Standards for Living Organisms in Ships' 

Ballast Water Discharged in U.S. Waters 

36 CFR Part 151 and 46 CFR Part 162 

Docket No. USCG-2001-10486 

RIN 1625-AA32 

Final Rule 

Regulatory Analysis and Final Regulatory Flexibility 

Analysis 

March 2012 

Prepared by:

United States Coast Guard (USCG) 

Office of Standards Evaluation and Development 

Standards Evaluation and Analysis Division 

USCG Headquarters 

Washington, DC 

Additional contributions by: 

AMSEC, LLC 

Virginia Beach, VA 

Herbert Engineering Corp. (HEC) 

Alameda, CA 
 Contents 

Executive Summary ................................................................................................................ 10

1 Introduction .................................................................................................................... 23

1.1 Statement of Need ............................................................................................................. 23

1.2 Overview ........................................................................................................................... 23

1.2.a Comparison Between the NPRM RA and the FR RA ................................................... 25

1.3 Alternative Ballast Water Discharge Standards ................................................................ 27

1.4 Implementation Schedule .................................................................................................. 28

1.5 Regulatory Analysis .......................................................................................................... 28

2 Population Affected ....................................................................................................... 30

2.1 Overview of Data and Sources ......................................................................................... 30

2.2 Description of the Maritime Transportation Industry ....................................................... 32

2.3 Vessel Types and Ownership ............................................................................................ 33

2.4 Fleet Growth and Makeup .............................................................................................. 37

3 Ballast Water Management Costs .................................................................................. 39

3.1 Descriptions of the BWMS and Assessment of Meeting the IMO Standard .................... 42

3.2 Applicability of BWMS to Vessel Types ......................................................................... 45

3.3 Acquisition and Installation Costs .................................................................................... 45

3.5 Discussion ......................................................................................................................... 51

4 Ballast Water Management Systems Cost ..................................................................... 57

4.1 Calculation Approach for Costs of Ballast Water Discharge Standards........................... 57

4.2 Installation Costs of Ballast Water Management Systems ............................................... 61

4.3 Operating Costs of Ballast Water Management System ................................................... 62

4.4 Total Costs of Ballast Water Management Systems ......................................................... 64

4.5 Additional Sources of Uncertainties on the Costs Estimates ............................................ 65

4.6 Uncertainties Related to More Stringent Standards .......................................................... 66

5 Benefits from Reducing Invasions of Non-indigenous Species .................................... 69

5.1 Resources at Risk .............................................................................................................. 69

5.2 Economic Impacts of Past NIS ......................................................................................... 72

5.3 Benefits of Ballast Water Discharge Standards ................................................................ 74

5.4 Functional Benefits of the Ballast Water Standards ......................................................... 75

5.5 Annual Number of Invasions Due to Ballast Water Discharge ........................................ 76

5.6 Costs of Ballast Water Invasions ...................................................................................... 81

5.7 Benefits (Averted Costs) of Ballast Water Discharge Standards ...................................... 83

5.8 Potential Benefits Transfer ............................................................................................... 86

5.9 Sources of Uncertainties and Alternative Use of Risk-Based Decision-Making in 

Addressing Benefits ................................................................................................................ 87

6 Comparison of Costs and Benefits ................................................................................. 89

6.1 Comparison of Alternative Phase-In Schedules ............................................................... 91

6.1.a. FR Phase-In Schedule for Costs and Benefits............................................................... 91

6.2 Comparison of NPRM Alternatives .................................................................................. 94

7 Final Regulatory Flexibility Act Analysis ..................................................................... 95

7.1 Summary of the NPRM IRFA .......................................................................................... 95

7.3 Final Regulatory Flexibility Analysis ............................................................................... 96

8 References .................................................................................................................... 106

ii 
Appendix A Ballast Water Tank Capacities and Fleet Makeup ........................................ 118

Appendix B Ballast Water Exchange (BWE) Cost ........................................................... 130

Appendix C Cost of Ballast Water Management Systems in Terms of Vessel Value and 

Daily Charter Rates ............................................................................................................... 135

Appendix D Ballast Water Management System Costs for the Foreign Vessels ............. 138

Appendix E Information Provided by Public Comments ................................................ 138

Appendix F Aquatic NIS Invasion Process................................................... 149 

Appendix G Alternative Analyses of Benefits (Economic Costs Avoided) ...................... 156

Appendix H Derivation of Estimates of Costs and Damages Due to Aquatic NIS ........... 161 

Appendix I Collection of Information for Compliance Extension Request .............. 172 

iii 
Tables 

Table ES-1 Comparison of Regulatory Impacts between the NPRM and FR ...................................................... 11

Table ES-2 Allowable concentration of organisms in BWD, by size, for BWDS ................................................ 12

Table ES-3 Potential vessels affected by BWD Standards ................................................................................... 14

Table ES-4 Costs to the U.S. vessels to comply with IMO Convention BWD Standard ($Mil) .......................... 15

Table ES-5 Estimated Annual Costs of Aquatic Introduced Species ($ 2007) ..................................................... 16

Table ES-6 Estimated Number of Initial Ballast Water Invasions that Cause Severe Economic and Financial 

Harm ..................................................................................................................................................................... 18

Table ES-7: Range of Annual Costs Associated with Selected NIS Introductions ($ 2007) ................................ 18

Table ES-8 Potential Cost ($Mil)/Damage of BW Invasion over a 10-year Period ............................................. 19

Table ES-9: Potential Annual Benefits (Averted Cost), in Millions, of BW Invasion over a 10-year Period ...... 20

Table 1.1 Comparison of Regulatory Impacts between the NPRM and FR ......................................................... 26

Table 1.2 Allowable concentration of organisms in BWD, by size, for Alternatives ........................................... 27

Table 1.3 Implementation Schedule for the Ballast Discharge Standards ............................................................ 28

Table 2.1 Vessel Type Definitions ....................................................................................................................... 34

Table 2.2 Potential vessels affected by BWD Standards ...................................................................................... 36

Table 2.3 U.S. Fleet Growth and Removal Rates ................................................................................................ 38

Table 3.1 Ballast Water Treatment Processes ...................................................................................................... 41

Table 3.2 Suitability of BWMS to Vessel Type ................................................................................................... 45

Table 3.6 Estimated Average Operational Cost per Cubic Meter of Ballast Treated by Vessel Category and 

Treatment Process ($/m3

) ..................................................................................................................................... 51

Table 4.3 Costs for U.S. Installed BWDS-2 ($Mil) .............................................................................................. 61

Table 4.4 Estimated Ballast Water Discharge for U.S. Vessels in 2007 .............................................................. 62

Table 4.5 Annual Operating Costs for BWM U.S. ($Mil) .................................................................................... 63

Table 4.6 Total Cost of the Rulemaking to US Vessels ($ Mil) ........................................................................... 65

Table 5.1 Estimated Cumulative Losses to the United States from Selected, Harmful, Nonindigenous Species, 

1906-1991 (OTA 1993) ........................................................................................................................................ 72

Table 5.3 Distribution of NIS by Plants, Invertebrates and Fish for Three Regions (Cohen and Carlton, 1995) . 77

Table 5.4 Forecasted Number of Initial Shipping Invasions Per Year ................................................................. 78

Table 5.5 Number of Nonnative Coastal Marine Species by Shipping Vector (Fofonoff, et al. 2003) ................ 79

Table 5.6 Estimated Number of Ballast Water Initial Invasions .......................................................................... 80

Table 5.7 Estimated Number of Ballast Water Initial Invasions That Cause Severe Economic or Financial Harm

 .............................................................................................................................................................................. 81

Table 5.8 Range of Annual Costs Associated with Selected NIS Introductions ($ 2007) .................................... 81

Table 5.9a Summary of Potential Cost ($ Mil)/Damage of BW Invasion over a 10-year Period ......................... 82

Table 5.9b Potential Cost ($ Mil)/Damage of BW Invasion over a 10-year Period – 7 Percent Discount Rate .. 82

Table 5.9c Potential Cost ($ Mil)/Damage of BW Invasion over a 10-year Period – 3 Percent Discount Rate .. 83

iv 
Table 5.10 Reductions in the Mean Rate of Successful INS Introductions (Multiple Species Model) ............... 85

Table 5.11 Harmful Ballast Water Initial Invasions Avoided – Phased-In Schedule ........................................... 85

Table 5.12 Potential Annual Benefits (Avoided Costs) of Ballast Water Initial Invasions over a 10-year Period 

($ Mil)* ................................................................................................................................................................ 86

Table 5.13 Uncertainties and Possible Effects on Estimation of Benefits ............................................................ 88

Table 7.1 . Comparison of the NPRM and FR Number of Small Entities ........................................................... 96

Table 7.2 . Comparison of the NPRM and FR Installation Impact on Small Entities ......................................... 96

Table A-1a Ballast Water Capacities (m3) for U.S. Vessels ............................................................................... 119

Table A-1b Ballast Water Capacities (m3) for Foreign Vessels ......................................................................... 120

Table A.2 World Fleet Growth and Removal Rates ........................................................................................... 122

Table A.3 Number of Active U. S. Vessels and Percentage Change (2002-2007) ............................................. 123

Table A.4 TRB Summary of Major Forecasts of Waterborne Cargo ................................................................. 123

Table A.5 U.S. Waterborne Imports, Arrivals by Type ...................................................................................... 124

Table A.6 U.S. Waterborne Trade ...................................................................................................................... 124

Table A.7 World Fleet Development (The Platou Report) (Mil DWT) ............................................................. 125

Table A.8 World Fleet Development with Derived Removal Rates (The Platou Report) (Mil DWT) .............. 126

Table B-1 Additional Maintenance Costs per m3 of Ballast Pumped for BWE ................................................. 132

Table B-2 Additional Crew Costs per m3 of Ballast Water Pumped for BWE ................................................... 133

Table B-3 Total Cost per m3 for Ballast Pumped for BWE ................................................................................ 133

Table B-4 BWE Costs for 2007 .......................................................................................................................... 135

Table C-1 Average Daily Time Charter Rates, 1980-2000 (Kite-Powell 2001) ................................................. 136

Table D-1 Estimated Average Installed Cost ($000) for the Foreign Fleet by Vessel Category and BWMS .... 140

Table D-2 Installed Ballast Water Management System Costs ($000) for the Foreign Vessels ......................... 141

Table D-3 Number of Foreign Vessels Undergoing BWMS Installation by Year and Type ............................. 142

Table D-4 Installation Costs for the BWMS for Foreign Vessels ($Mil) ........................................................... 143

Table D-5 Estimated ballast water discharge in 2007 ........................................................................................ 144

Table D-6 Annual Operating Costs for BWM ($Mil) ........................................................................................ 145

Table D-7 Total Cost of the Rulemaking to Foreign Vessels ($Mil) .................................................................. 146

Table D-8 Total Cost of the Rulemaking to U.S. and Foreign Vessels ($Mil) ................................................... 147

Table E-1 Cost Information on BWMS Provided by Public Comments ............................................................ 149

Table G-1 Benefits by Year Under Deferred Assumption – 7% ($Mil) ............................................................. 157

Table G-2 Benefits by Year Under Deferred Assumption – 3% ($Mil) ............................................................. 157

Table G-3 Benefits by Year Under Deferred Assumption, 20-Year Period of Analysis– 7% ($Mil) ................ 158

Table G-4 Benefits by Year Under Deferred Assumption, 20-Year Period of Analysis– 3% ($Mil) ................ 159

Figure G-1 Cumulative Benefits and Costs Under Deferred Assumption, 20-Year Period of Analysis– 7% .... 160

Table G-5 Benefits by Year Under Phased-In Assumption – 7% ($Mil) ........................................................... 160

Table G-6 Benefits by Year Under Phased-In Assumption – 3% ($Mil) ........................................................... 161

v 
Table H-1 Range of Annual Costs Associated with Selected NIS Introductions ($ 2007) ................................. 163

Table H-2 Summary of Cost Estimates for Invertebrates from Literature.......................................................... 164

vi 
Figures 

Figure ES: Comparison of Cumulative Costs and Benefits .................................................................................. 21

(7% Discount Rate, $2007, Mid-Point Invasion Estimate) ................................................................................... 21

Figure 6.1 Range of Quantified Benefits and Annual Costs (7% Discount Rate, $2007) .................................... 89

Figure 6.2 Comparison of Cumulative Costs and Benefits (7% Discount Rate, $2007, Mid-Point Benefit per 

Invasion Estimate) ................................................................................................................................................ 90

Figure A-1 Imports (Metric Tons) on Containerships, 1998-2003 ..................................................................... 124

Figure A-2 Imports (TEUs) on Containerships, 1998-2003 ............................................................................... 125

Figure A-3 LNG Fleet Growth (from ABS GASTECH paper) Based Upon 138K m3 Capacity ....................... 127

Figure A-4 LNG Growth Projected .................................................................................................................... 127

FigureA-5 Bulk Carrier BW Capacity vs. Deadweight ...................................................................................... 128

Figure A-6 Containership BW Capacity vs. TEU .............................................................................................. 129

Figure A-7 Tanker BW Capacity vs. Cargo Capacity (from HEC data) ............................................................ 129

vii 
Acronyms

BWD ballast water discharge 

BWE ballast water exchange 

BWM ballast water management 

CFR Code of Federal Regulations 

DWT Deadweight Ton 

EEZ Exclusive Economic Zone 

ER empty / refill 

FR Federal Register

FRFA Final Regulatory Flexibility Analysis 

FT flow-through 

GAO United States Government Accountability Office 

HEC Herbert Engineering Corp. 

HFO heavy fuel oil 

FR Final Rule 

IMO International Maritime Organization 

IRFA Initial Regulatory Flexibility Analysis 

LNG liquefied natural gas 

MARAD U.S. Maritime Administration 

MDO marine diesel oil 

MEPC Marine Environmental Protection Committee 

MISLE Marine Information Safety and Law Enforcement System 

NAICS North American Industrial Classification System 

NANPCA Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990 

NBIC National Ballast Water Information Clearinghouse 

NIS nonindigenous species 

NISA National Invasive Species Act 

NOBOB No Ballast On Board 

NPRM Notice of Proposed Rulemaking 

OMB Office of Management and Budget 

PEIS Programmatic Environmental Impact Study 

PV present value 

RORO Roll-on, Roll-off (Vessel) 

RA Regulatory Analysis 

RFA Regulatory Flexibility Act 

SERC Smithsonian Environmental Research Center 

TEU Twenty-foot Equivalent Unit 

ULCC ultra large crude carrier 

VLCC very large crude carrier 

viii 
ix 

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Executive Summary 

Under Executive Order 12866, the United States Coast Guard (USCG) is required to assess 

the costs and benefits of its regulatory actions. This Regulatory Analysis (RA) provides 

supporting documentation on the costs and benefits for the Final Rule (FR) for Standards for 

Living Organisms in Ships’ Ballast Water Discharged in U.S. Waters [USCG-2001-10486]. 

This rule is an economically significant regulatory action under Executive Order 12866 and 

has been reviewed by the Office of Management and Budget (OMB). We did not attempt to 

exactly replicate the regulatory language of the Final Rule or any other supporting 

documentation in this report; the regulatory text in the Final Rule, not the text of this report, 

is legally binding. 

The unintentional introduction of nonindigenous species (NIS) into the waters of the United 

States via the discharge of vessels’ ballast water continues to pose a serious risk to coastal 

facilities and global biodiversity. Current U.S. regulations require ballast water management 

(BWM) to prevent introductions of NIS through ballast water discharge (BWD). Currently, 

the primary management method for controlling ballast water discharged in U.S. waters is a 

mid-ocean exchange of ballast water obtained from waters outside the U.S. Exclusive 

Economic Zone (EEZ). Concern remains that this approach to ballast water management is 

not sufficiently effective in preventing the introduction of NIS nor can many vessels conduct 

ballast water exchange because of safety issues and or voyage constraints. 

The U.S. is proposing this rule to establish a ballast water discharge standard (BWDS) for the 

allowable concentrations of living organisms discharged via ballast water into U.S. waters. 

While BWDS has been adopted by the International Maritime Organization (IMO), it has not 

been ratified by enough countries to bring it into force as an international requirement. The 

Coast Guard expects this to eventually be ratified. 

On August 28, 2009, we published a Notice of Proposed Rulemaking (NPRM) entitled 

Standards for Living Organisms in Ships’ Ballast Water Discharged in U.S. Waters in the 

Federal Register (74 FR 44632). We received 662 letters in the docket, which contained 

approximately 2,216 individual comments on the proposed rule. We summarized these 

comments and corresponding changes in the FR section V. Discussion of Comments and 

Changes. 

As a result of public comments, we have revised the NPRM RA to reflect the following 

changes in the FR: 

(a) Exemption of coastwise1

 vessels operating in more than one COTP Zone and that 

do not operate outside of the EEZ, and are: 

1 The term used in the Final Rule is “seagoing” vessels. For the purposes of consistency with the NPRM RA, instead of 

“seagoing” we use the terms “coastwise” and “oceangoing” vessels. Seagoing vessels that do not operate beyond the U.S. 

EEZ are considered coastwise. Seagoing vessels that operate beyond the U.S. EEZ are considered oceangoing. We used the 

coastwise and oceangoing terms throughout the NPRM RA. The definition of seagoing vessel is a vessel in commercial 

10 
(i) less than or equal to 1600 Gross Register Tons; or 

(ii) less than or equal to 3000 Gross Tons (International Tonnage 

Convention); and 

(b) Exemption of inland2

 vessel and vessels that take on and discharge ballast water 

exclusively in one COTP Zone. 

Given the changes in the applicability and exemptions of this rule, we have revised our 

affected population estimates resulting in changes in the overall cost estimates. The revision 

on the affected population estimates resulted in changes in the overall cost estimates. The FR 

costs have decreased due to the reduction in the affected population. The benefits have 

decreased due to the longer phase-in period. We have also revised the original Initial 

Regulatory Flexibility Analysis (IRFA) and as a result, our estimates showed that there was a 

reduction in the number of small entities affected by this rule. Table ES-1 presents a 

summary of the changes in this FR RA comparing to the NPRM RA: 

Table ES-1 Comparison of Regulatory Impacts between the NPRM and FR 

NPRM FR 

Applicability All vessels discharging ballast water 

into U.S. waters. 

Oceangoing vessels and some 

coastwise vessels (> 1,600 GT) 

discharging ballast water in U.S. 

waters. 

Compliance Start Date Beginning 2012 Revised, beginning December 2013 

Number of BWMS 

Installations on Vessels (10-

year period of analysis) 

4,758 3,046 

Costs 

($ millions,7% discount rate) 

$167 (annualized) 

$1,176 (10-year) 

$92 (annualized) 

$649 (10-year)

Benefits 

($ millions,7% discount rate) 

$165-$282 (annualized) 

$1,161-$1,977 (10-year) 

$141-$240 (annualized) 

$989-$1,684 (10-year) 

This RA provides an evaluation of the economic impacts associated with the implementation 

of a standard limiting the quantities of living organisms in vessels’ ballast water discharged 

in U.S. waters as summarized in Table ES-2. 

 service that operates beyond the Boundary Line established by 46 CFR part 7. It does not include a vessel that navigates 

exclusively on inland waters. 

2 The term used in the Final Rule is “non-seagoing” vessels. We have used the terms inland in this RA in order to keep 

consistency with the terms used in the NPRM RA.

11 
Table ES-2 Allowable concentration of organisms in BWD, by size, for BWDS 

Large 

Organisms > 

50 microns in 

size 

Small 

Organisms 

>10 and ≤50 

microns in 

size 

Bacteria 

Toxigenic Vibrio 

cholerae (O1 and 

O139) 

E. coli Intestinal 

Enterococci

FR BWDS 

(IMO Standard) 

<10 per m3 <10 per ml <1 cfu per 100 ml <250 cfu per 

100 ml 

<100 cfu per 

100 ml 

For the NPRM, we considered five alternatives: 

• Alternative 1: No Action 

• Alternative 2: IMO Standard 

• Alternative 3: 10 times more strict than the IMO Standard 

• Alternative 4: 100 times more strict than the IMO Standard 

• Alternative 5: Sterilization 

We also considered a Phase 2 Standard that would be 1,000 times stricter than the IMO 

Standard. 

Based on comments received in the NPRM and as discussed in the FR notice, Coast Guard 

chose to implement the preferred alternative (the IMO Standard) in this Final Rule, with the 

consideration of more strict standards based upon future practicability. For further 

discussion of the alternatives considered, please refer to the Regulatory Analysis for the 

NPRM, the FR preamble and the Final Programmatic Environmental Impact Assessment. 

Population Affected

This FR will affect vessels, U.S. and foreign, operating in U.S waters3 equipped with ballast 

tanks. These vessels are required to install and operate a USCG approved ballast water 

management system (BWMS) before discharging ballast water into U.S. waters. This would 

include vessels bound for offshore ports or places. The following vessels are exempt from 

complying with this rule: 

(a) Department of Defense or Coast Guard vessels subject to the requirements of the 

Nonindigenous Aquatic Nuisance Prevention and Control Act (NANPCA ) or any vessel of 

the Armed Forces, as defined in the Federal Water Pollution Control Act that is subject to the 

“Uniform National Discharge Standards for Vessels of the Armed Forces”; 

(b) Any warship, naval auxiliary, or other vessel owned or operated by a foreign state, and 

used, for the time being, only on government non-commercial service. 

 

3

 Waters of the United States means waters subject to the jurisdiction of the United States as defined in 33 CFR 

2.3, including the navigable waters of the United States. For 33 CFR Part 151, subpart C and D, the navigable 

waters include the territorial sea as extended to 12 nautical miles from the baseline, pursuant to Presidential 

Proclamation No. 5928 of December 27, 1988. 

12 
(c) Crude oil tankers engaged in coastwise trade; 

(d) Vessels that operate exclusively within one Captain of the Port (COTP) Zone; 

(e) Coastwise (or Seagoing) vessels that operate in more than one COTP Zone, do not 

operate outside of the EEZ, and are (i) less than or equal to 1600 Gross Register Tons; or (ii) 

less than or equal to 3000 Gross Tons (International Tonnage Convention); 

(f) Inland (Non-seagoing) vessels; 

(g) Vessels that take on and discharge ballast water exclusively in one COTP Zone; 

(h) Vessels in innocent passage; and 

(i) Vessels that use only water from a public water supply, meeting the requirements of the 

Safe Drinking Water Act as ballast water. 

The primary source of data used in this analysis is the Marine Information for Safety and 

Law Enforcement (MISLE) system and Ballast Water Reporting Forms submitted to the 

National Ballast Information Clearinghouse (NBIC). MISLE is the USCG database system 

for information on vessel characteristics, arrivals, casualties, and inspections. The NBIC 

database is maintained by the Smithsonian and provides information on the amount of ballast 

water discharged in U.S. ports for the range of vessel types calling on U.S. waters. Since 

October 2004, all vessels, U.S. and foreign, operating in U.S. waters and bound for U.S. ports 

or places must submit reports of their BWM practices to the NBIC database. 33 CFR 

151.2041. 

We identified approximately 6,418 vessels as the current vessel population that would be 

required to meet the BWDS. Of these, 1,459 are U.S.-flagged vessels. We assumed that 

vessels would be in full compliance with the FR by 2018. The BWMS equipment installation 

requirements are phased-in for existing vessels over the 2014 through 2016 period. Table ES3 presents the number of potential vessels operating in U.S. waters that are projected to be 

covered under the BWDS. 

13 
Table ES-3 Potential vessels affected by BWD Standards 

Type of Vessel Classification Criteria a

Vessels Operating in U.S. Waters 

(2007) 

U.S. 

Vessels 

Foreign 

Vessels 

Total 

Number of 

Vessels 

Bulk carriers

Handy <50,000 DWT 11 1,050 1,061 

Panamax 50,000-80,000 DWT 6 509 515 

Capesize >80,000 DWT 0 46 46 

Tank Ships

Handy <35,000 DWT 10 116 126 

Handymax-Aframax 35,000-120,000 DWT 17 709 726 

Suezmax 120,000-160,000 DWT 7 100 107 

VLCC 160,000-320,000 DWT 4 154 158 

ULCC > 320,000 DWT 0 16 16 

Container ships

Feeder <500 TEU 23 39 62 

Feedermax 500-1000 TEU 1 51 52 

Handy 1000-2000 TEU 26 126 152 

Subpanamax 2000-3000 TEU 52 172 224 

Panamax >3000 TEUb 21 174 195 

Postpanamax >3000 TEUc 30 272 302 

Other vessels

Passenger ship All sizes 138 129 267 

Gas carrier All sizes 6 118 124 

Chemical carrier All sizes 23 513 536 

RORO All sizes 66 321 387 

Combination vessel All sizes 131 22 153 

General cargo All sizes 47 258 305 

Fishing Vessels All sizes 83 16 99 

Other Offshore and 

Coastal Vessels 

All sizes 

757 48 805 

Total 1,459 4,959 6,418 

a. Vessel classifications source: USGC (2004) 

b. Vessel length and beam within Panama Canal limits. 

c. Vessel length or beam exceed Panama Canal limits. 

. 

14 
For the purposes of this RA, we consider the bottom-line costs of this rulemaking to involve 

U.S. vessels only. Nevertheless, we anticipate that the development of management 

technology will involve the world fleet, not the U.S. fleet alone. In addition, for the purpose 

of this rulemaking, we do consider all vessels operating in U.S. waters when developing the 

average per vessel installation and operating unit costs since the U.S. fleet is relatively small 

and not representative of all vessel types. 

Costs of the Ballast Water Discharge Standard 

The IMO BWM Convention has spurred development of alternative ballast water 

management systems (BWMS) that will enable vessels to meet the IMO discharge standard 

(Alternative 2). Various technologies are being evaluated. Shipboard trials are being 

conducted for some of these technologies, while other systems are undergoing land-based 

laboratory testing. 

Not all systems are appropriate for all vessel types. The BWMS is an emerging technology in 

its formative stage. The BWMS on ships is a new process for which there is minimal 

operating practical experience. Any discussion of the management technologies, 

effectiveness, costs, and operating issues is provisional. The primary cost driver of this 

rulemaking is installation costs for all existing vessels. After this period, we estimate 

operating costs to be substantially less. The operating cost is a function of the number of 

vessels treating ballast water and the estimated average volume treated each year. We 

calculated the annual volume treated by using the average annual volume of ballast water 

discharged by different types of vessels. We expect highest annual costs in the period 

between years 3 and 5, as all of the existing fleet must meet the standards according to the 

phase-in schedule (Table ES-4). 

Table ES-4 Costs to the U.S. vessels to comply with IMO Convention BWD Standard ($Mil) 

Year 

Installation Costs 

Treated Ballast 

Water (m3) 

Annual Operation Costs Total Cost 

3% 

Discount 

7% 

Discount 

3% 

Discount 

7% 

Discount 

3% 

Discount 

7% 

Discount 

1 $51.88 $49.94 280,029 $0.05 $0.05 $51.92 $49.98

2 $51.71 $47.92 478,831 $0.09 $0.08 $51.80 $48.00

3 $191.14 $170.50 2,993,916 $0.46 $0.41 $191.61 $170.91

4 $178.68 $153.43 5,348,917 $0.80 $0.69 $179.49 $154.12

5 $105.08 $86.86 6,565,633 $0.96 $0.79 $106.04 $87.65

6 $35.68 $28.39 6,720,480 $0.96 $0.76 $36.64 $29.15

7 $36.08 $27.63 6,957,572 $0.97 $0.74 $37.05 $28.37

8 $36.49 $26.90 7,200,434 $0.97 $0.72 $37.46 $27.62

9 $36.91 $26.19 7,449,212 $0.98 $0.69 $37.88 $26.89

10 $37.33 $25.51 7,704,056 $0.98 $0.67 $38.31 $26.17

Total $760.98 $643.25 $7.21 $5.61 $768.20 $648.86

Annualized $89.21 $91.58 $0.85 $0.80 $90.06 $92.38 

Note: Totals may not add due to rounding. 

15 
We estimate the first-year total (initial) cost of this rulemaking to be $49.98 million based on 

a 7 percent discount rate and $51.92 million based on a 3 percent discount rate. Over the 10-

year period of analysis, the total cost of the FR BWDS for the U.S. vessels is approximately 

$648.86 million using the 7 percent discount rate and $768.20 million using the 3 percent 

discount rate. Our cost assessment includes existing and new vessels. 

Economic Costs of Invasions of Non-indigenous Species 

NIS introductions contribute to the loss of marine biodiversity and have associated with it 

significant social, economic, and biological impacts. NIS introductions in U.S. waters are 

occurring at increasingly rapid rates. Avoided costs associated with future NIS invasions 

represent one of the benefits of BWM. Economic costs from invasions of NIS range in the 

billions of dollars annually. Evaluation of these impacts was difficult because of limited 

knowledge of the patterns and basic processes that influence marine biodiversity. The most 

extensive review to date on the economic costs of introduced species in the U.S. includes 

estimates for many types of NIS, and is reflected in Table ES-5. 

Table ES-5 Estimated Annual Costs of Aquatic Introduced Species ($ 2007) 

Species Costs 

Fish $5.7 billion 

Zebra and Quagga mussels $1.06 billion 

Asiatic clam $1.06 billion 

Aquatic weeds $117 million 

Green Crab $47 million 

Note: See Chapter 5 "Economic Cost of Invasions of Non-indigenous 

Species" for additional details and source information. 

Though a particular invasion may have small direct economic impacts, the accumulation of 

these events may cost in the billions of dollars every year. Only a few invasions to date have 

led to costs in the billions of dollars per year. 

Ballast water discharge is one of the two main vectors by which NIS are introduced into the 

marine environment associated with shipping-- hull-fouling being the other. The BWDS will 

not address hull fouling. The relative impact of ballast water and hull fouling vectors has not 

been fully understood (Ruiz 2002). 

Benefits of Ballast Water Discharge Standards 

The benefits of BWDS are difficult to quantify because of the complexity of the ecosystem 

and a lack of understanding about the probabilities of invasions based on prescribed levels of 

organisms in ballast water. However, evaluation of costs associated with previous invasions 

(described above) allows a comparison of the cost of discharge standards versus the potential 

costs avoided. Because the amount of shipping traffic and the number of incidents of 

16 
invasions per year are both increasing, historical data provide a lower bound for the basis of 

benefit evaluation. 

We assessed the functional benefits prior to comparing monetary benefit measures. The 

primary functional benefits of a BWDS are: 

• A reduction in the concentration of all organisms leading to lower numbers of these 

organisms being introduced per discharge; and 

• The elimination of the exemptions in the BWM regulations leading to the discharge 

of unmanaged ballast water (e.g., safety concerns during exchange, deviation/delay of 

voyage required to travel to acceptable mid-ocean exchange location). 

This overall strategy should reduce the number of new invasions because the likelihood of 

establishment decreases with reduced numbers of organisms introduced per discharge or 

inoculation. 

We use the same benefits model for the FR as we did for the NPRM. This model quantifies 

benefits resulting from the reduction in “initial invasions” from vessels engaged in oceangoing traffic. We have not found complete data or identified appropriate models to quantify 

the possible benefits associated with reducing the secondary spread of invasions. Therefore, 

we do not expect the exemption of inland vessels to reduce the estimate of quantified benefits 

given data and modeling limitations. 

We calculate potential benefits of the BWDS by estimating the number of initial invasions 

reduced and the range of economic damage avoided. We use information on the initial 

invasion rate of invertebrates from shipping reported by Ruiz et al. (2000) to project the 

number of future shipping invasions per year. We then estimate the number of fish and 

aquatic plant invasions based on historical relationships of fish and plant invasions to 

invertebrate invasions. We then adjust the projected invasions to account for the fraction of 

invasions that are attributable to ballast water and the fraction of invasions that cause severe 

economic damage.4

 The resulting projection of the number of initial ballast water invasions 

that will cause harm is displayed in Table ES-6. 

 

4

 We recognize that invasive species can cause environmental harm without causing economic harm, but cannot 

monetize these benefits. Environmental harm from invasive species is discussed more fully in the FPEIS. 

17 
Table ES-6 Estimated Number of Initial Ballast Water Invasions that Cause Severe Economic and 

Financial Harm 

Year Invertebrate Fish Aquatic Plant 

1 0.39 0.08 0.16 

2 0.40 0.08 0.16 

3 0.41 0.08 0.16 

4 0.42 0.08 0.17 

5 0.43 0.09 0.17 

6 0.44 0.09 0.18 

7 0.45 0.09 0.18 

8 0.46 0.09 0.18 

9 0.47 0.09 0.19 

10 0.48 0.10 0.19 

Total 4.35 0.87 1.74 

 Note: Totals may not add due to rounding. 

To estimate the potential economic harm that may be caused by these invasions, we assign a 

cost per invasion based on the available data on the range of costs and damages incurred by 

past invasions. As no comprehensive estimate is available on the costs from past invasions, 

we do not try to develop a composite cost estimate for all invasions, but instead select a low 

and high estimate for fish, aquatic plants, and invertebrates based on representative species. 

We then calculate a mid-point for the range and calculate costs for future invasions using all 

three values. The resulting ranges of costs per invasions are summarized in Table ES-7. 

Table ES-7: Range of Annual Costs Associated with Selected NIS Introductions ($ 2007) 

Low-Range Mid-Range High Range 

Fish $ 15,805,000 [1] $ 160,547,000 $ 305,289,000 [2] 

Invertebrates $ 19,538,000 [3] $ 539,769,000 $ 1,060,000,000 [4] 

Aquatic Plants $ 4,507,000 [5] $ 214,585,500 $ 424,664,000 [6] 

[1] From Jenkins 2001, economic impact of sea lamprey on Great Lakes, updated from 2001$ 

[2] From Leigh 1998, commercial and recreational fishing benefits lost due to ruffe invasion of Great Lakes, 

updated from 1998$ 

[3] From Connelly et al. 2007, cost of Zebra Mussel control at WTP and electric generation facilities, updated 

from 2004$ 

[4] From Piementel et al. 2005, cost of Zebra Mussel or Asian Clam, updated from 2005$ 

[5] From Rockwell 2003, cost to control Water Hyacinth in Louisiana, updated from 2003$ 

[6] From Pimentel 2005, cost to control Eurasion watermilfoil, updated from 2005$ 

We assume that once an invasion is established, it will continue to generate costs and/or 

damages for each year subsequent to the invasion. Thus, an invasion that occurs in the first 

year of our analysis will incur costs/damages in each of the next 10 years. Also, these 

estimates of costs include the impact of secondary spread of an invasion to areas other than 

the site of the initial invasion. 

18 
Based on the cumulative impacts of invasions, we have calculated a mid-range estimate of 

annual costs for all harmful ballast water-introduced invasions over the 10-year period (we 

present results of benefits estimation for a longer period of analysis in Appendix D) at $1.453 

billion at a 7 percent discount (Table ES-8). These estimates assume no ballast water 

management. 

Table ES-8 Potential Cost ($Mil)/Damage of BW Invasion over a 10-year Period 

Range of NIS Costs Total Cost for 

(3% disc. rate) 

Total Cost for 

(7% disc. rate) 

Low Range $ 56 $ 54 

Mid Range $ 1,491 $ 1,453 

High Range $ 2,926 $ 2,852 

The Final Programmatic Environmental Impact Statement (USCG 2010) has estimated the 

reduction in the mean rate of successful introductions of various alternative standards. In 

comparison with the existing practice of ballast water exchange, the FR BWDS is between 

37 percent and 63 percent effective in preventing invasions when fully implemented. We use 

these estimates of the reduction in the rate of invasions to estimate the economic cost/damage 

avoided as a result of the BWDS. 

As discussed earlier, the implementation of the FR BWDS will be phased-in over several 

years. During the phase-in period of, there is uncertainty as to how effective the measures 

will be in preventing invasions if only a subset of ships have implemented ballast water 

management. For the purposes of estimating quantitative benefits, we assume that no 

invasions will be avoided before the end of this period because a subset of ships will have 

implemented ballast water management. This approach may lead to an underestimate of 

potential benefits. 

The resulting damages avoided for the FR BWDS range from a minimum of $5 million and 

the maximum is $470 million with a mid-range estimate of $141-$240 million per year at a 7 

percent discount rate5

 (Table ES-9). Over a 10-year period of analysis, we estimate the total 

discounted present value benefits of the phase-one BWDS to be as high as $3 billion with a 

mid-range estimate of $0.99 billion to $1.68 billion6

. Thus, quantified benefits exceed the 

estimated costs for the mid-point benefits estimate of Low Effectiveness. The high range 

annual cost estimate of $192 million7

 is less than the high range benefits estimate of Low 

Effectiveness. 

 

5

 The large range in the estimates of benefits from preventing invasive species is due to the natural variability in 

the amount of damage caused by any individual species (i.e., different species can cause a wide range of 

damages from very little in a small area to large, widespread damages). 

6

 The mid-range benefit estimate varies based on the assumed effectiveness factors of preventing invasions 

(37% and 63%). The average of the mid-range benefit estimate for the 10-year period of analysis is $1.34 

billion (range: $0.99 billion to $1.68 billion). 

7

 See OMB A-4 Account Statement for high cost estimates information. 

19 
Table ES-9: Potential Annual Benefits (Averted Cost), in Millions, of BW Invasion over a 10-year Period 

Reductions in Mean Rate 

of Invasion

Low Range Mid Range High Range 

3% discount 

rate 

7% 

discount 

rate 

3% 

discount 

rate 

7% 

discount 

rate 

3% 

discount 

rate 

7% 

discount 

rate 

Low Effectiveness - 37% $ 6 $ 5 $ 155 $ 141 $ 304 $ 276 

High Effectiveness - 63% $ 10 $ 9 $ 264 $ 240 $ 518 $ 470 

Figure ES-1: Range of Quantified Benefits and Annual Costs 

(7% Discount Rate, $2007) 

$5

Low

$141

Mid

$276

High

$9

Low

$240

Mid

$470

High

$- $100 $200 $300 $400 $500

($ Millions)

Annual Benefits

Low Effectiveness

Annual Benefits 

High Effectiveness

Average 

Annualized 

Costs

The cumulative economic damages avoided would equal cumulative costs incurred in year 7 

assuming a higher reduction rate of 63 percent and in year 9 assuming a low reduction by 

invasion rate of 37 percent. Figure ES-2 illustrates the cumulative costs of the BWD in 

relationship to the damages avoided. 

20 
21 

Figure ES-2: Comparison of Cumulative Costs and Benefits 

(7% Discount Rate, $2007, Mid-Point Invasion Estimate) 

Regulatory Flexibility Analysis 

In accordance with the Regulatory Flexibility Act (RFA), we have prepared a Final 

Regulatory Flexibility Analysis (FRFA) that examines the impacts of the FR on small entities 

(5 USC 601 et seq.). Based on available data, we estimated that approximately 29 percent of 

the businesses affected would be small by the Small Business Administration size standards. 

After installation, however, most small businesses would not incur a significant economic 

impact from the estimated annual recurring operating costs. We have determined that this 

rule would have a significant economic impact on a substantial number of small entities 

under section 605(b) of the Regulatory Flexibility Act. 

Reporting and Recordkeeping 

As a result of public comments, we have included a provision in the FR to allow vessel 

owners and operators to request an extension of their compliance date if they cannot 

practicably comply with the compliance date otherwise applicable to their vessel. This is a 

voluntary provision and will result reporting and recordkeeping burden to the vessel owner 

and operator applying for the extensions. Therefore, the Coast Guard is amending the 

existing (OMB CONTROL NUMBER: 1625-0069) to add these requests for extension (see 

Appendix I for more information). 
OMB A-4 ACCOUNTING STATEMENT 

The USCG has determined that this is an “economically significant” rulemaking within the definition 

of Executive Order (EO) 12866, because estimated annual costs or benefits exceed $100 million in any 

year. As required by OMB Circular A-4 (available at http://www.whitehouse.gov), the USCG has 

prepared an accounting statement showing the classification of expenditures associated with the FR. 

Agency/Program Office: USCG 

Rule Title: Standards for Living Organisms in Ship’s Ballast Water Discharged in U.S. Waters 

RIN#: 1625-AA32 

Date: March 2012 

Category Primary Estimate Minimum Estimate High Estimate Source

Benefits

Annualized monetized 

benefits ($ Mil) 

$141-$240 7% $5 7% $470 7% RA 

$155-$264 3% $6 3% $518 3% RA 

Annualized quantified, but 

unmonetized, benefits Unspecified Unspecified Unspecified RA 

Unquantifiable Benefits 

Avoidance of damages due to certain species such as viruses and the 

secondary spread of invasions 

Avoidance of environmental damages that cannot be monetized 

RA 

Costs

Annualized monetized 

costs ($ Mil) 

$92 7% $92 7% $178 7% RA 

$90 3% $90 3% $173 3% RA 

Annualized quantified, but 

unmonetized, costs None None None 

Qualitative (unquantified) RA 

Transfers 

Annualized monetized 

transfers: “on budget” 

Not calculated Not calculated Not calculated RA 

From whom to whom? RA 

Annualized monetized 

transfers: “off-budget” None None None

From whom to whom? None None None

Miscellaneous Analyses/Category 

Effects on State, local, and/or 

tribal governments None None None

Effects on small businesses We expect the rulemaking to have a significant economic impact on a 

substantial number of small entities. RA 

Effects on wages None None None

Effects on growth No determination No determination No determination

Discount rate appears to the right of estimates.

Note 1: We based primary estimates for annualized costs on low cost technology alternatives (see Chapters 3 and 4 

for more details and descriptions). The primary cost estimates are the same as the minimum estimate. High cost 

estimates are based on high cost technologies. 

Note 2: Primary estimates for annualized benefits are based on the mid-point cost per species estimate for low and 

high effectiveness (See Chapter 5 for more details). The minimal estimate is from the low range cost per species 

and low effectiveness. The high estimate is for the high range cost per species and high effectiveness. 

22 
1 Introduction 

1.1 Statement of Need 

Vessels that release untreated ballast water increase risks to aquatic life and possibly 

human health and cause other environmental and economic harm without accounting for 

the consequences of these actions on other parties (sometimes referred to as third parties) 

who do not directly participate in the business transactions of the business entities. These 

costs are not borne by the responsible entities and are therefore external to the business 

decisions of the responsible entity. The goal of environmental legislation and 

implementing regulations, including the BWDS, is to correct these environmental 

externalities by requiring vessels to treat their ballast water releases in order to reduce the 

environmental harm that results from the introduction of some non-indigenous invasive 

species. 

The invasion of NIS in the US waters is a complex negative externality that requires the 

establishment of a unified ballast water discharge standard. Individual initiatives from 

some States do not fully address the NIS invasion problem since waterways are 

interlinked making the withholding of an invasive species a difficult task. Because States 

regulations are not standardized, the cost and equipment requirements might represent an 

undo burden on vessels traveling from port – to – port. A Federal regulation that 

standardizes operational and equipment requirements on all vessels, with the capability of 

operating ballast tanks, is the most effect alternative to correct this market failure. In a 

published statement by the American Great Lakes Ports Association, they support the 

Coast Guard’s initiative to develop a Federal regulation that would standardize the 

criteria for the management of ballast water in U.S. waters8

. In addition, a Federal 

regulation on ballast water discharge will have the added benefit of a regulation that 

complies with international treaties. 

1.2 Overview 

As discussed above, the introduction of non-indigenous species (NIS) into the waters of 

the United States via the discharge of vessels’ ballast water continues to pose a serious 

risk to coastal facilities and global biodiversity. Ruiz et al. (2000a) analyzed the likely 

sources and pathways for North American marine invasions and concluded that most 

invasive species are associated with vessels. The authors estimated that of all invasive 

species introduced into U.S. waters -60 percent, 48 percent, and 64 percent on the 

Atlantic, Pacific, and Gulf coasts, respectively- could be attributed to some aspect of the 

shipping industry. Vectors associated with vessels include hull fouling and ballast water 

discharge (BWD). 

 

8

 Source: http://www.greatlakesports.org/aquatic.html 

23 
The shipping industry uses ballast to optimize the configuration of the vessel so that it 

operates in a safe and efficient manner. Vessels use ballast to meet orientation (trim, 

heel, and draft), stability, and strength (bending moments, shear forces, and slamming 

loads) requirements both in port and at sea. Ballast water taken into the vessel via 

onboard pumps is the most common form of ballast. Ballast quantities range from a few 

hundred cubic meters (m3

) to more than 200,000 m3 for the largest tankers. Analysis of 

the National Ballast Information Clearinghouse (NBIC) database shows that vessels 

discharge more than 40 million m3

 of ballast water from outside the U.S. into U.S. waters 

each year. 

Current ballast water regulations require vessels that operate outside the U.S. Exclusive 

Economic Zone (EEZ) to use one of the following ballast water management (BWM) 

practices: 

(a) Conduct mid-ocean ballast water exchange (BWE) at least 200 nautical miles 

from any shore (some vessels may not be able to conduct BWE depending on 

vessel design, age, load, sea conditions, and safety concerns); 

(b) Retain ballast water onboard; or 

(c) Use a United States Coast Guard (USCG) approved alternative method. 

Because there are currently no approved alternative methods, BWE and 

retention of ballast water are the only available methods of BWM. 

Under the legislative mandate in the National Invasive Species Act (NISA), the USCG 

must approve any alternative methods of BWM used in lieu of BWE. 16 U.S.C. 

4711(c)(2)(D)(iii). NISA further stipulates that such alternative methods must be at least 

as effective as BWE in preventing or reducing the introduction of NIS into U.S. waters. 

16 U.S.C. 4711(c)(2)(D)(iii). Determining whether an alternative method is as effective 

as BWE is not an easy task. The effectiveness of BWE is highly variable, largely 

depending on the specific vessel and voyage. These variables make comparing the 

effectiveness of an alternative BWM method to BWE extremely difficult. In addition, a 

majority of vessels are constrained by design or route from practicing BWE effectively. 

Ballast water exchange that show a proportional reduction in abundance of organisms, so 

every vessel then has a different allowable concentration of organisms in its discharge, 

support these results. Thus, vessels with very large starting concentrations of organisms 

in their ballast tanks might still have large concentrations of organisms after BWE. 

For these reasons, BWE is not well suited as the basis for a protective programmatic 

regimen, even though it has been a useful “interim” management practice. We have 

concluded that, as an alternative to using BWE as the benchmark, establishing a standard 

for the concentration of living organisms that can be discharged in ballast water would 

advance the protective intent of NISA and simplify the process for USCG approval of a 

ballast water management system (BWMS). Additionally, setting a discharge standard 

would promote the development of innovative BWM technologies to be used for 

enforcement of the BWM regulations and assist in evaluating the effectiveness of the 

BWM program. 

24 
1.2.a Comparison Between the NPRM RA and the FR RA 

The goal of the USCG Final Rule (FR) is to establish a ballast water discharge standard 

(BWDS) for the allowable concentrations of living organisms discharged via ballast 

water into U.S. waters. On August 28, 2009, we published a Notice of Proposed 

Rulemaking (NPRM) entitled Standards for Living Organisms in Ships’ Ballast Water 

Discharged in U.S. Waters in the Federal Register (74 FR 44632). We summarized these 

comments in the FR section V. Discussion of Comments and Changes. The great 

majority of the comments on the NPRM RA were from the inland, Great Lakes and 

coastwise industries. The commenters raised many different issues related to the ballast 

water operations, such as the use of municipal/potable water, technology costs, size 

limitations and underestimation of the affected population (for not including inland 

vessels and vessels under 100 feet due to the general applicability of the NPRM). 

Additionally, commenters expressed concern that the cost estimates for the proposed 

Phase 2 standard was not included in any of the supporting documentation or analysis. 

Remaining comments were on cost to foreign vessels, benefits and small entities analysis. 

Given the issues raised by commenters on the affected population (mainly from inland, 

Great Lakes and coastwise industries as stated in the paragraph above), the Coast Guard 

has revised the applicability of the BWDS rule. The FR requires compliance with IMO 

BWDS only to the following vessels, intending to discharge ballast water into water of 

the United States: vessels entering waters of the United States from outside the exclusive 

economic zone (EEZ); and coastwise vessels that operate in more than one Captain of the 

Port (COTP) Zone, and are greater than 1600 Gross Register Tons (or 3000 International 

Gross Tons). The Coast Guard fully intends to expand the BWDS rule to all vessels at 

some point, as noted in the NPRM, but has determined that additional research and 

analysis is necessary to support this expansion. Additionally, the Coast Guard has 

decided to move forward with the NPRM Phase one standard that will not include a 

standard that is more stringent than the IMO standard. 

In order to address the applicability changes in the FR, we have revised the NPRM RA 

affected population to incorporate the following : 

(a) Exemption of coastwise9

 vessels that do not operate outside of the EEZ, and 

are: 

(i) less than or equal to 1600 Gross Register Tons; or 

(ii) less than or equal to 3000 Gross Tons (International Tonnage 

Convention); and 

(b) Exemption of inland10 vessels. 

 

9 The term used in the Final Rule is “seagoing” vessels. For the purposes of this RA, instead of “seagoing” we use the 

terms “coastwise” and “oceangoing” vessels. Seagoing vessels that do not operate beyond the U.S. EEZ are 

considered coastwise. Seagoing vessels that operate beyond the U.S. EEZ are considered oceangoing. We used the 

coastwise and oceangoing terms in this RA in order to keep consistency with the terms used in the NPRM RA. The 

definition of seagoing vessel is a vessel in commercial service that operates beyond the Boundary Line established by 

46 CFR part 7. It does not include a vessel that navigates exclusively on inland waters. 

25 
The revision of the affected population estimates and the revised compliance start date 

resulted in changes in the overall cost estimates. The FR costs have decreased due to the 

reduction in the affected population. The quantified benefits have decreased due to the 

longer phase-in period.11 We have also revised the quantitative findings from the Initial 

Regulatory Flexibility Analysis (IRFA) and as a result, our estimates showed that there 

was a reduction in the number of small entities affected by this rule. Table 1.1 presents a 

summary of the changes in this FR RA compared to the NPRM RA: 

Table 1.1 Comparison of Regulatory Impacts between the NPRM and FR 

NPRM FR 

Applicability All vessels discharging ballast water 

into U.S. waters. 

Oceangoing vessels and some 

coastwise vessels (> 1,600 GT) 

discharging ballast water in U.S. 

waters. 

Compliance Start Date Beginning 2012 Revised, beginning December 2013 

Number of BWMS 

Installations on Vessels (10-

year period of analysis) 

4,758 3,046 

Costs 

($ millions,7% discount rate) 

$167 (annualized) 

$1,176 (10-year) 

$92 (annualized) 

$649(10-year)

Benefits 

($ millions,7% discount rate) 

$165-$282 (annualized) 

$1,161-$1,977 (10-year) 

$141-$240 (annualized) 

$989-$1,684 (10-year) 

In addition to the changes described above, we have included a provision in the FR to 

allow vessel owners and operators to request an extension of their compliance date if they 

cannot practicably comply with the compliance date otherwise applicable to their vessel. 

This is a voluntary provision and will result reporting and recordkeeping burden to the 

vessel owner and operator applying for the extensions. Therefore, the Coast Guard is 

amending the existing (OMB CONTROL NUMBER: 1625-0069) to add these requests 

for extension (see Appendix I for more information). 

This RA provides a revised evaluation of the economic impacts associated with FR 

requirements and is presented as follows: 

The remainder of Chapter 1 discusses the alternative discharge standards under 

consideration and implementation schedule. 

 10 The term used in the Final Rule is “non-seagoing” vessels. We have used the terms inland in this RA in order to 

keep consistency with the terms used in the NPRM RA. 11 We use the same benefits model for the FR as we did for the NPRM. This model quantifies benefits 

resulting from the reduction in “initial invasions” from vessels engaged in ocean-going traffic. Inland 

vessels have been increasingly associated with the secondary spread of invasions, but we have not found 

complete data or identified appropriate models to quantify the possible benefits associated with reducing 

the secondary spread of invasions. Therefore, we do not expect the exemption of inland vessels to reduce 

the estimate of quantified benefits given data and modeling limitations. See the Benefits chapter of this 

report for more discussion on the data and modeling framework used for this rulemaking. 

26 
Chapter 2 presents a description of the affected vessel population, data sources, and 

estimated fleet growth. 

Chapter 3 presents the discussion on the installation and operational costs of the BWMS. 

Chapter 4 presents estimates of the costs associated with installing and operating a 

BWMS required to meet the Alternative 2 standards. 

Chapter 5 discusses the economic costs of NIS invasions and the benefits of the 

application of a BWDS. 

We analyze some factors contributing to the evaluation of benefits of a BWDS and 

discuss costs that we may potentially incur or avoid. We also present limitations of the 

various standards in reducing the invasion of NIS. 

Chapter 6 presents a comparison discussion on cost and benefits, BWDS, BWE and a 

sensitivity analysis in the total cost for U.S. vessels based in the potential in percentages 

of vessels owners complying with the phase-in schedule. 

Chapter 7 contains the Final Regulatory Flexibility Act (FRFA) analysis. 

1.3 Alternative Ballast Water Discharge Standards 

As part of the rulemaking process, Coast Guard considered several alternative BWDS. 

As described in the NPRM RA, these alternatives included: 

• maintaining the current BWE requirement (Alternative 1 – “No Action”); 

• three alternatives that would establish different and increasingly stringent levels 

of maximum concentrations for living organisms in discharged ballast water 

(Alternatives 2, 3, and 4 as summarized in Table 1.2); and 

• an alternative that essentially requires sterilization of ballast water (Alternative 5). 

Coast Guard also considered a Phase 2 standard that required more stringent levels of 

maximum concentrations for living organisms in discharged ballast water than 

Alternative 4. See the NPRM RA for additional detail on the alternatives considered in 

the NPRM. 

Table 1.2 Allowable concentration of organisms in BWD, by size, for Alternatives 

Large 

Organisms 

> 50 

microns in 

size 

Small 

Organisms 

>10 and 

≤50 

microns in 

size

Bacteria 

Toxigenic Vibrio 

cholerae (O1 and 

O139) 

E. coli Intestinal 

Enterococci

Alternative 2 <10 per m3 <10 per ml <1 cfu per 100 ml <250 cfu per 100 ml <100 cfu per 100 ml 

Alternative 3 <1 per m3 <1 per ml <1 cfu per 100 ml <126 cfu per 100 ml <33 cfu per 100 ml 

27 
Alternative 4 <0.1 per m3 <0.1 per ml <1 cfu per 100 ml <126 cfu per 100 ml <33 cfu per 100 ml 

Phase 2 <0.01 per m3 <0.01 per ml <1 cfu per 100 ml <126 cfu per 100 ml <33 cfu per 100 ml 

Alternative 2 is the BWDS in the International Maritime Organization (IMO) Ballast 

Water Convention12. Alternative 2 was the preferred alternative in the NPRM RA and is 

the standard in the FR. Under the FR BWDS the allowable concentration of living 

organisms (per volume) in ships’ ballast water (by size class) is: 

• For organisms larger than 50 microns in minimum dimension: discharge less than 

10 living organisms per cubic meter (m3

) of ballast water. 

• For organisms equal to or smaller than 50 microns and larger than 10 microns: 

discharge less than 10 living individuals per milliliter (ml) of ballast water. 

• For bacteria and viruses, discharge of indicator microbes such that: 

o Toxigenic Vibrio cholera (Serotypes O1 and O139) occur at a 

concentration less than 1 colony forming unit (cfu) per 100 ml. 

o E. coli occur at a concentration less than 250 cfu per 100 ml. 

o Intestinal Enterococci occur at a concentration less than 100 cfu per 100 

ml. 

 

1.4 Implementation Schedule 

Table 1.3 shows the implementation schedule for meeting the BWDS. This 

implementation schedule provides vessel owners and operators time to install equipment 

needed to comply with the discharge standard. 

Table 1.3 Implementation Schedule for the Ballast Discharge Standards 

 

Vessel’s Ballast Water Capacity 

(cubic meters, m3) Vessel’s Construction Date Vessel’s Compliance Date 

New vessels All On or after December 1, 2013 On Delivery 

Existing 

vessels 

Less than 1500 Before December 1, 2013 First scheduled drydocking after 

January 1, 2016 

1500-5000 Before December 1, 2013 First scheduled drydocking after 

January 1, 2014 

Greater than 5000 Before December 1, 2013 First scheduled drydocking after 

January 1, 2016 

12 The IMO is an organization of 160 member countries with observers from governmental, industry, environmental, 

public interest, and labor organizations that is concerned with the safety of shipping and cleaner oceans. To achieve its 

objectives, the IMO has promoted the adoption of some 30 conventions and protocols, and has adopted well over 700 

codes and recommendations concerning maritime safety, the prevention of pollution, and related measures.

28 
1.5 Regulatory Analysis 

This rule is economically significant under Executive Order 12866. 

This report presents an analysis of costs and benefits from this rule. These cost estimates 

would likely differ from future costs due to changes in technology, installation, and 

implementation efficiencies that may take place in industry. We expressed costs in 

constant 2007 dollars, which is the same as the NPRM RA. This analysis covers a 10-

year period covering the phase-in time for the change from ballast management through 

exchange to management via a performance standard. 

29 
 

2 Population Affected 

This chapter presents the description of the population affected by the FR, data sources, 

and the estimation of the fleet growth over the period of this analysis. 

As described in the previous chapter, this FR will affect vessels, U.S. and foreign, that 

operate in the U.S waters,13 are bound for ports or places in the U.S., and are equipped 

with ballast tanks. These vessels are required to install and operate a USCG approved 

BWMS before discharging ballast water into U.S. waters. The FR includes the following 

vessel exemptions (please see the FR, sections 151.2015 and 151.2020, for more 

information on exemptions): 

 (1) Department of Defense or Coast Guard vessels subject to the requirements of 

section 1103 of the Nonindigenous Aquatic Nuisance Prevention and Control Act as 

amended by the National Invasive Species Act, or any vessel of the Armed Forces, as 

defined in the Federal Water Pollution Control Act (33 U.S.C. 1322(a)) that is subject to 

the “Uniform National Discharge Standards for Vessels of the Armed Forces” (33 U.S.C. 

1322(n)); 

(2) Warship, naval auxiliary, or other vessel owned or operated by a foreign state, 

and used, for the time being, only on government non-commercial service. However, 

each such foreign state shall ensure that such vessels act in a manner consistent, so far as 

is reasonable and practicable, with this subpart; 

(3) Crude oil tankers engaged in coastwise trade; 

(4) Vessels that operate exclusively within one Captain of the Port (COTP) Zone. 

(5) Seagoing self-propelled vessels that operate in more than one COTP Zone, do 

not operate outside of the EEZ, and are (i) less than or equal to 1600 Gross Register 

Tons; or (ii) less than or equal to 3000 Gross Tons (International Tonnage Convention); 

(6) Inland (Non-seagoing) vessels; 

(7) Vessels that take on and discharge ballast water exclusively in one COTP 

Zone; 

(8) Vessels in innocent passage; and 

(9) Vessels that use only water from a public water supply, meeting the 

requirements of the Safe Drinking Water Act as ballast water. 

2.1 Overview of Data and Sources 

The primary source of data used in this analysis is the Marine Information for Safety and 

Law Enforcement system (MISLE) and Ballast Water Reporting Forms (for 2007) 

submitted to the National Ballast Information Clearinghouse (NBIC). MISLE is the 

USCG database for information on vessels characteristics, arrivals, casualties, and 

inspections. This database presents data from 2002 to present and utilizes the SQL 

Sequel Software interface for the database searches. The Smithsonian Environmental 

13 U.S. waters means waters subject to the jurisdiction of the United States as defined in 33 CFR 2.3, 

including the navigable waters of the United States. For 33 CFR Part 151, subpart C and D, the navigable 

waters include the territorial sea as extended to 12 nautical miles from the baseline, pursuant to Presidential 

Proclamation No. 5928 of December 27, 1988. 

30 
Research Center (SERC) administers the NBIC. We present a description of the data used 

and their sources in the following discussion. 

Number of U.S. vessels affected by the rule 

We estimated the U.S. population affected by this rule, based on the number of vessels in 

the MISLE database for the year 2007. The U.S. population includes only active vessels.

Annual arrivals 

We used this data to determine the vessel’s origin and the distinct routes the vessel 

typically transit. We used the routes to differentiate between coastwise and non-coastwise 

(oceangoing)14 vessels. Both MISLE and the NBIC database provide the last port of call 

(and country). However, the last port of call is not necessarily the source of ballast water. 

Vessels that travel between two U.S. ports may discharge ballast that originated outside 

the EEZ and within 200 nautical miles off shore. The NBIC database provides the source 

for ballast water. Vessels on U.S. voyages that obtained ballast prior to their first U.S. 

arrival were entered into the database and included in the estimates of BWM and BWD 

standards costs. 

Average total ballast capacity 

We used this data to determine the average volumes (in m3) of ballast water that a vessel 

needs to exchange and the equipment necessary to perform the exchange. We obtained 

data from Ballast Water Reporting Forms submitted in 2007 to the NBIC. We then 

compared these average volumes of ballast water for each vessel type (Appendix A) to 

the data in the BWM RA (USCG, 2004). From these data it was determined that mean 

ballast water capacity ranges from 1,700 m3 (fishing vessels) to approximately 215,000 

m3 (large tankers). 

Vessel service and capacity or size 

We used this data to determine the exchange amount (empty-refill or flow-through) and 

equipment cost to complete the BWE information in Appendix B. The NBIC database 

provides the IMO number (a unique vessel identifier) for each vessel. The IMO number 

was cross-referenced with data from the MISLE (which used the Lloyd’s Register of 

Shipping 2002) and database to determine vessel service. We identified distinct types of 

cargo or passenger services that could feasibly conduct ballast exchange. These services 

were further delineated by 20-foot equivalent units (TEU) for containerships or 

deadweight tons (DWT) for all other services, yielding 22 distinct vessel types and sizes 

of vessels that would be subject to this rulemaking. The type of exchange utilized by the 

 

14 Vessels are deemed to be “coastwise” when they operate exclusively within the U.S. Exclusive 

Economic Zone (EEZ), which is shipping within 200 nautical miles of U.S. coastal waters. “NonCoastwise” vessels are those that travel outside the EEZ, with normal operations is to and from foreign 

ports. 

31 
 

various vessel types was determined from the NBIC data. Although there are trends 

associated with vessel type, some types and even some specific vessels use both the 

empty-refill and the flow-through methods. 

Vessel ballast pump capacity 

We used this data to determine the ballast water system maintenance cost as a function of 

total capital cost for a ballast water system. Herbert Engineering Corporation (HEC) 

developed information based on personal communications with members of the marine 

industry (e.g. equipment manufacturers) and vessel specifications. Ballast water system’s 

pump capacities range from 250 m3

/hour for small containerships to 6,500 m3/hour for 

large liquefied natural gas (LNG) carriers and tankers. 

 2.2 Description of the Maritime Transportation Industry 

A diverse group of businesses comprises the ocean transportation industry. 

Containerships, general cargo vessels, tankers, and dry-bulk carriers dominate the deepsea cargo carrying fleet. Added to this list are specialized vessels carrying commodities 

ranging from flammable gases to vehicles to passengers. Vessels pump ballast water, 

distribute it throughout the vessel, and discharge it from vessels to achieve acceptable 

conditions of stability, list, trim, and longitudinal strength. Cargo operations may change 

the required quantity of ballast water. 

The U.S. shipping industry is a net importer. In 2004, imports totaled more than 957 

million tons while exports were 350 million tons (MARAD 2005). Over the 5-year period 

from 2000 to 2004, import tonnage increased 18 percent while exports remained flat. 

This means that the majority of vessels arriving at U.S. ports arrive laden, and thus do not 

need to discharge large amounts of ballast. Containerships are also much more heavily 

laden inbound to the U.S. than outbound. One exception to this general trend are 

shipments of grain in bulk carriers to Asia. 

Ocean shipping operations fall into two broad categories: tramp shipping and liner 

service. Tramp shipping provides convenient, timely, and economical transportation of a 

broad variety of raw materials and finished goods necessary to a global economy. Tramp 

vessels contract for particular cargoes on routes that vary from voyage to voyage. These 

vessels provide excess capacity along established trade routes and low-cost transportation 

for agricultural goods and many natural (crude oil, timber, ores, mineral products) and 

manufactured (petroleum, cement, steel, fertilizers) raw materials. In this sector, it is 

common for all of the cargo on board to belong to a single owner and to be loaded and 

off-loaded at individual ports. Tankers and dry bulk carriers are vessel types that typically 

operate on the spot market.15 In contrast, liner-service vessels operate on set routes and 

on fixed schedules. They commonly carry a variety of cargoes, the majority of which are 

15 A spot market is one in which commodities, such as grain, gold, crude oil, or computer chips, are bought 

and sold for cash and delivered immediately. For example, the ownership of crude oil onboard a tanker 

may change several times during a single voyage. 

32 
finished goods and cargoes belonging to many different cargo owners. In this sector, 

timely service is critical to a successful operation, and the shipping company typically 

has a large traffic department responsible for generating the cargo business to fill the 

company vessels. General cargo and containerships are typical vessel types in this sector. 

Vessels in tramp service, moving shipload lots of cargo from one port to another, travel 

with a minimum of ballast and a maximum of cargo in order to maximize revenue 

generated by the voyage. After off-loading its cargo, the vessel typically takes on ballast 

and travels to a different port to load new cargo bound for yet a different port. Thus, these 

vessels routinely discharge all of their onboard ballast at the port in which they load 

cargo. Liner-service vessels, by contrast, travel between ports with a combination of 

cargo and ballast, therefore pumping small volumes of ballast in response to changes in 

cargo distribution. 

Prior to BWM requirements, it was unlikely that all ballast water in a particular tank on a 

liner-service vessel would have originated in a single port, let alone all the ballast water 

aboard the vessel. Current operations and requirements make the contents of a particular 

tank much more likely to come from the same source. 

2.3 Vessel Types and Ownership 

We grouped vessels by service and size using a similar procedure as in the BWM RA 

(USCG 2004). Data developed by the USCG provided the baseline for the vessel types. 

We identified each vessel in Lloyd’s Register of Ships through the seven-digit IMO 

number and recorded the vessel type reported by Lloyd’s Register of Ships for each 

vessel (Table 2.1). We further divided bulk cargo vessels and tank vessels into 

subcategories by dead weight tonnage (DWT) according to commonly used industry size 

ranges (Hunt and Butman 1994). We also placed the largest of these vessels into 

subgroups according to their ability to navigate the Panama and Suez Canals. We 

grouped container vessels into six subgroups based on 20-foot equivalent unit (TEU) 

capacity and their ability to transit the Panama Canal.16 

 

16 Panama Canal operations are such that vessels longer than 294 meters or wider than 32.2 meters are 

unable to pass through the locks. 

33 
Table 2.1 Vessel Type Definitions 

Vessel Type (this analysis) Ship Type (Lloyd’s Register) 

Bulk carriers— 

Handy 

Panamax 

Capesize 

Ore/Bulk/Oil Carriers 

Bulk Carriers 

Cement Carriers 

Great Laker 

Heavy Load Carrier 

Limestone Carrier 

Ore/Oil Carrier 

Sand Carrier 

Wood Chip Carrier 

Tank ships— 

Handy 

Handymax-Aframax 

Suezmax 

VLCCa

ULCCb

Fruit Juice Tanker 

Oil Tanker 

Products Tanker 

Shuttle Tanker 

Tanker 

Vegetable Oil/Wine/Beer Tanker 

Chemical carriers Chemical Tanker 

Gas carriers Liquefied Gas Carrier 

Liquid Petroleum Gas (LPG) Tanker 

Liquid Natural Gas Tanker 

Feeder 

Feedermax 

Handy 

Subpanamax 

Panamax 

Postpanamax 

Containerships 

Passenger ships Passenger Ferry 

Passenger Ship 

General cargo vessel General Cargo 

Deck Cargo Ship 

Refrigerated Cargo 

Pallets Carrier 

Other Specialized Cargo 

RORO RORO Cargo Ferryc

RORO Cargo with Lo/Lo Accessd

RORO Cargo/Vehicle Carrier 

Passenger RORO Car Ferry 

Combination vessel Bulk Carrier + Vehicle Decks 

Passenger/General Cargo 

General Cargo with RORO Facility 

Containership with RORO Facility 

Mobile Offshore Drilling Units (MODUs) 

Integrated Tug Barges (ITBs) 

Fishing Vessels Fishing Catching Vessels 

Processing Vessels 

Charter Fishing Vessels 

Fishing Support Vessels 

Offshore Drilling Vessels (OSVs) 

a. Very Large Crude Carrier 

b. Ultra Large Crude Carrier 

c. RORO is a vessel with roll-on, roll-off access 

34 
d. Lo/Lo is a vessel with lift-on, lift-off access 

As shown in Table 2.2, we grouped vessels by size and service into one of 22 vessel 

types based on data from Lloyd’s Register of Ships and MISLE database. We categorized 

vessels according to these classifications developed in the BWM RA (USCG 2004) to 

more accurately estimate costs based on pump capacities, which vary by vessel type and 

size.17(See Appendix A) 

We have not included the following vessels in the affected population due to the FR 

exemptions: 

(1) Coastwise (Non-Seagoing) vessels that are less than or equal to 1600 Gross 

Register Tons; or less than or equal to 3000 Gross Tons (International Tonnage 

Convention); 

(2) Inland and Great Lakes (Lakers) vessels; and 

(3) Crude Oil Tankers engaged in coastwise trade. 

 

17 Two tanker categories are renamed to agree with current industry practice. “Handymax” is changed to 

“Handymax – Aframax,” since this group reflects tankers from Handymax to Panamax to Aframax size, 

and the group previously described as “Panamax” is renamed “Suezmax.” 

35 
Table 2.2 Potential vessels affected by BWD Standards 

Type of Vessel Classification Criteria a

Vessels Operating in U.S. Waters 

(2007) 

U.S. 

Vessels 

Foreign 

Vessels 

Total 

Number of 

Vessels 

Bulk carriers

Handy <50,000 DWT 11 1,050 1,061 

Panamax 50,000-80,000 DWT 6 509 515 

Capesize >80,000 DWT 0 46 46 

Tank Ships

Handyb <35,000 DWT 10 116 126 

Handymax-Aframax 35,000-120,000 DWT 17 709 726 

Suezmax 120,000-160,000 DWT 7 100 107 

VLCC 160,000-320,000 DWT 4 154 158 

ULCC > 320,000 DWT 0 16 16 

Container ships

Feeder <500 TEU 23 39 62 

Feedermax 500-1000 TEU 1 51 52 

Handy 1000-2000 TEU 26 126 152 

Subpanamax 2000-3000 TEU 52 172 224 

Panamax >3000 TEUb 21 174 195 

Postpanamax >3000 TEUc 30 272 302 

Other vessels

Passenger ship All sizes 138 129 267 

Gas carrier All sizes 6 118 124 

Chemical carrier All sizes 23 513 536 

RORO All sizes 66 321 387 

Combination vessel All sizes 131 22 153 

General cargo All sizes 47 258 305 

Fishing Vessels All sizes 83 16 99 

Other Offshore and 

Coastal Vessels 

All sizes 

757 48 805 

Total 1,459 4,959 6,418 

a. Vessel classifications source: USGC (2007) 

 b. Vessel length and beam within Panama Canal limits. 

c. Vessel length or beam exceed Panama Canal limits. 

36 
This rulemaking is consistent with the IMO BWDS under the International Convention 

for the Control and Management of Ship’s Ballast Water and Sediments (also known as 

BWM Convention) of February 2004. For the purposes of this RA, we consider the 

bottom-line costs of this rulemaking for U.S. vessels18. 

 In order to estimate the cost associated with BWMTS on the U.S. fleet, we needed to 

develop the range of technologies that may be available and the unit costs of these 

technologies. We assume that there will be a broad market for the new BWMS that 

includes both U.S. and foreign vessels, thus improving the range of technologies 

available and the cost efficiencies of production. 

2.4 Fleet Growth and Makeup 

We estimated the U.S. fleet growth rates for the various vessel types using the following 

data sources: U.S. Department of Transportation (MARAD), Clarkson Research Service 

and the U.S. Coast Guard MISLE System Database. Additional details of the U.S. and 

world fleet growth and removal rate calculations are presented in Appendix A. 

We extracted the number of affected vessels from the MISLE database to provide a 

baseline fleet size for year 2007. In projecting fleet growth, we assumed that there would 

be no optimization of the fleet for U.S. traffic. That is, we assumed that all vessels 

involved in international trade will be built to both U.S. and international BWDS 

requirements. 

Table 2.3 shows the assumed growth and removal rates forming the baseline case. We 

estimated the number of new builds each year by adding the number of vessels removed 

to the number of vessels needed to achieve the net growth rate. 

 

18 See appendix D for cost estimates of foreign vessels projected to call in U.S. waters during the 10-year 

period of analysis. 

37 
Table 2.3 U.S. Fleet Growth and Removal Rates 

Type of Vessel Net Growth Rate Removal Rate19

Bulk carriers

Handy -1.24% 2.0% 

Panamax -1.24% 2.0% 

Capesize -1.24% 2.0% 

Tank ships

Handy 2.58% 1.0% 

Handymax-Aframax 2.58% 1.0% 

Suezmax 2.58% 1.0% 

VLCC 2.58% 1.0% 

ULCC 2.58% 1.0% 

Container ships

Feeder 1.99% 2.0% 

Feedermax 1.99% 2.0% 

Handy 1.99% 2.0% 

Subpanamax 1.99% 2.0% 

Panamax 1.99% 2.0% 

Postpanamax 1.99% 2.0% 

Other vessels

Passenger ship 3.36% 2.2% 

Gas carrier20 2.58% 2.0% 

Chemical carrier21 1.99% 2.2% 

RORO 2.59% 2.2% 

Combination vessel 2.65% 2.0% 

General cargo22 1.99% 2.2% 

Fishing Vessels 3.54% 2.2% 

Other Offshore and Coastal 

Vessels 4.87% 3.7% 

 

19 Removal rates for U.S. fleet is the same as the estimated removal rate for the world fleet, due to the fact 

that removal rates are related to vessel age and market conditions. 

20 Same as tank ships 

21 Same as container ships 

22 Same as container ships 

38 
3 Ballast Water Management Costs 

Onboard ballast water management systems (BWMS), which are intended to eliminate or 

greatly reduce the transmittance of live NIS, are an emerging technology. Manufacturers 

have derived some systems from existing shore-side water treatment processes, while 

others involve innovative techniques and technologies. We have analyzed the technology, 

costs, and effectiveness of a variety of systems. Much of the present analysis stems from 

previous work and information in papers submitted to MEPC 53. Many of the 

manufacturers developing alternative BWMS have provided direct feedback on costs, 

capabilities, and testing for their systems. Based on analysis of this information, it 

appears that the technology should be available for installation onboard vessels to meet 

the Alternative 2 (BWD-2) standard, the IMO regulation D-2, by the 2013 initial 

implementation date. 

In this RA, we describe alternative BWMS as generic treatment processes, avoiding 

discussion of specific manufacturers and systems. This approach accommodates 

situations in which multiple vendors may arise or have arisen for a specific treatment 

process. The object of this analysis was to survey the marketplace and describe systems 

currently under development, including the costs and capabilities of those systems. Many 

of the individual systems are patented or have patents pending. We have evaluated the 

following six different treatment (management) processes in detail: Chlorine Generate, 

Chemical Apply, Filter & Radiate, Deoxygenate, Ozone Generate, and Heat Treatment. 

See Table 3.1 for a description of these processes, including some of their characteristics 

and capabilities. We have selected these processes because some vendors are actively 

developing and testing systems that operate based on the indicated treatment process. 

The sources of information regarding the treatment processes are as follows: 

1. MEPC 53/2/14 by The United States, dated 15 April 2005; 

2. MEPC 53/2/16 by Norway, dated 15 April 2005; 

3. MEPC 53/2/6 by Sweden, dated 15 April 2005; 

4. USCG supplied system information; 

5. Herbert Engineering Corporation (HEC) updated the information for the BWMS 

technologies and added additional information including updated assessments of 

capabilities of the system, ability to meet stricter standards, testing carried out and 

planned, cost estimates for installation and operation, and effect on tank 

corrosion. This update included research on current BWMS and manufacturers. 

Some information on current BWMS technology and system capability was more 

complete and of greater use than others; and 

6. Technical information, brochures, technical papers, discussions, and other 

information provided by manufacturers. 

Table 3.1 describes the generic BWMS processes analyzed in this RA. For each, we 

determined when treatment is applied in the ballast cycle, the time required for treatment 

to achieve the desired lethality, and the effect on corrosion in ballast tanks. The effect on 

39 
corrosion is included because it is a significant concern for vessel owners, and this impact 

on a BWMS might influence their choice. 

40 
Table 3.1 Ballast Water Treatment Processes 

Treatment 

Process Method of Treatment When Applied 

Time for 

Lethality(2) 

Effect on 

Corrosion 

Chlorine 

Generate 

Use electrolytic cell to generate 

chlorine and bromine that act as 

biocides. Next, sodium sulfate 

neutralizes the ballast water prior 

to discharge. As long as free 

chlorine exists in the tank, biocide 

will be active so dosage can be 

adjusted to keep biocide always 

active. 

At uptake 

and 

neutralize at 

discharge 

Hours 

High dosage 

levels promote 

steel corrosion 

Chemical 

Apply 

Mix proprietary chemicals with the 

ballast water in metered dosage 

rates at intake to kill living 

organisms. Chemicals degrade 

over time so ballast will be safe to 

discharge. 

At uptake 

via eductor 24 hrs 

High dosage 

levels promote 

steel corrosion 

Filter & 

Radiate 

Filtration of the incoming water, 

usually with self-cleaning 50 

micron filters, in parallel with 

discharge of filtrate to the waters 

where intake takes place. Ballast 

water exposed to a form of 

radiation, such as UV energy or 

other (AOT to generate hydroxyl 

radicals), to kill smaller organisms 

and bacteria. 

At uptake 

for filter & 

UV and at 

discharge 

for UV 

At treatment No effect 

Deoxygenate 

Mix inert gas generated onboard 

with the ballast water, either by a 

venturi eductor or by bubbling 

from pipes in the tanks. This 

removes oxygen from the water 

and lowers pH, therefore killing 

the living organisms. This process 

requires the atmosphere in the 

ballast tank be maintained in an 

inert condition. 

At uptake 

for some 

systems and 

in tanks for 

others 

4 to 6 days Relatively less 

corrosive 

Ozone 

Generate 

Ozone is generated onboard and 

acts as a biocide. It is applied 

during the ballast pumping process 

by eductor either at uptake or 

discharge. It can be combined with 

filtration or other methods of 

treatment. 

At uptake 

for some 

systems and 

at discharge 

for others 

Up to 15 hrs 

Limited effect as 

ozone has short 

life. If treated at 

discharge, no 

effect 

Heat 

Treatment23

Heat ballast water to a 

predetermined temperature (such 

as over 42 deg C) for a period of 

time to kill living organisms. 

Source of heat is main engine or 

oil-fired boiler or water heater. 

During 

voyage and 

in port for 

vessels with 

large 

boilers. 

Hours to 

several days 

Heat promotes 

corrosion 

 

23 We did not consider the Heat Treatment process in the analyses of costs due to the uncertainties related 

to process effectiveness and potential system design and operation (see detailed discussion in Section 3.1) 

41 
 

3.1 Descriptions of the BWMS and Assessment of Meeting the IMO 

Standard24

All analyzed treatment processes have, at some point, been tested—many on full-size 

prototypes on vessels. All of the systems have had biological testing of effectiveness to 

varying degrees, and all of the processes have a proven ability to kill living marine 

organisms. We consider all of these processes to be systems that can be made effective 

for some flow rates and levels of treatment based upon industry information, publicly 

available test results, and Herbert Engineering Corporation (HEC) industry experience 

with marine equipment. Many of the systems need further optimization to determine the 

size of the components, the power requirements (such as for UV), or the lethal dosage 

and the flow rate that can be sustained for a given equipment size. 

Killing small aquatic life with chemical biocides based on chlorine or bromine is a 

proven technology used extensively in shore-side water treatment. We can adjust the 

degree of lethality by changing the dosage rate. However, the main concern with these 

systems is making the water suitable for discharge in order to minimize harm to the 

receiving waters. This can be accomplished by retaining the ballast onboard for a few 

days and allowing the treatment chemical to degrade (Chemical Apply Treatment, as 

claimed by manufacturer) or by adding a neutralizing substance (Chlorine Generate). 

These systems reach effectiveness in hours. The processes that kill the organisms 

consume the chemical biocide. The dosage rate is set at a level that will leave a small 

residual in the tank, which can be effective in killing any remaining organisms. Further 

dosing can be accomplished if the residual is consumed. Setting the correct dosage rate is 

an important consideration in the effectiveness of these types of systems. 

Treatment processes that deoxygenate the ballast water have a similar level of 

effectiveness. We base this rating on recent published reports on the effectiveness of 

testing a full-size unit on a bulk carrier.25 The deoxygenation process occurs either at 

uptake by mixing inert gas with the water by an eductor or by bubbling the gas into the 

24 New information about additional Ballast Water Management Systems was available after the 

completion of the NPRM RA. We have not incorporated these new findings in our analysis due to the 

complexities of the calculations used in estimating costs per system type, which would require an extensive 

re-estimation of all costs associated with this RA. The new systems available are Hydroyclone – 

Electrochlorination and Menadione or Vitamin K. 

The Hydroyclone – Electrochlorination system utilizes two methods to optimize the reduction of living 

organism in ballast water. The system’s initial operation (Hydoyclone) is intended to filter the in-coming 

ballast water by forcing the water into a high velocity rotational centrifugal motion resulting in the 

separation between particles (organisms) and water. Then the Electrochlorination process is introduced to 

either the particles and or the water to maximize the neutralization of any living organisms. 

Menadione or Vitamin K (proprietary name Seakleen), is a natural product that is used as a disinfectant for 

the neutralization of living organisms in ballast water. Method of use is as a chemical compound (powder 

or liquid) that is poured into the ballast tank. 

 

25 These systems require an inert gas generator and may require installation of a closed vent piping system 

for the ballast tanks, plus additional piping if the gas is distributed by a bubbler system. 

42 
ballast tanks by a dispersed array of bubbler pipes. The hypoxic inert gas will drive the 

oxygen out of the water. The presence of carbon dioxide in the inert gas stream will also 

significantly lower the pH of the water. The combination of low oxygen levels and low 

pH is toxic to most marine organisms. However, the process takes several days to 

complete and the ballast water needs an inert atmosphere for the entire period. Thus, the 

ballast tanks need to connect to a central inert gas system with a closed venting system 

similar to cargo tanks on tankers. This requires modification of the tanks in addition to 

the installation of a system to apply the inert gas to the ballast water. According to the 

research findings, when the ballast water is discharged, the hypoxic and low pH ballast 

water quickly returns to normal levels upon mixing with the receiving waters. According 

to research, the time required to achieve the desired kill rates is about 3 to 6 days, which 

may pose a problem for vessels on short routes. Additionally, some organisms, such as 

spores, are more resistant to this treatment method, particularly if the oxygen levels and 

pH levels are not as low as intended. 

Treatment processes based upon Filtration and Radiation are considered capable of 

meeting the BWD-2 standard, but testing done to date shows it may not be as effective as 

some of the other processes. 

For many of these systems, the filtration design can remove organisms above 50 microns 

in size, and filtration takes place at uptake with the filtrate returned to the source waters. 

One vendor proposes a portable system for ballast discharge. For this design, the filtrate 

needs to be disposed of ashore or retained onboard for disposal in the deep ocean. Some 

of the problems linked to filtration systems are that excessive sediment can overload 

them and some organisms can slip through filters because of their shape. Smaller 

organisms require a secondary treatment, such as ultra violet (UV) radiation or processes 

that use photocatalytic effects to create hydroxyl radicals. Both UV and hydroxyl radicals 

damage cells so that life is no longer sustainable. These technologies are well established; 

for example, UV is widely used in water purification. However, UV and other 

electromagnetic radiation-based treatments are sensitive to the transmittance capacity of 

the water and can be less effective in cloudy water and when insufficient wattage is 

applied. These systems require no residence time in the tank for the treatment to be 

effective. 

A fifth treatment process is the generation of ozone onboard. The systems for this 

treatment are less established compared to the other treatment processes considered. 

Application of the correct dosage depends on the condition of the incoming water and, 

therefore, these systems require complex controls and an ozone generator. Additionally, 

because ozone is a hazardous gas, the process becomes more complicated. Residuals, 

such as bromine-based compounds, may persist in the discharged water. Ballast residence 

time is not a concern with these types of systems because some of the procedures work at 

discharge only and others require only hours of residence time in the tank. 

While the use of heat as a mean to sterilize water is well documented and utilized 

extensively onshore, there is uncertainty about whether sufficient heat is available 

43 
 

onboard to meet the required temperature and maintain it for the requisite period of time. 

These uncertainties include: 

(1) The degree to which additional heat generators are needed to achieve the required 

heat; 

(2) Whether sufficient residence time is available at the required temperature; 

(3) The very large differences in allowable ballast flow rate depending on the 

temperature of the incoming water; 

(4) The significant impact of ambient conditions; and 

(5) Whether heat is only available at sea when the main engine is under full power. 

The Heat Treatment system may require operation while underway if there is insufficient 

heat available in port26 to achieve the required temperatures to kill the necessary number 

of organisms during ballast water loading. This system may not be practical except in 

circumstances in which recirculation of ballast water between the heating elements and 

the individual tanks is feasible and desirable. We did not consider Heat Treatment in the 

analyses of costs and performance described below because of the uncertainties identified 

above. Of particular concern is the large range in capital and operating costs, depending 

on the heat sources onboard the vessel and whether additional heat sources are necessary 

to achieve a fully functional heat treatment system on a variety of vessels. This process 

did not appear to offer lower costs or more effectiveness than competing treatment 

processes; therefore, we will not discuss this option further. 

We evaluated the following treatment processes and found that they have well-defined 

systems under development with the potential to meet the IMO standard: Chlorine 

Generate, Chemical Apply, Filter & Radiate, Deoxygenate and Ozone Generation. These 

processes are included in the analysis of their suitability for the various categories of 

vessels and the costs to acquire, install, and operate them. 

26 The source of heat will normally be the main propulsion system. This system may not be active in port 

or not operating at a level sufficient to provide heat to the ballast water treatment system. 

44 
3.2 Applicability of BWMS to Vessel Types 

In Table 3.2, we evaluated twenty-two different categories of vessels for this project. 

Table 3.2 Suitability of BWMS to Vessel Type 

Vessel Category Vessel Size Range Chlorine 

Generate 

Chemical 

Apply 

Filter & 

Radiate Deoxygenate Ozone Generate 

Bulk carriers

Handy < 50,000 DWT Yes Yes Yes Yes Yes 

Panamax 50,000–80,000 DWT Yes Yes Yes Yes Yes 

Capesize > 80,000 DWT Except large Yes Except large Yes Yes 

Tank ships

Handy < 35,000 DWT Yes Yes Some 

systems 

Yes Some 

systems 

HandymaxAframax 35,000–120,000 DWT Yes Yes Some 

systems 

Yes Some 

systems 

Suezmax 120,000–160,000 

DWT 

Yes Yes Some 

systems 

Some 

systems 

Some 

systems 

VLCC 160,000–320,000 

DWT 

No, too large Yes No, too large Some 

systems 

Some 

systems 

ULCC > 320,000 DWT No, too large Yes No, too large Some 

systems 

Some 

systems 

Containerships

Feeder < 500 TEU Yes Yes Yes Yes Yes 

Feedermax 500–1000 TEU Yes Yes Yes Yes Yes 

Handy 1000–2000 TEU Yes Yes Yes Yes Yes 

Subpanamax 2000–3000 TEU Yes Yes Yes Yes Yes 

Panamax > 3000 TEU Yes Yes Yes Yes Yes 

Postpanamax > 3000 TEU Yes Yes Yes Yes Yes 

Other vessels

Passenger ship All sizes Yes Yes Yes Yes Yes 

Gas carrier All sizes Except large Yes Except large Some 

systems 

Some 

systems 

Chemical carrier All sizes Except large Yes Except large Some 

systems 

Some 

systems 

RORO All sizes Yes Yes Yes Yes Yes 

Combination vessel All sizes Yes Yes Yes Yes Yes 

General cargo All sizes Yes Yes Yes Yes Yes 

Fishing Vessels All sizes Yes Yes Yes Yes Yes 

Other Offshore and 

Coastal Vessels 

All sizes Yes Yes Yes Yes Yes 

Note: For tankers, chemical carriers, and gas carriers, some systems are not suitable, either because they 

are not designed to be installed in a hazardous atmosphere such as a tanker pump room or because they are 

not produced at the high capacity required for large tankers. 

3.3 Acquisition and Installation Costs 

45 
Manufacturers have supplied estimates of the acquisition and installation costs for the 

alternative BWMS. Acquisition costs include the following: costs for designing the 

system, license fees, regulatory approvals, cost to purchase equipment, and costs for 

developing a specification suitable for installation of the unit on the desired vessel. We 

also included in the cost estimate the necessary changes to existing piping, equipment, 

arrangement, and structure. For new vessel construction, the information would be 

provided to the shipyard design staff so that they could properly incorporate the 

alternative BWMS into the ballast system and machinery space. Installation costs include 

transporting the system to the installation location, providing service technicians, 

surveying by regulatory agencies, carrying out required modifications to the vessel, 

installing the system onboard, and testing. Some of the less intrusive systems can be 

installed with the vessel in service, but many systems require the vessel to be out of 

service for several days to make the necessary modifications. The Chlorine Generate, 

Chemical Apply, Ozone Generate at discharge (if container mounted) and Filter and 

Radiate are easy to install on smaller vessels. The Deoxygenate systems would require a 

modification to the ballast tank venting system and the vessel to be out of service for 

several days or weeks. Based on information from system developers and manufactures, 

these systems do not require the vessel to be drydocked for installation. 

Costs associated with out-of-service time are not included in the installation cost 

estimates because we assumed the work would be completed either with the vessel on its 

normal drydocking schedule or during other regularly scheduled maintenance or repair 

out-of-service period. Installation costs would vary depending on the geographic location 

of the modification. 

In general, the cost of incorporating an alternative BWMS into a new vessel would be 

lower than an existing vessel because the required space and interface connections for the 

ballast and electric power systems can be designed in the most efficient manner without 

having to modify the vessel. However, the new construction designs and building cycle 

takes several years. Problems may arise if industry is not provided adequate 

implementation time to incorporate the systems into the initial design of some new 

vessels; therefore, a retrofit would be the only feasible option. 

Because this type of specialized equipment is difficult to independently price, the cost 

analysis relies largely on manufacturer provided data. Manufacturers supplied costs for 

equipment and installation. We estimated installation costs if unavailable from the 

manufacturers. Table 3.3 shows the high and low ranges of costs to acquire and install 

systems based on four nominal capacities of systems. 

 

46 
Table 3.3 Installed Costs ($000) per Vessel for Typical BWMS 

System Size 

(m3/hr) 

Costs for each 

process 

Chlorine 

Generate 

Chemical 

Apply 

Filter & 

Radiate Deoxygenate Ozone Generate 

250 

Acquire 250 200 175-250 100-400 200-250 

Install, High 100 100 100-110 100-150 100-125 

Install, Low 50 50 50-60 65-100 50-65 

750 

Acquire 350 225 390-450 300-400 375-400 

Install, High 150 150 150-175 150-250 150-200 

Install, Low 75 75 75-100 100-150 75-125 

2,000 

Acquire 500 275 650-700 400-625 650-750 

Install, High 200 200 325 220-450 250-400 

Install, Low 100 100 200 120-250 125-250 

5,000 

Acquire NA 400 NA 512-900 1,150-1,825 

Install, High NA 250 NA 255-750 375-700 

Install, Low NA 125 NA 150-425 200-400 

Source: Herbert Engineering Corporation. Note: We indicate a range of costs for a process when several 

manufacturers for that process were part of this analysis. We provide a single cost where a single 

manufacturer supplied data for that system. NA means the system is not available in that size. 

We applied the above costs to the 22 categories of vessels evaluated in this analysis. 

Because this work occurs at a wide variety of ports, we considered it suitable to use an 

average installed cost (average cost of acquisition and installation). 

Tables 3.4 provides the average ballast pumping capacities for each category of vessel 

and state the costs for the systems of the indicated capacities (using the data in Table 3.3) 

for the U.S fleet. Installed costs vary, depending on the technology utilized and the cost 

of the equipment to implement that process. However, variations in cost are also related 

to a process’s development stage. 

 

47 
Table 3.4 Estimated Average Installed Cost ($000) for the U.S. Fleet by Vessel Category and BWMS 

Vessel Category 

Est. Ballast 

Pumping 

Capacity 

(m3/hr) 

Chlorine 

Generate Chemical Apply Filter & Radiate Deoxygenate Ozone Generate 

Bulk carriers 

Handy 1,300 764 419 801 837 842 

Panamax 1,800 668 459 961 1007 1062 

Capesize 3,000 867 533 641 1267 1,608 

Tank ships 

Handy 1,100 556 403 737 769 754 

Handymax/ 

Aframax 2,500 725 504 750 1061 1,292 

Suezmax 3,125 894 541 641 1167 1,563 

VLCC 5,000 NA 650 NA 1650 2,525 

ULCC 5,500 NA 615 NA 1488 2,375 

Containerships

Feeder 250 350 300 360 550 375 

Feedermax 400 395 323 440 580 443 

Handy 400 395 323 440 580 443 

Subpanamax 500 425 338 462 563 488 

Panamax 500 425 338 462 563 488 

Postpanamax 750 500 375 625 650 600 

Other vessels

Passenger ship 250 350 300 360 550 375 

Gas carrier 4,800 NA 638 NA 1612 2,433 

Chemical carrier 600 455 353 546 620 533 

RORO 400 395 323 440 580 443 

Combination vessel 400 395 323 440 580 443 

General cargo 400 395 323 440 580 443 

Fishing Vessels 250 350 300 360 550 375 

Other Offshore and 

Coastal Vessels 325 319 258 346 508 347 

Source: Herbert Engineering Corporation. Note: The costs are derived from HEC information in Table 3.3. 

Data in the table reflect the costs of both installation and operation for the US fleet only. 

 

48 
 3.4 Operation Costs

The operational costs of a BWMS have several components. They are as follows: 

1. Energy, usually electrical, to power the system. 

2. Consumables utilized in operating the system. For some treatments, chemicals are 

consumed in the process. Others utilize lamps or filters that must be replaced 

periodically. The manufacturers for each process identified these. 

3. Crew labor to operate the system. 

4. Periodic maintenance and servicing of the system. 

5. Replacing components as they wear out or become defective. 

6. Other logistics, including training and technical information. 

The manufacturers supplied us with estimates for the energy needs. Based on these 

estimates, we developed a nominal cost per cubic meter of pumped ballast. 

Manufacturers also advised us on the normal consumables expended in the operation of 

the system. For example, using this information, we estimated the costs associated with 

chemical biocides on a cubic meter processed basis. Some consumables (such as UV 

lamps) are required after a certain quantity of hours of operation. We converted these 

costs into per cubic meter costs utilizing the pumping rate of the system. The cost of 

required crew labor was not a significant cost to manufacturers because most systems 

featured automatic controls in varying forms. We added all the direct operational costs 

together into an order of magnitude cost per cubic meter treated. We evaluated the costs 

for four nominal system sizes. Table 3.5 includes the estimated direct operational costs 

per cubic meter treated, covering costs for energy, consumables, and labor. 

Although not a direct cost of operation, the costs for service technicians, maintenance, 

repair, and replacement of components can be the largest cost component of a BWMS. 

The BWMS generally contain many expensive components, as evidenced by the high 

acquisition costs, and many of these components require servicing and periodic 

maintenance. Additionally, many components will require replacement over a vessel’s 

lifetime. As an estimating guide based on HEC input, we assumed that half the initial cost 

of a system was associated with mechanical and electrical components that need 

maintenance, repair, and replacement over time. The other half focuses on design fees, 

license fees, structural elements, etc. Based upon marine industry maintenance and repair 

experience, we have taken the annualized maintenance and replacement costs at 10 

percent of the purchase cost for machinery per year. 

To determine the maintenance costs per year for each management system, HEC 

averaged the different vessel category’s acquisition costs in Tables 3.4, divided it by two 

to account for machinery and electrical equipment costs, and multiplied that figure by 10 

percent to yield a net annualized maintenance cost of 5 percent of the initial cost per year. 

We then divided the estimated annual costs for the four nominal system sizes by the 

estimated annual ballast flow for each system equal to about 100 times the system flow 

rate to get the estimated annual maintenance cost per cubic meter of treated ballast. As 

can be seen, the maintenance and replacement costs are larger than the direct operating 

49 
costs. As expected from economies of scale, the maintenance and replacement costs per 

cubic meter treated get smaller as the system size increases because large systems cost 

less to buy and maintain per cubic meter treated. 

Table 3.5 Operation Costs per Cubic Meter Treated by Management Process ($/m3) 

System 

Size 

(m3/hr) 

Cost Component Chlorine 

Generate 

Chemical 

Apply 

Filter & 

Radiate Deoxygenate Ozone Generate 

250 

Direct Operation $0.02 $0.08 $0.05 $0.05 $0.05 

Maintenance & 

Replacement $0.42 $0.33 $0.36 $0.17 $0.38 

Total $0.44 $0.41 $0.41 $0.22 $0.43 

750 

Direct Operation $0.02 $0.08 $0.05 $0.05 $0.05 

Maintenance & 

Replacement $0.23 $0.15 $0.28 $0.20 $0.26 

Total $0.25 $0.23 $0.33 $0.25 $0.31 

2,000 

Direct Operation $0.02 $0.08 $0.05 $0.05 $0.05 

Maintenance & 

Replacement $0.13 $0.07 $0.17 $0.13 $0.18 

Total $0.15 $0.15 $0.22 $0.18 $0.23 

5,000 

Direct Operation NA $0.08 NA $0.05 $0.05 

Maintenance & 

Replacement NA $0.03 NA $0.08 $0.12 

Total NA $0.11 NA $0.13 $0.17 

Source: Herbert Engineering Corporation. Note: NA means the system is not available in that size. 

Table 3.6 shows the total estimated operating costs per year for each category of vessels 

analyzed in this RA. We obtained these values by interpolating the data for total 

operational costs based on nominal systems sizes as given in Table 3.5, assuming the 

average pumping capacity for each vessel category as given in Tables 3.4. 

50 
Table 3.6 Estimated Average Operational Cost per Cubic Meter of Ballast Treated by Vessel 

Category and Treatment Process ($/m3

) 

Vessel Category Chlorine 

Generate 

Chemical 

Apply 

Filter & 

Radiate Deoxygenate Ozone Generate 

Bulk carriers

Handy $0.21 $0.19 $0.28 $0.22 $0.27 

Panamax $0.17 $0.16 $0.24 $0.19 $0.24 

Capesize $0.13 $0.14 $0.18 $0.16 $0.21 

Tank ships

Handy $0.22 $0.21 $0.30 $0.23 $0.29 

Handymax/Aframax $0.11 $0.12 $0.17 $0.15 $0.20 

Suezmax $0.13 $0.14 $0.17 $0.16 $0.21 

VLCC NA $0.11 NA $0.13 $0.17 

ULCC NA $0.11 NA $0.13 $0.17 

Containership

Feeder $0.44 $0.41 $0.41 $0.22 $0.43 

Feedermax $0.38 $0.36 $0.39 $0.23 $0.39 

Handy $0.38 $0.36 $0.39 $0.23 $0.39 

Subpanamax $0.35 $0.32 $0.37 $0.24 $0.37 

Panamax $0.35 $0.32 $0.37 $0.24 $0.37 

Postpanamax $0.25 $0.23 $0.33 $0.25 $0.31 

Other vessels

Passenger ship $0.44 $0.41 $0.41 $0.22 $0.43 

Gas carrier NA $0.21 NA $0.13 $0.17 

Chemical carrier $0.31 $0.29 $0.36 $0.24 $0.35 

RORO $0.38 $0.36 $0.39 $0.23 $0.39 

Combination vessel $0.38 $0.36 $0.39 $0.23 $0.39 

General cargo $0.38 $0.36 $0.39 $0.23 $0.39 

Fishing Vessels $0.44 $0.41 $0.41 $0.22 $0.43 

Other Offshore and 

Coastal Vessels $0.43 $0.38 $0.40 $0.22 $0.42 

Source: Herbert Engineering Corporation. Note: NA means the system is not available in that size. 

3.5 Discussion 

Cost Uncertainty 

Several issues regarding the certainty of the estimations made for this RA merit 

discussion. Although significant progress has been made in the development of the 

systems able to meet the BWDS, these technologies are in continual development and 

refinement. 

We base all costs on manufacturer estimates for the prices they hope to receive for their 

equipment. The rigors of the competitive marketplace have not refined prices due to 

production efficiencies and competitive pressures. Additionally, the ease of installation 

onboard vessels depends on the vessel arrangement and its piping and machinery 

systems. Vessels within the same basic category can have significant differences that 

would affect the ease of installation. The costs for individual ships could vary widely 

51 
from what is estimated for that category of vessel. Therefore, it is possible that estimated 

installation costs could vary with location or due to competition in the market place. 

Similar variance is possible for operating costs. 

Approval Technology Testing 

The technologies discussed in this RA will be subjected to the USCG BWMS approval 

process before being available in the marketplace. The USCG is establishing an approval 

program, including requirements for designing, installing, operating, and testing BWMS 

to ensure these systems meet required safety and performance standards. Currently, 

manufacturers are submitting BWMS designed to meet the BWDS. All indications are 

that there will soon be technologies available on the market to allow vessels to meet this 

standard (see FR for detailed information on BWDS receiving approval). Nevertheless, 

testing is still an ongoing process as technologies are adapted to the different vessel 

design, operations and environmental conditions. 

Time Frame for Implementation 

There may be a shortage of equipment to implement BWMS on a large scale around the 

world in a short time frame. Because this is a new product, the specific components 

needed for this equipment are most likely not being manufactured today on the scale 

needed. Certainty about the requirements, testing, and approvals is needed before 

companies will invest in the facilities for large-scale production. There may be a time lag 

of several years from the time there is significant certainty to justify investment until 

equipment is produced and delivered on a wide scale. Additionally, the time lag between 

technical development of the regulatory requirements and enforcement of the regulation 

should be taken into consideration. Once the regulatory regime is articulated and actual 

production and installation have begun, we consider it relatively easy to install a system. 

The equipment for installation is often similar to commercially available equipment and 

production can be increased to meet demand. However, any specialized components may 

not be immediately available. The normal vessel repair industry can do the installation if 

it does not require special training or tools. 

Safety Issues 

The purpose of BWMS is to kill living organisms. The processes utilize chemicals, 

radiation, and equipment that create conditions that may be hazardous to human health. 

There is an existing regulatory environment onboard vessels and in industry regarding 

safety precautions and handling techniques for hazardous chemicals. We assume that any 

necessary modifications or special handling procedures will be resolved by individual 

vessels during the choice and installation of equipment. Manufacturers who use 

chemicals in the system have proposed transporting and restocking chemicals onboard 

using only their trained service agents, not the vessel’s crew. Manufacturers would also 

like to set up procedures for disposal of unused chemicals in the event that the system on 

a vessel needs to be disabled or dismantled. Most of the BWMS are sealed processes, in 

which case the vessel’s crew would not handle or apply the chemicals by hand. Sealed 

52 
pipes transfer chemicals from the storage tanks to the processing equipment. To prevent 

discharge of large amounts of hazardous chemicals during a vessel casualty, requirements 

are needed to ensure that the quantities onboard should be limited and that they should be 

stored in sturdy containers in a protected location. 

Systems that employ radiation, such as UV-based systems, require safeguards in place to 

ensure against human exposure to the UV and that users are aware of any special 

precautions needed for disposing of the UV lamps. Vessel operators should already be 

aware of these precautions as UV equipment is currently used onboard vessels for potable 

water sterilization. Chlorine generation systems have already been used onboard vessels 

on a small scale for eliminating fouling in vessel seawater cooling systems. With regard 

to the Deoxygenate process, in which the ballast tanks need to be inerted, tanks must be 

well-vented prior to personnel entering them. Tankers currently have experience with 

inerted cargo tanks, but most dry cargo vessel crews have no such experience. If there are 

cracks in the ballast tank bulkhead, inert gas may flow into adjacent spaces, including 

cargo holds or void spaces, posing a hazard to anyone entering those spaces. Good tank 

entry practice is to test the atmosphere in any enclosed space, such as a tank, for oxygen 

prior to entry. These procedures need to be rigorously applied onboard a vessel that 

employs a process utilizing inert gas. Overall, we believe the safety issues with regard to 

the operation of BWMS onboard vessels can be managed. 

Environmental Concerns 

BWMS that employ chemicals or generate chemicals onboard need to be designed in a 

manner that ensures that no active biocides are discharged overboard. For many of the 

systems, the biocide has a short life and would degrade by the time the vessel discharges 

ballast. Other manufacturers have determined that the discharged ballast water would 

have residual biocide and they have incorporated features into their systems to neutralize 

the residual chemicals. This typically involves adding a neutralizing agent, which makes 

it safe to discharge ballast overboard. Manufacturers that employ the Deoxygenate

process have tested the effect of the hypoxic and low pH water on the receiving waters 

and have determined that it dissipates within a few meters of discharge. There are 

pending guidelines from IMO about the testing requirements for systems that employ 

active substances, and these requirements cover verification of the effects on the 

environment of discharging ballast water treated by these systems. 

Effect on Corrosion in Tanks 

BWMS processes have varying effects on the corrosion of steel in ballast tanks. Several 

systems have no effect, such as the ones that filter and irradiate the water. The systems 

that deoxygenate the water actually reduce corrosion in tanks because there is less 

oxidation of the steel at reduced oxygen levels (Tamburri and Ruiz, 2005). Furthermore, 

manufacturers indicate that because these processes do not fully remove all oxygen, 

anaerobic conditions do not exist in the tanks; therefore, growth of anaerobic bacteria 

53 
would not be promoted. Possible establishment of anaerobic conditions would be of 

concern because anaerobic bacteria are able to accelerate corrosion. 

BWMS that apply chemicals such as chlorines and ozone generally create oxidants that 

can promote corrosion. If a tank is well-coated with a hard epoxy, there should be limited 

deleterious effects at the concentrations of chemicals required for ballast treatment. 

However, if tank coatings have deteriorated, then we expect accelerated corrosion. In 

addition, if we increase dosage rates to meet stricter standards, corrosion will increase. 

The heat treatment process also promotes corrosion in ballast tanks. This is an effect well 

known to the marine industry because ballast tanks adjacent to heated oil tanks suffer 

from accelerated coating breakdown and steel corrosion. Quality of coatings is an 

important consideration in adopting this system. 

It is difficult to quantify the impact of these processes on corrosion before 

implementation of the systems or collection of actual corrosion data. We do not anticipate 

that corrosion will be a significant cost driver except, perhaps, in the case of the heat 

treatment system, and, therefore, the effect of corrosion is not included in the cost 

analysis. 

Zero Discharge as a Means of Meeting Alternative 5 Ballast Water Discharge 

Standard 

The most effective way to stop the spread of NIS through BWD is by eliminating the 

discharge of ballast water containing live organisms into U.S. waters. This solution is 

difficult to apply to all vessels because of the wide variety of vessels, cargoes, and the 

need of some vessels to discharge ballast in U.S. waters for safety reasons. Nevertheless, 

the primary strategy for eliminating the discharge of live organisms is to discharge no 

ballast and, if the vessel has to discharge ballast, to take measures to ensure sterilization 

of the ballast. We have outlined some possible approaches in the following discussion. 

Sterilized Ballast 

There are several approaches to sterilizing ballast water for discharge in ports; however, 

none is without significant cost and many require some change in vessel operations or 

investment in facilities and means of transport. Approaches to achieve sterile ballast 

include: 

• Use fresh water for ballast: Clean fresh water taken from shore is one approach to 

ensure sterilization of ballast water. The principal difficulties in using fresh water for 

vessels that normally load and discharge ballast are its cost and availability. 

• Shore-based Treatment: Seawater ballast could be treated in a shore-based facility 

rather than onboard the vessel. A vessel could take on treated ballast or ballast taken 

on elsewhere could be discharged to a facility for treatment and disposal. Investment 

in widespread facilities for ballast treatment would cost millions of dollars, even at a 

regional level (URS/Dames & Moore 2000), and would most likely be paid for by 

54 
fees to process the ballast. Considering the high cost of implementation, shoreside 

sterilization also appears to be a niche solution. 

No Discharge of Ballast 

Besides the sterilization of ballast water, the other alternative to obtain zero discharge of 

live organisms is for vessels to avoid discharging ballast in ports or coastal waters. As 

discussed in this RA, many vessels have already adopted this policy for many of their 

U.S. ports calls, particularly the ports with the most stringent regulation of ballast 

discharge. 

One approach is to change vessel designs to make vessels more multi-purpose so they can 

carry a larger variety of cargoes. This would improve the possibility for backhaul 

cargoes. A zero discharge solution would encourage a new round of innovative solutions, 

but would no doubt also significantly increase overall costs. 

In evaluating the possibility of eliminating discharge of ballast, we divide vessels into 

two primary groups: 

1. Vessels that carry ballast and cargo: Vessels that normally carry a mix of ballast and 

cargo are the ones for which this approach is most practical. These vessels would 

normally not discharge or take on much ballast in any port and might achieve zero 

discharge. 

Vessels that normally carry a mix of cargo and ballast are: 

• Containerships 

• RORO ships 

• General cargo ships 

• Combination ships 

• Passenger ships 

2. Vessels that carry ballast or cargo: Some vessel types carry full loads of cargo from 

port to port and sail from discharge ports back to the loading port in a ballast condition. 

These vessels generally carry bulk cargoes, either dry or liquid. Such vessels would 

suffer the most from a no discharge of ballast operating mode. The weight of ballast 

onboard when entering the loading port would reduce by the same weight the amount of 

cargo that can be loaded, since these vessels normally take on full loads of cargo. This 

lost revenue represents the cost of implementing a zero-discharge standard. 

The vessels that carry either ballast or cargo are: 

• Tankers 

• Bulk carriers 

• LNG ships 

• Chemical carriers 

55 
For these vessels, the quantity of ballast onboard for a normal sea passage is roughly 35 

percent of the full load cargo weight. In good weather, it may be possible for these 

vessels to deballast as they approach the loading port to a state where the ballast weighs 

only 10 to 20 percent of the full load of cargo weight. In addition, vessels such as oil 

tankers and LNG carriers generally arrive at U.S. ports fully laden with cargo. Such 

vessels will normally not discharge ballast, but will take on ballast for the return leg, and 

thus could meet the zero-discharge standards for U.S. arrivals. 

56 
4 Ballast Water Management Systems Cost 

In this chapter, the system costs developed in the previous chapter are applied to the 

affected population. The analysis covers a 10-year period, when the requirements for 

BWM first stipulate meeting BWD performance. 

We have estimated the number of vessels that will have to install or retrofit ballast water 

systems each year for each vessel type based on the phase-in schedule (presented on 

Table 1.3. We apply these data together with the one-time capital and installation costs to 

develop overall implementation costs for U.S. vessels. Capital installation costs are based 

on the type of systems presented in Table 3.1. 

This rulemaking is consistent with a multi-lateral agreement at the IMO. For the 

purposes of this RA, we consider the bottom-line costs of this rulemaking to involve U.S. 

vessels. Nevertheless, we anticipate that the development of treatment technology will 

involve the world fleet, not the U.S. fleet alone. 

In order to estimate the cost associated with BWMS on the U.S. fleet, we needed to 

develop the range of technologies that may be available and the unit costs of these 

technologies. We assume that there will be a broad market for the new BWMS that 

includes both U.S. and foreign vessels, thus improving the range of technologies 

available and the cost efficiencies of production. 

4.1 Calculation Approach for Costs of Ballast Water Discharge 

Standards 

In this section, we describe the costs to install and operate BWMS. We have developed 

low and high estimates for installed costs for systems that would be applicable to the 

various vessel types. 

The BWMS industry is in its formative stage, and we expect scale-based efficiencies to 

evolve. As noted in the previous chapter, the costs should decrease over time, but the 

extent is unknown. 

Under the current rulemaking, implementation of BWMS would be required starting in 

December 2013 for new vessels and phased in, starting in 2014, for existing vessels. We 

use the growth assumption (including removal rates) as outlined in Chapter 2 to 

determine the size of the fleet and the number of new vessels each year. Projecting 

growth trends out 10 years is an uncertain process. Vessels affected in this FR will be 

required to meet the discharge standards by 2018 (based on the phase-in and drydocking 

schedules). In our cost model, for the period beyond 2018, we account only for the new 

vessels. 

Tables 4.1 presents the installation costs for the U.S. fleet. The installation costs were 

calculated based on the average costs for each available ballast water system. The low 

57 
costs presented on the tables below are related to the cheapest system available and the 

high costs are related to the most expensive system available. 

Table 4.1 Installed Ballast Water System Costs ($000) for the U.S. Vessels 

Vessel Type Installed Costs in 2007 

Low High 

Bulk carriers 

Handy 419 842 

Panamax 459 1,062 

Capesize 533 1,608 

Tank ships

Handy 403 769 

Handyman-Aframax 504 1,292 

Suezmax 541 1,563 

VLCC 650 2,525 

ULCC 615 2,375 

Container ships

Feeder 300 550 

Feedermax 323 580 

Handy 323 580 

Subpanamax 338 563 

Panamax 338 563 

Postpanamax 375 650 

Other vessels

Passenger ships 300 550 

Gas carriers 638 2,433 

Chemical carriers 353 620 

RORO 323 580 

Combination vessels 323 580 

General Cargo 323 580 

Fishing Vessels 300 550 

Other Offshore and Coastal 

Vessels 258 508 

 Source: Herbert Engineering Corporation (reference Table 3.4) 

 

58 
 In practice, many vessels do not discharge in U.S. waters and many could adjust their 

operations to avoid discharge. For example, many container vessels already set up their 

ballast before arriving in the EEZ based upon advance information about the next 

departure load condition. We anticipate that this will become the practice for many of 

these vessels independent of the imposed standard. In theory, these vessels could avoid 

the capital costs entirely. However, vessel owners will not consider the U.S. approach in 

isolation. For example, tankers that discharge no ballast in the U.S. may discharge ballast 

in other ports and so would install a BWMS if required to do so by any of the loading 

ports along their expected trading routes. In general, the likely approach would be to 

acquire the least expensive and easiest system to install and manage the ballast so that all 

the ballast onboard could be discharged at any time if needed. 

Vessels built before December 1, 2013 with ballast capacities between 1,500 and 5,000 

cubic meters will be required to meet the discharge standards on first scheduled 

drydocking after January 1, 2014 (Table 1.2). Oceangoing vessels are required to drydock 

twice every 5 years27; therefore, we assume that vessel owners will phase-in the 

installation over a period of 2.5 years after the compliance date. We assume that 40 

percent will install BWMS each year in the first two years and 20 percent in the last year 

of the compliance FR requirement. 

In 2016, the remainder of the fleet built before December 1, 2013 and certain new vessels 

will be required to meet the BWDS. In this case, we have assumed that 40 percent of the 

population will install the system each year in the first two years and 20 percent in the 

last year of the compliance requirement. Given these assumptions and the projected fleet 

growth as defined in Chapter 2 (Table 2.3), the number of vessels undergoing BWMS 

installations is as shown in Table 4.2. In order to account for the impact of these 

assumptions we have performed a sensitivity analysis on the effect of compliance 

percentage per year and the total cost of the rulemaking for U.S. vessels (section 6.1). 

 

27 Drydocking requirements are specified in the following CFRs: 46 CFR 71.50-3 (passenger vessels); 46 

CFR 176.600 (small passenger vessels); 46 CFR 126.140(a) (offshore supply vessels); 46 CFR 31.10-

21(tank vessels), and 46 CFR 91.40-3 (freight vessels) 

59 
60 

Table 4.2 Projected number of U.S. Vessels undergoing BWMS Installation by Year and Type* 

Vessel type 

Year 

Total 1 2 3 4 5 6 7* 8* 9* 10* 

Bulk carriers

Handy 0.1 0.1 3.8 3.8 1.9 0.1 0.1 0.1 0.1 0.1 9.9 

Panamax 0.0 0.0 2.1 2.1 1.0 0.0 0.0 0.0 0.0 0.0 5.4 

Capesize 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Tank ships

Handy 0.4 0.4 4.9 4.9 2.7 0.5 0.5 0.5 0.5 0.5 15.7 

HandyAframax 0.7 0.7 8.3 8.3 4.5 0.8 0.8 0.8 0.9 0.9 26.7 

Suezmax 0.3 0.3 3.4 3.4 1.9 0.3 0.3 0.3 0.4 0.4 11.0 

VLCC 0.2 0.2 1.9 1.9 1.1 0.2 0.2 0.2 0.2 0.2 6.3 

Containerships

Feeder 2.9 2.9 9.4 8.5 4.8 1.1 1.2 1.2 1.2 1.2 34.5 

Feedermax 0.0 0.0 0.5 0.5 0.3 0.0 0.1 0.1 0.1 0.1 1.5 

Handy 1.2 1.2 11.7 11.7 6.5 1.3 1.3 1.3 1.4 1.4 39.0 

Subpanamax 4.6 4.6 22.3 21.2 11.9 2.6 2.6 2.7 2.7 2.8 78.0 

Panamax 2.0 2.0 8.9 8.4 4.7 1.0 1.1 1.1 1.1 1.1 31.5 

Postpanamax 1.3 1.4 13.5 13.5 7.5 1.5 1.5 1.5 1.6 1.6 45.0 

Other vessels

Passenger 

ships 17.8 18.2 65.1 61.2 36.1 11.0 11.4 11.8 12.2 12.6 257.5 

Gas carriers 0.3 0.3 2.7 2.7 1.5 0.3 0.3 0.3 0.3 0.3 9.2 

Chemical 

carriers 1.2 1.2 10.8 10.8 6.1 1.4 1.4 1.5 1.5 1.5 37.3 

RORO 9.9 10.0 28.0 25.0 14.6 4.2 4.3 4.4 4.5 4.6 109.5 

Combination 

vessels 7.1 7.3 62.3 62.5 35.3 8.1 8.3 8.6 8.8 9.0 217.5 

General 

Cargo 4.7 4.8 19.8 18.6 10.5 2.4 2.5 2.5 2.6 2.6 71.1 

Fishing 10.0 10.2 40.3 38.4 22.7 7.0 7.2 7.5 7.8 8.0 159.2 

Other 

Offshore and 

Coastal 

Vessels 126.4 130.6 395.5 380.1 244.7 109.5 114.8 120.4 126.2 132.4 1,880.4 

Total 191 196 715 688 420 153 160 167 174 181 3,046.4 

Note: Totals may not add due to rounding. 

* We estimated the number of new vessels that will undergo installation after the phase-in period. We applied fleet 

growth rates (Table 2.3) to estimate the number of new vessels in the U.S. fleet per year. Some types of vessels have 

values representing a fraction of a vessel coming into service yearly. The fraction means that the rate of installation 

would be less than one per year. 
4.2 Installation Costs of Ballast Water Management Systems 

The assumptions and calculations described above form the basis for the baseline cost (based 

on the low installation costs presented on Table 4.1) of the FR discharge standard. Table 4.3 

shows the breakdown by year, vessel type, and the overall share for each vessel type. 

Table 4.3 Costs for U.S. Installed BWDS-2 ($Mil) 

Vessel Type 

Year 

Total 

1 2 3 4 5 6 7 8* 9* 10* 

Bulk Carriers 

Handy Bulk 0.03 0.03 1.58 1.58 0.80 0.03 0.03 0.03 0.03 0.03 4.17 

Panamax Bulk 0.02 0.02 0.94 0.94 0.48 0.02 0.02 0.02 0.02 0.02 2.49 

Capesize 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Tank Ships 

Handy 0.17 0.17 1.96 1.96 1.08 0.19 0.20 0.20 0.21 0.21 6.34 

HandymaxAframax 0.36 0.37 4.16 4.17 2.29 0.41 0.42 0.43 0.44 0.45 13.48 

Suezmax 0.16 0.16 1.84 1.84 1.01 0.18 0.18 0.19 0.19 0.20 5.96 

VLCC 0.11 0.11 1.26 1.27 0.69 0.12 0.13 0.13 0.13 0.14 4.09 

Containerships 

Feeder 0.87 0.87 2.83 2.56 1.45 0.34 0.35 0.36 0.36 0.37 10.35 

Feedermax 0.01 0.01 0.15 0.15 0.08 0.02 0.02 0.02 0.02 0.02 0.48 

Handy 0.38 0.38 3.78 3.79 2.10 0.42 0.42 0.43 0.44 0.45 12.60 

Subpanamax 1.55 1.56 7.53 7.17 4.02 0.87 0.89 0.91 0.92 0.94 26.36 

Panamax 0.68 0.68 3.02 2.84 1.60 0.35 0.36 0.37 0.37 0.38 10.65 

Postpanamax 0.51 0.52 5.06 5.07 2.82 0.56 0.57 0.58 0.59 0.60 16.87 

Other vessels 

Passenger 

ships 5.35 5.45 19.54 18.37 10.84 3.31 3.42 3.54 3.66 3.78 77.25 

Gas carriers 0.18 0.19 1.73 1.74 0.97 0.20 0.21 0.21 0.21 0.22 5.86 

Chemical 

carriers 0.43 0.44 3.80 3.81 2.15 0.49 0.50 0.51 0.53 0.54 13.18 

RORO 3.19 3.22 9.04 8.08 4.71 1.35 1.39 1.42 1.46 1.50 35.37 

Combination 

vessels 2.30 2.36 20.14 20.20 11.41 2.62 2.69 2.76 2.84 2.91 70.25 

General Cargo 1.53 1.55 6.39 6.00 3.39 0.79 0.81 0.82 0.84 0.85 22.97 

Fishing 3.01 3.07 12.09 11.53 6.81 2.10 2.17 2.25 2.33 2.41 47.75 

Other 

Offshore and 

Coastal 

Vessels 32.60 33.69 102.04 98.06 63.12 28.24 29.61 31.06 32.57 34.16 485.16 

Total 53.43 54.86 208.87 201.11 121.82 42.60 44.37 46.22 48.16 50.17 871.62 

Total PV 3% 51.88 51.71 191.14 178.68 105.08 35.68 36.08 36.49 36.91 37.33 760.98 

Total PV 7% 49.94 47.92 170.50 153.43 86.86 28.39 27.63 26.90 26.19 25.51 643.25 

Note: Totals may not add due to rounding 

* The estimated cost on Table 4.3 was obtained using data from Table 4.2 (project number of vessels undergoing BWTS 

installation), and multiplying it with the Lower range cost of Table 4.1 (installed BW system cost). We divide the results by 

1,000 and present those results in Table 4.3.

61 
4.3 Operating Costs of Ballast Water Management System 

BWMS operational costs are in addition to the capital costs for installation. In order to obtain 

a cost of operation for U.S, we first calculated the amount of ballast discharge per vessel type 

(Table 4.4). 

Table 4.4 Estimated Ballast Water Discharge for U.S. Vessels in 2007 

Vessel Type # of 

Arrival 

Total Ballast 

Water Discharged 

Average Ballast Water 

Discharged per Arrival 

Bulk carriers

Handy 1,135 10,572,584 9,315

Panamax 214 8,362,151 39,075

Capesize 578 12,719,493 22,006

Tank ships

Handy - - - 

Handymax-Aframax 34 2,931,103 86,209 

Suezmax 2 655,633 327,817 

VLCC 1 70,706 70,706 

Container ships

Feedera - - - 

Feedermax 52 18,868 363 

Handy 280 1,246,886 4,453 

Subpanamax 110 1,030,473 9,368 

Panamax 290 547,131 1,887 

Postpanamax 410 4,254,689 10,377 

Other vessels

Passenger ships 1 13 13 

Gas carriers - - - 

Chemical carriers 160 224,040 1,400 

RORO 357 21,508 60 

Combination vessels 29,718 15,673,816 527 

General Cargo 12,046 204,819 17 

Fishing Vessel 120 2,237 19 

Other Offshore and Coastal 

Vessels 114 1,415 12 

Note: Totals may not add due to rounding 

a. Information for Feeder vessel is assumed to the same as for Feedermax. 

The average amount of ballast water discharged per vessel type is calculated by using data 

collected by NBIC for year 2007. The amounts of discharge from vessels, represented in the 

above table, are of those vessels that reported actual discharge of ballast in year 2007. This 

data was then cross-referenced to population data gathered from USCG MISLE database in 

order to match vessel activity with their corresponding category by vessel type. 

Once the ballast water discharge by vessel type was determined, we multiplied these 

estimates by the number of vessels undergoing installation in Table 4.2 Then multiply this 

62 
product by the cost presented in Table 3.6 using the lowest cost per cubic meter of water for 

each particular vessel type. The calculated value is then used to formulate a cumulative 

annual operating cost for BWM (Table 4.5) per vessel type. 

Table 4.5 displays the operating costs for all affected vessels in the population. The total 

operating costs covering the period of analysis is $7.2 million and $5.6 million at 3 and 7 

percent discount rates, respectively. 

Table 4.5 Annual Operating Costs for BWM U.S. ($Mil) 

Vessel Type Year Total 

1 2 3 4 5 6 7 8 9 10 

Bulk Carriers 

Handy Bulk 0.000 0.000 0.007 0.014 0.017 0.017 0.017 0.017 0.017 0.018 0.125 

Panamax 

Bulk 0.000 0.001 0.013 0.026 0.033 0.033 0.033 0.033 0.034 0.034 0.240 

Capesize 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 

Tank Ships 

Handy 0.001 0.001 0.007 0.013 0.016 0.017 0.017 0.018 0.019 0.019 0.128 

HandymaxAframax 0.007 0.015 0.099 0.184 0.231 0.239 0.248 0.256 0.265 0.274 1.820 

Suezmax 0.012 0.025 0.167 0.309 0.388 0.402 0.416 0.430 0.445 0.461 3.055 

VLCC 0.005 0.002 0.018 0.018 0.010 0.002 0.002 0.002 0.002 0.002 0.063 

Containerships 

Feeder 0.000 0.000 0.001 0.001 0.001 0.000 0.000 0.000 0.000 0.000 0.005 

Feedermax 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.001 

Handy 0.002 0.004 0.023 0.041 0.052 0.054 0.056 0.058 0.060 0.063 0.412 

Subpanamax 0.014 0.028 0.094 0.158 0.194 0.201 0.209 0.217 0.226 0.234 1.575 

Panamax 0.001 0.002 0.008 0.013 0.016 0.016 0.017 0.018 0.018 0.019 0.129 

Postpanamax 0.003 0.006 0.039 0.071 0.089 0.092 0.096 0.100 0.104 0.107 0.708 

Other vessels 

Passenger 

ships 0.000 0.000 0.000 0.001 0.001 0.001 0.001 0.001 0.001 0.001 0.008 

Gas carriers 0.000 0.001 0.006 0.010 0.013 0.014 0.014 0.015 0.015 0.016 0.105 

Chemical 

carriers 0.000 0.001 0.005 0.010 0.012 0.013 0.013 0.014 0.015 0.015 0.098 

RORO 0.000 0.000 0.001 0.002 0.002 0.002 0.002 0.002 0.002 0.002 0.016 

Combination 

vessels 0.001 0.003 0.015 0.026 0.033 0.035 0.036 0.038 0.040 0.041 0.268 

General 

Cargo 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.003 

Fishing 0.000 0.000 0.000 0.001 0.001 0.001 0.001 0.001 0.001 0.001 0.008

Other 

Offshore and 

Coastal 

Vessels 0.001 0.001 0.003 0.005 0.006 0.007 0.007 0.008 0.008 0.009 0.054

Total 0.050 0.090 0.508 0.904 1.114 1.146 1.187 1.230 1.273 1.318 8.820 

Total PV 

3% 0.048 0.085 0.465 0.803 0.961 0.960 0.965 0.971 0.976 0.980 7.215 

Total PV 7% 0.046 0.079 0.414 0.690 0.794 0.763 0.739 0.716 0.693 0.670 5.605 

Note: Totals may not add due to rounding. 

63 
4.4 Total Costs of Ballast Water Management Systems 

For the purposes of estimating the total cost of BWMS, we multiply the operating costs by 

the estimated volume of treated ballast water each year. We calculated the annual volume of 

ballast water treated by using the average annual volume of ballast water discharged by the 

different types of vessels. Once a vessel begins exchange of ballast water through ballast 

management technology, their operational cost continues to be carried-over into the 

following periods. Therefore, total cost will increase substantially due to the commutative 

nature of operating BWM. This section illustrates the total costs (installation and operational) 

for U.S. vessels over the period of analysis. Appendix D (table D-8) presents the total cost 

for U.S. and foreign vessels. 

We estimate the first-year total (initial) cost of this rulemaking to be $49.98 million based on 

a 7 percent discount rate and $51.92 million based on a 3 percent discount rate (Table 4.6). 

Over the 10-year period of analysis, the total cost of Alternative 2 for the U.S. vessels is 

approximately $649 million using the 7 percent discount rate and $768 million using the 3 

percent discount rate. Our cost assessment includes existing and new vessels. The annualized 

cost over the 10-year period is $92 million at 7 percent and $90 million at 3 percent28. Our 

cost assessment includes existing and new vessels. In Appendix D (table D-7) we show the 

foreign cost to illustrate the potential impact to vessel owners and operators that will be 

operating in U.S. waters. 

In addition, owners and operators performing BWE will no longer be required to perform 

BWE. See Appendix B for more detail on BWE costs. We have not considered the potential 

cost savings due to the termination of the BWE operations in the BWDS total costs 

estimation. 

In Appendix C, we also present a discussion on the cost of BWMS in terms of vessel value 

and daily charter rates. We presented this discussion in the NPRM RA (Section 4.5). We 

found information to suggest that capital costs, such as the installation of BWMS, will have 

little or no effect on charter rates. We also found additional information suggesting the same 

finding in terms of the magnitude of global trade and the effects of costs being passed to 

consumers.29 

 

28 At the high end of costs, assuming vessel owners will install the highest cost system (Table 4.1), the annual 

costs over the 10-year period are $178 million at 7 percent and $173 million at 3 percent. 

29 King, Dennis. 2011. MEPC 62 special: The world can afford sustainable shipping. Sustainable Shipping, 

July 8 2011 (http://www.maritime-enviro.org/news/King_Sustainable_Shipping_070811.pdf). King suggests 

that if the cost of ballast water regulations was passed along to global businesses and consumers, the price 

increase of imported goods will be minimal and statistically indistinguishable from no change. 

64 
Table 4.6 Total Cost of the Rulemaking to US Vessels ($ Mil)

Year 

Installation Costs 

Treated Ballast 

Water (m3) 

Annual Operating Costs Total Cost 

3% 

Discount 

7% 

Discount 

3% 

Discount 

7% 

Discount 

3% 

Discount 

7% 

Discount 

1 $51.88 $49.94 280,029 $0.05 $0.05 $51.92 $49.98

2 $51.71 $47.92 478,831 $0.09 $0.08 $51.80 $48.00

3 $191.14 $170.50 2,993,916 $0.46 $0.41 $191.61 $170.91

4 $178.68 $153.43 5,348,917 $0.80 $0.69 $179.49 $154.12

5 $105.08 $86.86 6,565,633 $0.96 $0.79 $106.04 $87.65

6 $35.68 $28.39 6,720,480 $0.96 $0.76 $36.64 $29.15

7 $36.08 $27.63 6,957,572 $0.97 $0.74 $37.05 $28.37

8 $36.49 $26.90 7,200,434 $0.97 $0.72 $37.46 $27.62

9 $36.91 $26.19 7,449,212 $0.98 $0.69 $37.88 $26.89

10 $37.33 $25.51 7,704,056 $0.98 $0.67 $38.31 $26.17

Total $760.98 $643.25 $7.21 $5.61 $768.20 $648.86

Annualized $89.21 $91.58 $0.85 $0.80 $90.06 $92.38 

Note: Totals may not add due to rounding.

As a result of public comments, we have included a provision in the FR to allow vessel 

owners and operators to request an extension of their compliance date if they cannot 

practicably comply with the compliance date otherwise applicable to their vessel. This is a 

voluntary provision and will result reporting and recordkeeping burden to the vessel owner 

and operator applying for the extensions. This extension provision will give flexibility to 

vessel owners and operators to comply with this rule. We estimated the average cost per 

vessel to be $484 (see Appendix I for more information on). The total cost of the rule is not 

impacted by this paperwork provision. 

 

4.5 Discussion on More Stringent Standards 

While the IMO BWDS is practicable to achieve in the near term and will considerably 

advance environmental protection over the current exchange-based regime, we also 

recognize that it is not the ultimate endpoint for protection of U.S. waters. The purpose of 

NISA, as already noted, is to ensure, to the maximum extent practicable, that NIS are not 

introduced and spread into U.S. waters. In the NPRM published on August 28, 2009, we 

proposed a phase two standard that is potentially 1,000 times more stringent than the 

standard analyzed in this FR RA. Due to the lack of information on the phase two standard 

and issues raised by the public comments, the Coast Guard has decided to move forward with 

phase one standard while we assess the following issues: 

• practicability of implementing a phase-two standard, 

• obtain additional data on technology available to meet the phase-two standard for 

various vessel types, and 

65 
• develop a subsequent rule with the economic and environmental analysis necessary to 

support the phase-two standard, since the Coast Guard fully intends to issue a rule 

that will establish a more stringent phase-two discharge standard. 

In the NPRM, we have solicited information from the public on the phase two standard with 

respect to the following issues: 

 1. Acquisition, installation, operation/maintenance and replacement costs of technological 

systems that are able to meet more stringent standards, 

 2. Technology scalability to meet multiple stringency standards, 

 3. Additional costs for vessels compliant with the phase-one standard to go to the phasetwo standard, 

 4. Technology alternatives and costs for smaller coastwise vessel types, 

 5. Additional avoided environmental and social damages and economic benefits of ballast 

water discharge standards at more stringent standards, and 

 6. Potential for the rule to ensure to the maximum extent practicable that aquatic nuisance 

species are not discharged into waters of the United States from vessels, as required by 

NISA. 

We have not received any information from the public that would contribute to the 

development of the economic analysis for the phase two standard. Some commenters pointed 

out that this technology is still not available and therefore, they could not provide data on 

potential technology costs. We have received some data on costs for phase one only 

(Appendix E). Other commenters noted that the lack of the ability to test for compliance 

with stricter standards poses difficulties in determining whether an existing technology has 

the capacity to meet a higher standard. 

In addition to requesting information from the public, the Coast Guard has been conducting 

further research on BWMSs. Since the NPRM publication, the Coast Guard has conducted 

additional research on available BWMs technologies. The research has focused on systems’ 

cost and capacity of achieving more strict standards. Selected vendors of different BWMs 

technologies were interviewed in order to obtain information on the current systems status, 

costs and scalability potential for meeting standards that are more stringent. 

We have researched and contacted vendors of the following types of BWMS technologies: 

(1) Filtration + Chlorine, 

(2) Filtration+ Radiation (UV), and 

(3) Cavitation + Sterilization + Filtration. 

Only the vendor of one system (Filtration + Chlorine) said that they could currently meet 

standards that are more stringent then the IMO, such as the California standard30. The other 

 

30 California Interim Performance Standards for Ballast Water Discharges (Section 2293). 

Subject to the Implementation Schedule in Section 2294, before discharging ballast water in waters subject to 

the jurisdiction of California, the master, owner, operator, or person in charge of a vessel to which this section 

applies shall conduct ballast water treatment so that ballast water discharged will contain: 

66 
vendors were not certain if their systems could meet the more stringent standards because the 

current testing protocols are based on the IMO standard. Speculations on potential changes to 

a system to meet a higher standard included: installing UV bulbs in series (instead of 

parallel), increasing biocide concentration, and using finer filter meshes. 

In relation to the increase in acquisition, installation and operation costs for systems to meet 

a higher standard, vendors did not provide any information. According to one vendor, system 

development is still in the conceptual stage, thus predicting costs is not feasible without 

more certain information on the characteristics of the technology, the costs of R&D to 

develop the technology (which would need to be factored into the ultimate cost of the 

system) and the manufacturing costs. 

We have also been following Lloyd’s Register publications on ballast water technologies. 

According to the Lloyd’s Register (2007 and 2008) estimates that the costs for BWMSs will 

range between $135K to $2.3 million for capacities of 200 m3 /hr to 2,000 m3/hr respectively 

for systems meeting IMO standards. The Coast Guard cost estimates for BWMS are within 

the range described in the Lloyd’s report. The current Lloyd’s Register (February 2010) has 

the mean cost of BWMS ranging from $281K to $863K for capacities of 200 m3

 /hr to 2,000 

m3/hr respectively for systems meeting IMO standards, which is still within range of Coast 

Guard’s estimates. The 2010 Lloyd’s Register report shows technologies that have undergone 

preliminary pilot trails. According to the report, data from these trials has shown the systems 

to be generally effective with reference to the IMO standard. At present, there is no available 

information on any manufactures that are developing and designing a system that will meet 

standards more stringent than the IMO standard. These finding are in concurrence with other 

organizations and the Coast Guard’s conclusions about management systems that go beyond 

the IMO standard. 

In our research, we have also found that some vessels owners have requested the States (such 

as New York) postpone the implementation of phase two standard (1,000 times the IMO 

standard) due to the lack of technology available. According to the industry memo sent to the 

New York State Department of Environmental Conservation (DEC), there is currently no 

ballast water treatment technology, and there is no realistic expectation that such technology 

will be available in the near future31. 

 (a) No detectable living organisms that are greater than 50 micrometers in minimum dimension; 

(b) Less than 0.01 living organisms per milliliter that are less than 50 micrometers in minimum 

dimension and more than 10 micrometers in minimum dimension; 

(c) For living organisms that are less than 10 micrometers in minimum dimension: 

(1) less than 1,000 bacteria per 100 milliliter; 

(2) less than 10,000 viruses per 100 milliliter; 

(3) concentrations of microbes that are less than: 

(A) 126 colony forming units per 100 milliliters of Escherichia coli; 

(B) 33 colony forming units per 100 milliliters of Intestinal enterococci; and 

(C) 1 colony forming unit per 100 milliliters or 1 colony forming unit per gram of wet weight of zoological 

samples of Toxicogenic Vibrio cholerae (serotypes O1 and O139) 

31 http://www.infomarine.gr/attachments/article/857/New%20York%20Extension%20Request.doc or 

http://www.gard.no/webdocs/GardAlert25062010.doc 

67 
For these reasons, at this time we cannot estimate the costs of meeting stricter ballast water 

discharge standards based on the level of uncertainty of system configuration, performance 

and cost. 

After the publication of the NPRM, the EPA requested its Science Advisory Board (SAB) 

provide review and advice regarding whether existing shipboard treatment technologies can 

reach specified concentrations of organisms in vessel ballast water, how these technologies 

might be improved in the future, and how to overcome limitations in existing data (EPA SAB 

2011)32. The Panel used industry information as the source material for its assessment of 

ballast water treatment performance and, as requested by the EPA, used proposed ballast 

water discharge standards as the performance benchmarks. 

Based on its evaluation of the available data, the SAB concluded that the performance 

standards for discharge quality proposed by IMO and the USCG are currently measurable, 

based on data from land-based and shipboard testing. However, current methods (and 

associated detection limits) prevent testing of BWMS to any standard more stringent than 

BWDS-2 Phase I (i.e., IMO D-2) and make it impracticable for verifying a standard 100 or 

1000 times more stringent. New or improved methods will be required to increase detection 

limits sufficiently to statistically evaluate a standard 10x more stringent than BWDS-2 Phase 

I; such methods may be available in the near future. The SAB concluded that establishment 

of a ballast water discharge limit at the proposed BWDS-2 Phase I discharge standard will 

result in a substantial reduction in the concentration of living organisms in the vast majority 

of ballast water discharges, compared to discharges of ballast water managed by mid-ocean 

exchange or discharges of unexchanged ballast water. The numeric limitations in today’s 

rule represent the most stringent standards that ballast water management systems currently 

safely, effectively, credibly, and reliably meet (US EPA SAB, 2011). 

 

32 US EPA Science Advisory Board (SBA). 2011. Efficacy of Ballast Water Treatment Systems: a Report by 

the EPA Science Advisory Board. Washington, D.C. 

68 
5 Benefits from Reducing Invasions of Non-indigenous Species 

Bioinvasions of aquatic ecosystems can result in adverse economic impacts on industries that 

are dependent on those ecosystems. The purpose of this section is to discuss the economic 

costs associated with bioinvasions of aquatic ecosystems, and specifically to discuss the 

overall economic harm33 attributable to bioinvasions resulting from the introduction of NIS 

through ballast water. Subsequent sections discuss the costs (economic harm) associated 

with the primary economic activities impacted by aquatic bioinvasions: (1) water-dependent 

infrastructure, (2) subsistence, (3) tourism and recreation, (4) water-related subsistence 

activities, (5) commercial fishing, and (6) recreational (sport) fishing. Quantification of 

some of the economic impacts, as well as a reliable assessment of public health risks (and 

costs) related to bioinvasions of aquatic ecosystems remain problematic. 

In the second part of this chapter, we attempt to quantify and monetize avoided costs 

associated with future NIS invasions that represent the benefits of BWM. These avoided 

costs provide the same benefits whether the reduction in invasions is achieved through BWM 

via exchange (USCG 2004) or the use of a BWDS. Economic costs from invasions of NIS 

are in the billions of dollars annually. 

We use the same benefits model for the FR as we did for the NPRM. This model quantifies 

benefits resulting from the reduction in “initial invasions” from vessels engaged in oceangoing traffic. We have not found complete data or identified appropriate models to quantify 

the possible benefits associated with reducing the secondary spread of invasions. Therefore, 

we do not expect the exemption of inland vessels to reduce the estimate of quantified benefits 

given data and modeling limitations. 

5.1 Resources at Risk 

Loss of biodiversity 

Invasions of U.S. waters by NIS are occurring at increasingly rapid rates (Carlton et al. 1995, 

Ruiz et al. 2000a). The U.S. Commission on Ocean Policy notes that invasive species are 

considered one of the greatest threats to coastal environments and can contribute 

substantially to altering the abundance, diversity, and distribution of many native species 

(USCOP 2004). While introduction of a NIS does not necessarily lead to invasion, the 

sudden availability of a new habitat and absence of natural predators can lead to runaway 

growth that pushes out other species. Unlike oil and other forms of pollution, where the 

deleterious effects can degrade over time, invasive species can persist, reproduce, and spread. 

The discharge of ballast water is considered a primary pathway for the introduction of NIS 

(USCOP 2004). The social and economic implications of accelerating the loss of biodiversity 

bear directly on several ecological interrelationships, including the following (NRC, 1995): 

 

33 This section focuses on quantifying and monetizing the economic harm caused by aquatic NIS. The 

Programmatic Environmental Impact Statement provides a discussion of the environmental harm caused by 

NIS. 

69 
• the ocean’s capacity to sustain economically significant fisheries, 

• the quality of bays and estuaries as nurseries for important stocks, 

• the loss of species with significant potential for biomedical products, 

• the recreational value of ocean margins, and 

• the aesthetic value of marine environments that remain close to their 

aboriginal state. 

Water-dependent infrastructure 

Water-dependent infrastructure includes water intake pipes, storm sewer drains, docks, piers, 

canals, dams, navigation locks, and facilities such as electric power plants, drinking water 

treatment plants, water storage facilities, and water distribution systems (USCG 2006). 

Water-dependent infrastructure must deal with the impacts of unexpected interruptions 

caused by disruption or contamination (USEPA 2001). 

Invasive invertebrates, such as the zebra mussel and the Asian clam, have adversely affected 

water-dependent infrastructure by fouling intake pipes and screens, causing equipment 

malfunction and overheating, and jamming valves and other mechanisms. Affected systems 

include electric power generation stations, drinking water treatment plants, industrial 

facilities, and navigation lock and dam structures. Additionally, invasive aquatic plants have 

caused problems on rivers and canals. Costs associated with the zebra mussel approach $1 

billion annually and were about the same in the 1980s for the Asian clam (Pimentel et al. 

2005). 

Subsistence living primarily involving Native American, Alaskan, and Hawaiian tribes 

Subsistence living in the U.S. involves Native American, Alaskan, and Hawaiian tribes, as 

well as the inhabitants of the U.S. territories that include Puerto Rico, the U.S. Virgin 

Islands, American Samoa, Guam, and the Commonwealth of Northern Mariana Islands. The 

Indigenous Environmental Network (see http://www.ienearth.org/) notes that indigenous 

peoples depend on the fish, aquatic plants, and wildlife to a greater extent and in different 

ways than the general population. Many indigenous peoples are reliant on a subsistencebased lifestyle. Consumption and use of aquatic resources not only meets basic nutritional 

and economic needs, but also provides resources for cultural, traditional, and religious 

purposes (Maybee 2001). Fish stocks and water quality are linked to the health of an 

ecosystem and to the activities that occur in the watershed. NIS can impact both fish species 

and water quality, causing disruptions to local food webs. These disruptions can impact 

subsistence fishing and, in turn, the livelihoods of people who rely on it. 

Impacts to Commercial Fishing, Recreational Fishing, and Water-Dependent Tourism 

Invasions of NIS are capable of disrupting commercial and recreational fisheries and 

adversely affecting local and regional economies. NIS can degrade water-dependent tourism 

and recreational activities associated with fishing, boating, swimming, and scuba diving. 

70 
The domestic commercial fish and shellfish industry, which obtains its catch from many 

fresh and saltwater sources, including the Columbia River, the Great Lakes, the Atlantic and 

Pacific Oceans, and the Gulf of Mexico, contributes $45 billion to the U.S. economy 

annually (ERS 2004). This contribution reflects not only direct economic effects—the value 

of the fish and shellfish harvested—but also indirect effects, which include processing fish 

and shellfish for market, servicing the commercial fishing fleet, and repairing and 

maintaining commercial fishing gear. 

An example of costs to the local economy associated with NIS concerns Ohio’s $600 million 

Lake Erie sport fishery, which lost 50 to 65 percent of its value between 1985 and 1995. 

Possible reasons include an above-capacity walleye population in early 1982, a rapidly 

growing white perch population from 1985 to 1993, and the zebra mussel (Hushak 1997). 

Impacts to Public Health 

While the introduction of bacteria and viruses through ballast water is a growing concern, 

potential public health impacts remain virtually unexplored by scientists (Ruiz et al. 2000b). 

Concentrations of bacteria and viruses in ballast water have been found at very high levels—

up to six to eight times higher than those for other taxonomic groups in ballast water—

suggesting that invasions may be relatively common (Carlton and Geller 1993; Drake et al. 

2001; Drake et al. 2002; Ruiz et al. 2000b). For example, human pathogen microorganisms 

are common in coastal waters and have been found in the ballast water of vessels (Ruiz et al. 

2000b). 

During the 1997 and 1998 shipping seasons, samples were taken from the ballast tanks of 28 

transoceanic vessels (Knight et al. 1999; Reynolds et al. 1999; Zo et al. 1999). The sampling 

revealed the presence of a host of microorganisms, many of which are human pathogens, 

including fecal coliform, fecal streptococci, clostridium, salmonella, E. coli, Vibrio cholerae, 

cryptosporidium, giardia, and enteroviruses. The presence of these organisms demonstrated 

the survival of human pathogens during transoceanic transport of ballast water. It has been 

shown that certain microbial organisms can survive and become successfully established 

following BWD, thereby becoming vectors for human exposure. 

The global increase in HAB via BWD poses an increased risk to human health. Some algal 

species contain powerful toxins, which can adversely affect fish, birds, and humans through 

the consumption of contaminated fish and shellfish. Paralytic shellfish poisoning, diarrheic 

shellfish poisoning, amnesic shellfish poisoning, neurotoxic shellfish poisoning, and 

ciguatera fish poisoning are associated with natural toxins produced by HAB-forming 

diatoms and dinoflagellates. 

71 
5.2 Economic Impacts of Past NIS 

Reporting on the costs in NIS invasions is almost an industry in itself. Despite the difficulty 

of obtaining economic estimates of the costs of aquatic introductions (Randall and Gollamudi 

2001), such figures are widely published. The importance of these estimates is that they 

establish the scale of the costs in comparison with the costs of meeting a BWDS. Ultimately, 

the quantified and monetized benefits of more stringent standards lie in the reduction of the 

costs of invasions such as those described herein. 

The U.S. EPA (Lovell and Stone 2005) has published a literature review on NIS and has 

noted the weaknesses of the currently available estimates: “Current empirical estimates are 

not comprehensive enough to determine the national or regional economic impacts of aquatic 

invasives. Additionally, the realm of impact categories differs across the scale of analysis 

and methods of estimation. By and large, there are few estimates of the non-market impacts 

using known methods.” (Lovell et al 2006). 

In the absence of a national comprehensive estimate of the economic impacts due to invasive 

aquatic species, we review the literature on the existing estimates and develop a range of 

costs/impacts on a per species basis to characterize potential economic impacts of preventing 

future NIS invasions. The following discussion summarizes some of the available estimates 

of costs and damages related to past invasions, with more detailed information presented in 

Appendix H. 

A landmark assessment of the losses from selected NIS (Table 5.1) was made in 1993 by the 

U.S. Congress Office of Technology Assessment (OTA 1993). 

Table 5.1 Estimated Cumulative Losses to the United States from Selected, Harmful, Nonindigenous 

Species, 1906-1991 (OTA 1993) 

Category Species analyzed 

(number) 

Cumulative loss 

estimates 

(millions of dollars, 

1991) 

Species not analyzeda

(number) 

Plants 15 603 - 

Terrestrial vertebrates 6 225 >39 

Insects 43 92,658 >330 

Fish 3 467 >30 

Aquatic invertebrates 3 1,207 >35 

Plant pathogens 5 867 >44 

Other 4 917 - 

Total 79 96,944 >478 

Source: U.S. Congress Office of Technology Assessment (OTA 1993), “Harmful Non-Indigenous Species in 

the United States.” 

In the above table, the cumulative losses due to selected fish and aquatic invertebrates total 

nearly $1.7 billion. Other costs are not easily assigned to marine sources; however, the 

marine contribution is significant. In particular, the costs associated with non-native aquatic 

plants are notable. O’Neill (2000) has estimated the damages costs of the Zebra Mussel 

72 
(Dreissena spp.) introduction in the U.S and obtained amounts between $750 million and $1 

billion for the period 1989–2000. 

In the most extensive review to date on the economic costs of introduced species in the U.S., 

Pimentel et al. (2005) covers estimates for many types of NIS. As part of an overall estimate 

that includes both direct and indirect cost of $120 billion annually, they include $7.8 billion 

associated with damages and costs of controlling aquatic invaders. Aquatic contributions are 

broken down as follows. 

Table 5.2 Estimated Annual Costs of Aquatic Introduced Species 

(based on Pimentel et al. 2005) ($ 2007) 

Species Costs34

Fish $5.7 billion 

Zebra and quagga mussels $1.06 billion 

Asiatic clam $1.06 billion 

Aquatic weeds $117 million 

Green Crab $47 million 

The potential negative economic impact caused by aquatic invasive fish species has not been 

studied to the extent such that direct and indirect costs resulting from invasions can be 

quantified, nor is there very much data to support prevailing assumptions about the costs of 

invasions. In one study, an estimate of $5.7 billion is given for annual fish related costs 

(Pimentel 2005). This study defines cost in terms of losses to commercial and sports fishing 

in the Great Lakes and other U.S. inland waters. Two invasive species in particular are nearly 

always cited on this subject – the Ruffe (Gymnocephalus cernuus) and the Sea lamprey 

(Petromyzon marinus). The Ruffe came from Europe via ballast water in the 1980’s and the 

Sea lamprey migrated naturally. Both species prey on other fish and compete for habitat. In 

two studies on these species, losses were quantified in terms of future angler days lost due to 

decreases in fishing population (Leigh 1998 and Lupi et al 2003). While these two studies 

(which do not quantify costs in terms of actual expenditures) by themselves cannot be used to 

support the above figure of $5.7 billion, they underline one of the primary economic 

concerns to environmentalists regarding aquatic invasions, which is that they have the 

potential to cause significant harm to native fish populations and aquatic ecosystems. 

The economic costs associated with mollusk infestation to U.S. waters has been estimated as 

high as $1 billion per year in direct cost for Zebra Mussels (Dreissena polymorpha) (O’Neill 

1997), and $1 billion per year for Asian Clams (Corbicula fluminea) (Pimentel et al. 2005). 

The origin of Zebra Mussel is the Caspian Sea. Scientists believe that the introduction of 

Zebra Mussels occurred through ballast water discharged into the Great Lakes during the 

early part of the 1980’s. Their high rate of reproduction has enabled Zebra Mussels’ colonies 

to spread quickly throughout U.S. waters, including recent spread into the waters of western 

States. 

 

34 All economic costs/damages in benefits analysis have been updated to 2007 dollars (using the Consumer 

Price Index). 

73 
The Asiatic Clam like the Zebra Mussel is believed to have entered U.S. coastal waters 

through ballast water discharge. The first reported infestation of Asiatic Clams was 

discovered in San Francisco Bay during the early 1980’s. Like the Zebra Mussels, the Asiatic 

Clam colonization around the openings of drainage pipes and siphoning pipes have caused 

damages to industrial facilities. 

Aquatic weeds, in particular the Hydrilla weed (Hydrilla verticillata) which is “native to 

warmer areas of Asia, was first discovered in the U.S. in 1960....in Florida” (Langeland K.A. 

1996). Most damages caused by this weed are the blocking of irrigation, drainage canals, and 

the entanglement of propeller blades. 

Shipworms (Teredo navalis) are not worms, but elongated clams that feed on and live inside 

wooden structures. The destruction of wooden structures by Shipworm begins during the 

larval stage (Chesapeake Bay Program 2008) which makes detection of the infestation 

impossible until the damage is already done. Damage is usually done to wooden boats and 

piers that are untreated. 

The first European Green Crab (Carcinus maenas) was reported in North America in 1817 

along the Atlantic Coast. (Prince William Sound Regional Citizen’s Advisory Council 2004). 

The crab was then introduced to the west coast during the 1980’s through ballast water. 

Damage from the Green Crabs is seen in the disappearance of native species, due in part to 

the aggressive nature of these crabs. 

5.3 Benefits of Ballast Water Discharge Standards 

This section describes the benefits likely to occur from the establishment of a BWDS. The 

standard’s main goal is the prevention of future NIS invasions. Prevention of future NIS 

invasions will also prevent the negative impacts of such invasions, including loss of 

biodiversity, damage to water-dependent infrastructure, and impacts on commercial fishing, 

recreational fishing, water-dependent tourism, public health, and subsistence populations. 

We use estimates of costs associated with past NIS invasions to estimate benefits of 

preventing future invasions. The estimates of costs resulting from past invasions are derived 

from a selection of studies that vary in which types of costs are covered by the study and 

often vary on the time period and the geographic region covered by the study. Most often 

these studies include costs to control invasive species, with damages to infrastructure and 

impacts on fishing and tourism occasionally included. We are unable to quantify potential 

benefits associated with ecological damages such as loss of biodiversity, impacts to public 

health and impacts on subsistence populations. 

Further, the majority of the studies analyzed are not specific on the entities directly affected 

by the NIS damages, making the identification of the portion of benefits that are transfer 

payments difficult. 

We start the discussion of potential benefits of a BWDS by presenting information on the 

functional benefits of the standard. We then project the number of expected future invasions 

and the portion of invasions prevented by the standard. We present an analysis of the range 

74 
of potential cost per species and the estimated total damages of future species, as well as the 

potential benefits of the standard and potential transfers. 

5.4 Functional Benefits of the Ballast Water Standards 

Although it is difficult to determine monetary measures of the benefits of controlling NIS, we 

can assess the functional benefits. The primary functional benefits of the IMO standard 

(Alternative 2) are: 

• A reduction in the concentration of organisms greater than 50 microns in size, leading 

to lower numbers of these organisms being introduced per discharge. 

• A reduction in the concentration of organisms in the 10–50 micron size range for 

ballast water that was initially rich in organisms. 

• A general reduction in concentrations from BWM values due to the practical 

requirements of meeting an upper bound standard. 

• A consistent upper bound on number of organisms (of all sizes) introduced for a 

given discharge size. 

• The potential to reduce the survivability of organisms that have been present in 

sediments in NOBOB vessels that subsequently take on ballast. This applies to 

systems that maintain a toxic environment in the ballast tank during the voyage. 

• Elimination of the exemptions in the BWM regulations leading to discharge of 

unmanaged ballast water (e.g., safety concerns during exchange, delay of voyage 

required to travel to acceptable mid-ocean exchange location). The elimination of 

these exemptions is significant, because they often lead to discharge of large amounts 

of untreated ballast water. Large inoculations (i.e., large number of organisms in a 

discharge) are linked positively to the risk of invasions (Minton et al. 2005, Ruiz et al. 

2000a, and others). In 2005, 7.7 million cubic meters of ballast was discharged from 

vessels from outside the EEZ that did not travel further than 200 miles from shore and 

thus were unable to perform mid-ocean exchange. This represents about 19 percent of 

the ballast discharged from vessels whose ballast originated outside the EEZ. 

This overall strategy should reduce the number of new invasions because the likelihood of 

establishment increases with the number of organisms introduced per discharge or 

inoculation (Ruiz et al. 2000a, Minton et al. 2005). 

More stringent discharge standards further strengthen these benefits. Inoculation sizes will 

decrease in proportion to the reduction in concentrations. This reduces the chance of 

invasion, but the effects are extremely uncertain. There is evidence that probability of 

invasion reduces asymptotically with reduction in concentration (Tamburri 2005). 

Zero discharge standards, if achievable, would effectively eliminate the introduction of 

invasive species into ballast water. 

75 
5.5 Annual Number of Invasions Due to Ballast Water Discharge 

Rate of Future Invertebrate Invasions 

To assist in assessing the benefit of BWDS, we first estimate the number of invasions 

introduced by BWD from shipping. The approach is based on the invasion rate of 

invertebrates from shipping reported by Ruiz et al. (2000) to estimate an approximated 

number of initial invasions per year. The authors compiled data on past marine invasions of 

invertebrates and algae in North America from 1790 to 2000. The authors found 298 

invertebrate and algae NIS in the coastal waters of North America, with an additional 76 

instances in which a species has spread to more than one coast (designated as repeat 

invaders). We focus our primary analysis on the number of initial invasions, with a 

discussion of the impact of reducing “repeat invaders” in a later section of this document. 

The authors note that these estimates likely understate the number of actual invertebrate and 

algae invasions: “Our data provide only minimum estimates for established invasions of 

marine invertebrates and algae. We have excluded consideration of boundary residents and 

cryptogenic35 species from our estimates, and the latter group may include hundreds of NIS 

that have gone unrecognized as such. Furthermore, many sites and taxa within North 

America have received little scrutiny” (Ruiz et al. 2000).36

Ruiz et al characterized the mechanism for introduction of initial invasions and found that 62 

percent of the invasions over the most recent 30-year period studied (1970 – 2000) were due 

to shipping. An additional 15 percent of invasions had shipping as one of the potential 

mechanisms, often with fishing as the other potential mechanism. 

The authors also calculated the rate of initial invasions due solely to shipping based on 

historical invasion data (i.e., the number of invasions by time period back to 1790). The 

authors derive a “best fit mathematical model” to characterize the historical trend in 

invasions. The best fit model is an exponential function which is represented by the 

equation: , where x is time in 30-year intervals since 1790. )024.0( 127.1 x ⋅= ey

37 

We assume that this historical trend in initial invasions will continue in the future. We use 

this equation to project the number of invasions per year due to shipping for our 10-year 

evaluation period (see Table 5.4). Since this equation does not include the 15 percent of 

 

35 Cryptogenic – not clearly native or introduced 

36 According to the NAS 2011 report, studies on invasions in North America waters have involved mining 

occurrence records from the literature and diverse research programs, rather than an organized field-based 

monitoring program designed explicitly to detect invasions. Therefore, today’s knowledge of invasions 

represent an underestimate of the total number of NIS species that have colonized. 

37 The model shape (the exponential function) means that as time progresses, the rate of invasions increases 

greater than a simple linear relationship. In this equation, the values of 1.127 and 0.024 are constants that define 

the shape of the trend line (similar to the slope in a linear equation). The variable of x is a measure of time, 

specifically time in 30-year intervals since 1790. 

76 
invasions in which shipping was one of several potential mechanisms, this approach is likely 

to underestimate the actual number of invasions that are the result of shipping activities. 

Rate of Future Fish and Aquatic Plant Invasions 

The Ruiz et al analysis includes only invasions of invertebrate and algae species: “Although 

our analysis is restricted to invertebrates and algae, it is noteworthy that at least 100 species 

of non-indigenous fish and 200 species of non-indigenous vascular plants are known to be 

established within this coastal area” (Ruiz et al 2000). To account for the additional number 

of fish and plant invasions that are expected to occur, we use the results of the Ruiz et al 

2000 model to estimate the number of fish and plant invasions per year, based on historical 

data on the relationship of invasions for different specie groups. Table 5.3 summarizes the 

results of previous studies that characterized invasions for specific bodies of water. 

Table 5.3 Distribution of NIS by Plants, Invertebrates and Fish for Three Regions (Cohen and Carlton, 

1995) 

Miller et al. 1993 

Great Lakes 

Mills et al. 1995 

Hudson River 

Cohen and Carlton 1995 

San Francisco Estuary 

Plants 60% 63% 23% 

Invertebrates 20% 18% 61% 

Fish 18% 19% 13% 

Source: Cohen and Carlton, 1995, page 283. 

In two of the studies, the percent of invasive fish species was roughly equal to the number of 

invertebrates and the number of plant species was roughly 3 times the number of 

invertebrates. The third study employed more strict criteria for inclusion of plant species and 

found that the number of plant species was 40 percent of the number of invertebrates and fish 

species were roughly 20 percent of the number of invertebrates. We use these two sets of 

relationships to project the annual number of invasive fish and plant species as displayed in 

Table 5.4. For the purposes of estimating economic impacts of invasions, we use the 

number of fish and aquatic plant invasions that result from Relationship 2 (i.e., aquatic plants 

are 40 percent of invertebrates and fish are 20 percent). 

77 
Table 5.4 Forecasted Number of Initial Shipping Invasions Per Year 

Year Invertebrate 

Invasions a

Relationship 1 b Relationship 2 c

Fish Aquatic Plant Fish Aquatic Plant 

1 8.12 8.12 24.36 1.62 3.25 

2 8.32 8.32 24.95 1.66 3.33 

3 8.52 8.52 25.56 1.70 3.41 

4 8.73 8.73 26.18 1.75 3.49 

5 8.94 8.94 26.82 1.79 3.58 

6 9.16 9.16 27.47 1.83 3.66 

7 9.38 9.38 28.13 1.88 3.75 

8 9.61 9.61 28.82 1.92 3.84 

9 9.84 9.84 29.52 1.97 3.94 

10 10.08 10.08 30.23 2.02 4.03 

a. Derived from Ruiz et al. 2000 equation 

b. Derived from Great Lake & Hudson River data; fish equal to invertebrates, aquatic plants equals 

3 times invertebrates 

c. Derived from San Francisco Estuary data; fish equal to 20 percent of invertebrates, aquatic plants 

equal to 40 percent of invertebrates 

Fraction of Shipping Invasions Due to Ballast Water

Ballast water discharge is one of the two main vectors associated with shipping—hull fouling 

being the other. The discharge standard in this rule will not address risks associated with hull 

fouling, so the fraction of invasions associated with hull fouling needs to be removed from 

our estimates of future invasions. Appendix F presents a summary from the FEIS on the 

science and benefits of preventing invasions, including discussion on hull fouling. 

There are competing factors with regard to the influence of hull fouling versus BWD. On the 

one hand, reductions in the impact of hull fouling are expected as fuel costs continue to 

increase in overall importance and more attention is paid to maintaining non-fouled bottoms. 

Further, the trend to larger ships results in more volume for a given hull surface area, thus 

increasing the relative importance of ballast discharge as a vector. 

Reduced toxicity of bottom paint, improved water quality, creation of new harbor facilities, 

vessel activities (e.g., vessels that remain in place for long periods), biological triggers, and 

other factors (Minchin 2002) suggest that hull fouling may become a more significant vector. 

One contributing factor to this scenario is that NIS have a higher survivability rate on hulls 

than in ballast tanks. 

Past analyses of ballast water and hull fouling indicate that the rate of shipping invasions due 

to ballast water could be as high as 63 percent (Mills, et al. 1993) and as low as 10 percent. 

The relative impact of ballast water and hull fouling vectors has not been fully understood 

(Ruiz 2002). 

In a recent analysis of historical invertebrate invasions, Fofonoff, et al. (2003) classified 

nonnative species (invertebrates, algae and fish) associated with shipping to assess the 

78 
likelihood of invasion by the subvectors based on traits such as life history, etc. Table 5.5 

summarized the results of the Fofonoff et al. (2003) analysis: 

Table 5.5 Number of Nonnative Coastal Marine Species by Shipping Vector (Fofonoff, et al. 2003) 

Shipping Vector Number of Species Percent of Species 

Ballast Water 20 20% 

Ballast/Hull Fouling 34 34% 

Hull Fouling 36 36% 

Ballast Water/Dry Ballast 1 1% 

Hull Fouling/Dry Ballast 1 1% 

Hull Fouling/Dry Ballast/Ballast Water 1 1% 

Dry Ballast 1 1% 

Ballast Water/Cargo or Packing material 3 3% 

Dry Ballast/Cargo or Packing material 1 1% 

Cargo or Packing material 1 1% 

Total 99 100% 

Only Ballast Water 20% 

Ballast Water + Ballast/Hull Fouling 54% 

Ballast Water + Proportion of Ballast Water/Hull Fouling 32% 

Source: Fofonoff et al. "In Ships or On Ships? Mechanisms of Transfer and Invasion for Nonnative Species to 

the Coast of North America," Invasive Species: Vectors and Management Strategies, Island Press, Washington 

DC, 2003, page 170. 

Based on this analysis and using species as a proxy for invasions, 20 percent of invasions are 

solely attributed to ballast water, while another 34 percent of invasions could be attributable 

to either ballast water or hull fouling. If we assume none of the “Either Ballast Water or Hull 

Fouling” invasions was due to ballast water, then 20 percent of shipping invasions are due to 

ballast water. Similarly, if we assume that all of the “Either Ballast Water or Hull Fouling” 

are due to ballast water, the resulting fraction of ballast water invasions is 54 percent. If we 

assume that the “Either Ballast Water or Hull Fouling” invasions are distributed 

proportionally, then ballast water accounts for 32 percent of invasions. Table 5.6 presents 

the potential number of invasions per year assuming 32 percent of shipping invasions are 

attributable to ballast water. For the purposes of our main analysis, we assume that 32 

percent of shipping invasions are attributable to ballast water. 

79 
Table 5.6 Estimated Number of Ballast Water Initial Invasions 

Year 

Number of Shipping Invasions Number of Ballast Water Invasions (32% 

of Shipping Invasions) 

Invertebrate Fish Aquatic 

Plant Invertebrate Fish Aquatic Plant 

1 8.12 1.62 3.25 2.60 0.52 1.04 

2 8.32 1.66 3.33 2.66 0.53 1.06 

3 8.52 1.70 3.41 2.73 0.55 1.09 

4 8.73 1.75 3.49 2.79 0.56 1.12 

5 8.94 1.79 3.58 2.86 0.57 1.14 

6 9.16 1.83 3.66 2.93 0.59 1.17 

7 9.38 1.88 3.75 3.00 0.60 1.20 

8 9.61 1.92 3.84 3.07 0.61 1.23 

9 9.84 1.97 3.94 3.15 0.63 1.26 

10 10.08 2.02 4.03 3.22 0.64 1.29 

Total 90.68 18.14 36.27 29.02 5.80 11.61 

Note: Totals may not add due to rounding. 

Fofonoff et al. 2003 also evaluated temporal changes in the shipping vectors and found that 

ballast water invasions appear to be growing at a faster rate over the past 30 years in 

comparison to hull fouling invasions, although there is considerable uncertainty due to the 

relatively large number of invasions that could not be definitively classified. 

Fraction of Invasions That Cause Economic Harm

Further, not all invasions will cause economic harm. According to Windle 1997: “On 

average, 15 percent of foreign species trigger severe economic or financial damage and about 

40 percent cause some harm.” For the purposes of this analysis, we assume that 15 percent 

of the invasions will cause economic damage, a figure that is also in line with the findings of 

the OTA 1993 assessment. We note that we may be underestimating the number of harmful 

species by not including all or some fraction of the 40 percent of species that may cause 

some economic harm. We are also not including the impacts of invasions that cause 

environmental damage that does not result in economic harm. As seen in Table 5.7, during 

the 10-year period, 4.35 invertebrate invasions, 0.87 fish invasions, and 1.74 aquatic plant 

invasions due to ballast water are expected to cause severe economic or financial damage. 

 

80 
Table 5.7 Estimated Number of Ballast Water Initial Invasions That Cause Severe Economic or Financial 

Harm 

Year Invertebrate Fish Aquatic Plant 

1 0.39 0.08 0.16 

2 0.40 0.08 0.16 

3 0.41 0.08 0.16 

4 0.42 0.08 0.17 

5 0.43 0.09 0.17 

6 0.44 0.09 0.18 

7 0.45 0.09 0.18 

8 0.46 0.09 0.18 

9 0.47 0.09 0.19 

10 0.48 0.10 0.19 

Total 4.35 0.87 1.74 

 Note: Totals may not add due to rounding. 

5.6 Costs of Ballast Water Invasions 

As discussed earlier, no comprehensive estimate is available on the costs from past invasions. 

Most studies focus on one species and often only consider certain types of costs or costs in 

certain regions, resulting in a wide variability of estimates. For this reason, we do not try to 

develop a composite cost estimate for all invasions, but instead select a low and high estimate 

for fish, aquatic plants and invertebrates based on representative species. We then calculate a 

mid-point for the range and calculate costs for future invasions using all three values. 

Appendix H contains a summary of available cost estimates for invasions and a discussion 

documenting the choice of the low and high range cost estimates per species. Table 5.8 

displays the range of values used in subsequent calculations. 

Table 5.8 Range of Annual Costs Associated with Selected NIS Introductions ($ 2007) 

Low Range Mid Range High Range

Fish $ 15,805,000 [1] $ 160,547,000 $ 305,289,000 [2] 

Invertebrates $ 19,538,000 [3] $ 539,769,000 $ 1,060,000,000 [4] 

Aquatic Plants $ 4,507,000 [5] $ 214,585,500 $ 424,664,000 [6] 

[1] From Jenkins 2001, economic impact of sea lamprey on Great Lakes, updated from 2001$ 

[2] From Leigh 1998, commercial and recreational fishing benefits lost due to ruffe invasion of 

Great Lakes, updated from 1998$ 

[3] From Connelly et al. 2007, cost of Zebra Mussel control at WTP and electric generation facilities, updated 

from 2004$ 

[4] From Piementel et al. 2005, cost of Zebra Mussel or Asian Clam, updated from 2005$ 

[5] From Rockwell 2003, cost to control Water Hyacinth in Louisiana, updated from 2003$ 

[6] From Pimentel 2005, cost to control Eurasian watermilfoil, updated from 2005$ 

81 
We assume that once an invasion is established, it will continue to generate costs and/or 

damages for each year subsequent to the invasion. Thus, an invasion that occurs in the first 

year of our analysis will incur costs/damages in each of the next 10 years. Also, these 

estimates of costs include the impact of secondary spread of an invasion to areas other than 

the site of the initial invasion. 

Based on the cumulative impacts of invasions, we have calculated a mid-range estimate of 

annual costs for all harmful BW-introduced invasions over the 10 year period at $1.453 

billion (7 percent) assuming that ballast water invasions represent 32 percent of shipping 

invasions. The annual cost of ballast water invasion for the 10-year period varies from 

approximately $54 million to $2.852 billion based on the range of estimated costs per 

invasions as shown on Table 5.9 at 7 percent discount rate. 

Table 5.9a Summary of Potential Cost ($ Mil)/Damage of BW Invasion over a 10-year Period 

Range of NIS Costs Total Cost for 

(3% disc. rate) 

Total Cost for 

(7% disc. rate) 

Low Range $ 56 $ 54 

Mid Range $ 1,491 $ 1,453 

High Range $ 2,926 $ 2,852 

Table 5.9b Potential Cost ($ Mil)/Damage of BW Invasion over a 10-year Period – 

7 Percent Discount Rate 

 7% Discount Rate 

Year Low Mid High 

1 $10 $256 $503 

2 $18 $485 $952 

3 $26 $688 $1,351 

4 $32 $868 $1,704 

5 $38 $1,027 $2,015 

6 $43 $1,165 $2,288 

7 $48 $1,287 $2,525 

8 $52 $1,391 $2,731 

9 $55 $1,481 $2,907 

10 $58 $1,557 $3,056 

Total $380 $10,205 $20,031 

Annualized $54 $1,453 $2,852 

82 
Table 5.9c Potential Cost ($ Mil)/Damage of BW Invasion over a 10-year Period – 

3 Percent Discount Rate 

 3% Discount Rate 

Year Low Mid High 

1 $10 $256 $503 

2 $19 $504 $989 

3 $28 $743 $1,458 

4 $36 $973 $1,910 

5 $45 $1,196 $2,347 

6 $53 $1,410 $2,768 

7 $60 $1,617 $3,174 

8 $68 $1,816 $3,565 

9 $75 $2,009 $3,943 

10 $82 $2,194 $4,306 

Total $474 $12,718 $24,962 

Annualized $56 $1,491 $2,926 

5.7 Benefits (Averted Costs) of Ballast Water Discharge Standards 

This section describes the main benefits likely to occur from the establishment of BWDS. 

The standards main goal is the prevention of future NIS invasions. The value of the benefits 

for each alternative considered varies based on a particular alternative’s effectiveness in 

preventing future invasions. The Final Programmatic Environmental Impact Statement 

(FPEIS)38 has estimated the reduction in the mean rate of successful introductions of various 

alternative standards. As described in detail in Appendix A of the DPEIS, a mathematical 

model was developed based on the premise that a decrease in the number of living organisms 

initially introduced through ballast water discharges into a waterway reduces the probability 

that a population becomes successfully established39. The researchers first develop a model 

of the simplest case in which a single species is discharged during a ballast water discharge 

event (referred to as a single species model). The researchers then used this simple model to 

develop a more complex model representing a situation where multiple species are 

discharged from a vessel (referred to as the multi-species model). The multiple species 

 

38 Source: USCG. 2010. Final Programmatic Environmental Impact Statement for Standards for Living 

Organisms in Ship’s Ballast Water Discharged in U.S. Waters. DOT Document Number: USCG-2001-10486.. 

39As identified in the NAS 2011 report, there are major data gaps ("a profound lack of data and information") 

and therefore no available information on multiple discharges (at the time of this rule publication). As 

recommended by NAS, models need to be developed to assess these risks and to link to new information as they 

become available. USCG will consider models that may be available during a practicability review performed 

under NISA. This may provide additional information to address the risk associated with multiple ballast 

discharges. 

83 
model is the appropriate model to use for the calculation of benefits as it is the more 

ecologically realistic scenario.40

The goal of the multi-species model is to estimate the probability that a single ballast water 

discharge containing multiple invasive species in different concentrations will result in at 

least one successful introduction of an invasive species. The BWDS is intended to decrease 

the probability of NIS establishment by reducing the number of individual organisms that are 

introduced via BWD. The multi-species model is used to estimate the probability of a 

successful invasive species introduction. The probability of introductions is compared 

against the baseline probability of introduction to calculate the reduction in the probability of 

introduction.

The FPEIS developed two different baselines based on different assumptions about current 

ballast water management practices. One baseline assumes that no ballast water management 

is being practiced and the other assumes that ballast water exchange takes place. To estimate 

benefits, we use the ballast water exchange baseline as most ocean-going vessels are 

currently required to conduct ballast water exchange. However, not all ocean-going vessels 

can conduct exchange for all voyages, thus some fraction of voyages may occur under the no 

ballast water management baseline. For the purposes of this analysis of benefits, we are 

unable to separate out the invasion risk associated with conditions under which exchange is 

not conductedand therefore use the conservative assumption that all ocean-going vessels are 

conducting ballast water exchange for all voyages. 

Table 5.10 presents the reduction in the mean rate of invasions that would result from the 

BWDS. In comparison with the existing practice of ballast water exchange, the BWDS is 

between 37 percent to 63 percent effective in preventing invasions when fully implemented. 

41 Please refer to the FPEIS for further information on the derivation of these estimates. 

 

40 Source: FPEIS. 

41 The range in effectiveness is the result of different assumptions as to the threshold below which a population 

is considered extinct for the purposes of invasive species. For example, a Ne=1 in Table 5.10 assumes that all 

organisms of a particular species have to be eradicated for species to be unable to colonize the new environment 

(i.e., the new waterway). For many species, however, a certain population size is necessary for successful 

colonization. Thus, the analysis in the FPEIS also uses a threshold of 100, meaning that 100 organisms of a 

species would need to survive for the invasion to be successful (Ne=100). Please refer to Appendix A of the 

FPEIS for further explanation. 

84 
Table 5.10 Reductions in the Mean Rate of Successful INS Introductions 

 (Multiple Species Model) 

Extinction 

Threshold 

Assumption [1] 

BW 

Exchange 

Ne = 1 37% 

= 100 Ne 63% 

Source: FPEIS, Page 4-13, Table 4-2. 

[1] The extinction threshold refers to the number of organisms below which a population 

is considered extinct. 

As discussed in Chapter 4, the implementation of the FR BWDS will be phased-in over 

several years. For the purposes of estimating quantitative benefits, we assume that no 

invasions will be avoided before the end of this period, because only a subset of ships will 

have implemented ballast water management. This approach may lead to an underestimate of 

potential benefits.42 The resulting schedule of invasions avoided 

for the Ballast Water Discharge Standard is displayed in Table 5.11. 

Table 5.11 Harmful Ballast Water Initial Invasions Avoided – Phased-In Schedule 

Year 

Number of Harmful Ballast Water 

Invasions Avoided –Low Effectiveness 

Number of Harmful Ballast Water 

Invasions Avoided –High Effectiveness 

Invertebrate Fish Aquatic 

Plant Invertebrate Fish Aquatic Plant 

1 0.000 0.000 0.000 0.000 0.000 0.000 

2 0.000 0.000 0.000 0.000 0.000 0.000 

3 0.000 0.000 0.000 0.000 0.000 0.000 

4 0.000 0.000 0.000 0.000 0.000 0.000 

5 0.000 0.000 0.000 0.000 0.000 0.000 

6 0.163 0.033 0.065 0.277 0.055 0.111 

7 0.167 0.033 0.067 0.284 0.057 0.113 

8 0.171 0.034 0.068 0.290 0.058 0.116 

9 0.175 0.035 0.070 0.298 0.060 0.119 

10 0.179 0.036 0.072 0.305 0.061 0.122 

Total 0.85 0.17 0.34 1.45 0.29 0.58 

Note: Totals may not add due to rounding. 

Benefits are presented in Table 5.12 and assume no benefits during the phase-in period. 

Tables G-1 and G-2 in Appendix G present the estimate of benefits by year. 

The minimum avoided costs is $5 million and the maximum is $470 million with a midrange estimate of $141-$240 million per year at a 7 percent discount rate.

 

42 We estimate benefits using an alternative assumption that the fraction of invasions avoided will be 

proportional to the fraction of the vessels installing management systems in Appendix F. 

85 
Table 5.12 Potential Annual Benefits (Avoided Costs) of Ballast Water Initial Invasions over a 10-year 

Period ($ Mil)* 

Low Range Costs Per 

Species 

Mid Range Costs Per 

Species 

High Range Costs Per 

Species 

Reductions in Mean Rate 

of Invasion 

3% discount 

rate 

7% 

discount 

rate 

3% 

discount 

rate 

7% 

discount 

rate 

3% 

discount 

rate 

7% 

discount 

rate 

Low Effectiveness - 37% $ 6 $ 5 $ 155 $ 141 $ 304 $ 276 

High Effectiveness - 63% $ 10 $ 9 $ 264 $ 240 $ 518 $ 470 

* We estimated the costs in Table 5.12 using values in Table 5.8 and Table 5.11. Tables G-1 and G-2 in Appendix G 

present the estimate of benefits by year. 

Over a 10-year period of analysis, we estimate the total discounted present value benefits of 

the phase-one BWDS to be as high as $3 billion with a mid-range estimate of $0.99 billion to 

$1.68 billion43 (see Appendix G for details on 10 and 20-year estimates).

The estimates of benefits resulting from the ballast water discharge standard are based on 

preventing initial invasions only. The range of costs per invasion presented in Table 5.6 

includes the impact of secondary spread of invasions, but only in the context of preventing an 

initial invasion (i.e., if an initial invasion is prevented, the secondary spread of that invasion 

is also prevented). We have not found complete data or identified appropriate models to 

quantify the possible benefits associated with reducing the secondary spread of invasions. 

Therefore, we do not expect the exemption of inland vessels to reduce the estimate of 

quantified benefits given data and modeling limitations. 

5.8 Potential Benefits Transfer 

The estimates of costs avoided by preventing NIS invasions encompass many categories of 

losses, some of which may represent a potential transfer of benefits. Some of the categories 

of losses that are included in the avoided costs include: 

• Costs to control non-indigenous species 

• Damage to infrastructure and resulting losses 

• Loss of both commercial and recreational fishery resources 

• Loss of recreation and tourism opportunities 

Losses of natural or capital resources are generally not considered transfers. Thus, control 

costs, damage to infrastructure, and loss of fishery resources are not likely to be transfers, 

although lost business resulting from damaged infrastructure may be a transfer. Loss of 

recreation and tourism opportunities may be a transfer if the recreational user substituted 

 

43 The mid-range benefit estimate varies based on the assumed effectiveness factors of preventing invasions 

(37% and 63%). The average of the mid-range benefit estimate for the 10-year period of analysis is $1.34 

billion (range: $0.99 billion to $1.68 billion). 

86 
another form of recreation or participated in the same activity at a different location. Under 

the presumption that the original recreational experience was the first choice of the user, the 

alternative recreational opportunities would not have the same value as the primary choice of 

activity with the difference representing a net economic loss. 

It is difficult to comprehensively ascertain the portion of the calculated benefits in each 

category in order to break out potential transfers. Many of the estimates of costs per species 

simply do not provide sufficient detail to divide costs into the categories. In addition, the 

distribution of costs by category differ from invasive specie to specie. A few studies have 

provided specie-specific information of costs or damages by category. For example, O’Neill 

1997 surveyed infrastructure owners on their expenditures on zebra-mussel related activities. 

Only about 1.1 percent of the zebra mussel expenditures were related to recreation or 

tourism. The majority of the expenditures were related to water treatment plants and electric 

power generation facilities. Pimentel 2005 estimated that about 16 percent of economic 

impacts (damages and control costs) from mussels in the New York State Canal and Hudson 

River system were related to tourism or recreation. On the other hand, Pimentel 2005 

estimates that 50 percent of the impacts from invasive fish species in this region are related to 

tourism or recreational activities such as sport fishing. Based on this limited information, 

some portion of the estimated benefits from preventing future invasions may represent 

transfers, but the amount will vary widely depending on the nature of the specie and extent of 

the invasions. 

5.9 Sources of Uncertainties and Alternative Use of Risk-Based DecisionMaking in Addressing Benefits 

The benefit analysis is based on assumptions regarding a number of inputs, which introduces 

uncertainty into the resulting estimates. Table 5.13 summarizes some of the assumptions 

underlying the analyses and assesses the likely impact of the assumptions on the estimates of 

damages and benefits. 

87 
Table 5.13 Uncertainties and Possible Effects on Estimation of Benefits 

Uncertainty 

Effect on Benefits Estimate 

Under-Estimate Over-Estimate Unknown Impact 

Rate of future invertebrate invasions (uses Ruiz el al 

2000 model to project) X 

Exclusion of invasions that have shipping as one of 

the potential vectors X 

Relationship of the number of fish and aquatic plant 

invasions to the number of invertebrate invasions X

Fraction of shipping invasions due to ballast water X

Fraction of invasions that cause harm X

Costs per invasion Quantified in the primary analysis 

(addresses range of potential underestimate or overestimate) 

Mean rate of invasions/invasions reduced Quantified in the primary analysis 

(addresses range of potential underestimate or overestimate)

Invasions avoided during phase-in period X 

Potential transfers X

Risk-based approach to evaluate NIS invasions from 

ballast water X 

Impact of reducing secondary spread of invasions 

through coastwise and inland traffic X 

Potential impacts on biodiversity, public health, and 

subsistence populations are not quantified in the 

analysis 

X 

88 
6 Comparison of Costs and Benefits 

The annualized cost for domestic vessels over the 10-year period for the phase one standard 

is estimated at $92 million44 at a 7 percent discount rate. The estimate of quantified benefits 

for the phase one standard ranges from $5 million to $470 million per year (see Figure 6.1), 

with a mid-point of $141-$240 million per year at a 7 percent discount rate. Thus, quantified 

benefits exceed the estimated costs for mid-point benefits estimate of Low Effectiveness. 

The high range annual cost estimate of $178 million is considerably less than the high range 

benefits estimate of Low Effectiveness. Additional benefits to the areas of ecological 

damages such as loss of biodiversity, impacts to public health and impacts on subsistence 

populations are expected to accrue as a result of the BWDS, but cannot be quantified at this 

time. 

Figure 6.1 Range of Quantified Benefits and Annual Costs (7% Discount Rate, $2007) 

$5

Low

$141

Mid

$276

High

$9

Low

$240

Mid

$470

High

$- $100 $200 $300 $400 $500

($ Millions)

Annual Benefits

Low Effectiveness

Annual Benefits 

High Effectiveness

Average 

Annualized 

Costs

Comparison of Discounted Cumulative Benefits and Costs

Based on our projected invasions avoided, the breakeven point (discounted cumulative 

benefits equal or outweigh discounted cumulative costs) would be reached in year 7 for the 

Alternative 2 assuming a 63 percent reduction in the invasion rate and by year 9 for 

Alternative 2 assuming a low reduction in invasion rate of 37 percent. Figure 6.2 illustrates 

the cumulative costs of the BWD in relationship to the damages avoided. 

 

44 Total discounted cost of $1.191 billion amortized over 10 years using the Capital Recovery Factor equation at 

7% discount rate because of the large capital installation costs required by the rulemaking. 

89 
Figure 6.2 Comparison of Cumulative Costs and Benefits (7% Discount Rate, $2007, Mid-Point Benefit 

per Invasion Estimate) 

Based on comments received on the NPRM, commenters noted that the BWDS would 

continue to accrue benefits after the 10-period of our analysis. For illustrative purposes, we 

present cumulative benefits and costs over a 20-year period of analysis in Appendix G. 

90 
6.1 Comparison of Alternative Phase-In Schedules 

6.1.a. FR Phase-In Schedule for Costs and Benefits 

The schedule for vessels installing ballast water management systems and producing benefits 

from the reduction in the introduction of invasive species can vary based on the assumed 

timing of implementation. 

Based on the FR text, different groups of vessels have different compliance requirements: 

Table 6.1 FR Phase-In implementation Schedule 

Vessel’s Ballast Water 

Capacity 

Vessel’s Construction Date Vessel’s Compliance Date 

New vessels All On or after December 1, 2013 On delivery 

Existing 

vessels 

Less than 1500 m3 Before December 1, 2013 First scheduled drydocking 

after January 1, 2016 

1500-5000 m3 Before December 1, 2013 First scheduled drydocking 

after January 1, 2014 

Greater than 5000 m3 Before December 1, 2013 First scheduled drydocking 

after January 1, 2016 

All new vessels constructed on or after December 1, 2013 must comply with the standard. 

For existing vessels, the vessels that have the early conversion deadline are those with a 

ballast water capacity of greater than 5,000 and less than 1,500 cubic meters. These will be 

referred to below as Type 2 vessels. The remaining existing vessels will be referred to as 

Type 1 vessels. Based on these assumptions we have calculated different compliance 

scenarios in order to determine potential variation in cost and benefit estimates due to the 

compliance schedule. 

6.1.b. Compliance Comparison Between NPRM RA and FR RA 

NPRM Primary Cost Scenario 

Our analysis for the NPRM assumed that all vessels will comply with the standard by 2016, 

which follows the IMO Convention implementation schedule. We also assumed that some 

vessels will be required to convert by the end of 2014. Table 6.2 displays the fraction of 

vessels in each group scheduled to install management technology in each year as assumed in 

the NPRM analysis. 

91 
Table 6.2 NPRM Analysis Compliance Phase-In Assumption 

Year New Vessels Type 1 

Vessels 

Type 2 

Vessels 

1 100% 20% 30% 

2 100% 20% 30% 

3 100% 20% 40% 

4 100% 20% N/A

5 100% 20% N/A

6 100% N/A N/A

7 100% N/A N/A

8 100% N/A N/A

9 100% N/A N/A

10 100% N/A N/A

FR Primary Cost Scenario 

For existing vessels, the FR ties the installation of ballast water management systems to the 

drydocking schedule of a vessel. For vessels in Type 1, the compliance date for a vessel is at 

the first scheduled drydocking after January 1, 2016. For vessels in Type 2, the compliance 

date for a vessel is at the first scheduled drydocking after January 1, 2014. Based on 

information from the Navigation and Vessels Inspection Circular (NVIC) 1-89 on the vessel 

drydocking requirements, we assume that a vessel is on a once per 2.5-year drydocking 

schedule for saltwater vessels. In the absence of information a the specific business model 

for vessel owners and operators, we assume that for Type 1 vessels, 40 percent will install 

during 2016, 40 percent during 2017 and 20 percent during the half year in 2018. Type 2 

vessels will follow a similar pattern, only beginning in 2014. Table 6.3 presents the resulting 

schedule for compliance. 

Table 6.3 FR Primary Scenario Compliance Assumption 

Year New Vessels Type 1 

Vessels 

Type 2 

Vessels 

1 100% 0% 40% 

2 100% 0% 40%

3 100% 40% 20%

4 100% 40% N/A

5 100% 20% N/A

6 100% N/A N/A

7 100% N/A N/A

8 100% N/A N/A

9 100% N/A N/A

10 100% N/A N/A

6.1.c. Alternative Compliance Scenarios for the FR RA 

We looked into alternative compliance scenarios in order to access the sensitivity of the cost 

estimates to the percentage of vessels installing the BWMS in different years. 

92 
Scenario 1: In this scenario, we assume a more even (compared to Scenario 1) distribution of 

vessels complying with the FR requirements. This scenario might better represent vessel 

owners using their scheduled drydocking to install the BWMSs. In this case, for the Type 1 

vessels, 30 percent will install during year 3, 30 percent during year 4 and 40 percent during 

the half year in year 5. Type 2 vessels will follow a similar pattern, only beginning in year 1. 

Table 6.4 presents the resulting schedule for compliance.

Table 6,4 FR Primary Scenario Compliance Assumption 

Year New Vessels Type 1 

Vessels 

Type 2 

Vessels 

1 100% 0% 30% 

2 100% 0% 30%

3 100% 30% 40%

4 100% 30% N/A

5 100% 40% N/A

6 100% N/A N/A

7 100% N/A N/A

8 100% N/A N/A

9 100% N/A N/A

10 100% N/A N/A

Scenario 2: In this scenario, we assume that the majority of the vessel owners will postpone 

the system installation until the last year. This would be expected industry behavior in order 

to minimize risks and costs. In this scenario, the Type 1 vessels, 20 percent will install during 

year 3, 20 percent during year 4 and 60 percent during the half year in year 5. Type 2 vessels 

will follow a similar pattern, only beginning in year 1. Table 6.5 presents the resulting 

schedule for compliance.

Table 6.5 FR Primary Scenario Compliance Assumption 

Year New Vessels Type 1 

Vessels 

Type 2 

Vessels 

1 100% 0% 20% 

2 100% 0% 20%

3 100% 20% 60%

4 100% 20% N/A

5 100% 60% N/A

6 100% N/A N/A

7 100% N/A N/A

8 100% N/A N/A

9 100% N/A N/A

10 100% N/A N/A

6.1.d. Comparison Between Different Cost Scenarios in the FR RA 

The primary cost estimate represents the higher compliance costs since the majority of the 

vessels will have their systems installed in the first two years of the rule implementation. 

93 
While industry practice is to delay additional costs as long as possible, we assumed that the 

fleet will undergo system installations during routine drydocking for other regularly 

scheduled maintenance. As we postpone BWMS installations, the costs of the FR decrease 

(as shown in scenarios 1 and 2). The variation between the total and annual primary cost 

estimates and scenarios above are around only 1 percent. 

Table 6. 6 Cost Comparison Between Different FR RA Scenarios 

($ Mil, 7 Percent discount rate) 

Primary Scenario 1 Scenario 2 

Total Cost $649 $642 $634 

Annual Cost $92 $91 $90 

6.2 Comparison of NPRM Alternatives 

As discussed earlier, in the Regulatory Analysis for the NPRM, Coast Guard considered five 

regulatory Alternatives, plus a Phase 2 Alternative. The FPEIS contains effectiveness 

information that allows us to calculate an estimate of benefits for Alternatives 3, 4 and 5. 

The FPEIS does not have a similar estimate of effectiveness for the Phase 2 Alternative; 

therefore we cannot calculate benefits for Phase 2 based on existing information. In addition, 

as discussed in Section 4.6, we cannot estimate the costs of meeting BWDS more strict than 

the IMO standard based on the level of uncertainty of system configuration, performance, 

and cost. Table 6.7 summarizes the comparison of the Alternatives considered in NPRM 

based on available cost and benefits data. 

Table 6.7 Comparison of NPRM Alternatives 

($ Mil., 7 Percent discount rate) 

Alternative Standard

Annual Benefits 

(Low Effectiveness) Annual Costs 

Effectiveness ($ Millions) ($Millions)

1 No Action 0% $0 $0 

2 IMO Standard 37% $141 $92 

3 10X IMO Standard 64% $244 Data not available 

4 100X IMO Standard 85% $323 Data not available 

5 Sterilization* 100% $380 Data not available 

Phase 2 1,000X IMO Standard (CA) Data not available Data not available Data not available 

Note: Benefits for alternatives 1-4 are based on low effectiveness estimates from the FPEIS. The FPEIS 

presents Alternative 5, Sterilization, as 100% effective. See FPEIS pages 4-13 (Table 4-2) and 4-16. 

94 
7 Final Regulatory Flexibility Act Analysis 

7.1 Summary of the NPRM IRFA 

The U.S. Coast Guard (USCG) performed an initial regulatory flexibility analysis (IRFA) of 

the impacts on small businesses and other entities from the 2008 NPRM for Standards for 

Living Organisms in Ship’s Ballast Water Discharged in U.S. Waters. We have performed 

this assessment using the cost information discussed in chapter 4. We have determined that 

the rule will result in a significant economic impact on a substantial number of small entities 

under section 605(b) of the Regulatory Flexibility Act. Below is a summary of our IRFA 

findings: 

• There were an estimated 850 U.S. entities that would be affected by the rulemaking, 

these businesses operated 2,616 vessels affected by the NPRM; 

• We estimated that of these 850 U.S. entities, 57 percent were considered small; 

• These firms will be required to purchase and install a ballast water management 

system for each affected vessel they own, costing between $258,000 and $419,000 

per vessel, depending on the vessel type; 

• We have assumed that firms will finance the purchase of this equipment and therefore 

we have used the annual payment to service the loan as the annual cost for 

installation; 

• Annual recurring operational costs of the NPRM resulted in less than 1% impact on 

revenue for 100 percent of the firms; 

• For a 10-year finance scenario, we estimated 72 percent of small firms would incur an 

annual cost impact greater than 1 percent of annual revenue; and, 

• For a 20-year finance scenario, we estimated 59 percent of small firms would incur an 

annual cost impact greater than 1 percent of annual revenue. 

7.2 Changes from the NPRM IRFA 

Tables 7.1 and 7.2 present the comparison between the NPRM findings and revised FR 

findings. In the IRFA for the NPRM, we assumed 10-year and 20-year cost finance 

scenarios. The resulting analysis in the IRFA showed that 72 percent and 59 percent of the 

small entities (10-year finance and 20-year finance, respectively) would have an annual cost 

impact greater than 1 percent of annual revenue. For these estimates, we assumed that vessel 

owners would opt for the least expensive systems available. 

Given the changes in the applicability (from the NPRM to the FR), there was a reduction in 

the number of vessels and entities affected by the rule. For this reason, we updated the 

revenue impacts from the IRFA and found that 69 percent and 56 percent of the small entities 

(10-year finance and 20-year finance, respectively) would have an annual cost impact greater 

than 1 percent of annual revenue. There was a reduction in economic impacts on small 

entities as a result. 

95 
Table 7.1 . Comparison of the NPRM and FR Number of Small Entities 

Impact Range 

NRPM FR 

10-yr 

Finance 

20-yr 

Finance 

10-yr 

Finance 

20-yr 

Finance 

≤ 1% 20 29 11 16 

> 1 to ≤ 3% 16 12 11 7 

> 3 to ≤ 5% 8 8 2 3 

> 5 to ≤ 10% 8 11 2 3 

> 10% 19 11 10 7 

Total 71 71 36 36 

Note: Totals may not add due to rounding. 

Table 7.2 . Comparison of the NPRM and FR Installation Impact on Small Entities 

Impact Range 

NRPM FR 

10-yr 

Finance 

20-yr 

Finance 

10-yr 

Finance 

20-yr 

Finance 

≤ 1% 28% 41% 31% 44% 

> 1 to ≤ 3% 23% 17% 31% 19% 

> 3 to ≤ 5% 11% 11% 6% 8% 

> 5 to ≤ 10% 11% 15% 6% 8% 

> 10% 27% 15% 28% 19% 

Total 100% 100% 100% 100% 

Note: Totals may not add due to rounding. 

7.3 Final Regulatory Flexibility Analysis 

The Regulatory Flexibility Act of 1980 (Public Law 96-354) establishes “as a principle of 

regulatory issuance that agencies shall endeavor, consistent with the objectives of the rule 

and of applicable statutes, to fit regulatory and informational requirements to the scale of the 

businesses, organizations, and governmental jurisdictions subject to regulation. To achieve 

this principle, agencies are required to solicit and consider flexible regulatory proposals and 

to explain the rationale for their actions to assure that such proposals are given serious 

consideration.” 

When an agency promulgates a final rule under section 553 of the Regulatory Flexibility Act 

(RFA), after being required by that section or any other law to publish a general notice of 

proposed rulemaking, or promulgates a final interpretative rule involving the internal revenue 

laws of the United States as described in section 603(a), the agency must prepare a final 

96 
regulatory flexibility analysis (FRFA) or have the head of the agency certify pursuant to RFA 

section 605(b) that the rule will not, if promulgated, have a significant economic impact on a 

substantial number of small entities. The RFA prescribes the content of the FRFA in section 

604(a), which we discuss below. 

(1) a statement of the need for, and objectives of, the rule; 

The unintentional introduction of non-indigenous species (NIS) into the waters of the United 

States via the discharge of ships’ ballast water continues to contribute to the loss of marine 

biodiversity and to lead to significant social, economic, and biological impacts. Current U.S. 

regulations require ballast water management (BWM) to prevent introductions of NIS 

through ballast water discharge (BWD). Currently, the primary management method for 

controlling ballast water discharged in U.S. waters is a mid-ocean exchange of ballast water 

obtained from waters outside the U.S. Exclusive Economic Zone (EEZ). Concern remains 

that this approach to ballast water management is not sufficiently effective in preventing the 

introduction of NIS nor can many vessels conduct ballast water exchange because of safety 

issues and or voyage constraints. The U.S. is proposing a rule to establish a ballast water 

discharge standard for the allowable concentrations of living organisms discharged via 

ballast water into U.S. waters. The objective is to reduce the probability of unintentional 

introduction of NIS into the waters of the United States via the discharge of ships’ ballast 

water. Reducing the probability will reduce the harmful biological and economic effects of 

NIS with the goal of reducing the number of NIS invasions and resulting biological impacts 

and economic losses. 

(2) a statement of the significant issues raised by the public comments in response to the 

initial regulatory flexibility analysis, a statement of the assessment of the agency of such 

issues, and a statement of any changes made in the proposed rule as a result of such 

comments; 

On August 28, 2009, we published a Notice of Proposed Rulemaking (NPRM) entitled 

Standards for Living Organisms in Ships’ Ballast Water Discharged in U.S. Waters in the 

Federal Register (74 FR 44632). We summarized these comments in the Final Rule section 

V. Discussion of Comments and Changes. The great majority of the comments on the NPRM 

RA were from the inland, Great Lakes and coastwise industries. The commenters raised 

many different issues related to the ballast water operations, such as the use of 

municipal/potable water, technology costs, size limitations and underestimation of the 

affected population (for not including inland vessels and vessels under 100 feet due to the 

general applicability of the NPRM). Additionally, commenters expressed concern that the 

cost estimates for the proposed Phase 2 standard was not included in any of the supporting 

documentation or analysis. Remaining comments were on cost to foreign vessels, benefits, 

small entities analysis and uncertainties. The significant issues raised by the public comments 

on the IRFA were the following: 

A) Cumulative Impact of Regulations on Small Businesses - One commenter noted that 

the Coast Guard did not take into account the cumulative impact of other Coast Guard 

regulations on small businesses. The commenter argued that the BWDS rule will 

97 
impose more costs on top of the other regulations for affected passenger vessel 

operations. 

For the proposed rule, the Coast Guard completed an Initial Regulatory Flexibility 

Analysis (IRFA). The specific statutory requirements of an IRFA can be found at 5 

U.S.C. 603(b). Under these statutory requirements, we did not consider the 

cumulative impact of other Coast Guard regulations on small businesses or affected 

passenger vessel operations. The Coast Guard acknowledges that other Coast Guard 

regulations have imposed additional costs on vessel owners and operators subject to 

this rule, which contains revised applicability that excludes most vessels operating 

solely in coastwise trade as previously discussed. 

Many of these published regulations are due to international agreements such as the 

International Convention for the Prevention of Pollution from Ships (MARPOL) and 

the International Convention for the Safety of Life at Sea (SOLAS). This rule also 

aligns with the International Convention for the Control and Management of Ships 

Ballast Water and Sediments (IMO BWM Convention). The U.S. responsibility as a 

party to these international agreements is to ensure the fulfillment of the requirements 

by promulgating regulations that are consistent with these agreements. If the Coast 

Guard does not fulfill its obligations under these international agreements, then it 

risks the consequences of noncompliance (e.g., reduced commerce and trade as a 

result of U.S. flag vessels on foreign voyage not compliant with international 

agreements). 

Additionally, for this rule, the Coast Guard is acting under the legislative mandates in 

NANPCA, as amended by NISA, to authorize the use of any alternative methods of 

BWM that are used in lieu of mid-ocean BWE. As previously discussed, these 

mandates require the Secretary of Homeland Security to ensure to the maximum 

extent practicable that aquatic nuisance species are not discharged into waters of the 

United States from vessels. 16 U.S.C. 4711(c)(2)(A). In addition, NISA requires the 

Secretary to assess and revise the Department’s BWM regulations not less than every 

3 years based on the best scientific information available to her at the time of that 

review, and potentially to the exclusion of some of the BWM methods listed at 16 

U.S.C. 4711(c)(2)(D). 16 U.S.C. 4711(e). The Coast Guard is publishing this FR 

based on these mandates. 

B) Number of Employees - Two commenters argued that, as a part of the financial 

burden, it is important for vessel companies to note the amount of 

employees/mariners they have. 

The Coast Guard agrees with the commenters and would like to note that the number 

of employees is taken into consideration in the IRFA. The IRFA is in chapter 7 of the 

NPRM RA available on the docket. The IRFA’s goal is to assess the proposed rule’s 

impact on small entities. Company revenue and number of employees (as well as 

number of vessels) are variables used in the estimation of potential economic impacts 

to small businesses. 

98 
The Coast Guard has assessed the public comments received on the NPRM RA and 

has determined the more research is necessary to assess the practicability and impacts 

of phase two standard; and to better understand ballast water operations and 

technology available for the following vessels: small coastwise, Great Lakes and 

inland. As a result, the Coast Guard has made changes to the applicability and other 

requirements of the rule. Detailed explanation of these changes follows. 

The FR contains a number of changes from the rule proposed by the NPRM (74 FR 

44632). Below we discuss change in the FR that was related to the public comments 

on the NPRM IRFA. For a full discussion of comments and Coast Guard responses is 

found in the FR section V.B. Discussion of Comments. 

(a) Changes in the Rule Applicability

In order to reduce the burden of this regulation over small coastwise and inland 

vessels and to allow more time to research these vessels’ ballast water operations, the 

Coast Guard has made changes in the rule applicability. In the NPRM, the Coast 

Guard proposed requiring all vessels discharging ballast water into waters of the 

United States to comply with the BWDS. This included vessels operating solely in 

coastwise trade and on the internal waters of the United States. These vessels are not 

required to conduct a BWE under the existing Coast Guard regulations, and, as such, 

the proposal was correctly seen as an expansion of those regulations. Commenters 

raised a number of issues regarding the applicability of the NPRM. These issues 

included uncertainty as to whether any of the currently available BWMS could be 

successfully installed on non-seagoing vessels, the cost of installation of BWMS on 

these industries, and the benefit of requiring these vessels to install a BWMS. As a 

result of these comments, the Coast Guard removed some vessels which previously 

were not required to conduct BWE from the FR applicability. These vessels are 

seagoing vessels that do not operate beyond the U.S. Exclusive Economic Zone 

(EEZ), and are greater than 1,600 gross register tons (GRT) (3,000 gross tons (GT) 

(International Tonnage Convention (ITC)). Therefore, inland, Great Lakes vessels 

and small coastwise vessels (equal or smaller than 1,600 GRT) are not required to 

comply with the FR. 

In addition, we revised 33 CFR §§ 151.1510 and 151.2025 to 1) clarify that discharge 

of ballast water into waters of the U.S. is a threshold requirement, and 2) include an 

additional BWM option for use of water from a public water supply, meeting certain 

EPA water quality standards. This adds flexibility to vessel owners and operators on 

installing a BWMS or other sources of ballast water (as long as this water meets EPA 

water quality standards). 

The Coast Guard has determined that additional research and analysis is necessary to 

support the expansion of the rule applicability. 

 

 

99 
(b) Removal of Phase Two Standard

The Coast Guard has decided to move forward with the phase-one (IMO) standard 

while assessing the practicability of implementing a phase-two standard, gathers 

additional data on technology available to meet the phase-two standard for various 

vessel types, and develops a subsequent rule with the economic and environmental 

analysis necessary to support the phase-two standard. The decision to remove the 

more stringent standard from the FR should not be interpreted as a sign that the Coast 

Guard is reconsidering its intent to increase the protectiveness of the BWDS. To 

provide the public with as much information as possible on which to base comments, 

the Coast Guard will develop additional analyses regarding the potential costs, 

benefits, and environmental impacts of the proposed phase-two standard. When these 

analyses are completed, the Coast Guard will make them available for public 

comment, either via a notice of availability or in conjunction with a subsequent 

rulemaking published in the Federal Register. 

Since the FR only includes the phase-one standard, the Coast Guard has omitted the 

grandfather provision and applicability reviews proposed in the NPRM. The Coast 

Guard expects to reconsider these provisions when we re-propose the phase-two 

standard in a notice or a subsequent rulemaking. 

(c) Delay of Compliance Date for New Vessels

Even with the provision for acceptance of foreign type approvals, a process that is 

expected to be quicker than completing the full schedule of land-based and shipboard 

tests, the Coast Guard anticipates there will not be an adequate number of approved 

BWMS to allow vessel owners to meet the NPRM’s proposed compliance date for 

new vessels. For this reason, the Coast Guard have pushed back the compliance date 

for new vessels to install Coast Guard-approved BWMS from January 1, 2012, to 

December 1, 2013. Additionally, the December 1st date will align the compliance 

date with the proposed effective date for the 2013 EPA VGP. The Coast Guard 

estimates that this deferral could delay the compliance date for up to 600 newly 

constructed vessels. 

The Coast Guard has also added a provision to both 33 CFR part 151 subparts C and 

D that will allow individual vessel owners to extend their compliance date if, despite 

the owner’s efforts, he or she cannot meet the published compliance dates. This 

change is in response to commenters who argued that the compliance timelines 

included in the NPRM were too aggressive. 

(3) the response of the agency to any comments filed by the Chief Counsel for Advocacy of 

the Small Business Administration in response to the proposed rule, and a detailed statement 

of any change made to the proposed rule in the final rule as a results of the comments.45

 

45 This section of 604(a) has been added by the Small Business Jobs Act of 2010. 

100 
The Coast Guard received comments from the SBA, Office of Advocacy, regarding the 

impact that the proposed rule will have on small entities. The comments provided by the 

SBA focused on small businesses within the tugboat, tow boat, and supply barge industries. 

According to the SBA letter, these small businesses are concerned that the Coast Guard’s 

economic analysis does not account for a significant number of vessels operated by small 

businesses. These businesses also contend that installing the required BWMS will not be 

economically feasible for the large number of vessels that discharge relatively small amounts 

of ballast water. The SBA also expressed concern about the cumulative effect of the 

proposed regulations should the phase-two standards be implemented without a longer 

grandfathering period than the five year period proposed. The SBA has made the following 

suggestions to improve the Coast Guard small entities analysis: 

a. Expand the scope of regulatory flexibility analysis to include more vessels 

(vessels less than 100 feet in length, tugboat, towing and supply vessels). 

b. Consider additional regulatory alternatives to increase flexibility for small 

business (such as exemption for vessels with relatively low-volume ballast 

tanks). 

c. Include a grandfathering provision with the phase-two standards 

The Coast Guard acknowledges the SBA concerns related to the vessels mentioned 

previously and is studying the BWM options for small vessels and vessels less than 1,600 

gross tons that operate solely in coastwise trade and inland waters of the United States. The 

Coast Guard has received numerous comments from these industries and has revised the 

applicability of the rule. As noted earlier in this RA, the BWDS in this FR applies only to 

vessels entering waters of the United States from outside the EEZ, to coastwise vessels that 

are more than 1,600 gross tons, and to certain other seagoing vessels meeting specific size 

thresholds (see V.A. Summary of Changes from the NPRM). 

Detailed statement of changes in the final rule as a result of the SBA, Office of Advocacy, 

comments as well as public comments are presented above in paragraph (2). 

(4) a description of and an estimate of the number of small entities to which the rule will 

apply or an explanation of why no such estimate is available; 

Based on current data provided by the Coast Guard’s Marine Information for Safety and Law 

Enforcement (MISLE) database, we estimate that there are approximately 533 U.S. entities 

operating 1,459 vessels affected by this rule. 

We used available operator name and address information to research public and proprietary 

databases for entity type (subsidiary or parent company), primary line of business, employee 

size, revenue, and other information.46 We matched this information to the Small Business 

Administration’s (SBA) “Table of Small Business Size Standards” to determine if an entity is 

 

46 We used information and data from Manta (http://Manta.com) and ReferenceUSA 

(http://www.referenceusa.com). 

101 
small in its primary line of business as classified in the North American Industry 

Classification System (NAICS).47 

We used the employee size and revenue data to identify the number and type of entities 

affected by the rulemaking based on the NRPM random sample of 150 vessel owners.. Due 

to the changes in the applicability (from the NPRM to the FR), there was a reduction in the 

number of entities affected by this rule. We found 36 small entities and 7 entities with no 

available data. We estimate the number of small entities affected by this rulemaking is 43 (36 

small and 7 with no data available). This corresponds to approximately 29 percent of small 

entities from the original NPRM sample. We found small entities affected by this rule to have 

multiple business lines. Some have a primary business line that is not unique to the maritime 

industry. Please, see Tables 7.1 and 7.2 for information on installation cost impact on small 

entities. 

(5) a description of the projected reporting, recordkeeping and other compliance 

requirements of the rule, including an estimate of the classes of small entities which will be 

subject to the requirement and the type of professional skills necessary for preparation of the 

report or record; and 

As a result of public comments, we have included a provision in the FR to allow vessel 

owners and operators to request an extension of their compliance date if they cannot 

practicably comply with the compliance date otherwise applicable to their vessel. This is a 

voluntary provision and will result reporting and recordkeeping burden to the vessel owner 

and operator applying for the extensions. Therefore, the Coast Guard is amending the 

existing (OMB CONTROL NUMBER: 1625-0069) to add these requests for extension (see 

Appendix I for more information). 

(6) a description of the steps the agency has taken to minimize the significant economic 

impact on small entities consistent with the stated objectives of applicable statutes, including 

a statement of the factual, policy, and legal reasons for selecting the alternative adopted in 

the final rule and why each one of the other significant alternatives to the rule considered by 

the agency which affect the impact on small entities was rejected. 

As described in section 7.4, the Coast Guard has made a number of changes from the rule 

proposed by the NPRM (74 FR 44632) after consideration of public comments. For a full 

discussion of comments and Coast Guard responses is found in the FR section V.B. 

Discussion of Comments. The following steps were taken by the Coast Guard to minimize 

the economic impact on small entities: changes in the rule applicability to exclude inland, 

Great Lakes vessels and small coastwise vessels (equal or smaller than 1,600 GRT), removal 

of Phase Two standard and delay compliance for new vessels providing additional time for 

small entities to plan for BWMS. 

 

47 The SBA lists small business size standards for industries described in the North American Industry 

Classification System (NAICS). See http://www.smallbusinessnotes.com/fedgovernment/sba/13cfr121/201-

4849.html (as of April 7, 2008). 

102 
The Coast Guard has considered six alternatives. The Coast Guard took into account each 

one carefully before choosing the preferred alternative, based on the input provided through 

the scoping process, as well as the information developed through workshops, international 

discussions, and public comments. The alternatives include: maintaining the current BWE 

requirement or “No Action”; four alternatives that would establish different and increasingly 

stringent levels of maximum concentrations for living organisms in discharged ballast water 

(IMO standard, 10, 100 and 1,000 more strict than the IMO standard); and a one that 

essentially requires sterilization of ballast water. The IMO standard is the preferred 

alternative. 

 

103 
A. No Action 

This alternative would not establish a BWDS. Instead, the mandatory BWM program 

established in accordance with the directives in the NISA would continue for vessels entering 

U.S. waters. Currently, the mandatory BWM program directs vessels to utilize at least one of 

the following BWM practices: conduct mid-ocean ballast water exchange, retain ballast 

water onboard, or use an environmentally sound treatment method approved by the Coast 

Guard. Some vessels cannot conduct mid-ocean ballast water exchange due to safety and 

voyage constraints. In addition, the Coast Guard has not yet approved any environmentally 

sound treatment methods. Thus, “No Action” means that the primary BWM practice for 

vessels would be to conduct mid-ocean exchange (BWE) when it is safe to do so and when 

the voyage permits. The Coast Guard would need to develop an approval program for 

alternative methods in lieu of a BWDS. Such a program must verify that the alternative 

methods are as effective as mid-ocean ballast water exchange. 

The Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990 (NANPCA), as 

amended by the National Invasive Species Act of 1996 (NISA), authorizes the Coast Guard 

to determine alternative methods of ballast water management for use in lieu of mid-ocean 

ballast water exchange (BWE). 16 U.S.C. 4711(c)(2)(D)(iii). NISA further stipulates that 

Coast Guard approved alternative BWM methods must be at least as effective as BWE in 

preventing or reducing the introduction of nonindigenous species (NIS) into waters of the 

United States. 16 U.S.C. 4711(c)(2)(D)(iii). 

NISA also requires the Coast Guard to assess and revise its BWM regulations not less than 

every 3 years based on the best scientific information available to the Coast Guard at the time 

of that review, and potentially to the exclusion of some of the BWM methods listed at 16 

U.S.C. 4711(c)(2)(D). 16 U.S.C. 4711(e). Determining whether an alternative method of 

BWM is as effective as BWE is not an easy task. The effectiveness of BWE is highly 

variable, largely depending on the specific vessel and voyage. These variables make 

comparing the effectiveness of an alternative BWM method to BWE extremely difficult. 

Results from several studies have shown the effectiveness of BWE varies considerably and is 

dependent on vessel type (design), exchange method, ballasting system configuration, 

exchange location, and method of study. Some studies suggest that the efficacy of BWE is 

80 to 99 percent per event (Dickman and Zhang 1999; Hines and Ruiz 2000; Rigby and 

Hallegraeff 1993; Smith et al. 1996; Taylor and Bruce 2000; Zhang and Dickman 1999). 

Other studies demonstrate that the volumetric efficiency of BWE ranges from 50 to 90 

percent (Battelle 2003; USCG 2001; Zhang and Dickman 1999). Thus, vessels with very 

large starting concentrations of organisms in their ballast tanks might still have large 

concentrations of organisms after BWE. In addition, vessels are constrained by design or 

route from conducting BWE in compliance with existing regulations prior to the majority of 

arrivals into waters of the United States. 

For these reasons, BWE is not well-suited as the basis for a protective programmatic 

regimen, even though it has been a useful interim management practice. We have concluded 

that, as an alternative to using BWE as the benchmark, establishing a standard for the 

concentration of living organisms that can be discharged in ballast water would advance the 

protective intent of NISA and simplify the process for Coast Guard approval of ballast water 

104 
management systems (BWMS). Additionally, setting a ballast water discharge standard 

(BWDS) would promote the development of innovative BWM technologies, facilitate 

enforcement of the BWM regulations, and assist in evaluating the effectiveness of the BWM 

program. 

Therefore, in the FR, the Coast Guard amend 33 CFR part 151 by establishing a BWDS and 

46 CFR part 162 by adding an approval process for BWMS intended for use onboard vessels 

to meet the BWDS. 

B. Phase One – IMO Standard- Preferred Alternative 

The preferred BWDS proposed is the same standard adopted by the International Maritime 

Organization (IMO) in 2004, “International Convention for the Control and Management of 

Ships’ Ballast Water and Sediments” (BWM Convention). The Coast Guard leads the U.S. 

government delegation to the IMO, the organization responsible for improving maritime 

safety and preventing pollution from vessels. The Coast Guard coordinated U.S. 

participation in this effort with the Environmental Protection Agency, the National Oceanic 

and Atmospheric Administration, the U.S. Department of Defense, the U.S. Maritime 

Administration, the U.S. Department of Justice, and the U.S. Department of State. 

This requirement is intended to meet the directives under NISA that requires the Coast Guard 

to ensure to the maximum extent practicable that nonindigenous species (NIS) are not 

introduced and spread into U.S. waters and that they apply to all vessels equipped with 

ballast tanks that operate in U.S. waters. 16 U.S.C. 4711(c)(1), (c)(2)A , (e) and (f). A full 

discussion of the legislative and regulatory history of the Coast Guard’s actions to implement 

both NANPCA and NISA may be found in the NPRM for this rule, published on August 28, 

2009. 74 FR 44632, 44633. 

C. Standards More Stringent than the IMO Standard 

The Coast Guard has decided to move forward with the phase-one (IMO) standard while 

assessing the practicability of implementing a phase-two standard, gathers additional data on 

technology available to meet the phase-two standard for various vessel types, and develops a 

subsequent rule with the economic and environmental analysis necessary to support the 

phase-two standard. The decision to remove this more stringent standard from this FR 

should not be interpreted as a sign that the Coast Guard is reconsidering its intent to increase 

the protectiveness of the BWDS. 

Due to unavailability of data, the cost, benefit, and environmental impact analyses included 

in the NPRM did not specifically assess impacts related to the phase-two standard (although 

the analyses did include an evaluation of standards that are more stringent than the phase-one 

standard). Many commenters addressed this issue, noting that the lack of analyses made it 

impossible for them to comment on the phase-two standard in any meaningful manner. 

To provide the public with as much information as possible on which to base comments, the 

Coast Guard will develop additional analyses regarding the potential costs, benefits, and 

environmental impacts of the proposed phase-two standard. When these analyses are 

105 
completed, the Coast Guard will make them available for public comment, either via a notice 

of availability or in conjunction with a subsequent rulemaking published in the Federal 

Register. 

The Coast Guard fully intends to issue a subsequent rule that will establish a more stringent 

phase-two discharge standard. To demonstrate our commitment, we are issuing this rule as 

an FR rather than as a final rule to show that the Coast Guard does not view publication of 

the phase-one standard as completing the agency’s work in controlling the introduction and 

spread of NIS from ships’ ballast water. In the FR, we are also reserving the regulatory 

provisions where the phase-two standard would be found. 

D. Sterilization 

This alternative essentially requires sterilization of ballast water. It would require the 

removal or inactivation of all membrane-bound organisms (including bacteria) and most 

viruses. Vessels meeting this standard would have approved BWMS onboard that discharge 

virtually no living organisms in U.S. waters. This alternative was considered as not viable at 

this time. Additional research is needed to obtain information on technology and potential 

environmental impacts. 

106 
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118 
Appendix A Ballast Water Tank Capacities and Fleet Makeup 

Table A-1a Ballast Water Capacities (m3) for U.S. Vessels 

U.S. Vessel Category MISLE/NBIC 2007 Ballast Water Volume Breakdown 

Sample 

Size 

Average 

Capacity <1,500 1,500 -5,000 >5,000 

Bulk Carriers

Handy 7 14,329 100.00% 

Panamax 7 36,258 100.00% 

Capesize 5 59,065 100.00% 

Tank ships

Handy 21 17,038 4.76% 95.24% 

Handymax - Aframax 2 9,379 50.00% 50.00% 

Suezmax 2 61,558 100.00% 

VLCC 1 214,863 100.00% 

ULCC N/A N/A 100.00% 

Container ships 

Feeder 5 6,927 60.00% 20.00% 20.00% 

Feedermax 1 4,195 100.00% 

Handy 2 17,891 100.00% 

Subpanamax 28 9,469 10.71% 10.71% 78.57% 

Panamax 16 11,729 6.25% 12.50% 81.25% 

Postpanamax 12 21,359 100.00% 

Other vessels

Passenger ships 7 6,416 42.86% 14.29% 42.86% 

Gas carriers 2 30,841 100.00% 

Chemical carriers 11 17,266 100.00% 

RORO 22 5,896 18.18% 22.73% 59.09% 

Combination vessels 28 15,764 100.00% 

General Cargo 29 5,571 37.83% 13.49% 48.68% 

Fishing Vessels 26 1,666 80.77% 11.54% 7.69% 

Other Offshore and 

Coastal Vessels 16 7,605 31.25% 12.50% 56.25% 

119 
Table A-1b Ballast Water Capacities (m3) for Foreign Vessels 

Foreign Vessel 

Category MISLE/NBIC 2007 Ballast Water Volume Breakdown 

Sample Size Average 

Capacity <1,500 1,500 -5,000 >5,000 

Bulk Carriers

Handy 549 13,753 2.37% 9.47% 88.16% 

Panamax 215 27,849 0.93% 99.07% 

Capesize 7 46,153 100.00% 

Tank ships 

Handy 43 14,952 11.63% 37.21% 51.16% 

Handymax - 

Aframax 398 28,411 0.50% 99.50% 

Suezmax 67 55,560 100.00% 

VLCC 95 98,983 100.00% 

ULCC 10 82,045 100.00% 

Container ships 

Feeder 21 4,928 28.57% 52.38% 19.05% 

Feedermax 24 5,093 4.17% 79.17% 16.67% 

Handy 61 5,543 13.11% 24.59% 62.30% 

Subpanamax 85 11,631 100.00% 

Panamax 76 12,691 100.00% 

Postpanamax 180 18,502 0.00% 100.00% 

Other vessels 

Passenger ships 78 3,176 15.38% 75.64% 8.97% 

Gas carriers 78 15,469 3.85% 30.77% 65.38% 

Chemical carriers 324 14,378 0.31% 9.88% 89.81% 

RORO 121 7,951 9.92% 15.70% 74.38% 

Combination 

vessels 14 5,128 57.14% 21.43% 21.43% 

General Cargo 190 7,226 29.47% 31.05% 39.47% 

Fishing Vessels N/A N/A 80.77% 11.54% 7.69% 

Other Offshore 

and Coastal 

Vessels 11 3,209 54.55% 36.36% 9.09% 

120 
World Fleet Growth and Makeup 

Based on information provided by HEC, a BWDS would be phased in under the proposed 

U.S. and international regulations. During this period, the population of vessels will 

potentially change— some vessels would be removed and others will be constructed. We 

obtained estimates of growth and removal rates for the various vessel types from a number of 

sources. Primary sources are the Transportation Research Board (TRB) and the Maritime 

Administration (MARAD). We also consulted private sector information sources: Clarkson 

Register, RS Platou for generalized fleet forecasts; PIERS, Mercator Transportation 

Management, Herbert Engineering Corp, and MDS Transmodal for container traffic 

forecasts; and the American Bureau of Shipping and ConocoPhillips for LNG forecasts. 

Appendix A contains additional details on Fleet Makeup. 

We extracted the number of affected vessels from the MISLE database to provide a baseline 

fleet size for year 2007. In projecting fleet growth, we assumed that there would be no 

optimization of the fleet for U.S. traffic. That is, we assumed that all vessels involved in 

international trade will be built to both U.S. and international BWDS requirements. 

In addition to growth in number of vessels, the size composition of the fleet is changing, 

especially in the LNG and container fleets. The relationship between ballast water capacity 

and vessel size (deadweight) is approximately linear (see Figures A-5, A-6 and A-7). 

Although the increased cargo may be carried on a fleet that is growing more slowly in 

numbers than in tonnage or TEU capacity, the assumption is made that the amount of ballast 

water discharged will grow with tonnage or TEU capacity. 

Table A.2 shows the assumed growth and removal rates forming the baseline case. We 

estimated the number of new builds each year by adding the number of vessels removed to 

the number of vessels needed to achieve the net growth rate. 

121 
Table A.2 World Fleet Growth and Removal Rates 

Type of Vessel Net Growth Rate Removal Rate 

Bulk carriers

Handy -0.5% 2.0% 

Panamax -0.5% 2.0% 

Capesize -0.5% 2.0% 

Tank ships

Handy 2.0% 1.0% 

Handymax-Aframax 2.0% 1.0% 

Suezmax 2.0% 1.0% 

VLCC 2.0% 1.0% 

ULCC 2.0% 1.0% 

Container ships

Feeder 4.4% 2.0% 

Feedermax 4.4% 2.0% 

Handy 4.4% 2.0% 

Subpanamax 4.4% 2.0% 

Panamax 4.4% 2.0% 

Postpanamax 4.4% 2.0% 

Other vessels

Passenger ship 2.8% 2.2% 

Gas carrier 6.0% 2.0% 

Chemical carrier 2.8% 2.2% 

RORO 2.8% 2.2% 

Combination vessel 0.0% 2.0% 

General cargo 2.8% 2.2% 

Fishing Vessels 2.8% 2.2% 

Other Offshore and Coastal 

Vessels 3.6% 3.7% 

Data Source for Fleet Growth Calculations

U.S. Fleet Growth Rates

We estimated the U.S. fleet growth rates using different data sources: U.S Department of 

Transportation (MARAD), Clarkson Research Service and U.S.C.G. MISLE System 

database. 

122 
Table A.3 Number of Active U. S. Vessels and Percentage Change (2002-2007) 

Type of Vessel Year Increase 

% 

Average 

Change 

% 

2002 2003 2004 2005 2006 2007 

Bulk Carriers48 65 64 64 61 60 61 -6.15 -1.24 

Tanks49 7,229 7,381 7,419 7,661 7,901 8,209 13.56 2.58 

Containers50 41,391 43,806 42,766 43,300 44,186 45,596 10.16 1.99 

Passenger Ships 19,413 20,402 20,889 21,431 22,027 22,898 17.95 3.36 

RoRo51 57 63 63 73 69 66 12.12 2.59 

Combination Vessels52 9,901 10,423 10,392 10,633 10,913 11,275 13.88 2.65 

Fishing Vessels53 61,989 66,059 66,300 67,930 72,154 73,661 18.83 3.54 

Offshore Supply Vessel 1,465 1,530 1,522 1,583 1,624 1,849 26.21 4.87 

World Fleet Growth and Removal Rates

We estimated the world growth and removal rates using the following data sources: 

Transportation Research Board 

The Transportation Research Board has published forecasts for U.S. International Marine 

Trade54, as summarized in the following tables. 

Table A.4 TRB Summary of Major Forecasts of Waterborne Cargo 

Sector Units 

Traffic Compound 

Annual Growth 

Rate (%) 

Percent 

Change Source 

2000 2020 

International Million tons 1,143.4 1,674.5 1.9 46 Global Insight 

Container TEUs 

(thousands_ 

120,350 48,401 4.4 138 Global Insight 

Petroleum Million tons 669.7 1,056.3 2.3 58 EIA 

Dry bulk Million tons 355.9 444.0 1.1 25 Global Insight 

Total inland 

river 

Million tons 66137 836.0 1.3 26 USACE 

MARAD Statistics 

Vessel statistics compiled by MARAD are shown below 

 

48 Based on Clarkson Research Service (Source: U.S. Department of Transportation, Maritime Administration, 

Water Transportation Statistical Snapshot, May 2008) 49 Based on MISLE database, includes tank barges and tank ships. 

50 Based on MISLE database, includes freight barges and freight ships. 

51 Based original data from Clarkson Research Service available at U.S. Department of Transportation, 

Maritime Administration, Water Transportation Statistical Snapshot (May 2008) 

52 Based on MISLE database, includes mobile offshore drilling units, oil recovery vessels and towing vessels. 53 Based on MISLE database, includes commercial fishing vessels and fish processing vessels. 

54 The marine transportation system and the federal role: measuring performance, targeting improvement / Committee for a 

Study of the Federal Role in the Marine Transportation System. Transportation Research Board Special Report, 279

123 
Table A.5 U.S. Waterborne Imports, Arrivals by Type 

Vessel Calls Year 

Increase % Growth Rate 

%/year Vessel Type 1999 2000 2001 2002 2003 2004 

Tanker 17,279 18,535 18,387 17,320 18,503 19,316 12% 2.3% 

• Product 10,875 11,868 11,780 10,949 10,998 11,572 6% 1.3% 

• Crude 6,404 6,667 6,607 6,317 7,505 7,744 21% 3.9% 

Container 16,625 17,410 17,076 17,138 17,287 18,279 10% 1.9% 

Dry Bulk 11,946 12,013 11,628 11,112 10,271 11,631 -3% 0.5% 

RORO 5,.73 5,542 5,712 5,632 5,191 5,317 5% 0.9% 

Vehicle 3,072 3,646 3,646 3,605 3,113 3,065 0% 0.0% 

Gas Carrier 683 708 739 739 926 916 34% 6.0% 

Combination 767 856 770 761 666 459 -40% 9.8% 

General 

Cargo 

4,354 4,318 4,076 3,894 3m915 3m967 -9% -1.8% 

All Types 56,727 59,382 58,388 56,596 56,759 59,885 6% 1.1% 

Table A.6 U.S. Waterborne Trade 

Year (1000 Metric Tons) 

Increase Growth 

Rate 

Direction 2000 2001 2002 2003 2004 

Imports 809,928 829,959 813,571 881,414 957,210 18% 4.3% 

Exports 347,906 331,423 323,640 324,760 349,628 0% 0.1% 

Source: U.S. Maritime Administration, Waterborne Databank 

Figure A-1 Imports (Metric Tons) on Containerships, 1998-2003 

Containership Imports (Metric Tons)

y = 6E-34e0.0476x

R2 = 0.9603

0.00E+00

2.00E+07

4.00E+07

6.00E+07

8.00E+07

1.00E+08

1.20E+08

1.40E+08

1.60E+08

1.80E+08

1997 1998 1999 2000 2001 2002 2003 2004

Year

Imports (MT)

Source: Port Import/Export Reporting Services 

124 
Figure A-2 Imports (TEUs) on Containerships, 1998-2003 

Containership Imports (TEUs)

y = 1E-45e0.0601x

R2 = 0.9775

0.0E+00

5.0E+06

1.0E+07

1.5E+07

2.0E+07

2.5E+07

1997 1998 1999 2000 2001 2002 2003 2004

Year

Imports (TEUs)

Source: Port Import/Export Reporting Services 

The Platou Report 

R.S. Platou Economic Research provides and presents analyses of all major shipping 

markets, as well as markets representing the external conditions for worldwide shipping. 

Table A.7 World Fleet Development (The Platou Report) (Mil DWT) 

Year Tankers Bulk Carriers Comb. Carriers Others Total 

1995 270.9 22.9 25.9 134.8 661.5 

1996 270.5 241.3 20.7 140.9 673.4 

1997 275.2 250.0 17.3 149.1 691.5 

1998 279.5 260.7 16.9 155.3 712.4 

1999 285.2 260.4 16.1 160.9 722.6 

2000 289.5 264.8 15.2 166.7 736.2 

2001 296.4 274.0 14.6 169.3 754.3 

2002 290.0 287.4 13.8 174.7 765.9 

2003 294.2 295.0 12.6 181.2 783.0 

2004 305.2 303.3 12.2 189.6 810.3 

2005 322.1 320.8 11.7 200.5 855.0 

Increase % 19% 40% -55% 49% 29% 

Growth Rate 

%/year 

1.7% 3.4% -7.6% 4.1% 2.6% 

Source: The Platou Report (www.platou.com) 

125 
Table A.8 World Fleet Development with Derived Removal Rates (The Platou Report) (Mil DWT) 

Year Tankers Removed R Rate Bulk 

Carriers Removed R Rate Other Removed R Rate 

1995 270.9 10.9 229.9 2.6 160.7 2.2 

1996 270.5 6.8 0.025 241.3 8.5 0.037 161.6 2.6 0.016 

1997 275.2 3.7 0.014 250.0 7.9 0.033 166.3 4.8 0.030 

1998 279.5 7 0.025 260.7 11.8 0.047 172.2 4.3 0.026 

1999 285.2 16.4 0.059 260.4 .1 0.035 177.0 4.8 0.028 

2000 289.5 14.1 0.049 264.8 4.4 0.017 181.9 3.6 0.020 

2001 296.4 19.7 0.068 274.0 7.2 0.027 183.9 4.8 0.026 

2002 290.0 19.3 0.065 287.4 6 0.022 188.5 5.1 0.028 

2003 294.2 18.9 0.065 295.0 3.5 0.012 193.8 3.5 0.019 

2004 305.2 10.3 0.035 303.3 0.8 0.003 201.8 1.5 0.008 

2005 322.1 320.8 212.1 

Increase 

% 

19% 0.045 40% 0.026 32% 0.022 

Growth 

Rate 

%/year 

1.7% 3.4% 2.8% 

LNG Fleet Growth Projections 

Bloomberg Report: LNG Fleet Needs to Expand 66 percent 

The global fleet of tankers carrying liquefied natural gas needs to expand by 66 percent by 

2010 to meet current and future demand from exporters including Qatar, Australia and 

Nigeria, according to LNG Shipping Solutions, as reported by Bloomberg. 

About 205 carriers need to be ordered, adding to the 182 vessels in service and 127 units 

already contracted to be built, to meet demand for existing and future LNG projects. In 

addition, as many as 105 vessels need to be ordered to meet demand for future projects and 

100 vessels for current contracts. 

Source: http://www.marinelink.com/MembersNew/ViewStoryNR.asp?StoryID=200525

accessed Oct 13, 2005. 

ABS 

Numerous LNG vessels are under order in anticipation of rising demand for LNG shipments. 

We estimated an additional 220 vessels. 

126 
Figure A-3 LNG Fleet Growth (from ABS GASTECH paper) Based Upon 138K m3

 Capacity 

LNG Carriers

0

50

100

150

200

250

300

350

400

450

2004 2006 2008 2010 2012 2014 2016

No. of 135 K ships

ABS GASTECH paper Average 7.2% per year

Conoco Phillips Marine, USA 

Figure A-4 below shows the trend of LNG shipping (Noble, P. 2004). 

Figure A-4 LNG Growth Projected 

0

50

100

150

200

250

300

1964 1974 1984 1994 2004 2014

LNG Trade (billion cubic meters)

LNG Trade 6.5% Trend Line

127 
Ballast Water Capacity as a Vessel Cargo Capacity for Various Vessel Types 

A key assumption in the assumed growth rates is that modeling growth in cargo carrying 

capacity (DWT, TEU or volume) correlates to growth in ballast water capacity and thus, 

discharge potential. The following figures demonstrate that this assumption is well-founded. 

FigureA-5 Bulk Carrier BW Capacity vs. Deadweight 

Bulk Carrier BW Capacity vs DWT

y = 0.4776x - 1997.4

R2

 = 0.7656

0

10000

20000

30000

40000

50000

60000

70000

80000

90000

0 50000 100000 150000 200000

DWT (M T)

BW Capacity (m3)

128 
Figure A-6 Containership BW Capacity vs. TEU 

Containership BW Capacity vs TEU

y = 3.6774x + 887.54

R2

 = 0.9034

0

5000

10000

15000

20000

25000

30000

35000

40000

45000

0 2000 4000 6000 8000 10000 12000

TEU

BW Capacity (m3)

Figure A-7 Tanker BW Capacity vs. Cargo Capacity (from HEC data) 

Tanker BW Capacity vs. Cargo Capacity

-

20,000

40,000

60,000

80,000

100,000

120,000

0 100,000 200,000 300,000 400,000

Cargo Volume (m3)

SWB Tanks (m3)

 

129 
Number of Vessels Undergoing BWMS Installation over the Phase-in 

Period 

Table A-8 presents the break-down between number of existing and new vessels undergoing 

installation over the phase-in period (complete information on vessels undergoing BWMS 

installation over the period of the analysis is presented on chapter 4, table 4.2) 

Table A-8 Vessel undergoing installation during the phase-in period 

Vessel Type 

Year 1 Year 2 Year 3 Year 4 Year 5 

Existing New Existing New Existing New Existing New Existing New 

Bulk Ships 

Handy Bulk 0 0 0 0 3.7 0 3.7 0 1.8 0 

Panamax Bulk 0 0 0 0 2.0 0 2.0 0 1.0 0 

Capesize 0 0 0 0 0.0 0 0.0 0 0.0 0 

Tanker Ships 

Handy 0 0 0 0 4.4 0 4.4 0 2.2 0 

HandymaxAframax 0 1 0 1 7.5 1 7.5 1 3.8 1 

Suezmax 0 0 0 0 3.1 0 3.1 0 1.5 0 

VLCC 0 0 0 0 1.8 0 1.8 0 0.9 0 

Container Ship 

Feeder 2 1 2 1 8.3 1 7.4 1 3.7 1 

Feedermax 0 0 0 0 0.4 0 0.4 0 0.2 0 

Handy 0 1 0 1 10.5 1 10.5 1 5.2 1 

Subpanamax 2 2 2 2 19.9 2 18.7 2 9.4 3 

Panamax 1 1 1 1 7.9 1 7.4 1 3.7 1 

Postpanamax 0 1 0 1 12.1 1 12.1 1 6.1 1 

Other Vessels 

Passenger 

ships 8 9 8 10 55.1 10 50.9 10 25.5 11 

Gas carriers 0 0 0 0 2.4 0 2.4 0 1.2 0 

Chemical 

carriers 0 1 0 1 9.5 1 9.5 1 4.7 1 

RORO 6 4 6 4 24.1 4 21.0 4 10.5 4 

Combination 

vessels 0 7 0 7 54.8 8 54.8 8 27.4 8 

General Cargo 3 2 3 2 17.5 2 16.2 2 8.1 2 

Fishing 4 6 4 6 34.0 6 31.9 7 16.0 7 

Other Offshore 

and Coastal 

Vessels

40 86 40 90 300.6 95 280.6 100 140.3 104 

Total 67 125 67 130 580 135 546 141 273 147 

Note: Totals may not add due to rounding. 

130 
Appendix B Ballast Water Exchange (BWE) Cost55

This appendix presents the calculation of the ballast water exchange (BWE) cost, baseline 

cost, based on the 2007 vessel information provided by the National Ballast Information 

Clearinghouse (NBIC) database. The baseline cost is equivalent to the Alternative 1 (No 

Action) described in this RA. We then compared to the BWE costs the proposed BWDS, 

alternative 2 (see Chapter 6 for discussion). 

The direct costs of the current ballast water management practices (BWE) onboard vessels 

include the cost incurred by pumping additional ballast water and the cost of additional crew 

labor required to carry out the mid-ocean exchanges. Herbert Engineering Corp (HEC) 

estimated the pumping costs based on the cost of generating the electricity to run the ballast 

pump and the additional maintenance costs for the ballast pump and piping resulting from 

pumping more ballast. HEC assumed that no new equipment is required to comply with the 

rule. In determining the amount of ballast water involved in the exchange, three volumes of 

ballast tank capacity represents a complete flow-through (FT) exchange, while two volumes 

of the ballast tank capacity represents an empty/refill (ER) exchange. 

To determine pumping costs, HEC estimated the cost for pumping one cubic meter of ballast 

water. HEC used fluid mechanic equations to calculate the kilowatts (kW) of power required 

to pump one cubic meter of water against a typical ballast system pressure head of 25 m. 

Taking into account the efficiencies of the pumps, motors, and generators, HEC calculated 

that it takes 0.11 kW of generated power to pump one cubic meter per hour (m3

/h) of ballast 

is pumped. Because most vessels have diesel generators, HEC based the cost estimate on 

generating power in this manner. Considering the fuel rates of typical diesel generators and a 

fuel cost of $620 per ton for marine diesel oil (MDO), and $300 per ton for heavy fuel oil 

(HFO), plus lube oil costs, the calculated cost per m3/h based on MDO fuel is $0.13 and 

based on HFO fuel is $0.07. As a rough order estimate, HEC assumed that half the vessels 

use MDO for generators and half use HFO; consequently, HEC estimated the average cost 

for powering the pumps to be $0.10 per m3/hr pumped. 

Another component in the calculation of cost of BWE is the additional maintenance cost 

incurred by the use of the ballast pumps and piping systems to carry out BWE. A reasonable 

estimate based on industry experience is that the average annual maintenance costs are 

approximately 10 percent of the ballast pump’s capital cost.56 In order to adequately account 

for the extra maintenance burden, a uniform annual maintenance cost of 10 percent of the 

capital cost of one ballast pump is added for each vessel conducting exchanges. HEC divided 

this cost by the estimated annual quantity of ballast pumped per year. HEC estimated the 

annual quantity of ballast pumped without BWE with the assumption that the pumps operate 

 

55 Methodology and sources provided by Herbert Engineering Corporation, information updated to 2007. 

56 This number was also used in the BWM RA (USCG 2004). Here it is refined to account only for those costs 

that truly depend upon the increased ballast pumped required by BWE. 

131 
at rated capacity for 100 to 125 hours per year,57 increased by a factor of 2.5 on average by 

BWE (average factor of 2 for empty/refill and 3 for flow-through). HEC also assumed this 

maintenance cost covers replacement parts for pumps such as impellers, as well as 

maintenance of piping system components, such as pipes and valves. Approximately half of 

this maintenance cost is considered to be affected by increased flow through the system and 

half based on time of exposure to salt water by the system, which is unaffected by BWE. The 

maintenance cost affected by flow through the system is increased by 250 percent to account 

for BWE, and the total is divided by the estimated annual flow in the system to obtain the 

additional maintenance cost per cubic meter of ballast pumped for BWE. See Table B-1 for 

details on the maintenance cost calculations. 

Table B-1 Additional Maintenance Costs per m3 of Ballast Pumped for BWE 

System Size 

(m3/hr) 

Annual Maint 

Cost (no 

BWE) 

Variable Maint 

Cost (1/2 

affected by 

flow) 

Ballast 

Pumped/YrNo BWE 

Additional 

Ballast by 

BWE 

(250%) 

BWE 

Additional 

Maint./ Yr 

BWE Add 

Maint / m3

pumped 

250 $1,500 $750 25,000 62,500 $1,875 $0.030

750 $2,500 $1,250 75,000 187,500 $3,125 $0.017

2000 $5,000 $2,500 200,000 500,000 $6,250 $0.013

5000 $10,000 $5,000 500,000 1,250,000 $12,500 $0.010

Because carrying out BWE doubles or triples the amount of time needed to empty and refill 

or flow-through ballast tanks and could require many hours of operation at sea, it is 

reasonable to add additional crew labor costs to this number.58 This factor recognizes that the 

crew could be doing other work during this time. The charges would be primarily for officers 

to oversee the ballasting and possibly for unlicensed crew if the vessel has manually-operated 

valves. The labor charges vary from very low cost59 to over $5060 per hour for U.S. or 

European officers.61 Table B-2 shows an estimated average labor cost for BWE and includes 

the cost for BWE labor per m3 of water. HEC assumed that no additional personnel would be 

added to the vessel to conduct BWE. For smaller vessels, it is assumed that less time is 

required for ballasting and less supervision is required compared to a large tanker or bulk 

carrier, where ballasting is a major operation. 

 

57 This estimate is based upon a review of typical numbers of voyages and amounts discharged across all vessel 

types. 

58 Based upon recent industry experience, it is assumed that vessels can maintain course and speed while 

performing BWE. 

59 Costs are loaded. 

60 U.S. wage rate source comes from BLS data for year 2007 using NAIC 483100 and SOC Code # 53-5021. 

This is the mean wage rate, times the load rate of 40%, gave us approximately $50 as a loaded wage rate for 

U.S. 

61 For small incremental increases in labor use on a ship, it is appropriate in assessing real costs to use direct 

labor charges. 

132 
Table B-2 Additional Crew Costs per m3

 of Ballast Water Pumped for BWE 

System Size 

(m3/hr) Voyage /Year 

Add Labor 

Cost/Voyage 

BWE 

Add Labor Cost/Yr 

BWE 

Additional 

Ballast by 

BWE (250%) 

BWE Labor 

Cost/m3

250 15 $90 $1,350 62,500 $0.022

750 15 $120 $1,800 187,500 $0.010

2000 10 $150 $1,500 500,000 $0.003

5000 6 $180 $1,080 1,250,000 $0.001

Table B.3 summarizes the components of the cost for BWE described above and provides a 

total cost per cubic meter pumped for BWE. 

 Table B-3 Total Cost per m3 for Ballast Pumped for BWE 

System Size 

(m3/hr) Elect Power Cost Maintenance Cost Labor Cost Total Cost 

250 $0.010 $0.030 $0.022 $0.062

750 $0.010 $0.017 $0.010 $0.037

2000 $0.010 $0.013 $0.003 $0.026

5000 $0.010 $0.010 $0.001 $0.021

Note: All costs are per m3 of ballast pumped

Based on the above estimated cost per cubic meter of ballast pumped, HEC estimated the 

annual cost of BWE. While this estimate carries uncertainty, it provides a reasonable 

estimate of the magnitude of costs industry can expect to incur because of BWE. 

Ballast Water Exchange Practices 

The costs of BWE influence shipping operations. The NBIC data indicate how much ballast 

is managed through exchange; whether ER, FT, or alternative methods are used. Alternative 

methods as reported in the NBIC data can include treatment, mid-ocean filling, or 

undetermined methods. However, they represent only a small portion (<0.5 percent) of 

managed ballast water. 

Vessels that carry goods into the U.S. typically discharge little ballast. Imports and foreign 

goods dominate U.S. maritime trade. In particular, large VLCC and ULCC tankers, which 

have the largest ballast capacities, discharge virtually no ballast in U.S. waters; this is not 

surprising, since the U.S. imports primarily crude oil. 

Containerships vary significantly in the likelihood that they will discharge ballast, with the 

smallest size being the most likely to discharge. Nationally, large containerships discharge at 

a rate of about two-thirds of their port arrivals. HEC expects this rate to decrease over time. 

Generally, we expect all operators to minimize the costs of BWE. Ballast discharge data for 

regions such as the Great Lakes and California, where mandatory BWM programs have been 

in effect for a number of years, demonstrate this trend. 

133 
In an assessment of the role of no ballast onboard (NOBOB) vessels in the introduction of 

NIS into the Great Lakes (Johengen, et al. 2005), it was concluded that over 90 percent of the 

vessels entering the Great Lakes have NOBOB.62 HEC also used data from California, 

where BWM has been mandatory since 2000, to corroborate the behavior observed in the 

NBIC data. This data shows that implementation of the mandatory BWM program for 

vessels63 arriving at California ports (CSLC 2005) reduces the amount of ballast water 

discharged. Additionally, note that for containerships the no-discharge ratio has increased 

from about two-thirds to over 80 percent. Panamax and Post-Panamax vessels dominate 

containership traffic in California. 

HEC’s experience in developing BWE exchange plans for industry and their personal 

communications with vessel operators supported these behavior patterns. 

These data support the findings of this RA that the actual amount of ballast discharged, and 

thus requiring management, is significantly lower than the assumptions used in the upper 

bound evaluation made in the previous BWM RA (USCG 2004). 

The NBIC data also provide information on how the ballast water is managed. Table B-4 

presents the ratio of ballast water managed using ER and FT, as well as using alternative 

methods (discussed above). ER is the dominant process for most vessel types. Bulk carriers 

and passenger ships extensively use FT. 

 

62 The cited reference confirmed earlier analyses that NOBOBs dominate Great Lakes saltwater vessel entries 

despite significant discrepancies in the details reported by Colautti et al (2003) and the U.S. USCG. In most 

cases the disagreement involved a Colautti et al. designation of NOBOB vs. a USCG designation of ballast on 

board . St. Lawrence Seaway data for the 2000 season indicate that 89 percent of the vessels entered as 

NOBOBs. The cited reference included further analysis of the Seaway data that revealed that only ~7 percent of 

the vessels entering that year would have legally been subject to the deep-water ballast exchange and salinity 

verification requirements in effect at that time, the remainder having entered the system as NOBOBs, but 

ballasted at freshwater ports between Quebec City and Montreal, and were thus counted as in a ballasted 

condition by the Seaway. Such vessels would have been counted as being in a ballasted condition, but 

compliant with entry regulations, by the U.S. USCG. These numbers lead the authors to conclude that the best 

estimate is that over 90 percent of the vessels entering the Great Lakes do so as NOBOBs. 63 Vessel types are as categorized by California. 

134 
Annual Ballast Water Exchange Costs 

The BWE exchange costs were calculated based on the percentage ballast water managed 

through ER or FT64 and by the current discharged amount of non-coastwise vessels operating 

in the U.S. waters in 2007. In order to calculate the amount of managed ballast water, HEC 

assumed that all ballast water will be exchanged on every voyage to a U.S. port from outside 

the U.S. EEZ. Most operators will likely exchange only the tanks they need before entering 

port depending on the cargo operations they intend to perform once in the United States. 

They also assigned a uniform annual maintenance cost to every vessel that made at least one 

transit outside the EEZ; for many vessels that only make one port call in the United States 

from outside the EEZ, this would overstate the annual cost to this vessel. HEC believed, 

however, that even though they could be overestimating the annual cost of the final rule, their 

costs certainly represents the magnitude of the expenditure they would expect to see. HEC 

estimated a total annual cost for BWE to be $5 million for year 2007. 

Table B-4 BWE Costs for 2007 

Vessel Type %ER %FT 2007 

Cost/m3 Total Discharge BWE Costs 

Bulk Carriers

Handy 0.35 0.37 $0.036 19,205,314 $17,657 

Panamax 0.23 0.65 $0.028 13,643,470 $13,019 

Capesize 0.50 0.26 $0.025 13,058,853 $8,135 

Tank ships

Handy 0.12 0.17 $0.037 700,461 $20,035 

Handymax - Aframax 0.21 0.17 $0.022 165,111,289 $3,367,364 

Suezmax 0.07 0.00 $0.025 101,459,503 $344,409 

VLCC 0.45 0.00 $0.022 1,939,980 $37,906 

ULCC 1.00 0.00 $0.021 9,900 $418 

Container ships

Feeder 0.03 0.09 $0.067 20,068 $45 

Feedermax 1.00 0.00 $0.059 20,068 $239 

Handy 0.45 0.10 $0.056 1,275,040 $8,635 

Subpanamax 0.72 0.05 $0.050 1,216,466 $9,800 

Panamax 0.70 0.02 $0.050 654,601 $4,817 

Postpanamax 0.74 0.00 $0.037 4,468,678 $25,197 

Other vessels

Passenger ships 0.06 0.00 $0.064 809,286 $6,289 

Gas carriers 0.23 0.05 $0.022 189,918 $2,552 

Chemical carriers 0.37 0.18 $0.045 7,946,202 $455,901 

RORO 0.39 0.02 $0.056 365,683 $17,475 

Combination vessels 0.99 0.00 $0.056 15,673,816 $657,801 

General Cargo 0.47 0.23 $0.056 257,428 $6,310.96 

Total 348,026,022 $5,004,003 

 

64 Percentages provided by Herbert Engineering Corporation 

135 
Appendix C Cost of Ballast Water Management Systems in 

Terms of Vessel Value and Daily Charter Rates 

Shipowners face three cost elements: capital, operating, and voyage. Capital costs are fixed 

costs, whereas operating and voyage costs are variable. Because the fixed costs are always 

present, shipowners will offer their vessels for charter if at least the variable costs are 

covered. These costs represent the lower bound of charter rates. Installation of BWMS for 

new buildings represents part of the capital cost. We can compare the cost impact to the 

vessel value at various ages and their amortized cost to the increase in the charter rate 

necessary to recover this investment. Operational costs associated with BWMS would form 

part of the lower bound charter rate. However, as shown below for bulk carriers, these 

operational costs are small in comparison to charter rates. 

Long-term (i.e., 12-month) charter rates reflect supply and demand. Table C-1 shows a 

twenty-year average (1980-2000) of the daily time charter rates for several vessel types. 

However, current rates are significantly higher for most vessel types. 

Table C-1 Average Daily Time Charter Rates, 1980-2000 (Kite-Powell 2001) 

Vessel Type $/day 

Bulk Carriers

Handy 8,000 

Panamax 9,500 

Capesize 14,000 

Tank Ships

Product 12,000 

Aframax 13,000 

Suezmax 16,500 

VLCC 22,500 

Containerships

400 TEU (Feeder) 5,000 

100 TEU (Feedermax) 9,000 

1500 TEU (Handy) 13,500 

2000 TEU (Subpanamax) 18,000 

 Source: Hebert Engineering Corp., and AMSEC, LLC 

Bulk carriers represent 14 percent of the overall installation costs for BWD-2. Estimated 

installation costs in 2021 for Handy size bulk carriers range from $419,000 to $842,000 per 

vessel (see Table 3.4). Estimated values of bulk carriers at the top of the Handy size range 

(~50,000 DWT) vary, depending on trade demands. At the end of 2005, the estimated value 

of this size bulk carrier ranged from $29 million for a new vessel to $10 million for a 20- 

year-old vessel (Compass 2006). 

136 
The Baltic Exchange, formerly known as the Baltic Freight Index (BFI), tracks bulk carrier 

potential revenues through the Baltic Dry Index (BDI). From 1996 to 2003, this index varied 

in the range from approximately 1000 to approximately 1500 (Findata 2006). In the next two 

years, this index soared to over 5500 on two occasions, with a minimum below 2000, 

exhibiting a recent trend toward increasing volatility (Findata 2006). At the end of 2005, the 

BDI was about 2400. Recent projections based upon increased demand by China and other 

Asian countries suggest that the BDI, and thus charter rates, will tend to increase over the 

long term (Fearnley 2006). 

The assumption that current rates represent an estimate of future returns allows for the 

approximation of an upper bound of the amortized cost of BWMS relative to potential 

revenues. 

At the end of 2005, the average 12-month time charter rate for the top of the Handy size 

range was $17,000 per day (Compass 2006). According to HEC, amortizing the BWMS 

installation costs of $419,000 to $842,000 over an assumed 15-year service life, the 

additional cost of BWM is approximately 0.4 to 0.8 percent of the daily charter rate. Even if 

the charter rates were to temporarily return to the 20-year average of $8,000 per day, the 

amortized cost would rise to only about 1.7 percent of the daily charter rate. HEC has 

estimated operating costs in 2006 to be less than 0.05 percent of the daily charter rate. 

For a Capesize bulk carrier, the 10-year-old vessel estimated value is $38 million and the 

current average 12-month time charter is $34,500 per day (Compass 2006). Upper bound 

installation costs are about 3.8 percent of the value of a 10-year-old vessel. Amortizing the 

cost over 15 years indicates a daily cost of approximately 0.8 percent of the daily charter rate. 

Tanker long-term charter rates also reflect supply and demand. Over the past four years, 

charter rates for Aframax tankers have steadily increased from $17,000 per day at the end of 

2002 to $37,500 per day at the end of 2005 (Compass 2006). Demand for oil continues to 

increase as population and energy use per capita increase, thus requiring an increase in oil 

shipment. Tanker orders declined in 2005 compared with the previous two years (Marsoft 

2006). The existing fleet of single hull tankers has largely been replaced and new 

construction is tapering off. 

Assuming that the average 12-month time charter is $35,000 per day for an Aframax tanker, 

amortizing the installation cost over 15 years indicates a cost of approximately 0.6 percent of 

the daily charter rate. Assuming a 20-year average of $13,000 per day, the cost of the 

BWMS, installation increases to about 1.6 percent of the daily charter rate. Other vessel 

types exhibit comparable trends. 

Industry experts were consulted by HEC to assess other factors affecting costs and 

economies of scale are possible for BWMS. The consensus was that prices provided by 

manufacturers represent current costs with current technologies and construction facilities. 

Offshore manufacturing (e.g., in China, Korea) and larger manufacturing facilities will drive 

down future costs. 

137 
Charter rates and the overall cost of shipping goods are market driven. The operating costs 

represent the lower bound of charter rates. Ship owners will pull vessels off the market when 

rates fall much below this level. Therefore, in the short term, modest capital costs, such as the 

installation of BWMS, will have little or no effect on charter rates. Over the longer run, the 

cost of shipping goods will reflect the costs of BWMS because ship owners must ultimately 

recapture their investment in order to remain commercially viable. We also found additional 

information suggesting similar findings in terms of the magnitude of global trade and the low 

impact of costs being passed on to consumers. 65

 

65 King, Dennis. 2011. MEPC 62 special: The world can afford sustainable shipping. Sustainable Shipping, 

July 8 2011 (http://www.maritime-enviro.org/news/King_Sustainable_Shipping_070811.pdf). King suggests 

that if the cost of ballast water regulations was passed along to global businesses and consumers, the price 

increase of imported goods will be minimal and statistically indistinguishable from no change. 

138 
Appendix D Ballast Water Management System Costs for the 

Foreign Vessels 

This appendix presents the information on the ballast water management costs for the foreign 

vessels that operate in U.S. waters. The data sources for the information below are described 

on chapters 2 and 3 of the main document. 

Installation Costs of Ballast Water Management Systems 

In order to calculate the installation costs for the foreign vessel, HEC assumed that these 

vessels will have a wide range of options of BWMS vendors and therefore, the installation 

costs will be potentially lower than the costs incurred by the U.S. vessels. Tables D-1 

provides the average ballast pumping capacities for each category of vessel and the costs for 

the systems of the indicated capacities for the foreign fleet. Installed costs vary, depending on 

the technology utilized and the cost of the equipment to implement that process. However, 

variations in cost are also related to a process’s development stage 

139 
Table D-1 Estimated Average Installed Cost ($000) for the Foreign Fleet by Vessel Category and BWMS 

Vessel Category 

Est. Ballast 

Pumping 

Capacity 

(m3/hr) 

Chlorine 

Generate 

Chemical 

Apply 

Filter & 

Radiate Deoxygenate Ozone Generate 

Bulk carriers 

Handy 1,300 544 333 634 453 593 

Panamax 1,800 572 363 788 501 723 

Capesize 3,000 400 425 567 567 967 

Tank ships 

Handy 1,100 474 321 573 434 541 

Handymax/ 

Aframax 2,500 500 400 708 544 871 

Suezmax 3,125 375 431 531 573 991 

VLCC 5,000 NA 525 NA 662 1,350 

ULCC 5,500 NA 525 NA 662 1350 

Containerships

Feeder 250 300 250 225 165 252 

Feedermax 400 338 265 297 236 311 

Handy 400 338 265 297 236 311 

Subpanamax 500 363 275 345 283 351 

Panamax 500 363 275 345 283 351 

Postpanamax 750 425 300 465 400 450 

Other vessels

Passenger ship 250 300 250 225 165 252 

Gas carrier 4,800 NA 515 NA 653 1,312 

Chemical carrier 600 388 285 393 330 391 

RORO 400 338 265 297 236 311 

Combination 

vessel 400 338 265 297 236 311 

General cargo 400 338 265 297 236 311 

Fishing 

Vessels66 250 300 250 225 165 252 

Other Offshore 

and Coastal 

Vessels67 325 340 258 325 200 282 

Source: Herbert Engineering Corporation. Note: The costs are for the processes considered the most costeffective for the category of vessel, considering both installed cost and operating cost. 

Table D-2 presents the installation costs for the foreign vessels by vessel type. The 

installation costs were calculated based on the average costs for each available ballast water 

 

66 Information obtained through consultation with the U.S. Coast Guard Commercial Fishing Vessels Division. 67 Information obtained through consultation with the U.S. Coast Guard Offshore Vessels Division. 

140 
management system presented on Table D-1. The low costs presented on the table below are 

related to the cheapest management system available and the high costs are related to the 

most expensive management system available. 

Table D-2 Installed Ballast Water Management System Costs ($000) for the Foreign Vessels 

Vessel Type Installed Costs in 2007 

Low High 

Bulk carriers 

Handy 333 634 

Panamax 363 788 

Capesize 400 967 

Tank ships

Handy 321 573 

Handyman-Aframax 400 871 

Suezmax 375 991 

VLCC 525 1,350 

ULCC 525 1,350 

Container ships

Feeder 165 300 

Feedermax 236 338 

Handy 236 338 

Subpanamax 275 363 

Panamax 275 363 

Postpanamax 300 465 

Other vessels

Passenger ships 165 300 

Gas carriers 515 1,312 

Chemical carriers 285 393 

RORO 236 338 

Combination vessels 236 338 

General Cargo 236 338 

Fishing Vessels 165 300 

Other Offshore and Coastal 

Vessels 

200 340 

 Source: Herbert Engineering Corporation 

The primary cost estimate for the foreign fleet assumes that these vessels will be subjected to 

the same phase-in schedule as the U.S. fleet (Table 1.2). For the existing vessels that will 

comply with this rulemaking after January 2014, we have assumed that 40 percent will install 

BWMS each year, in the first two years and 20 percent in the last year of the compliance 

requirement. In 2016, the remainder of the fleet built before December 1, 2013 will be 

required to meet the BWDS. In this case, we have assumed that 40 percent of the population 

will install the system in the first two years and 20 percent in the last year of the compliance 

requirement. Given these assumptions and the projected fleet growth as defined in Chapter 2 

(Table 2.3), the number of foreign vessels undergoing BWMS installations is as shown in 

Table D-3. 

141 
142 

Table D-3 Number of Foreign Vessels Undergoing BWMS Installation by Year and Type 

Vessel type Year Total 

1 2 3 4 5 6 7 8 9 10 

Bulk carriers

Handy 40.7 40.6 342.3 325.5 166.2 7.0 6.9 6.8 6.7 6.6 949.3 

Panamax 5.2 5.1 173.2 172.4 87.9 3.4 3.3 3.3 3.2 3.2 460.2 

Capesize 0.3 0.3 15.7 15.7 8.0 0.3 0.3 0.3 0.3 0.3 41.6 

Tank ships

Handy 23.9 24.0 46.8 37.4 21.4 5.5 5.6 5.8 5.9 6.1 182.4 

HandyAframax 29.6 30.3 344.2 345.0 189.3 33.6 34.5 35.3 36.3 37.2 1115.1 

Suezmax 4.2 4.3 48.5 48.7 26.7 4.7 4.9 5.0 5.1 5.2 157.3 

VLCC 6.4 6.6 74.8 74.9 41.1 7.3 7.5 7.7 7.9 8.1 242.2 

ULCC 0.7 0.7 7.8 7.8 4.3 0.8 0.8 0.8 0.8 0.8 25.2 

Containerships

Feeder 10.0 10.0 13.4 9.3 5.6 1.9 2.0 2.0 2.1 2.1 88.0 

Feedermax 18.6 18.6 14.8 6.7 4.6 2.5 2.6 2.6 2.7 2.7 115.0 

Handy 18.2 18.3 50.5 44.3 25.3 6.2 6.4 6.5 6.6 6.8 284.2 

Subpanamax 7.7 7.9 77.4 77.6 43.0 8.5 8.7 8.9 9.0 9.2 387.9 

Panamax 7.8 8.0 78.3 78.5 43.5 8.6 8.8 9.0 9.1 9.3 392.4 

Postpanamax 12.2 12.5 122.4 122.7 68.1 13.5 13.7 14.0 14.3 14.6 613.5 

Other vessels

Passenger 

ships 50.7 51.0 43.9 23.2 16.7 10.3 10.7 11.0 11.4 11.8 240.7 

Gas carriers 20.3 20.4 46.1 38.9 22.6 6.2 6.3 6.5 6.6 6.7 180.6 

Chemical 

carriers 47.9 48.6 229.5 219.8 125.3 30.7 31.5 32.3 33.2 34.0 832.9 

RORO 38.7 39.2 140.8 130.9 75.6 20.4 20.9 21.4 22.0 22.6 532.5 

Combination 

vessels 3.2 3.2 9.5 8.5 4.9 1.4 1.4 1.4 1.5 1.5 36.5 

General 

Cargo 44.1 44.3 99.5 83.8 48.6 13.4 13.7 14.0 14.2 14.5 390.3 

Fishing 1.9 2.0 7.8 7.4 4.4 1.3 1.4 1.4 1.5 1.5 30.7 

Other 

Offshore and 

Coastal 

Vessels 12.9 13.1 22.7 19.2 13.1 6.9 7.3 7.6 8.0 8.4 119.2 

Total 405 409 2010 1898 1046 195 199 204 208 213 6787.7

Note: Totals may not add due to rounding 
Table D-4 shows the breakdown by year, vessel type, and the overall share for each vessel type. 

Table D-4 Installation Costs for the BWMS for Foreign Vessels ($Mil) 

Vessel Type 

Year 

Total 

1 2 3 4 5 6 7 8 9 10 

Bulk Carriers 

Handy Bulk 13.56 13.53 113.97 108.39 55.36 2.32 2.29 2.26 2.23 2.20 316.11 

Panamax 

Bulk 1.88 1.86 62.87 62.57 31.89 1.22 1.21 1.19 1.18 1.16 167.04 

Capesize 0.13 0.13 6.29 6.29 3.20 0.12 0.12 0.12 0.12 0.12 16.63 

Tank Ships 

Handy 7.67 7.71 15.02 12.00 6.88 1.76 1.81 1.86 1.90 1.95 58.57 

HandymaxAframax 11.83 12.13 137.66 137.98 75.71 13.44 13.78 14.14 14.50 14.88 446.05 

Suezmax 1.56 1.60 18.20 18.25 10.01 1.78 1.82 1.87 1.92 1.97 58.98 

VLCC 3.37 3.46 39.25 39.34 21.58 3.83 3.93 4.03 4.13 4.24 127.16 

ULCC 0.35 0.36 4.08 4.09 2.24 0.40 0.41 0.42 0.43 0.44 13.21 

Containerships 

Feeder 1.65 1.65 2.22 1.54 0.93 0.32 0.33 0.33 0.34 0.35 9.65 

Feedermax 4.38 4.39 3.50 1.58 1.09 0.60 0.61 0.62 0.63 0.65 18.05 

Handy 4.28 4.31 11.91 10.46 5.97 1.47 1.50 1.53 1.56 1.59 44.60 

Subpanamax 2.12 2.17 21.29 21.33 11.84 2.34 2.39 2.44 2.49 2.54 70.94 

Panamax 2.15 2.19 21.54 21.58 11.98 2.37 2.42 2.47 2.52 2.57 71.77 

Postpanamax 3.66 3.74 36.73 36.80 20.42 4.04 4.12 4.21 4.29 4.38 122.39 

Other vessels 

Passenger 

ships 8.37 8.42 7.24 3.82 2.76 1.70 1.76 1.82 1.88 1.94 39.72 

Gas carriers 10.44 10.50 23.75 20.04 11.62 3.20 3.26 3.33 3.39 3.46 93.00 

Chemical 

carriers 13.66 13.86 65.40 62.64 35.70 8.76 8.99 9.22 9.46 9.70 237.39 

RORO 9.14 9.24 33.23 30.90 17.85 4.81 4.93 5.06 5.19 5.33 125.68 

Combination 

vessels 0.75 0.76 2.24 2.01 1.17 0.32 0.33 0.34 0.35 0.36 8.62

General 

Cargo 10.41 10.47 23.49 19.78 11.48 3.17 3.23 3.30 3.36 3.43 92.11

Fishing 0.32 0.33 1.28 1.22 0.72 0.22 0.23 0.24 0.25 0.26 5.06

Other 

Offshore and 

Coastal 

Vessels 2.57 2.63 4.53 3.85 2.62 1.39 1.46 1.53 1.60 1.68 23.85

Total 114.27 115.44 655.67 626.47 343.01 59.59 60.93 62.31 63.72 65.18 2,166.59

Total PV 

3% 110.94 108.82 600.04 556.61 295.89 49.90 49.54 49.19 48.84 48.50 1,918.25

Total PV 

7% 106.79 100.83 535.23 477.93 244.56 39.70 37.94 36.26 34.66 33.13 1,647.05

143 
Operating Costs of Ballast Water Management System 

BWMS operational costs are in addition to the capital costs for installation. In order to obtain a 

cost of operation for the foreign vessel, we first had to calculate the amount of ballast discharge 

per vessel type (Table D-5). 

Table D-5 Estimated ballast water discharge in 2007 

Vessel Type # of 

Arrivasl 

Total Ballast 

Water Discharged 

Average Ballast Water 

Discharged per Vessel 

type 

Bulk carriers

Handy 1,137 8,632,730 7,593 

Panamax 300 5,281,319 17,604 

Capesize 42 339,360 8,080 

Tank ships

Handy 120 700,461 5,837 

Handymax-Aframax 7,303 162,180,186 22,207 

Suezmax 4,040 100,803,870 24,951 

VLCC 285 1,869,274 6,559 

ULCC 11 9,900 900 

Container ships

Feeder68 N/A N/A N/A 

Feedermax 6 1,200 200 

Handy 22 28,154 1,280 

Subpanamax 68 185,992 2,735 

Panamax 56 107,470 1,919 

Postpanamax 92 213,989 2,326 

Other vessels

Passenger ships 1,003 809,272.3 807 

Gas carriers 23 189,917.56 8,257 

Chemical carriers 1,211 7,722,161.79 6,377 

RORO 533 344,174.99 646 

Combination vessels N/A N/A N/A 

General Cargo 55 52,609.2 957 

Fishing Vessel N/A N/A N/A 

Other Offshore and Coastal 

Vessels 6 24,022 4,004 

Note: Totals may not add due to rounding. 

The average amount of ballast water discharged per vessel type is calculated by using data 

collected by NBIC for year 2007. The amounts of discharge from vessels, represented in the 

above table, are of those vessels that reported actual discharge of ballast in year 2007. This data 

was then cross-referenced to population data gathered from USCG MISLE database in order to 

match vessel activity with their corresponding category by vessel type. 

Once the average yearly amount of ballast discharge was determined, we multiplied these 

estimates by the number of vessels undergoing installation in Table D-3. Then multiply this 

 

68 Information for Feeder vessel is assumed to the same as for Feedermax 

144 
product by the cost presented in Table D -2 using the lowest cost per cubic meter of water for 

each particular vessel type. The calculated value is then used to formulate an annual operating 

cost for BWM (Table D-5) per vessel type. 

Table D-6 displays the operating costs for all affected vessels in the population. The total 

operating costs covering the period of analysis is approximately $61 million and $47 million at 3 

and 7 percent discount rates, respectively. 

Table D-6 Annual Operating Costs for BWM ($Mil) 

Vessel Type 

Year Vessel Type SubTotal 1 2 3 4 5 6 7 8 9 10 

Bulk Carriers 

Handy Bulk 0.072 0.144 0.750 1.326 1.620 1.632 1.644 1.656 1.668 1.680 12.191 

Panamax Bulk 0.032 0.064 1.147 2.224 2.773 2.795 2.815 2.836 2.856 2.876 20.420 

Capesize 0.001 0.002 0.050 0.099 0.123 0.124 0.125 0.126 0.127 0.128 0.907 

Tank Ships 

Handy 0.029 0.059 0.116 0.162 0.188 0.195 0.202 0.209 0.216 0.224 1.600 

Handymax- Aframax 

0.304 0.615 4.148 7.689 9.632 9.976 10.330 10.693 11.065 11.447 75.899 

Suezmax 0.175 0.354 2.385 4.421 5.538 5.736 5.939 6.148 6.362 6.581 43.638 

VLCC 0.211 0.062 0.701 0.703 0.385 0.068 0.070 0.072 0.074 0.076 2.422 

ULCC 0.001 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.001 

Containerships 

Feeder 0.001 0.001 0.002 0.001 0.001 0.000 0.000 0.000 0.000 0.000 0.009 

Feedermax 0.002 0.005 0.007 0.008 0.008 0.009 0.009 0.009 0.010 0.010 0.076 

Handy 0.029 0.058 0.139 0.211 0.251 0.261 0.271 0.282 0.292 0.303 2.098 

Subpanamax 0.023 0.047 0.279 0.512 0.641 0.666 0.692 0.719 0.746 0.774 5.098 

Panamax 0.005 0.010 0.057 0.104 0.130 0.136 0.141 0.146 0.152 0.158 1.038 

Postpanamax 0.029 0.059 0.351 0.644 0.806 0.838 0.871 0.905 0.939 0.974 6.416 

Other vessels 

Passenger ships 0.000 0.000 0.001 0.001 0.001 0.001 0.001 0.001 0.001 0.001 0.008 

Gas carriers 0.035 0.070 0.150 0.218 0.257 0.268 0.279 0.290 0.301 0.313 2.183 

Chemical carriers 

0.019 0.039 0.132 0.221 0.272 0.285 0.297 0.310 0.324 0.338 2.238 

RORO 0.001 0.002 0.005 0.008 0.009 0.010 0.010 0.011 0.011 0.012 0.077 

Combination vessels 

0.001 0.001 0.003 0.005 0.006 0.006 0.006 0.006 0.007 0.007 0.047 

General Cargo 0.000 0.001 0.001 0.002 0.002 0.002 0.002 0.002 0.002 0.002 0.017 

Fishing 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.002 

Other Offshore and Coastal 

Vessels 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.001 0.001 0.004 

Total 0.971 1.593 10.424 18.556 22.645 23.009 23.708 24.423 25.155 25.904 176.388

Total PV 3% 0.943 1.502 9.540 16.487 19.534 19.269 19.277 19.280 19.279 19.275 144.385

Total PV 7% 0.908 1.392 8.509 14.156 16.145 15.332 14.764 14.214 13.683 13.168 112.271

Note: Total may not add due to rounding. 

145 
Total Costs of Ballast Water Management Systems for Foreign Vessels 

In Table D-7, we estimate the total cost over the period of analysis for the foreign vessels. The 

total estimated cost was approximately $2.0 billion with a 3 percent discount rate and $1.6 

billion with a 7 percent discount rate. 

Table D-7 Total Cost of the Rulemaking to Foreign Vessels ($Mil) 

Year 

Installation Costs Treated Ballast 

Discharged 

(m3) 

Annual Operating 

Costs Total Cost 

3% 

Discount 7% Discount 3% Discount 

7% 

Discount 3% Discount 7% Discount 

1 $110.94 $106.79 6,975,800 $0.94 $0.91 $111.88 $107.70 

2 $108.82 $100.83 10,759,556 $1.50 $1.39 $110.32 $102.22 

3 $600.04 $535.23 74,183,840 $9.54 $8.51 $609.57 $543.73 

4 $556.61 $477.93 131,568,095 $16.49 $14.16 $573.10 $492.09 

5 $295.89 $244.56 159,811,057 $19.53 $16.15 $315.42 $260.71 

6 $49.90 $39.70 161,813,571 $19.27 $15.33 $69.17 $55.04 

7 $49.54 $37.94 166,832,339 $19.28 $14.76 $68.82 $52.71 

8 $49.19 $36.26 171,971,026 $19.28 $14.21 $68.47 $50.48 

9 $48.84 $34.66 177,232,781 $19.28 $13.68 $68.12 $48.34 

10 $48.50 $33.13 182,620,835 $19.28 $13.17 $67.77 $46.30 

Total $1,918.25 $1,647.05 $144.38 $112.27 $2,062.64 $1,759.32

Annualized $224.88 $234.50 $16.93 $15.98 $241.80 $250.49 

Comparison of Costs and Benefits of Ballast Water Management Systems 

Including Foreign Vessels 

In Chapter 6 of this RA we compared the benefits of the FR to the estimated costs for the U.S. 

fleet only. In this chapter, we present the same comparison but now include the costs for the 

foreign fleet. It should be noted that this comparison does not include a valuation of benefits that 

would result from the reduced risk of invasions from foreign-flagged vessels on a global basis69. 

The annualized cost for foreign vessels over the 10-year period of for the phase one standard is 

estimated to be $282 million at a 7 percent discount rate (Table D-7). Adding the annualized cost 

for foreign vessels to the annualized costs for U.S. ($92 million) we obtain a total annualized 

cost of approximately $251 million at a 7 percent discount rate (Table D-8). The quantified 

benefits for the phase one standard ranges from $5 million to $470 million per year, with a mid 

range of $141-$240 million per year and high range of $276- $470 million per year (at a 7 

 

69 The benefits estimates presented in this RA only consider reductions in NIS invasions to U.S. waters. Installing 

and using ballast water treatment systems will also result in reductions in NIS invasions to foreign waters, from both 

U.S. and foreign-flagged vessels. We have not attempted to estimate the benefits that might accrue to waters other 

than those in the U.S. 

146 
percent discount rate). Thus, quantified benefits will only exceed the estimated costs for high 

range benefits estimate of High Effectiveness. 

Table D-8 Total Cost of the Rulemaking to U.S. and Foreign Vessels ($Mil) 

Year 

Installation Costs Treated Ballast 

Discharged 

(m3) 

Annual Operating 

Costs Total Cost 

3% 

Discount 7% Discount 3% Discount 

7% 

Discount 3% Discount 7% Discount 

1 $165.76 $159.57 7,258,222.86 $0.99 $0.96 $166.75 $160.52 

2 $130.04 $120.50 11,018,776.04 $1.55 $1.44 $131.60 $121.94 

3 $793.18 $707.51 76,986,014.36 $9.97 $8.90 $803.16 $716.41 

4 $740.25 $635.61 136,789,064.58 $17.27 $14.83 $757.52 $650.44 

5 $423.61 $350.14 166,424,588.16 $20.50 $16.95 $444.11 $367.08 

6 $85.58 $68.09 168,569,876.26 $20.24 $16.10 $105.82 $84.19 

7 $85.62 $65.58 173,825,737.05 $20.25 $15.51 $105.87 $81.09 

8 $85.67 $63.17 179,207,285.60 $20.26 $14.93 $105.93 $78.10 

9 $85.74 $60.85 184,717,818.82 $20.26 $14.38 $106.01 $75.23 

10 $85.83 $58.64 190,360,716.72 $20.26 $13.84 $106.09 $72.48 

Total $2,681.30 $2,289.65 $151.55 $117.83 $2,832.86 $2,407.48 

Annualized $314.33 $326.00 $17.77 $16.78 $332.10 $342.77 

Comparison of Discounted Cumulative Benefits and Costs

When costs to foreign-flagged vessels are added to the domestic costs, the rule would reach the 

breakeven point (discounted cumulative benefits equal or outweigh discounted cumulative costs) 

by year 12 assuming a 63 percent reduction in the invasion rate and year 15 assuming a 37 

percent reduction in the invasion rate. Figure D-1 illustrates the cumulative costs of the BWD in 

relationship to the cumulative damages avoided to U.S. waters. 

 

147 
Figure D-1 Comparison of Cumulative Costs and Benefits (7% Discount Rate, $2007, Mid-Point Benefit per 

Invasion Estimate) 

$0 

$2,000 

$4,000 

$6,000 

$8,000 

$10,000 

$12,000 

$14,000 

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

$ Millions

Year

Benefits: 37% Reduction 

in Invasion Rate

Benefits: 

63% Reduction in Invasion Rate 

Domestic Costs

Foreign & Domestic Costs

 

148 
Appendix E Information Provided by Public Comments 

We received several comments from the public providing data on the BWMS costs during the 

NPRM public comment. We present the information submitted by the public in table E-1. For the 

standard and applicability of the FR, equipment and installation costs provided by the public are 

consistent with the costs in the RA. Therefore, there was no need to modify the range of costs 

used by Coast Guard due to the publicly supplied cost data. Some of the cost data provided by 

the public and presented below is related to vessels that are now excluded from the FR, such as 

Great Lakes and inland vessels. This data was not used on the FR analysis, but will be 

incorporated into any future applicable analyses. 

Table E-1 Cost Information on BWMS Provided by Public Comments 

 

Comment Equipment 

Costs 

 Installation 

Costs 

O & M Costs 

(per year) 

System 

size 

Retrofitting 

costs System 

Shipyard 

costs 

(per 

vessels) 

1 $400K - $580K - - - - - - 

2 $250K - $580K 

10% of 

equipment 

cost 

- - - 

3 $600K - $700K 

25% - 75% of 

equipment 

cost 

- 1200m3

/h - 

1500m3

/h - - 

4 - - - - $20 million - 

5 $200K - $250K - - - - UV - 

6 $750K - - - - Filter - 

7 $640K- 1.67Mil $134K $21K per 

system - - - - 

8 $250K - $2mil $2.5 - $500K - - - - - 

9 - - - - - - $50K - 

100K 

10 >$500K - $85K - $875K - - - - 

149 
Appendix F Aquatic NIS Invasion Process

This Appendix provides a brief summary of the scientific understanding of the aquatic NIS 

invasion process. It highlights the factors and events related to the introduction and successful 

establishment of aquatic NIS transported by a vector (e.g., ballast water). This analysis was 

prepared to provide the technical foundation for the Programmatic Environmental Impact 

Statement (PEIS) developed in support of the United States Coast Guard (USCG) Ballast Water 

Discharge Standard (BWDS) rulemaking. For the purposes of the FPEIS, the analysis focuses on 

the transport of individual organisms in ballast water and release into a new location 

(introduction), and the evaluation of whether these individuals provide the basis for successful 

population growth and survival (establishment). 

NIS introduction occurs when a species survives transport by a vector and is released into a new 

environment. Establishment occurs when the introduced species reproduces and spreads in its 

new environment. Thus, in simple terms, it is assumed that NIS are introduced when individual 

organisms are transported in ballast water and released into a new, non-native, location, whereas 

establishment occurs when introduced NIS establish a viable population. Impacts occur when an 

introduced species establishes a population that alters the ecology, food web, or fisheries, or 

otherwise disrupts the natural ecosystem or socioeconomics of an environment or region. 

Many factors affect the survival, spread, and proliferation of introduced species, including basic 

climatic factors and food resources, the nature of the reproductive biology of a species, and the 

presence or absence of competitors, predators, and parasites (Carlton 1996). The dispersal of 

introduced NIS occurs through vectors70 – the physical means or agent for transporting a species. 

In broad terms, the successful establishment of NIS involves seven sequential events, each 

having an associated probability of occurrence: (1) interface of species with transport vector; (2) 

vector take-up (engaging) of specific species; (3) survival of the transport event; (4) release from 

vector; (5) initial survival upon release; (6) establishment of first reproducing population; and (7) 

establishment of long-term reproducing populations. 

Each of these events is briefly described below, in a summary largely drawn from Carlton 

(1985). Some of these events may not be directly relevant to the discussion of potential impacts 

of BWDS, but they help in presenting the overall context of the NIS invasion process: 

1. Probability of interfacing with transport vector – species in the water column may or may 

not be immediately adjacent to the vessel at the moment the vessel is in a position to 

engage the local biota by drawing in ballast water. There is large temporal and spatial 

variability (determined by currents, tides, temperatures, salinity, stochastic events such as 

storms, as well as random probability) of the probability of interfacing with the transport 

vector, which can change within minutes to hours (as well as seasonally and annually). 

This temporal and spatial variability of the probability of interface determines which 

species are or are not in the available species pool for transport to a different location. 

 

70 Vector is the physical means or agent by which a species is transported. Ballast water is the vector of interest in 

this rulemaking, but many others exist and play an important role in the dispersal of NIS worldwide, including 

ships’ hulls (fouling organisms), drilling platforms and dry docks, fisheries activities, and the aquarium pet industry. 

150 
2. Probability of transport vector engaging specific species – only a subset of the pool of 

available species immediately next to the vessel are actually taken into the vessel. That 

is, being adjacent to the ship and within the effective zone of a vessel’s ballast water 

intake at the time of ballasting does not necessarily result in uptake. For example, 

species such as some shrimp and fish actively detect a water current (like the one created 

by the uptake of ballast water) and swim away from it. In addition, other species may not 

be engaged in the water flow as readily as others, even when acting as passive particles 

(e.g., planktonic organisms), due to their size, shape, or relative density. 

3. Probability of surviving the transport event – a substantial number of factors interact to 

determine the probability of a transported species surviving before being released. For 

example, the uptake process (including injury due to physical contact with the ship and 

its systems), light, temperature, salinity, oxygen, food, voyage duration, and other 

variables during transport all play an important role. Given the fact that there are 

thousands of species being transported in ballast water, it is particularly difficult to 

characterize the probabilities, except in very broad terms (i.e., the large variability in 

terms of the type of organisms entrained as well as the physical conditions in the ballast 

water, creates both ‘species specific’ and ‘voyage specific’ probabilities). 

4. Probability of being released – not all species transported are released; for example, 

organisms in a ballast tank may not leave the ballast tank, if not all of the water is 

discharged, or if the organisms in question are fouling species that attach themselves to 

the inside of the tank or imbed in the sediment that collects in the ballast tank. Organisms 

in a ballasted cargo hold are always either fully discharged (since the cargo now replaces 

100% of the ballast water) or die in transport (organisms that have settled on the cargo 

hold walls die of exposure, desiccation, or smothering by the cargo) (Carlton 2005). It is 

important to distinguish between these two different ballast systems (ballast tank and 

ballastable cargo hold) because of the long-term potential of ballast water in ballast tanks 

to not result in complete release after each voyage, which can then lead to colonies of 

living organisms in ballast tanks that remain there for a considerable period of time. 

These organisms could essentially re-seed the ship with larvae or other propagules, and 

pose a risk for future introductions even without new ballasting. 

5. Probability of initial survival upon release – regardless of inoculum size (the number of 

released individuals of any life stage), most released species (and perhaps all released 

species for most discharge events) do not survive after release. In addition, the discharge 

process can also result in injury to transported organisms due to physical contact with the 

ship systems. The scientific community does not have a complete understanding of the 

reasons for this, although some of the many potential causes include post-transport 

physiological weakness, post-transport starvation, physiological mismatch with the new 

environment once released, predation (consumption) at the release site, and competition 

with the resident biota. Over the decades, numerous vessels arriving in U.S. coastal 

waters have discharged millions of organisms (e.g., diatoms, copepods, worm larvae), 

which have appear to result in relatively few invasions. This fact is interpreted by the 

scientific community as the result of failure of initial survival. However, there is no 

certainty in this, as many other factors could be coming into play, including: many of the 

151 
organisms could have survived but not reproduced, and therefore failed to establish 

permanent populations; invasions could simply be overlooked for abundant, but poorly 

studied organisms and as such not recognized as invaders (seriously skewing our 

appreciation of the extent of invasions); or some established species that are considered 

rare may have population levels so low that they are below our ability to detect them 

without targeted searches. 

6. Probability of establishing the first reproducing population – as a general proposition, the 

probability that a species reproduces and becomes successfully established is positively 

related to the number of individual organisms that are introduced. Thus, the number of 

organisms of a particular species released via ballast water is a potentially important 

determinant of the probability that a population establishes its first reproducing 

population. However, it is important to highlight that the probability that an inoculum 

may result in an established population may also be largely dependent on dilution of the 

inoculum, hydrodynamics of water flow, and local microtopographic features, which 

affect the distribution of introduced organisms in the new environment. Those factors 

affect the ability to reproduce by influencing the probability that organisms of the same 

species interact with each other. However, there are a number of life stages and sexual 

and asexual reproductive modes which may characterize organisms in BW. For example, 

the presence of ovigerous females, bacteria, and spore-releasing organisms can result in 

elevated reproductive potential of the species in the receiving waters and is independent 

of the number of organisms released. 

7. Probability of establishing long-term reproducing populations – the establishment of 

long-term reproducing populations is dependent on a wide range of biological and 

physical variables. In addition, it is important to note that there is no scientific consensus 

about the meaning of "long-term" reproducing populations. For example, there are many 

scientists who, observing a new invader with multiple populations in a specific ecosystem 

and with multiple generations represented, argue that sampling needs to be conducted 

some time in the future (5 or 10 years) to verify whether the species is still present before 

concluding that long-term establishment has occurred. 

While each event is important and must be realized for invasion success, the most critical event 

for prevention of invasions is release. If the numbers released are sufficiently low that 

establishment does not occur the invasion is prevented. 

Predicting Invasion and Potential Impacts of NIS 

Biological and physical interactions in aquatic ecosystems are highly complex. Aquatic 

organisms are not static, isolated entities that merely occupy space in the water column or the 

benthic environment of aquatic ecosystems; they interact dynamically with their physical, 

chemical, and biological environment as components of an ecosystem. In addition, there is very 

limited information about the biology and ecology of the majority of aquatic species. The 

BWDS rulemaking is national in nature and thus applicable to widely diverse aquatic ecosystems 

throughout the U.S., thus increasing the relevance of the limitations of our knowledge for 

analyzing the alternatives in the FPEIS. These limitations, together with the variability involved 

152 
in the transport of aquatic organisms via ballast water, makes it extremely difficult to predict 

which NIS from a potential pool of thousands of species are likely to be delivered, which NIS are 

likely to become successfully established, and which NIS are likely to significantly affect the 

invaded ecosystems. 

The introduction and establishment of species into a new environment is so complex and full of 

variability and uncertainty, that it has been called “a game of ecological roulette” (Carlton and 

Geller 1993). The complexities associated with – and the limited knowledge of – the invasion 

process make predicting which organisms arrive, their origin, the time of their arrival, and 

whether they survive, persist, spread, and proliferate, an exceptionally challenging problem. 

Invasion rates vary dramatically with region and propagule delivery (vector) history. One of the 

main factors to be considered in the current context is the large variability in the densities of 

organisms transported via ballast water. Sampling studies show that organism densities in ballast 

water can range from very low (as little as 1 individual per cubic meter) to very high (thousands 

per cubic meter) (Carlton 2001, Cohen 1998). Low observed densities are generally associated 

with sampling schemes targeting multicellular forms or larger protists. In many cases, however, 

the bacterial and viral components may exist in higher concentrations. Furthermore, the 

potential number of organisms released by a given vessel could be considerable depending on the 

total amount of BW discharged. In addition, survival varies greatly in transits. However, in 

general, the longer the voyage, the more organisms die. Exceptions are species that reproduce in 

situ in the water column or that reproduce from the ballast benthic communities and shed larvae 

into the water column, and organisms that go into a resistant or dormant stage such as 

dinoflagellates cysts that can persist in the sediments when stressful conditions are intolerable for 

vegetative or reproductive stages. 

The extinction threshold (or conversely, the minimum number of organisms necessary for 

successful establishment) is unknown for most species under most conditions. For many 

organisms, the initial population sizes required for successful establishment upon release may be 

much lower than generally predicted. In theory, even a single organism, if monoecious, 

hermaphroditic, or parthenogenic, could establish a successful population. Many species that 

have such cycles have been found to be capable of successful establishment (Sakai et al. 2001) 

because they only need one individual to invade a new environment (Davis 2005). Thus, it is 

very difficult to determine whether a very small initial population size or a very large one led to 

successful establishment of a particular NIS. 

Understanding this would require detailed knowledge of the precise life stage of the specific 

species in question that would be released, in what numbers, into what ecosystem, and with what 

hydrodynamic71 conditions at the moment of release. Unfortunately, (most of the time, for most 

species, for most release events, at most places), only limited information is available, thus 

limiting the possibility of providing a more definitive assessment of the probability of invasion 

(Carlton 2005). It follows from the discussion above (e.g., in theory even a single organism of a 

 

71 In invasive species ecology, the "lagoonal hypothesis" argues that a few individuals can find themselves in a 

retention system that prevents loss due to export, such that a population can become established from a very small 

initial population size. This can be interpreted as meaning that most species simply do not successfully become 

established because upon release the individuals become so dispersed that the organisms do not locate each other to 

reproduce (not applicable to asexually reproducing species) even if some of these individuals survive and settle as 

transient species and establish an initially successful population. Thus, local (stochastic) events may facilitate 

invasion from a very small number of released organisms. 

153 
particular species can lead to successful establishment) that it is impossible to accurately predict 

whether individuals of unknown species in a given vessel on a given voyage will become 

successfully established when released in a new environment, or go extinct. 

An additional complicating factor is that a large number of species are not studied to determine 

their potential invasive capacity in a new environment. Some of the main ecological factors that 

determine the invasive capacity of organisms in a new environment include niche availability, 

lack of predation, resource abundance, and competitive advantage. 

For example, the shore crab Hemigrapsus sanguineus is of no particular concern in its native 

Asia, but it became a highly invasive species (with significant ecological impacts) when 

introduced to the U.S. Atlantic coast in the 1980s. In the 19 years since its discovery at Cape 

May, NJ in 1988, it has spread and can now be found in large numbers from Maine to the 

Carolinas. Further, detailed studies in Japan reveal that this crab is strictly a rocky shore 

(intertidal) species in its native range. However, on the U.S. Atlantic coast, it has become 

established in no fewer than five different habitats (USGS 2006). This was not a predictable 

outcome; thus, the invasion potential and impact of this species (and potentially many others) 

was not predictable from knowledge of its biology and ecology in its native environment 

(Carlton 2005). 

The context provided above sets the broader stage of the invasion process, and summarizes the 

variables that need to be considered to analyze the alternatives and their potential implications. 

It is important to clarify that, while (in general) the likelihood that any given individual of a 

particular species might go through all the steps previously described and become successfully 

established in the long-term is quite low, the likelihood that a vessel will release live organisms 

from ballast water is high. 

Current scientific knowledge makes predicting the fate of even a single population for even well 

studied organisms a very challenging problem. Indeed, Ludwig (1999) has argued that it is 

essentially impossible. The problem is even more challenging in the context of assessing the 

aggregate effect of the BWDSs (specified under the alternatives) on the rate at which NIS are 

introduced and become established in waters of the United States. This is because the 

populations of concern are difficult to identify and not well-studied. Predicting the ecological or 

economic impacts of NIS that successfully become established is even more challenging because 

cause and effect relationships would need to be established and well-defined (Carlton 2001) and 

the current poorly resolved state of scientific knowledge makes the latter very difficult. It is 

important to clarify that the difficulty lies in the prediction of which species will become 

established and the nature and extent of their subsequent impacts, even if the likelihood of 

organisms being released is considerable. 

Management measures aimed at reducing the number of organisms released are implicitly or 

explicitly aimed at reducing the probability that a population will become established or, 

equivalently, increasing the probability that the relatively small initial population will become 

extinct after introduction. Thus, the BWDSs prescribed under the alternatives differ in the 

degree to which they reduce the number of organisms that are introduced via discharged ballast 

water. The number of individual organisms introduced will be referred to as the initial 

population size. Even when transport and release occur, ballast water management efforts that 

reduce the number of organisms released (such as the alternatives analyzed in the PEIS) can help 

154 
to prevent successful establishment. As a general proposition, the probability that a population 

will become extinct is inversely related to the initial population size of the species of interest. 

The PEIS used the Population Viability Analysis (PVA) to analyze the relationship between 

population size and extinction probability for this rulemaking. PVA refers to the use of 

quantitative methods to predict the likely future status of a population or collection of 

populations of conservation (or extinction) concern. PVA is performed by developing a 

mathematical model of the dynamics of the population of interest and using this model to predict 

the effect of varying the initial population size (or other factors) on extinction probability and 

other variables of interest in conservation (Boyce 1992). PVA is typically used to assess the 

conservation status of a particular population and therefore typically involves the development of 

a model of the dynamics of each population of interest separately. The PEIS presents a detailed 

discussion on the use of PVA (PEIS, Appendix A) and the model results. As a result of the PVA 

model used in the PEIS we were able to estimate reductions in the mean rate of successful INS 

introductions. The reduction in the mean rate was used in our benefits estimates in Chapter 5 of 

this document. 

 

155 
References: 

Boyce, M. 1992. “Population Viability Analysis”. Annual Review of Ecology and Systematics

23: 481-506. 

Carlton, J.T. 1985. “Transoceanic and Interoceanic Dispersal of Coastal Marine Organisms: The 

Biology of Ballast Water”. Oceanography and Marine Biology Annual Review 23: 313–371. 

Carlton, J. T. 2001. Introduced Species in United States Coastal Waters: Environmental Impacts 

and Management Priorities. Pew Oceans Commission, Arlington, Virginia. 

Carlton, J.T. 2005. Personal communication with José G. Mantilla by electronic mail. 

December 15, 2005. 

Carlton, J.T. and Geller, J.B. 1993. “Ecological Roulette: The Global Transport of 

Nonindigenous Marine Organisms”. Science, 261(5117): 78-82. 

Cohen, A.N. 1998. Ships’ Ballast Water and the Introduction of Exotic Organisms into the San 

Francisco Estuary. San Francisco Estuary Institute, Richmond, CA. 

Davis, C. 2005. Personal communication with José G. Mantilla by electronic mail. December 

15, 2005. 

Ludwig, D. 1999. “Is It Meaningful to Estimate a Probability of Extinction?” Ecology 80(1): 

298-310. 

Sakai A.K., Allendorf, F.W., Holt, J.S., Lodge, D.M., Molofsky, J., With, K.A., Baughman, S., 

Cabin, R.J., Cohen, J.E., Ellstrand, N.C., McCauley, D.E., O' Neil, P., Parker, I.M., Thompson, 

J.N., and Weller, S.G. 2001. “The Population Biology of Invasive Species”. Annual Review of 

Ecology and Systematics 32 (1): 305-332. 

USGS, 2006. “Nonindigenous Species Information Bulletin: Asian Shore Crab, Japanese Shore 

Crab, Pacific Crab, Hemigrapsus sanguineus (De Haan) (Arthropoda: Grapsidae)” 

http://cars.er.usgs.gov/Nonindigenous_Species/Asian_shore_crab/asian_shore_crab.html 

 

156 
Appendix G Alternative Analyses of Benefits (Economic Costs 

Avoided) 

Summary of Benefits Assuming Benefits Deferred Until All Vessels Install Management 

Systems: 

Table G-1 Benefits by Year Under Deferred Assumption – 7% ($Mil) 

7% Discount Rate 

Low Effectiveness - 37% High Effectiveness - 63% 

Year Low Mid High Low Mid High 

1 $0 $0 $0 $0 $0 $0 

2 $0 $0 $0 $0 $0 $0 

3 $0 $0 $0 $0 $0 $0 

4 $0 $0 $0 $0 $0 $0 

5 $0 $0 $0 $0 $0 $0 

6 $3 $76 $150 $5 $130 $255 

7 $5 $144 $283 $9 $246 $482 

8 $8 $205 $402 $13 $349 $684 

9 $10 $258 $507 $16 $440 $863 

10 $11 $305 $599 $19 $520 $1,020 

Total $37 $989 $1,941 $63 $1,684 $3,304 

Annualized $5 $141 $276 $9 $240 $470 

Table G-2 Benefits by Year Under Deferred Assumption – 3% ($Mil) 

3% Discount Rate 

Low Effectiveness - 37% High Effectiveness - 63% 

Year Low Mid High Low Mid High 

1 $0 $0 $0 $0 $0 $0 

2 $0 $0 $0 $0 $0 $0 

3 $0 $0 $0 $0 $0 $0 

4 $0 $0 $0 $0 $0 $0 

5 $0 $0 $0 $0 $0 $0 

6 $3 $92 $181 $6 $157 $308 

7 $7 $181 $356 $12 $309 $606 

8 $10 $267 $525 $17 $455 $893 

9 $13 $350 $687 $22 $596 $1,170 

10 $16 $430 $844 $27 $733 $1,438 

Total $49 $1,321 $2,593 $84 $2,250 $4,416 

Annualized $6 $155 $304 $10 $264 $518 

157 
Several commenters expressed the view that Coast Guard did not fully account for all benefits 

that might result from a ballast water discharge standard in the 10-year period of analysis used in 

the NPRM RA. In response to these comments, we provide two alternative analyses of benefits 

– one that extends the comparison of benefits and costs over a longer, 20-year time period and 

one in which we assume that invasions are avoided before the entire fleet as installed 

management systems. For this alternative, we assume that the fraction of invasions avoided is 

proportional to the fraction of vessels (percent of fleet) that has installed management systems. 

Summary of Benefits Assuming No Benefits Until Rule All Vessels Install Management 

Systems, 20-Year Period of Analysis: 

Table G-3 Benefits by Year Under Deferred Assumption, 20-Year Period of Analysis– 7% ($Mil) 

7% Discount Rate 

Low Effectiveness - 37% High Effectiveness - 63% 

Year Low Mid High Low Mid High 

1 $0 $0 $0 $0 $0 $0 

2 $0 $0 $0 $0 $0 $0 

3 $0 $0 $0 $0 $0 $0 

4 $0 $0 $0 $0 $0 $0 

5 $0 $0 $0 $0 $0 $0 

6 $3 $76 $150 $5 $130 $255 

7 $5 $144 $283 $9 $246 $482 

8 $8 $205 $402 $13 $349 $684 

9 $10 $258 $507 $16 $440 $863 

10 $11 $305 $599 $19 $520 $1,020 

11 $13 $347 $680 $22 $590 $1,159 

12 $14 $383 $751 $24 $652 $1,279 

13 $15 $414 $812 $26 $705 $1,383 

14 $16 $440 $865 $28 $750 $1,472 

15 $17 $463 $909 $29 $789 $1,548 

16 $18 $482 $946 $31 $821 $1,611 

17 $19 $498 $977 $32 $848 $1,664 

18 $19 $510 $1,002 $32 $869 $1,706 

19 $19 $520 $1,021 $33 $886 $1,738 

20 $20 $528 $1,035 $33 $898 $1,763 

Total $208 $5,573 $10,939 $354 $9,490 $18,626 

Annualized $20 $526 $1,033 $33 $896 $1,758 

 

158 
Table G-4 Benefits by Year Under Deferred Assumption, 20-Year Period of Analysis– 3% ($Mil) 

3% Discount Rate 

Low Effectiveness - 37% High Effectiveness - 63% 

Year Low Mid High Low Mid High 

1 $0 $0 $0 $0 $0 $0 

2 $0 $0 $0 $0 $0 $0 

3 $0 $0 $0 $0 $0 $0 

4 $0 $0 $0 $0 $0 $0 

5 $0 $0 $0 $0 $0 $0 

6 $3 $92 $181 $6 $157 $308 

7 $7 $181 $356 $12 $309 $606 

8 $10 $267 $525 $17 $455 $893 

9 $13 $350 $687 $22 $596 $1,170 

10 $16 $430 $844 $27 $733 $1,438 

11 $19 $507 $996 $32 $864 $1,696 

12 $22 $582 $1,142 $37 $991 $1,945 

13 $24 $654 $1,283 $41 $1,113 $2,184 

14 $27 $723 $1,419 $46 $1,231 $2,416 

15 $29 $790 $1,550 $50 $1,344 $2,639 

16 $32 $854 $1,676 $54 $1,454 $2,853 

17 $34 $916 $1,797 $58 $1,559 $3,060 

18 $36 $975 $1,914 $62 $1,661 $3,260 

19 $38 $1,033 $2,027 $66 $1,758 $3,451 

20 $41 $1,088 $2,136 $69 $1,853 $3,636 

Total $352 $9,442 $18,533 $599 $16,077 $31,556 

Annualized $24 $635 $1,246 $40 $1,081 $2,121 

159 
Figure G-1 Cumulative Benefits and Costs Under Deferred Assumption, 20-Year Period of Analysis– 7% 

$0 

$2,000 

$4,000 

$6,000 

$8,000 

$10,000 

$12,000 

$14,000 

123456789

1011121314151617181920

$ Millions

Benefits: 37% 

Reduction in 

Invasion Rate

Benefits: 

63% Reduction in Invasion Rate 

Cumulative Domestic Costs

We also calculated benefits assuming that the reductions in invasions would be proportional to 

the fraction of the fleet that had installed a management system. Under this assumption, benefits 

of the BWDS start accruing in the first year of the analysis as vessels begin to install 

management systems. Under this assumption, the mid-range of annual benefits is $305-$519 

million at 7 percent, in comparison to a range of $141-$240 million when we assume that 

benefits do not accrue until all vessels have installed treatment. 

Table G-5 Benefits by Year Under Phased-In Assumption – 7% ($Mil) 

7% Discount Rate 

Low Effectiveness - 37% High Effectiveness - 63% 

Year Low Mid High Low Mid High 

1 $0 $3 $6 $0 $6 $11 

2 $1 $14 $28 $1 $24 $47 

3 $2 $54 $106 $3 $92 $180 

4 $4 $117 $230 $7 $199 $391 

5 $7 $189 $371 $12 $322 $632 

6 $9 $253 $497 $16 $431 $845 

7 $12 $309 $607 $20 $527 $1,034 

8 $13 $359 $705 $23 $611 $1,200 

9 $15 $402 $790 $26 $685 $1,345 

10 $16 $440 $864 $28 $749 $1,471 

Total $80 $2,141 $4,203 $136 $3,646 $7,157 

Annualized $11 $305 $598 $19 $519 $1,019 

160 
Table G-6 Benefits by Year Under Phased-In Assumption – 3% ($Mil) 

3% Discount Rate 

Low Effectiveness - 37% High Effectiveness - 63% 

Year Low Mid High Low Mid High 

1 $0 $3 $6 $0 $6 $11 

2 $1 $15 $29 $1 $25 $49 

3 $2 $58 $114 $4 $99 $194 

4 $5 $131 $258 $8 $224 $439 

5 $8 $220 $432 $14 $375 $736 

6 $11 $306 $601 $19 $521 $1,023 

7 $14 $389 $763 $25 $662 $1,300 

8 $17 $469 $920 $30 $798 $1,567 

9 $20 $546 $1,071 $35 $929 $1,824 

10 $23 $620 $1,217 $39 $1,056 $2,073 

Total $103 $2,757 $5,412 $175 $4,695 $9,215 

Annualized $12 $323 $634 $21 $550 $1,080 

161 
Appendix H Derivation of Estimates of Costs and Damages Due 

to Aquatic NIS 

Non-indigenous aquatic invasive species can cause considerable economic damages such as 

costs to control the invasion, damage to infrastructure and other assets, loss of fishery resources, 

and loss of recreation and tourism opportunities. We have reviewed the literature on economic 

damages resulting from existing NIS invasions to predict damages from future invasions. Since 

each invasive specie is unique, the type and level of cost varies widely from specie to specie (i.e., 

variability). Further, the cost estimates of damage for an individual specie can also vary as 

different studies focus on particular aspects of costs or costs within a specific geographic range. 

Because of variability in the amount of damage across species and the uncertainty in estimating 

damages for an individual species, we have not attempted to derive a comprehensive estimate of 

costs per non-invasive species. Instead, we establish a range of values to use – a low end of the 

range and upper end estimate with a calculated mid-range by species groups – invertebrates 

(mollusks), fish, and aquatic plants. 

Table H-1 summarizes estimates of costs due to NIS invasions as derived from the existing 

literature. The following discussion provides an explanation for the derivation of the low and 

upper end estimates by species group. 

Invertebrates 

• At the upper end, Piementel, et al. 2005 estimates costs resulting from Zebra Mussels of 

$1 billion per year. The estimate would be $1,060,000,000 annually updated to 2007 

price level. This value is meant to be a comprehensive estimate covering all damages and 

control costs in all geographic areas. In addition, Pimentel, et al 2005 reports an estimate 

for the Asian Clam at $1 billion per year in damages and costs, based on the reported cost 

in the 1993 OTA report. The estimate would be $1,060,000,000 annually updated to 

2007 price level. Based on the damage estimates for these two species of mollusks 

(Zebra Mussel and Asian Clam), we establish the upper end of the range at $1.060 billion 

per year in potential costs and damages for invertebrates. 

• At the lower end, two survey-based studies collected information on the amount that 

facilities (mainly electric generation and water treatment facilities) have spent on zebra 

mussel control and/or prevention. A 2007 study (Connelly, et al) provided in estimate of 

$17.8 million per year spent by electric generation and water treatment facilities over the 

time period of 1989 to 2004 ($19.6 million updated to 2007). O’Neill 1997 provided an 

estimate of $17.751 million per year for infrastructure owners and operators. Both of 

these studies, while based on survey responses, only account for a subset of impacted 

parties and only one category of costs, but can be used to establish the lower end of the 

range of potential costs from invertebrates. 

162 
163 

• The calculated mid-range between the upper end ($1.060 billion) and lower end ($19.538 

million) is $539.769 million. 

Fish 

• At the upper end, Leigh 1998 estimates that the annual commercial and recreational 

fishing benefits lost due to the ruffe invasion in the Great Lakes range from $24 million 

and $119 million to $240 million (1998 prices), $31.4 million, $155.9 million and 

$305.289 million updated (based on varying assumptions about the loss of yellow perch 

and walleye populations). We use the upper estimate of $305.289 million per year to 

represent potential damages for invasive fish species. 

• At the lower end, Jenkins 2001 reports an estimate of the economic impact of sea 

lamprey at $13.5 million, updated to $15.8 million. 

• The calculated mid-range between the upper end ($305.3 million) and lower end ($15.8 

million) is $160.547 million. 

Aquatic Plants 

• At the upper end, Pimentel 2005 estimates that the costs to control Eurasion milfoil is 

$400 million per year ($424.7 million updated) based on an average cost per hectacre. 

• At the lower end, Rockwell 2003 reported estimates of costs to control Water Hyacinth in 

Louisiana of $4.0 million per year, updated to $4.5 million. 

• The calculated mid-range between the upper end ($424.7 million and lower end ($4.5 

million) is $214.6 million.

Summary 

Table H-1 Range of Annual Costs Associated with Selected NIS Introductions ($ 2007) 

Low-Range Mid-Range High Range

Fish $ 15,805,000 [1] $ 160,547,000 $ 305,289,000 [2] 

Invertebrates $ 19,538,000 [3] $ 539,769,000 $ 1,060,000,000 [4] 

Aquatic Plants $ 4,507,000 [5] $ 214,585,500 $ 424,664,000 [6] 

[1] From Jenkins 2001, economic impact of sea lamprey on Great Lakes, updated from 2001$ 

[2] From Leigh 1998, commercial and recreational fishing benefits lost due to ruffe invasion of 

Great Lakes, updated from 1998$ 

[3] From Connelly et al. 2007, cost of Zebra Mussel control at WTP and electric generation facilities, updated 

from 2004$ 

[4] From Piementel et al. 2005, cost of Zebra Mussel or Asian Clam, updated from 2005$ 

[5] From Rockwell 2003, cost to control Water Hyacinth in Louisiana, updated from 2003$ 

[6] From Pimentel 2005, cost to control Eurasian watermilfoil, updated from 2005$ 
Table H-2 Summary of Cost Estimates for Invertebrates from Literature 

Zebra Mussel 

Reference: Source: What is included in estimate? 

Pimentel et al., "Update on the environmental and 

economic costs associated with alien-invasive species in the United States". Ecological Economics. 52 (2005) 273-288 

US Army COE Environmental Laboratory, "http://el.erdc.usace.army.mil/zebra/zmis/zmishelp/e

conomic_impacts_of_zebra_mussel_infestation.htm" Zebra Mussel Information Review, JanuaryFebruary 1994, congressional researchers estimate costs of $3 billion over 7 years for power industry alone, $5 billion by end of decade. 

All damages and control 

costs 

Pimentel, "Aquatic Nuisance Species in the New 

York State Canal and Hudson River Systems and the Great Lake Basin: An Economic and Environmental Assessment," Environmental Management. 35:5 (2005) 692-701 

Derived from larger estimate of $1 billion total. 

Damages to tourism, electric 

industry, fishing, boating, 

other recreation for limited 

geographic area 

Ben Grumbles, AA Office of Water, USEPA, Testimony Before WATER RESOURCES AND ENVIRONMENT SUBCOMMITTEE OF THE HOUSE TRANSPORTATION AND INFRASTRUCTURE COMMITTEE, March 7, 2007 

O’Neill, C. R. 2000. National Aquatic Nuisances Species Clearinghouse, New York Sea Grant Extension, Brockport NY, Personal Communication, 22 Dec. 2000. As reported in Carlton, Introducted Species in US Coastal Water for the Pew Oceans Commission 

Losses to natural resources 

and damage to infrastructure 

in Great Lakes of $750 

million to $1 billion from 

1989 to 2000 

EPA estimates, quotes from Dr. David Lodge of Notre Dame in a variety of media 

Costs for control and 

treatment of zebra mussels at industrial and municipal 

facilities fo $100 to $200 

million per year in Great 

Lakes 

US General Accounting Office, INVASIVE SPECIES: Clearer Focus and Greater Commitment GAO estimates Annual costs to the American power industry 

164 
Needed to Effectively Manage the Problem, 

October 2002, GAO-03-01. US Fish & Wildlife Service estimate as reported in Cataldo, R. "Musseling in on the Ninth District 

Economy," Fedgazette, 13(1) 15-17. 

Impacts on industry, 

recreation and fisheries of 

$3.1 billion over next ten 

years 

US Congress, Office of Technology Assessment, Harmful Non-Indigenous Species in the United States September 1993, OTA-F-565. 

Contractor report by Mark J. Cochran, Nonindigenous species in the United States-economic consequences, 1992. 

Economic impact over next 

10 years of $3.1 billion 

($1991) 

Connelly, et al. Economic Impacts of Zebra 

Mussels on Drinking Water Treatment and Electric Power Generation Facilities, Environ Manage 40 (2007) 105–112 

Survey of a subset of electric generation and drinking water treatment facilities within zebra mussel range in 2004 

$267 million (BCa 95% CI 

= $161 million–$467 

million) in total economic 

costs for electric generation 

and water treatment 

facilities through late 2004, 

since 1989. 

O'Neill, Economic Impact of Zebra Mussels - Results of the 1995 National Zebra Mussel Information Clearinghouse Study, Great Lakes Research Review 3:1(April 1997). 

Survey to infrastructure owners and operators 

$17751000 annually in 1995 

for respondents only (no 

scaling for non-response or 

universe of facilities), 

average $11,500,000 

annually for 1989-1995 

Hushak, L.J. and Y. Deng, 1997. Costs of Alternative Zebra Mussel Control Strategies: The Case of Great Lakes Surface Water Users, Ohio Sea Grant College Program, Ohio State University 

Estimate of zebra mussel research expenditures $8.8 million annually for 1992, 1992 and 1994 

Asian Clam 

Reference: Source: What is included in estimate? 

Pimentel et al., "Update on the environmental and 

economic costs associated with alien-invasive species in the United States". Ecological Economics. 52 (2005) 273-288 

OTA All damages and control costs 

US Congress, Office of Technology Assessment, Harmful Non-Indigenous Species in the United States September 1993, OTA-F-565. 

B.G. Isom, Historical Review of Asiatic Clam Invasions and Biofouling of Waters and Industries in the Americas 

All damages and control 

costs 

165 
Shipworm 

Reference: Source: 

What is included in 

estimate? 

Pimentel et al., "Update on the environmental and 

economic costs associated with alien-invasive species in the United States". Ecological Economics. 52 (2005) 273-288 

Cohen, A.N., Carlton, J.T., 1995. Nonindigenous Aqautic Species in a United States Estuary: A Case Study of the Biological Invasions of the San Francisco Bay and Delta. United States Fish and Wildlife Service, Washington, DC. 

Damages 

New Zealand Mud Snail 

Reference: Source: What is included in estimate? 

Davis, A. and Moeltner, K. Valuing the Prevention of an Infestation: The Threat of the New Zealand Mud Snail in Northern Nevada. UNR Joint Economics Working Paper Series Working Paper No. 09-001. July 2009. 

Original analysis 

Welfare and expenditure 

losses to recreational 

fishermen for 3 possible 

policies to control New 

Zealand mud snail in the 

Truckee/Carson/Walker 

watershed 

Green Crab 

Reference: Source: What is included in estimate? 

Pimentel et al., "Update on the environmental and 

economic costs associated with alien-invasive species in the United States". Ecological Economics. 52 (2005) 273-288 

Lafferty, K.D., Kuris, A.M., 1996. Biological control of marine pests. Ecology 77 (7), 1989–2000. Economic impacts 

Lafferty, K.D., Kuris, A.M., 1996. Biological control of marine pests. Ecology 77 (7), 1989–2000. 

Original analysis 

Economic value of existing 

fishery harvest at risk from 

introduction of green crab 

on west coast 

166 
S. Lovell, S., Besedin, E., and E. Grosholz. 

Modeling Economic Impacts of the European Green Crab. American Agricultural Economics Association Annual Meeting, Portland, OR, July 29-August 1, 2007 

Original analysis 

Damage to commercial 

shellfishery including softshell clams, hard clams, 

Manilla clams, and mussels 

from green crab predation 

on the East Coast 

Fish 

Reference: Source: What is included in estimate? 

Pimentel et al., "Update on the environmental and economic costs associated with alien-invasive species in the United States". Ecological Economics. 52 (2005) 273-288 

Unpublished data by author 

Economic losses due to 138 

alien invasive species that 

have negatively affected 

native fishes and other 

aquatic biota 

Leigh, "Benefits and Costs of the Ruffe Control Program for the Great Lakes Fishery," Journal of Great Lakes Research, 24:2 (1998) 351-360. 

Estimation of annual commercial and recreational 

fishing benefits lost due to ruffe invasion using a 

value per angler/day approach 

Recreational, commercial 

and sport fishing (assumes 

10%, 35% and 60% 

reduction in the population 

of yellow perch and 1%, 

12.5% and 25% reduction in 

the population of wall-eye) 

US Congress, Office of Technology Assessment, Harmful Non-Indigenous Species in the United States September 1993, OTA-F-565. 

Great Lake Commission estimates Economic losses due to ruffe 

US Congress, Office of Technology Assessment, Harmful Non-Indigenous Species in the United States September 1993, OTA-F-565. 

Schnittker, J., ‘ ‘Federal Policy on Non- Indigenous Species: An Overview of the U.S. Department of Agriculture, ” contractor report prepared for the Office of Technology Assessment, December 1991. 

Value of lost fishing 

opportunities and indirect 

impacts if sea lamprey is not 

controlled in the Great 

Lakes 

Jenkins, P. 2001. “Economic Impacts of Aquatic Nuisance Species in the Great Lakes.” Report prepared by Philip Jenkins and Associates, Ltd., for Environment Canada, Burlington, Ontario. 

As reported in Lovell et al 2006 

Economic impact of sea 

lamprey in Great Lakes (US 

and Canada) 

167 
Aquatic Plants 

Reference: Source: What is included in estimate? 

Pimentel et al., "Update on the environmental and 

economic costs associated with alien-invasive species in the United States". Ecological Economics. 52 (2005) 273-288 

OTA 

Amount invested annually 

in alien species aquatic 

week control (assume for 5 

species: hydrilla, European 

loosestrife, erasion water 

milfoil, melaluca, salt cedar) 

Pimentel et al., "Update on the environmental and 

economic costs associated with alien-invasive species in the United States". Ecological Economics. 52 (2005) 273-288 

Center et al, 1997 Spending by Florida for hydrilla control 

Pimentel, "Aquatic Nuisance Species in the New 

York State Canal and Hudson River Systems and Great Lakes Basin: An Economic and Environmental Assessment." Environmental Management. 35:5 (2005) 692-701 

Calculated based on reported cost per ha to control Cost to control Eurasion Watermilfoil nationally 

Pimentel, "Aquatic Nuisance Species in the New 

York State Canal and Hudson River Systems and Great Lakes Basin: An Economic and Environmental Assessment." Environmental Management. 35:5 (2005) 692-702 

Data from USGS Cost to control purple loosestrife nationally 

Pimentel, "Aquatic Nuisance Species in the New 

York State Canal and Hudson River Systems and Great Lakes Basin: An Economic and Environmental Assessment." Environmental Management. 35:5 (2005) 692-703 

Calculated based on reported costs to control in 

Lake Champlain Basin 

Cost to control water 

chestnut nationally 

US Congress, Office of Technology Assessment, Harmful Non-Indigenous Species in the United States September 1993, OTA-F-565. 

Courtenay, W. R., Jr., ‘ ‘Pathways and Consequences of the Introduction of NonIndigenous Fishes in the United States, ” contractor report prepared for the Office of Technology Assessment, August 1991. 

Amount invested annually 

in alien species aquatic 

weed control (assume for 5 

species: hydrilla, European 

loosestrife, erasion water 

milfoil, melaluca, salt cedar) 

168 
Bell , F.W., and M.A. Bonn. 2004. “Economic 

Sectors at Risk from Invasive Aquatic Weeds at Lake Istokpoga, Florida.” The Bureau of Invasive Plant Management, Florida De-partment of Environmental Protection, Tallahassee, Florida. Available at http://www.aquatics.org/pubs/economics.htm 

Original analysis 

Economic value at risk from 

invasive aquatic weeds 

(primarily hydrilla) in a FL 

lake includes recreation, 

agriculture support, flood 

control and property values 

Drissoll, P & et al, The Effect of Aquatic Plants on Residential Shoreline Property Values at Gunterville Reservoir, Tennessee Valley Authority and U.S. Army Corps of Engineers, 1994 

Original analysis using a hedonic model to related property values to aquatic weed conditions (primarily hydrilla) 

Complete control of aquatic 

plants 

increased property values by 

17% for developed lots and 

35% for undeveloped 

properties 

Rockwell 2003, "Summary of a Survey of the Literature on the Economic Impact of Aquatic Weeds", August 2003. 

USAID, Economic Damage Caused by Aquatic Weeds, 1971 

Spending by Louisianna to 

control water hyacinth 

Rockwell 2003, "Summary of a Survey of the Literature on the Economic Impact of Aquatic Weeds", August 2003. 

USAID, Economic Damage Caused by Aquatic Weeds, 1971 

Annual losses in Louisianna 

due to water hyacinth in 

agriculture, drainage, fish 

and wildlife, navigation, and 

public health 

Rockwell 2003, "Summary of a Survey of the Literature on the Economic Impact of Aquatic Weeds", August 2003. 

Schmitz et al 1991 Spending by Florida for hydrilla control 

Carlton, "Introduced Species in US Coastal Waters", 2001 Various 

Federal and state spending 

on cordgrass control over 2 

fiscal years 

Horsch, E. J. and D. J. Lewis. The Effects of 

Aquatic Invasive Species on Property Values: Evidence from a Quasi-Random Experiment. University of Wisconsin-Madison Department of Agricultural & Applied Economics. AGRICULTURAL & APPLIED ECONOMICS STAFF PAPER SERIES. Staff Paper No. 530: November 2008. 

Original analysis 

Hedonic estimate of the 

change in property values 

for lakeside property after 

infestation with Eurasian 

Watermilfoil (milfoil) 

 

169 
170 

Regional Impacts of AIS 

Reference: Source: What is included in estimate? 

U.S. Army Corps of Engineers. Lake Tahoe Region Aquatic Invasive Species Management Plan, California - Nevada. 2009. 

Original analysis 

Average annual damages 

from AIS in the Lake Tahoe 

region in the categories of 

recreation, tourism, property 

values, water supply, 

boats/piers 
Appendix I Collection of Information for Compliance 

Extension Requests 

The final rule calls for new collection of information under the Paperwork Reduction Act 

(PRA) of 1995 (44 U.S.C. 3501-3520). As defined in 5 CFR 1320.3(c), "collection of 

information" comprises reporting, recordkeeping, monitoring, posting, labeling, and other, 

similar actions. The title and description of the information collections, a description of 

those who must collect the information, and an estimate of the total annual burden follow. 

The estimate covers the time for reviewing instructions, searching existing sources of data, 

gathering and maintaining the data needed, and completing and reviewing the collection. 

This new collection of information is due to the final rule provision that allows vessel owners 

and operators to request a compliance extension. 

The final rule’s new collection of information is a result of public comments received in the 

NPRM. In the final rule, we have included a paperwork provision to allow vessel owners 

and operators to request an extension of their compliance date if they cannot practicably 

comply with the compliance date otherwise applicable to their vessel. This extension 

provision will give flexibility to vessel owners and operators to comply with the rule. 

Summary information concerning all extension decisions, including the name of the vessel 

and vessel owner, the term of the extension, and the basis for the extension will be promptly 

posted on the U.S. Coast Guard Maritime Information Exchange website (CGMIX), currently 

located at [http://cgmix.uscg.mil/Default.aspx]. 

The Coast Guard is amending the existing collection of information (OMB CONTROL 

NUMBER: 1625-0069) to add the above mentioned requests for extension. 

TITLE: Ballast Water Management for Vessels with Ballast Tanks Entering U.S. Waters 

SUMMARY OF THE COLLECTION OF INFORMATION: The information is needed to 

carry out the requirements of 16 U.S.C. 4711 regarding the management of ballast water, to 

prevent the introduction and spread of aquatic nuisance species into U.S. waters. 

Respondents are owners and operators of certain vessels. The Coast Guard is amending the 

existing collection of information to include application for extensions as established in the 

final rule (33 CFR 151.1513 or 151.2036). 

NEED FOR INFORMATION: The Coast Guard may grant an extension to the 

implementation schedule only in those cases where the master, owner, operator, agent, or 

person in charge of a vessel subject to this subpart can document that, despite all efforts, 

compliance with the requirements of the final rule is not possible, giving flexibility to vessel 

owners and operators to comply with the final rule. 

Extension evaluations will be on a per-vessel basis. Summary information concerning all 

extension decisions, including the name of the vessel and vessel owner, the term of the 

extension, and the basis for the extension will be promptly posted on the Internet. Extensions 

will be for no longer than the minimum time needed, as determined by the Coast Guard, for 

171 
the vessel to comply with the requirements of § 151.2030. 

Any extension request must be made no later than 12 months before the scheduled 

implementation date listed in § 151.1512(b) of this subpart and submitted in writing to the 

Commandant (CG-522), U.S. Coast Guard Office of Operating and Environmental 

Standards, 2100 2nd St. SW., Stop 7126, Washington, DC 20593-7126. 

PROPOSED USE OF INFORMATION: The Coast Guard will use the information provided 

in the extension request to evaluate whether to grant extension and for what period of time, 

and to keep records of vessels not meeting the established compliance date. The compliance 

extension provides additional time to determine how BWMS can be safely installed. An 

extension postpones installation costs for affected vessels. 

DESCRIPTION OF THE RESPONDENTS: Vessel owners and operators subject to the 

requirements of this final rule (see section V.A.3. Applicability). 

NUMBER OF RESPONDENTS: We do not have information on the potential number of 

vessel owners and operators that will take advantage of the compliance extension at this time. 

We estimate that between 10 and 30 percent of owners and operators of U.S. vessels affected 

by the final rule might request the extension based on preliminary information from industry, 

BWMS vendors and Coast Guard experts. We anticipate that extension requests will be 

based on issues related to safety and regulatory requirements of electrical equipment, vessel 

capacity to accommodate BWMS, vessel age, shipyard availability, and other reasons. At 

this time, we do not have the data to determine the potential number of requests for 

extension. We expect to obtain this information as we process the requests. We will revise 

this collection of information as we post the requests on the website or as needed. 

We estimate that owners and operators of approximately 146 to 438 vessels (estimated total 

U.S. vessel affected by this rule is 1,459) might request compliance extensions for the 

reasons listed above. We estimate the total average number of vessels that will submit a 

request for extension to be 292. 

FREQUENCY OF THE RESPONSE: Vessel owners and operators will submit a 

compliance extension request once. 

BURDEN OF RESPONSE: We estimate that there could be an average of 292 existing 

vessels that could request an extension for installing a BWMS. The 292 is the total number 

of vessels estimated to request the extension. We estimate that the average time burden to 

prepare and submit a request is approximately 8 hours (6 hours management and 2 hours 

clerical)72 but burden may vary depending on type of vessel and reason for the extension 

request. The total average burden hours of vessels requesting an extension is approximately 

2,336 hours (292 vessels x 8 hours for completing and submitting the extension 

documentation). The total burden cost is $141,328, calculated by (a) + (b): 

 

72 This estimate is based on an existing collection of information (OMB Control Number 1625-0095) for 

requests of exemption and alternatives for Oil and Hazardous Materials Pollution and Safety Records 

Equivalent. 

172 
173 

 

(a) Assuming someone at a management level (equivalent to GS-12 (out-ofgovernment rate)) prepares the submission to the Coast Guard, the applicable 

wage rate is $69/hour73. Therefore, the total management cost for preparing the 

extension request is $69 x 6 hrs x 292 vessels = $120,888. 

(b) Assuming someone at the clerical level (equivalent to GS-5 (out-of-government 

rate)) files the copies, then the applicable wage rate is $35/hour74. Therefore, the 

total management cost for preparing the extension request is $35 x 2 hrs x 292 

vessels= $20,440. 

The estimated cost per vessel is $484 ($141,328/292 vessels). The total cost of the rule is not 

impacted by this paperwork provision. 

ESTIMATE OF TOTAL ANNUAL BURDEN: At this time, we do not have information on 

how many vessel owners and operators will be requesting compliance extension per year. 

We expect to obtain this information as we process the requests. If we assume that 10 

percent of the estimated owners of 292 vessels (see “BURDEN OF RESPONSE,” above) 

will be applying for an extension every year, then the annual burden will be equal to 

approximately 234 hours (29.2 vessels x 8 hrs or 10 percent of 2,336 hours). The annual cost 

will be approximately $14,132 (10 percent of $141,328). 

As required by the Paperwork Reduction Act of 1995 (44 U.S.C. 3507(d)), we will submit a 

copy of this rule to the Office of Management and Budget (OMB) for its review of the 

collection of information. 

We ask for public comment on the proposed collection of information to help us determine 

how useful the information is; whether it can help us perform our functions better; whether it 

is readily available elsewhere; how accurate our estimate of the burden of collection is; how 

valid our methods for determining burden are; how we can improve the quality, usefulness, 

and clarity of the information; and how we can minimize the burden of collection. 

If you submit comments on the collection of information, submit them both to OMB and to 

the Docket Management Facility where indicated under ADDRESSES, by the date under 

DATES. 

You need not respond to a collection of information unless it displays a currently valid 

control number from OMB. Before the Coast Guard could enforce the collection of 

information requirements in this rule, OMB would need to approve the Coast Guard’s request 

to collect this information. 

73 Wage rate obtained from Enclosure (2) to COMDTINST 7310.1M and validated based on the Bureau of 

Labor Statistics (BLS) subcategory Managers (Occupation Code 11-9199). 

74 Wage rate obtained from Enclosure (2) to COMDTINST 7310.1M and validated based on the Bureau of 

Labor Statistics (BLS) subcategory First-line Supervisor of office and Administrative Support Worker 

(Occupation Code 43-1011).