United States 

Environmental Protection 

Agency 

Environmental and Economic Benefits 

Analysis for Proposed Section 316(b) 

Existing Facilities Rule 

EPA 821-R-11-002

March 28, 2011

March 28, 2011 i 

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

 Contents 

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

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

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

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

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

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

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

2 BASELINE IMPACTS ....................................................................................................................................2-1

2.1 INTRODUCTION..................................................................................................................................2-1

2.2 MAJOR ANTHROPOGENIC STRESSORS IN AQUATIC ECOSYSTEMS ......................................................2-1

2.2.1 Habitat Loss .................................................................................................................................2-2

2.2.2 Water Quality ..............................................................................................................................2-3

2.2.3 Overharvesting ............................................................................................................................2-7

2.2.4 Invasive Species ...........................................................................................................................2-7

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

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

2.3.2 I&E Mortality Effects on T&E species ...................................................................................... 2-12

2.3.3 Thermal Effects .......................................................................................................................... 2-12

2.3.4 Chemical Effects ........................................................................................................................ 2-13

2.3.5 Effects of Flow Alteration .......................................................................................................... 2-15

2.4 COMMUNITY-LEVEL OR INDIRECT EFFECTS OF CWISS ................................................................... 2-15

2.4.1 Altered Community Structure and Patchy Distribution of Species ............................................ 2-16

2.4.2 Altered Food Webs .................................................................................................................... 2-16

2.4.3 Reduced Taxa and Genetic Diversity ......................................................................................... 2-16

2.4.4 Nutrient Cycling Effects ............................................................................................................. 2-17

2.4.5 Reduced Ecological Resistance ................................................................................................. 2-17

2.5 CUMULATIVE IMPACTS OF MULTIPLE FACILITIES ........................................................................... 2-17

2.5.1 Clustering of Facilities and CWISs on Major Rivers ................................................................ 2-17

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

3.3.6 Great Lakes Region ................................................................................................................... 3-12

3.3.7 Inland Region ............................................................................................................................ 3-13

3.3.8 National Estimates ..................................................................................................................... 3-14

3.4 LIMITATIONS AND UNCERTAINTIES ................................................................................................. 3-15

3.4.1 Data Limitation and Uncertainty ............................................................................................... 3-15

3.4.2 Structural Uncertainty ............................................................................................................... 3-16

3.4.3 Parameter Uncertainty .............................................................................................................. 3-17

3.4.4 Engineering Uncertainty ........................................................................................................... 3-18

4 ECONOMIC BENEFIT CATEGORIES ASSOCIATED WITH I&E MORTALITY 

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

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

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

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

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

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

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

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

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

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

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

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

5.2 T&E SPECIES AFFECTED BY CWISS .................................................................................................5-2

5.2.1 T&E Species Identification and Data Collection .........................................................................5-2

5.2.2 Number of T&E Species Affected per Facility .............................................................................5-3

5.2.3 Number of Facilities Affecting Individual T&E Species ..............................................................5-5

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

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

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

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

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

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

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

6 COMMERCIAL FISHING BENEFITS ........................................................................................................6-1

6.1 METHODOLOGY ................................................................................................................................6-1

6.1.1 Estimating Consumer and Producer Surplus ..............................................................................6-1

6.2 BENEFITS ESTIMATES FOR REGIONAL COMMERCIAL FISHING ...........................................................6-9

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

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

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

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

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

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

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

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

7 RECREATIONAL FISHING BENEFITS ....................................................................................................7-1

7.1 INTRODUCTION..................................................................................................................................7-1

7.2 METHODOLOGY ................................................................................................................................7-1

7.2.1 Estimating Marginal Value per Fish ...........................................................................................7-2

7.2.2 Calculating Recreational Fishing Benefits ..................................................................................7-5

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

9 HABITAT BASED METHODOLOGY FOR ESTIMATING NONUSE VALUES OF FISH 

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

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

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

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

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

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

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

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

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

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

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

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

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

9.3.3 Estimated Proportion of Household WTP Estimates Attributed to Fish Production 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

A.2.2 Non-utility Manufacturers (MU Facilities) ................................................................................ A-5

A.3 ELECTRIC POWER GENERATING FACILITIES ..................................................................................... A-6

A.3.1 Defining the Strata and Control Variables ................................................................................. A-7

A.3.2 Comparison of Results of the Detailed Questionnaire and Post-Stratified Weighting 

Schemes ...................................................................................................................................... A-7

APPENDIX B : CONSIDERATION OF POTENTIAL ECOLOGICAL EFFECTS DUE TO 

THERMAL DISCHARGES ............................................................................................................................ B-1

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

B.2 GENERAL EFFECTS OF THERMAL DISCHARGES ON AQUATIC BIOTA AND ECOSYSTEMS .................. B-1

B.3 INFLUENCE OF SITE-SPECIFIC FACTORS AND ENVIRONMENTAL SETTING ON THERMAL 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

C.7 INLAND .......................................................................................................................................... C-17

C.8 NATIONAL ESTIMATES ................................................................................................................... C-20

APPENDIX D : DISCOUNTING BENEFITS ...................................................................................................... D-1

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

D.2 TIMING OF BENEFITS ........................................................................................................................ D-1

D.3 DISCOUNTING AND ANNUALIZATION ............................................................................................... D-3

APPENDIX E : LIST OF T&E SPECIES OVERLAPPING CWIS ................................................................... E-1

APPENDIX F : DETAILED METHODOLOGIES OF CWIS, AND ESTIMATED BENEFITS OF 

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

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

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

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

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

APPENDIX G : ESTIMATION OF PRICE CHANGES FOR CONSUMER SURPLUS ............................... G-1

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

G.2 METHODOLOGY AND RESULTS ......................................................................................................... G-1

APPENDIX H : DETAILS OF REGIONAL COMMERCIAL FISHING BENEFITS ................................... H-1

APPENDIX I : DETAILS OF REGIONAL RECREATIONAL FISHING BENEFITS ................................... I-1

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

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

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

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

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

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

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

APPENDIX J : METHODS USED IN THE HABITAT BASED METHODOLOGY FOR 

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

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

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

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

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

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

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

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

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

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

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

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

 Tables 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

13
March 28, 2011 vii 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

 Figures 

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

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

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

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

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

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

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

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

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

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

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

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

1 Introduction 

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

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

streams, rivers, estuaries and coastal marine waters by CWISs causes adverse environmental impacts 

(AEI) to aquatic biota and communities in these waterbodies. These impacts are caused through several 

means, including impingement mortality (where fish and other aquatic life are trapped on equipment at 

the entrance to the CWIS) and entrainment mortality (where aquatic organisms, including eggs, and 

larvae are taken into the cooling system, passed through the heat exchanger, then discharged back into the 

source body). Additional adverse effects are often associated with CWIS operation, including nonlethal 

effects of impingement, thermal discharges, chemical effluents, flow modifications caused by these 

plants, and other impacts of variable and unknown magnitudes. 

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

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

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

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

impingement and entrainment (I&E) mortality, as well as reduce the magnitude of other impacts (i.e., 

thermal, chemical, and flow alteration) on aquatic ecosystems. Thus, changes in CWIS design or 

operation resulting from Section 316(b) regulation are likely to result in enhanced ecosystem function and 

increased ecological services provided by affected waterbodies. 

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

include: (1) electric generators and (2) manufacturers. In-scope 316(b) facilities include existing electric 

generators and manufacturers with a design intake flow (DIF) of at least 2 million gallons per day (MGD) 

that use at least 25 percent of the water they withdraw (measured on an average annual basis for each 

calendar year) exclusively for cooling purposes. 

EPA is required to conduct a benefit-cost analysis under Executive Order 12866 for economically 

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

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

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

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

economic benefits of reduced I&E mortality. 

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

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

different regulatory options for in-scope facilities. The report also presents the basic concepts involved in 

analyzing these economic benefits—including benefit categories and benefit taxonomies associated with 

market and nonmarket goods and services likely to flow from reduced I&E mortality. Specific chapters of 

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

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

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

1.1 Summary of the Proposed Regulation and Other Evaluated Options 

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

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

option evaluated in developing this proposed regulation is described below. 

 Option 1: I Everywhere. Establish Impingement Mortality Controls at All Existing Facilities 

that Withdraw over 2 MGD; Determine Entrainment Controls for Facilities Greater than 2 MGD 

DIF On a Site-specific Basis. 

 Option 2: I Everywhere and E for Facilities > 125 MGD. Establish Impingement Mortality 

Controls at All Existing Facilities that Withdraw over 2 MGD DIF; Require Flow Reduction 

Commensurate with Closed-cycle Cooling By Facilities Greater Than 125 MGD DIF. 

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

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

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

1.2 Study Design 

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

regions (California,1

 North Atlantic, Mid-Atlantic, South Atlantic, Gulf of Mexico, Great Lakes, and 

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

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

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

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

facilities and total actual intake flow by study region. 

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

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

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

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

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

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

 

1

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

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

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

day) 

Region

Number of In-Scope 

Facilitiesa

Flow Without 

Recirculation Recirculated Flow Total Flow

Californiab 8 1.19 0.00 1.2

Great Lakes 67 18.81 0.24 19.0

Inlandc 669 134.87 3.89 138.8

Mid-Atlantic 54 28.10 0.07 28.2

Gulf of Mexico 30 12.89 0.00 12.9

North Atlantic 26 7.04 0.00 7.0

South Atlantic 17 7.42 0.05 7.5

All Regions 871 210.30 4.25 214.5 a

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

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

baseline closures).

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

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

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

c

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

current table to prevent the double counting of facilities.

Source: U.S. EPA analysis for this report.

1.2.1 Coastal Regions 

The five coastal regions (California, North Atlantic, Mid-Atlantic, South Atlantic, and Gulf of Mexico) 

correspond to those of the National Oceanic and Atmospheric Administration’s (NOAA) National Marine 

Fisheries Service (NMFS). These regions include facilities that withdraw cooling water from estuaries, 

tidal rivers and ocean facilities within the NMFS regions. All facilities that withdraw cooling water from 

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

included in the Inland Region (Section 1.2.3) 

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

manufacturing facilities in California.2

 plus four facilities in Hawaii. The North Atlantic region 

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

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

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

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

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

Coastal regions include a total of 152 facilities. 

1.2.2 Great Lakes Region 

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

withdrawing cooling water from Lake Superior, Lake Michigan, Lake Huron (including Lake St. Clair), 

Lake Erie and Lake Ontario, and the connecting channels (Saint Mary’s River, Saint Clair River, Detroit 

 

2

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

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

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

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

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

Lakes region is comprised of 67 facilities. 

1.2.3 Inland Region 

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

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

669 such facilities in 39 states (including states with both coastal and inland facilities). 

1.3 Organization of the Document 

Chapter 2 provides information on the baseline conditions of the water bodies affected by in-scope 

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

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

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

Chapter 3. 

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

regulatory options. EPA provides an overview of all benefits (Chapter 4) and investigates several benefit 

categories in detail, including: benefits from improved protection of threatened and endangered (T&E) 

species (Chapter 5), commercial fishing benefits (Chapter 6), recreational fishing benefits (Chapter 7), 

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

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

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

not documented in previous chapters. 

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

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

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

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

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

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

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

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

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

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

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

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

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

2 Baseline Impacts 

2.1 Introduction 

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

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

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

Water Act (CWA). 

CWIS impacts do not occur in isolation from other ongoing physical, chemical, and biological stressors 

on aquatic habitats and biota in the receiving waterbody. Additional anthropogenic stressors may include, 

but are not limited to: degraded water and sediment quality, low dissolved oxygen (DO), eutrophication, 

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

species, etc. For example, many aquatic organisms subject to the effects of cooling water withdrawals 

reside in impaired (i.e., CWA 303(d) listed) waterbodies. Accordingly, they are potentially more 

vulnerable to cumulative impacts from other anthropogenic stressors (USEPA 2006a). The effect of these 

anthropogenic stressors on local biota may contribute to or compound the local impact of I&E mortality, 

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

near a single CWIS, multiple facilities and CWISs located in close proximity along the same waterbody 

may have additive or cumulative effects on aquatic communities (USEPA 2006a). 

Although it is difficult to measure, EPA believes that an aquatic population's compensatory ability—the 

capacity for a species to increase survival, growth, or reproduction rates in response to decreased 

population —is likely compromised by impingement and entrainment (I&E) mortality losses and the 

cumulative impact of other stressors in the environment over extended periods of time (USEPA 2006a). 

These cumulative impacts may lead to subtle, less-easily observed changes in aquatic communities and 

ecosystem function. These secondary impacts are difficult to isolate from background variability, partly 

because of the limited scope and inherent limitations of the data available to characterize I&E mortality. 

Since the aquatic habitat quality and health of the biotic community are shaped by the cumulative effect 

of many factors, it is important to characterize the environmental context of baseline impacts. This will 

permit comparisons between the relative influences of CWIS-related stressors and other factors, and result 

in a more accurate estimate of the environmental impact of the Section 316(b) regulation. 

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

stressors found in aquatic environments affected by CWISs. 

2.2 Major Anthropogenic Stressors in Aquatic Ecosystems 

All ecosystems and their biota are subject to natural variability in environmental conditions (e.g., seasonal 

perturbations), as well as periodic large-scale disturbances in environmental settings (e.g., drought, flood, 

fire, disease). Indigenous aquatic species and communities are adapted to this natural variability, such that 

large-scale events elicit a predictable loss, response and recovery cycle. Conversely, anthropogenic 

stressors tend to be more chronic in nature and often do not lead to recognizable recovery phases. Instead 

these stressors often lead to long-term environmental degradation associated with lowered biodiversity, 

reduced primary and secondary production, and a lowered capacity or resiliency of the ecosystem to 

recover to its original state in response to natural perturbations (Rapport and Whitford 1999). 
March 28, 2011 2-2 

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

Anthropogenic stressors are present to some degree in all major waterbodies of the United States, and are 

the result of many different impacts (Table 2-1). Four of the more important stressors include: (i) habitat 

loss; (ii) degraded water quality and sediment contamination; (iii) extractive uses of aquatic resources; 

and (iv) invasion by non-indigenous species (Rapport and Whitford 1999). CWIS-related impacts are 

considered here as a separate, fifth category of anthropogenic stress, one with many apparent similarities 

to overharvesting. Other large-scale stressors, such as change in watershed land use and engineering 

diversions, may be present. Thus, the true impact of CWISs on an aquatic community may be partly 

masked, or difficult to detect, due to the influence of other stressors on the receiving water. 

The remainder of this section summarizes effects of these four anthropogenic stressors on the waterbodies 

affected by in-scope 316(b) facilities. CWIS impacts on the aquatic ecosystems are summarized in 

Section 2.3. 

Table 2-1: Anthropogenic Stressors Impacting Aquatic Ecosystems Potentially Affected, Both 

Directly and Indirectly, by 316(b) Option Scenarios 

Anthropogenic Stressor 

Impacted by Regulation 

Option 1 Option 2 Option 3 Scale of Stressor 

CWIS Yes: Direct Yes: Direct Yes: Direct Local/Regional/National 

Habitat loss 

Development No No No Local 

Eutrophication Yes: Indirect Yes: Indirect Yes: Indirect Local/Regional 

Climate change No No No Regional/National/Global 

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

Engineering diversions 

Re-routing No No No Local/Regional 

Flow adjustments/removals/ 

modifications No Yes: Direct Yes: Direct Local/Regional 

Water impoundments/damming No No No Local/Regional 

Water quality 

Eutrophication Yes: Indirect Yes: Indirect Yes: Indirect Local/Regional 

Loss of riparian buffer zones No No No Local/Regional 

Sedimentation No Yes: Direct Yes: Direct Local/Regional 

Chemical pollution (organics, 

heavy metals, etc.) No Yes: Direct Yes: Direct Local/Regional 

Non-native / invasive species Yes: Indirect Yes: Indirect Yes: Indirect Local/Regional 

Extractive uses (e.g. fishing) Yes: Indirect Yes: Indirect Yes: Indirect Local/Regional 

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

Everywhere. 

2.2.1 Habitat Loss 

Structural aquatic habitat is generally recognized as the most significant determinant of the nature and 

composition of aquatic communities. Human occupation and restructuring of shorelines; construction and 

maintenance of harbors; installation of dams, canals, and other navigational infrastructure; draining of 

wetlands for agriculture and residential uses; and degradation of critical fish habitats have all taken a 

heavy toll on the numbers and composition of local fish and shellfisheries. Most 316(b) facilities have 

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

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

impoundments, and other water storage or conveyance structures have often been constructed at the cost 

of natural habitat, including terrestrial, aquatic, and wetlands. 

The loss of coastal and estuarine wetlands that serve as important fishery spawning and nursery areas is 

particularly severe, with an estimated historical loss of 100 million acres of wetlands since the late 1700s 

(Bromberg and Bertness 2005; USEPA 2010b). Critical fishery habitat loss is not restricted to nearshore 

environments. Decades of fishing activities have degraded offshore bottom habitats (Auster and Langton 

1999; Turner et al. 1999). 

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

concentration of fishery spawning and nursery areas to fewer locations, shifts in species dominance based 

on available habitat, and local extirpation of historical fish species. Habitat loss in adjacent shoreline 

areas exacerbates the effect of CWIS losses, since many fish species affected by I&E mortality (e.g., bay 

anchovy, winter flounder) rely on coastal wetlands as nursery areas. 

In riverine environments, the effects of channelization and navigation can also lead to habitat loss. For 

example, Tondreau et al. (1982) conducted a 10-year study of the aquatic ecosystem of the Missouri River 

near the Neal Generating facility, Sioux City, IA. The investigators found that the combined effects of 

channelization, heavy barge traffic, and high river flow rates had resulted in a significant loss of fish 

habitat. As a result, reported I&E mortality losses were relatively minor, because local fish populations 

were already greatly diminished. 

2.2.2 Water Quality 

Water quality is a major stressor of aquatic biota and habitats. Degraded surface water and sediment 

contaminants reflect current and historical industrial, agricultural and residential land use as well as 

discharges from wastewater treatment plants. Poor water quality can limit the numbers, composition, and 

distribution of fish and invertebrates; reduce spawning effort and growth rates; select for pollutiontolerant species; cause periodic fishkills; or result in adverse effects to piscivorous wildlife. 

CWA Section 303(d) listings inventory, on a state-by-state basis, the locations of impaired waters not 

meeting designated uses and the known or suspected source(s) of impairment. Figure 2-1 identifies 316(b) 

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

impaired for temperature (red shapes). The map clearly shows that facilities along the coasts, Great Lakes, 

and major waterways such as the Mississippi, Missouri, and Ohio rivers are located in the vicinity of 

impaired waterbodies. 
March 28, 2011 

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

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

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

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

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

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

waterbodies impaired by any cause, by region. These include impairment due to chemical, physical, and 

biological factors, categorized into biological stressors, nutrients, organic enrichment/loading, 

bioaccumulation, toxics, unknown causes, and general water quality impairment. 

The most common causes of impairment for waterbodies serving as 316(b) source waters are 

polychlorinated biphenyls (PCBs), pathogens, mercury, as well as organic enrichment/oxygen depletion 

and nutrients. The entire universe of all 303(d) water quality impairment causes is much too diverse to 

cover fully in this section. However, below we discuss some of the more common and important physicochemical impairments in aquatic environment where 316(b) facilities potentially draw cooling water from 

and discharge to 303(d) listed waters. 

 An oversupply of nutrients can result in excessive algal production, reduced light clarity, more 

frequent outbreaks of harmful algal blooms (HABs), high internal loads of biochemical oxygen 

demand (BOD), and spatial and temporally variable DO levels. In addition, eutrophication can 

reduce or eliminate habitat-formers such as coral reefs and submerged aquatic vegetation (SAV), 

and create other adverse ecological effects. Thermal discharges from 316(b) facilities can 

increase receiving water temperature, which may favor formation of blue-green algal blooms. 

 Low levels of dissolved oxygen (hypoxia) may be present in many estuaries and coastal waters 

(IWG 2010), in the hypolimnia of eutrophic lakes, and in areas of high organic loading (e.g., 

below wastewater treatment plant outfalls). DO concentrations may be further decreased in or 

downstream of thermal plumes arising from cooling water return discharges from 316(b) 

facilities. Low DO can limit the distribution of fish and macroinvertebrates, reduce growth rates, 

and alter nutrient and carbon recycling. 

 Persistent, bioaccumulative and toxic substances (PBTs) such as mercury or PCBs may be present 

in waterbodies near 316(b) facilities, due to atmospheric deposition of local air emissions or from 

historical uses of PCBs in electrical transformer units, in addition to other urban or industrial 

sources. These PBTs can impair water uses by regulatory restrictions or advisories regarding 

acceptable ingestion of fish consumption (see below), as well as affecting higher trophic level 

predators in the food chain. 

 Toxic pollutants, such as metals, polycyclic aromatic hydrocarbons (PAHs), pesticides, 

biofouling chemicals, or chlorine may be present in the discharge of 316(b) facilities. This could 

lead to local extirpation of sensitive species, or to greatly altered biological communities due to 

chronic impacts on viability, growth, reproduction, and resistance to other stressors. 

In addition to the 303(d) listings, many of the waterbodies in which the CWIS are located are subject to 

fish advisories. Fish advisories are issued by States to protect their citizens from the risk of eating 

contaminated fish or wildlife (USEPA 2009a). Fish advisories are recommendations and do not carry 

regulatory authority, but they indicate the presence of bioaccumulative chemicals which may pose risk for 

humans and piscivorous wildlife and which may also interfere with reproduction and survival of lower 

taxa as well. 
March 28, 2011 2-6 

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

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

Impairment California

Great 

Lakes Inland 

MidAtlanticGulf of 

Mexico 

North 

Atlantic 

South 

Atlantic Total 

Biological Stressors

Noxious Aquatic Plants 2 2 

Nuisance Exotic Species 2 9 11 

Pathogens 1 15 99 5 1 12 6 139 

Nutrients

Algal Growth 1 1 

Nutrients 15 47 3 1 2 9 77 

Organic Enrichment / Loading

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

Sediment 9 18 2 29 

Persistent, Bioaccumulative, Toxic (PBTs) 

Dioxins 1 14 13 2 30 

Fish Consumption Advisory - Pollutant 

Unspecified 8 1 9 

Mercury 2 28 96 4 2 3 135 

PCBs 3 57 142 13 2 1 218 

Pesticides 8 12 16 36 

Physical Alterations

Flow Alteration 7 7 

Habitat Alteration 6 12 18 

Temperature 9 3 12 

Turbidity 27 1 3 31 

Toxics

Ammonia 3 1 4 

Chlorine 2 2 

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

Total Toxicity 2 5 2 1 15 

Toxic Inorganics 1 1 2 

Toxic Organics 3 12 3 18 

Unknown / Other Causes 

Cause Unknown 11 1 12 

Cause Unknown - Fish Kills 1 1 

Cause Unknown - Impaired Biota 1 3 14 2 20 

Other Cause 1 1 

Water Quality Use Impairments (General) 

Oil And Grease 6 3 9 

pH 3 8 11 

Salinity/TDS/Sulfates/Chlorides 1 1 7 9 

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

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

EPA’s 2008 National Listing of Fish Advisories (NLFA) database indicates that 97% of the advisories are 

due (in order of importance) to: mercury, PCBs, chlordane, dioxins, and DDT (USEPA 2009a). Fish 

advisories have been issued for 39 percent of the total river miles (approximately 1.4 million river miles) 

and 100 percent of the Great Lakes and connecting waterways (USEPA 2009a). Fish advisories have been 

steadily increasing over the NLFA period of record (1993-2008), but these increases are interpreted to 

reflect the increase in the number of waterbodies being monitored by States and advances in analytical 

methods rather than in increasing levels of these problematic chemicals. 

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

facilities and other anthropogenic sources (as indicted by the presence of widespread fish advisories) 

could result in highly degraded or altered aquatic communities that may be further reduced by I&E 

mortality. 

2.2.3 Overharvesting 

Overharvesting is a general term given to describe the exploitation of an aquatic population (e.g., fish, 

shellfish, and kelp) in an unsustainable fashion to the point of reducing or even eliminating much of the 

population. Stocks of commercial and recreationally important species are reduced as a result of fishing, 

but such fish catches may be sustainable if sufficient recruitment of juveniles into the fishery can replace 

population losses from fishing and other stressors. Unfortunately for many aquatic species, overharvesting 

has a long history and in many instances has preceded impacts by other competing anthropogenic 

stressors by several centuries (Jackson et al. 2001). 

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

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

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

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

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

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

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

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

lobster. Moreover, this assessment does not consider any threatened and endangered (T&E) species. 

Severe overfishing can drive species to ecological insignificance, where the overfished populations no 

longer interact meaningfully in the food web with other species in the community, or even to extinction 

(Jackson et al. 2001). The collapse of the Great Lakes whitefish fisheries has been shown to be principally 

due to overfishing, although habitat alteration and introduction of a non-indigenous (exotic) invader (sea 

lamprey) were also contributory (Rapport and Whitford 1999). 

2.2.4 Invasive Species 

Non-indigenous, invasive species (NIS) are a significant and increasingly prevalent stressor in both 

freshwater and marine environments (Cohen and Carlton 1998; Ruiz et al. 1999). Approximately 300 NIS 

are established in marine and estuarine habitats of the continental U.S., and that rate of invasion is rapidly 

increasing (Ruiz et al. 2000). Aquatic NIS are taxonomically diverse and include: plants, fish, crabs, 

snails, clams, mussels, bryozoans, and nudibranchs. Analysis of freshwater NIS indicated that between 

10-15 percent are nuisance species with undesirable effects (Ruiz et al. 1999). The adverse implications 

of marine and coastal NIS are generally not as well-characterized as those in freshwater settings. 
March 28, 2011 2-8 

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

Interactions between NIS and other anthropogenic stressors are likely to affect the colonization and 

distribution of native species subject to CWIS impacts. Thermal discharges from 316(b) facilities may 

extend the seasonal duration of non-resident organisms, allowing transient summer species to become 

permanently established in geographic areas beyond their historical range. For example, in Mount Hope 

Bay, increased water temperature due to the Brayton Point Station facility led to an increase in abundance 

of the predacious ctenophore Mneimiopsis leidyi as well as increased overwintering in the Bay for this 

formerly seasonal resident (USEPA 2002b). 

2.3 CWIS Impacts to Aquatic Ecosystems 

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

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

site. Many of these facilities employ once-through cooling water systems that impinge fishes and other 

aquatic organisms on intake screens if the intake velocity exceeds these organisms’ locomotive ability to 

move away. Impinged organisms may be killed, injured or weakened, depending on the nature and 

capacity of the plant’s filter screen configuration, cleaning and backwashing operations, and fish return 

system used to return organisms back to the source water. In addition, early life stage fish or planktonic 

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

Stock or Stock 

Complex Overfishing a Overfished b

Approaching 

Overfishedc Rebuilding Stock Region 

American Plaice No Yes Yes North/Mid-Atlantic 

Atlantic Cod Yes Yes Yes North/Mid-Atlantic 

Atlantic Sturgeon No Yes Yes Atlantic 

Black Sea Bass Yes Yes Yes South Atlantic 

Boccacio No No No Yes California 

Butterfish No Yes Yes Mid-Atlantic 

Gag Yes No Yes No South Atlantic/Gulf of Mexico 

Grouper species Yes Yes Yes Gulf of Mexico 

Haddock No Yes Yes North/Mid-Atlantic 

Ocean Pout No Yes Yes North/Mid-Atlantic 

Pink Shrimp No Yes No South Atlantic 

Pollock No No No Yes North/Mid-Atlantic 

Porgy No Yes Yes South Atlantic 

Rockfish species Yes Yes Yes California 

Skate species No Yes Yes North/Mid-Atlantic 

Spiny Dogfish No No No Yes North/Mid-Atlantic 

Summer Flounder No No No Yes Mid-Atlantic 

Tautog Yes Unknown Unknown N/A Atlantic 

White Hake Yes Yes Yes North/Mid-Atlantic 

Windowpane No Yes Yes North/Mid-Atlantic 

Winter Flounder Yes Yes Yes North/Mid-Atlantic 

Yellowtail Flounder Yes Yes Yes North/Mid-Atlantic 

a

 Fishing mortality exceeds sustainable levels. 

b

 Stock size is below a sustainable biomass threshold. c

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

d

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

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

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

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

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

can act in concert with the other stressors identified above. 

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

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

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

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

populations’ compensatory reserves; losses to populations, including reductions of indigenous species 

population levels, commercial fisheries (Chapter 6), and recreational fisheries (Chapter 7); and stresses to 

overall communities and ecosystems, as evidenced by reductions in diversity or other changes in 

ecosystem structure or function. In addition, fish and other species affected directly and indirectly by 

CWIS can provide other valuable ecosystem goods and services, including nutrient cycling and ecosystem 

stability. 

The impacts of I&E mortality occur at many levels of ecological organization and across a wide range of 

environmental scales. Table 2-4 presents a summary of direct and indirect impacts of CWISs and I&E 

mortality. The effects are identified as direct, indirect, or a combination. This table also indicates the 

relative scale (local, regional, national) of the particular effect. In most cases, EPA was unable to estimate 

the magnitude of these effects due to a lack of data. In this section, we discuss a subset of these effects. 

2.3.1 Losses of Fish from I&E Mortality 

The most visible direct impact of I&E mortality is the loss of large numbers of aquatic organisms, 

distributed non-uniformly among fish, benthic invertebrates, phytoplankton, zooplankton, and other 

susceptible aquatic taxa (e.g., sea turtles). This has immediate and direct effects on the population size 

and age distribution of affected species, and may cascade through food webs. The direct impacts on 

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

fish species (Chapter 7). 

Populations of aquatic organisms decline when recruitment rates are lower than mortality rates. Natural 

sources of mortality for fish species include predation, food availability, injury, climatic factors and 

disease. Anthropogenic sources of fish mortality, both proximate and ultimate, include fishing, habitat 

modification, pollution, and I&E mortality at CWISs. EPA believes that reducing I&E mortality will 

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

populations. 

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

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

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

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

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

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

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

Directly and Indirectly, by 316(b) Regulations

Category Direct/Indirect Local/Regional/National 

A. Impingement and Entrainment (direct and indirect effects) 

Effects on Individuals 

Loss of billions of individuals (direct effects) Direct Regional/National 

Phytoplankton Direct Local/Regional/National 

Zooplankton (excluding fish larvae/eggs) Direct Local/Regional/National 

Invertebrates Direct Local/Regional/National 

Fish Direct Local/Regional/National 

Non-fish vertebrates Direct Local/Regional/National 

 

Species and Population-Level Effects 

Alteration of phenology of system (function of % water reduction in stream) Direct Local/Regional/National 

Altered distribution of populations Direct Local 

Altered niche space Direct Local/Regional 

Altered stable age distributions of populations Direct Regional 

Loss of keystone species Direct Local 

Loss of T&E species Direct Regional 

Novel selection pressure (e.g., negatively buoyant or stationary eggs) Direct & Indirect Local 

Reduced/altered genetic diversity Direct & Indirect Regional/National 

Reduced lifetime ecological function of individuals Direct Local/Regional 

 

Community and Trophic Relationships 

Altered competitive interactions Direct & Indirect Local 

Disrupted trophic relationships Direct & Indirect Local 

Disrupted control of disease-harboring insects (e.g., mosquito larvae, etc.) Indirect & Direct Local/Regional 

Increased quantity of detritivores Indirect Local 

Loss of ecosystem engineers (due to trophic interactions) Indirect & Direct Local 

Reduced potential for energy flows (e.g. trophic transfers) Indirect Local/Regional 

Species diversity and richness Direct & Indirect Local/Regional/National 

Trophic cascades Indirect & Direct Local/Regional 

 

Ecosystem Function 

Altered ecosystem succession Indirect & Direct Local/Regional 

Decreased ability of ecosystem to control nuisance species (algae, 

macrophytes) Indirect Local 

Disrupted cross-ecosystem nutrient exchange (e.g., up/downstream, 

aquatic/terrestrial) Indirect Regional 

Disrupted nutrient cycling Indirect & Direct Local/Regional 

Reduced compensatory ability to deal with environmental stress (resilience) Direct & Indirect Regional 

Reduced ecosystem resistance Indirect Local/Regional 

Reduced ecosystem stability (alternate states) Indirect Local/Regional 

Sediment regulation Indirect Local/Regional 

Substrate regulation Indirect Local 

 

B. Thermal Effects (direct and indirect) 

Novel selection pressure (e.g., thermal optima, location of breeding, etc.) Direct & Indirect Regional/National 

Altered phenology Direct Local/Regional 

Links between temperature and metabolism 

Dissolved oxygen (physical) Direct Local 

Dissolved oxygen (bacterial, respiratory rates) Indirect Local 
March 28, 2011 2-11 

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

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

Directly and Indirectly, by 316(b) Regulations

Category Direct/Indirect Local/Regional/National 

Ecological energetic demands Indirect Local/Regional 

Ecological nutrient demands Indirect Local/Regional 

Altered algal productivity Direct & Indirect Local/Regional 

Shifted nutrient cycling Indirect & Direct Local/Regional 

 

C. Chemical Effects (anti-foulants, etc.) 

Altered survival/growth/production Indirect & Direct Local 

Altered food web dynamics Indirect Local 

 

D. Altered Flow Regimes (local and system-wide) 

Altered flow velocity Direct & Indirect Local/Regional 

Altered turbulence regime Direct & Indirect Local/Regional 

 

E. Cumulative Impacts (as a concentrated number of facilities) 

May push systems over the edge of nonlinearities in the system Direct/Indirect Local/Regional 

Intensified CWIS effects (as above, Section B.) Direct/Indirect Local/Regional 

Intensified thermal effects (as above, Section B.) Direct/Indirect Local/Regional 

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

pressure on native freshwater species, such as lake whitefish (Coregonus clupeaformi) and yellow perch 

(Perca flavescens), whose populations have seen dramatic declines in recent years (USDOI 2008; 

Wisconsin DNR 2003). Although recovery of these species is greatly affected by fisheries policy (e.g., 

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

harvested at unsustainable levels. 

Overall, EPA believes that I&E mortality is likely to contribute to reduction in the population sizes of 

species targeted by commercial and recreational fishers, particularly for stocks that are undergoing 

rebuilding. Although these reductions may be small in magnitude compared to fishing pressure (Lorda et 

al. 2000), and often difficult to measure due to the low statistical power of fisheries surveys, a reduction 

in mortality rates on overfished populations is likely to increase the rate of stock recovery. Thus, reducing 

I&E mortality may lead to more-rapid stock recovery, a long-term increase in commercial fish catches, 

increased population stability following periods of poor recruitment and, as a consequence of increased 

resource utilization, an increased ability to minimize the invasion of exotic species3

 (Shea and Chesson 

2002; Stachowicz and Byrnes 2006). 

For many fish species, I&E mortality may not lead to measurable reductions in adult populations. These 

losses, however, are likely to reduce the compensatory ability of populations to respond to environmental 

variability, including temperature extremes, heavy predation, disease, or years with low recruitment. 

Additionally, since predation rates are often directly related to the concentration of available prey, I&E 

mortality may lead to indirect population effects, whereby reductions in a prey fish may indirectly result 

in reductions to predator species or increases to species in apparent competition (Holt 1977). 

 

3

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

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

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

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

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

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

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

2.3.2 I&E Mortality Effects on T&E species 

T&E species are species vulnerable to future extinction or at risk of extinction in the near future, 

respectively. Due to low population sizes, I&E mortality from CWISs may represent a substantial portion 

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

recovery time, or hasten the demise of these species. For this reason, the population-level and social 

values of T&E losses are likely to be more important than the absolute number of losses that occur. 

Adverse effects on T&E species due to water withdrawals by CWISs may occur in several ways: 

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

 T&E species may suffer indirect harm if the CWIS substantially alters the food web in which 

these species interact. 

 T&E species may suffer indirect harm if the CWIS substantially alters habitat that is critical to 

their long-term survival. 

Chapter 5 provides detail on CWIS impacts on T&E species. 

2.3.3 Thermal Effects 

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

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

the facilities subject to 316(b) I&E mortality concerns have also been required to address the impact of 

thermal pollution in the discharge-receiving waters (Abt Associates 2010b). 

Thermal pollution has long been recognized as having effects upon the structure and function of 

ecosystems (Abt Associates 2009a). Numerous studies have shown that thermal discharges may 

substantially alter the structure of the aquatic community by modifying photosynthetic (Bulthuis 1987; 

Chuang et al. 2009; Martinez-Arroyo et al. 2000; Poornima et al. 2005), metabolic, and growth rates 

(Leffler 1982), and reducing levels of DO. Thermal pollution may also alter the location and timing of 

fish behavior including spawning (Bartholow et al. 2004), aggregation, and migration (USEPA 2002b), 

and may result in thermal shock-induced mortality for some species (Ash et al. 1974; Deacutis 1978; 

Smythe and Sawyko 2000). Thus, thermal pollution is likely to alter the ecological services provided by 

ecosystems surrounding facilities returning heated cooling water into nearby waterbodies. 

Adverse temperature effects may also be more pronounced in aquatic ecosystems that are already subject 

to other environmental stressors such as high biochemical oxygen demand (BOD) levels, sediment 

contamination, or pathogens. Thermal discharges may have indirect effects on fish and other vertebrate 

populations through increasing pathogen growth and infection rates. Langford (1990) reviewed several 

studies on disease incidence and temperature, and while he found no simple, causal relationship between 

the two, he did note that it was clear that warmer water enhances the growth rates and survival of 

pathogens, and that infection rates tended to be lower in cooler waters. 

The magnitude of thermal effects on ecosystem services is related to facility-specific factors, including 

the volume of the waterbody from which cooling water is withdrawn and returned, other heat loads, the 
March 28, 2011 2-13 

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

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

addition to reducing total I&E mortality, cooling towers reduce thermal pollution. Consequently, the 

installation of closed-system cooling towers could have geographically variable effects on ecosystems, 

ranging from comprehensive changes in community structure and habitat type (Schiel et al. 2004), to 

localized changes in the relative proportion of species adapted to warm and cold water (Millstone 

Environmental Laboratory 2009). Further information on thermal discharges is provided in Appendix 

12.1.1.1B1. 

2.3.4 Chemical Effects 

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

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

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

cleaning cycles. 

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

 to 

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

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

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

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

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

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

facilities in 2007, sorted by mass. These chemicals represent pollutants generated by the operation and 

maintenance of the facility and other location-specific activities. The most common pollutants include: 

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

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

operational concern for power plants. Microbial biofouling on surfaces in cooling water systems can 

accelerate metal corrosion, increase resistance to heat transfer energy, and increase fluid frictional 

resistance (Cloete et al. 1998). Sessile macrofouling-organisms such as algae, insects, hydroids, 

polychaetes, barnacles, mussels and tunicates can colonize intake pipes, bulkheads, and filter screens, and 

may clog pipes and reduce intake flows or filter-screen effectiveness. Further, some of these infestations 

produce larvae, which can colonize downstream equipment including pipelines, valves, and heat 

exchangers. Severe macrofouling-associated problems can include intake flow reduction, increased 

pressure drop across heat exchangers, and equipment breakdown. 

 

4

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

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

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

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

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

annual loadings in 2007. 

Parameter Number of 

facilities 

Total Loading 

(‘000 pounds/yr) 

1 Solids, total dissolved 46 5,416.4 

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

3 Solids, total suspended 619 1,100.6 

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

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

6 Sulfate, total (as SO4) 54 416.2 

7 Chloride (as Cl) 47 403.5 

8 Calcium Chloride 1 175.8 

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

10 Chemical Oxygen Demand (COD) 33 105.6 

11 Oil & grease 274 84.5 

12 Carbon, total organic (TOC) 76 45.1 

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

14 Oil and grease, hexane extraction method 80 42.0 

15 Sulfate (as S) 11 41.1 

16 Iron, total (as Fe) 220 33.9 

17 Fluoride, total (as F) 34 29.9 

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

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

20 Coliform, fecal general 108 21.2 

Source: Discharge Monitoring Report Pollutant Loading Tool (DMR-PLT) 

These anti-fouling and cleaning chemicals potentially pose a risk to organisms downstream of the CWIS 

discharge. Adverse effects to aquatic organisms may include acute and residual effects of biocides used as 

anti-fouling agents in condenser tubes, or from chemicals resulting from corrosion or use in cleaning of 

either stream or cooling cycles (Kelso and Milburn 1979). A typical biofouling procedure is continuous 

low-level chlorination at chronic toxicity levels with an occasional high (“shock”) dose. The use of 

oxidants (chlorine, bromide) can give rise to residuals and/or disinfection byproducts (DBPs) such as 

trihalomethanes, haloacetic acid, bromoform, and others (Taylor 2006). Concentrations of released 

chemicals are variable among facilities, and are a function of treatment dose, CWIS design, rates of 

degradation, and the volume and flushing rate of the receiving water. 

With the exception of chlorination impacts (Taylor 2006), the potential effects of chemicals in power 

plants’ cooling water discharges on local aquatic ecosystems are not well-characterized. In most cases, 

chemical effects are considered, along with thermal and mechanical effects, as a component of the 

cumulative stress of entrainment on organisms. Little information is available on the chronic or low-level 

effects of these discharge chemicals on local ecosystems or in concert with other anthropogenic stressors. 

Review of the effects of chemical treatment and discharge into the environment suggests that direct 

ecotoxicity in discharge plumes is relatively rare beyond the point of discharge or mixing zone near the 

pipe outlet (Poornima et al. 2005; Taylor 2006). However, concentrations of these chemicals may be 

additive to low-level chronic adverse effect with other anthropogenic stressors identified above. 
March 28, 2011 2-15 

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

2.3.5 Effects of Flow Alteration 

The operation of CWISs and discharge returns significantly alter patterns of flow within receiving waters 

both in the immediate area of the CWIS intake and discharge pipe, and in mainstream waterbodies, 

particularly in inland riverine settings. In ecosystems with strongly delineated boundaries (i.e., rivers, 

lakes, enclosed bays, etc.), CWISs may withdraw and subsequently return a substantial proportion of 

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

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

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

facilities changes relatively little, the flow characteristics of the waterbody, including turbulence and 

water velocity, may be significantly altered. This is particularly true in locations with multiple CWISs 

located close to each other. 

Altered flow velocities and turbulence may lead to several changes in the physical environment, including 

sediment deposition (Hoyal et al. 1995), sediment transport (Bennett and Best 1995), and turbidity 

(Sumer et al. 1996), each of which play a role in the physical structuring of ecosystems. Biologically, 

flow velocity is a dominant controlling factor in aquatic ecosystems. Flow has been shown to alter 

feeding rates, settlement and recruitment rates (Abelson and Denny 1997), bioturbation activity (Biles et 

al. 2003), growth rates (Eckman and Duggins 1993), and population dynamics (Sanford et al. 1994). 

In addition to flow rates, turbulence plays an important role in the ecology of small organisms, including 

fish eggs and larvae, phytoplankton, and zooplankton. In many cases, the turbulence of a waterbody 

directly affects the behavior of aquatic organisms, including fish, with respect to swimming speed 

(Lupandin 2005), location preference with a waterbody (Liao 2007), predator-prey interactions (Caparroy 

et al. 1998; MacKenzie and Kiorboe 2000), recruitment rates (MacKenzie 2000; Mullineaux and Garland 

1993), and the metabolic costs of locomotion (Enders et al. 2003). The sum of these effects may result in 

changes to the food web or the location of used habitat, and thereby substantially alter the aquatic 

environment. 

Climate change is predicted to have variable effects on future river discharge in different regions of the 

United States, with some rivers expected to have large increases in flood flows while other basins will 

experience water stress. For example, Palmer et al. (2008) predict that mean annual river discharge is 

expected to increase by about 20 percent in the Potomac and Hudson River basins but to decrease by 

about 20 percent in Oregon's Klamath River and California's Sacramento River. Thus, the adverse effects 

of flow alteration may increase or decrease over longer periods for larger rivers, depending on their 

national location. 

2.4 Community-level or Indirect Effects of CWISs 

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

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

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

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

For example, fish are essential for energy transfer in aquatic food webs (Summers 1989), and for the 

regulation of food web structure. Fish play important roles in nutrient cycling (Wilson et al. 2009) and 

sediment processes, and are known to play key roles in the maintenance of aquatic biodiversity 

(Holmlund and Hammer 1999; Peterson and Lubchenco 1997; Postel and Carpenter 1997; Wilson and 

Carpenter 1999). 
March 28, 2011 2-16 

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

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

monetized (Chapters 3, 6 and 7), the accompanying loss of other aquatic organisms may be poorly 

characterized (e.g., lumped into broad taxa such as “forage fish” or “other”) or simply not reported. In 

addition, I&E mortality on species of lower concern may create unrealized ripples of ecological effect 

within the aquatic community. Species may respond to altered ecological circumstances such as reduced 

predation, altered food concentrations, or slower nutrient recycling, etc. Therefore, the removal of 

selected fish species or considerable biomass by I&E mortality may substantially affect these processes. 

Several examples of ecological services indirectly affected by I&E mortality are described below, 

although others listed in Table 2-4 may be of equal importance for individual ecosystems. 

2.4.1 Altered Community Structure and Patchy Distribution of Species 

The role of some aquatic species may be more critical in shaping the structure and composition of the 

community than that of others. These keystone species are species that have an effect on community 

structure disproportionate to their population (Paine 1966; Paine 1969). Consequently, the loss or 

reduction of keystone species may lead to substantial changes in aquatic food webs, and decrease overall 

ecosystem stability. Thus, the potential for ecosystem impacts resulting from, for example, the loss of an 

important predator fish due to I&E mortality may not be strictly proportional to the number or biomass of 

lost fish or foregone fish production. 

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

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

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

populations they affect are geographically heterogeneous. This can result in a highly localized and patchy 

distribution of aquatic organisms in regional areas. A secondary effect is increased probability of 

colonization and establishment by NIS due to niche space availability caused by a local reduction in the 

density of native organisms (Byrnes et al. 2007; Ovaskainen and Cornell 2006). 

2.4.2 Altered Food Webs 

Sources of mortality, including I&E mortality, may disrupt established predator-prey relationships and the 

niche space available to species through direct pathways (i.e., mortality of the organism) or indirectly 

(i.e., alterations to the food web). The loss of young-of-year (YOY) predators (e.g., striped bass) or 

important forage fish (e.g., menhaden and bay anchovy) is likely to affect trophic relationships and alter 

food webs. These changes may alter the realized species niche and life history traits due to alterations in 

inter- and intra-specific interactions (e.g., predator-prey, competition, mate selection, etc.) (Fortier and 

Harris 1989; Hixon and Jones 2005; Jirotkul 1999). These alterations in trophic interactions and food 

webs, combined with other CWIS-related impacts such as thermal pollution (Section 2.2.3) or flow 

alteration (Section 2.3.5), may lead to rapid changes in life history strategies as a consequence of 

facultative (Ball and Baker 1996) or evolutionary changes (Hairston et al. 2005; Reznick and Endler 

1982). 

2.4.3 Reduced Taxa and Genetic Diversity 

I&E mortality may lead to reductions in local community biodiversity (due to destruction of selected 

species) or in a loss of genetic diversity in individual fish populations. I&E mortality represents a novel 

selective pressure on early life stages that may reduce the genetic diversity of resident fish and prevent the 

recovery of depleted stocks (Stockwell et al. 2003; Swain et al. 2007; Walsh et al. 2006). Since many 
March 28, 2011 2-17 

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

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

mortality could alter the seasonal timing and movement (i.e., phenology) of overall fish populations, 

which could have ramifications for predator species. 

2.4.4 Nutrient Cycling Effects 

I&E mortality impacts may alter the pace of nutrient cycling, and energy transfer through food webs. Fish 

species have been shown to have substantial effects on nitrogen, phosphorous, and carbon cycling due to 

storage effects (i.e., large quantities of nutrients are found within fish biomass) and translocation effects 

(i.e., fish migrate, moving large quantities of nutrients to new ecosystems) (Kitchell et al. 1979; Vanni et 

al. 1997). These alterations in nutrient cycling could lead to redirection of nutrient flows to other 

components of the ecosystem including water column phytoplankton, benthic macroalgae and attached 

epiphytes, with subsequent changes to the condition of critical ecosystem habitats, such as submerged 

aquatic vegetation. Juvenile (age-0) Atlantic menhaden (Brevoortia tyrannus) are capable of significantly 

grazing down plankton concentrations in Chesapeake Bay, leading to more-rapid regeneration of nutrients 

and enhanced primary production. Removal of the age-0 menhaden by I&E mortality would lead to 

reduced grazing and turnover of nutrients and increased algal density in the water column (Gottlieb 1998). 

The amount of nitrogen and phosphorus regenerated in facility discharge water due to nutrient recycling 

of I&E mortality biota might also lead to areas of localized nutrient enrichment near outfalls (Abt 

Associates 2010a). Additionally, the preferential removal of upper water column species by I&E 

mortality could increase energy flow to benthic organisms, and thereby increase the relative importance 

of detritivores in bottom communities. 

2.4.5 Reduced Ecological Resistance 

The effect of long-term or chronic I&E mortality may lead to a decrease in ecosystem resistance and 

resilience (i.e., ability to resist and recover from disturbance including invasive species) (Folke et al. 

2004; Gunderson 2000). That is, I&E mortality is likely to reduce the ability of ecosystems to withstand 

and recover from adverse environmental impacts, whether those impacts are due to anthropogenic effects 

or natural variability. 

2.5 Cumulative Impacts of Multiple Facilities 

Cumulative effects of CWISs are likely to occur if multiple facilities are located in close proximity such 

that they impinge or entrain aquatic organisms within the same source waterbody, watershed system, or 

along a migratory pathway of a specific species (e.g., striped bass in the Hudson River) (USEPA 2004c). 

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

discussed above (Section 2.2). 

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

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

(approximated by CWIS latitude and longitude) indicates that facilities in inland settings are clustered 

around rivers to a greater extent than marine and estuarine facilities (see Figure 2-1). 

2.5.1 Clustering of Facilities and CWISs on Major Rivers 

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

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

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

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

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

River 

Avg. Annual* 

Flow (MGD) Facilities 

Cumulative 

DIF (MGD) 

DIF as % Avg. 

Annual Flow 

Cumulative 

AIF (MGD) 

AIF as % Avg. 

Annual Flow 

Mississippi 383,266 57 22,436 5.9 13,170 3.4 

Ohio 181,615 47 19,315 10.6 13,384 7.4 

Missouri 49,249 23 10,718 21.8 6,598 13.4 

Illinois 8,079 11 6,259 77.5 1,605 19.9 

Delaware 7,562 11 3,585 47.4 1,485 19.6 

* Source: (USGS 1990) 

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

length, with 27 facilities located in Louisiana upstream of the Mississippi River delta. Using facility 

intake coordinates as location markers, the relative distances between facilities were estimated (Abt 

Associates 2010b). In upper Louisiana, facilities are typically separated by tens of miles; inter-facility 

distance decreases downstream of Baton Rouge, LA. Several locations along the Mississippi River have 

clusters of facilities: 

 Between Ascension and St. James Parishes, a 13-mile span of the river hosts six manufacturing 

facilities, three of which have intakes located within the same mile. These facilities have a 

combined DIF of nearly 270 MGD. 

 Fifteen miles downstream, near Garyville, LA, there is a cluster of three facilities within six miles 

of the river stretch. 

 Seven miles further downstream near Laplace, LA, six facilities occur on a six-mile stretch of the 

river. Four of these facilities, with a combined DIF exceeding 5 BGD (three generators and one 

manufacturer), are located within a 1.7 mile section of river. 

 Further downstream in Chalmette, LA (just east of New Orleans), three manufacturers, capable of 

withdrawing up to 457 MGD, are clustered within four river miles. 

Therefore, the potential for cumulative impacts is high, and investigating ecosystem effects by 

extrapolating results on a per facility basis may likely underestimate the true effects. 

2.5.2 Implications of Clustered Facilities for Cumulative Impacts 

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

combined intake flows, and the potential for other impacts such as thermal discharges. It should also be 

noted that power generation demand and cooling intake water volume is typically at its annual maximum 

during mid-late summer, which is also a period of seasonal low flows and highest in-stream temperatures. 

The effect of cumulative impacts may be greater in inland or Great Lakes waters due to the following 

factors: 

 The majority of national AIF is associated with freshwater CWISs. 

 Freshwater plants use a greater relative volume of available fish habitat than marine or estuarine 

counterparts. 

 Seasonal variation in power demand and river flow may increase entrainment potential during 

low-flow periods of the year (NETL 2009). Although low flows are traditionally in late summer 
March 28, 2011 2-19 

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

to early fall, drought conditions and manipulations of water levels may lead to low flow during 

other periods. This may be locally significant if periods of low flow overlap with seasonal 

concentrations of eggs, developing YOY, and migrating juveniles. 

 Freshwater facilities are more likely to be clustered along a waterbody, and pose a greater risk of 

cumulative impacts. This is exacerbated by the presence of numerous impoundments associated 

with navigational lock and dam structures located on larger river (e.g., Mississippi, Missouri, 

Ohio, etc). These impoundments result in slow or slack water conditions with a lower effective 

volume than free-flowing reaches or periods of higher flow. 

2.6 Case Studies of Facility I&E Mortality Impacts 

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

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

and to what extent these impacts and I&E mortality are realized, how site-specific factors come into play, 

the effects of cumulative impacts, and what has been learned with regard to community-level effects. 

Case studies provide useful, detailed information for evaluating I&E mortality and major stressors in the 

context of a specific waterbody or region. 

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

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

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

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

 Delaware Estuary Watershed 

 Ohio River Watershed 

 Tampa Bay Watershed 

 San Francisco Bay/Delta Estuary 

 Brayton Point Facility 

 Seabrook and Pilgrim Facilities 

 J.R. Whiting Facility 

 Monroe Facility 

These regional case studies provide a set of information describing the variety of CWIS impacts under 

marine, coastal, and riverine environmental settings. The following sections present three additional case 

studies to provide examples of facility-specific CWIS impacts in settings including freshwater coastal 

(Bay Shore, Oregon, OH), estuarine (Indian Point, Buchanan, NY), and estuarine-coastal (Indian River, 

Sussex County, DE) environments. These brief case studies also illustrate the quantitative levels of I&E 

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

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

examples. 

2.6.1 Bay Shore Power Station 

The Bay Shore power station is a 631 megawatt (MW) facility located on the south shore of Lake Erie 

near the confluence of the Maumee River and Maumee Bay, OH. Cooling water for the four coal-fired 
March 28, 2011 2-20 

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

steam-electric units is withdrawn from Maumee River/Maumee Bay via an open intake channel of 

approximately 3,700 ft in length, and enters the plant via a shoreline surface CWIS. Approximately 749 

million gallons per day (MGD) is withdrawn, including once-through cooling water and sluice water used 

for transporting bottom ash from the boilers to ash settling ponds (OEPA 2010). Major environmental 

concerns for the facility include I&E mortality and thermal impacts. 

In addition to I&E mortality effects, concerns have also been raised regarding the size and impact of the 

thermal discharge plume—a focus of concern for local residents and commercial fishermen. Depending 

on wind patterns and hydrological factors, the thermal plume extends to the south shore of Maumee Bay 

(over 1 mile from the facility). The Ohio Environmental Protection Agency (OEPA) assessed the results 

from a 2002 thermal mixing zone study, and concluded that the thermal discharge exceeded Ohio water 

quality standards for temperature within the thermal plume (>85o

F in Maumee Bay), but that the impacts 

on aquatic life and designated uses in Maumee River/Bay did not justify reduction of the thermal mixing 

zone. However, it did find that the thermal activity could restrict recreational activities in certain areas of 

the plant and required the plant owners to conduct a two-year study of the benthic community within the 

mixing zone (OEPA 2010). 

2.6.2 Indian Point Nuclear Power Plant 

The Indian Point nuclear power plant is a 2,045 MW facility located in Buchanan, Westchester County, 

New York, on the east shoreline of the Hudson River. Cooling water (up to 2,500 MGD) for the two 

nuclear-fired steam-electric units (Units 2 and 3) is withdrawn from the estuarine portion of the Hudson 

River through three intake structures on the shoreline (NYSDEC 2003a). The heated non-contact cooling 

water is discharged through sub-surface diffuser ports in a discharge canal located downstream of the 

intake structures. 

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

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

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

I&E mortality impacts. Accordingly, the Hudson River aquatic community has been sampled and studied 

over many decades, with detailed investigation starting in the 1970s. 

Results suggest that I&E mortality impacts to the local and transient anadramous fish species are 

substantial. For example, studies of fish entrainment in 1980 predicted fish class reductions ranging from 

6 to 79 percent, depending on fish species (Boreman and Goodyear 1988). Subsequent sampling work 

predicted year-class reductions due to I&E mortality of 20 percent for striped bass, 25 percent for bay 

anchovy, and 43 percent for Atlantic tomcod. The Final Environmental Impact Statement (FEIS) 

prepared by the New York State Department of Environmental Conservation (NYSDEC) concluded these 

Bay Shore Power Station I&E Mortality Losses: Medium-sized Plant with Large-Scale Impacts 

A comprehensive demonstration study, conducted in 2005-2006, estimated annual impingement at 

greater than 46 million fish per year, the majority of which were forage fish species—emerald shiner 

and gizzard shad. Annual estimates for entrainment were equally impressive—209 million fish eggs, 

2,247 million fish larvae, and 14 million juvenile fish (OEPA 2010). As noted on the NDPES fact 

sheet, “It is likely that Bay Shore Station impinges and entrains more fish than all other power 

stations in Ohio combined.” Notably, the plant does not currently employ any technologies to 

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

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

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

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

The FEIS considered the role of other major environmental factors currently or historically present in the 

Hudson River. These factors have the capacity to affect fish populations either positively (enhancements) 

or negatively (stressors). Relevant factors include, but are not limited to: improvements to water quality 

due to upgrades to sewage treatment plants, invasions by exotic species (e.g., zebra mussel), chemical 

contamination by toxins (e.g., PCBs and heavy metals), global climate shifts such as increases in annual 

mean temperatures and higher frequencies of extreme weather events (e.g., the El Nino-Southern 

Oscillation), and stricter management of individual species stocks such as striped bass (USEPA 2004a). 

Recently (April 2010), the NYSDEC denied a request by Indian Point for a CWA Section 401Water 

Quality Certificate. The CWA requires that, prior to any federal agency issuing a license or permit for a 

particular project (in this case, the approval of the State Discharges Permit Elimination System [SPDES] 

permit), it must certify that the project meets State water quality standards. The NYSDEC denial letter 

cited, among other concerns, continuing concerns over I&E mortality including potential impacts to two 

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

(under consideration for endangered species status). 

2.6.3 Indian River Power Plant 

The Indian River Generating Station (IRGS) is a 784 MW facility located in Sussex County, Delaware, 

on the south shore of the Indian River. Cooling water for three of the IRGS’s four coal-fired steamelectric units is withdrawn upstream from the freshwater portion of Indian River via an intake canal at a 

maximum rate of 411 MGD, or 21 times the average flow rate of Indian River. Heated return water is 

discharged via a canal into the upper reaches of Island Creek, a small tributary of Indian River, entering at 

Ward Cove. Island Creek and Ward Cove are part of a large estuarine stretch (approximately 150 acres) 

of Indian River that provides important fish and crab habitat. Its lower salinity and location in the estuary 

make it attractive to important species such as bay anchovy, spot, menhaden larvae, and young blue crabs. 

Indian Point Final Environmental Impact Statement (FEIS) details cumulative effects: 

The FEIS estimated, from samples collected between 1981 and 1987 for three facilities (Indian Point, 

Roseton, Bowline Point), that the average annual entrainment losses from these plants included 16.9 

million American shad, 303.4 million striped bass, 409.6 million bay anchovy, 468 million white 

perch, and 826.2 million river herring (NYSDEC 2003b). The loss of such large numbers of forage 

fish species and the potential impact on higher level piscivores is of high concern. The FEIS also 

viewed the overall effect of the CWIS impacts on the aquatic community as analogous to habitat 

degradation rather than overfishing. This judgment was based on evidence that the entire aquatic 

community was affected rather than only specimens of higher trophic level species. 

Indian River Power Plant has impact on important local species: 

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

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

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

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

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

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

also investigated. Based upon monitoring data collected from 1998-1999, the 316(a) report assessed the 

effects of elevated water temperatures on ecosystem communities with a focus on eight important fish 

species: bay anchovy, menhaden, winter and summer flounder, croaker, spot, striped bass, and weakfish. 

This report determined that juvenile and adult target species, although able to avoid areas of high water 

temperature, were not permanently restricted from most stretches of the Indian River, nor did they suffer 

loss of habitat services associated with these segments. The study concluded an overall condition of no 

adverse effect, or no appreciable harm, on the fish and shellfish populations in the Indian River and 

Delaware Bay (Entrix 2001). 

Despite the overall conclusion of no adverse effect, there were documented localized thermal impacts of 

consequence. For example, during warmer months, the thermal discharge reached potential adverse levels 

in Island Creek, often extending downstream to Ware Cove (Entrix 2001). The mortality associated with 

sub-adult stages of fish and crabs and the avoidance of the area by sub-adult and adult fish were 

substantial issues. In addition to direct thermal impacts to biota, temperature-related reductions in DO 

were observable (mean reduction = 0.6 mg/l) in the discharge canal. These reductions contributed to the 

amplitude of the day-night (diel) cycle of DO concentrations, already widely fluctuating due to 

cumulative effects of eutrophication in the river (Bason 2008). 

2.7 Conclusions 

Considerable information is available on the direct effects of CWISs and I&E mortality (Chapter 3) on 

commercially (Chapter 6) and recreationally important (Chapter 7) species derived from the accumulated 

data from facility-specific basis 316(b) studies and investigations. This has allowed EPA to monetize the 

potential environmental benefits that would arise as reduction in water withdrawals occur based of future 

316(b) regulations. 

However, as demonstrated in this section, there is much less information and high uncertainty regarding 

the magnitude and importance of indirect and/or cumulative impacts of CWISs, particularly effects on 

lower trophic organisms or ecosystem functions. This condition is due to the limitations of 316(b) 

sampling programs, as well as the failure of permitting process to consider the additive or cumulative 

effects of other major anthropogenic stressors. While EPA can identify and hypothesize regarding the 

direction and relative importance of impacts of CWISs on the totality of the aquatic ecosystem (i.e., not 

just focused on selected higher trophic level predator species and common prey), EPA is currently unable 

to connect these effects with quantifiable environmental benefits. Thus, it is highly likely that the total 

environmental and monetary impacts of CWISs are significantly underestimated, and that characterization 

of the fuller spectrum of benefits arising from reducing or eliminating I&E mortality will await future, 

targeted research efforts.
March 28, 2011 3-1 

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

3 Assessment of Impingement and Entrainment Mortality 

3.1 Introduction 

This chapter discusses the methods EPA used to convert results from impingement and entrainment 

mortality (I&E mortality) sampling studies into metrics suitable as inputs for EPA’s Section 316(b) 

benefits analysis.5

 Section 3.2 provides a brief overview of impingement and entrainment (I&E) loss 

metrics, and outlines how they were used in benefits analysis. Section 3.3 presents I&E mortality losses, 

by region, under baseline conditions, and the reductions in these losses under alternative regulatory 

options. Section 3.4 discusses limitations and uncertainties in the I&E mortality analysis. 

EPA’s I&E mortality assessment methods are discussed in detail in Chapter A-1 of the Regional Benefits 

Analysis for the Final Section 316(b) Phase III Existing Facilities Rule (Regional Benefits Analysis) 

(USEPA 2006b). Changes in methodology since EPA’s Phase III analysis include: (1) the addition of new 

I&E mortality data for several California facilities, (2) engineering reductions for power generators were 

estimated for sample facilities that received the detailed questionnaire rather than for all in-scope 

generators, and (3) changes in the proportionate reduction in I&E mortality under new regulatory options 

were estimated. Other modifications are identified in relevant portions of Section 3.2. 

3.2 Methods 

3.2.1 Objectives of I&E Mortality Analysis 

EPA’s evaluation of I&E mortality data had four main objectives: 

 To develop regional and national estimates of the magnitude of I&E mortality 

 To standardize I&E mortality rates using common biological metrics that allow comparison 

across species, years, facilities, and geographical regions 

 To provide I&E mortality metrics suitable for use in national economic benefits analysis 

 To estimate changes in metrics as a result of estimated reductions in I&E mortality under 

alternative regulatory options. 

EPA’s use of these methods for national rulemaking does not imply that these methods are the best or 

most suitable for studies of single facilities. In many cases, site-specific details on local fish populations 

and waterbody conditions may make other assessment approaches, such as population or ecosystem 

modeling, possible. 

 

5

 For the purposes of its national analysis, EPA assumed 100 percent impingement mortality and 100 percent entrainment 

mortality. This assumption is discussed at length in Chapter A7 of the Regional Analysis Document for the Final Section 

316(b) Existing Facilities Rule (USEPA 2004b). Briefly, EPA assessed 37 entrainment survival studies and found them 

variable, unpredictable, unreliable, and not defensible. As such, these studies support an assumption of 0 percent survival for

entrained organisms in benefits assessments. 
March 28, 2011 3-2 

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

3.2.2 I&E Mortality Loss Metrics 

Three loss metrics were derived from facility I&E mortality monitoring data available to EPA: (1) age-1 

equivalents, (2) forgone fishery yield, and (3) production forgone. These metrics are described briefly 

below. Equations used to calculate metrics and other details are provided in Chapter A-1 of EPA’s 

Regional Benefits Analysis (USEPA 2006b). 

3.2.2.1 Age-1 Equivalents 

The Equivalent Adult Model (EAM) is a method for converting organisms of different ages (life stages) 

into an equivalent number of individuals in any single age (Goodyear 1978; Horst 1975). For its 316(b) 

analyses, EPA standardized all I&E mortality losses into equivalent numbers of 1-year-old fish, a value 

termed age-1 equivalents (A1Es). This conversion allows losses to be compared among species, years, 

facilities, and regions. 

To conduct EAM calculations requires a life history schedule, for each species, incorporating age-specific 

mortality rates. Using these species-specific survival tables, a conversion rate between all life history 

stages and age 1 is calculated. For life history stages younger than 1 year of age, the conversion rate is 

calculated as the product of all stage-specific survival rates between the stage at which I&E mortality 

occurs and age 1. Consequently, the loss of an individual younger than age 1 results in a conversion rate 

less than 1. For individuals older than 1 year, the conversion rate is calculated as the quotient of all stagespecific survival rates between the stage at which I&E mortality occurs and age 1. Consequently, the loss 

of an individual older than age 1 results in a conversion rate greater than 1. 

Additional details on the EAM calculation are provided in Chapter A-1 of EPA’s Regional Benefits 

Analysis (USEPA 2006b). For the results presented in this chapter, the treatment of early life stages in this 

calculation considers all larval life stages reported in the original I&E mortality studies. 

3.2.2.2 Forgone Fishery Yield of Commercial and Recreational Species 

Fishery yield is a measure of the biomass harvested from a cohort of fish.6 EPA expressed I&E mortality 

of harvested species in terms of forgone (lost) fishery yield. To convert losses to forgone fishery yield, 

EPA used the Thompson-Bell equilibrium yield model (Ricker 1975). EPA’s application of the 

Thompson-Bell model assumed that 1) I&E mortality losses reduce the future yield of harvested adults, 

and 2) reductions in I&E mortality rates will lead to an increase in harvested biomass. 

The Thompson-Bell model is based on the principles used to estimate the expected yield in any harvested 

fish population (Hilborn and Walters 1992; Quinn and Deriso 1999). The general procedure involves 

multiplying age-specific harvest rates by age-specific weights to calculate an age-specific expected yield. 

The lifetime expected yield for a cohort of fish is the sum of all age-specific expected yields. Details of 

these calculations are provided in Chapter A-1 of EPA’s Regional Benefits Analysis (USEPA 2006b). 

3.2.2.3 Production Forgone for All Species 

Production forgone is an estimate of the biomass that would have been produced had individuals not been 

impinged or entrained (Rago 1984). It is calculated for all forage species from species- and age-specific 

growth rates and survival probabilities. This forgone biomass represents a decrease in prey availability for 

predator species, and is calculated because I&E mortality losses for forage species are not included in the 

forgone fishery yield calculations. Additional details regarding the calculation of production forgone are 

provided in Chapter A-1 of EPA’s Regional Benefits Analysis (USEPA 2006b). 

 

6

 A cohort of fish refers to fish produced in the same year, also referred to as a year-class of fish. 
March 28, 2011 3-3 

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

3.2.3 Valuation Approach 

EPA’s benefits analysis focused on increased commercial and recreational fishery harvests estimated 

from projected reductions in I&E mortality losses. For consistency with reported harvest data, 

commercial harvest is reported in pounds and recreational harvest is reported in numbers of fish. To 

project changes in fishery harvests, EPA integrated two components of fishery yield that change as a 

consequence of I&E mortality: direct contributions of commercially and recreationally harvested species 

(hereafter fishery species), and indirect contributions of forage species consumed by fishery species 

(Figure 3-1). The direct contribution of fishery species to yield (left side of Figure 3-1) is calculated by 

converting A1E losses to forgone yield as described in Section 3.2.2. The contribution of forage species 

to fishery yield is measured as a biotic transfer of mass through the food web to fishery species that are 

subsequently harvested (right side of Figure 3-1). EPA used a simple trophic transfer model for this 

purpose (discussed in Chapter A-1 of EPA’s Regional Benefits Analysis (USEPA 2006b), assuming a 

trophic transfer efficiency of 0.10 (Pauly and Christensen 1995).7

 Trophic transfer efficiency represents 

the fraction of forage species biomass incorporated into predator (fishery) species biomass. EPA 

estimated total changes to commercial and recreational harvest yield as the sum of the contributions of 

fishery and forage species. For benefits analysis, total yield was separated into commercial and 

recreational fractions based on the proportion of harvest occurring within each type of fishery, and 

benefits were calculated for harvestable adult fish. Details of the commercial and recreational fishing 

benefits analysis are provided in Chapters 6 and 7 of this report, respectively. 

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

EPA’s approach to estimating changes in fish harvest assumed that I&E mortality losses result in a 

reduction in the number of harvestable adults, and that I&E mortality reductions result in increases to 

future fish harvests. This approach estimates incremental fishery yield forgone because of I&E mortality 

and does not require knowledge of population size or total yield of a fishery. 

EPA’s forgone fishery yield analysis requires species- and stage-specific schedules of natural mortality 

(M), fishing mortality (F), and weight-at-age. The yield model assumes that these key parameters (F, M, 

and weight-at-age) are independent of I&E mortality rates for all species. EPA recognizes that this 

assumption does not fully reflect the dynamic nature of fish populations. However, by conducting benefits 

analysis using estimates of foregone yield, EPA was able to use a simple and direct measure of the 

potential economic value associated with each I&E-related death. EPA believes that this approach was 

warranted given: (1) the scope and objectives of its analysis of harvested species, (2) data availability, and 

(3) difficulties in distinguishing the causes of population changes. Each of these factors is discussed 

below. 

3.2.4.1 Scope and Objectives of EPA’s Analysis of Harvested Species 

EPA’s overall objective was to develop regional- and national-scale estimates of the magnitude of I&E 

mortality at hundreds of facilities that are in the scope of the proposed rule nationwide. As a consequence 

of the large geographic scope and multiple ecosystems involved, EPA modeled fishery yield using a 

relatively simplified approach to estimate the vulnerability of dozens of species to I&E mortality on a 

 

7

 EPA notes that its model of trophic transfer is a very simple and idealized representation of trophic dynamics; it is not 

intended to capture the details of trophic transfer in actual aquatic ecosystems. In reality, food webs and trophic dynamics 

are much more complex than EPA’s simple model implies, and include details that are specific to each particular aquatic 

ecosystem. This complexity was beyond the scope of EPA’s analysis and the available data. 
March 28, 2011 3-4 

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

national scale. Although sufficient data may exist to model the effects of I&E mortality on population and 

community-level impacts, sufficient data do not exist at the national scale to make such studies feasible. 

Figure 3-1: General Approach Used to Evaluate I&E Mortality Losses as Forgone Fishery 

Yield 

3.2.4.2 Data Availability and Uncertainties Related to Modeling Fish Harvest 

Forgone fishery yield and production forgone models used by EPA required age-specific life history data 

for all species analyzed. EPA acknowledges that many fish population models are available, and that 

these models may produce more accurate population-level impacts of I&E mortality. EPA did not pursue 

the development of species-specific population models for several reasons: 

 Constructing population models requires a large set of parameters and numerous assumptions 

about the nature of stock dynamics for each species, including current stock size, stockI&E Mortality

Losses 

Convert to

Age-1

Equivalents

Convert to

Production

Forgone

Convert to

Forgone Fishery

Yield

Convert to

Forgone Fishery

Yield

Total

Forgone Fishery

Yield

Commercial

Harvest

(pounds)

Recreational

Harvest

(# of fish)

Fishery

Species 

Forage

Species

Trophic

Transfer

Sum

Monetize

(Chapter 6) 

Monetize

(Chapter 7) 

Commercial

Fraction

Recreational

Fraction
March 28, 2011 3-5 

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

recruitment relationships, changes to growth and mortality rates as a function of stock size, and 

the separation of certain species into geographically based stock units. Because of these 

limitations, fewer than 40 percent of U.S.-managed commercially harvested fish stocks have been 

fully assessed (NMFS 2009; NMFS 2010b). As such, the information necessary to build morecomplex population models is available only for a subset of harvested species, which represent a 

minor fraction of I&E mortality. 

 Numerous difficulties exist in the definition of the size and spatial extent of fish stocks. As a 

result, it is often unclear how I&E mortality losses at particular cooling water intake structures 

(CWISs) can be related to specific stocks at a regional scale. For example, juvenile Atlantic 

menhaden (Brevoortia tryannus) found in Delaware Bay recruit from both local and long 

distances (Light and Able 2003). As a result, estimating the effects of local I&E mortality on 

recruitment rates would not be sufficient to understand the stock-recruitment relationship for 

Delaware Bay menhaden. 

Consequently, due to issues of data availability and difficulties estimating the effects of localized I&E 

mortality on regional-scale fish stocks, EPA determined that the construction of population models for all 

species subject to I&E mortality was not feasible. The level of uncertainty that would accompany the 

construction of such models (if constructing them were even possible) would be difficult to defend with 

available data at both the national and population level for many species. 

3.2.4.3 Difficulties Distinguishing Causes of Population Changes 

It is fundamentally difficult to demonstrate a causal relationship between a single stressor and changes in 

fish population sizes. Fish populations are affected by multiple nonlinear stressors and are constantly in 

flux. As such, determining whether changes to fish populations are the consequence of an identifiable 

stressor due to natural fluctuation around an equilibrium stock size is difficult. Fish recruitment is a 

multidimensional process, and identifying and distinguishing the causes of variance in fish recruitment 

remains a fundamental problem in fisheries science, stock management, and impact assessment (Boreman 

2000; Hilborn and Walters 1992; Quinn and Deriso 1999). Consequently, resolving issues of population 

fluctuation was beyond the scope and objectives of EPA’s Section 316(b) benefits analysis. 

3.2.5 Extrapolation of I&E Mortality to Develop Regional Estimates 

EPA examined I&E mortality losses and the economic benefits of reducing these losses at a regional 

scale. Estimated benefits were then aggregated across all regions to produce a national benefits estimate. 

Regions were based on regions used by fisheries management agencies such as the National Marine 

Fisheries Service (NMFS). The geographical scope of all regions is described in Chapter 1 (Section 1.2). 

To obtain regional I&E mortality estimates, EPA extrapolated losses observed at 97 facilities with I&E 

mortality data (hereafter model facilities) to all in-scope facilities within the same region. Extrapolation of 

I&E mortality rates was necessary because only a subset of all in-scope facilities have conducted I&E 

mortality studies. To allow extrapolation, EPA assumed that all facilities, regardless of size, have similar 

I&E mortality rates after normalization by flow. I&E mortality data were extrapolated on the basis of 

operational flow, in millions of gallons per day (MGD), where MGD is the average operational flow over 

the period 1996-1998 as reported by facilities in response to EPA’s Section 316(b) Detailed 

Questionnaire and Short Technical Questionnaire. Operational flow at all facilities was scaled using a 

multiplicative factor that reflected the effectiveness of in-place technologies used to reduce I&E 

mortality. During the extrapolation procedure, EPA also applied weighting factors to in-scope facilities 
March 28, 2011 3-6 

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

based on questionnaire results. Weighting factors for the current analysis were based on results of the 

Detailed Questionnaire. Additional details of EPA’s extrapolation methods are provided in Appendix A. 

The assumption that I&E mortality is proportional to flow is consistent with other published I&E 

mortality studies and models. Power plants on the Great Lakes exhibit an increasing relationship (on a 

log-log scale) between plant size (measured as electrical output) and I&E mortality rates (Kelso and 

Milburn 1979), and Goodyear (1978) predicted entrainment on the basis of the ratio of cooling water flow 

to source water flow. Additionally, the Spawning and Nursery Area of Consequence (SNAC) model, used 

as a screening tool for assessing potential I&E mortality impacts at Chesapeake Bay facilities, assumes 

that entrainment is proportional to cooling water withdrawal rates (Polgar et al. 1979). 

EPA recognizes that there may be substantial variability in actual I&E mortality losses per MGD resulting 

from a variety of time- and facility-specific features, such as sampling date, location and type of intake 

structure, as well as from ecological features that affect the abundance and species composition of fish in 

the vicinity of each facility. Consequently, EPA’s extrapolation procedure relies heavily on the 

assumption that I&E mortality rates recorded at model facilities are representative of I&E mortality rates 

at other facilities in the region. Although this assumption may not be met in some cases, limiting the 

extrapolation procedure within regions reduces the likelihood that model facilities are unrepresentative. 

EPA believes that its method of extrapolation makes the best use of a limited amount of empirical data, 

and is the only feasible approach for developing a national estimate of I&E mortality, and the associated 

benefits of I&E mortality reduction. While acknowledging that extrapolation introduces uncertainty into 

I&E mortality estimates, EPA has not identified information suggesting a systematic bias in regional loss 

estimates based upon extrapolation. 

3.3 I&E Mortality Losses By Region 

3.3.1 California Region 

Estimated baseline I&E mortality, and estimated reductions to I&E mortality under the three regulatory 

options are presented in Table 3-1 and Table 3-2. Estimated total baseline I&E mortality losses in the 

California region are 36.83 million A1Es per year, of which 17.56 million (47 percent) are forage fish. 

Approximately 5.59 percent of total baseline A1E losses are assigned a direct use value from recreational 

or commercial fishing (Table 3-1). Table C-1of Appendix C presents species-specific data on 

impingement and entrainment losses under the baseline conditions and estimated reductions under all 

options. Among commercially and recreationally-harvested species, the greatest losses occur in crabs, 

rockfishes, and sea basses (Appendix Table C-1). 

The majority of I&E mortality in the California region occur due to entrainment (Appendix Table C-1). 

Because Option 1 does not reduce entrainment losses in the majority of facilities, it reduces baseline I&E 

mortality of A1E by only 1.9 percent (Table 3-1). Conversely, by requiring the installation of closed-cycle 

cooling towers, which effectively reduce entrainment mortality, Options 2 and 3 reduce A1E losses by 

85.5 and 89.4 percent, respectively, providing over 40 times the reduction in A1E losses (Table 3-1). 
March 28, 2011 3-7 

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

Table 3-1: Summary of Baseline I&E Mortality Losses at All In-scope Facilities 

(Manufacturing and Generating) in California, and Reductions Under Option 

Scenarios 

IM&EM Loss Metric (per year) Option 1 Option 2 Option 3

All Species (million A1E) 36.83 0.69 31.50 32.92

Forage Species (million A1E) 17.56 0.18 14.99 15.67

Commercial & Recreational Species (million A1E) 19.28 0.52 16.51 17.25

Commercial & Recreational Harvest (million fish) 2.06 0.06 1.76 1.84

A1E Losses with Direct Use Value (%) 5.59 7.96 5.60 5.60

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for 

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Production foregone due to baseline I&E mortality is estimated to be 14.05 million pounds of fish, 

leading to a decrease in fishery yield of more than 3.28 million pounds per year (Table 3-2). Option 1 is 

estimated to result in increased fishery yields of 0.02 million pounds per year. Under Options 2 and 3, 

however, estimated increases to fishery yields are more than 100 times greater, at 2.80 and 2.93 million 

pounds per year, respectively (Table 3-2). 

Table 3-2: Baseline Losses in Fishery Yield, Catch, and Production 

Forgone as a Consequence of I&E Mortality at All In-scope Facilities 

(Manufacturing and Generating) in California, and Reductions Under 

Option Scenarios 

IM&E Loss Metric (million per year) Option 1 Option 2 Option 3

Foregone Fishery Yield (lbs) 3.28 0.02 2.80 2.93

Foregone Commercial Catch (lbs) 1.38 <0.01 1.18 1.23

Foregone Recreational Catch (fish) 1.02 0.04 0.88 0.92

Production Foregone (lbs) 14.05 0.10 11.99 12.54

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I 

Everywhere and E for Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Raw numbers of I&E mortality losses in California can be found in Appendix Table C-2. 

3.3.2 North Atlantic Region 

Estimated baseline I&E mortality, and estimated reductions to I&E mortality under the three regulatory 

options are presented in Table 3-3 and Table 3-4. Estimated total baseline I&E mortality losses in the 

North Atlantic region are 60.00 million A1Es per year, 78 percent of which are forage fish. 

Approximately 2.06 percent of total baseline A1E losses are assigned a direct use value from recreational 

or commercial fishing (Table 3-3). Table C-3 of Appendix C presents species-specific data on 

impingement and entrainment losses under the baseline conditions and estimated reductions under all 

options. Briefly, the vast majority (99 percent) of all A1E losses in the North Atlantic occur as a 

consequence of entrainment mortality (Appendix Table C-3). Notably, the combined I&E mortality of 

winter flounder, cunner, and sculpins account for 97 percent of all I&E mortality of commercially and 

recreationally-harvested species. 
March 28, 2011 3-8 

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

Because Option 1 does not reduce entrainment losses, it reduces baseline I&E mortality A1E losses by 

less than 1 percent (Table 3-3). Conversely, by requiring the installation of closed-cycle cooling towers, 

which effectively reduce entrainment mortality, Options 2 and 3 reduce A1E losses by 81.7 and 85.7 

percent, respectively, providing more than 100 times the benefits of Option 1 by A1E (Table 3-3). 

Table 3-3: Baseline I&E Mortality Losses and I&E Mortality Reductions at All Inscope Facilities (Manufacturing and Generating) in the North Atlantic, and 

Reductions Under Option Scenarios 

IM&EM Loss Metric (per year) Option 1 Option 2 Option 3

All Species (million A1E) 60.00 0.43 49.02 51.40

Forage Species (million A1E) 47.02 0.38 38.42 40.29

Commercial & Recreational Species (million A1E) 12.98 0.06 10.60 11.11

Commercial & Recreational Harvest (million fish) 1.23 <0.01 1.01 1.06

A1E Losses with Direct Use Value (%) 2.06 1.52 2.06 2.06

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for 

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Production foregone due to baseline I&E mortality is estimated to be 26.99 million pounds of fish, 

leading to a decrease in fishery yield of 1.02 million pounds per year (Table 3-4). Option 1 is estimated to 

result in increased fishery yields of less than 0.01 million pounds per year. Under Options 2 and 3, 

however, estimated increases to fishery yields are more than 100 times greater, at 0.83 and 0.87 million 

pounds per year, respectively (Table 3-4). 

Table 3-4: Baseline Losses in Fishery Yield, Catch, and Production 

Forgone as a Consequence of I&E Mortality at All In-scope Facilities 

(Manufacturing and Generating) in the North Atlantic, and Reductions 

Under Option Scenarios 

IM&E Loss Metric (million per year) Option 1 Option 2 Option 3

Foregone Fishery Yield (lbs) 1.02 <0.01 0.83 0.87

Foregone Commercial Catch (lbs) 0.45 <0.01 0.37 0.39

Foregone Recreational Catch (fish) 0.76 <0.01 0.62 0.65

Production Foregone (lbs) 26.99 0.03 22.01 23.09

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I 

Everywhere and E for Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Raw numbers of I&E mortality losses in the North Atlantic can be found in Appendix Table C-4. 

3.3.3 Mid-Atlantic 

Estimated baseline I&E mortality, and estimated reductions to I&E mortality under the three regulatory 

options are presented in Table 3-5 and Table 3-6. Estimated total baseline I&E mortality losses in the 

Mid-Atlantic region are 990.06 million A1Es per year, including 751.07 million A1Es of forage fish (75.9 

percent). Approximately 3.11 percent of total baseline A1E losses are assigned a direct use value from 

recreational or commercial fishing (Table 3-5). Table C-5 of Appendix C presents species-specific data 
March 28, 2011 3-9 

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

on impingement and entrainment losses under the baseline conditions and estimated reductions under all 

options. Briefly, the vast majority (95 percent) of all A1E losses in the Mid-Atlantic occur as a 

consequence of entrainment mortality. Nearly half (45.9 percent) of the I&E mortality estimated for 

commercially- and recreationally-harvested species occurs in Blue Crab, and substantial I&E mortality 

(i.e., greater than 20 million A1E) is estimated for Atlantic Croaker, Atlantic Menhaden, Spot, and White 

Perch. 

Because of the high proportion of I&E mortality losses attributed to entrainment mortality, it is estimated 

that Options 2 and 3 will reduce I&E mortality by 91.9 and 93.0 percent, respectively (Table 3-5). 

Conversely, Option 1 is projected to reduce I&E mortality by approximately 3.9 percent, more than 20 

times smaller than the reductions estimated to occur under Options 2 and 3. 

Table 3-5: Baseline I&E Mortality Losses and I&E Mortality Reductions at All Inscope Facilities (Manufacturing and Generating) in the Mid-Atlantic, and 

Reductions Under Option Scenarios 

IM&EM Loss Metric (per year) Option 1 Option 2 Option 3

All Species (million A1E) 990.06 38.69 909.74 920.90

Forage Species (million A1E) 751.07 14.27 688.96 697.59

Commercial & Recreational Species (million A1E) 238.98 24.42 220.78 223.31

Commercial & Recreational Harvest (million fish) 30.77 6.09 28.66 28.95

A1E Losses with Direct Use Value (%) 3.11 15.75 3.15 3.14

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for 

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

The I&E mortality model projects that baseline I&E mortality results in 80.73 million pounds of foregone 

production, and decreases fishery yield by 22.53 million pounds per year (Table 3-6). Option 1 is 

estimated to result in increased fishery yields of 5.40 million pounds per year. Under Options 2 and 3, 

increased fishery yields are 21.01 and 21.22 million pounds per year, respectively (Table 3-6). 

Table 3-6: Baseline Losses in Fishery Yield, Catch, and Production 

Forgone as a Consequence of I&E Mortality at All In-scope Facilities 

(Manufacturing and Generating) in the Mid-Atlantic, and Reductions 

Under Option Scenarios 

IM&E Loss Metric (million per year) Option 1 Option 2 Option 3

Foregone Fishery Yield (lbs) 22.53 4.73 21.01 21.22

Foregone Commercial Catch (lbs) 11.59 3.75 10.91 11.01

Foregone Recreational Catch (fish) 9.08 0.55 8.36 8.46

Production Foregone (lbs) 80.73 10.16 74.73 75.56

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I 

Everywhere and E for Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Raw numbers of I&E mortality losses in the Mid-Atlantic region can be found in Appendix Table C-6. 
March 28, 2011 3-10 

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

3.3.4 South Atlantic Region 

Estimated baseline I&E mortality, and estimated reductions to I&E mortality under the three regulatory 

options are presented in Table 3-7 and Table 3-8. Estimated total baseline I&E mortality losses in the 

South Atlantic region are estimated to be 33.40 million A1Es per year, including 31.22 million forage fish 

A1Es. Approximately 1.03 percent of total baseline A1E losses are assigned a direct use value from 

recreational or commercial fishing (Table 3-7). Table C-7 of Appendix C presents species-specific data 

on impingement and entrainment losses under the baseline conditions and estimated reductions under all 

options. Unlike other regions, the majority (67 percent) of all A1E losses in the South Atlantic occur as a 

consequence of impingement mortality. Among commercially- and recreationally-harvested species, I&E 

mortality is greatest in Drums and Croakers and Blue Crab. 

Due to the high proportion of I&E mortality lost to impingement, Option 1 is projected to reduce I&E 

mortality by 42.5 percent. However, because the installation of closed-cycle cooling towers reduces water 

usage, Options 2 and 3 are projected to reduce I&E mortality by approximately 84.6 and 84.7 percent 

(Table 3-7), approximately double the estimated reductions of Option 1. 

Table 3-7: Baseline I&E Mortality Losses and I&E Mortality Reductions at All Inscope Facilities (Manufacturing and Generating) in the South Atlantic, and 

Reductions Under Option Scenarios 

IM&EM Loss Metric (per year) Option 1 Option 2 Option 3

All Species (million A1E) 33.40 14.20 28.28 28.30

Forage Species (million A1E) 31.22 13.43 26.43 26.45

Commercial & Recreational Species (million A1E) 2.19 0.77 1.85 1.85

Commercial & Recreational Harvest (million fish) 0.35 0.11 0.29 0.29

A1E Losses with Direct Use Value (%) 1.03 0.75 1.03 1.03

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for 

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Production foregone due to baseline I&E mortality is estimated to be 0.86 million pounds per year, 

leading to a decrease in fishery yield of approximately 0.16 million pounds per year. Option 1 is 

estimated to result in increased fishery yields of 0.05 million pounds per year. Under Options 2 and 3, 

however, estimated increases to fishery yields are more than 2 times greater, at 0.13 and 0.13 million 

pounds per year, respectively (Table 3-8). 

Table 3-8: Baseline Losses in Fishery Yield, Catch, and Production 

Forgone as a Consequence of I&E Mortality at All In-scope Facilities 

(Manufacturing and Generating) in the South Atlantic, and Reductions 

Under Option Scenarios 

IM&E Loss Metric (million per year) Option 1 Option 2 Option 3

Foregone Fishery Yield (lbs) 0.16 0.05 0.13 0.13

Foregone Commercial Catch (lbs) 0.10 0.05 0.08 0.08

Foregone Recreational Catch (fish) 0.13 0.02 0.11 0.11

Production Foregone (lbs) 0.86 0.14 0.72 0.72

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I 

Everywhere and E for Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses
March 28, 2011 3-11 

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

Raw numbers of I&E mortality losses in the South Atlantic region can be found in Appendix Table C-8. 

3.3.5 Gulf of Mexico 

Estimated baseline I&E mortality, and estimated reductions to I&E mortality under the three regulatory 

options are presented in Table 3-9 and Table 3-10. Estimated total baseline I&E mortality losses in the 

Gulf of Mexico are estimated to be 135.64 million A1Es per year, including 47.75 million forage fish 

A1Es. Approximately 8.56 percent of total baseline A1E losses are assigned a direct use value from 

recreational or commercial fishing (Table 3-9). Table C-9 of Appendix C presents species-specific data 

on impingement and entrainment losses under the baseline conditions and estimated reductions under all 

options. The majority (67 percent) of all A1E losses in the Gulf of Mexico occur as a consequence of 

entrainment mortality. Among commercially- and recreationally-harvested species, I&E mortality is 

greatest in Blue Crab, and Pink Shrimp, which together account for 68 percent of A1E losses with direct 

use value. Other fish species with substantial I&E mortality (i.e., greater than 5 million A1E) include 

Black Drum, Menhaden, and Silver Perch (Appendix Table C-9). 

Due to the low proportion of I&E mortality lost to impingement, Option 1 is projected to reduce I&E 

mortality by only 25.4 percent. In contrast, Options 2 and 3 are projected to reduce I&E mortality by 78.2 

and 78.3 percent, respectively (Table 3-9), approximately triple the estimated reductions of Option 1. 

Table 3-9: Baseline I&E Mortality Losses and I&E Mortality Reductions at All Inscope Facilities (Manufacturing and Generating) in the Gulf of Mexico, and 

Reductions Under Option Scenarios 

IM&EM Loss Metric (per year) Option 1 Option 2 Option 3

All Species (million A1E) 135.64 34.50 106.02 106.21

Forage Species (million A1E) 47.75 4.31 34.09 34.16

Commercial & Recreational Species (million A1E) 87.89 30.19 71.94 72.05

Commercial & Recreational Harvest (million fish) 11.61 4.59 9.75 9.76

A1E Losses with Direct Use Value (%) 8.56 13.29 9.20 9.19

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for 

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Production foregone due to baseline I&E mortality is estimated to be 76.06 million pounds per year, 43 

percent of which is foregone fishery yield. Option 1 is estimated to reduce foregone fishery yields by 2.99 

million pounds, while Options 2 and 3 are estimated to reduce foregone fishery yields by 23.43 and 23.48 

million pounds, respectively (Table 3-10). 

Raw numbers of I&E mortality losses in the Gulf of Mexico can be found in Appendix Table C-10. 
March 28, 2011 3-12 

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

Table 3-10: Baseline Losses in Fishery Yield, Catch, and Production 

Forgone as a Consequence of I&E Mortality at All In-scope Facilities 

(Manufacturing and Generating) in the Gulf of Mexico, and 

Reductions Under Option Scenarios 

IM&E Loss Metric (million per year) Option 1 Option 2 Option 3

Foregone Fishery Yield (lbs) 32.81 2.99 23.43 23.48

Foregone Commercial Catch (lbs) 5.56 1.46 4.36 4.37

Foregone Recreational Catch (fish) 2.85 0.67 2.20 2.21

Production Foregone (lbs) 76.06 5.77 53.84 53.96

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I 

Everywhere and E for Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

3.3.6 Great Lakes Region 

Estimated baseline I&E mortality, and estimated reductions to I&E mortality under the three regulatory 

options are presented in Table 3-11 and Table 3-12. Estimated total baseline I&E mortality losses in the 

Great Lakes are 53.50 million A1Es per year, including 46.46 million A1E of forage fish. Approximately 

1.50 percent of total baseline A1E losses are assigned a direct use value from recreational or commercial 

fishing (Table 3-11). Table C-11 of Appendix C presents species-specific data on impingement and 

entrainment losses under the baseline conditions and estimated reductions under all options. Briefly, 

among commercially and recreationally-harvested species, the greatest losses occur in Smelts and 

Sunfish. 

The vast majority (83 percent) of I&E mortality losses in the Great Lakes occur due to impingement 

(Appendix Table C-11). Accordingly, Option 1 reduces baseline A1E I&E mortality by 71.5 percent 

(Table 3-11). By requiring the installation of closed-cycle cooling towers, which reduce the volume of 

water required for cooling purposes, Options 2 and 3 reduce A1E losses by 95.7 and 96.0 percent, 

respectively (Table 3-11). 

Table 3-11: Baseline I&E Mortality Losses and I&E Mortality Reductions at All Inscope Facilities (Manufacturing and Generating) in the Great Lakes, and 

Reductions Under Option Scenarios 

IM&EM Loss Metric (per year) Option 1 Option 2 Option 3

All Species (million A1E) 53.50 38.23 51.13 51.35

Forage Species (million A1E) 46.46 33.46 44.46 44.64

Commercial & Recreational Species (million A1E) 7.04 4.77 6.67 6.70

Commercial & Recreational Harvest (million fish) 0.80 0.49 0.75 0.75

A1E Losses with Direct Use Value (%) 1.50 1.28 1.47 1.47

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for 

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Production foregone due to baseline I&E mortality is estimated to be 32.02 million lbs of fish, leading to 

a decrease in fishery yield of 0.70 million pounds per year (Table 3-12). Option 1 is estimated to result in 

increased fishery yields of 0.42 million pounds per year. Under Options 2 and 3, however, estimated 
March 28, 2011 3-13 

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

increases to fishery yields are approximately 50 percent greater, at 0.65 and 0.65 million pounds per year, 

respectively (Table 3-12). 

Table 3-12: Baseline Losses in Fishery Yield, Catch, and Production 

Forgone as a Consequence of I&E Mortality at All In-scope Facilities 

(Manufacturing and Generating) in the Great Lakes, and Reductions 

Under Option Scenarios 

IM&E Loss Metric (million per year) Option 1 Option 2 Option 3

Foregone Fishery Yield (lbs) 0.70 0.42 0.65 0.65

Foregone Commercial Catch (lbs) 0.35 0.23 0.33 0.33

Foregone Recreational Catch (fish) 0.35 0.18 0.32 0.32

Production Foregone (lbs) 32.02 7.34 27.19 27.49

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I 

Everywhere and E for Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Raw numbers of I&E mortality losses in the Great Lakes region can be found in Appendix Table C-12. 

3.3.7 Inland Region 

Estimated baseline I&E mortality, and estimated reductions to I&E mortality under the three regulatory 

options are presented in Table 3-13 and Table 3-14. Estimated total baseline I&E mortality losses in the 

Inland region are 879.49 million A1Es per year, including 713.71 million A1E of forage fish. 

Approximately 1.43 percent of total baseline A1E losses are assigned a direct use value from recreational 

or commercial fishing (Table 3-13). Table C-13 of Appendix C presents species-specific data on 

impingement and entrainment losses under the baseline conditions and estimated reductions under all 

options. Briefly, the majority (66.4 percent) of all A1E losses in the Inland region occur as a consequence 

of impingement mortality (Appendix Table C-13). Notably, the I&E mortality of sunfish account for 78.4 

percent of the I&E mortality of commercially and recreationally-harvested species. 

Option 1 reduces baseline I&E mortality A1E losses by 55.5 percent (Table 3-13). The installation of 

closed-cycle cooling towers under Options 2 and 3 reduce A1E losses by 91.6 and 93.5 percent, 

respectively, providing a benefit more than 60 percent larger than the benefits of Option 1 (Table 3-13). 

Table 3-13: Baseline I&E Mortality Losses and I&E Mortality Reductions at All Inscope Facilities (Manufacturing and Generating) in the Inland Region, and 

Reductions Under Option Scenarios 

IM&EM Loss Metric (per year) Option 1 Option 2 Option 3

All Species (million A1E) 879.49 488.22 805.86 822.46

Forage Species (million A1E) 713.71 459.64 665.29 676.63

Commercial & Recreational Species (million A1E) 165.78 28.59 140.57 145.83

Commercial & Recreational Harvest (million fish) 12.59 4.32 11.06 11.39

A1E Losses with Direct Use Value (%) 1.43 0.89 1.37 1.38

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for 

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses
March 28, 2011 3-14 

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

The decrease in production due to baseline I&E mortality is estimated to be 407.08 million pounds of 

fish, leading to a decrease in fishery yield of 11.01 million pounds per year (Table 3-14). Option 1 is 

estimated to result in increased fishery yields of 3.77 million pounds per year. Under Options 2 and 3, 

however, estimated increases to fishery yields are more than two times greater, at 9.67 and 9.96 million 

pounds per year, respectively (Table 3-14). 

Table 3-14: Baseline Losses in Fishery Yield, Catch, and Production 

Forgone as a Consequence of I&E Mortality at All In-scope Facilities 

(Manufacturing and Generating) in the Inland Region, and Reductions 

Under Option Scenarios 

IM&E Loss Metric (million per year) Option 1 Option 2 Option 3

Foregone Fishery Yield (lbs) 11.01 3.77 9.67 9.96

Foregone Commercial Catch (lbs) <0.01 <0.01 <0.01 <0.01

Foregone Recreational Catch (fish) 12.59 4.32 11.06 11.39

Production Foregone (lbs) 407.08 102.90 351.01 362.84

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I 

Everywhere and E for Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Raw numbers of I&E mortality losses in the Inland region can be found in Appendix Table C-14. 

3.3.8 National Estimates 

Estimated baseline I&E mortality, and estimated reductions to I&E mortality under the three regulatory 

options are presented in Table 3-15 and Table 3-16. Estimated total baseline I&E mortality losses 

nationally are 2,188.92 million A1Es per year, including 1,654.78 million A1E of forage fish. 

Approximately 2.71 percent of total baseline A1E losses are assigned a direct use value from recreational 

or commercial fishing (Table 3-15). Table C-13 of Appendix C presents species-specific data on 

impingement and entrainment losses under the baseline conditions and estimated reductions under all 

options. Briefly, the majority (65.8 percent) of all A1E losses nationally occur as a consequence of 

entrainment mortality (Appendix Table C-13). 

Option 1 reduces baseline I&E mortality A1E losses by 28.1 percent (Table 3-15). The installation of 

closed-cycle cooling towers under Options 2 and 3 reduce A1E losses by 90.5 and 92.0 percent, 

respectively, providing a benefit approximately three times larger than the benefits of Option 1 (Table 

3-15). 
March 28, 2011 3-15 

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

Table 3-15: Baseline I&E Mortality Losses and I&E Mortality Reductions at All Inscope Facilities (Manufacturing and Generating) Nationally, and Reductions 

Under Option Scenarios 

IM&EM Loss Metric (per year) Option 1 Option 2 Option 3

All Species (million A1E) 2188.92 614.97 1981.55 2013.55

Forage Species (million A1E) 1654.78 525.66 1512.64 1535.44

Commercial & Recreational Species (million A1E) 534.15 89.31 468.91 478.11

Commercial & Recreational Harvest (million fish) 59.41 15.66 53.28 54.05

A1E Losses with Direct Use Value (%) 2.71 2.55 2.69 2.68

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for 

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

The decrease in production due to baseline I&E mortality is estimated to be 637.78 million pounds of 

fish, leading to a decrease in fishery yield of 71.50 million pounds per year (Table 3-16). Option 1 is 

estimated to result in increased fishery yields of 11.99 million pounds per year. Under Options 2 and 3, 

however, estimated increases to fishery yields are more than four times greater, at 58.52 and 59.24 million 

pounds per year, respectively (Table 3-16). 

Table 3-16: Baseline Losses in Fishery Yield, Catch, and Production 

Forgone as a Consequence of I&E Mortality at All In-scope Facilities 

(Manufacturing and Generating) Nationally, and Reductions Under 

Option Scenarios 

IM&E Loss Metric (million per year) Option 1 Option 2 Option 3

Foregone Fishery Yield (lbs) 71.50 11.99 58.52 59.24

Foregone Commercial Catch (lbs) 19.43 5.49 17.23 17.41

Foregone Recreational Catch (fish) 26.79 5.77 23.55 24.06

Production Foregone (lbs) 637.78 126.44 541.48 556.20

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I 

Everywhere and E for Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Raw numbers of national I&E mortality losses can be found in Appendix Table C-16. 

3.4 Limitations and Uncertainties 

There are four major kinds of uncertainty that may lead to imprecision and bias in EPA’s I&E mortality 

analysis: data, structural, statistical, and engineering uncertainty. Data limitations and uncertainty refers to 

uncertainty and inconsistency in sampling methodologies used in facility-specific I&E mortality studies. 

Structural uncertainty reflects the simplification built into any model of a complex natural system. 

Parameter uncertainty refers to uncertainty in the numeric estimates of model parameters. Finally, 

engineering uncertainty refers to the fact that facilities do not operate identically on an annual basis. 

3.4.1 Data Limitation and Uncertainty 

Quantification of regional and national I&E mortality losses is based on cumulative data generated by 

collection at individual facilities. In turn, these data are heterogeneous products of location-specific 

investigations set in differing geographic and ecological provinces. Interpretation of the significance and 
March 28, 2011 3-16 

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

trends of I&E mortality at regional and national scales (and of the accompanying ecological benefits upon 

mitigation) must consider the strengths and weaknesses of this data. 

The I&E mortality data from model facilities constitute a heterogeneous composite of results from many 

facility-specific studies. Sampling effort and data quality control vary tremendously among I&E mortality 

studies and baseline source water characterization programs. While there is broad EPA guidance as to the 

overall objectives and requirements for facility-specific data collection, there is little uniformity among 

studies as to the intensity, frequency and duration of data collection as well as the scope of target biota 

collected, identified, and enumerated. Sampling regimes may be properly adjusted to ensure that changes 

in local biotic activity associated with diurnal, tidal, and lunar cycles are incorporated; or may reflect 

regularly spaced sampling points with little concern paid to capturing environmental variability. 

In addition to the differences in environmental scope, sampling methods are not uniform among studies 

with regard to the types and meshes of sampling nets, deployment location of sampling nets (e.g., outside 

or within the intake structure), length and weight measurements, observations of field conditions, 

characterization of reference areas, etc. In addition to different sampling methods and timing, some 

sampling programs are designed primarily to estimate I&E mortality losses for a select suite of 

recreational or commercially important aquatic organisms. Studies differ in their taxonomic sorting 

classes and specificity of identification of impinged and entrained organisms (e.g., eggs, ichthyoplankton, 

zooplankton, etc.). Thus, many I&E mortality studies are poorly suited to provide insight into the direct 

and indirect impacts to forage fish species, non-vertebrate organisms (zooplankton, tunicates, algae, 

worms, etc.), or community/ecosystem impacts. For older facilities, sampling data commonly lack preoperational (i.e., baseline) samples or community surveys to compare to the results of more-current I&E 

mortality data. Finally, few I&E mortality studies are designed to allow evaluation of community impacts 

or ecosystem effects (Section 2.4). 

Within regions, studies of I&E mortality from model facilities are typically composed of data from a 

relatively limited number of facilities. Most facility-specific I&E mortality studies are limited to one or 

two years, and are rarely replicated within a time period that allows direct comparison of trends without 

historical complications due to fishery stock trends, climatic changes, or shifts in collection methods or 

water quality. Thus, studies within a regional database may not accurately represent average climatic and 

oceanographic conditions (e.g., El Nino years). Additionally, studies within the database may include 

historical (>20 years) and recent data, thus incorporating considerable uncertainty due to the annual 

variability of highly dynamic fish stocks. Thus, extrapolation from regional collections of facility-specific 

studies may not provide a true regional estimate because the available data may or may not be fully 

representative of regional trends and/or of associated ecological benefits derived from mitigating I&E 

mortality impacts. 

3.4.2 Structural Uncertainty 

The models EPA used to evaluate I&E mortality simplify complex processes. The degree of 

simplification is substantial, but necessary, because of limited data availability and the need to generate 

estimates on a national scale. Simplification occurs with respect to many processes within the model, to 

ensure computational tractability and national applicability (Table 3-17). 

EPA recognizes these uncertainties, but believes that addressing each of these uncertainties in a 

defensible way would require data that does not currently exist (see Section 3.2.4.2), would be timeconsuming and resource-intensive to develop, and would lead to greater parameter uncertainty (Section 

3.4.3). 
March 28, 2011 3-17 

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

Table 3-17: Structural Uncertainties 

Aspect of Model General Description Specific Treatment in Model 

Biological 

submodels 

Life history traits are fixed Life history parameters in the models (i.e., growth, survival) are constant 

through time and are thus independent of biological conditions (e.g., fish 

densities, seasonality, weather, recruitment variability, food availability, 

fisheries pressure, etc.). 

 No trophic effects Indirect food web effects such as trophic cascades, growth and population 

limitations due to a lack of food, etc., are not considered. Trophic transfer 

is treated simplistically. 

 Outside impacts not addressed I&E mortality loss rates are affected by a variety of outside influences not 

included in the model (e.g., fisheries pressure, pollution, future 

development, invasive species, climate change, etc.). 

Valuation 

structure 

National nonuse benefits not 

addressed 

Fish species grouped into two categories: harvested or not harvested (i.e., 

forage for harvested species). Only commercial and recreational harvests 

are assigned monetary values at the national level. Nonuse values of I&E 

mortality is estimated for the North Atlantic and Mid-Atlantic regions only.

 Fishing pressure constant The valuation procedure assumes that fisheries harvests will increase 

proportionately to decreases in I&E mortality losses, independent of 

Federal and State policies on commercial and recreational fishing (i.e., 

fisheries quotas, closures, bag limits, etc.). 

3.4.3 Parameter Uncertainty 

Parameter uncertainty refers to variability in the value of parameters used in biological and economic 

modeling. All parameters must be estimated from sampling studies that cannot identify the true values of 

interest due to statistical and logistical limitations. These limitations are broadly driven by three 

processes, including parameter fluctuation through time, geographic location, and sampling. 

The true value of many biological parameters fluctuates on an annual basis, due to changes in weather, 

food availability, indirect food-web effects, and compensatory population dynamics. Consequently, 

parameter values used within biological submodels, despite being based upon the best available data 

obtained from the scientific literature, cannot be without error due to annual variability in fish growth and 

(natural and fisheries) mortality rates. Similarly, because I&E mortality rates are driven by a combination 

of intake flow and the presence of vulnerable fish, actual I&E mortality cannot remain constant through 

time. 

True values of biological parameters and facility I&E mortality vary geographically. Biological 

parameters may vary substantially within regions due to changes in substrate, water temperature and 

salinity, etc., while facility I&E mortality data may be strongly connected to local substrates, distance 

from shore, depth, etc. It follows, then, that using biological data and extrapolating facility-specific I&E 

mortality rates to the regional scale will result in parameter variability based solely on geographic 

considerations. 

Finally, all model parameters contain uncertainty because they are small samples from a much larger 

dataset. Biological parameters such as mortality rates must be estimated using incomplete sampling data. 

Facility-reported I&E mortality studies necessarily subsample cooling water, and often do not take 

replicate samples across tidal periods, seasons, time of day, and between years. Moreover, these studies 

often present I&E mortality with limited taxonomic detail (i.e., the identification of eggs, larvae, and 

juveniles is not species-specific), and do not have standard methodologies. As is the case with 

retrospective data, these studies also reflect the biological and physical state of the waterbody when 
March 28, 2011 3-18 

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

studies were conducted. In some cases, the state of the waterbody itself has changed substantially since 

sampling was conducted. 

EPA recognizes many sources of parameter uncertainty in its models (Table 3-18), all of which lead to 

uncertainty in point estimates of I&E mortality losses. The nature of these uncertainties, however, does 

not inherently bias the point estimate. EPA believes that all biological and physical parameters were 

reported in good faith, and as such, parameter estimates are unlikely to be biased in aggregate, but 

distributed both above and below true parameter values. Thus, EPA believes that parameter uncertainty 

has resulted in imprecision rather than inaccuracy in model output.8

 

3.4.4 Engineering Uncertainty 

EPA’s evaluation of I&E mortality was also affected by uncertainty about the engineering and operating 

characteristics of the study facilities. It is unlikely that plant operating characteristics (e.g., seasonal, 

diurnal, or intermittent changes in intake water flow rates) are constant throughout any particular year. As 

such, the timing of sampling, and the annual repeatability of I&E mortality, may be biased by facility 

operating conditions. EPA assumed that the facilities’ loss estimates were provided in good faith and did 

not include any biases or omissions that significantly modified loss estimates. 

 

8 Accuracy refers to the degree of closeness of model results to the actual value. Precision refers to the reproducibility of model 

output, or the degree to which repeated measurements (or samples, for example from different model facilities) under similar 

conditions will result in the same model output.
March 28, 2011 3-19 

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

Table 3-18: Parameters Included in EPA’s I&E Mortality Analysis Subject to Uncertainty 

Model Aspect Parameter Description 

I&E mortality 

monitoring /loss rate 

estimates 

Sampling regimes Sampling regimes are subject to numerous plant-specific details. No 

established guidelines or performance standards for how to design and conduct 

sampling regimes. Not all sampling studies measured both impingement and 

entrainment mortality. 

Extrapolation 

assumptions 

Extrapolation of monitoring data to annual I&E mortality rates assumes 

sampling occurred under average conditions, and that diurnal/seasonal/annual 

cycles in fish presence and vulnerability and various technical factors (e.g., net 

collection efficiency; hydrological factors affecting I&E mortality rates) do not 

play a substantial role in the accuracy of extrapolation. No established 

guidelines or consistency in sampling regimes. 

Species selection Criteria for the selection of species evaluated in I&E mortality studies are not 

well-defined nor uniform across facilities. At many facilities, I&E mortality 

data was collected for only a subset of species, usually only fish and shellfish. 

Sensitivity of fish to 

I&E mortality 

Entrainment mortality was assumed by EPA to be 100%. Back-calculations 

were done in cases where facilities reported entrainment rates that assumed 

<100% mortality. These calculations were limited by data reporting (i.e., 

species-specific survival rates were not always provided). Impingement 

survival was included if presented in facility documents. 

Biological/life 

history 

Natural mortality rates Natural mortality rates (M) difficult to estimate, and vary with time and 

geography. Model results are highly sensitive to M. 

Growth rates Simple exponential growth rates or simple size-at-age parameters used, and 

assumed constant across all locations and years. 

Geographic 

considerations 

Migration patterns; I&E mortality occurring during spawning runs or larval 

out-migration; location of harvestable adults; intermingling with other stocks. 

Forage valuation Harvested species assumed to be food limited; trophic transfer efficiency to 

harvested species estimated by EPA based on general models; no consideration 

of trophic transfer to species not impinged and entrained. 

Fish stock 

characteristics 

Fishery yield For most harvested species, only one species-specific value for fishing 

mortality rate (F) was used for all stages subject to harvest. Used stage-specific 

constants for fraction vulnerable to fishery. 

Harvest behavior No assumed dynamics among harvesters to alter fishing rates or preferences in 

response to changes in stock size. Recreational access assumed constant (no 

changes in angler preferences or effort). 

Stock interactions I&E mortality losses assumed to be part of reported fishery yield rates on a 

statewide basis. No consideration of possible substock harvest rates or 

interactions, no unreported catch. 

Ecological 

system 

Fish community Long-term trends in fish community composition or abundance were not 

considered (general food webs assumed to be static), nor were indirect trophic 

interactions. Used constant value for trophic transfer efficiency, and specific 

trophic interactions were not considered. Trophic transfer to organisms not 

impinged and entrained is not considered. 

Spawning dynamics Sampled years assumed to be typical with respect to choice of spawning areas 

and timing of migrations that could affect vulnerability to I&E mortality 

(e.g., presence of larvae in vicinity of intake structure). 

Hydrology Sampled years assumed to be typical with respect to flow regimes and tidal 

cycles that could affect vulnerability to I&E mortality (e.g., presence of larvae 

in vicinity of CWIS). 

Meteorology Sampled years assumed to be typical with respect to vulnerability to I&E 

mortality (e.g., presence of larvae in vicinity of intake structure). 
March 28, 2011 4-1 

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

4 Economic Benefit Categories Associated with I&E Mortality 

Reduction 

Changes in CWIS design or operations resulting from the regulatory options for the proposed Section 

316(b) regulation for in-scope facilities are expected to increase the numbers of aquatic organisms present 

and increase local and regional fishery populations. They will do this by reducing impingement and 

entrainment (I&E) mortality of fish, shellfish, and other aquatic organisms. 

The aquatic organisms affected by CWISs provide a wide range of ecosystem services. Ecosystem 

services are the physical, chemical, and biological functions performed by natural resources and the 

human benefits derived from those functions, including both ecological and human use services (Daily 

1997; Daily et al. 1997). Scientific and public interest in protecting ecosystem services is increasing with 

the recognition that these services are vulnerable to a wide range of human activities and are difficult, if 

not impossible, to replace with human technologies (Meffe 1992). 

In addition to their importance in providing food and other goods of direct use to humans, the organisms 

lost to impingement and entrainment mortality (I&E mortality) are critical to the continued functioning of 

the ecosystems of which they are a part. Fish are essential for energy transfer in aquatic food webs, 

regulation of food web structure, nutrient cycling, maintenance of sediment processes, redistribution of 

bottom substrates, the regulation of carbon fluxes from water to the atmosphere, and the maintenance of 

aquatic biodiversity (Holmlund and Hammer 1999; Peterson and Lubchenco 1997; Postel and Carpenter 

1997; Wilson and Carpenter 1999). Many of these ecosystem services can be maintained only by the 

continued presence of all life stages of fish and other aquatic species in their natural habitats. Section 2.3 

provided detail on potential CWIS impacts on aquatic ecosystems. Due to a lack of data, many of these 

impacts could not be successfully evaluated or monetized. 

4.1 Economic Benefit Categories Applicable to the Regulatory Options for InScope Facilities 

The economic benefits of reducing I&E mortality at in-scope facilities stem from both market and 

nonmarket goods and services that the affected resources provide. These benefits can be divided into the 

following categories (Table 4-1, below). 

 Market benefits: Market benefits are positive welfare impacts that can be quantified using 

money-denominated measures of consumer and producer surplus. The most obvious example of 

market benefits from reduced I&E mortality is benefits to commercial fisheries. Changes in I&E 

mortality will directly affect the price, quantity, and/or quality of fish harvests; and the monetary 

value of the changes can be measured directly through market measures of consumer and 

producer behavior. Market benefits may be further categorized in terms of direct and indirect 

benefits. By definition, all market benefits are use benefits, as they involve either direct or 

indirect uses of goods or services. 

 Market direct use benefits: Market direct use benefits are benefits related to goods directly 

used, and bought and sold in markets; for example, fish caught for sale to consumers. 

 Market indirect use benefits: Indirect use benefits are those that contribute indirectly to an 

increase in welfare for users of the resource. Market indirect use benefits are benefits that 
March 28, 2011 4-2 

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

occur through indirect or secondary effects on marketed goods. For example, an increase in 

the number of forage fish may increase the population of commercially valuable species, 

which are marketed to consumers. Thus, reducing I&E mortality of forage species can 

indirectly result in welfare gains for commercial fishers and consumers who purchase fish. 

 Nonmarket benefits: Nonmarket benefits consist of goods and services that are not traded in the 

marketplace, but are nonetheless positively affected by reduced I&E mortality. Higher catch rates 

for recreational fishing are an obvious nonmarket benefit. Anglers place a high value on catching 

fish during their fishing trips, so higher catch rates from reduced I&E mortality will translate 

directly to greater utility from participation in recreational fishing. Because the monetary value of 

these improvements cannot be established by observing market transactions, nonmarket valuation 

techniques must be employed to estimate such benefits. Nonmarket benefits may be further 

categorized in terms of direct and indirect use benefits, and nonuse benefits. 

 Nonmarket direct use benefits: Nonmarket direct use benefits consist of goods and services 

that have direct uses, but are not traded in the marketplace. Higher catch rates for recreational 

fishing provide a typical nonmarket direct use benefit. 

 Nonmarket indirect use benefits: Nonmarket indirect use benefits contribute indirectly to 

an increase in welfare for nonmarketed uses of a resource. For example, the options’ positive 

impacts on local fisheries may generate an improvement in the population levels and diversity 

of fish-eating bird species. In turn, avid bird watchers might obtain greater enjoyment from 

their outings, as they are more likely to see a wider mix or greater numbers of birds. The 

increased welfare of the bird watchers is thus an indirect consequence of the regulatory 

options’ initial impact on fish..

 Nonuse benefits: Nonuse, or passive, benefits occur when individuals value improved 

environmental quality without any past, present, or anticipated future use of the resource in 

question. Individuals may gain utility simply from knowing that a particular good exists 

(existence value), or from knowing that a good is available for others to use now and in the 

future (bequest value). Nonuse benefits of reduced I&E mortality may include increased 

biodiversity, improved conditions for the recovery of T&E species that have no direct or 

indirect uses, and welfare gains to nonusers when reduced I&E mortality to forage species 

improve overall ecosystem function. 

Table 4-1 displays the benefit categories expected to be affected by the regulatory options considered for 

the Section 316(b) regulation for in-scope facilities. The table also reveals the various data needs, data 

sources, and estimation approaches associated with each category. Many ecosystem services with 

potential nonuse values could not be quantified or monetized due to a lack of sufficient data. A complete 

list of the ecosystem services potentially affect by reduction in I&E mortality is presented in Chapter 2 

(Table 2-4). 
March 28, 2011 4-3 

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

Table 4-1: Summary of Benefit Categories’ Data Needs, Potential Data Sources, Approaches, and 

Analyses Completed 

Benefit Category Basic Data Needs 

Potential Data Sources/ 

Approaches/Analyses Completed 

Market Goods, Direct Use

 Increased commercial landings 

 Estimated change in landings of specific 

species 

 Estimated change in total economic 

impact 

 Based on facility-specific I&E 

mortality data and ecological 

modeling. 

 Changes in commercial fishery 

landings are estimated using a 

market-based approach. 

 Indirect economic impacts are not 

estimated due to data constraints. 

Market Goods, Indirect Use

Increase in: 

 Equipment sales, rental, and repair 

 Bait and tackle sales 

 Consumer market choices 

 Choices in restaurant meals 

 Property values near the water 

 Ecotourism (charter trips, festivals, other 

organized activities with fees such as 

riverwalks) 

 Estimated change in landings of specific 

species 

 Relationship between increased 

fish/shellfish landings and secondary 

markets 

 Local activities and participation fees 

Estimated numbers of participating 

individuals 

 Indirect market impacts are not 

estimated, due to data constraints 

such as lack of information on the 

relationship between increased 

fish/shellfish yield and secondary 

impacts. 

Nonmarket Goods, Direct Use

 Improved value of a recreational fishing 

trip due to increased catch of 

targeted/preferred species and incidental 

catch 

 Improved value of subsistence fishing 

 Estimated number of affected anglers 

 Value of an improvement in catch rate 

 Changes in the value of a 

recreational fishing trip are estimated 

based on benefit transfer (including 

recreational use values of selected 

T&E species). 

 Changes in the value of subsistence 

fishing is not estimated.

 Increase in recreational fishing 

participation 

 Estimated number of affected anglers or 

estimate of potential anglers 

 Value of a fishing day 

 Not estimated due to data 

constraints. 

Nonmarket Goods, Indirect Use

Increase in value of boating, scuba-diving, 

and near-water recreational experience 

from: 

 Enjoying observing fish while boating, 

scuba-diving, hiking, or picnicking 

 Watching aquatic birds fish or catch 

aquatic invertebrates 

 Estimated number of affected nearwater recreationists, divers, and boaters

 Value of boating, scuba-diving, and 

near-water recreation experience 

 Not estimated due to data 

constraints such as number of 

affected recreational users.

 Increase in boating, scuba-diving, and 

near-water recreation participation

 Estimated number of affected boating, 

scuba-diving, and near-water 

recreationists 

 Value of a recreation day

 Not estimated. Changes in 

recreational participation are 

expected to be negligible at the 

regional level because fishery yield 

impacts are generally small.

Nonuse Goods

Increase in nonuse values such as: 

 Existence (stewardship) 

 Altruism (interpersonal concerns) 

 Bequest (interpersonal and 

intergenerational equity) motives 

 Appreciation of the importance of 

ecological services apart from human 

uses or motives (Table 2-4) 

 I&E mortality estimates 

 Primary valuation research using stated 

preference approach 

 Applicable studies upon which to 

conduct benefit transfer 

 Location of CWISs and T&E species 

ranges 

 Estimate nonuse values for an 

increase in relative fish abundance 

within two benefits regions using 

benefits transfer. Not estimated for 

other regions due to a lack of 

applicable studies. 

 Used geographic information 

system (GIS) data to identify T&E 

species potentially impacted by 

CWISs based on the overlap of 

CWIS locations and T&E species 

ranges.
March 28, 2011 4-4 

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

4.2 Market and Nonmarket Direct and Indirect Use Benefits from Reduced 

I&E Mortality 

Direct use benefits are the simplest to envision. The welfare of commercial, recreational, and subsistence 

fishers is improved when fish stocks increase and their catch rates rise or effort decreases. Higher catch 

rates increase the revenue and growth of commercial fisheries, the enjoyment of recreational fishing trips, 

and the availability of food for subsistence fishers—all of which are quantifiable benefits arising directly 

from changes in I&E mortality. Methodologies for estimating use values for recreational and commercial 

species are well developed, and some of the species affected by I&E mortality have been extensively 

studied. As a result, estimation of associated use values is often considered to be straightforward. 

Indirect use benefits refer to welfare improvements for those individuals whose activities are enhanced as 

an indirect consequence of fishery or habitat improvements generated by the regulatory options for inscope facilities. For example,an improvement in the population of a forage fish species may not be of any 

direct consequence to recreational or commercial fishers. However, the increased presence of forage fish 

will have an indirect effect on commercial and recreational fishing values if it increases food supplies for 

commercial and recreational predatory species. Thus, improvements in forage species populations can 

result in a greater number (and/or greater individual size) of those fish that are targeted directly by 

recreational or commercial fishers. In such an instance, the incremental increase in recreational and 

commercial fishing benefits would be an indirect consequence of the regulatory options’ effect on forage 

fish populations. 

The following sections discuss the benefits estimates presented in each chapter of this report, and 

techniques for estimating benefits of reduced I&E mortality for each category of benefits.9

4.2.1 Commercial Fisheries 

Commercial fishing benefits include both direct and indirect market use values. The social benefits 

derived from increased landings by commercial fishers can be valued by examining the markets through 

which the landed fish are sold. The first step of the analysis involves a fishery-based assessment of I&E 

mortality-related changes in commercial landings (pounds of commercial species as sold dockside by 

commercial harvesters). The changes in landings are then valued according to market data from relevant 

fish markets (dollars per pound) to derive an estimate of the change in gross revenue to commercial 

fishers. The final steps entail converting the I&E mortality-related changes in gross revenues into 

estimates of social benefits. These social benefits consist of the sum of the producers’ and consumers’ 

surpluses that are derived as the changes in commercial landings work their way through the multi-market 

commercial fishery sector. 

Indirect use values in markets occur through increases in commercial species caused by increased 

numbers of forage fish. An improvement in the population of a forage fish species may not be of any 

direct consequence to commercial fishers. However, the increased presence of forage fish will have an 

indirect effect on commercial fishing values if it increases food supplies for commercial predatory 

species. Thus, improvements in forage species populations can result in a greater number (and/or greater 

individual size) of those fish that are targeted directly by commercial fishers. In such an instance, the 

 

9

 Many of the fish species affected by I&E mortality at CWIS sites are harvested both recreationally and commercially. To 

avoid double-counting the economic impacts of I&E mortality of these species, EPA determined, based on historic NMFS 

landings data, the proportions of total species landings attributable to recreational and commercial fishing, and applied these

proportions to the total number of affected fish. 
March 28, 2011 4-5 

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

incremental increase in commercial fishing benefits would be an indirect consequence of the regulatory 

options’ effect on forage fish populations. See Chapter 3 for a discussion on the indirect influence of 

forage fish on abundance of commercial and recreational species. 

Chapter 6 of this report provides more detail on EPA’s analysis of commercial fishing benefits from 

reducing I&E mortality at the in-scope facilities’ cooling water intakes. 

4.2.2 Recreational Fisheries 

Recreational fishing benefits include both direct and indirect nonmarket use values. The benefits of 

recreational use cannot be tracked in the market, since much of the recreational activity associated with 

these fisheries occurs as nonmarket events. However, a variety of nonmarket valuation methods exist for 

estimating use value, including both “revealed” and “stated” preference methods (Freeman III 2003). 

These methods use other observable behavior to infer users’ value for environmental goods and services. 

Examples of revealed preference methods include travel cost, hedonic pricing, and random utility models. 

Compared to nonuse values, nonmarket use values are often considered relatively easy to estimate, due to 

their relationship to observable behavior, the variety of revealed preference methods available, and public 

familiarity with the recreational services that surface waterbodies provide. 

To evaluate the recreational benefits of the regulatory options for in-scope facilities, EPA developed a 

benefit transfer approach based on a meta-analysis of recreational fishing valuation studies. The analysis 

was designed to measure the various factors that determine willingness to pay (WTP) for catching an 

additional fish per trip. The estimated meta-model allows calculation of the marginal value per fish for 

different species, based on resource and policy context characteristics. 

Indirect use values for forage species occur through increases in recreational species caused by increased 

numbers of forage fish. An improvement in the population of a forage fish species may not be of any 

direct consequence to recreational anglers. However, the increased presence of forage fish will have an 

indirect effect on recreational fishing values if it increases food supplies for recreational predatory 

species. Thus, improvements in forage species populations can result in a greater number (and/or greater 

individual size) of those fish that are targeted directly by recreational anglers. In such an instance, the 

incremental increase in recreational fishing benefits would be an indirect consequence of the regulatory 

options’ effect on forage fish populations. See Chapter 3 for a discussion on the indirect influence of 

forage fish on abundance of commercial and recreational species. 

Chapter 7 of this report provides detail on the application of the meta-regression model to estimating 

recreational fishing benefits from the alternative regulatory options. 

4.2.3 Subsistence Fishers 

Subsistence fisheries benefits include both direct and indirect nonmarket use values. Subsistence use of 

fishery resources can be an important issue in areas where socioeconomic conditions (e.g., the number of 

low-income households) or the mix of ethnic backgrounds make such fishing economically or culturally 

important to a component of the community. In cases of Native American use of affected fisheries, the 

value of an improvement can sometimes be inferred from settlements in legal cases (e.g., compensation 

agreements between affected tribes and various government or other institutions in cases of resource 

acquisitions or resource use restrictions). For more-general populations, the value of improved 

subsistence fisheries may be estimated from the costs saved in acquiring alternative food sources 

(assuming the meals are replaced rather than foregone). This method may underestimate the value of a 

subsistence-fishery meal to the extent that the store-bought foods may be less preferred by some 
March 28, 2011 4-6 

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

individuals than consuming a fresh-caught fish. Subsistence-fishery benefits are not included in EPA’s 

benefits regional analyses. Impacts on subsistence fishers may constitute an important environmental 

justice consideration, leading to underestimation of the total benefits of the regulatory options. EPA’s 

analysis of the regulation’s impacts on low-income populations and subsistence fishers is presented in 

Chapter 9 of the Economic Analysis of the Proposed 316(b) Regulation. 

4.2.4 Benefits from Improved Protection to T&E Species 

T&E and other special status species can be adversely affected in several ways by CWISs. T&E species 

can suffer direct harm from I&E mortality; they can suffer indirect impacts if I&E mortality at CWISs 

adversely affects another species upon which the T&E species relies within the aquatic ecosystem (e.g., as 

a food source); or they can suffer impacts if the CWIS disrupts their critical habitat (e.g., via thermal 

discharges). The loss of individuals of listed species from CWISs is particularly important because, by 

definition, these species are already rare and at risk of irreversible decline because of other stressors. 

Benefits from improved protection of T&E species can include both direct and indirect nonmarket use 

values, as well as nonuse values. EPA identified nine special status fish species, six in California and 

three in the Inland region, for which I&E mortality data were available. Due to their special status as well 

as the fact that most of these species have either very limited or no direct uses, the major portion of the 

values for T&E species are nonuse values. However, some of these species have potentially significant 

recreational and commercial use values (e.g., sturgeon and paddlefish). EPA applied benefit transfer to 

estimate recreational use values for a subset of T&E species for which limited catch and release fisheries 

exist. EPA did not estimate potential commercial use values of these species due to the lack of market 

data. 

Chapter 5 of this report provides more detail on EPA’s analysis of T&E species benefits from reducing 

I&E mortality at in-scope facilities’ cooling water intakes. 

4.3 Nonuse Benefits from Reduced I&E Mortality 

Comprehensive estimates of total resource value include both use and nonuse values, such that the 

resulting total value estimates may be compared to total social cost. Recent economic literature provides 

substantial support for the hypothesis that nonuse values, such as option and existence values, are greater 

than zero. In fact, small per capita nonuse values held by a substantial fraction of the population can be 

very large in the aggregate. “Nonuse values, like use values, have their basis in the theory of individual 

preferences and the measurement of welfare changes. According to theory, use values and nonuse values 

are additive” (Freeman III 1993).10 Consequently, both EPA’s own Guidelines for Preparing Economic 

Analysis and OMB’s Circular A-4, governing Regulatory Analysis, support the need to assess nonuse 

values (USEPA 2000a; USOMB 2003). Excluding nonuse values from consideration is likely to 

substantially understate total social values. 

Reducing I&E mortality of fish and shellfish may result in both use and nonuse benefits. Of the 

organisms that are anticipated to be protected by the regulatory options for the Section 316(b) regulation 

for in-scope facilities, only a tiny fraction will eventually be harvested by commercial and recreational 

fishers and therefore can be valued with direct use valuation techniques. Unharvested fish, which were 

not assigned direct use value in this analysis, constitute the majority—97 percent—of the total loss, as 

 

10 This additive property holds under traditional conditions related to resource levels and prices for substitute goods in the 

household production model (Freeman III 1993). 
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Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

summarized in Table 4-2 which reports total I&E mortality losses and reduction in I&E mortality losses 

by four loss categories: all species, forage species, total commercial and recreational species, harvested 

commercial and recreational species. Although unlanded forage fish contribute to the yield of harvested 

fish and therefore have an indirect use value that is captured by the direct use value of the commercial 

species, this indirect use value represents only a portion of the total value of unlanded fish. Society also 

values both landed and unlanded fish for reasons unrelated to their use value—for example, individual 

welfare may be affected simply by knowing these fish exist. Additionally, nonuse values are likely to be 

substantial because fish and other species found within aquatic habitats impacted directly and indirectly 

by CWISs provide other valuable ecosystem goods and services. These include nutrient cycling and 

ecosystem stability. Therefore, a comprehensive estimate of the welfare gain from reducing I&E mortality 

must include an estimate of nonuse benefits. 

In contrast to direct and indirect use values, nonuse values are often considered more difficult to estimate. 

Stated preference methods, or benefit transfer based on stated preference studies, are the generally 

accepted techniques for estimating these values (USEPA 2000a; USOMB 2003). Stated preference 

methods rely on carefully designed surveys, which either (1) ask people about their WTP for particular 

ecological improvements, such as increased protection of aquatic species or habitats with particular 

attributes, or (2) ask people to choose between competing hypothetical “packages” of ecological 

improvements and household cost where their choice implies a WTP value. In either case, values are 

estimated by statistical analysis of survey responses. 

Table 4-2: Summary of Baseline National I&E Mortality Losses and Reductions in 

I&E Mortality Losses, by Regulatory Option 

IM&EM Loss Metric (per year) Option 1 Option 2 Option 3

All Species (million A1E) 2188.92 614.97 1981.55 2013.55

Forage Species (million A1E) 1654.78 525.66 1512.64 1535.44

Commercial & Recreational Species (million A1E) 534.15 89.31 468.91 478.11

Commercial & Recreational Harvest (million fish) 59.41 15.66 53.28 54.05

A1E Losses with Direct Use Value (%) 2.71 2.55 2.69 2.68

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for 

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Baseline Reductions in Losses

Losses

Nonuse values may be more difficult to assess than use values for several reasons. First, nonuse values 

are not associated with easily observable behavior. Second, nonuse values may be held by both users and 

nonusers of a resource. Because nonusers may be less familiar with particular services provided by a 

resource, their values may be different from the nonuse values for users of the same resource. Third, the 

development of a defensible stated preference survey is often a time- and resource-intensive process. 

Fourth, even carefully designed surveys may be subject to certain biases associated with the hypothetical 

nature of survey responses (Mitchell and Carson 1989). Finally, efforts to disaggregate total WTP into its 

use and nonuse components have proved troublesome (Carson et al. 1999). 

Although EPA is not always able to estimate changes in affected resources’ nonuse service values as part 

of regulatory development, an extensive body of environmental economics literature reveals that the 

public holds significant value for service flows from natural resources well beyond those associated with 

direct uses (Boyd et al. 2001; Fischman 2001; Heal et al. 2001; Herman et al. 2001; Ruhl and Gregg 

2001; Salzman et al. 2001; Wainger et al. 2001). Studies have documented public values for the nonuse 
March 28, 2011 4-8 

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

services provided by a variety of natural resources potentially affected by environmental impacts, 

including fish and wildlife (Loomis et al. 2000; Stevens et al. 1991); wetlands (Woodward and Wui 

2001); wilderness (Walsh et al. 1984); critical habitat for T&E species (Hagen et al. 1992; Loomis and 

Ekstrand 1997; Whitehead and Blomquist 1991); shoreline quality (Grigalunas et al. 1988); and beaches, 

shorebirds, and marine mammals (Rowe et al. 1992), among others. However, given EPA’s regulatory 

schedule, developing and implementing stated preference surveys to elicit total value (i.e., nonuse and 

use) of environmental quality changes resulting from environmental regulations is often not feasible.11

Existing stated preference studies suggest that nonuse benefits of aquatic habitat improvements may be 

significant. For example, results from a study of public values of migratory fish restoration projects in 

Rhode Island showed that nonuse motives such as existence and bequest values were rated as “important” 

or “very important” by 62 and 76 percent of survey respondents, respectively. Use motives such as 

commercial and recreational fishing, on the other hand, were rated as “important” or “very important” by 

only 38 and 43 percent of the survey respondents, respectively (Johnston et al. 2009, unpublished data). 

Additional detail regarding Johnston et al. (2009) is provided in Chapter 8, Section 8.3.1. 

Many ecosystems impacted by CWISs provide goods and services that contribute to well-being (see 

Chapter 2), but may be generally unrecognized because of their indirect nature. As such, valuations based 

on stated preferences are unlikely to capture the full complement of ecologically-based services with 

economic value (Costanza and Folke 1997). Despite these limitations, benefit transfers based on stated 

preference studies are the generally accepted techniques for estimating nonuse values. EPA was able to 

identify a single study that could be used to estimates total values (nonuse and use values) for reductions 

in I&E mortality in some regions. Chapter 8 of this report provides more detail on EPA’s quantitative 

analysis of nonuse benefits from reducing I&E mortality at the in-scope facilities’ cooling water intakes. 

 

11 EPA designed a stated preference survey to separately estimate total value (including use and nonuse value) of potential 

aquatic resource improvements that might occur because of the proposed 316(b) regulation. However EPA did not have 

sufficient time to fully develop and deploy this survey and derive reliable quantitative estimates of the monetary value of 

reducing those impacts at the national level. Benefit transfer of values from existing stated preference studies was used by 

EPA in the absence of an original study. For more details on development of the survey, see the Information Collection 

Request entitled “Development of Willingness to Pay Survey Instrument for Section 316(b) Cooling Water Intake 

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

5 Impacts and Benefits on Threatened and Endangered Species 

5.1 Introduction 

Threatened and endangered (T&E) species are species vulnerable to future extinction or at risk of 

extinction in the near future, respectively. These designations may be made because of low or rapidly 

declining population levels, loss of essential habitat, or life history stages that are particularly vulnerable 

to environmental alteration. In addition to T&E labels, the designation “species of concern” includes 

species that warrant special protection due to inherent vulnerabilities to habitat modification, disturbance, 

or other human impacts. Together, these stressors may result in the species becoming threatened or 

endangered in the foreseeable future.12 

The withdrawal of cooling water from streams, rivers, estuaries and coastal marine waters leads to the 

impingement and entrainment (I&E) of a large number of aquatic organisms. For species vulnerable to 

future extinction, impingement and entrainment mortality (I&E mortality) from cooling water intake 

structures (CWISs) may represent a substantial portion of annual reproduction. Consequently, I&E 

mortality may either lengthen recovery time, or hasten the demise of these species. For this reason, the 

population-level and social values of T&E losses are likely to be disproportionately higher than the 

absolute number of losses that occur. 

Adverse effects of CWISs on T&E species may occur in several ways: 

 Populations of T&E species may suffer direct harm as a consequence of I&E mortality. This 

direct loss of individuals may be particularly important because T&E species have severely 

depressed population levels that are approaching local, national, or global extinction. 

 T&E species may suffer indirect harm if the CWIS substantially alters the food web in which 

these species interact. This might occur as a result of altered populations of predator or prey 

species, the removal of foundation species, or (for species with parasitic life history stages) 

the loss of a host species. 

 CWISs may alter habitat that is critical to the long-term survival of T&E species. This might 

occur as a consequence of changes in the thermal characteristics of local waterbodies, altered 

flow regimes, turbidity, or changes in substrate characteristics as a consequence of any of 

these changes (Chapter 2). 

By definition, T&E species are characterized by low population levels. As such, it is unlikely that these 

species will be recorded in I&E mortality monitoring studies due to the logistical limitations of sampling 

and identification effort, time of day, season, and year. For T&E species to be recorded in monitoring 

studies, 1) an individual of a T&E species must be captured by a CWIS during the (often short) sampling 

window, and 2) the organism must be identifiable. Thus, despite the fact that the population impacts of 

I&E mortality on T&E species may be high, they are difficult to ascertain and quantify within a 

framework designed for common, more-abundant species. Thus, EPA identifies spatial overlap between 

CWISs and T&E species to estimate the potential for adverse I&E mortality impacts on T&E species. 

 

12 To simplify the discussion, in this chapter EPA uses the terms “T&E species” and “special status species” interchangeably 

to mean all species that are specifically listed as threatened or endangered, plus other species with special status designation 

at the state or federal level. 
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Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

From an economic perspective, T&E species affected by CWISs may have both use and nonuse values. 

However, despite the existence of T&E species with potentially high use values (e.g., Pacific Salmonids), 

the majority of T&E species affected by I&E mortality are obscure, relatively unknown, and may not 

have any direct uses (e.g., delta smelt). Given the protected nature of T&E species and the fact that the 

majority of T&E species do not have direct uses, the majority of the economic value for T&E species 

must come from nonuse values. Strictly speaking, species-specific estimates of nonuse values held for the 

protection of T&E species can be derived only by primary research using stated preference techniques. 

However, the cost, administrative burden, and time required to develop primary research estimates to 

value effects of the 316(b) regulation on T&E species are beyond the schedule and resources available to 

EPA for this rulemaking. As an alternative, EPA considered a benefit transfer approach that relies on 

information from existing studies (USEPA 2000a). 

EPA was able to use a benefit transfer approach to estimate changes in recreational use values for a subset 

of T&E species that are highly valued by recreational anglers (i.e., paddlefish13 and sturgeon). 

Commercial and nonuse values are not monetized for any of the affected species. Therefore, benefit 

estimates presented in this chapter are incomplete and likely to be highly conservative (i.e., low). 

In this chapter, EPA explores the extent to which CWISs may affect species protected by the Endangered 

Species Act on national and regional scales (Section 5.2), documents the value society places on the 

protection of T&E species (Section 5.3), and applies economic valuation studies of T&E species to case 

studies of sea turtles and finfish in the Inland region (Section 5.4). 

5.2 T&E Species Affected by CWISs 

To assess the potential impacts of CWISs on T&E species, EPA constructed a database that identifies 

spatial overlap between CWISs and vulnerable life history stages of all aquatic T&E species for which 

data are available. The database allowed EPA to estimate the potential for adverse I&E mortality impacts 

on T&E species. 

5.2.1 T&E Species Identification and Data Collection 

First, all species currently listed or in consideration for listing under the Endangered Species Act (as of 

January 16, 2010) with aquatic life history stages were identified using the US Fish and Wildlife Service 

Environmental Conservation Online System (USFWS 2010b). This primary list of all T&E species was 

filtered to include only species with life history stages vulnerable to CWIS mortality according to life 

history data. Examples of vulnerable stages include planktonic egg stages, free-swimming larval stages, 

and adult life history stages that occur near shore. Life history data used to exclude species from further 

consideration was obtained from a wide variety of sources (AFSC 2010; ASMFC 2010; Froese and Pauly 

2009; NatureServe 2009; NEFSC 2010; PIFSC 2010a; PIFSC 2010b; SEFSC 2010; SWFSC 2010; 

USFWS 2010b). After filtering by life history data, the list of T&E species potentially affected by I&E 

mortality contained 247 species. 

Whenever possible, the geographical distribution of T&E species susceptible to I&E mortality was 

obtained in geographic information system (GIS) format as polygon (shape) files, line files (for 

 

13 Note: the American Paddlefish is listed on T&E species lists for many states, but is not currently protected nationally under the 

US Endangered Species Act. A review of the species’ status in 1992 revealed that although the species did not then meet the 

requirements to be listed as threatened at the federal level, the US Fish and Wildlife Service expressed its concern for the future 

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

inhabitants of small creeks and rivers) and as a subset of geodatabase files. Data sources include the US 

Fish and Wildlife Service (USFWS 2010a), NOAA’s Office of Response and Restoration (NOAA 

2010a), NatureServe (NatureServe 2009), and NOAA NMFS (NMFS 2010b; NMFS 2010c; NMFS 

2010d). For several freshwater species, geographic ranges were available only as 6-digit hydrologic unit 

codes (HUC) (NatureServe 2009; USFWS 2010a). For these species, GIS data layers were generated 

using a GIS HUC database obtained from the USGS (Steeves and Nebert 1994). For several species, no 

GIS data could be acquired. For these species, species distribution descriptions were compared with 

mapped CWISs, and inspected for geographic overlap. In all such cases (e.g., the “inarticulated 

brachiopod,” Lingula reevii, endemic to Kaneohe Bay, HI) there were no in-scope CWISs within 10 

kilometers, and further inspection was not warranted. 

5.2.2 Number of T&E Species Affected per Facility 

To investigate the potential for individual facilities to affect a wide variety of T&E species, EPA 

calculated the number of T&E species affected on a per-facility basis. This calculation allowed EPA to 

assess the magnitude of differences between regions of CWIS effects on T&E species. 

Nationally, 88 of the 247 aquatic T&E species assessed or 36 percent had vulnerable life history stages 

that either overlapped with CWISs, or had records of entrainment or impingement mortality (Appendix 

E). These species overlapped with 446 of 871 in-scope facilities (51 percent). Among facilities, the 

variability in the number of T&E species potentially affected ranges between 0 and 26 species (Table 

5-1), with more than 90 percent of facilities affecting fewer than 5 T&E species, and more than 99 percent 

of facilities affecting fewer than 12 species (Figure 5-1). 

Excluding facilities whose CWISs do not overlap with at least one T&E species, the average number of 

species per facility is 3.89 (minimum 0, maximum 26) (Table 5-1). Sea turtles and freshwater mussels had 

the highest overlap rate on a per-facility basis, averaging 4.83 and 3.53 species per facility, respectively. 

Anadromous, freshwater, and marine fish had lower overlap rates with facility CWISs, averaging slightly 

higher than 1 species per interacting facility (Table 5-1). 

Driven by the high number of I&E mortality freshwater mussels overlapping with facility CWISs, the 

majority of all species by facility interactions occur in the inland region. However, the shape of 

cumulative distribution plots is similar among regions after accounting for sample size, suggesting that 

the overall probability of a facility affecting one or more T&E is not a function of geographic region 

(Figure 5-2). 
March 28, 2011 5-4 

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

Table 5-1: Number of T&E Species with Geographical Distributions Overlapping Inscope CWISs, on a Per-facility Basis 

Subset of Affected Species1 # Species Avg Max Avg Max

All T&E Species 88 1.99 26 3.89 26

T&E Freshwater Mussels 43 1.14 22 3.53 22

T&E Sea Turtles 6 4.83 5 4.83 5

T&E Anadromous Fish 13 0.13 3 1.08 3

Other T&E Freshwater Fish 21 0.09 4 1.33 4

Other T&E Marine Fish 3 0.13 2 1.42 2

1

 T&E species included species of concern and species under review for listing by the US Fish and Wildlife Service 

(freshwater) or NOAA National Marine Fisheries Service (marine). Only species overlapping with a minimum of one CWIS 

are included. 

2

 Interacting Facilities = all facilities with CWIS inside the range of at least one T&E species

3

 Avg = average, Max = maximum

All Facilities Interacting Facilities2

T&E Species per Facility3

 

Figure 5-1: Empirical cumulative distribution function plot of the number of T&E species 

potentially affected on a per-facility basis by in-scope facilities nationwide. 
March 28, 2011 5-5 

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

Figure 5-2: Cumulative distribution plot of the number of T&E species potentially affected on a 

per-facility basis by in-scope facilities nationwide. Sample sizes (i.e., number of in-scope facilities) 

are noted in parentheses. The horizontal axis is equivalent in all plots, with the exception of the 

Inland region (noted with an asterisk *). 

5.2.3 Number of Facilities Affecting Individual T&E Species 

To investigate the cumulative potential for CWISs to affect individual T&E species, EPA calculated the 

number of facilities affecting each T&E species. There are 1,734 examples of species by facility 

interactions across 88 T&E species nationally, resulting in an average of 19.7 facilities per species (Table 

5-2). Consequently, many T&E species are likely to be affected by a large number of facilities. Thus, 

even if individual facilities have low I&E mortality of T&E species, the cumulative effect of in-scope 

316(b) facilities on these populations may be substantial. The variation among species was large and 

ranged between 1 and 135 facilities per species (Table 5-2). Overall, 19 percent of species are affected by 

1 facility, 50 percent of species affected by fewer than 6 facilities, 80 percent of species affected by fewer 

than 24 facilities, and 90 percent affected by fewer than 44 facilities (Figure 5-3). 
March 28, 2011 5-6 

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

Table 5-2: Number of Facilities with CWISs Within the Geographical 

Distribution of T&E Species, on a Per-species Basis 

Subset of Affected Species1,2 Species Interactions Avg Max

All T&E Species 88 1734 19.70 135

T&E Sea Turtles 6 652 108.67 135

T&E Freshwater Mussels 43 836 19.44 85

T&E Anadromous Fish 13 115 8.85 64

Other T&E Freshwater Fish 21 64 3.05 7

Other T&E Marine Fish 3 17 5.67 11

1

 T&E species included species of concern and species under review for listing by the US Fish and Wildlife 

Service (freshwater) or NOAA National Marine Fisheries Service (marine). Only species overlapping with a 

minimum of one CWIS are included. 

2 Two species of coral are included in the 'All Species' category, and not in any subcategory

3

 Avg = average, SD = standard deviation, Med = median, Max = maximum

Facilities per T&E Species3

When species were analyzed within life history trait, sea turtles had the highest average number of 

overlapping facilities (108.7) (Table 5-2), a value skewed by these species’ extensive ranges (i.e., entire 

Atlantic, Gulf of Mexico, and/or Pacific coast), and the potential for I&E mortality impacts at all life 

stages. The six sea turtle species examined were the six species with the highest number of overlapping 

CWISs. Following sea turtles, freshwater mussels had the highest average number of overlapping 

facilities (19.4 facilities per species). Excepting turtles, freshwater mussels accounted for 9 of the top 10 

species sorted by the count of CWISs affecting them (Figure 5-4). Following freshwater mussels, 

anadromous fish species were most likely to be affected, with an average of 8.9 facilities per species 

(Table 5-2). This average, however, is highly skewed by a single species of fish (the pallid sturgeon, 

Figure 5-3: Empirical cumulative distribution function plot of the number of facilities that 

overlap geographically with vulnerable life history stages of T&E species. Species represented 

on the plot are those that overlap with a minimum of one in-scope facility. Sample size is 88. 
March 28, 2011 5-7 

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

Scaphirhynchus albus) which accounted for 54 percent of all overlap between facilities and anadromous 

fish species (Figure 5-4). Excepting the pallid sturgeon, anadromous fish had a similar level of potential 

exposure to I&E mortality as non-diadromous fish: freshwater and marine fish species averaged 

approximately 3.5 facilities with potential I&E mortality per species (Table 5-2, Figure 5-4). In addition 

to finfish and shellfish, elkhorn and staghorn corals (Acropora palmata and A. cervicornis) also have the 

potential for I&E mortality impacts: both species have the potential to be affected by 25 facilities. 

5.2.4 Summary of Overlap Between Cooling Water Intake Structures and T&E Species 

Nationally, 36 percent of T&E species assessed have vulnerable life history stages that overlap with a 

minimum of one CWIS (Table 5-1), suggesting a high probability of T&E populations’ being affected by 

I&E mortality. The potential for these impacts is widespread: T&E species overlap CWISs in all 

geographical regions of the country (Figure 5-2), in all waterbody types, and across multiple life histories 

(Figure 5-4). Overall, 51 percent of in-scope facilities overlap with at least one T&E species (Table 5-1), 

while 36 percent of aquatic endangered species overlap with at least one CWIS. Finally, our analysis 

includes only federally listed T&E species. Thus, the number of T&E species (including those species 

defined as threatened or endangered under state law) affected by I&E mortality is understated. 

Figure 5-4: Cumulative distribution plots of the number of facilities likely to affect individual 

threatened or endangered species, grouped by species life history trait. Sample sizes (species 

per life history trait) are in parentheses, and represent those species potentially affected by a 

minimum of one in-scope facility. 
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Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

5.2.5 Species with Documented I&E Mortality 

EPA identified several T&E species with documented I&E mortality (Table 5-3). In addition to 

documented instances of T&E mortality, EPA identified I&E mortality not identified to species but whose 

genus matched T&E species overlapping with the reporting facility’s CWIS (Table 5-3). Although these 

are not confirmed I&E mortality of T&E species, they provide evidence that additional T&E species are 

likely to be directly affected by I&E mortality. 

Including only individuals identified to species, EPA identified more than 130,000 baseline losses of 

T&E species (Table 5-3). However, for several reasons, T&E species suffering I&E mortality are likely to 

be underreported. First, T&E species are found at low population densities, and the volume of water 

sampled by facility-level impingement and entrainment studies is low. Thus, it is likely that many T&E 

species suffered I&E mortality outside of sampling periods and are never recorded. Second, because a 

high proportion of all I&E mortality occur during early life history stages (i.e., egg, larvae) when species 

identification is more challenging, T&E species may not be recognized during sampling (e.g., endangered 

species of darter, including the Cherokee and duskytail darters, may be reported as “darter,” or 

“unidentified darter”). 

5.3 Societal Values for Preservation of T&E Species Affected by I&E Mortality 

This section examines governmental spending, policy decisions, and private donations on the preservation 

and restoration of T&E species. It provides evidence of societal preferences for T&E preservation and 

spending related to ensuring sustainability of T&E species. 

The U.S. Fish and Wildlife Service (FWS) annually reports expenditures for the conservation of T&E 

species. Using the report for fiscal year 2008 (USFWS 2009) EPA calculated total government (federal 

and state) expenditures for the 88 federally listed T&E species with vulnerable life history stages that 

overlap CWISs (Table 5-4). Excluding expenditures on T&E species not subject to I&E mortality, 

expenditures on T&E species potentially affected by CWISs exceeded $465 million, and accounted for 86 

percent of all governmental spending on Fish, Marine Reptiles, Crustaceans, Corals and Clams listed 

under the Endangered Species Act (ESA) during FY 2008 (USFWS 2009). 

In addition to direct governmental spending associated with the protection of T&E species that overlap 

with CWISs, the presence of these species often guides policy discussions, and may require the 

installation of abatement technologies that reduce T&E species mortality and allow these species to 

migrate. For example, the life history of the American paddlefish (Polyodon spathula) (listed on many 

state T&E species lists, but not protected under the ESA) is occasionally discussed during Federal Energy 

Regulatory Commission relicensing of dams, because of the animal’s highly migratory life history. In the 

Wisconsin River, for example, Alliant Energy has been required to install a multi-million dollar fishway 

at the Prairie du Sac dam, primarily to allow the passage of paddlefish and lake sturgeon (WPLC v. FERC 

2004). 
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Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 5-3: T&E species with documented I&E mortality. Species are separated by the taxonomic 

resolution reported for the I&E mortality loss. 

Resolution Common Name Latin Name Baseline I&E Mortality 

Species Atlantic Salmon Salmo salar Qualitative 

Chinook Salmon Oncorhynchus tshawytscha 5,470b

 

Coho Salmon Oncorhynchus kisutch Qualitative 

Delta Smelt Hypomesus transpacificus 62,526b 

Green Sea Turtle Chelonia mydas Qualitative 

Hawksbill Sea Turtle Eretmochelys imbricata Qualitative 

Kemp's Ridley Sea Turtle Lepidochelys kempii Qualitative 

Leatherback Sea Turtle Dermochelys coriacea Qualitative 

Loggerhead Sea Turtle Caretta caretta 5-50b

Longfin Smelt Spirinchus thaleichthysa 24,919b

 

Olive Ridley Sea Turtle Lepidochelys olivacea Qualitative 

Pallid Sturgeon Scaphirhynchus albus 50 

Sacramento Splittail Pogonichthy macrolepidotusa 45,188b 

Steelhead Trout Oncorhynchus mykiss 5b

 Topeka Shiner Notropis Topeka 15b

Genus Alabama Sturgeon Scaphirhynchus suttkusi 8,174b

Atlantic Sturgeon Acipenser oxyrinchus oxyrinchus 785,667 

Blackside Dace Phoxinus cumberlandensis 10b

Blue Shiner Cyprinella caerulea 94,608,786 

Boulder Darter Etheostoma wapiti 3,529,746 

Cherokee Darter Etheostoma scotti 3,529,746 

Chum Salmon Oncorhynchus keta 22 

Duskytail Darter Etheostoma percnurum 3,529,746 

Etowah Darter Etheostoma etowahae 3,529,746 

Green Sturgeon Acipenser medirostris 785,667 

Gulf Sturgeon Acipenser oxyrinchus desotoi 785,667 

Neosho Madtom Noturus placidus 41,021b

Palezone Shiner Notropis albizonatus 19,421,686b

Pygmy Madtom Noturus stanauli 41,021b

Scioto Madtom Noturus trautmani 41,021b

Shortnose Sturgeon Acipenser brevirostrum 785,667 

Snail Darter Percina tanasi 259,500b

 Unarmored Threespine Stickleback Gasterosteus aculeatus williamsoni 2,922b

Notes: Species listed as threatened or endangered under state laws, such as the American Paddlefish (Polyodon spathula), are not 

included in this list. 

"Qualitative" indicates the species is reported by name from a minimum of one facility, but no loss estimates are provided. 

Baseline losses reported for genera reflect losses for all species within the genus. Losses are likely dominated by more-common

congeners.

a This species is under review for listing under the Endangered Species Act b

 This estimate is not derived using extrapolation procedures 
March 28, 2011 5-10 

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

Considerations for T&E species have also been responsible for changes in water diversions on the San 

Joaquin-Sacramento River delta, limiting water for downstream users. Under current regulations, the 

volume of water removed from the San-Joaquin-Sacramento River at the Banks Pumping Plant is limited 

from December to June, to protect Delta Smelt (NRDC v. Kempthorne 2007). This restriction limits the 

volume of water available for consumption as drinking water and for use in large-scale irrigation projects. 

Water restrictions, due to the potential for negative effects on Delta Smelt populations, have been 

estimated to result in the loss of 21,100 farm-related jobs and $703 million in agricultural revenue in 2009 

alone (Boxall 2010; Howitt et al. 2009).14

Although government spending and policy decisions made to protect or enhance stocks of T&E species 

are not direct indications of economic benefits, they indicate that society does place a significant value on 

protecting and restoring species of concern. 

5.4 Assessment of Benefits to T&E Species 

5.4.1 Economic Valuation Methods 

For several reasons, it is difficult to estimate the benefits of preserving T&E species by reducing I&E 

mortality. First, the contribution to ecosystem stability, ecosystem function, and life history remain 

relatively unknown for many T&E species. Second, because much of the wildlife economic literature 

focuses on commercial and recreational benefits that are not relevant for many protected species (i.e., use 

values), there is a paucity of economic data focused on the benefits of preserving T&E species. 

Consequently, nonuse values comprise the principal source of benefit estimates for most T&E species. 

To obtain an accurate estimate of the nonuse values of T&E species affected by I&E mortality, 1) 

quantitative I&E mortality impacts, and the benefits of policy options, must be estimated for T&E 

species; and 2) an economic value must be obtained for the value of reducing I&E mortality as a 

consequence of increased population sizes, extinction avoidance, and, for certain species (e.g., 

Salmonids), the potential for re-establishment of a commercial fishery. 

 

14 Water diversion in the San Joaquin-Sacramento River is currently undergoing active litigation. See San Luis & Delta-Mendota 

Water Authority, et al. v. Salazar, et al., USDC Case No. 1:09-CV-407 OWW GSA, and consolidated cases. 

Table 5-4: Federal and State Expenditures for T&E 

Species Overlapping with CWIS 

Life History 

Expenditure 

(2009$, millions) 

Anadromous Fish $ 383.2 

Corals $ 0.3 

Freshwater Fish $ 44.4 

Freshwater Mussels $ 5.6 

Marine and Estuarine Fish $ 0.2 

Sea Turtles $ 33.9 

All Species Overlapping CWIS $ 467.6 

All Fish, Marine Reptile, Crustacean, 

Coral, and Clam Species $ 541.7 
March 28, 2011 5-11 

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

Benefit transfer involves extrapolating existing estimates of nonmarket values to geographic locations or 

species that differ from the original analytical situation. Thus, the approach transfers estimates of values 

for preserving T&E species in one region to another region, or to a similar species. Ideally, the resource 

(i.e. species), policy variable (e.g., change in species status, recovery interval, population size, etc.), and 

the benefitting population (i.e., defined human population) are identical. Such a match rarely occurs. 

Despite discrepancies in these variables, however, a benefits transfer approach can provide useful insights 

into the social benefits gained by reducing I&E mortality of T&E species.15 

5.4.2 Case Studies 

EPA attempted to estimate the benefits of regulation for all T&E species with documented and quantified 

losses at CWIS. In most cases, EPA was unable to locate or calculate key components of the analysis 

necessary to apply a benefits transfer approach. However, EPA was able to obtain sufficient data to 

estimate the economic benefits to two categories of T&E species: a subset of T&E fish species in the 

inland region, and loggerhead sea turtles. The case studies of potential economic benefits from a decrease 

in T&E mortality are discussed below. 

5.4.2.1 Inland Region 

Baseline Losses of Special Status Species and Reductions in Losses Due to Regulatory Options 

EPA estimated losses for three T&E species in the Inland region: pallid sturgeon, American paddlefish, 

and Topeka shiner. However, sufficient data were available to estimate the benefits of regulation for only 

the pallid sturgeon (Scaphirhynchus albus), and the American paddlefish (Polyodon spathula). As such, 

benefits estimates address only 80–84 percent of documented T&E A1E losses in the Inland region (Table 

5-5). 

The pallid sturgeon is listed as an endangered species under the ESA; the American paddlefish is not 

listed federally. In the early 1990s, the U.S. FWS conducted a review of the paddlefish for threatened 

status, but ultimately did not list the species (Allardyce 1991). However, the review noted that immediate 

efforts were needed to restore stocks and degraded habitats (Allardyce 1991). Although not currently 

protected federally, paddlefish are protected by 11 states. 

The American paddlefish is a large (85 inches length and more than 220 lbs) species with roe suitable for 

caviar. The species once supported a large commercial fishery in the Mississippi Valley, and currently 

supports a limited recreational fishery in some states. Likewise, the pallid sturgeon is one of the largest 

(30-60 inches) fishe found in the Missouri-Mississippi River drainage, with specimens weighing up to 85 

pounds. Because their large size makes them a desirable commercial and trophy sport fish, and because 

they have roe suitable for caviar, both pallid sturgeon and American paddlefish have potentially 

significant direct use values. All extractive uses of the pallid sturgeon, however, are prohibited under the 

ESA. 

To estimate total baseline losses due to I&E mortality, EPA used the EAM to model A1Es for each of the 

three T&E species (Chapter 3).16 The choice of facilities used to extrapolate I&E mortality from model 

facilities was based on species’ historic ranges and current distributions. In addition to baseline estimates 

of I&E mortality for pallid sturgeon, paddlefish, and Topeka shiner, EPA calculated reductions in losses 

under three regulatory options (Table 5-5). 

 

15 Types of benefit transfer studies are discussed at length in U.S. EPA (2000a). 

16 Paddlefish and pallid sturgeon losses were observed at nine and two model facilities, respectively. 
March 28, 2011 5-12 

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

Table 5-5: Annual Baseline I&E Mortality and Reductions in Baseline I&E Mortality 

of T&E Species at In-scope Facilities in the Inland Region, by Regulatory Option 

(A1E) 

Species Value Type Baselinea Option 1 Option 2 Option 3

Pallid Sturgeon Nonuse 17,628 8,631 15,946 16,317 

Paddlefish Use and Nonuse 88 73 85 86 

Topeka Shiner Nonuse 3,669 3,069 3,546 3,581 

Total 21,384 11,773 19,577 19,984 

a

 The I&E mortality data used to develop regional estimates are from sampling at the Wabash and Cayuga facilities in 

1976, the only year of sampling data for these facilities.

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for 

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere.

Benefit Transfer Approach: Estimated WTP for Protection of Inland T&E Species 

A Nonuse Values 

EPA identified two studies that estimated both nonuse and use values for sturgeon. One study found that 

citizens of Maine are willing to pay $37.02 (2009$) as a one-time tax to create a self-sustaining 

population of shortnose sturgeon (Kotchen and Reiling 2000), a species listed as endangered under the 

ESA (NMFS 2004). A separate study found that lake sturgeon is a popular wildlife-viewing species in 

Wisconsin, and that viewers place a substantial value on protection of lake sturgeon populations. The 

average viewer’s WTP to maintain the current sturgeon population of Wisconsin’s Lake Winnebago 

system was $121.30 (2009$). Since the estimated number of sturgeon viewers in 2002 was 3,176 

individuals, total WTP for sturgeon-viewing opportunities in the Winnebago system was $0.39 million 

(2009$). Together, the results of these studies indicate that nonuse values for preservation of sturgeon are 

likely to be significant. However, EPA was unable to monetize total nonuse benefits from reduced I&E 

mortality, because reliable population estimates needed to transfer the values were unavailable. 

B Use Values 

Pallid sturgeon and paddlefish have potentially high commercial use values as sources of roe. This value 

has increased dramatically owing to the collapse of Caspian Sea sturgeon populations (Speer et al. 2000). 

Paddlefish roe have been reported to sell for more than $300 per pound, and as much as 3 lbs of roe may 

be harvested from a large female (McKean 2007). Despite these reports, EPA was unable to reliably 

quantify total commercial values for these species due to a lack of market data. 

Recreational use values for sturgeon and paddlefish caught in inland waters or paddlefish were not 

available. Based on a review of literature describing these species, EPA determined that sturgeon species 

(including white, green, and pallid sturgeons) and paddlefish share many characteristics, including roe 

suitable for caviar, and their value as game fish. Consequently, WTP values for sturgeon obtained in 

California were used to value recreational use of these species in the Inland region. A limited recreational 

fishery (mostly catch and release) exists for paddlefish in several states; although harvesting pallid 

sturgeon is illegal, the species is sometimes caught by recreational anglers. 

To estimate recreational use values for paddlefish and pallid sturgeon, EPA applied estimates from a 

random utility model (RUM) analysis conducted to evaluate recreational fishing benefits of the 2004 

Section 316(b) Phase II Final Rule. Model results indicate that California anglers were willing to pay 
March 28, 2011 5-13 

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

$69.88 (2009$) to catch a sturgeon (USEPA 2004b), a value transferred to anglers for pallid sturgeon and 

paddlefish in the Inland region (Table 5-6).17

The undiscounted recreational use value from eliminating baseline I&E mortality is approximately $1,238 

thousand, while use values from reducing pallid sturgeon and paddlefish I&E mortality range from $608 

thousand to $1,146 thousand for the three regulatory options considered. Annualized benefits range from 

$498 to $719 thousand at a 3 percent discount rate, and from $454 to $561 thousand at a 7 percent 

discount rate. EPA notes that these value estimates underestimate total values of reducing I&E mortality 

to T&E species in the Inland region, because both nonuse and commercial values, likely to be substantial, 

are not incorporated. 

Table 5-6: Estimated Annual WTP for Eliminating or Reducing I&E Mortality of Special 

Status Fish Species at In-scope Facilities in the Inland Region, by Regulatory Option 

(2009$) 

Baseline Option 1 Option 2 Option 3

Pallid Sturgeon $1,231.8 $603.1 $1,114.3 $1,140.3

Paddlefish $6.1 $5.1 $5.9 $6.0

Total Undiscounted $1,238.0 $608.2 $1,120.2 $1,146.2

Annualized Value $1,144.3 $498.0 $719.0 $717.8

Annualized Value $1,140.0 $454.3 $560.7 $549.7

a

 The I&E mortality data used to develop regional estimates are from sampling at the Wabash and Cayuga facilities in 1976, 

the only year of sampling data for these facilities.

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities 

> 125 MGD; Option 3 = I&E Mortality Everywhere.

3% Discount Rate

7% Discount Rate

T&E Species

Annual Benefits (2009$, thousands)

5.4.2.2 Potential Nonuse Values for T&E Species in the Inland Region 

To illustrate the potential magnitude of nonuse values for T&E species affected by I&E mortality in the 

Inland region, EPA applied a WTP meta-analytical model (Richardson and Loomis 2009) to hypothetical 

scenarios. Because EPA does not currently have region-wide I&E mortality for all T&E species, nor 

population models to estimate the effect of I&E mortality on population size, estimates are presented only 

to assess the range of benefits potentially resulting from 316(b) regulatory options. The modeled 

scenarios estimate the WTP for 0.25 percent and 0.5 percent increases for all T&E fish populations in the 

Inland region. 

EPA estimated nonuse values using benefit transfer according to Richard and Loomis (2009) (details in 

Appendix F, Section F.3). Excepting all policy-relevant variables, EPA used the mean values for all 

model parameters, and converted estimates to 2009$ using the Consumer Price Index (USBLS 2010). 

For a 0.25 percent change in T&E fish population size, projected WTP per household per year is $1.02 

(2009$). With 59.6 million households18, total WTP for T&E fish in the Inland region is $60.31 million. 

 

17 The Phase II analysis did not estimating WTP for catching a sturgeon in other states. Given similarity in species characteristics 

EPA used WTP for sturgeon caught in California to value sturgeon and paddlefish species in the Inland region. 

18 Household number in the Inland region is calculated for states where at least T&E species affected by I&E mortality is 

found. 
March 28, 2011 5-14 

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

For a 0.5 percent change in T&E fish populations, WTP per household is $1.85 per year, resulting in 

WTP values of $110.25 million in the Inland region (all values 2009$). 

5.4.2.3 Sea Turtles 

Six species of sea turtles are found in U.S. waters: green (Chelonia mydas), hawksbill (Eretmochelys 

imbricata), Kemp's Ridley (Lepidochelys kempii), leatherback (Dermochelys coriacea), loggerhead 

(Caretta caretta), and Olive Ridley (Lepidochelys olivacea) sea turtles. All have extensive ranges, migrate 

long distances during their lifetime, and are listed as either threatened or endangered (T&E) under the 

ESA. Because of these large ranges, there is substantial overlap between sea turtle habitat and CWISs for 

in-phase power generating and manufacturing facilities. Additionally, since individuals of all ages and 

sizes are susceptible to impingement and entrainment (Norem 2005), there are more than 730 potential 

species x CWIS interactions that may result in the injury or death of these T&E species (Table 5-1, details 

in Appendix Section F.1). 

Evidence for Public Values for Sea Turtles 

In addition to research sponsored by the National Science Foundation and various private philanthropic 

organizations, federal and state governmental spending on sea turtle protection under the ESA totaled 

$33.8 million in FY2008 (Table 5-4). Moreover, there are dozens of academic, nonprofit, and ecotourism 

organizations that recruit thousands of volunteers every year to participate in sea turtle conservation and 

research projects (Appendix Table F-2). Volunteers are often required to undergo substantial training at 

their own expense and commit to long hours (often during the night). For example, the nonprofit group 

Earthwatch matches volunteers with academic researchers working at field stations around the world. By 

paying to spend time working with scientists on research projects, volunteers support sea turtle research 

and conservation both financially and logistically, working to gain first-hand experience of conservation 

issues. Trips may last from days to several weeks, and often require a commitment of 10 or more hours 

work per day. For example, on one 10-day volunteer trip with a cost of $2,450 (plus airfare), volunteers 

spend time tagging, measuring, and weighing leatherback seat turtles in Trinidad, patrolling beaches from 

sundown to the early hours of the morning (Earthwatch Institute 2010). 

Baseline Losses of Special Status Species and Reductions in Losses Due to Regulatory Options 

There are several passive-use (e.g., wildlife viewing and photography) and nonuse values associated with 

U.S. sea turtle populations. Many households express passive use value by participating in ecotourism 

activities, such as visiting sea turtle nesting areas, or by participating in sea turtle conservation activities 

(Frazer 2005). Additionally, a high proportion of governmental expenditures on T&E species are for turtle 

species (Table 5-4), suggesting that the public values the preservation of sea turtle populations. 

Power plants are known to entrain and impinge all six species of sea turtles found in U.S. waters (Norem 

2005), with more than 730 occurrences of overlap between species ranges and CWISs (Table 5-1). 

Incidences of mortality have been reported at facilities in California, Texas, Florida, South Carolina, 

North Carolina, and New Jersey (National Research Council 1990; Plotkin 1995). These facilities span a 

wide range of intake flows (fewer than 30 to more than 1,400 million gallons per day average intake 

flow), suggesting that sea turtle mortality is not limited to large intakes. Although quantitative reports are 

available from a few power stations, high-quality data is available from only one source, the St. Lucie 

Nuclear Power Plant, at Hutchinson Island, FL, where annual capture rates range from 350 to 1,000 

turtles (Appendix Table F-1). Despite the fact that mortality rates due to entrainment are estimated to be < 

3 percent, approximately 85 percent of entrained organisms show evidence of injury as a result of 

entrainment (Norem 2005). As such, true mortality rates from CWISs may be higher than reported, 
March 28, 2011 5-15 

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

particularly for individuals who are recaptured repeatedly (37 percent of green and 13 percent of 

loggerhead sea turtles entrained between May and December 2000 were recaptured individuals) (Norem 

2005). 

Although the magnitude of I&E mortality is believed to be small relative to fishing-related mortality, the 

cumulative impact of I&E mortality is unclear. The only study presenting a quantitative estimate of 

annual I&E mortality estimated mortality rates to be between 5 and 50 individuals per year (Plotkin 

1995). Consequently, EPA does not believe sufficient data exist to estimate baseline sea turtle mortality 

due to entrainment and impingement at regional or national scales. However, due to lower population 

sizes, long life-span, and high reproductive potential of adult turtles (Crouse et al. 1987), EPA believes 

the effect of 316(b) regulation is likely to have a small effect on the long-term viability of turtle 

populations. 

Benefit Transfer Approach: Potential WTP for Protection of Sea Turtle Species 

A Per-household WTP 

EPA identified a study that used a stated preference valuation approach to estimate the total economic 

value (i.e., use and nonuse values) of a management program designed to reduce the risk of extinction for 

loggerhead sea turtles (Whitehead 1993). The mail survey asked North Carolina households whether they 

were willing to pay a bid amount for a management program that reduces the probability that loggerhead 

sea turtles will be extinct in 25 years. 

EPA used Whitehead (1993) to assess the range of benefits potentially resulting from 316(b) regulatory 

options (detailed methodology in Appendix Section F.2). Available data sources and biological models 

were reviewed to assess the potential impact of baseline losses and reductions on the probability of sea 

turtle extinction over 25 years. Although analyses of sea turtle extinction risk have been conducted (e.g., 

Conant et al. 2009), EPA was unable to identify an existing model or analysis that could be readily used 

in conjunction with available mortality data to estimate the marginal impacts of CWISs on sea turtle 

extinction risk. Estimates from the literature suggest that I&E mortality is of relatively low importance 

compared to other human-induced mortality such as shrimp trawling and other fisheries (Plotkin 1995). 

However, Crouse et al. (1987) found that mortality at juvenile and subadult life stages can have a 

substantial effect on population growth, suggesting that small changes in survivorship at these age classes 

could have a measurable impact on extinction risk. EPA believes that the marginal change in extinction 

probability of loggerhead sea turtles due to 316(b) regulatory options is unlikely to be lower than 0.01 

(i.e., a 1 percent decrease in the probability over 25 years). This assessment is based upon reports that 

I&E mortality may result in the loss of more than 100 turtles per year (Appendix Table E-1), and because 

turtle population growth rates are known to be sensitive to changes in juvenile and subadult mortality 

(Crouse et al. 1987). 

EPA used a value of 0.01 within Whitehead’s (1993) modeling framework to bound household values for 

changes in extinction risk for loggerhead sea turtles as a consequence of 316(b) regulation (details of this 

calculation are in Appendix Section F.2). Although this assessment is not based on formal quantitative 

analysis of extinction risk, it is intended to illustrate the range of potential benefits associated with 

reductions in sea turtle losses. Using the published mean values for all other model parameters, EPA 

calculated an annual household value of $0.35 (2009$). Estimates were converted to 2009 dollars using 

the consumer price index (USBLS 2010). 
March 28, 2011 5-16 

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

B Total WTP for all Households 

Whitehead’s (1993) study for loggerhead sea turtle management activities was based on a state-wide 

survey of North Carolina residents. However, the large geographic range of sea turtles suggests that 

households of many coastal states through their U.S. range would value activities that decrease their 

extinction risk. There is also the potential for differential values within and across states. Households 

farther from the resource may value sea turtle survival less than households near the ocean, due to lower 

likelihood of participation in passive uses of the resource. Although EPA recognizes that the application 

of the benefit transfer may overestimate household values for states with population centers far from sea 

turtle habitat, evidence from the literature suggests that households may value changes in environmental 

resource that are occurring at great distances. For example, Pate and Loomis (1997) found that 

respondents were willing to ascribe stated preference values to environmental amenity changes in other 

states. As such, by focusing on residents of coastal states only, estimated benefits may undervalue 

national willingness to pay for the preservation of loggerhead sea turtles. 

For the purposes of assessing potential benefits from improvements to a sea turtle population, EPA 

focused solely on impacts to loggerhead sea turtles (one of six T&E sea turtle species in the US). By 

focusing only on loggerhead sea turtles, EPA notes that estimated benefits are likely to be lower than 

those held by individuals for all T&E turtle species. This species of turtles was chosen because they are 

late-maturing, have an existing population model (Crouse et al. 1987), an existing valuation study 

(Whitehead 1993), and are the most commonly affected species of turtle (Appendix Table F-1). The U.S. 

range of loggerhead sea turtles includes the Gulf of Mexico, South Atlantic, Mid-Atlantic, and North 

Atlantic 316(b) regions (USFWS 2010c). Assuming affected populations include all households within 

states with 316(b) existing facilities that potentially have an impact loggerhead sea turtles, 53.35 million 

households would be willing to pay for improved protection of this species (Table 5-7). By applying the 

mean household value of $0.35 (2009$) across all four regions, the total annual WTP for a 1 percent 

increase in the survival probability of loggerhead sea turtles annualized at a 3% discount rate over 25 

years is $16.6 million. Annualized benefits for each region are presented in Table 5-7, assuming that 

benefits begin to accrue in 2012 and continue throughout the compliance period. Because EPA does not 

currently have accurate national estimates of I&E mortality for turtle species, nor are population models 

available that estimate the effect of 316(b) regulation on population size and extinction risk, estimates are 

presented only to assess the potential range of benefits, and are not included in national totals. Actual 

benefits may be higher or lower than these estimates, with Option 2 and Option 3 likely to provide 

substantially greater benefits than Option 1. 
March 28, 2011 5-17 

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

Table 5-7: Monetized Benefits of a 1 Percent Increase in the Probability that Loggerhead 

Sea Turtles Will Not Be Extinct in 25 Years 

3% Discount Rate 7 % Discount Rate

North Atlantic CT, MA, ME, NH, 

RI

5.40 $1.67 $1.62

Mid-Atlantic DE, MD, NJ, NY, 

PA, VA

20.97 $6.51 $6.31

South Atlantic FL, GA, NC, SC 11.85 $3.67 $3.56

Gulf of Mexicoa FL, LA, MS, TX 15.13 $4.69 $4.40

Total - 53.35 $16.55 $16.04

Annualized Benefits

(2009$, millions)

a

Florida households are included in both the South Atlantic and Gulf of Mexico regions. To prevent double-counting, Florida 

households were apportioned between these regions based on relative AIF.

Note: Because of uncertainty in estimates of increased survival probability, and because benefits were not calculated for options, 

these values are not included in national totals.

Number of 

Households 

Region States Included (millions)

5.4.3 Limitations and Uncertainties 

Table 5-8 summarizes the caveats, omissions, biases, and uncertainties known to affect the estimates 

developed for the benefits analysis of sea turtles (Section 5.4.2.3), and T&E finfish in the Inland (Section 

5.4.2.1) region. 

Table 5-8: Caveats, Omissions, Biases, and Uncertainties in the T&E Species Benefits Estimates 

Issue Impact on Benefits Estimate Comments 

Change in T&E populations due to 

I&E mortality is uncertain Uncertain 

Projected changes in number of fish affected may be 

underestimated because neither cumulative impacts of 

I&E mortality over time nor interactions with other 

stressors are considered. 

I&E mortality effects are not 

estimated for all T&E species and 

all regions 

Estimates understated 

EPA was unable to estimate I&E mortality of T&E 

species for all regions, due to lack of data. The large 

amount of overlap between T&E ranges and CWIS 

suggests that many affected species are likely to be 

missing from I&E mortality reports. 

Benefit estimates include only a 

subset of species identified as 

affected 

Estimates understated 

EPA was unable to apply benefit transfer of values for 

all affected species. Benefits estimates address 80–84 

percent of documented T&E A1E losses in the Inland 

region. 

Benefit estimates used in benefit 

cost analysis include only 

recreational use values 

Estimates understated 

EPA applied recreational use values to estimate benefits 

for the species included in the analysis. T&E species 

have primarily nonuse values, which were not 

monetized. In addition, some of the affected species 

have commercial use values, which were not estimated. 

Benefit transfer introduces 

uncertainties Uncertain 

EPA applied a recreational use value for sturgeon in 

California to value sturgeon and paddlefish in the Inland 

region. This value may over- or understate recreational 

values in the Inland region. 

Ecological consequences of 

reduced numbers of T&E species Estimates understated 

WTP values are unlikely to include damage to foodwebs and ecosystem stability as a consequence of the 

removal or restoration of T&E species. 

Effects of thermal impacts from 

CWIS on T&E populations is 

uncertain 

Uncertain EPA has no data with respect to the effect of thermal 

discharge on T&E species. 
March 28, 2011 6-1 

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

6 Commercial Fishing Benefits 

Commercial fisheries can be adversely affected by impingement and entrainment mortality (I&E 

mortality) in addition to many other stressors. Commercially landed fish are exchanged in markets with 

observable prices and quantities; however, estimating the change in economic surplus from increases in 

the number of commercially landed fish requires consideration of various conceptual and empirical 

issues. This chapter provides an overview of these issues, and indicates how EPA estimated the change in 

commercial fisheries-related economic surplus associated with the elimination of baseline I&E mortality 

and reduction in baseline I&E mortality under the regulatory options considered for the Section 316(b) 

regulation. The chapter includes a review of the concept of economic surplus, and describes economic 

theory and empirical evidence regarding the relationship between readily observable dockside prices and 

quantities and the economic welfare measures of producer and consumer surplus that are suitable for 

benefit-cost estimation. 

Section 6.1 describes the methodology used to estimate the commercial fisheries-related benefits 

including conceptual and empirical discussions of producer and consumer surplus. Section 6.2 presents 

the commercial fisheries-related benefits by region; and Section 6.3 presents the limitations and 

uncertainties associated with EPA’s analysis. 

6.1 Methodology 

The methodology employed to estimate the commercial fishing benefits associated with the regulatory 

options for the proposed Section 316(b) regulation closely follows the analysis conducted for the Section 

316(b) Phase III Final Rule (USEPA 2006b). Changes from that analysis include updated estimates of 

I&E mortality losses and reductions, and updated dockside prices. The dockside prices are now estimated 

based on the 5-year average price between 2005 and 2009, from commercial fishing landings data 

obtained from the National Oceanic and Atmospheric Administration’s National Marine Fisheries Service 

(NMFS). 

EPA measured commercial fishing benefits as changes in producer surplus. EPA considered estimating 

consumer surplus values associated with reductions in I&E mortality, but found that dockside prices 

would not change enough to produce measurable shifts in consumer surplus. The details of this analysis 

and the estimated price changes are presented in Section 6.2 and in Appendix G. 

6.1.1 Estimating Consumer and Producer Surplus 

The total loss to the economy from I&E mortality impacts on commercially harvested fish species is 

determined by the sum of changes in both producer and consumer surplus (Hoagland and Jin 2006). EPA 

modeled I&E mortality losses using the methods presented in Chapter 3 of this document. EPA assumed a 

linear relationship between stock and harvest. That is, if 10 percent of the current commercially targeted 

stock were harvested, EPA assumes that 10 percent of any increase in that species due to lower I&E 

mortality losses would be harvested. Thus, the percentage increase in harvest is assumed to be the same as 

the percentage increase in fish. The percentage of fish harvested is based on historical fishing mortality 

rates. EPA used historical NMFS landings data on commercial and recreational catch to determine the 

proportions of total species landings attributable to recreational and commercial fishing. EPA applied 

these proportions to the estimated total change in harvest to distribute benefits between commercial and 

recreational fisheries. 
March 28, 2011 6-2 

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

Producer surplus provides an estimate of the economic benefits to commercial fishers, but welfare 

changes can also be expected to accrue to final consumers of fish and to commercial consumers 

(including processors, wholesalers, retailers, and middlemen) if the projected decrease in catch is 

accompanied by an increase in price. These impacts can be expected to flow through the tiered 

commercial fishery market (as described in Holt and Bishop (2002)). 

This study used a fishery market model to estimate changes in welfare as a result of changes in the level 

of the commercial fishing harvest. The market model takes as inputs the expected change in harvest and 

baseline gross revenues, and provides as outputs the expected change in producer and consumer surplus. 

In general, the analysis of market impacts involves the following steps (Bishop and Holt (2003)): 

1. Assessing the net welfare changes for fish consumers due to changes in fish harvest and the 

corresponding change in fish price. 

2. Assessing net welfare changes for fish harvesters due to the change in total revenue, which could 

be positive or negative. 

3. Calculating the increase in net social benefits when the fish harvest changes. 

Figure 6-1 illustrates a simplified fishery market model as shown in Bishop and Holt (2003). For 

simplicity, the model assumes that the fishery is managed on quota basis with the baseline quota shown as 

F1

 and baseline dockside or ex-vessel price as P1. It uses an inverse demand function, P(F), because fish 

are perishable with the quantity harvested driving price in the short run. 

Figure 6-1: Fishery Market Model, reproduced from Bishop and Holt (2003) 

6.1.1.1 Step 1: Assessing Benefits to Consumers 

The downward sloping line labeled P(F), depicted in Figure 6-1, represents a general equilibrium demand 

function that accounts for markets downstream of commercial fishers. As described above, the vertical 

curve F1

 is the quantity of fish supplied to the market by commercial fishers under the baseline 

conditions. Equilibrium is attained at the point where P(F) equals F1

. The intersection of these two lines 

gives the price P1

 at which quantity F1 is sold. In this case the total amount paid by consumers for fish is 
March 28, 2011 6-3 

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

equal to P1 × F1, which is equal to the area of the boxes U + V + W in the graph. The consumer surplus or 

benefit to consumers is equal to the area of the triangle T.

The measurement of the benefits from reducing I&E mortality relies on the assumption that a decrease in 

mortality of fish, larvae, and eggs under a scenario of reduced I&E mortality would increase fish 

populations and the quantity of fish supplied to consumers (i.e., an increase from F1 to F2

). If the quantity 

of fish available to the market increases from F1 to F2

, this in turn would result in a lower market price for 

fish (i.e., P2

). This changes the total amount paid by consumers to P2 × F2, which is equal to the area of 

the boxes V + W + Y + Z. This may be less than or greater than area U + V + W, but unequivocally 

increases the consumer surplus so that it is equal to the area of the triangle T + U + X. The difference in 

consumer surplus between the reduced I&E mortality scenario and the current baseline scenario (i.e., U 

+ X) is the measure of benefits to consumers from reducing I&E mortality. 

Estimating the change in price of fish from changes in commercial fish harvest requires the following 

input data: (1) An estimate of the baseline prices and quantities of the commercial fishing harvest, (2) the 

estimated change in the commercial fishing harvest under the reduced I&E mortality scenario, and (3) an 

understanding of the price elasticity of demand for fish. The baseline commercial fishing prices and 

harvest quantities were estimated from NMFS landings data from 2005 to 2009 for regional markets for 

relevant species. Chapter 3 describes the methods and data used in estimating baseline I&E mortality 

losses and reductions under the regulatory options.19 The price elasticity of demand for fish measures the 

percentage change in demand in response to a percentage point change in fish price. Thus, the inverse 

elasticity, or price flexibility, measures the percent change in price for a given percent change in quantity. 

EPA did not include estimates of changes in consumer surplus for commercial species. Prices must 

change in order for consumer surplus to change. EPA estimated the expected price changes from 

eliminating baseline levels of I&E mortality losses, and found them to small, ranging from 0.13 percent to 

2.1 percent. Appendix G of this document presents the detailed calculations and results. Consumer 

surplus measures that have been estimated by NMFS for past environmental impact statements tend to be 

quite low. 20 Most species of fish have numerous close substitutes, and most fisheries are price-takers in 

the world market. Therefore, if harvest of one or several species increases, prices are unlikely to change 

by a significant amount. 

6.1.1.2 Step 2: Assessing Producer Surplus 

In an unregulated fishery, the long-run change in producer surplus due to an increase in fish stocks will be 

zero percent of the change in gross revenues, because in open access fisheries, excess profits are always 

driven to zero at the margin. Most fisheries are, however, regulated with quotas or restrictive permits to 

prevent overfishing. Thus, there are lasting economic benefits to commercial fishers from reductions in 

I&E mortality and the subsequent increase in harvest. Fishery regulations seek to create sustainable 

harvests that maximize resource rents.21 In a regulated fishery, I&E mortality impacts reduce the number 

of fish available to harvest. This may lead to more-stringent regulations and decreases in harvest. In this 

 

19 For several species, the predicted changes in harvest were quite large. EPA increased scrutiny on results for species with 10

percent or greater predicted change in harvest, to determine whether such increases were in fact reasonable estimates. In 

some cases, EPA capped the predicted harvest increases. The methods used and caps are described in Section 6.2. 

20 Personal communications with NMFS economists Cindy Thomson (2008), Eric Thunberg (2008), and Steve Freese (2008). 

21 In addition, even in open access fisheries, inframarginal rents are earned by at least some boats (personal communication, 

Thunberg 2008). 
March 28, 2011 6-4 

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

case, the change in producer surplus can be related to the change in harvest and the resulting gross 

revenue. 

In Figure 6-1, the line C represents the cost to the producer of supplying a pound of fish. The model 

assumes that average cost is equal to marginal cost, that is, C is constant for all pounds produced.22 When 

the supply of fish is equal to F1

, the commercial fishers sell F1 pounds of fish at a price of P1 and earn 

revenues equal to U + V + W. The area between P1 and C is the producer surplus that accrues to 

producers for each pound of fish. Total producer surplus realized by producers is equal to (P1 - C) × F1

. In 

the example, this producer surplus is equal to the area of U + V. The area W is the amount that producers 

pay for capital and labor and to suppliers if the harvest equals F1 (e.g., fishing gear and the costs of 

operating in the market). 

When supply increases to F2

, the producers sell F2 pounds of fish at a price of P2. The total cost to 

produce F2 increases from W to W + Z. The total producer surplus changes from U + V to V + Y. This 

change may be either positive or negative, depending on the relative elasticity of demand, which changes 

the relative sizes of areas U and Y. 

In theory, producer surplus is equal to normal profits (total revenue minus fixed and variable costs), 

minus the opportunity cost of capital. The fixed costs and inputs are incurred independently of the 

expected marginal changes in the level of fish landings (Squires et al. 1998; Thunberg and Squires 2005). 

Total variable costs including labor, fuel, ice, and other supplies, however, vary directly with the level of 

landings. Furthermore, since the opportunity cost of capital is estimated to be only about 0.4 to 2.6 

percent of producer surplus, normal profits are assumed to be a sufficient proxy for producer surplus 

(USEPA 2004b). As a result, assessment of producer surplus is reduced to a relatively straightforward 

calculation in which the change in producer surplus is calculated as a species- and region-specific fraction 

of the change in gross revenue due to increased landings. 

The change in producer surplus, captured by “normal profits,” is assumed to be equivalent to a fixed 

proportion of the change in gross revenues, as estimated from the change in the commercial harvest due to 

reducing I&E mortality and the change in prices associated with the increased commercial harvest. As 

discussed above, EPA estimated price changes to be negligible, and therefore did not include price 

changes in the model. EPA estimated species- and region-specific Net Benefits Ratios which represent the 

fractional share of gross revenue associated with net benefits. EPA’s approach for estimating Net 

Benefits Ratios using available data on variable costs from sources such as the National Marine Fisheries 

Service is described in more detail in Section A4-10 of US EPA (2006b). EPA then applied the Net 

Benefits Ratio to the estimated change in gross revenue under the 316(b) regulatory options to estimate 

the increase in producer surplus. The Net Benefits Ratios are shown by region and species in Table 6-1 

through Table 6-6; they range from 0.15 to 0.85.23,24 See Chapter 1, Section 1.2 for a definition of the 

seven study regions. The Inland region is excluded from the analysis due to a negligible commercial 

fishing harvest in this region. EPA notes that this approach yields an estimate of benefits to commercial 

 

22 If marginal cost increases as harvest increases, some of the producer surplus per unit will be lost due to the increased costs. 

23 Positive Net Benefits Ratios reflect the assumption that there will be rents (profits) to commercial fishers in regulated 

fisheries. When calculating the Net Benefits Ratios, EPA assumed that the predicted changes in harvest are such that fixed 

costs and variable costs per ton will not change. If costs remain constant, a marginal change in harvest is more likely to 

result in increases in profit and positive producer surplus. 

24 In the case of species aggregates (e.g., forage species), EPA assumed that the net benefit ratio is equal to the simple average of 

all empirically estimated net benefit ratios in the region. Species aggregates are listed as “Other” in Table 6-1 to Table 6-6.
March 28, 2011 6-5 

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

fisherman, not benefits to society as a whole. As described in Section 6.1.1.1, EPA did not estimate 

changes in consumer surplus. 

Table 6-1: California Region, Species-Specific Gear Type, Status of Stock, and Net Benefits Ratio 

Species Main Management 

Method 

Main Gear 

Type Status of Stock 

Net Benefits as a 

Ratio of Gross 

Revenue (NBRatio) 

Anchovies Annual landings Roundhaul Unknown 0.64 

Cabezon Total allowable catch Hook-and-line Not overfished or subject 

to overfishing 0.52 

Crabs Seasonal closures Pots and traps Unknown 0.74 

Drums and Croakers Permits Nets Unknown 0.42 

Dungeness Crab Size, no females, closed 

during molting season Traps Unknown 0.74 

Flounders Quotas Bottom trawl Not overfished or subject 

to overfishing 0.64 

California Halibut Total allowable catch Longline Not overfished or subject 

to overfishing 0.58 

Other N/A N/A N/A 0.53 

Rockfishes Quotas Trawls Overfished or subject to 

overfishing 0.62 

California Scorpionfish Quotas Otter trawl Unknown 0.47 

Sculpins Nonrestrictive permits Trawls Unknown 0.64 

Sea Basses Season, size, gear 

restrictions Gillnets Unknown 0.66 

Shad, American None Nets Not overfished or subject 

to overfishing 0.00 

Shrimp Seasonal closures Trawl Unknown 0.15 

Smelts Seasonal closures Nets Overfished or subject to 

overfishing 0.66 

Surfperches Quotas Handlines Unknown 0.37 
March 28, 2011 6-6 

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

Table 6-2: North Atlantic Region, Species-Specific Gear Type, Status of Stock, and Net Benefits 

Ratio 

Species Main Management 

Method 

Main Gear 

Type Status of Stock 

Net Benefits as a 

Ratio of Gross 

Revenue (NBRatio) 

Bluefish Quotas Gillnets Not overfished or subject 

to overfishing 0.63 

Butterfish Quotas NA Unknown 0.64 

Atlantic Cod Time/area closures Otter trawl Overfished or subject to 

overfishing 0.66 

Crabs Size, sex, season Traps Not overfished or subject 

to overfishing 0.57 

American Plaice Size Otter trawl Overfished or subject to 

overfishing 0.63 

Windowpane Time/area closures Bottom trawl Overfished or subject to 

overfishing 0.63 

Winter Flounder Quotas Otter trawls Overfished or subject to 

overfishing 0.64 

Flounders Total allowable landing Bottom trawl Overfished or subject to 

overfishing 0.63 

Red Hake Quotas Otter trawls Not overfished or subject 

to overfishing 0.62 

Silver Hake Quotas Otter trawls Not overfished or subject 

to overfishing 0.63 

Atlantic Herring Total allowable catch Purse seine Not overfished or subject 

to overfishing 0.76 

Atlantic Mackerel Annual quota Unknown Not overfished or subject 

to overfishing 0.77 

Atlantic Menhaden Not reg. In this area Unknown Not overfished or subject 

to overfishing 0.68 

Other N/A N/A N/A 0.57 

White Perch Size limits Unknown Unknown 0.82 

Pollock Time/area closures Bottom trawl Not overfished or subject 

to overfishing 0.71 

Sculpins Open access Unknown Unknown 0.00 

Scup Quotas Otter trawls Overfished or subject to 

overfishing 0.69 

Searobin Open access (by catch) Unknown Unknown 0.00 

Shad, American Mortality targets Unknown Fully exploited 0.60 

Skates Catch limits Otter trawl Overfished or subject to 

overfishing 0.68 

Tautog Possession limits Otter trawl Overfished or subject to 

overfishing 0.46 

Weakfish Size limits Trawls Not overfished or subject 

to overfishing 0.76 
March 28, 2011 6-7 

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

Table 6-3: Mid-Atlantic Region, Species-Specific Gear Type, Status of Stock, and Net Benefits Ratio 

Species Main Management 

Method 

Main Gear 

Type Status of Stock 

Net Benefits as a Ratio 

of Gross Revenue 

(NBRatio) 

Alewife Bans, species of concern Fish weirs Overfished or subject to 

overfishing 0.85 

American Shad Chesapeake fishery 

closed Unknown 

Overfished or subject to 

overfishing except for 

small by-catch allowance 

0.84 

Atlantic Croaker Gear restrictions Gillnets Not overfished or subject 

to overfishing 0.74 

Atlantic Menhaden Open access 

Purse seine, 

otter trawl, gill 

net 

Unknown 

0.67 

Black Drum Quotas Unknown Unknown 0.70 

Blue Crab Limits on female crabs, 

size Pots Overfished or subject to overfishing 0.57 

Bluefish Quotas Gillnets Not overfished or subject 

to overfishing 0.63 

Butterfish Quotas Unknown Overfished or subject to 

overfishing 0.64 

Crabs Season, size Unknown Unknown 0.57 

Drums and Croakers Gear restrictions, quotas Nets Unknown 0.74 

Flounders Quotas Bottom trawl Overfished or subject to 

overfishing 0.65 

Other N/A N/A N/A 0.73 

Red Hake Quotas Otter trawls Not overfished or subject 

to overfishing 0.62 

Scup Quotas Otter trawls Overfished or subject to 

overfishing 0.69 

Searobin Open access Unknown Unknown 0.00 

Silver Hake Quotas Otter trawls Not overfished or subject 

to overfishing 0.63 

Spot License Haul seines Unknown 0.84 

Striped Bass Quotas Gill nets Not overfished or subject 

to overfishing 0.67 

Striped Mullet Gear restrictions Cast nets Not overfished or subject 

to overfishing 0.70 

Tautog Possession limits Otter trawl Overfished or subject to 

overfishing 0.46 

Weakfish Size limits Trawls Not overfished or subject 

to overfishing 0.76 

White Perch Size limits Unknown Unknown 0.82 
March 28, 2011 6-8 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 6-4: South Atlantic Region, Species-Specific Gear Type, Status of Stock, and Net Benefits 

Ratio 

Species Main Management 

Method 

Main Gear 

Type Status of Stock 

Net Benefits as a Ratio 

of Gross Revenue 

(NBRatio) 

Blue Crab Size limits Pots Overfished or subject to 

overfishing 0.57 

Crabs Size, sex, season Traps Not overfished or subject 

to overfishing 0.57 

Drums and Croakers Open access (by catch) Otter trawl 

bottom, gill nets Overfished 0.54 

Atlantic Menhaden 

Five year annual cap on 

reduction fishery in 

Chesapeake 

Unknown Unknown 0.76 

Other N/A N/A N/A 0.59 

Spot License Haul seines Unknown 0.70 

Stone Crab Size Traps Not overfished or subject 

to overfishing 0.58 

Weakfish Size limits Trawls Not overfished or subject 

to overfishing 0.64 

Table 6-5: Gulf of Mexico Region, Species-Specific Gear Type, Status of Stock, and Net Benefits 

Ratio 

Species Main Management 

Method 

Main Gear 

Type Status of Stock 

Net Benefits as a Ratio 

of Gross Revenue 

(NBRatio) 

Blue Crab Limited entry, pot limits Pots Overfished or subject to 

overfishing 0.72 

Black Drum Limited access permits Hand lines, gill 

nets 

Unknown 0.69 

Leatherjacket N/A 

Rod/reel, hand 

and long lines, 

pots and traps 

Unknown 

0.00 

Mackerels Quotas Hook-and-line Not overfished or subject 

to overfishing 0.75 

Menhaden Seasonal/area closures Purse seines Fully exploited 0.76 

Other N/A N/A N/A 0.46 

Sea Basses Quotas Traps Overfished or subject to 

overfishing 0.72 

Sheepshead Size Cast net Not overfished or subject 

to overfishing 0.84 

Shrimp Same as pink shrimp Unknown Not overfished or subject 

to overfishing 0.43 

Spot License Haul seines Unknown 0.54 

Stone Crab Size Traps Not overfished or subject 

to overfishing 0.71 

Striped Mullet Gear restrictions Strike nets Not overfished or subject 

to overfishing 0.79 
March 28, 2011 6-9 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 6-6: Great Lakes Region, Species-Specific Gear Type, Status of Stock, and Net Benefits Ratio 

Species Main Management 

Method Main Gear Type Status of Stock 

Net Benefits as a Ratio 

of Gross Revenue 

(NBRatio) 

Bullhead State specific Gill and trap nets Unknown 0.29 

Freshwater Drum State specific Gill and trap nets Unknown 0.29 

Other State specific Gill and trap nets Unknown 0.29 

Smelt State specific Gill and trap nets Unknown 0.29 

White Bass State specific Gill and trap nets Unknown 0.29 

Whitefish State specific Gill and trap nets Unknown 0.29 

Yellow Perch State specific Gill and trap nets Unknown 0.29 

6.1.1.3 Step 3: Estimating Net Social Benefits When the Fishing Harvest Increases 

The change in net social benefits when the commercial fishing harvest increases from F1 to F2 is 

estimated by adding the results from Steps 1 and 2. Because area U is a transfer from commercial fishers 

to consumers, it does not affect social benefits.25 Therefore, the change in net social benefits is area X + Y 

(see Figure 6-1). However, if demand elasticity is such that changes in price are negligible, area X will be 

negligible relative to Y, and total social benefits will be measured by area Y. See Appendix G on EPA’s 

analysis of the estimated price changes due to reducing I&E mortality losses at CWIS sites by region and 

species. 

6.2 Benefits Estimates for Regional Commercial Fishing 

The first step of the analysis of commercial fishing benefits involves a fishery-based assessment of I&E 

mortality-related changes in harvested species landings. Many of the fish species affected by I&E 

mortality at CWIS sites are harvested both recreationally and commercially. As described in Section 

6.1.1, EPA assumed a linear relationship between stock and harvest and used historical NMFS landings 

data on commercial and recreational catch to determine the proportions of total species harvest 

attributable to recreational and commercial fishing. EPA applied these proportions to the estimated total 

change in harvest to distribute benefits between commercial and recreational fisheries. The estimated 

change in commercial fishery harvest was then used as a basis for estimating changes in producer surplus 

in the commercial fishing industry. 

EPA further assessed species with estimated harvest increases from the elimination of I&E mortality 

exceeding10 percent of baseline harvest from 2005 to 2009. This was done to evaluate whether potential 

harvest increases under 316(b) regulatory options are reasonable when compared to historic harvest data. 

Table 6-7 lists the species and potential percent increases in harvest over baseline harvest from 

eliminating baseline I&E mortality losses for the fourteen species found to exceed 10 percent. The species 

of concern are cabezon, California halibut, rockfishes, and sculpins in the California region; sculpins in 

the North Atlantic region; drums and croakers, spot, and weakfish in the Mid-Atlantic region; black drum, 

drums and croakers, leatherjacket, spot, and striped mullet in the Gulf of Mexico region; and smelt in the 

Great Lakes region. No species with 10 percent or greater potential change in harvest were found in the 

South Atlantic region. The increases range from 12 percent for striped mullet in the Gulf of Mexico to 

25,110 percent for sculpins in the North Atlantic. 

 

25 Note that in the model shown in Figure 6-1, X + Y = U + X + [(V + Y) – (U + V)] = U + X + (Y – U) 
March 28, 2011 6-10 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 6-7: Potential Harvest Increase from Eliminating I&E Mortality Losses as a Percentage of Total 

Harvest and Potential Harvest Capping Rules Used in EPA’s Analysis 

Region and 

Species 

Baseline 

Harvest 

(thousand 

lbs) 

Baseline 

I&E Losses 

(thousand 

lbs) 

Potential 

% Increase 

in Harvest 

Maximum 

Harvest 

1979-2009 

(thousand 

lbs) 

90th 

Percentile of 

Max. 

Harvest 

(thousand 

lbs) 

MSY or 

Other 

Capping 

Rule 

(thousand 

lbs) 

Cap Used 

California Cabezon 55.6 54.4 98% 374.2 256.7 207.2a Don’t cap 

California Halibut 629.9 126.4 20% 1,337.1 1,256.3 1,158.5b Don’t cap 

California Rockfishes 2,668.4 1,168.7 44% 58,189.5 43,216.7 77,161.8c Don’t cap 

California Sculpins 3.5 2.6 74% 19.5 7.1 482.8 d Don’t cap 

North Atlantic Sculpins <0.1 25.1 25,110% 4.8 4.0 Cap at 90th

Mid-Atlantic Drums and 

Croakers 11,430.1 1,519.2 13% 16,575.2 16,252.9 Don’t cap 

Mid-Atlantic Spot 3,286.9 2,033.0 62% 4,766.2 4,398.3 Cap at 90th

Mid-Atlantic Weakfish 497.0 741.9 149% 15,389.6 7,023.5 Don’t cap 

Gulf of Mexico Black 

Drum 4,397.3 1,885.2 43% 10,347.2 6,977.2 Don’t cap 

Gulf of Mexico Drums and 

Croakers 81.0 40.3 50% 1,787.4 1,193.3 Don’t cap 

Gulf of Mexico 

Leatherjacket 65.6 90.7 138% 509.3 437.5 Don’t cap 

Gulf of Mexico Spot 18.1 40.0 221% 442.8 299.1 Don’t cap 

Gulf of Mexico Striped 

Mullet 10,347.7 1,278.3 12% 33,141.6 27,395.6 Don’t cap 

Great Lakes Smelts 522.2 105.9 20% 4,107 3,520 Don’t cap 

a. MSY (maximum sustainable yield). 

b. Average of most recent four peaks in harvest. 

c. MSY for rockfishes for the West Coast. 

d. MSY for all scorpionfish and sculpins. 

Sources: EPA estimates of I&E mortality losses; NMFS data on baseline harvest, historical landings, and MSY. 

Economists and biologists with NMFS recommended using either maximum sustainable yield (MSY), 

allowable biological catch (ABC), or historical harvest to determine reasonable caps on projected total 

harvest under the post-compliance scenario.26 NMFS scientists recommended using 25 years or more of 

historical catch, because many populations peaked around 25 years ago—at that time there were virgin, 

non-exploited populations, so that maximum harvests were achievable. Using historical catch data from 

NMFS, EPA determined the maximum landings for the years 1979 through 2009, and calculated the 90th

percentile of landings for those years. NMFS biologists provided MSY where available (for California 

cabezon and all West Coast rockfishes). NMFS biologists suggested that sculpins in California be 

evaluated in combination with scorpionfish, as these species are grouped when determining the MSY. 

They also noted that halibut harvests fluctuate greatly, as the stock is highly variable. There is no stock 

assessment for halibut, so NMFS biologists suggested averaging the most recent four peaks in harvest.27 

 

26 Cindy Thomson, NMFS, personal communication (2008). 

27 Cindy Thomson, NMFS, personal communication (2008). 
March 28, 2011 6-11 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

MSY or ABC data were not available for the species of interest in the other regions.28 Therefore, EPA 

capped potential harvest increase at the 90th percentile of annual harvest from 1979 to 2009. The only 

species for Based on this criteria and the NMFS scientists’ recommendations, EPA capped estimated 

harvest increases for two species when estimated commercial fishing benefits, sculpins in the North 

Atlantic and spot in the Mid-Atlantic. 

The following sections present estimated benefits from commercial harvest changes in six of the seven 

study regions. The Inland region is excluded from the analysis due to a negligible commercial fishing 

harvest in this region. 

6.2.1 California 

Baseline levels of I&E mortality account for 1,379 thousand pounds of commercial fishing losses 

annually in the California region, as shown in Table 6-8. Rockfishes account for the major portion of 

overall losses in this region. The annual undiscounted commercial fishing benefits of eliminating baseline 

I&E mortality losses are estimated to be approximately $1,394 thousand, as shown in Table 6-8. 

Applying a 3 percent discount rate, the annualized benefits of eliminating baseline I&E mortality losses 

are estimated to be $1,236 thousand. Applying a 7 percent rate, these annualized benefits are 

approximately $1,195 thousand. 

As shown in Table 6-8, annual commercial harvest is estimated to increase by approximately 7 thousand 

pounds under Options 1, 1,176 thousand pounds under Option 2, and 1,230 thousand pounds under 

Option 3. Discounted at 3 percent, the estimated annualized benefits to commercial fishers are 

approximately $4 thousand under Option 1, $751 thousand under Option 2, and $776 thousand under 

Option 3. Discounted at 7 percent, the estimated annualized benefits to commercial fishers are 

approximately $3 thousand under Option 1, $573 thousand under Option 2, and $589 thousand under 

Option 3. (Table 6-8). Appendix Table H-1 presents species-specific results for the estimated annual 

increase in harvest and monetary benefits to commercial fishers. 

Table 6-8: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E 

Mortality Losses at In-Scope Facilities in the California Region, by Regulatory Option 

(2009$) 

Undiscounted 3% Discount Rate 7% Discount Rate

Baseline 1,379 1,394 1,236 1,195

Option 1 7 5 4 3

Option 2 1,176 1,189 751 573

Option 3 1,230 1,243 776 589

Regulatory Option

Annual Increase in 

Commercial Harvest

(thousand lbs)

Annualized Benefits from Increase in Commercial Harvest

(2009$, thousands)

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for 

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere

 

28 Based on information from NMFS and other Web sites, and personal communication with Nichola Meserve of the Atlantic 

States Marine Fisheries Commission (2008). 
March 28, 2011 6-12 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

6.2.2 North Atlantic 

Baseline levels of I&E mortality account for 430 thousand pounds of annual commercial fishing losses in 

the North Atlantic region, as shown in Table 6-9, with flounders playing a particularly important role. 

EPA estimated the annual undiscounted benefits to commercial fishers from eliminating baseline I&E 

mortality losses to be approximately $471 thousand, as shown in Table 6-9. Total annualized benefits 

from eliminating baseline I&E mortality losses, applying a 3 percent discount rate, are estimated to be 

$418 thousand. Applying a 7 percent rate, these annualized benefits are approximately $404 thousand. 

As shown in Table 6-9, annual commercial harvest is estimated to increase by approximately 3 thousand 

pounds under Option 1, 352 thousand pounds under Option 2, and 369 thousand pounds under Option 3. 

Discounted at 3 percent, the estimated annualized benefits to commercial fishers are approximately $2 

thousand under Options 1, $231 thousand under Option 2, and $242 thousand under Option 3. Discounted 

at 7 percent, the estimated annualized benefits to commercial fishers are approximately $1 thousand under 

Option 1, $171 thousand under Option 2, and $179 thousand under Option 3 (Table 6-9). Appendix Table 

H-2 presents species-specific results for the estimated annual increase in harvest and monetary benefits to 

commercial fishers. 

Table 6-9: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E 

Mortality Losses at In-Scope Facilities in the North Atlantic Region, by Regulatory 

Option (2009$) 

Undiscounted 3% Discount Rate 7% Discount Rate

Baseline 430 471 418 404

Option 1 3 2 2 1

Option 2 352 385 231 171

Option 3 369 403 242 179

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for 

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere

Regulatory Option

Annual Increase in 

Commercial Harvest

(thousand lbs)

Annualized Benefits from Increase in Commercial Harvest

(2009$, thousands)

6.2.3 Mid-Atlantic 

Baseline levels of I&E mortality account for approximately 10,672 thousand pounds of commercial 

fishing losses annually in the Mid-Atlantic region, as shown in Table 6-10. Atlantic menhaden, blue crab, 

drums and croakers, spot, and weakfish are the primary drivers of I&E mortality losses in the MidAtlantic region. The annual undiscounted benefits to commercial fishers from eliminating baseline I&E 

mortality losses are estimated to be $3,192 thousand, as shown in Table 6-10. Applying a 3 percent 

discount rate, annualized benefits from eliminating baseline I&E mortality losses are estimated to be 

$2,831 thousand. Applying a 7 percent rate, these annualized benefits are approximately $2,737 thousand. 

As shown in Table 6-10, annual commercial harvest is estimated to increase by approximately 3,750 

thousand pounds under Option 1, 10,152 thousand pounds under Option 2, and 10,224 thousand pounds 

under Option 3. Discounted at 3 percent, the estimated annualized benefits to commercial fishers are $342 

thousand under Options 1, $1,615 thousand under Option 2, and $1,629 thousand under Option 3. 

Discounted at 7 percent, the estimated annualized benefits to commercial fishers are approximately $303 
March 28, 2011 6-13 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

thousand under Option 1, $1,124 thousand under Option 2, and $1,134 thousand under Option 3 (Table 

6-10). Appendix Table H-3 presents species-specific results for the estimated annual increase in harvest 

and monetary benefits to commercial fishers. 

Table 6-10: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E 

Mortality Losses at In-Scope Facilities in the Mid-Atlantic Region, by Regulatory Option 

(2009$) 

Undiscounted 3% Discount Rate 7% Discount Rate

Baseline 10,672 3,192 2,831 2,737

Option 1 3,750 436 342 303

Option 2 10,152 3,010 1,615 1,124

Option 3 10,224 3,035 1,629 1,134

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for 

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere

Regulatory Option

Annual Increase in 

Commercial Harvest

(thousand lbs)

Annualized Benefits from Increase in Commercial Harvest

(2009$, thousands)

6.2.4 South Atlantic 

Baseline levels of I&E mortality account for more than 99 thousand pounds of commercial fishing losses 

in the South Atlantic region, as shown in Table 6-11. The estimated undiscounted annual commercial 

fishing benefits of eliminating baseline I&E mortality losses are driven primarily by spot, followed by 

Atlantic menhaden, blue crab, and stone crab, and total $23 thousand, as shown in Table 6-11. Applying a 

3 percent discount rate, the annualized benefits of eliminating baseline I&E mortality losses are estimated 

to be $21 thousand. Applying a 7 percent rate, these annualized benefits are $20 thousand. 

As shown in Table 6-11, annual commercial harvest is estimated to increase by approximately 84 

thousand pounds under Options 2 and 3 and 45 thousand pounds under Option 1. Discounted at 3 percent, 

the estimated annualized benefits to commercial fishers are $12 thousand under Options 2 and 3, and $8 

thousand under Option 1. Discounted at 7 percent, the estimated annualized benefits to commercial 

fishers are approximately $8 thousand under Options 2 and 3, and $7 thousand under Option 1 (Table 

6-11). Appendix Table H-4 presents species-specific results for the estimated annual increase in harvest 

and monetary benefits to commercial fishers. 
March 28, 2011 6-14 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 6-11: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E 

Mortality Losses at In-Scope Facilities in the South Atlantic Region, by Regulatory 

Option (2009$) 

Undiscounted 3% Discount Rate 7% Discount Rate

Baseline 99 23 21 20

Option 1 45 10 8 7

Option 2 84 20 12 8

Option 3 84 20 12 8

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for 

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere

Regulatory Option

Annual Increase in 

Commercial Harvest

(thousand lbs)

Annualized Benefits from Increase in Commercial Harvest

(2009$, thousands)

6.2.5 Gulf of Mexico 

Baseline levels of I&E mortality account for more than 5,559 thousand pounds of commercial fishing 

losses in the Gulf of Mexico region annually, as shown in Table 6-12. These losses are driven by black 

drum, Atlantic menhaden, and striped mullet. The estimated undiscounted annual commercial fishing 

benefits from eliminating baseline I&E mortality losses are approximately $3,747 thousand, as shown in 

Table 6-12. Applying a 3 percent discount rate, estimated commercial fishing benefits from eliminating 

baseline I&E mortality losses are estimated to be $3,463 thousand. Applying a 7 percent rate, these 

annualized losses are approximately $3,450 thousand. 

As shown in Table 6-12, annual commercial harvest is estimated to increase by approximately 4,400 

thousand pounds under Options 2 and 3, and 1,500 thousand pounds under Option 1. Discounted at 3 

percent, the estimated annualized benefits to commercial fishers are approximately $588 thousand under 

Option 1 and $1,800 under Options 2 and 3. Discounted at 7 percent, the annualized benefits to 

commercial fishers are estimated to be approximately $1,400 thousand under Options 2 and 3, and $537 

thousand under Option 1 (Table 6-12). Appendix Table H-5 presents species-specific results for the 

estimated annual increase in harvest and monetary benefits to commercial fishers. 

Table 6-12: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E 

Mortality Losses at In-Scope Facilities in the Gulf of Mexico Region, by Regulatory 

Option (2009$) 

Undiscounted 3% Discount Rate 7% Discount Rate

Baseline 5,559 3,747 3,463 3,450

Option 1 1,459 719 588 537

Option 2 4,364 2,832 1,806 1,394

Option 3 4,371 2,837 1,804 1,390

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for 

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere

Regulatory Option

Annual Increase in 

Commercial Harvest

(thousand lbs)

Annualized Benefits from Increase in Commercial Harvest

(2009$, thousands)
March 28, 2011 6-15 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

6.2.6 The Great Lakes 

Baseline levels of I&E mortality account for more than 346 thousand pounds of commercial fishing losses 

in the Great Lakes region annually, as shown in Table 6-13. These losses are driven by the impingement 

of smelts and whitefish. The annual undiscounted commercial fishing benefits from eliminating baseline 

I&E mortality losses in this region are estimated to be approximately $87 thousand, as shown in Table 

6-13. Total annualized commercial benefits from eliminating baseline I&E mortality losses, applying a 3 

percent discount rate, are estimated to be $80 thousand. Applying a 7 percent rate, these annualized losses 

are approximately $80 thousand as well. 

As shown in Table 6-13, annual commercial harvest is estimated to increase by approximately 330 

thousand pounds under Options 2 and 3, and 227 thousand pounds under Option 1. The increase in 

commercial harvest under Option 1 is relatively close to Options 2 and 3 due to the relative importance of 

impingement mortality compared to total I&E mortality in the Great Lakes region. Discounted at 3 

percent, the estimated annualized benefits to commercial fishers are approximately $53 thousand under 

Options 2 and 3 and by $48 thousand under Option 1. Discounted at 7 percent, the annualized benefits to 

commercial fishers are estimated to be approximately $44 thousand under Option 1 and $41 thousand 

under Options 2 and 3 (Table 6-13). Appendix Table H-6 presents species-specific results for the 

estimated annual increase in harvest and monetary benefits to commercial fishers. 

Table 6-13: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E 

Mortality Losses at In-Scope Facilities in the Great Lakes Region, by Regulatory Option 

(2009$) 

Undiscounted 3% Discount Rate 7% Discount Rate

Baseline 346 87 80 80

Option 1 227 58 48 44

Option 2 326 82 53 41

Option 3 328 83 53 41

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for 

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere

Regulatory Option

Annual Increase in 

Commercial Harvest

(thousand lbs)

Annualized Benefits from Increase in Commercial Harvest

(2009$, thousands)
March 28, 2011 6-16 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

6.3 Limitations and Uncertainties 

Table 6-14 summarizes the caveats, omissions, biases, and uncertainties known to affect the estimates that 

were developed for the benefits analysis. 

Table 6-14: Caveats, Omissions, Biases, and Uncertainties in the Commercial Benefits Estimates 

Issue Impact on Benefits Estimate Comments 

Change in commercial landings due to 

I&E mortality is uncertain Uncertain 

Projected changes in harvest may be 

underestimated because cumulative 

impacts of I&E mortality over time, 

interactions with other stressors, and 

population changes are not considered. 

Some estimates of commercial harvest 

losses due to I&E mortality under current 

conditions are not region/species-specific 

Uncertain 

EPA estimated the impact of I&E 

mortality in the case study analyses 

based on data provided by the facilities. 

The most current data available were 

used. However, in some cases these data 

are 20 years old or older. Thus, they may 

not reflect current conditions. 

Effect of change in stocks on landings is 

not considered Uncertain 

EPA assumed a linear stock to harvest 

relationship, so that a 10% change in 

stock would have a 10% change in 

landings; this may be low or high, 

depending on the condition of the stocks. 

Region-specific fisheries regulations also 

will affect the validity of the linear 

assumption. 

Effect of uncertainty in estimates of 

commercial landings and prices is 

unknown 

Uncertain 

EPA assumes that NMFS landings data 

are accurate and complete. In some cases 

prices and/or quantities may be reported 

incorrectly. 
March 28, 2011 7-1 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

7 Recreational Fishing Benefits 

7.1 Introduction 

This chapter presents the estimated benefits to recreational anglers from improved recreational fishing 

opportunities due to reductions in impingement and entrainment mortality (I&E mortality) under the 

regulatory options considered for the Section 316(b) regulation. For this analysis, EPA used a benefit 

transfer approach based on a meta-analysis of economic studies of recreational fishing benefits from 

improved catch rates. Benefit transfer involves adapting research conducted for another purpose to 

address the policy questions at hand (Bergstrom and De Civita 1999). Because benefit-cost analysis of 

environmental regulations rarely affords sufficient time to conduct original stated or revealed preference 

studies specific to policy effects, benefit transfer is often the only remaining option for providing 

information to inform policy decisions. EPA notes that Smith et al. (2002, p.134) state that “...nearly all 

benefit cost analyses rely on benefit transfers....” 

Boyle and Bergstrom (1992) define benefit transfer as “the transfer of existing estimates of nonmarket 

values to a new study which is different from the study for which the values were originally estimated.” 

There are four types of benefit transfer studies: point estimate, benefit function, meta-analysis, and 

Bayesian techniques (USEPA 2000a). These may be categorized into three fundamental classes: (1) 

transfer of an unadjusted fixed value estimate generated from a single study site; (2) the use of expert 

judgment to aggregate or otherwise alter benefits to be transferred from a site or set of sites; and (3) 

estimation of a value estimator model derived from study site data, often from multiple sites (Bergstrom 

and De Civita 1999). Recent studies have shown little support for the accuracy or validity of the first 

method, leading to increased attention to, and use of, adjusted values estimated by one of the remaining 

two approaches (Bergstrom and De Civita 1999). The third class of benefit transfer approaches includes 

meta-analysis techniques, which have been increasingly explored by economists as a potential basis of 

policy analysis conducted by various government agencies charged with the stewardship of natural 

resources. 29 

Section 7.2 provides a brief overview of the benefit transfer methodology used for estimating the 

recreational fishing benefits, and highlights the updates to methodology. Chapter A5 of EPA’s Regional 

Benefits Analysis of the Final Section 316(b) Phase III Existing Facilities Rule (USEPA 2006b) provides 

a detailed description of the benefit transfer methodology that is employed in this analysis. Section 7.3 

presents the recreational fishing benefits by region, and Section 7.4 summarizes the limitations and 

uncertainties inherent in EPA’s analysis of recreational fishing benefits. 

7.2 Methodology 

EPA’s analysis of recreational fishing benefits from reducing I&E mortality at cooling water intake 

structures (CWISs) at the in-scope facilities includes the following general steps: 

1. Estimate the forgone catch of recreational fish (in number of fish) attributable to I&E 

mortality under current conditions. EPA modeled these losses using the methods presented in 

 

29 Meta-analysis is “the statistical analysis of a large collection of results from individual studies for the purposes of integrating 

the findings” (Glass 1976). 
March 28, 2011 7-2 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Chapter 3 of this document. EPA’s estimates of recreational fish losses are expressed as the 

number of harvestable adults, rather than age-1 equivalents (A1Es), so as to not overstate the 

increases in catch resulting from 316(b) regulatory options.30 Many of the fish species affected by 

I&E mortality at CWIS sites are harvested both recreationally and commercially. EPA used the 

proportion of total species landings attributable to recreational fishing to estimate baseline 

welfare losses to recreational anglers from current levels of I&E mortality and benefits from 

reducing I&E mortality under alternative policy options. 

2. Estimate the marginal value per fish. EPA used the estimated meta-regression described in 

Chapter A5 of EPA (USEPA 2006b) to estimate marginal values per fish for the species affected 

by I&E mortality at Phase II facilities. To calculate the marginal value per fish for the affected 

species, EPA chose input values for the independent variables based on the affected species 

characteristics, study regions, and demographic characteristics of the affected angling 

populations. The study design variables were selected based on current economic literature. This 

step is described in more detail in Section 7.2.1. 

3. Estimate the value of forgone recreational catch lost to I&E mortality under the baseline 

scenario by multiplying the marginal value per fish by the number of recreational fish currently 

lost to I&E mortality that would otherwise be caught by recreational anglers. 

4. Estimate recreational fishing benefits from reducing I&E mortality losses at the in-scope 

facilities’ CWISs by multiplying the marginal value per fish by the reduction in recreational 

fishing losses under the alternative policy options. 

7.2.1 Estimating Marginal Value per Fish 

To estimate marginal values per fish for the species affected by I&E mortality at in-scope facilities, EPA 

used a benefit transfer function based on meta-analysis of recreational fishing studies from the Section 

316(b) Phase III Final Rule. The general approach follows standard methods illustrated by Johnston et al.

(2006) and Shrestha et al. (2007), among many others (Rosenberger and Phipps 2007). This function 

allows EPA to forecast willingness to pay (WTP) based on assigned values for model variables, chosen to 

best represent a resource change in the 316(b) policy context. EPA’s meta-analysis results imply a simple 

benefit function of the following general form: 

ln(WTP) = intercept + ∑(coefficienti)(Independent Variable Valuesi) (Eq. 7-1) 

Here, ln(WTP) is the dependent variable in the meta-analysis—the natural log of WTP for catching an 

additional fish. The independent variables included in the meta-analysis characterize the species being 

valued, study location, baseline catch rate, elicitation and survey methods, demographics of survey 

respondents, and other specific characteristics of each study. 

To calculate the marginal value per fish for the species affected by in-scope facilities, EPA chose input 

values for the independent variables based on the affected species’ characteristics, study regions, and 

demographic characteristics of the affected angling populations. The study design variables were selected 

based on current economic literature. Table 7-1 provides the independent variable names, the estimated 

variable coefficients (coefficienti), and the assigned input values for each of the independent variables in 

the model. 

 

30 Adult fish of harvestable age means that they are the age at which they can legally be harvested. 
March 28, 2011 7-3 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

EPA followed Johnston et al. (2006) in assigning values for methodological attributes (i.e., variables 

characterizing the study methodology used in the original source studies), which are set at mean values 

from the metadata except in cases where theoretical considerations dictate alternative specifications. This 

follows general guidance from Bergstrom and Taylor (2006) that meta-analysis benefit transfer should 

incorporate theoretical expectations and structures, at least in a weak form. In this instance, two of the 

methodology variables, RUM_nest and high_resp_rate, are included with an assigned value of one. 

RUM_year is given the value of 9.37, which corresponds to the average study year, 1985. 

EPA decided not to include the error term when using the regression equation to predict marginal values 

per fish. Bockstael and Strand (1987) argue that if the econometric error in an equation is primarily due to 

omitted variables, the error term should be included, but if the error is primarily due to random 

preferences, it should be excluded. EPA did not conclude whether the error is primarily due to omitted 

variables or random preferences. Because the error term is positive, the empirical effect of including this 

term is to increase the predicted marginal values. Therefore, EPA excluded the error term in order to 

result in more- conservative estimates. EPA also notes that when the error term is excluded, the values 

predicted by the regression equation are more consistent with those from the underlying studies. 

Table 7-2 presents region- and species-specific values for the input variables that vary across regions and 

Table 7-3 presents the estimated marginal value per fish for all species affected by I&E mortality in each 

region. 

Table 7-1: Independent Variable Assignments for Regression Equation 

Variable Coefficient Assigned Value Explanation 

Intercept -1.4568 1 The equation intercept was set to one by default. 

SP_conjoint -1.1672 0 

Current academic literature suggests that nested RUM models 

produce the most accurate valuation results, so RUM_nest was set 

to one, and the other study methodology variables were set to zero. 

SP_dichot -0.9958 0 

TC_individual 1.1091 0 

TC_zonal 2.0480 0 

RUM_nest 1.3324 1 

RUM_nonnest 1.7892 0 

sp_year 0.08754 0 

RUM_year was set equal to the average value across the studies in 

the analysis, 9.37. tc_year -0.03965 0 

RUM_year -0.00291 9.37 

sp_mail 0.5440 0 Since RUM_nest was the model specified above, sp_mail and 

sp_phone 1.0859 0 sp_phone were set to zero. 

high_resp_rate -0.6539 1 High survey response rates are desirable because they may provide 

more-accurate estimates, so high_response_rate was set to one. 

inc_thou 0.003872 Varies Inc_thou was set to the median household income for each study 

region evaluated, based on U.S. Census data. 

age42_down 0.9206 0.0972 Age42_down and age43_up were set to their sample means. age43_up 1.2221 0.2711 

trips19_down 0.8392 0.1100 Trips19_down and trips20_up were set to their sample means. trips20_up -1.0112 0.3350 

nonlocal 3.2355 0 

Because the default (zero) value for the nonlocal dummy variable 

represents a combination of local and nonlocal anglers, nonlocal

was set to zero. 
March 28, 2011 7-4 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 7-1: Independent Variable Assignments for Regression Equation 

Variable Coefficient Assigned Value Explanation 

big_game_pac 2.2530 Varies 

Species-targeted variables were assigned input values based on 

characteristics of the species affected by I&E mortality and the 

study region. In general, the match between the affected species 

and the variables in the meta-analysis equation was good. 

big_game_natl 1.5323 Varies 

big_game_satl 2.3821 Varies 

small_game_pac 1.6227 Varies 

small_game_atl 1.4099 Varies 

flatfish_pac 1.8909 Varies 

flatfish_atl 1.3797 Varies 

other_sw 0.7339 Varies 

musky 3.8671 Varies 

pike_walleye 1.0412 Varies 

bass_fw 1.7780 Varies 

trout_GL 1.8723 Varies 

trout_nonGL 0.8632 Varies 

salmon_pacific 2.3570 Varies 

salmon_atl_more

y 

5.2689 Varies 

salmon_GL 2.2135 Varies 

steelhead_pac 2.1904 Varies 

steelhead_GL 2.3393 Varies 

cr_nonyear -0.08135 Varies The variable cr_nonyear was assigned species and region-specific 

values for the coastal and Great Lakes regions based on catch rates 

data provided by the National Marine Fisheries Service (NMFS 

2002; 2003) and the Michigan Department of Natural Resources 

(MDNR 2002). For the Inland region, EPA assigned values to the 

cr_nonyear variable based on the average values for each species 

from the studies. The variable spec_cr was set to one. Cr_year and 

catch_year were set to zero, since catch per trip and catch per day 

are more common measures of angling quality. 

cr_year -0.05208 0 

catch_year 1.2693 0 

spec_cr 0.6862 1 

shore -0.1129 Varies 

Shore was assigned values based on NMFS (2002; 2003) and U.S. 

Fish and Wildlife Service (USDOI and USDOC 2002) survey data 

indicating the average percentage of anglers who fish from shore in 

each region. 

Source:U.S. EPA (2006b) 
March 28, 2011 7-5 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 7-2: Region- and Species-specific Variable Assignments for the Regression Equation 

Variable 

Region 

California North 

Atlantic 

MidAtlantic South 

Atlantic 

Gulf of 

Mexico 

Great 

Lakes Inland 

inc_thou 54.385 55.000 51.846 40.730 36.641 44.519 58.240 

Shore 24.0 24.0 23.1 30.0 25.0 48.0 57.0 

Species Species Type 

Dummy Variablea Baseline Catch Rate, Expressed in Fish per Day (cr_nonyear) 

Small gameb small_game_atl, 

small_game_pac

2.7 1.6 1.6 2.2 2.2 2.1 

Flatfishc flatfish_atl, 

flatfish_pac

1.3 1.0 1.0 1.5 

Other saltwater other_sw 1.7 1.7 1.7 1.7 1.7 

Salmon Salmon_GL 0.2 0.2 

Walleye/pike pike_walleye 0.8 0.8 

Bass bass_fw 0.2 0.2 

Panfishd 4.7 4.7 4.7 

Trout 3.2 3.2 

Unidentified 1.7 1.7 1.7 1.7 1.9 1.9 3.8 

a

 This column indicates which species type dummy variable was set to one to represent each species. 

b

 For “small game” fish in the North Atlantic, Mid-Atlantic, South Atlantic, Gulf of Mexico, and Inland regions, small_game_atl

was set to one. For “small game” fish in the California region, small_game_pac was set to one. c

 For “flatfish” in the North Atlantic, Mid-Atlantic, South Atlantic, Gulf of Mexico, Great Lakes, and Inland regions, flatfish_atl

was set to one. For flatfish in the California region, flatfish_pac was set to one. d

 To indicate that the target species was “panfish,” all species type dummy variables were set to zero. 

Source: U.S. EPA (2006b) 

Table 7-3: Marginal Recreational Value per Fish, by Region and Speciesa

Species California North Atlantic Mid-Atlantic South 

Atlantic 

Gulf of 

Mexico Great Lakes Inland 

Small game $7.23 $5.92 $5.88 $5.70 $5.61 $5.34 

Flatfish $9.73 $5.94 $5.60 $5.60 

Other saltwater $2.95 $2.97 $2.91 $2.84 $2.76 

Salmon $13.22 $13.22 

Walleye/pike $4.10 $4.09 

Bass $8.53 $8.98 

Panfish $1.06 $1.32 $1.06 

Trout $9.41 $2.81 

Unidentified $3.09 $3.00 $3.23 $2.86 $3.65 $6.20 $2.22 a

 All values are in 2009$. 

Source: U.S. EPA (2006b), converted to 2009$ using the Consumer Price Index (USBLS 2010), 

7.2.2 Calculating Recreational Fishing Benefits 

EPA estimated the recreational welfare gain from eliminating current I&E mortality losses and the 

recreational welfare gain from the regulatory options by combining estimates of the marginal value per 

fish with the estimated recreational fishing losses under the baseline level of I&E mortality and the 

reduction in recreational fishing losses attributable to each regulatory option. To calculate the recreational 
March 28, 2011 7-6 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

welfare gain from eliminating baseline I&E mortality losses, EPA multiplied the marginal value per fish 

by the number of fish that are lost due to baseline I&E mortality that would otherwise be caught by 

recreational anglers. To calculate the recreational welfare gain from each analyzed option, EPA 

multiplied the marginal value per fish by the estimated additional number of fish caught by recreational 

anglers that would have been impinged or entrained in the absence of the regulation. As explained in 

Chapter 3 of this report, these calculations express recreational fish losses as the number of harvestable 

adults. 

7.2.3 Sensitivity Analysis Based on the Krinsky and Robb (1986) Approach 

The meta-analysis model briefly described above can be used to predict mean WTP for catching an 

additional fish. However, estimates derived from regression models are subject to some degree of error 

and uncertainty. To better characterize the uncertainty or error bounds around predicted WTP, EPA 

adopted the statistical procedure described by Krinsky and Robb in their 1986 Review of Economics and 

Statistics paper, “Approximating the Statistical Property of Elasticities.” The procedure involves sampling 

from the variance-covariance matrix and means of the estimated coefficients. WTP values are then 

calculated for each drawing from the variance covariance matrix, and an empirical distribution of WTP 

values is constructed. By varying the number of drawings, it is possible to generate an empirical 

distribution with a desired degree of accuracy (Krinsky and Robb 1986). The lower or upper bound of 

WTP values can then be identified based on the 5th and 95th percentile of WTP values from the empirical 

distribution. These bounds may help decision-makers understand the uncertainty associated with the 

benefit results. 

The results of EPA’s calculations are shown in Table 7-4. The table presents 95th percentile upper 

confidence bounds and 5th percentile lower confidence bounds for the marginal value per fish for each 

species in each region. These bounds can be used to estimate upper and lower confidence bounds for the 

WTP for improvements in recreational catch rates from eliminating baseline I&E mortality losses or 

reducing I&E mortality losses under each regulatory analysis option. Refer to EPA (2006b) for more 

detail on the specific calculations. The 5th percentile values shown in Table 7-4 show that, with the 

exception of panfish, even the lowest estimates of recreational value are greater than $1 per fish. 
March 28, 2011 7-7 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 7-4: Confidence Bounds on Marginal Recreational Value per Fish, Based on the 

Krinsky and Robb Approacha

Species California North 

Atlantic 

MidAtlantic South 

Atlantic 

Gulf of 

Mexico 

Great 

Lakes Inland 

5th Percentile Lower Confidence Boundsb

Small game $4.19 $2.12 $2.26 $2.71 $2.86 $1.60

Flatfish $5.10 $3.80 $3.74 $3.86 

Other saltwater $1.78 $1.78 $1.84 $2.14 $2.13 

Salmon $8.40 $8.12 $8.12

Walleye/pike $2.17 $11.98

Bass $4.41 $4.27

Panfish $0.53 $0.69 $0.53

Trout $6.08 $1.51

Unidentified $1.85 $1.80 $1.90 $2.14 $2.36 $3.32 $1.08

95th Percentile Upper Confidence Boundsb

Small game $12.40 $16.70 $15.46 $11.99 $11.00 $18.00

Flatfish $18.56 $9.40 $8.49 $8.25 

Other saltwater $4.87 $4.96 $4.58 $3.77 $3.60 

Salmon $28.70 $21.53 $21.53

Walleye/pike $7.77 $8.49

Bass $16.56 $19.01

Panfish $2.10 $2.48 $2.10

Trout $14.61 $5.27

Unidentified $5.16 $5.01 $5.71 $3.81 $5.89 $11.67 $4.58

a

 All values are in 2009$. 

b

 Upper and lower confidence bounds based on results of the Krinsky and Robb (1986) approach. 

Source: U.S. EPA (2006b), converted to 2009$ using the Consumer Price Index (USBLS 2010). 

7.3 Benefits Estimates for Recreational Fishing by Region 

7.3.1 California 

Table 7-5 shows the results of EPA’s analysis of the recreational fishing losses from I&E mortality under 

the baseline conditions at in-scope facilities in California. Baseline recreational fishing losses from I&E 

mortality in the California region amount to 1.0 million fish per year. The majority of recreational losses 

from I&E mortality under baseline conditions are attributable to entrainment of rockfish and sea bass. 

Table 7-5 shows the results of EPA’s analysis of the potential welfare gain to recreational anglers from 

eliminating baseline recreational fishing losses at in-scope facilities in California. The estimated mean 

annual welfare gain to California anglers from eliminating all of these losses is $2.9 million and $2.8 

million evaluated at 3 percent and 7 percent discount rates, respectively. The majority of the monetized 

recreational benefits from eliminating baseline I&E mortality are attributable to eliminating entrainment 

of “other saltwater” fish31. Appendix I presents additional species-specific results. 

 

31 The “other saltwater” species group includes banded drum, black drum, chubby, cod family, cow cod, croaker, grouper, 

grunion, grunt, high-hat, kingfish, lingcod, other drum, perch, porgy, rockfish, sablefish, sand drum, sculpin, sea bass, smelt, 

snapper, spot, spotted drum, star drum, white sea bass, wreckfish, other bottom species, other coastal pelagics, and “no 

target” saltwater species. 
March 28, 2011 7-8 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

As shown in Table 7-5, the estimated reduction in I&E mortality leads to an estimated annual increase in 

recreational fishery harvest of less than 0.1 million fish under Option 1 and approximately 0.9 million fish 

per year under Options 2 and 3. Discounted at 3 percent, the estimated mean annualized welfare gain to 

California anglers is approximately $0.1 million under Option 1, $1.7 million under Option 2, $1.8 

million under Option 3. Discounted at 7 percent, the estimated mean annualized welfare gain is $1.3 

million and $1.4 million under Options 2 and 3, and $0.1 million under Option 1 (Table 7-5). Appendix I 

presents additional species-specific results. 

Table 7-5: Recreational Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality 

Losses at In-Scope Facilities in the California Region, by Regulatory Option (2009$) 

5th Mean 95th 5th Mean 95th

Baseline 1,022,339 $1,740 $2,923 $4,917 $1,681 $2,823 $4,750

Option 1 36,438 $51 $85 $141 $46 $75 $125

Option 2 876,841 $1,037 $1,741 $2,929 $792 $1,330 $2,237

Option 3 915,750 $1,096 $1,840 $3,095 $832 $1,396 $2,349

Annual Increase in 

Recreational Harvest

(harvestable adult fish)

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for 

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere; Option 4 = I for Facilities > 50 MGD

Regulatory 

Option 3 % Discount Rate 7 % Discount Rate

Annualized Benefits from Increase in Recreational Harvest 

(2009$, thousands)

7.3.2 North Atlantic Region 

Table 7-6 shows the results of EPA’s analysis of the recreational fishing losses from I&E mortality under 

the baseline conditions at in-scope facilities in the North Atlantic region. Baseline recreational fishing 

losses from I&E mortality in the North Atlantic region amount to 0.8 million fish per year. The majority 

of recreational losses from I&E mortality under baseline conditions are attributable to entrainment of 

winter flounder, cunner, and sculpin. Table 7-6 shows the results of EPA’s analysis of the potential 

welfare gain to recreational anglers from eliminating baseline recreational fishing losses at in-scope 

facilities in the North Atlantic. The estimated mean annual welfare gain to North Atlantic anglers from 

eliminating all of these losses is $2.8 million and $2.7 million evaluated at 3 percent and 7 percent 

discount rates, respectively. The majority of the monetized recreational benefits from eliminating baseline 

I&E mortality are attributable to eliminating the entrainment of “flatfish” and “other saltwater” fish. 

Appendix I presents additional species-specific results. 

As shown in Table 7-6, the estimated reduction in I&E mortality leads to an estimated annual increase in 

recreational fishery harvest of less than 0.1 million fish under Option 1, 0.6 million fish under Option 2, 

and 0.7 million fish under Option 3. Discounted at 3 percent, the estimated mean annualized welfare gain 

to North Atlantic anglers is less than $0.1 million under Option 1, $1.5 million under Option 2, and $1.6 

million under Option 3. Discounted at 7 percent, the estimated mean annualized welfare gain is less than 

$0.1 million under Option 1, $1.1 million under Option 2, and $1.2 million under Option 3 (Table 7-6). 

Appendix I presents additional species-specific results. 
March 28, 2011 7-9 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 7-6: Recreational Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality 

Losses at In-Scope Facilities in the North Atlantic Region, by Regulatory Option (2009$) 

5th Mean 95th 5th Mean 95th

Baseline 761,183 $1,765 $2,838 $4,596 $1,705 $2,742 $4,440

Option 1 1,495 $3 $5 $9 $3 $5 $8

Option 2 620,929 $939 $1,510 $2,446 $698 $1,122 $1,817

Option 3 651,307 $1,018 $1,638 $2,652 $756 $1,216 $1,969

Annual Increase in 

Recreational Harvest

(harvestable adult fish)

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for 

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere; Option 4 = I for Facilities > 50 MGD

Regulatory 

Option

Annualized Benefits from Increase in Recreational Harvest 

(2009$, thousands)

3 % Discount Rate 7 % Discount Rate

7.3.3 Mid-Atlantic Region 

Table 7-7 shows the results of EPA’s analysis of the recreational fishing losses from I&E mortality under 

the baseline conditions at in-scope facilities in the Mid-Atlantic region. Baseline recreational fishing 

losses from I&E mortality in the Mid-Atlantic region amount to 9.1 million fish per year. The majority of 

recreational losses from I&E mortality under baseline conditions are attributable to I&E mortality of spot, 

Atlantic croaker, and “other saltwater” fish. Table 7-7 shows the results of EPA’s analysis of the potential 

welfare gain to recreational anglers from eliminating baseline recreational fishing losses at in-scope 

facilities in the Mid-Atlantic. The estimated mean annual welfare gain to Mid-Atlantic anglers from 

eliminating all of these losses is $25.6 million and $24.7 million evaluated at 3 percent and 7 percent 

discount rates, respectively. The majority of the monetized recreational benefits from eliminating baseline 

I&E mortality are attributable to eliminating the entrainment of other saltwater fish. Appendix I presents 

additional species-specific results. 

As shown in Table 7-7, the estimated reduction in I&E mortality leads to an estimated annual increase in 

recreational fishery harvest of approximately 0.6 million fish under Option 1, 8.4 million fish under 

Option 2, and 8.5 million fish under Option 3. Discounted at 3 percent, the estimated mean annualized 

welfare gain to Mid-Atlantic anglers is $14.1 million and $14.4 million under Options 2 and 3, and $1.6 

million under Option 1. Discounted at 7 percent, the estimated mean annualized welfare gain is $9.8 

million and $10.0 million under Options 2 and 3, and $1.4 million under Option 1 (Table 7-7). Appendix 

I presents additional species-specific results. 

Table 7-7: Recreational Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality 

Losses at In-Scope Facilities in the Mid-Atlantic Region, by Regulatory Option (2009$) 

5th Mean 95th 5th Mean 95th

Baseline 9,081,061 $15,239 $25,569 $44,467 $14,721 $24,701 $42,958

Option 1 549,015 $846 $1,577 $3,136 $749 $1,396 $2,776

Option 2 8,359,591 $8,381 $14,073 $24,501 $5,831 $9,792 $17,049

Option 3 8,459,880 $8,584 $14,410 $25,078 $5,975 $10,030 $17,456

Annual Increase in 

Recreational Harvest

(harvestable adult fish)

Regulatory 

Option

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for 

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere; Option 4 = I for Facilities > 50 MGD

Annualized Benefits from Increase in Recreational Harvest 

(2009$, thousands)

3 % Discount Rate 7 % Discount Rate
March 28, 2011 7-10 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

7.3.4 South Atlantic Region 

Table 7-8 shows the results of EPA’s analysis of the recreational fishing losses from I&E mortality under 

the baseline conditions at in-scope facilities in the South Atlantic region. Baseline recreational fishing 

losses from I&E mortality in the South Atlantic region amount to 0.1 million fish per year. The majority 

of recreational losses from I&E mortality under baseline conditions are attributable to I&E mortality of 

“other saltwater” fish, especially spot and croakers. Table 7-8 shows the results of EPA’s analysis of the 

potential welfare gain to recreational anglers from eliminating baseline recreational fishing losses at inscope facilities in the South Atlantic. The estimated mean annual welfare gain to South Atlantic anglers 

from eliminating all of these losses is approximately $0.3 million evaluated at both 3 percent and 7 

percent discount rates. The majority of the monetized recreational benefits from eliminating baseline I&E 

mortality are attributable to eliminating impingement of “other saltwater” fish. Appendix I presents 

additional species-specific results. 

As shown in Table 7-8, the estimated reduction in I&E mortality leads to an estimated annual increase in 

recreational fishery harvest of approximately 0.1 million fish under Options 2 and 3, and less than 0.1 

million fish per year under Option 1. Discounted at 3 percent, the estimated mean annualized welfare gain 

to South Atlantic anglers is $0.2 million under Options 2 and 3, and less than $0.1 million under Option 1. 

Discounted at 7 percent, the estimated mean annualized welfare gain is $0.1 million under Options 2 and 

3, and less than $0.1 million under Option 1 (Table 7-8). Appendix I presents additional species-specific 

results. 

Table 7-8: Recreational Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality 

Losses at In-Scope Facilities in the South Atlantic Region, by Regulatory Option (2009$) 

5th Mean 95th 5th Mean 95th

Baseline 133,897 $257 $346 $469 $249 $335 $453

Option 1 15,882 $28 $37 $50 $24 $33 $45

Option 2 112,139 $141 $190 $257 $103 $139 $188

Option 3 112,301 $141 $190 $257 $103 $139 $188

Annual Increase in 

Recreational Harvest

(harvestable adult fish)

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for 

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere; Option 4 = I for Facilities > 50 MGD

Regulatory 

Option

Annualized Benefits from Increase in Recreational Harvest 

(2009$, thousands)

3 % Discount Rate 7 % Discount Rate

7.3.5 Gulf of Mexico 

Table 7-9 shows the results of EPA’s analysis of the recreational fishing losses from I&E mortality under 

the baseline conditions at in-scope facilities in the Gulf of Mexico region. Baseline recreational fishing 

losses from I&E mortality in the Gulf of Mexico region amount to 2.9 million fish per year. The majority 

of recreational losses from I&E mortality under baseline conditions are attributable to the impingement of 

spotted seatrout and the entrainment of black drum and “other saltwater” fish. Table 7-9 shows the results 

of EPA’s analysis of the potential welfare gain to recreational anglers from eliminating baseline 

recreational fishing losses at in-scope facilities in the Gulf of Mexico. The estimated mean annual welfare 

gain to Gulf of Mexico anglers from eliminating all of these losses is $8.9 million and $8.8 million 

evaluated at 3 percent and 7 percent discount rates, repectively. The majority of the monetized 

recreational benefits from eliminating baseline I&E mortality are attributable to both the impingement of 
March 28, 2011 7-11 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

“small game” fish and the entrainment of “other saltwater” species. Appendix I presents additional 

species-specific results. 

As shown in Table 7-9, the estimated reduction in I&E mortality leads to an estimated annual increase in 

recreational fishery harvest of approximately 2.2 million fish under Options 2 and 3, and 0.7 million fish 

per year under Option 1. Discounted at 3 percent, the estimated mean annualized welfare gain to Gulf of 

Mexico anglers is $2.4 million under Option 1, and $4.9 million under Options 2 and 3. Discounted at 7 

percent, the estimated mean annualized welfare gain is $2.2 million under Option 1, and $3.8 million 

under Options 2 and 3 (Table 7-9). Appendix I presents additional species-specific results. 

Table 7-9: Recreational Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality 

Losses at In-Scope Facilities in the Gulf of Mexico Region, by Regulatory Option (2009$) 

5th Mean 95th 5th Mean 95th

Baseline 2,851,347 $6,022 $8,852 $13,506 $5,999 $8,818 $13,456

Option 1 665,697 $1,398 $2,422 $4,334 $1,275 $2,210 $3,953

Option 2 2,204,063 $3,225 $4,866 $7,642 $2,491 $3,760 $5,908

Option 3 2,208,009 $3,258 $4,906 $7,690 $2,510 $3,781 $5,926

Annual Increase in 

Recreational Harvest

(harvestable adult fish)

Regulatory 

Option

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for 

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere; Option 4 = I for Facilities > 50 MGD

3 % Discount Rate

Annualized Benefits from Increase in Recreational Harvest 

(2009$, thousands)

7 % Discount Rate

7.3.6 Great Lakes Region 

Table 7-10 shows the results of EPA’s analysis of the recreational fishing losses from I&E mortality 

under the baseline conditions at in-scope facilities in the Great Lakes region. Baseline recreational fishing 

losses from I&E mortality in the Great Lakes region amount to 0.3 million fish per year. The majority of 

recreational losses from I&E mortality under baseline conditions are attributable to impingement of 

whitefish and entrainment of “unidentified” species. Table 7-10 shows the results of EPA’s analysis of the 

potential welfare gain to recreational anglers from eliminating baseline recreational fishing losses at inscope facilities in the Great Lakes. The estimated mean annual welfare gain to Great Lakes anglers from 

eliminating all of these losses is $2.0 million evaluated at both 3 percent and 7 percent discount rates. The 

majority of the monetized recreational benefits from eliminating baseline I&E mortality are attributable to 

eliminating the impingement of “other trout” and “unidentified” fish. Appendix I presents additional 

species-specific results. 

As shown in Table 7-10, the estimated reduction in I&E mortality leads to an estimated annual increase in 

recreational fishery harvest of approximately 0.2 million fish per year under Option 1, and 0.3 million fish 

under Options 2 and 3. Discounted at 3 percent, the estimated mean annualized welfare gain to Great 

Lakes anglers is $1.3 million under Options 2 and 3, and $1.0 million under Option 1. Discounted at 7 

percent, the estimated mean annualized welfare gain is $1.0 million under Options 2 and 3, and $0.9 

million under Option 1 (Table 7-10). Appendix I presents additional species-specific results. 
March 28, 2011 7-12 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 7-10: Recreational Fishing Benefits from Eliminating or Reducing Baseline I&E 

Mortality Losses at In-Scope Facilities in the Great Lakes Region, by Regulatory Option 

(2009$) 

5th Mean 95th 5th Mean 95th

Baseline 349,648 $1,127 $1,984 $3,544 $1,123 $1,977 $3,530

Option 1 176,089 $561 $951 $1,638 $511 $867 $1,495

Option 2 317,974 $720 $1,261 $2,241 $559 $979 $1,739

Option 3 320,196 $725 $1,271 $2,261 $561 $984 $1,750

Annual Increase in 

Recreational Harvest

(harvestable adult fish)

Regulatory 

Option

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for 

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere; Option 4 = I for Facilities > 50 MGD

Annualized Benefits from Increase in Recreational Harvest 

(2009$, thousands)

3 % Discount Rate 7 % Discount Rate

7.3.7 Inland Region 

Table 7-11 shows the results of EPA’s analysis of the recreational fishing losses from I&E mortality 

under the baseline conditions at in-scope facilities in the Inland region. Baseline recreational fishing 

losses from I&E mortality in the Inland region amount to 12.6 million fish per year. The majority of 

recreational losses from I&E mortality under baseline conditions are attributable to I&E mortality of 

“bass,” “panfish,” and “unidentified” species groups. Table 7-11 shows the results of EPA’s analysis of 

the potential welfare gain to recreational anglers from eliminating baseline recreational fishing losses at 

in-scope facilities in the Inland region. The estimated mean annual welfare gain to Inland anglers from 

eliminating all of these losses is $34.4 million and $34.2 million evaluated at 3 percent and 7 percent 

discount rates, respectively. The majority of the monetized recreational benefits from eliminating baseline 

I&E mortality are attributable to eliminating I&E mortality of “bass,” “panfish,” and “unidentified” fish. 

Appendix I presents additional species-specific results. 

As shown in Table 7-11, the estimated reduction in I&E mortality leads to an estimated annual increase in 

recreational fishery harvest of approximately 11.1 million fish and 11.4 million fish under Options 2 and 

3, and 4.7 million fish per year under Option 1. Discounted at 3 percent, the estimated mean annualized 

welfare gain to Inland anglers is $19.9 million and $20.7 million under Options 2 and 3, and $10.5 

million under Option 1. Discounted at 7 percent, the estimated mean annualized welfare gain is $9.6 

million under Option 1, $15.3 million under Option 2, and $15.8 million under Option 3 (Table 7-11). 

Appendix I presents additional species-specific results. 
March 28, 2011 7-13 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 7-11: Recreational Fishing Benefits from Eliminating or Reducing Baseline I&E 

Mortality Losses at In-Scope Facilities in the Inland Region, by Regulatory Option (2009$) 

5th Mean 95th 5th Mean 95th

Baseline 12,592,464 $16,566 $34,376 $71,653 $16,504 $34,247 $71,384

Option 1 4,321,037 $5,071 $10,545 $22,049 $4,626 $9,619 $20,115

Option 2 11,061,370 $9,578 $19,879 $41,449 $7,361 $15,277 $31,856

Option 3 11,389,049 $9,966 $20,684 $43,122 $7,592 $15,755 $32,847

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for 

Facilities >125 MGD; Option 3 = I&E Mortality Everywhere; Option 4 = I for Facilities > 50 MGD

Annual Increase in 

Recreational Harvest

(harvestable adult fish)

Regulatory 

Option

Annualized Benefits from Increase in Recreational Harvest 

(2009$, thousands)

3 % Discount Rate 7 % Discount Rate

7.4 Limitations and Uncertainties 

A number of limitations and uncertainties are common to all WTP values predicted using benefit transfer. 

To better characterize the uncertainty or error bounds around predicted WTP, EPA adopted the statistical 

procedure described by Krinsky and Robb in their 1986 Review of Economics and Statistics paper 

“Approximating the Statistical Property of Elasticities.” This procedure was used to generate lower and 

upper bound WTP values identified as the 5th and 95th percentile of values from the empirical 

distribution. Additional detail regarding the Krinsky and Robb approach is provided in Section 7.2.3. 

These bounds may help decision-makers understand the uncertainty associated with the benefit results for 

the elimination of baseline I&E mortality losses and 316(b) regulatory options. 

Specific limitations and uncertainties associated with the estimated regression model and the underlying 

studies are discussed in Section A5-3.3 of EPA (2006b). Additional limitations and uncertainties 

associated with implementation of the meta-analysis approach are addressed below. 

7.4.1 Variable Assignments for Independent Regressors 

The per-fish values estimated from the model depend on the values of the input variables in the metaanalysis. EPA assigned values to the input variables based on established economic theory and 

characteristics of the affected species and regions. However, because the input values for some variables 

are uncertain, the resulting per-fish values and benefits estimates also include some degree of uncertainty. 

7.4.2 Exclusion of Error Term from Regression Equation to Predict Marginal Values 

EPA decided not to include the error term when using the regression equation to predict marginal values 

per fish. Bockstael and Strand (1987) argue that if the source of econometric error in an equation is 

primarily due to omitted variables, the error term should be included, but if the error is primarily due to 

random preferences, it should be excluded. EPA did not conclude whether the error is primarily due to 

omitted variables or random preferences. Because the error term is positive, the empirical effect of 

including this term is to increase the predicted marginal values. Therefore, EPA excluded the error term in 

order to result in more- conservative estimates. EPA also notes that when the error term is excluded, the 

values predicted by the regression equation are more consistent with those from the underlying studies. 

This indicates that convergent validity is greater when the error term is excluded. 
March 28, 2011 7-14 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

7.4.3 Other Limitations and Uncertainties 

In addition to the limitations and uncertainties involved with the study data and model estimation, which 

are discussed in Section A5-3.3e of EPA (2006b), there are limitations and uncertainties involved with the 

calculation of per-fish values from the model, and with the use of those values to estimate the welfare 

gain resulting from the regulatory options considered for the final Section 316(b) regulation for existing 

Phase II facilities. 

The validity and reliability of benefit transfer—including that based on meta-analysis—depends on a 

variety of factors. While benefit transfer can provide valid measures of use benefits, tests of its 

performance have provided mixed results (e.g., Desvousges et al. 1998; Smith et al. 2002; Vandenberg et 

al. 2001). Nonetheless, benefit transfers are increasingly applied as a core component of benefit-cost 

analyses conducted by EPA and other government agencies (Bergstrom and De Civita 1999; Griffiths 

undated). Smith et al. (2002, p.134) state that “nearly all benefit cost analyses rely on benefit transfers, 

whether they acknowledge it or not.” 

An important factor in any benefit transfer is the ability of the study site or estimated valuation equation 

to approximate the resource and context for which benefit estimates are desired. As is common, the metaanalysis model presented here provides a close but not perfect match to the context in which values are 

desired. 

The final area of uncertainty related to the use of the regression results to calculate regulatory benefits is 

uncertainty in the estimates of I&E mortality. There are a number of reasons why recreational losses due 

to I&E mortality may be higher or lower than expected. Projected changes in recreational catch may be 

underestimated because cumulative impacts of I&E mortality over time are not considered. In particular, 

I&E mortality estimates include only individuals directly lost to I&E mortality, not their progeny. 

Additionally, the interaction of I&E mortality with other stressors may have either a positive or negative 

effect on recreational catch. Finally, in estimating recreational fishing losses, EPA used the most current 

I&E mortality data available provided by facilities, which in some cases may not reflect current 

conditions. 
March 28, 2011 8-1 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

8 Nonuse Benefits of Reducing I&E Mortality 

8.1 Introduction 

Comprehensive estimates of total resource value include both use and nonuse values, such that the 

resulting total value estimate may be compared to total social cost. “Non-use values, like use values, have 

their basis in the theory of individual preferences and the measurement of welfare changes. According to 

theory, use values and non-use values are additive” (Freeman III 1993). Consequently, excluding nonuse 

values from consideration is likely to substantially understate total social values. Recent economic 

literature provides substantial support for the hypothesis that nonuse values are greater than zero for many 

types of environmental improvements. Moreover, when a substantial fraction of the population holds even 

small per capita nonuse values, these nonuse values can be very large in the aggregate. As stated by 

Freeman (1993), “there is a real possibility that ignoring non-use values could result in serious 

misallocation of resources.” Consequently, both EPA’s own Guidelines for Preparing Economic Analysis 

and OMB’s Circular A-4, governing regulatory analysis, support the need to assess nonuse values 

(USEPA 2000a; USOMB 2003). 

The vast majority (97 percent) of current (i.e., baseline) impingement and entrainment mortality (I&E 

mortality) losses at cooling water intake structures (CWISs) consist of forage species or unlanded 

individuals of recreational and commercial species (Chapter 3). Although these forage fish and unlanded 

fish do not have direct use values, they may be valued by users (commercial fishers and recreational 

anglers) and nonusers of fisheries resources. Additionally, the nonuse values are likely to be substantial, 

because fish and other species found within aquatic habitats impacted directly and indirectly by CWISs 

provide other valuable ecosystem goods and services, including nutrient cycling and ecosystem stability. 

Therefore, a comprehensive estimate of the welfare gain from reducing I&E mortality losses must include 

an estimate of nonuse benefits. 

The following sections present EPA’s qualitative and quantitative assessments of nonuse benefits. EPA 

qualitatively evaluated the public’s nonuse values for aquatic habitats by considering evidence from 

existing aquatic restoration and protection programs (Section 8.2). This chapter also presents EPA’s 

benefit transfer approach for the quantification of nonuse benefits associated with reductions in I&E 

mortality of fish, shellfish, and other aquatic organisms under the 316(b) regulatory options in the North 

Atlantic and Mid-Atlantic Regions (Section 8.3). Section 8.4 presents estimated nonuse benefits under the 

316(b) regulatory options. 

8.2 Public Policy Significance of Ecological Improvements from the 

Proposed 316(b) Regulation for Existing Facilities 

Changes to CWIS design and operation resulting from 316(b) regulation of existing facilities is expected 

to reduce I&E mortality losses of fish, shellfish, and other aquatic organisms. These direct benefits are 

believed to lead to increases in local and regional fishery populations and ecosystem stability. Moreover, 

many indirect ecosystem goods and services are affected by I&E mortality, thermal effects, and flow 

alteration. Due to the wide-ranging nature of these indirect effects, EPA believes that regulation is likely 

to enhance the value of ecosystem goods and services provided by aquatic habitats, and that regulation 

will help reduce the overall impact of anthropogenic effects on aquatic systems affected by CWISs. Table 

2-4 provides a detailed list of ecosystem services potentially affected by the proposed 316(b) regulation. 
March 28, 2011 8-2 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

EPA assessed the potential magnitude of nonuse benefits that are quantified, but not monetized using 

information regarding government spending on the protection, restoration, and regulation of various 

aquatic habitats. This included Marine Protected Areas (Section 8.2.2) and a subset of freshwater 

ecosystems undergoing large-scale restoration efforts (Section 8.2.3). This spending serves as a lower 

bound of nonuse values in a subset of geographical locations 

8.2.1 Effects on Depleted Fish Populations 

EPA believes that reducing fish mortality from impingement and entrainment (I&E) would contribute to 

the health and sustainability of the affected fish populations by lowering the overall level of mortality for 

these populations. Fish populations suffer from numerous sources of mortality, both natural and 

anthropogenic. Natural sources include weather, predation by other fish, and the availability of food. 

Human impacts that affect fish populations include fishing, pollution, habitat changes, and I&E mortality 

losses at CWISs. Fish populations decline when they are unable to sufficiently compensate for their 

overall level of mortality. Although it is difficult to measure, EPA believes that an aquatic population's 

compensatory ability—the capacity for a species to increase survival, growth, or reproduction rates in 

response to decreased population —is likely compromised by impingement and entrainment mortality 

(I&E mortality) losses and the cumulative impact of other stressors in the environment over extended 

periods of time (USEPA 2006a). Lowering the overall mortality level increases the probability that a 

population will be able to compensate for mortality at a level sufficient to maintain its long-term health. 

In some cases, I&E mortality losses may be a significant source of anthropogenic mortality to alreadydepleted stocks of commercially targeted species (see Table 2-3). Depleted saltwater fish stocks affected 

by I&E mortality include winter flounder, Atlantic Cod, and rockfishes, for example (NMFS 2010a). As 

discussed in Section 2.3.1, I&E mortality also increases the pressure on freshwater species native to the 

Great Lakes, such as lake whitefish and yellow perch, whose populations have dramatically declined in 

recent years (USDOI 2008; Wisconsin DNR 2003). 

The federal government and the states have recognized the public importance of maintaining sustainable 

fisheries, achieving recovery of depleted fish stocks, and ensuring that functioning ecosystems are passed 

to future generations. Actions these governments have taken include buying fishing licenses and fishing 

vessels from individual fishers when stocks appear depressed, imposing restrictions on commercial and 

recreational harvests, conducting large-scale ecosystem restoration projects (USDOI 2008), and creating a 

national system of marine protected areas (Executive Order No. 13158 2001). Together, these 

governmental actions suggest that the public holds substantial nonuse values for aquatic habitats. 

To summarize, EPA believes that reducing fish mortality from I&E mortality along with other measures 

would contribute to the recovery of damaged fish populations. 

8.2.2 Marine Protected Areas 

A Marine Protected Area (MPA) is “any area of the marine environment that has been reserved by 

federal, state, tribal, territorial, or local laws or regulations to provide lasting protection for part or all of 

the natural and cultural resources therein” (Executive Order No. 13158 2001). In some states, the majority 

of coastal waters are found within MPAs (e.g., Massachusetts, Hawaii). The ecological importance of 

MPAs varies widely because of their broad focus on the preservation and maintenance of cultural and 

natural resources, and/or sustainable production (NMPAC 2006). Consequently, evaluating the impact of 

CWISs on the entire universe of MPAs may overstate the nonuse values for the ecological benefits 

associated with reductions in I&E mortality. For this reason, EPA focused on MPAs within the National 
March 28, 2011 8-3 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Estuary Program (NEP). The NEP was established in the 1987 amendments to the Clean Water Act 

(CWA) because the “Nation’s estuaries are of great importance to fish and wildlife resources and 

recreation and economic opportunity [and because maintaining] the health and ecological integrity of 

these estuaries is in the national interest” (Water Quality Act 1987). In addition to the 28 estuaries 

designated under the NEP (USEPA 2010a), EPA included facilities found in Chesapeake Bay (itself 

protected by the Chesapeake Bay Program [CBP]). 

Substantial federal and state resources have been directed to the NEP and Chesapeake Bay Program to 

enhance conservation of and knowledge about estuaries. From 2005 to 2007, NEP budgeted $965 million 

to protect and restore aquatic habitat, conduct outreach and research, upgrade stormwater infrastructure, 

and implement other priority actions to benefit the health of the 28 constituent estuaries. Approximately 

$130 million (13.5 percent) of the funding was designated for restoration programs (USEPA 2008). 

Between fiscal years 1995 and 2004, direct funding by federal and state governments to restore 

Chesapeake Bay averaged $366 million (GAO 2005), with an additional $131 million in direct spending 

in fiscal year 2005 (CBP 2007). Moreover, recent governmental action is likely to increase federal 

spending on restoration efforts in the future (Executive Order No. 13508 2009). All told, these 

expenditures reflect high public values for restoring (or protecting) the biological integrity of these 

ecosystems. 

A total of 116 Section 316(b) facilities exist on 75 waterbodies within MPAs designed to preserve natural 

resources and/or to ensure sustainable production (NOAA 2010b) (Figure 8-2; Table 8-1). Although these 

facilities are found in fresh, brackish, and marine waters, and in all regions of the country except 

California, the vast majority of 316(b) facilities occurring within MPAs occur in coastal waters, and are 

most highly concentrated in the Northeastern United States (i.e. both coastal and inland facilities) (Figure 

8-2; Table 8-1). Under Option 1, 87 percent of in-scope facilities found within MPAs obtain reductions in 

impingement mortality (IM), while entrainment mortality (EM) is not reduced at any facilities (Table 

8-1). Under Options 2 and 3, impingement mortality is reduced at 92 and 97 percent of 316(b) facilities in 

MPAs, while the addition of closed-cycle cooling results in reduced entrainment mortality at 72 and 92 

percent of in-scope facilities found in MPAs, respectively (Table 8-1). 
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Figure 8-2: In-scope Facilities with CWISs Located In Marine Protected Areas. 
March 28, 2011 8-5 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 8-1: 316(b) Facilities in Marine Protected Areas, and Improvements in I&E Mortality 

Technologies by Regulatory Option 

I 

Mortality

E 

Mortality

I 

Mortality

E 

Mortality

I 

Mortality

E 

Mortality

California 0 0 00 00 00

North Atlantic 18 9 17 0 19 16 20 20

Mid-Atlantic 24 10 40 0 41 31 43 40

South Atlantic 5 23 10 0 10 9 10 9

Gulf of Mexico 9 44 8 0 10 10 10 10

Great Lakes 3 20 8 0 9 8 9 9

Inland 14 10 18 0 18 9 20 18

Total 73 116 101 0 107 83 112 106

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1= I Everywhere; Option 2 = I Everywhere and E for Facilities > 

125 MGD; Option 3 = I&E Mortality Everywhere.

Option 2 Option 3

Number of Facilities with Improved Technologies by Policy Option

Benefits Region

Affected 

Waterbodies

Baseline 

316(b) 

Facilitiesa 

Option 1

8.2.3 Restoration of Freshwater Ecosystems 

Reducing the effect of CWISs at 316(b) facilities is likely to benefit aquatic ecosystems nationwide, but 

the largest magnitude of improvements may occur in areas of the Great Lakes Basin and Mississippi 

River, with their high density of facilities. These freshwater bodies are subject to large-scale ecosystem 

restoration efforts that indicate public support for restoring the ecological health of these ecosystems 

(Northeast Midwest Institute 2010; USDOI 2008; USFWS 2011; Upper Mississippi River Basin 

Association 2004). 

Nationally, ecosystem restoration efforts focus on many issues, including coastal habitat restoration, 

protection of fish species, and conservation of migratory birds. For example, the federal government 

provided in excess of $1.7 billion for sport fish restoration between fiscal years 2005-2009 (USFWS 

2010d), and has initiated a 5-year multi-agency initiative to restore the ecosystems of the Great Lakes, for 

which $475 million was appropriated in fiscal year 2010 (CEQ et al. 2010). The restoration of major 

inland river ecosystems has been recognized as a worthwhile goal, with more than $100 million spent on 

restoring ecosystems along the Mississippi River (Brescia 2002; USEPA 2004c). Additionally, substantial 

federal funding for river restoration has been proposed for FY2011, with more than $730 million 

requested for major projects in the Missouri, Mississippi, Columbia, and Kissimmee rivers (USOMB 

2010a; USOMB 2010b). These projects include the construction of fish ladders, restoration of wetland 

nursery habitat, and the reduction of pollution. These expenditures indicate a high value placed on the 

maintenance and restoration of ecosystem function and the integrity of freshwater ecosystems. 

8.2.4 Summary of Evidence for Nonuse Values of Ecosystems Impacted by CWISs 

Overall, the public appears to hold substantial nonuse values for ecosystems and species impacted by 

CWISs. For example, governments at various levels have committed to the designation of MPAs at large 

scales. Governments also have committed substantial resources to the restoration of degraded aquatic 

ecosystems. This evidence suggests that the nonuse benefits of 316(b) regulation, although unquantified, 

are substantial. Additional discussion of nonuse impacts occurring under baseline conditions is provided 

in Chapter 2. 
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Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

8.3 Quantitative Assessment of Ecological Nonuse Benefits 

Stated preference (SP) methods and benefit transfers based on SP studies are the generally accepted 

techniques for estimating nonuse values. SP methods rely on surveys that ask people to state their 

willingness to pay (WTP) for particular ecological improvements, such as increased protection of aquatic 

species or habitats with particular attributes. As mentioned above, EPA is in the process of developing a 

SP survey to estimate total WTP for improvements to fishery resources affected by I&E mortality from 

in-scope 316(b) facilities. This survey will provide estimates of total WTP which includes both use and 

nonuse values, will allow estimates of value associated with specific choice attributes (following standard 

methods for choice experiments), and will provide insight into the relative importance of use versus 

nonuse values in the 316(b) context. EPA did not have sufficient time before this notice of proposed 

rulemaking to fully develop and deploy this survey and thus derive estimates of the monetary value of 

reducing I&E mortality impacts at the national level. In the absence of original study values, EPA 

identified a recent SP study conducted by Johnston et al. (2009) that is closely related to the 316(b) policy 

context. Johnston et al. (2009) developed a Bioindicator-Based Stated Preference Valuation (BSPV) 

method specifically for applications to ecological systems.32 Like EPA’s planned survey, this study 

addresses policy changes that introduce forage fish to aquatic habitat but for which ultimate population 

effects are unknown. The study was originally developed to address Rhode Island residents’ preferences 

for the restoration of migratory fish passage over dams within an in-state watershed. It estimates nonuse 

values by asking respondents to consider changes in ecological indicators reflecting quantity of habitat, 

abundance of wildlife, ecological condition, and abundance of migratory fish species. 

EPA used Johnston et al. (2009) to conduct a benefits transfer to quantify nonuse benefits associated with 

reductions in I&E mortality under the 316(b) regulatory options for the North Atlantic and Mid-Atlantic 

benefits regions. The study’s choice experiment allows direct estimation of households’ WTP for policies 

that increase the number of fish in watersheds by changing human industrial uses of aquatic ecosystems. 

Section 8.3.1 describes Johnston et al. (2009) and BSPV methods in greater detail. This is followed by a 

description of EPA’s benefits transfer methods using Johnston et al. (2009) (Section 8.3.2) and estimated 

benefits for 316(b) regulatory options (Section 8.4). 

8.3.1 Description of Johnston et al. (2009) and BSPV Methods 

Johnston et al. (2009) developed the BSPV method to promote ecological clarity and closer integration of 

ecological and economic information within SP studies. The study’s focus on improved ecological 

valuation is an EPA priority as described in findings of EPA’s Science Advisory Board on valuing the 

protection of Ecological System and Services (USEPA 2009b). In contrast to traditional SP valuation, 

BSPV employs a more structured and formal use of ecological indicators to characterize and 

communicate welfare-relevant changes. It begins with a formal basis in ecological science, and extends to 

relationships between attributes in respondents’ preference functions and those used to characterize policy 

outcomes. Specific BSPV guidelines ensure that survey scenarios and resulting welfare estimates are 

characterized by (1) a formal basis in established and measurable ecological indicators, (2) a clear 

structure linking these indicators to attributes influencing individuals’ well-being, (3) consistent and 

meaningful interpretation of ecological information, and (4) a consequent ability to link welfare measures 

to measurable and unambiguous policy outcomes. The welfare measures provided by the BSPV method 

can be unambiguously linked to models and indicators of ecosystem function, are based on measurable 

 

32 The study was funded by the EPA’s Science to Achieve Results (STAR) competitive grant program. 
March 28, 2011 8-7 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

ecological outcomes, and are more easily incorporated into benefit cost analysis. It also provides a means 

to estimate values for ecological outcomes that individuals might value, even though they may not fully 

understand all relevant ecological science. 

Johnston et al. (2009) developed the BSPV methods for a case study addressing public preferences for the 

restoration of migratory fish passage in Rhode Island’s Pawtuxet Watershed. The BSPV survey (Rhode 

Island River: Migratory Fishes and Dams) was designed to estimate WTP of Rhode Island residents for 

options that would provide fish passage over dams and access to between 225 and 900 acres of historical 

habitat within the Pawtuxet Watershed to which there is currently no fish passage. The watershed 

currently provides no spawning habitat for migratory fish; access to all 4,347 acres of potential habitat is 

blocked by 22 dams and other obstructions (Erkan 2002). 

The survey was developed and tested over 21⁄2 years through a collaborative process involving 

interactions of economists and ecologists; meetings with resource managers, natural scientists, and 

stakeholder groups; and 12 focus groups with 105 total participants. In addition to survey development 

and testing in focus groups, individual interviews were conducted with both ecological experts and nonexperts. These included cognitive interviews (Kaplowitz et al. 2004), verbal protocols (Schkade and 

Payne 1994) and other pretests conducted to gain additional insight into respondents’ understanding and 

interpretation of the survey. Careful attention to development and testing helped ensure that the survey 

language and format would be easily understood by respondents, that respondents would have similar 

interpretations of survey terminology and scenarios, and that the survey scenarios captured restoration 

outcomes viewed as relevant and realistic by both respondents and natural scientists. In all cases, survey 

development paid particular attention to the use and interpretation of ecological indicators and related 

information in the survey. 

The choice scenarios and restoration options presented within the survey were informed in part by data 

and restoration priorities in the Strategic Plan for the Restoration of Anadromous Fishes to Rhode Island 

Coastal Streams (Erkan 2002). Additional information was drawn from the ecological literature on fish 

passage restoration, interviews with ecologists and policy experts, and other sources described below. 

Consistent with the strategic plan, the choice experiment within the survey addressed restoration methods 

that neither require dam removal nor would cause appreciable changes in river flows; considered options 

included fish ladders, bypass channels and fish lifts. The choice experiment addresses forage species such 

as alewife and blueback herring that neither are subject to current recreational or commercial harvest in 

Rhode Island nor are charismatic species. Hence, the species affected are a close analog to the forage fish 

affected in the 316(b) policy context. Moreover, the policy context of Johnston et al. (2009) involves 

changes to technologies used within in-water structures (i.e., the use of fish ladders or fish lifts at dams), 

providing another parallel to the 316(b) context, which also involves the use of new technologies within 

in-water structures to mitigate harm to aquatic organisms. 

The choice experiment asked respondents to consider alternative options for the restoration of migratory 

fish passage in the Pawtuxet Watershed. Respondents were provided with two multiattribute restoration 

options, “Restoration Project A” and “Restoration Project B,” as well as a status quo option that would 

result in no policy change and zero household cost. An example choice question is presented in Figure 8-

3. Prior to administration of the choice experiment questions, the survey provided information: (1) 

describing the current status of Rhode Island river ecology and migratory fish compared to historical 

baselines, (2) characterizing affected ecological systems and linkages, (3) describing the methods and 

details of fish passage restoration, and (4) providing the definitions, derivations and interpretations of 
March 28, 2011 8-8 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

ecological indicators used in the survey scenarios, including the reason for their inclusion. All survey 

language and graphics were pretested carefully to ensure respondent comprehension. 

The restoration options are characterized by seven attributes, including five ecological indicators, one 

attribute characterizing public access, and one attribute characterizing unavoidable household cost. The 

included ecological indicators characterize: (1) the quantity of river habitat accessible to migratory fishes, 

(2) the number of fish migrating to upstream habitat, (3) the abundance of fish suitable for recreational 

harvest, (4) the abundance of fish-dependent wildlife, (5) and overall ecological condition. 

8.3.2 Benefits Transfer Methodology 

The following subsections describe EPA’s benefits transfer methods using the BSPV study. Section 

8.3.2.1 describes the estimation of WTP for a percentage increase in fish numbers using the BSPV study, 

and Section 8.3.2.2 describes the application of BSPV WTP values to I&E mortality reductions under 

316(b) regulatory options. 

8.3.2.1 Estimating WTP for a Percentage Increase in Fish Numbers 

As shown in Figure 8-3, within Johnston et al. (2009)’s choice scenarios each ecological attribute is 

expressed in relative terms with regard to upper and lower reference conditions (i.e., best and worst 

possible in the Pawtuxet) as defined in survey informational materials. Relative scores represent percent 

progress towards the upper reference condition (100 percent), starting from the lower reference condition 

(0 percent). This also implies bounds on the potential attribute levels that might occur in the choice 

questions, following guidance in the literature to provide visible choice sets (Bateman et al. 2004). The 

number of fish affected by 316(b) regulations is many times larger than that considered by Johnston et al. 

(2009) — therefore it would be inappropriate to apply the Johnston et al. (2009) values per fish to the 

316(b) fish reduction estimates (which exceed the maximum reference condition for Johnston et al. 

(2009)) to obtain a WTP value for this rulemaking. In order to conduct a benefit transfer that closely 

follows Johnston et al. (2009)’s study design for the Pawtuxet Watershed, resource improvements should 

be expressed as a percentage improvement relative to the existing resource condition. A variant of 

Johnston et al.’s (2009) model was hence used to conduct a benefit transfer predicated on percentage 

improvements in the fish condition, relative to the reference condition for each ecosystem. As 

improvements are bounded by the 100 percent reference condition in all cases, this at least partially 

ameliorates the scale concern described above. The remainder of this section describes EPA approach for 

estimating WTP per percentage improvement based on Johnston et al. (2009).
March 28, 2011 8-9 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Figure 8-3: Example Choice Experiment Question from Johnston et al. (2009) 
March 28, 2011 8-10 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

When specifying mixed logit models for SP choice experiments, economic theory provides guidance 

regarding certain aspects of model specification. For example, the parameter on program cost is expected 

to have a negative sign, reflecting a positive marginal utility of income. To ensure an appropriate sign for 

this parameter within mixed logit models, a common solution is to specify a lognormal distribution on the 

sign-reversed cost parameter. This solution, however, leads to well-known ambiguities for WTP 

estimation related to the long right-hand tail of the lognormal distribution, and often unrealistic mean 

WTP estimates over the entire distribution (Hensher and Greene 2003; Johnston and Duke 2007). As a 

result of this well-established problem, Hensher and Greene (2003, p. 148) recommend alternatives 

including the bounded triangular distribution for the program cost parameter. 

Here, following Hensher and Greene (2003), the random utility model is estimated using maximum 

likelihood ML with Halton draws in the likelihood simulation. Coefficients on program cost (cost) and 

migrants (the percentage point increase in the number of migratory fish able to reach watershed habitat) 

are important for estimating WTP for a percentage increase in fish numbers. Coefficients on all variables 

except that on program cost (cost) are specified as random with a normal distribution. This includes the 

variable migrants. The coefficient on annual household cost (cost) is specified as random with a bounded 

triangular distribution as specified above with the mean equal to the spread (m=s), ensuring a positive 

marginal utility of income. Sign-reversal is applied to the cost variable prior to estimation, so that the 

expected parameter sign is positive (Hensher and Greene 2003).33 Table 8-2 presents model results. 

Because the mixed logit model includes random coefficients, EPA estimated WTP using the welfare 

simulation approach of Johnston and Duke (2007; 2009) following Hensher and Greene (2003). The 

procedure begins with a parameter simulation following the parametric bootstrap of Krinsky and Robb 

(1986), with R=1000 draws taken from the mean parameter vector and associated covariance matrix. For 

each draw, the resulting parameters are used to characterize asymptotically normal empirical densities for 

fixed and random coefficients. For each of these R draws, a coefficient simulation is then conducted for 

each random coefficient, with S=1000 draws taken from simulated empirical densities. Here, all 

coefficient simulations draw from a normal distribution except for that on cost, which draws from a 

bounded triangular distribution with m=s=0.05148015. Because the use of a triangular distribution on 

program cost ameliorates the “long tails” problem of the lognormal distribution, and also due to 

differences in the estimated functional form, these results provide lower WTP estimates, particularly for 

relatively small increases in fish numbers. Welfare measures are calculated for each draw, resulting in a 

combined empirical distribution of R×S observations from which summary statistics are derived. The 

resulting empirical distributions accommodate both the sampling variance of parameter estimates and the 

estimated distribution of random parameters. Here, we follow Hu et al. (2005) and simulate welfare 

estimates as the mean over the parameter simulation of mean WTP calculated over the coefficient 

simulation (i.e., mean of mean WTP). 

 

33 Because the mixed logit model includes random coefficients, we estimate WTP using the welfare simulation approach of 

Johnston and Duke (2007; 2009) following Hensher and Greene (2003). The resulting empirical distributions accommodate 

both the sampling variance of parameter estimates and the estimated distribution of random parameters. We follow Hu et al. 

(2005) and simulate welfare estimates as the mean over the parameter simulation of mean WTP calculated over the 

coefficient simulation (i.e., mean of mean WTP). 
March 28, 2011 8-11 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 8-2: Results of Mixed Logit Maximum Likelihood Estimation (Bounded Triangular 

Cost) 

Variable Coefficient Standard Error b/ St. Er. P[|Z|>z]

Random parameters in utility functions 

NEITHER -5.412 1.489 -3.635 0.000 

ACRES 0.047 0.013 3.637 0.000 

MIGRANT 0.028 0.009 3.266 0.001 

ACCESS 1.538 0.274 5.609 0.000 

CATCH -0.004 0.008 -0.474 0.635 

WILD 0.024 0.009 2.755 0.006 

IBI 0.016 0.017 0.957 0.338 

COST 0.051 0.009 5.998 0.000 

Derived standard deviations of parameter distributions 

NsNEITHER 5.424 1.140 4.760 0.000 

NsACRES 0.076 0.028 2.686 0.007 

NsMIGRANT 0.004 0.017 0.214 0.831 

NsACCESS 1.950 0.372 5.239 0.000 

NsCATCH 0.030 0.031 0.981 0.326 

NsWILD 0.031 0.024 1.279 0.201 

NsIBI 0.043 0.036 1.181 0.238 

TsCOST 0.051 0.009 5.998 0.000 

Parameter Descriptions: 

neither – Alternative specific constant (ASC) associated with the status quo, or a choice of neither plan. 

acres – The number of acres of river habitat accessible to migratory fish. 

migrant - The percentage point increase in the number of migratory fish able to reach watershed habitat. 

access – Indicates whether the restored area is accessible to the public for walking and fishing. 

catch – The number of catchable-size fish in restored areas. 

wild – Number of fish-eating wildlife species that are common in restored areas. 

IBI – Index of biotic integrity (IBI) score reflecting the similarity of the restored area to the most undisturbed 

watershed in Rhode Island. 

cost – The household annual cost required to implement the restoration program. 

Estimated benefit functions from the EPA/STAR choice experiment survey allow one to distinguish 

benefits associated with resource uses from those associated primarily with nonuse motives. Within the 

benefit transfer application, WTP is quantified for increases in non-harvested fish alone based on the 

implicit price for migratory fish changes. This transfer holds constant all effects related to identifiable 

human uses (e.g., effects on catchable fish, public access, observable wildlife, etc.). The remaining 

welfare effects—derived purely from effects on forage fish with little or no direct human use—may 

therefore be most accurately characterized as a nonuse benefit realized by households. 

The above simulation provides a WTP estimate of $0.76 per percentage point increase in migratory fish, 

where zero represents no fish and 100 percent represents the maximum possible number of fish that may 

be supported by the ecosystem, following Johnston et al. (2009). Results for total household WTP for a 

series of percentage improvements in fish numbers are shown below in Table 8-3.34 These percentage 

improvements do not represent population increases; rather, they reflect new fish within a specific habitat 

 

34 Within the Pawtuxet Watershed study area (the original study location), each percentage point increase in migratory fish is 

equivalent to 12,250 individual fish. 
March 28, 2011 8-12 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

area that may be counted. EPA transferred this estimate of $0.76 per percentage improvement to estimate 

nonuse benefits of 316(b) regulatory options. 

Table 8-3: WTP per Percentage Increase in the Number of Fish 

Percentage Point Increase 

in Number of Fish 

WTP per % Increase in the 

Number of Fish Total WTP per Household 

1 $0.76 $0.76 

12 $0.76 $9.13 

20 $0.76 $15.21 

33 $0.76 $25.10 

100 $0.76 $76.05 

8.3.2.2 Estimating Total WTP for Eliminating or Reducing I&E Mortality at CWISs 

The BSPV study was developed as a case study is for a watershed-level policy in Rhode Island. While it 

provides parameterized benefit functions that require the fewest assumptions to implement for benefit 

extrapolation to the 316(b) case, estimates are likely to be representative of nonuse values held by 

individuals residing in the Northeast U.S. EPA expects that it would provide less accurate estimates of 

nonuse values for residents of other U.S. regions outside the Northeast. EPA was unable to identify 

valuation studies conducted in other regions which would provide benefit functions of comparable quality 

and applicability to the 316(b) regulatory context. Although other studies in the literature value changes in 

aquatic resources, they don’t provide a good match to the 316(b) policy scenario in terms of the expected 

resource change. The large number of assumptions required for developing benefits transfer based on 

these studies would result in greater uncertainties compared to application of the BSPV study. Therefore, 

EPA restricted the benefits transfer to the North Atlantic and Mid-Atlantic EPA 316(b) study regions. 

The structure of the BVSP choice experiment dictates that WTP estimates for each species are not 

additive. Rather the overall WTP should be evaluated based on the single species that would experience 

the greatest relative increase in abundance from restoration. To match the original valuation scenario to 

the 316(b)policy scenario , EPA evaluated model results and available biological data to determine the 

species for which relative abundance is most affected by I&E mortality. By comparing baseline age-1 

equivalent losses to an estimate of total baseline fish abundance. EPA identified winter flounder as the 

species suffering the greatest from baseline I&E mortality in the Northeast U.S. (i.e., North Atlantic and 

Mid-Atlantic regions). EPA’s analysis was limited to species with readily available estimates of spawning 

stock biomass for the Northeast U.S. from stock assessments conducted by the NOAA Northeast 

Fisheries Science Center. This included a review of four species:winter flounder, striped bass, bluefish, 

and Atlantic butterfish. (Table 8-4). All four species are harvested commercially, however fish of 

commercial species may be forage during early life-stages and have nonuse values. The total baseline 

I&E mortality in the North-Atlantic and Mid-Atlantic regions were evaluated together to represent the 

Northeast U.S. for consistency with the available stock assessments, which include waters from Maine 

south to North Carolina. 
March 28, 2011 8-13 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 8-4: Baseline I&E Mortality Losses and Estimated Fish Numbers for the 

Northeast U.S. (North Atlantic and Mid-Atlantic Regions) 

Species Baseline I&E Losses

(millions of A1E)

Estimated Fish Numbers 

(millions)a

Winter Flounder 6.502 21.1

Striped Bass 1.399 14.3

Bluefish 0.001 116.1

Atlantic Butterfish 0.008 28.9

a

 Estimated population size was calculated by applying a conversion factor (lbs per fish) to an 

esitmate of spawning stock biomass.

EPA expects that decreasing I&E mortality will lead to increased fish abundance in affected waterbodies. 

EPA assumes that the total number of fish introduced to local habitats throughout the Northeast under 

each regulatory option would be equivalent to the sum of age-1 equivalent reductions for the North 

Atlantic and Mid-Atlantic regions. Application of the BSPV model results requires that the increases be 

expressed as a percentage improvement from current conditions relative to a maximum number of fish 

that could be supported by the ecosystem. EPA assumed a maximum of 99 million fish based on the 

estimated biomass maximum sustainable yield from the Northeast Fisheries Science Center assessment of 

the Southern New England stock (NOAA 2006) and a conversion factor of 1.2 lbs pounds per fish. 

EPA’s calculation of nonuse values from eliminating or reducing I&E mortality losses for each regulatory 

option involved the following steps: 

1. Calculate the percent change increase in total winter flounder numbers in the Northeast U.S. (the 

North Atlantic and Mid-Atlantic regions combined) by comparing age-1 equivalent reductions 

under each regulatory option relative to a baseline of 99 million fish. 

2. Multiply the percentage change in fish numbers by $0.76 (Table 8-3) to calculate the WTP per 

household per year for the relative increase in winter flounder numbers resulting from the 

regulatory option. 

3. Calculate regional WTP for each regulatory option by multiplying WTP per household by the 

total number of households within the North Atlantic and Mid-Atlantic regions, respectively. 

The results from implementing these steps for each of the 316(b) regulatory options are described in 

Section 8.4. 

8.4 Estimates of Total WTP by Option and Region 

Table 8-5 summarizes EPA’s estimates of WTP for increased fish numbers resulting from the 316(b) 

regulatory options in the North Atlantic and Mid-Atlantic regions. EPA estimates that elimination of 

baseline losses would increase the number of winter flounder in the Northeast U.S. by more than 6.5 

million fish. This is equivalent to a 6.6 percent increase in winter flounder relative to a maximum of 99 

million fish (i.e., 6.5 million divided by 99.0 million). Multiplying the 6.6 percent increase by a value of 

$0.76 per percentage increase (as presented in Table 8-3) yields a household WTP of $4.99 per year. 

Applying the household WTP values to the number of households in each region results in annualized 

WTP values of $26.3 million and $102.3 million for the North Atlantic and Mid-Atlantic regions, 

respectively, using a discount rate of 3 percent. Annualized WTP values are $26.8 million for the North 

Atlantic and $104.0 million for the Mid-Atlantic using a discount rate of 7 percent. 
March 28, 2011 8-14 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

EPA estimates that Option 1 would increase winter flounder numbers by less than 0.1 percent in the 

North Atlantic and Mid-Atlantic waters. Applying per household WTP to this percent increase in the 

number of winter flounder ($0.02) to the number of households in each region yields the total WTP for 

improvements in winter flounder abundance. The estimated annualized WTP values are approximately 

$0.1 million and $0.4 million for the North Atlantic and Mid-Atlantic regions, respectively, using both 3 

percent and 7 percent discount rates (Table 8-5). Table 8-5 also presents household WTP and annualized 

WTP for Option 2 and Option 3. 

Table 8-5: Nonuse Value of Eliminating or Reducing Baseline I&E Mortality Losses by 

Regulatory Option for All In-scope Facilities in the North Atlantic and Mid-Atlantic Regions 

Baseline Option 1 Option 2 Option 3

Reduction in Northeast IM&EM (millions of age-1 

equivalents) 6.50 0.03 5.32 5.57

Maximum Population (millions of fish) 99.0 99.0 99.0 99.0

Percentage Increase in Fish within Northeast 

Waters 6.56% 0.03% 5.37% 5.63%

Household WTP per Percent Increase in Fish 

Numbers (2009$) $0.76 $0.76 $0.76 $0.76

Annual WTP per Household (2009$) $4.99 $0.02 $4.08 $4.28

Number of Households (millions) 5.4 5.4 5.4 5.4

Annual WTP (millions of 2009$) $26.9 $0.1 $22.0 $23.1

Annualized WTP (3% discount rate; millions 

of 2009$) $26.3 $0.1 $14.8 $15.5

Annualized WTP (7% discount rate; millions 

of 2009$) $26.8 $0.1 $11.5 $12.0

Number of Households (millions) 21.0 21.0 21.0 21.0

Annual WTP (millions of 2009$) $104.6 $0.5 $85.6 $89.7

Annualized WTP (3% discount rate; millions 

of 2009$) $102.3 $0.4 $57.3 $60.0

Annualized WTP (7% discount rate; millions 

of 2009$) $104.0 $0.4 $44.5 $46.5

North Atlantic

Mid-Atlantic

Scenarios: Baseline = Elimination of Baseline I&E Mortality losses; Option 1 = I Everywhere; Option 2 = I 

Everywhere and E for Facilities with > 125 MGD; Option 3 = I&E Mortality Everywhere

8.5 Limitations and Uncertainties 

A number of issues are common to all benefit transfers. Benefit transfer involves adapting research 

conducted for another purpose in the available literature to address the policy questions at hand. Because 

benefits analysis of environmental regulations rarely affords enough time to develop original SP surveys 

that are specific to the policy effects, benefit transfer is often the only option to inform a policy decision. 

Some of the limitations and uncertainties associated with implementing a benefits transfer using Johnston 

et al. (2009) are addressed below. Broader limitations and uncertainties associated with benefit transfer in 

general are discussed by Johnston and Rosenberger (2010). 
March 28, 2011 8-15 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

8.5.1 Scale of Fishery Improvements 

Given the scale of the Johnston et al. (2009) survey upon which these results are based, the most reliable 

results apply within the range of the choice experiment data (e.g., fish percentage point increases < 33 

percent). Again, the maximum possible increase within the Pawtuxet policy context, 100 percent, is 

defined as the maximum number of fish that can be supported by the Pawtuxet Watershed with fish 

passage. Transfer to increases in fish below this magnitude may introduce uncertainty in the WTP 

estimate per percentage increase in fish numbers. 

8.5.2 Scale and Characteristics of the Affected Population 

The results of Johnston et al. (2009) reflect WTP for improvements in nearby watersheds, and there may 

be a decline in WTP as policy areas become more distant. The most reliable application of these results 

would be to calculate WTP for I&E mortality reductions in a single local watershed. However, the 316(b) 

regulation would reduce I&E mortality losses and would improve fish populations in multiple watersheds 

within some states. As noted, it was assumed for these purposes that households have consistent values 

for improvements in multiple watersheds within their state or region. Moreover, for transfers based on 

absolute fish numbers, it is assumed that the per household WTP for changes in the numbers of fish for all 

watersheds located within their state, including watersheds that are shared by multiple states, would be at 

least equal to the WTP value for improvements in a single watershed. Hence, estimated per household 

WTP is based on the average watershed improvement within the state—an approach to scale effects that 

likely provides conservative welfare estimates. 

The Johnston et al. (2009) study context was a single watershed in Rhode Island. Using the benefits 

transfer approaches outlined here, the benefit function is applied to all states in the North Atlantic and 

Mid-Atlantic regions without adjustment, based on mean household income or local watershed 

characteristics. Some heterogeneity in WTP would be expected across states and regions due to diversity 

in species and public values. EPA did not extend the benefits transfer beyond the North Atlantic and MidAtlantic regions because of the potential for substantial differences in preferences, demographics, and 

species characteristics in other regions compared to the original context of Johnston et al. (2009). 

8.5.3 Fish Population Size, Type and Improvement from the Elimination of I&E Mortality 

For the purposes of the benefit transfer it was assumed that the number of fish gained by eliminating I&E 

mortality would be equal to baseline I&E mortality losses and reductions under each option. These 

increases are not intended to represent changes in fish population. 

There is some uncertainty regarding the geographic range of species included in the analysis. Based on 

information from NOAA Northeast Fisheries Science Center, the range of species included here extends 

south of the Mid-Atlantic region to North Carolina. The lack of adjustment based on the additional 

geographic range factor leads to more-conservative estimates of benefits to the North Atlantic and MidAtlantic regions. 

Finally, while both the study and policy contexts involve forage fish, the specific species compositions 

involved differ between Johnston et al. (2009) and 316(b). For example, most of the fish affected within 

Johnston et al. (2009) are migratory fish such as river herring, while such species may make up a smaller 

proportion of those affected by CWISs. If WTP is sensitive to the specific type of forage fish involved, 

this could be a potential source of generalization error. 
March 28, 2011 9-1 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

9 Habitat Based Methodology for Estimating Nonuse Values of Fish 

Production Lost to I&E Mortality 

9.1 Introduction 

The loss of commercially- or recreationally-important aquatic species due to impingement and 

entrainment mortality (I&E mortality) at CWISs is typically valued as a direct use loss (e.g., commercial 

and recreational harvest). However, aquatic species without any direct uses account for 97.3 percent of 

I&E mortality at cooling water intake structures (CWIS) (Chapter 3). Therefore, estimating the total 

(inclusive of nonuse) value of these losses is important when determining the benefits of reducing 

impingement and entrainment (I&E) mortality. 

One way to estimate the value of direct I&E mortality is to approximate the area of habitat required to 

produce and support these organisms. Because fish habitat has been valued by many existing studies, 

habitat provides an indirect basis for valuing the nonuse values of fish. These values may be transferred 

because members of the general public are aware of the fish production services provided by eelgrass 

(submerged aquatic vegetation, SAV) and wetlands; individuals express support for programs that include 

increasing SAV and wetland areas with the expressed goal of restoring depleted fish and shellfish 

populations (Mazzotta 1996; Opaluch et al. 1995; 1998). 

Thus, the habitat-based method for estimating nonuse values of fish lost to I&E mortality is a two-step 

process. First, the area of habitat required to replace fish and shellfish lost to I&E mortality is estimated. 

The public’s WTP for this habitat is then assessed. When combined, these data yield an estimate of 

household values for improvements in fish and shellfish habitat, which in turn provides an indirect 

estimate of the benefits of reducing or eliminating I&E mortality. 

This benefit transfer approach involves four general steps: 

1. Estimate the area of habitat necessary to support the number of organisms lost to I&E mortality. 

2. Develop WTP values for fish production services of habitat ecosystems. 

3. Estimate the total value of baseline nonuse I&E mortality by multiplying WTP values for fish and 

shellfish services by the area of habitat required to offset I&E mortality. 

4. Estimate the direct nonuse benefits of proposed regulatory options, in terms of the value of 

decreased I&E mortality, by multiplying WTP values for fish and shellfish services by the area of 

habitat required to offset I&E mortality. 

This methodology estimates only those nonuse values related to I&E mortality of organisms, and not any 

indirect ecosystem effects of I&E mortality, or or chemical effects of CWISs (Chapter 2). EPA does not 

include values generated using this habitat based approach within its estimates of total benefits for 

eliminating or reducing I&E mortality under the 316(b) regulatory options. While they illustrate the 

potential magnitude of nonuse values, EPA does not consider HEA appropriate for a primary analysis of 

nonuse benefits. The remainder of this chapter describes the methodology and estimates of total WTP 

values for lost aquatic organisms, using a habitat equivalency analysis in conjunction with a benefit 

transfer of habitat values. It also includes a description of limitations and uncertainties of this approach. 
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Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

9.2 Estimating the Amount of Habitat Needed to Offset I&E Mortality 

The first step in the habitat-based method for valuing nonuse I&E mortality values is estimating the area 

of habitat needed to offset I&E mortality. The process of quantitatively adjusting the size of the 

restoration action such that the services that it provides equal those that were lost due to I&E mortality of 

aquatic organisms is referred to as restoration scaling (NOAA 2006; Strange et al. 2002). A restoration 

project is correctly “scaled” when it achieves ecological equivalence. Ecological equivalence is met when 

the magnitude of a restoration reproduces the ecological services provided by a resource prior to injury. 

Restoration scaling approaches are based on the principles of Habitat Equivalency Analysis (HEA). HEA 

was developed by the National Oceanic and Atmospheric Administration (NOAA) to determine public 

compensation for natural resource losses following natural resource damage assessments (NRDAs) that 

occur under the auspices of the Oil Pollution Act (OPA). HEA is a service-to-service scaling approach: it 

does not assume a one-to-one trade-off in resources, but instead in the natural resource services that these 

resources provide (NOAA 2006). In order to fully compensate for natural resource damages, restoration 

action must provide services of the same type and quality as those lost. Discounting is used to account for 

time lags between the loss of services and their restoration.35

To estimate the impact of I&E mortality and the benefits of regulation using a habitat-based methodology, 

EPA selected a trophic transfer approach to scale restoration. The trophic transfer approach is based on 

food-web connectivity that occurs between primary producers and the production of resident and transient 

fish (French McCay and Rowe 2003; Kneib 2003). Using this approach, the area of habitat necessary to 

provide fish and shellfish lost due to I&E mortality is calculated through food-web interactions to 

estimate the area of habitat necessary to compensate for these losses. Such an approach has been used to 

scale restoration to compensate for injuries to aquatic resources under various NRDAs as well as for 

estimating restoration necessary to compensate for I&E mortality under the National Pollutant Discharge 

Elimination System (NPDES) permitting process (Balletto et al. 2005; French McCay et al. 2002; NOAA 

2009; Penn and Tomasi 2002; PSEG 2006; Teal and Weinstein 2002). The trophic transfer approach 

requires four basic steps to estimate the area of habitat restoration necessary to compensate for I&E 

mortality (Figure 9-1). 

EPA estimated values in each region using a single habitat characteristic of the region. Although the 

Agency recognizes that many species lost to I&E mortality rely upon more than one habitat during their 

life history, a single habitat was chosen as most representative for each region to ensure data availability, 

ensure calculation simplicity, and provide a representative habitat required by many species in the region. 

9.2.1 Quantify the Mass of Production Lost to I&E Mortality 

The first step in application of the trophic transfer is estimating the mass of production lost to I&E 

mortality. This calculation requires estimating the number of organisms lost to I&E mortality on an 

annual basis (Chapter 3) as well as determining the annual reduction of productivity as a consequence of 

these losses. Additionally, this step requires estimating the benefits projected to accrue as a result of 

regulation. 

 

35 “The discount rate incorporates the standard economic assumptions that people place a greater value on having resources 

available in the present than on having their availability delayed until the future” (p.7) (NOAA 2006). For the methods 

discussed, the standard discount rate is 3%. 
March 28, 2011 9-3 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Within the trophic transfer framework, losses are calculated as the annual biomass production associated 

with organisms lost to I&E mortality. The vast majority of organisms lost to I&E mortality are less than 1 

year of age at the time of loss (numerically, the greatest losses occur for eggs and larvae, as discussed in 

Chapter 3). For this reason and to simplify computation, EPA converted all I&E mortality to age-1 

equivalents. These losses were then multiplied by the mass of age-1 equivalents and the ratio of dry to 

wet mass to estimate the dry mass of lost productivity on an annual basis (Appendix Equation J-1). 

Quantify regional I&E Mortality as 

a measure of lost productivity

Select a restoration habitat 

for all benefits regions

Quantify expected 

productivity increases 

from habitat restoration

Scale habitat restoration

to offset I&E Mortality and estimate 

benefits under regulatory options

Step 1:

Step 2:

Step 3:

Step 4:

Figure 9-1: Implementation of the Trophic Transfer Approach 

9.2.2 Production per Unit of Habitat 

The second step for implementation of the trophic transfer is the calculation of production per unit of 

habitat. Each acre of restored habitat generates some quantity of primary productivity per year, measured 

here as the annual accumulation rate of dry biomass (i.e., kg dry mass per acre per year). Some proportion 

of this productivity is exported from the ecosystem due to factors such as water movement; this 

productivity is not available to the ecosystem. Remaining primary productivity is then converted to 

secondary productivity using trophic conversion based on a highly simplified four-level food chain 

(Figure 9-2). Trophic conversion efficiencies (or trophic transfers) refer to the inefficiency of energy 

exchange between trophic levels. They can be thought of as the production rate of biomass of predatory 

organisms per unit biomass of food (Penn and Tomasi 2002; Strange 2008). EPA assumed that all 

consumers in the simplified food chain model are food-limited, and that the production of consumers is 

proportional to gains in prey abundance based on trophic conversion efficiencies (French McCay and 

Rowe 2003). 

EPA specified all I&E mortality species as secondary consumers when scaling restoration.36 Thus, to 

compare fish production lost to I&E mortality to production gained through habitat restoration, primary 

productivity from habitat must to be converted to an equivalent amount of production of secondary 

 

36 EPA’s assumption that I&E mortality species are secondary consumers is consistent with PSEG’s assumptions when scaling 

restoration for the Salem facility (e.g., Balletto et al. 2005; PSEG 2006) and assumptions in multiple NRDAs when scaling 

restoration to compensate for fish losses due to oil spills (e.g., French McCay et al. 2002; Penn and Tomasi 2002). 
March 28, 2011 9-4 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

consumer. This calculation requires estimated values for primary production, carbon export, and 

conversion efficiencies from primary production to detritus, detritus to primary consumers, and primary 

consumers to secondary consumers (Appendix Equation J-2). The remainder of this section describes 

these parameters in detail, and how EPA obtained estimates of these values. 

Primary Productivity

Accumulation of energy 

and nutrients by autotrophs

Detritus

Freshly dead or partially 

decomposed organic matter

Primary Consumers

Organisms that consume detritus 

and/or primary production. Includes 

macroinvertebrates and plankton.

Secondary Consumers

Consumers of primary consumers, 

including young-of-year fish

Carbon Export

Loss of productivity by 

water movement

Trophic Conversion

Loss of energy due 

to metabolic processes

Trophic Conversion

Trophic Conversion

Figure 9-2: Trophic Levels and Processes Calculated with the Simplified, 

Four Level Trophic Transfer Model 

9.2.2.1 Primary Production per Acre 

EPA identified five habitat types for scaling regional I&E mortality losses based on (1) importance as 

foundation species (i.e., species involved in habitat formation) with trophic linkages to secondary 

production, (2) regional geographic distribution, and (3) the availability of published values of primary 

productivity (Section 9.2.3). These habitats include: eelgrass (Zostera marina) meadows in the North 

Atlantic; saltmarsh dominated by smooth cordgrass (Spartina alterniflora) in the Mid-Atlantic, South 

Atlantic and Gulf of Mexico; giant kelp (Macrocystis pyrifera) forests in California; and wetlands 

dominated by broadleaf cattail (Typha latifolia) in the Inland and Great Lakes regions. 

Although estimates of primary productivity (PP) are best generated through site-specific study, it is 

common for analysts to use estimates from the literature when scaling restoration (e.g., French McCay et 

al. 2002; Penn and Tomasi 2002). EPA identified peer-reviewed sources for each habitat type used to 

scale I&E mortality. For each of the seven 316(b) regions, EPA compiled net primary productivity (NPP) 

values from the primary scientific literature as well as reviews or past compilations of primary 

productivity values. EPA standardized these values to the metric of kg dry mass per acre per year. In 

cases when multiple sites were measured within an investigation, EPA used the average value. 

Primary production depends on several factors, including but not limited to the conditions and 

characteristics of the study site and study methodology. Due to geographic variations in growing season 

and climate, primary productivity of species may differ substantially both within and among regions 

(Appendix Table J-1). For example, regional productivity estimates used in past salt marsh scaling 
March 28, 2011 9-5 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

applications include 2,204 kg dry mass acre-1 in Rhode Island (French McCay and Rowe 2003), 6,636 kg 

dry mass acre-1 yr-1 in New Jersey, (PSEG 2006; Strange 2008), and 11,716 kg dry mass acre-1 in 

Louisiana (Penn and Tomasi 2002) (Appendix Table J-1).37 To obtain regionally-applicable values for 

primary productivity, EPA used an average of habitat-specific productivity values from a minimum of 

four published values in all calculations (Appendix Table J-1). 

The NPP fraction most easily converted to detritus (freshly dead or partially decomposed organic matter 

(Ricklefs 2001)), and therefore available for secondary production, is above-substrate primary production. 

Consequently, EPA included above-substrate primary production in its calculations. This includes all 

emergent stems and leaf tissue in cordgrass and cattail, and leaf tissue for eelgrass and turtle grass. For 

giant kelp, which uses a benthic holdfast, all biomass production in the water column was included in 

estimates of NPP.38 Estimates of NPP also include primary production of epiphytic periphyton or 

macroalgae (e.g., attached to root stalks in wetland and saltmarsh, or to submerged leaves of eelgrass or 

kelp). Additionally, EPA included algal productivity in NPP estimates. In the North and Mid-Atlantic 

regions, NPP estimates include 533 kg dry mass acre-1 yr-1 of algal productivity [based on scaling 

assessments conducted in Rhode Island, New Jersey and Delaware salt marshes (French McCay and 

Rowe 2003; PSEG 2006; Strange 2008)]. This is equivalent to 16 percent of average mean aboveground 

macrophyte productivity within the North Atlantic and Mid-Atlantic regions (Appendix Table J-1).39 

For all other habitats, the contribution of epiphytes and algae was set to 10 percent of annual aboveground 

NPP of the foundation species. 

9.2.2.2 Trophic Conversion Efficiencies 

Trophic conversion efficiencies (or trophic transfer) account for the relative inefficiency of energy 

transfer between trophic levels (Penn and Tomasi 2002; Strange 2008). Trophic conversion efficiency is 

normally described as the production of predator per unit of prey or food item. Using a highly simplified 

trophic structure, trophic conversion efficiencies were applied to three trophic steps: 

 Primary productivity to detritus 

 Detritus to primary consumers 

 Primary consumers to secondary consumers 

There is evidence that algae and vascular plant detritus40 is important for production at higher trophic 

levels (Kneib 2003). However, there is substantial uncertainty regarding the most appropriate 

specification of the trophic conversion efficiency from primary productivity to detritus. For example, the 

trophic conversion efficiency of smooth cordgrass (S. alterniflora) biomass to detrital material has been 

estimated to be between 0.50 and 0.60. EPA conservatively assigned a transfer efficiency of 0.40 from 

 

37 Estimates of NPP were converted to kg dry mass/acre/year. Measurements reported as g carbon (C)/area/time were converted 

using a species-specific organic carbon content and appropriate adjustment for areal and time increments. Although EPA 

recognizes that the proportion of organic carbon in vascular plants is seasonally dynamic, this variability was not considered 

critical for estimation.

38 This assumption is likely to underestimate NPP for some species, since it does not consider conversion of roots and rhizomes 

to the organic detritus pool that may be used by the secondary consumers. 

39 French McCay and Rowe (2003) assumed 429 kg dry mass acre-1 yr-1 when scaling salt marsh in Rhode Island, while PSEG 

assumed 636 kg dry mass acre-1 yr-1 while scaling salt marsh in New Jersey and Delaware (PSEG 2006; Strange 2008). 

40 Vascular plant detritus includes dead organic material from plants having a vascular system of xylem and phloem (Walker 

1995) such as S. alterniflora. 
March 28, 2011 9-6 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

primary productivity to detritus to account for uncertainty regarding the importance of detritus for nekton 

production.41 Some past NRDAs have not explicitly included this trophic step (e.g., French McCay et al. 

2002; Penn and Tomasi 2002), but have included a low efficiency from primary productivity to primary 

consumers, reflecting the fact that a high percentage of primary productivity is broken down by 

decomposers such as bacteria, molds and fungi (French McCay and Rowe 2003). 

In its simplified trophic model, EPA assumed that primary consumers subsist off the detrital complex, 

which includes macroinvertebrates and zooplankton. A trophic conversion efficiency of 0.2 is assumed in 

the transfer of detritus material to primary consumers. Conversion efficiencies for fish and invertebrate 

consumers in freshwater and marine environments range from 0.1 to 0.3 (French et al. 1996). EPA used a 

value of 0.2, the mid-point of the range commonly used for scaling injuries (e.g., Balletto et al. 2005; 

French McCay et al. 2002; Penn and Tomasi 2002). 

Secondary consumers are assumed to include fish in their first year (i.e., young-of-year; defined as age-0 

fish). EPA assumed a trophic conversion efficiency of 0.2 from primary to secondary consumers, 

consistent with past scaling assessments (e.g., Balletto et al. 2005; French McCay et al. 2002; Penn and 

Tomasi 2002).42

9.2.2.3 Carbon Export 

Although quantifying local production is necessary to develop estimates of restoration area, it is not 

realistic to assume that all NPP remains within the local ecosystem. Export from aquatic ecosystems may 

be substantial, particularly in open or semi-enclosed ecosystems with substantial riverine or tidal flux. In 

these systems, tidal exchange and flushing may remove a large proportion of the local productivity before 

it is consumed and assimilated by local consumers (e.g., Cebrian 2002; Teal 1962). Consequently, if NPP 

export is not considered in trophic transfer models, the amount of habitat restoration required to 

compensate for lost ecosystem goods and services is likely to be underestimated. Although some scaling 

calculations conducted as part of NRDAs do not explicitly include an export adjustment (e.g., French 

McCay et al. 2002; Penn and Tomasi 2002), others acknowledge that productivity many be transported 

out of the area (French McCay and Rowe 2003).43

The rate at which net primary productivity is exported (E) depends on site-specific characteristics 

including marsh height, tidal flushing dynamics, and species mix. An examination of annual NPP from a 

variety of U.S. and international studies in wetlands had a median value of 22 percent NPP export 

(Appendix Table J-2). The uncertainty inherent in estimating carbon flux from ecosystems is large 

(Cebrian 2002) and variability in carbon export high. Accordingly, estimating trophic transfer values for 

habitats with unknown nutrient dynamics is fraught with uncertainty. EPA recognizes that the amount of 

NPP exported from the habitats (1) is not available locally to sponsor trophic transfer and secondary 

production, and (2) will be highly variable from site to site, depending on several factors including tidal 

or riverine flushing, droughts, storm events, and year-to-year variability in plant production. Recognizing 

 

41 The assumed value of 0.40 is consistent with the trophic transfer model that PSEG used to scale habitat restoration for the 

Salem facility. PSEG refers to its trophic model as the “Aggregate Food Chain Model” (PSEG 2006; Strange 2008). 

42 The trophic steps outlined match those used by PSEG for the Aggregate Food Chain Model (Balletto et al. 2005; PSEG 2006), 

and are generally consistent with those used in miscellaneous NRDAs (e.g., French McCay et al. 2002; Penn and Tomasi 

2002).

43 The PSEG AFCM assumed that 45% of primary productivity is lost to the ocean and was not converted to fish and invertebrate 

secondary productivity (PSEG 2006; Strange 2008), based on values from a Georgia salt marsh (Teal 1962). 
March 28, 2011 9-7 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

these limitations, EPA assumed, in all habitats, that 25 percent of net primary production is exported from 

the system and is not transferred to higher trophic levels. 

9.2.3 Select Preferred Restoration Habitat 

To best compensate for I&E mortality, restored habitats should produce the full complement of impacted 

species in each region. However, uncertainties regarding the species-specific benefits of restoration 

actions make scaling habitat loss on a per-species basis impractical. EPA’s application of the trophic 

transfer approach treats the production of secondary consumers as a proxy for the provision of food and 

nutrient cycling considered to be important ecological services (French McCay and Rowe 2003). Under 

this assumption, services are considered to be restored when production of secondary consumers due to 

restoration is equivalent to that lost annually due to I&E mortality. It is unnecessary for restored habitats 

to compensate for losses on a species-by-species basis.44 This approach underestimates restoration to the 

extent that the public has higher total nonuse values for individual species that may have commercial, 

recreational or nonuse values. 

To simplify analysis, one habitat type was chosen in each region as the basis for scaling I&E mortality. 

To select the most appropriate habitat type within each region, a subset of species, broader taxonomic, or 

functional groupings that accounted for 50-90 percent of the biomass lost to I&E mortality (typically, the 

top 5-6 species/groupings) for each 316(b) region were identified. Nursery habitat and life history traits 

for young-of-year fish were obtained (Fishbase 2009), and a habitat type that benefitted the greatest 

percentage of A1E losses was selected in each region (Appendix Section J.3). Because many aquatic 

organisms experience I&E mortality early in their life history (e.g., eggs, larvae, and juveniles), this step 

directly addresses the life stages most at risk of I&E mortality. Where available information for ecological 

habitat and nursery characteristics did not indicate a preferred habitat, ecosystems characterized with 

higher primary productivity per acre were favored. 

Table 9-1: Summary of Productivity Values of Preferred Scaling Habitats by Region (kg 

dry mass acre-1 yr-1) 

Region Species Sample Size

Macrophyte 

NPP Algal NPP Total NPP 

California Giant kelp 

Macrocystis pyrifera

4 7,300 730 8,030 

North Atlantic Eelgrass 

Zostera marina

6 3,750 375 4,125 

Mid-Atlantic Smooth cordgrass Spartina 

alterniflora

10 3,350 533 3,880 

South Atlantic Smooth cordgrass Spartina 

alterniflora

13 6,350 533 6,883 

Gulf of Mexico Smooth cordgrass Spartina 

alterniflora

13 6,350 533 6,883 

Great Lakes Broadleaf cattail 

Typha latifolia

14 6,200 620 6,820 

Inland Broadleaf cattail 

Typha latifolia

14 6,200 620 6,820 

For ease of calculation, the mean values were rounded to the nearest 50 kg dry mass per acre-1 yr-1. 

 

44 EPA’s treatment of productivity as a proxy for important ecosystem services is consistent with the implicit assumptions of 

various past scaling assessments conducted as part of NRDAs (e.g., French McCay et al. 2002; French McCay and Rowe 

2003; Penn and Tomasi 2002). 
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Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

9.2.4 Scaling Habitat Restoration Alternatives to Offset I&E Mortality 

Calculating the area required to compensate for annual I&E mortality combines estimates in increased 

biomass production of secondary consumers (Section 9.2.2) from preferred restoration habitats (Section 

9.2.3) with quantified I&E mortality (Chapter 3; Section 3.3 ). 

The scale of restoration required to compensate for I&E mortality is the quotient of annual I&E mortality 

divided by the expected increase in secondary production associated with a unit area of habitat (Appendix 

Equation J-3). Thus, a CWIS causing I&E mortality of 20,000 kg dry mass per year (across all species) 

would have to restore 200 acres of habitat that produced 100 kg dry mass of secondary production per 

acre per year. Conversely, if a regulatory option reduces I&E mortality by 5,000 kg dry mass per year, 

then its annual benefit is equivalent to 50 acres of similarly-productive habitat. 

Table 9-2 presents the I&E mortality reductions and equivalent habitat restoration area for each region 

under the proposed regulatory options. Among regions, habitat restoration area equivalent to baseline I&E 

mortality ranged from 410 acres in the South Atlantic region, to 76,432 acres in the Inland region. The 

total habitat area equivalent to I&E mortality reductions for all regions is approximately 54,000 acres 

under Option 1, 127,000 acres under Option 2, and 129,000 acres under Option 3. The rank order of 

regions by area of habitat equivalent to estimated I&E mortality reductions due to policy options differed 

among options, due to differences in the effectiveness of 316(b) regulatory options. Notably, however, the 

equivalent habitat restoration area was always greatest in the Inland region (Table 9-2).
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 9-2: Baseline I&E Mortality (metric tons A1E year-1) and Habitat Restoration Area (acres) Equivalent to BaseMortality Reductions (metric tons A1E year-1) and Habitat Restoration Area (acres) Equivalent to These ReductionRegulatory Option 

I&E 

Losses 

(metric 

tons A1E, 

dry 

weight)

Equivalent 

Restoration 

Area (acres)

I&E 

Losses 

(metric 

tons A1E, 

dry 

weight)

Equivalent 

Restoration 

Area (acres)

I&E 

Losses 

(metric 

tons A1E, 

dry 

weight)

Equivalen

Restoratio

Area (acre

California Giant kelp

Macrocystis pyrifera

96 282 2,930 3 36 241 2,50

North Atlantic Eelgrass

Zostera marina

50 158 3,183 1 23 129 2,60

Mid-Atlantic Smooth cordgrass

Spartina alterniflora

47 1,735 37,242 240 5,150 1,608 34,51

South Atlantic Smooth cordgrass 

Spartina alterniflora

83 34 410 13 159 29 34

Gulf of Mexico Smooth cordgrass

Spartina alterniflora

83 1,252 15,158 340 4,122 988 11,95

Great Lakes Broadleaf cattail

Typha latifolia

82 463 5,654 253 3,091 425 5,19

Inland Broadleaf cattail

Typha latifolia

82 6,255 76,432 3,424 41,834 5,723 69,92

Total

(All Regions)

- - 10,179 141,009 4,275 54,415 9,142 127,04

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 DI

Mortality Everywhere

Secondary 

Productivity 

(kg acre-1 

year-1)

Option 2 

Region Habitat

Baseline Option 1
March 28, 2011 9-10 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

9.3 Development of WTP Values for Fish Production Services of Habitat 

The approach EPA used to develop WTP values for fish production services is to 1) estimate the number 

of acres of habitat required to produce fish equivalent to those lost due to I&E mortality; and 2) evaluate 

citizens’ WTP for this habitat—not for the fish produced by the habitat. This method is consistent with 

NOAA’s preferred methods for NRDA under the Oil Pollution Act (OPA), since NOAA’s NRDA 

regulations focus on restoration of injured resources, rather than monetary compensation for damages. For 

lost interim values pending restoration, additional habitat may be restored in lieu of monetary 

compensation. NOAA refers to this as “compensatory restoration” (NOAA 1997). EPA calculated the 

amount of “service-to-service” compensatory restoration—in the form of restored habitat—required to 

offset losses, and then evaluated WTP for restoring this area of habitat. Whereas NOAA recommends 

restoring such acreage to compensate for I&E mortality, EPA does not suggest that the restoration be 

carried out. Instead, EPA quantifies the benefits, in the form of fish production, that the restored habitat 

would provide. This value provides a proxy for the nonuse values not otherwise estimated in this 

document. 

EPA performed an in-depth search of the economic literature to identify valuation studies that estimate 

WTP for aquatic habitat services. From this review, EPA identified seven studies relevant for its analysis 

(Appendix Section J.4). For inclusion in this list, studies were required to meet the following criteria: 

 Specific Amenity Valued: Environmental quality change being valued affects habitat similar to 

those habitat types included in the trophic transfer model.45

 U.S. Studies: Studies surveyed U.S. populations to value domestic resources. 

 Research Methods: Valuation methods were supported by journal literature and inclusive of 

nonuse values (e.g., contingent valuation, conjoint analysis). 

EPA applied values from seven studies for all 316(b) regions, based on consideration of the study 

location, habitat type, and services provided relative to biological scaling assumptions (i.e., Section 9.2). 

If a study was not applicable in a region, EPA transferred values from studies conducted in other 316(b) 

regions for the same habitat type. Reported WTP values per acre of habitat restored represent the average 

of mean values from individual valuation studies (Table 9-3). 

Eelgrass habitat was selected for restoration scaling in the North Atlantic region. The Peconic Estuary 

study (Johnston et al. 2002a; Johnston et al. 2001; Mazzotta 1996; Opaluch et al. 1995; Opaluch et al. 

1998), conducted on the East End of Long Island, NY within the Mid-Atlantic region, was the only study 

identified by EPA that estimates WTP per acre of eelgrass habitat. Although EPA recognizes that there is 

uncertainty when applying WTP values to external 316(b) regions, substantial differences in values are 

unlikely in this case due to the close proximity of the study area to the North Atlantic region and 

similarity in resource characteristics including assemblage of species supported by eelgrass habitat. 

 

45 Valuation studies were excluded from consideration if the habitat services provided by the study habitat were substantially 

different, or provided in drastically different ratios, than the restoration habitat used for scaling (e.g., Dillman et al. 1993; 

Roberts and Leitch 1997). 
March 28, 2011 9-11 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

EPA was unable to identify studies estimating the value of saltmarsh habitat in the South Atlantic and 

Gulf of Mexico regions. Therefore, it was necessary to apply wetland values from valuation studies 

conducted in other 316(b) regions: EPA identified two applicable saltmarsh habitat values, from Rhode 

Island (Bauer et al. 2004) and New York (Johnston et al. 2002a; Johnston et al. 2001; Mazzotta 1996; 

Opaluch et al. 1995; Opaluch et al. 1998). EPA recognizes that substantial uncertainty may occur when 

applying wetland values outside the region from which they were obtained, due to variation in habitat 

condition and resident preferences. However, it is not clear that application of these results will 

overestimate or underestimate WTP for wetland habitats. 

Only one study was identified that estimated WTP for wetland restoration in the Great Lakes region 

(Bishop et al. 2000). However, riverine wetlands inland of the Great Lakes provide fish production, which 

contributes to fish populations in the Great Lakes. Consequently, EPA also applied studies that estimated 

WTP for riverine wetland habitat in states adjacent to the Great Lakes (de Zyosa 1995; Mullarkey 1997; 

Mullarkey 1999). These studies were also applied to the Inland 316(b) region. 

9.3.1 Estimating the Importance of Fish Habitat as a Proportion of Habitat WTP Values: 

Salt Marshes 

To estimate the proportion of value associated with fish habitat, EPA used data from the 2001 Survey of 

Rhode Island Residents. The survey instrument, Rhode Island Salt Marsh Restoration: 2001 Survey of 

Rhode Island Residents, was designed to assess tradeoffs among attributes of salt marsh restoration plans 

in Narragansett Bay, Rhode Island (Johnston et al. 2002b). Development involved extensive background 

research, interviews with experts in salt marsh ecology and restoration, and 16 focus groups with more 

than 100 residents (details on survey development are in Appendix Section J.5.1). 

Survey data indicate that respondents favored plans that restored larger areas of salt marsh. Comparisons 

among specific improvements to habitat and mosquito control revealed that respondents placed the 

greatest weight on mosquito control, followed by habitat improvements for shellfish, fish, and birds, 

respectively (Johnston et al. 2002b). 

From the survey data, EPA calculated the proportion of wetland restoration value associated with 

different wetland services. Across all scenarios presented in the survey, the proportion of WTP values 

Table 9-3: Total Annual Household WTP Per Acre of Aquatic Habitat 

316(b) Region WTP acre-1 yr-1 (2009$) Valuation Studies Applied 

California - - 

North Atlantic 0.0761 Peconic Estuary Study (Johnston et al. 2002a; Johnston et al. 

2001; Mazzotta 1996; Opaluch et al. 1995; Opaluch et al. 1998) 

Mid-Atlantic 0.0672 Peconic Estuary Study (Johnston et al. 2002a; Johnston et al. 

2001; Mazzotta 1996; Opaluch et al. 1995; Opaluch et al. 1998) 

South Atlantic 0.0431 Bauer, Cyr, and Swallow (2004), Peconic Estuary Study 

(Johnston et al. 2002a; Johnston et al. 2001; Mazzotta 1996; 

Opaluch et al. 1995; Opaluch et al. 1998) 

Gulf of Mexico 0.0431 Bauer, Cyr, and Swallow (2004), Peconic Estuary Study 

(Johnston et al. 2002a; Johnston et al. 2001; Mazzotta 1996; 

Opaluch et al. 1995; Opaluch et al. 1998) 

Great Lakes 0.0131 de Zoysa (1995), Mullarky (1997), Mullarky (1999), Bishop et 

al. (2000) 

Inland 0.0118 de Zoysa (1995), Mullarky (1997), Mullarky (1999), Blomquist 

and Whitehead (1998), Whitehead and Blomquist (1991) 

EPA was unable to identify an applicable valuation study for kelp habitat, the preferred scaling habitat for the California region. 
March 28, 2011 9-12 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

associated with fish habitat, bird habitat, shellfish habitat, mosquito control, and other services were 

0.256, 0.198, 0.278, 0.121, and 0.147, respectively. (Additional results and discussion are in Appendix 

Section J.5.2.) 

EPA assumed that 25.6 percent of WTP per acre of salt marsh is associated with fish production services 

for all regions based on these data. EPA recognizes that the findings of the Johnston et al. (2002b) study 

are best applied to areas within or near the North Atlantic region for which coastal populations (i.e., 

preferences) are similar and salt marsh services are most similar. However, EPA was unable to identify 

comparable stated preference studies conducted within the Mid-Atlantic, South Atlantic, and Gulf of 

Mexico regions. 

There is general consensus that marine tidal wetlands and seagrasses provide good to excellent fish 

production function for many important commercial, recreational and forage species (Graff and 

Middleton 2003; Street et al. 2005), by providing favorable conditions for the growth and survival of 

juveniles and young-of-year (Deegan et al. 2000). It is true that the precise role of such habitats as 

nurseries for juvenile fish has recently been critically re-examined, suggesting the need for better 

quantification of the precise role of nearshore ecosystems in producing more adult fish (Beck et al. 2003). 

However, the fish production function of tidal wetlands would be considered high. By applying survey 

findings from Rhode Island across these regions, EPA assumes that preferences for salt marsh restoration 

and salt marsh services are not substantially different among regions. However, true regional WTP values 

may be higher or lower than those estimated within Narragansett Bay. 

9.3.2 Estimating the Importance of Fish Habitat as a Proportion of Habitat WTP Values: 

Freshwater Wetlands 

EPA was unable to identify any studies that permitted the apportionment of WTP for freshwater wetlands 

among habitat services. However, EPA reviewed the published literature to identify and estimate the 

proportion of WTP value that is associated with fish production. 

Tidal freshwater wetlands are located inland of estuaries. They experience tidal fluctuations, but are not 

regularly exposed to water with substantial salinity. As such, these communities are dominated by 

freshwater plants (e.g., cattails, bulrushes, etc). These wetlands are commonly used by freshwater, 

estuarine, marine and migratory fish: their dense vegetation provides refuges for juveniles, and protected 

spawning areas. Additionally, because nutrient cycling in these marshes is rapid, food is readily available 

(Graff and Middleton 2003). As described by Mitchell et al. (2009b) and consistent with the findings of 

Johnston et al. (2002b), EPA assumed that 25 percent of WTP per tidal marsh acre is associated with fish 

production services. 

Non-tidal freshwater wetlands connected to large bodies of water (including the Great Lakes) may also 

have enhanced fish production function. For example, it has been estimated that 75 percent of fish species 

in the Great Lakes use coastal marshes during some part of their life cycle (Jude and Pappas 1992; 

Meixler et al. 2005; Stephenson 1990). Moreover, Lake Erie is reported to support the best fishery of the 

Great Lakes, in terms of diversity and number, partly because of its extensive system of adjoining coastal 

marshes (Graff and Middleton 2003). Consequently, EPA assumed that 20 percent of WTP per acre for 

freshwater marshes in the Great Lakes is associated with fish production services based on the generallyrecognized importance of this habitat to fisheries. EPA used a value lower than recognized for marine 

marshes to reflect the absence of a regular tidal cycle that can provide habitat diversity within the 

ecosystem. 
March 28, 2011 9-13 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

The importance of fish production in isolated non-tidal freshwater wetlands, forested wetlands (i.e., 

seasonally flooded areas), swamps, bogs, etc., has not been well-quantified. Although wetlands attached 

to lakes or fringing marshes on rivers may be locally productive, isolated shallow depressions, headwater 

swamps, or seepage-derived wetlands may have poor or non-existent fish production (Graff and 

Middleton 2003). Consequently, EPA believes the average importance of isolated non-tidal freshwater 

marshes is far lower than similarly-sized marshes in marine systems or freshwater marshes connected to 

significant water bodies. Thus, EPA conservatively assumed that 10 percent of the WTP per acre is 

associated with fish production services. 

9.3.3 Estimated Proportion of Household WTP Estimates Attributed to Fish Production 

Services 

EPA assumed that 25.6 percent of household WTP values for salt marsh restoration are attributable to fish 

production services (Section 9.3.1). Similarly, EPA assumed values of 20 percent for freshwater marshes 

in the Great Lakes Region, and 10 percent for wetlands in the Inland region (Section 9.3.2). Finally, 

because the Peconic surveys used to estimate WTP for eelgrass habitat were described specifically as fish 

and shellfish habitat, EPA assigned 100 percent of the estimated WTP for eelgrass restoration to fish 

production services. Consequently, by multiplying total WTP per acre restored habitat per year (Table 

9-3) by estimates of the proportional contribution of fish production services, EPA obtained WTP per acre 

per year for fish production services in preferred habitats for all 316(b) regions with the exception of 

California (Table 9-4). 

Table 9-4: Household WTP per Acre per Year for Fish Production Services 

316(b) Region 

Total WTP acre-1 yr-1

(2009$) 

% Attributed to Fish 

Production Services 

WTP acre-1 yr-1 for Fish 

Production Services (2009$) 

California - - - 

North Atlantic1 0.0761 100.0% 0.0761 

Mid-Atlantic 0.0672 25.6% 0.0172 

South Atlantic 0.0431 25.6% 0.0110 

Gulf of Mexico 0.0431 25.6% 0.0110 

Great Lakes 0.0131 20.0% 0.0026 

Inland 0.0118 10.0% 0.0012 

Note: EPA was unable to identify an applicable valuation study for kelp habitat, the preferred scaling habitat for the California 

region. 

9.4 Estimating the Value of Habitat Needed to Offset I&E Mortality 

9.4.1 Determining the Extent of Nonuse Values 

Evaluating the total regional WTP value per acre of wetlands or eelgrass requires estimating the extent of 

the population holding nonuse values for these resources. EPA defined the population as the total number 

of households in the state following the methods used by several published studies (e.g., Bauer et al. 

2004; Blomquist and Whitehead 1998; Mullarkey 1997; Whitehead and Blomquist 1991). 

Households in close proximity are likely to value gains of fish in affected waterbodies, as will households 

in counties that do not directly abut affected water bodies. Evidence from Johnston et al. (2002b) 

indicates that this value can extend to the statewide level. Analysis of data from the Rhode Island Salt 
March 28, 2011 9-14 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Marsh Restoration Survey (Johnston et al. 2002b) reveals that values ascribed to even relatively smallscale salt marsh restoration actions (i.e., 3-12 acres) were stated by respondents from various parts of the 

state. A study by Pate and Loomis (1997) found that respondents outside the state in which a study site is 

located were also willing to ascribe stated preference values to the amenity being studied. It compared 

WTP values for environmental programs designed to improve wetland habitat in the San Joaquin Valley, 

CA across households in the Valley, California households outside the Valley, and households in 

Washington State, Oregon, and Nevada. They found that CA households outside the San Joaquin Valley 

expressed similar WTP compared to residents of the Valley, with households outside the state even 

holding positive WTP for the environmental programs. Thus, it is reasonable to assume in the context of 

316(b) analysis that residents within an affected state would have positive values for fish habitat 

improvements within state waters. 

The magnitude of habitat restoration efforts sufficient to compensate for I&E mortality would require a 

large geographical footprint. EPA recognized that, if implemented, this footprint would be divided into 

many sites dispersed throughout each region. To estimate WTP for fish production services that best 

reflect compensation for I&E mortality, EPA assigned habitat restoration based on the estimated 

distribution of I&E mortality throughout each 316(b) region based on the proportion of total AIF of instate facilities relative to total regional AIF. The proportional breakdown of restoration area by state and 

region is presented in Appendix Table J-7. 

9.4.2 Estimating Aggregate Values 

EPA calculated aggregate WTP for each 316(b) region as follows based on the area of habitat required to 

compensate for I&E mortality (Table 9-2), estimates of household WTP per acre per year for fish 

production services (Table 9-4), and the size of the affected population (Appendix Table J-7). 

1. Multiply the number of regional habitat acres needed to offset I&E mortality under the baseline 

condition or equivalent to I&E mortality reduction effect on fish production under the proposed 

316(b) regulation (Table 9-2) by the percentage of area attributed to each state within the 316(b) 

region (Appendix Table J-7) to obtain the magnitude of habitat restoration by state. 

2. Multiply regional household value per acre of restored habitat (Table 9-4) by the estimated 

number of habitat acres within 316(b) region (from 1, above) to obtain total household WTP for 

improved fish production in the waters affected by the 316(b) regulation by state for each region. 

3. For each region, multiply total WTP per household for each state (Step 2) by the number of 

households within the state, and sum across all states within the region to obtain unadjusted WTP 

for habitat restoration within the 316(b) region. 

EPA recognizes that WTP per household per acre is likely to be marginally decreasing as the scale of 

restoration increases (e.g., Bishop et al. 2000), particularly if all statewide households are simultaneously 

valuing fish production services provided by large-scale restoration of multiple habitat types. Household 

values for policy changes may not be additive, and the sum of WTP values when policies are assessed 

separately may exceed the total value of policies when assessed simultaneously. Simply summing the 

statewide values for multiple 316(b) regions may overestimate the value of fish production services from 

additional habitat acreage. 

Based on this assessment, EPA incorporated a weighting adjustment in order to limit the potential for 

overestimation of total WTP in cases where households within a given state are assigned values for 
March 28, 2011 9-15 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

multiple 316(b) benefits regions (e.g., Mid-Atlantic and Inland). State-level WTP values within a 316(b) 

region were adjusted based on the relative magnitude of regional restoration area compared to total 

restoration area assigned to the state. For example, if a state were to be assigned 100 acres from the MidAtlantic region and 300 acres from the Inland region, the statewide WTP for the Mid-Atlantic and Inland 

regions would be multiplied by factors of 0.25 (100 acres/400 acres) and 0.75 (300 acres/400 acres), 

respectively. In the final step of estimating aggregating values for each region, weighted WTP values 

were summed across all states to calculate the total annual WTP associated with each 316(b) region. 

9.5 WTP Results 

Table 9-5 presents the estimated WTP for habitat restoration area necessary to compensate for I&E 

mortality under baseline conditions, as well as estimated WTP for habitat restoration area equivalent to 

I&E mortality reductions under proposed regulatory options. EPA was unable to identify household WTP 

for the preferred scaling habitat (giant kelp) in the California region (Table 9-3). As such, national 

estimates of WTP are understated. 

National WTP for habitat restoration to compensate for baseline I&E mortality is approximately $3.6 

billion and $3.7 billion using 3 percent and 7 percent discount rates, respectively (Table 9-5). Under both 

discount rates, WTP for habitat restoration in the Mid-Atlantic region represents 61 percent of the 

national total. Despite representing 54 percent of the national area of restoration necessary to compensate 

for baseline I&E mortality (Table 9-2), WTP for habitat restoration in the Inland region represented only 

7 percent of national WTP. This difference is in large part due to lower household WTP values for habitat 

restoration than values found in other regions. 

At a 3 percent discount rate, total national WTP for habitat restoration equivalent to I&E mortality 

reductions under Option 1 is $513.3 million (Table 9-5). Because they reduce entrainment losses in the 

majority of facilities, and because 66 percent of national I&E mortality occurs due to entrainment 

mortality (Chapter 3), WTP for Options 2 and 3 is about four times greater than WTP for Option 1. 

Assuming a 3 percent discount rate, national WTP for both Options 2 and 3 is approximately $2.1 billion 

(Table 9-5). 
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 9-5: Weighted WTP for Habitat Restoration Area Equivalent to Baseline I&E Mortality, and Weighted WTP for Restoration Area Equivalent to I&E Mortality Reductions by Region and Regulatory Option 

Baseline Option 1 Option 2 Option 3 Baseline Option 1 

California Giant kelp

Macrocystis 

- ------

North Atlantic Eelgrass

Zostera marina

0.076 388.7 0.5 216.2 226.9 395.2 0.4 

Mid-Atlantic Smooth cordgrass

Spartina 

0.017 2,234.2 210.3 1,280.4 1,295.4 2,271.5 195.5 

South Atlantic Smooth cordgrass 

Spartina 

0.011 0.8 0.4 0.5 0.5 0.8 0.3 

Gulf of Mexico Smooth cordgrass

Spartina 

0.011 732.2 153.4 390.6 389.6 744.4 142.6 

Great Lakes Broadleaf cattail

Typha latifolia

0.003 18.9 10.4 12.2 12.2 19.2 9.7 

Inland Broadleaf cattail

Typha latifolia

0.001 264.3 138.5 167.8 170.6 268.7 128.7 

Total 

(All Regions)

- - 3,639.0 513.3 2,067.6 2,095.1 3,699.8 477.2 

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 DI

I&E Mortality Everywhere

7% Discou

Weighted WTP for Regulatory Options (2009$, millio

Region Habitat

Household 

WTP acre-1 

year

-1

3% Discount Rate
March 28, 2011 9-17 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

9.6 Limitations and Uncertainties 

Benefit transfer involves adapting research conducted for another purpose in the available literature to 

address the policy questions at hand. Because benefits analysis of environmental regulations rarely 

affords sufficient time to develop original stated preference surveys that are specific to the policy effects, 

benefit transfer is often the only option to inform a policy decision. Consequently, there are several 

limitations and uncertainties to this approach. 

9.6.1 Estimating the Extent of the Affected Population 

The magnitude of the affected population has a multiplicative effect on total WTP values for I&E 

mortality. EPA acknowledges that I&E mortality can have impacts not restricted to state boundaries, due 

to the migratory nature of fish populations, and the fact that multiple states may share impacted 

watersheds. EPA’s approach underestimates WTP if members of a population value I&E mortality 

occurring in different states. 

9.6.2 Not All Species and Losses Are Compensated 

EPA scaled restoration to compensate total production lost annually in each region rather than on a 

species-specific basis. This assumes that secondary production is a proxy for important ecosystem 

services such as food provision and nutrient cycling. This approach is likely to underestimate needed 

restoration to the extent that the public has higher nonuse values for specific species (for example, 

threatened and endangered species) that are under-compensated when habitat restoration is scaled based 

on total losses. 

9.6.3 Timing of Losses and Restoration 

Fish production services provided by a restored habitat may increase over time as the habitat undergoes 

natural successional processes, or conversely, fish production services may decline or cease if habitat 

restoration is not successful. EPA scaled restoration using primary productivity values reflective of 

mature habitat: scaling based on mature habitat is consistent with valuation studies that provide WTP for 

marginal habitat acres. EPA is not suggesting that restoration of habitat area estimated by the described 

approaches actually be implemented. If restoration were implemented, primary productivity values used 

in the calculation would likely overestimate marginal gains of restored habitats and would therefore 

underestimate WTP. If available, the inclusion of site-specific information regarding the trajectory and 

duration of restoration benefits would improve the accuracy of scaling estimates. 

9.6.4 Application of the Approach to Large Geographic Areas 

Application of the habitat-based approach for compensating I&E mortality on a regional scale is uncertain 

because of the diversity of habitats and species within a region. Many species of fish require more than 

one habitat: the non-restored habitat may represent the limiting factor for fish populations. Moreover, due 

to site-specific effects, species losses due to I&E mortality are likely to vary both among and within 

regions. Similarly, people may have diverse values for habitats across a state. Although such effects exist, 

EPA assigned ecological parameter values based on average values for a region. Also, most valuation 

studies included in the analysis used statewide survey populations. Consequently, mean values reflect the 

diversity of valuation that occurs throughout a state. 
March 28, 2011 9-18 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Valuation studies were not available for all habitats and regions. Primary WTP values were applied in 

regions when a reasonable value for the restored habitat was unavailable. Valuation studies are most 

accurately applied to areas near the original study location, and may underestimate or overestimate values 

in other states or regions. 

Uncertainty also exists in estimates of proportionate habitat value associated with fish production 

services. Application of the Johnston et al. (2002b) study may lead to overestimation or underestimation 

of WTP for fish habitat services of wetlands outside Rhode Island: the study is most appropriately 

transferred within southern New England and nearby areas where coastal populations (i.e., preferences) 

and coastal wetland conditions (i.e., ecology) are similar. In the absence of comparable studies conducted 

within individual regions, however, the estimate of Johnston et al. (2002b) was applied across regions for 

saltmarsh habitat. 

9.6.5 Specification of Parameter Assumptions 

EPA’s implementation of a trophic transfer approach required the estimation of several parameter inputs 

(e.g., primary productivity values, carbon export, trophic conversion efficiencies). These values represent 

extrapolations from different scales, regions, or ecosystems, and are dependent on many simplifying 

assumptions. Scaling results may exhibit substantial sensitivity to these assumptions. For example, EPA 

applied a simple four-level food chain to all fish species, and used mean value for trophic transfer 

efficiencies across all habitats (French et al. 1996). The scientific literature indicates substantial 

uncertainty in values estimated in local habitats, and fish species vary greatly in their position in natural 

food webs. Additionally, natural variability will impact production and consumption in all habitats. 

Consequently, productivity estimates cannot be viewed as representing anything more than a simplified 

average value. 
March 28, 2011 10-1 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

10 National Benefits 

10.1 Introduction 

This chapter summarizes the results of the seven regional analyses, and presents EPA’s estimates of the 

national benefits of the regulatory options for in-scope 316(b) facilities: 

 Option 1: I Everywhere. Establish Impingement Mortality Controls at All Existing Facilities 

that Withdraw over 2 MGD DIF; Determine Entrainment Controls for Facilities Greater than 2 

MGD DIF On a Site-specific Basis. 

 Option 2: I Everywhere and E for Facilities > 125 MGD. Establish Impingement Mortality 

Controls at All Existing Facilities that Withdraw over 2 MGD DIF; Require Flow Reduction 

Commensurate with Closed-cycle Cooling By Facilities Greater Than 125 MGD DIF. 

 Option 3: I&E Mortality Everywhere. Establish Impingement Mortality Controls at All 

Existing Facilities that Withdraw over 2 MGD DIF; Require Flow Reduction Commensurate with 

Closed-Ccycle Cooling at All Existing Facilities over 2 MGD DIF. 

Greater detail on the methods and data used in the regional analyses is provided in the previous chapters 

of this report. See Chapter 3 for a discussion of the methods used to estimate impingement mortality and 

entrainment (I&E mortality), and a summary of the estimated baseline I&E mortality losses and 

reductions in I&E mortality under the proposed 316(b) regulatory options. See Chapters 5 through 8 for a 

discussion of the methods used to estimate the value of I&E mortality losses and the benefits of the 

alternative policy options. 

EPA was unable to estimate monetized nonuse benefits for I&E mortality losses in all regions. Therefore, 

the benefits estimates presented in this section do not reflect total benefits associated with reducing I&E 

mortality at in-scope facilities, and overall national benefits may accordingly be higher. Section 10.2 

describes EPA’s methodology for aggregating benefits at the national level; Section 10.3 summarizes 

baseline losses and expected reductions in I&E mortality; Section 10.4 presents national benefits; and 

Section 10.5 discusses nonuse benefits and presents a break-even analysis. 

10.2 Methodology 

EPA notes that quantifying and monetizing the benefits that result from reductions in I&E mortality under 

the regulatory options considered for the Section 316(b) facilities rulemaking is challenging. The 

preceding sections of this report discuss specific limitations and uncertainties associated with estimating 

reductions in I&E mortality losses and monetized benefits. EPA estimated national-level benefits by 

summing benefit estimates over the seven study regions. Thus, national benefit estimates are subject to 

the same uncertainties inherent in the valuation approaches used for assessing each of the four benefit 

categories (threatened and endangered species, commercial fishing, recreational fishing, and nonuse 

values). The national benefits estimates do not include habitat-based values presented in Chapter 9; the 

habitat-based analysis was conducted for illustrative purposes to demonstrate the potential magnitude of 

total value inclusive of nonuse values. The combined effect of these uncertainties is of unknown 

magnitude and direction (i.e., the estimates may over- or understate the anticipated national level of use 

benefits). Nevertheless, EPA has no data to indicate that the results for any of the benefit categories are 

atypical or unreasonable. 
March 28, 2011 10-2 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

10.3 Summary of Baseline Losses and Expected Reductions in I&E Mortality 

Based on the results of the regional analyses, EPA calculated total I&E mortality losses under baseline 

(i.e., pre- regulatory) conditions and the total amount by which losses would be reduced under each of the 

regulatory options. The number of fish lost at in-scope facilities is presented in terms of age-1 equivalent 

(A1E) losses (i.e., the number of individual fish of different ages impinged and entrained by facility 

intakes, expressed as A1Es). 

Table 10-1 presents baseline impingement, entrainment, and total I&E mortality losses. The table shows 

that total national losses for all in-scope facilities are 2.2 billion fish in terms of A1Es. EPA notes that the 

count of total lost organisms is larger than values expressed in A1Es. This table shows that about 46 

percent of all A1E losses, or 1.0 billion fish, occur in the Mid-Atlantic region, followed by the Inland 

region with 0.9 billion fish lost. More-detailed discussions of the I&E mortality losses in each region are 

provided in Chapter 3 of this report. 

Table 10-1: Baseline National A1E Losses at All In-scope Facilities (millions of A1Es) 

Region Impingement Mortality Entrainment Mortality I&E Mortality

California 0.8 36.0 36.8

North Atlantic 0.6 59.4 60.0

Mid-Atlantic 50.7 939.4 990.1

South Atlantic 22.5 10.9 33.4

Gulf of Mexico 45.1 90.6 135.6

Great Lakes 44.1 9.4 53.5

Inland 583.6 295.9 879.5

National Total 747.4 1,441.5 2,188.9

EPA also calculated the total national I&E mortality losses prevented by each of the regulatory options. 

These prevented losses are based on the expected reductions in I&E mortality at each facility due to 

technology installation required under each option. Table 10-2 through Table 10-4 present expected 

reductions in I&E mortality, expressed as A1Es, by region, under regulatory options considered in EPA’s 

analysis. The tables show that at in-scope facilities, Option 1 reduces A1E losses by 0.6 billion fish. In 

comparison, Option 2 and Option 3 both reduce A1E losses by approximately 2.0 billion fish. 

Table 10-2: Reductions in National A1E Losses for All In-scope Facilities (millions of 

A1Es) Under Option 1 (I Everywhere) 

Region Impingement Mortality Entrainment Mortality I&E Mortality

California 0.7 0.0 0.7

North Atlantic 0.4 0.0 0.4

Mid-Atlantic 38.7 0.0 38.7

South Atlantic 14.2 0.0 14.2

Gulf of Mexico 34.5 0.0 34.5

Great Lakes 38.2 0.0 38.2

Inland 488.2 0.0 488.2

National Total 615.0 0.0 615.0
March 28, 2011 10-3 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 10-3: Reductions in National A1E Losses for All In-scope Facilities (million A1Es) 

Under Option 2 (I Everywhere and E for Facilities > 125 MGD) 

Region Impingement Mortality Entrainment Mortality I&E Mortality

California 0.8 30.7 31.5

North Atlantic 0.6 48.4 49.0

Mid-Atlantic 49.5 860.3 909.7

South Atlantic 19.2 9.1 28.3

Gulf of Mexico 44.7 61.3 106.0

Great Lakes 43.7 7.5 51.1

Inland 564.1 241.8 805.9

National Total 722.5 1,259.0 1,981.6

Table 10-4: Reductions in National A1E Losses for All In-scope Facilities (millions of A1Es)

Under Option 3 (I&E Mortality Everywhere) 

Region Impingement Mortality Entrainment Mortality I&E Mortality

California 0.8 32.1 32.9

North Atlantic 0.6 50.8 51.4

Mid-Atlantic 49.6 871.3 920.9

South Atlantic 19.2 9.1 28.3

Gulf of Mexico 44.8 61.4 106.2

Great Lakes 43.8 7.6 51.3

Inland 569.6 252.9 822.5

National Total 728.3 1,285.2 2,013.5

Table 10-5 presents EPA’s estimates of the current level of total annual I&E mortality losses and the 

reduction in total annual I&E mortality by option for the three metrics presented in Section 3.2.2. Option 

3 (I&E Mortality Everywhere) results in the greatest reduction in I&E mortality, followed by Option 2 (I 

Everywhere and E for Facilities > 125 MGD) and Option 1 (I Everywhere), respectively, for all of the 

metrics. 

Table 10-5: Baseline National I&E Mortality and I&E Mortality Reductions for All Inscope Facilities by Regulatory Option 

Regulatory Option Millions of A1Es Forgone Fishery Yield 

(million lbs)

Biomass Production Forgone 

(million lbs)

Baseline 2,188.9 71.5 637.8

Option 1 615.0 13.3 137.6

Option 2 1,981.6 58.6 542.2

Option 3 2,013.5 59.2 556.2

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E 

for Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere

As shown for all regions in Table 10-6, and by region in Chapter 3 of this report, the harvested 

commercial and recreational fish species that have direct use values comprise between 1 and 9 percent of 

baseline I&E mortality losses in each region, resulting in a national average of only 3 percent of I&E 

mortality losses receiving a monetary value based on direct use. The remaining 97 percent of I&E 

mortality losses include unharvested recreational and commercial fish and forage fish which do not have 
March 28, 2011 10-4 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

direct use values. EPA’s nonuse analysis was limited two of the seven benefits regions and nonuse values 

were not estimated for unharvested fish in the remaining five benefits regions. The total estimated 

benefits are likely to be significantly understated due to the regional limitations of EPA’s nonuse analysis 

and the relatively large fraction of I&E mortality reductions which are not commercially or recreationally 

harvested. 

Table 10-6: Distribution of National I&E Mortality for All In-scope Facilities by Regulatory 

Option 

Baseline 2,188.9 1,654.8 534.1 59.4 2.7%

Option 1 615.0 525.7 89.3 15.7 2.5%

Option 2 1,981.6 1,512.6 468.9 53.3 2.7%

Option 3 2,013.5 1,535.4 478.1 54.0 2.7%

Regulatory Option

a

 Harvestable fish are adult fish of the age at which they can legally be harvested.

Scenarios: Baseline = Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for 

Facilities > 125 MGD; Option 3 = I&E Mortality Everywhere

(a)

All Species

(millions of 

A1Es)

(b)

Forage Species

(millions of 

A1Es)

(c)

Commercial and 

Recreational 

Species

(millions of A1Es)

(d)

Harvested 

Commercial and 

Recreational 

Species

(millions of fish 

harvested)a

A1E Fish Assigned 

a Direct Use Value 

as Percentage of 

Total 

(column d / 

column a)

10.4 National Monetized Benefits from Eliminating and Reducing I&E Mortality 

Losses 

EPA’s estimates of total national baseline losses and total national benefits under each option are based 

on EPA’s regional estimates of monetized baseline losses and regulatory option benefits. To address the 

differences in the timing of benefits and costs, EPA developed a time profile of total benefits from all inscope facilities that reflects when benefits from compliance-related changes at each facility would be 

realized. The methodology that EPA used to develop this time profile is detailed in Appendix D. For each 

study region, EPA first calculated the undiscounted benefits (i.e., commercial and recreational fishing 

benefits, including recreational fishing benefits from an increased abundance of T&E species) from the 

expected annual I&E mortality reductions under the regulatory options, based on the assumptions that all 

facilities in each region would achieve compliance and that benefits would be realized immediately 

following compliance. Then, since there would be regulatory and biological time lags between 

promulgation of the regulatory options and the realization of benefits, EPA created a time profile of 

benefits that takes into account the fact that benefits do not begin immediately. Using this time profile of 

benefits, EPA discounted the total benefits generated in each year of the analysis to 2012, the year when 

the rule becomes effective, using discount rates of 3 percent and 7 percent.46 Appendix D of this report 

provides detail on EPA’s development of the time profile of benefits. 

 

46 The 3 percent rate represents a reasonable estimate of the social rate of time preference. The 7 percent rate represents an 

alternative discount rate, recommended by the Office of Management and Budget (OMB), that reflects an estimated 

opportunity cost of capital. 
March 28, 2011 10-5 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

EPA estimated mean national use values, as well as values that include the 5th percentile lower bound and 

95th percentile upper bound of the recreational benefits estimates.47 Table 10-9 through Table 10-11 

present these results for each region and for the nation as a whole. As described in above, the national 

benefits estimates do not include habitat-based values presented in Chapter 9. 

Table 10-7 shows that the total annual national value of losses due to CWIS at in-scope facilities, 

discounted at 3 percent, includes $76.9 million in recreational fishing losses, $8.0 million in commercial 

fishing losses, $1.1 million in T&E species losses, and $128.6 million in forgone nonuse benefits. The 

total benefits of elimination of baseline CWIS, discounted at 3 percent, are $214.7 million per year, with 

estimates based on the 5th percentile lower bound and 95th percentile upper bound for recreational values, 

totaling $180.5 million and $281.0 million, respectively. 

Discounted at 7 percent, the total annual national value of losses due to CWIS includes $75.6 million in 

recreational fishing losses, $7.9 million in commercial fishing losses, $1.1 million in T&E species losses, 

and $130.8 million in forgone nonuse benefits. The total use value of fishery resources lost, discounted at 

7 percent, is $215.5 million per year, with estimates based on the 5th percentile lower bound and 95th

percentile upper bound for recreational values, totaling $181.8 million and $280.8 million, respectively. 

Total monetized losses are greatest in the Mid-Atlantic region. More-detailed discussions of the valuation 

of impacts under the baseline conditions in each region are provided in Chapters 5 through 8 of this 

document. 

Table 10-8, Table 10-9, and Table 10-10 present EPA’s estimates of the regional and national benefits of 

reducing I&E mortality under each of the regulatory options (2009$, discounted at 3 percent and 7 

percent). The national value of these reductions in I&E mortality losses, evaluated at a 3 percent discount 

rate, is as follows: 

 Option 1 (I Everywhere) results in national benefits of $17.6 million per year, with estimates 

based on the 5th percentile lower bound and 95th percentile upper bound for recreational values, 

totaling $10.0 million and $30.3 million (Table 10-8). 

 Option 2 (I Everywhere and E for Facilities > 125 MGD) results in national benefits of $120.8 

million per year, with estimates based on the 5th percentile lower bound and 95th percentile 

upper bound for recreational values, totaling $101.3 million and $158.7 million (Table 10-9). 

 Option 3 (I&E Mortality Everywhere) results in national benefits of $125.6 million per year, 

with estimates based on the 5th percentile lower bound and 95th percentile upper bound for 

recreational values, totaling $105.5 million and $164.9 million (Table 10-10). 

Evaluated at a 7 percent discount rate, the national use benefits of the regulatory analysis options are 

somewhat smaller: 

 Option 1 (I Everywhere) results in national benefits of $16.0 million per year, with estimates 

based on the 5th percentile lower bound and 95th percentile upper bound for recreational values, 

totaling $9.1 million and $30.3 million (Table 10-8). 

 Option 2 (I Everywhere and E for Facilities with > 125 MGD) results in national benefits of 

$92.2 million per year, with estimates based on the 5th percentile lower bound and 95th

 

47 The lower estimates of value presented in this chapter are measured by the sum of the 5th percentile lower bound estimates 

of recreational values plus the mean value estimates for all other categories of value. The higher estimates of value presented

in this chapter are measured by the sum of the 95th percentile upper bound estimates of recreational values plus the mean 

value estimates for all other categories of value. 
March 28, 2011 10-6 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

percentile upper bound for recreational values, totaling $77.6 million and $120.6 million (Table 

10-9). 

 Option 3 (I&E Mortality Everywhere) results in national use benefits of $95.7 million per year, 

with estimates based on the 5th percentile lower bound and 95th percentile upper bound for 

recreational values, totaling $80.7 million and $124.9 million (Table 10-10). 

The majority of benefit values are attributable to recreational fishing and nonuse benefits. Table 10-11 

provides a convenient summary of benefits for the three regulatory options. More detailed discussions of 

regional benefits under each option are provided in Chapters 5 through 8 of this report. 
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 10-7: Summary of National Benefits from Eliminating Baseline I&E Mortality Losses for All In-scope Facilit

Low Mean High Low 

California $1.7 $2.9 $4.9 $1.2 - - $3.0 North Atlantic $1.8 $2.8 $4.6 $0.4 - $26.3 $28.5 Mid-Atlantic $15.2 $25.6 $44.5 $2.8 - $102.3 $120.4 South Atlantic $0.3 $0.3 $0.5 $0.0 - - $0.3 Gulf of Mexico $6.0 $8.9 $13.5 $3.5 - - $9.5 Great Lakes $1.1 $2.0 $3.5 $0.1 - - $1.2 Inland $16.6 $34.4 $71.7 - $1.1 - $17.7 Total $42.7 $76.9 $143.2 $8.0 $1.1 $128.6 $180.5 California $1.7 $2.8 $4.8 $1.2 - - $2.9 North Atlantic $1.7 $2.7 $4.4 $0.4 - $26.8 $28.9 Mid-Atlantic $14.7 $24.7 $43.0 $2.7 - $104.0 $121.5 South Atlantic $0.2 $0.3 $0.5 $0.0 - - $0.3 Gulf of Mexico $6.0 $8.8 $13.5 $3.4 - - $9.4 Great Lakes $1.1 $2.0 $3.5 $0.1 - - $1.2 Inland $16.5 $34.2 $71.4 - $1.1 - $17.6 Total $42.0 $75.6 $141.0 $7.9 $1.1 $130.8 $181.8 

a All benefits presented in this table are annualized, i.e., equal to the value of all benefits generated over the time frame of the analysis, discounted to 2012, and then an

of this analysis (2012 to 2062). See Appendix D for detail.

b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value pe

analysis. Commercial fishing benefits are computed based on a region-and species-specific range of gross revenue, as explained in Chapter 6 of this report. EPA estimfor some T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commercial fishing benefits and Tto the respective low, mean, and high values for recreational fishing benefits.c No significant commercial fishing takes place in the Inland region. Thus, this region is e

fishing analysis.

d Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon). See Chapter 5 of thi

for more detail on EPA’s analysis of T&E benefits.

e Zeros represent values less than 1,000.

Source: U.S. EPA analysis for this report.

3% Discount Rate7% Discount Rate

Region

Annualized Benefitsa (2009$, millions)

Recreational Fishing Benefits

Commercial 

Fishing 

Benefitsc

T&E Species 

Benefitsd,e

To

Nonuse 

Benefits
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 10-8: Summary of National Benefits of Option 1 (I Everywhere) for All In-scope Facilities (2009$)

Low Mean High Low 

California $0.1 $0.1 $0.1 $0.0 - - $0.1 North Atlantic $0.0 $0.0 $0.0 $0.0 - $0.1 $0.1 Mid-Atlantic $0.8 $1.6 $3.1 $0.3 - $0.4 $1.6 South Atlantic $0.0 $0.0 $0.1 $0.0 - - $0.0 Gulf of Mexico $1.4 $2.4 $4.3 $0.6 - - $2.0 Great Lakes $0.6 $1.0 $1.6 $0.0 - - $0.6 Inland $5.1 $10.5 $22.0 - $0.5 - $5.6 Total $8.0 $15.6 $31.4 $1.0 $0.5 $0.5 $10.0 California $0.0 $0.1 $0.1 $0.0 - - $0.0 North Atlantic $0.0 $0.0 $0.0 $0.0 - $0.1 $0.1 Mid-Atlantic $0.7 $1.4 $2.8 $0.3 - $0.4 $1.4 South Atlantic $0.0 $0.0 $0.0 $0.0 - - $0.0 Gulf of Mexico $1.3 $2.2 $4.0 $0.5 - - $1.8 Great Lakes $0.5 $0.9 $1.5 $0.0 - - $0.6 Inland $4.6 $9.6 $20.1 - $0.5 - $5.1 Total $7.2 $14.2 $28.5 $0.9 $0.5 $0.5 $9.1 

Nonuse 

Benefits

a All benefits presented in this table are annualized, i.e., equal to the value of all benefits generated over the time frame of the analysis, discounted to 2012, and then ann

of this analysis (2012 to 2062). See Appendix D for detail.

b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value per 

analysis. Commercial fishing benefits are computed based on a region-and species-specific range of gross revenue, as explained in Chapter 6 of this report. EPA estimafor some T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commercial fishing benefits and Tto the respective low, mean, and high values for recreational fishing benefits.c No significant commercial fishing takes place in the Inland region. Thus, this region is ex

fishing analysis.

d Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon). See Chapter 5 of this 

for more detail on EPA’s analysis of T&E benefits.

e Zeros represent values less than 1,000.

Source: U.S. EPA analysis for this report.

3% Discount Rate7% Discount Rate

Region

Annualized Benefitsa (2009$, millions)

Recreational Fishing Benefits Commercial 

Fishing 

Benefitsc

T&E Species 

Benefitsd,e

To
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 10-9: Summary of National Benefits of Option 2 (I Everywhere and E for Facilities > 125 MGD) for All In-scop

Low Mean High Low 

California $1.0 $1.7 $2.9 $0.8 - - $1.8 North Atlantic $0.9 $1.5 $2.4 $0.2 - $14.8 $15.9 Mid-Atlantic $8.4 $14.1 $24.5 $1.6 - $57.3 $67.3 South Atlantic $0.1 $0.2 $0.3 $0.0 - - $0.2 Gulf of Mexico $3.2 $4.9 $7.6 $1.8 - - $5.0 Great Lakes $0.7 $1.3 $2.2 $0.1 - - $0.8 Inland $9.6 $19.9 $41.4 - $0.7 - $10.3 Total $24.0 $43.5 $81.5 $4.5 $0.7 $72.1 $101.3 California $0.8 $1.3 $2.2 $0.6 - - $1.4 North Atlantic $0.7 $1.1 $1.8 $0.2 - $11.5 $12.3 Mid-Atlantic $5.8 $9.8 $17.0 $1.1 - $44.5 $51.4 South Atlantic $0.1 $0.1 $0.2 $0.0 - - $0.1 Gulf of Mexico $2.5 $3.8 $5.9 $1.4 - - $3.9 Great Lakes $0.6 $1.0 $1.7 $0.0 - - $0.6 Inland $7.4 $15.3 $31.9 - $0.6 - $7.9 Total $17.8 $32.4 $60.8 $3.3 $0.6 $55.9 $77.6 

a All benefits presented in this table are annualized, i.e., equal to the value of all benefits generated over the time frame of the analysis, discounted to 2012, and then ann

of this analysis (2012 to 2062). See Appendix D for detail.

b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value per 

analysis. Commercial fishing benefits are computed based on a region-and species-specific range of gross revenue, as explained in Chapter 6 of this report. EPA estimafor some T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commercial fishing benefits and Tto the respective low, mean, and high values for recreational fishing benefits.c No significant commercial fishing takes place in the Inland region. Thus, this region is ex

fishing analysis.

d Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon). See Chapter 5 of this 

for more detail on EPA’s analysis of T&E benefits.

e Zeros represent values less than 1,000.

Source: U.S. EPA analysis for this report.

3% Discount Rate7% Discount Rate

Region

Annualized Benefits a (2009$, millions)

Recreational Fishing Benefits

Nonuse 

Benefits

Commercial 

Fishing 

Benefitsc

T&E Species 

Benefitsd,e

To
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 10-10: Summary of National Benefits of Option 3 (I&E Mortality Everywhere) for All In-scope Facilities (2009

Low Mean High Low 

California $1.1 $1.8 $3.1 $0.8 - - $1.9 North Atlantic $1.0 $1.6 $2.7 $0.2 - $15.5 $16.7 Mid-Atlantic $8.6 $14.4 $25.1 $1.6 - $60.0 $70.2 South Atlantic $0.1 $0.2 $0.3 $0.0 - - $0.2 Gulf of Mexico $3.3 $4.9 $7.7 $1.8 - - $5.1 Great Lakes $0.7 $1.3 $2.3 $0.1 - - $0.8 Inland $10.0 $20.7 $43.1 - $0.7 - $10.7 Total $24.8 $44.9 $84.2 $4.5 $0.7 $75.5 $105.5 California $0.8 $1.4 $2.3 $0.6 - - $1.4 North Atlantic $0.8 $1.2 $2.0 $0.2 - $12.0 $12.9 Mid-Atlantic $6.0 $10.0 $17.5 $1.1 - $46.5 $53.6 South Atlantic $0.1 $0.1 $0.2 $0.0 - - $0.1 Gulf of Mexico $2.5 $3.8 $5.9 $1.4 - - $3.9 Great Lakes $0.6 $1.0 $1.8 $0.0 - - $0.6 Inland $7.6 $15.8 $32.8 - $0.5 - $8.1 Total $18.3 $33.3 $62.5 $3.3 $0.5 $58.5 $80.7 

a All benefits presented in this table are annualized, i.e., equal to the value of all benefits generated over the time frame of the analysis, discounted to 2012, and then ann

of this analysis (2012 to 2062). See Appendix D for detail.

b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value per 

analysis. Commercial fishing benefits are computed based on a region-and species-specific range of gross revenue, as explained in Chapter 6 of this report. EPA estimafor some T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commercial fishing benefits and Tto the respective low, mean, and high values for recreational fishing benefits.c No significant commercial fishing takes place in the Inland region. Thus, this region is ex

fishing analysis.

d Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon). See Chapter 5 of this 

for more detail on EPA’s analysis of T&E benefits.

e Zeros represent values less than 1,000.

Source: U.S. EPA analysis for this report.

3% Discount Rate7% Discount Rate

Nonuse 

Region Benefits

Annualized Benefitsa (2009$, millions)

Recreational Fishing Benefits Commercial 

Fishing 

Benefitsc

T&E Species 

Benefitsd,e

To
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 10-11: Summary of National Benefits by Regulatory Option for All In-scope Facilities (2009$) 

Low Mean High Low Mean 

Baseline $42.7 $76.89 $143.2 $8.05 $1.14 $128.64 $180.5 $214.72 

Option 1 $8.0 $15.62 $31.4 $0.99 $0.50 $0.52 $10.0 $17.63 

Option 2 $24.0 $43.52 $81.5 $4.47 $0.72 $72.10 $101.3 $120.80 Option 3 $24.8 $44.94 $84.2 $4.52 $0.72 $75.48 $105.5 $125.65 Baseline $42.0 $75.64 $141.0 $7.89 $1.14 $130.78 $181.8 $215.45 Option 1 $7.2 $14.21 $28.5 $0.89 $0.45 $0.48 $9.1 $16.04 

Option 2 $17.8 $32.40 $60.8 $3.31 $0.56 $55.94 $77.6 $92.2Option 3 $18.3 $33.30 $62.5 $3.34 $0.55 $58.52 $80.7 $95.7

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 MGD; Option 3 = I&E MEverywherea All benefits presented in this table are annualized, i.e., equal to the value of all benefits generated over the time frame of the analysis, discounted to 2012, and then annu

entire period of this analysis (2012 through 2062). See Appendix D for detail.

b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value per f

meta-analysis. Commercial fishing benefits are computed based on a region- and species-specific range of gross revenue, as explained in Chapter 6 of this report. EPA esrecreational use benefits for some T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commerciaand T&E species benefits are added to the respective low, mean, and high values for recreational fishing benefits.

c No significant commercial fishing takes place in the Inland region. Thus, this region is excluded from the commercial fishing analysis.d Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon). 

See Chapter 5 of this report for more detail on EPA’s analysis of T&E benefits.Source: U.S. EPA analysis for this report.

3% Discount Rate7% Discount Rate

Regulatory Option

Annualized Benefitsa (2009$, millions)

Recreational Fishing Benefits Commercial Fishing 

Benefitsc

T&E Species 

Benefitsd,e

Nonuse Total Bene

Benefits
March 28, 2011 10-12 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

10.5 Break-Even Analysis 

Comprehensive estimates of total resource value include both use and nonuse values, such that the 

resulting total value estimates may be compared to total social cost. Recent economic literature provides 

substantial support for the hypothesis that mean nonuse values are greater than zero. Moreover, when 

small per-capita nonuse values are held by a substantial fraction of the population, they can be very large 

in the aggregate. While the general proposition is true, in this specific context we have been able to 

estimate nonuse values for only two of the seven benefits regions. 

As shown in Table 10-6 above, nearly all—97 percent—I&E mortality losses at cooling water intake 

structures under current conditions (the baseline scenario) consist of either forage species or unlanded 

recreational and commercial species that are not harvested and thus were not assigned direct use values. 

Although individuals do not use these resources directly, they may value changes in the status or quality 

of these resources. EPA did not estimate nonuse values for forage and unlanded species occurring in five 

of the seven benefits regions. Due to the uncertainties of providing estimates of the magnitude of nonuse 

values associated with the regulatory options for all regions, this section provides an alternative approach 

for evaluating the potential relationship between benefits and costs. The approach used here applies a 

“break-even” analysis to identify what the unmonetized nonuse values would have to be in order for the 

proposed options to have benefits that are equal to costs. 

The break-even approach uses EPA’s estimates of monetized commercial and recreational use benefits for 

the regulatory options, and subtracts them from the estimated annual compliance costs incurred by 

facilities subject to the options. The resulting “net cost” enables one to work backwards to estimate what 

the nonuse values would need to be (in terms of willingness to pay per household per year) in order for 

total annualized benefits to equal annualized costs. Table 10-12 provides this assessment for the proposed 

options. The table shows benefit values using a 3 percent or 7 percent discount rate, respectively. 

As shown in Table 10-12, for total annualized benefits to equal total annualized costs, nonuse values per 

household would have to be at least $3, but may be as great as $40 under the 3 percent discount rate, 

depending on the regulatory option. The 7 percent discount estimates show that nonuse values per 

household would have to be $4 to $42, depending on the regulatory option. 
March 28, 2011 10-13 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 10-12: Implicit Nonuse Value—Break-Even Analysis, 3 Percent and 7 Percent Discount 

Rates (2009$) 

Regulatory Optiona

Use Benefits 

(2009$, 

millions)a

Annual Social 

Cost (2009$, 

millions)b

Annual Nonuse 

Benefits Necessary to 

Break Even (2009$) c, d

Number of Households 

in States with In-scope 

316(b) Facilities 

(millions)e

Annual BreakEven Nonuse WTP 

per Household 

(2009$)f

Option 1 $17.11 $383.80 $366.69 114.5 $3.20

Option 2 $48.71 $4,462.90 $4,414.19 114.5 $38.54

Option 3 $50.17 $4,631.62 $4,581.45 114.5 $40.00

Option 1 $15.55 $458.81 $443.26 114.5 $3.87

Option 2 $36.27 $4,699.35 $4,663.08 114.5 $40.71

Option 3 $37.19 $4,862.05 $4,824.86 114.5 $42.12

Scenarios: Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 MGD; Option 3 = I&E Mortality Everywhere

a

 Benefits are discounted using a 3% or 7% discount rate, respectively. Use benefits include estimated commercial fishing benefits, recreational 

fishing benefits, and use benefits for T&E species.

b

 The total social cost of the final rule includes facility compliance costs and administrative costs.

c

 Annualized compliance costs minus annualized use benefits.

d

 Nonuse benefits may also include unmonetized use benefits, i.e., improvements in bird watching.

e

 From U.S. Census 2000 (BLS): http://factfinder.census.gov. 

f

 Dollars per household per year that, when added to use benefits, would yield a total annualized benefit (use plus nonuse) equal to the 

annualized costs.

3% Discount Rate

7% Discount Rate

While this approach of backing out the “break-even” nonuse value per household does not answer the 

question of what nonuse values might actually be for the regulatory options, these results do frame what 

the unknown values would have to be in order for benefits to equal or exceed costs. The break-even 

approach poses the question: “Is the true per-household willingness to pay for the nonuse amenities 

(existence and bequest) associated with an option likely to be greater or less than the ‘break-even’ benefit 

levels displayed in Table 10-12?” The results of EPA’s Habitat Equivalency Analysis (HEA) (Chapter 9) 

illustrate the potential magnitude of nonuse values for 316(b) regulatory options. However, EPA does not 

consider HEA appropriate for a primary analysis of nonuse benefits due to limitations of the approach and 

assumptions required for its application to 316(b) regulatory options. 
March 28, 2011 11-1 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

11 Option 4 Results 

11.1 Introduction 

In addition to the three regulatory options presented in the preceding chapters of this report, i.e., Options 

1, 2, and 3, EPA analyzed an additional regulatory option – Option 4: I for Facilities > 50 MGD – in 

developing the Proposed 316(b) Existing Facilities Regulation. Option 4 is the same as Option 1: I 

Everywhere, in all respects except for not requiring I mortality control for facilities less than 50 MGD. 

Because EPA analyzed Option 4 after completing the analysis and documentation of the three main 

regulatory options, the analysis results for Option 4 are presented separately in this chapter. The 

methodology used to estimate the benefits of Option 4 are identical to those used for Options 1, 2, 3. See 

Chapters 3 through 9 for additional detail regarding EPA’s methodology. This chapter presents the results 

for Option 4 in two parts: 

 The expected reductions in I&E Mortality under Option 4; and 

 The monetized benefits under Option 4, including recreational fishing, commercial fishing, T&E 

species, and nonuse benefits. 

11.2 Expected Reductions in I&E Mortality under Option 4 

Based on the results of the regional analyses, EPA calculated the total amount by which I&E mortality 

losses would be reduced under Option 4. The number of fish lost at in-scope facilities is presented in 

terms of age-1 equivalent (A1E) losses within Table 11-1. All reductions in I&E mortality under Option 4 

are associated with reduced impingement. The reduction in national A1E losses is 602 million, or 

approximately 98 percent of the reductions under Option 1 (I Everywhere). The percentage of national 

A1E losses assigned a direct use value is 2.6 percent, slightly higher than the percentage observed under 

Option 1. The remaining 97 percent of I&E mortality losses include unharvested recreational and 

commercial fish and forage fish which are not assigned direct use values. Reductions in I&E mortality for 

T&E species are slightly less than Option 1 (Table 5-5). Appendix C provides additional detail regarding 

reductions in I&E mortality losses under Option 4. 

Table 11-1: Distribution of I&E Mortality for All In-scope Facilities by Region Under Option 4 (I 

Everywhere without New Units Requirements) 

Region

All Species 

(million A1E)

Forage Species 

(million A1E)

Commercial & 

Recreational Species 

(million A1E)

Commercial & 

Recreational Harvest 

(million fish)

A1E Losses 

with Direct Use 

Value (%)

California 0.7 0.2 0.5 0.1 8.0%

North Atlantic 0.4 0.4 0.1 <0.1 1.5%

Mid-Atlantic 38.6 14.3 24.4 6.1 15.8%

South Atlantic 14.2 13.4 0.8 0.1 0.7%

Gulf of Mexico 34.2 4.3 30.0 4.6 13.3%

Great Lakes 37.9 33.2 4.7 0.5 1.3%

Inland 476.3 448.4 27.9 4.2 0.9%

Total 602.4 514.1 88.3 15.5 2.6%
March 28, 2011 11-2 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

11.3 Monetized Benefits Under Option 4 

EPA’s estimation of regional and national benefits under Option 4 are based on EPA’s regional estimates 

of reductions in I&E mortality losses. Option 4 would result in an estimated increase of approximately 5.7 

million harvestable recreational fish and an estimated annual increase of 5.5 million pounds of 

commercial harvest (Table 11-2Error! Reference source not found.). Monetized nonuse benefits are 

based on estimated increase in winter flounder abundance of 0.03 percent, calculated using the approach 

described in Chapter 8. Under Option 4, recreational fishing benefits account for the majority of the 

national benefits similar to Option 1 (I Everywhere). As described in Chapter 10, EPA estimated mean 

values, as well as values that include the 5th percentile lower bound and 95th percentile upper bound of the 

recreational benefits estimates. 

Table 11-2: Annual Increase in Recreational and Commercial Harvest Under 

Option 4 (I Everywhere without New Units Requirements) 

Region

Annual Increase in Recreational 

Harvest

(harvestable adult fish)

Annual Increase in Commercial 

Harvest

(thousand lbs)

California 35,421 6.5

North Atlantic 1,495 2.9

Mid-Atlantic 548,496 3746.3

South Atlantic 15,882 45.1

Gulf of Mexico 660,672 1448.4

Great Lakes 174,601 225.1

Inland 4,215,546 -

Total 5,652,113 5474.3

Overall, monetized benefits under Option 4 are slightly less than those estimated for Option 1: 

 Using a 3% discount rate, Option 4 results in national benefits of $17.3 million per year, with 

estimates based on the 5th percentile lower bound and 95th percentile upper bound for 

recreational values, totaling $9.8 million and $32.8 million (Table 11-3). Use benefits are 

estimated to be $16.8 million with an annual break-even nonuse WTP of $2.70 per household 

based on total social costs of $326.6 million. 

 Using a 7% discount rate, Option 4 results in national benefits of $15.8 million per year, with 

estimates based on the 5th percentile lower bound and 95th percentile upper bound for 

recreational values, totaling $8.9 million and $29.8 million (Table 11-3). Use benefits are 

estimated to be $15.3 million with an annual break-even nonuse WTP of $3.21 per household 

based on total social costs of $383.1 million. 

Table 11-4 summarizes results from applying the habitat-based approach described in Chapter 9. Similar 

to other options, the Inland region accounts for the majority of habitat acres. National weighted WTP is 

estimated to be $510 million and $474 million using discount rates of 3% and 7%, respectively. As 

described in previous chapters, EPA did not include values estimated using the habitat-based approach 

within its estimate of national benefits as presented in Table 11-3. 
March 28, 2011 11-3 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 11-3: Summary of National Benefits of Option 4 (I for Facilities > 50 MGD) (2009$) 

Low Mean High Low 

California $0.1 $0.1 $0.1 $0.0 - - $0.1 North Atlantic $0.0 $0.0 $0.0 $0.0 - $0.1 $0.1 Mid-Atlantic $0.8 $1.6 $3.1 $0.3 - $0.4 $1.6 South Atlantic $0.0 $0.0 $0.1 $0.0 - - $0.0 Gulf of Mexico $1.4 $2.4 $4.3 $0.6 - - $2.0 Great Lakes $0.6 $0.9 $1.6 $0.0 - - $0.6 Inland $4.9 $10.3 $21.5 - $0.5 - $5.4 Total $7.8 $15.3 $30.8 $1.0 $0.5 $0.5 $9.8 

California $0.0 $0.1 $0.1 $0.0 - - $0.0 North Atlantic $0.0 $0.0 $0.0 $0.0 - $0.1 $0.1 Mid-Atlantic $0.7 $1.4 $2.8 $0.3 - $0.4 $1.4 South Atlantic $0.0 $0.0 $0.0 $0.0 - - $0.0 Gulf of Mexico $1.3 $2.2 $3.9 $0.5 - - $1.8 Great Lakes $0.5 $0.9 $1.5 $0.0 - - $0.6 Inland $4.5 $9.4 $19.6 - $0.4 - $5.0 Total $7.1 $13.9 $28.0 $0.9 $0.4 $0.5 $8.9 

Region

Annualized Benefitsa (2009$, millions)

Recreational Fishing Benefits

Commercial Fishing 

Benefitsc

T&E Species 

Benefitsd,e

Nonuse 

Benefits

To

3% Discount Rate7% Discount Rate

a All benefits presented in this table are annualized, i.e., equal to the value of all benefits generated over the time frame of the analysis, discounted to 2012, and then ann

this analysis (2012 to 2062). See Appendix D for detail.

b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value per 

analysis. Commercial fishing benefits are computed based on a region-and species-specific range of gross revenue, as explained in Chapter 6 of this report. EPA estimasome T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commercial fishing benefits and T&E respective low, mean, and high values for recreational fishing benefits.c No significant commercial fishing takes place in the Inland region. Thus, this region is excluded 

analysis.

d Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon). See Chapter 5 of this 

for more detail on EPA’s analysis of T&E benefits.

e Zeros represent values less than 1,000.
March 28, 2011 11-4 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table 11-4: Weighted WTP for Habitat Restoration Area Equivalent to I&E Mortality Reductions by 

Region under Option 4 (I for Facilities > 50 MGD) 

3% 

Discount 

Rate

7% 

Discount 

Rate

California 96 3 35 - 0.0 0.0

North Atlantic 50 1 23 0.076 0.5 0.4

Mid-Atlantic 47 240 5,145 0.017 211.1 196.3

South Atlantic 83 13 159 0.011 0.4 0.3

Gulf of Mexico 83 338 4,091 0.011 152.7 142.0

Great Lakes 82 251 3,065 0.003 10.4 9.6

Inland 82 3,340 40,813 0.001 134.8 125.4

Total

(All Regions) - 4,186 53,331 - 509.9 474.0

Region

Household 

WTP acre-1 

year

-1

(2009$)

Weighted WTP (2009$, 

Secondary millions)

Productivity 

(kg acre-1 year-1)

I&E Losses 

(metric tons 

A1E, dry 

weight)

Equivalent 

Restoration 

Area (acres)
March 28, 2011 12-1 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

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United States: 1971–1997." Ecological Applications 9(3): 772-783. 

Wilson, R. W., F. J. Millero, et al. (2009). "Contribution of Fish to the Marine Inorganic Carbon Cycle." 

Science 323(5912): 359-362. 

Wisconsin Department of Natural Resources (Wisconsin DNR) (2003). "Adrift on the sea of life." 

Wisconsin Natural Resources June: 17-21. 

Wisconsin Power & Light Company (WPLC) v. Federal Energy Regulatory Commission (FERC). 2004. 

363 F.3d 453. (DC Circ. 2004). 

Woodward, R. T. and Y.-S. Wui (2001). "The economic value of wetland services: a meta-analysis." 

Ecological Economics 37(2): 257-270. 

Woodwell, G. M., D. E. Whitney, et al. (1977). "The Flax Pond Ecosystem Study: Exchanges of Carbon 

in Water Between a Salt Marsh and Long Island Sound." Limnology and Oceanography 22(5): 

833-838. 
March 28, 2011 A-1 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Appendix A: Extrapolation Methods 

A.1 Introduction 

Survey sample weights for manufacturing facilities and electric power generating facilities were used in 

the analysis of 316(b) Phase II and Phase III regulations (USEPA 2004b; USEPA 2006b). To account for 

differences between electric power facilities that received the DQ and those that received the Short 

Technical Questionnaire (STQ), and to account for 316(b) study regions, new weights were developed. 

These weights are referred to as new benefits weights. This appendix explains the development of these 

facility-level weights and their use in the benefits analysis for the proposed 316(b) regulation. 

A.2 Manufacturing Facilities 

The current analysis of manufacturing facilities incorporates a set of technical weights developed for the 

2006 Final Phase III Rule. These technical weights are based on engineering information obtained from 

the 316(b) Manufacturers Questionnaire, including an estimate of the number of affected facilities and the 

cost of installing new technology. However, because technical weights do not account for facility location 

or intake flow, they cannot be used to directly estimate intake flow at a regional level, a key parameter for 

the benefits analysis. This section presents new benefits weights developed by EPA for in-scope 

manufacturing facilities. 

New benefits weights were developed by adjusting technical weights for traditional manufacturers (MN 

facilities)48 and non-utility manufacturers (MU facilities) such that estimates of regional mean operational 

flow are consistent with EPA’s best estimates for manufacturing facilities. EPA chose this characteristic 

because operational intake flow is the most important factor in the benefits analysis: I&E mortality losses 

as a function of mean operational intake flow. EPA included eight regions when developing weights for 

MN and MU facilities: North Atlantic, Mid-Atlantic, South Atlantic, Gulf of Mexico, California, Pacific 

Northwest,49 Great Lakes, and Inland regions.50 

Information on total regional flow was not available for MN and MU facilities. Thus, EPA used the 

number of facilities present in any single region as a control variable. This presumes that the flow 

characteristics of these represented facilities are the same as the DQ facilities. The following two sections 

describe development of weight adjustment factors for MN and MU facilities, respectively. 

A.2.1 Traditional Manufacturers (MN Facilities) 

EPA stratified the universe of MN facilities by study region and industry category so that the regional 

distribution of in-scope MN facilities corresponds to the actual geographic distribution of all MN facilities 

 

48 MN facilities include aluminum, steel, chemical, pulp and paper, and petroleum refining manufacturing industries. Note that 

Food and Kindred Products is not included in this list of industries for two reasons: a) this industry was not included in the 

original stratification of manufacturers, and b) all facilities later identified to be in the Food and Kindred Product industries 

were part of the MU universe. 

49 The Pacific Northwest region is ultimately excluded from the benefits analysis because it includes a single DQ facility which is 

projected to close as baseline. 

50 See Chapter 1 for additional information regarding regional definitions. 
March 28, 2011 A-2 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

in a given industry.51 Under this approach, EPA first determined the distribution of in-scope facilities by 

study region, and then calculated adjusted benefits weights based on this distribution. 

Determining the Distribution of In-scope Facilities by Study Region 

EPA obtained latitude-longitude coordinates (lat-long) for all facilities in relevant Standard Industrial 

Classification (SIC) codes52 that have NPDES permits within PCS (Permit Compliance System) and 

ICIS-NPDES (Integrated Compliance Information System- NPDES). Facilities within relevant SIC codes 

were assigned to a study region using lat-long. A map of RF1 reaches53 was also used to indicate whether 

the facility location is coastal/estuarine or inland. Table A-1 presents the distribution of the facility 

universe according to region and industry based on the PCS/ICIS data. 

The sample frame for the survey screener of manufacturing facilities did not include all facilities in the 

relevant SIC codes. Information on which facilities were included in the sample frame for the screener is 

not available. Therefore, EPA used two simplifying assumptions to develop weight adjustment factors: 

(1) the universe of in-scope facilities in any single industry equals the sum of DQ facilities weights and 

(2) the geographic distribution of NPDES permitted facilities in the relevant SIC codes is representative 

of the geographic distribution of in-scope facilities. 

For each industry, EPA assumed that the geographic distribution of facilities included in the EPA 

PCS/ICIS database was equivalent to the geographic distribution of the DQ frame. To meet this 

assumption, EPA redistributed the weights of in-scope DQ facilities in each study region to match the 

geographic distribution of facilities in the PCS/ICIS database. The second and third columns in Table A-1 

present the estimated distribution of in-scope MN facilities based on PCS/ICIS data.54

Calculating Adjusted Weights for Benefits Analysis

EPA first compared the regional distribution of weighted of in-scope DQ facilities to the distribution of 

facilities present in the PCS/ICIS universe. Table A-1 presents the distribution of DQ facilities based on 

technical weights, the weight adjustment factors for MN facilities, and the expected number of DQ 

facilities for all regions. The number of DQ facilities in each region was re-estimated using the PCS/ICIS 

distribution of facilities in that region. This adjustment factor was defined as the quotient of the number of 

DQ facilities within a region and industry divided by the original number of weighted DQ facilities 

assigned to the same stratum. If the PCS/ICIS facilities universe indicated that a region had a small 

number of facilities within a single industry and did not have DQ facilities (e.g., the North Atlantic region 

for the Aluminum sector), EPA assumed that no in-scope facilities existed within the stratum. Because 

regions without DQ facilities comprised a small fraction of the PCS/ICIS facility universe, this 

assumption is likely to introduce negligible error. If the adjusted weight for a sample DQ facility was less 

than one, it was assigned a weight of one so that its actual flow would be fully counted. The cost analysis 

 

51Weights were not adjusted for petroleum refineries because survey screeners were sent to the entire universe and DQs were sent 

to all in-scope facilities. Weights for facilities determined to be in other industries after receipt of the DQ were given 

weights of 1, which were not adjusted. 

52The SIC code describes the primary activity of the facility. 

53EPA’s reach file (RF1) is a database of interconnected steam segments of “reaches” that comprise the surface water drainage 

system for the United States. 

54EPA used the following databases to obtain information on the number of facilities in each SIC code: FRS (Federal Registry 

System), PCS (Permit Compliance System), ICIS-NPDES (Integrated Compliance Information System- NPDES) and TRI 

(Toxics Release Inventory). None of these databases records intake flow. 
March 28, 2011 A-3 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

estimates 32 facilities to close under baseline conditions. Accordingly, EPA excluded the baseline 

closures and their weights from the benefits analysis and weights readjustment. 

The final two columns of Table A-1 present estimated total flow for each sector and region when both 

original DQ and adjusted weights have been applied. In many sectors, estimated flow is slightly smaller 

due to the lack of DQ facilities combinations of region and industry. Conversely, weight-adjusted flow in 

the chemical sector increases slightly due to good coverage of DQ facilities which shifted weights to 

facilities with above-average flow. 
March 28, 2011 A-4 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table A-1: MN DQ Distribution and Calculation of Weight Adjustment Factors 

Benefits Region 

Distribution of 

Facilities in 

PCS/ICIS 

Databases 

Number of 

Regional Mean 

Operational Flow 

(MGD) 

Number % 

DQweighted 

Facilities1

Adjustment 

Factor 

Adjusted 

Weight 

Estimates 

DQweighted 

Adjusted 

Weight 

Estimates 

Aluminum 

North Atlantic 7 6% No DQs2 0 No DQs 0.0 

Mid-Atlantic 11 9% No DQs2 0 No DQs 0.0 

South Atlantic 1 1% No DQs 0 No DQs 0.0 

Great Lakes 2 2% 3 0.09 1 30.3 9.7 

Gulf of Mexico 1 1% No DQs 0 No DQs 0.0 

Pacific Northwest 0 0% No DQs 0 No DQs 0.0 

California 0 0% No DQs 0 No DQs 0.0 

Inland 95 81% 13 1.01 13 87.0 88.3 

Total 117 100% 16 14 117.3 98.0 

Chemical

North Atlantic 16 1% No DQs 0 No DQs 0.0 

Mid-Atlantic 75 6% 4 2.14 9 28.7 61.3 

South Atlantic 9 1% 4 0.26 1 56.4 14.5 

Great Lakes 32 3% 17 0.23 4 331.0 77.1 

Gulf of Mexico 100 8% 4 2.85 12 283.9 809.8 

Pacific Northwest 4 0% No DQs 0 No DQs 0.0 

California 5 0% 4 0.14 1 1.5 0.4 

Inland 951 80% 112 1.04 117 1,782.8 1,860.0 

Total 1,192 100% 146 144 2,484.3 2,823.1 

Paper

North Atlantic 2 1% No DQs 0 No DQs 0.0 

Mid-Atlantic 7 2% No DQs 0 No DQs 0.0 

South Atlantic 8 2% No DQs 0 No DQs 0.0 

Great Lakes 19 5% 3 1.684 5 6.7 11.2 

Gulf of Mexico 2 1% No DQs 0 No DQs 0.0 

Pacific Northwest 3 1% No DQs 0 No DQs 0.0 

California3 0 0% 3 1.00 3 32.2 32.2 

Inland 354 90% 91 0.95 86 1,242.9 1,181.4 

Total 395 100% 96 94 1,281.8 1,224.8 

Steel 

North Atlantic 3 1% No DQs 0 No DQs 0.0 

Mid-Atlantic 5 2% No DQs 0 No DQs 0.0 

South Atlantic 1 0% No DQs 0 No DQs 0.0 

Great Lakes 25 10% 6 0.54 3 2,054.3 1,112.1 

Gulf of Mexico 3 1% No DQs 0 No DQs 0.0 

Pacific Northwest 1 0% No DQs 0 No DQs 0.0 

California 2 1% No DQs 0 No DQs 0.0 

Inland 214 84% 28 1.03 29 519.6 535.0 

Total 254 100% 34 32 2,573.9 1,647.1 

Petroleum

North Atlantic 0 0% No DQs 0 No DQs 0.0 

Mid-Atlantic 2 11% 2 1.00 2 203.4 203.4 

South Atlantic 0 0% No DQs 0 No DQs 0.0 

Great Lakes 0 0% No DQs4 0 No DQs 0.0 

Gulf of Mexico 1 6% 1 1.00 1 42.6 42.6 

Pacific Northwest 0 0% No DQs 0 No DQs 0.0 

California 1 6% 1 1.00 1 31.8 31.8 

Inland 15 78% 15 1.00 15 250.7 250.7 

Total 19 100% 19 19 528.4 528.4 
March 28, 2011 A-5 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table A-1: MN DQ Distribution and Calculation of Weight Adjustment Factors 

Benefits Region 

Distribution of 

Facilities in 

PCS/ICIS 

Databases 

Number of 

Regional Mean 

Operational Flow 

(MGD) 

Number % 

DQweighted 

Facilities1

Adjustment 

Factor 

Adjusted 

Weight 

Estimates 

DQweighted 

Adjusted 

Weight 

Estimates 

Other 

Inland 1 100% 1 1.00 1 4.1 4.1 

Total 1 100% 1 1 4.1 4.1 

Total for All Industries 

North Atlantic 28 1% No DQs 0 No DQs 0.0 

Mid-Atlantic 100 5% 6 11 232.0 264.7 

South Atlantic 19 1% 4 1 56.4 14.5 

Great Lakes 78 4% 29 13 2,422.3 1,210.0 

Gulf of Mexico 107 5% 5 13 326.5 852.4 

Pacific Northwest 8 0% No DQs 0 No DQs 0.0 

California 8 0% 8 5 65.5 64.4 

Inland 1,630 82% 259 260 3,887.0 3,919.5 

Total 1,978 100% 312 304 6,989.8 6,325.5 1

EPA did not adjust weights for petroleum refineries because the DQ was a census of in-scope facilities, nor for facilities in “other” 

industries because they were outside the five SIC codes for which weights were developed and are not assumed to represent any 

other facilities. 

2

Though these regions account for more than 5% of Aluminum manufacturers but have no DQs, the average flow for Aluminum 

manufacturers is less than 10 MGD. Potential benefits associated with these facilities would be relatively minor. 3

While the PCS/ICIS data did not identify any Paper facilities in the California Region, there was 1 DQ facility in this region with a 

weight of 3. This weight was not adjusted. 

4

There was 1 DQ refinery in the Great Lakes region. However this facility was assessed as a baseline closure in the economic 

analysis and thus receives an adjustment factor of 0. 

A.2.2 Non-utility Manufacturers (MU Facilities) 

EPA accounted for the geographic distribution of MU facilities using a methodology similar to that used 

for MN facilities. Weights were adjusted so that the distribution of the weighted number of DQ facilities 

matched the actual geographic distribution of the facility universe. Under this approach, EPA first 

determined the distribution of in-scope facility by study region, and then calculated adjusted weights for 

use in the benefits analysis. 

Determining the Distribution of In-scope Facilities by Study Region 

The entire universe of MU facilities was known based on the survey screener and the OTIS Facility-finder 

tool was used to obtain facility location data.55 EPA distributed the universe of facilities among study 

regions based on the regional distribution of MU facilities with location data from OTIS Facility-finder. 

Calculating Adjusted Weights for Benefits Analysis

For each study region, EPA compared the estimated number of MU facilities with the DQ-weighted 

number of facilities in the region. An adjustment factor was calculated as the quotient of the estimated 

number of facilities in each region divided by the DQ-weighted number of facilities in each region. If the 

adjusted weight for a facility was less than one, it was assigned a weight of one to fully account for the 

 

55 While the survey screener asked for facilities’ flow, EPA was unable to develop adjustment factors using total flow as a control 

variable. 
March 28, 2011 A-6 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

flow of the sampled facility. Adjustment factors and adjusted flow by benefits region are presented in 

Table A-2. 

Table A-2: MU Adjustment Factors and Adjusted Flow by Benefits Region

Benefits Region 

Estimated 

Facilities 

from In-scope 

Distribution 

DQweighted 

Facilities 

Adjustment 

Factor 

Total Original 

Weighted Flow 

(MGD) 

Total Adjusted 

Weighted Flow 

(MGD) 

MU Facilities 

North Atlantic 6 5 1.2 220.9 275.3 

Mid-Atlantic 3 6 0.5 440.8 369.0 

South Atlantic 2 No DQs No DQs 0.0 

Great Lakes 14 12 1.2 1,186.4 1,400.0 

Gulf of Mexico 8 6 1.3 577.0 744.0 

Pacific Northwest 0 1 0.0 0 0.0 

California 2 1 2.0 3.6 7.3 

Inland 163 174 0.9 9,464.7 8,880.9 

Total 198 205 11,893.5 11,676.6 

NU Facilities Determined to be Manufacturers1

Inland N/A 12 16 392.9 392.9 

Paper

Grand Total N/A 217 12,286.4 12,069.5 1

Two facilities that were surveyed as non-utilities (NU) were later determined to be non-utility manufacturers and are analyzed as such in 

the cost analysis. Their weights were not adjusted because they were not part of the original MU facility universe and are both in the 

inland region. Given that the majority of MU facilities are located in the Inland region the use of original weights is unlikely to bias 

regional benefit results 

A.3 Electric Power Generating Facilities 

The benefits analysis for electric power generating facilities uses a combination of weights from the 

316(b) Phase II and Phase III analyses and sample weights developed to support the 2010 analysis. 

Weights from Phase II and Phase III accounted for non-sampled facilities and non-respondents to industry 

surveys and are referred to as the original survey weights.

56 

When estimating national-level benefits, sample weights based on facility-specific (e.g., size and 

engineering) characteristics can lead to conditional bias. In particular, this approach does not consider 

factors influencing the occurrence and size of benefits such as the location of facilities subject to the 

regulatory options, actual intake flow, similarities among aquatic species affected by these facilities, and 

characteristics of commercial and recreational fishing activities in the area. EPA used a post-stratification 

weight adjustment to calculate benefits weights that account for data dimensions not included in the 

original sample design. These benefits weights re-scale DQ-based weights using additional information 

from the STQ so that total regional flows represented by both weighting systems are equivalent. 

The remainder of this appendix describes the post-stratification weight adjustment for electric power 

generating facilities. Section A.3.1 describes how the strata were defined. Section A.3.2 presents and 

discusses the estimates resulting from the post-stratified weighting schemes and compares these to the 

original DQ weights. 

 

56In general, the original survey weights are numerically very low, as EPA had either DQ or STQ information for 621 out of the 

634 electric generating facilities presumed to be in scope of the regulation. For more information on EPA’s Section 316(b) 

Industry Surveys, please refer to the Information Collection Request (USEPA 2000b). 
March 28, 2011 A-7 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

AA 

A.3.1 Defining the Strata and Control Variables 

EPA included six study regions when developing benefits weights for electric power generating facilities: 

North Atlantic, Mid-Atlantic, South Atlantic, Gulf of Mexico, Great Lakes, Inland, and California 

regions. Strata characteristics used to adjust weights are presented in Table A-3. 

I&E mortality losses are largely a function of mean operational intake flow and characteristics of local 

fishery resources. Therefore, regional non-recirculated operational flow is the most important factor in 

defining strata for the benefits estimation, and it is more important to group estimated total benefits by 

non-recirculated intake flow in a study region than by number of facilities. When calculating weights, 

EPA included a strata based on a 125 MGD DIF so that benefit estimates accurately reflect changes in 

technology under the options analyzed under the regulation. 

Table A-3: Matrix of Strata and Control Variables for Adjusting DQ Weights 

Strata 

Mean Operational Flow (GPD) 

Facilities with Recirculation 

Technology1

Facilities without Recirculation 

Technology 

DIF < 125 

MGD 

DIF > 125 

MGD 

DIF < 125 

MGD 

DIF > 125 

MGD 

North Atlantic 0 0 238 6,510 

Mid-Atlantic 68 0 257 26,518 

South Atlantic 46 0 0 7,033 

Gulf of Mexico 0 0 0 9,049 

Great Lakes 57 181c 343 15,428 

Inland 1,258 2,221 1,900 117,989 

California2 0 0 0 1,135 

Total 1,429 2,402 2,738 183,663 1

Includes all electric generating facilities with recirculating technology regardless of intake velocity. 2

Generators in the state of California were excluded from the analysis; however, the California region includes 

three facilities in Hawaii. 

A.3.2 Comparison of Results of the Detailed Questionnaire and Post-Stratified 

Weighting Schemes 

EPA assigned post-stratification weights (Table A-3) so that tabulations of total mean operational flow by 

region and DIF threshold correspond to the best estimates of operational flow based on information 

provided by both DQ and STQ questionnaires. Estimated mean operational flow under various weighting 

procedures are presented in Table A-4. Regional control total is calculated using operational flow data 

from DQ and STQ and facility-level original sample weights that account for non-sampled facilities and 

non-respondents. The DQ total is the total operational flow of facilities to which weights are applied. By 

design, the post-stratification estimate of mean operational flow equals the control total estimate. Benefits 

weights are determined as the quotient of the control total divided by the DQ total. The number of 
March 28, 2011 A-8 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

facilities estimated using these weights may not match the control estimate of the population of facilities. 

For example, when average mean operational flow in the DQ sample of facilities is lower than the total 

operational flow of all facilities in a given region, larger sample weights must be assigned to ensure the 

estimated sample-weighted operational flow is equivalent to the control total. Thus, although total 

operational flow is equivalent, the number of facilities estimated using these weights may be an 

overestimate of facilities within the region. This shortcoming is not important, however, because DQ 

weights are not used to estimate the number of facilities. 

During the weight development process, EPA assessed the variance of the new weights to examine their 

reasonableness. Weights with smaller variance generally lead to estimates with smaller variance unless 

the larger variance of the weights reflects the characteristics on which the estimates depend. Since mean 

operational flow is the most important factor in determining benefits, EPA believes that accounting for 

this factor while minimizing the variance of the weights is the best approach. This is accomplished by 

assigning an equal weight to all facilities within a given stratum. One alternative would be to adjust the 

original DQ weight. However, adjusting original DQ weights increases the variance of new weights. The 

additional variance is not likely to reflect the characteristics on which the estimates depend, and therefore 

these weights are inferior. 

Table A-4: Mean Operational Flow by Benefits Region: Post-Stratification by Mean 

Regional Operational Flow for Facilities Without Recirculation (MGD) 

Region 

Recirculating Flow Non-recirculating Flow 

< 125 DIF (MGD) > 125 DIF (MGD) < 125 DIF (MGD) > 125 DIF (MGD) 

DQ 

Total 

Control 

Total 

DQ 

Total 

Control 

Total 

DQ 

Total 

Control 

Total 

DQ 

Total 

Control 

Total 

North Atlantic 0 0 0 0 209 238 2,978 6,510 

Mid-Atlantic 58 68 0 0 231 257 8,743 26,518 

South 

Atlantic1a 0 46 0 0 0 0 3,481 7,033 

Gulf of 

Mexico 0 0 0 0 0 0 6,751 9,049 

Great Lakes 0 57 0 181c 120 343 5,199 15,428 

Inland 528 1,258 620 2,221 1,003 1,900 51,560 117,989 

Total 587 1,429 620 2,402 1,625 2,799 80,631 194,997 1

A total of five STQ facilities with baseline (one in the South Atlantic and four in the Great Lakes) did not have a DQ facility to 

represent them within the region and DIF strata. Their flow was added to the respective non-recirculating totals when calculating 

benefits weights, and are assigned the same benefits weights as non-recirculating facilities within the same region and DIF category. 
March 28, 2011 B-1 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

B 

 

Appendix B: Consideration of Potential Ecological Effects due to 

Thermal Discharges 

B.1 Introduction 

Impacts of thermal discharges, along with other stressors, are a relevant consideration when assessing the 

potential impacts of electric power plant cooling water intakes (CWIS) and associated discharges. Several 

studies have demonstrated the adverse effects that increased temperatures or altered seasonal thermal 

regimes have on local biota and fauna. In some cases, studies have indicated little or no apparent harm is 

caused by the thermal discharges. This emphasizes the need for NPDES permit writers to consider sitespecific factors when assessing the potential ecological effects due to thermal discharges. 

This appendix provides information on the general effects of thermal discharges on aquatic biota and 

ecosystems, considers the influence of site-specific factors and environmental settings on determining the 

level (if any) of ecological impacts, and discusses limitation and uncertainty associated with thermal 

studies. It also presents three case studies from power plants in different environmental settings (Brayton 

Point Station, Quad Cities Nuclear Station, and Point Beach Nuclear Plant) which underwent detailed 

thermal studies under Clean Water Act (CWA) Section 316(a) provisions and which show the importance 

of site specific factors in determining the potential for appreciable harm. The Section 316(a) 

demonstrations described in the three case studies represent unusually complete and thorough 

investigations of thermal impacts to receiving aquatic ecosystems. Thermal investigations at other power 

plants are highly site-specific, but typically have a much reduced scope and effort compared to those 

portrayed by the case studies. 

It should be noted that even at power plants where demonstrations of no appreciable harm have been 

made to regulatory authorities under Section 316(a), supporting thermal studies nonetheless often show 

periods during which thermal limits are exceeded. Impacts of thermal discharges should therefore be 

revisited on a case-by-case basis as conditions change, for example(i) if plants increase their power 

capacity (i.e., “uprate”) and increase thermal loads to the receiving waterbody; (ii) if the thermal 

assimilative capacity of the receiving waterbody is otherwise compromised; or (iii) in the face of new 

evidence that cooling water discharges are causing appreciable harm to the balanced, indigenous 

population/community of shellfish, fish, and wildlife or fail to ensure the protection or propagation of the 

population. Such assessments need to consider the extent, duration, timing, and frequency of adverse 

thermal impacts, the target threshold temperature for each species, the potential for adverse temperature 

effects on larger ecological processes, and other relevant site-specific factors. 

B.2 General Effects of Thermal Discharges on Aquatic Biota and Ecosystems 

Thermal discharges affect aquatic organisms by elevating water temperatures or altering seasonal patterns 

of temperature change. Temperature is considered a master environmental variable for aquatic 

ecosystems, affecting virtually all biota and biologically mediated processes, chemical reactions, as well 

as structuring the physical environment of the water column. There is a well-established scientific 

literature cataloguing the impacts of elevated or variable temperature on a wide spectrum of aquatic life, 

including numerous species-specific determinations of thermal tolerance limits for growth, survival, 

reproduction and behavior (e.g., Beitinger et al. 2000; Leffler 1972; McMahon 1975). 
March 28, 2011 B-2 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Much of the relevant primary research on power plant thermal discharges dates from the 1970's-1980's; 

typically based on laboratory studies, field investigations, or environmental impact assessments 

associated with the siting, permitting, and/or operation of power plants with significant thermal plumes 

(e.g., Barnett 1972; Coles 1984; Hillman et al. 1977; Langford 1990 (for review); Squires et al. 1979). 

These studies found that the thermal discharges may affect aquatic species growth, survival and 

reproduction, altered community diversity and density, and may have led to shifts in ecological habitat. 

The character and magnitude of the observed impacts varies among the studies, however. 

Interest in this topic and relevant studies have also re-emerged in the last decade as part of a greater effort 

associated with the assessment and characterization of potential effects of global climate change (e.g., 

Schiel et al. 2004). The material below provides a representative, exemplary mix of studies on thermal 

effects for organisms and communities in a range of trophic levels or ecosystems with some emphasis on 

more recent research. The majority of the cited studies were identified from internet searches and crossreferencing appropriate permitting databases57. 

Primary Producers

Thermal discharges affect aquatic primary production through direct effects on photosynthetic activity 

and selection of temperature-tolerant species in phytoplankton, periphyton, macroalgae and submerged 

aquatic vegetation (SAV) and indirectly through temperature-related changes in nutrient availability and 

grazer activities. Several studies reported that thermal discharges substantially altered the local abundance 

and structure of the aquatic community, particularly benthos and periphyton (e.g., Chuang et al. 2009; 

Martinez-Arroyo et al. 2000; Schiel et al. 2004; Squires et al. 1979). Studies by Mallin et al. (1994) 

suggest that indirect effects of discharge altered the phytoplankton community taxonomic structure near 

the outfall and in general, support different communities of algae than those present in the background 

waters. Several authors suggest that residual chlorine (anti-fouling agent) may also influence these 

patterns (Choi et al. 2002; Moss Landing Marine Laboratories 2006; Poornima et al. 2005). 

Primary Heterotrophs

The bacterial and microbial components of aquatic ecosystems generally have a positive response to 

increasing water temperature – growth rates and bacterially mediated processes are enhanced until 

temperature tolerance limits are approached. Most studies found that the growth rates of bacteria and 

water temperatures are positively correlated. In contrast, Choi et al. (2002) found lower rates of bacteria 

production near outfalls but attributes this effect to residual chlorine in the discharge water rather than 

temperature alone. 

Zooplankton

Zooplankton and other pelagic macroinvertebrates typically increase their grazing activities and growth 

rate in response to increased temperature. Marasse et al. (1992) observed a higher rate of bacteria 

consumption (i.e., bacterivory) by samples of plankton that were incubated at higher temperatures. Jiang 

et al. (2009) suggests that copepod species with larger body sizes are more sensitive to thermal increases 

and that this water temperature increase induces mortalities of copepods. As noted for other organisms, 

 

57 Abt Associates used several general search engines for preliminary searches for scientific and grey literature including Scirus: 

http://www.scirus.com/; Google Scholar: http://scholar.google.com/; and Dogpile: http://www.dogpile.com/, as well as publicly 

available information from NPDES permits and related Section 316a/316b studies. 
March 28, 2011 B-3 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

estuarine copepods have more tolerance to thermal stress than those from more stenothermal, deepwater 

environments. 

Benthic Community

Benthic species and communities are often particularly vulnerable to thermal discharge due to their 

association with the substrate and limited ability to migrate from impacted areas. Growth rates and 

spawning times are usually accelerated by increased temperature (Barnett 1972). McMahon (1975) and 

Leffler (1972) found that snails and blue crabs, respectively, exhibit more rapid growth at higher 

temperatures, but both studies also observe greater species mortality. The study by Coles (1984) found a 

positive effect with the thermal effluent as both the number of organisms and the colonization by coral 

reef propagules near the outfall were significantly greater than background areas. A recent study of 

benthic communities and associated biota near a nuclear power plant discharge show that the thermal 

pollution alters composition and decreases richness in benthic cover (Teixeira et al. 2009). 

Fish

Fish are extremely well-studied with regard to temperature tolerance and thermal limits in both the 

laboratory and field. The thermal habitat requirements of coldwater, coolwater, and warmwater fish 

species are well-characterized (e.g., Beitinger et al. 2000; Sullivan et al. 2000) and these may be the basis 

for regulatory sub-classification of water bodies. Thermal discharges can influence the spatial distribution 

of fish due to direct responses to altered temperature (i.e., attraction, avoidance), effect on dissolved 

oxygen concentrations, and impacts to prey and habitat availability (Cooke et al. 2004; Sullivan et al. 

2000). Rapid fluctuations and decreases in water temperature, usually associated with steep thermal 

gradients in temperate winter waters, can lead to “cold shock” with reduced survival (Ash et al. 1974; 

Deacutis 1978). Smythe and Sawyko (2000) evaluated the effect of “cold shock” on fish and found no 

effect on larger predator species, though a forage species (gizzard shad) had lower survival rates. Some 

studies of thermal discharges have not observed significant effects in local fish communities. Hillman et 

al. (1977) and Krishnamoorthy et al. (2008) found that impacts on shore-zone fish and fingerlings from 

power station discharges were minimal. A study of salmonids by Sullivan et al. (2000) maintains that 

direct mortality from temperature is unlikely since acute lethal temperatures are rarely, if ever, observed 

in the field. Specifically, this study suggests that there is little or no risk of mortality if the annual 

maximum temperature is less than 26°C, but suggests a site-specific analysis when annual maximum 

temperatures exceed 24°C. 

Ecosystem Functions and Services 

In addition to the species-specific impacts, investigators have looked at the effects of thermal discharges 

on the structuring of species assemblages and communities, as well as secondary ecosystem function and 

services. Thermal discharges may have both detrimental and beneficial effects. For example, the 

bleaching and destruction of coral reefs by elevated thermal discharges is well documented, but Coles 

(1984) in the Moss Landing study found that the thermal effluent may have some beneficial effects, such 

as enhancing new coral regrowth or providing preferred water temperatures for avian birds and mammals. 

Work in seven Southeastern U.S. cooling reservoirs indicated that direct thermal effects on phytoplankton 

communities were generally minimal, but that the smaller reservoirs were more prone to algal blooms due 

to nutrient trapping and elevated temperatures (Mallin et al. 1994). Indirect effects of excessive thermal 

loads in these reservoirs caused ecosystem-wide alterations arising from both top-down (higher trophic 

consumers) and bottom-up (primary producers) effects. Martinez-Arroyo et al. (2000) found that 

phytoplankton subjected to elevated water temperature exhibited lowered photosynthetic capacity and 
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Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

light harvesting efficiency and required more light to reach a net oxygen production. Thus, primary 

production and oxygen levels, both critical ecosystem functions, may be decreased as a result of elevated 

temperatures. 

Teixeira et al. (2009) evaluated the effect of thermal discharge on fish communities and habitat structure 

in rocky substrates near a nuclear power plant in southeastern Brazil. Their studies indicate the heated 

effluents affected the habitat structure as well as fish community structure and its eco-spatial distribution. 

Lowered fish species richness was observed in the impacted area and this was attributed to effects to 

differences in benthic cover of a habitat former (i.e., reduced abundance of Sargassum weed). 

B.3 Influence of Site-Specific Factors and Environmental Setting on Thermal 

Effects 

As noted above, the environmental setting (i.e., the nature of the receiving waters) can have a pronounced 

influence on the potential for and the magnitude of adverse thermal impacts on biota. While physical 

features near the discharge and temporal climatic patterns usually dictate the observed level of thermal 

deviations for any given discharge, several environmental factors may be important in determining the 

magnitude of potential impacts, including: geographic location, marine vs. freshwater environments, 

volume of receiving water, rate of water exchange, other heat loads, and local habitats. 

Geographic location

Geographic location determines the duration and intensity of annual solar heating and usually dictates the 

resulting maximum ambient temperatures for the receiving waters. The more southerly the facility, the 

higher the seasonal temperature maxima is likely to be, increasing the possibility of reaching upper 

thermal temperature limits for sensitive organisms. Despite acclimation, relatively few North American 

aquatic organisms will tolerate chronic water temperatures in excess of 35-40o

C (Brock 1985). Northerly 

receiving waters will have lower maximum ambient temperatures in summer, but will also exhibit greater 

seasonal variation; with a more extreme temperature gradient between discharge and surface water during 

winter. Conversely, sub-tropical water temperatures have less seasonal variation and a more consistent 

thermal gradient is maintained between discharge and ambient conditions. Adverse effects to aquatic 

organisms are generally most pronounced at the acute and chronic high lethal temperatures and/or due to 

rapid fluctuations (e.g., "cold shock"). 

Marine vs. Freshwater Receiving Waters

Adverse thermal impacts have been documented in both freshwater and marine ecosystems, but the 

likelihood of impacts may be considered slightly greater in freshwaters simply due to the presumption 

that marine waters constitute a greater thermal reservoir due to larger volume and tidal flushing. 

However, as noted above, site-specific features will dictate the effective volume and the flushing rate, 

which are likely to be the key to vulnerability of receiving water ecosystem to thermal impacts. Clearly, 

the magnitude of thermal impacts also depends on the composition of the local biota and whether such 

organisms are temperature-sensitive. The sensitivity of coldwater freshwater fish (e.g., trout, salmonids, 

darters) to increased water temperature and associated lowering of available dissolved oxygen has been 

well characterized (Beitinger et al. 2000; Sullivan et al. 2000). There is less temperature-sensitivity in 

marine estuarine fish, which are often more tolerant than offshore fish, since they are subject to regular 

environmental fluctuations. 

Receiving Water Volume

The volume of the receiving water is a critical factor since it determines the total amount of heat that can 
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Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

be absorbed by a water body while still remaining at an acceptable temperature. The effective volume 

subject to the thermal discharge may be significantly less than that of the entire water body if it is 

constrained physically (e.g., narrow discharge channel, small coastal embayment) or can vary in the short 

term (e.g., low tide, hydropower releases), seasonally (e.g., thermally stratified lakes, salinity stratified 

estuary), or longer (e.g., multi-year droughts). Due to the buoyant properties of warm water, the effective 

mixed volume can be reduced even further if the thermal plume is not effectively or rapidly mixed into 

the receiving waters. 

Rate of water exchange 

The rate of water exchange is another factor which can compensate for a small effective volume. A short 

hydraulic residence time (HRT) (i.e., rapid flushing) of the receiving water at the point of the thermal 

discharge can rapidly dissipate a high heat load. Large fast rivers, open ocean outfalls, and coastal 

embayments with sweeping longshore currents, etc. can generally better tolerate thermal discharges and 

have limited or highly localized impacts to biota. Poorly flushed systems, those with seasonal flow 

minima, or episodic hydrologic inputs, are more likely to experience widespread or persistent thermal 

impacts. In some cases, the flow or volume of the thermal discharge may be very much greater than the 

receiving water. 

Local land use

Local land uses may also be influential in that they can provide additional thermal loads to the water body 

independent of the thermal discharge. Developed urban areas having watersheds with large percentages of 

impervious cover may produce large storm water flows with temperatures that are well above ambient 

temperatures in the receiving waters. Agricultural lands and irrigation return water may also increase 

local thermal loading. Channelization and removal of riparian buffer vegetation can increase water 

temperature through lack of shading, reflective artificial substrates, and removal of deep pool habitats. 

Local Habitats

Benthic biota and/or habitats (e.g., oyster reefs, eelgrass, and mussel beds) found in nearshore 

environments are often subject to greater impact since these largely sessile communities are affixed to the 

substrate. On the other hand, mobile aquatic organisms can track temperature change and fine-tune their 

temporal and spatial distribution (Cooke et al. 2004). Biota can sometimes avoid adverse thermal impacts 

by seeking out localized areas of cooler or better aerated waters (e.g., deep pool, tributary stream, bottom 

waters) for short-term or seasonal residence. These areas provide habitat that may allow the temperaturesensitive organisms to persist and emigrate back into the affected water body once the thermal stress is 

reduced. Thermal effects could be more severe in homogenous environments (e.g., open water column, 

unstratified reservoir) where the biota does not have access to these refugia. Thermal displacements from 

spawning habitat due to dam construction and operation (e.g., bottom water releases) has also been a 

concern in western rivers and elsewhere (Bartholow et al. 2004; Hayes et al. 2006). 

B.4 Uncertainties and Limitations of Assessing Thermal Impacts 

One of the major difficulties in accurately characterizing the influence of thermal discharges on aquatic 

communities is the uncertainty due to the potential influence of other abiotic water quality factors. 

Thermal discharges from power plant cooling systems often contain elevated levels of additional 

constituents including, but not restricted to: residual chlorine, total suspended solids, total dissolved 

solids, cleaning agents and surfactants, metals, and nutrients. The presence of these constituents may 
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Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

complicate the interpretation of the environmental factor(s) that are responsible for observed changes in 

biotic communities. 

For example, several of our studies on thermal effects on primary producers noted that residual chlorine 

in the discharge may be responsible for some of the observed effects (Chuang et al. 2009; Poornima et al. 

2005). Interaction of thermal effects and heavy metals was responsible for some phytoplankton taxonomic 

changes in one reservoir investigated by Mallin et al. (1994). Looking at the behavior of smallmouth bass, 

Cooke et al (2004) found that a majority of a local radio-tagged population overwintered in the warmest 

portions of a thermal discharge to Lake Erie. However, this area also was high in habitat complexity, had 

adequate flow velocity refuges, and abundant forage so selection for this habitat may not be a simple 

thermal preference. 

Adverse temperature effects may also be more pronounced in aquatic ecosystems which are already 

subject to other environmental stressors such as high biochemical oxygen demand (BOD) levels, sediment 

contamination, or pathogens. Thermal discharges may have indirect effects on fish and other vertebrate 

populations through increasing pathogen growth and infection rates. Langford (1990) reviewed several 

studies on disease incidence and temperature, and while he found no simple, causal relationship between 

the two, he did note that it was clear that warmer water enhances the growth rates and survival of 

pathogens, and that infection rates tended to be lower in cooler waters. 

B.5 Case Studies 

Three case studies were selected for large power generating stations whose thermal discharges may have 

a potential impact to the local aquatic community/ecosystem. These three case studies provide examples 

of investigations of thermal impacts in different environmental settings (marine coastal embayment, 

coastal Great Lake, and freshwater river) and with potential effects investigated at differing spatial scales 

(community, habitat, ecosystem). 

B.5.1 Brayton Point Station 

Brayton Point Station (BPS) is a 1538 megawatt (MW) coal and oil-fired electrical generating station 

located in Somerset, MA. This facility takes cooling water from and discharges heated effluent to Mount 

Hope Bay (MHB), a large coastal embayment whose waters lie within Massachusetts and Rhode Island. 

Generation Unit 1 began operating in 1963, Unit 2 in 1964, Unit 3 in 1969, and Unit 4 in 1974 (Dominion 

2011). One of the most thorough examinations of the individual and cumulative effects of a power plant 

thermal discharge was conducted as part of the regulatory review of the CWA Section 316(a) variance 

request application submitted in May 2001 as part of the NPDES discharge permit (Permit No. MA 

003654) renewal for BPS. The permitee’s 316(a) variance request application looked to keep the existing 

permit temperature criteria (maximum temperature of 95o

F; delta (departure from ambient) temperature of 

22o F) and to reduce the total heat load from the existing permit limits. However, these thermal criteria 

were still less stringent than what would be required by either technology-based or water quality-based 

discharge limits. 

CWA 316(a) authorizes alternative thermal discharge limits when it is demonstrable that the proposed 

thermal limits “will assure the protection and propagation of a balanced indigenous population (BIP) of 

shellfish, fish and wildlife in and on that body of water.” To evaluate whether the thermal limits proposed 

in the May 2001 316(a) variance request application would meet this protective criterion, EPA, in 

accordance with the 316(a) Technical Guidance Manual (USEPA 1977), conducted a review of the 

historical and current conditions of MHB biota on a community-by-community evaluation and considered 
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Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

potential thermal impacts to phytoplankton, zooplankton, habitat formers, shellfish, finfish, and other 

vertebrate (i.e., sea turtles and mammalian) wildlife. The findings of the community impact analyses are 

contained in the “Clean Water Act NPDES Permitting Determinations for Thermal Discharge and 

Cooling Water Intake from Brayton Point Station in Somerset, MA” (USEPA 2002b) dated July 22, 2002 

(hereafter “Determinations”) and summarized below. 

For each of the community types, the Determinations provides a preliminary consideration of whether the 

community’s nature, estuarine setting, and water column distribution within MHB relative to the location 

and magnitude of the BPS thermal discharge would result in a finding of “low potential impact areas” and 

lessened environmental concerns for the granting of the 316(a) variance. For those communities in MHB 

for which a “low potential impact” conclusion was not possible, the severity of the thermal effect was 

gauged by comparison to a list of a priori decision criteria for each community. 

EPA judged that MBH was not a low potential impact area for phytoplankton. As seagrasses and salt 

marshes have historically declined in importance in MHB, the phytoplankton community is the dominant 

primary producer (USEPA 2002b). The recent (2001) occurrence of a nuisance blue-green algal bloom 

(dominated by the cyanophyte Anacystis aeruginosa) in MHB near BPS may be due to the high nutrients 

and warm water temperatures which favor formation of such bloom. It was considered likely that thermal 

plume from BPS was a contributing factor. Perhaps of greater importance is the finding that the MHB 

phytoplankton community does not undergo the typical winter-spring phytoplankton bloom cycle (Keller 

et al. 1999). Extensive work was conducted on plankton communities in experimental mesocosms where 

temperature was shifted to mimic the expected thermal conditions in MHB surface waters. Extrapolating 

these changes seen in the mesocosms, such changes in phytoplankton population dynamics could very 

likely lead to significant impacts within the trophic dynamics of the MHB food web. Redirecting carbon 

away from benthic consumers and into pelagic food webs could represent a reduction in prey species for 

benthic-feeding finfish such as winter flounder, windowpane flounder, hogchoker, and tautog. 

EPA judged that MHB was not a low potential impact area for zooplankton since it is an estuary that 

serves as a spawning site for numerous fish and invertebrate species (USEPA 2002b). The most 

noticeable thermal effect in this community is the recent increase in abundance of the ctenophore 

Mneimiopsis leidyi and increased overwintering in MHB for this formerly seasonal resident. Dramatic 

increases in comb jellies (i.e., ctenophores) are usually indicative of stressed ecosystems with symptoms 

of increased water temperatures, increased nutrient levels, and depleted fish stocks (Pohl 2002). Since M. 

leidyi is a voracious consumer of pelagic fish eggs as well as zooplankton by which it competes with 

young-of-year winter flounder, it was concluded that BPS was significantly contributing to thermal 

increases in MHB and facilitating expansion of the range and time of year distribution of the comb jellies. 

Eelgrass is a coldwater plant that ranges from North Carolina to Canada and grows well in soft-bottom, 

low energy environments. Despite the current lack of eelgrass, the EPA judged that MBH was not a low 

potential impact area for habitat formers since the historic presence of extensive eelgrass meadows shows 

that it is capable of supporting this habitat type (USEPA 2002b). Experimental work has shown that 

optimal temperature ranges for photosynthesis decrease with increasing turbidity (Bulthuis 1987) so that 

in turbid waters, eelgrass growth decreases with increased temperature, because photosynthetic rates 

decrease and respiration rates increase. Based on the current lack of eelgrass, it was concluded that the 

combination of poor water quality and increased water temperature result in an “exclusion zone” for 

eelgrass growth in MHB (USEPA 2002b). Since BPS helps to elevate the water temperature over 

significant portions of the bay, it is considered a contributory cause to this exclusion. 
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Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

EPA judged that MBH was not a low potential impact area for shellfish and macroinvertebrates due to the 

presence of commercially important species, their “substantial” densities, the spawning and nursery areas 

in MHB, and the important role in ecosystem function that this community provides (USEPA 2002b). 

Benthic sampling indicated that there have been no significant changes in the benthic community between 

the 1970’s and mid-1990’s or over the span of time when BPS has been active and the annual heat flux 

was increased. The sampling also indicates a strong representation in the benthic community of the 

amphipod Ampelisca which is a preferred prey item for juvenile winter flounder. Overall, EPA found no 

substantial evidence of harm to shellfish and macroinvertebrates from the current thermal discharge, and 

any alternative which reduces the thermal discharge would be acceptable. 

EPA judged that MHB was not a low potential impact area for finfish due to the presence of numerous 

recreational and commercially important species, the important spawning and nursery areas, and the 

potential for blockage of fish migration (USEPA 2002b). The analysis for finfish was specifically targeted 

at determining the appropriate thermal discharge limits for BPS in order to protect finfish populations and 

included a retrospective examination of total finfish abundance trends in relation to plant operations. The 

analysis determined an acceptable annual flux of heat into MHB that is protective of finfish populations, 

based on the temperature thresholds for acute and chronic mortality as well as for several sub-lethal 

effects for some representative important species (RIS). 

The finfish stocks in MHB have declined precipitously since 1984-1985, a period which marked the shift 

of Unit 4 at BPS from closed-cycle to once-through cooling operations. Further, work by Gibson (2002) 

suggests that winter flounder have been declining since at least the initiation of sampling in 1972. While 

BPS had been operational for 9 years at that point, no fishery data are available to estimate what the 

finfish community was like prior to 1972. Comparison of the record of annual heat flux to MHB over that 

last 28 year period to records of finfish abundance led EPA to conclude that an annual heat flux of 28 

trillion British thermal units (tBTU) to MHB, as proposed in the 316(a) variance request application, 

would be unable to stop or reverse a decline in fish populations and thus would not be protective of the 

finfish community. 

The temperature tolerance limits of 16 RIS were reviewed to establish temperature thresholds for the 

more sensitive of these species (winter flounder, striped bass). These thresholds were used to establish 

critical temperatures for three target depth strata (surface, middle, and bottom waters) at two key seasonal 

periods (winter, summer). Winter corresponds to the period (March 1 -31) of active winter flounder 

spawning and when large numbers of larval planktonic winter flounder are present in MHB. The summer 

index period (July 15 – August 15) corresponds to the warmest time of the year. 

Predictive hydrothermal models (CORMIX for near-field effects; WQMAP for far-field effects) of MHB 

provided a means of evaluating the potential thermal impacts caused by the current (i.e., existing permit), 

the proposed (i.e., the requested 316(a) variance), and two alternative reduced heat flux options for BPS 

operations, as well as a “no-plant” condition. During warm summer conditions, the proposed operational 

heat flux would impact 62% of the bottom water strata as compared to 4% under a no-plant scenario, 

while other alternative operating options would have reduced impact proportional to their proposed total 

heat fluxes. Using this method, it is possible to show impacts to all target depth strata during summer 

conditions and impacts to the bottom strata during winter. 

The study also considered other heat effects on finfish caused by the thermal discharge. The first involved 

the attractive nuisance nature of the thermal plume (USEPA 2002b). The plume acts as an attractant for 

large numbers of striped bass and bluefish in the fall and winter and disrupts their seasonal migration. The 

crowding of large numbers of these species into a restricted area increases the potential for weakening or 
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Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

diseases to occur since the warm temperatures increase their metabolism at the same time there is reduced 

feeding due to a lack of prey. Similarly, the trapping of Atlantic menhaden in the thermal plume affects 

their migration and likely increases I&E losses due to longer periods spent in proximity to intake 

structures and which has been evidenced by several recent large winter impingement loss events. Another 

effect noted was the establishment in MHB of smallmouth flounder (Etropus microstomus) which is at the 

northern limit of its geographic distribution range. It is important to note that an increased abundance or 

distribution shift to a warm water species is not indicative of protection of a BIP. 

EPA judged that MBH is a low potential impact area for other vertebrate life since it is not a significant 

habitat for marine mammals or sea turtles (USEPA 2002b). Overall, there is no potential for harm from 

the current thermal discharge and any alternative which reduces the thermal discharge would be 

acceptable. 

A summary of current ecosystem thermal effects and predicted impacts associated with the proposed 

thermal flux was prepared (USEPA 2002b). The current thermal effects for which there appears to be no 

disagreement include: 

 Appearance of nuisance algal blooms; 

 Absence of normal winter-spring phytoplankton bloom; 

 Overwintering of the ctenophore Mneimiopsis leidyi; 

 Overwintering of striped bass and bluefish in discharge canal; 

 Increased abundance of smallmouth flounder in MHB; 

 Thermal avoidance of most of MHB by adult winter flounder; and 

 Multiple fish kills as a result of large impingement events in the winter. 

Evaluating the proposed 316(a) variance request, EPA predicted that, under the proposed thermal 

discharge under the 316(a) variance request, the following would occur: 

 Large areas of MHB would be avoided by juvenile winter flounder and striped bass during warm 

summer months; 

 Extensive areas of MHB would experience water temperatures resulting in chronic toxicity to 

juvenile winter flounder; 

 Reduced winter flounder egg hatching success for the entire MHB for the warmest winter 

months; 

 Increased predation on winter flounder eggs and larvae by sand shrimp; and 

 Potential exclusion of eelgrass. 

EPA also considered potential impacts from other stressors that could be responsible for mortality of 

finfish in MHB; including overfishing, predators, water quality, brown tides, and I&E (USEPA 2002b). 

Each of these stressors was examined for its potential role in causing or contributing to the finfish 

collapse. Analyses of these other potential stressors indicated that while possibly contributory, the adverse 

effects of each were generally exacerbated by the thermal conditions caused by the BPS plume. 

Based on the hydrothermal and ecological analyses conducted and documented in the Determinations

document, EPA concluded that a BIP has not been maintained in MHB and that the current BPS thermal 

discharge is a significant contributor to this problem (USEPA 2002b). Further, the proposed thermal 

reductions in annual heat flux contained in the 316(a) variance request application would not allow for the 

recovery of the winter flounder or the wider balanced indigenous ecosystem. Accordingly, EPA denied 

the permitee’s variance request and reissued the NPDES permit in 2003 with the provision for installing 

closed-cycle cooling in all four of the power units. 
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Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

B.5.2 Quad Cities Nuclear Station (QCNS) 

Quad Cities Nuclear Station (QCNS) is a dual-unit nuclear fueled steam electric generating facility (SIC 

4911) located on a 765-acre site along the Mississippi River in Cordova, Illinois. QCNS Units I (866 net 

megawatts (MW)) and 2 (871 net MW) began commercial production of electricity in 1973. QCNS 

withdraws water from the Mississippi River for non-contact condenser cooling and various service water 

uses. After passing through the condensers, the cooling water from Units 1 and 2 mixes and then exits to 

the River via a discharge canal. QCNS is located on Pool 14 of the Mississippi River, at approximate 

River Mile 506.5 above the confluence of the Ohio River. 

The thermal discharge is authorized under the Station’s NPDES Permit, issued by the ILEPA. Thermal 

limits in the NPDES Permit are based on Illinois environmental regulations, and studies and 

Demonstrations related to the thermal plume are performed under CWA Section 316(a). During the latest 

NDPES permit renewal cycle, QCNS requested issuance of a 316(a) variance for a proposed alternative 

thermal standard, specifically relaxation of a maximum thermal excursion temperature limits by 2o

F 

during late summer months (July-September), which would increase the predicted frequency of expected 

thermal excursions from 1% to 3%. This variance request was based on a demonstration that future 

operations of QCNS would assure the protection and propagation of a balanced indigenous community 

(BIC) of fish, wildlife, and shellfish, particularly within Pool 14. 

To evaluate the potential thermal impacts of QCNS’ discharge on Pool 14, a number of comprehensive 

studies were conducted (including thermal plume modeling and field surveys, review of current 

(“prospective analysis”) and historic (“retrospective demonstration”) biota monitoring, and water quality 

assessment. The thermal plume modeling is contained in “River temperature predictions downstream 

of Quad Cities Nuclear Generating Station” (Holly Jr. et al. 2004). The elements and findings of the 

biological and water quality assessments are contained in the “Quad Cities Nuclear Station Adjusted 

Thermal Standard CWA 316(a) Demonstration. Final Draft” (HDR 2009) dated November 2009 

(hereafter “Demonstration”) and summarized below. 

The thermal plume model study was able to successfully reproduce temperature field data (collected 

September 2003) without any adjustment of non-physical parameters (Holly Jr. et al. 2004). The model 

was used to show compliance of the thermal plume with the proposed alternative standard. The model 

validation revealed the importance of including site-specific river-entraining structures such as wing dams 

and chute closure dams in the model, as they have an important influence on the thermal flow patterns in 

the vicinity of the QCNS and local Steamboat Island (Holly Jr. et al. 2004). 

Current and past monitoring efforts have collected data on a variety of aquatic communities, including 

phytoplankton, zooplankton, benthic macroinvertebrates (including freshwater mussels), ichthyoplankton, 

and finfish, which are summarized in the Demonstration (HDR 2009). For the prospective assessment, 

QCNS conducted comprehensive literature surveys, analyzed field data, and followed EPA approved 

protocols for assessing potential thermal impacts on Representative Important Species (RIS) of fish. RIS 

species selected for the QCNS Demonstration included largemouth bass, channel catfish, spotfin shiner, 

and walleye. River and plant operating conditions were selected to provide a conservative assessment of 

potential power plant-related biological effects (i.e., the biothermal assessment focused on the months of 

June, July, August, and September). The results indicate that the proposed alternative thermal standard 

would have a negligible impact on largemouth bass, channel catfish, and a slightly positive one for spotfin 

shiner (i.e., increased growth) (HDR 2009). Walleye chronic mortality could be increased by 8.5% 
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Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

immediately downstream of the mixing zone, but placed in the areal relationship of the discharge to Pool 

14, this would translate to a <1% effect on the walleye population in the Pool (HDR 2009). 

The retrospective assessment indicated some changes in the upper trophic levels (i.e., finfish) in Pool 14 

since the Station began operating, but concluded that those changes are not attributable to the thermal 

input from QCNS (HDR 2009). In addition, the overall stability and health of upper trophic levels over 

the length of the monitoring period suggests that lower trophic levels (i.e., zooplankton, phytoplankton) 

have remained stable and abundant, providing an adequate food supply to allow and sustain growth of the 

finfish and mussel populations. The retrospective assessment also found that neither nuisance species 

(e.g., zebra mussel) nor heat tolerant species of fish have come to predominate in Pool 14 due to QCNS 

operations (HDR 2009). 

In addition, the Demonstration examined the potential for harmful interactions between the QCNS 

thermal discharge and other pollutants, including dissolved organic carbon, total phosphorus, total 

nitrogen, biocides (i.e., anti-fouling chemicals), heavy metals, and other thermal discharges located 

upstream. This analysis indicated that there was no evidence to suggest that the small amount of 

additional heat that would be permitted to be discharged to Pool 14 under the proposed alternative 

standard would have an adverse synergistic effect with other pollutants (HDR 2009). 

QCNS, based on their interpretation of EPA guidance documents and 316(a) Demonstrations for other 

facilities, maintained that the overall standard of compliance (i.e., protection of the BIC) would be 

demonstrated by meeting a series of functional criteria. Because this is a request for a change in the 

thermal standard, the Demonstration needed to show that these conditions will be satisfied in the future if 

the proposed standard was adopted: 

 No substantial increase in abundance or distribution of any nuisance species or heat tolerant 

community; 

 No substantial decreases in formerly abundant indigenous species or community structure to 

resemble a simpler successional stage than is natural for the locality and season, other than 

nuisance species; 

 No unaesthetic appearance, odor, or taste of the water; 

 No elimination of an established or potential economic or recreational use of the waters; 

 No reduction in the successful completion of life cycles of indigenous species, including those of 

migratory species; 

 No substantial reduction of community heterogeneity or trophic structure; 

 No adverse impact on threatened or endangered species; 

 No destruction of unique or rare habitat, without a detailed and convincing justification of why 

the destruction should not constitute a basis of denial; and 

 No detrimental interaction with other pollutants, discharges, or water-use activities. 

Based on the results of the thermal plume modeling study, the prospective analysis, the retrospective 

assessment, and the successful meeting of the criteria listed above, QCNS concluded that past or future 

operations have not caused appreciable harm to the BIC. 

B.5.3 Point Beach Nuclear Station 

Point Beach Nuclear Plant (PBNP) is located on the western shore of Lake Michigan in Two Rivers, 

Manitowoc County, WI. The facility consists of two nuclear powered steam electric generating units with 

a total net capacity of 1,540 megawatts thermal (MWt) each. Generation Unit 1 began commercial 
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Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

operation in December 1970 and Unit 2 in October 1972 (EA 2008). The units operate with a oncethrough cooling water system (EA 2008). Cooling water is withdrawn from a deep intake (22 ft contour) 

in Lake Michigan and current pumping capacity is estimated to be 680,000 gallons per minute. Each unit 

discharges the non-contact cooling water to Lake Michigan via its own outfall located at a mean 

temperature increase of 11.5°C (20.7°F) above the intake water temperature at the maximum flow rate 

(EA 2008). 

PBNP planned to implement an extended power uprate (EPU) at both units in the 2010/2011 time frame 

that was expected to increase the existing plant output by approximately 17 percent. The proposed EPU 

does not result in an increase in water being withdrawn from Lake Michigan, nor will it result in an 

increase in the amount of water discharged to Lake Michigan (NRC 2010). However, EPU did require 

modification of the facility’s Wisconsin Discharge Elimination System (WPDES) permit for the discharge 

of a pollutant from a point source into waters of the state (which includes the addition of heat from a 

point source). According to a modeling study performed by PBNP in 2008, the temperature of the 

discharge water was expected to increase by a maximum of 3.6 °F (2.0 °C) and the thermal plume expand 

as a result of the proposed EPU (NRC 2010). 

In support of the permit modification request, PBNP prepared an assessment of the potential impacts of 

the thermal discharge from the planned EPU (i.e., the “Planned Change”). This assessment is summarized 

in “Point Beach Nuclear Plant Evaluation of the Thermal Effects Due to a Planned Extended Power 

Uprate” (EA 2008). Since there currently are no temperature limits in the PBNP WPDES permit or 

thermal water quality standards for Lake Michigan, this assessment represented a “good faith effort” by 

PBNP to demonstrate that the impacts of the EPU would not have a significant effect on the fish or 

shellfish communities in Lake Michigan (EA 2008). 

Evaluation of the potential effects on the Lake Michigan aquatic community in the vicinity of the PBNP 

post-EPU discharge was based on a review of historical and current monitoring data collected in the 

vicinity of the facility and other power plants that utilize Lake Michigan water for once-through cooling 

(EA 2008). Those study results were compared to expected responses of 16 Wisconsin Department of 

Natural Resource (WDNR) selected Representative Important Species (RIS) to the projected higher 

discharge temperatures and larger thermal plume that will result from the planned EPU. The evaluation 

placed emphasis on the RIS and whether or not the BIC in the vicinity of the PBNP discharge would 

continue to be protected. 

The assessment relied heavily on the findings of the Type I CWA Section 316(a) Demonstration 

conducted by the plant in the 1970s as well as the 1976 finding by WDNR that no appreciable harm had 

occurred to the local BIC due to plant operations (EA 2008). The studies involved investigations of 

primary and secondary trophic levels from phytoplankton through fish in both reference and thermally 

affected areas (EA Engineering 2008; Limnetics 1974, as cited in EA 2008). 

Recent entrainment and impingement monitoring studies at PBNP indicate that the same species that were 

common in the vicinity of the facility during the Type I Demonstration remain common near the plant 

despite lake-wide changes in the Lake Michigan fish community (Kitchell 2007, as cited in EA 2008). 

Recent fisheries data collected from both PBNP and the Kewaunee Nuclear Power Plant (KNPP), which 

is located only five miles north of PBNP, show that the same species seasonally occur in nearshore areas 

in the vicinity of the shoreline discharge structures. These findings indicate that the BIC is protected 

under similar operating conditions as have occurred historically at PBNP. 

Evaluation of the modeled discharge temperatures and plume configurations under the planned EPU 

indicates that the predicted area, volume, and behavior of the plume will not be substantially different 
March 28, 2011 B-13 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

than under current PBNP operating conditions and similar to those evaluated during the Type 1 

Demonstration (EA 2008). Based on the thermal model results using a 0.2 ft/sec along-shore current, the 

planned EPU would expand the surface area of the 6.0oC contour from 27 to 39 acres; the 4.0oC contour 

would increase from 79 to 105 acres; and the 2.0oC contour would increase from 315 to 390 acres (EA 

2008). These projected increases in plume size are relatively small compared to the surface area available 

for mixing. Under critical summer conditions the buoyant plume provides an area of safety as well as a 

zone of passage when discharge temperatures approach or exceed upper avoidance temperatures of the 

RIS fish. 

The RIS evaluation showed that the predicted impact of the warmer and larger thermal plume as a result 

of the EPU at PBNP will be negligible (EA 2008). Thermal criteria for some of the 12 RIS fish species 

would be exceeded in the plume, but mainly at the point of discharge or in small areas for relatively brief 

periods of time. Fish readily move into and out of thermal discharge plumes, depending on their thermal 

requirements and the thermal regime of the plume at any given time. Cool and coldwater fish species 

would be somewhat restricted with regard to use of the plume area, especially during summer, but they 

generally spend the summer well offshore. In addition, the warmwater RIS could slightly benefit from the 

warmer temperatures. Combining these observations with the size of the PBNP plume relative to 

available lake habitat, it was concluded that the larger and warmer thermal plume resulting from the 

planned EPU would have a minimal and insignificant impact on the fish community in Lake Michigan 

(EA 2008). Similar conclusions were reached for the four invertebrate RIS (shellfish and opossum 

shrimp). 

Overall, the assessment concluded that the increased heat load to the discharge would not endanger the 

protection and propagation of a BIC of shellfish, fish, and wildlife in and on Lake Michigan. This 

conclusion was based on several lines of evidence including: 

 The PBNP Type I Demonstration established that the original thermal plume did not cause “prior 

appreciable harm;” 

 The PBNP thermal plumes resulting from the planned EPU will not be substantially larger than 

the original/existing plumes; 

 There have been no changes in the aquatic community attributable to operation of the facility that 

would preclude reliance on the results of the Type I Demonstration for PBNP; 

 The changes to the Lake Michigan fish community that have occurred during the past 50 years 

have occurred on a lake-wide basis; 

 The impacts on RIS will be negligible; and 

 The conclusion with respect to the effect of the planned EPU is consistent with assessments 

undertaken at other power plants on Lake Michigan. 

While the cooling water thermal plume of PBNP was expected to be larger as a result of the proposed 

EPU, it was not expected to disrupt the local BIC or have a signficant impact on RIS of Lake Michigan 

(EA 2008). Recently, as part of the plant’s operating license renewal, the Nuclear Regulatory 

Commission developed a draft Environmental Assessment (EA) for the power uprate. The draft EA was 

issued in December 2010 with a finding of no significant impact (NRC 2010). 
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

C: 

Appendix C: Details of Regional I&E Mortality LossesCC.1 California Table C-1: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the California per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality 

Species B 1 2 3 4 B 1 2 3 4 B 1 

All forage species 0.20 0.18 0.20 0.20 0.17 17.35 <0.01 14.79 15.47 <0.01 17.56 0.18 All harvested species 0.59 0.52 0.58 0.59 0.50 18.69 <0.01 15.93 16.66 <0.01 19.28 0.52 

American shad <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Cabezon <0.01 <0.01 <0.01 <0.01 <0.01 0.06 <0.01 0.05 0.05 <0.01 0.06 <0.01 California halibut <0.01 <0.01 <0.01 <0.01 <0.01 0.23 <0.01 0.20 0.21 <0.01 0.23 <0.01 California scorpionfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Crabs (other) 0.02 0.02 0.02 0.02 0.02 7.80 <0.01 6.65 6.95 <0.01 7.82 0.02 Sea Basses <0.01 <0.01 <0.01 <0.01 <0.01 2.83 <0.01 2.41 2.52 <0.01 2.83 <0.01 Shrimp (other) <0.01 <0.01 <0.01 <0.01 <0.01 0.63 <0.01 0.53 0.56 <0.01 0.63 <0.01 Drums and croakers 0.05 0.04 0.05 0.05 0.04 0.23 <0.01 0.19 0.20 <0.01 0.27 0.04 Dungeness crab <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Flounders 0.01 <0.01 0.01 0.01 <0.01 0.10 <0.01 0.08 0.09 <0.01 0.11 <0.01 Fish (other) <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 Northern anchovy 0.34 0.30 0.34 0.34 0.29 0.03 <0.01 0.03 0.03 <0.01 0.38 0.30 Rockfishes 0.02 0.01 0.02 0.02 0.01 6.33 <0.01 5.39 5.64 <0.01 6.34 0.01 Salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Sculpins 0.01 0.01 0.01 0.01 0.01 0.43 <0.01 0.36 0.38 <0.01 0.44 0.01 Smelts <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Striped bass <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 0.01 0.01 <0.01 0.01 <0.01 Sunfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Surfperches 0.11 0.10 0.11 0.11 0.10 <0.01 <0.01 <0.01 <0.01 <0.01 0.11 0.10 

Total (all species) 0.79 0.69 0.78 0.79 0.68 36.04 <0.01 30.72 32.13 <0.01 36.83 0.69 

Scenarios: B = Baseline I&E Mortality losses, 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality EveryFacilities > 50 MGD)

Impingement Entrainment 
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table C-2: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Californindividuals per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality 

Species B 1 2 3 4 B 1 2 3 4 B 1 

American shad <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Blennies <0.01 <0.01 <0.01 <0.01 <0.01 914.88 <0.01 389.87 407.84 <0.01 914.88 <0.01 

 

Bluegill <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Brown bullhead <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Cabezon <0.01 <0.01 <0.01 <0.01 <0.01 6.65 <0.01 2.83 2.96 <0.01 6.65 <0.01 

 

California halibut <0.01 <0.01 <0.01 <0.01 <0.01 7.71 <0.01 3.29 3.44 <0.01 7.72 <0.01 

 

California scorpionfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Chinook salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Crabs (other) 0.02 0.05 0.03 0.03 0.02 7,238.91 <0.01 3,084.81 3,227.00 <0.01 7,238.96 0.02 

 

Delta smelt <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 

Drums and croakers 0.18 0.41 0.20 0.21 0.18 915.22 <0.01 390.01 407.99 <0.01 915.63 0.18 

 

Dungeness crab <0.01 <0.01 <0.01 <0.01 <0.01 0.09 <0.01 0.04 0.04 <0.01 0.09 <0.01 

 

Fish (other) 0.04 0.09 0.04 0.04 0.04 1,299.61 <0.01 553.82 579.35 <0.01 1,299.70 0.04 

 

Flounders <0.01 <0.01 <0.01 <0.01 319.23 0.01 <0.01 136.04 142.31 <0.01 319.24 <0.01 

 

Gobies <0.01 <0.01 <0.01 <0.01 <0.01 1,579.24 <0.01 672.98 704.00 <0.01 1,579.24 <0.01 

 

Herrings 0.02 0.06 0.03 0.03 0.02 26.23 <0.01 11.18 11.69 <0.01 26.28 0.02 

 

Longfin smelt <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Northern anchovy 0.38 0.86 0.42 0.43 0.37 826.63 <0.01 352.26 368.50 <0.01 827.49 0.38 

 

Pacific herring <0.01 <0.01 <0.01 <0.01 <0.01 36.16 <0.01 15.41 16.12 <0.01 36.17 <0.01 

 

Rockfishes 0.01 0.03 0.01 0.01 0.01 63.96 <0.01 27.26 28.51 <0.01 63.99 0.01 

 

Sacramento splittail <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 

Salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Sculpins <0.01 <0.01 <0.01 <0.01 47.94 0.02 <0.01 20.43 21.37 <0.01 47.96 <0.01 

 

Sea Basses <0.01 <0.01 <0.01 <0.01 <0.01 13.24 <0.01 5.64 5.90 <0.01 13.24 <0.01 

 

Shrimp (other) 0.01 0.03 0.02 0.02 0.01 429.24 <0.01 182.92 191.35 <0.01 429.27 0.01 

 

Silversides 0.05 0.11 0.05 0.06 0.05 121.84 <0.01 51.92 54.31 <0.01 121.95 0.05 

 

Smallmouth bass <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Smelts <0.01 <0.01 <0.01 <0.01 <0.01 3.63 <0.01 1.55 1.62 <0.01 3.63 <0.01 

 

Striped bass <0.01 <0.01 <0.01 <0.01 <0.01 11.31 <0.01 4.82 5.04 <0.01 11.31 <0.01 

 

Sunfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Surfperches 0.06 0.13 0.06 0.06 0.06 <0.01 <0.01 <0.01 <0.01 <0.01 0.13 0.06 

 

Total (all species) 0.80 1.82 0.90 0.90 0.77 13,861.76 <0.01 5,907.09 6,179.38 <0.01 13,863.58 0.80 

 

Scenarios: B = Baseline I&E Mortality losses. 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Option Values for all options reflect reductions in losses.

Impingement Entrainment I
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

C.2 North Atlantic 

Table C-3: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the No(million A1Es per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mor

Species B 1 2 3 4 B 1 2 3 4 B 1 2 

All forage species 0.55 0.38 0.54 0.55 0.38 46.46 <0.01 37.88 39.74 <0.01 47.02 0.38 38

All harvested species 0.08 0.06 0.08 0.08 0.06 12.90 <0.01 10.52 11.03 <0.01 12.98 0.06 10

American plaice <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0American shad <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Atlantic cod <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 0.01 0.01 <0.01 0.01 <0.01 0Atlantic herring <0.01 <0.01 <0.01 <0.01 <0.01 0.12 <0.01 0.10 0.11 <0.01 0.13 <0.01 0Atlantic mackerel <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 0.02 0.02 <0.01 0.02 <0.01 0Atlantic menhaden <0.01 <0.01 <0.01 <0.01 <0.01 0.04 <0.01 0.03 0.03 <0.01 0.04 <0.01 0Bluefish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Butterfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Crabs (other) 0.03 0.02 0.03 0.03 0.02 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 0.02 0Cunner <0.01 <0.01 <0.01 <0.01 <0.01 4.26 <0.01 3.47 3.64 <0.01 4.26 <0.01 3Fish (other) <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Pollock <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Red hake <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Sculpins <0.01 <0.01 <0.01 <0.01 <0.01 1.94 <0.01 1.58 1.66 <0.01 1.94 <0.01 1Scup <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Searobin <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 0Silver hake <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Skates <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Striped bass <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Tautog <0.01 <0.01 <0.01 <0.01 <0.01 0.11 <0.01 0.09 0.10 <0.01 0.11 <0.01 0Weakfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0White perch <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Windowpane <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 0.02 0.02 <0.01 0.02 <0.01 0Winter flounder 0.03 0.02 0.02 0.02 0.02 6.35 <0.01 5.18 5.43 <0.01 6.38 0.02 5

Total (all species) 0.63 0.43 0.62 0.63 0.43 59.37 <0.01 48.40 50.77 <0.01 60.00 0.43 49

Impingement Entrainment I&

Scenarios: B = Baseline I&E Mortality losses, 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E M4 = Option 4 (I for Facilities > 50 MGD)
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table C-4: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the North Atlaindividuals per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality 

Species B 1 2 3 4 B 1 2 3 4 B 1 

Alewife 0.05 0.02 0.03 0.03 0.02 5.76 <0.01 2.35 2.46 <0.01 5.81 0.02 

 

American plaice <0.01 <0.01 <0.01 <0.01 <0.01 199.21 <0.01 81.20 85.19 <0.01 199.21 <0.01 

 

American sand lance 0.16 0.06 0.08 0.08 0.06 1,469.03 <0.01 598.82 628.20 <0.01 1,469.20 0.06 

 

American shad <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Atlantic cod <0.01 <0.01 <0.01 <0.01 <0.01 117.38 <0.01 47.85 50.19 <0.01 117.38 <0.01 

 

Atlantic herring 0.01 0.03 0.01 0.01 0.01 87.31 <0.01 35.59 37.33 <0.01 87.34 0.01 

 

Atlantic mackerel <0.01 <0.01 <0.01 <0.01 <0.01 7,067.69 <0.01 2,880.99 3,022.33 <0.01 7,067.69 <0.01 2

 

Atlantic menhaden 0.02 <0.01 <0.01 <0.01 <0.01 4,206.13 <0.01 1,714.54 1,798.65 <0.01 4,206.15 <0.01 

 

Atlantic silverside 0.14 0.05 0.07 0.07 0.05 96.58 <0.01 39.37 41.30 <0.01 96.71 0.05 

 

Atlantic tomcod <0.01 <0.01 <0.01 <0.01 <0.01 6.28 <0.01 2.56 2.68 <0.01 6.28 <0.01 

 

Bay anchovy 0.01 0.03 0.02 0.02 0.01 55,820.08 <0.01 22,753.85 23,870.13 <0.01 55,820.11 0.01 22

 

Blueback herring <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Bluefish <0.01 <0.01 <0.01 <0.01 <0.01 0.06 <0.01 0.02 0.02 <0.01 0.06 <0.01 

 

Butterfish <0.01 <0.01 <0.01 <0.01 <0.01 12.15 <0.01 4.95 5.20 <0.01 12.16 <0.01 

 

Crabs (other) 0.04 0.01 0.02 0.02 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.04 0.01 

 

Cunner <0.01 <0.01 <0.01 <0.01 <0.01 29,170.94 <0.01 11,890.91 12,474.26 <0.01 29,170.95 <0.01 1

 

Fish (other) 0.06 0.02 0.03 0.03 0.02 521.45 <0.01 212.56 222.99 <0.01 521.51 0.02 

 

Fourbeard rockling <0.01 <0.01 <0.01 <0.01 <0.01 464.23 <0.01 189.23 198.52 <0.01 464.23 <0.01 

 

Grubby <0.01 0.01 0.02 0.01 <0.01 431.08 <0.01 175.72 184.34 <0.01 431.10 <0.01 

 

Hogchoker 0.04 0.01 0.02 0.02 0.01 549.17 <0.01 223.86 234.84 <0.01 549.22 0.01 

 

Lumpfish <0.01 <0.01 <0.01 <0.01 <0.01 44.89 <0.01 18.30 19.20 <0.01 44.89 <0.01 

 

Northern 

pipefish <0.01 <0.01 <0.01 <0.01 <0.01 1.15 <0.01 0.47 0.49 <0.01 1.16 <0.01 

 

Pollock <0.01 <0.01 <0.01 <0.01 <0.01 3.46 <0.01 1.41 1.48 <0.01 3.47 <0.01 

 

Radiated shanny <0.01 <0.01 <0.01 <0.01 <0.01 110.36 <0.01 44.99 47.19 <0.01 110.36 <0.01 

 

Rainbow smelt 0.05 0.02 0.03 0.03 0.02 17.65 <0.01 7.19 7.55 <0.01 17.70 0.02 

 

Red hake <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Rock gunnel <0.01 <0.01 <0.01 <0.01 <0.01 395.87 <0.01 161.37 169.29 <0.01 395.88 <0.01 

 

Sculpins <0.01 <0.01 <0.01 <0.01 <0.01 218.67 <0.01 89.13 93.51 <0.01 218.67 <0.01 

 

Scup <0.01 <0.01 <0.01 <0.01 <0.01 16.64 <0.01 6.78 7.12 <0.01 16.65 <0.01 

 

Impingement Entrainment I&
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table C-4: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the North Atlayear), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality, continued 

Species B 1 2 3 4 B 1 2 3 4 B 1 

Seaboard goby <0.01 <0.01 <0.01 <0.01 <0.01 2,379.58 <0.01 969.99 1,017.57 <0.01 2,379.58 <0.01 

 

Searobin <0.01 <0.01 <0.01 <0.01 <0.01 11.48 <0.01 4.68 4.91 <0.01 11.48 <0.01 

 

Silver hake 0.03 0.01 0.02 0.02 0.01 568.71 <0.01 231.82 243.20 <0.01 568.75 0.01 

 

Skates <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Striped bass <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Striped killifish <0.01 <0.01 <0.01 <0.01 <0.01 0.06 <0.01 0.03 0.03 <0.01 0.07 <0.01 

 

Tautog <0.01 <0.01 <0.01 <0.01 <0.01 29,299.93 <0.01 11,943.48 12,529.42 <0.01 29,299.94 <0.01 1

 

Threespine stickleback 0.03 <0.01 0.01 0.01 <0.01 0.09 <0.01 0.04 0.04 <0.01 0.11 <0.01 

 

Weakfish <0.01 <0.01 <0.01 <0.01 <0.01 342.21 <0.01 139.49 146.34 <0.01 342.21 <0.01 

 

White perch 0.01 <0.01 <0.01 <0.01 <0.01 0.28 <0.01 0.12 0.12 <0.01 0.30 <0.01 

 

Windowpane 0.01 <0.01 <0.01 <0.01 <0.01 2,066.54 <0.01 842.38 883.71 <0.01 2,066.55 <0.01 

 

Winter flounder 0.09 0.03 0.05 0.05 0.03 6,688.08 <0.01 2,726.25 2,860.00 <0.01 6,688.17 0.03 2

 

Total (all species) 0.90 0.31 0.44 0.45 0.31 142,390.18 <0.01 58,042.28 60,889.79 <0.01 142,391.08 0.31 58

 

Scenarios: B = Baseline I&E Mortality losses. 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhe50 MGD). Values for all options reflect reductions in losses.

Impingement Entrainment I&
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

C.3 Mid-Atlantic 

Table C-5: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Mid-Atper year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality 

Species B 1 2 3 4 B 1 2 3 4 B 1 2 

All forage species 18.71 14.27 18.25 18.31 14.26 732.37 <0.01 670.71 679.28 <0.01 751.07 14.27 688All harvested species 32.00 24.42 31.22 31.33 24.39 206.98 <0.01 189.56 191.98 <0.01 238.98 24.42 220

Alewife 0.04 0.03 0.04 0.04 0.03 <0.01 <0.01 <0.01 <0.01 <0.01 0.05 0.03 0American shad <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Atlantic croaker 0.31 0.24 0.30 0.31 0.24 21.59 <0.01 19.77 20.03 <0.01 21.90 0.24 20Atlantic herring <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Atlantic menhaden 21.72 16.57 21.19 21.26 16.55 3.16 <0.01 2.89 2.93 <0.01 24.88 16.57 24Black crappie <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Black drum <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Blue crab 1.44 1.10 1.40 1.41 1.10 108.17 <0.01 99.07 100.33 <0.01 109.61 1.10 100Bluefish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Bluegill <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Brown bullhead <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 0.01 0.01 <0.01 0.02 <0.01 0Bullheads <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Butterfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Channel catfish 0.02 0.01 0.02 0.02 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.01 0Crabs (other) 0.03 0.02 0.03 0.03 0.02 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 0.02 0Crappie <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Cunner <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Freshwater drum <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Menhadens <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Muskellunge <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Fish (other) 1.30 0.99 1.27 1.27 0.99 10.81 <0.01 9.90 10.02 <0.01 12.10 0.99 11Red drum <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Red hake <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Scup <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Searobin <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Silver hake <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Silver perch <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0Smallmouth bass <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0

Impingement Entrainment I&
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table C-5: I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Mid-Atlantic ReA1Es) Estimated Under Baseline and Option Scenarios for All Sources of Mortality, continued 

Species B 1 2 3 4 B 1 2 3 4 B 1 2 

Spot 2.95 2.25 2.88 2.89 2.25 35.15 <0.01 32.19 32.60 <0.01 38.10 2.25 35.Spotted seatrout <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.Striped bass <0.01 <0.01 <0.01 <0.01 <0.01 1.39 <0.01 1.27 1.29 <0.01 1.40 <0.01 1.Striped mullet <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.Summer flounder 0.02 0.02 0.02 0.02 0.02 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.02 0.Sunfish 0.02 0.01 0.02 0.02 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.01 0.Tautog <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.Weakfish 1.43 1.09 1.40 1.40 1.09 2.71 <0.01 2.48 2.51 <0.01 4.14 1.09 3.

White perch 2.66 2.03 2.59 2.60 2.03 23.88 <0.01 21.87 22.15 <0.01 26.53 2.03 24.Whitefish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.Windowpane <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.Winter flounder 0.02 0.01 0.02 0.02 0.01 0.11 <0.01 0.10 0.10 <0.01 0.12 0.01 0.

Total (all species) 50.71 38.69 49.47 49.64 38.65 939.35 <0.01 860.27 871.26 <0.01 990.06 38.69 909.

Scenarios: B = Baseline I&E Mortality losses, 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality EverywhFacilities > 50 MGD)

Impingement Entrainment I&E
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table C-6: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Mid-Atlanper year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality 

Species B 1 2 3 4 B 1 2 3 4 B 1 

Alewife 0.33 0.13 0.16 0.16 0.13 6.10 <0.01 2.80 2.83 <0.01 6.44 0.13 

 

American shad 0.06 0.02 0.03 0.03 0.02 67.07 <0.01 30.71 31.11 <0.01 67.13 0.02 

 

Atlantic croaker 2.28 0.87 1.11 1.12 0.87 689.03 <0.01 315.51 319.54 <0.01 691.31 0.87 

 

Atlantic herring <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Atlantic menhaden 70.44 26.87 34.36 34.48 26.85 122.59 <0.01 56.13 56.85 <0.01 193.03 26.87 

 

Atlantic silverside 1.40 0.53 0.68 0.69 0.53 110.15 <0.01 50.44 51.08 <0.01 111.55 0.53 

 

Atlantic tomcod 0.13 0.05 0.06 0.07 0.05 <0.01 <0.01 <0.01 <0.01 <0.01 0.13 0.05 

 

Bay anchovy 5.25 13.78 6.72 6.74 5.25 98,332.37 <0.01 45,026.92 45,602.31 <0.01 98,346.15 5.25 4

 

Black crappie <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Black drum <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Blue crab 2.87 1.09 1.40 1.40 1.09 3,396.61 <0.01 1,555.33 1,575.20 <0.01 3,399.48 1.09 

 

Blueback herring 1.27 0.48 0.62 0.62 0.48 24.27 <0.01 11.11 11.26 <0.01 25.54 0.48 

 

Bluefish 0.01 0.03 0.01 0.01 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 0.01 

 

Bluegill <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Bluntnose minnow <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Brown bullhead <0.01 <0.01 <0.01 <0.01 <0.01 0.11 <0.01 0.05 0.05 <0.01 0.12 <0.01 

 

Bullheads <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Butterfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Carp <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Chain pipefish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Channel catfish 0.02 <0.01 0.01 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 

 

Crabs (other) 0.04 0.01 0.02 0.02 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.04 0.01 

 

Crappie <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Cunner <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Darters <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Fish (other) 5.34 2.04 2.60 2.61 2.03 3,804.94 <0.01 1,742.30 1,764.57 <0.01 3,810.28 2.04 

 

Freshwater drum <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Gizzard shad 0.34 0.13 0.17 0.17 0.13 <0.01 <0.01 <0.01 <0.01 <0.01 0.34 0.13 

 

Gobies <0.01 <0.01 <0.01 <0.01 <0.01 143.88 <0.01 65.88 66.72 <0.01 143.88 <0.01 

 

Grubby <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 

Herrings <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Hogchoker 0.20 0.53 0.26 0.26 0.20 25,970.61 <0.01 11,892.08 12,044.05 <0.01 25,971.14 0.20 1

 

Impingement Entrainment I&
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table C-6: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Mid-Atlanper year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality, continued 

Species B 1 2 3 4 B 1 2 3 4 B 1 

Menhadens <0.01 <0.01 <0.01 <0.01 <0.01 0.11 <0.01 0.05 0.05 <0.01 0.11 <0.01 

 

Muskellunge <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Northern pipefish 0.03 0.01 0.02 0.02 0.01 10.64 <0.01 4.87 4.93 <0.01 10.67 0.01 

 

Rainbow smelt <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Red drum <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.02 <0.01 

Red hake 0.07 0.03 0.04 0.04 0.03 <0.01 <0.01 <0.01 <0.01 <0.01 0.07 0.03 

 

Scup <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Seaboard goby 0.02 <0.01 <0.01 <0.01 <0.01 13,691.58 <0.01 6,269.45 6,349.56 <0.01 13,691.59 <0.01 

 

Searobin <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Shiners <0.01 <0.01 <0.01 <0.01 <0.01 1.00 <0.01 0.46 0.46 <0.01 1.00 <0.01 

 

Silver hake 0.02 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 

Silver perch <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Silversides <0.01 <0.01 <0.01 <0.01 <0.01 2.84 <0.01 1.30 1.32 <0.01 2.85 <0.01 

 

Smallmouth bass <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Spot 9.17 3.50 4.47 4.49 3.49 232.64 <0.01 106.53 107.89 <0.01 241.80 3.50 

 

Spotted seatrout <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Striped bass 0.04 0.01 0.02 0.02 0.01 1,060.00 <0.01 485.38 491.58 <0.01 1,060.04 0.01 

 

Striped killifish 0.32 0.12 0.16 0.16 0.12 <0.01 <0.01 <0.01 <0.01 <0.01 0.32 0.12 

 

Striped mullet <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Suckers <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Summer flounder 0.08 0.03 0.04 0.04 0.03 <0.01 <0.01 <0.01 <0.01 <0.01 0.08 0.03 

 

Sunfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Tautog <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Threespine stickleback 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 

Weakfish 3.31 1.26 1.61 1.62 1.26 486.50 <0.01 222.77 225.62 <0.01 489.81 1.26 

 

White perch 1.07 2.81 1.37 1.37 1.07 2,335.12 <0.01 1,069.26 1,082.93 <0.01 2,337.92 1.07 

 

Whitefish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Windowpane <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 Winter flounder 0.06 0.02 0.03 0.03 0.02 92.01 <0.01 42.13 42.67 <0.01 92.07 0.02 

 

Total (all species) 43.81 114.86 56.03 56.22 43.77 150,580.20 <0.01 68,951.48 69,832.59 <0.01 150,695.05 43.81 6

 

Scenarios: B = Baseline I&E Mortality losses. 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Option 4 (I for Facilreflect reductions in losses.

Impingement Entrainment I&
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

C.4 South Atlantic 

Table C-7: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Sout(million A1Es per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Morta

Species B 1 2 3 4 B 1 2 3 4 B 1 2 

All forage species 21.27 13.43 18.13 18.14 13.43 9.94 <0.01 8.29 8.31 <0.01 31.22 13.43 26.43 

All harvested species 1.22 0.77 1.04 1.04 0.77 0.96 <0.01 0.80 0.81 <0.01 2.19 0.77 1.85 

Atlantic menhaden 0.25 0.16 0.21 0.21 0.16 0.03 <0.01 0.02 0.03 <0.01 0.28 0.16 0.24 Blue crab 0.45 0.29 0.39 0.39 0.29 <0.01 <0.01 <0.01 <0.01 <0.01 0.45 0.29 0.39 Crabs (other) <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 0.02 0.02 <0.01 0.02 <0.01 0.02 Drums and croakers 0.02 0.01 0.02 0.02 0.01 0.80 <0.01 0.67 0.67 <0.01 0.82 0.01 0.69 Flounders <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Fish (other) 0.01 <0.01 0.01 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 0.01 Pinfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Silver perch 0.28 0.18 0.24 0.24 0.18 <0.01 <0.01 <0.01 <0.01 <0.01 0.28 0.18 0.24 Spot 0.20 0.12 0.17 0.17 0.12 0.10 <0.01 0.08 0.08 <0.01 0.29 0.12 0.25 Spotted seatrout <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Stone crab <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Weakfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Total (all species) 22.50 14.20 19.18 19.19 14.20 10.91 <0.01 9.10 9.11 <0.01 33.40 14.20 28.28 

Scenarios: B = Baseline I&E Mortality losses, 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E MOption 4 (I for Facilities > 50 MGD)

Impingement Entrainment I&E
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table C-8: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the South Atlindividuals per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality 

Species B1234 B 1 2 3 4 B 1 2 

Atlantic menhaden 0.26 0.82 0.35 0.35 0.26 157.54 <0.01 65.70 65.81 <0.01 158.36 0.26 

 

Atlantic silverside 0.04 0.13 0.05 0.05 0.04 <0.01 <0.01 <0.01 <0.01 <0.01 0.13 0.04 

 

Bay anchovy 8.06 25.54 10.89 10.89 8.06 2,402.75 <0.01 1,002.00 1,003.65 <0.01 2,428.30 8.06 1,0

 

Blue crab 0.28 0.90 0.38 0.38 0.28 <0.01 <0.01 <0.01 <0.01 <0.01 0.90 0.28 

 

Crabs (other) <0.01 <0.01 <0.01 <0.01 <0.01 667.97 <0.01 278.56 279.02 <0.01 667.97 <0.01 2

 

Drums and croakers 0.07 0.22 0.09 0.09 0.07 2,376.84 <0.01 991.19 992.83 <0.01 2,377.05 0.07 9

 

Fish (other) 0.53 1.67 0.71 0.71 0.53 272.99 <0.01 113.84 114.03 <0.01 274.66 0.53 1

 

Flounders <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <Gobies <0.01 <0.01 <0.01 <0.01 <0.01 3,576.38 <0.01 1,491.43 1,493.89 <0.01 3,576.38 <0.01 1,4

 

Herrings <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.01 0.01 <0.01 <

Pinfish <0.01 <0.01 <0.01 <0.01 <0.01 71.34 <0.01 29.75 29.80 <0.01 71.34 <0.01 

 

Scaled sardine <0.01 0.01 0.03 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 <0.01 

 

Shrimp (other) 2.81 8.90 3.79 3.79 2.81 1,040.49 <0.01 433.91 434.62 <0.01 1,049.39 2.81 4

 

Silver perch 0.14 0.45 0.19 0.19 0.14 <0.01 <0.01 <0.01 <0.01 <0.01 0.45 0.14 

 

Spot 0.23 0.72 0.31 0.31 0.23 2,152.83 <0.01 897.77 899.25 <0.01 2,153.54 0.23 8

 

Spotted seatrout <0.01 <0.01 <0.01 <0.01 <0.01 35.30 <0.01 14.72 14.75 <0.01 35.30 <0.01 

 

Stone crab <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <Weakfish 0.01 0.04 0.02 0.02 0.01 100.99 <0.01 42.12 42.19 <0.01 101.04 0.01 

 

Total (all species) 12.44 39.42 16.80 16.81 12.44 12,855.43 <0.01 5,360.98 5,369.82 <0.01 12,894.86 12.44 5,3

 

Scenarios: B = Baseline I&E Mortality losses. 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Option 4 (I fooptions reflect reductions in losses.

Impingement Entrainment I&
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

C.5 Gulf of Mexico 

Table C-9: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Gulf of A1Es per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality 

Species B 1 2 3 4 B 1 2 3 4 B 1 2 

All forage species 5.63 4.31 5.59 5.60 4.28 42.12 <0.01 28.49 28.56 <0.01 47.75 4.31 34.0All harvested species 39.42 30.19 39.15 39.18 29.96 48.47 <0.01 32.79 32.87 <0.01 87.89 30.19 71.9

Atlantic croaker 1.65 1.27 1.64 1.64 1.26 <0.01 <0.01 <0.01 <0.01 <0.01 1.65 1.27 1.6Black drum 0.01 <0.01 0.01 0.01 <0.01 5.93 <0.01 4.01 4.02 <0.01 5.94 <0.01 4.0Blue crab 5.66 4.33 5.62 5.62 4.30 19.03 <0.01 12.87 12.90 <0.01 24.68 4.33 18.4Leatherjacket 0.69 0.53 0.68 0.69 0.52 0.03 <0.01 0.02 0.02 <0.01 0.72 0.53 0.7Mackerels <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.0Menhadens 4.95 3.79 4.92 4.92 3.76 0.05 <0.01 0.03 0.03 <0.01 5.00 3.79 4.9Fish (other) 1.48 1.14 1.47 1.47 1.13 0.16 <0.01 0.11 0.11 <0.01 1.64 1.14 1.5Pinfish 0.03 0.02 0.03 0.03 0.02 1.07 <0.01 0.72 0.73 <0.01 1.10 0.02 0.7Pink shrimp 21.44 16.42 21.29 21.31 16.30 13.40 <0.01 9.07 9.09 <0.01 34.84 16.42 30.3Red drum 0.08 0.06 0.08 0.08 0.06 0.01 <0.01 <0.01 <0.01 <0.01 0.10 0.06 0.0Sea basses <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.0Searobin 0.94 0.72 0.93 0.93 0.71 0.36 <0.01 0.25 0.25 <0.01 1.30 0.72 1.1Sheepshead <0.01 <0.01 <0.01 <0.01 <0.01 0.03 <0.01 0.02 0.02 <0.01 0.04 <0.01 0.0Silver perch 0.28 0.22 0.28 0.28 0.21 5.11 <0.01 3.46 3.47 <0.01 5.40 0.22 3.7Spot 0.38 0.29 0.38 0.38 0.29 0.09 <0.01 0.06 0.06 <0.01 0.47 0.29 0.4Spotted seatrout 1.26 0.96 1.25 1.25 0.96 0.15 <0.01 0.10 0.10 <0.01 1.41 0.96 1.3Stone crab 0.19 0.14 0.18 0.19 0.14 0.41 <0.01 0.28 0.28 <0.01 0.60 0.14 0.4Striped mullet 0.37 0.28 0.37 0.37 0.28 2.62 <0.01 1.77 1.78 <0.01 2.99 0.28 2.1

Total (all species) 45.05 34.50 44.74 44.78 34.24 90.59 <0.01 61.28 61.43 <0.01 135.64 34.50 106.0

Scenarios: B = Baseline I&E Mortality losses, 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E MortOption 4 (I for Facilities > 50 MGD)

Impingement Entrainment I&
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table C-10: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Gulf of Mindividuals per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality 

Species B 1234 B 1 2 3 4 B 1 2 

Atlantic croaker 5.92 15.45 7.67 7.68 5.87 162.35 <0.01 54.91 55.05 <0.01 177.81 5.92 

 

Bay anchovy 1.66 4.33 2.15 2.15 1.65 301,092.72 <0.01 101,837.44 102,087.75 <0.01 301,097.05 1.66 101,8

 

Black drum <0.01 0.01 0.02 0.01 <0.01 96,328.24 <0.01 32,580.73 32,660.81 <0.01 96,328.26 <0.01 32,5

 

Blue crab 4.31 11.26 5.59 5.60 4.28 280.96 <0.01 95.03 95.26 <0.01 292.22 4.31 1

 

Chain pipefish 0.03 0.07 0.03 0.03 0.03 2.13 <0.01 0.72 0.72 <0.01 2.19 0.03 

 

Fish (other) 2.85 7.43 3.69 3.69 2.82 9,784.29 <0.01 3,309.30 3,317.44 <0.01 9,791.72 2.85 3,3

 

Gobies 0.05 0.14 0.07 0.07 0.05 3,407.68 <0.01 1,152.57 1,155.40 <0.01 3,407.82 0.05 1,1

 

Gulf killifish 0.01 0.04 0.02 0.02 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.04 0.01 

 

Hogchoker 0.06 0.15 0.07 0.07 0.06 198.72 <0.01 67.21 67.38 <0.01 198.87 0.06 

 

Leatherjacket 0.36 0.95 0.47 0.47 0.36 794.02 <0.01 268.56 269.22 <0.01 794.97 0.36 2

 

Mackerels <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Menhadens 6.15 16.06 7.98 7.98 6.10 269.13 <0.01 91.03 91.25 <0.01 285.19 6.15 

 

Pinfish 0.05 0.12 0.06 0.06 0.04 107.79 <0.01 36.46 36.55 <0.01 107.91 0.05 

 

Pink shrimp 16.74 43.73 21.71 21.73 16.62 126.32 <0.01 42.73 42.83 <0.01 170.05 16.74 

 

Red drum 0.06 0.16 0.08 0.08 0.06 1.10 <0.01 0.37 0.37 <0.01 1.26 0.06 

 

Scaled sardine 0.12 0.32 0.16 0.16 0.12 2,962.36 <0.01 1,001.95 1,004.41 <0.01 2,962.69 0.12 1,0

 

Sea basses <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Searobin 0.45 1.18 0.58 0.58 0.45 68.82 <0.01 23.28 23.33 <0.01 70.00 0.45 

 

Sheepshead <0.01 <0.01 <0.01 <0.01 <0.01 382.88 <0.01 129.50 129.82 <0.01 382.88 <0.01 1

 

Silver perch 0.17 0.45 0.23 0.23 0.17 88,985.72 <0.01 30,097.30 30,171.28 <0.01 88,986.17 0.17 30,0

 

Spot 0.53 1.39 0.69 0.69 0.53 34.75 <0.01 11.75 11.78 <0.01 36.14 0.53 

 

Spotted seatrout 0.46 1.20 0.60 0.60 0.46 5,338.00 <0.01 1,805.45 1,809.89 <0.01 5,339.20 0.46 1,8

 

Stone crab 0.10 0.27 0.14 0.14 0.10 28,711.01 <0.01 9,710.82 9,734.68 <0.01 28,711.29 0.10 9,7

 

Striped mullet 0.17 0.45 0.22 0.23 0.17 15.17 <0.01 5.13 5.14 <0.01 15.62 0.17 

 

Tidewater silverside 0.11 0.30 0.15 0.15 0.11 34.36 <0.01 11.62 11.65 <0.01 34.66 0.11 

 

Total (all species) 40.39 105.48 52.38 52.42 40.09 539,088.54 <0.01 182,333.86 182,782.02 <0.01 539,194.01 40.39 182,3

 

Scenarios: B = Baseline I&E Mortality losses. 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Option 4 (I for Facilities reflect reductions in losses.

Impingement Entrainment I&
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

C.6 Great Lakes 

Table C-11: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the G(million A1Es per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mor

Species B 1 2 3 4 B 1 2 3 4 B 1 2 

All forage species 38.62 33.46 38.20 38.29 33.17 7.84 <0.01 6.26 6.36 <0.01 46.46 33.46 44.46 

All harvested species 5.51 4.77 5.45 5.46 4.73 1.53 <0.01 1.22 1.24 <0.01 7.04 4.77 6.67 

Black bullhead <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Black crappie <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Bluegill <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Brown bullhead <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Bullheads <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Channel catfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Crappie <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 0.01 0.01 <0.01 0.02 <0.01 0.02 Freshwater drum 0.02 0.02 0.02 0.02 0.02 0.05 <0.01 0.04 0.04 <0.01 0.07 0.02 0.06 Muskellunge <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Fish (other) 0.06 0.05 0.06 0.06 0.05 <0.01 <0.01 <0.01 <0.01 <0.01 0.06 0.05 0.06 Rainbow smelt 0.37 0.32 0.36 0.36 0.32 0.07 <0.01 0.05 0.05 <0.01 0.44 0.32 0.42 Salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Sculpins <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 0.02 0.02 <0.01 0.03 <0.01 0.02 Smallmouth bass <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Smelts 4.49 3.89 4.45 4.46 3.86 0.02 <0.01 0.02 0.02 <0.01 4.52 3.89 4.46 Sunfish 0.02 0.02 0.02 0.02 0.02 1.18 <0.01 0.95 0.96 <0.01 1.20 0.02 0.96 Walleye <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 White bass 0.05 0.04 0.05 0.05 0.04 0.09 <0.01 0.08 0.08 <0.01 0.14 0.04 0.12 Whitefish 0.23 0.20 0.22 0.23 0.20 <0.01 <0.01 <0.01 <0.01 <0.01 0.23 0.20 0.22 Yellow perch 0.26 0.23 0.26 0.26 0.22 0.07 <0.01 0.05 0.05 <0.01 0.33 0.23 0.31 

Total (all species) 44.13 38.23 43.65 43.75 37.91 9.37 <0.01 7.48 7.60 <0.01 53.50 38.23 51.13 

Impingement Entrainment I&E

Scenarios: B = Baseline I&E Mortality losses, 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E M= Option 4 (I for Facilities > 50 MGD)
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table C-12: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Great Laindividuals per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality 

Species B 1 2 3 4 B 1 2 3 4 B 1 

Alewife 28.95 12.54 14.32 14.35 12.44 38,098.88 <0.01 15,213.50 15,443.27 <0.01 38,127.84 12.54 15

 

Black bullhead <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Black crappie <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Blueback herring <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Bluegill <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Bluntnose minnow 0.01 <0.01 <0.01 <0.01 <0.01 13.01 <0.01 5.20 5.27 <0.01 13.02 <0.01 

 

Brown bullhead <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Bullheads <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Burbot <0.01 <0.01 <0.01 <0.01 <0.01 0.53 <0.01 0.21 0.21 <0.01 0.53 <0.01 

 

Carp 0.04 0.02 0.02 0.02 0.02 3,239.89 <0.01 1,293.74 1,313.28 <0.01 3,239.94 0.02 1

 

Channel catfish <0.01 <0.01 <0.01 <0.01 <0.01 0.20 <0.01 0.08 0.08 <0.01 0.20 <0.01 

 

Chinook salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Crappie <0.01 <0.01 <0.01 <0.01 <0.01 0.90 <0.01 0.36 0.36 <0.01 0.90 <0.01 

 

Darters 0.01 <0.01 <0.01 <0.01 <0.01 2.87 <0.01 1.15 1.16 <0.01 2.88 <0.01 

 

Emerald shiner 0.17 0.40 0.20 0.20 0.17 47.50 <0.01 18.97 19.25 <0.01 47.90 0.17 

 

Fish (other) 0.19 0.08 0.09 0.10 0.08 40,037.77 <0.01 15,987.73 16,229.19 <0.01 40,037.96 0.08 15

 

Freshwater drum 0.07 0.03 0.03 0.03 0.03 221.20 <0.01 88.33 89.66 <0.01 221.27 0.03 

 

Gizzard shad 14.94 6.47 7.39 7.40 6.42 3,846.52 <0.01 1,535.98 1,559.17 <0.01 3,861.45 6.47 1

 

Golden redhorse <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Herrings <0.01 <0.01 <0.01 <0.01 <0.01 11.15 <0.01 4.45 4.52 <0.01 11.15 <0.01 

 

Logperch 0.22 0.10 0.11 0.11 0.09 10.26 <0.01 4.10 4.16 <0.01 10.48 0.10 

 

Muskellunge <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Rainbow smelt 0.51 0.22 0.25 0.25 0.22 74.33 <0.01 29.68 30.13 <0.01 74.84 0.22 

 

Salmon <0.01 <0.01 <0.01 <0.01 <0.01 6.16 <0.01 2.46 2.50 <0.01 6.16 <0.01 

 

Sculpins <0.01 <0.01 <0.01 <0.01 <0.01 3.50 <0.01 1.40 1.42 <0.01 3.50 <0.01 

 

Shiners 0.57 0.25 0.28 0.28 0.24 132.24 <0.01 52.80 53.60 <0.01 132.81 0.25 

 

Smallmouth bass <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Smelts 4.07 1.76 2.01 2.02 1.75 150.69 <0.01 60.17 61.08 <0.01 154.75 1.76 

 

Spotted sucker <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Impingement Entrainment I&
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table C-12: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Great Laindividuals per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality, co

Species B 1 2 3 4 B 1 2 3 4 B 1 

Suckers <0.01 <0.01 <0.01 <0.01 <0.01 2.31 <0.01 0.92 0.94 <0.01 2.32 <0.01 

 

Sunfish <0.01 <0.01 <0.01 <0.01 <0.01 7.03 <0.01 2.81 2.85 <0.01 7.03 <0.01 

 

Threespine stickleback 0.03 0.07 0.04 0.04 0.03 0.69 <0.01 0.28 0.28 <0.01 0.76 0.03 

 

Walleye <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 White bass 0.05 0.02 0.03 0.03 0.02 38.35 <0.01 15.31 15.54 <0.01 38.40 0.02 

 

White perch <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Whitefish 0.10 0.04 0.05 0.05 0.04 0.17 <0.01 0.07 0.07 <0.01 0.27 0.04 

 

Yellow perch 0.71 0.31 0.35 0.35 0.31 30.26 <0.01 12.08 12.27 <0.01 30.98 0.31 

 

Total (all species) 50.99 22.09 25.22 25.28 21.90 85,976.38 <0.01 34,331.75 34,850.27 <0.01 86,027.37 22.09 34

 

Scenarios: B = Baseline I&E Mortality losses. 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Option for all options reflect reductions in losses.

Impingement Entrainment I&
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

C.7 Inland 

Table C-13: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Inland A1Es per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality 

Species B 1 2 3 4 B 1 2 3 4 B 1 2 

All forage species 549.42 459.64 531.05 536.22 448.42 164.29 <0.01 134.24 140.41 <0.01 713.71 459.64 66All harvested species 34.17 28.59 33.03 33.35 27.89 131.61 <0.01 107.54 112.48 <0.01 165.78 28.59 14

American shad 0.05 0.04 0.05 0.05 0.04 <0.01 <0.01 <0.01 <0.01 <0.01 0.05 0.04 Black bullhead 0.18 0.15 0.18 0.18 0.15 <0.01 <0.01 <0.01 <0.01 <0.01 0.19 0.15 Black crappie 0.07 0.06 0.06 0.06 0.05 0.50 <0.01 0.41 0.43 <0.01 0.57 0.06 Bluegill 2.11 1.76 2.04 2.06 1.72 0.18 <0.01 0.15 0.15 <0.01 2.29 1.76 Brown bullhead 0.03 0.02 0.03 0.03 0.02 0.04 <0.01 0.04 0.04 <0.01 0.07 0.02 Bullheads 0.02 0.02 0.02 0.02 0.02 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 0.02 Channel catfish 1.63 1.36 1.58 1.59 1.33 1.01 <0.01 0.82 0.86 <0.01 2.64 1.36 Crappie 0.11 0.09 0.11 0.11 0.09 1.40 <0.01 1.14 1.20 <0.01 1.51 0.09 Freshwater drum 1.19 1.00 1.15 1.16 0.97 6.31 <0.01 5.16 5.40 <0.01 7.51 1.00 Menhadens <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <Muskellunge <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <Fish (other) <0.01 <0.01 <0.01 <0.01 <0.01 0.06 <0.01 0.05 0.05 <0.01 0.07 <0.01 Rainbow smelt 0.14 0.12 0.13 0.14 0.11 0.21 <0.01 0.17 0.18 <0.01 0.35 0.12 Salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <Sauger 0.10 0.08 0.09 0.09 0.08 1.75 <0.01 1.43 1.49 <0.01 1.84 0.08 Smallmouth bass 0.24 0.20 0.23 0.23 0.19 3.70 <0.01 3.03 3.16 <0.01 3.94 0.20 Smelts <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <Striped bass 0.16 0.13 0.15 0.15 0.13 <0.01 <0.01 <0.01 <0.01 <0.01 0.16 0.13 Sturgeons <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 0.02 0.02 <0.01 0.03 <0.01 Sunfish 19.92 16.66 19.25 19.44 16.25 110.06 <0.01 89.93 94.07 <0.01 129.98 16.66 10Walleye 0.06 0.05 0.05 0.05 0.05 0.68 <0.01 0.56 0.58 <0.01 0.74 0.05 White bass 2.35 1.97 2.27 2.29 1.92 2.66 <0.01 2.18 2.28 <0.01 5.01 1.97 White perch 2.58 2.16 2.49 2.52 2.10 0.55 <0.01 0.45 0.47 <0.01 3.13 2.16 Whitefish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <Yellow perch 3.24 2.71 3.13 3.16 2.64 2.44 <0.01 1.99 2.08 <0.01 5.67 2.71 

Total (all species) 583.59 488.22 564.08 569.57 476.31 295.89 <0.01 241.78 252.90 <0.01 879.49 488.22 80

Scenarios: B = Baseline I&E Mortality losses, 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality EverywhFacilities > 50 MGD)

Impingement Entrainment I
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table C-14: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Inland Rindividuals per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality 

Species B1234 B 1 2 3 4 B 1 

Alewife 17.90 42.79 20.68 20.88 17.46 1.29 <0.01 0.53 0.55 <0.01 44.07 17.90 

 

American shad 7.96 19.04 9.20 9.29 7.77 <0.01 <0.01 <0.01 <0.01 <0.01 19.04 7.96 

 

Bay anchovy 0.01 0.03 0.01 0.02 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 0.01 

 

Bigmouth buffalo 0.02 0.04 0.02 0.02 0.02 5.38 <0.01 2.20 2.30 <0.01 5.42 0.02 

 

Black bullhead 0.14 0.34 0.16 0.16 0.14 0.04 <0.01 0.02 0.02 <0.01 0.38 0.14 

 

Black crappie 0.14 0.35 0.17 0.17 0.14 24.81 <0.01 10.14 10.60 <0.01 25.16 0.14 

 

Blue crab <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Blueback herring 77.67 185.69 89.74 90.62 75.78 1,750.15 <0.01 715.03 747.92 <0.01 1,935.85 77.67 

 

Bluegill 14.88 35.57 17.19 17.36 14.51 48.04 <0.01 19.63 20.53 <0.01 83.61 14.88 

 

Bluntnose minnow 0.06 0.15 0.07 0.07 0.06 4,918.57 <0.01 2,009.49 2,101.92 <0.01 4,918.72 0.06 2,

 

Brown bullhead 0.02 0.05 0.02 0.02 0.02 0.35 <0.01 0.14 0.15 <0.01 0.40 0.02 

 

Bullheads 0.02 0.04 0.02 0.02 0.02 3.68 <0.01 1.50 1.57 <0.01 3.72 0.02 

 

Burbot <0.01 <0.01 <0.01 <0.01 <0.01 16.04 <0.01 6.55 6.85 <0.01 16.04 <0.01 

 

Carp 0.15 0.37 0.18 0.18 0.15 4,209.21 <0.01 1,719.68 1,798.78 <0.01 4,209.58 0.15 1,

 

Channel catfish 0.85 2.03 0.98 0.99 0.83 209.76 <0.01 85.70 89.64 <0.01 211.80 0.85 

 

Crappie 0.25 0.59 0.29 0.29 0.24 67.69 <0.01 27.66 28.93 <0.01 68.28 0.25 

 

Darters 0.42 0.99 0.48 0.49 0.41 161.74 <0.01 66.08 69.12 <0.01 162.74 0.42 

 

Emerald shiner 1.67 3.99 1.93 1.95 1.63 724.99 <0.01 296.20 309.82 <0.01 728.98 1.67 

 

Fish (other) 34.81 83.22 40.22 40.61 33.96 68,076.66 <0.01 27,812.84 29,092.11 <0.01 68,159.89 34.81 27,

 

Freshwater drum 1.91 4.58 2.21 2.23 1.87 3,010.39 <0.01 1,229.90 1,286.47 <0.01 3,014.97 1.91 1,

 

Gizzard shad 130.14 311.11 150.36 151.82 126.96 19,070.18 <0.01 7,791.16 8,149.52 <0.01 19,381.30 130.14 7,

 

Gobies <0.01 <0.01 <0.01 <0.01 <0.01 81.15 <0.01 33.15 34.68 <0.01 81.15 <0.01 

 

Golden redhorse 0.03 0.07 0.03 0.03 0.03 2.86 <0.01 1.17 1.22 <0.01 2.92 0.03 

 

Hogchoker 0.01 0.03 0.01 0.01 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 0.01 

 

Logperch 0.42 1.00 0.48 0.49 0.41 32.30 <0.01 13.20 13.80 <0.01 33.30 0.42 

 

Menhadens <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Muskellunge <0.01 0.01 0.02 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 <0.01 

 

Rainbow smelt 0.08 0.19 0.09 0.09 0.08 59.23 <0.01 24.20 25.31 <0.01 59.43 0.08 

 

River carpsucker 0.01 0.03 0.02 0.02 0.01 5.15 <0.01 2.10 2.20 <0.01 5.18 0.01 

 

Salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Sauger 0.09 0.23 0.11 0.11 0.09 314.24 <0.01 128.39 134.29 <0.01 314.47 0.09 

 

Impingement Entrainment I&
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table C-14: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) in the Inland Rindividuals per year), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality, co

Species B1234 B 1 2 3 4 B 1 

Shiners 1.43 3.41 1.65 1.66 1.39 296.49 <0.01 121.13 126.70 <0.01 299.90 1.43 

 

Silversides 0.02 0.04 0.02 0.02 0.02 46.52 <0.01 19.00 19.88 <0.01 46.56 0.02 

 

Skipjack herring 0.64 1.52 0.74 0.74 0.62 0.54 <0.01 0.22 0.23 <0.01 2.06 0.64 

 

Smallmouth bass 0.06 0.14 0.07 0.07 0.06 54.51 <0.01 22.27 23.30 <0.01 54.65 0.06 

 

Smelts <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Spotted sucker <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Striped bass 0.69 1.64 0.79 0.80 0.67 <0.01 <0.01 <0.01 <0.01 <0.01 1.64 0.69 

 

Striped killifish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Sturgeons <0.01 <0.01 <0.01 <0.01 <0.01 1.46 <0.01 0.59 0.62 <0.01 1.46 <0.01 

 

Suckers 0.07 0.16 0.08 0.08 0.07 4,342.48 <0.01 1,774.13 1,855.73 <0.01 4,342.64 0.07 1,

 

Sunfish 2.67 6.38 3.08 3.11 2.60 648.07 <0.01 264.77 276.95 <0.01 654.45 2.67 

 

Threespine stickleback <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Walleye 0.06 0.15 0.07 0.07 0.06 169.80 <0.01 69.37 72.56 <0.01 169.95 0.06 

 

White bass 1.10 2.63 1.27 1.28 1.07 1,067.79 <0.01 436.25 456.31 <0.01 1,070.42 1.10 

 

White perch 1.62 3.87 1.87 1.89 1.58 660.65 <0.01 269.91 282.33 <0.01 664.53 1.62 

 

Whitefish <0.01 <0.01 <0.01 <0.01 <0.01 0.75 <0.01 0.31 0.32 <0.01 0.75 <0.01 

 

Yellow Perch 3.71 8.88 4.29 4.33 3.62 1,100.04 <0.01 449.42 470.10 <0.01 1,108.92 3.71 

 

Total (all species) 301.78 721.46 348.67 352.06 294.41 111,183.92 <0.01 45,424.39 47,513.71 <0.01 111,905.38 301.78 45,

 

Scenarios: B = Baseline I&E Mortality losses. 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Option 4 (I for Facilities > 50 reductions in losses.

Impingement Entrainment I&
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

C.8 National Estimates Table C-15: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) Nationally (miland I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality 

Species B 1 2 3 4 B 1 2 3 4 B 1 

All forage species 634.40 525.66 611.97 617.31 514.11 1020.37 <0.01 900.67 918.13 <0.01 1654.78 525.66 1All harvested species 113.00 89.31 110.56 111.04 88.31 421.14 <0.01 358.35 367.07 <0.01 534.15 89.31 

Alewife 0.04 0.03 0.04 0.04 0.03 <0.01 <0.01 <0.01 <0.01 <0.01 0.05 0.03 American plaice <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 American shad 0.05 0.04 0.05 0.05 0.04 <0.01 <0.01 <0.01 <0.01 <0.01 0.06 0.04 Atlantic cod <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 0.01 0.01 <0.01 0.01 <0.01 Atlantic croaker 1.97 1.50 1.95 1.95 1.49 21.59 <0.01 19.77 20.03 <0.01 23.56 1.50 Atlantic herring <0.01 <0.01 <0.01 <0.01 <0.01 0.12 <0.01 0.10 0.11 <0.01 0.13 <0.01 Atlantic mackerel <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 0.02 0.02 <0.01 0.02 <0.01 Atlantic menhaden 21.97 16.73 21.40 21.48 16.71 3.23 <0.01 2.95 2.99 <0.01 25.20 16.73 Black bullhead 0.18 0.15 0.18 0.18 0.15 <0.01 <0.01 <0.01 <0.01 <0.01 0.19 0.15 Black crappie 0.07 0.06 0.06 0.06 0.05 0.50 <0.01 0.41 0.43 <0.01 0.57 0.06 Black drum 0.01 0.01 0.01 0.01 0.01 5.93 <0.01 4.01 4.02 <0.01 5.94 0.01 Blue crab 7.55 5.72 7.41 7.42 5.68 127.20 <0.01 111.94 113.23 <0.01 134.75 5.72 Bluefish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Bluegill 2.11 1.76 2.04 2.06 1.72 0.18 <0.01 0.15 0.15 <0.01 2.29 1.76 Brown bullhead 0.03 0.03 0.03 0.03 0.03 0.06 <0.01 0.05 0.05 <0.01 0.09 0.03 Bullheads 0.02 0.02 0.02 0.02 0.02 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 0.02 Butterfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Cabezon <0.01 <0.01 <0.01 <0.01 <0.01 0.06 <0.01 0.05 0.05 <0.01 0.06 <0.01 California halibut <0.01 <0.01 <0.01 <0.01 <0.01 0.23 <0.01 0.20 0.21 <0.01 0.23 <0.01 California scorpionfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Channel catfish 1.65 1.38 1.60 1.61 1.35 1.01 <0.01 0.82 0.86 <0.01 2.66 1.38 Crabs (other) 0.09 0.07 0.09 0.09 0.07 7.82 <0.01 6.66 6.97 <0.01 7.91 0.07 Sea Basses <0.01 <0.01 <0.01 <0.01 <0.01 2.83 <0.01 2.41 2.52 <0.01 2.83 <0.01 Shrimp (other) <0.01 <0.01 <0.01 <0.01 <0.01 0.63 <0.01 0.53 0.56 <0.01 0.63 <0.01 Crappie 0.11 0.09 0.11 0.11 0.09 1.42 <0.01 1.16 1.21 <0.01 1.53 0.09 Cunner <0.01 <0.01 <0.01 <0.01 <0.01 4.26 <0.01 3.47 3.64 <0.01 4.26 <0.01 

Impingement Entrainment 
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table C-15: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) Nationally (mand I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality, continued 

Species B 1 2 3 4 B 1 2 3 4 B 1 

Drums and croakers 0.07 0.05 0.07 0.07 0.05 1.03 <0.01 0.86 0.87 <0.01 1.10 0.05 Dungeness crab <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Flounders 0.01 0.01 0.01 0.01 0.01 0.10 <0.01 0.08 0.09 <0.01 0.11 0.01 

Freshwater drum 1.21 1.01 1.17 1.18 0.99 6.36 <0.01 5.20 5.44 <0.01 7.57 1.01 Leatherjacket 0.69 0.53 0.68 0.69 0.52 0.03 <0.01 0.02 0.02 <0.01 0.72 0.53 Mackerels <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Menhadens 4.95 3.79 4.92 4.92 3.76 0.05 <0.01 0.04 0.04 <0.01 5.01 3.79 Muskellunge <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Fish (other) 2.87 2.20 2.82 2.83 2.19 11.04 <0.01 10.06 10.19 <0.01 13.90 2.20 Northern anchovy 0.34 0.30 0.34 0.34 0.29 0.03 <0.01 0.03 0.03 <0.01 0.38 0.30 Pinfish 0.03 0.02 0.03 0.03 0.02 1.08 <0.01 0.73 0.73 <0.01 1.11 0.02 Pink shrimp 21.44 16.42 21.29 21.31 16.30 13.40 <0.01 9.07 9.09 <0.01 34.84 16.42 Pollock <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Rainbow smelt 0.51 0.44 0.50 0.50 0.43 0.28 <0.01 0.22 0.23 <0.01 0.78 0.44 Red drum 0.09 0.07 0.09 0.09 0.07 0.01 <0.01 <0.01 <0.01 <0.01 0.11 0.07 Red hake <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Rockfishes 0.02 0.01 0.02 0.02 0.01 6.33 <0.01 5.39 5.64 <0.01 6.34 0.01 Salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Sauger 0.10 0.08 0.09 0.09 0.08 1.75 <0.01 1.43 1.49 <0.01 1.84 0.08 Sculpins 0.02 0.02 0.02 0.02 0.02 2.39 <0.01 1.96 2.06 <0.01 2.41 0.02 Scup <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Sea basses <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Searobin 0.94 0.72 0.93 0.93 0.71 0.38 <0.01 0.26 0.26 <0.01 1.31 0.72 Sheepshead <0.01 <0.01 <0.01 <0.01 <0.01 0.03 <0.01 0.02 0.02 <0.01 0.04 <0.01 Silver hake <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Silver perch 0.56 0.39 0.52 0.52 0.39 5.11 <0.01 3.46 3.47 <0.01 5.68 0.39 Skates <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 

Impingement Entrainment 
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table C-15: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) Nationally (miland I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality, continued 

Species B 1 2 3 4 B 1 2 3 4 B 1 

Smallmouth bass 0.24 0.20 0.23 0.23 0.19 3.70 <0.01 3.03 3.16 <0.01 3.94 0.20 Smelts 4.50 3.90 4.45 4.46 3.87 0.02 <0.01 0.02 0.02 <0.01 4.52 3.90 Spot 3.52 2.66 3.42 3.43 2.66 35.34 <0.01 32.33 32.75 <0.01 38.86 2.66 Spotted seatrout 1.26 0.97 1.26 1.26 0.96 0.15 <0.01 0.10 0.10 <0.01 1.42 0.97 Stone crab 0.19 0.14 0.19 0.19 0.14 0.41 <0.01 0.28 0.28 <0.01 0.60 0.14 Striped bass 0.17 0.14 0.16 0.16 0.14 1.40 <0.01 1.28 1.30 <0.01 1.57 0.14 Striped mullet 0.37 0.28 0.37 0.37 0.28 2.62 <0.01 1.77 1.78 <0.01 2.99 0.28 Sturgeons <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 0.02 0.02 <0.01 0.03 <0.01 Summer flounder 0.02 0.02 0.02 0.02 0.02 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.02 Sunfish 19.95 16.69 19.29 19.47 16.29 111.25 <0.01 90.88 95.03 <0.01 131.20 16.69 Surfperches 0.11 0.10 0.11 0.11 0.10 <0.01 <0.01 <0.01 <0.01 <0.01 0.11 0.10 Tautog <0.01 <0.01 <0.01 <0.01 <0.01 0.11 <0.01 0.09 0.10 <0.01 0.11 <0.01 Walleye 0.06 0.05 0.05 0.05 0.05 0.68 <0.01 0.56 0.58 <0.01 0.74 0.05 Weakfish 1.44 1.10 1.40 1.41 1.10 2.71 <0.01 2.48 2.51 <0.01 4.14 1.10 White bass 2.40 2.01 2.32 2.34 1.96 2.76 <0.01 2.25 2.35 <0.01 5.16 2.01 White perch 5.24 4.18 5.08 5.12 4.13 24.43 <0.01 22.32 22.62 <0.01 29.67 4.18 Whitefish 0.23 0.20 0.23 0.23 0.20 <0.01 <0.01 <0.01 <0.01 <0.01 0.23 0.20 Windowpane <0.01 <0.01 <0.01 <0.01 <0.01 0.02 <0.01 0.02 0.02 <0.01 0.03 <0.01 Winter flounder 0.04 0.03 0.04 0.04 0.03 6.46 <0.01 5.28 5.53 <0.01 6.50 0.03 Yellow perch 3.50 2.93 3.39 3.42 2.86 2.50 <0.01 2.05 2.14 <0.01 6.00 2.93 Total (all species) 747.40 614.97 722.53 728.35 602.42 1441.52 <0.01 1259.02 1285.20 <0.01 2188.92 614.97 1

Impingement Entrainment 

Scenarios: B = Baseline I&E Mortality losses, 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Op
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table C-16: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) Nationally (milyear), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality 

Species B 1234 B 1 2 3 4 B 1 

Alewife 30.59 72.13 35.19 35.42 30.04 38,112.03 <0.01 15,219.17 15,449.11 <0.01 38,184.16 30.59 15

 

American plaice <0.01 <0.01 <0.01 <0.01 <0.01 199.21 <0.01 81.20 85.19 <0.01 199.21 <0.01 

 

American sand lance 0.06 0.16 0.08 0.08 0.06 1,469.03 <0.01 598.82 628.20 <0.01 1,469.20 0.06 

 

American shad 7.98 19.09 9.23 9.32 7.79 67.08 <0.01 30.72 31.11 <0.01 86.17 7.98 

 

Atlantic cod <0.01 <0.01 <0.01 <0.01 <0.01 117.38 <0.01 47.85 50.19 <0.01 117.38 <0.01 

 

Atlantic croaker 6.79 17.73 8.79 8.80 6.74 851.39 <0.01 370.43 374.59 <0.01 869.12 6.79 

 

Atlantic herring 0.01 0.04 0.02 0.02 0.01 87.31 <0.01 35.59 37.34 <0.01 87.34 0.01 

 

Atlantic mackerel <0.01 <0.01 <0.01 <0.01 <0.01 7,067.69 <0.01 2,880.99 3,022.33 <0.01 7,067.69 <0.01 2

 

Atlantic menhaden 27.14 71.28 34.72 34.84 27.11 4,486.26 <0.01 1,836.37 1,921.31 <0.01 4,557.54 27.14 1

 

Atlantic silverside 0.62 1.66 0.80 0.81 0.62 206.73 <0.01 89.81 92.38 <0.01 208.39 0.62 

 

Atlantic tomcod 0.05 0.14 0.07 0.07 0.05 6.28 <0.01 2.56 2.68 <0.01 6.42 0.05 

 

Bay anchovy 15.00 43.71 19.79 19.82 14.98 457,647.92 <0.01 170,620.21 172,563.84 <0.01 457,691.63 15.00 170

 

Bigmouth buffalo 0.02 0.04 0.02 0.02 0.02 5.38 <0.01 2.20 2.30 <0.01 5.42 0.02 

 

Black bullhead 0.14 0.34 0.16 0.17 0.14 0.04 <0.01 0.02 0.02 <0.01 0.38 0.14 

 

Black crappie 0.15 0.35 0.17 0.17 0.14 24.81 <0.01 10.14 10.60 <0.01 25.16 0.15 

 

Black drum 0.01 0.03 0.01 0.01 0.01 96,328.24 <0.01 32,580.73 32,660.81 <0.01 96,328.27 0.01 32

 

Blennies <0.01 <0.01 <0.01 <0.01 <0.01 914.88 <0.01 389.87 407.84 <0.01 914.88 <0.01 

 

Blue crab 5.69 15.03 7.37 7.38 5.66 3,677.57 <0.01 1,650.35 1,670.46 <0.01 3,692.60 5.69 1

 

Blueback herring 78.16 186.97 90.37 91.24 76.26 1,774.42 <0.01 726.14 759.17 <0.01 1,961.39 78.16 

 

Bluefish 0.01 0.03 0.01 0.01 0.01 0.06 <0.01 0.02 0.02 <0.01 0.09 0.01 

 

Bluegill 14.88 35.57 17.19 17.36 14.52 48.04 <0.01 19.63 20.53 <0.01 83.61 14.88 

 

Bluntnose minnow 0.07 0.16 0.08 0.08 0.07 4,931.58 <0.01 2,014.69 2,107.19 <0.01 4,931.75 0.07 2

 

Brown bullhead 0.02 0.06 0.03 0.03 0.02 0.46 <0.01 0.19 0.20 <0.01 0.52 0.02 

 

Bullheads 0.02 0.04 0.02 0.02 0.02 3.68 <0.01 1.50 1.57 <0.01 3.72 0.02 

 

Burbot <0.01 <0.01 <0.01 <0.01 <0.01 16.57 <0.01 6.76 7.07 <0.01 16.58 <0.01 

 

Butterfish <0.01 <0.01 <0.01 <0.01 <0.01 12.15 <0.01 4.95 5.20 <0.01 12.16 <0.01 

 

Cabezon <0.01 <0.01 <0.01 <0.01 <0.01 6.65 <0.01 2.83 2.96 <0.01 6.65 <0.01 

 

California halibut <0.01 <0.01 <0.01 <0.01 <0.01 7.71 <0.01 3.29 3.44 <0.01 7.72 <0.01 

 

Impingement Entrainment I&
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table C-16: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) Nationally (milyear), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality, continued 

Species B 1234 B 1 2 3 4 B 1 

California scorpionfish <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Carp 0.17 0.41 0.20 0.20 0.17 7,449.10 <0.01 3,013.42 3,112.06 <0.01 7,449.51 0.17 3

 

Chain pipefish 0.03 0.07 0.04 0.04 0.03 2.13 <0.01 0.72 0.72 <0.01 2.20 0.03 

 

Channel catfish 0.86 2.06 1.00 1.01 0.84 209.96 <0.01 85.78 89.72 <0.01 212.02 0.86 

 

Chinook salmon <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Crabs (other) 0.05 0.12 0.06 0.06 0.05 7,906.88 <0.01 3,363.37 3,506.02 <0.01 7,907.01 0.05 3

 

Crappie 0.25 0.60 0.29 0.29 0.24 68.59 <0.01 28.01 29.29 <0.01 69.19 0.25 

 

Cunner <0.01 <0.01 <0.01 <0.01 <0.01 29,170.94 <0.01 11,890.91 12,474.26 <0.01 29,170.95 <0.01 11

 

Darters 0.42 1.01 0.49 0.49 0.41 164.61 <0.01 67.23 70.28 <0.01 165.62 0.42 

 

Delta smelt <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 Drums and croakers 0.25 0.63 0.30 0.30 0.24 3,292.06 <0.01 1,381.20 1,400.82 <0.01 3,292.68 0.25 1

 

Dungeness crab <0.01 <0.01 <0.01 <0.01 <0.01 0.09 <0.01 0.04 0.04 <0.01 0.09 <0.01 

 

Emerald shiner 1.84 4.39 2.13 2.14 1.80 772.49 <0.01 315.16 329.07 <0.01 776.88 1.84 

 

Fish (other) 40.36 98.00 47.39 47.80 39.49 123,797.72 <0.01 49,732.40 51,319.67 <0.01 123,895.72 40.36 49

 

Flounders <0.01 <0.01 <0.01 <0.01 319.23 0.01 <0.01 136.04 142.31 <0.01 319.24 <0.01 

 

Fourbeard rockling <0.01 <0.01 <0.01 <0.01 <0.01 464.23 <0.01 189.23 198.52 <0.01 464.23 <0.01 

 

Freshwater drum 1.94 4.65 2.25 2.27 1.90 3,231.60 <0.01 1,318.23 1,376.14 <0.01 3,236.24 1.94 1

 

Gizzard shad 136.74 326.39 157.91 159.39 133.51 22,916.70 <0.01 9,327.13 9,708.69 <0.01 23,243.09 136.74 9

 

Gobies 0.05 0.14 0.07 0.07 0.05 8,788.33 <0.01 3,416.01 3,454.69 <0.01 8,788.47 0.05 3

 

Golden redhorse 0.03 0.07 0.03 0.03 0.03 2.86 <0.01 1.17 1.22 <0.01 2.92 0.03 

 

Grubby <0.01 0.01 0.02 0.01 <0.01 431.10 <0.01 175.73 184.35 <0.01 431.12 <0.01 

 

Gulf killifish 0.01 0.04 0.02 0.02 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.04 0.01 

 

Herrings 0.03 0.07 0.03 0.03 0.03 37.37 <0.01 15.63 16.21 <0.01 37.44 0.03 

 

Hogchoker 0.28 0.74 0.36 0.36 0.28 26,718.51 <0.01 12,183.16 12,346.27 <0.01 26,719.25 0.28 12

 

Leatherjacket 0.36 0.95 0.47 0.47 0.36 794.02 <0.01 268.56 269.22 <0.01 794.97 0.36 

 

Logperch 0.51 1.22 0.59 0.60 0.50 42.56 <0.01 17.29 17.96 <0.01 43.77 0.51 

 

Longfin smelt <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Lumpfish <0.01 <0.01 <0.01 <0.01 <0.01 44.89 <0.01 18.30 19.20 <0.01 44.89 <0.01 

 

Mackerels <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Menhadens 6.15 16.06 7.98 7.98 6.10 269.24 <0.01 91.08 91.30 <0.01 285.30 6.15 

 

Muskellunge <0.01 0.01 0.02 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.03 <0.01 

 

Northern anchovy 0.38 0.86 0.42 0.43 0.37 826.63 <0.01 352.26 368.50 <0.01 827.49 0.38 

 

Impingement Entrainment I&
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table C-16: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) Nationally (milyear), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality, continued 

Species B 1234 B 1 2 3 4 B 1 

Northern pipefish 0.01 0.04 0.02 0.02 0.01 11.79 <0.01 5.34 5.43 <0.01 11.83 0.01 

 

Pacific herring <0.01 <0.01 <0.01 <0.01 <0.01 36.16 <0.01 15.41 16.12 <0.01 36.17 <0.01 

 

Pinfish 0.05 0.12 0.06 0.06 0.04 179.13 <0.01 66.21 66.35 <0.01 179.25 0.05 

 

Pink shrimp 16.74 43.73 21.71 21.73 16.62 126.32 <0.01 42.73 42.83 <0.01 170.05 16.74 

 

Pollock <0.01 <0.01 <0.01 <0.01 <0.01 3.46 <0.01 1.41 1.48 <0.01 3.47 <0.01 

 

Radiated shanny <0.01 <0.01 <0.01 <0.01 <0.01 110.36 <0.01 44.99 47.19 <0.01 110.36 <0.01 

 

Rainbow smelt 0.32 0.76 0.37 0.37 0.32 151.21 <0.01 61.07 62.99 <0.01 151.97 0.32 

 

Red drum 0.07 0.18 0.09 0.09 0.07 1.10 <0.01 0.37 0.37 <0.01 1.27 0.07 

 

Red hake 0.03 0.08 0.04 0.04 0.03 <0.01 <0.01 <0.01 <0.01 <0.01 0.08 0.03 

 

River carpsucker 0.01 0.03 0.02 0.02 0.01 5.15 <0.01 2.10 2.20 <0.01 5.18 0.01 

 

Rock gunnel <0.01 <0.01 <0.01 <0.01 <0.01 395.87 <0.01 161.37 169.29 <0.01 395.88 <0.01 

 

Rockfishes 0.01 0.03 0.01 0.01 0.01 63.96 <0.01 27.26 28.51 <0.01 63.99 0.01 

 

Sacramento splittail <0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 <0.01 <0.01 <0.01 0.01 <0.01 

Salmon <0.01 <0.01 <0.01 <0.01 <0.01 6.16 <0.01 2.46 2.50 <0.01 6.16 <0.01 

 

Sauger 0.09 0.23 0.11 0.11 0.09 314.24 <0.01 128.39 134.29 <0.01 314.47 0.09 

 

Scaled sardine 0.13 0.35 0.17 0.17 0.13 2,962.36 <0.01 1,001.95 1,004.41 <0.01 2,962.72 0.13 1

 

Sculpins 0.01 0.02 0.01 0.01 <0.01 270.10 <0.01 110.96 116.30 <0.01 270.13 0.01 

 

Scup <0.01 <0.01 <0.01 <0.01 <0.01 16.64 <0.01 6.78 7.12 <0.01 16.65 <0.01 

 

Sea Basses <0.01 <0.01 <0.01 <0.01 <0.01 13.24 <0.01 5.64 5.90 <0.01 13.24 <0.01 

 

Seaboard goby <0.01 <0.01 <0.01 <0.01 16,071.16 0.02 <0.01 7,239.43 7,367.13 <0.01 16,071.18 <0.01 7

 

Searobin 0.45 1.18 0.58 0.59 0.45 80.30 <0.01 27.96 28.24 <0.01 81.48 0.45 

 

Sheepshead <0.01 <0.01 <0.01 <0.01 <0.01 382.88 <0.01 129.50 129.82 <0.01 382.88 <0.01 

 

Shiners 1.67 3.98 1.93 1.95 1.64 429.73 <0.01 174.39 180.77 <0.01 433.71 1.67 

 

Shrimp (other) 2.82 8.93 3.81 3.81 2.82 1,469.73 <0.01 616.82 625.97 <0.01 1,478.66 2.82 

 

Silver hake 0.02 0.05 0.03 0.03 0.02 568.71 <0.01 231.82 243.20 <0.01 568.76 0.02 

 

Silver perch 0.32 0.91 0.42 0.42 0.32 88,985.72 <0.01 30,097.30 30,171.28 <0.01 88,986.63 0.32 30

 

Silversides 0.07 0.16 0.08 0.08 0.07 171.19 <0.01 72.23 75.51 <0.01 171.35 0.07 

 

Skates <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Skipjack herring 0.64 1.52 0.74 0.74 0.62 0.54 <0.01 0.22 0.23 <0.01 2.06 0.64 

 

Smallmouth bass 0.06 0.14 0.07 0.07 0.06 54.51 <0.01 22.27 23.30 <0.01 54.66 0.06 

 

Impingement Entrainment I&
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table C-16: Baseline I&E Mortality Losses at All In-scope Facilities (Manufacturing and Generating) Nationally (milyear), and I&E Mortality Reductions for Option Scenarios Estimated for All Sources of Mortality, continued 

Species B 1234 B 1 2 3 4 B 1 

Smelts 1.76 4.07 2.01 2.02 1.75 154.31 <0.01 61.72 62.70 <0.01 158.39 1.76 

 

Spot 4.25 11.27 5.47 5.48 4.25 2,420.22 <0.01 1,016.05 1,018.92 <0.01 2,431.49 4.25 1

 

Spotted seatrout 0.46 1.21 0.60 0.60 0.46 5,373.31 <0.01 1,820.18 1,824.64 <0.01 5,374.51 0.46 1

 

Spotted sucker <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Stone crab 0.11 0.27 0.14 0.14 0.10 28,711.01 <0.01 9,710.82 9,734.68 <0.01 28,711.29 0.11 9

 

Striped bass 0.70 1.68 0.81 0.82 0.68 1,071.31 <0.01 490.20 496.62 <0.01 1,072.98 0.70 

 

Striped killifish 0.12 0.32 0.16 0.16 0.12 0.06 <0.01 0.03 0.03 <0.01 0.38 0.12 

 

Striped mullet 0.17 0.45 0.23 0.23 0.17 15.17 <0.01 5.13 5.14 <0.01 15.62 0.17 

 

Sturgeons <0.01 <0.01 <0.01 <0.01 <0.01 1.46 <0.01 0.59 0.62 <0.01 1.46 <0.01 

 

Suckers 0.07 0.17 0.08 0.08 0.07 4,344.79 <0.01 1,775.05 1,856.67 <0.01 4,344.96 0.07 1

 

Summer flounder 0.03 0.08 0.04 0.04 0.03 <0.01 <0.01 <0.01 <0.01 <0.01 0.08 0.03 

 

Sunfish 2.67 6.40 3.09 3.12 2.61 655.10 <0.01 267.58 279.80 <0.01 661.50 2.67 

 

Surfperches 0.06 0.13 0.06 0.06 0.06 <0.01 <0.01 <0.01 <0.01 <0.01 0.13 0.06 

 

Tautog <0.01 <0.01 <0.01 <0.01 <0.01 29,299.93 <0.01 11,943.48 12,529.42 <0.01 29,299.94 <0.01 11

 

Threespine stickleback 0.05 0.11 0.06 0.06 0.05 0.78 <0.01 0.31 0.32 <0.01 0.89 0.05 

 

Tidewater silverside 0.11 0.30 0.15 0.15 0.11 34.36 <0.01 11.62 11.65 <0.01 34.66 0.11 

 

Walleye 0.06 0.15 0.07 0.08 0.06 169.80 <0.01 69.37 72.56 <0.01 169.96 0.06 

 

Weakfish 1.28 3.35 1.63 1.64 1.28 929.71 <0.01 404.38 414.14 <0.01 933.06 1.28 

 

White bass 1.12 2.68 1.30 1.31 1.10 1,106.14 <0.01 451.56 471.86 <0.01 1,108.82 1.12 

 

White perch 2.70 6.70 3.25 3.27 2.66 2,996.05 <0.01 1,339.29 1,365.37 <0.01 3,002.75 2.70 1

 

Whitefish 0.04 0.10 0.05 0.05 0.04 0.92 <0.01 0.37 0.39 <0.01 1.02 0.04 

 

Windowpane <0.01 0.01 0.02 0.01 <0.01 2,066.54 <0.01 842.38 883.71 <0.01 2,066.57 <0.01 

 

Winter flounder 0.06 0.15 0.08 0.08 0.06 6,780.09 <0.01 2,768.38 2,902.67 <0.01 6,780.24 0.06 2

 

Yellow perch 4.02 9.59 4.64 4.68 3.93 1,130.30 <0.01 461.51 482.36 <0.01 1,139.89 4.02 

 

Total (all species) 421.62 1,034.92 500.44 504.14 413.70 1,055,936.41 <0.01 400,351.83 407,417.58 <0.01 1,056,971.34 421.62 400

 

Scenarios: B = Baseline I&E Mortality losses. 1 = Option 1 (I Everywhere), 2 = Option 2 (I Everywhere and E for Facilities > 125 MGD), 3 = Option 3 (I&E Mortality Everywhere), 4 = Option 4 (I for Facilities > 50 MGD). Va

losses.

Impingement Entrainment I&
March 28, 2011 D-1 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Appendix D: Discounting Benefits 

D.1 Introduction 

Discounting refers to the economic conversion of future benefits and costs to their present values, 

accounting for the fact that individuals tend to value future outcomes less than comparable near-term 

outcomes. Annualization refers to the conversion of a series of annual costs or benefits of differing 

amounts to an equivalent annual series of constant costs or benefits. Discounting and annualization are 

important because these techniques allow for the comparison of benefits and/or costs that occur in 

different time periods. 

For the benefits analysis of the regulatory options for the proposed Section 316(b) Rule, EPA’s 

discounting and annualization methodology included three steps. First, EPA developed a time profile of 

benefits to show when benefits occur. Second, the Agency calculated the total discounted value of the 

benefits as of the year 2012. Finally, EPA annualized the benefits of the regulatory options over a 50-year 

time span. The following sections explain these steps in detail. 

D.2 Timing of Benefits 

In order to calculate the annualized value of the welfare gain from the regulatory analysis options 

considered for the proposed Section 316(b) Rule, EPA developed a time profile of total benefits from all 

facilities that reflects when benefits from each facility will be realized. EPA first calculated the 

undiscounted welfare gain from the expected annual regional reductions in impingement and entrainment 

mortality (I&E mortality) under each option, based on the assumptions that all facilities in each region 

would achieved compliance and that benefits are realized immediately following compliance. Then, since 

there are regulatory and biological time lags between the potential promulgation of each respective 

regulatory option and the realization of benefits, EPA created a time profile of benefits that takes into 

account the fact that benefits do not begin immediately. 

Regulatory-related time lags occur because facilities will not always achieve compliance in the same year 

that costs are incurred. Facilities will face regulatory requirements once the rule takes effect, but it will 

take time to make the required changes. For this analysis, EPA assumed that facilities, in the aggregate, 

would achieve compliance on a uniform schedule over the 5-year periods 2013-2017, 2018-2022, or 

2023-2027 with all activities associated with the achievement of compliance estimated to occur uniformly 

over this period. Facilities required to comply with impingement mortality limits are assumed to achieve 

compliance on a uniform schedule over the 5-year period 2013-2017. Non-nuclear electric generating 

facilities required to reduce intake flow commensurate with closed cycle cooling are assumed to achieve 

compliance on a uniform schedule over the 5-year period 2018-2022. Nuclear electric generating facilities 

and manufacturing facilities required to reduce intake flow commensurate with closed cycle cooling are 

assumed to achieve compliance on a uniform schedule over the 5-year period 2023-2027. Following the 

achievement of compliance, all operational effects of compliance (i.e., reduction in I&E mortality losses) 

are also assumed to occur as though they originated from a compliance schedule that is uniformly spread 

over the 5-year window. Compliance is assumed to continue until the year 2056 for all facilities. See 

Chapter11 of the EA report for more detail. 

D
March 28, 2011 D-2 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

The biological time lags that affect the timing of commercial and recreational fishing benefits (including 

recreational use of threatened and endangered species) occur because most fish that would be spared from 

I&E mortality would be in larval or juvenile stages. Since these fish may require several years to grow 

and mature before commercial and recreational anglers can harvest them, there would be a lag between 

installation of technologies to reduce I&E mortality and realization of commercial and recreational 

angling benefits. For example, a larval fish spared from entrainment (in effect, at age zero) may be caught 

by a recreational angler at age three, meaning that a three-year time lag arises between the installation of 

technologies to reduce I&E mortality and the realization of the estimated recreational benefit. Likewise, if 

a one-year-old fish is spared from impingement and is then harvested by a commercial fisherman at age 

two, there is a one-year lag between the installation of technologies to reduce I&E mortality and the 

subsequent commercial fishery benefit. In general, fish that tend to be harvested at young ages will have 

relatively short time lags between implementation of technologies to reduce I&E mortality and the 

subsequent timing of changes in catch. In contrast, long-lived fish that tend to be caught at relatively older 

ages would tend to have longer time lags (and, hence, the effects of discounting would be larger, resulting 

in lower present values). 

In order to model the biological lags between installation of technologies to reduce I&E mortality and 

realization of commercial and recreational benefits, EPA collected species-specific information on ages of 

fish at harvest to estimate the average time required for a fish spared from I&E mortality to reach a 

harvestable age. The estimated time lags vary, depending on the life history of each fish species affected. 

EPA used this information, along with information about the estimated age and species composition of 

I&E mortality losses in each study region, to develop a benefits recognition schedule for facilities in each 

region.58

Following achievement of compliance, commercial and recreational fishing benefits from facilities in 

most regions (the California, North Atlantic, Mid-Atlantic, and South Atlantic regions) are assumed to 

increase over a seven-year period to a long-term, steady-state average, equal to the approximated perfacility benefit value discussed above, according to a numerical profile of <0.0, 0.1, 0.2, 0.8, 0.9, 0.95, 

1.0>. This profile indicates the fraction of the steady-state benefit value (i.e., the percentage of 

commercial and recreational fish spared from I&E mortality that reach a harvestable age) that is realized 

in each of the first seven years following the achievement of compliance at a facility. 

For regions with a relatively high contribution of impingement to total I&E mortality (the Inland, Great 

Lakes, and Gulf of Mexico regions), EPA used an adjusted profile of <0.1, 0.2, 0.8, 0.9, 0.95, 1.0> for 

commercial and recreational fishing benefits. This adjusted profile reflects the fact that impinged fish are 

usually larger and older than entrained fish and thus benefits will be realized sooner in these regions. 

These profile values are approximations based on a review of the age-specific fishing mortality rates that 

were used in the I&E mortality analysis and best professional judgment. 

In all regions, this fraction remains 1.0 until the final year of compliance, 2056. The commercial and 

recreational fishing benefits profile declines at the end of the compliance period in the same fashion that it 

increases at the beginning of compliance. . Specifically, at the end of the compliance period, benefit 

values follow a profile of <1.0, 0.9, 0.8, 0.2, 0.1, 0.05, 0.0> with the last benefits occurring in 2061. 

Therefore, the analysis of benefits encompasses a 50-year period from rule promulgation and first 

 

58 The benefits profile aggregated across all facilities in a region or nationwide was calculated using facility-level sample 

weights. These facility-level sample weights were designed so that the weighted actual regional intake flow for the sample 

facilities is the same as the estimated actual regional intake flow for the entire universe of facilities. These sample weights

and their derivation are described in more detail in Appendix A. 
March 28, 2011 D-3 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

occurrence of compliance-related costs in 2012 until the final benefits in 2061. The number of years when 

benefits do not equal zero varies among the in-scope facilities depending on the year that it initially 

achieves compliance. 

For nonuse benefits and the HEA analysis, EPA assumes that there is no initial biological lag at the start 

of the compliance period because benefits are not based on the harvest of fish spared from I&E mortality. 

Benefits are assumed to begin accruing immediately when a facility comes into compliance and to 

continue in full (i.e., fraction of 1.0) until the year 2056. 

The nonuse and HEA analysis include a linear decline in benefits starting at the end of the compliance 

period following a profile of <1.0, 0.83, 0.67, 0.50, 0.33, 0.17, 0.0> with the last benefits occurring in 

2061. This profile reflects the fact that increases in fish abundance and biological production resulting 

from reductions in I&E mortality will return to baseline over time. The duration of the profile is 

consistent with analyses for commercial and recreational fishing benefits and its trajectory is based on 

best professional judgment. 

D.3 Discounting and Annualization 

Using the time profile of benefits discussed above, EPA discounted the total benefits generated in each 

year of the analysis to 2012 using the following formula: 

   

t

t

t

r

2012 (1 )

Benefits

Present Value Equation D-1 

where: 

Benefitst = benefits in year t

r = discount rate (3 percent and 7 percent) 

t = year in which benefits are incurred 

After calculating the present value (PV) of these benefit streams, EPA calculated their constant annual 

equivalent value (annualized value) using the annualization formula presented below, again using two 

discount rates, 3 percent and 7 percent.59 Although the analysis period extends further, EPA annualized 

benefits over the assumed period of compliance for in-scope facilities. This same annualization concept 

and period of annualization were also followed in the analysis of costs, although for costs the time 

horizon of analysis for calculating the present value is shorter than for benefits. Using the same 

annualization period for both benefits and social costs allows comparison of constant annual equivalent 

values of benefits and costs that have been calculated on a mathematically consistent basis. The 

annualization formula is as follows: 

















 

  (1 ) 1* (1 ) Annualized Benefit PV of Benefit * n

n

r

r r

Equation D-2 

where: 

r = discount rate (3 percent and 7 percent) 

n = annualization period, 50 years for the benefits analysis 

 

59 The three percent rate represents an estimate of the social rate of time preference. 
March 28, 2011 D-4 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table D-1 presents a summary of the time profile of benefits discounted at the 3 percent and 7 percent 

rates for each of the regulatory options on the national scale. The table also presents the total value and 

annualized value that are equivalent to this stream of benefits. 

Table D-1: Time Profile of National Mean Total Benefits at In-scope Facilities by 

Regulatory Option (2009$, thousands)

Year 

Option 1: I Everywhere 

Option 2: I Everywhere 

and E for Facilities with 

DIF > 125 MGD 

Option 3: I&E 

Mortality Everywhere 

Option 4: I for 

Facilities with DIF > 

50 MGD 

3% 

Discount 

Rate 

7% 

Discount 

Rate 

3% 

Discount 

Rate 

7% 

Discount 

Rate 

3% 

Discount 

Rate 

7% 

Discount 

Rate 

3% 

Discount 

Rate 

7% 

Discount 

Rate 

2010 0 0 0 0 0 0 $0 $0 

2011 0 0 0 0 0 0 $0 $0 

2012 $0 $0 $0 $0 $0 $0 $0 $0 

2013 $470 $448 $32 $30 $7 $7 $463 $441 

2014 $1,309 $1,205 $85 $78 $20 $19 $1,288 $1,186 

2015 $4,165 $3,705 $264 $235 $72 $64 $4,091 $3,638 

2016 $7,461 $6,393 $458 $392 $126 $109 $7,329 $6,280 

2017 $10,765 $8,882 $652 $538 $181 $150 $10,576 $8,726 

2018 $13,640 $10,838 $14,443 $11,102 $14,415 $11,064 $13,400 $10,647 

2019 $16,019 $12,255 $28,190 $20,863 $28,616 $21,160 $15,737 $12,040 

2020 $16,464 $12,126 $44,411 $31,724 $45,435 $32,437 $16,179 $11,915 

2021 $16,347 $11,590 $61,484 $42,366 $63,150 $43,496 $16,064 $11,389 

2022 $16,047 $10,952 $77,979 $51,791 $80,270 $53,294 $15,769 $10,762 

2023 $15,598 $10,248 $86,028 $55,095 $88,729 $56,808 $15,329 $10,070 

2024 $15,144 $9,577 $93,426 $57,672 $96,529 $59,571 $14,882 $9,412 

2025 $14,703 $8,951 $98,547 $58,596 $102,101 $60,695 $14,449 $8,796 

2026 $14,274 $8,365 $103,581 $59,322 $107,577 $61,599 $14,028 $8,220 

2027 $13,859 $7,818 $108,187 $59,674 $112,604 $62,100 $13,619 $7,683 

2028 $13,455 $7,306 $108,905 $57,873 $113,471 $60,292 $13,223 $7,180 

2029 $13,063 $6,828 $109,142 $55,871 $113,816 $58,257 $12,837 $6,710 

2030 $12,683 $6,382 $108,273 $53,379 $112,912 $55,661 $12,464 $6,271 

2031 $12,313 $5,964 $105,740 $50,188 $110,279 $52,337 $12,101 $5,861 

2032 $11,955 $5,574 $102,961 $47,045 $107,385 $49,062 $11,748 $5,478 

2033 $11,606 $5,209 $100,080 $44,021 $104,379 $45,906 $11,406 $5,119 

2034 $11,268 $4,869 $97,165 $41,141 $101,339 $42,903 $11,074 $4,784 

2035 $10,940 $4,550 $94,335 $38,449 $98,387 $40,096 $10,751 $4,471 

2036 $10,622 $4,252 $91,588 $35,934 $95,522 $37,473 $10,438 $4,179 

2037 $10,312 $3,974 $88,920 $33,583 $92,739 $35,022 $10,134 $3,905 

2038 $10,012 $3,714 $86,330 $31,386 $90,038 $32,731 $9,839 $3,650 

2039 $9,720 $3,471 $83,816 $29,333 $87,416 $30,589 $9,552 $3,411 

2040 $9,437 $3,244 $81,374 $27,414 $84,870 $28,588 $9,274 $3,188 

2041 $9,162 $3,032 $79,004 $25,620 $82,398 $26,718 $9,004 $2,979 

2042 $8,895 $2,834 $76,703 $23,944 $79,998 $24,970 $8,742 $2,785 

2043 $8,636 $2,648 $74,469 $22,378 $77,668 $23,337 $8,487 $2,602 

2044 $8,385 $2,475 $72,300 $20,914 $75,406 $21,810 $8,240 $2,432 

2045 $8,141 $2,313 $70,194 $19,546 $73,209 $20,383 $8,000 $2,273 

2046 $7,903 $2,162 $68,150 $18,267 $71,077 $19,050 $7,767 $2,124 

2047 $7,673 $2,020 $66,165 $17,072 $69,007 $17,803 $7,541 $1,985 

2048 $7,450 $1,888 $64,238 $15,955 $66,997 $16,639 $7,321 $1,855 

2049 $7,233 $1,765 $62,367 $14,911 $65,046 $15,550 $7,108 $1,734 

2050 $7,022 $1,649 $60,550 $13,936 $63,151 $14,533 $6,901 $1,621 
March 28, 2011 D-5 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table D-1: Time Profile of National Mean Total Benefits at In-scope Facilities by 

Regulatory Option (2009$, thousands)

Year 

Option 1: I Everywhere 

Option 2: I Everywhere 

and E for Facilities with 

DIF > 125 MGD 

Option 3: I&E 

Mortality Everywhere 

Option 4: I for 

Facilities with DIF > 

50 MGD 

3% 

Discount 

Rate 

7% 

Discount 

Rate 

3% 

Discount 

Rate 

7% 

Discount 

Rate 

3% 

Discount 

Rate 

7% 

Discount 

Rate 

3% 

Discount 

Rate 

7% 

Discount 

Rate 

2051 $6,818 $1,541 $58,787 $13,024 $61,312 $13,582 $6,700 $1,515 

2052 $6,619 $1,440 $57,074 $12,172 $59,526 $12,694 $6,505 $1,416 

2053 $6,426 $1,346 $55,412 $11,376 $57,792 $11,863 $6,315 $1,323 

2054 $6,239 $1,258 $53,798 $10,632 $56,109 $11,087 $6,131 $1,236 

2055 $6,057 $1,176 $52,231 $9,936 $54,475 $10,362 $5,953 $1,155 

2056 $5,881 $1,099 $50,710 $9,286 $52,888 $9,684 $5,779 $1,080 

2057 $5,128 $922 $42,374 $7,475 $44,184 $7,794 $5,039 $906 

2058 $4,415 $765 $34,749 $5,906 $36,224 $6,156 $4,339 $751 

2059 $1,120 $186 $17,101 $2,772 $17,875 $2,897 $1,101 $183 

2060 $555 $89 $10,326 $1,608 $10,799 $1,682 $546 $87 

2061 $270 $42 $5,135 $770 $5,371 $805 $266 $41 

2062 $0 $0 $0 $0 $0 $0 $0 $0 

2063 0 0 0 0 0 0 $0 $0 

2064 0 0 0 0 0 0 $0 $0 

2065 0 0 0 0 0 0 $0 $0 

Total 

Present 

Valuea

$453,679 $221,341 $3,108,232 $1,272,593 $3,232,893 $1,320,887 $445,825 $217,499

Annualized 

Valueb

$17,632 $16,038 $120,794 $92,200 $125,649 $95,711 $17,327 $15,760

a The total present value is equal to the sum of the values of the benefits realized in all years of the analysis, discounted to 2012. 

b The annualized value represents the total present value of the benefits of the regulation, distributed over a 50-year period.

Source: U.S. EPA analysis for this report. 
March 28, 2011 E-1 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Appendix E: List of T&E Species Overlapping CWIS 

E 

Table E-1: List of T&E Species Overlapping One or More In-Scope 316(b) Cooling Water Intake 

Structure 

Latin Name Common Name 

Acipenser brevirostrum Shortnose Sturgeon 

Acipenser medirostris Green Sturgeon 

Acipenser oxyrinchus desotoi Gulf Sturgeon 

Acipenser oxyrinchus oxyrinchus Atlantic Sturgeon 

Acropora cervicornis Staghorn Coral 

Acropora palmata Elkhorn Coral 

Alasmidonta heterodon Dwarf Wedgemussel 

Amblyopsis rosae Ozark Cavefish 

Arkansia wheeleri Ouachita Rock Pocketbook 

Caretta caretta Loggerhead Sea Turtle 

Chelonia mydas Green Sea Turtle 

Conradilla caelata Birdwing Pearlymussel 

Cottus paulus (=pygmaeus) Pygmy Sculpin 

Cyprinella caerulea Blue Shiner 

Cyprogenia stegaria Fanshell 

Dermochelys coriacea Leatherback Sea Turtle 

Dromus dromas Dromedary Pearlymussel 

Elliptio steinstansana Tar River Spinymussel 

Epioblasma brevidens Cumberlandian Combshell 

Epioblasma florentina florentina Yellow (Pearlymussel) Blossom 

Epioblasma florentina walkeri (=E. walkeri) Tan Riffleshell 

Epioblasma obliquata obliquata Catspaw (Purple Cat's Paw Pearlymussel) 

Epioblasma obliquata perobliqua White (Pearlymussel) Catspaw 

Epioblasma penita Southern Combshell 

Epioblasma torulosa gubernaculum Green (Pearlymussel) Blossom 

Epioblasma torulosa rangiana Northern Riffleshell 

Epioblasma torulosa torulosa Tubercled (Pearlymussel) Blossom 

Epioblasma turgidula Turgid (Pearlymussel) Blossom 

Eretmochelys imbricata Hawksbill Sea Turtle 

Etheostoma etowahae Etowah Darter 

Etheostoma percnurum Duskytail Darter 

Etheostoma scotti Cherokee Darter 

Etheostoma wapiti Boulder Darter 

Fusconaia cor Shiny Pigtoe 

Fusconaia cuneolus Finerayed Pigtoe 

Gasterosteus aculeatus williamsoni Unarmored Threespine Stickleback 

Gila bicolor mohavensis Mohave Tui Chub 

Hemistena lata Cracking Pearlymussel 

Hypomesus transpacificus Delta Smelt 

Lampsilis abrupta Pink (Pearlymussel) Mucket 

Lampsilis higginsii Higgins Eye (Pearlymussel) 

Lampsilis powellii Arkansas Fatmucket 

Lampsilis virescens Alabama Lampmussel 

Lepidochelys kempii Kemp's Ridley Sea Turtle 
March 28, 2011 E-2 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table E-1: List of T&E Species Overlapping One or More In-Scope 316(b) Cooling Water Intake 

Structure 

Latin Name Common Name 

Lepidochelys olivacea Olive Ridley Sea Turtle 

Leptodea leptodon Scaleshell Mussel 

Margaritifera hembeli Louisiana Pearlshell 

Microphis brachyurus lineatus Opossum Pipefish 

Notropis albizonatus Palezone Shiner 

Notropis Topeka Topeka Shiner 

Noturus placidus Neosho Madtom 

Noturus stanauli Pygmy Madtom 

Noturus trautmani Scioto Madtom 

Obovaria retusa Ring Pink (Mussel) 

Oncorhynchus clarkii stomias Greenback Cutthroat 

Oncorhynchus keta Chum Salmon 

Oncorhynchus kisutch Coho Salmon 

Oncorhynchus mykiss Steelhead Trout 

Oncorhynchus tshawytscha Chinook Salmon 

Oregonichthys crameri Oregon Chub 

Pegias fabula Littlewing Pearlymussel 

Percina rex Roanoke Logperch 

Percina tanasi Snail Darter 

Phoxinus cumberlandensis Blackside Dace 

Plethobasus cicatricosus White (Pearlymussel) Wartyback 

Plethobasus cooperianus Orangefoot (Pearlymussel) Pimpleback 

Pleurobema clava Clubshell 

Pleurobema collina James Spinymussel 

Pleurobema marshalli Flat Pigtoe 

Pleurobema plenum Rough Pigtoe 

Pleurobema taitianum Heavy Pigtoe 

Potamilus capax Fat Pocketbook 

Potamilus inflatus Alabama (=Inflated) Heelsplitter 

Pristis pectinata Smalltooth Sawfish 

Ptychocheilus lucius Colorado Pikeminnow (=Squawfish) 

Quadrula fragosa Winged Mapleleaf 

Quadrula intermedia Cumberland (Pearlymussel) Monkeyface 

Quadrula sparsa Appalachian (Pearlymussel) Monkeyface 

Quadrula stapes Stirrupshell 

Rivulus marmoratus Mangrove Rivulus 

Salmo salar Atlantic Salmon 

Salvelinus confluentus Bull Trout 

Scaphirhynchus albus Pallid Sturgeon 

Scaphirhynchus suttkusi Alabama Sturgeon 

Speoplatyrhinus poulsoni Alabama Cavefish 

Toxolasma cylindrellus Pale (Pearlymussel) Lilliput 

Villosa perpurpurea Purple Bean 

Villosa trabalis Cumberland (Pearlymussel) Bean 

Xyrauchen texanus Razorback Sucker 
March 28, 2011 F-1 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

F

Appendix F: Detailed Methodologies of CWIS, and Estimated Benefits 

of Regulation on, Threatened and Endangered Species 

F.1 I&E Mortality of Sea Turtles 

Six species of sea turtles are found in U.S. waters: Green, Hawksbill, Kemp's Ridley, Leatherback, 

Loggerhead, and Olive Ridley sea turtles. All have extensive ranges, migrate long distances during their 

lifetime, and are listed as either threatened or endangered (T&E) under the Endangered Species Act 

(ESA). Because of these large ranges, there is substantial overlap between sea turtle habitat and cooling 

water intake structures (CWIS) for in-phase power generating and manufacturing facilities. Moreover, 

because individuals of all ages and sizes are susceptible to impingement and entrainment (Norem 2005), 

there are more than 730 locations of potential species x CWIS interactions that may result in the injury or 

death of these T&E species. 

Power plants are known to entrain and impinge all species of sea turtles, with individual incidences of 

mortality reported from California, Texas, Florida, South Carolina, North Carolina and New Jersey 

(Plotkin 1995). Although the cumulative impact of this mortality is unclear, it is believed to be relatively 

small considered to fishing mortality. Although quantitative reports are available from a few power 

stations (Table F-1), high-quality data is available from only one source, the St. Lucie Nuclear Power 

Plant, at Hutchinson Island, FL, where annual capture rates range from 350-1000 turtles. Although 

estimated mortality rates due to entrainment are < 3%, approximately 85% of entrained organisms show 

evidence of injury as a result of entrainment (Norem 2005). As such, true mortality rates from CWIS may 

be higher than reported, particularly for individuals who are recaptured repeatedly (37% of Green and 

13% of Loggerhead sea turtles entrained between May and December 2000 were recaptured individuals) 

(Norem 2005). 

In addition to research sponsored by the National Science Foundation, federal and state governmental 

spending on sea turtles under the ESA totaled $33.8 million in FY2008 (USFWS 2009). Moreover, the 

number of volunteer organizations dedicated to sea turtle recovery (Table F-2) provides further evidence 

of the high non-use values placed upon the survival of these animals by the public. 
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table F-1: Reported Values of Sea Turtle Entrainment 

Facility Species

Takes

Dates

Takes / yr

Non‐lethal Lethal Non‐lethal Letha

Crystal River, FL Kemp's Ridley, Loggerhead 40 5 1998 40 5 Brunswick, NC Loggerhead, Kemp's Ridley, Green 50 11 2000 50 11 Oyster Creek, NJ,Salem, NJ,

Hope NJ

Loggerhead 40 8 1999 40 8

Kemp's Ridley 7 3 1999 7 3 Green 8 2 1999 8 2

Salem, NJ Loggerhead, Kemp's Ridley, Green 23 2 1991 23 2 Salem, NJ Loggerhead 18 8 1980‐1988 2.25 1 Salem, NJ Kemp's Ridley 6 6 1980‐1988 0.75 0.75St. Lucie, FL Loggerhead 6313 169 1976‐2005 225.5 6 San Diego, Edison Olive Ridley Qualitative Reports OnlySan Diego, Encina, Edison GreenSt. Lucie, FL Leatherback 20 1976‐1998 0.95St. Lucie, FL Hawksbill 19 1976‐1998 0.90St. Lucie, FL Green 2297 1976‐1998 109.38 St. Lucie, FL Kemp's Ridley 34 1976‐1998 1.62All US Waters Loggerhead 5‐50

Annual

Estimate 5‐5
March 28, 2011 F-3 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table F-2: A subset of US-based nongovernmental organizations dedicated to sea turtle 

research and conservation 

Name Group Type Web Address 

Amelia Island Sea Turtle Watch, Inc. Volunteer www.ameliaislandseaturtlewatch.com/ 

Archie Carr Center for Sea Turtle 

Research 

Academic accstr.ufl.edu/ 

Bald Head Island Conservancy Volunteer www.bhic.org/STPP.shtml 

California Turtle & Tortoise Club Volunteer www.tortoise.org/ 

Caribbean Conservation Corporation Nonprofit www.helpingseaturtles.org/ 

Chelonian Research Foundation Academic www.chelonian.org/ 

Clearwater Marine Aquarium Nonprofit/Volunteer www.seewinter.com/what-we-do/nesting 

Coastal Research and Education 

Society of Long Island, Inc., New 

York State Sea Turtle Program 

Nonprofit/Volunteer www.cresli.org/cresli/turtles/turtpage.html 

Conservation International Sea Turtle 

Flagship Program 

Nonprofit www.conservation.org/discover/centers_pr

ograms/sea_turtles/Pages/seaturtles.aspx 

Earthwatch Nonprofit/Ecotourism www.earthwatch.org 

Gulf Coast Turtle and Tortoise Society Volunteer www.gctts.org/ 

Hawksbill Sea Turtle Recovery 

Project 

Government/Volunteer www.fpir.noaa.gov/PRD/prd_volunteer_op

ps.html 

Malama na Honu Nonprofit/Volunteer malamanahonu.org/ 

Marine Turtle Specialist Group Academic www.iucn-mtsg.org/ 

Maryland Marine Mammal and Sea 

Turtle Stranding Network 

Government/Volunteer www.dnr.state.md.us/fisheries/oxford/resea

rch/fwh/strandingprogram.html 

National Aquarium in Baltimore, 

Marine Animal Rescue Program 

Nonprofit/Volunteer www.aqua.org/oceanhealth_marp.html 

National Save the Sea Turtle 

Foundation 

Nonprofit savetheseaturtle.org/ 

Network for Endangered Seaturtles Volunteer www.nestonline.org/ 

Ocean Conservancy Nonprofit www.oceanconservancy.org/ 

Riverhead Foundation for Marine 

Research and Preservation 

Nonprofit/Volunteer www.riverheadfoundation.org/index.asp 

Sanibel-Captiva Conservation 

Foundation 

Nonprofit/Volunteer www.sccf.org/ 

Sea Turtle Restoration Project Nonprofit www.seaturtles.org 

Share the Beach, Sea Turtle 

Volunteering Program 

Volunteer www.alabamaseaturtles.com/ 

The Leatherback Trust Nonprofit leatherback.org/ 

The Turtle Foundation Nonprofit www.turtle-foundation.org 

F.2 Application of Whitehead (1993)’s Benefit Transfer Approach for Estimating 

WTP for T&E Sea Turtle Species 

EPA identified a study that used a stated preference valuation approach to estimate the total economic 

value (i.e. use and non-use values) of a management program designed to reduce the risk of extinction for 

loggerhead sea turtles (Whitehead 1993). The mail survey asked North Carolina households whether they 

were willing to pay a bid amount for a management program which reduces the probability that 

loggerhead sea turtles would be extinct in 25 years. Within the model framework, the baseline extinction 
March 28, 2011 F-4 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

risk and change from the management program are expressed in terms of a supply probability. Supply 

probability reflects the probability that “the wildlife resource will continue to exist so it can be enjoyed by 

recreational users and non users (p.121)” (Whitehead 1993). The household value is expressed as option 

price, or willingness to pay under conditions of future supply and demand uncertainty. The option price is 

estimated by solving for the dollar amount which would make respondent indifferent to utility with and 

without the management program. The function used to estimate option price (Model B from Whitehead 

(1993)) is: 

OP (1991$) = 1.272 [p2(r2-q2)] / 0.029 Equation F-3 

Variable definitions for the parameters in the function are described in Table F-3. 

EPA used Whitehead (1993) to assess the range of benefits potentially resulting from 316(b) regulatory 

options. Available data sources and biological models were reviewed to assess the potential impact of 

baseline losses and reductions on sea turtle supply probability (r2-q2). While analyses of sea turtle 

extinction risk have been conducted (e.g., Conant et al. 2009), EPA was unable to identify an existing 

model or analysis which could be readily used in conjunction with available mortality data to estimate the 

marginal impacts of CWIS on sea turtle extinction risk. Estimates from the literature suggest that 

impingement and entrainment mortality is of relatively low importance compared to other human-induced 

mortality such as shrimp trawling and other fisheries (Plotkin 1995). However, Crouse et al. (1987) found 

that mortality at juvenile and subadult life stages can have a substantial effect on population growth, 

suggesting that small changes in survivorship at these age classes could have a measurable impact on 

extinction risk. As such, EPA believes that marginal change in supply probability of loggerhead sea 

turtles due to 316(b) regulatory options is unlikely to be lower than 0.01 (i.e., a 1% increase in 25 year 

survival probability). 

EPA specified a marginal improvement of 0.01 within Whitehead’s (1993) modeling framework to bound 

household values for changes in extinction risk for loggerhead sea turtles as a consequence of 316(b) 

regulation. Although this assessment is not based on formal quantitative analysis of extinction risk, it is 

intended to illustrate the range of potential benefits associated with reductions in sea turtle losses. Using 

the author’s mean values for demand probability (p2) and supply probability without the management 

program (q2) (Table F-3), EPA calculated an annual household value of $0.35 (2009$). Estimates were 

converted to 2009 dollars using the consumer price index (USBLS 2010). 
March 28, 2011 F-5 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table F-3: Variable Descriptions and Values used for EPA’s Benefits Transfer Application 

Variable Name Description

Value Used in EPA's 

Applications

OP Option Price - The amount a household would be willing to pay under 

conditions of supply and demand uncertainty Estimated by the model

p2 Demand Probability - for wildlife users, demand uncertainty occurs 

when it is indeterminate whether recreational use of the wildlife 

resource will be pursued because of uncertain travel costs, income, 

and tastes. For nonusers, demand uncertainty depends on uncertain 

tastes. 0.51

q2

a Supply Probability without the Management Program - probability 

that the resource will continue to exist in 25 years without 

implementation of the management program. 0.43

r2 Supply Probability with the Management Program - probability that 

the resource will continue to exist in 25 years with implementation of 

the management program. 0.44

(r2-q2)

b Marginal increase in supply probability resulting from the 

management program 0.01

a

 The model results are linear for marginal improvements in supply probability.

b

 EPA notes that a marginal change in supply probability of 0.01 is substantially less than changes used by Whitehead (1993) for model 

estimation. Whitehead (1993) estimated an annual household willingness to payvalue of $10.98 (1991$) for a mean increase in supply 

probability of 0.47 in 25 years. 

F.3 Application of Richardson & Loomis’ (2008) WTP Model 

To illustrate the potential magnitude of nonuse values for T&E species affected by I&E mortality in the 

California and Inland regions, EPA applied a WTP meta-analytical model (Richardson and Loomis 2009) 

to hypothetical scenarios. Because EPA does not currently have region-wide I&E mortality losses for all 

T&E species, nor population models to estimate the effect of I&E mortality on population size, estimates 

are presented only to assess the range of benefits potentially resulting from 316(b) regulatory options. The 

modeled scenarios estimate the WTP for 0.25% and 0.5% increases for all T&E fish populations in the 

California and Inland regions. 

The model used by EPA to estimate nonuse values using benefit transfer is a double log specification 

(Model 4 from Richardson and Loomis (2009)), where: 

ln WTP (2006$) = -153.231 + 0.870 ln CHANGESIZE + 1.256 VISITOR + 1.020 FISH + 0.772 

MARINE + 0.826 BIRD – 0.603 ln RESPONSERATE+ 2.767 CONJOINT + 1.024 CHARISMATIC – 

0.903 MAIL + 0.078 STUDYYEAR Equation F-4 

Model variables are described in Table F-4. Excepting all policy-relevant variables, EPA used the mean 

values for all model parameters, and converted estimates to 2009$ using the consumer price index 

(USBLS 2010). 
March 28, 2011 F-6 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table F-4: Variables in the Meta-Analysis Model and Values Used in EPA’s Application 

Variable Name Description Value Used in EPA’s Application 

ln WTP Natural log of willingness to pay Estimated by model 

ln CHANGESIZE Natural log of the percentage change in 

the population of the species of interest 

Log of percentage change in fish 

population: ln(.25) and ln(.5) 

VISITOR = 1 if survey respondents are visitors 

rather than full-time residents 0.0 

FISH = 1 for fish species 1.0 

MARINE = 1 for marine mammals 0.0 

BIRD = 1 for bird species 0.0 

ln RESPONSERATE Natural log of the survey response rate 4.0 

CONJOINT = 1 for conjoint method surveys 0.0 

CHARISMATIC = 1 for charismatic species 0.0 

MAIL Indicates mail surveys 0.9 

STUDY YEAR Year of study 2007 
March 28, 2011 G-1 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

G 

Appendix G: Estimation of Price Changes for Consumer Surplus 

G.1 Introduction 

EPA considered estimating consumer surplus values associated with reductions in impingement and 

entrainment mortality (I&E mortality), but found that dockside prices would not change enough to 

produce measurable shifts in consumer surplus. This appendix presents the details of this analysis and the 

estimated price changes by region and species. 

G.2 Methodology and Results 

To properly estimate price changes, it is necessary to consider the contribution of the species to the 

overall market. Because individual demand functions incorporating substitutes are not available for most 

species, EPA estimated price changes in the following way. First, the Agency estimated the total baseline 

harvest for relevant species (commercial species of similar types to those affected by I&E mortality), in 

three categories: finfish, shrimp, and crabs.60, The totals for finfish were summed for the East Coast and 

Gulf, and for the West Coast; while totals for shrimp and crabs were summed across all coastal regions.61

Next, EPA calculated the percentage change in harvest if baseline I&E mortality losses were to be 

eliminated, by dividing the total increase in harvest from elimination of baseline I&E mortality by the 

total harvest. The percentage change in price for each region and species was then estimated by dividing 

the percentage change in harvest by the elasticity for the species group (finfish, shrimp, or crabs). 

This last step requires estimates of elasticities. The price elasticity of demand for fish measures the 

percentage change in demand in response to a percentage change in fish price. Thus, the inverse elasticity, 

or price flexibility, measures the percentage change in price for a given percentage change in quantity. 

EPA’s review of the economics literature identified several potentially relevant studies, including Asche, 

Bjorndal, and Gordon (2005); Capps and Lambrgets (1991); Cheng and Capps (1988); Tsoa, Schrank, and 

Roy (1982); Davis, Yen, and Hwan-Lin (2007); and Lin, Richards, and Terry (1988). 

Table G-1 presents the own-price elasticities identified in the literature review for those commercial 

species where I&E mortality losses were estimated. Since elasticities can vary by species, the Agency 

grouped the own-price elasticities found in the literature review into three categories: (1) saltwater fish, 

(2) shrimp, and (3) crabs. The median elasticities within each of these groups, presented in the fourth 

column of Table G-1, are the elasticities used in this analysis. Table G-1 shows that there is a substantial 

amount of variation in the elasticity estimates, so by selecting the median elasticity rather than taking an 

average, the influence of the more extreme estimates is reduced.62g 

 

60 For example, offshore species such as tuna and swordfish, baitfish species, and shellfish were not included. 

61 Harvests for Alaska and Hawaii were not included in the totals. 

62 Only two studies were available for crabs, so EPA used the mean elasticity for crabs. The Agency did not distinguish 

between finfish elasticities for the East and West Coast, because some sources provide elasticities based on models that 

include both regions. 
March 28, 2011 G-2 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table G-1: Own-Price Elasticity Estimates from Literature Review

Species 

Group Species Study Elasticity 

Median Species 

Group 

Elasticity 

Study Notes 

Saltwater Cod -0.54 -1.89 Cheng and Capps (1988) 

Saltwater Cod -3.15 -1.89 Bell (1986) as cited in Asche, 

Bjorndal and Gordon (2005) 

 

Saltwater Cod(Blocks) -3.16 -1.89 

Mazany, Roy and Schrank (1996) as 

cited in Asche, Bjorndal and Gordon 

(2005) 

 

Saltwater Cod(Fillets) -0.46 -1.89 Tsoa, Schrank and Roy (1982) Long run estimate. 

Saltwater Cod(Fillets) -1.89 -1.89 Asche, Bjorndal and Gordon (2005) 

Saltwater Flounder -1.63 -1.89 

Mazany, Roy and Schrank (1996) as 

cited in Asche, Bjorndal and Gordon 

(2005) 

 

Saltwater Flounder/Sole -0.45 -1.89 Cheng and Capps (1988) 

Saltwater Flounder/Sole -1.04 -1.89 Tsoa, Schrank and Roy (1982) Long run estimate. 

Saltwater Halibut -5.56 -1.89 

Lin, Richards and Terry (1988) as 

cited in Asche, Bjorndal and Gordon 

(2005) 

 

Saltwater Perch -0.70 -1.89 Cheng and Capps (1988) 

Saltwater Perch -3.09 -1.89 Capps and Lambrgets (1991) 

Saltwater Perch -0.60 -1.89 Tsoa, Schrank and Roy (1982) Long run estimate. 

Saltwater Perch -215.00 -1.89 Bell (1986) as cited in Asche, 

Bjorndal and Gordon (2005) 

 

Saltwater Rockfish -3.55 -1.89 Capps and Lambrgets (1991) 

Saltwater Whitefish -5.24 -1.89 Capps and Lambrgets (1991) 

Shrimp Shrimp -0.70 -0.63 Cheng and Capps (1988) 

Shrimp Shrimp -1.08 -0.63 Davis, Yen and Hwan-Lin (2007) Low income 

estimate. 

Shrimp Shrimp -0.30 -0.63 Davis, Yen and Hwan-Lin (2007) High income 

estimate. 

Shrimp Shrimp -2.84 -0.63 Capps and Lambrgets (1991) 

Shrimp Shrimp -0.63 -0.63 Doll (1972) as cited in Cheng and 

Capps (1988) 

 

Shrimp Shrimp 0.28 -0.63 Cleary (1969) as cited in Cheng and 

Capps (1988) 

 

Shrimp Shrimp -0.57 -0.63 Sun (1995) as cited in Asche, 

Bjorndal and Gordon (2005) 

Crabs Crabs -0.77 -1.31 Cheng and Capps (1988) 

Crabs Crabs -1.84 -1.31 Capps and Lambrgets (1991) 

Table G-2 shows the results of the calculations of percentage changes in price. These percentage changes 

were applied to the baseline prices to develop estimates of prices for the increased harvests that would 

result from eliminating baseline I&E mortality losses. Table G-3 to Table G-7 show the projected prices 

after eliminating baseline I&E mortality losses.63 For a 0.27 percent change in total harvest in California, 

 

63 Values of 0.0 for increased harvest from elimination of baseline I&E mortality losses may include increases less than 0.1 

thousand lbs. 
March 28, 2011 G-3 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

finfish prices are predicted to change by 0.14 percent; for a 5.52 percent change in harvest for the East 

Coast and Gulf, finfish prices are predicted to change by 2.92 percent; for a 0.11 percent change in 

harvest of shrimp, prices are predicted to change by 0.17 percent; and for a 0.26 percent change in harvest 

for crabs, prices are predicted to change by 0.20 percent. This translates into very small changes 

(generally one to two cents) in ex-vessel prices per pound for the species affected by I&E mortality. 

Because of the negligible effects on prices, EPA did not include measures of changes in consumer surplus 

in the commercial fishing benefits estimates. 

Table G-2: Estimated Percentage Change in Ex-Vessel Price by Region and Species Group 

Region Species 

Group 

Baseline 

Increase in 

Harvesta 

(lbs) 

Total Average 

Annual Harvestb 

(lbs) 

Percentage 

Change in 

Harvest 

Elasticity 

Percentage 

Change in 

Price 

California Finfish 1,373,100 546,791,850 0.25% -1.89 -0.13% 

East Coast and Gulf Finfish 15,758,900 397,297,400 3.97% -1.89 -2.10% 

All Regions Crabs 678,900 315,657,146 0.22% -1.31 -0.16% 

All Regions Shrimp 327,700 289,878,937 0.11% -0.63 -0.18% 

a. Estimated increase in harvest due to elimination of baseline I&E mortality. 

b. Sum of total landings for all relevant species; source – NMFS landings data. 

Table G-3: Estimated Price Changes for the California Region 

Species Average Annual Harvest 

2005-2009 (thousand lbs) 

Price Per Pound 

(2009$)a

Increase in Harvest from 

Elimination of Baseline 

I&E Losses (thousand 

lbs) 

New Price 

Per Pound 

(2009$)a

American Shad 75.1 $0.98 0.0 $0.98 

Anchovies 22,607.2 $0.05 0.6 $0.05 

Cabezon 55.6 $5.83 54.4 $5.82 

California Halibut 629.9 $4.06 126.4 $4.05 

California Scorpionfish 7.9 $3.40 0.0 $3.40 

Commercial Crabs 1,290.8 $1.33 1.6 $1.33 

Commercial Shrimp 2,552.2 $1.93 0.0 $1.93 

Drums and Croakers 77.0 $0.63 4.9 $0.63 

Dungeness Crabs 14,370.0 $2.07 4.3 $2.07 

Flounders 474.8 $0.45 10.1 $0.45 

Other 57,125.4 $0.89 4.7 $0.89 

Rockfishes 2,668.4 $1.25 1,168.7 $1.25 

Sculpins 3.5 $3.43 2.6 $3.43 

Sea Basses 6.5 $2.39 0.0 $2.39 

Smelts 319.5 $0.38 0.2 $0.38 

Surfperches 30.9 $1.92 0.5 $1.92 

Total 102,294.7 . 1,379.0 . 
March 28, 2011 G-4 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table G-4: Estimated Price Changes for the North Atlantic Region 

Species Average Annual Harvest 

2005-2009 (thousand lbs) 

Price Per Pound 

(2009$)a

Increase in Harvest from 

Elimination of Baseline 

I&E Losses (thousand lbs) 

New Price 

Per Pound 

(2009$)a

American Shad 38.1 $0.69 0.0 $0.68 

Atlantic Cod 15,427.3 $1.55 2.4 $1.52 

Atlantic Herring 106,047.1 $0.12 18.0 $0.12 

Atlantic Menhaden 5,548.6 $0.10 5.0 $0.10 

Bluefish 1,077.2 $0.47 0.0 $0.46 

Butterfish 550.9 $0.66 0.2 $0.65 

Commercial Crabs 15,107.8 $0.58 0.4 $0.58 

Flounders 17,675.4 $1.87 386.9 $1.83 

Mackerels 38,896.8 $0.14 2.3 $0.14 

Other 270,552.6 $0.44 3.9 $0.43 

Pollock 14,567.6 $0.55 0.0 $0.54 

Red Hake 576.9 $0.45 0.0 $0.44 

Sculpins <0.1 $0.25 4.0 $0.24 

Scup 4531 $0.86 0.1 $0.84 

Searobin 23.9 $0.12 0.1 $0.12 

Silver Hake 9,613.2 $0.53 0.6 $0.52 

Skate Species 31,638.4 $0.20 0.5 $0.20 

Tautog 147.1 $2.03 4.9 $1.99 

Weakfish 28.2 $1.48 0.2 $1.45 

White Perch 6.6 $1.45 0.0 $1.42 

Total 53,2054.6 . 429.6 .
March 28, 2011 G-5 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table G-5: Estimated Price Changes for the Mid-Atlantic Region 

Species Average Annual Harvest 

2005-2009 (thousand lbs) 

Price Per Pound 

(2009$)a

Increase in Harvest from 

Elimination of Baseline 

I&E Losses (thousand lbs) 

New Price 

Per Pound 

(2009$)a

Alewife 173.3 $0.21 0.4 $0.21 

American Shad 111.4 $0.92 1.5 $0.90 

Atlantic Herring 1,284.2 $0.11 0.1 $0.11 

Atlantic Menhaden 338,097.3 $0.07 4,915.4 $0.07 

Black Drum 93.8 $1.26 0.3 $1.23 

Blue Crab 62,874.0 $1.17 1,014.2 $1.15 

Bluefish 2,906.3 $0.43 0.1 $0.42 

Butterfish 501.3 $0.85 0.0 $0.83 

Commercial Crabs 2,240.2 $0.60 0.4 $0.60 

Drums and Croakers 11,430.1 $0.49 1,519.2 $0.48 

Flounders 6,468.0 $2.01 8.7 $1.97 

Other 462,429.6 $0.32 1,264.4 $0.31 

Red Hake 150.7 $0.52 0.8 $0.51 

Scup 3,225.6 $0.98 0.0 $0.96 

Searobin 12.0 $0.22 0.0 $0.22 

Silver Hake 3,867.0 $0.67 0.1 $0.66 

Spot 3,286.9 $0.74 1,111.4 $0.72 

Striped Bass 5,413.8 $2.02 88.6 $1.98 

Striped Mullet 20.3 $0.53 0.3 $0.52 

Tautog 135.9 $2.64 0.0 $2.58 

Weakfish 497.0 $1.10 741.9 $1.08 

White Perch 1,190.0 $0.76 4.0 $0.74 

Total 906,408.6 . 10,671.9 . 

Table G-6: Estimated Price Changes for the South Atlantic Region 

Species 

Average Annual 

Harvest 2005-2009 

(thousand lbs) 

Price Per Pound 

(2009$)a

Increase in Harvest 

from Elimination of 

Baseline I&E Losses 

(thousand lbs) 

New Price 

Per Pound 

(2009$)a

Atlantic Menhaden 3,726.8 $0.11 55.7 $0.11 

Blue Crab 36,414.4 $0.91 4.2 $0.91 

Commercial Crabs 518 $1.51 0.0 $1.51 

Drums and Croakers 8,333.3 $0.40 14.9 $0.39 

Other 93,761.3 $1.17 3.0 $1.15 

Spot 1,167.6 $0.65 20.4 $0.64 

Stone Crab 101.1 $4.56 0.5 $4.55 

Weakfish 266.5 $0.93 0.7 $0.91 

Total 144,289.1 . 99.4 
March 28, 2011 G-6 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table G-7: Estimated Price Changes for the Gulf of Mexico Region 

Species 

Average Annual 

Harvest 2005-2009 

(thousand lbs) 

Price Per Pound 

(2009$)a

Increase in Harvest from 

Elimination of Baseline 

I&E Losses (thousand 

lbs) 

New Price 

Per Pound 

(2009$)a

Atlantic Menhaden 930,460.2 $0.06 988.4 $0.06 

Black Drum 4,397.3 $0.83 1,885.2 $0.81 

Blue Crab 56,804.0 $0.77 228.5 $0.77 

Drums and Croakers 81.0 $6.47 40.3 $6.33 

Leatherjacket 65.6 $1.40 90.7 $1.37 

Mackerels 3,967.4 $1.04 0.3 $1.02 

Other 1,250,334.1 $0.41 240.5 $0.40 

Pink Shrimp 8,696.5 $2.06 327.7 $2.06 

Sea Basses 66.6 $0.97 0 $0.95 

Sheepshead 1,366.3 $0.41 0 $0.40 

Spot 18.1 $0.43 40.0 $0.42 

Stone Crab 5,313.9 $4.23 439.0 $4.22 

Striped Mullet 10,347.7 $0.67 1,278.3 $0.66 

Total 2,271,918.70 . 5,558.9 . 
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

H

Appendix H: Details of Regional Commercial Fishing Benefits Table H-1: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality Losses at In-Scope FCalifornia Region, by Species and Regulatory Option (2009$) 

Baseline Option 1 Option 2 Option 3 Option 4 Baseline Option 1 Optio

American Shad 75.1 $0.98 0.0 0.0 0.0 0.0 0.0 . . Anchovies 22,607.2 $0.05 0.6 0.5 0.6 0.6 0.5 0.0 0.0 Cabezon 55.6 $5.83 54.4 0.1 46.4 48.5 0.1 166.5 0.2 California Halibut 629.9 $4.06 126.4 0.2 107.8 112.8 0.2 298.8 0.6 2California Scorpionfish 7.9 $3.40 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Commercial Crabs 1,290.8 $1.33 1.6 0.0 1.3 1.4 0.0 1.5 0.0 Commercial Shrimp 2,552.2 $1.93 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Drums and Croakers 77.0 $0.63 4.9 0.7 4.3 4.5 0.7 1.3 0.2 Dungeness Crabs 14,370.0 $2.07 4.3 0.4 3.8 3.9 0.4 6.6 0.6 Flounders 474.8 $0.45 10.1 0.9 8.8 9.1 0.9 2.9 0.3 Other 57,125.4 $0.89 4.7 0.6 4.1 4.2 0.6 2.2 0.3 Rockfishes 2,668.4 $1.25 1,168.7 2.6 996.4 1,042.2 2.5 907.7 2.0 7Sculpins 3.5 $3.43 2.6 0.1 2.2 2.3 0.1 5.7 0.2 Sea Basses 6.5 $2.39 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Smelts 319.5 $0.38 0.2 0.1 0.1 0.1 0.1 0.0 0.0 Surfperches 30.9 $1.92 0.5 0.5 0.5 0.5 0.4 0.4 0.3 Total (undiscounted) 102,294.7 . 1,379.0 6.7 1,176.4 1,230.3 6.5 1,393.9 4.7 1,1Total (3% Discount Rate) . . . . . . . 1,236.0 3.7 7Total (7% Discount Rate) . . . . . . . 1,195.0 3.3 5

Annual Benefits from Incre

(2009$, th

Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 MGD; OptiEverywhere; Option 4 = I for Facilities > 50 MGD

Species Name

Average 

Annual 

Harvest 2006-

2009

(thousand lbs)

Price per 

Pound

Annual Increase in Commercial Harvest

(thousand lbs)
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table H-2: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality Losses at In-Scope FAtlantic Region, by Species and Regulatory Option (2009$) 

Baseline Option 1 Option 2 Option 3 Option 4 Baseline Option 1 Optio

American Shad 38.1 $0.69 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Atlantic Cod 15,427.3 $1.55 2.4 0.1 2.0 2.1 0.1 2.5 0.1 Atlantic Herring 106,047.1 $0.12 18.0 0.4 14.8 15.5 0.4 1.7 0.0 Atlantic Menhaden 5,548.6 $0.10 5.0 0.0 4.1 4.3 0.0 0.4 0.0 Bluefish 1,077.2 $0.47 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Butterfish 550.9 $0.66 0.2 0.1 0.2 0.2 0.1 0.1 0.0 Commercial Crabs 15,107.8 $0.58 0.4 0.2 0.4 0.4 0.2 0.1 0.1 Flounders 17,675.4 $1.87 386.9 1.3 315.8 331.2 1.3 460.2 1.5 3Mackerels 38,896.8 $0.14 2.3 0.0 1.8 1.9 0.0 0.3 0.0 Other 270,552.6 $0.44 3.9 0.2 3.2 3.4 0.2 1.0 0.0 Pollock 14,567.6 $0.55 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Red Hake 576.9 $0.45 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Sculpins 0.0 $0.25 4.0 0.0 4.0 4.0 0.0 . . Scup 4,531.0 $0.86 0.1 0.0 0.1 0.1 0.0 0.1 0.0 Searobin 23.9 $0.12 0.1 0.0 0.1 0.1 0.0 . . Silver Hake 9,613.2 $0.53 0.6 0.1 0.5 0.6 0.1 0.2 0.0 Skate Species 31,638.4 $0.20 0.5 0.4 0.5 0.5 0.4 0.1 0.0 Tautog 147.1 $2.03 4.9 0.0 4.0 4.2 0.0 4.5 0.0 Weakfish 28.2 $1.48 0.2 0.0 0.2 0.2 0.0 0.3 0.0 White Perch 6.6 $1.45 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Total (undiscounted) 532,054.6 . 429.6 2.9 351.7 368.6 2.9 471.2 1.9 3Total (3% Discount Rate) . . . . . . . 417.9 1.5 2Total (7% Discount Rate) . . . . . . . 404.0 1.3 1Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 MGD; OptiEverywhere; Option 4 = I for Facilities > 50 MGD

Annual Benefits from Incre

(2009$, th

Species Name

Average 

Annual 

Harvest 2006-

2009

(thousand lbs)

Price per 

Pound

Annual Increase in Commercial Harvest

(thousand lbs)
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table H-3: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality Losses at In-Scope FAtlantic Region, by Species and Regulatory Option (2009$) 

Baseline Option 1 Option 2 Option 3 Option 4 Baseline Option 1 Optio

Alewife 173.3 $0.21 0.4 0.3 0.4 0.4 0.3 0.1 0.1 American Shad 111.4 $0.92 1.5 0.0 1.3 1.4 0.0 1.1 0.0 Atlantic Herring 1,284.2 $0.11 0.1 0.1 0.1 0.1 0.1 0.0 0.0 Atlantic Menhaden 338,097.3 $0.07 4,915.4 3,273.9 4,758.3 4,780.2 3,270.8 223.3 148.7 2Black Drum 93.8 $1.26 0.3 0.2 0.3 0.3 0.2 0.3 0.2 Blue Crab 62,874.0 $1.17 1,014.2 10.2 929.6 941.4 10.2 678.0 6.8 6Bluefish 2,906.3 $0.43 0.1 0.1 0.1 0.1 0.1 0.0 0.0 Butterfish 501.3 $0.85 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Commercial Crabs 2,240.2 $0.60 0.4 0.3 0.3 0.3 0.3 0.1 0.1 Drums and Croakers 11,430.1 $0.49 1,519.2 16.5 1,392.6 1,410.2 16.5 549.3 6.0 5Flounders 6,468.0 $2.01 8.7 3.4 8.3 8.3 3.4 11.9 4.5 Other 462,429.6 $0.32 1,264.4 126.9 1,167.9 1,181.3 126.8 293.0 29.4 2Red Hake 150.7 $0.52 0.8 0.6 0.8 0.8 0.6 0.3 0.2 Scup 3,225.6 $0.98 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Searobin 12.0 $0.22 0.0 0.0 0.0 0.0 0.0 . . Silver Hake 3,867.0 $0.67 0.1 0.1 0.1 0.1 0.1 0.0 0.0 Spot 3,286.9 $0.74 1,111.4 120.0 1,111.4 1,111.4 119.9 693.6 74.9 6Striped Bass 5,413.8 $2.02 88.6 0.4 81.2 82.2 0.4 119.2 0.6 Striped Mullet 20.3 $0.53 0.3 0.2 0.3 0.3 0.2 0.1 0.1 Tautog 135.9 $2.64 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Weakfish 497.0 $1.10 741.9 196.1 694.9 701.4 196.0 619.3 163.7 5White Perch 1,190.0 $0.76 4.0 0.3 3.7 3.7 0.3 2.5 0.2 Total (undiscounted) 906,408.6 . 10,671.9 3,749.8 10,151.6 10,224.0 3,746.3 3,192.2 435.5 3,0Total (3% Discount Rate) . . . . . . . 2,831.2 342.0 1,6Total (7% Discount Rate) . . . . . . . 2,736.8 302.7 1,1Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 MGD; OptiEverywhere; Option 4 = I for Facilities > 50 MGD

Annual Benefits from Incre

(2009$, th

Species Name

Average 

Annual 

Harvest 2006-

2009

(thousand lbs)

Price per 

Pound

Annual Increase in Commercial Harvest

(thousand lbs)
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table H-4: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality Losses at In-Scope FAtlantic Region, by Species and Regulatory Option (2009$) 

Baseline Option 1 Option 2 Option 3 Option 4 Baseline Option 1 Optio

Atlantic Menhaden 3,726.8 $0.11 55.7 31.4 47.4 47.4 31.4 4.7 2.7 Blue Crab 36,414.4 $0.91 4.2 2.6 3.6 3.6 2.6 2.2 1.4 Commercial Crabs 518.0 $1.51 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Drums and Croakers 8,333.3 $0.40 14.9 0.3 12.4 12.4 0.3 3.2 0.1 Other 93,761.3 $1.17 3.0 1.5 2.5 2.5 1.5 2.1 1.1 Spot 1,167.6 $0.65 20.4 8.6 17.3 17.3 8.6 9.3 3.9 Stone Crab 101.1 $4.56 0.5 0.3 0.5 0.5 0.3 1.4 0.9 Weakfish 266.5 $0.93 0.7 0.4 0.6 0.6 0.4 0.4 0.2 Total (undiscounted) 144,289.1 . 99.4 45.1 84.2 84.3 45.1 23.3 10.2 Total (3% Discount Rate) . . . . . . . 20.7 8.0 Total (7% Discount Rate) . . . . . . . 20.0 7.1 Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 MGD; OptiEverywhere; Option 4 = I for Facilities > 50 MGD

Annual Benefits from Incre

(2009$, th

Species Name

Average 

Annual 

Harvest 2006-

2009

(thousand lbs)

Price per 

Pound

Annual Increase in Commercial Harvest

(thousand lbs)
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table H-5: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality Losses at In-Scope FMexico Region, by Species and Regulatory Option (2009$) 

Baseline Option 1 Option 2 Option 3 Option 4 Baseline Option 1 Optio

Atlantic Menhaden 930,460.2 $0.06 988.4 749.3 978.5 979.2 743.6 44.1 33.5 Black Drum 4,397.3 $0.83 1,885.2 3.1 1,276.5 1,279.7 3.1 1,087.6 1.8 7Blue Crab 56,804.0 $0.77 228.5 40.2 171.2 171.5 39.9 126.3 22.2 Drums and Croakers 81.0 $6.47 40.3 30.8 40.0 40.0 30.6 140.7 107.7 Leatherjacket 65.6 $1.40 90.7 66.2 88.7 88.8 65.7 . . Mackerels 3,967.4 $1.04 0.3 0.2 0.3 0.3 0.2 0.2 0.2 Other 1,250,334.1 $0.41 240.5 164.8 230.8 231.0 163.6 45.7 31.3 Pink Shrimp 8,696.5 $2.06 327.7 154.4 285.5 285.9 153.3 293.4 138.3 2Sea Basses 66.6 $0.97 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Sheepshead 1,366.3 $0.41 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Spot 18.1 $0.43 40.0 24.8 37.3 37.3 24.6 9.3 5.8 Stone Crab 5,313.9 $4.23 439.0 104.1 340.1 340.7 103.3 1,323.1 313.8 1,0Striped Mullet 10,347.7 $0.67 1,278.3 121.5 914.9 916.9 120.5 676.0 64.2 4Total (undiscounted) 2,271,918.7 . 5,558.9 1,459.4 4,363.8 4,371.3 1,448.4 3,746.5 718.7 2,8Total (3% Discount Rate) . . . . . . . 3,462.9 588.4 1,8Total (7% Discount Rate) . . . . . . . 3,449.9 536.8 1,3Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 MGD; OptiEverywhere; Option 4 = I for Facilities > 50 MGD

Species Name

Average 

Annual 

Harvest 2006-

2009

(thousand lbs)

Price per 

Pound

Annual Benefits from Incre

(2009$, th

Annual Increase in Commercial Harvest

(thousand lbs)
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table H-6: Commercial Fishing Benefits from Eliminating or Reducing Baseline I&E Mortality Losses at In-Scope FLakes Region, by Species and Regulatory Option (2009$) 

Baseline Option 1 Option 2 Option 3 Option 4 Baseline Option 1 Optio

Bullhead 569.7 $0.41 0.8 0.7 0.8 0.8 0.7 0.1 0.1 Freshwater Drum 497.5 $0.16 16.1 3.8 13.7 13.8 3.8 0.8 0.2 Other 13,819.0 $0.94 97.2 35.0 85.3 86.1 34.7 26.6 9.6 Smelts 522.2 $0.91 105.9 91.2 104.6 104.9 90.5 27.8 24.0 White Bass 432.2 $0.68 22.0 6.4 19.0 19.2 6.4 4.3 1.3 Whitefish 9,406.5 $0.87 101.9 88.3 100.8 101.1 87.6 25.9 22.4 Yellow Perch 1,609.7 $2.08 2.3 1.6 2.2 2.2 1.6 1.4 0.9 Total (undiscounted) 40,675.8 . 346.2 227.0 326.4 328.0 225.1 86.8 58.4 Total (3% Discount Rate) . . . . . . . 80.3 47.8 Total (7% Discount Rate) . . . . . . . 80.0 43.6 Scenarios: Baseline = Eliminating Baseline I&E Mortality Losses; Option 1 = I Everywhere; Option 2 = I Everywhere and E for Facilities >125 MGD; OptiEverywhere; Option 4 = I for Facilities > 50 MGD

Species Name

Average 

Annual 

Harvest 2006-

2009

(thousand lbs)

Price per 

Pound

Annual Benefits from Incre

(2009$, th

Annual Increase in Commercial Harvest

(thousand lbs)
March 28, 2011 I-1 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

I 

Appendix I: Details of Regional Recreational Fishing Benefits 

I.1 California 

Table I-1: Recreational Fishing Benefits from Eliminating Baseline I&E Mortality Losses at Inscope Facilities in the California Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

California halibut 38,418.0 $5.11 $9.76 $18.62 196.7 374.6 715.4

Flounders 246.0 $5.11 $9.76 $18.62 1.3 2.4 4.6

Total (Flatfish) 38,664.0 $5.11 $9.76 $18.62 198.0 377.0 720.0

Striped bass 1,209.0 $4.21 $7.26 $12.43 5.0 9.0 15.0

Total (Small Game) 1,209.0 $4.21 $7.26 $12.43 5.0 9.0 15.0

Cabezon 7,158.0 $1.79 $2.96 $4.89 12.8 21.2 35.0

California scorpionfish 58.0 $1.79 $2.96 $4.89 0.1 0.2 0.3

Croakers 32,132.0 $1.79 $2.96 $4.89 57.5 95.0 157.1

Rockfish 285,002.0 $1.79 $2.96 $4.89 509.8 842.9 1,393.2

Sculpin 111,780.0 $1.79 $2.96 $4.89 200.0 330.6 546.4

Sea bass 512,501.0 $1.79 $2.96 $4.89 916.8 1,515.8 2,505.3

Smelts 21.0 $1.79 $2.96 $4.89 0.0 0.1 0.1

Sunfish 13.0 $1.79 $2.96 $4.89 0.0 0.0 0.1

Surfperch 30,172.0 $1.79 $2.96 $4.89 54.0 89.2 147.5

Total (Other Saltwater) 978,837.0 $1.79 $2.96 $4.89 1,751.0 2,895.0 4,785.0

Total (Unidentified) 3,629.0 $1.86 $3.10 $5.18 7.0 11.0 19.0

Total (Undiscounted) 1,022,339.0 . . . 1,960.0 3,292.0 5,539.0

Total (3% discount rate) . . . . 1,740.0 2,923.0 4,917.0

Total (7% discount rate) . . . . 1,681.0 2,823.0 4,750.0

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands) Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish
March 28, 2011 I-2 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-2: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 1 (I Everywhere) in the California Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

California halibut 71.0 $5.11 $9.76 $18.62 0.0 0.8 1.5

Flounders 22.0 $5.11 $9.76 $18.62 0.0 0.2 0.5

Total (Flatfish) 92.0 $5.11 $9.76 $18.62 0.0 1.0 2.0

Striped bass 0.0 $4.21 $7.26 $12.43 0.0 0.0 0.0

Total (Small Game) 0.0 $4.21 $7.26 $12.43 0.0 0.0 0.0

Cabezon 10.0 $1.79 $2.96 $4.89 0.0 0.0 0.0

California scorpionfish 50.0 $1.79 $2.96 $4.89 0.1 0.1 0.2

Croakers 4,696.0 $1.79 $2.96 $4.89 8.4 13.9 23.0

Rockfish 636.0 $1.79 $2.96 $4.89 1.1 1.9 3.1

Sculpin 3,284.0 $1.79 $2.96 $4.89 5.8 9.7 16.1

Sea bass 284.0 $1.79 $2.96 $4.89 0.5 0.8 1.4

Smelts 17.0 $1.79 $2.96 $4.89 0.0 0.1 0.1

Sunfish 1.0 $1.79 $2.96 $4.89 0.0 0.0 0.0

Surfperch 26,391.0 $1.79 $2.96 $4.89 47.0 78.3 129.1

Total (Other Saltwater) 35,369.0 $1.79 $2.96 $4.89 63.0 105.0 173.0

Total (Unidentified) 976.0 $1.86 $3.10 $5.18 2.0 3.0 5.0

Total (Undiscounted) 36,438.0 . . . 66.0 109.0 180.0

Total (3% discount rate) . . . . 51.0 85.0 141.0

Total (7% discount rate) . . . . 46.0 75.0 125.0

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands) Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish
March 28, 2011 I-3 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-3: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 2 (I Everywhere and E for Facilities > 125 MGD) in the California 

Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

California halibut 32,753.0 $5.11 $9.76 $18.62 167.9 319.9 610.0

Flounders 213.0 $5.11 $9.76 $18.62 1.1 2.1 4.0

Total (Flatfish) 32,967.0 $5.11 $9.76 $18.62 169.0 322.0 614.0

Striped bass 1,031.0 $4.21 $7.26 $12.43 4.0 7.0 13.0

Total (Small Game) 1,031.0 $4.21 $7.26 $12.43 4.0 7.0 13.0

Cabezon 6,103.0 $1.79 $2.96 $4.89 10.9 18.0 29.8

California scorpionfish 57.0 $1.79 $2.96 $4.89 0.1 0.2 0.3

Croakers 28,097.0 $1.79 $2.96 $4.89 50.3 83.1 137.3

Rockfish 242,999.0 $1.79 $2.96 $4.89 434.7 718.6 1,187.8

Sculpin 95,765.0 $1.79 $2.96 $4.89 171.3 283.2 468.1

Sea bass 436,840.0 $1.79 $2.96 $4.89 781.5 1,291.9 2,135.3

Smelts 20.0 $1.79 $2.96 $4.89 0.0 0.1 0.1

Sunfish 12.0 $1.79 $2.96 $4.89 0.0 0.0 0.1

Surfperch 29,711.0 $1.79 $2.96 $4.89 53.2 87.9 145.2

Total (Other Saltwater) 839,604.0 $1.79 $2.96 $4.89 1,502.0 2,483.0 4,104.0

Total (Unidentified) 3,240.0 $1.86 $3.10 $5.18 6.0 10.0 17.0

Total (Undiscounted) 876,841.0 . . . 1,681.0 2,822.0 4,748.0

Total (3% discount rate) . . . . 1,037.0 1,741.0 2,929.0

Total (7% discount rate) . . . . 792.0 1,330.0 2,237.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-4 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-4: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 3 (I&E Mortality Everywhere) in the California Region, by Species 

(2009$) 

5th Mean 95th 5th Mean 95th

California halibut 34,260.0 $5.11 $9.76 $18.62 174.9 333.8 637.9

Flounders 222.0 $5.11 $9.76 $18.62 1.1 2.2 4.1

Total (Flatfish) 34,482.0 $5.11 $9.76 $18.62 176.0 336.0 642.0

Striped bass 1,078.0 $4.21 $7.26 $12.43 5.0 8.0 13.0

Total (Small Game) 1,078.0 $4.21 $7.26 $12.43 5.0 8.0 13.0

Cabezon 6,383.0 $1.79 $2.96 $4.89 11.4 18.9 31.2

California scorpionfish 57.0 $1.79 $2.96 $4.89 0.1 0.2 0.3

Croakers 29,198.0 $1.79 $2.96 $4.89 52.2 86.3 142.7

Rockfish 254,174.0 $1.79 $2.96 $4.89 454.5 751.6 1,242.4

Sculpin 100,044.0 $1.79 $2.96 $4.89 178.9 295.9 489.0

Sea bass 456,964.0 $1.79 $2.96 $4.89 817.2 1,351.3 2,233.6

Smelts 21.0 $1.79 $2.96 $4.89 0.0 0.1 0.1

Sunfish 12.0 $1.79 $2.96 $4.89 0.0 0.0 0.1

Surfperch 29,987.0 $1.79 $2.96 $4.89 53.6 88.7 146.6

Total (Other Saltwater) 876,840.0 $1.79 $2.96 $4.89 1,568.0 2,593.0 4,286.0

Total (Unidentified) 3,349.0 $1.86 $3.10 $5.18 6.0 10.0 17.0

Total (Undiscounted) 915,750.0 . . . 1,755.0 2,948.0 4,959.0

Total (3% discount rate) . . . . 1,096.0 1,840.0 3,095.0

Total (7% discount rate) . . . . 832.0 1,396.0 2,349.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-5 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-5: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 4 (I for Facilities > 50 MGD) in the California Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

California halibut 69.0 $5.11 $9.76 $18.62 0.0 0.8 1.5

Flounders 21.0 $5.11 $9.76 $18.62 0.0 0.2 0.5

Total (Flatfish) 90.0 $5.11 $9.76 $18.62 0.0 1.0 2.0

Striped bass 0.0 $4.21 $7.26 $12.43 0.0 0.0 0.0

Total (Small Game) 0.0 $4.21 $7.26 $12.43 0.0 0.0 0.0

Cabezon 10.0 $1.79 $2.96 $4.89 0.0 0.0 0.0

California scorpionfish 49.0 $1.79 $2.96 $4.89 0.1 0.1 0.2

Croakers 4,565.0 $1.79 $2.96 $4.89 8.1 13.5 22.3

Rockfish 618.0 $1.79 $2.96 $4.89 1.1 1.8 3.0

Sculpin 3,192.0 $1.79 $2.96 $4.89 5.7 9.5 15.6

Sea bass 276.0 $1.79 $2.96 $4.89 0.5 0.8 1.3

Smelts 16.0 $1.79 $2.96 $4.89 0.0 0.0 0.1

Sunfish 1.0 $1.79 $2.96 $4.89 0.0 0.0 0.0

Surfperch 25,654.0 $1.79 $2.96 $4.89 45.5 76.1 125.4

Total (Other Saltwater) 34,382.0 $1.79 $2.96 $4.89 61.0 102.0 168.0

Total (Unidentified) 949.0 $1.86 $3.10 $5.18 2.0 3.0 5.0

Total (Undiscounted) 35,421.0 . . . 64.0 106.0 175.0

Total (3% discount rate) . . . . 50.0 83.0 137.0

Total (7% discount rate) . . . . 44.0 73.0 121.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-6 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

I.2 North Atlantic 

Table I-6: Recreational Fishing Benefits from Eliminating Baseline I&E Mortality Losses at Inscope Facilities in the North Atlantic Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Winter flounder 310,442.0 $3.81 $5.96 $9.42 1,182.0 1,850.0 2,925.0

Total (flatfish) 310,442.0 $3.81 $5.96 $9.42 1,182.0 1,850.0 2,925.0

Atlantic mackerel 903.0 $2.13 $5.94 $16.76 1.9 5.8 15.4

Bluefish 1.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Striped bass 0.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Weakfish 33.0 $2.13 $5.94 $16.76 0.1 0.2 0.6

Total (small game) 937.0 $2.13 $5.94 $16.76 2.0 6.0 16.0

Atlantic Cod 1,281.0 $1.79 $2.98 $4.97 2.3 3.8 6.4

Cunner 107,374.0 $1.79 $2.98 $4.97 191.9 320.2 533.7

Pollock 4.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Sculpin 323,088.0 $1.79 $2.98 $4.97 577.5 963.4 1,606.0

Scup 128.0 $1.79 $2.98 $4.97 0.2 0.4 0.6

Searobin 823.0 $1.79 $2.98 $4.97 1.5 2.5 4.1

Tautog 14,323.0 $1.79 $2.98 $4.97 25.6 42.7 71.2

White Perch 0.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Total (other saltwater) 447,021.0 $1.79 $2.98 $4.97 799.0 1,333.0 2,222.0

Total (unidentified) 2,783.0 $1.80 $3.01 $5.03 5.0 8.0 14.0

Total (Undiscounted) 761,183.0 . . . 1,988.0 3,197.0 5,177.0

Total (3% discount rate) . . . . 1,765.0 2,838.0 4,596.0

Total (7% discount rate) . . . . 1,705.0 2,742.0 4,440.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-7 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-7: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 1 (I Everywhere) in the North Atlantic Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Winter flounder 836.0 $3.81 $5.96 $9.42 3.0 5.0 8.0

Total (flatfish) 836.0 $3.81 $5.96 $9.42 3.0 5.0 8.0

Atlantic mackerel 0.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Bluefish 1.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Striped bass 0.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Weakfish 0.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Total (small game) 1.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Atlantic Cod 40.0 $1.79 $2.98 $4.97 0.1 0.1 0.2

Cunner 19.0 $1.79 $2.98 $4.97 0.0 0.0 0.1

Pollock 1.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Sculpin 345.0 $1.79 $2.98 $4.97 0.7 0.7 1.4

Scup 8.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Searobin 45.0 $1.79 $2.98 $4.97 0.1 0.1 0.2

Tautog 17.0 $1.79 $2.98 $4.97 0.0 0.0 0.1

White Perch 0.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Total (other saltwater) 476.0 $1.79 $2.98 $4.97 1.0 1.0 2.0

Total (unidentified) 181.0 $1.80 $3.01 $5.03 0.0 1.0 1.0

Total (Undiscounted) 1,495.0 . . . 4.0 7.0 11.0

Total (3% discount rate) . . . . 3.0 5.0 9.0

Total (7% discount rate) . . . . 3.0 5.0 8.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-8 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-8: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 2 (I Everywhere and E for Facilities > 125 MGD) in the North Atlantic 

Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Winter flounder 253,297.0 $3.81 $5.96 $9.42 964.0 1,510.0 2,387.0

Total (flatfish) 253,297.0 $3.81 $5.96 $9.42 964.0 1,510.0 2,387.0

Atlantic mackerel 736.0 $2.13 $5.94 $16.76 1.9 4.8 12.5

Bluefish 1.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Striped bass 0.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Weakfish 27.0 $2.13 $5.94 $16.76 0.1 0.2 0.5

Total (small game) 764.0 $2.13 $5.94 $16.76 2.0 5.0 13.0

Atlantic Cod 1,054.0 $1.79 $2.98 $4.97 1.9 3.1 5.2

Cunner 87,542.0 $1.79 $2.98 $4.97 156.6 261.0 435.1

Pollock 3.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Sculpin 263,485.0 $1.79 $2.98 $4.97 471.2 785.6 1,309.6

Scup 106.0 $1.79 $2.98 $4.97 0.2 0.3 0.5

Searobin 682.0 $1.79 $2.98 $4.97 1.2 2.0 3.4

Tautog 11,681.0 $1.79 $2.98 $4.97 20.9 34.8 58.1

White Perch 0.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Total (other saltwater) 364,555.0 $1.79 $2.98 $4.97 652.0 1,087.0 1,812.0

Total (unidentified) 2,313.0 $1.80 $3.01 $5.03 4.0 7.0 12.0

Total (Undiscounted) 620,929.0 . . . 1,622.0 2,608.0 4,223.0

Total (3% discount rate) . . . . 939.0 1,510.0 2,446.0

Total (7% discount rate) . . . . 698.0 1,122.0 1,817.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-9 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-9: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 3 (I&E Mortality Everywhere) in the North Atlantic Region, by Species 

(2009$) 

5th Mean 95th 5th Mean 95th

Winter flounder 265,676.0 $3.81 $5.96 $9.42 1,012.0 1,583.0 2,503.0

Total (flatfish) 265,676.0 $3.81 $5.96 $9.42 1,012.0 1,583.0 2,503.0

Atlantic mackerel 772.0 $2.13 $5.94 $16.76 1.9 4.8 12.5

Bluefish 1.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Striped bass 0.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Weakfish 29.0 $2.13 $5.94 $16.76 0.1 0.2 0.5

Total (small game) 801.0 $2.13 $5.94 $16.76 2.0 5.0 13.0

Atlantic Cod 1,104.0 $1.79 $2.98 $4.97 2.0 3.3 5.5

Cunner 91,836.0 $1.79 $2.98 $4.97 164.3 273.8 456.5

Pollock 3.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Sculpin 276,392.0 $1.79 $2.98 $4.97 494.4 823.9 1,374.0

Scup 111.0 $1.79 $2.98 $4.97 0.2 0.3 0.6

Searobin 713.0 $1.79 $2.98 $4.97 1.3 2.1 3.5

Tautog 12,253.0 $1.79 $2.98 $4.97 21.9 36.5 60.9

White Perch 0.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Total (other saltwater) 382,413.0 $1.79 $2.98 $4.97 684.0 1,140.0 1,901.0

Total (unidentified) 2,417.0 $1.80 $3.01 $5.03 4.0 7.0 12.0

Total (Undiscounted) 651,307.0 . . . 1,701.0 2,736.0 4,430.0

Total (3% discount rate) . . . . 1,018.0 1,638.0 2,652.0

Total (7% discount rate) . . . . 756.0 1,216.0 1,969.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-10 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-10: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 4 (I for Facilities > 50 MGD) in the North Atlantic Region, by Species 

(2009$) 

5th Mean 95th 5th Mean 95th

Winter flounder 836.0 $3.81 $5.96 $9.42 3.0 5.0 8.0

Total (flatfish) 836.0 $3.81 $5.96 $9.42 3.0 5.0 8.0

Atlantic mackerel 0.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Bluefish 1.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Striped bass 0.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Weakfish 0.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Total (small game) 1.0 $2.13 $5.94 $16.76 0.0 0.0 0.0

Atlantic Cod 40.0 $1.79 $2.98 $4.97 0.1 0.1 0.2

Cunner 19.0 $1.79 $2.98 $4.97 0.0 0.0 0.1

Pollock 1.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Sculpin 345.0 $1.79 $2.98 $4.97 0.7 0.7 1.4

Scup 8.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Searobin 45.0 $1.79 $2.98 $4.97 0.1 0.1 0.2

Tautog 17.0 $1.79 $2.98 $4.97 0.0 0.0 0.1

White Perch 0.0 $1.79 $2.98 $4.97 0.0 0.0 0.0

Total (other saltwater) 476.0 $1.79 $2.98 $4.97 1.0 1.0 2.0

Total (unidentified) 181.0 $1.80 $3.01 $5.03 0.0 1.0 1.0

Total (Undiscounted) 1,495.0 . . . 4.0 7.0 11.0

Total (3% discount rate) . . . . 3.0 5.0 9.0

Total (7% discount rate) . . . . 3.0 5.0 8.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-11 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

I.3 Mid-Atlantic 

Table I-11: Recreational Fishing Benefits from Eliminating Baseline I&E Mortality Losses at Inscope Facilities in the Mid-Atlantic Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Summer Flounder 5,310.0 $3.74 $5.62 $8.52 19.7 30.0 45.0

Winter Flounder 4,946.0 $3.74 $5.62 $8.52 18.3 28.0 42.0

Total (Flatfish) 10,256.0 $3.74 $5.62 $8.52 38.0 58.0 87.0

Black Crappie 3.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Bluegill 16.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Brown bullhead 3,847.0 $0.53 $1.06 $2.10 1.9 3.9 8.2

Bullhead 11.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Channel catfish 2,891.0 $0.53 $1.06 $2.10 1.5 2.9 6.2

Crappie 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Menhaden 966.0 $0.53 $1.06 $2.10 0.5 1.0 2.1

Sunfish 221.0 $0.53 $1.06 $2.10 0.1 0.2 0.5

Total (Panfish) 7,956.0 $0.53 $1.06 $2.10 4.0 8.0 17.0

Bluefish 126.0 $2.26 $5.90 $15.52 0.3 0.7 2.0

Red drum 2,667.0 $2.26 $5.90 $15.52 6.0 15.7 41.4

Spotted seatrout 1,768.0 $2.26 $5.90 $15.52 4.0 10.4 27.4

Striped bass 166,917.0 $2.26 $5.90 $15.52 377.4 985.1 2,589.8

Weakfish 459,710.0 $2.26 $5.90 $15.52 1,039.3 2,713.0 7,132.5

Total (Small Game) 631,187.0 $2.26 $5.90 $15.52 1,427.0 3,725.0 9,793.0

Northern pike 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Total (Walleye/Pike) 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Atlantic croaker 1,782,932.0 $1.85 $2.92 $4.60 3,304.3 5,205.0 8,205.4

Atlantic herring 57.0 $1.85 $2.92 $4.60 0.1 0.2 0.3

Black drum 255.0 $1.85 $2.92 $4.60 0.5 0.7 1.2

Cunner 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Scup 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Searobin 8.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Silver perch 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Smallmouth bass 57.0 $1.85 $2.92 $4.60 0.1 0.2 0.3

Spot 5,388,053.0 $1.85 $2.92 $4.60 9,985.6 15,729.6 24,796.9

Striped mullet 12.0 $1.85 $2.92 $4.60 0.0 0.0 0.1

Tautog 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

White perch 33,237.0 $1.85 $2.92 $4.60 61.6 97.0 153.0

Whitefish 426.0 $1.85 $2.92 $4.60 0.8 1.2 2.0

Total (Other Saltwater) 7,205,039.0 $1.85 $2.92 $4.60 13,353.0 21,034.0 33,159.0

Total (Unidentified) 1,226,622.0 $1.91 $3.24 $5.74 2,344.0 3,978.0 7,036.0

Total (Undiscounted) 9,081,061.0 . . . 17,166.0 28,803.0 50,092.0

Total (3% discount rate) . . . . 15,239.0 25,569.0 44,467.0

Total (7% discount rate) . . . . 14,721.0 24,701.0 42,958.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-12 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-12: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 1 (I Everywhere) in the Mid-Atlantic Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Summer Flounder 4,051.0 $3.74 $5.62 $8.52 15.1 23.1 34.7

Winter Flounder 499.0 $3.74 $5.62 $8.52 1.9 2.9 4.3

Total (Flatfish) 4,550.0 $3.74 $5.62 $8.52 17.0 26.0 39.0

Black Crappie 3.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Bluegill 12.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Brown bullhead 787.0 $0.53 $1.06 $2.10 0.5 0.7 1.7

Bullhead 8.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Channel catfish 2,205.0 $0.53 $1.06 $2.10 1.4 2.1 4.8

Crappie 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Menhaden 0.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Sunfish 169.0 $0.53 $1.06 $2.10 0.1 0.2 0.4

Total (Panfish) 3,185.0 $0.53 $1.06 $2.10 2.0 3.0 7.0

Bluefish 96.0 $2.26 $5.90 $15.52 0.2 0.6 1.5

Red drum 2,035.0 $2.26 $5.90 $15.52 4.6 12.0 31.6

Spotted seatrout 1,349.0 $2.26 $5.90 $15.52 3.0 8.0 20.9

Striped bass 796.0 $2.26 $5.90 $15.52 1.8 4.7 12.4

Weakfish 121,529.0 $2.26 $5.90 $15.52 274.3 716.8 1,885.7

Total (Small Game) 125,805.0 $2.26 $5.90 $15.52 284.0 742.0 1,952.0

Northern pike 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Total (Walleye/Pike) 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Atlantic croaker 19,396.0 $1.85 $2.92 $4.60 35.9 56.6 89.3

Atlantic herring 43.0 $1.85 $2.92 $4.60 0.1 0.1 0.2

Black drum 195.0 $1.85 $2.92 $4.60 0.4 0.6 0.9

Cunner 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Scup 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Searobin 5.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Silver perch 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Smallmouth bass 44.0 $1.85 $2.92 $4.60 0.1 0.1 0.2

Spot 318,070.0 $1.85 $2.92 $4.60 589.2 928.2 1,464.2

Striped mullet 9.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Tautog 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

White perch 2,541.0 $1.85 $2.92 $4.60 4.7 7.4 11.7

Whitefish 325.0 $1.85 $2.92 $4.60 0.6 0.9 1.5

Total (Other Saltwater) 340,629.0 $1.85 $2.92 $4.60 631.0 994.0 1,568.0

Total (Unidentified) 74,846.0 $1.91 $3.24 $5.74 143.0 243.0 429.0

Total (Undiscounted) 549,015.0 . . . 1,077.0 2,009.0 3,994.0

Total (3% discount rate) . . . . 846.0 1,577.0 3,136.0

Total (7% discount rate) . . . . 749.0 1,396.0 2,776.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-13 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-13: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 2 (I Everywhere and E for Facilities > 125 MGD) in the Mid-Atlantic 

Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Summer Flounder 5,180.0 $3.74 $5.62 $8.52 19.1 29.2 44.1

Winter Flounder 4,569.0 $3.74 $5.62 $8.52 16.9 25.8 38.9

Total (Flatfish) 9,749.0 $3.74 $5.62 $8.52 36.0 55.0 83.0

Black Crappie 3.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Bluegill 16.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Brown bullhead 3,585.0 $0.53 $1.06 $2.10 1.9 3.8 7.6

Bullhead 10.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Channel catfish 2,820.0 $0.53 $1.06 $2.10 1.5 3.0 6.0

Crappie 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Menhaden 885.0 $0.53 $1.06 $2.10 0.5 0.9 1.9

Sunfish 216.0 $0.53 $1.06 $2.10 0.1 0.2 0.5

Total (Panfish) 7,536.0 $0.53 $1.06 $2.10 4.0 8.0 16.0

Bluefish 123.0 $2.26 $5.90 $15.52 0.3 0.7 1.9

Red drum 2,602.0 $2.26 $5.90 $15.52 5.9 15.4 40.4

Spotted seatrout 1,724.0 $2.26 $5.90 $15.52 3.9 10.2 26.7

Striped bass 152,927.0 $2.26 $5.90 $15.52 345.7 902.6 2,372.8

Weakfish 430,538.0 $2.26 $5.90 $15.52 973.2 2,541.1 6,680.2

Total (Small Game) 587,915.0 $2.26 $5.90 $15.52 1,329.0 3,470.0 9,122.0

Northern pike 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Total (Walleye/Pike) 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Atlantic croaker 1,634,350.0 $1.85 $2.92 $4.60 3,028.8 4,771.2 7,521.5

Atlantic herring 55.0 $1.85 $2.92 $4.60 0.1 0.2 0.3

Black drum 249.0 $1.85 $2.92 $4.60 0.5 0.7 1.1

Cunner 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Scup 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Searobin 8.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Silver perch 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Smallmouth bass 56.0 $1.85 $2.92 $4.60 0.1 0.2 0.3

Spot 4,959,382.0 $1.85 $2.92 $4.60 9,190.9 14,478.0 22,823.8

Striped mullet 12.0 $1.85 $2.92 $4.60 0.0 0.0 0.1

Tautog 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

White perch 30,638.0 $1.85 $2.92 $4.60 56.8 89.4 141.0

Whitefish 415.0 $1.85 $2.92 $4.60 0.8 1.2 1.9

Total (Other Saltwater) 6,625,167.0 $1.85 $2.92 $4.60 12,278.0 19,341.0 30,490.0

Total (Unidentified) 1,129,224.0 $1.91 $3.24 $5.74 2,158.0 3,662.0 6,477.0

Total (Undiscounted) 8,359,591.0 . . . 15,805.0 26,536.0 46,188.0

Total (3% discount rate) . . . . 8,381.0 14,073.0 24,501.0

Total (7% discount rate) . . . . 5,831.0 9,792.0 17,049.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-14 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-14: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 3 (I&E Mortality Everywhere) in the Mid-Atlantic Region, by Species 

(2009$) 

5th Mean 95th 5th Mean 95th

Summer Flounder 5,198.0 $3.74 $5.62 $8.52 19.6 29.1 44.5

Winter Flounder 4,622.0 $3.74 $5.62 $8.52 17.4 25.9 39.5

Total (Flatfish) 9,820.0 $3.74 $5.62 $8.52 37.0 55.0 84.0

Black Crappie 3.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Bluegill 16.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Brown bullhead 3,622.0 $0.53 $1.06 $2.10 1.9 3.8 7.6

Bullhead 10.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Channel catfish 2,830.0 $0.53 $1.06 $2.10 1.5 3.0 6.0

Crappie 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Menhaden 896.0 $0.53 $1.06 $2.10 0.5 0.9 1.9

Sunfish 216.0 $0.53 $1.06 $2.10 0.1 0.2 0.5

Total (Panfish) 7,595.0 $0.53 $1.06 $2.10 4.0 8.0 16.0

Bluefish 123.0 $2.26 $5.90 $15.52 0.3 0.7 1.9

Red drum 2,611.0 $2.26 $5.90 $15.52 5.9 15.4 40.5

Spotted seatrout 1,730.0 $2.26 $5.90 $15.52 3.9 10.2 26.8

Striped bass 154,871.0 $2.26 $5.90 $15.52 350.2 914.0 2,402.9

Weakfish 434,593.0 $2.26 $5.90 $15.52 982.7 2,564.7 6,742.8

Total (Small Game) 593,930.0 $2.26 $5.90 $15.52 1,343.0 3,505.0 9,215.0

Northern pike 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Total (Walleye/Pike) 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Atlantic croaker 1,655,004.0 $1.85 $2.92 $4.60 3,067.0 4,831.4 7,616.6

Atlantic herring 55.0 $1.85 $2.92 $4.60 0.1 0.2 0.3

Black drum 250.0 $1.85 $2.92 $4.60 0.5 0.7 1.2

Cunner 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Scup 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Searobin 8.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Silver perch 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Smallmouth bass 56.0 $1.85 $2.92 $4.60 0.1 0.2 0.3

Spot 5,018,970.0 $1.85 $2.92 $4.60 9,301.1 14,651.8 23,098.1

Striped mullet 12.0 $1.85 $2.92 $4.60 0.0 0.0 0.1

Tautog 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

White perch 30,999.0 $1.85 $2.92 $4.60 57.4 90.5 142.7

Whitefish 417.0 $1.85 $2.92 $4.60 0.8 1.2 1.9

Total (Other Saltwater) 6,705,773.0 $1.85 $2.92 $4.60 12,427.0 19,576.0 30,861.0

Total (Unidentified) 1,142,763.0 $1.91 $3.24 $5.74 2,183.0 3,706.0 6,555.0

Total (Undiscounted) 8,459,880.0 . . . 15,995.0 26,851.0 46,731.0

Total (3% discount rate) . . . . 8,584.0 14,410.0 25,078.0

Total (7% discount rate) . . . . 5,975.0 10,030.0 17,456.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-15 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-15: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 4 (I for Facilities > 50 MGD) in the Mid-Atlantic Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Summer Flounder 4,047.0 $3.74 $5.62 $8.52 15.1 23.1 34.7

Winter Flounder 499.0 $3.74 $5.62 $8.52 1.9 2.9 4.3

Total (Flatfish) 4,546.0 $3.74 $5.62 $8.52 17.0 26.0 39.0

Black Crappie 3.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Bluegill 12.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Brown bullhead 786.0 $0.53 $1.06 $2.10 0.5 0.7 1.7

Bullhead 8.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Channel catfish 2,203.0 $0.53 $1.06 $2.10 1.4 2.1 4.8

Crappie 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Menhaden 0.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Sunfish 169.0 $0.53 $1.06 $2.10 0.1 0.2 0.4

Total (Panfish) 3,182.0 $0.53 $1.06 $2.10 2.0 3.0 7.0

Bluefish 96.0 $2.26 $5.90 $15.52 0.2 0.6 1.5

Red drum 2,033.0 $2.26 $5.90 $15.52 4.6 12.0 31.5

Spotted seatrout 1,347.0 $2.26 $5.90 $15.52 3.0 8.0 20.9

Striped bass 796.0 $2.26 $5.90 $15.52 1.8 4.7 12.3

Weakfish 121,415.0 $2.26 $5.90 $15.52 274.3 716.8 1,883.7

Total (Small Game) 125,687.0 $2.26 $5.90 $15.52 284.0 742.0 1,950.0

Northern pike 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Total (Walleye/Pike) 0.0 $0.00 $0.00 $0.00 0.0 0.0 0.0

Atlantic croaker 19,377.0 $1.85 $2.92 $4.60 35.9 56.5 89.2

Atlantic herring 43.0 $1.85 $2.92 $4.60 0.1 0.1 0.2

Black drum 195.0 $1.85 $2.92 $4.60 0.4 0.6 0.9

Cunner 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Scup 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Searobin 5.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Silver perch 1.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Smallmouth bass 44.0 $1.85 $2.92 $4.60 0.1 0.1 0.2

Spot 317,770.0 $1.85 $2.92 $4.60 589.2 927.2 1,462.3

Striped mullet 9.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

Tautog 0.0 $1.85 $2.92 $4.60 0.0 0.0 0.0

White perch 2,538.0 $1.85 $2.92 $4.60 4.7 7.4 11.7

Whitefish 324.0 $1.85 $2.92 $4.60 0.6 0.9 1.5

Total (Other Saltwater) 340,307.0 $1.85 $2.92 $4.60 631.0 993.0 1,566.0

Total (Unidentified) 74,775.0 $1.91 $3.24 $5.74 143.0 243.0 429.0

Total (Undiscounted) 548,496.0 . . . 1,076.0 2,007.0 3,991.0

Total (3% discount rate) . . . . 845.0 1,576.0 3,133.0

Total (7% discount rate) . . . . 748.0 1,395.0 2,773.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-16 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

I.4 South Atlantic 

Table I-16: Recreational Fishing Benefits from Eliminating Baseline I&E Mortality Losses at Inscope Facilities in the South Atlantic Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Flounders 778.0 $3.87 $5.61 $8.28 3.0 4.0 6.0

Total (Flatfish) 778.0 $3.87 $5.61 $8.28 3.0 4.0 6.0

Spotted seatrout 1,898.0 $2.72 $5.72 $12.04 4.8 10.5 22.6

Weakfish 455.0 $2.72 $5.72 $12.04 1.2 2.5 5.4

Total (Small Game) 2,353.0 $2.72 $5.72 $12.04 6.0 13.0 28.0

Croakers 96,913.0 $2.14 $2.85 $3.78 207.6 276.1 365.6

Pinfish 1,518.0 $2.14 $2.85 $3.78 3.3 4.3 5.7

Silver perch 76.0 $2.14 $2.85 $3.78 0.2 0.2 0.3

Spot 30,313.0 $2.14 $2.85 $3.78 64.9 86.4 114.4

Total (Other Saltwater) 128,820.0 $2.14 $2.85 $3.78 276.0 367.0 486.0

Total (Unidentified) 1,945.0 $2.15 $2.86 $3.82 4.0 6.0 7.0

Total (Undiscounted) 133,897.0 . . . 290.0 390.0 529.0

Total (3% discount rate) . . . . 257.0 346.0 469.0

Total (7% discount rate) . . . . 249.0 335.0 453.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)

Table I-17: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 1 (I Everywhere) in the South Atlantic Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Flounders 491.0 $3.87 $5.61 $8.28 2.0 3.0 4.0

Total (Flatfish) 491.0 $3.87 $5.61 $8.28 2.0 3.0 4.0

Spotted seatrout 0.0 $2.72 $5.72 $12.04 0.0 0.0 0.0

Weakfish 224.0 $2.72 $5.72 $12.04 1.0 1.0 3.0

Total (Small Game) 224.0 $2.72 $5.72 $12.04 1.0 1.0 3.0

Croakers 1,762.0 $2.14 $2.85 $3.78 3.8 5.0 6.7

Pinfish 0.0 $2.14 $2.85 $3.78 0.0 0.0 0.0

Silver perch 48.0 $2.14 $2.85 $3.78 0.1 0.1 0.2

Spot 12,733.0 $2.14 $2.85 $3.78 27.1 35.9 48.2

Total (Other Saltwater) 14,543.0 $2.14 $2.85 $3.78 31.0 41.0 55.0

Total (Unidentified) 624.0 $2.15 $2.86 $3.82 1.0 2.0 2.0

Total (Undiscounted) 15,882.0 . . . 35.0 47.0 64.0

Total (3% discount rate) . . . . 28.0 37.0 50.0

Total (7% discount rate) . . . . 24.0 33.0 45.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-17 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-18: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 2 (I Everywhere and E for Facilities > 125 MGD) in the South Atlantic 

Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Flounders 663.0 $3.87 $5.61 $8.28 3.0 4.0 5.0

Total (Flatfish) 663.0 $3.87 $5.61 $8.28 3.0 4.0 5.0

Spotted seatrout 1,583.0 $2.72 $5.72 $12.04 4.0 8.8 19.3

Weakfish 386.0 $2.72 $5.72 $12.04 1.0 2.2 4.7

Total (Small Game) 1,969.0 $2.72 $5.72 $12.04 5.0 11.0 24.0

Croakers 80,881.0 $2.14 $2.85 $3.78 173.2 230.2 305.2

Pinfish 1,266.0 $2.14 $2.85 $3.78 2.7 3.6 4.8

Silver perch 65.0 $2.14 $2.85 $3.78 0.1 0.2 0.2

Spot 25,654.0 $2.14 $2.85 $3.78 54.9 73.0 96.8

Total (Other Saltwater) 107,866.0 $2.14 $2.85 $3.78 231.0 307.0 407.0

Total (Unidentified) 1,641.0 $2.15 $2.86 $3.82 4.0 5.0 6.0

Total (Undiscounted) 112,139.0 . . . 243.0 327.0 443.0

Total (3% discount rate) . . . . 141.0 190.0 257.0

Total (7% discount rate) . . . . 103.0 139.0 188.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)

Table I-19: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 3 (I&E Mortality Everywhere) in the South Atlantic Region, by Species 

(2009$) 

5th Mean 95th 5th Mean 95th

Flounders 663.0 $3.87 $5.61 $8.28 3.0 4.0 5.0

Total (Flatfish) 663.0 $3.87 $5.61 $8.28 3.0 4.0 5.0

Spotted seatrout 1,586.0 $2.72 $5.72 $12.04 4.0 8.8 19.3

Weakfish 387.0 $2.72 $5.72 $12.04 1.0 2.2 4.7

Total (Small Game) 1,972.0 $2.72 $5.72 $12.04 5.0 11.0 24.0

Croakers 81,012.0 $2.14 $2.85 $3.78 174.0 231.0 306.0

Pinfish 1,268.0 $2.14 $2.85 $3.78 2.7 3.6 4.8

Silver perch 65.0 $2.14 $2.85 $3.78 0.1 0.2 0.2

Spot 25,677.0 $2.14 $2.85 $3.78 55.1 73.2 97.0

Total (Other Saltwater) 108,023.0 $2.14 $2.85 $3.78 232.0 308.0 408.0

Total (Unidentified) 1,642.0 $2.15 $2.86 $3.82 4.0 5.0 6.0

Total (Undiscounted) 112,301.0 . . . 243.0 327.0 443.0

Total (3% discount rate) . . . . 141.0 190.0 257.0

Total (7% discount rate) . . . . 103.0 139.0 188.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-18 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-20: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 4 (I for Facilities > 50 MGD) in the South Atlantic Region, by Species 

(2009$) 

5th Mean 95th 5th Mean 95th

Flounders 491.0 $3.87 $5.61 $8.28 2.0 3.0 4.0

Total (Flatfish) 491.0 $3.87 $5.61 $8.28 2.0 3.0 4.0

Spotted seatrout 0.0 $2.72 $5.72 $12.04 0.0 0.0 0.0

Weakfish 224.0 $2.72 $5.72 $12.04 1.0 1.0 3.0

Total (Small Game) 224.0 $2.72 $5.72 $12.04 1.0 1.0 3.0

Croakers 1,762.0 $2.14 $2.85 $3.78 3.8 5.0 6.7

Pinfish 0.0 $2.14 $2.85 $3.78 0.0 0.0 0.0

Silver perch 48.0 $2.14 $2.85 $3.78 0.1 0.1 0.2

Spot 12,733.0 $2.14 $2.85 $3.78 27.1 35.9 48.2

Total (Other Saltwater) 14,543.0 $2.14 $2.85 $3.78 31.0 41.0 55.0

Total (Unidentified) 624.0 $2.15 $2.86 $3.82 1.0 2.0 2.0

Total (Undiscounted) 15,882.0 . . . 35.0 47.0 64.0

Total (3% discount rate) . . . . 28.0 37.0 50.0

Total (7% discount rate) . . . . 24.0 33.0 45.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)

Gulf of Mexico 

Table I-21: Recreational Fishing Benefits from Eliminating Baseline I&E Mortality Losses at Inscope Facilities in the Gulf of Mexico Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Mackerels 1,156.0 $2.87 $5.63 $11.04 3.3 6.5 12.8

Red drum 26,719.0 $2.87 $5.63 $11.04 76.6 150.4 294.9

Spotted seatrout 512,503.0 $2.87 $5.63 $11.04 1,470.0 2,885.1 5,656.4

Total (Small Game) 540,378.0 $2.87 $5.63 $11.04 1,550.0 3,042.0 5,964.0

Atlantic croaker 179,036.0 $2.14 $2.78 $3.61 382.3 497.3 646.6

Black drum 1,542,661.0 $2.14 $2.78 $3.61 3,294.3 4,284.6 5,571.5

Pinfish 257,750.0 $2.14 $2.78 $3.61 550.4 715.9 930.9

Sea bass 119.0 $2.14 $2.78 $3.61 0.3 0.3 0.4

Searobin 118,160.0 $2.14 $2.78 $3.61 252.3 328.2 426.7

Sheepshead 46.0 $2.14 $2.78 $3.61 0.1 0.1 0.2

Silver perch 1,474.0 $2.14 $2.78 $3.61 3.1 4.1 5.3

Spot 30,308.0 $2.14 $2.78 $3.61 64.7 84.2 109.5

Striped mullet 49,804.0 $2.14 $2.78 $3.61 106.4 138.3 179.9

Total (Other Saltwater) 2,179,358.0 $2.14 $2.78 $3.61 4,654.0 6,053.0 7,871.0

Total (Unidentified) 131,612.0 $2.36 $3.66 $5.91 311.0 482.0 778.0

Total (Undiscounted) 2,851,347.0 . . . 6,515.0 9,576.0 14,612.0

Total (3% discount rate) . . . . 6,022.0 8,852.0 13,506.0

Total (7% discount rate) . . . . 5,999.0 8,818.0 13,456.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-19 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-22: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 1 (I Everywhere) in the Gulf of Mexico Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Mackerels 885.0 $2.87 $5.63 $11.04 2.5 5.0 9.8

Red drum 17,368.0 $2.87 $5.63 $11.04 49.8 97.8 191.7

Spotted seatrout 351,547.0 $2.87 $5.63 $11.04 1,008.6 1,979.2 3,879.6

Total (Small Game) 369,800.0 $2.87 $5.63 $11.04 1,061.0 2,082.0 4,081.0

Atlantic croaker 136,979.0 $2.14 $2.78 $3.61 292.8 380.2 494.6

Black drum 2,576.0 $2.14 $2.78 $3.61 5.5 7.1 9.3

Pinfish 5,161.0 $2.14 $2.78 $3.61 11.0 14.3 18.6

Sea bass 91.0 $2.14 $2.78 $3.61 0.2 0.3 0.3

Searobin 65,096.0 $2.14 $2.78 $3.61 139.1 180.7 235.0

Sheepshead 0.0 $2.14 $2.78 $3.61 0.0 0.0 0.0

Silver perch 59.0 $2.14 $2.78 $3.61 0.1 0.2 0.2

Spot 18,785.0 $2.14 $2.78 $3.61 40.1 52.1 67.8

Striped mullet 4,732.0 $2.14 $2.78 $3.61 10.1 13.1 17.1

Total (Other Saltwater) 233,480.0 $2.14 $2.78 $3.61 499.0 648.0 843.0

Total (Unidentified) 62,417.0 $2.36 $3.66 $5.91 147.0 228.0 369.0

Total (Undiscounted) 665,697.0 . . . 1,707.0 2,959.0 5,293.0

Total (3% discount rate) . . . . 1,398.0 2,422.0 4,334.0

Total (7% discount rate) . . . . 1,275.0 2,210.0 3,953.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-20 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-23: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 2 (I Everywhere and E for Facilities > 125 MGD) in the Gulf of Mexico 

Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Mackerels 1,148.0 $2.87 $5.63 $11.04 3.3 6.5 12.7

Red drum 25,256.0 $2.87 $5.63 $11.04 72.5 142.2 278.7

Spotted seatrout 492,047.0 $2.87 $5.63 $11.04 1,412.2 2,770.3 5,430.6

Total (Small Game) 518,450.0 $2.87 $5.63 $11.04 1,488.0 2,919.0 5,722.0

Atlantic croaker 177,750.0 $2.14 $2.78 $3.61 379.5 493.6 642.0

Black drum 1,044,602.0 $2.14 $2.78 $3.61 2,230.5 2,900.8 3,772.7

Pinfish 176,490.0 $2.14 $2.78 $3.61 376.9 490.1 637.4

Sea bass 119.0 $2.14 $2.78 $3.61 0.3 0.3 0.4

Searobin 106,846.0 $2.14 $2.78 $3.61 228.1 296.7 385.9

Sheepshead 31.0 $2.14 $2.78 $3.61 0.1 0.1 0.1

Silver perch 1,021.0 $2.14 $2.78 $3.61 2.2 2.8 3.7

Spot 28,270.0 $2.14 $2.78 $3.61 60.4 78.5 102.1

Striped mullet 35,647.0 $2.14 $2.78 $3.61 76.1 99.0 128.7

Total (Other Saltwater) 1,570,775.0 $2.14 $2.78 $3.61 3,354.0 4,362.0 5,673.0

Total (Unidentified) 114,838.0 $2.36 $3.66 $5.91 271.0 420.0 679.0

Total (Undiscounted) 2,204,063.0 . . . 5,113.0 7,701.0 12,073.0

Total (3% discount rate) . . . . 3,225.0 4,866.0 7,642.0

Total (7% discount rate) . . . . 2,491.0 3,760.0 5,908.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-21 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-24: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 3 (I&E Mortality Everywhere) in the Gulf of Mexico Region, by Species 

(2009$) 

5th Mean 95th 5th Mean 95th

Mackerels 1,149.0 $2.87 $5.63 $11.04 3.3 6.5 12.7

Red drum 25,279.0 $2.87 $5.63 $11.04 72.5 142.3 279.0

Spotted seatrout 492,479.0 $2.87 $5.63 $11.04 1,413.2 2,772.2 5,435.3

Total (Small Game) 518,907.0 $2.87 $5.63 $11.04 1,489.0 2,921.0 5,727.0

Atlantic croaker 177,884.0 $2.14 $2.78 $3.61 379.8 494.1 642.4

Black drum 1,047,164.0 $2.14 $2.78 $3.61 2,235.9 2,908.4 3,781.9

Pinfish 176,912.0 $2.14 $2.78 $3.61 377.7 491.4 638.9

Sea bass 119.0 $2.14 $2.78 $3.61 0.3 0.3 0.4

Searobin 106,965.0 $2.14 $2.78 $3.61 228.4 297.1 386.3

Sheepshead 31.0 $2.14 $2.78 $3.61 0.1 0.1 0.1

Silver perch 1,024.0 $2.14 $2.78 $3.61 2.2 2.8 3.7

Spot 28,298.0 $2.14 $2.78 $3.61 60.4 78.6 102.2

Striped mullet 35,724.0 $2.14 $2.78 $3.61 76.3 99.2 129.0

Total (Other Saltwater) 1,574,119.0 $2.14 $2.78 $3.61 3,361.0 4,372.0 5,685.0

Total (Unidentified) 114,982.0 $2.36 $3.66 $5.91 272.0 421.0 680.0

Total (Undiscounted) 2,208,009.0 . . . 5,122.0 7,714.0 12,091.0

Total (3% discount rate) . . . . 3,258.0 4,906.0 7,690.0

Total (7% discount rate) . . . . 2,510.0 3,781.0 5,926.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-22 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-25: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 4 (I for Facilities > 50 MGD) in the Gulf of Mexico Region, by Species 

(2009$) 

5th Mean 95th 5th Mean 95th

Mackerels 878.0 $2.87 $5.63 $11.04 2.5 4.9 9.7

Red drum 17,237.0 $2.87 $5.63 $11.04 49.5 97.0 190.2

Spotted seatrout 348,894.0 $2.87 $5.63 $11.04 1,001.0 1,964.0 3,850.1

Total (Small Game) 367,009.0 $2.87 $5.63 $11.04 1,053.0 2,066.0 4,050.0

Atlantic croaker 135,945.0 $2.14 $2.78 $3.61 290.4 377.8 491.1

Black drum 2,556.0 $2.14 $2.78 $3.61 5.5 7.1 9.2

Pinfish 5,122.0 $2.14 $2.78 $3.61 10.9 14.2 18.5

Sea bass 91.0 $2.14 $2.78 $3.61 0.2 0.3 0.3

Searobin 64,604.0 $2.14 $2.78 $3.61 138.0 179.6 233.4

Sheepshead 0.0 $2.14 $2.78 $3.61 0.0 0.0 0.0

Silver perch 58.0 $2.14 $2.78 $3.61 0.1 0.2 0.2

Spot 18,644.0 $2.14 $2.78 $3.61 39.8 51.8 67.3

Striped mullet 4,696.0 $2.14 $2.78 $3.61 10.0 13.1 17.0

Total (Other Saltwater) 231,717.0 $2.14 $2.78 $3.61 495.0 644.0 837.0

Total (Unidentified) 61,946.0 $2.36 $3.66 $5.91 146.0 227.0 366.0

Total (Undiscounted) 660,672.0 . . . 1,694.0 2,936.0 5,253.0

Total (3% discount rate) . . . . 1,387.0 2,404.0 4,301.0

Total (7% discount rate) . . . . 1,265.0 2,193.0 3,923.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-23 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

I.5 Great Lakes 

Table I-26: Recreational Fishing Benefits from Eliminating Baseline I&E Mortality Losses at Inscope Facilities in the Great Lakes Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Smallmouth bass 23.0 $4.42 $8.56 $16.61 0.1 203.0 394.0

White bass 23,688.0 $4.42 $8.56 $16.61 104.9 203.0 394.0

Total (Bass) 23,710.0 $4.42 $8.56 $16.61 105.0 203.0 394.0

Whitefish 69,428.0 $6.10 $9.43 $14.66 424.0 655.0 1,018.0

Total (Other Trout) 69,428.0 $6.10 $9.43 $14.66 424.0 655.0 1,018.0

Black crappie 11.0 $0.70 $1.33 $2.50 0.0 0.0 0.0

Bluegill 27.0 $0.70 $1.33 $2.50 0.0 0.0 0.1

Channel catfish 571.0 $0.70 $1.33 $2.50 0.4 0.8 1.4

Crappie 4,785.0 $0.70 $1.33 $2.50 3.3 6.3 12.0

Rainbow smelt 5,802.0 $0.70 $1.33 $2.50 4.1 7.7 14.5

Sculpin 6,516.0 $0.70 $1.33 $2.50 4.6 8.6 16.3

Smelts 14,657.0 $0.70 $1.33 $2.50 10.2 19.3 36.6

Sunfish 13,996.0 $0.70 $1.33 $2.50 9.8 18.5 35.0

Yellow perch 18,055.0 $0.70 $1.33 $2.50 12.6 23.8 45.1

Total (Panfish) 64,420.0 $0.70 $1.33 $2.50 45.0 85.0 161.0

Salmon 1,253.0 $8.16 $13.27 $21.61 10.0 17.0 27.0

Total (Salmon) 1,253.0 $8.16 $13.27 $21.61 10.0 17.0 27.0

Northern Pike 0.0 $2.18 $4.11 $7.80 0.0 0.0 0.0

Walleye 250.0 $2.18 $4.11 $7.80 1.0 1.0 2.0

Total (Walleye/Pike) 250.0 $2.18 $4.11 $7.80 1.0 1.0 2.0

Total (Unidentified) 190,587.0 $3.33 $6.22 $11.71 635.0 1,185.0 2,232.0

Total (Undiscounted) 349,648.0 . . . 1,219.0 2,146.0 3,834.0

Total (3% discount rate) . . . . 1,127.0 1,984.0 3,544.0

Total (7% discount rate) . . . . 1,123.0 1,977.0 3,530.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-24 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-27: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 1 (I Everywhere) in the Great Lakes Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Smallmouth bass 19.0 $4.42 $8.56 $16.61 0.1 60.0 116.0

White bass 6,939.0 $4.42 $8.56 $16.61 30.9 60.0 116.0

Total (Bass) 6,958.0 $4.42 $8.56 $16.61 31.0 60.0 116.0

Whitefish 60,141.0 $6.10 $9.43 $14.66 367.0 567.0 882.0

Total (Other Trout) 60,141.0 $6.10 $9.43 $14.66 367.0 567.0 882.0

Black crappie 9.0 $0.70 $1.33 $2.50 0.0 0.0 0.0

Bluegill 23.0 $0.70 $1.33 $2.50 0.0 0.0 0.1

Channel catfish 460.0 $0.70 $1.33 $2.50 0.3 0.6 1.1

Crappie 112.0 $0.70 $1.33 $2.50 0.1 0.1 0.3

Rainbow smelt 4,248.0 $0.70 $1.33 $2.50 2.9 5.6 10.6

Sculpin 290.0 $0.70 $1.33 $2.50 0.2 0.4 0.7

Smelts 12,641.0 $0.70 $1.33 $2.50 8.7 16.6 31.6

Sunfish 192.0 $0.70 $1.33 $2.50 0.1 0.3 0.5

Yellow perch 12,437.0 $0.70 $1.33 $2.50 8.6 16.4 31.1

Total (Panfish) 30,413.0 $0.70 $1.33 $2.50 21.0 40.0 76.0

Salmon 845.0 $8.16 $13.27 $21.61 7.0 11.0 18.0

Total (Salmon) 845.0 $8.16 $13.27 $21.61 7.0 11.0 18.0

Northern Pike 0.0 $2.18 $4.11 $7.80 0.0 0.0 0.0

Walleye 217.0 $2.18 $4.11 $7.80 0.0 1.0 2.0

Total (Walleye/Pike) 217.0 $2.18 $4.11 $7.80 0.0 1.0 2.0

Total (Unidentified) 77,515.0 $3.33 $6.22 $11.71 258.0 482.0 908.0

Total (Undiscounted) 176,089.0 . . . 685.0 1,162.0 2,001.0

Total (3% discount rate) . . . . 561.0 951.0 1,638.0

Total (7% discount rate) . . . . 511.0 867.0 1,495.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-25 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-28: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 2 (I Everywhere and E for Facilities > 125 MGD) in the Great Lakes 

Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Smallmouth bass 22.0 $4.42 $8.56 $16.61 0.1 175.0 340.0

White bass 20,444.0 $4.42 $8.56 $16.61 90.9 175.0 340.0

Total (Bass) 20,466.0 $4.42 $8.56 $16.61 91.0 175.0 340.0

Whitefish 68,676.0 $6.10 $9.43 $14.66 419.0 648.0 1,007.0

Total (Other Trout) 68,676.0 $6.10 $9.43 $14.66 419.0 648.0 1,007.0

Black crappie 10.0 $0.70 $1.33 $2.50 0.0 0.0 0.0

Bluegill 27.0 $0.70 $1.33 $2.50 0.0 0.0 0.1

Channel catfish 557.0 $0.70 $1.33 $2.50 0.4 0.7 1.4

Crappie 3,846.0 $0.70 $1.33 $2.50 2.7 5.1 9.6

Rainbow smelt 5,568.0 $0.70 $1.33 $2.50 3.9 7.4 13.9

Sculpin 5,267.0 $0.70 $1.33 $2.50 3.7 7.0 13.1

Smelts 14,487.0 $0.70 $1.33 $2.50 10.2 19.2 36.1

Sunfish 11,220.0 $0.70 $1.33 $2.50 7.9 14.9 28.0

Yellow perch 17,155.0 $0.70 $1.33 $2.50 12.1 22.7 42.8

Total (Panfish) 58,137.0 $0.70 $1.33 $2.50 41.0 77.0 145.0

Salmon 1,187.0 $8.16 $13.27 $21.61 10.0 16.0 26.0

Total (Salmon) 1,187.0 $8.16 $13.27 $21.61 10.0 16.0 26.0

Northern Pike 0.0 $2.18 $4.11 $7.80 0.0 0.0 0.0

Walleye 247.0 $2.18 $4.11 $7.80 1.0 1.0 2.0

Total (Walleye/Pike) 248.0 $2.18 $4.11 $7.80 1.0 1.0 2.0

Total (Unidentified) 169,259.0 $3.33 $6.22 $11.71 564.0 1,053.0 1,982.0

Total (Undiscounted) 317,974.0 . . . 1,124.0 1,970.0 3,502.0

Total (3% discount rate) . . . . 720.0 1,261.0 2,241.0

Total (7% discount rate) . . . . 559.0 979.0 1,739.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-26 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-29: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 3 (I&E Mortality Everywhere) in the Great Lakes Region, by Species 

(2009$) 

5th Mean 95th 5th Mean 95th

Smallmouth bass 23.0 $4.42 $8.56 $16.61 0.1 177.0 343.0

White bass 20,651.0 $4.42 $8.56 $16.61 90.9 177.0 343.0

Total (Bass) 20,674.0 $4.42 $8.56 $16.61 91.0 177.0 343.0

Whitefish 68,832.0 $6.10 $9.43 $14.66 420.0 649.0 1,009.0

Total (Other Trout) 68,832.0 $6.10 $9.43 $14.66 420.0 649.0 1,009.0

Black crappie 10.0 $0.70 $1.33 $2.50 0.0 0.0 0.0

Bluegill 27.0 $0.70 $1.33 $2.50 0.0 0.0 0.1

Channel catfish 559.0 $0.70 $1.33 $2.50 0.4 0.7 1.4

Crappie 3,902.0 $0.70 $1.33 $2.50 2.7 5.2 9.7

Rainbow smelt 5,590.0 $0.70 $1.33 $2.50 3.9 7.4 13.9

Sculpin 5,343.0 $0.70 $1.33 $2.50 3.7 7.1 13.3

Smelts 14,520.0 $0.70 $1.33 $2.50 10.2 19.3 36.2

Sunfish 11,386.0 $0.70 $1.33 $2.50 8.0 15.2 28.4

Yellow perch 17,232.0 $0.70 $1.33 $2.50 12.1 22.9 43.0

Total (Panfish) 58,570.0 $0.70 $1.33 $2.50 41.0 78.0 146.0

Salmon 1,192.0 $8.16 $13.27 $21.61 10.0 16.0 26.0

Total (Salmon) 1,192.0 $8.16 $13.27 $21.61 10.0 16.0 26.0

Northern Pike 0.0 $2.18 $4.11 $7.80 0.0 0.0 0.0

Walleye 248.0 $2.18 $4.11 $7.80 1.0 1.0 2.0

Total (Walleye/Pike) 248.0 $2.18 $4.11 $7.80 1.0 1.0 2.0

Total (Unidentified) 170,680.0 $3.33 $6.22 $11.71 569.0 1,062.0 1,999.0

Total (Undiscounted) 320,196.0 . . . 1,131.0 1,982.0 3,526.0

Total (3% discount rate) . . . . 725.0 1,271.0 2,261.0

Total (7% discount rate) . . . . 561.0 984.0 1,750.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-27 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-30: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 4 (I for Facilities > 50 <MGD) in the Great Lakes Region, by Species 

(2009$) 

5th Mean 95th 5th Mean 95th

Smallmouth bass 19.0 $4.42 $8.56 $16.61 0.1 59.0 115.0

White bass 6,880.0 $4.42 $8.56 $16.61 30.9 59.0 115.0

Total (Bass) 6,900.0 $4.42 $8.56 $16.61 31.0 59.0 115.0

Whitefish 59,632.0 $6.10 $9.43 $14.66 364.0 563.0 874.0

Total (Other Trout) 59,632.0 $6.10 $9.43 $14.66 364.0 563.0 874.0

Black crappie 9.0 $0.70 $1.33 $2.50 0.0 0.0 0.0

Bluegill 23.0 $0.70 $1.33 $2.50 0.0 0.0 0.1

Channel catfish 456.0 $0.70 $1.33 $2.50 0.3 0.6 1.1

Crappie 111.0 $0.70 $1.33 $2.50 0.1 0.1 0.3

Rainbow smelt 4,212.0 $0.70 $1.33 $2.50 2.9 5.6 10.5

Sculpin 287.0 $0.70 $1.33 $2.50 0.2 0.4 0.7

Smelts 12,534.0 $0.70 $1.33 $2.50 8.7 16.6 31.2

Sunfish 190.0 $0.70 $1.33 $2.50 0.1 0.3 0.5

Yellow perch 12,332.0 $0.70 $1.33 $2.50 8.6 16.4 30.7

Total (Panfish) 30,156.0 $0.70 $1.33 $2.50 21.0 40.0 75.0

Salmon 838.0 $8.16 $13.27 $21.61 7.0 11.0 18.0

Total (Salmon) 838.0 $8.16 $13.27 $21.61 7.0 11.0 18.0

Northern Pike 0.0 $2.18 $4.11 $7.80 0.0 0.0 0.0

Walleye 215.0 $2.18 $4.11 $7.80 0.0 1.0 2.0

Total (Walleye/Pike) 215.0 $2.18 $4.11 $7.80 0.0 1.0 2.0

Total (Unidentified) 76,860.0 $3.33 $6.22 $11.71 256.0 478.0 900.0

Total (Undiscounted) 174,601.0 . . . 679.0 1,152.0 1,984.0

Total (3% discount rate) . . . . 556.0 943.0 1,624.0

Total (7% discount rate) . . . . 507.0 860.0 1,482.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-28 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

I.6 Inland 

Table I-31: Recreational Fishing Benefits from Eliminating Baseline I&E Mortality Losses at Inscope Facilities in the Inland Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Smallmouth bass 190,994.0 $4.28 $9.01 $19.08 818.3 1,721.3 3,643.5

White bass 1,656,537.0 $4.28 $9.01 $19.08 7,097.7 14,929.7 31,600.6

Total (Bass) 1,847,530.0 $4.28 $9.01 $19.08 7,916.0 16,651.0 35,244.0

Whitefish 2,061.0 $1.52 $2.83 $5.29 3.0 6.0 11.0

Total (Other Trout) 2,061.0 $1.52 $2.83 $5.29 3.0 6.0 11.0

Black bullhead 31,025.0 $0.53 $1.06 $2.10 16.4 32.8 65.3

Black crappie 145,478.0 $0.53 $1.06 $2.10 76.9 153.7 306.0

Bluegill 433,471.0 $0.53 $1.06 $2.10 229.0 458.0 911.7

Brown bullhead 14,807.0 $0.53 $1.06 $2.10 7.8 15.6 31.1

Bullhead 5,390.0 $0.53 $1.06 $2.10 2.8 5.7 11.3

Channel catfish 441,689.0 $0.53 $1.06 $2.10 233.4 466.7 929.0

Crappie 386,810.0 $0.53 $1.06 $2.10 204.4 408.7 813.6

Menhaden 308.0 $0.53 $1.06 $2.10 0.2 0.3 0.6

Rainbow smelt 9,240.0 $0.53 $1.06 $2.10 4.9 9.8 19.4

Smelts 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Sunfish 1,511,686.0 $0.53 $1.06 $2.10 798.7 1,597.3 3,179.6

White Perch 5,479.0 $0.53 $1.06 $2.10 2.9 5.8 11.5

Yellow perch 625,983.0 $0.53 $1.06 $2.10 330.7 661.5 1,316.7

Total (Panfish) 3,611,368.0 $0.53 $1.06 $2.10 1,908.0 3,816.0 7,596.0

Salmon 5.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

Total (Salmon) 5.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

American shad 3,070.0 $1.61 $5.36 $18.07 5.0 16.5 55.4

Striped bass 19,797.0 $1.61 $5.36 $18.07 32.2 106.2 357.3

Sturgeon 1,735.0 $1.61 $5.36 $18.07 2.8 9.3 31.3

Total (Small Game) 24,603.0 $1.61 $5.36 $18.07 40.0 132.0 444.0

Northern pike 36.0 $1.98 $4.10 $8.53 0.1 0.1 0.3

Sauger 180,270.0 $1.98 $4.10 $8.53 357.2 739.7 1,537.2

Walleye 209,854.0 $1.98 $4.10 $8.53 415.8 861.1 1,789.5

Total (Walleye/Pike) 390,160.0 $1.98 $4.10 $8.53 773.0 1,601.0 3,327.0

Total (Unidentified) 6,716,737.0 $1.08 $2.23 $4.60 7,283.0 14,985.0 30,898.0

Total (Undiscounted) 12,592,464.0 . . . 17,923.0 37,191.0 77,520.0

Total (3% discount rate) . . . . 16,566.0 34,376.0 71,653.0

Total (7% discount rate) . . . . 16,504.0 34,247.0 71,384.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-29 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-32: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 1 (I Everywhere) in the Inland Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Smallmouth bass 9,573.0 $4.28 $9.01 $19.08 41.0 86.3 182.6

White bass 649,610.0 $4.28 $9.01 $19.08 2,783.0 5,854.7 12,392.4

Total (Bass) 659,182.0 $4.28 $9.01 $19.08 2,824.0 5,941.0 12,575.0

Whitefish 1,642.0 $1.52 $2.83 $5.29 2.0 5.0 9.0

Total (Other Trout) 1,642.0 $1.52 $2.83 $5.29 2.0 5.0 9.0

Black bullhead 25,176.0 $0.53 $1.06 $2.10 13.3 26.6 53.0

Black crappie 14,071.0 $0.53 $1.06 $2.10 7.4 14.9 29.6

Bluegill 334,160.0 $0.53 $1.06 $2.10 176.6 353.1 703.0

Brown bullhead 4,771.0 $0.53 $1.06 $2.10 2.5 5.0 10.0

Bullhead 3,245.0 $0.53 $1.06 $2.10 1.7 3.4 6.8

Channel catfish 228,275.0 $0.53 $1.06 $2.10 120.6 241.2 480.2

Crappie 24,144.0 $0.53 $1.06 $2.10 12.8 25.5 50.8

Menhaden 258.0 $0.53 $1.06 $2.10 0.1 0.3 0.5

Rainbow smelt 3,097.0 $0.53 $1.06 $2.10 1.6 3.3 6.5

Smelts 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Sunfish 193,777.0 $0.53 $1.06 $2.10 102.4 204.8 407.6

White Perch 4,067.0 $0.53 $1.06 $2.10 2.1 4.3 8.6

Yellow perch 298,679.0 $0.53 $1.06 $2.10 157.8 315.6 628.3

Total (Panfish) 1,133,719.0 $0.53 $1.06 $2.10 599.0 1,198.0 2,385.0

Salmon 4.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

Total (Salmon) 4.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

American shad 2,569.0 $1.61 $5.36 $18.07 4.1 13.7 46.4

Striped bass 16,562.0 $1.61 $5.36 $18.07 26.6 88.3 299.3

Sturgeon 184.0 $1.61 $5.36 $18.07 0.3 1.0 3.3

Total (Small Game) 19,315.0 $1.61 $5.36 $18.07 31.0 103.0 349.0

Northern pike 30.0 $1.98 $4.10 $8.53 0.1 0.1 0.3

Sauger 7,809.0 $1.98 $4.10 $8.53 15.6 32.0 66.6

Walleye 13,152.0 $1.98 $4.10 $8.53 26.3 53.9 112.2

Total (Walleye/Pike) 20,991.0 $1.98 $4.10 $8.53 42.0 86.0 179.0

Total (Unidentified) 2,486,184.0 $1.08 $2.23 $4.60 2,696.0 5,547.0 11,437.0

Total (Undiscounted) 4,321,037.0 . . . 6,194.0 12,880.0 26,933.0

Total (3% discount rate) . . . . 5,071.0 10,545.0 22,049.0

Total (7% discount rate) . . . . 4,626.0 9,619.0 20,115.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-30 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-33: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 2 (I Everywhere and E for Facilities > 125 MGD) in the Inland Region, by 

Species (2009$) 

5th Mean 95th 5th Mean 95th

Smallmouth bass 157,772.0 $4.28 $9.01 $19.08 676.0 1,421.9 3,009.7

White bass 1,469,625.0 $4.28 $9.01 $19.08 6,297.0 13,245.1 28,035.3

Total (Bass) 1,627,397.0 $4.28 $9.01 $19.08 6,973.0 14,667.0 31,045.0

Whitefish 1,977.0 $1.52 $2.83 $5.29 3.0 6.0 10.0

Total (Other Trout) 1,977.0 $1.52 $2.83 $5.29 3.0 6.0 10.0

Black bullhead 29,849.0 $0.53 $1.06 $2.10 15.8 31.5 62.8

Black crappie 121,385.0 $0.53 $1.06 $2.10 64.1 128.3 255.3

Bluegill 413,894.0 $0.53 $1.06 $2.10 218.7 437.3 870.6

Brown bullhead 12,951.0 $0.53 $1.06 $2.10 6.8 13.7 27.2

Bullhead 4,984.0 $0.53 $1.06 $2.10 2.6 5.3 10.5

Channel catfish 401,691.0 $0.53 $1.06 $2.10 212.2 424.4 844.9

Crappie 320,377.0 $0.53 $1.06 $2.10 169.3 338.5 673.9

Menhaden 298.0 $0.53 $1.06 $2.10 0.2 0.3 0.6

Rainbow smelt 8,104.0 $0.53 $1.06 $2.10 4.3 8.6 17.0

Smelts 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Sunfish 1,269,826.0 $0.53 $1.06 $2.10 670.9 1,341.7 2,671.0

White Perch 5,204.0 $0.53 $1.06 $2.10 2.7 5.5 10.9

Yellow perch 564,857.0 $0.53 $1.06 $2.10 298.4 596.8 1,188.1

Total (Panfish) 3,153,418.0 $0.53 $1.06 $2.10 1,666.0 3,332.0 6,633.0

Salmon 5.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

Total (Salmon) 5.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

American shad 2,968.0 $1.61 $5.36 $18.07 4.8 15.9 53.7

Striped bass 19,136.0 $1.61 $5.36 $18.07 30.9 102.4 346.1

Sturgeon 1,450.0 $1.61 $5.36 $18.07 2.3 7.8 26.2

Total (Small Game) 23,554.0 $1.61 $5.36 $18.07 38.0 126.0 426.0

Northern pike 35.0 $1.98 $4.10 $8.53 0.1 0.1 0.3

Sauger 148,695.0 $1.98 $4.10 $8.53 294.6 609.9 1,267.7

Walleye 173,822.0 $1.98 $4.10 $8.53 344.4 713.0 1,482.0

Total (Walleye/Pike) 322,552.0 $1.98 $4.10 $8.53 639.0 1,323.0 2,750.0

Total (Unidentified) 5,932,467.0 $1.08 $2.23 $4.60 6,433.0 13,236.0 27,290.0

Total (Undiscounted) 11,061,370.0 . . . 15,751.0 32,690.0 68,154.0

Total (3% discount rate) . . . . 9,578.0 19,879.0 41,449.0

Total (7% discount rate) . . . . 7,361.0 15,277.0 31,856.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-31 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-34: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 3 (I&E Mortality Everywhere) in the Inland Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Smallmouth bass 164,627.0 $4.28 $9.01 $19.08 705.4 1,483.6 3,140.5

White bass 1,509,996.0 $4.28 $9.01 $19.08 6,469.6 13,609.0 28,805.5

Total (Bass) 1,674,624.0 $4.28 $9.01 $19.08 7,175.0 15,092.0 31,946.0

Whitefish 1,999.0 $1.52 $2.83 $5.29 3.0 6.0 11.0

Total (Other Trout) 1,999.0 $1.52 $2.83 $5.29 3.0 6.0 11.0

Black bullhead 30,167.0 $0.53 $1.06 $2.10 15.9 31.9 63.5

Black crappie 126,378.0 $0.53 $1.06 $2.10 66.8 133.6 265.8

Bluegill 418,926.0 $0.53 $1.06 $2.10 221.4 442.8 881.2

Brown bullhead 13,347.0 $0.53 $1.06 $2.10 7.1 14.1 28.1

Bullhead 5,077.0 $0.53 $1.06 $2.10 2.7 5.4 10.7

Channel catfish 410,600.0 $0.53 $1.06 $2.10 217.0 434.0 863.7

Crappie 334,101.0 $0.53 $1.06 $2.10 176.6 353.1 702.7

Menhaden 300.0 $0.53 $1.06 $2.10 0.2 0.3 0.6

Rainbow smelt 8,347.0 $0.53 $1.06 $2.10 4.4 8.8 17.6

Smelts 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Sunfish 1,320,111.0 $0.53 $1.06 $2.10 697.6 1,395.3 2,776.7

White Perch 5,273.0 $0.53 $1.06 $2.10 2.8 5.6 11.1

Yellow perch 578,320.0 $0.53 $1.06 $2.10 305.6 611.2 1,216.4

Total (Panfish) 3,250,948.0 $0.53 $1.06 $2.10 1,718.0 3,436.0 6,838.0

Salmon 5.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

Total (Salmon) 5.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

American shad 2,997.0 $1.61 $5.36 $18.07 4.8 16.1 54.1

Striped bass 19,322.0 $1.61 $5.36 $18.07 30.8 103.8 348.7

Sturgeon 1,509.0 $1.61 $5.36 $18.07 2.4 8.1 27.2

Total (Small Game) 23,828.0 $1.61 $5.36 $18.07 38.0 128.0 430.0

Northern pike 35.0 $1.98 $4.10 $8.53 0.1 0.1 0.3

Sauger 155,207.0 $1.98 $4.10 $8.53 307.2 637.0 1,323.3

Walleye 181,266.0 $1.98 $4.10 $8.53 358.8 743.9 1,545.4

Total (Walleye/Pike) 336,508.0 $1.98 $4.10 $8.53 666.0 1,381.0 2,869.0

Total (Unidentified) 6,101,138.0 $1.08 $2.23 $4.60 6,616.0 13,612.0 28,066.0

Total (Undiscounted) 11,389,049.0 . . . 16,216.0 33,654.0 70,160.0

Total (3% discount rate) . . . . 9,966.0 20,684.0 43,122.0

Total (7% discount rate) . . . . 7,592.0 15,755.0 32,847.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 I-32 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table I-35: Recreational Fishing Benefits from Reducing I&E Mortality Losses at In-scope 

Facilities Under Option 4 (I for Facilities > 50 MGD) in the Inland Region, by Species (2009$) 

5th Mean 95th 5th Mean 95th

Smallmouth bass 9,339.0 $4.28 $9.01 $19.08 40.0 84.2 178.2

White bass 633,751.0 $4.28 $9.01 $19.08 2,715.0 5,711.7 12,089.8

Total (Bass) 643,090.0 $4.28 $9.01 $19.08 2,755.0 5,796.0 12,268.0

Whitefish 1,602.0 $1.52 $2.83 $5.29 2.0 5.0 8.0

Total (Other Trout) 1,602.0 $1.52 $2.83 $5.29 2.0 5.0 8.0

Black bullhead 24,562.0 $0.53 $1.06 $2.10 13.0 26.0 51.7

Black crappie 13,727.0 $0.53 $1.06 $2.10 7.2 14.5 28.9

Bluegill 326,002.0 $0.53 $1.06 $2.10 172.1 344.6 685.6

Brown bullhead 4,655.0 $0.53 $1.06 $2.10 2.5 4.9 9.8

Bullhead 3,165.0 $0.53 $1.06 $2.10 1.7 3.3 6.7

Channel catfish 222,702.0 $0.53 $1.06 $2.10 117.6 235.4 468.3

Crappie 23,555.0 $0.53 $1.06 $2.10 12.4 24.9 49.5

Menhaden 251.0 $0.53 $1.06 $2.10 0.1 0.3 0.5

Rainbow smelt 3,021.0 $0.53 $1.06 $2.10 1.6 3.2 6.4

Smelts 1.0 $0.53 $1.06 $2.10 0.0 0.0 0.0

Sunfish 189,046.0 $0.53 $1.06 $2.10 99.8 199.8 397.6

White Perch 3,967.0 $0.53 $1.06 $2.10 2.1 4.2 8.3

Yellow perch 291,387.0 $0.53 $1.06 $2.10 153.9 308.0 612.8

Total (Panfish) 1,106,041.0 $0.53 $1.06 $2.10 584.0 1,169.0 2,326.0

Salmon 4.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

Total (Salmon) 4.0 $8.16 $13.27 $21.61 0.0 0.0 0.0

American shad 2,506.0 $1.61 $5.36 $18.07 4.0 13.4 45.2

Striped bass 16,158.0 $1.61 $5.36 $18.07 25.7 86.6 291.6

Sturgeon 179.0 $1.61 $5.36 $18.07 0.3 1.0 3.2

Total (Small Game) 18,843.0 $1.61 $5.36 $18.07 30.0 101.0 340.0

Northern pike 29.0 $1.98 $4.10 $8.53 0.1 0.1 0.2

Sauger 7,619.0 $1.98 $4.10 $8.53 15.3 31.3 65.1

Walleye 12,831.0 $1.98 $4.10 $8.53 25.7 52.6 109.6

Total (Walleye/Pike) 20,479.0 $1.98 $4.10 $8.53 41.0 84.0 175.0

Total (Unidentified) 2,425,487.0 $1.08 $2.23 $4.60 2,630.0 5,411.0 11,157.0

Total (Undiscounted) 4,215,546.0 . . . 6,043.0 12,566.0 26,275.0

Total (3% discount rate) . . . . 4,947.0 10,287.0 21,511.0

Total (7% discount rate) . . . . 4,513.0 9,384.0 19,623.0

Species

Annual Increase in 

Recreational 

Harvest

(harvestable adult 

fish)

Value per Fish

Annual Benefits from Increase in 

Recreational Harvest

(2009$, thousands)
March 28, 2011 J-1 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

J

Appendix J: Methods Used in the Habitat Based Methodology for 

Estimating Nonuse Values 

J.1 Equations for estimating nonuse values using a habitat based 

methodology 

Equation J-1: estimating lost production from I&E mortality on an annual basis. 

Productivity loss due to I&E mortality is calculated as: 

i

n

i

k

j

SPx tot  Li j x Ci j  Mi  DM   1 1

, , , , Equation J-1 

where: 

 SPx,tot is the estimated loss in regional production for all I&E mortality species under regulatory 

option x, measured in kg dry mass per year. 

 Li,x is the number of individuals of species i (with n species in the region) at life history stage j

(with k life history stages) lost to I&E mortality under regulatory option x. Measured in organisms 

per year. 

 Ci,j is the ratio used to convert losses of species i and life history stage j into age-1 equivalents. 

 Mi is the mass of an individual of species i at age 1. Measured in kg. 

 DMi is the ratio of dry mass to wet mass for species i.

Equation J-2: Estimating habitat-based fish production 

The calculation of secondary productivity per acre (SPrest) is as follows: 

1 2 3 SPrest  PP(1 E)TC TC TC Equation J-2

where: 

 PP is primary productivity per acre of restoration 

 E is the rate of productivity export, the portion of primary productivity excluded from transfer to 

higher trophic levels 

 TC1 the trophic conversion efficiency from primary productivity to detritus 

 TC2 the trophic conversion efficiency from detritus to first level consumers 

 TC3 the trophic conversion efficiency from first level consumers to second level consumers 

B1 
March 28, 2011 J-2 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Equation J-3: Estimating habitat-based fish production 

The number of habitat acres (A) estimated to generate annual productivity equivalent to reduction in I&E 

mortality achieved by regulatory option x is calculated for each region as: 

rest

n

i

Ax SPi x  SP



 



  1

, Equation J-3

where: 

 Ax is the number needed to achieve ecological equivalence with option x

 SPi,x is the total increase in secondary productivity per year for species i under option x 

 SPrest is the total secondary productivity gained per year per acre or restoration 
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

J.2 Estimated Primary Productivity and Carbon Export in Marine and Aquatic Habitats 

Table J-1: Summary of Aboveground Primary Productivity (measured in kg dry mass acre-1 yr-1) Species Study Region(s) 

Sample 

Size Min Max Mean Sources 

Eelgrass Zostera marina

North Atlantic, MidAtlantic, and South Atlantic 

6 934 7,561 3,745 Beal et al. (2004), Nixon and Oviatt (1972), M

Rizzo and Wetzel (1985), Bach et al. (1986) 

Smooth cordgrass Spartina alterniflora

North Atlantic and MidAtlantic 10 1,416 6,520 3,332 Reimold and Linthurst (1977)*, Valiela, Teal

(1972)*, Walton (1972)*, Cahoon (1975)*, M(1976)* 

Smooth cordgrass Spartina alterniflora

South Atlantic and Gulf of Mexico 

13 1,331 16,148 6,372 Stroud and Cooper (1968)*, Marshall (1970)*

(1972)*, de la Cruz (1974)*, Kirby (1972)*, K

Turtle grass Thalassia testudinum

Gulf of Mexico 5 1,329 3,570 2,417 Tomasko et al. (1996), Kaldy and Dunton (20

Giant Kelp Macrocystis pyrifera

California 4 1,472 11,344 7,312 Dayton (1985), Rassweiler (2008) 

Broadleaf cattail Typha latifolia

Great Lakes and Inland 14 2,024 12,971 6,199 Gustafson (1976)*, Penko and Pratt (1986), G

Mitsch et al (2002), Smith and Kadlec (1985)van der Valk and Davis (1978)*, Keefe (1972(1975)*, Johnson (1970)* 

Sample size is the number of estimates included in calculation of the mean value. The sample size differs from the number of sources because several studies provide mu

different sites. Values reported in units of g C m-2 day-1 were converted using specifes-specific factors. 

 Eelgrass – carbon accounts for 38% of dry weight biomass (Thom 1988).  Smooth cordgrass - carbon accounts for 45% of dry weight biomass (French McCay and Rowe 2003; Gallagher 1975).  Turtle grass - carbon accounts for 36.4% of dry weight biomass (Fourqurean and Zieman 2002).  Kelp – carbon accounts for 33% of dry weight biomass (Dayton 1985).  Broadleaf cattail - carbon accounts for 40.2% of dry weight biomass (Esteves et al. 2008).* Indicates values were taken from USEPA (1980).
March 28, 2011 J-4 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table J-2: Estimates of Carbon Export from Salt Marshes 

Location 

C Export 

(g C m-2 yr-1) 

ANPP 

(g C m-2 yr-1) 

Export as 

% of NPP Dominant Species Source 

Cape Cod, MA 3 67.5 4.4% Spartina alternaflora Howes et al (1985)1

Flax Pond, NY -53 372 -14.2% Spartina alterniflora Woodwell et al (1977) 

Canary Creek, DE 159 252 63.1% Spartina alterniflora Roman & Daiber (1989) 

Ware Creek, VA 115 599 19.2% Spartina alterniflora Axelrad et al. (1976) 

Carter Creek, VA 142 599 23.7% Spartina alterniflora Axelrad et al. (1976) 

Beaufort, NC 40 548 7.3% Spartina alterniflora Bach et al. (1986)* 

Beaufort, NC 124 568 21.9% Spartina alterniflora Bach et al. (1986)* 

Beaufort, NC 32 837 3.9% Spartina alterniflora Bach et al. (1986)* 

Bly Creek, SC 252 1080 23.3% Spartina alterniflora Williams et al. (1992)* 

Bly Creek, SC 493 1080 45.6% Spartina alterniflora Williams et al. (1992)* 

North Inlet, SC 456 1059 43.1% Spartina alterniflora Dame et al (1986) 

Bly Creek, SC 242 1028 23.5% Spartina alterniflora Dame et al. (1991) 

Duplin River, GA 1090 2025 12.8-53.8% Spartina alterniflora Wang and Cai (2004) 

Sapelo Island, GA 393 878 44.8% Spartina alterniflora Teal (1962) 

Sapelo Island, GA 365 992 36.8% Spartina alterniflora Teal (1962)* 2

Barataria Basin, LA 224 600 37.3% 

Panicum hemitomo 

Eleocharis sp Feijtel et al (1985) 

Barataria Basin, LA 296 550 53.8% 

Spartina patens 

Distichlis spicata Feijtel et al (1985) 

Barataria Basin, LA 183 860 21.3% Spartina alterniflora Feijtel et al (1985) 

LA 226 1147 19.7% Day et al. (1973)* 

LA 47 926 5.1% Hopkinson et al. (1978)* 

LA 55 1267 4.3% Hopkinson et al. (1978)* 

LA 161 599 26.8% Hopkinson et al. (1978)* 

LA 821 2416 34.0% Hopkinson et al. (1978)* 

LA 80 540 14.9% Hopkinson et al. (1978)* 

LA 26 518 5.0% White et al. (1978)* 

Coon Creek, TX 25 559-900 2.7-4.5% 

Spartina patens 

Distichlis spicata Borey et al. (1983) 

EMS-Dollard Marsh 

 Netherlands -125 500 -25.00% 

Puccinellietum maritime

Spartina anglica Dankers et al (1984) 

Kariega Marsh, 

 South Africa 16 200-300 5.0-8.0% 

Spartina perennis, 

Chenolea diffusa Taylor & Allanson (1995) 

Hong Kong 0 880 0.0% Phragmites communis Lee (1990)* 

Unknown 58 105 55.8% McLusky (1981)* 

Unknown 51 181 28.2% McLusky (1981)* 

Unknown 142 1080 13.2% Schlesinger (1997)* 

Unknown 431 1080 39.9% Schlesinger (1997)* 

Unknown 117 1080 10.8% Schlesinger (1997)* 

Unknown 99 1080 9.1% Schlesinger (1997)* 

Unknown 164 1080 15.2% Schlesinger (1997)* 

* Indicates values taken from Cebrian (2002). 1

 Carbon export for Howes et al. (1985) was calculated based on annual sediment budget in mol m-2 yr-1. 2

 These values were calculated directly based on Teal (1962) and differ from values included in the meta-data of Cebrian (2002).

J.3 Regional Determination of Preferred Habitat 

In the North Atlantic region, species accounting for the greatest proportion of I&E mortality [rock gunnel 

(42% of regional I&E mortality), winter founder (11%), radiated shanny (7%), cunner (7%), American 

sand lance (7%) and seaboard goby (7%)] are generally found in estuarine, sandy or nearshore rocky reef 

areas, and are not strongly associated with coastal wetlands (Fishbase 2009). Therefore, eelgrass was 

selected for scaling I&E mortality losses in the North Atlantic. 
March 28, 2011 J-5 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

In the Mid-Atlantic region, species with the greatest I&E mortality by mass [bay anchovy (65% of the 

regional I&E mortality losses), blue crab (10%), Atlantic menhaden (5%) and spot (4%)] are commonly 

found in tidal salt marshes (Fishbase 2009). Consequently, the preferred habitat for restoration projects is 

smooth cordgrass, the dominant foundation species in Atlantic salt marshes. 

Similarly, in the South Atlantic, important I&E mortality species [bay anchovy (71%), forage shrimp 

(13%), gobies (4%) and other forage fish (4%)] are associated with salt marshes dominated by cordgrass. 

Thus, saltmarsh is the preferred habitat choice for this region. 

In the Gulf Coast region, there is less dominance by a single species in I&E mortality results [pink shrimp 

(30%) blue crab (15%) bay anchovy (14%) and other forage fish (11%)], and there is no strong ecological 

argument for preferring turtle grass or saltmarsh. Consequently, due to its higher productivity, smooth 

cordgrass was chosen as the preferred habitat type for regional restoration calculations. 

In California, the preferred habitat choice is the highly productive giant kelp (M. pyrifera), known to be a 

nursery habitat for many fish species. 

In the Great Lakes and Inland regions, the freshwater macrophyte broadleaf cattail (T. latifolia) was 

selected for restoration calculations. 
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

J.4 Willingness to Pay for Fish Production and Other Aquatic Habitat Goods and Services 

Table J-3: Studies Used to Estimate WTP Values for Fish Production Services and Habitat Study 

Survey 

Year 

Location 

(State) Habitat 

WTP acre-1 yr-1(2009$)1

Population (Sample Size) Change Valued Sur

Peconic Estuary Study (Johnston et al. 2002a; Johnston et al. 2001; Mazzotta 1996; Opaluch et al. 1995; Opaluch et al. 1998) 

1995 New York Eelgrass and 

Salt marsh 

Eelgrass - $0.07608 Saltmarsh- $0.0672 

East End Long Island Households (968 completed surveys) 

Eelgrass presented at current level of 9,000 acres, “no action” level of 8,000 acres, and with restoration level of 11,000 acres.Wetlands presented at their current level of 16,000 acres, “no action” level of 12,000 acres, and with restoration level of 17,500 acres. 

Usechorelaresinatureso

Bauer, Cyr, and Swallow (2004) 

2004 Rhode Island Salt marsh $0.0190 Rhode Island 

Households (320 inperson surveys administered) 

Survey level included four levels of wetland preservation or restoration; 33, 64, 101, or 135 acres. One-time payment converted to annual value assuming 3% discount rate. 

Statdesprefmitdeteto trattr

pub

end

De Zoysa (1995) 1994 Ohio Freshwater 

wetlands 

$0.0299 Residents of 

Maumee, Ohio (476 responses) 

Wetlands program description indicated that the proposed program would restore and protect 3,000 acres of wetlands from a baseline of 10,000 existing acres that were declining. 

The valuversof wresoprogrouwetcom

Bishop et al. (2000) 1999 Wisconsin Freshwater 

wetlands 

$0.00125 Households within a 

ten county area around Green Bay (470 responses) 

Restoration level ranging up to a 11,600 acre increase in wetlands within five miles of Green Bay, WI to support birds, fish, and other wildlife equivalent to a 20% increase from the 58,000 baseline acres. WTP reported here is the mid-point of marginal 

values for 5% and 20% changes.

Tot(TVsupconLow

NR
March 28, 2011 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table J-3: Studies Used to Estimate WTP Values for Fish Production Services and Habitat Study 

Survey 

Year 

Location 

(State) Habitat 

WTP acre-1 yr-1(2009$)1

Population (Sample Size) Change Valued Sur

Mullarky (1997; 1999) 1994 Wisconsin Freshwater 

wetlands 

$0.00822 Wisconsin residents 

(239 complete surveys) 

Case study of a highway expansion project in Northwest Wisconsin which would require filling of 110 acres of wetlands. One-time payment converted to annual value assuming 3% discount rate. 

ConWiswoucreaisolhighis b“scoinfobein

Blomquist and Whitehead (1998) 

1990 Kentucky Freshwater 

wetlands 

$0.0056 Kentucky residents 

(379 responses) 

WTP to purchase and manage 500 acres which if not purchased would be mined and reclaimed after ten years. 

Conresufour WTFlat wetcon

Whitehead and Blomquist (1991) 

1989 Kentucky Freshwater 

wetlands 

$0.0037 Kentucky residents 

(215 responses) 

WTP for purchase and management of the approximately 5,000 acres Clear Creek wetland which would be mined if not purchased. 

Conwith presinfoenvSmBlo(19

1 WTP values were converted to 2009$ based on the Consumer Price Index (CPI). 2 Mullarky (1997; 1999) present multiple WTP estimates based on the survey group used for the estimate (“base group” or “scope group”) and cert

the polychotomous choice format. The reported value is based for the “scope group”, which was not informed regarding mitigation, and the highesresponses. 
March 28, 2011 J-8 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

J.5 Narragansett Bay Wetland Restoration Study 

J.5.1 Survey Development and Data Collection 

EPA designed a survey instrument, entitled Rhode Island Salt Marsh Restoration: 2001 Survey of Rhode 

Island Residents to assess tradeoffs among attributes of salt marsh restoration plans. Development of this 

survey required more than 16 months and involved extensive background research, interviews with 

experts in salt marsh ecology and restoration, and 16 focus groups with more than 100 Rhode Island 

residents. Numerous pretests, including verbal protocol analysis (Schkade and Payne 1994) ensured that 

the survey language and format would be easily understood by respondents, and that respondents would 

have a common understanding of survey scenarios (cf. Johnston et al. 1995). 

Johnston et al. (2002b) chose attributes distinguishing restoration plans based on background research, 

expert interviews, and focus groups. The authors tailored these attributes to reflect primary salt marsh 

services in the northeast United States that would be influenced by restoration activities, and 

characterized each wetland by the size of the marsh, together with effects of restoration, on (1) habitat for 

birds, (2) habitat for fish, (3) habitat for shellfish, (4) potential to control mosquito nuisance, (5) 

recreational access, and (6) household cost.64 Based on the results of focus groups and expert interviews, 

habitat and mosquito control services were presented from a standardized, statewide perspective. For 

example, improvements to fish habitat were characterized as “ecological improvements to RI fish 

populations...[resulting from a particular restoration project]...as judged by wetlands experts, compared 

to all other potential salt marsh restoration projects in Rhode Island.” 

Following the general approach of Johnston et al. (1999), the conjoint (or multi-attribute choice) survey 

presented respondents with four sets of discrete choices, each involving two alternative, multi-attribute 

restoration plans. The authors used fractional factorial design to construct a range of survey questions 

with an orthogonal array of attribute levels, resulting in 80 contingent choice questions divided among 20 

unique booklets. Attributes distinguishing plans were selected based on background research, expert 

interviews, and focus groups. All attributes were free to vary over their full range for both restoration 

plans presented in each question, with no imposed ordering of attribute levels between the two plans. 

Based on these attributes, respondents chose one of the two plans, or chose “Neither Plan.” 

The survey was conducted from September through December, 2001. Respondents were intercepted in 

person at Rhode Island Department of Motor Vehicle offices, public libraries, and other survey sites. 

Interviewers did not tell respondents that the survey concerned salt marsh restoration. Rather, 

interviewers asked respondents to participate in an important survey regarding “environmental issues in 

Rhode Island,” to reduce the potential for topic-related nonresponse. Following the general approach of 

Johnston et al. (1999), the survey presented respondents with four sets of discrete choices, each involving 

two alternative, multi-attribute restoration plans. Attributes included in the survey included the size of salt 

marsh restoration, and the importance of (1) habitat for birds, (2) habitat for fish, (3) habitat for shellfish, 

 

64Additional, non-habitat services that may be provided by salt water wetlands include, among others, nutrient transformation, 

storm buffering, and coastal erosion control. Interviews with experts on salt water wetland functions in New England (and 

Rhode Island in particular) indicated, however, that wetland restoration would provide negligible impacts on these nonhabitat functions in the majority of cases. They based this assessment on the small size of most New England coastal 

wetlands, and on the fact that restoration may not always increase substantially the ability of a wetland to provide such 

functions as storm buffering or erosion control. Based on this advice, the survey focused mainly on wetland habitat 

functions. 
March 28, 2011 J-9 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

(4) the potential for mosquito control, (5) recreational access, and (6) household cost. Based on variations 

in the presented attributes of conservation plans, respondents either chose either one of two plans 

presented, or chose “Neither Plan.” In total, interviewers collected 661 completed surveys, providing 

complete and usable responses to 2,341 individual contingent choice questions (89% of a potential 2,644). 

J.5.2 Results 

Table J-4 presents variables incorporated in the analysis of salt marsh restoration choices. These variables 

include: (1) a dummy variable identifying the “neither” option, (2) quadratic interactions between this 

dummy and certain demographic characteristics, and (3) variables for the restored salt marsh attributes. 

Mean values for salt marsh attributes (Table 9-5) indicate the mean values of these attributes over all 

completed surveys included in the analysis. The final column of the table calculates these mean values 

with "neither plan" data rows excluded. (As noted above, each wetland restoration choice included the 

option of choosing neither plan. In the multinomial logit data, these options are presented as a "plan" with 

zeros for all wetland attributes.) 

Table J-5 presents results for a conditional logit model of survey data. The model is significant at p 

<0.0001 (-2LnL P2=1157.56, df = 13); all individual parameter estimates are significant at p <0.05, with 

most significant at p <0.01. 

The signs of parameter estimates correspond with prior expectations derived from focus groups, where 

prior expectations exist. Respondents favor plans that restore larger salt marshes; improve bird, fish, and 

shellfish habitat; control mosquitoes; provide public access; and result in lower costs to the household. 

Comparing preferences for habitat improvements and mosquito control (all measured on a ten-point 

scale), respondents placed the greatest weight on mosquito control, followed by habitat improvements for 

shellfish, fish, and birds, respectively. The likelihood of rejecting restoration outright (i.e., choosing 

neither plan) was smaller for members of environmental organizations, and larger for members of 

taxpayers organizations, lower income individuals, and more highly educated individuals (Johnston et al. 

2002b). Changes in education and income do not influence the marginal utility of fish and shellfish 

habitat, or that of other wetland attributes. 

Results of the conjoint analysis (i.e., the public survey results) presented by Johnston et al. (2002b) allow 

policy makers to rank restoration projects based on their estimated influence on residents’ welfare. These 

results also allow assessment of residents’ willingness to trade off elements of wetland restoration plans, 

or WTP for particular wetland attributes. Finally, for any specified restoration plan, provided that 

incremental gains or losses in wetland services are known, it allows the calculation of the proportion of 

the total gain in social value attributable to a particular service (e.g., fish habitat). 

To estimate the proportion of value associated with fish habitat, in a representative, conservative scenario, 

EPA began with the average wetland restoration scenario considered by the Rhode Island survey sample. 

The mean values of wetland attributes presented to survey respondents provide the most representative set 

of results from which value proportions may be estimated, and forecast the value proportions that would 

result from an average survey respondent confronted with an average wetland restoration scenario, as 

characterized by the Rhode Island Salt Marsh Restoration Survey data. Excluding all “Neither Plan” 

scenarios, which offered zero restoration, Table J-4 summarizes the mean values for services considered 

by the Rhode Island sample. 
March 28, 2011 J-10 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table J-4: Definitions and Summary Statistics for Model Variables for Narragansett Bay Wetland 

Restoration Study 

Variable 

Name Description 

Whole Sample 

Mean (Std. Dev.) 

Mean, Excluding 

“Neither Plan” 

Scenariosa

Neither Neither=1 identifies “neither plan” options 0.333 

(0.471) 

0.000 

Environ Dummy variable identifying respondents with membership in 

environmental organizations 

0.190 

(0.392) 

0.190 

Taxgrp Dummy variable identifying respondents with membership in taxpayer 

associations 

0.023 

(0.151) 

0.023 

Loincome Dummy variable identifying respondents with household income less than 

$35,000/year 

0.245) 

(0.430) 

0.245 

Hiedu Dummy variable identifying respondents with greater than a four-year 

college degree 

0.182 

(0.386) 

0.182 

Birds Ecological improvement to statewide bird populations resulting from 

specified salt marsh restoration plan, compared to all other potential salt 

marsh restoration plans in Rhode Island (0-10 scale) 

2.761 

(2.607) 

4.141 

Fish Ecological improvement to statewide fish populations resulting from 

specified salt marsh restoration plan, compared to all other potential salt 

marsh restoration plans in Rhode Island (0-10 scale) 

2.908 

(2.653) 

4.361 

Shellfish Ecological improvement to statewide shellfish populations resulting from 

specified salt marsh restoration plan, compared to all other potential salt 

marsh restoration plans in Rhode Island (0-10 scale) 

2.907 

(2.652) 

4.362 

Mosquito Increased ability to control statewide mosquito nuisance resulting from 

specified salt marsh restoration plan, compared to all other potential salt 

marsh restoration plans in Rhode Island (0-10 scale) 

2.908 

(2.651) 

4.362 

Size Size of restored salt marsh (minimum 3 acres; maximum 12 acres) 4.889 

(4.397) 

7.334 

Pro-access Dummy variable indicating that respondent feels that access to salt 

marshes should be “somewhat limited” or “unlimited” 

0.837 

(0.370) 

0.837 

Con-access Dummy variable indicating that respondent feels that access to salt 

marshes should be “severely limited” or “prohibited” 

0.227 

(0.419) 

0.163 

Platform Dummy variable indicating that restoration provides “viewing platforms” 

but no “trails” 

0.222 

(0.415) 

0.340 

Both Dummy variable indicating that restoration provides both “viewing 

platforms” and “trails” 

0.222 

(0.415) 

0.332 

Cost Annual cost of restoration plan in increased taxes (minimum $0; maximum 

$200) 

63.169 

(70.782) 

94.754 

a Each wetland restoration choice included the option of choosing neither plan. In the multinomial logit data, this option is presented as a “plan” with 

zeros for all wetland attributes. The final column of the table calculates means with the “neither plan” zeros excluded.

Although mean values are used for most attributes (i.e., wetland attributes or services considered by 

survey respondents in choice scenarios), changes in certain attributes are set to zero to correspond more 

closely with the policy scenario and with the Peconic study (because the purpose of this analysis is to 

assess the proportion of the Peconic wetland values that may reasonably be attributed to fish habitat 

services). For example, because the Peconic study survey did not specify or discuss the provision of 

viewing platforms or trails at preserved wetlands, EPA assumed that survey respondents to the Peconic 

study did not consider such provisions when making survey choices. Accordingly, in calculating value 

proportions in this analysis using the Rhode Island data, EPA assumed that viewing platforms and trails 

are not provided. 

EPA also assumed that any wetland created or restored to provide fish habitat will likely not provide a 

great degree of additional mosquito control, because a large proportion of existing salt marshes have 
March 28, 2011 J-11 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

already been modified to minimize mosquito production.65 For this reason, modern marsh restoration 

typically does not provide a significant increase in mosquito control. Rather, it often replaces older, more 

detrimental (to marsh function and habitat) forms of mosquito control with Open Marsh Water 

Management (OMWM), in which open water and natural fish predation is used to control mosquito 

nuisance (Kennish 2001). OMWM has not been an “unqualified success” at eliminating the mosquito 

nuisance (New York Conservationist 1997). Accordingly, for many salt marshes, the positive net effect of 

restoration on mosquito nuisance, if any, is often minimal. To generate the most conservative estimates, 

however, and in recognition of the fact that some salt marsh restoration projects may provide significant 

mosquito control, EPA also estimated value proportions assuming that significant additional mosquito 

control is provided. For all other wetland attributes included in the Rhode Island survey, EPA used the 

mean values shown in the final column of Table J-4. 

Estimation of value proportions is based on the estimated utility function v(.), which specifies the utility 

provided by a wetland restoration plan as a function of the attributes or services provided by that plan 

(Johnston et al. 2002b). That is, following the standard random utility model of Hanemann (1984), the 

underlying model specifies respondents’ choices using the conditional logit specification, in which the 

probability (Pi) of choosing any wetland restoration plan i (plan A, plan B, or neither plan) over the two 

remaining options (j or k) is given by: 

exp[ ( )] exp[ ( )] exp[ ( )]

exp[ ( )]

    

 

i j k

i

i

v v v

v P Equation J-4 

where v(.) represents the relative benefits or utility resulting from each restoration option, including the 

“neither plan” option. The function v(.) is typically estimated as a simple function of program attributes 

(in this case wetland restoration); in practice linear, functional forms are often used (Johnston et al. 

2002b). 

From the assumptions and model noted above, the attribute definitions given in Table J-4, and the model 

results of Table J-5, the estimated utility function used to calculate value proportions is specified as 

 0.1611( ) 0.0510( )

(.) 0.1191( ) 0.1465( ) 0.1587( )

mosquito size

v birds fish shellfish



   

 Equation J-5 

If mosquito control is not provided, then mosquito=0. Given this linear specification, the proportion of 

wetland restoration value provided by the gain in fish habitat services is given by 

( )

( ) ( ) 0



   

fish

fish fish

v

v v

 Equation J-6 

where v(.)fish represents the value of v(.) with the gain in fish habitat services set to its mean value (as 

described above), and v(.)fish=0 represents the value of the function with the gain in fish habitat services 

set to zero. 

 

65The mosquito control variable was included in the survey in response to the strong concern of Rhode Island residents over the 

impact of restoration on mosquitoes and related illnesses for which mosquitoes are the primary vector. Wetlands experts 

indicated, however, that salt marsh restoration had limited impact on mosquito populations in most cases. 
March 28, 2011 J-12 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table J-5: Conditional Logit Results for Narragansett Bay Wetland 

restoration Study 

Parameter Estimate Std. Error z P>|z| 

Neither 1.157 0.193 5.98 0.0001 

Neither x Environ -1.182 0.223 -5.30 0.0001 

Neither x Tax 0.868 0.365 2.38 0.0170 

Neither x Loincome 0.310 0.144 2.16 0.0310 

Neither x Hiedu 0.415 0.169 2.46 0.0140 

Birds 0.119 0.015 7.78 0.0001 

Fish 0.147 0.016 9.36 0.0001

Shellfish 0.159 0.016 9.78 0.0001

Mosquito 0.161 0.016 9.95 0.0001 

Size 0.051 0.010 5.22 0.0001 

Pro-access x Platform 0.168 0.083 2.03 0.0420 

Pro-access x Both 0.431 0.084 5.11 0.0001 

Cost -0.007 0.001 -14.23 0.0001 

-2LnL P2 1157.56 Prob>P2 0.0001 

Table J-6 shows the resulting value proportions, in which EPA calculated the proportion of wetland 

restoration value associated with different wetland services based on mean values of wetland attributes 

presented to survey respondents, as discussed above. Analogous methods were used to assess value 

proportions associated with shellfish and other habitat services; Table J-6 shows these results for 

comparison. The table also illustrates the results of a sensitivity analysis in which EPA calculated 

analogous value proportions for wetland habitat services, but allow wetland size to vary. Wetland size 

was allowed to vary from its minimum value in the Rhode Island survey data (3 acres) to its maximum 

value (12 acres), while holding habitat service changes constant. EPA chose these size values to be 

representative of unrestored salt water wetlands currently existing in Narragansett Bay, which are 

typically quite small (i.e., less than five acres). The three estimates of acreage are therefore likely closer 

to the “average” Rhode Island wetland than estimates based on larger acreages. (In actual wetlands, 

changes in restored acres are typically correlated with larger gains in habitat services (Johnston et al. 

2002b). To illustrate even more conservative estimates, however, Table J-6 contains cases in which 

restored wetland size increases from the mean, without any resultant increase in habitat services.) 

Across scenarios the proportion of value associated with fish habitat ranges from 0.2035 to 0.3231, with a 

mean value over all scenarios of 0.2564 (Table J-6). Scenario 1a is perhaps the most representative 

scenario for estimating value proportions for two reasons: (1) restored wetlands are not expected to 

provide additional mosquito control and (2) other wetland attributes are set to their mean values. Its 

results are somewhat higher than those of scenario 3a, which represents the mean value over all scenarios 

presented. To be conservative (i.e. low) in its estimates, EPA used the proportion calculated in scenario 3a 

(0.2564) as an estimate of the proportion of total wetland restoration value attributable to gains in fish 

habitat services, given representative, mean values for other wetland services. 
March 28, 2011 J-13 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

Table J-6: Proportions of Restored Wetland Value Associate with Various Service 

Categories 

Restoration Scenario 

Percentage of Value Associated with Service: 

Fish Habitat Bird Habitat Shellfish 

Habitat 

Mosquito 

Control 

Otherb

1a: No additional mosquito 

control; mean values for all other 

attributes 

0.291 0.224 0.315 0.000 0.170 

1b: No additional mosquito 

control; mean values for habitat 

gains; Size=3 acres 

0.323 0.249 0.350 0.000 0.077 

1c: No additional mosquito 

control; mean values for habitat 

gains; size=12 acres 

0.262 0.202 0.284 0.000 0.251 

2a: Mosquito control at mean 

value; mean values for all other 

attributes 

0.220 0.170 0.239 0.242 0.129 

2b: Mosquito control at mean 

value; mean values for habitat 

gains; size=3 acres 

0.238 0.184 0.258 0.262 0.057 

2c: Mosquito control at mean 

value; mean values for habitat 

gains; size=12 acres 

0.204 0.157 0.220 0.224 0.195 

3a: Mean over all scenarios 0.256 0.198 0.278 0.121 0.147 

a Results assume that restoration does not provide viewing platforms or hiking trails. b Other services may include, among others, nutrient transformations, storm buffering, and coastal erosion control. 

Although these numbers are not directly comparable to other results found in the literature, they appear to 

be reasonable and conservative compared to similar proportions generated for freshwater habitats. For 

example, Schulze et al. (1995) estimate that between 32.98 percent and 33.44 percent of WTP for 

resource cleanup in the Clark Fork River Basin was associated with “aquatic resources and riparian 

habitat” (p. 5-13). 

EPA also considered directly the parametric results of Table J-5 for further support of the soundness of 

the proposed value proportions. Estimates presented in Table J-5 indicate that the parametric weights are 

similar among the dominant wetland services in Narragansett Bay (i.e., bird habitat services, fish habitat 

services, shellfish habitat services, and mosquito control). In other words, the parameter estimates are 

very similar among these four variables. This correspondence suggests that restoration providing similar 

scale improvements for each of these services should produce a roughly equivalent increment to utility. 

Given the four habitat services considered in the survey (including mosquito control), each service 

provides roughly 1/4 (or 25 percent) of the total marginal utility associated with the combination of 

habitat improvements and mosquito control. For wetlands that do not provide substantial access 

provisions (e.g., boardwalks) and that are of moderate or small size, it would be highly improbable for the 

proportion of value associated with fish habitat to fall significantly below the 25.64 percent 

approximation estimated here. 
March 28, 2011 J-14 

Environmental and Economic Benefits Analysis of the Proposed Section 316(b) Existing Facilities Regulation 

J.6 Determining the Affected Population and Estimating Aggregate Values 

Table J-7: Number of Households by State and Percentage of Regional Habitat Acres Assigned to 

Each State. 

State 

No. of 

Households California 

North 

Atlantic Mid-Atlantic

South 

Atlantic 

Gulf of 

Mexico Great Lakes Inland 

AL 1,836,096 - - - - - - 5.90% 

AR 1,132,706 - - - - - - 1.53% 

AZ 2,266,797 - - - - - - 0.21% 

CA 12,371,970 100.00% - - - - - <0.01% 

CO 1,891,368 - - - - - - 0.22% 

CT 1,365,529 - 29.83% - - - - 0.14% 

DC 268,559 - - - - - - <0.01% 

DE 329,246 - - 5.08% - - - 0.02% 

FL 7,252,011 - - - 70.27% 53.26% - 0.54% 

GA 3,472,892 - - - 2.66% - - 2.36% 

IA 1,248,977 - - - - - - 1.73% 

IL 4,821,525 - - - - - 3.76% 7.30% 

IN 2,501,050 - - - - - 11.63% 4.58% 

KS 1,120,251 - - - - - - 1.56% 

KY 1,695,340 - - - - - - 2.53% 

LA 1,595,221 - - - - 7.44% - 5.02% 

MA 2,533,224 - 49.80% - - - - 0.11% 

MD 2,138,174 - - 24.02% - - - 0.34% 

ME 561,927 - 3.54% - - - - 0.08% 

MI 3,977,292 - - - - - 35.46% 1.62% 

MN 2,095,360 - - - - - 1.27% 1.56% 

MO 2,373,024 - - - - - - 4.51% 

MS 1,106,531 - - - - 2.28% - 0.66% 

MT 383,318 - - - - - - 0.13% 

NC 3,562,025 - - - 19.12% - - 6.24% 

ND 285,857 - - - - - - 0.65% 

NE 719,904 - - - - - - 2.17% 

NH 518,506 - 12.92% - - - - 0.17% 

NJ 3,186,057 - - 22.20% - - - 0.08% 

NM 735,720 - - - - - - 0.03% 

NV 947,691 - - - - - - 0.05% 

NY 7,303,783 - - 31.93% - - 19.52% 1.85% 

OH 4,622,384 - - - - - 11.95% 4.92% 

OK 1,431,014 - - - - - - 1.36% 

OR 1,476,434 - - - - - - 0.04% 

PA 5,021,383 - - 0.17% - - 0.20% 4.77% 

RI 419,621 - 3.91% - - - - - 

SC 1,718,297 - - - 7.94% - - 4.36% 

SD 327,165 - - - - - - 0.01% 

TN 2,449,562 - - - - - - 6.81% 

TX 8,271,247 - - - - 37.02% - 17.89% 

UT 837,511 - - - - - - 0.03% 

VA 2,996,176 - - 16.60% - - - 1.32% 

VT 260,831 - - - - - - 0.23% 

WA 2,519,727 - - - - - - 0.18% 

WI 2,302,752 - - - - - 16.21% 1.23% 

WV 756,778 - - - - - - 2.80% 

WY 211,883 - - - - - - 0.16%