vyEPA
   United States
   Environmental Protection
   Agency
   Economic and Environmental Impact
   Analysis of the Proposed Effluent
   Limitations Guidelines and Standards for the
   Concentrated Aquatic Animal Production
   Industry

   September 2002

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                                          EPA-821-R-02-015
         Economic and Environmental Impact
               Analysis of the Proposed
     Effluent Limitations Guidelines and Standards
for the Concentrated Aquatic Animal Production Industry
                      September 2002

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                                      CONTENTS
                                                                                      Page
FIGURES  	vi

TABLES  	  vii


CHAPTER 1           INTRODUCTION                                               1-1

       1.1     Scope and Purpose  	1-1
       1.2     Data Sources  	1-2
       1.3     Report Organization  	1-4
       1.4     References  	1-5


CHAPTER 2           INDUSTRY PROFILE                                           2-1

       2.1     Public/Private Roles in Aquaculture  	2-2

              2.1.1     Federal 	2-2
              2.1.2     State	2-3
              2.1.3     Tribal and Others 	2-3
              2.1.4     Private Aquaculture	2-4
              2.1.5     Aquariums  	2-6
              2.1.6     Observations	2-6

       2.2     Geographic Distribution  	2-7

              2.2.1     Public	2-7
              2.2.2     Private  	2-8

       2.3     Major Species Produced  	2-18

              2.3.1     Public	2-18
              2.3.2     Private  	2-19
              2.3.3     Observations	2-26

       2.4     Economic Value 	2-29

              2.4.1     Public	2-29
              2.4.2     Private  	2-30
              2.4.3     Aquariums  	2-31

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      2.5     Organizational Structure	2-31

              2.5.1     Public: Government or Government Agency	2-34
              2.5.2     Nonprofit Organizations  	2-34
              2.5.3     Private  	2-37

      2.6     Employment	2-37

      2.7     Small Businesses	2-38

              2.7.1     Public	2-38
              2.7.2     Private  	2-38

      2.8     Market Structure	2-40

              2.8.1     Public	2-40
              2.8.2     Private  	2-41

      2.9     International Trade  	2-45

              2.9.1     Imports	2-46
              2.9.2     Exports	2-49
              2.9.3     Government Intervention	2-50

      2.10    References  	2-51
CHAPTER 3           EPA SCREENER SURVEY                                      3-1

      3.1     Survey Description	3-1

      3.2     Development of Survey Mailing List	3-1

      3.3     Response to the Screener Survey	3-2

      3.4     Summary  	3-2

      3.5     References  	3-3


CHAPTER 4           TECHNOLOGIES AND ENGINEERING COST ESTIMATES      4-1

      4.1     Model Facility Approach	4-1

      4.2     Technology Descriptions  	4-3

              4.2.1     Quiescent Zones 	4-3

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              4.2.2     Sedimentation Basins (Gravity Separation)  	4-4
              4.2.3     Solids Control Best Management Practices (BMP) Plan	4-6
              4.2.4     Compliance Monitoring	4-6
              4.2.5     Feed Management	4-6
              4.2.6     Drugs and Chemical Management	4-7
              4.2.7     Additional Solids Removal (Solids Polishing)	4-8
              4.2.8     Active Feed Monitoring	4-8

       4.3     Compliance Cost Estimation	4-9

       4.4     Frequency Factors	4-10

       4.5     References  	4-11


CHAPTER 5           ECONOMIC IMPACT METHODOLOGY                          5-1

       5.1     Facility Impacts  	5-1

              5.1.1     Revenue Test	5-1
              5.1.2     Alternative Approaches Considered	5-2
              5.1.3     Revenue Estimates for Non-Commercial Facilities	5-2
              5.1.4     Revenue Estimates for Alaskan Facilities	5-3

       5.2     Steps in the Facility Analysis	5-3

              5.2.1     Calculation of Annualized Costs for Individual Option Components	5-3
              5.2.2     Identification of Possible Facility Option Costs  	5-5
              5.2.3     Calculation of the Likelihood of a Facility Incurring Particular Costs .... 5-6
              5.2.4     Calculation of Facility Counts Showing Impacts at a Given Revenue
                        Test Threshold  	5-7
              5.2.5     Sample Calculation	5-8

       5.3     Industry Costs	5-9

       5.4     National Industry Compliance Costs	5-10

       5.5     Cost-reasonableness and BCT Cost Test	5-11

       5.6     References  	5-12
                                               in

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CHAPTER 6           REGULATORY OPTIONS: DESCRIPTIONS, COSTS,
                      AND CONVENTIONAL REMOVALS                           6-1

      6.1     Proposed Subcategories and Options	6-1

      6.2     Subcategory Costs  	6-1

      6.3     Cost of Proposed Options  	6-3

      6.4     Cost-Reasonableness	6-6

      6.5     Reference 	6-8


CHAPTER 7           ECONOMIC IMPACT RESULTS                               7-1

      7.1     Flow-Through Systems (BPT, BCT, BAT, and NSPS)	7-1

             7.1.1     BPTandBAT   	7-1
             7.1.2     BCT	7-4
             7.1.3     NSPS 	7-5

      7.2     Recirculating Systems  (BPT, BCT, BAT, and NSPS)	7-6

      7.3     Net Pen Systems (BPT, BCT, BAT, and NSPS)  	7-6

      7.4     Other Economic Impacts	7-7

             7.4.1     Firm-Level Impacts	7-7
             7.4.2     Community-Level Impacts	7-7
             7.4.3     Foreign Trade Impacts	7-8


CHAPTER 8           SMALL BUSINESS FLEXIBILITY ANALYSIS                  8-1

      8.1     Introduction  	8-1

      8.2     Initial Assessment	8-1

      8.3     Small Business Flexibility Analysis Components	8-2

             8.3.1     Need for Objectives of the Rule	8-3
             8.3.2     Small Entity Identification	8-4
             8.3.3     Description of the Proposed Reporting, Recordkeeping, and Other
                      Compliance Requirements	8-6
                                           IV

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              8.3.4     Identification of Relevant Federal Rules That May Duplicate,
                       Overlap, or Conflict with the Proposed Rule  	8-7
              8.3.5     Significant Regulatory Alternatives  	8-7

      8.4     Potential Impacts from  Promulgated Rule on Small Entities	8-12

              8.4.1     Small Facilities with 20,000 to 100,000 Pounds Annual Production	8-12
              8.4.2     Small Commercial Facilities  	8-13
              8.4.3     Nonprofit Organizations  	8-14

      8.5     Regulatory Flexibility Analysis	8-14

      8.6     References  	8-15
CHAPTER 9  ENVIRONMENTAL IMPACTS OF THE AAP INDUSTRY IN THE U.S.     9-1

      9.1     Introduction 	9-1

      9.2     Water Quality Impacts from Nutrients and Solids 	9-1

              9.2.1     AAP Industry Pollutant Loadings  	9-5
              9.2.2     Potential and Observed Water Quality Impacts  	9-8
              9.2.3     State Listings of Impaired Waters  	9-9

      9.3     Non-Native Species	9-15

              9.3.1     Impacts of Non-Native Species 	9-16
              9.3.2     Case Studies of Non-Native Species  	9-19

      9.4     Pathogens	9-26

      9.5     Drugs and Other Chemicals	9-26

      9.6     Other Potential Impacts	9-29

      9.7     References  	9-31


CHAPTER 10         ENVIRONMENTAL BENEFITS OF PROPOSED
                       REGULATION                                                10-1

      10.1    Introduction 	10-1

      10.2    Benefits Endpoints Evaluated  	10-2

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              10.2.1    Water Quality Standards and Nutrient Criteria	10-2
              10.2.2    Water Quality for Recreational Use	10-3

      10.3    Other Benefits Not Quantified	10-4

              10.3.1    Water Quality Benefits from Net Pen Loadings Reductions 	10-4
              10.3.2    Reductions in Escapements  	10-5
              10.3.4    Reductions in Drugs and Other Chemicals	10-5

      10.4    Benefits Modeling Approach	10-5

              10.4.1    Water Quality Modeling and "Prototype" Case Study  	10-6
              10.4.2    Extrapolation to National-Scale Impacts 	 10-15

      10.5    Estimated Water Quality Benefits  	 10-15

              10.5.1    Water Quality Standards and Nutrient Criteria	 10-15
              10.5.2    Recreational Use Value Benefits 	 10-16

      10.6    Unqualified Benefits 	 10-25

      10.7    References  	 10-25
CHAPTER 11          COST-BENEFIT COMPARISON AND UNFUNDED
                      MANDATES REFORM ACT ANALYSIS                       11-1

      11.1   Cost-Benefit Comparison 	11-1

      11.2   Unfunded Mandates Reform Act Analysis	11-2

             11.2.1    Background	11-2
             11.2.2    Potential Impacts on Non-Commercial Facilities  	11-4
             11.2.3    Summary  	11-5

      11.3   Reference  	11-5


APPENDIX A         INDUSTRY PROFILE SUPPORTING TABLES                  A-l

APPENDIX B         ENTERPRISE BUDGETS: LITERATURE SEARCH             B-l

APPENDIX C         PRODUCTION THRESHOLDS                                C-l

APPENDIX D         CALCULATION OF MUNICIPAL DOMESTIC
                      WASTELOAD EQUIVALENTS                                D-l
                                           VI

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APPENDIX E


APPENDIX F

APPENDIX G


APPENDIX H
LITERATURE REVIEW FOR AAP IMPACTS
ON WATER QUALITY                               E-l

WATER QUALITY STANDARDS AND NUTRIENT CRITERIA   F-l

WATER QUALITY AND FLOW DATA FROM
SELECTED STREAMGAGE STATIONS IN NC              G-l

METHOD FOR CONVERTING MODEL FACILITY
POLLUTANT LOADS INTO EFFLUENT CONCENTRATIONS   H-l
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                                         FIGURES
2-1      Number of Catfish Producing Facilities by State	2-9
2-2      Number of Trout Producing Facilities by State	2-10
2-3      Number of Food Fish Producing Facilities by State	2-11
2-4      Number of Mollusk and Crustacean Producing Facilities by State	2-12
2-5      Number of Other Aquatic Animal Producing Facilities by State  	2-13
2-6      Aquatic Animal Production by Pounds Sold: 1998  	2-22
2-7      Aquatic Animal Production by Value Sold: 1998  	2-23
2-8      United States Private Aquatic Animal Production By Weight 1985-1999	2-24
2-9      United States Private Aquatic Animal Production By Value 1985-1999	2-27
2-10     Value of U.S. Imports and Exports of Fishery Products 1989-2000 ($1 billion)	2-47

10-1     Example of QUAL2E output for simulated BOD concentrations downstream of a
         medium trout stockers flow-through facility on the "prototype" stream	  10-14
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                                          TABLES

Table

2-1      Tribal Hatcheries	2-5
2-2      Aquatic Animal Production Industry: Estimated Number of Facilities 	2-6
2-3      1998 Aquatic Animal Commercial Facilities	2-14
2-4      1998 Private Aquatic Animal Facilities Providing Stock or Eggs for Restoration
         or Conservation Purposes	2-16
2-5      Inland Trout Produced and Stocked by Number and Biomass	2-20
2-6      U.S. Private Aquaculture Production for 1985-1999: Growth in Time by
         Weight (1,000 Ibs)	2-25
2-7      U.S. Private Aquaculture Production for 1985-1999: Growth in Time by
         Value ($1,000 Nominal)	2-28
2-8      Number of Aquaculture Facilities by Revenue- United States 1998	2-32
2-9      Number of Farms by Revenue Category By Species	2-33
2-10     FY 1999 Revenue Sources	2-35
2-11     Small Business Size Standards	2-39
2-12     Sources and Uses of Aquaculture Species in the United States, 1998	2-42
2-13     Characteristics of Aquaculture Species Markets	2-43
2-14     Industry Concentration	2-44
2-15     2000 Imports and Exports of Selected Products ($1000)	2-48
2-16     2001 Imports and Exports of Selected Products ($1000)	2-49
2-17     "Catfish" Imports 1995-2001	2-50

4-1      Non-Alaska Model Facilities Unit Costs—Regulatory Option 1 	4-12
4-2      Non-Alaska Model Facilities Unit Costs—Regulatory Option 2 	4-14
4-3      Non-Alaska Model Facilities Unit Costs—Regulatory Option 3 	4-15
4-4      Alaska Facilities Unit Costs—Regulatory Option 1	4-16
4-5      Alaska Facilities Unit Costs—Regulatory Option 2	4-18
4-6      Alaska Facilities Unit Costs—Regulatory Option 3	4-19

5-1      Calculation of Sample Costs and Their Probabilities	5-9

6-1      Regulatory Options  	6-1
6-2      Option Costs by Subcategory ($2000)  	6-2
6-3      Flow-Through Systems: Cost by Annual Production ($2000) 	6-3
6-4      Estimated Pre-Tax Annualized Cost for Proposed Option
         (Screener Survey Facility Counts)  	6-5
6-5      Estimated Pre-Tax Annualized Cost for Proposed Option	6-6
6-6      Cost-reasonableness of Proposed BPT Options 	6-7
6-7      Nutrient Cost-effectiveness of Proposed Options	6-9

7-1      Flow-Through Systems: Facilities Showing Impacts at 3%, 5%, and 10% Revenue
         Test Thresholds	7-2
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Table                                                                                   Page

7-2      POTW Cost Test Calculations for Flow-Through Systems (100,000-475,000
         Pounds in Annual Production)  	7-5

8-1      Small Business Size Standards	8-5
8-2      Estimated Number of Facilities	8-13

8-3      Facilities with 20,000-1000,000 Pounds Annual Production Estimated Compliance
         Costs and Facilities Showing Impacts at 1% and 3% Revenue Test Thresholds	8-15

9-1      Example Raw Pollutant Concentrations for Flow-Through and Recirculating
         Model Facilities	9-6
9-2      Example Model Facility Raw Pollutant Loadings for Flow-Through and
         Recirculating Systems  	9-7
9-3      Impaired Water Bodies Where CAAP is Listed as a Source of Impairment  	9-10
9-4      Source of Impairment by Water Body Type 	9-11
9-5      Miles/Acres for Which CAAP is Listed as a Potential Source of Impairment	9-11
9-6      Comparison of Leading Pollutants Among Sources of Impairment 	9-13
9-7      Comparison of Sources of Impairment in Rivers and Streams (Miles)   	9-14
9-8      Comparison of Sources of Impairment in Lakes,  Reservoirs, and Ponds (Acres)  	9-14
9-9      Atlantic Salmon Escapements in Maine and Washington	9-20

10-1     Model Stream Background Concentrations	 10-10
10-2     Background Flow/Hydrology Scenarios Used in the Modeling	 10-10
10-3     Raw Effluent Concentrations for Flow-Through and Recirculating Systems  	 10-13
10-4     Effluent Flows	 10-14
10-5     Criteria and Values  	 10-19
10-6     Example of Application of Water Quality Index Use	 10-21
10-7     National Benefits from AAP Facility Regulatory Options When Applied
         to All Facilities  	 10-24
10-8     National Benefits from the Proposed Option	 10-24

11-1     Estimated Pre-Tax Annualized Compliance Costs and Monetized Benefits  	11-2

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                                         CHAPTER 1

                                     INTRODUCTION
1.1    SCOPE AND PURPOSE

       The U.S. Environmental Protection Agency (EPA) proposes and promulgates water effluent
discharge limits (effluent limitations guidelines and standards) for industrial sectors. This document
summarizes both the costs and economic impacts of technologies that form the bases for the proposed

limits and standards for the concentrated aquatic animal production (CAAP) industry and the change in
water quality and potential benefits associated with the proposed regulation.


       The Federal Water Pollution Control Act (commonly known as the Clean Water Act [CWA, 33

U.S.C. §1251 et seq. ]) establishes a comprehensive program to "restore and maintain the chemical,

physical, and biological integrity of the Nation's waters" (section 101 (a)). EPA is authorized under
sections 301, 304, 306, and 307 of the CWA to establish effluent limitations  guidelines and standards of
performance for industrial dischargers. The standards EPA establishes include:

        •       Best Practicable Control Technology Currently Available (BPT).  Required under section
               304(b)(l), these rules apply to existing industrial direct dischargers. BPT limitations are
               generally based on the average of the best existing performances by plants of various
               sizes,  ages, and unit processes within a point source category or subcategory.

        •       Best Available Technology Economically Achievable (BAT). Required under section
               304(b)(2), these rules control the discharge of toxic and nonconventional pollutants and
               apply  to existing industrial direct dischargers.

        •       Best Conventional Pollutant Control Technology (BCT). Required under section
               304(b)(4), these rules control the discharge of conventional pollutants from existing
               industrial direct dischargers.1   BCT replaces BAT for control of conventional pollutants.

        •       Pretreatment Standards for Existing Sources (PSES).  Required under section 307(b).
               Analogous to BAT controls, these rules apply to existing indirect dischargers (whose
               discharges flow to publicly owned treatment works [POTWs]).
(TSS),
material."
 1 Conventional pollutants include biochemical oxygen demand (BOD), total suspended solids
fecal coliform, pH, and oil and grease. EPA now measures oil and grease as "hexane extractable
d."
                                               1-1

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       •      New Source Performance Standards (NSPSY Required under section 306(b), these
               rules control the discharge of toxic and nonconventional pollutants and apply to new
               source industrial direct dischargers.

       •      Pretreatment Standards for New Sources (PSNSY Required under section 307(c).
               Analogous to NSPS controls, these rules apply to new source indirect dischargers (whose
               discharges flow to POTWs).


       Prior to this proposed rule, EPA defined "concentrated aquatic animal production facilities" at 40

CFR 122, Appendix C, and identified the need for them to obtain National Pollutant Discharge Elimination

System (NPDES) permits, but had not set  national effluent limitations guidelines or standards for these

dischargers.
1.2    DATA SOURCES


       EPA's economic analysis relied on a wide variety of data and information sources.  Data sources

used in the economic analysis include:


       •     EPA's Screener Questionnaire for the Aquatic Animal Production Industry (U.S. EPA,
              2001)

       •     U.S. Department of Agriculture (USDA; particularly the 1998 Census of Aquaculture,
              USDA, 2000)

       •     Joint Subcommittee on Aquaculture (JSA). JSA in an interagency statutory committee
              established by the National Aquaculture Act of 1980 to encourage the industry.

       •     Academic literature

       •     Industry journals

       •     General economic and financial references


The use of each of these major data sources is discussed in turn below.


       EPA collected facility-level production data from individual aquatic animal producers through a

screener survey administered under the authority of the CWA Section 308 (U.S. EPA, 2001).  EPA used

response  data from the screener survey to classify and subcategorize facilities by production method,
                                              1-2

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species produced and production level, and water treatment practices in place prior to the proposed
regulation.   EPA identified the subset of concentrated aquatic animal production facilities deemed to be in
scope of the proposed rule.

       EPA relied heavily on the USDA 1998 Census ofAquaculture to profile the industry (USDA,
2000).  EPA used the Census to identify the approximate number of aquaculture facilities in the U.S.,
their geographic distribution, species raised and production levels, and the distribution of facilities by
revenue classification.  EPA developed the production rate thresholds based on 1998 Census of
Agriculture data and the screener data that was available prior to proposal.  Six production size
categories, corresponding to the revenue classifications used in the 1998 Census of Agriculture (i.e.,
$l,000-$24,999; $25,000 - $49,999; $50,000 - $99,999; $100,000 - $499,999; $500,000 - $1,000,000; and
>$1,000,000) were used to group facility production data reported in the screener surveys. EPA used
national average product prices taken from the  1998 Census to estimate the production (in pounds) for the
dominant species that were reported grown in flow-through (e.g., trout salmon, tilapia),  recirculating (e.g.,
tilapia, hybrid striped bass), and net pen (e.g., salmon) systems.

       Based on revenues from aquaculture sales alone (not including other farm-related revenues from
other agricultural crops at the facility), more than 90 percent of the facilities have revenues less than
$0.75 million annually and thus may be considered small businesses.  The Small Business Administration's
(SBA) size standard is based on annual revenue at the company level for all products, so using facility
revenue from aquaculture sales reported in the  1998 Census ofAquaculture is likely to  over-estimate the
proportion of small businesses in the industry.  The Census data revenue category of $500,000 to
$1,000,000 spans the SBA size standard of $0.75 million for this industry.  USDA's National Agricultural
Statistics Service (NASS) provided a special tabulation of statistics (count, sum, mean, median, standard
deviation, and coefficient of variation) by species by revenue class where one of the revenue classes
corresponded to SBA size standard ($0.75  million and greater).

       JSA formed an Aquaculture Effluents Task Force to assist EPA. The Economics Subgroup
provided enterprise budgets, additional references, and articles to EPA.  An enterprise budget depicts
financial conditions for representative aquaculture facilities.  Enterprise budgets are useful tools for
examining the potential profitability of an enterprise prior to actually making an investment.  To create an
enterprise budget, an analyst gathers information on capital investments, variable costs (such as labor
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and feed), fixed costs (e.g., interest and insurance), and typical yields and combines it with price
information to estimate annual revenues, costs and return for a project.  By varying different input

parameters, enterprise budgets can be used to examine the relative importance of individual parameters to

the financial return of the project or to identify breakeven prices required to provide a positive return.

The Economics Subgroup of the JSA/AETF provided EPA with enterprise budgets for trout, shrimp, hard

clams, prawns, and alligators.


       EPA used academic journals and industry sources such as trade journals and trade associations to

develop its industry profile, to formulate a better understanding of industry changes, trends, and concerns.

As necessary, EPA cites various economic and financial references used in its analysis throughout the

EA.  These references may be in the form of financial and economic texts, or other relevant sources of

information germane to the impact analysis.
1.3    REPORT ORGANIZATION
       This report is organized as follows:
               Chapter 2—Industry Profile. Provides background information on the CAAP industry.

               Chapter 3—EPA's Screener Questionnaire for the Aquatic Animal Production Industry.
               Provides information from EPA's screener survey and focuses on the facilities EPA
               determined to be within the scope of the proposed rule.

               Chapter 4—Engineering Cost Methodology. Summarizes the engineering cost models
               and assumptions; a precis of the Development Document accompanying the proposal
               (U.S. EPA, 2002).

               Chapter 5—Economic Impact Methodology. Summarizes the methodology by which
               EPA examines incremental pollution control costs and their associated economic impacts.

               Chapter 6—Regulatory Options: Descriptions, Costs, and Conventional Pollutant
               Removals. Presents short descriptions of the regulatory options considered by EPA.
               More detail is given in the Development Document (U.S. EPA, 2002).

               Chapter 7—Economic Impacts.  Using the methodology presented in Chapter 5, EPA
               presents the economic impacts associated with the compliance costs, including impacts on
               commercial and non-commercial facilities.
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              Chapter 8—Small Business Analysis. Pursuant to the Regulatory Flexibility Act as
              amended by the Small Business Regulatory Enforcement Fairness Act, EPA examines
              whether the regulatory options have a significant adverse impact on a substantial number
              of small entities.

              Chapter 9—Environmental Impacts. Summarizes the issues examined by EPA regarding
              water quality impacts from nutrients and solids, ecological impacts, aquatic nuisance
              species, pathogens, drugs, and other potential impacts.

              Chapter 10—Environmental Benefits. Summarizes the methodology by which EPA
              identifies, qualifies, quantifies, and—where possible—monetizes the benefits associated
              with reduced pollution from implementing the proposed rule.

              Chapter 11—Cost-Benefit Comparison and Unfunded Mandates Reform Act Analysis.
              Using the benefits described in Chapter 10, EPA presents an assessment of the
              nationwide costs and benefits of the regulation pursuant to Executive Order 12866 and
              the Unfunded Mandates Reform Act (UMRA).
1.4    REFERENCES
USDA.  2000.  United States Department of Agriculture. National Agricultural Statistics Service.  1998
Census  ofAquaculture. Also cited as 1997 Census of Agriculture.  Volume 3, Special Studies, Part 3.
AC97-SP-3. February.

USDA,NASS. 2002.  Special tabulation request submitted to USDA NASS. Information relayed to
EPA and Eastern Research Group, Inc.  March 6.

U.S. EPA.  2002. Development Document for the Proposed Effluent Limitations Guidelines and
Standards for the Aquatic Animal Production Industry. EPA-821-R-02-016. Washington, DC: U.S.
Environmental Protection Agency, Office of Water.

U.S. EPA.  2001. United States Environmental Protection Agency.  Screener Questionnaire for the
Aquatic  Animal Production Industry. Washington, DC: OMB Control No. 2040-0237. Expiration Date
July 26, 2004.
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                                         CHAPTER 2

                                   INDUSTRY PROFILE

       Aquaculture is broadly defined as the farming or husbandry offish, shellfish, and other aquatic
animals and plants, usually in a controlled or selected environment (Becker and Buck, 1997). EPA is
developing effluent limitations guidelines and standards for concentrated aquatic animal production
facilities, that is, plant production facilities are not included. In this chapter, the term "aquaculture" has
both the extended (aquatic animal and plant) and limited (aquatic animal only) meanings, depending on the
context of the word.

       An industry profile provides background information necessary to understand and characterize the
industry being examined.  When completed, it develops a baseline against which to evaluate the economic
impacts to the industry as a result of compliance with any proposed requirements developed by the
Agency.  This chapter briefly describes the range in the entire U.S.  aquatic animal production industry.
The commercial sector, alone, produced nearly $1  billion in goods in 1998 (USDA, 2000a). The remainder
of this document focuses on the subset of concentrated aquatic animal production facilities that EPA
considers within the scope of the proposed effluent guideline.

       The aquatic animal production industry is  one marked by substantial public as well as private
activity. This chapter begins with a general discussion of the government and private roles in aquaculture.
The economic characteristics of the owner/operator of a production system vary greatly depending on
whether it is a non-commercial or commercial venture.  Hence, each of the subsequent
sections—geographic distribution of facilities, the major species produced, economic value of production
organizational structure, small entity definitions, market structure, and international trade—discusses
public and private operations separately.  Large supporting tables are located in Appendix A.
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2.1    PUBLIC/PRIVATE ROLES IN AQUACULTURE

       2.1.1   Federal

       The National Aquaculture Act of 1980 provides for a national policy to encourage the domestic
aquaculture industry and established the interagency Joint Subcommittee on Aquaculture (JSA).  JSA is a
statutory committee that reports to the National Science and Technology Council (NSTC) committee on
science. NSTC, in turn, operates under the White House Office of Science and Technology Policy.l

       The United States Department of Agriculture (USDA), the Commerce Department, and the
Interior Department all have roles in the aquaculture industry. USDA focuses primarily on private
aquaculture production, while the other two agencies concentrate more on public aquaculture production
for recreational fishing and ecosystem restoration.  JSA serves as a federal government-wide
coordinating group among these and other  agencies.

       The Agriculture and Food Act of 1981 authorized USDA to establish regional aquaculture
research centers (Title XIV, P.L. 97-98).2  USDA also collects information (Economic Research Service,
National Agricultural Statistics Service), provides assistance under farm lending programs and the
Commodity Credit Corporation (CCC) credit guarantee programs, and promotes exports through the
market access program.

       Two branches within the Commerce Department's National Oceanic and Atmospheric
Administration are concerned with aquaculture activities—the National Marine Fisheries Service
(NMFS) and the National Sea Grant College Program. NMFS administers the Saltonstall-Kennedy grant
program to fund research related to the harvesting, processing, and marketing of fisheries products.
NMFS also supports four regional Fisheries Science Centers3 to help restore depleted fish stocks and
       'This description is based on Becker and Buck, 1997.
       2University of Massachusetts, Mississippi State University, Michigan State University, the
University of Washington, and the Oceanic Institute (Hawaii).
       Southeast (Galveston, TX), Northwest, Northeast, and Alaska.
                                              2-2

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establish sustainable fisheries.  The National Sea Grant Program funds aquaculture research projects at
universities.

        The Interior Department's Fish and Wildlife Service (FWS) operates a system offish hatcheries
and conducts fish research.  Among its roles and responsibilities, FWS operates six Fish Technology
Centers4 for developing fish culture techniques and recovering endangered species and nine Fish Health
Centers for research. FWS also operates the 66-facility National Fish Hatchery System to conserve,
restore, enhance, and manage the Nation's fishery resources and ecosystems for the benefit of future
generations. Table A-l  lists the FWS facilities  (FWS, 2000a-c).
        2.1.2   State

        Every state has an agency to administer state natural resources, including fisheries. Many states
operate fish hatcheries for stocking recreational fisheries. FWS maintains a memoranda of understanding
with state fisheries to manage resources on U.S. Forest Service lands within the state (Epifanio, 2000).
FWS distributes some of its hatchery production to various states.  Many states have agreements with
other states and Tribal governments to enable interjurisdictional management of shared resources.  Based
on Epifanio (2000) and individual state websites, EPA identified 369 coldwater propagation facilities
nationwide and 53 warmwater hatcheries in 15 states (see Table A-2). EPA identified a total of 53
warmwater facilities in 15 states. An additional 78 facilities in 12 states could not be classified as
coldwater or warmwater because they did not report which species are being raised.  The number of
warmwater state hatcheries, then, ranges from 53 to 131.
        2.1.3   Tribal and Others

        Tribal hatcheries support Indian communities' needs and desires for a healthy and abundant
fishery for subsistence and cultural heritage.  These hatcheries may be funded by the Bureau of Indian
        4Abernathy, WA; Bozeman, MT; Dexter and Mora, NM; Lamar, PA; San Marcos, TX; and
Warm Springs, GA (including the Bear's Bluff, SC field station).
                                               2-3

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Affairs or the tribal entity (WDNR, 2000). Table 2-1 lists the 17 tribal programs EPA has identified to
date. The academic community is very active in aquaculture, with more than 80 institutions that have
programs in fisheries, fishing, or fish and game management nationwide (see Table A-3). USDA funds
regional aquaculture research centers, while NOAA administers its Sea Grant program to multiple
institutions.
       2.1.4   Private Aquaculture

       Aquaculture's growing economic importance is marked by the 1998 Census of Aquaculture
(USDA, 2000a). The USDA National Agricultural Statistics Service (NASS) determined that there was
a need for a comprehensive snapshot of all aquatic species produced throughout the 50 states and U.S.
Territories. The respondent universe for the Census is all farms identified as having sales of $1,000 or
more from aquaculture products (USDA, 1998a).5 As such, the production and revenues from aquatic
animals represent a range from some to all of the commercial activities at the facility.  The absence of
total facility revenues affects the estimates of the number of small businesses in the industry, as discussed
in Section 2.7 below.

       The 1998 Census forms the basis for the description of commercial activities in this chapter.
USDA identified 4,028 facilities that raise aquaculture products, including 20 that raise aquatic vegetables.
USDA provided a breakout of facilities by species (e.g., catfish) or groups of related species (e.g.,
mollusks). Because a facility can raise more than one species, the sum of these individual listings totals
about 4,800 operations.
       5Form OMB 83-1 (Paperwork Reduction Act Submission) box 11 for the 1998 Census identifies
the affected public as "farms;" the categories for not-for-profit, federal government, and state, local, or
tribal governments are not marked.  However, when contacted, USDA mentioned that the survey
included commercial and non-commercial facilities but, for the most part, the sales tables do not include
noncommercial data (Lang, 2000).
                                              2-4

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                                         Table 2-1
                                      Tribal Hatcheries
Tribal Program
Bad River
Keweenaw Bay
Lac Courte Orielles
Lac du Flambeau
Lac Vieux Desert
Leech Lake
Menominee
Nunns Creek
Red Cliff
Red Lake
Sokaogon
St. Croix
White Earth
Nez Pierce
Cherokee
Navajo Nation
Fort Hall Shoshone-Bannock
State(s)
WI
MI
WI
WI
MI
MN
WI
MI
WI
MI
WI
WI
MI
ID
OK
AZ, NM, UT
ID
Annual Distributions
8,000-10,000 walleye fmgerlings
10-14 million walleye fry
100,000 lake trout yearlings
25,000 brook trout yearlings
7 million walleye eggs
140,000 walleye
~14 million walleye fry
160,000 walleye fmgerlings
also muskellunge, bass, and trout
1.3 million walleye eggs
8-10 million walleye fry
50,000 walleye fmgerlings
400,000 lake whitefish fmgerlings
20 million white sucker eggs
walleye rearing station
400,000 fmgerling capacity
2-3 million walleye eggs
800,000 walleye fmgerlings
trout and walleye rearing station
capacity for 75 million walleye
eggs; walleye and northern pike
1993 production (under
reconstruction)
3 million walleye eggs
2 million walleye fry
walleye
200,000 walleye fmgerlings




Sources: FWS, 2000c; FWS, 2000d.
                                            2-5

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       2.1.5   Aquariums

       EPA initially considered aquariums as part of the aquatic animal production industry. Through an
Internet search, EPA identified approximately 50 aquariums in the United States (seeTable A-4).
Aquariums are part of North American Industry Classification System (NAICS) code 712130. There is
no further breakdown of this code.  Included in this code are: Animal exhibits, live; Animal safari parks;
Aquariums; Arboreta; Aviaries; Botanical gardens; Conservatories, botanical; Gardens, zoological or
botanical; Petting zoos; Reptile exhibits, live; Wild animal parks; Zoological gardens; and Zoos. Census
data identify 269 non-taxable and 117 taxable establishments in this NAICS code (Census, 2001a and b).
The upper bound count for aquariums, then, is 386 establishments.
       2.1.6   Observations

       Table 2-2 summarizes the estimated facility counts for each of the groups described above.
There are between 4,600 to 6,000 facilities within the Agency's definition of the industry.
                                           Table 2-2
              Aquatic Animal Production Industry: Estimated Number of Facilities
General Category
Federal Hatcheries/Centers
State Hatcheries
Tribal
Academic/research
Private/commercial
Aquariums
Total
Estimated Number of Facilities
Lower
90
422
17
80
4,028
50
4,687
Upper
90
500
17
80
4,800
386
5,873
Source: EPA estimates based on information presented in Section 2.1.
                                              2-6

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2.2     GEOGRAPHIC DISTRIBUTION

        2.2.1   Public

        FWS operates 66 hatcheries, nine fish health centers, and six fish technology centers in 37 states6
while USDA funds five regional aquaculture research centers located in Hawaii, Massachusetts,
Michigan, Mississippi, and Washington.

        A survey of state coldwater fisheries (Epifanio, 2000) found that all but three states—Florida,
Mississippi, and Louisiana—actively manage coldwater species.7 The survey results report 369 coldwater
propagation facilities nationwide, with the state of Washington having the largest number (90).

        EPA compiled a partial list of state warmwater hatcheries (see Table A-4). EPA identified a
total of 53 warmwater facilities in 15 states.  An additional 78 facilities in 12 states could not be classified
because they did not report which species are being raised (i.e., they may include trout and salmon
facilities).

        The information provided in Table A-3 indicates that there is at least one academic institution with
some type of fisheries-related program in 46 states, potentially operating an aquaculture facility.8

        In sum, EPA believes that every state has at least one public aquaculture facility.
        6 States without FWS facilities are: Alabama, Alaska, Connecticut, Delaware, Hawaii, Illinois,
Iowa, Kansas, Maryland, Minnesota, Nebraska, Ohio, and Rhode Island.
        7Indiana did not respond to the survey, hence it does not appear in any of these discussions or
tables.
        Connecticut, Nevada, Oklahoma, and Utah are the exceptions.
                                                2-7

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        2.2.2  Private

        The 1998 Census ofAquaculture identified a total of 4,028 private facilities with aquaculture
production.  Figures 2-1 through 2-5 identify the number of production facilities by state for different
species breakdowns. Figure 2-1 illustrates the 1,370 catfish producing facilities (which account for over
30 percent of the total aquaculture facilities) by state. Note that the heaviest concentrations are in
Alabama and Mississippi (with a combined total of 654 facilities), with Arkansas and Louisiana having the
next heaviest concentration with 156 and 100 facilities respectively.  Another 561 facilities raise trout (see
Figure 2-2), with North Carolina having the heaviest concentration of facilities (70). Figure 2-3 identifies
the 435 facilities that produce food fish (other than catfish or trout); Maryland and Wisconsin have a
combined total of 65 facilities.  Louisiana dominates crustacean production with nearly 500 crawfish
facilities (out of a nationwide total of 837 crustacean facilities), Virginia has 206 of 218 softshell crabs
facilities and 33 mollusk facilities, while Florida accounts for 221 of the total 535 mollusk producing
facilities (see Figure 2-4). Figure 2-5 illustrates the geographic distribution of other aquatic animal
production facilities.9  A facility that produces more than one type of aquatic animal product is listed under
each of the species produced; hence, summing the total facilities by individual species exceeds the 4,028
facility total for the industry.  Table 2-3 summarizes the geographic distribution of aquaculture facilities in
tabular form. The importance of aquaculture to the southern states is evident; this region is home to two-
thirds of the aquaculture facilities in the nation.  However, every state has at least one aquatic animal
production facility, with several states having marked concentrations, depending on the species.

        As shown in Table 2-4, nearly 30 percent of the facilities in the 1998 Census report provide fish
and/or eggs for restoration or conservation purposes. Salmon is the largest category with 288 million
pounds provided (USDA, 2000a).
        9Including baitfish, ornamental fish (171 facilities in FL), sport or game fish, turtles (51 of 56
facilities in LA), alligators, and frogs.

-------
                                                   Figure 2-1
                                  Number of Catfish Producing Facilities By State
                                                                                            DO
                                                                                               1-45
                                                                                               46-90
                                                                                               91-135
                                                                                               136-180
                                                                                               180 and more
Source: USDA, 2000a.
                                                       2-9

-------
                                                Figure 2-2
                                Number of Trout Producing Facilities By State
Source: USDA, 2000a.
                                                   2-10

-------
                                               Figure 2-3
                             Number of Food Fish Producing Facilities By State
Source: USDA, 2001 a.
                                                  2-11

-------
                                                 Figure 2-4
                        Number of Mollusk and Crustacean Producing Facilities By State
Source: USDA, 2000a.
                                                    2-12

-------
                                               Figure 2-5
                        Number of Other Aquatic Animal Producing Facilities By State
Source: USDA, 200la.
                                                  2-13

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               Table 2-3




1998 Aquatic Animal Commercial Facilities
Total Number Number of Number of
of Aquatic Number of Number of Number of Crustacean All Other
Animal Trout Catfish Food Fish Mollusk Aquatic Animal
Producing Producing Producing Producing Producing Producing
Facilities Facilities Facilities Facilities* Facilities Facilities
United States
Northeastern
Region
Connecticut
Delaware
Maine
Maryland
Massachusetts
Mew
Hampshire
Mew Jersey
New York
Pennsylvania
Rhode Island
Vermont
West Virginia
Southern
Region
Alabama
Arkansas
Florida
Georgia
Kentucky
Louisiana
Mississippi
North Carolina
Oklahoma
South Carolina
Tennessee
Texas
Virginia
North Central
Region
Illinois
Indiana
4106
465

24
3
56
40
115
9
33
79
65
3
7
31
2719

271
238
429
90
34
604
418
145
27
25
45
95
298
488

32
35
561
132

6
0
9
4
8
5
2
30
38
0
7
23
136

0
1
1
11
3
0
1
70
1
0
12
1
35
137

3
3
1370
24

0
0
0
7
0
1
2
4
5
0
0
5
1152

250
156
21
55
20
100
404
36
13
13
25
51
8
112

15
9
435
81

1
5
12
31
2
1
5
11
6
0
0
7
132

14
20
19
6
2
7
15
13
2
5
0
13
16
116

3
11
1372
172

15
0
16
9
97
0
18
12
3
2
0
0
1035

6
1
227
1
5
498
3
20
2
11
1
17
243
22

1
5
803
137

3
3
31
20
10
3
11
33
19
1
0
3
396

15
80
180
23
6
6
10
19
11
1
7
26
12
217

13
18
                 2-14

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                                              Table 2-3 (cont.)
Total Number Number of Number of
of Aquatic Number of Number of Number of Crustacean All Other
Animal Trout Catfish Food Fish Mollusk Aquatic Animal
Producing Producing Producing Producing Producing Producing
Facilities Facilities Facilities Facilities* Facilities Facilities
Iowa
Kansas
Michigan
Minnesota
Missouri
STebraska
North Dakota
Ohio
South Dakota
Wisconsin
Western
Region
Arizona
California
Colorado
Idaho
Montana
Nevada
New Mexico
Oregon
Utah
Washington
Wyoming
Alaska
Hawaii
17
36
64
32
67
27
0
60
8
110
371

12
121
37
36
10
2
4
38
18
84
9
20
43
2
2
34
5
10
10
0
8
5
55
156

4
22
27
33
10
1
1
21
15
16
6
0
0
5
14
12
0
35
4
0
10
1
7
66

5
51
3
2
0
1
1
2
0
1
0
0
16
4
8
7
17
4
5
4
15
4
34
54

6
20
6
6
0
0
3
3
0
9
1
19
33
0
5
0
0
3
2
0
5
0
1
96

1
18
1
1
0
0
0
10
1
64
0
20
27
10
15
18
27
19
11
0
37
2
47
53

2
30
6
0
0
0
2
5
2
3
3
0
0
*Food fish category excludes trout and catfish.
Grand total exceeds 4,028 facilities because a facility may produce in more than one category.
Source:  USDA, 2000a.
                                                   2-15

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                                            Table 2-4




1998 Private Aquatic Animal Facilities Providing Stock or Eggs for Restoration or Conservation Purposes
Total Number Number of Number of
of Aquatic Number of Number of Number of Crustacean All Other
Animal Trout Catfish Food Fish Mollusk Aquatic Animal
Producing Producing Producing Producing Producing Producing
Facilities Facilities Facilities Facilities* Facilities Facilities
United States
Northeastern
Region
Connecticut
Delaware
Maine
Maryland
Massachusetts
Mew
Hampshire
Mew Jersey
New York
Pennsylvania
Rhode Island
Vermont
West Virginia
Southern
Region
Alabama
Arkansas
Florida
Georgia
Kentucky
Louisiana
Mississippi
North Carolina
Oklahoma
South Carolina
Tennessee
Texas
Virginia
North Central
Region
Illinois
Indiana
1176
196

15
1
19
15
38
11
8
28
32
5
10
14
211

9
23
8
25
9
23
3
9
19
0
49
13
24
367

5
33
362
70

4
0
10
3
6
6
1
10
14
3
4
9
32

0
5
0
4
1
0
0
4
1
0
11
1
5
81

0
7
113
6

0
0
0
2
1
0
1
0
1
0
0
1
48

3
6
2
7
1
2
2
1
6
0
10
5
3
52

1
7
470
57

3
1
6
3
2
4
1
15
11
2
6
3
66

3
7
3
8
3
3
0
3
7
0
18
4
7
159

1
13
75
44

8
0
2
3
28
0
2
0
1
0
0
0
23

0
0
0
0
0
16
0
0
0
0
0
1
6
2

1
0
156
19

0
0
1
4
1
1
3
3
5
0
0
1
42

3
5
3
6
4
2
1
1
5
0
10
2
3
73

2
6
                                              2-16

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                                           Table 2-4 (cont.)
Total Number Number of Number of
of Aquatic Number of Number of Number of Crustacean All Other
Animal Trout Catfish Food Fish Mollusk Aquatic Animal
Producing Producing Producing Producing Producing Producing
Facilities Facilities Facilities Facilities* Facilities Facilities
Iowa
Kansas
Michigan
Minnesota
Missouri
STebraska
North Dakota
Ohio
South Dakota
Wisconsin
Western
Region
Arizona
California
Colorado
Idaho
Montana
Nevada
New Mexico
Oregon
Utah
Washington
Wyoming
Alaska
16
7
10
170
24
4
10
30
12
46
371

0
35
31
56
23
11
11
61
15
115
13
28
3
0
7
28
5
0
2
7
4
18
179

0
18
18
29
11
6
7
31
12
36
11
0
1
4
1
27
5
1
0
5
0
0
7

0
0
2
1
1
1
0
0
0
2
0
0
7
2
0
85
8
0
5
11
6
21
160

0
15
9
24
7
3
3
29
1
67
2
28
0
0
0
1
0
0
0
0
0
0
6

0
0
0
0
0
0
0
0
0
6
0
0
5
1
2
29
6
3
3
7
2
7
19

0
2
2
2
4
1
1
1
2
4
0
0
*Food fish category excludes trout and catfish.
Source: USDA, 2000a.
                                                 2-17

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2.3     MAJOR SPECIES PRODUCED

        2.3.1  Public

        The U.S. Fish and Wildlife Service provided their 1999 fish and fish egg distribution data (FWS,
2000d). In 1999, the National Fish Hatchery system made over 5,500 distributions of over 50 species to
federal, Tribal, state, and local governments; universities; and private entities. Tables A-5 and A-6
summarize the egg and fish distribution respectively. Egg distributions totaled 146 million, most of which
were walleye (36 percent) and rainbow trout (26 percent).  These eggs were distributed to the following
programs:

        •      Federal—59.4 million (41 percent)
        •      State and Local—81.7 million (56 percent)
        •      Tribal—4.8 million (3 percent)
        •      Universities—0.5 million (less than one percent)

A minuscule amount (less than 0.02 percent) was distributed to private entities. (Percentages do not sum
to 100 because of rounding.)

        Fish distributions from National Fish Hatcheries totaled 5.5 million pounds, most of which were
rainbow trout (40 percent) and steelhead trout (15 percent).  These fish were distributed to the following
programs:

        •      Federal—4.2 million  (77 percent)
        •      State and Local—0.7  million (13 percent)
        •      Tribal—0.5 million (9 percent)

A small amount (less than 0.2 percent) were distributed to private entities, and universities received about
0.03 percent.
                                               2-18

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        Epifanio (2000) lists the 1996 production of trout and salmon from state hatcheries at 23.7 million
pounds (see Table 2-5). Most of the state hatcheries for fish other than trout or salmon report releases in
terms of the number of fish, not necessarily by weight. Assuming roughly a sixth of a pound per stocked
fish,10 the information in Table A-2 indicates that approximately another 3.8 to 79 million pounds of
warmwater fish may be produced at state hatcheries.

        Tribal production is at least 1.3 million fish (see Table 2-1).  This may be relatively small in
relation to nationwide public or private aquaculture, but extremely important in terms of cultural and
religious significance and issues related to fishing rights.

        EPA identified no estimates for aquaculture production at academic and research institutions.
EPA intends to request this information as part of its detailed questionnaire for the aquatic animal
production industry.
        2.3.2   Private

        Figures 2-6 and 2-7 illustrate the distribution of private aquatic animal production by weight and
sales, respectively.  Catfish accounts for 68 percent of the total pounds sold and 48 percent of the total
value produced.  Trout accounts for nearly nine percent of the total pounds sold and eight percent of the
total value. The relatively high value per pound for mollusks and crustaceans is evident; they account for
only five percent of the total pounds produced but account for 13 percent of the total value.  Ornamental
fish are included in the "all other aquatic animals" category.  The specialized crop is less than one percent
of production but accounts for 12 percent of the total value.

        Aquaculture production has shown a marked increase over the 1985-1997 time period (JSA,
2002).  Figure 2-8 and Table 2-6 track the production increase in terms of weight.  Catfish is the primary
commodity, with production more than doubling from 207 million pounds in 1985 to 600 million pounds in
1999. Clam production increased from 1.6 million pounds to 10.7 million pounds in 1999. Salmon
        10Epifanio (2000) reports 136,774,388 trout stocked with an associated biomass of 23,676,004
pounds or, roughly, six trout to a pound.
                                               2-19

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                      Table 2-5
Inland Trout Produced and Stocked by Number and Biomass
State
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Maine
Maryland
Massachusetts
Michigan
Minnesota
Missouri
Montana
Nebraska
Total Trout
Stocked (no.)
27,738
1,966,646
2,970,000
2,600,000
15,357,977
13,098,073
857,317
30,900
1,438,742
20,000
11,575,197
342,100
55,015
438,598
94,203
753,950
1,203,974
600,000
664,525
2,175,192
1,596,689
1,754,500
8,780,317
472,586
Total Trout
Biomass (Ibs)
11,524
68,103
446,220
788,000
3,895,234
1,603,085
334,000
16,200
472,297
NA
1,244,872
80,000
24,394
208,853
NA
251,317
243,107
250,000
505,502
215,789
142,907
1,209,600
311,193
115,521
Catchables
Stocked
(no.)
27,738
245,014
1,200,000
2,100,000
7,041,978
3,609,934
669,000
39,900
1,278,792
10,000
2,492,177
121,800
55,015
370,848
94,203
718,800
639,136
500,000
664,525
7,159
408,117
1,754,500
145,116
313,607
Catchables
Biomass
(Ibs)
11,524
52,952
428,500
636,000
3,722,575
1,432,394
321,000
16,200
465,810
NA
908,733
60,500
24,393
207,178
NA
239,600
186,423
200,000
505,502
7,779
72,999
1,209,600
48,179
112,000
                        2-20

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                                           Table 2-5 (cont.)
State
Nevada
New Hampshire
New Jersey
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Totals
Total Trout
Stocked (no.)
1,971,841
1,671,084
758,310
5,332,865
698,826
372,667
363,939
483,936
7,318,486
7,929,747
188,400
418,288
650,000
1,917,498
348,093
10,137,544
1,163,938
1,541,151
15,770,000
1,505,667
1,310,675
6,47,194
136,774,388
Total Trout
Biomass (Ibs)
487,784
438,382
262,000
889,127
286,426
68,202
34,991
NA
887,069
2,701,158
155,880
132,518
128,700
516,324
70,036
941,788
185,483
731,766
1,169,200
748,942
NA
402,510
23,676,004
Catchables
Stocked
(no.)
1,613,000
938,130
687,205
3,535,007
612,747
75,431
32,104
408,871
3,428,752
5,216,110
137,400
273,248
174,600
1,129,431
209,862
1,865,721
612,859
1,267,054
3,517,000
1,186,311
666,800
744,246
52,850,248
Catchables
Biomass
(Ibs)
474,194
426,701
254,000
9
285,351
41,031
18,668
NA
825,478
2,543,015
154,100
91,028
88,440
486,004
69,954
712,948
173,448
686,170
939,900
743,045
NA
203,356
20,086,672
Note:   Indiana did not reply to the survey. Data for New Mexico not included.  Florida, Mississippi and Louisiana
        do not actively manage cold water species.

Source:  Epifanio, 2000.
                                                  2-21

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                                                         Figure 2-6
                                    Aquatic Animal Production by Pounds Sold: 1998
                                  68.2%
                                                                                    18.3%
                                                  i.6%
                                                                                     Catfish
                                                                                     Trout
                                                                                     Foodfish
                                                                                    1 Mollusks and Crustaceans
                                                                                    ] All other aquatic animals
Source: USDA, 2000a.
                                                            2-22

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                                                          Figure 2-7
                                      Aquatic Animal Production by Value Sold: 1998
                                 18.1%
                                                         48.4%
                                                                           13.5%
                                                                                                 12.3%
                                                                                     | Catfish
                                                                                      Trout
                                                                                      Foodfish
                                                                                      Mollusks and Crustaceans
                                                                                      All other aquatic animals
Source: USDA, 2000a.
                                                             2-23

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                                                            Figure 2-8
                          United States Private Aquatic Animal Production By Weight 1985-1999
       800
       600
          1984     1985
                                       1988    1989    1990    1991
                                                                   1992

                                                                   Year
                                                                           1993     1994     1995     1996    1997    1998    1999    2000
All Species
Catfish
                                                      " Crawfish
                                                       Catfish & Crawfish
                                                                      -0- Trout  A Catfish, Crawfish & Trout
Source: JSA, 2002.
                                                               2-24

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                                                                    Table 2-6

                                               U.S. Private Aquaculture Production for 1985-1999
                                                      Growth in Time by Weight (1,000 Ibs)
Species
Non-
food1
Catfish
Clams
Craw
fish
Fresh
water
Prawns
Mussels
Oysters
Salmon
Shrimp
Trout
Other
Species
Total
1985
24,807
206,945
1,600
65,300
267
800
20,700
	
440
52,000
14,000
386,859
1986
25,247
230,856
2,500
68,400
178
1,000
21,100
	
1,354
54,000
15,500
420,135
1987
27,000
302,936
3,500
71,600
150
950
23,100
	
1,500
55,000
20,000
505,736
1988
28,000
318,718
4,000
67,000
250
1,200
17,900
	
2,500
56,000
22,000
517,568
1989
30,000
369,252
4,200
72,400
250
1,100
18,300
	
2,500
56,100
22,000
576,102
1990
20,000
392,429
6,100
61,100
250
1,000
16,500
8,000
6,600
56,800
10,000
578,779
1991
20,000
409,358
6,300
57,700
250
900
15,500
16,200
4,409
58,900
12,000
601,517
1992
21,000
497,275
6,600
60,000
250
1,100
17,600
24,100
5,200
55,200
16,000
704,325
1993
20,000
495,758
6,100
54,600
250
700
18,600
25,600
6,600
54,600
22,000
704,808
1994
20,000
479,379
7,500
46,700
250
800
17,900
26,000
4,409
52,000
27,000
681,938
1995
21,000
481,503
7,800
55,400
250
1,000
19,300
32,800
5,200
55,600
31,000
710,853
1996
19,000
526,276
9,000
44,400
250
900
17,700
32,600
6,200
53,600
35,000
744,926
1997
19,000
569,579
8,100
46,900
250
600
15,400
33,000
5,800
56,900
37,000
792,529
1998
16,369
564,355
9,735
37,945
—
527
18,157
32,017
4,409
55,103
51,071
789,708
1999
16,389
596,628
10,683
42,889
—
531
18,662
39,114
4,625
60,238
23,667
841,982
Data shown are live weight except for oysters, clams and mussels which are meat weight. Excluded are eggs, fingerlings, etc. which are intermediate products.

1. Baitfish and ornamental fish
2. Salmon estimates are for non-pen production only.

Source: ISA, 2002.
                                                                    2-25

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production is tracked only for the time period 1990 to 1999, but increased nearly fivefold from 8 million to
39 million pounds during that time.  The only exception to this trend is crawfish production, which shows
an overall decline during this period.


       Figure 2-9 and Table 2-7 show the increase in production value over the same time period.1l
Catfish is still the primary commodity, with production value ranging from $160 million in 1985 to $439
million in 1999 (nearly 45 percent of the total value tracked in JSA, 2002).  Salmon and trout are second
and third in terms of production value, with $76.8 million and $65 million, respectively, in 1999.  Combined,
catfish, trout,  and salmon accounted for 60 percent  of the total value of aquatic animal production in 1999.
The data for total value changes sharply between 1997 and 1998.  This is driven primarily by the change
in the value of the "Other species" category which jumped from $34 million in 1997 to $209 million in
1998. Although this might be the result of including data in 1998 and 1999 for new species not recorded in
earlier years, the web site does  not provide any information to this effect.
       2.3.3   Observations
       The relative sizes of the public and private aquatic animal production may be coarsely
summarized as:
               Public: approximately 35 to 110 million pounds (broken down as follows)

                      Federal: 5.5 million pounds (1999)
                      State:          -28 to 103 million pounds (no date)
                      Tribal:          1.3 million pounds (no date)
                      Academic Institutions:   unknown

               Private:  approximately 842 million pounds (1999)
        "Values are presented in nominal dollars.
                                              2-26

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                                                             Figure 2-9
                            United States Private Aquatic Animal Production by Value 1985-1999
       1000
        900
        800
        700
    |    600
   §,

    I
   I    500
   Q
    o

    §    400
        300
        200
        100
                   t     t
                                                                                            -&	I-
4      +
*      t
           1984    1985    1986   1987   1988    1989    1990    1991   1992   1993    1994   1995   1996    1997    1998    1999   2000

                                                                 Year
                                      f All Species   A Crawfish         -O-Trout  A-Catfish, Crawfish Si Trout

                                      O Catfish        Catfish Si Crawfish
Source: JSA, 2002.
                                                                2-27

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                                                                 Table 2-7

                                            U.S. Private Aquaculture Production for 1985-1999
                                                Growth in Time by Value ($1,000 Nominal)
Species
Non-
food1
Catfish
Clams
Craw
fish
Fresh
water
Prawns
Mussels
Oysters
Salmon2
Shrimp
Trout
Other
Species
Total
1985
25,000
159,800
4,500
31,000
1,500
400
33,300
5,500
1,500
58,000
9,800
330,300
1986
26,000
164,200
8,100
33,100
900
1,000
40,900
4,500
1,800
60,500
10,000
351,000
1987
27,500
199,300
10,300
32,300
750
1,000
48,900
7,500
3,000
63,000
12,000
405,550
1988
32,000
254,300
11,000
27,700
1,200
,1200
41,200
2,100
4,500
66,400
14,000
455,600
1989
34,500
281,900
12,500
24,000
1,000
1,150
47,100
24,000
3,800
72,600
13,500
516,050
1990
38,000
323,200
13,500
34,100
1,000
1,150
51,000
23,000
3,000
77,100
15,000
580,050
1991
40,000
284,700
11,000
31,700
1,000
1,100
43,000
43,90
3,500
70,000
19,000
548,900
1992
44,000
319,100
11,500
33,100
1,000
1,500
50,000
62,100
5,300
64,900
20,000
612,500
1993
46,000
370,500
12,000
26,600
1,000
1,400
41,700
63,300
6,600
68,600
22,000
659,700
1994
52,000
397,400
14,000
25,200
1,000
1,950
47,400
64,700
4,409
65,100
25,000
698,159
1995
59,000
399,500
18,500
33,100
1,000
2,500
51,000
79,100
5,200
73,900
28,000
750,800
1996
58,000
425,400
20,000
33,200
1,000
3,100
48,900
73,500
6,200
72,000
30,000
771,300
1997
56,000
426,800
18,000
27,900
1,000
1,200
46,700
75,000
6,500
79,800
34,000
772,900
1998
57,392
419,094
29,612
23,649
—
2,801
47,951
62,694
17,637
59,710
218,103
938,643
1999
57,392
438,936
42,051
28,287
—
799
55,635
76,778
13,706
64,954
208,562
987,080
Data shown are live weight except for oysters, clams and mussels which are meat weight. Excluded are eggs, fingerlings, etc. which are intermediate products.
1. Baitfish and ornamental fish
2. Salmon estimates are for non-pen production only.

Source: ISA, 2002.
                                                                   2-28

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In terms of pounds produced, the data indicate that the private sector is about 8 to 24 times larger than the
public sector.  Aquariums are not reported here because they do not distribute their animals.


2.4     ECONOMIC VALUE

        2.4.1   Public

        Public aquatic animal production supports a myriad of goals, including helping to restore depleted
fish stocks, establishing sustainable fisheries, and recovering endangered species. Pursuit of these goals
may also simultaneously support recreational fishing and Tribal fishing rights.


        It is extremely difficult to estimate the total economic value to society associated with public
aquatic animal production, particularly accounting for the cultural and religious significance of Tribal
fishing and helping to re-establish endangered species.  However, we can begin to get an idea of the
importance of recreational fishing to national, state, regional and local economies by examining what
anglers actually spend to fish.  FWS' 1996 National Survey of Fishing, Hunting, and Wildlife
Associated Recreation (FWS, 1997) reports that anglers spent $24 billion in trip-related and equipment
expenditures for freshwater fishing in 1996.12  FWS (1997) does not break down other expenditures, such
as magazines, memberships, and licences by fresh- or salt-water fishing.  However, in 1996 anglers spent
approximately $0.6 billion for licenses, stamps, tags, and permits.

        Expenditures are not included when estimating societal benefits.  Money that is not spent for
fishing at a particular site will be spent fishing at a different site or on an entirely different activity.  Any
change in expenditures is considered a transfer from one subgroup in society to another subgroup.13 Net
economic value or consumer surplus  is the value measured as participants' "willingness to pay" above
        12Other than salmon, the species listed in Table 5 of FWS (1997) for saltwater fishing are not
among those listed in the aquatic animal production lists.  Salmon account for only 637,000 of 9,438,000
anglers and 3,976,000 of 103,034,000 fishing days. Hence, the trip-related and equipment expenditures for
saltwater fishing are not included in this estimate.
        "Savings are considered a form of expenditure.
                                               2-29

-------
what they actually spend to participate.  FWS (1998) examines the economic values for bass, trout, and
walleye fishing, and other recreational activities.  The goal of the study was to develop net economic
value estimates for use in cost-benefit analyses, damage assessments, and project evaluations.  The data
were analyzed in three different groupings of states, and the decision of which grouping is best for a
particular analysis is left to the wildlife manager doing the study. No national estimates are provided.  The
per-fish marginal values depend on the region and how the states are grouped into regions, but are
represented by the following ranges:

        •      trout - $0.24 to $3.38 per fish caught

        •      bass - $1.44 to $6.05 per fish caught

Given the 53 million catchable trout stocked by state hatcheries (see Table 2-5), the net economic value
for this segment of public aquaculture ranges from $12.7 million to $179 million. Other efforts to restore
sustainable fish stocks also contribute to social welfare, so this range represents a lower bound estimate.
        2.4.2   Private


        In 1998, the value of private aquaculture production was $978 million.14 The National Marine
Fisheries Service presents data for domestic fisheries in its annual Fisheries of the United States.  In
1997, the value of aquaculture production was nearly one-quarter of the domestic commercial landings
(NMFS, 1999). Data for 1998 are available from the Census of Aquaculture (USD A, 2000a) and from
NMFS, 1999 for domestic commercial landings.  Aquaculture is approximately 30 percent of the domestic
commercial landings (i.e., $978 million compared to $3.1 billion).
        14This is within 4 percent of the value presented on the JSA web site (JSA, 2002).
                                              2-30

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        For two states—Maine and Mississippi—aquaculture products were one of the top five
agricultural commodities produced in terms of value.  Aquaculture ranked fourth in both states, accounting
for 10.8 percent of total farm receipts in Maine and 9.0 percent of total farm receipts in Mississippi
(USDA, 2000b).


        USDA (2000a) categorized facilities by aquaculture revenues.  Table 2-8 provides the nationwide
data while Table 2-9 disaggregates the information by species. USDA requested information on
aquaculture activities only, not on all farm activities.  Nearly one-half of the facilities show aquaculture
revenues less than $25,000.  However, this does not necessarily mean that the total facility income is less
than $25,000.  Presumably, the 409 facilities with aquaculture revenues in excess of $500,000 represent
all-aquaculture entities, while the plethora of smaller facilities represent the range to which an aquaculture
enterprise contributes to overall facility revenues.  The distinction between aquaculture revenues and total
facility revenues is discussed further in Section 2.6.
        2.4.3   Aquariums

        Revenue data for aquariums represent what people are willing to pay to see and study aquatic
animals.  Census data are the only source of revenue information for aquariums, however, the
information is presented for all of NAICS code 712130 Zoos and Botantical Gardens.  Census reports
$1.3 billion in revenues for all non-taxable establishments and $0.1 billion for taxable establishments in
1997 form NAICS code 712130 (Census, 2001b).
2.5     ORGANIZATIONAL STRUCTURE
        Public entities with aquaculture activities may be separated into four categories:
                                               2-31

-------
              Government or Government Agency (Federal, state, or local)
              Not for profit entities, such as Alaskan hatcheries
              Research institutions, such as colleges and universities
              Tribe entities.
                                          Table 2-8
              Number of Aquaculture Facilities by Revenue- United States 1998
Revenues
Lower Limit
$1,000
$25,000
$50,000
$100,000
$500,000
$1,000,000
Upper Limit
$24,999
$49,999
$99,999
$499,999
$999,999
$1,000,000+
Total
Number of
Farms
1,977
433
465
743
202
208
4,028
Percent of
Farms
49.1%
10.8%
11.5%
18.4%
5.0%
5.2%
100.0%
Source: USDA, 2000a.
                                             2-32

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                                       Table 2-9

                         Number of Farms by Revenue Category
                                       By Species



Category
Catfish
Trout
Other food
fish
Baitfish
Ornamental
Fish
Sport/game
fish
Other fish
Crustaceans
Mollusks
Other
animal
aquaculture,
algea, and
sea
vegetables
Number of Farms by Size (Revenue)


Total
1,370
561

435
275

345

204
11
837
535





216
$1,000 -
$24,999
(No. and
Percent)
515
333

244
161

169

158
9
637
306





96
38%
59%

56%
59%

49%

77%
82%
76%
57%





44%
$25,000
to
$49,999
112
56

36
28

44

20

106
63





30
$50,000
to
$99,999
165
64

39
22

44

6

45
60





31
$100,000
to
$499,999
354
82

62
45

60

19
2
40
75





42
$500,000
and
$999,999
121
17

14
12

16

0
0
3
14





8

$1,000,000
and above
103
9

40
7

12

1
0
6
17





9

Total
Percentage
4,789

2,628
55%


495
10%
476
10%
781
16%
205
4%
204
8%
Note: Total exceeds 4,028 farms because a farm may raise more than one species.
Source: USDA, 2000a.
                                          2-33

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       2.5.1   Public: Government or Government Agency

       Table 2-10 indicates the relationship between Federal and state efforts in fisheries management.
Federal funds comprise anywhere from zero to 75 percent of a state's fisheries management budget. For
eight states, Federal funds make up 70 percent or more of their operating budget.  Only Massachusetts
and Washington do not receive Federal funds.  Table 2-10 also indicates the relative importance of
revenue from fishing licenses and fees to a state budget.  For 23 states, this source of revenue forms at
least 50 percent of the budget.
       2.5.2   Nonprofit Organizations

       This section primarily focuses on financial organizations unique to Alaskan hatcheries. The
farming of salmon, per se, was outlawed in 1990 (Alaska, 200la).  Instead, Alaska permits nonprofit
"ocean ranching" where salmon are reared from egg to smolt stage and then released into public waters
to be available for harvest by fishermen upon their return to Alaskan waters as adults.  Two types of
nonprofit organizations are represented in Alaska operations: regional aquaculture associations and private
nonprofit corporations. The state promotes increased salmon production through the Fisheries
Enhancement Revolving Loan Fund, e.g., long-term, low-interest loans for hatchery planning, construction,
and operation. The corporations are permitted to harvest a certain amount of the fish that return to the
hatchery area as adults for cost recovery purposes.  Regional corporations vote on a self-imposed state
tax (from 1 percent to 3  percent) of the ex-vessel value of the fish in the regions where caught.  The tax
is collected by the Alaska Department of Revenue and disbursed only to the regional corporations through
annual grants (Alaska, 2001b and Alaska, 2002).


        Census data identify non-taxable establishments in NAICS code 712130.  EPA assumes that
this count might include non-profit aquariums  (Census, 2001b).
                                              2-34

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       Table 2-10
FY 1999 Revenue Sources
State
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Budget
($1,000)
6,200
10,974
6,8008
6,698
44,850
11,894
2,292
270
19,578
7,440
20
5,647
9,389
4,685
4,558
7,767
8,304
6,978
4,762
4,640
22,103
20,319
4,877
10,628
7,678
3,156
GRF*
Revenue (%)
0
44
0
0
0
0
17
19
NA
0
10
NA
10
0
0
0
NA
0
0
0
1
0
2
0
0
0
Licenses and
Fees (%)
35
17
25
81
41
68
37
16
NA
59
15
NA
69
61
54
30
NA
25
70
100
64
61
23
9
49
25
Federal
Aid (%)
65
12
75
19
23
28
46
51
NA
40
75
NA
19
38
46
70
NA
75
30
0
28
39
75
5
45
75
Other
Revenue (%)
0
27
0
0
36
4
0
14
NA
1
0
NA
2
1
0
0
NA
0
0
0
7
0
0
86
6
0
          2-35

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                                          Table 2-10 (cont.)
State
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Total
Budget
($1,000)
2,975
3,571
4,705
3,900
13,568
10,989
1,176
16,604
7,760
12,369
19,513
422
5,455
2,937
11,548
32,817
7,454
2,080
9,177
13,083
4,696
21,517
5,999
486,9877
GRF*
Revenue (%)
5
0
0
0
5
0
0
4
0
12
0
6
32
0
0
NA
7
0
0
63
0
3
0
-
Licenses and
Fees (%)
25
56
80
39
70
70
25
74
50
27
54
19
27
63
60
NA
43
56
55
0
80
72
40
-
Federal
Aid (%)
70
44
20
61
25
30
75
18
30
4
37
75
33
37
40
NA
39
44
42
0
20
20
41
-
Other
Revenue (%)
0
0
0
0
0
0
0
4
20
57
9
0
8
0
0
NA
11
0
3
37
0
5
19
-
*GRF = State General Revenue (appropriated) Funds
Note:   Indiana did not reply to the survey. Florida, Mississippi and Louisiana do not actively manage cold water
        species.
Source: Epifanio, 2000.
                                                  2-36

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       2.5.3   Private



       Private entities may be broadly classified as:



       •      Proprietorship (individual operations)


       •      Partnership


       •      Corporations (family and non-family15)


If facilities with aquacultural activities follow the same pattern as agricultural farms in general, about 90
percent of the facilities are proprietorships.  Within the corporation classification, 89 percent are family

corporations with more than 50 percent of the stock held by people related by blood or marriage (USD A,
1998b).
2.6    EMPLOYMENT



       EPA did not identify a reference or references with industry-wide numbers for employment in

aquatic animal production for either the public or private sectors.
        15EPA searched SEC's Directory of Companies Required to File Annual Reports with the
Securities and Exchange Commission under the Securities Exchange Act of 1934 for industries in
Standard Industrial Classification (SIC) codes 0200 (agriculture production, livestock and animal
specialties) and 0700 (agriculture services) (SEC, 1999), as well as Internet searches on sites such as
Hoovers.com and usinfo.com for publicly held aquatic animal production companies but did not find a
sufficient number to develop a representative sample.

                                              2-37

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2.7     SMALL BUSINESSES

        2.7.1   Public

        The Regulatory Flexibility Act as Amended by the Small Business Regulatory Enforcement
Fairness Act (RFA/SBREFA, Public Law No. 104-121) defines a "small" governmental jurisdiction as the
government of a city, county, or town with a population of less than 50,000. For the purposes of the
Regulatory Flexibility Act, states and tribal governments are not considered small governments but rather
as independent sovereigns (EPA, 1999).  Accordingly, EPA has not identified any small governmental
jurisdictions for the purpose of a small business analysis.
        2.7.2   Private

        The Small Business Administration (SBA) sets size standards to define whether a business entity
is small and publishes these standards in 13 CFR 121. When making classification determinations, SBA
counts receipts or employees of the entity and all of its domestic and foreign affiliates (13
CFR121.103(a)(4))). As of October, 2000, the size standards are based on NAICS (SBA, 2000).  On 21
December 2000, Public Law 106-554 "Small Business Reauthorization Act of 2000" became effective.
Section 806(b) of the legislation raised the size standard to $0.75 million for small businesses in the
Agriculture Industry. SBA published a direct final rule on 7 June 2001 with this change (SBA, 2001).  On
23 January, 2002, SBA adjusted its monetary-based size standards for inflation (SBA, 2002). Table 2-11
summarizes the size standards  applicable to the aquatic animal industry.
                                              2-38

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                                           Table 2-11
                                 Small Business Size Standards
Business
Code
NAICS
112511
112512
112519
712130
Description

Finfish Farming and Fish Hatcheries
Shellfish Fanning
Other Animal Aquaculture
Zoos and Botanical Gardens (Aquariums)
Size Standard (Annual Revenues)

$0.75 million
$0.75 million
$0.75 million
$6.0 million
        The only readily available source of aquaculture revenue data is USDA Census of Aquaculture
(2000a). The USDA revenue data are on an individual facility basis while the SBA small business
definitions are based on total company revenues.  Given that a large percentage of the facilities with
aquacultural activities are proprietorships and likely to be single-facility entities (i.e. the facility is the
company), this does not necessarily preclude using this data to examine the economic impacts to small
businesses.  More problematic is the fact that the USDA data reports only revenues from aquaculture, not
total facility revenues, while the determination of whether the company (or farm in this case) is a small
entity should be done on the basis of total revenues.

        Based on these aquaculture revenue data, nearly nine out of every ten facilities would be
considered "small" (see Table 2-8). If an individual facility has revenues  that exceed the SBA size
standard then, by definition, total company revenues must also exceed the size standard. However, if an
individual facility has revenues less than the SBA size standard, the total company revenues may or may
not exceed the size standard depending on the revenues from the other facilities owned by the  company.
For example, a company that owns eight facilities, each with $100,000 in  annual revenues, would exceed
the size standard and hence would not be classified as a small business.
        Table 2-9 summarizes the distribution of facilities by revenue category and by species. The
individual entries sum to 4,789 facilities while the reported national total is 4,028 facilities, indicating that as
many as 761 facilities raise more than one species.  Catfish and trout account for approximately 40
percent of the total number of facilities but represent 61 percent of the large facilities. According to this
data, about three-quarters of crustacean facilities have revenues below $25,000 (637 out of 837 facilities).

                                               2-39

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However, this revenue data does not include income from crops that are co-produced with aquaculture.
For example, about half the crawfish in Louisiana are raised in rice ponds (Frank, 2000).  EPA is aware
that classifying operations as "small" solely on the basis of aquaculture revenues at individual facilities will
overestimate the number of small entities, but prefers to err by overestimating rather than underestimating
that number.
2.8     MARKET STRUCTURE


        While the industry profile is organized to present data on the public and private sectors of aquatic
animal production, it is in the market structure that the two sectors are inexorably intertwined. In addition,
wild catch and imports influence the commercial market and the importance and strength of these
influences vary by species.  This section summarizes the interplay of these forces and identifies the
different markets within the aquatic animal production industry.
        2.8.1   Public

         Sections 2.1 and 2.3 document the role of public aquatic animal production for ecological
restoration, recreation, or fee-fishing. Many of these fish are grown in government fish hatcheries; others
are sold to government entities by commercial growers for stocking.  Production decisions for these
recreationally oriented growers are not governed by the same types of market forces that influence
commercial decision-makers. Much of this production is financed by fishing license fees and other taxes.
The ultimate consumers are anglers and those who value a natural environment. They do not make
consumption decisions based on the price of stocking fish. Hence, there is no market relationship, in the
traditional sense for these fish.
                                               2-40

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        Table 2-12 summarizes the uses of aquaculture products and their sources for 1998 combining
information from Census of Aquaculture and National Marine Fisheries Service (NMFS) documents.16
Almost half the trout and three-quarters of the salmon raised in U.S. aquaculture are used for ecological
restoration, fee-fishing, or recreation. Table 2-13 abstracts information from Table 2-12 to graphically
illustrate the variety of market types among the aquaculture products.
        2.8.2   Private

        The market structure for the private aquaculture industry is characterized by high facility
concentration offset by competing sources and substitutes.   The Census data indicate a high degree of
concentration at the facility level.  In the extreme cases, eight facilities in Texas produce 70 percent of
the value of shrimp produced by aquaculture in the U.S.; three percent of the ornamental fish facilities (12
facilities) produce 59 percent of the value of the industry.  Table 2-14 summarizes the share of production
from the top ten percent of facilities. Many of the aquaculture production industries are small and highly
concentrated both in terms of the number of firms and geographic area (ornamentals, baitfish, salmon, and
shrimp). Commercial production of each aquaculture species also is concentrated geographically (see
Figures 2-1 through 2-5).

        However, the existence of other sources, namely, wild catch and imports, and close substitutes
may limit the exercise of oligopoly power on the part of aquaculture producers. For salmon, shrimp, and
most mollusks, the wild catch is greater than domestic aquacultural production.  For baitfish, wild catch is
not recorded in the fisheries statistics but is an important part of the market and always an option for
anglers if farm-raised baitfish prices rise too high.  Even when the wild product is only a close substitute
for the farm-raised product, prices for the wild product will influence prices for the aquacultural  product.
If the wild products or imports are setting the price, it is unlikely that changes in costs of aquaculture
        16 Table 2-12 was assembled from three different sources so the data in each column may not be
comparable to neighboring columns and adding them together may be incorrect.  The purpose of the table,
however,  is to show rough scales of contributions of aquaculture (for recreation and food use), wild catch
and imports to total U.S. supply for various species.
                                               2-41

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                                            Table 2-12
              Sources and Uses of Aquaculture Species in the United States, 1998
species
Catfish
Trout
salmon
Filapia
lybrid Striped Bass
Dmamentals
3aitfish
Crawfish
shrimp
>ab
^lam
Mussel
Dyster
Units
(l,0001bs)
(l,0001bs)
(l,0001bs)
(l,0001bs)
(l,0001bs)
($1,000)
($1,000)
(l,0001bs)
(l,0001bs)
($1,000)
($1,000)
($1,000)
($1,000)
Aquaculture
Total to
Recreation,
Restoration
10,175
2%
46,341
47%
291,147
27%
0
0%
612
3%
414
0%
1,537
4%
35
0%
8
0%
21
0%
50
0%
3
0%
27
0%
Total to
Food/
End use
563,934
96%
47,422
48%
107,160
10%
11,571
16%
8,407
48%
68,568
66%
35,945
96%
17,426
39.5%
4,209
0%
10,276
1%
50,026
23%
3,177
9%
26,985
19%
Wild Catch
11,590
2%
789(i)
1%
644,434
59%
0
0%
6,715
38%
0
0%
0(D
0%
22,226
50.4%
277,757
29%
473,378
61%
135,237
62%
1,604
5%
88,627
61%
Net Imports
1,100
0%
4,217
4%

60,911
84%
1,927
11%
34,563
33%
0
0%
4,387
10.0%
670,212
70%
295,518
38%
31,164
14%
29,855
86%
29,785
20%
Total Use
586,799
100%
98,769
100%
1,085,072
100%
72,482
100%
17,661
100%
103,545
100%
37,482
100%
44,074
100%
952,186
100%
779,193
100%
216,477
100%
34,639
100%
145,424
100%
(1) Figures shown for wild catch are from NMFS, 1999. Much of the trout and all of the baitfish wild catch is not
reported to NMFS.  Wild catch will be a substantial factor in both these markets.
Sources: USDA, 2000a; USDA, 2000c; NMFS, 1998; and NMFS 1999.
                                               2-42

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                                              Table 2-13
                          Characteristics of Aquaculture Species Markets
Species
Catfish
Trout
Salmon
Tilapia
Hyb Striped Bass
Ornamentals
Baitfish
Crawfish
Shrimp
Crab
Clam
Mussel
Oyster
Aquaculture
is largest
source
X
X
_
_
X
X
X
_
.
_
_
-
-
Recreation
is a large
use
-
X
X
_
_
-
-
_
_
_
-
-
-
Imports...
dominate
domestic
aquaculture
-
-
_
X
_
-
-
_
X
X
-
X
X
are a
major
component
-
-
_
X
X
X
-
-
X
X
X
X
X
Wild catch...
dominates
domestic
aquaculture
-
-
X
_
_
-
-
X
X
X
X
-
X
is a
major
component
-
(1)
X
_
X
-
(1)
X
X
X
X
-
X
(1) Much of the trout and all of the baitfish wild catch is not reported. Baitfish wild harvest was reported to be 50
percent of market at ISA Aquaculture Effluents Technical Workshop, 9/20/2000.  Wild catch will be a substantial
factor in both these markets.
Note: "Recreation is a large use" means ecological restoration, fee-fishing, recreational, and government use is
greater than 20 percent of total use. "Dominates domestic aquaculture" means wild catch or net trade provides a
greater proportion of total use than aquaculture.  "Major component" means more than 10 percent of total use.
                                                  2-43

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                                           Table 2-14
                                     Industry Concentration
>pecies
Catfish
Trout
Other Food Fish
Ornamentals
Baitflsh
Crustaceans
Vlollusks
Top 10 percent of farms
Numbei
of Farms
137
56
44
35
28
84
54
Produce
(Percentage of
value)
65%
72%
85%
75%
67%
74%
79%
Total Value
($1,000)
450,710
72,473
168,532
68,982
37,482
36,318
89,128
        Source: USDA, 2000a.
        Note: Production value categories added together to find top 10 percent.
production will be passed through to consumers and more of the costs of compliance (if not all) will need
to be absorbed by the facility.
       Like wild catch, a high level of imports reduces the effect of changes in aquacultural production
on the market. Imports are discussed in more detail in the next section while the market effects are
summarized here. For tilapia, shrimp, and mussels, imports are a much larger share of the market than
domestic aquaculture and undoubtedly have more influence on the market price. The situation for salmon
is more complex as Tables 2-12 and 2-13 combine Pacific and Atlantic salmon.  The U.S. is a large
importer of Atlantic salmon and exporter of Pacific salmon so the net trade appears small. Atlantic
salmon imports are twice total domestic salmon farm production.  There is evidence that Atlantic and
                                              2-44

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Coho salmon are substitutes in some situations (Clayton and Gordon, 1999).  Whatever the precise
relationships, trade flows have a large effect on the prices of many aquaculture products.
2.9    INTERNATIONAL TRADE

       Import and export codes used by the United States are based on the Harmonized Tariff System
(HTS). Import codes (called HTS) are administered by the United States International Trade
Commission (ITC) while export codes (called Schedule B) are administered by the U.S. Census (Census
2002a and 2002b; USITC 2002).  This means the same product will have different codes depending on
whether it is an import or an export.  Only three aquatic animal products have export codes that identify
them as "farmed"—rainbow trout (0302.11.0010), Atlantic salmon (0302.12.0003), and mussels
(0307.31.0010). "Farmed" imports include the rainbow trout (0302.11.00.10), Atlantic salmon
(0302.12.00.03), and mussels (0307.31.0010), as well as Chinook salmon (0302.12.00.12), Coho salmon
(0302.12.00.53), and oysters (0307.10.00.60).  The Census and ITC data, then, provide an incomplete
view of trade in aquaculture.

       Import and export data for a wider variety of aquaculture products are available from NMFS and
USDA.  Data on imports and exports of seafood or fishery products include data for both raised
(aquaculture) and wild harvested products (confirmed by Harvey, 2000).17 Hence, data used in this
section does not solely reflect aquaculture production.  Foreign trade data of certain seafood products and
fishery products is provided to portray the overall picture of seafood-related international trade.
       In 1999, the world's aquaculture production (inland and marine) equaled 33 million metric tons in
live weight (NMFS, 2001).  This was 26 percent of the world's total commercial catch.  The leading
        17Harvey (2000) noted that it might be possible to estimate the percentage of aquaculture
products traded into and out of the United States. This estimation would depend on the species, the size
of the product, the country of origin, among other factors. Mr. Harvey appears to have done this for the
USDA website which states that, in 1999 the total value of aquaculture exports was approximately $30-35
million (Harvey, 2002).
                                              2-45

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aquaculture and commercial catch countries are China, Peru, Japan, Chile, United States, and India. Of
these countries, China has the largest share while the U.S. ranks fifth (NMFS, 2001).


       Figure 2-10 demonstrates import and export values of fishery products from 1989 to 2000.  The
solid pair of lines are for all fishery products, both edible and non-edible, while the dashed pair of lines
shows only the value for edible products.  For all fishery products, U.S. exports increased from 1989 to
1997 and declined in 1998 (perhaps due to the economic difficulties of the U.S.'s largest market—Asia).
The trade gap had been increasing slowly until 1998. The U.S. has a growing net trade deficit in fishery
products with a pronounced gap in 1998.  Exports of edible fishery products peaked in 1992 with $3.5
billion and have been declining ever since.
       2.9.1   Imports

       The value of total U.S. imports of edible and nonedible fishery products in 2000 was $19 billion.
As a trading region, Asia was the largest source of these imports, accounting for 44 percent of the total
tonnage (NMFS, 2001). Canada was the individual country with the largest volume of imports to the U.S.
(NMFS, 2001).  The value of edible fishery imports has nearly doubled from $5.5 billion in 1989 to $10.1
billion in 2000 (see Figure 2-10).


       Switching to USD A data, Tables 2-15 and 2-16 show the value of U.S. imports and exports of
selected seafood products for 2000 and 2001, respectively.  In both years, the U.S.  imported about $4.8
billion worth of these seafood products and exported about $0.6 billion.

       Tables 2-15 and 2-16 are rank-ordered from largest net import to largest net export. The largest
seafood import for both years was frozen shrimp, accounting for about  62 to 63 percent of the value of all
imports. Thailand is the largest exporter of shrimp to the U.S., accounting for 36 percent of shrimp
imports in 2000 and 34 percent in 2001 (USDA, 2002a). Mexico, Ecuador, and India are the second
through fourth largest shrimp importers to the United States, respectively, in terms of value (USDA,
2002a).
                                              2-46

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                                                    Figure 2-10
                    Value of U.S. Imports and Exports of Fishery Products 1989-2000 ($1 billion)

  a
     20




     19



     18




     17




     16




     15




     14




     13




     12




     11



     10
,	-If
                                                                          A	^	
                                                         I
                                             I
          1989
                   1990
                            1991
                                     1992
                                              1993
                                                       1994     1995




                                                            Year
                                                                         1996
                                                                                   1997
                                                                                            1998
                                                                                                     1999
                                                                                                              2000
                                            Imports
                                   Exports
Import
                                                                          "A~
Export
Source: NMFS, 1999 andNMFS, 2001.
                                                        2-47

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       The value of tilapia imports grew 26 percent from $101.4 million in 2000 to $127.8 million in 2001,
while the quantity increase was 39 percent (USDA, 2002a). That is, there was a decrease in the average
price of tilapia.  Most imports are from Taiwan and China (USDA, 2002a).  Although imports of tilapia
have been a recent addition to U.S. foreign trade, documented only since  1992, tilapia was the fourth
largest seafood product imported in 2001.


       The value of Atlantic salmon (both frozen and fresh) imports increased between 2000 and 2001,
from $741 million to $773 million.  The largest suppliers—Chile and Canada—together account for more
than 90 percent of U.S. Atlantic salmon imports (USDA, 2002a).
                                           Table 2-15
                     2000 Imports and Exports of Selected Seafood Products ($1000)
Product
Shrimp, frozen
Shrimp, fresh & prepared
Atlantic salmon, fresh
Tilipia
Atlantic salmon, frozen
Mussels
Oysters
Ornamental Fish
Trout, fresh & frozen
Pacific salmon, fresh
Clams
Trout, live
Canned & prepared salmon
Pacific salmon, frozen
Total
Imports
3,035,173
707,565
654,725
101,378
85,658
47,359
40,763
40,761
11,291
42,633
7,504
131
32,021
20,527
4,827,489
Exports
62,891
52,738
34,471
0
583
1,681
7,227
8,189
2,893
37,048
5,649
185
147,127
273,271
633,953
Net
2,972,282
654,827
620,254
101,378
85,075
45,678
33,536
32,572
8,398
5,585
1,855
(54)
(115,106)
(252,744)
4,193,536
                                             2-48

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                                          Table 2-16
                2001 Imports and Exports of Selected Seafood Products ($1000)
Product
Shrimp, frozen
Atlantic salmon, fresh
Shrimp, fresh & prepared
Tilipia
Atlantic salmon, frozen
Mussels
Ornamental Fish
Oysters
Trout, fresh & frozen
Pacific salmon, fresh
Clams
Trout, live
Canned & prepared salmon
Pacific salmon, frozen
Total
Imports
2,957,944
685,289
678,853
127,797
87,483
43,610
40,863
36,914
11,507
30,462
8,296
99
36,199
14,940
4,760,256
Exports
54,553
37,945
51,481
0
139
1,595
6,914
8,238
1,577
22,166
6,593
271
167,825
236,604
595,901
Net
2,903,391
647,344
627,372
127,797
87,344
42,015
33,949
28,676
9,930
8,296
1,703
(172)
(131,626)
(221,664)
4,164,355
            Source: USDA, 2002a.
       2.9.2   Exports


       Figure 2-10 portrays the value of U.S. imports and exports of fishery products from 1989 to 2000.
 The total value of U.S. seafood exports increased slightly, while the export value of edible fish remained
relatively constant during the period.


       In recent years, however, USDA data show a drop in the value of exports from $634 million to
$596 million, see Tables 2-15 and 2-16. Frozen Pacific salmon is the largest U.S. export, comprising
between 40 and 43  percent of the total value of U.S. exports.18 Between 2000 and 2001, the export value
of frozen Pacific salmon decreased from $273 million to $237 million.  The quantity of  exports
       1 Differences between the East and West coasts are obvious for salmon. Fresh Atlantic salmon
is the second largest U.S. net import while frozen Pacific salmon is the largest U.S. net export.
                                             2-49

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increased during this period from 162 million pounds to 168 million pounds. This reflects a decrease in the
unit value of Pacific salmon.  From 2000 to 2001, only fresh Atlantic salmon, canned and prepared
salmon, oysters, and clams showed an increase in the value of exports. All other commodities showed a
decline.
       2.9.3  Government Intervention


       Table 2-17 lists the dramatic rise in reported "catfish" imports from Vietnam from less than
80,000 kilograms in 1995 to 7.8 million kilograms in 2001.  In 2001, the value of these imports totaled
$21.5 million (NMFS, 2002).  Prices paid by catfish processors averaged $0.7 Mb in 1997 but dropped to
$0.55/lb in December 2001 (USDA, 2002b). The situation was covered in industry news (Fiorillo and
McGovern, 2001; McGovern, 2002; Rappaport, 2002; and Rappaport, 2001a and 200Ib).  In November
2001, President Bush signed a one-year provision declaring that only products from the family Ictaluridae
could be labeled "catfish."  The Vietnamese imports are members of the Pangasiidae family.
Legislation to make the ban permanent passed the Senate in December (McCain, 2001; Philadelphia,
2002; USDA 2002c).


                                         Table 2-17
                                 "Catfish" Imports 1995-2001

Year
1995
1996
1997
1998
1999
2000
2001

All
1,101,337
1,119,074
427,118
628,354
1,564,631
3,736,242
8,201,420
Imports (kg)
Vietnam
79,553
59,096
54,505
261,352
902,598
3,191,068
7,765,319

Percent
7%
5%
13%
42%
58%
85%
95%

All
$2,591,161
$3,179,001
$1,412,010
$2,135,905
$5,674,123
$12,365,582
$22,751,433
Imports ($)
Vietnam
$263,926
$260,847
$233,846
$1,156,550
$4,052,524
$10,695,974
$21,509,704

Percent
10%
8%
17%
54%
71%
86%
95%
Source: NMFS, 2002.
                                             2-50

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2.10   REFERENCES
Alaska.  2002.  Alaska Department of Community & Economic Development. Division of Investments.
Fisheries Enhancement Revolving Loan Fund: Program Overview.  February.


Alaska.  2001a.  Alaska Department of Fish and Game.  Public Communications Section. Alaska's
Salmon Management: A story of Success.
 downloaded 3 October.
Alaska.  2001b.  Alaska Department of Fish and Game.  Division of Commercial Fisheries. Alaska
Salmon enhancement Program: 2000 Annual Report.  Regional Information Report 5J01-01. Juneau,
AK. January.
Becker, GS. and E.H. Buck. 1997. Aquaculture and the federal role.  CRS Report for Congress. 97-
436 ENR.  Washington, DC: Congressional Research Service.  The Library of Congress. April.


Census. 2002a. United States Department of Commerce. Census Bureau. FAQ;  What's the
difference between the Schedule B codes (for exports) and the Harmonized Tariff Schedule (HTS)
codes (for imports)? www.census.gov/foregin-trade/faq/sb0008.html downloaded  16 April.


Census. 2002b. United States Department of Commerce. Census Bureau. Schedule B codes
www.census.gov/foregin-trade/schedules/b/#download downloaded 16 April.
Census. 2001a. United States Department of Commerce. Census Bureau.
http://www.census.gov/epcd/naics/NDEF712.HTM.  Downloaded November 9.


Census. 2001b. United States Department of Commerce. Census Bureau.  Establishment and Firm Size
(including Legal Form of Organization).  1997 Economic Census. Arts, entertainment, and Recreation.
Subject Series. EC97S71-SZ. October 2000.  http://www.census.gov/prod/ec97/97s71-sz.pdf
Downloaded November 9.
Clayton, Patty L. and Daniel V. Gordon.  1999.  From Atlantic to Pacific: Price Links in the US Wild and
Farmed Salmon Market. Aquaculture Economics and Management, 3(2):93-104.
EPA.  1999.  U.S. Environmental Protection Agency. Revised interim guidance for EPA mlewriters:
Regulatory Flexibility Act as amended by the Small Business Regulatory Enforcement Fairness Act.
Washington,  D.C.  March.
                                            2-51

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Epifanio, J. 2000. The status of coldwater fishery management in the United States: an overview of state
programs. Fisheries.  25(7)13-27.  Sponsored by Trout Unlimited.


Fiorillo, John and Dan McGovern.  2001.  "Cat Fight: The Vietnam, U.S. catfish war," WorldCatch News
Network.  27 September.  downloaded 12
April 2002.


Frank, A.D.  2000. Personal communication between A. David Frank, USDA, NASS, LA state office
and Maureen F. Kaplan, ERG, dated 24 August.


FWS. 2000a. U.S. Fish and Wildlife Service. Technical publications of the U.S. Fish and Wildlife
Service Fish Technology Centers 1996-June 1999. http://fisheries.fws.gov/FTC/FTCPub.htm.
Downloaded on 26 July.
FWS. 2000b.  U.S. Fish and Wildlife Service. National fish hatchery system.
http://fisheries.fws.gov/FWSFFi/draftpage/NFHSintro.htm. Downloaded on 26 July.


FWS. 2000c.  U.S. Fish and Wildlife Service. Tribal fish hatchery programs of the northern Great Lakes
region. Ed. F.G Stone,  Downloaded on 16 August.


FWS. 2000d.  U.S. Fish and Wildlife Service. Division of National Fish Hatcheries.  Spreadsheet entitled
USFWS99.txt, e-mailed by Donna Kraus, 17 August.


FWS. 1998.  U.S. Fish and Wildlife Service. 1996 Net Economic Values for Bass, Trout and Walleye
Fishing, Deer, Elk and Moose Hunting, and Wildlife Watching: Addendum to the 1996 National
Survey of Fishing, Hunting,  and Wildlife Associated Recreation. Report 96-2.  August.


FWS. 1997.  U.S. Fish and Wildlife Service. 1996 National Survey of Fishing,  Hunting, and Wildlife
Associated Recreation.  FHW/96NAT. November.
Harvey, David. 2002. U.S. Department of Agriculture. Economic Research Service.  Web Site.
 downloaded on 12 April. Mr. Harvey is cited as the
contact for further information.
Harvey, David.  2000. Personal communication between David Harvey, USDA and Reetika Motwane,
ERG, dated 23 August.
JSA. 2002. United States Joint Subcommittee on Aquaculture. U.S. Private Aquaculture Production for
1985-1999.  Downloaded on May 1.
                                             2-52

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Lang, John. 2000. Personal communication between John Lang, USDA and Andrea Poppiti, ERG, dated
2 August.


McCain. John.  2001.  "McCain: Catfish Import Barrier Puts International Trade Agreements at Risk,"
Press release dated 18 December 2001.  downloaded 12 April
2002.
McGovern, Dan.  2002.  "Catfish prices remain depressed; Imports from Vietnam grow 62%,"
WorldCatch News Network. 23 January.
 downloaded 12 April 2002.


NMFS. 2002.  U.S. Department of Commerce. National Oceanic and Atmospheric Administration.
National Marine Fisheries Service. Web-based trade data base, http://www.st.nmfs.gov/trade/index.html
Inquiry dated 12 April
NMFS. 2001. U.S. Department of Commerce. National Oceanic and Atmospheric Administration.
National Marine Fisheries Service.  Fisheries of the United States, 2000. August.


NMFS.  1999.  U.S. Department of Commerce.  National Oceanic and Atmospheric Administration.
National Marine Fisheries Service.  Fisheries of the United States, 1998. Current Fishery Statistics No.
9800. July.
NMFS.  1998.  U.S. Department of Commerce.  National Oceanic and Atmospheric Administration.
National Marine Fisheries Service. Imports and Exports of Fishery Products, Annual Summary,
1998.
Philadelphia, Desa.  2002.  "Catfish by Any Other Name." Time. February,  pp. B14-15.
Rappaport, Stephen. 2002. "US farm-raised catfish industry sees light on horizon." Fish Farming
News.  Volume 10.  January/February issue. Pp. 1, 5.
Rappaport, Stephen.  2001a.  "Trade Wars! Fish Farmers fight for market equity." Fish Farming News.
Volume 9. July/August issue. Pp. 1, 10.
Rappaport, Stephen. 2001b. "Catfish: Industry earns Congressional split decision." Fish Farming News.
Volume 9. November/December issue. Pp. 1, 20A.
SBA 2002.  Small Business Administration.  13 CFR Part 121.  Small business size standards; inflation
adjustment to size standards. Interim Final Rule. 67 FR 15:3041-3057.  23 January.
                                           2-53

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SB A. 2001. Small Business Administration.  13 CFR Parts 107 and 121 Size eligibility requirements for
SBA financial assistance and size standards for agriculture. Direct Final Rule.  65 FR 100:30646-30649.
7 June.
SBA. 2000. Small Business Administration.  13 CFR Part 121 Small business size regulations: Size
standards and the North American Industry Classification System; Final Rule. 65 FR 94:30836-30863. 15
May.


SEC. 1999. Securities and Exchange Commission. Directory of Companies Required to File Annual
Reports with the Securities and Exchange Commission under the Securities Exchange Act of 1934:
alphabetically and by industry groups.  Washington, DC. September.


USDA.  2002a.  U.S. Department of Agriculture.  Economic Research Service. Aquaculture Outlook.
LDP-AQS-15.  6 March.
USDA.  2002b. U.S. Department of Agriculture. National Agricultural Statistics Service.  Catfish
Processing. Report Aq 1 (3-02).  22 March.


USDA.  2002c. U.S. Department of Agriculture. Agricultural Outlook. Commodity spotlight.  April.


USDA.  2000a. United States Department of Agriculture. National Agricultural Statistics Service. 1998
Census  of Aquaculture. Also cited as 1997 Census of Agriculture. Volume 3, Special Studies, Part 3.
AC97-SP-3. February.


USDA.  2000b. U.S. Department of Agriculture.  Economic Research Service.  U.S. State Fact Sheets
at  for  Maine (me.htm) and Mississippi (ms.htm).  Downloaded
25 August.
USDA.  2000c. U.S. Department of Agriculture.  Economic Research Service. Aquaculture Outlook.
LDP-AQS-111. 13 March.


USDA.  1999. U.S.  Department of Agriculture. National Agricultural Statistics Service.  Letter to Mr.
Bob Durborow, Cooperative Extension Program, Kentucky State University from Rich Allen, Associate
Administrator, dated 2 August 1999, included as Attachment D to supporting statement for Information
collection request for revision to the catfish and trout production aquaculture surveys.  OMB No. 0535-
0150.
USDA.  1998a.  U.S. Department of Agriculture. National Agricultural Statistics Service. Supporting
statement for Information collection request for 1998 Census of Aquaculture.  OMB No. 0535-0237.
                                             2-54

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USDA.  1998b. U.S. Department of Agriculture. Office of Communications. Agriculture Fact Book
1998. Washington, D.C.  November.


USITC.  2002. United States International Trade Commission. Harmonized Tariff Schedule of the
United States (2002) (Rev. 2) Chapter 3. 
downloaded 16 April.


WDNR.  2000.  Tribal and Federal Hatcheries.
 Downloaded 16 August.
                                             2-55

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                                        CHAPTER 3
                               EPA SCREENER SURVEY
3.1.    SURVEY DESCRIPTION

       In August 2001, EPA mailed a short screener survey, entitled "Screener Questionnaire for the
Aquatic Animal Production Industry" to approximately 6,000 aquatic animal production facilities (EPA,
2001).  The screener survey consisted of eleven questions that requested general facility information,
including confirmation that the facility was engaged in aquatic animal production, the species and size
category produced, type of production system, wastewater disposal method, and the total production at the
facility in the year 2000.  The Agency used the reported  production information combined with price
information from the Census to estimate revenues for each facility surveyed.
3.2.    DEVELOPMENT OF SURVEY MAILING LIST

       The mailing list (sample frame) for EPA's screener survey was developed by synthesizing facility
information found in the Dunn and Bradstreet database, EPA's Permit Compliance System (PCS),
contacts with EPA regional permit writers, EPA site visits, state aquaculture contacts, assistance from the
Bureau of Indian Affairs on tribal facilities, universities, recent issues of Aquaculture Magazine, and an
extensive collection  of web sites with aquaculture references.  Additionally, EPA requested but was
denied access to the  facility identification data associated with the U.S. Department of Agriculture's 1998
Census of Aquaculture (USDA, 2000). The mailing list EPA developed contained approximately 6,000
facilities. This  number seemed to compare favorably with the roughly 4,000 facilities found in the 1998
Census of Aquaculture. EPA believes that this mailing population was as current as possible and
reasonably  complete.
                                              3-1

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3.3    RESPONSE TO THE SCREENER SURVEY

       EPA sent the screener survey to all 6,000 facilities on its mailing list.  EPA received responses
from 4,900 facilities, with about 2,300 facilities reporting that they do produce aquatic animals. The
discrepancy between the number of surveys sent and the number of facilities reporting that they are
aquatic animal producers is largely attributed to the fact that the list was compiled from general industry
sources and included aquatic animal processors, retailers, etc.

       EPA compared the number of direct discharging facilities identified in the NPDES permit
compliance (PCS) data base with the number of direct dischargers identified in the EPA screener survey.
EPA identified a total of 1,174 aquatic animal production facilities in the PCS database.  Based on the
NPDES permits found in the PCS database, EPA estimated  that there are about 377 facilities with active
permits. EPA identified a comparable number of direct discharging aquatic animal production facilities in
the screener survey data.
3.4     SUMMARY

        The screener survey identified approximately 2,300 facilities in the aquatic animal production
industry. This count encompasses the range of public and private ownership, production systems, water
pollution control technologies in place prior to the regulation, species, and size (annual harvest).  Of
these, less than 400 facilities directly discharge wastewater into U.S. water bodies and have sufficiently
large production levels to qualify as a "concentrated" aquatic animal production facility,  i.e., need an
NPDES permit under 40 CFR 122.24 and Appendix C.  The screener data, then, provide the foundation
for the engineering cost analysis, see Chapter 3 in the Development Document (EPA, 2002) for a more
complete description.
                                              3-2

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3.5    REFERENCES
EPA.  2002.  Development Document for the Proposed Effluent Limitations Guidelines and Standards for
the Aquatic Animal Production Industry.  EPA-821-R-02-016. Washington, DC: U.S. Environmental
Protection Agency, Office of Water.

EPA. 2001. United States Environmental Protection Agency. Screener Questionnaire for the Aquatic
Animal Production Industry.  OMB Control Number 2040-0237. Washington, DC. July.

USDA  2000.  United States Department of Agriculture.  National Agricultural Statistics Service. 1998
Census ofAquaculture. Also cited as 1997 Census of Agriculture. Volume 3, Special Studies, Part 3.
AC97-SP-3.  February.
                                             3-3

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                                         CHAPTER 4
           TECHNOLOGIES AND ENGINEERING COST ESTIMATES
       This chapter provides a brief overview of the treatment practices considered by EPA for the
concentrated aquatic animal production industry and the associated engineering cost estimates.  More
information on EPA's methodology to estimate costs is located in the Development Document for the
proposed rulemaking (EPA, 2002a).  Section 4.1 discusses the model facility approach used by EPA for
the proposed rulemaking. Section 4.2 reviews the treatment practices considered for the rule.  Cost
estimates are presented in Section 4.3 while frequency factors, used to adjust national  costs to reflect
treatment practices already in place in the industry, are discussed in Section 4.4.
4.1    MODEL FACILITY APPROACH

       Depending on data availability, EPA can develop either facility-specific or model facility
compliance costs and pollutant load reduction estimates. Facility-specific compliance costs and pollutant
load reduction estimates require detailed process and geographic information about many, if not all,
facilities in an industry. These data typically include production, capacity, water use, wastewater
generation, waste management operations (including design and cost data), monitoring data, geographic
location, financial conditions, and any other industry-specific data required for the analyses. EPA uses
each facility's information to estimate the cost of installing new pollution controls and the expected
pollutant removals from these  controls.

       When facility-specific data are not available, EPA develops model facilities to provide a
reasonable representation of the industry. EPA developed model facilities to  reflect Concentrated
Aquatic Animal Production (CAAP) facilities with a specific production system, ownership (e.g.,
commercial, Federal, state, and other) and species. EPA developed six models for each production
system/ownership/species combination based on the six size classifications in  the USDA Census (2000).
Each model facility represented all facilities within a size classification and were based on the average
production value.  These model facilities were developed based on data gathered during site visits,

                                              4-1

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information provided by industry members and their associations, and other publicly available information.
EPA estimated the number of facilities that each model represented based on data from the screener
survey (EPA, 2001) and the USDA 1998 Census of Aquaculture (USDA, 2000). Compliance costs and
pollutant load reductions were estimated for each model facility.  Industry-level compliance costs were
calculated by multiplying model facility costs by the estimated number of facilities required to implement
the treatment practice in each model category.  For the proposed rule, EPA used a model-facility
approach to estimate compliance costs because detailed information was not available. EPA intends to
collect facility level information from a sample of facilities through the detailed survey (EPA, 2002b).

        EPA developed the model facilities to capture the key characteristics of individual AAP facilities.
Data from the Census of Aquaculture and the screener survey were used to estimate the average values
of these key characteristics, which were then used to develop representative model facilities. Using this
approach, every model facility was characterized according to the representative values for a set of
specific attributes, which included production system type, species, dollar level of production, system
inputs (e.g. feed), estimated pollutant loads, discharge flow characteristics, and geographic data. All of
these attributes were then linked into options modules using a computing platform to enable changes to
model facility assumptions and characteristics.

        Control technology options and BMPs used to prevent the discharge of pollutants into the
environment were linked in the unit cost modules, which calculated an estimated cost of the component
based on estimates of capital (which included elements such as engineering design, equipment, installation,
one-time costs, or land) and annual operation and maintenance (O&M). For each model facility, EPA
applied combinations of technologies  and BMPs, given the model facility configuration characteristics
(e.g. system type, size, and species).  EPA adjusted the total cost of the component with a frequency
factor to account for those CAAP facilities that already have that treatment practice in place. This
adjusted cost, which reflects the number of facilities that would incur the costs associated with the
treatment practices, is used to estimate national capital and O&M costs from each of the model facility
configurations.
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4.2    TECHNOLOGY DESCRIPTIONS

       This section presents a brief description of treatment practices considered by EPA.  See the
Development Document (EPA, 2002a) for more detailed descriptions of the treatment practices, their unit
cost estimation, and references.
       4.2.1   Quiescent Zones

       Quiescent zones are a technology control considered in Option 1 for all flow-through CAAP
facilities as a part of primary solids removal.  Quiescent zones are a practice used in raceway flow-
through systems that use the last approximately 10% of the raceway to serve as a settling area for solids.
It is important to note that flow-through system raceways are typically sized according to loading densities
(e.g., 3-5 pounds offish per ft3), but the flow rate of water through the system drives the production levels
in a particular raceway. Thus, EPA evaluated the impacts of placing quiescent zones in the lower 10% of
raceways and found no adverse impacts on the production capacity of a facility. The goal of quiescent
zones (QZ) and other in-system solids collection practices is to reduce the TSS (and associated pollutants)
in the effluent.

       Quiescent zones usually are constructed with a wire mesh screen, which extends from the bottom
of the raceway to above the maximum water height, to prohibit the cultured species from entering the
quiescent zone.  The reduction in turbulence, usually caused by the swimming action of the cultured
species, allows the solids to settle in the quiescent zone. Then, the collected solids are available to be
efficiently removed  from the system. The quiescent zones are usually cleaned on a regular schedule,
typically once per week in medium to large systems to remove the settled solids. The Idaho BMP Manual
recommends minimal quiescent zone cleaning of once per month in upper raceways and twice per month
in lower units.  The  settled solids must be removed regularly to prevent breakdown of particles and
leaching of pollutants such as nutrients  and BOD.

       Quiescent zones placed at the bottom or end of each rearing unit or raceway allow for the settling
of pollutants before  they are discharged to other production units (when water is serially reused in several
rearing units) or receiving waters.
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       4.2.2   Sedimentation Basins (Gravity Separation)

       Sedimentation basins are a technology control considered in Option 1 for all flow-through and
recirculating CAAP facilities as a part of primary solids removal. Sedimentation basins at flow-through
facilities can be in the form of offline or full-flow. Offline settling treats a portion of the flow-through
effluent volume in which solids have been concentrated. When offline settling is used, treatment
technologies to concentrate solids (e.g., quiescent zones) are also used.  Full-flow settling treats the entire
flow-through effluent volume. For recirculating systems, sedimentation basins are  used to treat the waste
stream that is discharged from the recirculating system.

       Sedimentation, also known as settling, separates solids from water using gravity settling of the
heavier solid particles.  In the simplest form of sedimentation, particles that are heavier than water settle
to the bottom of a tank or basin.  Sedimentation basins (also called settling basins, settling ponds,
sedimentation ponds, or sedimentation lagoons) are used extensively in the wastewater treatment  industry
and are commonly found in many flow-through and recirculating aquatic animal production facilities
(EPA, 2001). Most sedimentation basins are used to produce a clarified effluent (for solids removal), but
some sedimentation basins remove water from solids to produce a more concentrated sludge.  Both of
these applications of sedimentation basins are used and are important in aquatic animal production
systems.

       Periodically, when accumulating solids  exceed the designed storage capacity of the basin, the
basin is cleaned of the accumulated solids.  EPA found that cleaning frequencies of sedimentation basins
used at CAAP facilities ranged from two to twelve times per year depending on the size of the facility.
For estimating costs, EPA used a cleaning frequency of nine times per year to capture some of the
variation in cleaning frequencies used by the industry. By sizing sedimentation basins for a cleaning
frequency of nine times per year, the basin volume will be larger than for a cleaning frequency of twelve
times per year.  The extra storage will  also provide a safety factor to accommodate facilities that cannot
use a solids disposal method, such as land application, which requires year round access to application
sites.
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        The primary advantages of sedimentation basins for removing suspended solids in effluents from
aquatic animal production systems are the relative low cost of designing, constructing, and operating
sedimentation basins; the low technology requirements for the operators; and the demonstrated
effectiveness of their use in treating similar effluents.  In many aquatic animal production systems, most
of the solids from feces and uneaten feed are of sufficient size to settle efficiently in most moderately
sized (i.e., 37 ft3 to 741 ft3) sedimentation basins, without using chemical addition. Many of the pollutants
of concern in aquatic animal production system effluents can be partly or wholly removed with the solids
captured in a sedimentation basin. Much of the phosphorus tends to bind with the solids, BOD and
organic nitrogen are in the form of organic particles in the fish feces and uneaten feed, and some other
compounds, such as oxytetracycline, were found in the sediments captured in sedimentation basins in
EPA's sampling data.

        Disadvantages of sedimentation basins include the need to clean out accumulated solids, the
potential odor emitted from the basin under normal operating conditions, and the inability of the basins to
remove small-sized  particles without chemical addition.  Accumulated solids must be periodically
removed and properly disposed of through land application or other sludge disposal methods.  For the
purpose of costing, EPA assumed no cost associated with the disposal of collected solids in flow-through
and recirculating systems.  EPA based this assumption  on the observation that there are several
alternatives for  CAAP facilities that collect solids, which offer a no cost impact to the facility. Collected
solids can be used as a valuable fertilizer taken for free by local farmers  and gardeners.   System
operators should maintain or increase the efficiency of sedimentation basins by cleaning quiescent zones
as frequently as possible and attempt to minimize the breakdown of particles (into smaller sizes) by
avoiding cleaning methods that tend to grind up the particles. Industry representatives report that existing
aquatic animal production systems might have limited available space for the installation of properly sized
sedimentation basins.  Therefore included in the cost for sedimentation basins is a cost for the purchase of
land.
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       4.2.3   Solids Control Best Management Practices (BMP) Plan

       Solids control BMP plans are considered as a management practice for all CAAP facilities under
Option 1.  All requirements and costs associated with the solids control BMP Plans are assumed to be
equal for all species and culture systems.

       Evaluating and planning site-specific activities to control the release of solids from CAAP
facilities is a practice currently required in several EPA Regions as part of individual and general NPDES
permits (e.g., shrimp pond facilities in Texas, net pens in Maine, and flow-through facilities in Washington
and Idaho).  BMP plans in these permits require the facility operators to develop a management plan for
removed solids and prevention of excess feed from entering the system. The BMP plan also ensures
planning for proper operation and maintenance of equipment, especially treatment control technologies.
Implementation of the BMP plan results in a series  of pollution prevention activities, such as ensuring that
employees do not waste feed and planning for the implementation of other O&M activities, which are
costed under each technology control or BMP.
       4.2.4   Compliance Monitoring

       Compliance monitoring is a management practice considered under Option 1 for all flow-through
and recirculating systems. In addition, for flow-through and recirculating facilities that would be subject to
compliance with numeric limitations, EPA proposed an alternative compliance provision that would allow
facilities to develop and implement a BMP plan to control solids provided the permitting authority
determines the plan will achieve the numeric limitations (see proposed 40 CFR 451.4). For the purpose of
estimating costs, EPA assumed compliance monitoring for CAAP facilities was a function of the
production level on production system used at the facility. EPA assumed that all costs related to
compliance monitoring  would be  included under operation and maintenance costs. The O&M costs for
monitoring consist of two components, 1) the labor associated with sampling (e.g., collecting the sample
and preparing it for transport) and transport of the sample to the lab and 2) sampling materials (e.g.,
bottles) and analysis.
                                              4-6

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       4.2.5   Feed Management

       Feed management is a management practice considered under Option 1 for all net pen operations.
Feed management recognizes the importance of effective, environmentally sound use of feed. Net pen
operators should continually evaluate feeding practices to ensure that feed placed in the production
system is consumed at the highest rate possible. Observing feeding behavior and noting the presence of
excess feed can be used to adjust feeding rates to ensure minimal excess.  An advantage of this practice
is that proper feed management decreases the costs associated with the use of excess feed that is never
consumed by the cultured species. Excess feed distributed to net pens breaks down, and some of the
resulting products remain dissolved in the receiving water. More importantly, solids from the excess feed
usually settle and are naturally processed along with feces from the aquatic animals. Excess feed and
feces accumulate under net pens, and if there is  inadequate flushing this accumulation can overwhelm the
natural benthic processes  resulting in increased benthic degradation.

The primary operational factors associated with proper feed management include development of precise
feeding regimes based on the weight of the cultured species and constant observation of feeding activities
to ensure that the feed offered is consumed. Other feed management practices include using high quality
feeds, proper storage and handling (which includes keeping feed in cool, dry places, protecting feed from
rodents and mold conditions, and handling gently to prevent breakage of the pellets), and feeding pellets of
proper size.  Feed management is a practice required in net pen facility permits issued by EPA Regions 1
and 10.  Feed management costs are O&M costs for the extra time required will be used to observe
feeding behavior and perform additional record keeping (i.e., amount of feed added to each net pen, along
with records tracking the number and size offish in the pen). The record keeping duties involve filling in a
logbook.
       4.2.6   Drugs and Chemical Management

       The drugs and chemical BMP plan proposed under Option 2 for large flow-through systems
(producing 475,000 pounds or more annually), net pens and recirculating systems. All requirements and
costs associated with the Drugs and Chemical BMP Plan are estimated to be equal for all species and
culture systems.  The purpose of the BMP plan is to avoid spillage or inadvertent release of drugs and
                                               4-7

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chemicals, and ensure the proper disposal of mortalities.  Facilities producing non-native species must also
develop and implement practices to minimize the potential escape of the non-native species.  BMP plans
must be prepared and certified by the facility owner or operator.  Employees of the facility must be
familiar with the BMP plan and be adequately trained in the specific procedures that the BMP plan
requires. Facilities must also report the use of any drug not used according to the label and investigational
new animal drugs.  Oral reports are required within 7 days after initiating treatment with drugs not used
according to the label and written reports within 30 days after completion of the treatment for drugs not
used according to the label and investigational new animal drugs.
       4.2.7   Additional Solids Removal (Solids Polishing)

       Additional solids removal is considered under Option 3 for flow-through systems and recirculating
systems.  The term "solids polishing" refers to the use of a wastewater treatment technology to further
reduce solids discharged from sedimentation basins used to treat flow-through and recirculating systems.
Several technologies are available, including microscreen filters and polishing ponds. For the purpose of
cost analysis, EPA assumed that microscreen filters were used.  Microscreen filters consist of fine mesh
filters that are usually fitted to a rotating drum. The wastewater stream is pumped into the inside of the
drum and solids are removed from the effluent as the water passes through the screen. The screen size
usually varies between 60 and 90 microns. The filters are equipped with automatic backwash systems that
remove collected solids from the screen and direct them to further treatment or solids storage.
       4.2.8   Active Feed Monitoring

       Active feed monitoring is considered as a management practice in Option 3 for all net pen
facilities. Active feed monitoring is a relatively new (but proven and used by some facility operators in the
salmon industry) technology that uses some type of remote monitoring equipment such as an underwater
video camera lowered from the surface to the bottom of a net pen during feeding to monitor for uneaten
feed pellets as they pass by the video camera.  The goal of active feed monitoring is to further reduce
pollutant loads associated with feeding activities. A variety of technologies have been reported, including
                                               4-8

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video cameras with human or computer interfaces to detect passing feed pellets. A new NPDES permit
issued in Maine (USEPA, 2002b) also suggests that ultrasonic equipment may be available. Most facilities
that use this technology use a video monitor at the surface that is connected to the video camera. An
employee watches the monitor for feed pellets passing by the video camera and then stops feeding
activity  when a predetermined number of pellets (typically only two or three) pass the camera.
4.3     COMPLIANCE COST ESTIMATION

        EPA estimated compliance costs based on the implementation of the practices or technologies to
meet particular requirements.  EPA developed computer cost equations to estimate compliance costs for
each model facility and regulatory option based on information collected during the site visits, sampling
events, published information, vendor contacts, and engineering judgment. Costs were calculated for each
technology or practice that make up each regulatory option for each model facility. EPA based cost
estimates on model facility characteristics, including system type, species, feeding strategy, size, and
system specific characteristics. (The options are described in Chapter 6 of this document.)

        The cost estimates generated contain the following types of costs: (1) Capital costs—costs for
facility upgrades (e.g., construction  projects), including land costs and other capital costs  (equipment,
labor, design, etc.); (2) one-time non-capital costs—one-time costs for items that cannot  be amortized
(e.g., consulting services or training); and (3) annual operating and maintenance (O&M)  costs—annually
recurring costs, which may be positive or negative. A positive O&M cost indicates an annual cost to
operate, and a negative O&M cost indicates a benefit to operate, due to cost offsets. The term "unit
cost" refers to the capital, one-time, and O&M costs for a technology.

        Tables 4-1 through 4-3 summarize the  unit costs developed for each option for each model facility
in the Lower 48 States. Tables 4-4 through 4-6 summarize the costs developed for each option for  each
Alaska facility.  Alaska provided facility-level information to  EPA; hence, EPA could develop cost
estimates for each individual facility.  Chapter 8 in the Technical Development Document contains a more
detailed discussion on the derivation of these costs (EPA, 2002a).
                                               4-9

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4.4    FREQUENCY FACTORS


       EPA recognizes that some individual facilities have already implemented some treatment

technologies or best management practices that were described in Section 4.2. EPA uses the term
"frequency factor" to describe the portion of the regulated universe that already had a particular
technology or treatment practice in place. Facilities that already have the component in place would not

incur additional costs for that component as a result of the proposed regulation.  If a cost component has
frequency factor value of 0, the cost for that component is incurred by all facilities. If a cost component

has a frequency factor of 1, the cost for that component is incurred by none of the facilities.


       EPA estimated frequency factors based on sources such as those listed below.  (Each source

was considered along with its limitations.)
               EPA site visit information was used to assess general practices of CAAP operations and
               how they vary between regions and size classes.

               Screener survey data were used to assess general practices of CAAP operations and
               how they vary between regions and size classes.

               Observations on CAAP operations by industry experts that were contacted to provide
               insight into operations and practices, especially where data were limited or not publicly
               available.

               USDA National Agricultural Statistical Service (NASS)—The data currently available
               from 1998 Aquaculture Census were used to determine the distribution of AAP
               operations across the regions by size class.

               USDA APHIS National Animal Health Monitoring System (NAHMS)—This source
               provides information on catfish production.

               State Compendium: Programs and Regulatory Activities Related to Aquatic Animal
               Production was used to estimate frequency factors, based on current requirements for
               treatment technologies and BMPs that already apply to CAAP facilities in various states.
               For example, BMP plans  are required for all facilities with permits in Idaho and
               Washington, so the facilities from these states were assumed to have solids control BMP
               plans in place.
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       Tables 4-1 through 4-6 also contain the associated frequency factors for each technology by
model facility. Section 5.1.4 explains how EPA uses these frequency factors in evaluating the range of

compliance costs that a facility might incur under each option while Section 5.2 describes how EPA uses

these frequency factors when calculating the national industry costs for each option.
4.5    REFERENCES
EPA. 2002a.  United States Environmental Protection Agency. Development Document for Proposed
Effluent Limitations Guidelines and Standards for the Aquatic Animal Production Industry Point Source
Category.  EPA 821-R-02-016. Washington, DC.

EPA. 2002b.  United States Environmental Protection Agency. Detailed Questionnaire for the Aquatic
Animal Production Industry. OMB Control Number 2040-0240. Washington, DC. April

EPA. 2001. United States Environmental Protection Agency.  Screener Questionnaire for the Aquatic
Animal Production Industry. OMB Control Number 2040-0237. Washington, DC. July.

USDA  2000. United States Department of Agriculture.  National Agricultural Statistics Service. 1998
Census  ofAquaculture. Also cited as 1997 Census of Agriculture. Volume 3,  Special Studies, Part 3.
AC97-SP-3. February.
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           Table 4-1
  Non-Alaska Model Facilities
Unit Costs—Regulatory Option 1
Regulatory Option 1 Unit Costs and Frequency Factors
Species
Trout- Flow-through
Trout- Flow-through
Trout- State Flow-through
Trout- State Flow-through
Trout Stockers-Flow-through
Trout Stockers-Flow-through
Trout Stockers- Federal FT
Trout Stockers- Federal FT
Trout Stockers- State FT
Trout Stockers- State FT
Trout Stockers- Other FT
Trout Stockers- Other FT
Tilapia- Flow-through
Tilapia- Flow-through
Tilapia- Recirculating
Striped Bass-FT
Model
Medium
Large
Medium
Large
Medium
Large
Medium
Large
Medium
Large
Medium
Large
Medium
Large
Large
Medium
Count
22
8
<5
<5
5
0
7
<5
44
<5
<5
<5
<5
<5
5
<5
Feed Management
Capital
—
—
—
—
—
—
	
	
	
—
—
—
—
—
—
—
Feed Management
O&M
—
—
—
—
—
—
	
	
	
—
—
—
—
—
—
-
Feed Management
Frequency
—
—
—
—
—
—
	
	
	
—
—
—
—
—
—
-
Quiescent Zone
Capital
$7,195.56
$53,367.07
$7,795.19
$11,992.60
$6,595.93
$0.00
$7,195.56
$29,381.87
$7,195.56
$10,793.34
$12,592.23
$10,193.71
$8,394.82
$21,586.68
—
$3,911.33
Quiescent Zone
O&M
$4,339.28
$28,974.66
$4,659.22
$6,898.80
$4,019.34
$0.00
$4,339.28
$16,177.06
$4,339.28
$6,258.92
$7,218.74
$5,938.98
$4,979.16
$12,017.84
—
$2,586.94
Quiescent Zone
Frequency Factor
0.91
1.00
1.00
1.00
1.00
0.00
0.57
0.50
0.91
1.00
1.00
1.00
0.67
1.00
—
1.00
             4-12

-------
     Table 4-1 (continued)
  Non-Alaska Model Facilities
Unit Costs—Regulatory Option 1
Regulatory Option 1 Unit Costs and Frequency Factors (continued)
Species
Trout- Flow-through
Trout- Flow-through
Trout- State Flow-through
Trout- State Flow-through
Trout Stockers-Flow-through
Trout Stockers-Flow-through
Trout Stockers- Federal FT
Trout Stockers- Federal FT
Trout Stockers- State FT
Trout Stockers- State FT
Trout Stockers- Other FT
Trout Stockers- Other FT
Tilapia- Flow-through
Tilapia- Flow-through
Tilapia- Recirculating
Striped Bass-FT
Striped Bass-FT
Striped Bass-Recirculating
Salmon-Other Flow-through
Salmon-Other Flow-through
Salmon-Net Pen
Model
Medium
Large
Medium
Large
Medium
Large
Medium
Large
Medium
Large
Medium
Large
Medium
Large
Large
Medium
Large
Large
Medium
Large
Large
Count
22
8
<5
<5
5
0
7
<5
44
<5
<5
<5
<5
<5
5
<5
0
<5
0
<5
8
BMP Plan
Capital
$1,076.80
$1,076.80
$1,076.80
$1,076.80
$1,076.80
$0.00
$1,076.80
$1,076.80
$1,076.80
$1,076.80
$1,076.80
$1,076.80
$1,076.80
$1,076.80
$1,076.80
$1,076.80
$0.00
$1,076.80
$0.00
$1,076.80
$1,076.80
BMP Plan
O&M
$918.36
$918.36
$918.36
$918.36
$918.36
$0.00
$918.36
$918.36
$918.36
$918.36
$918.36
$1,381.32
$918.36
$918.36
$918.36
$918.36
$0.00
$918.36
$0.00
$918.36
$253.80
BMP Plan
Frequency Factor
0.32
1.00
0.00
0.00
0.60
$0.00
0.14
0.50
0.02
0.00
1.00
1.00
0.00
0.00
0.40
0.00
$0.00
0.00
$0.00
0.00
0.13
Monitoring
Capital
$0.00
0.00
0.00
0.00
0.00
$0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
$0.00
0.00
$0.00
0.00
—
Monitoring
O&M
$2,731.92
$2,731.92
$2,731.92
$2,731.92
$2,731.92
$0.00
$2,731.92
$2,731.92
$2,731.92
$2,731.92
$2,731.92
$2,731.92
$2,731.92
$2,731.92
$2,731.92
$2,731.92
$0.00
$2,731.92
$0.00
$2,731.92
—
Monitoring
Frequency Factor
0.32
1.00
0.00
0.00
0.60
0.00
0.14
0.50
0.02
0.00
1.00
1.00
0.00
0.00
0.40
0.00
0.00
0.00
0.00
0.00
—
             4-13

-------
           Table 4-2
  Non-Alaska Model Facilities
Unit Costs—Regulatory Option 2
Regulatory Option 2 Unit Costs and Frequency Factors
Species
Trout- Flow-through
Trout- Flow-through
Trout- State Flow-through
Trout- State Flow-through
Trout Stockers-Flow-through
Trout Stockers-Flow-through
Trout Stackers- Federal FT
Trout Stackers- Federal FT
Trout Stackers- State FT
Trout Stackers- State FT
Trout Stackers- Other FT
Trout Stackers- Other FT
Tilapia- Flow-through
Tilapia- Flow-through
Tilapia- Recirculating
Striped Bass-FT
Striped Bass-FT
Striped Bass-Recirculating
Salmon-Other Flow-through
Salmon-Other Flow-through
Model
Medium
Large
Medium
Large
Medium
Large
Medium
Large
Medium
Large
Medium
Large
Medium
Large
Large
Medium
Large
Large
Medium
Large
Count
22
8
<5
<5
5
0
7
<5
44
<5
<5
<5
<5
<5
5
<5
0
<5
0
<5
Drugs & Chemical BMP
Plan Capital
$1,076.80
$1,076.80
$1,076.80
$1,076.80
$1,076.80
$0.00
$1,076.80
$1,076.80
$1,076.80
$1,076.80
$1,076.80
$1,076.80
$1,076.80
$1,076.80
$1,076.80
$1,076.80
$0.00
$1,076.80
$0.00
$1,076.80
Drugs & Chemical
BMP Plan O&M
$253.80
$253.80
$253.80
$253.80
$253.80
$0.00
$253.80
$253.80
$253.80
$253.80
$253.80
$253.80
$253.80
$253.80
$253.80
$253.80
$0.00
$253.80
$0.00
$253.80
Drugs & Chemical BMP
Plan Frequency Factor
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Monitoring
Capital
$0.00
0.00
0.00
0.00
0.00
$0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
$0.00
0.00
$0.00
0.00
Monitoring
O&M
$2,731.92
$2,731.92
$2,731.92
$2,731.92
$2,731.92
$0.00
$2,731.92
$2,731.92
$2,731.92
$2,731.92
$2,731.92
$2,731.92
$2,731.92
$2,731.92
$2,731.92
$2,731.92
$0.00
$2,731.92
$0.00
$2,731.92
Monitoring Frequency
Factor
0.32
1.00
0.00
0.00
0.60
0.00
0.14
0.50
0.02
0.00
1.00
1.00
0.00
0.00
0.40
0.00
0.00
0.00
0.00
0.00
             4-14

-------
           Table 4-3
  Non-Alaska Model Facilities
Unit Costs—Regulatory Option 3
Regulatory Option 3 Unit Costs and Frequency Factors
Species
Trout- Flow-through
Trout- Flow-through
Trout- State Flow-through
Trout- State Flow-through
Trout Stockers-Flow-through
Trout Stockers-Flow-through
Trout Stackers- Federal FT
Trout Stackers- Federal FT
Trout Stackers- State FT
Trout Stackers- State FT
Trout Stackers- Other FT
Trout Stackers- Other FT
Tilapia- Flow-through
Tilapia- Flow-through
Tilapia- Recirculating
Striped Bass-FT
Model
Medium
Large
Medium
Large
Medium
Large
Medium
Large
Medium
Large
Medium
Large
Medium
Large
Large
Medium
Count
22
8
<5
<5
5
0
7
<5
44
<5
<5
<5
<5
<5
5
<5
Solids Polishing
Capital
$8,052.91
$8,574.86
$8,052.91
$8,052.91
$8,052.91
$0.00
$8,052.91
$8,052.91
$8,052.91
$8,052.91
$8,052.91
$8,052.91
$8,052.91
$8,052.91
$8,052.91
$8,052.91
Solids Polishing
O&M
$1,861.32
$1,861.32
$1,862.32
$1,861.32
$1,861.32
$0.00
$1,861.32
$1,861.32
$1,861.32
$1,831.32
$1,861.32
$1,861.32
$1,861.32
$1,861.32
$1,861.32
$1,861.32
Solids Polishing
Freauencv Factor
0.09
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.05
0.00
0.00
0.00
0.00
0.00
0.40
1.00
Monitoring
Capital
—
0.00
—
0.00
—
0.00
—
0.00
—
0.00
—
0.00
—
0.00
0.00
-
Monitoring
O&M
—
4171.92
—
4171.92
—
4171.92
—
4171.92
—
4171.92
—
4171.92
—
4171.92
4171.92
-
Monitoring
Freauencv Factor
—
1.00
—
0.00
—
0.00
—
0.50
—
0.00
—
1.00
—
0.00
0.40
-
Active Feed
Monitoring Capital
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
-
             4-15

-------
           Table 4-4
        Alaska Facilities
Unit Costs—Regulatory Option 1
Regulatory Option 1 Unit Costs and Frequency Factors
Facility
Facility 1
Facility 2
Facility 3
Facility 4
Facility 5
Facility 6
Facility 7
Facility 8
Facility 9
Facility 10
Facility 11
Facility 12
Facility 13
Facility 14
Facility 15
Facility 16
Facility 17
Facility 18
Harvest
201,052
204,139
144,436
135,510
403,515
150,822
125,720
207,649
985,194
116,636
366,030
244,543
571,095
145,089
222,290
250,047
104,738
153,371
Quiescent
Zone Capital
6,378.67
6,476.61
4,582.44
4,299.25
12,802.10
4,785.05
3,988.65
6,587.97
31,256.71
3,700.45
11,612.83
7,758.48
18,118.82
4,603.16
7,052.47
7,933.10
3,322.97
4,865.92
Quiescent
Zone O&M
5,933.51
6,016.94
4,403.44
4,162.21
11,405.15
4,576.02
3,897.63
6,111.80
27,125.26
3,652.13
10,392.11
7,108.87
15,934.07
4,421.09
6,507.48
7,257.62
3,330.59
4,644.91
Quiescent Zone
Frequency Factor
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Settling Basin
Capital
24,884.00
25,252.76
17,862.69
16,796.40
49,715.01
18,625.54
15,626.91
25,672.06
121,265.81
14,541.75
45,108.09
30,208.38
70,378.97
17,940.69
27,421.04
30,865.88
12,991.40
19,059.08
Settling
Basin O&M
5,071.32
5,075.47
4,995.29
4,983.30
5,343.22
5,003.87
4,970.16
5,080.18
6,124.40
4,957.96
5,292.88
5,129.73
5,568.28
4,996.17
5,099.85
5,137.12
4,941.98
5,007.29
Settling Basin
Frequency Factor
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Monitoring
Capital
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Monitoring
O&M
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
Monitoring
Frequency Factor
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
             4-16

-------
      Table 4-4 (continued)
        Alaska Facilities
Unit Costs—Regulatory Option 1
Regulatory Option 1 Unit Costs and Frequency Factors (continued)
Facility
Facility 1
Facility 2
Facility 3
Facility 4
Facility 5
Facility 6
Facility 7
Facility 8
Facility 9
Facility 10
Facility 11
Facility 12
Facility 13
Facility 14
Facility 15
Facility 16
Facility 17
Facility 18
Harvest
201,052
204,139
144,436
135,510
403,515
150,822
125,720
207,649
985,194
116,636
366,030
244,543
571,095
145,089
222,290
250,047
104,738
153,371
BMP Plan
Capital
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
BMP Plan
O&M
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
BMP Plan
Frequency Factor
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Monitoring
Capital
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Monitoring
O&M
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
Monitoring
Frequency Factor
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
             4-17

-------
           Table 4-5
        Alaska Facilities
Unit Costs—Regulatory Option 2
Regulatory Option 2 Unit Costs and Frequency Factors
Facility
Facility 1
Facility 2
Facility 3
Facility 4
Facility 5
Facility 6
Facility 7
Facility 8
Facility 9
Facility 10
Facility 11
Facility 12
Facility 13
Facility 14
Facility 15
Facility 16
Facility 17
Facility 18
Harvest
201,052
204,139
144,436
135,510
403,515
150,822
125,720
207,649
985,194
116,636
366,030
244,543
571,095
145,089
222,290
250,047
104,738
153,371
Drugs &
Chemical
BMP Plan
Capital
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
1,710.40
Drugs &
Chemical
BMP Plan
O&M
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
1,277.64
Drugs & Chemical
BMP Plan
Frequency Factor
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Monitoring
Capital
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Monitoring
O&M
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
2,731.92
Monitoring
Frequency Factor
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
             4-18

-------
           Table 4-6
        Alaska Facilities
Unit Costs—Regulatory Option 3
Regulatory Option 3 Unit Costs and Frequency Factors
Facility
Facility 1
Facility 2
Facility 3
Facility 4
Facility 5
Facility 6
Facility 7
Facility 8
Facility 9
Facility 10
Facility 11
Facility 12
Facility 13
Facility 14
Facility 15
Facility 16
Facility 17
Facility 18
Harvest
201,052
204,139
144,436
135,510
403,515
150,822
125,720
207,649
985,194
116,636
366,030
244,543
571,095
145,089
222,290
250,047
104,738
153,371
Solids Polishing
Capital
8,052.91
8,052.91
8,052.91
8,052.91
8,052.91
8,052.91
8,052.91
8,052.91
8,052.91
8,052.91
8,052.91
8,052.91
8,052.91
8,052.91
8,052.91
8,052.91
8,052.91
8,052.91
Solids Polishing
O&M
2,320.48
2,320.48
2,320.48
2,320.48
2,320.48
2,320.48
2,320.48
2,320.48
2,320.48
2,320.48
2,320.48
2,320.48
2,320.48
2,320.48
2,320.48
2,320.48
2,320.48
2,320.48
Solids Polishing
Frequency Factor
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Monitoring
Capital
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Monitoring
O&M
5,405.04
5,405.04
5,405.04
5,405.04
5,405.04
5,405.04
5,405.04
5,405.04
5,405.04
5,405.04
5,405.04
5,405.04
5,405.04
5,405.04
5,405.04
5,405.04
5,405.04
5,405.04
Monitoring
Frequency Factor
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
             4-19

-------
                                         CHAPTER 5

                       ECONOMIC IMPACT METHODOLOGY

       This section provides an overview of the methodology used in the economic impact analysis.
Section 5.1 discusses EPA's facility impact analysis using a revenue test while Section 5.2 describes each
step in the analysis.   Section 5.3 summarizes the approach used to calculate the incremental industry
compliance costs while Section 5.4 describes the adjustment to the commercial cost estimate to obtain the
national industry compliance costs for the rule.  Section 5.5 discusses the structure of EPA's Best
Conventional Technology (BCT) cost test.
5.1    FACILITY ANALYSIS

       5.1.1   Revenue Test

       EPA used the facility production data from the screener survey, combined with available price
data from the Census and other sources, to estimate revenues for the model facilities for which the
Agency estimated costs. EPA calculated model facility impacts using the test measure of the ratio of the
estimated annual compliance costs to revenue from aquacultural sales  (hereafter referred to as a
"revenue test").        EPA calculated the revenue test as:

                                     Pre -tax annualizedcompliance cost
                                   Estimated revenues from aquaculture sales

for each model facility configuration. The costs were annualized over a ten-year period with a seven
percent real discount rate and included a mid-year convention for putting any new equipment into
operation (i.e., six months between purchase, installation, and operation). EPA calculated pre-tax
annualized costs for two reasons: these costs are compared to pre-tax revenue and EPA had no data or
information on which to estimate a post-tax cost.
                                               5-1

-------
       5.1.2   Alternative Approaches Considered

       No financial data were collected in EPA's screener survey and the USDA Census collected only
revenue data. Neither the 1998 Census of Aquaculture (USDA, 2000; hereafter referred to as "the
Census") nor EPA's screener survey collected data on farm-level operating costs. This absence of
matched pairs of cost and revenue limited EPA's efforts in developing the economic analysis for
proposal. The Census collected information on revenues from aquaculture sales (not including other
farm-related revenues from other agricultural crops at the facility) while the screener survey collected
aquatic animal production data at the facility.  EPA could not calculate the test measure of the ratio of the
estimated annual compliance costs to facility profit (otherwise known as a "profit test") due to the
absence of corresponding cost data. EPA is currently in the process of collecting  detailed facility-level
economic data on concentrated aquatic animal producers, including matched pairs of cost and revenue
data, and intends to perform a detailed financial analysis on this real-world data for final promulgation.

       EPA considered alternative approaches to the revenue test used to examine economic impacts to
the industry, including developing representative model facilities based on enterprise budget data.  EPA
determined these alternative approaches to be  infeasible given the lack of information on the distribution
of profits among aquatic animal producers.  EPA's examination of the feasibility of using an enterprise
budget approach to analyze economic impacts is summarized in the rulemaking record (DCNs 20146-
20150 and 20152-20155).
       5.1.3   Revenue Estimates for Non-Commercial Facilities

       While some non-commercial facilities—Federal and state hatcheries, academic and research
facilities, and tribal facilities— might sell some of their production, most fish and egg distribution from
these facilities have no market transaction (that is, they are not sold). The industry profile (Chapter 2)
stresses the differences between commercial and non-commercial facilities, but the economic analysis is
constrained by the absence of cost and/or funding data for non-commercial facilities until detailed survey
data are available.  Given the data available at this time—production level from the screener survey and
market value from the Census—the only measure by which to evaluate impacts is to impute a value to
their production based on annual harvest and commercial prices.

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       5.1.4   Revenue Estimates for Alaskan Facilities

       Alaskan non-profit facilities have a unique financial structure (see Section 2.5.3 for further
discussion).  Alaskan facilities practice ocean ranching where the salmon smolts are released to the sea.
A non-profit corporation is allowed to harvest adult salmon that return to the region.  In addition, reginal
corporations vote on a self-imposed tax of 1, 2, or 3 percent of the ex-vessel value offish in the region
caught.  Alaska provided operator-reported revenues and enhancement tax revenues for each facility
(Alaska, 2002). For these facilities, EPA compared the annualized compliance costs to the sum of
operator-reported revenues and enhancement tax revenues (Alaska, 2002).
5.2     STEPS IN THE FACILITY ANALYSIS

        The analysis of economic impacts includes the following steps: (1) assessing the number of
facilities that could be affected by this rule; (2) estimating the annualized incremental compliance costs for
model facilities to comply with the different requirements identified in the rule; (3) calculating model
facility impacts using the revenue test; and  (4) extrapolating from the individual model facility results to
estimate facility impacts at the national level (i.e., in the regulated universe) using the revenue test.  Each
of these steps is discussed below.
       5.2.1   Calculation of Annualized Costs for Individual Option Components

       EPA's engineering staff developed estimates of the capital, one-time non-equipment1, and
operating and maintenance (O&M) costs for incremental pollution control in the aquatic animal
production industry.  The capital cost, a one-time cost, is the initial investment needed to purchase and
install the equipment.  The one-time non-equipment cost is incurred in its entirety in the first year of the
        1A one-time non-equipment cost is best explained by example, such as an engineering study that
recommends improved operating parameters as a method of meeting effluent limitations guidelines.  One-
time non-equipment costs cannot be depreciated because the product is not associated with property that
wears out, nor is it an annual expense.
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model. The O&M cost is the annual cost of operating and maintaining the equipment; the site incurs it
each year.

       There are two reasons for the annualization of capital, one-time non-capital, and O&M costs.
First, the capital cost is incurred only once in the equipment's lifetime; therefore, initial investment should
be expended over the life of the equipment. Second, money has a time value.  A dollar today is worth
more than a dollar in the future; expenditures incurred 10 years from now do not have the same value to
the firm as the same expenditures incurred tomorrow. The model develops a time series for cash flows
involving pollution control capital, one-time non-capital, and annual O&M costs.  The cash outflows are
then discounted to calculate the present value of future cash outflows in terms of dollars for the first year
of the model.  This methodology evaluates what a business would pay in constant dollars for all initial and
future expenditures.  Finally, the model calculates the annualized cost for the cash outflow as an annuity
that has the same present value of the cash outflows and includes  the cost of money or interest.  The
annualized cost is analogous to a mortgage payment that spreads the one-time investment of a home into a
defined series of monthly payments.

       Because EPA is  evaluating only pre-tax annualized costs at this time, only three additional
parameters are needed for the cost annualization model:
        •      Interest rate, discount rate,  or opportunity cost of capital
               EPA uses the Office of Management and Budget (OMB) recommendation of seven
               percent real discount rate for the opportunity cost of capital and three percent for
               discounting benefits (OMB, 1992).
        •      Time period for annualization
               EPA uses a 10-year period for cost annualization in the rulemakings for animal feeding
               operations and aquatic animal production industry.  The time period coincides with
               equipment lifetime for major equipment expenditures and Internal Revenue Service (IRS)
               definitions that place single-purpose agricultural structures as 10-year property (IRS,
               1999).
        •      Mid-year convention for putting equipment in service, that is, a six-month lag between the
               time the initial monetary outlay is made and  when the enterprise goes into operation.

EPA intends to use a more complex cost annualization model for final promulgation which takes into
account depreciation schedules, differentiation between non-depreciable items such as land and one-time
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non-capital expenditures and depreciable costs, tax shields, and tax rates that differ earnings level for
corporate and individuals to calculate post-tax annualized costs.
        5.2.2   Identification of Possible Facility Option Costs


        EPA identified several technologies and treatment practices that reduce pollutant loadings to a

water body from a concentrated aquatic animal enterprise.  The following is a selected list of technologies

that EPA reviewed as part of the rulemaking process:
               Solids Control Best Management Practices (called solids control BMP or "B" in the
               example below).

               Drugs & Chemical Best Management Practices.

               Quiescent Zone (called "Quiescent" or "Q"). This is a zone with lower currents or water
               activity  (usually at the end of a raceway) that allows solids to settle out of the water
               column.

               Active feed monitoring.  This involves watching the fish in net-pens (e.g., salmon) while
               they feed. The fish are fed until satiation but no more. The purpose is to minimize the
               amount  of uneaten feed in the water column and settling below the pen.

               Settling  Basin (called "Settling" or "S").  This is an area not in line with any raceway or
               other part of the aquaculture system. The purpose of the basin is to allow the water to
               stand for some period of time to let solids drop out of the water column.

               Solids Polishing (called "Polish" or "P").  Effluent is discharged to a pond where it is held
               for a longer period of time to allow natural processes to treat the effluent.
Not all cost components are considered for each production system. Some components are restricted to

certain production systems for technical reasons. EPA considers active feed management for net-pen

systems where it can affect the amount of uneaten feed accumulating beneath the pens, and not other

systems.  Quiescent zones, settling basins, and the subsequent management of the collected nutrients are

associated with flow-through and recirculating systems.


       EPA calculated the range in possible costs incurred by a facility to comply with the proposed or

evaluated option.  For example, suppose an option has three components: (1) solids control BMP plan
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[B], (2) quiescent zone [Q], and (3) settling basin [S]. A facility might incur any one of eight cost
combinations:


        •      B, Q, S (i.e., all three costs are incurred)

        •      B, Q    (site has a settling basin, only BMP plan and quiescent zone cost components
                       apply)

        •      B, S    (site has quiescent zone, only BMP plan and settling basin cost components
                       apply)

        •      B      (site has quiescent zone and settling basin, only solids control BMP cost
                       component applies)

        •      Q, S    (site has BMP plan, only settling basin and quiescent zone cost components
                       apply)

        •      Q      (site has BMP plan and settling basin, only quiescent zone cost component
                       applies)

        •      S       (site has BMP plan and quiescent zone, only settling basin cost component
                       applies)

        •      no cost (site has all three components in place prior to the rulemaking)

EPA calculated the total cost to a facility to implement and operate a technology or treatment practice.

These costs differed according to the production system and annual harvest (pounds) for each model
facility.
        5.2.3   Calculation of the Likelihood of a Facility Incurring Particular Costs


        On the basis of screener survey data, EPA characterized the industry by production system,
species, operator (commercial and non-commercial; the latter includes federal, state, tribal,

academic/research, and other operators), and size. All costs are reported in 2000 dollars unless otherwise
noted.


        EPA also used the screener information to calculate "frequency factors" to account for the
portion of the regulated population that already had a particular treatment practice in place.  For example,
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if three of every ten flow-through facilities already had a quiescent zone in place prior to the regulation,
the quiescent zone frequency factor is 0.30.  This means that seven often facilities might incur the cost of
installing and operating a quiescent zone if it is part of the proposed option. Frequency factors differ by
production system, species, operator, and size (see Tables 4-1 and 4-2).

       In the example given in Section 5.1.3, the probability of a site incurring a cost is the product of (1
minus the frequency factor) for the three components. Likewise, the likelihood of a site incurring no
costs is the product of the three frequency factors. If a cost component has a frequency factor value of 0
or 1, the cost for that component is incurred  by either all or none of the facilities, respectively. Under
these conditions, the number of possible cost combinations is reduced. That is, depending on the value of
the frequency factors, the revenue test needs to examine 1, 2, 4, or 8 possible configurations. The number
of cost combinations for which probabilities  must be calculated therefore differs for each production
system/ species/ owner/ size configuration.

       For example, using the information in Table 4-1, a medium commercial trout flow-through facility
has an 0.0848 probability of incurring no costs to meet Option 1 requirements and an 0.0037 probability of
incurring costs for all components of Option 1 (i.e., the frequency factors are .91 x .91 x .32 x .32 for
quiescent zone, settling basin, BMP plan, and monitoring, respectively).  The frequency factors for large
commercial trout flow-through facilities are all 1.0, hence, none of the eight facilities in this model
category are anticipated to incur costs to meet Option 1 requirements.
       5.2.4   Calculation of Facility Counts Showing Impacts at a Given Revenue Test
               Threshold

       EPA calculated the possible cost combinations for each option for each model facility and
compared these costs to the model facility and evaluated whether a revenue test showed impacts. As
mentioned in Section 5.1.1, EPA used the average annual production from the screener survey and
national average price from Census data to estimate revenues for each commercial model facility.  For
non-commercial facilities, EPA used an imputed revenue based on average production from the screener
survey and national average commercial price from Census data for reasons given in Section 5.1.3. For
Alaskan non-profit corporations, EPA used the sum of operator-reported revenues and enhancement tax
revenues for each facility (see Section 5.1.4).

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        EPA used revenue test thresholds of one, three, five, and ten percent.  EPA used the full pre-tax
annualized cost in the revenue test; that is, EPA did not assume that any portion of the cost could be
passed through to the consumers in terms of higher prices.  EPA is not associating any particular
threshold of the revenue test with facility failure; such a determination will be made on the basis of
facility-specific information collected in the detailed survey.  For purposes of the proposed regulation,
EPA believes that a large percentage of facilities experiencing impacts greater than 5% and/or a small
percentage experiencing impacts greater than 10% indicate disproportionate economic burden.

        For each model facility, EPA calculated the range in costs that potentially could be incurred by
the facility under an option and the likelihood of incurring those costs. In the example given in Section
5.2.3, the hypothetical option consists of three components. Say a model facility has a 50-50 chance of
having each technology or treatment in place.  Each of the eight cost combinations identified in Section
5.2.3 has a 1/8 or 0.125 chance of occurring (that is, .5 x .5 x .5 = .125).  Say that only two cost
combinations have a cost that exceed x percent of revenues where x is the test threshold.  In this case,
0.25 (i.e., the sum of the probabilities of those costs) of the facilities represented by this model facility are
assumed to show impacts under this option.  EPA then multiplies the percentage showing impacts by the
number of facilities in the  screener survey represented by the model facility to estimate the number of
facilities showing impacts  on the revenue test. To continue with the example, say the model facility
represents 40 facilities in the screener survey data. EPA would estimate that 10 facilities would show
impacts at the x percent threshold for that option .
        5.2.5   Sample Calculations

        To illustrate the process discussed in Sections 5.2.1 through 5.2.4, suppose an option has three
components: A with a cost of $10 and a frequency factor of 0.9, B with a cost of $100 and a frequency
factor of 0.5, and C with a cost of $ 1000  and a frequency factor of 0.1.  In the example, these are
annualized costs that take into account capital, annual, and the cost of capital (Section 5.2.1).  A facility
could incur any cost from  $0 (all control practices are in place) to $1110 (none of the control practices are
in place, Section 5.2.2).
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       EPA used the frequency factors  to calculate the probability of a facility incurring a particular
control practice cost combination (Section 5.2.3).  Table 5-1 summarizes the probabilities of a facility
incurring the example costs:

                                           Table 5-1
                      Calculation of Sample Costs and Their Probabilities
Cost
Combination
ABC
AB
AC
A
BC
B
C
no cost
Frequency Factor (or inverse)
A
0.1
0.1
0.1
0.1
0.9
0.9
0.9
0.9
B
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
C
0.9
0.1
0.9
0.1
0.9
0.1
0.9
0.1
Facility
Cost
$1,110
$110
$1,010
$10
$1,100
$100
$1,000
$0
Sum of probabilities
Probability of
Facility Cost
0.045
0.005
0.045
0.005
0.405
0.045
0.405
0.045
1.000
From Table 5-1, we see that the example model facility has a 90 percent probability of incurring a cost of
$1,000 or more. If the example model facility represents 50 facilities and the $1,000 cost shows impacts
at the 1 percent level, EPA estimates that 50 x 0.9 or 45 facilities would show impacts at the 1 percent
revenue test.
5.3    INDUSTRY COSTS

       EPA used the following approach to calculate national industry compliance costs. For each
model facility, EPA calculated the weighted average cost for each component (that is, the cost of the
component times (1 minus the frequency factor) for that component), multiplied the weighted-average
cost by the number of facilities represented by  that configuration, and summed over the components that
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comprise a given option. In the example given in Section 5.2.3, the industry capital cost for each model
facility configuration is calculated as:

(N x UA x [1-FFA]) + (N x UB x [1-FFB]) + (N x UC x [1-FFC])
where:
N      =      number of facilities represented by the model facility configuration
               (taken from EPA screener survey data)
UA     =      capital cost for component A (e.g., solids control BMP plan)
UB     =      capital cost for component B (e.g., quiescent zone)
UC     =      capital cost for component C (e.g., settling basin)
FFA    =      frequency factor for component A
FFB    =      frequency factor for component B
FFC    =      frequency factor for component C

EPA then summed the estimated costs for all the model facility configurations to estimate the industry
compliance cost associated with each option. The industry costs are used in the cost-reasonableness and
nutrient cost-effectiveness calculations.  EPA estimated costs for three size groups based on production:
less than 100,000 pounds/year, between 100,000 and 475,000 pounds/year, and greater than 475,000
pounds/year.  Appendix C discusses EPA's determination of the production thresholds.
5.4    NATIONAL INDUSTRY COMPLIANCE COSTS

       In order to estimate the national pre-tax annualized compliance costs attributed to the proposed
rule, EPA multiplied the compliance costs for commercial facilities identified by the screener by a factor
of 2.5. This factor was estimated by calculating the ratio of the number of potentially regulated
commercial facilities identified in the Census to the number of potentially regulated commercial facilities
identified in the screener survey results. EPA evaluated this comparison by system type and found, for
those potentially regulated facilities, that the ratio was fairly consistent (approximately 2.5).  A more
detailed explanation of this analysis can be found in the rulemaking record (Terra Tech, 2002).  EPA
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believes it was able to identify all public facilities in the screener, so these compliance costs did not need
to be adjusted.
5.5    COST-REASONABLENESS AND BCT COST TESTS

       EPA is evaluating technology options for the control of only conventional parameters at BPT.2
CWA Section 304(b)(l)(B) requires a cost-reasonableness assessment for BPT limitations.  In
determining BPT limitations, EPA must consider the total cost of treatment technologies in relation to the
effluent reduction benefits gained by such technology. This inquiry does not limit EPA's broad discretion
to adopt BPT limitations that are achievable with available technology unless the required additional
reductions are wholly out of proportion to the costs of achieving such marginal reduction.

       The cost reasonableness ratio is the average cost per pound of pollutants removed by a BPT
regulatory option.  The cost component is measured as total pre-tax annualized costs in 2000 dollars. In
this case, the pollutants removed are conventional pollutants although, in some cases, removals may
include priority and nonconventional pollutants.

       In July 1986, EPA explained how it developed its methodology for setting effluent limitations
based on BCT (EPA, 1986). EPA evaluates the reasonableness of candidate technologies considered for
BCT—those that remove more conventional pollutants than BPT—by applying a two-part cost test: a
POTW test and an industry cost-effectiveness test.

       EPA first calculates the cost per pound of conventional pollutant removed by industrial
dischargers in upgrading from BPT to a BCT candidate technology, and then compares this cost to the
cost per pound of conventional pollutants removed in upgrading Publicly Owned Treatment Works
(POTWs, also called sewage treatment plants)  to advanced secondary treatment (i.e., "the POTW
test").  The upgrade cost to industry must be less than the POTW  benchmark of $0.25 per pound in 1976
dollars or $0.65 per pound in 2000 dollars.  In the industry cost-effectiveness test, the ratio of the cost per
       2 Conventional pollutants considered in the aquatic animal production industry include biological
oxygen demand (BOD) and total suspended solids (TSS).  EPA also evaluated option cost-effectiveness
for nutrients as measured by total nitrogen and total phosphorus.
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pound to go from BPT to BCT divided by the cost per pound to go from raw wastewater to BPT for the
industry must be less than 1.29 (that is, the cost increase must be less than 29 percent).
5.6    REFERENCES
Alaska.  2002.  Alaska Department of Community & Economic Development. Division of Investments.
Fisheries Enhancement Revolving Loan Fund: Program Overview.  February.

EPA. 2001. United States Environmental Protection Agency.  Screener Questionnaire for the Aquatic
Animal Production Industry.  OMB Control Number 2040-0237.  Washington, DC. July.

EPA. 1999. United States Environmental Protection Agency.  Revised Interim Guidance for EPA
Rulewriters: Regulatory Flexibility Act as amended by the Small Business Regulatory Enforcement
Fairness Act.  Washington, DC.  29 March.

EPA. 1997. United States Environmental Protection Agency.  Economic Impact Analysis of Effluent
Limitations Guidelines and Standards for the Organic Chemicals, Plastics and Synthetic Fibers
Industry.  Washington, DC. EPA 440/2/87-007. September.

EPA. 1986. United States Environmental Protection Agency.  Best Conventional Pollutant Technology;
Effluent Limitations Guidelines, Final Rule. Federal Register. 51:24974-25002.  9 July.

IRS.  1999. Internal Revenue Service.  The Complete Internal Revenue Code.  Section 168(e)(D)(i) and
Section 168(1X13). July.

OMB. 1992.  Office of Management and Budget. Guidelines and Discount Rates for Benefit-Cost
Analysis of Federal Programs.  Revised Circular No. A-94.  October.

Terra Tech. 2002.  Screener Conversion Factor.  Technical memorandum to Marta Jordan, EPA from J.
Hochheimer, Terra Tech, dated July 10, 2002. Tetra Tech, Inc., Fairfax, Virginia. DCN 61505.  June.

USDA.  2000.  United States Department of Agriculture.  National Agricultural Statistics Service. 1998
Census  ofAquaculture. Also cited as 1997 Census of Agriculture. Volume 3, Special Studies, Part 3.
AC97-SP-3. February.
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                                     CHAPTER 6
                            REGULATORY OPTIONS:
        DESCRIPTIONS, COSTS, AND CONVENTIONAL REMOVALS
6.1
PROPOSED SUBCATEGORIES AND OPTIONS
       Table 6-1 summarizes the options evaluated for each subcategory. The Best Management
Practices (BMP) plan listed for Option 1 addresses solids control.  The drugs and chemicals BMP listed
for Options 2 and 3 addresses general reporting requirements for drug and chemical use.
                                       Table 6-1
                                   Regulatory Options
Option
1
2
3
Subcategory
Flow-through
Sedimentation Basin
Quiescent Zone
BMP plan
Compliance Monitoring
Option 1 plus
Drugs & Chemical BMP
Option 2 plus
Solids Polishing
Recirculating
Sedimentation Basin
Quiescent Zone
BMP plan
Compliance Monitoring
Option 1 plus
Drugs & Chemical BMP
Option 2 plus
Solids Polishing
Net Pens
Feed Management
BMP plan
Option 1 plus
Drugs & Chemical BMP
Option 2 plus
Active Feed Monitoring
6.2    SUBCATEGORY COSTS

       EPA first examined subcategory costs for all facilities meeting the definition of "concentrated
aquatic animal production facilities" that need an NPDES permit under 40 CFR 122.24 and Appendix C.
These are summarized in Table 6-2.  The annual operating and maintenance (O&M) costs are
comparable in order of magnitude to the combined capital and one-time costs, such as equipment, for all
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subcategories.  Total pre-tax annualized costs for Options 1 to 3 are estimated to be: $510,000 to
$930,000 for flow-through systems excluding Alaska; $440,000 to $510,000 for flow-through systems in
Alaska; $31,000 to $45,000 for recirculating systems; and $6,200 to $34,000 for net pen systems.
                                           Table 6-2
                             Option Costs by Subcategory ($2000)
Subcategory
Flow-through
Flow-through
Alaska
Nonprofits
Recirculating
Net Pens
Option
1
2
3
1
2
3
1
2
3
1
2
3
Capital and
One time cost
$750,000
$860,000
$1,653,000
$765,000
$796,000
$941,000
$6.000
$15,000
$47,000
$7,000
$16,000
$66,000
Annual
O&M Cost
$418,000
$444,000
$727,000
$350,000
$358,000
$400,000
$31.000
$33,000
$40,000
$5,000
$7,000
$26,000
Pre-tax
Annualized Costs
$506,000
$545,000
$925,000
$441,000
$453,000
$513,000
$30.000
$34,000
$45,000
$6,000
$9,000
$34,000
       Note: Numbers rounded to nearest $1,000.
       Source: 30 May costs for Flow-through Medium facilities.
       16 May costs for Large Flow-through facilities, Recirculating, and Net Pen Systems.
       23 May 2002 costs for Alaska facilities.
       EPA performed several rounds of costing analysis as it developed the effluent guideline. In
March 2002, EPA developed compliance cost estimates for the six revenue size categories used by
USDA in its Census (see Chapter 2, Table 2-8 and USDA, 2000). Based on the estimated impacts for
each category using the revenue tests, EPA set three production levels:
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        •      below 100,000 pounds per year
        •      100,000 to 475,000 pounds per year
        •      more than 475,000 pounds  per year

Appendix C provides more details on this early analysis. EPA is not proposing effluent limitations
guidelines for CAAP facilities with production below 100,000 pounds per year.

        The flow-through subcategory has the largest number of facilities (120 including Alaskan
nonprofit facilities, 102 excluding Alaska).  EPA estimated the compliance costs for two different size
groups within the subcategory: (1) from 100,000 to 475,000 pounds of annual production, and (2) 475,000
pounds or greater of annual production.  Table 6-3 summarizes the cost information by size.
                                           Table 6-3
                  Flow-through Systems:1 Cost by Annual Production ($2000)
Size
100,000 to 475,000
Pounds
475,000 Pounds
and Greater
Option
1
2
3
1
2
3
Capital and
One Time Cost
$558,000
$652,000
$1,319,000
$192,000
$208,000
$333,000
Annual
O&M
$372,000
$394,000
$649,000
$46,000
$50,000
$78,000
Pre-tax
Annualized
Costs
$435,000
$469,000
$805,000
$70,000
$76,000
$120,000
        1 Excluding Alaskan facilities.
        Note: Numbers rounded to nearest $1,000.
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6.3    COST OF PROPOSED OPTIONS


       EPA is proposing the following options:


       •      Flow-through systems (BPT/BCT/BAT/NSPS)
                      Facilities with less than 100,000 pounds annual production: no regulation
                      Facilities with annual production with 100,000 pounds or more and less than
                      475,000 pounds: Option 1
                      Facilities with 475,000 pounds and greater annual production: Option 3

       •      Recirculating systems (BPT/BCT/BAT/NSPS)
                      Facilities with less than 100,000 pounds annual production: no regulation
                      Facilities with 100,000 pounds and greater annual production: Option 3

       •      Net Pen systems (BPT/BCT/BAT/NSPS)
                      Facilities with less than 100,000 pounds annual production: no regulation
                      Facilities with 100,000 pounds and greater annual production: Option 3


An analysis of potential costs and impacts to CAAP facilities producing less than 100,000 pounds per year

is located in Section 8.4.1


       Table 6-4 summarizes the pre-tax annualized compliance costs associated with the proposed

options based on the screener survey facility counts.  The data are divided in terms of commercial and

non-commercial groups and annual production category.  (Non-commercial facilities include  Federal and

state hatcheries, Tribal facilities, and academic/research facilities). EPA did not identify any non-

commercial facilities with more than 100,000 pounds of annual production in the recirculating and net  pen

system subcategories.  EPA estimates that the total pre-tax annualized compliance costs attributed to  the

proposed rule are $1.1 million for the facilities in the screener survey data.
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                                            Table 6-4
 Estimated Pre-Tax Annualized Cost for Proposed Options (Screener Survey Facility Counts)
Subcategory
Owner
Number of
Regulated
CAAPs
Pre-tax Annualized Cost
(Millions, 2000 dollars)
100,000 - 475,000 Pounds Production
Flow-through
Flow-through
Flow-through
Recirculating
Net Pen
Commercial
Non-Commercial
Alaska Non-Profit
Commercial
Commercial
31
57
15
5
0
$0.16
$0.30
$0.32
$0.03
$0.00
475,000 Pounds Production and Above
Flow-through
Flow-through
Flow-through
Recirculating
Net Pen
Total
Commercial
Non-Commercial
Alaska Non-Profit
Commercial
Commercial

9
6
2
3
8
136
$0.04
$0.09
$0.11
$0.02
$0.03
$1.10
Note: Count for Flow-through Non-commercial includes one Alaska state-owned facility.
        In order to estimate the national pre-tax annualized compliance costs attributed to the proposed
rule, EPA multiplied the commercial facilities by a factor of 2.5 (see Section 5.4 and Tetra Tech, 2002).
These results are presented in Table 6-5.  EPA believes it was able to identify all public facilities in its
screener survey mailing list, so these compliance costs did not need to be adjusted.  EPA estimates that
the total pre-tax annualized compliance costs attributed to the proposed rule are $1.5 million for the
industry. More than half of the estimated cost ($0.82 million) is projected to be borne by non-commercial
and non-profit facilities.  Among commercial facilities, those with flow-through systems will incur the
greatest share of the cost ($0.49 million annually).
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                                          Table 6-5
                  Estimated Pre-Tax Annualized Cost for Proposed Options
Subcategory
Owner
Number of
Regulated
CAAPs
Pre-tax Annualized Cost
(Millions, 2000 dollars)
100,000 - 475,000 Pounds Production
Flow-through
Flow-through
Flow-through
Recirculating
Net Pen
Commercial
Non-Commercial
Alaska Non-Profit
Commercial
Commercial
78
57
15
13
0
$0.40
$0.30
$0.32
$0.06
NA
475,000 Pounds Production and Above
Flow-through
Flow-through
Flow-through
Recirculating
Net Pen
Total
Commercial
Non-Commercial
Alaska Non-Profit
Commercial
Commercial

23
6
2
8
20
222
$0.09
$0.09
$0.11
$0.05
$0.09
$1.51
Note: Count for Flow-through Non-commercial includes one Alaska state-owned facility.
6.4    COST-REASONABLENESS

       EPA compared the removals of the higher of BOD or TSS with the cost of the proposed BPT
option for each subcategory. Cost-reasonableness is calculated on the basis of the screener survey
facility counts. The results are summarized in Table 6-6 where the $/lb ranges from $0.04/lb for net pen
systems to $0.39/lb for flow-through systems producing between 100,000 to 475,000 pounds per year.
The industry average for all four regulated subcategories is $0.18/lb.
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                                                             Table 6-6
                                          Cost-reasonableness of Proposed BPT Options
Subcategory
Flow-through
Recirculating
Net Pens
Industry Totals
Annual
Production
Level (Ibs)
100,000 to 475,000
>475,000



Number of
Facilities
103
17
8
8
136
Removals
(Ibs, BOD or TSS)
1,974,210
2,476,255
638,365
868,899
5,957,729
Pre-tax
Annualized
Costs (2000$)
$777,688
$226,675
$45,071
$34,345
$1,083,779
Cost per Pound
Removed ($/lb)
$0.39
$0.09
$0.07
$0.04
$0.18
Note: Screener survey facility counts.  18 Alaska facilities include one state-owned facility (the rest are non-profit).
                                                                6-7

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       EPA also has calculated the cost-effectiveness of the removal of nutrients for the options
considered in today's proposal.  As a benchmark for comparison, EPA has estimated that the average
cost-effectiveness of nutrient removal by POTWs with biological nutrient removal is $4/lb for nitrogen
and $10/lb for phosphorus.  Table 6-7 summarizes the nutrient cost-effectiveness by production system
for the proposed options. The removals are given for total nitrogen (TN) and total phosphorus (TP)
individually and on a combined basis. On the basis of nutrient removal, the proposed options are within
the $4/lb benchmark for recirculating and net pen systems, but not for flow-through systems.  For flow-
through systems,  nutrient CE exceeds $10/lb threshold for phosphorus (even looking at the combined TN
and TP removals) suggesting that the requirements are not very cost-effective for removing nutrients at
flow-through systems.
6.5    REFERENCE
Terra Tech. 2002.  Screener Conversion Factor. Technical memorandum to Maria Jordan, EPA from J.
Hochheimer, Terra Tech, dated July 10, 2002. Tetra Tech, Inc., Fairfax, Virginia.  DCN 61505. June.
USDA.  2000.  United States Department of Agriculture. National Agricultural Statistics Service. 1998
Census  ofAquaculture. Also cited as 1997 Census of Agriculture. Volume 3, Special Studies, Part 3.
AC97-SP-3. February.
                                              6-8

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                                             Table 6-7
                          Nutrient Cost-effectiveness of Proposed Options
Sub category
Flow-Through
Recirculating
Net Pens
Industry Totals
Pre-tax
Annualized
Costs (2000$)
$1,004,363
$45,071
$34,345
$1,083,779
Nutrient Removals (Ibs)
TN
50,273
25,090
74,477
149,840
TP
15,830
7,363
12,413
35,606
TN + TP
66,103
32,453
86,890
185,446
Cost per Pound
Removed ($/lb)
TN
$19.98
$1.80
$0.46
$7.23
TP
$63.45
$6.12
$2.77
$30.44
TN + TP
$15.19
$1.39
$0.40
$5.84
Note: 18 Alaska facilities include one state-owned facility (the rest are non-profit).
                                                6-9

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                                        CHAPTER 7

                           ECONOMIC IMPACT RESULTS

       Chapter 7 describes the economic impacts that may result from the costs of complying with the
proposed concentrated aquatic animal production industry rule.  The impacts are estimated using the
revenue test described in Chapter 5 and the compliance costs presented in Chapter 6 of this report. The
results are presented for each proposed subcategory. Because EPA projects the costs for new sources
to be equal to, or less than, those for existing sources and because limited impacts are projected for these
existing sources, EPA does not  expect significant economic impacts (or barrier to entry) for new sources.
EPA is not proposing standards  for indirect dischargers, hence, this Chapter does not include a discussion
for PSES and PSNS.
7.1    FLOW-THROUGH SYSTEMS (BPT, BCT, BAT, and NSPS)

       7.1.1   BPT and BAT

       EPA evaluated the impacts on 181 flow-through systems from the estimated costs of
implementing Option 1, 2, or 3. Section 7.1.1.1 contains the discussion for the 164 commercial and non-
commercial flow-through facilities in the lower 48 states.  The remaining seventeen facilities are non-
profit establishments in the state of Alaska; these facilities are discussed in Section 7.1.1.2. Table 7-1
summarizes the findings for commercial and non-commercial ownership and for nonprofit facilities in the
state of Alaska.1
       1 Non-commercial facilities include Federal hatcheries, state hatcheries, Tribal facilities,
academic/research facilities, and any other nonprofit facilities.
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                                                           Table 7-1

                                                     Flow-through Systems
                            Facilities Showing Impacts at 3%, 5%, and 10% Revenue Test Thresholds
Size
100,000 - 475,000 poum
Commercial
Non-Commercial1
Alaska Nonprofit
Greater than 475,000 p<
Commercial
Non-Commercial
Alaska Nonprofit
Total
Number of
Facilities
Is Annual Pi
78
57
15
unds Annua
23
6
2
181
Option 1 Option
3% 5% 10% Proposed
•oduction
25 8 0 *
000 *
000 *
1 Production
000
000
000
25 8 0
Option 2 Option
3% 5% 10% Proposed
25 15 0
000
000
000
000
000
25 15 0
Option 3 Option
3% 5% 10% Propose!
35 23 23
400
000
000 *
000 *
100 *
40 23 23
        1 EPA found one state-owned hatchery in Alaska produces between 100,000 and 475,000 pounds annually. Impacts to this facility were
tabulated with other non-commercial facilities in this table.
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        7.1.1.1 Non-Alaskan Facilities

        Of the 164 non-Alaskan facilities identified through the screener survey, 135 produce between
100,000 and 475,000 pounds per year (78 commercial and 57 non-commercial) and 29 facilities produce
more than 475,000 pounds annually (23 commercial, six non-commercial).

        For facilities with annual production ranging from 100,000 to 475,000 pounds, the largest impacts
are expected to be incurred by commercial facilities.  For non-commercial facilities, only four of 57
facilities (about 7 percent) incur costs exceeding three percent of revenues for the most stringent option,
Option 3. The results indicate that non-commercial facilities are unlikely to incur compliance costs that
exceed three percent of revenues for Option 1 or Option 2.  In contrast, nearly half of the commercial
facilities are expected to incur costs exceeding three percent of revenues under Option 3 (35 of 78
facilities). About one-third of the commercial facilities show impacts at the three-percent-of-revenues
threshold for both Option 1 and Option 2 (25 of 78 facilities).  However, the number of commercial
facilities incurring costs in excess  of five percent of revenues drops from 15 under Option 2 to eight under
Option 1. (No facility incurs costs in excess of 10 percent of revenues under Option 1 or Option 2.) EPA
is proposing Option 1 for flow-through facilities with annual production between 100,000 pounds and
475,000 pounds.

        The effects  of economies  of scale in the costing models are evident for facilities  with production
of 475,000 pounds or more per year. The results indicate that these facilities are not likely to incur
impacts at the three-percent threshold even under the most stringent option, Option 3. EPA is proposing
Option 3 for flow-through facilities with an annual production of 475,000 pounds or greater.
        7.1.1.2 Alaskan Facilities

        EPA used information provided by the state on production and revenues to evaluate impacts on
nonprofit facilities in the state of Alaska. Production level was used to determine those facilities within
scope of the proposed rule and to estimate facility-level compliance costs.  EPA identified 15 nonprofit
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Alaskan facilities that produce between 100,000 pounds and 475,000 pounds annually, and two nonprofit
facilities that produce more than 475,000 pounds annually.2

       Alaskan facilities perform ocean ranching where salmon smolts are released to the ocean.  The
members of the nonprofit corporation are allowed to harvest adult fish that return to that region.  These
are reported as operator revenues.  In addition, nonprofit hatcheries may allow region permit holders to
vote for a self-imposed "enhancement tax" on the value offish caught in that region (i.e., by member and
non-member fishermen).  EPA used the sum of operator-reported revenues and the enhancement tax
(where applicable) income as the revenues against which compliance cost impacts are measured.
Revenues and enhancement tax income are reported at the level of the nonprofit association,  which may
own more than one hatchery.  EPA estimated facility level revenues based on the facility's percentage of
total association production. The 17 nonprofit facilities that exceed 100,000 pounds in annual production
are owned by nine associations.

       The projected impacts on the 17 Alaskan nonprofit facilities are reported in Table 7-1. No
facilities with annual production ranging from 100,000 to 475,000 pounds are expected to incur costs
exceeding three percent of revenues. One facility with annual production in excess of 475,000 pounds is
projected to incur costs exceeding the three percent threshold under Option 3.
       7.1.2   BCT

       EPA's methodology for evaluating candidate BCT technologies is discussed in Section 5.3 of this
report. EPA is establishing BPT limitations for flow-through facilities with an annual production of
100,000 pounds. A BCT test can be performed for the category with 100,000 to 475,000 in annual
production. (EPA is proposing the most stringent option for facilities with 475,000 and greater in annual
production. Hence, there is no more stringent option to be considered for BCT for this group.) For
purposes of this analysis, EPA is assuming that the proposed BPT limits are the baseline.  Thus, EPA is
considering only Options 2 and 3 as BCT candidate options.
       2 In addition, EPA found one state-owned hatchery in Alaska produces between 100,000 and
475,000 pounds annually. Impacts to this facility were tabulated with other non-commercial facilities in
Table 7-1.
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       Table 7-2 presents the calculations for the BCT cost test. The cost per pound to upgrade from
secondary to advanced secondary treatment is less than $0.65 for Option 3, so Option 3 passes the first of
the two-part test.  However, the cost per pound to go from raw wastewater to BPT is $0.20; therefore,
the ratio of the cost per pound to go from BPT to BCT divided by the cost per pound to go from raw
wastewater to BPT for the industry is 2.08 and Option 3 fails the second part of the test.  Based on these
results, EPA is proposing that BCT be set equal to BPT.
                                           Table 7-2
                   POTW Cost Test Calculations for Flow-through Systems
                        (100,000-475,000 Pounds in Annual Production)



Option
2
3
Incremental
Conventional
Pollutants
Removed
(Ibs.)
0
874,136

Incremental
Pre-tax Total
Annualized Costs
(Millions, 2000$)
$0.03
$0.37
Ratio of
Costs to
Removals
(POTW
Test)
undefined
0.42


Pass
POTW
Test?
no
yes
BPT-BCT
Raw-BPT
Ratio
(Industry
Test)
NA
2.08


Pass
Industry
Test?
NA
no
       7.1.3   NSPS

       EPA is proposing new source performance standards that are identical to those proposed for
existing dischargers that meet the 100,000 pound production threshold. Thus, new facilities with annual
production ranging from 100,000 to 475,000 pounds will be required to meet Option 1 standards, and new
facilities with annual production in excess 475,000 pounds will be required to meet Option 3 standards.
Engineering analysis indicates that the cost of installing pollution control systems during new construction
is no more expensive than the cost of retrofitting existing facilities and is frequently less expensive than
the retrofit cost.  Because EPA projects the costs for new sources to be equal to or less than those for
existing sources and because limited impacts are projected for these existing sources, EPA does not
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expect significant economic impacts (or barrier to entry) for new sources that meet the 100,000 pound
production threshold.
7.2    RECIRCULATING SYSTEMS (BPT, BCT, BAT, and NSPS)

       EPA evaluated impacts on 21 recirculating systems, all of which are commercial and have annual
production in excess of 100,000 pounds. EPA found 13 facilities with annual production ranging from
100,000 to 475,000 pounds, and eight facilities with annual production in excess of 475,000 pounds. No
recirculating facilities are projected to incur costs exceeding three percent of revenues under any option.
EPA is proposing Option 3 for recirculating facilities with production of 100,000 pounds per year or
greater for BPT.

       EPA is proposing the most stringent option for facilities with recirculating systems.  Hence, there
is no more stringent option to be considered for BCT, so BCT is set equal to BPT.  The technology
options EPA considered for BAT are identical to those it considered for BPT. Because  EPA projects
limited economic impacts associated with the BPT requirements, EPA does not expect significant
economic impacts for BAT. Because EPA projects the costs for new sources to be equal to or less than
those for existing sources and because limited impacts are projected for these existing sources, EPA does
not expect significant economic impacts (or barrier to entry) for new sources that meet the 100,000 pound
production threshold.
7.3    NET PEN SYSTEMS (BPT, BCT, BAT, and NSPS)

       EPA evaluated impacts on 20 facilities with net pen systems, all of which are commercial and
have annual production in excess of 475,000 pounds.  None of the facilities shows impacts under the most
stringent combination of technologies and thresholds, i.e., 3 percent with Option 3. EPA is proposing
Option 3 for net pen facilities as BPT.

       EPA is proposing the most stringent option for facilities with net pen systems. Hence, there is no
more stringent option to be considered  for BCT, so BCT is set equal to BPT.  The technology options

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EPA considered for BAT are identical to those it considered for BPT for existing dischargers.  Because
EPA projects limited economic impacts associated with the BPT requirements, EPA does not expect
significant economic impacts for BAT. Because EPA projects the costs for new sources to be equal to
or less than those for existing sources and because limited impacts are projected for these existing
sources, EPA does not expect significant economic impacts (or barrier to entry) for new sources that
meet the 100,000 pound production threshold.
7.4    OTHER ECONOMIC IMPACTS

       7.4.1   Firm-Level Impacts

       For the final rule, EPA intends to conduct an analysis of firm-level impacts with the detailed
survey data.  No firm-level analysis is possible at this time due to data constraints that arise from the
predominance of privately-held (i.e. firm not required to file financial information with the Securities and
Exchange Commission) and foreign-held firms. The salmon industry, for example, is predominantly
foreign-held. Due to differences in accounting standards, EPA does not routinely consider foreign firms
in its financial analysis. EPA also intends to examine the potential cumulative impacts on non-commercial
concentrated aquatic animal production facilities, such as state and Federal hatcheries, using information
collected in the detailed survey.
       7.4.2   Community-level Impacts

       EPA did not identify any data source with detailed employment information for the aquatic animal
production industry.  Given that the scope of the proposed regulation is focused on a limited number of
larger facilities, EPA believes that is not likely to cause severe community impacts.  EPA intends to
examine community-level impacts  based on detailed survey data.
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        7.4.3   Foreign Trade Impacts

        EPA believes that proposed regulations will have little, if any, impact on foreign trade.  Several
species, including striped bass, tilapia, trout, and salmon, face significant foreign competition.  However,
no facilities in the striped bass sector are expected to incur compliance costs that exceed the  1 percent
revenue threshold, and no tilapia or salmon facilities are expected   to incur compliance costs that exceed
the 3 percent revenue threshold.  EPA used its regulatory flexibility and proposed different options for
different levels of production for the system most commonly used to raise trout (i.e., flow-through) to
mitigate potential adverse impacts.
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                                        CHAPTER 8
                    SMALL BUSINESS FLEXIBILITY ANALYSIS
8.1    INTRODUCTION

       This chapter analyzes the projected effects of incremental pollution control costs on small entities.
This analysis is required by the Regulatory Flexibility Act (RFA) as amended by the Small Business
Regulatory Enforcement Fairness Act of 1996 (SBREFA). The RFA acknowledges that small entities
have limited resources and makes it the responsibility of the regulating federal agency to avoid burdening
such entities unnecessarily.  If, based on an initial assessment, a regulation is likely to have a significant
economic impact on a substantial number of small entities, the RFA requires a regulatory flexibility
analysis.

       EPA has determined that the proposed rule will not have a significant economic impact on a
substantial number of small entities.  Despite this determination, EPA prepared a small business flexibility
analysis that examines the impact of the proposed rule on small entities along with regulatory alternatives
that could reduce that impact. This small business flexibility analysis would meet the requirements for an
initial regulatory flexibility analysis (IRFA) and is summarized below.

       The Chapter is organized as follows: Section 8.2 provides EPA's initial assessment; Section 8.3
describes the components of the small business flexibility analysis; Section 8.4 presents the analysis of
economic impacts to small entities in the concentrated aquatic animal production (CAAP) industry; and
Section 8.5 summarizes the steps EPA has taken to minimize the impacts to small entities under the
proposed rule.
8.2    INITIAL ASSESSMENT

       EPA guidance on implementing RFA requirements suggests the following must be addressed in
an initial assessment.  First, EPA must indicate whether the proposal is a rule subject to notice-and-
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comment rulemaking requirements. EPA has determined that the proposed concentrated aquatic animal
production effluent limitations guidelines (ELG) are subject to notice-and-comment rulemaking
requirements.

       Second, EPA should develop a profile of the affected small entities. EPA has developed a profile
of the AAP industry that covers all affected operations, including small entities.  The industry profile
information is provided in Chapter 2 of this report, while Chapter 7 presents the projected economic
impacts to the industry. Much of the discussion in these two chapters applies to small businesses.
Additional information on small businesses in the AAP industry is also provided below in Sections 8.3 and
       Third, EPA's assessment needs to determine whether the rule would affect small entities and
whether the rule would have an adverse economic impact on small entities.  EPA has determined that
some small entities may incur incremental compliance costs as a result of the rule, if promulgated as
proposed.  EPA examines the impacts of these compliance costs in Section 8.4.
8.3    SMALL BUSINESS FLEXIBILITY ANALYSIS COMPONENTS

       Section 603 of the RFA requires that an IRFA must contain the following:

       •      An explanation of why the rule may be needed.
       •      A short explanation of the objectives and legal basis for the proposed rule.
       •      A description of, and where feasible, an estimate of the number of small business entities
               to which the proposed rule will apply.
       •      A description of the proposed reporting, recordkeeping, and other compliance
               requirements (including estimates of the types of small entities that will be subject to the
               requirement and the type of professional skills necessary for the preparation of the report
               or record).
       •      An identification, to the extent practicable, of all relevant federal rules that may duplicate,
               overlap, or conflict with the proposed rule.
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        •      A description of "any significant regulatory alternatives" to the proposed rule that
               accomplish the statement objectives of the applicable statutes and minimize any
               significant economic impact of the rule on small entities.

Each of these issues are addressed in the following subsections.
        8.3.1   Need for Objectives of the Rule

        The Agency is considering this action because the operation of CAAP facilities may introduce a
variety of pollutants into receiving waters. Under some conditions, these pollutants can be harmful to the
environment. According to the 1998 USD A Census of Aquaculture (USDA, 2000), there are
approximately 4,200 commercial aquatic animal production (AAP) facilities in the United States that might
qualify as a small business. Aquaculture has been among the fastest-growing sectors of agriculture until a
recent slowdown that began several years ago caused by declining or level growth among producers of
several major species.  EPA analysis indicates that many  CAAP facilities have treatment technologies in
place that greatly reduce pollutant loads. However, in the absence of treatment, pollutant loads from
individual CAAP facilities such as those covered by the proposed rule, can contribute up to several
thousand pounds of nitrogen and phosphorus per year, and tens to hundreds of thousands of pounds of
TSS per year.  These pollutants can contribute to eutrophication and other aquatic ecosystem responses to
excess nutrient loads and BOD effects.  In recent years, Illinois, Louisiana, North Carolina, New
Hampshire, New Mexico, Ohio and Virginia have cited the AAP  industry as a potential or contributing
source of impairment to water bodies (EPA, 2000).  Several state authorities have set water quality based
permit requirements for CAAP facilities in addition to technology based limits based on best professional
judgement (EPA, 2002a).

        Another area of potential concern relates to non-native species introductions from CAAP
facilities, which may pose risks to native fishery resources and wild native aquatic species from the
establishment of escaped individuals (Hallerman and Kapuscinski, 1992; Carlton, 2001; Volpe et al.,
2000). CAAP facilities also employ a range of drugs and chemicals used therapeutically that may be
released into receiving waters.  For some investigational drugs, as well as for certain application of
approved drugs, there is a concern that further information is needed to fully evaluate risks to ecosystems
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and human health associated with their use in some situations (EPA, 2002b). Finally, CAAP facilities also
may inadvertantly introduce pathogens into receiving waters, with potential impacts on native biota. The
proposed rule attempts of address a number of these concerns. These regulations are proposed under the
authority of Section 301, 304, 306, 308, 402, and 501 of the Clean Water Act, 33 U.S.C.1311, 1314, 1316,
1318,  1342, and 1361.
       8.3.2   Small Entity Identification

       The RFA/SBREFA defines several types of small entities, including:

       •      Small governments,
       •      Small organizations, and
       •      Small businesses.

These are described in Sections 8.3.2.1 through 8.3.2.3, respectively.
       8.3.2.1 Small Governments

       The RFA/SBREFA defines  "small governmental jurisdiction" as the government of a city,
county, town, school district, or special district with a population of less than 50,000.  For the purposes of
the RFA, States and tribal governmental are not considered small governments but rather as independent
sovereigns (EPA, 1999).1  Federal facilities, regardless of their production levels, are not part of small
governments.
       JSee Section 11.2 where impacts on these entities are analyzed in accordance with Unfunded
Mandates Reform Act requirements.
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       8.3.2.2 Small Organizations

       The RFA/SBREFA defines "small organization" as any not-for-profit enterprise that is
independently owned and operated and is not dominant in its field. For the purpose of this rulemaking,
EPA considers many of the non-profit organizations that produce salmon for the State of Alaska to be
"small." These non-profit facilities have assumed what is usually a State function, which is to raise fish
(in this case salmon) in hatcheries to be released into the wild to supplement wild populations, and sustain
the Alaska commercial and recreational fishing industries.
       8.3.2.3 Small Businesses

       The Small Business Administration (SBA) sets size standards to define whether a business entity
is small and publishes these standards in 13 CFR 121. The standards are based either on the number of
employees or annual receipts.  Table 8-1 lists the North America Industry Classification System (NAICS)
codes potentially in scope of the proposed rule and their associated SBA size standards as of January 1,
2002 (SBA, 2000 and SBA, 2001).
                                           Table 8-1
                                 Small Business Size Standards
 NAICS Code
Description
Size Standard (Annual Revenues)
 112511
 112512
 112519
Finfish Farming and Fish Hatcheries
Shellfish Farming
Other Animal Aquaculture
            $0.75 million
            $0.75 million
            $0.75 million
       When making classification determinations, SBA counts receipts or employees of the entity and
all of its domestic and foreign affiliates (13 CFR.121.103(a)(4)).  SBA considers affiliations to include:
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        •      stock ownership or control of 50 percent or more of the voting stock or a block of stock
               that affords control because it is large compared to other outstanding blocks of stock (13
               CFR121.103(c)).
        •      common management (13CFR121.103 (e)).
        •      joint ventures (13 CFR 121.103(f)).

EPA interprets this information as follows:

        •      Sites with foreign ownership are not small (regardless of the number of employees or
               receipts at the domestic site).
        •      The definition of small is set at the highest level in the corporate hierarchy and includes all
               employees or receipts from all members of that hierarchy.
        •      If any one of a joint venture's affiliates is large, the venture cannot be classified as small.

EPA's estimate of the number of small entities in the AAP industry is presented in Section 8.3.5 below.
       8.3.3   Description of the Proposed Reporting, Recordkeeping, and Other Compliance
               Requirements

       In the proposed rule, flow-through and recirculating facilities would be subject to compliance with
numeric limitations; however, EPA proposes to provide an alternative compliance provision that would
allow facilities to develop and implement a BMP plan to control solids provided that the permitting
authority determines the plan will achieve the numeric limitations.  Also flow-through facilities that
segregate the bulk discharge from off-line settling discharge would develop and implement the solids
control BMP plan.  Larger flow-through facilities and all recirculating and net pen facilities within the
scope of the proposed rule would also develop a BMP plan to address mortalities, non-native species, and
drugs and chemicals storage. These facilities would also be required to report to the permitting authority
whenever an investigational new animal drug is used or drug or chemical is used for a purpose that is not
in accordance with its label requirements.
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       EPA estimates that each plan will require 40 hours per facility to develop the plan.  The plan will
be effective for the term of the permit (5 years).  An additional two hours per month (comprised of 1 hour
of a manager's time and 1 hour of a laborer's time) or 24 hours per year are assumed to be required for
implementation.  EPA does not believe that the development and implementation of these BMPs will
require any special skills. All of the CAAP facilities within the proposed scope should currently be
permitted, so incremental administrative costs of the regulation are negligible. However, Federal and
State permitting authorities will incur a burden for tasks such as  reviewing and certifying the BMP plan
and reports on the use of drugs and chemicals.  EPA estimated these costs at approximately $10,011 for
the three-year period covered by the information collection request (EPA, 2002, Table 9) or roughly
$3,337 per year.
       8.3.4   Identification of Relevant Federal Rules That May Duplicate, Overlap, or
               Conflict with the Proposed Rule

       EPA identified Federal rules that have an impact on the CAAP industry and believes that there
are no such rules that would duplicate, overlap or conflict with the proposed rule.  EPA has identified two
sets of Federal rules, however, the implementation of which would be supplemented by the proposed rule
requirements - specifically, the reporting requirements proposed for certain drugs  and chemicals.  The
proposed rule requires reporting of investigational new animal drugs and any drug  that is not used
according to label requirements. Regulations administered by the Food and Drug Administration published
at 21 CFR Part 511 impose restrictions on such usage, but typically do not require  reporting of the usage
after discharge to waters of the  United States. Similarly, the proposed rule requires reporting of the usage
(and discharge)  of chemicals when such usage does not  comply with label requirements.  Some such
chemicals would be pesticides subject to regulatory requirements under the Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA), which is administered by EPA.  EPA has not published FIFRA
requirements to  require the reporting proposed in the rule for CAAP facilities.
       8.3.5   Significant Regulatory Alternatives

       EPA took steps to minimize the regulatory burden associated with the rulemaking.  EPA
reviewed effluent characteristics from the aquatic animal production industry and determined that several
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sectors were not within the scope of the rule (see Development Document for more details as well as
Section 6.1.1 of this report). EPA is not proposing regulations for discharges from:


       •      closed ponds,

       •      lobster pounds,

       •      alligator pens,

       •      crawfish facilities,

       •      molluskan shellfish production in open waters,

       •      aquariums.


In addition, EPA proposed an annual production threshold of 100,000 pounds before a facility is in the
scope of the regulation. The number of facilities to which the proposed rule would apply after excluding:
(1) ponds, lobster pounds, alligator pens, crawfish, molluskan shellfish production in open waters, and

aquariums, and (2) facilities with annual production of less than 100,000 pounds, is estimated in sections
8.3.5.1 and 8.3.5.2 below.
       8.3.5.1 Evaluation of the Number of Small Entities Based on Publicly Available Data


       8.3.5.1.1      Small Facilities


       Prior to receipt of the screener survey data, EPA's primary data source for an upper bound

estimate of the number of small entities in the AAP industry was the Census (USDA, 2000). The
reasons why the USDA data provide an "upper bound" estimate include:
               The aquaculture revenues for a site might be underestimated when costs are evaluated
               on a species-by-species basis.  EPA developed cost models for various production
               system/species combinations.  The USDA data are given by species and revenue
               category. When USDA presents the data on an industry basis, it identifies 4,028 sites
               with aquatic animal production.  When the data are presented on a species basis, the
               counts sum to 4,789 sites. This indicates that as many as 761 sites raise more than one
               species (compare Table 2-8 and Table 2-9 in the industry profile). EPA therefore loses
               any economies of scale that might occur when treating effluents from multiple species  on

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               a combined basis. EPA's cost estimates might be an overestimate and, if the revenues
               against which the costs are compared are based only one species, the facility revenues
               might be an underestimate.

        •      Total site revenues might be underestimated.  The Census data report only aquatic animal
               production revenues, not revenues from all agricultural products produced at that site
               (whether it is  a farm, facility, or single-facility company).

        •      The USDA revenue data are on an individual site basis while the SBA small business
               definitions are based on total company revenues. An individual facility can have
               revenues less than the SBA size standard while the total company revenues may or may
               not exceed the size standard depending on the revenues from the other facilities owned
               by the company. For example, a company in NAICS code 1 125 1 1 (finfish farming) that
               owns eight facilities, each with $100,000 in annual revenues, would exceed the size
               standard and hence would not be classified as a small business.

EPA is aware that classifying operations as "small" solely on the basis of aquaculture revenues at
individual facilities will likely  overestimate the number of small entities, and intends to conduct a company
level analysis using the detailed survey data for final promulgation.
        While a small facility might be part of a large company, the inverse is not possible.  If the

revenues from a single species at a single site exceed that SBA standard for  a small business, that site
must belong to a large company. EPA requested a special tabulation of the USDA Census of
Aquaculture data (USDA, 2002).2  The special tabulation provides information for a new  revenue

catergory that corresponds to the SBA size standard for a small AAP business. EPA used the special
tabulation data to  examine the distribution of aquatic animal operations by revenue and species and to
estimate the number of small entities in the industry. USDA data identify  a minimum of 261 aquatic

animal production facilities that are not small, implying that as much as 94 percent of the total AAP
facilities might be considered small. On the basis of this estimate, EPA initiated the SBAR process.
        2EPA requested data for alligators, baitfish, carp, catfish, crawfish, frogs, mollusks, ornamentals,
perch, salmon, shrimp, sport fish, striped bass, tilapia, trout, turtles, and walleye. USDA provided as much
data as possible without compromising confidentiality. The observations for each species matched the
total count presented in Table 2 of the Census. The special tabulation reflected 4,489 observations.

                                               8-9

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        8.3.5.1.2      Summary
       The Census (USDA, 2000) identified approximately 4,800 facility/species combinations.
Specifically, it identified 4,028 facilities with aquaculture activities, while the facility counts by species sum
to 4,789 facilities. In approximate terms, EPA proposed to exclude catfish (1,370 operations), baitfish
(275 operations), ornamental fish (345 operations), crawfish (563 operations), molluskan shellfish (535
operations) in addition to the 20 farms that raise algae and other sea vegetables - or a total of 3,108
operations. In other words, EPA proposed to exclude approximately 65 percent  of the aquatic animal
production operations from the scope of the regulation based on technical reasons.

       An alternative approach is to estimate the number of facilities with production systems for which
EPA is proposing guidelines and standards (i.e., flow-through systems, recirculating systems, and net pens
systems).  A coarse measure of the size of the regulated community might be to assume that the count
for trout, salmon, and other food fish operations given in the Census represent an approximation of the
number of these production systems  (996 farms).

       EPA also proposed an annual production threshold of 100,000 pounds before a facility is in the
scope of the proposed regulation. This would exempt approximately 453 of the 561 trout operations and
about 319 of the 435 food fish operations listed Table 2 of the Cenus (USDA, 2000).  This results in a
regulated community of about 224  operations. Even though this is only 224 out of 4,789 - or about five
percent of the aquatic animal production industry - this count might still be  an over estimate  if any of the
trout and food fish production facilities use pond systems for production.  The number of small facilities,
then, is some fraction of the 224 facilities that are within the regulated community yet have revenues of
$750,000 or less.  Because the Census data do not cross reference production  systems by revenue and
species, EPA cannot provide a better estimate of the number of small facilities, except to say that it is a
small fraction of the original industry.
       8.3.5.2 EPA Screener Survey Data

       Table 8-2 summarizes facility counts based on the screener survey data and information
submitted by the state of Alaska.  EPA identified a universe of almost 1,500 aquatic animal production

                                               8-10

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facilities.  About 1,000 of these are potentially small commercial facilities (i.e., earn less than $750,000 per
year in revenues).  Many of the remaining 500 facilities produce less than 475,000 pounds per year and/or
earn less than $750,000 per year in revenues, but are not small businesses based on other criteria (e.g.,
federal or state ownership).
                                             Table 8-2
                                  Estimated Number of Facilities
Description
Universe
Meeting definition of
a CAAPF
Annual production in
excess of 100,000
pounds
Number of Facilities
All Facilities
Screener
1,446
600
118
Alaska
31
25
18
Sum
1,477
625
136
Small Facilities
Screener
(Commercial)
973
318
36
Alaska
26 l
16 2
12 3
Sum
999
334
48
Source: Terra Tech e-mail, 29 May 2002.
1  Excludes two State and three Federal/Tribal facilities.
2  Six facilities have less than 20,000 pounds in annual production.  Five facilities that belong to a large
nonprofit organization are counted as a single entity.
3  Eighteen facilities with 100,000 pounds or more in annual production minus one State facility and five
facilities that belong to a large nonprofit organization.
Table 8-2 indicates that the community considered for regulation is about 9 percent of the original
universe of AAP operations (i.e., 136 of 1,477 facilities).  The number of small facilities within the
proposed regulated community, however, is only about 5 percent of the original universe of small entities
(i.e., 48 of 999 facilities). EPA identified 48 small facilities (including 36 commercial facilities and 12
Alaskan facilities). An additional 81 commercial facilities earn less than $750,000 per year, and are thus
considered small, but are not within the proposed scope (i.e.,  they produce less than 100,000 pounds per
year).
                                                8-11

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8.4    POTENTIAL IMPACTS FROM PROMULGATED RULE ON SMALL ENTITIES

       EPA examined potential impacts on all facilities that earn less than $750,000 per year before
concluding that it would not regulate facilities with annual production ranging from 20,000 to 100,000
pounds. Section 8.4.1 presents EPA's impact analysis on facilities that fall within this production range.
Section 8.4.2 and 8.4.3 present projected impacts small facilities in the regulated community.
       8.4.1   Small Facilities with 20,000 to 100,000 Pounds Annual Production

       EPA identified 81 commercial and 78 non-commercial flow through facilities, as well as one non-
commercial recirculating facility in the screener data, that: (1) earn less than $750,000 per year, and (2)
whose annual production is more than 20,000 but less than 100,000 pounds.  Table 8-3 summarizes EPA's
analysis of these facilities.

       EPA examined a lower cost option for facilities in the 20,000 to 100,000 pounds of annual
production range based on the BMP plan. Total annualized compliance costs for these  160 facilities total
$208,000 under the BMP Option.  Even with these relatively minimal requirements, 85 percent of
commercial flow through facilities (69 of 81) and 49 percent of all facilities (78 of 160) exceed the 1
percent threshold. Furthermore, 32 percent of all facilities (51 of 160) are projected to incur costs
exceeding 3  percent of revenues.  Based on these results, EPA is not proposing any guidelines and
limitations for facilities with 20,000 to 100,000 pounds of annual production.
                                              8-12

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                                           Table 8-3
                  Facilities with 20,000 - 100,000 Pounds Annual Production
                  Estimated Compliance Costs and Facilities Showing Impacts
                           at 1% and 3% Revenue Test Thresholds
Subcategory
Flow Through Commercial
Flow Through Non-
Commercial
Recirculating Non-
Commercial
Total
Number of
Facilities
81
78
1
160
BMP Option
Total Annualized
Compliance Costs
($2000)
$102,743
$104,087
$1,424
$208,254
Revenue Test Threshold
1%
69
8
1
78
3%
45
6
0
51
       8.4.2   Small Commercial Facilities

       EPA identified 36 small facilities with (1) flow-through or recirculating systems, (2) annual
production above 100,000 pounds, and (3) annual revenues at or below $750,000.3 Of these,
approximately 17 (which represents 5 percent of the total small CAAPs or 47 percent of the small
CAAPs within the scope of the proposed rule) incur compliance costs greater than 1 percent of
aquaculture revenue and 10 small commercial entities (which represents less than 3 percent of the total
small CAAPs or 28 percent of the small CAAPs within the scope of the proposed rule) incur compliance
costs greater than 3 percent. For commercial facilities, EPA assumed that the facility is equivalent to the
business, an assumption that will be re-examined when detailed survey data is available.
       3As noted in Section 8.2.3, small facilities might belong to large companies. Given the
predominance of foreign-ownership of salmon aquaculture and the dominance of a single firm in trout
aquaculture, there is a good probability of small facilities belonging to large firms, but EPA will need to
have the detailed questionnaire data to conduct further evaluations.
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       8.4.3   Nonprofit Organizations

       EPA estimates that 17 Alaskan facilities within scope of the proposed rulemaking meet the
definition of a small nonprofit organization. EPA guidance recommends a test for nonprofit organizations
that calculates annualized compliance costs as a percentage of total operating expenditures (EPA, 1999).
EPA used the sum of operator-reported revenues and enhancement tax revenues as a proxy for total
operating expenditures.

       For commercial facilities, EPA assumed that the facility is equivalent to the business, an
assumption that will be re-examined when detailed survey data is available.  However, because sufficient
data is available to determine the parent nonprofit association (and its revenues) for the small Alaskan
nonprofit facilities, EPA analyzed small entity impacts at the level of the parent association.  EPA
determined that 12 small Alaskan nonprofit facilities within scope of the proposed rule are owned by 8
small nonprofit associations.  Of the 6 small Alaskan nonprofit associations for which EPA had data, 3
associations incur compliance costs greater than 1 percent of revenues and 1 association incurs
compliance costs greater than 3 percent.
8.5    REGULATORY FLEXIBILITY ANALYSIS

       EPA has chosen to minimize economic impacts to small business establishments in the aquatic
animal production industry by tailoring its proposed guidelines to differences in species, production
systems, and facility size. Specifically, EPA is :
               not proposing regulations for discharges from: ponds, lobster pounds, alligator pens,
               crawfish operations, molluskan shellfish production in open waters, or aquariums;
               proposing to exclude facilities that produce less than 100,000 pounds of aquatic animals
               per year;
               proposing to set less stringent guidelines (Option 1 instead of Option 3) for facilities that
               produce more than 100,000 pounds, but less than 475,000 pounds of aquatic animals per
               year in flow through production systems.
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Furthermore, EPA finds that 17 small commercial facilities, and three small nonprofit associations are
expected to incur costs exceeding 1 percent of revenues.  EPA intends to make its final determination of

the impact of the aquatic animal production rulemaking on small businesses based on analyses of the

detailed survey data. At this time, the Agency sees no basis for finding that the regulation would impose a

significant impact on a substantial number of small entities, specifically, based on restrictions in the scope

of the proposed rule as well as the  estimates of (low) costs of compliance.
8.6    REFERENCES

Alaska.  2002.  Alaska Department of Community & Economic Development.  Division of Investments.
Fisheries Enhancement Revolving Loan Fund: Program Overview. February.

Amos, Kevin H. and Andrew Appleby.  1999.  Atlantic Salmon in Washington State: A Fish Management
Perspective.  Washington Department of Fish and Wildlife.  September.
 downloaded 10 October 2001.

Berge, Alsak. 2002. The world's 30 largest salmon farmers,  downloaded 30 April 2002.

Carlton, IT.  2001. Introduced Species in  U.S. Coastal Waters.  Environmental Impacts and
Management Priorities. Prepared for the Pew Oceans Commission, Arlington, VA., 28 pp.

Coons, Ken.  2001. Seaboard completes sale of ContiSea to Fjord Seafood.
 downloaded 26 April 2002.

Frank, A.D.  2000. Personal communication between  A. David Frank, USDA, NASS, LA state office
and Maureen F. Kaplan, ERG, dated 24 August.

Hallerman, E.M., and A.R. Kapuscinski, 1992.  Ecological Implications of Using Transgenic Fishes in
Aquaculture. ICES March Science Symposium 194:56-66.

Heritage. 2001. Heritage Salmon website.   Company information and links to George Weston Ltd and
Heritage Aquaculture.  and links to  and
 downloaded 10 October.

Idaho. 2002.  Clear Springs Foods.  Hagerman.Idaho.
 downloaded 13 May 2002.

Jensen, Bent-Are.  2001.  Norwegian imperialism in the USA.  IntraFish. 2 February.
 downloaded 31 October.
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Lee, Michael and Andre Ranieri. 2002. In search of the Snake: the river as industry. Part 5 of series
carried in Tri-city Herald.  downloaded 13 May
2002.

LexisNexis.  2002.  Directory of Corporate Affiliations. LinkfromHoovers.com. Search on Clear
Springs Foods, Inc.  13 May 2002.

PSBJ.  2000.  Puget Sound Business Journal.  Heard and Overheard. 26 May.
 downloaded 10 October 2001.

SB A. 2001.  Small Business Administration.  13 CFR Parts 107 and 121 Size eligibility requirements for
SBA financial assistance and size standards for agriculture. Direct Final Rule.  65 FR 100:30646-30649.
7 June.

SBA. 2000.  Small Business Administration.  13 CFR Part 121 Small business size regulations:  Size
standards and the North American Industry Classification System; Final Rule. 65 FR 94:30836-30863.  15
May.

Seaboard Corporation. 2001. 2001 Annual report. Downloaded from company website.
 downloaded 26 April 2002.

Stolt Sea Farm.  2001. Information downloaded from company web site.
 downloaded 10 October.

USDA. 2002.  United States Department of Agriculture. National Agricultural Statistics Service.
Special tabulation request from EPA for the Census ofAquaculture data.  March.

USDA. 2000.  United States Department of Agriculture. National Agricultural Statistics Service.  1998
Census ofAquaculture.  Also cited as 1997 Census of Agriculture. Volume 3, Special Studies, Part 3.
AC97-SP-3.  February.

U.S. EPA. 2002a. U.S. Environmental Protection Agency.  Response to Public Comments on the
Proposed Issuance of the General National Pollutant Discharge Elimination System (NPDES)
Permit for Aquaculture Facilities in Idaho and Associated,  On-site Fish Processors. Prepared by
EPA-Region 10, Seattle, WA. 20pp.

U.S. EPA. 2002b.  U.S. Environmental Protection Agency. Response to Comments in Regard to
Authorization to Discharge Under the National Pollutant Discharge Elimination System.   Prepared
by EPA-Region 1, Boston, MA. 64 pp.

U.S. EPA. 2000. U.S. Environmental Protection Agency. National Water Quality Inventory: 1998
Report to Congress.  EPA 841-R-00-001. U.S. Environmental Protection Agency, Office of Water,
Washington, DC. .  Accessed December 2001.

U.S. EPA. 1999. U.S. Environmental  Protection Agency.  Revised Interim Guidance for EPA
Rulewriters: Regulatory Flexibility Act as amended by the Small Business Regulatory Enforcement
Fairness Act. Washington, DC. 29 March.
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Volpe, J.P., E.B. Taylor, D.W. Rimmer, and B.W. Glickman. 2000. Evidence of Natural Reproduction
of Aquaculture-Escaped Atlantic Salmon in a Coastal British Columbia River. Conservation Biology.
14(June):899-903.
                                             8-17

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                                        CHAPTER 9

                       ENVIRONMENTAL IMPACTS OF THE
                     AAP INDUSTRY IN THE UNITED STATES

9.1    INTRODUCTION

       Concentrated aquatic animal production (CAAP) facilities produce a variety of waste products
that are discharged to receiving waters. CAAP facilities, such as those covered by the proposed rule, add
nutrients and solid loadings to receiving waters. In the absence of treatment, pollutant loadings from
individual CAAP facilities can contribute up to several thousand pounds of nitrogen and phosphorus per
year and up to several million pounds of total suspended solids (TSS) per year. Water quality concerns
related to these pollutant loadings are among several environmental concerns associated with the CAAP
industry.  CAAP facilities may also be associated with risks to native fishery resources and wild native
aquatic species from the establishment of escaped individuals. Several chemicals and therapeutic drugs
are used by the CAAP industry and can be released into receiving waters. CAAP facilities can also be
associated with the introduction of pathogens into receiving waters with potential impacts on native biota.
This chapter summarizes background information on these environmental concerns.
9.2    WATER QUALITY IMPACTS FROM NUTRIENTS AND SOLIDS

       The nutrient (nitrogen and phosphorus) and organic solids generated by CAAP facilities and
contained in their effluents have the potential to contribute to eutrophication (e.g., NOAA, 1999).
Eutrophication can be defined as an increase in the rate of supply of organic matter in an ecosystem
(NSTC, 2000).  The increase in organic matter can be caused either by increased inputs from sources
outside of the ecosystem (e.g., CAAP effluents, agricultural runoff, or industrial effluents) or by enhanced
organic matter production within the ecosystem caused by increased nutrient inputs to the system.
Eutrophication can lead to many water resource and aquatic ecosystem effects.  Consequences of
eutrophication have long been a concern in the protection and development of water resources and
include algal blooms, increased turbidity, low dissolved oxygen and associated stresses to stream biota,
                                              9-1

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increased water treatment requirements, changes in benthic fauna, and stimulation of harmful microbial
activity with potential consequences for human health (e.g., Dunne and Leopold, 1978, Wetzel, 1983).

       Ammonia, which is a form of the nutrient nitrogen, can also be directly toxic to aquatic life,
affecting hatching and growth rates offish.  It can also cause changes in the tissues of the liver, kidneys,
and gills  during structural development (Murphy, 2000a). When un-ionized levels of ammonia exceed
0.0125 -  0.025 mg/L, growth rates of rainbow trout are reduced and damage to liver, kidney, and gill
tissue may occur (IDEQ, n.d.).

       Solids (both suspended and settleable) can degrade aquatic ecosystems through multiple
mechanisms.  Suspended solids can increase turbidity and reduce the depth to which sunlight can
penetrate, which decreases photosynthetic activity and oxygen production by plants and phytoplankton
and potentially causes plant death and oxygen depletion associated with organic matter decomposition.
Decreased growth of aquatic plants also  affects a variety of aquatic life, which use the plants as habitat.
Increased suspended solids can also increase the temperature of surface waters by absorbing heat from
sunlight.  Suspended particles can also abrade and damage fish gills, increasing the risk of infection and
disease.  Increased levels of suspended solids can also cause  a shift toward more sediment tolerant
species, reduce filtering efficiency for zooplankton in lakes and estuaries, carry nutrients and metals,
adversely impact aquatic insects that are  at the base of the food chain, (Schueler and Holland, 2000), and
reduce fish growth rates (Murphy, 2000b).  Suspended particles reduce visibility for sight feeders and
disrupt migration by interfering with a fish's ability to navigate using chemical signals (USEPA, 2000a).
As sediment settles, it can smother fish eggs and bottom-dwelling  organisms, interrupt the reproduction of
aquatic species, destroy habitat for benthic organisms (USEPA, 2000a) and fish spawning areas, and
contribute to the decline of freshwater mussels and sensitive  or threatened darters and dace. Deposited
sediments also increase sediment oxygen demand,  which can  deplete dissolved oxygen in lakes or streams
(Schueler and Holland,  2000).

       A number of studies have quantified relationships between solid loadings and specific biological
endpoints.  These include studies relating suspended solids or  turbidity levels to stream
macroinvertebrate and invertebrate abundance and diversity (Gammon, 1970; Quinn  et al., 1992) and
reduced growth rates of stream invertebrates (Herbert and Richards, 1963; Buck, 1956).  Turbidity and
suspended solids have also been associated with reduced food consumption by certain life-stages of such

                                               9-2

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species as striped bass (Brietburg, 1988); coho salmon (Gregory and Northcote, 1993; Redding, 1987);
and cutthroat trout (European Inland Fisheries Advisory Council, 1964).

       The following subsections describe general characteristics of each major production system that
affect the potential of CAAP facilities to discharge nutrients and solids to receiving waters. Descriptions
for ponds, crawfish production, lobster pounds, bottom and off-bottom shellfish culture, aquariums, and
alligator production systems are not included because they are not subject to the proposed rule.
        Flow-Through Systems1

        Flow-through systems consist of raceways, ponds, or tanks that have constant flows of water
through them.  Flowing water in the systems is used to maintain water quality in the production system by
carrying away accumulating waste products, including feces, uneaten feed, and other metabolic wastes.
Discharges from flow-through systems tend to be large in volume and continuous.

        Raceway systems typically have quiescent zones located at the tail ends of the raceways to
collect solids.  The flowing water and swimming fish help move solids down through the raceway.  The
quiescent zones allow solids to settle in an area of the raceway that is screened off from the swimming
fish. The settled solids are then regularly removed from the quiescent zone by vacuuming. Designs,
which include baffles or other solids-flushing enhancements, help move solids to the quiescent zones
without breaking them into smaller particles.  Some systems, typically smaller raceway systems, use full-
flow settling in which all of the effluent passes through prior to discharge.  Tanks can be self-cleaning or
use concentrating devices to collect solids, enabling solids to be efficiently removed from the system.
Most facilities treat the collected solids in settling basins or some other type of dewatering process.  When
solids in tanks or raceways are collected and removed, waste streams from the treatment systems are
usually higher in pollutant concentrations, including solids, nutrients, and biochemical oxygen demand than
bulk flow discharges.
1 Information for the following four subsections was adapted from J. Avault, Fundamentals of
Aquaculture (AVA Publishing, Baton Rouge, Louisiana, 1996).
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       Recirculating Systems

       Recirculating systems are highly intensive culture systems that actively filter and reuse water
many times before it is discharged.  Recirculating systems usually have tanks or raceways to hold the
growing animals, and they have extensive filtration and support equipment to maintain adequate water
quality.  Recirculating systems use filtration equipment to remove ammonia from the production water.
Solids removal, oxygenation, temperature control, pH management, carbon dioxide control, and
disinfection are common water treatment processes used in recirculating systems.  The size of the
recirculating system depends primarily on available capital to fund the project and can be designed to
meet the production goals of the operator.

       The production water treatment process is designed to minimize water requirements, which leads
to small-volume, concentrated waste streams. A typical recirculating facility has one or more discrete
waste streams.  Solids removal from the production water produces an effluent that is high in solids,
nutrients, and BOD. Most systems add make-up water (about 5 to 10 percent of the system volume each
day) to dilute the production water and to account for evaporation and other losses. Some overflow
water, which is dilute compared to the solids water, is usually generated.

       Recirculating system facilities use a variety of methods to treat, hold, or dispose of the solids
collected from the production water. Some facilities send the collected solids, and some overflow water
directly to a publicly owned treatment works (POTW) for treatment.  Other facilities pretreat in settling
ponds or other primary treatment systems to concentrate solids and send a more dilute effluent to the
POTW.  Still others concentrate solids and then land-apply the solids slurry when practical. The overflow
water may be directly discharged, land-applied, or otherwise treated.
       Net Pens

       Net pens are suspended or floating holding systems used to culture some species offish in larger
water bodies, such as lakes, reservoirs, coastal waters, and the open ocean. The systems may be located
along a shore or pier or may be anchored and floating offshore. Net pens rely on tides and currents to
provide a continual supply of high-quality water to the cultured animals.  In most locations, net pens are

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designed to withstand the high-energy environments of open waters and are anchored to keep them in
place during extreme weather events. Strict siting requirements typically restrict the number of units at a
given site to ensure sufficient flushing to distribute wastes and prevent degradation of the bottom near the
net pens.

       Net pens use a floating structure to support nets, which are suspended under the structure in the
water column. The net pens vary in shape but are typically circular, square, or rectangular on the water
surface.  Their size also varies, depending on the available surface area and depth.  A common practice
in net pen culture is to use two nets—a containment net on the inside and an outer predator net to keep
out predators, such as seals.  At the surface, jump nets are used to keep fish from jumping out of the net
pen.  Bird nets are also suspended above the surface of the net pens to prevent bird predation.

       For net pen culture, the mesh size of the netting used to contain the fish is as large as possible to
prevent reduced water flows when fouling occurs, while still keeping the cultured fish inside the structure.
Most nets are cleaned mechanically with brushes and power washers.  Antifoulants have limited use in
the United States.  A few have been approved for food fish production, but those typically show minimal
effectiveness.

       Most net pens are regularly inspected by divers.  The divers look for holes in the nets, dead fish,
and fouling problems. State regulatory programs require benthic monitoring at many net pen sites to
ensure  that degradation is not occurring under or around the net pens.
        9.2.1   CAAP Industry Pollutant Loadings

        Pollutant concentrations in CAAP facility process waters are generally low because cultured
species require relatively high water quality for optimal production. However, pollutant concentrations in
effluents from waste treatment systems (e.g., settling basins) and solids storage structures can be quite
high, although discharges typically occur in small volumes.  Table 9-1 indicates example raw (in the
absence of effluent pollutant reduction treatments) pollutant concentrations from two different kinds of
CAAP facilities, as estimated by EPA for CAAP model facilities (Hochheimer and Mosso, 2002b,
Mosso, 2002).

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                                           Table 9-1
  Example Raw Pollutant Concentrations for Flow-Through and Recirculating Model Facilities

Flow-Through
Recirculating
BOD5
(mg/L)
11.172
1,838.66
TSS
(mg/L)
9.576
1,576.00
NH3
(mg/L)
0.010
1.58
Organic N
(mg/L)
0.014
2.36
NO2
(mg/L)
0.001
0.20
NO3
(mg/L)
0.023
3.77
Dissolved P
(mg/L)
0.059
11.37
Organic P
(mg/L)
0.053
8.67
Source: EPA estimates (Hochheimer and Mosso, 2002b).
       The values in Table 9-1 do not represent actual facilities but were derived using an engineering
model developed by EPA to calculate raw pollutant loadings from model facilities.  The model calculates
wastes generated in an CAAP system based on feed inputs, which were acquired from literature reviews
(Hochheimer and Mosso, 2002b).

       In the absence of treatment, CAAP facilities can generate locally significant loadings of
pollutants in terms of total annual mass (Table 9-2). These values are derived by multiplying appropriate
facility effluent flow rates, as estimated by EPA (Mosso, 2002) for a given facility type by the
corresponding raw pollutant concentrations in Table 9-1.  Raw pollutant loading estimates are presented in
Table 9-2 for several flow-through and recirculating systems model  facilities.  Raw pollutant loadings
from large net pen systems can be equal to or greater than the pollutant loading values shown in
Table 9-2.
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                                           Table 9-2
Example Model Facility Raw Pollutant Loadings for Flow-Through and Recirculating Systems
Model facility
Large salmon flow-through
Medium striped bass flow-through
Medium tilapia flow-through
Large tilapia flow-through
Medium trout flow-through
Large trout flow-through
Medium trout stackers flow-through
Large trout stockers flow-through
Large striped bass recirculating
Larae tilaoia recirculatine
Effluent
flow
(ft3/s)
92.7
2.7
6.0
22.3
4.7
47.2
4.9
20.7
0.1
0.05
BOD5
db/yr)
2,019,852
62,149
155,373
388,433
77,687
1,009,926
77,687
466,120
383,564
127.855
Total
Suspended
Solids (Ib/yr)
1,731,301
53,271
133,177
332,943
66,589
865,651
66,589
399,531
328,770
2.039.478
Note: See text for description of calculation.
Source: Hochheimer and Mosso, 2002b; Mosso, 2002.

       Table 9-2 demonstrates that total annual BOD5 and TSS loadings from medium and large CAAP
model facilities can be considerable. To place these annual loadings in context, the BOD5 and TSS
loading from a large salmon flow-through system is equivalent to the BOD5 and TSS loading in the
domestic wasteload of a city with over 20,000 individuals.  Appendix D documents the conversion factors
for this calculation.   Loadings from net pen facilities can also be relatively high. For example, the annual
BOD5 loading produced by a  single large salmon net pen facility (e.g., a facility with annual production of
over 3 million pounds, estimated to produce over 4 million pounds of BOD5 per year, is equivalent to the
BOD5 loading in the domestic wasteload of a city of approximately 65,000 people (Hochheimer, 2002).
                                              9-7

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        In addition, when multiple CAAP facilities are located on a single receiving water, which occurs
in such states as Idaho and Maine, cumulative pollutant loadings to the receiving water may be
correspondingly higher and may be of concern from a stream ecology perspective. EPA's Region 10
identified discharges from CAAP facilities as contributors to phosphorus loadings in the middle Snake
River, where over 70 CAAP facilities, several municipal treatment plants, and several food processors
were identified. The region adopted strict numeric limits on phosphorus from the CAAP facilities that led
to an overall reduction in phosphorus over the past 5 years (Fromm and Hill, 2002). Finally, observations
in Idaho receiving waters downstream of aquaculture facilities suggest that in the absence of solids
capturing treatments, sediment deposition can occur. Observations of 18 inches or more of organic
accumulations downstream of aquaculture facilities in Billingsley Creek, prior to the adoption of solids
capturing, and six feet deep below Box Canyon, also prior to solids capturing, have been reported
(USEPA, 2002b).
        9.2.2   Literature Review on Potential and Observed Water Quality Impacts

        EPA performed a literature review for reports of environmental effects associated with aquatic
animal production facilities (Terra Tech, 2001; Mosso, 2002). EPA's review focused on scientific
research reports in the United States. EPA also recognizes that research has been performed on the
environmental effects of CAAP facilities in other countries (e.g., within the European Union) as well.

        Much of the literature reviewed by EPA describes observations of nutrient and solids within the
discharge from CAAP facilities.  Some of these studies also discuss the release of biochemical or
chemical oxygen demand. There are limited studies in which biological variables downstream of CAAP
facilities have been measured.  Impacts such as the presence of pollution-tolerant benthic invertebrates
have been observed;  but in other cases, pollutants were not found to negatively impact the receiving
stream (e.g., Kendra, 1991; Selong and Helfrich, 1998).  Overall, EPA's initial literature search did not
identify extensive research literature regarding ecological effects arising from water quality degradation
downstream of CAAP facilities in the United States.  Appendix E lists publications found in EPA's
literature review that describe water quality measurements associated with CAAP facilities, by major
production system, as well as citations to additional literature describing aquatic animal production
practices or studies outside of the United States.

                                               9-8

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       9.2.3   State Listings of Impaired Waters

       Nutrient impacts from aquatic animal production facilities can also be evaluated from reports to
EPA on the causes and status of impaired water bodies (TMDL listings or State 303(d) reports). State
listings of waters for which CAAP has been identified as a potential source of impairment have been
compiled from 1998 and 2000 State TMDL listings (i.e. all 1998 State listings plus any new listings added
between 1998 and 2000).  Approximately forty-five different sources of impairment have been identified
on State TMDL listings. These other sources include general agricultural runoff, hydromodification, and
urban runoff. According to these recent reports, seven States (IL, LA, NH, NM, NC, OH, and VA) have
identified CAAP facilities as a potential source of impairment for one or more water bodies.  Again,
however, multiple potential causes of impairment are frequently cited for an impaired water body.

       Table 9-3 provides information about water bodies that are listed as impaired, where CAAP has
been identified as a potential source of impairment. Data which isolate the exclusive impact of CAAP
facilities on stream/river miles, lake/reservoir/pond acres, or square miles of estuaries/bays does not exist.
Thus, the values presented in the tables below represent water bodies and areas impacted by a number of
sources, where CAAP is one of the potential sources.  The table also provides the specific cause (e.g.,
pollutants) contributing to the impairment and the number of miles or acres affected. Types of causes
include nutrients, solids, organic enrichment, benthic degradation, other water quality concerns, and listings
where the cause was unknown.
                                              9-9

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                                         Table 9-3
          Impaired Water Bodies Where CAAP is Listed as a Source of Impairment
ID
ILNDDA01_NDDA01
LA- 120201
LA-120302
NHL70002010
NHL80101150(B)
NM-MRG2-20400
NC_27-86-26
NC_2-
SANTEETLAH_
LAKE GRAHAM
NC_6-10-lb
NC_6-10b
NC_6-2-(0.5)b
OH70 1
OH71 16
OH80 17- 86
VAV-B10R-02
VAV-B47R-03
VAV-B52R
VAV-H09R
VAV-I14R
VAV-I32R-01
State
Illinois
Louisiana
Louisiana
New Hampshire
New Hampshire
New Mexico
North Carolina
North Carolina
North Carolina
North Carolina
North Carolina
Ohio
Ohio
Ohio
Virginia
Virginia
Virginia
Virginia
Virginia
Virginia
Water Body Name
L Grassy Creek
Lower Grand River and
Belle River
Company Canal
Marsh Pond
York Pond
Rio Cebolla
Little Contentnea Creek
Santeetlah Lake
Morgan Mill Creek
Peter Weaver Creek
West Fork French Broad
Auglaize River
(Blanchard R. To Little
Auglaize R)
Flatrock Creek (OH/IN
Border To Wildcat Creek"
Bucyrus Reservoir #2
Cockran Spring
Lacey Spring
Orndorff Spring Branch
Montebello Spring
Branch
Coursey Springs Branch
Castaline Spring Branch
Stated Cause(s)
Flow Alterations, Nutrients, Siltation,
Suspended Solids
Nutrients, Organic Enrichment/Low DO,
Pathogens
Organic Enrichment/Low DO, Pathogens
Phosphorus
Phosphorus
Stream Bottom Deposits, Temperature
Low DO
Nutrients
Unknown
Unknown
Unknown
Habitat Alterations, Siltation, Organic
Enrichment/Low DO, Metals
Flow Alteration, Organic Enrichment/
Low DO, Pathogens
Flow Alteration, Noxious Aquatic Plants,
Nutrients, Siltation, Turbidity
Benthic Degradation
Benthic Degradation
Benthic Degradation
Benthic Degradation
Benthic Degradation
Benthic Degradation
Miles
4.6
39.5
5.9


15.0
27.0

0.3
0.8
0.5
7.5
10.1

16.0
16.0
16.0
0.2
16.0
16.0
Acres

2,026.0
183.1
59.4
180.0
23.5

280.0





36.4






Summary of Water Bodies Listed as Impaired

The information from Table 9-3 can be summarized by water body type and scope of impact to provide a
general summary of the impact of CAAP on impaired water bodies. Table 9-4 summarizes the specific
causes of impairment for each water body type. According to the data, streams and rivers have the most
reported impairments (sixteen) from  causes in which CAAP was a contributing source.  Only four lakes,
reservoirs, and ponds were listed as impaired, while only no estuaries/bays were reported as impaired.
                                          9-10

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                                           Table 9-4
                          Source of Impairment by Water Body Type
Water Body Type
Stream/River
L ake/Reservoir/Pond
Nutrients
X
X
Solids
X

Organic
X

Benthic
X

Other Water
X
X
Total Number
16
4
Table 9-5 provides information about the number of stream/river miles and lake/reservoir/pond acres
listed as impaired (where CAAP is a source of impairment) in each State.
                                           Table 9-5
          Miles/Acres for Which CAAP is Listed as a Potential Source of Impairment.3
State
Illinois
Louisiana
New Hampshire
New Mexico
North Carolina
Ohio
Virginia
Total
Miles of Streams/Rivers Impaired
5
45
n/a
15
29
18
80
192
Acres of Lakes/ Reservoirs/Ponds
Impaired
n/ab
2,209
239
24
280.0
36
n/a
2,788
3Other sources in addition to CAAP may have been cited as a potential source of impairment by the State
bn/a = not available.
Comparison to National Information

       Nutrients, solids, organic enrichment, benthic degradation, and other water quality concerns
(which as a group include flow alteration, siltation, low dissolved oxygen, turbidity, pathogens, metals,
temperature, and habitat alterations) are the leading pollutants in impaired streams and rivers in which
CAAP may be a contributing factor to the impairment. Nationally, the leading pollutants causing
                                             9-11

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impairment in streams and rivers are nutrients and other water quality concerns, such as metals and
siltation (USEPA, 2000b).  Thus, nutrients are frequently identified as a potential cause of impairment
both nationally and in waters where CAAP facilities are a potential source of impairment. Additionally,
metals and siltation are important causes of impairment both nationally and with CAAP-related listings.

       The leading pollutants in impaired lakes, reservoirs, and ponds in which CAAP may be a
contributing factor to the impairment are nutrients and other water quality concerns (which include flow
alteration, noxious aquatic plants, siltation, and turbidity). Nationally, the leading pollutants causing
impairment in lakes, reservoirs, and ponds are nutrients, metals, and siltation (USEPA, 2000b). Thus,
nutrients are frequently identified as a potential cause of impairment both nationally and in waters where
CAAP facilities are a potential source of impairment.  Siltation is also an important cause of impairment
both nationally and in water bodies where CAAP may be a source of impairment.

       CAAP is listed as one of the sources of impairment for f 92  miles of rivers and streams, based on
f 998 and 2000 TMDL State listings. Nationally, a total of 291,264 miles of rivers and streams are
impaired (USEPA, Appendix A-2, f 998a). For lakes, reservoirs, and ponds, CAAP was listed by the
States as a source of impairment for 2,788 acres.  By comparison, in the  entire United States, a total of
7,897,f f 0 acres of lakes, reservoirs, and ponds are listed as impaired (USEPA, Appendix B-2, f998b).
No information was available about the number of square miles of estuaries and bays listed as impaired, in
cases where CAAP was a potential source of impairment.  Again, it  is important to note that not all of the
water bodies in the United States have been assessed.
Comparison to Other Sources of Impairment

       To compare the leading pollutants associated with select sources of impairment, information about
the types of pollutants generally associated with each source was compiled in Table 9-6. Based on the
information in this table, nutrients and solids are the most common pollutants associated with each of the
sources of impairment examined.
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                                          Table 9-6
               Comparison of Leading Pollutants Among Sources of Impairment
Source of Impairment
Agriculture
Animal Feeding
Operations
Natural Sources
Urban Runoff
Pollutants
Nutrients
X
X
X
X
Solids
X
X
X
X
Organic Matter

X
X

Pathogens

X
X
X
Metals



X
Oil/Grease



X
       The leading sources of impairment in assessed streams, rivers, lakes, reservoirs, and ponds are
agriculture, hydromodification, and urban runoff/storm sewers.  Hydromodification is defined as the
alteration of the hydrologic characteristics of coastal and noncoastal waters, which in turn could cause
degradation of water resources (USEPA, 1997). It includes such changes as channelization or channel
modification.  The leading sources of impairment in estuaries are municipal point sources, urban
runoff/storm sewers, and atmospheric deposition (USEPA, 2000b).

       The scope of impact on various water bodies can be compared among sources of impairment.
Information from Table 9-7, where the scope of impact was provided for those States that reported
CAAP as a source of impairment, was compared to the scope of impact for other sources of impairment.
For the purposes of this comparison, other sources of impairment include agriculture, animal feeding
operations, natural sources, and urban runoff. These other sources are known to be large contributors to
the same causes of impairment (e.g., nutrients) as CAAP.  Table 9-7 compares the miles of impaired
streams and rivers among different sources of impairment.
                                            9-13

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                                           Table 9-7
             Comparison of Sources of Impairment in Rivers and Streams (Miles)
State
Illinois
Louisiana
New Mexico
North Carolina
Ohio
Virginia
Total
CAAP
Industry
5
45
15
28
17
80
192
Animal Feeding
Operations
124
269
0
0
28
0
421
Urban Runoff/
Storms Sewers
1,865
1,122
97
700
508
341
4633
Natural
Sources
213
1,377
221
0
240
532
2583
Agriculture
10,977
1,662
3,179
2,496
1,121
842
20277
Note: Only States that reported CAAP as an impairment source are listed.
Note: New Hampshire was not included in this table because the number of impaired miles in the State was not
provided.
Source: National Water Quality Inventory, Appendix A-5 (USEPA, 1998a).
       Table 9-8 provides information to compare the acres of impaired lakes, reservoirs, and ponds
among different sources of impairment. No impairment information was provided for animal feeding
operations for this category of water body.


                                           Table 9-8
       Comparison of Sources of Impairment in Lakes, Reservoirs, and Ponds (Acres)3
State
Louisiana
New Hampshire
New Mexico
North Carolina
Ohio
Total
Urban Runoff/
Storms Sewers
60
68
18
470
0
616
CAAP Industry
2,209
239
24
280
36
2,788
Natural Sources
76,397
75
11,357
0
0
87,829
Agriculture
17,040
0
92,834
74
0
109,948
aOnly States that reported CAAP as an impairment source are listed. Illinois and Virginia were not included in this
table because the number of impaired acres in these States was not provided.
Source: National Water Quality Inventory, Appendix B-5 (USEPA, 1998b).
                                              9-14

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Comments
       It is also important to recognize that not all water bodies have been assessed in every State and
the percentage assessed may vary widely. In some States, a very small percentage of water bodies have
been assessed. In other States, most or all of the water bodies have been assessed. For example, it is
reported that Louisiana has only assessed 9 percent of their rivers and streams (USEPA, 1998a) and that
Ohio has not assessed any of their lake, reservoir, and pond acres (USEPA, 1998b). In contrast, North
Carolina has assessed 89 percent of their river and stream miles (USEPA, 1998a) and New Hampshire
has assessed 95 percent of their lake, reservoir, and pond acres (USEPA, 1998b). Differences in
percentage of water bodies assessed makes comparisons among States difficult.  More important, for
States that have a low percentage of assessed water bodies,  conclusions from limited data may not
accurately represent the condition of a State's water bodies. Finally, when more than one source of
impairment and more than one pollutant are listed for a water body, it is difficult to determine which
source of impairment is "responsible" for which pollutant. For example, if CAAP and animal feeding
operations (AFOs) are both listed as the sources of impairment and nutrients and pathogens are both
listed as the pollutants causing impairment, such a listing makes it appear as if the nutrients and pathogens
are caused by both sources.   It is possible that CAAP may not be a source of pathogens for that
particular listed water body.  As a result, 303(d) data can complicate linkages between sources of
impairment and pollutants.
9.3    NON-NATIVE SPECIES

       Another area of concern regarding environmental impacts of CAAP facilities relates to potential
introductions of non-native aquatic organisms via intentional or accidental releases from CAAP facilities.
Non-native species can be defined as an individual, group, or population of a species that is introduced
into an area or ecosystem outside its historic or native geographic range. This term may include both
foreign (i.e., exotic) and transplanted species, and it can be used synonymously with "alien" and
"introduced" (Fuller et al., 1999).  There is some inconsistency in the terminology used by literature and
scientists when discussing non-native species.  The following terms are also used and their differences
should be noted:
                                              9-15

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        •      Aquatic nuisance species (ANS) - nonindigenous species that threaten the diversity or
               abundance of native species; the ecological stability of infested waters; or commercial,
               agricultural, aquacultural, or recreational activities dependent on such waters (Fuller et al.,
               1999).
        •      Exotic species - an organism introduced from a foreign country; a species native to an
               area outside of, or foreign to, the national geographic area under discussion (Fuller et al.,
               1999).
        •      Nonindigenous species - synonymous with non-native species (Fuller et al., 1999).
        •      Introduced - An organisms moved by humans (or by human actions) to an ecosystem,
               or region where it was not found historically due to human actions (i.e., an individual,
               group,  or population of organisms that occur in a particular locale because of human
               actions (Fuller et al., 1999).
        •      Invasive species  - a species that is 1) non-native (or alien) to the ecosystem under
               consideration and 2) whose introduction causes or is likely to cause economic or
               environmental harm or harm to human health (USDA, 2002).

        Scientists and resource managers have identified CAAP as a potential source of concern with
respect to non-native species issues (e.g. Alaska Department of Fish and Game,  2002; Carlton, 2001;
Goldburg et al., 2001; Naylor et al., 2001; and Volpe et al., 2000).  In addition, scientists have highlighted
concerns related to potential risks associated with the possible future use of genetically modified
organisms in aquatic animal production (e.g. Hedrick, 2001; Reichardt, 2000).
       9.3.1   Impacts of Non-Native Species

       In general, non-native species, which might be considered biological pollutants, can alter and
degrade habitat.  When species are introduced into new habitats, they often overrun the area and crowd
out existing species. If enough food is available, populations of non-native species can increase
considerably. Once non-native species are established in an area, they can be difficult to eliminate
(UMN, 2000).

       Many non-native species are introduced into the environment by accident when they are carried
into an area by vehicles, ships, produce, commercial goods, animals, or clothing (UMN, 2000) or when
                                              9-16

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they escape from CAAP facilities.  Other non-natives are introduced intentionally. Although some
species can be harmless or beneficial to an environment, others can be detrimental to ecosystems and
recreation (UMN, 2000).  Impacts  of non-native aquatic organisms on native aquatic species in North
America can be classified into five general categories, which include habitat alteration, trophic alteration,
spatial alteration, gene pool deterioration, and introduction of diseases.
       Habitat Alteration

       Non-native fish, such as carp or tilapia, introduced to control vegetation can cause a variety of
habitat impacts. Both exotic and native vegetation can be destroyed as a result of carp predation.  This, in
turn, results in bank erosion, restrictions on fish nursery areas, and acceleration of eutrophication as
nutrients are released from the plants.  Grass carp may adversely impact rice fields and waterfowl
habitat, while common carp reduce vegetation by direct consumption and by uprooting, as they dig through
the substrate in search of food.  Digging also increases turbidity in the water (AFS,  1997; Kohler and
Courtenay, n.d.).
        Trophic Alteration

        Non-native species may also cause complex and unpredictable changes in community trophic
structure.  Communities can be changed by explosive population increases of non-native fish or by
predation of native species by introduced species (AFS, 1997).  Several studies have documented dietary
overlap in native and introduced fishes.  As a result, there is potential for competition. However, it has
proven difficult to link dietary overlap to competition (Kohler and Courtenay, n.d.).

        Spatial Alteration

        Spatial changes may result from overlap in the use of space by native and non-native fish, which
may lead to competition if space is limited or of variable quality (AFS, 1997).
                                              9-17

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       Gene Pool Deterioration

       Heterogeneity may be decreased through inbreeding by species being produced in a hatchery.
This risk is most serious with species of intercontinental origin because the initial broodstock has a limited
gene pool  to begin with. If these species are introduced to new habitat, they may lack the genetic
characteristics necessary for them to adapt or perform as predicted. There is also a possibility that native
gene pools may be altered through hybridization when non-native species are introduced to a habitat.
However,  hybridization events in open waters are rare (AFS, 1997; Kohler  and Courtenay, n.d.).
       Introduction of Diseases

       Non-native species may transmit diseases caused by parasites, bacteria, and viruses to an
environment. The transmission of diseases from non-native species to native species is considered one of
the most serious threats to native communities (AFS, 1997).  There are numerous examples of non-native
species introducing diseases in native species. Transfer of diseased non-native fish from Europe is
believed to be responsible for introducing whirling disease in North America. Infectious hypodermal and
hematopoietic necrosis (IHHN) virus has been spread to a number of countries as a result of shipments of
live penaeid shrimp. IHHN was first diagnosed  at Hawaiian shrimp culture facilities in shrimp from
Panama.  "Ich," a common fish disease that is caused by a ciliated protozoan, may have been transferred
from Asia throughout the temperate zone with fish shipments (Kohler and Courtenay, n.d.).
       9.3.2   Case Studies of Non-Native Species

       EPA reviewed the literature for examples that illustrate the potential or actual role of aquatic
animal production in releases of non-native species. Several examples are presented below describing
Atlantic Salmon and several carp species.
                                              9-18

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       Atlantic Salmon

       Atlantic salmon (Salmo salar} are native to the Atlantic Coast drainages from northern Quebec
to the Housatonic River in Connecticut; inland to Lake Ontario.  They are also found in eastern Atlantic
drainages from the Arctic Circle to Portugal (USGS, 2000b).  Atlantic salmon are raised in net pens off
the East and West Coasts of the United States and in British Columbia.  Escapement has become a
critical concern due to potential impacts from disease, parasitism, interbreeding, and competition.  In areas
where the salmon are exotic, most concerns do not focus on interbreeding with  other salmon species.
Rather, they center on whether the escaped salmon will establish feral populations, reduce the
reproductive success of native species through competition, alter the ecosystem  in some unpredictable
way, or transfer diseases (EAO,  1997).

       Smolts and adult salmon are lost mainly as a result of operator error, predation, storms, accidents,
and vandalism.  However, it is important to note that escapement reports may not always be accurate.
While most escapement reports involve large numbers offish, small escapements are often unnoticed or
unreported. Leakage may occur from small holes in the net, during handling, or during transfer of fish to
another cage. Therefore, the number of escapements may be considerably greater if small escapes were
accounted for (Alverson and Ruggerone, 1998). It is also important to consider the fact that losses of
salmon from net pens may not always result from escapements. Fish may be lost because of
decomposition of carcasses or scavenging by birds, mammals, and fish (Nash, 2001). As a result, this
could reduce the estimated number of escapes. Reported escapes of Atlantic salmon in the United States
are summarized in Table 9-9.

       In addition to accidental escapes, some Atlantic salmon have been introduced intentionally.
Between 1951 and 1991, the State of Washington released 76,000 Atlantic salmon smolts into the Puget
Sound Basin in an attempt to establish this species on the west coast (Nash, 2001).
                                              9-19

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                     Table 9-9
Atlantic Salmon Escapements in Maine and Washington
Year
Area
No. of
Escapes
Comments
Reference
Maine
1996
2000
2000
2001
Trumpet
Island
Maine
Maine,
Stone Island
Maine
18,000
22,315
170,000
3,000-
5,000
Approximately 18,000 fish escaped when seals
ripped open one net pen.
Atlantic salmon escaped off the coast of Maine,
near one of the rivers where wild Atlantic salmon
are listed as endangered. The fish escaped from a
net pet, when a boat slammed into the pen and tore
a hole. The number of escaped fish reported by
Clancy (2000) was 13,000. However, the
Department of Marine Resources reported the
number of escapes as 22,315.
Atlantic salmon escaped from net pens when a
December Northeaster rocked Maine's Machias
Bay and uprooted the pen's moorings. The number
of fish that escaped has frequently been reported as
100,000. However, the actual number, which was
obtained from the Department of Marine
Resources, was 170,000.
Atlantic salmon escaped from a net pen in Eastport,
Maine.
Lewis, 2002,
)ersonal
communication
Clancy, 2000;
Lewis, 2002,
)ersonal
communication
Daley, 2001;
ASF, 2001;
Lewis, 2002,
)ersonal
communication
Daley, 2001;
ASF, 2001
Washington
1996
1997
1999
Cypress
Island
Bainbridge
Island
Bainbridge
Island
107,000
369,000
115,000
Atlantic salmon smolt and adults escaped from net
)ens near Cypress Island
Atlantic salmon escaped near Bainbridge Island
when the net pens were damaged pens as they
were towed away from a toxic algae bloom.
Atlantic salmon escaped from pens near Bainbridge
Island when extreme tidal flows snapped anchor
ines.
Amos and Appleby,
1999; Appleby,
2002, personal
communication;
Mottram, 1996;
Goldburg and
Triplett, 1997
Amos and Appleby,
1999; Appleby,
2002, personal
communication;
Mottram 1999
Amos and Appleby,
1999; Appleby,
2002, personal
communication
                       9-20

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       It is also important to note the number of escapes of Atlantic salmon in British Columbia because
these fish may end up in U.S. waters. Between  1987 and 1996, an estimated 154,554 Atlantic salmon
were reported to have escaped from marine farms in British Columbia.  These  losses do not include
"leakage," which could be substantial over time and may double estimated escapes as a worst-case
scenario (Alverson and Ruggerone, 1998). Additionally, the average number of escapees in British
Columbia reported from 1992 to 1996 was approximately 42,000 fish per year (EAO, 1997). Specific
examples of escapements of Atlantic salmon in British Columbia include the following (Alverson and
Ruggerone, 1998):

       •      Based on a 1994 report, 7,000 Atlantic salmon escaped from a trucker tank spill at
               Morstrom Lake.
       •      In the same year, more than 20,000 salmon escaped at Johnstone Strait because of seals.
       •      Over 21,000 salmon escaped at Johnstone Strait in 1994 because of a break in the
               mooring lines.
       •      In 1995, more than 31,000 salmon escaped because of a 15-foot tear at 30 feet depth.
       •      40,000 young Atlantic salmon escaped in 1996 from a net pen  in Georgia Lake.

Although it remains uncertain whether escaped Atlantic salmon can definitely transfer diseases, it is
useful to  examine some biological information on escaped salmon, which was reported by the
Environmental Assessment Office (EAO) of British Columbia. Between 1991  and 1995, ninety adult
Atlantic salmon recovered in British Columbia and Alaska were examined to determine if they were
infected with any diseases. Two fish were infected with Aeromonas salmonicida, the causative agent of
furunculosis, and none of the fish contained unusual parasite infestations. Additionally, none of the tested
fish were infected with common viral infections  (Alverson and Ruggerone, 1998).

       In contrast, Atlantic salmon stocked in Puget Sound were believed to have been responsible for
introducing a new disease, viral hemorraghic septicemia (VHS), to the west coast.  This disease has been
found in two salmon hatcheries in Puget Sound (Dentler, 1993). VHS is a systemic infection of various
salmonid and a few nonsalmonid fish.  It is caused by a rhabdovirus and may result in significant
cumulative mortality. Fish that survive become  carriers of the disease.  VHS is enzootic in most
                                             9-21

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countries of continental Eastern and Western Europe.  However, the virus has been isolated off the coast
of Washington, in Puget Sound (McAllister, 1990).

       Experiments have shown that Atlantic salmon (Salmo salar), brook trout (Salvelinus fontinalis),
golden trout (O. aguabonita), rainbow trout x coho salmon hybrids, giebel (Carassius auratus gibelio),
sea bass (Dicentrarchus labrax) and turbot (Scophthalmus maximus) are all susceptible to VHS.
Experiments have also shown that common carp (Cyprinus carpio), chub (Leuciscus cephalus),
Eurasian perch (Perca fluviatilis), roach (L.  rutilus),  and tench (Tinea tinea) are all refractory to VHS
(McAllister, 1990).
       Common Carp

       Common carp (Cyprinus carpio), which are also referred to as German carp, European carp,
mirror carp, leather carp, and koi, are native to Eurasia. There is some uncertainty concerning when and
where they were first introduced into the United States (USGS,  1999). However, early reports state that
common carp were brought to the United States from Europe in 1831.  After that time, common carp
were produced and distributed throughout the Upper Mississippi River System (USGS, 200la). Common
carp can be used as an example to show how other carp species can become an environmental
problem.

       The common carp can be considered a nuisance species because it is widely distributed
throughout the United States and it detrimentally affects aquatic habitats (USGS, 1999). Richardson et al.
(1995) found that common  carp adversely affect biological systems, causing increased turbidity and
destruction of vegetated breeding habitats for birds and fish. The carp stirs up bottom sediments during
feeding, which increases turbidity and siltation (Lee et al.,  1980). This type of behavior also destroys
rooted aquatic plants, which provide habitat for native fish species and food for waterfowl (Dentler,
1993). Laird and Page (1996) also found that common carp might compete with ecologically similar
species such as buffalos and carpsuckers.

       Common carp sometimes prey on the eggs of other fish species (Taylor et al., 1984; Miller and
Beckman, 1996).  This may have caused the decline of the razorback sucker (Xyrauchen texanus} in the

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Colorado River basin (Taylor et al., 1984). Additionally, Miller and Beckman (1996) found white sturgeon
(Acipenser transmontanus) eggs in the stomachs of common carp in the Columbia River.
        Grass Carp

        The grass carp (Ctenopharyngodon idelld), or white amur, is native to the Amur River in China
and Russia.  It was first imported to the United States in 1963 to aquatic animal production facilities in
Alabama and Arkansas and is used for biological control of vegetation. The first release of grass carp
occurred in Arkansas, when fish escaped from the Fish Farming Experimental Station (Courtenay et al.,
1984).  Grass carp were first documented in the Mississippi River along Illinois in  1971 (USGS, 200la).
In the last few decades, the grass carp has spread rapidly as a result of research projects, escapes from
ponds and aquaculture facilities, legal and illegal interstate transport, releases by individuals and groups,
stockings by Federal, State, and local government agencies,  and natural dispersion from introduction sites
(Pflieger, 1975; Lee et al., 1980; Dill and Cordone, 1997).

        Pennsylvania, New Jersey, Delaware, and Virginia have  all approved the use of grass carp for
weed control, with certain restrictions.  These States require that the fish be "triploid," meaning that they
must have three sets of chromosomes instead of two, which makes the fish sterile (University of
Delaware, 1995).  Although researchers have reported that the probability of successful reproduction of
triploid grass carp is "virtually nonexistent" (Loch and Bonar, 1999), some researchers have questioned
the sterility of triploids because techniques used to induce triploidy are not always effective.  Therefore,
each fish should be genetically checked (USGS, 2001b).  Measures should also be taken to reduce the
number of escapes by these fish.  Barriers could be constructed and maintained to prevent migration from
lakes.  Additionally, consideration should be given to the location and type of water bodies stocked with
grass carp.  Lakes and ponds that are prone to flooding should not be stocked with these carp (Loch and
Bonar, 1999).

        According to the literature, there are a variety of actual and potential impacts of introducing
grass carp to an area.  Shireman and Smith (1983) concluded that the effects of grass carp on a water
body are complex and depend on the stocking rate, macrophyte abundance, and the ecosystem's
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community structure.  Negative effects of grass carp include interspecific competition for food with
invertebrates and other fish, interference with fish reproduction, and significant changes in the
composition of macrophyte, phytoplankton, and invertebrate communities. Chilton and Muoneke (1992)
reported that grass carp might affect other species indirectly, by modifying preferred habitat, or directly,
through predation or competition when food is scarce.  Bain (1993) reports that grass carp have
significantly altered the food web and trophic structure of aquatic ecosystems by causing changes in fish,
plant, and invertebrate communities. More specifically, he indicates that these effects are largely a result
of decreased density and composition of aquatic plants.

       The removal of vegetation by grass carp can result in the elimination of food, shelter, and
spawning substrates for native fish (Taylor et al., 1984).  Additionally, the partial digestion of plant
material by grass carp results in increased phytoplankton populations because grass carp can only digest
half of the plant material that they consume.  The rest of the material is released into the water and
increases algal blooms (Rose, 1972), which decreases oxygen levels and reduces water clarity  (Bain,
1993).

       Grass carp may carry diseases and parasites that are known to be infectious or potentially
infectious to native fish. Grass carp imported from China are believed to be responsible for introducing
the Asian tapeworm Bothriocephalus opsarichthydis (Hoffman and Schubert, 1984;  Ganzhorn et al.,
1992).
        Other Species of Carp

        Black carp (Mylopharyngodon piceus), which are also known as Asian black carp, black amur,
snail carp, and Chinese roach, are native to eastern Asia, from the Pearl River basin in China north to the
Amur River (USGS, 2000a). Black carp are currently maintained in research, resource management, and
other fish production facilities in several States and were first brought into the United States in the early
1970s as a "contaminant" in imported stocks of grass carp. In the early  1980s, black carp were imported
as a food fish and as a biological control agent to combat the spread of yellow grub Clinostomum
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margaritum in aquaculture ponds (Nico and Williams, 1996).  Although black carp have been in the
United States for about 30 years, they have not been found in the wild (USFWS, 2002).

        Although Asian black carp provide a cheap means for controlling trematodes in catfish ponds,
they feed on many different mollusks. This may pose an ecological risk in the Mississippi Basin because
black carp are currently held in eight southern States and 90 percent of the freshwater mollusks
designated as threatened, endangered, or of special concern are found in the Southeast. Additionally,
black carp have escaped and colonized open water in all other countries where they have been
introduced.  Although most of the carp in the eight States are in sterile triploid form, Mississippi permitted
the use of fertile diploids in 1999 in response to a major outbreak of trematodes.  This caused fishing and
conservation groups to petition for black carp to be listed as "injurious" under the Federal Lacey Act
(Naylor et al.,  2001).  The U.S. Fish and Wildlife Service has proposed to list  black carp as an injurious
species (67 FR 49286, July 31, 2002).

        Black carp are very similar to grass carp.  The body shape and size and the position and size of
both the eyes and fins are similar with both species. Additionally, it is difficult to distinguish between
juveniles of the two species. Nico and Williams (1996) expressed concern that if black carp become
more common in U.S. aquaculture, there will be an increased risk of accidental introductions as grass
carp if the two species are identified incorrectly.

        Silver and bighead carp are two Asian carp that have been identified  as species  of significant,
immediate concern to aquatic resource  managers.  Bighead carp first began to appear in open waters in
the Ohio and Mississippi rivers in the early 1980s "likely as a result of escapes from aquaculture facilities"
(Jennings 1988, as cited in Fuller et al.,  1999). According to the International Joint Commission
(Schomack and Gray, 2002), Asian carp pose a tremendous threat to the biological integrity of the Great
Lakes and may result in economic and ecological damages to the  Great Lakes ecosystem that far exceed
those brought  about by the previous introduction of the sea lamprey and the zebra mussel. The
International Joint  Commission recently urged that U.S. and Canadian governments should consider
implementing  regulatory controls to prevent introduction of Asian carp via other pathways including the
food and bait fish industries, the aquarium trade, and aquaculture (Schomack and Gray, 2002).
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9.4    PATHOGENS

       CAAP facilities are not considered a source of pathogens that adversely affect human health.
CAAP facilities culture cold-blooded animals (fish, crustaceans, mollusks, etc.) that are unlikely to harbor
or foster such pathogens (MacMillan et al., 2002). Although it is possible for CAAP facilities to become
contaminated with human pathogens (e.g., by contamination of facility or source waters by wastes from
warm-blooded animals) and, as a result, become a source of human pathogens, this is not considered a
substantial risk in the United States (MacMillan et al., 2002).

       On the other hand, some CAAP facilities may serve as sources of pathogens that adversely
affect aquatic organisms (JSA, 1997). For example, wastes and escapement of infected shrimp from
CAAP facilities is considered a major potential pathway for wild shrimp exposure to viral diseases (JSA,
1997). The Pacific Northwest Fish Health Protection Committee (PNFHPC) has established policies to
prevent the spread of pathogens that might lead to release from hatcheries of seriously infected salmon
(Strom et al., n.d.). With respect to fish hatcheries, however, while they may potentially be reservoirs of
infectious agents (due to higher rearing densities  and stress), little evidence suggests that disease
transmission to wild stocks from hatcheries occurs routinely (Strom et al., n.d.).
9.5    DRUGS AND OTHER CHEMICALS

       A number of drugs and chemicals are in use at CAAP facilities.  For example, formalin and
hydrogen peroxide are used to control fungus on salmon and esocid eggs (Hochheimer and Mosso,
2002a).  In addition, antibiotics are also used at CAAP facilities, are typically incorporated into feed, and
can ultimately be released into the environment.  Once in the environment, antibiotics are most commonly
bound to sediment and other particles.  Prolonged exposure to residual antibiotics can alter target
organisms, making them antibiotic resistant with effects that may spread beyond the original area of use
(NOAA, 1999).
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       Metals may be present in CAAP wastewaters due to a variety of reasons. They may be used as
feed additives, occur in sanitation products, or they may result from deterioration of CAAP machinery
and equipment. Many metals are toxic to algae, aquatic invertebrates, and/or fish. Although metals may
serve useful purposes in CAAP operations, most metals retain their toxicity once they are discharged into
receiving waters. EPA has observed that many of the treatment systems used within the CAAP industry
provide substantial reductions of most metals since most of the metals can be adequately controlled by
controlling solids.

       Pesticides may  be used for controlling animal parasites and aquatic plants and may be present in
wastewaters. Some pesticides are bioaccumulative and retain their toxicity once they are discharged into
receiving waters. Similar  to metals, although EPA observed that many of the treatment systems used
within the CAAP industry provide adequate reductions of pesticides, most systems are not specifically
designed and operated to  remove pesticides.

       The U.S. Food and Drug Administration (FDA)/Center for Veterinarian Medicine (CVM)
regulates animal drugs under the Federal Food, Drug, and Cosmetic Act (FFD&CA). Four categories of
drugs are used in aquaculture: (1) six commercial drugs currently approved for specific species, specific
diseases, and at specific doses or concentrations; (2) investigational new animal drugs which are used
under controlled conditions under an Investigational New Animal Drug (INAD) application; (3) other
veterinary and human drugs as determined by a veterinarian under the extra-label use provisions of the
Animal Medicinal Drug Use Clarification Act of 1994 (AMDUCA); and (4) drugs designated by FDA as
low regulatory priority. The use of these drugs is regulated by FDA/CVM, which requires that users read
the label directions to ensure that the product is used in a safe and  effective manner. The label  directions
may include directions on proper dilution before discharge and can require other conditions that affect the
amount of drug contained in effluents.  FDA/CVM approves new animal drugs based on scientific data
provided by the drug sponsor. This data includes environmental safety data that is used in an
environmental risk assessment for the drug (Eirkson et al., 2000).

       Reviews of literature relating to drugs and chemicals used in aquaculture have been published
(e.g., GESAMP 1997; Boxall et al., 2001).  Although these reviews are not focused on practices in the
United States,  certain observations may have relevance to the United  States.  GESAMP (1997) reviewed
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chemicals used in coastal aquaculture, which include chemicals associated with structural materials, soil
and water treatments, antibacterial agents and other therapeutic drugs, pesticides, feed additives, and
anaesthetics.  According to this review, most aquaculture chemicals, if properly used, can be viewed as
wholly beneficial with no adverse environmental impacts or increased risks to aquaculture workers.
However, the authors identified several factors that could make the use of otherwise acceptable
chemicals unsafe: these include excessive dosage and failure to provide for adequate neutralization or
dilution prior to discharge. Among potential environmental issues of concern relating to improper use
include chemical residues in wild fauna, toxic effects in non-target species, and antibacterial resistance.
The authors conclude with recommended measures to promote safe and effective use of chemicals in
coastal aquaculture.

        Boxall et al.  (2001) present a summary of environmental impacts from drug use in aquatic animal
production that includes a comprehensive review of the potential impacts of oxytetracycline, which is the
most widely used antibiotic medication at CAAP facilities in the United States.  Because most CAAP
treatments with medications  use medicated feed and treatment baths, the direct application of the drug to
the production water presents higher risks for water quality and ecological problems. In net pen systems,
the production water is the receiving water and any uneaten or residual drug directly transfers to the
water around and bottom sediments under the net pen. For other CAAP facilities, like flow-through and
recirculating systems, much of the unmetabolized drug can be bound to feces and other solids in the
effluent. Unless all of the solids are captured in these systems, some of the drug is released to the
surrounding receiving water bound to the released solids, as well as any of the drug still in aqueous forms.

        Using oxytetracycline as an example, the drug is administered through the feed, which presents
several challenges. Oxytetracycline is administered in the feed, to sick fish that often have reduced
appetites.  Most forms of oxytetracycline are not readily assimilated by the fish, so much of the
medication in the feed eaten  by the fish passes through unmetabolized. Boxall et al. (2001) reported that
oxytetracycline is very persistent in manures and manure slurries, soils, and sediments with detection in
these media ranging from 9 to over 400 days post treatment.  These bound forms of oxytetracycline
create the potential for uptake by non-targeted species (i.e., wild populations offish, crustaceans, and
other organisms). Some of the studies reported by Boxall et al. (2001) indicate evidence of
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oxytetracycline residue in wild species (see Capone et al., 1996 for an example from net pen systems in
the western United States).

       In the United States, some attention has been given to potential water quality and environmental
effects of the release of drugs and chemicals into receiving waters (e.g., Goldburg et al., 2001). EPA's
Region 10 office has included requirements in a general permit for CAAPs in Idaho  to submit data on
disease control drugs, disinfectants, and similar products.  As stated in the proposed  permit, these data
would be used to enable EPA to determine whether there is a reasonable potential for the effluent
discharge to cause or contribute to an instream excursion above the state of Idaho's water quality
standards. In addition, in the Response to Comments document  accompanying the proposed permit, EPA
noted that such data were deemed necessary to determine whether aspects of these  products' application
may have adverse effects on aquatic biota (USEPA, 2002b).  Similarly, in a final permit issued to a
salmon net pen CAAP in Maine, EPA's Region 1 office required certain limits and monitoring
requirements to ensure that the discharge of some chemicals will meet state water quality standards.
These provisions include limiting of the discharge of drugs to those approved by FDA for treatment of
salmonids; prohibition of prophylactic use of drugs except for specific situations which warrant such use;
monthly reporting requirements regarding drug use; monitoring for the presence of copper in sediments if
nets are impregnated with copper-based antifoulants; and monitoring for the presence of zinc in sediments
if feed contains zinc additives.  In addition, EPA reserved the right to require the permittee to monitor the
discharge of FDA approved drugs if EPA suspects that the frequency, concentration, or method of
application creates a reasonable potential to cause or contribute to a violation of state water quality
standards (USEPA, 2002a).
9.6     OTHER POTENTIAL IMPACTS

        Maintenance of the physical plant of aquaculture facilities can generate organic materials that
may contribute to water quality degradation (NOAA, 1999). For example, the activity of cleaning
fouling organisms from net pens can contribute solids, BOD, and nutrients, although these inputs are
generally produced only over a short period of time. Cleaning algae from flow-through raceway walls
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and bottoms similarly generates pollutants in effluent. Net pen facilities in both Maine and Washington
are prohibited from cleaning net pens in place and must take them onshore for cleaning.

        Some concern about the potential presence of contaminants (e.g., PCBs, dioxins, pesticides, and
mercury) in aquatic animals produced at CAAP facilities has been reported and debated in the technical
literature.  EPA found limited evidence that contaminants, primarily from feed ingredients, could be
infrequently present in the aquatic animals and presumably in the effluents.  EPA also found that the most
comprehensive studies indicate very few problems associated with  such contaminants in aquatic animals
produced at CAAP facilities.

        The Massachusetts Office of Coastal Zone Management asserts that the fish consumption
advisories set by the Department of Public Health do not pertain to fish cultured in aquaculture facilities
because fish from aquaculture facilities come from clean water sources and do not bioaccumulate
contaminants during the short time they are being grown out to market size (Massachusetts Office of
Coastal Zone Management, 2001). The World Bank Group argues that aquaculture facilities can
minimize public health risks by proper  site evaluation and good aquacultural practices because operators
of aquaculture facilities have more control over the environment of their cultured fish than anyone has
over wild fish, and can therefore reduce health risks (The World Bank Group, 2001).

        The Pennsylvania Department  of Environmental Protection laboratory conducted testing from
Pennsylvania Fish and Boat Commission hatcheries revealed levels of PCBs in trout did not warrant a fish
consumption advisory, as  the hatchery fish were below the  Food and Drug Administration (FDA)
tolerance level of two parts per million (ppm). In fact, the  PCB levels were found to be less than 0.10
ppm (Pennsylvania Department of Health, 2001;  Fish and  Boat Commission, 2001). Santerre et al.,
(2000) studied contaminants in channel catfish, rainbow trout, and red swamp crayfish  collected from 8
southern States in the United States. The research revealed that 45% catfish, 72% trout, and 92%
crayfish contained no detectable residues of organochlorine, organophosphate, pyrethroid compounds.  Of
the detectable residues, most were well below FDA action limits for fish. Chlorpyrifos was detected in
some samples of catfish, but there is not an established limit for this and these residues  were not found in
fish collected after the first year of study (Santerre et al., 2000). This study also showed that levels of
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mercury in the fish were 40 to 100 times lower than the 1-ppm limit set by FDA. In a related study, these
researchers found very low levels of 34 pesticides in the same fish species (Scientific America, 2001).

       Results from these studies tend to indicate that most aquaculturally grown fish contain very low
and safe amounts of potentially harmful pollutants.  When they occur, the most likely source of these
pollutants is the feed or ingredients used to formulate the feed, although source water or local soil
conditions could contribute pollutants as well. A study conducted by Rappe et al., (1998) analyzed a
combined catfish feed sample from Arkansas and concluded that one of its ingredients (soybean meal)
was highly contaminated with polychlorinated dibenzo-p-dioxens (PCDDs). A more extensive study by
the same researchers showed that samples of farm-raised catfish from the southeast US contained
significant levels  of PCDD, polychlorinated dibenzofurans (PCDF), and PCB.  They concluded that the
major source for  the PCDD, PCDF,  and PCB appeared to be from the feed, which, as discovered earlier,
contained high levels of PCDD (Fiedler, 1998).  The source of contaminants in the catfish feed was
identified and subsequently eliminated from the feed ingredients.
9.7    REFERENCES

Alaska Department of Fish and Game, 2002. Atlantic Salmon. A White Paper. White Paper prepared by
the Alaska Department of Fish and Game. March 5, 2002.

Alverson, D.L., and G.T. Ruggerone. 1998. Escaped Farm Salmon: Environmental and Ecological
Concerns. Environmental Assessment Office, Government of British Columbia.
.
Accessed March 2002.

AFS (American Fisheries Society). 1997. Resource Policy Handbook: Introduction of Aquatic
Species.  American Fisheries Society, . Accessed
January 2002.

Amos, K.H., and A. Appleby. 1999. Atlantic Salmon in Washington State: A Fish Management
Perspective. Washington Department of Fish and Wildlife,  Olympia, WA
. Accessed April 2002.

Appleby, A., Washington Department of Fish and Wildlife. Personal communication, April 24, 2002.

                                             9-31

-------
ASF (Atlantic Salmon Federation). 2001. Catastrophic Salmon Escape Prompts Call for Moratorium
on the Aquaculture Industry. Atlantic Salmon Federation, St. Andrews, NB.
. Accessed April 2002.

Avault, J. 1996. Fundamentals of Aquaculture. AVA Publishing, Baton Rouge LA.

Bain, M.B. 1993. Assessing Impacts of Introduced Aquatic Species: Grass Carp in Large Systems.
Environmental Management 17(2):211-224.

Boxall, A., L. Fogg, P. Blackwell, P. Kay, and E. Pemberton. 2001. Review of Veterinary Medicines in
the Environment. R&D Technical Report, Environment Agency, Bristol, UK.

Breitburg, L. 1988.  Effects of Turbidity on Prey Consumption by Striped Bass Larvae. Transactions of
the American Fisheries Society 177:72-77.


Buck, D.H. 1956. Effects of Turbidity on Fish and Fishing.  Transactions of the 195 6 North American
Wildlife Conference 21:249-216.

Capone, D., D. Weston, V. Miller, and C. Shoemaker.  1996. Antibacterial residues in marine sediments
and invertebrates following chemotherapy in aquaculture. Aquaculture, 145, 55-75.

Carlton, IT. 2001. Introduced Species in U.S. Coastal Waters. Environmental Impacts and
Management Priorities. Prepared for the Pew Oceans Commission, Arlington, VA., 28 pp.

Chilton, E.W., and M.I. Muoneke. 1992.  Biology and Management of Grass Carp {Ctenopharyngodon
idella, Cyprinidae) for Vegetation Control:  a North American Perspective. In Fish Biology and
Fisheries 2:283-320. In United States Geological Survey, 2001. Nonindigenous Fishes -
Ctenopharyngodon idella. .
Accessed March 2002.

Clancy, M.A. 2000, November 30. Mishap Releases Farmed Salmon. Bangor Daily News.


Courtenay, W. R, Jr., D. A. Hensley, J. N. Taylor, and J. A. McCann. 1984. Distribution of Exotic
Fishes in the Continental United States. In Distribution, Biology and Management of Exotic Fishes,
ed. W.R Courtenay, Jr., and J.R. Stauffer, Jr., pp.41-77. Johns Hopkins University Press, Baltimore,
MD.

Daley, B.  2001, February 23. Escaped Farm Salmon Raise Alarm in Maine. The Boston Globe.

Dentler, J. L. 1993.  Noahs Farce: The regulation and Control of Exotic Fish and Wildlife. University of
Puget Sound Law Review  17:191-242.

Dill, W.A, and A. J. Cordone. 1997. History and Status of Introduced Fishes in California,  1871-1996.
Manuscript for Fish Bulletin of the California Department of Fish and Game. In United States

                                             9-32

-------
Geological Survey, 2001.  Nonindigenous Fishes - Ctenopharyngodon idella.
. Accessed March 2002.

Dunne, T., and L.B. Leopold. 1978. Water in Environmental Planning.  W.H. Freeman and Company,
NY.,  818pp.

EAO (Environmental Assessment Office). 1997.  Impacts of Farmed Salmon Escaping from Net Pens.
Environmental Assessment Office, Government of British Columbia.
.  Accessed March 2002.

Eirkson, C.E., R. Schnick, R. MacMillian, M.P. Gaikowski, and J. F. Hobson.  2000. Aquaculture
Effluents Containing Drugs and Chemicals, second draft prepared July 23, 2000. Technical  Subgroup
for Drugs and Chemicals, Aquaculture Effluents Task Force, Joint Subcommittee on Aquaculture,
Washington, DC.

European Inland Fisheries Advisory Commission.  1964.  Water Quality Criteria for European Freshwater
Fish: Report on Finely Divided Solids and Inland Fisheries. Journal of Air and Water Pollution
9(3): 151-168.

Fiedler, H., K.  Cooper, S. Bergek, M.  Hjelt, C. Rappe, M. Bonner, F. Howell, K. Willett, and S. Safe.
1998. PCDD, PCDF, and PCB in Farm-Raised Catfish from Southeast United States - Concentrations,
Sources, and CYP1A Induction. Chemosphere 37(9-12):1645-1656.

Fromm, C. and B. Hill. 2002. EPA Region 10 Comment Letter on the Developing Effluent Guidelines for
Concentrated Aquatic Animal Production Facilities. Letter to Jan Goodwin, U.S. Environmental
Protection Agency, May 1, 2002.

Fuller, P.L., L.G Nico, and J.D. Williams. 1999. Nonindigenous Fishes Introduced into Inland
Waters of the United States. American Fisheries Society Special publication 27.  Bethesda, MD.

Gammon, J.R.  1970. The Effect of Inorganic Sediment on Stream Biota.  Water Pollution Control
Research Series 18050 DWC 12/70. U.S. Environmental Protection Agency, Washington, DC, 141 pp.

Ganzhorn, J., J. S. Rohovec,  and J. L.  Fryer. 1992. Dissemination of Microbial Pathogens through
Introductions and Transfers of Finfish. In Dispersal of Living Organisms into Aquatic Ecosystems, ed.
A. Rosenfield,  and R. Mann, pp. 175-192. Maryland Sea Grant, College Park, MD. In United States
Geological Survey, 2001.  Nonindigenous Fishes - Ctenopharyngodon idella.
. Accessed March 2002.

GESAMP.  1997.  Towards  safe and effective use of chemicals  in coastal aquaculture.
IMO/FAO/UNESCO-IOC/WMO/IAEA/UN/UNEP Joint Group of Experts on the Scientific Aspects of
Marine Environmental  Protection.  Reports and Studies GESAMP. No. 65. London, IMO. 40 pp.
. Accessed October 23, 2001.
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-------
Goldburg, R, and T. Triplett.  1997. Murky Waters: Environmental Effects ofAquaculture in the US.
The Environmental Defense Fund, NY.

Goldburg, R.J., M.S. Elliott, and R.L. Naylor. 2001. Marine Aquaculture in the United States:
Environmental Impacts and Policy Options. Pew Oceans Commission, Arlington, VA., 33 pp.

Gregory, R.S., and T.G Northcote. 1993. Surface, Planktonic and Benthic Foraging by Juvenile Chinook
Salmon, Oncorhynchus tshawytscha, in turbid laboratory conditions. Canadian Journal of Fisheries
and Aquatic Sciences 50:233-240.

Hedrick, P.W. 2001. Invasion of Transgenes from Salmon or other Genetically Modified Organisms into
Natural Populations. Canadian Journal of Fisheries and Aquatic Science 58(2001):841-844.

Herbert, D.W.M., and J. M. Richards. 1963. The Growth and Survival of Fish in some Suspensions of
Solids of Industrial Origin. International Journal of Air and Water Pollution 7:297-302.


Hochheimer, J. 2002.  Technical Memorandum: Human Population Equivalents. Terra Tech Inc., Fairfax,
VA.

Hochheimer, J. and D.  Mosso. 2002a. Technical  Memorandum: Formalin and Hydrogen Peroxide Use on
Fish Eggs. Tetra  Tech  Inc., Fairfax, VA.

Hochheimer, J. and D.  Mosso. 2002b. Technical  Memorandum: Revised North Carolina Prototype
Facility Case Study. Tetra Tech Inc., Fairfax, VA.

Hoffman, G L., and G. Schubert. 1984. Some Parasites of Exotic Fishes. In Distribution, Biology, and
Management of Exotic Fishes, ed. W.R. Courtenay, Jr., and J.R Stauffer, Jr., pp. 233-261. The Johns
Hopkins University Press, Baltimore, MD.

IDEQ (Idaho Division of Environmental Quality). n.d. Idaho  Waste Management Guidelines for
Aquaculture Operations. Idaho Division of Environmental Quality.
. Accessed December 2001.


Jennings, D.P. 1988. Bighead carp (hypophthalmichthys nobilis): a biological synopsis.  U.S. Fish and
Wildlife Service.  Biological Report 88(29).

JSA (Joint Subcommittee on Aquaculture) Shrimp Virus Work Group. 1997. An Evaluation of Potential
Shrimp Virus Impacts on Cultured Shrimp and Wild Shrimp Populations in the Gulf of Mexico and
Southeastern U.S. Atlantic Coastal Waters. A report to the Joint Subcommittee on Aquaculture
prepared by the JSA Shrimp Virus Work Group.  June 5, 1997, 65 pp.
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-------
Kendra, W. 1991. Quality of Salmonid Hatchery Effluents during a Summer Low-Flow Season.
Transactions of the American Fishery Society 120:43-51.

Kohler, C.C., and W.R. Courtenay. n.d.  American Fisheries Society Position on Introductions of Aquatic
Species. American Fisheries Society, Introduced Fish Section, .
Accessed January 2002.

Laird, C.A., and L.M. Page. 1996. Non-Native Fishes Inhabiting the Streams and Lakes of Illinois.
Illinois Natural History Survey Bulletin 35(1):1-51. In United States Geological Survey, 1999.
Nonindigenous Fishes- Cyprinus carpio. . Accessed March 2002.

Lee, D. S., C. R.  Gilbert, C. H. Hocutt, R. E. Jenkins, D. E. McAllister, and J. R Stauffer, Jr. 1980.
Atlas of North American Freshwater Fishes. North Carolina State Museum of Natural History, Raleigh,
NC.

Lewis, J., Maine  Department of Marine Resources. Personal communication, April 9, 2002.

Loch, J.J., and S.A. Bonar. 1999. Occurrence of Grass Carp in the Lower Columbia and Snake Rivers.
Transactions of the American Fisheries Society 128:374-379.

MacMillan, J.R,  R. Reimschuessel, B.A. Dixon, GJ. Flick, and E.S. Garrett. 2002. Aquaculture
Effluents and Human Pathogens: A Negligible Impact. Contributed report by the Human Pathogens
and Aquaculture  Effluent Special Subgroup, submitted to the JSA Aquaculture Effluents Task Force,
January 2002,  8pp.


Massachusetts Office of Coastal Zone Management. 2001. Massachusetts Aquaculture White Paper -
Fish Consumption/Public Health and Safety, .
Accessed November 19,  2001.

McAllister, P.E. 1990. Fish Disease Leaflet 83: Viral Hemorrhagic Septicemia of Fishes. U.S. Fish
and Wildlife Service, National Fisheries Research Center - Leetown, National Fish Health Research
Laboratory. . Accessed March 2002.

Miller, A.I., and L.G Beckman. 1996. First Record of Predation on White Sturgeon Eggs by Sympatric
Fishes. Transactions of the American Fisheries Society 125:338-340.

Mosso, D. 2002,  May 13. Updated Model Parameters.  E-mail message to Lisa Chang of Environmental
Protection Agency, Washington, DC.

Mottram, B. 1996, October 23. Firm's Atlantic Salmon Loss NW Angler's Gain. The News Tribune,
Tacoma, WA.
                                             9-35

-------
Mottram, B. 1999, January 6. Groups Want to Stop Wild Atlantic Salmon/Environmentalists Concerned
about Effect on Native Salmon Species. The News Tribune, Tacoma, WA.

Murphy, S. 2000a. General Information on Nitrogen.  Boulder Area Sustainability Information
Network (BASIN). . Accessed
December 2001.

Murphy, S. 2000b. General Information on Solids. Boulder Area Sustainability Information Network
(BASIN). . Accessed December
2001.

Nash, C.E., ed. 2001. Technical Memorandum: The Net-Pen Salmon Farming Industry in the Pacific
Northwest. NMFS-NWFSC-49. U.S. Department of Commerce, National Oceanic and Atmospheric
Administration, 125 p.

Naylor, R.L., S.L. Williams, and D.R. Strong. 2001. Aquaculture - A Gateway for Exotic Species.
Science (294): 1655-1656. .

Nico, L. G, and J. D. Williams. 1996. Risk Assessment on Black Carp {Pisces: Cyprinidae). Final
Report to the Risk Assessment and Management Committee of the Aquatic Nuisance Species Task
Force. In United States Geological Survey, 2000. Nonindigenous Fishes - Mylopharyngodon piceus,
61 pp. U.S. Geological  Survey, Biological Resources Division, Gainesville, FL.
.  Accessed March 2002.

NSTC (National Science and Technology Council). 2000. Integrated Assessment ofHypoxia in the
Northern Gulf of Mexico. National Science and Technology Council, Committee on Environment and
Natural Resources, Washington, DC.

NOAA (National Oceanic and Atmospheric Administration). 1999.  The Environmental Impacts of
Aquaculture. A White Paper prepared by NOAA Marine Sanctuaries Division, National Ocean Service
and Office of Habitat Conservation, Northeast Region, National Marine Fisheries Service, July  1999, 29
pp.

Pennsylvania Department of Health. 2001. Press Release: Fish Consumption Advisory Not Needed for
PFBC Hatchery Trout. . Accessed
November 11, 2001.

Pennsylvania Fish and Boat Commission. 2001. Frequently Asked Questions about PCBs Found in
Trout at PFBC Fish Culture Stations, . Accessed November 11, 2001.

Pflieger, W. L. 1975. The Fishes of Missouri. In United States Geological Survey, 2001.
Nonindigenous Fishes - Ctenopharyngodon idella, 343 pp. Missouri Department of Conservation,
Jefferson City, MO. 
-------
accounts/cyprinid/ct_idell.html>. Accessed March 2002.

Quinn, J. M., R. J. Davies-Colley, C. W. Rickey, M. L. Vickers, and P. A. Ryan. 1992. Effects of Clay
Discharges on Streams 2: Benthic Invertebrates. Hydrobiologia 248:235-247.

Rappe, C., S. Bergek, H. Fiedler, and K. Cooper. 1998. PCDD and PCDF Contamination in Catfish Feed
from Arkansas. Chemosphere 36(13):2705-2720.

Redding, J.M., C.B. Schreck, and F.H. Everest. 1987. Physiological Effects on Coho Salmon and
Steelhead of Exposure to Suspended Solids.  Transactions American Fisheries Society 116:737-744.

Reichhardt, T. 2000.  Will Souped Up Salmon Sink or Swim. Nature, Volume 406: 10-12.

Richardson, M.J., F.G. Whoriskey, and L.H. Roy. 1995. Turbidity Generation and Biological Impacts of
an Exotic Fish Carassius auratus, Introduced into Shallow Seasonally Anoxic Ponds. Journal of Fish
Biology 47:576-585.

Rose, S. 1972. What about the White Amur? A Superfish or a Supercurse? Florida Naturalist
(Oct. 1972): 156-157. In United States Geological Survey, 2001. Nonindigenous Fishes -
Ctenopharyngodon idella.  .
Accessed March 2002.

Santerre, C.R, R. Ingram, G.W. Lewis, J.T. Davis, L.G Lane, RM. Grodner,  C.I. Wei, P.B. Bush, D.H.
Xu, J. Shelton, E.G. Alley, and J.M. Hinshaw. 2000. Organochlorines, Organophosphates, and Pyrethroids
in Channel Catfish, Rainbow Trout, and Red Swamp Crayfish from Aquaculture Facilities. Journal of
Food Science 65(2):231-234.

Schueler, T.R, and H.K. Holland. 2000.  The  Practice of Watershed Protection. Center for Watershed
Protection, Ellicott City, MD.

Schomack, D. and H.  Gray, 2002. Letter from Hon. Dennis Schomack, Chair, U.S. Section, International
Joint Commission, and The Rt. Hon. Herb Gray, PC, QC, Chair, Canadian Section, International Joint
Commission, to Honorable Colin Powell, Secretary of State, and The Honorable Bill Graham, Minister of
Foreign Affairs.  Letter dated July 5, 2002.

Scientific America. 2001. Farm-raised Fish  Come Clean.
. Accessed November 19, 2001.

Selong, J.H., and L.A. Helfrich. 1998. Impacts of Trout Culture Effluent on Water Quality and
Biotic Communities in Virginia Headwater Streams.  The Progressive Fish-Culturist 35(7):247-262.

Shireman, J. V., and C. R. Smith. 1983. Synopsis of Biological Data on the Grass Carp
Ctenopharyngodon idella. FAO Fisheries Synopsis No. 135. 86 pp. Food and Agriculture Organization of
the United Nations (FAO), Rome, Italy.


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 Strom, M.S., L.D. Rhodes, and L.W. Harrell. n.d. A Review of the Interactions between Hatchery and
 Wild Salmonids and Possible Spread of Infectious Disease. Fish Health/Microbiology Team,
 Integrative Fish Biology Program, Resource Enhancement and Utilization Technologies Division,
 Northwest Fisheries Science Center.

 Taylor, J. N., W. R. Courtenay, Jr., and J. A. McCann. 1984. Known Impact of Exotic Fishes in the
 Continental United States. In Distribution,  Biology, and Management of Exotic Fish, ed. W.R.
 Courtenay, Jr., and J.R. Stauffer, pp. 322-373. Johns Hopkins Press, Baltimore, MD.

 Terra Tech, Inc.  2001.  Aquatic Animal Production Industry Environmental Assessment Case Study
 Evaluation.  Tetra Tech, Inc., Fairfax, VA.

 UMN (University of Minnesota). 2000. A Field Guide to Aquatic Exotic Plants and Animals.
 University of Minnesota, Minnesota Sea Grant Program, . Accessed January 2002.

 University of Delaware. 1995. Exotic Species  Watch: News About Non-Native Aquatic Plants and
 Animals of Concern to Delaware. University of Delaware Sea Grant College Program.
 . Accessed March 2002.

 USDA (U.S. Department of Agriculture). 2002. Invasive Species: The Nation's Invasive Species
 Information System. U.S. Department of Agriculture, National Agricultural Library.
 . Accessed March 2002.

 USEPA (U.S. Environmental Protection Agency). 1997. Guidance Specifying Management Measures
for Sources of Nonpoint Pollution in Coastal Waters: Glossary. EPA-840-B-93-001c. U.S.
 Environmental Protection Agency, Washington, DC. . Accessed March 2002.

 USEPA (U.S. Environmental Protection Agency).  1998a. National Water Quality Inventory,
 Appendix A: Total Miles of Rivers and Streams in the Nation.  U.S. Environmental Protection Agency.
 .  Accessed February 2002.

 USEPA (U.S. Environmental  Protection Agency).  1998b. National Water Quality Inventory,
 Appendix B: Total Lake,  Reservoir, and Pond Acres in the Nation.  U.S. Environmental Protection
 Agency,  .  Accessed February 2002.

 USEPA (U.S. Environmental Protection Agency).  2000a. National Water Quality Inventory: 1998
 Report to Congress. EPA 841-R-00-001.  U.S. Environmental Protection Agency, Office of Water,
 Washington, DC. . Accessed December 2001.
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-------
USEPA.  (U.S. Environmental Protection Agency). 2000b. Water Quality Conditions in the United
States: A Profile from the 1998 National Water Quality Inventory Report to Congress. U.S.
Environmental Protection Agency.  EPA-841-F-00-006.
.  Accessed February 2002.

USEPA (U.S. Environmental Protection Agency). 2002a.  Response to Comments in Regard to
Authorization to Discharge Under the National Pollutant Discharge Elimination System. Prepared
by EPA-Region 1, Boston, MA. 64 pp.

USEPA (U.S. Environmental Protection Agency). 2002b.  Response to Public Comments on the
Proposed Issuance of the General National Pollutant Discharge Elimination System (NPDES)
Permit for Aquaculture Facilities in Idaho and Associated, On-site Fish Processors. Prepared by
EPA-Region 10, Seattle, WA.  20pp.

USFWS (U.S. Fish and Wildlife Service).  2002.  Black Carp Invasive Species Program. U.S. Fish and
Wildlife Service. . Accessed August 2002.

USGS (U.S. Geological Survey). 1999. Nonindigenous Fishes - Cyprinus carpio.  U.S. Geological
Survey, Nonindigenous Aquatic Species, . Accessed March 2002.

USGS (U.S. Geological Survey). 2000a. Nonindigenous Fishes - Mylopharyngodon piceus. U.S.
Geological Survey, Nonindigenous Aquatic Species, . Accessed March 2002.

USGS (U.S. Geological Survey). 2000b. Nonindigenous Fishes - Salmo salar.  U.S. Geological Survey,
Nonindigenous Aquatic Species, .  Accessed March 2002.

USGS (U.S. Geological Survey). 2001a. Asian Carp Invasion of the Upper Mississippi River System.
U.S. Geological Survey, Upper Midwest Environmental Sciences Center.
. Accessed March 2002.

USGS (U.S. Geological Survey). 2001b. Nonindigenous Fishes - Ctenopharyngodon idella. U.S.
Geological Survey, Nonindigenous Aquatic Species, . Accessed March 2002.
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Volpe, J.P., E.B. Taylor, D.W. Rimmer, and B.W. Glickman.  2000.  Evidence of Natural Reproduction
of Aquaculture-Escaped Atlantic Salmon in a Coastal British Columbia River.  Conservation Biology.
14(June):899-903.

Wetzel, R.G. 1983. Limnology. 2d ed. Saunders College Publishing, Philadelphia, PA. 767 pp. and
appendices.

The World Bank Group. 2001. Aquaculture. 
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                                       CHAPTER 10

         ENVIRONMENTAL BENEFITS OF PROPOSED REGULATION

10.1   INTRODUCTION

       EPA anticipates several environmental benefits of the proposed concentrated aquatic animal
production (CAAP) regulatory action.  These include improvements in water quality and, as a
consequence, increases in the recreational and non-use value of affected water bodies. The proposed
minimization of releases of non-native species  (through best management practices) is also anticipated to
better protect aquatic ecosystems and resources.  Finally, the proposed action is expected to reduce
releases of drugs and other chemicals, and aquatic animal pathogens, into the environment by requiring
facilities to develop and implement best management practice (BMP) plans.

       EPA has quantified and monetized a subset of the anticipated benefits of the  proposed action
listed above. The central basis for the quantitative benefits analysis is a water quality modeling
assessment that estimates water quality responses to the pollutant loading reductions under technology
options described earlier in this document.  Specifically, the benefits that EPA has been able to quantify
are (a) water quality improvements in stream reaches downstream of flow-through and recirculating
systems, and (b) improvements in the recreational use value of these same reaches.  Benefits that were
not quantified include water quality and ecological responses to pollutant loading reductions at net pen
systems and ecological and other water resource benefits from reductions in releases  of non-native
species, aquatic animal pathogens, and drugs and chemicals used at CAAP facilities.  EPA did not
quantify or monetize these potential benefits due to lack of readily available assessment modeling tools for
such an analysis. Thus, the estimated monetized benefits of the proposed action are based only on a
portion of the expected environmental benefits  of the proposed regulation.
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10.2    BENEFITS ENDPOINTS EVALUATED

        EPA considered several possible endpoints or metrics for characterizing the national
environmental benefits of the proposed regulation.  For receiving waters of representative CAAP
facilities, EPA considered comparing baseline and post-regulatory values for specific water quality
parameters for which national numeric or narrative criteria had been established (e.g., total nitrogen and
total phosphorus).  EPA also considered using a composite index of water quality which could, based upon
a national contingent valuation survey, be related to households' willingness-to-pay (WTP) for water
quality improvements.  Finally, EPA considered estimating responses of key biological variables (e.g.,
presence of pollution tolerant or intolerant species) to water quality changes induced by the regulation.
Each of these approaches require analysis of the effect of the proposed regulation on receiving waters of
CAAP facilities.

        Data limitations precluded detailed site-specific water quality studies for actual representative
CAAP facilities. Such analyses would be needed to develop accurate baseline water quality estimates for
representative CAAP facilities, which would in turn be preferable bases for benefits estimates. Instead,
EPA used a water quality model to simulate a range of potential water quality changes arising from the
regulation downstream of CAAP model facilities, using a range of assumed hypothetical background
conditions. EPA then used this range of simulated changes to determine a potential range of national
economic benefits from water quality improvements, using the composite water quality index and national
contingent valuation survey results. EPA also  included a qualitative discussion of potential changes in
downstream water quality and the impact of these  changes on stream impairment as judged by
comparison to water quality criteria.  These analyses are described in the following sections.
        10.2.1 Water Quality Standards and Nutrient Criteria

        Water quality criteria reflect the latest scientific knowledge on the effects of water pollutants on
public health and welfare, aquatic life, and recreation. These criteria guide states, territories, and
authorized tribes in developing water quality standards and ultimately provide a basis for controlling
discharges or releases of pollutants into our nation's waterways.  Ambient water quality criteria are based
solely on data and scientific judgments on the relationship between pollutant concentrations and the
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effects on aquatic life, human health, and the environment.  These criteria do not reflect consideration of
economic impacts or the technological feasibility of reducing chemical concentrations in ambient water
(USEPA, 2002a). Water quality criteria have been established for ammonia and dissolved oxygen. More
information about these criteria is provided in Appendix F.  Appendix F also includes information on BOD
and solids limits established for water quality protection purposes.

       Nutrient criteria represent nutrient levels that protect against the adverse effects of nutrient
overenrichment in aquatic environments.  The criteria are associated with preventing and assessing
eutrophic conditions.  Surface waters that meet nutrient criteria would have minimal impacts caused by
human activities (USEPA, 200 Ib). EPA has developed criteria for each of several ecoregions for total
phosphorus, total nitrogen, chlorophyll a, and turbidity. More information about these criteria is provided in
Appendix F.
        10.2.2 Water Quality for Recreational Use

        Improvements in water quality change the ways people can use water bodies.  Recreational use
of water is highly dependent on water quality.  The recreational use supported is also an indicator of other
benefits derived from the water body, such as use by public water authorities and aesthetic enjoyment.
Changes in the  recreational use supported by waterways associated with the CAAP regulatory options
forms the basis  for estimating monetized benefits of the proposal.

        Monetized benefits are based on incremental changes in the recreational use supported by water
bodies receiving CAAP facility flows.  Waters can be classified into a spectrum of permissible
recreational uses from beatable, which does not require the water to be suitable for body contact, to
swimmable, which requires the water to be nearly potable. A national contingent valuation survey has
related changes in water quality along this spectrum to households' willingness to pay (WTP) for water
quality improvements (Carson and Mitchell, 1993). EPA used this value, along with estimates of the
affected water area and population, to measure the benefits of improved water quality for recreational
uses.
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       Nutrient and solids loadings lead to biological and ecological impacts in the receiving waters.
These impacts were described in Chapter 9 of this document. EPA has not separately quantified potential
biological and ecological benefits arising from pollutant load reductions.  EPA may explore methods for
evaluating potential biological and ecological benefits from reduced CAAP pollutant loads for the final
regulation.
10.3    OTHER BENEFITS NOT QUANTIFIED

        There are several additional categories of potential environmental and economic benefits that
EPA has not quantified for the proposed CAAP rule. The following subsections describe these potential
areas. EPA believes that these unquantified benefits have the potential to be significant and may pursue
quantification of these benefits for the final rule.
        10.3.1  Water Quality Benefits from Net Pen Loadings Reductions

        EPA estimates that large salmon net pen facilities (i.e., with annual production greater than
500,000 Ib) discharge significant pollutant loadings into receiving waters, most frequently marine
embayments. For a large salmon facility with an annual production of 3.6 million pounds per year,
quantities of BOD5, total nitrogen, total phosphorus, and total suspended solids discharged annually to the
environment are 4,086,153; 350,242; 58,374, and 3,502,417 Ibs, respectively. For comparison, the annual
domestic wasteload of a city of about 65,800 individuals produces an equivalent annual load of BOD5. In
many cases, facilities may  be sited such that adequate flushing prevents water quality degradation in the
receiving water. EPA is aware of research that has examined environmental impacts of net pen
aquaculture (e.g., Strain et  al., 1995; Findlay et al., 1995), as well as recent regulatory activity to address
potential environmental concerns with net pen aquaculture (USEPA, 2002c). EPA estimates that under
the regulatory options set forth in the proposed CAAP regulation, substantial reductions in net pen
pollutant loadings would occur. However, EPA has not evaluated the water quality, biological, recreational
use, or other benefits from the loadings reductions anticipated under the proposed CAAP effluent
guideline.
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       10.3.2  Reductions in Escapements

       A reduction in the incidences of escapements may have the potential to have economic and
ecological benefits because of the large impacts that non-native aquatic species can have, as described in
Chapter 9. In addition, sources indicate that equipment-related failures, catastrophic events, and
accidents are major causes of escapements from marine aquaculture facilities (Ministry of Agriculture,
Food and Fisheries, n.d.). In the proposed CAAP regulation, EPA proposes to require BMPs to minimize
potential escapement of non-native species.  Although EPA expects reductions in escapements as a result
of this requirement, the Agency has not quantified potential environmental or economic benefits from
reductions in releases of non-native species from CAAP facilities. EPA may explore methods for
evaluating benefits for the final regulation.
       10.3.3 Reductions in Drugs and Other Chemicals

       EPA's proposed rule requires some regulated facilities develop and implement Best Management
Practices (BMP) plans which, among other elements, specifies that facilities' BMP plans must ensure the
storage of drugs and chemicals to avoid inadvertent spillage or release into the aquatic animal production
facility.  Moreover, EPA proposes to require that CAAP permittees comply with reporting requirements
under certain situations involving the use of extra-label and unapproved drugs and chemicals at the CAAP
facility.  EPA expects that implementation of these two provisions of the proposed rule will lead to
reductions in releases of drugs or chemicals that may have occurred as a result of inadvertent spillage or
release.  EPA has not quantified either baseline quantities of drugs and chemicals released to the
environment, or potential environmental or economic benefits that might arise from the proposed
requirements.  EPA may pursue a quantitative benefits analysis for the final regulation.
10.4   BENEFITS MODELING APPROACH

       At the time of the proposed rule, EPA focused on modeling CAAP industry impacts to streams
and rivers. This enables the quantification of water quality and recreational use benefits for flow-through
                                             10-5

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and recirculating facilities, which are primarily located on streams and rivers, but not for net pen systems
which are primarily located in embayments, reservoirs, and other non-riverine systems. Thus, some of the
potential benefits associated with the proposed regulation are not captured by this modeling approach.
The focus on developing a method for assessing impacts to streams and rivers was shaped by limited
availability of environmental and economic modeling tools and data required to quantify benefits other than
stream-based water quality and recreational use benefits.

        This preliminary focus is reasonable because the majority of CAAP facilities throughout the
nation discharge to streams and rivers. Based upon a preliminary analysis of NPDES permit data (data
not shown), approximately 87 percent of the facilities contribute to streams and rivers; 8 percent to
reservoirs and lakes; and 5 percent to estuaries, bays, and coastal areas. Moreover, among the water
bodies identified as "impaired" or included on states' Clean Water Act Section 303(d) and for which
CAAP is cited as one of the potential sources of impairment, rivers and streams are identified more
frequently than other water body types (see Chapter 9, section 9.2.3, of this document). Finally, CAAP
impacts on rivers and streams can be more completely assessed in a less complex manner (e.g., with a
one-dimensional water quality model) than for other water body types - an important consideration when
a large number of facility types and scenarios must be evaluated. Nevertheless, EPA believes that
environmental benefits from reduced pollutant loadings from net pen facilities may be significant and
intends to pursue methods for characterizing these benefits for the final rule.
        10.4.1 Water Quality Modeling and "Prototype" Case Study

        EPA applied the QUAL2E model to quantitatively assess the water quality-related impacts to
receiving stream waters from the proposed CAAP rule.  QUAL2E (Enhanced Stream Water Quality
Model) is a one-dimensional water quality model that allows both dynamic and steady state flow,
providing simulation of diurnal variations in temperature, algal photosynthesis, and respiration (Brown and
Barnwell, 1987). The basic equation in QUAL2E solves the advective-dispersive mass transport
equation. Water quality constituents simulated include conservative substances, temperature, bacteria,
BOD, DO, ammonia, nitrate and organic nitrogen, phosphate and organic phosphorus, and algae (Brown
and Barnwell, 1987).
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       Definition of "Prototype " Stream Hydrology and Hydraulics

       To model the impacts of CAAP facilities on receiving waters of flow-through and recirculating
systems, EPA developed a "prototype" case study using a range of background flow and water quality
conditions. Briefly, a set of model facilities, representing different species, effluent flow rates, and system
types (i.e., flow-through and recirculating) was used to reflect the characteristics of the potentially
regulated population of facilities.  The results of this "prototype" case study for this set of model facilities
were then extrapolated based on number of facilities of each type to form a national estimate of water
quality-based benefits of the proposed CAAP regulation.

       In order to develop the prototype case study, adequate facility location and water quality,
hydrology, and hydraulic characteristics for the relevant streams were required. At the time of proposal,
such data were available for the Central and Eastern Forested Uplands ecoregion.  Although case studies
should ideally be developed for all regions in which potentially regulated CAAP facilities are found,
sufficient data were not available  at time of proposal.  The results of the prototype case  study should
therefore be interpreted with caution.  The restricted geographic scope of the analysis is thought to be less
of a limitation for flow-through systems because most flow-through systems are located on upland
streams such as those used in the analysis described below.  EPA intends to explore enhanced
approaches to evaluating water quality benefits of CAAP regulation, including expanding the case study
approach to other regions in which CAAP facilities  are found.

       A stream network was developed for a typical system representative of those characteristics
most common in the Central and Eastern Forested Uplands ecoregion. Receiving water bodies in the
mountains of North Carolina were selected for survey, and the hydraulic and hydrology  attributes of those
streams in the region that receive CAAP discharges were analyzed. Sources of data utilized for this study
included streamflow data, land use data, RF1 stream coverages in GIS, NPDES permit information, and
gage data provided by USGS and the Better Assessment Science Integrating Point and Nonpoint Sources
(BASINS) modeling system (USEPA, 200la).

       To develop the streamflow characteristics of the prototype stream, the following procedure was
used. First, USGS streamflow gages located in the North Carolina mountains were reviewed. All CAAP
facilities identified in BASINS for the study area are located only on tributaries of the RF1 stream
                                             10-7

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coverage. Therefore, all USGS stream gages located on RF1 stream mainstems, or water bodies
receiving substantial flow from tributaries, were removed from the collection of gages under review.
Also, all streamgages located below lakes or dams were also removed from the review, since such
obstructions to the natural streamflow would affect results from the analysis. The set of remaining
streamgages was further reduced by removing those with certain flow criteria which were inconsistent
with those for streamgages associated with CAAP facilities in this region.  Of the remaining USGS
stream gages that met the defined criteria, 12 gages provided sufficient streamflow, depth,  and velocity
data to determine average depth and velocity verses flow relationships.  These relationships and resulting
regression equations were utilized in the QUAL2E model to simulate the characteristic hydraulic
conditions of the typical CAAP receiving waters in the study area:

                                depth = 0.524 x Flow0'1295
                                velocity = 0.39Ix Flow0'2212

where  depth  = stream depth (m)
       velocity = streamflow velocity (m/s)
       Flow = streamflow (mYs)

       Baseflow in the model stream is assumed to increase with  stream distance.  This function is the
driving force for much of the dispersion, settling, and dilution processes that control constituent
concentrations  and their respective longitudinal variations within the stream during low flow.  To estimate
the gradual increase in baseflow as a function of stream distance, a typical stream in the North Carolina
mountains was assessed in GIS using BASINS. The selected stream met the same flow criteria used in
the aforementioned hydraulic analysis. Contributing drainage areas were measured at varying locations
along the length of the stream, and a correlation was made between distance and size of watershed.
Assuming the size of the watershed is proportional to streamflow, a relation between distance
downstream and magnitude of flow could be estimated. The resulting equation was used to predict the
gradual increase in streamflow corresponding to the segmented distance  in the QUAL2E model.
                                 Flow(down)=Flow(up)x \.\6d
where Flow (down) = downstream flow (rrf/s)

                                             10-8

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       Flow (up) = upstream flow (m?/s)
       d = distance between upstream and downstream locations (km)

       Typical values that describe evaporation, temperature correction factors for model calculations,
biological processes, climatological influence, and decay and settling or water quality constituents were
selected from the literature and using professional judgment (Brown and Barnwell, 1987; Chapra, 1997;
Bowie et al., 1985). Parameters were selected based upon the assumed applicability to the study area.
Due to the lack of data for a specific site, and since the predictive capability of the QUAL2E model is not
to be descriptive of a single stream segment but rather a range of typical scenarios under varying
conditions, calibration of the QUAL2E model and the associated parameters (beyond inspection of results
for reasonableness according to professional judgment) was not performed for proposal. However, a
more thorough calibration and validation of the model can be provided once sufficient water quality data is
collected for a specific stream segment and facility discharge.
       Definition of Background Flow and Water Quality in the Prototype Receiving Water

       To account for differences in background concentrations in the model stream, "low" and "high"
background stream water quality scenarios were determined.  To estimate the "low" scenario
(representing relatively pristine water quality) water quality data was accessed from a typical upland
water quality gage maintained by the State of North Carolina (station C1370000).  This station is within a
primarily wooded tributary in the North Carolina mountains, and has no discharges or other obvious
influences within its vicinity that might influence water quality observations within the stream. As a result
of data analysis, the water quality concentrations shown in Table 10-1 were assumed.  Dissolved
phosphorus was assumed as 1 percent of total phosphorus observations and organic phosphorus was
assumed to be 75  percent of total phosphorus1.  Also, nitrate and nitrite concentrations were assumed to
constitute 95 percent and 5 percent, respectively, of the combined nitrate + nitrite observations at the
gage2. Concentrations for the "high" scenario, intended to represent relatively high background
1 This assumption was based on PCS and DMR monitoring data that show similar ratios.
2 This was also based on PCS and DMR monitoring data indicating similar ratios.

                                              10-9

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concentrations of pollutants, were developed based upon an analysis of water quality data from a sample
of stream gages in watersheds of North Carolina that encompass a variety of land uses and that are

associated with CAAP facilities (see Appendix G).


                                        Table 10-1

                         Model Stream Background Concentrations
Scenario
Low
High
BOD5
(mg/L)
0.4
3.86
TSS
(mg/L)
15
45
NH3
(mg/L)
0.04
0.28
Organic
N (mg/L)
0.15
0.57
NO2
(mg/L)
0.02
0.05
NO3
(mg/L)
0.4
0.78
Dissolved
P (mg/L)
0.001
0.159
Organic P
(mg/L)
0.003
0.013
DO
(mg/L)
6.63
6.63
       The background concentrations shown in Table 10-1 were modeled with steady state stream

flows of both 15 cfs and 30 cfs to represent a range of summer flow conditions in the hypothetical stream.

The modeled combinations are described in Table 10-2. These flows were chosen to represent a range of

summer low-flow conditions on the "prototype" stream.
                                         Table 10-2
                Background Flow/Hydrology Scenarios Used in the Modeling
                           Background Water Quality 1
                                     "Low"
                                   Background Water Quality 2
                                  	"High"	
   Background Flow 1
Flow= 15 cfs
BOD5 = 0.4 mg/L
TSS =15 mg/L
NH3 = 0.04 mg/L
Organic N = 0.15 mg/L
NO2 = 0.02 mg/L
NO3 = 0.4 mg/L
Dissolved? = 0.001 mg/L
Organic P = 0.003 mg/L
DO = 6.63 mg/L	
Flow = 15 cfs
BOD5 = 3.86 mg/L
TSS = 45 mg/L
NH3 = 0.28 mg/L
Organic N = 0.57 mg/L
NO2 = 0.05 mg/L
NO3 = 0.78 mg/L
Dissolved? = 0.159 mg/L
Organic P = 0.013 mg/L
DO = 6.63 mg/L	
                                           10-10

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                            Background Water Quality 1
                                       "Low"
                                     Background Water Quality 2
                                    	"High"	
   Background Flow 2
Flow = 30 cfs
BOD5  = 0.4 mg/L
TSS = 15mg/L
NH3 = 0.04 mg/L
Organic N = 0.15 mg/L
NO2 = 0.02 mg/L
NO3 = 0.4 mg/L
Dissolved? = 0.001 mg/L
Organic P = 0.003 mg/L
DO = 6.63  mg/L
Flow = 30 cfs
BOD5  = 3.86 mg/L
TSS = 45 mg/L
NH3 = 0.28 mg/L
Organic N = 0.57 mg/L
NO2 = 0.05 mg/L
NO3 = 0.78 mg/L
Dissolved? = 0.159 mg/L
Organic? = 0.013 mg/L
DO = 6.63 mg/L
       Definition of Pollutant Loading Scenarios

       For each regulatory option, EPA estimates the pollution reduction from operating and maintaining
specific techniques and practices.  EPA traditionally develops pollution loads that are either facility-
specific or specific to a "model" facility, described below.  Facility-specific compliance loads require
detailed information about many, if not all, facilities in the industry. These data typically include
production, capacity, water use, wastewater generation, waste management operations, monitoring data,
geographic location, financial conditions, and any other industry-specific data that may be required for the
analyses. EPA then uses each facility's information to estimate the loads or impact associated with new
pollution controls.

       When facility-specific data are not available, EPA  develops model facilities to provide a
reasonable representation of the industry.  Model facilities are developed to reflect the different
characteristics found in the industry, such as the size or capacity of an operation, type of operation,
geographic location, mode of operation, and type of waste management operations. These models are
based on data gathered during site visits, information provided by industry members and their associations,
and other available information.  EPA estimates the number of facilities that are represented by each
model. Pollutant loads and their impacts are estimated for  each model facility. The model facility
approach was chosen for estimating compliance pollutant loads, impacts, and associated benefits for the
CAAP industry.
                                             10-11

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       EPA developed three technology-based options (Options 1, 2, and 3) and estimated pollutant
loadings under each of these Options using an engineering model. The CAAP engineering model
estimates loadings for different facility systems (e.g., flow-through or recirculating), species (e.g., trout,
tilapia, or hybrid striped bass), and sizes under these technology Options.  Option 1 and Option 2 are
grouped for this case study because they estimate the same pollutant loadings (Option 2 adds a health
management plan, but does not reduce the loadings estimated with Option 1). Option 3 adds solids
polishing to reduce effluent loadings further.

       EPA evaluated treatment-in-place at surveyed facilities and determined that the majority have in
place all or most of the technology and practices that would be required by the lowest technology Option.
However, to estimate the benefits of the regulation for the few facilities that have no treatment in place,
EPA also estimated loadings in the absence of treatment ("Raw effluent").  Again, the loadings included
under "Raw effluent" estimates are wastes generated in an CAAP system based on feed inputs, which
were acquired from literature reviews. Only a minority of CAAP facilities lack some form of treatment.
The majority of CAAP facilities employ some form of effluent treatment. The pollutant reductions
estimated with Option I/Option 2, and Option 3 were taken from literature reviews and sampling data.  A
wastewater treatment model was then used to obtain treatment efficiencies for the reductions, which are
expressed in loads. The loadings were converted to concentrations to accommodate the requirements of
the QUAL2E model. The conversion equations for flow-through and recirculating systems, along with
example calculations for both, are described in Appendix H.

       Three pollutant concentrations scenarios (Raw, Option  I/Option 2, and Option 3) were each
modeled for different species types and facility production sizes (medium and large). Table 10-3
summarizes the effluent concentrations modeled for each model facility, by option and facility type.  The
effluent flow for each of the model facility types is summarized in Table 10-4, along with a summary of
the total number of facilities for each facility type. Several scenarios of the model CAAP discharge and
stream were simulated using a low-flow, steady state procedure in the QUAL2E model framework.  The
stream was divided into 3 segments, each consisting of 20 computational elements for iterative water
quality calculations. The values in Tables 10-1, 10-2, 10-3, and 10-4 were combined to create a variety of
scenarios of effluent flows and concentrations and background  stream flows and concentrations.
                                             10-12

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                                          Table 10-3
                 Modeled Untreated and Treated Effluent Concentrations for
                           Flow-Through and Recirculating Systems

Raw effluent
(Flow-
Through)
Opt I/Opt 2
(Flow-
Through)
Opt3
(Flow-
Through)
Raw effluent
(Recirculating)
Opt I/Opt 2
(Recirculating)
Opt3
(Recirculating)
BOD5
(mg/L)
11.172
2.876
1.773
1,838.66
1,537.10
768.56
TSS
(mg/L)
9.576
5.453
4.985
1,576.0C
237.98
95.19
NH3
(mg/L)
0.010
0.010
0.009
1.58
0.73
0.36
Organic
N
(mg/L)
0.014
0.014
0.014
2.36
1.09
0.54
NO2
(mg/L)
0.001
0.001
0.001
0.20
0.09
0.05
NO3
(mg/L)
0.023
0.023
0.022
3.77
1.74
0.87
Dissolved
P (mg/L)
0.056
0.056
0.056
11.37
9.22
9.22
Organic
P (mg/L)
0.053
0.050
0.047
8.67
7.02
3.51
DO
(mg/L)
5.0
5.0
5.0
5.0
5.0
5.0
       Example Water Quality Modeling Output

       Water quality modeling output were generated for the 30-km "prototype" downstream reach for
each model facility (listed in Table 10-4) under the 4 different background water quality and flow scenario
described earlier in this section. Pre- and post-regulatory dissolved oxygen, BOD, TSS, and nutrient
concentrations were simulated. Figure 10-1 presents an example of simulated BOD downstream of a
medium-sized Trout Stackers Flow-Through model facility. For this example, background (receiving
water) flow is assumed to be 30 cfs and background water quality is assumed to be relatively pristine
("low" scenario  in Table 10-2). Output similar to this for all model facility species/size combinations listed
in Table 10-4, for all four different background water quality and flow scenarios (Table 10-2), and for the
parameters BOD, TSS, and DO, were generated..  These ouput were considered in a discussion (Section
10.5.1) of potential contributions of facility effluents to stream impairment, expressed as possible
exceedences of  water quality criteria values. These output were also used as inputs to the monetized
benefits calculation described in Section  10.5.2.
                                             10-13

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                                    Table 10-4


                                   Effluent Flows
Facility Type
Salmon Flow-through
Striped Bass Flow-through
Tilapia Flow-through
Trout Flow-through
Trout Stackers Flow-through
Striped Bass Recirculating
Tilapia Recirculating
Facility Size
Medium
Large
Medium
Large
Medium
Large
Medium
Large
Medium
Large
Large
Large
Effluent Flow
(ft3/s)
-
92.7
2.7
-
6.02
22.28
4.7
47.2
4.9
20.7
0.1
0.05
(m3/s)
-
2.6
0.0
-
0.2
0.5
0.1
1.3
0.1
0.6
0.003
0.001
                                    Figure 10-1

Example QUAL2E output for simulated BOD concentrations downstream of a medium trout

                stockers flow-through facility on the "prototype" stream
    2.5
 o>
 Q
 O
 m
                   Raw effluent
    0.5
                           Option 1
                      Option 3
                            10         15         20        25


                             Distance downstream of facility (km)
30
35
                                       10-14

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        10.4.2 Extrapolation to National-Scale Impacts

        For the national monetized benefits calculation, it was necessary to extrapolate monetized benefits
that were obtained from the "prototype" water quality modeling results for each model facility, described
in Section 10.4.1, to all flow-through and recirculating systems nationwide that fall under the scope of the
proposed regulation. Information on the total number of facilities for each facility type, derived from the
AAP screener survey described earlier in this document and from USDA's Census of Aquaculture
(USDA, 2000), were used to perform this extrapolation. The calculation of monetized benefits arising
from water quality improvements at each model facility, and the extrapolation to a national benefits
estimate, are described in Section 10.5.2.
10.5    ESTIMATED WATER QUALITY BENEFITS

        10.5.1 Water Quality Standards and Nutrient Criteria

        EPA briefly reviewed the results of the QUAL2E "prototype" case study analyses for individual
model facilities, described in Section 10.4.1 to gain some insight as to whether CAAP facilities could
potentially contribute to water quality criteria exceedences and whether the proposed controls could
reduce these exceedences.  The results suggested that the modeled flow-through and recirculating
systems may, under certain background receiving water conditions, contribute to water quality
impairments in receiving waters.  EPA compared simulated stream water quality in the receiving waters
(such as the output shown in Figure 10-1) with national ambient water quality standards that have been
established for the protection of aquatic life.  Results (Hochheimer and Mosso, 2002) from these initial
evaluations show that nutrients, such as total phosphorus (TP), added to streams from CAAP facilities
can lead to changes in the observed impairment (as measured by changes in impaired stream length) for
different background water quality scenarios.  For example, the length of impaired stream ranged from
3.5 to 12.5 km for untreated wastes from model CAAP facilities located on the simulated stream reach.
When the regulatory scenarios were imposed on the model facilities, the length of impaired stream was
reduced by 0.5 to 2.5 km in  smaller facilities and up to 4.5 km in larger facilities.

                                              10-15

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        For other parameters (dissolved oxygen, total nitrogen (TN), and ammonia), the simulated model
CAAP facility discharges did not cause impairments relative to the criteria chosen, even when
discharging "raw" effluent. This was a common result when a facility with relatively small effluent
volumes or pollutant concentrations was assumed to be located on a stream with relatively high
background pollutant concentrations and higher flow rate.

        Modeling results such as these may be useful for EPA in evaluating water quality changes arising
from the proposed CAAP rule in streams and rivers in the context of national (or other) water quality
criteria. However, EPA recognized several limitations with the initial case study analysis approach for
evaluating water quality standards and nutrient criteria. Presently, there is not an efficient methodology to
assign a monetary value to reductions in nutrients for receiving waters. Furthermore, EPA has  not
considered water quality effects when multiple facilities discharge to the same receiving waters.  In
addition, the models were not calibrated with site-specific data, which are needed to provide accurate
absolute values of modeled baseline and post-regulatory water quality, and therefore the results  may be
more  amenable for analyses that are less sensitive to baseline conditions. Consequently, EPA primarily
used the model results for evaluating and monetizing recreational benefits, described in the following
section, which require changes in the water quality variables. EPA intends to continue to refine this
modeling approach for wider, national application. EPA also intends to create additional model stream
case studies to reflect  a wider range of stream conditions to better simulate "real world" scenarios.
        10.5.2 Recreational Use Benefits

        The facility modeling described above also provided estimates of changes in water quality
measures in terms of stream lengths.  These measures, BOD, DO, and TSS, are also indicators of the
type of recreation which may be permitted in the waters. That is, they locate the water body in the
spectrum of uses from beatable to swimmable described in Section 10.2.2. If the proposed regulation
improves these measures, then more demanding uses may be safely enjoyed and the value of the water
body to society increases. With the information from the facility models, estimates of how society values
changes in recreational use, and estimates of the population affected, it is possible to place a monetary
value on the changes anticipated from the regulation. The method is discussed in some detail below.
                                              10-16

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        Each use category can be defined in terms of a set of water quality indicators. In past benefits
assessments, categories were defined discretely so that if all of the indicator measures exceeded all of the
criteria for a given use, then the water body could be used for that use.  Vaughan (1986) developed a
water quality criteria ladder that describes criteria for four types of recreational use (none, boating,
fishing,  or swimming).  For example, a water body with a biological oxygen demand (BOD) between 3
and 4 mg/1 is suitable for boating and fishing but not for swimming. All of the indicators must achieve the
proscribed level for the water body to support a given level of use. Thus, if the water body had a fecal
coliform count greater than 2,000 per 100 ml, even though its BOD was between 3 and 4 mg/1, it would be
classified as not beatable because of the high coliform count.   With the discrete water quality ladder, the
overall use category is the least demanding use supported by any of the water quality indicators.

        Once the use of the water body is defined by the Vaughan ladder, the public willingness to pay
for changes in use  category can be  estimated.  Carson and Mitchell (1986) conducted a national
contingent valuation survey which sought households' willingness to pay for improvements in the quality
of the nation's waters in terms  of a use ladder. This survey characterized households' annual willingness
to pay for improvements in freshwater resources from their baseline conditions to fishable and swimmable
conditions. The survey sought values for discrete changes from one use category to another which
corresponded with the Vaughan water quality ladder.

        Several regulatory impact analyses have operationalized the Vaughan/Carson  and Mitchell
approach to estimate the value  of benefits from proposed regulations.  When the proposed regulation
causes a reach to change category, the household annual willingness to pay from the Carson and Mitchell
study is applied to  estimate the benefits of the change. Carson and Mitchell (1993) also established that
families value water quality changes in their own region more highly than generic national improvements.
In past benefit assessments, EPA has attributed two-thirds  of the willingness to pay value to households
within the state and one-third to households elsewhere. As specific information about where facilities are
located was not available at this time, EPA treated all of the benefits estimated in this assessment as
being distant from individual households.  Thus, only one-third of the Carson and Mitchell willingness to
pay amount is applied.  As the Carson and Mitchell willingness to pay refers to improvement in ALL of
the nation's waters, the benefits are also scaled by the proportion that the length of streams improved in
                                              10-17

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the model facilities analysis is to the total length of all streams in the U.S.  These assumptions greatly
reduce the level of benefits estimated for this proposed rule.

       A Continuous Measure of Benefits

       One criticism of the water quality ladder approach is that a rule is only credited with a benefit
when it results in a change from one category to another. Thus, even if a regulation causes significant
improvements in water quality, if it does not result in a change in use, no benefits are attributed to it.
When a marginal change in water quality measures results in a change in use category, large benefits are
ascribed to it. This critique is unimportant for major rules affecting many point sources of pollution.  It is
more significant for rules affecting non-point sources where the diffuse nature of the contaminant makes
it unlikely a single rule will shift use categories for many reaches.  There has been considerable debate
about how to measure benefits continuously in the non-point emissions context.

       As an alternative to the stepwise ladder approach, EPA has adopted a change in a single unified
index as an indicator of water quality improvement for valuation for this proposed regulation.  The Water
Quality Index (WQI) combines information from four water quality measures rather than using only the
limiting lowest quality criterion to define use category. For this benefit valuation, the model facilities
analysis generated estimates of changes in BOD, dissolved oxygen, and TSS. Fecal coliforms were
assumed to be unaffected by the proposed rule. These estimates were converted into a WQI  based on
work by McClelland (1974).  McClelland developed a method whereby water quality indicators are
converted from whatever units are appropriate for the indicator, e.g., mg/1, NTU, to a single index of
water quality valued from zero to 100. One hundred indicates excellent water quality in terms of that
particular measure.  The conversion equations for each measure are of different, non-linear functional
forms and segmented so they cannot be expressed in simple equations. EPA has developed spreadsheet
functions which accomplish the conversion (Miles, 2002, personal communication).  Once all of the
indicators are in the same index units, they can be combined into a single index of overall water quality.
This combined WQI is a geometrically weighted average of its four components, such that

                           WQI= DOI0333  FEC0314 BOD0216 TSS° 137+ 0.5
                                              10-18

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Where DOI, FEC, BOD, and TSS are water quality indexes for dissolved oxygen, fecal coliforms,
biological oxygen demand, and total suspended solids.  The weighting exponents were derived by
McClelland (1974) using a Delphi approach among water quality experts.

       EPA developed a simple method to map the WQI onto the Vaughan water quality ladder in the
Meat Products Industry Economic Analysis (USEPA, 2002b). The same method was used to translate
changes in combined WQI into changes in water use for this assessment. The mapping is based on the
observed combined WQI calculated for all stream reaches in the RF3 database. Each reach is classified
as to use category so the average WQI for each use category in the baseline file can be calculated.
Assuming WQI values are normally distributed within each use category, placing the upper bound for the
category at the mean plus one standard deviation should ensure that 84 percent of observations will fall
below the upper bound. Tests with the baseline data indicated that this method of assigning values by
WQI tends to assign a lower value than other mapping approaches. Table 10-5 shows the lower threshold
WQI for each category. A more detailed description of the mapping and testing is in the Meat Products
Industry Economic Analysis (USEPA, 2002b).

                                          Table 10-5
                                      Criteria and Values
Use Category
No Use
Boatable
Fishable
Swimmable
Lower Threshold
(WQI)
—
79.0
94.4
99.0
Household Annual
WTPa
($ 1999)
—
$245
$429
$634
Rate, R
($/WQI, 1999)
$ 3.10
$ 11.91
$ 44.92
—
Source:        EPA Meat Products Industry Economic Analysis; WTP values from USEPA, 2001b,
               CAFOs Economic Analysis.
3Total annual willingness to pay for upgrading all U.S. freshwater bodies from baseline quality to the next
designated use category, i.e. annual WTP is $634 to move all sub-swimmable waters to use category 3,
swimmable.
       The Carson and Mitchell willingness to pay values were updated to 1999 values for the recent
Concentrated Animal Feeding Operations (CAFOs) regulation benefit assessment to account for changes
                                             10-19

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in income and the value of the dollar. The CAFOs assessment, however, valued only changes in use
categories. The continuous WQI method requires that the Carson and Mitchell willingness to pay values
be converted to continuous measures of benefits. This rate of change for each use category is calculated
so that the total willingness to pay at each breakpoint is equal to the total in the Carson and Mitchell study
and shown in Table 10-5.  The "no use" category is arbitrarily spread over the whole range from 0 to 79.1
No value is associated with improvements above the swimmable level, which is a very small range. With
each step, the rate of increase in benefits is roughly four times higher than the previous step.

        Thus the average household would be willing to pay $3.10 for a one point change in WQI from 50
to 51 in all of the nation's rivers, i.e. an improvement in water quality within the "no use" category.  The
same household would be willing to pay $11.91 for a one point change in WQI from 83 to 84 in all of the
nation's rivers, i.e. an improvement in water quality within the beatable category.  Changes that cross
category boundaries are valued at the rate for each portion of the categories included. Table 10-6
illustrates  the WQI values and changes for the medium size trout stacker flow-through facility, discharging
into a stream with high water quality, E.G.  1, and low flow, 15 cfs.  The change in WQI for km 29.0
shows the non-linearity of the valuation method.  The three point  change from a baseline value of 76 to
the Option I/Option 2  value of 79 is valued at $9.30, three times $3.10 the per point value for changes in
the non-usable category. The four point change from 76 to 80 for Option 3 is valued at $21.21, three
times $3.10 plus $11.91, since the fourth point is in the  more valued beatable category.  Clearly, the larger
values occur in reaches with better water quality.

        Each set of WQI values represents the conditions in a 0.5 km reach of the model stream. Thus,
the total of the WTP values is the average value per household for that level of change in all of the
nation's waters in terms of half kilometers.  The bottom of Table  10-6 illustrates the calculation from
WQI to benefit value.  To place the value on a kilometer basis the total is divided by two. This total
value for the model stream was scaled up by the number of facilities identified as similar to the model
facility. There were 57 facilities judged to be similar to the medium flow-through trout stacker model
facility. This value must then be weighted by the proportion of the nation's waters represented by the
'Mitchell and Carson described non-boatable waters in graphic terms so their value for the change may be
an overestimate. However, few water bodies approach a zero WQI, so much less than the full value for
the improvement from not usable to beatable can ever be attributed to the regulation.
                                              10-20

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                                       Table 10-6
                    Example of Application of Water Quality Index Use
Trout Stackers, Flow-through Facility, Medium Size,

Km
30
29.5
29.0
28.5
28.0
27.5
27.0
26.5
26.0
25.5
25.0
24.5
24.0
23.5
23.0
22.5
22.0
21.5
21.0
20.5
20.0
19.5
19.0
18.5
18.0
17.5
17.0
16.5

8.5
8.0
7.5

3.5
3.0
2.5

Total
Baseline
80
75
76
77
78
79
80
80
81
81
81
82
82
82
83
83
83
83
83
84
84
84
83
83
83
83
83
84

84
83
83

83
83
84


Total/2
lumber of facilities of model
Total km of streams in U.S.
3ut-of-Locality factor
Total Households in U.S.
Receiving waters flow 1 5 cfs,
High water quality, i.e., E.G. 1
Water Quality Index (WQI)
Option '/2 Option 3
80
78
79
80
81
81
82
82
83
83
83
83
83
84
84
84
84
84
84
84
84
84
84
84
84
84
84
84
No change Km 16.0-9.0
84
84
83
No change Km 8. 0-4.0
83
84
84
No change Km 2. 0-0.0


type



80
79
80
81
81
82
82
82
83
83
83
83
84
84
84
84
84
84
84
84
85
84
84
84
84
84
84
84

84
84
83

83
84
84


Willingness to Pay
Option '/2
-
9.30
9.30
18.11
26.92
23.82
23.82
23.82
23.82
23.82
23.82
11.91
11.91
23.82
11.91
11.91
11.91
11.91
11.91
-
-
-
11.91
11.91
11.91
11.91
11.91
-

_
11.91
-

_
11.91
-

$397.11
$198.55
x57 11318
71,067,019 0.0106
xO.33 0.0035
x 103,874,000 $363,584

for Change
Option 3
-
12.40
21.21
30.02
26.92
35.73
23.82
23.82
23.82
23.82
23.82
11.91
23.82
23.82
11.91
11.91
11.91
11.91
11.91
-
11.91
-
11.91
11.91
11.91
11.91
11.91
-

_
11.91
-

_
11.91
-

$459.76
$229.88
13103
0.0123
0.0041
$420,944
Source: EPA Analysis
                                         10-21

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length of the prototype stream improved in the model analysis. EPA assumed that each reach is valued
equally and divided the total value by the total number of stream kilometers in the nation.

       Carson and Mitchell found that households placed a greater value on changes in water quality
close to home where they were likely to have access to and use the water resource. As specific
information on the location of each facility is not available at this time, EPA could not identify the number
of households that would consider each facility as local.  As a conservative assumption, EPA assumed
that all of the reaches would be considered non-local and so receive only one third of the total WTP. In
the trout stacker example, this process resulted in an estimated benefit value per household of 0.35 cents
and 0.41 cents for Option I/Option 2 and 3, respectively. EPA scaled this value up by the number of
households in the country in 1999, 103.9 million (U.S. Census Bureau, 2000), to yield national benefits for
this class of facility. The values derived for all classes of facilities in this way were then summed to yield
a national estimate of benefits.

       The Mitchell-Carson WTP values represent annual household values in 1999 dollars. EPA has no
intuition as to the timing of these benefits and no dynamic modeling was undertaken to suggest variation in
benefits through time. Thus, the estimate of total benefits represents a typical year once the proposed
regulation is in place.  When the same discount rate is used to calculate both the present value and
annualized value of a stream of equal flows through time, the annual flow is  the same as the annualized
value.  So, the total benefits stated may be considered an annualized value for any time period and any
discount rate (unless different discount rates are to be used for the present value and annualization
calculations).

       As discussed in Section 10.4, each facility model was run with two flow regimes,  15 and 30 cfs,
and two ambient quality levels  in the receiving waters. This resulted in four  different benefit estimates
for each model facility under each option. The largest benefits occurred when CAAP facility outflow
was a substantial portion of the total stream flow and when the regulation resulted in substantial
improvement in the quality of the outflow.  The maximum among the four estimates was considered the
high end of the range of benefits and the minimum was considered the low end of the range.  Each model
                                              10-22

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facility type was considered separately and all of the minima and maxima summed to yield the national
range of benefits in 1999 dollars.1

        Benefit Valuation Results

        As discussed above, data was only available at this time to estimate benefits of flow-through and
recirculating systems.  Table 10-7 shows the overall benefits if Option I/Option 2 and 3 are applied to all
of the facilities in the current database.  Eleven facilities do not achieve Option I/Option 2 standards.2
Implementing the Option I/Option 2 BMPs for these facilities would improve water quality in their
receiving streams and generate a benefit of $16,000 to $77,000.  Implementing Option 3 for all facilities
includes upgrading those facilities not up to Option I/Option 2 standards and installing solids polishing at 13
large facilities.  It would generate benefits of $34,000 to $207,000. Table 10-7 shows the benefits that
could be achieved if the standards of Option 3 were applied to all medium and large facilities.

        The proposed option, however, applies Option I/Option 2 standards to medium sized facilities
while requiring Option 3 BMPs for large facilities. Table 10-8 shows how the benefits of the two options
are combined to generate a total benefit estimate for the Proposed Option. The Option I/Option 2 and
Option 3 columns in Table 10-8 show only those benefit values which will be realized under the
proposed option.  Thus, all of the medium sized facilities show no benefits from Option 3 since this option
will not apply to them and all of the large facilities show no benefits for Option I/Option 2 since they will
meet Option 3 standards.
1 Different elements of the development of the regulation have required re-statement of the results in
various constant dollar base years.  The 1999 constant dollar results are shown above to maintain the
direct connection with the CAFO and Meat Products documentation.  Results may be re-stated in any
base year using the consumer price index for all urban consumers (CPI-U).
2 The database contains 100 facilities. Thirteen (13) are large, and 87 medium sized.  One large and 10
medium sized facilities do not use Option I/Option 2 BMPs.  So, 77 medium sized facilities in the database
already comply with Optionl/Option2  in the baseline and will not generate any additional benefits as a
result of the proposed rule.  The 13 large and 10 non-compliant medium facilities are the basis for this
assessment.
                                              10-23

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                                             Table 10-7
            National Benefits from CAAP Facility Regulatory Options when Applied to All Facilities
                         (Annualized difference from baseline; 2000 constant dollars)
Subcategory
Flow-Through
Recirculating
Total
Annual Production
Level (Ibs)
100,000 to 475,000
>475,000
100,000 to 475,000
>475,000

Option 1
Minimum
$12,249
$4,117
$0
$0
$16,367
Maximum
$66,188
$10,984
$0
$0
$77,172
Option 3
Minimum
$24,242
$6,897
$0
$3,242
$34,381
Maximum
$160,430
$25,400
$0
$21,564
$207,394
Note: Entries may not sum due to rounding.
Source: EPA Analysis
                                             Table 10-8
                               National Benefits from the Proposed Option
                         (Annualized difference from baseline; 2000 constant dollars)
Subcategory
Flow-Through
Recirculating
Total
Annual
Production
Level (Ibs)
100,000 to
475,000
>475,000
100,000 to
475,000
>475,000

Option 1
Min.
$12,249
$0
$0
$0
$12,249
Max,
$66,188
$0
$0
$0
$66,188
Option 3
Min.
$0
$6,897
$0
$3,242
$10,139
Max,
$0
$25,400
$0
$21,564
$46,964
Proposed
Min.
$12,249
$6,897
$0
$3,242
$22,389
Max.
$66,188
$25,400
$0
$21,564
$113,152
Note: Entries may not sum due to rounding.
Source: EPA Analysis
The annualized national monetized benefits for the change from baseline to the post-regulatory condition
for the proposed option are estimated to range from $22,000 to $113,000 (2000 dollars). Almost half of
the benefits are attributable to the medium sized trout stacker flow-through facility model that
encompasses 7 of the 23 facilities included in this assessment.
                                                10-24

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       The Carson and Mitchell survey question requested an overall value so the total willingness to pay
based on their survey results may be considered to include aesthetic and non-use values, as well as
recreational and other use values.
10.6   UNQUANTIFIED BENEFITS

       EPA has quantified and monetized a subset of the anticipated benefits of today's proposed action
as described in this chapter. In summary, the central basis for the quantitative benefits analysis is a water
quality modeling assessment that estimates water quality responses to the pollutant loading reductions
under technology options described earlier in this document.  Specifically, the benefits that EPA has only
been able to quantify and monetize are improvements in the recreational use value of these same reaches.

       Several potential benefits associated with the proposed regulation were not quantified.  These
include water quality and ecological responses to pollutant loading reductions at net pen systems; and
ecological and other water resource benefits from reductions in releases of non-native species,  aquatic
animal pathogens, and drugs and chemicals used at CAAP facilities.  EPA did not quantify or monetize
these important benefits due to lack of assessment modeling tools readily available for such an analysis.
For these reasons, as well as for the assumptions that were made in the benefits monetization calculations
due to lack of data on facility locations (see section 10.5.2), the estimated monetized benefits of the
proposed regulatory action are believed to represent a lower bound of potential benefits of the proposed
regulation.
10.7   REFERENCES
Bowie, G.L., W.B. Mills, D.B. Porcella, C.L. Campbell, J.R. Pagenkopf, G.L. Rupp, K.M. Johnson,
P.W.H. Chan, and S.A. Gherini. 1985. Rates, Constants, and Kinetics Formulations in Surface Water
Quality Modeling. 2d ed. EPA-600-3-85-040. Environmental Research Laboratory, Athens, GA.

Brown, L.C., and T.O. Barnwell, Jr. 1987. The Enhanced Stream Water Quality Models QUAL2E and
QUAL2E-UNCAS: Documentation and User Manual. EPA 600-3-87-007. U.S. Environmental
Protection Agency, Office of Water, Washington, DC.
                                             10-25

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Carson, R.T. and R.C. Mitchell. 1986. The Use of Contingent Valuation Data for Benefit/Cost
Analysis in Water Pollution Control, Final Report. Resources for the Future, Washington, DC.

Carson, R T. and R.C. Mitchell. 1993. The Value of Clean Water: The Public's Willingness to Pay for
Beatable, Fishable, and Swimmable Quality Water.  Water Resources Research 29(July):2445-2454.

Chapra, S.C. 1997. Surface  Water Quality Modeling. McGraw-Hill, NY.

Findlay, R.H., Watling, L., and L.M. Mayer, 1995. Environmental Impact of Salmon Net-Pen Culture on
Marine Benthic Communities in Maine: A Case Study.  Estuaries 18(1A): 145-179.

Hochheimer, J. and D. Mosso.  2002. Technical Memorandum: Revised North Carolina Prototype Facility
Case Study. Tetra Tech Inc., Fairfax, VA.

McClelland, N. I. 1974.  Water Quality Index Application in the Kansas River Basin.  Prepared for U.
S. Environmental Protection Agency -Region VII.

Miles,  A., Center for Environmental Analysis, Research Triangle Institute. Personal Communication April
8, 2002.

Ministry of Agriculture, Food and Fisheries. n.d. Summary of Marine Escape Reports: 1989-2000.
Government of British  Columbia. .
Accessed April 19, 2002.

Strain,  P.M., D.J. Wildish, and P.A Yeats. 1995.  The Application of Simple Models of Nutrient Loading
and Oxygen Demand to the Management of a Marine Tidal Inlet. Marine Pollution Bulletin
30(4):253-261.

U.S. Census Bureau. 2000. Statistical Abstract of the U.S.: 2000.
. Accessed June 17, 2002.

USDA (U.S. Department of Agriculture). 2000. 1998 Census ofAquaculture. U.S. Department of
Agriculture, National Agriculture Statistical Services, Washington, DC.

USEPA (U.S. Environmental Protection Agency). 200 la. Better Assessment Science Integrating point
andNonpoint Sources: BASINS  Version 3.0 User's Manual,. EPA 823-H-01-001. U.S. Environmental
Protection Agency, Washington, DC.

USEPA (U.S. Environmental Protection Agency). 2001b. Environmental and Economic Benefit
Analysis of Proposed Revisions to the National Pollutant Discharge Elimination System Regulation
and the Effluent Guidelines for Concentrated Animal Feeding Operations. EPA-821-R-01-002.
                                            10-26

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Chapter 4, Modeling of Improvements in Surface Water Quality and Benefits of Achieving Recreational
Use levels. U.S. Environmental Protection Agency, Office of Water, Washington, DC. January 2001.

USEPA (U.S. Environmental Protection Agency). 2002a. Ammonia Fact Sheet: 1999 Update. U.S.
Environmental Protection Agency, Office of Water, Washington, DC.
.  Accessed April 2002.

USEPA (U.S. Environmental Protection Agency). 2002b. Economic Analysis of Proposed Effluent
Guidelines for the Meat and Poultry Products Industry.  EPA-821-B-01-006. Chapter 7,
Environmental Benefits. U.S. Environmental Protection Agency, Office of Water, Washington, DC.
February 2002.

USEPA (U.S. Environmental Protection Agency). 2002c. National Pollutant Discharge Elimination
System Permit no. ME0036234, issued to Acadia Aquaculture, Inc. Signed February 21, 2002.

Vaughan, W. J. 1986. The RFF Water Quality Ladder, Appendix B in Robert Cameron Mitchell and
Richard T. Carson, The Use of Contingent Valuation Data for Benefit/Cost Analysis in Water
Pollution  Control, Final Report. Resources for the Future, Washington, DC.
                                            10-27

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                                       CHAPTER 11
                        COST-BENEFIT COMPARISON AND
               UNFUNDED MANDATES REFORM ACT ANALYSIS
11.1   COST-BENEFIT COMPARISON

       Table 11-1 summarizes the social costs and benefits of the proposed rule.  The estimated pre-tax
annualized compliance cost is $1.51 million in 2000 dollars for the proposed rule (see Table 6-5).  All of
the CAAP facilities in the proposed scope currently permitted, so incremental administrative costs of the
regulation are expected to be negligible. However, Federal and State permitting authorities will incur a
burden for tasks such as reviewing and certifying the BMP plan and reports on the use of drugs and
chemicals.  EPA estimated these costs at approximately $10,011 for the three-year period covered by  the
information collection request (EPA, 2002, Table 9) or roughly $3,337 per year. That is, the
recordkeeping and reporting burden to the permitting authorities is less than two-tenths of one percent  of
the pre-tax compliance cost for the proposed rule. The costs are shown using both a 7 percent discount
rate and a 3 percent discount rate in Table 11-1.

       The monetized benefits are based on the Carson and Mitchell (1993)  contingent valuation
estimates of an annual willingness to pay.  Hence, the total willingness to pay derived from those values is
an annual amount.  The model facility approach did not provide any intuition about the timing of
compliance or the  dynamics of when benefits would accrue, so the benefit analysis is based on the
environmental effects achieved when the proposed regulation is fully implemented.  There is no variation
through time.  The annualized value of a level annual flow is equal to the annual flow itself, when the rate
for discounting and annualization are the same.  Thus, the annualized benefits are the same as the annual
benefits no matter what discount rate is applied. The estimated quantified and monetized benefits of the
rule range from $0.022 million to $0.113 million. These values are likely to be underestimates because
EPA can fully characterize only a limited set of benefits to the point of monetization.  Section 10.6 in this
report describes several types of benefits—those that can be both quantified and monetized; those that
can be quantified but not monetized; and those that cannot be quantified or monetized.
                                             11-1

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                                         Table 11-1
           Estimated Pre-Tax Annualized Compliance Costs and Monetized Benefits
Production System
Flow-through
Recirculating
Net Pen
Industry Total

State and Federal
Permitting Authorities
Estimated cost of the
proposed rule
Number of
Regulated
CAAPs
181
21
20
222



Pre-tax Annualized
Cost (Millions, 2000
dollars)
Discount Rate
7%
$1.31
$0.11
$0.09
$1.51

$0.003
$1.513
3%
$1.20
$0.11
$0.08
$1.39

$0.003
$1.393
Annualized
Monetized Benefits*
(Millions, 2000 dollars)
Min
$0.019
$0.003
—
$0.022


$0.022
Max
$0.091
$0.022
—
$0.113


$0.113
^Monetized benefits are not scaled to the national level.
       The monetized benefits are based on the 128 flow-through and recirculating systems from the
screener data (i.e., are not scaled to the national level) because EPA was not able to estimate a
representative national scaling factor.  Hence, Table 11-1 compares annualized compliance costs
associated with 222 facilities to annualized benefits from 128 facilities.
11.2    UNFUNDED MANDATES REFORM ACT ANALYSIS

       11.2.1 Background

       Title II of the Unfunded Mandates Reform Act of 1995 (Public Law 104-4; UMRA) establishes
requirements for Federal agencies to assess the effects of their regulatory actions on State, local, and
                                             11-2

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tribal governments as well as on the private sector.  Under Section 202(a)(l) of UMRA, EPA must
generally prepare a written statement, including a cost-benefit analysis, for proposed and final regulations
that "includes any Federal mandate that may result in the expenditure by State, local, and tribal
governments, in the aggregate or by the private sector" in excess of $100 million per year.1  As a general
matter, a federal mandate includes Federal Regulations that impose enforceable duties on State, local, and
tribal governments, or on the private sector (Katzen, 1995).  Significant regulatory actions require Office
of Management and Budget review and the preparation of a Regulatory Impact Assessment that
compares the costs and benefits of the action.

        State and tribal government facilities are within the scope of the regulated community for the
proposed aquatic animal production industry effluent limitations guidelines, see Chapter 2. EPA has
determined that this rule would not contain a Federal mandate that may result in expenditures of $100
million or more for State, local, and tribal governments, in the aggregate, or the private sector in any one
year. The total annual cost of this rule is estimated to be $1.5 million.  Thus, the proposed rule is not
subject to the requirements of Sections 202 and 205 of the UMRA. The facilities which are affected by
the proposed rule are direct dischargers engaged in concentrated aquatic animal production.  These
facilities would be subject to the proposed requirements through the issuance or renewal of an NPDES
permit either from the Federal EPA or authorized State governments.  These facilities should already
have NPDES permits as the Clean Water Act requires a permit be held by any point source  discharger
before that facility may discharge wastewater pollutants into surface  waters.  Therefore, the proposed
rule could require these permits to be revised to comply with revised Federal standards, but should not
require a new permit program be implemented.

        EPA has determined that this rule contains no  regulatory requirements that might significantly or
uniquely affect small governments.  EPA is not proposing to establish pretreatment standards for this point
source category which are applied to indirect dischargers and overseen by Control Authorities. Local
governments are frequently  the pretreatment Control Authority but since this regulation proposes no
pretreatment standards, there would be no impact imposed on local governments. EPA proposed
requirements are not expected to impact any tribal governments, either as producers or because facilities
   1 The $100 million in annual costs is the same threshold that identifies a "significant regulatory action"
in Executive Order 12866.
                                               11-3

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are located on tribal lands. Thus, the proposed rule is not subject to the requirements of section 203 of
UMRA.


       EPA, however, is responsive to all required provisions of UMRA. In particular, the Economic
Analysis (EA) addresses:


       •      Section 202(a)(l)—authorizing legislation (Section 1 and the preamble to the rule);

       •      Section 202(a)(2)—a qualitative and quantitative assessment of the anticipated costs and
               benefits of the regulation, including administration costs to state and local governments
               (Sections 6 and 9 as well as this Chapter);

       •      Section 202(a)(3)(A)—accurate estimates of future compliance costs (as reasonably
               feasible; Section 6);

       •      Section 202(a)(3)(B)—disproportionate effects on particular regions, local communities,
               or segments of the private sector. EPA identified no disproportionate impacts as a result
               of the proposed rule (Chapter 7);

       •      Section 202(a)(4)—effects on the national economy. Due to the small cost associated
               with the proposed rule (less than $2 million), EPA anticipates no discernable effects on
               the national economy.

       •      Section 205(a)—least burdensome option or explanation required (this Chapter).


The preamble to the Rule summarizes the extent of EPA's consultation with stakeholders including
industry,  environmental groups,  states, and local governments (UMRA, sections 202(a)(5) and 204).
        11.2.2 Potential Impacts on Non-Commercial Facilities


        EPA identified 142 non-commercial flow-through facilities including Federal, State, Tribal, and
Academic/Research facilities, see Table 7-1.  As mentioned in Section 5.13, EPA imputed revenues for

non-commercial facilities based on the market value of production.  Under the proposed rule: seven
facilities show an impact at a 3 percent revenue test threshold; one facility shows an impact at a 5 percent

revenue test threshold; and no facilities show impacts under a 10 percent revenue test threshold.
                                               11-4

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       11.2.3  Summary

       Pursuant to section 205(a)(l)-(2), EPA has selected the "least costly, most cost-effective or least
burdensome alternative" consistent with the requirements of the Clean Water Act (CWA) for the reasons
discussed in the preamble to the rule. EPA is required under the CWA (section 304, Best Available
Technology Economically Achievable (BAT)) to set effluent limitations guidelines and standards based on
BAT considering factors listed in the CWA such as age of equipment and facilities involved, and
processes employed.  EPA is also required under the CWA (section 306, New Source Performance
Standards (NSPS)) to set effluent limitations guidelines and standards based on Best Available
Demonstrated Technology.  The preamble to the proposed rule and Chapter 8 review EPA's steps to
mitigate any adverse impacts of the rule. EPA determined that the rule constitutes the least burdensome
alternative consistent with the CWA.
11.3   REFERENCE

Carson, R. T. and R.C. Mitchell. 1993. The Value of Clean Water: The Public's Willingness to Pay for
Beatable, Fishable, and Swimmable Quality Water.  Water Resources Research 29(7 July):2445-2454.
EPA. 2002.  Environmental Protection Agency. Information Collection Request: Concentrated Aquatic
Animal Production Effluent Guidelines Proposed Rule.  Draft June 27.
Katzen. 1995. Guidance for implementing Title II of S.I., Memorandum for the Heads of Executive
Departments and Agencies from Sally Katzen, Ad, OIRA. March 31, 1995.
                                             11-5

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            APPENDIX A




INDUSTRY PROFILE SUPPORTING TABLES
                A-l

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                                       Table A-l
                              U.S. Fish and Wildlife Facilities
Abernathy Salmon Culture  Technology
Center
Alchesay  -  Williams  Creek  NFH
Complex*
Allegheny NFH*
Bears Bluff NFH
Bozeman FTC*
Carson NFH
Chattahoochee Forest NFH*
Coleman NFH
Craig Brook NFH
Creston NFH*
Dale Hollow NFH*
Dexter NFH &TC
Dworshak NFH*
Eagle Creek NFH
Edenton NFH
Ennis NFH*
Entiat NFH
Erwin NFH*
Garrison Dam NFH*
Gavins Point NFH*
Genoa NFH*
Green Lake NFH*
Greers Ferry NFH*
Hagerman NFH
Harrison Lake NFH
Hiawatha Forest NFH
Hotchkiss NFH*
Inks Dam NFH*
Iron River NFH*
Jackson NFH*
Jones Hole NFH*
Jordan River NFH*
KooskiaNFH
Lahontan NFH*
Lamar FTC
Leadville NFH*
Leavenworth NFH
Little White Salmon - Willard NFH
Livingston Stone NFH
Makah NFH
Mammoth Spring NFH*
Mescalero NFH*
Nashua NFH*
Natchitoches NFH
Neosho NFH
Norfork NFH*
North Attleboro NFH*
Orangeburg NFH
Ouray NFH
Pendills Creek NFH*
Pittsford NFH*
Quilcene NFH
QuinaultNFH
Richard Cronin NSS
San Marcos NFH & TC
Saratoga NFH
Spring Creek NFH
Tishomingo NFH
Uvalde NFH
Valley City NFH
Warm Springs NFH - Region 1
Warm Springs NFH -Region 4*
WelakaNFH
White River NFH*
White Sulphur Springs NFH
Willard NFH
Willow Beach NFH*
Winthrop NFH
Wolf Creek NFH*
Source: FWS, 2000a through 2000c
NFH: National Fish Hatchery
NTC: National Fish Technology Center
*: also listed as receiving fish or fish eggs from other FWS hatcheries.
                                         A-2

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                                          Table A-2
                                 Warmwater State Hatcheries
State
Description
Annual Distributions
IA         Total of 6 hatcheries
           Spirit Lake (SL): walleye, muskellunge
           Rathbun (R): channel catfish, walleye, saugeye,
           largemouth bass
           Fairport (F): largemouth bass, bluegill, northern
           pike, walleyes, saugeyes, channel catfish, white
           amur
                                                 Walleye: 60-70 million fry (SL),
                                                 35 million fry (R); 60,000
                                                 fingerlings (R)
                                                 Muskellunge: (SL)
                                                 Catfish: 500,000 (R)
                                                 Saugeye: 5 million fry (R)
                                                 Bass: 15,000 fingerlings (R)
ID         Total of 22 hatcheries*
           Kootenai, Sandpoint, Clark Fork, Cabinet George,
           Mullan, Clearwater, Rapid River, Oxbow, Me Call,
           Pahisimeroi, Sawtooth, Henrys Lake, Mackay,
           Ashton, Eagle, Nampa, Haysur, Hagerman, Niagara
           Springs, American Falls, Grace, Magic Valley
                                                 Together produce 23 million fish*
IN         Total of 8 hatcheries*
           Avoca, Cikana, Driftwood, East Fork, Fawn River,
           Mixsawbah, Bodine
KN        Total of 4 hatcheries
           Milford (M): walleye, sauger, saugeye wiper, striped
           bass fry, channel and blue catfish fingerlings, paddle
           intermediates.
           Pratt (P):  walleye, wiper, sauger, saugeye,
           largemouth bass, channel catfish, bluegill.
           Meade (Me): largemouth bass, redear sunfish,
           smallmouth bass, grass carp.
           Farlington (F): striped bass, channel catfish, blue
           catfish, wipers, walleye, saugeye, bluegill, redear
           sunfish, grass carp.
                                                 Walleye: 55-65 million fry (M)
                                                 Blue Catfish: 50,000 (M)
                                                 Channel Catfish: 500,000 (M)
KS        Total of 2 hatcheries *
           Minor Clark, Frankfurt
LA
Booker Fowler
Fish Stocking in LA
Florida Largemouth Bass:
4,869,758
Channel Catfish: 127,759
Blue Catfish: 42,933
Flathead Catfish: 15,561
Bluegill/Redear Sunfish: 217,532
Paddlefish: 533,379
                                             A-3

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Table A-2 (cont.)
State
MA
MI
MN
MO
MT
NC
ND
NE
NH
Description
Total of 5 hatcheries*
Roger Reed: northern pike
Total of 6 hatcheries*
Harrietta, Wolf Lake
Walleye: 17 spawning stations, 15 hatcheries (9 of
which also hatch sucker eggs, 5 of which also hatch
OO "
muskellunge eggs), 300 rearing ponds.
Muskellunge: 7 spawning stations, 50 rearing ponds.
Sucker (to feed muskellunge): 7 spawning stations.
Lost Valley Fish Hatchery (40% complete) will
produce largemouth bass, walleye, muskellunge,
hybrid striped bass, catfish, paddlefish, bluegill,
hybrid sunfish.
1 hatchery*
Giant Springs
Total of 3 hatcheries*
Armstrong, Marion, Table Rock
1 hatchery*
Valley City
Total of 5 hatcheries
Valentine: largemouth bass, bluegill, black crappie,
channel catfish, tiger musky
Calamus: walleye, hybrid bass, trout. Also planned:
yellow perch, largemouth bass, bluegill, hybrid
muskie
North Platte: walleye, northern pike, channel catfish
Total of 6 hatcheries*
Berlin, Twin Mountain, Warren, New Hampton,
Powder Mill, Milford
Annual Distributions


325 million fish*
Capacity of 15 million fish per year
1.3 million fish


Valentine:
northern pike - 3 million eggs
walleye - 60 million eggs
yellow perch - 5 million eggs
largemouth bass - 300,000
bluegill - 1 million
black crappie - 50,000
channel catfish - 18,000
tiger musky - 7,000

      A-4

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                                      Table A-2 (cont.)
State
Description
Annual Distributions
NJ         2 hatcheries
           Charles O. Hayword (Hackettstown): channel
           catfish, walleye, muskellunge, northen pike, tiger
           muskie, largemouth and smallmouth bass, hybrid
           striped bass
                                                 500,000 to 1 million*
NM       Total of 6 hatcheries*
           Seven Springs, Glenwood, RockLake
NY        Total of 12 hatcheries*
           Chautauqua: muskellunge, walleye
           Oneida: walleye, lake sturgeon
           South Otselic: walleye, tiger muskellunge
                                                 Together produce 1 million pounds
                                                 offish*
OH        7 hatcheries*
           Senecaville (S): walleye, saugeye, striped bass,
           hybrid striped bass, channel catfish
           St. Mary's: saugeye, channel catfish, yellow perch.
           Broodstock of largemouth bass.
           Hebron, Kincaid, London, Put-in-Bay
                                                 S: 3 - 5 million fish
OK        Total of 4 hatcheries*
           Durant, Holdenville, Byron, J.A.Manning
                                                 Together produce 25 million fish*
OR
1 facility*
SC        Total of 7 hatcheries*
           Dennis Wildlife Center: striped bass
           Springs Stevens, Glenmore Shirey, Barnwell
           Cohen Campbell, Cheraw, Walhalla
SD        Total of 3 hatcheries*
           Blue Dog Lake (B): northen pike, walleye, yellow
           perch, largemouth & smallmouth bass, bluegill and
           crappie
                                                 B: >70 million
TX        15 hatcheries*
           Dindee, Possum Kingdom, Jasper, Texas
           Freshwater, Brownsville, GCCA Center, Palacios,
           Perry Bass, Port O'Connor, Rockport, Sabine,
           Seabrook, Sea Center, A.E.Wood, Heart of the Hills
                                            A-5

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                                        Table A-2 (cont.)
 State
Description
Annual Distributions
 UT
Total of 10 hatcheries*
J. Perry Egan, Mammoth Creek, Fountain Green,
Mantua, Glenwood, Midway, Kamas, Springville,
Loa, Whiterocks
 VA
Total of 9 hatcheries*
Vic Thomas: striped bass
King & Queen: walleye, channel catfish, American
shad, redar, bluegill
Duller: muskellunge, smallmouth bass, walleye
Front Royal: muskellunge, northen pike, walleye
Together produce 3 to 5 million
 VT
Total of 5 hatcheries*
Bald Hill, Bennington, Roxbury, Salisbury, Ed
Weed
 WI
Total of 14 facilities*
Art Oehmecke: muskellunge, walleye, and suckers
Gov. Tommy G. Thompson: muskellunge, walleye,
northern pike, suckers
Lake Mills: northern pike, and walleye
Wild Rose: muskellunge, suckers, northern pike,
walleye and lake sturgeon.	
* Uncertain whether warm water or cold water facility and/or distribution amount.
Source: State Websites, 2000.
                                              A-6

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                              Table A-3
Universities with Fisheries/Fishing/Fish and Game Management Departments
Name
University of Alaska, Fairbanks
Sheldon Jackson College
Auburn University
University of Arkansas at Pine Bluff
University of Arizona
Humboldt State University
University of California Davis
College of the Redwoods
Fullerton College
Modesto Junior College
Colorado State University
Delaware State University
University of Florida
Florida Institute of Technology
University of Georgia
Oceanic Institute
Iowa State University
North Idaho College
University of Idaho
College of Southern Idaho
Lake Land College
Ball State University
Kansas State University
Pittsburg State University
Kentucky State University
Murray State University
Louisiana State University and Agricultural and
Mechanical College
Massachusetts Maritime Academy
University of Massacusetts
Frostburg State University
University of Maine
Unity College
University of Michigan
Michigan State University
Town
Fairbanks
Sitka
Auburn
Pine Bluff
Tuscon
Arcata
Davis
Eureka
Fullerton
Modesto
Fort Collins
Dover
Gainesville
Melbourne
Athens

Ames
Cour d Aloie
Moscow
Twin Falls
Mattoon
Muncie
Manhatten
Pittsburg
Frankfort
Murray
Baton Rouge
Buzzards Bay
Amherst
Frostburg
Augusta
Unity
Ann Arbor
East Lansing
State
AK
AK
AL
AR
AZ
CA
CA
CA
CA
CA
CO
DE
FL
FL
GA
HI
IA
ID
ID
ID
IL
IN
KS
KS
KY
KY
LA
MA
MA
MD
ME
ME
MI
MI
                                 A-7

-------
Table A-3 (cont.)
Name
Mid Michigan Community College
Northern Michigan University
Lake Superior State University
Vermilion Community College
University of Minnesota Twin Cities
East Central College
Mississippi Gulf Coast Community College-
Jefferson Davis Campus
Mississippi State University
Mississippi Gulf Coast Community College-
Perkinston
Miles Community College
Haywood Community College
North Carolina State University
Brunswick Community College
North Dakota State University
University of North Dakota
Minot State University-Bottineau Campus
University of Nebraska- Lincoln
Rutgers, The State University of New Jersey, Cook
College
New Mexico State University
State University of New York College of
Agriculture and Technology at Cobleskill
Cornell University
State University of New York College of
Agriculture and Technology at Morrisville
State University of New York College of
Environmental Science and Forestry
Ohio State University- Columbus Campus
Hocking Technical College
Central Oregon Community College
Oregon State University
Mount Hood Community College
Mansfield University of Pennsylvania
Penn State University
University of Rhode Island
Town
Harrison
Marquette
Sault St. Marie
Ely
Minneapolis-St.
Paul
Union
Gulfport
Mississippi State
Perkinston
Miles City
Clyde
Raleigh
Supply
Fargo
Grand Forks
Minot
Lincoln
Piscataway
Las Cruces
Cobleskill
Ithaca
Morrisville
Syracuse
Columbus
Nelsonville
Bend
Corrallis
Gresham
Mansfield
University Park
Kingston
State
MI
MI
MI
MN
MN
MO
MS
MS
MS
MT
NC
NC
NC
ND
ND
ND
NE
NJ
NM
NY
NY
NY
NY
OH
OH
OR
OR
OR
PA
PA
RI
      A-8

-------
                                Table A-3 (cont.)
Name
Clemson University
South Dakota State University
Tennessee Technological University
Lincoln Memorial University
University of Tennessee
Texas A & M University
Texas A & M University- Galveston
Texas Tech University
Stephen F. Austin University
Virginia Polytechnic and State University
University of Vermont
Peninsula College
University of Washington
Northland College
Bluefield State College
West Virginia University
University of Wyoming
Town
Clemson
Brookings
Cookeville
Harrogate
Knoxville
College Station
Galveston
Lubbock
Nacogdoches
Blacksburg
Burlington
Port Angeles
Seattle
Ashland
Bluefield
Morgantown
Laramie
State
SC
SD
TN
TN
TN
TX
TX
TX
TX
VA
VT
WA
WA
WI
WV
WV
WY
Sources: Barren's, 2001; The College Board, 2000; and University Websites, 2001.
                                      A-9

-------
             Table A-4
List of Aquariums in the United States
Vame
\qua Zoo
Jerkshire Museum Aquarium
'ape Cod Aquarium




bid Spring Harbor Fish Hatchery & Aquarium
julf of Maine Aquarium
Tie Maritime Aquarium at Norwalk
Vlystic Marinelife Aquarium
sfew England Aquarium
sfew Jersey State Aquarium
view York Aquarium






)cean Alliance / Whale Conservation Institute
•viewport Aquarium
Tennessee Aquarium
"learwater Marine Aquarium
Fhe Florida Aquarium
Vliami Seaquarium
\laska SeaLife Center
Vlaui Ocean Center
)regon Coast Aquarium
'ort Defiance Zoo & Aquarium
Fhe Seattle Aquarium
Vaikiki Aquarium
Tie Whale Museum
Colorado's Ocean Journey
Jelle Island Zoo and Aquarium
jreat Lakes Aquarium
ihedd Aquarium
















it. Lawrence Aquarium and Ecological Center
\quarium of the Americas
)allas World Aquarium
)auphin Island Sea Lab
Vlarine Life Oceanarium
Texas State Aquarium
National Aquarium in Baltimore






Tie North Carolina Aquarium on Roanoke Island
Tie North Carolina Aquarium at Pine Knoll Shores
City
Alexandria Bay
Pittsfield
Brewster




Cold Spring Harbor
Portland
Norwalk
Mystic
Boston
Camden
Brooklyn
Lincoln
Newport
Chattanooga
Clearwater










Tampa / St. Petersburg
Miami
Seward
Wailuku, Maui
Newport
Tacoma
Seattle
Honolulu, Oahu
Friday Harbor
Denver
Detroit
Deluth
Chicago
Massena
New Orleans
Dallas
Dauphin Island
Gulfport
Corpus Christi
Baltimore
Manteo
Atlantic Beach





















State
NY
MA
MA
NY
ME
CT
CT
MA
NJ
NY
MA
KY
TN
FL
FL
FL
AK
HI
OR
WA
WA
HI
WA
CO
MI
MN
IL
NY
LA
TX
AL
MS
TX
MD
NC
NC
               A-10

-------
                                       Table A-4 (cont.)
Vame

Hie North Carolina Aquarium at Fort Fisher
South Carolina Aquarium
Virginia Marine Science Museum
3irch Aquarium at Scripps
Dabrillo Marine Aquarium
^ong Beach Aquarium of the Pacific
VIonterey Bay Aquarium
Roundhouse Marine Lab and Aquarium
iteinhart Aquarium
Jnderwater World
Columbus Zoo and Aquarium
'ittsburgh Zoo and Aquarium
lipley's Aquarium












san Antnnin 7nn1nairn1 frnrrlRnQ nnH Arpiariiim
City
Fort Fisher
Charleston
Virginia Beach
La Jolla
San Pedro
Long Beach
Monterey Park
Manhattan Beach
San Francisco
San Francisco
Powell
Pittsburgh
Orlando
Ssnn Antnnin















State
NC
sc
VA
CA
CA
CA
CA
CA
CA
CA
OH
PA
FL
TY
Source: http://www.whaleofagoodtime.com
                                            A-ll

-------
           Table A-5
1999 Federal Fish Egg Distribution

Species Name
^A
\pache Trout
\tlantic Salmon
3rook Trout
3rown Trout
3ull Trout
Channel Catfish
3hum Salmon
3oho Salmon
Colorado
iquawfish
Cutthroat Trout
7all Chinook
Salmon
^ake Trout
^andlocked Atlantic
Salmon
Northern Pike
lainbow Trout
lazorback Sucker
Sauger
Saugeye
ihortnose Sturgeon
Total Number
of Eggs
252,540
557,310
10,574,831
266,000
3,639,131
115,133
2,043,195
217,465
1,350,500
90,000
410,834
4,102,941
15,432,196
357,136
3,414,000
37,940,493
129,580
1,375,000
4,716,000
8.000
Percent of
Distribution
0%
0%
7%
0%
2%
0%
1%
0%
1%
0%
0%
3%
11%
0%
2%
26%
0%
1%
3%
0%
Agency Controlling Receiving Water or Facility
NA
252,540














4,244,935




Bureau of Indian
Affairs




416,713





234,700




727,555




Corps of
Engineers




















Indian Tribal
(Non-BIA)








900,000


1,948,000



548,784




International


859,345




217,465
450,000











Local
Government


300








1,200



145,089




National
Biological
Service












154,445


69,888




              A-12

-------
Table A-5 (cont.)

Species Name
Splake
Spring Chinook
Salmon
Steelhead
Walleye
fellow Perch

Total

Total Number
of Eggs
285,800
680,316
2,703,105
52,960,000
2,750,000

146,371,506

Percent of
Distribution
0%
0%
2%
36%
2%



Agency Controlling Receiving Water or Facility
NA






4,497,475

Bureau of Indian
Affairs






1,378,968

Corps of
Engineers



1,440,00
0


1,440,00
0

Indian Tribal
(Non-BIA)






3,396,784

International






1,526,810

Local
Government






146,589

National
Biological
Service






224,333

      A-13

-------
Table A-5 (cont.)

Species Name
vfA
\pache Trout
Atlantic Salmon
Brook Trout
Brown Trout
Bull Trout
Channel Catfish
^hum Salmon
^oho Salmon
Colorado Squawfish
Cutthroat Trout
7all Chinook
salmon
^ake Trout
^andlocked Atlantic
salmon
Northern Pike
lainbow Trout
lazorback Sucker
sauger
saugeye
shortnose Sturgeon
splake
spring Chinook
salmon
steelhead
Total
Number of
Eggs
252,540
557,310
10,574,831
266,000
3,639,131
115,133
2,043,195
217,465
1,350,500
90,000
410,834
4,102,941
15,432,196
357,136
3,414,000
37,940,493
129,580
1,375,000
4,716,000
8,000
285,800
680,316
2,703,105
Percent of
Distribution
2%
5%
100%
3%
34%
1%
19%
2%
13%
1%
4%
39%
146%
3%
32%
359%
1%
13%
45%
0%
3%
6%
26%
Agency Controlling Receiving Water or Facility
National
Fish
Hatchery























Private















12,868






15,500
State Fish
Hatchery


















520,000




State
Government


2,512,959
61,000
1,462,525
10,046
1,596,595

500

176,134
2,136,000
374,211


13,771,573

1,062,500
4,196,000

285,800
392,570
2,687,605
Tennessee
Valley
Authority















1,200







U.S. Fish &
Wildlife
Service

557,310
7,202,227
205,000
1,734,273
59,212
446,600


60,000


14,903,540
357,136
3,414,000
17,795,714
102,600


8,000

243,057

U.S.
Geological
Survey




25,620




30,000

17,741



530,998
26,980




44,689

University





45,87f









91,88$

312,50C





      A-14

-------
                                                           Table A-5 (cont.)

Species Name
Valleye
fellow Perch

Total
Total
Number of
Eggs
52,960,000
2,750,000

146,371,506
Percent of
Distribution
501%
26%

100%
Agency Controlling Receiving Water or Facility
National
Fish
Hatchery
1,200,000


1,200,000
Private



28,368
State Fish
Hatchery
5,240,000


5,760,000
State
Government
45,080,000


75,806,018
Tennessee
Valley
Authority



1,200
U.S. Fish &
Wildlife
Service

2,750,000

49,838,669
U.S.
Geological
Survey



676,028
University



450,264
Source: FWS, 2000.
                                                                 A-15

-------
         Table A-6
1999 Federal Fish Distribution

Species Name
American Shad
Apache Trout
Arctic Grayling
Atlantic
Salmon
Atlantic
Sturgeon
Beautiful
Shiner
Black Bullhead
Black Crappie
Bluegill
Bonytail
Brook Trout
Brown Trout
Cape Fear
Shiner
Channel
Catfish
Chihuahua
Chub
Chum Salmon
Coho Salmon
Colorado
Squawfish
Cutthroat Trout
Desert Pupfish
Fall Chinook
Salmon
Total
Fish
Weight
1
31,483
14
173,210
33
2
9
1,405
3,684
6,318
12,588
78,698
3
77,722
14
8,353
425,534
79
140,169
2
339,921
Percent
of
Distrib
ution
0%
1%
0%
3%
0%
0%
0%
0%
0%
0%
0%
1%
0%
1%
0%
0%
8%
0%
3%
0%
6%
Agency Controlling Receiving Water or Facility
NA





















Air
Force







2
2

1,265
1,498






5,402


Army








32

200
801

12,059




1,391


Bureau of
Indian
Affairs








59

205







5,661


Bureau
of Land
Manage
ment





















Bureau
of
Reclama
tion









2,802



1,542




45,087

14
Corps of
Engi-
neers







935


5,591
34,352

2,217




36,011

2,544
DOJ





















EPA





















Forest
Service








8


668

1




2,974


Inter
jurisdictional
waters



21,280

















Indian
Tribal

30,928








2,278
13,451

29,670


27,778

17,882

3,756
Inter-
national
1


132,223











8,353
247,615



292,578
            A-16

-------
Table A-6 (cont.)

Species Name
Fathead
Minnow
Gila
Topminnow
Gila Trout
Kokanee
Lahontan
Cutthroat Trout
Lake Sturgeon
Lake Trout
Landlocked
Atlantic
Salmon
Largemouth
Bass
Late Fall
Chinook
Salmon
Leon Springs
Pupfish
Northern Pike
Paddlefish
Pallid Sturgeon
Rainbow Trout
Razorback
Sucker
Redbreast
Sunfish
Shortnose
Sturgeon
Total
Fish
Weight
2
2
148
761
74,427
762
372,450
24,818
5,264
52,936
1
1,955
39,528
480
2,174,839
7,479
1,009
404
Percent
of
Distrib
ution
0%
0%
0%
0%
1%
0%
7%
0%
0%
1%
0%
0%
1%
0%
40%
0%
0%
0%
Agency Controlling Receiving Water or Facility
NA









27








Air
Force














3,440



Army














20,983



Bureau of
Indian
Affairs





669


76


3


2,067



Bureau
of Land
Manage
ment






10,354







33
330


Bureau
of
Reclama
tion






8,777

252
112

359


250,630
4,218


Corps of
Engi-
neers








1,659


171
16,812

952,099


325
DOJ














406



EPA

















1
Forest
Service


100





8





20,133



Inter
jurisdictional
waters







18,715




19,349
9




Indian
Tribal



332
59,929

726

146





273,726



Inter-
national






85,132
5,074

40,539








      A-17

-------
Table A-6 (cont.)

Species Name
Shovelnose
Sturgeon
Smallmouth
Bass
Spring Chinook
Salmon
Steelhead
Striped Bass
Tiger
Muskellunge
Walleye
White Bass
White Crappie
Winter Chinook
Salmon
Woundfin
Yaqui Catfish
Yellow Perch

Total

Total
Fish
Weight
83
1,605
522,143
825,036
42,552
581
5,452
400
530
1,789
3
270
1,457

5,458,408

Percent
of
Distrib
ution
0%
0%
10%
15%
1%
0%
0%
0%
0%
0%
0%
0%
0%

100%

Agency Controlling Receiving Water or Facility
NA




1,492









1,519

Air
Force

201




50







11,860

Army














35,466

Bureau of
Indian
Affairs






1,067





14

9,821

Bureau
of Land
Manage
ment






4







10,721

Bureau
of
Reclama
tion

119


120

1,400





1,232

316,664

Corps of
Engi-
neers

816
155

27,152
364
841

530





1,082,574

DOJ














406

EPA














1

Forest
Service














23,892

Inter
jurisdictional
waters




4,503









63,856

Indian
Tribal


21,540











482,142

Inter-
national


422,039
690,099
4,381









1,928,034

      A-18

-------
Table A-6 (cont.)

Species Name
American Shad
Apache Trout
Arctic Grayling
Atlantic
Salmon
Atlantic
Sturgeon
Beautiful
Shiner
Black Bullhead
Black Crappie
Bluegill
Bonytail
Brook Trout
Brown Trout
Cape Fear
Shiner
Channel
Catfish
Chihuahua
Chub
Chum Salmon
Coho Salmon
Colorado
Squawfish
Cutthroat Trout
Desert Pupfish
Fall Chinook
Salmon
Fathead
Minnow
Total
Fish
Weight
1
31,483
14
173,210
33
2
9
1,405
3,684
6,318
12,588
78,698
3
77,722
14
8,353
425,534
79
140,169
2
339,921
2
Percent
of
Distrib
ution
0%
1760%
1%
9682%
2%
0%
1%
79%
206%
353%
704%
4399%
0%
4344%
1%
467%
23786%
4%
7835%
0%
19001%
0%
Agency Controlling Receiving Water or Facility
Navy










227











National
Biologic
al
Service



373













2




National
Marine
Fisheries




















2

Nationa
IPark
Service


















64



National
Resources
Conservation
Services








38













Privat
e


14
71

2

110

1




14


22
56
2


State
Gov

555

15,451



328
61
2
731
5,053
3
26,826


16,497
22
22,062

2,481

Local
Govt







3
68

370
648

1,401








TVA











22,227










U.S. Fish
&
Wildlife
Service



3,525
2



3,416
3,513
1,721


3,751


133,644
33
3,579

38,466

U.S.
Geological
Survey



286
11

9













80

Uni-
versity



1
20


27





255







2
Veterans
Admin






















      A-19

-------
Table A-6 (cont.)

Species Name
Gila
Topminnow
Gila Trout
Kokanee
Lahontan
Cutthroat Trout
Lake Sturgeon
Lake Trout
Landlocked
Atlantic
Salmon
Largemouth
Bass
Late Fall
Chinook
Salmon
Leon Springs
Pupfish
Northern Pike
Paddlefish
Pallid Sturgeon
Rainbow Trout
Razorback
Sucker
Redbreast
Sunfish
Shortnose
Sturgeon
Shovelnose
Sturgeon
Total
Fish
Weight
2
148
761
74,427
762
372,450
24,818
5,264
52,936
1
1,955
39,528
480
2,174,839
7,479
1,009
404
83
Percent
of
Distrib
ution
0%
8%
43%
4160%
43%
20819%
1387%
294%
2959%
0%
109%
2210%
27%
121567
%
418%
56%
23%
5%
Agency Controlling Receiving Water or Facility
Navy


















National
Biologic
al
Service





621












National
Marine
Fisheries


















Nationa
IPark
Service














1,656



National
Resources
Conservation
Services







54


5


2,517




Privat
e
2






12


141

11
6,872



1
State
Gov


429
14,478
81
9,177

2,773
12,258
1
472
917
63
430,578
1,235

32
82
Local
Govt



0



98


207

6
19,397




TVA




12








148,191




U.S. Fish
&
Wildlife
Service

48



257,663
532
160


595
2,405
23
41,683
30
1,009
46

U.S.
Geological
Survey






57
10


2
12




0

Uni-
versity



20


440
16



33
368
396
10



Veterans
Admin













1,688




      A-20

-------
                                                             Table A-6 (cont.)

Species Name
Smallmouth
Bass
Spring Chinook
Salmon
Steelhead
Striped Bass
Tiger
Muskellunge
Walleye
White Bass
White Crappie
Winter Chinook
Salmon
Woundfin
Yaqui Catfish
Yellow Perch

Total
Total
Fish
Weight
1,605
522,143
825,036
42,552
581
5,452
400
530
1,789
3
270
1,457

5,458,408
Percent
of
Distrib
ution
90%
29186%
46117%
2379%
32%
305%
22%
30%
100%
0%
15%
81%

100%
Agency Controlling Receiving Water or Facility
Navy













227
National
Biologic
al
Service



16









1,012
National
Marine
Fisheries

61











63
Nationa
IPark
Service













1,720
National
Resources
Conservation
Services
4




30







2,648
Privat
e





91



2

40

7,464
State
Gov
254
500
134,218
3,660
217
991





50

702,538
Local
Govt
143

640


208







23,189
TVA













170,430
U.S. Fish
&
Wildlife
Service
68
77,827

1,208

760
400

1,789
1
270
67

578,234
U.S.
Geological
Survey

21



10





54

552
Uni-
versity


79
20









1,687
Veterans
Admin













1,688
Source: FWS, 2000.
                                                                   A-21

-------
REFERENCES

Barren's. 2001. Profiles of American Colleges 2001.  Barrens Educational Series. 14th edition, August.

FWS. 2000a. U.S. Fish and Wildlife Service.  Technical publications of the U.S. Fish and Wildlife
Service Fish Technology Centers 1996-June 1999. http://fisheries.fws.gov/FTC/FTCPub.htm.
Downloaded on 26 July.

FWS. 2000b. U.S. Fish and Wildlife Service.  National fish hatchery system.
http://fisheries.fws.gov/FWSFFi/draftpage/NFHSintro.htm.  Downloaded on 26 July.

FWS. 2000c. U.S. Fish and Wildlife Service. Tribal fish hatchery programs of the northern Great Lakes
region. Ed.  F.G. Stone,  Downloaded on 16 August.

FWS. 2000d. U.S. Fish and Wildlife Service.  Division of National Fish Hatcheries.  Spreadsheet entitled
USFWS99.txt, e-mailed by Donna Kraus,  17 August.

State Websites.  2000.  Printouts of various State Websites. Downloaded in August 2000.

The College Board. 2000.  Index of Majors and Graduate Degrees 2000. College Entrance Examination
Board.

University Websites. 2001.  Printouts of various University Websites.  Downloaded in February 2001.

Whale of a Good Time. 2001. Aquariums by Region,  Downloaded on 11
November.
                                            A-22

-------
    APPENDIX B

ENTERPRISE BUDGETS
LITERATURE SEARCH
         B-l

-------
B-2

-------

Citation
*Brannan, Darrell, Kenneth Roberts, and
Walter Keithly. Louisiana Alligator
Farming: 1991 Economic Impact. Louisiana
Sea Grant College Program and the Louisiana
Department of Wildlife and Fisheries.
October.
*Dodson, D.L. and R.L. Degner. 1984.
Budgets and Financial Analyses for Various
Alligator Enterprises. Florida Agricultural
Market Research Center, University of
Florida, Gainesville. July.





Heykoop, Jerry and Darren Frechette. 1999.
A Dynamic Model of the U.S. Alligator
Industry: Lessons for Sustainable Use and
Farm Management. Selected paper at the
American Agricultural Economics
Association Annual Meeting, Nashville, TN.
August.
* Adams, Chuck, Stephen G. Holiman, and
P.J. Van Blokland. 1993. Economic and
Financial Considerations Regarding the
Commercial Culture of Hard Clams in the
Cedar Key Area of Florida. Food and
Resource Economics Department, Institute of
Food and Agricultural Sciences, University of
Florida. May.
Riepe, Jean Rousscup. 1997. Enterprise
Budgets for Yellow Perch Production in
Cages and Ponds in the North Central
Region, 1994/95. Purdue University. School
of Agriculture. Department of Agricultural
Economics. Technical Bulletin Series #111.
May.

Species
Alligator





Alligator









Alligator






Hard
Clams






Yellow
Perch





Production
System
Alligator





Alligator









Alligator






Bottom culture







Cage and Ponds







Measure of Return
Profit
$5.33 -$60.06 per
animal depending on
size.


Internal Rate of
Return depending on
low, medium, and
high sales values:
High-cost farm: -
171% to 13%
Low-cost farm: -135
to 27%
High-cost feedlot: -
175% to 17%
An abstract model;
not an enterprise
budget




Net returns to
owner/operator for
capital,
management, labor,
and risk: $25,313



Break-even costs
$1.92 to $2. 80 per
Ib




B-3

-------

Citation
Riepe, Jean Rosscup, Paul B. Brown, and
LaDon Swann. 1993. Analyzing the
Profitability of Hybrid Striped Bass Cage
Culture. Aquaculture Extension, AS-487,
Illinois-Indiana Sea Grant Program. March.
Yohn, Craig W. No date. Budget for Raising
Trout in Pond Cages. West Virginia
University Extension Service.

-------

Citation
Engle, R. Carole and Diego Valderrama.
2002. The Economics of Environmental
Impacts on Aquaculture in the United States.
In Tomasso, J.R., Aquaculture and the
Environment in the United States , U.S.
Aquaculture Society, A Chapter of the World
Aquaculture Society.








Hinshaw, Jeffrey M., Lindsay E. Rogers and
James E. Easley. 1990. Budgets for Trout
Production. Southern Regional Aquaculture
Center. SRAC Publication No. 221. January.

Shelton, James L. 1994. Trout Production.
Aquaculture Technical Series. Georgia
Cooperative Extension Service. 94-53-5-94.
May.
Belle, Sebastian. 1998. The Move Offshore:
Costs, Returns and Operational
Considerations from the Entrepreneurial
Perspective. In Stickney, Robert R.
(compiler). Joining forces with industry:
open ocean aquaculture 1998. Corpus
Christi, Texas. TAMU-SG-99-103. Page 61.
Forster, John. 1996. Cost and Market
Realities in Open Water Aquaculture. In
Polk, Marie (ed.). Open Ocean Aquaculture:
Proceedings of an international conference,
May 8-10, 1996, Portland, ME. New
Hampshire/Maine Sea Grant College
Program. Report # UNHMP-CP-SG-96-9.
Pp. 137-149.

Species















Trout




Trout



Salmon






Salmon







Production
System
Flow-through
Ponds













Flow-through




Flow-through



Net Pen Systems






Net Pen Systems








Measure of Return
Unit cost ($/kg)
increases for
pollution control
Settling basin
$0.01 to $0.10
Storage pond
up to $0.02
Constructed
wetlands
$0.11
Quiescent zones and
settling basins for
flow-through
systems
$0.08 to $0.18
Returns to land,
overhead, and
management:
Small: 15%
Large: 21%
Descriptive only
(i.e., what costs to
consider)

Abstract only -
paper not presented





Profit-per-Pound:
$0.16
Profit as a percent of
sales: 8%




B-5

-------

Citation
Engle, Carole R. and Nathan Stone. 1996.
Baitfish Production: Enterprise Budget.
Southern Regional Aquaculture Center.
SRAC Publication No. 122. October.
Pounds, Gayle L., Larry W. Dorman and
Carole R. Engle. 1991. An Economic
Analysis of Baitfish Production in Arkansas.
Arkansas Agricultural Experiment Station.
Division of Agriculture. University of
Arkansas. December.










Stone, Nathan, Eric Park, Larry Dorman, and
Hugh Thomforde. 1997. Baitfish Culture in
Arkansas: Golden Shiners, Goldfish, and
Fathead Minnows. Arkansas Cooperative
Extension. Publication MP 386.

Engle, Carole R. 1998. Annual Costs and
Returns ofBighead Carp Stocked in
Fertilized Earthen Ponds. University of
Arkansas. Cooperative Extension Service.
FSA9079. September
Engle, Carole R. 1998. Annual Costs and
Returns of Raising Bighead Carp in
Commercial Catfish Ponds. University of
Arkansas. Cooperative Extension Service.
FSA9078. September.


Species
Baitfish



Baitfish
(golden
shiner,
goldfish &
fathead
minnow)










Baitfish





Bighead
Carp



Bighead
Carp




Production
System
Ponds



Ponds















Ponds





Ponds




Ponds






Measure of Return
$275
(Net returns/acre)


5 acre ponds in 160
water acre farm:
$(87.26)
5 acre ponds in 320
water acre farm:
$(93.92)
20 acre ponds in 160
water acre farm:
$153.48
20 acre ponds in 160
water acre farm:
$148.57
20 acre ponds in 640
water acre farm:
$168.71
(Net returns/ acre)
Annual returns can
be $137/acre if the
yield is 400 pounds
per acre and the
price is $2.75 per
pound
Net returns are
$(127) per acre



Raising both
Bighead carp and
catfish yields returns
of $536 per acre
(returns for catfish
alone are $342)
B-6

-------
Citation
Dunning, R. No Date a. North Carolina
Department of Agriculture and Consumer
Services. Division of Aquaculture and
Natural Resources. Aquaculture in North
Carolina. Catfish: Inputs, Outputs, and
Economics. Plymouth, NC.
Engle, Carole R. and P. -Justin Kouka. 1996.
Effects of Inflation on the Cost of Producing
Catfish. Report submitted to The Catfish
Bargaining Association. Pine Bluff, AR.
Engle, Carole R. and Gregory N. Whitis. No
Date. Costs and Returns of Catfish
Production in Watershed Ponds . Arkansas
Cooperative Extension Program.
Engle, Carole R. and H. Steven Killian. 1996.
Costs of Producing Catfish on Commercial
Farms in Levee Ponds on Arkansas.
Cooperative Extension Program, University at
Pine Bluff.
Kouka, Pierre-Justin and Carole R. Engle.
1994. Cost of Alternative Effluent Treatments
for Catfish Production. Southern Regional
Aquaculture Center. SRAC Publication No.
467. June.
Kouka, Pierre-Justin and Carole R. Engle.
1996. Economic Implications of Treating
Effluents from Catfish Production.
Aquacultural Engineering. 15 (4): 273 -290.
Rode, Robert A. and Carole R. Engle. 1997.
Catfish Production Cost Estimates for Farms
with Level Land. University of Arkansas.
Aquaculture/Fisheries Center.
Species
Catfish
Catfish
Catfish
Catfish
Catfish
Catfish
Catfish
Production
System
Ponds
Ponds
Ponds
Ponds
Ponds
Ponds
Ponds
Measure of Return
$562
(Returns above total
costs per water acre)
$0.12
(profit per pound)
Data from 1977
through 1995 show
real profit of $0.00
to $0.33 per pound
(1982 dollars)
Fitted trend line for
real margins has
negative slope.
1 levee -$102
2 levees - $65
3 levees - $6
(net returns/acre)
Breakeven price
$0.70 to $0.73 per
pound
Break-even price
will be an additional
$0.03/lb to $0.05/lb
depending on method
of effluent treatment
break-even prices
increase up to
$0.05/lb from
incremental pollution
control costs
Breakeven prices
range from $0.61 to
$0.65 per Ib.
B-7

-------

Citation
Stone, Nathan, Carole R. Engle, and Robert
Rode. 1997. Costs of Small-Scale Catfish
Production. Arkansas Cooperative Extension
Program.
Wynne, Forrest. 1997. Budgets for Small
Scale Catfish Production to Supply a Fee
Fishing Operation. National Aquaculture
Extension Conference.

Downloaded on 16 August.
Avery, Jimmy L., Robert P. Romaire, and W.
Ray McClain. 1998. Crawfish Production:
Production Economics, Pond Construction
and Water Supply. Southern Regional Aqua-
culture Center. SRAC Publication No. 240
revised.
Boucher, Robert W. and J.M. Gillespie.
200 1 . Projected Costs and Returns for
Crawfish and Catfish Production in
Louisiana, 2001. Louisiana State University.
Dept. of Agricultural Economics and
Agribusiness. A.E.A Info. Series No. 187.



de la Bretonne, Larry W. Jr. and Robert P.
Romaire. 1990. Crawfish Production:
Harvesting, Marketing and Economics.
Southern Regional Aquaculture Center.
SRAC Publication No. 242. January.

Dunning, R. No Date b. North Carolina
Department of Agriculture and Consumer
Services. Division of Aquaculture and
Natural Resources. Aquaculture in North
Carolina. Crawfish: Inputs, Outputs, &
Economics. Plymouth, NC.

Species
Catfish



Catfish
for fee-
fishing
operations



Crawfish





Crawfish
and
Catfish






Crawfish





Crawfish





Production
System
Ponds



Ponds






Ponds





Ponds








Ponds





Ponds






Measure of Return
Breakeven prices:
Total costs $0.85/lb
Operating costs
$0.61/lb
Profit ranges from
$0.12 to $0.67 per
Ib.
Net returns to acre:
$306 -$2,213


For new operations,
break-even prices
vary from $0.27 to
$0.83 per pound


Breakeven prices
Crawfish
$0.27 to $0.77 per
pound.
Catfish
$0.43 to $0.73 per
pound
Returns per acre
$820 - $853
Break-even prices
vary from $0.37 to
$1.9 depending on
acreage devoted to
production and
production in pounds
$662 in Yr 2
(Returns above total
costs per water acre)
[$ 1.02 per Ib
$6,6 19 per farm]

B-8

-------
Citation
Masser, Michael, Gregory Whitis, and Jerry
Crews. 1997. Production of Crawfish in
Alabama. Alabama Cooperative Extension
System. ANR-891. May.
Lutz, Greg C. and Jimmy L. Avery. 1999.
Bullfrog Culture. Southern Regional
Aquaculture Center. Publication No. 436.
March.
Dunning, R. No Date c. North Carolina
Department of Agriculture and Consumer
Services. Division of Aquaculture and
Natural Resources. Aquaculture in North
Carolina. Hybrid Striped Bass: Inputs,
Outputs, and Economics. Plymouth, NC.
Wynne, Forrest. Outlook for Hybrid Striped
Bass Production in Kentucky. Kentucky
State university Cooperative Extension
Program.
Riepe, J. Rosscup. 1997. Costs for Pond
Production of Yellow Perch in the North
Central Region, 1994-1995. North Central
Region Aquaculture Center. Fact Sheet Series
#111
* Hughes, David W. 1999. The Impact of the
Louisiana Pet Turtle Industry on the State
Economy. Department of Agricultural
Economics and Agribusiness, Louisiana State
University.
* JSA. 2001. Joint Subcommittee on
Aquaculture. Aquaculture Effluent Task
Force (AETF). Economics Subgroup. South
Carolina Shrimp Farm Budget Adaptation.
Delivered by the AETF Economics Subgroup
to the AETF Co-chair on 20 June 2001 for
transmittal to EPA.
Species
Crawfish
Frog
Hybrid
Striped
Bass
Hybrid
Striped
Bass
Perch
Pet
Turtles
Shrimp
Production
System
Ponds
Ponds
Ponds
Ponds
Ponds
Ponds
Ponds
Measure of Return
Break-even cost per
pound is $0.75
including variable
and fixed costs but
not labor costs
Descriptive only
(discussion of
culture and
breeding)
Year 2 = (1,251)
Year 3 = 3,272
(Returns above total
costs per water acre)
[=(0.67) Yr 2
=0.87Yr3per
pound]
Break-even price
ranges between $2
and $3 per pound
Breakeven Prices
ranges from $2.14 to
$3 .48 per pound.
Prices range from
$2.00 to $3. 00 per
pound
Not an enterprise
budget. Examines
impact on gross state
product through
input-output model.
Internal Rate of
Return:
14. 16% -7 years
13.70% -12 years
B-9

-------

Citation
D'Abramo, Louis R. and Martin W. Brunson.
1996. Production of Freshwater Prawns in
Ponds. Southern Regional Aquaculture
Center. Publication No. 484. July.
Griffin, Wade L. and Granvil D. Treece.
1999. A Guide to the Financial Analysis of
Shrimp Farming, 1999. Texas A&M
University (TAMU), TAMU-SG-99-502
Chaves, P.A., R. M. Sutherland, and L. M.
Laird. 1999. An Economic and Technical
Evaluation of Integrating Hydroponics in a
Recirculation Fish Production System.
Aquaculture Economics & Management
3(1):83-91.
Martens, Bradley P. and Ernie W. Wade.
1996. Aquaculture in Rural Development:
The Economic Impact of Recirculating
Aquaculture Systems on Rural Communities.
Paper presented at the First International
Conference on Recirculating Aquaculture
Systems. Symposium 2: Business Plans and
Management. 12 pages. (Papers are not
paginated consecutively.)
Adams, Charles M. and Robert S. Pomeroy.
1992. Economics of Size and Integration in
Commercial Hard Clam Culture in the
Southeastern United States. Journal of
Shellfish Research. 11(1):169-176.



Van Wyk, Peter. 2000. Economics of Shrimp
Culture in a Freshwater Recirculating
Aquaculture System. Paper presented at the
Third International Conference on
Recirculating Aquaculture Systems. Special
Session 1 — Economics/Computers. 6 pages.

Species
Shrimp



Shrimp



Catfish





Catfish,
striped
bass, trout






Hard
Clams






Shrimp





Production
System
Ponds



Pond



Recirculating
Systems




Recirculating
Systems







Recirculating
system for
hatchery,
land-based
upflow for
nursery, and
bottom culture
for grow-out
Recirculating
Systems





Measure of Return
Expected rate of
return can be as high
as $2,000 to $2,500
per acre
Internal Rate of
Return
45% to 47%

Internal Rate of
Return is 27.3%




Net income:
Catfish -$128,494
Striped Bass -
$190,758
Trout - $66,250




Minimum output for
profitability.






Internal Rate of
Return:
12%



B-10

-------

Citation
Bailey, D.S., J.E. Rakocy, W.M. Cole, and
K.A. Shultz. 1997. Economic Analysis of a
Commercial-Scale Aquaponic System for the
Production of Tilapia and Lettuce. \n_Natural
Resource, Agriculture, and Engineering
Service (NRAES), Tilapia Aquaculture :
Proceedings from the Fourth International
Symposium on Tilapia in Aquaculture.
NRAES-106. Ithaca, NY. Volume 2: 603-
612.
Lutz, C. Greg. 1998. Greenhouse Tilapia
Production in Louisiana. Arkansas
Cooperative Extension. Publication 2705.

Lutz, C. Greg and Kenneth J. Roberts. 1998.
Investment and Management Aspects of
Owner/operator Scale Greenhouse Tilapia
Systems. Paper presented at the Third
International Conference on Recirculating
Aquaculture Systems. Pp. 98-105.
O'Rourke, Patrick D. 1996. The Economics
of Recirculating Aquaculture Systems. Paper
presented at the First International
Conference on Recirculating Aquaculture
Systems. Symposium 2: Business Plans and
Management. 19 pages. (Papers not
paginated consecutively.)
Timmons, Michael B. and Paul W. Aho.
1998. Comparison of Aquaculture and
Broiler Production systems. Paper presented
at the Second International Conference on
Recirculating Aquaculture Systems. Pp. 190-
199.
Dunning, Rebecca D., Thomas M. Losordo,
and Alex O. Hobbs. 1998. The Economics of
Recirculating Tank Systems: A Spreadsheet
for Individual Analysis . Southern Regional
Aquaculture Center. SRAC Publication No.
456. November.

Species
Tilapia









Tilapia



Tilapia





Tilapia






Tilapia





—





Production
System
Recirculating
Systems








Recirculating
Systems


Recirculating
Systems




Recirculating
Systems





Recirculating





Recirculating
Systems





Measure of Return
Negative unless
paired with lettuce
production with 24
tanks






Production costs
$1.19/lb.
Three-year payback
period
Production costs
$1.19/lb.
Three-year payback
period


Net profit: $3,260
Break-even volume:
$93,528




Cost per kilogram
produced
Tilapia $1.62
Catfish $1.56
Broiler $0.65

Price for tilapia set
to$1.25/lbtomake
costs



B-ll

-------
Citation
Wade, Edward M., Steven T. Summerfelt and
Joseph A. Hankins. 1996. Economies of
Scale in Recycle Systems. Paper presented at
the First International Conference on
Recirculating Aquaculture Systems. AES
Technical Session 2: Open Papers. 13 pages.
Species

Production
System
Recirculating
Systems
Measure of Return
Break-even prices
Calculated ($/lb):
$1.04 to $2.64
Enterprise budget submitted to EPA from JSA AETF.
                                        B-12

-------
      APPENDIX C




PRODUCTION THRESHOLDS
           C-l

-------
MEMORANDUM
SUBJECT:     Establishing the Production Threshold for the Concentrated Aquatic Animal Production
               Proposed Effluent Limitations Guidelines

FROM:        Janet Goodwin

TO:            The Record

       The proposed Effluent Limitations Guidelines (ELG) regulation for the Concentrated Aquatic
Animal Production (CAAP) Point Source Category apply to CAAP facilities, but not all CAAP facilities.
The proposed ELG regulation established a production threshold of 100,000 pounds produced annually.
Any CAAP facility producing this amount or more annually would be subject to the ELG regulation.
There is a population of CAAP facilities that will not be subject to this proposed ELG because they will
fall below this production threshold. This memo describes the basis for establishing the proposed
production threshold.

       The establishment of the proposed threshold was largely driven by the results of EPA's economic
impact analysis. As described in greater detail in the Economic and Environmental Impact Analysis
Document, the measure used to estimate economic impacts was the ratio of incremental compliance costs to
revenues from aquaculture sales. EPA estimated compliance costs for model facilities which were
originally developed from data in the USDA 1998 Census of Aquaculture. From the Census of
Aquaculture, EPA developed model facilities based on the six annual  revenue ranges presented in the
Census Report1. We called the corresponding revenue size categories National 1 through National 6,
respectively.  The appendices present the ranges for the major species both in terms of annual revenues
(taken directly from the Census of Aquaculture) and annual production in pounds (derived from price
information combined with the revenue data).

       As a result of the preliminary round of technology options and estimates of costs, EPA decided
to only consider facilities that would be defined as CAAP facilities under the current regulations found at
40 CFR 122.24 and Appendix C of Part 122. Under this definition, any facility producing cold water
species (salmon and trout) listed in the tables in the Appendix that produce less than 20,000 pounds
annually would not be considered  a CAAP facility. Thus for trout (see Table 2 in the Appendix), National
Foodsize Model 1  and Stackers Models 1  & 2 are not considered to be CAAP facilities and were not
considered for regulation.  For salmon, shown in Table 6 in the Appendix, Foodsize Model 1 is below the
20,000 pound threshold and is not considered a CAAP facility.  Facilities that produce warm water species
(catfish, tilapia, hybrid striped bass and shrimp) in amounts less than 100,000 pounds annually are not
considered to be a CAAP facility.  (Based on separate analysis,  EPA  determined that pond systems are
outside the scope of the proposed ELG; therefore, catfish and shrimp  produced in pond systems were not
further analyzed.)  For tilapia, National Foodsize Models 1 through 3 are not CAAP facilities and were not
considered for regulation (see Table 3 in the Appendix).  Likewise, hybrid striped bass National Foodsize
Models 1 through 3 are also below the production threshold for CAAP facilities.
       'The six revenue categories are: $1,000 to $24,999; $25,000 to $49,999; $50,000 to $99,999;
$100,000 to $499,999; $500,000 to $999,999; and $1 million or more.

                                              C-2

-------
       EPA considered three technology options for the three different production systems in scope of the
proposed rule, flow-through systems, recirculating systems and net pen systems.  The options are described
in detail in the Preamble to the proposed regulation and in the Technical Development Document. The
following tables (Tables 1 through 4) present the results of the revenue tests for each of the three
technology options considered for this proposal. The revenue tests are based EPA's initial (March 21,
2002) compliance cost estimates and 1998 prices.  For non-commercial facilities - such as Federal and
state hatcheries, academic and research, and tribal facilities - we imputed a revenue based on annual
harvest and commercial prices.
                                             Table 1
                           Flow-through Systems, Trout, Food Size Fish
Owner
Trout
Commercial
Trout
Federal
Trout
State
Trout
Academic
Trout
Other
Size
2
3
4
5
6
6
2
4
5
2
3
2
5
Percent of Facilities Showing Revenue Test Impacts (Option 1)
1%
87%
66%
70%
55%
20%
100%
85%
25%
92%
100%
0%
88%
100%
3%
87%
66%
37%
11%
0%
0%
85%
0%
51%
100%
0%
88%
0%
5%
87%
34%
25%
0%
0%
0%
85%
0%
2%
100%
0%
88%
0%
10%
69%
11%
0%
0%
0%
0%
55%
0%
0%
0%
0%
75%
0%
                                              C-3

-------
                      Table 2
Flow-through Systems, Food Size Fish Other Than Trout
Owner
Salmon
Commercial
Salmon
Federal
Salmon
Other
Striped Bass
Tilapia
Size
6
2
6
4
4
5
6
Percent of Facilities Showing Revenue Test Impacts (Option 1)
1%
0%
100%
0%
0%
88%
100%
0%
3%
0%
100%
0%
0%
50%
0%
0%
5%
0%
100%
0%
0%
13%
0%
0%
10%
0%
100%
0%
0%
0%
0%
0%
                       C-4

-------
           Table 3
Flow-through Systems, Stockers
Owner
Trout
Commercial
Trout
Federal
Trout
State
Trout
Other
Trout
Tribal
Size
2
3
4
3
4
2
3
4
3
4
3
Percent of Facilities Showing Revenue Test Impacts (Option 1)
1%
50%
51%
62%
100%
64%
94%
85%
31%
100%
0%
0%
3%
0%
22%
7%
75%
10%
75%
32%
2%
0%
0%
0%
5%
0%
7%
0%
50%
0%
69%
16%
0%
0%
0%
0%
10%
0%
0%
0%
0%
0%
19%
0%
0%
0%
0%
0%
             C-5

-------
                                          Table 4
                             Recirculating Systems and Net Pens
Owner
Recirculating
Striped Bass
Recirculating
Tilapia
Net Pens
Salmon
Size
4
6
4
5
6
5
6
Percent of Facilities Showing Revenue Test Impacts (Option 1)
1%
0%
0%
75%
0%
0%
0%
17%
3%
0%
0%
0%
0%
0%
0%
0%
5%
0%
0%
0%
0%
0%
0%
0%
10%
0%
0%
0%
0%
0%
0%
0%
       Based on the results of the revenue tests shown above it was determined that flow-
through systems below National Model 4 would incur significant financial impacts under even the
least stringent option (Option 1) considered.  EPA did not identify any facilities below the
National 4 production level for recirculating systems and net pens. Model Facility 4 represented a
range of annual production values that varied according to the individual species being
considered.
                                          Table 5
                       Production Ranges for Model Facility 4 by Species
Species
Trout Foodsize
Trout Stackers
Tilapia Foodsize
Hybrid Striped Bass
Foodsize
Salmon Foodsize
Lower Bound 1998 per
Farm Production
(pounds)
94,339.62
43,668.12
58,823.53
40,983.61
50,000.00
Average 1998 per
Farm Production
(Pounds)
192,147.17
88,941.48
120,876.47
84,217.21
102,745.00
Upper Bound 1998 per
Farm Production
471,697.17
218,340.17
294,117.96
204,917.62
249,999.50
                                           C-6

-------
       As shown by Table 5, the lower bound of the annual production for each of the Model 4
facilities ranges from 41,000 pounds for hybrid striped bass to 94,000 pounds for foodsize trout.
Since flow-through systems producing foodsize trout showed the greatest impacts based on the
revenue test, and given that these facilities represent the largest class of CAAP facilities in terms
of the number regulated, EPA chose this basis to establish the production threshold for the ELG
requirements. EPA is proposing to round the production threshold up tolOO,000 pounds
produced rather than the actual value calculated when revenues were converted to pounds based
on the reported price per pound.

       EPA believes this 100,000 pound production threshold represents a reasonable threshold
above which all facilities in scope can comply with the proposed regulatory requirements.
Facilities that produce less than 100,000 pounds annually of cold water species are not covered by
the proposed ELG regulations based on the economic impacts that would result from the costs to
comply, while facilities that produce less than 100,000 pounds annually of warm water species do
not meet the definition of a CAAP facility and are thus not covered either.

       EPA also proposes to establish tiered requirements for the flow-through subcategory,
based on the estimated economic impacts associated with more stringent requirements (Option 2)
for the National 4 size flow-through facilities. The results of the revenue tests shows that flow-
through facilities in Model Size 4 would experience  significant economic impacts if they were
required to comply with Option 2 requirements while Model Size 5 and 6 would not experience
impacts (see Tables 6 through 8 below). Therefore, EPA proposes to establish a threshold within
the flow-through subcategory and establish less stringent requirements for flow-through facilities
in Model Size 4. As shown above in Table 5, the Model 4 foodsize trout facility size ranges from
94,336 pounds to 471,700 pounds in annual production. EPA rounded these values to range from
100,000 to 475,000 pounds, and used this production range to represent medium sized flow-
through facilities. Facilities that  produce aquatic animals in flow-through systems and have an
annual production greater than 475,000 pounds annually would have to comply with more
stringent requirements based on Option 3 as described in the preamble, Economic and
Environmental Impact Analysis and Technical Development Document.
                                          C-7

-------
                     Table 6
   Flow-through Systems, Trout, Food Size Fish
Owner
Trout
Commercial
Trout
Federal
Trout
State
Trout
Other
Size
4
5
6
6
4
5
5
Percent Showing Revenue Test Impacts (Option 2)
1%
100%
55%
20%
100%
100%
92%
100%
3%
70%
11%
0%
50%
25%
51%
0%
5%
70%
0%
0%
0%
25%
2%
0%
10%
3%
0%
0%
0%
0%
0%
0%
                     Table 7
Flow-through Systems, Food Size Fish Other Than Trout
Owner
Salmon
Commercial
Salmon
Other
Striped Bass
Tilapia
Size
6
6
4
4
5
6
Percent Showing Revenue Test Impacts (Option 2)
1%
100%
100%
100%
100%
100%
0%
3%
0%
0%
0%
88%
0%
0%
5%
0%
0%
0%
50%
0%
0%
10%
0%
0%
0%
0%
0%
0%
                      C-8

-------
           Table 8
Flow-through Systems, Stockers

Owner
Trout
Commercial
Trout
Federal
Trout
State
Trout
Other

Size

4

4

4

4
Percent Showing Revenue Test Impacts (Option 2)
1%

100%

100%

100%

100%
3%

49%

54%

27%

0%
5%

7%

10%

2%

0%
10%

0%

0%

0%

0%
             C-9

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Table Appendix 1
     Catfish
National
Foodsize
1
2
3
4
5
6
Lower Bound
1998 per Farm
Production ($)
1,000.00
25,000.00
50,000.00
100,000.00
500,000.00
1,000,000.00
Lower Bound
1998 per Farm
Production
(pounds)
1,351.35
33,783.78
67,567.57
135,135.14
675,675.68
1,351,351.35
Average 1998 per
Farm Production
($)
6,893.00
34,968.00
71,676.00
222,538.00
695,276.00
2,606,890.00
Average 1998 per
Farm Production
(Pounds)
9,314.86
47,254.05
96,859.46
300,727.03
939,562.16
3,522,824.32
Upper Bound
1998 per
Farm
Production
($)
24,999.00
49,999.00
99,999.00
499,999.00
999,999.00

Upper Bound
1998 per
Farm
Production
(pounds)
33,782.42
67,566.22
135,133.7*
675,674.32
1,351,350.0(


National
Broodsize
1
2
3
4
5
6
Lower Bound
1998 per Farm
Production ($)
1,000.00
25,000.00
50,000.00
100,000.00
500,000.00
1,000,000.00
Lower Bound
1998 per Farm
Production
(pounds)
1,000.00
27,472.53
54,945.05
109,890.11
549,450.55
1,098,901.10
Average 1998 per
Farm Production
($)
6,893.00
34,968.00
71,676.00
222,538.00
695,276.00
2,606,890.00
Average 1998 per
Farm Production
(Pounds)
6,893.00
38,426.37
78,764.84
244,547.25
764,039.56
2,864,714.29
Upper Bound
1998 per
Farm
Production
($)
24,999.00
49,999.00
99,999.00
499,999.00
999,999.00

Upper Bound
1998 per
Farm
Production
(pounds)
27,471.42
54,943. 9(
109,889.01
549,449.4=
1,098,900.0(


National
Stockers
1
2
3
4
5
6
Lower Bound
1998 per Farm
Production ($)
1,000.00
25,000.00
50,000.00
100,000.00
500,000.00
1,000,000.00
Lower Bound
1998 per Farm
Production
(pounds)
1,000.00
24,271.84
48,543.69
97,087.38
485,436.89
970,873.79
Average 1998 per
Farm Production
($)
6,893.00
34,968.00
71,676.00
222,538.00
695,276.00
2,606,890.00
Average 1998 per
Farm Production
(Pounds)
6,893.00
33,949.51
69,588.35
216,056.31
675,025.24
2,530,961.17
Upper Bound
1998 per
Farm
Production
($)
24,999.00
49,999.00
99,999.00
499,999.00
999,999.00

Upper Bound
1998 per
Farm
Production
(pounds)
24,270.81
48,542.72
97,086.41
485,435.92
970,872.82


National
Fry/
?ingerlings
1
2
3
4
5
6
Lower Bound
1998 per Farm
Production ($)
1,000.00
25,000.00
50,000.00
100,000.00
500,000.00
1.000.000.00
Lower Bound
1998 per Farm
Production
(pounds)
1,000.00
15,060.24
30,120.48
60,240.96
301,204.82
602.409.64
Average 1998 per
Farm Production
($)
6,893.00
34,968.00
71,676.00
222,538.00
695,276.00
2.606.890.00
Average 1998 per
Farm Production
(Pounds)
6,893.00
21,065.06
43,178.31
134,059.04
418,840.96
1.570.415.66
Upper Bound
1998 per
Farm
Production
($)
24,999.00
49,999.00
99,999.00
499,999.00
999,999.00

Upper Bound
1998 per
Farm
Production
(pounds)
15,059.64
30,119.8*
60,240.3(
301,204.22
602,409.04

1998 per Farm Production ($) numbers are from 1998 Census of Aquaculture, Table 2., p 4. These numbers were then
divided by Average per pound (dollars) in Table 8., pp 18-22. Foodsize were divided by (.74); Broodsize by (.91); Stockers
by (1.03); Fingerlings by (1.66).
      C-10

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Table Appendix-2
     Trout
National
Foodsize
1
2
3
4
5

6
Lower
Bound 1998
per Farm
Production
($)
1,000.00
25,000.00
50,000.00
100,000.00
500,000.00

1,000,000.00
Lower Bound
1998 per Farm
Production
(pounds)
943.40
23,584.91
47,169.81
94,339.62
471,698.11

943,396.23
Average 1998 per
Farm Production
($)
8,027.00
35,707.00
73,918.00
203,676.00
751,456.00

3,732,614.00
Average
1998 per
Farm
Production
(Pounds)
7,572.64
33,685.85
69,733.96
192,147.17
708,920.75
3,521,333.9
6
Upper Bound
1998 per Farm
Production ($)
24,999.00
49,999.00
99,999.00
499,999.00
999,999.00


Upper Bound
1998 per Farm
Production
(pounds)
23,583.96
47,168.87
94,338.68
471,697.17
943,395.28



Stockers
1
2
3
4
5
6
Lower
Bound 1998
per Farm
Production
($)
1,000.00
25,000.00
50,000.00
100,000.00
500,000.00
1.000.000.00
Lower Bound
1998 per Farm
Production
(pounds)
1,000.00
10,917.03
21,834.06
43,668.12
218,340.61
436.681.22
Average 1998 per
Farm Production
($)
8,027.00
35,707.00
73,918.00
203,676.00
751,456.00
3.732.614.00
Average
1998 per
Farm
Production
(Pounds)
8,027.00
15,592.58
32,278.60
88,941.48
328,146.72
1,629,962.4
5
Upper Bound
1998 per Farm
Production ($)
24,999.00
49,999.00
99,999.00
499,999.00
999,999.00

Upper Bound
1998 per Farm
Production
(pounds)
10,916.5?
21,833.62
43,667.6?
218,340.17
436,680.7?

1998 per Farm Production ($) numbers are from 1998 Census of Aquaculture, Table 2., p 4. These numbers were then divided
by Average per pound (dollars) in Table 9., pp 23-25. Foodsize were divided by (1.06); Stockers by (2.29).
      C-ll

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Table Appendix-3
     Tilapia
National
Foodsize
1
2
3
4
5
6
Lower Bound
1998 per Farm
Production ($)
1,000.00
25,000.00
50,000.00
100,000.00
500,000.00
1.000.000.00
Lower Bound
1998 per Farm
Production
588.24
14,705.88
29,411.76
58,823.53
294,117.65
588.235.29
Average 1998
per Farm
Production ($)
6,106.00
34,013.00
67,576.00
205,490.00
719,808.00
3.509.109.00
Average 1998 per
Farm Production
(Pounds)
3,591.76
20,007.65
39,750.59
120,876.47
423,416.47
2.064.181.76
Upper Bound
1998 per Farm
Production ($)
24,999.00
49,999.00
99,999.00
499,999.00
999,999.00
Upper Bound
1998 per Farm
Production
14,705.29
29,411.18
58,822.94
294,117.06
588,234.71
1998 per Farm Production ($) numbers are from 1998 Census of Aquaculture, Table 2., p 4 (Food fish other than catfish
and trout). These numbers were then divided by Average per pound (dollars) in Table 12., p 41. Foodsize were divided by
(1.70).
      C-12

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Table Appendix-4
     Shrimp


Foodsize
1
2
3
4
5
6
Lower Bound
1998 per Farm
Production ($)
1,000.00
25,000.00
50,000.00
100,000.00
500,000.00
1.000.000.00
Lower Bound
1998 per Farm
Production
362.32
9,057.97
18,115.94
36,231.88
181,159.42
362.318.84
Average 1998
per Farm
Production ($)
8,166.00
33,980.00
65,593.00
186,995.00
766,667.00
2.463.833.00
Average 1998 per
Farm Production
(Pounds)
2,958.70
12,311.59
23,765.58
67,751.81
277,777.90
892.693.12
Upper Bound
1998 per Farm
Production ($)
24,999.00
49,999.00
99,999.00
499,999.00
999,999.00

Upper Bound
1998 per Farm
Production
9,057.61
18,115.58
36,231.52
181,159.06
362,318.48

1998 per Farm Production ($) numbers are from 1998 Census of Aquaculture, Table 2., p 4 (Crustaceans). These numbers were
then divided by Average per pound (dollars) in Table 17., p 57. Foodsize were divided by (2.76).
      C-13

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 Table Appendix-5
Hybrid Striped Bass
National
Foodsize
1
2
3
4
5
6
Lower Bound
1998 per Farm
Production ($)
1,000.00
25,000.00
50,000.00
100,000.00
500,000.00
1.000.000.00
Lower Bound
1998 per Farm
Production
409.84
10,245.90
20,491.80
40,983.61
204,918.03
409.836.07
Average 1998
per Farm
Production ($)
6,106.00
34,013.00
67,576.00
205,490.00
719,808.00
3.509.109.00
Average 1998 per
Farm Production
(Pounds)
2,502.46
13,939.75
27,695.08
84,217.21
295,003.28
1.438.159.43
Upper Bound
1998 per Farm
Production ($)
24,999.00
49,999.00
99,999.00
499,999.00
999,999.00
Upper Bound
1998 per Farm
Production
10,245.49
20,491.39
40,983.20
204,917.62
409,835.66
1998 per Farm Production ($) numbers are from 1998 Census of Aquaculture, Table 2., p 4 (Food fish other than catfish and
trout). These numbers were then divided by Average per pound (dollars) in Table 12., p 41. Foodsize were divided bv (2.44).
       C-14

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Table Appendix-6
     Salmon
Foodsize
1
2
3
4
5
6
Lower
Bound 1998
per Farm
1,000.00
25,000.00
50,000.00
100,000.00
500,000.00
1.000.000.00
Lower Bound
1998 per Farm
Production
500.00
12,500.00
25,000.00
50,000.00
250,000.00
500.000.00
Average 1998 per
Farm Production
($)
6,106.00
34,013.00
67,576.00
205,490.00
719,808.00
3.509.109.00
Average 1998 per
Farm Production
(Pounds)
3,053.00
17,006.50
33,788.00
102,745.00
359,904.00
1.754.554.50
Upper Bound
1998 per Farm
Production ($)
24,999.00
49,999.00
99,999.00
499,999.00
999,999.00
Upper Bound
1998 per Farm
Production
12,499.50
24,999.50
49,999.50
249,999.50
499,999.50
1998 per Farm Production ($) numbers are from 1998 Census of Aquaculture, Table 2., p 4 (Food fish other than catfish
and trout). These numbers were then divided by Average per pound (dollars) (2.00 as per John H.).
      C-15

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                                        Appendix D

              Calculation of Municipal Domestic Wasteload Equivalents

Typical pollutant concentrations and loads associated with municipal domestic wastewater reported by
WEF and ASCE (1998) are shown in Table D-l. These estimated daily per capita pollutant load
production values are used in the sizing and design of wastewater treatment facilities.  Similar values are
reported in Metcalf and Eddy, Inc. (1991).
                                          Table D-l
                  Typical Major Pollutant Composition of Domestic Wastewater
Parameter
BOD5
Total Nitrogen
Total Phosphorus
Total Suspended Solids
Concentration in
Domestic Wastewater
400 mg/L
30mg/L
7 mg/L
240 mg/L
Estimated Daily Per Capita
Production of Pollutants
0.171b/capd
0.04 Ib/cap d
0.006 Ib/cap d
0.2 Ib/cap d
Estimated Annual Per
Capita Production of
Pollutants
62.05 Ib/cap year
14.60 Ib/cap year
2.19 Ib/cap year
73. 00 Ib/cap year
The per capita values can be used to estimate annual municipal domestic wasteload equivalents. The
equation for this calculation is:
       Human Equivalents (persons) =  AAP Facility Load (Ib/yr)
                                    Human Load (Ib/capita yr)


REFERENCES
Metcalf and Eddy, Inc. 1991.  Wastewater Engineering:  Treatment, Disposal, and Reuse, 3d ed., revised
by Tchobanoglous, G., and F. Burton., McGraw Hill, Inc., NY.

WEF and ASCE (Water Environment Federation and American Society of Civil Engineers). 1998.  Design
of Municipal Wastewater Treatment Plants, 4th ed., WEF Manual of Practice, Water Environment
Federation, Alexandria, VA.
                                            D-l

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                                  Appendix E




           Literature Review for AAP Impacts on Water Quality
Examples of Effluents by Production System Type




Table El. Examples of Effluents from Cage Systems
Reference
Cornel, G.E. and F.G.
Whoriskey. 1993. The
effects of rainbow trout
(Oncorhynchus mykiss)
cage culture on the water
quality, zooplankton,
benthos, and sediments of
Lac du Passage, Quebec.
Aquaculture 109: 101-
117.












Source
Category
Foreign


















System
Cages


















Species
Trout


















Flow Or
Volume
8 cages, each
9m x 9m x 9m,
combined
producing 14
metric tons fish
per year with
feed input of
52, 125 kg dry
feed/year













Parameter Data
After 4 years of operation, water quality
was sampled at the farm:

0.09 to 0.011 mg/1 P04-P, 0.05 to 0.06
mg/1 N03-N, 0.03 to 0.04 mg/1 NH4-N.

Daphnia were less abundant around the
farm during the summer. Wild perch,
and escaped farm trout hang around
outside the net pens to eat waste feed.
Bloodworm (Chironomus) was the most
widespread benthic organism.
Bloodworms are a pollution-tolerant
species; therefore, their abundance is a
negative indicator of water quality.
There was low DO around the farm, but
nutrient and chlorophyll a levels were
small and localized. Sediment available
P levels were higher at the farm than at
control sites, but the peaks coincided
with periods of overfeeding.
Pollutant



nutrients

(other)













Table E2. Examples of Effluents from Flow-Through Systems

Reference
Ruane, R.J., T.Y.J. Chu, and
V.E. Vandergriff. 1977.
Characterization and
treatment of waste discharged
from high-density catfish
cultures. Water Res. 11:789-
800.


Westers, H. 2000.
Michigan's Platte River State
Fish Hatchery Case History,
RAS 2000 Conference,
Blacksburg, VA

Weston, D.P., B. Dixon, and
C. Forney. 1998. Fate and
Microbial Effects of
Aquacultural Drug Residues
in the Environment.
University of California,
Berkeley.



Source
Category
Primary






Gray
















System
Flow-
Through





Flow-
Through




Flow-
Through









Species
Catfish






Salmon





Sturgeon









Flow Or
Volume
190 liters/sec






1200 + 5000
+8500 GPM
(three
potential
sources)

unknown










Parameter Data
0.07 kg/day/100 kg fish ammonia
nitrogen

0.8 kg/day/100 kg fish suspended
solids, 0.3 ml/1 settleable solids

10,000,000 organisms/lOOml water
Fecal coliforms
Yearly P loading from Platte River
Hatchery:
1990tol996: 157kg/yrP.

1990to 1992:316kg/yrP.
1993to 1996:96kg/yrP.
Tetracycline concentrations in
sediments downstream of a sturgeon
farm were up to 5 ug/g.
Oxytetracycline concentrations in
sediments beneath net-cage sites are
commonly in the 1 to 10 ug/g range.
300 ug/g under a salmon net pen in
Norway was the highest
oxytetracycline concentration ever
recorded in aquaculture sediment.

Pollutant
nutrients


solids

(other)

nutrients





(other)









                                       E-l

-------

Reference
Boardman, G.D., V. Mallard,
J. Nyland, G.J. Flick, and
G.S. Libey. 1998. Final
Report: The Characterization,
Treatment and Improvement
of Aquacultural Effluents.
Virginia Polytechnic Institute
and State University. October
23, 1998.









Brannon, E.L. no date. Fish
Farm Effluent Quality. Idaho.




Jensen, J.B. No date.
Environmental Regulation of
Fresh Water Fish Farms in
Denmark. Danish National
Agency of Environmental
Protection. 1 1 pp.


JRB Associates. 1984.
Development of Effluent
Limitations for Idaho Fish
Hatcheries. July 23, 1984.

Kendra, W. 1991. Quality of
salmonid hatchery effluents
during a summer low-flow
season. Trans. Am. Fish Soc.
120:43-51












Source
Category






















Foreign












Primary

















System
Flow-
Through














Flow-
Through




Flow-
Through






Flow-
Through



Flow-
Through
















Species
Trout















Trout





Trout







Trout




Trout
















Flow Or
Volume
Farm A -2.70
to 4.05 mVmin

FarmB- 11.2
to 24.8 m3/min

Farm C - 25.6
to 28.9 nvVmin









unknown,
from
groundwater
source


not specified







Flow 22 to 30
cfs



0.06 to 0.41
m3/sec
















Parameter Data
-Farm A outlet: 0.5 to 0.6 mg/1 NH3-
N
Farm B outlet: 0.45 mg/1 NH3-N
Farm C outlet: 0.02 to 0.17 mg/1
NH3-N
-Farm A outlet: 0.8 to 6 mg/1 TSS, 0
to 0.04 ml/1 suspended solids
Farm B outlet: 1.5 to 7.5 mg/1 TSS,
0.01 to 0.08 ml/1 suspended solids
Farm C outlet: 4.1 to 62 mg/1 TSS,
0.04 to 0.08 ml/1 suspended solids
- Farm A outlet: 0.96 to 1.9 mg/1
BOD5, 1.5 to 2.4 mg/1 DOC
Farm B outlet: 0.6 to 2.4 mg/1 BOD5,
1.2 to 3.1 mg/1 DOC
Farm C outlet:, 0.5 to 1.8 mg/1
BOD5, 1.5 to 3.8 mg/1 DOC
Post-settling effluent:
0.074 mg/1 total P, 0.054 mg/1
orthophosphate, .040 mg/1 ammonia,
4.980 mg/1 NO2-N + NO3-N.
<0.02 ml/1 settleable solids, 3.0 mg/1
suspended solids
In 1985, pelleted feed was made
mandatory. Mandatory
improvements in feed quality were
phased in 1989-1992. Total Danish
fish farm effluent in 1987 was
approximately 5,000 1 BOD5/year,
2,200 1 nitrogen/year, and 400 1
phosphorus/year.
JRB study: 0.72 to 1.64 pounds TSS/
100 pounds fish. Pisces effluent:, 92
to 150 mg/1 TSS, 4,880 to 11,370
kg/day TSS, trace ml/1 settleable
solids.
Yakima Trout Hatchery:
- normal operations: 0.43 mg/1 TKN,
0.22 mg/1 total P
- during cleaning: 1.7 mg/1 TKN, 4.0
mg/1 total P
- normal operations: 1 mg/1 total
suspended solids, 0 mg/1 total
volatile suspended solids, <0. 1 ml/1
settleable solids
- during cleaning: 88 mg/1 total
suspended solids, 69 mg/1 total
volatile suspended solids, and 2.5
ml/1 settleable solids.
- normal operations: 6 mg/1 COD, 3
mg/1 BOD5.
- during cleaning: 130 mg/1 COD, 32
mg/1 BOD5.

Pollutant
nutrients


solids





organic
enrichment






nutrients



solids
(other)







solids




nutrients




solids







organic
enrichment


E-2

-------

Reference
Niemi, M., and I. Taipalinen.
1982. Faecal indicator
bacteria at fish farms.
Hydrobiologia 76(1982):171-
175.
Piedrahita, R.H. 1994.
Managing Environmental
Impacts in Aquaculture. Bull.
Natl. Res. Inst. Aquaculture,
Suppl. 1:13-20. 1994.
Rennert, B. 1994. Water
pollution by a land-based
trout farm. J. Appl. Ichthyol.
10(1994):373-378.
















Selong, J.H. and L.A.
Helfrich. 1998. Impacts of
trout culture effluent on water
quality and biotic
communities in Virginia
headwater streams. The
Progressive Fish-Culturist
35(7): 247-262.
Source
Category
Foreign









Foreign



















Primary








System
Flow-
Through



Flow-
Through



Flow-
Through


















Flow-
Through







Species
Trout




Trout




Trout



















Trout







Flow Or
Volume
2.6 nvVsec




22.6m3/sec




1 10 I/sec with
additional 240
I/sec recycled

















0.27 to 1.24
m3/sec







Parameter Data
Fecal streptococci in effluent 0.18 to
0.37 ml -1, g-1, total coliforms 5.2 to
8.0 ml -1, g -1, fecal coliforms 0.48
to 1.2ml-l, g-1.

-Fish waste solids were analyzed at
4. 13 mg/1 N, 2.15 mg/1 P, and 88%
moisture.


-Effluent values: 0.02 mg/1 NO2-N,
0.96 mg/1 NO3-N, 0.64 mg/1 NH4-N,
0.21 mg/1 PO4-P. Nitrogen loading
rate was 465 g N per tone offish per
day. Phosphorus loading rate was
155 g P per tone offish per day in
water, and also an additional 2.07 g
P per ton of fish per day that is in
suspended solids that are flushed
from the raceways once per day
-Effluent values: 0.03 mg/1
suspended matter. Nitrogen loading
rate was 465 g N per metric ton of
fish per day. Additional loadings of
30 liters or suspended matter per
metric ton of fish per day.
- Effluent values: 4.2 mg/1 COD.
Additional loadings of 3100 g COD
per metric ton of fish per day were
also observed.
0.3 to 1.0 mg/1 total ammonia-N for
trout farm A; highest ammonia
concentrations occurred during low
flow conditions in fall.





Pollutant
(other)




nutrients




nutrients









solids






organic
enrichment


nutrients



benthic
degradation


E-3

-------
Table E3. Examples of Effluents from Other Types of Production Systems: Gator Pens
Reference
Pardue, J.H., R.D. DeLaune, W.H.
Patrick, Jr., and J.A. Nyman. 1994.
Treatment of alligator farm wastewater
using land application. Aquacult. Eng.
13(1994) 129-145.


Source
Category
Primary



System
Gator
Pens



Species
Alligators



Flow Or
Volume
hypothetical
6000 mVyear



Parameter Data
Data from alligator
farm effluent:
10.9 mg/1 total P, 77.5
mg/1 NH3, 4.6 mg/1
NO3-N, 153.4 mg/1
TKN
379 mg/1 total solids,
2 19 mg/1 volatile
solids
452 mg/1 BOD
Pollutant

nutrients
solids
organic
enrichment
Table E4. Examples of Effluents from Net Pens
Reference
Hargrave, B.T., Phillips,
G.A., Doucette, L.I., White,
M.J., Milligan, T.G.,
Wildish, D.J., and R.E.
Cranston. 1997. Assessing
benthic impacts of organic
enrichment from marine
aquaculture. Water, Air and
Soil Pollution 99: 641-650.



























Source
Category
Foreign



































System
Net
Pens


































Species
Salmon



































Flow Or
Volume
1 1 farms and 1 1
reference sites.
Farm production
varied from
40,000 to
320,000 tons of
fish per year.





























Parameter Data
Sediment cores were collected under
farms and at reference sites and
analyzed at a lab. The authors do not
report specific data values for
specific farms or control sites. The
most sensitive variables for finding
differences between farms and
reference sites were total sulfide,
benthic O2 uptake, benthic CO2
release, and redox potential. The
polychaete Capitella sp. can tolerate
total sulfide concentrations up to 2
mM. Total sulfide concentrations
above 2 mM are toxic to larvae and
prevent settlement. No Capitella sp.
were observed at any of the farm
sites. All of the farms had total
sulfide over 1 80 uM, with a
maximum of 6 to 7mM. All but
one of the reference sites had total
sulfide under 200 uM. Redox
potential at all but three of the farms
was under +100 mV. Redox
potential at all but two of the
reference sites was over +100 mV.
Mean values for total sediment O2
uptake was 175 percent higher at the
farms than reference sites. Mean
values for total sediment CO2
release was 355 percent higher at
farms than reference sites.
Measurements of modal grain size
pore water salinity, SO4, and
sediment water content were not
significantly different between
farms and reference sites.
Pollutant
benthic
degradation


































                                           E-4

-------

Reference
Holmer, M. 1991. Impacts
of Aquaculture on
Surrounding Sediments:
Generation of Organic-Rich
Sediments. In Aquaculture
and the Environment:
Reviews of the International
Conference Aquaculture
Europe 91, European
Aquaculture Society,
Dublin, Ireland, June 10-12,
1991, pp. 155-175.














Johnsen, R.I., O. Grahl-
Nielsen, and B.T. Lunestad.
1993. Environmental
distribution of organic waste
from a marine fish farm.
Aquaculture 118(3-4): 229-
244.














Source
Category
Foreign















































System
Net
Pens
























Net
Pens




















Species
Salmon

























Salmon




















Flow Or
Volume
not specified

























N/A





















Parameter Data
One farm, seasonal variation 34 to
41 mmolperm2 per day SOU. Six
farms, annual mean 86 to 446 mmol
per m2 per day SOU. One farm,
seasonal variation 60 to 230 mmol
per m2 per day SOU. CO2
production in sediment metabolism
was related to food input with an
r2 = 0.975. Oxygen uptake in
sediments increased sharply with
sediment thickness up to 10 cm, and
then gradually leveled out.
Antibiotic resistant bacteria were
found in sediments from antibiotic
feeds. Zinc from feed, and copper
from antifouling agents have been
measured in fish farm sediments.
Sedimentation rates under mussel
rafts were three times the
sedimentation rates at control sites.
- Zinc from feed, and copper from
antifouling agents have been
measured in fish farm sediments.
Sedimentation rates under mussel
rafts were three times the
sedimentation rates at control sites.
Researchers collected sediment
under a working farm and at control
sites. Feed, feces and sediment were
analyzed to screen fatty acids that
might be used as chemical markers
for organic sediment enrichment
caused by fish farms. Pristane is
one of the compounds investigated.
Anoxic sediments beneath fish
farms gave off H2S smell. Beneath
the farm, divers observed a fine
white blanket of what was likely
elemental sulfur and sulphur-
oxidizing bacteria (Beggiatoa) on
the sediment surface. The authors
used multivariate statistics to show
differences between pristine
concentrations in farm sediments
and control sediments. Fatty acids
and/or pristane show promise as fish
farm sediment markers.

Pollutant
benthic
degradation


















(other)





benthic
degradation



















E-5

-------

Reference
Kaspar, H.F., G.H. Hall, and
A.J. Holland. 1988. Effects
of sea cage salmon farming
on sediment nitrification and
dissimilatory nitrate
reduction. Aquaculture
70(4): 333-344.






















Milewski, I., J. Harvey, and
B. Buerkle. 1997. After the
Goldrush: Salmon
Aquaculture in New
Brunswick. In Murky
Waters: Environmental
Effects of Aquaculture in the
U.S, ed. R. Goldberg and T.
Triplet!, pp. 131-152. The
Environmental Defense
Fund, New York.
Source
Category
Foreign




























Gray











System
Net
Pens



























Net
Pens










Species
Salmon




























Salmon










Flow Or
Volume
N/A




























N/A











Parameter Data
Sediment cores and gas bubbles
from sediment were collected
beneath a working salmon farm in
New Zealand. At site 1 (the site
beneath the center of a cage at a
water depth of 13 m): 14.3 to 34.3
mmol/m NH4+, 1.4 to 5.3 mol/m
Organic N, 0.4 to 3.6 mol/m Total
P, 1.4 to 3.1 N:P ratio.
- Gas evolving from sediment at site
1 consisted of 64 percent methane, 5
percent carbon dioxide, 2 percent
water vapor, 7 percent air, and 22
percent unknown. The unknown
portion probably contained H2S,
because the divers could smell it. In
situ nitrification rates were <0.1 to
0.3 mmol N/m per day.
Denitrification at the sites was
determined not to be a significant
nitrogen removal mechanism.
Nitrification / Denitrification was
not occurring because the sediments
lacked oxygen to supply the
nitrification step. Beneath the net
pens, divers observed black colored
sediments covered by a Beggiatoa-
like bacterial mat that smelled like
H2S and was bubbling off methane.
In one study, 8.3 ha out of 34.6 ha
salmon farms investigated were
classified as heavily degraded.
Heavy degradation includes
bubbling gas, the absence of fish
and sediment-dwelling organisms,
accumulations of fish feed and feces
not dispersed by a tidal cycle, and
bacterial mats. Areas less impacted
would have no organisms other than
worms tolerant of low DO.

Pollutant
nutrients








benthic
degradation


















benthic
degradation









E-6

-------

Reference
Mazzola, A., S. Mirto, and
R. Danovaro. 1999. Initial
fish-farm impact on
meiofaunal assemblages in
coastal sediments of the
Western Mediterranean.
Mar. Poll. Bull. 38(12):
1126-1133.


































Gale, P. 1999. Appendix 9.
Water Quality Impacts from
Aquaculture Cage
Operations in the
LaCloche/North Channel of
Lake Huron. In Addressing
Concerns for Water Quality
Impacts from Large-Scale
Great Lakes Aquaculture: A
Roundtable. Habitat
Advisory Board of the Great
Lakes
Source
Category
Foreign









































Foreign












System
Net
Pens








































Net
Pens











Species
Sea
Bream








































Trout











Flow Or
Volume
N/A(cultured
fish biomass
varied from
about 18,000 -
30,000 kg fish
during the year)




































N/A












Parameter Data
Sampling of sediment chemistry and
meiofauna started when the cages
were stocked and continued for six
months. After six weeks the
sediments were suboxic. Chemical
parameters included 2.3 to 8.2 ug/g
Chlorophyll-a at the control, and 1.3
to 15.4 ug/g Chlorophyll-a at the
cage. 1617 to 3 3 04 ug/g Proteins at
the control, and 1677 to 6740 ug/g
Proteins at the cage. 503 to 2814
ug/g sedimentary carbohydrates at
the control, and 628 to 5690 ug/g
sedimentary carbohydrates at the
cage. 33 1 to 2096 ug/g Lipids at the
control, and 848 to 3096 ug/g Lipids
at the cage. No significant
differences were found between
control and cage for biopolymeric
carbon. Redox potential
discontinuity (RPD) depth is the
depth at which sediment turns
brown to black. 1.4 to 2.9 cm RPD
at the control, and 0 to 1 . 1 cm RPD
at the cage. Meiofaunal organisms
were extracted from sediment cores.
Copepods and ostracods
significantly decreased in farm
sediments. Kinorhynchs were
extremely sensitive to farm reducing
sediments and disappeared almost
completely from the farms.
Polychaete densities were the same
at cages and controls. Nematodes
are usually tolerant of reducing
conditions in sediment, but did show
some effects at the farm sites. The
nematode to copepod ratio has been
used in the literature to detect
pollution. In this study, the ratio did
not reliably point to pollution effects
at either cage or control.
Water quality monitoring at Grassy
Bay site: 6 to 10 ug/1 total
phosphorus. Near the pens,
researchers observed 16 to 26 ug/1
total P in September, and 40 ug/1
total P in October. Anoxic
conditions in the hypolimnion can
result in the release of P from the
sediments. Historic P concentration
in that part of the lake is 5 ug/1 total
P.


Pollutant
benthic
degradation








































nutrients











E-7

-------
Table E5. Examples of Effluents from Ponds
Reference
Boyd et al. 2000.
Environmental
Assessment of Channel
Catfish Farming in
Alabama, Auburn
University, Department of
Fisheries and Allied
Aquaculture, Auburn, AL.




























Boyd, C.E. 1978.
Effluents from catfish
ponds during fish harvest.
Journal of Environmental
Quality 7(l):59-62.







Source
Category




































Primary











System
Ponds



































Ponds











Species
Catfish



































Catfish











Flow Or
Volume




































0.53 to 5.02 ha
with depths of
1.5 to 1.8m









Parameter Data
-Average effluent concentrations
during precipitation overflow
events: 0.12 mg/1 soluble reactive
P, 0.68 mg/1 total P, 0.86 mg/1
NO3-N, 1.20 mg/1 total ammonia
N, 3.42 mg/1 total N.
-Average effluent concentrations
during partial drawdown events:
0.01 mg/1 soluble reactive P,
0.25 mg/1 total P, 0.69 mg/1
NO3-N, 1.13 mg/1 total ammonia
N, 5. 68 mg/1 total N.
-Average effluent concentrations
during final pond drawdown:
0.06 mg/1 soluble reactive P, 1.59
mg/1 total P, 0.14 mg/1 NO3-N,
1.37 mg/1 total ammonia N, 9.58
mg/1 total N
-Average effluent concentrations
during precipitation overflow
events: 81 mg/1 TSS.
-Average effluent concentrations
during partial draw down events:
69 mg/1 TSS.
-Average effluent concentrations
during final pond draw down:
1027 mg/1 TSS
-Average effluent concentrations
during precipitation overflow
events: 11.0 mg/1.
-Average effluent concentrations
during partial draw down events:
9.42 mg/1 BOD5.
- Average effluent concentrations
during final pond draw down:
31.8mg/lBOD5
Mean effluent parameters during
seining phase of harvest (Over
half of the total settleable matter
and orthophosphate was lost
during the seining phase.):
59 ug/1 soluble orthophosphate,
0.49 mg/1 total P, 2.34 mg/1 total
NH3, 0.14 mg/1 NO3-N.

28.5-ml/l settleable matter

28.9 mg/1 BOD, 342 mg/1 COD
Pollutant

.
nu nen s

















solids







organic
enrichment













nutrients

solids

organic
enrichment
                                           E-8

-------
Reference
Huggett, D.B., D. Schlenk
andB.R. Griffin. 2001.
Toxicity of copper in an
oxic stream sediment
receiving aquaculture
effluent. Chemosphere 44:
361-367.






Schwartz, M.F., and C.E.
Boyd. 1994a. Channel
catfish pond effluents.
Prog. Fish Cult. 56: 273-
281.




Shireman, J.V., and C.E.
Cichra. 1994. Evaluation
of aquaculture effluents.
Aquaculture 123(1994):
55-68.




Source
Category
Primary








Primary




Primary




System
Ponds








Ponds




Ponds




Species
Catfish








Catfish




Catfish




Flow Or
Volume
Nine- 10,000
fish/ha ponds
were treated
with a total of
45 kg of
dispersed
copper over 3
years, drained
after harvest
into a nearby
stream






Unknown




0.4 hectare by
1.5 m deep =
6,000 m3(l
acre pond)




Parameter Data
Hyallea azteca and Typha
latifolia were exposed to
sediments collected upstream, at
outflow, and downstream from
catfish ponds medicated with
copper. No significant loss was
observed in the upstream or
outflow samples. H. azteca did
suffer significant mortality in the
downstream sample. However,
because copper levels in all 3
locations were similar to each
other and to those from ponds
where copper was not used, it
was determined the use of copper
in this study did not negatively
impact the receiving stream.
Bulk sediment copper
concentrations in the samples
were:
Upstream: 29 mg Cu/kg dry
weight
Outfall: 31 mg Cu/kg dry weight
Downstream: 25 mg Cu/kg dry
weight
-Production water values: 0 to
1.85 mg/1 total P, 0 to 0.074 mg/1
soluble reactive P, 0.58 to 14.04
mg/1 TKN, 0.008 to 8.071 mg/1
TAN, 0 to 6.661 mg/1 NO3-N.
-Production water values: 0 to 1.8
ml/1 settleable solids, 5.2 to 336.7
mg/1 suspended solids, 0.02 to
221.0 mg/1 volatile solids.
- Production water values: 1.9 to
35.54 mg/1 BOD5
At Schuler Fish Farm, production
water ranges:
0.050 to 0.350 mg/1 NH4-N,
0.030 to 0.280 mg/1 N03-N,
0.000 to 0.007 mg/1 NO2-N, 0.8
to 4.9 mg/1 Total N, 0. 148 to
0.238 mg/1 Total P
4.3 to 63.4 mg/1 TSS, 2.7 to 39.4
mg/1 VSS, 1.6 to 29.3 mg/1 FSS
4 to 16mg/lCBOD
1,400 to 160,000 number/lOOml
Fecal coliforms
Pollutant









nutrients
solids


organic
enrichment
nutrients

solids
organic
enrichment

(other)
E-9

-------
Reference
Tucker, C. S., S.K.
Kingsbury, J.W. Pole, and
C.L. Wax. 1996. Effects of
water management
practices on discharge of
nutrients and organic
matter from channel
catfish (Ictalurus
punctatus) ponds.


























Tucker, C.S. no date.
Quality of potential
effluents from channel
catfish culture ponds






Source
Category
Primary










































System
Ponds

































Ponds








Species
Catfish

































Catfish








Flow Or
Volume
Ponds
averaged 7 ha
in area and
1.25 m in
depth; water
was supplied
by wells
pumping from
an aquifer;
periodic
additions of
well water
were made to
replace
evaporation;
overflow
occurred only
during periods
of excessive
rainfall.
















Unknown, but
stocked at
17,000 fish/
ha






Parameter Data
Predicted discharge (kg ha" of
pond surface) of selected
parameters in overflow from
levee-type ponds, in an average
year, under two management
scenarios
(1) With no water storage
potential:
total nitrogen: Spring 14.7;
Summer 12.4; Autumn 15.2;
Winter 17.2 ;
total phosphorus: Spring 1.0;
Summer 0.9; Autumn 0.7; Winter
1.1;
chemical oxygen demand (as O?)
Spring 223; Summer 172;
Autumn 165; Winter 245;

biochemical oxygen demand (as
OjlSpring 45; Summer 41;
Autumn 25; Winter 42.
(2) With 7.5-cm water storage
potential:
total nitrogen: Spring 4.2;
Summer 1.0; Autumn 2.0; Winter
10.1;
total phosphorus: Spring 0.3;
Summer 0. 1; Autumn 0.2; Winter
0.7;
chemical oxygen demand (as O?)
Spring 64; Summer 14; Autumn
22; Winter 143;
biochemical oxygen demand (as
O?) Spring 13; Summer 3;
Autumn 3; Winter 25.
Production water values for
August:
3.9 to 9.9 mg/1 total N, 0.06 to
1.79 mg/1 total ammonia, 0 to
0.15 mg/1 NO3-N, 0 to 0.08 mg/1
NO2-N, 0.45 to 1.13 mg/1 total P,
0.01 to 0.06 mg/1 soluble
phosphorus.

64 to 200 mg/1 COD
Pollutant




































nutrients




organic
enrichment
E-10

-------

Reference
Tucker, C.S., and S.W.
Lloyd. 1985. Water
Quality in Streams and
Channel Catfish (Ictalurus
punctatus) Ponds in West-
Central Mississippi.
Technical Bulletin 129.
Mississippi Agricultural &
Forestry Experiment
Station, Mississippi.












Smydra, T.M. 1994.
Characterization and
effects of aquacultural
effluents from two Iowa
hatcheries. Master's
thesis, Iowa State
University, Ames, Iowa.



Tucker, C.S. 1998a.
Characterization and
Management of Effluents
from Aquaculture Ponds in
the Southeastern United
States. July 1998. SRAC
Final Project No. 600.
Southern Regional
Aquaculture Center.







Dierberg, F.E., and W.
Kiattisimkul. 1996.
Issues, impacts, and
implications of shrimp
aquaculture in Thailand.
Environ. Manage. 20(5):
649-666.




Source
Category
Secondary



















Primary









Gray















Foreign










System
Ponds



















Ponds









Ponds















Ponds










Species
Catfish



















Catfish,
Walleye,
Largemouth
Bass






Crawfish















Shrimp









Flow Or
Volume
pond volumes
20,000 to
80,000 m3,
stocked at
10,000 to
20,000 fish per
hectare













Unknown and
variable








2.2 to 23.6 ha
commercial
ponds













N/A










Parameter Data
-Mean production water values
for spring: 0.072 mg/1 soluble
reactive phosphorus, 0.560 mg/1
total P, 0.934 mg/1 total
ammonia, 0.053 mg/1 NO2-N +
NO3-N, 4.41 mg/1 total N.
-Mean production water values
for summer: 0.159 mg/1 soluble
reactive phosphorus, 0.855 mg/1
total P, 0.416 mg/1 total
ammonia, 0.235 mg/1 NO2-N +
N03-N, 5. 55 mg/1 total N.
-Mean production water values
for spring: 48 1 mg/1 total solids,
149 mg/1 total volatile solids.
-Mean production water values
for summer: 500 mg/1 total solids,
162 mg/1 total volatile solids.
-Mean production water values
for spring: 6 1 mg/1 COD.
-Mean production water values
for summer: 97 mg/1 COD
0. 10 to 0.49 kg/day soluble
reactive P, 0.13 to 0.41 kg/day
NO2-N, 0.29 to 1 1.68 kg/day
ammonia-N, 0.00 to 0.0378
kg/day un-ionized ammonia, 0.95
to 10. 11 kg/day Total N


22. 8 to 549.9 kg/day TSS
3.38 to 20. 1 1 kg/day CBOD5
Mean values for effluents during
draining period (Effluent quality
is poorest during the summer
drainage period. Ponds with
native vegetation generally have
lower concentrations of nutrients
and solids than ponds with rice or
sorghum-sudan grass):
0.139 mg/1 soluble reactive P,
0.6 14 mg/1 total P, 0.353 mg/1
total ammonia N, 0.009 mg/1
NO2-N, 0.040 mg/1 NO3-N.
607 mg/1 total solids, 109 mg/1
total volatile solids.
61.3 mg/1 COD, 11.6 mg/1 BOD

Effluent loading per 4 month
cycle from shrimp grow out
ponds stocked at 50-60 shrimp
per m2:
0.71 kg/ha N02-N, 2.7 kg/ha
N03-N, 18. 4 kg/ha TAN, 178
kg/ha total N, 2.0 kg/ha SRP,
15. 7 kg/ha total P
6,650 kg/ha TSS.

474 kg/ha BOD5.

Pollutant
nutrients

















organic
enrichment

nutrients






solids
organic
enrichment









nutrients



solids
organic
enrichment




nutrients

solids

organic
enrichment
E-ll

-------

Reference
Hopkins, J.S., C.L.
Browdy, R.D. Hamilton II,
and J.A. Heffernan III.
1995. The effect of low-
rate sand filtration and
modified feed
management on effluent
quality, pond water quality
and production of
intensive shrimp ponds.
Estuaries 18(1A): 116-
123.


Hopkins, J.S., J.D.
Holloway, P. A. Sandifer,
and C.L. Browdy. No
date. Results of Recent
Controlled Comparisons of
Intensive Shrimp Ponds
Operated With and
Without Water Exchange.
Waddell Mariculture
Center, Bluffton, South
Carolina.

Lopez-Ivich, M.A. 1996.
Characterization of
effluents from three
commercial aquaculture
facilities in South Texas.
Master's thesis, Texas
A&M University, Corpus
Christi, Texas.




























Source
Category
Primary








Gray









Primary



































System
Ponds








Ponds









Ponds



































Species
Shrimp








Shrimp









Shrimp


































Flow Or
Volume
1300 m3
ponds, one
pond had 5%
daily water
exchange




0.25 ha lined
ponds, 1.3 to
1.5 m deep
(about 3,500
m3) that did
not use water
exchange




Taiwan
Shrimp
Village,
sampling point
TV3 (located
at the end of
the discharge
canal running
along eastern
border of
facility) -
63,961 m3/day


Harlington
Shrimp Farm
sampling point
H2 (located
before the last
gate of the
farm's

discharge
canal) -
193,562
m3/day

Southern Star
Farm sampling
point SS2
(located in
front of the
last gate of the
farm's
discharge
canal) - 12,748
m3/day

Parameter Data
Effluent from daily water
exchange passed through a sand
filter before discharge:
0.08 to 2.86 mg/1 TAN, <0.01 to
0.65 mg/1 NO2-N, <0.01 to 0.06
mg/1 N03-N, 0.07 to 0.90 mg/1
reactive orthophosphate, 0.5 to
2.9 mg/1 Total P, 2.8 to 15.9 mg/1
Kjeldahl N, <0.1 to 19.5 mg/1
dissolved Kjeldahl N
18 to 347 mg/1 suspended solids,
14 to 143 mg/1 volatile solids
5. 7 to 43.0 mg/1
Feeding at 136 kg/ha feed per day
with a 20% protein feed,
production water values were:
0.2 mg/1 TAN, 2.8 mg/1 NO3-N,
0.3 mg/1 NO2-N, 4.0 mg/1 TKN,
1. 2 mg/1 Total P, 0.4 mg/1
Reactive orthophosphate
93.3 mg/1 TSS, 46.2 mg/1 organic
suspended solids
15.7 mg/1 BOD, 16.5 mg/1 total
organic carbon.
-TV3 effluent sampling point:
1.14 mg/1 NH4-N, 0. 23 mg/1 NO2-
N, 0.45 mg/1 NO3-N, 0.45 mg/1
Total P, 0.23 mg/1 Total reactive
P
-H2 effluent sampling point: 0.04
mg/1 NH4-N, 0.01 mg/1 NO2-N,
0.65 mg/1 NO3-N, 0. 15 mg/1 Total
P, 0.01 mg/1 Total reactive P
-SS2 effluent sampling point:
0.44 mg/1 NH4-N, 0. 12 mg/1 NO2-
N, 0.34 mg/1 NO3-N, 0.34 mg/1
Total P, 0. 1 1 mg/1 Total reactive
P
-TV3 effluent sampling point:
99.46 mg/1 TSS, 0.29 ml/1
settleable solids

-H2 effluent sampling point:
95.08 mg/1 TSS, 0.14 ml/1
settleable solids

-SS2 effluent sampling point:
71. 46 mg/1 TSS, 0.12 ml/1
settleable solids
-TV3 effluent sampling point:
3.56mg/lCBOD5
H2 effluent sampling point: 9.16
mg/1 CBOD5
SS2 effluent sampling point: 3.93
mg/1 CBOD5






Pollutant




nutrients

solids
organic
enrichment



nutrients


solids
organic
enrichment

nutrients













solids










organic
enrichment








E-12

-------

Reference
Martin, J., Y. Veran, O.
Guelorget, and D. Pham.
1998. Shrimp rearing:
Stocking density, growth,
impact on sediment, waste
output and their
relationships studied
through the nitrogen.
Aquaculture.
164(1998): 135-149.

Samocha, T.M., and A.L.
Lawrence. 1995. Shrimp
farms' effluent waters:
environmental impact and
potential treatment
methods. Water Effluent
and Quality, With Special
Emphasis on Finfish and
Shrimp Aquaculture.
U.S. -Japan Cooperative
Program in Natural
Resources, Corpus Christi,
Texas.
Teichert-Coddington,
D.R., D.B. Rouse, A.
Potts, and C.E. Boyd.
1999. Treatment of
Harvest Discharge from
Intensive Shrimp Ponds by
Settling. Aquacult. Eng.
19(1999): 147-161.





Source
Category
Foreign










Gray







Primary













System
Ponds










Ponds







Ponds













Species
Shrimp










Shrimp







Shrimp












Flow Or
Volume
ponds 1370 to
1520m2 by 1.3
m deep, with
10% daily
water
exchange





378,540
m3/day
permitted
average
discharge flow





888 m3, during
last month of
culture, 25 to
30 percent of
water
exchanged per
week







Parameter Data
Data from shrimp pond stocked
at 15 shrimp per m : 1460 m
pond area, 79.0 percent survival
area, 19.9 g final body weight,
346 kg final biomass, 546.5 kg
total feed, 1.58FCR: 0.10 to
0.74 mg/1 nitrogen, 10.5 +/- 6.0
ug/1 NH4-N, 2.7 +1-6.6 ug/1 NO2-
N + NO3-N, 127.7 +/- 40.7 ug/1
organic N, 72 to 240 ug/1 total
soluble N.
Effluent from main discharge to
county canal:
0.39 to 0.66 mg/1 total P, 0.15 to
0.37 mg/1 reactive P, 0 to 7 mg/1
NH3-N.

58 to 203 mg/1 TSS. Effluent
from one pond while draining for
harvest: 41 to 652 mg/1 TSS, and
37 to 49 mg/1 VSS.

1.7to5.0mg/lCBOD5.
During draining, mean values for
effluent when pond is drained
from full capacity to empty:
0.53 to 1.67 mg/L Total P, 1.57
to 4.15 mg/1 Total N, 0.59 to 2.40
mg/1 TAN


0.4 21.5 ml/1 settleable solids,
181 to 2788 mg/1 total solids, 88
to 563 mg/1 volatile solids.

30.6 to 44.3 mg/1 BOD

Pollutant
nutrients












nutrients
...
solids


organic
enrichment




nutrients



solids


organic
enrichment
E-13

-------

Reference
Ziemann, D.A. 1991.
Effluent Mixing Zones -
Theory and Practice


































Tucker, C.S. 1998a.
Characterization and
Management of Effluents
from Aquaculture Ponds in
the Southeastern United
States. July 1998. SRAC
Final Project No. 600.
Southern Regional
Aquaculture Center.

Seok, K., S. Leonard, C.E.
Boyd, and M.F. Schwartz.
1995. Water quality in
annually drained and
undrained channel catfish
ponds over a three-year
period. The Progressive
Fish-Culturist 57:52-58.



Source
Category
Gray




































Gray





Primary










System
Ponds




































Ponds,
Freshwater
And
Saltwater




Ponds,
Levee









Species
Shrimp




































Hybrid
Striped Bass




Catfish









Flow Or
Volume
Pacific Sea
Farms - 2. 7 to
4.5 mgd


Oceanic
Institute -
0.032 to 0.058
mgd




























Commercial
ponds of
unknown size




400 to 600 m2
with average
depth 1m is
about 400 to
600 m3 (about
1/10 acre
pond)





Parameter Data
-Pacific Sea Farms effluent: 90 to
330 ug/1 N03-N + N02-N, 150 to
1280 ug/1 NH4-N, 1 1 10 to 3930
ug/1 Total N, 270 to 1030 ug/1
Total P. Loadings Pacific Sea
Farms effluent: 2. 7 to 4.5 mgd
flow, 0.9 to 5 kg/day NO3-N +
N02-N, 1.5 to 20.4 kg/day NH4-
N, 17.6 to 61 kg/day Total N, 2.8
to 13.6 kg/day Total P.
-Oceanic Institute effluent: 0 to
548 ug/1 NO3-N + NO2-N, 3 to
1534 ug/1 NH4-N, 80 to 3055 ug/1
Total N, 15 to 712 ug/1 Total P.
Loadings Oceanic Institute
effluent: 0.032 to 0.058 mgd
flow, 0.000 to 0.100 kg/day NO3-
N + NO2-N, 0.001 to 0.277
kg/day NFLt-N, 0.020 to 0.600
kg/day Total N, 0.003 to 0. 140
kg/day Total P.
- Pacific Sea Farms effluent: 16
to 36 mg/1 TSS. Loadings Pacific
Sea Farms effluent: 197 to 565
kg/day TSS.
-Oceanic Institute effluent: 13 to
102 mg/1 TSS. Loadings Oceanic
Institute effluent: 2.8 to 17
kg/day TSS.
- Pacific Sea Farms effluent: 4 to
10 mg/1 BOD. Loadings Pacific
Sea Farms effluent 63 to 157
kg/day BOD.
-Oceanic Institute effluent: 7 to
1 5 mg/1 BOD. Loadings Oceanic
Institute effluent: 1.1 to 2.8
kg/day BOD.
Production water mean values
7.1 mg/1 Kjeldahl Nitrogen, 0.95
mg/1 total ammonia, 0.07 mg/1
NO2-N, 0.36 mg/1 NO3-N, 0.31
mg/1 total P, 0.02 mg/1 soluble
reactive P.
49 mg/1 suspended solids, 29
mg/1 volatile suspended solids.
11. 5 mg/1 BOD.
Ranges for effluents from
draining ponds during October
harvest:
1.65 to 14.45 mg/1 Kjeldahl
nitrogen, 0.3 4 to 3.70 mg/1 TAN,
0.004 to 0.065 mg/1 NO3-N.
0.007 to 0.17 mg/1 NO2-N, 0.231
to 3.302 mg/1 Total P
47 to 1948 mg/1 TSS, 1.1 to 10.0
ml/1 settleable solids.
30.0 to 54.4 mg/1 BOD.

Pollutant
nutrients




















solids







organic
enrichment







nutrients


solids
organic
enrichment




nutrients


.
solids

organic
enrichment
E-14

-------

Reference
Boyd, C.E. and T.
Dhendup. 1995. Quality of
Potential Effluents from
the Hypolimnia of
Watershed Ponds Used in
Aquaculture. The
Progressive Fish-Culturist
57:59-63. 1995.
Schwartz, M.F., and C.E.
Boyd. 1994b. Effluent
quality during harvest of
channel catfish from
watershed ponds. The
Progressive Fish Culturist
56:25-32.













Source
Category







Primary

















System
Ponds,
Watershed





Ponds,
Watershed
















Species
Catfish






Catfish
















Flow Or
Volume
9,400 to
66,900 m3
pond volume




0.92 to 1.32
hectare by
1.37 to 1.73m
deep, (ballpark
18,000m3)















Parameter Data
Measurements taken July to
September,
-TAN 0.34 to 3.59 mg/1; NO2-N
0.0 to 0.15 mg/1

-BOD5 8.5 to 20.6 mg/1


Effluent loadings discharged per
hectare of pond:
2.95 kg/ha TAN, 77.8 kg/ha
TKN, 0.03 kg/ha NO2-N, 3.95
kg/ha N03-N, 0. 17 kg/ha soluble
reactive P, 3.23 kg/ha Total P.
Loadings discharged per metric
ton (MT) offish in pond: 0.74
kg/MT TAN, 18.6 kg/MT TKN,
0.01 kg/MT NO2-N, 0.95 kg/MT
N03-N, 0.04 kg/MT soluble
reactive P, 0.78 kg/MT Total P
9,362 kg/ha settleable solids.
Loadings discharged per metric
ton (MT) offish in pond: 2,302
kg/MT settleable solids.
164 kg/ha BOD. Loadings
discharged per metric ton (MT)
offish in pond: 39.3 kg/MT
BOD.

Pollutant


nutrients
organic
enrichment




nutrients







SO 1 S


organic
enrichment


Additional Literature for Review

Alanara, A., Bergheim, A., Cripps, S.J., Eliassen, R., Kristiansen., 1994. An integrated approach
to aquaculture wastewater management. J. Appl. Ichthyol. 10, 389.

Bergheim, A., Dsgard, T., 1996. Waste production from aquaculture. In: Baird, D.J., Beveridge,
M.C.M., Kelly, L.A., Muir, J.F. (Eds.), Aquaculture and Water Resource Management.
Blackwell, Oxford, pp. 50-80.

Beveridge, M.C.M., Phillips, M.J. and Clarke, R.M., 1991. A quantitative and qualitative
assessment of wastes from aquatic animal production. In: D.E. Brune and J.R. Tomasso (Editors),
Aquaculture and Water Quality. World Aquaculture Society, Baton Rouge, LA. pp. 506 - 533.

Boaventura,  R., A.M. Pedro,  S. Coimbra and E. Lencastre. 1997. Trout farm effluents:
characterization and impact on the receiving streams. Environmental Pollution. 95(3): 379 - 387.

Boersen, G., Westers, H., 1986. Waste solids control in hatchery raceways. Prog. Fish. Cult.
48, 151-154.

Boyd, C. E. 2000. Shrimp farm effluent during draining for harvest. Global Aquaculture
Advocate, 3(4): 26 -27.

Costa-Pierce, B.A., 1996. Environmental impacts of nutrients from aquaculture: towards the
                                          E-15

-------
evolution of sustainable aquaculture systems: In: Baird, D.J., Beveridge, M.C.M., Kelly, L.A.,
Muir, J.F. (Eds.), Aquaculture and Water Resource Management. Blackwell, Oxford, pp. 81-113.

Cripps, S.J., Kelly, L.A., 1996. Reductions in wastes from Aquaculture. In Baird, D.J.,
Beveridge, M.C.M., Kelly, L.A., Muir, J.F. (Eds.), Aquaculture and Water Resource
Management. Blackwell, Oxford, pp. 166-201.

Einen, O., Holmefjord, I., Dsgard, T., Talbot, C., 1995. Auditing nutrient discharges from fish
farms: theoretical and practical considerations. Aquacult. Res. 26, 701 - 713.

Enell, M., Lof, J., 1983. Environmental impact of aquaculture: sediment and nutrient loadings
from fish cage culture farming. Vatten 39, 364 - 375.

Gowen, R.J. & Bradbury, N.B. 1987. The ecological impact of salmonid farming in coastal
waters: a review. Oceanogr. Mar. Biol. Ann. Rev. 25: 563 - 575.

Handy, R.D. and M.G. Poxton. 1993. Nitrogen pollution in mariculture: toxicity and excretion of
nitrogenous compounds by marine fish. Rev. Fish Biol. Fish. 3: 205 - 241.

Heinen, J.M., J.A. Hankins and P.R. Adler. 1996. Water quality and waste production in a
recirculating trout-culture system with feeding of a higher-energy or lower-energy diet. Aquat.
Res. 27: 699-710.

Jory, D.E. 1997. Status of marine shrimp farming. Aquaculture Magazine 26: 39 - 46.

Muir, J. F., 1982. Recirculated water systems in aquaculture. In:  J.F. Muir and R.J. Roberts
(Editors), Recent Advances in Aquaculture. Westview Press, Boulder, CO, pp. 357 - 447.

Screenivasan A. 1995. Pollution  from industrial shrimp culture: A serious environmental threat.
Fish. Chimes. 15(5): 19-20.

Steward, J.E.  1997. Environmental Effects of Aquaculture. World Aquacult. 28 (1): 47 - 52.

Summerfelt, S.T., 1998. An integrated approach to aquaculture waste management in flowing
water systems. In: Libey, G.S., Timmons, M.B. (Eds.), Proceedings of the Second international
Conference on Recirculating Aquaculture, 16 - 19 July 1998, Roanoke, USA, pp. 87 - 97.

Tomasso, J.R., ed. 2002. Aquaculture and the Environment in the United States. U.S.
Aquaculture Society, a Chapter of the World Aquaculture Society, Baton Rouge, Louisiana.

Tovar, A., Moreno, C., Manuel-Vez, M.P. and Garcia-Vargas, M. 2000. Environmental impacts
of intensive aquaculture in marine waters. Water Research 34(1): 334 - 342.

Uhlmann, D., 1979. BOD removal rates of waste stabilization ponds as a function of loading,
retention time, temperature and hydraulic pattern. Water Res., 13: 193 - 200.

Williams, M.J. In: J.E. Bardach (Ed.),  Sustainable Aquaculture, J.E. Bardach, Ed. (Wiley, New
York, 1997), pp.  15-51; R.J. Goldburg and T. Triplett, Murky Waters: Environmental Effects of
Aquaculture in the United States (Environmental Defense Fund, New York, 1997).
                                          E-16

-------
Wu, R.S.S. 1995. The environmental impact of marine fish culture: towards a sustainable future.
Mar.Pollut.BuU.31,4-12.
                                         E-17

-------
                                     Appendix F
                   Water Quality Standards and Nutrient Criteria
F.I    NUTRIENT CRITERIA

       Tables F-l and F-2 summarize nutrient criteria for total nitrogen and total phosphorus,
water quality criteria for ammonia and dissolved oxygen, and guidelines for BOD and solids.
EPA has developed criteria for each of the aggregate nutrient ecoregions for total phosphorus,
total nitrogen, chlorophyll a, and turbidity. Criteria for these different parameters are presented
for rivers/streams and lakes/reservoirs for each ecoregion in Tables F-l and F-2, respectively. A
range has also been included in these tables to present the minimum and maximum values for each
parameter.
                                          F-l

-------
                                                    Table F-l

                            Nutrient Criteria for Rivers and Streams by Ecoregion

Parameter
TP//g/L
TNmg/L
Ecoregions for Rivers & Streams
1
47.00
0.31
2
10.00
0.12
3
21.88
0.38
4
23.00
0.56
5
67.00
0.88
6
76.25
2.18
7
33.00
0.54
8
10.00
0.38
9
36.56
0.70
10
128*
0.76
77
10.00
0.31
12
40.00
0.90
7¥
31.25
0.71
Range
10.00- 128
0.12-2.18
Source: USEPA, 2000b. (Updated table from USEPA, 2002.)
Note: *This value appears inordinately high and may either be a statistical anomaly or reflects a unique conditions. In any case, further regional
investigation is indicated to determine the sources, i.e., measurement error, notational error, statistical error, statistical anomaly, natural enriched
conditions, or cultural impacts.
                                                    Table F-2
                           Nutrient Criteria for Lakes and Reservoirs by Ecoregion

Parameter
TP//g/L
TNmg/L
Ecoregions for Lakes & Reservoirs
2
8.75
0.10
3
17.00
0.40
4
20.00
0.44
5
33.00
0.56
6
37.5
1.68
7
14.75
0.66
8
8.00
0.24
9
20.00
0.36
77
8.00
0.46
12
10.00
0.52
13
17.50
1.27
14
8.00
0.32
Range
8.00-37.50
0.10- 1.68
  Source: USEPA, 2000b. (Updated table from USEPA, 2002.)
                                                       F-2

-------
F.2     AMMONIA CRITERIA

        Water quality criteria for ammonia are expressed as the Criteria Maximum Concentration (CMC
or acute criterion) and the Criteria Continuous Concentration (CCC or chronic criterion). These values,
which were finalized by EPA in 1999, are intended to be protective to aquatic life.  The CMC and CCC are
expressed in terms of milligrams ammonia nitrogen per liter (mg N/L) and they vary with pH. For the
CMC, based on differences in species acute sensitivity, different CMC values were derived for waters
where salmonids (e.g., trout and salmon) are present and waters where salmonids are not present. For the
CCC, no substantial differences between salmonid and non-salmonid chronic sensitivity were apparent and
consequently, the CCC does not vary with the type offish present.  Criteria concentrations for a few
example pH values are shown in Table F-3. Refer to the 7999 Update of Ambient Water Quality Criteria
for Ammonia for the computational formula and for other example pH values between 6.5 and 9.0
(USEPA, 1999).

                                           Table F-3
                     CMC and CCC (mg N/L) at a Few Example pH Values
PH
6.5
7.0
7.5
8.0
8.5
9.0
CMC
(salmonids present)
32.5
24.0
13.3
5.60
2.13
0.88
CMC
(salmonids absent)
48.8
36.1
19.9
8.40
3.20
1.32
CCC
3.48
3.08
2.28
1.27
0.57
0.25
 Source: USEPA, 1999.
F.3     DISSOLVED OXYGEN CRITERIA

        National criteria for ambient dissolved oxygen concentrations for the protection of freshwater
aquatic life are presented in Table F-4.  The criteria are derived from production impairment estimates
found in the criteria document, which are based on growth data and information on temperature, disease,
                                             F-3

-------
and pollutant stresses. Each criterion may be viewed as an estimate of the threshold concentration below

which detrimental effects are expected (USEPA, 1986).


        Criteria for coldwater fish are intended to apply to waters containing species of the family

Salmonidae or other coldwater or coolwater fish deemed by the user to be closer to salmonids in sensitivity
than to most warmwater species.  The criteria for warmwater fish are necessary for protecting early life

stages of warmwater fish as sensitive as channel catfish and to protect other life stages offish as sensitive
as largemouth bass (USEPA,  1986).
                                            Table F-4

               Water Quality Criteria for Ambient Dissolved Oxygen Concentration


30 Day Mean (mg/L)
7 Day Mean (mg/L)
7 Day Mean Minimum (mg/L)
1 Day Minimum4'5 (mg/L)
Coldwater Criteria
Early Life
Stages1'2
n/a3
9.5 (6.5)
n/a
8.0(5.0)
Other Life
Stages
6.5
n/a
5.0
4.0
Warmwater Criteria
Early Life
Stages2
n/a
6.0
n/a
5.0
Other Life
Stages
5.5
n/a
4.0
3.0
1 These are water column concentrations recommended to achieve the required intergravel DO
concentrations shown in parentheses.  The 3-mg/L differential is discussed in the criteria document.  For
species that have early life stages exposed directly to the water column, the figures in parentheses apply.
2 Includes all embryonic and larval stages and all juvenile forms to 30-days following hatching.
3 n/a = not applicable.
4 For highly manipulatable discharges, further restrictions apply (see page 37 of the dissolved oxygen
criteria document).
5 All minima should be considered as instantaneous concentrations to be achieved at all times.
Source: USEPA, 1986.
F.4     BIOCHEMICAL OXYGEN DEMAND


        There are no national in-stream criteria for BOD. However, ambient levels for BOD vary by

state. EPA has established effluent limitations guidelines for discharges such as wastewater treatment

plants. These guidelines are based on the ability of technologies to economically and effectively remove
                                               F-4

-------
BOD from waste streams, which can vary depending on location and site-specific considerations.  In any
case, minimum secondary treatment effluent concentration limits for BOD5 have been established for
wastewater treatment plants. The average value during a 30-day period shall not exceed 30 mg/L and the
average 7-day value shall not exceed 45 mg/L (USEPA, 2000a).

        Furthermore, BOD (together with dissolved oxygen (DO), fecal coliforms (FC), and total
suspended solids (TSS)) has been used as an indicator of the recreational use value of a water body.
Changes in the recreational use value of a water body, as indicated by changing values of BOD, DO, FC,
and TSS, can then be monetized (USEPA, 2001).
F.5     SOLIDS1

        There are no national water quality criteria for solids.  However, many AAP facilities with NPDES
permits must control and monitor their discharge levels of solids.  In Idaho for example, NPDES permits
specify a maximum average of 0.1 mL/L for settleable solids and 5 mg/L for total suspended solids (IDEQ,
n.d.).  According to the U.S. Army Corps of Engineers Fisheries Handbook, streams with silt loads (e.g.,
settleable solids) averaging between 80 and 4,000 mg/L should not be considered good areas for supporting
fresh water fisheries. Additionally, streams with less than 25 mg/L may be expected to support good fresh
water fisheries (Bell, 1986).  High turbidity can also prove fatal to fish.  Fatal turbidity levels for various
fish species are presented in Table F-5.
 1 Total suspended solids are the suspended solids in wastewater, effluent, or water bodies, determined by tests for
 "total suspended non-filterable solids."  Settleable solids include material heavy enough to sink to the bottom of a
 wastewater treatment tank.  Silt is sedimentary material composed of fine or intermediate-sized mineral particles.
 Sediment is defined as soil, sand, and minerals washed from land into water, usually after rain (USEPA, 1998).
                                               F-5

-------
                                          Table F-5
                         Turbidity Levels Fatal to Various Fish Species
Common name of fish
Golden shiner
Mosquito fish
Goldfish
Green sunfish
Black bullhead
Red Shiner
River carpsucker
Largemouth bass
Pumpkinseed
Orangespotted sunfish
Channel catfish
Blackstrip top-minnow
Black crappie
Rock bass
Range of
temperature
(°Q
20-29
20-28
24-32
20-29
22-32
22-32
24-32
16-32
16-22
22-32
24-32
22-26
28-29
—
Average
time of test
(days)
7.1
16.5
12.0
5.5
17.0
9.0
9.6
7.6
13.0
10.0
9.3
19.3
2.0
3.5
Fatal turbidity in mg/L
Minimum
55,000
120,000
90,000
50,000
175,000
175,000
105,000
52,000
16,500
100,000
—
—
—
—
Average
166,000
181,500
197,000
166,500
222,000
183,000
165,000
101,000
69,000
157,000
85,000
175,000
145,000
38,250
Maximum
200,000
225,000
270,000
225,000
270,000
190,000
250,000
150,000
120,000
200,000
—
—
—
—
Note: 1 ppm is assumed to equal 1 mg/L.
Source: U.S. Army Corps of Engineers Fisheries Handbook. Bell, 1986.
F.6    REFERENCES
Bell, M. C. 1986. Fisheries Handbook of Engineering Requirements and Biological Criteria.  U.S. Army
Corps of Engineers, Fish Passage Development and Evaluation Program.

IDEQ (Idaho Division of Environmental Quality). N.d. Idaho Waste Management Guidelines for
Aquaculture Operations. Idaho Division of Environmental Quality, Boise, ID.
. Accessed December 2001.
                                             F-6

-------
USEPA (U.S. Environmental Protection Agency). 1986. Ambient Water Quality Criteria for Dissolved
Oxygen. EPA 440-5-86-003. U.S. Environmental Protection Agency, Office of Water, Washington, DC.

USEPA (U.S. Environmental Protection Agency). 1998. Terms of the Environment: B. U.S.
Environmental Protection Agency. . Accessed December
2001.

USEPA (U.S. Environmental Protection Agency). 1999. 7999 Update of Ambient Water Quality Criteria
for Ammonia. EPA 822-R-99-014. U.S Environmental Protection Agency, Office of Water, Washington,
DC. . Accessed February 2002.

USEPA (U.S. Environmental Protection Agency). 2000a. Progress in Water Quality: An Evaluation of the
National Investment in Municipal Wastewater Treatment. EPA-832-R-00-008. U.S. Environmental
Protection Agency .  Accessed February 2002.

USEPA (U.S. Environmental Protection Agency). 2000b. Summary Table for the Nutrient Criteria
Documents. U.S. Environmental Protection Agency, Office of Water, Washington, DC.
. Accessed February 2002.

USEPA (U.S. Environmental Protection Agency). 2001. Environmental and Economic Benefit Analysis of
Proposed Revisions to the National Pollutant Discharge Elimination System Regulation and the Effluent
Guidelines for Concentrated Animal Feeding Operations. EPA-821-R-01-002. U.S. Environmental
Protection Agency, Office of Water, Washington, DC.

USEPA (U.S. Environmental Protection Agency). 2002. Summary Table for the Nutrient Criteria
Documents. U.S. Environmental Protection Agency, Office of Water, Washington, DC.
. Accessed May 2002.
                                             F-7

-------
                                         Appendix G
        Water Quality and Flow Data from Selected Streamgage Stations in NC

EPA performed a detailed analysis of stream pollutant background concentrations for several watersheds in
Western North Carolina to assess the appropriateness of the water quality modeling assumptions.
Specifically, EPA determined whether the ranges of stream background concentrations used in the
prototype model account for a variety of other feasible watershed conditions, such as varying levels of
population, land uses, and point sources, that might exist for the watersheds of streams on which
concentrated aquatic animal production (CAAP) facilities might be located. Eight watersheds in the
Western North Carolina area were selected for review of in-stream water quality monitoring information
during 1995-1997.  These  watersheds were chosen because they contained at least one CAAP facility that
reported to PCS. All of the dischargers reporting in PCS within each of the eight watersheds were also
summarized according to type of SIC code. EPA reviewed land use data for these watersheds to determine
the presence of water quality monitoring  stations located in urban areas, forested, and agricultural areas. A
map of the analyzed watersheds is provided in Figure G-l.
                                              G-l

-------
                                          Figure G-l
                         Location of Water Quality Monitoring Stations

                     Location of Water Quality Monitoring Stations
          •   WQ Monitoring Station
            J State Boundaries
            • Watershed Boundaries
EPA selected representative water quality parameters, including BOD5, total suspended solids, ammonia,
dissolved phosphorus, and dissolved oxygen to compare actual watershed conditions with model stream
background conditions. EPAfound 8 6 water quality monitoring stations in these watersheds for the statistical
analysis.

EPA performed a statistical analysis of the available data from the 86 water quality stations to obtain a range
of concentrations to compare to the original stream background concentrations used in the prototype model.
Each of the five parameters was analyzed in the same manner, with the weighted mean, standard deviation of
the weighted mean, and the minimum and maximum concentrations calculated for each.

Every station reported the number of samples taken  (i.e., the number of observations) and the  mean
concentration of those observations.  The number of observations differs for each station; some stations
                                             G-2

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reported the average concentration  from two observations while  other stations monitored their  streams
continuously, resulting in a much larger number of observations. Because the means are based upon different
numbers of observations, the weighted mean was calculated for each station. The weighted mean varies the
contribution of an individual station's mean value proportionally according to the number of sample points that
make up the individual station mean.  Thus, a station mean value with 10 observations carries less weight than
a station with several hundred observations.

EPA calculated the weighted means by multiplying the station's mean by the number of observations that the
respective station recorded.  These values were then added together  for all of the stations that reported data;
and lastly, the resulting value was divided by the total number of observations for the particular parameter,
thereby producing the weighted mean.  The standard deviation for the weighted mean was also calculated in
order to better understand the spread of the data for each parameter.  Finally, the range (minimum and
maximum values) of the mean concentrations reported by the stations was found for each parameter.  This
range was then used to support the range that was used for modeling purposes.

The results of the statistical analysis are available in Table G-l, along with the original stream background
concentrations used in the  prototype model.  The results  show that the weighted means for the stream
observations fall within the range of values used in the water quality modeling for BOD5, ammonia, and
dissolved phosphorus. The range of in-stream BOD values falls within the range of values used in the water
quality modeling. The range of in-stream ammonia values is wider than the water quality modeling values.
The range of in-stream phosphorus values falls within the range of values used in the modeling. The weighted
mean for TSS was lower than the range of values for the prototype case study stream.  However, the range of
values for the case study stream was narrower than the range of the monitored streams for TSS.  The value
for dissolved oxygen used in the modeling fell within the range of in-stream values and was slightly greater than
the weighted mean value.
                                               G-3

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                                          Table G-l
                           Comparison of Background Concentrations

Range used to represent
background flows in
prototype case study stream
BOD5
(mg/L)
0.4-3.86
TSS
(mg/L)
15-45
NH3
(mg N/L)
0.04-0.28
Dissolved P
(mg P/L)
0.001-0.159
DO
(mg/L)
6.63
Water Quality Station Analysis (from eight watersheds)
No. of Water Quality
Stations
Total No. of Observations
Weighted Mean
Standard Deviation of
Weighted Means
Parameter Range
(Min and Max)
6
149
1.970
0.701
1.343- 1.636
39
1,094
12.903
12.764
0.300-64.918
39
1,160
0.118
0.315
0.014- 1.789
2
15
0.051
0.346
0.0412-0.087
69
61,803
5.711
3.221
3.629 -
10.584
       To assess the stream flow characteristics of the model system, USGS stream flow gages located in
eight watersheds in the North Carolina mountains were reviewed. These watersheds are the same ones used
in the analysis of stream background concentrations.  A map of the analyzed watersheds and tributaries is
provided in Figure G-2 below. AAP facilities identified in BASINS were present in these watersheds and are
located primarily on tributaries of the RF1 stream coverage. Therefore, all USGS stream gages located on
tributaries, or starting stream reaches of RF1, were selected from the collection of gages under review. The
stream gages were checked to assure locations below lakes were not included, since such obstructions to the
natural stream flow would affect results from the analysis. Two additional gages were removed from analysis
because of location at a main stem river reach juncture with a tributary.  Of the remaining 29 stream gages,
the 7Q10 flows ranged from 0.71 to 43.20 cubic feet per second (cfs) and the mean flow ranged from 10.62
to 285.48 cfs. The same stream gages were also reviewed for summer flow, which is considered as July 1
through September 30 for this analysis. Of the original 29 stream gages, 28 gages provided values for summer
flow.  The resulting  average summer flow was 58.96 cfs.  A summary of the flow data, including ranges,
means, and standard deviations, is provided in Table G-2.
                                             G-4

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                                Table G-2
                          Summary of Flow Data
Flows
7Q10Flow(cfs)
Mean Flow (cfs)
Summer Flow (cfs)
Minimum
0.71
10.62
5.14
Maximum
43.20
285.48
192.72
Mean
14.1
94.43
58.96
Standard
Deviation
11.42
66.71
40.38
                               Figure G-2

                         Location of USGS Gages
                      Location of USGS Gages
  *   Uses Gage
  *   AAP facilities
     Tributaries
     RF1 rivers
   ] Stifle Boundaries
|    | Watershed Boundaries
                                   G-5

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                                      Appendix H
          Method for Converting Model Facility Pollutant Loads
                          into Effluent Concentrations
H.1    GENERAL EQUATION

Pollutant loads, in units of pounds per year (Ib/yr), are calculated by EPA's engineering models (see
USEPA, 2002, Chapter 10). These may in turn be converted into effluent concentrations by dividing the
annual mass load by the annual flow volume from a particular model facility. Facility flow rates in units of
gallons per minute (gal/min) are also available from EPA's engineering analysis (see USEPA, 2002,
Chapter 10).  That is,
                           LoadX(lb I yf) x 453,000mg I Ib
 [Pollutant X](mg/L)=                 y           S
                    Flow(ga/ / min) x 3.785Z / gal x 525,600 min/ yr
where  /Pollutant^/ = the concentration of the pollutant of concern (mg/L)
       LoadA"= the annual mass load of Pollutant X (Ib/yr)
       Flow = the flow rate of the model facility under consideration (gal/min)
H.2    EXAMPLE CALCULATIONS

The calculation, using the above equation, for the "raw" (i.e., in the absence of treatment) effluent scenario
for medium trout stacker flow-through systems is provided as an example below. The BOD5 load of
108,228 Ib/yr for this model facility was calculated by EPA as described in the CAAP Development
Document. The effluent flow rate of 2,208.7 gal/min was also determined as described in the CAAP
Development Document.
                                          H-l

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 m^ci _       108,228 Ib/yr BODS * 453,600 mg/lb
 [BOD5J —
           2,208.7 gal/min * 3.785 L/gal * 525,600 min/yr
       [BOD5] = 11.172 mg/L for "raw" effluent from a medium trout stacker flow-through system


A second example for the Option I/Option 2 load for "large" striped bass recirculating systems is provided
as an example below.
                590,400 lb/ Yr BOD * 453,600 mg / Ib
     JjUL) j  — 	
             123,000 gal / day * 3.785 L / g * 365 day / yr
       [BOD5] = 1,575.3 mg/L for large striped bass recirculating systems under Option I/Option 2
H.3    REFERENCE
USEPA (U.S. Environmental Protection Agency).  2002.  Development Document for Proposed Effluent
Limitations Guidelines and Standards for the Concentrated Aquatic Animal Production Industry Point
Source Category.  U.S. Environmental Protection Agency.  EPA-821-R-02-016.
                                             H-2

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