 

(μg/L) 

ECW

(Post-Permit 

Condition); 

(μg/L) 

CTETO 

(mg/kg bw/d) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Mammals (Freshwater) 0.00328 0.00319 15 NAa NAa

Birds (Freshwater) - NAa NAa

Mammals (Saltwater) 2.14 0.66 - NAa NAa

Birds (Saltwater) - NAa NAa

a) Not applicable because TRC does not accumulate in tissue, and therefore, a risk quotient cannot be calculated as 

in Equation 5-5. 

5.3.1.1.2 Indirect Effects from TRC 

The RQs summarized above and in Table 5-14 indicate “remote” risk for direct effects of 

TRC to listed aquatic and aquatic-dependent species in this BE. Furthermore, discharge of TRC 

from covered vessels does not result in measureable concentrations in estuaries and freshwater 

receiving water bodies due to its low persistence and short half-life as discussed above, even 

under semi-continuous discharge. 

Due to its low persistence, interactions between the sediments and the water column and 

potential effects on benthos are not expected with this pollutant. There is also no basis for 

assuming indirect effects on listed species via TRC exposure and corresponding toxicity-related 

reduction in the prey base [loss of prey] available to upper trophic level organisms. The 

information summarized in Table 5-14 indicates that TRC at maximum exposure concentrations 

calculated from pre-, and especially after post-permit conditions, has essentially no risk of 

causing direct effects on vascular freshwater plants, thus indirect effects typically associated with 

the loss of aquatic and riparian vegetation, including loss of cover and changes in water quality 

parameters, are not expected for TRC. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-61 

Risk Conclusion Aquatic and Aquatic-Dependent Listed Species and Their Critical Habitats in 

RAAs - TRC

Based on the consideration of potential direct and indirect effects as outlined above, the 

following risk conclusions are being made for each of the listed species in the RAAs (see Table 

5-15). This information is used to inform decisions in the effects determinations made in Section 

7 of this document. 

Table 5-15. Summary of Risk Conclusions for Listed Species and Critical Habitats in RAAs 

to TRC 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumption 

Saltwater Corals Remote  Exposed via water column only 

 Risk quotient indicates very low potential for direct chronic effects 

 Fate of TRC indicates very low potential for indirect effects (loss of 

prey and change in habitat/water quality parameters) 

 Surrogate CTET is representative and appropriate 

Unionid Mussels Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a conservative 

ACR of 17.64 for amphipod Gammarus pseudolimnaeus (USEPA, 

1984a) and recent acute 96-hr EC50s from sensitive life stages 

(glochidia) of freshwater mussels (>40 μg/L – see Wang et al., 

2007a). Calculation results in pre- and post-permit RQs of 0.00145 

and 0.00141, respectively. 

Saltwater Bivalve 

Mollusk 

Remote  RQ directly applicable since estimated for C. virginica as presented 

in Table 5-14 above 

Freshwater Shrimp/ 

Crustacean 

Remote  Same as Saltwater Corals’ Presumptions 

 No taxon-specific acute or chronic toxicity data readily available. 

Freshwater Fish/ Inland 

Salmonid 

Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using chronic toxicity 

data from a 21-day test for juvenile Coho salmon (Larson et al., 

1977 in USEPA, 1984a). Calculation results in post-permit RQs 

approximately 0.060 or less in fresh- and saltwater. 

Anadromous Salmonid Remote  Same as Freshwater Inland Salmonids – no chronic toxicity data are 

available for salmonids tested in seawater 

Freshwater Fish/ Inland 

Sturgeon 

Remote Same as Saltwater Corals’ Presumptions 

Anadromous Sturgeon Remote Same as Saltwater Corals’ Presumptions 

Estuarine/ Marine Fish Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for M. peninsulae as 

presented in Table 5-14 above 

Beetle and Aquatic 

Insect 

Remote Same as Saltwater Corals’ Presumptions 

Amphibian Remote Same as Saltwater Corals’ Presumptions 

Snakes and Other 

Reptiles 

Remote Same as Saltwater Corals’ Presumptions 

Sea Turtles Remote Same as Saltwater Corals’ Presumptions 

Coastal/Marine Birds Remote Same as Saltwater Corals’ Presumptions 

Marine Mammal Remote Same as Saltwater Corals’ Presumptions 

Terrestrial Mammal Remote Same as Saltwater Corals’ Presumptions 

Seagrass Remote Same as Saltwater Corals’ Presumptions 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-62 

Table 5-15. Summary of Risk Conclusions for Listed Species and Critical Habitats in RAAs 

to TRC 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumption 

Freshwater- Saltwater 

Aquatic and Wetland 

Plants 

Remote Same as Saltwater Corals’ Presumptions 

 Because toxicity for chlorine is already expressed on the basis for TRC (or CPO), which 

includes several toxic forms of combined chlorine such as monochloramine and dichloramine, 

risk from mixtures is already represented in this analysis. 

5.3.1.2 Total Suspended Solids (TSS) 

Total suspended solids are expected in appreciable concentrations in bilgewater, deck 

washdown effluent, graywater, and ballast water. Each of these vessel discharges can contain 

sediments and have elevated turbidity levels and TSS (see Section 3.2.3.7). It is important to note 

here that while the focus of this analysis is on TSS, both turbidity and TSS are terms that define 

the measurement of solids or sediment in the water column. These metrics (along with measures 

of water clarity), however, measure different aspects of suspended sediments, and thus, are often 

incorrectly used interchangeably in water quality monitoring and research papers. Turbidity is 

defined as the optical property of water where suspended and dissolved materials such as silt, 

clay, finely divided organic and inorganic matter, pollutants, plankton, and other microscopic 

organisms cause light to be scattered rather than transmitted in straight lines. Turbidity is usually 

measured in nephelometric turbidity units (NTU). TSS, on the other hand, represents the actual 

gravimetric measure of the mineral and organic particles suspended in a water sample. 

Both fluctuating TSS and turbidity levels in the water column can affect aquatic life from 

fish to phytoplankton. At high TSS concentrations, for example, suspended sediment causes a 

range of “physical” environmental effects, including benthic smothering and irritation of fish 

gills (Bash et al., 2001). Much of the impact of suspended sediment at lower concentrations is 

related to its light attenuation, which reduces visual range in water and light availability for 

photosynthesis. 

For this BE, it should be noted that the Agency has published water quality criteria for 

turbidity, which include scientific assessments of the effects of turbidity on aquatic life (see 

http://www.epa.gov/waterscience/criteria/library/goldbook.pdf), but the problem that remains is 

translating the turbidity threshold into equivalent concentrations of suspended solids. In general, 

and to support the quantitative effects analysis of TSS in this BE, EPA assumes a conversion 

factor to convert from NTU to TSS (expressed in units of mg/L) ranging from 1.0 to 1.5 (see 

http://www.lakesuperiorstreams.org/understanding/param_turbidity.html). Recent review of the 

literature indicates that adverse effects to aquatic organisms are not observed at turbidities below 

5-10 NTU in freshwater (see Turbidity: A Water Quality Measure." Water Action Volunteers, 

Monitoring Factsheet Series. UW-Extension, Environmental Resources Center). Thus, applying 

the highest NTU:TSS conversion factor of 1.5 to the lowest chronic effects value to aquatic 

organisms of 5 NTU results in a TSS concentration of 3.33 mg/L, which is the conservative 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-63 

value for CTETA,W used to calculate risk quotients for the direct effects to fresh- and saltwater 

aquatic organisms below. 

5.3.1.2.1 Direct Effects for TSS 

Table 5-16 summarizes the chronic toxicity data available for calculating RQA,W for 

aquatic listed species exposed to predicted concentrations of TSS in water receiving permitted 

discharges from covered vessels. Table 5-17 presents the maximum exposure concentrations 

estimated in the hypothetical estuary and river harbor under pre- and post-permit conditions, as 

well as the corresponding RQA,Ws calculated for each taxonomic group based on the various 

chronic toxicity threshold values (CTETA,W) readily available for representative surrogate taxa. 

Risk to Freshwater Aquatic Animal and Plant Species - TSS

The overall risk to freshwater aquatic organisms from maximum exposure to TSS from 

permitted vessels is remote. A RQA,W of only 0.000701 is estimated under the pre-permit 

condition. Control measures implemented as part of the issuance of the permits is anticipated to 

lower the risk to all freshwater species exposed to TSS from permitted vessel discharges by 

approximately 30 percent. 

Risk to Saltwater (Estuarine/Marine) Aquatic Animal and Plant Species - TSS 

The overall risk to saltwater aquatic organisms from maximum exposure to TSS from 

permitted vessels is also remote. A RQA,W of only 0.0607 is estimated under the pre-permit 

condition. Control measures implemented as part of the issuance of the permits is anticipated to 

lower the risk to all saltwater species exposed to TSS from permitted vessel discharges by 

approximately 36 percent. 

Risk to Birds and Mammals - TSS

No risk of exposure to aquatic-dependent birds and mammals to TSS from permitted 

vessel discharge is anticipated because TSS does not bioaccumulate in aquatic prey items, and 

therefore, is not expected to be available to wildlife for uptake. 

Turbidity standards do exist to ensure the quality of drinking water in the United States. 

Drinking water produced by treatment systems that use conventional or direct filtration methods 

cannot have turbidities higher than 1 NTU, and at least 95 percent of the drinking water samples 

collected in a month must have turbidities less than or equal to 0.3 NTU 

(http://water.epa.gov/drink/contaminants/index.cfm#). Assuming this level [for humans] 

adequately reflects the concentration of turbidity at which taste may be impaired and drinking 

intake diminished, risk to wildlife from TSS at maximum concentrations is expected to be 

“remote” (i.e., 0.3 NTU x conversion factor of 1.5 = 0.45 mg TSS/L; ECW (pre-permit condition) 

of 0.00233 mg TSS/L ÷ 0.45 mg TSS/L= RQ of only 0.00518). 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-64 

Table 5-16. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Total Suspended Solids (TSS) 

Surrogate Aquatic 

Species Type 

No Adverse Effect 

Concentration for Turbidity 

measured in NTU 

(see text above) 

NTU:TSS Ratio CTETA,W 

(mg/L) 

Freshwater and 

Estuarine/Marine 5 - 10 1 5.00 

Freshwater and 

Estuarine/Marine 5 - 10 1.5 3.33 

Surrogate AquaticDependent Species Type Surrogate Species Assessment Type CTETA,W 

(mg/kg bw/d) 

Mammals Not Available - - 

Birds Not Available - - 

Table 5-17. Risk Quotients Based on Division of Pre- and Post-permit 

Exposure Concentrations by Chronic Toxicity Effect Thresholds of 

Representative Surrogate Taxa for Total Suspended Solids (TSS) 

Taxa 

ECW

(Pre-Permit 

Condition); 

(mg/L) 

ECW

(PostPermit 

Condition); 

(mg/L) 

CTETA,W 

(mg/L) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Freshwater Environment 0.00233 0.00162 3.33 0.000701 0.000488 

Estuarine/Marine 

Environment 0.202 0.13 3.33 0.0607 0.0389 

Taxa 

ECW

(Pre-Permit 

Condition); 

(mg/L) 

ECW

(PostPermit 

Condition); 

(mg/L) 

CTETO 

(mg/kg 

bw/d) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Mammals (Freshwater) 0.00233 0.00162 - NAa NAa

Birds (Freshwater) - NAa NAa

Mammals (Saltwater) 0.202 0.13 - NAa NAa

Birds (Saltwater) - NAa NAa

a) Not applicable because TSS does not accumulate in tissue, and therefore, a risk quotient cannot be 

calculated as in Equation 5-5. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-65 

5.3.1.2.2 Indirect Effects for TSS 

The RQs summarized above and in Table 5-18 indicate “remote” risk for direct effects of 

TSS to listed aquatic and aquatic-dependent species in this BE. Furthermore, discharge of TSS 

from covered vessels are not expected to result in appreciable concentrations in estuaries and 

freshwater receiving water bodies, likely due to rapid settling of solids on bottom surfaces. 

There is no basis for assuming indirect effects on listed species via TSS exposure and 

corresponding toxicity-related reduction in the prey base [loss of prey] available to upper trophic 

level organisms. Since the information summarized in Table 5-17 indicates that TSS at 

maximum exposure concentrations calculated from pre-, and especially after post-permit 

conditions, has little risk of directly affecting fresh- and saltwater aquatic organisms, indirect 

effects typically associated with physical smothering, including loss of cover and changes in 

water quality parameters, are also not expected for TSS. 

Risk Conclusion for Aquatic and Aquatic-Dependent Listed Species and Their Critical Habitats 

in RAAs - TSS

Based on the consideration of potential direct and indirect effects as outlined above, the 

following risk conclusions are being made for each of the listed species in the RAAs (see Table

5-18). This information is used to inform decisions in the effects determinations made in Section 

7 of this document. 

Table 5-18. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to TSS 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumptions 

Saltwater Corals Remote  Exposed via water column only 

 Risk quotient indicates very low potential for direct 

chronic effects. 

 Fate of TSS indicates very low potential for indirect 

effects (loss of prey and change in habitat/water quality 

parameters) 

 Surrogate CTET is representative and appropriate 

Unionid Mussels Remote Same as Saltwater Corals’ Presumptions

Saltwater Bivalve Mollusk Remote Same as Saltwater Corals’ Presumptions 

Freshwater Shrimp/ Crustacean Remote Same as Saltwater Corals’ Presumptions 

Freshwater Fish/ Inland 

Salmonid 

Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed since the preponderance of 

data used as CTET was salmonid-specific toxicity data 

as summarized in Bash et al. (2001). 

Anadromous Salmonid Remote Same as above for Freshwater Inland Salmonids – no 

chronic toxicity data are available for salmonids in seawater 

Freshwater Fish/ Inland 

Sturgeon 

Remote Same as Saltwater Corals’ Presumptions 

Anadromous Sturgeon Remote Same as Saltwater Corals’ Presumptions 

Estuarine/ Marine Fish Remote Same as Saltwater Corals’ Presumptions 

Beetle and Aquatic Insect Remote Same as Saltwater Corals’ Presumptions 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-66 

Table 5-18. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to TSS 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumptions 

Amphibian Remote Same as Saltwater Corals’ Presumptions

Snakes and Other Reptiles Remote Same as Saltwater Corals’ Presumptions

Sea Turtles Remote Same as Saltwater Corals’ Presumptions

Coastal/Marine Birds Remote Same as Saltwater Corals’ Presumptions

Marine Mammal Remote Same as Saltwater Corals’ Presumptions

Terrestrial Mammal Remote Same as Saltwater Corals’ Presumptions

Seagrass Remote Same as Saltwater Corals’ Presumptions

Freshwater- Saltwater Aquatic 

and Wetland Plants 

Remote Same as Saltwater Corals’ Presumptions

5.3.2 Metals

One of the key factors in evaluating risk from exposure to metals is the bioavailability of 

the metal to an organism. Exposure to metals at toxic levels (which is partially dependent on the 

essentiality of the metal) can cause a variety of changes in biochemical, physiological, 

morphological, and behavioral patterns in aquatic organisms. In the aquatic environment, 

elevated concentrations of dissolved metals can be toxic to many species of algae, crustaceans, 

and fish because it is this dissolved form of the metal that is most readily available and taken up 

and internalized by an organism. As indicated above, some metals have a strong tendency to 

adsorb to suspended organic matter and clay minerals, or to precipitate out of solution, thus 

removing the metal from the water column. The tendency of a given metal to adsorb to 

suspended particles is typically controlled by the pH and salinity of the waterbody, as well as the 

organic carbon content of the suspended particles. If the metal is highly sorbed to particulate 

matter, then it is likely to not be in a dissolved form that aquatic organisms can process, i.e., 

bioavailable. 

Accordingly, the protection of aquatic life for metals is typically expressed in the 

dissolved metal form. This is true in the cases of several metals in fresh water, e.g., cadmium, 

copper, lead, nickel and zinc. Because of the well known influence of water hardness (calcium 

and magnesium) on metal toxicity which competitively excludes the free metal ion from 

adhering to binding sites on a biotic ligand, and thus, preventing against its toxicity (see Wood et 

al., 1997), it is appropriate to also normalize the toxicity values for these metals to a standard 

water hardness (e.g., 100 mg/L expressed as CaCO3). In contrast, the use of total metals is more 

important for aquatic-dependent animals where the primary route of exposure is assumed to be 

through the consumption of aquatic organisms, and where the digestive process is assumed to 

transform all forms of metals to the dissolved phase, thus increasing the amount of biologically 

available metals. This latter is also applicable in aquatic animals exposed to metalloids such as 

arsenic and selenium. 

The bioavailability of metals is a relative term and depends on many factors. For 

example, particulate metals complexed to suspended organic matter or clay minerals may be 

recycled into the water column and become bioavailable due to physical re-suspension (dredging 

activities) of bed sediments or bioturbation (the stirring or mixing of sediment particles by 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-67 

benthic animals). Depending on conditions in the water column and microbiological activity 

within the surficial sediment-overlying water surface layers, these physical and biological actions 

might re-mobilize the metals in the dissolved bioavailable form for potential uptake by aquatic 

organisms. Likewise, certain benthic organisms called deposit feeders might consume 

particulate-bound metals and re-release metals via digestion and excretion or introduce metals 

into the food chain when consumed by predators. Except possibly for selenium, there is an 

absence of scientific and commercial data available to accurately account for these other 

pathways of potential exposure in this BE for metals. 

5.3.2.1 Aluminum (Total) 

Total aluminum is expected to be found at appreciable concentrations in at least some 

samples for all discharge types selected for detailed analysis in this BE, and particularly from 

deck washdown discharges, followed by fish hold discharges, and then stern tube packing gland 

discharges (see Section 3.2.3.5). Because kinetic considerations, complex formation, and other 

interactions in natural waters greatly influence the form of aluminum in the aqueous 

environment, aluminum speciation in ambient waters is not easily predicted, and no available 

analytical measurement (besides total recoverable aluminum) is known to be ideal for accurately 

expressing toxicity for aluminum. 

Aluminum, like other metals, generally acts as a surface active toxicant, exerting its damage by 

binding to anionic sites on respiratory surfaces of aquatic animals, such as a fish gill (Wood et 

al., 1997). The physiological manifestation of these deleterious surface effects at the gill include 

both ionoregulatory and respiratory effects. Ionoregulatory effects of aluminum predominate at 

low pH (e.g., less than pH 5.0) and include a mechanism similar to hydrogen ion toxicity alone, 

i.e., sodium uptake blockade (Playle and Wood, 1989). In moderately acidic water, it is generally 

the respiratory effects of aluminum that predominate. Respiratory effects are likely the result of 

the physical coating of the gills which occurs when aluminum-rich water passes into the more 

basic gill microenvironment (Gensemer and Playle, 1999). Overall, aluminum toxicity to fish 

species is substantially greater at low pH, particularly for salmonids, and aquatic invertebrates 

are generally less sensitive to aluminum when compared with fish. For this BE and based on 

recent evidence from EPA’s Vessel Study Report to Congress (USEPA, 2010), EPA assumes pH 

in ambient receiving waters above 6.0 and less than 9.0. 

5.3.2.1.1 Direct Effects from Aluminum 

Table 5-19 summarizes the chronic toxicity values available for calculating the risk 

quotients for aquatic and aquatic-dependent species exposed to total aluminum. Table 5-20 

presents maximum exposure concentrations estimated in ambient receiving waters (ECW), in 

tissues of aquatic organisms exposed to those concentrations (ECT), and in oral doses of aquaticdependent animals ingesting food (prey) and water in those receiving waters (ECO). Maximum 

exposure concentrations in ambient receiving water are from the hypothetical harbor modeling 

(pre- and post-permit condition), as described above in Section 5.2.1. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-68 

Risk to Freshwater Aquatic Animal and Plant Species - Aluminum

The overall risk to freshwater aquatic organisms as a result of maximum exposure in 

ambient waters from aluminum discharged by permitted vessels is remote. All RQA,Ws are below 

a value of 0.001. The highest RQ is 0.00069 estimated for freshwater vertebrates under the prepermit condition. Control measures implemented as part of the issuance of the permits is 

anticipated to lower the risk to all freshwater species exposed to total aluminum from permitted 

vessel discharges by approximately 8 percent. 

While aluminum does not bioaccumulate to high levels in aquatic animals, EPA believes 

it is prudent to incorporate an analysis on multiple routes of exposure in this BE for this nonessential metal. The evaluation of potential risks from bioaccumulated aluminum provides a 

means of identifying potential risks to listed aquatic species via exposure to criteria 

concentrations from all exposure routes combined. 

The only RQs that could be calculated for a freshwater organism was for vertebrates 

based on estimated concentrations accumulated in tissues (i.e., 10 mg Al/kg wet wt tissue 

measured in Salmo trutta) from continuous exposure to maximum concentrations of total 

aluminum in ambient receiving waters of 0.0334 and 0.0309 μg/L, pre- and post-permit 

conditions, respectively (see Table 5-20). Corresponding RQs were 0.000167 and 0.000154, 

respectively, indicating “remote” risk to freshwater vertebrates from aluminum accumulated in 

tissues. 

Risk to Saltwater (Estuarine/Marine) Aquatic Animal and Plant Species - Aluminum

The overall risk to saltwater aquatic organisms from maximum exposure to total 

aluminum from permitted vessels is also remote. An RQA,W of only 0.0384 is estimated for 

invertebrates under the pre-permit condition. Control measures implemented as part of the 

issuance of the permits is anticipated to lower the risk to all saltwater species exposed to total 

aluminum from permitted vessel discharges by approximately 20 percent. 

EPA did not calculate a RQs for saltwater organisms based on estimated concentrations 

of aluminum accumulated in tissues of these organisms, because no such data exist from which 

an appropriate CTETA,T could be determined. 

Risk to Birds and Mammals - Aluminum

An evaluation of risk to aquatic-dependent birds and mammals from exposure via 

consumption of prey items or drinking ambient surface water at the maximum concentrations 

predicted for total aluminum is required because of the apparent ability of some organisms to 

accumulate aluminum in tissues, albeit to low levels. The RQs estimated for surrogate mammals 

and birds based on the quotient of ECO and CTETO for total aluminum range from values that are 

low (<0.01) to very low (<0.001), respectively, indicating only “remote” risk. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-69 

Table 5-19. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Total Aluminum 

Surrogate Aquatic 

Species Type 

Surrogate 

Species 

Exposure/ 

Effect 

Endpoint 

NOEC - 

LOEC 

(μg/L) 

CTETA,W

(μg/L) Study (source) 

Freshwater Vertebrate 

a

 Atlantic salmon, 

Salmo salar 

ELS Test - 

Growth 33 - 71 48.40 

Buckler et al. 

1995 

(GLEC NODA 

Review) 

Freshwater Invertebrate 

Cladoceran, 

Ceriodaphnia 

dubia 

LC Test -

Reproduction 460 - 930 650 

ENSR 1992 

(GLEC NODA 

Review) 

Freshwater Plant 

(Vascular) 

Eurasian 

watermilfoil, 

Myriophyllum 

spicatum

32-day EC50 

(root weight) - 2,500 

Stanley 1974 

(GLEC NODA 

Review) 

Estuarine/Marine 

Vertebrate Not Available - - - - 

Estuarine/Marine 

Invertebrate 

Polychaete 

worm, 

Ctenodrilus 

serratus 

Genus Mean 

Acute Value 

of 97 μg/L ÷ 

Freshwater 

ACR 

(ACR=2.900) 

- 

33.45 

(estimated

) 

ENSR 1992; 

McCauley et al. 

1986; Kimball 

1978 (ACR); 

Petrich and Reish 

1979 (LC50) 

(GLEC NODA 

Review) 

Estuarine/ Marine Plant 

(Vascular) Not Available - - - - 

Surrogate Aquatic 

Species Type 

Surrogate 

Species 

Exposure 

Type Effect 

CTETA,T

(mg/kg 

wet wt.) 

Study (source) 

Freshwater Vertebrate 

a

 Atlantic salmon, 

Salmo trutta 

5-day 

waterborne to 

230 μg/L at 

pH 5 

Decreased 

growth, no 

effect on 

survival or 

mucus cell 

b

10.00 Segner et al. 

1988 

Freshwater Invertebrate Not Available - - - - 

Estuarine/ 

Marine Vertebrate Not Available - - - - 

Estuarine/ Marine 

Invertebrate Not Available - - - - 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-70 

Table 5-19. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Total Aluminum 

Surrogate AqauticDependent Species Type Surrogate 

Species 

Exposure 

Type 

Effect 

Endpoint 

CTETO

(mg/kg 

bw/d) 

Study (source) 

Mammals Mouse 3 generation 

oral via water Reproduction 1.93 

Sample et al. 

1996 

(OR Toxics BE) 

Birds Ringed Dove 4 month oral 

in diet Reproduction 109.7 

Sample et al. 

1996 

(OR Toxics BE)

a) Listed species. 

Table 5-20. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative Surrogate 

Taxa to Total Aluminum 

Taxa 

ECW

(Pre-Permit 

Condition); 

(μg/L) 

ECW

(Post-Permit 

Condition); 

(μg/L) 

CTETA,W

(μg/L) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Freshwater Vertebrate 

0.0334 0.0309 

48.4 0.00069 0.000637 

Freshwater Invertebrate 650 <0.0001 <0.0001 

Freshwater plant (Vascular) 2,500 <0.0001 <0.0001 

Estuarine/Marine 

Vertebrate 

1.28 1.02 

NAa

 

Estuarine/Marine 

Invertebrate 33.45 0.0384 0.0306 

Saltwater plant (Vascular) NAa - - 

Taxa 

ECT

(Pre-Permit 

Condition); 

(mg/kg wet 

wt.) 

ECT

(Post-Permit 

Condition); 

(mg/kg wet 

wt.) 

CTETA,T

(mg/kg 

wet wt.) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Freshwater Vertebrate 

0.00167 0.00154 

10.00 0.000167 0.000154 

Freshwater Invertebrate NA - - 

Freshwater plant (Vascular) NA - - 

Estuarine/Marine 

Vertebrate 

0.0642 0.0511 

NA - - 

Estuarine/Marine 

Invertebrate NA - - 

Saltwater plant (Vascular) NA - - 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-71 

Table 5-20. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative Surrogate 

Taxa to Total Aluminum 

Taxa 

ECO

(Pre-Permit 

Condition); 

(mg/kg bw/d) 

ECO

(Post-Permit 

Condition); 

(mg/kg bw/d) 

CTETO

(mg/kg 

bw/d) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Mammals (Freshwater) 0.000268 0.000248 1.930 0.000139 0.000128 

Birds (Freshwater) 0.00202 0.00187 109.7 <0.0001 <0.0001 

Mammals (Saltwater) 0.00992 0.0079 1.930 0.00514 0.00409 

Birds (Saltwater) 0.0775 0.0618 109.7 0.000707 0.000563 

a) Not applicable because a CCC for aluminum in saltwater has not been calculated by EPA due to lack 

of sufficient data. 

5.3.2.1.2 Indirect Effects from Aluminum 

The RQs summarized above and in Table 5-21 indicate “remote” risk for direct effects of 

total aluminum to listed aquatic and aquatic-dependent species in this BE. Furthermore, 

discharge of total aluminum from covered vessels likely will not result in appreciable 

concentrations in estuaries and freshwater receiving water bodies, likely due to rapid complex 

formation and subsequent settling on bottom surfaces. 

There is no basis for assuming indirect effects on listed species via total aluminum 

exposure and corresponding toxicity-related reduction in the prey base [loss of prey] available to 

upper trophic level organisms. Since the information summarized in Table 5-20 indicates that 

total aluminum at maximum exposure concentrations calculated from pre-, and especially after 

post-permit conditions (8-20 percent reduction), has little risk of directly affecting fresh- and 

saltwater aquatic animals and plants (freshwater only, no data for saltwater plants), indirect 

effects typically associated with exposure, including loss of cover and changes in water quality 

parameters, are also not expected for this metal. 

Risk Conclusion for each of Listed Species in RAAs - Aluminum 

Based on the exposure and direct and indirect effects assessment as outlined above, the 

following risk conclusions are being made for each of the listed species in the RAAs (see Table 

5-21). This information is used to inform decisions in the effects determinations made in Section 

7 of this document. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-72 

Table 5-21. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Total Aluminum 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumptions 

Saltwater Corals Remote  Exposed via water column only 

 Risk quotient indicates very low potential for direct 

chronic effects 

 Fate of total aluminum indicates very low potential for 

indirect effects (loss of prey and change in habitat/water 

quality parameters) – at the concentrations predicted 

 Surrogate CTET is representative and appropriate 

Unionid Mussels Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a 15-d 

study with the non-North-American species, swan 

mussel (Anodonta cygena), and a MATC (decrease in 

duration of shell gape) of 353.0 μg/L. Hardness was not 

provided (Kadar et al., 2001). Calculation results in preand post-permit RQs below 0.0001. 

Saltwater Bivalve Mollusk Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using an 

ACR of 2 (no saltwater ACR available) for the barnacle 

(Balanus eburneus) and a LC50 of 240 μg/L (Taneeva, 

1973). Calculation results in pre- and post-permit RQs 

of less than 0.011. 

Freshwater Shrimp/ Crustacean Remote Same as Saltwater Corals’ Presumptions 

Freshwater Fish/ Inland 

Salmonid 

Remote RQ directly applicable since estimated for S. salar as 

presented in Table 5-19 above 

Anadromous Salmonid Remote Same as above for Freshwater Inland Salmonids – no 

chronic toxicity data are available for salmonids tested in 

seawater 

Freshwater Fish/ Inland 

Sturgeon 

Remote Same as Saltwater Corals’ Presumptions 

Anadromous Sturgeon Remote Same as Saltwater Corals’ Presumptions 

Estuarine/ Marine Fish Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using acute 

toxicity data for the non-North-American species, 

Australian bass (Macquaria novemaculeata), with 

reduced survival at 200 μg/L at 25 mg/L hardness, or 

634.3 μg/L normalized to 100 mg/l hardness (Hyne and 

Wilson ,1997). Using a freshwater fish ACR of 6.06 (P. 

promelas) resulted in a chronic effect estimate of 104.7 

μg/L. Calculation results in pre- and post-exposure RQs 

of 0.0123 and 0.0098, respectively. 

Beetle and Aquatic Insect Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a 14-

d study with an aquatic beetle (Tropistermus lateralis 

nimbatus) that changed the body fat composition at 200 

μg/L (only conc.) (Wooldridge and Wooldridge, 1969). 

Calculation results in pre- and post-permit RQs below 

0.0002. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-73 

Table 5-21. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Total Aluminum 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumptions 

Amphibian Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a 7-d 

study with common toad (Bufo bufo) with NOEC 

(survival) >320 μg/L at 50 mg/L hardness, or 569.8 

μg/L normalized to 100 mg/L hardness (Gardner et al., 

2002). Calculation results in pre- and post-permit RQs 

are below 0.0001. 

Snakes and Other Reptiles Remote Same as Saltwater Corals’ Presumptions 

Sea Turtles Remote Same as Saltwater Corals’ Presumptions 

Coastal/Marine Birds Remote Same as Saltwater Corals’ Presumptions 

Marine Mammal Remote Same as Saltwater Corals’ Presumptions 

Terrestrial Mammal Remote Same as Saltwater Corals’ Presumptions 

Seagrass Remote Same as Saltwater Corals’ Presumptions 

Freshwater- Saltwater Aquatic 

and Wetland Plants 

Remote RQ directly applicable since estimated for M. spicatum as 

presented in Table 5-19 above.

5.3.2.2 Arsenic (Dissolved and Total) 

Arsenic is found at concentrations exceeding screening level benchmarks primarily in 

exhaust gas scrubber effluent, but also in fish hold and fish hold cleaning effluent (see Section 

3.2.3.5). Compared to most of the other metals and metalloids selected for detailed evaluation in 

this BE, this non-essential metalloid is among the least toxic to aquatic organisms (McIntyre and 

Linton, 2012). In general, inorganic arsenic is substantially more toxic to aquatic organisms than 

organic arsenic, and arsenite (AsIII) is more toxic than arsenate (AsV). 

Arsenic bioaccumulates in tissues of aquatic organisms, but does not appear to 

biomagnify up the aquatic food chain (USEPA, 2003b; Williams et al., 2006). Arsenic BAFs in 

upper trophic level freshwater and estuarine fish and shellfish typically consumed by wildlife 

generally range between 5 L/kg at 100 μg/L in laboratory or ambient surface water, to greater 

than 1,000 L/kg at 0.1 μg/L (USEPA, 2003b; Williams et al., 2006). Despite the recent attention 

focused on arsenic uptake and accumulation in aquatic biota, there is still much uncertainty about 

the mechanisms and bioaccumulation potential of the various forms of arsenic in the 

environment. Tissue data collected from the most recent arsenic bioaccumulation studies appear 

to confirm the presumption that the majority of arsenic in fish is relatively non-toxic organic 

arsenic, i.e., arsenobetaine (AsB), arsenocholine (AsC), or mono- and dimethylated arsenic 

(McIntyre and Linton, 2012). This is especially true for saltwater fishes. 

For this analysis, EPA assumes that all inorganic arsenic in fresh- and saltwater is 

dissolved arsenic, and that the evaluation of risk from both direct and indirect effects is best 

addressed using aquatic toxicity data based on the more toxic arsenite (AsIII) form of this 

metalloid. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-74 

5.3.2.2.1 Direct Effects from Arsenic 

Table 5-22 summarizes the chronic toxicity values available for calculating the risk 

quotients for aquatic and aquatic-dependent species exposed to arsenic. Table 5-23 presents the 

maximum exposure concentrations estimated in ambient receiving waters (ECW), in tissues of 

aquatic organisms exposed to those concentrations (ECT), and in oral doses of aquatic-dependent 

animals ingesting food and water in those receiving waters (ECO). Maximum exposure 

concentrations in ambient receiving water are from the hypothetical harbor modeling, as 

described above in Section 5.2.1. In this case, EPA’s risk analysis is based on the use of 

maximum exposure concentration estimated via the post-permit condition only since maximum 

exposure concentrations based on pre-permit condition was the same. 

Risk to Freshwater Aquatic Animal and Plant Species - Arsenic

The risk to freshwater aquatic organisms from maximum exposure to arsenic in ambient 

receiving water from discharges of covered vessels is remote. Using the maximum exposure 

concentration (post-permit condition only since pre- and post-permit exposure concentrations are 

essentially the same, per above), RQs for freshwater organisms are all well below a value of 

0.001 (Table 5-23). 

RQs were also calculated for freshwater vertebrates and invertebrates based on estimated 

concentrations accumulated in tissues from continuous exposure to maximum concentrations of 

dissolved arsenic in ambient receiving waters of 0.164 μg/L. Corresponding RQs were 0.00623 

(for vertebrates) and 0.00181 (for invertebrates), respectively, indicating “remote” risk to these 

organisms from arsenic accumulated in tissues (see Table 5-23). 

Risk to Saltwater (Estuarine/Marine) Aquatic Animal and Plant Species - Arsenic 

The risk to saltwater aquatic organisms from maximum exposure to arsenic in ambient 

receiving water from discharges of covered vessels is also remote. Using the maximum exposure 

concentration estimated under the post-permit condition, RQs for saltwater organisms are below 

0.05 for vascular plants (based on EPA’s conservative CCC for AsIII in saltwater) and 0.002 for 

vertebrates and invertebrates. 

EPA could not calculate RQs for saltwater organisms based on estimated concentrations 

accumulated in tissues of these organisms, because no such data exist upon which a CTETA,T

could be determined. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-75 

Risk to Birds and Mammals - Arsenic

An evaluation of risk to aquatic-dependent birds and mammals from exposure via 

consumption of prey items or drinking ambient surface water at the maximum concentrations 

predicted for arsenic is required because of the known propensity of some organisms to 

accumulate arsenic in tissues. The RQs estimated for surrogate mammals and birds based on the 

quotient of ECO and CTETO for arsenic ranges from a value of approximately 0.1 predicted for 

saltwater mammals to 0.00118 for freshwater birds (Table 5-23). These RQs indicate “remote” to 

“negligible” risk of arsenic to aquatic-dependent birds and mammals. 

Table 5-22. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Dissolved Arsenic 

Surrogate Aquatic Species 

Type 

Surrogate 

Species 

Exposure/ 

Effect 

Endpoint 

NOEC - LOEC 

(μg/L) 

CTETA,W

(μg/L) 

Study 

(source) 

ARSENIC (as Arsenic (III) and assuming a dissolved: total Arsenic ratio of 1.0) 

Freshwater Vertebrate 

Flagfish, 

Jordanella 

floridae 

ELS Test - 

Growth 2,130 - 4,120 2,962 

Call et al. 

1983; Lima et 

al. 1984 

(1985 ALC

Freshwater Invertebrate 

Cladoceran, 

Daphnia 

magna 

LC Test - 

Survival and 

growth 

633.0 - 1,320 914.1 

Call et al. 

1983; Lima et 

al. 1984 

(1985 ALC 

Freshwater Plant (Vascular) 

Eurasian 

watermilfoil, 

Myriophyllum 

spicatum

32-day EC50 

Biomass - 2,600 

Stanley 1974 

(NODA 

Review) 

Estuarine/ Marine 

Vertebrate 

Sheepshead 

minnow, 

Cyprinodon 

variegatus 

Acute LC50 of 

3,339 μg/L ÷ 

FACR 

(FACR=3.803) 

- 3,339 

(estimated) 

Cardin 1982 

(1985 ALC 

doc.) 

Estuarine/ Marine 

Invertebrate 

Mysid, 

Americamysis 

bahia 

LC Test - 

Survival 631 - 1,270 895.2 

Lussier et al. 

1985 

(NODA 

Review) 

Estuarine/ Marine Plant 

(Vascular) Not Available - - 36 

(CCC) 

CCC from 

USEPA 1985a
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-76 

Table 5-22. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Dissolved Arsenic 

Surrogate Aquatic Species 

Type 

Surrogate 

Species Exposure Type Effect Endpoint 

CTETA,T

(mg/kg wet 

wt.) 

Study 

(source) 

Freshwater Vertebrate 

Bluegill, 

Lepomis 

macrochirus 

16 week outdoor 

mesocosm to 

arsenical 

herbicide 

i i 2 320

Decreased 

juvenile 

survival and 

growth 

0.97 Gilderhus 

1966 

Freshwater Invertebrate 

Cladoceran, 

Moina 

macrocopa 

14 day Lab Food 

Chain 

Experiment 

Reduced 

growth 3.58 Maeda et al. 

1990 

Estuarine/ Marine 

Vertebrate Not Available - - - - 

Estuarine/ Marine 

Invertebrate Not Available - - - - 

Surrogate AquaticDependent Species Type Surrogate 

Species Exposure Type Effect Endpoint 

CTETO

(mg/kg 

bw/d) 

Study 

(source) 

Mammals Mouse 3 generation oral 

via water Reproduction 0.126 

Sample et al. 

1996 

(OR Toxics 

BE) 

Birds Mallard 128-day oral via 

diet Mortality 5.14 

Sample et al. 

1996 

(OR Toxics 

BE) 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-77 

Table 5-23. Risk Quotients based on Division of Pre- and Post-permit 

Exposure Concentrations by Chronic Toxicity Thresholds of 

Representative Surrogate Taxa to Arsenic 

Taxa 

ECW

(Post-Permit 

Condition); 

(μg/L) 

CTETA,W

(μg/L) 

RQ 

(PostPermit) 

Freshwater Vertebrate 

0.164 

2,962 <0.0001 

Freshwater Invertebrate 914.1 0.00018 

Freshwater plant (Vascular) 2,600 <0.0001 

Estuarine/Marine Vertebrate 

1.94 

3,339 0.00058 

Estuarine/Marine Invertebrate 895.2 0.00216 

Saltwater plant (Vascular) 36 0.0538 

Taxa 

ECT

(Post-Permit 

Condition); 

(mg/kg wet wt.) 

CTETA,T

(mg/kg wet 

wt.) 

RQ 

(PostPermit) 

Freshwater Vertebrate 0.00604 0.970 0.00623 

Freshwater Invertebrate 0.00647 3.58 0.00181 

Freshwater plant (Vascular) - NA - 

Estuarine/Marine Vertebrate 

0.0852 

NA - 

Estuarine/Marine Invertebrate NA - 

Saltwater plant (Vascular) NA - 

Taxa 

ECO

(Post-Permit 

Condition); 

(mg/kg bw/d) 

CTETO

(mg/kg 

bw/d) 

RQ 

(PostPermit) 

Mammals (Freshwater) 0.000983 0.126 0.0078 

Birds (Freshwater) 0.000608 5.14 0.000118 

Mammals (Saltwater) 0.0132 0.126 0.104 

Birds (Saltwater) 0.00852 5.14 0.00166 

5.3.2.2.2 Indirect Effects from Arsenic 

The RQs summarized above and in Table 5-24 indicate generally “remote” risk for direct 

effects of dissolved arsenic (expressed as AsIII in its dissolved form) to listed aquatic and 

aquatic-dependent species in this BE, except for saltwater mammals where the risk is estimated 

to be “negligible”. Furthermore, discharge of dissolved arsenic does not appear to result in 

appreciable concentrations in estuaries and freshwater receiving water bodies under highly 

conservative scenarios. 

There is no basis for assuming indirect effects on listed species via arsenic exposure and 

corresponding toxicity-related reduction in the prey base [loss of prey] available to upper trophic 

level organisms. Additionally, exposure of wildlife via the water or via the food web to this 

metalloid appears to be of limited (negligible) consequence. Since the information summarized 

in Table 5-23 indicates that arsenic at maximum exposure concentrations under post-permit 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-78 

conditions has little risk of directly affecting fresh- and saltwater aquatic animals and plants 

(freshwater only, no toxicity data for saltwater plants), indirect effects typically associated with 

exposure, including loss of cover and changes in water quality parameters, are also not expected 

for this metal. 

Risk Conclusion for each of Listed Species in RAAs - Arsenic 

Based on the exposure and direct and indirect effects assessment as outlined above, the 

following risk conclusions are being made for each of the listed species in the RAAs (see Table 

5-24). This information is used to inform decisions in the effects determinations made in Section 

7 of this document. 

Table 5-24. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Arsenic 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumptions 

Saltwater Corals Remote  Exposed via water column only 

 Risk quotient indicates very low potential for direct 

chronic effects 

 Fate of dissolved arsenic indicates very low potential for 

indirect effects (loss of prey and change in habitat/water 

quality parameters) 

 Surrogate CTET is representative and appropriate 

Unionid Mussels Remote Same as Saltwater Corals’ Presumptions 

Saltwater Bivalve Mollusk Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a 2-d 

study with a Pacific oyster (Crassostrea gigas) LC50 of 

326 μg/L (Martin et al., 1981). Dividing by the FACR 

(3.803) results in a chronic value of 85.72 μg/L. 

Calculation results in pre- and post-permit RQs are 

below 0.02. 

Freshwater Shrimp/ Crustacean Remote Same as Saltwater Corals’ Presumptions 

Freshwater Fish/ Inland 

Salmonid 

Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using 28-d 

study with rainbow trout (O. mykiss) and a LC50 of 540 

μg/L (Birge, 1978). Calculation results in pre- and postpermit RQs less than 0.004. 

Anadromous Salmonid Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using 10-d 

study with pink salmon (O. gorbuscha) and a LC54 of 

3,787 μg/L (Holland et al., 1960). Calculation results in 

pre-post permit RQs less than 0.001. 

Freshwater Fish/ Inland 

Sturgeon 

Remote Same as Saltwater Corals’ Presumptions 

Anadromous Sturgeon Remote Same as Saltwater Corals’ Presumptions 

Estuarine/ Marine Fish Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for C. variegatus

as presented in Table 5-22 above 

Beetle and Aquatic Insect Remote Same as Saltwater Corals’ Presumptions 

Amphibian Remote  Same as Saltwater Corals’ Presumptions 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-79 

Table 5-24. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Arsenic 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumptions 

 Risk conclusion is confirmed via estimation using a 4-d 

study with a giant toad (Bufo marinus) LC50 of 123,000 

μg/L (Johnson, 1976). Dividing by the FACR (3.803) 

results in a chronic value of 32,343 μg/L. Calculation 

results in pre- and post-permit RQs are below 0.0001. 

Snakes and Other Reptiles Remote Same as Saltwater Corals’ Presumptions

Sea Turtles Remote Same as Saltwater Corals’ Presumptions

Coastal/Marine Birds Remote Same as Saltwater Corals’ Presumptions

Marine Mammal Negligible Same as Saltwater Corals’ Presumptions

Terrestrial Mammal Remote Same as Saltwater Corals’ Presumptions

Seagrass Remote Same as Saltwater Corals’ Presumptions

Freshwater- Saltwater Aquatic 

and Wetland Plants 

Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for M. spicatum

as presented in Table 5-22 above 

5.3.2.3 Cadmium (Dissolved) 

Dissolved cadmium was detected in bilgewater and deck washdown discharges at 

concentrations above benchmark screening levels (see Section 3.2.3.5). Cadmium occurs 

naturally in the aquatic environment, but has no known biological use and is considered one of 

the most toxic of metals to fish (Sorensen, 1991). Background concentrations of cadmium in 

streams and rivers range from <0.01 to 0.2 μg/L and are usually less than 0.05 μg/L in waters unimpacted by man (Korte, 1983; USEPA, 1985b; Eisler, 1985a; Wren et al., 1995). 

Cadmium is bioconcentrated by organisms, but is not biomagnified through the food 

chain (Eisler, 1985a). Toxicity of cadmium to aquatic organisms varies with water hardness, 

alkalinity, the type and life stage of organisms, presence of organic matter, presence of other 

toxicants, and the duration of exposure (USEPA, 2001). Cadmium is a known teratogen, 

carcinogen, and a probable mutagen to freshwater organisms (Eisler, 1985a). 

One known mechanism of cadmium toxicity to fish is suppression of calcium uptake 

(Verbost et al., 1987). Calcium is vital for growth in fish (Pelgrom et al., 1997), and bone repair 

mechanisms are probably inhibited due to the hypocalcemic effect of cadmium (DWAF, 1996). 

Since cadmium toxicity to freshwater aquatic animals has been shown to be related to water 

hardness, it is appropriate to normalize chronic toxicity effect thresholds for freshwater aquatic 

animals to a standard water hardness (i.e., 100 mg/L as CaCO3) for comparative purposes and to 

support risk calculation (USEPA, 2005b). 

5.3.2.3.1 Direct Effects from Cadmium 

Table 5-25 summarizes the chronic toxicity values available for calculating the risk 

quotients for aquatic and aquatic-dependent species exposed to dissolved cadmium. Table 5-26 

presents the maximum exposure concentrations estimated in ambient receiving waters (ECW), in 

tissues of aquatic organisms exposed to those concentrations (ECT), and in oral doses of aquatic-
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-80 

dependent animals ingesting food (prey) and water in those receiving waters (ECO). Maximum 

exposure concentrations in ambient receiving water are from the hypothetical harbor modeling 

(pre- and post-permit condition), as described above in Section 5.2.1. 

Risk to Freshwater Aquatic Animal and Plant Species - Cadmium 

The overall risk to freshwater aquatic organisms as a result of maximum exposure in 

ambient waters from dissolved cadmium discharged by permitted vessels is “remote”. All 

RQA,Ws are <0.0001, with the highest RQ of 0.000068 estimated for freshwater invertebrates 

under the pre-permit condition. Control measures implemented as part of the issuance of the 

permits is anticipated to lower the risk to all freshwater species exposed to dissolved cadmium 

from permitted vessel discharges by approximately 8 percent. 

While cadmium does not bioaccumulate to high levels in aquatic animals, EPA believes it 

is prudent to incorporate the analysis on multiple routes of exposure in this BE for this nonessential metal. The evaluation of potential risks from bioaccumulated cadmium provides a 

means of identifying potential risks to listed aquatic species via exposure to criteria 

concentrations from all exposure routes combined. 

RQs were calculated for freshwater vertebrates and invertebrates based on estimated 

concentrations accumulated in tissues from continuous exposure to maximum concentrations of 

dissolved cadmium in ambient receiving waters of 0.0000129 and 0.0000118 μg/L, pre- and 

post-permit conditions, respectively (see Table 5-26). Corresponding RQs were all below 

0.00010, indicating “remote” risk to freshwater aquatic animals from cadmium accumulated in 

tissues. 

Risk to Saltwater (Estuarine/Marine) Aquatic Animal and Plant Species - Cadmium

The overall risk to saltwater aquatic organisms as a result of maximum exposure in 

ambient waters from dissolved cadmium discharged by permitted vessels is also “remote”. All 

RQA,Ws are 0.0001 or less. Control measures implemented as part of the issuance of the permits 

is anticipated to lower the risk to all saltwater species exposed to dissolved cadmium from 

permitted vessel discharges by approximately 20 percent. 

RQs were calculated for saltwater vertebrates and invertebrates based on estimated 

concentrations accumulated in tissues from continuous exposure to maximum concentrations of 

dissolved cadmium in ambient receiving waters of 0.000867 and 0.000697 μg /L, pre- and postpermit conditions, respectively (see Table 5-26). Corresponding RQs were all below 0.001, 

again, indicating “remote” risk to aquatic animals (saltwater in this case) from cadmium 

accumulated in tissues. 

Risk to Birds and Mammals - Cadmium 

An evaluation of risk to aquatic-dependent birds and mammals from exposure via 

consumption of prey items or drinking ambient surface water at the maximum concentrations 

predicted for dissolved cadmium is required because of the apparent ability of some organisms to 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-81 

accumulate cadmium in tissues, albeit to low levels. The RQs for representative freshwater and 

saltwater mammals and birds based on the chronic toxicity values in relation to the oral effects 

concentrations calculated for this BE are all extremely low (<0.00001). These RQs indicate 

“remote” risk of cadmium to aquatic-dependent birds and mammals. 

Table 5-25. Summary of Chronic Toxicity Values for Aquatic and Aquatic-dependent 

Organisms Exposed to Dissolved Cadmium 

Surrogate Aquatic 

Species Type Surrogate Species 

Exposure/ 

Effect 

Endpoint 

NOEC - LOEC

(μg/L) 

CTETA,W

(μg/L) Study (source) 

CADMIUM - Dissolved 

(* data normalized to hardness = 100 mg/L CaCO3 using USGS derived chronic slope of 0.6247 and EPA 

dissolved conversion factor of 1.101672-[(ln hardness)(0.041838)]-freshwater and 0.994-estuarine/marine) 

Freshwater 

Vertebrate 

Rainbow trout, 

Oncorhynchus 

mykiss 

ELS Test - 

Survival 1.3 - 2.7 1.87 (1.672 *) 

Besser et al. 2007 

(NODA Review) 

Freshwater 

Invertebrate 

Cladoceran, 

Daphnia magna 

LC Test - 

Reproduction 0.16 - 0.28 0.2117 (0.1889 *) 

Chapman et al. 

Manuscript (2001 

ALC doc.) 

Freshwater Plant 

(Vascular) 

Duckweed, 

Lemna gibba 96-hr - Growth <1 – 1 <1 

Megateli et al. 

2009 

(NODA Review) 

Estuarine/ Marine 

Vertebrate 

Striped bass, 

Morone saxatilis 

Acute LC50 ÷ 

Estuarine ACR 

(ACR=9.11) 

75.0 ÷ 9.11 

8.232 

(8.182 *) 

(estimated) 

Genitle et al. 1982; 

Nimmo et al. 

1977; Lussier et al. 

1985 (ACR); 

Palawski et al. 

1985 (LC50) 

Estuarine/ Marine 

Invertebrate 

Mysid, 

Americamysis 

bahia 

LC Test - 

Reproduction 5.1 – 10 7.141 

(7.099 *) 

Gentile et al. 1982; 

Lussier et al. 1985 

(2001 ALC doc.) 

Estuarine/ Marine 

Plant (Vascular) Not Available - - 9.3 CCC from USEPA 2001 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-82 

Table 5-25. Summary of Chronic Toxicity Values for Aquatic and Aquatic-dependent 

Organisms Exposed to Dissolved Cadmium 

Surrogate Aquatic 

Species Type 

Surrogate 

Species 

Exposure 

Type 

Effect 

Endpoint 

CTETA,T

(mg/kg 

wet wt.) 

Study (source) 

Freshwater 

Vertebrate 

a Atlantic salmon, 

Salmo salar ELS Test Reduction in 

growth 0.0050 Rombough and 

Garside 1982 

Freshwater 

Invertebrate 

Amphipod, 

Hyalella azteca 

42-d 

Mesocosm 

Study 

Significant 

decrease in 

weight 

0.118 Stanley et al. 2005 

Estuarine/ Marine 

Vertebrate 

European 

flounder, 

Platichthys flesus 

- 

Reduction in 

percentage of 

eggs that hatch 

0.04 

von Westernhagen 

and Dethlefsen 

1975 

Estuarine/ Marine 

Invertebrate 

Starfish, 

Asterias rubens 

5 mo Semifield Study 

76% reduction 

in normal 

embryo 

development 

0.14 den Besten et al. 

1989 

Surrogate AquaticDependent Species 

Type 

Surrogate Species Exposure 

Type 

Effect 

Endpoint 

CTETO

(mg/kg 

bw/d) 

Study (source) 

Mammals Rat 6-wk oral 

gavage Reproduction 1 Sample et al. 1996 (OR Toxics BE) 

Birds Mallard 90-d oral in 

diet Reproduction 1.45 Sample et al. 1996 

(OR Toxics BE) 

a) Listed species. 

Table 5-26. Risk Quotients Based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Thresholds of Representative Surrogate Taxa to 

Dissolved Cadmium 

Taxa 

ECW

(Pre-Permit 

Condition); 

(μg/L) 

ECW

(Post-Permit 

Condition); 

(μg/L) 

CTETA,W

(μg/L) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Freshwater Vertebrate 

0.0000129 0.0000118 

1.672 <0.0001 <0.0001 

Freshwater Invertebrate 0.1889 <0.0001 <0.0001 

Freshwater plant (Vascular) 1.000 <0.0001 <0.0001 

Estuarine/Marine 

Vertebrate 

0.000867 0.000697 

8.182 0.000106 <0.0001 

Estuarine/Marine 

Invertebrate 7.099 0.000122 <0.0001 

Saltwater plant (Vascular) 9.3 <0.0001 <0.0001 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-83 

Table 5-26. Risk Quotients Based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Thresholds of Representative Surrogate Taxa to 

Dissolved Cadmium 

Taxa 

ECT

(Pre-Permit 

Condition); 

(mg/kg wet 

wt.) 

ECT

(Post-Permit 

Condition); 

(mg/kg wet 

wt.) 

CTETA,T

(mg/kg wet 

wt.) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Freshwater Vertebrate 

0.000000489 0.000000448 

0.0050 <0.0001 <0.0001 

Freshwater Invertebrate 0.1180 <0.0001 <0.0001 

Freshwater plant (Vascular) NA - - 

Estuarine/Marine 

Vertebrate 

0.0000329 0.0000265 

0.040 0.000824 0.000662 

Estuarine/Marine 

Invertebrate 0.140 0.000235 0.000189 

Saltwater plant (Vascular) NA - - 

Taxa 

ECO

(Pre-Permit 

Condition); 

(mg/kg bw/d) 

ECO

(Post-Permit 

Condition); 

(mg/kg bw/d) 

CTETO

(mg/kg bw/d) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Mammals (Freshwater) 0.0000000394 0.0000000361 1.00 <0.00001 <0.00001

Birds (Freshwater) 0.0000000492 0.000000045 1.45 <0.00001 <0.00001

Mammals (Saltwater) 0.00000264 0.00000212 1.00 <0.00001 <0.00001

Birds (Saltwater) 0.00000329 0.00000265 1.45 <0.00001 <0.00001

5.3.2.3.2 Indirect Effects from Cadmium 

The RQs summarized above and in Table 5-27 indicate “remote” risk for direct effects of 

dissolved cadmium to listed aquatic and aquatic-dependent species in this BE. Furthermore, 

discharge of dissolved cadmium from covered vessels will not result in appreciable 

concentrations in estuaries and freshwater receiving water bodies. 

There is no basis for assuming indirect effects on listed species via dissolved cadmium 

exposure and corresponding toxicity-related reduction in the prey base [loss of prey] available to 

upper trophic level organisms. Since the information summarized in Table 5-26 indicates that 

dissolved cadmium at maximum exposure concentrations calculated from pre-, and especially 

after post-permit conditions (8 to 20 percent reduction, freshwater and saltwater receiving water, 

respectively) has little risk of directly affecting fresh- and saltwater aquatic animals and plants, 

indirect effects typically associated with exposure, including loss of cover and changes in water 

quality parameters, are also not expected for this metal. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-84 

Risk Conclusion for each of Listed Species in RAAs - Cadmium

Based on the exposure and direct and indirect effects assessment as outlined above, the 

following risk conclusions are being made for each of the listed species in the RAAs (see Table 

5-27). This information is used to inform decisions in the effects determinations made in Section 

7 of this document. 

Table 5-27. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Cadmium 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumptions 

Saltwater Corals Remote  Exposed via water column only 

 Risk quotient indicates very low potential for direct 

chronic effects 

 Fate of dissolved cadmium indicates very low potential 

for indirect effects (loss of prey and change in 

habitat/water quality parameters) 

 Surrogate CTET is representative and appropriate 

Unionid Mussels Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a 77-d 

study with zebra mussel (Dreisena polymorpha) with an 

EC50 of 130 μg/L at a hardness of 268 mg/L (70.22 

μg/L normalized to 100 mg/L hardness) (Kraak et al., 

1992). Calculation results in pre- and post-permit RQs 

far below 0.000001. 

Saltwater Bivalve Mollusk Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a 

chronic study with the common mussel (Mytilus edulis) 

with 6% mortality at 200 μg/L (only conc.) at a hardness 

of 31 mg/L (415.6 μg/L normalized to 100 mg/L 

hardness) (Geret et al., 2002). Calculation results in preand post-permit RQs far below 0.000001. 

Freshwater Shrimp/ Crustacean Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a 24-

hr acute study with fairy shrimp (Streptocephalus 

proboscideus) with a LC50 of 250 μg/L at hardness of 

250 mg/L (116.1 μg/L normalized to 100 mg/L 

hardness) (Crisinel et al., 1994). Using an ACR for 

freshwater invertebrates of 34.30 results in a chronic 

value of 3.384 μg/L. Calculation results in pre- and postpermit RQs below 0.000001. 

Freshwater Fish/ Inland 

Salmonid 

Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for O. mykiss as 

presented in Table 5-25 above 

Anadromous Salmonid Remote Same as Freshwater Inland Salmonids – no chronic toxicity 

data are available for salmonids tested in seawater 

Freshwater Fish/ Inland 

Sturgeon 

Remote Same as Saltwater Corals’ Presumptions 

Anadromous Sturgeon Remote Same as Saltwater Corals’ Presumptions 

Estuarine/ Marine Fish Remote  Same as above 

 RQ directly applicable since estimated for M. saxatilis

as presented in Table 5-25 above 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-85 

Table 5-27. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Cadmium 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumptions 

Beetle and Aquatic Insect Remote Same as Saltwater Corals’ Presumptions 

Amphibian Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a 60-d 

study with American toad (Bufo americanus) reduced 

growth at 5 μg/L (lowest concentration tested) at 

hardness 51.2 mg/L (7.60 μg/L normalized to 100 mg/L 

hardness) (James and Little, 2003). Calculation results in 

pre- and post-permit RQs below 0.000001. 

Snakes and Other Reptiles Remote Same as Saltwater Corals’ Presumptions 

Sea Turtles Remote Same as Saltwater Corals’ Presumptions

Coastal/Marine Birds Remote Same as Saltwater Corals’ Presumptions

Marine Mammal Remote Same as Saltwater Corals’ Presumptions

Terrestrial Mammal Remote Same as Saltwater Corals’ Presumptions

Seagrass Remote Same as Saltwater Corals’ Presumptions

Freshwater- Saltwater Aquatic 

and Wetland Plants 

Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for L. gibba as 

presented in Table 5-25 above 

5.3.2.4 Chromium (Dissolved) 

Dissolved chromium was found to be present in bilgewater and stern tube packing gland 

effluent at concentrations above benchmark screening levels (see Section 3.2.3.5). Chromium is 

a naturally occurring metallic element present in minute concentrations in the environment. The 

most common forms of chromium are trivalent (chromium III) and hexavalent chromium 

(chromium VI). Chromium (III) occurs naturally in the environment and is an essential nutrient. 

Chromium (VI), in contrast, is generally man-made and more toxic to aquatic organisms because 

its oxidizing potential is high and it easily penetrates biological membranes (Steven et al., 1976, 

Taylor and Parr, 1978). 

Eisler (1986) reported that background levels of chromium in rivers and lakes ranged 

between 1 and 10 μg/L, and average 9.7 μg/L in streams. In freshwater environments, hydrolysis 

and precipitation are the most important processes in determining the environmental fate of 

chromium, while absorption and bioaccumulation are considered minor. 

Inorganic forms of chromium do not biomagnify (Eisler, 1986). Chromium toxicity to 

aquatic biota is significantly influenced by abiotic variables such as water hardness, temperature, 

pH, and salinity (Eisler, 1986). Sensitivity to chromium varies widely, even among closely 

related species (Eisler, 1986). 

For this analysis, EPA assumes that analysis of direct and indirect effects is best 

addressed using aquatic toxicity data published for surrogate species based on the more toxic 

(chromium VI) form of this metal, although the form of chromium measured in discharges was 

not specifically dissolved chromium VI, but rather, dissolved chromium (III and VI). 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-86 

5.3.2.4.1 Direct Effects from Chromium 

Table 5-28 summarizes the chronic toxicity values available for calculating the risk 

quotients for aquatic and aquatic-dependent species exposed to dissolved chromium. Table 5-29 

presents the maximum exposure concentrations estimated in ambient receiving waters (ECW), in 

tissues of aquatic organisms exposed to those concentrations (ECT), and in oral doses of aquaticdependent animals ingesting food (prey) and water in those receiving waters (ECO). Maximum 

exposure concentrations in ambient receiving water are from the hypothetical harbor modeling 

(pre- and post-permit condition), as described above in Section 5.2.1. 

Risk to Freshwater Aquatic Animal and Plant Species - Chromium 

The overall risk to freshwater aquatic organisms as a result of maximum exposure in 

ambient waters from dissolved chromium discharged by permitted vessels is “remote”. All 

RQA,Ws are well below a value of 0.0001, particularly for freshwater vertebrates and vascular 

plants. The highest RQ is 0.00002 estimated for freshwater invertebrates under the pre-permit 

condition. Control measures implemented as part of the issuance of the permits is anticipated to 

lower the risk to all freshwater species exposed to dissolved chromium from permitted vessel 

discharges by approximately 15 percent. 

Because chromium is a nutritionally essential inorganic element, chromium has the 

potential to accumulate in tissues of aquatic animals. Like other essential metals, aquatic 

organism exposure to chromium concentrations in excess of nutritional needs via other potential 

routes of exposure in addition to direct waterborne toxicity (e.g. dietary toxicity) may pose a 

threat to listed species. While chromium does not bioaccumulate to high levels in aquatic 

animals (Reid, 2012), EPA believes it is prudent to incorporate an analysis on multiple routes of 

exposure in the analysis of this pollutant. The evaluation of potential risks from bioaccumulated 

chromium provides a means of identifying potential risks to listed species via exposure to criteria 

concentrations from all exposure routes combined. 

An RQ was calculated for freshwater vertebrates based on estimated concentrations 

accumulated in tissues (1.28 mg chromium/kg wet tissue; Chinook salmon) from continuous 

exposure to maximum concentrations of dissolved chromium in ambient receiving waters of 

0.0000399 and 0.0000338 μg dissolved chromium/L, pre- and post-permit conditions, 

respectively (see Table 5-18). Corresponding RQs were all below 0.00001, indicating “remote” 

risk to freshwater aquatic animals from chromium accumulated in tissues. 

Risk to Saltwater (Estuarine/Marine) Aquatic Animal and Plant Species - Chromium

The overall risk to saltwater aquatic organisms as a result of maximum exposure in 

ambient waters from dissolved chromium discharged by permitted vessels is also “remote”. All 

RQA,Ws are 0.0001 or less. Control measures implemented as part of the issuance of the permits 

is anticipated to lower the risk to all saltwater species exposed to dissolved chromium from 

permitted vessel discharges by approximately 3 percent. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-87 

An RQ was calculated for saltwater invertebrates based on estimated concentrations 

accumulated in tissues (3.20 mg Cr/kg wet tissue; flower crab) from continuous exposure to 

maximum concentrations of dissolved cadmium in ambient receiving waters of 0.00024 and 

0.00020 μg dissolved chromium/L, pre- and post-permit conditions, respectively (see Table 

5-29). Corresponding RQs were below 0.00001, again, indicating “remote” risk to aquatic 

animals (saltwater in this case) from chromium accumulated in tissues. 

Risk to Birds and Mammals - Chromium

An evaluation of risk to aquatic-dependent birds and mammals from exposure via 

consumption of prey items or drinking ambient surface water at the maximum concentrations 

predicted for dissolved chromium is required because of the apparent ability of some organisms 

to accumulate chromium in tissues, albeit to low levels. The RQs for representative freshwater 

and saltwater mammals and birds based on the chronic toxicity values in relation to the oral 

effects concentrations calculated for this BE are all extremely low (<0.00001). These RQs 

indicate “remote” risk of chromium to aquatic-dependent birds and mammals. 

Table 5-28. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Dissolved Chromium 

Surrogate Aquatic Species 

Type 

Surrogate 

Species 

Exposure/ 

Effect 

Endpoint 

NOEC - 

LOEC 

(μg/L) 

CTETA,W

(μg/L) Study (source) 

CHROMIUM VI - Dissolved 

(* using EPA dissolved conversion factor of 0.962 freshwater and 0.993 estuarine/marine) 

Freshwater Vertebrate 

a

 Atlantic 

salmon, 

Salmo salar 

ELS Test - 

Survival 10.1 - 97 31.30 

(30.11 *) 

Grande and 

Andersen 1983 

(NODA 

review) 

Freshwater Invertebrate 

Cladoceran, 

Ceriodaphnia 

dubia 

LC Test - 

Reproduction 0.8 - 3.2 1.6 (1.539 *) 

Spehar and 

Fiandt 1986 

(NODA 

review)

Freshwater Plant (Vascular) 

Esthwaite 

waterweed, 

Hydrilla 

verticillata 

3-d test - 

Decrease 

chlorophyll 

content 

10 - 100 31.62 

(30.42 *) 

Rai et al. 1995 

(NODA 

review) 

Estuarine/ Marine 

Vertebrate 

Atlantic 

silverside, 

Menidia 

menidia 

Acute LC50 

÷ Estuarine 

ACR 

(ACR=15.38) 

14,271 ÷ 

15.38 

927.9 

(921.4 *) 

(estimated) 

Lussier et al. 

1985 (ACR); 

Cardin 1982; 

1985a (LC50) 

(NODA 

review) 

Estuarine/ Marine 

Invertebrate 

Polychaete 

worm, 

Neanthes 

d

LC Test - 

Reproduction 12.5 - 25 17.68 (17.56 *) 

Oshida et al. 

1981 (NODA 

review) 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-88 

Table 5-28. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Dissolved Chromium 

Estuarine/ Marine Plant 

(Vascular) 

Fungus, 

Apergillus 

flavus 

15-d Biomass 

Test 

100,000 - 

>100,000 

>100,000 

(>99,300 *) 

Vala et al. 2004 

(NODA 

review) 

Surrogate Aquatic Species 

Type 

Surrogate 

Species 

Exposure 

Type 

Effect 

Endpoint 

CTETA,T

(mg/kg wet 

wt.) 

Study (source) 

Freshwater Vertebrate 

a

 Chinook 

salmon, 

Oncorhynchus 

tshawytscha 

134 d 

Juvenile 

Exposure 

(Laboratory) 

29.2% weight 

reduction, 

morphological 

changes in 

kidney, DNA 

damage 

1.28 Farag et al. 

2006 

Freshwater Invertebrate Not Available 

Estuarine/ Marine 

Vertebrate Not Available 

Estuarine/ Marine 

Invertebrate 

Flower crab, 

Portunus 

pelagicus 

- Decreased 

size of crabs 3.20 Mortimer and Miller 1994 

Surrogate AquaticDependent Species Type Surrogate 

Species 

Exposure 

Type 

Effect 

Endpoint 

CTETO

(mg/kg 

bw/d) 

Study (source) 

Mammals Rat 1-yr oral in 

water 

body weight 

and food 

consumption 

3.28 

Sample et al. 

1996 

(OR Toxics 

BE) 

Birds Chick - - 8.59 

Romoser et al. 

1961 

(OR Toxics 

BE) 

a) Listed species. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-89 

Table 5-29. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative Surrogate 

Taxa to Dissolved Chromium 

Taxa 

ECW

(Pre-Permit 

Condition); 

(μg/L) 

ECW

(Post-Permit 

Condition); 

(μg/L) 

CTETA,W

(μg/L) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Freshwater Vertebrate 

0.0000399 0.0000338 

30.11 <0.0001 <0.0001 

Freshwater Invertebrate 1.539 <0.0001 <0.0001 

Freshwater plant (Vascular) 30.42 <0.0001 <0.0001 

Estuarine/Marine 

Vertebrate 

0.00191 0.00185 

921.4 <0.0001 <0.0001 

Estuarine/Marine 

Invertebrate 17.56 0.000109 0.000106 

Saltwater plant (Vascular) 99,300 <0.00001 <0.00001 

Taxa 

ECT

(Pre-Permit 

Condition); 

(mg/kg wet 

wt.) 

ECT

(Post-Permit 

Condition); 

(mg/kg wet 

wt.) 

CTETA,T

(mg/kg wet 

wt.) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Freshwater Vertebrate 

0.0000016 0.00000135 

1.28 <0.00001 <0.00001 

Freshwater Invertebrate NA - - 

Freshwater plant (Vascular) NA - - 

Estuarine/Marine 

Vertebrate 

0.0000765 0.0000742 

NA - - 

Estuarine/Marine 

Invertebrate 3.20 <0.00001 <0.00001 

Saltwater plant (Vascular) NA - - 

Taxa 

ECO

(Pre-Permit 

Condition); 

(mg/kg bw/d) 

ECO

(Post-Permit 

Condition); 

(mg/kg bw/d) 

CTETO

(mg/kg bw/d) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Mammals (Freshwater) 0.000000128 0.000000109 3.28 <0.00001 <0.00001 

Birds (Freshwater) 0.00000121 0.00000103 8.59 <0.00001 <0.00001 

Mammals (Saltwater) 0.00000612 0.00000593 3.28 <0.00001 <0.00001 

Birds (Saltwater) 0.000058 0.0000562 8.59 <0.00001 <0.00001 

5.3.2.4.2 Indirect Effects from Chromium 

The RQs summarized above and in Table 5-30 indicate “remote” risk for direct effects of 

dissolved chromium (expressed as chromium VI) to listed aquatic and aquatic-dependent species 

in this BE. Furthermore, discharge of dissolved chromium from covered vessels will not result in 

appreciable concentrations in estuaries and freshwater receiving water bodies. 

There is no basis for assuming indirect effects on listed species via dissolved chromium 

exposure and corresponding toxicity-related reduction in the prey base [loss of prey] available to 

upper trophic level organisms. Since the information summarized in Table 5-29 indicates that 

dissolved chromium at maximum exposure concentrations calculated from pre-, and especially 

after post-permit conditions (15 to 3 percent reduction, freshwater and saltwater receiving water, 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-90 

respectively), has little risk of directly affecting fresh- and saltwater aquatic animals and plants 

(particularly saltwater plants), indirect effects typically associated with exposure, including loss 

of cover and changes in water quality parameters, are also not expected for this metal. 

Risk Conclusion for each of Listed Species in RAAs - Chromium

Based on the exposure and direct and indirect effects assessment as outlined above, the 

following risk conclusions are being made for each of the listed species in the RAAs (see Table 

5-30). This information is used to inform decisions in the effects determinations made in Section 

7 of this document. 

Table 5-30. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Chromium 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumptions 

Saltwater Corals Remote  Exposed via water column only 

 Risk quotient indicates very low potential for direct 

chronic effects 

 Fate of dissolved chromium indicates very low potential 

for indirect effects (loss of prey and change in 

habitat/water quality parameters) – at the concentrations 

predicted 

 Surrogate CTET is representative and appropriate 

Unionid Mussels Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using an 

acute toxicity data for a juvenile mussel (Andonta 

imbecillis) with an LC50 of 39 μg/L (Keller and Zam, 

1991). Dividing the acute value by the freshwater 

invertebrate ACR of 5.00 results in a chronic value of 

7.8 μg/L. Calculation results in pre- and post-permit 

RQs are below 0.00001. 

Saltwater Bivalve Mollusk Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a 7-d 

study with Asian clam (Potamocorbula amurensis) with 

an MATC (survival) of 14,664 μg/L. Calculation results 

in pre- and post-permit RQs far below 0.00001. 

Freshwater Shrimp/ Crustacean Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a 24-

hr acute study with fairy shrimp (Streptocephalus 

texanus) and an LC50 of 53.1 μg/L (Crisinel et al. 1994). 

Dividing by the freshwater invertebrate ACR of 5.00 

results in a chronic value of 10.62 μg/L. Calculation 

results in pre- and post-permit RQs below 0.00001. 

Freshwater Fish/ Inland 

Salmonid 

Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using an 

ELS test with Atlantic salmon (S. salar) and an MATC 

(survival) of 31.30 μg/L (Grande and Andersen, 1983). 

Calculation results in pre- and post-permit RQs below 

0.00001. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-91 

Table 5-30. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Chromium 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumptions 

Anadromous Salmonid Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a 15-d 

study with Coho/silver salmon (O. kisutch) and an 

MATC (survival) of 23,792 μg/L (Holland et al., 1960). 

Calculation results in pre- and post-permit RQs far 

below 0.00001. 

Freshwater Fish/ Inland 

Sturgeon 

Remote Same as Saltwater Corals’ Presumptions 

Anadromous Sturgeon Remote Same as Saltwater Corals’ Presumptions 

Estuarine/ Marine Fish Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for M. menidia 

as presented in Table 5-28 above 

Beetle and Aquatic Insect Remote Same as Saltwater Corals’ Presumptions 

Amphibian Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using 

chronic toxicity data with Montevido tree frog 

(Hypsiboas pulchellus) and an MATC (survival) of 

4,243 μg/L (Natale et al., 2006). Calculation results in 

pre- and post-permit RQs far below 0.00001. 

Snakes and Other Reptiles Remote Same as Saltwater Corals’ Presumptions 

Sea Turtles Remote Same as Saltwater Corals’ Presumptions

Coastal/Marine Birds Remote Same as Saltwater Corals’ Presumptions

Marine Mammal Remote Same as Saltwater Corals’ Presumptions

Terrestrial Mammal Remote Same as Saltwater Corals’ Presumptions

Seagrass Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for A. flavus as 

presented in Table 5-28 above 

Freshwater- Saltwater Aquatic 

and Wetland Plants 

Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for H. 

verticillata as presented in Table 5-28 above 

 RQ directly applicable since estimated for A. flavus as 

presented in Table 5-28 above 

5.3.2.5 Copper (Dissolved) 

Dissolved copper is ubiquitous in vessel discharges, often at concentrations that could 

potentially pose risk based on screening level benchmarks (see Section 3.2.3.5). The highest 

concentrations of dissolved copper were detected in the deck washdown, graywater, fish hold, 

and bilgewater discharges from most covered vessels, particularly working “utility” vessels (e.g., 

towboats, supply boats). Dissolved copper is also expected to continuously leach into 

surrounding waters from copper-based anti-fouling coatings specifically applied to the vessel 

hull and sea water piping systems to limit attachment of aquatic species. 

The toxicity of copper is dependent on copper speciation where free ionic copper (Cu2+) 

is the main toxic form of copper. In general, free ionic copper, and thus potential toxicity, will be 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-92 

high in waters of low ionic strength, low concentrations of natural organic matter, and low pH 

(Grosell, 2012). In addition recent studies have revealed that extreme salinities, low as well as 

high (33 ppt), render euryhaline fish more sensitive to copper than intermediate salinities, 

although fish in seawater show greater overall tolerance to copper than those in freshwater 

(Grosell et al., 2007). 

Copper is an essential element for all aerobic organisms where it is utilized by 

mitochondrial cytochrome c oxidase, as well as a cofactor for a high number of other enzymes 

(Solomon and Lowery, 1993). Specific evidence for an important role for copper as a 

micronutrient in teleost fish comes from observations of reduced growth under conditions of low 

ambient and dietary copper (Ogino and Yang, 1980; Gatlin and Wilson, 1986; Kamunde et al., 

2002). Owing to its relatively strong essentiality where copper uptake is under homeostatic 

control (i.e., carrier-mediated and a function of concentration in water and diet), 

biomagnification is not considered a major factor for copper (Grosell, 2012). In fact, BCFs 

(accumulation from dissolved sources) and BAFs (accumulation from dissolved and dietary 

sources combined) for copper in freshwater organisms in general are inversely related to 

exposure concentrations (McGeer et al., 2003; DeForest et al., 2007). 

Since copper toxicity to freshwater aquatic animals has been shown to be related to water 

hardness, it is appropriate to normalize chronic toxicity effect thresholds for freshwater aquatic 

animals to a standard water hardness (i.e., 100 mg/L as CaCO3) for comparative purposes and to 

support risk calculation (USEPA, 2005b). 

5.3.2.5.1 Direct Effects from Copper 

Table 5-31 summarizes the chronic toxicity values available for calculating the risk 

quotients for aquatic and aquatic-dependent species exposed to dissolved copper. Table 5-32 

presents the maximum exposure concentrations estimated in ambient receiving waters (ECW), in 

tissues of aquatic organisms exposed to those concentrations (ECT), and in oral doses of aquaticdependent animals ingesting food (prey) and water in those receiving waters (ECO). Maximum 

exposure concentrations in ambient receiving water are from the hypothetical harbor modeling 

(pre- and post-permit condition), as described above in Section 5.2.1. 

Risk to Freshwater Aquatic Animal and Plant Species - Copper 

The risk to freshwater aquatic organisms from maximum exposure to dissolved copper in 

ambient receiving water from discharges of covered vessels is expected to generally be low. RQs 

for freshwater vertebrates and the more “chronically copper-sensitive” freshwater invertebrates 

are 0.007 and 0.008, respectively, and indicate only “remote” risk (Table 5-32). The RQ for 

freshwater vascular plants is substantially lower at approximately 0.0003, also indicative of 

“remote” risk. Control measures implemented as part of the issuance of the permits is anticipated 

to lower the risk to all freshwater species exposed to dissolved copper from permitted vessel 

discharges by approximately 1 percent. 

Because copper is a nutritionally essential inorganic element for all species, both plant 

and animal, copper has the potential to accumulate in tissues of aquatic animals, as long as water 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-93 

column or dietary concentrations are not so high as to overwhelm homeostatic mechanisms, 

aquatic species are able to regulate their internal body burden of copper. Aquatic organism 

exposure to copper concentrations in excess of nutritional needs via other potential routes of 

exposure in addition to direct waterborne toxicity (e.g. dietary toxicity) may pose a threat to 

listed species. While copper does not bioaccumulate to high levels in aquatic animals, EPA 

believes it is prudent to incorporate an analysis on multiple routes of exposure in their analysis of 

this pollutant. The evaluation of potential risks from bioaccumulated copper provides a means of 

identifying potential risks to listed species via exposure to criteria concentrations from all 

exposure routes combined. 

RQs for freshwater aquatic vertebrates and invertebrates based on estimated 

concentrations accumulated in tissues from continuous exposure to a maximum concentration of 

dissolved copper in ambient receiving water of 0.0328 μg/L (post-permit condition) are 

approximately 0.00318 and 0.00251, respectively, indicating “remote” risk to freshwater aquatic 

animals from copper accumulated in tissues. 

Risk to Saltwater (Estuarine/Marine) Aquatic Animal and Plant Species - Copper

The risk to saltwater aquatic organisms from maximum exposure to dissolved copper in 

ambient receiving water is lower than the same risk predicted for freshwater organisms. The risk 

to saltwater invertebrates is “remote” (RQ of approximately 0.047), as are the risks to saltwater 

vascular plants and vertebrates (RQs below 0.01). Control measures implemented as part of the 

issuance of the permits is anticipated to lower the risk to all saltwater species exposed to 

dissolved copper from permitted vessel discharges by approximately 1 percent. 

RQs for saltwater aquatic vertebrates and invertebrates based on estimated concentrations 

accumulated in tissues from continuous exposure to a maximum concentration of dissolved 

copper in ambient receiving water of 0.37 μg/L (post-permit condition) are approximately 0.0234 

and 0.0275, respectively, indicating “remote” risk to saltwater aquatic animals from copper 

accumulated in tissues. 

Risk to Birds and Mammals - Copper 

An evaluation of risk to aquatic-dependent birds and mammals from exposure via 

consumption of prey items or drinking ambient surface water at the maximum concentrations 

predicted for dissolved copper is required because of the need for and ability of organisms to 

accumulate copper in tissues at low levels. The RQs for representative freshwater and saltwater 

mammals and birds based on the chronic toxicity values in relation to the oral effects 

concentrations calculated for this BE are at or less than 0.002. These RQs indicate “remote” risk 

of dissolved copper to aquatic-dependent birds and mammals. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-94 

Table 5-31. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Dissolved Copper 

Surrogate Aquatic 

Species Type Surrogate Species 

Exposure/ 

Effect 

Endpoint 

NOEC - LOEC 

(μg/L) 

CTETA,W

(μg/L) Study (source) 

COPPER - Dissolved 

(*freshwater data normalized to hardness = 100 mg/L CaCO3 using EPA derived acute slope of 0.8545 and 

EPA dissolved conversion factor of 0.960; or, using dissolved conversion factor of 0.83 only in 

estuarine/marine)

Freshwater 

Vertebrate 

a

 Fountain darter, 

Etheostoma 

fonticola 

28-day juvenile 

F,M/ 

Survival 

- 4.69 * Mayer et al. 2008 

Freshwater 

Invertebrate 

Rotifer, 

Brachionus 

calyciflorus 

LC Test - 

Intrinsic 

growth rate 

2.5 - 5.0 3.535 

(3.899 *) 

Janssen et al. 1994 

(2007 ALC doc.) 

Freshwater Plant 

(Vascular) 

Duckweed, 

Lemna minor 7-d EC50 - 119 (114.2 *) 

Walbridge 1977 

(2007 ALC doc.) 

Estuarine/ Marine 

Vertebrate 

Sheepshead 

minnow, 

Cyprinodon 

variegatus 

ELS Test – 

Growth 172 - 362 249 (206.7 *) 

Hughes et al. 1989 

(2007 ALC doc.) 

Estuarine/ Marine 

Invertebrate 

Rotifer, 

Brachionus 

plicatilis 

96-hr Growth 6.1 - 10.3 7.9 

(dissolved) 

Arnold et al. 2010 

(Cu Dev. Assoc. 

work) 

Estuarine/ Marine 

Plant (Vascular) 

Giant kelp, 

Macrocystis 

pyrifera 

96-hr EC50 – 

Photosynthesis - 60 (49.8 *) 

Clendenning and 

North 1959 

(2003 Draft ALC 

Update) 

Surrogate Aquatic 

Species Type 

Surrogate 

Species 

Exposure 

Type 

Effect 

Endpoint 

CTETA,T

(mg/kg wet 

wt.) 

Study (source) 

Freshwater 

Vertebrate 

Rainbow trout, 

Oncorhynchus 

mykiss 

ELS Test Reduction in 

growth 3.0 Seim et al. 1984 

Freshwater 

Invertebrate 

Cladoceran, 

Ceriodaphnia 

dubia 

LC Test 

25% reduction 

offspring 

produced 

3.8 Schwartz et al. 

2004 

Estuarine/ Marine 

Vertebrate 

Grey mullet, 

Chelon labrosus 

10-wk juvenile 

dietary 

exposure 

Decreased 

growth and food 

intake, 

induced hepatic 

lipid 

4.59 Baker et al. 1998 

Estuarine/ Marine 

Invertebrate 

Copepod, 

Acartia clausi - Reduced egg 

production 3.9 

MoraitouApostolopoulos 

and Verriopoulos 

1979 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-95 

Table 5-31. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Dissolved Copper 

Surrogate AquaticDependent Species 

Type 

Surrogate 

Species 

Exposure 

Type 

Effect 

Endpoint 

CTETO

(mg/kg 

bw/d) 

Study (source) 

Mammals Mink 357-d oral in 

diet Reproduction 11.7 

Sample et al. 1996 

(Oregon Toxics 

BE) 

Birds Chicken 10-wk oral in 

diet 

Growth, 

mortality 47 

Sample et al. 1996 

(Oregon Toxics 

BE) 

a) Listed species. 

Table 5-32. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative Surrogate Taxa to 

Dissolved Copper 

Taxa 

ECW

(Post-Permit Condition) 

(μg/L) 

CTETA,W

(μg/L) 

RQ 

(Post-Permit) 

Freshwater Vertebrate 0.0328 4.690 0.007 

Freshwater Invertebrate 3.899 0.00842 

Freshwater plant 

(Vascular) 114.2 0.000288 

Estuarine/Marine 

Vertebrate 

0.37 206.7 0.00179 

Estuarine/Marine 

Invertebrate 7.900 0.0469 

Saltwater plant (Vascular) 49.80 0.00743 

Taxa 

ECT

(Post-Permit Condition) 

(mg/kg wet wt) 

CTETA,T

(mg/kg wet wt) 

RQ 

(Post-Permit) 

Freshwater Vertebrate 0.00953 3.00 0.00318 

Freshwater Invertebrate 3.80 0.00251 

Freshwater plant 

(Vascular) NA - 

Estuarine/Marine 

Vertebrate 0.107 4.59 0.0234 

Estuarine/Marine 

Invertebrate 3.90 0.0275 

Saltwater plant (Vascular) NA - 

Taxa 

ECO

(Post-Permit Condition) 

(mg/kg bw/d) 

CTETO

(mg/kg bw/d) 

RQ 

(Post-Permit) 

Mammals (Freshwater) 0.00131 11.7 0.000112 

Birds (Freshwater) 0.00722 47.0 0.000154 

Mammals (Saltwater) 0.0147 11.7 0.00126 

Birds (Saltwater) 0.0813 47.0 0.00173 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-96 

5.3.2.5.2 Indirect Effects from Copper 

The RQs summarized above and in Table 5-32 indicate “remote” risk for direct effects of 

dissolved copper to listed aquatic and aquatic-dependent species in this BE. Furthermore, 

discharge of dissolved copper does not appear to result in appreciable concentrations in modeled 

estuaries and freshwater receiving water bodies under highly conservative scenarios. 

There is no basis for assuming indirect effects on listed species via copper exposure and 

corresponding toxicity-related reduction in the prey base [loss of prey] available to upper trophic 

level organisms. Additionally, exposure of wildlife via the water or via the food web to this 

essential metal appears to be of limited (negligible) consequence. Since the information 

summarized in Table 5-32 indicates that copper at maximum exposure concentrations under 

post-permit conditions has only reomte risk of directly affecting fresh- and saltwater aquatic 

animals and plants, indirect effects typically associated with exposure, including loss of cover 

and changes in water quality parameters, are also not expected for this metal. 

Risk Conclusion for each of Listed Species in RAAs - Copper

Based on the exposure and direct and indirect effects assessment as outlined above, the 

following risk conclusions are being made for each of the listed species in the RAAs (see Table 

5-33). This information is used to inform decisions in the effects determinations made in Section 

7 of this document. 

Table 5-33. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Copper 

Listed Species 

Taxonomic Group Risk Conclusion Presumptions 

Saltwater Corals Remote  Exposed via water column only 

 Risk quotient indicates very low potential for direct chronic 

effects 

 Fate of dissolved copper indicates very low potential for 

indirect effects (loss of prey and change in habitat/water 

quality parameters) – at the concentrations predicted 

 Surrogate CTET is representative and appropriate 

 Risk conclusion is confirmed via estimation using 4-d acute 

toxicity data with the non-North American coral (Galaxea 

fascicularis) with an LC50 of 32 μg/L (26.82 μg/L 

dissolved; Sabdono, 2009). Dividing this by the FACR of 

3.22 results in a chronic value of 8.33 μg/L. Calculation 

results in pre- and post-permit RQs of approximately 0.019. 

Unionid Mussels Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using acute 

study with the mussel (Actinonaias sp.) SMAV from the 

2007 ALC doc. of 11.33 μg/L (Keller, unpublished) and 

dividing by the FACR of 3.22, which results in a chronic 

value of 3.519 μg/L. Calculation results in pre- and postpermit RQs of approximately 0.0094. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-97 

Table 5-33. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Copper 

Listed Species 

Taxonomic Group Risk Conclusion Presumptions 

Saltwater Bivalve 

Mollusk 

Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using 7-d study 

with blue mussel (Mytilus edulis) and a LOEC (mortality) of 

200 μg/L (167.6 μg/L dissolved; Scott and Major, 1972). 

Calculation results in pre- and post-permit RQs of 

approximately 0.0009. 

Freshwater Shrimp/ 

Crustacean 

Remote Same as Saltwater Corals’ Presumptions 

Freshwater Fish/ Inland 

Salmonid 

Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a chronic 

study with rainbow trout (O. mykiss) and an MATC (growth) 

of 7.29 μg/L (normalized to 100 mg/L on a dissolved basis) 

(Mayer et al., 2008). Calculation results in pre- and postpermit RQs of approximately 0.045. 

Anadromous Salmonid Remote Same as Saltwater Corals’ Presumptions 

Freshwater Fish/ Inland 

Sturgeon 

Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using acute 

toxicity data with the shovelnose sturgeon (Scaphirhynchus 

platorynchus) from the 2007 ALC doc., which has an 

SMAV of 69.63 μg/L (Dwyer et al., 1999). Dividing by the 

FACR of 3.22 results in a chronic value of 21.62 μg/L. 

Calculation results in pre- and post-permit RQs of 

approximately 0.0015. 

Anadromous Sturgeon Remote Same as Saltwater Corals’ Presumptions 

Estuarine/ Marine Fish Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for L. variegatus as 

presented in Table 5-31 above 

Beetle and Aquatic Insect Remote Same as Saltwater Corals’ Presumptions 

Amphibian Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using acute 

toxicity data with the boreal toad (Bufo boreas) from 

USEPA 2007b ALC document, which has an SMAV of 

47.49 μg/L (Dwyer et al., 1999). Dividing by the FACR of 

3.22 results in a chronic value of 14.75 μg/L. Calculation 

results in pre- and post-permit RQs of approximately 0.0022. 

Snakes and Other 

Reptiles 

Remote Same as Saltwater Corals’ Presumptions 

Sea Turtles Remote Same as Saltwater Corals’ Presumptions 

Coastal/Marine Birds Remote Same as Saltwater Corals’ Presumptions 

Marine Mammal Remote Same as Saltwater Corals’ Presumptions 

Terrestrial Mammal Remote Same as Saltwater Corals’ Presumptions 

Seagrass Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for M. pyrifera as 

presented in Table 5-31 above 

Freshwater- Saltwater 

Aquatic and Wetland 

Plants 

Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for L. minor as 

presented in Table 5-31 above 

 RQ directly applicable since estimated for M. pyrifera as 

presented in Table 5-31 above 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-98 

5.3.2.6 Lead (Dissolved) 

Dissolved lead is found at levels exceeding screening level benchmarks in the deck 

washdown discharges from most covered vessels, particularly working “utility” vessels (e.g., 

towboats, supply boats), and to a lesser extent, in graywater and fish hold discharges (see Section 

3.2.3.5). Lead is a naturally occurring, ubiquitous compound in freshwater present at 

concentrations generally less than 3 μg/L in most streams (Moore and Ramamoorthy, 1984). 

Measured concentrations in rivers and streams of the United States averaged between 5 and 23 

μg/L nationwide (Eisler, 1988). Higher concentrations are associated either with anthropogenic 

sources or occur in highly mineralized regions. 

The solubility of lead compounds in water depends heavily on pH and ranges from about 

10,000,000 μg/L of lead at pH 5.5 to 1 μg/L at pH 9.0 (Hem and Durum, 1973). The 

bioavailability of lead increases in environments with low pH, low organic content, and low 

metal salt content (Eisler, 1988). Invertebrates tend to have higher BCFs than vertebrates 

(USEPA, 1984b). 

Toxicity of lead to aquatic organisms varies with water temperature, pH, water hardness, 

metal salt concentrations, organic matter, and suspended solid concentration (USEPA, 1984b). 

Organic lead compounds are generally more toxic than inorganic (Eisler, 1988). 

Since lead toxicity to freshwater aquatic animals has been shown to be related to water 

hardness, it is appropriate to normalize chronic toxicity effect thresholds for freshwater aquatic 

animals to a standard water hardness (i.e., 100 mg/L as CaCO3) for comparative purposes and to 

support risk calculation (USEPA, 2005b). 

5.3.2.6.1 Direct Effects from Lead 

Table 5-34 summarizes the chronic toxicity values available for calculating the risk 

quotients for aquatic and aquatic-dependent species exposed to dissolved lead. Table 5-35 

presents the maximum exposure concentrations estimated in ambient receiving waters (ECW), in 

tissues of aquatic organisms exposed to those concentrations (ECT), and in oral doses of aquaticdependent animals ingesting food (prey) and water in those receiving waters (ECO). Maximum 

exposure concentrations in ambient receiving water are from the hypothetical harbor modeling 

(pre- and post-permit condition), as described above. 

Risk to Freshwater Aquatic Animal and Plant Species - Lead

The overall risk to freshwater aquatic organisms as a result of maximum exposure in 

ambient waters from dissolved lead discharged by permitted vessels is “remote”. All RQA,Ws are 

well below a value of 0.0001, particularly for freshwater vertebrates and vascular plants. The 

highest RQ is 0.00002 estimated for freshwater invertebrates under the pre-permit condition. 

Control measures implemented as part of the issuance of the permits is anticipated to lower the 

risk to all freshwater species exposed to dissolved copper from permitted vessel discharges by 

approximately 5 percent. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-99 

While lead does not bioaccumulate to high levels in aquatic animals, EPA believes it is 

prudent to incorporate the analysis on multiple routes of exposure in this BE for this essential 

metal. The evaluation of potential risks from bioaccumulated lead provides a means of 

identifying potential risks to listed aquatic species via exposure to criteria concentrations from all 

exposure routes combined. 

RQs were calculated for freshwater vertebrates and invertebrates based on estimated 

concentrations accumulated in tissues from continuous exposure to maximum concentrations of 

dissolved lead in ambient receiving waters of 0.0000922 and 0.0000878 μg/L, pre- and postpermit conditions, respectively (see Table 5-35). Corresponding RQs were also all below 0.0001, 

indicating “remote” risk to freshwater aquatic animals from lead accumulated in tissues. 

Risk to Saltwater (Estuarine/Marine) Aquatic Animal and Plant Species - Lead

The overall risk to saltwater aquatic organisms as a result of maximum exposure in 

ambient waters from dissolved lead discharged by permitted vessels is also “remote”. All RQA,Ws 

are 0.0004 or less. Control measures implemented as part of the issuance of the permits is 

anticipated to lower the risk to all saltwater species exposed to dissolved lead from permitted 

vessel discharges by approximately 11 percent. 

An RQ was calculated for saltwater invertebrates based on estimated concentrations 

accumulated in tissues from continuous exposure to maximum concentrations of dissolved lead 

in ambient receiving waters of 0.00295 and 0.00262 μg/L, pre- and post-permit conditions, 

respectively (see Table 5-35). Corresponding RQs were at or below 0.0001, again, indicating 

“remote” risk to aquatic animals (saltwater in this case) from lead accumulated in tissues. 

Risk to Birds and Mammals - Lead

An evaluation of risk to aquatic-dependent birds and mammals from exposure via 

consumption of prey items or drinking ambient surface water at the maximum concentrations 

predicted for dissolved lead is required because of the apparent ability of some organisms to 

accumulate lead in tissues, albeit to low levels. The RQs for representative freshwater and 

saltwater mammals and birds based on the chronic toxicity values in relation to the oral effects 

concentrations calculated for this BE are all extremely low (<0.00001). These RQs indicate 

“remote” risk of lead to aquatic-dependent birds and mammals. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-100 

Table 5-34. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Dissolved Lead 

Surrogate Aquatic 

Species Type 

Surrogate 

Species 

Exposure/ 

Effect 

Endpoint 

NOEC - 

LOEC 

(μg/L) 

CTETA,W

(μg/L) Study (source) 

LEAD - Dissolved 

(* normalized using EPA pooled slope of 1.442 and using dissolved conversion factor of 1.46203-[(ln 

hardness)(0.145712)] freshwater and 0.951 estuarine/marine) 

Freshwater Vertebrate 

Rainbow trout, 

Oncorhynchus 

mykiss 

ELS Test - 

Development 13.2 - 27 18.88 

(93.62*) 

Goettl et al. 1972; 

Davies and 

Everhart 1973; 

Davies et al. 1976 

(1980 ALC doc.) 

Freshwater Invertebrate Amphipod, 

Hyalella azteca LC Test 7.9 - 18 11.92 

(6.050*) 

Besser et al. 

2005b 

(NODA review) 

Freshwater Plant 

(Vascular) 

Duckweed, 

Lemna minor 

96-hr EC50 – 

Growth - 8,000 Wang 1986 

Estuarine/ Marine 

Vertebrate 

Cabezon, 

Scorpaenichthys 

marmoratus 

Acute LC50 ÷ 

Estuarine 

ACR 

(ACR=124.8) 1,500 ÷ 124.8 

12.02 

(11.43 *) 

(estimated

) 

Dinnel et al. 1989 

(LC50); Lussier 

et al. 1985 (ACR) 

Estuarine/ Marine 

Invertebrate 

Mysid, 

Americamysis 

bahia 

LC Test - 

Reproduction 17 - 37 25.08 

(23.85 *) 

Lussier et al. 

1985 

(1984 ALC doc.) 

Estuarine/ Marine Plant 

(Vascular) Not Available - - 8.1 

CCC from 

USEPA 1980a 

(ALC doc.) 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-101 

Table 5-34. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Dissolved Lead 

Surrogate Aquatic 

Species Type 

Surrogate 

Species 

Exposure 

Type 

Effect 

Endpoint 

CTETA,T

(mg/kg 

wet wt) 

Study (source) 

Freshwater Vertebrate 

Brook trout, 

Salvelinus 

fontinalis 

3 Generation 

Laboratory 

Study 

Reduced 

hatchability 

and survival of 

third 

generation fish 

0.40 Holcombe et al. 

1976 

Freshwater Invertebrate Amphipod, 

Hyalella azteca 

42-d 

concurrent 

exposure in 

water and diet 

Fewer 

offspring 

produced 

4.20 Besser et al. 

2005b 

Estuarine/ Marine 

Vertebrate Not Available 

Estuarine/ Marine 

Invertebrate 

Cockle, 

Cerastoderma 

edule 

- 

Partial 

inhibition of 

burrowing 

260.00 Amiard et al. 

1986 

Surrogate AquaticDependent Species Type Surrogate 

Species 

Exposure 

Type 

Effect 

Endpoint 

CTETO

(mg/kg 

bw/d) 

Study (source) 

Mammals Rat 

3 generations 

(>1 year) oral 

in diet 

Reproduction 8 

Sample et al. 

1996 

(Oregon Toxics 

BE)

Birds Japanese quail 12-wk oral in 

diet Reproduction 1.13 

Sample et al. 

1996 

(Oregon Toxics 

BE) 

Table 5-35. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative Surrogate 

Taxa to Dissolved Lead 

Taxa 

ECW

(Pre-Permit 

Condition); 

(μg/L) 

ECW

(Post-Permit 

Condition); 

(μg/L) 

CTETA,W

(μg/L) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Freshwater Vertebrate 

0.0000922 0.0000878 

93.62 <0.0001 <0.0001 

Freshwater Invertebrate 6.050 <0.0001 <0.0001 

Freshwater plant (Vascular) 8,000 <0.0001 <0.0001 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-102 

Table 5-35. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative Surrogate 

Taxa to Dissolved Lead 

Taxa 

ECW

(Pre-Permit 

Condition); 

(μg/L) 

ECW

(Post-Permit 

Condition); 

(μg/L) 

CTETA,W

(μg/L) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Estuarine/Marine 

Vertebrate 

0.00295 0.00262 

11.43 0.000258 0.000229 

Estuarine/Marine 

Invertebrate 23.85 0.000124 0.00011 

Saltwater plant (Vascular) 8.1 0.000364 0.000323 

Taxa 

ECT

(Pre-Permit 

Condition); 

(mg/kg wet 

wt) 

ECT

(Post-Permit 

Condition); 

(mg/kg wet 

wt) 

CTETA,T

(mg/kg wet 

wt) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Freshwater Vertebrate 

0.00000452 0.0000043 

0.40 <0.0001 <0.0001 

Freshwater Invertebrate 4.20 <0.0001 <0.0001 

Freshwater plant (Vascular) NA - - 

Estuarine/Marine 

Vertebrate 

0.000144 0.000128 

NA - - 

Estuarine/Marine 

Invertebrate 260 <0.0001 <0.0001 

Saltwater plant (Vascular) NA - - 

Taxa 

ECO

(Pre-Permit 

Condition); 

(mg/kg bw/d) 

ECO

(Post-Permit 

Condition); 

(mg/kg bw/d) 

CTETO

(mg/kg bw/d) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Mammals (Freshwater) 0.000000363 0.000000346 8.00 <0.00001 <0.00001 

Birds (Freshwater) 0.00000343 0.00000327 1.13 <0.00001 <0.00001 

Mammals (Saltwater) 0.0000116 0.0000103 8.00 <0.00001 <0.00001 

Birds (Saltwater) 0.000109 0.0000972 1.13 <0.00001 <0.00001 

5.3.2.6.2 Indirect Effects from Lead 

The RQs summarized above and in Table 5-36 indicate “remote” risk for direct effects of 

dissolved lead to listed aquatic and aquatic-dependent species in this BE. Furthermore, discharge 

of dissolved lead from covered vessels will not result in appreciable concentrations in estuaries 

and freshwater receiving water bodies. 

There is no basis for assuming indirect effects on listed species via dissolved lead 

exposure and corresponding toxicity-related reduction in the prey base [loss of prey] available to 

upper trophic level organisms. Since the information summarized in Table 5-35 indicates that 

dissolved lead at maximum exposure concentrations calculated from pre-, and especially after 

post-permit conditions (11 to 5 percent reduction, saltwater and freshwater receiving water, 

respectively), has little risk of directly affecting fresh- and saltwater aquatic animals and plants 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-103 

(particularly freshwater plants), indirect effects typically associated with exposure, including loss 

of cover and changes in water quality parameters, are also not expected for this metal. 

Risk Conclusion for each of Listed Species in RAAs - Lead

Based on the exposure and direct and indirect effects assessment as outlined above, the 

following risk conclusions are being made for each of the listed species in the RAAs (see Table 

5-36). This information is used to inform decisions in the effects determinations made in Section 

7 of this document. 

Table 5-36. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Lead 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumptions 

Saltwater Corals Remote  Exposed via water column only 

 Risk quotient indicates very low potential for direct 

chronic effects 

 Fate of dissolved lead indicates very low potential for 

indirect effects (loss of prey and change in habitat/water 

quality parameters) – at the concentrations predicted 

 Surrogate CTET is representative and appropriate 

Unionid Mussels Remote Same as Saltwater Corals’ Presumptions 

Saltwater Bivalve Mollusk Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a 40-d 

study with blue mussel (Mytilus edulis) and an LC50 of 

30,000 μg/L (28,530 μg/L dissolved) (Talbot et al., 

1976). Calculation results in pre- and post-permit RQs 

far below 0.00001. 

Freshwater Shrimp/ Crustacean Remote Same as Saltwater Corals’ Presumptions 

Freshwater Fish/ Inland 

Salmonid 

Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for O. mykiss as 

presented in Table 5-35 above 

Anadromous Salmonid Remote Same as Freshwater Inland Salmonids – no chronic toxicity 

data are available for salmonids tested in seawater 

Freshwater Fish/ Inland 

Sturgeon 

Remote Same as Saltwater Corals’ Presumptions 

Anadromous Sturgeon Remote Same as Saltwater Corals’ Presumptions 

Estuarine/ Marine Fish Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for S. 

marmoratus as presented in Table 5-34 above 

Beetle and Aquatic Insect Remote Same as Saltwater Corals’ Presumptions 

Amphibian Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a 30-d 

study of leopard frog (Rana pipiens) with an effect 

concentration (death) of 100 μg/L (note hardness not 

provided cannot be normalized) (Kaplan et al., 1967). 

Calculation results in pre- and post-permit RQs of less 

than 0.00001. 

Snakes and Other Reptiles Remote Same as Saltwater Corals’ Presumptions 

Sea Turtles Remote Same as Saltwater Corals’ Presumptions

Coastal/Marine Birds Remote Same as Saltwater Corals’ Presumptions
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Table 5-36. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Lead 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumptions 

Marine Mammal Remote Same as Saltwater Corals’ Presumptions

Terrestrial Mammal Remote Same as Saltwater Corals’ Presumptions

Seagrass Remote Same as Saltwater Corals’ Presumptions

Freshwater- Saltwater Aquatic 

and Wetland Plants 

Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for L. minor as 

presented in Table 5-34 above 

5.3.2.7 Nickel (Dissolved) 

Dissolved and total nickel are ubiquitous in vessel discharges, often at concentrations that 

could pose potential risk based on screening level benchmarks (see Section 3.2.3.5). The highest 

concentrations of nickel were detected in the stern tube packing gland effluent, followed by 

exhaust gas scrubber effluent and bilgewater discharges. 

Nickel occurs naturally in the United States and has been noted to range between 0.4 and 

3.8 μg/L, but is typically less than 10 μg/L (Eisler, 1998). 

Nickel can be carcinogenic, may be mutagenic, but is not teratogenic. Nickel essentiality 

in plants and microorganisms is well established, but of all the known nickel-containing enzymes 

have been isolated from plants or microorganisms, none, as yet, have been isolated in animal 

tissues (Pyle and Couture, 2012). In fish, the evidence for possible nickel essentiality is based on: 

1) the observations that nickel concentrations in fish tissues remain relatively constant despite 

wide fluctuations in environmental concentrations (Tja ̈lve et al., 1988; Ray et al., 1990), 2) 

nickel can be reabsorbed by the kidney (Sreedevi et al., 1992b; Ptashynski and Klaverkamp, 

2002), and 3) nickel uptake from food and water appears to be regulated (Lapointe and Couture, 

2009). Thus, nickel is bioconcentrated and bioaccumulated by aquatic organisms (Eisler, 1998), 

but only to low levels. 

Toxicity of nickel to aquatic organisms is dependent on water hardness, pH, ionic 

composition, pollutant form, type and concentration of ligands, presence of mixtures, and 

availability of solid surfaces for adsorption (Eisler, 1998). Nickel interacts with many 

compounds to produce altered patterns of accumulation, metabolism, and toxicity (Eisler, 1998). 

Mixtures of metals containing nickel salts can be more toxic to daphnids and fishes than are 

predicted on the basis of individual components (Enserink et al., 1991). 

For this analysis, because dissolved nickel concentrations exceeded total nickel 

concentrations on the average, EPA is only considering risk to listed species based on dissolved 

nickel, the most bioavailable (and therefore, toxic) form of the metal. Also, since nickel toxicity 

to freshwater aquatic animals has been shown to be related to water hardness, it is appropriate to 

normalize chronic toxicity effect thresholds for freshwater aquatic animals to a standard water 

hardness (i.e., 100 mg/L as CaCO3) for comparative purposes and to support risk calculation 

(USEPA, 2005b). 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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5.3.2.7.1 Direct Effects from Nickel 

Table 5-37 summarizes the chronic toxicity values available for calculating the risk 

quotients for aquatic and aquatic-dependent species exposed to dissolved nickel. Table 5-38 

presents the maximum exposure concentrations estimated in ambient receiving waters (ECW), in 

tissues of aquatic organisms exposed to those concentrations (ECT), and in oral doses of aquaticdependent animals ingesting food and water in those receiving waters (ECO). Maximum 

exposure concentrations in ambient receiving water are from the hypothetical harbor modeling, 

as described above. Since maximum exposure concentrations based on pre- and post-permit 

conditions are essentially the same, the following risk analysis is based on the use of maximum 

exposure concentrations predicted under the post-permit condition only 

Risk to Freshwater Aquatic Animal and Plant Species - Nickel

The risk to freshwater aquatic organisms from maximum exposure to dissolved nickel in 

ambient receiving water from discharges of covered vessels is “remote”. The RQA,W for 

freshwater invertebrates is 0.00349 while the RQA,W for freshwater vertebrates and vascular 

plants are less than 0.0002 and 0.0001, respectively. 

Because nickel is a nutritionally essential inorganic element, it has the potential to 

accumulate in tissues of aquatic animals. Like other essential metals, aquatic organism exposure 

to nickel concentrations in excess of nutritional needs via other potential routes of exposure in 

addition to direct waterborne toxicity (e.g. dietary toxicity) may pose toxicity threats to some 

species. While nickel does not bioaccumulate to high levels in aquatic animals (Pyle and 

Couture, 2012), EPA believes it is prudent to incorporate an analysis on multiple routes of 

exposure in their analysis of this pollutant. The evaluation of potential risks from bioaccumulated 

nickel provides a means of identifying potential risks to listed species via exposure to criteria 

concentrations from all exposure routes combined. 

An RQ was calculated for freshwater invertebrates based on estimated concentrations 

accumulated in tissues (1.15 mg nickel/kg wet tissue; amphipod - Hyalella azteca) from 

continuous exposure to a maximum concentration of dissolved nickel in ambient receiving 

waters of 0.0246 μg/L (see Table 5-38). The corresponding RQ was 0.001, indicating “remote” 

risk to freshwater aquatic animals from nickel accumulated in tissues. 

Risk to Saltwater (Estuarine/Marine) Aquatic Animal and Plant Species - Nickel

The risk to saltwater aquatic organisms from maximum exposure to dissolved nickel in 

ambient receiving water from discharges of covered vessels is also “remote”. Using the 

maximum exposure concentration estimated under the post-permit condition, RQs for saltwater 

organisms are approximately 0.0354 for vascular plants, 0.0133 for invertebrates and <0.0001 for 

vertebrates. 

An RQ was calculated for saltwater invertebrates based on estimated concentrations 

accumulated in tissues (26.4 mg nickel/kg wet tissue; sea urchin – Lytechinus pictus) from 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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continuous exposure to a maximum concentration of dissolved nickel in ambient receiving 

waters of 0.291 μg/L (see Table 5-38). The corresponding RQ was 0.000518, indicating 

“remote” risk to saltwater aquatic animals from nickel accumulated in tissues. 

Risk to Birds and Mammals - Nickel

An evaluation of risk to aquatic-dependent birds and mammals from exposure via 

consumption of prey items or drinking ambient surface water at the maximum concentrations 

predicted for dissolved nickel is required because of the ability of (and need for) aquatic 

organisms to accumulate this essential metal in tissues. The RQs estimated for surrogate 

mammals and birds based on the quotient of ECO and CTETO for nickel are all below 0.0001. 

These RQs indicate “remote” risk of nickel to aquatic-dependent birds and mammals. 

Table 5-37. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Dissolved Nickel 

Surrogate Aquatic 

Species Type 

Surrogate 

Species 

Exposure/ 

Effect 

Endpoint 

NOEC - 

LOEC 

(μg/L) 

CTETA,W

(μg/L) Study (source) 

NICKEL - Dissolved 

(*normalized using EPA pooled slope of 0.8460 and using EPA dissolved conversion factor of 0.997 

freshwater and 0.990 estuarine/marine)

Freshwater Vertebrate 

Rainbow trout, 

Oncorhynchus 

mykiss 

ELS Test - 62 - 134 91.15 

(158.0 *) 

Nebeker et al. 

1985 

(1986 ALC doc.) 

Freshwater Invertebrate Cladoceran, 

Daphnia magna LC Test - 

5 - 10 

(hardness not 

provided) 

7.071 

(7.050 *) 

Lazareva 1985 

(1986 ALC doc.) 

Freshwater Plant 

(Vascular) 

Duckweed, 

Lemna minor 28-d EC50 

- 

(hardness not 

provided) 

340 

(339.0 *) 

Brown and 

Rattigan 

1979 (1986 ALC 

doc.) 

Estuarine/ Marine 

Vertebrate 

Topsmelt, 

Atherinops affinis LC Test 3,240 - 5,630 4,270 

(4,227 *) 

Hunt et al. 2002 

(Ni saltwater 

addendum) 

Estuarine/ Marine 

Invertebrate 

Mysid, 

Mysidopsis intii LC Test 10.0 - 48.8 22.09 

(21.87 *) 

Hunt et al. 2002 

(Ni saltwater 

addendum) 

Estuarine/ Marine Plant 

(Vascular) Not Available - - 8.2 

(CCC) 

CCC in USEPA 

1986 (ALC doc.) 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Table 5-37. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Dissolved Nickel 

Surrogate Aquatic 

Species Type 

Surrogate 

Species 

Exposure 

Type 

Effect 

Endpoint 

CTETA,T

(mg/kg 

wet wt) 

Study (source) 

Freshwater Vertebrate Not Available 

Freshwater Invertebrate Amphipod, 

Hyalella azteca 

4-wk 

Exposure to 

nickel-spiked 

sediment 

ED25 for 

reduced 

growth 

1.15 Borgmann et al. 

2001 

Estuarine/ Marine 

Vertebrate Not Available 

Estuarine/ Marine 

Invertebrate 

Sea urchin, 

Lytechinus pictus - 

Inhibited 

normal 

development 

of embryos 

26.40 

Timourian and 

Watchmaker 

1972 

Surrogate AquaticDependent Species Type Surrogate 

Species 

Exposure 

Type 

Effect 

Endpoint 

CTETO

(mg/kg 

bw/d) 

Study (source) 

Mammals Rat 

3 generations 

(>1 yr) oral in 

diet 

Reproduction 40 

Sample et al. 

1996 

(Oregon Toxics 

BE) 

Birds Mallard 90-d oral in 

diet 

Mortality, 

growth, 

behavior 

77.4 

Sample et al. 

1996 

(Oregon Toxics 

BE) 

Table 5-38. Risk Quotients based on Division of Pre- and Post-Permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative Surrogate Taxa to 

Dissolved Nickel 

Taxa 

ECW

(Post-Permit Condition) 

(μg/L) 

CTETA,W

(μg/L) 

RQ 

(Post-Permit) 

Freshwater Vertebrate 

0.0246 

158.0 0.000156 

Freshwater Invertebrate 7.050 0.00349 

Freshwater plant (Vascular) 339.0 <0.0001 

Estuarine/Marine Vertebrate 

0.291 

4.227 <0.0001 

Estuarine/Marine Invertebrate 21.87 0.0133 

Saltwater plant (Vascular) 8.2 0.0354 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Table 5-38. Risk Quotients based on Division of Pre- and Post-Permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative Surrogate Taxa to 

Dissolved Nickel 

Taxa 

ECT

(Post-Permit Condition) 

(mg/kg wet wt) 

CTETA,T

(mg/kg wet wt) 

RQ 

(Post-Permit) 

Freshwater Vertebrate 

0.00116 

NA - 

Freshwater Invertebrate 1.15 0.001 

Freshwater plant (Vascular) NA - 

Estuarine/Marine Vertebrate 

0.0137 

NA - 

Estuarine/Marine Invertebrate 26.4 0.000518 

Saltwater plant (Vascular) NA - 

Taxa 

ECO

(Post-Permit Condition) 

(mg/kg bw/d) 

CTETO

(mg/kg bw/d) 

RQ 

(Post-Permit) 

Mammals (Freshwater) 0.0000929 40.0 <0.0001 

Birds (Freshwater) 0.000116 77.4 <0.0001 

Mammals (Saltwater) 0.00109 40.0 <0.0001 

Birds (Saltwater) 0.00137 77.4 <0.0001 

5.3.2.7.2 Indirect Effects for Nickel 

The RQs summarized above and in Table 5-39 indicate “remote” risk for direct effects of 

dissolved nickel to listed aquatic and aquatic-dependent species in this BE. Furthermore, 

discharge of dissolved nickel from covered vessels will not result in appreciable concentrations 

in estuaries and freshwater receiving water bodies. 

There is no basis for assuming indirect effects on listed species via dissolved nickel 

exposure and corresponding toxicity-related reduction in the prey base [loss of prey] available to 

upper trophic level organisms. Since the information summarized in Table 5-38 indicates that 

dissolved nickel at maximum exposure concentrations under post-permit conditions has little risk 

of directly affecting fresh- and saltwater aquatic animals and plants (particularly freshwater 

plants), indirect effects typically associated with exposure, including loss of cover and changes 

in water quality parameters, are also not expected for this metal. 

Risk Conclusion for each of Listed Species in RAAs - Nickel

Based on the exposure and direct and indirect effects assessment as outlined above, the 

following risk conclusions are being made for each of the listed species in the RAAs (see Table 

5-39). This information is used to inform decisions in the effects determinations made in Section 

7 of this document. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Table 5-39. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Nickel 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumptions 

Saltwater Corals Remote  Exposed via water column only 

 Risk quotient indicates very low potential for direct 

chronic effects 

 Fate of dissolved nickel indicates very low potential for 

indirect effects (loss of prey and change in habitat/water 

quality parameters) – at the concentrations predicted 

 Surrogate CTET is representative and appropriate 

Unionid Mussels Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a 4-d 

study with southern fatmucket (Lampsilis straminea 

claibornen) and an LC50 of 132 μg/L (131.6 μg/L 

dissolved; note: hardness not provided) (Keller, 2000). 

Dividing by a FACR of 17.99 results in a chronic value 

of 38.41 μg/L. Calculation results in pre- and postpermit RQs of approximately 0.0006. 

Saltwater Bivalve Mollusk Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a lifecycle test with red abalone (Haliotis rufescens) MATC 

of 26.43 μg/L (26.17 μg/L dissolved; Hunt et al., 2002). 

Calculations result in pre- and post-permit RQs of 

approximately 0.011. 

Freshwater Shrimp/ Crustacean Remote Same as Saltwater Corals’ Presumptions 

Freshwater Fish/ Inland 

Salmonid 

Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for O. mykiss as 

presented in Table 5-37 above 

Anadromous Salmonid Remote Same as Freshwater Inland Salmonids – no chronic toxicity 

data are available for salmonids tested in seawater 

Freshwater Fish/ Inland 

Sturgeon 

Remote Same as Saltwater Corals’ Presumptions 

Anadromous Sturgeon Remote Same as Saltwater Corals’ Presumptions 

Estuarine/ Marine Fish Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for A. affinis as 

presented in Table 5-39 above 

Beetle and Aquatic Insect Remote Same as Saltwater Corals’ Presumptions 

Amphibian Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a 7-d 

study of narrow-mouthed toad (Gastrophryne 

carolinensis) with an EC50 (death and deformity) of 50 

μg/L (50.27 μg/L dissolved and normalized to 100 mg/L 

hardness) (Birge and Black, 1980). Calculations result in 

pre- and post-permit RQs of approximately 0.0005. 

Snakes and Other Reptiles Remote Same as Saltwater Corals’ Presumptions 

Sea Turtles Remote Same as Saltwater Corals’ Presumptions 

Coastal/Marine Birds Remote Same as Saltwater Corals’ Presumptions 

Marine Mammal Remote Same as Saltwater Corals’ Presumptions 

Terrestrial Mammal Remote Same as Saltwater Corals’ Presumptions 

Seagrass Remote Same as Saltwater Corals’ Presumptions 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Table 5-39. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Nickel 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumptions 

Freshwater- Saltwater Aquatic 

and Wetland Plants 

Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for L. minor as 

presented in Table 5-39 above 

 Risk conclusion is confirmed via estimation using a 

study with an unknown duration with giant kelp 

(Macrocystis pyritera) and an EC50 (reduction in 

photosynthesis) of 2,000 (1,980 dissolved) 

(Clendenning and North, 1959). Calculations result in 

pre- and post-permit RQs less than 0.0001. 

5.3.2.8 Selenium (Dissolved and Total) 

Both total and dissolved selenium have been detected in exhaust gas scrubber effluent 

and fish hold and fish hold cleaning effluent that could potentially pose risk based on screening 

level benchmarks (Section 3.2.3.5). Selenium is an abundant trace element in soils derived from 

rocks formed principally in the Cretaceous period (Stephens and Waddell, 1998). Typical 

background concentrations of [total] selenium have been estimated at 0.25 μg/L (Wilber, 1980), 

0.1 to 0.3 μg/L (Lemly, 1985), 0.2 μg/L (Lillebo et al, 1988), and 0.1 to 0.4 μg/L (average <0.2, 

Maier and Knight, 1994). Selenium is also an essential trace element that becomes toxic in living 

systems at concentrations only slightly higher than the optimum concentration (Porcella et al. 

1991; Maier and Knight, 1994). For example, aquatic and terrestrial organisms require 0.5 μg/g 

dry weight (approximately 0.1 mg/kg wet weight tissue) of selenium in their diet to sustain 

metabolic processes, whereas concentrations of selenium that are only an order of magnitude 

greater than the required level have been shown to be toxic to fish. This unique feature of 

selenium has generated a great deal of academic and regulatory research over the past several 

decades. Its role as either a nutrient or toxicant depends on both its concentration and its form 

(Spallholz and Hoffman, 2002). 

In aquatic systems selenium exists in both inorganic and organic forms, each with 

different bioavailability and toxicity properties (see USEPA, 2002). Much like with arsenic, 

selenium is a metalloid and can exist in aquatic systems in a broad range of oxidation states, but 

only elemental selenium, selenites (HSeO3

-

 and SeO3

2-), and selenate (SeO42-) exist in 

thermodynamic equilibrium under most conditions observed in freshwater (EPRI, 2003). Primary 

sources in freshwater and estuarine environments originate from various land use practices, point 

source discharges and natural background, including: fly-ash from coal-fired power plants, 

agricultural irrigation drainage, natural background levels including weathering of seleniferous 

shales and soils in the Western United States. The propensity of selenium to bioaccumulate in 

aquatic and aquatic-dependent organisms directly affected by these point sources has received 

special attention over the last few decades. From these and other intensively studied aquatic 

systems, including several corroborating laboratory studies, it has become clear that the greatest 

threat posed by selenium to aquatic organisms results from chronic selenium exposure, leading to 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-111 

elevated selenium concentrations in tissues (and often to chronic toxic effects), principally 

during early life stages (USEPA, 2002). 

Much like in the case with arsenic, for this analysis, EPA assumes that all selenium in 

fresh- and saltwater is dissolved selenium, and that analysis of direct and indirect effects is best 

addressed using aquatic toxicity data published for surrogate species based on this form of the 

metalloid in tissues of aquatic organisms especially. 

5.3.2.8.1 Direct Effects from Selenium 

Table 5-40 summarizes the chronic toxicity values available for calculating the risk 

quotients for aquatic and aquatic-dependent species exposed to total selenium (assumed 

equivalent to 100 percent dissolved). Table 5-41 presents the maximum exposure concentrations 

estimated in ambient receiving waters (ECW), in tissues of aquatic organisms exposed to those 

concentrations (ECT), and in oral doses of aquatic-dependent animals ingesting food (prey) and 

water in those receiving waters (ECO). Maximum exposure concentrations in ambient receiving 

water are from the hypothetical harbor modeling, as described above in Section 5.2.1. As with 

arsenic, EPA’s risk analysis is based on the use of maximum exposure concentration estimated 

via the post-permit condition only since maximum exposure concentrations based on pre-permit 

condition was the same. 

Risk to Freshwater Aquatic Animal and Plant Species - Selenium

The risk to freshwater aquatic organisms from maximum exposure to total selenium in 

ambient receiving water from discharges of covered vessels is remote. Using the post-permit 

maximum exposure concentrations, RQs for freshwater vertebrates and invertebrates are 

approximately 0.002 (Table 5-41). The RQ for freshwater vascular plants is substantially lower 

at less than 0.0001, indicative of “remote” risk. 

Because selenium is a nutritionally essential inorganic element for all species, both plant 

and animal, selenium has the potential to accumulate in tissues of aquatic animals, as long as 

water column or dietary concentrations are not so high as to overwhelm homeostatic 

mechanisms, aquatic species are able to regulate their internal body burden of selenium. Aquatic 

organism exposure to selenium concentrations in excess of nutritional needs via other potential 

routes of exposure in addition to direct waterborne toxicity (e.g. dietary toxicity) poses the 

greatest threat to listed species. While selenium does bioaccumulate in aquatic animals, it does 

not biomagnify (EPRI, 2003), and it is thus both important and prudent to incorporate an analysis 

on multiple routes of exposure in the analysis of this pollutant for this BE. The evaluation of 

potential risks from bioaccumulated selenium provides a means of identifying potential risks to 

listed species via exposure to criteria concentrations from all exposure routes combined. 

RQs for freshwater aquatic vertebrates and invertebrates based on estimated 

concentrations accumulated in tissues from continuous exposure to a maximum concentration of 

total selenium in ambient receiving water of 0.203 μg/L are approximately 0.0105 and 0.028, 

respectively, indicating “remote” risk to freshwater aquatic animals from total selenium 

accumulated in tissues. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-112 

Risk to Saltwater (Estuarine/Marine) Aquatic Animal and Plant Species - Selenium

The risk to saltwater aquatic organisms from maximum total selenium exposure in 

ambient receiving water is higher than the same risk predicted for freshwater organisms (Table 

5-41). The risk to saltwater vertebrates and invertebrates is “remote” (0.01 and less), and only 

slightly higher for saltwater vascular plants when using EPA’s CCC for selenium in saltwater at 

the basis for CTETA,W (RQ equal to 0.034). 

An RQ for saltwater aquatic vertebrates based on estimated concentrations accumulated 

in tissues from continuous exposure to maximum concentrations of total selenium in ambient 

receiving water of 2.39 μg/L is approximately thirteen times higher (i.e., 0.136) than for 

vertebrates in freshwater, indicating a “negligible” risk to saltwater aquatic animals from total 

selenium accumulated in tissues. 

Risk to Birds and Mammals - Selenium

An evaluation of risk to aquatic-dependent birds and mammals from exposure via 

consumption of prey items or drinking ambient surface water at the maximum concentrations 

predicted for total selenium is required because of the need for and ability of organisms to 

accumulate selenium in tissues at low levels. The RQs for representative freshwater and 

saltwater mammals and birds based on the chronic toxicity values in relation to the oral effects 

concentrations calculated for this BE range from 0.0101 to 0.0203 for freshwater birds and 

mammals, respectively, and from 0.054 to 0.108 for saltwater birds and mammals (Table 5-41). 

Table 5-40. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Total Selenium 

Surrogate Aquatic 

Species Type 

Surrogate 

Species 

Exposure/ 

Effect 

Endpoint 

NOEC - 

LOEC 

(μg/L) 

CTETA,W

(μg/L) Study (source) 

Freshwater Vertebrate 

Rainbow trout, 

Oncorhynchus 

mykiss 

ELS Test - 60 - 130 88.32 

Goettl and Davies 

1977 

(2004 Draft ALC 

doc.) 

Freshwater Invertebrate Cladoceran, 

Daphnia magna LC Test - 70 - 120 91.65 

Kimball 1978 

(2004 Draft ALC 

doc.) 

Freshwater Plant 

(Vascular) 

Duckweed, 

Lemna minor EC50 - 2,400 

Wang 1986 

(2004 Draft ALC 

doc.) 

Estuarine/ Marine 

Vertebrate 

Sheepshead 

minnow, 

Cyprinodon 

variegatus 

ELS Test - 470 - 970 675.2 

Ward et al. 1981 

(2004 Draft ALC 

doc.) 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Table 5-40. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Total Selenium 

Estuarine/ Marine 

Invertebrate 

Mysid, 

Americamysis 

bahia 

LC Test - 140 - 320 211.7 

USEPA 1978; 

Ward et al. 1981 

(2004 Draft ALC 

doc.) 

Estuarine/ Marine Plant 

(Vascular) Not Available - - 71 

CCC from 

USEPA 1987a 

(ALC doc.) 

Surrogate Aquatic 

Species Type 

Surrogate 

Species 

Exposure 

Type 

Effect 

Endpoint 

CTETA,T

(mg/kg 

wet wt) 

Study (source) 

Freshwater Vertebrate 

Rainbow trout, 

Oncorhynchus 

mykiss 

Dietary and 

waterborne 

(Field StudyLuscar River, 

Alberta) 

Cranio-facial 

deformity in 

larvae 

4.84 

Holm 2002; 

Holm et al. 2003 

in 2004 Draft 

ALC document 

(see USEPA 

2004b) 

Freshwater Invertebrate 

Mayfly, 

Centroptilum 

triangulifer 

- Reproduction 5.28 

2004 Draft ALC 

document (see 

USEPA 2004b) 

Estuarine/ Marine 

Vertebrate Fish

Based on 

tissue-based 

Final Chronic 

Value of 7.91 

ug/g dw tissue 

assuming 

75% moisture 

Survivorship 1.98 

2004 Draft ALC 

document (see 

USEPA 2004b) 

Estuarine/ Marine 

Invertebrate Not applicable - 

Surrogate AquaticDependent Species Type Surrogate 

Species 

Exposure 

Type 

Effect 

Endpoint 

CTETO

(mg/kg 

bw/d) 

Study (source) 

Mammals Rat 1-yr oral in 

diet Reproduction 0.2 

Sample et al. 

1996 (OR Toxics 

BE) 

Birds Mallard 78-d oral in 

diet Reproduction 0.5 

Sample et al. 

1996 (OR Toxics 

BE) 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Table 5-41. Risk Quotients Based on Division of Pre- and 

Post-permit Exposure Concentrations by Chronic Toxicity 

Effect Thresholds of Representative Surrogate Taxa to 

Total Selenium 

Taxa 

ECW

(Post-Permit 

Condition); 

(μg/L) 

CTETA,W

(μg/L) 

RQ 

(PostPermit) 

Freshwater Vertebrate 

0.203 

88.32 0.0023 

Freshwater Invertebrate 91.65 0.00221 

Freshwater plant (Vascular) 2,400 <0.0001 

Estuarine/Marine 

Vertebrate 

2.39 

675.2 0.00354 

Estuarine/Marine 

Invertebrate 211.7 0.0113 

Saltwater plant (Vascular) 71 0.0337 

Taxa 

ECT

(Post-Permit 

Condition); 

(mg/kg wet 

wt) 

CTETA,T

(mg/kg wet 

wt) 

RQ 

(PostPermit) 

Freshwater Vertebrate 0.0507 4.84 0.0105 

Freshwater Invertebrate 0.148 5.28 0.028 

Freshwater plant (Vascular) - NA - 

Estuarine/Marine 

Vertebrate 0.27 1.98 0.136 

Estuarine/Marine 

Invertebrate - NA - 

Saltwater plant (Vascular) - NA - 

Taxa 

ECO

(Post-Permit 

Condition); 

(mg/kg bw/d) 

CTETO

(mg/kg bw/d) 

RQ 

(PostPermit) 

Mammals (Freshwater) 0.00406 0.20 0.0203 

Birds (Freshwater) 0.00507 0.50 0.0101 

Mammals (Saltwater) 0.0216 0.20 0.108 

Birds (Saltwater) 0.027 0.50 0.054 

5.3.2.8.2 Indirect Effects from Selenium 

The RQs summarized above and in Table 5-42 indicate “remote” risk to all freshwater 

aquatic and aquatic-dependent species, and “negligible” risk to saltwater animal species based 

primarily on direct effects of total selenium via the food web. Because risk is “remote” to listed 

aquatic species via direct waterborne toxicity and “negligible” from multiple routes of exposure 

(water and diet), a reduction in prey base (loss of prey) to upper trophic level organisms is not 

expected. The low risk from direct toxicity also indicates that total selenium will not affect 

vascular plants, thus indirect effects typically associated with the loss of aquatic and riparian 

vegetation, including loss of cover and changes in water quality parameters, are not expected to 

be significant for total selenium. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Risk Conclusion for each of Listed Species in RAAs - Selenium

Based on the exposure and direct and indirect effects assessment as outlined above, the 

following risk conclusions are being made for each of the listed species in the RAAs (see Table 

5-42). This information is used to inform decisions in the effects determinations made in Section 

7 of this document. 

Table 5-42. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Total Selenium 

Listed Species 

Taxonomic Group Risk Conclusion Presumptions 

Saltwater Corals Remote  Exposed via water column only 

 Risk quotient indicates very low potential for direct 

chronic effects 

 Fate of total selenium indicates very low potential for 

indirect effects (loss of prey and change in 

habitat/water quality parameters) 

 Surrogate CTET is representative and appropriate 

Unionid Mussels Remote Same as Saltwater Corals’ Presumptions 

Saltwater Bivalve Mollusk Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using 

acute toxicity data for Pacific oyster (Crassostrea 

gigas) with a SMAV of >10,000 μg/L (USEPA, 

1987) Dividing by the FACR of 8.314 results in a 

chronic value of 1,203 μg/L. Calculation results in 

pre- and post-permit RQs less than 0.002. 

Freshwater Shrimp/ Crustacean Remote Same as Saltwater Corals’ Presumptions 

Freshwater Fish/ Inland 

Salmonid 

Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for O. mykiss 

as presented in Table 5-40 above 

Anadromous Salmonid Negligible Same as Freshwater Inland Salmonids – no chronic 

toxicity data are available for salmonids tested in seawater 

Freshwater Fish/ Inland 

Sturgeon 

Remote Same as Saltwater Corals’ Presumptions 

Anadromous Sturgeon Negligible Same as Saltwater Corals’ Presumptions 

Estuarine/ Marine Fish Negligible  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for C. 

variegatus as presented in Table 5-40 above 

Beetle and Aquatic Insect Remote Same as Saltwater Corals’ Presumptions 

Amphibian Remote Same as Saltwater Corals’ Presumptions 

Snakes and Other Reptiles Remote Same as Saltwater Corals’ Presumptions 

Sea Turtles Remote Same as Saltwater Corals’ Presumptions 

Coastal/Marine Birds Remote Same as Saltwater Corals’ Presumptions 

Marine Mammal Negligible Same as Saltwater Corals’ Presumptions 

Terrestrial Mammal Remote Same as Saltwater Corals’ Presumptions 

Seagrass Remote Same as Saltwater Corals’ Presumptions 

Freshwater- Saltwater Aquatic 

and Wetland Plants 

Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for L. minor 

as presented in Table 5-40 above 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-116 

5.3.2.9 Zinc (Dissolved) 

Dissolved zinc is ubiquitous in vessel discharges, often at concentrations that may pose a 

risk based on screening level benchmarks (see Section 3.2.3.5). The highest concentrations of 

dissolved zinc were detected in the deck washdown, graywater, fish hold, and bilgewater 

discharges from most covered vessels, particularly utility vessels (e.g., towboats, supply boats). 

Zinc occurs naturally in the aquatic environment, typically as leachate from igneous 

rocks. Background concentrations in freshwater systems are estimated to range between 0.5 μg/L 

and 40 μg/L (Groth, 1971; Moore and Ramamoorthy, 1984; Eisler, 1993). Although most 

naturally introduced zinc is adsorbed to sediments, a small amount remains dissolved. 

Zinc interacts with many pollutants to produce altered patterns of accumulation, 

metabolism, and toxicity; some interactions reduce toxicity and others increase toxicity (Eisler, 

1993). Most of the zinc introduced into aquatic environments is eventually partitioned into 

sediments (Eisler, 1993). Zinc bioavailability from sediment is increased under conditions of 

high DO, low salinity, low pH, and high levels of inorganic oxides and humic substances. 

Zinc bioconcentrates but does not biomagnify in the aquatic food chain (USEPA, 1987b). 

The essentiality of zinc is unequivocal; zinc is present in every plant and animal tissue that was 

measured (Hogstrand, 2012). There can be literally thousands of zinc proteins in animals, the 

majority of which use zinc to create folds in the protein structure or to join different gene 

products together (Andreini et al., 2005; Passerini et al., 2007; Maret and Li, 2009). In addition 

to its structural and catalytic roles in proteins, there is also a growing appreciation for zinc as a 

signaling substance and role as a neuromodulator or transmitter substance (Laity and Andrews, 

2007; Hirano et al., 2008; Besser et al., 2009; Hogstrand et al., 2009; Sensi et al., 2009; 

Hershfinkel et al., 2010). 

Toxicity of zinc to aquatic organisms is dependent on water hardness, pH, DO, presence 

of mixtures, and trophic level (Sorensen 1991, Eisler 1993). Since zinc toxicity to freshwater 

aquatic animals has been shown to be related to water hardness, it is appropriate to normalize 

chronic toxicity effect thresholds for freshwater aquatic animals to a standard water hardness 

(i.e., 100 mg/L as CaCO3) for comparative purposes and to support risk calculation (USEPA, 

2005b). 

5.3.2.9.1 Direct Effects from Zinc 

Table 5-43 summarizes the chronic toxicity values available for calculating the risk 

quotients for aquatic and aquatic-dependent species exposed to dissolved zinc. Table 5-44 

presents the maximum exposure concentrations estimated in ambient receiving waters (ECW), in 

tissues of aquatic organisms exposed to those concentrations (ECT), and in oral doses of aquaticdependent animals ingesting food (prey) and water in those receiving waters (ECO). Maximum 

exposure concentrations in ambient receiving water are from the hypothetical harbor modeling 

(pre- and post-permit condition), as described above in Section 5.2.1. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-117 

Risk to Freshwater Aquatic Animal and Plant Species - Zinc

The overall risk to freshwater aquatic organisms as a result of maximum exposure in 

ambient waters from dissolved zinc discharged by permitted vessels is remote. All RQA,Ws are 

well below a value of 0.01, particularly for freshwater vascular plants (RQ < 0.0001). The 

highest RQ is 0.000395 estimated for freshwater invertebrates under the pre-permit condition. 

Control measures implemented as part of the issuance of the permits is anticipated to lower the 

risk to all freshwater species exposed to dissolved zinc from permitted vessel discharges by 

approximately 2 percent. 

Because zinc is a nutritionally essential inorganic element for all species, both plant and 

animal, zinc has the potential to accumulate in tissues of aquatic animals, as long as water 

column or dietary concentrations are not so high as to overwhelm homeostatic mechanisms, 

aquatic species are able to regulate their internal body burden of zinc (Hogstrand, 2012). Aquatic 

organism exposure to zinc concentrations in excess of nutritional needs via other potential routes 

of exposure in addition to direct waterborne toxicity (e.g. dietary toxicity) may pose a threat to 

listed species. While zinc does not bioaccumulate to high levels in aquatic animals, EPA believes 

it is prudent to incorporate an analysis on multiple routes of exposure in their analysis of this 

pollutant. The evaluation of potential risks from bioaccumulated zinc provides a means of 

identifying potential risks to listed species via exposure to criteria concentrations from all 

exposure routes combined. 

RQs were calculated for freshwater vertebrates and invertebrates based on estimated 

concentrations accumulated in tissues from continuous exposure to maximum concentrations of 

dissolved zinc in ambient receiving waters of 0.00968 and 0.00948 μg/L, pre- and post-permit 

conditions, respectively (see Table 5-44). Corresponding RQs were also all below 0.0001, 

indicating “remote” risk to freshwater aquatic animals from zinc accumulated in tissues. 

Risk to Saltwater (Estuarine/Marine) Aquatic Animal and Plant Species - Zinc

The overall risk to saltwater aquatic organisms as a result of maximum exposure in 

ambient waters from dissolved zinc discharged by permitted vessels is also remote. All RQA,Ws 

are 0.01 or less. Control measures implemented as part of the issuance of the permits is 

anticipated to lower the risk to all saltwater species exposed to dissolved zinc from permitted 

vessel discharges by approximately 8 percent. 

An RQ was calculated for saltwater invertebrates based on estimated concentrations 

accumulated in tissues from continuous exposure to maximum concentrations of dissolved zinc 

in ambient receiving waters of 0.493 and 0.452 μg/L, pre- and post-permit conditions, 

respectively (see Table 5-44). Corresponding RQs were at or below 0.001, again, indicating 

“remote” risk to aquatic animals (saltwater in this case) from zinc accumulated in tissues. 

Risk to Birds and Mammals - Zinc

An evaluation of risk to aquatic-dependent birds and mammals from exposure via 

consumption of prey items or drinking ambient surface water at the maximum concentrations 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-118 

predicted for dissolved zinc is required because of the ability of and need for organisms to 

accumulate zinc in tissues, albeit to low levels. The RQs for representative freshwater and 

saltwater mammals and birds based on the chronic toxicity values in relation to the oral effects 

concentrations calculated for this BE are all extremely low (<0.0001), except saltwater birds with 

post-permit RQ of 0.0011. These RQs indicate “remote” risk of zinc to aquatic-dependent birds 

and mammals. 

Table 5-43. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Dissolved Zinc 

Surrogate Aquatic 

Species Type 

Surrogate 

Species 

Exposure/ 

Effect 

Endpoint 

NOEC - 

LOEC 

(μg/L) 

CTETA,W

(μg/L) 

Study 

(source) 

ZINC - Dissolved 

(*normalized using EPA pooled slope of 0.8473 and using EPA dissolved conversion factor of 0.986 

freshwater and 0.946 estuarine/marine) 

Freshwater Vertebrate 

Flagfish, 

Jordanella 

floridae 

LC Test - 26 - 51 36.41 

(71.98 *) 

Spehar 1976 

(1987 ALC 

doc.) 

Freshwater Invertebrate Cladoceran, 

Daphnia magna LC Test - 42 - 52 46.73 (24.47 *) 

Chapman et 

al. 

Manuscript 

(1987 ALC 

doc.) 

Freshwater Plant 

(Vascular) 

Duckweed, 

Lemna minor 

Growth - 

EC50 - 10,000 

(9,860 *) 

Wang 1986 

(1987 ALC 

doc.) 

Estuarine/ Marine 

Vertebrate 

Cabezon, 

Scorpaenichthys 

marmoratus

Acute LC50 ÷ 

Estuarine 

ACR 

(ACR=2.997) 

191.4 ÷ 2.997 

63.86 

(60.41 *) 

(estimated) 

Dinnel et al. 

1983 (ACR) 

(1987 ALC 

doc.) 

Estuarine/ Marine 

Invertebrate 

Mysid, 

Americamysis 

bahia 

LC Test – 

Survival, 

reproduction 

120 - 231 166.5 

(157.5 *) 

Lussier et al. 

1985 

(1987 ALC 

doc.) 

Estuarine/ Marine Plant 

(Vascular) 

Giant kelp, 

Macrocystis 

pyrifera 

96-hr EC50 -

Photosynthetic 

rate 

- 10,000 

(9,460 *) 

Clendenning 

and North 

1959 (1987 

ALC doc.) 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-119 

Table 5-43. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Dissolved Zinc 

Surrogate Aquatic 

Species Type 

Surrogate 

Species 

Exposure 

Type 

Effect 

Endpoint 

CTETA,T

(mg/kg wet 

wt) 

Study 

(source) 

Freshwater Vertebrate 

Rainbow trout, 

Oncorhynchus 

mykiss 

Zinc 

deficiency 

Study 

Increased 

mortality, 

decreased 

growth

7.70 Spry et al. 

1988 

Freshwater Invertebrate Cladoceran, 

Daphnia magna 

Zinc 

Accumulation 

and 

Regulation 

Study 

Decreased 

reproduction, 

growth and 

energy 

17.40 

Muyssen and 

Janssen 

2002 

Estuarine/ Marine 

Vertebrate Not Available 

Estuarine/ Marine 

Invertebrate 

Amphipod, 

Allorchestes 

compressa 

4-wk Dietary 

Accmulation 

Study 

Reduction in 

growth 24.00 

Ahsanullah 

and Williams 

1991 

Surrogate AquuticDependent Species Type Surrogate 

Species 

Exposure 

Type 

Effect 

Endpoint 

CTETO

(mg/kg 

bw/d) 

Study 

(source) 

Mammals Rat 

Days 1 -16 of 

gestation, oral 

in diet 

Reproduction 160 

Sample et al. 

1996 (OR 

Toxics BE) 

Birds White leghorn 

chicken 

44-wk oral in 

diet Reproduction 14.5 

Sample et al. 

1996 (OR 

Toxics BE) 

Table 5-44. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative Surrogate Taxa to 

Dissolved Zinc 

Taxa 

ECW

(Pre-Permit 

Condition); 

(μg/L) 

ECW

(Post-Permit 

Condition); 

(μg/L) 

CTETA,W

(μg/L) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Freshwater Vertebrate 

0.00968 0.00948 

71.98 0.000134 0.000132 

Freshwater Invertebrate 24.47 0.000395 0.000387 

Freshwater plant (Vascular) 9,860 <0.0001 <0.0001 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Table 5-44. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative Surrogate Taxa to 

Dissolved Zinc 

Taxa 

ECW

(Pre-Permit 

Condition); 

(μg/L) 

ECW

(Post-Permit 

Condition); 

(μg/L) 

CTETA,W

(μg/L) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Estuarine/Marine Vertebrate 

0.493 0.452 

60.41 0.00817 0.00749 

Estuarine/Marine 

Invertebrate 157.5 0.00313 0.00287 

Saltwater plant (Vascular) 9,460 <0.0001 <0.0001 

Taxa 

ECT

(Pre-Permit 

Condition); 

(mg/kg wet wt) 

ECT

(Post-Permit 

Condition); 

(mg/kg wet wt) 

CTETA,T

(mg/kg wet wt) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Freshwater Vertebrate 

0.000455 0.000445 

7.70 <0.0001 <0.0001 

Freshwater Invertebrate 17.40 <0.0001 <0.0001 

Freshwater plant (Vascular) NA - - 

Estuarine/Marine Vertebrate 

0.0232 0.0213 

NA - - 

Estuarine/Marine 

Invertebrate 24.00 0.000966 0.000886 

Saltwater plant (Vascular) NA - - 

Taxa 

ECO

(Pre-Permit 

Condition); 

(mg/kg bw/d) 

ECO

(Post-Permit 

Condition); 

(mg/kg bw/d) 

CTETO

(mg/kg bw/d) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Mammals (Freshwater) 0.0000366 0.0000358 160 <0.0001 <0.0001 

Birds (Freshwater) 0.000346 0.000338 14.5 <0.0001 <0.0001 

Mammals (Saltwater) 0.00186 0.0017 160 <0.0001 <0.0001 

Birds (Saltwater) 0.0176 0.0161 14.5 0.00121 0.00111 

5.3.2.9.2 Indirect Effects from Zinc 

The RQs summarized above and in Table 5-45 indicate “remote” risk for direct effects of 

dissolved zinc to listed aquatic and aquatic-dependent species in this BE. Furthermore, discharge 

of dissolved zinc from covered vessels will not result in appreciable concentrations in estuaries 

and freshwater receiving water bodies. 

There is no basis for assuming indirect effects on listed species via dissolved zinc 

exposure and corresponding toxicity-related reduction in the prey base [loss of prey] available to 

upper trophic level organisms. Since the information summarized in Table 5-44 indicates that 

dissolved zinc at maximum exposure concentrations calculated from pre-, and especially after 

post-permit conditions (8 to 2 percent reduction, saltwater and freshwater receiving water, 

respectively), has little risk of directly affecting fresh- and saltwater aquatic animals and plants, 

indirect effects typically associated with exposure, including loss of cover and changes in water 

quality parameters, are also not expected for this metal. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-121 

Risk Conclusion for each of Listed Species in RAAs - Zinc

Based on the exposure and direct and indirect effects assessment as outlined above, the 

following risk conclusions are being made for each of the listed species in the RAAs (see Table 

5-45). This information is used to inform decisions in the effects determinations made in Section 

7 of this document. 

Table 5-45. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Zinc 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumptions 

Saltwater Corals Remote  Exposed via water column only 

 Risk quotient indicates very low potential for direct 

chronic effects 

 Fate of dissolved zinc indicates very low potential for 

indirect effects (loss of prey and change in habitat/water 

quality parameters) 

 Surrogate CTET is representative and appropriate 

Unionid Mussels Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using acute 

toxicity data for Asiatic clam (Corbiucla fluminea) with 

an LC50 of 6,040 μg/L (8,692 μg/L dissolved and 

normalized to 100 mg/L hardness) (Cherry et al., 1980; 

Rodgers et al., 1980). Dividing by the FACR of 2.208 

results in a chronic value of 3,936 μg/L. Calculation 

results in pre- and post-permit RQs of less than 0.0001. 

Saltwater Bivalve Mollusk Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a 23-d 

study of Pacific oyster (Crassostrea gigas) with an LC50 

of 75 μg/L (70.95 μg/L dissolved; Watling, 1983). 

Calculation results in pre- and post-permit RQs of 

0.0070 and 0.0064, respectively. 

Freshwater Shrimp/ Crustacean Remote Same as Saltwater Corals’ Presumptions 

Freshwater Fish/ Inland 

Salmonid 

Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using an 

ELS study of rainbow trout (Oncorhynchus mykiss) with 

an MATC of 371.1 μg/L (1,184 μg/L dissolved and 

normalized to 100 mg/L hardness) (Chapman, 1975). 

Calculation results in pre- and post-permit RQs of less 

than 0.0001. 

Anadromous Salmonid Remote Same as Freshwater Inland Salmonids – no chronic toxicity 

data are available for salmonids tested in seawater 

Freshwater Fish/ Inland 

Sturgeon 

Remote Same as Saltwater Corals’ Presumptions 

Anadromous Sturgeon Remote Same as Saltwater Corals’ Presumptions 

Estuarine/ Marine Fish Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for S. 

marmoratus as presented in Table 5.2-32 above 

Beetle and Aquatic Insect Remote Same as Saltwater Corals’ Presumptions 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-122 

Table 5-45. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Dissolved Zinc 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumptions 

Amphibian Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using a 7-d 

study of narrow-mouthed toad (Gastrophryne 

carolinensis) with an EC50 (death and deformity) of 10 

μg/L (5.599 μg/L dissolved and normalized to 100 mg/L 

hardness). Calculation results in pre- and post-permit 

RQs of 0.0017. 

Snakes and Other Reptiles Remote Same as Saltwater Corals’ Presumptions 

Sea Turtles Remote Same as Saltwater Corals’ Presumptions 

Coastal/Marine Birds Remote Same as Saltwater Corals’ Presumptions 

Marine Mammal Remote Same as Saltwater Corals’ Presumptions 

Terrestrial Mammal Remote Same as Saltwater Corals’ Presumptions 

Seagrass Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for M. pyrifera 

as presented in Table 5-43 above 

Freshwater- Saltwater Aquatic 

and Wetland Plants 

Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for L. minor as 

presented in Table 5-43 above 

 RQ directly applicable since estimated for M. pyrifera 

as presented in Table 5-43 above 

5.3.3 Nutrient and Nutrient-related Toxicity

 Nutrient pollution is one of the leading causes of water quality impairment in the nation, 

primarily because the quantity of nutrients reaching the nations waters has dramatically escalated 

over the past 50 years (USEPA, 2009a). Nutrient loadings in the form of nitrogen and 

phosphorus to waterbodies impact water quality by stimulating plant and algae growth which 

subsequently may result in depletion of dissolved oxygen, degradation of habitat, development of 

harmful algal blooms, impairment of the waterbody’s designated use, and impairment of 

drinking water sources. In cases where the waterbody is shown to be impaired, it is scientifically 

prudent to attempt to demonstrate the source–response relationship by first identifying the 

causative agent, whether it is nutrients or another factor such as hydrologic conditions, and then 

determining the limiting nutrient (WERF, 2010). In general, nitrogen is most often the limiting 

nutrient in estuarine waters, and phosphorus is more often limiting in freshwater systems. This 

means that the growth of phytoplankton is substantially controlled by the concentration and 

availability of phosphorus in freshwater systems. Increased phosphorus concentrations can lead 

to changes in composition of flora and fauna present, increased eutrophication of a water body, 

rates of ecosystem functioning, nutrient uptake, recycling rates of the ecosystem, and 

decomposition rates (WERF, 2010). Determining risk to aquatic life from excess nutrients (e.g., 

eutrophication) is complicated because nitrogen and phosphorus are essential for primary 

production in aquatic ecosystems, and over-enrichment problems involve multiple interrelated 

variables. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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The most visible symptom of eutrophication is the excessive algal growth that reduces 

water clarity. Eutrophication can also significantly affect phytoplankton community structure 

resulting in a greater abundance of less desirable taxa such as blue-green algae. These changes in 

the phytoplankton community can have cascading effects on higher trophic levels and the 

eventual transfer of organic carbon from the primary producers to less desired species – for 

example, the replacement of seagrasses with less desirable vegetation types (WERF, 2010). 

5.3.3.1 Total Phosphorus 

Total phosphorus is detected in bilgewater, deck washdown, and graywater discharges 

from covered vessels at concentrations that likely causes risk based on screening level 

benchmarks (see Section 3.2.3.2). Excessive increases in phosphorus can lead to a decreased 

photic zone and increase of turbidity, local extinction of intolerant or specialized aquatic flora, 

high pH, and a decrease in dissolved oxygen (WERF, 2010). These changes in turn can cause 

loss of habitat and other impacts to aquatic and aquatic-dependent species, including listed 

species which use or would otherwise use these eutrophic waters. Generally, there would be 

little, if any, impact to listed species from total phosphorus in brackish estuaries and coastal 

waters where nitrogen is usually the limiting factor. 

Under natural conditions, freshwater ecosystems generally have low phosphorous 

concentrations (< 100 μg/L), but each waterbody is different, and there are numerous factors 

which impact how any particular waterbody will respond to excess nutrient loading, including 

hydraulic residence time, freshwater inflow, clarity and light attenuation, geologic substrate, 

depth, temperature, and degree of physical alterations, such as channelizing. Additionally, 

excessive phosphorus and the resulting problems associated with nutrient enrichment in general 

are frequently widespread and manifested at a location remote from the sources, and may not 

show themselves for some time after significant inputs to the system have occurred (WERF, 

2010). 

Because of the above, EPA is using the lowest statewide and/or site-specific water quality 

criteria for total phosphorus (10 μg/L) as the basis for CTETA,W in the analysis. 

5.3.3.1.1 Direct Effects from Total Phosphorus 

Table 5-46 summarizes the statewide and site-specific water quality criteria values 

available for calculating the risk quotients for aquatic and aquatic-dependent species exposed to 

total phosphorus. Table 5-47 presents the maximum before (expected or pre-permit condition) 

and after (anticipated or post-permit condition) exposure concentrations estimated in ambient 

receiving waters from the hypothetical harbor modeling, as well as the RQs calculated for each 

taxonomic group potentially exposed to total phosphorus in relation to the lowest water quality 

criterion for this nutrient (i.e., 10 μg/L – see Table 5-46). 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Risk to the Freshwater Environment Inclusive of Aquatic Animal and Plant Species - Total 

Phosphorus 

The risk to the freshwater environment and its aquatic organisms from maximum 

exposure to total phosphorus from permitted vessels is “remote”. The RQ estimated under the 

pre-permit exposure condition is 0.00453, but when the control measures are implemented and 

enforced as part of the issuance of the permits, the RQ is anticipated to be substantially reduced 

to only 0.000594. Control measures implemented as part of the issuance of the permits are 

anticipated to lower the risk to all freshwater species exposed to total phosphorus from permitted 

vessel discharges by approximately 87 percent. 

Risk to the Saltwater Environment Inclusive of Aquatic Animal and Plant Species - Total 

Phosphorus 

The risk to the saltwater environment and its aquatic organisms from maximum exposure 

to total phosphorus from permitted vessels is also dependent on pre- and post-permit exposure 

concentrations. The RQ estimated under the pre-permit condition is 1.19, but when the control 

measures are implemented and enforced as part of the issuance of the permits, the RQ is 

anticipated to be dramatically reduced to only 0.0543. Control measures implemented as part of 

the issuance of the permits are anticipated to lower the risk to all saltwater species exposed to 

total phosphorus from permitted vessel discharges by approximately 95 percent, reducing the 

risk to listed saltwater organisms from “potentially significant” to “remote”. Irrespective of the 

phosphorus loading reduction itself, the “remote” risk conclusion is especially true in most 

saltwater environments since nitrogen, not phosphorus, is often the limiting nutrient in 

coastal/estuarine waters (WERF, 2010), making it far less likely for phosphorus to be a stressor 

in these environments. 

Risk to Birds and Mammals - Total Phosphorus 

The risk of exposure to aquatic-dependent birds and mammals from total phosphorus 

from permitted vessel discharge is via drinking of surface water alone because total phosphorus 

does not bioaccumulate in the tissues of prey organisms. There is no NOAEL for phosphorus via 

oral exposure of wildlife via drinking water, although the maximum “safe” level for phosphate in 

drinking water for human consumption from the World Health Organization is 5 mg/L.. A RQ 

based on the WHO phosphate drinking water standard would indicate a “remote” risk to aquaticdependent birds and mammals. 

Table 5-46. Summary of Statewide and Site-specific (waterbody) 

Approved Water Quality Standards for Total Phosphorus across the 

United States 

State Types 

Statewide 

Criteria 

(μg/L) 

Site-Specific 

Criteria 

(μg/L) 

AZ Rivers/Streams - 50-1,000 

CA Rivers/Streams - 5-250 

FL Rivers/Streams 60-490 - 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Table 5-46. Summary of Statewide and Site-specific (waterbody) 

Approved Water Quality Standards for Total Phosphorus across the 

United States 

State Types 

Statewide 

Criteria 

(μg/L) 

Site-Specific 

Criteria 

(μg/L) 

HI Rivers/Streams 30-50 - 

IL Rivers/Streams - 50 

MT Rivers/Streams - 20-39 

NJ Rivers/Streams 100 - 

NM Rivers/Streams - 100 

NV Rivers/Streams - 100-330 

OK Rivers/Streams - 37 

RI Rivers/Streams - 25 

TN Rivers/Streams - 10-250 

UT Rivers/Streams 50 

VT Rivers/Streams - 10 

WI Rivers/Streams 75-100 - 

CA Estuaries - 25-50 

DE Estuaries - 10 

HI Estuaries 250 60 

Source: U.S. survey conducted in April 2011 by GLEC for Jack Oliver, US EPA, HECD. 

Table 5-47. Risk Quotients based on Division of Pre- and Post-permit 

Exposure Concentrations by Lowest Water Quality Criteria for Total 

Phosphorus 

Taxa 

ECW

(Pre-Permit 

Condition); 

(μg/L) 

ECW

(Post-Permit 

Condition); 

(μg/L) 

CTETA,W

(μg/L) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Freshwater 

Environment 0.0453 0.00594 10 0.00453 0.000594 

Estuarine/ Marine 

Environment 11.9 0.543 10 1.19 0.0543 

5.3.3.1.2 Indirect Effects from Total Phosphorus 

The RQs summarized above indicate a large reduction in risk to listed species in this BE 

via the issuance of the VGP and sVGP. Furthermore, the information summarized in Table 5-47 

indicates that the maximum concentration modeled under post-permit conditions for total 

phosphorus in ambient receiving waters [fresh in particular] is of “remote” risk of causing direct 

effects on the plant and animal communities there, and thus, indirect effects typically associated 

with the loss of aquatic and riparian vegetation, including loss of cover and changes in water 

quality parameters, are no longer expected – because the water quality criterion used as CTET to 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-126 

calculate RQ in this analysis already considers and is based on protection of listed species from 

such indirect effects. 

Risk Conclusion for each of Listed Species in RAAs - Total Phosphorus

Based on the exposure and direct and indirect effects assessment as outlined above, EPA 

concludes there is a “remote” risk of impact from total phosphorus to all listed species in the 

RAAs (Table 5-48). This information is used to inform decisions in the effects determinations 

made in Section 7 of this document. 

Table 5-48. Summary of Risk Conclusions for Listed Species and Critical Habitats in RAAs 

to Total Phosphorus 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumptions 

Saltwater Corals Remote  Phosphorus is only limiting in freshwater ecosystems 

 Risk quotients inclusive of direct and indirect chronic 

effects to entire plant and animal community 

Unionid Mussels Remote Same as Saltwater Corals’ Presumptions 

Saltwater Bivalve Mollusk Remote Same as Saltwater Corals’ Presumptions 

Freshwater Shrimp/ Crustacean Remote Same as Saltwater Corals’ Presumptions 

Freshwater Fish/ Inland 

Salmonid 

Remote Same as Saltwater Corals’ Presumptions

Anadromous Salmonid Remote Same as Saltwater Corals’ Presumptions 

Freshwater Fish/ Inland 

Sturgeon 

Remote Same as Saltwater Corals’ Presumptions 

Anadromous Sturgeon Remote Same as Saltwater Corals’ Presumptions 

Estuarine/ Marine Fish Remote Same as Saltwater Corals’ Presumptions 

Beetle and Aquatic Insect Remote Same as Saltwater Corals’ Presumptions 

Amphibian Remote Same as Saltwater Corals’ Presumptions 

Snakes and Other Reptiles Remote Same as Saltwater Corals’ Presumptions 

Sea Turtles Remote Same as Saltwater Corals’ Presumptions 

Coastal/Marine Birds Remote Same as Saltwater Corals’ Presumptions 

Marine Mammal Remote Same as Saltwater Corals’ Presumptions 

Terrestrial Mammal Remote Same as Saltwater Corals’ Presumptions 

Seagrass Remote Same as Saltwater Corals’ Presumptions 

Freshwater- Saltwater Aquatic 

and Wetland Plants 

Remote Same as Saltwater Corals’ Presumptions 

5.3.3.2 Total Ammonia Nitrogen 

Ammonia (expressed as total ammonia nitrogen) is a constituent commonly found in 

bilgewater, deck washdown, fish hold and fish hold cleaning effluent, and graywater at 

concentrations that may potentially pose risk based on screening level benchmarks 

(Section 3.2.3.2). Ammonia is found throughout the environment in the air, soil, and water, 

where is excreted by animals, including humans. Ammonia occurs naturally and is also produced 

by human activity. Ammonia is rapidly taken up by plants, bacteria, and animals where it is an 

important source of nitrogen. Because of this, ammonia does not build up in the food chain, but 

does serve as a nutrient for plants and bacteria (USEPA, 2009b). 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-127 

The pollutant form of ammonia in water consists of two species, a larger component 

which is the ammonium ion (NH4

+

), and a smaller component which is the non-dissociated or 

un-ionized ammonia (NH3) molecule. The sum of the two forms is usually expressed as total 

ammonia-nitrogen. The ratio of un-ionized ammonia to ammonium ion, dependent upon both pH 

and temperature, generally increases by 10-fold for each rise of a single pH unit and by 

approximately 2-fold for each 10°C rise in temperature over the 0-30°C range (Erickson, 1985). 

Toxicity of ammonia to aquatic life was initially thought to arise largely from the small 

uncharged NH3 molecule (Wuhrmann and Woker, 1948, Downing and Merkens, 1955), but the 

ammonium ion has since proved toxic as well, particularly at low pH (Armstrong et al., 1978; 

Tomasso et al., 1980); thus, toxicity of ammonia is best expressed as a function of pH and/or 

temperature and on the basis of total ammonia nitrogen (USEPA, 2009b). 

For this purpose of comparison and risk calculation in this BE, CTETA,Ws for freshwater 

aquatic organisms are expressed on the basis of total ammonia nitrogen at pH 8.0 (freshwater 

vertebrates), or, pH 8 and 25o

C (freshwater invertebrates) where a functional relationship 

between toxicity and pH and/or temperature has been demonstrated (USEPA, 2009b). 

Conversely, CTETA,Ws for saltwater aquatic vertebrates and invertebrates are expressed simply 

as total ammonia nitrogen. 

5.3.3.2.1 Direct Effects from Total Ammonia Nitrogen 

Table 5-49 summarizes the chronic toxicity data available for calculating RQA,W for 

aquatic listed species exposed to predicted concentrations of total ammonia in water receiving 

permitted discharges from covered vessels. Table 5-50 presents the maximum before (expected 

or pre-permit condition) and after (anticipated or post-permit condition) exposure concentrations 

estimated in these waters from the hypothetical harbor modeling, as well as the corresponding 

RQA,Ws calculated for each taxonomic group based on the various chronic toxicity threshold 

values (in this case, CTETA,W) readily available for representative surrogate taxa. 

Risk to Freshwater Aquatic Animal and Plant Species - Total Ammonia Nitrogen

The overall risk to freshwater aquatic organisms from maximum exposure to total 

ammonia from permitted vessels is remote. All RQA,Ws are below a value of 0.001, particularly 

for freshwater vertebrates and vascular plants (estimated using EPA’s CCC). The highest RQ is 

0.00484 estimated for freshwater invertebrates under the pre-permit condition. Control measures 

implemented as part of the issuance of the permits is anticipated to lower the risk to all 

freshwater species exposed to total ammonia from permitted vessel discharges by approximately 

11 percent. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-128 

Risk to Saltwater (Estuarine/Marine) Aquatic Animal and Plant Species - Total Ammonia 

Nitrogen

The risk to saltwater aquatic organisms from maximum exposure to total ammonia from 

permitted vessels is also remote. The RQs for saltwater vertebrate and invertebrate species are 

below a RQA,W of 0.005. No appropriate data are available for saltwater vascular plants exposed 

to total ammonia, although saltwater plants are likely not any more sensitive to total ammonia 

than saltwater animals. Control measures implemented as part of the issuance of the permits is 

anticipated to lower the risk to all saltwater species exposed to total ammonia from permitted 

vessel discharges by approximately 22 percent. 

Risk to Birds and Mammals - Total Ammonia Nitrogen

The risk of exposure to aquatic-dependent birds and mammals from total ammonia from 

permitted vessel discharge is via drinking of [fresh] surface water alone because total ammonia 

does not bioaccumulate in the tissues of prey [food] organisms. Furthermore, as noted above, 

total ammonia has a short half-life in water, and therefore, does not remain readily available to 

the organism for uptake. 

There is no NOAEL for ammonia via oral exposure of wildlife via drinking water; 

therefore, EPA assumes zero risk to wildlife via oral ingestion. 

Table 5-49. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Total Ammonia Nitrogen 

Surrogate Aquatic 

Species Type 

Surrogate 

Species 

Exposure/ 

Effect 

Endpoint 

NOEC - 

LOEC 

(mg N/L) 

CTETA,W 

(mg N/L) Study (source) 

Freshwater Vertebrate 

Bluegill Sunfish, 

Lepomis 

macrochirus 

ELS Test - 

Biomass - 1.349 

(EC20) 

Smith et al. 1984 

(2009 Draft 

Update ALC doc.) 

Freshwater Invertebrate 

Fatmucket, 

Lampsilis 

siliquoidea 

28-day 

Juvenile Test - 

Survival 

- 0.3027 

(IC20) 

Wang et al. 2007 

(2009 Draft 

Update ALC doc.) 

Freshwater Plant 

(Vascular) - 1.2 

CCC from ALC 

Update document 

(USEPA, 1999) 

Estuarine/ Marine 

Vertebrate 

Inland silverside, 

Menidia beryllina 

ELS Test - 

Growth 2.1 – 4.2 2.970 

(2.446) 

Miller et al. 1990 

(2004 GLEC 

Update File) 

Estuarine/ Marine 

Invertebrate 

Greenlip abalone, 

Haliotis laevigata 

95-day Test – 

Growth 1.46-2.65 1.97 Harris et al. 1998 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-129 

Table 5-49. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to Total Ammonia Nitrogen 

Surrogate Aquatic 

Species Type 

Surrogate 

Species 

Exposure/ 

Effect 

Endpoint 

NOEC - 

LOEC 

(mg N/L) 

CTETA,W 

(mg N/L) Study (source) 

Estuarine/ Marine Plant 

(Vascular) - - 

Surrogate AquaticDependent Species 

Type 

Surrogate 

Species 

Exposure 

Type Effect 

CTETO 

(mg/kg 

bw/d) 

Study (source) 

Mammals Rodents - 

Birds Not Available - - - - 

Table 5-50. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative 

Surrogate Taxa to Total Ammonia Nitrogen 

Taxa 

ECW

(Pre-Permit 

Condition) 

(mg/L) 

ECW

(PostPermit 

Condition) 

(mg N/L) 

CTETA,W 

(mg N/L) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Freshwater Vertebrate 

0.000032 0.0000285 

1.349 <0.0001 <0.0001 

Freshwater Invertebrate 0.3027 0.000106 <0.0001 

Freshwater plant (Vascular) 1.2 <0.0001 <0.0001 

Estuarine/Marine Vertebrate 

0.00954 0.00742 

2.446 0.0039 0.00303 

Estuarine/Marine Invertebrate 1.97 0.00484 0.00377 

Saltwater plant (Vascular) - - - 

Taxa 

ECO

(Pre-Permit 

Condition) 

(mg/kg bw/d) 

ECO

(PostPermit 

Condition) 

(mg/kg 

bw/d) 

CTETO 

(mg/kg 

bw/d) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Mammals NAa

 NAa - - - 

Birds - - - 

a) Not applicable because ammonia does not accumulate in tissue, and therefore, a risk quotient cannot be 

calculated as in Equation 5-5. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-130 

5.3.3.2.2 Indirect Effects from Total Ammonia Nitrogen 

The RQs summarized above indicate “remote” risk of direct effects of total ammonia to 

the aquatic and aquatic-dependent listed species in this BE. Furthermore, total ammonia 

discharges from covered vessels does not result in measureable concentrations in estuaries and 

freshwater receiving water bodies due to its non-persistence and short half-life. 

Due to its low persistence, interactions between the sediments and the water column and 

potential effects on benthos are not expected with this pollutant. There is also no basis for 

assuming indirect effects on listed species via total ammonia exposure and corresponding 

toxicity-related reduction in the prey base [loss of prey] available to upper trophic level 

organisms. The information summarized in Table 5-50 indicates that total ammonia at maximum 

exposure concentrations calculated from pre-, and especially after post-permit conditions, has no 

risk of causing direct effects on vascular freshwater plants, thus indirect effects typically 

associated with the loss of aquatic and riparian vegetation, including loss of cover and changes in 

water quality parameters, are also not expected for this pollutant. 

Risk Conclusion for Aquatic and Aquatic-Dependent Listed Species and Their Critical Habitats 

in RAAs - Total Ammonia Nitrogen

Based on the consideration of potential direct and indirect effects as outlined above, the 

following risk conclusions are being made for each of the listed species in the RAAs. This 

information is used to inform decisions in the effects determinations made in Section 7 of this 

document. 

Table 5-51. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Total Ammonia Nitrogen 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumptions 

Saltwater Corals Remote  Exposed via water column only 

 Risk quotient indicates very low potential for direct 

chronic effects 

 Fate of total ammonia indicates very low potential for 

indirect effects (loss of prey and change in habitat/water 

quality parameters) –at the concentrations predicted 

 Surrogate CTET is representative and appropriate 

Unionid Mussels Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for L. siliquoidea

as presented in Table 5-49 above 

Saltwater Bivalve Mollusk Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for H. laevigata

as presented in Table 5-49 above 

Freshwater Shrimp/ Crustacean Remote Same as Saltwater Corals’ Presumptions 

Freshwater Fish/ Inland 

Salmonid 

Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using 

chronic toxicity data from a 62-d test on the hatchability 

of embryonic sockeye salmon (Oncorhynchus nerka) 

(Rankin, 1979) with a chronic value of <4.160 mg N/L at 

pH 8. Calculation results in pre- and post-permit RQs of 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-131 

Table 5-51. Summary of Risk Conclusions for Listed Species and Critical Habitats in 

RAAs to Total Ammonia Nitrogen 

Listed Species 

Taxonomic Group 

Risk 

Conclusion Presumptions 

less than 0.0001. 

Anadromous Salmonid Remote Same as Freshwater Inland Salmonids – no chronic toxicity 

data are available for salmonids tested in seawater 

Freshwater Fish/ Inland 

Sturgeon 

Remote  Same as Saltwater Corals’ Presumptions 

 Risk conclusion is confirmed via estimation using acute 

toxicity data for shortnosed sturgeon (Acipenser 

brevirostrum) with an LC50 of 36.49 mg N/L at pH 8 

(Fontenot et al. 1998). Dividing by the FACR of 6.8 

(USEPA, 2009b) results in a chronic value of 5.37 mg 

N/L at pH 8. Calculation results in pre- and post-permit 

RQs of less than 0.002. 

Anadromous Sturgeon Remote Same as Saltwater Corals’ Presumptions 

Estuarine/ Marine Fish Remote  Same as Saltwater Corals’ Presumptions 

 RQ directly applicable since estimated for M. beryllina

as presented in Table 5-49 above 

Beetle and Aquatic Insect Remote Same as Saltwater Corals’ Presumptions 

Amphibian Remote Same as Saltwater Corals’ Presumptions 

Snakes and Other Reptiles Remote Same as Saltwater Corals’ Presumptions 

Sea Turtles Remote Same as Saltwater Corals’ Presumptions 

Coastal/Marine Birds Remote Same as Saltwater Corals’ Presumptions 

Marine Mammal Remote Same as Saltwater Corals’ Presumptions 

Terrestrial Mammal Remote Same as Saltwater Corals’ Presumptions 

Seagrass Remote Same as Saltwater Corals’ Presumptions 

Freshwater- Saltwater Aquatic 

and Wetland Plants 

Remote Same as Saltwater Corals’ Presumptions 

5.3.4 VOCs and SVOCs

A number of volatile organic compounds (VOCs) and semi-volatile organic compounds 

(SVOCs), including monocyclic aromatic hydrocarbons (MAHs) and polyaromatic hydrocarbons 

(PAHs), were identified in Section 3.2.3.6 as pollutants for detailed evaluation in this BE. Many 

of these pollutants were identified because their levels measured in select discharges (e.g., those 

associated with fuel and fuel combustion) exceeded screening level benchmarks. Several VOCs 

and SVOCs identified for detailed evaluation were included for consideration because their 

concentrations in vessel discharges exceeded screening level benchmarks for the protection of 

human health via consumption of fish and drinking water. EPA’s human health criteria are riskbased criteria designed to protect human health by preventing a one in a million chance of 

causing cancer from the oral ingestion of the pollutant. For many of the VOCs and SVOCs, there 

are no definitive chronic toxicity test data available for aquatic organisms, as well as no data to 

support selection of a wildlife CTET (or CTETO) based on growth or reproduction. Therefore, in 

this analysis, only the following VOCs and SVOCs are subjected to a quantitative effects 

analysis based on the availability of appropriate chronic toxicity data from which risk can be 

calculated as described in this BE: 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-132 

 Benzo(a)anthracene 

 Benzo(a)pyrene 

 Benzo(b)fluoranthene 

 Benzo(k)fluoranthene 

 Chrysene 

 Ideno(1,2,3-cd)pyrene 

 Benzene 

 Bis(2-ethylhexyl) phthalate 

 2,4,6-Trichlorphenol 

EPA identified chronic toxicity data for five polycyclic aromatic hydrocarbons (PAHs) 

with four or more carbon rings: benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, 

benzo(k)fluoranthene, chrysene, and ideno(1,2,3-cd)pyrene. For all other PAHs, EPA used 

chronic toxicity data for benzo(a)pyene to calculate RQs from multiple routes of exposure to 

aquatic organisms and for oral ingestion by aquatic-dependent wildlife. EPA selected 

benzo(a)pyene because it is one of the most toxic PAHs and because the appropriate data exist to 

support risk calculations. 

5.3.4.1 MAHs and PAHs 

The toxicity of oil and grease measured as SGT-HEM to aquatic and aquatic-dependent 

animals is most often attributed to the water-soluble monocyclic aromatic hydrocarbons or 

MAHs (benzene, toluene, ethylbenzene, and xylene, otherwise known as BTEX), and the 

polycyclic aromatic hydrocarbons or PAHs (McGrath and DiToro, 2009). The MAH compounds 

like benzene are low-molecular-weight compounds that usually do not persist in the environment 

because they are volatile and highly biodegradable. Conversely, the PAH compounds 

(particularly those with four or more carbon rings) are high-molecular-weight compounds that 

are less volatile and degrade more slowly, and thus, persist in the aquatic environment. Because 

MAHs and PAHs are Type I narcotic compounds, the toxicity of these compounds in water (and 

sediments) is most easily assessed using what is called the target lipid model or TLM (DiToro 

and McGrath, 2000). The TLM has been successfully used to predict the acute and chronic 

toxicity of MAHs and PAHs to aquatic animals as single pollutants and as mixtures by allowing 

for the calculation of a critical body burden in the target lipid of an organism. Here, EPA used 

the the critical body burden of benzo(a)pyene and benzene in lipid to develop CTET in support 

of the risk analysis below. 

5.3.4.1.1 Direct Effects from MAHs and PAHs 

Table 5-52 summarizes what is referred to as “predicted chronic five percent hazard 

concentrations” (or HC5, used here as CTETA,W) from McGrath and DiToro (2009) for 

calculating RQA,W for listed species exposed to predicted concentrations of the MAH pollutant 

benzene and several “heavy molecular weight” PAHs in water receiving permitted discharges 

from covered vessels. Table 5-53 presents the maximum before (expected or pre-permit 

condition) and after (anticipated or post-permit condition) exposure concentrations estimated in 

these waters from the hypothetical harbor modeling. Table 5-53 also presents the corresponding 

RQs calculated for all aquatic and aquatic-dependent organisms based on the HC5 derived from 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-133 

the TLM, which is proved to be a benchmark that closely approximates the level of protection 

necessary to prevent adverse chronic effects on survival, growth and reproduction to aquatic 

animals and the aquatic-dependent animals that may consume them (invertebrates and 

vertebrates, fresh- and saltwater). The basis for the various RQs calculated to support this 

analysis is provided in Appendices H and I. 

Risk to Freshwater and Saltwater Aquatic Organisms - MAHs and PAHs

The overall risk to freshwater aquatic organisms from maximum exposure to the various 

PAHs and benzene in receiving water from permitted vessels is remote. All RQA,Ws are either 

below or well below a value of 0.02. The highest RQ is approximately 0.0218 estimated for 

saltwater organisms potentially exposed to benzo(a)pyrene (the most toxic PAH) under the postpermit condition (because there is no anticipated reduction in PAHs via the issuance of the 

permits). No risk from direct toxicity is expected to aquatic organisms from exposure to benzene 

under any exposure condition. 

PAHs (and to a lesser extent, MAHs) accumulate in tissues of aquatic organisms as well 

as biomagnify up the food chain. Unlike the situation with metals and metalloids, the partitioning 

and subsequent bioaccumulation of PAHs occurs in the lipid fraction of these organisms. The 

TLM accounts for this partitioning and predicts a critical body burden in the lipid of aquatic 

organisms. When paired with an appropriate “expected” tissue concentration predicted from the 

product of the maximum concentration of the PAH (or MAH) in receiving water and freelydissolved BAF for animals in the trophic level of interest, the critical body burden in the lipid of 

the organism serves as the basis for calculating RQA,M in this BE (see Equation 5-3 in Section 

5.2.3.2 and corresponding values included in Appendix H). While PAHs do not bioaccumulate to 

particularly high levels in aquatic animals in the field due to biotransformation and 

detoxification, EPA believes it is still prudent to incorporate an analysis on multiple routes of 

exposure in the BE. 

The evaluation of potential risks from bioaccumulated PAHs and MAHs in this BE are 

limited to just benzo(a)pyrene and benzene because: 1) benzo(a)pyrene is the most toxic of the 

PAHs being considered here, and thus, the most relevant for evaluating risk, and 2) benzene is 

the only MAH for which a critical lipid body burden exists to support risk evaluation from 

multiple routes of exposure (as well as exposure via oral ingestion by wildlife). 

RQs were calculated for freshwater vertebrates and invertebrates based on estimated 

concentrations accumulated in tissues from continuous exposure to maximum concentrations of 

benzo(a)pyrene and benzene in ambient receiving waters under post-permit (benzo(a)pyerene) 

and pre- and post-permit conditions (benzene), respectively (see Table 5-54). Corresponding 

RQs for both pollutants were all below 0.01, indicating “remote” risk to fresh- and saltwater 

aquatic animals from benzo(a)pyrene (PAHs) and benzene (representative MAH) accumulated in 

tissues. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-134 

Risk to Birds and Mammals - MAHs and PAHs

An evaluation of risk to aquatic-dependent birds and mammals from exposure via 

consumption of prey items or drinking ambient surface water at the maximum concentrations 

predicted for benzo(a)pyrene and benzene is required because of the propensity of aquatic 

organisms to accumulate these pollutants in tissues. The oral exposure concentration (ECO) for 

aquatic-dependent wildlife represents the pollutant concentration (in mg/kg body weight per day) 

ingested from consumption of prey and drinking water (fresh only) in surface water at maximum 

concentrations of benzo(a)pyrene and benzene. The CTETO for a representative wildlife species 

is then compared to this value to estimate risk. The RQs estimated for surrogate mammals based 

on the quotient of ECO and CTETO for benzo(a)pyrene and benzene are below 0.02 and ≤0.0001, 

respectively. These RQs indicate “remote” risk of MAHs and PAHs to aquatic-dependent 

mammals. EPA did not quantitatively evaluate risk to birds because of the lack of toxicity data; 

however, based on the very low RQ for mammals, the risk to birds is not expected to be 

significant. 

Table 5-52. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to MAHs and PAHs 

Surrogate Aquatic Species 

Type Pollutant Exposure Type Effect CTETA,Wa (μg/L) Study (source) 

Aquatic animals Benzo(a)pyrene Water 

column 

Long-term 

survival, 

growth and 

reproduction 

0.281 McGrath and 

DiToro 2009 

Aquatic animals Benzo(k)fluorant

hene 

Water 

column 

Same as 

above 0.286 Same as for 

Benzo(a)pyrene 

Aquatic animals Benzo(b)fluorant

hene 

Water 

column 

Same as 

above 0.325 Same as for Benzo(a)pyrene

Aquatic animals Ideno(1,2,3-

cd)pyrene 

Water 

column 

Same as 

above 0.530 Same as for Benzo(a)pyrene 

Aquatic animals Chrysene Water 

column 

Same as 

above 0.99 Same as for Benzo(a)pyrene 

Aquatic animals Benzo(a)anthrac

ene 

Water 

column 

Same as 

above 1.08 Same as for 

Benzo(a)pyrene 

Aquatic animals Benzene Water 

column 

Same as 

above 2,413 Same as for Benzo(a)pyrene 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-135 

Table 5-52. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to MAHs and PAHs 

Surrogate Aquatic Species 

Type Pollutant Exposure Type Effect 

CTETT 

(mg/kg 

wet wt) 

Study (source) 

Vertebrate (Pink salmon – 

Oncorhynchus gorbuscha) Benzo(a)pyrene Critical lipid body burden 

Acute 

converted to 

chronic 

using ACR 

of 3.83 

71.74 

Calculated this 

BE based on data 

from McGrath 

and DiToro 2009 

– See Appendix I 

Invertebrate (Amphipod – 

Rhepoxyinus abronius) Benzo(a)pyrene Same as 

above 

Same as 

above 18.27 Same as for 

Benzo(a)pyrene 

Vertebrate (Pink salmon – 

Oncorhynchus gorbuscha) Benzene Same as above 

Same as 

above 38.68 Same as for Benzo(a)pyrene 

Invertebrate (Amphipod – 

Rhepoxyinus abronius) Benzene Same as above 

Same as 

above 9.898 Same as for Benzo(a)pyrene 

Surrogate AquaticDependent Species Type 

Pollutant and 

Surrogate 

Species 

Exposure 

Type Effect 

CTETO 

(mg/kg 

bw/d) 

Study (source) 

Mammals Benzo(a)pyrene - 

Mouse 

Oral 

intubation 

during days 

7 16 f

Reproductio

n 

1.0 

Sample et al. 

1996 (OR Toxics 

BE) 

Birds Not Available - - - - 

Mammals Benzene - Mouse 

Oral gavage 

during days 

6-12 of 

Reproductio

n 

26.36 

Sample et al. 

1996 (OR Toxics 

BE) 

Birds Not Available - - - - 

a) Represented here as an HC5, see text. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-136 

Table 5-53. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative 

Surrogate Taxa to MAHs and PAHs 

Pollutant (Aquatic 

Environment) 

ECW

(PrePermit 

Condition) 

(μg/L) 

ECW

(Post-Permit 

Condition) 

(μg/L) 

CTETA,W 

(μg/L) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Benzo(a)pyrene - FW NA 0.000536 0.281 - 0.00191 

Benzo(a)pyrene - SW NA 0.00614 0.281 - 0.0218 

Benzo(k)fluoranthene - FW NA 0.000252 0.286 - 0.000882 

Benzo(k)fluoranthene - SW NA 0.00538 0.286 - 0.0188 

Benzo(b)fluoranthene - FW NA 0.000228 0.325 - 0.000701 

Benzo(b)fluoranthene - SW NA 0.00486 0.325 - 0.0149 

Ideno(1,2,3-cd)pyrene - FW NA 0.000203 0.530 - 0.000384 

Ideno(1,2,3-cd)pyrene - SW NA 0.00434 0.530 - 0.00818 

Chrysene - FW NA 0.00102 0.99 - 0.00103 

Chrysene - SW NA 0.00943 0.99 - 0.00952 

Benzo(a)anthracene - FW NA 0.0008 1.08 - 0.00074 

Benzo(a)anthracene - SW NA 0.00685 1.08 - 0.00635 

Benzene – FW 0.00117 0.0011 2,413 <0.0001 <0.0001 

Benzene - SW 0.0311 0.0258 2,413 <0.0001 <0.0001 

Pollutant and Taxa 

ECT

(PrePermit 

Condition) 

(mg/kg wet 

wt) 

ECT

(Post-Permit 

Condition) 

(mg/kg wet 

wt) 

CTETT 

(mg/kg 

wet wt) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Benzo(a)pyrene – FW 

Vertebrates NA 0.00699 71.74 - <0.0001 

Benzo(a)pyrene –SW 

Vertebrates NA 0.000393 71.74 - <0.0001 

Benzo(a)pyrene –FW 

Invertebrates NA 0.08 18.27 - 0.00112 

Benzo(a)pyrene –SW 

Invertebrates NA 0.0045 18.27 - 0.000246 

Benzene – FW Vertebrates 0.000102 0.0000964 38.68 <0.0001 <0.0001 

Benzene – FW Invertebrates 0.000102 0.0000964 9.898 <0.0001 <0.0001 

Benzene – SW Vertebrates 0.00273 0.00226 38.68 <0.0001 <0.0001 

Benzene – SW Invertebrates 0.00273 0.00226 9.898 0.000276 0.000228 
2013 VGP and sVGP BE Section 5- Effects Analysis 

5-137 

Table 5-53. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative 

Surrogate Taxa to MAHs and PAHs 

Pollutant and Taxa 

ECO

(PrePermit 

Condition) 

(mg/kg 

bw/d) 

ECO

(Post-Permit 

Condition) 

(mg/kg bw/d) 

CTETO 

(mg/kg 

bw/d) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Benzo(a)pyrene – FW 

Mammals NA 0.00108 1.0 - 0.00108 

Benzo(a)pyrene – SW 

Mammals NA 0.0124 1.0 - 0.0124 

Benzo(a)pyrene – All Birds NA NA - - - 

Benzene – FW Mammals 0.0000161 0.0000152 26.36 <0.0001 <0.0001 

Benzene – SW Mammals 0.000422 0.000349 26.36 <0.0001 <0.0001 

Benzene – All Birds NA NA - - - 

FW = Freshwater, SW = Saltwater 

5.3.4.1.2 Indirect Effects from MAHs and PAHs 

The RQs summarized above indicate “negligible” potential for direct effects of PAHs and 

benzene to listed species aquatic and aquatic-dependent in this BE. This is the case despite 

discharge of these pollutants from covered vessels resulting in detectable concentrations in 

estuaries and freshwater receiving water bodies where the heavy-molecular-weight PAHs, but 

not benzene (and other MAHs), could persist due to longer half-lives. 

The critical lipid body burdens calculated in this BE are inclusive of possible interactions 

between the sediments and the water column and any potential effects on benthic and pelagic 

aquatic organisms. Because of the low risk to all aquatic organisms from direct effects of PAHs 

(represented by benzo(a)pyrene) at maximum exposure concentrations calculated from pre-, and 

especially after post-permit conditions), indirect effects typically associated with the loss of 

aquatic and riparian vegetation, including loss of cover and changes in water quality parameters, 

are also not expected. 

Risk Conclusion Aquatic and Aquatic-Dependent Listed Species and Their Critical Habitats in 

RAAs - MAHs and PAHs

Based on the consideration of potential direct and indirect effects as outlined above, the 

risk conclusion made for each of the listed species in the RAA is remote. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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5.3.4.2 Bis(2-ethylhexyl) phthalate and 2,4,6-Trichlorophenol 

Ecotoxicological data for to bis(2-ethylhexyl)phthalate and 2,4,6-trichlorphenol are 

severely limited. EPA only identified sufficient data to support risk assessments of aquaticdependent species exposure to maximum concentrations of bis(2-ethylhexyl) phthalate in 

receiving water and risk to freshwater aquatic species from predicted exposure to 2,4,6-

trichlorophenol. 

Risk of Direct Effects of Bis(2-ethylhexyl) phthalate to Birds and Mammals 

In theory, bis(2-ethylhexyl) phthalate, with a log(Kow) or octanol-water partition 

coefficient of 4.0, can accumulate in tissues of aquatic organisms and potentially biomagnify up 

the food chain, although the trophic transfer factor is likely small (no greater than a factor of 1.23 

from trophic level 2 to 3 – see USEPA, 2003a). Thus, using log(Kow) and the appropriate trophic 

transfer factor, EPA calculated BAFs for bis(2-ethylhexyl) phthalate of 10,000 and 12,300 L/kg 

for invertebrates and vertebrates, respectively. These BAFs are an overestimate of the true BAFs 

likely for this pollutant because they are not based on the fraction of bis(2-ethylhexyl) phthalate 

that is freely dissolved. 

The evaluation of risk to aquatic-dependent birds and mammals from exposure via 

consumption of prey items or drinking ambient surface water at the maximum concentrations 

predicted for bis(2-ethylhexyl) phthalate is driven by the information calculated in Table 5-54. 

The RQs estimated for surrogate birds and mammals based on the quotient of ECO and CTETO

for bis(2-ethylhexyl) phthalate were all below or well below a value of 0.08, particularly for 

freshwater and saltwater mammals (all RQs are less than 0.001). The highest RQ is 

approximately 0.0768 estimated for saltwater birds potentially exposed to this pollutant under the 

pre-permit condition. Control measures implemented as part of the issuance of the permits are 

anticipated to lower the risk to all aquatic-dependent species exposed in freshwater by 12 

percent, and in saltwater by 25 percent. These RQs indicate “remote” risk of bis(2-ethylhexyl) 

phthalate to aquatic-dependent birds and mammals. 

Table 5-54. Risk Quotients based on Division of Pre- and Post-permit Exposure 

Concentrations by Chronic Toxicity Effect Thresholds of Representative Surrogate Taxa to 

Bis(2-ethylhexyl) phthalate 

Taxa – Aquatic Environment 

ECO

(Pre-Permit 

Condition) 

(mg/kg bw/d) 

ECO

(Post-Permit 

Condition) 

(mg/kg bw/d) 

CTETO

a

(mg/kg 

bw/d) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Mammals – FW 0.000376 0.000332 18.3 <0.0001 <0.0001 

Birds – FW 0.00294 0.0026 1.1 0.00267 0.00236 

Mammals – SW 0.0108 0.00806 18.3 0.000591 0.000441 

Birds – SW 0.0845 0.063 1.1 0.0768 0.0573 

a) Values based on studies reported in Sample et al. (1996); see Appendices H and I for calculations. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Risk of Direct Effects of 2,4,6-Trichlorphenol to Freshwater Aquatic Organisms 

Table 5-55 summarizes the chronic toxicity data available for calculating RQA,W for 

aquatic listed species exposed to predicted concentrations of 2,4,6-trichlorphenol in water 

receiving permitted discharges from covered vessels. Values are provided for the maximum 

before (expected or pre-permit condition) and after (anticipated or post-permit condition) 

exposure concentrations estimated in rivers from the hypothetical harbor modeling, as well as the 

corresponding RQA,Ws calculated for each major taxonomic group based on the various chronic 

toxicity threshold values (in this case, CTETA,W) readily available for representative surrogate 

taxa. 

The overall risk to freshwater aquatic organisms from maximum exposure to 2,4,6-

Trichlorpheno from permitted vessels is remote. All RQA,Ws are below a value of 0.0001, 

particularly for freshwater vertebrates and vascular plants. The highest RQ is 0.000024 estimated 

for freshwater invertebrates under the pre-permit condition. Control measures implemented as 

part of the issuance of the permits are anticipated to lower the risk to all freshwater species 

exposed to this pollutant from permitted vessel discharges by approximately 13 percent. 

Table 5-55. Summary of Chronic Toxicity Effect Thresholds for Aquatic and Aquaticdependent Organisms Exposed to 2,4,6-Trichlorphenol 

Surrogate Aquatic 

Species Type 

Surrogate 

Species 

Exposure/Effe

ct Endpoint 

NOEC - 

LOEC 

(μg/L) 

CTETA,W 

(μg/L) Study (source) 

Freshwater 

Vertebrate 

Fathead minnow, 

Pimephales 

l

ELS Test 530-970 720 USEPA 1980b 

Freshwater 

Invertebrate 

Cladoceran, 

Daphnia magna - - 0.464 USEPA 1980b 

Freshwater Plant 

(Vascular) 

Duckweed, 

Lemna minor 

Undescribed 

Test/Chlorosis 

LC50 

equivalent 5,923 

Blackman et al. 

1955 in USEPA 

1980b 

Taxa

ECW

(Pre-Permit 

Condition) 

(μg/L) 

ECW

(Post-Permit 

Condition) 

(μg/L) 

CTETA,W

(μg/L) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Freshwater 

Vertebrate 0.0000113 0.00000986 720 <0.0001 <0.0001 

Freshwater 

Invertebrate 0.0000113 0.00000986 0.464 <0.0001 <0.0001 

Freshwater Plant 

(Vascular) 0.0000113 0.00000986 5,923 <0.0001 <0.0001 

5.4 UNCERTAINTIES IN THE QUANTITATIVE EFFECTS ANALYSIS 

As described above in Section 5.2.5, there are five major categories of uncertainty in this 

BE potentially limiting interpretation of results and corresponding conclusions, including: 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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1. Estimation of exposure concentrations used to support the effects analysis; 

2. Selection of chronic toxicity values representative of the sensitivity of aquatic 

organisms; 

3. Use of surrogate species effects information for listed species 

4. Estimation of risk for aquatic-dependent birds and mammals; and 

5. Representativeness of results to other listed species. 

Of these five major categories of uncertainty, uncertainty regarding selection of chronic 

toxicity values representative of the sensitivity of aquatic organisms (#2), and use of surrogate 

species effects information for listed species (#3), are further addressed below in terms of their 

relevance to interpreting the results of the quantitative effects analysis, as well as to the overall 

uncertainty regarding possible risk to pollutant mixtures. 

5.4.1 Uncertainty Variation Associated with Estimation of Chronic Toxicity

From Section 5.2.6.2, it is understood that uncertainty variation exists with regard to 

estimation of chronic toxicity in this analysis due to three key areas: 

 Degree of data availability (e.g., species versus genus versus family); 

 Test and endpoint uncertainty (e.g., full or partial life cycle versus ELS test; selection 

of endpoint); and 

 Method of effect quantification (NOEC-LOEC versus point estimate). 

All of these issues strongly influence evaluation of the potential risk of a given exposure 

concentration. 

In addition to the above, it should also be understood that: 

 Very little scientifically and commercially available, definitive ecotoxicological data 

exist for the vast majority of listed species (exception, steelhead trout) because of 

restrictions in place preventing use of such species for toxicity testing, and 

 What data do exist are limited to only a few pollutants (ammonia, copper, carbaryl, 4-

nonylphenol, pentachlorophenol, and permethrin) and freshwater/euryhaline fish 

species (shortnose and Atlantic sturgeon, bonytail chub, Cape Fear shiner, Colorado 

pikeminnow, razorback sucker, Apache trout, Lahontan and greenback cutthroat 

trout, and desert and Leon Spring pupfish; again, steelhead trout excluded). 

In terms of the latter, side-by-side acute and chronic toxicity testing clearly indicates that listed 

fish species do not appear universally more sensitive than other common surrogate fish species 

(Mayer et al., 2008). Such conclusion is assumed for all other species groups as well (e.g., listed 

freshwater unionid mussels are no more sensitive to ammonia and copper than other surrogate 

freshwater bivalve mollusk species, i.e., non-threatened or endangered freshwater unionid 

mussels, Asian clam, fingernail clam, etc. – see USEPA, 2005c and 2009b) 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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 Finally, if it were feasible, the least uncertain chronic toxicity effect threshold value 

would be one determined from numerous field tests with individual pollutants (and their 

mixtures) added to a wide variety of unpolluted bodies of fresh (or salt) water containing an 

array of aquatic and aquatic-dependent organisms. It would be necessary to add various amounts 

of the material to each body of water in order to determine the highest concentration that would 

not cause any unacceptable long-term or short-term effect on the organisms or their uses. The 

lowest of these highest concentrations would serve as the basis for derivation of a toxicity 

threshold value that would be protective of all species, including listed species. Because it is not 

feasible to conduct such field tests, nor are such results scientifically or commercially available, 

EPA believes that the approach used in this analysis provides an objective, internally consistent, 

appropriate, and feasible way of determining risk to listed aquatic and aquatic-dependent species, 

which is also intended to provide roughly the same level of protection as the infeasible field 

testing approach described above. 

 In order to account for any possible (although unexpected) difference in sensitivity 

between a listed species and its surrogate species, EPA opted to apply its recently published 

safety adjustment factor of 2.0 (see Mayer et al., 2008) to the Agency’s criterion continuous 

concentration to further evaluate the risk to the 82 RAA listed species and subsequent 454 listed 

species considered in the quantitative effects analysis. Table 5-56 presents the pre- and postpermit RQ values for water-only exposure of listed fish species to the estimated maximum 

exposure concentrations in the hypothetical estuary and river harbor. 

Table 5-56. Summary of Species-Specific Risk Conclusions for Listed Aquatic and Aquaticdependent Species in RAAs 

Pollutant 

ECW

(Pre-Permit 

Condition) 

(μg/L) 

ECW

(Post-Permit 

Condition) 

(μg/L) 

CCC/2.0b 

(μg/L) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Freshwater

Total Residual Chlorine 0.00328 0.00319 5.5 0.000597 0.00058 

Aluminum, Total 0.0334 0.0309 44 0.000759 0.000701 

Arsenic, Dissolved 0.164 0.164 75 0.00219 0.00219 

Cadmium, Dissolved 0.0000129 0.0000118 1.1 <0.0001 <0.0001 

Chromium, Dissolved 0.0000399 0.0000338 5.5 <0.0001 <0.0001 

Copper, Dissolved 0.033 0.0328 1.5c 0.022 0.0219 

Lead, Dissolved 0.0000922 0.0000878 1.3 <0.0001 <0.0001 

Nickel, Dissolved 0.0246 0.0246 26 0.000946 0.000945 

Selenium, Total 0.203 0.203 2d 0.101 0.101 

Zinc, Dissolved 0.00968 0.00948 60 0.000161 0.000158 

Total Ammonia Nitrogen 0.000032a 0.0000285a 0.28a 0.000114 0.000102 

Saltwater

Total Residual Chlorine 2.14 0.66 3.8 0.564 0.174 

Aluminum, Total 1.28 1.02 - <0.0001 <0.0001 

Arsenic, Dissolved 1.94 1.94 18 0.108 0.108 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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Table 5-56. Summary of Species-Specific Risk Conclusions for Listed Aquatic and Aquaticdependent Species in RAAs 

Pollutant 

ECW

(Pre-Permit 

Condition) 

(μg/L) 

ECW

(Post-Permit 

Condition) 

(μg/L) 

CCC/2.0b 

(μg/L) 

RQ 

(PrePermit) 

RQ 

(PostPermit) 

Cadmium, Dissolved 0.000867 0.000697 4.7 0.000184 0.000148 

Chromium, Dissolved 0.00191 0.00185 25 <0.0001 <0.0001 

Copper, Dissolved 0.374 0.37 1.6 0.234 0.231 

Lead, Dissolved 0.00295 0.00262 4.1 0.000719 0.000639 

Nickel, Dissolved 0.291 0.291 4.1 0.0709 0.0709 

Selenium, Total 2.39 2.25 36 0.0664 0.0624 

Zinc, Dissolved 0.493 0.452 40 0.0123 0.0113 

Total Ammonia Nitrogen 0.00954a 0.00742a - - - 

a) Total ammonia nitrogen exposure concentrations and CCCs are expressed in mg N/L. 

b) CCCs are either final or publically-available draft (ammonia) values expressed as in the National 

Recommended Water Quality Criteria, i.e., as dissolved metals and normalized to 100 mg/L CaCO3, or pH=8 

and 25oC in the case of ammonia –see http://water.epa.gov/scitech/swguidance/standards/current/index.cfm. 

c) From EPA’s 2005 Biotic Ligand Model-based ALC (USEPA, 2005c). 

d) Recommended water-based CCC for total selenium back-calculated from a recommended tissue-based chronic 

toxicity value for freshwater fish (Lemly, 1993). 

 The RQs provided in Table 5-56 support the results presented in the preceding analysis. 

That is to say, all but one of the pollutants analyzed show “remote” (RQ<0.1) or “negligible” 

(RQ<1.0) risk to listed aquatic species (and likely also to the aquatic-dependent species that may 

consume them) under maximum pre-permit and post-permit exposure concentrations. 

5.4.2 Uncertainty and Evaluation of Risk from Possible Exposure to Pollutant Mixtures

 Although organisms are simultaneously exposed to multiple pollutants in their natural 

environment, environmental toxicologists and EPA have historically assessed the risk from 

exposure to a single pollutant present in the environment. Assessing mixture toxicity is 

extremely complicated due to the vast number of combinations of pollutants that could be 

present in a mixture, the limited amount of information on interactions among pollutants in 

mixtures, and the differing mechanisms of action among pollutants within a given mixture. In 

addition, determining the actual dose of each pollutant within the mixture to which an organism 

is exposed presents a significant amount of uncertainty due to the numerous factors that can 

control the bioavailability and uptake of an individual pollutant by the organism within the 

mixture. 

 Given that real world environments contain a mix of pollutants with differing 

mechanisms of action, any approach that hopes to accurately predict mixture toxicity must 

ultimately be based upon toxicity data for all of the individual pollutants within the mixture. 

Evaluating and quantifying the effects of mixtures is challenging as the toxic effects of pollutants 

in mixture can be less than those predicted for the same pollutants singly, greater than, or have 

no appreciable difference. Concentration addition is a common method used to assess mixture 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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toxicity; however, this method is accurate only when the mixture consists solely of pollutants 

with the same toxicological mechanism of action. Perhaps the best known examples of pollutant 

mixtures where toxicity is additive is for metals and type 1 narcotics such as PAHs (USEPA, 

2005c; McGrath and DiToro, 2009). 

 As an additional assessment of the risk posed to listed aquatic species from incidental 

discharges from vessels covered under the VGP and sVGP, EPA calculated the additive toxicity 

of metals and PAHs in mixture from vessel discharges. In this analysis, EPA summed the RQs 

for water-column only exposure based on a mixture of metals and PAHs to give a total RQ 

representative of the risk of those mixtures to listed aquatic species. The RQs of individual 

metals and PAHs in mixture are provided in Table 5-57 and Table 5-58 below, along with the 

sum of RQs representing their mixture. Based on the results of this analysis, EPA believes that 

exposure to the maximum exposure concentrations of metals and PAHs in mixture presents a 

“remote” risk to listed species. 

 Although EPA limited the quantitative mixture analysis to metals and PAHs, the postpermit RQ values for all of the pollutants evaluated in the BE were low to extremely low (i.e., 

<0.1 to <0.01) suggesting that any additive risk from the pollutants from vessel discharges in 

mixture is likely not of concern. 

 
2013 VGP and sVGP BE Secti

144 

Table 5-57. Sum of RQs for Metals Under Pre- and Post-Permit Conditions 

Taxa Cd RQ CrVI RQ Cu RQ Pb RQ Ni RQ Z

Pre-Permit 

Conditions 

Freshwater Fish 0.0000077 0.00000133 0.00705 0.000000985 0.000156 0Freshwater Invertebrate 0.0000682 0.0000259 0.00847 0.0000152 0.00349 0Freshwater plant 0.0000129 0.00000131 0.000289 0.0000000115 0.0000725 0.0Estuarine/Marine Fish 0.000106 0.00000208 0.00181 0.000258 0.0000688 0Estuarine/ Marine Invertebrate 0.000122 0.000109 0.0474 0.000124 0.0133 0Saltwater plant 0.0000932 0.0000000193 0.00752 0.000364 0.0355 0.

Post-Permit 

Conditions 

Freshwater Fish 0.00000705 0.00000112 0.007 0.000000937 0.000156 0Freshwater Invertebrate 0.0000624 0.000022 0.00842 0.0000145 0.00349 0Freshwater plant 0.0000118 0.00000111 0.000288 0.000000011 0.0000725 0.0Estuarine/Marine Fish 0.0000851 0.00000201 0.00179 0.000229 0.0000688 0Estuarine/ Marine Invertebrate 0.0000981 0.000106 0.0469 0.00011 0.0133 0Saltwater plant 0.0000749 0.0000000187 0.00743 0.000323 0.0354 0.

Table 5-58. Sum of RQs for PAHs Under Post-Permit Conditions 

Taxa Benzo(a)- anthracene Benzo(a)-pyrene Benzo(b)- fluoranthene Benzo(k)- fluoranthene Chrysene Ideno- (1,2,3-cd)-

pyrene 

All Freshwater Taxa 0.00074 0.00191 0.000701 0.000882 0.00103 0.000384 0All Saltwater Taxa 0.00635 0.0218 0.0149 0.0188 0.00952 0.00818 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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5.5 SUMMARY OF RISK CONCLUSIONS FOR LISTED AQUATIC AND AQUATIC-DEPENDENT 

SPECIES AND THEIR CRITICAL HABITATS REPRESENTED WITHIN RAAS

 EPA qualitatively and quantitatively evaluated the potential for ANS and pollutants in 

vessel discharges to adversely affect listed species potentially impacted by the issuance of these 

permits. EPA’s qualitative analysis considered both potential for exposure and likelihood of 

adverse effects from vessel discharges within the context of the species-specific life history 

information provided in Appendix F. EPA’s quantitative analysis assessed pollutant-specific risk 

based on the calculation of risk quotients (RQs) for listed and surrogate species exposed to 

maximum pollutant concentrations in a hypothetical estuary and river harbor under pre- and 

post-permit conditions. For the quantitative analysis, EPA considered both the potential for direct 

and indirect effects to the 82 RAA listed species within the context of the life history information 

provided in Appendix F. Table 5-59 summarizes EPA’s risk conclusions for each of the 82 listed 

aquatic and aquatic-dependent species and their critical habitats potentially exposed to vessel 

discharges covered under the VGP and sVGP. Table 5-59 also includes highlights of important 

life history information for individual species that were taken into consideration in determining 

the indirect effect risk conclusions. 

 EPA’s qualitative analysis for ANS presented in Section 5.1.1 indicates a potential ongoing risk in U.S. coastal and inland waters to listed (and other) species due to the risk of new 

invasions resulting from vessel discharges, albeit one that is significantly reduced with the 

issuance of the VGP and sVGP. Coastal environments in particular are vulnerable to ANS due to 

unmanged ballast water discharges and biofouling from commercial shipping vessels. Numerous 

studies have concluded that the reductions in the discharge of viable organisms capable of 

establishing a viable population will reduce the risk of invasions (NAS, 2011). Thus, while it is 

presently not possible to calculate the risk associated with ANS, EPA believes that the VGP and 

sVGP will significantly reduce the risk of ANS to aquatic and aquatic-dependent listed species 

and their critical habitats that may be affected by the permit actions. See Section 6.1 for a full 

discussion of mitigating effects of the VGP and sVGP on ANS in vessel discharges. 

 EPA qualitatively and quantitatively evaluated the effects of the 32 pollutants identified 

as requiring detailed evaluation and determined that the risks under post-permit conditions 

ranged from “remote” to “negligible”. The pollutants that resulted in the highest RQ values (all 

less than 1.0 indicating “negligible” risk) in the quantitative analysis for listed and surrogate 

aquatic species were selenium, total residual chlorine, total phosphorus, and arsenic. The 

conclusion of “negligible” risk to aquatic listed species from exposure to several of the pollutants 

was subsequently corroborated by applying a safety adjustment factor of 2.0 to the Agency’s 

criterion continuous concentration (Table 5-56). EPA’s analysis of the potential risk of various 

metals and PAHs in mixture also resulted in RQ values less than 0.1, thus, EPA assumes that the 

risk to aquatic species from mixtures is “remote”. Finally, the majority of the RQs calculated for 

aquatic-dependent wildlife species were very low (<0.001) or low (<0.1) such that the estimation 

of risk based on use of CTETs from surrogate species should still be predictive even when 

extrapolating differences in dietary absorption between actual listed versus surrogate species. 

Based on these results, EPA concluded that the discharge of toxic and conventional pollutants 

with toxic effects from VGP and sVGP vessels presents a “remote” to “negligible” risk to the 82 

RAA listed species. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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 In addition to the qualitative and quantitative risk analyses, EPA evaluated and 

considered the stressors currently affecting the 82 RAA listed species (see Table 4-19). 

Biological and natural threats (e.g., competition, predation, disease, and genetic threats) with no 

relationship to vessel discharges were the predominant stressors documented for the 82 RAA 

listed species. EPA identified 23 of the 82 RAA species with known threats from water pollution 

and other related water quality problems; however, none of the species-specific threat 

information identified vessel discharges as a specific pollution source of concern. The results of 

the quantitative analysis estimated RQ values indicate a “remote” to “negligible” risk to listed 

aquatic and aquatic-dependent species and their critical habitats from vessel discharges alone. 

The RAAs evaluated in the effects analysis are heavily impacted by pollutant sources other than 

vessel discharges such as industrial discharges, urban storm water, superfund sites, and 

agricultural runoff (see RAA-specific discussion of water quality impairments in Section 4). The 

magnitude of the pollutant loads associated with these other pollutant sources in the RAAs are 

likely greater than the pollutant loads associated with the vessel populations present in RAAs. 

Given that pollutant loads from vessel discharges are comparatively lower than those from other 

sources in the RAAs, and given that the estimated RQs from incidental vessel discharges are 

extremely low, EPA believes that vessel discharges covered under the VGP and sVGP are 

unlikely a primary pollution source for listed species with identified sensitivities to water 

pollution. 

 EPA also determined 24 of the 82 RAA listed species designated existing ANS as a 

major threat of concern, 14 of which are wetland plants. Therefore, based on this information, it 

appears that only a select number of the 82 RAA listed species have a higher historic sensitivity 

to ANS (and therefore have a documented elevated risk from past exposure to ANS). Given this 

assessment, EPA concluded that even when known threats are taken into consideration and 

potentially more vulnerable species (i.e., species with water quality and/or ANS designated as a 

known threat) are exposed to post-permit vessel discharges the risk remains “remote” or 

“negligible” that vessel discharges will adversely affect the aquatic and aquatic-dependent and 

their crititical habitats that may be affected by the VGP and sVGP. Given this and all of the 

supporting information provided in Section 5.2, EPA is confident that the use of the risk 

conclusions (see Section 5.2.5) presented in Table 5-59 for the 82 RAA listed species to support 

the effects determinations in Section 7.0 appropriately captures the species variability in 

taxonomic group, spatial scale, life history, and environmental stressors for all 612 aquatic and 

aquatic-dependent listed species and their critical habitats that may be affected by the VGP and 

sVGP (Appendix E). 
2013 VGP and sVGP BE Secti

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Table 5-59. Summary of Species-Specific Risk Conclusions for Listed Aquatic and Aquatic-dependent Spe

Listed Species/ Taxa RAA(s)a

Exposure 

Pathway of 

Concernb

Direct 

Effectsc

Potential for Indirect Effects 

Loss of Preyc Loss of Habitat Water Quality 

Alameda Whipsnake SFBE Aq Dep – FW Remote Remote Remote RemoteAmerican Chaffseed BB FW wetland Remote Remote Remote RemoteAmerican Crocodile BB Aq Mult - FW, SW Remote Remote Remote RemoteAudubon's Crested Caracara BB Aq Dep – FW Remote Negligible – Se Remote RemoteBog Turtle ULB Aq Mult – FW Remote Remote Remote Remote AN

sen

Brooksville Bellflower BB Wet prairie, edges of ponds Remote Remote Remote RemoteBull Trout PS Aq Mult – FW Remote Remote Remote Remote PolCalifornia Freshwater Shrimp SFBE Aq Mult – FW Remote Remote Remote Remote Lim

Pol

California Red-legged Frog SFBE Aq Mult – FW Remote Remote Remote Remote ANCalifornia Tiger Salamander SFBE Aq Mult – FW Remote Remote Remote Remote

Aquvern(pre

Calistoga Allocarya SFBE Wetland-riparian Remote Remote Remote Remote Lim

sen

Cape Sable Seaside Sparrow BB Aq Dep – FW Remote Remote Remote RemoteChinook Salmon (Puget Sound) PS Aq Mult - FW, SW Negligible – Se Remote Remote Remote Rem

lifesen

Chum Salmon (Hood Canal summer-run) PS Aq Mult - FW, SW Negligible – Se Remote Remote Remote Rem

lifesen

Colusa Grass SFBE 

FW wetland, vernal pools, 

wetland-riparian 

Remote Remote Remote Remote Lim

sen

Conservancy Fairy shrimp SFBE Aq Mult – SW Remote Remote Remote Remote Lim

sen

Decurrent False Aster UMR Lakes shores, stream banks Remote Remote Remote RemoteDelta Green Ground Beetle SFBE Aq Dep – FW Remote Remote Remote Remote Lim
2013 VGP and sVGP BE Secti

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Table 5-59. Summary of Species-Specific Risk Conclusions for Listed Aquatic and Aquatic-dependent Spe

Listed Species/ Taxa RAA(s)a

Exposure 

Pathway of 

Concernb

Direct 

Effectsc

Potential for Indirect Effects 

Loss of Preyc Loss of Habitat Water Quality 

Delta Smelt SFBE Aq Mult - FW, SW Negligible – Se Remote Remote RemoteEastern Indigo Snake BB Aq Dep – FW Remote Remote Remote RemoteEastern Prairie Fringed Orchid UMR Pothole marsh, fen – FW Remote Remote Remote Remote ANElkhorn Coral BB Aq Water Only – SW Remote Remote Remote Remote NonEverglade Snail Kite BB Aq Dep – FW Remote Remote Remote ANFinback Whale ULB, GB Aq Mult – SW Negligible – As, Se Negligible – Se Remote Remote LimFlorida Panther BB Aq Dep – FW Remote Remote Remote Remote LimFountain Thistle SFBE Wetland-riparian Remote Remote Remote Remote ANGiant garter Snake SFBE Aq Dep – FW Remote Remote Remote Remote ANGray Bat UMR, BB Aq Dep – FW Remote Remote Remote Remote LimGreen Sea Turtle 

PS, ULB, 

GB, BB, 

SFBE 

Aq Mult – SW Remote Remote Remote Remote Lim

Grizzly Bear PS Aq Dep – FW Remote Negligible – Se Remote RemoteGuadalupe Fur Seal SFBE Aq Mult – SW Negligible – As, Se Negligible – Se Remote Remote Pol

spil

Gulf Sturgeon BB Aq Mult - FW, SW Negligible – Se Remote Remote Remote Rem

lifesen

Hairy Orcutt Grass SFBE 

FW wetland, vernal pools, 

wetland-riparian 

Remote Remote Remote Remote Lim

sen

Hawksbill Sea Turtle ULB, GB, BB Aq Mult – SW Remote Remote Remote Remote LimHoover's Spurge SFBE 

FW wetland, vernal pools, 

wetland-riparian 

Remote Remote Remote Remote Lim

sen

Humpback Whale PS, ULB, GB, BB Aq Mult – SW Negligible – As, Se Negligible – Se Remote Remote Lim
2013 VGP and sVGP BE Secti

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Table 5-59. Summary of Species-Specific Risk Conclusions for Listed Aquatic and Aquatic-dependent Spe

Listed Species/ Taxa RAA(s)a

Exposure 

Pathway of 

Concernb

Direct 

Effectsc

Potential for Indirect Effects 

Loss of Preyc Loss of Habitat Water Quality 

Indiana Bat ULB, UMR, BB Aq Dep – FW Remote Remote Remote Remote LimJohnson's Seagrass BB Intertidal zones, coastal lagoons Remote Remote Remote RemoteKemps’s Ridley Sea Turtle ULB, GB Aq Mult – SW Remote Remote Remote Remote LimKiller Whale PS, SFBE Aq Mult – SW Negligible – As, Se Negligible – Se Remote Remote PolLeast Tern UMR Aq Dep - FW, SW Remote Negligible – Se Remote Remote Leatherback Sea Turtle 

PS, ULB, 

GB, BB, 

SFBE 

Aq Mult – SW Remote Remote Remote Remote Lim

Loggerhead Sea Turtle ULB, GB, BB Aq Mult – SW Remote Remote Remote Remote LimLonghorn Fairy shrimp SFBE Aq Mult – FW Remote Remote Remote Remote LimMarbled Murrelet PS, SFBE Aq Mult – SW Remote Negligible – Se Remote RemoteNapa Bluegrass SFBE Wetland-riparian Remote Remote Remote Remote Lim

sen

North American Green Sturgeon SFBE Aq Mult - FW, SW Negligible – Se Remote Remote Remote Rem

lifesen

North Atlantic Right Whale ULB, BB Aq Mult – SW Negligible – As, Se Negligible – Se Remote Remote Lim

Pol

Olive Ridley Sea Turtle SFBE Aq Mult – SW Remote Remote Remote Remote LimPallid Sturgeon UMR Aq Mult – FW Remote Remote Remote Remote PolPalmate-bracted Bird's Beak SFBE Wetland-riparian Remote Remote Remote Remote ANPink Mucket UMR Aq, Water only – FW Remote Remote Remote Remote AN

mus

Piping Plover ULB, GB, SLE Aq Dep - FW, SW Remote Remote Remote Remote Pol

con

Red Wolf BB Aq Dep – FW Remote Remote Remote Remote LimRiparian Woodrat SFBE Aq Dep – FW Remote Remote Remote RemoteRoseate Tern ULB, BB Aq Dep – SW Remote Negligible – Se Remote Remote Pol
2013 VGP and sVGP BE Secti

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Table 5-59. Summary of Species-Specific Risk Conclusions for Listed Aquatic and Aquatic-dependent Spe

Listed Species/ Taxa RAA(s)a

Exposure 

Pathway of 

Concernb

Direct 

Effectsc

Potential for Indirect Effects 

Loss of Preyc Loss of Habitat Water Quality 

Salt Marsh Harvest Mouse SFBE Aq Dep – SW Remote Remote Remote RemoteScaleshell Mussel UMR Aq, Water only – FW Remote Remote Remote Remote AN

mus

Seabeach Amaranth ULB Beach – SW Remote Remote Remote RemoteShortnose Sturgeon ULB, BB Aq Mult - FW, SW Negligible – Se Remote Remote Remote

Remlife(comPol(nut

Short-Tailed Albatross PS Aq Mult – SW Remote Negligible – Se Remote Remote Pol

con

Smalltooth Sawfish GB, BB Aq Mult – SW Negligible – Se Remote Remote Remote PolSoft Bird's Beak SFBE Coastal salt marsh, wetland-riparian Remote Remote Remote Remote AN

Polspil

Solano Grass SFBE 

FW wetland, vernal pools, 

wetland-riparian 

Remote Remote Remote Remote Lim

sen

Sonoma Alopecurus SFBE 

FW wetland, 

wetland-riparian, 

FW marsh 

Remote Remote Remote Remote

Sonoma Sunshine SFBE 

FW wetland, vernal pools, 

wetland-riparian 

Remote Remote Remote Remote Lim

Southern Sea Otter SFBE Aq Mult – SW Negligible – As, Se Negligible – Se Remote Remote Pol

spil

Staghorn Coral BB Aq Water Only – SW Remote Remote Remote Remote NonSteelhead Salmon (Puget Sound and CA Coast) PS, SFBE Aq Mult - FW, SW Negligible – Se Remote Remote Remote Rem

lifesen
2013 VGP and sVGP BE Secti

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Table 5-59. Summary of Species-Specific Risk Conclusions for Listed Aquatic and Aquatic-dependent Spe

Listed Species/ Taxa RAA(s)a

Exposure 

Pathway of 

Concernb

Direct 

Effectsc

Potential for Indirect Effects 

Loss of Preyc Loss of Habitat Water Quality 

Steller Sea-Lion PS, SFBE Aq Mult – SW Negligible – As, Se Negligible – Se Remote Remote PolSuisun Thistle SFBE Coastal salt marsh, wetland-riparian Remote Remote Remote Remote ANTidewater Goby SFBE Aq Mult - FW, SW Negligible – Se Remote Remote Remote AN

Pol

Ute Ladies’-Tresses PS Riparian, wetland – FW Remote Remote Remote RemoteValley Elderberry Longhorn Beetle SFBE Aq Dep – FW Remote Remote Remote Remote

Speeldesen

Vernal Pool Tadpole Shrimp SFBE Aq Mult – FW Remote Remote Remote Remote LimWater Howellia PS, SFBE Ponds – FW Remote Remote Remote Remote Lim

sen

West Indian Manatee GB, BB Aq Mult - FW, SW Negligible – As, Se Remote Remote RemoteWestern Snowy Pacific Plover SFBE Aq Dep – SW Remote Remote Remote RemoteWhite Abalone SFBE Aq Water Only – SW Remote Remote Remote Remote NonWhite Sedge SFBE 

FW wetland, 

wetland-riparian, 

FW marsh, 

bogs/fens 

Remote Remote Remote Remote

Whooping Crane GB Aq Dep - FW, SW Remote Remote Remote RemoteWood Stork BB Aq Dep – FW Remote Negligible – Se Remote Remote ANa) RAA designations: PS=Puget Sound RAA; ULB=Upper and Lower Bay RAA; GB=Galveston Bay RAA; UMR=Mississippi River 

Estuary RAA; SFBE=San Francisco Bay Estuary RAA; BB=Biscayne Bay RAA. 

b) FW = Freshwater; SW = Saltwater, Aq = Aquatic, Aq Dep = Aquatic Dependent, Mult = Multiple Routes of Exposure 

c) As = arsenic, Se = selenium. 

d) EPA identified species as sensitive to ANS and or pollution based on the identified threats presented inTable 4-19. EPA limited the 

considerations in this table to ANS and pollution threats that could reasonably be attributed to vessel discharges covered under the example, a species identified as sensitive to pollution from entanglement with debris is not designated as sensitive to pollution in th

debris is not allowed under the VGP or sVGP. 
2013 VGP and sVGP BE Section 5- Effects Analysis 

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on Mitigating Impact to Listed Species 

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SECTION 6 

ANTICIPATED EFFECT OF PROPOSED ACTIONS ON 

MITIGATING IMPACT TO LISTED SPECIES 

 EPA has determined that the combined numeric and narrative technology-based effluent 

limits (TBELs) in the VGP and sVGP achieve the reduction and/or elimination of many of the 

pollutants in the permitted discharges, in most cases without using highly engineered, complex 

treatment systems (see Section 2.3). All discharge- and vessel class-specific TBELs (except for 

ballast water) are included in the permit excerpts included in Appendices A and B. Limits for 

ballast water are included separately in Appendix C and discussed in greater detail in Section 6.1 

below. Collectively, EPA used this information to support both the qualitative and quantitative 

effects analyses presented in Section 5.0, and specifically, calculation of the post-permit 

exposure concentrations for pollutants selected for detailed evaluation (see Section 3.2.3). 

 EPA’s evaluation of the permit’s ability to mitigate risk to listed species falls into two 

broad categories: reduced risk of the introduction of ANS (e.g., ballast water), and improved 

environmental quality from reduced pollutant loads. EPA evaluated the mitigation of risk from 

these two categories by considering the likelihood for reductions in ANS and pollutant loads to 

affect both direct and indirect effects of the proposed actions on listed species and their critical 

habitats. 

 For both ANS and the pollutants identified for detailed evaluation, EPA anticipates that 

any potential negative impact (direct or indirect) to listed species from incidental vessel 

discharges will be minimized or eliminated following implementation of the VGP and sVGP due 

to the reduction in ANS and pollutant loads anticipated from the permit actions. The reduction in 

ANS and pollutant load is anticipated to be achieved one of three ways: 

 A significant reduction in flow (volume) of the pollutant-containing discharge; 

 A significant reduction in concentration of the pollutant in a discharge; or 

 The combination of a reduction in flow and concentration of pollutant in a discharge 

(e.g., Parts 2.2, 5.1, and 5.2 of the VGP). 

Sections 6.1 through 6.4 below describe the anticipated ability of the proposed actions on 

mitigating impact to listed species for the following pollutant categories and/or vessel 

discharges: 

 ANS in vessel discharges; 

 Pollutants lacking specific concentration-response toxic effects thresholds (i.e., 

pathogens, BOD, and oil and grease); 

 Toxic and non-conventional pollutants with toxic effects; and 

 Coal ash from coal fired propulsion systems on ferries. 
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6.1 MITIGATION OF RISK TO LISTED SPECIES FROM THE VGP’S CONTROL OF ANS IN 

VESSEL DISCHARGES

EPA’s permit limits minimize the impacts of ANS in vessel ballast water discharge, 

biofouling, and other vessel discharges with both non-numeric best management practices and 

numeric standards from ballast water discharges. This approach combines the use of technologyand water quality-based BMPs in situations and circumstances where their application will 

control and mitigate the risk of ANS introduction and establishment. EPA expects that such 

limitations will result in significant reductions in concentrations of living organisms beyond 

current management practices, and will result in discharges with a very small absolute risk of 

invasion which will mitigate risk to endangered species and their critical habitats. 

This section presents a qualitative assessment of the reduction of risk of ANS invasion 

and establishment via vessel discharge vectors to listed species expected due to EPA’s permit 

limits. The assessment considers the relative effectiveness of mitigation options to control the 

propagule pressure from ANS in vessel discharges. This information is being offered in support 

of the effects determinations made in this BE regarding ANS and is organized as follows: 

 The scientific framework for addressing ANS invasion and establishment, including 

using modeling methodologies, is reviewed in Section 6.1.1. 

 This framework is followed by Section 6.1.2 which presents the relative effectiveness 

of mitigation options to control propagule pressure from ANS in ballast water 

discharges (the most-studied and previously-regulated vessel discharge vector). 

 Finally, the relative effectiveness of mitigation options to control the other major 

vessel discharge vector for ANS, biofouling (of hulls, recessed areas, seawater 

cooling systems, etc.), is addressed in Section 6.1.3. 

 Section 6.1.4 considers BMPs included in the VGP to control the discharge of ANS in 

two other vessel discharge vectors, chain locker effluent and fish hold effluent. 

 VGP requirements for inspection, monitoring, reporting and recordkeeping of vessels 

(and their operations) relevant to efforts to mitigate and control the discharge of ANS 

via ballast water discharge, biofouling, and other discharges are addressed in Section 

6.1.5. 

 Section 6.1.6 considers management measures included in the new sVGP to mitigate 

ANS discharges from small vessels. 

 Finally, section 6.1.7 provides two specific examples of how EPA anticipates the use 

of the technology and water quality-based BMPs included in the permits will mitigate 

impacts of ANS on listed species from the ballast water vector. 

6.1.1 Mitigating Risk of ANS by Reducing Propagule Pressure

As presented in Section 5.1.1, the concept that risk to invasion from ANS decreases with 

decreasing propagule supply is the fundamental assumption behind efforts to mitigate risk from 

ANS in vessel discharges. This assumption is supported by a wide body of empirical, theoretical, 

and experimental evidence showing that the success of ANS invasion decreases with a decrease 

in propagule pressure, either by a lower concentration of organisms in a discharge and/or by a 

decrease in the number and frequency of discharges (NAS, 2011). One challenge of quantifying 
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the risk of ANS invasion and establishment in general, is that the concentration-response (riskrelease) relationship for ANS in natural receiving waters is unknown and therefore cannot be 

quantified. A second challenge (in the context of this BE) is that the impact of ANS from vessel 

discharges to listed species is itself unknown and cannot be quantitated or predicted1, except for 

a relatively few examples of negative impacts as described in Section 5.1.1.9, although ANS 

generally pose an array of threats to native species. 

6.1.1.1 Predicting the Relationship Between Propagule Pressure and Risk of ANS 

Invasion and Establishment 

As established by the previous discussions of ANS, in Sections 5.1.1 and above, the lack 

of quantitative risk-release relationships for ANS in vessel discharges severely limits efforts to 

quantifiably mitigate ANS. A recent National Academy of Science publication titled “assessing 

the relationship between propagule pressure and invasion risk in ballast water” (NAS, 2011) 

presents and critically reviews mathematical modeling approaches that have been developed to 

express the risk–release relationship between ballast water organism concentration and the risk 

(probability) of ANS establishment. The NAS evaluated several mathematical models and other 

approaches that have been developed to express this relationship, including a discussion on the 

data needed to support each model as well as other strengths and weaknesses. The models range 

from descriptive models that simply represent the shape of the relationship to mechanistic 

models that define the processes generating the relationship. The models are also distinguished 

by whether they consider a single species vs. multiple species. 

The NAS (2011) report discussed three of the mathematical modeling approaches to 

project the risk–release relationship: the reaction-diffusion approach, the per capita invasion 

probability approach, and population viability analysis (PVA). Reaction-diffusion models predict 

the concentration of a “substance” that is simultaneously influenced by diffusion which dilutes it and 

by some type of reaction affecting its concentration. The primary use of such models in invasion 

biology has been the theoretical analysis of the pattern of invasion spread of terrestrial invaders. The 

only published example of a reaction-diffusion model applied to ballast water is that of Drake et al. 

(2005). Using changes in relative population densities, Drake et al. (2005) predicted the maximum 

safe volume of ballast water that could be exchanged. Because these predictions are volume based, 

they can not be used to generate organism-based standards (Lee et al., 2010). On a more general 

level, Lee et al. (2010) determined that the reaction-diffusion model assumption that species are 

passively distributed is generally violated and is likely to result in a substantial underestimation of 

the likelihood of establishment of a species. In particular, benthic species whose larval and/or 

juvenile phases actively settle out of the water column are much more likely to become established 

than predicted from dilution models. Thus, in aquatic environments, diffusion models are primarily 

limited to predicting invasions of small, holoplanktonic organisms, such pelagic copepods. Because 

of this limitation, diffusion models do not appear to be suitable for generating concentration-based 

discharge standards applicable to the wide range of taxa found in ballast water. 

Lee et al. (2010) developed a “per capita invasion probability” (PCIP) approach to estimate 

the likelihood of invasion based on historical invasion rates and calculated ballast-associated 

 

1

 To the best of EPA’s knowledge, the quantification or estimation of risk from ANS impacts to listed species 

associated with vessel discharges is not addressed in the scientific literature. 
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propagule pressure, based on the general consensus that an increase in propagule supply increases the 

likelihood of invasion. The PCIP is the per year probability that an individual non-native propagule 

discharged from ballast water will become established as a new ANS in a specified waterbody. Using 

a linear dose response assumption, the PCIP is calculated from the historical number of potential 

ballast-mediated invasions in a specified waterbody over a defined time period, the average annual 

total ballast discharged at that location during this time period, and the estimated organism 

concentration in the discharged ballast water. Once a PCIP is calculated from historical data, it can 

be used to predict the rate of new ballast-associated invasions in a waterbody with a projected ballast 

discharge volume and organism concentration. By altering the organism concentration, it is possible 

to generate risk scenarios predicting the number of new invaders for different discharge standards. 

The NAS concluded that, in principle, a well-supported model of the relationship 

between invasion risk and organism release could eventually be used to derive a ballast water 

discharge standard that is “known” to be sufficient to prevent successful ANS introductions, but 

there is currently a “profound lack of data” to populate the models. For a given discharge 

standard, the corresponding invasion risk could be predicted, or, for a given target invasion risk, 

the corresponding target release level could be obtained if there was sufficient data. For the 

purposes of this BE, the ensuing discussion is limited to the prospects of using existing modeling 

efforts to predict the relationship between propagule pressure and risk of ANS establishment. 

In the absence of data and models necessary to support a science-based quantitative 

approach to setting ballast water discharge standards, the NAS (2011) noted that expert opinion 

has been a common alternative. The NAS report discusses the strengths and weaknesses of nonquantitative, expert opinion-based methods for setting ballast water discharge standards. 

6.1.1.2 Population Viability Analysis (PVA) Models 

Population viability analysis (PVA) models are a family of population growth models 

commonly used in the conservation field to predict the extinction probability of endangered 

species (Beissinger and McCullough, 2002; Morris and Doak, 2002). The basic premise of PVA 

models is that any population undergoing stochastic growth has a certain probability of going 

extinct even if it is presently showing positive growth. There is growing recognition that PVA 

models are a potential tool to predict the establishment of ANS (Andersen, 2005). When used 

with ANS, the objective is to predict either the time to extinction or the probability of extinction 

for an invader, where extinction is the converse of establishment. 

6.1.1.3 Use of PVA Models in the USCG Draft Programmatic Environmental 

Impact Statement 

PVA modeling analysis was conducted for the US Coast Guard (USCG) Final 

Programmatic Environmental Impact Statement (FPEIS) (USCG, 2012a) as part of the technical 

analysis used by the USCG in setting their proposed ballast water discharge rule (USCG, 2012b). 

This is the only direct study that EPA is aware of that used a modeling approach to directly 

address ballast water standards. However, as discussed below, the formulation used in the FPEIS 

is not the only possible PVA methodology to addressing the risks associated with ballast 

discharges. 
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A PVA model (Dennis et al., 1991) was used in the risk assessment for single and multispecies ANS invasion scenarios. The strategy taken by the USCG in their FPEIS was to evaluate 

different discharge standards by predicting the relative increase in the probability of extinction of 

the invader based on the fractional reductions in the number of organisms per cubic meter of 

ballast discharge. This is a relative approach and it was not the objective of the FPEIS analysis to 

predict the actual probability of invasion associated with any specific organism. In other words, 

the FPEIS evaluated the reduction in probability of invasion using ballast water treatment 

relative to ballast water exchange, but could not predict the absolute risk of reduction. 

In their analysis, the USCG considered five potential treatment alternatives for the 

>50 micron size group (which includes most holoplanktonic organisms [e.g., calanoid copepods], 

pelagic species such as fish, and larval stages of benthic species). These alternatives ranged from 

No Action (ballast water exchange if vessels can conduct it, but no ballast water treatment), 

through three alternative order-of-magnitude reductions in organism density, to zero organisms 

(complete sterilization). Alternative #1 (No Action) was taken as the baseline against which the 

other alternatives were compared. Ranges in organism concentrations for both un-exchanged and 

exchanged ballast water were used to establish this baseline. Alternative #5 was not formally 

analyzed because no invasions would occur with complete sterilization. 

Lee et al. (2010) reanalyzed the probability of extinction of a single ANS from 10 

identical ballast water discharge events using the same PVA model applied by the USCG in their 

FPEIS. By considering the risk of multiple discharge events, Lee et al. were able to highlight the 

importance of reducing organism concentrations in ballast water on a discharge by discharge 

basis. The key point from consideration of the modeling results is that reductions in the organism 

concentrations in ballast water result in relative, ecologically significant decreases in the 

invasion risk, even for species and environments with a naturally low invasion probability (Lee 

et al., 2010). 

In addition to their analysis of a single species invasion scenario, USCG also used PVA 

modeling to address the probability of invasion by more than one ANS in a ballast discharge. In 

other words, the question the multiple species analysis attempted to address was “What is the 

probability that at least one of the species in a ballast discharge will successfully invade?” The 

conclusion that the USCG drew in their FPEIS from this analysis was that, “The specific 

reduction depends upon the [treatment] alternative selected and the size class of the organism 

considered, but the modeling results for multiple species support the conclusion that more 

stringent treatment alternatives will substantially reduce the likelihood of new ballast water 

introductions” (USCG, 2012a). This particular analysis also emphasized the importance of 

evaluating the total risk potential from multiple species that may be present in ballast discharges. 

6.1.1.4 Recommendations from the National Academy of Science Regarding the Use 

of Risk-Release Models 

In its review of risk-release models, the NAS (2011) noted that the rigorous use of riskrelease models requires that multiple candidate models be formulated and compared in their 

ability to represent the data. This approach, they also note, is well established in the population 

dynamic literature at the single-species scale. However, currently there are insufficient data to 
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distinguish among risk–release relationship models at the multi-species scale. NAS offered a 

number of conclusions and recommendations to identify how models might be put to use at 

present, and in the future, to help inform a numeric discharge standard for ANS in ballast water. 

As noted by the NAS (2011), models of any kind are only as informative as their input 

data. In the case of ballast water, both invasion risk and organism density discharged from ballast 

are characterized by considerable and largely un-quantified uncertainty. At the multi-species 

scale in particular, the existing data (historical invasion records vs. recent ballast surveys) are 

substantially mismatched in time and patchy in time, space, and taxonomy; current statistical 

relationships with these or proxy variables are of dubious value. 

To date, approaches to setting ballast discharge standards have relied primarily on expert 

opinion to evaluate the risk–release relationship (NAS, 2011). On-going research such as what 

has been summarized above provides EPA confidence that the approach of using statistical 

modeling to empirically examine ANS invasion under the risk-release paradigm is a potentially 

viable one, but so far, data are scattered too far across sites and usually too short-term in nature 

to be used in a more definitive manner (NAS, 2011). Clearly several models exist which can 

quantify the risk–release relationship, but sufficient data are lacking. According to the NAS, until 

such a time that key data gaps are filled, risk of invasion cannot be quantified, and therefore, risk 

to listed species from ANS invasion via ballast water also cannot be quantified. 

6.1.2 Reducing Propagule Pressure by Ballast Water Management

Ballast water discharge is a known vector for the spread of ANS, as discussed in 

Section 5.1.1.3. To reiterate from above, the risk of establishment of ANS is assumed to decrease 

with decreasing propagule supply, although the exact quantitative relationship between 

propagule pressure and invasion/establishment risk is unknown for any species, and, in fact, 

likely varies for any species over time and location. Nevertheless, significantly reducing 

propagule pressure will reduce the probability of invasions, when controlling for all other 

variables (NAS, 2011). 

In this subsection, past and present approaches to mitigate ANS propagule pressure in 

ballast water discharge are reviewed. The following approaches, which are ordered both 

chronologically and in terms of reducing propagule pressure, are presented below: 

 No management of ballast water (unmitigated discharge), 

 Interim management pre-2006 (Mandatory Ballast Water Exchange on the Great 

Lakes and Voluntary Exchange Nationwide), 

 Interim management post-2006 (e.g., Mandatory Ballast Water Exchange and 

Flushing on the Great Lakes and Mandatory Ballast Water Exchange Nationwide), 

 IMO/USCG Ballast Water Management (Numerical Discharge Standards), 

 2013 VGP (Numerical Discharge Standards plus Risk-based BMPs), and 

 Potentially more Stringent Numerical Discharge Limits. 

For each mitigation approach, a summary of the literature documenting the reduction in 

propagule pressure is offered. 
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6.1.2.1 No Management of Ballast Water (Unmitigated discharge) 

The introductions of ANS via ballast water discharge became an issue in the late-1980s 

when massive infestations of the ship-mediated zebra mussel (Dreissena polymorpha) and 

Eurasian ruffe (Gymnocephalus cernua) burgeoned in the Great Lakes (NAS, 2011). Propagule 

pressure from unmitigated ballast water discharge is documented in Section 5.1.1.3. The impacts 

of ANS invasion and establishment on native and listed species are discussed in Sections 5.1.1.7 

and 5.1.1.8, respectively. 

In 1990 Congress passed the Nonindigenous Aquatic Nuisance Prevention and Control 

Act of 1990, also known as NANPCA (P.L. 101-646; 16 U.S.C. 4701 et seq.,). NANPCA was 

the first U.S. federal law with the explicit purpose of regulating ballast discharges of ANS (NAS, 

2011). NANPCA required the USCG to issue voluntary guidelines within six months and 

regulations within two years of enactment to prevent new introductions of ANS by ships entering 

the Great Lakes. With these guidelines and regulations, the USCG ushered in the era of ballast 

water management to mitigate the discharge of ANS. 

6.1.2.2 Interim Management Pre-2006 (Mandatory Ballast Water Exchange on the 

Great Lakes and Voluntary Exchange Nationwide) 

Regulations implemented under NANPCA requires ships entering the Great Lakes to 

undertake open-ocean ballast water exchange or use an alternative environmentally sound 

treatment method approved by the USCG that was at least as protective as ballast water 

exchange. Because there were generally no approved alternatives to ballast water exchange, it 

has been the most utilized practice to mitigate ballast mediated transfers of species (by reducing 

the densities of coastal organisms transferred among global regions). 

In general, ballast water exchange operates to reduce the concentration of coastal 

organisms that are transferred among global regions by transferring water from a ship’s ballast 

system to the environment, with concomitant or subsequent uptake of water. Coastal organisms 

are considered less likely to survive under oceanic conditions, and oceanic organisms are 

considered less likely to colonize coastal and inland waters, due to habitat and environmental 

mismatch. Numerous peer reviewed studies and government reports by have shown that midocean ballast water exchange significantly reduces the presence of living organisms adapted to 

surviving in coastal, estuarine, and freshwater environments (Locke et al., 1993; Gray et al., 

2007; McCollin et al., 2007; Ruiz and Reid, 2007). A diverse range of studies, mainly for the 

greater than 50 μm organism size class, demonstrate the efficacy of ballast water exchange on 

the original contents of ballast tanks. The available data suggest the process of ballast water 

exchange removes on average 88 to 99 percent of waterborne contents of ballast tanks when 

performed properly (see review by Ruiz and Reid, 2007). The efficacy of exchange is highest 

when source ports are freshwater locations and lowest when it involves source ports of high 

salinity. For freshwater and estuarine biota, exposure to high salinity waters often also results in 

osmotic shock and mortality, further increasing the efficacy of ballast water exchange (Santagata 

and Ruiz, 2007; Santagata et al., 2008). This combined effect is demonstrated in shipboard 

experiments, which exposed ballast tanks to saltwater (Gray et al., 2007; Bailey et al., 2011). 
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From these experiments it was shown that the mean abundance of freshwater invertebrates, 

measured as the number of individuals per cubic meter, is significantly reduced (>99.99 percent) 

following salt-water flushing. In addition, the variation (standard error) is reduced greatly 

following exchange, further indicating the removal of high density discharges, both for total 

abundance and freshwater species alone. 

Ruiz and Reid (2007) concluded that: “Ballast Water Exchange should be considered a 

useful and beneficial ballast management practice to reduce species transfers and invasion risk. It 

is a valuable measure, especially because it is available now for immediate use on many vessels 

and shipping routes, in the absence of proven alternative treatment methods.” Hence, ballast 

water exchange was an appropriate interim step toward mitigating the risk from the spread of 

ANS until effective treatment technology became available. 

In 2001, the USCG reported to Congress that the proportion of vessels that provided 

information on ballast water management was around 25 percent, too low for a positive 

assessment of compliance with the voluntary guidelines for vessels arriving outside the Great 

Lakes, thus resulting, in accordance with NISA, a transition to a national mandatory regulatory 

program of ballast management (USCG, 2001), with the guidelines being made mandatory in 

July 2004.

The USCG requirements for the management of ballast water are listed in 33 CFR Part 

151, Subparts C (Great Lakes) and D (national). These regulations require vessels transiting to 

U.S. waters with ballast water that was taken on within 200 nautical miles (nm) of any shore into 

waters of the United States after operating beyond the U.S. EEZ to either conduct mid-ocean 

ballast water exchange further than 200 nm from any shore prior to entering U.S. waters, retain 

the ballast water on board while in U.S. waters, or use a USCG approved alternative 

environmentally sound method to manage the ballast water. The regulations also contain a safety 

exception from exchange , providing that the master of a vessel will not be prohibited from 

discharging unmanaged ballast water, in areas other than the Great Lakes and the Hudson River 

north of the George Washington Bridge, if the master decides the practices would be unsafe for 

the vessel (33 CFR 151.2030(b)). In addition, the USCG national regulations state that vessels 

will not be required to deviate from, or delay, their voyage in order to conduct ballast water 

exchange. 

6.1.2.3 Interim Management post-2006 (Mandatory Ballast Water Exchange and 

Flushing on the Great Lakes and Mandatory Ballast Water Exchange 

Nationwide) 

Although ballast water exchange was documented to be highly effective (as discussed 

above in Section 6.1.2.2), invasions by ANS discovered subsequent to ballast water exchange 

requirements on ships entering the Great Lakes, such as by the fishhook water flea (Cercopagis 

pengoi) in Lake Ontario in 1998, suggested that the ballast water vector was still transmitting 

ANS species into the Great Lakes (NAS, 2011). One major cause of continued problems was 

likely incomplete application of ballast water exchange. As explained by Bailey et al. (2011), 

this was due to both changes in commercial shipping practices and deficiencies in understanding 

and effectively regulating ballast water discharges. In the mid-1990s, concurrent with the advent 
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of the first ballast water exchange regulatory program, a large percentage of vessels entered the 

St. Lawrence Seaway laden at least partially with cargo (e.g., steel) (Cangelosi and Mays, 2006), 

such that most vessels had less than 10 percent of their ballast tanks loaded with declarable (i.e., 

pumpable) ballast water (Bailey et al., 2011). Ballast water exchange at that time was considered 

safe and practicable only on fully ballasted tanks (NAS, 2011). The USCG therefore exempted 

ships that were carrying cargo rather than ballast from ballast water exchange. Ships had the 

option of declaring their condition as “No Ballast On Board” (NOBOB) and those that did were 

not subject to any further scrutiny. 

As a consequence, it is possible that some ships laden mostly with cargo but with one or 

more full, un-exchanged ballast tanks declared NOBOB in good faith and proceeded to discharge 

their un-exchanged ballast at ports of call in the Great Lakes in the 1990s and the first half of the 

following decade (NAS, 2011). In addition to the problems attendant to un-exchanged ballast 

water from this minority of full tanks discharged into the Lakes, subsequent studies revealed that 

even the so-called “empty” tanks, carrying only un-pumpable residual water and sediment, 

entrained a diverse but varied flora and fauna, and themselves could be a potentially important 

vector for new invasive species introductions to the Great Lakes (NAS, 2011). These ballast 

residuals were suspected as posing a risk owing to the predominance among vessels associated 

within the foreign trade, the live biota they contained, and the abundance of viable resting stages 

contained in residual sediments (e.g., Bailey et al., 2003; Reid et al., 2007; Bailey et al., 2011). 

In September 2000 a Code of Best Practices for Ballast Water Management for vessels 

entering the Great Lakes was codified by the Shipping Federation of Canada. This Code required 

(among other things) more rigorous ballast water management practices that subject residual 

ballast water to similar flushing practices as filled tanks, to purge and kill live freshwater 

organisms, and to minimize sediment accumulation. In 2002, the twin Seaway authorities—the 

St. Lawrence Seaway Development Corporation (USA) and the St. Lawrence Seaway 

Management Corporation (Canada)—required all foreign flagged vessels to comply with these 

best management practices (BMPs). Transport Canada and the USCG later reinforced these 

regional requirements (NAS, 2011). 

The purpose of mandatory saltwater flushing is to prevent the spread of ANS in ballast 

water tanks that appear empty, but often have unpumpable ballast water and/or residual sediment 

at the bottom of the tanks that may contain organisms which can become ANS. Saltwater 

flushing has been shown to be effective in preventing the introduction of ANS from vessels with 

residual ballast water and sediment in their ballast water tanks. Ruiz and Reid (2007) concluded 

that: “the use of high-salinity water to flush NOBOB ballast tanks should be considered a useful 

and beneficial management practice to reduce species transfers and invasion risks associated 

with NOBOB ships entering the Great Lakes. In the absence of proven alternatives, this practice 

provides some level of protection against some adult and larval life stages.” 

While ballast water exchange and salt-water flushing (in the case of NOBOB tanks) have 

a strong effect in reducing original organisms and appear to significantly reduce the risk of ANS 

invasion and establishment by reducing propagule pressure, including species considered highrisk in the case of the Great Lakes, these practices have shortcomings. Some shipping industry 

stakeholders complained that ballast water exchange was difficult to implement and costly in 
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terms of fuel and carbon emissions; federal officials found ballast water exchange was not able 

to be safely applied by all vessels or all vessel voyages and difficult to enforce; and scientists 

expressed concern that ballast water exchange and flushing were not sufficiently effective or 

consistent in reducing organism concentrations in ballast water, especially in coastal/estuarine 

environments (e.g., Locke et al., 1991; see also summary in Section 4.3.2 of USCG, 2012a). 

In 2006, Canada implemented requirements that all ballast water, including NOBOB 

residual water, be at a salinity of 30 or greater. In 2008, the St. Lawrence Seaway management 

corporations harmonized their entry rules with the Canadian regulations. According to U.S. and 

Canadian officials, as of 2009 there is no unmanaged ballast water entering the Great Lakes, 

including that associated with coastwise vessels. If salinity and flushing requirements are 

consistently applied and enforced for all vessels entering the Great Lakes, it is expected that a 

very significant reduction in the risk of ballast-associated ANS introductions to 

 the Great Lakes will be achieved, especially compared to the risk prior to 2006. However, 

 the risk will not be zero (NOAA, 2012). 

6.1.2.4 IMO/USCG Ballast Water Management (Numerical Discharge Standards) 

In response to the criticism of ballast water exchange and salt-water flushing expressed 

above, national and international efforts began to evaluate other options for managing ballast 

water discharges. Congressional legislation (P.L. 104-332), International Maritime Organization 

(IMO) discussion, the USCG and other federal agencies, and the National Research Council 

(NRC, 1996) began recommending ballast water treatment in lieu of ballast water exchange as 

the best long-term solution to ballast-mediated ANS invasions (NAS, 2011). Concurrently, early 

treatment performance demonstrations suggested that mechanical operation of ballast treatment 

on ships could be feasible and biologically effective (Cangelosi, 1997; Rigby et al., 1997; 

Parsons and Harkins, 2002). Ultimately, a key decision was made to base ballast water discharge 

standards on the concentration of organisms in discharged ballast water, rather than on the 

percentage of ballast water exchanged during mid-ocean exchanges. This was first expressed in 

the IMO’s International Convention for the Control and Management of Ships' Ballast Water and 

Sediments, 2004). The convention was negotiated to reduce the spread of ANS through ballast 

water transport (IMO, 2004a). 

The IMO treaty identifies two key standards (in Regulations D-1 and D-2. D-1 is a ballast 

water exchange standard, requiring at least 95 percent volumetric exchange for empty-refill-style 

exchange, and three times the tank volume for vessels that conduct flow-through exchange. The 

D-2 standard sets maximum permissible limits on live organisms in ballast effluent, based on the 

size or taxonomic category of organisms. The latter (D-2) standard states that ships conducting 

ballast water management shall discharge: 

 Less than 10 viable organisms per m3

, for organisms greater than or equal to 50 μm in 

minimum dimension; 

 Less than 10 viable organisms per mL, for organisms less than 50 μm in minimum 

dimension and greater than or equal to 10 μm in minimum dimension; and 

 Discharge of the indicator microbes shall not exceed the specified concentrations. The 

indicator microbes, as a human health standard, include: 
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o Toxicogenic Vibrio cholerae (O1 and O139) with less than 1 colony forming unit 

(CFU) per 100 mL or less than 1 CFU per 1 gram (wet weight) zooplankton 

samples; 

o Escherichia coli with less than 250 CFU per 100 mL; 

o Intestinal enterococci with less than 100 CFU per 100 mL. 

The size classes contained in the IMO standard roughly coincide with taxonomic groups 

of plankton (i.e., zooplankton and phytoplankton for the larger and smaller class sizes, 

respectively) in marine systems. 

A suite of studies have examined the environmental protection offered by the IMO 

discharge standard, and all of them indicate a reduction in risk associated with that standard from 

no ballast water management or ballast water exchange (see summary by Lee et al., 2010 or NAS 

2011). EPA also notes that treatment to the IMO discharge standard will result in a significant 

decrease in the concentration of living organisms discharged from ballast tanks for the vast 

majority of vessels applying treatment. Several studies have looked at the composition of living 

organisms found in ballast water tanks for some or all organisms greater than 50 μm; comparing 

the results for this size class (50 μm) meeting the VGP’s permit limits to the values in untreated 

ballast water illustrates that there would be a substantial decrease in inoculum density after 

treatment. For example, for each of the studies discussed below, EPA derived the percentage that 

the discharge concentration would be reduced from the mean, median, or mode values 

(dependent on the study and how the authors present the data). This percent reduction is 99.67% 

to 99.94% from mean and mode values presented in Minton et al. (2005), 99.63% from median 

values presented in Bailey et al. (2011), 99.994% from mean values presented in David et al. 

(2007), 95.15% from mean values presented (Murphy et al., 2002), and 99.93% from mean 

values presented in Verling et al. (2005). The maximum values presented by the authors show 

considerably more notable reduction; this is noteworthy because EPA assumes that these high 

concentration discharge events pose more risk. The discharge concentration would be reduced 

from the maximum value presented by 99.98% to 99.99% from the range of mean and upper 

1.1% of density values presented in Minton et al. (2005), 99.96% from the range of median 

values presented in Bailey et al. ( 2011), 99.999% from the range of mean values presented in 

David et al. ( 2007), 99.41% from the range of mean values presented Murphy et al. (2002), and 

99.97% from the range of mean values presented in Verling et al. (2005). 

One specific study, (Bailey et al., 2009) evaluated the efficacy of such limitations through 

the use of mesocosm experiments and modeling of certain parthenogenetic taxa (i.e., organisms 

that reproduce asexually) that are of significant concern for invasion to the Great Lakes. In this 

study, the authors concluded that the proposed IMO standards for >50 μm organisms would 

reduce the probability of establishment of certain parthenogenic species by three fold. Even 

taking a “precautionary approach by deliberately investigating establishment success under 

favorable physical, chemical, and biological conditions (e.g., reduced competition and predation 

inside enclosures)” results in “best fit estimates of establishment probabilities for inocula less 

than 10 individuals per cubic meter [that] are nil, indicating that the proposed ballast water 

discharge standards [the IMO standard] will be very effective even for parthenogenetic taxa” 

(Bailey, 2009). 
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6.1.2.5 2013 VGP 

EPA is proposing new, more stringent numeric technology-based effluent limitations to 

replace the non-numeric limitations in the 2008 VGP for ballast water in the 2013 VGP. The 

reader is referred to Section 2.3.1.4 and Appendix C for a summary of the ballast water discharge 

provisions of the proposed VGP. The ballast water discharge standard in the 2013 VGP will 

achieve significant reductions in the number of living organisms discharged via ballast water into 

waters subject to this permit, in comparison to ballast water exchange and flushing and 

IMO/USCG Ballast Water Management (discussed above), thereby reducing risk of the spread of 

aquatic nuisance species. 

EPA is proposing numeric TBELs for the discharge of living organisms equivalent to the 

USCG discharge standard (USCG, 2012b), which is generally equivalent to the standard set forth 

in Regulation D-2 of the IMO standard. EPA has set the numeric effluent limit for ballast water 

as numbers of living organisms per cubic meter discharged (i.e., as a maximum acceptable 

concentration) because reducing the concentration of living organisms will reduce inoculum 

densities of potential invasive species discharged in a vessel’s ballast water. 

EPA has established the VGP permit limits because several treatment technologies have 

been shown to be safe, reliable and effective at reducing viable living organisms in ballast water 

discharges to meet these limits. Furthermore, it has been demonstrated that several of these 

technologies are commercially available for shipboard installation and their use is economically 

achievable. Several studies and publications are available that discuss current treatment 

technologies, their efficacy and performance, and whether they are commercially available for 

shipboard installation (ABS, 2010; Albert et al., 2010; CSLC, 2010; GLBWC, 2010; Lloyd’s 

List, 2010; WDNR, 2010; SAB, 2011; Dobroski et al., 2011). Establishment of a ballast water 

discharge limit at the USCG / IMO discharge standard will result in a substantial reduction in the 

concentration of living organisms in the vast majority of ballast water discharges, compared to 

discharges of ballast water managed by mid-ocean exchange or discharges of un-exchanged 

ballast water. 

In addition, EPA has determined that the numeric limitations in the proposed VGP 

represent the most stringent standards that ballast water management systems currently safely, 

effectively, credibly, and reliably meet (SAB, 2011). The NAS (2011) recommended that: “as a 

logical first step, a benchmark discharge standard should be established that clearly reduces 

concentrations of coastal organisms below current levels resulting from ballast water exchange 

(such as the IMO D-2 standard). This will serve to reduce the likelihood of invasion in coastal 

ecosystems beyond that of the present time.” EPA concurs with the NAS study that such 

limitations will result in significant reductions in concentrations of living organisms beyond 

current management practices (i.e., ballast water exchange and the other management practices 

described in the permit). The numeric discharge limitations for ballast water in the proposed 

permit are expected to be effective in reducing the risk from untreated or exchanged ballast water 

discharges. EPA expects that compliance with the permit’s numeric effluent limitations will 

likely result in discharges that are controlled as necessary to result in a very small absolute risk 

of invasion and thus are controlled as necessary to achieve applicable water quality standards. 
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SAB (2011) noted that integrated sets of practices and technologies can be used to 

systematically advance ballast water management. These practices include managing ballast 

uptake to reduce the presence of invasive species, reducing invasion risk through operational 

adjustments and changes in ship design to reduce or eliminate the need for ballast water, 

development of voyage-based risk and/or hazard assessments, and treatment of ballast water in 

onshore reception facilities. Consistent with this recommendation, EPA has included 

management practices in the proposed VGP that reduce risks from ballast water at multiple 

points in the vessel voyage. 

As in the 2008 VGP, EPA has included BMPs applicable to all vessels equipped with 

ballast water tanks that enter or operate within waters subject to this permit. These BMPs are 

designed to reduce the number of living organisms taken up in, and later discharged in, ballast 

water or to ensure that such discharges do not occur in known sensitive areas. Examples of these 

BMPs include avoiding or minimizing ballast water uptake in areas recognized as having a high 

potential to contain harmful organisms, only discharging the minimum amounts of ballast water 

necessary in coastal and internal waters, and regularly cleaning ballast water tanks to remove 

sediment. 

Like the 2008 VGP, the proposed 2013 VGP does not authorize the discharge of 

sediments from the cleaning of ballast tanks. Hence, the discharge of sediment removed from 

tanks by cleaning operations into waters subject to the permit, including the discharge of 

sediments suspended as a result of ballast tank cleaning, are prohibited from being discharged 

into waters covered by this permit and must be disposed of in accordance with any applicable 

local, State, and Federal regulations. 

6.1.2.6 Feasibility of More Stringent Numerical Discharge Limits for the 2013 

issuance of the VGP 

Though California and other states had previously adopted or proposed standards with the 

goal of “zero detectable living organisms” in ballast water discharges, EPA did not find that 

technologies were available which met limits more stringent than the IMO standard. The 

California State Lands Commission (CSLC) report: i.e., 2010 Assessment of the Efficacy, 

Availability, and Environmental Impacts of Ballast Water Treatment Systems for use in 

California Waters (CSLC, 2010; Dobroski et al., 2011) discusses that States treatment limits and 

the ability of existing treatment systems to meet those limits. California’s standards would be 

adopted in two phases, with an interim standard of “no detectable living organisms” >50 μm in 

ballast discharged from ships constructed in 2010 to 2012, and a final standard in 2020 of “no 

detectable discharge” of zooplankton, phytoplankton, protists, bacteria, or viruses in ballast 

discharges for ships constructed beginning in 2020. 

EPA notes that the CSLC report has served a role in consolidating summary data 

regarding the efficacy of ballast water treatment systems (BWTS) and stating its conclusions 

from those data. However, the methodology employed by the State of California is not adequate 

to determine whether any of the treatment systems can reliably meet a significantly more 

stringent limit than that proposed for the term of the 2013 VGP. EPA believes that the data 

California reviewed for their evaluation of ballast water treatment systems were generally from 
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tests to determine whether systems could meet the IMO limits, and do not have significant 

precision or resolution to detect efficacy significantly beyond those limits. As noted by the SAB 

(2011): “current methods (and associated detection limits) prevent testing of BWTS to any 

standard more stringent than D-2 and make it impracticable for verifying a standard 100 or 1000 

times more stringent.” Hence, EPA does not believe that the report can be used to support the 

assertion that technologies are available to meet a limit 100 or 1000 times more stringent than 

IMO. In fact, until better shipboard testing methods are developed, there is no way to efficiently 

detect organisms present in low concentrations (e.g., at or below the IMO standard) from a 

shipboard discharge. This means that, in practice, the “no detectable living organism standard” 

proposed by California is no more stringent than the IMO standard at this time. This conclusion 

is supported by the 2011 NAS report, which states that the zero-detectable organism standard “is 

functionally defined by the ability to characterize concentrations of organisms at low densities” 

and that the exact California discharge standard “is largely undefined and contingent on 

sampling protocols.” 

EPA believes that the work done recently by numerous scientists (Drake et al., 2005; 

USCG, 2012a; Lee et al., 2010) has greatly improved our understanding of the risk posed by 

ballast water discharge events, and acknowledges that some have even gone so far as to clearly 

quantify a relative reduction in risk by using various standards versus ballast water exchange 

(USCG, 2012a). However, EPA also agrees with the NAS (2011) that establishing a precise, 

quantified ballast water discharge standard more stringent than the numeric TBELs contained in 

Part 2.2.3.5 of the VGP at this time is not possible with available data and information, and thus, 

numeric water quality-based effluent limits are infeasible to calculate. 

6.1.2.7 Evidence Supporting Effectiveness of Ballast Water Management 

Evidence supporting the effectiveness of ballast water management as a means of 

preventing ANS introductions from this vector comes from the Bailey et al. (2011) study, which 

examined the efficacy of ballast water policies enacted to prevent biological invasions in the 

Laurentian Great Lakes. Bailey et al. (2011) analyzed 20 years of Great Lakes ANS invasion 

data post ballast water regulation, by assembling data on dates of discovery of ship-mediated 

ANS reported in the Great Lakes after the opening of the modern St. Lawrence Seaway in 1959. 

The cumulative and annual numbers of ANS discovered over time was graphed and visually 

inspected to determine if the rate of discovery changed after implementation of ballast water 

regulations. The authors acknowledged that their analysis of ANS discovery rate was 

confounded by time lags (the gap between the date of introduction and the date of discovery), 

inconsistent research effort, taxonomic bias, and insufficient data. 

The analysis conducted by Bailey et al. (2011) revealed 34 aquatic ship-mediated ANS 

reported from the Great Lakes after 1959.The rate of ANS discovery was relatively linear 

between 1959 and the mid-1980s, after which time it began to increase. The peak number of 

discoveries occurred in 1992 when six ANS were reported, including five parasitic species 

associated with the Eurasion ruffe; the discovery rate begins to decline rapidly after the peak. 

1995 was identified as the most likely point of decline in discovery rate. This date may 

correspond with a six year time lag after the inception of voluntary ballast water management in 

1989, or a two year time lag after implementation of mandatory ballast water exchange 
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regulations. Since 2000, shipping activities have been responsible for three of eight (37.5%) 

ANS introductions. No new ANS have been reported since 2006, the first time there has been a 

four-year gap in ship-mediated ANS discoveries since 1974-1977, indicating that NOBOB tank 

flushing regulations may have been an important component of ANS mitigation via the ballast 

water vector. Since Bailey et al. (2011) published this study, the authors of this biological 

evaluation are unaware of any new invasions in the Great Lakes. 

The comprehensive assessment of the Great Lakes’ ballast water management program, 

using multiple lines of evidence, indicates that the risk of ship-mediated ANS introductions has 

been markedly reduced (Bailey et al., 2011), because: 

 Comprehensive laboratory and shipboard studies indicate that ballast water exchange 

and tank flushing can effectively decrease the number of viable propagules in ballast 

tanks. Modeling indicates that the combined effects of tank purging and osmotic 

shock are typically 99.993% effective at removing or exterminating freshwater 

zooplankton from being transported between freshwater ports. 

 Biological monitoring data confirms that at the operational level, ballast water 

exchange and flushing significantly reduce the probability for rare, high density, 

introduction events and nearly eliminate high risk taxa. 

 Compliance rates by the general vessel population appear very high, perhaps a direct 

result of the intensive inspection regime. Only 4.2% of approximately2850 tanks 

tested in 2007 contained ballast water with a salinity <30% and, because they were 

detected by inspectors, were prohibited from being discharged into the Great Lakes; 

and 

 Examination of the discovery rate of ANS in the Great Lakes basin supports a decline 

in ship-mediated introductions following the initiation of the ballast water 

management program. 

Bailey et al. (2011) acknowledge that ballast water can transport a variety of active and 

dormant taxa, ranging from microbes and bacteria to fishes and large sessile invertebrates. A 

complementary study examining efficacy of tank flushing on dormant invertebrate eggs in ballast 

sediments under operational conditions (see Briski et al., 2010) found significant reductions in 

total egg density, viable egg density, and density of eggs of high risk ANS. Unfortunately, a 

dearth of data precludes assessment of the Great Lakes ballast water management regulations 

with respect to other taxa. Even so, it is clear that the prescribed management strategies will not 

provide complete protection against aquatic invasions, since a large percentage reduction can 

still result in substantial propagule pressure if initial densities were high (Bailey et al., 2011). 

Total propagule pressure, however, is not reflective of the effective invasion risk for Great Lakes 

ports, since many marine taxa will not be able to survive if introduced into fresh water. While 

these data are promising, they are not conclusive in demonstrating that ballast water exchange 

and salt-water flushing alone are sufficient to prevent ANS invasion due to a number of factors. 

For example, as noted by Bailey et al. (2011), analyses of discovery rate are confounded by time 
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lags (where there is a gap between the date of introduction and the date of discovery), 

inconsistent research effort, taxonomic bias and insufficient data. 

6.1.2.8 Effectiveness of Ballast Water Exchange and Flushing to Reduce Propagule 

Pressure in Fresh Waters vs. Coastal Waters (no osmotic shock benefit) 

Ballast water exchange and saltwater flushing is most effective at eliminating organisms 

adapted to freshwater and low salinity environments due to the combined impacts of saltwater 

shock and physical dilution. In the case of vessels arriving to the Great Lakes, with tanks having 

been exposed to seawater by ballast water exchange, many or most of the waterborne organisms 

are likely to be marine species which are less likely to successfully colonize the Great Lakes 

relative to freshwater biota. However, many freshwater species produce resting stages (e.g., 

cysts, resting eggs, ephippia) that may survive ballast water exchange and be present in ballast 

sediments (e.g., Fahnenstiel et al., 2009; Gray and MacIsaac, 2010). Likewise, some diatoms can 

live for decades or longer in anoxic sediments and are unlikely to be affected by osmotic shock 

associated with saltwater flushing or ballast water exchange (Stoermer, E. personal 

communication, October 25, 2010 cited in NAS, 2011). 

Ballast water exchange and saltwater flushing may reduce viable living organisms in 

residual ballast water through dilution. Secondly, saltwater flushing reduces the number of viable 

living organisms and organisms in resting stages in the residual sediment. However, the efficacy 

of ballast water exchange and saltwater flushing is likely lower when it involves source and 

recipient ports of high salinity, as there is no added benefit of “osmotic shock” to residual 

organisms. In such cases, without added mortality, Minton et al. (2005) estimated that vessels 

implementing ballast water exchange/saltwater flushing would still deliver more than one million 

coastal zooplankton alone from the original source per discharge event. The numbers are greater 

for smaller organisms, simply because their densities in ballast tanks are much greater than those 

for zooplankton. 

Numerous studies have indicated that ballast water exchange and saltwater flushing 

significant reduction in risk for ballast water discharges. Ballast water management strategies 

have resulted in overall reductions in propagule pressure and, therefore, also in reducing the risk 

of ANS establishment in US waters. In this context, implementation of the ballast water 

treatment standards in the new VGP will further reduce the likelihood of ANS invasion and 

establishment as these are expected to provide a higher degree of protection than ballast water 

exchange and saltwater flushing. 

6.1.3 Reducing Propagule Pressure by Biofouling Management

Biofouling of vessel hulls, recessed areas, seawater cooling systems, etc. has been 

identified as an important pathway for the spread of ANS, as discussed in Section 5.1.1.4. The 

risks from vessel biofouling are principally associated with the release of competent life stages of 

ANS from the vessel into an environment in which it does not already occur (Floerl et al, 2010). 

Competent life stages are those that are capable of establishing self-sustaining populations and 

could be adult life-stages, gametes, larvae or vegetative fragments (Grahame and Branch, 1985; 

Santelices, 1990; Ceccherelli and Cinelli, 1999). The likelihood of this happening in a given 
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receiving water body is influenced by factors such as local environmental conditions, the 

reproductive state of the organisms, and the length of time the vessel spends in port (Apte et al., 

2000; Minchin and Gollasch, 2003). Left unmanaged, a fouled vessel can pose an elevated ANS 

risk through the detachment and dispersal of viable material, and through spawning by adult taxa 

upon arrival in a recipient port or region. 

Mitigating the ANS risks associated with vessel biofouling has proven challenging. Laws 

and management frameworks addressing hull husbandry vary widely between jurisdictions 

(Floerl et al, 2010), because there is little information on the efficacy of management strategies 

for controlling the biofouling ANS vector, and because the technologies employed in several hull 

husbandry practices (including use of anti-fouling coatings (AFCs) and underwater hull 

cleaning) continue to evolve. Coordination is needed, for example, to resolve conflicts between 

policies to control hull-borne ANS via hull fouling and reduction of the release of toxic biocides 

(e.g., copper) from anti-fouling paint. 

EPA recognizes that vessel hulls and hull appendages are a potential source for the spread 

of ANS and has included requirements in the permits to address these sources. Vessel 

owner/operators must minimize the transport of attached living organisms when they travel into 

waters subject to this permit from outside the U.S. economic zone or when traveling between 

COTP zones. Minimization techniques include preventing the hull from fouling using 

appropriate anti-foulant paint and frequently removing fouling organisms from the hull. 

The 2011 IMO Guidelines for the Control and Management of Ships' Biofouling to 

Minimize the Transfer of Invasive Aquatic Species (Annex 26 Resolution MEPC.207(62)) are 

intended to provide a globally consistent approach to the management of biofouling. As noted by 

the IMO Guidelines, implementing practices to control and manage biofouling can greatly assist 

in reducing the risk of the transfer of ANS. According to the Guidelines, a ship should 

implement biofouling management practices, including the use of anti-fouling systems and other 

operational management practices to reduce the development of biofouling, to minimize the 

transfer of ANS. The intent of such practices is to keep the ship's submerged surfaces, and 

internal seawater cooling systems, as free of biofouling as practical. A ship following this 

guidance and minimizing macrofouling would have a reduced potential for transferring invasive 

aquatic species via biofouling. 

There are many different practices involved with effectively controlling biofouling and 

ANS prevention. For example, the selection, application, and maintenance of effective AFCs are 

primary practices for controlling biofouling on vessel hulls. ANS biofouling risks can be 

managed effectively through the removal of the vessel to land for de-fouling (e.g., drydocking). 

However, alternative methods are needed for small vessels, as well as for large vessels fouled 

outside their drydocking schedule. Among the various treatment options, the underwater 

cleaning of vessel hulls and niche areas is relatively common. 

It has been suggested that underwater cleaning may enhance the release of competent life 

stages through direct dislodgement from the vessel or by triggering reproductive activity that 

causes propagules to be released (e.g., see Hopkins and Forrest, 2008, and references therein). 

However, there is little empirical evidence that propagules released in this manner are 
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competent. These propagules can be released or can detach from the vessel even when no 

cleaning is taking place. 

In the 2013 VGP, EPA requires and recommends several BMPs to minimize the 

likelihood of ANS introduction from vessel biofouling. The VGP includes specific requirements 

regarding hull husbandry and BMPs designed to mitigate the biofouling vector. These include, 

but are not limited to, the selection of effective AFCs (Section 6.1.3.1), the drydock or 

underwater cleaning of vessel hulls and niche areas (Section 6.1.3.2), and management of 

biofouling in seawater cooling systems (Section 6.1.3.3). 

6.1.3.1 Reducing the Biofouling Vector by Selection of Appropriate AFCs 

Anti-fouling systems and operational practices are the primary means of biofouling 

prevention and control for existing ships' submerged surfaces, including the hull and niche areas, 

according to the 2011 IMO Guidelines. An anti-fouling system can be a coating system applied 

to exposed surfaces, biofouling resistant materials used for piping and other unpainted 

components, marine growth prevention systems (MGPSs) for sea chests and internal seawater 

cooling systems, or other innovative measures to control biofouling. 

EPA has identified three types of BMPs related to AFCs for control of ANS from vessel 

hulls. The first type of BMP addresses the contents and application of the coating. EPA 

recognizes that different coating options are available and believes that the types of active agents 

in hull coatings should be selected to maximize efficacy, while minimizing other potential 

adverse effects (e.g., minimizing copper leachate and eliminating TBT release). The practice of 

applying coatings according to the instructions on the coating’s FIFRA label should currently be 

a BMP for all vessels. 

The second type of BMP addresses the need for particular coatings and selection of the 

type of coating to apply. The selection of an anti-fouling system for a particular vessel must be 

made in consideration of the vessel’s operational profile, including operating speed, dry docking 

requirements, and the waters in which the vessel will be operating, because such factors affect 

the fouling rate of the hull and other underwater areas of the vessel. Fouling on vessels that 

typically operate at high speeds may be effectively managed with non-stick, low surface energy, 

AFC. Vessels traveling in waters with lower fouling pressure (i.e., reproduction and growth of 

hard- and soft-fouling organisms) and those that spend less time at dock are expected to have a 

lower fouling rate; consequently, such vessels should be able to use either non-biocidal coating 

or AFC with lower biocide release rates. The permit requires that vessel operators minimize the 

use of AFC that are designed to control fouling in higher fouling-pressure environments than 

those in which the vessel is expected to operate. EPA believes these options should be used 

where feasible rather than opting for more environmentally-damaging coatings. 

The third type of BMP is accomplished by matching the coating’s abilities or strength to 

dry dock cycles. Larger vessels, particularly those used in trade and cargo transport, must adhere 

to requirements for safety inspections and maintenance activities that dictate how frequently they 

must be dry docked. The major manufacturers of hull coatings for this industry will typically 

guarantee the effectiveness of their products for a certain period of time based on ship and 
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operational characteristics, so the owner/operator should match the hull coating choice to the 

appropriate dry docking interval. By factoring this schedule into the hull coating selection, EPA 

believes that vessel operators will make better decisions regarding the use of coatings that will 

sufficiently protect the vessel for the period of time needed without creating additional leachate 

or wastes. 

6.1.3.2 Reducing Propagule Pressure from Underwater Cleaning 

Despite the use of effective anti-fouling systems and operational practices, undesirable 

amounts of biofouling may still accumulate during the intended lifetime of the anti-fouling 

system. To maintain a ship as free of biofouling as practical, it may be advisable for the ship to 

undertake in-water inspection, cleaning and maintenance. In-water inspection can be a useful and 

flexible means to inspect the condition of anti-fouling systems and the biofouling status of a ship. 

According to the IMO Biofouling Guidelines, in-water inspections should be undertaken 

periodically as a general means of routine surveillance, augmented by specific inspections as 

necessary to address any situations of elevated risk. Specific occasions when an in-water 

inspection may be appropriate, include the following: 

 Before and after any planned period of inactivity or significant or unforeseen change 

to the ship's operating profile; 

 Prior to undertaking in-water cleaning to determine the presence of known or 

suspected invasive aquatic species or other species of concern on the ship; 

 After a known or suspected marine pest or other species of concern is discovered in a 

ship's internal seawater cooling systems; and 

 Following damage to, or premature failure of, the anti-fouling system. 

The results of in-water biofouling inspection may indicate the need for cleaning or 

defouling of the vessel’s hull and/or niche areas. In the VGP, EPA recommends that extensive 

hull cleaning be conducted when the vessel is in drydock or when the byproducts of the cleaning 

can be contained and disposed of properly, especially when cleaning hulls using water pressure 

based systems. This VGP further encourages all waste to be collected and disposed of properly to 

ensure that it is not washed into nearby waters. While these practices do not specifically address 

the release of anti-fouling materials from hulls during vessel operations (i.e., hull coating 

leachate), they are critical to controlling levels of contaminants that result in the same type of 

environmental degradation. In addition, these same practices are likely reduce the potential for 

release of ANS during hull cleaning and paint preparation activities, because fouling organism 

fragments (which may be viable propagules) removed by hydroblasting or other cleaning 

techniques can be contained with the particulate debris (paint chips, corrosion, sediment) 

generated by hull cleaning (Floerl, 2005). 

Between drydocking intervals, underwater cleaning can be an important part of 

biofouling management; however, it may also introduce different degrees of environmental risk, 

depending on the nature of biofouling (i.e. microfouling versus macrofouling), the amount of 

anti-fouling coating system residue released and the biocidal content of the anti-fouling coating 

system. Hull cleaning and repair activities conducted on the water can cause the release of a wide 

range of constituents, including elements of the vessel hull; hull coatings; cleaning agents; and 
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any ANS that are attached to and are associated with the hull and other submerged areas of the 

vessel. Relative to macrofouling, microfouling can be removed with gentler techniques that 

minimize degradation of the anti-fouling coating system and/or biocide release. Microfouling 

removal may enhance a ship's hull efficiency, reducing fuel consumption and greenhouse gas 

emissions. It is, therefore, recommended that the ship's hull is cleaned when practical by 

soft methods if significant microfouling occurs. In-water cleaning can also reduce the risk of 

spreading ANS by preventing macrofouling accumulation. 

Relatively few studies investigating the effectiveness of hull cleaning in mitigating ANS 

have been conducted and published. To examine the ANS risks posed by various hull cleaning 

operations, researchers from the New Zealand National Institute of Water and Atmospheric 

Research (NIWA) visited hull cleaning facilities in four New Zealand ports where vessels were 

removed from the water for cleaning (drydock and haul-out facilities) or where fouling 

organisms were removed underwater by divers (Floerl, 2005). In all of the cleaning operations 

examined, physical removal of fouling assemblages from vessel hulls did not result in mortality 

of all organisms. The overall viability of organisms removed from hulls was lowest in haul-out 

facilities (16 %) and drydock facilities (43 %), where fouling organisms were often exposed to 

air, high-pressure freshwater blasting and trampling. NIWA staff noted that survival viability 

was high for (1) hard-bodied organisms not directly attached to hull surfaces (epibiota), and (2) 

organisms associated with clumps of mussels in the protected sea chests of large ships. Survival 

and viability of organisms following underwater cleaning by divers, which did not involve 

exposure to air or high-pressure water blasting, was significantly higher (72 %) than in shorebased operations. 

EPA has not identified an alternative to underwater ship husbandry, a viable treatment 

technology, or specific practices that will eliminate all releases of contamination. To limit such 

releases to the maximum extent possible, the Agency is requiring that vessel operators employ 

removal and cleaning methods that reduce the environmental impacts due to releases of biocides, 

hull coating materials, and invasive species. EPA has determined that use of soft brushes when 

cleaning hulls reduce the release of paints and hull materials; hence, the softest brush practicable 

to effectively remove fouling from the vessel hull must be selected and used for underwater 

cleaning. Furthermore, when available, EPA recommends that vacuum cleaning technologies be 

employed in conjunction with mechanical scrubbing to reduce releases of environmental 

contaminants. Vacuum cleaning allows the materials scrubbed from the vessel hulls to be 

collected and disposed of onshore. These approaches are not widely commercially available; 

hence, EPA has not required that they must be used in this permit. 

The thorough examination of the vessel that occurs while it is in drydock provides 

owners/operators with an additional opportunity to implement the permit's requirements. For 

example, cleaning the vessel hull of attached organisms is much easier in drydock, and is safer 

for the environment because any attached organisms can be properly disposed of away from 

water, minimizing the risk of an introduction of ANS. Dry dock cleaning is the preferred 

alternative to underwater ship husbandry whenever possible. 
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6.1.3.3 Management of Biofouling in Seawater Cooling Systems 

Vessels often have specialized marine growth protection systems (MGPSs) installed in 

their sea chests to eliminate biofouling in seawater circulation systems. Through the use of 

strategically placed anodes and cathodes, incoming seawater is electrolyzed with either copper or 

hypochlorite ions, depending on the manufacturer. The resulting solutions provide an 

inhospitable environment for fouling organisms. According to the IMO Biofouling Guidelines, 

the installation of MGPSs is encouraged to assist in treating the sea chest and internal seawater 

piping as part of the biofouling management plan. A careful evaluation of the consequential 

effects of MGPSs should be made before installation, including potential effects on the ship 

and/or the environment and the existence of regulations affecting the use of MGPSs.

Coutts et al. (2003) found not only typical fouling organisms, but also such surprising 

finds as the introduced European clam (Corbula gibba), and three introduced Green crabs 

(Carcinus maenas), two of which were ovigerous females capable of releasing viable propagules, 

were found in vessel sea chests. The same paper also mentions that the unique habitat provided 

by a sea-chest has yielded an invasive sea-star, Asterias amurensis, and several species of small 

fish. In a later paper, Coutts and Dodgshun (2007) found that while MGPS systems significantly 

reduce fouling by sessile and sedentary organisms, the systems have little influence on the 

occurrence of mobile species within sea-chests; therefore, MGPS may reduce, but not eliminate 

entirely, the risk of sea-chests as vectors for introductions. 

The requirements of the 2013 VGP reinforce current environmental regulations 

established under FIFRA. Under the permit, biofouling chemicals for seawater piping must be 

used according to their FIFRA label and are prohibited from discharge if they are banned for use 

in the U.S. Vessel owner/operators must use the minimum amount of biocide needed to keep 

fouling under control. 

6.1.4 Control of ANS Discharges in Chain Locker Effluent and Fish Hold Effluent

The VGP includes BMPs to control the discharge of ANS release from chain locker 

effluent and, where they may be relevant, fish hold effluent. Although these discharges are not 

generally considered to be significant vectors of ANS introduction, requirements in the 2013 

VGP reduce the limited risk of ANS introduction they pose. 

BMPs to reduce or eliminate chain locker effluent discharge require the vessel operator to 

ensure the chain itself is properly cleaned when brought out of the water to reduce the likelihood 

of transporting marine organisms and sediment. This practice is typically performed by vessels, 

using their firemain system, to remove sediments and other material. However, EPA believes 

vessel operators should use this practice routinely and be advised to perform more thorough 

wash downs to effectively prevent the transport of marine organisms between water bodies. 

Additionally, EPA is requiring ocean-going vessels to clean out, rinse, or pump out chain 

lockers in open waters (greater than 50 nm from shore), if technically feasible, to reduce the 

chances of transporting organisms to other water bodies where they may cause potential harm. 

Vessels that leave waters subject to the permit at least once per month are not allowed to rinse or 
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pump chain lockers in waters subject to the permit, unless not doing so would compromise 

safety. 

Fish hold effluent also has the potential to introduce ANS into receiving waters from fish 

waste or water transported from one port to another. The effluent limits in the 2013 VGP are 

designed to reduce the amount of fish hold effluent discharged into enclosed, sensitive, or 

heavily trafficked water bodies, such as in ports, and to lessen the environmental impact of fish 

hold effluent that is discharged. The requirement to physically separate excess fish waste from 

fish hold effluent prior to discharge will reduce the amount and concentration of the discharge. 

EPA has also prohibited the discharge of fish hold effluent pierside where shore based facilities 

are available: where they are available, vessels must utilize these facilities. This requirement will 

reduce fish hold effluent discharges at piers. This permit also prohibits discarding unused bait 

overboard, unless the bait was caught in that water body or watershed. This requirement will 

help to prevent the spread or dispersal of potentially invasive species if the bait is invasive 

species or is contaminated with invasive pathogens. 

6.1.5 Inspection, Monitoring, Reporting and Recordkeeping

Many class societies and the United States Coast Guard require that the vessel operator 

conduct drydock inspections before relaunching the vessel. Based on discussion with technical 

experts, EPA assumes most, if not all vessels currently must undergo drydock inspections, and 

EPA requires the vessel to maintain a drydock inspection report as a record. When a vessel is in 

drydock, it is much easier to access a wide range of areas on the vessel that are not easily 

accessible while the vessel is in water. The thorough examination of the vessel that occurs while 

it is in drydock provides owners/operators with an additional opportunity to implement the 

permit's requirements. As previously mentioned, cleaning the vessel hull of attached organisms 

is much easier in drydock. It also poses lower risk of releasing organisms from the hull into 

surrounding waters because any attached organisms can be disposed of shoreside (away from 

receiving waters), minimizing the risk of an introduction of ANS. For any drydock report, the 

permit requires that it include confirmation that the chain locker, hull, and cathodic protection 

have been inspected and cleaned, that anti-fouling hull coatings are maintained and applied in 

accordance with the permit's requirements, and that all pollution control equipment is maintained 

and properly functioning. 

The 2013 VGP includes requirements for inspection, monitoring, reporting and 

recordkeeping of vessels and their operations. Many of these requirements are relevant to efforts 

to mitigate and control the discharge of ANS via ballast water discharge, biofouling, and other 

discharges as described above. Comprehensive vessel inspections must be conducted by 

qualified personnel at least once every 12 months, and cover all areas of the vessel affected by 

the requirements in the VGP that can be inspected without forcing a vessel into dry dock. Special 

attention should be paid to those areas most likely to result in discharges that have the potential 

to violate effluent limits established in the VGP. Inspectors must examine the vessel hull for 

attached living organisms, as well as flaking anti-foulant paint, exposed TBT or other organotin 

surfaces. Vessel owner/operators must also make any drydock reports prepared by the class 

society or their flag administrations available to EPA or an authorized representative of EPA 

upon request. Relevant to ANS, the drydock report must note that: 
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 The chain locker has been cleaned for both sediment and living organisms; 

 The vessel hull, propeller, rudder, thruster gratings, sea chest, and other surface areas 

of the vessel have been inspected for attached living organisms and those organisms 

have been removed or neutralized; and, 

 Any antifoulant hull coatings have been applied, maintained and removed consistent 

with the FIFRA label, if applicable; any exposed existing or any new coating does not 

contain biocides or toxics that are banned for use in the United States. 

6.1.6 Measures in the sVGP to Reduce Risk from ANS

The new sVGP also includes management measures to mitigate ANS discharges from 

small vessels. These include vessel hull maintenance, fish hold effluent management, and ballast 

water management. Part 2.6 of the sVGP includes required BMPs for vessel hull maintenance 

that are designed to reduce or eliminate discharges from AFC and to prevent the spread or 

dispersal of potentially invasive species. While vessel hull maintenance of AFC is necessary to 

prevent the spread or dispersal of potentially invasive species, it unavoidably results in a release 

of toxic biocides from AFC. 

The required BMPs for fish hold effluent in Part 2.8 of the sVGP are designed to reduce 

the amount of fish hold effluent discharged into sensitive water bodies and to lessen the 

environmental impact fish hold effluent that is discharged. The requirement to physically 

separate excess fish waste from fish hold effluent prior to discharge will reduce the amount and 

concentration of the discharge. Requiring the discharge of fish hold effluent to shore facilities 

where available will reduce fish hold effluent discharges at piers. Prohibiting the discard of 

unused bait, unless the bait was caught in that water body or watershed, will help prevent the 

spread or dispersal of potentially invasive species if the bait are invasive species or are 

contaminated with invasive pathogens. Minimizing fish hold effluent discharges when in port 

will reduce the amount of fish hold effluent discharged into these nearshore waters. 

 In addition, vessels with less than 8 cubic meters of ballast water capacity must 

implement the management practices outlined in Part 2.9 of the sVGP. These BMPs include 

avoiding or minimizing ballast water uptake in areas with a high potential to contain harmful 

organisms and only discharging the minimal amounts of ballast water necessary in coastal and 

internal waters. These requirements are common sense measures that reduce the risk of vessels 

transporting potentially harmful pollution and aquatic nuisance species from one water body to 

another. 

6.1.7 Specific Examples of Anticipated Mitigation of Risk in Ballast Water by Permits

 As described above, the 2013 VGP and new sVGP include ballast water management 

measures that EPA anticipates should greatly mitigate risk to listed aquatic and aquaticdependent species and their critical habitats from discharge of ANS. This presumption is 

predicated on the fact that: i) the combination of ballast water exchange and saltwater flushing 

are highly effective at removing or exterminating freshwater zooplankton, and ii) with treatment 

of ballast water in the future to current proposed numeric standards, removal of a higher 
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percentage of living organisms from ballast water tanks (including dormant and other resilient 

(e.g., euryhaline) species is likely. The following subsections provide examples of the anticipated 

mitigation of risk to list species from ANS from the issuance of VGP and sVGP. 

6.1.7.1 Mitigation of Risk to Listed Species from a Freshwater Macroinvertebrate: 

Case of the Bloody Red Shrimp 

 The bloody red shrimp (Hemimysis anomala) is a brackish water mysid shrimp able to 

adapt to freshwater environments. Salinity toleration ranges from 0 to 19 ppt, and preferred water 

temperatures are from 9 to 20o

C (Pienimäki and Leppakoski, 2004; Jazdzewski et al., 2005). This 

shrimp is native to freshwater margins of the Black Sea, the Azov Sea and the Eastern PontoCaspian Sea (USGS, 2012). It also historically occurred in the lower reaches of the Don, 

Danube, Dnieper and Dniester Rivers. It was reported for the first time in 2006 from two disjunct 

regions in the Great Lakes: southeastern Lake Ontario at Nine Mile Point near Oswego, NY 

(May 2006 – J. Wyda, The Ecosystem Center, the Marine Biological Laboratory, Woods Hole, 

MA; 2007, author communication used as reported in USGS, 2102), and from a channel 

connecting Muskegon Lake to Lake Michigan in November 2006 (Pothoven et al. 2007). 

Scientists at USGS and others believe that the species is probably present at other locations in the 

Great Lakes Basin, but has escaped detection (i.e., specimens resembling H. anomala were found 

in the stomach contents of white perch collected near Port Dover, Lake Erie in August 2006 – T. 

MacDougall, Ontario Ministry of Natural Resources, author communication used as reported in 

USGS, 2012). 

 Mature individuals range from 6 to 13 mm in length, with females being slightly larger 

than males. Sexual maturity occurs in less than 45 days, and females produce up to 2 to 4 broods 

(6 to 70 embroys per individual) per year. H. anomala is an opportunistic omnivore that feeds 

primarily on zooplankton, particularly cladocerans, but also consumes plant and animal remains 

(detritus), phytoplankton (particularly green algae and diatoms), and insect larvae (Ketelaars et 

al., 1999; Borcherding et al., 2006; Dumont, 2006). Adults are fast swimmers and favor rocky 

substrates as opposed to soft sediments or areas with dense vegetation or high siltation (Janas 

and Wysocki 2005; Borcherding et al. 2006; Pothovan et al. 2007). Because this species avoids 

areas where other mysid species are found (Salemaa and Hietalahti, 1993) and because they are 

adapted to warmer temperatures relative to native freshwater shrimp (Bondarenko and 

Yablonskaya, 1979), H. anomala could become abundant in many areas of the Great Lakes 

currently devoid of mysid shrimp, and, in turn, could reduce zooplankton biomass and diversity 

in these areas, with cladocerans, rotifers and ostracods being most affected (Ketelaars et al., 

1999). Conceptually, these direct effects of H. anomala on the food web could potentially 

indirectly affect special interest aquatic (e.g., Chinook salmon) and listed aquatic-dependent 

species (e.g., Lake Erie water snake) and their critical habitats, although there are no recorded 

impacts yet associated with the relatively recent introduction of this species into the Great Lakes 

(USGS, 2012). 

 This species was likely introduced into the Great Lakes via ballast water release from 

transoceanic ships a few years before being discovered in 2006 (USGS, 2012). This supposition 

is supported by the fact that the population in Lake Michigan at the port as Muskegon, which is 

not a high-traffic area for shipping, probably reflects an introduction from another invaded site in 
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the Great Lakes. Given its introduction into waters of the Great Lakes which preceded the post2006 provision of NBOB saltwater flushing in combination with ballast water exchange, and the 

fact this species is not known to tolerate salinity in excess of 19 ppt, EPA thinks it highly likely 

that the risk to listed (and other) species from this ANS would have been completely mitigated 

had the provisions in the 2013 VGP and sVGP regarding ballast water exchange and saltwater 

flushing been in place prior to 2006. 

6.1.7.2 Mitigation of Risk to Listed Species from a Saltwater Macroinvertebrate: 

Case of the European Green Crab 

 The native range for the European green crab (Carcinus maenas) extends along the 

Atlantic coasts of Europe and northern Africa from Norway and the British Isles south to 

Mauritania (WDFW, 2001). The species now occurs in coastal areas from Nova Scotia to 

Virginia on the East Coast, and from British Columbia to California on the West Coast (USGS, 

2012). Earliest documentation of its occurrence in North America dates back to 1817 on the East 

Coast (Say, 1817). The species was first collected on the West Coast in San Francisco Bay in 

1989 (Cohen and Carlton, 1995).

 This species has colonized all types of protected and semi-protected marine and estuarine 

habitats, including habitats with mud, sand, or rock substrates, submerged aquatic vegetation, 

and emergent marsh (Cohen and Carlton, 1995). Dumbauld (as cited in Holmes, 2001) noted that 

the presence of green crabs in Washington's Willapa Bay was highly correlated with the 

occurrence of Spartina alterniflora, another invasive species for the U.S. west coast (though it is 

a highly valued native species on the east coast). Green crabs are ecologically important in rocky 

intertidal communities in eastern North America (Menge, 1995); however, they have not yet 

occupied exposed rocky shores in western North America (Grosholz and Ruiz, 2002). Postlarval 

crabs are found in intertidal areas and in the subtidal zone as deep as 55 m (Grosholz and Ruiz, 

2002). Reviewing studies from countries with established populations of the green crab, 

Grosholz and Ruiz (2002) noted that within its present range, C. maenas is often the most 

abundant crab species in soft-sediment bays and estuaries of Europe, Australia, and both coasts 

of North America. 

 Green crabs are both euryhaline, tolerating salinities from 4 to 52 ppt, and eurythermic, 

surviving in temperatures from 0 to 30o

C (Cohen and Carlton, 1995). The larvae are less tolerant 

of temperature and salinity extremes with successful development occurring at temperatures 

between 11 and 25oC and salinities between 26 and 39 ppt (WDFW, 2001). First stage zoeae are 

transported offshore with development to the megalopal stage occurring in approximately two 

weeks. Reinvasion of nearshore waters occurs during the megalopal stage with molt to the first 

crab stage taking place in the upper intertidal zone (WDFW, 2001). Females may produce up to 

185,000 eggs per sponge (Cohen and Carlton, 1995). Prey items include clams, mussels, oysters, 

and gastropods. 

 This species has the ability to disperse as adults by a variety of anthropogenic and natural 

mechanisms including: 1) ballast, 2) ship's hulls, 3) packing materials (seaweeds) used to ship 

live marine organisms, 4) bivalves moved for aquaculture, 5) rafting, 6) migration on surface 

currents, and 7) movement of submerged aquatic vegetation for coastal zone management 
2013 VGP and sVGP BE Section 6- Anticipated Effect of Proposed Actions 

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initiatives (USGS, 2012). Green crabs also spread by planktonic transport of larvae and once 

established in an area can expand their range rapidly (Grosholz, 1996; Grosholz and Ruiz, 2002). 

Research data strongly suggest that colonization of estuaries in Washington, Oregon and British 

Columbia was facilitated by the El Nino events of 1997 and 1998 (WDFW, 2001). Holmes 

(2001) also noted that the vector of introduction to Washington State was probably "simple 

larval transport" from established populations in California and Oregon. 

 According to Grosholz and Ruiz (2002), the green crab is one of the most successful 

invasive predators in coastal ecosystems with populations established on five continents. These 

authors noted that these crabs were able to expand their range over 750 km in less than ten years 

on the Pacific coast of North America with populations firmly established in every significant 

bay and estuary from Monterey Bay, California to Gray's Harbor, Washington. Because of their 

ability to rapidly expand their range, Cohen et al. (1995) suggested that the species has the 

potential to spread and become established from Alaska to Baja California. Expansion of the 

range on the East Coast of North America thus far has been primarily northward. 

 The introductions of C. maenas have had a negative impact on soft-shell clams, young 

oysters, and native crabs in the Northeast beginning in the 1950s (USGS, 2012). Significant 

impacts to commercial fisheries and natural ecosystems have been documented. Green crabs 

have been implicated in the destruction of the soft-shell clam (Mya arenaria) fisheries in New 

England (Cohen and Carlton, 1995) and the reduction of populations of other commercially 

important bivalves including the scallop, Argopecten irradians, and the northern quahog, 

Mercenaria mercenaria (Morgan et al. 1980; Walton, unpublished data as cited in Grosholz and 

Ruiz, 2002). In Connecticut, weekly rates of crab predation on scallops were as high as 70% 

leading Tettlebach (1986) to observe that green crabs were responsible for most observed 

mortality in scallops and were a limiting factor in population size. MacPhail et al. (1955) 

concluded that the green crab was "one of the worst, if not the worst, clam predators we know." 

Their ability to out compete native species for food resources, high reproductive capacity, and 

wide environmental tolerances lend them the capacity to fundamentally alter community 

structure in coastal ecosystems. Potentially, this species could directly affect coastal mollusk 

species such as the white abalone via predation or possibly even coastal short birds (e.g., least 

tern) or marine/estuarine fish species (e.g., Atlantic sturgeon) via direct competition for similar 

prey items such as mollusks and/or crustaceans. 

 Briski et al. (2012) recently assessed the relationship between macroinvertebrate presence 

and the amount of sediment in ballast tanks in 62 ships (67 ballast tanks) following three distinct 

geographic pathways to Canadian ports on the Saint Lawrence Seaway: transoceanic ships 

performing mid-ocean [ballast water] exchange, coastal ships performing mid-ocean exchange, 

and coastal ships without ballast water exchange. The authors documented the presence of the 

highly invasive Eurpoean green crab, as well as mud crab (Rhithropanopeus harrisii), common 

periwinkle (Littorina littorea), soft shell clam (Mya arenaria), and blue mussel (Mytilus 

galloprovincialis). The authors determined in this study that mid-ocean [ballast water] exchange 

did not affect macroinvertebrate occurrence, and that the relationship between amount of 

sediment and organism presence in ballast tanks was not significant. They also found that while 

macroinvertebrates were present in the sediment collected from empty ballast tanks of ships from 

all three pathways, half of the records (including for C. maenas) were from ballast tanks of 
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coastal ships practicing mid-ocean exchange, suggesting that this best management practice was 

ineffective for these particular taxonomic groups (marine mollusks and decapods). The average 

voyage length for these types of “inter-coastal transport” ships was only 4.47 days. Because C. 

maenas is recognized as a species able to tolerate ambient salinity in the recipient port (Briski et 

al., 2012), the authors conclude that risk for invasion of this species remains. By proposing 

numeric TBELs in the 2013 VGP, EPA recognizes the importance of treatment of ballast water 

tanks in addition to other BMPs in mitigating risk to even resilient species such as C. maenas. 

The Agency has every reason to believe that the likelihood for reductions in ANS such as C. 

maenas, and therefore, reductions in risk to listed (and other) species, are achievable with the 

combination of numerical discharge standards (found in Part 2.2.3.5 of the VGP) in addition to 

risk-based BMPs (found in Parts 2.2.3.1 through 2.2.3.4 of the VGP). 

6.2 MITIGATION OF RISK TO LISTED SPECIES FROM DISCHARGE OF POLLUTANTS LACKING 

SPECIFIC CONCENTRATION-RESPONSE TOXIC EFFECT THRESHOLDS

 In addition to ANS, EPA identified three pollutants (i.e., pathogens, oil and grease, and 

BOD) for analysis where a risk quotient could not be calculated to support a risk conclusion and 

subsequent effects determinations in the BE. For these pollutants, EPA qualitatively evaluated 

the potential for exposure and likelihood of adverse effects in Section 5.1. Although the lack of 

toxic effect thresholds prevented the quantification of risk, EPA determined the issuance of the 

VGP and sVGP not only improves water quality, but also reduces the risk to listed species to 

“remote”2 levels of concern as a result of the permits’ requirements such that any impacts are 

discountable. This section describes the mitigation of risk to threatened and endangered species 

from the permit actions for pollutants lacking specific concentration-response toxic effect 

thresholds. 

6.2.1 Pathogens

As discussed in Section 5.1.2, EPA is unaware of any outbreak of pathogenic disease 

among aquatic or aquatic-dependent species from vessel discharges and concluded that it is 

highly improbable that any infection could occur at the levels detected in vessel discharges. 

Although the probability of risk from vessel discharges is extremely low, EPA anticipates the 

permit actions will further reduce exposure of listed species to pathogens. The primary 

discharges of concern for pathogens include graywater and fish hold effluent. Mitigating 

requirements to reduce the discharge of pathogens primarily focus on minimizing the discharge 

of graywater and fish hold effluent while in port or in the near shore environment (i.e., less than 

1 nm). EPA identified the following methods for reducing the discharge of graywater and fish 

hold in the near shore environment: 

 Delay laundry and scullery activities; 

 Restrict length of showers while in port and use high efficiency faucets and 

showerheads; 

 

2

 For the purpose of this BE, EPA established a sliding scale to describe the risk conclusion and overall health 

concern from a given pollutant. EPA uses the term “remote” to describe the lowest possible risk level above no 

effect and presumes that the pollutant does not present a health risk to listed species, See Section 5.2.3 for further 

discussion of the sliding scale and how it is applied in the effects analysis. 
2013 VGP and sVGP BE Section 6- Anticipated Effect of Proposed Actions 

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 Store graywater and discharge greater than 1 nm from shore while the vessel is 

underway; 

 Dispose graywater or fish hold at onshore facilities; 

 Use a physical separation method (e.g., filters for removal of residuals) prior to 

discharging fish hold effluent; and 

 Avoid discarding unused bait overboard, unless that bait was caught in the same 

water body or watershed. 

EPA anticipates that the highly improbable risk to listed aquatic and aquatic-dependent species 

and their critical habitats from pathogens under pre-permit conditions will be further reduced to 

extremely low exposure concentrations in the receiving water through implementation of the 

VGP and sVGP. 

6.2.2 Oil and Grease

Oil and grease is measured as hexane extractable material (HEM) and silica gel treated 

hexane extractable material (SGT-HEM). The HEM method captures both the petroleum 

components of oil and grease, plus the non-petroleum components including non-volatile 

hydrocarbons, vegetable oils, animal fats, waxes, soaps, and greases. The SGT-HEM method 

targets the petroleum components of oil and grease, including petroleum and gasoline byproducts as well as degradates such as polycyclic aromatic hydrocarbons (PAHs) and benzene, 

ethylene, toluene, and xylene (BETX). Mitigation of exposure to SGT-HEM, specifically PAHs 

and benzene, is discussed in Section 6.3 below. 

EPA anticipates that oil and grease from vegetable oils, animal fats, waxes, soaps and 

greases constitutes anywhere from 48 percent (fish hold effluent) to as high as 83 percent 

(graywater) of all oil and grease in vessel dischargers (see Section 5.1.3 and data presented in 

Table 3-15). Permit requirements designed to minimize the discharge of non-petroleum oil and 

grease (i.e., HEM minus SGT-HEM) include: 

 Minimizing the discharge of fish hold water or ice while in port by holding the 

effluent or requiring that all reasonable steps be taken to prevent the discharge of 

excess fish hold water and ice while the vessel is stationary at the pier; 

 Use a physical separation method (e.g., filters for removal of residuals) prior to 

discharging fish hold effluent; 

 Store graywater and discharge greater than 1 nm from shore while the vessel is 

underway; 

 Dispose graywater or fish hold at onshore facilities; 

 Prohibition of discarding excess oils, including animal fats and vegetable oils, used 

during cooking to the graywater system or into any other discharge covered by the 

permit; and 

 Prohibition of the discharge of oils and oily mixtures in quantities that may be 

harmful as determined in accordance with 40 CFR Part 110, i.e., that result in a 

visible sheen, a Best Practicable Technology (BPT) for oil and grease. 
2013 VGP and sVGP BE Section 6- Anticipated Effect of Proposed Actions 

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Table 6-1. presents the estimated percent reduction in pollutant concentrations for 

modeled estuary and river harbors. EPA calculated the percent reduction based on the maximum 

pollutant concentration predicted from the hypothetical harbor scenarios described in Section 

5.2.1.3 under pre- and post-permit conditions. EPA estimates that as much as approximately 51 

to 64 percent of oil and grease measured as HEM will be reduced via issuance of the permits (see 

Table 6-1). Consequently, the “remote” risk to listed aquatic and aquatic-dependent species and 

their critical habitats from HEM in vessel discharges under pre-permit conditions is expected to 

be further reduced following implementation of the permits to extremely low exposure 

concentrations in the receiving water. 

6.2.3 BOD 

BOD loads from fish hold and fish hold cleaning effluent can be problematic in fishing 

ports and harbors where discharges are concentrated within a limited area. Specific permit 

control measures designed to reduce BOD in fish hold and fish cleaning effluent include: 

 Minimizing the discharge of fish hold water or ice while in port by holding the 

effluent or requiring that all reasonable steps be taken to prevent the discharge of 

excess fish hold water and ice while the vessel is stationary at the pier; and 

 Using physical separation methods such as filters to remove fish waste and residuals 

prior to discharge in the port. 

As described in Appendix G, EPA assumes that all fishing vessels will reduce discharge 

flow and BOD concentrations by 25 percent as a result of the mitigation requirements in the 

VGP and sVGP (see Tables G-3 and G-4). While BOD is also expected to be found in 

appreciable concentrations from bilgewater, deck washdown effluent, and graywater, control 

measures to further reduce BOD in these discharges focus primarily on minimizing the discharge 

of these waste streams while in port or in the near shore environment (i.e., less than 1 nm). EPA 

estimates a 26 percent reduction in BOD from incidental vessel discharges in modeled estuarine 

harbors and anticipates a nominal reduction in BOD from incidental vessel discharges of 1 

percent in modeled river harbors. The minimal reduction in river systems is due to the limited 

number of fishing vessels covered under the VGP present in these waters. EPA determined a 

“remote”3

 risk to listed aquatic and aquatic-dependent species and their critical habitats under 

pre-permit conditions; thus, EPA assumes that any mitigation in BOD load via the permits, while 

measureable, will have little overall affect on further reducing risk to listed species. 

6.3 MITIGATING RISK TO LISTED SPECIES FROM VESSEL DISCHARGES OF TOXIC AND NONCONVENTIONAL POLLUTANTS WITH TOXIC EFFECTS 

In Section 5.3, EPA quantitatively evaluated the risk to listed species from toxic and nonconventional pollutants with toxic effects. Under pre-permit conditions, EPA concluded the risk 

to aquatic and aquatic-dependent species and their critical habitats from pollutants with toxic 

effects is either “remote” (RQ<0.1) or “negligible” (RQ<1) with the exception of phosphorus in 

estuary harbors. Therefore, EPA assumes that any estimated reductions in pollutant loads will 

 

3

 See footnote 2 in this section. 
2013 VGP and sVGP BE Section 6- Anticipated Effect of Proposed Actions 

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only further reduce the overall risk to listed species from pollutants with toxic effects to 

extremely low levels. Specific permit requirements and EPA’s load reduction assumptions that 

contribute to the further mitigation of risk from pollutants with toxic effects is described in 

Appendix G (see Tables G-3 and G-4). 

Phosphorus was the only pollutant under pre-permit conditions with an estimated risk of 

potentially significant (1< RQ <10).4 EPA estimates that approximately 87 to 95 percent of total 

phosphorus will be reduced by the issuance of the permits in modeled estuary and river harbors. 

The primary driver for phosphorus reductions include the permit requirements to use soaps, 

detergents, and cleaners that are phosphate-free, non-toxic, and biodegradable for any activities 

that might result in their introduction into deck washdown, fish hold cleaning, and graywater 

discharges. The mitigation of risk to aquatic ecosystems inclusive of all organisms, whether 

listed or otherwise, is of such magnitude that EPA concluded in Section 5.3.3.1 risk of 

phosphorus to listed species is “remote” (RQ< 0.1) under post-permit conditions for estuary 

systems. 

 Although EPA concluded that the risk under pre-permit conditions to aquatic and aquaticdependent species and their critical habitats from all other pollutants with toxic effects was 

“remote” or “negligible”, EPA notes that several of the pollutants undergo significant percent 

reductions following implementation of the VGP and sVGP. Pollutants with percent reductions 

greater than 50 percent include: 

 HEM 

 SGT-HEM 

 Total Residual Chlorine 

 2,3,6-Trichlorophenol 

 2,4,6-Trichlorophenol 

 Bromodichloromethane 

 Dibromochloromethane 

 Tetrachloroethene 

 Trichloroethene 

While the absolute reduction in risk from these pollutants is anticipated to be small (i.e., risk to 

listed species is “remote” to begin with), the reduction in pollutant loads indicates that 

implementation of the permits’ requirements will help improve overall water quality by reducing 

vessel discharge contributions to water quality impairments and exceedances of water quality 

standards. EPA anticipates that the pollutant load reductions associated with issuance of the VGP 

and sVGP will improve water quality and potentially lower the risk to species with known 

sensitivities to pollution such as the California Freshwater Shrimp, Steelhead Salmon, Bog 

Turtle, Roseate Tern, and Pallid Sturgeon. 

 

4

 EPA calculated RQ values using the lowest statewide and/or site-specific water quality criteria for total phosphorus 

(10 μg/L) in an estuary or river environment. 
2013 VGP and sVGP BE Section 6- Anticipated Effect of Proposed Actions 

on Mitigating Impact to Listed Species 

6-31 

Table 6-1. Estimated Percent Reduction in Pollutant Load Following Issuance of the 2013 

VGP and sVGP 

Class Pollutant 

Percent Reduction in 

Hypothetical Estuary 

Harbora

Percent Reduction in 

Hypothetical 

River Harborb

Classicals Biochemical Oxygen Demand (BOD) 26 1 

Classicals Hexane Extractable Material (HEM) 51 64 

Classicals Silica Gel Treated HEM (SGT-HEM) 47 61 

Classicals Total Residual Chlorine 69 3 

Classicals Total Suspended Solids (TSS) 36 30 

Metals Aluminum, Total 20 8 

Metals Arsenic, Dissolved 0 0 

Metals Arsenic, Total 0 0 

Metals Cadmium, Dissolved 20 8 

Metals Chromium, Dissolved 3 15 

Metals Copper, Dissolved 1 1 

Metals Lead, Dissolved 11 5 

Metals Nickel, Dissolved 0 0 

Metals Nickel, Total 0 0 

Metals Selenium, Dissolved 0 0 

Metals Selenium, Total 0 0 

Metals Zinc, Dissolved 8 2 

Nutrients Ammonia As Nitrogen (NH3-N) 22 11 

Nutrients Total Phosphorus 95 87 

SVOC 2,4,6-Trichlorophenol 50 13 

SVOC Benzo(a)anthracene 0 0 

SVOC Benzo(a)pyrene 0 0 

SVOC Benzo(b)fluoranthene 0 0 

SVOC Benzo(k)fluoranthene 0 0 

SVOC Bis(2-ethylhexyl) phthalate 25 12 

SVOC Chrysene 0 0 

SVOC Ideno(1,2,3-cd)pyrene 0 0 

VOC Benzene 17 6 

VOC Bromodichloromethane 71 55 

VOC Dibromochloromethane 71 55 

VOC Tetrachloroethene 50 50 

VOC Trichloroethene 100 100 

a) Percent reduction calculated based on the maximum receiving water concentration determined for the 

hypothetical estuary harbor under pre- and post-permit conditions. 

b) Percent reduction calculated based on the maximum receiving water concentration determined for the 

hypothetical river harbor under pre- and post-permit conditions. 
2013 VGP and sVGP BE Section 6- Anticipated Effect of Proposed Actions 

on Mitigating Impact to Listed Species 

6-32 

6.4 MITIGATING RISK TO LISTED SPECIES FROM COAL ASH FROM COAL FIRED 

PROPULSION SYSTEMS ON FERRIES

Combusting coal in boilers produces a residue of combustible flue constituents known as 

ash. Some of the ash consists of very fine particles that are entrained in the flue gas and carries 

out of the furnace (fly ash), while heavier ash settles at the bottom of the boiler (bottom ash). 

Bottom ash may be hydraulically conveyed (i.e., sluiced with water) and must be disposed. 

A U.S. company, Lake Michigan Carferry Inc. (LMC) estimates that the S.S. Badger the 

only known coal-fired vessel operating in the U.S. and discharging that ash to U.S. waters5

, 

generated 769.7 tons of coal ash in 2008 (GLEC, 2011). This ash was discharged to Lake 

Michigan via approximately 60 million gallons of coal ash slurry. Coal ash slurry discharge 

characterization data are not available from S.S. Badger; however, this discharge is expected to 

be similar to that generated by shoreside coal fired power plants. Coal ash slurry from coal fired 

power plants is known to contain multiple metals. According to EPRI, 1997 and EPRI, 1997b, 

discharges from ash holding ponds (i.e., coal ash slurry following sedimentation in ponds) 

exceeded water quality criteria for arsenic, selenium, aluminum, antimony, copper, mercury, 

nickel, cadmium, and thallium. Discharge concentrations exceeding Federal criteria indicate a 

potential risk to aquatic life, possibly including listed species. 

In October 2008 during development of the 2008 VGP, LMC submitted comments on 

EPA’s Notice of Proposed Permit Issuance (LMC, 2008). Within these comments, LMC 

requested that EPA designate coal ash as a permitted discharge and suggested BMPs to mitigate 

any possible environmental impacts. LMC stated in their comments their intent to identify and 

implement an engineering solution that would eliminate the discharge it its entirety in the future. 

In consideration of these comments, EPA included coal ash from coal fired propulsion systems 

on ferries as a permitted discharge, subject to effluent limits provided in Part 5.3.2.3 of the permit. 

The permit also included a provision authorizing the discharge in waters subject to the permit until 

December 19, 2012, to provide time for LMC to eliminate the coal ash discharge. This provision 

remains in effect in the 2008 VGP; the 2013 VGP does not authorize discharge of coal ash from 

coal fired propulsion systems on ferries. By eliminating authorization to discharge, EPA’s 2008 

VGP (after December 19, 2012) and 2013 VGP eliminate all risk to listed species from coal ash 

from coal fired propulsion systems on ferries. 

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5

 All other coal-fired vessels are believed no longer in service or to have converted to other forms of propulsion. At 

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on Mitigating Impact to Listed Species 

6-33 

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2013 VGP and sVGP BE Section 7- Effects Summary and Determination 

7-1 

SECTION 7 

EFFECTS SUMMARY AND DETERMINATION 

This section provides EPA’s determinations regarding potential effects based on the 

analyses presented in Section 5.0. EPA used the risk analysis and conclusions in Section 5.5 for 

the 82 listed aquatic and aquatic-dependent species and their critical habitats identified in the 

seven RAAs to inform EPA’s effects determinations for the full range of 612 listed species with 

respect to potential ANS impacts and for the 454 listed species potentially exposed to all other 

pollutants (Appendix E). Risk conclusions outlined in Section 5.5 included consideration of 

species-specific life histories for the 82 listed species in the RAAs and the potential for direct 

and indirect effects from ANS and other pollutants. EPA employed this risk extrapolation 

approach because the Agency believes it allowed for a more in-depth focus on the potential risks, 

exposures, and use of the best available data applicable to evaluate potential effects for the full 

range of listed species listed in Appendix E. To further refine EPA’s effects determinations 

presented in this section, EPA conducted several additional species-specific assessments on the 

complete list of species that may be affected by the VGP and sVGP. For each aquatic and 

aquatic-dependent species identified for evaluation, EPA confirmed the current status for each 

species and their associated critical habitats (see Appendix E). In addition, EPA conducted 

several geographical information system (GIS) analyses to assess individual species distributions 

with the concurrence of waters navigable by vessels covered under the permit actions (see 

Appendix E). EPA further reviewed and considered relevant life history, habitat status, 

constituent element requirements, principle food sources, and major threat information for all 

612 species evaluated in this BE (see examples in Section 7.1 and the Affects Determination for 

ANS column and associated footnotes in Table 7-2). EPA’s ultimate determinations are divided 

into categories of “no effect”, “not likely to adversely affect”, and “may affect” for all 612 

species addressed by this BE. 

7.1 METHODOLOGY FOR EFFECTS DETERMINATIONS FOR ANS 

 EPA considered the individual life history for each of the 612 species addressed in this 

BE and assessed the potential for exposure and likelihood of adverse effects from ANS. Section 

5.1.1 provided a literature review and discussion of the relationship between exposure 

(propogule pressure) and the likelihood of effects (invasion success and risks to listed species) 

from ballast water, vessel biofouling, and other potential vessel discharge vectors for ANS (e.g., 

chain locker). When considered within the context of other examples of ANS invasions in the 

U.S. and how ANS impact native species, EPA is confident the control measures in the VGP and 

sVGP will substantially reduce the probability of ANS invasions and their potential impact on 

listed species and critical habitats (see detailed discussion in Section 6.1). 

 At this time, no data or associated predictive or probabilistic tools exist to estimate or 

quantify potential adverse effects on listed aquatic or aquatic-dependent species and their critical 

habitats due to ANS with any reasonable certainty. EPA anticipates both permits will 

significantly benefit listed species due to the anticipated reduction in potential ANS release from 

ballast water due to the requirements of the VGP and sVGP. In all cases, the relatively low 

historic potential for adverse impacts from ANS introductions over the five-year permit term will 
2013 VGP and sVGP BE Section 7- Effects Summary and Determination 

7-2 

be reduced significantly, particularly in comparison to the existing VGP and currently 

unpermitted discharges under the sVGP. The permit actions substantially reduce propagule 

pressure (as discussed in Section 6.1) and, thereby, significantly reduce the risk of ANS invasion 

(as discussed in Section 5.1.1). 

 Although EPA anticipates a significant reduction in exposure to new ANS introductions 

under the requirements of the VGP and sVGP, EPA cannot state with certainty there will be no 

invasions of ANS from vessel discharges. However, EPA also believes that direct or future 

indirect effects on listed aquatic species and their critical habitats due to discharges during the 

five-year term of the permits are unlikely. Nonetheless, in evaluating aquatic species and their 

critical habitats, in light of limited data and uncertainty quantifying risk of ANS introduction, 

EPA concluded an effects determination of “may affect”. For aquatic-dependent species and 

their critical habitats, given the anticipated prevention and control measures to reduce possible 

ANS introductions, EPA assessed a lower risk for adverse effects from ANS invasions over the 

permit terms. The potential for both harm and exposure is lower due to their more limited 

exposure to the aquatic environment. Notwithstanding, EPA evaluated the life histories of each 

aquatic-dependent species using the following criteria: 

 Could any specific food and/or habitat (vegetation) requirements reasonably be affected 

by vessel-related ANS under post-permit conditions? 

 Are invasive species which potentially are or were likely to be transmitted by ballast 

water and other incidental discharge vectors listed as a major threat? Do any critical 

habitat/constituent elements identify ANS (also where incidental discharge vessel 

mediated introduction is likely)? Though past introductions of ANS are not under 

consultation, this metric is simply used to see if past vulnerabilities have been identified. 

 Is a significant portion of their life cycle spent in areas where vessel discharge-related 

ANS has potential occur? 

The following subsections present examples of this further risk analysis for aquatic-dependent 

species using the methodology outlined above. 

7.1.1 Example “Not Likely to Adversely Affect” With Low Potential Exposure: Valley 

Elderberry Long Beetle

 The species profile for the Valley Elderberry Longhorn Beetle (VELB) given in 

Appendix F indicates that this small (approximately 2 cm long) terrestrial beetle is dependent on 

its host plant, the elderberry. In the Central Valley of California, the elderberry tree is associated 

with riparian forest along rivers and streams. Recent surveys have revealed that the VELB 

persists only in scattered localities along the Sacramento, American, San Joaquin, Kings, 

Kaweah, and Tule rivers and their tributaries, which encompasses the entire California Central 

Valley and the Sacramento River Delta below 900 m (2,953 ft) elevation. VELB habitat is 

defined as stands of elderberry shrubs that are adjacent to, or contiguous with, riparian forest, 

floodplains, or relict elderberry savannah. Critical habitat has been designated for the VELB for 

Sacramento County in the Sacramento Zone and the American River Parkway Zone. 
2013 VGP and sVGP BE Section 7- Effects Summary and Determination 

7-3 

 The VELB is associated with elderberry trees during its entire life cycle. The adults 

emerge in the spring from pupation inside the wood of these trees as they begin to bloom. The 

adults eat the elderberry foliage until about June when they mate. The females lay their eggs in 

crevices in the bark. Upon hatching, the larvae then begin to tunnel into the tree where they will 

spend 1-2 years eating the interior wood, their sole source of food. 

 The greatest current threat to VELB is from the invasive non-native Argentine ant 

(Linepithema humile) and European earwig (Forficula auricularia), which predate VELB larvae 

(note: neither of these species were introduced by vessel discharge vectors regulated under the 

VGP or sVGP). Non-native invasive plant species such as black locust, giant reed, red sesbania, 

Himalaya blackberry, tree of heaven, Spanish broom, Russian olive, edible fig, and Chinese 

tallowtree, may also have significant indirect impact on VELB by impacting elderberry shrub 

vigor and recruitment (note: none of these species were introduced by vessel discharge vectors 

regulated under the VGP or sVGP). 

 Though the VELB habitat and entire life-cycle are exclusive to the elderberry tree and 

because the elderberry tree exists in riparian zones and floodplains, it is unlikely that invasive 

species transmitted via ballast water would impact this species. Hence, EPA believes that the 

Valley Elderberry Long Beetle is not likely to be adversely affected. 

7.1.2 Example “Not Likely to Adversly Affect” With Very Low Potential Exposure:

Marbled Murrelet

 The marbled murrelet (Brachyramphus marmoratus) is a small (approximately 9 inches 

long) seabird belonging to the Alcidae Family (see species profile in Appendix F). This species 

nests in trees in coastal, older forests throughout most of their current range in North America 

(currently Washington, Oregon and California where critical habitat for the species has been 

designated) where breeding females usually lay only one egg. Its migratory movements primarily 

consist of small-scale seasonal shifts of habitat where individuals move seasonally from outer 

coastal to protected waters, from inland waters of unknown locations, south of breeding areas, or 

to areas further offshore. Primary habitat requirements for the marbled murrelet include: (1) 

individual trees with potential nesting platforms, and (2) forested areas within 0.8 kilometers (0.5 

miles) of individual trees with potential nesting platforms, and with a canopy height of at least 

one-half the site-potential tree height. This includes all such forest, regardless of contiguity. 

These primary habitat elements are essential to provide and support suitable nesting habitat for 

successful reproduction of the marbled murrelet. 

 Marbled murrelets feed primarily on small fish and invertebrates in near-shore marine 

environment, where it dives underwater and forages throughout the marine water column on 

small ocean fish, such as anchovy, herring, and sardines. Chicks are semiprecocial and are fed 

whole fish soon after hatching. 

 Two of the greatest threats for the marbled murrelet population are genetic threats (and 

subsequent reduction in a population’s gene pool) and disease. Loss of viable nesting habitat (in 

old growth coastal forest) is thought to be a primary factor responsible for its current threatened 

status. 
2013 VGP and sVGP BE Section 7- Effects Summary and Determination 

7-4 

 EPA does not believe that any specific food, habitat (vegetation) requirements could 

reasonably be affected by vessel-related ANS because marbled murrelets exhibit a relatively 

diverse prey base in more open ocean waters which are not as likely to be subject to extensive 

invasion by vessel-related ANS and because their critical habitat (old growth forest) is also not 

as likely to be affected by vessel-mediated ANS. In addition, ANS has not been identified as a 

major threat to this species, its critical habitat/constituent elements do not identify ANS as an 

issue for the species, and a significant portion of their life cycle is not spent in areas where 

vessel-related ANS has potential to occur. Given the weight-of-evidence, EPA concluded that an 

effects determination of not likely to adversely affect from ANS on the marbled murrelet would 

be appropriate. 

7.1.3 Example “May Affect” Determination for ANS for an Aquatic-dependent Species: 

California Clapper Rail

 The California clapper rail (Rallus longirostris obsoletus) is a small (approximately 13–

19 inches from bill to tail) coastal bird species that inhabits (almost exclusively) saltwater 

marshes south of the San Francisco Bay area (Monterey and San Luis Obispo) where it uses the 

network of small tidal sloughs for foraging, cover and nesting (EPA, 2010). Preference is for salt 

marshes dominated by both pickleweed (Salicornia virginica) and Pacific cordgrass (Spartina 

foliosa), but such refugia is being eliminated due to dyking for fill and land conversion, as well 

as losses to do to erosion and non-native Spartina invasion (EPA, 2010; San Francisco Estuary 

Invasive Spartina Project, 2012) 

 California clapper rails primarily forage on mud flats or in very shallow water where 

mussels and clams are preferred prey items. A primary threat to rails is predation (e.g., Norway 

rat predation, red foxes and northern harriers, red-tailed hawks, and peregrine falcons). Invasive 

Spartina species also pose a threat: these plants displace both pickleweed and native Sparina

species. In particular, non-native S. alterniflora-hybrids are believed to be invading small tidal 

sloughs causing sediment accretion resulting in steeper sided channels and the loss of gently 

sloping channel flats used by clapper rail for foraging and cover. As discussed in Section 6.1.7, 

the European green crab (Carcinus maenas), a voracious predator of clams, mussels, oysters, and 

gastropods, has also recently invaded (1989) San Francisco Bay (Cohen and Carlton, 1995), and 

thus, also presents a potential threat to the existence of this species. 

 For this analysis, because California clapper rail exist in saltwater marshes known to be 

susceptible to non-native invasive plant species, and because another vessel-mediated, 

historically-introduced, invasive species (i.e., the European green crab) has the potential to 

negatively impact major prey items of clapper rail (i.e., clams and mussels), EPA believes that, 

though unlikely, this species could potentially be affected by new vessel discharge related ANS, 

and thus, EPA made a “may affect” determination. 

7.2 METHODOLOGY FOR EFFECTS DETERMINATIONS FOR POLLUTANTS SELECTED FOR 

DETAILED EVALUATION

 EPA analyzed in detail 32 pollutants in vessel discharges (Section 3.2.4). In Sections 

5.1.2, 5.1.3, 5.1.4, and 5.3, EPA directly evaluated the potential exposure to and risk posed by 

each pollutant to the 82 aquatic and aquatic-dependent listed species and their critical habitats 
2013 VGP and sVGP BE Section 7- Effects Summary and Determination 

7-5 

analyzed in-depth in the seven RAAs. EPA qualitatively discussed the potential threat to listed 

species posed by pollutants lacking specific concentration-response toxic effect thresholds (i.e., 

[human] pathogens, non-petroleum or HEM-related oil and grease, and BOD) taking into 

consideration potential direct and indirect effects within the context of the species life history 

information provided in Appendix F. For pollutants with specific toxic effect threshold data, 

EPA quantitatively evaluated the risk posed by a given pollutant through various exposure 

pathways (e.g., water column only, multiple routes for aquatic species, ingestion of contaminated 

food and water for aquatic-dependent species) and assessed potential direct and indirect effects 

within the context of the species life history information. Based on these qualitative and 

quantitative evaluations, EPA reached a risk conclusion for each of the 82 RAAs listed species 

(Table 5-57). 

 In Appendix E, EPA identified 612 listed aquatic and aquatic-dependent species and their 

critical habitats to be addressed in this BE. EPA narrowed the scope of species potentially 

exposed to traditional pollutants (everything but ANS) to only those species whose range 

coincide with U.S. waters navigable by vessels covered under the VGP and sVGP. As described 

in Appendix E, this left 454 species of the 612 for further consideration. For the 158 listed 

species not occurring in covered-vessels-navigable waters, EPA concluded vessel discharges 

would have “no effect” as these species are not generally expected to be exposed to such 

discharges. 

 EPA reviewed the in-depth risk analysis for the 82 RAA listed species, as well as other 

individual species information, to inform and support effect determinations for the 454 species 

present in U.S. waters navigable by the relevant vessels. EPA grouped the 82 RAA listed species 

into 18 taxonomic groups (Table 5-11) and used the in-depth analysis and risk conclusions 

presented in Table 5-57 to determine the general risks from conventional pollutants to each 

taxonomic group (Table 7-1). In doing so, EPA conservatively assumed that the 454 listed 

species considered are as sensitive to a given pollutant as the most sensitive representative 

surrogate species for the taxonomic group. 

As discussed in Section 5, moreover, EPA‘s in-depth risk evaluations were based on 

exposure to the maximum exposure concentrations in a hypothetical estuary and river harbor. 

The actual likelihood of a listed species being exposed to a given pollutant at these 

concentrations from vessel discharges is extremely low because of the conservative assumptions 

made during hypothetical harbor modeling and the potential for other water quality parameters 

(e.g., pH, dissolved organic carbon, water hardness, and salinity) to reduce bioavailability and 

therefore toxicity of many pollutants to aquatic organisms. EPA then reviewed individual species 

information for possible unique concerns and made the effects determinations presented in Table 

7-1. 

 
2013 VGP and sVGP BE Section 7- Effects 

7-6 

Table 7-1. Effects Determinations by Taxonomic Group for Pollutants Selected for Detailed Evaluation 

Listed Species Taxonomic Grouping 

Pollutants Subjected to 

Qualitative Effects Analysis Pollutants Subjected to Quantitative E

Pathogens 

[Human] 

Oil and 

Grease 

[HEM] 

BOD TRC TSS Metals TP Ammo

Saltwater Corals No Effect NLAA NLAA NLAA NLAA NLAA NLAA NLAUnionid Mussel No Effect NLAA NLAA NLAA NLAA NLAA NLAA NLASaltwater Bivalve Mollusk No Effect NLAA NLAA NLAA NLAA NLAA NLAA NLAFreshwater Shrimp/Crustacean No Effect NLAA NLAA NLAA NLAA NLAA NLAA NLAFreshwater Fish/Inland Salmonid No Effect NLAA NLAA NLAA NLAA NLAA NLAA NLAAnadromous Salmonid No Effect NLAA NLAA NLAA NLAA NLAA NLAA NLAFreshwater Fish/Inland Sturgeon No Effect NLAA NLAA NLAA NLAA NLAA NLAA NLAAnadromous Sturgeon No Effect NLAA NLAA NLAA NLAA NLAA NLAA NLAEstuarine/Marine Fish No Effect NLAA NLAA NLAA NLAA NLAA NLAA NLABeetle and Aquatic Insect No Effect NLAA NLAA NLAA NLAA NLAA NLAA NLAAmphibian No Effect NLAA NLAA NLAA NLAA NLAA NLAA NLASnakes and Other Reptiles No Effect NLAA NLAA NLAA NLAA NLAA NLAA NLASea Turtle No Effect NLAA NLAA NLAA NLAA NLAA NLAA NLACoastal/Marine Bird No Effect NLAA NLAA NLAA NLAA NLAA NLAA NLATerrestrial Mammal No Effect NLAA NLAA NLAA NLAA NLAA NLAA NLAMarine Mammal No Effect NLAA NLAA NLAA NLAA NLAA NLAA NLASeagrass No Effect NLAA NLAA NLAA NLAA NLAA NLAA NLAFreshwater- Saltwater Aquatic and Wetland Plants No Effect NLAA NLAA NLAA NLAA NLAA NLAA NLA
2013 VGP and sVGP BE Section 7- Effects Summary and Determination 

7-7 

7.3 EFFECTS DETERMINATION FOR ALL SPECIES

 EPA analyzed potential effects from discharges on 612 listed aquatic and aquaticdependent species and their critical habitats. Based on the methodology described in Section 7.1, 

EPA determined that potential discharge-related ANS are “not likely to adversely affect” 80 

aquatic-dependent species and their critical habitats. EPA concluded that new introductions of 

ANS from vessel discharges “may affect” 532 aquatic and aquatic-dependent species and/or their 

critical habitats. However, EPA believes that the permit conditions are designed to minimize the 

discharge of potential ANS which will substantially mitigate the likelihood of new introductions. 

Hence, the permits will significantly reduce risk from ANS to listed species and critical habitats -

- especially when compared to pre-permit conditions. EPA believes these conditions make a 

possible introduction of ANS over the next five years which would impact listed species very 

uncertain and speculative. EPA further believes that given these permit conditions and the most 

recent research on ANS (see Section 5.1.1), NLAA determinations could reasonably be made for 

all of the 532 species. Nonetheless, given the limited available data and uncertainties in the 

science, EPA has concluded only that potential ANS “may effect” the relevant listed species and 

critical habitats, to afford the Services an opportunity to provide their biological opinion and 

views on additional mitigation that may be appropriate. 

 For pollutants other than ANS, EPA concluded that 158 aquatic and aquatic-dependent 

species and their critical habitats will experience “no effect” as these species are not present in 

U.S. waters navigable by vessels covered under the VGP and sVGP. In addition, EPA concluded 

that these pollutants are “not likely to adversely affect” the remaining 454 aquatic and aquaticdependent listed species and their critical habitats. 

 Table 7-2 presents the species-specific effects determinations for ANS and the other 

pollutants. 
2013 VGP and sVGP BE Section 7- Effects Summ

7-8 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Abalone, black Haliotis cracherodii 

Saltwater Bivalve Mollusk 

E May Affect 

Abalone, white Haliotis sorenseni 

Saltwater Bivalve Mollusk 

E SFBE May Affect 

Acornshell, southern Epioblasma othcaloogensis Unionid Mussels E May Affect Albatross, short-tailed Phoebastria (=Diomedea) albatrus Coastal/Marine Bird E PS NLAAe Alligator, American Alligator mississippiensis Snakes and Other Reptiles T(S/A) May Affect Ambersnail, Kanab Oxyloma haydeni kanabensis Unionid Mussels E May Affect Amphipod, diminutive Gammarus hyalleloides 

Freshwater Shrimps/ Crustacean 

C May Affect 

Amphipod, Hay's Spring Stygobromus hayi 

Freshwater Shrimps/ Crustacean 

E May Affect 

Amphipod, Illinois cave Gammarus acherondytes 

Freshwater Shrimps/ Crustacean 

E May Affect 

Amphipod, Kauai cave Spelaeorchestia koloana 

Freshwater Shrimps/ Crustacean 

E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-9 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Amphipod, Noel's Gammarus desperatus 

Freshwater Shrimps/ Crustacean 

E May Affect 

Amphipod, Peck's cave Stygobromus (=Stygonectes) pecki Freshwater Shrimps/ Crustacean E May Affect Arrowhead, bunched Sagittaria fasciculata 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Asphodel, bog Narthecium americanum 

FreshwaterSaltwater Aquatic and Wetland Plants 

C May Affect 

Aster, decurrent false Boltonia decurrens 

FreshwaterSaltwater Aquatic and Wetland Plants 

T MR May Affect 

Atlantic sturgeon (Gulf of Maine) Acipenser oxyrinchus oxyrichus Anadromous Sturgeon T May Affect Bankclimber, purple (mussel) Elliptoideus sloatianus Unionid Mussels T May Affect Bat, gray Myotis grisescens Terrestrial Mammal E MR; BB NLAAg Bat, Hawaiian hoary Lasiurus cinereus semotus Terrestrial Mammal E NLAAd,e Bat, Indiana Myotis sodalis Terrestrial Mammal E ULB; MR; BB NLAAg 
2013 VGP and sVGP BE Section 7- Effects Summ

7-10 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Bat, Ozark big-eared Corynorhinus (=Plecotus) townsendii ingens Terrestrial Mammal E NLAAd,e Bat, Virginia big-eared Corynorhinus (=Plecotus) townsendii virginianus Terrestrial Mammal E NLAAd,e Beaked-rush, Knieskern's Rhynchospora knieskernii 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Bean, Choctaw Villosa choctawensis Unionid Mussels PE May Affect Bean, Cumberland (pearlymussel) Villosa trabalis Unionid Mussels E;XN May Affect Bean, purple Villosa perpurpurea Unionid Mussels E May Affect Bean, rayed Villosa fabalis Unionid Mussels E May Affect Bear, American black Ursus americanus Terrestrial Mammal T(S/A) NLAAd Bear, grizzly Ursus arctos horribilis Terrestrial Mammal T;XN PS NLAAe Bear, Louisiana black Ursus americanus luteolus Terrestrial Mammal T NLAAd,e Bear, polar Ursus maritimus Terrestrial Mammal T NLAAe Bearded seal (Beringia) Erignathus barbatus nauticus Marine Mammal PT May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-11 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Beardtongue, Penland Penstemon penlandii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Beauty, Harper's Harperocallis flava 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Beetle, Comal Springs dryopid Stygoparnus comalensis Beetle and Aquatic Insect E May Affect Beetle, Comal Springs riffle Heterelmis comalensis Beetle and Aquatic Insect E May Affect Beetle, delta green ground Elaphrus viridis Beetle and Aquatic Insect T SFBE NLAAg Beetle, Hungerford's crawling water Brychius hungerfordi Beetle and Aquatic Insect E May Affect Beetle, valley elderberry longhorn Desmocerus californicus dimorphus Beetle and Aquatic Insect T SFBE NLAAg Bellflower, Brooksville Campanula robinsiae 

FreshwaterSaltwater Aquatic and Wetland Plants 

E BB May Affect 

Bird's-beak, salt marsh Cordylanthus maritimus ssp. maritimus 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-12 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Bird's-beak, soft Cordylanthus mollis ssp. mollis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E SFBE May Affect 

Birds-in-a-nest, white Macbridea alba 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Bittercress, small-anthered Cardamine micranthera 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Blazingstar, Ash Meadows Mentzelia leucophylla 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Blossom, green (pearlymussel) Epioblasma torulosa gubernaculum Unionid Mussels E May Affect Blossom, tubercled (pearlymussel) Epioblasma torulosa torulosa Unionid Mussels E;XN May Affect Blossom, turgid (pearlymussel) Epioblasma turgidula Unionid Mussels E;XN May Affect Blossom, yellow (pearlymussel) Epioblasma florentina florentina Unionid Mussels E;XN May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-13 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Bluecurls, Hidden Lake Trichostema austromontanum ssp. compactum 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Bobwhite, masked (quail) Colinus virginianus ridgwayi Coastal/Marine Bird E NLAAe Bocaccio Sebastes paucispinis Estuarine/ Marine Fish E May Affect Brodiaea, Chinese Camp Brodiaea pallida 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Brodiaea, thread-leaved Brodiaea filifolia 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Bulrush, Northeastern Scirpus ancistrochaetus 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Buttercup, autumn Ranunculus aestivalis (=acriformis) 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Butterfly plant, Colorado Gaura neomexicana var. coloradensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-14 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Butterfly, lotis blue Lycaeides argyrognomon lotis Beetle and Aquatic Insect E NLAAe Butterfly, Mitchell's satyr Neonympha mitchellii mitchellii Beetle and Aquatic Insect E NLAAe Butterfly, Saint Francis' satyr Neonympha mitchellii francisci Beetle and Aquatic Insect E NLAAe Butterwort, Godfrey's Pinguicula ionantha 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Button, Mohr's Barbara Marshallia mohrii 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Button-celery, San Diego Eryngium aristulatum var. parishii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Caddisfly, Sequatchie Glyphopsyche sequatchie Beetle and Aquatic Insect C May Affect Calistoga Allocarya Plagiobothrys strictus 

FreshwaterSaltwater Aquatic and Wetland Plants 

E SFBE May Affect 

Campeloma, slender Campeloma decampi Unionid Mussels E May Affect Caracara, Audubon's crested Polyborus plancus audubonii Coastal/Marine Bird T BB NLAAg 
2013 VGP and sVGP BE Section 7- Effects Summ

7-15 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Catfish, Yaqui Ictalurus pricei 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Catspaw (=purple cat's paw pearlymussel) 

Epioblasma obliquata obliquata 

Unionid Mussels E;XN May Affect 

Catspaw, white (pearlymussel) Epioblasma obliquata perobliqua Unionid Mussels E May Affect Cavefish, Alabama Speoplatyrhinus poulsoni 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Cavefish, Ozark Amblyopsis rosae 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Cavesnail, Tumbling Creek Antrobia culveri Unionid Mussels E May Affect Centaury, spring-loving Centaurium namophilum 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Chaffseed, American Schwalbea americana 

FreshwaterSaltwater Aquatic and Wetland Plants 

E BB May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-16 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Checker-mallow, Kenwood Marsh Sidalcea oregana ssp. valida 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Checker-mallow, Nelson's Sidalcea nelsoniana 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Checker-mallow, pedate Sidalcea pedata 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Checkermallow, Wenatchee Mountains Sidalcea oregana var. calva 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Chub, bonytail Gila elegans 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Chub, Borax Lake Gila boraxobius 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Chub, Chihuahua Gila nigrescens 

Freshwater Fish/ Inland Salmonid 

T May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-17 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Chub, Gila Gila intermedia 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Chub, headwater Gila nigra 

Freshwater Fish/ Inland Salmonid 

C May Affect 

Chub, humpback Gila cypha 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Chub, Hutton tui Gila bicolor ssp. 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Chub, Mohave tui Gila bicolor mohavensis 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Chub, Oregon Oregonichthys crameri 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Chub, Owens tui Gila bicolor snyderi 

Freshwater Fish/ Inland Salmonid 

E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-18 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Chub, Pahranagat roundtail Gila robusta jordani 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Chub, slender Erimystax cahni 

Freshwater Fish/ Inland Salmonid 

T;XN May Affect 

Chub, Sonora Gila ditaenia 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Chub, spotfin Erimonax monachus 

Freshwater Fish/ Inland Salmonid 

T;XN May Affect 

Chub, Virgin River Gila seminuda (=robusta) 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Chub, Yaqui Gila purpurea 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Cinquefoil, Soldier Meadows Potentilla basaltica 

FreshwaterSaltwater Aquatic and Wetland Plants 

C May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-19 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Clover, showy Indian Trifolium amoenum 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Clubshell Pleurobema clava Unionid Mussels E;XN May Affect Clubshell, black Pleurobema curtum Unionid Mussels E May Affect Clubshell, ovate Pleurobema perovatum Unionid Mussels E May Affect Clubshell, southern Pleurobema decisum Unionid Mussels E May Affect Cobana negra Stahlia monosperma 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Combshell, Cumberlandian Epioblasma brevidens Unionid Mussels E;XN May Affect Combshell, southern Epioblasma penita Unionid Mussels E May Affect Combshell, upland Epioblasma metastriata Unionid Mussels E May Affect Coot, Hawaiian Fulica americana alai Coastal/Marine Bird E NLAAe Coral, elkhorn Acropora palmata Saltwater Corals T BB May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-20 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Coral, staghorn Acropora cervicornis Saltwater Corals T BB May Affect Crake, spotless Porzana tabuensis Coastal/Marine Bird C May Affect Crane, Mississippi sandhill Grus canadensis pulla Coastal/Marine Bird E NLAAd,e Crane, whooping Grus americana Coastal/Marine Bird E;XN GB NLAAe Crayfish, cave Cambarus aculabrum 

Freshwater Shrimps/ Crustacean 

E May Affect 

Crayfish, cave Cambarus zophonastes 

Freshwater Shrimps/ Crustacean 

E May Affect 

Crayfish, Nashville Orconectes shoupi 

Freshwater Shrimps/ Crustacean 

E May Affect 

Crayfish, Shasta Pacifastacus fortis 

Freshwater Shrimps/ Crustacean 

E May Affect 

Cress, Tahoe yellow Rorippa subumbellata 

FreshwaterSaltwater Aquatic and Wetland Plants 

C May Affect 

Crocodile, American Crocodylus acutus Snakes and Other Reptiles E;T BB NLAAe 
2013 VGP and sVGP BE Section 7- Effects Summ

7-21 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Crow, Mariana (=aga) Corvus kubaryi Coastal/Marine Bird E NLAAe Crownscale, San Jacinto Valley Atriplex coronata var. notatior 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Cuckoo, yellow-billed Coccyzus americanus Coastal/Marine Bird C NLAAd Cui-ui Chasmistes cujus 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Curlew, Eskimo Numenius borealis Coastal/Marine Bird E NLAAd Dace, Ash Meadows speckled Rhinichthys osculus nevadensis 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Dace, blackside Phoxinus cumberlandensis 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Dace, Clover Valley speckled Rhinichthys osculus oligoporus 

Freshwater Fish/ Inland Salmonid 

E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-22 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Dace, desert Eremichthys acros 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Dace, Foskett speckled Rhinichthys osculus ssp. 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Dace, Independence Valley speckled 

Rhinichthys osculus lethoporus 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Dace, Kendall Warm Springs Rhinichthys osculus thermalis

Freshwater Fish/ Inland Salmonid 

E May Affect 

Dace, Laurel Phoxinus saylori 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Dace, Moapa Moapa coriacea 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Daisy, Willamette Erigeron decumbens var. decumbens 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-23 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Damselfly, blackline Hawaiian Megalagrion nigrohamatum nigrolineatum Beetle and Aquatic Insect PE May Affect Damselfly, crimson Hawaiian Megalagrion leptodemus Beetle and Aquatic Insect PE May Affect Damselfly, flying earwig Hawaiian Megalagrion nesiotes Beetle and Aquatic Insect E May Affect Damselfly, oceanic Hawaiian Megalagrion oceanicum Beetle and Aquatic Insect PE May Affect Damselfly, orangeblack Hawaiian Megalagrion xanthomelas Beetle and Aquatic Insect C May Affect Damselfly, Pacific Hawaiian Megalagrion pacificum Beetle and Aquatic Insect E May Affect Darter, amber Percina antesella 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Darter, Arkansas Etheostoma cragini 

Freshwater Fish/ Inland Salmonid 

C May Affect 

Darter, bayou Etheostoma rubrum 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Darter, bluemask (=jewel) Etheostoma sp. 

Freshwater Fish/ Inland Salmonid 

E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-24 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Darter, boulder Etheostoma wapiti 

Freshwater Fish/ Inland Salmonid 

E;XN May Affect 

Darter, Cherokee Etheostoma scotti 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Darter, Cumberland Etheostoma susanae 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Darter, duskytail Etheostoma percnurum 

Freshwater Fish/ Inland Salmonid 

E;XN May Affect 

Darter, Etowah Etheostoma etowahae 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Darter, fountain Etheostoma fonticola 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Darter, goldline Percina aurolineata 

Freshwater Fish/ Inland Salmonid 

T May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-25 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Darter, leopard Percina pantherina 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Darter, Maryland Etheostoma sellare 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Darter, Niangua Etheostoma nianguae 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Darter, Okaloosa Etheostoma okaloosae 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Darter, Pearl Percina aurora 

Freshwater Fish/ Inland Salmonid 

C May Affect 

Darter, relict Etheostoma chienense 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Darter, rush Etheostoma phytophilum 

Freshwater Fish/ Inland Salmonid 

E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-26 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Darter, slackwater Etheostoma boschungi 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Darter, snail Percina tanasi 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Darter, vermilion Etheostoma chermocki 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Darter, watercress Etheostoma nuchale 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Darter, yellowcheek Etheostoma moorei 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Desert-parsley, Bradshaw's Lomatium bradshawii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Dragonfly, Hine's emerald Somatochlora hineana Beetle and Aquatic Insect E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-27 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Dropwort, Canby's Oxypolis canbyi 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Duck, Hawaiian (=koloa) Anas wyvilliana Coastal/Marine Bird E NLAAe Duck, Laysan Anas laysanensis Coastal/Marine Bird E NLAAe Ebonyshell, round Fusconaia rotulata Unionid Mussels PE May Affect Eider, spectacled Somateria fischeri Coastal/Marine Bird T NLAAe Eider, Steller's Polysticta stelleri Coastal/Marine Bird T NLAAe Elepaio, Oahu Chasiempis sandwichensis ibidis Coastal/Marine Bird E NLAAe Elimia, lacy (snail) Elimia crenatella Unionid Mussels T May Affect Elktoe, Appalachian Alasmidonta raveneliana Unionid Mussels E May Affect Elktoe, Cumberland Alasmidonta atropurpurea Unionid Mussels E May Affect Eulachon, Pacific Thaleichthys pacificus Estuarine/ Marine Fish T May Affect Fairy shrimp, Conservancy Branchinecta conservatio 

Freshwater Shrimps/ Crustacean 

E SFBE May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-28 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Fairy shrimp, longhorn Branchinecta longiantenna 

Freshwater Shrimps/ Crustacean 

E SFBE May Affect 

Fairy shrimp, Riverside Streptocephalus woottoni 

Freshwater Shrimps/ Crustacean 

E May Affect 

Fairy shrimp, San Diego Branchinecta sandiegonensis 

Freshwater Shrimps/ Crustacean 

E May Affect 

Fairy shrimp, vernal pool Branchinecta lynchi 

Freshwater Shrimps/ Crustacean 

T May Affect 

False killer whale (Hawaii Insular) Pseudorca crassidens Marine Mammal PE May Affect Fanshell Cyprogenia stegaria Unionid Mussels E;XN May Affect Fatmucket, Arkansas Lampsilis powelli Unionid Mussels T May Affect Flycatcher, southwestern willow Empidonax traillii extimus Coastal/Marine Bird E NLAAd,e Frog, California red-legged Rana aurora draytonii Amphibian T SFBE May Affect Frog, Chiricahua leopard Rana chiricahuensis Amphibian T May Affect Frog, Columbia spotted Rana luteiventris Amphibian C May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-29 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Frog, mountain yellow-legged Rana muscosa Amphibian E;C May Affect Frog, Oregon spotted Rana pretiosa Amphibian C May Affect Frog, relict leopard Rana onca Amphibian C May Affect Gambusia, Big Bend Gambusia gaigei 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Gambusia, Clear Creek Gambusia heterochir 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Gambusia, Pecos Gambusia nobilis 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Gambusia, San Marcos Gambusia georgei 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Gilia, Monterey Gilia tenuiflora ssp. arenaria

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Gnatcatcher, coastal California Polioptila californica californica Coastal/Marine Bird T NLAAd,e 
2013 VGP and sVGP BE Section 7- Effects Summ

7-30 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Goby, tidewater Eucyclogobius newberryi Estuarine/ Marine Fish E SFBE May Affect Goldenrod, Houghton's Solidago houghtonii 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Goldenrod, Yadkin River Solidago plumosa 

FreshwaterSaltwater Aquatic and Wetland Plants 

C May Affect 

Goldfields, Burke's Lasthenia burkei 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Goldfields, Contra Costa Lasthenia conjugens 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Grass, Colusa Neostapfia colusana 

FreshwaterSaltwater Aquatic and Wetland Plants 

T SFBE May Affect 

Grass, Tennessee yellow-eyed Xyris tennesseensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Grouse, greater sage Centrocercus urophasianus Coastal/Marine Bird C NLAAd 
2013 VGP and sVGP BE Section 7- Effects Summ

7-31 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Guajon Eleutherodactylus cooki Amphibian T May Affect Gumplant, Ash Meadows Grindelia fraxino-pratensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Haha Cyanea grimesiana ssp. grimesiana 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Harperella Ptilimnium nodosum 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Hawk, Puerto Rican broadwinged Buteo platypterus brunnescens Coastal/Marine Bird E NLAAe Heartleaf, dwarf-flowered Hexastylis naniflora 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Heau Exocarpos luteolus 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Heelsplitter, Alabama (=inflated) Potamilus inflatus Unionid Mussels T May Affect Heelsplitter, Carolina Lasmigona decorata Unionid Mussels E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-32 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Hellbender, Ozark Cryptobranchus alleganiensis bishopi Amphibian E May Affect Higgins eye (pearlymussel) Lampsilis higginsii Unionid Mussels E May Affect Higuero de sierra Crescentia portoricensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Hornshell, Texas Popenaias popei Unionid Mussels C May Affect Hornsnail, rough Pleurocera foremani Unionid Mussels E May Affect Howellia, water Howellia aquatilis 

FreshwaterSaltwater Aquatic and Wetland Plants 

T PS May Affect 

Ihi`ihi Marsilea villosa 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Isopod, Lee County cave Lirceus usdagalun 

Freshwater Shrimps/ Crustacean 

E May Affect 

Isopod, Madison Cave Antrolana lira 

Freshwater Shrimps/ Crustacean 

T May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-33 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Isopod, Socorro Thermosphaeroma thermophilus Freshwater Shrimps/ Crustacean E May Affect Ivesia, Ash Meadows Ivesia kingii var. eremica 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Jaguarundi, Gulf Coast Herpailurus (=Felis) yagouaroundi cacomitli Terrestrial Mammal E NLAAd Jaguarundi, Sinaloan Herpailurus (=Felis) yagouaroundi tolteca Terrestrial Mammal E NLAAd,e Joint-vetch, sensitive Aeschynomene virginica 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Kampua`a Hedyotis fluviatilis 

FreshwaterSaltwater Aquatic and Wetland Plants 

C May Affect 

Kidneyshell, fluted Ptychobranchus subtentum Unionid Mussels C May Affect Kidneyshell, southern Ptychobranchus jonesi Unionid Mussels PE May Affect Kidneyshell, triangular Ptychobranchus greenii Unionid Mussels E May Affect Kite, Everglade snail Rostrhamus sociabilis plumbeus Coastal/Marine Bird E BB May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-34 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Knot, red Calidris canutus rufa Coastal/Marine Bird C May Affect Ko`oko`olau Bidens conjuncta 

FreshwaterSaltwater Aquatic and Wetland Plants 

PE May Affect 

Kopiko Psychotria grandiflora 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Kuahiwi laukahi Plantago princeps 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Ladies'-tresses, Canelo Hills Spiranthes delitescens 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Ladies'-tresses, Navasota Spiranthes parksii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Ladies'-tresses, Ute Spiranthes diluvialis 

FreshwaterSaltwater Aquatic and Wetland Plants 

T PS May Affect 

Lampmussel, Alabama Lampsilis virescens Unionid Mussels E;XN May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-35 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Liliwai Acaena exigua 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Lilliput, pale (pearlymussel) Toxolasma cylindrellus Unionid Mussels E May Affect Lily, Pitkin Marsh Lilium pardalinum ssp. pitkinense 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Lily, Western Lilium occidentale 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Limpet, Banbury Springs Lanx sp. Unionid Mussels E May Affect Lioplax, cylindrical (snail) Lioplax cyclostomaformis Unionid Mussels E May Affect Lizard, blunt-nosed leopard Gambelia silus Snakes and Other Reptiles E NLAAd,e Lizard, St. Croix ground Ameiva polops Snakes and Other Reptiles E NLAAe Lo`ulu Pritchardia kaalae 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-36 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Lo`ulu Pritchardia napaliensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Lo`ulu Pritchardia remota 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Lo`ulu, (=Na`ena`e) Pritchardia hardyi 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Locoweed, Fassett's Oxytropis campestris var. chartacea 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Logperch, Conasauga Percina jenkinsi 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Logperch, Roanoke Percina rex 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Lomatium, Cook's Lomatium cookii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-37 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Loosestrife, rough-leaved Lysimachia asperulaefolia 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Madtom, chucky Noturus crypticus 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Madtom, Neosho Noturus placidus 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Madtom, pygmy Noturus stanauli 

Freshwater Fish/ Inland Salmonid 

E;XN May Affect 

Madtom, Scioto Noturus trautmani 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Madtom, smoky Noturus baileyi 

Freshwater Fish/ Inland Salmonid 

E;XN May Affect 

Madtom, yellowfin Noturus flavipinnis 

Freshwater Fish/ Inland Salmonid 

T;XN May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-38 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Makou Ranunculus mauiensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

C May Affect 

Manatee, West Indian Trichechus manatus Marine Mammal E GB; BB May Affect Mapleleaf, winged Quadrula fragosa Unionid Mussels E;XN May Affect Marstonia, royal (snail) Pyrgulopsis ogmorhaphe Unionid Mussels E May Affect Massasauga (=rattlesnake), eastern Sistrurus catenatus catenatus Snakes and Other Reptiles C NLAAe Meadowfoam, Butte County Limnanthes floccosa ssp. californica 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Meadowfoam, large-flowered woolly 

Limnanthes floccosa ssp. grandiflora 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Meadowrue, Cooley's Thalictrum cooleyi 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Mesa-mint, Otay Pogogyne nudiuscula 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-39 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Milk-vetch, Ash meadows Astragalus phoenix 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Milk-vetch, coastal dunes Astragalus tener var. titi 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Milk-vetch, Fish Slough Astragalus lentiginosus var. piscinensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Minnow, Devils River Dionda diaboli 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Minnow, loach Tiaroga cobitis 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Minnow, Rio Grande silvery Hybognathus amarus 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Moccasinshell, Alabama Medionidus acutissimus Unionid Mussels T May Affect Moccasinshell, Coosa Medionidus parvulus Unionid Mussels E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-40 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Moccasinshell, Gulf Medionidus penicillatus Unionid Mussels E May Affect Moccasinshell, Ochlockonee Medionidus simpsonianus Unionid Mussels E May Affect Monkeyface, Appalachian (pearlymussel) Quadrula sparsa Unionid Mussels E;XN May Affect Monkeyface, Cumberland (pearlymussel) Quadrula intermedia Unionid Mussels E;XN May Affect Monkey-flower, Michigan Mimulus glabratus var. michiganensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Monkshood, northern wild Aconitum noveboracense 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Moorhen, Hawaiian common Gallinula chloropus sandvicensis Coastal/Marine Bird E NLAAe Moorhen, Mariana common Gallinula chloropus guami Coastal/Marine Bird E NLAAe Mouse, Anastasia Island beach Peromyscus polionotus phasma Terrestrial Mammal E NLAAe,f Mouse, Pacific pocket Perognathus longimembris pacificus Terrestrial Mammal E NLAAe Mouse, salt marsh harvest Reithrodontomys raviventris Terrestrial Mammal E SFBE NLAAe 
2013 VGP and sVGP BE Section 7- Effects Summ

7-41 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Mouse, southeastern beach Peromyscus polionotus niveiventris Terrestrial Mammal T NLAAd,e,f Mucket, Neosho Lampsilis rafinesqueana Unionid Mussels C May Affect Mucket, orangenacre Lampsilis perovalis Unionid Mussels T May Affect Mucket, pink (pearlymussel) Lampsilis abrupta Unionid Mussels E MR May Affect Mudalia, black Elimia melanoides Unionid Mussels C May Affect Murrelet, Kittlitz's Brachyramphus brevirostris Coastal/Marine Bird C NLAAe Murrelet, marbled Brachyramphus marmoratus Coastal/Marine Bird T PS; SFBE NLAAg Murrelet, Xantus's Synthliboramphus hypoleucus Coastal/Marine Bird C NLAAe Mussel, oyster Epioblasma capsaeformis Unionid Mussels E;XN May Affect Mussel, scaleshell Leptodea leptodon Unionid Mussels E MR May Affect Mussel, sheepnose Plethobasus cyphyus Unionid Mussels E May Affect Mussel, snuffbox Epioblasma triquetra Unionid Mussels E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-42 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Mustard, Penland alpine fen Eutrema penlandii 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Nani wai`ale`ale Viola kauaiensis var. wahiawaensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Napa Bluegrass Poa napensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E SFBE May Affect 

Naucorid bug (=Furnace Creek), Nevares Spring Ambrysus funebris Beetle and Aquatic Insect C May Affect Naucorid, Ash Meadows Ambrysus amargosus Beetle and Aquatic Insect T May Affect Navarretia, few-flowered Navarretia leucocephala ssp. pauciflora (=N. pauciflora) 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Navarretia, many-flowered Navarretia leucocephala ssp. plieantha 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Navarretia, spreading Navarretia fossalis 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-43 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Niterwort, Amargosa Nitrophila mohavensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

No common name Cordia bellonis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

No common name Gesneria pauciflora 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

No common name Lysimachia filifolia 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

No common name Nesogenes rotensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

No common name Platanthera holochila 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-44 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

No common name Pteris lidgatei 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

No common name Sanicula purpurea 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

No common name Viola helenae 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Nohoanu Geranium multiflorum 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Ocelot Leopardus (=Felis) pardalis Terrestrial Mammal E NLAAd,e Oha wai Clermontia oblongifolia ssp. mauiensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Orchid, eastern prairie fringed Platanthera leucophaea 

FreshwaterSaltwater Aquatic and Wetland Plants 

T MR May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-45 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Orchid, white fringeless Platanthera integrilabia 

FreshwaterSaltwater Aquatic and Wetland Plants 

C May Affect 

Orcutt grass, California Orcuttia californica 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Orcutt grass, hairy Orcuttia pilosa 

FreshwaterSaltwater Aquatic and Wetland Plants 

E SFBE May Affect 

Orcutt grass, Sacramento Orcuttia viscida 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Orcutt grass, San Joaquin Orcuttia inaequalis 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Orcutt grass, slender Orcuttia tenuis 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Otter, Northern sea Enhydra lutris kenyoni Marine Mammal T May Affect Otter, Southern sea Enhydra lutris nereis Marine Mammal T;XN SFBE May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-46 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Owl's-clover, fleshy Castilleja campestris ssp. succulenta 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Palmate-bracted Bird's Beak Cordylanthus palmatus 

FreshwaterSaltwater Aquatic and Wetland Plants 

E SFBE May Affect 

Pamakani Viola chamissoniana ssp. chamissoniana 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Panic grass, Hirsts' Dichanthelium (=Panicum) hirstii 

FreshwaterSaltwater Aquatic and Wetland Plants 

C May Affect 

Panther, Florida Puma (=Felis) concolor coryi Terrestrial Mammal E BB NLAAg Pawpaw, beautiful Deeringothamnus pulchellus 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Pawpaw, Rugel's Deeringothamnus rugelii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Pearlshell, Alabama Margaritifera marrianae Unionid Mussels PE May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-47 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Pearlshell, Louisiana Margaritifera hembeli Unionid Mussels T May Affect Pearlymussel, birdwing Conradilla caelata Unionid Mussels E;XN May Affect Pearlymussel, cracking Hemistena lata Unionid Mussels E;XN May Affect Pearlymussel, Curtis Epioblasma florentina curtisii Unionid Mussels E May Affect Pearlymussel, dromedary Dromus dromas Unionid Mussels E;XN May Affect Pearlymussel, littlewing Pegias fabula Unionid Mussels E May Affect Pearlymussel, slabside Lexingtonia dolabelloides Unionid Mussels C May Affect Pebblesnail, flat Lepyrium showalteri Unionid Mussels E May Affect Petrel, Hawaiian dark-rumped Pterodroma phaeopygia sandwichensis Coastal/Marine Bird E NLAAe Pigtoe, Cumberland Pleurobema gibberum Unionid Mussels E May Affect Pigtoe, dark Pleurobema furvum Unionid Mussels E May Affect Pigtoe, finerayed Fusconaia cuneolus Unionid Mussels E;XN May Affect Pigtoe, flat Pleurobema marshalli Unionid Mussels E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-48 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Pigtoe, fuzzy Pleurobema strodeanum Unionid Mussels PT May Affect Pigtoe, Georgia Pleurobema hanleyianum Unionid Mussels E May Affect Pigtoe, heavy Pleurobema taitianum Unionid Mussels E May Affect Pigtoe, narrow Fusconaia escambia Unionid Mussels PT May Affect Pigtoe, oval Pleurobema pyriforme Unionid Mussels E May Affect Pigtoe, rough Pleurobema plenum Unionid Mussels E;XN May Affect Pigtoe, shiny Fusconaia cor Unionid Mussels E;XN May Affect Pigtoe, southern Pleurobema georgianum Unionid Mussels E May Affect Pigtoe, tapered Quincuncina burkei Unionid Mussels PT May Affect Pikeminnow (=squawfish), Colorado Ptychocheilus lucius 

Freshwater Fish/ Inland Salmonid 

E;XN May Affect 

Pimpleback, orangefoot (pearlymussel) Plethobasus cooperianus Unionid Mussels E;XN May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-49 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Pink, swamp Helonias bullata 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Pitcher-plant, Alabama canebrake Sarracenia rubra alabamensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Pitcher-plant, green Sarracenia oreophila 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Pitcher-plant, mountain sweet Sarracenia rubra ssp. jonesii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Plover, piping Charadrius melodus Coastal/Marine Bird E;T ULB; GB; SLE May Affect Plover, western snowy Charadrius alexandrinus nivosus Coastal/Marine Bird T SFBE May Affect Plymouth Red-Bellied Turtle Pseudemys rubriventris bangsi Snakes and Other Reptiles E May Affect Pocketbook, fat Potamilus capax Unionid Mussels E May Affect Pocketbook, finelined Lampsilis altilis Unionid Mussels T May Affect Pocketbook, Ouachita rock Arkansia wheeleri Unionid Mussels E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-50 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Pocketbook, shinyrayed Lampsilis subangulata Unionid Mussels E May Affect Pocketbook, speckled Lampsilis streckeri Unionid Mussels E May Affect Pondberry Lindera melissifolia 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Pondweed, Little Aguja (=Creek) Potamogeton clystocarpus 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Poolfish, Pahrump Empetrichthys latos 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Popcornflower, rough Plagiobothrys hirtus 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Potentilla, Hickman's Potentilla hickmanii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Prickly-apple, fragrant Cereus eriophorus var. fragrans 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-51 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Primrose, Maguire Primula maguirei 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Pseudoscorpion, Tooth Cave Tartarocreagris texana Beetle and Aquatic Insect E NLAAd,e Pu`uka`a Cyperus trachysanthos 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Pupfish, Ash Meadows Amargosa Cyprinodon nevadensis mionectes 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Pupfish, Comanche Springs Cyprinodon elegans 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Pupfish, desert Cyprinodon macularius 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Pupfish, Devils Hole Cyprinodon diabolis 

Freshwater Fish/ Inland Salmonid 

E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-52 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Pupfish, Leon Springs Cyprinodon bovinus 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Pupfish, Owens Cyprinodon radiosus 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Pupfish, Warm Springs Cyprinodon nevadensis pectoralis 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Quillwort, black spored Isoetes melanospora 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Quillwort, Louisiana Isoetes louisianensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Quillwort, mat-forming Isoetes tegetiformans 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Rabbitsfoot, rough Quadrula cylindrica strigillata Unionid Mussels E May Affect Rail, California clapper Rallus longirostris obsoletus Coastal/Marine Bird E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-53 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Rail, light-footed clapper Rallus longirostris levipes Coastal/Marine Bird E May Affect Rail, Yuma clapper Rallus longirostris yumanensis Coastal/Marine Bird E May Affect Redhorse, Sicklefin Moxostoma sp. 

Freshwater Fish/ Inland Salmonid 

C May Affect 

Reedgrass, Maui Calamagrostis expansa 

FreshwaterSaltwater Aquatic and Wetland Plants 

C May Affect 

Rhododendron, Chapman Rhododendron chapmanii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Riffle beetle, Stephan's Heterelmis stephani Beetle and Aquatic Insect C May Affect Riffleshell, northern Epioblasma torulosa rangiana Unionid Mussels E May Affect Riffleshell, tan Epioblasma florentina walkeri (=E. walkeri) Unionid Mussels E May Affect Ring pink (mussel) Obovaria retusa Unionid Mussels E;XN May Affect Ringed seal (Arctic) Phoca hispida hispida Marine Mammal PT May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-54 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Riversnail, Anthony's Athearnia anthonyi Unionid Mussels E;XN May Affect Rockfish, Canary Sebastes pinniger Estuarine/ Marine Fish T May Affect Rockfish, Yelloweye Sebastes ruberrimus Estuarine/ Marine Fish T May Affect Rocksnail, interrupted (=Georgia) Leptoxis foremani Unionid Mussels E May Affect Rocksnail, painted Leptoxis taeniata Unionid Mussels T May Affect Rocksnail, plicate Leptoxis plicata Unionid Mussels E May Affect Rocksnail, round Leptoxis ampla Unionid Mussels T May Affect Rose-mallow, Neches River Hibiscus dasycalyx 

FreshwaterSaltwater Aquatic and Wetland Plants 

C May Affect 

Roseroot, Leedy's Sedum integrifolium ssp. leedyi 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Salamander, Austin blind Eurycea waterlooensis Amphibian C May Affect Salamander, Barton Springs Eurycea sosorum Amphibian E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-55 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Salamander, California tiger Ambystoma californiense Amphibian E;T SFBE May Affect Salamander, Cheat Mountain Plethodon nettingi Amphibian T NLAAd,e Salamander, desert slender Batrachoseps aridus Amphibian E NLAAe Salamander, flatwoods Ambystoma cingulatum Amphibian T May Affect Salamander, Georgetown Eurycea naufragia Amphibian C May Affect Salamander, Jollyville Plateau Eurycea tonkawae Amphibian C May Affect Salamander, Salado Eurycea chisholmensis Amphibian C May Affect Salamander, San Marcos Eurycea nana Amphibian T May Affect Salamander, Santa Cruz long-toed Ambystoma macrodactylum croceum Amphibian E May Affect Salamander, Sonora tiger Ambystoma tigrinum stebbinsi Amphibian E May Affect Salamander, Texas blind Typhlomolge rathbuni Amphibian E May Affect Salmon, Atlantic Salmo salar Anadromous Salmonid E May Affect Salmon, Chinook Oncorhynchus tshawytscha Anadromous Salmonid E;T PS May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-56 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Salmon, chum Oncorhynchus keta Anadromous Salmonid T PS May Affect Salmon, coho Oncorhynchus kisutch Anadromous Salmonid E May Affect Salmon, sockeye Oncorhynchus nerka Anadromous Salmonid E;T May Affect sandshell, Southern Hamiota (=Lampsilis) australis Unionid Mussels PE May Affect Sandwort, Marsh Arenaria paludicola 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Sawfish, smalltooth Pristis pectinata Estuarine/ Marine Fish E GB; BB May Affect Sculpin, grotto Cottus sp. 

Freshwater Fish/ Inland Salmonid 

C May Affect 

Sculpin, pygmy Cottus paulus (=pygmaeus) 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Sea Lion, Steller Eumetopias jubatus Marine Mammal E PS; SFBE May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-57 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Sea turtle, green Chelonia mydas Sea Turtle E;T 

PS; ULB; 

GB; 

SFBE; 

BB 

NLAAe 

Sea turtle, hawksbill Eretmochelys imbricata Sea Turtle E ULB; GB; BB NLAAe Sea turtle, Kemp's ridley Lepidochelys kempii Sea Turtle E ULB; GB NLAAe Sea turtle, leatherback Dermochelys coriacea Sea Turtle E 

PS; ULB; 

GB; 

SFBE; 

BB 

NLAAe 

Sea turtle, loggerhead Caretta caretta Sea Turtle T 

ULB; GB; 

SFBE; 

BB 

NLAAe 

Sea turtle, olive ridley Lepidochelys olivacea Sea Turtle E;T SFBE NLAAe Seabeach Amaranth Amaranthus pumilus 

FreshwaterSaltwater Aquatic and Wetland Plants 

T ULB May Affect 

Seablite, California Suaeda californica 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Seagrass, Johnson's Halophila johnsonii Seagrass T BB May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-58 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Seal, Guadalupe fur Arctocephalus townsendi Marine Mammal T SFBE May Affect Seal, Hawaiian monk Monachus schauinslandi Marine Mammal E May Affect Seal, spotted Phoca largha Marine Mammal T May Affect Sedge, golden Carex lutea 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Sedge, Navajo Carex specuicola 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Shearwater, Newell's Townsend's Puffinus auricularis newelli Coastal/Marine Bird T May Affect Shiner, Arkansas River Notropis girardi 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Shiner, beautiful Cyprinella formosa 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Shiner, blue Cyprinella caerulea 

Freshwater Fish/ Inland Salmonid 

T May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-59 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Shiner, Cahaba Notropis cahabae 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Shiner, Cape Fear Notropis mekistocholas 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Shiner, palezone Notropis albizonatus 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Shiner, Pecos bluntnose Notropis simus pecosensis 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Shiner, sharpnose Notropis oxyrhynchus 

Freshwater Fish/ Inland Salmonid 

C May Affect 

Shiner, smalleye Notropis buccula 

Freshwater Fish/ Inland Salmonid 

C May Affect 

Shiner, Topeka Notropis topeka (=tristis) 

Freshwater Fish/ Inland Salmonid 

E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-60 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Shrew, Buena Vista Lake ornate Sorex ornatus relictus Terrestrial Mammal E NLAAe Shrimp, Alabama cave Palaemonias alabamae 

Freshwater Shrimps/ Crustacean 

E May Affect 

Shrimp, anchialine pool Metabetaeus lohena 

Freshwater Shrimps/ Crustacean 

C May Affect 

Shrimp, anchialine pool Palaemonella burnsi 

Freshwater Shrimps/ Crustacean 

C May Affect 

Shrimp, anchialine pool Procaris hawaiana 

Freshwater Shrimps/ Crustacean 

C May Affect 

Shrimp, anchialine pool Vetericaris chaceorum 

Freshwater Shrimps/ Crustacean 

C May Affect 

Shrimp, California freshwater Syncaris pacifica 

Freshwater Shrimps/ Crustacean 

E SFBE May Affect 

Shrimp, Kentucky cave Palaemonias ganteri 

Freshwater Shrimps/ Crustacean 

E May Affect 

Shrimp, Squirrel Chimney Cave Palaemonetes cummingi 

Freshwater Shrimps/ Crustacean 

T May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-61 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Silverside, Waccamaw Menidia extensa 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Silversword, Mauna Loa (=Ka'u) Argyroxiphium kauense 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Skipper, Carson wandering Pseudocopaeodes eunus obscurus Beetle and Aquatic Insect E May Affect Skipper, Laguna Mountains Pyrgus ruralis lagunae Beetle and Aquatic Insect E May Affect Skullcap, Florida Scutellaria floridana 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Slabshell, Chipola Elliptio chipolaensis Unionid Mussels T May Affect Smelt, delta Hypomesus transpacificus 

Freshwater Fish/ Inland Salmonid 

T SFBE May Affect 

Snail, armored Pyrgulopsis (=Marstonia) pachyta Unionid Mussels E May Affect Snail, Bliss Rapids Taylorconcha serpenticola Unionid Mussels T May Affect Snail, Chittenango ovate amber Succinea chittenangoensis Unionid Mussels T May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-62 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Snail, Diamond Y Spring Pseudotryonia (=Tryonia) adamantina Unionid Mussels C May Affect Snail, Newcomb's Erinna newcombi Unionid Mussels T May Affect Snail, Pecos assiminea Assiminea pecos Unionid Mussels E May Affect Snail, Phantom Cave Cochliopa texana Unionid Mussels C May Affect Snail, Snake River physa Physa natricina Unionid Mussels E May Affect Snail, tulotoma Tulotoma magnifica Unionid Mussels T May Affect Snake, Atlantic salt marsh Nerodia clarkii taeniata Snakes and Other Reptiles T May Affect Snake, copperbelly water Nerodia erythrogaster neglecta Snakes and Other Reptiles T May Affect Snake, eastern indigo Drymarchon corais couperi Snakes and Other Reptiles T BB NLAAg Snake, giant garter Thamnophis gigas Snakes and Other Reptiles T SFBE May Affect Snake, San Francisco garter Thamnophis sirtalis tetrataenia Snakes and Other Reptiles E May Affect Sneezeweed, Virginia Helenium virginicum 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-63 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Solano Grass Tuctoria mucronata 

FreshwaterSaltwater Aquatic and Wetland Plants 

E SFBE May Affect 

Sonoma Alopecurus Alopecurus aequalis var. sonomensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E SFBE May Affect 

Sparrow, Cape Sable seaside Ammodramus maritimus mirabilis Coastal/Marine Bird E BB NLAAe Spectaclecase Cumberlandia monodonta Unionid Mussels E May Affect Spikedace Meda fulgida 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Spinedace, Big Spring Lepidomeda mollispinis pratensis 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Spinedace, Little Colorado Lepidomeda vittata 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Spinedace, White River Lepidomeda albivallis 

Freshwater Fish/ Inland Salmonid 

E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-64 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Spinymussel, Altamaha Elliptio spinosa Unionid Mussels E May Affect Spinymussel, James Pleurobema collina Unionid Mussels E May Affect Spinymussel, Tar River Elliptio steinstansana Unionid Mussels E May Affect Spiraea, Virginia Spiraea virginiana 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Springfish, Hiko White River Crenichthys baileyi grandis 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Springfish, Railroad Valley Crenichthys nevadae 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Springfish, White River Crenichthys baileyi baileyi 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Springsnail (=Tryonia), Phantom Tryonia cheatumi Unionid Mussels C May Affect Springsnail, Alamosa Tryonia alamosae Unionid Mussels E May Affect Springsnail, Bruneau Hot Pyrgulopsis bruneauensis Unionid Mussels E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-65 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Springsnail, Chupadera Pyrgulopsis chupaderae Unionid Mussels PE May Affect Springsnail, elongate mud meadows Pyrgulopsis notidicola Unionid Mussels C May Affect Springsnail, Gonzales Tryonia circumstriata(=stocktonensis) Unionid Mussels C May Affect Springsnail, Huachuca Pyrgulopsis thompsoni Unionid Mussels C May Affect Springsnail, Koster's Juturnia kosteri Unionid Mussels E May Affect Springsnail, Page Pyrgulopsis morrisoni Unionid Mussels C May Affect Springsnail, Roswell Pyrgulopsis roswellensis Unionid Mussels E May Affect Springsnail, San Bernadino Pyrgulopsis bernardina Unionid Mussels E May Affect Springsnail, Socorro Pyrgulopsis neomexicana Unionid Mussels E May Affect Springsnail, Three Forks Pyrgulopsis trivialis Unionid Mussels E May Affect Spurge, Hoover's Chamaesyce hooveri 

FreshwaterSaltwater Aquatic and Wetland Plants 

T SFBE May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-66 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Stickleback, unarmored threespine 

Gasterosteus aculeatus williamsoni 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Stilt, Hawaiian Himantopus mexicanus knudseni Coastal/Marine Bird E May Affect Stirrupshell Quadrula stapes Unionid Mussels E May Affect Stonecrop, Lake County Parvisedum leiocarpum 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Stork, wood Mycteria americana Coastal/Marine Bird E BB NLAAe Storm-petrel, band-rumped Oceanodroma castro Coastal/Marine Bird C NLAAe Sturgeon, Alabama Scaphirhynchus suttkusi Anadromous Sturgeon E May Affect Sturgeon, green Acipenser medirostris Anadromous Sturgeon T SFBE May Affect Sturgeon, gulf Acipenser oxyrinchus desotoi Anadromous Sturgeon T BB May Affect Sturgeon, pallid Scaphirhynchus albus 

Freshwater Fish/ Inland Sturgeon 

E MR May Affect 

Sturgeon, shortnose Acipenser brevirostrum Anadromous Sturgeon E ULB; BB May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-67 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Sturgeon, white Acipenser transmontanus Anadromous Sturgeon E May Affect Sucker, June Chasmistes liorus 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Sucker, Lost River Deltistes luxatus 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Sucker, Modoc Catostomus microps 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Sucker, razorback Xyrauchen texanus 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Sucker, Santa Ana Catostomus santaanae 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Sucker, shortnose Chasmistes brevirostris 

Freshwater Fish/ Inland Salmonid 

E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-68 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Sucker, Warner Catostomus warnerensis 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Sucker, Zuni bluehead Catostomus discobolus yarrowi 

Freshwater Fish/ Inland Salmonid 

C May Affect 

Sunflower, Pecos (=puzzle, =paradox) Helianthus paradoxus 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Sunshine, Sonoma Blennosperma bakeri 

FreshwaterSaltwater Aquatic and Wetland Plants 

E SFBE May Affect 

Tadpole shrimp, vernal pool Lepidurus packardi 

Freshwater Shrimps/ Crustacean 

E SFBE May Affect 

Tern, California least Sterna antillarum browni Coastal/Marine Bird E NLAAe Tern, least Sterna antillarum Coastal/Marine Bird E MR NLAAe Tern, roseate Sterna dougallii dougallii Coastal/Marine Bird E;T ULB; BB NLAAe 
2013 VGP and sVGP BE Section 7- Effects Summ

7-69 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Thistle, Chorro Creek bog Cirsium fontinale var. obispoense 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Thistle, fountain Cirsium fontinale var. fontinale 

FreshwaterSaltwater Aquatic and Wetland Plants 

E SFBE May Affect 

Thistle, La Graciosa Cirsium loncholepis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Thistle, Loch Lomond coyote Eryngium constancei 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Thistle, Sacramento Mountains Cirsium vinaceum 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Thistle, Suisun Cirsium hydrophilum var. hydrophilum 

FreshwaterSaltwater Aquatic and Wetland Plants 

E SFBE May Affect 

Three-ridge, fat (mussel) Amblema neislerii Unionid Mussels E May Affect Thrush, small Kauai (=puaiohi) Myadestes palmeri Coastal/Marine Bird E NLAAd 
2013 VGP and sVGP BE Section 7- Effects Summ

7-70 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Tiger beetle, northeastern beach Cicindela dorsalis dorsalis Beetle and Aquatic Insect T NLAAe Tiger beetle, Puritan Cicindela puritana Beetle and Aquatic Insect T NLAAe Tiger beetle, Salt Creek Cicindela nevadica lincolniana Beetle and Aquatic Insect E NLAAe Toad, arroyo (=arroyo southwestern) 

Bufo californicus (=microscaphus) Amphibian E May Affect 

Toad, Houston Bufo houstonensis Amphibian E May Affect Toad, Wyoming Bufo baxteri (=hemiophrys) Amphibian E May Affect Toad, Yosemite Bufo canorus Amphibian C May Affect Topminnow, Gila (incl. Yaqui) Poeciliopsis occidentalis 

Freshwater Fish/ Inland Salmonid 

E May Affect 

Treefrog, Arizona Hyla wrightorum Amphibian C May Affect Trout, Apache Oncorhynchus apache 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Trout, bull Salvelinus confluentus 

Freshwater Fish/ Inland Salmonid 

T;XN PS May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-71 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Trout, Gila Oncorhynchus gilae 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Trout, greenback cutthroat Oncorhynchus clarki stomias 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Trout, Lahontan cutthroat Oncorhynchus clarki henshawi 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Trout, Little Kern golden Oncorhynchus aguabonita whitei 

Freshwater Fish/ Inland Salmonid 

T May Affect 

Trout, Paiute cutthroat Oncorhynchus clarki seleniris

Freshwater Fish/ Inland Salmonid 

T May Affect 

Trout, steelhead Oncorhynchus mykiss Anadromous Salmonid E PS; SFBE May Affect Tuctoria, Greene's Tuctoria greenei 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Turtle, Alabama red-belly Pseudemys alabamensis Snakes and Other Reptiles E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-72 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Turtle, bog (=Muhlenberg) Clemmys muhlenbergii Snakes and Other Reptiles T;T(S/A) ULB May Affect Turtle, flattened musk Sternotherus depressus Snakes and Other Reptiles T May Affect Turtle, ringed map Graptemys oculifera Snakes and Other Reptiles T May Affect Turtle, Sonoyta mud Kinosternon sonoriense longifemorale Snakes and Other Reptiles C May Affect Turtle, yellow-blotched map Graptemys flavimaculata Snakes and Other Reptiles T May Affect Vervain, Red Hills Verbena californica 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Vireo, least Bell's Vireo bellii pusillus Coastal/Marine Bird E NLAAd,e Vole, Amargosa Microtus californicus scirpensis Terrestrial Mammal E NLAAe Vole, Florida salt marsh Microtus pennsylvanicus dukecampbelli Terrestrial Mammal E NLAAe Warbler, nightingale reed (old world warbler) Acrocephalus luscinia Coastal/Marine Bird E NLAAe Wartyback, white (pearlymussel) Plethobasus cicatricosus Unionid Mussels E;XN May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-73 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Watercress, Gambel's Rorippa gambellii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Waterdog, black warrior (=Sipsey Fork) Necturus alabamensis Amphibian C May Affect Water-plantain, Kral's Sagittaria secundifolia 

FreshwaterSaltwater Aquatic and Wetland Plants 

T May Affect 

Water-umbel, Huachuca Lilaeopsis schaffneriana var. recurva 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Wedgemussel, dwarf Alasmidonta heterodon Unionid Mussels E May Affect Whale, beluga Delphinapterus leucas Marine Mammal E May Affect Whale, blue Balaenoptera musculus Marine Mammal E NLAAe Whale, bowhead Balaena mysticetus Marine Mammal E May Affect Whale, fin Balaenoptera physalus Marine Mammal E ULB; GB; BB May Affect Whale, gray Eschrichtius robustus Marine Mammal E May Affect 
2013 VGP and sVGP BE Section 7- Effects Summ

7-74 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Whale, humpback Megaptera novaeangliae Marine Mammal E PS; ULB; GB; BB NLAAe Whale, killer Orcinus orca Marine Mammal E PS; SFBE May Affect Whale, North Atlantic right whale Eubalaena glacialis Marine Mammal E ULB; BB May Affect Whale, North Pacific right whale Eubalaena japonica Marine Mammal E May Affect Whale, sei Balaenoptera borealis Marine Mammal E May Affect Whale, southern right Eubalaena australis Marine Mammal E May Affect Whale, sperm Physeter macrocephalus Marine Mammal E May Affect Whipsnake (=striped racer), Alameda 

Masticophis lateralis euryxanthus 

Snakes and Other Reptiles T SFBE NLAAg 

White Sedge Carex albida 

FreshwaterSaltwater Aquatic and Wetland Plants 

E SFBE May Affect 

Wild-rice, Texas Zizania texana 

FreshwaterSaltwater Aquatic and Wetland Plants 

E May Affect 

Wolf, red Canis rufus Terrestrial Mammal E;XN BB NLAAg 
2013 VGP and sVGP BE Section 7- Effects Summ

7-75 

Table 7-2. Effects Determination for Aquatic and Aquatic-dependent Species that May Be Affected by the 2013 VGP and sVGP 

Inverted Common Name Scientific Name 

Listed Species 

Taxonomic 

Groupa

Listing Statusb RAA Speciesc Effects Determin

for ANS 

Woodpecker, ivory-billed Campephilus principalis Coastal/Marine Bird E NLAAe Woodrat, riparian (=San Joaquin Valley) Neotoma fuscipes riparia Terrestrial Mammal E SFBE NLAAg Woundfin Plagopterus argentissimus 

Freshwater Fish/ Inland Salmonid 

E;XN May Affect 

a) Listed species taxonomic groups were determined based on taxonomic groups determined for 82 RAA listed species. See 

information. 

b) Listing status designations include: T= threatened; E=endangered; C=candidate; XN=experiment population, non-essential; PT=

proposed endangered; T(S/A)=threatened due to similarity of appearance. 

c) Species is present in one of the following RAAs: BB = Biscayne Bay, GB = Galveston Bay, PS = Puget Sound, SFBE = San Fran

Saint Luis River Estuary, UMR = Upper Mississippi River, ULB = Upper and Lower [New York] Bay. 

d) Source from NatureServe. e) Source from ecos.fws.gov’s information in the species profiles, including recovery plans, critical habitat, and other documents conta

f) Source from http://www.fws.gov/northflorida/Species-Accounts/Beach-Mice-2005.htm. 

g) See Appendix F for information about this species, including sources. h) EPA has determined that there will be no effect for the listed species. 
2013 VGP and sVGP BE Section 8- Cumulative Effects 

8-1 

SECTION 8 

CUMULATIVE EFFECTS 

Section 7 regulations require EPA to provide an analysis of cumulative effects, along 

with other information, when requesting initiation of formal consultation. Cumulative effects are 

the effects of future state, tribal, local, and private actions, not involving a Federal action, that 

are reasonably certain to occur within the action area under consideration. 50 C.F.R. § 402.02 

(emphasis added). 

EPA notes that most of the activities that are likely to impact species in the future are 

similar in nature to activities that have impacted species in the past; these activities were 

discussed in detail within the seven RAAs in the environmental baseline section of this BE (see 

Section 4.0). Anticipated non-federal future activities that are reasonably certain to occur in or 

near surface waters in the entire action area applicable in this BE include: timber harvesting, 

grazing, mining, agriculture, development, urban runoff, municipal and industrial wastewater 

discharges, road building, sand and gravel operations, introduction of non-native species, climate 

change, and commercial and recreational fishing. These non-federal actions are likely to continue 

exerting adverse effects on many or all of the listed species and designated critical habitats at 

issue. 

There are also non-federal future activities reasonably certain to occur in or near surface 

waters in the action area that are likely to have beneficial effects on some listed species and their 

designated critical habitat. These activities include: implementation of water conservation and reuse programs; toxic reduction and pollution prevention programs; riparian improvement 

measures; best management practices associated with timber harvesting, grazing, agricultural 

activities, urban development and urban retrofitting, and road building and retrofitting; road 

abandonment; restrictions on recreational activities; fishing quotas or limitations, and other nonpoint source pollution controls. However, despite these beneficial effects and the positive impact 

of actions to implement recovery plans, where in place, EPA believes that the overall cumulative 

effects from future state, local and private actions are likely to continue to stress listed species 

and their critical habitats. 
2013 VGP and sVGP BE Section 9- Interrelated and Interdependent 

9-1 

SECTION 9 

INTERRELATED AND INTERDEPENDENT ACTIONS 

Effects of the action under consultation are to be analyzed together with the effects of 

other activities that are interrelated to, or interdependent with, that action. An interrelated activity 

is an activity that is part of the proposed action and depends on the proposed action for its 

justification An interdependent activity is an activity that has no independent utility apart from 

the action under consultation [50 CFR § 402.02.] 

For the action under consultation, EPA is not aware of any interrelated or interdependent 

activities with effects on listed species or critical habitats. 
2013 VGP and sVGP BE Appendix A 

Appendix A. Discharge-Specific Technology-based Effluent Limits, Except 

Ballast Water, Required by the VGP for All Covered Vessels 
Proposed 2013 Vessel General Permit (VGP)

21 

referred to as “MARPOL vessels”) must have concentrations of oil less than 15 parts per million 

(ppm) (as measured by EPA Method 1664 or other appropriate method for determination of oil 

content as accepted by the International Maritime Organization (IMO) (e.g. ISO Method 9377) 

or U.S. Coast Guard) before discharge. All MARPOL vessels must have a current International 

Oil Pollution Prevention Certificate (IOPP) issued in accordance with 33 CFR §§ 151.19 or 

151.21. All other discharges of oil including oily mixtures must not contain oil in quantities that 

may be harmful, pursuant to 40 CFR Part 110. 

2.1.5 Compliance with Other Statutes and Regulations

As required by 40 CFR §122.44(p), you must comply with any applicable regulations 

promulgated by the Secretary of the Department in which the Coast Guard is operating that 

establish specifications for safe transportation, handling, carriage, and storage of pollutants. 

Any discharge from your vessel must comply with sections 311 (33 USC 1321) of the CWA, the 

Act to Prevent Pollution from Ships (APPS 33 USC §§ 1905-1915), the National Marine 

Sanctuaries Act, (16 USC 1431 et seq.) and implementing regulations found at 15 CFR Part 922 

and 50 CFR Part 404, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA, 7 USC § 

136 et seq.), and the Oil Pollution Act (OPA of 1990, 33 USC § 2701-2720). 

The US Code of Federal Regulations containing these provisions can be found at: 

www.gpoaccess.gov/ecfr/. 

2.1.6 General Training

All owner/operators of vessels must ensure that the master, operator, person-in-charge, and crew 

members who actively take part in the management of incidental discharges or who may affect 

those discharges are adequately trained in implementing the terms of this permit. This training 

need not be formal or accredited courses; however, it is the vessel owners/operators’ 

responsibility to ensure these staff are given the necessary information to conduct shipboard 

activities in accordance with the terms of this permit.

Vessel owners/operators must also meet all training-related recordkeeping requirements of Part 

4.2 of this permit. 

2.2 Effluent Limits and Related Requirements for Specific Discharge Categories 

The requirements in Part 2.2 constitute technology-based effluent limitations and related 

requirements except where it is specifically noted that the requirements constitute water quality 

based limits.

2.2.1 Deck Washdown and Runoff and Above Water Line Hull Cleaning 

Vessel owner/operators must minimize the introduction of on-deck debris, garbage, residue, and 

spill into deck washdown and runoff discharges. Before deck washdowns occur, you must broom 

clean exposed decks or use comparable management measures and remove all existing debris. 

When required by their class societies (e.g., oil tankers), their flag Administrations, or the U.S. 

Coast Guard, vessels must be fitted with and use perimeter spill rails and scuppers to collect the 
Proposed 2013 Vessel General Permit (VGP)

22 

runoff for treatment. Where feasible, machinery on deck must have coamings or drip pans where 

necessary to collect any oily discharge that may leak from machinery and prevent spills. The drip 

pans must be drained to a waste container for proper disposal and/or periodically wiped and 

cleaned. The presence of floating solids, visible foam, halogenated phenol compounds, and 

dispersants, or surfactants in deck washdowns must be minimized. Vessel owners/operators must 

minimize deck washdowns while in port. 

Vessel owners/operators must maintain their topside surface and other above water line portions 

of the vessel to minimize the discharge of rust (and other corrosion by-products), cleaning 

compounds, paint chips, non-skid material fragments, and other materials associated with 

exterior topside surface preservation. Furthermore, vessel owners/operators must minimize 

residual paint droplets from entering waters subject to this permit whenever they are conducting 

maintenance painting. Possible minimization techniques include, but are not limited to, avoiding 

paint spraying in windy conditions or avoiding overapplication of paint. This permit does not 

authorize the disposal of unused paint into waters subject to this permit. 

If deck washdowns or above water line hull cleaning will result in a discharge, they must be 

conducted with “non-toxic” and “phosphate free” cleaners and detergents as defined in Appendix 

A of this permit. Furthermore, cleaners and detergents should not be caustic and must be 

biodegradable. 

2.2.2 Bilgewater/Oily Water Separator Effluent 

All bilgewater discharges must be in compliance with the regulations in 40 CFR Parts 110 

(Discharge of Oil), 116 (Designation of Hazardous Substances), and 117 (Determination of 

Reportable Quantities for Hazardous Substances) and 33 CFR §151.10 (Control of Oil 

Discharges). In addition: 

• Vessel operators may not use dispersants, detergents, emulsifiers, chemicals, or 

other substances that remove the appearance of a visible sheen1 in their bilgewater 

discharges. This requirement does not prohibit the use of these materials in 

machinery spaces for the purposes of maintaining or cleaning equipment. 

• Except in the case of flocculants or other required additives (excluding any 

dispersants or surfactants) used to enhance oil/water separation during processing 

(after bilgewater has been removed from the bilge), vessel operators may not add 

substances that drain to the bilgewater that are not produced in the normal 

operation of a vessel. The use of oil solidifiers, flocculants, or other required 

additives are allowed only as part of an oil water separation system provided they 

do not alter the chemical make-up of the oils being discharged and any discharge 

of such materials into waters subject to this permit must be minimized. Routine 

cleaning and maintenance activities associated with vessel equipment and 

 

1 40 CFR 110.4 states that: “addition of dispersants or emulsifiers to oil to be discharged that would circumvent 

the provisions of this part is prohibited.” 33 CFR 151.10 (g) states that: “No discharge into the sea shall contain 

chemicals or other substances introduced for the purpose of circumventing the conditions of discharge specified in 

this regulation.
Proposed 2013 Vessel General Permit (VGP)

23 

structures are considered to be normal operation of a vessel if those practices fall 

within normal marine practice.

• All vessels must minimize the discharge of bilgewater into waters subject to this 

permit. This can be done by minimizing the production of bilgewater, disposing 

of bilgewater on shore where adequate facilities exist, or discharging into waters 

not subject to this permit (i.e., more than 3 nautical miles [nm] from shore) for 

vessels that regularly travel into such waters. Though not regulated under this 

permit, EPA notes that discharges of bilgewater outside waters subject to this 

permit (i.e., more than 3 nm from shore) are regulated under Annex I of the 

International Convention for the Prevention of Pollution from Ships as 

implemented by the Act to Prevent Pollution from Ships and U.S. Coast Guard 

regulations found in 33 CFR part 151. 

• Vessels greater than 400 gross tons shall not discharge untreated oily bilgewater 

into waters subject to this permit.

• Vessels greater than 400 gross tons that regularly sail outside the territorial sea (at 

least once per month) shall not discharge treated bilgewater within 1 nm of shore 

if technologically feasible (e.g., holding would not impact safety and stability, 

would not contaminate other holds or cargo, or would not interfere with essential 

operations of the vessel). Any discharge which is not technologically feasible to 

avoid must be documented as part of the requirements in Part 4.2 and reported to 

EPA as part of the vessel’s annual report. 

• Vessels greater than 400 gross tons shall not discharge treated bilgewater into 

waters referenced in Appendix G unless the discharge is necessary to maintain the 

safety and stability of the ship. Any discharge of bilgewater into these waters 

must be documented as part of the recordkeeping requirements in Part 4.2 and 

reported to EPA as part of the vessel’s annual report. 

• For vessels greater than 400 gross tons that regularly sail outside the territorial sea 

(at least once per month), if treated bilgewater is discharged into waters subject to 

this permit, it must be discharged when the vessel is underway (sailing at speeds 

greater than 6 knots), unless doing so would threaten the safety and stability of the 

ship. EPA notes that vessel operators may also choose to dispose of bilgewater on 

shore where adequate facilities exist. Any discharge which is made for safety 

reasons must be documented as part of the requirements in Part 4.2 and reported 

to EPA as part of the vessel’s annual report. 

Note: EPA is specifically seeking comment on whether to alter the bilgewater management 

regime for new build vessels and whether to provide existing vessels with additional bilgewater 

management options. Please see Part 4.4.2 of the Fact Sheet for details.

2.2.3 Ballast Water

All discharges of ballast water must comply with the requirements in this permit as described 

below. Additionally, owner/operators of all vessels subject to coverage under this permit which 

are equipped with Ballast Tanks must comply with any additional BMPs in this section. 
Proposed 2013 Vessel General Permit (VGP)

40 

extraordinary condition, to effect a BWE before entering the EEZ prior to entering the Great 

Lakes, must employ another method of ballast water management listed in 33 CFR 151.1510 or 

otherwise comply with the provision of 33 CFR 151.1514. 

Additionally, vessels utilizing a ballast water treatment system (see Part 2.2.3.5.1.1 of the 

permit) must also conduct ballast water exchange or saltwater flushing (as applicable) in addition 

to treating their ballast water if they meet the following requirements:

• The vessel operates outside the EEZ and more than 200 nm from any shore and 

then enters the Great Lakes via the Saint Lawrence Seaway System, and

• The vessel has taken on ballast water that has a salinity of less than 18 ppt from a 

coastal, estuarine, or freshwater ecosystem within the previous month. 

If a vessel affected by these requirements has not taken on ballast water with a salinity of less 

than 18 ppt in the previous month, the master of the vessel must certify to this effect in their 

ballast water recordkeeping requirements before entering the Great Lakes.

2.2.3.8 Vessels in the U.S. Coast Guard Shipboard Technology Evaluation Program 

(STEP)

Owner/operators of vessels are not required to meet the requirements of Parts 2.2.3.5 (except 

Parts 2.2.3.5.1.1.5 2.2.3.5.1.1.6) and 2.2.3.6 of this permit if either:

• The vessel is accepted by the U.S. Coast Guard into the Shipboard Technology 

Evaluation Program (STEP), 

• The technology is operated in accordance with requirements of that program, and 

• The acceptance has not been withdrawn

Owner/operators of these vessels are required to meet the requirements of Parts 2.2.3.5.1.1.5 and 

2.2.3.5.1.1.6 of this permit.

2.2.4 Anti-Fouling Hull Coatings/ Hull Coating Leachate 

• All anti-fouling hull coatings subject to registration under FIFRA (see 40 CFR § 

152.15) must be registered, sold or distributed, applied, maintained, and removed 

in a manner consistent with applicable requirements on the coatings’ FIFRA label. 

• For anti-fouling hull coatings not subject to FIFRA registration (i.e., not produced 

for sale and distribution in the United States), hull coatings must not contain any 

biocides or toxic materials banned for use in the United States (including those on 

EPA’s List of Banned or Severely Restricted Pesticides). This requirement applies 

to all vessels, including those registered and painted outside the United States. 

At the time of initial application or scheduled reapplication of anti-fouling coatings, you must 

give consideration, as appropriate for vessel class and vessel operations, to the use of hull 

coatings with the lowest effective biocide release rates, rapidly biodegradable components (once 

separated from the hull surface), or non-biocidal alternatives, such as silicone coatings.
Proposed 2013 Vessel General Permit (VGP)

41 

Some ports and harbors are impaired by copper, a biocide used commonly in anti-foulant paints. 

These waters include Shelter Island Yacht Basin in San Diego, California, and waters in and 

around the ports of Los Angeles/Long Beach. A complete list of such waters may be found at 

www.epa.gov/npdes/vessels. When vessels spend considerable time in these waters (defined as 

spending more than 30 days per year), or use these waters as their home port (i.e., house boats, 

ferries or rescue vessels), vessel owners/operators shall consider using anti-fouling coatings that 

rely on a rapidly biodegradable biocide or another alternative rather than copper-based coatings. 

If after consideration of alternative biocides, vessel operators continue to use copper-based 

antifoulant paints, they must document in their recordkeeping documentation how this decision 

was reached.

The discharge of Tributyltin (TBT) from any source (whether used as a biocide or not) or any 

other organotin compound used as a biocide is prohibited by this permit. Therefore, vessel 

owners/operators covered by this permit have a zero discharge standard for TBT (whether or not 

used as a biocide) or any other organotin compound used as a biocide. You may not use an 

antifoulant coating containing TBT or any other organotin compound used as a biocide. If the 

vessel has previously been covered with a hull coating containing TBT (whether or not used as a 

biocide) or any other organotin compound used as a biocide, vessels must be effectively 

overcoated so that no TBT or other organotin leaches from the vessel hull or the TBT or other 

organotin coating must have been removed from the vessel’s hull. 

When used as a catalyst, an organotin compound other than TBT (e.g., dibutyltin) is not to be 

present above 2500 mg total tin per kilogram of dry paint. Furthermore, the coating shall not be 

designed to slough or otherwise peel from the vessel hull. Incidental amounts of coating 

discharged by abrasion during cleaning or after contact with other hard surfaces (e.g., moorings) 

are not prohibited. 

2.2.5 Aqueous Film Forming Foam (AFFF)

Discharges of AFFF are authorized for emergency purposes when needed to ensure the safety 

and security of the vessel and crew.

For vessels that sail outside of the territorial sea more than once per month, maintenance and 

training discharges of fluorinated AFFF are not authorized within waters subject to this permit 

(any such discharges should be collected and stored for onshore disposal or scheduled when the 

vessel is outside such waters). Discharge volumes associated with regulatory certification and 

inspection must be minimized and a substitute foaming agent (i.e., non-fluorinated) must be used 

if possible within waters subject to this permit.

For vessels that do not leave the territorial sea more than once per month, if vessel maintenance 

and training discharges are required, AFFF must be collected and stored for onshore disposal 

unless the vessel uses a non-fluorinated or alternative foaming agent. Training should be 

conducted as far from shore as is practicable. Maintenance and training discharges are not 

allowed in port. 

For all vessels, AFFF discharges may not occur in or within 1 nm of a water referenced in 

Appendix G unless they are discharged:
Proposed 2013 Vessel General Permit (VGP)

42 

• For emergency purposes; 

• By rescue vessels such as fireboats for firefighting purposes; or 

• By vessels owned or under contract to do business exclusively in or within 1 nm 

of those protected areas by the United States government or state or local 

governments. 

If AFFF discharges occur in waters referenced in Appendix G for emergency purposes, a written 

explanation must be kept in the ship’s log or other vessel recordkeeping documentation 

consistent with Part 4.2 of this permit.

2.2.6 Boiler/Economizer Blowdown 

You must minimize the discharge of boiler/economizer blowdown in port if chemicals or other 

additives are used to reduce impurities or prevent scale formation. For vessels greater than 400 

gross tons which leave the territorial sea at least once per week, boiler/economizer blowdown 

may not be discharged in waters subject to this permit, unless: 

• The vessel remains within waters subject to this permit for a longer period than 

the necessary duration between blowdown cycles; 

• The vessel needs to conduct blowdown immediately before entering drydock; or 

• For safety purposes. 

For all vessels, boiler/economizer blowdown may not be discharged in waters referenced in 

Appendix G except for safety purposes. Furthermore, boiler/economizer blowdown should be 

discharged as far from shore as practicable.

2.2.7 Cathodic Protection 

Cathodic protection must be maintained to prevent the corrosion of the ship’s hull. The discharge 

of zinc, magnesium, and aluminum are expected from properly functioning cathodic protection 

sacrificial electrodes. However, vessel operators must minimize the flaking of large, corroded 

portions of these anodes. Sacrificial anodes must not be used more than necessary to adequately 

prevent corrosion of the vessel’s hull, sea chest, rudder, and other exposed areas of the vessel. 

Vessel operators must appropriately clean and/or replace these anodes during periods of 

maintenance (such as drydocking), so that release of these metals to waters is minimized. 

Furthermore, when feasible, sacrificial anodes should be flush-fitted to the hull, or vessel 

operators must fill the space between the anode and hull backing to remove the potential for 

hotspots for fouling organisms. 

Vessel operators should note that magnesium is less toxic than aluminum and aluminum is less 

toxic than zinc. If vessel operators use sacrificial electrodes, they must select electrode devices 

with metals that are less toxic to the extent technologically feasible and economically practicable 

and achievable. If a vessel selects aluminum, they must document in their recordkeeping 

documentation why they made this selection, and why use of magnesium is not appropriate. 

Likewise, if a vessel selects zinc, they must document why they did not select magnesium or 

aluminum.
Proposed 2013 Vessel General Permit (VGP)

43 

EPA recommends the use of Impressed Current Cathodic Protection (ICCP) in place of or to 

reduce the use of sacrificial electrodes when technologically feasible (e.g., adequate power 

sources, appropriate for vessel hull size and design), safe, and adequate to protect against 

corrosion, particularly for new vessels. If vessel operators use ICCP, they must maintain 

dielectric shields to prevent flaking. 

2.2.8 Chain Locker Effluent

The anchor chain must be carefully and thoroughly washed down (i.e., more than a cursory rinse) 

as it is being hauled out of the water to remove sediment and marine organisms. In addition, 

chain lockers must be cleaned thoroughly during dry-docking to eliminate accumulated 

sediments and any potential accompanying pollutants. For vessels that regularly sail outside 

waters subject to this permit (at least once per month), if technically feasible, periodically clean,

rinse, and/or pump out the space beneath the chain locker prior to entering waters subject to this 

permit (preferably mid-ocean) if the anchor has been lowered into any nearshore waters. 

Furthermore, for vessels that leave waters subject to this permit at least once per month, chain 

lockers shall not be rinsed or pumped out in waters subject to this permit, unless not emptying 

them would compromise safety. Such a safety claim must be documented in the vessel’s 

recordkeeping documentation consistent with Part 4.2. 

2.2.9 Controllable Pitch Propeller and Thruster Hydraulic Fluid and Other Oil-toSea Interfaces Including Lubrication Discharges from Paddle Wheel 

Propulsion, Stern Tubes, Thruster Bearings, Stabilizers, Rudder Bearings, 

Azimuth Thrusters, Propulsion Pod Lubrication, and Wire Rope and 

Mechanical Equipment Subject to Immersion

The protective seals on controllable pitch propellers, azimuth thrusters, propulsion pods, rudder 

bearings, or any other oil-to-sea interfaces must be maintained in good operating order to 

minimize the leaking of hydraulic oil or other oils. The vessel owner/operator must not discharge 

oil in quantities that may be harmful as defined in 40 CFR Part 110 from any oil-to-sea interface. 

If possible, maintenance activities on controllable pitch propellers, thrusters, and other oil-to-sea 

interfaces should be conducted when a vessel is in drydock. 

Minimize maintenance activities on stern tube seals when a vessel is outside of drydock. If 

maintenance or emergency repair must occur on stern tubes or other oil-to-sea interfaces which 

have a potential to release oil in quantities that may be harmful as defined in 40 CFR Part 110, 

appropriate spill response equipment (e.g., oil booms) must be used to contain any oil leakage. 

Operators of the vessel must have ready access to spill response resources to clean up any oil 

spills.

After applying lubrication to wire rope and mechanical equipment subject to immersion, wire 

ropes, and other equipment must be thoroughly wiped down to remove excess lubricant. 

All vessels constructed on or after December 19, 2013 must use an environmentally acceptable 

lubricant in all oil-to-sea interfaces. “Environmentally acceptable lubricants” means lubricants 

that are “biodegradable” and “non-toxic” and are not “bioaccumulative” as defined in Appendix 

A of this permit. 
Proposed 2013 Vessel General Permit (VGP)

44 

For all vessels built before December 19, 2013, unless technically infeasible, owners/operators 

must use an environmentally acceptable lubricant in all oil to sea interfaces. If a vessel is unable 

to use an environmentally acceptable lubricant, you must document in your recordkeeping 

documentation consistent with Part 4.2 why you are unable to do so, and must report the use of a 

non-environmentally acceptable lubricant to EPA in your Annual Report. Use of an 

environmentally acceptable lubricant does not authorize the discharge of any lubricant in a 

quantity that may be harmful as defined in 40 CFR Part 110. 

2.2.10 Distillation and Reverse Osmosis Brine

Brine from the distillation system and reverse osmosis reject water shall not contain or come in 

contact with machinery or industrial equipment (other than that necessary for the production of 

potable water), toxic or hazardous materials, or wastes. 

2.2.11 Elevator Pit Effluent

Discharges of untreated elevator pit effluent are not authorized within waters subject to this 

permit except in cases of emergency. Elevator pit effluent may be discharged into waters subject 

to this permit if it is managed with the vessel’s bilgewater and meets all the requirements of Part 

2.2.2 of this permit. Otherwise, it must be treated with an oily-water separator and discharged 

with an oil content below 15 ppm for existing vessels, as measured by EPA Method 1664 or 

other appropriate method for determination of oil content as accepted by the IMO (e.g., ISO 

Method 9377) or U.S. Coast Guard. Emergency discharges must be documented in the ship’s log 

or other vessel recordkeeping documentation consistent with Part 4.2. 

2.2.12 Firemain Systems

Discharges from firemain systems are authorized for emergency purposes to ensure the safety 

and security of the vessel and her crew, other emergency situations, and testing and inspections 

of the firemain systems in order to assure its operability in an emergency. Firemain systems may 

be discharged in port for certification, maintenance, and training requirements if the intake 

comes directly from the surrounding waters or potable water supplies and there are no additions 

(e.g., AFFF) to the discharge. Furthermore, firemain systems may be used for deck washdown or 

other secondary uses if the intake comes directly from the surrounding waters or potable water 

supplies and the discharge meets all relevant effluent limitation associated with that activity. 

When feasible, maintenance and training should be conducted outside port and/or outside waters 

subject to this permit. 

The vessel owner/operator shall not discharge firemain systems in waters listed in Appendix G

except in emergency situations or when washing down the anchor chain to comply with anchor 

wash down requirements in Part 2.2.8. 

2.2.13 Freshwater Layup

Minimize the amount of disinfection or biocidal agents used in freshwater layup to the minimum 

required to prevent aquatic growth. 
Proposed 2013 Vessel General Permit (VGP)

45 

2.2.14 Gas Turbine Washwater 

Gas turbine washwater must not be directly discharged within waters subject to this permit. 

Where feasible, gas turbine washwater must be prevented from commingling with bilgewater 

that will be discharged in waters subject to this permit, for example by collecting it separately 

and properly disposing of it at an onshore facility. Under no circumstances may oils, including 

oily mixtures, from gas turbine washwater be discharged into waters subject to this permit in 

quantities that may be harmful as determined in accordance with 40 CFR Part 110. 

2.2.15 Graywater

All vessels must minimize the discharge of graywater while in port. For those vessels that cannot 

store graywater, the owner or operator and their crews must minimize the production of 

graywater in port. Examples of ways to minimize production of graywater include delaying 

laundry, scullery activities, and restricting length of showers while in port, and using high 

efficiency faucets and showerheads. All vessels that have the capacity to store graywater shall

not discharge it in waters listed in Appendix G. For vessels that cannot store graywater, vessel 

operators must minimize the production of graywater while in waters listed in Appendix G. 

For vessels greater than 400 gross tons that regularly travel more than 1 nm from shore that have 

the capacity to store graywater for a sufficient period, graywater must be discharged greater than 

1 nm from shore while the vessel is underway, unless the vessel meets the treatment standards 

and other requirements contained under Parts 5.1.1 and 5.1.2 or 5.2.1 and 5.2.2 of this permit. 

Additional specific requirements for graywater apply to cruise ships (Parts 5.1 and 5.2) and large 

ferries (Part 5.3).

Vessels that do not travel more than 1 nm from shore shall minimize the discharge of graywater 

and, provided the vessel has available graywater storage capacity, must dispose of graywater 

onshore if appropriate facilities are available and such disposal is economically practicable and 

achievable unless the vessel meets the treatment standards and other requirements contained 

under Parts 5.1.1 and 5.1.2 or 5.2.1 and 5.2.2 of this permit. You must also minimize the 

discharge of graywater when the vessel is not underway. 

If graywater will be discharged in waters subject to this permit, the introduction of kitchen oils to 

the graywater system must be minimized. When cleaning dishes, you must remove as much food 

and oil residue as practicable before rinsing dishes. Excess oils used in cooking, including animal 

fats and vegetable oils, shall not be added to the graywater system. Under no circumstances may 

oil from the galley and scullery be discharged in quantities that may be harmful as defined in 40 

CFR Part 110. 

Vessel owners/operators must use phosphate-free and non-toxic soaps and detergents, as defined 

in Appendix A of this permit, for any purpose if graywater will be discharged into waters subject 

to this permit. Soaps and detergents must be free from toxic or bioaccumulative compounds and 

not lead to extreme shifts in receiving water pH. For purposes of this part, extreme shifts means 

causing pH to fall below 6.0 or rise above 9.0 as a direct result of the discharge. 
Proposed 2013 Vessel General Permit (VGP)

46 

If your vessel is underway in a nutrient-impaired water, or a water that is impaired as a result of 

nutrient enrichment (such as waters listed as impaired for phosphorus, nitrogen, or for hypoxia or 

anoxia [low dissolved oxygen concentrations]), you must follow these additional requirements: 

When the vessel has adequate graywater storage capacity, the vessel owner/operator shall not 

discharge graywater into nutrient-impaired waters subject to this permit (e.g., the Chesapeake 

Bay). A complete list of such waters can be found at www.epa.gov/npdes/vessels. Where the 

vessel does not have adequate storage capacity to eliminate such discharges, graywater 

production and discharge must be minimized in such waters. Any such discharge must be 

conducted while the vessel is underway in areas with significant circulation and depth to the 

extent feasible. Graywater stored while in such waters can later be disposed of onshore or 

discharged in accordance with the other requirements of this permit.

2.2.15.1 Additional Graywater Requirements for Certain VGP Vessels Operating in the 

Great Lakes 

Any vessel operating on the Great Lakes that is not a “commercial vessel” as defined in 

CWA section 312(a)(10) must meet one of the following requirements for graywater 

management:

(i) The vessel must hold all graywater for onshore discharge to an appropriate 

shoreside facility; or 

(ii) The graywater discharge must not exceed 200 fecal coliforms per 100 milliliters 

and contain no more than 150 milligrams per liter of suspended solids. 

Vessels subject to this part must conduct monitoring required under Part 2.2.15.2 to demonstrate 

treatment equipment maintenance and compliance with the limits of this part. Records of the 

sampling and testing results must be retained onboard for a period of 3 years in the vessel’s 

recordkeeping documentation consistent with Part 4.2 of this permit.

2.2.15.2 Graywater Monitoring

The following monitoring requirements are applicable to vessels which discharge graywater into 

waters subject to this permit and meet one of the following conditions: 

• The vessel is a new build vessel constructed on or after December 19, 2013, has a 

maximum crew capacity greater or equal to 10, and provides overnight 

accommodations to those crew; or 

• The vessel is subject to Part 2.2.15.1 of this permit.

Vessel owners/operators must conduct and analyze two samples per year, at least 14 days apart, 

and report the results of those samples as part of their Annual Report. Samples must be taken for 

Biochemical Oxygen Demand (BOD), fecal coliform, suspended solids, pH, and total residual 

chlorine. Sampling and testing shall be conducted according to 40 CFR Part 136. If the vessel is 

subject to Part 2.2.15.1, measured samples must meet the standards specified in that part.

Records of monitoring information shall include: 
Proposed 2013 Vessel General Permit (VGP)

47 

• The date, exact place, and time of sampling or measurements;

• The individual(s) who performed the sampling or measurements; 

• The date(s) analyses were performed;

• The individual(s) who performed the analyses; 

• The analytical techniques or methods used; and 

• The results of such analyses.

Vessels subject to this part must note whether the graywater effluent is treated or untreated, and 

also note whether the effluent is graywater alone or if it is mixed with another effluent type (e.g., 

graywater mixed with sewage). Records of the sampling and testing results must be retained 

onboard for a period of 3 years in the vessel’s recordkeeping documentation consistent with Part 

4.2. 

Vessels which do not enter waters subject to this permit for the calendar year need not conduct 

monitoring for that year, but must clearly indicate on their Annual Report that they did not enter 

waters subject to this permit during that year. 

2.2.16 Motor Gasoline and Compensating Discharge 

The discharge of motor gasoline and compensating effluent must not have oil in quantities that 

may be harmful as defined in 40 CFR § 110.3, which includes discharges resulting in a visible 

sheen, or an oil concentration that exceeds 15 ppm. Determination of oil concentration may be 

measured by EPA Method 1664 or other appropriate method for determination of oil content as 

accepted by the IMO (e.g., ISO Method 9377) or U.S. Coast Guard. Compliance with the 15 ppm 

oil concentration limitation may be established with visual monitoring for an oily sheen. 

Minimize discharge of motor gasoline and compensating discharge in port. If an oily sheen is 

observed, the vessel operator must deploy appropriate oil containment practices. Vessels shall 

not discharge motor gasoline and compensating discharge in waters subject to this permit listed 

in Appendix G. 

2.2.17 Non-Oily Machinery Wastewater

If discharged directly overboard, non-oily machinery wastewater must be free from oils (in 

quantities that may be harmful pursuant to 40 CFR Part 110) and any additives that are toxic or 

bioaccumulative in nature. Non-oily machinery wastewater may also be drained to the bilge.

2.2.18 Refrigeration and Air Condensate Discharge 

You must not allow refrigeration and air condensate discharge to come into contact with oily or 

toxic materials if it is discharged directly overboard. Refrigeration and air conditioning 

condensate that is collected and plumbed for internal recycling (e.g., recycled as “technical 

water”) is allowed to commingle with oily water; however, the commingled discharge must meet 

all requirements of Part 2.1.4 of this permit and Part 2.2.2 of this permit if applicable.
Proposed 2013 Vessel General Permit (VGP)

48 

2.2.19 Seawater Cooling Overboard Discharge (Including Non-Contact Engine 

Cooling Water; Hydraulic System Cooling Water, Refrigeration Cooling Water) 

When possible, non-contact engine cooling water, hydraulic system cooling water, refrigeration 

cooling water and other seawater cooling overboard discharges should occur when the vessel is 

underway to minimize any thermal impacts to the receiving water. 

To reduce the production and discharge of seawater cooling overboard discharge, EPA 

recommends that vessel owner/operators use shore-based power when the vessel is in port if: 

• Shore power is readily available for vessel owner/operators from utilities or port 

authorities;

• Shore-based power supply systems are capable of providing all needed electricity 

required for vessel operations; and 

• The vessel is equipped to connect to shore-based power and such systems are 

compatible with the available shore power. 

Maintenance of all piping and seawater cooling systems must meet the requirements of Part 

2.2.20 (Seawater-Piping Biofouling Prevention). 

2.2.20 Seawater Piping Biofouling Prevention 

Seawater piping biofouling chemicals subject to FIFRA registration (see 40 CFR § 152.15) must 

be used in accordance with their FIFRA label. No pesticides or chemicals banned for use in the 

United States may be discharged into waters subject to this permit.

Vessel owner/operators must use the minimum amount of biofouling chemicals needed to keep 

fouling under control. Discharges containing active agents must contain as little chlorine as 

possible. 

Vessel owner/operators must remove fouling organisms from seawater piping on a regular basis 

and dispose of removed substances in accordance with local, state, and federal regulations. 

Removed fouling organisms shall not be discharged into waters subject to this permit and EPA 

recommends that if discharged into any waters, should be discharged more than 50 nm from 

shore. Vessel owner/operators should remove any organisms while at sea to reduce the risk of 

invasive species introduction in ports. 

2.2.21 Boat Engine Wet Exhaust 

Vessel engines generating wet exhaust must be maintained in good operating order, well tuned, 

and function according to manufacturer specifications to decrease pollutant contributions to wet 

exhaust. Vessel owner/operators should use low sulfur or alternative fuels for their vessels to 

reduce the concentration of pollutants in discharges from boat engine wet exhaust. 

EPA encourages vessel operators to consider four stroke engines instead of two stroke engines 

for vessels generating wet exhaust that are covered under this permit. Use of a four stroke engine 

may minimize the discharge of pollutants to waters subject to this permit. Where vessels utilize 

two stroke engines, environmentally acceptable lubricants (as defined in Appendix A of this 
Proposed 2013 Vessel General Permit (VGP)

49 

permit) must be used unless technologically infeasible. If technologically infeasible, the vessel 

owner/operator must document in their recordkeeping documentation why they are not using 

environmentally acceptable lubricants. 

2.2.22 Sonar Dome Discharge 

The water inside the sonar dome shall not be discharged into waters subject to this permit for 

maintenance purposes. Vessel operators should not use biofouling chemicals that are 

bioaccumulative for the exterior of sonar domes when non-bioaccumulative alternatives are 

available.

2.2.23 Underwater Ship Husbandry Discharges 

Vessel owners/operators must minimize the transport of attached living organisms when 

traveling into U.S. waters from outside the U.S. economic zone or between Captain of the Port 

(COTP) zones.

Whenever possible, rigorous hull-cleaning activities should take place in drydock, or at a landbased facility where the removal of fouling organisms or spent antifouling coatings paint can be 

contained. If water-pressure-based systems are used to clean the hull and remove old paint, you 

must use facilities which treat the washwater prior to discharging to waters subject to this permit 

in order to remove the antifouling compound(s) and fouling growth from the washwater. If 

mechanical means (scraping, etc.) are used to clean the hull and remove old paint, the materials 

removed from the hull during that process must be collected and disposed of properly (e.g., 

onshore). These materials must not be allowed to contaminate nearby waters. 

Vessel owners/operators who remove fouling organisms from hulls while the vessel is 

waterborne must employ methods that minimize the discharge of fouling organisms and 

antifouling hull coatings. These shall include: 

• Use of appropriate cleaning brush or sponge rigidity to minimize removal of 

antifouling coatings and biocide releases into the water column; 

• Limiting use of hard brushes and surfaces to the removal of hard growth; and 

• When available and feasible, use of vacuum or other control technologies to 

minimize the release or dispersion of antifouling hull coatings and fouling 

organisms into the water column. 

Vessel owners/operators must minimize the release of copper-based antifoulant paints during 

vessel cleaning operations. Cleaning of hull surfaces coated with copper-based antifoulant paint 

must not result in any visible cloud or plume of paint in the water; if a visible cloud or plume of 

paint develops, shift to a softer brush or less abrasive cleaning technique. A plume or cloud of 

paint can be noted by the presence of discoloration or other visible indication that is 

distinguishable from hull growth or sediment removal. Production of a plume or cloud of 

sediment or hull growth is normal in some cases during vessel hull cleaning, but this plume or 

cloud must be substantially paint free (e.g., paint should not be clearly identifiable in the plume 

or cloud). When feasible, attempts must be made to minimize the release of fouling organisms 

and antifouling systems (including copper-based coatings) into surrounding waters. 
Proposed 2013 Vessel General Permit (VGP)

50 

Vessels that use copper-based anti-fouling paint must not clean the hull in copper-impaired 

waters within the first 365 days after paint application unless there is a significant visible 

indication of hull fouling. EPA maintains a list of copper-impaired waters on its webpage at 

www.epa.gov/npdes/vessels. If you clean before 365 days in copper-impaired waters, you must 

document in your recordkeeping documentation why this early cleaning was necessary. 

2.2.24 Welldeck Discharges

Welldeck discharges that contain graywater from smaller vessels should not be discharged within 

waters subject to this permit except in cases of emergency. Welldeck discharges from washdown 

of gas turbine engines may not be discharged within waters subject to this permit. Welldeck 

discharges from equipment and vehicle washdowns must be free from garbage and must not 

contain oil in quantities that may be harmful as defined in 40 CFR Part 110. 

2.2.25 Graywater Mixed with Sewage from Vessels

The commingled discharge of graywater mixed with sewage from vessels must comply with the 

effluent limits for graywater discharge in Part 2.2.15 or Part 5 of this permit if applicable. 

Though not a requirement of this permit, vessel owner/operators are advised that all discharges 

commingled with sewage must meet the requirements set forth in section 312 of the CWA and its 

implementing regulations found at 40 CFR Part 140 and 33 CFR Part 159. Hence, discharges of 

graywater mixed with sewage must meet both standards to be in compliance with the CWA.

2.2.26 Exhaust Gas Scrubber Washwater Discharge 

Exhaust gas scrubber washwater discharge must not contain oil, including oily mixtures, in 

quantities that may be harmful as determined in accordance with 40 CFR Part 110. Sludge or 

residues generated in treating exhaust gas scrubber washwater discharge must not be discharged 

in waters subject to this permit and must be delivered ashore to adequate reception facilities. 

In addition, owner/operators of vessels with exhaust gas cleaning systems that result in 

washwater discharges must meet the numeric effluent limits found in Part 2.2.26.1 and the 

monitoring requirements found in Part 2.2.26.2 this permit. These limits are consistent with the 

IMO guidelines set forth in section 10 for Exhaust Gas Cleaning (EGC) Systems (resolution 

MEPC.184(59)). Among other things, these guidelines recommend the establishment of limits 

for concentrations of pollutants in the effluent. 

2.2.26.1 Exhaust Gas Scrubber Treatment Standards

2.2.26.1.1 pH 

The discharge washwater from the exhaust gas scrubber treatment system must have a pH of no 

less than 6.5 measured at the ship’s overboard discharge, with the exception that during 

maneuvering and transit, the maximum difference between inlet and outlet of 2.0 pH units is 

allowed. This difference is to be measured at the ship’s inlet and overboard discharge. 
Proposed 2013 Vessel General Permit (VGP)

51 

2.2.26.1.2 PAHs (Polycyclic Aromatic Hydrocarbons) 

The maximum continuous PAH concentration in the washwater must not be greater than 50 μg/L 

PAHphe (phenanthrene equivalence) above the inlet water PAH concentration for washwater 

flow rates normalized to 45 t/MWh. MWh refers to the maximum continuous rating (MCR) or 80 

percent of the power rating of the fuel oil combustion unit. For the purposes of this criterion, the 

PAH concentration in the washwater must be measured downstream of the water treatment 

equipment, but upstream of any washwater dilution or other reactant dosing unit, if used, prior to 

discharge. 

 The 50-μg/L limit is adjusted upward for lower washwater flow rates per MWh, and vice-versa, 

and the applicable permit limits are contained in Table 7. 

Table 7: PAH Permit Limits in Exhaust Gas Scrubber Discharge

Flow Rate

(t/MWh)

Discharge Concentration Limit

(μg/L PAHphe equivalents)

Measurement Technology

0 - 1 2,250 Ultraviolet Light

2.5 900 Ultraviolet Light

5 450 Fluorescence

11.25 200 Fluorescence

22.5 100 Fluorescence

45 50 Fluorescence

90 25 Fluorescence

2.2.26.1.3 Turbidity 

The washwater treatment system must be designed to minimize suspended particulate matter, 

including heavy metals and ash. The maximum turbidity (monitored continuously) in washwater 

must not be greater than 25 FNU (formazin nephelometric units) or 25 NTU (nephelometric 

turbidity units) or equivalent units, above the inlet water turbidity. However, during periods of 

high inlet turbidity, the precision of the measurement device and the time lapse between inlet 

measurement and outlet measurement are such that the use of a difference limit is unreliable. 

Therefore, all turbidity difference readings must be a rolling average over a 15-minute period to 

a maximum of 25 FNU or NTU. For the purposes of this criterion, the turbidity in the washwater 

must be measured downstream of the water treatment equipment but upstream of washwater 

dilution (or other reactant dosing) prior to discharge. For a maximum of one 15-minute period 

within any 12-hour period, the continuous turbidity discharge limit may be exceeded by 20 

percent.

2.2.26.1.4 Nitrates +Nitrites

The washwater treatment system must prevent the discharge of nitrates, plus nitrites beyond that 

associated with a 12 percent removal of NOx from the exhaust, or beyond 60 mg/l normalized for 

washwater discharge rate of 45 tons/MWh, whichever is greater. MWh refers to the MCR or 80 

percent of the power rating of the fuel oil combustion unit. For the purposes of this criterion, the 

nitrate concentration in the washwater must be measured downstream of the water treatment 
Proposed 2013 Vessel General Permit (VGP)

52 

equipment, but upstream of any washwater dilution or other reactant dosing unit, if used, prior to 

discharge.

The 60-mg/L limit is adjusted upward for lower washwater flow rates per MWh, and vice-versa, 

and the applicable permit limits are contained in Table 8. 

Table 8: Nitrates + Nitrites Permit Limits in Exhaust Gas Scrubber Discharge

Flow Rate

(t/MWH)

Discharge Concentration Limit

(mg/L nitrate + nitrite)

0 - 1 2,700

2.5 1,080

5 640

11.25 240

22.5 120

45 60

90 30

2.2.26.2 Exhaust Gas Scrubber Analytical Monitoring Requirements

2.2.26.2.1 Continuous Monitoring 

The data recording system must comply with the guidelines in sections 7 and 8 of 

MEPC.184(59) and must continuously record pH, PAH, and turbidity. 

When the EGC system is operated in waters subject to this permit, the washwater monitoring and 

recording must be continuous. The values monitored and recorded must include pH, PAH, 

turbidity, and temperature. 

The pH electrode and pH meter must have a resolution of 0.1 pH units and temperature 

compensation. The electrode must comply with the requirements defined in BS 2586 or of 

equivalent or better performance and the meter should meet or exceed BS EN ISO 60746-

2:2003. 

The PAH monitoring equipment must be capable of monitoring PAH in water in a range of at 

least twice the discharge concentration limit given in the table above. A demonstration must be 

made that the equipment operates correctly and does not deviate more than 5 percent in 

washwater with turbidity within the working range of the application. For those applications 

discharging at lower flow rates and higher PAH concentrations, ultraviolet light monitoring 

technology or equivalent should be used due to its reliable operating range. 

The turbidity monitoring equipment must meet requirements defined in ISO 7027:1999 or 

USEPA 180.1. 

All continuous monitoring equipment must be calibrated as recommended by probe 

manufacturers or Exhaust Gas scrubber manufacturers. At a minimum, all probes must be 
Proposed 2013 Vessel General Permit (VGP)

53 

calibrated at least annually. EPA expects many probe types (e.g., turbidity probes) will need to 

be calibrated on a more frequent basis. 

2.2.26.2.2 Quarterly Analytical Monitoring. 

In addition to the continuous monitoring found in Part 2.2.26.2.1 of this permit, vessel 

owner/operators must collect and analyze one sample per quarter for each of the constituents 

analyzed in Part 2.2.26.2.3 to demonstrate treatment equipment maintenance, probe accuracy, 

and compliance with this permit. Records of the sampling and testing results must be retained 

onboard for a period of 3 years in the vessel’s recordkeeping documentation consistent with Part 

4.2. 

2.2.26.2.3 Analytes for Quarterly Analytical Monitoring 

Vessels conducting monitoring as required by Part 2.2.26.2.2 must monitor for the following 

parameters, choosing either sufficiently sensitive EPA Part 136 methods or other methods if 

specifically allowed:

• Dissolved and Particulate Metals, including Aluminum, Antimony, Arsenic, 

Cadmium, Chromium, Copper, Lead, Manganese, Nickel, Selenium, Thallium, 

and Zinc (recommend using EPA Methods 200.8 or 200.9); 

• PAHs including Acenaphthylene, Acenaphthene, Anthracene Benz[a]anthracene, 

Benzo[ghi]perylene, Benzo[a]pyrene, Benzo[b]fluoranthene +, 

benzo[k]fluoranthene, Chrysene, Dibenz[a,h]anthracene, Fluoranthene, Fluorene, 

Indeno[1,2,3,c,d]pyrene, Naphthalene, Phenanthrene, and Pyrene (recommend 

using EPA Methods 550.1, 610, 625, 8100, 8270c, 8310); 

• Nitrates (recommend using EPA Method 353.2); 

• pH (using Standard Methods (SM) 4500-H B); 

• Turbidity (using SM 2130 B); 

• Temperature (using SM 2550); and 

• Dissolved Oxygen (using SM 4500-O G).

2.2.26.2.4 Monitoring Reporting 

Vessel owners/operators must submit all monitoring data to EPA’s e-reporting system, unless 

exempted from electronic reporting consistent with Part 1.14 of this permit. Monitoring data 

must be submitted at least once per calendar year no later than February 28 of the following year 

on the vessel annual report. Data must be submitted on or attached to a DMR available in 

Appendix I of this permit or submitted to EPA’s e-reporting system available at 

www.epa.gov/vessels/eNOI. Data may be submitted as part of the vessel’s annual report.

2.2.27 Fish Hold Effluent 

You must minimize the discharge of fish hold water and/or ice while in port. All reasonable steps 

must be taken to prevent the discharge of excess fish hold water and ice while the vessel is 

stationary at the pier. If fish waste is contained in the fish hold effluent, the fish hold effluent 
Proposed 2013 Vessel General Permit (VGP)

54 

may not be discharged while in port, unless a physical separation method is used (e.g., filters or 

removal of residuals). 

• The discharge of fish hold effluent (including dirty ice) is prohibited if you are 

unloading your catch at a land-based seafood processing facility or pier. If a 

shore-based discharge facility is otherwise available to receive your effluent, then 

discharge of fish hold effluent (including dirty ice) is prohibited if the facility 

meets the following:

– Its use is economically achievable, and

– The facility has a valid NPDES permit, or 

– That facility discharges to an NPDES-permitted sewage treatment facility. 

• The discharge of unused bait overboard is prohibited, unless you caught that bait 

in the same water body or watershed. Unused bait purchased from a bait shop or 

dealer may not be discharged overboard. 

2.3 Additional Water Quality-Based Effluent Limits 

The requirements in Part 2.3 constitute the water quality-based effluent limitations in this permit. 

These water quality-based effluent limitations supplement this permit’s effluent limitations in 

Parts 2.1, 2.2, 2.3.2 and 5 of this permit.

2.3.1 Water Quality-Based Effluent Limitations 

Your discharge must be controlled as necessary to meet applicable water quality standards in the 

receiving water body or another water body impacted by your discharges. 

EPA generally expects that compliance with the other conditions in this permit, including Parts 

2.1, 2.2, and 5, will control discharges as necessary to meet applicable water quality standards. If 

at any time you become aware, or EPA determines, that your discharge causes or contributes to 

an exceedance of applicable water quality standards, you must take corrective actions as required 

in Part 3; you must also report the exceedance(s) to EPA as required in Parts 1.14 and 4.4.1. 

EPA may impose additional water quality-based limitations on a site-specific basis, or require 

you to obtain coverage under an individual permit, if information in your NOI (if applicable), 

required reports, or from other sources indicates that, after meeting the water quality-based 

limitations in this part, your discharges are not controlled as necessary to meet applicable water 

quality standards, either in the receiving water body or another water body impacted by your 

discharges. EPA or an authorized representative of EPA may inform vessel owner/operators of 

specific requirements.

2.3.2 Discharges to Water Quality Impaired Waters 

Impaired waters or “water quality limited segment[s]” are those which have been identified by a 

state or EPA pursuant to section 303(d) of the CWA as not meeting applicable state water quality 

standards. Impaired waters may include both waters with EPA-approved or EPA-established 

Total Maximum Daily Loads (TMDLs), and those for which EPA has not yet approved or 

established a TMDL.
2013 VGP and sVGP BE Appendix B 

Appendix B. Vessel Class-Specific Technology-based Effluent Limits 

Required by the VGP for Select Permitted Vessels
Proposed 2013 Vessel General Permit (VGP)

69 

5. VESSEL-CLASS-SPECIFIC REQUIREMENTS

You must comply with the requirements of Part 5 of this permit, Vessel-Class-Specific 

Requirements, associated with your vessel class in addition to any applicable requirements that 

apply to all vessels specified elsewhere in this permit.

5.1 Large Cruise Ships (authorized to carry 500 people or more for hire)

The requirements in Part 5.1 apply to vessel discharges from cruise ships providing overnight 

accommodations (i.e., cruise ships with onboard sleeping facilities) to passengers and authorized 

to carry 500 people or more for hire. 

5.1.1 Additional Effluent Limits

5.1.1.1 Graywater Management

5.1.1.1.1 Graywater Discharge Location and Rate 

Pierside Limits – While pierside, appropriate onshore reception facilities for graywater must be 

used unless the vessel treats graywater with a device to meet the standards in Part 5.1.1.1.2. If 

such facilities are not reasonably available and you do not have the capacity to treat graywater to 

meet the standards in Part 5.1.1.1.2, you must hold the graywater until the vessel is underway 

and not in waters subject to this permit. Appropriate reception facilities are those authorized for 

use by the port authority or local municipality and that treat the discharge in accordance with its 

NPDES permit. 

Operational Limits – You must meet the following restriction:

• While operating within 3 nm from shore, discharges of graywater are prohibited 

unless they meet the effluent standards in Part 5.1.1.1.2. 

Limits Applicable to Operation in Nutrient Impaired Waters – If you operate in nutrient-impaired 

waters including, but not limited to, the Chesapeake Bay or the territorial sea surrounding the 

mouth of the Mississippi River in the Gulf of Mexico, you must: 

• Not discharge any graywater in nutrient-impaired waters subject to this permit 

unless the length of voyage in that water exceeds the vessel’s holding capacity for 

graywater; and

• Minimize the discharge of any graywater into nutrient-impaired waters subject to 

this permit, which may require minimizing the production of graywater; and 

• If your vessel’s holding capacity for graywater is exceeded, treat such excess 

graywater (above the vessel holding capacity) by a device meeting the standards 

in Part 5.1.1.1.2 prior to discharge into nutrient-impaired waters subject to this 

permit; or 

• Dispose of the graywater at an onshore facility which will discharge the effluent 

under a valid NPDES permit. 
Proposed 2013 Vessel General Permit (VGP)

70 

A list of nutrient impaired waters is available at www.epa.gov/npdes/vessels.

5.1.1.1.2 Graywater Treatment Standards 

The discharge of treated graywater must meet the following standards: 

1. The discharge must satisfy the minimum level of effluent quality specified in 40 

CFR § 133.102; 

2. The geometric mean of the samples from the discharge during any 30-day period 

may not exceed 20 fecal coliform/100 milliliters (ml) and not more than 10 

percent of the samples may exceed 40 fecal coliform/100 ml; and

3. Concentrations of total residual chlorine may not exceed 10.0 micrograms per 

liter (μg/l). 

5.1.1.1.3 Sculleries and Galleys 

Cruise ship owners/operators must use soaps and detergents that are phosphate-free, non-toxic, 

and biodegradable. Degreasers must be non-toxic if they will be discharged as part of any waste 

stream. 

5.1.1.1.4 Other Materials

Waste from mercury-containing products, dry cleaners or dry cleaner condensate, photo 

processing labs, medical sinks or floor drains, chemical storage areas, and print shops using 

traditional or non-soy-based inks and chlorinated solvents must be prevented from entering the 

ship’s graywater, blackwater, or bilgewater systems if water from these systems will be 

discharged into waters subject to this permit. Preventing these wastes from entering these 

systems can be accomplished by plugging all drains that flow to the graywater, blackwater, or 

bilge systems in areas where these wastes are produced and creating alternate waste receptacles 

or replumbing drains to appropriate holding tanks. 

Vessel owners/operators must not discharge any toxic materials, including products containing 

acetone, benzene, or formaldehyde into salon and day spa sinks or floor drains if those sinks or 

floor drains lead to any system which will be discharged into waters subject to this permit. This 

includes using these materials on passengers (or crew) and rinsing residuals into these sinks. 

Alternate waste receptacles or holding tanks must be used for these materials. Addition of these 

materials to any systems which will discharge into waters subject to this permit is a permit 

violation. 

5.1.1.2 Pool and Spa Discharges 

Discharges of pool or spa water to waters listed in Appendix G are not authorized under this 

permit. Discharges from pools and spas are authorized into non-Appendix G waters subject to 

this permit, provided pool and spa water to be discharged is dechlorinated and/or debrominated, 

and discharge occurs while the vessel is underway. To be considered dechlorinated, the total 

residual chlorine in the pool or spa effluent must be less than 100 μg/l if the pool or spa water is 
Proposed 2013 Vessel General Permit (VGP)

71 

discharged without going through an Advanced Wastewater Treatment System (AWTS). To be 

considered debrominated, the total residual oxidant in the pool or spa effluent must be below 25 

μg/l if the pool or spa water is discharged without going through an AWTS. Pool and spa water 

may be added to the graywater treatment systems; however, any resultant discharge must meet 

all standards and requirements found in Part 5.1.1.1 and must be dechlorinated and/or 

debrominated as applicable.

5.1.2 Monitoring Requirements 

5.1.2.1 Untreated Graywater

The discharge of untreated graywater by large cruise ships is not authorized in waters subject to 

this permit. Any discharge of untreated graywater within waters subject to this permit must be 

reported to EPA as an incidence of noncompliance on the vessel’s Annual Report. 

5.1.2.2 Treated Graywater

Prior to entering waters of the United States, vessel operators must demonstrate that they have an 

effective treatment system that complies with the standards in Part 5.1.1.1.2 if they will 

discharge graywater within 3 nm of shore. 

5.1.2.2.1 Initial Monitoring

In order to demonstrate the effectiveness of the treatment system, the vessel operator must take at 

least five (5) samples from the vessel on different days over a 30-day period that are 

representative of the treated effluent to be discharged. A vessel owner/operator that submitted 

data to EPA for a vessel’s discharge from an AWTS under the 2008 VGP requirements or 

submitted such data to the U.S. Coast Guard to meet the requirements of Section 1411(b) of Title 

XIV, Pub. L. 106-554 (Dec. 31, 2000, 114 Stat. 2763) [Certain Alaska Cruise Ship Operations] 

(codified at 33 USC 1901 note) does not need to conduct initial monitoring, and may instead 

immediately commence maintenance monitoring consistent with Part 5.1.2.2.2 of this permit.

Initial monitoring must be done within the first 90 days of permit coverage, within 90 days of 

AWTS installation onboard the vessel, or before vessels discharge into waters subject to this 

permit, whichever is later. Samples must be taken for BOD, fecal coliform, suspended solids, 

pH, and total residual chlorine. Furthermore, samples must be taken for E. coli, total phosphorus 

(TP), ammonia, nitrate/nitrite, and Total Kjeldahl Nitrogen (TKN). Sampling and testing shall be 

conducted according to 40 CFR Part 136. If the measured samples meet the standards specified 

in Part 5.1.1.1.2, then the owner/operator has demonstrated the effectiveness of their treatment 

system for controlling their graywater discharge. Records of the sampling and testing results 

must be retained onboard for a period of 3 years in the vessel’s recordkeeping documentation. 

Records of monitoring information shall include: 

• The date, exact place, and time of sampling or measurements;

• The individual(s) who performed the sampling or measurements;

• The date(s) analyses were performed;

• The individual(s) who performed the analyses; 
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72 

• The analytical techniques or methods used; and 

• The results of such analyses.

Analytical results for total residual chlorine below the method detection limit shall be deemed 

compliant with the effluent limits, provided the permittee uses a testing method with a detection 

limit no higher than 10.0 μg/L under ideal conditions. EPA recommends Method SM4500-CL G 

(DPD Colorimetric Method) for these purposes as it is able to reach 10 μg/L under ideal 

conditions and so meets these requirements. SM4500-Cl G is typically the method that Alaska 

Department of Environmental Conservation (ADEC)/U.S. Coast Guard uses for compliance 

monitoring. 

Testing and reporting for total residual chlorine is not required if chlorine is not used as 

disinfectant in the wastewater treatment works process and no water is drained to the graywater 

system from water with onboard chlorine additions (e.g., swimming pools, spas). 

If a permittee has already received certification for continuous discharges from an AWTS by the 

U.S. Coast Guard to meet the requirements of Title XIV, Pub. L. 106-554 (Dec. 31, 2000, 114 

Stat. 2763) [Certain Alaska Cruise Ship Operations] (codified at 33 USC 1901 note), the vessel 

need not conduct initial monitoring and may commence conducting maintenance monitoring. 

5.1.2.2.2 Maintenance Monitoring 

After demonstrating the effectiveness of their system, vessel owners/operators must collect and 

analyze one sample per quarter for each of the constituents listed in Part 5.1.2.2.1 to demonstrate 

treatment equipment maintenance and compliance with this permit. Furthermore, samples must 

be taken for E. coli, total phosphorus (TP), ammonia, nitrate/nitrite, and Total Kjeldahl Nitrogen 

(TKN). Records of the sampling and testing results must be retained onboard for a period of 3 

years in the vessel’s recordkeeping documentation. 

5.1.2.2.3 Monitoring Reporting 

The owner/operator must submit data showing that the graywater standards are achieved by their 

treatment system to EPA’s e-reporting system or to EPA, ATTN: VGP Cruise Ship Monitoring 

Results, 1200 Pennsylvania Ave., MC 4203M, Washington, DC 20460. Initial sampling data 

must be submitted at least 7 days before entering waters subject to this permit, within 90 days of 

obtaining permit coverage, or within 90 days of AWTS installation onboard the vessel, 

whichever is later. Maintenance monitoring data must be submitted at least once per calendar 

year no later than February 28 of the following year (e.g., 2014 data must be submitted by 

February 28, 2015). Data must be submitted on DMRs available in Appendix I of this permit or 

submitted to EPA’s e-reporting system available at www.epa.gov/vessels/eNOI. Data may be 

submitted as part of the vessel’s annual report. 

5.1.2.2.4 Reserved Authority

Even if owners/operators have demonstrated their systems meet the standards in Part 5.1.1.1.2, if 

EPA, its authorized representative, or the U.S. Coast Guard sample their graywater effluent and 
Proposed 2013 Vessel General Permit (VGP)

73 

find that they are not meeting these standards, the cruise ship owners/operators are liable for 

violating their effluent limits.

5.1.2.2.5 Treated Graywater Records 

The owner/operator must maintain records estimating the quantity and quality of all discharges 

of treated graywater into waters subject to this permit, including date, location and volume 

discharged, and pollutant concentrations monitored in their recordkeeping documentation. These 

records shall be maintained as part of or in combination with the vessel’s sewage and graywater 

discharge record book required under 33 CFR § 159.315. 

5.1.2.3 Treated Pool and Spa Discharges 

Vessel owners/operators must monitor chlorine or bromine concentrations (as applicable) in pool 

or spa water before every discharge event using sufficiently sensitive 40 CFR Part 136 methods 

if they will discharge these streams directly into waters subject to this permit to ensure that the 

dechlorination/debromination process is complete. If vessel owners/operators are monitoring 

bromine concentrations, they may use a field test kit which uses the colorimetric method in lieu 

of 40 CFR Part 136 methods to ensure waters have been debrominated, provided that test kit has 

a method detection limit no higher than 50 μg/l. You must record the location of the discharge, 

the estimated volume of the discharge, and the concentration of chlorine or bromine (as 

applicable). Records of this monitoring must be kept with other graywater monitoring records. 

For chlorine, analytical results below the method detection limit shall be deemed compliant with 

the effluent limits, provided the permittee uses a testing method with a detection limit no higher 

than 10.0 μg/L under ideal conditions. EPA recommends Method SM4500-CL G (DPD 

Colorimetric Method) for these purposes as it is able to reach 10 μg/L under ideal conditions and 

so meets these requirements. SM4500-Cl G is typically the method that ADEC/USCG uses for 

compliance monitoring. For bromine, analytical results below the method detection limit shall be 

deemed compliant with the effluent limits, provided the permittee uses a testing method with a 

detection limit no higher than 50.0 μg/l. 

5.1.3 Educational and Training Requirements 

The crews of cruise ships play a key role in minimizing the discharge of pollutants from cruise 

ship operations and passengers. Therefore, cruise ship operators must provide the following 

educational and training requirements to ship personnel: 

• The ship’s crew members who actively take part in the management of a 

discharge or who may affect any discharge must receive training regarding 

shipboard environmental procedures and must be able to demonstrate proficiency 

in implementing these procedures; 

• Advanced training in shipboard environmental management procedures must be 

provided for those directly involved in managing specific discharge types or areas 

of the ship and these crew members must be able to demonstrate proficiency in 

implementing these procedures; and 
Proposed 2013 Vessel General Permit (VGP)

74 

• Appropriate reprimand procedures must be developed for crew whose actions lead 

to violations of any effluent limit set forth in this permit or procedures established 

by the cruise ship operator to minimize the discharge of pollutants. 

Cruise ships must also educate passengers on their potential environmental impacts. The goals of 

these education efforts must include preventing trash from entering any waste stream, 

eliminating the addition of unused soaps, detergents, and pharmaceuticals to the graywater or 

blackwater systems, and minimizing production of graywater. This can be accomplished in a 

variety of ways including, but not limited to, posting signage and informational material in 

guestrooms and common areas, incorporating environmental information passenger orientation 

presentations or packages at the start of cruises, incorporating this information into additional 

lectures and seminars, or broadcasting information via loudspeakers. 

Vessel owners/operators must also meet all training-related recordkeeping requirements of Part 

4.2 of this permit. 

5.2 Medium Cruise Ships (authorized to carry 100 to 499 people for hire)

The requirements in Part 5.2 apply to vessel discharges from cruise ships providing overnight 

accommodations (i.e., cruise ships with onboard sleeping facilities) to passengers and authorized 

to carry between 100 and 499 people for hire. 

5.2.1 Additional Effluent Limits

5.2.1.1 Graywater Management

All medium cruise ships must meet all requirements of this part, including the requirements of 

Parts 5.2.1.1.1, unless they are a vessel unable to voyage more than 1 nm from shore and were 

constructed before December 19, 2008. Medium cruise ships unable to voyage 1 nm from shore 

and constructed before December 19, 2008 must meet the requirements in Parts 5.2.1.1.3, 

5.2.1.1.4, 5.2.1.1.5, 5.2.1.2, 5.2.2.1, 5.2.2.3, and 5.2.3. 

5.2.1.1.1 Graywater Discharge Location and Rate 

Pierside Limits – While pierside, appropriate onshore reception facilities for graywater must be 

used, unless the vessel treats graywater with a device to meet the standards in Part 5.2.1.1.2. If 

such facilities are not reasonably available and you do not have the capacity to treat graywater to 

meet the standards in Part 5.2.1.1.2, you must hold the graywater until the vessel is underway 

and not in waters subject to this permit. Appropriate reception facilities are those authorized for 

use by the port authority or local municipality and that treat graywater in accordance with its 

NPDES permit. 

Operational Limits – You must meet the following restrictions: while operating within 3 nm 

from shore, discharges of graywater are prohibited unless they meet the effluent standards in Part 

5.2.1.1.2. 
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75 

Limits Applicable to Operation in Nutrient Impaired Waters – If you operate in nutrient-impaired 

waters including, but not limited to, the Chesapeake Bay or the territorial sea surrounding the 

mouth of the Mississippi River in the Gulf of Mexico, you must: 

• Not discharge any graywater in nutrient-impaired waters subject to this permit 

unless the length of voyage in that water exceeds the vessel’s holding capacity for 

graywater; and

• Minimize the discharge of any graywater into nutrient-impaired waters subject to 

this permit, which may require minimizing the production of graywater; and 

• If your vessel’s holding capacity for graywater is exceeded, treat such excess 

graywater (above the vessel-holding capacity) by a device meeting the standards 

in Part 5.2.1.1.2 prior to discharge into nutrient-impaired waters subject to this 

permit; or 

• Dispose of the graywater properly onshore; or 

• Discharge the graywater while the cruise ship is sailing at a speed of at least 6 

knots. 

A list of nutrient-impaired waters is available at www.epa.gov/npdes/vessels.

5.2.1.1.2 Graywater Treatment Standards 

The discharge of treated graywater must meet the following standards: 

1. The discharge must satisfy the minimum level of effluent quality specified in 40 

CFR § 133.102; 

2. The geometric mean of the samples from the discharge during any 30-day period 

may not exceed 20 fecal coliform/100 milliliters (ml) and not more than 10 

percent of the samples exceed 40 fecal coliform/100 ml; and

3. Concentrations of total residual chlorine may not exceed 10.0 micrograms per 

liter (μg/l).

5.2.1.1.3 Sculleries and Galleys 

Cruise ship owners/operators must use soaps and detergents that are non-toxic, phosphate free, 

and biodegradable. Degreasers must be non-toxic if they will be discharged as part of any waste 

stream. 

5.2.1.1.4 Other Materials

Waste from mercury-containing products, dry cleaners or dry cleaner condensate, photo 

processing labs, medical sinks or floor drains, chemical storage areas, and print shops using 

traditional or non-soy based inks and chlorinated solvents must be prevented from entering the 

ship’s graywater, blackwater, or bilgewater systems if water from these systems will ever be 

discharged into waters subject to this permit. Preventing these wastes from entering these 

systems can be accomplished by plugging all drains that flow to the graywater, blackwater, or 
Proposed 2013 Vessel General Permit (VGP)

76 

bilge systems in areas where these wastes are produced and creating alternate waste receptacles 

or replumbing drains to appropriate holding tanks. 

Vessel owners/operators must not discharge any toxic materials, including products containing 

acetone, benzene, or formaldehyde into salon and day spa sinks or floor drains if those sinks or 

floor drains lead to any system which will be discharged into waters subject to this permit. This 

includes using these materials on passengers (or crew) and rinsing residuals into these sinks. 

Alternate waste receptacles or holding tanks must be used for these materials. Addition of these 

materials to any systems which will discharge into waters subject to this permit is a permit 

violation. 

5.2.1.1.5 Graywater Discharge Location and Rate for Vessels Built before December 19, 2008 

While pierside, appropriate onshore reception facilities for graywater must be used if available 

and their use is economically achievable (unless the vessel treats graywater with a device to meet 

the standards in Part 5.2.1.1.2). Appropriate reception facilities are those authorized for use by 

the port authority or local municipality and that treat the discharge in accordance with its NPDES 

permit. 

If such facilities are not available and you do not have the capacity to treat graywater to meet the 

standards in Part 5.2.1.1.2, you must hold the graywater unless the vessel is underway and 

sailing at a speed of at least 6 knots in a water that is not a water listed in Appendix G. 

5.2.1.2 Pool and Spa Discharges 

Discharges of pool or spa water to waters listed in Appendix G are not authorized under this 

permit. Discharges from pools and spas are authorized into non-Appendix G waters subject to 

this permit, provided pool and spa water to be discharged is dechlorinated and/or debrominated, 

and discharge occurs while the vessel is underway. To be considered dechlorinated, the total 

residual chlorine in the pool or spa effluent must be less than 100 μg/l if the pool or spa water is 

discharged without treatment through an AWTS. To be considered debrominated, the total 

residual oxidant in the pool or spa effluent must be below 25 μg/l if the pool or spa water is 

discharged without going through an AWTS. Pool and spa water may be added to the graywater 

treatment systems; however, any resultant discharge must meet all standards and requirements 

found in Part 5.2.1.1 and must be dechlorinated and/or debrominated as applicable. 

5.2.2 Monitoring Requirements 

5.2.2.1 Untreated Graywater

The owner/operator must maintain records estimating all discharges of untreated graywater into 

waters subject to this permit, including date, location, and volume discharged in their 

recordkeeping documentation. These records can be maintained as part of the vessel’s sewage 

and graywater discharge record book required under 33 CFR § 159.315. 
Proposed 2013 Vessel General Permit (VGP)

77 

5.2.2.2 Treated Graywater

Prior to entering waters of the United States, vessel operators must demonstrate that they have an 

effective treatment system that complies with the standards in Part 5.2.1.1.2 if they will 

discharge graywater within 3 nm of shore. 

5.2.2.2.1 Initial Monitoring

In order to demonstrate the effectiveness of the treatment system, the vessel operator must take at 

least five (5) samples taken from the vessel on different days over a 30-day period that are 

representative of the treated effluent to be discharged. A vessel owner/operator that submitted 

data to EPA for a vessel’s discharge from an AWTS under the 2008 VGP requirements or 

submitted such data to the U.S. Coast Guard to meet the requirements of Section 1411(b) of Title 

XIV, Pub. L. 106-554 (Dec. 31, 2000, 114 Stat. 2763) [Certain Alaska Cruise Ship Operations] 

(codified at 33 USC 1901 note) does not need to conduct initial monitoring, and may instead 

immediately commence maintenance monitoring consistent with Part 5.2.2.2.2 of this permit.

Initial monitoring must be done within the first 90 days of permit coverage, within 90 days of 

AWTS installation onboard the vessel, or before vessels discharge into waters subject to this 

permit, whichever is later. Samples must be taken for BOD, fecal coliform, suspended solids, 

pH, and total residual chlorine. Furthermore, samples must be taken for E. coli, TP, ammonia, 

nitrate/nitrite, and TKN. Sampling and testing shall be conducted according to 40 CFR Part 136. 

If the measured samples meet the standards specified in Part 5.2.1.1.2, then the owner/operator 

has demonstrated the effectiveness of their treatment system for controlling their graywater 

discharge. Records of the sampling and testing results must be retained onboard for a period of 3 

years in the vessel’s recordkeeping documentation. 

Records of monitoring information shall include: 

• The date, exact place, and time of sampling or measurements;

• The individual(s) who performed the sampling or measurements; 

• The date(s) analyses were performed;

• The individual(s) who performed the analyses; 

• The analytical techniques or methods used; and 

• The results of such analyses.

Analytical results for total residual chlorine below the method detection limit shall be deemed 

compliant with the effluent limits, provided the permittee uses a testing method with a detection 

limit no higher than 10.0 μg/L under ideal conditions. EPA recommends Method SM4500-CL G 

(DPD Colorimetric Method) for these purposes as it is able to reach 10 μg/L under ideal 

conditions and so meets these requirements. SM4500-Cl G is typically the method that 

ADEC/U.S. Coast Guard uses for compliance monitoring. 

Testing and reporting for total residual chlorine is not required if chlorine is not used as 

disinfectant in the wastewater treatment works process and no water is drained to the graywater 

system from water with onboard chlorine additions (e.g., swimming pools, spas). 
Proposed 2013 Vessel General Permit (VGP)

78 

5.2.2.2.2 Maintenance Monitoring 

After demonstrating the effectiveness of their system, vessel owners/operators must collect and 

analyze one sample per quarter for each of the constituents listed in Part 5.2.2.2.1 to demonstrate 

treatment equipment maintenance and compliance with this permit. Records of the sampling and 

testing results must be retained onboard for a period of 3 years in the vessel’s recordkeeping 

documentation. 

5.2.2.2.3 Monitoring Reporting 

The owner/operator must submit data showing that the graywater standards are achieved by their 

treatment system to EPA’s e-reporting system or to EPA, ATTN: VGP Cruise Ship Monitoring 

Results, 1200 Pennsylvania Ave., MC 4203M, Washington, DC 20460. Initial sampling data 

must be submitted at least 7 days before entering waters subject to this permit, within 90 days of 

obtaining permit coverage, or within 90 days of AWTS installation onboard the vessel, 

whichever is later. Maintenance monitoring data must be submitted at least once per calendar 

year no later than February 28 of the following year (e.g., 2014 data must be submitted by 

February 28, 2015). Data must be submitted on DMRs available in Appendix I of this permit or 

submitted to EPA’s e-reporting system available at www.epa.gov/vessels/eNOI, which will be 

available within two years of finalization of this permit. Data may be submitted as part of the 

vessel’s Annual Report. 

5.2.2.2.4 Reserved Authority

Even if owners/operators have demonstrated their system meets the standards in Part 5.2.1.1.2, if 

EPA, its authorized representative, or the U.S. Coast Guard sample their graywater effluent and 

find that they are not meeting these standards, the cruise ship owners/operators are liable for 

violating their effluent limits.

5.2.2.2.5 Treated Graywater Records 

The owner/operator shall maintain records estimating the quantity and quality of all discharges 

of treated graywater into waters subject to this permit, including date, location, and volume 

discharged, and pollutant concentrations monitored in their recordkeeping documentation. These 

records shall be maintained as part of or in combination with the vessel’s sewage and graywater 

discharge record book required under 33 CFR § 159.315. 

5.2.2.3 Treated Pool and Spa Discharges 

Vessel owners/operators must monitor chlorine or bromine concentrations (as applicable) in pool 

or spa water before every discharge event using sufficiently sensitive 40 CFR Part 136 methods 

if they will discharge these streams directly into waters subject to this permit to ensure that the 

dechlorination/debromination process is complete. If vessel owners/operators are monitoring 

bromine concentrations, they may use a field test kit which uses the colorimetric method in lieu 

of 40 CFR Part 136 methods to ensure waters have been debrominated, provided that test kit has 

a method detection limit no higher than 50 μg/l. You must record the location of the discharge, 

the estimated volume of the discharge, and the concentration of chlorine or bromine (as 

applicable). Records of this monitoring must be kept with other graywater monitoring records. 
Proposed 2013 Vessel General Permit (VGP)

79 

For chlorine, analytical results below the method detection limit shall be deemed compliant with 

the effluent limits, provided the permittee uses a testing method with a detection limit no higher 

than 10.0 μg/L under ideal conditions. EPA recommends Method SM4500-CL G (DPD 

Colorimetric Method) for these purposes as it is able to reach 10 μg/l under ideal conditions and 

so meets these requirements. SM4500-Cl G is typically the method that ADEC/U.S. Coast Guard 

uses for compliance monitoring. For bromine, analytical results below the method detection limit 

shall be deemed compliant with the effluent limits, provided the permittee uses a testing method 

with a detection limit no higher than 50.0 μg/l.

5.2.3 Educational and Training Requirements

The crews of cruise ships play a key role in minimizing the discharge of pollutants from cruise 

ship operations and passengers. Therefore, cruise ship operators are responsible for providing the 

following educational and training requirements to ship personnel: 

• The ship’s crew members who actively take part in the management of the 

discharge or who may affect the discharge must receive training regarding 

shipboard environmental procedures and must be able to demonstrate proficiency 

in implementing these procedures; 

• Advanced training in shipboard environmental management procedures must be 

provided for those directly involved in managing specific discharge types or areas 

of the ship and these crew members must be able to demonstrate proficiency in 

implementing these procedures; and 

• Appropriate reprimand procedures must be developed for crew whose actions lead 

to violations of any effluent limit set forth in this permit or procedures established 

by the cruise ship operator to minimize the discharge of pollutants. 

Cruise ships must also educate passengers on their potential environmental impacts. The goals of 

these education efforts must include preventing trash from entering any waste stream, 

eliminating the addition of unused soaps, detergents, and pharmaceuticals to the graywater or 

blackwater systems, and minimizing production of graywater. This can be accomplished in a 

variety of ways including, but not limited to, posting signage and informational material in 

guestrooms and common areas, incorporating environmental information passenger orientation 

presentations or packages at the start of cruises, incorporating this information into additional 

lectures and seminars, or broadcasting information via loudspeakers. 

Vessel owner/operators must also meet all training-related recordkeeping requirements of Part 

4.2 of this permit. 

5.3 Large Ferries

Ferries are vessels for hire that are designed to carry passengers and/or vehicles between two 

ports, usually in inland, coastal, or near-shore waters. “Large Ferry” means a “ferry” that: a) has 

a capacity greater than or equal to 100 tons of cargo (e.g., for cars, trucks, trains, or other landbased transportation); or b) is authorized by the U.S. Coast Guard to carry 250 or more people. 

All large ferries authorized to carry 100 or more tons of cars, trucks, trains, or other land-based 

transportation must meet the requirements in Part 5.3.1.1 (Deck Water) and Part 5.3.2 (Education 
Proposed 2013 Vessel General Permit (VGP)

80 

and Training). Large ferries authorized by the Coast Guard to carry 250 or more people must 

meet the requirements of Part 5.3.1.2 (Graywater Management) and Part 5.3.2 (Education and 

Training Requirements). 

5.3.1 Additional Effluent Limits

5.3.1.1 Deck Water

Large ferries may not discharge untreated below deck water from parking areas or other storage 

areas for motor vehicles or other motorized equipment into waters subject to this permit without 

first treating the effluent with an oily water separator or other appropriate wastewater treatment 

system. Large ferry operators must use oil absorbent cloths or other appropriate spill response 

resources to clean oily spills or substances from deck surfaces. Any effluent created by washing 

the decks may not be discharged into the waters subject to this permit listed in Appendix G. 

5.3.1.2 Graywater Management

5.3.1.2.1 Graywater Discharge Location and Rate 

Pierside Limits – While pierside, appropriate onshore reception facilities for graywater must be 

used, if available and their use is economically achievable, unless the vessel treats graywater to

the limits found in Part 5.1.1.1.2 of the permit. If such facilities are not available, you must hold 

the graywater if the vessel has the holding capacity and discharge the effluent while the vessel is 

underway. Appropriate reception facilities are those authorized for use by the port authority or 

municipality and that treat the discharge in accordance with its NPDES permit. 

Operational Limits – You must also meet the following restriction: if you operate within 3 nm

from shore, discharges of graywater may only be released while the ferry is sailing at a speed of 

at least 6 knots if feasible. If not feasible, you must document why in your recordkeeping 

documentation. 

5.3.2 Educational and Training Requirements 

The crews of ferries play a key role in minimizing the discharge of pollutants from ferry 

operations and its passengers. Therefore, ferry operators are subject to the following 

requirements:

• The ship’s crew members who actively take part in the management of the 

discharge or who may affect the discharge must receive training regarding 

shipboard environmental procedures and must be able to demonstrate proficiency 

in implementing these procedures; 

• Advanced training in shipboard environmental management procedures must be 

provided for those directly involved in managing specific discharge types or areas 

of the ship and these crew must be able to demonstrate proficiency in 

implementing these procedures; and 

• Appropriate reprimand procedures must be developed for crew whose actions lead 

to violations of any effluent limit set forth in this permit or procedures established 

by the ferry operator to minimize the discharge of pollutants. 
Proposed 2013 Vessel General Permit (VGP)

81 

Ferry operators must also educate passengers on their potential environmental impacts. The goals 

of these education efforts should include eliminating the discharge of trash overboard, 

minimizing the production of trash from parking areas or other storage areas, eliminating the 

addition of unused soaps, detergents, and pharmaceuticals to the graywater or blackwater 

systems, and minimizing production of graywater. This can be accomplished in a variety of ways 

including, but not limited to, posting signage and informational material in common areas, 

incorporating environmental information into orientation presentations, or broadcasting 

information via loudspeakers. 

Vessel owners/operators of large ferries must also meet all training-related recordkeeping 

requirements of Part 4.2 of this permit. 

5.4 Barges (such as Hopper Barges, Chemical Barges, Tank Barges, Fuel Barges, Crane 

Barges, Dry Bulk Cargo Barges) 

The requirements in Part 5.4 apply to vessel discharges from barges. Barges engaged in the 

transportation of oil or other petroleum products must also comply with Part 5.5 of this permit. 

5.4.1 Additional Effluent Limits

Barges must minimize the contact of below deck condensation with oily or toxic materials and 

any materials containing hydrocarbon. Whenever barges are pumping water from below deck, 

the discharge shall not contain oil in quantities that may be harmful as defined in 40 CFR Part 

110. If a visible sheen, as defined in Appendix A of this permit, is noted, vessel operators must 

initiate corrective action in accordance with Part 3 and meet recordkeeping requirements in Part 

4.2 of this permit. 

All tank barges must have spill rails and must mechanically plug their scuppers before any cargo 

operations if required by vessel class society and/or 33 CFR Parts 155 and/or 156. Additionally, 

scuppers, when available, must be mechanically plugged during fueling of ancillary equipment 

(e.g., generators and compressors) located on the deck of the barge. If scuppers are unavailable, 

other types of secondary containment should be employed. If any spills result during loading or 

unloading of cargo, or other ancillary equipment fueling operations, vessel owners/operators 

must completely clean up spills or residue before scuppers are unplugged. 

Vessel owners/operators must clean out cargo residues (i.e., broom clean) such that any 

remaining residue is minimized before washing the cargo compartment or tank and discharging 

washwater overboard. 

5.4.2 Supplemental Inspection Requirements

After every instance of pumping water from areas below decks, or immediately following 

washing down the decks, you must conduct a visual sheen test. The visual sheen test is used to 

detect free oil by observing the surface of the receiving water for the presence of an oily sheen. 

The operator should focus the inspection on the area surrounding the vessel where discharges 

from below deck or deck washings are discharges into the receiving water. A visible sheen is 

defined in Appendix A of this permit. If a visible sheen is observed, you must initiate corrective 
Proposed 2013 Vessel General Permit (VGP)

82 

actions required in Part 3 of this permit and meet recordkeeping and notification (reporting) 

requirements in Part 4.2 of this permit. 

5.5 Oil Tankers, Petroleum Tankers, and Bulk Chemical Carriers

The requirements in Part 5.5 apply to vessel discharges from oil tankers, petroleum tankers, and 

bulk chemical carriers, as well as barges engaged in transportation of oil or petroleum products. 

5.5.1 Additional Authorized Discharges 

For vessels which have an inert gas system, the effluent produced from inert gas scrubbers (IGS) 

may be discharged into waters subject to this permit. 

The discharges of water from deck seals are authorized when such seals are installed as an 

integral part of an IGS system.

5.5.2 Additional Effluent Limits 

Owners/operators of oil tankers must plug scuppers during cargo loading and unloading 

operations to prevent the discharge of oil into waters subject to this permit. Any oil spilled must 

be cleaned with oil absorbent cloths or another appropriate approach. Additionally, 

owners/operators of oil tankers must comply with applicable requirements of 33 CFR § 155.310 

and 33 CFR Part 156, Subpart A. 

Vessel owners/operators must minimize the discharge of effluent produced from inert gas 

scrubbers if feasible for their vessel design.

5.5.3 Supplemental Inspection Requirements

After every instance of loading or unloading operations or immediately following washing down 

the decks, you must conduct a visual sheen test. The visual sheen test is used to detect free oil by 

observing the surface of the receiving water for the presence of an oily sheen. The 

owner/operator should focus the inspection on the area surrounding the vessel where effluent 

from loading operations or deck washings discharge into the receiving water. A visible sheen is 

defined in Appendix A of this permit. If a visible sheen is observed, you must comply with all 

requirements contained in Part 4.4 of this permit, initiate corrective actions required in Part 3 of 

this permit, and meet recordkeeping and notification (reporting) requirements in Part 4.2 of this 

permit. 

5.5.4 Educational and Training Requirements

The crews of oil tankers play a key role in minimizing the discharge of pollutants from vessel 

operations. Therefore, oil tanker operators are subject to the following requirements: 

• The ship’s crew members who actively take part in the management of the 

discharge or who may affect the discharge must receive training regarding 

shipboard environmental procedures and must be able to demonstrate proficiency 

in implementing these procedures; 
Proposed 2013 Vessel General Permit (VGP)

83 

• Advanced training in shipboard environmental management procedures must be 

provided for those directly involved in managing specific discharge types or areas 

of the ship and these crew must be able to demonstrate proficiency in 

implementing these procedures; and 

• Appropriate reprimand procedures must be developed for crew actions that lead to 

violations of any effluent limit set forth in this permit or procedures established 

by the vessel operator to minimize the discharge of pollutants.

Vessel owners/operators of tankers must also meet all training-related recordkeeping 

requirements of Part 4.2 of this permit. 

5.6 Research Vessels

The requirements in Part 5.6 apply to vessel discharges from research vessels. Research vessels 

are those that are engaged in investigation or experimentation aimed at discovery and 

interpretation of facts, revision of accepted theories or laws in the light of new facts, or practical 

application of such new or revised theories or laws. 

5.6.1 Supplemental Authorized Discharges

In addition to the discharges incidental to the normal operation of a vessel authorized elsewhere 

in this permit, owners/operators of research vessels are authorized to discharge tracers (dyes, 

fluorescent beads, SF6), drifters, tracking devices and the like, and expendable 

bathythermograph (XBT) probes, into waters subject to this permit, provided such discharges are 

for the sole purpose of conducting research on the aquatic environment or its natural resources in 

accordance with generally recognized scientific methods, principles, or techniques. 

5.6.2 Additional Effluent Limits

Owners/operators of research vessels must discharge only the minimal amount of materials 

referenced in Part 5.6.1 necessary to conduct research on the aquatic environment or its natural 

resources in accordance with generally recognized scientific methods, principles, or techniques. 

5.7 Emergency and Rescue Vessels (Fire Boats, Police Boats)

The requirements in Part 5.7 apply to vessel discharges from emergency and rescue boats.

5.7.1 Supplemental Authorized Discharges

In addition to the discharges incidental to the normal operation of a vessel authorized elsewhere 

in this permit, owners/operators of emergency and rescue vessels are authorized to discharge 

waste streams in conjunction with training, testing, and maintenance operations, provided that 

they comply with all additional requirements of the CWA (e.g., section 311) and the National 

Contingency Plan (40 CFR Part 300). This part does not relieve vessel operators of any 

additional responsibilities under the CWA and the National Contingency Plan which prohibits 

the discharge of oil for research or demonstration purposes without Administrator approval. The 

use of foaming agents for oil or chemical fire response must be implemented in accordance with 

the National Contingency Plan (40 CFR Part 300). 
Proposed 2013 Vessel General Permit (VGP)

84 

5.7.2 Additional Effluent Limits 

Owners/operators are strongly encouraged to seek alternative formulations of AFFF that are less 

harmful to the aquatic environment, such as non-fluorinated foam, while maintaining their 

effectiveness in emergency operations. Furthermore, operators are encouraged to not use AFFF 

or discharge toxic substances in areas near active commercial or recreational fisheries, near 

swimmable waters, or in high traffic areas for maintenance or training purposes. Emergency 

vessel owners/operators are also encouraged to perform training, testing, and maintenance 

operations outside of port and as far from shore as possible. The use of foaming agents for oil or 

chemical fire response, and the control of their discharge from a vessel, must be implemented in 

accordance with the National Contingency Plan (40 CFR Part 300). 
2013 VGP and sVGP BE Appendix C 

Appendix C. Ballast Water Technology-based Effluent Limits Required by 

the VGP for All Covered Vessels 
Proposed 2013 Vessel General Permit (VGP)

23 

structures are considered to be normal operation of a vessel if those practices fall 

within normal marine practice.

• All vessels must minimize the discharge of bilgewater into waters subject to this 

permit. This can be done by minimizing the production of bilgewater, disposing 

of bilgewater on shore where adequate facilities exist, or discharging into waters 

not subject to this permit (i.e., more than 3 nautical miles [nm] from shore) for 

vessels that regularly travel into such waters. Though not regulated under this 

permit, EPA notes that discharges of bilgewater outside waters subject to this 

permit (i.e., more than 3 nm from shore) are regulated under Annex I of the 

International Convention for the Prevention of Pollution from Ships as 

implemented by the Act to Prevent Pollution from Ships and U.S. Coast Guard 

regulations found in 33 CFR part 151. 

• Vessels greater than 400 gross tons shall not discharge untreated oily bilgewater 

into waters subject to this permit.

• Vessels greater than 400 gross tons that regularly sail outside the territorial sea (at 

least once per month) shall not discharge treated bilgewater within 1 nm of shore 

if technologically feasible (e.g., holding would not impact safety and stability, 

would not contaminate other holds or cargo, or would not interfere with essential 

operations of the vessel). Any discharge which is not technologically feasible to 

avoid must be documented as part of the requirements in Part 4.2 and reported to 

EPA as part of the vessel’s annual report. 

• Vessels greater than 400 gross tons shall not discharge treated bilgewater into 

waters referenced in Appendix G unless the discharge is necessary to maintain the 

safety and stability of the ship. Any discharge of bilgewater into these waters 

must be documented as part of the recordkeeping requirements in Part 4.2 and 

reported to EPA as part of the vessel’s annual report. 

• For vessels greater than 400 gross tons that regularly sail outside the territorial sea 

(at least once per month), if treated bilgewater is discharged into waters subject to 

this permit, it must be discharged when the vessel is underway (sailing at speeds 

greater than 6 knots), unless doing so would threaten the safety and stability of the 

ship. EPA notes that vessel operators may also choose to dispose of bilgewater on 

shore where adequate facilities exist. Any discharge which is made for safety 

reasons must be documented as part of the requirements in Part 4.2 and reported 

to EPA as part of the vessel’s annual report. 

Note: EPA is specifically seeking comment on whether to alter the bilgewater management 

regime for new build vessels and whether to provide existing vessels with additional bilgewater 

management options. Please see Part 4.4.2 of the Fact Sheet for details.

2.2.3 Ballast Water

All discharges of ballast water must comply with the requirements in this permit as described 

below. Additionally, owner/operators of all vessels subject to coverage under this permit which 

are equipped with Ballast Tanks must comply with any additional BMPs in this section. 
Proposed 2013 Vessel General Permit (VGP)

24 

In addition, as a condition of this permit, all discharges of ballast water must also comply with 

applicable U.S. Coast Guard regulations found in 33 CFR Part 151. 

All discharges of ballast water may not contain oil, noxious liquid substances (NLSs), or 

hazardous substances in a manner prohibited by U.S. laws, including section 311 of the Clean 

Water Act. 

2.2.3.1 Training

All owner/operators of vessels equipped with ballast water tanks must train the master, operator, 

person-in-charge, and crew members who actively take part in the management of the discharge 

or who may affect the discharge, on the application of ballast water and sediment management 

and treatment procedures. As part of Ballast Water Management Plans under 2.2.3.2, a standalone training plan, or other recordkeeping documentation, owner/operators must maintain a 

written training plan describing the training to be provided and a record of the date of training 

provided to each person trained. Persons required to be trained must be trained promptly upon 

installation of treatment technology and in the event of a significant change in ballast water 

treatment practices or technology. 

2.2.3.2 Ballast Water Management Plans 

All owner/operators of vessels equipped with ballast water tanks must maintain a ballast water 

management plan that has been developed specifically for the vessel that will ensure that those 

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

management strategy. Owner/operators must make that plan available upon request to EPA or its 

authorized representative. Vessel owner/operators must assure that the master and crew members 

who actively take part in the management of the discharge or who may affect the discharge 

understand and follow the management strategy laid out in the plan. 

At a minimum, all vessels must have a plan which outlines how they will meet the requirements 

of Part 2.2.3.3 of this permit. The plan must also include how vessels will comply with training 

requirements of 2.2.3.1 and meet all other subparts of Part 2.2.3 as applicable. EPA notes that a 

Ballast Water Management Plan is also required by the United States Coast Guard by 33 CFR 

Part 151. Provided owner/operators meet the requirements discussed above, EPA expects that 

vessels will need one ballast water management plan to meet both EPA and USCG requirements.

2.2.3.3 Mandatory Ballast Water Management Practices: Management measures 

required of all vessel owner/operators

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

that operate in waters of the U.S. must: 

• Avoid the discharge or uptake of ballast water in areas / into waters subject to this 

permit within, or that may directly affect, marine sanctuaries, marine preserves, 

marine parks, or coral reefs or other waters listed in Appendix G waters (also 

called Part 12 waters). 

• Minimize or avoid uptake of ballast water in the following areas and situations: 
Proposed 2013 Vessel General Permit (VGP)

25 

— Areas known to have infestations or populations of harmful organisms and 

pathogens (e.g., toxic algal blooms). 

— Areas near sewage outfalls. 

— Areas near dredging operations. 

— Areas where tidal flushing is known to be poor or times when a tidal 

stream is known to be turbid. 

— In darkness, when bottom-dwelling organisms may rise up in the water 

column. 

— Where propellers may stir up the sediment. 

— Areas with pods of whales, convergence zones, and boundaries of major 

currents 

• Clean ballast tanks regularly to remove sediments in mid-ocean (when not 

otherwise prohibited by applicable law) or under controlled arrangements in port, 

or at dry dock. 

• No discharge of sediments from cleaning of ballast tanks is authorized in waters 

subject to this permit.

• When discharging ballast water in port, if the vessel is equipped with high and 

low suction within ballast tanks, utilize the high suction for ballast tank discharge 

to minimize the discharge of entrained sediment. The low suction may be used to 

strip sediment from tanks when suitable disposal facilities are available. 

• Minimize the discharge of ballast water essential for vessel operations while in 

the waters subject to this permit.

Suggested control measures to minimize the discharge of ballast water include, but are not 

limited to, transferring ballast water between tanks within the vessel in lieu of ballast water 

discharge. Another option is to use public water supply for ballast. 

2.2.3.4 Mandatory Ballast Water Management Practices for Existing Bulk Carrier 

vessels (commonly known as Lakers) built before January 1, 2009, confined 

exclusively to the Great Lakes upstream of the Welland Canal 

Existing Bulk Carrier Vessels known as “Lakers” that operate exclusively in the Great Lakes 

upstream of the Welland Canal (i.e. those vessels confined to the upper Great Lakes because they 

are too large to exit the Great Lakes via the St. Lawrence Seaway) must meet the following 

additional ballast water management requirements:

• Each owner/operator must perform annual inspections on their vessel to assess 

sediment accumulations. Removal of sediment, if necessary, must be carried out. 

Each vessel owner/operator must develop sediment removal policies as part of the 

Ballast Water Management Plan. Records of sediment removal and disposal 

(including facility name and location and all invoices) shall be kept onboard the 

vessel. EPA notes the discharge of sediments from cleaning of ballast tanks is not 

authorized in waters subject to this permit (see Part 2.2.3.3 of this permit).

• When practical and safe, vessels must minimize the ballast water taken dockside. 

This will typically mean limiting uptake to the amount of ballast water required to 

safely depart the dock and then complete ballasting in deeper water.
Proposed 2013 Vessel General Permit (VGP)

26 

• The vessel sea chest screen is the first line of defense in keeping large living 

organisms out of the vessel ballast water tanks. Owner/operators of Laker vessels 

must perform annual inspections of their sea chest screens to assure that they are 

fully intact. The inspection must assure that there is no deterioration which has 

resulted in wider openings or holes in the screen. If the screen has deteriorated 

such that there are wider openings than the screen design, the vessel owner 

operator must repair or replace the screen. Any repairs must be of sufficient 

quality that they are expected to last at least one year.

If a confined Laker meets the permit limits found in Part 2.2.3.5 of this permit, the vessel 

owner/operator is not required to conduct the additional management measures found in Part 

2.2.3.4, but must still comply with Part 2.2.3.3. 

2.2.3.5 Ballast Water Numeric Discharge Limitations 

Owners/operator must meet the following discharge limits consistent with the schedule found in 

Part 2.2.3.5.2, unless you are excluded from these requirements by Parts 2.2.3.5.3 or 2.2.3.8 of 

this permit:

1. For organisms greater than or equal to 50 micrometers in minimum dimension: 

discharge must include fewer than 10 living organisms per cubic meter of ballast 

water.

2. For organisms less than 50 micrometers and greater than or equal to 10 

micrometers: discharge must include fewer than 10 living organisms per milliliter 

(mL) of ballast water.

3. Indicator microorganisms must not exceed: 

(i) For Toxicogenic Vibrio cholerae (serotypes O1 and O139): a 

concentration of less than 1 colony forming unit (cfu) per 100 mL. 

(ii) For Escherichia coli: a concentration of fewer than 250 cfu per 100 mL. 

(iii) For intestinal enterococci: a concentration of fewer than 100 cfu per 100 

mL.

These limits may be met by using one of the ballast water management measures in Parts 

2.2.3.5.1., 2.2.3.5.1.2, 2.2.3.5.1.3, or 2.2.3.5.1.4. 

Note: EPA will continue to explore new technologies with industry and states, and when 

warranted, will make this numeric limit more stringent in the future (see discussion in section 

4.4.3.5.1 of the fact sheet). Additionally, EPA encourages and anticipates, as part of this 

process, that states will continue to work with industry to test and provide opportunities for new 

technologies. 

2.2.3.5.1 Ballast Water Management Measures 

In addition to the other requirements of this permit, owner/operators of vessels with the capacity 

to carry greater than or equal to 8 cubic meters of ballast water may use one of the four following 

ballast water management methods to meet the numeric discharge limits in Part 2.2.3.5: 
Proposed 2013 Vessel General Permit (VGP)

27 

2.2.3.5.1.1 Ballast Water Management using a Ballast Water Treatment System 

Vessel owner/operators utilizing a ballast water treatment system (BWTS) must use a system 

which has been shown to be effective by testing in accordance with the EPA-ETV protocol for 

the verification of ballast water treatment technology conducted by an independent third party 

laboratory, test facility or test organization. Once the effluent limits in Part 2.2.3.5 become 

applicable to a vessel (see part 2.2.3.5.2 for applicability timeframes for specified categories of 

vessels), owners/operators of vessels utilizing a ballast water treatment system to meet the 

requirements of Part 2.2.3.5 of this permit must meet those limits as an instantaneous maximum. 

Additionally, following installation of a BWTS, the master, owner, operator, agent, or person in 

charge of the vessel must maintain the BWTS in accordance with all manufacturer specifications. 

Furthermore, all treatment must be conducted in accordance with the BWTS manufacturer’s 

instructions. The BWTS must be used prior to any discharge of ballast water to waters of the 

U.S.

2.2.3.5.1.1.1 Monitoring From Vessels Using Ballast Water Treatment Systems

The monitoring requirements in Part 2.2.3.5.1.1 apply to ballast water discharges from vessels 

employing ballast water treatment systems that are required to achieve the effluent limitations of 

Part 2.2.3.5. The monitoring is divided into three components. The first, in Part 2.2.3.5.1.1.2, is 

required of all vessels and generally requires monitoring equipment performance to assure the 

system is fully functional. Vessels conducting this monitoring also must adequately calibrate 

their equipment as required in Part 2.2.3.5.1.1.3. The second component, in Part 2.2.3.5.1.1.4

requires monitoring from all ballast water systems for selected biological indicators. The third 

component, in part 2.2.3.5.1.1.5 requires monitoring of the ballast water discharge itself for 

biocides and residuals to assure compliance with the effluent limitations established in part 

2.2.3.5 of the permit, as applicable. 

2.2.3.5.1.1.2 Ballast Water System Functionality Monitoring

Ballast water treatment systems use physical and/or chemical processes, or a combination 

thereof, to achieve reductions in living organisms. The use of physical/chemical indicators of 

treatment performance verifies that the ballast water treatment system is operating according to 

the manufacturers’ operating specifications. To assess the BWTS functionality, monitoring 

indicators of the BWTS functionality is required at least once per month for specific parameters 

that are applicable to your system. The required parameters to be monitored, with appropriate 

monitoring approaches are contained in Appendix J. For example, if your system uses a filter 

and chlorine dioxide, you must meet the requirements for systems using both filters and chlorine 

dioxide. If your system uses cavitation, UV, and hypochlorite generation, you must monitor 

conditions for all three treatment units. EPA expects that most ballast water treatment systems 

will make use of at least two physical and/or chemical processes. 

Most ballast water treatment systems have control and self diagnostic equipment such as sensors 

that continuously measure treatment parameters to verify performance. The metrics to be 

monitored are based on common approaches used in ballast water treatment systems. As new 
Proposed 2013 Vessel General Permit (VGP)

28 

approaches become commonly available, EPA will develop new monitoring parameters as 

appropriate. 

2.2.3.5.1.1.3 Ballast Water monitoring equipment calibration

At a minimum, all applicable sensors and other equipment must be calibrated annually. 

Additionally, all applicable sensors and other control equipment must be calibrated no less 

frequently than recommended by the sensor or other equipment manufacturer, or by the ballast 

water treatment system manufacturer or when warranted based on device drift from a standard or 

calibrated setting. EPA expects many sensor types (e.g., pH probes, TRO sensors, turbidity 

sensors) will need to be calibrated on a more frequent basis. Calibration of the sensors and 

equipment can be conducted on-board the vessel or they can be removed and shipped to the 

manufacturer or other vendor for calibration. During the period when the sensors are not 

installed (or otherwise inoperable thus significantly compromising the performance of the ballast 

water treatment system), the vessel must not discharge ballast water.

2.2.3.5.1.1.4 Effluent Biological Organism Monitoring

Once a ballast water treatment system is required to be installed onboard a vessel (see part 

2.2.3.5.2 for applicability and timeframe for installation of such vessels), any ballast water 

discharges from such vessels will be subject to the effluent limitations in Part 2.2.3.5 of this 

permit. To ascertain compliance with the effluent limitation in that section, EPA is establishing 

the following biological indicator compliance monitoring. These samples can be taken by 

collecting a small volume sample from the ballast water discharge (consistent with the sampling 

guidance found in EPA’s Generic Protocol for the Verification of Ballast Water Treatment 

Technology) and analyzing the sample for concentrations of certain biological indicator 

parameters. Analysis of concentrations of indicator organisms must include monitoring for the 

parameters in Table 2 below utilizing the methods in that table, or other EPA Part 136 methods 

as applicable. 

Table 2: Indicator Organism Monitoring Parameters

Measurement Instrument 

or Analysis

EPA 

Method

Standard 

Method

ASTM ISO Other

Total 

heterotrophic 

bacteria

Plate counts SM 9215 ASTM 

D5465

ISO 

6222:1999

E. coli Selective 

substrate 

EPA Method 

1103.1 and 

1603

SM 9223B ASTM 

D5392 – 93

ISO 9308-

1:2000

Colilert®

Enterococci Selective 

substrate

EPA Method 

1106.1 and 

1600

SM 9230C ASTM 

D5259 – 

92(2006)

ISO 7899-

2:2000

Enterolert®

Biological indicator compliance monitoring sampling of ballast water effluent must be conducted 

2 times per year for vessels with type approved devices for which high quality type approval 

data are available, and 4 times per year for non-type approved devices or type approved devices 

for which high quality data are not available. Each sample must be tested independently and the 
Proposed 2013 Vessel General Permit (VGP)

29 

individual results must be reported and not averaged. Monitoring must be conducted at least 14 

days apart from different discharge events. 

Type approved devices for which high quality type approval data are available means either:

a) any ballast water treatment system type approved by the United States federal 

government; or 

b) any ballast water treatment system: 

i. type approved by a foreign administration; 

ii. for which efficacy testing was conducted by an independent 3rd party testing 

organization, either in accordance with the ETV protocol or in a manner 

consistent with the ETV protocol with respect to QA/QC procedures, the use of 

validated methods including appropriate volumes of representative samples, and 

full description and documentation of test procedures, results and analyses; and

iii. all active substance data (e.g., the full data package submitted to the flag 

administration for type approval) have all been made available to the US EPA. 

2.2.3.5.1.1.5 Requirements and Effluent Limitations for BWTS that use Active Substances (e.g., 

biocides) 

2.2.3.5.1.1.5.1 Authorization of Residual Biocides Associated with Ballast Water Treatment 

Systems

Many ballast water treatment systems produce or use biocides as an agent to reduce living 

organisms present in the ballast water tank. In order to be eligible for coverage under this permit, 

any ballast water treatment system must not use any biocide that is a “pesticide” within the 

meaning of the Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C § 136 et seq.) 

unless that biocide has been registered for use in ballast water treatment under such Act. The 

requirement in the preceding sentence does not apply if such biocide is generated solely by the 

use of a “device” on board the same vessel as the ballast water to be treated by the biocide, as the 

term “device” is defined in the Federal Insecticide, Fungicide, and Rodenticide Act. In addition, 

if the ballast water treatment system uses or generates biocides and you will discharge ballast 

water treated with biocides into waters subject to this permit, you must meet one of the following 

conditions to be eligible for permit coverage. 

The discharge of biocides or residuals may not exceed the following instantaneous maximum 

limits expressed as micrograms per liter (μg/l). 
Proposed 2013 Vessel General Permit (VGP)

30 

Table 3: Maximum Ballast Water Effluent Limits for Residual Biocides

Biocide or Residual Limit

(instantaneous maximum)

Chlorine Dioxide 200 μg/l

Chlorine (expressed as Total Residual Oxidizers (TRO as TRC)) 100 μg/l

Ozone (expressed as Total Residual Oxidizers (TRO as TRC)) 100 μg/l

Peracetic Acid 500 μg/l

Hydrogen Peroxide (for systems using Peracetic Acid) 1,000 μg/l

Any other biocides or derivatives may not exceed acute water quality criteria listed in EPA’s 

1986 Quality Criteria for Water [the Gold Book], and any subsequent revision, at the point of 

ballast water discharge. The Gold Book can be found at: 

www.epa.gov/waterscience/criteria/library/goldbook.pdf. Tables summarizing the subsequent 

revisions can be found at: http://www.epa.gov/waterscience/criteria/wqctable/index.html. 

Discharges of biocide residuals or derivatives must also meet monitoring requirements under 

Part 2.2.3.5.1.1.1, and reporting and recordkeeping requirements in Part 2.2.3.5.1.1.6. 

If the biocide used or produced by your system and its derivatives is not listed in the previous 

table or found in EPA’s Gold Book, you must notify EPA at least 120 days in advance of its use 

and provide any associated aquatic toxicity data for that biocide or its derivatives of which you 

are aware. EPA may impose additional limitations on a treatment system-specific basis, or 

require you to obtain coverage under an individual permit, if necessary. EPA may inform the 

vessel owner/operator of specific requirements. You may also seek coverage under an individual 

NPDES permit pursuant to Part 1.8.2 of this permit. You may not discharge the biocide at issue 

until you receive a response from EPA to your notification. 

2.2.3.5.1.1.5.2 Residual Biocide and Derivative Monitoring 

For vessels subject to Part 2.2.3.5.1.1.1, you must conduct monitoring of the vessel ballast water 

discharge for any residual biocides or derivatives used in the treatment process, in part to 

demonstrate compliance with the conditions in Part 2.2.3.5.1.1.5.1. For instance, if chlorine is the 

biocide used in the ballast water treatment, you must test for residual chlorine in the vessel 

ballast water discharge to see if it complies with the standards in Part 2.2.3.5.1.1.5.1. 

In order to demonstrate that residual biocides or derivatives are in compliance with this permit, 

that substantial quantities of harmful byproducts are not produced, and provide EPA with needed 

information about system functionality, the vessel operator initially must take samples according 

to the following: 
Proposed 2013 Vessel General Permit (VGP)

31 

Table 4: Monitoring Schedule for Residual Biocides or Derivatives of the Residual 

Biocide

Type approved devices for which 

high quality type approval data are 

available

Type approved devices for 

which high quality data are not 

available

Initial 

Monitoring 

3 times in the first 10 discharge events

(not to exceed a 180 day period) 

5 times in the first 10 discharge 

events (not to exceed a 180 day 

period)

Maintenance 

monitoring

2 times per year 4 times per year

Type approved devices for which high quality type approval data are available means either:

a) any ballast water treatment system type approved by the United States 

federal government; or 

b) any ballast water treatment system: 

i. type approved by a foreign administration; 

ii. for which efficacy testing was conducted by an independent 3rd 

party testing organization, either in accordance with the ETV 

protocol or in a manner consistent with the ETV protocol with 

respect to QA/QC procedures, the use of validated methods 

including appropriate volumes of representative samples, and full 

description and documentation of test procedures, results and 

analyses; and

iii. all active substance data (e.g., the full data package submitted to 

the flag administration for type approval) have all been made 

available to the US EPA. 

Each sample must be tested independently and the individual results must be reported and not 

averaged. Samples must be tested as soon as possible after sampling, and may not be held longer 

than recommended for each tested constituent as given in 40 CFR Part 136. Sampling and testing 

shall be conducted using a sufficiently sensitive method according to 40 CFR Part 136 or may 

use an alternate method if allowed in Table 5 below.

Table 5: Residual Biocides and Biocide Derivative Monitoring Requirements

Biocide Analyte Analytical 

Methods

Minimum 

Sample 

Volume

Sample 

Holding 

Time

MDL Effluent 

Limit or 

Action

Limit Type

Alkylamines Alkylamines EPA 

Method 

8360B and 

8270D

25 mL 

(8260B)

14 days 

(8260B)

Varies by 

compound 

(8260D); 

10 μg/L 

(8270C)

Report NA
Proposed 2013 Vessel General Permit (VGP)

32 

Table 5: Residual Biocides and Biocide Derivative Monitoring Requirements

Biocide Analyte Analytical 

Methods

Minimum 

Sample 

Volume

Sample 

Holding 

Time

MDL Effluent 

Limit or 

Action

Limit Type

Chlorine or 

Chlorine 

dioxide

Chlorine dioxide EPA 

Method 

327.0-1; 

SM 4500 

ClO2 E 

16 mL 

(327.0-1)

4 hours 

(327.0-

1); As 

soon as 

possible 

(SM)

Varies 

(327.0-1); 

10 to 100 

mg/L (SM)

200 μg/L Instantaneous 

Maximum

Total Residual 

Oxidizers (TRO) 

as Cl2

SM 4500-

Cl G; ISO 

7393/2

50 mL 15 

minutes

10 μg/L, 

under ideal 

conditions

100 μg/L Instantaneous 

Maximum

Chlorite* EPA 

Method 

300.1

250 mL 14 days Varies Report NA

Chlorate* EPA 

Method 

300.1

250 mL 28 days Varies Report NA

Total 

trihalomethanesa* 

EPA 

Method 

8260

25 mL 14 days Varies Report NA

Haloacetic acidsb* EPA 

Method 

552.2 

40 mL 14 days Varies by 

compound

Report NA

Menadione Menadione NA Report NA

Ozone Total Residual 

Oxidizers (TRO) 

as Cl2

SM 4500-

Cl G; ISO 

7393/2

50 mL 15 

minutes

10 μg/L, 

under ideal 

conditions

100 μg/L NA

Bromate* EPA 

Method 

317 ; EPA 

Method 

300.1; 

ASTM D 

6581-00

250 mL 28 days 

(317; 

300.1)

Varies 

(317; 

300.1)

Report NA

Bromoform* EPA 

Method 

8260

25 mL 14 days Varies Report NA

Total 

trihalomethanesa* 

EPA 

Method 

8260

25 mL 14 days Varies Report NA

Haloacetic acidsb* EPA 

Method 

552.2 

40 mL 14 days Varies by 

compound

Report NA

Peracetic Acid pH SM 4500 

H+

25 mL As soon 

as 

possible

6.5 – 9 

s.u.

Instantaneous 

Maximum

Peracetic acid Photometri

c analysis 

(Pinkernell, 

1997; EMD 

Chemicals, 

2011; 

CHEMetric

s 2010)

25 mL As soon 

as 

possible

500 μg/L Report NA
Proposed 2013 Vessel General Permit (VGP)

33 

Table 5: Residual Biocides and Biocide Derivative Monitoring Requirements

Biocide Analyte Analytical 

Methods

Minimum 

Sample 

Volume

Sample 

Holding 

Time

MDL Effluent 

Limit or 

Action

Limit Type

Hydrogen 

peroxide/

Titimetric 

analysis 

(JIS K 

1463:2007; 

EMD 

Chemicals, 

2011; 

CHEMetric

s 2010))

25 mL As soon 

as 

possible

500 μg/L Report NA

* Potential byproduct or derivative

a. Total trihalomethanes is the sum of the concentrations of chloroform, bromodichloromethane, dibromochloromethane, and 

bromoform.

b. Haloacetic acids is the sum of the concentrations of mono-, di-, and trichloroacetic acids and mono- and dibromoacetic 

acids.

ISO: International Organization for Standardization

SM: Standard Methods

MDL: Method detection limit

NA: Not applicable

2.2.3.5.1.1.6 Ballast Water Treatment System Recordkeeping and Reporting 

Records of sampling and testing results required under Part 2.2.3.5.1.1 must be retained onboard 

for a period of three years in the vessel’s recordkeeping documentation. Vessels must also 

submit the testing results to EPA using EPA’s e-reporting system as part of the vessel’s annual 

report (unless you are eligible to submit a hard copy of the annual report). 

Records of monitoring information shall include: 

• The ballast water treatment system used, its type approval certificate, and records 

of whether the system is a vessel with type approved devices for which all type 

approval data have been made available;

• The individual(s) who performed the sampling, measurements, and/or inspections; 

• The date(s) analyses and/or inspections were performed;

• Any sensor or other control equipment calibration and functional tests conducted 

during the inspection as applicable; 

• The techniques or methods used for any sensor or other control equipment 

calibration and functional tests as applicable;

• The date and time of all monitoring results (monitoring in Parts 2.2.3.5.1.1.2, 

2.2.3.5.1.1.4, and 2.2.3.5.1.1.5, as applicable);

• The analytical techniques or methods used as applicable, and 

• The results of such analyses.

You must submit your monitoring data as part of your annual report. For systems already in use 

as of the effective date of this permit, initial sampling data must be submitted with the first 

annual report. For systems which are not already in use as of the effective date of this permit, 

initial sampling data must be submitted on the annual report following the calendar year of the 

system’s first use. Data must be submitted on the Ballast Water Treatment System Report form 
Proposed 2013 Vessel General Permit (VGP)

34 

attached to the annual report available in Appendix H of this permit or submitted to EPA’s ereporting system available at www.epa.gov/npdes/vessels/eNOI. 

2.2.3.5.1.2 Onshore Treatment of Ballast Water

For those vessels whose design and construction safely allows for the transfer of ballast water to 

shore, if compatible onshore treatment for ballast water is available, the vessel owner/operator 

may use onshore treatment for any ballast water discharges to meet the requirements of 2.2.3.5. 

EPA notes that the lack of availability of adequate reception facilities is not an acceptable reason 

to discharge ballast water which does not meet the treatment requirements found in Part 

2.2.3.5.1.1 into waters subject to this permit, and such discharges would therefore constitute a 

permit violation.

Any vessel owner/operator utilizing onshore treatment must ensure that all piping and supporting 

infrastructure up to the last manifold or valve immediately before the dock manifold connection 

of the receiving facility or similar appurtenance on a reception vessel must be fully free from any 

leaks or other avenues whereby untreated ballast may be discharged into waters subject to this 

permit. 

EPA notes that transferring ballast water to a treatment barge for eventual treatment and

discharge could constitute “on-shore treatment” for purposes of this subpart. The discharge of 

treated ballast water (transferred from other vessels) from a treatment barge is not eligible for 

coverage under the VGP as this is a discharge from an industrial operations, not a discharge 

incidental to the normal operation of a vessel. Instead, these vessels must apply for individual 

NPDES permit coverage from the appropriate NPDES permitting authority, generally the State 

in which they are operating. 

2.2.3.5.1.3 Use of Public Water Supply Water 

Vessels may meet the requirements of Part 2.2.3.5 by using only water from a U.S. public water 

system or Canadian drinking water system (both referred to as PWS in this permit), as defined in 

a) 40 CFR 141.2 and subject to the requirements of 40 CFR parts 141 and 143 or b) Health 

Canada’s “Guidance For Providing Safe Drinking Water in Areas of Federal Jurisdiction,” as 

ballast water. Vessels using water from a PWS as ballast must maintain a record of which PWS 

they received the water and a receipt, invoice, or other documentation from the PWS indicating 

that water came from that system. 

Vessels using water from a PWS must use such water exclusively for all ballast water to avoid 

contamination of the ballast water tank. Vessels using PWS water as ballast must have either:

• Previously cleaned the ballast tanks (including removing all residual sediments) 

and not subsequently introduced ambient water; or 

• Never introduced ambient water to those tanks and supply lines. 

Vessels utilizing water from a PWS as ballast water must certify in their recordkeeping 

documentation that they have met all the requirements of this section, including maintaining 
Proposed 2013 Vessel General Permit (VGP)

35 

certification by the master or NOI certifier that one of the two above conditions are met 

regarding contamination. 

In the event a vessel that normally uses PWS water as ballast is forced for purposes of vessel 

safety to take on untreated ballast water from a sea, estuary, lake or river source, such vessel may 

not return to using PWS water until the tanks and supply lines have been cleaned, including 

removal of all residual sediments.

2.2.3.5.1.4 No Discharge of Ballast Water

Vessels may meet the requirements of Part 2.2.3.5 of this permit by not discharging any ballast 

water into waters subject to this permit. EPA notes that any discharge of untreated ballast water, 

including for reasons of unscheduled voyages, loading of unexpected cargo, etc., do not qualify 

as an acceptable reason to discharge untreated ballast water into waters subject to this permit, 

and therefore constitute a permit violation. EPA notes that in the case of a shipboard emergency 

that endangers the safety of the vessel or its crew, ballast water may need to be pumped out 

quickly by bypassing the BWTS. In such cases, the provisions regarding the prohibition of 

bypassing treatment where unavoidable to prevent loss of life, personal injury of severe property 

damage may be applicable. See 40 CFR 122.41(m)(4)(A) and Part 1.13 of this permit. 

2.2.3.5.2 Schedule for when Ballast Water Treatment Becomes BAT (and Therefore Required) 

Table 6 describes when BWTS will become the Best Available Technology Economically 

Achievable (BAT) and thus when any ballast water discharges from such vessels will be subject 

to the Effluent limitations in Part 2.2.3.5.1 of this permit. Vessels must meet the requirements in 

Part 2.2.3.5.1 according to the schedule below in Table 6. 

Table 6: Ballast Water Treatment to BAT Schedule

Vessel’s

Ballast Water 

Capacity

Date Constructed Vessel’s Compliance

Date

New

vessels

After January 1, 2012 On delivery

Existing

vessels

Less than 1500 m3 Before January 1, 2012 First scheduled drydocking after 

January 1, 2016

1500-5000 m3 Before January 1, 2012 First scheduled drydocking after 

January 1, 2014

Greater than 5000 m3 Before January 1, 2012 First scheduled drydocking after 

January 1, 2016

2.2.3.5.3 Vessels Not Required to Meet Part 2.2.3.5 Treatment Standards 

The following Vessel Types are not required to meet Part 2.2.3.5 ballast water management 

measures:
Proposed 2013 Vessel General Permit (VGP)

36 

2.2.3.5.3.1 Vessels Engaged in Short-Distance Voyages

Vessels engaged in short distance voyages means vessels that: 

• Operate exclusively in one Coast Guard Captain of the Port (COTP) Zone, or 

• Vessels which do not travel more than 10 nm and cross no physical barriers or 

obstructions (e.g., locks), whether or not they operate within one U.S. Coast 

Guard COTP zone. 

2.2.3.5.3.2 Unmanned, Unpowered Barges 

Unmanned, unpowered barges such as hopper barges are not required to meet the ballast water 

management measures of Part 2.2.3.5. 

2.2.3.5.3.3 Existing Bulk Carrier Vessels (Commonly Known as Lakers) Built Before January 1, 

2009, Confined Exclusively to the Great Lakes Upstream of the Welland Canal 

Existing Lakers built before January 1, 2009 confined exclusively to the Great Lakes upstream of 

the Welland Canal are not required to meet the requirements of Part 2.2.3.5. 

2.2.3.6 Interim requirements for vessels not meeting the ballast water management 

measures in Part 2.2.3.5

Vessel owner/operators not meeting the requirements of Part 2.2.3.5 of the permit must meet the 

exchange and flushing requirements of this part as applicable. Ballast water exchange may not 

be used in lieu of meeting the numeric effluent limits in Part 2.2.3.5 of the permit once a vessel is 

required to meet these limits. Conversely, vessel owner/operators meeting the numeric effluent 

limits in Part 2.2.3.5 before they are required to do so by the implementation schedule in Part 

2.2.3.5.2 are not required to meet the exchange and flushing requirements of this subpart. 

2.2.3.6.1 Requirements for Oceangoing Voyages While Carrying Ballast Water 

Any vessels that carry ballast water that was taken on in areas less than 200 nautical miles from 

any shore that will subsequently operate beyond the Exclusive Economic Zone (EEZ) and more 

than 200 nm from any shore must carry out an exchange of ballast water for any tanks that will 

discharge ballast water into waters subject to this permit unless the vessel meets one of the 

exemptions in Part 2.2.3.6.6. 

This exchange must be conducted in compliance with the following standards prior to 

discharging ballast water into waters subject to this permit:

• The exchange must occur in waters beyond the U.S. EEZ;

• The exchange must occur in an area more than 200 nautical miles from any shore; 

and

• The exchange must be commenced as early in the vessel voyage as possible, as 

long as the vessel is more than 200 nm from any shore. 
Proposed 2013 Vessel General Permit (VGP)

37 

2.2.3.6.2 Vessels Carrying Ballast Water Engaged in Pacific Nearshore Voyages 

Unless the vessel meets one of the exemptions in Part 2.2.3.6.6, any vessel engaged in Pacific 

nearshore voyages that carries ballast water that was taken on in areas less than 50 nautical miles 

from any shore must carry out an exchange of ballast water in accordance with this Part before 

discharging from any tanks that carry ballast water into waters subject to this permit if the vessel 

travels through more than one COTP zone as listed in 33 CFR Part 3 or the vessel crosses 

international boundaries. 

Vessels engaged in Pacific nearshore voyages are:

• Vessels engaged in the Pacific coastwise trade and vessels transiting between 

Pacific ports that travel between more than one Captain of the Port Zone, and 

• All other vessels that sail from foreign, non-U.S Pacific, Atlantic (including the 

Caribbean Sea), or Gulf of Mexico ports, which do not sail further than 200 nm 

from any shore, and that discharge or will discharge ballast water into the 

territorial sea or inland waters of Alaska or off the west coast of the continental 

United States.

Ballast water exchange for vessels subject to this Part must occur in waters more than 50 nautical 

miles from any shore (US or otherwise), and in waters more than 200 meters deep, prior to 

discharging ballast water into waters subject to this permit. Exchange should occur as far from 

the shore, major estuary and oceanic river plumes, subsurface physical features (e.g. seamounts), 

and known fishery habitats as practicable. Vessels engaged in voyages that take them further 

than 200 nm from any shore and who will remain outside 200 nm for a sufficient period to 

conduct exchange, are not allowed to exchange ballast water between 50 and 200 nm from shore 

to meet the requirements of Part 2.2.3.6.1 (unless the master determines that flushing farther than 

200 nm from shore would interfere with essential vessel operations or safety of the vessel but the 

master determines that the vessel is able to safely flush more than 50 nm from shore) and instead, 

must conduct exchange more than 200 nm from shore in accordance with Part 2.2.3.6.1 of this 

permit. Vessels engaged in the coastwise trade who are not outside 200 nm for a sufficient period 

to conduct exchange may conduct exchange outside 50 nm (even if they voyage beyond 200 nm) 

to meet the requirements of this permit.

2.2.3.6.3 Vessels with any Ballast Water Tanks that are Empty or have Unpumpable Residual 

Water

For vessels that travel between more than one COTP Zone while undertaking voyages described 

in Part 2.2.3.6.1 and which either reported No Ballast on Board (NOBOB) in accordance with 

Coast Guard regulations or which have any ballast water tank that is empty or contains 

unpumpable residual water, you must follow the applicable requirements in Part 2.2.3.6.1 for 

those tanks with ballast water. EPA notes that when the term “empty” tank is used, the Agency is 

also referring to tanks that contain unpumpable residual water. For those tanks which are empty 

or contain unpumpable residual water, you must either seal the tank so that there is no discharge 

or uptake and subsequent discharge of ballast water within waters subject to this permit or 

conduct saltwater flushing of such tanks in an area 200 nm from any shore prior to the discharge 

or uptake and subsequent discharge of any ballast water to any U.S. waters subject to this permit, 
Proposed 2013 Vessel General Permit (VGP)

38 

unless you meet one of the exemptions in Part 2.2.3.6.6. For the purposes of Part 2.2.3.6.3, 

saltwater flushing means the addition of mid-ocean water to empty ballast water tanks; the 

mixing of the added water with residual ballast water and sediment through the motion of the 

vessel; and the discharge of the mixed water until loss of suction, such that the resulting residual 

water remaining in the tank has either a salinity greater than or equal to 30 parts per thousand 

(ppt) or a salinity concentration equal to the ambient salinity of the location where the uptake of 

the added water took place. In order to conduct saltwater flushing, the vessel should take on as 

much mid-ocean water into each tank as is safe (for the vessel and crew).

For all vessel owner/operators subject to this section that contain some empty ballast water tanks 

and some full ballast water tanks, if you elect to seal those empty tanks, you must not allow 

water that will be discharged into waters subject to this permit to commingle with waters from 

the empty tanks if you have not conducted saltwater flushing as specified above. 

2.2.3.6.4 Vessels Engaged in Pacific Nearshore Voyages with Unpumpable Ballast Water and 

Residual Sediment (including NOBOBs) 

Unless the vessel meets one of the exemptions in Part 2.2.3.6.6, any vessel engaged in Pacific 

Nearshore Voyages as defined in Part 2.2.3.6.2 which the owner/operator has reported as having 

No Ballast on Board in accordance with Coast Guard regulations, or which have any ballast 

water tank that is empty or contains unpumpable residual water, must follow the applicable 

requirements in Part 2.2.3.6.2 for those tanks with ballast water and Part 2.2.3.6.4.1 for those 

tanks which are empty or contain unpumpable residual water. 

2.2.3.6.4.1 Nearshore Saltwater Flushing Requirements

For those tanks which are empty or contain unpumpable residual water, you must either seal the 

tank so that there is no discharge or uptake and subsequent discharge of ballast water within 

waters subject to this permit or conduct saltwater flushing of such tanks in an area 50 nm from 

any shore and in waters at least 200 meters deep prior to the discharge or uptake and subsequent 

discharge of any ballast water to or from any waters subject to this permit. For purposes of Part 

2.2.3.6.4, saltwater flushing means the addition of water from the “coastal exchange zone” to 

empty ballast water tanks; the mixing of the flush water with residual water and sediment 

through the motion of the vessel; and the discharge of the mixed water, such that the resulting 

residual water remaining in the tank has either a salinity greater than or equal to 30 parts per 

thousand (ppt) or a salinity concentration equal to the ambient salinity of the location where the 

uptake of the added water took place. In order to conduct saltwater flushing, the vessel should 

take on as much coastal exchange zone water into each tank as is safe (for the vessel and crew). 

These requirements apply to all vessels on nearshore voyages carrying ballast water that will 

enter any US port in the states of Alaska, California, Oregon, or Washington and that travels 

through more than one US Coast Guard Sector. 

Vessels engaged in voyages that take them further than 200 nm from any shore and who will 

remain outside 200 nm for a sufficient period to flush ballast water, are not allowed to exchange 

ballast water between 50 and 200 nm from shore to meet the requirements of Part 2.2.3.6.3

(unless the master determines that flushing farther than 200 nm from shore would interfere with 

essential vessel operations or safety of the vessel but the master determines that the vessel is able 
Proposed 2013 Vessel General Permit (VGP)

39 

to safely flush more than 50 nm from shore) and instead, must conduct flushing more than 200 

nm from shore in accordance with Part 2.2.3.6.3 of this permit. Vessels engaged in the coastwise 

trade who are not outside 200 nm for a sufficient period to conduct flushing may flush outside 50 

nm (even if they voyage beyond 200 nm) to meet the requirements of this permit. 

For all vessel owner/operators subject to this section that contain some empty ballast water tanks 

and some full ballast water tanks, if you elect to seal those empty tanks, you must not allow 

water from the full tanks to commingle with waters from the empty tanks if it will subsequently 

be discharged into waters subject to this permit. 

2.2.3.6.5 Discharge Prohibitions 

Vessels referenced in Parts 2.2.3.6.1, 2.2.3.6.2, 2.2.3.6.3, and 2.2.3.6.4 may not discharge 

unexchanged or untreated ballast water or sediment in waters subject to this permit referenced in 

Appendix G. These waters include all National Parks and National Marine Sanctuaries. 

2.2.3.6.6 Exemptions 

The operator or master of a vessel may elect not to exchange ballast water (or not conduct 

saltwater flushing if applicable) if the vessel meets one of the following conditions: 

• The master of the vessel determines, and justifies in writing, and documents in the 

log or record book, that it is unsafe to do so, in accordance with the Coast Guard 

Regulations at 33 CFR Part 151. If this exemption is claimed, the vessel operator 

must record the date, location, and reason for the claim in its recordkeeping 

documentation. Furthermore, the vessel owner/operator must report this 

information to EPA as part of its annual report. 

• The master uses an alternative, environmentally sound method of ballast water 

management that has been approved by the Commandant of the Coast Guard prior 

to the vessel's voyage in accordance with 33 C.F.R. Part 151. 

• The master retains all ballast water on board the vessel for the duration of the 

vessel’s voyage in waters subject to this permit.

• The vessel is not engaged in an international voyage and does not traverse more 

than one U.S. Coast Guard Sector. 

Additionally, except for vessels entering the Great Lakes or into Appendix G waters, a vessel is 

not required to deviate from its voyage, or delay the voyage to conduct ballast water exchange or 

saltwater flushing.

2.2.3.7 Vessels Entering the Great Lakes

In addition to complying with the requirements of this permit, all vessels that are equipped to 

carry ballast water and enter the Great Lakes must comply with 33 CFR Part 151, Subpart C 

titled: “Ballast Water Management for Control of Nonindigenous Species in the Great Lakes and 

Hudson River.” Vessels that operate outside the EEZ and more than 200 nm from any shore and 

then enter the Great Lakes via the Saint Lawrence Seaway System must also comply with 33 

CFR Part 401.30. Vessels that are unable, due to weather, equipment failure, or other 
Proposed 2013 Vessel General Permit (VGP)

40 

extraordinary condition, to effect a BWE before entering the EEZ prior to entering the Great 

Lakes, must employ another method of ballast water management listed in 33 CFR 151.1510 or 

otherwise comply with the provision of 33 CFR 151.1514. 

Additionally, vessels utilizing a ballast water treatment system (see Part 2.2.3.5.1.1 of the 

permit) must also conduct ballast water exchange or saltwater flushing (as applicable) in addition 

to treating their ballast water if they meet the following requirements:

• The vessel operates outside the EEZ and more than 200 nm from any shore and 

then enters the Great Lakes via the Saint Lawrence Seaway System, and

• The vessel has taken on ballast water that has a salinity of less than 18 ppt from a 

coastal, estuarine, or freshwater ecosystem within the previous month. 

If a vessel affected by these requirements has not taken on ballast water with a salinity of less 

than 18 ppt in the previous month, the master of the vessel must certify to this effect in their 

ballast water recordkeeping requirements before entering the Great Lakes.

2.2.3.8 Vessels in the U.S. Coast Guard Shipboard Technology Evaluation Program 

(STEP)

Owner/operators of vessels are not required to meet the requirements of Parts 2.2.3.5 (except 

Parts 2.2.3.5.1.1.5 2.2.3.5.1.1.6) and 2.2.3.6 of this permit if either:

• The vessel is accepted by the U.S. Coast Guard into the Shipboard Technology 

Evaluation Program (STEP), 

• The technology is operated in accordance with requirements of that program, and 

• The acceptance has not been withdrawn

Owner/operators of these vessels are required to meet the requirements of Parts 2.2.3.5.1.1.5 and 

2.2.3.5.1.1.6 of this permit.

2.2.4 Anti-Fouling Hull Coatings/ Hull Coating Leachate 

• All anti-fouling hull coatings subject to registration under FIFRA (see 40 CFR § 

152.15) must be registered, sold or distributed, applied, maintained, and removed 

in a manner consistent with applicable requirements on the coatings’ FIFRA label. 

• For anti-fouling hull coatings not subject to FIFRA registration (i.e., not produced 

for sale and distribution in the United States), hull coatings must not contain any 

biocides or toxic materials banned for use in the United States (including those on 

EPA’s List of Banned or Severely Restricted Pesticides). This requirement applies 

to all vessels, including those registered and painted outside the United States. 

At the time of initial application or scheduled reapplication of anti-fouling coatings, you must 

give consideration, as appropriate for vessel class and vessel operations, to the use of hull 

coatings with the lowest effective biocide release rates, rapidly biodegradable components (once 

separated from the hull surface), or non-biocidal alternatives, such as silicone coatings.
2013 VGP and sVGP BE Appendix D

Appendix D. Water Quality and Other Benchmark Values Used to Screen the 

Vessel Discharge Data
2013 VGP and sVGP BE Appendix D

D-1

To provide a context for the level of contaminant concentrations presented, EPA used 

National Recommended Water Quality Criteria (NRWQC)1 and several other benchmarks as a 

preliminary screen for all discharge data with the potential to cause or contribute to the 

nonattainment of a water quality standard in a given receiving water body. The “screening-level” 

benchmarks chosen for this purpose are shown in the Table D-1 below, and generally represent 

EPA’s most conservative (protective) concentration available for the specific analyte of interest. 

Several “legacy” standards (for BOD, TSS and total phosphorus) are also included with the screening 

benchmarks. For BOD and TSS, these benchmarks are EPA’s secondary treatment effluent limits for 

sewage treatment plants.2 For total phosphorus, the benchmark of 0.1 mg/L is from EPA’s Gold 

Book (USEPA, 1986) and represents a concentration recommended to prevent nuisance algal blooms 

resulting from eutrophication in flowing waters. EPA did not consider it appropriate to apply 

ecoregional nutrient criteria for this project. 

EPA’s NRWQC are recommended concentrations of analytes in a water body that are 

intended to protect human health, aquatic organisms and the water body uses from unacceptable 

effects from exposures to these pollutants. The NRWQC are not directly related to analyte 

concentrations in a discharge for a number of reasons. First, NRWQC not only have a concentration 

component, but also a duration and frequency component. Second, it is not always necessary to meet 

all water quality criteria within the discharge pipe to protect the integrity of a water body (USEPA, 

1991). Under EPA’s regulations at 40 CFR 122.44(d)(1)(ii), when determining whether a discharge 

causes, has the reasonable potential to cause, or contributes to an in-stream excursion above a 

narrative or numeric criteria within a state water quality standard, the permitting authority will use 

procedures that account for, where appropriate, the dilution of the effluent in the receiving water. A 

mixing zone allows for ambient concentrations above the criteria in small areas near outfalls while 

dilution occurs. To ensure mixing zones do not impair the integrity of the water body, the permitting 

authority will determine the mixing zone such that it does not cause lethality to passing organisms 

and, considering likely pathways of exposure, significant human health risks. 

Nevertheless, comparing analyte concentrations in vessel discharges to NRWQC (or other 

equivalent screening benchmark) provides a conservative screen of whether these discharges cause, 

have the reasonable potential to cause, or contribute to nonattainment of the water quality standards 

in a water body. 

 1 National Recommended Water Quality Criteria (NRWQC) include acute (short-term) and chronic (long-term) 

criteria (toxicity threshold values) for the protection of aquatic life, as well as Human Health criteria for protection 

of humans from consumption of contaminated water or contaminated water and aquatic organisms. EPA's most 

recent compilation of NRWQC (2006) is presented as a summary table containing recommended water quality 

criteria for the protection of aquatic life and human health in surface water for approximately 150 pollutants. These 

criteria are published pursuant to Section 304(a) of the Clean Water Act (CWA) and provide guidance for states and 

tribes to use in adopting water quality standards. EPA’s 2006 NRWQC are available at: 

http://www.epa.gov/waterscience/criteria/wqctable/, hereafter referred to as EPA’s 2006 NRWQC. 

2 Secondary treatment standards for sewage treatment plants were technology-based limits developed in the late 

1970s and early 1980s, and are not the same as the water-quality-based criteria in the 2006 NRWQC. Thus, the 

PHQs for BOD and TSS calculated as described below are not directly comparable to the PHQs based on criteria 

designed to protect aquatic life or human health but, by design, such standards are imposed to limit ecological 

impacts. 
2013 VGP and sVGP BE Appendix D

D-2

Table D-1. Water Quality and Other Benchmark Values Used to Screen the Vessel 

Discharge Data

Analyte Screening 

Benchmarks Units Sources

1,1,2,2-Tetrachloroethane 0.17 μg/L 2006 NRWQC HH W+O

1,1,2-Trichloroethane 0.59 μg/L 2006 NRWQC HH W+O

1,1-Dichloroethene 330 μg/L 2006 NRWQC HH W+O

1,2,4,5-Tetrachlorobenzene 0.97 μg/L 2006 NRWQC HH W+O

1,2,4-Trichlorobenzene 35 μg/L 2006 NRWQC HH W+O

1,2-Dichlorobenzene 420 μg/L 2006 NRWQC HH W+O

1,2-Dichloroethane 0.38 μg/L 2006 NRWQC HH W+O

1,2-Dichloropropane 0.5 μg/L 2006 NRWQC HH W+O

1,2-Diphenyl hydrazine 0.036 μg/L 2006 NRWQC HH W+O

1,3-Dichlorobenzene 320 μg/L 2006 NRWQC HH W+O

1,3-Dichloropropane 0.34 μg/L 2006 NRWQC HH W+O

1,4-Dichlorobenzene 63 μg/L 2006 NRWQC HH W+O

2,3,7,8-TCDD (Dioxin) 5.0E-09 μg/L 2006 NRWQC HH W+O

2,4,5-Trichlorophenol 1,800 μg/L 2006 NRWQC HH W+O

2,4,6-Trichlorophenol 1.4 μg/L 2006 NRWQC HH W+O

2,4-Dichlorophenol 77 μg/L 2006 NRWQC HH W+O

2,4-Dimethylphenol 380 μg/L 2006 NRWQC HH W+O

2,4-Dinitrophenol 69 μg/L 2006 NRWQC HH W+O

2,4-Dinitrotoluene 0.11 μg/L 2006 NRWQC HH W+O

2-Chloronaphthalene 1,000 μg/L 2006 NRWQC HH W+O

2-Chlorophenol 81 μg/L 2006 NRWQC HH W+O

2-Methyl-4,6-Dinitrophenol 13 μg/L 2006 NRWQC HH W+O

3,3'-Dichlorobenzidine 0.021 μg/L 2006 NRWQC HH W+O

4,4'-DDD 0.00031 μg/L 2006 NRWQC HH Org Only

4,4'-DDE 0.00022 μg/L 2006 NRWQC HH Org Only

4,4'-DDT 0.001 μg/L 2006 NRWQC CCC

4,6-Dinitro-2-methylphenol 13 μg/L 2006 NRWQC HH W+O

Asbestos 7,000,000 fibers/L 2006 NRWQC HH W+O

Acenaphthene 670 μg/L 2006 NRWQC HH W+O

Acrolein 6.0 μg/L 2006 NRWQC HH W+O

Acrylonitrile 0.051 μg/L 2006 NRWQC HH W+O

Aldrin 1.3 μg/L 2006 NRWQC SW CMC

Alkalinity 20,000 μg/L 2006 NRWQC FW CCC

alpha-BHC 0.0026 μg/L 2006 NRWQC HH W+O

alpha-Endosulfan 0.0087 μg/L 2006 NRWQC SW CCC

Aluminum, Total 87 μg/L 2006 NRWQC FW CCC

Ammonia As Nitrogen (NH3-N) 1.2 mg/L 2006 NRWQC FW CCC

Anthracene 8,300 μg/L 2006 NRWQC HH W+O

Antimony, Total 5.6 μg/L 2006 NRWQC HH W+O

Arsenic, Total 0.018 μg/L 2006 NRWQC HH W+O

Arsenic, Dissolved 36 μg/L 2006 NRWQC SW CCC

Barium, Total 1,000 μg/L 2006 NRWQC HH W+O

Benzene 2.2 μg/L 2006 NRWQC HH W+O

Benzidine 0.000086 μg/L 2006 NRWQC HH W+O

Benzo(a)Anthracene 0.0038 μg/L 2006 NRWQC HH W+O

Benzo(a)Fluoranthene 0.0038 μg/L 2006 NRWQC HH W+O

Benzo(a)pyrene 0.0038 μg/L 2006 NRWQC HH W+O

Benzo(b)fluoranthene 0.0038 μg/L 2006 NRWQC HH W+O
2013 VGP and sVGP BE Appendix D

D-3

Table D-1. Water Quality and Other Benchmark Values Used to Screen the Vessel 

Discharge Data

Analyte Screening 

Benchmarks Units Sources

Benzo(k)Fluoranthene 0.0038 μg/L 2006 NRWQC HH W+O

beta-BHC 0.0091 μg/L 2006 NRWQC HH W+O

beta-Endosulfan 0.0087 μg/L 2006 NRWQC SW CCC

Biochemical Oxygen Demand (BOD) 30 mg/L 1984 Secondary Treatment Effluent 

Limits

Bis (2-Chloroethyl) ether 0.030 μg/L 2006 NRWQC HH W+O

Bis (2-chloroisopropyl)ether 1,400 μg/L 2006 NRWQC HH W+O

Bis(2-Ethylhexyl) phthalate 1.2 μg/L 2006 NRWQC HH W+O

Bromodichloromethane 0.55 μg/L 2006 NRWQC HH W+O

Bromoform 4.3 μg/L 2006 NRWQC HH W+O

Bromomethane 47 μg/L 2006 NRWQC HH W+O

Butyl benzyl Phthalate 1,500 μg/L 2006 NRWQC HH W+O

Cadmium, Dissolved 0.25 μg/L 2006 NRWQC FW CCC

Carbon tetrachloride 0.23 μg/L 2006 NRWQC HH W+O

Chlordane 0.004 μg/L 2006 NRWQC SW CCC

Chloride 230,000 μg/L 2006 NRWQC SW CCC

Chlorobenzene 130 μg/L 2006 NRWQC HH W+O

Dibromochloromethane 0.40 μg/L 2006 NRWQC HH W+O

Chloroform 5.7 μg/L 2006 NRWQC HH W+O

Chlorophenoxy Herbicide (2,4,5,-TP) 10 μg/L 2006 NRWQC HH W+O

Chlorophenoxy Herbicide (2,4-D) 100 μg/L 2006 NRWQC HH W+O

Chloropyrifos 0.0056 μg/L 2006 NRWQC SW CCC

Chromium, Dissolved 11 μg/L 2006 NRWQC SW CCC

Chrysene 0.0038 μg/L 2006 NRWQC HH W+O

Copper, Dissolved 3.1 μg/L 2006 NRWQC SW CCC

Copper, Total 1,300 μg/L 2006 NRWQC HH W+O

Cyanide 1.0 μg/L 2006 NRWQC SW CMC

Demeton 0.1 μg/L 2006 NRWQC FW and SW CCC

Diazinon 0.17 μg/L 2006 NRWQC FW CMC and CCC

Dibenz(a,h)Anthracene 0.0038 μg/L 2006 NRWQC HH W+O

Chlorodibromomethane 0.40 μg/L 2006 NRWQC HH W+O

Dichlorobromomethane 0.55 μg/L 2006 NRWQC HH W+O

Dieldrin 0.0019 μg/L 2006 NRWQC SW CCC

Diethyl Phthalate 17,000 μg/L 2006 NRWQC HH W+O

Dimethyl phthalate 270,000 μg/L 2006 NRWQC HH W+O

Di-n-butyl phthalate 2,000 μg/L 2006 NRWQC HH W+O

Dinitrophenols 69 μg/L 2006 NRWQC HH W+O

E. Coli by MPN 126 MPN/100 

ml 1986 NRWQC B FW

Endosulfan Sulfate 62 μg/L 2006 NRWQC HH W+O

Endrin 0.0023 μg/L 2006 NRWQC SW CCC

Endrin Aldehyde 0.29 μg/L 2006 NRWQC HH W+O

Enterococci by MPN 33 MPN/100 

ml 1986 NRWQC B FW

Ether, Bis(Chloromethyl) 0.0001 μg/L 2006 NRWQC HH W+O

Ethylbenzene 530 μg/L 2006 NRWQC HH W+O
2013 VGP and sVGP BE Appendix D

D-4

Table D-1. Water Quality and Other Benchmark Values Used to Screen the Vessel 

Discharge Data

Analyte Screening 

Benchmarks Units Sources

Fecal Coliform by MF 14 MPN/100 

ml 1976 QCW SH

Fluoranthene 130 μg/L 2006 NRWQC HH W+O

Fluorene 1,100 μg/L 2006 NRWQC HH W+O

Gamma-BHC (Lindane) 0.16 μg/L 2006 NRWQC SW CMC

Guthion 0.01 μg/L 2006 NRWQC FW and SW CCC

Heptachlor 0.0036 μg/L 2006 NRWQC SW CCC

Heptachlor Epoxide 0.0036 μg/L 2006 NRWQC SW CCC

Hexachlorobenzene 0.00028 μg/L 2006 NRWQC HH W+O

Hexachlorobutadiene 0.44 μg/L 2006 NRWQC HH W+O

Hexachlorocyclo-hexane-Technical 0.0123 μg/L 2006 NRWQC HH W+O

Hexachlorocyclopentadiene 40 μg/L 2006 NRWQC HH W+O

Hexachloroethane 1.4 μg/L 2006 NRWQC HH W+O

Hexane Extractable Material (HEM) 15 mg/L MARPOL 73/78

Ideno(1,2,3-cd)Pyrene 0.0038 μg/L 2006 NRWQC HH W+O

Iron, Total 300 μg/L 2006 NRWQC HH W+O

Isophorone 35 μg/L 2006 NRWQC HH W+O

Lead, Dissolved 2.5 μg/L 2006 NRWQC FW CCC

Malathion 0.1 μg/L 2006 NRWQC FW and SW CCC

Manganese 50 μg/L 2006 NRWQC HH W+O

Mercury 0.77 μg/L 2006 NRWQC FW CCC

Methoxychlor 0.03 μg/L 2006 NRWQC FW CCC

Methylene chloride 4.6 μg/L 2006 NRWQC HH W+O

Mirex 0.001 μg/L 2006 NRWQC FW and SW CCC

Nickel, Dissolved 8.2 μg/L 2006 NRWQC SW CCC

Nickel, Total 610 μg/L 2006 NRWQC HH W+O

Nitrates 10,000 μg/L 2006 NRWQC HH W+O

Nitrobenzene 17 μg/L 2006 NRWQC HH W+O

Nitrosamines 0.0008 μg/L 2006 NRWQC HH W+O

Nitrosodibutylamine,N 0.0063 μg/L 2006 NRWQC HH W+O

Nitrosodiethylamine,N 0.0008 μg/L 2006 NRWQC HH W+O

Nitrosopyrrolidine,N 0.016 μg/L 2006 NRWQC HH W+O

N-Nitroso Di-n-propylamine 0.005 μg/L 2006 NRWQC HH W+O

N-Nitrosodimethylamine 0.00069 μg/L 2006 NRWQC HH W+O

N-Nitrosodiphenylamine 3.3 μg/L 2006 NRWQC HH W+O

Parathion 0.013 μg/L 2006 NRWQC FW CCC

Pentachlorobenzene 1.4 μg/L 2006 NRWQC HH W+O

Pentachlorophenol 7.9 μg/L 2006 NRWQC SW CCC

Phenol 21,000 μg/L 2006 NRWQC HH W+O

Phorphorus (as phosphate) 0.1 mg/L EPA 1986 Goldbook

Polychlorinated Biphenyls (PCBs) 0.000064 μg/L 2006 NRWQC HH W+O

Pyrene 830 μg/L 2006 NRWQC HH W+O

Selenium, Dissolved 5 μg/L 2006 NRWQC FW CCC

Selenium, Total 170 μg/L 2006 NRWQC HH W+O

Silica Gel Treated HEM (SGT-HEM) 15 mg/L MARPOL 73/78

Silver, Dissolved 1.9 μg/L 2006 NRWQC SW CMC

Solids Dissolved and Salinity 250,000 μg/L 2006 NRWQC HH W+O

Sulfide-Hydrogen Sulfide 0.002 mg/L 2006 NRWQC FW and SW CCC
2013 VGP and sVGP BE Appendix D

D-5

Table D-1. Water Quality and Other Benchmark Values Used to Screen the Vessel 

Discharge Data

Analyte Screening 

Benchmarks Units Sources

Tetrachloroethene 0.69 μg/L 2006 NRWQC HH W+O

Thallium, Total 0.24 μg/L 2006 NRWQC HH W+O

Toluene 1,300 μg/L 2006 NRWQC HH W+O

Total Nonylphenols 1.7 μg/L 2006 NRWQC SW CCC

Total Phosphorus 0.1 mg/L 1986 NRWQC

Total Polychlorinated Biphenyls 0.000064 μg/L 2006 NRWQC HH Org Only

Total Suspended Solids (TSS) 30 mg/L 1984 Secondary Treatment Effluent 

Limits

Total Residual Chlorine (TRC) 0.0075 mg/L 2006 NRWQC SW CCC

Toxaphene 0.0002 μg/L 2006 NRWQC FW and SW CCC

trans-1,2-Dichloroethene 140 μg/L 2006 NRWQC HH W+O

Tributyltin (TBT) 0.0074 μg/L 2006 NRWQC SW CCC

Trichloroethene 2.5 μg/L 2006 NRWQC HH W+O

Vinyl chloride 0.025 μg/L 2006 NRWQC HH W+O

Zinc, Dissolved 81 μg/L 2006 NRWQC SW CCC

Zinc, Total 7400 μg/L 2006 NRWQC HH W+O

Sources:

MARPOL 73/78: International Convention for the Prevention of Pollution From Ships, 1973 as modified by the 

Protocol of 1978 (MARPOL 73/88, 1978).

1976 QCW SH (shellfish harvesting): Note MPN is most probable number and approximates the unit of measure for 

fecal coliform in this study of CFU (colony forming units) (USEPA, 1976).

1984 Secondary Treatment Effluent Limits: 49 FR 37006, Sept. 20, 1984.

1986 NRWQC B FW (bathing (full body contact) recreational waters – fresh water): (USEPA, 1986).

Quality Criteria for Water 1986 (Goldbook) (USEPA, 1986).

2006 NRWQC FW CCC (freshwater chronic): (USEPA, 2006).

2006 NRWQC SW CCC (saltwater chronic) (USEPA, 2006).

2006 NRWQC SW CMC (saltwater acute) (USEPA, 2006).

2006 NRWQC HH Org Only (human health for the consumption of organism only) (USEPA, 2006).

2006 NRWQC HH W+O (human health for the consumption of water + organism) (USEPA, 2006).

References

MARPOL 73/78. 1978. International Convention for the Prevention of Pollution from Ships, 

1973 as modified by the Protocol of 1978. Retrieved from

http://www.imo.org/Conventions/mainframe.asp?topic_id=258&doc_id=678.

“Secondary Treatment” 40 Code of Federal Regulations Part 133.102.

USEPA. 1986. Quality Criteria for Water-1986. “Gold Book.” EPA 440/5-86-001. U.S. 

Environmental Protection Agency. Washington, D.C. (May). Retrieved from

http://www.epa.gov/waterscience/criteria/library/goldbook.pdf.

USEPA. 1976. Quality Criteria for Water. “Red Book.” EPA PB-263-943. U.S. Environmental 

Protection Agency. Washington, DC. Retrieved from 

http://www.epa.gov/waterscience/criteria/library/redbook.pdf.
2013 VGP and sVGP BE Appendix D

D-6

USEPA. 1991. Technical Support Document for Water Quality-Based Toxics Control. EPA 505-

2-90-001. U.S. Environmental Protection Agency. Washington, DC.

USEPA. 2006. National Recommended Water Quality Criteria. U.S. Environmental Protection 

Agency. Washington, DC. 
2013 VGP and sVGP BE Appendix E 

Appendix E. Methodology for Determining the Aquatic and AquaticDependent Species that May Be Affected by the 2013 VGP and sVGP 
2013 VGP and sVGP BE Appendix E 

E-1

 EPA obtained an initial list of over 1,9001 federally-listed aquatic, aquatic-dependent, and 

terrestrial species (including foreign species) from the United States Fish and Wildlife Service’s 

(USFWS) Environmental Conservation Online System (ECOS).2

 From this list, EPA identified a 

subset of aquatic and aquatic-dependent species that have more than limited exposure to “waters 

of the United States” as defined by the following criteria: 

 Species is a fully-aquatic species (e.g., fish); 

 Species is an aquatic-dependent terrestrial species which has an important life-stage 

in aquatic ecosystems (e.g., amphibian); 

 Species is an aquatic-dependent terrestrial species which has a substantial portion of 

its diet directly from the aquatic environment (e.g., shorebird); 

 Species migration pattern includes an aquatic environment; or 

 Species critical habitat includes or is dependent upon an aquatic environment. 

EPA excluded listed species deemed to have only limited exposure to water (i.e., terrestrial 

species which do not have an important life-stage in aquatic systems and/or do not rely on 

aquatic systems for a substantial portion of their diet), from the BE analysis and determined there 

would be no effect on these species. 

 The initial list of aquatic and aquatic-dependent species and their critical habitats was 

originally prepared by EPA to support national 304(a) criteria ESA consultations and the 2008 

VGP BE. EPA identified this list as an appropriate starting point for this BE because the list had 

been subjected to substantial quality control and assurance and because it represented the 

Agency’s most current and comprehensive compilation of aquatic and aquatic-dependent 

species. EPA updated the initial aquatic and aquatic-dependent species list for this BE to reflect 

additional species identified in a listing provided by the National Marine Fisheries Services 

(NMFS) to EPA on March 15, 2012 to support the 2013 VGP and sVGP BE. EPA also revised 

the list of aquatic and aquatic-dependent species to reflect changes in species status and 

designations of critical habitats based on the information available in the ECOS database. Table 

E-1 presents the current list of 612 aquatic and aquatic-dependent species and their critical 

habitats that may be affected by the 2013 VGP and sVGP. The list includes 44 mammals, 44 

birds, 24 reptiles, 27 amphibians, 135 fish, 27 crustaceans, 34 snails, 93 bivalve mollusks (clams 

and abalone), 25 insects, 2 corals, and 157 sea grasses and aquatic and wetland plants. 

 As described in Section 3.2.4, EPA identified ANS and 32 additional pollutants for 

detailed evaluation in the BE. Vessel-related ANS are capable of being transported from the 

original site of discharge to upstream environments through multiple pathways and mechanisms. 

Given the migration potential for ANS once introduced and established (e.g., fish can swim 

upstream), EPA evaluated the full list of 612 aquatic and aquatic-dependent species for potential 

risks from vessel-related ANS in the BE. For the 32 additional pollutants identified for detailed 

evaluation EPA assumes pollutant fate and transport is limited to downstream movement and 

dispersion and narrowed the scope of listed species considered in the BE to only those species 

                                                           

1

 The Environmental Conservation Online System (ECOS) geographical information dataset provided by the 

Services included 1,973 unique species polygon ranges for listed species in the United States and its territories. 2

 For the purpose of this BE, all listed species means all possible status categories: i.e., candidate, endangered, 

experimental, proposed endangered, proposed threatened, recovery, species of concern, and threatened. 
2013 VGP and sVGP BE Appendix E 

E-2

exposed to navigable waters traveled by vessels covered under the VGP and sVGP using the 

methodology described below. In this context, for the purpose of identifying species potentially 

exposed to pollutants in vessel discharges covered under the VGP and sVGP, EPA includes 

downstream waters and nearby tidally-influenced waters within the term navigable waters 

traveled by vessels covered under the VGP and sVGP. This methodology excluded all aquatic 

and aquatic-dependent species located upstream from where vessel discharges are generally 

expected to occur based on the assumption that traditional pollutants (other than ANS) in vessel 

discharge will not migrate upstream and present a potential risk in only the immediate water 

body or downstream waters where vessels discharge. 

 To identify the subset of listed aquatic and aquatic-dependent species potentially 

impacted by pollutants in vessel discharges, EPA conducted a geographical information system 

(GIS) spatial analysis to determine the concurrence of the full list of 612 aquatic and aquaticdependent animal and plant species and their critical habitats to U.S. navigable waterways where 

VGP and sVGP vessels operate (and discharge). EPA identified the U.S. Army Corps of 

Engineers (USACE) National Waterway Network (NWN) GIS data as the best data available to 

represent U.S. navigable waterways where VGP and sVGP operate in the GIS analysis (Figure 

E-1).3

 The NWN data includes representations of shipping lanes in channels, intracoastal 

waterways, sealanes, and rivers, as well as paths in open water where no defined shipping lanes 

are present. In addition, the USACE NWN includes channels for lakes connected to the USACE 

NWN and channels for a select number of lakes that are not directly linked to the USACE NWN. 

Figure E-1 presents the navigable rivers and shipping channels included in the USACE NWN 

used to identify species for inclusion in the BE. 

 Occasionally, small pockets of commercial vessels covered under the VGP and sVGP 

may also operate on lakes and reservoirs not connected to USACE NWN. EPA first identified all 

lakes and reservoirs greater than 0.5 square miles in the National Hydrography Dataset (NHD) 

Plus GIS dataset and performed internet searches to determine the vessel populations likely to 

operate on different size lakes. Based on these searches, EPA determined that vessels covered by 

the VGP rarely operate on lakes smaller than 50 square miles. EPA also found that vessels 

covered under the sVGP are present in limited numbers (i.e., fewer than five vessels) on lakes 

smaller than 50 square miles, and that they operate (and discharge) for only limited periods of 

time. For example, a smaller lake may have a single dinner cruise boat that operates three days a 

week for two hours a day during the summer season. Based these findings, EPA considers that 

the risk posed by covered vessel populations to listed species present in lakes smaller than 50 

square miles to be discountable. EPA identified all lakes and reservoirs greater than 50 square 

miles included in the NHD Plus GIS dataset as an additional waterbody dataset for identifying 

aquatic and aquatic-dependent species potentially impacted by pollutants in vessel discharges. 

Figure E-1 presents the lakes and reservoirs greater than 50 square miles included in NHD Plus 

used in the GIS analysis. 

                                                           

3

 EPA chose to use the USACE NWN navigable waterways data for this effort instead of the NHD Plus streams 

attributed with Strahler order to delineate waters navigable by vessels covered under the VGP and sVGP because it 

is likely that many significant factors such as navigation obstacles (i.e., dams) would be ignored if waters were 

identified based on stream order alone. EPA obtained the NWN data as ESRI Shapefile polylines and point files 

from the U.S. Department of Transportation Bureau of Transportation Statistics National Transportation Atlas (dated 

2011). 
2013 VGP and sVGP BE Appendix E 

E-3

 EPA obtained the species profile GIS data set from the USFWS Environmental 

Conservation Online System (ECOS). The ECOS GIS dataset represents current (as of March, 21 

2012) USFWS field office reports of the spatial extent (by county, quadrangle, or watershed) of 

1,902 listed species for U.S. States, Puerto Rico, and U.S. Territories. EPA compared the list of 

612 species to the ECOS GIS dataset to determine the spatial range in GIS for all species that 

may be affected by the VGP and sVGP. EPA identified 564 matches (by scientific name) 

between the ECOS GIS dataset and the list of 612 aquatic and aquatic-dependent species. EPA 

identified 48 additional aquatic and aquatic-dependent species for further research that were not 

represented in the ECOS GIS dataset.4

 EPA extracted the 564 matching species in the ECOS GIS 

dataset to a separate dataset for further analysis with the USACE NWN data. 

 As the next step of this analysis, EPA overlaid the USACE NWN dataset in Figure E-1 

with the ECOS GIS dataset and spatially selected all species range polygons that intersected with 

a USACE NWN line (i.e., the species range is estimated to coincide with navigable waters). 

From this analysis, EPA determined that 367 species out of the 612 aquatic and aquaticdependent plant and animal species have some spatial concurrence to U.S. waterways navigable 

by vessels covered under the VGP and sVGP as defined by the USACE NWN dataset. EPA then 

overlaid the lakes and reservoirs greater than 50 square miles included in the NHD Plus dataset 

in Figure E-1 with the ECOS GIS dataset and spatially selected all species range polygons that 

intersected with a NHD Plus polygon. From the lakes analysis, EPA identified an additional 49 

species out of the 612 aquatic and aquatic-dependent plant and animal species that have some 

spatial concurrence with the selected lakes and reservoirs. 

Regarding the 48 species that were missing in the ECOS GIS data, EPA individually 

researched the species (by viewing on-line species’ distribution maps5

 and using best 

professional judgment) to determine if they should be included in the list of aquatic and aquaticdependent animal and plant species exposed to U.S. waters navigable by vessels covered by the 

VGP and sVGP. EPA determined that 38 of the 48 species are likely to be exposed to U.S. 

waters navigable by vessels covered by the VGP and sVGP. 

 Based on these analyses, EPA identified a subset of 454 listed aquatic and aquaticdependent species and their critical habitats for risk consideration from exposure to the 32 

additional pollutants in vessel discharges identified for detailed evaluation in the BE. Table E-1 

presents the full list of 612 species and their critical habitats to that may be affected by the 

permits and designates the subset of 454 species and their critical habitats identified as 

potentially exposed to pollutants from vessel discharges covered under the VGP and sVGP. EPA 

evaluated all aquatic and aquatic-dependent species and their critical habitats in the United States 

and its territories. To illustrate the methodology, Figures E-2 and E-3 present examples of the 

geographic overlap among certain aquatic and aquatic-dependent taxa and the USACE NWN 

dataset and lakes from the NHD Plus dataset. 

                                                           

4

 Some of the missing species were added explicitly at the request of researchers at the NMFS. 5

 Generally available either in ECOS, NatureServe, or NOAA Fisheries, Office of Protected Resources, Species 

Under the ESA website, at: http://www.nmfs.noaa.gov/pr/species/esa/. 
2013 VGP and sVGP BE 

E-4

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Abalone, black Haliotis cracherodii Saltwater Bivalve Mollusk E Abalone, white Haliotis sorenseni Saltwater Bivalve Mollusk E Acornshell, southern Epioblasma othcaloogensis Unionid Mussel E 17.95(f) Albatross, short-tailed Phoebastria (=Diomedea) albatrus Coastal/Marine Bird E Alligator, American Alligator mississippiensis Snakes and Other Reptiles T(S/A) Ambersnail, Kanab Oxyloma haydeni kanabensis Unionid Mussel E Amphipod, diminutive Gammarus hyalleloides 

Freshwater Shrimp/ Crustacean 

C 

Amphipod, Hay's Spring Stygobromus hayi 

Freshwater Shrimp/ Crustacean 

E 

Amphipod, Illinois cave Gammarus acherondytes 

Freshwater Shrimp/ Crustacean 

E 

Amphipod, Kauai cave Spelaeorchestia koloana 

Freshwater Shrimp/ Crustacean 

E 17.95(h) 

Amphipod, Noel's Gammarus desperatus 

Freshwater Shrimp/ Crustacean 

E 17.95(h) 

Amphipod, Peck's cave Stygobromus (=Stygonectes) pecki Freshwater Shrimp/ Crustacean E 17.95(h) 
2013 VGP and sVGP BE 

E-5

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Arrowhead, bunched Sagittaria fasciculata 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Asphodel, bog Narthecium americanum 

FreshwaterSaltwater Aquatic and Wetland Plants 

C 

Aster, decurrent false Boltonia decurrens 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Atlantic sturgeon (Gulf of Maine) Acipenser oxyrinchus oxyrichus Anadromous Sturgeon T Bankclimber, purple (mussel) Elliptoideus sloatianus Unionid Mussel T 17.95(f) Bat, gray Myotis grisescens Terrestrial Mammal E Bat, Hawaiian hoary Lasiurus cinereus semotus Terrestrial Mammal E Bat, Indiana Myotis sodalis Terrestrial Mammal E 17.95(a) Bat, Ozark big-eared Corynorhinus (=Plecotus) townsendii ingens Terrestrial Mammal E Bat, Virginia big-eared Corynorhinus (=Plecotus) townsendii virginianus Terrestrial Mammal E 17.95(a) Beaked-rush, Knieskern's Rhynchospora knieskernii 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 
2013 VGP and sVGP BE 

E-6

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Bean, Choctaw Villosa choctawensis Unionid Mussel PE Bean, Cumberland (pearlymussel) Villosa trabalis Unionid Mussel E;XN Bean, purple Villosa perpurpurea Unionid Mussel E 17.95(f) Bean, rayed Villosa fabalis Unionid Mussel E Bear, American black Ursus americanus Terrestrial Mammal T(S/A) Bear, grizzly Ursus arctos horribilis Terrestrial Mammal T;XN Bear, Louisiana black Ursus americanus luteolus Terrestrial Mammal T 17.95(a) Bear, polar Ursus maritimus Terrestrial Mammal T 17.95(a) Bearded seal (Beringia) Erignathus barbatus nauticus Marine Mammal PT Beardtongue, Penland Penstemon penlandii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Beauty, Harper's Harperocallis flava 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Beetle, Comal Springs dryopid Stygoparnus comalensis 

Beetle and Aquatic Insect E 17.95(i) 

Beetle, Comal Springs riffle Heterelmis comalensis 

Beetle and Aquatic Insect E 17.95(i) 
2013 VGP and sVGP BE 

E-7

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Beetle, delta green ground Elaphrus viridis Beetle and Aquatic Insect T 17.95(i) Beetle, Hungerford's crawling water Brychius hungerfordi Beetle and Aquatic Insect E Beetle, valley elderberry longhorn 

Desmocerus californicus dimorphus 

Beetle and Aquatic Insect T 17.95(i)  

Bellflower, Brooksville Campanula robinsiae 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Bird's-beak, salt marsh Cordylanthus maritimus ssp. maritimus 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Bird's-beak, soft Cordylanthus mollis ssp. mollis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Birds-in-a-nest, white Macbridea alba 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Bittercress, small-anthered Cardamine micranthera 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Blazingstar, Ash Meadows Mentzelia leucophylla 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 17.96(a) 
2013 VGP and sVGP BE 

E-8

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Blossom, green (pearlymussel) 

Epioblasma torulosa gubernaculum Unionid Mussel E 

Blossom, tubercled (pearlymussel) Epioblasma torulosa torulosa Unionid Mussel E;XN Blossom, turgid (pearlymussel) Epioblasma turgidula Unionid Mussel E;XN Blossom, yellow (pearlymussel) Epioblasma florentina florentina Unionid Mussel E;XN Bluecurls, Hidden Lake Trichostema austromontanum ssp. compactum 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Bobwhite, masked (quail) Colinus virginianus ridgwayi Coastal/Marine Bird E Bocaccio Sebastes paucispinis Estuarine/Marine Fish E Brodiaea, Chinese Camp Brodiaea pallida 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Brodiaea, thread-leaved Brodiaea filifolia 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 17.96(a) 

Bulrush, Northeastern Scirpus ancistrochaetus 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 
2013 VGP and sVGP BE 

E-9

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Buttercup, autumn Ranunculus aestivalis (=acriformis) 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Butterfly plant, Colorado Gaura neomexicana var. coloradensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 17.96(a) 

Butterfly, lotis blue Lycaeides argyrognomon lotis Beetle and Aquatic Insect E Butterfly, Mitchell's satyr Neonympha mitchellii mitchellii Beetle and Aquatic Insect E Butterfly, Saint Francis' satyr Neonympha mitchellii francisci Beetle and Aquatic Insect E Butterwort, Godfrey's Pinguicula ionantha 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Button, Mohr's Barbara Marshallia mohrii 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Button-celery, San Diego Eryngium aristulatum var. parishii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Caddisfly, Sequatchie Glyphopsyche sequatchie 

Beetle and Aquatic Insect C 
2013 VGP and sVGP BE 

E-10

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Calistoga Allocarya Plagiobothrys strictus 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Campeloma, slender Campeloma decampi Unionid Mussel E Caracara, Audubon's crested Polyborus plancus audubonii Coastal/Marine Bird T Catfish, Yaqui Ictalurus pricei Freshwater Fish/ Inland Salmonid T 17.95(e) Catspaw (=purple cat's paw pearlymussel) Epioblasma obliquata obliquata Unionid Mussel E;XN Catspaw, white (pearlymussel) 

Epioblasma obliquata perobliqua Unionid Mussel E 

Cavefish, Alabama Speoplatyrhinus poulsoni Freshwater Fish/ Inland Salmonid E 17.95(e) Cavefish, Ozark Amblyopsis rosae Freshwater Fish/ Inland Salmonid T Cavesnail, Tumbling Creek Antrobia culveri Unionid Mussel E 17.95(f) Centaury, spring-loving Centaurium namophilum 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 17.96(a) 

Chaffseed, American Schwalbea americana 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 
2013 VGP and sVGP BE 

E-11

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Checker-mallow, Kenwood Marsh Sidalcea oregana ssp. valida 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Checker-mallow, Nelson's Sidalcea nelsoniana 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Checker-mallow, pedate Sidalcea pedata 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Checkermallow, Wenatchee Mountains Sidalcea oregana var. calva 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a)  

Chub, bonytail Gila elegans Freshwater Fish/ Inland Salmonid E 17.95(e) Chub, Borax Lake Gila boraxobius Freshwater Fish/ Inland Salmonid E 17.95(e) Chub, Chihuahua Gila nigrescens Freshwater Fish/ Inland Salmonid T Chub, Gila Gila intermedia Freshwater Fish/ Inland Salmonid E 17.95(e) Chub, headwater Gila nigra Freshwater Fish/ Inland Salmonid C Chub, humpback Gila cypha Freshwater Fish/ Inland Salmonid E 17.95(e) Chub, Hutton tui Gila bicolor ssp. Freshwater Fish/ Inland Salmonid T 
2013 VGP and sVGP BE 

E-12

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Chub, Mohave tui Gila bicolor mohavensis Freshwater Fish/ Inland Salmonid E Chub, Oregon Oregonichthys crameri Freshwater Fish/ Inland Salmonid T 17.95(e) Chub, Owens tui Gila bicolor snyderi Freshwater Fish/ Inland Salmonid E 17.95(e) Chub, Pahranagat roundtail Gila robusta jordani Freshwater Fish/ Inland Salmonid E Chub, slender Erimystax cahni Freshwater Fish/ Inland Salmonid T;XN 17.95(e) Chub, Sonora Gila ditaenia Freshwater Fish/ Inland Salmonid T 17.95(e) Chub, spotfin Erimonax monachus Freshwater Fish/ Inland Salmonid T;XN 17.95(e) Chub, Virgin River Gila seminuda (=robusta) Freshwater Fish/ Inland Salmonid E 17.95(e) Chub, Yaqui Gila purpurea Freshwater Fish/ Inland Salmonid E 17.95(e) Cinquefoil, Soldier Meadows Potentilla basaltica 

FreshwaterSaltwater Aquatic and Wetland Plants 

C 

Clover, showy Indian Trifolium amoenum 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Clubshell Pleurobema clava Unionid Mussel E;XN Clubshell, black Pleurobema curtum Unionid Mussel E 
2013 VGP and sVGP BE 

E-13

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Clubshell, ovate Pleurobema perovatum Unionid Mussel E 17.95(f) Clubshell, southern Pleurobema decisum Unionid Mussel E 17.95(f) Cobana negra Stahlia monosperma 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Combshell, Cumberlandian Epioblasma brevidens Unionid Mussel E;XN 17.95(f) Combshell, southern Epioblasma penita Unionid Mussel E Combshell, upland Epioblasma metastriata Unionid Mussel E 17.95(f) Coot, Hawaiian Fulica americana alai Coastal/Marine Bird E Coral, elkhorn Acropora palmata Saltwater Corals T 17.95(j) Coral, staghorn Acropora cervicornis Saltwater Corals T 17.95(j) Crake, spotless Porzana tabuensis Coastal/Marine Bird C Crane, Mississippi sandhill Grus canadensis pulla Coastal/Marine Bird E 17.95(b) Crane, whooping Grus americana Coastal/Marine Bird E;XN 17.95(b) Crayfish, cave Cambarus aculabrum 

Freshwater Shrimp/ Crustacean 

E 

Crayfish, cave Cambarus zophonastes 

Freshwater Shrimp/ Crustacean 

E  
2013 VGP and sVGP BE 

E-14

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Crayfish, Nashville Orconectes shoupi 

Freshwater Shrimp/ Crustacean 

E 

Crayfish, Shasta Pacifastacus fortis 

Freshwater Shrimp/ Crustacean 

E 

Cress, Tahoe yellow Rorippa subumbellata 

FreshwaterSaltwater Aquatic and Wetland Plants 

C 

Crocodile, American Crocodylus acutus Snakes and Other Reptiles E;T 17.95( c) Crow, Mariana (=aga) Corvus kubaryi Coastal/Marine Bird E 17.95(b)  Crownscale, San Jacinto Valley Atriplex coronata var. notatior 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Cuckoo, yellow-billed Coccyzus americanus Coastal/Marine Bird C Cui-ui Chasmistes cujus Freshwater Fish/ Inland Salmonid E Curlew, Eskimo Numenius borealis Coastal/Marine Bird E Dace, Ash Meadows speckled Rhinichthys osculus nevadensis Freshwater Fish/ Inland Salmonid E 17.95(e) Dace, blackside Phoxinus cumberlandensis Freshwater Fish/ Inland Salmonid T  Dace, Clover Valley speckled Rhinichthys osculus oligoporus Freshwater Fish/ Inland Salmonid E 
2013 VGP and sVGP BE 

E-15

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Dace, desert Eremichthys acros Freshwater Fish/ Inland Salmonid T 17.95(e) Dace, Foskett speckled Rhinichthys osculus ssp. Freshwater Fish/ Inland Salmonid T Dace, Independence Valley speckled Rhinichthys osculus lethoporus Freshwater Fish/ Inland Salmonid E Dace, Kendall Warm Springs Rhinichthys osculus thermalis Freshwater Fish/ Inland Salmonid E Dace, Laurel Phoxinus saylori Freshwater Fish/ Inland Salmonid E Dace, Moapa Moapa coriacea Freshwater Fish/ Inland Salmonid E Daisy, Willamette Erigeron decumbens var. decumbens 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Damselfly, blackline Hawaiian 

Megalagrion nigrohamatum nigrolineatum 

Beetle and Aquatic Insect PE 

Damselfly, crimson Hawaiian Megalagrion leptodemus 

Beetle and Aquatic Insect PE 

Damselfly, flying earwig Hawaiian Megalagrion nesiotes 

Beetle and Aquatic Insect E 

Damselfly, oceanic Hawaiian Megalagrion oceanicum 

Beetle and Aquatic Insect PE 

Damselfly, orangeblack Hawaiian Megalagrion xanthomelas 

Beetle and Aquatic Insect C 
2013 VGP and sVGP BE 

E-16

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Damselfly, Pacific Hawaiian Megalagrion pacificum 

Beetle and Aquatic Insect E 

Darter, amber Percina antesella Freshwater Fish/ Inland Salmonid E 17.95(e) Darter, Arkansas Etheostoma cragini Freshwater Fish/ Inland Salmonid C Darter, bayou Etheostoma rubrum Freshwater Fish/ Inland Salmonid T  Darter, bluemask (=jewel) Etheostoma sp. Freshwater Fish/ Inland Salmonid E Darter, boulder Etheostoma wapiti Freshwater Fish/ Inland Salmonid E;XN  Darter, Cherokee Etheostoma scotti Freshwater Fish/ Inland Salmonid T Darter, Cumberland Etheostoma susanae Freshwater Fish/ Inland Salmonid E  Darter, duskytail Etheostoma percnurum Freshwater Fish/ Inland Salmonid E;XN  Darter, Etowah Etheostoma etowahae Freshwater Fish/ Inland Salmonid E Darter, fountain Etheostoma fonticola Freshwater Fish/ Inland Salmonid E 17.95(e) Darter, goldline Percina aurolineata Freshwater Fish/ Inland Salmonid T Darter, leopard Percina pantherina Freshwater Fish/ Inland Salmonid T 17.95(e) Darter, Maryland Etheostoma sellare Freshwater Fish/ Inland Salmonid E 17.95(e) Darter, Niangua Etheostoma nianguae Freshwater Fish/ Inland Salmonid T 17.95(e)  
2013 VGP and sVGP BE 

E-17

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Darter, Okaloosa Etheostoma okaloosae Freshwater Fish/ Inland Salmonid T Darter, Pearl Percina aurora Freshwater Fish/ Inland Salmonid C Darter, relict Etheostoma chienense Freshwater Fish/ Inland Salmonid E Darter, rush Etheostoma phytophilum Freshwater Fish/ Inland Salmonid E Darter, slackwater Etheostoma boschungi Freshwater Fish/ Inland Salmonid T 17.95(e) Darter, snail Percina tanasi Freshwater Fish/ Inland Salmonid T 17.95(e) Darter, vermilion Etheostoma chermocki Freshwater Fish/ Inland Salmonid E 17.95(e) Darter, watercress Etheostoma nuchale Freshwater Fish/ Inland Salmonid E Darter, yellowcheek Etheostoma moorei Freshwater Fish/ Inland Salmonid E  Desert-parsley, Bradshaw's Lomatium bradshawii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Dragonfly, Hine's emerald Somatochlora hineana 

Beetle and Aquatic Insect E 17.95(i) 

Dropwort, Canby's Oxypolis canbyi 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Duck, Hawaiian (=koloa) Anas wyvilliana Coastal/Marine Bird E 
2013 VGP and sVGP BE 

E-18

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Duck, Laysan Anas laysanensis Coastal/Marine Bird E Ebonyshell, round Fusconaia rotulata Unionid Mussel PE Eider, spectacled Somateria fischeri Coastal/Marine Bird T 17.95(b) Eider, Steller's Polysticta stelleri Coastal/Marine Bird T 17.95(b) Elepaio, Oahu Chasiempis sandwichensis ibidis Coastal/Marine Bird E 17.95(b) Elimia, lacy (snail) Elimia crenatella Unionid Mussel T Elktoe, Appalachian Alasmidonta raveneliana Unionid Mussel E 17.95(f) Elktoe, Cumberland Alasmidonta atropurpurea Unionid Mussel E 17.95(f)  Eulachon, Pacific Thaleichthys pacificus Estuarine/Marine Fish T Fairy shrimp, Conservancy Branchinecta conservatio 

Freshwater Shrimp/ Crustacean 

E 17.95(h) 

Fairy shrimp, longhorn Branchinecta longiantenna 

Freshwater Shrimp/ Crustacean 

E 17.95(h) 

Fairy shrimp, Riverside Streptocephalus woottoni 

Freshwater Shrimp/ Crustacean 

E 17.95(h) 

Fairy shrimp, San Diego Branchinecta sandiegonensis 

Freshwater Shrimp/ Crustacean 

E 17.95(h) 
2013 VGP and sVGP BE 

E-19

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Fairy shrimp, vernal pool Branchinecta lynchi 

Freshwater Shrimp/ Crustacean 

T 17.95(h) 

False killer whale (Hawaii Insular) Pseudorca crassidens Marine Mammal PE Fanshell Cyprogenia stegaria Unionid Mussel E;XN Fatmucket, Arkansas Lampsilis powelli Unionid Mussel T Flycatcher, southwestern willow Empidonax traillii extimus Coastal/Marine Bird E 17.95(b) Frog, California red-legged Rana aurora draytonii Amphibian T 17.95(d) Frog, Chiricahua leopard Rana chiricahuensis Amphibian T 17.95(d) Frog, Columbia spotted Rana luteiventris Amphibian C  Frog, mountain yellowlegged Rana muscosa Amphibian E;C 17.95(d) Frog, Oregon spotted Rana pretiosa Amphibian C Frog, relict leopard Rana onca Amphibian C Gambusia, Big Bend Gambusia gaigei Freshwater Fish/ Inland Salmonid E Gambusia, Clear Creek Gambusia heterochir Freshwater Fish/ Inland Salmonid E Gambusia, Pecos Gambusia nobilis Freshwater Fish/ Inland Salmonid E Gambusia, San Marcos Gambusia georgei Freshwater Fish/ Inland Salmonid E 17.95(e) 
2013 VGP and sVGP BE 

E-20

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Gilia, Monterey Gilia tenuiflora ssp. arenaria 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Gnatcatcher, coastal California 

Polioptila californica californica 

Coastal/Marine Bird T 17.95(b) 

Goby, tidewater Eucyclogobius newberryi Estuarine/Marine Fish E 17.95(e) Goldenrod, Houghton's Solidago houghtonii 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Goldenrod, Yadkin River Solidago plumosa 

FreshwaterSaltwater Aquatic and Wetland Plants 

C 

Goldfields, Burke's Lasthenia burkei 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Goldfields, Contra Costa Lasthenia conjugens 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Grass, Colusa Neostapfia colusana 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 17.96(a) 
2013 VGP and sVGP BE 

E-21

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Grass, Tennessee yelloweyed Xyris tennesseensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Grouse, greater sage Centrocercus urophasianus Coastal/Marine Bird C Guajon Eleutherodactylus cooki Amphibian T 17.95(d)  Gumplant, Ash Meadows Grindelia fraxino-pratensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 17.96(a) 

Haha Cyanea grimesiana ssp. grimesiana 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Harperella Ptilimnium nodosum 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Hawk, Puerto Rican broadwinged Buteo platypterus brunnescens Coastal/Marine Bird E Heartleaf, dwarf-flowered Hexastylis naniflora 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Heau Exocarpos luteolus 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 
2013 VGP and sVGP BE 

E-22

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Heelsplitter, Alabama (=inflated) Potamilus inflatus Unionid Mussel T Heelsplitter, Carolina Lasmigona decorata Unionid Mussel E 17.95(f) Hellbender, Ozark Cryptobranchus alleganiensis bishopi Amphibian E Higgins eye (pearlymussel) Lampsilis higginsii Unionid Mussel E Higuero de sierra Crescentia portoricensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Hornshell, Texas Popenaias popei Unionid Mussel C Hornsnail, rough Pleurocera foremani Unionid Mussel E 17.95(f) Howellia, water Howellia aquatilis 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Ihi`ihi Marsilea villosa 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Isopod, Lee County cave Lirceus usdagalun 

Freshwater Shrimp/ Crustacean 

E 

Isopod, Madison Cave Antrolana lira 

Freshwater Shrimp/ Crustacean 

T 
2013 VGP and sVGP BE 

E-23

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Isopod, Socorro Thermosphaeroma thermophilus 

Freshwater Shrimp/ Crustacean 

E 

Ivesia, Ash Meadows Ivesia kingii var. eremica 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 17.96(a) 

Jaguarundi, Gulf Coast Herpailurus (=Felis) yagouaroundi cacomitli Terrestrial Mammal E Jaguarundi, Sinaloan Herpailurus (=Felis) yagouaroundi tolteca Terrestrial Mammal E Joint-vetch, sensitive Aeschynomene virginica 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Kampua`a Hedyotis fluviatilis 

FreshwaterSaltwater Aquatic and Wetland Plants 

C 

Kidneyshell, fluted Ptychobranchus subtentum Unionid Mussel C Kidneyshell, southern Ptychobranchus jonesi Unionid Mussel PE Kidneyshell, triangular Ptychobranchus greenii Unionid Mussel E 17.95(f) Kite, Everglade snail Rostrhamus sociabilis plumbeus Coastal/Marine Bird E 17.95(b) Knot, red Calidris canutus rufa Coastal/Marine Bird C 
2013 VGP and sVGP BE 

E-24

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Ko`oko`olau Bidens conjuncta 

FreshwaterSaltwater Aquatic and Wetland Plants 

PE 

Kopiko Psychotria grandiflora 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Kuahiwi laukahi Plantago princeps 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Ladies'-tresses, Canelo Hills Spiranthes delitescens 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Ladies'-tresses, Navasota Spiranthes parksii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Ladies'-tresses, Ute Spiranthes diluvialis 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Lampmussel, Alabama Lampsilis virescens Unionid Mussel E;XN Liliwai Acaena exigua 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Lilliput, pale (pearlymussel) Toxolasma cylindrellus Unionid Mussel E 
2013 VGP and sVGP BE 

E-25

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Lily, Pitkin Marsh Lilium pardalinum ssp. pitkinense 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Lily, Western Lilium occidentale 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Limpet, Banbury Springs Lanx sp. Unionid Mussel E Lioplax, cylindrical (snail) Lioplax cyclostomaformis Unionid Mussel E Lizard, blunt-nosed leopard Gambelia silus Snakes and Other Reptiles E Lizard, St. Croix ground Ameiva polops Snakes and Other Reptiles E 17.95(c) Lo`ulu Pritchardia kaalae 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Lo`ulu Pritchardia napaliensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Lo`ulu Pritchardia remota 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Lo`ulu, (=Na`ena`e) Pritchardia hardyi 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 
2013 VGP and sVGP BE 

E-26

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Locoweed, Fassett's Oxytropis campestris var. chartacea 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Logperch, Conasauga Percina jenkinsi Freshwater Fish/ Inland Salmonid E 17.95(e) Logperch, Roanoke Percina rex Freshwater Fish/ Inland Salmonid E Lomatium, Cook's Lomatium cookii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Loosestrife, rough-leaved Lysimachia asperulaefolia 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Madtom, chucky Noturus crypticus Freshwater Fish/ Inland Salmonid E Madtom, Neosho Noturus placidus Freshwater Fish/ Inland Salmonid T Madtom, pygmy Noturus stanauli Freshwater Fish/ Inland Salmonid E;XN Madtom, Scioto Noturus trautmani Freshwater Fish/ Inland Salmonid E Madtom, smoky Noturus baileyi Freshwater Fish/ Inland Salmonid E;XN 17.95(e) Madtom, yellowfin Noturus flavipinnis Freshwater Fish/ Inland Salmonid T;XN 17.95(e) 
2013 VGP and sVGP BE 

E-27

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Makou Ranunculus mauiensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

C 

Manatee, West Indian Trichechus manatus Marine Mammal E 17.95(a) Mapleleaf, winged Quadrula fragosa Unionid Mussel E;XN Marstonia, royal (snail) Pyrgulopsis ogmorhaphe Unionid Mussel E Massasauga (=rattlesnake), eastern Sistrurus catenatus catenatus Snakes and Other Reptiles C Meadowfoam, Butte County Limnanthes floccosa ssp. californica 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a)  

Meadowfoam, largeflowered woolly Limnanthes floccosa ssp. grandiflora 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Meadowrue, Cooley's Thalictrum cooleyi 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Mesa-mint, Otay Pogogyne nudiuscula 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Milk-vetch, Ash meadows Astragalus phoenix 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 17.96(a) 
2013 VGP and sVGP BE 

E-28

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Milk-vetch, coastal dunes Astragalus tener var. titi 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Milk-vetch, Fish Slough Astragalus lentiginosus var. piscinensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 17.96(a) 

Minnow, Devils River Dionda diaboli Freshwater Fish/ Inland Salmonid T 17.95(e) Minnow, loach Tiaroga cobitis Freshwater Fish/ Inland Salmonid E 17.95(e) Minnow, Rio Grande silvery Hybognathus amarus Freshwater Fish/ Inland Salmonid E 17.95(e) Moccasinshell, Alabama Medionidus acutissimus Unionid Mussel T 17.95(f) Moccasinshell, Coosa Medionidus parvulus Unionid Mussel E 17.95(f) Moccasinshell, Gulf Medionidus penicillatus Unionid Mussel E 17.95(f) Moccasinshell, Ochlockonee Medionidus simpsonianus Unionid Mussel E 17.95(f) Monkeyface, Appalachian (pearlymussel) Quadrula sparsa Unionid Mussel E;XN Monkeyface, Cumberland (pearlymussel) Quadrula intermedia Unionid Mussel E;XN Monkey-flower, Michigan Mimulus glabratus var. michiganensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 
2013 VGP and sVGP BE 

E-29

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Monkshood, northern wild Aconitum noveboracense 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Moorhen, Hawaiian common 

Gallinula chloropus sandvicensis 

Coastal/Marine Bird E 

Moorhen, Mariana common Gallinula chloropus guami Coastal/Marine Bird E  Mouse, Anastasia Island beach Peromyscus polionotus phasma Terrestrial Mammal E Mouse, Pacific pocket Perognathus longimembris pacificus Terrestrial Mammal E Mouse, salt marsh harvest Reithrodontomys raviventris Terrestrial Mammal E Mouse, southeastern beach Peromyscus polionotus niveiventris Terrestrial Mammal T Mucket, Neosho Lampsilis rafinesqueana Unionid Mussel C Mucket, orangenacre Lampsilis perovalis Unionid Mussel T 17.95(f) Mucket, pink (pearlymussel) Lampsilis abrupta Unionid Mussel E Mudalia, black Elimia melanoides Unionid Mussel C Murrelet, Kittlitz's Brachyramphus brevirostris Coastal/Marine Bird C Murrelet, marbled Brachyramphus marmoratus Coastal/Marine Bird T 17.95(b) Murrelet, Xantus's Synthliboramphus hypoleucus Coastal/Marine Bird C Mussel, oyster Epioblasma capsaeformis Unionid Mussel E;XN 17.95(f) 
2013 VGP and sVGP BE 

E-30

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Mussel, scaleshell Leptodea leptodon Unionid Mussel E Mussel, sheepnose Plethobasus cyphyus Unionid Mussel E Mussel, snuffbox Epioblasma triquetra Unionid Mussel E Mustard, Penland alpine fen Eutrema penlandii 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Nani wai`ale`ale Viola kauaiensis var. wahiawaensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Napa Bluegrass Poa napensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Naucorid bug (=Furnace Creek), Nevares Spring Ambrysus funebris 

Beetle and Aquatic Insect C 

Naucorid, Ash Meadows Ambrysus amargosus 

Beetle and Aquatic Insect T 17.95(i) 

Navarretia, few-flowered Navarretia leucocephala ssp. pauciflora (=N. pauciflora) 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Navarretia, many-flowered Navarretia leucocephala ssp. plieantha 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 
2013 VGP and sVGP BE 

E-31

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Navarretia, spreading Navarretia fossalis 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 17.96(a) 

Niterwort, Amargosa Nitrophila mohavensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

No common name Cordia bellonis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

No common name Gesneria pauciflora 

FreshwaterSaltwater Aquatic and Wetland Plants 

T  

No common name Lysimachia filifolia 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

No common name Nesogenes rotensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

No common name Platanthera holochila 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 
2013 VGP and sVGP BE 

E-32

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

No common name Pteris lidgatei 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

No common name Sanicula purpurea 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

No common name Viola helenae 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Nohoanu Geranium multiflorum 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Ocelot Leopardus (=Felis) pardalis Terrestrial Mammal E `Oha wai Clermontia oblongifolia ssp. mauiensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Orchid, eastern prairie fringed Platanthera leucophaea 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Orchid, white fringeless Platanthera integrilabia 

FreshwaterSaltwater Aquatic and Wetland Plants 

C 
2013 VGP and sVGP BE 

E-33

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Orcutt grass, California Orcuttia californica 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Orcutt grass, hairy Orcuttia pilosa 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Orcutt grass, Sacramento Orcuttia viscida 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Orcutt grass, San Joaquin Orcuttia inaequalis 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 17.96(a) 

Orcutt grass, slender Orcuttia tenuis 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 17.96(a)  

Otter, Northern sea Enhydra lutris kenyoni Marine Mammal T 17.95(a) Otter, Southern sea Enhydra lutris nereis Marine Mammal T;XN Owl's-clover, fleshy Castilleja campestris ssp. succulenta 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 17.96(a) 

Palmate-bracted Bird's Beak Cordylanthus palmatus 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 
2013 VGP and sVGP BE 

E-34

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Pamakani Viola chamissoniana ssp. chamissoniana 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Panic grass, Hirsts' Dichanthelium (=Panicum) hirstii 

FreshwaterSaltwater Aquatic and Wetland Plants 

C 

Panther, Florida Puma (=Felis) concolor coryi Terrestrial Mammal E Pawpaw, beautiful Deeringothamnus pulchellus 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Pawpaw, Rugel's Deeringothamnus rugelii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Pearlshell, Alabama Margaritifera marrianae Unionid Mussel PE Pearlshell, Louisiana Margaritifera hembeli Unionid Mussel T  Pearlymussel, birdwing Conradilla caelata Unionid Mussel E;XN Pearlymussel, cracking Hemistena lata Unionid Mussel E;XN Pearlymussel, Curtis Epioblasma florentina curtisii Unionid Mussel E Pearlymussel, dromedary Dromus dromas Unionid Mussel E;XN Pearlymussel, littlewing Pegias fabula Unionid Mussel E 
2013 VGP and sVGP BE 

E-35

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Pearlymussel, slabside Lexingtonia dolabelloides Unionid Mussel C Pebblesnail, flat Lepyrium showalteri Unionid Mussel E Petrel, Hawaiian darkrumped Pterodroma phaeopygia sandwichensis Coastal/Marine Bird E Pigtoe, Cumberland Pleurobema gibberum Unionid Mussel E Pigtoe, dark Pleurobema furvum Unionid Mussel E 17.95(f) Pigtoe, finerayed Fusconaia cuneolus Unionid Mussel E;XN Pigtoe, flat Pleurobema marshalli Unionid Mussel E Pigtoe, fuzzy Pleurobema strodeanum Unionid Mussel PT Pigtoe, Georgia Pleurobema hanleyianum Unionid Mussel E 17.95(f) Pigtoe, heavy Pleurobema taitianum Unionid Mussel E Pigtoe, narrow Fusconaia escambia Unionid Mussel PT Pigtoe, oval Pleurobema pyriforme Unionid Mussel E 17.95(f) Pigtoe, rough Pleurobema plenum Unionid Mussel E;XN Pigtoe, shiny Fusconaia cor Unionid Mussel E;XN Pigtoe, southern Pleurobema georgianum Unionid Mussel E 17.95(f) Pigtoe, tapered Quincuncina burkei Unionid Mussel PT 
2013 VGP and sVGP BE 

E-36

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Pikeminnow (=squawfish), Colorado Ptychocheilus lucius Freshwater Fish/ Inland Salmonid E;XN 17.95(e) Pimpleback, orangefoot (pearlymussel) Plethobasus cooperianus Unionid Mussel E;XN Pink, swamp Helonias bullata 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Pitcher-plant, Alabama canebrake Sarracenia rubra alabamensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Pitcher-plant, green Sarracenia oreophila 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Pitcher-plant, mountain sweet Sarracenia rubra ssp. jonesii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Plover, piping Charadrius melodus Coastal/Marine Bird E;T 17.95(b) Plover, western snowy Charadrius alexandrinus nivosus Coastal/Marine Bird T 17.95(b) Plymouth Red-Bellied Turtle Pseudemys rubriventris bangsi Snakes and Other Reptiles E 17.95(c) Pocketbook, fat Potamilus capax Unionid Mussel E Pocketbook, finelined Lampsilis altilis Unionid Mussel T 17.95(f) 
2013 VGP and sVGP BE 

E-37

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Pocketbook, Ouachita rock Arkansia wheeleri Unionid Mussel E Pocketbook, shinyrayed Lampsilis subangulata Unionid Mussel E 17.95(f) Pocketbook, speckled Lampsilis streckeri Unionid Mussel E Pondberry Lindera melissifolia 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Pondweed, Little Aguja (=Creek) Potamogeton clystocarpus 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Poolfish, Pahrump Empetrichthys latos Freshwater Fish/ Inland Salmonid E Popcornflower, rough Plagiobothrys hirtus 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Potentilla, Hickman's Potentilla hickmanii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Prickly-apple, fragrant Cereus eriophorus var. fragrans 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Primrose, Maguire Primula maguirei 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 
2013 VGP and sVGP BE 

E-38

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Pseudoscorpion, Tooth Cave Tartarocreagris texana Beetle and Aquatic Insect E Pu`uka`a Cyperus trachysanthos 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Pupfish, Ash Meadows Amargosa 

Cyprinodon nevadensis mionectes 

Freshwater Fish/ Inland Salmonid E 17.95(e) 

Pupfish, Comanche Springs Cyprinodon elegans Freshwater Fish/ Inland Salmonid E Pupfish, desert Cyprinodon macularius Freshwater Fish/ Inland Salmonid E 17.95(e) Pupfish, Devils Hole Cyprinodon diabolis Freshwater Fish/ Inland Salmonid E Pupfish, Leon Springs Cyprinodon bovinus Freshwater Fish/ Inland Salmonid E 17.95(e) Pupfish, Owens Cyprinodon radiosus Freshwater Fish/ Inland Salmonid E Pupfish, Warm Springs Cyprinodon nevadensis pectoralis Freshwater Fish/ Inland Salmonid E Quillwort, black spored Isoetes melanospora 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Quillwort, Louisiana Isoetes louisianensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 
2013 VGP and sVGP BE 

E-39

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Quillwort, mat-forming Isoetes tegetiformans 

FreshwaterSaltwater Aquatic and Wetland Plants 

E  

Rabbitsfoot, rough Quadrula cylindrica strigillata Unionid Mussel E 17.95(f) Rail, California clapper Rallus longirostris obsoletus Coastal/Marine Bird E Rail, light-footed clapper Rallus longirostris levipes Coastal/Marine Bird E Rail, Yuma clapper Rallus longirostris yumanensis Coastal/Marine Bird E Redhorse, Sicklefin Moxostoma sp. Freshwater Fish/ Inland Salmonid C Reedgrass, Maui Calamagrostis expansa 

FreshwaterSaltwater Aquatic and Wetland Plants 

C 

Rhododendron, Chapman Rhododendron chapmanii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Riffle beetle, Stephan's Heterelmis stephani Beetle and Aquatic Insect C Riffleshell, northern Epioblasma torulosa rangiana Unionid Mussel E Riffleshell, tan Epioblasma florentina walkeri (=E. walkeri) Unionid Mussel E Ring pink (mussel) Obovaria retusa Unionid Mussel E;XN Ringed seal (Arctic) Phoca hispida hispida Marine Mammal PT 
2013 VGP and sVGP BE 

E-40

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Riversnail, Anthony's Athearnia anthonyi Unionid Mussel E;XN Rockfish, Canary Sebastes pinniger Estuarine/Marine Fish T Rockfish, Yelloweye Sebastes ruberrimus Estuarine/Marine Fish T Rocksnail, interrupted (=Georgia) Leptoxis foremani Unionid Mussel E 17.95(f) Rocksnail, painted Leptoxis taeniata Unionid Mussel T Rocksnail, plicate Leptoxis plicata Unionid Mussel E Rocksnail, round Leptoxis ampla Unionid Mussel T Rose-mallow, Neches River Hibiscus dasycalyx 

FreshwaterSaltwater Aquatic and Wetland Plants 

C 

Roseroot, Leedy's Sedum integrifolium ssp. leedyi 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Salamander, Austin blind Eurycea waterlooensis Amphibian C Salamander, Barton Springs Eurycea sosorum Amphibian E Salamander, California tiger Ambystoma californiense Amphibian E;T 17.95(d) Salamander, Cheat Mountain Plethodon nettingi Amphibian T Salamander, desert slender Batrachoseps aridus Amphibian E 
2013 VGP and sVGP BE 

E-41

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Salamander, flatwoods Ambystoma cingulatum Amphibian T 17.95(d) Salamander, Georgetown Eurycea naufragia Amphibian C Salamander, Jollyville Plateau Eurycea tonkawae Amphibian C Salamander, Salado Eurycea chisholmensis Amphibian C Salamander, San Marcos Eurycea nana Amphibian T 17.95(d) Salamander, Santa Cruz long-toed 

Ambystoma macrodactylum croceum Amphibian E 

Salamander, Sonora tiger Ambystoma tigrinum stebbinsi Amphibian E Salamander, Texas blind Typhlomolge rathbuni Amphibian E Salmon, Atlantic Salmo salar Anadromous Salmonid E 17.95(e) Salmon, Chinook Oncorhynchus tshawytscha Anadromous Salmonid E;T 

17.95(e), 

226.212, 226.204, 

226.205 

Salmon, chum Oncorhynchus keta Anadromous Salmonid T 17.95(e), 226.212 Salmon, coho Oncorhynchus kisutch Anadromous Salmonid E 17.95(e), 226.210, 226.212 Salmon, sockeye Oncorhynchus nerka Anadromous Salmonid E;T 17.95(e), 226.212, 226.205 sandshell, Southern Hamiota (=Lampsilis) australis Unionid Mussel PE 
2013 VGP and sVGP BE 

E-42

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Sandwort, Marsh Arenaria paludicola 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Sawfish, smalltooth Pristis pectinata Estuarine/Marine Fish E Sculpin, grotto Cottus sp. Freshwater Fish/ Inland Salmonid C  Sculpin, pygmy Cottus paulus (=pygmaeus) Freshwater Fish/ Inland Salmonid T Sea Lion, Steller Eumetopias jubatus Marine Mammal E 226.202 Sea turtle, green Chelonia mydas Sea Turtle E;T 226.208 Sea turtle, hawksbill Eretmochelys imbricata Sea Turtle E 17.95(c), 226.209 Sea turtle, Kemp's ridley Lepidochelys kempii Sea Turtle E Sea turtle, leatherback Dermochelys coriacea Sea Turtle E 17.95(c), 226.207 Sea turtle, loggerhead Caretta caretta Sea Turtle T 
2013 VGP and sVGP BE 

E-43

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Sea turtle, olive ridley Lepidochelys olivacea Sea Turtle E;T Seabeach Amaranth Amaranthus pumilus 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Seablite, California Suaeda californica 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Seagrass, Johnson's Halophila johnsonii Seagrass T 226.213 Seal, Guadalupe fur Arctocephalus townsendi Marine Mammal T Seal, Hawaiian monk Monachus schauinslandi Marine Mammal E 226.201 Seal, spotted Phoca largha Marine Mammal T Sedge, golden Carex lutea 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Sedge, Navajo Carex specuicola 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 17.96(a) 

Shearwater, Newell's Townsend's Puffinus auricularis newelli Coastal/Marine Bird T Shiner, Arkansas River Notropis girardi Freshwater Fish/ Inland Salmonid T 17.95(e) Shiner, beautiful Cyprinella formosa Freshwater Fish/ Inland Salmonid T 17.95(e) 
2013 VGP and sVGP BE 

E-44

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Shiner, blue Cyprinella caerulea Freshwater Fish/ Inland Salmonid T Shiner, Cahaba Notropis cahabae Freshwater Fish/ Inland Salmonid E Shiner, Cape Fear Notropis mekistocholas Freshwater Fish/ Inland Salmonid E 17.95(e) Shiner, palezone Notropis albizonatus Freshwater Fish/ Inland Salmonid E Shiner, Pecos bluntnose Notropis simus pecosensis Freshwater Fish/ Inland Salmonid T 17.95(e) Shiner, sharpnose Notropis oxyrhynchus Freshwater Fish/ Inland Salmonid C Shiner, smalleye Notropis buccula Freshwater Fish/ Inland Salmonid C Shiner, Topeka Notropis topeka (=tristis) Freshwater Fish/ Inland Salmonid E 17.95(e) Shrew, Buena Vista Lake ornate Sorex ornatus relictus Terrestrial Mammal E 17.95(a) Shrimp, Alabama cave Palaemonias alabamae 

Freshwater Shrimp/ Crustacean 

E 

Shrimp, anchialine pool Metabetaeus lohena 

Freshwater Shrimp/ Crustacean 

C 

Shrimp, anchialine pool Palaemonella burnsi 

Freshwater Shrimp/ Crustacean 

C 

Shrimp, anchialine pool Procaris hawaiana 

Freshwater Shrimp/ Crustacean 

C 
2013 VGP and sVGP BE 

E-45

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Shrimp, anchialine pool Vetericaris chaceorum 

Freshwater Shrimp/ Crustacean 

C 

Shrimp, California freshwater Syncaris pacifica 

Freshwater Shrimp/ Crustacean 

E 

Shrimp, Kentucky cave Palaemonias ganteri 

Freshwater Shrimp/ Crustacean 

E 17.95(h) 

Shrimp, Squirrel Chimney Cave Palaemonetes cummingi 

Freshwater Shrimp/ Crustacean 

T 

Silverside, Waccamaw Menidia extensa Freshwater Fish/ Inland Salmonid T 17.95(e) Silversword, Mauna Loa (=Ka'u) Argyroxiphium kauense 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Skipper, Carson wandering Pseudocopaeodes eunus obscurus Beetle and Aquatic Insect E Skipper, Laguna Mountains Pyrgus ruralis lagunae 

Beetle and Aquatic Insect E 17.95(i) 

Skullcap, Florida Scutellaria floridana 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Slabshell, Chipola Elliptio chipolaensis Unionid Mussel T 17.95(f) 
2013 VGP and sVGP BE 

E-46

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Smelt, delta Hypomesus transpacificus Estuarine/Marine Fish T 17.95(e) Snail, armored Pyrgulopsis (=Marstonia) pachyta Unionid Mussel E Snail, Bliss Rapids Taylorconcha serpenticola Unionid Mussel T Snail, Chittenango ovate amber Succinea chittenangoensis Unionid Mussel T Snail, Diamond Y Spring Pseudotryonia (=Tryonia) adamantina Unionid Mussel C Snail, Newcomb's Erinna newcombi Unionid Mussel T 17.95(f) Snail, Pecos assiminea Assiminea pecos Unionid Mussel E 17.95(f) Snail, Phantom Cave Cochliopa texana Unionid Mussel C Snail, Snake River physa Physa natricina Unionid Mussel E Snail, tulotoma Tulotoma magnifica Unionid Mussel T Snake, Atlantic salt marsh Nerodia clarkii taeniata Snakes and Other Reptiles T Snake, copperbelly water Nerodia erythrogaster neglecta Snakes and Other Reptiles T Snake, eastern indigo Drymarchon corais couperi Snakes and Other Reptiles T Snake, giant garter Thamnophis gigas Snakes and Other Reptiles T Snake, San Francisco garter Thamnophis sirtalis tetrataenia Snakes and Other Reptiles E 
2013 VGP and sVGP BE 

E-47

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Sneezeweed, Virginia Helenium virginicum 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Solano Grass Tuctoria mucronata 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Sonoma Alopecurus Alopecurus aequalis var. sonomensis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Sparrow, Cape Sable seaside Ammodramus maritimus mirabilis Coastal/Marine Bird E 17.95(b) Spectaclecase Cumberlandia monodonta Unionid Mussel E Spikedace Meda fulgida Freshwater Fish/ Inland Salmonid E 17.95(e) Spinedace, Big Spring Lepidomeda mollispinis pratensis Freshwater Fish/ Inland Salmonid T 17.95(e) Spinedace, Little Colorado Lepidomeda vittata Freshwater Fish/ Inland Salmonid T 17.95(e) Spinedace, White River Lepidomeda albivallis Freshwater Fish/ Inland Salmonid E 17.95(e) Spinymussel, Altamaha Elliptio spinosa Unionid Mussel E 17.95(f) Spinymussel, James Pleurobema collina Unionid Mussel E Spinymussel, Tar River Elliptio steinstansana Unionid Mussel E 
2013 VGP and sVGP BE 

E-48

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Spiraea, Virginia Spiraea virginiana 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Springfish, Hiko White River Crenichthys baileyi grandis Freshwater Fish/ Inland Salmonid E 17.95(e) Springfish, Railroad Valley Crenichthys nevadae Freshwater Fish/ Inland Salmonid T 17.95(e) Springfish, White River Crenichthys baileyi baileyi Freshwater Fish/ Inland Salmonid E 17.95(e) Springsnail (=Tryonia), Phantom Tryonia cheatumi Unionid Mussel C Springsnail, Alamosa Tryonia alamosae Unionid Mussel E Springsnail, Bruneau Hot Pyrgulopsis bruneauensis Unionid Mussel E Springsnail, Chupadera Pyrgulopsis chupaderae Unionid Mussel PE Springsnail, elongate mud meadows Pyrgulopsis notidicola Unionid Mussel C Springsnail, Gonzales Tryonia circumstriata(=stocktonensis) Unionid Mussel C Springsnail, Huachuca Pyrgulopsis thompsoni Unionid Mussel C Springsnail, Koster's Juturnia kosteri Unionid Mussel E 17.95(f) Springsnail, Page Pyrgulopsis morrisoni Unionid Mussel C Springsnail, Roswell Pyrgulopsis roswellensis Unionid Mussel E 17.95(f) Springsnail, San Bernadino Pyrgulopsis bernardina Unionid Mussel E 17.95(f) 
2013 VGP and sVGP BE 

E-49

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Springsnail, Socorro Pyrgulopsis neomexicana Unionid Mussel E Springsnail, Three Forks Pyrgulopsis trivialis Unionid Mussel E 17.95(f) Spurge, Hoover's Chamaesyce hooveri 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 17.96(a) 

Stickleback, unarmored threespine 

Gasterosteus aculeatus williamsoni 

Freshwater Fish/ Inland Salmonid E 

Stilt, Hawaiian Himantopus mexicanus knudseni Coastal/Marine Bird E Stirrupshell Quadrula stapes Unionid Mussel E Stonecrop, Lake County Parvisedum leiocarpum 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Stork, wood Mycteria americana Coastal/Marine Bird E Storm-petrel, band-rumped Oceanodroma castro Coastal/Marine Bird C Sturgeon, Alabama Scaphirhynchus suttkusi Anadromous Sturgeon E 17.95(e) Sturgeon, green Acipenser medirostris Anadromous Sturgeon T Sturgeon, gulf Acipenser oxyrinchus desotoi Anadromous Sturgeon T 17.95(e) Sturgeon, pallid Scaphirhynchus albus 

Freshwater Fish/Inland Sturgeon 

E 
2013 VGP and sVGP BE 

E-50

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Sturgeon, shortnose Acipenser brevirostrum Anadromous Sturgeon E Sturgeon, white Acipenser transmontanus Anadromous Sturgeon E 17.95(e) Sucker, June Chasmistes liorus Freshwater Fish/ Inland Salmonid E 17.95(e) Sucker, Lost River Deltistes luxatus Freshwater Fish/ Inland Salmonid E Sucker, Modoc Catostomus microps Freshwater Fish/ Inland Salmonid E 17.95(e) Sucker, razorback Xyrauchen texanus Freshwater Fish/ Inland Salmonid E 17.95(e) Sucker, Santa Ana Catostomus santaanae Freshwater Fish/ Inland Salmonid T 17.95(e) Sucker, shortnose Chasmistes brevirostris Freshwater Fish/ Inland Salmonid E Sucker, Warner Catostomus warnerensis Freshwater Fish/ Inland Salmonid T 17.95(e) Sucker, Zuni bluehead Catostomus discobolus yarrow Freshwater Fish/ Inland Salmonid C Sunflower, Pecos (=puzzle, =paradox) Helianthus paradoxus 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 17.96(a) 

Sunshine, Sonoma Blennosperma bakeri 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Tadpole shrimp, vernal pool Lepidurus packardi 

Freshwater Shrimp/ Crustacean 

E 17.95(h) 
2013 VGP and sVGP BE 

E-51

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Tern, California least Sterna antillarum browni Coastal/Marine Bird E Tern, least Sterna antillarum Coastal/Marine Bird E Tern, roseate Sterna dougallii dougallii Coastal/Marine Bird E;T Thistle, Chorro Creek bog Cirsium fontinale var. obispoense 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Thistle, fountain Cirsium fontinale var. fontinale 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Thistle, La Graciosa Cirsium loncholepis 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Thistle, Loch Lomond coyote Eryngium constancei 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Thistle, Sacramento Mountains Cirsium vinaceum 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Thistle, Suisun Cirsium hydrophilum var. hydrophilum 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 
2013 VGP and sVGP BE 

E-52

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Three-ridge, fat (mussel) Amblema neislerii Unionid Mussel E 17.95(f) Thrush, small Kauai (=puaiohi) Myadestes palmeri Coastal/Marine Bird E Tiger beetle, northeastern beach Cicindela dorsalis dorsalis Beetle and Aquatic Insect T Tiger beetle, Puritan Cicindela puritana Beetle and Aquatic Insect T Tiger beetle, Salt Creek Cicindela nevadica lincolniana Beetle and Aquatic Insect E 17.95(i) Toad, arroyo (=arroyo southwestern) 

Bufo californicus (=microscaphus) Amphibian E 17.95(d) 

Toad, Houston Bufo houstonensis Amphibian E 17.95(d) Toad, Wyoming Bufo baxteri (=hemiophrys) Amphibian E Toad, Yosemite Bufo canorus Amphibian C Topminnow, Gila (incl. Yaqui) Poeciliopsis occidentalis Freshwater Fish/ Inland Salmonid E Treefrog, Arizona Hyla wrightorum Amphibian C Trout, Apache Oncorhynchus apache Freshwater Fish/ Inland Salmonid T Trout, bull Salvelinus confluentus Freshwater Fish/ Inland Salmonid T;XN 17.95(e) Trout, Gila Oncorhynchus gilae Freshwater Fish/ Inland Salmonid T Trout, greenback cutthroat Oncorhynchus clarki stomias Freshwater Fish/ Inland Salmonid T Trout, Lahontan cutthroat Oncorhynchus clarki henshawi Freshwater Fish/ Inland Salmonid T 
2013 VGP and sVGP BE 

E-53

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Trout, Little Kern golden Oncorhynchus aguabonita whitei Freshwater Fish/ Inland Salmonid T 17.95(e) Trout, Paiute cutthroat Oncorhynchus clarki seleniris Freshwater Fish/ Inland Salmonid T Trout, steelhead Oncorhynchus mykiss Anadromous Salmonid E 17.95(e), 226.21 Tuctoria, Greene's Tuctoria greenei 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Turtle, Alabama red-belly Pseudemys alabamensis Snakes and Other Reptiles E Turtle, bog (=Muhlenberg) Clemmys muhlenbergii Snakes and Other Reptiles T;T(S/A) Turtle, flattened musk Sternotherus depressus Snakes and Other Reptiles T Turtle, ringed map Graptemys oculifera Snakes and Other Reptiles T Turtle, Sonoyta mud Kinosternon sonoriense longifemorale Snakes and Other Reptiles C Turtle, yellow-blotched map Graptemys flavimaculata Snakes and Other Reptiles T Vervain, Red Hills Verbena californica 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Vireo, least Bell's Vireo bellii pusillus Coastal/Marine Bird E 17.95(b) Vole, Amargosa Microtus californicus scirpensis Terrestrial Mammal E 17.95(a) 
2013 VGP and sVGP BE 

E-54

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Vole, Florida salt marsh Microtus pennsylvanicus dukecampbelli Terrestrial Mammal E Warbler, nightingale reed (old world warbler) Acrocephalus luscinia Coastal/Marine Bird E  Wartyback, white (pearlymussel) Plethobasus cicatricosus Unionid Mussel E;XN Watercress, Gambel's Rorippa gambellii 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Waterdog, black warrior (=Sipsey Fork) Necturus alabamensis Amphibian C Water-plantain, Kral's Sagittaria secundifolia 

FreshwaterSaltwater Aquatic and Wetland Plants 

T 

Water-umbel, Huachuca Lilaeopsis schaffneriana var. recurva 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Wedgemussel, dwarf Alasmidonta heterodon Unionid Mussel E Whale, beluga Delphinapterus leucas Marine Mammal E Whale, blue Balaenoptera musculus Marine Mammal E Whale, bowhead Balaena mysticetus Marine Mammal E Whale, fin Balaenoptera physalus Marine Mammal E Whale, gray Eschrichtius robustus Marine Mammal E 
2013 VGP and sVGP BE 

E-55

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Whale, humpback Megaptera novaeangliae Marine Mammal E Whale, killer Orcinus orca Marine Mammal E 17.95(a) Whale, North Atlantic right whale Eubalaena glacialis Marine Mammal E 17.95(a), 226.203 Whale, North Pacific right whale Eubalaena japonica Marine Mammal E Whale, sei Balaenoptera borealis Marine Mammal E Whale, southern right Eubalaena australis Marine Mammal E Whale, sperm Physeter macrocephalus Marine Mammal E Whipsnake (=striped racer), Alameda 

Masticophis lateralis euryxanthus 

Snakes and Other Reptiles T 17.95(c) 

White Sedge Carex albida 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 

Wild-rice, Texas Zizania texana 

FreshwaterSaltwater Aquatic and Wetland Plants 

E 17.96(a) 

Wolf, red Canis rufus Terrestrial Mammal E;XN Woodpecker, ivory-billed Campephilus principalis Coastal/Marine Bird E Woodrat, riparian (=San Joaquin Valley) Neotoma fuscipes riparia Terrestrial Mammal E 
2013 VGP and sVGP BE 

E-56

Table E-1. List of Aquatic and Aquatic-Dependent Species that May Be Affected by the 2013 VGP and sV

Inverted Common Namea Scientific Name 

Listed Species 

Taxonomic 

Groupb

Listing Statusc Critical Habitatd

Evaluated 

for 

Impacts 

from ANS 

Onlye

Woundfin Plagopterus argentissimus Freshwater Fish/ Inland Salmonid E;XN 17.95(e) a) In the 2008 BE, EPA evaluated 664 aquatic and aquatic-dependent species. EPA identified a total of 612 aquatic and aquatic-depend

in the 2013 BE based reassessments of aquatic-dependent species, changes in status listings, and species identified by NMFS for coBE. 

b) Taxonomic groups are meant to roughly coincide with the Species Group provided in ECOS, but with further delineation according 

and attributes for the express purpose of showing the strong representation given by the subset of 82 species considered from the sevspecies datasets to which the risk conclusions and species-specific effects determinations made in this BE apply. See Section 5.2.5 f

of this relationship and extrapolation made between the subset of 82 species and their linkages to the larger taxonomic groupings. 

c) Listing status designations include: T= threatened; E=endangered; C=candidate; XN=experiment population, non-essential; PT=pro

PE=proposed endangered; T(S/A) =threatened due to similarity of appearance. 

d) Designation indicates where species’ critical habitat can be found in 50 CFR; No entry indicates no critical habitat for the species. 

e) A check mark in this column indicates that this species is an aquatic or aquatic-dependent listed species with more than limited expo

U.S.” that is not anticipated to be exposed to pollutants in vessel discharges covered under the VGP and sVGP. 

f) A check mark in this column indicates that this species is an aquatic or aquatic-dependent listed species with more than limited expo

U.S.” that may be exposed to ANS and pollutants in vessel discharges covered under the VGP and sVGP. 

g) RAA designations: PS=Puget Sound RAA; ULB=Upper and Lower Bay RAA; GB=Galveston Bay RAA; MR=Mississippi River R

Estuary RAA; SFBE=San Francisco Bay Estuary RAA; BB=Biscayne Bay RAA. 

h) Species included upon the recommendation of the National Marine Fisheries Service (NMFS). 

i) EPA identified 48 species that were missing in the ECOS GIS dataset out of the 612 aquatic and aquatic-dependent species that may 

and sVGP. For each of the missing species, EPA individually researched the species range by viewing on-line species distribution m

available range information. EPA determined that the species range was concurrent with waters navigable by vessels covered under on best professional judgment see page E-4 for more discussion. 

j) In addition to the 367 species identified as concurrent with the USACE NWN, EPA conducted further analysis to identify aquatic an

species concurrent with lakes and reservoirs greater than 50 square miles. EPA identified an additional 49 aquatic and aquatic-depenis range concurrent with NHD Plus lakes and reservoirs greater than 50 square miles, but not present in areas concurrent with the US
2013 VGP and sVGP BE 

E-57

Figure E-1. Waters Navigable by Vessels Covered Under the VGP and sVGP 

USACE National Waterway Network NHD Plus Lakes and Reservoirs Greater than 50 square miles
2013 VGP and sVGP BE 

E-58

Figure E-2. Range of Fish Species Present on the Continental U.S. that 

May Be Affected by the 2013 VGP and sVGP 

USACE National Waterway Network

Aquatic and Aquatic-Dependent Species Range Evaluated for Risk from ANS Only in Vessel Discharges

Aqautic and Aquatic-Dependent Species Range Evaluated for Risk from ANS and AdditionalPollutants in Vessel DischargesNHD Plus Lakes and Reservoirs Greater than 50 square miles
2013 VGP and sVGP BE 

E-59

Figure E-3. Range of Amphibian Species Present on the Continental U.S. that 

May Be Affected by the 2013 VGP and sVGP 

USACE National Waterway Network

Aquatic and Aquatic-Dependent Species Range Evaluated for Risk from ANS Only in Vessel Discharges

Aqautic and Aquatic-Dependent Species Range Evaluated for Risk from ANS and AdditionalPollutants in Vessel DischargesNHD Plus Lakes and Reservoirs Greater than 50 square miles
2013 VGP and sVGP BE Appendix F

Appendix F. Species Descriptions for Listed Aquatic and Aquatic-dependent 

Species from One of Seven RAAs Selected to Support Effects Analysis
2013 VGP and sVGP BE Appendix F

i

Table of Contents

F.1. SEATTLE, WASHINGTON..........................................................................................F-1

F.1.1. MARBLED MURRELET ......................................................................................F-1

F.1.2. GREEN SEA TURTLE ..........................................................................................F-3

F.1.3. LEATHERBACK SEA TURTLE ..........................................................................F-6

F.1.4. STELLER SEA-LION............................................................................................F-8

F.1.5. WATER HOWELLIA ..........................................................................................F-11

F.1.6. HUMPBACK WHALE ........................................................................................F-12

F.1.7. CHUM SALMON (Hood Canal summer-run) .....................................................F-15

F.1.8. STEELHEAD SALMON (Puget Sound)..............................................................F-18

F.1.9. CHINOOK SALMON (Puget Sound) ..................................................................F-21

F.1.10. KILLER WHALE.................................................................................................F-25

F.1.11. SHORT-TAILED ALBATROSS .........................................................................F-29

F.1.12. BULL TROUT......................................................................................................F-31

F.1.13. UTE LADIES’-TRESSES ....................................................................................F-34

F.1.14. GRIZZLY BEAR..................................................................................................F-36

F.2. NEW YORK, NEW YORK .........................................................................................F-39

F.2.1. SHORTNOSE STURGEON.................................................................................F-39

F.2.2. SEABEACH AMARANTH .................................................................................F-41

F.2.3. FINBACK WHALE..............................................................................................F-43

F.2.4. LOGGERHEAD SEA TURTLE ..........................................................................F-46

F.2.5. PIPING PLOVER.................................................................................................F-50

F.2.6. GREEN SEA TURTLE ........................................................................................F-53

F.2.7. BOG TURTLE......................................................................................................F-53

F.2.8. LEATHERBACK SEA TURTLE ........................................................................F-55

F.2.9. HAWKSBILL SEA TURTLE..............................................................................F-56

F.2.10. NORTH ATLANTIC RIGHT WHALE...............................................................F-58

F.2.11. KEMP’S RIDLEY SEA TURTLE .......................................................................F-61

F.2.12. HUMPBACK WHALE ........................................................................................F-63

F.2.13. INDIANA BAT ....................................................................................................F-64

F.2.14. ROSEATE TERN.................................................................................................F-66

F.3. HOUSTON, TEXAS .....................................................................................................F-68

F.3.1. FINBACK WHALE..............................................................................................F-68

F.3.2. LOGGERHEAD SEA TURTLE ..........................................................................F-68
2013 VGP and sVGP BE Appendix F

ii

F.3.3. PIPING PLOVER.................................................................................................F-68

F.3.4. GREEN SEA TURTLE ........................................................................................F-68

F.3.5. LEATHERBACK SEA TURTLE ........................................................................F-69

F.3.6. HAWKSBILL SEA TURTLE..............................................................................F-69

F.3.7. WHOOPING CRANE ..........................................................................................F-69

F.3.8. KEMP’S RIDLEY SEA TURTLE .......................................................................F-72

F.3.9. HUMPBACK WHALE ........................................................................................F-72

F.3.10. SMALLTOOTH SAWFISH.................................................................................F-72

F.3.11. WEST INDIAN MANATEE................................................................................F-75

F.4. SAINT LOUIS, MISSOURI.........................................................................................F-78

F.4.1. DECURRENT FALSE ASTER............................................................................F-78

F.4.2. PINK MUCKET ...................................................................................................F-80

F.4.3. SCALESHELL MUSSEL.....................................................................................F-82

F.4.4. GRAY BAT ..........................................................................................................F-84

F.4.5. INDIANA BAT ....................................................................................................F-86

F.4.6. EASTERN PRAIRIE FRINGED ORCHID .........................................................F-86

F.4.7. PALLID STURGEON..........................................................................................F-88

F.4.8. LEAST TERN (Interior Population).....................................................................F-90

F.5. DULUTH, MINNESOTA.............................................................................................F-92

F.5.1. PIPING PLOVER.................................................................................................F-92

F.6. SAN FRANCISCO, CALIFORNIA............................................................................F-92

F.6.1. NORTH AMERICAN GREEN STURGEON......................................................F-92

F.6.2. SONOMA ALOPECURUS..................................................................................F-94

F.6.3. CALIFORNIA TIGER SALAMANDER.............................................................F-97

F.6.4. GUADALUPE FUR SEAL ..................................................................................F-99

F.6.5. SONOMA SUNSHINE ......................................................................................F-101

F.6.6. MARBLED MURRELET ..................................................................................F-102

F.6.7. CONSERVANCY FAIRY SHRIMP..................................................................F-102

F.6.8. LONGHORN FAIRY SHRIMP .........................................................................F-104

F.6.9. LOGGERHEAD SEA TURTLE ........................................................................F-107

F.6.10. WHITE SEDGE..................................................................................................F-107

F.6.11. HOOVER’S SPURGE........................................................................................F-108

F.6.12. WESTERN SNOWY PLOVER .........................................................................F-110

F.6.13. GREEN SEA TURTLE ......................................................................................F-113
2013 VGP and sVGP BE Appendix F

iii

F.6.14. FOUNTAIN THISTLE.......................................................................................F-113

F.6.15. SUISUN THISTLE.............................................................................................F-115

F.6.16. SOFT BIRD’S-BEAK ........................................................................................F-117

F.6.17. PALMATE-BRACTED BIRD’S BEAK............................................................F-119

F.6.18. LEATHERBACK SEA TURTLE ......................................................................F-120

F.6.19. VALLEY ELDERBERRY LONGHORN BEETLE..........................................F-121

F.6.20. DELTA GREEN GROUND BEETLE...............................................................F-123

F.6.21. SOUTHERN SEA OTTER.................................................................................F-124

F.6.22. TIDEWATER GOBY.........................................................................................F-126

F.6.23. STELLER SEA-LION........................................................................................F-129

F.6.24. WHITE ABALONE............................................................................................F-129

F.6.25. DELTA SMELT .................................................................................................F-131

F.6.26. OLIVE RIDLEY SEA TURTLE........................................................................F-134

F.6.27. VERNAL POOL TADPOLE SHRIMP..............................................................F-137

F.6.28. ALAMEDA WHIPSNAKE................................................................................F-141

F.6.29. COLUSA GRASS...............................................................................................F-143

F.6.30. RIPARIAN WOODRAT ....................................................................................F-145

F.6.31. STEELHEAD SALMON....................................................................................F-147

F.6.32. KILLER WHALE...............................................................................................F-148

F.6.33. HAIRY ORCUTT GRASS.................................................................................F-148

F.6.34. CALISTOGA ALLOCARYA ............................................................................F-151

F.6.35. NAPA BLUEGRASS .........................................................................................F-153

F.6.36. CALIFORNIA RED-LEGGED FROG ..............................................................F-154

F.6.37. SALT MARSH HARVEST MOUSE.................................................................F-158

F.6.38. CALIFORNIA FRESHWATER SHRIMP.........................................................F-160

F.6.39. GIANT GARTER SNAKE.................................................................................F-162

F.6.40. SOLANO GRASS ..............................................................................................F-164

F.7. MIAMI, FLORIDA.....................................................................................................F-167

F.7.1. SHORTNOSE STURGEON...............................................................................F-167

F.7.2. GULF STURGEON............................................................................................F-167

F.7.3. STAGHORN CORAL ........................................................................................F-170

F.7.4. ELKHORN CORAL...........................................................................................F-173

F.7.5. CAPE SABLE SEASIDE SPARROW...............................................................F-175

F.7.6. FINBACK WHALE............................................................................................F-177
2013 VGP and sVGP BE Appendix F

iv

F.7.7. BROOKSVILLE BELLFLOWER .....................................................................F-177

F.7.8. RED WOLF ........................................................................................................F-179

F.7.9. LOGGERHEAD SEA TURTLE ........................................................................F-181

F.7.10. GREEN SEA TURTLE ......................................................................................F-181

F.7.11. AMERICAN CROCODILE ...............................................................................F-181

F.7.12. LEATHERBACK SEA TURTLE ......................................................................F-184

F.7.13. EASTERN INDIGO SNAKE.............................................................................F-184

F.7.14. HAWKSBILL SEA TURTLE............................................................................F-186

F.7.15. NORTH ATLANTIC RIGHT WHALE.............................................................F-186

F.7.16. JOHNSON’S SEAGRASS .................................................................................F-186

F.7.17. HUMPBACK WHALE ......................................................................................F-188

F.7.18. WOOD STORK..................................................................................................F-189

F.7.19. GRAY BAT ........................................................................................................F-191

F.7.20. INDIANA BAT ..................................................................................................F-191

F.7.21. AUDUBON’S CRESTED CARACARA...........................................................F-191

F.7.22. SMALLTOOTH SAWFISH...............................................................................F-193

F.7.23. FLORIDA PANTHER........................................................................................F-193

F.7.24. EVERGLADE SNAIL KITE..............................................................................F-196

F.7.25. AMERICAN CHAFFSEED ...............................................................................F-198

F.7.26. ROSEATE TERN...............................................................................................F-200

F.7.27. WEST INDIAN MANATEE..............................................................................F-200

F.8. REFERENCES............................................................................................................F-200
2013 VGP and sVGP BE Appendix F

F-1

The following subsections describe the listed aquatic and aquatic-dependent species 

identified in Table 3-22 for each of the seven RAAs evaluated in the BE. For each species 

presented, EPA collected information on the life history, population dynamics, and current status 

and distribution of each species using the sources identified at the beginning of each species 

subsection. The information and data are generally directly from the Services or a related 

government source. In order to avoid inaccurate paraphrasing, information is often directly 

collected and presented from these other government sources, and EPA does not claim 

ownership or authorship of all language found within this appendix. However, EPA believes that 

the compilation of information contained within this appendix is a succinct collection of key, 

credible information used by the Agency to inform our effects determinations. Additionally, the 

listed sources at the beginning of the subsection represent the primary references EPA reviewed 

to obtain the presented species information and are cited in the reference section of this 

appendix. Additional citations provided within the text are as cited within the primary references. 

In the interest of brevity, bibliographical information for citations presented within the text are 

not contained within this appendix's bibliography and can be obtained from the reference 

sections from the species-specific sources sections instead.

F.1. SEATTLE, WASHINGTON

F.1.1.

Brachyramphus marmoratus or Brachyramphus marmoratus marmoratus

MARBLED MURRELET 

Family: Alcidae

Threatened: CA, OR, and WA 

Not Listed: everywhere else

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=B08C)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Brachyramphus

+marmoratus)

• UMMZ, 2012 

Description:

Marbled murrelets are a small seabird, approximately 9 inches long. Adult breeding murrelets 

are dark above and heavily mottled below and have an entirely dark tail and black bill. The 

underparts are mostly white. They belong to the Alcidae family, whose species are sometimes 

referred to as the black-and white “penguins of the north”. Birds in this family have set-back legs 

that give them an upright stance on land. In flight, they zigzag on rapid wingbeats at up to 

98 mph (USFWS, 2004b).

Geographic Boundaries and Spatial Distribution:

The current range of B. m. marmoratus in the United States is Washington, Oregon, and 

California. Migratory movements primarily consist of small-scale seasonal shifts of habitat. 

Individuals move seasonally from outer coastal to protected waters, from inland waters to 
2013 VGP and sVGP BE Appendix F

F-2

unknown locations, south of breeding areas, or to areas further offshore. Winter ranges are 

poorly documented, but some individuals have been recorded in southern California and the 

extreme northwest coastline of Baja California, Mexico. The exact numbers of B. m. marmoratus 

are unknown. Based upon surveys completed in 1995, the estimates of number of individuals are: 

5,000-6,500 in Washington, 6,600-20,000 in Oregon, and 6,450 in California.

Habitat: (has critical habitat)

The murrelet's historic breeding habitat was forested areas along the coast from the Aleutian 

Archipelago in Alaska, British Columbia, Washington, Oregon, and south to Santa Cruz County 

in west-central California, and it wintered in northwest Mexico (USFWS, 2004b). In the current 

range, marbled murrelets use older forest stands near the coastline for nesting. These forests are 

generally characterized by large trees (>80cm (32 inches) dbh), multi-storied stands, and a 

moderate to high canopy closure. In certain parts of the range, marbled murrelets are also known 

to use mature forest with an old-growth component.

Critical habitat for the marbled murrelet was designated on May 24, 1996 in Washington, 

California and Oregon. In Oregon, a total of 1,515,300 acres are designated. Of this, habitat, 

1,338,200 acres are federally owned, 175,100 acres belong to the State, 1,100 acres are County 

lands and the remaining 900 acres are privately held (USFWS, 1996).

Primary constituent elements for the marbled murrelet include: (1) individual trees with potential 

nesting platforms, and (2) forested areas within 0.8 kilometers (0.5 miles) of individual trees 

with potential nesting platforms, and with a canopy height of at least one-half the site-potential 

tree height. This includes all such forest, regardless of contiguity. These primary constituent 

elements are essential to provide and support suitable nesting habitat for successful reproduction 

of the marbled murrelet (UFWS, 1996).

Life History:

Marbled murrelets nest in trees in coastal, older forests throughout most of their range in North 

America. They attend their breeding sites during periods of low light, and nest solitarily. 

Murrelets have been one of the most difficult species to study because of their secretive behavior 

and elusive nests. The first verified nest was found in North America in 1974 (USFWS, 2004b). 

Nest building commences in March to mid-July. Nests are constructed on naturally occurring 

platforms in large-diameter conifer limbs created by normal growth, disease, mistletoe, and 

deformed branching (especially in coastal redwoods). The murrelet adds needles and bits of 

debris to complete the nest. They usually lay only one egg. No data exists on renesting after 

failure. Incubation lasts about 30 days and fledging takes another 28 days. Marbled murrelets do 

not reach sexual maturity until their second year. Courtship takes place at sea in early spring and 

throughout summer; pairs display synchronous flight and diving behaviors (USFWS, 2004b).

Marbled murrelets feed primarily on fish and invertebrates in near-shore marine environments. 

The murrelet dives underwater and forages throughout the marine water column on small ocean 

fish, such as anchovy, herring, and sardines. Chicks are semiprecocial and are fed whole fish 

soon after hatching (USFWS, 2004b).
2013 VGP and sVGP BE Appendix F

F-3

Historical Information:

The North American subspecies of marbled murrelet ranges from the Aleutian Islands and 

southern Alaska south to central California, the largest portion of the population occurs in Alaska 

and British Columbia. Due to loss of older forests used for nesting sites, the species is declining. 

For example, current estimates indicate that the population has declined by 50% to 82%; 

approximately 6,500 individual murrelets inhabit the area along the coast of California (OFWO,

2003f). Using known population numbers relative to remaining suitable nesting habitat, it has 

been estimated that historically, 60,000 marbled murrelet pairs may have been found in this same 

area. Along the Oregon coast, recent surveys have shown a decline in murrelet numbers during 

the 1990's. 

Conservation Status:

Although the population size of the marbled murrelet prior to 1980 is not known, scientists 

strongly suspect that industrial logging caused a significant decline in numbers prior to this year 

(Carter and Erickson, 1992). Air surveys conducted in September 1993 in Oregon indicate that 

the highest densities of the birds occurred from Cape Lookout to Brookings (5.4-6.8 birds/km2), 

with somewhat lower densities reported north of Cape Lookout (3.2-5.0 birds/km2) (Varoujean 

and Williams, 1995). The current number of marbled murrelets in Oregon is also unknown, yet 

the number of birds at sea along the Oregon coast during the breeding season for three years

(2000 to 2002) averaged 12,133, or 10.7 birds per km (Huff et al., 2003). In North America, it is 

estimated that there are approximately 947,500 birds, the majority of which are found in Alaska.

Summary of Major Threats:

The greatest threats for the marbled murrelet population include genetic threats and disease. Loss 

of viable nesting habitat is thought to be a primary factor responsible for an estimated annual 4% 

to 7% decline in marbled murrelet populations in Washington, Oregon, and California. It is 

unlikely that population numbers will increase rapidly due to the naturally low reproductive rate 

and the continued loss of nesting habitat indicates that the recovery of the species is likely to take 

decades (OFWO, 2003f).

F.1.2.

Chelonia mydas

GREEN SEA TURTLE

Family: Cheloniidae

Endangered: breeding colony populations in FL and on Pacific Coast of Mexico

Threatened: everywhere else

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=C00S)

• USFWS, 2012c

(http://www.fws.gov/northflorida/SeaTurtles/Turtle%20Factsheets/green-sea-turtle.htm) 

• NOAA Fisheries, 2012 (http://www.nmfs.noaa.gov/pr/pdfs/fr/fr63-46693.pdf)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Chelonia+mydas

)
2013 VGP and sVGP BE Appendix F

F-4

Description:

The green sea turtle grows to a maximum size of about 4 feet and a weight of 440 pounds. It has 

a heart-shaped shell, small head, and single-clawed flippers. Color is variable. Hatchlings 

generally have a black carapace, white plastron, and white margins on the shell and limbs. The 

adult carapace is smooth, keelless, and light to dark brown with dark mottling; the plastron is 

whitish to light yellow. Adult heads are light brown with yellow markings. Identifying 

characteristics include four pairs of costal scutes, none of which borders the nuchal scute, and 

only one pair of prefrontal scales between the eyes. 

Geographic Boundaries and Spatial Distribution:

The green turtle has a worldwide distribution in tropical and subtropical waters. Major green 

turtle nesting colonies in the Atlantic occur on Ascension Island, Aves Island, Costa Rica, and 

Surinam. Within the U.S., green turtles nest in small numbers in the U.S. Virgin Islands, Puerto 

Rico, Georgia, South Carolina, and North Carolina, and in larger numbers in Florida. The Florida 

green turtle nesting aggregation is recognized as a regionally significant colony. About 200 to 

1,100 females are estimated to nest on beaches in the continental U.S. In the U.S. Pacific, over 

90 percent of nesting throughout the Hawaiian archipelago occurs at the French Frigate Shoals, 

where about 200 to 700 females nest each year. Elsewhere in the U.S. Pacific, nesting takes place 

at scattered locations in the Commonwealth of the Northern Marianas, Guam, and American 

Samoa. In the western Pacific, the largest green turtle nesting aggregation in the world occurs on 

Raine Island, Australia, where thousands of females nest nightly in an average nesting season. In 

the Indian Ocean, major nesting beaches occur in Oman where 6,000 to 20,000 females are 

reported to nest annually.

Habitat: (has critical habitat)

Green turtles are generally found in fairly shallow waters (except when migrating) inside reefs, 

bays, and inlets. The turtles are attracted to lagoons and shoals with an abundance of marine 

grass and algae. Open beaches with a sloping platform and minimal disturbance are required for 

nesting.

Critical habitat includes: (50 CFR 226.208) Culebra Island, Puerto Rico – Waters surrounding 

the island of Culebra from the mean high water line seaward to 3 nautical miles (5.6 km). These 

waters include Culebra’s outlying Keys including Cayo Norte, Cayo Ballena, Cayos Geniquí, 

Isla Culebrita, Arrecife Culebrita, Cayo de Luis PeZa, Las Hermanas, El Mono, Cayo Lobo, 

Cayo Lobito, Cayo Botijuela, Alcarraza, Los Gemelos, and Piedra Steven.

Life History:

Green turtles apparently have a strong nesting site fidelity and often make long distance 

migrations between feeding grounds and nesting beaches. Hatchlings have been observed to seek 

refuge and food in Sargassum rafts. Hatchling green turtles eat a variety of plants and animals, 

but adults feed almost exclusively on seagrasses and marine algae. Hatchling green turtles eat a 

variety of plants and animals, but adults feed almost exclusively on seagrasses and marine algae.

The nesting season varies with the locality. In the Southeastern U.S., it is roughly June through 

September. Nesting occurs nocturnally at 2, 3, or 4-year intervals. Only occasionally do females 

produce clutches in successive years. A female may lay as a many as nine clutches within a 
2013 VGP and sVGP BE Appendix F

F-5

nesting season (overall average is about 3.3 nests per season) at about 13-day intervals. Clutch 

size varies from 75 to 200 eggs, with an average clutch size of 136 eggs reported for Florida. 

Incubation ranges from about 45 to 75 days, depending on incubation temperatures. Hatchlings 

generally emerge at night. Age at sexual maturity is believed to be 20 to 50 years.

Historical Information:

Green turtles are primarily restricted to tropical and subtropical waters. In U.S. Atlantic and Gulf 

of Mexico waters, green turtles are found from Massachusetts to Texas and in the U.S. Virgin 

Islands and Puerto Rico. Caribbean populations of green turtles have diminished significantly 

from historical levels, primarily due to the directed turtle fishery that existed prior to their listing 

under the ESA. Additionally, researchers have documented that habitat loss is a primary factor 

slowing the recovery of the species throughout its range. Degradation of seagrass beds has 

slowed recovery of green turtles in the Caribbean due to reduced carrying capacity of seagrass 

meadows (Williams, 1988). Therefore, the extent of habitat required for foraging green turtles is 

likely to be increasing due to the reduced productivity of remaining seagrass beds.

Conservation Status:

In U.S. Atlantic waters, green sea turtles occur around the U.S. Virgin Islands and Puerto Rico, 

where small numbers nest (islas Mona, Vieques, and Culebra, and St. Thomas, St. John, St. 

Croix), and a juvenile population exists in eastern portion of Puerto Rican Bank (Collazo et al.,

1992), and from Texas to Massachusetts. Relatively small numbers nest in Florida, particularly 

in Brevard, Indian River, St. Lucie, Martin, Palm Beach, and Broward counties (CSTC, 1990), 

mostly from Volusia County to Dade County (Ehrhart and Witherington, 1992), with rare recent 

nesting on the Gulf Coast in Santa Rosa County (Ehrhart and Witherington, 1992); important 

feeding areas in Florida include the Indian River, Florida Bay, Homossassa Bay, Crystal River, 

and Cedar Key (CSTC, 1990). Rarely nests in Georgia, North Carolina, and Texas.

Summary of Major Threats:

Sea turtles face nesting and marine threats. Nesting threats include: loss or degradation of nesting 

habitat from coastal development and beach armoring, degradation of foraging habitat,

landscaping, erosion, erosion control methods, disorientation of hatchlings by beachfront 

lighting, beach and vehicle traffic, sand mining, beach cleaning, and excessive nest predation by 

native and non-native predators. Marine threats include: entanglement in and ingestion of marine 

debris, degradation of foraging habitat, boat collisions, sedimentation and siltation, agricultural 

and industrial pollution, oil spills, sewage, incidental take from channel dredging and 

commercial fishing operations, and illegal exploitation.

A major factor contributing to the green turtle's decline worldwide is commercial harvest for 

eggs and meat. Fibropapillomatosis, a disease of sea turtles characterized by the development of 

multiple tumors on the skin and internal organs, is also a mortality factor and has seriously 

impacted green turtle populations in Florida, Hawaii, and other parts of the world. The tumors 

interfere with swimming, eating, breathing, vision, and reproduction, and turtles with heavy 

tumor burdens become severely debilitated and die. 
2013 VGP and sVGP BE Appendix F

F-6

F.1.3.

Dermochelys coriacea

LEATHERBACK SEA TURTLE

Family: Dermochelyidae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=C00F)

• USFWS, 2012c

(http://www.fws.gov/northflorida/SeaTurtles/Turtle%20Factsheets/leatherback-seaturtle.htm) 

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Dermochelys+co

riacea)

• GLEC, 2011

Description:

The leatherback is the largest, deepest diving, and most migratory and wide ranging of all sea 

turtles. The adult leatherback can reach 4 to 8 feet in length and 500 to 2,000 pounds in weight. 

Its shell is composed of a mosaic of small bones covered by firm, rubbery skin with seven 

longitudinal ridges or keels. The skin is predominantly black with varying degrees of pale 

spotting, including a notable pink spot on the dorsal surface of the head in adults. A toothlike 

cusp is located on each side of the gray upper jaw; the lower jaw is hooked anteriorly. The 

paddle-like, clawless limbs are black with white margins and pale spotting.

Geographic Boundaries and Spatial Distribution:

The leatherback turtle is distributed worldwide in tropical and temperate waters of the Atlantic, 

Pacific, and Indian Oceans. It is also found in small numbers as far north as British Columbia, 

Newfoundland, and the British Isles, and as far south as Australia, Cape of Good Hope, and 

Argentina. 

Habitat: (has critical habitat)

The leatherback is the most pelagic of the sea turtles. Adult females require sandy nesting 

beaches backed with vegetation and sloped sufficiently so the crawl to dry sand is not too far. 

The preferred beaches have proximity to deep water and generally rough seas.

Critical habitat includes: (50 CFR 17.95) U.S. Virgin Islands – A strip of land 0.2 miles wide 

(from mean high tide inland) at Sandy Point Beach on the western end of the island of St. Croix 

beginning at the southwest cape to the south and running 1.2 miles northwest and then northeast 

along the western and northern shoreline, and from the southwest cape 0.7 miles east along the 

southern shoreline. (50 CFR 226.207) Also includes the waters adjacent to Sandy Point, St. 

Croix, U.S. Virgin islands, up to and inclusive of the waters from the hundred fathom curve 

shoreward to the level of mean high tide with boundaries at 17 42’12" North and 64 50’00" 

West.
2013 VGP and sVGP BE Appendix F

F-7

On January 5, 2010, NMFS proposed regulations to revise the critical habitat designation for the 

endangered leatherback sea turtle by designating additional areas within the Pacific Ocean. 

Specific areas proposed for designation include two adjacent marine areas totaling approximately 

46,100 square miles (119,400 square km), stretching along the California coast from Point Arena 

to Point Vincente, and one 24,500 square mile (63,455 square km) marine area, stretching from 

Cape Flattery, WA, to the Umpqua River (Winchester Bay), OR, east of a line approximating the 

2,000 meter depth contour. The areas proposed for designation comprise approximately 70,600 

square miles (182,854 square km) of marine habitat.

Life History:

Jellyfish are the main staple of its diet, but it is also known to feed on sea urchins, squid, 

crustaceans, tunicates, fish, blue-green algae, and floating seaweed. The turtles are exposed to 

cyanide dissolved in the water and through contaminated items in their diet.

In the United States, the females nest from about March to July. Female leatherbacks nest an 

average of 5 to 7 times within a nesting season, with an observed maximum of 11 nests. The 

average intra-nesting interval is about 9 to 10 days. The nests are constructed at night in clutches 

of about 70 to 80 yolked eggs. The white spherical eggs are approximately 2 inches in diameter. 

Typically incubation takes from 55 to 75 days, and the hatchlings emerge at night. Most 

leatherbacks remigrate to their nesting beaches at 2 to 3-year intervals. Leatherbacks are believed 

to reach sexual maturity in 6 to 10 years. 

Historical Information:

Endangered throughout its range (Federal Register, June 2, 1970), recent estimates of global 

nesting populations indicate 26,000 to 43,000 nesting females annually, which is a dramatic 

decline from the 115,000 estimated in 1980. This reduction is a result of exponential declines in 

leatherback nesting that has been documented over the last two decades along the Pacific coasts 

of Mexico and Costa Rica. The Mexico leatherback nesting population, once considered to be the 

world’s largest leatherback nesting population (65 percent of worldwide population), is now less 

than one percent of its estimated size in 1980.

Conservation Status:

Oceanic distribution is nearly worldwide, but the number of nesting sites is few; many nesting 

areas have few breeding females and suffer from some human predation; range and number of 

occurrences have undergone reduction; recent severe population declines at some nesting 

locations.

The largest nesting populations now occur in the western Atlantic in French Guiana (4,500 to 

7,500 females nesting/year) and Colombia (estimated several thousand nests annually), and in 

the western Pacific in West Papua (formerly Irian Jaya) and Indonesia (about 600 to 650 females 

nesting/year). In the United States, small nesting populations occur on the Florida east coast 

(35 females/year), Sandy Point, U.S. Virgin Islands (50 to 100 females/year), and Puerto Rico 

(30 to 90 females/year).
2013 VGP and sVGP BE Appendix F

F-8

Summary of Major Threats:

Sea turtles face nesting and marine threats. Nesting threats include: loss or degradation of nesting 

habitat from coastal development and beach armoring, degradation of foraging habitat,

landscaping, erosion, erosion control methods, disorientation of hatchlings by beachfront 

lighting, beach and vehicle traffic, sand mining, beach cleaning, and excessive nest predation by 

native and non-native predators. Marine threats include: entanglement in and ingestion of marine 

debris, degradation of foraging habitat, boat collisions, sedimentation and siltation, agricultural 

and industrial pollution, oil spills, sewage, incidental take from channel dredging and 

commercial fishing operations, and illegal exploitation.

F.1.4.

Eumetopias jubatus

STELLER SEA-LION

Family: Otariidae

Endangered: population segment west of 144° W longitude

Threatened: everywhere else

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=A0FS)

• NOAA Fisheries, 2012 

(http://www.nmfs.noaa.gov/pr/species/mammals/pinnipeds/stellersealion.htm)

• UMMZ, 2012 

Description:

The Steller sea-lion is the largest member of the Otariidae (eared seal) family. Males may be up 

to 10-11 feet in length and can weigh up to 2,400 lb. Females are smaller than males, 7.5-9.5 feet 

in length and up to 770 lb. in mass. Males and females are light buff to reddish brown and 

slightly darker on the chest and abdomen; naked parts of the skin are black. Wet animals usually 

appear darker than dry ones. Pups are about 3.3 feet in length and 35-50 lb. at birth and grow to 

about 65-90 lb. after 6-10 weeks. Pups are dark brown to black until 4 to 6 months old when they 

molt to a lighter brown. By the end of their second year, pups have taken on the same pelage 

color as adults.

Geographic Boundaries and Spatial Distribution:

Steller sea-lions are distributed across the North Pacific Ocean rim from northern Hokkaido, 

Japan, through the Kuril Islands, Okhotsk Sea, and Commander Islands in Russia, the Aleutian 

Islands, central Bering Sea, and southern coast of Alaska, and south to the Channel Islands off 

California. During the May-to-July breeding season, Steller sea-lions congregate at more than 

40 rookeries, where adult males defend territories, pups are born, and mating takes place. Nonreproductive animals congregate to rest at more than 200 haul-out sites where little or no 

breeding takes place. Sea-lions continue to gather at both rookeries and haul-out sites outside of 

the breeding season (NMML, 2004).

The world population of Steller sea-lions includes two stocks (Western and Eastern) divided at 

144° W longitude (Cape Suckling, just east of Prince William Sound, Alaska). The stock 
2013 VGP and sVGP BE Appendix F

F-9

differentiation is based primarily on differences in mitochondrial DNA, but also on differing 

population trends in the two regions (NMML, 2004).

Habitat: (has critical habitat)

Marine habitats of the stellar sea-lion include coastal waters near shore and over the continental 

slope; sometimes rivers are ascended in pursuit of prey. When not on land, the sea-lions may 

congregate at nearshore traditional rafting sites, or move out to the edge of the continental shelf 

(Kajimura and Loughlin, 1988). While offshore, the sea-lions are most often found within 

22 miles of shore (Kenyon and Rice, 1961, Fiscus and Baines, 1966) but may range out to 

several hundred kilometers offshore. The distance sea-lions move offshore varies seasonally, 

with fewer animals being sighted at sea during the summer (Fiscus et al., 1976, Bonnell et al.,

1983). 

The most commonly used terrestrial habitat types are rookeries and haulouts. Rookeries are areas 

where adults congregate for breeding and pupping. These habitats generally occur on beaches of 

remote islands with difficult access for humans and other mammalian predators (NMFS, 1990). 

The beaches can be sand, gravel, cobble, boulder, or bedrock. Female sea-lions tend to select 

locations for pupping that are gently sloping and protected from waves (Sandegren, 1970). 

Females often use the same pupping site in successive years and tend to breed in or near their 

natal colony (Calkins and Pitcher, 1982). Rookery sites may be used as haulout sites during the 

nonbreeding season. Independent juveniles usually avoid rookeries (Gentry, 1970; Sandegren 

1970; Calkins and Pitcher, 1983; Hoover, 1988). From about two weeks after birth, the pups 

begin to spend increasing amounts of time in the intertidal areas and swimming near shore. 

Haulouts are areas used by adult sea-lions during the nonbreeding season and by nonbreeding 

adults and subadults throughout the year (NMFS, 1990). Haulout locations include exposed 

rocks, reefs, beaches, jetties, breakwaters, navigational aids, floating docks, and sea ice. 

Selection of both rookery and haulout sites appears to depend on a number of factors including 

substrate type, degree of exposure to wind and waves, proximity to food resources, tradition of 

use, season, and the degree of human disturbance (Gentry, 1970; Sandegren, 1970; Calkins and 

Pitcher, 1983; Hoover, 1988, Johnson et al., 1989).

Critical habitat areas, designated by the National Marine Fisheries Service on August 27, 1993, 

respond to requirements of the Endangered Species Act (50 CFR 226.202). Steller sea-lion 

critical habitat includes a 20 nautical mile buffer around all major haulouts and rookeries, as well 

as associated terrestrial, air and aquatic zones, and three large offshore foraging areas. NMFS has 

implemented a complex suite of fishery management measures designed to minimize 

competition between fishing and the endangered population of Steller sea-lions in critical habitat 

areas. Those management measures are the Steller sea-lion protection measures (NOAA, 1993). 

Specific primary constituent elements for this species are not described in the regulation.

Life History:

Bulls become mature between 3 and 8 years of age, but typically are not massive enough to hold 

territory successfully until 9 or 10 years old. Females reproduce for the first time at 4 to 6 years 

of age, bearing at most a single pup each year. Pups are born from late May through early July, 

with peak numbers of births during the second or third week of June. Females stay with their 

pups for about 9 days before beginning a regular routine of foraging trips to sea. Females mate 
2013 VGP and sVGP BE Appendix F

F-10

11 to 14 days after giving birth. Implantation takes place in late September or early October, 

after a 3-4 month delay. Weaning is not sharply defined as it is for most other pinniped species, 

but probably takes place gradually during the winter and spring prior to the following breeding 

season. It is not uncommon to observe 1- or 2-year-old sea-lions suckling from an adult female 

(NMML, 2004).

Steller sea-lions are opportunistic predators, feeding primarily of a wide variety of fishes and 

cephalopods. Prey varies geographically and seasonally. Some of the more important prey 

species in Alaska include walleye pollock, Atka mackerel, Pacific herring, Capelin, Pacific sand 

lance, Pacific cod, and salmon. Steller sea-lions have been known to prey on harbor seal, fur 

seal, ringed seal, and possibly sea otter pups, but this would represent only a supplemental 

component to the diet (NMML, 2004).

Historical Information:

The number of Steller sea-lions in the western stock declined by 75% between 1976 and 1990. 

The extent of this decline led the National Marine Fisheries Service (NMFS) to list the Steller 

sea-lion as threatened range-wide under the Endangered Species Act (ESA) in April 1990. A 

1992-93 analysis conducted by A. York, R. Merrick, and T. Loughlin (see York et al., 1996) of 

the National Marine Mammal Laboratory indicated that if the 1985-92 population trend 

continued, there was a very high probability that sea lions would be extinct in Alaska from 

Prince William Sound westward within 100 years. The decline has continued for the western 

stock in Alaska, which was declared endangered in 1997. The eastern stock remains listed as 

threatened (NMML 2004).

Conservation Status:

Between the late 1950s and the late 1970s, the total population of Steller sea-lions had remained 

relatively stable at about 250,000-300,000 individuals. Breeding animals were distributed among 

51 rookeries, 60% of which included over 1000 adults; 38% of the recorded population was at 

nonbreeding haul-out sites during the breeding season (Loughlin et al., 1984). In 1989, there 

were at least 4,000 sea-lions in Washington, Oregon and California. The eastern population in

1994 was estimated at about 28,600 individuals (NMFS, 1990) (18,600 non-pups according to 

Mello, 1994). The eastern population segment has exhibited an overall increasing trend since 

1990, although there have been reductions in the population in certain areas.

Summary of Major Threats:

Anthropogenic (or human-induced) threats to Steller sea-lions include boat strikes, 

contaminants/pollutants, habitat degradation, illegal hunting/shooting, offshore oil and gas 

exploration, direct and indirect interactions with fisheries, and subsistence harvests by natives in 

Alaska and Canada (150-300 taken a year). In the 1800s, they were targeted by hunters for their 

meat (food), fur hides (clothing), oil, and various other products. In the early 1900s, fishermen 

killed and placed bounties on this species, which they blamed for stealing fish from them. Some 

Steller sea-lions were killed to limit their predation on fish in aquaculture facilities (fish farms), 

but intentional killing of Steller sea-lions has not been permitted since they were protected under 

the Marine Mammal Protection Act (MMPA) and listed under the ESA.
2013 VGP and sVGP BE Appendix F

F-11

Steller sea-lions' direct and indirect interactions with fisheries are currently receiving significant 

attention and may possibly be an important factor in their decline. Direct fishing impacts are 

largely due to fishing gear (drift and set gillnets, longlines, trawls, etc.) that has the potential to 

entangle, hook, injure, or kill sea-lions. These pinnipeds have been seen entangled in fishing 

equipment with what are considered "serious injuries." Steller sea-lions are also indirectly 

threatened by fisheries because they have to compete for food resources and critical habitat may 

be modified by fishing activities.

F.1.5.

Howellia aquatilis

WATER HOWELLIA

Family: Campanulaceae

Threatened: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q2RM)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Howellia+aquati

lis)

• USFWS, 2012d (http://www.fws.gov/oregonfwo/Species/Data/WaterHowellia/)

Description:

Water howellia is a winter annual aquatic plant that grows 4-24 inches high. It has extensively 

branched, submerged or floating stems and narrow, linear, alternate (sometimes opposite) leaves 

up to 2 inches in length. Water howellia usually flowers in May and June, with small trumpetshaped blooms ranging from white to light purple in color, at or above the water surface. There 

may also be small axillary flowers beneath the water surface. 

Geographic Boundaries and Spatial Distribution:

Howellia aquatilis is known to occur in California, Idaho, Montana, and Washington. 

Historically found in Oregon. The plant has also been found on Turnbull National Wildlife 

Refuge in Washington. 

Habitat: (no critical habitat)

Its habitat consists of small vernal wetlands with a bottom surface of firm, consolidated clay and 

organic sediments. These include shallow, low-elevation glacial pothole ponds and former river 

oxbows with margins of deciduous trees and shrubs. These habitats are inundated by spring rains 

and snowmelt runoff and typically dry out by the end of the growing season. The plants tend to 

root in the shallow water at the edges of deeper ponds that are (at lower elevations) surrounded 

by deciduous trees such as black cottonwood and aspen.

Life History:

A dry pond bed is required for seed germination, which begins shortly after the bottom is 

uncovered and continues until seeds are once again submerged. Most of the current year’s seed 
2013 VGP and sVGP BE Appendix F

F-12

crop germinates during that interval. Plants begin to grow by early May, producing closed 

(cleistogamous) flowers below water and open (chasmogomous) flowers when they reach the 

surface. Both types of flowers are adapted for self-pollination. Seed dispersal begins in June 

from the underwater fruits, and extends until late summer as the emergent fruits mature. If a 

pond does not fill with water in spring, no seed will be produced. If the portion of the pond 

supporting the plant does not dry out at some point, that year’s seed crop will not germinate. The 

plants overwinter as seedlings. This results in annual variability in population size depending on 

the extent of the previous season’s drying.

Historical Information:

Historically, this species occurred over a large area of the Pacific Northwest, but extant 

populations are mostly clustered in 2 main population centers, one in eastern Washington and 

one in northwestern Montana. 

Conservation Status:

The species has also been found recently at several sites in Mendocino County, California; 

extirpated in Oregon. Genetic variability is low throughout its range; the species may represent a 

single genotype that is narrowly adapted to specific habitat conditions. Populations vary widely 

in size from year to year and very wet or very dry seasons can have a detrimental effect on 

abundance. The large fluctuations in annual numbers and low genetic variability indicate that 

isolated populations may be vulnerable to extirpation. Populations near the larger "population 

centers" may be inherently more resilient.

Summary of Major Threats:

In Oregon, sites where Water howellia were historically found are now within developed urban 

areas. Channelization and construction of dams along the Columbia, Willamette, and other rivers 

has led to loss of suitable wetland habitats. The historical California population may have been 

eliminated by cattle grazing and trampling. Idaho bottomland habitats have been altered by 

roads, development, and conversion to agriculture and pasture lands. Timber harvest, wetland 

succession, and encroachment by non-native plants such as reed canarygrass (Phalaris 

arundinaceae) have also contributed to the decline of this species.

F.1.6.

Megaptera novaeangliae

HUMPBACK WHALE

Family: Balaenopteridae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=A02Q)

• NOAA Fisheries, 2012 

(http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/humpbackwhale.htm)

• UMMZ, 2012 
2013 VGP and sVGP BE Appendix F

F-13

Description:

Humpback whales generally have dark backs, with varying degrees of white on the flippers, 

sides and ventral regions. They often also have a number of scars (either white or black) all 

across the body. Researchers distinguish individual humpbacks by the unique black and white 

patterns on the underside of their fluke (NMFS 2005). Humpback whales are well known for 

their long "pectoral" fins, which can be up to 15 feet in length. Their scientific name, Megaptera 

novaeangliae, means "big-winged New Englander" as the New England population was the one 

best known to Europeans. These long fins give them increased maneuverability; they can be used 

to slow down or even go backwards. 

Similar to all baleen whales, adult females are larger than adult males, reaching lengths of up to 

60 feet. The maximum-recorded size for a humpback whale is 59 feet (NMFS, 2005). Humpback 

whales are the favorite of whale watchers, as they frequently perform aerial displays, such as 

breaching (jumping out of the water), or slapping the surface with their pectoral fins, tails, and 

heads.

Geographic Boundaries and Spatial Distribution:

The humpback whale is distributed worldwide in all ocean basins, though it is less common in 

Arctic waters. Humpback whales are seasonal migrants and during winter (the breeding season), 

most humpbacks are found in temperate and tropical waters of both hemispheres. In summer

(the feeding season), most are in waters of high biological productivity, usually in higher 

latitudes. There are currently four recognized stocks (based on geographically distinct winter 

ranges) of humpback whales in the U.S.: the Gulf of Maine stock (previously known as the 

western North Atlantic stock), the eastern North Pacific stock (previously known as the

California-Oregon-Washington stock), the central North Pacific stock, and the western North 

Pacific stock (NMFS, 2005).

Habitat: (no critical habitat)

Humpback whales make long migrations seasonally, swimming to polar waters in high latitudes 

in the summer and tropical waters in the low latitudes in the winter. Humpback whales are 

generally considered to inhabit waters over continental shelves, along their edges and around 

some oceanic islands. They winter in warm waters at a small number of relatively specific 

locations. Summer ranges are often relatively close to shore, including major coastal 

embayments and channels. However, humpbacks may also summer offshore, as in the Gulf of 

Alaska, or in the southern ocean, along the margin of the seasonal pack ice and in water of the 

Antarctic Convergence. Many summer habitats are apparently traditional feeding grounds, as 

evidenced by the long historic record of occupation (NMFS, 2005).

Life History:

Winters are spent mating and calving in warmer waters and summers are spent feeding in colder 

waters. The age at sexual maturity is between 4 and 7 years. The gestation period is 11 to 12 

months, with most births occurring between January and March. Females typically give birth 

once every two to three years. During the summer, humpback whales feed on schooling fish and 

other small marine animals, including sand lance, herring, capelin, and krill.
2013 VGP and sVGP BE Appendix F

F-14

Most humpbacks migrate considerable distances to high latitude summer areas, where they feed 

intensively. Calves probably learn migration routes and the location of feeding areas as they 

accompany their mothers. Major prey species are small schooling fishes (including herring, sand 

lance, capelin, mackerel, small pollock, and haddock) and large zooplankton, mainly krill. Sonar 

observations have shown humpback whales may dive as deep as 660 feet while pursuing prey. 

Humpback whales carry out the most diverse repertory of feeding behaviors known for any 

baleen whale. Among the unique feeding methods reported are: 1) use of column, clouds or nets 

of expelled bubbles to concentrate krill or fish; 2) herding, and possibly disabling, prey by 

maneuvering, flicking or pounding with the flukes and flippers; 3) using the water surface as a 

barrier to prevent the escape of prey; 4) feeding in formation (“echelon feeding”); 5) apparent 

use of acoustic cues to synchronize feeding lunges; and 6) apparent short- and long-term (multiyear) cooperation between individuals, frequently mature females without calves (NMFS, 2005).

Historical Information:

The humpback whale was first listed on June 02, 1970. It is currently designated as endangered 

in the entire range (35 FR 8491). Within the area covered by this listing, this species is known to 

occur off both coasts of the United States. Prior to commercial whaling, the worldwide 

population of humpback whales is thought to have been in excess of 125,000. American whalers 

alone killed between 14,000 and 18,000 humpbacks in the North Atlantic between 1805 and 

1907. In addition, a total of approximately 28,000 humpbacks were killed in the North Pacific. 

Currently, it is estimated that the U.S. population of humpbacks is less than 7,000 whales 

(NMFS, 2005).

Conservation Status:

The world population of humpback whales in the mid-1980s was estimated at 9,500-10,000, 

though census data were incomplete (NMFS, 1985); subsequent estimates indicate a total 

population about twice this size. Various estimates in the 1980s placed the North Pacific 

population at 600-2,500 (IUCN, 1991). With protection, some populations are showing signs of 

recovery, but populations remain far below pre-exploitation levels.

Summary of Major Threats:

Humpbacks can become entangled in fishing gear, either swimming off with the gear or 

becoming anchored. NOAA Fisheries has observed "incidental take" of humpback whales in the 

California/Oregon swordfish and thresher shark drift gillnet fishery. Potential entanglement from 

gear from several fisheries can occur on their long migration from Hawaii to Alaska. Humpbacks 

in Hawaii have been observed entangled in longline gear, crab pots, and other non-fisheryrelated lines.

Whale watching vessels may stress or even strike whales. The Gulf of Maine stock is the focus 

of whale watching in New England from late spring to early fall, particularly within the 

Stellwagen Bank National Marine Sanctuary. The central North Pacific stock is the focus of a 

whale-watching industry on their wintering grounds in the Hawaiian Islands. The feeding

aggregation in southeast Alaska is also the focus of a developing whale-watching industry that 

may impact whales in localized areas.
2013 VGP and sVGP BE Appendix F

F-15

Shipping channels, fisheries, and aquaculture may occupy or destroy humpback whale 

aggregation areas. Recreational use of marine areas, including resort development and increased 

boat traffic, may displace whales that would normally use that area. In Hawaii, acoustic impacts 

from vessel operation, oceanographic research using active sonar, and military operations are 

also of increasing concern.

F.1.7.

Oncorhynchus keta

CHUM SALMON (Hood Canal summer-run)

Family: Salmonidae

Threatened: All naturally spawned populations in the Columbia R. and its tributaries (OR, WA) 

and Columbia River and all naturally spawned summer-run populations in Hood 

Canal and its tributaries and Olympic Peninsula rivers between Hood Canal and 

Dungeness Bay (WA)

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=E09Q)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Oncorhynchus+

keta)

• NOAA Fisheries, 2012 (http://www.nmfs.noaa.gov/pr/species/fish/chumsalmon.htm)

• UMMZ, 2012 

• USEPA, 2009

Description:

Chum salmon grow to be among the largest of Pacific salmon, second only to Chinook salmon in 

adult size, with individuals reported up to 3.5 feet in length and 46 lb. in weight. Average size for 

the species is around 8 to 15 lb. The species is best known for the enormous canine-like fangs 

and striking body color (a calico pattern, with the anterior two-thirds of the flank marked by a 

bold, jagged, reddish line and the posterior third by a jagged black line) of spawning males. 

Females are less flamboyantly colored and lack the extreme dentition of the males. 

Geographic Boundaries and Spatial Distribution:

The species has the widest natural geographic and spawning distribution of any Pacific salmonid, 

primarily because its range extends farther along the shores of the Arctic Ocean than that of the 

other salmonids. Spawning populations are known from Korea and Japan and into the far north 

of Russia. Historically, in North America, chum salmon were distributed throughout the coastal 

regions of western Canada and the United States, as far south as Monterey, California. Presently, 

major spawning populations are found only as far south as Tillamook Bay on the northern 

Oregon coast.

The Hood Canal summer-run includes all naturally spawned populations of summer-run chum 

salmon in Hood Canal and its tributaries as well as populations in Olympic Peninsula rivers 

between Hood Canal and Dungeness Bay, Washington (64 FR 14508). Eight artificial 
2013 VGP and sVGP BE Appendix F

F-16

propagation programs are considered as part of the Hood Canal summer-run: the Quilcene 

National Fish Hatchery, Hamma Hamma Fish Hatchery, Lilliwaup Creek Fish Hatchery, Union 

River/Tahuya, Big Beef Creek Fish Hatchery, Salmon Creek Fish Hatchery, Chimacum Creek 

Fish Hatchery, and the Jimmycomelately Creek Fish Hatchery summer-run chum hatchery 

programs. NMFS determined that these artificially propagated stocks are no more divergent 

relative to the local natural population(s) than what would be expected between closely related 

natural populations within the species. 

Habitat: (has critical habitat)

Chum salmon spend most of their lives (2-7 years, usually 3-5 years) in the ocean. Adults return 

to spawn in streams where they hatched, sometimes moving up to 1,200 miles upstream in rivers 

lacking major barriers in Alaska and Canada but usually spawning not far from salt water 

(usually within 60 miles). Spawning occurs in gravel riffles in rivers and streams of various 

sizes. The female digs a redd, or nest, by displacing gravel and making depressions in an area of 

about 24 feet2 (Moyle, 1976).

Critical habitat for this species was designated on September 2, 2005 (70 FR 52630). Hood 

Canal summer-run chum salmon have primary constituent elements of: (1) Freshwater spawning, 

(2) freshwater rearing, (3) freshwater migration, (4) estuarine areas free of obstruction, (5) 

nearshore marine areas free of obstructions, and (6) offshore marine areas with good water 

quality. The physical or biological features that characterize these sites include water quality and 

quantity, natural cover, forage, adequate passage conditions, and floodplain connectivity.

Of 17 sub-basins reviewed in NMFS’ assessment of critical habitat for the Hood Canal chum 

salmon Evolutionarily Significant Unit (ESU), 14 sub-basins were rated as having a high 

conservation value, while only three were rated as having a medium value to the conservation. 

Limiting factors identified for this species include: (1) Degraded floodplain and mainstem river 

channel structure, (2) degraded estuarine water quality conditions and loss of estuarine habitat, 

(3) riparian area degradation and loss of in-river wood in mainstem, (4) excessive sediment in 

spawning gravels, and (5) reduced stream flow in migration areas. These conditions also 

introduce sediment, nutrients, biocides, metals, and other pollutants into surface and ground 

water and degrade water quality in the freshwater, estuarine, and coastal ecosystems throughout 

the Pacific Northwest.

Life History:

In order to mate, chum salmon adults migrate from a marine environment into the freshwater 

streams and rivers of their birth (called anadromy). They spawn only once and then die (called 

semelparity). Unlike most species that rear extensively in fresh water, chum salmon form 

schools, presumably to reduce predation. Most chum salmon mature and return to their birth 

stream to spawn between 3 and 5 years of age, with 60 to 90 percent of the fish maturing at 4 

years of age. The species has only a single form (sea-run) and does not reside in fresh water. As 

the time for migration to the sea approaches, juvenile chum salmon lose their parr marks (vertical 

bars and spots useful for camouflage). They then gain the dark back and light belly coloration 

used by fish living in open water. They seek deeper water and avoid light; their gills and kidneys 

begin to change so that they can process salt water. Chum salmon feed on insects and marine 
2013 VGP and sVGP BE Appendix F

F-17

invertebrates while in rivers. As adults, their diet consists of copepods, fish, mollusks, squid and 

tunicates.

The Hood Canal summer-run chum salmon are defined in the Salmon and Steelhead Stock 

Inventory (WDF, WDW et al., 1993) as fish that spawn from mid-September to mid-October. 

However, summer chum have been known to enter natal rivers in late August. Fall-run chum 

salmon are defined as fish that spawn from November through December or January. Run-timing 

data for as early as 1913 indicated temporal separation between summer and fall chum salmon in 

Hood Canal (Johnson, Grant et al., 1997). Hood Canal summer chum salmon are genetically 

distinct from healthy populations of Hood Canal fall chum salmon originating within this area. 

Hood Canal summer chum salmon return to natal rivers to spawn during the August through 

early October period. The fall chum salmon spawn between November and December, when 

streams are higher and water temperature is lower.

The time to hatching varies among populations and among individuals within a population (Salo,

1991). Fry tend to emerge when they had their best chances of surviving in streams and estuaries 

(Koski, 1975). A variety of factors may influence the time to hatching, emergence from the 

gravel, or both. They include dissolved oxygen, gravel size, salinity, nutritional conditions, 

behaviour of alevins in the gravel and incubation temperature [reviewed in (Bakkala, 1970; 

Schroder, Koski et al. 1974; Schroder, 1977; Salo, 1991)]. The average residence time in 

estuaries for Hood Canal chum salmon is 23 days. Fry in Hood Canal have not been observed to 

display daily tidal migrations (Bax, 1983). Fry movement is associated with prey availability. 

Summer-run chum salmon migrate up the Hood Canal and into the main body of Puget Sound. 

Fish may emerge from streams over an extended period or juveniles may also remain in Quilcene 

Bay for several weeks.

Historical Information:

Historically, chum salmon were distributed throughout the coastal regions of western Canada 

and the U.S. Presently, major spawning populations are found only as far south as Tillamook 

Bay on the northern Oregon coast. Chum salmon may historically have been the most abundant 

of all Pacific salmonids. Seven of 16 historical spawning populations in the Hood Canal 

Summer-run ESU are extinct. Recently some of these populations have shown encouraging 

increases in numbers, but the 2005 status review report shows that the population trend overall is 

a 6% decline per year. In the Columbia River, historical populations reached hundreds of 

thousands to a million adults each year. In the past 50 years, the average has been a few thousand

a year. Currently, it is thought that 14 of the 16 spawning populations in the Columbia River 

ESU are extinct. About 500 spawners occur in the ESU presently, and the long-term trend is flat.

Conservation Status:

Hood Canal summer-run chum salmon were listed as threatened on March 25, 1999, and 

reaffirmed as threatened on June 28, 2005 (70 FR 37160). Adult returns for some populations in 

the Hood Canal summer-run chum salmon species showed modest improvements in 2000, with 

upward trends continuing in 2001 and 2002. The recent five-year mean abundance is variable 

among populations in the species, ranging from one fish to nearly 4,500 fish. Hood Canal 

summer-run chum salmon are the focus of an extensive rebuilding program developed and 

implemented since 1992 by the state and tribal co-managers. Two populations (the combined 
2013 VGP and sVGP BE Appendix F

F-18

Quilcene and Union River populations) are above the conservation thresholds established by the 

rebuilding plan. However, most populations remain depressed. Estimates of the fraction of 

naturally spawning hatchery fish exceed 60% for some populations. This indicates that 

reintroduction programs are supplementing the numbers of total fish spawning naturally in 

streams. Long-term trends in productivity are above replacement for only the Quilcene and 

Union River populations. Buoyed by recent increases, seven populations are exhibiting shortterm productivity trends above replacement.

Of an estimated 16 historical populations in the ESU, seven populations are believed to have 

been extirpated or nearly extirpated. Most of these extirpations have occurred in populations on 

the eastern side of Hood Canal, generating additional concern for ESU spatial structure. The 

widespread loss of estuary and lower floodplain habitat are a continuing threat to ESU spatial 

structure and connectivity. There is some concern that the Quilcene hatchery stock is exhibiting 

high rates of straying, and may represent a risk to historical population structure and diversity. 

However, with the extirpation of many local populations, much of this historical structure has 

been lost, and the use of Quilcene hatchery fish may represent one of a few remaining options for 

Hood Canal summer-run chum salmon conservation.

Summary of Major Threats:

Chum salmon, like the other salmon NMFS has listed, have declined under the combined effects 

of overharvests in fisheries; competition from fish raised in hatcheries and native and non-native 

exotic species; dams that block their migrations and alter river hydrology; gravel mining that 

impedes their migration and alters the dynamics of the rivers and streams that support juveniles; 

water diversions that deplete water levels in rivers and streams; destruction or degradation of 

riparian habitat that increase water temperatures in rivers and streams sufficient to reduce the 

survival of juvenile chum salmon; and land use practices (logging, agriculture, urbanization) that 

destroy or alter wetland and riparian ecosystems. The above activities and features also introduce 

sediment, nutrients, biocides, metals, and other pollutants into surface and ground water and 

degrade water quality in the freshwater, estuarine, and coastal ecosystems throughout the Pacific 

Northwest.

F.1.8. STEELHEAD SALMON

Oncorhynchus mykiss

(Puget Sound)

Family: Salmonidae

Endangered: southern California coast

Threatened: Upper Willamette River, upper Columbia River Basin, central California coast, 

south central California coast, Central Valley California, lower Columbia River, 

middle Columbia River, northern California, and Snake River Basin

Under Review: Klamath Mountains Province

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=E08D)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Oncorhynchus+

mykiss)
2013 VGP and sVGP BE Appendix F

F-19

• NOAA Fisheries, 2012 (http://www.nmfs.noaa.gov/pr/species/fish/steelheadtrout.htm)

• UMMZ, 2012 

• USEPA, 2009

Description:

Steelhead trout can reach up to 55 pounds in weight and 45 inches in length, though average size 

is much smaller. They are usually dark-olive in color, shading to silvery-white on the underside 

with a heavily speckled body and a pink to red stripe running along their sides. They are a unique 

species; individuals develop differently depending on their environment. While all 

Oncorhynchus mykiss hatch in gravel-bottomed, fast-flowing, well-oxygenated rivers and 

streams, some stay in fresh water all their lives. These fish are called rainbow trout. The 

steelhead that migrate to the ocean develop a slimmer profile, become more silvery in color, and 

typically grow much larger than the rainbow trout that remain in fresh water.

Geographic Boundaries and Spatial Distribution:

In the United States, steelhead trout are found along the entire Pacific Coast. Worldwide, 

steelhead are naturally found in the Western Pacific south through the Kamchatka peninsula. 

They have been introduced worldwide.

Puget Sound steelhead occupy river basins of the Strait of Juan de Fuca, Puget Sound, and Hood 

Canal, Washington. Included are river basins as far west as the Elwha River and as far north as 

the Nooksack River. Puget Sound's fjord-like structure may affect steelhead migration patterns. 

For example, some populations of coho and Chinook salmon, at least historically, remained 

within Puget Sound and did not migrate to the Pacific Ocean. Even when Puget Sound steelhead 

migrate to the high seas, they may spend considerable time as juveniles or adults in the protected 

marine environment of Puget Sound. This is a feature not readily accessible to steelhead from 

other areas of the Pacific Northwest. The species is primarily composed of winter steelhead but 

includes several stocks of summer steelhead, usually in subbasins of large river systems and 

above seasonal hydrologic barriers.

Habitat: (no critical habitat)

Steelhead are capable of surviving in a wide range of temperature conditions. They do best 

where dissolved oxygen concentration is at least 7 parts per million. In streams, deep lowvelocity pools are important wintering habitats. Anadromous populations occur in coastal rivers. 

Resident populations now inhabit small headwater streams, large rivers, lakes, or reservoirs; 

often in cool clear lakes and cool swift streams with silt-free substrate. In streams, deep low 

velocity pools are important wintering habitats (Sublette et al. 1990). 

Steelhead usually require a gravel stream riffle for successful spawning. Lake populations move 

to tributaries to spawn. Eggs are laid in gravel in a depression made by the female. Salinity of 8 

ppt is the upper limit for normal development of eggs and alevins (Morgan et al., 1992).

Critical habitat has not yet been determined for the Puget Sound steelhead trout.
2013 VGP and sVGP BE Appendix F

F-20

Life History:

Steelhead typically migrate to marine waters after spending 2 years in freshwater. They then 

reside in marine waters for 2 to 3 years prior to returning to their natal stream to spawn as 4- or 

5-year-olds. Depending on water temperature, steelhead eggs may incubate in redds for 1.5 to 4 

months before hatching as alevins (larval stage dependent on yolk sac as food). Following yolk 

sac absorption, alevins emerge from the gravel as young juveniles (fry) and begin actively 

feeding. Juveniles rear in freshwater from 1 to 4 years, then migrate to the ocean as smolts.

Biologically, steelhead can be divided into two reproductive ecotypes, based on their state of 

sexual maturity at the time of river entry and the duration of their spawning migration. These two 

ecotypes are termed “stream maturing” and “ocean maturing.” Stream maturing steelhead return 

to freshwater in a sexually immature condition and require several months to mature and spawn. 

Ocean maturing steelhead enter freshwater with well-developed gonads and spawn shortly after 

river entry. These two reproductive ecotypes are more commonly referred to by their season of 

freshwater entry (e.g., summer and winter steelhead).

In lakes, the species feeds mostly on bottom-dwelling invertebrates (e.g., aquatic insects, 

amphipods, worms, fish eggs, sometimes small fish) and plankton. In streams, the species feeds 

primarily on drift organisms. They may also ingest aquatic vegetation (probably for attached 

invertebrates). Their diet changes seasonally. In the ocean, the diet consists of fishes and 

crustaceans.

Historical Information:

Historically, steelhead likely inhabited most coastal streams in Washington, Oregon, and 

California, as well as many inland streams in these states and Idaho. However, during the 20th

century, over 23 indigenous, naturally reproducing stocks of steelhead are believed to have been 

extirpated, and many more are thought to be in decline in numerous coastal and inland streams.

In 1994, NMFS received a petition to list steelhead throughout its range in California, Oregon, 

Washington, and Idaho under the Endangered Species Act (ESA). On January 5, 2006, NMFS 

listed nine Distinct Population Segments (DPSs) of west coast steelhead as threatened and one as 

endangered. Some of them had been previously listed between 1996 and 1998, but, because of 

legal and other issues, all listings were reaffirmed and/or revised in 2006.

Puget Sound steelhead were listed as a threatened species on May 11, 2007 (72 FR

26722). Run size was calculated in the early 1980s at about 100,000 winter-run fish and 20,000 

summer-run fish. It is unclear what portion were hatchery fish. However, a combined estimate 

with coastal steelhead suggested that roughly 70% of steelhead in ocean runs were of hatchery 

origin. The percentage in escapement to spawning grounds would be substantially lower due to 

differential harvest and hatchery rack returns. By the 1990s, total run size for four major stocks 

exceeded 45,000, roughly half of which was natural escapement.

Conservation Status:

Nehlsen et al. (1997) identified nine Puget Sound steelhead stocks at some degree of risk or 

concern. The WDFW et al. (1993) estimated that 31 of 53 stocks were of native origin and 

predominantly natural production. The WDFW assessment of the status of these 31 stocks was 
2013 VGP and sVGP BE Appendix F

F-21

11 healthy, three depressed, one critical, and 16 of unknown status. Their assessment of the 

status of the remaining (not native/natural) stocks was three healthy, 11 depressed, and eight of 

unknown status.

Of the 21 populations in the Puget Sound ESU reviewed by Busby et al. (1996), 17 had declining 

and four had increasing trends, with a range from 18% annual decline (Lake Washington winterrun steelhead) to 7% annual increase (Skykomish River winter-run steelhead). Eleven of these 

trends (nine negative, two positive) were significantly different from zero. These trends were for 

the late-run naturally produced component of winter-run steelhead populations. No adult trend 

data were available for summer-run steelhead. Most of these trends were based on relatively 

short data series. The Skagit and Snohomish River winter-run populations have been 

approximately three to five times larger than the other populations in the DPS, with average 

annual spawning of approximately 5,000 and 3,000 total adult spawners, respectively. These two 

basins exhibited modest overall upward trends at the time of the (Busby et al., 1996) report. 

(Busby et al., 1996) estimated five-year average natural escapements for streams with adequate 

data range from less than 100 to 7,200, with corresponding total run sizes of 550 to 19,800.

Summary of Major Threats:

Declines in winter steelhead stocks from the Siuslaw River north to Tillamook Bay, Oregon, may 

have resulted from deterioration of ocean feeding conditions, widespread use of hatchery stock, 

predation by marine mammals, and ocean drift-net fishing (Nehlsen et al., 1991). Declining 

winter catches on the Illinois River (tributary to the Rogue River), Oregon, since the mid-1970s 

have been attributed to water withdrawal for irrigation (Nehlsen et al., 1991). In the Columbia 

River basin, winter stocks are threatened by habitat degradation, main stem passage problems, 

and interactions with hatchery fish (Nehlson et al., 1991). Declines in several winter populations 

in the Puget Sound area of Washington have resulted from habitat degradation (e.g., water 

quality problems, siltation, and sedimentation); predation by sea lions has been reported as a 

problem for the Lake Washington population (Nehlsen et al., 1991). Whirling disease has caused 

population declines in some areas. The disease is caused by a protozoan pathogen (inadvertently 

introduced from Europe) and involves tubifex worms as an alternate host.

F.1.9. CHINOOK SALMON

Oncorhynchus tshawytscha

(Puget Sound)

Family: Salmonidae

Endangered: Sacramento River (winter-run), and Upper Columbia (spring-run)

Threatened: California coastal, Snake River (fall, spring/summer run), Central Valley (springrun), upper Willamette River, Puget Sound, lower Columbia River 

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=E06D)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Oncorhynchus+t

shawytscha)

• NOAA Fisheries, 2012 (http://www.nmfs.noaa.gov/pr/species/fish/chinooksalmon.htm)
2013 VGP and sVGP BE Appendix F

F-22

• UMMZ, 2012 

• USEPA, 2009

Description:

Chinook salmon are easily distinguished from other Oncorhynchus species by their large size. 

Adults weighing over 120 pounds have been caught in North American waters. Chinook salmon 

are very similar to coho salmon in appearance while at sea (blue-green back with silver flanks), 

except for their large size, small black spots on both lobes of the tail, and black pigment along 

the base of the teeth.

Of the Pacific salmon species, Chinook salmon exhibit one of the most diverse and complex life 

history strategies. Chinook salmon are generally described as one of two races, within which 

there is substantial variation. One form, the “stream-type” resides in freshwater for a year or 

more following emergence from gravel nests. Another form, the “ocean-type” migrates to the 

ocean within their first year. The ocean-type typifies populations north of 56oN (Healey, 1991). 

Within each race, there is often variation in age at seaward migration, age of maturity, timing of 

spawning migrations, male precocity, and female fecundity.

Geographic Boundaries and Spatial Distribution:

Native range includes the Pacific Ocean and tributary drainages, in North America presently 

from the Sacramento-San Joaquin system (sometimes farther south) north to Point Hope, Alaska, 

and in northeastern Asia, from northern Japan to the Anadyr River. The species has been widely 

stocked elsewhere.

The boundaries of the Puget Sound Evolutionarily Significant Unit (ESU) correspond generally 

with the boundaries of the Puget Lowland Ecoregion. The Puget Lowland Ecoregion begins in 

Washington at approximately the Dungeness River near the eastern end of the Strait of Juan de 

Fuca and extends through Puget Sound to the British Columbia border and up to the Cascade 

foothills. The Puget Sound ESU includes all runs of Chinook salmon in the Puget Sound region 

from the North Fork Nooksack River to the Elwha River on the Olympic Peninsula. This ESU is 

comprised of 31 historical populations. Of these, 22 populations are believed to be extant. 

Thirty-six hatchery populations were included as part of the ESU, and five were considered 

essential for recovery and listed. They include spring Chinook salmon from Kendall Creek, the 

North Fork Stillaguamish River, White River, and Dungeness River, and fall run fish from the 

Elwha River.

Habitat: (has critical habitat)

Among Chinook salmon, two distinct races have evolved. One race, described as a “stream-type” 

Chinook, is found most commonly in headwater streams. Steam-type Chinook salmon have a 

longer freshwater residency, and perform extensive offshore migrations before returning to their 

natal streams in the spring or summer months. The second race is called the “ocean-type” 

Chinook, which is commonly found in coastal streams in North America. Ocean-type Chinook 

typically migrate to sea within the first 3 months of emergence, but they may spend up to a year 

in freshwater before emigrating. They also spend their ocean life in coastal waters. Ocean-type 

Chinook salmon return to their natal streams or rivers in spring, winter, fall, summer, and late-
2013 VGP and sVGP BE Appendix F

F-23

fall runs, but summer and fall runs predominate. The difference between these life history types 

is also physical, with both genetic and morphological foundations.

Juvenile steam- and ocean-type Chinook salmon have adapted to different ecological niches. 

Ocean-type Chinook salmon tend to use estuaries and coastal areas more extensively for juvenile 

rearing. The brackish water areas in estuaries also moderate physiological stress during parrsmolt 

transition. The development of the ocean-type life history strategy may have been a response to 

the limited carrying capacity of smaller stream systems and glacially scoured, unproductive 

watersheds, or a means of avoiding the impact of seasonal floods in the lower portion of many 

watersheds.

Stream-type juveniles are much more dependent on freshwater stream ecosystems because of 

their extended residence in these areas. A stream-type life history may be adapted to those 

watersheds, or parts of watersheds, that are more consistently productive and less susceptible to 

dramatic changes in water flow or that have environmental conditions that would severely limit 

the success of subyearling smolts. At the time of saltwater entry, stream-type (yearling) smolts 

are much larger, averaging 73-134 mm depending on the river system, than their ocean-type 

(subyearling) counterparts and are, therefore, able to move offshore relatively quickly.

Coast-wide, Chinook salmon remain at sea for 1 to 6 years (more commonly 2 to 4 years), with 

the exception of a small proportion of yearling males, called jack salmon, which mature in 

freshwater or return after 2 or 3 months in salt water. Ocean- and stream-type Chinook salmon 

are recovered differentially in coastal and mid-ocean fisheries, indicating divergent migratory 

routes. Ocean-type Chinook salmon tend to migrate along the coast, while stream-type Chinook 

salmon are found far from the coast in the central North Pacific. Differences in the ocean 

distribution of specific stocks may be indicative of resource partitioning and may be important to 

the success of the species as a whole.

The critical habitat for the Puget Sound Chinook can be found at (70 FR 52630). The primary 

constituent elements include:

(1) Freshwater spawning sites with water quantity and quality conditions and substrate 

supporting spawning, incubation and larval development;

(2) Freshwater rearing sites with:

i. Water quantity and floodplain connectivity to form and maintain physical habitat 

conditions and support juvenile growth and mobility;

ii. Water quality and forage supporting juvenile development; and

iii. Natural cover such as shade, submerged and overhanging large wood, log jams 

and beaver dams, aquatic vegetation, large rocks and boulders, side channels, and 

undercut banks.

(3) Freshwater migration corridors free of obstruction and excessive predation with water 

quantity and quality conditions and natural cover such as submerged and overhanging 

large wood, aquatic vegetation, large rocks and boulders, side channels, and undercut 

banks supporting juvenile and adult mobility and survival;

(4) Estuarine areas free of obstruction and excessive predation with:
2013 VGP and sVGP BE Appendix F

F-24

i. Water quality, water quantity, and salinity conditions supporting juvenile and adult 

physiological transitions between fresh- and saltwater;

ii. Natural cover such as submerged and overhanging large wood, aquatic vegetation, 

large rocks and boulders, side channels; and

iii. Juvenile and adult forage, including aquatic invertebrates and fishes, supporting 

growth and maturation.

(5) Nearshore marine areas free of obstruction and excessive predation with:

i. Water quality and quantity conditions and forage, including aquatic invertebrates and 

fishes, supporting growth and maturation; and

ii. Natural cover such as submerged and overhanging large wood, aquatic vegetation, 

large rocks and boulders, and side channels.

(6) Offshore marine areas with water quality conditions and forage, including aquatic 

invertebrates and fishes, supporting growth and maturation.

Life History:

Chinook salmon in Puget Sound generally have an “ocean-type” life history. Puget Sound 

populations exhibit both the early-returning and late-returning Chinook salmon spawners 

described by (Healey, 1997). However, within these two generalized behavioral forms, 

substantial variation occurs in juvenile behavior and residence time in fresh water and estuarine 

environments. Hayman et al. (1996) described three juvenile life histories for Chinook salmon 

with varying freshwater and estuarine residency times in the Skagit River system in northern 

Puget Sound. Chinook salmon use the nearshore area of Puget Sound during all seasons of the 

year and can be found long distances from their natal river systems (Brennan, Higgins et al., 

2004).

Historical Information:

Chinook salmon are the largest of the Pacific salmon and historically ranged from the Ventura 

River in California to Point Hope, Alaska in North America, and in northeastern Asia from 

Hokkaido, Japan to the Anadyr River in Russia (Healey 1991). In addition, Chinook salmon have 

been reported in the Canadian Beaufort Sea (McPhail and Lindsey, 1970). 

Puget Sound Chinook salmon were listed as threatened in 1999 (64 FR 14308). This status was 

re-affirmed on June 28, 2005 (70 FR 37160). This ESU has lost 15 spawning aggregations that 

were either demographically independent historical populations or major components of the life 

history diversity of the remaining 22 existing independent historical populations identified 

(Good, Waples et al., 2005). Nine of the 15 extinct spawning aggregations were early-run type 

Chinook salmon (Good, Waples et al., 2005). The disproportionate loss of early-run life history 

diversity represents a significant loss of the evolutionary legacy of the historical ESU.

Conservation Status:

Long-term trends in abundance and median population growth rates for naturally spawning 

populations of Puget Sound Chinook salmon indicate that approximately half of the populations 

are declining and the other half are increasing in abundance over the length of available time 

series. Eight of 22 populations are declining over the short-term, compared to 11 or 12 

populations that have long-term declines (Good, Waples et al., 2005). Widespread declines and 
2013 VGP and sVGP BE Appendix F

F-25

extirpations of spring- and summer-run Puget Sound Chinook salmon populations represent a 

significant reduction in the life history diversity of this ESU (Meyers, Kope et al., 1998). The 

median overall populations of long-term trend in abundance is 1, indicating that most 

populations are just replacing themselves. Populations with the greatest long-term population 

growth rate are the North Fork Nooksack and White Rivers.

Regarding spatial structure, the populations (22) presumed to be extinct are mostly early 

returning fish. Most of these are in the mid- to southern Puget Sound or Hood Canal and the 

Strait of Juan de Fuca. The ESU populations with the greatest estimated fractions of hatchery 

fish tend to be in the mid-to southern Puget Sound, Hood Canal, and the Strait of Juan de Fuca. 

Finally, all but one of the nine extinct Chinook salmon stocks is an early run population (or 

component of a population).

Summary of Major Threats:

Initial cause of decline was adverse effects of logging, mining, irrigation withdrawals, and 

overfishing, then construction of hydroelectric dams that blocked migrations and resulted in high 

mortality of smolts in turbines (Nehlsen et al., 1991, Williams et al., 1992). Spawning runs 

continue to be threatened by construction of dams and degradation of natural environment. 

Extinctions or large declines of some local native populations in recent decades may have been 

masked by releases of non-native hatchery stock (Williams et al., 1992).

Juveniles incur high mortality as they migrate through today's river systems and out to sea. 

Sources of mortality include hydroelectric turbines, mechanical bypass facilities (including 

transporation by barge or truck), and predation by non-native fishes. Gas bubble trauma (GBT) 

associated with total dissolved gas supersaturation (TDGS) at spillways also causes mortality and 

detrimental sublethal effects, but passage of juveniles through spillways may be the least 

damaging of the routes for juvenile passage at dams (Backman et al., 2002). In the Columbia 

River basin, adults were rarely observed with GBT, despite high TDGS levels (Backman and 

Evans, 2002). Concurrent with the construction of fish hatcheries, bacterial kidney disease 

became prevalent and may now play a significant role in mortality. A change in climate, 

beginning around 1977, led to poor ocean survival.

F.1.10.

Orcinus orca

KILLER WHALE

Family: Delphinidae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=A0IL)

• NOAA Fisheries, 2012 

(http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/killerwhale.htm)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Orcinus+orca)
2013 VGP and sVGP BE Appendix F

F-26

Description:

Killer whales are distinctively marked with a black back, white chest and sides, and a white 

patch above and behind the eye. Calves are born with a yellowish or orange tint that fades to 

white. Killer whales have a heavy and stocky body and a large dorsal fin with a dark grey 

"saddle patch" at the fin's rear. Males can be up to 31 feet and weigh in excess of 6.6 tons; it has 

been reported that especially large males have reached nearer 8.8 tons. Females are smaller, 

reaching up to 28 feet and a weight of about 5.5 tons. The longest killer whale ever recorded was 

a male from Washington state, measuring 32 feet. Calves at birth weigh about 400 lb. and are 

about 8 feet long. The killer whale's large size and strength make them the fastest marine 

mammals, often reaching speeds in excess of 35 mph.

In the eastern North Pacific Ocean, three distinct forms, or types, of killer whales are recognized. 

1. residents 

2. transients 

3. offshores 

The three types differ in morphology, ecology, behavior, and genetics. A recent genetic study 

suggests the transient type has been separated from all other killer whales for approximately 

750,000 years and might represent a separate species or subspecies. All three types of killer 

whales share at least part of a home range, yet they are not known to intermix with one another. 

The resident and transient types both have multiple populations within their range.

Geographic Boundaries and Spatial Distribution:

Killer whales are found throughout the world's oceans and seas, from high latitudes to the 

equator; most common in cooler coastal waters of both hemispheres, with the greatest abundance 

within 500 miles from continental coasts.

In the North Pacific Ocean, killer whales are often sighted in all parts of Alaska, including:

• Bering Sea 

• Aleutian Islands 

• Prince William Sound 

• southeastern Alaska 

They are also often sighted in other areas of the North Pacific Ocean, such as:

• nearshore and intercoastal waterways of British Columbia, Canada and Washington State 

• along the U.S. Pacific coast in Washington, Oregon, and California 

• along the Russian coast in the Bering Sea and the Sea of Okhotsk 

• on the eastern side of Sakhalin and the Kuril Islands 

In the North Atlantic Ocean, sightings of killer whales are commonly documented:

• up to the pack-ice edge in Norwegian waters and around Iceland. 

In the South Atlantic and Pacific Oceans, killer whales are frequently sighted

• along the pack ice of Antarctica 

• off the coasts 

o Patagonia 
2013 VGP and sVGP BE Appendix F

F-27

o southern Argentina 

o New Zealand 

Habitat: (has critical habitat)

Critical habitat for the Southern Resident killer whale Distinct Population Segment (DPS) 

includes the entirety of Puget Sound and Strait of Juan de Fuca. The area extends to the northern 

portion of the San Juan islands, and far south with the exception of the Hood Canal area. 

Characteristics of critical habitat could not be specified.

Life History:

Resident Killer Whales are noticeably different from both transient and offshore forms. The 

dorsal fin is rounded at the tip and curved and tapering, or "falcate". Resident whales have a 

variety of saddle patch pigmentations with five different patterns recognized. They've been 

sighted from California to Russia. They primarily eat fish. Resident killer whales in the North 

Pacific consist of the following populations:

• Southern Residents 

• Northern Residents 

• Southern Alaska Residents 

• Western Alaska North Pacific Residents 

Resident killer whales occur in large social groups termed "pods," which are defined to be 

groups of whales that are seen in association with one another greater than 50% of the time. The 

pods represent collections of matrilines (a matriarch and all her descendents), which have been 

found to be the stable social unit. In the North Pacific, the resident killer whale populations 

mainly feed on salmonids, such as Chinook salmon and chum salmon

The Southern Resident killer whale ("Southern Resident") population contains three pods (J pod, 

K pod, and L pod), considered one stock under the Marine Mammal Protection Act (MMPA) and 

as a "distinct population segment" (therefore, "species") under the Endangered Species Act 

(ESA). Their range during the spring, summer, and fall includes the inland waterways of Puget 

Sound, Strait of Juan de Fuca, and Southern Georgia Strait. Their occurrence has been 

documented in the coastal waters off of Oregon, Washington, Vancouver Island, central 

California, and Queen Charlotte Islands. Relatively little is known about the winter movements 

and range of the Southern Resident stock. Southern Residents have not been observed 

associating with other resident whales, and genetic data suggest that Southern Residents rarely, if 

ever, interbreed with other killer whale populations.

Transient Killer Whales occur throughout the eastern North Pacific, and have primarily been 

studied in coastal waters. Their geographical range overlaps that of the resident and offshore 

killer whales. The dorsal fin of transient whales tends to be more erect (straighter at the tip) than 

those of resident and offshore whales. Saddle patch pigmentation of transient killer whales is 

restricted to two patterns, and never has the large areas of black pigmentation intruding into the 

white of the saddle patch that is seen in resident and offshore types. Transient type whales are 

often found in long-term stable social units that tend to be smaller than resident social groups 

(e.g., fewer than 10 whales); these social units do not seem as permanent as matrilines are in 

resident type whales. Transient killer whales feed nearly exclusively on marine mammals. 
2013 VGP and sVGP BE Appendix F

F-28

Offshore Killer Whales are similar to resident whales, but can be distinguished generally (these 

characteristics need to be further quantified) by features such as their:

• fins, which appear more rounded at the tip with multiple nicks on the trailing edge 

• smaller overall size 

• tendency for males and females to be more similar in size (less "sexual dimorphism")

Offshore killer whales have the largest geographic range of any killer whale community in the 

northeastern Pacific and often occur 9 miles or more offshore, but also visit coastal waters and 

occasionally enter protected inshore waters. Animals typically congregate in groups of 20-75 

animals with occasional sightings of larger groups up to 200 whales. They are presumed to feed 

primarily on fish, though they have been documented feeding on sharks. It has even been 

hypothesized that they may be shark specialists, but further observations are needed to confirm 

this theory. Genetic analyses indicate that offshore killer whales are reproductively isolated from 

other forms.

Sexual maturity of female killer whales is achieved when the whales reach lengths of 

approximately 15-18 feet, depending on geographic region. The gestation period for killer 

whales varies from 15-18 months, and birth may take place in any month. Calves are nursed for 

at least 1 year, and may be weaned between 1 and 2 years of age. The birth rate for killer whales 

is not well understood, but, in some populations, is estimated as every 5 years for an average 

period of 25 years.

Historical Information:

In November 2005, the Southern Resident killer whale Distinct Population Segment (DPS) was 

listed as endangered under the ESA (70 FR 69903). Little information is available on the 

historical abundance of killer whales worldwide. Nevertheless, it is likely that many populations 

have declined significantly since 1800 in response to greatly diminished stocks of fish, whales, 

and pinnipeds (seals and sea lions) in the ocean. 

Conservation Status:

The population size of killer whales is difficult to measure in many areas because of their general 

scarcity as well as their widespread and often unpredictable movement patterns. During the past 

few decades, populations have been surveyed primarily through photo-identification studies and 

line-transect counts. Photo-identification catalogs for killer whales were first established in the 

early 1970s for the resident communities of Washington and British Columbia and have since 

been initiated for most areas where population studies have been undertaken. Line-transect 

surveys from ships or aircraft generally occur in large areas of open ocean where photoidentification is impractical. However, this technique cannot be used for gathering most 

demographic data, such as age of sexual maturity.

As top-level predators, killer whales occur in low densities throughout most of their geographic 

range. Densities are typically much greater in colder waters than in tropical regions. One 

estimate put the worldwide population of killer whales at over 100,000 animals. However, the 

most recent estimate revised this figure to a minimum of about 50,000 animals. In the 
2013 VGP and sVGP BE Appendix F

F-29

northeastern Pacific, from California to the western Aleutian Islands and Bering Sea, at least 

2,250-2,700 resident, transient, and offshore whales are currently thought to exist.

Summary of Major Threats:

Although all killer whales are protected under the MMPA (and some are protected under the 

ESA) and they have not been commercially hunted or captured in the past 40 years within the 

U.S. waters, historic live capture for aquarium display and culling for depredation of fisheries 

reduced some killer whale populations, especially the Southern Resident killer whale DPS. 

Today, these killer whales still face many threats caused by human activities, such as 

contaminants (e.g., PCBs), depletion of prey due to overfishing and habitat degradation, ship 

collisions, and oil spills. Additional threats may also include disturbance from such activities as 

noise from industrial and military activities, entanglement in fishing gear, and whale-watching. 

Outside U.S. waters, directed catch of killer whales still occurs, though these levels are presumed 

low.

F.1.11.

Phoebastria albatrus

SHORT-TAILED ALBATROSS

Family: Diomedeidae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=B00)

• UMMZ, 2012 

Description:

The short-tailed albatross is a large pelagic bird with long narrow wings adapted for soaring just 

above the water surface. The bill, which is disproportionately large compared to the bills of other 

northern hemisphere albatrosses, is pink and hooked with a bluish tip, with external tubular 

nostrils, and a thin but conspicuous black line extending around the base. Adult short-tailed 

albatrosses are the only North Pacific albatross with an entirely white back. The white head 

develops a yellow-gold crown and nape over several years. Fledged juveniles are dark brownblack, but soon develop the pale bills and legs that distinguish them from black-footed and 

Laysan albatrosses (Tuck 1978, Roberson, 1980).

Geographic Boundaries and Spatial Distribution:

Short-tailed albatrosses range throughout the North Pacific Ocean and north into the Bering Sea 

during the non-breeding season; breeding colonies are limited to two Japanese islands, Torishima 

and Minami-kojima. There are no breeding populations of short-tailed albatrosses in the United 

States, but several individuals have been regularly observed during the breeding season on 

Midway Atoll in the northwestern Hawaiian Islands. At-sea sightings since the 1940s indicate 

that the short-tailed albatross, while very few in number today, is distributed widely throughout 

its historical foraging range of the temperate and subarctic North Pacific Ocean and is often 

found close to the U.S. coast, including the coastal water of Oregon (UFWFS, 2000). This 
2013 VGP and sVGP BE Appendix F

F-30

species is known to occur in Alaska, California, Hawaii, Oregon, Washington, Northern Pacific 

Ocean, Japan, and Russia.

Habitat: (no critical habitat)

Available evidence from historical accounts and from current breeding sites indicates that shorttailed albatross nesting occurs on flat or sloped sites with sparse or full vegetation, and on 

isolated windswept offshore islands with restricted human access. The nest is a grass or mosslined concave scoop about 2 feet in diameter (Tickell, 1975). 

Short-tailed albatross forage at sea but specific geographic and seasonal distribution patterns 

within the marine range are not well understood. The short-tailed albatross is a frequent visitor to 

the productive waters in shelf break areas of the Northern Gulf of Alaska, Aleutians Islands, and 

Bering Sea. The marine range of the short-tailed albatross within U.S. territorial waters includes 

Alaska's vast coastal shelf break areas and the marine waters of Hawaii for foraging, but it is not 

know how much or to what extent it utilizes open ocean areas of the Gulf of Alaska, North 

Pacific Ocean, and Bering Sea. There is no specific habitat or area use patterns within the vast 

shelf break areas used by the species (USFWS, 2000).

Life History:

Short-tailed albatrosses are long-lived and slow to mature; the average age at first breeding is 6 

years old. Breeding is restricted to two small island groups, Torishima Island (approximately 

580 km south of Japan) and Minami-kojima (about 270 kilometers northeast of Taiwan) 

(USFWS, 2000). At Torishima, birds arrive at the breeding colony in October and begin nest 

building. Egg-laying begins in late October and continues through late November. The female 

lays a single egg with incubation involving both parents, and lasts for 64-65 days. Eggs hatch in 

late December and January, and by late May or early June, the chicks are almost full grown and 

the adults begin abandoning their nests (Hasegawa and DeGange, 1982). The chicks fledge soon 

after the adults leave the colony. By mid-July, the breeding colony is totally deserted (Austin 

1949). Breeding success (the percent of eggs laid that result in a fledged chick) varies between 

approximately 60 and 70 percent. Low breeding success occurs in years when catastrophic 

volcanic or weather events occur during the breeding season.

Non-breeders and failed breeders disperse from the breeding colony in late winter through spring 

(Hasegawa and DeGange, 1982). There is no detailed information on breeding activities on 

Minami-kojima, but it is likely to be similar to that on Torishima. Short-tailed albatrosses are 

monogamous and highly philopatric to nesting areas (returning to the same breeding site year 

after year). Chicks hatched at Torishima return there to breed. However, young birds may 

occasionally disperse from their natal colonies to breed, as evidenced by the appearance of adult 

birds on Midway Atoll that were banded as chicks on Torishima (Richardson, 1994).

The short-tailed albatross feeds at the water’s surface on items such as squid, fish, eggs of flying 

fish, shrimp, and other crustaceans. The birds will sometimes follow ships and feed on scraps 

and offal. Chicks are fed a mixture of stomach oil and partially digested, regurgitated food; 

nestlings are fed squid, flying fishes, large crustaceans, and similar foods (Hasegawa and 

DeGange 1982; Austin, 1949). 
2013 VGP and sVGP BE Appendix F

F-31

Historical Information:

The short-tailed albatross (Phoebastria albatrus) was first listed on June 2, 1970. It is currently 

designated as endangered (65 FR 46643) in the entire range. At the beginning of the 20th century, 

the species declined in population numbers to near extinction, primarily as a result of hunting at 

the breeding colonies in Japan. Albatross were killed for their feathers and various other body 

parts. The down feathers were used for quilts and pillows, and wing and tail feathers were used 

for writing quills; their bodies were processed into fertilizer and rendered into fat, and their eggs 

were collected for food (Austin, 1949).

Pre-exploitation worldwide population estimates of short-tailed albatrosses are not known; the 

total number of birds harvested may provide the best estimate, since the harvest drove the species 

nearly to extinction. Between approximately 1885 and 1903, an estimated five-million shorttailed albatrosses were harvested from the breeding colony on Torishima (Austin 1949), and 

harvest continued until the early 1930s. By 1949, there were no short-tailed albatrosses breeding 

at any of the historically known breeding sites, and the species was thought to be extinct (Austin 

1949). The species persisted, however, and in 1950, there were reports of nesting short-tailed 

albatross on the island of Torishima. 

Conservation Status:

Originally numbering in the millions, the current worldwide population of breeding age birds is 

approximately 1,200 individuals. Of these, the total number of breeding age birds is thought to 

be approximately 600 birds (UFWFS, 2000). The population on Tourishima Island is growing at 

a fairly rapid rate, especially given that it is a long-lived and slow-to-reproduce species. Habitat 

management within the species main nesting colony has increased its nest success rate and 

probably its population growth rate as well. Based on egg counts and breeding bird observations, 

it is estimated that there are currently approximately 267 nesting pairs on Torishima, and 40 pairs 

on Minami-kojima (Hasegawa 2002). The recent annual population growth rate is 7.5% on 

Torishima and 11% on the Senkaku Islands (COSEWIC, 2004). 

Summary of Major Threats:

The worldwide population of short-tailed albatrosses continues to be in danger of extinction 

throughout its range due to natural environmental threats, small population size, and the small 

number of breeding colonies. Longline fishing, plastics pollution, oil contamination, and airplane 

strikes are not viewed as threats to the species survival, but are considered threats to the species 

conservation and recovery (OFWO, 2003h).

F.1.12.

Salvelinus confluentus

BULL TROUT

Family: Salmonidae

Threatened: ID, MT, NV, OR and WA

Experimental Population, Non-Essential: Clackamas River subbasin and the mainstem 

Willamette River, from Willamette Falls to its points of confluence with the 

Columbia River, including Multnomah Channel
2013 VGP and sVGP BE Appendix F

F-32

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=E065)

• USFWS, 2003 (http://library.fws.gov/Pubs/bulltrt03.pdf) 

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Salvelinus+confl

uentus)

• UMMZ, 2012 

Description:

Bull trout are members of the char subgroup of the Salmonid family. Bull trout, Dolly Varden 

trout, and lake trout are species of char native to the northwest. Char species such as bull trout 

live farther north than any other group of freshwater fish except Alaskan blackfish and are well 

adapted for life in very cold water. Bull trout living in streams grow to about four pounds while 

those in lake environments can weigh more than 20 pounds. 

Biologists distinguish char from other salmonids such as trout and salmon by the absence of 

teeth in the roof of the mouth, the presence of light-colored spots on a dark background (trout 

and salmon have dark spots on a lighter background), the absence of spots on the dorsal fin, their 

smaller scales, and differences in skeletal structure. 

Geographic Boundaries and Spatial Distribution:

Bull trout exist in five distinct population segments: coastal Puget Sound, St. Mary-Belly River, 

Klamath River, Columbia River, and Jarbridge River. This species is known to occur in Idaho, 

Montana, Nevada, Oregon, and Washington.

Habitat: (has critical habitat)

Bull trout are seldom found in waters where temperatures are warmer than 15 ̊C to 18 ̊C. Besides

very cold water, bull trout require stable stream channels, clean spawning gravel, complex and 

diverse cover, and unblocked migration routes (USFWS, 2002a).

Critical habitat includes approximately 18,975 miles of streams and 488,252 acres of lakes and 

reservoirs in Idaho, Oregon, Washington, Montana and Nevada for the wide-ranging fish. In 

Washington, 754 miles of marine shoreline are included in the final designation. These lands 

include complex habitats, streams with riffles and deep pools, undercut banks, and large logs. 

These habitats often connect to headwater streams for annual spawning and feeding migrations.

On November 29, 2002, USFWS proposed to designate critical habitat for the Klamath River and 

Columbia River bull trout populations (67 FR 71235). On October 6, 2004, USFWS finalized the 

critical habitat designation for the Klamath River and Columbia River bull trout populations (69 

FR 59995). On June 25, 2004, USFWS proposed to designate critical habitat for the Jarbidge 

River, coastal Puget Sound, and Saint Mary-Belly River bull trout populations (69 FR 35767). 

On September 26, 2005, critical habitat was designate for the Klamath River, Columbia River, 

Jarbidge River, coastal Puget Sound, and Saint Mary-Belly River populations of bull trout (70 

FR 56212). 
2013 VGP and sVGP BE Appendix F

F-33

Life History:

Small bull trout eat terrestrial and aquatic insects but shift to preying on other fish as they grow 

larger. Large bull trout are primarily fish predators. Bull trout evolved with whitefish, sculpins, 

and other trout and use all of them as food sources. In the Willamette River Basin, Chinook 

salmon are an important food source for bull trout. Adult bull trout are usually small, but can 

grow to 36 inches in length and up to 32 pounds. Bull trout reach sexual maturity at between 4 

and 7 years of age and are known to live as long as 12 years. They spawn in the fall after 

temperatures drop below 9 ̊C, in streams with abundant cold, unpolluted water, clean gravel and 

cobble substrate, and gentle stream slopes. Many spawning areas are associated with cold water 

springs or areas where stream flow is influenced by ground water. Bull trout eggs require a long 

incubation period compared with other salmon and trout, hatching in late winter or early spring.

Fry may remain in the stream gravels for up to 3 weeks before emerging (USFWS, 2002a).

Four life-history forms of char are recognized, each exhibiting a specific behavioral or life 

history pattern (Brown 1994). Resident fish live their whole lives near areas where they were 

spawned. Migratory fish are usually spawned in small headwater streams and then migrate to 

larger streams or rivers (fluvial), lakes or reservoirs (adfluvial), or salt water (anadromous) 

where they grow to maturity. Smaller resident fish remain near the areas where they were 

spawned in smaller, high elevation streams and seldom reach size of over 12 inches (Brown,

1994; USFWS, 2002a). Larger, migratory fish will move considerable distances to spawn when 

habitat conditions allow. For instance, bull trout in Montana's Flathead Lake have been known to 

migrate up to 150 miles to spawn (USFWS, 2002a).

Historical Information:

Bull trout are native throughout the Pacific Northwest. Historically bull trout occurred 

throughout the Columbia River Basin, east to western Montana, south to the Jarbidge River in 

northern Nevada, the Klamath Basin in Oregon, and the McCloud River in California, and north 

to Alberta, British Columbia, and possibly southeastern Alaska. It was first listed on June 10, 

1998. It is currently designated as threatened (64 FR 58909) in the lower 48 states. 

Conservation Status:

Today bull trout are found primarily in upper tributary streams and several lake and reservoir 

systems. They have been eliminated from or their numbers reduced in the main stems of most 

large rivers. The main populations remaining in the lower 48 states are in Montana, Idaho, 

Oregon, and Washington with a small population in northern Nevada. Bull trout no longer occur 

in northern California.

Summary of Major Threats:

Bull trout are vulnerable to many of the same threats that have reduced salmon populations. 

Because of their need for very cold waters and long incubation time, bull trout are more sensitive 

to increased water temperatures, poor water quality, and degraded stream habitat than many 

other salmonids. Further threats to bull trout include hybridization and competition with 

nonnative brook trout, brown trout, and lake trout; overfishing; poaching; and man-made 

structures that block migration (USFWS, 2002a).
2013 VGP and sVGP BE Appendix F

F-34

In many areas, continued survival of the species is threatened by a combination of factors rather 

than one major factor. For example, past and continuing land management activities have 

degraded stream habitat, especially along larger river systems and streams located in valley 

bottoms. Degraded conditions have severely reduced or eliminated migratory bull trout as water 

temperature, stream flow, and other water quality parameters fall below the range of conditions 

that these fish can tolerate. In many watersheds, remaining bull trout are smaller, resident fish 

isolated in headwater streams. Brook trout, introduced throughout much of the range of bull 

trout, easily hybridize with them, producing sterile offspring. Brook trout also reproduce earlier 

and at a higher rate than bull trout, so bull trout populations are often supplanted by these nonnatives. Dams and other instream structures also affect bull trout by blocking migration routes, 

altering water temperatures, and killing fish as they pass through and over dams or are trapped in 

irrigation and other diversion structures (USFWS, 2002a).

F.1.13.

Spiranthes diluvialis

UTE LADIES’-TRESSES

Family: Orchidaceae

Threatened: wherever found

Sources: 

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q2WA)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Spiranthes+diluv

ialis)

Description:

Ute ladies’-tresses is a perennial herb with erect, glandular-pubescent stems 5-24 inches tall 

arising from tuberous-thickened roots. Basal leaves are narrowly linear, up to 0.5 inches wide 

and 11 inches long, and persist at the time of flowering. Leaves become progressively smaller up 

the stem. The inflorescence is a sparsely pubescent 1-6 inches long spike of numerous small 

white or ivory-colored flowers arranged in a gradual spiral. Individual flowers are 0.3-0.6 inches 

long and faintly fragrant (with a vanilla-like scent). The lip petal is oval to lance-shaped, 

narrowed at the middle, and has crispy-wavy margins. Sepals are separate or fused only at the 

base (not fused into a hood-like structure) and are often spreading at their tips. Fruits are 

cylindric capsules with numerous seeds. 

Geographic Boundaries and Spatial Distribution:

The species occurs in Colorado, Idaho, Montana, Nebraska, Nevada, Utah, Washington, and 

Wyoming. More specifically it is known from northern and south-central Utah, central to northcentral and northwestern Colorado, east-central and southeastern Wyoming, eastern Idaho, 

southwestern Montana, eastern Nevada, western Nebraska, and central to north-central 

Washington (Fertig et al., 2005); as well as British Columbia, where recently discovered (J. 

Penny, pers. comm. 2008). 
2013 VGP and sVGP BE Appendix F

F-35

Habitat: (no critical habitat)

Ute ladies’-tresses occupy various habitat types including: (1) alluvial banks, point bars, 

floodplains, or ox-bows associated with perennial streams, with a high water table and short, 

perennial graminoid- and forb-dominated vegetation maintained by grazing, periodic flooding, or 

mowing; (2) river floodplain habitats which experience regular spring flooding and/or frequent 

large scale floods but maintain relatively stable, moist to wet soil in summer, within moist 

meadow, riparian woodland, or riparian shrubland communities; (3) shores of lakes and 

reservoirs, in mesic meadow-type vegetation maintained by lake level fluctuations or seasonal 

flooding of gravel bars; (4) groundwater-fed springs, sometimes in desert settings, or subirrigated meadows where edaphic characteristics (e.g. high water table and calcic soil), fire, 

and/or grazing are sufficient to prevent invasion of later seral vegetation; and (5) humaninfluenced habitats, including perennial stream, river, lakeshore, and spring sites directly 

associated with human-developed dams, levees, reservoirs, irrigation ditches, reclaimed gravel 

quarries, roadside barrow pits, and irrigated meadows. More than half of documented 

populations occur in sites in which natural hydrology has been influenced by dams, reservoirs, or 

supplemental irrigation, and many populations occur within agricultural or urban settings (Fertig 

et al., 2005).

The riparian areas where it’s found are most concisely characterized as medium-to-large streams 

and rivers of moderate gradient (not slow and meandering), generally near the edge of the 

mountains or somewhat out onto the plains. It does not occur in dense shrub patches, although it 

can occur in small grassy openings. Soil must be moist on the surface throughout the growing 

season. This moisture level is usually maintained by capillary fringe from the water table. 

Life History:

Spiranthes diluvialis is a long-lived perennial herb that probably reproduces exclusively by seed. 

The orchid can produce as many as 7300 tiny seeds per fruit. Seedlings may persist for up to 8 

years as subterranean saprophytes dependent on mycorrhizal fungi. Small, inconspicuous leaf 

rosettes may emerge at the end of the growing season and overwinter. It flowers in August to 

early September and is often not in full flower until mid-August. Individual plants may not 

flower in consecutive years or under adverse environmental conditions and may persist below 

ground with their mycorrhizal symbionts. Life expectancy for at least one Spiranthes species has 

been estimated at more than 50 years.

Historical Information:

When Ute ladies’-tresses was listed in 1992 it was known primarily from moist meadows 

associated with perennial stream terraces, floodplains, and oxbows at elevations between 4,300-

6,850 feet. Surveys since 1992 have expanded the number of vegetation and hydrology types 

occupied by Ute ladies’-tresses to include seasonally flooded river terraces, sub-irrigated or 

spring-fed abandoned stream channels and valleys, and lakeshores. In addition, 26 populations 

have been discovered along irrigation canals, berms, levees, irrigated meadows, excavated gravel 

pits, roadside barrow pits, reservoirs, and other human-modified wetlands. New surveys have 

also expanded the elevational range of the species from 720-1,830 feet in Washington to 7,000 

feet in northern Utah. Over one-third of all known Ute ladies’-tresses populations are found on 

alluvial banks, point bars, floodplains, or ox-bows associated with perennial streams.
2013 VGP and sVGP BE Appendix F

F-36

Conservation Status:

Recognizing that most annual survey data underestimates the number of dormant, vegetative, and 

fruiting plants, the maximum number of flowering plants observed over a multi-year period of 

monitoring can be used to estimate total population size. Based on the maximum number of 

plants reported for each known occurrence since 1985, the total range-wide number is estimated 

as at least 83,316 plants (Fertig et al. 2005). However, most occurrences are relatively small, in 

terms of both number of plants and area occupied. Of all extant occurrences, 39% contain fewer 

than 100 plants and 81% have less than ,1000 individuals; in addition, nearly 66% of all known 

occurrences are reported from areas of 0.1-10 acres, while only 5% occupy more than 50 acres 

(Fertig et al., 2005).

Population monitoring studies in Colorado and Utah have projected long-term declines if not 

extirpations in both riparian corridor and wet meadow settings and under current land use 

practices without conservation intervention. In Idaho, long-term monitoring has detected local 

extirpation of subpopulations as habitat condition deteriorates through flooding or vegetative 

succession. Nevertheless, new monitoring and demographic research have documented that 

populations are more stable than originally suspected because most past monitoring studies had 

focused on counts of flowering plants, which are more likely to fluctuate than counts that include 

more cryptic vegetative, fruiting, and dormant plants (Fertig et al., 2005). Most of the multi-year 

monitoring studies based on flowering plants exhibit an oscillating trend, alternating between 

periods of increase and decrease around a relatively stable mean (Fertig et al., 2005). This 

species also appears more tolerant of human-induced disturbances than originally supposed, 

based on the discovery of additional populations in significantly human-modified habitats (Fertig 

et al., 2005). 

Summary of Major Threats:

In 1992, the U.S. Fish and Wildlife Service identified habitat loss and modification (through 

urbanization, water development, and conversion of wetlands to agriculture), overcollection, 

competition from exotic weeds, and herbicides as the main current and potential threats to the 

long term survival of Ute ladies’-tresses. Since 1992, other threats have been identified including 

impacts from recreation; mowing for hay production, (mowing, especially in conjunction with 

winter grazing, can have positive effects on Ute ladies’-tresses by reducing competing vegetative 

cover and protective cover for voles); grazing by cattle or horses; hydrology change 

(modification of wetland habitats through development, flood control, de-watering, and other 

changes to hydrology); herbivory by native wildlife (particularly voles); reduction in the number 

and diversity of insect pollinators; drought; absence or rarity of mycorrhizal symbionts; and 

conflicting management with other rare species.

F.1.14.

Ursus arctos horribilis

GRIZZLY BEAR

Family: Ursidae

Threatened: lower 48 States, except where listed as an experimental population or delisted

Status Undefined: AK
2013 VGP and sVGP BE Appendix F

F-37

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=A001)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?sourceTemplate=tabular_repor

t.wmt&loadTemplate=species_RptComprehensive.wmt&selectedReport=RptComprehen

sive.wmt&summaryView=tabular_report.wmt&elKey=102187&paging=home&save=tru

e&startIndex=1&nextStartIndex=1&reset=false&offPageSelectedElKey=102187&offPag

eSelectedElType=species&offPageYesNo=true&post_processes=&radiobutton=radiobutt

on&selectedIndexes=102187&selectedIndexes=742339&selectedIndexes=777433&selec

tedIndexes=777441)

• USEPA, 2010

Description:

Grizzly bears reach weights of 400-1,500 lb. The male is on average 1.8 times as heavy as the 

female, an example of sexual dimorphism. Their coloring ranges widely across geographic areas, 

from blond to deep brown or black. These differences, once attributed to subspeciation, are now 

thought to be primarily due to the different environments these bears inhabit, particularly with 

regard to diet and temperature. The grizzly has a large hump over the shoulders which is a 

muscle mass used to power the forelimbs in digging. The head is large and round with a concave 

facial profile. In spite of their massive size, these bears can run at speeds of up to 35 mph. 

Geographic Boundaries and Spatial Distribution:

In North America, present range includes Alaska, northern and western Canada, northern 

Continental Divide in Montana, Cabinet/Yaak mountains in Montana/Idaho, Selkirk Mountains 

in Idaho/Washington, Northern Cascades in Washington, and Yellowstone area, 

Wyoming/Montana/Idaho. Some bears in the Cabinet-Yaak ecosystem of Montana and Idaho 

and Selkirk ecosystem of Idaho and Washington mingle in the Purcell Mountains in southern 

British Columbia, and movement data indicate that the Cabinet-Yaak and Selkirk populations are 

connected to a much larger population (several hundred bears) extending north into British 

Columbia (USFWS, 1999). However, the listed Distinct Population Segment (DPS) is confined 

to the U.S. portion of these ecosystems. Common only in Alaska, parts of the Yukon, northern 

and coastal British Columbia, and portions of the northern Rocky Mountains. USFWS has 

proposed reintroduction in the Bitterroot ecosystem of east-central Idaho and adjacent Montana. 

In Europe, apart from northern Europe, distribution has shrunk to a few isolated populations in 

the Pyrenees, the Apenines, the Alps, the Balkan Peninsula, and the Carpathians (see Hartl and 

Hell, 1994).

Habitat: (no critical habitat)

Grizzly bears need a very large home range (50 to 300 square miles for females; 200 to 

500 square miles for males), encompassing diverse forests interspersed with moist meadows and 

grasslands in or near mountains. In the spring, bears usually range at lower elevations and go to 

higher altitudes for winter hibernation. For hibernating, they seek a high, remote mountain slope 

where deep snow will serve as insulation until spring. They are common only where food is 
2013 VGP and sVGP BE Appendix F

F-38

abundant and concentrated (e.g., salmon runs, caribou calving grounds). They typically dig their 

own hibernation den, usually on steep northern slope.

Life History:

Grizzlies often dig beneath the roots of a large tree to create their dens. Except for mating and 

caring for the young, grizzly bears primarily lead solitary lives, spending most of their time 

foraging, or looking for food. The grizzly bear will generally enter its den in October or 

November. Male grizzly bears usually emerge from the den in March or April, while females 

emerge in late April and May. When a grizzly comes out of its den, the first food is sometimes 

carrion from animals that did not survive the winter. A grizzly will usually travel to lower 

elevations to reach vegetated areas. 

Mating season is from June through July. Grizzly bear embryos do not begin to develop until the 

mother begins her winter hibernation, although mating may have taken place up to 6 months 

before. As with other bears, if the mother has not accumulated enough fat to sustain her as well 

as developing cubs, the embryos may not implant (develop). In January, usually 1 to 3 cubs are 

born. Cubs remain dependent upon their mother’s milk for almost a year, stay with their mother 

for up to 3 years, and reach breeding maturity at about 4 1/2 to 5 1/2 years. In some cases they 

may not breed until 8 1/2 years of age. When they do reach breeding age, females usually only 

breed every 3 years. Grizzlies usually live to 15 to 20 years of age, and a few survive for up to 30 

years.

The grizzly is North America’s largest omnivore. About 80 to 90 percent of the grizzly’s food is 

green vegetation, wild fruits and berries, nuts, and bulbs or roots of certain plants. Grizzlies also 

eat a great deal of insects, sometimes tearing rotten logs apart and turning over heavy stones in 

search of the adult insects or their larvae. Most of the meat in the grizzly’s diet comes from 

animal carcasses, or carrion, of big game animals, although it will sometimes prey on elk or 

moose calves or smaller mammals. For grizzlies along the west coast of Canada and in Alaska, 

salmon is an important food source.

Historical Information:

Historically they were found throughout western North America, north from northern Mexico 

northwestern Africa, all of the Palearctic from western Europe, Near and Middle East through 

the northern Himalayas to western and northern China and Chukot (Russia) and Hokkaido 

(Japan) (Wilson and Reeder, 1993; Pasitschniak-Arts, 1993).

In 1975, The U.S. Fish and Wildlife Service listed the grizzly bear as a threatened species in the 

lower 48 states. In Alaska, where there are estimated to be over 30,000 grizzly bears, they are 

classified as a game animal with regionally established regulations. The Yellowstone population 

of grizzly bears was declared recovered and removed from the threatened species list in April of 

2007.

Conservation Status:

The grizzly bear has disappeared over much of Holarctic range, and continues to decline in the 

face of habitat alienation, alteration, and loss, as well as increased human access to wilderness. 
2013 VGP and sVGP BE Appendix F

F-39

In North America, there are currently about 30,000-35,000 grizzly bears in Alaska, 21,660 in 

Canada, and 800-1000 in the lower 48 states. Population estimates for Asian grizzlies are 

unavailable. 

Summary of Major Threats:

There are a number of factors that that have led to the historical decline of the grizzly bear 

population including habitat loss and fragmentation, and killing by humans. Current primary 

threats are habitat alienation, alteration, and loss, increased human access to wilderness and 

hunting (both legal and illegal). The increase in human-bear contacts have resulted in the 

destruction of bears. Other threats include non-native species threatening food resources in some 

areas (e.g. white pine blister rust has killed whitebark pines whose seeds serve as food) and 

displacement of native plants that serve as food for bears and their prey. In addition forestry, 

mining, recreation, and road building activities have a negative effect on habitat (USFWS 1999).

F.2. NEW YORK, NEW YORK

F.2.1.

Acipenser brevirostrum

SHORTNOSE STURGEON

Family: Acipenseridae

Endangered: wherever found

Sources:

• NJDEP, 2012 (http://www.state.nj.us/dep/fgw/ensp/pdf/end-thrtened/sturgeon.pdf)

• NYDEC, 2012 (http://www.dec.ny.gov/animals/26012.html)

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=E00B)

• NOAA Fisheries, 2012 

(http://www.nmfs.noaa.gov/pr/species/fish/shortnosesturgeon.htm)

• GLEC, 2011

Description:

The shortnose sturgeon is a fish that has a short and bluntly rounded snout, wide mouth, barbels, 

numerous dorsal, lateral and ventral scutes (bony or horny plates), and a heterocercal tail (the 

upper lobe of the tail fin is larger and contains the upturned end of the spinal column). Typically, 

the body is yellowish brown to nearly black on the head, and whitish to yellowish below. At 

initial maturity the length of this species ranges between 18-22 inches fork length (from the 

snout to the middle of the tail), for both males and females. Maximum known fork lengths are 

nearly 49 inches for a female and nearly 39 inches for a male. 

Geographic Boundaries and Spatial Distribution:

The shortnose sturgeon is found on the Atlantic Coast of North America where its range extends 

from the Saint John River, New Brunswick, to the St. Johns River, Florida. The federal recovery 

plan (NMFS, 1998a) for the species identifies 19 Distinct Population Segments (DPSs), each 

associated with a river/estuarine system in which shortnose sturgeons have been captured in the 

generation time of the species (30 years). 
2013 VGP and sVGP BE Appendix F

F-40

Habitat: (no critical habitat)

River mouths, tidal rivers, estuaries, and bays serve as prime habitat for the shortnose sturgeon. 

In addition, individuals occasionally enter the open ocean. Shortnose sturgeons generally occupy 

the main stem of their natal rivers, and migrate between freshwater and mesohaline river reaches. 

They will move to upper freshwater areas for spawning, but will occupy fresh or saline habitats 

for feeding and overwintering. 

Life History:

The shortnose sturgeon's life history is complex. Much of its spawning behavior and early life 

stages are still not fully understood. The shortnose sturgeon is anadramous, migrating from 

saltwater to spawn in freshwater. In the Hudson River, it spawns from April to May. Unlike most 

fish species, spawning is not a yearly event for most shortnose sturgeon. Males spawn every 

other year and females every third year. Females lay between 40,000-200,000 eggs, which hatch 

in approximately 13 days. Newly-hatched fry are poor swimmers and drift with the currents 

along the bottom. As they grow and mature, the fish move down-river into more brackish water.

Shortnose sturgeon are long-lived; the oldest known female reached 67 years of age, and the 

oldest known male was 32. Shortnose sturgeons are bottom/benthic feeders that eat sludge 

worms, aquatic insect larvae, plants, snails and other gastropods, shrimp, and crayfish using their 

barbels to locate food and their extendable mouths to vacuum it up.

Historical Information:

The shortnose sturgeon was first listed on March 11, 1967. It is currently designated as 

endangered in its entire range. The shortnose sturgeon has been federally listed as endangered 

since the inception of the Endangered Species Act in 1973.

No estimate of the historical population size of shortnose sturgeon is available. While the 

shortnose sturgeon was rarely the target of a commercial fishery, it often was taken incidentally 

in the commercial fishery for Atlantic sturgeon. In the 1950s, sturgeon fisheries declined on the 

east coast which resulted in a lack of records of shortnose sturgeon. This led the Fish and 

Wildlife Service (FWS) to conclude that the fish had been eliminated from the rivers in its 

historic range (except the Hudson River) and was in danger of extinction. 

Conservation Status:

A combination of factors can be blamed for declines in shortnose sturgeon populations. During 

the 1800s and early 1900s, large tidal rivers, such as the Hudson, served as dumping grounds for 

pollutants that lead to major oxygen depletions and corresponding high fish losses. At the same

time, great demands for sturgeon eggs (caviar) and the fish's smoked flesh resulted in 

overexploitation of sturgeon stocks.

Summary of Major Threats:

Some of the major threats facing the shortnose sturgeon are habitat loss (the construction of 

dams in particular along the Atlantic seaboard), impingement on cooling water intake screens, 

dredging (resulting in an increase of suspended sediments and degraded water quality), and 

accidental capture from commercial fishing (NMFS, 1998a). 
2013 VGP and sVGP BE Appendix F

F-41

Some other threats are less known including the effects of introduced species (NMFS 1998a). It 

is anticipated, however, that intentional or accidental introductions and transfers of indigenous 

and non-indigenous sturgeon, e.g., white sturgeon (A. transmontanus) or lake sturgeon (A. 

fulvescens), may threaten wild shortnose sturgeon populations by imposing genetic threats, 

increasing competition for food or habitat, or spreading diseases. It is also anticipated that rapid 

increases in abundance of other non-indigenous species (e.g., Asian clams, zebra mussels, blue 

and flathead catfish) in some rivers will affect sturgeon prey and/or introduce new predators to 

compete for resources of shortnose sturgeon (NMFS, 1998a).

Shortnose sturgeons are not the main prey item of any known species, and lethal parasites are 

uncommon (NatureServe, accessed April 2008). Sturgeon species, in general, do however appear 

to be susceptible to viruses enzootic to the west coast, and therefore fish introduced species could 

cause further spread these and other diseases. One such pathogen of concern is viral hemorrhagic 

septicemia (VHS). In 2005, a freshwater strain of VHS was discovered in freshwater drum from 

Lake Ontario, and subsequently it was found in numerous freshwater species throughout much of 

the Great Lakes. It has also been found in preserved samples from as far back as 2003. Prior to 

2003, the virus, a finfish pathogen, was only known to exist in marine fish off both coasts 

(USDA, 2006). Genetic studies have determined that the strain in the Great Lakes is most closely 

related to the North Atlantic strain (Gagné et al., 2007). Ballast water is a possible vector.

High nitrogen and phosphorus loadings, or nutrient pollution, resulting in eutrophication and 

oxygen depletion is stressful to aquatic life and to sturgeon as well (Jenkins et al., 1993; 

Campbell and Goodman 2004; Flournoy et al., 1992). The toxicity data available evaluating the 

sensitivity of shortnose sturgeon, and sturgeon species in general, is extremely limited with 

regard to petroleum hydrocarbons, and non-existent for other hydrocarbons, including animal 

fat-based hydrocarbons (grease). Several characteristics of shortnose sturgeon (i.e., long lifespan, 

extended residence in estuarine habitats, benthic predator) predispose the species to long-term 

and repeated exposure to environmental contamination from oil and oil-related derivatives 

(PAHs). There is also some evidence indicates that shortnose sturgeon is as sensitive to metals as 

rainbow trout, a sensitive salmonid fish species. In general, the relative rank sensitivity among 

fishes to heavy metals tends to be similar across the metals. Therefore, shortnose sturgeon may 

be presumed to be relatively sensitive to other heavy metals. 

Because viability of sturgeon populations is affected greatly by variability in juvenile recruitment 

and survival (Anders et al., 2002; Gross et al., 2002; Secor et al., 2002), and because young-ofthe-year shortnose sturgeon move downstream after hatching, but remain in fresh water for 

approximately a year (Kynard, 1997), any threats to the species from degraded water quality or 

other factors (habitat loss, decrease in dietary food items, impingement on water intakes, 

competition from invasive species, among others) are presumed to be more important to 

shortnose sturgeon in the freshwater environment.

F.2.2.

Amaranthus pumilus

SEABEACH AMARANTH

Family: Amaranthaceae
2013 VGP and sVGP BE Appendix F

F-42

Threatened: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q2MZ)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Amaranthus+pu

milus)

• USFWS, 2012b (http://ecos.fws.gov/docs/recovery_plan/961112b.pdf)

Description:

Seabeach amaranth is an annual plant found on the dunes of Atlantic Ocean beaches. The stems 

are fleshy and pink-red or reddish, with small rounded leaves that are 0.5-1 inch in diameter. The 

leaves, with indented veins, are clustered toward the tip of the stem and have a small notch at the 

rounded tip. Flowers and fruits are relatively inconspicuous, borne in clusters along the stems. 

Geographic Boundaries and Spatial Distribution:

The species is currently found in New York, New Jersey, Delaware, Maryland, Virginia, North 

Carolina, and South Carolina. More specifically it is extant from vicinity of Cape Hatteras, NC, 

to vicinity of Cape Romain, SC, and at scattered sites on Long Island, NY, and in coastal 

Delaware, Maryland, Virginia, and New Jersey. Its actual occupied area, even historically, is 

quite small, because it occurs only in a narrow band of suitable habitat.

Habitat: (no critical habitat)

Seabeach amaranth occurs on barrier island beaches, where its primary habitat consists of 

overwash flats at accreting ends of islands and lower foredunes and upper strands of non-eroding 

beaches. It occasionally establishes small temporary populations in other habitats, including 

sound-side beaches, blowouts in foredunes, and sand and shell material placed as beach 

replenishment or dredge spoil. Seabeach amaranth appears to be intolerant of competition and 

does not occur on well-vegetated sites. The species appears to need extensive areas of barrier 

island beaches and inlets, functioning in a relatively natural and dynamic manner. These 

characteristics allow it to move around in the landscape as a fugitive species, occupying suitable 

habitat as it becomes available.

Life History:

Germination takes place over a relatively long period of time, generally beginning in April and 

continuing at least through July. Upon germinating, this plant initially forms a small unbranched 

sprig but soon begins to branch profusely into a clump, often reaching a foot in diameter and 

consisting of 5 to 20 branches. Occasionally a clump may get as large as a yard or more across, 

with a hundred or more branches.

Flowering begins as soon as plants have reached sufficient size, sometimes as early as June, but 

more typically commencing in July and continuing until the death of the plant in late fall. Seed 

production begins in July or August and peaks in September during most years, but continues 

until the death of the plant. Weather events, including rainfall, hurricanes, and temperature 

extremes, and predation by webworms have strong effects on the length of seabeach amaranth's 
2013 VGP and sVGP BE Appendix F

F-43

reproductive season. As a result of one or more of these influences, the flowering and fruiting 

period can be terminated as early as June or July. Under favorable circumstances, however, the 

reproductive season may extend until January or sometimes later. The species is an effective 

sand binder, building dunes where it grows.

Seeds are regularly produced by nearly all adult plants and fertility is assumed to be high (Baskin 

and Baskin, 1994). For an annual species such as seabeach amaranth, the presence of plants in 

any given year is evidence of reproduction in the former year or of reproduction in earlier years 

and seed-banking. The relative roles of the fresh seed crop and banked seeds are unknown in 

seabeach amaranth. It is known, however, that century-old seeds of some species of amaranth are 

capable of successful germination and growth (David Brenner, University of Iowa, personal 

communication, 1990). Such controlled experiments, of course, have limited applicability to seed 

viability in the coastal environment, where salt, abrasion, temperature changes, and moisture 

changes are all factors likely to limit seed longevity.

Historical Information:

Historically, seabeach amaranth occurred in 31 counties in nine States from Massachusetts to 

South Carolina. The species has now been completely eliminated from two-thirds of its historic 

range (six of the States in its original range). Seabeach amaranth was listed as Threatened on 

April 7, 1993. Before its listing, seabeach amaranth had undergone a reduction in range, 

population sizes and populations. At the time of listing, only 55 populations were known.

Conservation Status:

Approximately 50 populations are estimated to remain, all in a narrow band of suitable habitat. 

As of 1990 (the last year a complete rangewide census was done), there were 55 remaining 

populations. Of these, 34 were in North Carolina, 8 were in South Carolina, and 13 were in New 

York.

Summary of Major Threats:

The most serious threats to the continued existence of seabeach amaranth include the 

construction of beach stabilization structures (sea walls and dune fencing), beach erosion and 

tidal inundation, beach grooming, herbivory by insects and feral animals, development, and, in 

certain circumstances, by off-road vehicles. 

F.2.3.

Balaenoptera physalus

FINBACK WHALE

Family: Balaenopteridae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=A02O)

• NOAA Fisheries, 2012 

(http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/finwhale.htm)
2013 VGP and sVGP BE Appendix F

F-44

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Balaenoptera+ph

ysalus)

Description:

Fin whales are the second-largest species of whale, with a maximum length of about 75 feet in 

the Northern Hemisphere and 85 feet in the Southern Hemisphere. Fin whales show mild sexual 

"dimorphism", with females measuring longer than males by 5-10%. Adults can weigh between 

80,000-160,000 lbs. (40-80 tons). Fin whales have a sleek, streamlined body with a V-shaped 

head. They have a tall, "falcate" dorsal fin, located about two-thirds of the way back on the body, 

that rises at a shallow angle from the animal's back. The species has a distinctive coloration 

pattern: the back and sides of the body are black or dark brownish-gray, and the ventral surface is 

white. The unique, asymmetrical head color is dark on the left side of the lower jaw, and white 

on the right side. Many individuals have several light-gray, V-shaped "chevrons" behind their 

head, and the underside of the tail flukes is white with a gray border. Fin whales can live 80-90 

years. 

Geographic Boundaries and Spatial Distribution:

There are two named subspecies of fin whale, B. physalus physalus in the North Atlantic and B. 

physalus quoyi in the Southern Ocean. There is also a population of fin whales in the North 

Pacific, which most experts consider a separate, unnamed subspecies. These populations rarely 

mix, if at all, and there are geographical stocks within these ocean basins. Fin whales are 

migratory, moving seasonally into and out of high-latitude feeding areas, but the overall 

migration pattern is complex, and specific routes have not been documented. However, acoustic 

recordings from passive-listening hydrophone arrays indicate that a southward "flow pattern" 

occurs in the fall from the Labrador-Newfoundland region, past Bermuda, and into the West 

Indies (Clark, 1995). There may be resident groups of fin whales in some areas, such as the Gulf 

of California, the East China Sea, and the Mediterranean Sea.

Habitat: (no critical habitat)

Fin whales are found in deep, offshore waters of all major oceans, primarily in temperate to polar 

latitudes, and less commonly in the tropics. They occur year-round in a wide range of latitudes 

and longitudes, but the density of individuals in any one area changes seasonally. Finback whales 

are migratory, moving seasonally into and out of high-latitude feeding areas. 

Life History:

Fin whales can be found in social groups of 2-7 whales and in the North Atlantic are often seen 

feeding in large groups that include humpback whales, minke whales, and Atlantic white-sided 

dolphins (Jefferson et al., 2008). Fin whales are large, fast swimmers, and the killer whale 

(Orcinus orca) is their only non-human predator.

During the summer, fin whales feed on krill, small schooling fish (e.g., herring, capelin, and sand 

lance), and squid by lunging into schools of prey with their mouth open, using their 50-100 

accordion-like throat pleats to gulp large amounts of food and water. They then filter the food 

particles from the water using the 260-480 baleen plates on each side of the mouth. Fin whales 

fast in the winter while they migrate to warmer waters.
2013 VGP and sVGP BE Appendix F

F-45

Little is known about the social and mating systems of fin whales. Similar to other baleen 

whales, long-term bonds between individuals are rare. Males become sexually mature at 6-10 

years of age; females at 7-12 years of age. Physical maturity is attained at approximately 25 

years for both sexes. After 11-12 months of gestation, females give birth to a single calf in 

tropical and subtropical areas during midwinter. Newborn calves are approximately 18 feet long, 

and weigh 4,000-6,000 lb. (2 tons).

Historical Information:

Finback whales were once widespread in Atlantic, Pacific, Indian, and Southern oceans; however 

their populations were greatly reduced by commercial whaling. Approximately 102,000-122,000 

remain from pre-exploitation levels of over 450,000; threatened by general deterioration of the 

marine ecosystem.

Conservation Status:

Most populations apparently have increased little if at all since commercial harvest was ended in 

the 1970s. Population off coast of eastern U.S. may be increasing (Ratnaswamy and Winn,

1993). Ten-year survey (published in 1989) of prime Antarctic waters yielded far fewer numbers 

than expected, raising concern (Matthews and Moseley, 1990).

Although reliable and recent estimates of fin whale abundance are available for large portions of 

the North Atlantic Ocean, this is not the case for most of the North Pacific Ocean nor for the 

Southern Oceans. The present status of populations in these ocean basins relative to their prewhaling population size is uncertain.

For management purposes, fin whales in U.S. waters have been divided into four stocks:

• Hawaii 

• California/Oregon/Washington 

• Alaska (Northeast Pacific) 

• Western North Atlantic 

Reliable estimates of current and historical abundance of fin whales in the entire northeast 

Pacific are currently not available. While reliable estimates of the minimum population size and 

population trends are available for a portion of this area, much of the North Pacific range has not 

been surveyed.

A 2002 shipboard line-transect survey of the entire Hawaiian Islands EEZ resulted in an 

abundance estimate of 174 fin whales (Barlow 2003). As of the 2004 Hawaii stock assessment 

report, this was the best available abundance estimate for this stock.

The California/Oregon/Washington stock was estimated at 3,279 fin whales based on ship 

surveys in summer/autumn of 1996 (Barlow and Taylor, 2001) and 2001 (Barlow, 2003). The 

2003 stock assessment report lists the minimum population of this stock at approximately 2,541

animals.
2013 VGP and sVGP BE Appendix F

F-46

Although the full range of the Alaska (Northeast Pacific) stock of fin whales has not been 

surveyed, a rough estimate of the size of the population west of the Kenai Peninsula is 5,700 (as 

of the 2007 stock assessment report). This is a minimum estimate for the entire Alaska stock 

because it was estimated from surveys which covered only a small portion of the range of this 

stock.

The minimum population estimate for the Western North Atlantic fin whale stock is 1,678. There 

are insufficient data to determine trends for this population.

Summary of Major Threats:

Commercial whaling for this species ended in the North Pacific Ocean in 1976, in the Southern 

Ocean in 1976-77, and in the North Atlantic Ocean in 1987. Fin whales are still hunted in 

Greenland and subject to catch limits under the International Whaling Commission’s “aboriginal 

subsistence whaling" scheme.

Other current threats are collisions with vessels, entanglement in fishing gear, reduced prey 

abundance due to overfishing, habitat degradation, disturbance from low-frequency noise and the 

possibility that illegal whaling or resumed legal whaling will cause removals at biologically 

unsustainable rates. Of all species of large whales, fin whales are most often reported as hit by 

vessels (Jensen and Silber 2004). Schooling fish constitute a large proportion of the fin whale's 

diet in many areas of the North Atlantic, so trends in fish populations, whether driven by fishery 

operations, human-caused environmental deterioration, or natural processes, may strongly affect 

the size and distribution of fin whale populations.

F.2.4.

Caretta caretta

LOGGERHEAD SEA TURTLE

Family: Cheloniidae

Threatened: wherever found

Under Review: North Pacific population segment

Sources:

• NJDEP, 2012 (http://www.nj.gov/dep/fgw/ensp/pdf/end-thrtened/marinetrtls.pdf) 

• USFWS, 2012c

(http://www.fws.gov/northflorida/SeaTurtles/Turtle%20Factsheets/loggerhead-seaturtle.htm)

• NOAA Fisheries, 2012 (http://www.nmfs.noaa.gov/pr/species/turtles/loggerhead.htm)

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=C00U)

• GLEC, 2011

Description:

Loggerheads were named for their relatively large heads, which support powerful blunt jaws and 

enable them to feed on hard-shelled prey, such as whelks and conch. The top shell (carapace) is 

slightly heart-shaped and reddish-brown in adults and sub-adults, while the bottom shell 
2013 VGP and sVGP BE Appendix F

F-47

(plastron) is generally a pale yellowish color. The carapace has five pairs of costal scutes, with 

the first touching the nuchal scute. There are three large inframarginal scutes on each of the 

bridges between the plastron and carapace. The neck and flippers are usually dull brown to 

reddish brown on top and medium to pale yellow on the sides and bottom. Adults grow to an 

average weight of about 200 pounds.

Geographic Boundaries and Spatial Distribution:

The loggerhead sea turtle has been observed throughout the temperate and tropical regions of the 

Atlantic, Pacific, and Indian Oceans. However, the majority of loggerhead nesting is at the 

western rims of the Atlantic and Indian oceans. In the Atlantic, the loggerhead turtle's range 

extends from Newfoundland to as far south as Argentina. During the summer, nesting occurs 

primarily in the subtropics. Although the major nesting concentrations in the U.S. are found in 

South Florida, loggerheads nest from Texas to Virginia. The loggerhead nesting aggregations in 

Oman, the U.S., and Australia account for about 88% of nesting worldwide. Loggerheads are the 

most abundant species of sea turtle found in U.S. coastal waters. 

In the eastern Pacific, loggerheads have been reported as far north as Alaska, and as far south as 

Chile. In the U.S., occasional sightings are reported from the coasts of Washington and Oregon, 

but most records are of juveniles off the coast of California. The west coast of Mexico, including 

the Baja Peninsula, provides critically important developmental habitats for juvenile 

loggerheads. The only known nesting areas for loggerheads in the North Pacific are found in 

southern Japan.

Habitat: (has critical habitat)

The loggerhead is widely distributed within its range. It may be found hundreds of miles out to 

sea, as well as in inshore areas such as bays, lagoons, salt marshes, creeks, ship channels, and the 

mouths of large rivers. Coral reefs, rocky places, and ship wrecks are often used as feeding areas. 

Loggerheads nest on ocean beaches and occasionally on estuarine shorelines with suitable sand. 

Nests are typically made between the high tide line and the dune front. 

In October 1978, critical habitat was proposed in the FEDERAL REGISTER for the loggerhead 

sea turtle in the area of Port Canaveral navigation channel, Cape Canaveral, Florida. This area 

was found to be a major hibernating and nesting area for the species. 

Life History:

Loggerheads occupy three different ecosystems during their lives:

• beaches (terrestrial zone) 

• water (oceanic zone) 

• nearshore coastal areas ("neritic" zone) 

Loggerheads nest on ocean beaches, generally preferring high energy, relatively narrow, steeply 

sloped, coarse-grained beaches. The United States nesting season extends from about May 

through August, primarily nesting at night. Loggerheads are known to nest from one to seven 

times within a nesting season (mean is about 4.1 nests per season) at intervals of approximately 

14 days. Mean clutch size varies from about 100 to 126 along the southeastern United States 

coast. Incubation ranges from about 45 to 95 days, depending on incubation temperatures, but 
2013 VGP and sVGP BE Appendix F

F-48

averages 55 to 60 days for most clutches in Florida. Hatchlings generally emerge at night. 

Remigration intervals of 2 to 3 years are most common in nesting loggerheads, but remigration 

can vary from 1 to 7 years. Age at sexual maturity is believed to be about 20 to 30 years.

Immediately after hatchlings emerge from the nest, they begin a period of frenzied activity. 

During this active period, hatchlings move from their nest to the surf, swim, are swept through 

the surf zone, and continue swimming away from land for up to several days.

After this swim frenzy period, post-hatchling loggerheads take up residence in areas where 

surface waters converge to form local downwellings. These areas are often characterized by 

accumulations of floating material, such as seaweed (for example, Sargassum), and, in the 

southeast U.S., are common between the Gulf Stream and the southeast U.S. coast, and between 

the Loop Current and the Gulf Coast of Florida. Post-hatchlings within this habitat are observed 

to be low-energy float-and-wait foragers that feed on a wide variety of floating items 

(Witherington, 2002). As post-hatchlings, loggerheads may linger for months in waters just off 

the nesting beach or become transported by ocean currents within the Gulf of Mexico and North 

Atlantic. 

Once individuals get transported by ocean currents farther offshore, they've entered the oceanic 

zone. Within the North Atlantic, juvenile loggerheads have been primarily studied in the waters 

around the Azores and Madeira (Bolten, 2003). Other populations exist (for example, in the 

region of the Grand Banks off Newfoundland), but data on these populations are limited. The 

juvenile turtles around the Azores and Madeira spend the majority of their time in the top 15 feet 

of the water column.

Somewhere between 7-12 years old, oceanic juveniles migrate to nearshore coastal areas (neritic 

zone) and continue maturing until adulthood. In addition to providing critically important habitat 

for juveniles, the neritic zone also provides crucial foraging habitat, inter-nesting habitat, and 

migratory habitat for adult loggerheads in the western North Atlantic. To a large extent, these 

habitats overlap with the juvenile stage, the exception being most of the bays, sounds, and 

estuaries along the Atlantic and Gulf coasts of the U.S. from Massachusetts to Texas, which are 

infrequently used by adults. However, adult loggerheads are present year-round in Florida Bay, 

an important feeding area, probably because of relatively easy access to open ocean and 

migratory routes. The predominate foraging areas for western North Atlantic adult loggerheads 

are found throughout the relatively shallow continental shelf waters of the U.S., Bahamas, Cuba, 

and the Yucatán Peninsula, Mexico. Migration routes from foraging habitats to nesting beaches 

(and vice versa) for a portion of the population are restricted to the continental shelf, while other 

routes involve crossing oceanic waters to and from the Bahamas, Cuba, and the Yucatán 

Peninsula. Seasonal migrations of adult loggerheads along the mid- and southeast U.S. coasts 

have also been documented.

The species feeds on mollusks, crustaceans, fish, and other marine animals. The turtles are 

exposed to cyanide dissolved in seawater and through contaminated items in their diet.
2013 VGP and sVGP BE Appendix F

F-49

Historical Information:

The loggerhead turtle was first listed as threatened throughout its range on July 28, 1978. In 

September 2011, NMFS and U.S. Fish and Wildlife Service listed 9 Distinct Population 

Segments (DPSs) of loggerhead sea turtles under the ESA. NMFS and USFWS had proposed to 

list 9 DPSs of loggerhead sea turtles under the ESA in 2010.

Conservation Status:

The most recent reviews show that only two loggerhead nesting beaches have greater than 

10,000 females nesting per year: South Florida (U.S.) and Masirah Island (Oman). The status of 

the Oman nesting colony has not been evaluated recently. Total estimated nesting in the U.S. is 

approximately 68,000 to 90,000 nests per year. Recent analyses of nesting data from the Index 

Nesting Beach Survey program in southeast Florida show the population is declining. Similarly, 

long-term nesting data show loggerhead nesting declines in North Carolina, South Carolina, and 

Georgia.

In the Eastern Atlantic, the Cape Verde Islands support an intermediately-sized loggerhead 

nesting assemblage. In 2000, researchers tagged over 1,000 nesting females on just 5 km (3.1 mi) 

of beach on Boavista Island (Ehrhart et al., 2003). In the Western Atlantic (excluding the U.S.), 

Brazil supports an intermediately-sized loggerhead nesting assemblage. Published and 

unpublished reports provide an estimate of about 4,000 nests per year in Brazil (Ehrhart et al.,

2003). Loggerhead nesting throughout the Caribbean is sparse.

In the Mediterranean, loggerhead nesting is confined almost exclusively to the eastern portion of 

the Mediterranean Sea. The main nesting assemblages occur in Cyprus, Greece, and Turkey. 

However, small numbers of loggerhead nests have been recorded in Egypt, Israel, Italy, Libya, 

Syria, and Tunisia. Based on the recorded number of nests per year in Cyprus, Greece, Israel, 

Tunisia, and Turkey, loggerhead nesting in the Mediterranean ranges from about 3,300 to 7,000 

nests per season (Margaritoulis et al., 2003).

Loggerheads nest throughout the Indian Ocean and, with the exception of Oman, the number of 

nesting females is small. Most trends in loggerhead nesting populations in the Indian Ocean are 

unknown.

Loggerhead populations in Honduras, Mexico, Colombia, Israel, Turkey, Bahamas, Cuba, 

Greece, Japan, and Panama have been declining. This decline continues and is primarily 

attributed to incidental capture in fishing gear, directed harvest, coastal development, increased 

human use of nesting beaches, and pollution.

Summary of Major Threats:

Loggerheads face threats on both nesting beaches and in the marine environment. The greatest 

cause of decline and the continuing primary threat to loggerhead turtle populations worldwide is 

incidental capture in fishing gear, primarily in longlines and gillnets, but also in trawls, traps and 

pots, and dredges. There is a particular concern about the extensive incidental take of juvenile 

loggerheads in the eastern Atlantic by longline fishing vessels from several countries. Directed 

harvest for loggerheads still occurs in many places (for example, the Bahamas, Cuba, and 

Mexico) and is a serious and continuing threat to loggerhead recovery. Other threats include loss 

or degradation of nesting habitat from coastal development and beach armoring, disorientation of 
2013 VGP and sVGP BE Appendix F

F-50

hatchlings by beachfront lighting, excessive nest predation by native and non-native predators, 

degradation of foraging habitat, marine pollution and debris accumulation, watercraft strikes, and 

disease 

F.2.5.

Charadrius melodus

PIPING PLOVER

Family: Charadriidae

Endangered: Great Lakes watershed

Threatened: everywhere else

Sources:

• NJDEP, 2012 (http://www.nj.gov/dep/fgw/ensp/pdf/end-thrtened/plover.pdf)

• USFWS, 2012b

(http://ecos.fws.gov/species_profile/servlet/gov.doi.species_profile.servlets.SpeciesProfil

e?spcode=B079)

• NatureServe Explorer, 2012 (http://www.natureserve.org/explorer/index.htm)

• USFWS, 2012c (http://www.fws.gov/midwest/endangered/pipingplover/pipingpl.html)

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=B079)

• GLEC, 2011

Description:

The piping plover is a small shorebird with a black neck band and a black bar across the 

forehead. The upperparts are light sandy-brown and the under parts are white, providing the 

plover with camouflage against sandy beach backgrounds. The legs are bright orange and, in 

breeding plumage, the bill is also orange with a black tip. Although males and females are 

similar in appearance, males typically have darker, more extensive neck bands. Juvenile and 

winter-plumage adults are similar in appearance. Both lack the black neck and forehead bands 

characteristic of breeding adults. Rather, there is a pale band around the neck. The bill is solid 

black and the legs are pale yellow.

Geographic Boundaries and Spatial Distribution:

Piping plovers are migratory birds. In the spring and summer they breed in northern U.S. and 

Canada. There are three locations where piping plovers nest in North America: the shorelines of 

the Great Lakes, the shores of rivers and lakes in the Northern Great Plains, and along the 

Atlantic Coast. Their nesting range has become smaller over the years, especially in the Great 

Lakes area.

The Atlantic Coast Population of piping plovers nest along beaches in New Brunswick, Prince 

Edward Island, Nova Scotia, Quebec, southern Maine, Rhode Island, Massachusetts, 

Connecticut, New York, New Jersey, Delaware, Maryland, Virginia, and North Carolina. Piping 

plovers migrate through the Great Lakes along the river systems through the Bahamas and West 

Indies. They are currently found along the Atlantic Coast from Canada to North Carolina and 

along the shorelines of Lakes Michigan and Superior. Gulf Coast beaches from Florida to 
2013 VGP and sVGP BE Appendix F

F-51

Mexico, and Atlantic coast beaches from Florida to North Carolina provide winter homes for 

plovers.

Habitat: (has critical habitat)

Piping plovers inhabit oceanfront beaches and barrier islands, typically nesting on the stretch of 

beach between the dunes and the high-tide line. Nests are often located in flat areas with shell 

fragments and sparse vegetation. The coloration of piping plovers and their eggs blend in 

remarkably with sand and broken pieces of shell. Sparse vegetation, such as American beach 

grass (Ammophila breviligulata) or sea rocket (Cakile endentula), is favored, as it provides cover 

against predators and the elements. However, areas with dense vegetation, such as dunes, are 

avoided by nesting plovers, since these sites provide cover for predators. During the nonbreeding season, piping plovers inhabit coastal beaches, barrier islands, inlets, sandflats, 

mudflats, and dredged material islands. 

Critical habitat was designated for wintering piping plovers in July of 2001. This designation 

identifies areas that are important to the plovers on their wintering grounds, and provides the 

public and resource agencies with information that can be used to minimize impacts to these 

areas. The Fish and Wildlife Service designated 137 areas along the coasts of North Carolina, 

South Carolina, Georgia, Florida, Alabama, Mississippi, Louisiana, and Texas as critical habitat 

for the wintering Atlantic Coast population of the piping plover. This includes approximately 

2,891.7 kilometers of mapped shoreline and approximately 66,881 hectares of mapped area 

along the Gulf and Atlantic coasts and along margins of interior bays, inlets, and lagoons.

As of September 2001, The U.S. Fish and Wildlife Service designated critical habitat for the 

northern great plains breeding population of the piping plover. This includes habitat in 

Minnesota, Montana, Nebraska, North Dakota, and South Dakota totaling approximately

183,422 acres (ac) (74,228.4 hectares (ha)) and portions of 4 rivers totaling approximately 

1,207.5 river miles (rm) (1,943.3 kilometers (km)). Critical habitat includes prairie alkali 

wetlands and surrounding shoreline, including 200 feet (ft) (61 meters (m)) of uplands above the 

high water mark; river channels and associated sandbars, and islands; reservoirs and their 

sparsely vegetated shorelines, peninsulas, and islands; and inland lakes and their sparsely 

vegetated shorelines and peninsulas.

Life History:

Piping plovers begin returning to their Atlantic Coast nesting beaches in mid-March. Males 

establish and defend territories and court females. Eggs may be present on the beach from midApril through late July. Clutch size is generally four eggs, and the incubation period usually lasts 

for 27-28 days. Piping plovers fledge only a single brood per season, but may re-nest several 

times if previous nests are lost. Chicks develop fast. They may move hundreds of yards from the 

nest site during their first week of life. Chicks remain together with one or both parents until they 

fledge (able to fly) at 25 to 35 days of age. Depending on date of hatching, flightless chicks may 

be present from mid-May until late August, although most fledge by the end of July. Piping 

plovers forage on intertidal beaches, washover areas, exposed mudflats and sandflats, 

wracklines, and shorelines. Food consists of worms, fly larvae, beetles, crustaceans, mollusks, 

and other invertebrates (Bent 1928). In New Jersey, intertidal polychaetes are the main prey of 
2013 VGP and sVGP BE Appendix F

F-52

plovers foraging at night (Staine and Burger 1994). The primary route of exposure to nickel is 

through contaminated prey items in the diet.

Historical Information:

On December 11, 1985, the piping plover was listed Threatened (50 FR 50726-50734, 1985, 

December 11) in its entire range except in the Great Lakes watershed where it was listed 

endangered. The Revised Recovery Plan for the Atlantic Coast Population was completed on 

May 2, 1996. 

Although common during the 1800s, the piping plover was on the verge of extirpation by the 

1890s and early 1900s due to market hunting and egg collecting. Protection afforded by the 

Migratory Bird Treaty Act of 1918 and changing fashion trends allowed plover populations to 

gradually recover during the 1920s and 1930s. However, since the late 1940s, coastal 

development and the elevated recreational use of beaches have caused plover population 

declines. Human habitation along the shore has also resulted in elevated populations of many 

mammalian and avian predators.

Conservation Status:

Atlantic coast populations experienced a 50 to 80 percent decline over the past 50 years. The 

Long Island and New York population declined from over 500 pairs (Wilcox, 1939) to about 

100 pairs in 1988 (Cairns and McLaren, 1980, USFWS, 1988). In 1980 the size of Atlantic coast 

populations was estimated at 910 pairs (Cairns and McLaren 1980); this estimate declined to 

790 pairs in 1986 (550 pairs in the U.S. and 240 pairs in Canada) (USFWS, 1988). However, 

many populations have increased with management attention since the mid-1980s. Most of the 

increase since 1989 has been in New England; the Mid-Atlantic and Canadian Atlantic 

populations have declined somewhat since 1989 (USFWS, 1996). The 1991-1996 international 

census data indicate an overall increase of 30.4 per cent, from about 1979 individuals to 2,581 

(Plissner and Haig, 2000). The Canadian Atlantic populations declined 16.6 per cent over the 

same period, from about 513 individuals to 428 (Plissner and Haig, 2000). Subsequently, these 

numbers began to increase again, reaching 475 in 1999 (USFWS, 2002a).

The Great Lakes population of the piping plover was at a perilously low level. But intensive 

conservation efforts have seen the number of breeding pairs steadily climb from a low of 12 in 

1983. Also, the breeding range has expanded from Michigan into Wisconsin and Canada.

Summary of Major Threats:

Habitat alteration and destruction are the primary causes for the decline of the piping plover. 

Loss of sandy beaches and lakeshores due to recreational, residential, and commercial 

development has reduced available habitat on the Great Lakes, Atlantic Coast, and the Gulf of 

Mexico. Reservoir construction, channel excavation, and modification of river flows have 

eliminated sandbar nesting habitat along hundreds of miles of the Missouri and Platte Rivers. 

Winter habitats along the Gulf coast are threatened by industrial and urban expansion and 

maintenance activities for commercial waterways. There are limited reports of oil pollution from 

commercial or recreational watercraft affecting plover populations (Amirault-Langlais et al.,

2006).
2013 VGP and sVGP BE Appendix F

F-53

Predators remain one of the most burdensome threats to the piping plover, and developments 

near beaches provide food that attracts increased numbers of predators such as raccoons, skunks, 

and foxes. Domestic and feral cats are also very efficient predators of plover eggs and chicks 

(U.S. FWS, 2002b). On the breeding grounds, reproductive success can be curtailed by human 

disturbance. Vehicular and foot traffic also destroys eggs and chicks. The presence of people on 

beaches and sandbar islands inhibits incubation and other breeding behavior. 

F.2.6.

Chelonia mydas

GREEN SEA TURTLE

(See Seattle, Washington for information on this species)

F.2.7.

Clemmys (Glyptemys) muhlenbergii

BOG TURTLE

Family: Emydidae

Threatened: wherever found (except where Threatened)

Similarity of Appearance (Threatened): GA, NC, SC, TN, and VA

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=C048)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?sourceTemplate=tabular_repor

t.wmt&loadTemplate=species_RptComprehensive.wmt&selectedReport=RptComprehen

sive.wmt&summaryView=tabular_report.wmt&elKey=101495&paging=home&save=tru

e&startIndex=1&nextStartIndex=1&reset=false&offPageSelectedElKey=101495&offPag

eSelectedElType=species&offPageYesNo=true&post_processes=&radiobutton=radiobutt

on&selectedIndexes=101495)

Description:

This is the smallest emydid turtle, and one of the smallest turtles in the world. Adult carapace 

length is 3.1 to 4.5 inches. The dark brown or black carapace may be marked with radiating light 

lines or a light blotch on the vertebral and pleural scutes. Scute annuli are usually prominent in 

juvenile and young adult specimens, but the carapace may be nearly smooth in old adults. The 

head, neck, and limbs are typically dark brown with variable reddish to yellow spots and streaks. 

A large reddish-orange to yellow blotch is visible behind and above each tympanum, sometimes 

merging into a continuous band on the neck. The upper jaw is weakly notched. (Ernst, Lovich, 

and Barbour, 1994; Harding, 1997) The plastron is also brown or black, but often with lighter 

yellow blotches towards the medial and anterior scute edges. A mature male bog turtle has a 

concave plastron and a long, thick tail, with the vent posterior to the rear edge of the carapace 

with tail extended. The female has a flat plastron and a thinner, smaller tail, with the vent at or 

beneath the rear carapace edge. (Ernst, Lovich, and Barbour, 1994; Harding, 1997) 
2013 VGP and sVGP BE Appendix F

F-54

Geographic Boundaries and Spatial Distribution:

The bog turtle has a discontinuous, spotty distribution. The species is known to occur in New 

York (including remnant population at two sites in the Finger Lakes region), western 

Massachusetts, and western Connecticut southward to Pennsylvania, New Jersey, Maryland, and 

northern Delaware; southeastern Virginia through western and central North Carolina and 

extreme eastern Tennessee to western South Carolina and Georgia (Herpetol. Rev. 14:55). There 

is a large hiatus of about 250 miles between the northern populations and the southern 

populations. In the north, Maryland has the largest number of occurrences and turtles; only about 

20 populations thought to be viable exist outside Maryland and New Jersey. In the south, most 

occurrences and turtles are in North Carolina and Virginia (only a few viable populations 

elsewhere). Most populations occur on private property. The species is extirpated in western 

Pennsylvania and in the Lake George region of New York.

Habitat: (no critical habitat)

Bog turtles inhabit slow, shallow, muck-bottomed rivulets of sphagnum bogs, calcareous fens, 

marshy/sedge-tussock meadows, spring seeps, wet cow pastures, and shrub swamps. The habitat 

usually contains an abundance of sedges or mossy cover. The turtles depend on a mosaic of 

microhabitats for foraging, nesting, basking, hibernation, and shelter (USFWS, 2000). Bog 

turtles commonly bask on tussocks in the morning in spring and early summer. They burrow into 

soft substrate of waterways, crawls under sedge tussocks, or enter muskrat burrows during 

periods of inactivity in summer (see Bury, 1979). 

In Pennsylvania, bog turtles hibernated mainly in water and mud in muskrat burrows, and in mud 

bottom of marsh rivulets under 5-15 cm of water. In New Jersey, hibernacula were in 

subterranean rivulets or seepage areas where water flowed continuously from underground 

springs; turtles were under 5-55 cm of water and mud (Ernst et al., 1989). In Maryland, larger 

population sizes were associated with sites with the following characteristics: circular basin with 

spring-fed pockets of shallow water, bottom substrate of soft mud and rock, dominant vegetation 

of low grasses and sedges, and interspersed wet and dry pockets; winter retreats were shallow, 

just below upper surface of frozen mud and/or ice (Chase et al., 1989). Studies in Maryland and 

Pennsylvania noted use of the lower portion of wetlands for overwintering. In Virginia, selected 

habitats included wet meadow, smooth alder edge, and bulrush; dry meadow and streams were 

avoided (Carter et al., 1999). 

Life History:

Bog turtles emerge from their muddy hibernation in early to mid-April and by early May are 

actively seeking a mate. Adults are sexually mature at five to eight years of age. In June or July, 

the female lays a clutch of one to six small white elliptical eggs in a shallow “nest” she digs in a 

clump of sphagnum moss or tuft of grass above the water line. After seven or eight weeks of 

being incubated by the sun, the inch-long hatchlings emerge. Because they are born so late in the 

year, the hatchlings often spend their first winter near the nest.

They feed opportunistically on insects, worms, slugs, crayfish, snails, and other small 

invertebrates; also amphibian larvae and fruits. Diet generally is dominated by insects. 

Apparently forages on land and in water (Bury, 1979).
2013 VGP and sVGP BE Appendix F

F-55

Historical Information:

The northern population was listed as threatened and the southern population was listed as 

“Threatened due to similarity of appearance” on November 4, 1997 (62 FR 59605), though the 

southern population had not experienced the extent of habitat loss that the northern population 

had. Because individuals from the northern and southern populations are almost identical, a 

poacher could claim that a turtle he collected from the threatened northern populations was taken 

from the south. In order to eliminate such confusion for law enforcement personnel, the southern 

populations was designated as “threatened due to similarity of appearance,” which makes the 

poaching of bog turtles a federal offense anywhere within the species’ range. The southern 

population of the species is not subject to section seven consultations requirements under the 

Endangered Species Act.

Conservation Status:

The northern population has declined by at least 50% over the past 20 years (USFWS 1997, 

2000). The species is apparently extirpated in the majority of historical sites in Connecticut, New 

Jersey, and New York, and nearly half of the historic occurrences in Maryland have been 

extirpated; most losses have occurred since the 1970s. Trend in abundance is unknown in most 

areas due to inadequate demographic information. Rangewide, it seems likely that there has been 

at least a 30% reduction in population size over the past three generations.

Summary of Major Threats:

The greatest threats to the bog turtle are the loss, degradation, and fragmentation of its habitat 

from wetland alteration (i.e. development, draining, dredging, water impoundment, water 

diversion, and other hydrological alterations). Other threats include pollution, invasive species, 

and natural vegetational succession. In some areas, successional changes (e.g., reforestation) and 

exotic plant species have reduced habitat quality (Morrow et al., 2001). Heavy grazing is 

detrimental, especially when nesting females are disturbed or eggs are trampled (light grazing 

may be beneficial in some cases if it maintains an open canopy and avoid the problems just 

mentioned) (Morrow et al., 2001). Habitat fragmentation has made it difficult for turtles to cope 

with successional changes and ecosystem changes caused by humans or beavers (simply moving 

to another area is now often not an option).

The species is also threatened by collection for illegal wildlife trade. Laws against collecting 

have been largely ineffective in reducing that threat. In addition, mosquito control via pesticide 

application is a potential threat is some areas (impact turtles directly or affects food supply). Also 

abnormally high raccoon populations, associated with human impacts, may result in excessive 

predation on turtles and eggs. Eggs are susceptible to trampling by humans walking through the 

habitat. Frequent human visits to single sites conceivably could interfere with the turtles' basking 

behavior and may disturb females attempting to nest. Spotty distribution and specialized habitat 

requirements make this species vulnerable to local extirpation. 

F.2.8.

Dermochelys coriacea

LEATHERBACK SEA TURTLE

(See Seattle, Washington for information on this species)
2013 VGP and sVGP BE Appendix F

F-56

F.2.9.

Eretmochelys imbricata

HAWKSBILL SEA TURTLE

Family: Cheloniidae

Endangered: wherever found

Sources:

• UMMZ, 2012 

(http://animaldiversity.ummz.umich.edu/site/accounts/information/Eretmochelys_imbrica

ta.html)

• USFWS, 2012c

(http://www.fws.gov/northflorida/SeaTurtles/Turtle%20Factsheets/hawksbill-seaturtle.htm)

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=C00E)

• GLEC, 2011

Description:

The hawksbill is a small-to-medium-sized marine turtle with an elongated oval shell with 

overlapping scutes on the carapace, a relatively small head with a distinctive hawk-like beak, and 

flippers with two claws. General coloration is brown with numerous splashes of yellow, orange, 

or reddish-brown on the carapace. The plastron is yellowish with black spots on the intergular 

and postanal scutes. Juveniles are black or very dark brown with light brown or yellow 

coloration on the edge of the shell, limbs, and raised ridges of the carapace. As an adult, the 

hawksbill may reach up to 3 feet in length and weigh up to 300 lbs., although adults more 

commonly average about 2.5 feet in length and weigh between 95 to 165 lbs. It is the only sea 

turtle with a combination of two pairs of prefrontal scales on the head and four pairs of costal 

scutes on the carapace.

Geographic Boundaries and Spatial Distribution:

The hawksbill is found in tropical and subtropical regions of the Atlantic, Pacific, and Indian 

Oceans. The species is widely distributed in the Caribbean Sea and western Atlantic Ocean. In 

contrast to all other sea turtle species, hawksbills nest in low densities on scattered small 

beaches. The Gulf and Caribbean coasts of the Yucatán Peninsula, Mexico, where hawksbills 

nest on long expanses of beach in densities of 20 to 30 nests/km, are exceptions. 

Habitat: (has critical habitat)

Hawksbills frequent rocky areas, coral reefs, shallow coastal areas, lagoons or oceanic islands, 

and narrow creeks and passes. They are seldom seen in water deeper than 65 feet. Hatchlings are 

often found floating in masses of sea plants, and the females may nest on almost any undisturbed 

deep-sand beach in the tropics. Adult females are able to climb over reefs and rocks to nest in 

beach vegetation.

Designation of critical habitat for the hawksbill sea turtle was established September 1998 by 

NMFS, and includes coastal water surrounding Mona and Monita Islands, Puerto Rico. These 
2013 VGP and sVGP BE Appendix F

F-57

waters contain diverse and pristine coral reefs, which are directly related to the species’ highly 

specific diet of sponges. Additionally, the ledges and caves of reefs provide shelter for resting 

and refuge from predators. Hawksbills also utilize both low- and high-energy nesting beaches. 

Both insular and mainland nesting sites are known. Hawksbills will nest on small pocket beaches 

and, because of their small body size and great agility, can traverse fringing reefs that limit 

access to other species. Nesting within the southeastern United States occurs principally in 

Puerto Rico and in the U.S. Virgin Islands.

Life History:

The hawksbill feeds primarily on sponges and is most often associated with the coral reef 

community. Hawksbill turtles are exposed to cyanide dissolved in the water and through 

contaminated items in their diet.

The nesting season varies with locality, but in most locations these turtles nest between April and 

November. Hawksbills nest at night and, on average, about 4.5 times per season at intervals of 

approximately 14 days. In Florida and the U.S. Caribbean, clutch size is approximately 140 eggs, 

although several records exist of over 200 eggs per nest. The incubation period averages 60 days. 

Hawksbills are recruited into the reef environment at about 14 inches in length and are believed 

to begin breeding about 30 years later. However, the time required to reach 14 inches in length is 

unknown, and growth rates vary geographically. As a result, actual age at sexual maturity is not 

known.

Historical Information:

The hawksbill sea turtle was first listed on June 2, 1970. It is currently designated as endangered 

in the entire range. Within the United States, this species has been found in: Alabama, American 

Samoa, Connecticut, Delaware, Florida, Georgia, Guam, Hawaii, Louisiana, Massachusetts, 

Maryland, Northern Mariana Islands, Mississippi, North Carolina, New Jersey, New York, 

Puerto Rico, Rhode Island, South Carolina, Texas, Virginia, and the Virgin Islands.

Conservation Status:

The hawksbill sea turtle has experienced global population declines of 80 percent or more during 

the past century, and continued declines are projected. Most populations are declining, depleted, 

or are remnants of larger aggregations. Only five regional populations remain with more than 

1,000 females nesting annually (Seychelles, Mexico, Indonesia, and two in Australia). 

Summary of Major Threats:

The decline of this species is primarily due to human exploitation for tortoiseshell. While the 

legal hawksbill shell trade ended when Japan agreed to stop importing shell in 1993, a significant 

illegal trade continues. In addition, there are serious attempts by Cuba, with support from other 

countries, to delist hawksbills in Cuba to Appendix 2 of the Convention on International Trade in 

Endangered Species of Wild Fauna and Flora in order to make it possible to reopen trade with 

Japan and possibly other countries. Other threats include loss or degradation of nesting habitat 

from coastal development and beach armoring, disorientation of hatchlings by beachfront 

lighting, excessive nest predation by native and non-native predators, degradation of foraging 

habitat, marine pollution and debris accumulation, watercraft strikes and incidental take from 

commercial fishing operations.
2013 VGP and sVGP BE Appendix F

F-58

F.2.10.

Eubalaena glacialis

NORTH ATLANTIC RIGHT WHALE

Family: Balaenidae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=A02R)

• NOAA Fisheries, 2012 

(http://www.nmfs.noaa.gov/pr/species/mammals/cetaceans/rightwhale_northatlantic.htm)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Eubalaena+glaci

alis)

Description:

The Northern Atlantic right whale is a large baleen whale. Adults are generally between 45 and 

55 feet in length and can weigh up to 70 tons. Females are larger than males. The distinguishing 

features for right whales include a stocky body, generally black coloration (although some 

individuals have white patches on their undersides), lack of a dorsal fin, a large head (about 1/4 

of the body length), strongly bowed margin of the lower lip, and callosities on the head region. 

Two rows of long (up to about eight feet in length), dark baleen plates hang from the upper jaw, 

with about 225 plates on each side. The tail is broad, deeply notched, and all black with smooth 

trailing edge.

Geographic Boundaries and Spatial Distribution:

Right whales have occurred historically in all the world's oceans from temperate to subpolar 

latitudes. They primarily occur in coastal or shelf waters, although movements over deep waters 

are known. For much of the year, their distribution is strongly correlated to the distribution of 

their prey. During winter, right whales occur in lower latitudes and coastal waters where calving 

takes place. However, the whereabouts of much of the population during winter remains 

unknown. Right whales migrate to higher latitudes during spring and summer

Habitat: (has critical habitat)

The north Atlantic right whale (Eubalaena glacialis) has been sighted in waters off 

Massachusetts in most months. Most sightings occur between February and May, with peak 

abundance in late March. Right whales are frequently found in coastal or shelf waters, although 

movements over abyssal depths are known. The North Atlantic right whale is a migratory, slowswimming whale that often travels in small groups. Like many North Atlantic whales, the right 

whale spends the winter calving and mating in warmer waters and the summer feeding in cooler 

waters. 

There are five well-known habitats used annually by western North Atlantic right whales: 1) 

coastal Florida and Georgia, 2) the Great South Channel, east of Cape Cod, 3) Cape Cod and 

Massachusetts Bays, 4) the Bay of Fundy, and 5) Browns and Baccaro Banks, south of Nova 
2013 VGP and sVGP BE Appendix F

F-59

Scotia. The first three areas occur in U.S. waters and were designated by NMFS as critical 

habitat in June 1994 (59 FR 28793).

The five primary habitats used by northern right whales during their annual migration, as 

described by Kenney, Winn and Macaulay (1994), include the following three areas off the 

eastern coast of the United States: (1) A spring/ early summer feeding and nursery area for a 

majority of the population in the Great South Channel (GSC), (2) a late winter/spring feeding 

and nursery area for a small portion of the population in Cape Cod Bay (CCB), and (3) a winter 

calving ground and nursery area in the coastal waters of the southeastern United States (SEUS); 

and the following two areas located in Canadian waters: (4) a summer/fall feeding and nursery 

area for some animals, including nearly all mother/calf pairs, in the lower Bay of Fundy; and (5) 

a summer/fall feeding ground, with almost exclusively mature individuals, on the southern Nova 

Scotian shelf (73 FR 19000 19014).

NMFS has designated areas essential for the reproduction, rest and refuge, health, continued 

survival, conservation and recovery of the northern right whale population. The following areas 

are designated as critical habitat: Great South Channel: The area designated as critical habitat in 

these waters is bounded by the following coordinates: 41 deg.40'N/69 deg.45'W; 41 deg.00'N/69 

deg.05'W; 41 deg.38'N/68 deg.13'W; 42 deg.10'N/68 deg.31'W. Cape Cod Bay: The area 

designated as critical habitat in these waters is bounded by the following coordinates: 42 

deg.04.8'N/70 deg.10.0'W; 42 deg.12'N/70 deg.15'W; 42 deg.12'N/70 deg.30'W; 41 

deg.46.8'N/70 deg.30'W; and on the south and east, by the interior shoreline of Cape Cod, MA. 

Southeastern United States: The area designated as critical habitat in these waters encompasses 

waters between 31 deg.15'N (approximately located at the mouth of the Altamaha River, GA) 

and 30 deg.15'N (approximately Jacksonville, FL) from the shoreline out to 15 nautical miles 

offshore; and the waters between 30 deg.15'N and 28 deg.00'N (approximately Sebastian Inlet, 

FL) from the shoreline out to 5 nautical miles (73 FR 19000 19014).

Life History:

Most known right whale nursery areas are in shallow, coastal waters. In the western North 

Atlantic, calving takes place between December and March. In both the northern and southern 

hemisphere, females give birth to their first calf at an average age of nine years (Best et al., 1998; 

Hamilton et al., 1998a). Calves are 18-20 feet in length at birth (Best, 1994). Gestation lasts from 

357 to 396 days in southern right whales (Best, 1994), and it is likely to be similar in the 

northern species. Weaning seems to be variable, and has been reported as 8 to 17 months in 

North Atlantic right whales (Hamilton and Marx, 1995).

Various species of large sharks and killer whales may be predators of right whales, particularly 

for young or sick individuals. However, no such attacks have been observed in this species. Scars 

from killer whale attacks have been photographed on North Atlantic right whales (Kraus, 1990), 

although the level of killer whale attacks and the extent to which they result in death is not 

known. In the western North Atlantic, right whales feed primarily on copepods, with Calanus 

finmarchicus believed to be the primary prey (Kraus et al., 1988; Wishner et al., 1988; Murison 

and Gaskin, 1989). However, other zooplankters are also taken, including Pseudocalanus, 

Centropages, and even cyprids (Mayo and Marx, 1990). There is no evidence for consumption of 

euphausiids although, given the inclusion of this taxon in the diet of right whales elsewhere, it 
2013 VGP and sVGP BE Appendix F

F-60

would be surprising if North Atlantic right whales were different in this regard. Unlike 

balaenopterid whales, right whales are skimmers; they feed by continuously filtering prey 

through their baleen while moving, mouth agape, through a patch of zooplankton.

Feeding occurs from spring through fall, and also in winter in certain areas (e.g., Cape Cod Bay; 

Mayo and Marx, 1990). Oceanographic and bathymetric features, such as relatively cooler water 

temperatures and 100-200 m depths adjacent to steeply sloping bottom topography, also seem to 

be related to the utilization of certain areas for feeding (Winn et al., 1986; Clapham, 1999).

Historical Information:

Right whales have occurred historically in all the world’s oceans from temperate to subpolar 

latitudes. The pre-exploitation distribution of the North Atlantic right whale probably included 

coastal and continental shelf waters in temperate to subarctic latitudes of the North Atlantic 

Ocean. Post-exploitation distribution is much more limited.

The Northern right whale is among the rarest of all large whales, and among the rarest of all 

marine mammal species. Right whales have been listed as endangered under the Endangered 

Species Act (ESA) since its passage in 1973 (35 FR 8495). Although precise estimates of 

abundance are not available, it appears that the eastern North Atlantic population is nearly 

extinct and the western North Atlantic population numbers approximately 300 whales.

Conservation Status:

Historically, right whale populations were severely depleted by commercial whaling. More 

recently, direct and indirect impacts from human activities (mostly in the form of vessel 

collisions and entanglement in fishing gear) have contributed to a lack of recovery. While past 

population estimates were based on more limited information and may have been less accurate, 

the best estimate of population size for the North Atlantic right whale in 1991, when the first 

recovery plan was adopted, was 350 animals. The population is currently believed to contain 

only about 300 individuals and it remains unclear whether its abundance is static, undergoing 

modest growth or, as recent modeling exercises suggest, currently in decline. However, there has 

been no apparent sign of recovery in the last 15 years and the species may be rarer and more 

endangered than previously thought. Because the right whale is a long-lived species, extinction 

may not occur in the near future, but the possibility of biological extinction in the next century is 

very real.

Summary of Major Threats:

Ship collisions and entanglements in fishing gear are the most common anthropogenic causes of 

mortality in North Atlantic right whales. Other potential threats are habitat degradation, noise, 

contaminants, and climate and ecosystem change. It is necessary to further examine such threats 

to identify and modify activities that may pose risks to right whales.

Deaths resulting from human activities account for at least one-third of all known mortalities in 

the western North Atlantic right whale population (Kraus, 1990). The extent to which natural 

factors, such as disease and predation, affect mortality rates is not known. Kraus (1990) used 

photo-identification data from the western North Atlantic population to calculate an average 

mortality rate of 17 percent per year in first-year right whales, while second- through fourth year 
2013 VGP and sVGP BE Appendix F

F-61

whales had an average mortality rate of 3 percent per year. Including all sources of mortality, 

both natural and anthropogenic, 27 percent of all western North Atlantic right whales die before 

reaching four years of age (Kraus, 1990).

F.2.11.

Lepidochelys kempii

KEMP’S RIDLEY SEA TURTLE

Family: Cheloniidae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/species_profile/servlet/gov.doi.species_profile.servlets.SpeciesProfil

e?spcode=C00O)

• NJDEP, 2012 (http://www.nj.gov/dep/fgw/ensp/pdf/end-thrtened/marinetrtls.pdf)

• NOAA Fisheries, 2012 (http://www.nmfs.noaa.gov/prot_res/species/turtles/kemps.html)

• GLEC, 2011

Description:

The Kemp's Ridley and olive Ridley sea turtles are the smallest of all extant sea turtles, with the 

weight of an adult generally being less than 45 kg, and with the straight carapace length around 

65 cm. Adult Kemp's Ridleys' shells are almost as wide as long. Coloration changes significantly 

during development, from the grey-black carapace and plastron of hatchlings to the lighter greyolive carapace and cream-white or yellowish plastron of adults. There are two pairs of prefrontal 

scales on the head, five vertebral scutes, five pairs of coastal scutes and generally twelve pairs of 

marginals on the carapace. In each bridge adjoining the plastron to the carapace, there are four 

scutes, each of which is perforated by a pore. This is the external opening of Rathke's gland 

which secretes a substance of unknown function (possibly a pheromone). Males resemble the 

females in size and coloration. Secondary sexual characteristics of male sea turtles include a 

longer tail, a more distal vent, recurved claws and, during breeding, a softened mid-plastron. 

Eggs are 34-45 mm in diameter and 24-40 g in weight. Hatchlings range from 42-48 mm in 

straight line carapace length, 32-44 mm in width and 15-20 g in weight. 

Geographic Boundaries and Spatial Distribution:

Kemp's ridley sea turtles are distributed throughout the Gulf of Mexico and U.S. Atlantic 

seaboard, from Florida to New England. A few records exist for Kemp's ridley sea turtles near 

the Azores, waters off Morocco, and within the Mediterranean Sea. There is only one confirmed 

Kemp's ridley arribada in the state of Tamaulipas, Mexico, where nearly 95% of worldwide 

Kemp's ridley nesting occurs. The three main nesting beaches in Tamaulipas, Mexico are Rancho 

Nuevo, Tepehuajes, and Barra del Tordo. Nesting also occurs in Veracruz, Mexico, and Texas, 

U.S., but on a much smaller scale. Occasional nesting has been documented in North Carolina, 

South Carolina, and the Gulf and Atlantic coasts of Florida.
2013 VGP and sVGP BE Appendix F

F-62

Habitat: (no critical habitat)

Adult Kemp's ridleys primarily occupy "neritic" habitats. Neritic zones typically contain muddy 

or sandy bottoms where prey can be found. Their diet consists mainly of swimming crabs, but 

may also include fish, jellyfish, and an array of mollusks.

Depending on their breeding strategy, male Kemp's ridleys appear to occupy many different 

areas within the Gulf of Mexico. Some males migrate annually between feeding and breeding 

grounds, yet others may not migrate at all, mating with females opportunistically encountered.

Female Kemp's ridleys have been tracked migrating to and from nesting beaches in Mexico. 

Females leave breeding and nesting areas and continue on to foraging zones ranging from the 

Yucatán Peninsula to southern Florida. Some females take up residence in specific foraging 

grounds for months at a time, leading scientists to suggest that females have a goal-oriented 

migration, opposed to the suggested wandering strategy employed by olive ridleys. Kemp's 

ridleys rarely venture into waters deeper than 160 ft (50 m) (Byles and Plotkin, 1994).

Newly emerged hatchlings inhabit a much different environment than adult turtles. After 

emerging from the nest, hatchlings enter the water and must swim quickly to escape near shore 

predators. There is strong evidence that many sea turtle species employ an open ocean 

developmental stage because encounters with healthy, neonate sea turtles are extremely rare in 

near shore waters. Some hatchlings remain in currents within the Gulf of Mexico while others 

may be swept out of the Gulf, around Florida, and into the Atlantic Ocean by the Gulf Stream.

Juveniles of many species of sea turtles have been known to associate with floating sargassum 

seaweed, utilizing the sargassum as an area of refuge, rest, and/or food. This developmental 

drifting period is hypothesized to last about two years or until the turtle reaches a carapace length 

of about 8 inches (20 cm). Subsequently, these sub-adult turtles return to neritic zones of the 

Gulf of Mexico or northwestern Atlantic Ocean to feed and develop until they reach adulthood 

(Collard and Ogren, 1990).

On February 17, 2010, NOAA Fisheries and USFWS were jointly petitioned to designate critical 

habitat for Kemp's ridley sea turtles for nesting beaches along the Texas coast and marine 

habitats in the Gulf of Mexico and Atlantic Ocean. They are currently reviewing the petition.

Life History:

Neonatal Kemp's ridleys feed on the available sargassum and associated infauna or other 

epipelagic species found in the Gulf of Mexico. In post-pelagic stages, the Kemp’s ridley is 

largely a crab-eater, with a preference for portunid crabs. The turtles are exposed to cyanide 

dissolved in seawater and through contaminated items in their diet. Age at sexual maturity is not 

known, but is believed to be approximately 7-15 years, although other estimates of age at 

maturity range as high as 35 years. Female Kemp's ridleys nest from May to July, laying two to 

three clutches of approximately 100 eggs, which incubate for 50-60 days.

Historical Information:

The Kemp's ridley sea turtle was first listed on December 2, 1970. It is currently designated as 

endangered in the entire range. Within the United States, this species is has been observed in: 
2013 VGP and sVGP BE Appendix F

F-63

Alabama, Connecticut, Delaware, Florida, Georgia, Louisiana, Massachusetts, Maryland, 

Mississippi, North Carolina, New Jersey, New York, Rhode Island, South Carolina, Texas, 

Virginia; the Mexico-Atlantic Coast, and in tropical and temperate waters in the Atlantic Basin.

Conservation Status:

The Kemp's ridley has experienced a historical, dramatic decrease in arribada size. An amateur 

video from 1947 documented an extraordinary Kemp's ridley arribada near Rancho Nuevo. It has 

been estimated that approximately 42,000 Kemp's ridleys nested during that single day. This 

video has also served to measure the species' collapse. Twenty years after the video was filmed, 

the largest arribada measured was just 5,000 individuals. Between the years of 1978 and 1991 

only 200 Kemp's ridleys nested annually. Today, the Kemp's ridley population appears to be in 

the early stages of recovery. Nesting has increased steadily over the past decade.

During the 2000 nesting season, an estimated 2,000 females nested at Rancho Nuevo, a single 

arribada of 1,000 turtles was reported in 2001, and an estimated 3,600 turtles produced over 

8,000 nests in 2003. In 2006, a record number of nests were recorded since monitoring began in 

1978; 12,143 nests were documented in Mexico, with 7,866 of those at Rancho Nuevo.

On the Texas coast, 251 Kemp's ridley nests were recorded from 2002-2006. For the 2007 

nesting season, 127 nests have been recorded in Texas, with 73 of those nests documented at 

Padre Island National Seashore. Those 127 nests are a record for the Texas coast, passing the 

2006 record of 102 nests.

Summary of Major Threats:

Kemp's ridleys face threats on both nesting beaches and in the marine environment. The greatest 

cause of decline and the continuing primary threat to Kemp's ridleys is incidental capture in 

fishing gear, primarily in shrimp trawls, but also in gill nets, longlines, traps and pots, and 

dredges in the Gulf of Mexico and North Atlantic. It is estimated that before the implementation 

of turtle exclusion devices, the commercial shrimp fleet killed 500-5000 Kemp's Ridley each 

year. Beginning in 1976, the U.S. and Mexican governments agreed to phase out U.S. shrimping 

in Mexican waters by 1979. U.S. shrimp vessels continued to illegally operate off Mexico 

through the mid-1980s. The Mexican shrimp fleet has declined and consists of only 

approximately 600 vessels, many of which do not operate. Also since 1978, Mexico has closed 

the nearshore waters off Rancho Nuevo to fishing during the nesting season. However, this 

closure has not been strictly enforced. 

Dredging operations affect Kemp's Ridley turtles through incidental take and by degrading the 

habitat. Incidental take of Kemp’s Ridley has been documented with hopper dredges. In addition 

to direct take, channelization of the inshore and nearshore areas can degrade foraging and 

migratory habitat through spoil dumping, degraded water quality/clarity and altered current flow. 

Egg collection was an extreme threat to the population, but since nesting beaches were afforded 

official protection in 1966, this threat no longer poses a major concern.

F.2.12.

Megaptera novaeangliae

HUMPBACK WHALE
2013 VGP and sVGP BE Appendix F

F-64

(See Seattle, Washington for information on this species)

F.2.13.

Myotis sodalis

INDIANA BAT

Family: Vespertilionidae

Endangered: wherever found 

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=A000)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Myotis+sodalist)

• USFWS, 2012b (http://ecos.fws.gov/docs/recovery_plan/070416.pdf)

Description:

The Indiana bat is a medium-sized Myotis, closely resembling the little brown bat (Myotis 

lucifugus) but differing in coloration. Its fur is a dull grayish chestnut rather than bronze, with the 

basal portion of the hairs on the back a dull-lead color. This bat's underparts are pinkish to 

cinnamon, and its hind feet are smaller and more delicate than in M. lucifugus. The calcar (heel 

of the foot) is strongly keeled. 

Geographic Boundaries and Spatial Distribution:

The range extends west to the western Ozark region in eastern Oklahoma (Saugey et al. 1990) 

and Iowa (Clark et al. 1987), north and east to Michigan (Evers 1992, Kurta and Teramino 1994, 

Kurta 1995), New York, New England, and northern New Jersey, and south to northern Alabama 

and Arkansas, with accidental/nonregular occurrences outside this range. 

Northern populations migrate south to Alabama, Tennessee, Kentucky, Indiana, Missouri, and 

West Virginia for winter. In winter, they are apparently absent from Michigan, Ohio, and 

northern Indiana where suitable caves and mines are unknown. The most important hibernating 

caves are: Bat Wing and Twin Domes caves (Indiana); Bat, Hundred Dome, and Dixon caves 

(Kentucky); and Bat Cave, Great Scott Cave, and Pilot Knob Mine (Missouri); Pilot Knob Mine 

is the largest colony (Lowe 1990). Half of the total population hibernates in southern Indiana.

Habitat: (has critical habitat)

During winter, Indiana bats are restricted to suitable underground hibernacula. The vast majority 

of these sites are caves located in karst areas of the east-central United States; however, Indiana 

bats also hibernate in other cave-like locations, including abandoned mines. Suitable hibernacula 

in the central and southern United States often provide a wide range of vertical structure. These 

hibernacula tend to have large volumes and often have large rooms and vertical or extensive 

passages, often below the lowest entrance. Cave volume and complexity help buffer the cave 

environment against rapid and extreme changes in outside temperature, and vertical relief helps 

provide a range of temperatures and roost sites. Most Indiana bats hibernate in caves or mines 

where the ambient temperature remains below 10°C (50.0°F) but infrequently drops below 

freezing, and the temperature is relatively stable.
2013 VGP and sVGP BE Appendix F

F-65

In summer, most reproductive females occupy roost sites under the exfoliating bark of dead trees 

that retain large, thick slabs of peeling bark. Primary roosts usually receive direct sunlight for 

more than half the day. Roost trees are typically within canopy gaps in a forest, in a fence line, or 

along a wooded edge. Habitats in which maternity roosts occur include riparian zones, 

bottomland and floodplain habitats, wooded wetlands, and upland communities. Indiana bats 

typically forage in semi-open to closed (open understory) forested habitats, forest edges, and 

riparian areas.

Critical habitat was designated for this species on 24 September 1976 (41 FR 41914). These cave 

and mine refuges are necessary for seasonal wintering. The following areas (exclusive of those 

existing man-made structures or settlements which are not necessary to the normal needs or 

survival of the species) are considered critical habitat for the Indiana bat;

(1) Illinois. The Blackball Mine, La Salle County

(2) Indiana. Big Wyandotte Cave, Crawford County; Bay’s Cave, Greene County

(3) Kentucky. Bat Cave, Carter County; Coach Cave, Edmonson County

(4) Missouri. Cave 021, Crawford County; Cave 009, Franklin County; Cave 017, Franklin 

County; Pilot Knob Mine, Iron County; Bat Cave, Shannon County; Cave 029, Washington 

County [numbers assigned by Division of Ecological Services, U.S. Fish and Wildlife Service, 

Region].

(5) Tennessee. White Oak Blowhole Cave, Blount County

(6) West Virginia. Hellhole Cave, Pendleton County.

Life History:

The Indiana bat is a temperate, insectivorous, migratory bat that hibernates colonially in caves 

and mines in the winter. In spring, reproductive females migrate and form maternity colonies 

where they bear and raise their young in wooded areas. Males and nonreproductive females 

typically do not roost in colonies and may stay close to their hibernaculum or migrate to summer 

habitat. Both males and females return to hibernacula in late summer or early fall to mate and 

enter hibernation.

Biologically intrinsic needs of this species include limiting use of fat during hibernation, obligate 

colonial roosting, high energy demands of pregnant and nursing females, and timely parturition 

and rapid development and weaning of young. Factors that may exacerbate the bats vulnerability 

because of these constraints include energetic impacts of significant disruptions to roosting areas 

(both in hibernacula and maternity colonies), availability of hibernation habitat, and connectivity 

and conservation of roosting-foraging and migration corridors.
2013 VGP and sVGP BE Appendix F

F-66

Historical Information:

Historically, the Indiana bat had a winter range restricted to areas of cavernous limestone in the 

karst regions of the east-central United States (Miller and Allen, 1928, Hall, 1962, Thomson 

1982, Figure 1). Prior to and during much of the European settlement of the eastern United 

States, winter populations of Indiana bats likely occurred in karst regions of what would 

eventually become Alabama, Arkansas, Georgia, Illinois, Indiana, Iowa, Kentucky, Maryland, 

Massachusetts, Missouri, New Jersey, New York, North Carolina, Oklahoma, Pennsylvania, 

Tennessee, Vermont, Virginia, and West Virginia. Based on early accounts and other indirect 

evidence (Silliman et al., 1851, Blatchley, 1897, Tuttle, 1997, Tuttle, 1999), some researchers 

have suggested that vast numbers, presumably the majority, of Indiana bats historically 

converged at a relatively small number of large complex cave systems to hibernate (e.g., 

Wyandotte Cave in Indiana; Bat, Coach, and Mammoth caves in Kentucky; Great Scott Cave in 

Missouri; and Rocky Hollow Cave in Virginia) and used other caves to a lesser extent (Olson,

1996; Tuttle, 1997; Tuttle, 1999; Toomey et al., 2002; Whitaker et al., 2003).

The historic summer distribution and range for this species is poorly documented. The first 

maternity colony was not discovered until the summer of 1971 in east-central Indiana (Cope et 

al., 1974). Nonetheless, based on our current knowledge of Indiana bat seasonal migration 

patterns and limits, and locations of historic and potential hibernacula, it is reasonable to assume

that the species’ historic summer distribution was more or less similar to its current summer 

distribution.

Conservation Status:

The species was originally listed as in danger of extinction under the Endangered Species 

Preservation Act of 1966, and is currently listed as endangered. The current Recovery Priority of 

the Indiana Bat is 8, which means that the species has a moderate degree of threat and high 

recovery potential. As of October 2006, the Service had records of extant winter populations at 

approximately 281 hibernacula in 19 states and 269 maternity colonies in 16 states. The 2005 

winter census estimate of the population was 457,000.

Summary of Major Threats:

Threats to the Indiana bat vary during its annual cycle. At the hibernacula, threats include 

modifications to caves, mines, and surrounding areas that change airflow and alter microclimate 

in the hibernacula. Human disturbance and vandalism pose significant threats during hibernation 

through direct mortality and by inducing arousal and consequent depletion of fat reserves. 

Natural catastrophes can also have a significant effect during winter because of the concentration 

of individuals in a relatively few sites. During summer months, possible threats relate to the loss 

and degradation of forested habitat. Migration pathways and swarming sites may also be affected 

by habitat loss and degradation. In addition to these threats, significant information gaps remain 

regarding the species’ ecology that hinder sound decision-making on how best to manage and 

protect the species.

F.2.14.

Sterna dougallii dougallii

ROSEATE TERN

Family: Laridae
2013 VGP and sVGP BE Appendix F

F-67

Endangered: Northeast U.S. nesting population (CT, ME, MA, NJ, NY, NC, RI, and VA)

Threatened: Western hemisphere except northeast U.S. (FL, GA, SC, Puerto Rico and U.S. 

Virgin Islands) 

Sources:

• NJDEP, 2012 (http://www.nj.gov/dep/fgw/ensp/pdf/end-thrtened/roseatetern.pdf)

• USFWS, 2012b (http://ecos.fws.gov/speciesProfile/SpeciesReport.do?spcode=B07O)

• NYDEC, 2012 (http://www.dec.ny.gov/animals/7084.html)

• GLEC, 2011

Description:

The roseate tern is a medium-sized, light colored tern with a dark cap and long tail. In breeding 

plumage, the adult has a black cap and nape, and a pale gray back and lower wing surface. Black 

tips on the outer primaries contrast with the otherwise pale upper surface of the wing. The tail is 

white and deeply forked with long streamers. On perched birds, the tail extends beyond the 

wingtips. The bill is black with a dark red base. The legs and feet are dark red and the iris is 

brownish-black. Sexes are alike in plumage. The non-breeding adult has brown legs, a black bill, 

and a white forehead with a black mask extending from the eye to the nape.

Geographic Boundaries and Spatial Distribution:

In North America, the roseate tern breeds in two discrete areas: from Nova Scotia to Long Island, 

New York (northeastern population), and around the Caribbean Sea (including the Florida Keys). 

It is believed to winter in northern South America and along the Brazilian coast. 

Habitat: (no critical habitat)

The roseate tern is a coastal species that nests on barrier islands and salt marshes and forages 

over shallow coastal waters, inlets, and offshore seas. Nesting colonies are located above the 

high-tide line, often within vegetated dunes where dense concentrations of beach grasses and 

seaside goldenrod (Solidago sempervirens) provide cover. In comparison to other terns, roseate 

terns nest at sites with more vegetative cover. Infrequently, they may nest in open areas, 

especially when they are displaced from optimal sites by gulls.

Life History:

Roseate terns arrive on their Atlantic coast breeding grounds in late April or early May and begin 

nesting one month later. In New York, roseate terns are always found nesting with common 

terns. The nest may be only a depression in sand, shell or gravel, and may be lined with bits of 

grass and other debris. It is usually placed in dense grass clumps, or even under boulders or riprap. Both adults incubate the eggs for about 23 days, and the young fledge in 22- 29 days. One 

brood per season is typical, although two broods are sometimes produced. Migration begins in 

late summer. One banded individual from Great Gull Island, New York was 9 years old when 

recovered. The Roseate tern is an aquatic-dependent species that feeds primarily on small 

freshwater and marine fishes.

Historical Information:

From the late 1800s to the early 1900s, roseate tern populations along the Atlantic Coast were 

greatly reduced as a result of the millinery trade, in which birds were killed to acquire plumes for 
2013 VGP and sVGP BE Appendix F

F-68

women’s hats. The Migratory Bird Treaty Act of 1918, which afforded legal protection to all 

migratory birds, coupled with a change in fashion styles, reduced the pressure on roseate terns, 

enabling populations to reestablish and increase. However, by the 1950s, populations again 

began to decline, and continued to do so for several decades.

The roseate tern was first listed on November 02, 1987. It is currently designated as endangered 

in the U.S.A. (Atlantic Coast south to NC), Canada (Newfoundland, Nova Scotia, Quebec), and 

Bermuda. Within the United States, this species has been observed in: Connecticut, 

Massachusetts, Maine, North Carolina, New Jersey, New York, Rhode Island, Virginia; and 

Canada (Newfoundland, Nova Scotia and Quebec).

Conservation Status:

The total world population was estimated in 1998 at approximately 40,000 pairs. The 

northeastern population has recently fluctuated around 3,500 pairs, with a low of 3,125 in 1992, 

and a high of 3,775 in 1996; including 125 pairs in Canada. Various estimates placed the 

Caribbean population at between 5,000 and 8,500 pairs in 1993, and the Florida breeding 

population at about 350 pairs in 1995.

Summary of Major Threats:

Threats to the roseate tern include habitat loss on or near coastal barrier islands from 

development, and disturbance of beach-nesting birds from human recreation and other activities 

in coastal areas. Predation by great black-backed (Larus marinus) and herring (Larus argentatus) 

gulls is a threat in areas where human garbage provides an abundant food supply to attract and 

support these predator species (USFWS, 1993). Reports of threat due to pollutants are extremely 

limited. Limited data are available for organochlorine contaminants, mercury, and oil pollution 

(USFWS, 1993).

F.3. HOUSTON, TEXAS

F.3.1.

Balaenoptera physalus

FINBACK WHALE

(See New York, New York for information on this species)

F.3.2.

Caretta caretta

LOGGERHEAD SEA TURTLE

(See New York, New York for information on this species)

F.3.3.

Charadrius melodus

PIPING PLOVER

(See New York, New York for information on this species)

F.3.4.

Chelonia mydas

GREEN SEA TURTLE
2013 VGP and sVGP BE Appendix F

F-69

(See Seattle, Washington for information on this species)

F.3.5.

Dermochelys coriacea

LEATHERBACK SEA TURTLE

(See Seattle, Washington for information on this species)

F.3.6.

Eretmochelys imbricate

HAWKSBILL SEA TURTLE

(See New York, New York for information on this species)

F.3.7.

Grus americana

WHOOPING CRANE

Family: Gruidae

Endangered: wherever found, except where experimental population

Experimental Population, Non-Essential: AL, AK, GA, IL, IN, IA, KY, LA, MS, MN, MI, MO, 

NC, OH, SC, TN, VA, WI, WV, CO, ID, FL, NM, and UT

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=B003)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Grus+americana

)

Description:

The whooping crane occurs only in North America and is North America’s tallest bird, with 

males approaching 5 feet when standing erect. The whooping crane adult plumage is snowy 

white except for black primaries, black or grayish alula (specialized feathers attached to the 

upper leading end of the wing), sparse black bristly feathers on the carmine crown and malar 

region (side of the head from the bill to the angle of the jaw), and a dark gray-black wedgeshaped patch on the nape. The common name "whooping crane" probably originated from the 

loud, single-note vocalization given repeatedly by the birds when they are alarmed. Whooping 

cranes are a long-lived species; current estimates suggest a maximum longevity in the wild of at 

least 30 years. 

Geographic Boundaries and Spatial Distribution:

Current distribution includes just three populations: (1) the Aransas-Wood Buffalo National Park 

Population that nests in Wood Buffalo National Park and adjacent areas in Canada (south-central 

Mackenzie and adjacent northern Alberta) and winters in coastal marshes in Texas, with 

significant migration stopovers in southern Saskatchewan, Nebraska, Kansas, and Oklahoma; (2) 

a reintroduced non-migratory Florida Population that occurs in central Florida; and (3) a 

reintroduced Eastern Migratory Population that migrates between Wisconsin (Necedah National 

Wildlife Refuge) and Florida (Chassahowitzka NWR) (CWS and USFWS, 2007).
2013 VGP and sVGP BE Appendix F

F-70

Habitat: (has critical habitat)

The whooping crane breeds, migrates, winters, and forages in a variety of wetland and other 

habitats, including coastal marshes and estuaries, inland marshes, lakes, ponds, wet meadows 

and rivers, and agricultural fields. Whooping cranes breed and nest in wetland habitat in WoodBuffalo National Park, Canada. Bulrush is the dominant vegetation type in the potholes used for 

nesting, although cattail, sedge, musk-grass, and other aquatic plants are common. Nest sites are 

primarily located in shallow diatom ponds that contain bulrush. During migration, whooping 

cranes use a variety of habitats; however wetland mosaics appear to be the most suitable. For 

feeding, whooping cranes primarily use shallow, seasonally and semi permanently flooded 

palustrine wetlands for roosting, and various cropland and emergent wetlands. In Nebraska, 

whooping cranes also often use riverine habitats. Wintering habitat in the Aransas National 

Wildlife Refuge, Texas, includes salt marshes and tidal flats on the mainland and barrier islands, 

dominated by salt grass, saltwort, smooth cordgrass, glasswort, and sea ox-eye.

Critical habitat determination was finalized June 1978 and included the following areas:

Monte Vista National Wildlife Refuge (Colorado), Alamosa National Wildlife Refuge 

(Colorado), Grays Lake National Wildlife Refuge and vicinity (Idaho), Cheyenne Bottoms State 

Waterfowl Management Area (Kansas), Quivira National Wildlife Refuge (Kansas), Platte River 

Bottoms between Lexington and Dehman (Nebraska), Bosque del Apache National Wildlife 

Refuge (New Mexico), Salt Plains National Wildlife Refuge (Oklahoma), and Aransas National 

Wildlife Refuge and vicinity (Texas) (43 FR 20938 20942).

In August 2007, the U.S. Fish and Wildlife Service determined that whooping crane populations 

in four areas were considered experimental and nonessential, and thus delisted as critical habitat. 

Those areas include Bosque del Apache National Wildlife Refuge (New Mexico), Monte Vista 

National Wildlife Refuge (Colorado), Alamosa National Wlidlife Refuge (Colorado), and Grays 

Lake National Wildlife Refuge (Idaho) (72 FR 29544).

Life History:

Whooping cranes are omnivorous, probing the soil subsurface with their bills and taking foods 

from the soil surface or vegetation. Young chicks are fed by their parents. Summer foods include 

large nymphal or larval forms of insects, frogs, rodents, small birds, minnows, and berries. Foods 

utilized during migration are poorly documented but include frogs, fish, plant tubers, crayfish, 

insects, and agricultural grains. The largest amount of time is spent feeding in harvested grain 

fields. In the winter, whooping cranes forage for blue crabs, clams and the plant wolfberry in the 

brackish bays, marshes, and salt flats on the edge of the Texas mainland and on barrier islands. 

Occasionally, cranes fly to upland sites when attracted by fresh water to drink or by foods such 

as acorns, snails, crayfish and insects, and then return to the marshes to roost. Uplands are 

particularly attractive when partially flooded by rainfall, burned to reduce plant cover or when 

food is less available in the salt flats and marshes. 

The whooping crane is a bi-annual migrant, traveling between its summer habitat in central 

Canada, and its wintering grounds on the Texas coast, across the Great Plains of the U.S. in the 

spring and fall of each year. The migratory corridor runs in an approximately straight line from 

the Canadian Prairie Provinces of Alberta and Saskatchewan through the Great Plains states of 

eastern Montana, North Dakota, South Dakota, Nebraska, Kansas, Oklahoma, and Texas. The 
2013 VGP and sVGP BE Appendix F

F-71

complete corridor is approximately 2,400 miles long by 220 miles wide, a zone that encompasses 

95% of known sightings of whooping cranes. Autumn migration normally begins in midSeptember, with most birds arriving on the Texas wintering grounds between late October and 

mid-November. Whooping cranes migrate south as singles, pairs, in family groups, or as small 

flocks of 3 to 5 birds. They are diurnal migrants and stop daily to feed and rest. Local weather 

conditions influence distance and direction of travel, but whooping cranes generally are capable 

of reaching the autumn staging grounds in the north central portion of the Saskatchewan 

agricultural area on the second day of migration, where they remain for 2 to 4 weeks. The 

remainder of the migration from Saskatchewan to the wintering grounds is usually rapid, 

probably weather-induced, and may be completed in a week. Whooping cranes occupy winter 

areas for almost half a year. Although close association with other whooping cranes is tolerated 

at times on the wintering grounds, pairs and family groups typically occupy and defend relatively 

discrete territories. As spring approaches, “dancing” behavior (running, leaping and bowing, 

unison calling, and flying) increases in frequency, and is indicative of pre-migratory restlessness. 

Spring migration departure dates are normally between March 25 and April 15, with the last 

birds usually leaving by May 1. 

Whooping cranes are monogamous, forming pairs and laying eggs as early as three years of age, 

although the average age of first egg production is five years. They show considerable fidelity to 

their breeding territories, and normally nest in the same general vicinity each year. These nesting 

territories, termed "composite nesting areas", vary considerably in size, ranging from about 0.8 to 

29 mi2 but averaging 2.5 mi2

. Adjoining pairs usually nest at least 0.6 miles apart. From the 

initiation of egg laying until chicks are a few months of age, the activities of pairs and family 

groups are restricted to the breeding territory. Eggs are normally laid in late April to mid-May, 

and hatching occurs about one month later. The incubation period is from 29 to 31 days. 

Whooping cranes usually produce clutches of two eggs laid 48-60 hours apart. Incubation begins 

with the first egg laid, resulting in asynchronous hatching of the eggs. This asynchrony may 

follow the “insurance” hypothesis, where parents add marginal offspring to their clutch/brood as 

a hedge against early failure of core brood members. Whooping crane parents share incubation 

and brood-rearing duties. Except for brief intervals, one member of the pair remains on the nest 

at all times.

Historical Information:

The historical range extended from the Arctic coast of North America south to central Mexico, 

and from Utah east to New Jersey, South Carolina, Georgia, and Florida; in the 19th and 20th

centuries, nesting occurred principally in the region extending from central Canada to the northcentral United States (see CWS and USFWS, 2007).

USFWS proposed to reintroduce whooping cranes into historic breeding habitat in Wisconsin; 

the population would winter in Florida and be designated a nonessential experimental population 

(Federal Register, 9 March 2001). On June 26, 2001, the final rule was passed to designate the 

eastern United States as an experimental nonessential population. Introduced Florida population 

is listed by USFWS as an experimental nonessential population (Federal Register, 22 January 

1993). In 1996, USFWS proposed to designate the Rocky Mountains population as an 

experimental nonessential population (Federal Register, 6 February 1996). Rocky Mountain 

population designated as experimental nonessential (Federal Register 21 July 1997). 
2013 VGP and sVGP BE Appendix F

F-72

Southwestern Louisiana population designated as an experimental nonessential population, 

which will include the entire state of Louisiana as the geographic boundary (Federal Register, 3 

February 2011). Everywhere else it is listed by USFWS as Endangered (Federal Register, 21 July 

1997).

Conservation Status:

Whooping cranes currently exist in the wild at three locations and in captivity at twelve sites. 

The July 2010 total wild population was estimated at 383. There is only one self-sustaining wild 

population, the Aransas-Wood Buffalo National Park population, which nests in Wood Buffalo 

National Park and adjacent areas in Canada, and winters in coastal marshes in Texas at Aransas. 

In addition, there is a small captive-raised, non-migratory population in central Florida, and a 

small migratory population of individuals introduced beginning in 2001 that migrate between 

Wisconsin and Florida in an eastern migratory population. The last remaining wild bird in the 

reintroduced Rocky Mountain Population died in the spring of 2002. The captive population 

contained 152 birds in July, 2010, with annual production from the Calgary Zoo, International 

Crane Foundation, Patuxent Wildlife Research Center, Audubon Species Survival Center, and 

the San Antonio Zoo. The total population of wild and captive whooping cranes in July, 2010, 

was 535.

Summary of Major Threats:

Historically, population declines were caused by shooting and destruction of nesting habitat in 

the prairies from agricultural development. The species was listed because of low population 

numbers, slow reproductive potential (sexual maturity is delayed and pairs average less than one 

chick annually), cyclic nesting and wintering habitat suitability, a hazardous 2,500 mile 

migration route that is traversed twice annually, and many human pressures on the wintering 

grounds. Current threats to wild cranes include collisions with manmade objects such as power 

lines and fences, shooting, chemical spills along the intracoastal waterways that bisects its winter 

habitat, predators, disease, habitat destruction, severe weather, and a loss of two thirds of the 

original genetic material. Threats to the captive flock include disease, accidents, and in-breeding. 

F.3.8.

Lepidochelys kempii

KEMP’S RIDLEY SEA TURTLE

(See New York, New York for information on this species)

F.3.9.

Megaptera novaeangliae

HUMPBACK WHALE

(See Seattle, Washington for information on this species)

F.3.10.

Pristis pectinata

SMALLTOOTH SAWFISH

Family: Pristidae

Endangered: wherever found
2013 VGP and sVGP BE Appendix F

F-73

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=E0A9)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Pristis+pectinata

)

• NOAA Fisheries, 2012 

(http://www.nmfs.noaa.gov/pr/species/fish/smalltoothsawfish.htm)

• USFWS, 2012b (http://ecos.fws.gov/docs/recovery_plan/smalltoothsawfish.pdf)

Description:

Sawfish, like sharks, skates and rays, belong to a group of fish called elasmobranchs, whose 

skeletons are made of cartilage. Sawfish are actually modified rays with a shark-like body and 

gill slits on their ventral side. Early sawfish arose around 100 million years ago, but these first 

sawfish are actually distant cousins to modern day sawfishes, which first appeared around 56 

million years ago. Sawfish get their name from their "saws" (long, flat snouts edged with pairs of 

teeth) which are used to locate, stun, and kill prey. Their diet includes mostly fish but also some 

crustaceans. Smalltooth sawfish is one of two species of sawfish that inhabit U.S. waters. 

Smalltooth sawfish commonly reach 18 feet in length, and may grow to 25 feet. Little is known 

about the life history of these animals, but they may live up to 25-30 years, maturing after about 

10 years.

Geographic Boundaries and Spatial Distribution:

Smalltooth sawfish have been reported in the Pacific and Atlantic Oceans, and Gulf of Mexico; 

however, the U.S. population is found only in the Atlantic Ocean and Gulf of Mexico. 

Historically, the U.S. population was common throughout the Gulf of Mexico from Texas to 

Florida, and along the east coast from Florida to Cape Hatteras. The current range of this species 

has contracted to peninsular Florida, and smalltooth sawfish are relatively common only in the 

Everglades region at the southern tip of the state.

Habitat: (has critical habitat)

Sawfish species inhabit shallow coastal waters of tropical seas and estuaries throughout the 

world. They are usually found in shallow waters very close to shore over muddy and sandy 

bottoms. They are often found in sheltered bays, on shallow banks, and in estuaries or river 

mouths. Certain species of sawfish are known to ascend inland in large river systems, and they 

are among the few elasmobranchs that are known from freshwater systems in many parts of the 

world. Larger animals can be found in the same habitat, but are also found offshore at depths up 

to at least 400 feet.

According to the U.S. Fish and Wildlife Service, smalltooth sawfish have no designated critical 

habitat. However, NMFS designated critical habitat for smalltooth sawfish in September 2009 

(74 FR 45353). The critical habitat consists of two units: the Charlotte Harbor Estuary Unit, 

which comprises approximately 221,459 acres of coastal habitat; and the Ten Thousand Islands/ 

Everglades Unit (TTI/E), which comprises approximately 619,013 acres of coastal habitat. The
2013 VGP and sVGP BE Appendix F

F-74

two units are located along the southwestern coast of Florida between Charlotte Harbor and 

Florida Bay. These areas are considered nursery areas used by juveniles as critical habitat. 

Juvenile smalltooth sawfish use highly specific nearshore areas as nursery areas for the first 

several years of their lives, where vulnerable juveniles find protection from predators and ample 

food resources for early stage growth. Juvenile sawfish need several essential physical and 

biological features: red mangroves and shallow, euryhaline habitats characterized by water 

depths between the mean high water line and 3 ft (0.9 m) measured at mean lower low water. 

Life History:

Life history characteristics are a limiting factor for the species’ ability to recover. Sawfish are 

slow growing, late maturing, and produce small numbers of young; hence, recovery will take 

decades, even if all threats are effectively eliminated. Like many elasmobranchs, smalltooth 

sawfish are ovoviviparous, meaning the mother holds the eggs inside of her until the young are 

ready to be born, usually in litters of 15 to 20 pups.

Bigelow and Schroeder (1953) reported that sawfish in general subsist chiefly on small schooling 

fish, such as mullets and clupeids. Bigelow and Schroeder also reported that they feed to some 

extent on crustaceans and other bottom dwelling inhabitants. Breder (1952), in summarizing the 

literature on observations of sawfish feeding behavior, noted that they attack fish by slashing 

sideways through schools, and often impale the fish on their rostral teeth. These are subsequently 

scraped off the teeth by rubbing them on the bottom and then ingested whole. The oral teeth of 

sawfish are ray-like, having flattened cusps that are better suited to crushing or gripping. 

Historical Information:

The smalltooth sawfish is a tropical marine and estuarine elasmobranch fish that has been 

reported to have a circumtropical distribution. In the western Atlantic, the smalltooth sawfish has 

been reported from Brazil through the Caribbean and Central America, the Gulf of Mexico, and 

the Atlantic coast of the United States. The smalltooth sawfish has also been recorded from 

Bermuda (Bigelow and Schroeder 1953). Forms of smalltooth sawfish have been reported from 

the eastern Atlantic in Europe and West Africa; the Mediterranean; South Africa; and the IndoWest Pacific, including the Red Sea, India, Burma, and the Philippines (Bigelow and Schroeder 

1953; Van der Elst 1981; Compagno and Cook 1995). Whether populations outside the Atlantic 

are truly smalltooth sawfish or closely related species is unknown (Adams and Wilson 1995). 

Pacific coast records of smalltooth sawfish off Central America need confirmation (Bigelow and 

Schroeder, 1953; Compagno and Cook, 1995).

The smalltooth sawfish was listed as endangered under the Endangered Species Act of 1973, as 

amended (ESA) on April 1, 2003 (68 FR 15674) in response to a 1999 listing petition from The 

Ocean Conservancy (formerly the Center for Marine Conservation). 

Conservation Status:

No accurate estimates of abundance trends over time are available for this species. However, 

available records, including museum records and anecdotal fisher observations, indicate that this 

species was once common throughout its historic range and that smalltooth sawfish have 

declined dramatically in U.S. waters over the last century. Based on the contraction in range and 
2013 VGP and sVGP BE Appendix F

F-75

anecdotal data, it is likely that the population is currently at a level less than 5% of its size at the 

time of European settlement.

Summary of Major Threats:

The primary reason for the decline of the smalltooth sawfish population has been by catch in 

various commercial and recreational fisheries, due to high propensity for entanglement in net 

gear. The secondary reason for the decline of the smalltooth sawfish population is habitat loss 

and degradation. Other threats to the species include entanglement in marine debris, injury from 

saw removal, pollution, and disturbance of natural behavior by divers and other marine activities.

F.3.11.

Trichechus manatus

WEST INDIAN MANATEE

Family: Trichechidae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=A007)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Trichechus+man

atus)

Description:

Manatees are marine mammals found in marine, estuarine, and freshwater environments. The 

West Indian manatee, Trichechus manatus, includes two distinct subspecies, the Florida manatee 

(Trichechus manatus latirostris) and the Antillean manatee (Trichechus manatus manatus). 

While morphologically distinctive, both subspecies have many common features. Manatees have 

large, seal-shaped bodies with paired flippers and a round, paddle-shaped tail. They are typically 

grey in color (color can range from black to light brown) and occasionally spotted with barnacles 

or colored by patches of green or red algae. The muzzle is heavily whiskered and coarse, single 

hairs are sparsely distributed throughout the body. Adult manatees, on average, are about nine 

feet long and weigh about 1,000 pounds. At birth, calves are between three and four feet long 

and weigh between 40 and 60 pounds.

Geographic Boundaries and Spatial Distribution:

U.S. populations occur primarily in Florida, where they are effectively isolated from other 

populations by the cooler waters of the northern Gulf of Mexico and the deeper waters of the 

Straits of Florida (Domning and Hayek, 1986). In the southeastern United States, manatees are 

more or less restricted to the vicinity of warm-water sites in peninsular Florida during the winter, 

although a few may remain year-round in Cumberland Sound, southeastern Georgia, where 

factory warm-water outfalls allow survival of colder winter months (Reeves et al., 1992). 

Occasional manatees occur in summer from Texas to North Carolina. Those in Texas may be 

wanderers from Mexican population, but DNA analysis of an individual captured linked it to the 

Florida population. Manatees range along most of the Gulf coast of Florida but infrequently 

occur north of the Suwannee River and between the Chassahowitzka River and Tampa Bay. 
2013 VGP and sVGP BE Appendix F

F-76

They inhabit the Atlantic coast of Florida from the Georgia coast to Biscayne Bay and the 

Florida Keys, including the St. Johns River, the Indian River lagoon system, and various other 

waterways (O'Shea and Ludlow, 1992). In Florida, the most well-used wintering areas are at 

Crystal River, Homosassa River, Tampa Bay, Ft. Myers, Port Everglades, Riviera Beach, near 

Titusville, and Blue Spring (O'Shea and Ludlow, 1992).

Antillean manatees are found in coastal and riverine systems in South and Central America (from 

Brazil to Mexico) and in the Greater and Lesser Antilles throughout the Caribbean Basin. Due to 

a variety of human activities (hunting, loss of habitat, etc.), manatees have been extirpated from 

many areas and their distribution is patchy throughout the region. USFWS recovery activities 

primarily focus on manatees in Florida and Puerto Rico, although the species is managed 

throughout its range.

Habitat: (has critical habitat)

Florida and Antillean manatees range freely between marine and freshwater habitats. Specific 

habitat types/use areas include foraging and drinking sites, resting areas, travel corridors and 

others. Florida manatees, living at the northern limit of the species' range, have little tolerance 

for cold. Historically, this sub-species has sought out natural, warm-water sites, including 

springs, deep water areas, and areas thermally influenced by the Gulf Stream, as refuges from the 

cold. In the 1930s and 40s, industrial plants, including power plants, paper mills, etc., were built 

along coastal and riverine shoreline areas. Plants discharging large volumes of heated discharge 

water into areas accessible to manatees have attracted large numbers of wintering manatees to 

these warm-water sites ever since. In the spring, manatees leave the warm-water sites and may 

travel great distances during the summer, only to return to warm water sites in the fall. 

Critical habitat characteristics were not specified, however, as of September 1977, The US Fish 

and Wildlife Service designated the following areas as critical habitat areas within the state of 

Florida: 

The Crystal River and its headwaters known as King’s Bay, Citrus County; the Little Manatee 

River downstream from the U.S. Highway 301 bridge, Hillsborough County; the Manatee River 

downstream from the Lake Manatee Dam, Manatee County; the Myakka River downstream from 

Myakka River State Park, Sarasota and Charlotte Counties; the Peace River downstream from 

the Florida State Highway 760 bridge, De Soto and Charlotte Counties; Charlotte Harbor north 

of the Charlotte-Lee county line, Charlotte County; Caloosahatchee River downstream from the 

Florida State Highway 31 bridge, Lee County; all U.S. territorial waters adjoining the coast and 

islands of Lee County; all U.S. territorial waters adjoining the coast and islands and all 

connected bays, estuaries, and rivers from Gordon’s Pass, near Naples, Collier County, 

southward to and including Whitewater Bay, Monroe County; all waters of Card, Barnes, 

Blackwater, Little Blackwater, Manatee, and Buttonwood sounds between Key Large, Monroe 

County, and the mainland of Dade County: Biscayne Bay, and all adjoining and connected lakes, 

rivers, canals, and waterways from the southern tin of Key Biscayne northward to and including 

Maule Lake, Dade County; all of Lake Worth, from it northernmost point immediately south of 

the intersection of U.S. Highway 1 and Florida State Highway A1A -southward to its 

southernmost point immediately north of the town of Boynton Beach, Palm Beach County; the 

Loxanatchee River and its headwaters, Martin and West Palm Beach Counties; that section of the 
2013 VGP and sVGP BE Appendix F

F-77

intracoastal waterway from the town of Seawalls Point, Martin County to Jupiter Inlet, Palm 

Beach County; the entire inland section of water known as the Indian River. from its 

northernmost point immediately south of the Intersection of US Highway 1 and Florida State 

Highway 3, Volusia County, southward to its southernmost point near the town of Seawalls 

Point, Martin County, and the entire inland section of water known as the Banana River and all 

waterways between Indian and Banana rivers, Brevard County; the St. Johns River including 

Lake George, and including Blue Springs and Silver Glen Springs from their points of origin to 

their confluences with the St. Johns River; that section of the Intracoastal Waterway from its 

confluence with the St. Marys River on the Georgia- Florida border to the Florida State Highway 

A1A bridge south of Coastal City, Nassau and Duval Counties.

Life History:

Manatees are herbivores that feed opportunistically on a wide variety of marine, estuarine, and 

freshwater plants, including submerged, floating, and emergent vegetation. Common forage 

plants include and are not limited to: cord grass, alga, turtle grass, shoal grass, manatee grass, eel 

grass, and other plant types. (Calves initially suckle and may start feeding on plants when a few 

months of age. Weaning generally takes place within a year of birth.) Manatees also require 

sources of freshwater, obtained from both natural and anthropogenic sources.

Manatees mature at three to five years of age. Mature females go into heat for anywhere from 

two to four weeks. Mating activity can occur throughout the year. When in heat, females will 

attract numerous males and mate repeatedly; aggregations that include an estrus or focal female 

and numerous males are described as mating herds. Gestation lasts for about 13 months and cows 

usually give birth to a single calf; twinning is known to occur. While calving primarily peaks in 

the spring, calves may be born at any time of the year. Reproductive senescence is poorly 

described; a known female has given birth to seven individual calves over a period of about 30 

years. A calf may remain with its mother for about two years. Calving intervals range from two 

and three years. The oldest known manatee is 61 years of age.

Historical Information:

The West Indian manatee, Trichechus manatus, was listed as endangered throughout its range for 

both the Florida and Antillean subspecies (T. manatus latirostris and T. manatus manatus) in 

1967 (32 FR 4061) and received federal protection with the passage of the ESA in 1973.

Conservation Status:

Per a 2009 survey, there are at least 3,800 Florida manatees; Antillean manatees in Puerto Rico 

are thought to include about 350 animals. Both stocks are thought to be stable and perhaps 

increasing in certain areas. Survival and reproductive rates are generally positive, even in the 

face of increasing human-related threats, including watercraft, habitat loss, and other activities.

Summary of Major Threats:

Threats manatees face many threats to their survival throughout their range. Historically, they 

were hunted for their flesh, bones, and hide. Manatee fat was used for lamp oil, bones were used 

for medicinal purposes, and hides were used for leather. Hunting is thought to be largely 

responsible for the initial decline of the species; however, hunting is no longer allowed in 

countries where manatees are protected.
2013 VGP and sVGP BE Appendix F

F-78

Today, the greatest threats to manatee survival are collisions with boats and, in Florida, loss of 

warm water habitat. Speeding boats can injure and kill manatees that are submerged just below 

the surface. Manatees that survive such encounters carry distinctive scars. In fact, biologists 

studying the species use the scars as ways of identifying individual animals. As a conservation 

measure, many areas now post speed-limit signs for boats or prohibit them completely. The loss 

of natural springs as a result of the increasing demands on water usage from development 

pressure, and the potential loss of warm water from power plants that are eventually shut down, 

could limit the available habitat for manatees in the future. Biologists are working to secure 

sources of warm water for manatees in Florida to eliminate this future threat. Flood gates and 

canal locks can kill manatees either by crushing them or drowning them; however, recent 

modifications of operating procedures have reduced the number of fatalities from this source. 

Fishing line and other trash discarded into the water are responsible for a small number of 

manatee deaths each year. Natural events also imperil manatees. Because manatees cannot 

survive long in cold water, unusually cold winters in Florida pose a serious threat. As the water 

temperature drops below 60°F, manatees become sluggish and stop eating. Young manatees are 

especially susceptible to the effects of cold temperatures. Periodic red tide blooms have also 

been associated with a number of manatee deaths. The microorganisms associated with red tide 

produce a toxin that can kill manatees if the animals breathe them or eat them. Harassment of 

manatees from skin divers, fishermen, and boaters can interrupt feeding and breeding. During the 

winter, manatees may be driven into cooler water where they are susceptible to disease and cold 

stress.

F.4. SAINT LOUIS, MISSOURI

F.4.1.

Boltonia decurrens

DECURRENT FALSE ASTER

Family: Asteraceae

Threatened: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q26A)

• USFWS, 2012 (http://www.fws.gov/midwest/Endangered/plants/pdf/d-f-aster.pdf)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Boltonia+decurr

ens)

• USFWS, 2012a (http://www.fws.gov/midwest/Endangered/plants/decurrfa.html)

Description:

A robust, short-lived perennial herb, up to 6.5 feet tall, that produces numerous flower heads 

with white or pale violet ray flowers surrounding a yellow central disk. Its branches are 

somewhat leafy with numerous aster-like capitula. 
2013 VGP and sVGP BE Appendix F

F-79

Geographic Boundaries and Spatial Distribution:

The decurrent false aster is known to or is believed to occur in Illinois, and Missouri.

Habitat: (no critical habitat)

This plant is found on moist, sandy, floodplains and prairie wetlands along the Illinois River. It 

relies on periodic flooding to scour away other plants that compete for the same habitat.

Life History:

Boltonia decurrens blooms from August through October throughout its range (Schwegman and 

Nyboer, 1985). Both seedlings and vegetatively-produced rosettes can withstand prolonged 

periods of flooding (Stoecker, Smith and Melton, 1995), and have been observed to develop 

while completely submerged, to bolt above water level, flower and produce seeds (Smith, 1990). 

Seeds are conditionally dormant (Baskin and Baskin, 1988), with freshly-produced seeds 

germinating at warmer temperatures (30 ̊C). Peak germination appears to be in spring (Smith, 

1991). Seeds stored in a refrigerator at 4 ̊C for 6 years are still viable (50% germination 

percentage), and a recent study indicates that in the field seeds remain viable in the soil for at 

least two years (Smith, 1994). 

Dispersal is chiefly by floodwater. The species is primarily outcrossing, but some selfing occurs 

(Smith, 1995). Seed production is prolific with an average of 50,000 seeds produced per plant 

(Smith, 1990). Germination is 60% under laboratory conditions (Smith, 1990), but seedling 

survival in the field is <1%. In late fall, as each flowering individual dies, leaving no persistent 

root stock, basal rosettes develop independent root systems. The rosettes overwinter, bolt the 

following spring, and flower.

Historical Information:

Historical collection records reveal that Boltonia decurrens formerly occurred in almost 

contiguous populations between LaSalle, Illinois and St. Louis, Missouri within the Illinois and 

Mississippi River floodplain. It was listed as threatened on November 14, 1988. 

Conservation Status:

The number of distinct occurrences varies from about 10 to about 30, depending on the flooding 

regime. In 1989, following extensive searches by the Illinois and Missouri Departments of 

Conservation, a total of 18 populations were discovered in Illinois and 10 in Missouri (U.S. Fish 

and Wildlife Service, 1990). Following the flood of 1993, the number of populations declined to 

10. By the end of the summer of 1994, population number had recovered again. In spite of record 

flooding on the Illinois River in the spring of 1995, the total number of populations of Boltonia 

decurrens increased to 34 in 1995. Because of the vulnerability of this species to changes in 

flooding regime, population numbers are expected to continue to fluctuate in upcoming years.

Summary of Major Threats:

Excessive silting seems to be a major cause of the decurrent false aster's decline. Highly 

intensive agricultural practices have increased topsoil runoff, which smothers seeds and 

seedlings. Habitat destruction is another threat. Agriculture has eliminated wet prairies and 

marshes within the species' range, natural lakes have been drained and converted to row crops. 

Marina construction, building levees along rivers, and draining wetlands for cultivation has also 
2013 VGP and sVGP BE Appendix F

F-80

changed patterns of flooding and eliminated habitat. Herbicides also kill these plants and may be 

a factor in the decline of the species. Several communities of decurrent false asters have been 

found in areas of low-intensity agriculture. Biologists believe that the plant may actually benefit 

from occasional farming, which eliminates competitive plant species.

F.4.2.

Lampsilis abrupta

PINK MUCKET

Family: Unionidae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=F00G)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Lampsilis+abrup

ta)

Description:

The pink mucket is a medium-sized (reaching up to approximately 100 mm in length) freshwater 

mussel with a smooth, yellow or yellowish green shell and faint green rays (INHS, 1997, 

VFWIS, 2003). The life span of the species exceeds 50 years (VFWIS, 2003). Like other 

freshwater mussels, the pink mucket feeds by filtering food particles from the water column. 

This species can be easily confused with Lampsilis higginsi although the former is lighter in 

color, less inflated and more "humped". Young shells are more elongated and the beaks are less 

elevated than L. higginsi.

Geographic Boundaries and Spatial Distribution:

This species has been known to occur in Alabama, Arkansas, Iowa, Illinois, Indiana, Kentucky, 

Louisiana, Missouri, Mississippi, Ohio, Pennsylvania, Tennessee, Utah, Washington, and West 

Virginia.

Habitat: (no critical habitat)

The pink mucket typically inhabits medium to large rivers with strong currents; however, it has 

also been able to survive and reproduce in areas of impounded reaches with river/lake conditions 

without standing water (NatureServe, 2003, USFWS, 1985). Substrate preferences include sand, 

gravel, and pockets between rocky ledges in high velocity areas and mud and sand in slower 

moving waters. Individuals have been found at depths up to one meter in swiftly moving currents 

and in much deeper waters with slower currents (Gordon and Layzer, 1989).

Life History:

The reproductive cycle of the pink mucket is similar to that of other native freshwater mussels. 

Males release sperm into the water column; the sperm are then taken in by the females through 

their siphons during feeding and respiration. The females retain the fertilized eggs in their gills 

until the larvae (glochidia) fully develop. The mussel glochidia are released into the water, and 

within a few days they must attach to the appropriate species of fish, which they parasitize for a 
2013 VGP and sVGP BE Appendix F

F-81

short time while they develop into juvenile mussels. Laboratory studies have confirmed that four 

of nineteen fish tested are suitable hosts for the pink mucket. These include the largemouth bass 

spotted bass, smallmouth bass, and walleye (Barnhart 1997). Other reported glochidial fish host 

species include the sauger and the freshwater drum (USFWS, 1985, VFWIS, 2003). The pink 

mucket is unique in that the females possess a spotted mantle flap which may serve to mimic a 

fish eyespot to attract host fish (USFWS, 1985).

The specific food habits of the species are unknown, but other juvenile and adult freshwater 

mussels have been documented to feed on detritus, diatoms, phytoplankton, and zooplankton 

(Churchill and Lewis 1924). The diet of pink mucket glochidia, like other freshwater mussels, 

comprises water (until encysted on a fish host) and fish body fluids (once encysted). 

Historical Information:

This species has historically been considered as an Ohioan and Interior Basin species in origin. It 

was formerly scattered throughout the Mississippi, Tennessee, Ohio and Cumberland River 

systems (USFWS, 1985). Historical occurrences (all rare and represented by few, if any, live 

individuals) include the Flint River, Alabama; Limestone Creek, Alabama; Duck River; Holston 

River; French Broad River; Cumberland River; Clinch River; Obey River; Ohio River; 

Allegheny River; Elk River, West Virginia; Kanawha River, West Virginia; Scioto River; 

Muskingum River; White River, Indiana; Wabash River, Indiana and Illinois; Mississippi River, 

Illinois and Iowa; Illinois River; Ouachita River and Old River, Arkansas; Black River; Sac 

River, Missouri; and St. Francis River, Missouri (see USFWS, 1985). It was historically known 

from at least 25 river systems with a widespread distribution (USFWS, 1985). It is now 

extirpated in Ohio except possibly small parts of the Ohio River (Watters, 1995; Matthews and 

Moseley, 1990; Cummings and Mayer, 1997), and is completely extirpated from Pennsylvania 

(Bogan, 1993) and New York (Strayer and Jirka, 1997).

On June 14, 1976, the pink mucket was designated as endangered throughout its entire range in 

Alabama, Arkansas, Illinois, Indiana, Kentucky, Louisiana, Missouri, Ohio, Pennsylvania, 

Tennessee, Virginia, and West Virginia (USFWS, 1976). A recovery plan addressing the pink 

mucket was approved in January 24, 1985 (USFWS, 1985).

Conservation Status:

The overall range of this once very widespread species has diminished, but this species was 

always considered rare whenever it was found and it seems to be surviving and reproducing in 

sections of river that have been altered by impoundments. More dramatic has been the decline in 

area of occupancy (probably greater than 30%) as it continues to be found in historical sites but 

often only in very low numbers. Although currently known from a few dozen localities, most are 

represented by very few individuals and have poor viability. If populations west of the 

Mississippi River prove to be a different species the conservation status will need to be 

reevaluated.

Summary of Major Threats:

Continued threats to the survival of this species include alteration or destruction of stream habitat 

due to impoundment for flood control, navigation, hydroelectric power, and recreation and 

degradation of water quality. Other threats include siltation due to strip mining, coal washing, 
2013 VGP and sVGP BE Appendix F

F-82

dredging, farming, logging, road construction, and pollution from municipal, industrial, and 

agricultural waste discharges (USFWS, 1985).

F.4.3.

Leptodea leptodon

SCALESHELL MUSSEL

Family: Unionidae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=F00W)

• USFWS, 2012a (http://www.fws.gov/midwest/endangered/clams/scmu_fct.html)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Leptodea+leptod

on)

Description:

The scaleshell is a relatively small freshwater mussel with a thin, fragile shell and faint green 

rays. It grows to about one to four inches in length. It has an elongated-elliptical, compressed, 

thin, translucent shell with a rounded anterior margin. The inside of the shell is pinkish white or 

light purple and highly iridescent. The scaleshell gets its name from the scaly appearance of the 

shell, which is only seen in females.

Geographic Boundaries and Spatial Distribution:

Current range for this species is much reduced from its historic extent. Of the 53 locales in which 

the scaleshell has been collected historically, only 13 or 14 are believed to contain extant 

populations (USFWS, 1999; Szymanski, 1998). The species is considered extirpated from 

Minnesota with the only specimen collected in the Minnesota River at Pike Island in the late 

1800s (Sietman, 2003). It has probably been extirpated from Tennessee rivers for at least several 

decades (Parmalee and Bogan, 1998). It has been extirpated from the Upper Mississippi River 

system for over 50 years where it historically occurred in eight rivers and tributaries in the 

system (Szymanski, 1998). It is also nearly extirpated from the previously known 25 rivers and 

tributaries within the Middle Mississippi River system with only about 4 or 5 rivers in the 

Missouri and Meramec River drainages currently containing populations (Szymanski, 1998). It is 

extirpated from Alabama, probably during the 1900s; but probably once occurred in the 

Tennessee River across northern Alabama however all records are from Muscle Shoals 

(Williams et al., 2008). It is extirpated from Ohio with historical occurrences in the Ohio River at 

Cincinnati and Marietta, lower Muskingum River, and Scioto River at Columbus and Circleville 

(Watters et al., 2009).

Habitat: (no critical habitat)

Scaleshell live in medium-sized and large rivers with stable channels and good water quality. 

They bury themselves in sand and gravel on the bottom with only the edge of their partiallyopened shells exposed. This species occurs in riffles with moderate to high gradients in creeks to 
2013 VGP and sVGP BE Appendix F

F-83

large rivers. It is typically associated with riffles, relatively strong currents, and substrate of mud, 

sand, or assemblages of gravel, cobble, and boulder. It has been found completely buried in the 

substrate down to depths of 15 cm (Oesch, 1984; 1995). It occurs in medium to large rivers with 

low to moderate gradients in a variety of stream habitats including gravel, cobble, boulders, and 

occasionally mud or sand substrates (Buchanan, 1980; 1994; Oesch, 1995).

Life History:

As river currents flow over them, they siphon particles out of the water for food such as plant 

debris, plankton, and other microorganisms. The roles of scaleshell in river ecosystems are as 

food for wildlife like muskrats, otters, and raccoons and as filters which improve water quality.

The life cycle of the scaleshell, like most freshwater mussels, is unusual and complex. Their eggs 

develop into microscopic larvae (glochidia) within the gills of the female. The female discharges 

its glochidia into the river where they must attach to gills or fins of a fish to continue developing. 

Each mussel species has specific fish species (host fish) that are needed by the glochidia to 

develop. Freshwater drum have been identified as a host fish for the scaleshell but there may be 

other species. Glochidia continue growing on the fish and transform into juveniles. After a few

weeks they drop off and land on the river bottom where they grow into adults.

Historical Information:

Historically this species was distributed through 55 streams in much of the Interior Basin and a 

portion of the St. Lawrence drainage, including 13 states (USFWS, 2004). Within the latter, 

records are primarily from the Lake Erie basin incorporating portions of western New York, 

southern Ontario, and southern Michigan. Records from New York are doubtful, however and 

are likely attributed to wingless examples of Leptodea fragilis (Szymanski, 1998). Interior Basin 

records are from streams in Ohio, Kentucky, Tennessee, Indiana, Illinois, southern Wisconsin, 

Iowa, Missouri, Kansas, Arkansas, and Oklahoma. Extensive surveys for the species in 

Minnesota have revealed no extant populations and only one historical record (MN DNR, 2004; 

Sietman, 2003). The only known extant populations are now restricted 13 streams in the Interior 

Highland divisions in Missouri, Arkansas, and Oklahoma (see Oesch, 1984; 1995; Gordon, 1985; 

Harris and Gordon, 1987; Clarke, 1987; Cummings and Mayer, 1992; Parmalee and Bogan, 

1998; Szymanski, 1998; and USFWS, 1999). An additional site in the lower Missouri River near 

St. Louis, was discovered in 1990 (Hoke, 2000) bringing the total to 14. The species has not 

reported from Alabama since ompoundment of the Tennessee River (Mirarchi et al., 2004). 

Extensive surveys for the species in Minnesota have revealed no extant populations and only one 

historical record (MN DNR, 2004). Fresh dead shells were recently discovered below Lewis and 

Clark Lake, Nebraska in the Missouri River (Hoke, 2005).

Conservation Status:

This species has experienced a severe reduction in extant occurrences (approximately 75% 

reduction in number of streams) that has reduced this species from a fairly widespread species to 

a "regional endemic" in the Interior Highlands region. Sub-national extirpations have occurred in 

Alabama, Iowa, Illinois, Indiana, Kentucky, Minnesota, Ohio, Tennessee, and Wisconsin. While 

it exists in 14 streams, only three or four populations are thought to be stable and most 

occurrences are widely disjunctive.
2013 VGP and sVGP BE Appendix F

F-84

Summary of Major Threats:

This species is severely impacted by alteration and inundation of channels, siltation from 

agriculture and clear-cutting, chemical and organic pollution. The decline of scaleshell is 

primarily due to threats that cause habitat loss and degradation from construction activities and 

intensive land use (USFWS, 2004). Although sedimentation is a natural process, poor land use 

practices, dredging, impoundments, intensive timber harvesting, heavy recreational use, and 

other activities may accelerate erosion and increase sedimentation. A sudden or slow blanketing 

of the river bottom with sediment can suffocate freshwater mussels because it is difficult for 

them to move away from the threat. Increased sediment levels may also make it difficult for 

scaleshells to feed, which can lead to decreased growth, reproduction, and survival.

Adult mussels are easily harmed by toxins and declines in water quality from pollution because 

they are sedentary (stay in one place). Pollution may come from specific, identifiable sources 

such as factories, sewage treatment plants and solid waste disposal sites or from diffuse sources 

like runoff from cultivated fields, pastures, cattle feedlots, poultry farms, mines, construction 

sites, private wastewater discharges, and road drainage. Contaminants reduce water quality and 

may directly kill mussels, reduce the ability of surviving mussels to have young, or result in poor 

health or disappearance of host fish.

Dams affect both upstream and downstream mussel populations by disrupting natural flow 

patterns, scouring river bottoms, changing water temperatures, and eliminating habitat. The 

scaleshell, a mussel adapted to living in river currents, cannot survive in the still water 

impounded behind dams. 

Scaleshells depend on their host fish as a means of moving upstream. Because dams are barriers 

that prevent fish from moving upstream they also prevent mussels from moving upstream. 

Upstream mussel populations then become isolated from downstream populations. This isolation 

leads to small unstable populations which are more likely to die out. 

The invasion of the exotic zebra mussel into the U.S. poses a substantial threat because it starves 

and suffocates native mussels by attaching to their shells in large numbers.

F.4.4.

Myotis grisescens

GRAY BAT

Family: Vespertilionidae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=A04J)

• USFWS, 2012e

(http://www.fws.gov/northeast/virginiafield/pdf/endspecies/fact_sheets/gray%20bat.pdf)
2013 VGP and sVGP BE Appendix F

F-85

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Myotis+grisesce

ns)

Description:

Gray bats are distinguished from other bats by the unicolored fur on their back. In addition, 

following their molt in July or August, gray bats have dark gray fur which often bleaches to a 

chestnut brown or russet. They weigh 7-16 grams. The bat's wing membrane connects to its 

ankle instead of at the toe, where it is connected in other species of Myotis. Their ears are dark, 

usually black and longer than in any other Myotis. 

Geographic Boundaries and Spatial Distribution:

The gray bat occupies a limited geographic range in limestone karst areas of the southeastern 

United States. They are mainly found in Alabama, northern Arkansas, Kentucky, Missouri, and 

Tennessee. A few can be found in northwestern Florida, western Georgia, southeastern Kansas, 

southern Indiana, southern and southwestern Illinois, northeastern Oklahoma, northeastern 

Mississippi, western Virginia, and possibly western North Carolina. Summer and winter ranges 

are essentially the same.

Habitat: (no critical habitat)

With rare exceptions, gray bats live in caves year-round. During the winter gray bats hibernate in 

deep, vertical caves. In the summer, they roost in caves which are scattered along rivers. These 

caves are in limestone karst areas of the southeastern United States. They do not use houses or 

barns.

Tuttle (1979) showed that forested areas along the banks of streams and lakes provide important 

protection for adults and young. Young often feed and take shelter in forest areas near the 

entrance to cave roosts (Tuttle 1979). They do not feed in areas along rivers or reservoirs where 

the forest has been cleared (LaVal et al., 1977).

Life History:

The gray bat migrates south for the winter. This species lives in caves year-round, but during the 

summer uses multiple caves. In summer, the gray bat uses caves that are warm and have flowing 

water or are close to rivers or reservoirs. Mating occurs in the fall, and one young per female is 

born in late May or early June. Young can fly by early to mid-July. Females are very specific in 

selecting the caves in which they give birth and raise their young. All maternity caves contain a 

stream; therefore fewer than five percent of all caves are suitable for use by pregnant females. 

Females migrate in early September, while males and juveniles migrate in mid-October. Some 

individuals migrate up to 300 miles to their winter cave. Males and females hibernate together in 

the winter in caves that are large and cold, and contain complex caverns. Almost all gray bats 

hibernate in five caves in the southeastern U.S. The gray bat forages over water and forested 

areas. The bats eat a variety of flying aquatic and terrestrial insects present along rivers or lakes. 

The energy demands on adult females are tremendous during lactation, and individual females 

sometimes feed continuously for seven or more hours per night (Tuttle and Stevenson).
2013 VGP and sVGP BE Appendix F

F-86

Historical Information:

The gray bat was listed as endangered on April 28, 1976.

Conservation Status:

The species' present total population is estimated to number over 1,500,000; however, about 95 

percent hibernate in only eight caves--two in Tennessee, three in Missouri, and one each in 

Kentucky, Alabama, and Arkansas. Although gray bat numbers are still relatively high, their 

total population has decreased significantly during recent years.

Summary of Major Threats:

Cave disturbance has been the major factor in the decline. Cave protection efforts have greatly 

reduced this threat. Decline began with cave disturbance associated with saltpeter production 

during the Civil War. Some of the largest colonies were lost as a result of cave 

commercialization. The commercialization of caves drives bats away. Any gating on the cave 

that prevents access or alters the air flow, temperature, humidity, and amount of light is harmful. 

The species is especially vulnerable due to its high fidelity to particular favored caves, and it is 

very sensitive to disturbance, including the mere presence of humans with lights; disturbance 

may result in bats moving to less favorable roosting places. 

White-nose syndrome has been detected in this species, and this emerging disease must be 

regarded as the major threat and one that could cause large, rapid declines. The use of forestry 

insecticides and crop pesticides in areas adjacent to riparian corridors where gray bats forage 

may reduce the prey base or kill bats that ingest contaminated insects (Northern Prairie Wildlife 

Research Center). Some maternity and hibernating colonies are susceptible to human disturbance 

(Northern Prairie Wildlife Research Center). Other threats include pesticides, deforestation, and 

impoundment of waterways (and subsequent cave inundation).

F.4.5.

Myotis sodalis

INDIANA BAT

(See New York, New York for information on this species)

F.4.6.

Platanthera leucophaea

EASTERN PRAIRIE FRINGED ORCHID

Family: Orchidaceae

Threatened: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q2GG)

• USFWS, 2012a (http://www.fws.gov/midwest/endangered/plants/epfo.html)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Platanthera+leuc

ophaea)
2013 VGP and sVGP BE Appendix F

F-87

Description:

This plant is 8 to 40 inches tall and has an upright leafy stem with a flower cluster called an 

inflorescence. The 3 to 8 inch lance-shaped leaves sheath the stem. Each plant has one single 

flower spike composed of 5 to 40 creamy white flowers. Each flower has a three-part fringed lip 

less than 1 inch long and a nectar spur (tube-like structure) which is about 1 to 2 inches long.

Geographic Boundaries and Spatial Distribution:

Current range is the Midwest region of the U.S. The eastern prairie fringed orchid is known to or 

is believed to occur in Illinois, Indiana, Iowa, Maine, Michigan, Ohio, Oklahoma, Virginia, and 

Wisconsin.

Habitat: (no critical habitat)

The eastern prairie fringed orchid occurs in a wide variety of habitats, from mesic prairie to 

wetlands such as sedge meadows, marsh edges, even bogs. It requires full sun for optimum 

growth and flowering and a grassy habitat with little or no woody encroachment. A symbiotic 

relationship between the seed and soil fungi, called mycorrhizae, is necessary for seedlings to 

become established. This fungus helps the seeds assimilate nutrients in the soil.

Life History:

This orchid is a perennial herb that grows from an underground tuber. Flowering begins from 

late June to early July, and lasts for 7 to 10 days. Blossoms often rise just above the height of the 

surrounding grasses and sedges. The more exposed flower clusters are more likely to be visited 

by the hawkmoth pollinators, though they are also at greater risk of being eaten by deer. Seed 

capsules mature over the growing season and are dispersed by the wind from late August through 

September. Night flying hawkmoths pollinate the nocturnally fragrant flowers of this white 

orchid. Visiting hawkmoths inadvertently collect pollen on their proboscises as they ingest nectar 

from the flower’s long nectar spurs.

Historical Information:

The historic range of this species was east of the Mississippi River in the Great Lakes Region 

and the area that comprises the prairie peninsula: Nova Scotia and Ontario, Canada; Nebraska to 

Ohio and Louisiana. It was listed as threatened on September 28, 1989.

Conservation Status:

The species is extirpated in much of its large historic range and is very rare throughout its current 

range. Most of this species' wet prairie habitat has been destroyed due to drainage and 

conversion to agriculture, fire suppression, and intensive mowing. Because of the destruction of 

most of the natural grasslands east of the Mississippi River, large populations no longer occur 

anywhere in the United States (the only population with more than 2000 individuals is in 

Ontario, Canada). The mostly small, isolated populations that remain are not representative of 

populations supported by the once-vast prairie habitat, and many are only infrequently visited by 

appropriate pollinators.

Summary of Major Threats:

Early decline was due to the loss of habitat, mainly conversion of natural habitats to cropland 

and pasture. Current decline is mainly due to the loss of habitat from the drainage and 
2013 VGP and sVGP BE Appendix F

F-88

development of wetlands for crop production, and commercial and residential development. 

Populations along the shores of the Great Lakes are threatened by high water levels and invasion 

of purple loosestrife. Other reasons for the current decline include succession to woody 

vegetation, competition from non-native species, grazing by cattle and deer, cutting hay in 

midsummer (prevents seed dispersal) and over-collection from humans. 

F.4.7.

Scaphirhynchus albus

PALLID STURGEON

Family: Acipenseridae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=E06X)

• USFWS, 2012a (http://www.fws.gov/midwest/Endangered/fishes/palld_fc.html)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Scaphirhynchus

+albus)

Description:

Pallid sturgeons have a unique dinosaur-like appearance. They have a flattened snout, long 

slender tail and are armored with lengthwise rows of bony plates instead of scales. Their mouth 

is toothless and positioned under the snout for sucking small fishes and invertebrates from the 

river bottom. Pallid sturgeons can weigh up to 80 pounds and reach lengths of 6 feet, whereas the 

closely related shovelnose sturgeon rarely weights more than 8 pounds. The back and sides of 

pallid sturgeons are grayish-white versus the brown color of the shovelnose sturgeons.

Geographic Boundaries and Spatial Distribution:

Range includes the Missouri River (from mouth to Fort Benton, Montana), lower Yellowstone 

River, lower Platte River, Mississippi River downstream from its junction with the Missouri 

River and upstream at least several kilometers from the Missouri River, and Atchafalaya River in 

central Louisiana (Reed and Ewing,1993; USFWS, 2007). Occasional sightings have occurred 

near the mouths of various other large tributaries of the Mississippi River (e.g., Big Sunflower

River and St. Francis River) and Missouri River (e.g., Kansas River and Platte River), but these 

instances may reflect fishes utilizing unusual flow conditions (USFWS, 1989). The lower 

Yellowstone River and lower Platte River may be significant spawning tributaries (see USFWS,

2007).

Habitat: (no critical habitat)

Pallid sturgeons evolved and adapted to living close to the bottom of large, silty rivers with 

natural a hydrograph. Their preferred habitat has a diversity of depths and velocities formed by 

braided channels, sand bars, sand flats and gravel bars. Pallid sturgeons tend to select main 

channel habitats in the Mississippi River (Sheehan et al., 1998) and main channel areas with 

islands or sand bars in the upper Missouri River (Bramblett, 1996). In the lower Platte River, 
2013 VGP and sVGP BE Appendix F

F-89

Nebraska, hatchery-reared individuals (age 6-7) usually were downstream of sand bars where 

currents converge (Snook et al., 2002). Specific characteristics of spawning habitat have not been 

documented. 

Life History:

Sexual maturity for males is estimated to be 7-9 years, with 2-3 year intervals between spawning. 

Females are not expected to not reach sexual maturity until 7-15 years, with up to 10-year 

intervals between spawning. Pallid sturgeons are long lived, with individuals perhaps reaching 

50 years of age. They feed opportunistically on aquatic insects, crustaceans, mollusks, annelids, 

eggs of other fishes, and sometimes other fishes (USFWS, 1989).

Historical Information:

Listed as endangered (55 Federal Register 36641) on September 6, 1990.

Conservation Status:

The upper Missouri River supports a small, declining, wild population of a couple hundred 

adults; recruitment is very low or absent. The lower Missouri River contains a small wild 

population of probably fewer than 200 adults, with sporadic or limited recruitment. Population 

size in the Atchafalaya River may be a few thousand. Population size in the largest segments of 

the range--the Mississippi River--is unknown (USFWS, 2007). According to Duffy et al. (1996), 

the total range-wide population size may be as few as 6,000 individuals or as many as 21,000.

Summary of Major Threats:

Construction and operation of large dams and river channelization have eliminated and degraded 

preferred sturgeon habitat (Pflieger and Grace, 1987). On the main stem of the Missouri River, 

approximately 36 percent of riverine habitat within the pallid sturgeon's range was eliminated by 

construction of six massive earthen dams between 1926 and 1952 (USFWS, 1993); the dams are 

believed to block migrations, and the reservoirs probably inundated historical spawning and 

nursery areas. Another 40 percent has been channelized. The remaining 24 percent has been 

altered due to changes in water flows caused by dam operations (USFWS, 1993). USFWS (2007) 

concluded that the species is still threatened by habitat loss and inadequate regulatory 

mechanisms in all or portions of the range. Habitat changes have severely reduced or eliminated 

successful reproduction. The low level of natural recruitment is a major concern and impediment 

to recovery.

Past commercial exploitation likely exceeded biological recruitment. Illegal commercial harvest 

is currently occurring in portions of the lower Missouri River and Mississippi River; pallid 

sturgeon exhibits lower ages and higher mortality rates in areas where shovelnose sturgeons are 

commercially harvested (Colombo et al., in press). This threat is likely to increase as caviar 

sources are reduced world-wide and caviar prices increase (USFWS, 2007).

Limited data suggest that contaminants may have some effect on reproduction (USFWS, 2007).

Significant hybridization with shovelnose sturgeon has been documented (USFWS, 1989, Wills 

et al., 2002). However, it is unclear whether hybridization is actually a threat (USFWS, 2007).
2013 VGP and sVGP BE Appendix F

F-90

F.4.8.

Sterna antillarum (athalassos)

LEAST TERN (Interior Population)

Family: Laridae

Endangered: AR, CO, IA, IL, IN, KS, KY, LA (Mississippi River and tributaries north of Baton 

Rouge), MS (Mississippi River), MO, MT, ND, NE, NM, OK, SD, TN, and TX 

(except within 50 miles of coast).

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=B07N)

• USFWS, 2012a (http://www.fws.gov/midwest/Endangered/birds/tern.html)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?sourceTemplate=tabular_repor

t.wmt&loadTemplate=species_RptComprehensive.wmt&selectedReport=RptComprehen

sive.wmt&summaryView=tabular_report.wmt&elKey=103386&paging=home&save=tru

e&startIndex=1&nextStartIndex=1&reset=false&offPageSelectedElKey=101508&offPag

eSelectedElType=species&offPageYesNo=true&post_processes=&radiobutton=radiobutt

on&selectedIndexes=101508&selectedIndexes=103386&selectedIndexes=104205)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?sourceTemplate=species_Rpt

Comprehensive.wmt&loadTemplate=tabular_report.wmt&paging=home&elKey=103386

&save=false&page=2)

Description:

Least terns are the smallest member of the gull and tern family. They are approximately 9 inches 

in length. Unlike gulls, terns will dive into the water for small fish. The body of least terns is 

predominately gray and white, with black “crown” streaking on the head. They have snowy 

whiter underside and forehead, grayish back and wings, orange legs, and a yellow bill with a 

black tip. Least terns have a forked tail and narrow pointed wings. Least terns less than a year old 

have less distinctive black streaking on the head and less of a forked tail. 

Geographic Boundaries and Spatial Distribution:

Interior least terns breed in isolated areas along the Missouri, Mississippi, Ohio, Red, and Rio 

Grande river systems. Their winter home is not known, but probably includes coastal areas of 

Central and South America. The Least tern (interior population) is known to or is believed to 

occur in Arkansas, Colorado, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Mississippi, 

Missouri, Montana, Nebraska, New Mexico, North Dakota, Oklahoma, South Dakota, 

Tennessee, and Texas.

Habitat: (no critical habitat)

From late April to August, terns use barren to sparsely vegetated sandbars along rivers, sand and 

gravel pits, or lake and reservoir shorelines. In the breeding season they can be found along sea 

coasts, beaches, bays, estuaries, lagoons, lakes, and rivers (AOU, 1983). Rests and loafs on 

sandy beaches, mudflats, and salt-pond dikes (Stiles and Skutch, 1989). They nest usually in 
2013 VGP and sVGP BE Appendix F

F-91

shallow depression on level ground on sandy or gravelly beaches and banks of rivers or lakes, 

typically in areas with sparse or no vegetation; also on dredge spoils, on mainland or on barrier 

island beaches, and on flat gravel-covered rooftops of buildings (especially in the southeastern 

U.S.) or other similarly barren artificial sites (AOU, 1983). 

Adults do not require cover during the breeding season, but chicks may use sparse vegetation and 

debris for shade and protection (Hardy, 1957; Blodgett, 1978). Parents may lead chicks toward 

the periphery of the colony into more heavily vegetated areas (Akers, 1975), where the young 

utilize debris and vegetation for cover (Hardy, 1957). In coastal areas, beach grass is the 

commonly associated vegetation. Along river systems, willow is the common vegetation 

adjacent to sites. 

Since least terns always nest near water, they are vulnerable to flood inundation and seem to seek 

high ground. In coastal Texas, Thompson and Slack (1982) documented that the densest nesting 

area in 67% of the colonies was above the midpoint of available elevations. Gochfeld (1983) 

found that least terns on Long Island avoid beaches that have less than 32.8 feet (10 m) of width 

beyond the hightide mark. Interior least tern nests on salt plains in Oklahoma were located an 

average of 110.5 m away from the nearest water (Grover and Knopf, 1982). However, nests on 

the Platte River in Nebraska, were located at an average of 18.9 m away from the nearest river 

channel on sand bars that averaged 58.9 m wide (Faanes, 1983).

Life History:

Courtship behavior includes chases, vocalizations, and sometimes presentation of a fish to the 

female by the male. Least terns lay eggs mostly in May-June (July-August nests probably are

renests). Renesting may occur after egg loss associated with heavy rains and/or flooding 

(Jernigan et al., 1978; Blus and Prouty, 1979). Clutch size usually is 2-3, rarely up to 4-5 (Hardy,

1957, Swickard, 1974, Houde, 1977, Hays, 1980, Faanes, 1983). Incubation usually lasts 20-25 

days, by both sexes but mostly by female. 

Hatching success varies greatly and is affected by factors such as weather, tides, predation, and 

human disturbance; although it may be high under optimal conditions. Young are tended by both 

parents. Reproductive success rarely exceeds one chick per pair (Kress et al., 1983). Its 

maximum known natural longevity is 21 years (Massey and Atwood, 1978; Clapp et al., 1982). 

In recent years, colonies generally have included no more than 20 pairs, sometimes up to about 

75 pairs (Ehrlich et al., 1992), rarely up to several hundred pairs. Their colony may be divided 

into subcolonies (Massey, 1974).

In California, usually nests in same area in successive years; tends to return to natal site to nest 

(Atwood and Massey, 1988). On Long Island, New York, tends to nest in same area in 

successive years if physical conditions are conducive to nesting (MacLean et al., 1991).

They eat mainly small fish, sometimes crustaceans or insects, obtained by diving from air into 

shallow water usually less than 4 m deep (Moseley 1976). Interior populations depend almost 

entirely on cyprinids. Feeding in newly plowed fields has been observed in Texas; apparently 

beetle larvae were being captured (McDaniel and McDaniel, 1963, Auk 80:544). 
2013 VGP and sVGP BE Appendix F

F-92

Historical Information:

Interior populations of the least tern, formerly well distributed in the Mississippi Basin, now 

survive only in scattered remnants. The least tern (interior population) was listed as an 

endangered species in 1985.

Conservation Status:

Interior population declined through at least the early 1980s. Its decline has taken place over 

many decades. Many populations are not fledging enough young to successfully increase local 

populations, but there appears to be immigration from Gulf populations and a good deal of 

movement among interior populations. Local populations fluctuate substantially (Kirsch and 

Sidle, 1994). USFWS (1990) categorized the status of the interior population as "improving." 

California population has responded well to management, and populations are continuing to 

increase; population increased from 600 pairs in 1970 to 1,700 pairs in 1992 (Massey, pers. 

comm.).

Summary of Major Threats:

Populations were decreased greatly by formerly extensive plume hunting. Current major 

problems are human use/disturbance and development of nesting habitat. Habitat loss and 

degradation has been caused by dams, reservoirs, and other changes to river systems that have 

eliminated most historic least tern habitat. The wide channels dotted with sandbars that are 

preferred by the terns have been replaced by narrow forested river corridors. In addition, 

recreational activities on rivers and sandbars disturb the nesting terns, causing them to abandon 

their nests.

Other factors include predation on adults, eggs, and young by birds and mammals (see Burger 

and Gochfeld 1990). Some habitat is lost due to encroachment of vegetation, but this may be 

offset by habitat created when storm overwash removes vegetation from portions of barrier 

beaches or creates overwash fans of sandy/gravelly substrate. Storms during spring tides 

sometimes wash out nests. Increasing human use of beaches, may seriously limit the availability 

of productive nesting sites in the southeast U.S. 

F.5. DULUTH, MINNESOTA

F.5.1.

Charadrius melodus

PIPING PLOVER

(See New York, New York for information on this species)

F.6. SAN FRANCISCO, CALIFORNIA

F.6.1. NORTH AMERICAN GREEN STURGEON

Acipenser medirostris

Family: Acipenseridae

Endangered: Threatened (CA Southern Distinct Population Segment)
2013 VGP and sVGP BE Appendix F

F-93

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=E09K

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Acipenser+medi

rostris

Description:

Green sturgeons are among the largest and longest living species found in freshwater, living up 

to 70 years and weighing up to 350 pounds. They resemble a prehistoric creature, possessing a 

skeleton that is more cartilage than bone and rows of bony plates for protection rather than 

scales. Green sturgeon are olive green in color and have a vacuum cleaner-like mouth that is 

used to siphon food.

Geographic Boundaries and Spatial Distribution:

States in which green sturgeons are known or believed to occur are Alaska, California, Oregon 

and Washington. Based on genetic data, NMFS (2003) identified two distinct population 

segments (DPSs). The geographic range of the northern DPS occurs largely within the Coastal 

Range ecoregion which extends from the Olympic Peninsula southward through the Coast Range 

and Klamath Mountains to and including the Eel River. The southern DPS occurs south of the 

Eel River, largely within the Central California Valley ecoregion which includes the Sacramento 

and San Joaquin rivers. NMFS stated that further research may revise these ranges and that 

additional DPSs could be recognized in the future.

The largest spawning population is thought to occur in the Klamath River on the north coast of 

California (NMFS, 2003). Juveniles are captured each year in the Klamath River and have also 

been found in the lower portion of the Salmon River (a tributary to the Klamath River). Adults 

occur in the Trinity River, a major tributary to the Klamath River, to Gray's Falls, but spawning 

can be confirmed only up to the Willow Creek trap. In the Sacramento River system, spawning 

occurs predominantly in the upper Sacramento River, above Hamilton City and perhaps as far 

upstream as Keswick Dam (NMFS, 2003). Juveniles are found throughout the Delta and San 

Francisco Bay. Adults and juveniles occur throughout the upper Sacramento River (NMFS,

2003).

Habitat: (no critical habitat)

Green sturgeons spend most of their lives in coastal marine waters, estuaries, and the lower 

reaches of large rivers. They ascend rivers to spawn, but specific spawning and rearing habitats 

are poorly known.

Life History:

Spawning appears to occur in the spring. Individuals become sexually mature at about 17 years 

(males) or approximately 21 years (females) (NMFS, 2001). Females spawn at intervals of 3-7 

years (NMFS, 2001). Individuals live up to several decades.
2013 VGP and sVGP BE Appendix F

F-94

Historical Information:

They have a large marine range along North Pacific Ocean of North America, but only a few 

known spawning rivers.

Conservation Status:

Some historical California spawning streams are no longer used (Moyle et al., 1995). Existing 

spawning stream channels and flows have been modified so it is likely that suitable conditions 

for spawning and rearing occur less frequently than in the past (Moyle et al., 1995). Apparently 

reduced in numbers throughout the range, although evidence is limited (Moyle et al., 1995). 

Musick et al. (2000) cited evidence that populations have declined by 88% throughout much of 

the range, and there appears to have been recent declines in the Umpqua River in Oregon and the 

Fraser River in Canada. NMFS (2003) concluded that available information is inadequate for 

assessing trend.

Summary of Major Threats:

There is a great deal of uncertainty regarding the effects of potential risk factors on green 

sturgeon in the southern DPS (NMFS, 2003). While there is some information on harvest 

bycatch impacts, it appears most of the identified risk factors are not well documented or are 

only suspected to be risk factors. Examples of the latter include entrainment at the Delta water 

export facilities, impacts from exotic species introductions, impacts from contaminants, and 

lethal water temperatures. In the case of harvest bycatch, for which there is the most information 

and perhaps the greatest concern, it is not possible to directly assess the impact of harvest on 

green sturgeon in this DPS. Nevertheless, direct harvest appears to be limited in California and 

harvest from fisheries in Oregon and Washington has declined substantially since the mid-1980s 

and even more so since the mid-1990s due to increasingly restrictive harvest management 

measures. These harvest reductions and associated restrictive management measures suggest that 

risk to green sturgeon from harvest bycatch has been reduced. Although the risk to green 

sturgeon from bycatch harvest may be declining, NMFS (2003) believed that it may be prudent 

to consider additional harvest protections until population monitoring information can be 

obtained to assess the status of this DPS with greater certainty. Based on a review of the best 

available information, NMFS (2003) concluded that the southern green sturgeon DPS is not 

presently in danger of extinction nor is it likely to become so in the foreseeable future.

Other threats include modification of spawning habitats (e.g., as a result of logging, agriculture, 

mining, road construction, and urban development in coastal watersheds), entrainment in water 

project diversions, and pollution (see Moyle et al., 1995 for further details). All known spawning 

rivers, have flow regimes that are affected by water projects (Moyle et al., 1995).

F.6.2.

Alopecurus aequalis var. sonomensis

SONOMA ALOPECURUS

Family: Poaceae

Endangered: wherever found
2013 VGP and sVGP BE Appendix F

F-95

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q01F)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?sourceTemplate=tabular_repor

t.wmt&loadTemplate=species_RptComprehensive.wmt&selectedReport=RptComprehen

sive.wmt&summaryView=tabular_report.wmt&elKey=148177&paging=home&save=tru

e&startIndex=1&nextStartIndex=1&reset=false&offPageSelectedElKey=152667&offPag

eSelectedElType=species&offPageYesNo=true&post_processes=&radiobutton=radiobutt

on&selectedIndexes=152667&selectedIndexes=134370&selectedIndexes=148177&selec

tedIndexes=156116&selectedIndexes=146786&selectedIndexes=151682&selectedIndexe

s=143240&selectedIndexes=130762&selectedIndexes=144157&selectedIndexes=128750

&selectedIndexes=156995&selectedIndexes=156475&selectedIndexes=132489)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc3898.pdf)

Description:

Alopecurus aequalis var. sonomensis (or Sonoma Shortawn Foxtail) is a tufted perennial grass 

that grows from 30 to 75 centimeters (12 to 30 inches) tall. The stems are mostly erect and either 

straight or weakly bent near the base. The leaf blades are up to 7.5 millimeters (0.3 inch) wide. 

The panicle is 2.5 to 9.0 centimeters (1.0 to 3.5 inches) long and 4 to 8 millimeters (0.1 to 0.3 

inch) wide. The spikelets are usually tinged violet-gray near the tip. The awn is straight, and 

exceeds the lemma body by 1.0 to 2.5 millimeters (0.04 to 0.1 inch). This variety is distinguished 

from A. aequalis var. aequalis by a more robust, upright appearance, generally wider panicle, 

violet-gray tinged spikelets, and longer awn (Rubtzoff 1961; W. Crins, Ontario Ministry of 

Natural Resources, in litt. 1993).

Geographic Boundaries and Spatial Distribution:

Sonoma alopecurus/Sonoma shortawn foxtail is known to or is believed to occur in California. 

The plant occurs in freshwater marshes and swamps and riparian scrub within Marin and 

Sonoma Counties, California (California Natural Diversity Database (CNDDB) 2011). Five of 

six known populations are clustered within a 12-square kilometer (4.6-square mile) area on the 

Point Reyes Peninsula in Marin County. The only known extant population in Sonoma County is 

located at Annadel State Park.

Habitat: (no critical habitat)

Sonoma alopecurus is found in riparian stream communities both in the stream channel and 

along the wet banks between 3 and 360 meters (10 and 1,180feet) in elevation. Most of the 

wetlands where Sonoma alopecurus now grow are located within coastal grasslands. In the Point 

Reyes National Seashore (PRNS), Sonoma alopecurus occurs in the pastoral zone, where cattle 

grazing have occurred since the 1830s (PRNS, 2010). On PRNS the plants are found in running 

water flowing from freshwater marsh through dunes and in a marshy area along the edge of a 

lagoon. Soil types in these locations are Sirdak sand, Sirdak variant sand, and dunes (U.S. Soil 

Conservation Service, 1985). 
2013 VGP and sVGP BE Appendix F

F-96

Life History:

While the reproductive mechanisms of this species have not been studied, Sonoma alopecurus 

appears to reproduce both sexually (assumed via wind pollination) and vegetatively (via 

rhizomes) (Gennet, 2004). Flowering begins in mid - May and lasts through August (Gennet,

2004). Gennet (2004) observed germination rates in the greenhouse at 62.2 percent. All seed 

germination occurred within 16 days of planting. There appeared to be a linear relationship 

between seed weight and germination rate (Gennet, 2004).

Historical Information:

The historical range of Sonoma alopecurus was approximately 48 kilometers (30 miles), 

reaching north from Point Reyes Peninsula to Guerneville and east to Cunningham Marsh. At the 

time of listing, we noted that although fewer sites were present, the range of the species had 

changed little from the historical range. Currently, PRNS has five out of six known extant 

populations of Sonoma alopecurus. These five populations are clustered in a small (12-square 

kilometer) area on the Point Reyes Peninsula (PRNS, 2010). A small population at Ledson 

Marsh is the only known extant population in Sonoma County, and the population distribution of 

this grass species has shifted to Marin, rather than Sonoma, County (Gennet, 2004). In addition, 

as of summer 2010, the population at Ledson Marsh was present, but reduced in size, and 

appropriate habitat appeared to be shrinking (A. Howald, Garcia and Associates, in litt. 2009 in 

A. Ryan, PRNS, in litt. 2011; J. Herrick, California Native Plant Society (CNPS) in litt. 2010).

Conservation Status:

The number of individuals in populations of Sonoma alopecurus may fluctuate markedly within 

and between years. The exact number of individuals is difficult to determine due to the species’ 

growth habitat (PRNS, 2006) and different methods of assessing population size that have been 

used. At the time of final listing in 1997, 8 populations of Sonoma alopecurus were known to 

exist in Marin and Sonoma Counties. Three of the populations, in Sonoma County, were 

privately owned, four populations were on Federal land within PRNS in Marin County, 

California, and one population was on a private inholding within the PRNS (CNDDB, 1993; 

Service, 1997).

Summary of Major Threats:

At the time of listing, the primary threats to Sonoma alopecurus were habitat destruction and 

modification due to urbanization, land use changes, or alterations in hydrology. We noted that a 

portion of the historical range of Sonoma alopecurus was within the project boundaries of a 

wastewater treatment facility (Service, 1997). The majority of the historical populations of 

Sonoma alopecurus experienced dramatic human-influenced land use changes prior to their 

decline or extirpation. Some wetland areas had been drained or altered in preparation for the 

construction of structures or buildings; others were fenced and intensively grazed (CNDDB,

2002; Gennet, 2004). Currently, competition from invasive plants, extirpation from random 

events and small population size, occasional trampling by cattle; and lack of reproductive 

success in the field still threaten Sonoma alopecurus. Additionally, Sonoma alopecurus is likely 

threatened by global climate change throughout its range.
2013 VGP and sVGP BE Appendix F

F-97

F.6.3.

Ambystoma californiense

CALIFORNIA TIGER SALAMANDER

Family: Ambystomatidae

Endangered: CA: Santa Barbara and Sonoma Counties

Threatened: Central CA Distinct Population Segment

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=D01T)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Ambystoma+cal

iforniense)

• Goals Project, 2000. (http://www.sfestuary.org/pdfs/speciescommunity/Species_and_Community_Profiles%5BPart1%5D.pdf)

• 76 FR 54346 (http://www.gpo.gov/fdsys/pkg/FR-2011-08-31/pdf/2011-21945.pdf)

• 70 FR 49380 

(http://www.gpo.gov/fdsys/search/citation.result.FR.action?federalRegister.volume=2005

&federalRegister.page=49380&publication=FR)

Description:

The California tiger salamander is a large, stocky, terrestrial salamander with a broad, rounded 

snout. Adult males are about 8 inches long, females a little less than 7 inches long. Coloration 

consists of white or pale yellow spots or bars on a black background on the back and sides. The 

belly varies from almost uniform white or pale yellow to a variegated pattern of white or pale 

yellow and black. The salamander's small eyes protrude from their heads with black irises.

Geographic Boundaries and Spatial Distribution:

The species has a discontinuous distribution in west-central California: coast ranges between 

Sonoma and Santa Barbara counties, Central Valley and surrounding foothills from southern 

Colusa County to northwestern Kern County on the west side of the valley and southern Butte 

County to northern Tulare County on the east side.

Habitat: (has critical habitat)

The best habitats for California tiger salamanders are vernal pool complexes with colonies of 

California ground squirrels or Botta’s pocket gophers within the complex or nearby (Shaffer et 

al., 1993). Such habitats are normally associated with grasslands or oak woodlands (Barry and 

Shaffer, 1994). Additionally, there needs to be abundant invertebrate resources and other native 

amphibian larvae in the vernal pools used by breeding salamanders.

Juvenile and adult salamanders have also been found in a number of human-created habitats such 

as septic tank lines, pipes, wells, wet basements, and permanent irrigation ponds (Jennings and 

Hayes, 1994). Such habitats may not be suitable for the long-term survival or successful 

reproduction of local salamander populations.
2013 VGP and sVGP BE Appendix F

F-98

Critical habitat for the Sonoma County DPS of the California tiger salamander was amended to 

47,383 acres of land on Sept. 30, 2011. 199,109 acres of critical habitat was designated for the 

central CA population of the California tiger salamander on Sept. 22, 2005.

The Central and Sonoma County populations of the CTS require the following primary 

constituent elements: (1) standing bodies of fresh water (including natural and manmade (e.g., 

stock)) ponds, vernal pools, and other ephemeral or permanent water bodies which typically 

support inundation during winter rains and hold water for a minimum of 12 weeks in a year of 

average rainfall; (2) upland habitats adjacent and accessible to and from breeding ponds that 

contain small mammal burrows or other underground habitat that CTS depend upon for food, 

shelter, and protection from the elements and predation; (3) accessible upland dispersal habitat 

between occupied locations that allow for movement between such sites.

Life History:

Most adults probably reach sexual maturity in two years, but some individuals may take longer 

during periods of unfavorable conditions such as annual droughts (Shaffer et al. 1993). Adults 

migrate during the night from subterranean refuge sites (small mammal burrows) to breeding 

ponds after the onset of relatively warm winter rains (late November-early March) where 

courtship and egg deposition occurs (Twitty, 1941; Barry and Shaffer, 1994; Loredo and Van 

Vuren, 1996). Females lay single or small groups of 2-4 eggs (8.5-12 mm in diameter) on 

detritus, submerged vegetation, or on the benthos of relatively shallow rain pools (Storer, 1925). 

Eggs hatch after 2-4 weeks (Storer 1925, Twitty 1941), and gilled aquatic larvae take a minimum 

of at least 10 weeks to successfully reach metamorphosis (Anderson, 1968, Feaver, 1971). 

Larvae lack legs upon hatching at 10.5 mm total length, but quickly grow four legs within 1-2 

weeks. Larvae generally are about 75 mm in total length and weigh about 10 grams at 

metamorphosis into juveniles, although they may remain in water (for up to six months) and 

grow to much larger sizes with a better chance of survival after metamorphosis (Jennings and 

Hayes, 1994).

California tiger salamanders are relatively long-lived animals, reaching ages of 20 years or more 

in captivity (Jennings, unpubl. data). The average life span of adults in the wild is unknown. 

Larval California tiger salamanders subsist on aquatic invertebrates (Oligochaetes, Cladocera, 

Conchostraca, Ostracoda, Anostraca, Notostraca, Chironomids, etc.), as well as the larvae of 

western spadefoots (Scaphiopus hammondii), California toads (Bufo boreas halophilus), and 

Pacific treefrogs (Hyla regilla) (Anderson 1968; Feaver 1971; Jennings, unpubl. data). Larval 

salamanders are also highly cannibalistic (Jennings, unpubl. data). Good numbers of food 

organisms in breeding ponds appear to be important for the survival and rapid growth of 

salamander larvae to metamorphosis (Jennings, unpubl. data). Juvenile and adult salamanders 

subsist on terrestrial invertebrates (Oligochaetes, Isopoda, Orthoptera, Coleoptera, Diptera, 

Araneida, Gastropoda) (Stebbins, 1972; Morey and Guinn, 1992; Jennings, unpubl. data). There 

is no evidence of adult salamanders feeding in aquatic environments (Jennings, unpubl. data).

Historical Information:

The historical distribution of the California tiger salamander ranged from the vicinity of 

Petaluma, Sonoma County and Dunnigan, Colusa-Yolo County line (Storer, 1925) with an 
2013 VGP and sVGP BE Appendix F

F-99

isolated outpost north of the Sutter Buttes at Gray Lodge, Butte County (Hayes and Cliff, 1982) 

in Central Valley, south to vernal pools in northwest Tulare County, and in the South Coast 

Range south to ponds and vernal pools between Bulleton and Lompoc in the Santa Ynez 

drainage, Santa Barbara County (Jennings and Hayes, 1994). The known elevational range 

extends from 3 m-1054 m (Shaffer et al., 1993). The species has disappeared from about 55% of 

its historic range (Jennings and Hayes, 1994).

In the Bay Area, California tiger salamanders have disappeared from almost all of the lower 

elevation areas (<50 m), save one small site on the San Francisco Wildlife Refuge near Fremont, 

Alameda County (Jennings, unpubl. data). There are scattered populations currently inhabiting 

vernal pool and stockpond habitats in hills surrounding the South Bay (Jennings, unpubl. data), 

to the nort of Coyote Hills in Suisun, and in northern Contra Costa. A group of relict populations 

is also present in the North Bay region in vernal pool habitats near Petaluma (Shaffer et al.,

1993)

Conservation Status:

Based on the data presented in Shaffer et al. (1993) and Jennings and Hayes (1994), California 

tiger salamanders appear to have disappeared from approximately 58% and 55% (respectively), 

of their historic range in the state (Sorensen, 1994). Although the species still occurs throughout 

most of the historical range and remains locally common in some areas, the recent and projected 

future rate of decline remains high. Consequently, the species was federally listed as Threatened 

rangewide in 2004.

Summary of Major Threats:

This salamander is most affected by land use patterns and other anthropogenic events which 

fragment habitat and create barriers between breeding and refuge sites (Jennings and Hayes,

1994). Some of the more important factors negatively influencing salamander populations 

include: conversion and isolation of vernal pool habitats (and surrounding oak woodland and 

grasslands) to agriculture and urbanization (Barry and Shaffer, 1994); lowering of the 

groundwater table by overdraft (Jennings and Hayes, 1994); mortality of juvenile and adult 

salamanders by vehicles on roads (Twitty, 1941); the introduction of non-native predators such 

as mosquitofish (Gambusia affinis), bullfrogs (Rana catesbeiana) and crayfish into breeding 

habitats (Shaffer et al. 1993); the widespread poisoning of California ground squirrels and other 

burrowing rodents (Loredo et al., 1996); and interbreeding with introduced salamanders 

originally brought in as live fish bait (Shaffer et al., 1993).

F.6.4.

Arctocephalus townsendi

GUADALUPE FUR SEAL

Family: Otariidae

Threatened: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=A0A8)
2013 VGP and sVGP BE Appendix F

F-100

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Arctocephalus+t

ownsendi)

• NOAA Fisheries, 2012 

(http://www.nmfs.noaa.gov/pr/species/mammals/pinnipeds/guadalupefurseal.htm)

Description:

Guadalupe fur seals are members of the "eared seal" family, Otariidae. Guadalupe fur seals are 

sexually dimorphic with males reaching average lengths of about 7 ft. (2 m) and weighing about 

400 lbs. (180 kg) while females average lengths and weights are much smaller at about 5 ft. (1.5 

m) and 110 lbs. (50 kg), respectively. They have a narrow, flat head with a pointed, narrow, and 

long snout. Their fore-flippers are broad, with some hair, reaching slightly past their wrist. Their 

coloration is dark brown to black with adult males having tan or yellow hairs on the back of the 

mane.

Geographic Boundaries and Spatial Distribution:

Guadalupe fur seals are non-migratory and their breeding grounds are almost entirely on 

Guadalupe Island, Mexico. There are small populations off of Baja California on San Benito 

Island and off of Southern California at San Miguel Island. It is the only species of the 

Arctocephalus genus that occurs north of the equator. The species is known or is believed to 

occur in California.

Habitat: (no critical habitat)

Guadalupe fur seals reside in the tropical waters of the Southern California/Mexico region. 

During breeding season, they are found in coastal rocky habitats and caves. Little is known about 

their whereabouts during the non-breeding season (May to September).

Life History:

Guadalupe fur seals are solitary, non-social animals. Males are polygamous and may mate with 4 

to 12 females during a single breeding season. Males form small territories that they defend by 

roaring or coughing. Breeding season is June through August, with females arriving in early June 

and pups are born a few days after their arrival. A female will mate about a week after giving 

birth to her pup and weaning occurs around 9 months. Guadalupe fur seals feed mainly at night 

on squid, mackerel, and lantern fish by diving up to depths of 65 ft. (20 m).

Historical Information:

Historical population was at least 30,000. They were reduced to near extinction by the fur seal 

trade. Population increased in the early 1900s to at least 1,073 in 1978 and 1,600 in 1984; total 

count in 1987 was 3,259 at Guadalupe Island, including 468 adult males, 78 subadult males, 

1,134 females, 472 juveniles, and 998 pups (Reeves et al. 1992).

Conservation Status:

The Guadalupe fur seal population is slowly recovering from the brink of extinction. The current 

population abundance is approximately 10,000 animals. Of all the fur seal species, this one is the 
2013 VGP and sVGP BE Appendix F

F-101

least studied due to their limited geographic locations. The Guadalupe fur seal population is 

increasing about 13.7% annually.

The Guadalupe fur seal was listed as threatened throughout its range on December 16, 1985 

under the Endangered Species Act of 1973 and is also protected under the Marine Mammal 

Protection Act of 1972, as amended. In 1975, the government of Mexico declared Guadalupe 

Island a pinniped sanctuary. NMFS has classified the U.S. Guadalupe fur seal stock as a strategic 

stock.

Summary of Major Threats:

In the 1700s and 1800s, commercial sealers heavily hunted Guadalupe fur seals to the point 

where the species was thought to be extinct by the early 1900s. Insufficient data exist on the 

incidental bycatch of Guadalupe fur seals in fishing gear, although some juvenile seals have been 

documented with entanglement injuries. Currently, the species is vulnerable to mortality from oil 

spills, and offshore oil and gas exploration may affect potential habitat off California coast 

(Matthews and Moseley, 1990). USAF space shuttle program's sonic booms could cause 

disturbance. Three of nine stranded individuals found recently in central and northern California 

had experienced entanglement in fishing gear or marine debris (Hanni et al., 1997).

F.6.5.

Blennosperma bakeri

SONOMA SUNSHINE

Family: Asteraceae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q1TO)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Blennosperma+b

akeri)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc1992.pdf)

Description:

Blennosperma bakeri is a small (up to 30.5 centimeters (12.0 inches) in height), annual herb in 

the aster family (Asteraceae). The plant has alternate, narrow, hairless leaves 5.1 centimeters (2.0 

inches) to 15.2 centimeters (6.0 inches) long. The upper ones have 1 to 3 lobes, the lower ones 

none. From March through April, the species produces yellow daisy-like flowers. The yellow 

disk flowers have white pollen and stigmas. Sterile ray flowers, which are yellow or sometimes 

white, have red stigmas. The lobe pattern of the leaves and the color of ray stigmas separate this 

species from others in the genus.

Geographic Boundaries and Spatial Distribution:

Blennosperma bakeri occurs only in Sonoma County, California, and ranges in the Santa Rosa 

Plain from near the community of Fulton in the north to Scenic Avenue between Santa Rosa and 
2013 VGP and sVGP BE Appendix F

F-102

Cotati in the south. Additionally, the species extends from near Glen Ellen to near the junction of 

State Routes 116 and 121 in the Sonoma Valley. In addition, B. bakeri has been introduced to at 

least one site on Alton Lane during mitigation activities.

Habitat: (no critical habitat)

Blennosperma bakeri grows in vernal pools and wet grasslands below 100 meters (330 feet) 

(Ornduff 1993a). Blennosperma bakeri occurs in vernal pools on nearly level to slightly sloping 

loams, clay loams, and clays.

Life History:

The flowers of B. bakeri are self-incompatible, meaning that they can set seed only when 

fertilized by pollen from a different plant.

Historical Information:

Patterson et al. (1994) estimated less than 12 biologically separate populations remain. Of the 

sites they examined, 17 percent had been extirpated, and 17 percent had not been confirmed 

recently. An additional 17 percent were believed to be extant but threatened by development as 

of 1994 (Patterson et al., 1994). At one occurrence, 12 B. bakeri colonies were observed in 1989, 

by 1993, only six remained (CNDDB, 1998).

Conservation Status:

The Service used data from 1994 (Patterson et al. 1994) to examine how numbers of B. bakeri 

plants at particular sites changed between the time of listing and the most current surveys that 

had been performed after listing. After listing, the number of sites with many individuals 

decreased, and the number with less than 10 individuals increased. The percentage of sites with 

fewer than 10 individuals has increased by 15 percent between the time of listing and 1994.

Summary of Major Threats:

The reduction and fragmentation of habitat due to urban development, agriculture-land 

conversion, and habitat degradation from overgrazing, agriculture, and other human-related 

changes to vernal pool hydrology are listed as the primary threats to the species in the 1991 

listing rule (56 FR 61173). Additional threats identified in the 1991 rule include off-road 

vehicles and erosion. Consistent with the 1991 rule, the largest continuing threat to this species 

are urban development and land conversion to viticulture or other intense agriculture activities.

F.6.6.

Brachyramphus marmoratus or Brachyramphus marmoratus marmoratus

MARBLED MURRELET 

(See Seattle, Washington for information on this species)

F.6.7.

Branchinecta conservatio

CONSERVANCY FAIRY SHRIMP

Family: Branchinectidae

Endangered: wherever found
2013 VGP and sVGP BE Appendix F

F-103

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=K03D)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Branchinecta+co

nservatio)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc1148.pdf)

• 71 FR 7118 (http://www.gpo.gov/fdsys/pkg/FR-2006-02-10/pdf/06-1080.pdf#page=1)

• 70 FR 46924 (http://www.gpo.gov/fdsys/pkg/FR-2005-08-11/pdf/05-15569.pdf#page=1)

Description:

Conservancy fairy shrimp are tiny freshwater crustaceans with delicate elongate bodies, large 

stalked compound eyes, and 11 pairs of phyllopods (swimming legs that also function as gills). 

Fairy shrimp do not have a hard shell, a characteristic of the order Anostraca to which they 

belong, this species differs from other branchinectids in the flattened portions of its antennae.

Geographic Boundaries and Spatial Distribution:

Conservancy fairy shrimp are endemic to vernal pools in California and this species is restricted 

to the Central Valley except for one population in the Central Coast in Ventura County.

Habitat: (has critical habitat):

The majority of sites inhabited by this animal are relatively large and turbid vernal pools called 

playa pools (Helm, 1998, Eriksen and Belk, 1999, Vollmar, 2002). Playa pools typically remain 

inundated much longer than most vernal pools, often well into the summer, even though they 

often have maximum depths comparable to vernal pools. Playa pools are distinguished from 

vernal pools because they are larger in size and they are much rarer on the landscape than vernal 

pools (Vollmar, 2002).

Critical habitat for the Conservancy fairy shrimp and several other vernal pool species was 

designated on August 11, 2005. The final designation of critical habitat for Conservancy fairy 

shrimp is 161,786 ac (65,473 ha).

The primary constituent elements of critical habitat for Conservancy fairy shrimp are the habitat 

components that provide: (1) topographic features characterized by mounds and swales and 

depressions within a matrix of surrounding uplands that result in complexes of continuously, or 

intermittently, flowing surface water in the swales connecting pools, providing for dispersal and 

promoting hydroperiods of adequate length in the pools; (2) depressional features including 

isolated vernal pools with underlying restrictive soil layers that become inundated during winter 

rains and that continuously hold water for a minimum of 19 days, in all but the driest years, 

thereby providing adequate water for incubation, maturation, and reproduction. As these features 

are inundated on a seasonal basis, they do not promote the development of obligate wetland 

vegetation habitats typical of permanently flooded emergent wetlands; (3) sources of food, 

expected to be detritus occurring in the pools, contributed by overland flow from the pools’ 

watershed, or the results of biological processes within the pools themselves, such as singlecelled bacteria, algae, and dead organic matter, to provide for feeding; and (4) structure within 
2013 VGP and sVGP BE Appendix F

F-104

the pools, consisting of organic and inorganic materials, such as living and dead plants from 

plant species adapted to seasonally inundated environments, rocks, and other inorganic debris 

that may be washed, blown, or otherwise transported into the pools, that provide shelter.

Life History:

The eggs are dropped from the brooding female to the benthos. The eggs hatch when the vernal 

pools and swales fill with rainwater and the immature stages rapidly develop into adults. Other 

life history characteristics include mean days to mature (36.5), mean days to reproduce (46.2), 

mean population longevity in days (113.9) (Helm, 1998).

Historical Information:

The historical range of Conservancy fairy shrimp is not known (Service, 2005). The species’ 

range has not increased since the species was listed in 1994. Two populations of Conservancy 

fairy shrimp were detected on State lands since the time of listing, and include the Great Valley 

Grasslands State Park and the Yolo Bypass Wildlife Area; however, these detections did not 

increase the known range of this species.

Conservation Status:

Conservancy fairy shrimp are rare, and at the time of listing, six widely separated populations 

(i.e., clusters of localities) of this species were known (59 FR 48136). Extensive surveys for fairy 

shrimp species throughout the range of Conservancy fairy shrimp have located only two 

additional populations since the species was listed in 1994. Currently, the Service is aware of 

eight populations of Conservancy fairy shrimp, which include (from north to south): (1) Vina 

Plains, Butte and Tehama counties; (2) Sacramento National Wildlife Refuge (NWR), Glenn 

County; (3) Yolo Bypass Wildlife Area, Yolo County; (4) Jepson Prairie, Solano County; 

(5) Mapes Ranch, Stanislaus County; (6) University of California (U.C.) Merced area, Merced 

County; (7) Grasslands Ecological Area, Merced County; and, (8) Los Padres National Forest, 

Ventura County (Figure 1).

Summary of Major Threats:

When the Conservancy fairy shrimp was listed as endangered in 1994, the primary threats to its 

survival and recovery were stochastic (random) extinction by virtue of the small isolated nature 

of many of the populations, and loss of habitat due to urban development and conversion to 

agriculture (59 FR 48136). This species is highly susceptible to extirpation due to chance events 

or additional environmental disturbance as described above. If an isolated population is 

extirpated, the opportunities for recolonization will be greatly reduced due to physical isolation 

from other source populations. Other potential threats include habitat degradation due to 

inappropriate grazing regimes, pesticide use, and invasive weedy species.

F.6.8.

Branchinecta longiantenna

LONGHORN FAIRY SHRIMP

Family: Branchinectidae

Endangered: wherever found
2013 VGP and sVGP BE Appendix F

F-105

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=K03E)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Branchinecta+lo

ngiantenna)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc1149.pdf)

• 71 FR 7118 (http://www.gpo.gov/fdsys/pkg/FR-2006-02-10/pdf/06-1080.pdf#page=1)

• 70 FR 46924 (http://www.gpo.gov/fdsys/pkg/FR-2005-08-11/pdf/05-15569.pdf#page=1)

Description:

Longhorn fairy shrimp are tiny freshwater crustaceans with delicate elongate bodies, large 

stalked compound eyes, and 11 pairs of phyllopods (swimming legs that also function as gills). 

Fairy shrimp do not have a hard shell, a characteristic of the order Anostraca to which they 

belong. Longhorn fairy shrimp are easily distinguished from other fairy shrimp by the male’s 

extremely long second antennae.

Geographic Boundaries and Spatial Distribution:

Longhorn fairy shrimp are restricted to the Central Valley. The four known populations of 

longhorn fairy shrimp include: (1) areas within and adjacent to the Carrizo Plain National

Monument, San Luis Obispo County; (2) areas within the San Luis National Wildlife Refuge 

(NWR) Complex, Merced County; (3) areas within the Brushy Peak Preserve, Alameda County; 

and, (4) areas within the Vasco Caves Preserve, near the town of Byron in Contra Costa County 

(Service, 2005). The Brushy Peak and Vasco Caves Preserves are within three miles of each 

other. This species was also detected in a roadside ditch two miles north of Los Banos, in 

Merced County.

Habitat: (has critical habitat)

Longhorn fairy shrimp are dependent on seasonally inundated wetlands, such as vernal pools, 

and are endemic to California vernal pool habitat. It has been found in grass-bottomed pools in 

unplowed grasslands as well as rock outcrop, clear-water pools (Eng et al., 1990). Known to 

occur in clear, small (4.6-74.4 square meter) to medium size (2788 square meter) pool 

depressions in bedrock outcrops in Contra Costa and Alameda Counties; moderately deep (15-40 

cm), medium to large sized (2788-8364 square meter) turbid alkali pools in the Kesterson 

National Wildlife Refuge in western Merced County and similar habitats surrounding Soda Lake 

in San Luis Obispo County (Eriksen and Belk, 1999). It is currently found in pools located 

within a matrix of alkali sink and alkali scrub plant communities north and northwest of Soda 

Lake and at the southern end of the Carrizo Plain National Monument in the Carrizo Vernal Pool 

Region, in a series of sandstone outcrop pools in the Livermore Vernal Pool Region, and from 

alkaline grassland vernal pools in the San Luis NWR (USFWS, 2005).

Critical habitat for the longhorn fairy shrimp and several other vernal pool species was 

designated on August 11, 2005. The final designation of critical habitat for longhorn fairy shrimp 

is 13,557 ac (5,486 ha).
2013 VGP and sVGP BE Appendix F

F-106

The primary constituent elements of critical habitat for longhorn fairy shrimp are the habitat 

components that provide: (1) topographic features characterized by mounds and swales and 

depressions within a matrix of surrounding uplands that result in complexes of continuously, or 

intermittently, flowing surface water in the swales connecting pools, providing for dispersal and 

promoting hydroperiods of adequate length in the pools; (2) depressional features including 

isolated vernal pools with underlying restrictive soil layers that become inundated during winter 

rains and that continuously hold water for a minimum of 23 days, in all but the driest years; 

thereby providing adequate water for incubation, maturation, and reproduction. As these features 

are inundated on a seasonal basis, they do not promote the development of obligate wetland 

vegetation habitats typical of permanently flooded emergent wetlands; (3) sources of food, 

expected to be detritus occurring in the pools, contributed by overland flow from the pools’ 

watershed, or the results of biological processes within the pools themselves, such as singlecelled bacteria, algae, and dead organic matter, to provide for feeding; and (4) Structure within 

the pools, consisting of organic and inorganic materials, such as living and dead plants from 

plant species adapted to seasonally inundated environments, rocks, and other inorganic debris 

that may be washed, blown, or otherwise transported into the pools, that provide shelter.

Life History:

Longhorn fairy shrimp require a minimum of 23 days, but averaged 43 days, to reach maturity in 

artificial pools (Helm, 1998). The mean population longevity is 114 days (Helm, 1998). The eggs 

are dropped from the brooding female to the benthos. The eggs hatch when the vernal pools and 

swales fill with rainwater and the immature stages rapidly develop into adults. 

Historical Information:

The distribution of the longhorn fairy shrimp may never have extended into the northern portion 

of the Central Valley or into southern California. Extensive surveying of vernal pool habitats in 

southern California has never revealed populations of longhorn fairy shrimp. There is some 

evidence that temperatures may not be warm enough for the species to mature in the northern 

portions of the Central Valley. However, it is likely the longhorn fairy shrimp was once more 

widespread in the regions where it is currently known to occur, and in adjacent areas such as the 

San Joaquin and Southern Sierra Foothill Vernal Pool Regions, where habitat loss has been 

extensive. Despite lack of knowledge on the tolerance of longhorn fairy shrimp to cooler 

temperatures, its presence in northern Central Valley vernal pool regions cannot be ruled out 

until further surveys have been conducted (Service, 2005).

Conservation Status:

Longhorn fairy shrimp are rare, and at the time of listing four widely separated populations of 

this species were known (59 FR 48136). Since the time of listing in 1994, extensive surveys for 

fairy shrimp species throughout the range of longhorn fairy shrimp have not located additional 

populations of this species, although longhorn fairy shrimp have been detected in additional 

localities within the four populations. Currently, the California Natural Diversity Database 

(CNDDB) reports 11 occurrences of this species (CNDDB, 2007).

There is a lack of monitoring data to indicate numbers of longhorn fairy shrimp at any locality, 

or whether the species is present in only a small percentage of the pools at a site. In most cases, 

there is no information to indicate that observed localities represent demographically 
2013 VGP and sVGP BE Appendix F

F-107

independent units that contribute to species viability, and the long-term viability of the species at 

most sites is unknown.

Summary of Major Threats:

The primary threat to this species described in the 1994 final listing rule is habitat loss due to 

agriculture conversion and urbanization. While this continues to be a threat to vernal pool 

species in general, the majority of known populations of longhorn fairy shrimp are protected 

from land-use conversion on public lands. Therefore, this threat has been removed from 

protected populations. Other threats exist, such as the increased risk of local extirpations from 

stochastic events because of the small number of isolated populations for this species, and risks 

from environmental disturbances, including severe drought, degradation of habitat from invasive 

weedy plant species, inappropriate grazing regimes, and other unforeseen events. 

F.6.9.

Caretta caretta

LOGGERHEAD SEA TURTLE

(See New York, New York for information on this species)

F.6.10.

Carex albida

WHITE SEDGE

Family: Cyperaceae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q0BL)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Carex+albida)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc2555.pdf)

Description:

White sedge, Carex albida is a perennial herb in the sedge family with short fiber-covered 

rhizomes. The culms (stems) are triangular, 1.3-2.0 ft. tall, erect, and longer than the leaves. 

White sedge has inflorescence with staminate (male) flowers above the pistillate (female) 

flowers, especially on the terminal inflorescence, lateral spikelets, and leaves that are shorter 

than the stems and 0.1-0.2 inches (3-5 mm) wide.

Geographic Boundaries and Spatial Distribution:

The species is known only from a 10 square km area in Sonoma County, California. A single 

population, consisting of < 1000 plants, is known extant. 
2013 VGP and sVGP BE Appendix F

F-108

Habitat: (no critical habitat)

White sedge is found in wet hillside meadows and freshwater wetlands 150-200 ft. in elevation. 

These wetlands are acidic, sandy/peaty fens, which support mixed native willow riparian, oak 

woodland, and grasslands.

Life History:

No information.

Historical Information:

Three historically known occurrences were extirpated by wetland drainage, channelization of a 

stream, and by the disposal of cannery waste (CNPS, 2001). Only 1 site is confirmed extant 

(CNPS 2001). Botanists have been denied access to other historically known sites, but it is feared 

that altered hydrology may have extirpated these populations.

Conservation Status:

Currently, white sedge continues to be known from one occurrence in the lower northern marsh. 

The surveys conducted in 2005 revealed the occurrence was distributed in six somewhat separate 

colonies on the 27-acre property and totaled approximately 200 plants (Patterson, 2005). The 

lowermost colony, which was estimated to have about 100 plants in the late 1980s, had 

apparently declined to 130 plants in 2005.

Summary of Major Threats:

The acquisition of the property that has the only known occurrence has eliminated the threat of 

development and agricultural uses, however several dense strand of invasive blackberry and 

perennial grasses on the property pose a significant threat of habitat encroachment. Additionally 

surrounding residential and agricultural uses in the upper slopes of the watershed pose a threat on 

the hydrology of the marsh. 

F.6.11.

Chamaesyce hooveri

HOOVER’S SPURGE

Family: Euphorbiaceae

Threatened: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q0E9)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Chamaesyce+ho

overi)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc2387.pdf)

• 71 FR 7118 (http://www.gpo.gov/fdsys/pkg/FR-2006-02-10/pdf/06-1080.pdf#page=1)

• 70 FR 46924 (http://www.gpo.gov/fdsys/pkg/FR-2005-08-11/pdf/05-15569.pdf#page=1)
2013 VGP and sVGP BE Appendix F

F-109

Description:

Hoover’s spurge, Chamaesyce hooveri is a summer annual member of the Euphorbiaceae 

(spurge family) that is a vernal pool endemic. It forms gray-green mats from a few inches to a 

few feet across. The flowering structure is a small, highly simplified cup-like "cyathium," as in 

all other spurges (Chamaesyce and Euphorbia). The flowering structure in Hoover’s spurge has 

petallike glands that are red to olive in color. Flowers bloom in July. This species is readily 

distinguished from other species of Chamaesyce by characteristics of growth habit, plant color 

and leaf shape. It is distinguished from plants in the genus Euphorbia on the basis of growth 

habit, vascular anatomy, and photosynthetic pathway.

Geographic Boundaries and Spatial Distribution:

The plant is restricted to vernal pools on the eastern margin of the Central Valley of California 

with 25 extant populations. Hoover’s spurge has been reported in Tehama, Butte, Glenn, 

Stanislaus, Merced, and Tulare Counties.

Habitat: (has critical habitat)

Hoover’s spurge generally grows in relatively large, deep vernal pools among the rolling hills, 

remnant alluvial fans and depositional stream terraces at the base of the Sierra Nevada foothills. 

It tends to occur where competition from other species has been reduced by prolonged seasonal 

inundation or other factors. This species is currently found in three types of vernal pools: 

Northern Basalt Flow, Northern Claypan, and Northern Hardpan on both low and high terraces 

(Stone, et al. 1988).

Critical habitat for Hoover’s spurge and several other vernal pool species was designated on 

August 11, 2005. The final designation of critical habitat for Hoover’s spurge is 114,713 ac 

(46,423 ha).

The primary constituent elements of critical habitat for Hoover’s spurge are the habitat 

components that provide: (1) topographic features characterized by isolated mound and 

intermound complex within a matrix of surrounding uplands that result in continuously, or 

intermittently, flowing surface water in the depressional features including swales connecting 

pools, providing for dispersal and promoting hydroperiods of adequate length in the pools; and 

(ii) depressional features including isolated vernal pools with underlying restrictive soil layers 

that become inundated during winter rains and that continuously hold water or whose soils are 

saturated for a period long enough to promote germination, flowering, and seed production of 

predominantly annual native wetland species and typically exclude both native and nonnative 

upland plant species in all but the driest years. As these features are inundated on a seasonal 

basis, they do not promote the development of obligate wetland vegetation habitats typical of

permanently flooded emergent wetlands.

Life History:

It grows on the dried mudflats in the deepest portions (often middle) of vernal pools. Plant 

emerges from large cracks which spread as the clay of the pool bottom dries. There is usually 

very little herbaceous cover growing with Hoover’s spurge, though the plant has been observed 

to grow in the shade of other low-growing species. Distribution and abundance of Hoover’s 

spurge may be limited by competition from native and introduced plants. 
2013 VGP and sVGP BE Appendix F

F-110

Historical Information:

The species was original listed on March 26, 1997 (62 FR 14338). Critical habitat for this species 

was proposed on September 24, 2002 (67 FR 60033). The final rule to designate critical habitat 

for Chamaesyce hooveri was published on August 6, 2003 (68 FR 46684). A re-evaluation of 

non-economic exclusions from the August 2003 final designation was published on March 8, 

2005 (70 FR 11140). An evaluation of economic exclusions from the August 2003 final 

designation was published on August 11, 2005 (70 FR 46924). Administrative revisions were 

published on February 10, 2006 (71 FR 7117). Clarifications on the economic and non-economic 

exclusions for the final designation of critical habitat were published on May 31, 2007 (72 FR 

30279).

Conservation Status:

Of the 31 known occurrences and sites, 27 are presumed to be extant (LSA, 2003; CNDDB,

2007). The majority of the presumed extant occurrences and sites are located in the Vina Plains 

area, in Tehama and Butte Counties, where 14 occurrences and one site are presumed extant 

(LSA, 2003; CNDDB, 2007). The next largest concentration of occurrences is in Tulare County, 

where seven occurrences are presumed extant. The CNDDB indicates that of the 26 occurrences 

that are listed as “presumed extant,” 6 occurrences have not been surveyed in over 20 years and 

another 8 have not been surveyed since the late 1980s (CNDDB, 2007). Because surveys have 

not been performed at many of these occurrences in nearly twenty years, the actual status of 

these occurrences is not known at this time. The majority of occurrences of C. hooveri are not 

protected. 

Summary of Major Threats:

When Hoover’s spurge was listed as threatened in 1997, the primary threats to its survival and 

recovery were loss of habitat by agricultural conversion, habitat degradation by numerous 

activities associated with agricultural development, past extirpation and continued threat by 

urban development projects, inadequate regulatory mechanisms, and competition with nonnative 

weeds. There is no new information to suggest that these threats to the species have substantially 

changed since the time of listing in 1997. In addition, other factors, such as drought, climate 

change, and small population size, may also threaten this species. The majority of the localities 

of Hoover’s spurge do not have management plans, monitoring programs, or adequate funding to 

ensure that these localities are sustainable in perpetuity. Lack of management especially for 

nonnative species and hydrology; monitoring; and funding are not, in themselves, threats to 

Hoover’s spurge; however, without these components, the potential threats may not be identified 

and eliminated.

F.6.12.

Charadrius alexandrines nivosus

WESTERN SNOWY PLOVER

Family: Charadriidae

Threatened: Pacific Coastal Population (CA, OR and WA)
2013 VGP and sVGP BE Appendix F

F-111

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=B07C)

• Goals Project, 2000 (http://www.sfestuary.org/pdfs/speciescommunity/Species_and_Community_Profiles%5BPart1%5D.pdf)

• 76 FR 16046 (http://www.gpo.gov/fdsys/pkg/FR-2011-03-22/pdf/2011-4906.pdf)

• 70 FR 56970 (http://www.gpo.gov/fdsys/pkg/FR-2005-09-29/pdf/05-19096.pdf#page=1)

Description:

The snowy plover is a small (15-17 cm long) shorebird, with a light brown back and cap; white 

underparts; brown to black forehead bar; brown to black lateral breast patches and cheek patches; 

short black bill; and black legs. Snowy plovers weigh between 1.2 and 2 ounces.

Geographic Boundaries and Spatial Distribution:

Breeding distribution of the snowy plover is along the Pacific coast north to Washington (most 

numerous from San Francisco Bay south), south to Oaxaca, and locally (but in larger numbers) 

inland from Oregon and California (especially the San Joaquin Valley, Mojave Desert, and 

Salton Sea regions) east to Kansas and Texas and south to southeastern California, southern 

Arizona, southern New Mexico, and north-central Texas. The largest inland concentration is 

around the Great Salt Lake, Utah. Non-breeding distribution includes islands and on coast from 

Oregon south to Guatemala; and the Gulf of Mexico from southern Texas to Mississippi (Page et 

al. 1995).

Habitat: (has critical habitat)

Habitats important to snowy plover include mudflats and sandflats (used for feeding); salt pan 

(used for nesting and feeding); and unvegetated levees, islets, and beaches (used for nesting, 

feeding, and roosting). In the San Francisco Bay RAA, important geographic regions are South 

Bay, Central Bay, and North Bay.

A total of 12,145 ac of land was designated as critical habitat for the snowy plover, in California, 

Oregon, and Washington on October 31, 2005. In March 2011, it was proposed to increase the 

critical habitat to 28,261 ac, with 16,777 ac in California.

The primary constituent elements of critical habitat for the pacific coast population of western 

snowy plover are the habitat components that provide: (1) sparsely vegetated areas above daily 

high tides (such as sandy beaches, dune systems immediately inland of an active beach face, salt 

flats, seasonally exposed gravel bars, dredge spoil sites, artificial salt ponds and adjoining levees) 

that are relatively undisturbed by the presence of humans, pets, vehicles or human-attracted 

predators (essential for reproduction, food, shelter from predators, protection from disturbance, 

and space for growth and normal behavior); (2) sparsely vegetated sandy beach, mud flats, gravel 

bars or artificial salt ponds subject to daily tidal inundation, but not currently under water, that

support small invertebrates (essential for food); and (3) surf or tide-cast organic debris such as 

seaweed or driftwood (essential to support small invertebrates for food, and to provide shelter 

from predators and weather for reproduction).
2013 VGP and sVGP BE Appendix F

F-112

Life History:

Snowy plovers are foraging birds usually pausing, looking, and then running to seize invertebrate 

prey from the surface of a beach, tidal flat or salt pan. Plovers also probe shallowly into the sand 

or mud for prey, or lower their heads and charge openmouthed at aggregations of flies, snapping 

the bill at those that are flushed. 

Feeney and Maffei (1991) monitored snowy plover nests in the Oliver Brothers/Baumberg region 

salt ponds during the 1989 breeding season. They located 66 nests, and 14 broods from nests 

which they did not find. Assuming the broods were from nests in locations they were studying, 

they located a seasonal nest total ranging from one nest per 1.1 hectare (ha) to one nest per 5.8 ha 

in four subregions of their salt pond study area. From all day watches of parent(s) with broods, 

they found the daily area covered by a brood ranged from 0.1- 5.5 ha and averaged 1.6 ha. They 

noted that vegetation was used by chicks for hiding and for foraging. Northern harriers were 

observed hunting in areas where young snowy plovers were the only likely prey; an American 

kestrel was observed taking a snowy plover chick; and a peregrine falcon was seen taking an 

adult snowy plover. Ravens, ground squirrels, and California gulls also prey on the species.

Snowy plovers are known to move between salt pond breeding, foraging, and roosting sites, and 

mudflat foraging sites during all seasons.

Historical Information:

The population of snowy plovers that breeds along the Pacific Coast of the United States and 

Baja California, Mexico was designated as Threatened by the U.S. Fish and Wildlife Service in 

March 1993. There are no records of snowy plover breeding in San Francisco Bay prior to the 

construction of salt ponds. This species may have bred on natural playas on the inner fringes of 

salt marsh which existed prior to conversion of South Bay marshes to salt ponds. Snowy plovers 

have been documented in San Francisco Bay during winter as early as the late 1800s (Page et al. 

1986).

Conservation Status:

The breeding population along the western coast of the United States has declined and the 

breeding range has become increasingly fragmented during the past century. Surveys from the 

late 1970s, the species was absent from 33 of 53 California coastal locations with breeding 

records prior to 1970 and was missing from parts of San Diego, Ventura and Santa Barbara 

counties, most of Orange County, and all of Los Angeles County (Page and Stenzel, 1981). 

Along the coast of Washington, Oregon and California combined, there was an approximate 20% 

decline in the size of the breeding population on surveys between the late 1970s and late 1980s 

(Page et al., 1991). Within San Francisco Bay, the population also appears to have declined as 

evidenced by the drop from 351 adults on the 1978 survey to 226 (216 in South Bay) on a 1989 

survey (Page et al., 1991).

Summary of Major Threats:

Poor reproductive success due to human disturbance (including mechanical raking of beaches) is 

a major problem; much habitat has been lost to development, and spread of introduced beach 

grass limits the amount of suitable nesting habitat. The species is increasingly vulnerable to 

native and introduced predators (1992, End. Sp. Tech. Bull. 17(12):18; Page et al. 1995).
2013 VGP and sVGP BE Appendix F

F-113

F.6.13.

Chelonia mydas

GREEN SEA TURTLE

(See Seattle, Washington for information on this species)

F.6.14.

Cirsium fontinale var. fontinale

FOUNTAIN THISTLE

Family: Asteraceae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q1UH)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc3564.pdf)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?sourceTemplate=tabular_repor

t.wmt&loadTemplate=species_RptComprehensive.wmt&selectedReport=RptComprehen

sive.wmt&summaryView=tabular_report.wmt&elKey=147464&paging=home&save=tru

e&startIndex=1&nextStartIndex=1&reset=false&offPageSelectedElKey=144460&offPag

eSelectedElType=species&offPageYesNo=true&post_processes=&radiobutton=radiobutt

on&selectedIndexes=144460&selectedIndexes=147464&selectedIndexes=130070)

Description:

Fountain thistle, Cirsium fontinale var. fontinale, is a perennial herb in the aster family 

(Asteraceae) and is 30 to 60 cm (1 to 2 feet) tall and is restricted to perpetually moist serpentine 

seeps or streams in chaparral, valley, or foothill grasslands (Keil and Turner, 1993; CNPS, 

2001). Generally, the flower heads are grouped into clusters and are nodding when in bloom. 

Flowers are white to pink or lavender and appear from June to October (Keil and Turner, 1993). 

Geographic Boundaries and Spatial Distribution:

Fountain thistle is currently found only in San Mateo County, California.

Habitat: (no critical habitat)

Fountain thistle is found in serpentine seeps in grasslands or chaparral. The largest occurrence of 

the species, which is a group of approximately 10 subpopulations, is located on the east side of 

Crystal Springs Reservoir and is approximately 400 feet in elevation. The Stulsaft Park 

occurrence is found in a serpentine seep in an opening in a coast live oak-bay (Quercus agrifolia 

– Umbellularia Californica) woodland. The elevation of this site is 150 feet. The occurrence east 

of Woodside Glens is located on a serpentine seep in an open area associated with sedges. The 

elevation of this site is not known.

Life History:

Flowering period is June-October.
2013 VGP and sVGP BE Appendix F

F-114

Historical Information:

At the time of listing in 1995, the fountain thistle was known from three locations in San Mateo 

County. One occurrence consisting of several subpopulations was located east of Crystal Springs 

Reservoir, a second occurrence was found 10 km (6 mi) to the south in the Triangle area, 

southwest of the intersection of Edgewood Road and the I-280 overpass and west of Redwood 

City (CNDDB, 2009) and the third occurrence consisted of a single plant in Edgewood Park. 

During surveys conducted by the San Francisco Public Utilities Commission (SFPUC) in 

December 2009, plants continued to be found at Element Occurrence 1 (in the CNDDB), east of 

Crystal Springs Reservoir. In recent years some small subpopulations of Element Occurrence 1 

could not be relocated; however, during the December 2009 surveys a new large subpopulation 

was discovered which is also part of Element Occurrence 1. Element Occurrence 1 comprises 97 

percent of all known plants of this species. The Triangle and Edgewood Park occurrences have 

been extirpated (S. Foree, San Francisco Water District, pers. comm., August 5, 2009). Two 

additional small occurrences have been found since the time of listing. One occurrence (Element 

Occurrence 7) was discovered at Stulsaft Park, in Redwood City, in 2007. Another occurrence 

(Element Occurrence 8) was found east of Woodside Glens in 2003. 

Conservation Status:

At the time of listing in 1995, three fountain thistle occurrences were known to exist: 1) the 

occurrence located east of Crystal Springs Reservoir which contained between 1,000 and 2,800 

plants, 2) the occurrence located 10 km (6 mi) to the south in the Triangle area which contained 

between 100 and 200 plants, and 3) the third occurrence in Edgewood Park which consisted of a 

single plant in 1987. The most recent data show that a newly discovered portion (Boat Ramp) of 

the Crystal Springs Reservoir occurrence, Element Occurrence 1, had 19,342 plants in December 

2009 (S. Foree, in. litt., January 12, 2010). Survey data collected from 2007 to 2009 estimate that 

the entire Crystal Springs occurrence consists of approximately 25,000 plants (Environmental 

Science Associates 2010). The Triangle area occurrence declined to 7 plants by 2000 (CNDDB, 

2010) and is no longer considered extant as of 2009 (S. Foree, San Francisco Water District, 

pers. comm., August 5, 2009). The single plant in Edgewood Park disappeared in 1996 

(CNDDB, 2010). 

Summary of Major Threats:

The San Francisco Public Utilities Commission (SFPUC) is proposing to implement a project 

which would modify the Lower Crystal Springs Dam resulting in restoration of the historical 

storage capacity of the reservoir. The March 2010 Draft Environmental Impact Statement states, 

that the increased water level would impact at least 0.30 acre of occupied fountain thistle habitat, 

supporting an undetermined number of plants. Because the subpopulations at the Reservoir 

represent at least 97 percent of all known fountain thistle plants, any loss of habitat at this site 

would be a significant loss to the species. Recent research on fountain thistle shows that two 

pollinators, Bombus vosnesenskii, a native bumblebee, and the honey bee, are extremely 

important to successful seed production. Other threats include nonnative plant species including 

pampas grass, seed predation by beetle larvae, road widening, fire, and dumping of household 

garden debris on the plants (USFWS, 2010). 
2013 VGP and sVGP BE Appendix F

F-115

F.6.15.

Cirsium hydrophilum var. hydrophilum

SUISUN THISTLE

Family: Ateraceae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q0FC)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?sourceTemplate=tabular_repor

t.wmt&loadTemplate=species_RptComprehensive.wmt&selectedReport=RptComprehen

sive.wmt&summaryView=tabular_report.wmt&elKey=161085&paging=home&save=tru

e&startIndex=1&nextStartIndex=1&reset=false&offPageSelectedElKey=161085&offPag

eSelectedElType=species&offPageYesNo=true&post_processes=&radiobutton=radiobutt

on&selectedIndexes=161085&selectedIndexes=153947)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc2400.pdf)

• 72 FR 18518 (http://www.gpo.gov/fdsys/pkg/FR-2007-04-12/pdf/07-1777.pdf#page=1)

Description:

Suisun thistle, Cirsium hydrophilum var. hydrophilum, is a perennial herb in the Asteraceae

(aster) family. It has slender, erect stems that are 3.0 to 4.5 feet tall and well branched. The upper 

leaves are deeply lobed and reduced to narrow strips with strongly spine-toothed margins. Pale 

lavender-rose flower heads appear between July and September.

Geographic Boundaries and Spatial Distribution:

Suisun thistle is only known from locations in Suisun Marsh, Solano County, California. Its 

distribution has been reduced to only four locations therein and its total range covers only 

7 square miles. 

Habitat: (has critical habitat)

Suisun thistle grows in the upper reaches of tidal marshes, with most known occurrences found 

in regularly flooded and permanently saturated habitats, along the banks of canals or ditches, 

within 50 to 100 feet of the high water mark of natural tidal channels; and on tidal floodplains 

within tidal marshes (U.S. Fish and Wildlife Service, 2007).

Approximately 2,052 ac of land was designated as critical habitat for the Suisun thistle in Solano 

County on May 14, 2007.

The PCEs for the Suisun thistle are: (1) persistent emergent, intertidal, estuarine wetland at or 

above the mean high-water line (as extended directly across any intersecting channels); (2) open 

channels that periodically contain moving water with ocean-derived salts in excess of 0.5 

percent; and (3) gaps in surrounding vegetation to allow for seed germination and growth.
2013 VGP and sVGP BE Appendix F

F-116

Life History:

Specific flower pollinators of Suisun thistle have not been directly studied; however field 

observations indicate that several bee species may be important in pollinating the species 

(LCLA, 2003). The most common insect species observed gathering pollen at Rush Ranch was 

the yellow-faced bumble bee (Bombus vosnesenskii) (LCLA, 2003). Flowering plants may 

produce hundreds of seed heads. Seed heads observed in July 2000 had three to five ripe seeds 

per head, but many of them contained aborted seeds or were found with insect larvae in active 

seed predation (Baye, 2000).

Information on short and long distance seed dispersal in Suisun thistle lacking. All new colonies 

detected in the last decade have been clustered around known populations in Suisun Marsh (B. 

Grewell pers. comm. 2000). The presence of numerous small, discrete colonies of Suisun thistle 

(LCLA, 2003) at Rush Ranch suggests that the subspecies may have relatively local breeding 

microhabitats resulting in limited seed dispersal. However, the height of the point of seed release 

has a large effect on dispersal distances of plumed seeds (Harper, 1977). The relatively tall 

stature of this subspecies, as compared to other associated tidal marsh plants, and flat topography 

of the surrounding marsh could potentially allow for long distance seed dispersal.

Historical Information:

At the time of listing, only two sites were known to have been occupied by Suisun thistle: 

Peytonia Slough Ecological Reserve and Rush Ranch, both in Suisun Marsh. Collectively, the 

occurrences of the subspecies totaled a few thousand individuals, occupying a total area of less 

than one acre (U.S. Fish and Wildlife Service, 1997). At the time of listing, no active 

management was occurring at either location.

Conservation Status:

Once fairly common in appropriate habitat throughout Suisun Marsh (Solano County), the 

subspecies' current distribution is restricted within Suisun Marsh to scattered colonies within 

relict undiked high tidal marshes (fully tidal, emergent estuarine marshes) at Peytonia Slough 

Ecological Reserve, Rush Ranch, upper Hill Slough, and the Joice Island portion of Grizzly 

Island Wildlife Area. Since the time of listing and in the absence of recent surveys, the species is 

thought to be present at the above two sites, plus upper Hill Slough and the Joice Island portion 

of Grizzly Island Wildlife Area, both in Suisun Marsh (CNDDB, 2006). The Joice Island 

location is near the eastern end of the Rush Ranch colonies and may be part of that same 

population. Potential habitat exists on private land directly adjacent to the four known locations 

on public land. The status of the species on private land is unknown.

Summary of Major Threats:

Much of its historic tidal wetland habitat has been converted to diked, managed, or muted 

(damped tide) tidal marshes. Extant populations are threatened by changes to natural tidal 

regimes, feral pigs (rooting and trampling), mosquito abatement activities, invasion by Lepidium 

latifolium (perennial pepperweed), plant-eating insects, and extirpation of small populations due 

to random events. The muting of tidal cycles and invasion of non-native Lepidium latifolium in 

Suisun thistle habitat are immediate, ongoing, widespread and significant threats which show no 

sign of being ameliorated in the near future. The significant ramifications of sea level rise due to 

global climate change could result in loss of populations and habitat in the future.
2013 VGP and sVGP BE Appendix F

F-117

F.6.16.

Cordylanthus mollis ssp. mollis

SOFT BIRD’S-BEAK

Family: Scrophulariaceae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q0GT)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?sourceTemplate=tabular_repor

t.wmt&loadTemplate=species_RptComprehensive.wmt&selectedReport=RptComprehen

sive.wmt&summaryView=tabular_report.wmt&elKey=153973&paging=home&save=tru

e&startIndex=1&nextStartIndex=1&reset=false&offPageSelectedElKey=152551&offPag

eSelectedElType=species&offPageYesNo=true&post_processes=&radiobutton=radiobutt

on&selectedIndexes=152551&selectedIndexes=153973)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc2397.pdf)

• 72 FR 18518 (http://www.gpo.gov/fdsys/pkg/FR-2007-04-12/pdf/07-1777.pdf#page=1)

Description:

Soft bird’s-beak, Cordylanthus mollis ssp. mollis, is a hemiparasitic annual herb in the 

Orobanchaceae (broomrape) family. It is 2.5-4 decimeter tall, with foliage that is grayish-green, 

often tinged red or purple. The inconspicuous white or pale yellow flowers, each subtended by 

bracts, are borne in a spike, usually 5-15 cm long. The herb blooms from July-September.

Geographic Boundaries and Spatial Distribution:

It grows in the coastal salt marshes and brackish marshes of San Pablo and Suisun Bays, in 

Solano, Contra Costa, Napa, Sonoma, Sacramento, Del Norte Sonoma, and Marin Counties, 

California. The species is currently restricted to widely scattered populations from Point Pinole 

and Fagan Slough marsh through the Carquinez Strait to Suisun Bay.

Habitat: (has critical habitat)

Soft bird’s-beak is found predominantly in the high marsh (upper reaches) of salt grasspickleweed marshes at or near the limits of tidal action (Stromberg and Villasenor, 1986). Most 

known soft bird’s-beak occurrences are found in regularly flooded and permanently saturated 

habitats within mixed halophytic plant communities, that is, communities where plants are 

adapted to live and reproduce in salt or brackish water (NWI, 2005). Tidal events are important 

for regulating tidal marsh plant communities and may be a critical factor in decreasing granivory 

and regulating the life cycle phases of the subspecies.

Approximately 2,276 ac of land was designated as critical habitat for the soft bird’s-beak in 

Solano, Contra Costa, and Napa Counties on May 14, 2007.

The PCEs for the soft bird’s-beak are: (1) persistent emergent, intertidal, estuarine wetland at or 

above the mean high-water line (as extended directly across any intersecting channels); (2) rarity 
2013 VGP and sVGP BE Appendix F

F-118

or absence of plants that naturally die in late spring (winter annuals); and (3) partially open 

spring canopy cover (approximately 790 nMol/m2/s) at ground level, with many small openings 

to facilitate seedling germination.

Life History:

As a hemiparasitic plant, seedling survival in soft bird’s-beak is critically dependent on 

establishing an early connection with a suitable host plant. Hemiparasites are parasitic plants that 

are capable of some photosynthesis, but receive crucial host subsidies of water, nitrogen, fixed 

carbon, and mineral compounds through underground organ connections to vascular tissues in 

host plant roots for water and soil nutrients (Ruygt, 1994; Grewell et al., 2003).

Soft bird’s-beak maintains at least a short-term persistent seed bank that can greatly influence 

population dynamics and persistence (Grewell, 2005). Seeds may disperse short distances from 

parent plants by tidal inundations or animals (Grewell et al., 2003), but successful long-distance 

dispersal by these or other means has not been documented. Grewell et al. (2003) observed bees 

determined to represent five genera and one bee-fly acting as potential pollinators on the flowers 

of soft bird’s-beak at the reintroduced population at Rush Ranch and a natural population at Hill 

Slough marsh. 

Historical Information:

Historically, soft bird’s-beak ranged from the Petaluma River near the City of Novato in Marin 

County, in the west, to the mouth of the Sacramento River in Sacramento County, in the east. At 

the time of listing, there were nine known occurrences of soft bird’s-beak, including Point 

Pinole, Rush Ranch, Joice Island, Fagan Slough, Hill Slough, CNWS, and McAvoy Boat Harbor, 

scattered throughout coastal salt or brackish tidal marshes fringing San Pablo and Suisun Bays, 

in Napa, Contra Costa, and Solano Counties (CNDDB, 1994).

Conservation Status:

In the final listing rule, it was reported that the number of individuals within the populations 

varied from 1 to 150,000 plants and that most sites varied between 1,000 and 6,000 plants 

(CNDDB, 1996). Individual populations fluctuate in size from year to year, as is typical of 

annual plants (U.S. Fish and Wildlife Service, 1997). While populations appear generally stable 

at the major population centers where status surveys have been recently conducted, at other 

populations centers no recent surveys have been conducted, making current population estimates 

difficult.

Although no recent comprehensive status surveys have been conducted, the latest information 

indicates that 11 extant populations of soft bird’s-beak are currently distributed within 50 percent 

of the historical range and that a large percentage of the remaining plants are in Solano County 

(Grewell et. al., 2003). Some areas within the remaining 50 percent of the historic habitat could 

presumably still support the species; however, many areas have been altered so that they are no 

longer suitable.

Summary of Major Threats:

Much of its original habitat has been lost or fragmented due to marsh alteration and 

development. Extant populations are threatened by muting (damping) of tides and salinity, 
2013 VGP and sVGP BE Appendix F

F-119

invasive non-native plants, seed predation, sea level rise predicted to result from global climate 

change, mosquito abatement, oil spills, and (for these small populations) random events.

Muting of tidal cycles, seed predation, and invasion of non-native competitor plants continue to 

threaten all the species occurrences to some degree. Inappropriate host plants in soft bird’s-beak 

habitat is likely the most significant threat to all occurrences of the species. 

F.6.17.

Cordylanthus palmatus or Chloropyron palmatum

PALMATE-BRACTED BIRD’S BEAK

Family: Scrophulariaceae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q1UT)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Cordylanthus+p

almatus)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc2628.pdf)

Description:

Palmate-bracted bird’s beak is an annual herb in the broomrape family (Orobanchaceae) 

(Olmstead et al., 2001). The plants are 4-12 inches tall and highly branched. The stems and 

leaves are grayish green and sometimes are covered with salt crystals excreted by glandular 

hairs. Small pale whitish flowers, up to 1-inch long, are arranged in dense clusters (spikes) and 

are densely surrounded by herbaceous leaf-like bracts. The petals are divided into two lips. The 

upper one is shaped like a bird's beak, leading to the common name of the genus. Seedlings grow 

in late March or April, while flowers bloom from late spring through summer.

Geographic Boundaries and Spatial Distribution:

The current range of the palmate-bracted bird’s beak is disjunct and occurs in the lowland areas 

of the Sacramento Valley, California. The species ranges from the northern Sacramento Valley 

south to the San Joaquin Valley with a large population in Alameda County at Springtown Alkali 

Sink.

Habitat: (no critical habitat)

Palmate-bracted bird’s beak grows on seasonally-flooded, saline-alkali soils in lowland plains 

and basins at elevations of less than 500 feet (Coats et al., 1993). More precisely, the species is 

restricted to seasonally-flooded, saline-alkali soils in lowland plains and basins at elevations of 

less than 155 meters (about 500 feet) (Showers, 1988; ESRP, 2006). Within these areas, the 

species grows primarily along the edges of channels and drainages, alkali scalds, and grassy 

areas. The suitability of microhabitats for the palmate-bracted bird’s beak depends primarily on 

soil pH and to a lesser extent on soil layering, salinity, and moisture (Service 1998).
2013 VGP and sVGP BE Appendix F

F-120

Life History:

Like other members of this family, palmate-bracted bird’s beak is partially parasitic on the roots 

of other plants (Chuang and Heckard, 1971). The palmate-bracted bird’s beak is a hemi-parasite 

(it manufactures its own food but obtains water and nutrients from the roots of other [host] plants 

(Endangered Species Recovery Program, 2007).

Historical Information:

At the time of listing, only two natural colonies and one transplanted population of the species 

were extant. In the final listing rule, there were 100 to 200 plants from Woodland, Yolo County; 

2,000 to 5,000 plants from lands near Livermore, Alameda County; and, 20 to 30 plants from the 

transplant site in the Mendota State Wildlife Area, Fresno County.

Conservation Status:

Population fluctuations are common in the palmate-bracted bird’s beak and may be a result of 

changes in pollination success, rainfall patterns, freshwater influence (e.g., hydrology patterns), 

and marsh pollution (e.g., herbicides for vegetation control and pesticides for mosquito control; 

Skinner and Pavlik, 1994; Endangered ESRP, 2007; Service, 2007c). In general, the populations 

of palmate-bracted bird’s beak are decreasing throughout the Central and Livermore Valleys in 

California. While translocations at Sacramento NWR may increase the population locally, the 

long-term status of those individuals is uncertain. Likewise, the discovery of additional locations 

reflects better survey techniques and likely not an increase in the spatial distribution of the 

species. As a result of intensive survey efforts and additional introductions, the species was 

determined to be present in 1998 at seven localities comprising about 1500 acres: Sacramento 

NWR in Glenn County, Delevan NWR in Colusa County, Colusa NWR in Colusa County, an 

area near the City of Woodland in Yolo County (Alkali Grasslands Preserve Management), 

Springtown Alkali Sink near the City of Livermore in Alameda County, Western Madera 

County, and Combined Alkali Sink Ecological Reserve-Mendota Wildlife Area in Fresno County 

(Service, 1998)

Summary of Major Threats:

When Cordylanthus palmatus was originally listed as endangered in 1986 (Service, 1986), the 

primary threat to its survival and recovery was habitat loss. Eight additional threats that further 

define or subdivide “habitat loss” have been identified since listing, including: urban expansion, 

changes in the hydrologic regime, random or catastrophic events (e.g., uncontrolled burns or 

unseasonable floods), road maintenance, unauthorized fill of wetlands, encroachment by exotic 

plants, off-road vehicle use, and livestock wallowing in seasonal ponds (Service, 1998). This 

species and its seasonally-flooded saline-alkaline soils are still threatened by at least four current 

or potential new threats: invasive nonnative plants, climate change, ozone, and excessive dust. 

F.6.18.

Dermochelys coriacea

LEATHERBACK SEA TURTLE

(See Seattle, Washington for information on this species)
2013 VGP and sVGP BE Appendix F

F-121

F.6.19.

Desmocerus californicus dimorphus

VALLEY ELDERBERRY LONGHORN BEETLE

Family: Cerambycidae

Threatened: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=I01L)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Desmocerus+cal

ifornicus+dimorphus)

• Univeristy of California, Berkeley, 2012 (http://essig.berkeley.edu/endins/desmocer.htm)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc779.pdf)

• Yolo Natural Heritage Program, 2012 

(http://www.yoloconservationplan.org/yolo_pdfs/speciesaccounts/invertebrates/valleyelderberry-longhorn-beetle.pdf)

• USFWS, 2012b (http://ecos.fws.gov/docs/federal_register/fr449.pdf)

Description:

The valley elderberry longhorn beetle (VELB) is a medium-sized (about 2 cm long) beetle. The 

“dimorphus” in its name refers to differences in appearance between the males and females. The 

forewings of the male are primarily red with dark green spots, whereas those of the female are 

dark metallic green with red margins.

Geographic Boundaries and Spatial Distribution:

The VELB is completely dependent on its host plant, the elderberry (Linsley and Chemsak,

1972, 1997; Eng, 1984; Barr, 1991; Collinge et al., 2001). In the Central Valley, California the 

elderberry tree is associated with riparian forests, which occur along rivers and streams. Recent 

surveys have revealed the beetle to persist only in scattered localities along the Sacramento, 

American, San Joaquin, Kings, Kaweah, and Tule rivers and their tributaries. The USFWS 

(1999) prepared a map of the presumed range of VELB, which encompasses the entire California 

Central Valley and the Sacramento River Delta below 900 m (2,953 ft) elevation. 

Habitat: (has critical habitat)

The elderberry shrub is a component of riparian forests throughout the Central Valley. Although 

this shrub occasionally occurs outside riparian areas, shrubs supporting the greatest beetle 

densities are located in areas where the shrubs are abundant and interspersed among dense 

riparian forest (Barr, 1991, USFWS, 1999, Collinge et al., 2001). Isolated elderberry shrubs 

separated from contiguous habitat by extensive development are not typically considered to 

provide viable habitat for VELB (USFWS, 1998, Collinge et al., 2001). VELB habitat is defined 

as stands of elderberry shrubs that are adjacent to, or contiguous with, riparian forest, 

floodplains, or relict elderberry savannah.
2013 VGP and sVGP BE Appendix F

F-122

Critical habitat was designated for the valley elderberry longhorn beetle on September 15, 1980 

for Sacramento County in the Sacramento Zone and the American River Parkway Zone.

Life History:

This beetle is associated with elderberry trees (Sambucus spp.) during its entire life cycle. The 

adults emerge in the spring from pupation inside the wood of these trees as they begin to bloom. 

The exit holes made by the emerging adults are distinctive, small oval openings. Often these 

holes are the only clue that the beetles occur in an area. The adults eat the elderberry foliage until 

about June when they mate. The females lay their eggs in crevices in the bark. Upon hatching, 

the larvae then begin to tunnel into the tree where they will spend 1-2 years eating the interior 

wood, their sole source of food.

Historical Information:

Historically the beetle ranged throughout the Central Valley, California. At the time of its listing 

in 1980, the beetle was known from less than 10 locations on the American River, Putah Creek, 

and the Merceed River (USFWS, 1980). The beetle currently inhabits the Central Valley from 

the southern Shasta County to Fresno County in the San Joaquin Valley (Barr, 1991).

Conservation Status:

Since the time of listing, surveys have identified approximately 190 locations of the beetle 

ranging from Shasta County to Fresno County. Significant programs specific to beetle protection 

have resulted in the protection of 50,000 acres of riparian habitat and the restoration of over 

5,100 acres of beetle habitat. Based upon the number of sightings throughout the Central Valley 

and the reduction of the primary threats to the species, it was recommended that the valley 

elderberry longhorn beetle be delisted in the 5-Year Review by the USFWS (Sept. 2006).

Summary of Major Threats:

The greatest current threat to VELB is from the invasive non-native Argentine ant (Linepithema 

humile) and European earwig (Forficula auricularia) (Talley et al., 2006). The non-native 

invasive Argentine ant has been observed attacking and killing VELB larvae. The ants enter the 

exit hole that the beetle makes prior to pupation and remove the larva (Huxel, 2000; Huxel et al.,

2003). Given that the invasion of riparian systems by Argentine ant in the Central Valley is 

continuing to spread, it is unclear how the invasion will impact VELB, but it appears that the 

Argentine ant may have caused the disappearance of some populations (Talley et al., 2006). The 

non-native invasive European earwig is also considered to be a threat to VELB through direct 

predation or by supporting higher populations of predators of insects (Talley et al., 2006), and 

earwig populations are also significantly larger in mitigation plantings and irrigated areas 

(Klasson et al., 2005). 

Non-native invasive plant species such as black locust, giant reed, red sesbania, Himalaya 

blackberry, tree of heaven, Spanish broom, Russian olive, edible fig, and Chinese tallowtree, 

may have significant indirect impacts on VELB by impacting elderberry shrub vigor and 

recruitment (Talley et al., 2006). It is also predicted that ripgut brome, foxtail barley and yellow 

starthistle may increase seedling mortality through competition for light and water or through 

increased fire return intervals (Talley et al., 2006). 
2013 VGP and sVGP BE Appendix F

F-123

F.6.20.

Elaphrus viridis

DELTA GREEN GROUND BEETLE

Family: Carabidae

Threatened: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=I01G)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Elaphrus+viridis

)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc2384.pdf)

Description:

The delta green ground beetle (Elaphrus viridis) is a member of the ground beetle family 

(Carabidae) in the order Coleoptera. The beetle is about 0.25 inch long and colored in brilliant 

metallic green and bronze with moderately large eyes. Elytra are oval and are broadest behind 

the middle. There are two color forms, one with solid green elytra, and the other spotted with 

three series of elevated highly polished spots, a sutural series of three, four median spots, and an 

outer series with two spots. 

Geographic Boundaries and Spatial Distribution:

Only known from the greater Jepsen Prairie area in south-central Solano County, California. The 

historical distribution is unknown, but data suggests that it may have inhabited a much larger 

range than it does presently (USFWS, 2005). It presently occupies less than 2,800 hectares 

(7,000 acres) (USFWS, 2007; USFWS, 2005).

Habitat: (no critical habitat)

Found along the margins of vernal pools within 1.5 meters of the water. Specifically the 

microhabitat seems to consist of areas where the sandy mud substrate slopes gently into the 

water, and where there is very low-growing vegetation providing 25-100% cover. Beetles have 

however been found hundreds of meters from vernal pools (Arnold, 1983).

Life History:

Males actively search through the vegetation for females who hide in the plant cover or run away 

from the males. Males chase the females when they see one moving nearby, and mounting 

occurs almost immediately upon contact. In all cases in which copulation was observed, the 

beetle on the top (male) was spotted and the one on the bottom (female) was solid green. 

These predators consume soft-bodied prey, with springtails forming the bulk of their diet. Pacific 

treefrogs could be the most serious predator. Although no predation events have been actually 

observed, these highly camouflaged frogs are found along the pool margins and are known to be 

ambush predators.
2013 VGP and sVGP BE Appendix F

F-124

Historical Information:

Proposed for federal listing on August 10, 1978, as a threatened species with critical habitat 

(USFWS, 1978) and listed as a threatened species with designated critical habitat on August 8, 

1980 (USFWS, 1980) and a recovery plan was approved in 1985 (USFWS, 1985). The beetle 

was known only from a single museum specimen until the species was rediscovered in the wild 

in 1974, at the Jepson Prairie in Solano County, California (USFWS, 2005). 

Conservation Status:

The 2005 Recovery Plan identified six known occurrences at that time. Unfortunately, the 

population sizes and trends of the beetle populations are not currently known, owing to the 

difficulty in visually locating these beetles during surveys and the lack of continuous and 

consistent monitoring. Currently about 11,047 acres of beetle habitat are protected, or about 54 

percent of the suitable habitat known to be available. Not only has a substantial portion of the 

Wilcox Ranch, which is inhabited by populations of the beetle, been secured, but also several 

conservation banks for mitigation involving vernal pool species were opened. 

Summary of Major Threats:

The primary threat is the conversion of the grassland vernal pool matrix to agriculture and the 

subsequent plowing that accompanies this conversion. This represents a permanent loss of 

habitat. Much of the original habitat has already been destroyed in this manner. Expansion of 

housing subdivisions existing near actual and/or potential sites would mean permanent loss of 

habitat. Cattle, sheep and horse grazing are less destructive than conversion to agriculture or 

subdivisions because it is reversible. Of these, cattle present the greatest threat because they are 

so heavy that their feet sink into the soft wet mud, creating a pock-marked topography that is 

difficult for the beetles to negotiate. This damage is compounded because cattle spend a lot of 

time near or even in vernal pools. Another threat to beetle survival are Coleoptera collectors 

who pose a potentially serious threat. It was no accident that the locality for the species was 

unknown from 1878 until 1974, as the original collector probably did not want other beetle 

collectors to know where to find the species. It is suggested that the precise locations in which 

this species is found should not be revealed to the general public or even educational institutions.

F.6.21.

Enhydra lutris nereis

SOUTHERN SEA OTTER

Family: Mustelidae

Threatened: wherever found, except where experimental population

Experimental Population, Non-Essentail: all areas subject to U.S. jurisdiction south of Point 

Conception, CA (34029.9’ N. Lat.)

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=A0A7)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Enhydra+lutris+

nereis)

• USFWS, 2012b (http://ecos.fws.gov/docs/recovery_plan/030403.pdf)
2013 VGP and sVGP BE Appendix F

F-125

Description:

The sea otter is the largest member of the family Mustelidae and the smallest species of marine 

mammal in North America. Body size varies among populations. Adult sea otters average about 

30 kilograms (65 pounds) for males and 20 kilograms (45 pounds) for females; average lengths 

are about 135 centimeters (4.5 feet) and 125 centimeters (4 feet) for males and females, 

respectively. Forepaws are padded, have claws, and are used in feeding and grooming. Hind 

limbs are posteriorly oriented and flipper-like for swimming. The tail is less than one-third the 

body length and of uniform thickness from base to tip. 

Geographic Boundaries and Spatial Distribution:

The southern sea otter’s distribution is about 100-8,000 sure miles off the California coast, 

mainly from Santa Cruz to Pismo Beach. It was recently reintroduced to San Nicolas Island. 

Habitat: (no critical habitat)

Sea otters occupy hard- and soft-sediment marine habitats from the littoral zone to depths of less 

than 100 meters (330 feet), including protected bays and exposed outer coasts. Most individuals 

occur between shore and the 20-meter (65-foot) depth contour. As one of the few marine 

representatives of the order Carnivora, the sea otter evolved to inhabit a narrow ecological zone, 

adapting to the nearshore ecosystem and preferring rocky shoreline with kelp beds.

Life History:

Sea otters eat numerous species of invertebrates and, in some areas, fish. By comparing 

neighboring long-established and recently-established populations from several locations in the 

North Pacific Ocean, Estes et al. (1981) concluded that dietary diversity increased with increased 

population density and the presumed increase in competition for food.

Long-term records from marked individuals have established that most adult female sea otters 

give birth to a single pup each year (Siniff and Ralls, 1991, Jameson and Johnson, 1993). The 

collective data, which are not necessarily representative for the entire population, indicate that 

the average birth rate of adult females is about 0.90 per year, or perhaps somewhat higher 

(Riedman et al., 1994; Monson et al., 2000). In contrast with most carnivores and all other lutrine 

(otter) species, but consistent with other marine mammals, except the polar bear, litter size is 

typically one (Estes, 1989). Twin births occur rarely, and seldom, if ever, do both young survive 

to weaning (Jameson and Bodkin, 1986). Records from tagged animals also have suggested that 

females typically attain sexual maturity after 3 years, but that weaning success by primiparous 

females (females with their first litters) is relatively low (Riedman et al., 1994, Monson et al.,

2000). The age of sexual maturity in males is less well known but appears to be about 5 years. 

However, the age at which males actually first successfully breed may be somewhat less than or 

considerably longer than 5 years, depending on population status and social context. 

In California, most births occur from late February to early April. The seasonality is not highly 

synchronous, in that births may occur throughout the year, and the birth peak may extend over 

several months (Siniff and Ralls, 1991). The birth peak is seasonally asynchronous in some parts 

of central California (Riedman et al., 1994). 
2013 VGP and sVGP BE Appendix F

F-126

Historical Information:

The southern sea otter population was exploited to near extinction from an estimated historical 

population (in California) of approximately 16,000 animals (Laidre et al., 2001). Since the early 

1970s, population counts have ranged between 1,250 and 2,300 animals. Population counts 

declined from the mid-1970s to the early 1980s, then increased from the mid-1980s to the mid 

1990s. The historical range of the species southeastward from Prince William Sound to central 

Baja California remains uninhabited except for translocated colonies in southeast Alaska, British 

Columbia, and Washington, the remnant population in central California, and the translocated 

colony at San Nicolas Island.

Conservation Status:

The southern sea otter population presently contains about 2,150 animals and ranges between 

Half Moon Bay and Point Conception along the coast of central and southern California. Rangewide population counts declined at a rate of approximately 5 percent per year between 1995 and 

1999, although this declining trend has been less certain in recent years. The translocated colony 

at San Nicolas Island contains about 27 individuals, including pups. Although more than 70 

births are known to have occurred at San Nicolas Island from 1987 to 2002, the population size 

has remained small and its future prospects are uncertain. 

Summary of Major Threats:

The main threats to the southern sea otter are habitat degradation (including oil spills and other 

environmental contaminants) and human take (including shooting, entanglement in fishing gear, 

and harassment). Oil spills, which could occur at any time, could decimate the sea otter 

population. The reasons for the recent decline in abundance are unknown, but it may be in part 

related to one or more of the following factors, infectious disease resulting from increased 

immune deficiencies or elevated parasite and pathogen exposure, incidental mortality caused by 

commercial fishing activities and food resource limitation. 

F.6.22.

Eucyclogobius newberryi

TIDEWATER GOBY

Family: Gobiidae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=E071)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Eucyclogobius+

newberryi)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc1144.pdf)

Description:

The tidewater goby is a two-inch long nearly translucent benthic fish with large fins, a ventral 

sucker, and a large mouth. It is a has 6-7 slender spines in the first dorsal fin, 9-13 rays in the 
2013 VGP and sVGP BE Appendix F

F-127

second, 9-12 rays in the anal fin, and 8-10 gill rakers. It is dorsum dark olive with dark mottling 

and its dorsal fins are mottled, pelvic fins yellow or dusky, and anal fin dusky (Moyle, 1976;

Eschmeyer et al., 1983).

Geographic Boundaries and Spatial Distribution:

It has a discontinuous distribution along the coast of California that is characterized by small 

isolated populations with about 85 extant populations. Recent surveys indicate that the species is 

not as scarce or threatened as previously believed, except in Orange and San Diego counties, 

where the species continues to be regarded as endangered.

Habitat: (no critical habitat)

The lagoons, estuaries, backwater marshes, and freshwater tributaries that tidewater gobies 

occupy are dynamic environments that are subject to considerable fluctuations on a seasonal and 

annual basis. A lagoon cycle that creates the fluctuating environment for lagoon-inhabiting 

species can be generalized as follows. Late spring and summer beach development builds a full 

or partial sandbar across a stream mouth, thereby producing a summer lagoon. In wetter years, 

the extensive loss of beach sand through high stream discharge (lagoon inflows) results in later 

development of the bar; in some wet years, high summer discharge results in periodic overtopping and breaching of the sandbars of some lagoons. In drier years, sandbar formation is 

usually earlier, but may be delayed at some stream mouths due to a scarcity of tidal sand. After 

sandbar formation, freshwater inflows raise lagoon levels and greatly increase lagoon size and 

habitat variety (especially by flooding vegetation adjacent to lagoons). Inflows also convert the 

lagoon towards fresh water, with the surface freshwater layer thickening and the heavier, bottom 

saltwater layer percolating through the bar. Larger lagoons, or lagoons with substantial amounts 

of salt water present at the time of sandbar formation, require more inflow and/or a longer time 

to convert to fresh water. Lagoons that are fully converted to fresh water are generally relatively 

cool and well-mixed. Brackish lagoons, with insufficient inflows after sandbar formation, remain 

stratified unless mixed by strong winds; water temperatures are generally high and dissolved 

oxygen levels often low in the bottom saltwater layer. 

Its habitat includes small coastal lagoons, lower reaches of streams and the uppermost portions 

of large bays. It is most abundant in the upper ends of lagoons created by small coastal streams 

(Swift, in Moyle 1976). In lower sections of coastal streams, it occurs in fresh to brackish water 

(preferably less than 10 ppt salinity). It also inhabits vegetated pools of slow (but not stagnant) 

areas of streams. There is documentation of its occurrence in ponded freshwater habitats as far as 

8 km upstream from San Antonio lagoon in Santa Barbara County. Generally occurs in water 25-

100 cm deep. The tidewater goby is able to complete life cycle in fresh or brackish water. Prefers 

mud substrates and areas of high dissolved oxygen. It spawns on substrate of coarse sand, in 

burrows dug by male usually in water 25-50 cm deep (Swift et al., 1989). Larvae are found 

midwater around vegetation until they become benthic (Swift et al., 1989).

Life History:

In southern California, it spawns throughout much of the year, with an April-June peak at water 

temperatures (Lee et al., 1980; 18-22 C according to Moyle et al., 1989). In San Francisco Bay 

area streams, spawning peaks from late August through November. In Santa Barbara County, 

spawning peaks in fall, with most recruitment in winter. Low temperatures and disruptions of 
2013 VGP and sVGP BE Appendix F

F-128

lagoons during storms generally restrict spawning to non-winter months, though spawning as 

early as early January has been recorded. Apparently an annual species, though some in the north 

may live up to three years (Moyle et al., 1989). Male guards the eggs with larvae emerging in 9-

10 days. Tidewater goby are benthic feeders on small crustaceans (mysids, ostracods, 

amphipods), insects (chironomid larvae, diptera larvae), and molluscs.

Historical Information:

The species is historically widespread in brackish coastal lagoons and coastal creeks in 

California from the mouth of the Smith River, Del Norte County, south to Agua Hedionda 

Lagoon, San Diego County (Lee et al., 1980, USFWS, 1999). It is naturally absent (due to lack 

of suitable habitat) between Humboldt Bay and Ten Mile River, between Point Arena and 

Salmon Creek, and between Monterey Bay and Arroyo del Oso. Historically there were about 

110 populations; current number of extant populations is believed to be about 85 (USFWS,

1999). In Orange and San Diego counties, California, known from six localities (USFWS, 1999).

Conservation Status:

Recent surveys indicate that the species has disappeared from less than 25% of the historical 

range (USFWS, 1999). Of the 25 population considered to be permanently extirpated, 19 were 

extirpated prior to 1970, before regulations protecting the environment were promulgated 

(USFWS, 1999). It is difficult to determine the status of the species throughout its range 

however, based on the more than doubling of the number of occupied localities since it was 

listed (from 48 localities to 106), the species appears to be more resilient to perturbations and 

climatic factors (particularly, drought) than previously believed. Under natural conditions, 

tidewater goby populations are highly dynamic. Tidewater gobies will periodically be extirpated 

or reach such low numbers that they cannot be detected at some localities. This is a natural 

occurrence within many species exhibiting a metapopulation dynamic including the tidewater 

goby. The rate of loss is expected to be higher during drought conditions. During wetter periods, 

these localities will again be occupied assuming that suitable habitat still exists. 

Summary of Major Threats:

Coastal lagoons have been degraded by and are highly susceptible to degradation through 

diversion of water (dewaters stream habitat, affects marsh habitats, and alters temperature and 

salinity), dredging, pollution from agricultural and sewage effluents, siltation (e.g., resulting 

from cattle overgrazing and feral pig activity), urban development of surrounding lands, and 

coastal road construction (interfers with marsh-ocean water flow, results in altered temperatures 

and salinity). Tidewater gobies are sensitive to this degradation and so are good indicators of 

ecosystem health. These impacts are exacerbated by drought. Introduced predatory fishes, 

especially centrarchids and channel catfish, have reduced or eliminated goby populations in 

some areas. Crayfish and mosquitofish may threaten populations through direct predation on 

eggs, larvae, and adults. Introduced gobies (e.g., yellowfin) are a potential threat (through 

competition and predation). Introduced clawed frogs prey on gobies in the Santa Clara River, 

California (Lafferty and Page, 1997). Populations in large habitats that are close to other 

occupied habitats are most likely to persist, but habitat alteration and introduced species may 

eliminate the species from even large habitats (Lafferty et al., 1999). People walking through 

mudflats at low tide can also easily trample them. 
2013 VGP and sVGP BE Appendix F

F-129

F.6.23.

Eumetopias jubatus

STELLER SEA-LION

(See Seattle, Washington for information on this species)

F.6.24.

Haliotis sorenseni

WHITE ABALONE

Family: Haliotididae

Endangered: West Coast from Point Conception, CA to Punta Abreojos, Baja California, Mexico

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=G0C8)

• USFWS, 2012b (http://ecos.fws.gov/docs/recovery_plan/whiteabalone.pdf)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Haliotis+sorense

ni)

Description:

Abalone are prosobranch marine gastropods, in the phylum Mollusca, that first appeared in the 

fossil record about 100 million years ago. White abalone are deep-sea mollusk that reaches a 

length of 150 to 200 mm (25 cm) with a shell that is thin and light, oval and highly arched. There 

are three to five open respiratory pores that are highly elevated above the shell’s surface. 

Typically, the shell’s interior is a pearly white and contains a poorly differentiated or absent 

muscle scar (Cox, 1962). The epipodium is a mottled yellowish green and beige color, with 

foliose epipodial papillae edged in orange, and brown cephalic tentacles (Cox 1962, Leighton,

1972). 

Geographic Boundaries and Spatial Distribution:

Since the mid-1990s, extremely low numbers of isolated survivors have been identified along the 

mainland coast in Santa Barbara County and at some of the offshore islands and banks in the 

middle portion of the range, indicating the current range of white abalone in California may be 

similar to what it was historically (see below). No recent information on current range is 

available for Baja California. 

Habitat: (no critical habitat)

Adult white abalones occur in open, low relief rocky reefs or boulder habitat surrounded by sand 

(Hobday and Tegner, 2000). Suitable habitat is patchy, thus, the distribution of white abalone is 

also patchy. Adult white abalone may be found between 5-60 m depths, (Cox, 1960), but current 

remnant populations are most common between 30-60 m depth. A recent survey by Butler et al. 

(2006), found the highest densities of white abalone at 40-50 m depth. Factors controlling the 

depth distribution of white abalone are poorly known. Tutschulte (1976) speculated that white 

abalone may have been restricted to deeper waters (> 25 m) as a result of sea otter predation or 

competition from pink abalone. Human fishing activities may have also contributed to this 

deeper depth distribution.
2013 VGP and sVGP BE Appendix F

F-130

Whether the same habitat is used, or preferred, by both adult and juvenile white abalone, is 

unknown. There is some evidence that abalone may shift their depth distribution as they age. For 

example, studies in Australia suggest that H. roei juveniles (3-4 m depth) and adults (deeper 

depths) occupy physically different, and distant, habitat (Wells and Keesing 1990). In California, 

H. fulgens may move into deeper water with increasing age (Leighton pers. comm.). 

Life History:

White abalone are dioecious, with separate sexes occurring in approximately a 1:1 ratio, and 

exhibit broadcast spawning (i.e. directly releasing gametes into the water column for external 

fertilization). Factors known to affect fecundity in abalone include organism size and food 

availability. For those species that have been examined, fecundity has been shown to increase 

linearly with increasing body size (Tutschulte 1976, Clavier 1992). Adult abalones of 

intermediate sizes are capable of spawning over two million viable eggs, indicating high 

reproductive potential (Leighton, 2000). Fecundity has been shown to decrease in several species 

of abalone (H. laevigata and in H. fulgens) when food is limited (Tegner and Dayton, 1987, 

Shepherd and Breen 1992), and nutrition is essential for the production of fully viable gametes. 

Historical Information:

The historic range of white abalone extended from Point Conception, California, U.S.A. to Punta 

Abreojos, Baja California, Mexico (Bartsch 1940, Cox 1960, 1962). In the northern part of the 

California range, white abalone were reported as being more common along the mainland coast. 

In the middle portion of the California range, they were noted to occur more frequently at the 

offshore islands (especially San Clemente and Santa Catalina Islands)(Cox 1962, Leighton 

1972). At the southern end of the range in Baja California, Mexico, white abalone were reported 

to occur more commonly along the mainland coast, but were also found at a number of islands 

including Isla Cedros and Isla Natividad (Guzman del Proo, 1992, Shepherd et al., 1998). It 

remains unknown whether this distribution pattern resulted because of lack of suitable habitat 

along the mainland coast in the middle portion of the range, or to overfishing in these more 

accessible mainland regions (Hobday and Tegner, 2000). 

Conservation Status:

Estimates of the total population size of white abalone past and present have been difficult to 

calculate because most data are based on emergent (adult) individuals only. Cryptic (juvenile) 

white abalone has seldom been observed in nature, even prior to exploitation by the fishery. In 

addition to body size limitations, there is evidence from other abalone species that factors such as 

presence of predators and abundance of food may mediate cryptic behavior. The paucity of 

abundance data for cryptic animals prevents establishing links between the numbers of early and 

later life stages and thus, the reconstruction of recruitment histories for white abalone 

populations has not been possible. As a result, a poor understanding of population dynamics 

exists for white abalone. Given the limitations of fishery-independent and dependent data, only 

adult population abundance and density can be evaluated for changes through time and space. 

Summary of Major Threats:

Subjected to intense commercial and recreational exploitation from 1969-1977. Its continued 

survival is threatened by poor reproductive success due to size and fragmentation of existing 
2013 VGP and sVGP BE Appendix F

F-131

populations. This species is also highly susceptible to withering syndrome, a rickettsial disease 

of abalone (Friedman et al., 2007).

F.6.25.

Hypomesus transpacificus

DELTA SMELT

Family: Laridae

Threatened: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=E070)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Hypomesus+tran

spacificus)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc3570.pdf)

• USFWS, 2012b (http://ecos.fws.gov/docs/federal_register/fr2751.pdf)

Description:

Delta smelt are slender-bodied fish, generally about 60 to 70 mm (2 to 3 in.) long, although they 

may reach lengths of up to 120 mm (4.7 in) (Moyle, 2002). Delta smelt are in the Osmeridae 

family (smelts) (Stanley et al., 1995). Live fish are nearly translucent and have a steely blue 

sheen to their sides (Moyle, 2002). Delta smelt usually aggregate into loose schools, but their 

discontinuous stroke-and-glide swimming behavior likely makes schooling difficult (Moyle,

2002).

Geographic Boundaries and Spatial Distribution:

Delta smelt are endemic to the upper San Francisco Estuary in California, principally the upper 

Sacramento-San Joaquin Delta (primarily below Isleton in the Sacramento River, and below 

Mossdale in the San Joaquin River) and Suisun Bay (California Department of Fish and Game 

1990; Moyle, 2002). The species congregates in upper Suisun Bay and occurs in small numbers 

in larger sloughs of Suisun Marsh when river outflows are high (mainly March to mid-June). In 

1994-1998, delta smelt were found mainly in Suisun Bay (Moyle et al., 1989; Moyle, 2002). 

During periods of drought, the center of abundance has been in the northwestern Delta in the 

channel of the Sacramento River, and the species is then rare in Suisun Bay (Moyle et al., 1989; 

Moyle, 2002). During years with average or high outflow, smelt may concentrate prior to 

spawning movements anywhere from the Sacramento River near Decker Island to Suisun Bay 

(Moyle 2002). Spawning occurs in the sloughs and channels of the upper Delta (e.g., Barker, 

Lindsey, Cache, Georgiana, Prospect, Beaver, Hog, and Sycamore sloughs) and in the 

Sacramento River above Rio Vista (Moyle, 2002). In some years spawning also occurs north of 

Suisun Bay in Montezuma and Suisun sloughs and their tributaries or in the Napa River estuary 

(Federal Register, 6 January 1994; Moyle, 2002). 
2013 VGP and sVGP BE Appendix F

F-132

Habitat: (has critical habitat)

Studies indicate that delta smelt require specific environmental conditions (freshwater flow, 

water quality) and habitat types (shallow open waters) within the estuary for migration, 

spawning, egg incubation, rearing, and larval and juvenile transport from spawning to rearing 

habitats (Moyle, 2002). Delta smelt are a euryhaline (tolerate a wide range of salinities) species; 

however, they rarely occur in water with more than 10-12 parts per thousand salinity (about one 

third seawater). Delta smelt tolerate temperatures ranging from 7.5-25.4 ̊C in the laboratory 

(Swanson et al., 2000), but may be found in warmer waters in the Delta. Feyrer at al. (2007) 

found that relative abundance of delta smelt was related to fall salinity and turbidity (water 

clarity). Delta smelt probably evolved within the naturally turbid (silt and particulate-laden) 

environment of the Delta and likely rely on certain levels of background turbidity at different life 

stages and for certain behaviors. Laboratory studies found that delta smelt larval feeding 

increased with increased turbidity (Baskerville-Bridges et al. 2004). Although spawning has not 

been observed in the wild, spawning location and timing has been inferred from the collection of 

larvae in sloughs and shallow edge-waters of channels in the upper Delta and in Montezuma 

Slough near Suisin Bay (Wang, 1991).

Critical habitat for this species was published on January 6, 1994, following information by the 

California Department of Fish and Game and UC Davis that delta smelt spawned in the 

Sacramento River, as far as the City of Sacramento and tidally influenced shallow freshwater 

sloughs. The critical habitat also included the Suisun Slough, as far

upstream as Suisun City (Lesa Meng, pers. comm., 1993).

The primary constituent elements for the delta smelt are: (1) shallow, fresh or slightly brackish 

backwater sloughs and edgewaters and substrates for egg attachment for spawning; (2) rivers and 

channels free from physical disturbance and flow disruption; (3) 2 ppt isohaline, shallow, 

protective, food-rich waters for larvae and juveniles to mature; (4) adequate flow and water 

quality to attract migrating adults to the Sacramento and San Joaquin Rivers and tributaries.

Life History:

Spawning is believed to occur from late January through late June or early July at water 

temperatures ranging from 7-15 ̊C (Moyle, 2002). In the laboratory, spawning has been observed 

to occur between 12-22 ̊C (Bennett, 2005, p. 13). In laboratory conditions, eggs typically hatch 

after 9 to 14 days and larvae begin feeding 5 to 6 days later (Mager et al., 2004). Larvae are 

generally most abundant in the Delta from mid-April through May (Bennett, 2005, p. 13). After 

several weeks of development, larval surveys indicate that larvae move downstream until they 

reach nursery habitat in the low salinity zone (LSZ) where the salinity ranges from 

approximately 2 to 7 ppt (Moyle, 2002). Juvenile smelt rear and grow in the LSZ for several 

months, preferring relatively shallow open water (Dege and Brown, 2004). In September or 

October, delta smelt reach adulthood and begin a gradual migration back into freshwater areas 

where spawning is thought to occur. Most delta smelt die after spawning, but a small contingent 

of adults survives and can spawn in their second year (Moyle, 2002).

Delta smelt feed primarily on small planktonic (free-floating) crustaceans, and occasionally on 

insect larvae (Moyle 2002). Historically, the main prey of delta smelt was the copepod 

(Eurytemora affinis) and the mysid shrimp (Neomysis mercedis). The slightly larger copepod 
2013 VGP and sVGP BE Appendix F

F-133

(Pseudodiaptomus forbesi) has replaced E. affinis as a major prey source of delta smelt since its 

introduction into the San Francisco Bay–Delta. Two other copepod species (Limnoithona 

tetraspina and Acartiella sinenisi) have become abundant since their introduction to the San 

Francisco Bay-Delta in the mid-1990s. Delta smelt eat these introduced copepods, but P. forbesi

remains a dominant prey item (Baxter et al., 2008). The diets of larval delta smelt are limited to 

larval copepods (Nobriga, 2002). As mentioned previously, delta smelt are thought to require a 

turbid environment for efficient, successful foraging.

Historical Information:

Historically, this was the most abundant pelagic fish in the upper Sacramento-San Joaquin 

estuary (Erikkila et al., 1950), and it remained abundant in California Department of Fish and 

Game trawl surveys in the Delta during the early 1970s (Stevens and Miller, 1983; Moyle et al.,

1989; Stevens et al., 1990). Their historical range is thought to have extended from San Pablo 

Bay upstream to at least the city of Sacramento on the Sacramento River and the city of 

Mossdale on the San Joaquin River. 

Conservation Status:

Population estimates are not possible to obtain for this species (Herbold, 1996). A relative 

abundance index has been developed using various net surveys as well as counts of individuals 

entrained by (drawn into) Federal and State water export facilities (Bennett, 2005), and 

population assessments have been based on abundance index trends. Based on those indices, 

significant changes in delta smelt abundance occurred in 1975-76, 1980-81, and 1998-99 (Manly 

and Chotkowski, 2006). The 1980-1981 abundance index decline was one of the factors that 

resulted in listing delta smelt as a threatened species in 1993 (58 FR 12854; Moyle, 2002; 

CDFG, 2008). From 1991 to 2001, abundance index trends fluctuated wildly. In 2002, delta 

smelt and three other pelagic Delta fishes seemed to decline significantly, with delta smelt 

abundance indices trending to record lows from 2002 through 2008 (Armor et al., 2005; CDFG,

2008). In March of 2004, we completed a 5 year review of the species that recommended against 

changing the listing status of the delta smelt. At that time there was no indication that the 

decreasing trend of 2002 was outside of the range of expected variability, similar to those in 

1992, 1994, and 1996. However, the delta smelt index continues a decreasing trend and is now 

estimated at the lowest level ever measured-roughly one and a half percent of the 1980 index 

level (CDFG, 2008). USFWS (2004) concluded that although there has been a general increase 

in numbers since the low point during a long period of drought in the 1980s and early 1990s, 

delta smelt abundance has not recovered to its pre-decline (prior to 1982) levels and that the 

overall trend is negative.

Summary of Major Threats:

The decline may be attributable to the delta smelt's low fecundity and one-year lifespan, in 

combination with changes and fluctuations in the estuarine ecosystem. These changes and 

fluctuations are mostly human induced threats which include: reduction in outflows (water 

projects have allowed the intrusion of higher salinity water into the Delta, restricting the smelt's 

spawning and nursery areas to less favorable river channel habitat and making them more 

vulnerable to diversion in massive water project pumping plants); entrainment losses of larvae 

and adults to water diversion, high outflows during years with unusually high rainfall (flush 

smelt and their food resources out of the system; may make it easier for exotic species of 
2013 VGP and sVGP BE Appendix F

F-134

copepods, clams and fishes to colonize); and changes in food resources (e.g., increased 

abundance of various species of exotic copepods, which could deplete smelt food resources 

and/or be more difficult for smelt to capture; the introduced Asiatic clam now abundant in 

Suisun Bay, may reduce availability of zooplankton to smelt larvae; the diatom (Melosira), 

which is difficult for zooplankton to consume, sometimes becomes very abundant in the Delta 

(Moyle et al., 1989; Moyle, 2002; USFWS, 1993, 1996). Another threat is the hybridization of 

the species (e.g., introduced H. nipponensis represents a potential threat through hybridization 

and/or competition; hybrids may be sterile but interbreeding may result in loss of delta smelt 

gametes).

F.6.26.

Lepidochelys olivacea

OLIVE RIDLEY SEA TURTLE

Family: Cheloniidae

Endangered: Breeding colony populations on Pacific coast of Mexico

Threatened: wherever found, except where listed as endangered

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=C00V)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Lepidochelys+ol

ivacea)

• NOAA Fisheries, 2012 (http://www.nmfs.noaa.gov/pr/species/turtles/oliveridley.htm)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc1077.pdf)

Description:

The olive ridley gets its name from the olive coloration of its heart-shaped top shell (carapace). 

Adult turtles are relatively small (22-31 in). The size and morphology of the olive ridley varies 

from region to region, with the largest animals being observed on the Pacific coast of Mexico. 

There are often only five pairs of costal "scutes" on the carapace, but that number varies. Some 

individuals have been documented having as many as nine pairs of costal scutes. Each of the four 

flippers has one or two visible claws. The carapace of eastern Pacific olive ridleys is greater in 

height than other populations. Western Atlantic olive ridleys usually have a darker coloration 

than eastern Pacific olive ridleys.

Geographic Boundaries and Spatial Distribution:

Olive ridleys are globally distributed in the tropical regions of the South Atlantic, Pacific, and 

Indian Oceans. In the South Atlantic Ocean, they are found along the Atlantic coasts of West 

Africa and South America. In the Eastern Pacific, they occur from Southern California to 

Northern Chile.

Olive ridleys often migrate great distances between feeding and breeding grounds. In two 

separate satellite telemetry studies, both male and female olive ridleys leaving the breeding and 

nesting grounds off the Pacific coast of Costa Rica migrated out to the deep waters of the Pacific 

Ocean. Both sexes migrated to waters deeper than 9800 ft (3000 m). The results did not indicate 
2013 VGP and sVGP BE Appendix F

F-135

a directed migration to a specific foraging area, instead it appears the olive ridley forages 

opportunistically in deep ocean waters (Plotkin et al., 1994).

Arribadas occur on a few beaches worldwide in the eastern Pacific and northern Indian oceans.

In the eastern Pacific, arribadas occur from June through December on certain beaches on the 

coasts of Mexico, Nicaragua, and Costa Rica and on a single beach in Panama. In the northern 

Indian Ocean, arribadas occur on three different beaches along the coast of India. Solitary 

nesting occurs extensively throughout this species' range; nesting has been documented in 

approximately 40 countries worldwide.

Habitat: (no critical habitat)

Habitat includes tropical and subtropical waters, ranging from protected, shallow, marine and 

estuarine waters, including bays and lagoons, to offshore areas well beyond the continental shelf 

(NMFS and USFWS, 2007). Nesting occurs on upper beaches. Individuals sometimes change to 

a different nesting beach within a single nesting season (see Eckert et al., 1989).

The olive ridley is mainly a pelagic sea turtle. Olive ridleys mostly breed annually and have an 

annual migration from pelagic foraging, to coastal breeding and nesting grounds, back to pelagic 

foraging. Trans-Pacific ships have observed olive ridleys over 2,400 miles (4,000 km) from 

shore.

Life History:

The olive ridley has one of the most extraordinary nesting habits in the natural world. Large 

groups of turtles gather off shore of nesting beaches. Then, all at once, vast numbers of turtles 

come ashore and nest in what is known as an "arribada". During these arribadas, hundreds to 

thousands of females come ashore to lay their eggs. At many nesting beaches, the nesting density 

is so high that previously laid egg clutches are dug up by other females excavating the nest to lay 

their own eggs.

There are many theories on what triggers an arribada, including offshore winds, lunar cycles, and 

the release of pheromones by females. Despite these theories, scientists have yet to determine the 

actual cues for ridley arribadas. Not all females nest during an arribada, instead some are solitary 

nesters. Some olive ridleys employ a mixed nesting strategy. For example, a single female might 

nest during an arribada, as well as nest alone during the same nesting season. Arribada nesting is 

a behavior found only in the genus Lepidochelys. Although other turtles have been documented 

nesting in groups, no other turtles (marine or otherwise) have been observed nesting in such mass 

numbers and synchrony.

Olive ridleys reach sexual maturity around 15 years, a young age compared to some other sea 

turtle species. Females nest every year, once or twice a season, laying clutches of approximately 

100 eggs. Incubation takes 50-60 days. The olive ridley is omnivorous, meaning it feeds on a 

wide variety of food items, including algae, lobster, crabs, tunicates, mollusks, shrimp, and fish. 

Olive ridleys dive to depths of about 500 feet (150 m), to forage on benthic invertebrates.
2013 VGP and sVGP BE Appendix F

F-136

Historical Information:

The olive ridley turtle was listed under the ESA on July 28, 1978. The breeding populations in 

the Pacific coast of Mexico are listed as endangered; elsewhere the species is listed as threatened.

Since 1967, there has been an 80% reduction in certain nesting populations in the western 

Atlantic Ocean (Surinam, French Guiana, and Guyana) (USFWS, 2005). In the Eastern Atlantic 

Ocean, lack of data and trends on specific nesting beaches make it difficult to estimate nesting 

populations. Along the entire west coast of Africa, nesting females and eggs are regularly taken 

for consumption, except where research stations have been established. This impact is likely 

extremely devastating to the entire Eastern Atlantic population (Plotkin ed., 2007).

Prior to 1950, an estimated ten million olive ridleys nested on the Pacific coast of Mexico. In the 

mid-1960s, an olive ridley fishery developed in Mexico and Ecuador, and the taking of eggs and 

females also increased, which devastated the population. Over 20 nesting populations have been 

severely depleted since the 1960s and only a single arribada nesting beach remains in La 

Escobilla, Mexico. The other nesting populations from 40 years ago have yet to recover despite 

increased protection. Further, in Guatemala, solitary nesting turtles have decreased 34% between 

1981 and 1997 (Muccio, 1999).

Gahirmatha, Orissa, India used to be one of the largest arribada nesting sites in the world. Over 

the past five years at Gahirmatha, there has been an arribada nesting event in only two of those 

five years. Additionally, between 1996 and 2002, the average size of nesting females declined at 

that site, indicative of a declining population (Plotkin ed., 2007). Declines in solitary nesting of 

olive ridleys have been recorded in Bangladesh, Myanmar, Malaysia, and Pakistan. In particular, 

the number of nests in Terengganu, Malaysia has declined from thousands of nests to just a few 

dozen per year (Limpus, 1995).

Conservation Status:

The olive ridley is listed as endangered by the IUCN (International Union for Conservation of 

Nature). Degradation of nesting beaches, ongoing directed harvest, and bycatch in fisheries have 

all contributed to the decline of the species. The olive ridley may be the most abundant sea turtle 

on the planet, but some argue that it is also the most exploited.

According to the Marine Turtle Specialist Group (MTSG) of the IUCN, there has been a 50% 

reduction in population size since the 1960s. Although some nesting populations have increased 

in the past few years, the overall reduction is greater than the overall increase. However, not all 

populations are depleted. Some nesting populations are currently stable and/or increasing. In 

Sergipe, Brazil, strict nest protection has led to increases of the nesting population over the past 

20 years. In La Escobilla, Mexico, conservation measures, such as increased nesting beach 

protection and closure of the turtle fishery in 1990, have led to a dramatic increase in the once 

largest nesting population in the world. The number of olive ridley nests has increased from 

50,000 in 1988 to over 700,000 in 1994 to more than a million nests in 2000 (Márquez et al. 

2002). This dramatic improvement gives hope that with strict protections the once depleted 

populations can begin recovering.
2013 VGP and sVGP BE Appendix F

F-137

Summary of Major Threats:

The principal cause of the historical, worldwide decline of the olive ridley sea turtle is long-term 

collection of eggs and killing of adults on nesting beaches. Because arribadas concentrate 

females and nests in time and space, they allow for mass killing of adult females as well as the 

taking of an extraordinary number of eggs. These threats continue in some areas of the world 

today, compromising efforts to recover this species.

In the western south Atlantic Ocean, killing adults and collecting eggs of all nesting sea turtle 

species is historically widespread in the Guianas and northeastern Brazil. Despite a current 

prohibition on olive ridley egg harvest in Suriname, an estimated 40% of the olive ridley nests 

were harvested in 1995 (Hoekert et al., 1996). In the eastern North Atlantic Ocean, nesting olive 

ridleys are captured along the entire west coast of Africa and sold in local and regional markets. 

A survey of 27 west African nations indicated that nesting females were killed in 14 of those 

countries.

In the eastern Pacific Ocean, killing sea turtles and collecting their eggs has occurred for 

hundreds of years. Little data on historical egg taking in Mexico currently exist, but egg 

collection has previously reached nearly 100% at solitary nesting sites. In many places, egg 

collecting currently continues at this level (Plotkin ed., 2007).

Throughout the Indian Ocean, nesting populations of olive ridleys have declined due to both 

killing of nesting females at solitary nesting beaches and a directed fishery for the species 

concentrated at the major arribada nesting beach in Orissa, India during the 1970s.

Expansion of the shrimp trawling fishery in the eastern Indian Ocean in the mid-1970s has 

resulted in numerous olive ridley deaths. During the 1982-1983 nesting season, over 7,000 

carcasses washed ashore over a 9 mile (15 km) stretch of beach. Between 1993 and 1999, more 

than 46,200 carcasses were recorded by beach surveyors, with a peak during the 1997-1998 

seasons of 13,575 dead olive ridleys. Over 10,000 olive ridley carcasses a year have been 

counted on the Orissa coast since 1999 (Wright and Mohanty, 2006). These carcasses have 

largely been attributed to the shrimp trawl fishery, but trawling is not the only source of olive 

ridley mortality in the Eastern Indian Ocean. On February 17, 2002, 205 dead olive ridleys 

entangled in a section of gillnet were washed ashore at Gundalba Beach, Orissa (Wright and 

Mohanty, 2002).

Additionally, incidental captures in fishing gear, primarily in longlines, but also in trawls, gill 

nets, purse seines, and hook and line, is a serious ongoing source of mortality that adversely 

affects the species' recovery. Specifically, incidental capture of sea turtles in shrimp trawls along 

the coast of Central America is estimated as exceeding 60,000 sea turtles annually, most of 

which are olive ridleys (Arauz, 1996).

F.6.27.

Lepidurus packardi

VERNAL POOL TADPOLE SHRIMP

Family: Triopsidae

Endangered: wherever found
2013 VGP and sVGP BE Appendix F

F-138

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=K048)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Lepidurus+pack

ardi)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc1160.pdf)

• 70 FR 46924 (http://www.gpo.gov/fdsys/pkg/FR-2005-08-11/pdf/05-15569.pdf#page=1)

• 71 FR 7118 (http://www.gpo.gov/fdsys/pkg/FR-2006-02-10/pdf/06-1080.pdf#page=1)

Description:

Lepidurus packardi is a large tadpole shrimp with dorsal compound eyes; a large (up to 3.5 cm 

long) dorsal shield-like carapace, which is attached to the head region, covering most of the 35 to 

48 pairs of swimming appendages (phyllopods) and two long cercopods at the end of the last 

body segment (telson) (Pennak, 1978; Longhurst, 1955).

Geographic Boundaries and Spatial Distribution:

The vernal pool tadpole shrimp has a patchy distribution across the Central Valley of California, 

from Shasta County southward to northwestern Tulare County, with isolated occurrences in 

Alameda and Contra Costa Counties (CNDDB, 2007). Although vernal pool tadpole shrimp are 

spread over a wide geographic range, their habitat is highly fragmented and they are uncommon 

where they are found (Helm 1998; Service 2005a). The California Natural Diversity Database 

currently reports 226 occurrences of vernal pool tadpole shrimp in the following 19 counties: 

Alameda, Butte, Colusa, Contra Costa, Fresno, Glenn, Kings, Merced, Placer, Sacramento, San 

Joaquin, Shasta, Solano, Stanislaus, Sutter, Tehama, Tulare, Yolo, and Yuba. Sacramento 

County contains 28 percent, the greatest amount, of the known occurrences (CNDDB, 2007).

Habitat: (has critical habitat)

The vernal pool tadpole shrimp is found only in ephemeral freshwater habitats, including 

alkaline pools, clay flats, vernal lakes, vernal pools, vernal swales, and other seasonal wetlands 

in California (Helm, 1998). Vernal pools are an ephemeral type of wetland that is found in 

California and southern Oregon. Vernal pools are generally small, shallow wetlands, located on 

clay or hardpan layer, which fill with water during the winter and spring, then dry up until the 

next rainy season. Vernal pools form where a soil layer (hardpan, duripan, or claypan) exists 

below or at the surface that is impermeable or nearly impermeable to water (Smith and Verrill,

1998). Hardpan layers are formed on alluvial terraces by leaching, redeposition, and cementing 

of silica minerals from high in the soil profile to a lower (“B”) horizon (Smith and Verrill, 1998). 

Duripan is a horizon in a mineral soil that is characterized by cementation by silica. Claypan 

layers are formed by a similar redeposition process of fine clay particles sometimes augmented 

by saline or alkaline compounds, being transported to the B horizon where they accumulate and 

eventually hold water. Crustaceans, such as the vernal pool tadpole shrimp, produce cysts or 

eggs that lie buried in the soil until the next winter rains trigger the eggs to hatch. The cysts may 

hatch in as little as 4 days (Ahl 1991, Rogers in litt. 2001). This species inhabits freshwater 
2013 VGP and sVGP BE Appendix F

F-139

habitats containing clear to highly turbid water, with water temperatures ranging from 50 to 84 ̊F 

and pH ranging from 6.2 to 8.5 (King 1996; Syrdahl 1993).

Critical habitat for the Vernal Pool Tadpole Shrimp and several other vernal pool species was 

designated on August 11, 2005. The final designation of critical habitat for vernal pool tadpole 

shrimp is 228,785 ac (92,586 ha).

The primary constituent elements for the vernal pool tadpole shrimp are: (1) mounds and swales 

and depressions within a matrix of surrounding uplands that result in complexes of continuously, 

or intermittently, flowing surface water in the swales connecting pools, providing for dispersal 

and promoting hydroperiods of adequate length in the pools; (2) depressional features including 

isolated vernal pools with underlying restrictive soil layers that become inundated during winter 

rains and that continuously hold water for a minimum of 41 days (Helm 1998), in all but the 

driest years, for incubation, maturation, and reproduction; (3) sources of food, expected to be 

detritus occurring in the pools, contributed by overland flow from the pools’ watershed, or the 

results of biological processes within the pools themselves, such as single-celled bacteria, algae, 

and dead organic matter, to provide for feeding; (4) structure within the pools, consisting of 

organic and inorganic materials that provide shelter.

Life History:

Vernal pool tadpole shrimp generally take between 3 and 4 weeks to mature (Ahl, 1991; King et 

al., 1996). Reproduction begins after individuals reach 0.4 inch or more in carapace length and 

fecundity increases with body size Ahl (1991). Large females, greater than 0.8 inch carapace 

length, can deposit as many as 6 clutches, ranging from 32 to 61 eggs per clutch, in a single wet 

season Ahl (1991). Vernal pool tadpole shrimp may be hermaphroditic (individuals have both 

male and female reproductive organs) (Longhurst, 1955; Lynch, 1966; C. Rogers, 2001). 

Multiple hatching within the same wet season allows vernal pool tadpole shrimp to persist within 

pools as long as these habitats remain inundated, sometimes for 6 months or more (Ahl, 1991; 

Gallagher, 1996; Helm, 1998). Hatching of vernal pool tadpole shrimp eggs is temperaturedependent. Optimal hatching occurs between 50 to 59 ̊F, with hatching rates becoming 

significantly lower at temperatures above 68 ̊F (Ahl, 1991). Vernal pool tadpole shrimp eggs and 

adults are carried from one wetland to another by a variety of methods, the most important likely 

being overland flooding from rainstorms, and by waterfowl and other migratory birds (on the 

bird’s feet or in its gut). Vernal pool tadpole shrimp feed on both living organisms such as fairy 

shrimp and on detritus (Service, 2005a), and can be identified by the large, shield-like carapace 

that covers the anterior half of their bodies and the paddle-like supra-anal plate located between 

the paired cercopods (jointed antenna-like appendages). Vernal pool tadpole shrimp have from 

30 to 35 pairs of phyllopods (swimming legs that also function as gills), a segmented abdomen, 

and fused eyes. Mature vernal pool tadpole shrimp range from 0.6 to 3.3 inches in length 

(Service, 2005a).

Historical Information:

There are currently 226 known occurrences of this species (CNDDB, 2007), of which at least 

two are thought to be extirpated (CNDDB, 2007; P. Balfour, ECORP, pers. comm., 2007). Many 

occurrences on private property were last surveyed 10 to 15 years ago and their current status is 

unknown. Since the time of listing, the species has been discovered in four additional counties 
2013 VGP and sVGP BE Appendix F

F-140

(Contra Costa, Fresno, Kings, and Tulare Counties), extending the range by approximately 

100 miles to the south into Tulare County. The greatest number of vernal pool tadpole shrimp 

occurrences are located in Sacramento County (CNDDB, 2007), and the Mather core area, within 

in the Southeastern Sacramento Valley Vernal Pool Region, likely contains the highest density of 

vernal pool tadpole shrimp occurrences within the range of the species (CNDDB, 2007; Service 

2007). This area, well known for its vernal pools of exceptional quality and representing 

important, high quality habitat for the vernal pool tadpole shrimp (Rogers, 2006), has a limited 

amount of remaining habitat that is able to be preserved (Sacramento County 2006; R. 

Radmacher, Sacramento County, pers. comm., 2007).

Conservation Status:

The vernal pool tadpole shrimp continues to be found in each of the vernal pool regions from 

which it was known historically. At the time of listing in 1994, vernal pool tadpole shrimp were 

known from 18 populations, extending from east of Redding, Shasta County, southward to the 

San Luis NWR, Merced County, in the Central Valley, with a disjunct population at the San 

Francisco NWR, Alameda County (59 FR 48136).

The extant occurrences of the vernal pool tadpole shrimp are distributed among seven vernal 

pool regions: Central Coast, Northeastern Sacramento Valley, Northwestern Sacramento Valley, 

San Joaquin Valley, Solano-Colusa, Southeastern Sacramento Valley, and Southern Sierra 

Foothills. The Southeastern Sacramento Valley Vernal Pool Region, which includes Sacramento 

County, contains almost 15 percent of the remaining vernal pool grasslands in California 

(Keeler-Wolf et al., 1998) and supports the largest concentration, or approximately 35 percent, of 

the known occurrences of the vernal pool tadpole shrimp (Service, 2005a). Sacramento County, 

which is part of the Southeastern Sacramento Valley Vernal Pool Region, contains the greatest 

number of vernal pool tadpole shrimp occurrences, or approximately 28 percent, of any single 

county (CNDDB, 2007). Sugnet and Associates’ (1993) found that of the pools that they 

surveyed in California, the majority of the pools (about 63 percent) occupied by vernal pool 

tadpole shrimp were located in Sacramento County. These occurrences are concentrated in 

Sacramento County southeast of the City of Sacramento, in and around the Mather core area 

(CNDDB, 2007; Service, 2005a). The Service has estimated that approximately 74 percent of all 

the vernal pool tadpole shrimp occurrences in the Southeastern Sacramento Valley occur in the 

Mather core area (Service, 2007). 

Summary of Major Threats:

The elimination and degradation of vernal pool habitat from agricultural (grapes) and urban 

development seem to be the greatest threat; however, grazing, off-road vehicle use and 

hydrologic modification may also contribute (USFWS, 1992). The primary threats are 

elimination and degradation of vernal pool habitat by urban development and conversion of 

grasslands to agricultural fields (U.S. Fish and Wildlife Service, 1992). In addition, it is known 

to have been parasitized by flukes (Trematoda) of an undetermined species at the Vina Plains, 

Tehama County (Ahl, 1991) (gonads of both sexes greatly reduced in size and body cavities 

filled with many young flukes). Ahl (1991) thus concluded that parasitic castration was the major 

limiting factor affecting reproduction of the vernal pool tadpole shrimp at the Vina Plains. 
2013 VGP and sVGP BE Appendix F

F-141

F.6.28.

Masticophis lateralis euryxanthus

ALAMEDA WHIPSNAKE

Family: Colubridae

Threated: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=C04A)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Masticophis+lat

eralis+euryxanthus)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc3886.pdf)

• 71 FR 58176 (http://www.gpo.gov/fdsys/pkg/FR-2006-10-02/pdf/06-8367.pdf#page=1)

Description:

The Alameda whipsnake is a slender, fast-moving, semi-arboreal, diurnal snake with a broad 

head, large eyes, and slender neck. These characteristics are typical of snake species that predate 

on lizards. Its dorsum is dark brown with a broad orange stripe on each side, ventral surface is 

plain cream colored, pink, and/or orange and adults generally are 90-124 cm in total length. This 

subspecies differs by having comparatively wide lateral stripes that tend to be orange rather than 

yellow.

Geographic Boundaries and Spatial Distribution:

Its Inner Coast range in western and central Contra Costa and Alameda counties, California has 

five major populations: (1) Sobrante Ridge, Tilden/Wildcat regional parks area to the Briones 

Hills, in Contra Costa County, (2) Oakland Hills, Anthony Chabot area to Las Trampas Ridge, in 

Costra Costa County, (3) Hayward Hills, Palomares area to Pleasanton Ridge, in Alameda 

County, (4) Mount Diablo vicinity and the Black Hills, in Costra Costa County, and (5) Wauhab 

Ridge, Del Valle area to the Cedar Mountain Ridge, in Alameda County (Federal Register, 1 

November 1996; USFWS 1997, 2000). This species is commonly associated with small to large 

patches of chaparral or coastal scrub vegetation, interspersed with other native vegetation types 

and rock lands throughout Contra Costa County, most of Alameda County, and portions of 

northern Santa Clara and western San Joaquin counties.

Habitat: (has critical habitat)

Alameda whipsnakes are typically associated with small to large patches of chaparral or coastal 

scrub vegetation, interspersed with other native vegetation types and rock lands (areas containing 

large percentage of rocks, rocky features, and/or rock-bearing soil types). Chaparral and coastal 

scrub vegetation serve as the center of home ranges and provide for concealment from predators, 

and foraging opportunities. Core areas have been found to center around patches of coastal scrub 

or chaparral as small 0.2 hectare (0.5 acre) embedded within a mosaic of other dominant 

vegetation types. Small rodent burrows are important retreats, and brush piles and deep soil 

crevices can also serve as important habitat features (Swaim, 1994). These habitat features are 

essential for normal behaviors such as breeding, reproduction, and foraging, because they 
2013 VGP and sVGP BE Appendix F

F-142

provide refuge from predators, egg-laying sites, thermal cover, shelter, winter hibernacula, and 

increased numbers of foraging opportunities (Swaim, 1994).

Six units were established as critical habitat for the Alameda whipsnake on October 2, 2006. 

Unit 1 is Tilden-Briones in Alameda and Contra Costa Counties (34,119 ac), unit 2 is OaklandLas Trampas in Contra Costa and Alameda Counties (24,436 ac), unit 3 is Hayward-Pleasanton 

Ridge in Alameda County (25,966 ac), unit 4 is Mount Diablo-Black Hills in Contra Costa and 

Alameda Counties (23,225 ac), unit 5A is Cedar Mountain in Alameda and San Joaquin Counties 

(24,723 ac), unit 5B is Alameda Creek in Alameda and Santa Clara Counties (18,214 ac), and 

unit 6 is Caldecott Tunnel in Contra Costa and Alameda Counties (4,151 ac).

Primary constituent elements for the Alameda whipsnake include: (1) Scrub/shrub communities 

with a mosaic of open and closed canopy as characterized by the chamise,

chamise-eastwood manzanita, chaparral whitethorn, and interior live oak shrub vegetation series, 

occurring at elevations from sea level to approximately 3,850 ft (1,170 m); (2) woodland or 

annual grassland plant communities contiguous to the above, comprised of one or more of the 

following: Blue oak, coast live oak, California bay, California buckeye, and California annual 

grassland vegetation series; (3) Lands containing rock outcrops, talus, and small mammal 

burrows within or adjacent to the above, essential for retreats (shelter), hibernacula, foraging, 

and dispersal, and provide additional prey population support functions.

Life History:

Adult Alameda whipsnakes have a bimodal seasonal activity pattern, with peaks during the 

spring mating season and a smaller peak during late summer and early fall (Swaim, 1994). They 

generally retreat into winter hibernacula (the location chosen for hibernation) in November and 

emerge in March. However, short, above-ground activity such as basking in the immediate 

vicinity of the hibernaculum may occur during this time (Swaim, 1994). Courtship and mating 

occur from late March through mid-June. During this time, males have been found to move 

throughout their home range and females have been found to remain at or near their hibernacula 

until mating completes. Average clutch size was found to be 7.21 with a significant correlation 

between body size and clutch size (Goldberg, 1975). Incubation lasts about 3 months and young 

appear in late summer and fall. Hatchlings have been observed or captured above ground from 

August through November (Hammerson, 1978, Swaim, 1994). Prey items have been detected in 

the stomachs of captured hatchlings during this period, indicating feeding may occur prior to 

winter hibernation (Swaim, 1994). 

When hunting, it commonly moves with its head held high and occasionally moves it from side 

to side. Prey is seized with great speed, pinioned under loops of the body, and engulfed without 

constriction. The Alameda whipsnake is semi-arboreal and can escape into or hunt within shrubs 

or trees. Lizards, especially the western fence lizard (Sceloporus occidentalis), appear to be 

important prey items (Stebbins, 1985, Swaim, 1994, H. Greene personnel communication 1998), 

although other prey items including frogs, snakes, small birds, small mammals, and insects have 

been reported to be eaten by California whipsnakes (Stebbins, 1985). 
2013 VGP and sVGP BE Appendix F

F-143

Historical Information:

The loss and fragmentation of habitat, as a result of urban development and transportation 

corridors, were considered to be substantial threats to the Alameda whipsnake when it was listed 

and remain threats today. 

Conservation Status:

Little population abundance data exists for the Alameda whipsnake. However, Alameda 

whipsnakes have been found to be locally abundant and the dominant snake species when habitat 

quality is high (Swaim, 2002). Almost all trapping studies targeting this species have been 

designed to determine presence or absence for regulatory purposes and assessing impacts to 

potential habitat. As such, monitoring is most often habitat based; assuming snake abundance is 

positively correlated with the amount of coastal scrub or chaparral vegetation and rock lands 

present. 

Summary of Major Threats:

The species has declined due to residential and commercial development of habitat, which 

continues to be the major problem. The removal of shrub and grass cover by overgrazing has 

eliminated or degraded habitat in some areas (California Department of Fish and Game 1990; 

McGinnis 1992; Federal Register, 4 February 1994). Its habitat is also threatened also by fire 

suppression and related wildfire problems associated with lack of fuel reduction (USFWS, 1997).

F.6.29.

Neostapfia colusana

COLUSA GRASS

Family: Poaceae

Threatened: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q19I)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc1930.pdf)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Neostapfia+colu

sana)

• 70 FR 46924 (http://www.gpo.gov/fdsys/pkg/FR-2005-08-11/pdf/05-15569.pdf#page=1)

• 71 FR 7118 (http://www.gpo.gov/fdsys/pkg/FR-2006-02-10/pdf/06-1080.pdf#page=1)

Description:

Colusa grass is an annual plant in the grass family (Poaceae) and is in the Orcuttieae taxonomic 

tribe, which also includes species of the Orcuttia and Tuctoria genera. It is an annual grass, up to 

30 cm tall, with a robust inflorescence that resembles a small ear of corn. Its aquatic seedlings 

have only one or two juvenile leaves. In the terrestrial stage, multiple stems arise in clumps from 

a common root system. Plants are pale green when young, but become brownish as the exudate 

darkens. Each stem produces a dense, cylindrical inflorescence 2-8 cm long by 8-12 mm broad. 
2013 VGP and sVGP BE Appendix F

F-144

The spikelets are densely packed in a spiral arrangement and the tip of the rachis projects beyond 

the spikelets (USFWS, 2005).

Geographic Boundaries and Spatial Distribution:

Grasses of the Orcuttieae tribe are endemic to California vernal pool habitat in the Central 

Valley. The majority of extant Colusa grass occurrences are in the Southern Sierra Foothills 

Vernal Pool Region, where they are concentrated northeast of the City of Merced in Merced 

County and east of Hickman in Stanislaus County. The majority of these known extant 

occurrences (42 percent) are at the Flying M Ranch, the Ichord Ranches, and the Virginia Smith 

Trust site (Vollmar, 2002). The current range is estimated to be about 6,500 square km. 

Habitat: (has critical habitat)

The grass occurs in Northern Claypan and Northern Hardpan vernal pools (Sawyer and KeelerWolf 1995) within rolling grasslands. Sites are located on the rim of alkaline basins in the 

Sacramento and San Joaquin Valleys, as well as on acidic soils of alluvial fans and stream 

terraces along the eastern margin of the San Joaquin Valley and adjacent foothills. Soils include 

clay, silty clay, silty clay loam, and gravelly loam. Impermeable layers underlying occupied 

pools range from claypan to lime-silica or iron-silica cemented hardpan and tuffaceous alluvium. 

Occupied pools range in size from 0.01 to 250 hectares (median size 0.2 hectares); the species 

also occurs in the beds of intermittent streams and in artificial ponds. Typically grows in the 

deepest portion of the pool or stream bed, although it may also occur on the margins.

Critical habitat for Colusa grass and several other vernal pool species was designated on August 

11, 2005. The final designation of critical habitat for Colusa grass is 152,093 acres.

The PCEs of critical habitat for Colusa grass are the habitat components that provide: (1) 

topographic features characterized by isolated mound and intermound complex within a matrix 

of surrounding uplands that result in continuously, or intermittently, flowing surface water in the 

depressional features including swales connecting pools, providing for dispersal and promoting 

hydroperiods of adequate length in the pools; (2) depressional features including isolated vernal 

pools with underlying restrictive soil layers that become inundated during winter rains and that 

continuously hold water or whose soils are saturated for a period long enough to promote 

germination, flowering, and seed production of predominantly annual native wetland species and 

typically exclude both native and nonnative upland plant species in all but the driest years. As 

these features are inundated on a seasonal basis, they do not promote the development of obligate 

wetland vegetation habitats typical of permanently flooded emergent wetlands.

Life History:

Long-term inundation of approximately three months is required for seed germination, and it 

appears that deeper pools and stock ponds are most likely to provide the long inundation period 

required (Service, 2005). Unlike terrestrial grasses, grasses in the Orcuttieae tribe have pith-filled 

stems, lack distinct leaf sheaths and ligules, and produce exudate.

Historical Information:

When Colusa grass was listed as threatened in 1997, there were 40 known extant occurrences. 

Approximately 39 occurrences are currently considered extant, most of them located within a 
2013 VGP and sVGP BE Appendix F

F-145

200 km-long area. At least 8 populations have been extirpated. Vernal pool habitats in 

California's Central Valley have been greatly reduced from pre-European times; the remaining 

habitats are limited in extent, fragmented, and are facing on-going degradation and elimination 

due to numerous housing development projects and other types of urban development, 

agricultural activities and development, grazing, the invasion of non-native plant species, and 

other threats.

Conservation Status:

Population sizes of Colusa grass can vary widely from year to year. Colusa grass has the 

broadest ecological range among the Orcuttieae tribe, as it occurs on the rim of alkaline basins in 

the Sacramento and San Joaquin Valleys, on acidic soils of alluvial fans and stream terraces 

along the eastern margin of the San Joaquin Valley and into the adjacent foothills, as well as in 

Northern Claypan and Northern Hardpan vernal pool types. 

Currently, there are 43 presumed extant occurrences in Yolo, Solano, Merced, and Stanislaus 

Counties (Hogle, 2002; CNDDB, 2008). The vast majority of these occurrences are in Stanislaus 

County (15 occurrences) and Merced County (22 occurrences). During the 1980s, many new 

occurrences of Colusa grass were located during extensive surveys. As of 1989, 40 occurrences 

were extant and 11 had been extirpated (Stone et al., 1988). In 2002, there were 48 occurrences 

believed to be extant (Vollmar, 2002, Service, 2002). The overall trend of this species is unclear 

due to lack of systematic surveys. 

Summary of Major Threats:

The remaining occurrences remain threatened by land conversion to urban development and to 

irrigated cropland, impacts from surrounding land use, competition with non-native plant 

species, potential changes to hydrology, and other human activities. Many occurrences occupy a 

small area, indicating that extirpation is still a threat even on protected sites.

F.6.30.

Neotoma fuscipes riparia

RIPARIAN WOODRAT

Family: Muridae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=A0FC)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Neotoma+fuscip

es+riparia)

• USFWS, 2012b (http://ecos.fws.gov/docs/recovery_plan/980930a.pdf)

Description:

The riparian woodrat is a medium-sized (200 to 400 grams; 7.05 to 14.11 ounces) rodent with a 

stockier build and a tail that is well furred (Hooper, 1938; Williams et al. 1992) and not scaled. 
2013 VGP and sVGP BE Appendix F

F-146

N. fuscipes riparia differs from other, adjacent subspecies of woodrats by being larger, lighter, 

and more grayish in color, with hind feet white instead of dusky on their upper surfaces, and a 

tail more distinctly bicolored (lighter below contrasting more with the darker dorsal color) 

(Hooper 1938).

Geographic Boundaries and Spatial Distribution:

The woodrat distribution it limited to Lower San Joaquin Valley, California (Williams and 

Kilburn 1984) with a range of about 100-8,000 square miles. It is presently known to be extant 

only at Caswell Memorial State Park (Williams, 1993). Williams (1993) estimated the size of 

this population at 437 individuals.

Habitat: (no critical habitat)

Woodrats inhabit evergreen or live oaks and other thick-leaved trees and shrubs (Kelly, 1990;

Williams et al., 1992). Riparian woodrats are common, however, where there are deciduous 

valley oaks, but few live oaks. They are most numerous where shrub cover is dense and least 

abundant in open areas. In riparian areas, highest densities of woodrats and their houses are often 

encountered in willow thickets with an oak overstory (Linsdale and Tevis, 1951).

Dusky-footed woodrats are well known for their large terrestrial stick houses, some of which can 

last for 20 or more years after being abandoned (Linsdale and Tevis, 1951; Carraway and Verts,

1991). At Caswell Memorial State Park, riparian woodrats also make houses of sticks and other 

litter (Williams, 1993). At the Hastings Reserve, Monterey County, dusky-footed woodrat 

houses range from 60 centimeters (2 feet) to 150 centimeters (5 feet) in height, and can be 

120 centimeters (4 feet) to 240 centimeters (8 feet) in basal diameter. Houses typically are placed 

on the ground against or straddling a log or exposed roots of a standing tree and are often located 

in dense brush. Nests also are placed in the crotches and cavities of trees and in hollow logs. 

Sometimes tree nests are constructed but this behavior seems to be more common in habitat with 

evergreen trees such as live oak (Williams et al., 1992).

Life History:

Although some species have more specialized diets than others, woodrats are, for the most part, 

generalist herbivores. They consume a wide variety of nuts and fruits, fungi, foliage and some 

forbs (Linsdale and Tevis, 1951). Dusky-footed woodrats live in loosely-cooperative societies 

and have a matrilineal (mother-offspring associations; through the maternal line) social structure 

(Kelly, 1990). Unlike males, adjacent females are usually closely related and, unlike females, 

males disperse away from their birth den and are highly territorial and aggressive, especially 

during the breeding season. Consequently, populations are typically female-biased and, because 

of pronounced polygyny (mating pattern in which a male mates with more than one female in a 

single breeding season), the effective population size (i.e., successful breeders) is generally much 

smaller than the actual population size (Kelly, 1990).

Historical Information:

The known historical distribution included areas along the San Joaquin, Stanislaus, and 

Tuolumne rivers, and Corral Hollow, in San Joaquin, Stanislaus, and Merced Counties. The 

range of the riparian woodrat is far more restricted today than it was in 1938 (Williams, 1986).
2013 VGP and sVGP BE Appendix F

F-147

Conservation Status:

The riparian woodrat occurs in one location in riparian habitat in the San Joaquin Valley, 

California with a total population in the early 1990s estimated at about 450. Its habitat has 

shrunk greatly and is now very limited.

Summary of Major Threats:

The only known extant population of riparian woodrat is small, with its size limited by the 

available habitat. It is thus at an increased risk of extinction because of genetic, demographic, 

and random catastrophic events (e.g., drought, flooding, fire) that threatens small, isolated 

populations. Because of its breeding behavior, the effective size of woodrat populations is 

generally much smaller than the actual population size. This increases the risk of inbreeding 

depression. 

The woodrat population at Caswell Memorial State Park is vulnerable to flooding of the 

Stanislaus River. Because of its well-developed arboreality (ability to climb in trees), the 

woodrat itself is not as sensitive to flooding as some other brush-dwelling species (e.g., the 

riparian brush rabbit). However, woodrat houses are essential for survival and these can be 

severely impacted by flooding, thus affecting population viability.

F.6.31. STEELHEAD SALMON

(Central CA Coast, South Central CA Coast, and Southern CA Coast)

Oncorhynchus mykiss

(See Seattle, Washington for information on this species)

Sources:

• 70 FR 52488 (http://www.gpo.gov/fdsys/pkg/FR-2005-09-02/pdf/05-16389.pdf#page=1)

Habitat: (has critical habitat) -for these DPS

Final critical habitat was designated for the above ESUs of steelhead on September 2, 2005. 

There are 46 occupied HAS watersheds within the freshwater and estuarine range of the central 

CA coast steelhead ESU. HSA watershed habitat areas for this ESU include approximately 1,832 

mi (2,931 km) of stream habitat and approximately 442 mi2 (1,140 km2) of estuarine habitat 

(principally San Francisco Bay-San Pablo Bay). Of these, approximately 0.6 stream miles (1.0 

km) are being excluded because they overlap with Indian lands (Coyote Valley and Redwood 

Valley Rancherias). Counties with critical habitat are Lake, Mendocino, Sonoma, Napa, Marin, 

San Francisco, San Mateo, Santa Clara, Santa Cruz, Alameda, Contra Costa, and San Joaquin.

There are 30 occupied HAS watersheds within the freshwater and estuarine range of the south 

central CA coast steelhead ESU. HSA watershed habitat areas for this ESU include 

approximately 1,251 mi (2,000 km) of stream habitat and approximately 3 mi2 (8 km2) of 

estuarine habitat (e.g., Morro Bay). Approximately 22 stream miles (35 km) are not eligible for 

designation because they are within lands controlled by the DOD (Camp San Luis Obispo and 

Camp Roberts) that have qualifying INRMPs. Counties with critical habitat are Monterey, San 

Benito, Santa Clara, Santa Cruz, San Luis Obispo.
2013 VGP and sVGP BE Appendix F

F-148

There are 32 occupied HAS watersheds within the freshwater and estuarine range of the southern 

CA steelhead ESU. HSA watershed habitat areas for this ESU include approximately 741 mi 

(1,186 km) of stream habitat. Of these, approximately 22 mi (35 km) of occupied stream miles 

are excluded because they are within lands controlled by the DOD (Vandenberg AFB and Camp 

Pendleton Marine Corps Base ) that have qualifying INRMPs and for which the benefits of 

exclusion outweigh the benefits of designation. Counties with critical habitat are San Luis 

Obispo, Santa Barbara, Ventura, Los Angeles, Orange and San Diego.

Critical habitat includes the stream channels within the designated stream reaches, and includes a 

lateral extent as defined by the ordinary high-water line. Within these areas, the primary 

constituent elements essential for the conservation of these ESUs are those sites and habitat 

components that support one or more life stages, including: (1) freshwater spawning sites with 

water quantity and quality conditions and substrate supporting spawning, incubation and larval 

development; (2) freshwater rearing sites with: (i) water quantity and floodplain connectivity to 

form and maintain physical habitat conditions and support juvenile growth and mobility; 

(ii) water quality and forage supporting juvenile development; and (iii) natural cover such as 

shade, submerged and overhanging large wood, log jams and beaver dams, aquatic vegetation, 

large rocks and boulders, side channels, and undercut banks; (3) freshwater migration corridors 

free of obstruction and excessive predation with water quantity and quality conditions and 

natural cover such as submerged and overhanging large wood, aquatic vegetation, large rocks 

and boulders, side channels, and undercut banks supporting juvenile and adult mobility and 

survival. (4) estuarine areas free of obstruction and excessive predation with: (i) water quality, 

water quantity, and salinity conditions supporting juvenile and adult physiological transitions 

between fresh- and saltwater; (ii) natural cover such as submerged and overhanging large wood, 

aquatic vegetation, large rocks and boulders, side channels; and (iii) juvenile and adult forage, 

including aquatic invertebrates and fishes, supporting growth and maturation.

F.6.32.

Orcinus orca

KILLER WHALE

(See Seattle, Washington for information on this species)

F.6.33.

Orcuttia pilosa

HAIRY ORCUTT GRASS

Family: Poaceae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q1AY)

• USFWS, 2012b

(http://ecos.fws.gov/docs/recovery_plans/2006/060307_docs/doc533.pdf)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Orcuttia+pilosa)
2013 VGP and sVGP BE Appendix F

F-149

• 70 FR 46924 (http://www.gpo.gov/fdsys/pkg/FR-2005-08-11/pdf/05-15569.pdf#page=1)

• 71 FR 7118 (http://www.gpo.gov/fdsys/pkg/FR-2006-02-10/pdf/06-1080.pdf#page=1)

Description:

Hairy orcutt grass, Orcuttia pilosa, grows in tufts consisting of numerous stems. The stems are 

decumbent or erect and branch from only the lower nodes. Stems are 5 to 20 cm (2.0 to 7.9 in.) 

long and 1 to 2 mm (0.04 to 0.08 in.) in diameter (Stone et al., 1988). Almost the entire plant is 

pilose (bearing long, soft, straight hairs), giving it a grayish appearance. The terrestrial leaves are 

3 to 6 mm (0.12 to 0.24 in.) wide. The inflorescence is 5 to 10 cm (2.0 to 3.9 in.) long and 

contains between 8 and 18 flattened spikelets. The spikelets near the tip of the inflorescence are 

crowded together, whereas those near the base are more widely spaced. Each spikelet consists of 

10 to 40 florets and two tiny (3 mm) glumes. The lemmas are 4 to 5 mm (0.16 to 0.20 in.) long, 

with five teeth of equal size. Each caryopsis is 1.75 to 2 mm (0.07 to 0.08 in.) long (Hoover,

1941; Reeder, 1982, 1993) and weighs 0.46 to 0.95 mg (Griggs, 1980).

Geographic Boundaries and Spatial Distribution:

Hairy orcutt grass occurs over a 490 km stretch on the eastern margin of the San Joaquin and 

Sacramento Valleys from Tehema County south through Merced and Mariposa Counties, 

California. It is endemic to vernal pool habitats along the eastern edge of the Central Valley of 

California. It is known from 24 extant native populations, only about half of which are thought to 

be stable and extirpated at least 11 sites.

Habitat: (has critical habitat)

This species is found on high or low stream terraces and alluvial fans (Stone et al. 1988). Hairy 

orcutt grass occurs in Northern Basalt Flow, Northern Claypan, and Northern Hardpan vernal 

pools (Sawyer and Keeler-Wolf, 1995) within annual grasslands (California Natural Diversity 

Data Base, 2003). The median size of occupied pools measured in the late 1980s was 1.7 

hectares (4.2 acres), with a range of 0.34 to 250 hectares (0.8 to 617.5 acres) (Stone et al., 1988). 

At the Vina Plains, hairy orcutt grass was found growing only in pools that held water until May, 

June, or July in 1995, and not in those that had dried by April (Alexander and Schlising, 1997). 

This species is known from elevations of 26 meters (85 feet) in Glenn County to 123 m (405 ft.) 

in Madera County (California Natural Diversity Data Base, 2003). Hairy orcutt grass is found on 

both acidic and saline-alkaline soils, in pools with an iron-silica cemented hardpan or claypan. In 

the Northeastern Sacramento Valley Vernal Pool Region, pools supporting hairy orcutt grass 

occur on the Anita and Tuscan soil series (Stone et al. 1988, California Natural Diversity Data 

Base 2003).

Critical habitat for hairy orcutt grass and several other vernal pool species was designated on 

August 11, 2005. The final designation of critical habitat for hairy orcutt grass is 79,608 acres.

The PCEs of critical habitat for hairy orcutt grass are the habitat components that provide: (1) 

topographic features characterized by isolated mound and intermound complex within a matrix 

of surrounding uplands that result in continuously, or intermittently, flowing surface water in the 

depressional features including swales connecting pools, providing for dispersal and promoting 

hydroperiods of adequate length in the pools; (2) depressional features including isolated vernal 

pools with underlying restrictive soil layers that become inundated during winter rains and that 
2013 VGP and sVGP BE Appendix F

F-150

continuously hold water or whose soils are saturated for a period long enough to promote 

germination, flowering, and seed production of predominantly annual native wetland species and 

typically exclude both native and nonnative upland plant species in all but the driest years. As 

these features are inundated on a seasonal basis, they do not promote the development of obligate 

wetland vegetation habitats typical of permanently flooded emergent wetlands

Life History:

Life history characteristics shared among all Orcutt grasses (Orcuttia species), but not other 

genera in the Orcuttieae. In particular, seeds of Orcuttia species germinate underwater in January 

and February (Griggs, 1980; Griggs and Jain, 1983; Keeley, 1998), after being colonized by 

aquatic fungi (Griggs, 1980, 1981). This observation was supported by Keeley’s (1988) research, 

which indicated that fungicide inhibited germination of O. californica seeds, but did not affect 

Tuctoria greenei seeds. Detailed germination studies have not been conducted on all species, but 

cold treatment and other forms of stratification promoted germination in O. californica (Keeley,

1988), O. pilosa, and O. tenuis (Griggs 1974, as cited in Stone et al. 1988) and most likely 

benefit other Orcuttia species as well. 

Orcuttia plants grow underwater for 3 months or more and have evolved specific adaptations for 

aquatic growth (Keeley, 1998). Among these adaptations is the formation of the three different 

leaf types. The well-developed rosette of juvenile leaves is more specialized than those in 

Neostapfia or Tuctoria species, however (Keeley, 1998). The floating-leaf stage is unique to 

Orcuttia species; these leaves form as water in the pool warms and remain as long as the standing 

water lasts (Hoover, 1941; Griggs, 1980, 1981; Reeder, 1982; Keeley, 1998). Aquatic leaves of 

Orcuttia species also lack stomates, even though they are present on the juvenile leaves of both 

Neostapfia and Tuctoria (Keeley, 1998).

As soon as the pools dry, normally in June or July, Orcutt grasses begin producing their typical 

terrestrial leaves (Hoover, 1941; Griggs, 1980, 1981; Reeder, 1982; Keeley, 1998). 

Inflorescences appear within a few days after the water evaporates. June and July are the peak 

months of flower production for most species, although flowering may continue into August and 

September in years of above-normal precipitation (Griggs, 1980; 1981). Late-spring rains may 

prolong the flowering season (Griggs, 1981; Griggs and Jain, 1983), but inundation is more 

likely to kill flowering individuals (J. Silveira, 1997). Spikelets break apart and scatter their 

seeds when autumn rains arrive (Reeder, 1965; Crampton, 1976; Griggs, 1980; 1981).

Historical Information:

Prior to the surveys by Stone et al. (1988), hairy orcutt grass had been reported from 25 sites, 

primarily in the Northeastern Sacramento Valley and Southern Sierra Foothills Vernal Pool 

Regions (Keeler-Wolf et al., 1998). These included eight occurrences each in Tehama and 

Stanislaus Counties, six in Madera County, and two in Merced County (Hoover, 1941; 

Crampton, 1959; Reeder, 1982; Stone et al., 1988; California Natural Diversity Data Base,

2003). Hairy orcutt grass also was collected in the Solano-Colusa Vernal Pool Region, Glenn 

County, in 1937 (California Natural Diversity Data Base, 2003); the specimen has since been 

lost, but may have originally been misidentified as California Orcutt grass (Oswald and Silveira,

1995; J. Silveira pers. comm., 1997; J. Silveira, 2000).
2013 VGP and sVGP BE Appendix F

F-151

Conservation Status:

Within about the last decade, 10 new natural occurrences of hairy orcutt grass have been 

discovered: 5 in Madera County, 4 in Tehama County, and 1 in Stanislaus County (California 

Natural Diversity Data Base, 2005). Hairy orcutt grass also has been discovered in another pool 

at the Vina Plains Preserve in Tehama County (Alexander and Schlising, 1997); this pool may 

represent a separate occurrence or it may be an extension of California Natural Diversity Data 

Base Element Occurrence 25. In addition, this species has been introduced into a re-created pool 

in Madera County (Durgarian, 1995, Stebbins et al., 1995, California Natural Diversity Data 

Base, 2005).

Of the 39 Element Occurrences listed by the California Natural Diversity Data Base (2003), not 

counting the misidentified population of Orcuttia inaequalis previously mentioned, 27 natural 

occurrences and the introduced population are presumed to be extant (California Natural

Diversity Data Base, 2005). Currently, the main area of concentration for Orcuttia pilosa (9 

extant occurrences and 1 that is possibly extirpated) is the Vina Plains in Tehama County, which 

is in the Northeastern Sacramento Valley Vernal Pool Region. An isolated occurrence in central 

Butte County is in the same region. Eleven occurrences are in the Southern Sierra Foothills 

Vernal Pool Region, including nine in Madera County between the City of Madera and Millerton 

Lake, and two in eastern Stanislaus County. All six extant occurrences in the Solano-Colusa 

Vernal Pool Region are on the Sacramento National Wildlife Refuge in Glenn County (Stone et 

al., 1988; Keeler-Wolf et al., 1998; California Natural Diversity Data Base, 2005).

Summary of Major Threats:

Its dependence on vernal pools for survival, the changes to natural hydrology and habitat loss are 

this species' biggest threats (USFWS, 2005). The species is also threatened due to agriculture, 

urbanization, overgrazing, non-native plants and trampling.

F.6.34.

Plagiobothrys strictus

CALISTOGA ALLOCARYA

Family: Boraginaceae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q1HV)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc3218.pdf)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Plagiobothrys+st

rictus)

Description:

Calistoga allocarya, Plagiobothrys strictus, is an annual herb in the Boraginaceae (borage 

family). It can grow 10 to 40 cm (4 to 16 in.) tall from a single stem at the base. It has small, 

usually paired white flowers that appear in March-April in a slender, curved inflorescence.
2013 VGP and sVGP BE Appendix F

F-152

Geographic Boundaries and Spatial Distribution:

Calistoga allocarya occurs in alkaline sites near thermal springs at two extant sites on private 

land within a radius of 6 km (4 miles) of Calistoga in Napa County, California. The range extent 

covers a small area in Napa County, near Calistoga. The total range is only about 14 square 

miles.

Habitat: (no critical habitat)

The species inhabits pools and swales adjacent to and fed by hot springs and small geysers in 

grasslands between 90 and 160 m (300 to 500 ft.) in elevation. Calistoga allocarya grows in clay 

soils that are characterized by high boron, acidity, arsenic and sulfate concentrations. It is found 

in foothill grasslands, in mesic areas including vernal pools, next to and fed by hot springs and 

small 

Life History:

The fruit is an egg-shaped nutlet about 0.15 cm (0.06 in.) long, keeled on the back and covered 

with smooth, wart-like projections (California Department of Fish and Game, 2005a; Service,

2008a). Hot springs are part of the hydrologic requirements for its growth. 

Historical Information:

Historically, three populations of Calistoga allocarya were documented within a 3 km (2 mile) 

radius of Calistoga, Napa County, California. Prior to listing one population had been extirpated 

due to urbanization and agricultural land conversion (California Native Plant Society, 2008a). No 

plants were observed south of the former runway on the airport property during the 2005, 2008, 

and 2009 surveys even though it is assumed suitable habitat does exist there (Ecosystems West 

Consulting Group, 2009). In 2009, Calistoga allocarya was found in areas with sparse vegetation 

(cover less than 60 percent, occasionally 80 percent or more) and low surrounding vegetation 

(less than 1 foot high) (Ecosystems West Consulting Group, 2009).

Conservation Status:

Currently, there are two extant occurrences, both in Napa County, California. The most recent 

surveys for the species on the former Calistoga glider airport property (airport property) were 

conducted during spring 2009 by EcoSystems West Consulting Group and by WRA 

Environmental Consultants. The most recent visit to the second locality, Myrtledale Hot Springs, 

which is also near the City of Calistoga in Napa County was in 2007 (CNDDB, 2009b). The 

estimated number of Calistoga allocarya plants on the airport property for 2008 was 6,250. The 

2009 plant surveys estimate the 26 colonies have 3,310 to 5,000 Calistoga allocarya plants 

occupying this property (EcoSystems West Consulting Group, 2009). The other population of 

Calistoga allocarya is scattered over 4 hectares (10 acres) bisected by an asphalt road on the 

private property with the barn. The number of individuals in this population has fluctuated 

between 100 and 10,000 plants. During one observation in 2009, Mr. Rugyt estimated 

approximately several hundred plants were present on this property (Rugyt, pers. comm. 2009). 

In recent years, access to the site has been unavailable, and so the current size of this population 

is unknown.
2013 VGP and sVGP BE Appendix F

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Summary of Major Threats:

When Calistoga allocarya was listed as endangered in 1997, the threats to its survival and 

recovery included airport activities, development, potential alteration of hot springs hydrology, 

restricted range and number and size of populations, and inadequate existing regulatory 

mechanisms. Currently, the species is still threatened by potential habitat loss due to 

development, potential alteration of hot springs hydrology, restricted range and number and size 

of populations, and inadequate existing regulatory mechanisms. In addition, other factors, such 

as climate change and competition from weedy invasive plants may be adversely affecting the 

species and are considered threats to their survival.

F.6.35.

Poa napensis

NAPA BLUEGRASS

Family: Poaceae

Endangered: wherever found

Sources:

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc3218.pdf)

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q1ID)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Poa+napensis)

Description:

Napa bluegrass, Poa napensis, grows 30 to 100 centimeters (12 to 39.4 inches) tall and is an 

erect, tufted perennial bunch grass. Longer basal leaves grow to about 20.3 cm (8 in.) long, with 

upper leaves that are about 15.2 cm (6 in.). 

Geographic Boundaries and Spatial Distribution:

Napa bluegrass occur in alkaline sites near thermal springs at two extant sites on private land 

within a radius of 6 km (4 miles) of Calistoga in Napa County, California. It is known only from 

a small area in Napa County, near Calistoga. The entire range encompasses no more than 3 

square miles.

Habitat: (no critical habitat)

Its habitat includes Geyser and hot spring fed moist meadows at 100-120 m elevation. Soils are 

clay or gravelly-clay loams with high concentrations of boron and sulfates. It is found in foothill 

grasslands, in mesic areas including vernal pools, next to and fed by hot springs and small 

geysers (California Department of Fish and Game, 2005b; Service, 2008b).

Life History:

A few erect flowering stems appear in May and grow as much as 69 cm (27 in.) in height. Pale 

green to purple flowers bloom in condensed, round-shaped clusters at the end of the few 

flowering stems.
2013 VGP and sVGP BE Appendix F

F-154

Historical Information:

At the time of listing, Napa bluegrass was only known from two populations in the vicinity of 

Calistoga (California Native Plant Society 2008b). A 2008 survey conducted by Glenn Lukos 

Associates identified approximately 520 Napa bluegrass plants at 26 locations on the airport 

property. A March 9, 2009 EcoSystems West Consulting Group survey identified 244 individual 

Napa bluegrass plants at 31 locations on the airport property (WRA, 2009). The second 

population of Napa bluegrass is scattered over a 4 hectare (10 acre) area bisected by an asphalt 

road on private land in Calistoga. In recent years, the landowner has denied access to the site, 

and no current information on the size of this population is available (Symonds, pers. comm. 

2008).

Conservation Status:

The species is known only from hot springs-influenced habitats in a tiny area near Calistoga, 

California. The species' habitat has been reduced by health spa and resort development. Two 

small populations remain; one is located on airport property, where it is threatened by grass 

mowing and vehicle parking. Both populations are limited to private land (California Native 

Plant Society, 2008b; Service, 2008b). The airport property was most recently surveyed for Napa 

bluegrass during the blooming period in March 2009 (WRA, 2009). Historically, the range of 

this plant has been diminished by the development of recreational hot springs and the growth of 

the town of Calistoga (Service, 1997). Currently neither property is being developed. The airport 

property remains vacant and the second property contains an abandoned house and barn structure 

which seem vacant as well (Kasparian, pers. obs. 2008).

Summary of Major Threats:

When Napa bluegrass was listed as endangered in 1997, the threats to its survival and recovery 

included airport activities, development, potential alteration of hot springs hydrology, restricted 

range and number and size of populations, and inadequate existing regulatory mechanisms. 

Currently, the species is still threatened by potential habitat loss due to development, potential 

alteration of hot springs hydrology, restricted range and number and size of populations, and 

inadequate existing regulatory mechanisms. In addition, other factors, such as climate change 

and competition from weedy invasive plants may be adversely affecting the species and are 

considered threats to their survival.

F.6.36.

Rana draytonii

CALIFORNIA RED-LEGGED FROG

Family: Ranidae

Threatened: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=D02D)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Rana+draytonii)

• Goals Project, 2000. (http://www.sfestuary.org/pdfs/speciescommunity/Species_and_Community_Profiles%5BPart1%5D.pdf)
2013 VGP and sVGP BE Appendix F

F-155

• 75 FR 12816 (http://www.gpo.gov/fdsys/pkg/FR-2010-03-17/pdf/2010-

4656.pdf#page=1)

Description:

The California red-legged frog (Family: Ranidae) is a large (85-138 mm) brown to reddish 

brown frog with prominent dorsolateral folds and diffuse moderate sized dark brown to black 

spots that sometimes have light centers (Storer, 1925, Jennings and Hayes, 1994a).

Geographic Boundaries and Spatial Distribution:

Native historical range extended from southern Mendocino County in northwestern California 

south (primarily west of the Cascade-Sierra crest) to northwestern Baja California (Shaffer et al. 

2004) (8,000-1,000,000 square miles). Historical populations on the floor of the Central Valley 

may not have persisted due to extensive natural flooding (Fellers, in Lannoo 2005). The current 

range is now much reduced in the Sierra Nevada and in southern California, but the species is 

still present throughout much of its former range in the central California coast range (Fellers, in 

Lannoo 2005). This species has been introduced in a few places in Nevada, but the current status 

of those populations is uncertain (A. Cook, cited by Fellers, in Lannoo 2005). Rana draytonii is 

still present in Baja California, Mexico (USFWS, 2000, Grismer, 2002, Shaffer et al., 2004). The 

elevational range extended from sea level to about 1,500 meters (5,000 feet); usually below 

1,200 meters (3,935 feet). 

Habitat: (has critical habitat)

Although California red-legged frogs can occur in ephemeral or artificially-created ponds devoid 

of vegetation, the habitats that have been observed to have the largest frog populations are 

perennial, deep (>0.7 m) water pools bordered by dense, shrubby riparian vegetation (Jennings,

1988, Hayes and Jennings, 1986). This dense riparian vegetation is characterized by arroyo 

willows (Salix lasiolepis) intermixed with an understory of cattails (Typha sp.), tules (Scirpus 

sp.), or bulrushes (Scirpus sp.) (Jennings, 1988).

On April 16, 2010, approximately 1,636,609 acres of critical habitat in 27 California counties 

were designated for California red-legged frog.

The California red-legged frog’s PCEs are: (1) standing bodies of fresh water (with salinities less 

than 4.5 ppt) for aquatic breeding habitat, including natural and manmade (e.g., stock) ponds, 

slow-moving streams or pools within streams, and other ephemeral or permanent water bodies 

that typically become inundated during winter rains and hold water for a minimum of 20 weeks 

in all but the driest of years; (2) freshwater pond and stream habitats, as described above, for 

non-breeding habitat, that provide for shelter, foraging, predator avoidance, and aquatic dispersal 

of juvenile and adult California red-legged frogs, including, but are not limited to plunge pools 

within intermittent creeks, seeps, quiet water refugia within streams during high water flows, and 

springs of sufficient flow to withstand short-term dry periods; (3) upland areas adjacent to or 

surrounding breeding and non-breeding aquatic and riparian habitat up to a distance of 1 mi (1.6 

km) in most cases (i.e., depending on surrounding landscape and dispersal barriers) including 

various vegetational types such as grassland, woodland, forest, wetland, or riparian areas that 

provide shelter, forage, and predator avoidance for the California red-legged frog, maintaining 

the hydrologic, geographic, topographic, ecological, and edaphic features that support and 
2013 VGP and sVGP BE Appendix F

F-156

surround the aquatic, wetland, or riparian habitat; (4) accessible upland or riparian habitat within 

and between occupied or previously occupied sites that are located within 1 mi (1.6 km) of each 

other, and that support movement between such sites as dispersal habitat, including various 

natural habitats, and altered habitats such as agricultural fields, that do not contain barriers (e.g., 

heavily traveled roads without bridges or culverts) to dispersal.

Life History:

Adults generally reach sexual maturity in their second year for males and third year for females 

(Jennings and Hayes, 1985), although sexual maturity may be reached earlier during years of 

abundant food resources (Jennings, unpubl. data). During extended periods of drought, frogs may 

take 3-4 years to reach maturity (Jennings and Hayes, 1994a). Reproduction generally occurs at 

night in permanent ponds or the slack water pools of streams during the winter and early spring 

(late November-through April) after the onset of warm rains (Storer, 1925; Hayes and Jennings 

1988; Jennings and Hayes, 1994a). 

Egg masses are normally laid at the surface of the water (Livezey and Wright, 1947). California 

red-legged frogs are explosive breeders, usually depositing their egg masses within 3-4 week 

period after large rainfall events (Hayes and Miyamoto, 1984). After reproduction, males usually 

remain at the breeding sites for several weeks before removing to foraging habitats, while 

females immediately remove to these foraging habitats (Jennings, unpubl. data). There is no 

evidence of double clutching with this species (Jennings, unpubl. data).

Eggs hatch after 6-14 days (depending on the prevailing water temperature), and the resulting 

larvae (8.8-10.3 mm total length) require 3.5-7 months to attain metamorphosis at 65-85 mm 

total length (Storer 1925; Jennings, unpubl. data). Larvae, which are solitary and almost never 

overwinter, typically metamorphose between July and September (Storer 1925, Jennings and 

Hayes 1994a). Juvenile frogs are 25-30 mm total length at metamorphosis and commonly sun 

themselves during the day at the edge of the riparian zone next to the breeding site. As they 

grow, they gradually shift from diurnal and nocturnal periods of activity, to largely nocturnal 

activity (Hayes and Tennant, 1986). During periods of rainfall, both juveniles and a few adults 

may disperse away from breeding sites and may be found some distance (up to 0.8 km) away 

from the nearest water (Jennings, unpubl. data). Along the lower reaches of streams on the 

Central Coast of California which tend to almost completely dry up during the late summer, 

subadult and adult frogs have been found to occupy small mammal burrows under leaf litter or 

dense vegetation in the riparian zone (Rathbun et al., 1993). These frogs make overland trips 

every few days or so to isolated stream pools to rehydrate themselves although one frog 

remained in riparian habitat for 77 days (Rathbun in litt. 1994 as cited in Miller et al., 1996). 

Based on these observations, frogs found in coastal drainages appear to be rarely inactive, 

whereas those found in interior sites probably hibernate (Storer, 1925). Based on limited field 

data, California red-legged frogs appear to live about 8-10 years in the wild (Jennings, unpubl. 

data).

Larvae are thought to be algal grazers (Storer, 1925), but the feeding ecology of larval California 

red-legged frogs is unknown. Juvenile and adult frogs have a highly variable animal food diet 

that includes: Amphipods, Isopods, Orthoptera, Isoptera, Hemiptera, Homoptera, Neuroptera, 

Coleoptera, Lepidoptera, Diptera, Hymenoptera, Arachnids, Gastropoda, small fishes, 

amphibians, and small mammals (Stebbins, 1972; Hayes and Tennant, 1985; Baldwin and 
2013 VGP and sVGP BE Appendix F

F-157

Stanford, 1987). Most prey that can be swallowed that is not distasteful are eaten, with larger 

frogs capable of taking larger prey (Jennings and Hayes, 1994a). Small red-legged frogs, Pacific 

treefrogs (Hyla regilla), and California mice (Peromyscus californicus) may contribute 

significantly to the diet of subadults and adults (Arnold and Halliday, 1986, Hayes and Tennant,

1985).

Historical Information:

Historically, California red-legged frogs were found throughout the Pacific slope drainages from 

the vicinity of Redding, Shasta County (Storer, 1925), inland and at least to Point Reyes, Marin 

County (Hayes and Kremples, 1986), California (coastally) southward to the Santo Domingo 

River drainage in Baja California, Mexico (Linsdale, 1932). They also historically occurred in a 

few desert slope drainages in southern California (Jennings and Hayes, 1994b). California redlegged frogs generally occurred below 1370 m in the Sierra Nevada foothills (Jennings, 1996) 

and 1520 m in southern California, although some of the populations toward the upper limit of 

the range of this frog may represent translocations (Jennings and Hayes, 1994a). 

In the Bay Area, this frog was historically abundant enough to support an important commercial 

fishery just before the turn of the century (Jennings and Hayes, 1985) and up to the 1950s it was 

still considered to be present in much of the San Francisco Bay region (Stebbins, 1959). 

However, earlier overexploitation, subsequent habitat loss from agriculture and urbanization, and 

the introduction of exotic aquatic predators have presently reduced red-legged frog distribution 

to scattered locations in the foothills and mountains of the San Francisco Bay region (Jennings, 

unpubl. data). 

In 1993, the California red-legged frog was petitioned for listing as an endangered species by the 

U.S. Fish and Wildlife Service (Sorensen, 1993) based on a significant range reduction and 

continued threats to surviving populations (Miller, 1994). The frog was subsequently listed as 

Threatened by the U.S. Fish and Wildlife Service (Miller et al., 1996).

Conservation Status:

Based on the data presented in Jennings and Hayes (1994a; 1994b), California red-legged frogs 

appear to have disappeared from approximately 70-75%, of their historic range in the state 

(Miller et al., 1996). This frog is most affected by land use patterns and other anthropogenic 

events which fragment high quality habitat and create environments unsuitable for the continued 

survival of the species (Jennings and Hayes, 1994a; 1994b). 

Summary of Major Threats:

Factors contributing to local declines include wetland destruction and degradation/fragmentation, 

urbanization, residential development, reservoir construction, stream channelization, livestock 

grazing of riparian vegetation, off-road vehicle activity, drought, overharvesting, and exotic 

fishes (bass, mosquitofish) and possibly bullfrogs (Kiesecker and Blaustein, 1988, 1998; 

USFWS, 1994, 1996, 2000; Adams, 1999, 2000; Lawler et al., 1999; Cook and Jennings, 2001; 

Kiesecker, Blaustein and Miller, 2001a; Cook 2002). Conversion of habitat to more permanent 

ponds is an important threat (as this allows breeding waters to be invaded by non-native 

predators). Habitat characteristics and good leaping ability may render the frog less vulnerable to 
2013 VGP and sVGP BE Appendix F

F-158

bullfrog predation (Pearl et al., 2004). McAllister and Leonard (in Jones et al., 2005) noted that 

in many areas red-legged frogs coexist with bullfrogs.

Declines in the red-legged frog complex (including Rana draytonii) also have been attributed to 

global warming, UV-B radiation (Belden and Blaustein, 2002), airborne contaminants (pesticide 

drift), and disease (see Davidson et al., 2001). Davidson et al. (2002) found support for the 

negative impact of wind-borne agrochemicals and weaker evidence for the widespread impact of 

habitat destruction and UV-B radiation; evidence did not support the hypothesis that declines 

have been caused by climate change.

F.6.37.

Reithrodontomys raviventris

SALT MARSH HARVEST MOUSE

Family: Muridae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=A03Y)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Reithrodontomy

s+raviventris)

• Goals Project, 2000 (http://www.sfestuary.org/pdfs/speciescommunity/Species_and_Community_Profiles%5BPart1%5D.pdf)

Description:

Salt marsh harvest mice are small rodents with dark ears and a long, indistinctly bicolored tail; 

most individuals have tufts of ochraceous hairs at the anterior bases of the ears. They range in 

total length from 118 to 175 mm and in weight from 8 to 14 g.

Geographic Boundaries and Spatial Distribution:

Salt marsh harvest mice are endemic to the salt marshes of the San Francisco Bay system (San 

Francisco, San Pablo, and Suisun bays) in central California (Shellhammer, 1982). The salt 

marsh harvest mouse is composed of two subspecies. The northern subspecies, Reithrodontomys 

raviventris haliocoetes, is found on the upper portions of the Marin Peninsula; in the Petaluma, 

Napa and Suisun marshes; as well as a disjunct series of populations on the northern Contra 

Costa County coast. The southern subspecies, Reithrodontomys raviventris raviventris, is found 

in the more highly developed portions of the Bay from the Richmond area, down around the 

South San Francisco Bay (primarily south of a line between Redwood City and Hayward), and a 

disjunct series of small populations on the Marin Peninsula. 

Habitat: (no critical habitat)

The species is dependent on the thick, perennial cover of salt marshes and move in the adjacent 

grasslands only in the spring and summer when the grasslands provide maximum cover (Fisler 

1965). Their preferred habitats are the middle and upper portions of those marshes (i.e. the 
2013 VGP and sVGP BE Appendix F

F-159

pickleweed (Salicornia virginica) and peripheral halophyte zones) and similar vegetation in 

diked wetlands adjacent to the Bay (Shellhammer et al., 1982; 1988). 

Life History:

Salt marsh harvest mice are vegetarians that can drink water ranging from moderately saline to 

sea water. They swim calmly and well. They do not burrow, but will build ball-like nests of dry 

grasses and other vegetation on the ground or up in the pickleweed (Fisler, 1965). The average 

litter size is 3.7-4.0 young and there may be only a single litter per year in Reithrodontomys 

raviventris haliocoetes (breeds May-November) but multiple litters Reithrodontomys raviventris 

raviventris (breeds March-November). They are primarily nocturnal but sometimes active during 

the day.

Historical Information:

The former, probably more or less continuous historical distribution has been fragmented, 

leaving harvest mouse populations restricted to discontinuous patches of suitable habitat. About 

84% of historical tidal marshes of the San Francisco Bay area have been destroyed. Over 3,600 

acres of habitat have been filled or degraded since the 1970s. Since 1982, hundreds of acres of 

nontidal salt marsh in the South Bay have been diced and the damage continued into at least 

1989 (California DF&G, 1990).

Conservation Status:

Salt marsh harvest mice have disappeared from many marshes and are present in very low 

numbers in most others. The highest consistent populations are found in relatively large marshes 

along the eastern edge of San Pablo Bay and in old dredge spoil disposal ponds on former Mare 

Island Shipyard property; most of these marshes are in or will be included in the San Pablo Bay 

unit of the San Francisco Bay National Wildlife Refuge (Bias and Morrison, 1993, Duke et al.

1995). Other areas supporting large populations include some parts of the Contra Costa County 

coastline (Duke et al., 1990, 1991), some parts of the Petaluma Marshes, and the Calaveras Point 

Marsh in the South San Francisco Bay (Duke et al., 1990), although the latter area is 

deteriorating because of the declining salinity and correlated changes in vegetation. USFWS 

(1990) categorized the status of this species as "declining."

Summary of Major Threats:

The major threats to their habitat include filling, diking, subsidence, and changes in water 

salinity (Shellhammer, 1982, 1989). Various estimates have been made that at least 75% of all 

the tidal marshes around the Bay have been filled in or otherwise destroyed over the last 150 

years. Most of the remaining marshes have been back-filled or diked-off, and hence most of the 

remaining tidal marshes are narrow strips along the bay side of the levees. Those strip marshes 

and most of the remaining larger marshes have lost their upper and part of their middle zones, 

such that there is little escape cover from high tides available. In the southern end of the South 

San Francisco Bay, the combination of subsidence caused by water drawdown and the freshening 

of that part of the Bay by massive amounts of non-saline, treated sewage effluent has changed 

the saline vegetation of that area to brackish and freshwater species such as bulrushes, cattails, 

and peppergrass, plants not used by the species (Duke et al. 1990; Shellhammer 1982, 1989).
2013 VGP and sVGP BE Appendix F

F-160

F.6.38.

Syncaris pacifica

CALIFORNIA FRESHWATER SHRIMP

Family: Atyidae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=K01W)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Syncaris+pacific

a)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc3890.pdf)

Description:

The California freshwater shrimp is a decapod crustacean of the family Atyidae and is believed 

to be the only extant species of the genus. They are generally less than 50 millimeters (2.17 

inches) (Eng, 1981) in postorbital length (from eye orbit to tip of tail). Females are generally 

larger than males by the time they reach sexual maturity, at the end of the second summer. 

Juveniles and males typically appear translucent to nearly transparent while mature females are 

often brown with a tan dorsal stripe. The California freshwater shrimp is readily distinguished 

from other shrimp species that occur in California by the family characteristics of terminal tufts 

of setae (hair-like structures) on the chelae (claws) of the first and second pereiopods (walking 

legs) (Hedgpeth, 1975). In addition, they have a supraorbital spine (small spine on the carapace 

(backshield) above the eye), a long-slender rostrum, and exopods (oar like outer branches of the 

thoracid legs) on all pereiopods except the last pair. 

Geographic Boundaries and Spatial Distribution:

The species is restricted to a few coastal streams in Marin, Sonoma, and Napa Counties in 

California. They are found in low elevation, low gradient, freshwater, perennial streams.

Habitat: (no critical habitat)

During the winter, habitat includes shallow margins of stream pools containing undercut banks 

and exposed living fine-root material that provide shelter and refuge from high water velocities 

associated with winter storm events. During the summer months, California freshwater shrimp 

are often associated with submerged leafy branches. It is believed both winter and summer 

habitat components need to be found in close proximity in order for this species to persist for 

prolonged periods. California freshwater shrimp have not been found in salt or brackish water 

and are not known to inhabit intertidal or estuarine areas (Born, 1968).

Life History:

The reproductive ecology of the California freshwater shrimp has not been formally described. 

Reproduction seems to occur once a year. Based on the reproductive physiology and behavior of 

other marine and freshwater shrimps, the male probably transfers and fixes a sperm sac to the 

female immediately after her last molt, before autumn. Courtship and mating behavior have not 

been described. The timing of mating has been deduced from the presence of egg bearing 

females starting in September (Born, 1968; Eng, 1981). By November, Serpa (1991) noticed that 
2013 VGP and sVGP BE Appendix F

F-161

most adult females in Huichica Creek bear eggs. Adult females produce relatively few eggs,

generally, 50 to 120 (Hedgpeth, 1968; Eng, 1981). The eggs adhere to the pleopods (swimming 

legs on the abdomen) where they are protected and cared for during the winter incubation. 

Young are released in May or early June and are approximately 6 millimeters (0.24 inch) in 

length (Eng, 1981). No information is available on the percentage of larvae that reach 

reproductive maturity.

Newly hatched young (post larvae) grow rapidly and reach 19 millimeters (0.75 inch) in length 

by early autumn of their first year (Eng, 1981). Growth slows through the fall, winter, and early 

spring, and then increases through the second summer (Messer and Brumbaugh, 1989). A size 

difference between males and females is apparent at the end of the second summer (Messer and 

Brumbaugh, 1989). Larger female size is consistent with characteristics of other freshwater 

shrimp (Neilsen and Reynolds, 1977). California freshwater shrimp reach sexual maturity by the 

end of their second summer of growth (Eng, 1981).and may live longer than 3 years (Eng, 1981).

Historical Information:

At the time the California freshwater shrimp was listed (Service, 1988), 12 streams were known 

to support populations and four streams once known to support the populations were believed to 

have been extirpated. A population was rediscovered in Stemple Creek by the time the recovery 

plan was issued (Service, 1998). According to Hedgpeth (1968), Atascadero Creek and Laguna 

de Santa Rosa, two streams cited as being extirpated at the time of listing, supported small and 

sporadic populations that may not occur there every year, but may be a result of infrequent 

migrations from connecting streams. Extant populations are now known from tributaries to these 

two streams, Jonive Creek and Blucher Creek, respectively. Despite surveys over the past 35 

years, California freshwater shrimp have not been rediscovered in Santa Rosa Creek since the 

1960s and are now believed to be extirpated (B. Cox, personnel communication 2011).

Conservation Status:

The majority of recent survey information on the California freshwater shrimp is the result of 

independent surveys for various projects. These surveys have resulted in an increase in the 

number of streams known to support populations of the species, but do not represent a uniform 

effort to examine the current spatial distribution throughout its range. In addition to the 17 

streams noted in the recovery plan (Service 1998), the species is now known from Bud Creek 

(Serpa, 2004), Fallon Creek, Franz Creek , Ebabias Creek, an unnamed tributary of Huichica 

Creek (CNDDB, 2011), and Cheda Creek (Fong, 2004). Of these new streams, Ebabias and 

Franz creeks are most significant because they are within watersheds that are relatively 

disconnected from other streams known to support the species.

Long term population trends are only available for the Lagunitas and Olema creek populations. 

The number of individual California freshwater shrimp collected at six sites in Lagunitas creek 

increased from approximately 1,878 in 1991 to approximately 4,407 in 2000 (Serpa, 2002). The 

increased numbers followed an increase in the amount of available habitat in 1997. Continuing 

changes in the stream’s morphology resulted in increased water flows that have improved and/or 

increased habitat conditions in some areas, but worsened and/or decreased habitat in other areas. 

Although the species has been found in 11 additional streams since it was listed in 1988, they 

may be rare in some of these newly discovered streams or the additional stream is tributary to an 
2013 VGP and sVGP BE Appendix F

F-162

already known population and represents only a slight increase in the distribution of the species 

within the watershed. For example, fewer than 10 individuals were captured in Olema Creek, all 

within 0.6 mile (1.0 kilometer) of its confluence with Lagunitas Creek, during surveys conducted 

in six of eight years from 1996 to 2004 (Martin et al., 2009), and only one shrimp was collected 

from Cheda Creek in 2002, and none were detected during subsequent survey efforts (Fong 

2004).

Summary of Major Threats:

Although the known distribution of the California freshwater shrimp has expanded from 

12 streams to 23 streams since the species was listed, eight of the eleven newly discovered 

streams do not represent new populations, but rather the discovery California freshwater shrimp 

in tributaries to already known populations. In addition, the stability of the species in a few 

occupied streams is questionable. Primary threats to the species continue to be degradation and 

loss of habitat as a result of increased urbanization (i.e., water diversion, urban runoff, loss of 

riparian vegetation, and bank stabilization), agricultural development and inappropriate grazing 

practices (i.e., loss of riparian vegetation, reduced water quality from manure runoff, water 

diversion, and increased sedimentation), pollutants and contaminants, and water development 

(i.e., barriers to migration, conversion of glide to pool habitat, introduced predators, altered 

hydrology, and reduced stream flows).

F.6.39.

Thamnophis gigas

GIANT GARTER SNAKE

Family: Colubridae

Threatened: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=C057)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Thamnophis+gig

as)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc778.pdf)

Description:

Thamnophis gigas is one of the largest garter snakes, reaching a total length of at least 162 cm 

(see USFWS, 1993). Its dorsal background coloration varies from brownish to olive, with a 

checkered pattern of black spots separated by a yellow dorsal stripe and two pale lateral stripes. 

The prominence of checkered pattern and stripes varies geographically and individually; stripes 

tend to be most pronounced in individuals from the northern Sacramento Valley; venter is cream 

to olive or brown, sometimes infused with orange, especially in northern populations; 

Geographic Boundaries and Spatial Distribution:

Extant populations are distributed in portions of the rice production zones of Sacramento, Sutter, 

Butte, Colusa, and Glenn Counties in California Its range is about 2,000-8,000 square miles.
2013 VGP and sVGP BE Appendix F

F-163

Habitat: (no critical habitat)

Habitat of this highly aquatic species includes primarily marshes and sloughs, sometimes lowgradient streams, ponds, and small lakes, with cattails, bulrushes, willows, or other emergent or 

water-edge vegetation usually present and used for basking and cover (California Department of 

Fish and Game, 1990, USFWS, 1993, Rossman et al., 1996, Stebbins, 2003). Because of the 

direct loss of natural habitat, this snake now relies heavily on rice fields in the Sacramento 

Valley, but it also uses managed marsh areas in various national wildlife refuges and state 

wildlife areas (USFWS, 1999). Essential habitat components consist of: (1) adequate water 

during the snake's active season (early spring through mid-fall) to provide adequate permanent 

water to maintain dense populations of food organisms; (2) emergent, herbaceous wetland 

vegetation, such as cattails and bulrushes, for escape cover and foraging habitat during the active 

season; (3) upland habitat with grassy banks and openings in waterside vegetation for basking; 

and (4) higher elevation upland habitats for cover and refuge from flood waters during the 

snake's inactive season in the winter (from USFWS, 1999).

The giant gartersnake is absent from large rivers and other waters with populations of large, 

introduced, predatory fishes, and from wetlands with sand, gravel, or rock substrates (see 

USFWS, 1993). Riparian woodlands do not provide suitable habitat because of excessive shade 

and inadequate prey resources (Hansen).

Life History:

The species is most active during daylight (Biosystems Analysis, Inc., 1989). They are dormant 

from about November to mid-March (Hansen, cited by USFWS, 1993). The garter snake is 

viviparous with mating occurring in March-April. The litter size is 10-46 (average 23) (Herp. 

Rev. 21:93-94). Males are sexually mature in average of 3 years and females in average of 5 

years (Hansen, cited by USFWS, 1993).

Historical Information:

Historically the range included much of the floor of the Central Valley (Sacramento and San 

Joaquin valleys) of California, from Butte County in the north to Kern County in the south, at 

elevations from near sea level to 122 m (Rossman et al., 1996; Ernst and Ernst, 2003; Stebbins,

2003). The species apparently is now extirpated from most of the range in the San Joaquin 

Valley (Rossman et al., 1996; USFWS, 1993; Stebbins, 2003).

Conservation Status:

As of 1992, there were 13 known populations as follows (population = cluster of locality records 

in a contiguous habitat): (1) Butte Basin, (2) Colusa Basin, (3) Sutter Basin, (4) American Basin, 

(5) Yolo Basin-Willow Slough, (6) Yolo Basin-Liberty Farms, (7) Sacramento Basin, (8) Badger 

Creek-Willow Creek, (9) Caldoni Marsh, (10) East Stockton-Diverting Canal and Duck Creek, 

(11) North and South Grasslands (possibly extirpated), (12) Mendota (possibly extirpated), and 

(13) Burrell-Lanare (probably extirpated) (USFWS, 1993). These population largely coincide 

with historical riverine flood basins and tributary streams. Populations 1-4 are associated with 

rice production zones; populations 5-13 mainly are in small, isolated patches of valley floor 

habitat.
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Summary of Major Threats:

Loss and fragmentation of wetland habitats have extirpated the giant garter snake from the 

majority of its historical range (USFWS, 1999). Loss and degradation of habitat remain the 

greatest threat to the survival of the species (USFWS, 1999). Activities that may degrade habitat 

include maintenance of flood control and agricultural waterways, weed abatement, rodent 

control, discharge of contaminants into wetlands and waterways, and overgrazing in wetland or 

streamside habitats. Factors that may be significant in some areas include predation by and 

competition with introduced species, parasitism, and road kills (USFWS, 1999, Carpenter et al.,

2002).

USFWS (1993) listed threats as habitat loss (e.g., through large-scale urbanization in the 

American Basin, dewatering of habitat through water diversions and impoundments), flooding 

(in rice production areas), contaminants (e.g., selenium and salinity in North and South 

Grassland areas), agricultural and vegetation maintenance activities (e.g., on levees and canal 

borders), vehicular traffic (on levees and roads along canals), livestock grazing, and introduced 

predators (e.g., house cats, bullfrogs, perhaps bass). 

F.6.40.

Tuctoria mucronata

SOLANO GRASS

Family: Poaceae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q23L)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Tuctoria+mucro

nata)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc2398.pdf)

• 70 FR 46924 (http://www.gpo.gov/fdsys/pkg/FR-2005-08-11/pdf/05-15569.pdf#page=1)

• 71 FR 7118 (http://www.gpo.gov/fdsys/pkg/FR-2006-02-10/pdf/06-1080.pdf#page=1)

Description:

Solano grass, also known as Crampton’s tuctoria, is a member of a small tribe (three genera and 

nine species) of semi-aquatic annual grasses that are unique among grasses in exhibiting singlecell C4 photosynthesis, which occurs in only 0.003 percent of known species of C4 flowering 

plants (Boykin et al., 2008). Plants with C4 photosynthesis utilize a more complex biochemical 

process than most plants (with C3 photosynthesis) in converting CO2 to energy, which increases 

photosynthetic efficiency at low CO2 concentrations (Boykin et al., 2008). 

Solano grass is a small (1 to 8 in. tall) grass. It produces stems and leaves covered with small 

droplets of a sticky, acrid secretion. This is characteristic of the genus Tuctoria. Solano grass is 

grayish-green, pilose (hairy), and viscid. It has several solid stems (up to 4.7 inches long) that do 

not branch and grow somewhat decumbently (lying on the ground), turning up only at the tips. 
2013 VGP and sVGP BE Appendix F

F-165

The leaves lack ligules, which are the small, scalelike leaf outgrowths found on some grasses. 

Solano grass blooms from June to July. Seven to 19 spikelets overlap one another along the full 

length of the spike-like inflorescence. Unlike other closely related species, the inflorescence of 

Solano grass remains partially enclosed by the upper leaf sheath and is never fully exerted from 

the uppermost leaf. The lemma (bract) ends in a single tooth with a short, narrow point (Service 

2005).

Geographic Boundaries and Spatial Distribution:

The species is endemic to California, known only from Olcott Lake and vicinity. It is known 

from only 3 vernal pools in Solano and Yolo counties, California. The number of plants varies 

greatly at each pool from year-to-year. 

No plants have been seen since 1993 at the type locale. At a second site the number of observed 

individuals has varied from a single plant to about 150. The third site, discovered in 1993 on 

what was then Department of Defense land, was observed to have several thousand plants in 

2000 (Sacramento Fish and Wildlife Endangered Species Program, 2003). This is the only large 

population known. The site is being transferred to the Yolo County Parks Department.

Nation: United States

Habitat: (has critical habitat)

Solano grass is known only from the Northern Claypan type of vernal pool (Sawyer and KeelerWolf 1995) within annual grassland habitat within Solano and Yolo Counties (CNDDB, 2009). 

The pools where the species occurs are characterized by turbid water quality caused by 

suspended clay sediments from the “lake” bed (Holland 1987). In Solano County, the pools are 

essentially alkaline playa pools or intermittent lakes (Crampton, 1959), while the pools at the 

Yolo County site are smaller, although they have the characteristic saline-alkali soil chemistry 

that is diagnostic of alkali vernal pools (ESA, 2008). However, location of the species at the 

Davis Communications Annex may suggest that the species is not restricted solely to large 

playatype pools, as the features there include a disturbed swale on pescadero clay loam (J. 

Gerlach, in litt., 2007).

Critical habitat for Solano grass and several other vernal pool species was designated on August 

11, 2005. The final designation of critical habitat for Solano grass is 440 acres.

The PCEs of critical habitat for Solano grass are the habitat components that provide: (1) 

topographic features characterized by isolated mound and intermound complex within a matrix 

of surrounding uplands that result in continuously, or intermittently, flowing surface water in the 

depressional features including swales connecting pools, providing for dispersal and promoting 

hydroperiods of adequate length in the pools; (2) depressional features including isolated vernal 

pools with underlying restrictive soil layers that become inundated during winter rains and that 

continuously hold water or whose soils are saturated for a period long enough to promote 

germination, flowering, and seed production of predominantly annual native wetland species and 

typically exclude both native and nonnative upland plant species in all but the driest years. As 

these features are inundated on a seasonal basis, they do not promote the development of obligate 

wetland vegetation habitats typical of permanently flooded emergent wetlands.
2013 VGP and sVGP BE Appendix F

F-166

Life History:

Many life history characteristics are common to all members of the Orcuttieae. In particular, they 

are all annuals and are all endemic to vernal pools (Griggs, 1981). All are wind-pollinated, but 

pollen probably is not carried long distances between populations (Griggs, 1980; Griggs and 

Jain, 1983) and pollination may be limiting for small populations (Stephens et al., 1999; Davis et 

al., 2004; Taylor et al., 2004). Local seed dispersal is by water, which breaks up the 

inflorescences (Reeder, 1965; Crampton, 1976; Griggs, 1980, 1981). Long-distance dispersal is 

unlikely (Service, 1985), but seed may be carried occasionally by waterfowl, or by tule elk, or 

pronghorn in historical times (Griggs, 1980). 

The seeds can remain dormant for an undetermined length of time (but at least 3 to 4 years) and 

germinate underwater after they have been immersed for prolonged periods (Crampton, 1976; 

Griggs, 1980; Keeley, 1998). Unlike typical terrestrial grasses that grow in the uplands 

surrounding vernal pools, members of the Orcuttieae flower during the summer months (Keeley,

1998).

Historical Information:

At the time of listing (1978), the Solano grass was only known from Olcott Lake, a large 

(approximately one square mile) alkaline vernal lakebed 12 miles south of Dixon in Solano 

County (43 FR 44810). The species was not observed at Olcott Lake from 1976 to 1981, when it 

reappeared, suggesting that seeds may remain viable for at least 5 years in situ (Holland, 1987). 

The occurrence was last seen at Olcott Lake in 1993, when four individual plants were 

documented. The site has been surveyed since then to census rare vernal pools plants, most 

recently in 2007, when no individuals of Solano grass were found (C. Witham, pers. comm. 

2007). This species occurrence is considered to be extirpated (CNDDB, 2009).

Conservation Status:

Population sizes for this species, as with other species in the Orcuttieae tribe, fluctuate highly 

between years, depending on annual precipitation (Holland 1987). However, population trends 

for the species are thought to be generally downward and the species may be near extinction (C. 

Witham, pers. comm. 2007). 

The latest rare grass surveys at the Yolo Regional Grasslands/Davis Communications Site were 

conducted in 2008, when approximately 5600 individual plants were counted within six 

relatively discrete basins onsite (J. Gerlach, Environmental Science Associates, in litt. 2008). In 

2007, a year with little precipitation, monitors documented only 45 individual Solano grass 

plants that germinated but were not expected to produce seed (J. Gerlach, Environmental Science 

Associates, in litt. 2007). Several thousand individual plants were seen at this site in 2000, and 

transect counts in 2003 provided a population count of at least 1,400 plants. The distribution of 

the plants within pools has been found to change annually (ESA, 2008; J. Gerlach, in litt. 2007). 

Because the number of germinated plants varies substantially each year depending on interannual climatic conditions, to date monitors have not been able to determine a trend for the 

occurrence (J. Gerlach in litt. 2008). In 2005, a census of the occurrence on private property near 

Jepson Prairie provided a count of five plants. The number of plants documented at the site has 

been up to 200, but is generally around 25 plants (C. Witham, pers. comm. 2007).
2013 VGP and sVGP BE Appendix F

F-167

Summary of Major Threats:

The primary threats to the species continue to be the modification, destruction, and degradation 

of suitable habitat, and the resulting habitat fragmentation. Modification of habitat is currently 

caused by altered site hydrology, inappropriate grazing levels (cessation of grazing or 

overgrazing), nonnative invasive plants, and related issues such as thatch build-up. Contaminant 

runoff into vernal pools, and drought and climate change are also major threats. Even on 

protected sites, new and emerging threats have been identified in the form of hydrologic 

alteration resulting from invasive nonnative plants and land use activities. 

In addition, Solano grass occurrences are threatened by their small size and isolation. Small 

population size may be a factor in pollination success for this species. Currently populations 

fluctuate greatly, are thought to be declining, and one protected population is thought to be 

extirpated. The Service is working with the State of California, Yolo County, conservation 

organizations, and private landowners to protect the remaining suitable habitat and to restore the 

species to unoccupied suitable habitat.

F.7. MIAMI, FLORIDA

F.7.1.

Acipenser brevirostrum

SHORTNOSE STURGEON

(See New York, New York for information on this species)

F.7.2.

Acipenser oxyrinchus desotoi

GULF STURGEON

Family: Acipenseridae

Threatened: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=E04W)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Acipenser+oxyri

nchus+desotoi)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc2620.pdf)

• 68 FR 13370 

(http://www.gpo.gov/fdsys/search/citation.result.FR.action?federalRegister.volume=2003

&federalRegister.page=13370&publication=FR)

Description:

Gulf sturgeons are anadromous fish with a sub-cylindrical body imbedded with bony plates or 

scutes. The snout is greatly extended and bladelike with four fleshy barbels in front of the mouth, 

which is protractile on the lower surface of the head. The upper lobe of the tail is longer than the 
2013 VGP and sVGP BE Appendix F

F-168

lower lobe. The subspecies is light brown to dark brown in color and pale underneath (Vladykov,

1955; Vladykov and Greeley, 1963).

Geographic Boundaries and Spatial Distribution:

According to Wooley and Crateau (1985) Gulf sturgeon occurred in most major river systems 

from the Mississippi River to the Suwannee River, Florida and in marine waters of the Central 

and Eastern Gulf of Mexico south to Florida Bay. Comparison of historic information and 

current data indicates that Gulf sturgeon populations are reduced from historic levels (Barkuboo,

1988). The present range extends from Lake Pontchartrain and the Pearl River system in 

Louisiana and Mississippi east to the Suwannee River in Florida (USFWS, 2003).

At present, Gulf sturgeon population estimates are unknown throughout its range; however, 

estimates have been completed for the Apalachicola and Suwannee rivers. It was once widely 

distributed throughout the coastal rivers of the northeastern Gulf of Mexico, primarily from the 

Mississippi River east to Tampa Bay, including the states of Louisiana, Mississippi, Alabama, 

and Florida. Sporatic occurrences are known as far west as Texas (Rio Grande) and in marine 

waters in Florida south to Florida Bay. 

Habitat: (has critical habitat)

The Gulf sturgeon is an anadromous fish which migrates from salt water into large coastal rivers 

to spawn and spend the warm months. The majority of its life is spent in fresh water. The species 

feeds in the winter months in the marine waters of the Gulf of Mexico including bays and 

estuaries, migrating in the spring up freshwater rivers to spawn on hard substrates, and then 

spending summers in the lower rivers before emigrating back out into estuarine/marine waters in 

the fall.

On March 19, 2003, 14 geographic areas among the Gulf of Mexico rivers and tributaries were 

designated as critical habitat for the Gulf sturgeon. These 14 geographic areas (units) encompass 

approximately 2,783 river kilometers (1,730 river miles ) and 6,042 square kilometers (2,333 

square miles) of estuarine and marine habitat. Critical habitat in Florida is in Escambia River 

System in Santa Rosa and Escambia Counties; Yellow River System in Santa Rosa and Okaloosa 

Counties; Choctawhatchee River System in Holmes, Washington, and Walton Counties; 

Apalachicola River System in Franklin, Gulf, Liberty, Calhoun, Jackson, and Gadsen Counties; 

Suwannee River System in Hamilton, Suwannee, Madison, Lafayette, Gilchrist, Levy, Dixie, and 

Columbia Counties; Pensacola Bay System in Escambia and Santa Rosa Counties; Santa Rosa 

Sound in Escambia,Santa Rosa, and Okaloosa Counties; Florida Nearshore Gulf of Mexico Unit 

in Escambia, Santa Rosa, Okaloosa, Walton, Bay, and Gulf Counties; Choctawhatchee Bay in 

Okaloosa and Walton Counties; Apalachicola Bay in Gulf and Franklin County; and Suwannee 

Sound in Dixie and Levy Counties.

Based on the best available information, primary constituent elements essential for the 

conservation of the Gulf sturgeon include the following: (1) abundant food items, such as 

detritus, aquatic insects, worms, and/or molluscs, within riverine habitats for larval and juvenile 

life stages and abundant prey items, such as amphipods, lancelets, polychaetes, gastropods, ghost 

shrimp, isopods, molluscs and/or crustaceans, within estuarine and marine habitats and substrates 

for subadult and adult life stages; (2) tiverine spawning sites with substrates suitable for egg 
2013 VGP and sVGP BE Appendix F

F-169

deposition and development, such as limestone outcrops and cut limestone banks, bedrock, large 

gravel or cobble beds, marl, soapstone, or hard clay; (3) riverine aggregation areas, also referred 

to as resting, holding, and staging areas, used by adult, subadult, and/or juveniles, generally, but 

not always, located in holes below normal riverbed depths, believed necessary for minimizing 

energy expenditures during fresh water residency and possibly for osmoregulatory functions; (4) 

a flow regime (i.e., the magnitude, frequency, duration, seasonality, and rate-of-change of fresh 

water discharge over time) necessary for normal behavior, growth, and survival of all life stages 

in the riverine environment, including migration, breeding site selection, courtship, egg 

fertilization, resting, and staging, and for maintaining spawning sites in suitable condition for egg 

attachment, egg sheltering, resting, and larval staging; (5) water quality, including temperature, 

salinity, pH, hardness, turbidity, oxygen content, and other chemical characteristics, necessary 

for normal behavior, growth, and viability of all life stages; (6) sediment quality, including 

texture and other chemical characteristics, necessary for normal behavior, growth, and viability 

of all life stages; and (7) safe and unobstructed migratory pathways necessary for passage within 

and between riverine, estuarine, and marine habitats (e.g., an unobstructed river or a dammed 

river that still allows for passage).

Life History:

Feeds primarily on benthic invertebrates and small fishes as available (e.g., worms, crustaceans, 

aquatic insects, snails, sand lances). Feeding evidently occurs only during the winter and spring 

in offshore or estuarine waters (Cross, 1992). The species takes at least 7-8 years to mature with 

females spawning at intervals of more than one year (USFWS, 2003).

Adults migrate between fresh water spawning areas and salt water nonspawning areas. The 

sturgeon moves into the Suwanne River in February-May (mainly late March-early April) and 

may migrate as far as 140 miles upstream. Subadults and adults return to the Gulf of Mexico in 

late fall, while young generally stay in the river mouth in winter and spring (Cross, 1992). 

Historical Information:

Historically, Gulf sturgeon occurred from the Mississippi River east to Tampa Bay. Sporadic 

occurrences were recorded as far west as the Rio Grande River in Texas and Mexico, and as far 

east and south as Florida Bay (Wooley and Creteau,1985; Reynolds, 1993). 

Conservation Status:

Using the mark-recapture data, general estimates of population size can be calculated. Although 

variable, most populations appear relatively stable with a few exceptions. The number of Gulf 

sturgeon in the Escambia River system may have recently declined due to hurricane impacts, and 

the Suwannee River population appears to be slowly increasing. Due to lack of research since 

Hurricanes Ivan and Katrina, no data are available to determine the current size of the Gulf 

sturgeon populations within the Pearl and Pascagoula Rivers.

Research on Gulf sturgeon population characteristics in the past 5 years has been limited to the 

eastern five populations. The FWS Panama City Field Office has annually monitored one or 

more of the four Florida Panhandle rivers (Escambia, Yellow, Choctawhatchee, and 

Apalachicola) since 2003 (fiscal year annual reports USFWS 2003-2008). USGS researchers 

completed the first assessment of the Yellow River population (Berg, 2004; Berg et al., 2007). 
2013 VGP and sVGP BE Appendix F

F-170

Advances in modeling population dynamics have been made, especially for the Apalachicola and 

Suwannee River populations (Flowers, 2008, Pine and Martell, 2009). The species is currently 

reproducing in seven river systems (USFWS, 2003).

Summary of Major Threats:

Gulf sturgeon numbers declined due to overfishing throughout most of the 20th century. The 

decline was exacerbated by habitat loss associated with the construction of water control 

structures, such as dams and sills (submerged ridge or vertical wall of relatively shallow depth 

separating two bodies of water), mostly after 1950. In several rivers throughout the range, dams 

have severely restricted sturgeon access to historic migration routes and spawning areas 

(USFWS, 2003).

Other threats and potential threats identified in the listing rule included modifications to habitat 

associated with dredged material disposal, de-snagging (removal of trees and their roots), and 

other navigation maintenance activities; incidental take by commercial fishermen; poor water 

quality associated with contamination by pesticides, heavy metals, and industrial contaminants; 

aquaculture and incidental or accidental introductions; and the Gulf sturgeon's slow growth and 

late maturation (USFWS, 2003).

F.7.3.

Acropora cervicornis

STAGHORN CORAL

Family: Acroporidae

Threatened: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=P000)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Acropora+cervic

ornis)

• NOAA Fisheries, 2012 

(http://www.nmfs.noaa.gov/pr/species/invertebrates/staghorncoral.htm)

• 73 FR 72210 (http://www.gpo.gov/fdsys/pkg/FR-2008-11-26/pdf/E8-27748.pdf#page=1)

Description:

Staghorn coral is a branching coral with cylindrical branches ranging from a few centimeters to 

over 6.5 feet (2 m) in length. This coral exhibits the fastest growth of all known western Atlantic 

corals, with branches increasing in length by 4-8 inches (10-20 cm) per year. Staghorn coral has 

been one of the three most important Caribbean corals in terms of its contribution to reef growth 

and fish habitat.

Geographic Boundaries and Spatial Distribution:

Staghorn coral is found in the Atlantic Ocean, Caribbean Sea, and western Gulf of Mexico (nonU.S. waters). Specifically, staghorn coral is found throughout the Florida Keys, the Bahamas, the 
2013 VGP and sVGP BE Appendix F

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Caribbean islands, and Venezuela. The northern limit of staghorn coral is around Boca Raton, 

Florida.

Habitat: (has critical habitat)

Staghorn coral occur in back reef and fore reef environments from 0-100 ft. (0 to 30 m) deep. 

The upper limit is defined by wave forces, and the lower limit is controlled by suspended 

sediments and light availability. Fore reef zones at intermediate depths of 15-80 ft. (5-25 m) 

were formerly dominated by extensive single species stands of staghorn coral until the mid1980s.

In Florida, approximately 1,329 square miles (3,442 sq km) of marine habitat is designated as 

critical habitat for staghorn coral. The specific areas contain the substrate physical feature 

determined to be essential to the conservation of these species and that may require special 

management considerations or protection. Critical habitat includes one specific area of the 

Atlantic Ocean offshore of Palm Beach, Broward, Miami-Dade, and Monroe counties, Florida, 

Except as specified below, the seaward boundary is the 98-ft (30–m) depth contour and the 

shoreward boundary is the line of mean low water (MLW; 33 CFR 2.20). Within these 

boundaries, discrete areas of water deeper than 98 ft (30 m) are not included. The Florida area 

contains three sub-areas. (i) The shoreward boundary for Florida sub-area A begins at the 6–ft 

(1.8 m) contour at the south side of Boynton Inlet, Palm Beach County then runs due east to the 

point of intersection with the 98–ft (30 m) contour; then follows the 98–ft (30 m) contour to the 

point of intersection with Government Cut, Miami-Dade County; then runs due west to the point 

of intersection with the 6-ft (1.8 m) contour, then follows the 6-ft (1.8 m) contour to the 

beginning point. (ii) The shoreward boundary of Florida sub-area B begins at the MLW line 

Government Cut, Miami-Dade County; then runs due east to the point of intersection with the 

98–ft (30 m) contour; then follows the 98–ft (30 m) contour to the point of intersection with 

longitude 82° W; then runs due north to the point of intersection with the South Atlantic Fishery 

Management Council (SAFMC) boundary at 24° 31′ 35.75′′ N; then follows the SAFMC 

boundary to a point of intersection with the MLW line at Key West, Monroe County; then 

follows the MLW line, the SAFMC boundary (see 50 CFR 600.105(c)), and the COLREGS line 

(see 33 CFR 80.727. 730, 735, and 740) to the beginning point. (iii) The seaward boundary of 

Florida sub-area C (the Dry Tortugas) begins at the northern intersection of the 98–ft (30 m) 

contour and longitude 82° 45’ W; then follows the 98–ft (30 m) contour west around the Dry 

Tortugas, to the southern point of intersection with longitude 82° 45’ W; then runs due north to 

the beginning point.

The only primary constituent element essential for the staghorn coral is substrate of suitable 

quality and availability to support successful larval settlement and recruitment, and reattachment 

and recruitment of fragments. For purposes of this definition, ‘‘substrate of suitable quality and 

availability’’ means natural consolidated hard substrate or dead coral skeleton that is free from

fleshy or turf macroalgae cover and sediment cover. This feature is essential to the conservation 

of this species due to the extremely limited recruitment currently being observed.

Life History:

The dominant mode of reproduction for staghorn coral is asexual fragmentation, with new 

colonies forming when branches break off a colony and reattach to the substrate. Sexual 
2013 VGP and sVGP BE Appendix F

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reproduction occurs via broadcast spawning of gametes into the water column once each year in 

August or September. Individual colonies are both male and female (simultaneous 

hermaphrodites) and will release millions of "gametes". Some massive coral species reach sexual 

maturity when their polyps grow to about 4 inches (10 cm) in diameter, which occurs when they 

are about 8 years old. Acropora, which are faster-growing, likely reach sexual maturity at a 

younger age.

The coral larvae (planula) live in the plankton for several days until finding a suitable area to 

settle, but very few larvae survive to settle and metamorphose into new colonies. The 

preponderance of asexual reproduction in this species raises the possibility that genetic diversity 

is very low in the remnant populations.

This coral exhibits the fastest growth of all known western Atlantic corals, with branches 

increasing in length by 4-8 inches (10-20 cm) per year. Tropical corals, like staghorn coral, get 

as much as 90 percent of their energy from the organic byproducts of photosynthesis thanks to a 

symbiotic relationship with algae. They may also capture and consume live prey, such as small 

fish and zooplankton, using their tentacles.

Historical Information:

NMFS finalized the ESA listing of staghorn coral on May 4, 2006 (71 FR 26852). NMFS 

designated critical habitat for staghorn corals in November 2008.

Conservation Status:

Since 1980, populations have collapsed throughout their range from various threats, as detailed 

below. Populations have declined by up to 98% throughout their range, and localized 

extirpations have occurred.

Summary of Major Threats:

The declining populations in south Florida and the Caribbean due to thermal events, anchor 

damage, and diseases of unknown etiology (Dustan, 1977; Tunnicliffe, 1983; Peters, 1984). The 

greatest source of region-wide mortality for staghorn coral has been disease outbreaks, mainly of 

white band disease. Other, more localized losses have been caused by hurricanes, increased 

predation, bleaching, algae overgrowth, human impacts, and other factors. This species is also 

particularly susceptible to damage from sedimentation and is sensitive to temperature and 

salinity variation.

The dominant mode of reproduction for staghorn coral is asexual fragmentation; this life history 

trait allows rapid population recovery from physical disturbances such as storms. However, this 

mode of reproduction makes recovery from disease or bleaching episodes (in which entire 

colonies or even entire stands are killed) very difficult. The large role of asexual reproduction for 

this species also increases the likelihood that genetic diversity in the remnant populations is very 

low.
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F.7.4.

Acropora palmata

ELKHORN CORAL

Family: Acroporidae

Threatened: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=P001)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Acropora+palma

ta)

• NOAA Fisheries, 2012 

(http://www.nmfs.noaa.gov/pr/species/invertebrates/elkhorncoral.htm)

• 73 FR 72210 (http://www.gpo.gov/fdsys/pkg/FR-2008-11-26/pdf/E8-27748.pdf#page=1)

Description:

Elkhorn coral is a large, branching coral with thick and sturdy antler-like branches. Colonies are 

fast growing with branches that increase in length by 2-4 in. (5-10 cm) per year. Colonies reach 

their maximum size in approximately 10-12 years. Over the last 10,000 years, elkhorn coral has 

been one of the three most important Caribbean corals contributing to reef growth and 

development and providing essential fish habitat.

Geographic Boundaries and Spatial Distribution:

Elkhorn coral is found on coral reefs in southern Florida, the Bahamas, and throughout the 

Caribbean. Its northern limit is Biscayne National Park, Florida, and it extends south to 

Venezuela. It is not found in Bermuda. Once found in continuous stands that extended along the 

front side of most coral reefs, the characteristic "Acropora palmata zone" supported a diverse 

assemblage of other invertebrates and fish. These zones have been largely transformed into 

rubble fields with few, isolated living colonies.

Habitat: (has critical habitat)

Elkhorn coral was formerly the dominant species in shallow water 3 ft-16 ft. (1-5 m) deep 

throughout the Caribbean and on the Florida Reef Tract, forming extensive, densely aggregated 

thickets (stands) in areas of heavy surf. Coral colonies prefer exposed reef crest and fore reef 

environments in depths of less than 20 ft. (6 m), although isolated corals may occur to 65 ft. (20 

m).

In Florida, approximately 1,329 square miles (3,442 sq km) of marine habitat is designated as 

critical habitat for elkhorn coral. The specific areas contain the substrate physical feature 

determined to be essential to the conservation of these species and that may require special 

management considerations or protection. Critical habitat includes one specific area of the 

Atlantic Ocean offshore of Palm Beach, Broward, Miami-Dade, and Monroe counties, Florida, 

Except as specified below, the seaward boundary is the 98-ft (30–m) depth contour and the 

shoreward boundary is the line of mean low water (MLW; 33 CFR 2.20). Within these 

boundaries, discrete areas of water deeper than 98 ft (30 m) are not included. The Florida area 
2013 VGP and sVGP BE Appendix F

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contains three sub-areas. (i) The shoreward boundary for Florida sub-area A begins at the 6–ft 

(1.8 m) contour at the south side of Boynton Inlet, Palm Beach County then runs due east to the 

point of intersection with the 98–ft (30 m) contour; then follows the 98–ft (30 m) contour to the 

point of intersection with Government Cut, Miami-Dade County; then runs due west to the point 

of intersection with the 6-ft (1.8 m) contour, then follows the 6-ft (1.8 m) contour to the 

beginning point. (ii) The shoreward boundary of Florida sub-area B begins at the MLW line 

Government Cut, Miami-Dade County; then runs due east to the point of intersection with the 

98–ft (30 m) contour; then follows the 98–ft (30 m) contour to the point of intersection with 

longitude 82° W; then runs due north to the point of intersection with the South Atlantic Fishery 

Management Council (SAFMC) boundary at 24° 31′ 35.75′′ N; then follows the SAFMC 

boundary to a point of intersection with the MLW line at Key West, Monroe County; then 

follows the MLW line, the SAFMC boundary (see 50 CFR 600.105(c)), and the COLREGS line 

(see 33 CFR 80.727. 730, 735, and 740) to the beginning point. (iii) The seaward boundary of 

Florida sub-area C (the Dry Tortugas) begins at the northern intersection of the 98–ft (30 m) 

contour and longitude 82° 45’ W; then follows the 98–ft (30 m) contour west around the Dry 

Tortugas, to the southern point of intersection with longitude 82° 45’ W; then runs due north to 

the beginning point.

The only primary constituent element essential for the elkhorn coral is substrate of suitable 

quality and availability to support successful larval settlement and recruitment, and reattachment 

and recruitment of fragments. For purposes of this definition, ‘‘substrate of suitable quality and 

availability’’ means natural consolidated hard substrate or dead coral skeleton that is free from 

fleshy or turf macroalgae cover and sediment cover. This feature is essential to the conservation 

of this species due to the extremely limited recruitment currently being observed.

Life History:

The dominant mode of reproduction for elkhorn coral is asexual, with new colonies forming 

when branches break off of a colony and reattach to the substrate. Sexual reproduction occurs via 

broadcast spawning of gametes into the water column once each year in August or September. 

Individual colonies are both male and female (simultaneous hermaphrodites) and will typically 

release millions of "gametes".

The coral larvae (planula) live in the plankton for several days until finding a suitable area to 

settle, but very few larvae survive to settle and metamorphose into new colonies. The 

preponderance of asexual reproduction in this species raises the possibility that genetic diversity 

may be very low in the remnant populations.

Historical Information:

NMFS finalized the ESA listing of elkhorn coral on May 4, 2006 (71 FR 26852). NMFS 

designated critical habitat for elkhorn corals in November 2008.

Conservation Status:

In areas where loss has been quantified, estimates are in the range of 90-95% reduction in 

abundance since 1980. Additional drastic reductions (e.g., 75-90%) were recently observed in 

some areas such as the Florida Keys in 1998 due to bleaching and hurricane damage.
2013 VGP and sVGP BE Appendix F

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Summary of Major Threats:

Since 1980, populations have collapsed throughout their range from disease outbreaks with 

losses compounded locally by hurricanes, increased predation, bleaching, and elevated 

temperatures. This species is also particularly susceptible to damage from sedimentation. Other 

threats include algae overgrowth and salinity variation.

The dominant mode of reproduction for elkhorn coral is asexual fragmentation; this life history 

trait allows rapid population recovery from physical disturbances such as storms. However, this 

mode of reproduction makes recovery from disease or bleaching episodes (in which entire 

colonies or even entire stands are killed) very difficult. The large role of asexual reproduction for 

this species increases the likelihood that genetic diversity in the remnant populations may be 

very low. Scientists are becoming increasingly concerned for this species based on its 

demographic paramaters; specifically, how species recruitment and genetic diversity affect 

recovery potential.

F.7.5.

Ammodramus maritimus mirabilis

CAPE SABLE SEASIDE SPARROW

Family: Fringillidae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=B00Q)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc3272.pdf)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Ammodramus+

maritimus+mirabilis)

• 72 FR 62736 (http://www.gpo.gov/fdsys/pkg/FR-2007-11-06/pdf/07-5460.pdf#page=1)

Description:

Cape Sable seaside sparrows are small birds about 13 cm (5 in.) long. Dorsally, they are dark 

olive-gray with olive-brown on the tail and wings. The greenish cast on the nape is generally 

difficult to detect. Ventrally, adults are light gray to almost white with dark olive-gray streaks on 

the breast and sides. Occasionally, the breast streaks converge forming a diffuse central spot. 

There is a dark whisker on either side of the white throat. These sparrows have yellow lores, 

brown eyes, and a gray ear patch behind the eye which is fringed by a dark line. There is a small 

patch of yellow on the edge of the wing. No sexual differences in the plumages are obvious.

Geographic Boundaries and Spatial Distribution:

The species is found in extreme southern and southwestern Florida. It had scattered populations 

that formerly occurred from Ochopee south to Taylor Slough, in Dade, Collier, and Monroe 

Counties. Two remaining disjunct populations occur in marshes of Big Cypress Swamp and 

Taylor Slough.
2013 VGP and sVGP BE Appendix F

F-176

Habitat: (has critical habitat)

Its habitat includes seasonally flooded, brushless, subtropical interior marshes, fresh to slightly 

brackish; cordgrass, rushes, and sawgras. They have adapted to habitat subject to periodic fires, 

but fires late in dry season may be detrimental to eggs and young. Also, too-frequent burning 

may prevent establishment of a vigorous sparrow population (Matthews and Moseley, 1990). 

They nest in wetter areas in tufts of herbaceous growth.

The critical habitat was designated for the cape sable seaside sparrow in December 6, 2007, and 

is located in Miami Dade County, Florida, and approximately 84,865 acres fall within the 

boundaries of the designation. Five units were designated as critical habitat: (1) Marl prairie 

habitats that support sparrow subpopulation B and lie exclusively within ENP in the vicinity of 

the Main Park Road, between Shark River Slough and Taylor Slough; (2) marl prairie habitat 

that supports sparrow subpopulation C within ENP along its eastern boundary in the vicinity of 

Taylor Slough; (3) marl prairie habitats that support sparrow subpopulation D within ENP and 

the State-owned Southern Glades Wildlife and Environmental Area to the east of Taylor Slough; 

(4) marl prairie habitats that support sparrow subpopulation E within ENP, along the eastern 

edge of Shark River Slough; and (5) marl prairies that support sparrow subpopulation F within 

the northern portion of ENP along its eastern boundary and lying to the east of Shark River 

Slough.

The PCEs for the Cape Sable seaside sparrows are: (1) calcitic marl soils characteristic of the 

short-hydroperiod freshwater marl prairies of the southern Everglades with soils that support the 

unique vegetation community and probably many of the food items upon which sparrows 

depend; (2) herbaceous vegetation that includes greater than 15 percent combined cover of live 

and standing dead vegetation of one or more of the following species (when measured across an 

area of greater than 100 ft2 (9.3 m2)): Muhly grass (Muhlenbergia filipes), Florida little bluestem 

(Schizachyrium rhizomatum), blacktopped sedge (Schoenus nigricans), and cordgrass (Spartina 

bakeri), which act as cover and substrate for foraging, nesting, and normal behavior for sparrows 

during a variety of environmental conditions; (3) large, expansive, contiguous habitat patches 

with few or sparse woody shrubs or trees with space for population and individual growth; (4) 

hydrologic regime such that the water depth, as measured from the water surface down to the soil 

surface, does not exceed 7.9 inches (20 cm) for more than 30 days during the period from March 

15 to June 30 at a frequency of more than 2 out of every 10 years.

Life History:

Its clutch size is 3-4 with incubation lasting 12-13 days. Nesting period is about 11 days, after 

which young are active but flightless on ground. After leaving the nest, young are tended by both 

parents for up to 20 days after which young can fly (Matthews and Moseley 1990). Nests 

generally are in loosely defined, often isolated colonies (Ehrlich et al. 1992). Males defend nestcentered territories year-round (Ehrlich et al. 1992). Occasional flooding can be a major cause of 

nest loss (Matthews and Moseley 1990). They eat mainly insects and other small invertebrates; 

also some seeds (Terres 1980). Generally picks food items off substrate or gleans them from low 

foliage (Ehrlich et al. 1992).
2013 VGP and sVGP BE Appendix F

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Historical Information:

The species was listed on March 11, 1967 with critical habitat designations made on September 

22, 1977 and November 6, 2007.

Conservation Status:

Wildfires and declines in five of the six subpopulations suggest an overall declining status within 

the last 5 years. The overall status of the sparrow declined in 2009. No sparrows were detected in 

one subpopulation, and two and three males were detected in two others, indicating limited 

production for these subpopulations. Summer fires in 2008 burned significant portions of three 

subpopulations, and the burned habitat is not expected to recover fully for at least 2 years 

(Lockwood et al., 2005; La Puma et al., 2007). Recovery of burned habitat within subpopulation 

A is particularly tenuous due to water management issues. High water levels can flood nests or 

preclude birds from nesting, and, particularly after fire, high water levels can alter the vegetative 

community, making it unsuitable. The overall population is less secure because of the decline or 

lack of production in two subpopulations, and degradation of habitat due to fire in three 

subpopulations.

Summary of Major Threats:

Threats include agriculture (rock plowing), wild fires, hurricanes, hydroperiod alteration, 

invasion of habitat by brush and exotic trees, and soil salinity increases.

F.7.6.

Balaenoptera physalus

FINBACK WHALE

(See New York, New York for information on this species)

F.7.7.

Campanula robinsiae

BROOKSVILLE BELLFLOWER

Family: Campanulaceae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q1TV)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc3206.pdf)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Campanula+robi

nsiae)

• USFWS, 2012c (http://www.fws.gov/northflorida/Species-Accounts/BellflowerWaterwillow-2005.htm)

Description:

Brooksville bellflower, an annual herb, has a slender taproot and slender, four-angled stems 0.4 

to 6 in. (1 to 15 cm) tall. Its largest leaves, ovate to elliptic, are at the base of the plant. Leaves 
2013 VGP and sVGP BE Appendix F

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are narrower and shorter closer to the top. Flowers are solitary, bell-shaped, deep purple in color, 

and 3-10 mm long.

Geographic Boundaries and Spatial Distribution:

The plant is native to the Brooksville Ridge, in north central Hernando County, Florida. 

Although Brooksville bellflower was first collected near Mascotte in Lake County, all 

subsequent collections have been from the Ridge. There are now only two known populations of 

Brooksville bellflower. 

Habitat: (no critical habitat)

Brooksville bellflower is found in a wet prairie and along the edges of ponds near pastureland. 

The number of plants seems to vary yearly, perhaps depending on water levels. Brooksville 

Ridge, the area to which the plants is endemic, has the most irregular surface of any comparablysized area in peninsular Florida. Its limestone rock outcrops are unique in the peninsula, and its 

sinkholes have especially rich fern floras. The Ridge has few surface streams, and most drainage 

goes to ponds, prairies, and sinkholes.

Life History:

Many of this plant's flowers are closed, self-pollinating, and inconspicuous. Those that are open 

and cross-pollinating are solitary, with 0.04-to-0.10-inch long sepals and a deep purple, bellshaped corolla. Flowering occurs in the spring during March and April. The seeds produced by 

this species are the smallest of any North American bellflower (Shetler and Morin, 1986). 

Historical Information:

Campanula robinsiae was originally found in 1924 at Chinsegut Hill in Hernando County. It was 

not until 1983 that this species was found at Burns Prairie and on privately owned land (Young 

site) in Hernando County. The 1983 surveys documented plants at all three sites, although habitat 

conditions at Chinsegut Hill were poor and extreme trampling by cattle resulted in a low number 

of plants. Additional surveys of the Young and Burns Prairie sites has occurred over the years 

(1995-1998 and again from 2007-2010). In 2006, a biologist with the Florida Department of 

Environmental Protection (FDEP) at Hillsborough River State Park in Hillsborough County 

found two sites with C. robinsiae (Gandy, FDEP, personal communication, 2009). A third site 

was found at Hillsborough River State Park in 2009.

Conservation Status:

Since 1924 when C. robinsiae was originally found, the abundance of this species has fluctuated 

greatly due to many factors including an increase in water levels and drought (Wunderlin et al. 

1980). Germination appears to be affected by the changes in water levels. At Burns Prairie, 

Williams (1998) found that after a period of high rainfall that caused water levels to rise in the 

ponds, a large number of flowering plants were present the following growing season when 

waters had receded. It was determined that water levels from rainfall rather than time of year 

may be a critical factor controlling germination (Williams, 1998). Seeds may remain dormant for 

long periods until high levels of cumulative rainfall could affect germination and the annual life 

cycle (Landry, 1996). From 2001-2009, a decrease in the number of plants was documented by 

BTG at the Burns Prairie site, which is likely the result of drought conditions that have caused 

water levels to drop and habitat conditions to change (Peterson, 2007). In 2010, surveys found an 
2013 VGP and sVGP BE Appendix F

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increase in the number of seedlings at the Burns Prairie site, likely the result of heavy winter 

rainfall.

Summary of Major Threats:

The plant is primarily threatened by residential and agricultural development. Hernando County, 

where these plants occur, continues to grow at a rapid rate and in the recent past it was one of the 

fastest growing counties in the nation. Brooksville bellflower is being indirectly threatened by 

the resulting changes in land use within prairie watersheds. As development increases, so does 

the potential for runoff. Runoff increases pond water levels and higher water levels mean 

decreased bellflower populations. Also, runoff from developed areas may be contaminated by 

petroleum, fertilizers, and herbicides. Brooksville bellflower is also subject to collecting and 

vandalism.

F.7.8.

Canis rufus

RED WOLF

Family: Canidae

Endangered: wherever found, except where listed as experimental population

Experimental Population, Non-Essential: portions of NC and TN

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=A00F)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Canis+rufus)

Description:

The red wolf is one of two species of wolves in the world, the other being the gray wolf, Canis 

lupus. As their name suggests, red wolves are known for the characteristic reddish color of their 

fur most apparent behind the ears and along the neck and legs, but are mostly brown and buff 

colored with some black along their backs. Intermediate in size to gray wolves and coyotes, the 

average adult red wolf weighs 45-80 pounds, stands about 26 inches at the shoulder and is about 

4 feet long from the tip of the nose to the end of the tail.

Geographic Boundaries and Spatial Distribution:

Delineation of the range of this wolf is hampered by a paucity of specimens and debate over the 

taxonomic status of the species (Nowak, 2002). Data presented by Nowak (2002) indicate a 

range extending from Maine to Florida and eastward (south of the Great Lakes) to Illinois, 

Oklahoma, and Texas, based on pre-1918 complete skulls (fragmentary archaeological and 

paleontological material dating back 10,000 years do not change this much). If the red wolf is 

regarded as a valid species, its range historically was essentially confined to the southeastern 

United States.

A reintroduced population now occurs in an area of roughly 6,900 square km in northeastern 

North Carolina (reintroduction in Great Smoky Mountains National Park failed and has been 

terminated; Federal Register, 8 October 1998). Propagation populations currently exist on two 
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islands: Bulls Island, Cape Romain National Wildlife Refuge, South Carolina; and St. Vincent 

National Wildlife Refuge, Florida. Other red wolves exist in many captive-breeding facilities.

Habitat: (no critical habitat)

Suitable habitat for this habitat generalist includes upland and lowland forests, shrublands, and 

coastal prairies and marshes; areas with heavy vegetative cover. Young are born in a den in a 

hollow log, in a burrow, or in similar secluded sites.

Life History:

The species mates in January-February with gestation lasting 60-63 days. The litter size is 3-12 

(average 6-7) and born in March-May. There is typically one litter per year. Red wolves are 

sexually mature in 3 years.

Red wolves are more social than coyotes but less than gray wolves. They typically travel and 

forages in small family groups or alone. There former density was probably not more than 1 per 

2 square miles. They are opportunistic feeders whose diet consists of a variety of invertebrates 

and vertebrates (rabbits, rodents, deer, birds, etc.). They particularly favor marsh rabbits, nutria, 

and carrion. Red wolves are not considered a threat to livestock (does not hunt in packs), but 

may prey on unattended young calves, pigs, and barnyard fowl (Matthews and Moseley, 1990).

Historical Information:

Assuming the traditional view that the red wolf is a valid species and that it still exists in the 

unhybridized form, the species was, until recent reintroductions, extinct in the wild since early 

1980s (or mid-1970s) (Rennie, 1991). Formerly it was believed to have occurred from central 

Texas eastward to the coasts of Florida and Georgia and north to North Carolina, and along the 

Mississippi River Valley north to southern Illinois, and occasionally in Mexico. The last remnant 

population along Texas/Louisiana coast was rendered functionally extinct due to hybridization 

with coyote. 

Conservation Status:

Exterminated from formerly large range in the southeastern U.S.; now exists in one major 

population in northeastern North Carolina, plus a couple islands used for propagation. They are 

intensively monitored and managed. The attempted reintroduction in Great Smoky Mountains 

National Park was unsuccessful.

Summary of Major Threats:

Historical decline was due to human interactions (trapping, poisoning), habitat loss, and 

hybridization with coyote. Attempted reintroduction in Great Smoky Mountians National Park 

failed, probably due to parovirus and other common canine diseases, internal and external 

parasites, poor nutrition caused by low food availability, and predation (Federal Register, 8 

October 1998). Hybridization with coyotes is still an ongoing threat in northeastern North 

Carolina.
2013 VGP and sVGP BE Appendix F

F-181

F.7.9.

Caretta caretta

LOGGERHEAD SEA TURTLE

(See New York, New York for information on this species)

F.7.10.

Chelonia mydas

GREEN SEA TURTLE

(See Seattle, Washington for information on this species)

F.7.11.

Crocodylus acutus

AMERICAN CROCODILE

Family: Crocodylidae

Endangered: wherever found, except FL

Threatened: FL population

Sources:

• Crocodilian Species List, 2012 (http://crocodilian.com/cnhc/csp_cacu.htm)

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=C02J)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Crocodylus+acut

us)

• USFWS, 2012b (http://ecos.fws.gov/docs/federal_register/fr115.pdf)

Description:

A large lizard-shaped reptile, the crocodile closely resembles the alligator. Hatchlings are about 

23 cm in length; adults may grow to 4.5 m or larger. Florida crocodiles may be distinguished 

from alligators by their more slender build and their difference in snout shape. The crocodile's 

snout tapers forward from the eyes while the alligator's snout is untapered and rounded at the 

end. When the mouth is closed, the fourth tooth in the lower jaw is exposed in the crocodile but 

concealed in the alligator. Juveniles are lighter colored (light tan) than more mature animals, 

with banding on the body and tail. Adults take on an olive brown color and the iris is silvery.

The adult crocodile's diet includes fish, crabs, birds, turtles, snakes, and small mammals. The 

young feed chiefly on aquatic invertebrates and small fish. As a general rule crocodilians feed on 

any prey items which can be caught and overpowered.

Geographic Boundaries and Spatial Distribution:

The distribution of the American crocodile includes the Southern United States, Central and 

South America. Specifically it includes Belize, Cayman Islands (possibly extinct), Colombia, 

Costa Rica, Cuba, Dominican Republic, Ecuador, El Salvador, Guatemala, Haiti, Hispaniola, 

Honduras, Jamaica, Margarita (possibly extinct), Martinique (possibly extinct), Mexico, 

Nicaragua, Panama, Peru, Trinidad (possibly extinct), United States (extreme south Florida), and 

Venezuela
2013 VGP and sVGP BE Appendix F

F-182

Habitat: (has critical habitat)

Habitat includes coastal mangrove swamps, brackish and salt water bays, lagoons, marshes, tidal 

rivers, brackish creeks; also abandoned coastal canals and borrow pits. Individuals may wander 

widely in coastal waters and may range inland into lakes and lower reaches of large rivers. 

American crocodiles occupy mostly nonsaline waters in the nonbreeding season, move to saline 

waters when breeding. In Florida, primary habitat is inland mangrove swamps protected from 

wave action; females use open waters of Florida Bay only for access to nesting sites (Kushlan 

and Mazzotti, 1989). 

Eggs are laid in a mounded nest of soil, sand, or peat, or in a hole in the ground (Kushlan and 

Mazzoti, 1989). Florida Bay nest sites usually are at edge of hardwood thickets on small sand 

beaches, or on high marl banks of coastal creeks, or in mangrove swamps along old canal banks; 

also on berms of power plant cooling canal systems (Gaby et al., 1985). In Florida, shortly after 

hatching, hatchlings disperse from nest sites to nursery habitats that are generally more sheltered, 

have lower salinity (1-20 ppt), shallower water (generally), and more vegetation cover (USFWS,

2007). Lazell (1989) reported that young generally occupy brackish water but seem to do well in 

full salt water on North Key Largo (Florida), perhaps due to the effect of abundant rainfall.

On September 24, 1976, critical habitat was designated for the American crocodile beginning at 

the easternmost tip of Turkey Point, Dade County on the coast of Biscayne Bay, southeastward 

towards Christmas Point at the southern point of Elliot Key, southwestward along the Old 

Rhodes Key, Palo Alto Key, Anglefish Key, Key Largo, Plantation Key, Windley Key, Upper 

Mantecumbe Key, Lower Mantecumbe Key, and Long Key to the western tip of Long Key, 

northwestward to the western tip of Middle Cape, northward along the Gulf of Mexico shoreline 

to the north side of Little Sable Creek, eastward to the north part of Nine-Mile Pond, then back to 

Turkey Point.

Life History:

They feed primarily on fish and other aquatic species including turtles and crabs and sometimes 

even take birds. American crocodiles feed primarily at night. Juveniles take small fish and 

invertebrates. They are often blamed for the disappearance of domestic animals in more 

populated areas. Occasional reports of attacks on humans, but authenticated records are very 

rare. 

Females reach sexual maturity when they grow to 2.5 m in length. Populations adapt their 

breeding strategy to suit the environment. This species is mainly a hole nester, but populations 

without access to suitable nest sites which can be excavated (relatively well drained) will build 

mound nests using whatever nesting materials are available. Flooding creates high mortality. 

Nesting occurs during the dry season (to minimise flooding, especially in hole nests which are in 

danger of falling below the water table after heavy rains), following an extended courtship period 

which can last up to two months. The minimum number of eggs laid in the nest can be around 20 

in some populations, but is usually between 30 and 60, the mean being around 38. Nests are 

often found which contain eggs from two separate females. Hatching, after around 90 days, 

coincides with the beginning of the annual rains. At hatching, juveniles are around 25 cm in 

length. The degree of parental care seems to be variable, with some sources noting minimal 
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F-183

protection of the nest and the newly hatched juveniles, while others report a higher degree of 

parental attention, from guarding the nest (a burrow is constructed nearby), to assisting the 

hatching juveniles and subsequently protecting them (predators include birds, wild cats, raccoons 

and even large fish). However, it appears that the juveniles move away from the nesting area 

within a few days of hatching. They have been noted to vocalise less than other species during 

the first few weeks of life. 

Historical Information:

The Florida historical range centered on the southern tip of mainland Florida but extended at 

least as far north as Sanibel Island and Sarasota County on the west coast and Indian River 

County on the Atlantic coast, and southward into the Florida Keys (USFWS, 2007). The primary 

historical nesting area in Florida was on the mainland shore of Florida and Biscayne bays, 

including many of the small islands near shore, in what is today Everglades National Park, and it 

also included the upper Florida Keys from Key Largo south to Lower Matecumbe Key (see 

USFWS, 2007). Today most nesting occurs on the mainland shore of Florida Bay between Cape

Sable and Key Largo, but the nesting range also includes Biscayne Bay and the upper Florida 

Keys, with unsuccessful nesting north to Marco Island (USFWS, 2007).

Conservation Status:

The decline in numbers was primarily due to demand for the high-quality skin of this species, 

mainly from 1930 to 1960, and it is perhaps ironic that this high-value skin now makes 

sustainable use management programs feasible. Presently, continuing hunting (on a lesser scale) 

combined with habitat destruction (e.g. destruction of coastal mangrove habitat in Ecuador for 

aquaculture) are the most immediate threats. In Nicaragua, for example, illegal hunting occurs 

during the legal harvesting of caimans.

Range-wide trends are poorly documented, but in most of the range this species undoubtedly has 

declined in population size over the past three generations (three generations is at least 45 years 

and may be as high as 60-75 years). In Florida, extent of occurrence, area of occupancy, 

population size, nesting range, and number of known nests have been increasing in recent 

decades (Mazzoti et al., 2007, USFWS, 2007). The maximum number of nesting females in 

Florida increased from 20 in 1975 to 85 in 2004 (Mazzoti et al., 2007).

Summary of Major Threats:

Major threat in most parts of the range is poaching for skins. In some areas, populations have 

declined as a result of killing for meat or fat, killing for "fun," collection of eggs, and 

entanglement in fishing gear (Schubert, 1994). Habitat loss is also a threat, especially in Florida. 

Nesting sites and non-nesting habitat have been lost to development at Miami Beach and in the 

upper Florida Keys, but this loss has been partially offset by creation of artificial nesting sites on 

spoil banks along southern Biscayne Bay and a westward addition to nesting range in Florida 

Bay (Kushlan and Mazzotti, 1989). Future threats in Florida include stochastic natural disasters 

such as hurricanes and cold weather, road mortality, continued habitat degradation, and poaching 

(USFWS, 1998). Crocodiles are sensitive to human presence (especially at nest sites). In Florida, 

disturbance at nest sites caused females to abandon the site (Kushlan and Mazzotti, 1989).
2013 VGP and sVGP BE Appendix F

F-184

In Florida, crocodiles remain threatened by modification of habitat because of development 

adjacent to crocodile habitat; they will benefit from restored freshwater flow into estuaries 

(Mazzoti et al., 2007). As crocodiles increase in abundance and expand into new areas, 

interactions with humans will occur more frequently; integration of a recovering crocodile 

population with ever-increasing human use of coastal areas is a major challenge (Mazzoti et al.,

2007).

F.7.12.

Dermochelys coriacea

LEATHERBACK SEA TURTLE

(See Seattle, Washington for information on this species)

F.7.13.

Drymarchon corais couperi

EASTERN INDIGO SNAKE

Family: Colubridae

Threatened: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=C026)

• Florida Natural Areas Inventory, 2001 

(http://www.fnai.org/fieldguide/pdf/drymarchon_couperi.pdf)

• Hallam, 1998 (http://www.dtic.mil/cgi-bin/GetTRDoc?AD=ADA342329)

Description:

Drymarchon corais couperi is a very large, stout-bodied, shiny black snake reaching lengths as 

great as 8 ft. (244 cm). The body is glossy black and in sunlight has iridescent blue highlights. 

The chin and throat is reddish or white, and the color may extend down the body. The belly is 

cloudy orange and blue-gray. The scales on its back are smooth, but some individuals may 

possess some scales that are partially keeled. There are 17 dorsal scale rows at mid-body. The 

pupil is round. Juveniles are black-bodied with narrow whitish blue bands.

Geographic Boundaries and Spatial Distribution:

Its range-wide distribution is from Florida to southern Georgia. It formerly extended from 

southern South Carolina to southeastern Mississippi. In Florida, they are found statewide 

including Upper and Lower Keys, but rare in panhandle.

Habitat: (no critical habitat)

The snake has a broad range of habitats, from scrub and sandhill to wet prairies and mangrove 

swamps. In the northern part of range, the eastern indigo snake often winters in gopher tortoise 

burrows in sandy uplands but forages in more hydric habitats. They also were found along canal 

banks, using crab holes instead of gopher tortoise burrows. They require very large tracts to 

survive.
2013 VGP and sVGP BE Appendix F

F-185

In Georgia, indigo snakes may use creek bottom thickets, upland pine-hardwood forest, mixed 

hardwood forest, and agricultural fields during spring and fall (Speake et al., 1978). Maintaining 

corridors that link seasonal habitats may be important to allow snakes to safely travel among 

habitats. Habitat preferences appear to be less restricted in the southern portions of its current 

range, as indigo snakes occupy a wider range of habitats possibly due to climate and winter 

behavior (USFWS, 1982). For example, in southern Florida, indigo snakes can be found in 

riparian habitat, tropical hammocks, and dry glades (Carr and Goin, 1955; Lawler, 1977; 

Kochman, 1978).

Life History:

Temperature and season of year affect activity and seasonal home range sizes. Little is known 

about reproductive behavior in natural indigo snake populations. However, they have bred 

successfully in captivity at Auburn University, Alabama. Indigo snakes appear to reach sexual 

maturity at 3 to 4 years of age. Copulation in captivity has occurred primarily between October 

and March, with a peak in mid-November through late December (Speake et al., 1978, Ernst and 

Barbour 1989), although Moulis (1976) reported mating during April in Georgia. Clutches of 5 

to 12 eggs are laid from April through May with hatchlings emerging approximately 3 months 

later (from late July through October) (Behler and King, 1979; Ernst and Barbour, 1989). 

Females can lay fertile eggs after several years of isolation (Behler and King, 1979; Moler,

1992). Nest sites have not been described, although eggs may be laid in inactive gopher tortoise 

burrows (USFWS, 1992). 

The indigo snake is an active, diurnal predator. Prey are captured and killed with strong jaws; it 

does not kill by constriction or poisoning. Snakes often feed along the edge of wetlands (Moler,

1992) on a variety of vertebrates including fish, frogs, toads, lizards, small turtles including 

young gopher tortoises, snakes (e.g., black racers and diamondback rattlesnakes (Conant, 1975; 

Mount, 1975)), birds, and small mammals (e.g., cotton rats). 

Historical Information:

Historically, the range of the eastern indigo snake extended from South Carolina through 

Georgia and Florida to the Keys, and west to southern Alabama and Mississippi (Moler, 1985). 

In 1982, the snake was known from 50 counties in Georgia, where it appeared to be maintaining 

viable populations in protected areas of good habitat (USFWS, 1982). 

Conservation Status:

In recent years, there has been much concern over the decline of the eastern indigo snake across 

most of its original range. Indigo snakes currently occur almost exclusively in Florida and the 

Coastal Plain of Southern Georgia; they are now extremely rare or extirpated in Alabama, 

Mississippi, and South Carolina. However, recent reintroductions have been made; as of 1990, 

the Alabama Cooperative Wildlife Research Unit had released captive-reared individuals in 

Florida, Alabama, Georgia, and Mississippi. Populations are common to locally abundant in 

parts of peninsular Florida, but few known populations occur in the panhandle. Overall, indigo 

snake populations are declining in abundance and distribution.
2013 VGP and sVGP BE Appendix F

F-186

Summary of Major Threats:

Habitat loss, conversion, and degradation (e.g., farming, urbanization/construction, forestry 

practices, pasture) are the major factors contributing to the decline of the eastern indigo snake 

(Lawler, 1977, Moler, 1992). Remaining habitat continues to be degraded. Because of its 

dependence on gopher tortoise burrows for shelter, factors that degrade tortoise habitat, such as 

fire suppression, also negatively impact indigo snake populations. Fire suppression has allowed 

suitable habitat to undergo succession from longleaf pine/scrub-oak to communities dominated 

by larger oak species, such as laurel oak. Many even-aged pine plantations potentially suitable 

for snakes are often either not burned at a frequency suitable for snakes, are stocked too densely, 

or lack adequate prey. 

In contrast to other secretive species that can persist on small woodlots, indigo snakes require 

relatively large tracts of suitable habitat. Habitat fragmentation exacerbates this problem since 

the indigo snake is a wide-ranging species (Moler, 1992). Land development, even at low 

densities (e.g., 8-ha (20-acres) lot size), can negatively impact indigo snake populations since the 

home range of a single snake may overlap numerous individual properties (Moler, 1992). Other 

threats include collection for pets, and deliberate persecution, all of which are illegal.

F.7.14.

Eretmochelys imbricate

HAWKSBILL SEA TURTLE

(See New York, New York for information on this species)

F.7.15.

Eubalaena glacialis

NORTH ATLANTIC RIGHT WHALE

(See New York, New York for information on this species)

F.7.16.

Halophila johnsonii

JOHNSON’S SEAGRASS

Family: Hydrocharitaceae

Threatened: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q3AL)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Halophila+johns

onii)

• USFWS, 2012b (http://ecos.fws.gov/docs/recovery_plan/johnsonsseagrass.pdf)

• 65 FR 17786 (http://www.gpo.gov/fdsys/pkg/FR-2000-04-05/pdf/00-8394.pdf#page=2)
2013 VGP and sVGP BE Appendix F

F-187

Description:

Johnson's seagrass is a rare plant that may have the most limited distribution of any seagrass on 

earth. It frequently occurs in small (cm to a few m diameter) isolated patches. All species of 

Halophila are morphologically distinguished from the other seagrass genera by having either a 

pair of leaves or a pseudowhorl of leaves at each rhizome node. Most Halophilas are small, 

shallow rooted, and have 2-3 orders of magnitude less biomass per unit area compared to other 

seagrass genera. Although small, biomass turnover rate is relatively high, and the plants 

decompose quickly (Kenworthy et al., 1989). 

Morphologically, Johnson’s seagrass is recognized by the presence of pairs of linearly shaped 

foliage leaves, each with a petiole formed on the node of a horizontally creeping rhizome. The 

rhizome is located at or just below the sediment surface and is anchored to unconsolidated 

substrate by unbranched roots. The leaves are generally 2-5 cm long (including the petioles), and 

the rhizome internodes rarely exceed 3-5 cm in length, making this species appear diminutive 

relative to the larger seagrasses. 

Geographic Boundaries and Spatial Distribution:

Halophila johnsonii has been found growing only along approximately 200 km of coastline in 

southeastern Florida between Sebastian Inlet and north Biscayne Bay. This narrow range and 

apparent endemism indicate that H. johnsonii has the most limited known geographic 

distribution of any seagrass in the world. It is restricted to coastal lagoons and extends from 

Brevard, St. Lucie, Martin, Dade, and Palm Beach counties.

Habitat: (has critical habitat)

Where present in its limited geographic range, H. johnsonii often grows in a patchy, noncontiguous distribution at water depths extending from the intertidal down to 3 m. Species of 

Halophila are documented to occur from intertidal to 85 m depths (may be the deepest growing 

seagrasses); shallow occurrence is frequently associated with high turbidity. Halophila regularly 

occur in 30-40 m depths, thus are important contributors to primary production of coastal shelf 

environments (e.g., extensive beds on the West Florida Shelf). Some species are the primary 

colonizers of disturbed environments, apparently due to their tolerance to low light, their high 

sexual fecundity, and their rapid horizontal growth rates. 

Within Johnson’s seagrasses range, 10 areas were designated as critical habitat on May 5, 2000: 

a portion of the Indian River Lagoon, north of the Sebastian Inlet Channel; a portion of the 

Indian River Lagoon, south of the Sebastian Inlet Channel; a portion of the Indian River Lagoon 

near the Fort Pierce Inlet; a portion of the Indian River Lagoon, north of the St. Lucie Inlet; a 

portion of Hobe Sound; a site on the south side of Jupiter Inlet; a site in central Lake Worth 

Lagoon; a site in Lake Worth Lagoon, Boynton Beach; a site in Lake Wyman, Boca Raton; and a 

portion of Biscayne Bay.

Based on the best available information, general physical and biological features of the critical 

habitat areas include adequate water quality, salinity levels, water transparency, and stable, 

unconsolidated sediments that are free from physical disturbance. The specific areas occupied by 

Johnson’s seagrass are those with one or more of the following criteria: (1) locations with 

populations that have persisted for 10 years; (2) locations with persistent flowering populations; 
2013 VGP and sVGP BE Appendix F

F-188

(3) locations at the northern and southern range limits of the species; (4) locations with unique 

genetic diversity; and (5) locations with a documented high abundance of Johnson’s seagrass 

compared to other areas in the species’ range.

Life History:

Johnson’s seagrass grows vegetatively by the division of meristems located on the apex of the 

horizontal rhizome and in the axial point (node) where the petioles intersect the rhizome. As in 

all clonal plants, vegetative growth and areal coverage is achieved by meristem division, the 

iteration of modules (leaf pairs and apical meristems), and branching of the horizontal stem 

(rhizome). Since seagrasses are angiosperms, many species also reproduce sexually; however, no 

male flowers have ever been described nor is there any evidence of successful recruitment by 

seed for Johnson's seagrass, even with extensive, decade-long observations. Female flowers of 

H. johnsonii arising from the base of the petioles are enclosed in a two-leaved spathe. The fruits 

are long-necked with 3 stigmas, each 2-4 cm in length. There is no evidence of sexual 

reproduction in this species; therefore, H. johnsonii must rely on asexual branching and clonal 

reproduction for maintenance and dispersal. 

Historical Information:

Johnson's Seagrass was listed as threatened on September 14, 1998 (63 FR 49035): the first 

marine plant species to be listed under the ESA. Critical habitat for Johnson's seagrass was 

designated on April 5, 2000 (65 FR 17786). Halophila johnsonii has only relatively recently 

been identified as a distinct species (Eiseman and McMillan 1980) and no historical information 

on the species’ distribution is available. 

Conservation Status:

No monitoring program exists specifically for H. johnsonii. The most comprehensive and 

quantitative distribution and abundance data comes from the State of Florida Surface Water 

Improvement and Management Act of 1987 (SWIM) Project. Since 1994, all seagrass species 

have been monitored twice a year within 1 m2 quadrats placed every 10 m along 75 fixed 

transects in the IRL between Sebastian Inlet and Jupiter Inlet. In the IRL, H. johnsonii is 

discontinuous. It occurs over a range of depths (intertidal to 1.8 m), salinities, and water quality. 

Halophila johnsonii was found at 20 of 33 transects within the IRL during 1994-1997, but at not 

more than 12 transects at any one sampling time. Eight of the transects were specifically located 

to include H. johnsonii; the species is therefore over-represented in this monitoring program 

compared to random sampling. Where it does occur, its distribution is patchy, both spatially and 

temporally. It occurred in 4.6% (106 of 2,280) of the 1 m2 quadrats sampled within the IRL. 

Summary of Major Threats:

Principal threats to the species' survival include habitat degradation and destruction from 

dredging and filling, construction and shading from in- and overwater structures, prop scarring, 

altered water quality, and siltation Other threats include stochastic storm events. 

F.7.17.

Megaptera novaeangliae

HUMPBACK WHALE

(See Seattle, Washington for information on this species)
2013 VGP and sVGP BE Appendix F

F-189

F.7.18.

Mycteria americana

WOOD STORK

Family: Ciconiidae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=B06O)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc1115.pdf)

Description:

Wood storks are large, long-legged wading birds, about 50 in. tall, with a wingspan of 60 to 65 

inches. The plumage is white except for black primaries and secondaries and a short black tail. 

The head and neck are largely unfeathered and dark gray in color. The bill is black, thick at the 

base, and slightly decurved. Immature birds are dingy gray and have a yellowish bill.

Geographic Boundaries and Spatial Distribution:

The wood stork is a large wading bird that occurs from northern Argentina, eastern Peru and 

western Ecuador, north to Central America, Mexico, Cuba, Hispaniola, and the southeastern 

United States. The breeding range of the species extends from the southeastern U.S. south 

through Mexico and Central America, to Argentina, Brazil, and Uruguay (Bent, 1926). The 

Service listed the U.S. breeding population of wood storks in their known range of Florida, 

Georgia, South Carolina and Alabama in 1984. 

Habitat: (no critical habitat)

Wood storks are a wetland dependent species and loss of foraging wetlands continues to be the 

primary threat to this population. To ensure long-term survival and recovery of this population, 

wood storks require a mosaic of wetlands with varying climatological and seasonal conditions 

around colonies and within the wintering habitat in the coastal plain of the Southeast U.S. 

Wood storks have a unique feeding technique and require higher prey concentrations than other 

wading birds. Optimal water regimes for the wood stork involve periods of flooding, during 

which prey (fish) populations increase, alternating with dryer periods, during which receding 

water levels concentrate fish at higher densities coinciding with the stork's nesting season. 

Life History:

Small fish from 1 to 6 inches long, especially topminnows and sunfish, provide this bird's 

primary diet. Wood storks capture their prey by a specialized technique known as grope-feeding 

or tacto-location. Feeding often occurs in water 6 to 10 inches deep, where a stork probes with 

the bill partly open. When a fish touches the bill it quickly snaps shut. The average response time 

of this reflex is 25 milliseconds, making it one of the fastest reflexes known in vertebrates. Wood 

storks use thermals to soar as far as 80 miles from nesting to feeding areas. Since thermals do not 

form in early morning, wood storks may arrive at feeding areas later than other wading bird 

species such as herons. Energy requirements for a pair of nesting wood storks and their young is 
2013 VGP and sVGP BE Appendix F

F-190

estimated at 443 pounds of fish for the breeding season (based on an average production of 2.25 

fledglings per nest).

The wood stork is a highly colonial species usually nesting in large rookeries and feeding in 

flocks. Age at first breeding is 3 years but typically do so at 4. Nesting periods vary 

geographically. In South Florida, wood storks lay eggs as early as October and fledge in 

February or March. However, in north and central Florida, Georgia, and South Carolina, storks 

lay eggs from March to late May, with fledging occurring in July and August. Nests are 

frequently located in the upper branches of large cypress trees or in mangroves on islands. 

Several nests are usually located in each tree. Wood storks have also nested in man-made 

structures. Storks lay two to five eggs, and average two young fledged per successful nest under 

good conditions.

Historical Information:

The United States breeding population of wood storks declined from an estimated 20,000 nesting 

pairs in the 1930s, to about 10,000 pairs by 1960 (49 FR 7332), and then to a low of around 

5,000 nesting pairs in the late 1970s (Ogden et al., 1987). The lowest recorded annual total was 

2,500 pairs in 1978, a result of poor nesting conditions in conjunction with the low population. 

From the 1960s to the mid-1980s, the wood stork nesting population declined in southern Florida 

and increased in northern Florida, Georgia, and South Carolina (Ogden et al., 1987). Prior to 

1970, a majority (70 percent) of the population nested south of Lake Okeechobee and declined 

from 8,500 pairs in 1961 to fewer than 500 pairs in the late 1980s and early 1990s. During the 

same period, nesting in Georgia increased from 4 to 1,501 pairs and nesting in South Carolina 

increased from 11 to 829 pairs (Service, 1997). This extended the breeding range north along the 

coastal plain of Georgia and South Carolina. Overall, surveys between 1983 and 1995 

documented a population in the Southeast U.S. ranging between 4,073 and 7,853 pairs (Service 

1997). 

Conservation Status:

Three-year averages calculated from nesting data from 2001 through 2006 indicate that the total 

nesting population has been consistently above the 6,000 reclassification threshold for nesting 

pairs, and the averages have ranged from 7,400 to over 8,700. The 2006 nesting totals indicate 

that the stork population has reached its highest level since it was listed as endangered in 1984 

and since the early 1960s with over 11,000 nesting pairs documented in Florida, Georgia, South 

Carolina and North Carolina during the 2006 breeding season. Since listing, the number of 

nesting pairs is increasing, the number of nesting colonies is increasing, and the nesting range is 

growing. Even though threats that affect wood storks appear to be continuing at the same levels, 

the conclusion is that the overall population status is improving. 

Summary of Major Threats:

Habitat loss, fragmentation, and modification, is known to impact the species but the significance 

of the threat cannot be quantified. Other threats such as utilization of the species for commercial, 

recreational, scientific, or educational purposes; disease and predation; and other natural or manmade factors (i.e., contaminants, electrocution, road kill, invasion of exotic plants and animals, 

disturbance, and stochastic events) are known to occur but are not significant. 
2013 VGP and sVGP BE Appendix F

F-191

F.7.19.

Myotis grisescens

GRAY BAT

(See St. Louis, Missouri for information on this species)

F.7.20.

Myotis sodalis

INDIANA BAT

(See New York, New York for information on this species)

F.7.21.

Polyborus plancus audubonii -- Renamed: Northern Crested Caracara (Caracara cheriway)

AUDUBON’S CRESTED CARACARA

Family: Falconidae

Threatened: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=B06Q)

• USFWS, 2012b (http://ecos.fws.gov/docs/five_year_review/doc2507.pdf)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?sourceTemplate=tabular_repor

t.wmt&loadTemplate=species_RptComprehensive.wmt&selectedReport=RptComprehen

sive.wmt&summaryView=tabular_report.wmt&elKey=101875&paging=home&save=tru

e&startIndex=1&nextStartIndex=1&reset=false&offPageSelectedElKey=101875&offPag

eSelectedElType=species&offPageYesNo=true&post_processes=&radiobutton=radiobutt

on&selectedIndexes=101875)

Description:

While listed as Audubon’s crested caracara (Polyborus plancus audubonii), taxonomic research 

has revealed that the Florida population should be recognized as the northern crested caracara 

(Caracara cheriway) (Dove and Banks, 1999; Integrated Taxonomic Information System, 2008). 

Minor variations between populations do not warrant recognition of subspecies within C. 

cheriway (Dove and Banks, 1999). This taxonomic change has been accepted by the scientific 

community. 

The long neck, long yellow legs, and massive gray-blue bill of the caracara make its appearance 

unique among the raptors. About 58 cm in length, the crested caracara has a white head and 

throat, white wing tips, and white tail contrasting with a dark body, red face, and signature black 

crest.

Geographic Boundaries and Spatial Distribution:

Caracara cheriway (CRCA) ranges from northern Brazil, through Central America and Mexico, 

north to the United States (except Guadalupe Island) (Dove and Banks, 1999). The range in 

Florida has shrunk; it formerly ranged commonly from northern Brevard County south to Fort 

Pierce, Lake Okeechobee, and Rocky Lake (Hendry County), but it is now only rarely found as 
2013 VGP and sVGP BE Appendix F

F-192

far north as Orlando or east of the St. Johns River. It is most abundant in five-county area 

(Glades, De Soto, Highlands, Okeechobee, and Osceola counties) north and west of Lake 

Okeechobee (Matthews and Moseley 1990). Small numbers occur in Arizona, where the range is 

probably as large now as formerly (Ellis et al., 1988). In Texas, has declined in recent decades, 

but now increasing over much of its range there (Ellis et al., 1988). Records from Washington, 

Oregon, and California, and north to Wyoming, Ontario, Pennsylvania, New York, and New 

Jersey are of individuals of "questionable origin" (AOU, 1998, 2000).

Habitat: (no critical habitat)

Habitat heterogeneity is necessary in maintaining suitable CRCA habitat (Root and Barnes,

2007). Primary CRCA habitat in Florida consists of prairies interspersed with marshes and 

cabbage palm hammocks (Morrison and Humphrey, 2001). Current habitat use of CRCA, based 

on habitat evaluations conducted proximal to nest sites, includes (ranked highest to lowest 

proportion): improved pasture, dry prairie, freshwater marsh, mixed upland hardwoods, shrub 

swamp, shrub and brushland, grassland, pinelands, bare soil, urban, other agriculture, citrus, and 

scrub (Morrison, 2006). Core CRCA habitat (i.e., a 95 percent kernel of high density area) lies 

within the Kissimmee Prairie, located northwest of Lake Okeechobee, and includes less than 

1000 km2 of suitable habitat (Root and Barnes, 2007). Only 15 percent of the habitat in this core 

area is managed (Root and Barnes, 2007).

Nesting habitat may be limiting CRCA population growth (Root and Barnes, 2007). CRCA most 

frequently nest in cabbage palms within pasture or grassland habitat, but a few nests have been 

observed in cypress, live oak, pine, and other trees (Bent, 1938; Sprunt, 1954; Service, 1989; 

Morrison et al., 1997; Morrison, 2007). 

Life History:

CRCAs have a relatively long lifespan. Annual survival estimates suggest a lifespan of 8 to 10 

years (Morrison, 2003), and banding records indicate wild individuals living over 20 years 

(Morrison, 2009). The age at first breeding is approximately 3 years (Morrison, 2009); many 

birds over 3 years of age, if unable to find breeding sites, remain as non- breeders (Dwyer,

2009). Clutch size averages two eggs (Dickinson and Arnold, 1996; Layne, 1996; Morrison,

1999) and young fledge after 8 weeks (Layne, 1978). Double-brooding has been documented, 

but second clutches are generally not as successful as first attempts (Morrison, 1996; 1998). 

Historical Information:

Its historic range in Florida generally consisted of St. Johns River marshes in Brevard County 

and the major prairie ecosystem originally present within Highland, Glades, Polk, Osceola, 

Okeechobee, Hardee, Desoto, Indian River, St. Lucie, and Martin Counties (Davis, 1967; 

Morrison, 2006). The Florida population has undergone a long-term decline through the 1900s; 

in the mid-1970s, it was estimated at a minimum of 350-400 (Evans, 1982, USFWS, 1987); in 

1987, at 300 adults and about 200 immatures (less than 1/3 of population in 1900); and in 1990 

at a minimum of 500 individuals (USFWS, 1990).

Conservation Status:

Abundance estimates have been dubious and continue to be problematic due to the bird’s low 

detectability and surveyors’ limited access to suitable habitat on private lands (Humphrey and 
2013 VGP and sVGP BE Appendix F

F-193

Morrison, 1997). Population trends are also difficult to interpret because of the bird’s long 

lifespan, site-fidelity, and the lack of data on recruitment rates of young (Morrison, 1996). Based 

on current knowledge of over 150 nest sites within a limited portion of the bird’s range in 

Florida, over 500 individuals inhabit Florida (Morrison, 2009). 

Summary of Major Threats:

In the U.S., declines have been associated with conversion of habitat to agriculture, residential 

development, and illegal shooting and trapping; increase in roads and traffic has resulted in 

increased mortality as the birds feed on road kills. Range has expanded in tropical America 

concurrent with deforestation; invasion of woody species with overgrazing tends to degrade 

habitat and result in declines (Ellis et al., 1988). In Texas, Dickinson (1995, Wilson Bull. 

107:761-762) observed two instances of red imported fire ant predation on caracara hatchlings.

F.7.22.

Pristis pectinata

SMALLTOOTH SAWFISH

(See Houston, Texas for information on this species)

F.7.23.

Puma concolor coryi

FLORIDA PANTHER

Family: Felidae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=A008)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Puma+concolor

+coryi)

• USFWS, 2012b (http://ecos.fws.gov/docs/recovery_plan/081218.pdf)

Description:

The Florida panther is a large, long-tailed cat with a great deal of color variation: pale brown or 

rusty upper parts, dull white or buff under parts; tail tip, back of ears, and sides of nose are dark 

brown or blackish. Mature male panthers examined in the wild in Florida since 1978 have 

weighed from 102 to 154 pounds (Roelke 1990, Roelke and Glass, 1992) and measured nearly 7 

feet from nose to tip of tail. Females were considerably smaller, with a weight range of 50 to 108 

pounds (Roelke, 1990) and measuring about 6 feet (U.S. Fish and Wildlife Service, 1987). The 

skull of the Florida panther is unique in that it has a broad, flat, frontal region, and broad, higharched or upward-expanded nasal bones (Young and Goldman, 1946).

Florida panther kittens are gray with dark brown or blackish spots and five bands around the tail. 

The spots gradually fade as the kittens grow older and are almost unnoticeable by the time they 

are six months old. At this age, their bright blue eyes slowly turn to the light-brown straw color 

of the adult (Belden, 1988).
2013 VGP and sVGP BE Appendix F

F-194

Geographic Boundaries and Spatial Distribution:

The species occurs primarily in swampland in southern Florida; apparently ranged formerly 

throughout the southeastern U.S., but now probably extirpated in states other than Florida. They 

occupy less than 15,000 square km primarily in southern Florida: Fakahatchee Strand, Big 

Cypress National Preserve/Florida Panther National Wildlife Refuge, southern portion of 

Everglades Conservation Area, Everglades National Park (from Hole-in-the-Donut area 

northward), Big Cypress Seminole Indian Reservation, and private ranches and preserves in parts 

of Collier, Hendry, Lee, and Glades Counties (Maehr, 1992, Matthews and Moseley, 1990). It 

has also recently known from Highlands, Palm Beach, Broward, Martin, Osceola, Volusia, and 

St. Johns Counties, though reproduction has not been recorded in these areas (Maehr, 1992).

Habitat: (no critical habitat)

Panthers are wide-ranging, secretive, and occur at low densities. They require large contiguous 

areas to meet their social, reproductive, and energetic needs. Panther habitat selection is related 

to prey availability (i.e., habitats that make prey vulnerable to stalking and capturing are 

selected). Dense understory vegetation provides some of the most important feeding, resting, and 

denning cover for panthers. Telemetry monitoring and ground tracking indicate that panthers 

select forested habitat types interspersed with other habitat types that are used in proportion to 

their availability.

Generally the Florida panther occurs in heavily forested areas in lowlands and swamps, also 

upland forests in some parts of range; areas with adequate deer or wild hog population. Habitats 

include tropical hammocks, pine flatwoods, cabbage palm forests, mixed swamp, cypress 

swamp, live oak hammocks, sawgrass marshes, and Brazilian pepper thickets; depends on large 

contiguous blocks of wooded habitat, though interspersed fields and early successional habitats 

may be beneficial through their positive effect on prey populations; day-use sites typically are 

dense patches of saw palmetto surrounded by swamp, pine flatwoods, or hammock (Maehr 

1992). Dees et al. (2001) found a strong selection for pine stands burned within one year. Young 

are born in dense thickets or fallen timber, or in other sites providing adequate cover.

Life History:

Male Florida panthers are polygynous, maintaining large, overlapping home ranges containing 

several adult females and their dependent offspring. The first sexual encounters for males 

normally occur at about three years based on 26 radio-collared panthers of both sexes (Maehr et 

al., 1991a). Based on genetics work, some males may become breeders as early as 17 months 

(W. Johnson, National Cancer Institute, pers. comm. 2005). Breeding activity peaks from 

December to March (Shindle et al., 2003). Litters are produced throughout the year, with 56-60% 

of births occurring between March and June (Jansen et al., 2005; Lotz et al., 2005). The greatest 

number of births occurs in May and June (Jansen et al., 2005, Lotz et al., 2005). Female panthers 

have bred as young as 18 months (Maehr et al., 1989a) and successful reproduction has occurred 

up to 11 years old. Average litter size is 2.4 kittens.

Panther dispersal begins after a juvenile becomes independent from its mother and continues 

until it establishes a home range. Male Florida panthers disperse an average distance of 25 miles 

(40 km); females typically remain in or disperse short distances from their natal ranges 
2013 VGP and sVGP BE Appendix F

F-195

(Comiskey et al., 2002). Panthers require large areas to meet their needs. Numerous factors 

influence panther home range size including habitat quality, prey density, and landscape 

configuration (Belden, 1988; Comiskey et al., 2002). Home range sizes of 26 radio-collared 

panthers monitored between 1985 and 1990 averaged 200 mi2 (519 km2) for resident adult males 

and 75 mi2 (193 km2) for resident adult females

Activity levels for Florida panthers are greatest at night with peaks around sunrise and after 

sunset (Maehr et al., 1990a). The lowest activity levels occur during the middle of the day. 

Female panthers at natal dens follow a similar pattern with less difference between high and low 

activity periods. 

Interactions between panthers occur indirectly through urine markers or directly through contact. 

Urine markers are made by piling ground litter using a backwards-pushing motion with the hind 

feet. This pile is then scent-marked with urine and occasionally feces. Both sexes make urine 

markers, apparently males use them as a way to mark their territory and announce presence while 

females advertise their reproductive condition.

Primary panther prey is white-tailed deer and feral hog (Maehr et al., 1990b; Dalrymple and 

Bass, 1996). Secondary prey includes raccoons, nine-banded armadillos, marsh rabbits (Maehr et 

al. 1990b) and alligators (Dalrymple and Bass, 1996). No seasonal variation in diet has been 

detected. A resident adult male puma generally consumes one deer-sized prey every 8-11 days; 

this frequency is 14-17 days for a resident female; and 3.3 days for a female with three 13-month 

old kittens (Ackerman et al., 1986). Maehr et al. (1990b) documented domestic livestock 

infrequently in scats or kills, although cattle were readily available on their study area.

Historical Information:

The Florida panther once ranged throughout the southeastern U.S. from Arkansas and Louisiana 

eastward across Mississippi, Alabama, Georgia, Florida, and parts of South Carolina and 

Tennessee (Young and Goldman 1946) (Figure 1). Historically, the panther intergraded to the 

north with Puma concolor cougar, to the west with Puma concolor stanleyana, and to the 

northwest with Puma concolor hippolestes (Young and Goldman 1946). Although generally 

considered unreliable, sightings of panthers regularly occur throughout the Southeast. However, 

no reproducing populations of panthers have been found outside of south Florida for at least 30 

years despite intensive searches to document them (Belden et al., 1991; McBride et al., 1993; 

Clark et al., 2002). Survey reports and more than 70,000 locations of radio-collared panthers 

recorded between 1981 and 2004 clearly define the panther’s current breeding range. 

Conservation Status:

The Florida panther is the last subspecies of Puma still surviving in the eastern United States. 

Historically occurring throughout the southeastern United States, today the panther is restricted 

to less than 5% of its historic range in one breeding population located in south Florida. The 

panther population has increased from an estimated 12-20 (excluding kittens) in the early 1970s 

to an estimated 100 - 120 in 2007. While the species as a whole is not close to extinction, this 

formerly widespread subspecies has undergone a severe decline in numbers and range and is now 

restricted to a small area.
2013 VGP and sVGP BE Appendix F

F-196

Summary of Major Threats:

A major limiting factor in southern Florida appears to be availability of suitable habitat (Belden 

et al., 1988). Habitat loss and alteration have resulted from logging, drainage, oil field activity, 

housing development, citrus agriculture, and road construction. Though continuing urbanization 

and agricultural development of habitat has been regarded as the greatest threat, mercury 

contamination apparently is another major threat, especially where panthers feed most 

extensively on raccoons (Jordan, 1990; Roelke et al., 1992). Collisions with vehicles (most 

common around the Fakahatchee Strand) are the greatest known mortality factor, but these are 

relatively easy to document (Maehr, 1992). Threatened also by loss of genetic variability, which 

evidently is responsible for recently observed congenital heart defects, reproductive 

abnormalities (high incidence of unilateral cryptorchidism) (Barone et al., 1994), and possible 

immune deficiencies. Hunting of deer (a primary food resource) may be an additional threat.

F.7.24.

Rostrhamus sociabilis plumbeus

EVERGLADE SNAIL KITE

Family: Accipitridae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=B00F)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Rostrhamus+soc

iabilis+plumbeus)

• USFWS, 2012b (http://ecos.fws.gov/docs/federal_register/fr151.pdf)

Description:

The Everglade snail kite is a medium-sized hawk with a wingspan of about 45 inches, very 

similar to the marsh hawk but without wavering, tilting flight. The beak is slender and very 

hooked. The adult males are slate gray with black head and wing tips, a white patch at the base 

of a square tail, and red legs. The female has a buffy body, heavily streaked with dark lines, a 

white line above the eye, a white tail patch, yellow legs, and red eyes. The immature kites 

resemble the females, only they are darker and their eyes are brown. 

Geographic Boundaries and Spatial Distribution:

The species is restricted to Florida, Cuba and the Isle of Pines. It formerly occurred in freshwater 

marshes throughout peninsular Florida. It is now restricted to St. Johns River headwaters; 

southwestern Lake Okeechobee; small areas in Broward, Dade, and Palm Beach Counties; parts 

of Everglades National Park, Loxahatchee National Wildlife Refuge, and Big Cypress National 

Preserve. The present distribution of the kite in Cuba is not well known.

Habitat: (has critical habitat)

In Florida, its habitat is large, open freshwater marshes and lakes with shallow (< 4 ft.) open 

waters. Open water areas without emergent vegetation are required for foraging and nests are 
2013 VGP and sVGP BE Appendix F

F-197

usually 1-5 m above water in low tree or shrub (commonly willow, wax myrtle, pond apple, or 

cattails). It is also occasionally sawgrass, maidencane (especially during low water) used for 

support (Palmer, 1988). Usually builds (mainly male) a new nest for each nesting attempt, 

though may build over old nest or in same location as old nest (Johnsgard, 1990).

Some observers report movements that they interpret as migration, but available evidence 

indicates birds are better characterized as nomadic, moving in response to changes in water level 

(Palmer, 1988, Stiles and Skutch, 1989). Some individuals banded in Florida have been found in 

Cuba.

Critical habitat was designated for the Everglade snail kite in August and September of 1977 in 

St. John’s Reservoir, Indian River County; Cloud Lake Reservoir, St. Lucie County; Strazzulla 

Reservoir, St. Lucie County; western parts of Lake Okeechobee, Glades and Hendry Counties; 

Loxahatchee National Wildlife Refuge, Palm Beach County; Central and Southern Flood Control 

District Water Conservation Area 2A, Palm Beach and Broward Counties; Central and Southern 

Flood Control District Water Conservation Area 2B, Broward County; Central and Southern 

Flood Control District Water Conservation Area 3A, Broward and Dade Counties; and a portion 

of the Everglades National Park, Dade County.

Life History:

The species eats small, slow-moving, shelled animals. The snail kite is uniquely adapted for a 

diet almost exclusively of freshwater apple snails (Pomacea paludosa). As of 1987, there were 

only five documented occurrences of Everglade snail kites preying on non-snail items. Exclusive 

utilization of the genus Pomacea is apparently because this is the only large Florida snail 

occurring near the surface. The kite extracts the snail from the shell by means of its greatly 

curved beak.

The main nesting period is January-August (eggs laid mainly February-April). Clutch size is 

usually 2-3 in Florida. Incubation, by both sexes, lasts 26-30 days. Young are tended by both 

sexes 3-6 weeks, then one adult deserts (and may renest) unless snails are scarce. Young fledge 

at 23-28 days according to Matthews and Moseley (1990). Nestling period in Florida averaged 

29 days (see Johnsgard, 1990). First breeds at 1-2 years (reaches breeding age at 10 months 

according to Matthews and Moseley, 1990). 

Historical Information:

Population and range have declined dramatically since river channelization and drainage of 

wetlands began in 19th and 20th centuries. It was a listed as an endangered species in 1967.

Conservation Status:

Occurrences may change from year to year, dependent upon water levels. Bennetts et al. (1999) 

estimate about 650 in Florida in 1994 and comment on interpretations of censuses from 1969 

through 1994. Other Florida population estimates: 25-60 in the mid-1960s, 250-650 in the early 

1980s, 668 in 1984, as low as 326 in 1987; a 1989 survey recorded 464 kites (USFWS, 1990).
2013 VGP and sVGP BE Appendix F

F-198

Summary of Major Threats:

Habitat destruction, principally via wetland drainage and conversion for agriculture, is the major 

threat. Agricultural runoff has caused pollution and eutrophication of much of habitat below 

Lake Okeechobee. Introduction of exotic plants (e.g., water hyacinth, water lettuce, torpedo 

grass, and hydrilla) prevents feeding. Other threats include illegal shooting by humans,

particularly during waterfowl hunting season.

F.7.25.

Schwalbea americana

AMERICAN CHAFFSEED

Family: Scrophulariaceae

Endangered: wherever found

Sources:

• USFWS, 2012b

(http://ecos.fws.gov/speciesProfile/profile/speciesProfile.action?spcode=Q2I4)

• NatureServe Explorer, 2012 

(http://www.natureserve.org/explorer/servlet/NatureServe?searchName=Schwalbea+ame

ricana)

• USFWS, 2012b (http://ecos.fws.gov/docs/recovery_plan/950929c.pdf)

Description:

American chaffseed is a monotypic perennial member of the figwort family, Scrophulariaceae, in 

the tribe Euphrasieae. It is an erect herb with unbranched stems or stems branched only at the 

base, growing to a height of 3.0 to 6.0 cm (12 to 24 in.). The plant is densely albeit minutely 

hairy throughout, including the flowers. The leaves are alternate, lance-shaped to elliptic, 

stalkless, 2.5 to 5.0 cm (0.8 to 2 in.) long, and entire; the upper leaves are reduced to narrow 

bracts. The large, purplish-yellow, tubular flowers, 3.0 to 3.5 cm long (1.2 to 1.4 in.) are borne 

singly on short stalks in the axils of the uppermost, reduced leaves (bracts) and form a manyflowered, spike-like raceme. The showy flowers have a high degree of bilateral symmetry 

elaborated for pollination by bees (Pennell, 1935). The fruit is a narrow capsule approximately 

10 to 12 mm (0.4 to 0.5 in.) long, with a septicidal dehiscence. The numerous seeds are pale 

greenish brown or yellowish-tan, narrowly linear, somewhat flattened or compressed, slightly 

curved, and enclosed in a loose-fitting, sac-like structure that provides the basis for the common 

name, chaffseed (Musselman and Mann, 1978). Flowering occurs from April to June in the 

southern part of the species’ range, and from June to mid-July in the northern part of its range. 

Fruits mature from early summer in the South to October in the North (Johnson, 1988).

Geographic Boundaries and Spatial Distribution:

It is primarily a coastal plain species off the Atlantic and Gulf coasts. Exceptions to its coastal 

distribution, all of which are historical records, include: an occurrence in the sand plains near 

Albany, New York, which Pennell (1935) considered a possible remnant population of glacial 

migration along the shores of the Hudson River; occurrences from Tennessee and Kentucky on 

sandstone knobs and ridges of the Cumberland Plateau and Highland Rim; an inland site on the 
2013 VGP and sVGP BE Appendix F

F-199

Montague sand plain near the Connecticut River; and a sand plain in Hubbardston, 

Massachusetts (The Nature Conservancy, 1993).

Habitat: (no critical habitat)

Characteristically, the chafseed occurs in sandy (sandy peat, sandy loam), acidic, seasonally 

moist to dry soils. The species is generally found in habitats described as pine flatwoods, firemaintained savannas, ecotonal areas between peaty wetlands and xeric sandy soils, and other 

open grass-sedge systems (Kral, 1983). It appears to be shade intolerant and, therefore, occurs in 

areas maintained in an open to partially open condition.

Historically, the species was reported to exist on savannas and pinelands throughout the coastal

plain. It also occurred inland on sandstone knobs and plains where frequent, naturally occurring 

fires maintained open grass and herbaceous communities or partially open forest communities 

such as those dominated by longleaf pine. Under such conditions, herbaceous plants avoided 

competition from trees and shrubs. Most of the surviving populations, including the most 

vigorous, are in areas that are still subject to frequent fire.

Life History:

The root parasitic behavior has been known since 1856 (Musselman and Mann, 1977). As with 

many Scrophulariaceae, it exhibits hemiparasitic behavior. Hemiparasites (also called 

semiparasites) contain chlorophyll and can produce all or part of their own food, as opposed to 

holoparasites, which lack chlorophyll and are entirely dependent on host plants for food and 

water. Haustoria developing from roots are unique among Scrophulariaceae parasites in that a 

well-developed neck, interrupted zone, a sclerotic layer, and a very broad endophyte are present. 

It produces showy, insect-pollinated flowers with a high degree of zygomorphy elaborated for 

pollination by bees (Pennell, 1935). On Fort Bragg, bumblebees were observed visiting 

Schwalbea flowers exclusively (The Nature Conservancy, 1993) and observations of insect 

visitation suggest that probable pollinators are worker bumblebees (Kirkman, 1993).

Historical Information:

American chaffseed (Schwalbea americana) was listed as an endangered species on September 

29, 1992. The range of American chaffseed once included all the coastal States from 

Massachusetts to Louisiana, and the inland States of Kentucky and Tennessee. Although the 

range was widespread, the historical record shows that the species was always relatively rare and 

local in distribution.

Conservation Status:

Currently, 72 occurrences of this species are known to be extant in New Jersey, North Carolina, 

South Carolina, Georgia, and Florida. At the time of listing, 19 extant occurrences were known; 

the increase in the number of known occurrences is the result of extensive searches for the 

species in North and South Carolina (Fort Bragg has about 6,000 plants; one occurrence in South 

Carolina has >2,000)
2013 VGP and sVGP BE Appendix F

F-200

Summary of Major Threats:

The plant has been, and continues to be, endangered by development and by succession of its 

habitat. Sandy pineland communities where the species exists have proven to be especially 

vulnerable to development because soils are level, deep, and suitable for building sites. In 

addition, many populations were or are very near the Atlantic Coast where development 

pressures are high (Rawinski and Cassin, 1986). While the demise of many populations can be 

attributed to direct loss of habitat to development (Rawinski and Cassin, 1986; Johnson, 1988; 

The Nature Conservancy, 1993), development also presents indirect threats to the species, as 

urbanization generally results in total fire suppression, which ultimately leads to the loss of the 

open ecosystems. Continuing concerns regarding the species survival on private lands include 

discontinuation of game management and subsequent cessation of burning resulting in 

vegetational succession and loss of suitable habitat; conversion of the fire-maintained flatwoods 

and savannas to commercial pine plantations, which can create dense canopies unsuitable for 

Schwalbea; and direct destruction of Schwalbea plants due to the placement of firebreaks or the 

planting of game food plots or other extensive soil disturbances. 

Occurrences of American chaffseed along roadsides are especially vulnerable to disturbance and 

loss. Besides succession of habitat, actions such as direct trampling, herbicide application and 

road maintenance can adversely affect the plants. Another potential threat to the New Jersey 

population is herbivory. A single white-tailed deer herbivory episode in May 1994 severely 

affected flowering of the population. Most of the plants, which were severed at the base, grew 

back, often in multiple branches, but did not grow to full size and did not flower (T. Hampton in 

litt. 1995).

F.7.26.

Sterna dougallii dougallii

ROSEATE TERN

(See New York, New York for information on this species)

F.7.27.

Trichechus manatus

WEST INDIAN MANATEE

(See Houston, Texas for information on this species)

F.8. REFERENCES 

Crocodilian Species List. 2012. Crocodylus acutus (Cuvier, 1807). Retrieved from

http://crocodilian.com/cnhc/csp_cacu.htm. Accessed March 2012.

“Designation of Critical Habitat: Critical Habitat for Johnson’s Seagrass.” Federal Register 65 

(April 5, 2000): 17786-17804. Print.

“Endangered and Threatened Species; Critical Habitat for Threatened Elkhorn and Staghorn 

Corals.” Federal Register 73 (November 26, 2008): 72210-72240. Print.

“Endangered and Threatened Wildlife and Plants; Cirtical Habitat Revised Designation for the 

Cape Sable Seaside Sparrow.” Federal Register 72 (November 6, 2007): 62736-62766. 

Print.
2013 VGP and sVGP BE Appendix F

F-201

“Endangered and Threatened Wildlife and Plants; Designation of Critical Habitat for Cirsium 

hydrophilium var. hydrophilium (Suisan thistle) and Cordylanthus mollis ssp. Mollis (soft 

bird’s-beak).” Federal Register 72 (April 12, 2007): 18518-18553. Print.

“Endangered and Threatened Wildlife and Plants; Designation of Critical Habitat for Four 

Vernal Pool Crustaceans and Eleven Vernal Pool Plants.” Federal Register 71 (February 

10, 2006): 7118-7316. Print.

“Endangered and Threatened Wildlife and Plants; Designation of Critical Habitat for Pacific 

Coast Population of the Western Snowy Plover.” Federal Register 70 (September 29, 

2005): 56970-57119. Print.

“Endangered and Threatened Wildlife and Plants; Designation of Critical Habitat for Seven 

Evolutionarily Significant Units of Pacific Salmon and Steelhead in California.” Federal 

Register 70 (September 2, 2005): 52488-52627. Print.

“Endangered and Threatened Wildlife and Plants; Designation of Critical Habitat for the 

California Tiger Salamander, Central Population.” Federal Register 70 (August 23, 

2005): 49380-49458. Print.

“Endangered and Threatened Wildlife and Plants; Designation of Critical Habitat for the 

Alameda Whipsnake.” Federal Register 71 (October 2, 2006): 58176-58231. Print.

“Endangered and Threatened Wildlife and Plants; Designation of Critical Habitat for the Gulf 

Sturgeion.” Federal Register 68 (March 19, 2003): 13370-13495. Print.

“ Endangered and Threatened Wildlife and Plants; Final Designation of Critical Habitat for Four 

Vernal Pool Plants in California and Southern Oregon; Evaluation of Economic 

Exclusions From August 2003 Final Designation.” Federal Register 70 (August 11, 

2005): 46924-46999. Print.

“Endangered and Threatened Wildlife and Plants; Revised Designation of Critical Habitat for the 

California Red-Legged Frog.” Federal Register 75 (March 17, 2010): 12816-12959. 

Print.

“Endangered and Threatened Wildlife and Plants; Revised Critical Habitat for the Pacific Coast 

Population of the Western Snowy Plover.” Federal Register 76 (March 22, 2011): 16046-

16165. Print.

“Endangered and Threatened Wildlife and Plants; Revised Designation of Critical Habitat for the 

Sonoma County Distinct Population Segment of California Tiger Salamander.” Federal 

Register 76 (August 31, 2011): 54346-54372. Print.

Florida Natural Areas Inventory. 2001. Eastern Indigo Snake. Field Guide to the Rare Animals 

of Florida. Retrieved from http://www.fnai.org/fieldguide/pdf/drymarchon_couperi.pdf. 

(Accessed March 2012).
2013 VGP and sVGP BE Appendix F

F-202

GLEC. 2011. Biological Evaluation for the Region 2 ESA Consultation on New Jersey’s Revised 

Saltwater Cyanide Water Quality Standards. Prepared for the United States 

Environmental Protection Agency, Region II. Great Lakes Environmental Center, Dated 

August 2, 2011. 

Goals Project. 2000. Baylands Ecosystem Species and Community Profiles: Life histories and 

environmental requirements of key plants, fish and wildlife. Prepared by the San 

Francisco Bay Area Wetlands Ecosystem Goals Project. P.R. Olofson, editor. San 

Francisco Bay Regional Water Quality Control Board, Oakland, Calif. Retrieved from

http://www.sfestuary.org/pdfs/speciescommunity/Species_and_Community_Profiles%5BPart1%5D.pdf.

Hallam, Charlotte O., Kimberly Wheaton, Richard A. Fischer. 1998. Species Profile: Eastern 

Indigo Snake (Drymarchon corais couperi) on Military Installations in the Southeastern 

United States. USACE. Retrieved from http://www.dtic.mil/cgibin/GetTRDoc?AD=ADA342329. (Accessed March 2012).

NatureServe Explorer. 2012. NatureServe Explore: An Online Encyclopedia of Life. Retrieved 

from http://www.natureserve.org/explorer/. (Accessed March 2012).

NJDEP. 2012. New Jersey’s Endangered and Threatened Wildlife. New Jersey Division of Fish 

and Wildlife. Retrieved from http://www.njfishandwildlife.com/tandespp.htm. (Accessed 

March 2012).

NYDEC. 2012. Endangered and Threatened Fishes of New York. New York Department of 

Environmental Conservation. Retrieved from http://www.dec.ny.gov/animals/7008.html. 

Accessed March 2012.

NOAA Fisheries. 2012. National Oceanic and Atmospheric Administration (NOAA) Fisheries: 

Office of Protected Resources. Retrieved from http://www.nmfs.noaa.gov/pr/. Accessed 

March 2012.

UMMZ. 2012. Animal Diversity Web. University of Michigan Museum of Zoology. Retrieved 

from http://animaldiversity.ummz.umich.edu/site/index.html. (Accessed March 2012).

University of California, Berkeley, 2012. Essig Museum of Entomology. Retrieved from

http://essig.berkeley.edu/. (Accessed March 2012).

USEPA. 2008. Biological Evaluation of Oregon’s Water Quality Criteria for Toxics. U.S. 

Environmental Protection Agency, Region 10. Dated January, 2008. 

USEPA. 2009. Draft Biological Opinions Issued Under the Endangered Species Act, by the 

National Marine Fisheries Services, Related to Pesticides and Pacific Salmon and 

Steelhead Species. Retrieved from http://www.epa.gov/espp/litstatus/effects/draft-biopmarch09.pdf. 
2013 VGP and sVGP BE Appendix F

F-203

USEPA. 2010. Biological Evaluation for the United States Environmental Protections Agency’s 

(EPA) Pesticides General Permit (PGP). 

USFWS, 2003. Bull Trout (Salvelinus confluentus). Retrieved from

http://library.fws.gov/Pubs/bulltrt03.pdf. (Accessed March 2012).

USFWS, 2012a. Endangered Species Midwest Region. Retrieved from

http://www.fws.gov/midwest/endangered/index.html. (Accessed March 2012).

USFWS. 2012b. Environmental Conservation Online System (ECOS). Retrieved from

http://ecos.fws.gov/ecos/indexPublic.do#. (Accessed March 2012).

USFWS, 2012c. North Florida Ecological Services Office. Retrieved from

http://www.fws.gov/northflorida/. (Accessed March 2012).

USFWS, 2012d. Oregon Fish and Wildlife Office. Retrieved from

http://www.fws.gov/oregonfwo. (Accessed March 2012).

USFWS, 2012e. Virginia Ecological Services, Northeast Region. Retrieved from

http://www.fws.gov/northeast/virginiafield/. (Accessed March 2012).

Yolo Natural Heritage Program, 2012. Draft Species Accounts. Retrieved from

http://www.yoloconservationplan.org/yolo_pdfs/speciesaccounts/invertebrates/valleyelderberry-longhorn-beetle.pdf. (Accessed March 2012).
2013 VGP and sVGP BE Appendix G 

Appendix G. Methodology for Hypothetical Harbor Modeling 
2013 VGP and sVGP BE Appendix G 

G-1

The purpose of Appendix G is to provide additional details and descriptions of the methodology 

for the hypothetical harbor modeling and exposure concentrations presented in Section 5.2.1. Appendix G 

discusses the following topics: 

 Model selection process for the BE; 

 Selection of estuary and river model input values; 

 Development of RAA loading scenarios; 

 Presentation of the raw data for vessel-specific loading rates; and 

 Presentation of the total loads for RAA loading scenarios. 

G.1 MODEL SELECTION

VGP and sVGP vessels discharge into coastal and inland waters throughout the United 

States. Estuarine models, which are commonly used to assess coastal harbor water quality, 

consist of two primary components: hydrodynamics (i.e., water transport processes) and water 

quality. Estuarine models are generally classified into the following four levels according to the 

temporal and spatial complexity of the hydrodynamic component of the model: 

 Level I - Desktop screening models that calculate seasonal or annual mean 

concentrations based on steady-state conditions and simplified flushing time 

estimates. 

 Level II - Computerized steady-state or tidally averaged quasi-dynamic simulation 

models, which generally use a box or compartment-type network. 

 Level III - Computerized one-dimensional (i.e., estuary is well-mixed vertically and 

laterally) and quasi-two-dimensional (i.e., a link-node system describes estuary 

longitudinal and lateral mixing) dynamic simulation models. 

 Level IV - Computerized two-dimensional (i.e., represents estuary longitudinal and 

lateral mixing) and three-dimensional (i.e., represents estuary longitudinal, lateral, 

and vertical mixing) dynamic simulation models (EPA, 2001). 

The sheer number of different coastal harbor environments potentially impacted by these vessels means 

that EPA would need to consider wide ranging environmental conditions. Using a Level I screening 

model provides an opportunity for the Agency to evaluate “best case” and “worst scenarios” under a wide 

range of environmental conditions for this BE. 

 Similar to estuarine models, river models can range in complexity from simple steady state 

representations of a river to more dynamic fate and transport models that compartmentalize the river 

environment and capture spatial and temporal variations in river inputs. The wide range of river 

environments potentially impacted by vessels covered under the VGP and sVGP also means that EPA 

would need to consider wide ranging environmental conditions to support the BE effects analysis. For 

these reasons, EPA selected a Level I screening-level model, the “fraction of freshwater model,” to 

calculate receiving water concentrations for coastal harbors, and a steady state dilution equation for the 

river systems to support the effects analysis further described in Section 5.2. 
2013 VGP and sVGP BE Appendix G 

G-2

G.1.1 Fraction of Freshwater Model For Hypothetical Estuarine Harbor

The “fraction of freshwater model” is a series of equations that represent the harbor 

environment in zero dimensions and at a steady state (USEPA, 2001). These calculations are 

zero-dimensional in that they estimate concentrations at a given point in a water body within a 

specified, spatially homogenous volume. For example, the calculations assume instantaneous and 

homogeneous mixing of vessel discharges within the defined volume of a given harbor. It does 

not account for gradients of concentrations that would occur within a certain distance from 

discharge source(s) such as plumes from vessels and other sources. Specifying plumes and 

accounting for locations of numerous discharge sources would require a two- or threedimensional model, which is beyond this Level I screening-level analysis. 

Steady state means that the calculations provide an instantaneous estimate of the 

concentration under the assumption of chemical and physical equilibrium. Chemical equilibrium 

means that the water body salinity and the vessel discharge analyte concentrations do not change 

over time, while physical equilibrium means that the volume of water in the water body, tides, 

currents, and vessel discharge flow rates do not change over time. The assumption is that every 

process occurs instantaneously; therefore, temporal variability is not a factor. Accounting for 

changes in tides, currents, river flow, vessel discharge flow rates, and discharge concentrations 

over time would require a dynamic model, which is beyond this Level I screening-level model. 

This aspect of the model may cause it to underestimate localized environmental impacts, 

especially in areas with inadequate flushing. However, in estimating quantities of pollutants 

discharged from the various discharge types, EPA has tended to use conservative parameter 

estimates (i.e., estimates that may overstate the average value) for variables such as flow and 

pollutant concentration. 

The “fraction of freshwater model” calculates the analyte concentration in a harbor 

resulting from vessel discharges using the following four steps: 

 Step 1: Calculate vessel discharge analyte loading rates (Equations G-1 and G-2) 

 Step 2: Calculate the fraction of freshwater in the hypothetical harbor (Equation G-3) 

 Step 3: Calculate the hypothetical harbor flushing time (Equation G-4) 

 Step 4: Calculate the hypothetical harbor analyte concentration (Equation G-5) 

The following subsections describe the input requirements, assumptions, and calculations for each step in 

the “fraction of freshwater model.” 

G.1.1.1 Step: Calculate Vessel Discharge Analyte Loading Rates 

Analyte-specific total discharge loading rates (We) are required as input values in the 

“fraction of freshwater model” and the river dilution equation to calculate the instantaneous 

analyte concentrations in the harbor (Cx). In this analysis, EPA estimated analyte loading rates 

using the following four input parameters: 
2013 VGP and sVGP BE Appendix G 

G-3

 Estimated average analyte concentrations for each vessel type discharge type; 

 Estimated flow rate for each discharge type for each vessel type; 

 Estimated number of vessels per vessel type present in the harbor; and 

 Percentage of vessels per vessel type discharging each discharge type in the harbor 

(Equation 5-1). 

We,z = ∑( Ce,y,z* Qy,z * N,z) Equation G-1 

 Where: 

We,z = Discharge loading rate for analyte e from vessel type z (mass/time) 

Ce,y,z = Average concentration of analyte e in discharge y from vessel type z 

(mass/volume) 

Qy,z = Flow rate for discharge y from vessel type z (volume/time) 

N,z = Number of vessels equivalents of vessel type z present in the harbor 

EPA calculated the analyte-specific total discharge loading rate by summing the 

discharge loading rates for that analyte from each vessel type (Equation 5-2). 

We = ∑( We,z) Equation G-2 

 Where: 

We = Total discharge loading rate for analyte e from study vessel 

discharges (mass/time) 

We,z = Discharge loading rate for analyte e from vessel type z (mass/time) 

G.1.1.2 Step 2: Calculate the Fraction of Freshwater in the Hypothetical Harbor 

The “fraction of freshwater model” estimates analyte concentrations in one dimension 

using information on freshwater inflow and by comparing salinity in the harbor with salinity in 

the seawater at the mouth of the harbor (USEPA, 2001). The fraction of freshwater (fx) at any 

location in the estuary is calculated as: 

fx = (Ss – Sx)/Ss Equation G-3 
2013 VGP and sVGP BE Appendix G 

G-4

 Where: 

fx = Fraction of freshwater at location x in the model harbor (unit-less) 

Ss = Seaward boundary salinity at the mouth of model harbor (PSU) 

Sx = Salinity at location x in model harbor (PSU) 

EPA states that this ratio (fx ) “...can be viewed as the degree of dilution of the 

freshwater inflow (as well as pollutants) by seawater” from tidal influx in the harbor (USEPA, 

2001). 

G.1.1.3 Step 3: Calculate the Hypothetical Harbor Flushing Time 

Harbor flushing time is defined as the amount of time required to replace the freshwater 

volume of the harbor by the river freshwater input. The flushing time (t) of the model harbor is 

calculated using Equation 5-4: 

t = (V * fx)/Qfw Equation G-4 

 Where: 

t = Model harbor flushing time 

V = Volume of model harbor 

fx = Fraction of freshwater at location x in model harbor (unit-less) 

Qfw = Inflow of freshwater to model harbor from the model river 

(volume/time) 

G.1.1.4 Step 4: Calculate the Hypothetical Harbor Analyte Concentration 

The concentration of an analyte at location x (Cx) is the analyte-specific total loading rate 

(We, mass/time) divided by the flow rate away from location x, described by the volume of the 

harbor (V) divided by the flushing time (t) (USEPA, 2001): 

Cx,estuary = We/(V/t) Equation G-5 

 

 Where: 

Cx,estuary = Instantaneous analyte concentration at location x in hypothetical 

estuary harbor (mass/volume) 

We = Analyte-specific loading rate (mass/time) as calculated under Step 

1 

V = Volume of the model harbor as defined in Step 3 

t = Model harbor flushing time as calculated in Step 3 

G.1.2 Hypothetical River Harbor Dilution Model

EPA selected a dilution equation to model the receiving water concentrations for the river 

environments potentially impacted by vessel discharges covered under the VGP and sVGP. EPA 
2013 VGP and sVGP BE Appendix G 

G-5

used Equations G-1 and G-2 to estimate the pollutant-specific discharge load values for the river 

harbor environment. Equation G-6 calculates the receiving water concentration for the 

hypothetical river harbor environment. 

C x,river= We/Qriver Equation G-6 

 Where: 

Cx,river = Instantaneous analyte concentration at location x in 

hypothetical river harbor (mass/volume) 

We = Analyte-specific loading rate (mass/time) as calculated in 

Equation 5-2 

Qriver = Average annual river flow rate (volume/time) 

G.2 SELECTION OF MODEL INPUT VALUES

The “fraction of freshwater model” used to model the hypothetical estuary harbor 

requires the following four input parameters to define the water body characteristics: 

 Seaward boundary salinity at the mouth of the harbor (Ss) 

 Salinity at location x in the harbor (Sx) 

 Volume of the harbor (V) 

 Inflow of freshwater to the harbor (Qfw) 

EPA collected data on the four input parameters for the estuary harbors listed in Table G-1 to 

develop the water body characteristics for the ten hypothetical estuary harbor scenarios (see 

Table 5-7). Although EPA used the entire RAA to indentify the listed species evaluated in the 

BE, EPA selected a smaller subset of the estuary for the model to more accurately represent the 

primary area where vessels covered under the VGP and sVGP reside within the larger RAA. 

EPA limited the modeling area to the immediate port area and surrounding waters within 2 to 7 

miles from the port depending on the RAA. Table G-1 presents the environmental data identified 

by EPA for each estuary harbor considered for the model input parameters. EPA selected the 

input parameters for the hypothetical harbors’ salinity based on the minimum and maximum 

salinity presented in Table G-1. EPA selected the input parameters for the volume and river flow 

based on the minimum and average values collected for the estuary harbors in Table G-1. EPA 

chose to model the average rather than the maximum value for the river flow and volume to 

represent more typical flushing times the hypothetical estuary and evaluate a more conservative 

harbor scenario in the BE. For example, selecting the maximum river flow would effectively 

result in a greater amount of dilution in the harbor environment than assuming the average flow. 

To calculate the average, EPA selected the following harbors that most represented an estuary 

where the freshwater inflow is the primary driver for mixing in the estuary as indicated by a 

higher river flow and lower salinity value: Houston, New York, San Francisco, and Norfolk. 

EPA excluded Mobile, AL in the river flow calculations in the model because it was significantly 

higher than the other harbors and skewed the final average assumptions in the model. EPA 

assumed an average ocean salinity of 35 PSU for the salinity at the seaward boundary of the 

hypothetical estuary harbor. 
2013 VGP and sVGP BE Appendix G 

G-6

Table G-1. Estuary Harbor Characteristics 

Harbor 

City Estuary Name 

Primary River 

Flowing into 

Estuary 

Harbor 

Salinity 

(PSU)a

Harbor Volume 

(m3)

b

River Flow 

(m3/day)c

Flushing 

Time 

(days) 

Boston, 

MA 

Boston Inner 

Harbor 

Charles River and 

Mystic River 31.1d

 551,000,000 1,560,000 39.4 

Charleston, 

SC 

Charleston 

Harbor 

Cooper River and 

Ashley River 26.6 615,000,000 2,840,000 52 

Coos Bay, 

OR Coos Bay Coos River 30.50 1,120,000,000 3,230,000 44.6 

Houston, 

TX Galveston Bay 

San Jacinto River 

and Buffalo 

Bayou 

13.4 834,000,000 12,000,000 42.9 

Juneau, AK Auke Bay Mendenhall River 

and Indian River 26.1d

 10,100,000 2,900,000e 0.886 

Miami, FL Biscayne Bay Miami River and 

Little River 31f

 390,000,000 1,160,000 38.4 

Mobile, AL Mobile Bay Mobile River 16.7d 619,000,000 166,000,000 1.95 

New York, 

NY 

Upper and 

Lower New 

York Harbor 

Hudson River 22.6 3,010,000,000 59,000,000 18 

Norfolk, 

VA Craford Bay Elizabeth River 

and James River 19.8 3,140,000,000 26,200,000 52 

San 

Francisco, 

CA 

San Francisco 

Bay 

Sacramento River 

and San Joaquin 

River 

24.3 6,650,000,000 99,200,000 20.5 

Seattle, 

WA Puget Sound 

Duwamish 

Waterway and 

Dunguess River 

28.2 25,500,000,000 9,790,000 506 

a) All salinity data was collected from EMAP unless another source is identified. 

b) EPA estimated harbor volume based on average depth near the port and surface areas estimated from NOAA 

booklet charts (http://www.nauticalcharts.noaa.gov/staff/BookletChart.html). 

c) All river flow data is from NHD Plus unless another source is identified. 

d) National Oceans Data Center (http://www.nodc.noaa.gov). 

e) Average monthly flow from USGS stream gauge (USGS 15052500 MENDENHALL R NR AUKE BAY AK) 

http://waterdata.usgs.gov/nwis. 

f) Hunt, 2006. 

 As discussed in Section 5.2.1.1, the dilution equation for the hypothetical river harbor 

requires the average annual river flow rate (Qriver) to calculate a receiving water concentration. 

Table G-2 presents the river flow rates for the nine river harbors identified. EPA selected the 

minimum and maximum flow rates to represent the bounding conditions for the hypothetical 

river harbor (see Table 5-4). 

Table G-2. River Harbor Characteristics

City Name River Name River Flow (m3/day) 

St. Louis, MO Mississippi River 424,000,000 

Duluth, MN St. Louis River 8,870,000 

Memphis, TN Mississippi River 1,440,000,000 

St. Paul, MN Mississippi River 27,200,000 
2013 VGP and sVGP BE Appendix G 

G-7

Table G-2. River Harbor Characteristics

City Name River Name River Flow (m3/day) 

Cincinnati, OH Ohio River 248,000,000 

Pittsburgh, PA Ohio River 73,200,000 

Decatur, AL Tennessee River 131,000,000 

Peoria, IL Illinois River 24,400,000 

Lewiston, ID Snake River 147,000,000 

Source: NHD Plus Data. 

G.3 DEVELOPMENT OF RAA LOADING SCENARIOS

Based on the vessel types, discharges, and corresponding pollutants/constituents selected 

for detailed evaluation in the BE (see Section 3.2.4), EPA identified 32 pollutants to include in 

the quantitative effects analysis. Sections 3.2.2 and 3.3.3 present EPA’s assumptions for flow 

rates and pollutant concentrations expected before implementation of the VGP and sVGP permit 

conditions. These flow rates and pollutant concentrations are used to calculate the vessel-specific 

loading rates (We,z) in Equation G-1. Based on the VGP and sVGP permit requirements, EPA 

estimated reductions in pollutant concentrations and flow rates anticipated to occur after 

implementation of the permit conditions for the specific pollutants, discharges and vessel types. 

Table G-3 presents EPA’s assumptions for pollutant concentration and flow reductions for VGP 

vessel types following implementation of the permit. Table G-4 presents EPA’s assumptions for 

pollutant concentration and flow reductions for sVGP vessel types following implementation of 

the permit. Table G-5 and Table G-6 presents the daily discharge loading under pre- and postpermit conditions per vessel equivalent for each discharge and pollutant considered under the 

VGP and sVGP for detailed evaluation in the quantitative effects analysis. 

EPA determined the vessel populations by contacting the port authority of each RAA or 

using available online data from the Department of Transportation and other vessel related 

sources (e.g., online ferry schedules). In addition to documenting the number of vessels present 

in each RAA at a given time, EPA estimated the duration that vessels actually operate in the 

RAAs location to determine a vessel equivalent for the harbor. EPA chose to express vessel 

populations as vessel equivalents to capture the variability in number of vessels present and the 

length of time the vessels discharge within the modeled area. In the analysis a vessel equivalent 

represents a single vessel discharging 24-hours per day in the harbor. For example, 1 vessel 

equivalent could represent 24 vessels that each operate (and discharge) for 1 hour in the harbor 

environment each day. Table G-7 presents the vessel population equivalents for each of the seven 

RAAs and documents the assumptions used to develop the vessel equivalent for each vessel type. 

EPA multiplied the pollutant loads presented in Table G-5 and Table G-6 by the vessel 

equivalents in Table G-7 and summed the results to calculate the total pollutant-specific load for 

each of the seven RAA loading scenarios. Table G-8 and Table G-9 present the total pollutant loads 

from vessels covered under the VGP and sVGP under pre- and post-permit conditions, respectively. 
2013 VGP and sVGP BE Appendix G 

G-8

References

Hunt. 2006. Biscayne Bay Water Quality Monitoring Network. South Florida Water 

Management District. February. Retrieved from 

http://www.sfwmd.gov/portal/page/portal/xrepository/sfwmd_repository_pdf/se_coast_0.

pdf.

USEPA. 2001. Nutrient Criteria Technical Manual, Coastal and Marine Waters. October, 2001. 

Chapter 9. U.S. Environmental Protection Agency. Washington, DC. EPA-822-B-01-003. 

USEPA. 2011. Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharge. EPA 800-R11-005. November 2011. http://www.epa.gov/npdes/pubs/vgp_fishfold.pdf. 

USEPA. 2011. Graywater Discharges from Vessels. EPA 800-R-11-001. November 2011. 

http://www.epa.gov/npdes/pubs/vgp_graywater.pdf. 

USEPA. 2008. Cruise Ship Discharge Assessment Report. EPA 842-R-07-005. December 2008. 

http://water.epa.gov/type/oceb/upload/0812cruiseshipdischargeassess.pdf. 

USEPA. 2011. Environmentally Acceptable Lubricants. EPA 800-R-11-002. November 2011. 

http://www.epa.gov/npdes/pubs/vgp_environmentally_acceptable_lubricants.pdf. 
2013 VGP and sVGP BE 

G-9

Table G-3. Flow and Pollutant Reductions Based on 2013 VGP Requirements 

Vessel 

Discharge 

Select Proposed 2013 VGP Requirements 

Affecting Pollutant Discharge Loadsa

Estimated Potential Flow Reductions from 

VGP Requirements 

Estimated P

Reductions 

R

Anti-Fouling Leachate from Anti-Fouling Hull Coatings 

At the time of initial application or scheduled reapplication of anti-fouling coatings, consideration must be given, as appropriate for vessel type and vessel operations, to the use of hull coatings with the lowest effective biocide release rates, rapidly biodegradable components (once separated from the hull surface), or nonbiocidal alternatives, such as silicon coatings. When vessels spend more than 30 days per year in waters impaired by copper, or use these waters as their home port, vessel owner/operators shall consider using anti-fouling coatings that rely on a rapidly biodegradable biocide or another alternative rather than copper-based coatings.

None. VGP requirements are not expected to impact discharge flow. 

Assume, based ojudgment, that coreduced by 25% some vessels wilto copper-based cmanufacturers wcopper and non-c

Bilgewater All vessels must minimize the discharge of 

bilgewater into waters subject to this permit. This can be done by minimizing the production of bilgewater, disposing of bilgewater on shore where adequate facilities exist, or discharging into waters not subject to this permit (i.e., more than 3 nautical miles [nm] from shore) for vessels that regularly travel into such waters. 

Assume, based on best professional judgment, that vessels that regularly sail outside the territorial sea will reduce discharge flow to waters subject to this permit by 50% as a result of prohibition of discharge within 1 nm of shore. Assume, based on best professional judgment, that vessels that regularly sail outside the territorial sea include all VGP vessel types requiring further analyses, except for barges 

None. VGP requsignificantly impconcentrations. 
2013 VGP and sVGP BE 

G-10

Table G-3. Flow and Pollutant Reductions Based on 2013 VGP Requirements 

Vessel 

Discharge 

Select Proposed 2013 VGP Requirements 

Affecting Pollutant Discharge Loadsa

Estimated Potential Flow Reductions from 

VGP Requirements 

Estimated P

Reductions 

R

Vessels greater than 400 gross tons shall not discharge untreated oily bilgewater into waters subject to this permit. Vessels greater than 400 gross tons that regularly sail outside the territorial sea (at least once per month) shall not discharge treated bilgewater within 1 nm of shore if technologically feasible. 

and ferries. Assume, based on best professional judgment, that VGP requirements are not expected to impact discharge flow for barges and ferries

Deck Washdown 

Vessel owners/operators must minimize the introduction of on-deck debris, garbage, residue, and spill into deck washdown and runoff discharges. Before deck washdowns occur, exposed decks must be broom cleaned or use comparable management measures and remove all existing debris. Where feasible, machinery on deck must have coamings or drip pans where necessary to collect any oily discharge that may leak from machinery and prevent spills. The drip pans must be drained to a waste container for proper disposal and/or periodically wiped and cleaned. 

Assume, based on best professional judgment, that vessels that regularly sail outside the territorial sea will reduce the number of deck washdowns when operating in waters subject to this permit by 50%. Assume, based on best professional judgment, that vessels that regularly sail outside the territorial sea include all VGP vessel types requiring further analyses, except for barges and ferries. Assume, based on best professional judgment, that VGP requirements are not expected to impact discharge flow for barges and ferries. 

Assume, based ojudgment, that thclean decks will concentrations by Assume, based ojudgment, that thor drip pans (and water on large fegrease (HEM/SGconcentrations by Assume, based ojudgment, that th
2013 VGP and sVGP BE 

G-11

Table G-3. Flow and Pollutant Reductions Based on 2013 VGP Requirements 

Vessel 

Discharge 

Select Proposed 2013 VGP Requirements 

Affecting Pollutant Discharge Loadsa

Estimated Potential Flow Reductions from 

VGP Requirements 

Estimated P

Reductions 

R

Vessel owners/operators must minimize deck washdowns while in port. If deck washdowns or above water line hull cleaning will result in a discharge, they must be conducted with “non-toxic” and “phosphate free” cleaners and detergents. Large Ferries: Large ferries may not discharge 

untreated below deck water from parking areas or other storage areas for motor vehicles or other motorized equipment into waters subject to this permit without first treating the effluent with an oily water separator or other appropriate wastewater treatment system. Large ferry operators must use oil absorbent cloths or other appropriate spill response resources to clean oily spills or substances from deck surfaces. 

or drip pans and toxic cleaners antoxic organics di50%. Assume, based ojudgment, that thenvironmentally-detergents will reconcentrations to 

Exhaust Gas Scrubber Washdown Effluent 

Exhaust gas scrubber washwater discharge must not contain oil, including oily mixtures, in quantities that may be harmful as determined in accordance with 40 CFR Part 110. Sludge or residues generated in treating exhaust gas scrubber 

None. VGP requirements are not expected to impact discharge flow.c

None. Available washdown effluedischarges curren
2013 VGP and sVGP BE 

G-12

Table G-3. Flow and Pollutant Reductions Based on 2013 VGP Requirements 

Vessel 

Discharge 

Select Proposed 2013 VGP Requirements 

Affecting Pollutant Discharge Loadsa

Estimated Potential Flow Reductions from 

VGP Requirements 

Estimated P

Reductions 

R

washwater discharge must not be discharged in waters subject to the permit and must be delivered ashore to adequate reception facilities. In addition, owner/operators of vessels with exhaust gas cleaning systems that result in washwater discharges must meet the numeric effluent limits found in Part 2.2.26.1. 

effluent limitatio

Fish Hold and Fish Hold Cleaning 

Fishing vessels must minimize the discharge of fish hold water and/or ice while in port. All reasonable steps must be taken to prevent the discharge of excess fish hold water and ice while the vessel is stationary at the pier. If fish waste is contained in the fish hold effluent, the fish hold effluent may not be discharged while in port, unless a physical separation method is used (e.g., filters or removal of residuals).The discharge of fish hold effluent (including dirty ice) is prohibited when unloading catch at a landbased seafood processing facility or pier. If a shore-based discharge facility is otherwise available to receive effluent, then discharge of fish hold effluent (including dirty ice) is prohibited if the facility meets the following: 

- Its use is economically achievable, and - The facility has a valid NPDES permit, or - That facility discharges to an NPDES 

permitted sewage treatment facility. 

Assume, based on best professional judgment, that fishing vessels will reduce discharge flow to waters subject to this permit by 25% as a result of the discharge prohibition (expected to be applicable for many fishing vessels) and/or minimization requirements (expected to be applicable to all fishing vessels).e

Assume, based ojudgment, that anhold cleaning waof a physical sepmethod will redu

concentrations by 

Graywater All vessels must minimize the discharge of 

graywater while in port. Examples of ways to minimize production of graywater include 

Large cruise ships. Large cruise ships are 

believed to have sufficient graywater storage 

Large and mediu

conservative esti
2013 VGP and sVGP BE 

G-13

Table G-3. Flow and Pollutant Reductions Based on 2013 VGP Requirements 

Vessel 

Discharge 

Select Proposed 2013 VGP Requirements 

Affecting Pollutant Discharge Loadsa

Estimated Potential Flow Reductions from 

VGP Requirements 

Estimated P

Reductions 

R

delaying laundry, scullery activities, and restricting length of showers while in port, and using high efficiency faucets and showerheads. For vessels greater than 400 gross tons that regularly travel more than 1 nm from shore that have the capacity to store graywater for a sufficient period, graywater must be discharged greater than 1 nm from shore while the vessel is underway, unless the vessel meets the treatment standards and other requirements contained under Parts 5.1.1 and 5.1.2 or 5.2.1 and 5.2.2. Vessels that do not travel more than 1 nm from shore shall minimize the discharge of graywater, and provided the vessel has available graywater storage capacity, must dispose of graywater onshore if appropriate facilities are available and such disposal is economically practicable and achievable unless the vessel meets the treatment standards and other requirements contained under Parts 5.1.1 and 5.2.1 or 5.2.1 and 5.2.2. Vessel owners/operators must use phosphate-free 

capacity to hold all graywater generated while pierside or operating within the waters subject to this permit,f which would allow for zero 

discharge of graywater. In addition, some large cruise ships are capable of treating graywater to the permit treatment standards. As a conservative estimate for the purpose of this BE, EPA assumes that the VGP requirements will not impact discharge flow (rather than assuming zero discharge). Medium cruise ships. Medium cruise ships are 

believed to have sufficient graywater storage capacity to hold all graywater generated while pierside or operating within the waters subject to this permit.f EPA is aware of at least one 

medium cruise ship capable of treating graywater to the permit treatment standards. As a conservative estimate for the purpose of this BE, EPA assumes that the VGP requirements will not impact discharge flow (rather than assuming zero discharge). Large ferries. VGP requirements are not 

expected to impact discharge flow, based on the 

BE, EPA assumeconcentrations eqaverage effluent cruise ships that treatment system

discharge). Assuprofessional judgfor environmentadetergents will reconcentrations to All other VGP ve

analysis: VGP re

to significantly imconcentrations. Aprofessional judgfor environmentadetergents will reconcentrations to HEM and SGT-H
2013 VGP and sVGP BE 

G-14

Table G-3. Flow and Pollutant Reductions Based on 2013 VGP Requirements 

Vessel 

Discharge 

Select Proposed 2013 VGP Requirements 

Affecting Pollutant Discharge Loadsa

Estimated Potential Flow Reductions from 

VGP Requirements 

Estimated P

Reductions 

R

and non-toxic soaps and detergents. Large cruise ships. While pierside, appropriate 

onshore reception facilities for graywater must be used, unless the vessel treats graywater with a device to meet the standards in Part 5.1.1.1.2. If such facilities are not reasonably available and capacity is insufficient to treat graywater to meet the standards in Part 5.1.1.1.2, graywater must be held until the vessel is underway and not in waters subject to this permit. While operating within 3 nm from shore, discharges of graywater are prohibited unless they meet the effluent standards in Part 5.1.1.1.2. Medium cruise ships, except those unable to 

voyage 1 nm from shore and constructed before December 19, 2008. While pierside, appropriate 

onshore reception facilities for graywater must be used, unless the vessel treats graywater with a device to meet the standards in Part 5.2.1.1.2. If such facilities are not reasonably available and capacity is insufficient to treat graywater to meet the standards in Part 5.2.1.1.2, graywater must be held until the vessel is underway and not in waters subject to this permit. While operating within 3 nm from shore, discharges of graywater are prohibited unless they meet the effluent standards in Part 5.2.1.1.2. 

assumption that these vessels have little or no graywater storage capacity and seldom operate in waters not subject to this permit. Cargo [Bulk] and other carriers, large 

commercial fishing, and oil and gas tankers.

Graywater storage capacities on these vessels are believed to be limited; however, certain discharges can be minimized while pierside or operating in waters subject to this permit.6 Assume, based on best professional judgment, that these vessels will reduce discharge flow to waters subject to this permit by 25% as a result of minimizing discharges. Barges. VGP requirements are not expected to 

impact discharge flow, based on the assumption that most of these vessels are unmanned have little or no graywater generation. 
2013 VGP and sVGP BE 

G-15

Table G-3. Flow and Pollutant Reductions Based on 2013 VGP Requirements 

Vessel 

Discharge 

Select Proposed 2013 VGP Requirements 

Affecting Pollutant Discharge Loadsa

Estimated Potential Flow Reductions from 

VGP Requirements 

Estimated P

Reductions 

R

Large Ferries. While pierside, appropriate onshore 

reception facilities for graywater must be used, if available and their use is economically achievable, unless the vessel treats graywater to the limits found in Part 5.1.1.1.2 of the permit. If such facilities are not available, graywater must be held if the vessel has the holding capacity and effluent discharged while the vessel is underway. When operating within 3 nm from shore, discharges of graywater may only be released while the ferry is sailing at a speed of at least 6 knots if feasible. 

Stern Tube Packing Gland and Other Oil/Water Interfaces 

Minimize maintenance activities on stern tube seals when a vessel is outside of dry dock. If maintenance or emergency repair must occur on stern tubes or other oil-to-sea interfaces which have a potential to release oil in quantities that may be harmful as defined in 40 CFR Part 110, appropriate spill response equipment(e.g., oil booms) must be used to contain any oil leakage. Operators of the vessel must have ready access to spill response resources to clean up any oil spills. All vessels constructed on or after December 19, 2013 must use an environmentally acceptable lubricant in all oil-to-sea interfaces. 

Environmentally acceptable lubricants” means lubricants that are “biodegradable” and “nontoxic” and are not “bioaccumulative” as defined in Appendix A of the permit. 

None. VGP requirements are not expected to impact discharge flow. 

Assume, based ojudgment, that pereduce all toxic o

tube packing glan

a) For the purpose of this BE, EPA reviewed the VGP requirements to classify them within the following categories: (1) requirem

quantified discharge flow and/or pollutant concentration reductions, (2) requirements for which EPA was unable to quantify d

pollutant concentration reductions due to lack of necessary information, and (3) requirements for which EPA estimates negligi
2013 VGP and sVGP BE 

G-16

pollutant concentration reductions because the requirement represents existing practice. This table lists VGP requirements clas

provides EPA’s assessment of discharge flow and/or pollutant concentration reductions. 

b) Companies represented by the National Paint and Coatings Association Marine Antifouling Working Group have developed b

of which are currently in the market. Notwithstanding this, these coatings do not work in every situation and are particularly il

are at rest for any length of time. These companies will continue to work on improving biocide-free antifouling coatings. SourCoatings Association Marine Antifouling Working Group. 2008. Comments on EPA’s 2008 Proposed Issuance of a NPDES VDischarges Incidental to the Normal Operation of Commercial and Large Recreational Vessels. EPA-HQ-OW-2008-0055-039

c) Note that exhaust gas scrubber washdown effluent treatment conducted onboard vessels typically includes neutralizing the pH 

blending with reaction water, typically seawater used for engine cooling (Source: EGCSA. 2010. Exhaust Gas Cleaning System(http://www.egcsa.com/the-science.php), accessed September 3, 2010EGCSA, 2010). Reaction water and washwater can be mproportions (Source: HA & H-K. 2010. Holland America Line Sea Water Scrubber Technology Demonstration Project. Final RAmerica and Hamworthy-Krystallon to U.S. Environmental Protection Agency. March 31, 2010. (http://www.hollandamerica

cruise-lines/Final_report.pdf)). EPA’s estimated exhaust gas scrubber washwater discharge rates incorporate increased flow re

using reaction water, based on the assumption that effluent treatment is standard practice onboard vessels. Therefore, the VGP expected to further impact discharge flow. 

d) Based on available exhaust gas scrubber washdown effluent sampling data provided in USEPA. 2011. Exhaust Gas Scrubber E

006. November 2011. http://www.epa.gov/npdes/pubs/vgp_exhaust_gas_scrubber.pdf. 

e) Source: USEPA. 2011.Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharge. EPA 800-R-11-005. November 201

http://www.epa.gov/npdes/pubs/vgp_fishfold.pdf. 

f) Source: USEPA. 2011. Graywater Discharges from Vessels. EPA 800-R-11-001. November 2011. http://www.epa.gov/npdes

g) Source: USEPA. 2008. Cruise Ship Discharge Assessment Report. EPA 842-R-07-005. December 2008. 

http://water.epa.gov/type/oceb/upload/0812cruiseshipdischargeassess.pdf. 

h) Includes all volatile and semi-volatile organic compounds. i) Source: USEPA. 2011. Environmentally Acceptable Lubricants. EPA 800-R-11-002. November 2011. 

http://www.epa.gov/npdes/pubs/vgp_environmentally_acceptable_lubricants.pdf. 
2013 VGP and sVGP BE 

G-17

Table G-4. Flow and Pollutant Reductions Based on 2013 sVGP Permit Requirements 

Vessel Discharge 

Select Proposed 2013 sVGP Requirements Affecting Pollutant 

Discharge Loadsa

Potential Flow 

Reductions from 

sVGP Requirements 

Pollutant C

in Dis

Anti-Fouling Leachate from Anti-Fouling Hull Coatings 

Consider whether the use of non-copper based anti-foulant paints adequately meet anti-foulant needs and use less toxic alternatives to the extent practicable and available. When drying or hull cleaning at haul-out is adequate for managing fouling (e.g., for vessels that are hauled frequently or for over-winter storage), do not use anti-foulant coatings if not needed. Do not clean anti-foulant paint which releases biocides for the first 90 days after application. If the anti-foulant paint requires cleaning, gently clean hulls on a regular basis (this minimizes the need for stronger cleaners and more abrasive 

brushes). When cleaning hulls coated with anti-foulant paint while the vessel is in the water, use only soft brushes. Examine the water while cleaning to assure that a plume of paint is not formed. Stop immediately if any visible plume of paint appears in the water. Consider hiring a qualified, professional hull cleaner to do the work, and ensure that they follow 

environmental guidelines. When cleaning hulls coated with anti-fouling paint while the vessel is out of the water, always work away from the water in a location where paint 

chips and dust will not be washed into the water. Place a tarp under the area to catch loose particles, and properly dispose of paint chips, dust, and other particles.

None. sVGP requirements are not expected to impact discharge flow. 

Assume, bajudgment, thbe reduced bassumption able to use abased coatinmanufactureimprove botbased coatin

Bilgewater Regularly inspect the fuel and hydraulic systems for any damage or 

leaks. Unless technically infeasible, use environmentally acceptable lubricants (as defined in Part 6 of the permit) in all machinery and equipment, including but not limited to stern tubes, wires, and two-stroke engines, where discharges of oil to surrounding waters are likely to occur. 

None. sVGP requirements are not expected to impact discharge flow.

Assume, bajudgment, thwill reduce (HEM/SGTorganicsc di

50%. 
2013 VGP and sVGP BE 

G-18

Table G-4. Flow and Pollutant Reductions Based on 2013 sVGP Permit Requirements 

Vessel Discharge 

Select Proposed 2013 sVGP Requirements Affecting Pollutant 

Discharge Loadsa

Potential Flow 

Reductions from 

sVGP Requirements 

Pollutant C

in Dis

Place oil absorbent material or other spill response equipment under the 

vessel engine or use other preventative practices to minimize oil entering bilgewater. Any spill or overflow of oil or other engine fluids must be cleaned up immediately. A supply of absorbent pads, pillows, or other materials should be kept onboard as appropriate for use in addressing or remediating any such spills or overflows. If the vessel has a bilge oily water separator, periodically check for the presence of a visible sheen in surrounding water while discharging. If a visible sheen is observed as a result of this discharge, suspend discharge until the problem is corrected and clean up immediately. If the vessel does not use a US Coast Guard type-approved bilge oily water separator, use an oil-absorbent material to remove any oil from the bilge before discharging. Unless infeasible, prior to pumping the bilge, inspect the bilgewater for 

an oily sheen. While pumping the bilge, examine the surrounding water for the presence of a visible sheen. If a visible sheen is observed as a result of this bilge pumping, suspend the discharge until the problem is corrected and clean up immediately. 

Deck Washdown Prevent trash or garbage, including food waste, cigarette butts, bottles, 

and caps from entering any waste stream covered by this permit. This can be accomplished in part, by maintaining a tidy deck. Use all soaps and cleaners as directed by the label. Any soaps, detergents, or cleaners used on the vessel must be non-toxic, phosphate-free, and biodegradable. The use of soaps that are labeled toxic or highly toxic is prohibited under this permit. Prevent the introduction of on-deck debris, garbage, residue, and spills into deck washdown and runoff discharges. 

None. sVGP requirements are not expected to impact discharge flow.

Assume, bajudgment, thhousekeepinreduce TSS(HEM/SGTconcentratioAssume, bajudgment, thenvironmenand detergendischarge co
2013 VGP and sVGP BE 

G-19

Table G-4. Flow and Pollutant Reductions Based on 2013 sVGP Permit Requirements 

Vessel Discharge 

Select Proposed 2013 sVGP Requirements Affecting Pollutant 

Discharge Loadsa

Potential Flow 

Reductions from 

sVGP Requirements 

Pollutant C

in Dis

Minimize the discharge of paint chips and residue, especially during cleaning, maintenance, paint application, and reapplication. When performing these activities, collect and then dispose of chips and residues onshore in accordance with applicable requirements for the facility where operations are performed. Use all soaps and cleaners as directed by the label. Any soaps, detergents, or cleaners used on the vessel must be non-toxic, phosphatefree, and biodegradable. The use of soaps that are labeled toxic or highly toxic is prohibited. Prevent the introduction of on-deck debris, garbage, residue, and spills onto deck washdown and runoff discharges. Minimize the discharge of paint chips and residue, especially during cleaning, maintenance, paint application and paint reapplication. When performing these activities, collect and then dispose of chips and residue on shore in accordance with applicable requirements for the facility where operations are performed. 

mg/L. 

Engine Wet Exhaust Effluent 

None of the sVGP requirements specifically regard engine wet exhaust effluent. 

None. sVGP requirements are not expected to impact discharge flow. 

None. sVGP expected to concentratio

Fish Hold and Fish Hold Cleaning 

In unloading catch at a shore-based seafood processor or other pier and a shore-based discharge facility is available and economically achievable, effluent (including dirty ice) must be discharged to that shore-based facility instead of discharging to surrounding waters. Do not discharge any unused bait overboard, unless that bait was caught in the same water body or watershed. Unused bait purchased from a bait shop or dealer may not be discharged overboard. Minimize the discharge of fish hold water or ice while in port. All reasonable steps must be taken to prevent the discharge of excess fish hold water and ice while the vessel is stationary at the pier. If fish waste is contained in the fish hold effluent, the fish hold effluent may not be discharged while in port, unless a physical separation method is used (e.g., filters or removal of residuals).

Assume, based on best professional judgment, that fishing vessels will reduce discharge flow to waters subject to this permit by 25% as a result of the minimization requirements (expected to be applicable to all fishing vessels).d

Assume, bajudgment, thhold/fish howill include separation mmethod will 

discharge co

Assume, bajudgment, thenvironmenand detergendischarge co
2013 VGP and sVGP BE 

G-20

Table G-4. Flow and Pollutant Reductions Based on 2013 sVGP Permit Requirements 

Vessel Discharge 

Select Proposed 2013 sVGP Requirements Affecting Pollutant 

Discharge Loadsa

Potential Flow 

Reductions from 

sVGP Requirements 

Pollutant C

in Dis

When cleaning the fish hold, use non-toxic, phosphate-free, and biodegradable soaps and cleaners. Furthermore, while pierside and stationary, do not wash any residual solids into surrounding waters. 

mg/L. 

Graywater Minimize graywater discharges in areas that have heavy vessel traffic or 

heavy recreational use and in marine sanctuaries, national wildlife refuges, national wild and scenic rivers, and national wilderness areas. If the vessel has the capacity to store graywater in these waters, it should be stored and later discharged in other waters or onshore. Minimize the production of graywater while the vessel is stationary in confined waters (e.g., marinas, harbors). If the vessel has the capacity to store graywater, it should be stored and discharged in an appropriately equipped onshore facility or discharged while the vessel is underway. Use soaps, detergents, and cleaners that are phosphate free, non-toxic, and biodegradable for any activities that my result in their introduction into graywater. Excess oils, including animal fats and vegetable oils, used during cooking must not be added to the graywater system or into any other discharge covered by this permit.

sVGP requirements are not expected to impact discharge flow, based on the assumption that these vessels have little or no graywater storage capacity and seldom operate in waters not subject to this permit, and due to the lack of appropriately equipped onshore facilities. 

Assume, bajudgment, thgraywater owill reduce concentratio

Assume, bajudgment, thenvironmenand detergendischarge comg/L. 

Stern Tube Packing Gland 

Any discharge of packing gland or stuffing box effluent must not contain oil, including oily materials, in quantities that may be harmful. These discharges must not produce a visible sheen of oil or oily materials. If accessible, segregated water which contains drips from packing gland effluent or stuffing box effluent must be checked daily for the presence of a visible sheen, while the vessel is operational and manned. If not accessible while the vessel is operational and manned, then the surrounding water must be checked for the presence of visible sheen (while operating). If a visible sheen is observed, appropriate measures such as the use of oil absorbent materials must be used to remove the presence of oil before the effluent may be discharged. If a visible sheen is observed in surrounding waters as a result of this discharge, suspend the discharge until the problem is corrected and clean 

None. sVGP requirements are not expected to impact discharge flow. 

Assume, bajudgment, thwill reduce (HEM/SGTconcentratio
2013 VGP and sVGP BE 

G-21

Table G-4. Flow and Pollutant Reductions Based on 2013 sVGP Permit Requirements 

Vessel Discharge 

Select Proposed 2013 sVGP Requirements Affecting Pollutant 

Discharge Loadsa

Potential Flow 

Reductions from 

sVGP Requirements 

Pollutant C

in Dis

up immediately. Unless technically infeasible, use environmentally acceptable lubricants (as defined in Part 6 of the permit) in all machinery and equipment, including but not limited to stern tubes, wires, and two-stroke engines, where discharges of oil to surrounding waters are likely to occur. 

a) 1 For the purpose of this BE, EPA reviewed the sVGP requirements to classify them within the following categories: (1) requireme

quantified discharge flow and/or pollutant concentration reductions, (2) requirements for which EPA was unable to quantify discha

concentration reductions due to lack of necessary information, and (3) requirements for which EPA estimates negligible discharge concentration reductions because the requirement represents existing practice. This table lists sVGP requirements classified as CateEPA’s assessment of discharge flow and/or pollutant concentration reductions. 

b) Companies represented by the National Paint and Coatings Association Marine Antifouling Working Group have developed biocid

which are currently in the market. Notwithstanding this, these coatings do not work in every situation and are particularly ill-suited 

for any length of time. These companies will continue to work on improving biocide-free antifouling coatings. Source: National PaAssociation Marine Antifouling Working Group. 2008. Comments on EPA’s 2008 Proposed Issuance of a NPDES Vessel General Incidental to the Normal Operation of Commercial and Large Recreational Vessels. EPA-HQ-OW-2008-0055-0396.3. 

c) Includes all volatile and semi-volatile organic compounds. 

d) Source: USEPA. 2011. Fish Hold Effluent and Fish Hold Cleaning Wastewater Discharge. EPA 800-R-11-005. November 2011. 

http://www.epa.gov/npdes/pubs/vgp_fishfold.pdf. 
2013 VGP and sVGP BE 

G-22

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Classicals Biochemical Oxygen Demand (BOD) Bilgewater Barge 0.0745 Classicals Biochemical Oxygen Demand (BOD) Bilgewater Cargo/Bulk Carrier 1.69 Classicals Biochemical Oxygen Demand (BOD) Bilgewater Commercial Fishing 0.595 Classicals Biochemical Oxygen Demand (BOD) Bilgewater Large Cruise Ship 5.66 Classicals Biochemical Oxygen Demand (BOD) Bilgewater Large Ferry 0.154 Classicals Biochemical Oxygen Demand (BOD) Bilgewater Medium Cruise Ship 0.484 Classicals Biochemical Oxygen Demand (BOD) Bilgewater Oil/Gas Tankers 2.63 Classicals Biochemical Oxygen Demand (BOD) Deck Washdown Barge 0.213 Classicals Biochemical Oxygen Demand (BOD) Deck Washdown Cargo/Bulk Carrier 4.83 Classicals Biochemical Oxygen Demand (BOD) Deck Washdown Commercial Fishing 0.0945 Classicals Biochemical Oxygen Demand (BOD) Deck Washdown Large Cruise Ship 37.1 Classicals Biochemical Oxygen Demand (BOD) Deck Washdown Large Ferry 0.994 Classicals Biochemical Oxygen Demand (BOD) Deck Washdown Medium Cruise Ship 3.18 Classicals Biochemical Oxygen Demand (BOD) Deck Washdown Oil/Gas Tankers 7.54 Classicals Biochemical Oxygen Demand (BOD) Fish Hold Commercial Fishing 11 
2013 VGP and sVGP BE 

G-23

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Classicals Biochemical Oxygen Demand (BOD) Fish Hold Cleaning Commercial Fishing 0.676 Classicals Biochemical Oxygen Demand (BOD) Graywater Barge 0 Classicals Biochemical Oxygen Demand (BOD) Graywater Cargo/Bulk Carrier 4.04 Classicals Biochemical Oxygen Demand (BOD) Graywater Commercial Fishing 4.68 Classicals Biochemical Oxygen Demand (BOD) Graywater Large Cruise Ship 558 Classicals Biochemical Oxygen Demand (BOD) Graywater Large Ferry 90.3 Classicals Biochemical Oxygen Demand (BOD) Graywater Medium Cruise Ship 50.9 Classicals Biochemical Oxygen Demand (BOD) Graywater Oil/Gas Tankers 3.55 Classicals Hexane Extractable Material (HEM) Bilgewater Barge 0.00365 Classicals Hexane Extractable Material (HEM) Bilgewater Cargo/Bulk Carrier 0.0825 Classicals Hexane Extractable Material (HEM) Bilgewater Commercial Fishing 0.0291 Classicals Hexane Extractable Material (HEM) Bilgewater Large Cruise Ship 0.277 Classicals Hexane Extractable Material (HEM) Bilgewater Large Ferry 0.00753 Classicals Hexane Extractable Material (HEM) Bilgewater Medium Cruise Ship 0.0237 Classicals Hexane Extractable Material (HEM) Bilgewater Oil/Gas Tankers 0.129 
2013 VGP and sVGP BE 

G-24

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Classicals Hexane Extractable Material (HEM) Deck Washdown Barge 0.0271 Classicals Hexane Extractable Material (HEM) Deck Washdown Cargo/Bulk Carrier 0.614 Classicals Hexane Extractable Material (HEM) Deck Washdown Commercial Fishing 0.012 Classicals Hexane Extractable Material (HEM) Deck Washdown Large Cruise Ship 4.72 Classicals Hexane Extractable Material (HEM) Deck Washdown Large Ferry 0.127 Classicals Hexane Extractable Material (HEM) Deck Washdown Medium Cruise Ship 0.404 Classicals Hexane Extractable Material (HEM) Deck Washdown Oil/Gas Tankers 0.96 Classicals Hexane Extractable Material (HEM) Fish Hold Commercial Fishing 0.042 Classicals Hexane Extractable Material (HEM) Fish Hold Cleaning Commercial Fishing 0.00776 Classicals Hexane Extractable Material (HEM) Graywater Barge 0 Classicals Hexane Extractable Material (HEM) Graywater Cargo/Bulk Carrier 0.366 Classicals Hexane Extractable Material (HEM) Graywater Commercial Fishing 0.425 Classicals Hexane Extractable Material (HEM) Graywater Large Cruise Ship 193 Classicals Hexane Extractable Material (HEM) Graywater Large Ferry 8.19 Classicals Hexane Extractable Material (HEM) Graywater Medium Cruise Ship 4.61 
2013 VGP and sVGP BE 

G-25

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Classicals Hexane Extractable Material (HEM) Graywater Oil/Gas Tankers 0.322 Classicals Hexane Extractable Material (HEM) Stern Tube Packing Gland Cargo/Bulk Carrier 0.14 Classicals Hexane Extractable Material (HEM) Stern Tube Packing Gland Commercial Fishing 0.000234 Classicals Hexane Extractable Material (HEM) Stern Tube Packing Gland Large Cruise Ship 0.469 Classicals Hexane Extractable Material (HEM) Stern Tube Packing Gland Large Ferry 0.0126 Classicals Hexane Extractable Material (HEM) Stern Tube Packing Gland Medium Cruise Ship 0.0401 Classicals Hexane Extractable Material (HEM) Stern Tube Packing Gland Oil/Gas Tankers 0.218 Classicals Silica Gel Treated HEM (SGT-HEM) Bilgewater Barge 0.00173 Classicals Silica Gel Treated HEM (SGT-HEM) Bilgewater Cargo/Bulk Carrier 0.039 Classicals Silica Gel Treated HEM (SGT-HEM) Bilgewater Commercial Fishing 0.0138 Classicals Silica Gel Treated HEM (SGT-HEM) Bilgewater Large Cruise Ship 0.131 Classicals Silica Gel Treated HEM (SGT-HEM) Bilgewater Large Ferry 0.00356 Classicals Silica Gel Treated HEM (SGT-HEM) Bilgewater Medium Cruise Ship 0.0112 Classicals Silica Gel Treated HEM (SGT-HEM) Bilgewater Oil/Gas Tankers 0.061 Classicals Silica Gel Treated HEM (SGT-HEM) Deck Washdown Barge 0.0136 
2013 VGP and sVGP BE 

G-26

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Classicals Silica Gel Treated HEM (SGT-HEM) Deck Washdown Cargo/Bulk Carrier 0.307 Classicals Silica Gel Treated HEM (SGT-HEM) Deck Washdown Commercial Fishing 0.00602 Classicals Silica Gel Treated HEM (SGT-HEM) Deck Washdown Large Cruise Ship 2.36 Classicals Silica Gel Treated HEM (SGT-HEM) Deck Washdown Large Ferry 0.0633 Classicals Silica Gel Treated HEM (SGT-HEM) Deck Washdown Medium Cruise Ship 0.202 Classicals Silica Gel Treated HEM (SGT-HEM) Deck Washdown Oil/Gas Tankers 0.48 Classicals Silica Gel Treated HEM (SGT-HEM) Fish Hold Commercial Fishing 0.0446 Classicals Silica Gel Treated HEM (SGT-HEM) Fish Hold Cleaning Commercial Fishing 0.00704 Classicals Silica Gel Treated HEM (SGT-HEM) Graywater Barge 0 Classicals Silica Gel Treated HEM (SGT-HEM) Graywater Cargo/Bulk Carrier 0.076 Classicals Silica Gel Treated HEM (SGT-HEM) Graywater Commercial Fishing 0.0882 Classicals Silica Gel Treated HEM (SGT-HEM) Graywater Large Cruise Ship 47.5 Classicals Silica Gel Treated HEM (SGT-HEM) Graywater Large Ferry 1.7 Classicals Silica Gel Treated HEM (SGT-HEM) Graywater Medium Cruise Ship 0.958 Classicals Silica Gel Treated HEM (SGT-HEM) Graywater Oil/Gas Tankers 0.0669 
2013 VGP and sVGP BE 

G-27

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Classicals Silica Gel Treated HEM (SGT-HEM) Stern Tube Packing Gland Cargo/Bulk Carrier 0.13 Classicals Silica Gel Treated HEM (SGT-HEM) Stern Tube Packing Gland Commercial Fishing 0.000217 Classicals Silica Gel Treated HEM (SGT-HEM) Stern Tube Packing Gland Large Cruise Ship 0.435 Classicals Silica Gel Treated HEM (SGT-HEM) Stern Tube Packing Gland Large Ferry 0.0117 Classicals Silica Gel Treated HEM (SGT-HEM) Stern Tube Packing Gland Medium Cruise Ship 0.0372 Classicals Silica Gel Treated HEM (SGT-HEM) Stern Tube Packing Gland Oil/Gas Tankers 0.203 Classicals Total Residual Chlorine Bilgewater Barge 0.0000302 Classicals Total Residual Chlorine Bilgewater Cargo/Bulk Carrier 0.000683 Classicals Total Residual Chlorine Bilgewater Commercial Fishing 0.000241 Classicals Total Residual Chlorine Bilgewater Large Cruise Ship 0.00229 Classicals Total Residual Chlorine Bilgewater Large Ferry 0.0000623 Classicals Total Residual Chlorine Bilgewater Medium Cruise Ship 0.000196 Classicals Total Residual Chlorine Bilgewater Oil/Gas Tankers 0.00107 Classicals Total Residual Chlorine Deck Washdown Barge 0.000232 Classicals Total Residual Chlorine Deck Washdown Cargo/Bulk Carrier 0.00527 
2013 VGP and sVGP BE 

G-28

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Classicals Total Residual Chlorine Deck Washdown Commercial Fishing 0.000103 Classicals Total Residual Chlorine Deck Washdown Large Cruise Ship 0.0405 Classicals Total Residual Chlorine Deck Washdown Large Ferry 0.00108 Classicals Total Residual Chlorine Deck Washdown Medium Cruise Ship 0.00347 Classicals Total Residual Chlorine Deck Washdown Oil/Gas Tankers 0.00823 Classicals Total Residual Chlorine Fish Hold Commercial Fishing 1.83 Classicals Total Residual Chlorine Fish Hold Cleaning Commercial Fishing 0.000417 Classicals Total Residual Chlorine Graywater Barge 0 Classicals Total Residual Chlorine Graywater Cargo/Bulk Carrier 0.00113 Classicals Total Residual Chlorine Graywater Commercial Fishing 0.00131 Classicals Total Residual Chlorine Graywater Large Cruise Ship 0.156 Classicals Total Residual Chlorine Graywater Large Ferry 0.0252 Classicals Total Residual Chlorine Graywater Medium Cruise Ship 0.0142 Classicals Total Residual Chlorine Graywater Oil/Gas Tankers 0.000991 Classicals Total Suspended Solids (TSS) Bilgewater Barge 0.0153 
2013 VGP and sVGP BE 

G-29

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Classicals Total Suspended Solids (TSS) Bilgewater Cargo/Bulk Carrier 0.346 Classicals Total Suspended Solids (TSS) Bilgewater Commercial Fishing 0.122 Classicals Total Suspended Solids (TSS) Bilgewater Large Cruise Ship 1.16 Classicals Total Suspended Solids (TSS) Bilgewater Large Ferry 0.0316 Classicals Total Suspended Solids (TSS) Bilgewater Medium Cruise Ship 0.0993 Classicals Total Suspended Solids (TSS) Bilgewater Oil/Gas Tankers 0.541 Classicals Total Suspended Solids (TSS) Deck Washdown Barge 0.329 Classicals Total Suspended Solids (TSS) Deck Washdown Cargo/Bulk Carrier 7.46 Classicals Total Suspended Solids (TSS) Deck Washdown Commercial Fishing 0.146 Classicals Total Suspended Solids (TSS) Deck Washdown Large Cruise Ship 57.3 Classicals Total Suspended Solids (TSS) Deck Washdown Large Ferry 1.54 Classicals Total Suspended Solids (TSS) Deck Washdown Medium Cruise Ship 4.91 Classicals Total Suspended Solids (TSS) Deck Washdown Oil/Gas Tankers 11.7 Classicals Total Suspended Solids (TSS) Fish Hold Commercial Fishing 2.75 Classicals Total Suspended Solids (TSS) Fish Hold Cleaning Commercial Fishing 0.273 
2013 VGP and sVGP BE 

G-30

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Classicals Total Suspended Solids (TSS) Graywater Barge 0 Classicals Total Suspended Solids (TSS) Graywater Cargo/Bulk Carrier 0.488 Classicals Total Suspended Solids (TSS) Graywater Commercial Fishing 0.566 Classicals Total Suspended Solids (TSS) Graywater Large Cruise Ship 67.5 Classicals Total Suspended Solids (TSS) Graywater Large Ferry 10.9 Classicals Total Suspended Solids (TSS) Graywater Medium Cruise Ship 6.15 Classicals Total Suspended Solids (TSS) Graywater Oil/Gas Tankers 0.43 Classicals Total Suspended Solids (TSS) Stern Tube Packing Gland Cargo/Bulk Carrier 0.588 Classicals Total Suspended Solids (TSS) Stern Tube Packing Gland Commercial Fishing 0.000985 Classicals Total Suspended Solids (TSS) Stern Tube Packing Gland Large Cruise Ship 1.98 Classicals Total Suspended Solids (TSS) Stern Tube Packing Gland Large Ferry 0.0532 Classicals Total Suspended Solids (TSS) Stern Tube Packing Gland Medium Cruise Ship 0.169 Classicals Total Suspended Solids (TSS) Stern Tube Packing Gland Oil/Gas Tankers 0.92 Metals Aluminum, Total Bilgewater Barge 0.000145 Metals Aluminum, Total Bilgewater Cargo/Bulk Carrier 0.00328 
2013 VGP and sVGP BE 

G-31

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Metals Aluminum, Total Bilgewater Commercial Fishing 0.00116 Metals Aluminum, Total Bilgewater Large Cruise Ship 0.011 Metals Aluminum, Total Bilgewater Large Ferry 0.000299 Metals Aluminum, Total Bilgewater Medium Cruise Ship 0.000942 Metals Aluminum, Total Bilgewater Oil/Gas Tankers 0.00513 Metals Aluminum, Total Deck Washdown Barge 0.00658 Metals Aluminum, Total Deck Washdown Cargo/Bulk Carrier 0.149 Metals Aluminum, Total Deck Washdown Commercial Fishing 0.00292 Metals Aluminum, Total Deck Washdown Large Cruise Ship 1.15 Metals Aluminum, Total Deck Washdown Large Ferry 0.0307 Metals Aluminum, Total Deck Washdown Medium Cruise Ship 0.0982 Metals Aluminum, Total Deck Washdown Oil/Gas Tankers 0.233 Metals Aluminum, Total Fish Hold Commercial Fishing 0.0108 Metals Aluminum, Total Fish Hold Cleaning Commercial Fishing 0.00158 Metals Aluminum, Total Graywater Barge 0 
2013 VGP and sVGP BE 

G-32

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Metals Aluminum, Total Graywater Cargo/Bulk Carrier 0.00357 Metals Aluminum, Total Graywater Commercial Fishing 0.00414 Metals Aluminum, Total Graywater Large Cruise Ship 0.493 Metals Aluminum, Total Graywater Large Ferry 0.0798 Metals Aluminum, Total Graywater Medium Cruise Ship 0.0449 Metals Aluminum, Total Graywater Oil/Gas Tankers 0.00314 Metals Arsenic, Dissolved 

Exhaust Gas Scrubber (Saltwater) Cargo/Bulk Carrier 1.54 

Metals Arsenic, Dissolved 

Exhaust Gas Scrubber (Saltwater) Large Cruise Ship 0.868 

Metals Arsenic, Dissolved 

Exhaust Gas Scrubber (Saltwater) Large Ferry 0 

Metals Arsenic, Dissolved 

Exhaust Gas Scrubber (Saltwater) Medium Cruise Ship 0 

Metals Arsenic, Dissolved 

Exhaust Gas Scrubber (Saltwater) Oil/Gas Tankers 1.54 

Metals Arsenic, Dissolved Fish Hold Commercial Fishing 0.000407 Metals Arsenic, Dissolved Fish Hold Cleaning Commercial Fishing 0.0000316 
2013 VGP and sVGP BE 

G-33

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Metals Arsenic, Total 

Exhaust Gas Scrubber (Saltwater) Cargo/Bulk Carrier 1.54 

Metals Arsenic, Total 

Exhaust Gas Scrubber (Saltwater) Large Cruise Ship 0.868 

Metals Arsenic, Total 

Exhaust Gas Scrubber (Saltwater) Large Ferry 0 

Metals Arsenic, Total 

Exhaust Gas Scrubber (Saltwater) Medium Cruise Ship 0 

Metals Arsenic, Total 

Exhaust Gas Scrubber (Saltwater) Oil/Gas Tankers 1.54 

Metals Arsenic, Total Fish Hold Commercial Fishing 0.000525 Metals Arsenic, Total Fish Hold Cleaning Commercial Fishing 0.0000503 Metals Arsenic, Total Graywater Barge 0 Metals Arsenic, Total Graywater Cargo/Bulk Carrier 0.0000188 Metals Arsenic, Total Graywater Commercial Fishing 0.0000218 Metals Arsenic, Total Graywater Large Cruise Ship 0.00259 Metals Arsenic, Total Graywater Large Ferry 0.00042 Metals Arsenic, Total Graywater Medium Cruise Ship 0.000237 
2013 VGP and sVGP BE 

G-34

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Metals Arsenic, Total Graywater Oil/Gas Tankers 0.0000165 Metals Cadmium, Dissolved Bilgewater Barge 0.000000745 Metals Cadmium, Dissolved Bilgewater Cargo/Bulk Carrier 0.0000169 Metals Cadmium, Dissolved Bilgewater Commercial Fishing 0.00000595 Metals Cadmium, Dissolved Bilgewater Large Cruise Ship 0.0000566 Metals Cadmium, Dissolved Bilgewater Large Ferry 0.00000154 Metals Cadmium, Dissolved Bilgewater Medium Cruise Ship 0.00000484 Metals Cadmium, Dissolved Bilgewater Oil/Gas Tankers 0.0000263 Metals Cadmium, Dissolved Deck Washdown Barge 0.00000252 Metals Cadmium, Dissolved Deck Washdown Cargo/Bulk Carrier 0.000057 Metals Cadmium, Dissolved Deck Washdown Commercial Fishing 0.00000112 Metals Cadmium, Dissolved Deck Washdown Large Cruise Ship 0.000438 Metals Cadmium, Dissolved Deck Washdown Large Ferry 0.0000117 Metals Cadmium, Dissolved Deck Washdown Medium Cruise Ship 0.0000375 Metals Cadmium, Dissolved Deck Washdown Oil/Gas Tankers 0.0000891 
2013 VGP and sVGP BE 

G-35

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Metals Cadmium, Dissolved Fish Hold Commercial Fishing 0.0000101 Metals Chromium, Dissolved Bilgewater Barge 0.00000471 Metals Chromium, Dissolved Bilgewater Cargo/Bulk Carrier 0.000106 Metals Chromium, Dissolved Bilgewater Commercial Fishing 0.0000376 Metals Chromium, Dissolved Bilgewater Large Cruise Ship 0.000357 Metals Chromium, Dissolved Bilgewater Large Ferry 0.00000971 Metals Chromium, Dissolved Bilgewater Medium Cruise Ship 0.0000305 Metals Chromium, Dissolved Bilgewater Oil/Gas Tankers 0.000166 Metals Chromium, Dissolved Stern Tube Packing Gland Cargo/Bulk Carrier 0.000189 Metals Chromium, Dissolved Stern Tube Packing Gland Commercial Fishing 0.000000317 Metals Chromium, Dissolved Stern Tube Packing Gland Large Cruise Ship 0.000636 Metals Chromium, Dissolved Stern Tube Packing Gland Large Ferry 0.0000171 Metals Chromium, Dissolved Stern Tube Packing Gland Medium Cruise Ship 0.0000544 Metals Chromium, Dissolved Stern Tube Packing Gland Oil/Gas Tankers 0.000296 Metals Copper, Dissolved Bilgewater Barge 0.0000392 
2013 VGP and sVGP BE 

G-36

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Metals Copper, Dissolved Bilgewater Cargo/Bulk Carrier 0.000887 Metals Copper, Dissolved Bilgewater Commercial Fishing 0.000313 Metals Copper, Dissolved Bilgewater Large Cruise Ship 0.00298 Metals Copper, Dissolved Bilgewater Large Ferry 0.0000809 Metals Copper, Dissolved Bilgewater Medium Cruise Ship 0.000255 Metals Copper, Dissolved Bilgewater Oil/Gas Tankers 0.00139 Metals Copper, Dissolved Deck Washdown Barge 0.0000813 Metals Copper, Dissolved Deck Washdown Cargo/Bulk Carrier 0.00184 Metals Copper, Dissolved Deck Washdown Commercial Fishing 0.0000361 Metals Copper, Dissolved Deck Washdown Large Cruise Ship 0.0142 Metals Copper, Dissolved Deck Washdown Large Ferry 0.00038 Metals Copper, Dissolved Deck Washdown Medium Cruise Ship 0.00121 Metals Copper, Dissolved Deck Washdown Oil/Gas Tankers 0.00288 Metals Copper, Dissolved 

Exhaust Gas Scrubber (Saltwater) Cargo/Bulk Carrier 0.286 

Metals Copper, Dissolved 

Exhaust Gas Scrubber 

Large Cruise Ship 0.161 
2013 VGP and sVGP BE 

G-37

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

(Saltwater) 

Metals Copper, Dissolved 

Exhaust Gas Scrubber (Saltwater) Large Ferry 0 

Metals Copper, Dissolved 

Exhaust Gas Scrubber (Saltwater) Medium Cruise Ship 0 

Metals Copper, Dissolved 

Exhaust Gas Scrubber (Saltwater) Oil/Gas Tankers 0.286 

Metals Copper, Dissolved Fish Hold Commercial Fishing 0.00126 Metals Copper, Dissolved Fish Hold Cleaning Commercial Fishing 0.0000489 Metals Copper, Dissolved Graywater Barge 0 Metals Copper, Dissolved Graywater Cargo/Bulk Carrier 0.000516 Metals Copper, Dissolved Graywater Commercial Fishing 0.000599 Metals Copper, Dissolved Graywater Large Cruise Ship 0.0714 Metals Copper, Dissolved Graywater Large Ferry 0.0115 Metals Copper, Dissolved Graywater Medium Cruise Ship 0.00651 Metals Copper, Dissolved Graywater Oil/Gas Tankers 0.000454 Metals Copper, Dissolved Stern Tube Packing Gland Cargo/Bulk Carrier 0.000219 
2013 VGP and sVGP BE 

G-38

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Metals Copper, Dissolved Stern Tube Packing Gland Commercial Fishing 0.000000367 Metals Copper, Dissolved Stern Tube Packing Gland Large Cruise Ship 0.000737 Metals Copper, Dissolved Stern Tube Packing Gland Large Ferry 0.0000198 Metals Copper, Dissolved Stern Tube Packing Gland Medium Cruise Ship 0.000063 Metals Copper, Dissolved Stern Tube Packing Gland Oil/Gas Tankers 0.000343 Metals Lead, Dissolved Deck Washdown Barge 0.0000116 Metals Lead, Dissolved Deck Washdown Cargo/Bulk Carrier 0.000263 Metals Lead, Dissolved Deck Washdown Commercial Fishing 0.00000516 Metals Lead, Dissolved Deck Washdown Large Cruise Ship 0.00202 Metals Lead, Dissolved Deck Washdown Large Ferry 0.0000542 Metals Lead, Dissolved Deck Washdown Medium Cruise Ship 0.000173 Metals Lead, Dissolved Deck Washdown Oil/Gas Tankers 0.000411 Metals Lead, Dissolved Fish Hold Cleaning Commercial Fishing 0.00000388 Metals Lead, Dissolved Graywater Barge 0 Metals Lead, Dissolved Graywater Cargo/Bulk Carrier 0.0000235 
2013 VGP and sVGP BE 

G-39

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Metals Lead, Dissolved Graywater Commercial Fishing 0.0000272 Metals Lead, Dissolved Graywater Large Cruise Ship 0.00324 Metals Lead, Dissolved Graywater Large Ferry 0.000525 Metals Lead, Dissolved Graywater Medium Cruise Ship 0.000296 Metals Lead, Dissolved Graywater Oil/Gas Tankers 0.0000207 Metals Nickel, Dissolved Bilgewater Barge 0.00000361 Metals Nickel, Dissolved Bilgewater Cargo/Bulk Carrier 0.0000816 Metals Nickel, Dissolved Bilgewater Commercial Fishing 0.0000288 Metals Nickel, Dissolved Bilgewater Large Cruise Ship 0.000274 Metals Nickel, Dissolved Bilgewater Large Ferry 0.00000745 Metals Nickel, Dissolved Bilgewater Medium Cruise Ship 0.0000234 Metals Nickel, Dissolved Bilgewater Oil/Gas Tankers 0.000128 Metals Nickel, Dissolved 

Exhaust Gas Scrubber (Saltwater) Cargo/Bulk Carrier 0.229 

Metals Nickel, Dissolved 

Exhaust Gas Scrubber (Saltwater) Large Cruise Ship 0.129 
2013 VGP and sVGP BE 

G-40

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Metals Nickel, Dissolved 

Exhaust Gas Scrubber (Saltwater) Large Ferry 0 

Metals Nickel, Dissolved 

Exhaust Gas Scrubber (Saltwater) Medium Cruise Ship 0 

Metals Nickel, Dissolved 

Exhaust Gas Scrubber (Saltwater) Oil/Gas Tankers 0.229 

Metals Nickel, Dissolved Stern Tube Packing Gland Cargo/Bulk Carrier 0.00209 Metals Nickel, Dissolved Stern Tube Packing Gland Commercial Fishing 0.0000035 Metals Nickel, Dissolved Stern Tube Packing Gland Large Cruise Ship 0.00703 Metals Nickel, Dissolved Stern Tube Packing Gland Large Ferry 0.000189 Metals Nickel, Dissolved Stern Tube Packing Gland Medium Cruise Ship 0.000601 Metals Nickel, Dissolved Stern Tube Packing Gland Oil/Gas Tankers 0.00327 Metals Nickel, Total Stern Tube Packing Gland Cargo/Bulk Carrier 0.00608 Metals Nickel, Total Stern Tube Packing Gland Commercial Fishing 0.0000102 Metals Nickel, Total Stern Tube Packing Gland Large Cruise Ship 0.0204 Metals Nickel, Total Stern Tube Packing Gland Large Ferry 0.00055 Metals Nickel, Total Stern Tube Packing Gland Medium Cruise Ship 0.00175 
2013 VGP and sVGP BE 

G-41

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Metals Nickel, Total Stern Tube Packing Gland Oil/Gas Tankers 0.00951 Metals Selenium, Dissolved 

Exhaust Gas Scrubber (Saltwater) Cargo/Bulk Carrier 1.79 

Metals Selenium, Dissolved 

Exhaust Gas Scrubber (Saltwater) Large Cruise Ship 1.01 

Metals Selenium, Dissolved 

Exhaust Gas Scrubber (Saltwater) Large Ferry 0 

Metals Selenium, Dissolved 

Exhaust Gas Scrubber (Saltwater) Medium Cruise Ship 0 

Metals Selenium, Dissolved 

Exhaust Gas Scrubber (Saltwater) Oil/Gas Tankers 1.79 

Metals Selenium, Dissolved Fish Hold Commercial Fishing 0.000121 Metals Selenium, Dissolved Fish Hold Cleaning Commercial Fishing 0.00000862 Metals Selenium, Total 

Exhaust Gas Scrubber (Saltwater) Cargo/Bulk Carrier 1.9 

Metals Selenium, Total 

Exhaust Gas Scrubber (Saltwater) Large Cruise Ship 1.07 

Metals Selenium, Total 

Exhaust Gas Scrubber (Saltwater) Large Ferry 0 
2013 VGP and sVGP BE 

G-42

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Metals Selenium, Total 

Exhaust Gas Scrubber (Saltwater) Medium Cruise Ship 0 

Metals Selenium, Total 

Exhaust Gas Scrubber (Saltwater) Oil/Gas Tankers 1.9 

Metals Zinc, Dissolved Bilgewater Barge 0.000051 Metals Zinc, Dissolved Bilgewater Cargo/Bulk Carrier 0.00115 Metals Zinc, Dissolved Bilgewater Commercial Fishing 0.000407 Metals Zinc, Dissolved Bilgewater Large Cruise Ship 0.00387 Metals Zinc, Dissolved Bilgewater Large Ferry 0.000105 Metals Zinc, Dissolved Bilgewater Medium Cruise Ship 0.000331 Metals Zinc, Dissolved Bilgewater Oil/Gas Tankers 0.0018 Metals Zinc, Dissolved Deck Washdown Barge 0.000503 Metals Zinc, Dissolved Deck Washdown Cargo/Bulk Carrier 0.0114 Metals Zinc, Dissolved Deck Washdown Commercial Fishing 0.000223 Metals Zinc, Dissolved Deck Washdown Large Cruise Ship 0.0876 Metals Zinc, Dissolved Deck Washdown Large Ferry 0.00235 
2013 VGP and sVGP BE 

G-43

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Metals Zinc, Dissolved Deck Washdown Medium Cruise Ship 0.00751 Metals Zinc, Dissolved Deck Washdown Oil/Gas Tankers 0.0178 Metals Zinc, Dissolved Fish Hold Commercial Fishing 0.00236 Metals Zinc, Dissolved Fish Hold Cleaning Commercial Fishing 0.000273 Metals Zinc, Dissolved Graywater Barge 0 Metals Zinc, Dissolved Graywater Cargo/Bulk Carrier 0.00376 Metals Zinc, Dissolved Graywater Commercial Fishing 0.00436 Metals Zinc, Dissolved Graywater Large Cruise Ship 0.519 Metals Zinc, Dissolved Graywater Large Ferry 0.084 Metals Zinc, Dissolved Graywater Medium Cruise Ship 0.0473 Metals Zinc, Dissolved Graywater Oil/Gas Tankers 0.0033 Nutrients Ammonia As Nitrogen (NH3-N) Bilgewater Barge 0.000667 Nutrients Ammonia As Nitrogen (NH3-N) Bilgewater Cargo/Bulk Carrier 0.0151 Nutrients Ammonia As Nitrogen (NH3-N) Bilgewater Commercial Fishing 0.00532 Nutrients Ammonia As Nitrogen (NH3-N) Bilgewater Large Cruise Ship 0.0506 
2013 VGP and sVGP BE 

G-44

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Nutrients Ammonia As Nitrogen (NH3-N) Bilgewater Large Ferry 0.00138 Nutrients Ammonia As Nitrogen (NH3-N) Bilgewater Medium Cruise Ship 0.00433 Nutrients Ammonia As Nitrogen (NH3-N) Bilgewater Oil/Gas Tankers 0.0236 Nutrients Ammonia As Nitrogen (NH3-N) Fish Hold Commercial Fishing 0.157 Nutrients Ammonia As Nitrogen (NH3-N) Fish Hold Cleaning Commercial Fishing 0.023 Nutrients Ammonia As Nitrogen (NH3-N) Graywater Barge 0 Nutrients Ammonia As Nitrogen (NH3-N) Graywater Cargo/Bulk Carrier 0.0122 Nutrients Ammonia As Nitrogen (NH3-N) Graywater Commercial Fishing 0.0142 Nutrients Ammonia As Nitrogen (NH3-N) Graywater Large Cruise Ship 2.72 Nutrients Ammonia As Nitrogen (NH3-N) Graywater Large Ferry 0.273 Nutrients Ammonia As Nitrogen (NH3-N) Graywater Medium Cruise Ship 0.154 Nutrients Ammonia As Nitrogen (NH3-N) Graywater Oil/Gas Tankers 0.0107 Nutrients Total Phosphorus Bilgewater Barge 0.00118 Nutrients Total Phosphorus Bilgewater Cargo/Bulk Carrier 0.0266 Nutrients Total Phosphorus Bilgewater Commercial Fishing 0.00939 
2013 VGP and sVGP BE 

G-45

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Nutrients Total Phosphorus Bilgewater Large Cruise Ship 0.0894 Nutrients Total Phosphorus Bilgewater Large Ferry 0.00243 Nutrients Total Phosphorus Bilgewater Medium Cruise Ship 0.00764 Nutrients Total Phosphorus Bilgewater Oil/Gas Tankers 0.0416 Nutrients Total Phosphorus Deck Washdown Barge 0.00329 Nutrients Total Phosphorus Deck Washdown Cargo/Bulk Carrier 0.0746 Nutrients Total Phosphorus Deck Washdown Commercial Fishing 0.00146 Nutrients Total Phosphorus Deck Washdown Large Cruise Ship 0.573 Nutrients Total Phosphorus Deck Washdown Large Ferry 0.0154 Nutrients Total Phosphorus Deck Washdown Medium Cruise Ship 0.0491 Nutrients Total Phosphorus Deck Washdown Oil/Gas Tankers 0.117 Nutrients Total Phosphorus Fish Hold Commercial Fishing 0.171 Nutrients Total Phosphorus Fish Hold Cleaning Commercial Fishing 0.0122 Nutrients Total Phosphorus Graywater Barge 0 Nutrients Total Phosphorus Graywater Cargo/Bulk Carrier 0.0131 
2013 VGP and sVGP BE 

G-46

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

Nutrients Total Phosphorus Graywater Commercial Fishing 0.0152 Nutrients Total Phosphorus Graywater Large Cruise Ship 13 Nutrients Total Phosphorus Graywater Large Ferry 0.294 Nutrients Total Phosphorus Graywater Medium Cruise Ship 0.166 Nutrients Total Phosphorus Graywater Oil/Gas Tankers 0.0116 Nutrients Total Phosphorus Stern Tube Packing Gland Cargo/Bulk Carrier 0.0013 Nutrients Total Phosphorus Stern Tube Packing Gland Commercial Fishing 0.00000217 Nutrients Total Phosphorus Stern Tube Packing Gland Large Cruise Ship 0.00435 Nutrients Total Phosphorus Stern Tube Packing Gland Large Ferry 0.000117 Nutrients Total Phosphorus Stern Tube Packing Gland Medium Cruise Ship 0.000372 Nutrients Total Phosphorus Stern Tube Packing Gland Oil/Gas Tankers 0.00203 SVOC 2,4,6-Trichlorophenol Bilgewater Barge 0.00000275 SVOC 2,4,6-Trichlorophenol Bilgewater Cargo/Bulk Carrier 0.0000621 SVOC 2,4,6-Trichlorophenol Bilgewater Commercial Fishing 0.0000219 SVOC 2,4,6-Trichlorophenol Bilgewater Large Cruise Ship 0.000209 
2013 VGP and sVGP BE 

G-47

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

SVOC 2,4,6-Trichlorophenol Bilgewater Large Ferry 0.00000567 SVOC 2,4,6-Trichlorophenol Bilgewater Medium Cruise Ship 0.0000178 SVOC 2,4,6-Trichlorophenol Bilgewater Oil/Gas Tankers 0.000097 SVOC Benzo(a)anthracene 

Exhaust Gas Scrubber (Saltwater) Cargo/Bulk Carrier 0.00499 

SVOC Benzo(a)anthracene 

Exhaust Gas Scrubber (Saltwater) Large Cruise Ship 0.00281 

SVOC Benzo(a)anthracene 

Exhaust Gas Scrubber (Saltwater) Large Ferry 0 

SVOC Benzo(a)anthracene 

Exhaust Gas Scrubber (Saltwater) Medium Cruise Ship 0 

SVOC Benzo(a)anthracene 

Exhaust Gas Scrubber (Saltwater) Oil/Gas Tankers 0.00499 

SVOC Benzo(a)pyrene 

Exhaust Gas Scrubber (Saltwater) Cargo/Bulk Carrier 0.00259 

SVOC Benzo(a)pyrene 

Exhaust Gas Scrubber (Saltwater) Large Cruise Ship 0.00146 

SVOC Benzo(a)pyrene 

Exhaust Gas Scrubber (Saltwater) Large Ferry 0 
2013 VGP and sVGP BE 

G-48

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

SVOC Benzo(a)pyrene 

Exhaust Gas Scrubber (Saltwater) Medium Cruise Ship 0 

SVOC Benzo(a)pyrene 

Exhaust Gas Scrubber (Saltwater) Oil/Gas Tankers 0.00259 

SVOC Bis(2-ethylhexyl) phthalate Bilgewater Barge 0.00000588 SVOC Bis(2-ethylhexyl) phthalate Bilgewater Cargo/Bulk Carrier 0.000133 SVOC Bis(2-ethylhexyl) phthalate Bilgewater Commercial Fishing 0.0000469 SVOC Bis(2-ethylhexyl) phthalate Bilgewater Large Cruise Ship 0.000447 SVOC Bis(2-ethylhexyl) phthalate Bilgewater Large Ferry 0.0000121 SVOC Bis(2-ethylhexyl) phthalate Bilgewater Medium Cruise Ship 0.0000382 SVOC Bis(2-ethylhexyl) phthalate Bilgewater Oil/Gas Tankers 0.000208 SVOC Bis(2-ethylhexyl) phthalate Deck Washdown Barge 0.0000091 SVOC Bis(2-ethylhexyl) phthalate Deck Washdown Cargo/Bulk Carrier 0.000206 SVOC Bis(2-ethylhexyl) phthalate Deck Washdown Commercial Fishing 0.00000404 SVOC Bis(2-ethylhexyl) phthalate Deck Washdown Large Cruise Ship 0.00158 SVOC Bis(2-ethylhexyl) phthalate Deck Washdown Large Ferry 0.0000425 
2013 VGP and sVGP BE 

G-49

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

SVOC Bis(2-ethylhexyl) phthalate Deck Washdown Medium Cruise Ship 0.000136 SVOC Bis(2-ethylhexyl) phthalate Deck Washdown Oil/Gas Tankers 0.000322 SVOC Bis(2-ethylhexyl) phthalate Stern Tube Packing Gland Cargo/Bulk Carrier 0.0000469 SVOC Bis(2-ethylhexyl) phthalate Stern Tube Packing Gland Commercial Fishing 0.0000000784 SVOC Bis(2-ethylhexyl) phthalate Stern Tube Packing Gland Large Cruise Ship 0.000157 SVOC Bis(2-ethylhexyl) phthalate Stern Tube Packing Gland Large Ferry 0.00000424 SVOC Bis(2-ethylhexyl) phthalate Stern Tube Packing Gland Medium Cruise Ship 0.0000135 SVOC Bis(2-ethylhexyl) phthalate Stern Tube Packing Gland Oil/Gas Tankers 0.0000733 SVOC Chrysene 

Exhaust Gas Scrubber (Saltwater) Cargo/Bulk Carrier 0.0071 

SVOC Chrysene 

Exhaust Gas Scrubber (Saltwater) Large Cruise Ship 0.004 

SVOC Chrysene 

Exhaust Gas Scrubber (Saltwater) Large Ferry 0 

SVOC Chrysene 

Exhaust Gas Scrubber (Saltwater) Medium Cruise Ship 0 

SVOC Chrysene 

Exhaust Gas Scrubber (Saltwater) Oil/Gas Tankers 0.0071 
2013 VGP and sVGP BE 

G-50

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

VOC Benzene Bilgewater Barge 0.0000239 VOC Benzene Bilgewater Cargo/Bulk Carrier 0.000541 VOC Benzene Bilgewater Commercial Fishing 0.000191 VOC Benzene Bilgewater Large Cruise Ship 0.00182 VOC Benzene Bilgewater Large Ferry 0.0000494 VOC Benzene Bilgewater Medium Cruise Ship 0.000155 VOC Benzene Bilgewater Oil/Gas Tankers 0.000845 VOC Benzene Deck Washdown Barge 0.0000252 VOC Benzene Deck Washdown Cargo/Bulk Carrier 0.00057 VOC Benzene Deck Washdown Commercial Fishing 0.0000112 VOC Benzene Deck Washdown Large Cruise Ship 0.00438 VOC Benzene Deck Washdown Large Ferry 0.000117 VOC Benzene Deck Washdown Medium Cruise Ship 0.000375 VOC Benzene Deck Washdown Oil/Gas Tankers 0.000891 VOC Bromodichloromethane Deck Washdown Barge 0.0000252 
2013 VGP and sVGP BE 

G-51

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

VOC Bromodichloromethane Deck Washdown Cargo/Bulk Carrier 0.00057 VOC Bromodichloromethane Deck Washdown Commercial Fishing 0.0000112 VOC Bromodichloromethane Deck Washdown Large Cruise Ship 0.00438 VOC Bromodichloromethane Deck Washdown Large Ferry 0.000117 VOC Bromodichloromethane Deck Washdown Medium Cruise Ship 0.000375 VOC Bromodichloromethane Deck Washdown Oil/Gas Tankers 0.000891 VOC Dibromochloromethane Deck Washdown Barge 0.0000252 VOC Dibromochloromethane Deck Washdown Cargo/Bulk Carrier 0.00057 VOC Dibromochloromethane Deck Washdown Commercial Fishing 0.0000112 VOC Dibromochloromethane Deck Washdown Large Cruise Ship 0.00438 VOC Dibromochloromethane Deck Washdown Large Ferry 0.000117 VOC Dibromochloromethane Deck Washdown Medium Cruise Ship 0.000375 VOC Dibromochloromethane Deck Washdown Oil/Gas Tankers 0.000891 VOC Tetrachloroethene Stern Tube Packing Gland Cargo/Bulk Carrier 0.000014 VOC Tetrachloroethene Stern Tube Packing Gland Commercial Fishing 0.0000000234 
2013 VGP and sVGP BE 

G-52

Table G-5. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of V

Class Analyte Discharge Vessel Type 

Pollutant Load 

Before 

Implementation 

VGP Condition

(lbs/day) 

VOC Tetrachloroethene Stern Tube Packing Gland Large Cruise Ship 0.0000469 VOC Tetrachloroethene Stern Tube Packing Gland Large Ferry 0.00000126 VOC Tetrachloroethene Stern Tube Packing Gland Medium Cruise Ship 0.00000401 VOC Tetrachloroethene Stern Tube Packing Gland Oil/Gas Tankers 0.0000218 VOC Trichloroethene Bilgewater Barge 0.077 VOC Trichloroethene Bilgewater Cargo/Bulk Carrier 0.0000231 VOC Trichloroethene Bilgewater Commercial Fishing 0.00000814 VOC Trichloroethene Bilgewater Large Cruise Ship 0.0000775 VOC Trichloroethene Bilgewater Large Ferry 0.0000021 VOC Trichloroethene Bilgewater Medium Cruise Ship 0.00000662 VOC Trichloroethene Bilgewater Oil/Gas Tankers 0.000036 
2013 VGP and sVGP BE 

G-53

Table G-6. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of s

Class Analyte Discharge Vessel Type 

Pollutant Load Before 

Implementation of 

sVGP Conditions 

(lbs/day) 

Classicals 

Biochemical Oxygen Demand (BOD) Bilgewater Commercial Fishing 0.595 

Classicals 

Biochemical Oxygen Demand (BOD) Bilgewater Passenger Vessel 0.0349 

Classicals 

Biochemical Oxygen Demand (BOD) Bilgewater Utility Boats 0.0587 

Classicals 

Biochemical Oxygen Demand (BOD) Deck Washdown Commercial Fishing 0.0945 

Classicals 

Biochemical Oxygen Demand (BOD) Deck Washdown Passenger Vessel 0.0248 

Classicals 

Biochemical Oxygen Demand (BOD) Deck Washdown Utility Boats 0.0129 

Classicals 

Biochemical Oxygen Demand (BOD) Fish Hold Commercial Fishing 11 

Classicals 

Biochemical Oxygen Demand (BOD) Fish Hold Cleaning Commercial Fishing 0.676 

Classicals 

Biochemical Oxygen Demand (BOD) Graywater Commercial Fishing 4.68 

Classicals 

Biochemical Oxygen Demand (BOD) Graywater Passenger Vessel 45.5 

Classicals 

Biochemical Oxygen Demand 

Graywater Utility Boats 0.969 
2013 VGP and sVGP BE 

G-54

Table G-6. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of s

Class Analyte Discharge Vessel Type 

Pollutant Load Before 

Implementation of 

sVGP Conditions 

(lbs/day) 

(BOD) 

Classicals 

Hexane Extractable Material (HEM) Bilgewater Commercial Fishing 0.0291 

Classicals 

Hexane Extractable Material (HEM) Bilgewater Passenger Vessel 0.00171 

Classicals 

Hexane Extractable Material (HEM) Bilgewater Utility Boats 0.00287 

Classicals 

Hexane Extractable Material (HEM) Deck Washdown Commercial Fishing 0.012 

Classicals 

Hexane Extractable Material (HEM) Deck Washdown Passenger Vessel 0.00315 

Classicals 

Hexane Extractable Material (HEM) Deck Washdown Utility Boats 0.00164 

Classicals 

Hexane Extractable Material (HEM) Fish Hold Commercial Fishing 0.042 

Classicals 

Hexane Extractable Material (HEM) Fish Hold Cleaning Commercial Fishing 0.00776 

Classicals 

Hexane Extractable Material (HEM) Graywater Commercial Fishing 0.425 

Classicals 

Hexane Extractable Material (HEM) Graywater Passenger Vessel 4.13 
2013 VGP and sVGP BE 

G-55

Table G-6. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of s

Class Analyte Discharge Vessel Type 

Pollutant Load Before 

Implementation of 

sVGP Conditions 

(lbs/day) 

Classicals 

Hexane Extractable Material (HEM) Graywater Utility Boats 0.0879 

Classicals 

Hexane Extractable Material (HEM) Stern Tube Packing Gland Commercial Fishing 0.000234 

Classicals 

Hexane Extractable Material (HEM) Stern Tube Packing Gland Passenger Vessel 0.000304 

Classicals 

Hexane Extractable Material (HEM) Stern Tube Packing Gland Utility Boats 0.000701 

Classicals 

Silica Gel Treated HEM (SGTHEM) Bilgewater Commercial Fishing 0.0138 

Classicals 

Silica Gel Treated HEM (SGTHEM) Bilgewater Passenger Vessel 0.000808 

Classicals 

Silica Gel Treated HEM (SGTHEM) Bilgewater Utility Boats 0.00136 

Classicals 

Silica Gel Treated HEM (SGTHEM) Deck Washdown Commercial Fishing 0.00602 

Classicals 

Silica Gel Treated HEM (SGTHEM) Deck Washdown Passenger Vessel 0.00158 

Classicals 

Silica Gel Treated HEM (SGTHEM) Deck Washdown Utility Boats 0.000818 

Classicals 

Silica Gel Treated HEM (SGTFish Hold Commercial Fishing 0.0446 
2013 VGP and sVGP BE 

G-56

Table G-6. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of s

Class Analyte Discharge Vessel Type 

Pollutant Load Before 

Implementation of 

sVGP Conditions 

(lbs/day) 

HEM) 

Classicals 

Silica Gel Treated HEM (SGTHEM) Fish Hold Cleaning Commercial Fishing 0.00704 

Classicals 

Silica Gel Treated HEM (SGTHEM) Graywater Commercial Fishing 0.0882 

Classicals 

Silica Gel Treated HEM (SGTHEM) Graywater Passenger Vessel 0.858 

Classicals 

Silica Gel Treated HEM (SGTHEM) Graywater Utility Boats 0.0182 

Classicals 

Silica Gel Treated HEM (SGTHEM) Stern Tube Packing Gland Commercial Fishing 0.000217 

Classicals 

Silica Gel Treated HEM (SGTHEM) Stern Tube Packing Gland Passenger Vessel 0.000282 

Classicals 

Silica Gel Treated HEM (SGTHEM) Stern Tube Packing Gland Utility Boats 0.000651 

Classicals Total Residual Chlorine Bilgewater Commercial Fishing 0.000241 Classicals Total Residual Chlorine Bilgewater Passenger Vessel 0.0000141 Classicals Total Residual Chlorine Bilgewater Utility Boats 0.0000238 Classicals Total Residual Chlorine Deck Washdown Commercial Fishing 0.000103 
2013 VGP and sVGP BE 

G-57

Table G-6. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of s

Class Analyte Discharge Vessel Type 

Pollutant Load Before 

Implementation of 

sVGP Conditions 

(lbs/day) 

Classicals Total Residual Chlorine Deck Washdown Passenger Vessel 0.000027 Classicals Total Residual Chlorine Deck Washdown Utility Boats 0.000014 Classicals Total Residual Chlorine Fish Hold Commercial Fishing 0.00126 Classicals Total Residual Chlorine Fish Hold Cleaning Commercial Fishing 0.000417 Classicals Total Residual Chlorine Graywater Commercial Fishing 0.00131 Classicals Total Residual Chlorine Graywater Passenger Vessel 0.0127 Classicals Total Residual Chlorine Graywater Utility Boats 0.00027 Classicals Total Suspended Solids (TSS) Bilgewater Commercial Fishing 0.122 Classicals Total Suspended Solids (TSS) Bilgewater Passenger Vessel 0.00716 Classicals Total Suspended Solids (TSS) Bilgewater Utility Boats 0.012 Classicals Total Suspended Solids (TSS) Deck Washdown Commercial Fishing 0.146 Classicals Total Suspended Solids (TSS) Deck Washdown Passenger Vessel 0.0383 Classicals Total Suspended Solids (TSS) Deck Washdown Utility Boats 0.0199 Classicals Total Suspended Solids (TSS) Fish Hold Commercial Fishing 2.75 Classicals Total Suspended Solids (TSS) Fish Hold Cleaning Commercial Fishing 0.273 Classicals Total Suspended Solids (TSS) Graywater Commercial Fishing 0.566 
2013 VGP and sVGP BE 

G-58

Table G-6. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of s

Class Analyte Discharge Vessel Type 

Pollutant Load Before 

Implementation of 

sVGP Conditions 

(lbs/day) 

Classicals Total Suspended Solids (TSS) Graywater Passenger Vessel 5.51 Classicals Total Suspended Solids (TSS) Graywater Utility Boats 0.117 Classicals Total Suspended Solids (TSS) Stern Tube Packing Gland Commercial Fishing 0.000985 Classicals Total Suspended Solids (TSS) Stern Tube Packing Gland Passenger Vessel 0.00128 Classicals Total Suspended Solids (TSS) Stern Tube Packing Gland Utility Boats 0.00295 Metals Aluminum, Total Bilgewater Commercial Fishing 0.00116 Metals Aluminum, Total Bilgewater Passenger Vessel 0.0000679 Metals Aluminum, Total Bilgewater Utility Boats 0.000114 Metals Aluminum, Total Deck Washdown Commercial Fishing 0.00292 Metals Aluminum, Total Deck Washdown Passenger Vessel 0.000766 Metals Aluminum, Total Deck Washdown Utility Boats 0.000397 Metals Aluminum, Total Fish Hold Commercial Fishing 0.0108 Metals Aluminum, Total Fish Hold Cleaning Commercial Fishing 0.00158 Metals Aluminum, Total Graywater Commercial Fishing 0.00414 Metals Aluminum, Total Graywater Passenger Vessel 0.0402 Metals Aluminum, Total Graywater Utility Boats 0.000856 
2013 VGP and sVGP BE 

G-59

Table G-6. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of s

Class Analyte Discharge Vessel Type 

Pollutant Load Before 

Implementation of 

sVGP Conditions 

(lbs/day) 

Metals Arsenic, Dissolved Fish Hold Commercial Fishing 0.000407 Metals Arsenic, Dissolved Fish Hold Cleaning Commercial Fishing 0.0000316 Metals Arsenic, Total Fish Hold Commercial Fishing 0.000525 Metals Arsenic, Total Fish Hold Cleaning Commercial Fishing 0.0000503 Metals Arsenic, Total Graywater Commercial Fishing 0.0000218 Metals Arsenic, Total Graywater Passenger Vessel 0.000212 Metals Arsenic, Total Graywater Utility Boats 0.00000451 Metals Cadmium, Dissolved Bilgewater Commercial Fishing 0.00000595 Metals Cadmium, Dissolved Bilgewater Passenger Vessel 0.000000349 Metals Cadmium, Dissolved Bilgewater Utility Boats 0.000000587 Metals Cadmium, Dissolved Deck Washdown Commercial Fishing 0.00000112 Metals Cadmium, Dissolved Deck Washdown Passenger Vessel 0.000000293 Metals Cadmium, Dissolved Deck Washdown Utility Boats 0.000000152 Metals Cadmium, Dissolved Fish Hold Commercial Fishing 0.0000101 Metals Chromium, Dissolved Bilgewater Commercial Fishing 0.0000376 Metals Chromium, Dissolved Bilgewater Passenger Vessel 0.0000022 
2013 VGP and sVGP BE 

G-60

Table G-6. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of s

Class Analyte Discharge Vessel Type 

Pollutant Load Before 

Implementation of 

sVGP Conditions 

(lbs/day) 

Metals Chromium, Dissolved Bilgewater Utility Boats 0.0000037 Metals Chromium, Dissolved Stern Tube Packing Gland Commercial Fishing 0.000000317 Metals Chromium, Dissolved Stern Tube Packing Gland Passenger Vessel 0.000000412 Metals Chromium, Dissolved Stern Tube Packing Gland Utility Boats 0.000000951 Metals Copper, Dissolved Bilgewater Commercial Fishing 0.000313 Metals Copper, Dissolved Bilgewater Passenger Vessel 0.0000184 Metals Copper, Dissolved Bilgewater Utility Boats 0.0000309 Metals Copper, Dissolved Deck Washdown Commercial Fishing 0.0000361 Metals Copper, Dissolved Deck Washdown Passenger Vessel 0.00000946 Metals Copper, Dissolved Deck Washdown Utility Boats 0.00000491 Metals Copper, Dissolved Fish Hold Commercial Fishing 0.00126 Metals Copper, Dissolved Fish Hold Cleaning Commercial Fishing 0.0000489 Metals Copper, Dissolved Graywater Commercial Fishing 0.000599 Metals Copper, Dissolved Graywater Passenger Vessel 0.00582 Metals Copper, Dissolved Graywater Utility Boats 0.000124 Metals Copper, Dissolved Stern Tube Packing Gland Commercial Fishing 0.000000367 
2013 VGP and sVGP BE 

G-61

Table G-6. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of s

Class Analyte Discharge Vessel Type 

Pollutant Load Before 

Implementation of 

sVGP Conditions 

(lbs/day) 

Metals Copper, Dissolved Stern Tube Packing Gland Passenger Vessel 0.000000477 Metals Copper, Dissolved Stern Tube Packing Gland Utility Boats 0.0000011 Metals Copper, Dissolved Wet Exhaust (Generator) Commercial Fishing 0.0000497 Metals Copper, Dissolved Wet Exhaust (Generator) Passenger Vessel 0.000228 Metals Copper, Dissolved Wet Exhaust (Generator) Utility Boats 0.0000634 Metals Copper, Dissolved Wet Exhaust (Propulsion) Commercial Fishing 0.000556 Metals Copper, Dissolved Wet Exhaust (Propulsion) Passenger Vessel 0.00145 Metals Copper, Dissolved Wet Exhaust (Propulsion) Utility Boats 0.00128 Metals Lead, Dissolved Deck Washdown Commercial Fishing 0.00000516 Metals Lead, Dissolved Deck Washdown Passenger Vessel 0.00000135 Metals Lead, Dissolved Deck Washdown Utility Boats 0.000000701 Metals Lead, Dissolved Fish Hold Cleaning Commercial Fishing 0.00000388 Metals Lead, Dissolved Graywater Commercial Fishing 0.0000272 Metals Lead, Dissolved Graywater Passenger Vessel 0.000265 Metals Lead, Dissolved Graywater Utility Boats 0.00000563 Metals Nickel, Dissolved Bilgewater Commercial Fishing 0.0000288 
2013 VGP and sVGP BE 

G-62

Table G-6. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of s

Class Analyte Discharge Vessel Type 

Pollutant Load Before 

Implementation of 

sVGP Conditions 

(lbs/day) 

Metals Nickel, Dissolved Bilgewater Passenger Vessel 0.00000169 Metals Nickel, Dissolved Bilgewater Utility Boats 0.00000284 Metals Nickel, Dissolved Stern Tube Packing Gland Commercial Fishing 0.0000035 Metals Nickel, Dissolved Stern Tube Packing Gland Passenger Vessel 0.00000456 Metals Nickel, Dissolved Stern Tube Packing Gland Utility Boats 0.0000105 Metals Nickel, Total Stern Tube Packing Gland Commercial Fishing 0.0000102 Metals Nickel, Total Stern Tube Packing Gland Passenger Vessel 0.0000132 Metals Nickel, Total Stern Tube Packing Gland Utility Boats 0.0000305 Metals Selenium, Dissolved Fish Hold Commercial Fishing 0.000121 Metals Selenium, Dissolved Fish Hold Cleaning Commercial Fishing 0.00000862 Metals Zinc, Dissolved Bilgewater Commercial Fishing 0.000407 Metals Zinc, Dissolved Bilgewater Passenger Vessel 0.0000239 Metals Zinc, Dissolved Bilgewater Utility Boats 0.0000401 Metals Zinc, Dissolved Deck Washdown Commercial Fishing 0.000223 Metals Zinc, Dissolved Deck Washdown Passenger Vessel 0.0000586 Metals Zinc, Dissolved Deck Washdown Utility Boats 0.0000304 
2013 VGP and sVGP BE 

G-63

Table G-6. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of s

Class Analyte Discharge Vessel Type 

Pollutant Load Before 

Implementation of 

sVGP Conditions 

(lbs/day) 

Metals Zinc, Dissolved Fish Hold Commercial Fishing 0.00236 Metals Zinc, Dissolved Fish Hold Cleaning Commercial Fishing 0.000273 Metals Zinc, Dissolved Graywater Commercial Fishing 0.00436 Metals Zinc, Dissolved Graywater Passenger Vessel 0.0424 Metals Zinc, Dissolved Graywater Utility Boats 0.000901 Nutrients 

Ammonia As Nitrogen (NH3-N) Bilgewater Commercial Fishing 0.00532 

Nutrients 

Ammonia As Nitrogen (NH3-N) Bilgewater Passenger Vessel 0.000312 

Nutrients 

Ammonia As Nitrogen (NH3-N) Bilgewater Utility Boats 0.000525 

Nutrients 

Ammonia As Nitrogen (NH3-N) Fish Hold Commercial Fishing 0.157 

Nutrients 

Ammonia As Nitrogen (NH3-N) Fish Hold Cleaning Commercial Fishing 0.023 

Nutrients 

Ammonia As Nitrogen (NH3-N) Graywater Commercial Fishing 0.0142 

Nutrients 

Ammonia As Nitrogen (NH3-N) Graywater Passenger Vessel 0.138 
2013 VGP and sVGP BE 

G-64

Table G-6. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of s

Class Analyte Discharge Vessel Type 

Pollutant Load Before 

Implementation of 

sVGP Conditions 

(lbs/day) 

Nutrients 

Ammonia As Nitrogen (NH3-N) Graywater Utility Boats 0.00293 

Nutrients Total Phosphorus Bilgewater Commercial Fishing 0.00939 Nutrients Total Phosphorus Bilgewater Passenger Vessel 0.000551 Nutrients Total Phosphorus Bilgewater Utility Boats 0.000926 Nutrients Total Phosphorus Deck Washdown Commercial Fishing 0.00146 Nutrients Total Phosphorus Deck Washdown Passenger Vessel 0.000383 Nutrients Total Phosphorus Deck Washdown Utility Boats 0.000199 Nutrients Total Phosphorus Fish Hold Commercial Fishing 0.171 Nutrients Total Phosphorus Fish Hold Cleaning Commercial Fishing 0.0122 Nutrients Total Phosphorus Graywater Commercial Fishing 0.0152 Nutrients Total Phosphorus Graywater Passenger Vessel 0.148 Nutrients Total Phosphorus Graywater Utility Boats 0.00315 Nutrients Total Phosphorus Stern Tube Packing Gland Commercial Fishing 0.00000217 Nutrients Total Phosphorus Stern Tube Packing Gland Passenger Vessel 0.00000282 Nutrients Total Phosphorus Stern Tube Packing Gland Utility Boats 0.00000651 SVOC 2,4,6-Trichlorophenol Bilgewater Commercial Fishing 0.0000219 
2013 VGP and sVGP BE 

G-65

Table G-6. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of s

Class Analyte Discharge Vessel Type 

Pollutant Load Before 

Implementation of 

sVGP Conditions 

(lbs/day) 

SVOC 2,4,6-Trichlorophenol Bilgewater Passenger Vessel 0.00000129 SVOC 2,4,6-Trichlorophenol Bilgewater Utility Boats 0.00000216 SVOC Benzo(a)anthracene Wet Exhaust (Generator) Commercial Fishing 0.0000102 SVOC Benzo(a)anthracene Wet Exhaust (Generator) Passenger Vessel 0.0000469 SVOC Benzo(a)anthracene Wet Exhaust (Generator) Utility Boats 0.0000131 SVOC Benzo(a)anthracene Wet Exhaust (Propulsion) Commercial Fishing 0.000115 SVOC Benzo(a)anthracene Wet Exhaust (Propulsion) Passenger Vessel 0.000298 SVOC Benzo(a)anthracene Wet Exhaust (Propulsion) Utility Boats 0.000264 SVOC Benzo(a)pyrene Wet Exhaust (Generator) Commercial Fishing 0.00000993 SVOC Benzo(a)pyrene Wet Exhaust (Generator) Passenger Vessel 0.0000455 SVOC Benzo(a)pyrene Wet Exhaust (Generator) Utility Boats 0.0000127 SVOC Benzo(a)pyrene Wet Exhaust (Propulsion) Commercial Fishing 0.000111 SVOC Benzo(a)pyrene Wet Exhaust (Propulsion) Passenger Vessel 0.000289 SVOC Benzo(a)pyrene Wet Exhaust (Propulsion) Utility Boats 0.000256 SVOC Benzo(b)fluoranthene Wet Exhaust (Generator) Commercial Fishing 0.00000869 SVOC Benzo(b)fluoranthene Wet Exhaust (Generator) Passenger Vessel 0.0000398 
2013 VGP and sVGP BE 

G-66

Table G-6. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of s

Class Analyte Discharge Vessel Type 

Pollutant Load Before 

Implementation of 

sVGP Conditions 

(lbs/day) 

SVOC Benzo(b)fluoranthene Wet Exhaust (Generator) Utility Boats 0.0000111 SVOC Benzo(b)fluoranthene Wet Exhaust (Propulsion) Commercial Fishing 0.0000972 SVOC Benzo(b)fluoranthene Wet Exhaust (Propulsion) Passenger Vessel 0.000253 SVOC Benzo(b)fluoranthene Wet Exhaust (Propulsion) Utility Boats 0.000224 SVOC Benzo(k)fluoranthene Wet Exhaust (Generator) Commercial Fishing 0.00000962 SVOC Benzo(k)fluoranthene Wet Exhaust (Generator) Passenger Vessel 0.0000441 SVOC Benzo(k)fluoranthene Wet Exhaust (Generator) Utility Boats 0.0000123 SVOC Benzo(k)fluoranthene Wet Exhaust (Propulsion) Commercial Fishing 0.000108 SVOC Benzo(k)fluoranthene Wet Exhaust (Propulsion) Passenger Vessel 0.00028 SVOC Benzo(k)fluoranthene Wet Exhaust (Propulsion) Utility Boats 0.000248 SVOC Bis(2-ethylhexyl) phthalate Bilgewater Commercial Fishing 0.0000469 SVOC Bis(2-ethylhexyl) phthalate Bilgewater Passenger Vessel 0.00000275 SVOC Bis(2-ethylhexyl) phthalate Bilgewater Utility Boats 0.00000463 SVOC Bis(2-ethylhexyl) phthalate Deck Washdown Commercial Fishing 0.00000404 SVOC Bis(2-ethylhexyl) phthalate Deck Washdown Passenger Vessel 0.00000106 SVOC Bis(2-ethylhexyl) phthalate Deck Washdown Utility Boats 0.000000549 
2013 VGP and sVGP BE 

G-67

Table G-6. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of s

Class Analyte Discharge Vessel Type 

Pollutant Load Before 

Implementation of 

sVGP Conditions 

(lbs/day) 

SVOC Bis(2-ethylhexyl) phthalate Stern Tube Packing Gland Commercial Fishing 0.0000000784 SVOC Bis(2-ethylhexyl) phthalate Stern Tube Packing Gland Passenger Vessel 0.000000102 SVOC Bis(2-ethylhexyl) phthalate Stern Tube Packing Gland Utility Boats 0.000000235 SVOC Bis(2-ethylhexyl) phthalate Wet Exhaust (Generator) Commercial Fishing 0.00000528 SVOC Bis(2-ethylhexyl) phthalate Wet Exhaust (Generator) Passenger Vessel 0.0000242 SVOC Bis(2-ethylhexyl) phthalate Wet Exhaust (Generator) Utility Boats 0.00000674 SVOC Bis(2-ethylhexyl) phthalate Wet Exhaust (Propulsion) Commercial Fishing 0.000059 SVOC Bis(2-ethylhexyl) phthalate Wet Exhaust (Propulsion) Passenger Vessel 0.000154 SVOC Bis(2-ethylhexyl) phthalate Wet Exhaust (Propulsion) Utility Boats 0.000136 SVOC Chrysene Wet Exhaust (Generator) Commercial Fishing 0.0000102 SVOC Chrysene Wet Exhaust (Generator) Passenger Vessel 0.0000469 SVOC Chrysene Wet Exhaust (Generator) Utility Boats 0.0000131 SVOC Chrysene Wet Exhaust (Propulsion) Commercial Fishing 0.000115 SVOC Chrysene Wet Exhaust (Propulsion) Passenger Vessel 0.000298 SVOC Chrysene Wet Exhaust (Propulsion) Utility Boats 0.000264 SVOC Ideno(1,2,3-cd)pyrene Wet Exhaust (Generator) Commercial Fishing 0.00000776 
2013 VGP and sVGP BE 

G-68

Table G-6. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of s

Class Analyte Discharge Vessel Type 

Pollutant Load Before 

Implementation of 

sVGP Conditions 

(lbs/day) 

SVOC Ideno(1,2,3-cd)pyrene Wet Exhaust (Generator) Passenger Vessel 0.0000355 SVOC Ideno(1,2,3-cd)pyrene Wet Exhaust (Generator) Utility Boats 0.00000991 SVOC Ideno(1,2,3-cd)pyrene Wet Exhaust (Propulsion) Commercial Fishing 0.0000868 SVOC Ideno(1,2,3-cd)pyrene Wet Exhaust (Propulsion) Passenger Vessel 0.000226 SVOC Ideno(1,2,3-cd)pyrene Wet Exhaust (Propulsion) Utility Boats 0.0002 VOC Benzene Bilgewater Commercial Fishing 0.000191 VOC Benzene Bilgewater Passenger Vessel 0.0000112 VOC Benzene Bilgewater Utility Boats 0.0000188 VOC Benzene Deck Washdown Commercial Fishing 0.0000112 VOC Benzene Deck Washdown Passenger Vessel 0.00000293 VOC Benzene Deck Washdown Utility Boats 0.00000152 VOC Benzene Wet Exhaust (Generator) Commercial Fishing 0.0000372 VOC Benzene Wet Exhaust (Generator) Passenger Vessel 0.000171 VOC Benzene Wet Exhaust (Generator) Utility Boats 0.0000476 VOC Benzene Wet Exhaust (Propulsion) Commercial Fishing 0.000417 VOC Benzene Wet Exhaust (Propulsion) Passenger Vessel 0.00108 
2013 VGP and sVGP BE 

G-69

Table G-6. Pollutant Loads by Analyte, Discharge, and Vessel Type Before and After Implementation of s

Class Analyte Discharge Vessel Type 

Pollutant Load Before 

Implementation of 

sVGP Conditions 

(lbs/day) 

VOC Benzene Wet Exhaust (Propulsion) Utility Boats 0.00096 VOC Bromodichloromethane Deck Washdown Commercial Fishing 0.0000112 VOC Bromodichloromethane Deck Washdown Passenger Vessel 0.00000293 VOC Bromodichloromethane Deck Washdown Utility Boats 0.00000152 VOC Dibromochloromethane Deck Washdown Commercial Fishing 0.0000112 VOC Dibromochloromethane Deck Washdown Passenger Vessel 0.00000293 VOC Dibromochloromethane Deck Washdown Utility Boats 0.00000152 VOC Tetrachloroethene Stern Tube Packing Gland Commercial Fishing 0.0000000234 VOC Tetrachloroethene Stern Tube Packing Gland Passenger Vessel 0.0000000304 VOC Tetrachloroethene Stern Tube Packing Gland Utility Boats 0.0000000701 VOC Trichloroethene Bilgewater Commercial Fishing 0.00000814 VOC Trichloroethene Bilgewater Passenger Vessel 0.000000477 VOC Trichloroethene Bilgewater Utility Boats 0.000000803 
2013 VGP and sVGP BE 

G-70

Table G-7. Vessel Population in Each RAA Vessel Type 

Number of Vessel Equivalentsa

Seattle, WA 

Marine/Estuarine 

St. Louis, MO 

Freshwater 

Duluth, MN 

Freshwater 

Houston, TX 

Marine/Estuarine 

New York, NY 

Marine/Estuarine 

San Francisc

Marine/Estu

VGP Vessel Types Barges 12.8b 60.1c 0.00d 340e 62.4f 2.8g Oil/Gas Tankers 0.09i 0.00j 0.00k 18.3l 5.39

m 2.92n 

Large Cruise Ships 4.00p 0.00q 0.00r 1.00s 5.00t 3.00u Commercial Fishing Vessels 24.5

w 0.00x 0.00x 0.00x 1.00y 0.00x 

Medium Cruise Ships 1.00z 1.00aa 0.54ab 0.00ac 1.00ad 1.00ad Cargo/Bulk Carriers 2.86ae 0.00af 2.08ag 9.99ah 17.1ai 12.3aj Large Ferries 4.00al 0.00am 0.00am 0.00am 50.0an 4.11ao sVGP Vessel TypesCommercial Fishing Vessels 1,000aq 0.00ar 1.00as 0.00ar 33.3at 53.8au Passenger Vessels 15.0av 2.00aw 1.64ax 0.10ay 10.0az 4.43ba Utility Boats 6bc 16.3bd 16.4be 42.7bf 28.9bg 16.3bh Total Number of Vessels Assumed in RAA Habor 1,070 79.4 21.7 412 214 101 a) Vessel populations presented are expressed as vessel equivalents where a vessel equivalent represents a single vessel discharging 2

harbor. For example, 1 vessel equivalent could represent 24 vessels that each operate (and discharge) for 1 hour in the harbor envir

b) Estimated 12.8 barge equivalents as the sum of 0.8 barge equivalents from vessel calls to the Port of Seattle and 12 barge equivalen

harbor area (0.8+12=12.8). Barge equivalents from vessels calls calculated by multiplying reported 141 annual port calls (Source: 

www.portseattle.org/About/Publications/Statistics/Seaport/Pages/Vessel-Calls.aspx, accessed February 2012) by 2 days per port ca

judgment) and dividing by 365 days/year (144×2÷365=0.77). Barge equivalents working in harbor calculated by dividing reported reported barge product (Source: U.S. Army Corps of Engineers http://www.ndc.iwr.usace.army.mil/wcsc/webpub09/Part4_Ports_tonsbycommCY2009.HTM) by estimated barge capacity of 1,50

estimated 350 operating days per year (6.5 million÷1,500÷350=12). 

c) Estimated 60.1 barge equivalents as the sum of 15.8 barge equivalents from vessels calls to the Port of St. Louis, plus 37.8 barge eq

St. Louis harbor area, plus 6.5 barge equivalents transiting through St. Louis harbor as traveling up or down river (15.8+37.8+6.5=

from vessel calls calculated by multiplying reported 823 annual port calls (Source: Personal communication with representative at 

days per port call (best professional judgment) and dividing by 365 days per year (823×7÷365=15.8). Barge equivalents working in dividing reported annual 19.9 million tons of reported barge product (Source: U.S. Army Corps of Engineers http://www.ndc.iwr.usace.army.mil/wcsc/webpub09/Part4_Ports_tonsbycommCY2009.HTM) by estimated barge capacity of 1,50

estimated 350 operating days per year (19.9 million÷1,500÷350=37.8). Barge equivalents transiting through St. Louis harbor calcu
2013 VGP and sVGP BE 

G-71

reported barges hailing from St. Louis (Source: http://www.ndc.iwr.usace.army.mil/index.htm) by 10% (assumed 10% of all vesse

would pass through the harbor on a given day) and by 0.5 hr/day (estimated transit time through harbor) (3,118×0.1×0.5÷24=6.5).

d) No cargo barges visited the Port of Duluth in 2011 (Source: Personal communication with James Sharrow, Facilities Manager at th

Authority, January 2012). 

e) The Houston Ship Channel hosts more than 340 barge movements each day (Source: Houston-Galveston Navigation Safety Adviso

Navigating the Houston Ship Channel: a reference for commercial users. May 2011. http://www.galvestonpilots.com/HOGANSACNavigatingtheHoustonShipChannel.pdf). 

f) Estimated 62.4 barge equivalents as the sum of 1.4 barge equivalents from vessel calls to the Port of New York and 61 barge equiv

York harbor area (1.4+61=62.4). Barge equivalents from vessels calls calculated by multiplying reported 506 annual port calls (So

www.worldportsource.com/ports/USA_NY_Port_of_New_York_68.php, Accessed February 2012) by 1 day per port call (best pro

dividing by 365 days per year (506×1÷365=1.4). Barge equivalents working in harbor determined using Google Earth to count 61 operating in the harbor. 

g) Estimated 2.8 barge equivalents as the sum of 0.8 barge equivalents from vessel calls to the Port of San Francisco and 2 barge equi

San Francisco harbor area (0.8+2=2.8). Barge equivalents from vessels calls estimated to equal barge equivalents from vessels call

(Source: Personal communication with Anita Yao, Port of San Francisco and Julie Coombes, California Department of Fish and GBarge equivalents working in harbor calculated by dividing reported annual 1.2 million tons of reported barge product (Source: U.Engineers http://www.ndc.iwr.usace.army.mil/wcsc/webpub09/Part4_Ports_tonsbycommCY2009.HTM) by estimated barge capacand by estimated 350 operating days per year (1.2 million÷1,500÷350=2). 

h) Estimated 2.9 barge equivalents as the product of 1.9 barge equivalents from vessel calls to the Port of Miami multiplied by a facto

judgment) to provide a conservative estimate of vessel activity on a busy day (1.9×1.5=2.9). On average, Port of Miami operates 2 

350 days/yr (2×350÷365=1.9) (Source: Personal communication with Jill Taft, Regulatory Compliance Manager at Enterprise Mar

Tug and Barge of Miami, March 2012). 

i) Estimated 0.09 tanker equivalents as the sum of 0.07 tanker equivalents from vessel calls to Seattle and 0.02 tanker equivalents tran

harbor as traveling to and from Port of Tacoma (0.07+0.02=0.09). Tanker equivalents from vessel calls calculated by multiplying rcarrier, and combination carrier calls in 2010 (Source: MARAD http://www.marad.dot.gov/documents/US_Port_Calls_by_Vessel_

port (Source: Personal communication with Diane Falcione, Director of Governmental Relations and Legistative Affairs at the Por

2012) and dividing by 365 days/yr (18×1.5÷365=0.07). Tanker equivalents transiting through Seattle to and from Tacoma calculate

tanker equivalents for vessel calls for Tacoma (calculated by multiplying reported 56 tanker, gas carrier, and combination carrier c

MARAD] by 1.5 days in port and dividing by 365 days/yr, 56×1.5÷365=0.23) by estimated 2 hours/day transit time (0.23×2÷24=0

j) Tankers do not visit the Port of St. Louis (Source: www.boatinfoworld.com/boat/registrations/saint-louis-mo-63111.asp). 

k) Tankers do not visit the Port of Duluth (Source: Personal communication with James Sharrow, Facilities Manager at the Duluth Se

January 2012). 

l) Estimated 18.3 tanker equivalents from vessel calls to Houston. Tanker equivalents from vessel calls calculated by multiplying rep

carrier, and combination carrier calls in 2010 (Source: MARAD http://www.marad.dot.gov/documents/US_Port_Calls_by_Vessel_

port (Source: Personal communication with Diane Falcione, Director of Governmental Relations and Legistative Affairs at the Por

2012) and dividing by 365 days/yr (4,450×1.5÷365=18.3). 

m) Estimated 5.39 tanker equivalents from vessel calls to New York. Tanker equivalents from vessel calls calculated by multiplying re

carrier, and combination carrier calls in 2010 (Source: MARAD http://www.marad.dot.gov/documents/US_Port_Calls_by_Vessel_

port (Source: Personal communication with Diane Falcione, Director of Governmental Relations and Legistative Affairs at the Por

2012) and dividing by 365 days/yr (1,311×1.5÷365=5.39). 
2013 VGP and sVGP BE 

G-72

n) Estimated 2.92 tanker equivalents from vessel calls to San Francisco. Tanker equivalents from vessel calls calculated by multiplyin

carrier, and combination carrier calls in 2010 (Source: MARAD http://www.marad.dot.gov/documents/US_Port_Calls_by_Vessel_

port (Source: Personal communication with Diane Falcione, Director of Governmental Relations and Legistative Affairs at the Por

2012) and dividing by 365 days/yr (710×1.5÷365=2.92). 

o) Miami receives a negligible number of annual tanker, gas carrier, and combination carrier port calls (Source: MARAD 

http://www.marad.dot.gov/documents/US_Port_Calls_by_Vessel_Type.xls). 

p) Maximum of 4 large cruise ships visit Seattle simultaneously (Source: MARAD 

http://www.marad.dot.gov/documents/north_america_cruise_detail_data.xls). 

q) Large cruise ships do not visit St. Louis (Source: MARAD http://www.marad.dot.gov/documents/north_america_cruise_detail_dat

r) Negligible number of large cruise ships visit Duluth (Source: MARAD http://www.marad.dot.gov/documents/north_america_cruis

s) Maximum of 1 large cruise ships visit Houston simultaneously (Source: MARAD 

http://www.marad.dot.gov/documents/north_america_cruise_detail_data.xls). 

t) Maximum of 5 large cruise ships visit New York simultaneously (Source: MARAD 

http://www.marad.dot.gov/documents/north_america_cruise_detail_data.xls). 

u) Maximum of 3 large cruise ships visit San Francisco simultaneously (Source: MARAD 

http://www.marad.dot.gov/documents/north_america_cruise_detail_data.xls). 

v) Maximum of 7 large cruise ships visit Miami simultaneously (Source: MARAD 

http://www.marad.dot.gov/documents/north_america_cruise_detail_data.xls). 

w) Estimated 24.5 large commercial fishing equivalents calculated by multiplying the 49 large commercial fishing vessels that hail fro

eNOI database) by a factor of 0.5 to account for the estimated maximum portion of these vessels operating or offloading fish in the (best professional judgment) (49×0.5=24.5). 

x) Zero or negligible numbers of large commercial fishing vessels operate in St. Louis, Duluth, Houston, San Francisco, and Miami (b

judgment). 

y) Assumed a maximum of 1 large commercial fishing vessel operates in New York harbor at any given time (best professional judgmz) Maximum of 1 medium cruise ships visit Seattle (Source: MARAD http://www.marad.dot.gov/documents/north_america_cruise_d

aa) Queen of the Mississippi visits St. Louis 5 times per year (Source: Personal communication with representative at American Cruise 

maximum of 1 medium cruise ship operating in St. Louis at any given time. 

ab) There were 11 arrivals of a medium cruise ship in Duluth during 2 of the last 5 seasons (Source: Personal communication with Jam

Manager at the Duluth Seaway Port Authority, January 2012); assumed maximum of 1 medium cruise ship operating in Duluth at a

ac) Medium cruise ships do not visit Houston (Source: MARAD http://www.marad.dot.gov/documents/north_america_cruise_detail_d

ad) Maximum of 1 medium cruise ships visit New York, San Francisco, and Miami simultaneously (Source: MARAD 

http://www.marad.dot.gov/documents/north_america_cruise_detail_data.xls). 

ae) Estimated 2.86 container ship equivalents as the sum of 2.41 container ship equivalents from vessel calls to the Port of Seattle and 

transiting through Seattle harbor as traveling to and from Port of Tacoma (2.41+0.45=2.86). Container ship equivalents from vessemultiplying the reported sum of 787 container calls and 93 grain vessel calls (Source: www.portseattle.org/About/Publications/Statistics/Seaport/Pages/Vessel-Calls.aspx, accessed February 2012) by 1 day per port cal

communication with Diane Falcione, Director of Governmental Relations and Legislative Affairs at the Port of Galveston, Februar365 days/year (880×1÷365=2.41). Container equivalents transiting through Seattle to and from Tacoma calculated by multiplying t

equivalents for vessel calls for Tacoma (calculated by multiplying reported 977 container, dry bulk, and Ro-Ro calls in 2010 [Sourhttp://www.marad.dot.gov/documents/US_Port_Calls_by_Vessel_Type.xls] by 2 days in port (Source: Personal communication w
2013 VGP and sVGP BE 

G-73

Facilities Manager at the Duluth Seaway Port Authority, January 2012) and dividing by 365 days/yr, 977×2÷365=5.35) by estimat

(5.35×2÷24=0.45). 

af) Container vessels do not visit the Port of St. Louis (Source: www.boatinfoworld.com/boat/registrations/saint-louis-mo-63111.asp). 

ag) Estimated 2.08 container equivalents as the sum of 1.39 Laker equivalents and 0.69 Saltie equivalents from vessel calls to the Port 

(1.39+0.69=2.08). Laker equivalents from vessels calls calculated by multiplying the average of 902 port calls over the last 5 years dividing by 270 days/year shipping season (902×10÷24÷270=1.39) (Source: Personal communication with James Sharrow, FacilitiSeaway Port Authority, January 2012). Saltie equivalents from vessels calls calculated by multiplying the average of 93 port calls odays/port call and dividing by 270 days/year shipping season (93×2÷270=0.69) (Source: Personal communication with James Shar

the Duluth Seaway Port Authority, January 2012). 

ah) Estimated 9.99 container ship equivalents calculated by multiplying the reported 1,824 container, dry bulk, and Ro-Ro calls in 201

http://www.marad.dot.gov/documents/US_Port_Calls_by_Vessel_Type.xls) by 2 days in port (Source: Personal communication w

Facilities Manager at the Duluth Seaway Port Authority, January 2012) and dividing by 365 days/yr (1,824×2÷365=9.99). 

ai) Estimated 17.1 container ship equivalents calculated by multiplying the reported 3,128 container, dry bulk, and Ro-Ro calls in 201

http://www.marad.dot.gov/documents/US_Port_Calls_by_Vessel_Type.xls) by 2 days in port (Source: Personal communication wFacilities Manager at the Duluth Seaway Port Authority, January 2012) and dividing by 365 days/yr (3,128×2÷365=17.1). 

aj) Estimated 12.3 container ship equivalents calculated by multiplying the reported 2,249 container, dry bulk, and Ro-Ro calls in 201

http://www.marad.dot.gov/documents/US_Port_Calls_by_Vessel_Type.xls) by 2 days in port (Source: Personal communication wFacilities Manager at the Duluth Seaway Port Authority, January 2012) and dividing by 365 days/yr (2,249×2÷365=12.3). 

ak) Estimated 9.11 container ship equivalents calculated by multiplying the reported 1,663 container vessel port calls (Source: Persona

George Arocha, Terminal Manager at the Port of Miami Terminal Operating Company, March 2012) by 2 days in port (Source: Pewith James Sharrow, Facilities Manager at the Duluth Seaway Port Authority, January 2012) and dividing by 365 days/yr (1,663×2

al) Four large ferries leave from Alaskan Way, operating 7 days/week (Source: http://www.wsdot.com/ferries/schedule/). am) Large ferries do not operate in St. Louis, Duluth, and Houston. an) Fifty large ferries operate in New York harbor year round (Source: Personal communication with representative at the Port Author

Jersey). 

ao) Estimated 4.11 large ferry equivalents calculated by multiplying 5 large ferries operating in San Francisco (Source: Personal comm

Port of San Francisco and Julie Coombes, California Department of Fish and Game, February 2012) by an estimated 300 day opera(5×300÷365=4.11). 

ap) Estimated 4.11 large ferry equivalents calculated by multiplying 5 large ferries operating in Miami (Source: Personal communicati

Regulatory Compliance Manager at Enterprise Marine Services and Coastal Tug and Barge of Miami, and George Arocha, Termin

Miami Terminal Operating Company, March 2012) by an estimated 300 day operating season (5×300÷365=4.11). 

aq) Estimated 1,000small commercial fishing equivalents calculated by multiplying the 2,000 small commercial fishing vessels that ha

USEPA. 2010. Report to Congress: Study of Discharges Incidental to Normal Operation of Commercial Fishing Vessels and other 

Vessels Less than 79 Feet, August, 2010. Figure 1.6. U.S. Environmental Protection Agency. Washington, D.C; best professional ju0.5 to account for the estimated maximum portion of these vessels operating or offloading fish in the harbor at any given time (bes(2,000×0.5=1,000). 

ar) Zero or negligible numbers of small commercial fishing vessels operate in St. Louis, Houston, and Miami (best professional judgm

as) One small commercial fishing vessel is berthed in the harbor about 10 months/yr (Source: Personal communication with James Sh

at the Duluth Seaway Port Authority, January 2012). 
2013 VGP and sVGP BE 

G-74

at) Estimated the 100 small commercial fishing that hail from New York operated 8 hr/day in the harbor (Source: USEPA. 2010. Repo

Discharges Incidental to Normal Operation of Commercial Fishing Vessels and other Non-Recreational Vessels Less than 79 Feet

U.S. Environmental Protection Agency. Washington, D.C; best professional judgment based on personal observation) (100×8÷24=

au) Estimated 53.8small commercial fishing vessel equivalents by multiplying the annual 6,540 vessel calls (Source: Personal commun

Port of San Francisco and Julie Coombes, California Department of Fish and Game, February 2012) by a factor of 3 to account for 

fishing season (6,540÷365×3=53.8). 

av) Estimated 15.0 passenger vessel equivalents as the sum of 2.4 water taxi equivalents, 10.9 tour boat equivalents, and 1.6 charter bo

(2.4+10.9+1.6=15.0). Water taxi equivalents calculated by multiplying 2 water taxis operating 5 days/week for 7 months/yr [2×(5×Tour boat equivalents calculated by multiplying 17 tour boats operating 9 hr/day for 7 months/yr [17×(9÷24)×(12÷7)=10.9]. Chartcalculated by multiplying 3 charter boats each operating a maximum of five 90 minute charters per day (7.5 hours/day) for 7 month[3×(7.5÷24)×(12÷7)=1.6]. (Source: http://www.frommers.com/destinations/seattle/0032010019.html, www.seattleducktours.net, and http://www.sailingseattle.com/ind

aw) Two passenger vessels operate in St. Louis harbor 7 days/week for 9 months/yr (Source: http://www.boatinfoworld.com/boat/regis

63111.asp, Accessed Feb 2012). 

ax) Estimated 1.64 passenger vessel equivalents calculated based on two passenger vessels operating in the Duluth harbor 300 days/yr 

600 tours (2×300÷365=1.64 (Source: Personal communication with James Sharrow, Facilities Manager at the Duluth Seaway Port 

ay) Estimated 0.1 passenger vessel equivalents based on one passenger vessel operating in the Houston harbor conducting ten 1.5 hour

months/yr round [1×(1.5×10÷7÷24)×(12÷11)=0.1] (Source: http://boattours.poha.com/boattour/default.aspx). 

az) Estimated 10.0 passenger vessel equivalents calculated based on 20 charters, sightseeing, tour, and water taxi vessels operating in N

each assumed to operated 9 hours/day for 9 months/yr [20×(9÷24)×(12÷9)=10.0] (Sources: http://www.newyorksightseeing.com/c

http://www.citysightsny.com/category.php?id=-1, http://manhattan.about.com/od/gettingaround/tp/nycsightseeingboattrips.htm, an

nyc.com/). 

ba) Estimated 4.43 passenger vessel equivalents calculated based on based on 13 tour and dinner cruise vessels (3 Red and White Fleet

and 7 Hornblower Cruises) operating a combined equivalent of 1,616 24-hour operating days/yr, divided by 365 days/yr (1,616÷36Blue Fleet, Blue and Gold Fleet, and Hornblower websites). 

bb) Estimated 4.94 passenger vessel equivalents calculated based on based on 6 charter, sightseeting, tour, and water taxi vessels opera

operating a combined equivalent of 1,802 24-hour operating days/yr, divided by 365 days/yr (1,802÷365=4.94) (Source: passenger 

bc) Estimated 6 utility vessel equivalents based on 20 tug boats operating in Miami (Source: Personal communication with Jill Taft, Re

Manager at Enterprise Marine Services and Coastal Tug and Barge of Miami, and George Arocha, Terminal Manager at the Port oOperating Company, March 2012) for an assumed 8 hours/day [20×(8÷24)=6] year round. 

bd) Estimated 16.3 utility vessel equivalents working in harbor determined using Google Earth to count 17 tug boats operating in the h

operating days per year (17×350÷365=16.3). 

be) Estimated 16.4 utility vessel equivalents working in harbor based on 20 tug boats operating in the harbor for 300 operating days pe

communication with James Sharrow, Facilities Manager at the Duluth Seaway Port Authority, January 2012) (20×300÷365=16.4). 

bf) Estimated 42.7 utility vessel equivalents working in harbor calculated by multiplying the 20 tug boats operating in Seattle by an as

scaling factor of 6.4 (20×8÷24×6.4=42.7). Scaling factor calculated as the ratio between the annual total number of vessel port callthe annual total number of port calls in Seattle (6,698÷1,046=6.4) (Source: MARAD http://www.marad.dot.gov/documents/US_Port_Calls_by_Vessel_Type.xls). 

bg) Estimated 28.9 utility vessel equivalents working in harbor calculated by multiplying the 20 tug boats operating in Seattle by an as

scaling factor of 4.33 (20×8÷24×4.33=28.9). Scaling factor calculated as the ratio between the annual total number of vessel port c
2013 VGP and sVGP BE 

G-75

by the annual total number of port calls in Seattle (4,534÷1,046=4.33) (Source: MARAD http://www.marad.dot.gov/documents/US_Port_Calls_by_Vessel_Type.xls). 

bh) Estimated 16.3 utility vessel equivalents calculated based on 17 tug boats operating in San Francisco (Crowley, 2 tugs; Bay Delta M

Marine Services, 11 tugs) (Source: Personal communication with AEP River Operations) for an assumed 350 operating days/yr [17

round. 

bi) Estimated 7.67 utility vessel equivalents calculated based on 8 tug boats operating in Miami (Source: Personal communication with 

Compliance Manager at Enterprise Marine Services and Coastal Tug and Barge of Miami, March 2012) for an assumed 350 operat

[8×(350÷365)=7.67]. 

Table G-8. Total VGP and sVGP Pollutant Loads for RAA Harbors Under Pre-permit Conditions 

Class Analyte Estuary Harbor Loads (lb/day) River Harbo

(lb/day

Seattle Houston New York San Fran Miami Duluth 

Classicals Biochemical Oxygen Demand (BOD) 21,000 1,100 8,970 3,540 4,960 161 Classicals Hexane Extractable Material (HEM) 1,430 255 1,510 703 1,460 14.1 Classicals Silica Gel Treated HEM (SGT-HEM) 389 76.9 372 182 371 3.72 Classicals Total Residual Chlorine 49.3 0.561 4.6 1.08 1.65 0.0537 Classicals Total Suspended Solids (TSS) 4,650 589 1,720 831 1,070 40.1 Metals Aluminum, Total 29.5 9.97 19.5 9.51 13.8 0.513 Metals Arsenic, Dissolved 8.47 44.5 39.1 26.1 20.1 3.21 Metals Arsenic, Total 8.65 44.5 39.1 26.2 20.2 3.21 Metals Cadmium, Dissolved 0.0199 0.00449 0.00589 0.00378 0.00425 0.000207 Metals Chromium, Dissolved 0.044 0.0142 0.0157 0.0103 0.00991 0.00078 Metals Copper, Dissolved 4.95 8.56 8.61 5.43 4.49 0.646 Metals Lead, Dissolved 0.066 0.0203 0.0678 0.0267 0.0437 0.00143 Metals Nickel, Dissolved 1.26 6.69 5.9 3.93 3.06 0.481 Metals Nickel, Total 0.115 0.256 0.288 0.169 0.203 0.0141 Metals Selenium, Dissolved 9.44 51.6 45.4 30.3 23.4 3.73 Metals Selenium, Total 9.91 54.9 48.3 32.2 24.9 3.96 Metals Zinc, Dissolved 11.3 1.43 8.58 3.12 5.05 0.157 Nutrients Ammonia As Nitrogen (NH3-N) 219 4.06 36.8 21.5 21.7 0.626 Nutrients Total Phosphorus 273 19.7 96 56.3 98.8 0.886 
2013 VGP and sVGP BE 

G-76

Table G-8. Total VGP and sVGP Pollutant Loads for RAA Harbors Under Pre-permit Conditions 

Class Analyte Estuary Harbor Loads (lb/day) River Harbo

(lb/day

Seattle Houston New York San Fran Miami Duluth 

SVOC 2,4,6-Trichlorophenol 0.0236 0.00363 0.00393 0.00294 0.0021 0.000198 SVOC Benzo(a)anthracene 0.158 0.156 0.142 0.0972 0.069 0.0156 SVOC Benzo(a)pyrene 0.141 0.0862 0.0808 0.0562 0.0375 0.0105 SVOC Benzo(b)fluoranthene 0.112 0.0101 0.0133 0.0108 0.00325 0.00445 SVOC Benzo(k)fluoranthene 0.124 0.0111 0.0147 0.012 0.0036 0.00493 SVOC Bis(2-ethylhexyl) phthalate 0.131 0.0285 0.0349 0.023 0.0213 0.00376 SVOC Chrysene 0.169 0.217 0.196 0.133 0.0965 0.02 SVOC Ideno(1,2,3-cd)pyrene 0.0997 0.00899 0.0118 0.00966 0.0029 0.00398 VOC Benzene 0.716 0.11 0.136 0.0964 0.069 0.0222 VOC Bromodichloromethane 0.0319 0.035 0.0448 0.0243 0.0368 0.00143 VOC Dibromochloromethane 0.0319 0.035 0.0448 0.0243 0.0368 0.00143 VOC Tetrachloroethene 0.000263 0.000588 0.000662 0.000388 0.000465 0.0000324 0VOC Trichloroethene 0.992 26.2 4.81 0.215 0.222 0.0000737 Table G-9. Total VGP and sVGP Pollutant Loads for RAA Harbors Under Post-permit Conditions 

Class Analyte Estuary Harbor Loads (lb/day) River Harbo

(lb/day

Seattle Houston New York San Fran Miami Duluth 

Classicals Biochemical Oxygen Demand (BOD) 15,500 930 8,580 3,130 4,770 146 Classicals Hexane Extractable Material (HEM) 718 123 745 345 721 5.5 Classicals Silica Gel Treated HEM (SGT-HEM) 205 37.7 184 89.6 182 1.55 Classicals Total Residual Chlorine 15.2 0.417 3.02 0.937 1.46 0.0456 Classicals Total Suspended Solids (TSS) 2,980 263 1,250 519 703 24.2 Metals Aluminum, Total 23.5 6.43 14.5 6.26 9 0.323 Metals Arsenic, Dissolved 8.35 44.5 39.1 26.1 20.1 3.21 
2013 VGP and sVGP BE 

G-77

Table G-9. Total VGP and sVGP Pollutant Loads for RAA Harbors Under Post-permit Conditions 

Class Analyte Estuary Harbor Loads (lb/day) River Harbo

(lb/day

Seattle Houston New York San Fran Miami Duluth 

Metals Arsenic, Total 8.5 44.5 39.1 26.2 20.2 3.21 Metals Cadmium, Dissolved 0.016 0.00281 0.00359 0.00225 0.00216 0.000116 Metals Chromium, Dissolved 0.0426 0.012 0.0134 0.00886 0.00816 0.000661 Metals Copper, Dissolved 4.55 8.5 8.51 5.36 4.42 0.642 Metals Lead, Dissolved 0.0602 0.014 0.0591 0.0212 0.0353 0.00109 Metals Nickel, Dissolved 1.23 6.68 5.89 3.93 3.05 0.481 Metals Nickel, Total 0.115 0.256 0.288 0.169 0.203 0.0141 Metals Selenium, Dissolved 9.41 51.6 45.4 30.3 23.4 3.73 Metals Selenium, Total 9.91 54.9 48.3 32.2 24.9 3.96 Metals Zinc, Dissolved 10.4 1.11 8.14 2.83 4.66 0.139 Nutrients Ammonia As Nitrogen (NH3-N) 171 3.67 34.7 18.8 21.4 0.558 Nutrients Total Phosphorus 12.5 1.22 2.28 1.32 1.11 0.0767 SVOC 2,4,6-Trichlorophenol 0.0118 0.00228 0.00219 0.00149 0.00106 0.0000992 SVOC Benzo(a)anthracene 0.158 0.156 0.142 0.0972 0.069 0.0156 SVOC Benzo(a)pyrene 0.141 0.0862 0.0808 0.0562 0.0375 0.0105 SVOC Benzo(b)fluoranthene 0.112 0.0101 0.0133 0.0108 0.00325 0.00445 SVOC Benzo(k)fluoranthene 0.124 0.0111 0.0147 0.012 0.0036 0.00493 SVOC Bis(2-ethylhexyl) phthalate 0.0976 0.0159 0.0186 0.0127 0.00842 0.0031 SVOC Chrysene 0.169 0.217 0.196 0.133 0.0965 0.02 SVOC Ideno(1,2,3-cd)pyrene 0.0997 0.00899 0.0118 0.00966 0.0029 0.00398 VOC Benzene 0.593 0.0739 0.0891 0.0657 0.0326 0.0203 VOC Bromodichloromethane 0.011 0.0109 0.0132 0.00638 0.00935 0.000368 VOC Dibromochloromethane 0.011 0.0109 0.0132 0.00638 0.00935 0.000368 VOC Tetrachloroethene 0.000132 0.000294 0.000331 0.000194 0.000233 0.0000162 0VOC Trichloroethene 0.00439 0.000847 0.000814 0.000552 0.000395 0.0000368 
2013 VGP and sVGP BE Appendix H 

Appendix H. Summary of RQs for Aquatic Multiple Routes of Exposure and 

Oral Ingestion by Aquatic and Aquatic-Dependent Wildlife Species 
2013 VGP and sVGP BE 

H-1 

Table H-1. Information Used to Calculate RQ based on Multiple Routes of Exposure for Aquatic Organis

Pollutant Species Type BCF or BAF L/kg ECwater ug/L ECTissue mg/kg ww CTETA,Tissue mg/kg ww Surrogat

From OR 

Toxics BE, 

Unless Noted 

Otherwise 

From 

Hypothetical 

Harbor Model 

Calc 

Value = BCF x 

(EC

W/ 1,000) 

From OR 

Toxics BE, 

Unless Noted 

Otherwise 

Provided 

Latin Nam

Pre-permit 

Aluminum, Total Estuary Vert 50.00 1.28 0.0642 - - Aluminum, Total Estuary Invert 50.00 1.28 0.0642 - - Aluminum, Total River Vert 50.00 0.0334 0.00167 10.00 S. trutta Aluminum, Total River Invert 50.00 0.0334 0.00167 - - 

Post-permit 

Aluminum, Total Estuary Vert 50.00 1.02 0.0511 - - Aluminum, Total Estuary Invert 50.00 1.02 0.0511 - - Aluminum, Total River Vert 50.00 0.0309 0.00154 10.00 S. trutta Aluminum, Total River Invert 50.00 0.0309 0.00154 - - 

Post-permit 

Arsenic, Dissolved Estuary Vert 44.00 1.94 0.0852 - - Arsenic, Dissolved Estuary Invert 44.00 1.94 0.0852 - - Arsenic, Dissolved River Vert 36.80a 0.164 0.00604 0.97 L. macrochiArsenic, Dissolved River Invert 39.40a 0.164 0.00647 3.58 M. macroco

Pre-permit 

Cadmium, Dissolved Estuary Vert 38.00 0.000867 0.0000329 0.04 P. flesus Cadmium, Dissolved Estuary Invert 38.00 0.000867 0.0000329 0.14 A. rubens Cadmium, Dissolved River Vert 38.00 0.0000129 0.000000489 0.01 S. salar Cadmium, Dissolved River Invert 38.00 0.0000129 0.000000489 0.12 H. azteca 
2013 VGP and sVGP BE 

H-2 

Table H-1. Information Used to Calculate RQ based on Multiple Routes of Exposure for Aquatic Organis

Pollutant Species Type BCF or BAF L/kg ECwater ug/L ECTissue mg/kg ww CTETA,Tissue mg/kg ww Surrogat

From OR 

Toxics BE, 

Unless Noted 

Otherwise 

From 

Hypothetical 

Harbor Model 

Calc 

Value = BCF x 

(EC

W/ 1,000) 

From OR 

Toxics BE, 

Unless Noted 

Otherwise 

Provided 

Latin Nam

Post-permit 

Cadmium, Dissolved Estuary Vert 38.00 0.000697 0.0000265 0.04 P. flesus Cadmium, Dissolved Estuary Invert 38.00 0.000697 0.0000265 0.14 A. rubens Cadmium, Dissolved River Vert 38.00 0.0000118 0.000000448 0.01 S. salar Cadmium, Dissolved River Invert 38.00 0.0000118 0.000000448 0.12 H. azteca 

Pre-permit 

ChromiumVI, Dissolved Estuary Vert 40.00 0.00191 0.0000765 - - ChromiumVI, Dissolved Estuary Invert 40.00 0.00191 0.0000765 3.20 P. pelagicChromiumVI, Dissolved River Vert 40.00 0.0000399 0.0000016 1.28 O. tshawytsChromiumVI, Dissolved River Invert 40.00 0.0000399 0.0000016 - - 

Post-permit 

ChromiumVI, Dissolved Estuary Vert 40.00 0.00185 0.0000742 - - ChromiumVI, Dissolved Estuary Invert 40.00 0.00185 0.0000742 3.20 P. pelagicChromiumVI, Dissolved River Vert 40.00 0.0000338 0.00000135 1.28 O. tshawytsChromiumVI, Dissolved River Invert 40.00 0.0000338 0.00000135 - - 

Post-permit 

Copper, Dissolved Estuary Vert 290.00 0.37 0.107 4.59 C. lebrosuCopper, Dissolved Estuary Invert 290.00 0.37 0.107 3.90 A. clausi Copper, Dissolved River Vert 290.00 0.0328 0.00953 3.00 O. mykiss 
2013 VGP and sVGP BE 

H-3 

Table H-1. Information Used to Calculate RQ based on Multiple Routes of Exposure for Aquatic Organis

Pollutant Species Type BCF or BAF L/kg ECwater ug/L ECTissue mg/kg ww CTETA,Tissue mg/kg ww Surrogat

From OR 

Toxics BE, 

Unless Noted 

Otherwise 

From 

Hypothetical 

Harbor Model 

Calc 

Value = BCF x 

(EC

W/ 1,000) 

From OR 

Toxics BE, 

Unless Noted 

Otherwise 

Provided 

Latin Nam

Copper, Dissolved River Invert 290.00 0.0328 0.00953 3.80 C. dubia 

Pre-permit 

Lead, Dissolved Estuary Vert 49.00 0.00295 0.000144 - - Lead, Dissolved Estuary Invert 49.00 0.00295 0.000144 260.00 C. edule Lead, Dissolved River Vert 49.00 0.0000922 0.00000452 0.40 S. fontinalLead, Dissolved River Invert 49.00 0.0000922 0.00000452 4.20 H. azteca 

Post-permit 

Lead, Dissolved Estuary Vert 49.00 0.00262 0.000128 - - Lead, Dissolved Estuary Invert 49.00 0.00262 0.000128 260.00 C. edule Lead, Dissolved River Vert 49.00 0.0000878 0.0000043 0.40 S. fontinalLead, Dissolved River Invert 49.00 0.0000878 0.0000043 4.20 H. azteca 

Post-permit 

Nickel, Dissolved Estuary Vert 47.00 0.291 0.0137 - - Nickel, Dissolved Estuary Invert 47.00 0.291 0.0137 26.40 L. pictus Nickel, Dissolved River Vert 47.00 0.0246 0.00116 - - Nickel, Dissolved River Invert 47.00 0.0246 0.00116 1.15 H. azteca 

Post-permit 

Nickel, Total Estuary Vert 47.00 0.0125 0.000589 - - Nickel, Total Estuary Invert 47.00 0.0125 0.000589 26.40 L. pictus Nickel, Total River Vert 47.00 0.000723 0.000034 - - Nickel, Total River Invert 47.00 0.000723 0.000034 1.15 H. azteca 
2013 VGP and sVGP BE 

H-4 

Table H-1. Information Used to Calculate RQ based on Multiple Routes of Exposure for Aquatic Organis

Pollutant Species Type BCF or BAF L/kg ECwater ug/L ECTissue mg/kg ww CTETA,Tissue mg/kg ww Surrogat

From OR 

Toxics BE, 

Unless Noted 

Otherwise 

From 

Hypothetical 

Harbor Model 

Calc 

Value = BCF x 

(EC

W/ 1,000) 

From OR 

Toxics BE, 

Unless Noted 

Otherwise 

Provided 

Latin Nam

Post-permit 

Selenium, Total Estuary Vert 113.00 2.39 0.27 1.98 Fish Selenium, Total Estuary Invert 113.00 2.39 0.27 - A. clausi Selenium, Total River Vert 250.00b 0.203 0.0507 4.84 O. mykiss Selenium, Total River Invert 729.40b 0.203 0.148 5.28 C. trangulif

Pre-permit 

Zinc, Dissolved Estuary Vert 47.00 0.493 0.0232 - - Zinc, Dissolved Estuary Invert 47.00 0.493 0.0232 24.00 A. compresZinc, Dissolved River Vert 47.00 0.00968 0.000455 7.70 O. mykiss Zinc, Dissolved River Invert 47.00 0.00968 0.000455 17.40 D. magna 

Post-permit 

Zinc, Dissolved Estuary Vert 47.00 0.452 0.0213 - - Zinc, Dissolved Estuary Invert 47.00 0.452 0.0213 24.00 A. compresZinc, Dissolved River Vert 47.00 0.00948 0.000445 7.70 O. mykiss Zinc, Dissolved River Invert 47.00 0.00948 0.000445 17.40 D. magna 

Post-permit 

Benzo(a)pyrene Estuary Vert 13035c 0.00614 0.08 71.74 O. gorbuscBenzo(a)pyrene Estuary Invert 733d 0.00614 0.0045 18.27 R. abroniuBenzo(a)pyrene River Vert 13035c 0.000536 0.00699 71.74 O. gorbuscBenzo(a)pyrene River Invert 733d 0.000536 0.000393 18.27 H. azteca 

Pre-permit 

Bis(2-ethylhexyl) phthalate Estuary Vert 

12300e 0.00569 0.0699 - - 
2013 VGP and sVGP BE 

H-5 

Table H-1. Information Used to Calculate RQ based on Multiple Routes of Exposure for Aquatic Organis

Pollutant Species Type BCF or BAF L/kg ECwater ug/L ECTissue mg/kg ww CTETA,Tissue mg/kg ww Surrogat

From OR 

Toxics BE, 

Unless Noted 

Otherwise 

From 

Hypothetical 

Harbor Model 

Calc 

Value = BCF x 

(EC

W/ 1,000) 

From OR 

Toxics BE, 

Unless Noted 

Otherwise 

Provided 

Latin Nam

Bis(2-ethylhexyl) phthalate Estuary Invert 

10000f 0.00569 0.0569 - - 

Bis(2-ethylhexyl) phthalate River Vert 

12300e 0.000198 0.00243 - - 

Bis(2-ethylhexyl) phthalate River Invert 

10000f 0.000198 0.00198 - - 

Post-permit 

Bis(2-ethylhexyl) phthalate Estuary Vert 

12300e 0.00424 0.0522 - - 

Bis(2-ethylhexyl) phthalate Estuary Invert 

10000f 0.00424 0.0424 - - 

Bis(2-ethylhexyl) phthalate River Vert 

12300e 0.000175 0.00215 - - 

Bis(2-ethylhexyl) phthalate River Invert 

10000f 0.000175 0.00175 - - 

Pre-permit 

Benzene Estuary Vert 87.7g 0.0311 0.00273 38.86 O. gorbuscBenzene Estuary Invert 87.7g 0.0311 0.00273 9.90 R. abroniuBenzene River Vert 87.7g 0.00117 0.000102 38.86 O. gorbuscBenzene River Invert 87.7g 0.00117 0.000102 9.90 H. azteca 
2013 VGP and sVGP BE 

H-6 

Table H-1. Information Used to Calculate RQ based on Multiple Routes of Exposure for Aquatic Organis

Pollutant Species Type BCF or BAF L/kg ECwater ug/L ECTissue mg/kg ww CTETA,Tissue mg/kg ww Surrogat

From OR 

Toxics BE, 

Unless Noted 

Otherwise 

From 

Hypothetical 

Harbor Model 

Calc 

Value = BCF x 

(EC

W/ 1,000) 

From OR 

Toxics BE, 

Unless Noted 

Otherwise 

Provided 

Latin Nam

Post-permit 

Benzene Estuary Vert 87.7g 0.0258 0.00226 38.86 O. gorbuscBenzene Estuary Invert 87.7g 0.0258 0.00226 9.90 R. abroniuBenzene River Vert 87.7g 0.0011 0.0000964 38.86 O. gorbuscBenzene River Invert 87.7g 0.0011 0.0000964 9.90 H. azteca 

Source: USEPA 2008 unless otherwise noted a) EPRI, 2008. 

b) EPRI, 2006. c) Log Baseline BAF of 4.114 

d) Kolok et al., 1996. e) log Kow=4xFCM=1.23 

f) log Kow=4x FCM=1 g) log Kow=1.943 
2013 VGP and sVGP BE 

H-7 

Table H-2. Information Used to Calculate Oral Ingestion RQ for Aquatic-Dependent Mammals 

Pollutant 

Water 

Type 

BCF or BAF

L/kg 

ECwater

ug/L 

ECTissue

mg/kg ww 

Eprey

mg/kg/d 

Ewater

mg/kg/d 

ECoral

mg/kg/d 

CTETOral

mg/kg/d 

From OR 

Toxics BE, 

Unless Noted 

Otherwise 

From 

Hypothetical 

Harbor 

Model Calc 

Value = BCF 

x (EC

W/ 

1,000) 

Value = 

IRF (surr) 

x ECT - 

see Table 

Inset 

Below for 

IRFs 

Value = DRF 

(surr) x (EC

W/ 

1,000) - see 

Table Inset 

Below for 

DRFs 

Value = 

Eprey + 

Ewater

From Sampl

et al. 1996 in 

OR Toxics 

BE 

Pre-permit 

Aluminum, Total Estuary 50.00 1.28 0.0642 0.00992 N/A 0.00992 1.93 Aluminum, Total River 50.00 0.0334 0.00167 0.000258 0.00001 0.000268 1.93 

Post-permit 

Aluminum, Total Estuary 50.00 1.02 0.0511 0.0079 N/A 0.0079 1.93 Aluminum, Total River 50.00 0.0309 0.00154 0.000238 0.00000926 0.000248 1.93 

Post-permit 

Arsenic, Dissolved Estuary 44.00 1.94 0.0852 0.0132 N/A 0.0132 0.126 Arsenic, Dissolved River 36.80a 0.164 0.00604 0.000934 0.0000493 0.000983 0.126 

Pre-permit 

Cadmium, Dissolved Estuary 38.00 0.000867 0.0000329 0.00000264 N/A 0.00000264 1 Cadmium, Dissolved River 38.00 0.0000129 0.000000489 0.0000000391 0.000000000243 0.0000000394 1 

Post-permit 

Cadmium, Dissolved Estuary 38.00 0.000697 0.0000265 0.00000212 N/A 0.00000212 1 Cadmium, Dissolved River 38.00 0.0000118 0.000000448 0.0000000358 0.000000000222 0.0000000361 1 

Pre-permit 

ChromiumVI, Dissolved Estuary 40.00 0.00191 0.0000765 0.00000612 N/A 0.00000612 3.28 ChromiumVI, Dissolved River 40.00 0.0000399 0.0000016 0.000000128 0.000000000753 0.000000128 3.28 

Post-permit 

ChromiumVI, Dissolved Estuary 40.00 0.00185 0.0000742 0.00000593 N/A 0.00000593 3.28 ChromiumVI, Dissolved River 40.00 0.0000338 0.00000135 0.000000108 0.000000000638 0.000000109 3.28 
2013 VGP and sVGP BE 

H-8 

Table H-2. Information Used to Calculate Oral Ingestion RQ for Aquatic-Dependent Mammals 

Pollutant 

Water 

Type 

BCF or BAF

L/kg 

ECwater

ug/L 

ECTissue

mg/kg ww 

Eprey

mg/kg/d 

Ewater

mg/kg/d 

ECoral

mg/kg/d 

CTETOral

mg/kg/d 

From OR 

Toxics BE, 

Unless Noted 

Otherwise 

From 

Hypothetical 

Harbor 

Model Calc 

Value = BCF 

x (EC

W/ 

1,000) 

Value = 

IRF (surr) 

x ECT - 

see Table 

Inset 

Below for 

IRFs 

Value = DRF 

(surr) x (EC

W/ 

1,000) - see 

Table Inset 

Below for 

DRFs 

Value = 

Eprey + 

Ewater

From Sampl

et al. 1996 in 

OR Toxics 

BE 

Post-permit only 

Copper, Dissolved Estuary 290.00 0.37 0.107 0.0147 N/A 0.0147 11.7 Copper, Dissolved River 290.00 0.0328 0.00953 0.0013 0.00000325 0.00131 11.7 

Pre-permit 

Lead, Dissolved Estuary 49.00 0.00295 0.000144 0.0000116 N/A 0.0000116 8 Lead, Dissolved River 49.00 0.0000922 0.00000452 0.000000361 0.00000000174 0.000000363 8 

Post-permit 

Lead, Dissolved Estuary 49.00 0.00262 0.000128 0.0000103 N/A 0.0000103 8 Lead, Dissolved River 49.00 0.0000878 0.0000043 0.000000344 0.00000000165 0.000000346 8 

Post-permit 

Nickel, Dissolved Estuary 47.00 0.291 0.0137 0.00109 N/A 0.00109 40 Nickel, Dissolved River 47.00 0.0246 0.00116 0.0000924 0.000000464 0.0000929 40 

Post-permit 

Nickel, Total Estuary 47.00 0.0125 0.000589 0.0000471 N/A 0.0000471 40 Nickel, Total River 47.00 0.000723 0.000034 0.00000272 0.0000000136 0.00000273 40 

Post-permit 

Selenium, Total Estuary 113.00 2.39 0.27 0.0216 N/A 0.0216 0.2 Selenium, Total River 250.00b 0.203 0.0507 0.00405 0.00000382 0.00406 0.2 

Pre-permit 

Zinc, Dissolved Estuary 47.00 0.493 0.0232 0.00186 N/A 0.00186 160 Zinc, Dissolved River 47.00 0.00968 0.000455 0.0000364 0.000000182 0.0000366 160 
2013 VGP and sVGP BE 

H-9 

Table H-2. Information Used to Calculate Oral Ingestion RQ for Aquatic-Dependent Mammals 

Pollutant 

Water 

Type 

BCF or BAF

L/kg 

ECwater

ug/L 

ECTissue

mg/kg ww 

Eprey

mg/kg/d 

Ewater

mg/kg/d 

ECoral

mg/kg/d 

CTETOral

mg/kg/d 

From OR 

Toxics BE, 

Unless Noted 

Otherwise 

From 

Hypothetical 

Harbor 

Model Calc 

Value = BCF 

x (EC

W/ 

1,000) 

Value = 

IRF (surr) 

x ECT - 

see Table 

Inset 

Below for 

IRFs 

Value = DRF 

(surr) x (EC

W/ 

1,000) - see 

Table Inset 

Below for 

DRFs 

Value = 

Eprey + 

Ewater

From Sampl

et al. 1996 in 

OR Toxics 

BE 

Post-permit 

Zinc, Dissolved Estuary 47.00 0.452 0.0213 0.0017 N/A 0.0017 160 Zinc, Dissolved River 47.00 0.00948 0.000445 0.0000356 0.000000179 0.0000358 160 

Post-permit 

Benzo(a)pyrene Estuary 13035c 0.00614 0.08 0.0124 N/A 0.0124 1 Benzo(a)pyrene River 13035c 0.000536 0.00699 0.00108 0.000000161 0.00108 1 

Pre-permit 

Bis(2-ethylhexyl) phthalate Estuary 12300d 0.00569 0.0699 0.0108 N/A 0.0108 18.3 Bis(2-ethylhexyl) phthalate River 12300d 0.000198 0.00243 0.000376 0.0000000593 0.000376 18.3 

Post-permit 

Bis(2-ethylhexyl) phthalate Estuary 12300d 0.00424 0.0522 0.00806 N/A 0.00806 18.3 Bis(2-ethylhexyl) phthalate River 12300d 0.000175 0.00215 0.000332 0.0000000524 0.000332 18.3 
2013 VGP and sVGP BE 

H-10 

Table H-2. Information Used to Calculate Oral Ingestion RQ for Aquatic-Dependent Mammals 

Pollutant 

Water 

Type 

BCF or BAF

L/kg 

ECwater

ug/L 

ECTissue

mg/kg ww 

Eprey

mg/kg/d 

Ewater

mg/kg/d 

ECoral

mg/kg/d 

CTETOral

mg/kg/d 

From OR 

Toxics BE, 

Unless Noted 

Otherwise 

From 

Hypothetical 

Harbor 

Model Calc 

Value = BCF 

x (EC

W/ 

1,000) 

Value = 

IRF (surr) 

x ECT - 

see Table 

Inset 

Below for 

IRFs 

Value = DRF 

(surr) x (EC

W/ 

1,000) - see 

Table Inset 

Below for 

DRFs 

Value = 

Eprey + 

Ewater

From Sampl

et al. 1996 in 

OR Toxics 

BE 

Pre-permit 

Benzene Estuary 87.70e 0.0311 0.00273 0.000422 N/A 0.000422 26.36 Benzene River 87.70e 0.00117 0.000102 0.0000158 0.00000035 0.0000161 26.36 

Post-permit 

Benzene Estuary 87.70e 0.0258 0.00226 0.000349 N/A 0.000349 26.36 Benzene River 87.70e 0.0011 0.0000964 0.0000149 0.00000033 0.0000152 26.36 

Source: USEPA, 2008, unless otherwise noted a) EPRI, 2008. 

b) EPRI, 2006. c) Log Baseline BAF of 4.114 

d) log Kow=4xFCM=1.23 e) log Kow=1.943 
2013 VGP and sVGP BE 

H-11 

Table H-3. Information Used to Calculate Oral Ingestion RQ for Aquatic-Dependent Birds 

Pollutant Species Type BCF or BAF, L/kg ECwater, ug/L ECTissue, mg/kg ww Eprey, mg/kg/d Ewater, mg/kg/d ECoral, mg/kg/d CTETOral

mg/kg/d 

From OR 

Toxics BE, 

unless noted 

otherwise 

From 

Hypothetical 

Harbor 

Model Calc 

Value = BCF 

x (EC

W/ 

1,000) 

Value = 

IRF (surr) 

x ECT - 

see Table 

Inset 

Below for 

IRFs 

Value = DRF 

(surr) x (EC

W/ 

1,000) - see 

Table Inset 

Below for 

DRFs 

Value = 

Eprey + 

Ewater

From Sampl

et al. 1996 in 

OR Toxics 

BE 

 Pre-permit 

Aluminum, Total Estuary 50.00 1.28 0.0642 0.0775 N/A 0.0775 109.7 Aluminum, Total River 50.00 0.0334 0.00167 0.00202 0.0000046 0.00202 109.7 

 Post-permit 

Aluminum, Total Estuary 50.00 1.02 0.0511 0.0618 N/A 0.0618 109.7 Aluminum, Total River 50.00 0.0309 0.00154 0.00186 0.00000425 0.00187 109.7 

 Post-permit 

Arsenic, Dissolved Estuary 44.00 1.94 0.0852 0.00852 N/A 0.00852 5.14 Arsenic, Dissolved River 36.80a 0.164 0.00604 0.000604 0.00000328 0.000608 5.14 

 Pre-permit 

Cadmium, Dissolved Estuary 38.00 0.000867 0.0000329 0.00000329 N/A 0.00000329 1.45 Cadmium, Dissolved River 38.00 0.0000129 0.000000489 0.0000000489 0.000000000257 0.0000000492 1.45 

 Post-permit 

Cadmium, Dissolved Estuary 38.00 0.000697 0.0000265 0.00000265 N/A 0.00000265 1.45 Cadmium, Dissolved River 38.00 0.0000118 0.000000448 0.0000000448 0.000000000236 0.000000045 1.45 

 Pre-permit 

ChromiumVI, Dissolved Estuary 40.00 0.00191 0.0000765 0.000058 N/A 0.000058 8.59 ChromiumVI, Dissolved River 40.00 0.0000399 0.0000016 0.00000121 0.00000000403 0.00000121 8.59 

 Post-permit 

ChromiumVI, Dissolved Estuary 40.00 0.00185 0.0000742 0.0000562 N/A 0.0000562 8.59 ChromiumVI, Dissolved River 40.00 0.0000338 0.00000135 0.00000103 0.00000000342 0.00000103 8.59 
2013 VGP and sVGP BE 

H-12 

Table H-3. Information Used to Calculate Oral Ingestion RQ for Aquatic-Dependent Birds 

Pollutant Species Type BCF or BAF, L/kg ECwater, ug/L ECTissue, mg/kg ww Eprey, mg/kg/d Ewater, mg/kg/d ECoral, mg/kg/d CTETOral

mg/kg/d 

From OR 

Toxics BE, 

unless noted 

otherwise 

From 

Hypothetical 

Harbor 

Model Calc 

Value = BCF 

x (EC

W/ 

1,000) 

Value = 

IRF (surr) 

x ECT - 

see Table 

Inset 

Below for 

IRFs 

Value = DRF 

(surr) x (EC

W/ 

1,000) - see 

Table Inset 

Below for 

DRFs 

Value = 

Eprey + 

Ewater

From Sampl

et al. 1996 in 

OR Toxics 

BE 

 Post-permit 

Copper, Dissolved Estuary 290.00 0.37 0.107 0.0813 N/A 0.0813 47 Copper, Dissolved River 290.00 0.0328 0.00953 0.00722 0.00000332 0.00722 47 

 Pre-permit 

Lead, Dissolved Estuary 49.00 0.00295 0.000144 0.000109 N/A 0.000109 1.13 Lead, Dissolved River 49.00 0.0000922 0.00000452 0.00000342 0.00000000931 0.00000343 1.13 

 Post-permit 

Lead, Dissolved Estuary 49.00 0.00262 0.000128 0.0000972 N/A 0.0000972 1.13 Lead, Dissolved River 49.00 0.0000878 0.0000043 0.00000326 0.00000000886 0.00000327 1.13 

 Post-permit 

Nickel, Dissolved Estuary 47.00 0.291 0.0137 0.00137 N/A 0.00137 77.4 Nickel, Dissolved River 47.00 0.0246 0.00116 0.000116 0.000000492 0.000116 77.4 

 Post-permit 

Nickel, Total Estuary 47.00 0.0125 0.000589 0.0000589 N/A 0.0000589 77.4 Nickel, Total River 47.00 0.000723 0.000034 0.0000034 0.0000000145 0.00000341 77.4 

 Post-permit 

Selenium, Total Estuary 113.00 2.39 0.27 0.027 N/A 0.027 0.5 Selenium, Total River 250.00b 0.203 0.0507 0.00507 0.00000405 0.00507 0.5 

 Pre-permit 

Zinc, Dissolved Estuary 47.00 0.493 0.0232 0.0176 N/A 0.0176 14.5 
2013 VGP and sVGP BE 

H-13 

Table H-3. Information Used to Calculate Oral Ingestion RQ for Aquatic-Dependent Birds 

Pollutant Species Type BCF or BAF, L/kg ECwater, ug/L ECTissue, mg/kg ww Eprey, mg/kg/d Ewater, mg/kg/d ECoral, mg/kg/d CTETOral

mg/kg/d 

From OR 

Toxics BE, 

unless noted 

otherwise 

From 

Hypothetical 

Harbor 

Model Calc 

Value = BCF 

x (EC

W/ 

1,000) 

Value = 

IRF (surr) 

x ECT - 

see Table 

Inset 

Below for 

IRFs 

Value = DRF 

(surr) x (EC

W/ 

1,000) - see 

Table Inset 

Below for 

DRFs 

Value = 

Eprey + 

Ewater

From Sampl

et al. 1996 in 

OR Toxics 

BE 

Zinc, Dissolved River 47.00 0.00968 0.000455 0.000345 0.000000977 0.000346 14.5 

 Post-permit 

Zinc, Dissolved Estuary 47.00 0.452 0.0213 0.0161 N/A 0.0161 14.5 Zinc, Dissolved River 47.00 0.00948 0.000445 0.000337 0.000000957 0.000338 14.5 

 Pre-permit 

Bis(2-ethylhexyl) phthalate Estuary 12300c 0.00569 0.0699 0.0845 N/A 0.0845 1.1 Bis(2-ethylhexyl) phthalate River 12300c 0.000198 0.00243 0.00294 0.0000000272 0.00294 1.1 

 Post-permit 

Bis(2-ethylhexyl) phthalate Estuary 12300c 0.00424 0.0522 0.063 N/A 0.063 1.1 Bis(2-ethylhexyl) phthalate River 12300c 0.000175 0.00215 0.0026 0.0000000241 0.0026 1.1 Source: USEPA, 2008, unless otherwise noted a) EPRI, 2008. 

b) EPRI, 2006. c) log Kow=4xFCM=1.23 
2013 VGP and sVGP BE 

H-14 

Table H-4. Ingestion Rate Assumptions for Mammals and Birds ReferencesElectric Power Research Institute (EPRI). 2006. Fate and effects of selenium in lentic and lotic systems. Technic

1005315. EPRI, Palo Alto, CA. 

Electric Power Research Institute (EPRI). 2008. Evaluation of U.S. Environmental Protection Agency's arsenic a

criteria: Speciation and bioaccumulation issues. Technical Update No. 1015570. EPRI, Palo Alto, CA, DCorporation, Charlotte, NC, Progress Energy, Inc., Raleigh, NC, SCANA Corporation, Columbia, SC, S

Birmingham, AL, and Tennessee Valley Authority, Chattanooga, TN. 

Kolok, A.S., J.N. Huckins, J.D. Petty, and J.T. Oris. 1996. The role of water ventilation and sediment ingestion i

Benzo[a]pyrene in gizzard shad (Dorosoma cepedianum). Environ. Toxicol. Chem. 15(10):1752-1759. 

Surrogate 

Body 

weight, 

kg 

Food 

Intake 

Rate, 

kg/d 

Water 

Intake 

Rate, 

kg/d 

IRF, 

kg/kg bw/d 

IRD, 

L/kg bw/d Com

MammalsMouse 0.02 0.00 0.01 0.15 0.30 Rat 0.35 0.03 0.01 0.08 0.02 Using body weight from E

Sample et al. 1996 and wa

Mink 1.00 0.14 0.10 0.14 0.10 Birds Robin/Dove 0.08 0.09 0.01 1.21 0.14 Woodcock/ Chick/Quail 0.20 0.15 0.02 0.76 0.10 Mallard 1.00 0.10 0.02 0.10 0.02 Using water intake from wSource: USEPA, 2008, unless otherwise noted. IRF = Ingestion rate of food, calculated as Food Intake Rate ÷ Body Weight DRF = Ingestion rate of water, calculated as Water Intake Rate ÷ Body Weight 
2013 VGP and sVGP BE 

H-15 

Sample, B. E., D. M. Opresko, G.W. Suter II. 1996. Toxicological Benchmarks for Wildlife: 1996 Revision. Prep

Department of Energy Office of Environmental Management. 

EPA. 1988. Recommendations for and documentation of Biological Values for Use in Risk Assessment. EPA 60

Environmental Criteria and Assessment Office, Cincinnati, OH. 

USEPA. 2008. Biological Evaluation of Oregon’s Water Quality Criteria for Toxics. U.S. Environmental Protect

10. Dated January, 2008. 
2013 VGP and sVGP BE Appendix I 

Appendix I. Basis of Critical Body Burden Calculations for Benzo(a)pyrene 

and Benzene Used as CTET to Calculate RQA,M in Quantitative 

Effects Analysis 
2013 VGP and sVGP BE 

I-1 

Table I-1. Basis of Critical Body Burden Calculations for Benzo(a)pyrene and Benzene Used as CTET to C

Quantitative Effects 

Latin Name As Reported 

Value = 

log(C*L)- 

0.352 (PAH) 

Or 

0.109 

(MAH) 

Value = 

PAHCorrected 

antilog(C*L) 

ACR for 

Type 1 

Narcotics 

As 

Reported 

Value = 

C*L / ACR 

Benzo(a)pyreneSpecies 

log(C*L) - 

Acute Basis 

PAH 

correctionlog(C*L) 

C*L, 

μmol PAH (BaP)/

g octanol - 

Acute Basis ACR 

C*L, 

μmol BaP/ 

g octanol=lipid - 

Chronic Basis 

MW BaP,

μg /μmol 

Estima

fracti

lipid, 

O. gorbuscha 1.39 1.04 10.9 3.83 2.84 252.31 0.1 A. abronius 1.49 1.14 13.9 3.83 3.62 252.31 0.0H. azteca 1.51 1.16 14.5 3.83 3.77 252.31 0.0Benzene

log(C*L) – 

Acute Basis 

MAH 

correctionlog(C*L) 

C*L, 

μmol MAH (BZ)/ 

g octanol – 

Acute Basis 

ACR 

C*L, 

μmol BZ/ 

g octanol=lipid – 

Chronic Basis 

MW BZ, 

μg/μmol 

Estima

Fract

lipid, 

O. gorbuscha 1.39 1.28 19.1 3.83 4.98 78.11 0.1 A. abronius 1.49 1.39 24.3 3.83 6.34 78.11 0.0H. azteca 1.51 1.40 25.3 3.83 6.60 78.11 0.0Source: McGrath, J. A. and Di Toro, D. M. (2009), Validation of the target lipid model for toxicity assessment of residual petroleum coand polycyclic aromatic hydrocarbons. Environmental Toxicology and Chemistry, 28: 1130–1148. (Appendices 1 and 2 unless specifie