&EPA
United States
Environmental Protection
Agency
Benefits Analysis for the
Final Section 316(b) Existing
Facilities Rule
EPA-821 -R-14-005
May 2014
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U.S. Environmental Protection Agency
Office of Water (4303T)
1200 Pennsylvania Avenue, NW
Washington, DC 20460
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Table of Contents
Table of Contents
1 Introduction 1-1
1.1 Summary of the Final Rule and Other Options Considered 1-2
1.2 Study Design 1-3
1.2.1 Coastal Regions 1-4
1.2.2 Great Lakes Region 1-5
1.2.3 Inland Region 1-5
1.3 Organization of the Document 1-5
2 Baseline Impacts 2-1
2.1 Introduction 2-1
2.2 Major Anthropogenic Stressors in Aquatic Ecosystems 2-1
2.2.1 Habitat Loss 2-2
2.2.2 Water Quality 2-3
2.2.3 Overharvesting 2-7
2.2.4 Invasive Species 2-8
2.3 CWIS Impacts on Aquatic Ecosystems 2-8
2.3.1 Losses of Fish from IM&E 2-9
2.3.2 IM&E Effects on T&E species 2-12
2.3.3 Thermal Effects 2-12
2.3.4 Chemical Effects 2-13
2.3.5 Effects of Flow Alteration 2-15
2.4 Community-level or Indirect Effects of CWIS 2-15
2.4.1 Altered Community Structure and Patchy Distribution of Species 2-16
2.4.2 Altered Food Webs 2-16
2.4.3 Reduced Taxa and Genetic Diversity 2-17
2.4.4 Nutrient Cycling Effects 2-17
2.4.5 Reduced Ecological Resistance 2-17
2.5 Cumulative Impacts of Multiple Facilities 2-17
2.5.1 Clustering of Facilities and CWIS on Major Rivers 2-18
2.5.2 Implications of Clustered Facilities for Cumulative Impacts 2-19
2.6 Case Studies of Facility IM&E Impacts 2-19
2.6.1 Bay Shore Power Station 2-20
2.6.2 Indian Point Nuclear Power Plant 2-21
2.6.3 Indian River Power Plant 2-22
2.7 Conclusions 2-23
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Table of Contents
3 Assessment of Impingement and Entrainment Mortality 3-1
3.1 Introduction 3-1
3.2 Methods 3-1
3.2.1 Objectives of IM&E Analysis 3-1
3.2.2 IM&E Loss Metrics 3-1
3.2.3 Valuation Approach 3-2
3.2.4 Rationale for EPA's Approach to Valuation of IM&E 3-3
3.2.5 Extrapolation of IM&E to Develop Regional Estimates 3-5
3.3 IM&E by Region 3-6
3.3.1 California Region 3-6
3.3.2 North Atlantic Region 3-7
3.3.3 Mid-Atlantic Region 3-8
3.3.4 South Atlantic Region 3-9
3.3.5 Gulf of Mexico Region 3-10
3.3.6 Great Lakes Region 3-12
3.3.7 Inland Region 3-13
3.3.8 National Estimates 3-14
3.4 Limitations and Uncertainties 3-15
3.4.1 Data Limitation and Uncertainty 3-15
3.4.2 Structural Uncertainty 3-16
3.4.3 Parameter Uncertainty 3-17
3.4.4 Engineering Uncertainty 3-18
4 Economic Benefit Categories 4-1
4.1 Economic Benefit Categories of the Rule 4-1
4.2 Market and Nonmarket Direct and Indirect Use Benefits from Reduced IM&E 4-4
4.2.1 Commercial Fisheries 4-5
4.2.2 Recreational Fisheries 4-5
4.2.3 Subsistence Fishers 4-6
4.2.4 Benefits from Improved Protection to T&E Species 4-6
4.3 Nonuse Benefits from Reduced IM&E 4-7
5 Impacts and Benefits on Threatened and Endangered Species 5-1
5.1 Introduction 5-1
5.2 T&E Species Affected by CWIS 5-2
5.2.1 T&E Species Identification and Data Collection 5-2
5.2.2 Number of T&E Species Affected per Facility 5-3
5.2.3 Number of Facilities Affecting Individual T&E Species 5-6
5.2.4 Summary of Overlap between Cooling Water Intake Structures and T&E Species 5-8
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5.2.5 Summary of Overlap between Cooling Water Intake Structures and Critical Habitat 5-8
5.2.6 Effect of the Final Rule on Facilities Overlapping T&E Species Habitat 5-9
5.2.7 Species with Documented IM&E 5-9
5.3 Societal Values for Preservation of T&E Species Affected by IM&E 5-12
5.4 Assessment of Benefits to T&E Species 5-13
5.4.1 Economic Valuation Methods 5-13
5.4.2 Case Studies 5-13
5.4.3 Limitation and Uncertainties 5-20
6 Commercial Fishing Benefits 6-1
6.1 Methodology 6-1
6.1.1 Estimating Consumer and Producer Surplus 6-1
6.2 Benefits Estimates for Regional Commercial Fishing 6-10
6.2.1 California Region 6-12
6.2.2 North Atlantic Region 6-13
6.2.3 Mid-Atlantic Region 6-14
6.2.4 South Atlantic Region 6-15
6.2.5 Gulf of Mexico Region 6-16
6.2.6 Great Lakes Region 6-16
6.2.7 National Estimates 6-17
6.3 Limitations and Uncertainties 6-18
7 Recreational Fishing Benefits 7-1
7.1 Introduction 7-1
7.2 Methodology 7-1
7.2.1 Estimating Marginal Value per Fish 7-2
7.2.2 Calculating Recreational Fishing Benefits 7-7
7.2.3 Sensitivity Analysis Based on the Krinsky and Robb (1986) Approach 7-7
7.3 Benefits Estimates for Recreational Fishing by Region 7-8
7.3.1 California Region 7-8
7.3.2 North Atlantic Region 7-9
7.3.3 Mid-Atlantic Region 7-10
7.3.4 South Atlantic Region 7-11
7.3.5 Gulf of Mexico Region 7-12
7.3.6 Great Lakes Region 7-13
7.3.7 Inland Region 7-14
7.3.8 National Estimates 7-15
7.4 Limitations and Uncertainties 7-16
8 Nonuse Benefit Transfer Approach 8-1
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Table of Contents
8.1 Introduction 8-1
8.2 Public Policy Significance of Ecological Improvements from the Final Rule 8-2
8.2.1 Effects on Depleted Fish Populations 8-2
8.2.2 Marine Protected Areas 8-3
8.2.3 Restoration of Freshwater Ecosystems 8-5
8.2.4 Summary of Evidence for Nonuse Values of Ecosystems Affected by CWIS 8-6
8.3 Benefit Transfer for Nonuse Values in the North Atlantic and Mid-Atlantic Regions 8-6
8.3.1 Description of the Benefit Transfer Study and BSPV Methods 8-7
8.3.2 Benefit Transfer Methodology 8-9
8.4 Benefit Transfer Results for the Final Rule and Options Considered 8-16
8.5 Habitat-Based Methodology for Estimating Nonuse Values for Fish Production Lost to IM&E .8-17
8.6 Limitations and Uncertainties 8-19
8.6.1 Scale of Fishery Improvements 8-19
8.6.2 Scale and Characteristics of the Affected Population 8-19
8.6.3 Fish Population Size, Type and Improvement from the Elimination of IM&E 8-20
9 Assessment of Social Cost of Carbon 9-1
9.1 Analysis Approach and Data Inputs 9-1
9.1.1 Electric Generators 9-1
9.1.2 Manufacturers 9-6
9.2 Key Findings for Regulatory Options 9-7
9.2.1 Electric Generators 9-7
9.2.2 Manufacturers 9-8
10 Summary of Monetized Benefits for Existing Units 10-1
10.1 Introduction 10-1
10.2 Summary of Methods and Limitations 10-1
10.3 Summary of Baseline Losses and Monetized Benefits for the Final Rule and Options Considered
for Existing Units 10-1
11 Stated Preference Survey 11-1
11.1 Introduction 11-1
11.2 Survey Design 11-2
11.2.1 Survey Format 11-2
11.2.2Experimental Design 11-4
1 1.2.3 Pre-Tests 11-6
11.3 Sampling Frame 11-7
11.4 Mail Survey Responses 11-9
11.5 Non-Response Study 11-12
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11.5.1 Non-Response Sample 11-13
11.5.2 Statistical Testing of Mail Survey and Non-Response Data 11-14
11.6 Random Utility Model 11-17
11.6.1 Model Specification 11-18
11.6.2 Model Estimation 11-19
11.6.3 Approach for Estimating Weights 11-20
11.6.4Model Results 11-21
11.6.5 Validity Tests 11-24
11.7 Estimation of Implicit Prices and WTP 11-26
11.8 Method for Estimating Regional Benefits 11-29
11.9 Results for the Final Rule and Regulatory Options Considered 11-30
11.10 Uncertainties 11-32
12 Analysis of New Units at Existing Facilities 12-1
12.1 Introduction 12-1
12.2 Analysis Approach and Benefits for IM&E Reductions at New Units 12-1
12.2.1 Flow Reductions at New Units 12-1
12.2.2IM&E Reductions and Associated Benefits per MGD 12-2
12.2.3 IM&E Reductions and Associated Benefits under the final Rule and Options Considered for
New Units 12-3
12.2.4 Limitations and Uncertainties for the Analysis of IM&E Reductions and Associated Benefits
for New Units 12-6
12.3 Analysis of Social Cost of Carbon for New Units 12-7
12.3.1 Analysis Approach and Data Inputs 12-7
12.3.2Key Findings for Regulatory Options 12-8
12.4 Monetized Benefits for New Units 12-9
13 Summary of National IM&E Reductions and Benefits for Existing and New Units 13-1
13.1 Introduction 13-1
13.2 Summary of Limitations and Uncertainties 13-1
13.3 Summary of Baseline IM&E Losses and IM&E Reductions 13-2
13.4 Summary of National Monetized Benefits 13-7
13.5 Results based on the SP Survey 13-11
13.6 Break-Even Analysis 13-11
14 References 14-1
Appendix A: Extrapolation Methods A-l
A. 1 Introduction A-l
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A.2 Manufacturing Facilities A-l
A.2.1 Traditional Manufacturers (MN Facilities) A-2
A.2.2 Non-Utility Manufacturers (MU Facilities) A-5
A.3 Electric Power Generating Facilities A-6
A.3.1 Defining the Strata and Control Variables A-7
A.3.2 Comparison of Results of the Detailed Questionnaire and Post-Stratified Weighting
Schemes A-8
A.4 Adjustment for State Regulations of CWIS A-9
Appendix B: Consideration of Potential Effects due to Thermal Discharges B-l
B. 1 Introduction B-l
B.2 General Effects of Thermal Discharges on Aquatic Biota and Ecosystems B-l
B.2.1 Primary Producers B-2
B.2.2 Primary Heterotrophs B-2
B.2.3 Zooplankton B-3
B.2.4 Benthic Community B-3
B.2.5 Fish B-3
B.2.6 Ecosystem Functions and Services B-3
B.3 Influence of Site-Specific Factors and Environmental Setting on Thermal Effects B-4
B.3.1 Geographic Location B-4
B.3.2 Marine vs. Freshwater Receiving Waters B-5
B.3.3 Receiving Water Volume B-5
B.3.4 Rate of Water Exchange B-5
B.3.5 Local Land Use B-5
B.3.6 Local Habitats B-6
B.4 Uncertainties and Limitations of Assessing Thermal Impacts B-6
B.5 Case Studies B-6
B.5.1 Brayton Point Station B-7
B.5.2 Quad Cities Nuclear Station B-10
B.5.3 Point Beach Nuclear Station B-12
Appendix C: Details of Regional IM&E C-l
C. 1 California Region C-l
C.2 North Atlantic Region C-3
C.3 Mid-Atlantic Region C-6
C.4 South Atlantic Region C-10
C.5 Gulf of Mexico Region C-12
C.6 Great Lakes Region C-14
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C.7 Inland Region C-17
C.8 National Estimates C-20
Appendix D: Discounting Benefits D-l
D. 1 Introduction D-l
D.2 Timing of Benefits D-l
D.3 Discounting and Annualization D-3
Appendix E: List of T&E Species Overlapping CWIS E-l
Appendix F: Detailed Methodologies for Estimating Benefits to Threatened and Endangered
Species F-l
F.l IM&E of Sea Turtles F-l
F.2 Application of Whitehead's (1993) Benefit Transfer Approach for Estimating WTP for T&E Sea
Turtle Species F-3
Appendix G: Estimation of Price Changes for Consumer Surplus G-l
G. 1 Introduction G-l
G.2 Methodology and Results G-l
Appendix H: Details of Regional Commercial Fishing Benefits H-l
Appendix I: Details of Regional Recreational Fishing Benefits 1-1
1.1 California Region 1-1
1.2 North Atlantic Region 1-5
1.3 Mid-Atlantic Region 1-9
1.4 South Atlantic Region 1-13
1.5 Gulf of Mexico Region 1-15
1.6 Great Lakes Region 1-19
1.7 Inland Region 1-23
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 1: Introduction
1 Introduction
EPA is issuing the final rule implementing section 316(b) of the Clean Water Act (CWA) to address the
environmental impacts of cooling water intake structures (CWIS). The withdrawal of cooling water from
streams, rivers, estuaries and coastal marine waters by CWIS causes adverse environmental impacts
(AEI) to aquatic biota and communities in these waterbodies. These impacts are caused through several
means, including impingement mortality (where fish and other aquatic life are trapped on equipment at
the entrance to the CWIS and entrainment (where aquatic organisms, including eggs and larvae, are
pulled into the cooling system, passed through the heat exchanger, then discharged back into the source
body). Additional adverse effects are often associated with CWIS operation, including nonlethal effects of
impingement, thermal discharges, chemical effluents, flow modifications caused by these facilities, and
other impacts of variable and unknown magnitudes.
The final rule would establish national performance requirements for the location, design, construction,
and capacity of CWIS. It is designed to minimize the AEI caused by CWIS through reduction of volume,
frequency, and/or seasonality of water withdrawals. The final rule will significantly reduce impingement
mortality and entrainment (IM&E), as well as reduce the magnitude of other impacts (i.e., thermal,
chemical, and flow alteration) on aquatic ecosystems. Thus, changes in CWIS design or operation
resulting from the final rule are likely to result in enhanced ecosystem function and increased ecological
services provided by affected waterbodies.
The two broad categories of regulated facilities include: (1) electric generators and (2) manufacturers.
These facilities include existing electric generators and manufacturers with a design intake flow (DIF) of
at least 2 million gallons per day (mgd) that use at least 25 percent of the water (measured on an average
annual basis for each calendar year) exclusively for cooling purposes.
EPA is required to conduct a benefit-cost analysis under Executive Orders 12866 and 13563 for
economically significant rules. This report presents the methods EPA used for the environmental
assessment and benefits analysis of the regulatory options. EPA had three main objectives: (1) to develop
a national estimate of the baseline magnitude of IM&E at regulated facilities; (2) to estimate changes in
IM&E of fish and invertebrates as a result of the rule; and (3) to estimate the national economic benefits
of reduced IM&E.
This report describes the regulatory options that EPA considered, and identifies the types of economic
benefits that are likely to be generated by improved ecosystem functioning under different regulatory
options. The report also presents the basic concepts involved in analyzing these economic benefits—
including benefit categories and benefit taxonomies associated with market and nonmarket goods and
changes in ecological services likely to result from reduced IM&E. Specific chapters of the report detail
the methods used to estimate values for reductions in IM&E. The organization of this analysis is
described in Section 1.3.
The analysis conducted in support of the final rule and discussed in this report is based on data generated
or obtained in accordance with EPA's Quality Policy and Information Quality Guidelines. EPA's quality
assurance (QA) and quality control (QC) activities for this rulemaking include the development, approval
and implementation of Quality Assurance Project Plans for the use of environmental data generated or
collected from all sampling and analyses, existing databases and literature searches, and for the
development of any models which used environmental data. Unless otherwise stated within this
document, the data used and associated data analyses were evaluated as described in these quality
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 1: Introduction
assurance documents to ensure they are of known and documented quality, meet EPA's requirements for
objectivity, integrity and utility, and are appropriate for the intended use.
1.1 Summary of the Final Rule and Other Options Considered
EPA considered regulatory options for existing units and new units at existing facilities. The options
apply only to existing facilities with a DIF for cooling water of 2 mgd or greater. EPA considered three
options for the existing units based on two technologies:
> Proposal Option 4: IM for Facilities > 50 mgd. Establish impingement mortality controls at all
existing facilities that withdraw over 50 mgd; determine entrainment controls for facilities greater
than 2 mgd DIF on a site-specific basis.
> Final Rule - Existing Units: IM Everywhere. Establish impingement mortality controls at all
existing facilities that withdraw over 2 mgd; determine entrainment controls for facilities greater
than 2 mgd DIF on a site-specific basis.
> Proposal Option 2: IM Everywhere and E for Facilities > 125 mgd. Establish impingement
mortality controls at all existing facilities that withdraw over 2 mgd DIF; require flow reduction
commensurate with closed-cycle recirculating systems for entrainment control by facilities
greater than 125 mgd DIF.
Proposal Options 4 and Proposal Option 2 above correspond to Options 4 and 2 from EPA's analysis for
the proposed rule (USEPA 2011) with some modifications. The final rule is Option 1 from the proposed
rule with the same modifications. The final rule will establish entrainment controls for facility greater
than 2 mgd DIF on a site-specific basis, as would Proposal Option 4. Findings presented in this document
assume that facilities with impoundments will qualify as having closed-cycle recirculating systems in the
baseline. As a result, EPA estimated zero IM&E reductions for these facilities under the final rule and
other options considered; however, these facilities remain subject to today's rule and are assigned
administrative costs. To the extent that some of these facilities do not qualify as having closed-cycle
recirculating systems in the baseline, the monetized benefits reported in this document may be
underestimates.1
EPA considered four regulatory options for new units at existing facilities. Stand-alone new units are
newly built units adjacent to existing units and repowered units are existing units that have been wholly or
partially demolished and rebuilt or upgraded on the same site.
> Option A: Entrainment performance requirements for all standalone new units and all types of
repowered units.
> Option B: Entrainment performance requirements for all stand-alone new units, and replaced or
repowered units in which turbine or condenser are newly built or replaced.
> Option C: Entrainment performance requirements for all stand-alone new units, and repowered
new units where the turbine and condenser are newly built or replaced, but excluding high
efficiency systems.
> Final Rule - Option D: Entrainment performance requirements for all stand-alone new units
only.
EPA notes that the vast majority of these facilities occur in the Inland benefits region. Any underestimation in monetized
benefits due to the treatment of facilities with impoundments is likely to be minor because commercial fishing benefits and
nonuse benefits are not estimated for the Inland region.
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Chapter 1: Introduction
Refer to Section VI of the preamble for a more complete description of the final rule and other options
considered for existing and new units.
This report presents EPA's analysis of environmental and economic benefits for the final rule and the
other options considered described above. EPA also presents monetized values for baseline IM&E losses
at existing facilities. The associated benefits estimates equivalent to benefits if all baseline IM&E losses
were to be eliminated. EPA emphasizes that this not a regulatory option and that it presents baseline
values for illustration purposes only.
EPA discounted and annualized benefits for the final rule and other options considered following three
steps. First, EPA developed a time profile of benefits to show when benefits occur. Second, the Agency
calculated the total discounted present value of the benefits as of the year 2013. Finally, EPA annualized
the benefits of the final rule and other options considered, over a 51 -year time span. Refer to Appendix D
for additional detail regarding discounting and annualization.
1.2 Study Design
EPA's analysis of the regulatory options examined CWIS impacts and regulatory benefits in seven study
regions. EPA defined the study regions on the basis of ecological similarities within regions (e.g.,
freshwater versus marine, similar communities of aquatic species), and on characteristics of commercial
and recreational fishing activities. The seven study regions are: California2, North Atlantic, Mid Atlantic,
South Atlantic, Gulf of Mexico, Great Lakes, and Inland. The Great Lakes region includes all facilities
located on the Great Lakes, the Inland region includes all other freshwater facilities, and the remaining
five regions include coastal and estuarine facilities. Sections 1.2.1, 1.2.2, and 1.2.3 provide additional
detail regarding the definition of each region. National estimates are the sum of regional estimates. Table
1-1 presents the number of regulated facilities that participated in the Section 316(b) Industry Surveys and
their total actual intake flow by study region. EPA excluded facilities that it classifies as baseline closures
from all totals and figures presented throughout this document, including Table 1-1. Baselines closures
are also excluded from all totals and figures presented throughout this document. EPA classifies an
electric generating facility as a baseline closure if it has retired all steam operations since the 316(b)
survey was conducted or if EPA expects that it will retire its steam capacity by 2021, according the 2011
EIA-860 Database published by the Energy Information Administration (EIA) and U.S. Department of
Energy (DOE). For manufacturers, baseline closures are facilities showing materially inadequate financial
performance in the baseline. Refer to Appendix H of the Economic Analysis (EA) for additional detail
regarding baseline closures.
The facility universe includes facilities that are subject to state regulations for CWIS in California and
New York. The California state regulation requires closed-cycle recirculating systems for coastal electric
generating facilities while the New York state regulation requires closed-cycle recirculating systems for
all in-state facilities with DIF greater than or equal to 20 mgd. Fourteen surveyed facilities fall within the
scope of the California state regulation and 32 surveyed facilities fall within the scope of the New York
state regulation.3 EPA determined that the state regulations are at least as stringent as the final rule and
other options considered. Facilities within the scope of the state regulations would be subject to the
requirements of the final rule, but they may not be required to install additional technologies to reduce
IM&E under the final rule. Within the benefits analysis for the 316(b) rule, EPA assigns these facilities
baseline levels of IM&E that are commensurate with compliance with the state regulations. These
Includes four regulated facilities in Hawaii.
These counts exclude 6 California facilities and 5 New York facilities which EPA classifies as baseline closures.
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Chapter 1: Introduction
facilities do not influence the occurrence and magnitude of benefits under the final rule, similar to other
facilities which already meet the requirements of the final rule.
EPA has determined that 280 surveyed facilities currently satisfy the IM performance standard
established by the final rule or use one of several compliant technologies to achieve this goal, including
all facilities that are subject to the California and New York state regulations described above. Although
these 280 facilities are subject to the requirements of the final rule, they may not be required to install
technologies in order to comply with the final rule. Thus, these facilities have not been factored into the
benefits analysis for the final rule.
Table 1-1: Number of Facilities and Total Mean Operational Flow, by Region3'"
Flow
Region
Number of Surveyed
(billions of gallons per day)
Facilities
Non-Recirculating
Recirculating
Total Flow
Facilities0
Facilities
California11
21
10.65
0.00
10.65
Great Lakes
50
16.24
0.24
16.47
Inland0
566
107.56
18.06
125.62
Mid-Atlantic
46
24.69
0.07
24.76
Gulf of Mexico
22
10.14
0.05
10.18
North Atlantic-
21
5.93
0.00
5.93
South Atlantic-
12
5.91
0.05
5.96
All Regions
738
181.12
18.46
199.58
a This table presents counts of unweighted facility counts and flow for surveyed facilities (excluding baseline closures). The regional
study design for the benefits analysis weights based on flow rather than facility counts. EPA did not developed weighted facility
counts by benefits region. The "All Regions" total of 738 surveyed facilities includes 532 electric generating facilities and 206
manufacturing facilities, excluding baseline closures. The total (weighted) estimated universe of facilities, excluding baseline
closures, is 1,065 facilities.
b The facility counts and flow presented in this table include facilities which are subject to state regulations for CWIS in California
and New York. Within the benefits analysis for the 316(b) rule, EPA assigns these facilities baseline levels of IM&E that are
commensurate with compliance with the state regulations.
c Recirculating facilities are facilities with closed-cycle recirculating systems or impoundments that qualify as closed-cycle
recirculating systems. Non-recirculating facilities includes facilities with CWIS classified as once-through.
11 The California region includes four facilities in Hawaii. There are no coastal facilities in Oregon and one costal facility in
Washington is classified as a baseline closure.
e A facility in Texas has intakes located in both the Inland and Gulf of Mexico regions. It is included within the Inland region within
in the table to prevent the double counting of facilities.
Source: U.S. EPA analysis for this report.
1.2.1 Coastal Regions
The five coastal regions (California, North Atlantic, Mid-Atlantic, South Atlantic, and Gulf of Mexico)
correspond to regions defined by the National Oceanic and Atmospheric Administration's (NOAA)
National Marine Fisheries Service (NMFS). These regions include facilities that withdraw cooling water
from estuaries, tidal rivers and ocean facilities within the NMFS regions.
Coastal regions are defined as follows. The California region includes all coastal, estuarine or tidal
facilities in the state of California, plus four facilities in Hawaii. The North Atlantic region encompasses
coastal, estuarine, or tidal facilities in Maine, New Hampshire, Massachusetts, Rhode Island, and
Connecticut. The Mid-Atlantic region includes all coastal, estuarine or tidal facilities in New York, New
Jersey, Pennsylvania, Delaware, Maryland, the District of Columbia, and Virginia. The South Atlantic
region includes all coastal, estuarine or tidal facilities in North Carolina, South Carolina, Georgia, and the
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Chapter 1: Introduction
east coast of Florida. Finally, the Gulf of Mexico region includes coastal, estuarine or tidal facilities in
Texas, Louisiana, Mississippi, Alabama, and the west coast of Florida. Coastal regions include a total of
123 facilities.
1.2.2 Great Lakes Region
The Great Lakes region is defined in accordance with the CWA to include facilities withdrawing cooling
water from Lake Superior, Lake Michigan, Lake Huron (including Lake St. Clair), Lake Erie and Lake
Ontario, and the connecting channels (Saint Mary's River, Saint Clair River, Detroit River, Niagara
River, and Saint Lawrence River to the Canadian border) (Great Lakes 1990). The Great Lakes region is
comprised of 50 facilities.
1.2.3 Inland Region
The Inland region includes all regulated facilities that withdraw water from all inland waterbodies such as
freshwater streams and rivers, lakes, reservoirs (excluding those included within the Great Lakes Region)
regardless of geographical location. There are 566 such facilities in 39 states (including states with both
coastal and inland facilities).
1.3 Organization of the Document
Chapter 2 provides information on the baseline conditions of the water bodies affected by regulated
facilities. To obtain regional IM&E estimates, EPA extrapolated loss rates from facilities for which IM&E
data are available (hereafter, model facilities), to all regulated facilities within the same region. EPA's
extrapolation methods for, and results from, regional IM&E models are described in Chapter 3.
EPA provides an overview of all benefits (Chapter 4) and investigates several benefit categories in detail,
including: benefits from improved protection of threatened and endangered (T&E) species (Chapter 5),
commercial fishing benefits (Chapter 6), recreational fishing benefits (Chapter 7), and nonuse benefit
transfer (Chapter 8). Chapter 9 presents benefits estimates based on the social cost of carbon. Chapter 10
summarizes benefits for existing units estimated using the methodologies described in Chapters 5 through
9. EPA also used the preliminary results of a its 316(b) stated preference study to illustrate potential
willingness to pay (WTP) for aquatic ecosystem improvements (Chapter 11). Chapter 12 presents benefit
estimates for new units at existing facilities based on benefits methodologies described in Chapter 5
through 9. Chapter 13 summarizes total national benefits for existing and new units at regulated facilities.
Additional details regarding EPA's benefits analysis are presented in Appendix A through Appendix I.
Appendix A presents the extrapolation methods used by EPA to analyze the benefits from reducing
IM&E at regulated facilities; Appendix B describes potential ecological effects due to thermal discharges;
Appendix C presents detailed output from IM&E models; Appendix D discusses economic discounting
and the expected timing of benefits; Appendix E presents a list of T&E species likely impacted by IM&E;
Appendix F provides details on the methodologies used to estimate the effects of IM&E on T&E species,
and the benefits from the section 316(b) rule; Appendix G presents EPA's analysis of the potential for
IM&E reductions to impact the market price of commercially fished species; Appendix H presents details
of the benefits of IM&E on commercial fishing by region; and Appendix I presents detailed regional
results of the effects of IM&E on recreational fishing benefits.
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Chapter 2: Baseline Impacts
2 Baseline Impacts
2.1 Introduction
This chapter provides a brief summary of adverse environmental impacts from the IM&E of fish and
invertebrates in CWIS used by electric power and manufacturing facilities subject to the final rule under
section 316(b) of the CWA.
CWIS impacts do not occur in isolation from other ongoing physical, chemical, and biological stressors
on aquatic habitats and biota in the receiving waterbody. Additional anthropogenic stressors may include,
but are not limited to: degraded water and sediment quality, low dissolved oxygen (DO), eutrophication,
fishing pressure, channel or shoreline (habitat) modification, hydrologic regime changes, and invasive
species. For example, many aquatic organisms subject to the effects of cooling water withdrawals reside
in impaired (i.e., CWA 303(d) listed) waterbodies. Accordingly, they are potentially more vulnerable to
cumulative impacts from other anthropogenic stressors (USEPA 2006a). The effect of these
anthropogenic stressors on local biota may contribute to or compound the local impact of IM&E,
depending on the influence of location-specific factors. In addition to multiple stressors acting on biota
near a single CWIS, multiple facilities and CWIS located in close proximity along the same waterbody
may have additive or cumulative effects on aquatic communities (USEPA 2006a).
Although it is difficult to measure, an aquatic population's compensatory ability—the capacity for a
species to increase survival, growth, or reproduction rates in response to decreased population —is likely
compromised by IM&E and the cumulative impact of other stressors in the environment over extended
periods of time (USEPA 2006a). These cumulative impacts may lead to subtle, less-easily observed
changes in aquatic communities and ecosystem function. These secondary impacts are difficult to isolate
from background variability, partly because of the limited scope and inherent limitations of the data
available to characterize IM&E.
Since the aquatic habitat quality and health of the biotic community are shaped by the cumulative effect
of many factors, it is important to characterize the environmental context of baseline impacts. This will
permit comparisons between the relative influences of CWIS-related stressors and other factors, and result
in a more accurate estimate of the environmental impact of the final rule.
This chapter provides a qualitative description of baseline IM&E impacts and anthropogenic stressors
found in aquatic environments affected by CWIS.
2.2 Major Anthropogenic Stressors in Aquatic Ecosystems
All ecosystems and biota are subject to natural variability in environmental conditions (e.g., seasonal
perturbations), as well as periodic large-scale disturbances in environmental settings (e.g., drought, flood,
fire, disease). Indigenous aquatic species and communities are adapted to this natural variability, such that
large-scale events elicit a predictable loss, response and recovery cycle. Conversely, anthropogenic
stressors tend to be more chronic in nature and often do not lead to recognizable recovery phases. Instead
these stressors often lead to long-term environmental degradation associated with lowered biodiversity,
reduced primary and secondary production, and a lowered capacity or resiliency of the ecosystem to
recover to its original state in response to natural perturbations (Rapport and Whitford 1999).
Anthropogenic stressors are present to some degree in all major waterbodies of the United States, and are
the result of many different impacts (Table 2-1). Four of the more important stressors include: (i) habitat
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Chapter 2: Baseline Impacts
loss; (ii) degraded water quality and sediment contamination; (iii) extractive uses of aquatic resources;
and (iv) invasion by non-indigenous species (Rapport and Whitford 1999). CWIS-related impacts are
listed here as a separate, fifth category of anthropogenic stress, one with many apparent similarities to
overharvesting. Other large-scale stressors, such as change in watershed land use and engineering
diversions, may be present. Thus, the true impact of CWIS on an aquatic community may be partly
masked, or difficult to detect, due to the influence of other stressors on the receiving water.
The remainder of this section summarizes effects of these four anthropogenic stressors on the waterbodies
affected by regulated facilities. CWIS impacts on the aquatic ecosystems are summarized in Section 2.3.
Table 2-1: Anthropogenic Stressors Impacting Aquatic Ecosystems Potentially Affected, Both
Directly and Indirectly, by the Final Rule and Options Considered
Impacted by the Rule
Anthropogenic Stressor
Proposal
Option 4
Final Rule
Proposal
Option 2
Scale of Stressor
CWIS
Yes: Direct
Yes: Direct
Yes: Direct
Local/Regional/National
Habitat loss
Development
No
No
No
Local
Eutrophication
Yes: Indirect
Yes: Indirect
Yes: Indirect
Local/Regional
Climate change
No
No
No
Regional/National/Global
Engineering diversions
Re-routing
No
No
No
Local/Regional
Flow adjustments/removals/
modifications
No
No
Yes: Direct
Local/Regional
Water impoundments/damming
No
No
No
Local/Regional
Water quality
Eutrophication
Yes: Indirect
Yes: Indirect
Yes: Indirect
Local/Regional
Loss of riparian buffer zones
No
No
No
Local/Regional
Sedimentation
No
No
Yes: Direct
Local/Regional
Chemical pollution (organics,
heavy metals, etc.)
No
No
Yes: Direct
Local/Regional
Non-native / invasive species
Yes: Indirect
Yes: Indirect
Yes: Indirect
Local/Regional
Extractive uses (e.g. fishing)
Yes: Indirect
Yes: Indirect
Yes: Indirect
Local/Regional
Source: U.S. EPA analysis for this report
2.2.1 Habitat Loss
Structural aquatic habitat is generally recognized as the most significant determinant of the nature and
composition of aquatic communities. Human occupation and restructuring of shorelines; construction and
maintenance of harbors; installation of dams, canals, and other navigational infrastructure; draining of
wetlands for agriculture and residential uses; and degradation of critical fish habitats have all taken a
heavy toll on the numbers and composition of local fish and shellfisheries. Most regulated facilities have
been built on shoreline locations where power-generation buildings, roadways, CWIS, canals,
impoundments, and other water storage or conveyance structures have often been constructed at the cost
of natural habitat, including terrestrial, aquatic, and wetlands.
The loss of coastal and estuarine wetlands that serve as important fishery spawning and nursery areas is
particularly severe, with an estimated historical loss of 100 million acres of wetlands since the late 1700s
(Bromberg and Bertness 2005; USEPA 2010c). Critical fishery habitat loss is not restricted to nearshore
environments. Decades of fishing activities have degraded offshore bottom habitats (Auster and Langton
1999; Turner et al. 1999).
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The main impact of aquatic habitat loss is a reduction in the number of fish in the environment, a
reduction in fish spawning and nursery areas, shifts in species dominance based on available habitat, and
local extirpation of historical fish species. Habitat loss in adjacent shoreline areas exacerbates the effect of
CWIS losses, since many fish species affected by IM&E (e.g., bay anchovy, winter flounder) rely on
coastal wetlands as nursery areas.
In riverine environments, the effects of channelization and navigation can also lead to habitat loss. For
example, Tondreau et al. (1982) conducted a 10-year study of the aquatic ecosystem of the Missouri River
near the Neal Generating facility in Sioux City, IA. The investigators found that the combined effects of
channelization, heavy barge traffic, and high river flow rates had resulted in a significant loss of fish
habitat. As a result, reported IM&E is relatively minor, because local fish populations were already
greatly diminished.
2.2.2 Water Quality
Water quality is a major stressor of aquatic biota and habitats. Degraded surface water and sediment
contaminants reflect current and historical industrial, agricultural and residential land use as well as
discharges from wastewater treatment facilities. Poor water quality can limit the numbers, composition,
and distribution of fish and invertebrates; reduce spawning effort and growth rates; select for pollution-
tolerant species; cause periodic fish kills; or result in adverse effects to piscivorous wildlife.
CWA section 303(d) listings inventory, on a state-by-state basis, the locations of impaired waters not
meeting designated uses and the known or suspected source(s) of impairment. Figure 2-1 identifies
regulated facilities, those within two miles of a 303(d)-listed waterbody, and those impaired for
temperature, using a database of 303(d) waterbodies assembled in October, 2010. The map clearly shows
that facilities along the coasts, Great Lakes, and major waterways such as the Mississippi, Missouri, and
Ohio rivers are located in the vicinity of impaired waterbodies.
EPA's analysis of regulated facilities demonstrated that the majority of facilities (74 percent) are within
two miles of a 303(d)-listed waterbody. Table 2-2 summarizes the number of regulated facilities on
waterbodies impaired by any cause, by region. These include impairment due to chemical, physical, and
biological factors, categorized into biological stressors, nutrients, organic enrichment/loading,
bioaccumulation, toxics, unknown causes, and general water quality impairment.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 2: Baseline Impacts
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Temperature in 2010
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 2: Baseline Impacts
The most common causes of impairment for waterbodies serving as 316(b) source waters are
polychlorinated biphenyls (PCBs), pathogens, mercury, as well as organic enrichment/oxygen
depletion and nutrients. The entire universe of all 303(d) water quality impairment causes is much
too diverse to cover fully in this section. However, below is a discussion of some of the more
common and important physico-chemical impairments in aquatic environment where regulated
facilities draw cooling water from, and discharge to, 303(d) listed waters.
> An oversupply of nutrients can result in excessive algal production, reduced light clarity,
more frequent outbreaks of harmful algal blooms (HABs), high internal loads of
biochemical oxygen demand (BOD), and spatial and temporally variable DO levels. In
addition, eutrophication can reduce or eliminate habitat-formers such as coral reefs and
submerged aquatic vegetation (SAV), and create other adverse ecological effects.
Thermal discharges from regulated facilities can increase receiving water temperature,
which may favor formation of blue-green algal blooms.
> Low levels of dissolved oxygen (hypoxia) may be present in many estuaries and coastal
waters (IWG 2010), in the hypolimnia of eutrophic lakes, and in areas of high organic
loading (e.g., below wastewater treatment plant outfalls). DO concentrations may be
further decreased in or downstream of thermal plumes arising from cooling water return
discharges from regulated facilities. Low DO can limit the distribution of fish and
macroinvertebrates, reduce growth rates, and alter nutrient and carbon recycling.
> Persistent, bioaccumulative and toxic substances (PBTs) such as mercury or PCBs may
be present in waterbodies near regulated facilities, due to atmospheric deposition of local
air emissions or from historical uses of PCBs in electrical transformer units, in addition to
other urban or industrial sources. These PBTs can impair water uses by regulatory
restrictions or advisories regarding acceptable ingestion of fish consumption (see below),
as well as affecting higher trophic level predators in the food chain.
> Toxic pollutants, such as metals, polycyclic aromatic hydrocarbons (PAHs), pesticides,
biofouling chemicals, or chlorine may be present in the discharge of regulated facilities.
This could lead to local extirpation of sensitive species, or to greatly altered biological
communities due to chronic impacts on viability, growth, reproduction, and resistance to
other stressors.
In addition to the 303(d) listings, many of the waterbodies in which the CWIS are located are
subject to fish advisories. Fish advisories are issued by States to protect their citizens from the
risk of eating contaminated fish or wildlife (USEPA 2009a). Fish advisories are recommendations
and do not carry regulatory authority, but they indicate the presence of bioaccumulative
chemicals which may pose risk for humans and piscivorous wildlife, and which may also
interfere with the reproduction and survival of taxa in lower trophic levels.4
4 Although fish advisories do not themselves carry regulatory authority, waterbodies may be included on 303(d)
lists because of persistent fish advisories resulting from the bioaccumulation of specified and unspecified toxics.
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Table 2-2: Number of Regulated Facilities on 303(d)-listed Waterbodies, by Impairment
and Region3
Impairment
California
Great
Lakes
Inland
Mid-
Atlantic
Gulf of
Mexico
North
Atlantic
South
Atlantic
Total
Regulated Facilities
21
50
566
46
22
21
12
738
Biological Stressors
Noxious Aquatic Plants
1
1
Nuisance Exotic Species
3
3
6
Pathogens
6
9
85
5
1
9
4
119
Nutrients
Algal Growth
1
1
Nutrients
9
37
3
1
2
6
58
Organic Enrichment / Loading
Organic Enrichment, Oxygen
Depletion
2
6
43
1
5
3
6
66
Sediment
2
3
15
2
22
Persistent, Bioaccumulative, Toxic (PBTs)
Dioxins
2
13
12
2
29
Fish Consumption Advisory,
Pollutant Unspecified
3
7
1
11
Mercury
3
24
85
3
2
2
119
PCBs
9
45
122
10
2
1
189
Pesticides
10
11
15
36
Physical Alterations
Flow Alteration
4
4
I labitat Alteration
1
7
8
Temperature
6
3
9
Turbidity
21
1
2
24
Toxics
Ammonia
1
1
2
Chlorine
1
1
Metals (Other Than Mercury)
5
4
37
6
1
53
Total Toxicity
7
4
2
1
14
Toxic Inorganics
1
1
2
Toxic Organics
3
8
2
13
Unknown / Other Causes
Cause Unknown
8
8
Cause Unknown - Fish Kills
1
1
Cause Unknown - Impaired
Biota
2
2
12
2
18
Other Cause
3
1
4
Water Quality Use Impairments (General)
Oil And Grease
4
3
7
pH
3
7
10
Salinity, TDS, Sulfates,
Chlorides
1
1
6
8
Taste, Color And Odor
3
1
4
All Impairment Categories
One or More Impairments
18
46
398
38
12
20
11
543
a Waterbodies may be listed for multiple impairments and facilities may be counted in more than one row.
Source: U.S. EPA analysis for this report
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EPA's 2008 National Listing of Fish Advisories (NLFA) database indicates that 97 percent of the
advisories are due (in order of importance) to: mercury, PCBs, chlordane, dioxins, and DDT
(USEPA 2009a). Fish advisories have been issued for 39 percent of the total river miles
(approximately 1.4 million river miles) and 100 percent of the Great Lakes and connecting
waterways (USEPA 2009a). Fish advisories have been steadily increasing over the NLFA period
of record (1993-2008), but these increases are interpreted to reflect the increase in the number of
waterbodies being monitored by States and advances in analytical methods rather than increasing
levels of these problematic chemicals.
The water quality impacts arising from the combination of operations and/or discharges of
regulated facilities and other anthropogenic sources (as indicted by the presence of widespread
fish advisories) could result in highly degraded or altered aquatic communities that may be
further reduced by IM&E.
2.2.3 Overharvesting
Overharvesting is a general term which describes the exploitation of an aquatic population (e.g.,
fish, shellfish, and kelp) in an unsustainable fashion to the point of reducing or even eliminating
much of the population. Stocks of commercial and recreationally important species are reduced as
a result of fishing, but such fish catches may be sustainable if sufficient recruitment of juveniles
into the fishery can replace population losses from fishing and other stressors.5 Unfortunately for
many aquatic species, overharvesting has a long history and in many instances has preceded
impacts by other competing anthropogenic stressors by several centuries (Jackson et al. 2001).
Many species (and fishery stocks) subject to IM&E are also subject to overharvesting. For
example, the 2011 NMFS stock status report indicated that 14 percent of federally monitored fish
stocks were being fished at rates above the maximum sustainable yield ("overfishing"), while 21
percent of species are considered over-exploited ("overfished") (NMFS 2012c); many of these
fish stocks are also subject to IM&E. Table 2-3 lists 10 groups of species subject to IM&E that
are overfished or subject to overfishing. Additional detail regarding the status of stocks is
provided in Chapter 6 on commercial fishing benefits. Notably, this assessment does not include
many important fishery species not subject to federal regulation that may be subject to high
IM&E, nor does this assessment consider threatened and endangered (T&E) species.
Severe overfishing can drive species to ecological insignificance, where the overfished
populations no longer interact meaningfully in the food web with other species in the community,
or even to extinction (Jackson et al. 2001). The collapse of the Great Lakes whitefish fisheries has
been shown to be principally due to overfishing, although habitat alteration and introduction of a
non-indigenous (exotic) invader (sea lamprey) were also contributory (Rapport and Whitford
1999).
5 Recruitment is the number of young fish that enter into a population.
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Table 2-3: Depleted Commercial Fish Stocks Subject to IM&E
Stock or Stock Complex
Status of Stock3
Stock Region
Surfperches
Overfished but not subject to overfishingb
California
Atlantic Cod
Overfished or subject to overfishing
North Atlantic
Windowpane
Overfished but not subject to overfishing
North Atlantic
Winter Flounder
Overfished but not subject to overfishing
North Atlantic
Flounders
Overfished or subject to overfishing
North Atlantic
Atlantic Menhaden
Subject to overfishing but not overfished
North Atlantic/South Atlantic
American Shad
Overfished
North Atlantic/Md-Atlantic
Weakfish
Overfished but not subject to overfishing
North Atlantic/Md-
Atlantic/South Atlantic
Alewife
Overfished
Mid-Atlantic
Tautog
Overfished and subject to overfishing
Mid-Atlantic
a Species group may consist of many individual component species with conflicting stock statuses. The most common stock
status among the component species was designated the Status of Stock for the species group.
b "Perch" species were used as a proxy for Surfperch.
Source: NA1FS 2012c and U.S. EPA analysis for this report
2.2.4 Invasive Species
Non-indigenous, invasive species (NIS) are a significant and increasingly prevalent stressor in
both freshwater and marine environments (Cohen and Carlton 1998; Ruiz et al. 1999).
Approximately 300 NIS are established in marine and estuarine habitats of the continental United
States, and that rate of invasion is rapidly increasing (Ruiz et al. 2000). Aquatic NIS are
taxonomically diverse and include plants, fish, crabs, snails, clams, mussels, bryozoans, and
nudibranchs. Analysis of freshwater NIS indicated that between 10 to 15 percent are nuisance
species with undesirable effects (Ruiz et al. 1999). The adverse implications of marine and
coastal NIS are generally not as well-characterized as those in freshwater settings.
Interactions between NIS and other anthropogenic stressors are likely to affect the colonization
and distribution of native species subject to CWIS impacts. Thermal discharges from regulated
facilities may extend the seasonal duration of non-resident organisms, allowing transient summer
species to become permanently established in geographic areas beyond their historical range. For
example, in Mount Hope Bay, increased water temperature due to the Brayton Point Station
facility led to an increase in abundance of the predacious ctenophore Mneimiopsis leidyi as well
as increased overwintering in the Bay for this formerly seasonal resident (USEPA 2002b).
2.3 CWIS Impacts on Aquatic Ecosystems
EPA has determined that multiple types of adverse environmental impacts may be associated with
CWIS operations at regulated facilities, depending on site-specific conditions at an individual
facility. Many of these facilities employ once-through cooling water systems that impinge fish
and other aquatic organisms on intake screens if the intake velocity exceeds these organisms"
locomotive ability to move away. Impinged organisms may be killed, injured or weakened,
depending on the nature and capacity of the plant's filter screen configuration, cleaning and
backwashing operations, and fish return system used to return organisms to the source water. In
addition, early life stage fish or planktonic organisms can be entrained by the CWIS and
subjected to death or injury due to high velocity and pressure, increased temperature, and
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chemical anti-biofouling agents in the system. This IM&E can act in concert with the other
stressors identified above.
The magnitude and regional importance of IM&E is generally a function of the operational intake
volumes and the characteristics of the aquatic community in the region (see Chapter 3 for details).
IM&E can contribute to: impacts to T&E species (Chapter 4); reductions in ecologically critical
aquatic organisms, including important elements of an ecosystem's food chain; diminishment of
organism populations" compensatory reserves; population declines, including reductions of
indigenous species population levels, commercial fisheries (Chapter 6), and recreational fisheries
(Chapter 7); and stresses to overall communities and ecosystems, as evidenced by reductions in
diversity or other changes in ecosystem structure or function. In addition, fish and other species
affected directly and indirectly by CWIS can provide other valuable ecosystem goods and
services, including nutrient cycling and ecosystem stability.
The impacts of IM&E occur at many levels of ecological organization and across a wide range of
environmental scales. Table 2-4 presents a summary of direct and indirect impacts of CWIS and
IM&E. The effects are identified as direct, indirect, or a combination. This table also indicates the
relative scale (local, regional, national) of the particular effect. In most cases, EPA was unable to
estimate the magnitude of these effects due to a lack of data. This section discusses a subset of
these effects.
2.3.1 Losses of Fish from IM&E
The most visible direct impact of IM&E is the loss of large numbers of aquatic organisms,
distributed non-uniformly among fish, benthic invertebrates, phytoplankton, zooplankton, and
other susceptible aquatic taxa (e.g., sea turtles). This has immediate and direct effects on the
population size and age distribution of affected species, and may cascade through food webs.
Populations of aquatic organisms decline when recruitment rates are lower than mortality rates.
Natural sources of mortality for fish species include predation, food availability, injury, climatic
factors and disease. Anthropogenic sources of fish mortality, both proximate and ultimate,
include fishing, habitat modification, pollution, and IM&E at CWIS. Reducing IM&E will
contribute to the health and sustainability of fish populations by lowering the total mortality rate
for these populations.
In some cases, IM&E has been shown to be a significant source of anthropogenic mortality to
depleted stocks of commercially targeted species. For example, IM&E [expressed as age-one
equivalents (A IE)] equal approximately 10 percent of the average annual recruitment to the
Southern New England/Massachusetts stock of winter flounder (Pseudopleuronectes americanus)
(IM&E values from Chapter 3; recruitment data from Terceiro (2008)).
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Table 2-4: CWIS Effects on Ecosystem Functions/Cumulative Impacts Potentially
Affected, Both Directly and Indirectly, by the 316(b) Rule
Category
Direct/Indirect
Local/Regional/
National
A. Impingement and Entrainment (direct and indirect effects)
Effects on Individuals
I,oss of individuals (direct effects)
Direct
focal/Resiional/National
l'hytoplankton
Direct
focal/Resiional/National
Xooplankton (excluding lish larvae/eggs)
Direct
focal/Resiional/National
Invertebrates
Direct
focal/Resiional/National
fish
Direct
focal/Resiional/National
Non-lish vertebrates
Direct
focal/Resiional/National
Species and Population-Level Effects
Alteration of phenology of system (function of % water
reduction in stream I
Direct
Local/Regional/National
Altered distribution of populations
Direct
I ,ocal
Altered niche space
Direct
I ,ocal/Re»ional
Altered stable age distributions of populations
Direct
Resiional
I,oss of keystone species
Direct
I ,ocal
I,oss off&f: species
Direct
Resiional
Novel selection pressure (e.g.. negatively buoyant or
stationary eggs)
Direct & Indirect
Local
Reduced/altered genetic diversity
Direct & Indirect
Regional/National
Reduced lifetime ecological function of individuals
Direct
Local/Regional
Community and Trophic Relationships
Altered competitive interactions
Direct & Indirect
I ,ocal
Disrupted trophic relationships
Direct & Indirect
I ,ocal
Disrupted control of disease-harboring insects (e.g., mosquito
larvae, etc.)
Indirect & Direct
Local/Regional
Increased quantity of detritivores
Indirect
I ,ocal
I,oss of ecosystem engineers (due to trophic interactions)
Indirect & Direct
I ,ocal
Reduced potential for energy Hows (e.g. trophic transfers)
Indirect
I ,ocal/Re»ional
Species diversity and richness
Direct & Indirect
focal/Resiional/National
Trophic cascades
Indirect & Direct
Local/Regional
Ecosystem Enaction
Altered ecosystem succession
Indirect & Direct
I ,ocal/Re»ional
Decreased ability of ecosystem to control nuisance species
(algae, macrophytes)
Indirect
Local
Disrupted cross-ecosystem nutrient exchange (e.g.,
up/downstream, aquatic/terrestrial)
Indirect
Regional
Disrupted nutrient cycling
Indirect & Direct
Local/Regional
Reduced compensatory ability to deal with environmental
stress (resilience)
Direct & Indirect
Regional
Reduced ecosystem resistance
Indirect
I ,ocal/Re»ional
Reduced ecosystem stability (alternate states)
Indirect
I ,ocal/Re»ional
Sediment regulation
Indirect
I ,ocal/Regional
Substrate regulation
Indirect
Local
B. Thermal Effects (direct and indirect)
Novel selection pressure (e.g., thermal optima, location of
breeding, etc. )
Direct & Indirect
Regional/National
Altered phenology
Direct
I ,ocal/Re»ional
finks between temperature and metabolism
Dissolved oxygen (physical)
Direct
I ,ocal
Dissolved oxygen (bacterial, respirator) rates)
Indirect
I ,ocal
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Table 2-4: CWIS Effects on Ecosystem Functions/Cumulative Impacts Potentially
Affected, Both Directly and Indirectly, by the 316(b) Rule
Category
Direct/Indirect
Local/Regional/
National
Ixolosiical eneraetic demands
Indirect
I ,ocal/Re»ional
Ixolosiical nutrient demands
Indirect
I ,ocal/Re»ional
Altered algal productivity
Direct & Indirect
I ,ocal/Re»ional
Shifted nutrient cycling
Indirect & Direct
Local/Regional
C. Chemical Effects (anti-foulants, etc.)
Altered survival/growth/production
Indirect & Direct
Local
Altered food web dynamics
Indirect
Local
D. Altered Flow Regimes (local and system-wide)
Altered flow velocity
Direct & Indirect
Local/Regional
Altered turbulence regime
Direct & Indirect
Local/Regional
E. Cumulative Impacts (as a concentrated number of facilities)
May push systems over the edge of nonlinearities in the
system
Direct/Indirect
Local/Regional
Intensified CWIS effects (as above, Section B.)
Direct/Indirect
Local/Regional
Intensified thermal effects (as above, Section B.)
Direct/Indirect
Local/Regional
Source: U.S. EPA analysis for this report
In addition to its impact on stocks of marine commercial fish species, IM&E increases the
pressure on native freshwater species, such as lake whitefish (Coregonus clupeaformi) and yellow
perch (Percci flavescens), whose populations have seen dramatic declines in recent years (USDOI
2008; Wisconsin DNR 2003). Although recovery of these species is greatly affected by fisheries
policy (e.g., NEFSC 2008), IM&E represent an additional source of mortality to fish populations
being harvested at unsustainable levels.
Overall, IM&E is likely to contribute to reduction in the population sizes of species targeted by
commercial and recreational fishers, particularly for stocks that are undergoing rebuilding.
Although these reductions may be small in magnitude compared to fishing pressure (Lorda et al.
2000), and often difficult to measure due to the low statistical power of fisheries surveys, a
reduction in mortality rates on overfished populations is likely to increase the rate of stock
recovery. Although researchers know less about the population biology of forage fish not targeted
by fishers, similar benefits are likely to accrue for these species. Overall, reducing IM&E may
lead to more-rapid stock recovery, a long-term increase in commercial fish catches, increased
population stability following periods of poor recruitment and, as a consequence of increased
resource utilization, an increased ability to minimize the invasion of exotic species (Shea and
Chesson 2002; Stachowicz and Byrnes 2006).
For many fish species, IM&E may not lead to measurable reductions in adult populations. These
losses, however, are likely to reduce the compensatory ability of populations to respond to
environmental variability, including temperature extremes, heavy predation, disease, or years
with low recruitment. Additionally, because predation rates are often directly related to the
concentration of available prey, IM&E may lead to indirect population effects, whereby
reductions in a prey fish may indirectly result in reductions to predator species or increases to
species in apparent competition (Holt 1977).
Moreover, IM&E represents a novel selective pressure for fish populations. Consequently,
populations may be selected for resistance to IM&E (through behavioral or physiological
changes) at the expense of other, more "natural" evolutionary pressures. Although this may help
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sustain populations in the short term, it may reduce genetic diversity and population stability in
the long-term.
2.3.2 IM&E Effects on T&E species
T&E species are species vulnerable to future extinction or at risk of extinction in the near future,
respectively. Due to low population sizes, IM&E from CWIS may represent a substantial portion
of the annual reproduction of T&E species. Consequently, IM&E may either lengthen population
recovery time, or hasten the demise of these species. For these reasons, the population-level and
social values of T&E losses are likely to be more important than the absolute number of losses
that occur.
Adverse effects on T&E species due to water withdrawals by CWIS may occur in several ways:
> Populations of T&E species may suffer increased mortality as a consequence of IM&E.
> T&E species may suffer indirect harm if the CWIS substantially alters the food web in
which these species interact.
> T&E species may suffer indirect harm if the CWIS substantially alters habitat that is
critical to their long-term survival.
Chapter 5 provides detail on CWIS impacts on T&E species.
2.3.3 Thermal Effects
Once-through cooling water systems release heated effluent as a byproduct. Concerns about the
impacts of heated effluents are addressed by provisions of CWA section 316(a) rule. Most of the
facilities subject to 316(b) IM&E concerns have also been required to address the impact of
thermal pollution in the discharge-receiving waters (Abt Associates 2010b).
Thermal pollution has long been recognized as having effects upon the structure and function of
ecosystems (Abt Associates 2009). Numerous studies have shown that thermal discharges may
substantially alter the structure of the aquatic community by modifying photosynthetic (Bulthuis
1987; Chuang et al. 2009; Martinez-Arroyo et al. 2000; Poornima et al. 2005), metabolic, and
growth rates (Leffler 1972), and reducing levels of DO. Thermal pollution may also alter the
location and timing of fish behavior including spawning (Bartholow et al. 2004), aggregation, and
migration (USEPA 2002b), and may result in thermal shock-induced mortality for some species
(Ash et al. 1974; Deacutis 1978; Smythe and Sawyko 2000). Thus, thermal pollution is likely to
alter the ecological services provided by ecosystems surrounding facilities returning heated
cooling water into nearby waterbodies.
Adverse temperature effects may also be more pronounced in aquatic ecosystems that are already
subject to other environmental stressors such as high biochemical oxygen demand (BOD) levels,
sediment contamination, or pathogens. Thermal discharges may have indirect effects on fish and
other vertebrate populations through increasing pathogen growth and infection rates. Langford
(1990) reviewed several studies on disease incidence and temperature, and while he found no
simple, causal relationship between the two, he did note that it was clear that warmer water
enhances the growth rates and survival of pathogens, and that infection rates tended to be lower in
cooler waters.
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The magnitude of thermal effects on ecosystem services is related to facility-specific factors,
including the volume of the waterbody from which cooling water is withdrawn and returned,
other heat loads, the rate of water exchange, the presence of nearby refugia, and the assemblage
of nearby fish species. In addition to reducing total IM&E, cooling towers reduce thermal
pollution. Consequently, the installation of closed-system cooling towers could have
geographically variable effects on ecosystems, ranging from comprehensive changes in
community structure and habitat type (Schiel et al. 2004), to localized changes in the relative
proportion of species adapted to warm and cold water (Millstone Environmental Laboratory
2009). Further information on thermal discharges is provided in Appendix B.
2.3.4 Chemical Effects
One of the environmental impacts associated with operation of electric generators is the release of
chemicals in the discharge of once-through cooling water. These chemicals include metals from
internal corrosion of pipes, valves and pumps (e.g., chromium, copper, iron, nickel, and zinc),
additives (anti-fouling, anti-corrosion, and anti-scaling agents) and their byproducts, and
materials from boiler blowdown and cleaning cycles.
EPA used the Discharge Monitoring Report Pollutant Loading Tool (DMR-PLT)6 to obtain
estimated annual pollutant loadings for regulated facilities. EPA extracted data for all regulated
facilities (excluding those designated as baseline closures) by querying on a facility's NPDES
permit identification number. Of the 739 regulated facilities (excluding baseline closures), 569
have annual loading estimates in DMR-PLT; of these, nearly 75 percent are electric power
generators. Table 2-5 lists the top 20 pollutants discharged by regulated facilities in 2011, sorted
by mass. These chemicals represent pollutants generated by the operation and maintenance of the
facility and other location-specific activities. The most common pollutants include: total
dissolved solids, calcium carbonate, sulfate, chloride and fecal coliform.
In addition to these pollutants, facilities also discharge anti-fouling agents. Biofouling is a serious
operational concern for facilities. Microbial biofouling on surfaces in cooling water systems can
accelerate metal corrosion, increase resistance to heat transfer energy, and increase fluid frictional
resistance (Cloete et al. 1998). Sessile macrofouling-organisms such as algae, insects, hydroids,
polychaetes, barnacles, mussels and tunicates can colonize intake pipes, bulkheads, and filter
screens, and may clog pipes and reduce intake flows or filter-screen effectiveness. Further, some
of these infestations produce larvae, which can colonize downstream equipment including
pipelines, valves, and heat exchangers. Severe macrofouling-associated problems can include
intake flow reduction, increased pressure drop across heat exchangers, and equipment breakdown.
0 The Discharge Monitoring Report (DMR) Pollutant Loading Tool calculates pollutant loadings from EPA's
Permit Compliance System (PCS) and Integrated Compliance Information System for the National Pollutant
Discharge Elimination System (ICIS-NPDES) as well as wastewater pollutant discharge data from EPA's Toxics
Release Inventory (TRI). Data is currently available for the years 2007 through 2011.
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Table 2-5: Top 20 Pollutants Discharged by Regulated Facilities, by
Total Annual Loadings (2011)
Parameter
Number of
facilities
Total Loading
(million lbs/yr)
1 Solids, total dissolved
42
18,508.3
2 I lardness. total (as CaC03)
31
1.548.5
3 Solids, total suspended
487
651.0
4 Colilbnn. local general
82
535.3
5 Residue, total filterable (dried at 105 C)
8
524.3
6 Sulfate, total las S()4 I
52
485.1
7 Chloride las CI i
53
440.3
8 Nickel, total recoverable
41
395.4
9 Selenium, total recoverable
51
262.6
10 Lead, total recoverable
47
251 .2
1 1 Chromium, total recoverable
27
224.7
12 Chromium, trivalent total recoverable
4
217.7
13 Sulfate
11
178.6
14 Cadmium, total recoverable
32
165.6
15 Solids, total dissolved- 180 dog. C
7
127.7
16 Calcium Chloride
1
106.9
17 Chemical Oxygen Demand (COD)
35
105.9
18 Solids, total dissolved ( I DS)
3
102.1
19 Chromium, hexavalent dissolved (as Cr)
14
97.4
20 Antimony, total (as Sb)
12
81.9
Source: Discharge Monitoring Report Pollutant Loading Tool (DA1R-PLT)
These anti-fouling and cleaning chemicals potentially pose a risk to organisms downstream of the
CWIS discharge. Adverse effects to aquatic organisms may include acute and residual effects of
biocides used as anti-fouling agents in condenser tubes, or from chemicals resulting from
corrosion or use in cleaning of either stream or cooling cycles (Kelso and Milburn 1979). A
typical biofouling procedure is continuous low-level chlorination at chronic toxicity levels with
an occasional high ("shock") dose. The use of oxidants (chlorine, bromide) can give rise to
residuals and/or disinfection byproducts (DBPs) such as trihalomethanes, haloacetic acid,
bromoform, and others (Taylor 2006). Concentrations of released chemicals are variable among
facilities, and are a function of treatment dose, CWIS design, rates of degradation, and the
volume and flushing rate of the receiving water.
With the exception of chlorination impacts (Taylor 2006), the potential effects of chemicals in
facilities" cooling water discharges on local aquatic ecosystems are not well-characterized. In
most cases, chemical effects are considered, along with thermal and mechanical effects, as a
component of the cumulative stress of entrainment on organisms. Little information is available
on the chronic or low-level effects of these discharge chemicals on local ecosystems or in concert
with other anthropogenic stressors.
Review of the effects of chemical treatment and discharge into the environment suggests that
direct ecotoxicity in discharge plumes is relatively rare beyond the point of discharge or mixing
zone near the pipe outlet (Poornima et al. 2005; Taylor 2006). However, concentrations of these
chemicals may be additive to low-level chronic adverse effect with other anthropogenic stressors
identified above.
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2.3.5 Effects of Flow Alteration
The operation of CWIS and discharge returns significantly alter patterns of flow within receiving
waters both in the immediate area of the CWIS intake and discharge pipe, and in mainstream
waterbodies, particularly in inland riverine settings. In ecosystems with strongly delineated
boundaries (i.e., rivers, lakes, enclosed bays, etc.), CWIS may withdraw and subsequently return
a substantial proportion of water available to the ecosystem. For example, of the 435 facilities
that are located on freshwater streams or rivers, 30 percent (132) of these facilities have average
actual intake flow that is greater than 5 percent of the mean annual flow of the source waters.7
Even in situations where the volume of water downstream of regulated facilities changes
relatively little, the flow characteristics of the waterbody, including turbulence and water
velocity, may be significantly altered. This is particularly true in locations with multiple CWIS
located close to each other.
Altered flow velocities and turbulence may lead to several changes in the physical environment,
including sediment deposition (Hoyal et al. 1995), sediment transport (Bennett and Best 1995),
and turbidity (Sumer et al. 1996), each of which play a role in the physical structuring of
ecosystems. Biologically, flow velocity is a dominant controlling factor in aquatic ecosystems.
Flow has been shown to alter feeding rates, settlement and recruitment rates (Abelson and Denny
1997), bioturbation activity (Biles et al. 2003), growth rates (Eckman and Duggins 1993), and
population dynamics (Sanford et al. 1994).
In addition to flow rates, turbulence plays an important role in the ecology of small organisms,
including fish eggs and larvae, phytoplankton, and zooplankton. In many cases, the turbulence of
a waterbody directly affects the behavior of aquatic organisms, including fish, with respect to
swimming speed (Lupandin 2005), location preference with a waterbody (Liao 2007), predator-
prey interactions (Caparroy et al. 1998; MacKenzie and Kiorboe 2000), recruitment rates
(MacKenzie 2000; Mullineaux and Garland 1993), and the metabolic costs of locomotion (Enders
et al. 2003). The sum of these effects may result in changes to the food web or the location of
used habitat, and thereby substantially alter the aquatic environment.
Climate change is predicted to have variable effects on future river discharge in different regions
of the United States, with some rivers expected to have large increases in flood flows while other
basins will experience water stress. For example, Palmer et al. (2008) predict that mean annual
river discharge is expected to increase by about 20 percent in the Potomac and Hudson River
basins but to decrease by about 20 percent in Oregon's Klamath River and California's
Sacramento River. Thus, the adverse effects of flow alteration may increase or decrease over
longer periods for larger rivers, depending on their geographic location.
2.4 Community-level or Indirect Effects of CWIS
In addition to the direct effects of CWIS, IM&E may alter a wide range of aquatic ecosystem
functions and services at the community-level (Table 2-4). Most of these impacts on aquatic
community function and service are poorly characterized, given the limited scope of IM&E
studies and an incomplete knowledge of baseline or pre-operational conditions within affected
waters.
Facility counts exclude baseline closures.
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For example, fish are essential for energy transfer in aquatic food webs (Summers 1989), and for
the regulation of food web structure. Fish play important roles in nutrient cycling (Wilson et al.
2009) and sediment processes, and are known to play key roles in the maintenance of aquatic
biodiversity (Holmlund and Hammer 1999; Peterson and Lubchenco 1997; Postel and Carpenter
1997; Wilson and Carpenter 1999).
While IM&E of commercially or recreationally important fish species can be quantified and
monetized (Chapters 6 and 7), the accompanying loss of other aquatic organisms may be poorly
characterized (e.g., lumped into broad taxa such as "forage fish" or "other") or simply not
reported. In addition, IM&E on species of lower concern may create unrealized ripples of
ecological effect within the aquatic community. Species may respond to altered ecological
circumstances such as reduced predation, altered food concentrations, or slower nutrient
recycling, etc. Therefore, the removal of selected fish species or considerable biomass by IM&E
may substantially affect these processes.
Several examples of ecological services indirectly affected by IM&E are described below,
although others listed in Table 2-4 may be of equal importance for individual ecosystems.
2.4.1 Altered Community Structure and Patchy Distribution of Species
The role of some aquatic species may be more critical in shaping the structure and composition of
the community than that of others. These keystone species are species that have an effect on
community structure disproportionate to their population (Paine 1966; Paine 1969).
Consequently, the loss or reduction of keystone species may lead to substantial changes in aquatic
food webs, and decrease overall ecosystem stability. Thus, the potential for ecosystem impacts
resulting from, for example, the loss of an important predator fish due to IM&E may not be
strictly proportional to the number or biomass of lost fish or foregone fish production.
The operation of CWIS by generating facilities can lead to localized areas of depressed fish and
shellfish abundance. Facilities (and the intake volume they represent) are distributed in a non-
uniform manner along coastlines and rivers, and may be clustered (Section 2.5), such that IM&E
and the populations they affect are geographically heterogeneous. This can result in a highly
localized and patchy distribution of aquatic organisms in regional areas. A secondary effect is
increased probability of colonization and establishment by NIS due to niche space availability
caused by a local reduction in the density of native organisms (Byrnes et al. 2007; Ovaskainen
and Cornell 2006).
2.4.2 Altered Food Webs
Sources of mortality, including IM&E, may disrupt established predator-prey relationships and
the niche space available to species through direct pathways (i.e., mortality of the organism) or
indirectly (i.e., alterations to the food web). The loss of young-of-year (YOY) predators (e.g.,
striped bass) or important forage fish (e.g., menhaden and bay anchovy) is likely to affect trophic
relationships and alter food webs. These changes may alter the realized species niche and life
history traits due to alterations in inter- and intra-specific interactions (e.g., predator-prey,
competition, mate selection, etc.) (Fortier and Harris 1989; Hixon and Jones 2005; Jirotkul 1999).
These alterations in trophic interactions and food webs, combined with other CWIS-related
impacts such as thermal pollution (Section 2.2.3) or flow alteration (Section 2.3.5), may lead to
rapid changes in life history strategies as a consequence of facultative (Ball and Baker 1996) or
evolutionary changes (Hairston et al. 2005; Reznick and Endler 1982).
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2.4.3 Reduced Taxa and Genetic Diversity
IM&E may lead to reductions in local community biodiversity (due to destruction of selected
species) or in a loss of genetic diversity in individual fish populations. IM&E represents a novel
selective pressure on early life stages that may reduce the genetic diversity of resident fish and
prevent the recovery of depleted stocks (Stockwell et al. 2003; Swain et al. 2007; Walsh et al.
2006). Because many populations stocks are differentiated by oceanic region and/or timing of
migratory movements, IM&E could alter the seasonal timing and movement (i.e., phenology) of
overall fish populations, which could have ramifications for predator species.
2.4.4 Nutrient Cycling Effects
IM&E impacts may alter the pace of nutrient cycling, and energy transfer through food webs.
Fish species have been shown to have substantial effects on nitrogen, phosphorous, and carbon
cycling due to storage effects (i.e., large quantities of nutrients are found within fish biomass) and
translocation effects (i.e., fish migrate, moving large quantities of nutrients to new ecosystems)
(Kitchell et al. 1979; Vanni et al. 1997). These alterations in nutrient cycling could lead to
redirection of nutrient flows to other components of the ecosystem including water column
phytoplankton, benthic macroalgae and attached epiphytes, with subsequent changes to the
condition of critical ecosystem habitats, such as submerged aquatic vegetation. Juvenile Atlantic
menhaden (Brevoortia tyrcmmis) are capable of significantly grazing down plankton
concentrations in Chesapeake Bay, leading to more-rapid regeneration of nutrients and enhanced
primary production. Removal of juvenile menhaden by IM&E would lead to reduced grazing and
turnover of nutrients and increased algal density in the water column (Gottlieb 1998). The amount
of nitrogen and phosphorus regenerated in facility discharge water due to nutrient recycling of
IM&E biota might also lead to areas of localized nutrient enrichment near outfalls (Abt
Associates 2010a). Additionally, the preferential removal of upper water column species by
IM&E could increase energy flow to benthic organisms, and thereby increase the relative
importance of detritivores in bottom communities.
2.4.5 Reduced Ecological Resistance
The effect of long-term or chronic IM&E may lead to a decrease in ecosystem resistance and
resilience (i.e., ability to resist and recover from disturbance including invasive species) (Folke et
al. 2004; Gunderson 2000). That is, IM&E is likely to reduce the ability of ecosystems to
withstand and recover from adverse environmental impacts, whether those impacts are due to
anthropogenic effects or natural variability.
2.5 Cumulative Impacts of Multiple Facilities
Cumulative effects of CWIS are likely to occur if multiple facilities are located in close proximity
such that they impinge or entrain aquatic organisms within the same source waterbody, watershed
system, or along a migratory pathway of a specific species (e.g., striped bass in the Hudson River)
(USEPA 2004a). The cumulative impacts of CWIS may be exacerbated by the presence of other
anthropogenic stressors discussed above (Section 2.2).
EPA analyses suggest that approximately 20 percent of all regulated facilities are located on
waterbodies with multiple CWIS (USEPA 2004a). Inspection of geographic locations of
regulated facilities (approximated by CWIS latitude and longitude) indicates that facilities in
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inland settings are clustered around rivers to a greater extent than marine and estuarine facilities
(see Figure 2-1).
2.5.1 Clustering of Facilities and CWIS on Major Rivers
To illustrate the potential for cumulative impacts, EPA reviewed data from five major U.S. rivers
with clustered concentrations of facilities. Table 2-6 summarizes average annual river flow and
facility DIF and actual intake flow (AIF). Based on the non-uniform distribution of facilities,
locations were noted where the potential for cumulative impacts is high (Abt Associates 2010b).
Table 2-6: U.S. Rivers with Largest Withdrawals by Regulated Facilities
River
Avg. Annual3
Flow (mgd)
Facilities
Cumulative
DIF (mgd)
DIF as % Avg.
Annual Flow
Cumulative
AIF (mgd)
AIF as %
Avg. Annual
Flow
Mississippi
383.266
57
22.436
5.9
13,170
3.4
Ohio
181.615
47
19.315
10.6
13,384
7.4
Missouri
49.249
23
10.718
21.8
6,598
13.4
Illinois
8,079
11
6,259
77.5
1,605
19.9
Delaware
7,562
11
3,585
47.4
1,485
19.6
Sources: USGS 1990 and U.S. EPA analysis for this report
For example, the Mississippi River provides source water for cooling water for 57 facilities along
its length,8 with 27 facilities located in Louisiana upstream of the Mississippi River delta. Using
facility intake coordinates as location markers, the relative distances between facilities were
estimated (Abt Associates 2010b). In upper Louisiana, facilities are typically separated by tens of
miles; inter-facility distance decreases downstream of Baton Rouge, LA. Several locations along
the Mississippi River have clusters of facilities:
> Between Ascension and St. James Parishes, a 13-mile span of the river hosts six
manufacturing facilities, three of which have intakes located within the same mile. These
facilities have a combined DIF of nearly 270 mgd.
> Fifteen miles downstream, near Garyville, LA, there is a cluster of three facilities within
six miles of the river stretch.
> Seven miles further downstream near Laplace, LA, six facilities are located on a six-mile
stretch of the river. Four of these facilities, with a combined DIF exceeding 5 billion
gallons per day (bgd) (three generators and one manufacturer), are located within a 1.7
mile section of river.
> Further downstream in Chalmette, LA (just east of New Orleans), three manufacturers,
capable of withdrawing up to 457 mgd, are clustered within four river miles.
Therefore, the potential for cumulative impacts is high, and investigating ecosystem effects by
extrapolating results on a per facility basis is likely to underestimate the true effects.
This total excludes one facility that EPA projects as baseline closure.
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2.5.2 Implications of Clustered Facilities for Cumulative Impacts
The cumulative impact of clustered facilities may be significant, due to the concentrated IM&E,
combined intake flows, and the potential for other impacts such as thermal discharges. It should
also be noted that power generation demand and cooling intake water volume are typically at
their annual maximum during mid-late summer, which is also a period of seasonal low flows and
highest in-stream temperatures. The effect of cumulative impacts may be greater in inland or
Great Lakes waters due to the following factors:
> The majority of national AIF is associated with freshwater CWIS.
> Freshwater facilities use a greater relative volume of available fish habitat than marine or
estuarine counterparts.
> Seasonal variation in power demand and river flow may increase entrainment potential
during low-flow periods of the year (NETL 2009). Although low flows are traditionally
in late summer to early fall, drought conditions and manipulations of water levels may
lead to low flow during other periods. This may be locally significant if periods of low
flow overlap with seasonal concentrations of eggs, developing YOY, and migrating
juveniles.
> Freshwater facilities are more likely to be clustered along a waterbody, and pose a greater
risk of cumulative impacts. This is exacerbated by the presence of numerous
impoundments associated with navigational lock and dam structures located on larger
rivers (e.g., Mississippi, Missouri, Ohio, etc). These impoundments result in slow or
slack water conditions with a lower effective volume than free-flowing reaches or periods
of higher flow.
2.6 Case Studies of Facility IM&E Impacts
While the information provided in this chapter provides a broad overview of potential impacts
associated with CWIS, it is highly informative to evaluate these impacts in the context of actual
facilities to see how and to what extent these impacts and IM&E are realized, how site-specific
factors come into play, the effects of cumulative impacts, and what has been learned with regard
to community-level effects. Case studies provide useful, detailed information for evaluating
IM&E and major stressors in the context of a specific waterbody or region.
As part of the Phase II regulations, review and analyses of IM&E data and environmental
information were presented in comprehensive case studies in EPA's 2002 Case Study Analysis
for the Proposed Section 316(b) Phase II Existing Facilities Rule (USEPA 2002a). The document
provided detailed analyses of CWIS impacts in major regional waterbodies throughout the United
States. These cases studies included:
> Delaware Estuary Watershed: a regional assessment of the impacts of 7 generating and 6
manufacturing facilities in the transition zone of the Delaware River Estuary. The
estuary's transition zone was chosen due to its biological, recreational, and economic
importance, and because of the high concentration of CWIS.
> Ohio River Watershed: a detailed assessment of the impacts of 9 (of 29) facilities in a
500-mile stretch of the Ohio River between the McAlpine and New Cumberland pools,
this case study is representative of a large industrial river.
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> Tampa Bay Watershed: highlighted as a representative of the Southeast Atlantic and Gulf
coasts, this case study included four of eight facilities in watersheds draining into Tampa
Bay.
> San Francisco Bay/Delta Estuary: included as representative of an urban estuary, and a
waterbody containing several T&E species, this case study highlighted the effects of two
large generating facilities.
> Brayton Point Facility: a case study of a single facility and its impacts on a confined
waterbody.
> Seabrook and Pilgrim Facilities: with a pair of facilities located in the same ecological
region, but with very different CWIS placements, this case study highlights the potential
effects of CWIS location of IM&E impacts.
> J.R. Whiting Facility: an assessment of the before and after effects of the installation of a
deterrent net on IM&E for a representative facility on the Great Lakes.
> Monroe Facility: located nearby the J.R. Whiting facility (above), the Monroe facility
case study provides an estimate of the effects of IM&E on Great Lakes facilities.
These regional case studies provide a set of information describing the variety of CWIS impacts
under marine, coastal, and riverine environmental settings. The following sections present three
additional case studies to provide examples of facility-specific CWIS impacts in settings
including freshwater coastal (Bay Shore, Oregon, OH), estuarine (Indian Point, Buchanan, NY),
and estuarine-coastal (Indian River, Sussex County, DE) environments. These brief case studies
also illustrate the quantitative levels of IM&E, the indirect effects of IM&E on local aquatic
ecosystems, and the cumulative effects of combined effects (IM&E and thermal).
2.6.1 Bay Shore Power Station
The Bay Shore power station is a 631 megawatt (MW) facility located on the south shore of Lake
Erie near the confluence of the Maumee River and Maumee Bay, OH. Cooling water for the four
coal-fired steam-electric units is withdrawn from Maumee River/Maumee Bay via an open intake
channel of approximately 3,700 ft in length, and enters the facility via a shoreline surface CWIS.
Approximately 749 million gallons per day (mgd) are withdrawn, including once-through cooling
water and sluice water used for transporting bottom ash from the boilers to ash settling ponds
(OEPA 2010). Major environmental concerns for the facility include IM&E and thermal impacts.
Bay Shore Power Station IM&E: Medium-sized Plant with Large-Scale Impacts:
A comprehensive demonstration study, conducted in 2005-2006, estimated annual impingement
at greater than 46 million fish per year, the majority of which were forage fish species—emerald
shiner and gizzard shad. Annual estimates for entrainment were equally impressive—209 million
fish eggs, 2,247 million fish larvae, and 14 million juvenile fish (OEPA 2010). As noted on the
NDPES fact sheet, "It is likely that Bay Shore Station impinges and entrains more fish than all
other power stations in Ohio combined/' Notably, the facility does not currently employ
technologies to reduce IM&E (OEPA 2010).
In addition to IM&E effects, concerns have also been raised regarding the size and impact of the
thermal discharge plume—a focus of concern for local residents and commercial fishermen.
Depending on wind patterns and hydrological factors, the thermal plume extends to the south
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shore of Maumee Bay (over 1 mile from the facility). The Ohio Environmental Protection
Agency (OEPA) assessed the results from a 2002 thermal mixing zone study, and concluded that
the thermal discharge exceeded Ohio water quality standards for temperature within the thermal
plume (>85°F in Maumee Bay), but that the impacts on aquatic life and designated uses in
Maumee River/Bay did not justify reduction of the thermal mixing zone. However, it did find that
the thermal activity could restrict recreational activities in certain areas of the facility and
required the facility owners to conduct a two-year study of the benthic community within the
mixing zone (OEPA 2010).
2.6.2 Indian Point Nuclear Power Plant
The Indian Point nuclear power plant is a 2,045 MW facility located in Buchanan, Westchester
County, New York, on the east shoreline of the Hudson River. Cooling water (up to 2,500 mgd)
for the two nuclear-fired steam-electric units (Units 2 and 3) is withdrawn from the estuarine
portion of the Hudson River through three intake structures on the shoreline (NYSDEC 2003a).
The heated non-contact cooling water is discharged through sub-surface diffuser ports in a
discharge canal located downstream of the intake structures.
Concerns regarding impact to fish, particularly anadromous striped bass populations, as well as a
high level of involvement and litigation from local stakeholder groups, have made the Indian
Point power generation plant (along with other Hudson River facilities) particularly well-
characterized in terms of IM&E impacts. Accordingly, the Hudson River aquatic community has
been sampled and studied over many decades, with detailed investigation starting in the 1970s.
Results suggest that IM&E impacts to the local and transient anadramous fish species are
substantial. For example, studies of fish entrainment in 1980 predicted fish class reductions
ranging from 6 to 79 percent, depending on fish species (Boreman and Goodyear 1988).
Subsequent sampling work predicted year-class reductions due to IM&E of 20 percent for striped
bass, 25 percent for bay anchovy, and 43 percent for Atlantic tomcod. The Final Environmental
Impact Statement (FEIS) prepared by the New York State Department of Environmental
Conservation (NYSDEC) concluded these levels of mortality "could seriously deplete any
resilience or compensatory capacity of the species needed to survive unfavorable environmental
conditions" (USEPA 2006a).
Indian Point Final Environmental Impact Statement (FEIS) details cumulative effects:
The FEIS estimated, from samples collected between 1981 and 1987 for three facilities (Indian
Point, Roseton, Bowline Point), that average annual entrainment included 16.9 million American
shad, 303.4 million striped bass, 409.6 million bay anchovy, 468 million white perch, and 826.2
million river herring (NYSDEC 2003b). The loss of such large numbers of forage fish species and
the potential impact on higher level piscivores is of high concern. The FEIS also viewed the
overall effect of the CWIS impacts on the aquatic community as analogous to habitat degradation
rather than overfishing. This judgment was based on evidence that the entire aquatic community
was affected rather than only specimens of higher trophic level species.
The FEIS considered the role of other major environmental factors currently or historically
present in the Hudson River. These factors have the capacity to affect fish populations either
positively (enhancements) or negatively (stressors). Relevant factors include, but are not limited
to: improvements to water quality due to upgrades to sewage treatment facilities, invasions by
exotic species (e.g., zebra mussel), chemical contamination by toxins (e.g., PCBs and heavy
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Chapter 2: Baseline Impacts
metals), global climate shifts such as increases in annual mean temperatures and higher
frequencies of extreme weather events (e.g., the El Nino-Southern Oscillation), and stricter
management of individual species stocks such as striped bass (USEPA 2006a).
In April 2010, the NYSDEC denied a request by Indian Point for a CWA section 401 Water
Quality Certificate. The CWA requires that, prior to any federal agency issuing a license or
permit for a particular project (in this case, the approval of the State Discharges Permit
Elimination System [SPDES] permit), it must certify that the project meets State water quality
standards. The NYSDEC denial letter cited, among other concerns, continuing concerns over
IM&E including potential impacts to two species protected under the Endangered Species Act
(ESA) —the Shortnose Sturgeon (endangered) and the Atlantic Sturgeon (endangered).
2.6.3 Indian River Power Plant
The Indian River Generating Station (IRGS) is a 784 MW facility located in Sussex County,
Delaware, on the south shore of the Indian River. Cooling water for three of the IRGS's four
coal-fired steam-electric units is withdrawn upstream from the freshwater portion of Indian River
via an intake canal at a maximum rate of 411 mgd, or 21 times the average flow rate of Indian
River. Heated return water is discharged via a canal into the upper reaches of Island Creek, a
small tributary of Indian River, entering at Ward Cove. Island Creek and Ward Cove are part of a
large estuarine stretch (approximately 150 acres) of Indian River that provides important fish and
crab habitat. Its lower salinity and location in the estuary make it attractive to important species
such as bay anchovy, spot, menhaden larvae, and young blue crabs.
Indian River Power Plant has impact on important local species:
The 2003 316(b) Comprehensive Demonstration Study for the Indian River Power Plant reported
IM&E for a number of important species (Entrix 2003, as described in Bason 2008). This IM&E
has been recalculated by a local stakeholder group as A1E for bay anchovy (1.6 million), blue
crab (300,000), croaker (270,000), and menhaden (60,000) (Bason 2008).
Due to the size of the heated discharge relative to the receiving water, thermal effects of the
facility were also investigated. Based upon monitoring data collected from 1998 to 1999, the
316(a) report assessed the effects of elevated water temperatures on ecosystem communities with
a focus on eight important fish species: bay anchovy, menhaden, winter and summer flounder,
croaker, spot, striped bass, and weakfish. This report determined that juvenile and adult target
species, although able to avoid areas of high water temperature, were not permanently restricted
from most stretches of the Indian River, nor did they suffer loss of habitat services associated
with these segments. The study concluded an overall condition of no adverse effect, or no
appreciable harm, on the fish and shellfish populations in the Indian River and Delaware Bay
(Entrix 2001).
Despite the overall conclusion of no adverse effect, the report documented localized thermal
impacts of consequence. For example, during warmer months, the thermal discharge reached
potential adverse levels in Island Creek, often extending downstream to Ware Cove (Entrix
2001). The mortality associated with sub-adult stages of fish and crabs and the avoidance of the
area by sub-adult and adult fish were substantial issues. In addition to direct thermal impacts to
biota, temperature-related reductions in DO were observable (mean reduction = 0.6 mg/1) in the
discharge canal. These reductions contributed to the amplitude of the day-night (diel) cycle of DO
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Chapter 2: Baseline Impacts
concentrations, already widely fluctuating due to cumulative effects of eutrophication in the river
(Bason 2008).
2.7 Conclusions
Considerable information is available on the direct effects of CWIS and IM&E (Chapter 3) on
commercially (Chapter 6) and recreationally important (Chapter 7) species derived from the
accumulated data from facility-specific basis 316(b) studies and investigations. This information
allowed EPA to monetize the potential commercial and recreational fishing benefits for the final
rule and other options EPA considered. However, as demonstrated in this section, much less
information and high uncertainty exist regarding the magnitude and importance of indirect and/or
cumulative impacts of CWIS, particularly effects on lower trophic organisms or ecosystem
functions. This condition is due to the limitations of 316(b) sampling programs, as well as the
failure of permitting process to consider the additive or cumulative effects of other major
anthropogenic stressors. While EPA can identify and hypothesize regarding the direction and
relative importance of impacts of CWIS on the totality of the aquatic ecosystem (i.e., not just
focused on selected higher trophic level predator species and common prey), EPA is currently
unable to connect these effects with quantifiable environmental benefits. Thus, it is highly likely
that the total environmental and monetary impacts of CWIS are significantly underestimated, and
that characterization of the fuller spectrum of benefits arising from reducing or eliminating IM&E
will await future, targeted research efforts.
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Chapter 3: Assessment of IM&E
3 Assessment of Impingement and Entrainment Mortality
3.1 Introduction
This chapter discusses the methods EPA used to convert results from IM&E sampling studies into metrics
suitable as inputs for EPA's section 316(b) benefits analysis.9 Section 3.2 provides a brief overview of
IM&E metrics, and outlines how they were used in the benefits analysis. Section 3.3 presents IM&E, by
region, under baseline conditions, and the reductions in these losses under alternative regulatory options.
Section 3.4 discusses limitations and uncertainties in the IM&E analysis.
EPA's IM&E assessment methods are discussed in detail in Chapter A-l of the Regional Benefits
Analysis for the Final Section 316(b) Phase III Existing Facilities Rule (Regional Benefits Analysis)
(USEPA 2006b). Changes in methodology since EPA's Phase III analysis include: (1) the addition of new
IM&E data for several California facilities, (2) engineering reductions for power generators were
estimated for sample facilities that received the detailed questionnaire rather than for all regulated
generators, and (3) estimated changes in the proportionate reduction in IM&E under the final rule and
Proposal Options 2 and 4. Other modifications are identified in relevant portions of Section 3.2.
3.2 Methods
3.2.1 Objectives of IM&E Analysis
EPA's evaluation of IM&E data had four main objectives:
> To develop regional and national estimates of the magnitude of IM&E;
> To standardize IM&E using common biological metrics that allow comparison across species,
years, facilities, and geographical regions;
> To provide IM&E metrics suitable for use in national economic benefits analysis; and,
> To estimate changes in metrics as a result of estimated reductions in IM&E under the final rule
and Proposal Options 2 and 4.
EPA's use of these methods for national rulemaking does not imply that these methods are the best or
most suitable for studies of single facilities. In many cases, site-specific details on local fish populations
and waterbody conditions may make other assessment approaches, such as population or ecosystem
modeling, possible.
3.2.2 IM&E Loss Metrics
Three loss metrics were derived from facility IM&E monitoring data available to EPA: (1) age-one
equivalents (A1E), (2) forgone fishery yield, and (3) production forgone. These metrics are described
For the purposes of its national analysis, EPA assumed 100 percent entrainment mortality. This assumption is discussed at
length in Chapter A7 of the Regional Analysis Document for the Final Section 316(b) Existing Facilities Rule (USEPA
2004a). Briefly, EPA assessed 37 entrainment survival studies and found them variable, unpredictable, unreliable, and not
defensible. As such, these studies support an assumption of 0 percent survival for entrained organisms in benefits
assessments.
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Chapter 3: Assessment of IM&E
briefly below. Equations used to calculate metrics and other details are provided in Chapter A-l of EPA's
Regional Benefits Analysis (USEPA 2006b).
3.2.2.1 Age-One Equivalents
The Equivalent Adult Model (EAM) is a method for converting organisms of different ages (life stages)
into an equivalent number of individuals in any single age (Goodyear 1978; Horst 1975). For its 316(b)
analyses, EPA standardized all IM&E into equivalent numbers of 1-year-old fish, a value referred to as
AlEs. This conversion allows losses to be compared among species, years, facilities, and regions.
To conduct EAM calculations requires a life history schedule, for each species, incorporating age-specific
mortality rates. Using these species-specific survival tables, a conversion rate between all life history
stages and age 1 is calculated. For life history stages younger than 1 year of age, the conversion rate is
calculated as the product of all stage-specific survival rates between the stage at which IM&E occurs and
age 1. Consequently, the loss of an individual younger than age 1 results in a conversion rate less than 1.
For individuals older than 1 year, the conversion rate is calculated as the quotient of all stage-specific
survival rates between the stage at which IM&E occurs and age 1. Consequently, the loss of an individual
older than age 1 results in a conversion rate greater than 1.
Additional details on the EAM calculation are provided in Chapter A-l of EPA's Regional Benefits
Analysis (USEPA 2006b). For the results presented in this chapter, the treatment of early life stages in
this calculation considers all larval life stages reported in the original IM&E studies.
3.2.2.2 Forgone Fishery Yield of Commercial and Recreational Species
Fishery yield is a measure of the biomass harvested from a cohort of fish.10 EPA expressed IM&E of
harvested species in terms of forgone (lost) fishery yield. To convert losses to forgone fishery yield, EPA
used the Thompson-Bell equilibrium yield model (Ricker 1975) with the assumptions that 1) IM&E
reduce the future yield of harvested adults, and 2) reductions in IM&E will lead to an increase in
harvested biomass.
The Thompson-Bell model is based on the principles used to estimate the expected yield in any harvested
fish population (Hilborn and Walters 1992; Quinn and Deriso 1999). The general procedure involves
multiplying age-specific harvest rates by age-specific weights to calculate an age-specific expected yield.
The lifetime expected yield for a cohort of fish is the sum of all age-specific expected yields. Details of
these calculations are provided in Chapter A-l of EPA's Regional Benefits Analysis (USEPA 2006b).
3.2.2.3 Production Forgone for All Species
Production forgone is an estimate of the biomass that would have been produced had individuals not been
impinged or entrained (Rago 1984). It is calculated for all forage species from species- and age-specific
growth rates and survival probabilities. This forgone biomass represents a decrease in prey availability for
predator species, and is calculated because IM&E for forage species are not included in the forgone
fishery yield calculations. Additional details regarding the calculation of production forgone are provided
in Chapter A-l of EPA's Regional Benefits Analysis (USEPA 2006b).
3.2.3 Valuation Approach
EPA's benefits analysis focused on increased commercial and recreational fishery harvests estimated
from projected reductions in IM&E. For consistency with reported harvest data, commercial harvest is
10 A cohort of fish refers to fish produced in the same year, also referred to as a year-class of fish.
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Chapter 3: Assessment of IM&E
reported in pounds and recreational harvest is reported in numbers of fish. To project changes in fishery
harvests, EPA integrated two components of fishery yield that change as a consequence of IM&E: direct
contributions of commercially and recreationally harvested species (hereafter fishery species), and
indirect contributions of forage species consumed by fishery species (Figure 3-1). The direct contribution
of fishery species to yield (left side of Figure 3-1) is calculated by converting A1E mortality to forgone
yield as described in Section 3.2.2. The contribution of forage species to fishery yield is measured as a
biotic transfer of mass through the food web to fishery species that are subsequently harvested (right side
of Figure 3-1). EPA used a simple trophic transfer model for this purpose (discussed in Chapter A-l of
EPA's Regional Benefits Analysis (USEPA 2006b), assuming atrophic transfer efficiency of 0.10 (Pauly
and Christensen 1995).11 Trophic transfer efficiency represents the fraction of forage species biomass
incorporated into predator (fishery) species biomass. EPA estimated total changes to commercial and
recreational harvest yield as the sum of the contributions of fishery and forage species. For benefits
analysis, total yield was separated into commercial and recreational fractions based on the proportion of
harvest occurring within each type of fishery, and benefits were calculated for harvestable adult fish.
Details of the commercial and recreational fishing benefits analysis are provided in Chapters 6 and 7 of
this report, respectively.
3.2.4 Rationale for EPA's Approach to Valuation of IM&E
EPA's approach to estimating changes in fish harvest assumed that IM&E result in a reduction in the
number of harvestable adults, and that IM&E reductions result in increases to future fish harvests. This
approach estimates incremental fishery yield forgone because of IM&E and does not require knowledge
of population size or total yield of a fishery.
EPA's forgone fishery yield analysis requires species- and stage-specific schedules of natural mortality
(M), fishing mortality (F), and weight-at-age. The yield model assumes that these key parameters (F, M,
and weight-at-age) are independent of IM&E for all species. EPA recognizes that this assumption does
not fully reflect the dynamic nature of fish populations. However, by conducting benefits analysis using
estimates of forgone yield, EPA was able to use a simple and direct measure of the potential economic
value associated with each IM&E-related death. Used of this approach was warranted given: (1) the scope
and objectives of its analysis of harvested species, (2) data availability, and (3) difficulties in
distinguishing the causes of population changes. Each of these factors is discussed below.
3.2.4.1 Scope and Objectives of EPA's Analysis of Harvest Species
EPA's overall objective was to develop regional- and national-scale estimates of the magnitude of IM&E
at hundreds of facilities subject to the final rule. As a consequence of the large geographic scope and
multiple ecosystems involved, EPA modeled fishery yield using a relatively simplified approach to
estimate the vulnerability of dozens of species to IM&E on a national scale. Although sufficient data may
exist to model the effects of IM&E on population and community-level impacts, sufficient data do not
exist at the national scale to make such studies feasible.
11 EPA notes that its model of trophic transfer is a very simple and idealized representation of trophic dynamics; it is not
intended to capture the details of trophic transfer in actual aquatic ecosystems. In reality, food webs and trophic dynamics
are much more complex than EPA's simple model implies, and include details that are specific to each particular aquatic
ecosystem. This complexity was beyond the scope of EPA's analysis and the available data.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 3: Assessment of IM&E
Fishery
Sp ecies
Forage
Species
Trophic
Transfer
Sum
Commercial
Fraction
Recreati onal
Fraction
IM&E
Recreational
Harvest
(# offish)
Convert to
Forgone Fishery
Yield
Convert to
Age-One
Equivalent
Commercial
Harvest
(pounds)
Convert to
Forgone Fishery
Yield
Total
Forgone Fisher/
Yield
Monetize Monetize
(Chapter 6) (Chapter 7)
Figure 3-1: General Approach Used to Evaluate IM&E as Forgone Fishery Yield
3.2.4.2 Data Availability and Uncertainties Related to Modeling Fish Harvest
Forgone fishery yield and production forgone models used by EPA required age-specific life history data
for all species analyzed. EPA acknowledges that many fish population models are available, and that
these models may produce more accurate population-level impacts of IM&E. EPA did not pursue the
development of species-specific population models for several reasons:
> Constructing population models requires a large set of parameters and numerous assumptions
about the nature of stock dynamics for each species, including current stock size, stock-
recruitment relationships, changes to growth and mortality rates as a function of stock size, and
the separation of certain species into geographically based stock units. Because of these
limitations, fewer than 40 percent of U.S.-managed commercially harvested fish stocks have been
fully assessed (NMFS 2009; NMFS 2010a). As such, the information necessary to build more-
complex population models is available only for a subset of harvested species, which represent a
minor fraction of IM&E.
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Chapter 3: Assessment of IM&E
> Numerous difficulties exist in the definition of the size and spatial extent of fish stocks. As a
result, it is often unclear how IM&E at particular cooling water intake structures (CWIS) can be
related to specific stocks at a regional scale. For example, juvenile Atlantic menhaden
(Brevoortia tryannus) found in Delaware Bay recruit from both local and long distances (Light
and Able 2003). As a result, estimating the effects of local IM&E on recruitment rates would not
be sufficient to understand the stock-recruitment relationship for Delaware Bay menhaden.
Consequently, issues of data availability and difficulties estimating the effects of localized IM&E on
regional-scale fish stocks led EPA to determine that the construction of population models for all species
subject to IM&E was not feasible. The level of uncertainty that would accompany the construction of
such models (if constructing them were even possible) would be difficult to support with available data at
both the national and population level for many species.
3.2.4.3 Difficulties Distinguishing Causes of Population Changes
It is fundamentally difficult to demonstrate a causal relationship between a single stressor and changes in
fish population sizes. Fish populations are affected by multiple nonlinear stressors and are constantly in
flux. As such, determining whether changes to fish populations are the consequence of an identifiable
stressor due to natural fluctuation around an equilibrium stock size is difficult. Fish recruitment, the
number of young fish surviving early life stages (e.g., egg, larvae, juvenile) to join an adult population, is
a multidimensional process, and identifying and distinguishing the causes of variance in fish recruitment
remains a fundamental problem in fisheries science, stock management, and impact assessment (Boreman
2000; Hilborn and Walters 1992; Quinn and Deriso 1999). Consequently, resolving issues of population
fluctuation was beyond the scope and objectives of EPA's section 316(b) benefits analysis.
3.2.5 Extrapolation of IM&E to Develop Regional Estimates
EPA examined IM&E and the economic benefits of reducing these losses at a regional scale. EPA then
aggregated estimated benefits across all regions to produce a national benefits estimate. Regions were
based on regions used by fisheries management agencies such as the National Marine Fisheries Service
(NMFS). The geographical scope of all regions is described in Chapter 1 (Section 1.2).
To obtain regional IM&E estimates, EPA extrapolated losses observed at 98 facilities with IM&E data
(hereafter model facilities) to all regulated facilities within the same region. Extrapolation of IM&E rates
was necessary because only a subset of all regulated facilities have conducted IM&E studies. To allow
extrapolation, EPA assumed that all facilities, regardless of size, have similar IM&E rates after
normalization by flow. IM&E data were extrapolated on the basis of operational flow, in millions of
gallons per day (mgd), where mgd is the average operational flow over the period 1996-1998 as reported
by facilities in response to EPA's Section 316(b) Detailed Questionnaire and Short Technical
Questionnaire (USEPA 2000). Operational flow at all facilities was scaled using a multiplicative factor
that reflected the effectiveness of in-place technologies used to reduce IM&E. During the extrapolation
procedure, EPA also applied weighting factors to regulated facilities based on questionnaire results.
Weighting factors for the current analysis were based on results of the Detailed Questionnaire. Additional
details of EPA's extrapolation methods are provided in Appendix A.
The assumption that IM&E is proportional to flow is consistent with other published IM&E studies and
models. Power facilities on the Great Lakes exhibit an increasing relationship (on a log-log scale)
between facility size (measured as electrical output) and IM&E rates (Kelso and Milburn 1979), and
Goodyear (1978) predicted entrainment on the basis of the ratio of cooling water flow to source water
flow. Additionally, the Spawning and Nursery Area of Consequence (SNAC) model, used as a screening
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Chapter 3: Assessment of IM&E
tool for assessing potential IM&E impacts at Chesapeake Bay facilities, assumes that entrainment is
proportional to cooling water withdrawal rates (Polgar et al. 1979).
EPA recognizes that actual IM&E per mgd may vary substantially, resulting from a variety of time- and
facility-specific features, such as sampling date, location and type of intake structure, as well as from
ecological features that affect the abundance and species composition of fish in the vicinity of each
facility. Consequently, EPA's extrapolation procedure relies heavily on the assumption that IM&E rates
recorded at model facilities are representative of IM&E rates at other facilities in the region. Although
this assumption may not be met in some cases, limiting the extrapolation procedure within regions
reduces the likelihood that model facilities are unrepresentative.
This method of extrapolation makes the best use of a limited amount of empirical data, and is the only
feasible approach for developing a national estimate of IM&E, and the associated benefits of IM&E
reduction. While acknowledging that extrapolation introduces uncertainty into IM&E estimates, EPA has
not identified information suggesting a systematic bias in regional loss estimates based upon
extrapolation.
3.3 IM&E by Region
3.3.1 California Region
Table 3-1 and Table 3-2 present estimated baseline IM&E and reductions in IM&E under the final rule
and other options considered. Estimated total baseline IM&E in the California region is 51.55 million
AlEs per year, of which 24.56 million (47.6 percent) are forage fish. Approximately 5.6 percent of total
baseline A1E mortality is assigned a direct use value from recreational or commercial fishing (Table 3-1).
Table 1 of Appendix C presents species-specific data on impingement and entrainment under the baseline
conditions and estimated reductions under all options. Among commercially and recreationally-harvested
species, the greatest losses occur in crabs, rockfishes, and sea basses (Appendix Table C-l).
The majority of IM&E in the California region occur due to entrainment (Appendix C Table 1). Because
the final rule and Proposal Option 4 do not reduce entrainment, they each reduce baseline A IE mortality
by only 1.4 percent (0.73/51.55) and 1.3 percent (0.68/51.55), respectively (Table 3-1). Conversely, by
requiring the installation of closed-cycle recirculating systems, which effectively reduce entrainment
mortality, Proposal Option 2 reduces A1E mortality by 61.1 percent (31.52/51.55), providing more than
40 times the reduction in A1E mortality (Table 3-1).
Table 3-1: Summary of Baseline IM&E at All Regulated facilities (Manufacturing
and Generating) in California, and Reductions Under the Final Rule and Other
Options Considered
Reductions in Losses
Baseline
Losses
IM&E Loss Metric (per year)
Proposal
Option 4
Final
Rule
Proposal
Option 2
All Species (million A1E)
0.68
0.73
31.52
51.55
Forage Species (million A1E)
0.17
0.18
15.00
24.56
Commercial & Recreational Species (million A1E)
0.50
0.54
16.52
26.98
Commercial & Recreational Harvest (million fish)
0.05
0.06
1.76
2.88
A1E Losses with Direct Use Value (%)
8.0%
8.0%
5.6%
5.6%
Source: U.S. EPA analysis for this report
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Chapter 3: Assessment of IM&E
Production forgone due to baseline IM&E is estimated to be 19.65 million pounds of fish, leading to a
decrease in fishery yield of 4.59 million pounds per year (Table 3-2). The final rule is estimated to result
in increased fishery yields of 0.02 million pounds per year. Increases in fishery yields under other options
considered range from 0.02 million pounds per year under Proposal Option 4 to 2.80 million pounds per
year under Proposal Option 2. Estimated increases in fishery yields under Proposal Option 2 are more
than 100 times greater than under the final rule and Proposal Option 4 (Table 3-2).
Table 3-2: Baseline Losses in Fishery Yield, Catch, and Production
Forgone as a Consequence of IM&E at All Regulated facilities
(Manufacturing and Generating) in California, and Reductions Under
the Final Rule and Other Options Considered
Reductions in Losses
Baseline
Losses
IM&E Loss Metric (million per year)
Proposal
Option 4
Final
Rule
Proposal
Option 2
Forgone Fishery Yield (lbs)
0.02
0.02
2.80
4.59
Forgone Commercial Catch (lbs)
<0.01
<0.01
1.18
1.93
Forgone Recreational Catch (fish)
0.04
0.04
0.88
1.43
Production Forgone (lbs)
0.09
0.10
12.00
19.65
Source: U.S. EPA analysis for this report
Raw numbers of IM&E in California can be found in Appendix Table C-2.
3.3.2 North Atlantic Region
Table 3-3 and Table 3-4 present estimated baseline IM&E and reductions in IM&E under the final rule
and other options considered. Estimated total baseline IM&E in the North Atlantic region is 57.86 million
AlEs per year, 78.4 percent (45.34 million) of which are forage fish. Approximately 2.1 percent of total
baseline A1E mortality is assigned a direct use value from recreational or commercial fishing (Table 3-3).
Table 3 of Appendix C presents species-specific data on impingement and entrainment under the baseline
conditions and estimated reductions under all options. Briefly, the vast majority (99.0 percent) of all A1E
mortality in the North Atlantic occur as a consequence of entrainment mortality (Appendix Table C-3).
Notably, the combined IM&E of winter flounder, cunner, and sculpins account for 96.9 percent of all
IM&E of commercially and recreationally-harvested species.
Because the final rule and Proposal Option 4 do not reduce entrainment, they reduce baseline IM&E A IE
mortality by 1.6 percent (0.93/57.86) and 0.7 percent (0.40/57.86), respectively (Table 3-3). Conversely,
by requiring the installation of closed-cycle recirculating systems, which effectively reduce entrainment
mortality, Proposal Option 2 reduces A1E mortality by 76.7 percent (44.40/57.86) (Table 3-3).
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Chapter 3: Assessment of IM&E
Table 3-3: Baseline IM&E and IM&E Reductions at All Regulated Facilities
(Manufacturing and Generating) in the North Atlantic, and Reductions Under the
Final Rule and Other Options Considered
Reductions in Losses
Baseline
Losses
IM&E Loss Metric (per year)
Proposal
Option 4
Final
Rule
Proposal
Option 2
All Species (million A1E)
0.40
0.93
44.40
57.86
Forage Species (million A1E)
0.35
0.77
34.80
45.34
Commercial & Recreational Species (million A1E)
0.05
0.16
9.60
12.52
Commercial & Recreational Harvest (million fish)
<0.01
0.02
0.91
1.19
A1E Losses with Direct Use Value (%)
1.5%
1.8%
2.1%
2.1%
Source: U.S. EPA analysis for this report
Production forgone due to baseline IM&E is estimated to be 26.03 million pounds of fish, leading to a
decrease in fishery yield of 0.98 million pounds per year (Table 3-4). The final rule will result in
increased fishery fields of 0.01 million pounds per year. Increases in fishery yields under other options
considered range from less than 0.01 million pounds under Proposal Option 4 to 0.75 million pounds
under Proposal Option 2. Estimated increases in fishery yields under Proposal Option 2 are more than 75
times greater than under the final rule and Proposal Option 4 (Table 3-4).
Table 3-4: Baseline Losses in Fishery Yield, Catch, and Production
Forgone as a Consequence of IM&E at All Regulated Facilities
(Manufacturing and Generating) in the North Atlantic, and Reductions
Under the Final Rule and Other Options Considered
IM&E Loss Metric (million per year)
Reductions in Losses
Baseline
Losses
Proposal
Option 4
Final
Rule
Proposal
Option 2
Forgone Fishery Yield (lbs)
<0.01
0.01
0.75
0.98
Forgone Commercial Catch (lbs)
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Chapter 3: Assessment of IM&E
Because of the high proportion of IM&E attributed to entrainment mortality, EPA estimates that the final
rule and Proposal Option 4 reduce A1E mortality by 5.2 percent (32.99/630.97) and 4.8 percent
(30.50/630.97), respectively (Table 3-5). Conversely, by requiring the installation of closed-cycle
recirculating systems, Proposal Option 2 would reduce A1E mortality by approximately 87.4 percent
(551.90/630.97).
Table 3-5: Baseline IM&E and IM&E Reductions at All Regulated Facilities
(Manufacturing and Generating) in the Mid-Atlantic, and Reductions Under the
Final Rule and Other Options Considered
Reductions in Losses
Baseline
Losses
IM&E Loss Metric (per year)
Proposal
Option 4
Final
Rule
Proposal
Option 2
All Species (million A1E)
30.50
32.99
551.90
630.97
Forage Species (million A1E)
11.63
12.75
415.46
475.89
Commercial & Recreational Species (million A1E)
18.87
20.25
136.44
155.08
Commercial & Recreational Harvest (million fish)
4.68
5.01
18.20
20.51
A1E Losses with Direct Use Value (%)
15.3%
15.2%
3.3%
3.3%
Source: U.S. EPA analysis for this report
EPA projects that baseline IM&E reduces fishery production by 52.74 million pounds, and decreases
fishery yield by 15.07 million pounds per year (Table 3-6). The final rule will result in increased fishery
yields of 3.89 million pounds per year. Increases in fishery yields under other options considered range
from 3.63 million pounds per year under Proposal Option 4 to 13.38 million pounds per year under
Proposal Option 2. Estimated increases in fishery yields under Proposal Option 2 are more than three
times greater than under the final rule and Proposal Option 4 (Table 3-6).
Table 3-6: Baseline Losses in Fishery Yield, Catch, and Production
Forgone as a Consequence of IM&E at All Regulated Facilities
(Manufacturing and Generating) in the Mid-Atlantic, and Reductions
Under the Final Rule and Other Options Considered
Reductions in Losses
Baseline
Losses
IM&E Loss Metric (million per year)
Proposal
Option 4
Final
Rule
Proposal
Option 2
Forgone Fishery Yield (lbs)
3.63
3.89
13.38
15.07
Forgone Commercial Catch (lbs)
2.87
3.07
7.17
8.00
Forgone Recreational Catch (fish)
0.43
0.46
5.10
5.82
Production Forgone (lbs)
7.83
8.40
46.50
52.74
Source: U.S. EPA analysis for this report
Raw numbers of IM&E in the Mid-Atlantic region can be found in Appendix Table C-6.
3.3.4 South Atlantic Region
Table 3-7 and Table 3-8 present estimated baseline IM&E and reductions in IM&E under the final rule
and other options considered. Estimated total baseline IM&E in the South Atlantic region is estimated to
be 26.36 million AlEs per year, including 24.61 million forage fish AlEs. Approximately 1.1 percent of
total baseline A IE mortality is assigned a direct use value from recreational or commercial fishing (Table
3-7). Table 7 of Appendix C presents species-specific data on impingement and entrainment under the
May 2014
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Chapter 3: Assessment of IM&E
baseline conditions and estimated reductions under all options. Unlike other regions, the majority (65.0
percent) of all A IE mortality in the South Atlantic occur as a consequence of impingement mortality.
Among commercially- and recreationally-harvested species, IM&E is greatest in Drums and Croakers and
Blue Crab.
Due to the high proportion of IM&E lost to impingement, the final rule and Proposal Option 4 are
projected to reduce A1E mortality by 49.1 percent (12.93/26.36) and 44.0 percent (11.61/26.36),
respectively. However, because the installation of closed-cycle recirculating systems reduces water usage,
Proposal Option 2 is projected to reduce A1E mortality by 97.1 percent (25.60/26.36) (Table 3-7).
Table 3-7: Baseline IM&E and IM&E Reductions at All Regulated Facilities
(Manufacturing and Generating) in the South Atlantic, and Reductions Under the
Final Rule and Other Options Considered
IM&E Loss Metric (per year)
Reductions in Losses
Baseline
Losses
Proposal
Option 4
Final
Rule
Proposal
Option 2
All Species (million A1E)
11.61
12.93
25.60
26.36
Forage Species (million A1E)
10.98
12.21
23.91
24.61
Commercial & Recreational Species (million A1E)
0.63
0.72
1.69
1.75
Commercial & Recreational Harvest (million fish)
0.09
0.10
0.27
0.28
A1E Losses with Direct Use Value (%)
0.7%
0.8%
1.0%
1.1%
Source: U.S. EPA analysis for this report
Production forgone due to baseline IM&E is estimated to be 0.71 million pounds per year, leading to a
decrease in fishery yield of approximately 0.12 million pounds per year. The final rule will increase
fishery yields of 0.05 million pounds per year. Increases in fishery yields under other options considered
range from 0.04 million pounds per year under Proposal Option 4 to 0.12 million pounds per year under
Proposal Option 2. Estimated increases in fishery yields under Proposal Option 2 are more than two times
greater than under the final rule and Proposal Option 4 (Table 3-8).
Table 3-8: Baseline Losses in Fishery Yield, Catch, and Production
Forgone as a Consequence of IM&E at All Regulated Facilities
(Manufacturing and Generating) in the South Atlantic, and Reductions
Under the Final Rule and Other Options Considered
Reductions in Losses
Baseline
Losses
IM&E Loss Metric (million per year)
Proposal
Option 4
Final
Rule
Proposal
Option 2
Forgone Fishery Yield (lbs)
0.04
0.05
0.12
0.12
Forgone Commercial Catch (lbs)
0.04
0.04
0.08
0.08
Forgone Recreational Catch (fish)
0.01
0.02
0.10
0.1 1
Production Forgone (lbs)
0.12
0.15
0.67
0.71
Source: U.S. EPA analysis for this report
Raw numbers of IM&E in the South Atlantic region can be found in Appendix Table C-8.
3.3.5 Gulf of Mexico Region
Table 3-9 and Table 3-10 present the estimated baseline IM&E and reductions in IM&E under the final
rule and other options considered. Estimated total baseline IM&E in the Gulf of Mexico is estimated to be
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Chapter 3: Assessment of IM&E
147.01 million AlEs per year, including 50.15 million forage fish AlEs. Approximately 8.8 percent of
total baseline A IE mortality are assigned a direct use value from recreational or commercial fishing
(Table 3-9). Table 9 of Appendix C presents species-specific data on impingement and entrainment under
the baseline conditions and estimated reductions under all options. The majority (63.6 percent) of all A1E
mortality in the Gulf of Mexico occur as a consequence of entrainment mortality. Among commercially -
and recreationally-harvested species, IM&E is greatest in Blue Crab, and Pink Shrimp, which together
account for 67.8 percent of A IE mortality with direct use value. Other commercially- or recreationally-
harvested fish species with substantial IM&E (i.e., greater than 5 million A1E) include Black Drum,
Menhaden, and Silver Perch (Appendix Table C-9).
Due to the low proportion of IM&E lost to impingement, the final rule and Proposal Option 4 are
projected to reduce A1E mortality by 27.4 percent (40.29/147.01) and 26.4 percent (38.82/147.01),
respectively. In contrast, Proposal Option 2 is estimated to reduce A IE mortality by 70.3 percent
(103.42/147.01) (Table 3-9), nearly triple the estimated reductions of the final rule or Proposal Option 4.
Table 3-9: Baseline IM&E and IM&E Reductions at All Regulated Facilities
(Manufacturing and Generating) in the Gulf of Mexico, and Reductions Under the
Final Rule and Other Options Considered
Reductions in Losses
Baseline
Losses
IM&E Loss Metric (per year)
Proposal
Option 4
Final
Rule
Proposal
Option 2
All Species (million A1E)
38.82
40.29
103.42
147.01
Forage Species (million A1E)
4.88
5.06
31.69
50.15
Commercial & Recreational Species (million A1E)
33.94
35.22
71.73
96.86
Commercial & Recreational Harvest (million fish)
54 5
5.35
9.83
12.92
A1E Losses with Direct Use Value (%)
13.3%
13.3%
9.5%
0s
00
OO
Source: U.S. EPA analysis for this report
Production forgone due to baseline IM&E is estimated to be 79.65 million pounds per year, 43.3 percent
of which is forgone fishery yield. The final rule will result in increased fishery yields of 3.51 million
pounds per year. Increases in fishery yields under other options considered range from 3.38 million
pounds per year under Proposal Option 4 to 21.78 million pounds per year under Proposal Option 2.
Estimated increases in fishery yields under Proposal Option 2 are more than six times greater than under
the final rule and Proposal Option 4 (Table 3-10).
Table 3-10: Baseline Losses in Fishery Yield, Catch, and Production
Forgone as a Consequence of IM&E at All Regulated Facilities
(Manufacturing and Generating) in the Gulf of Mexico, and Reductions
Under the Final Rule and Other Options Considered
Reductions in Losses
Baseline
Losses
IM&E Loss Metric (million per year)
Proposal
Option 4
Final
Rule
Proposal
Option 2
Forgone Fishery Yield (lbs)
3.38
3.51
21.78
34.45
Forgone Commercial Catch (lbs)
1.64
1.70
4.27
6.03
Forgone Recreational Catch (fish)
0.75
0.78
2.14
3.08
Production Forgone (lbs)
6.54
6.78
49.81
79.65
Source: U.S. EPA analysis for this report
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Chapter 3: Assessment of IM&E
Raw numbers of IM&E in the Gulf of Mexico can be found in Appendix Table C-10.
3.3.6 Great Lakes Region
Table 3-11 and Table 3-12 present estimated baseline IM&E and reductions in IM&E under the final rule
and other options considered. Estimated total baseline IM&E in the Great Lakes is 261.26 million AlEs
per year, including 240.01 million A1E of forage fish. Approximately 1.7 percent of total baseline A1E
mortality is assigned a direct use value from recreational or commercial fishing (Table 3-11). Table 11 of
Appendix C presents species-specific data on impingement and entrainment under the baseline conditions
and estimated reductions under all options. Briefly, among commercially and recreationally-harvested
species, the greatest losses occur in Smelts.
The vast majority (90.6 percent) of IM&E in the Great Lakes occur due to impingement (Appendix Table
C-l 1). Accordingly, the final rule and Proposal Option 4 are projected to reduce baseline A IE mortality
by 81.5 percent (202.58/248.47) and 70.4 percent (184.04/261.26), respectively (Table 3-11). By
requiring the installation of closed-cycle recirculating systems, which reduce the volume of water
required for cooling purposes, Proposal Option 2 reduces A1E mortality by 95.1 percent (248.47/261.26)
(Table 3-11).
Table 3-11: Baseline IM&E and IM&E Reductions at All Regulated Facilities
(Manufacturing and Generating) in the Great Lakes, and Reductions Under the
Final Rule and Other Options Considered
IM&E Loss Metric (per year)
Reductions in Losses
Baseline
Losses
Proposal
Option 4
Final
Rule
Proposal
Option 2
All Species (million A1E)
184.04
202.58
248.47
261.26
Forage Species (million A1E)
175.88
193.58
230.50
240.01
Commercial & Recreational Species (million A1E)
8.16
9.00
17.97
21.25
Commercial & Recreational Harvest (million fish)
2.58
2.84
3.98
4.35
A1E Losses with Direct Use Value (%)
1.4%
1.4%
1.6%
1.7%
Source: U.S. EPA analysis for this report
Production forgone due to baseline IM&E is estimated to be 63.28 million pounds of fish, leading to a
decrease in fishery yield of 4.14 million pounds per year (Table 3-12). The final rule will result in
increased fishery yields of 2.69 million pounds per year. Increases in fishery yields under other options
considered range from 2.44 million pounds per year under Proposal Option 4 to 3.78 million pounds per
year under Proposal Option 2. Estimated increases in fishery yields under Proposal Option 2 are over 40
percent greater than under the final rule or Proposal Option 4 (Table 3-12).
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 3: Assessment of IM&E
Table 3-12: Baseline Losses in Fishery Yield, Catch, and Production
Forgone as a Consequence of IM&E at All Regulated Facilities
(Manufacturing and Generating) in the Great Lakes, and Reductions
Under the Final Rule and Other Options Considered
Reductions in Losses
Baseline
Losses
IM&E Loss Metric (million per year)
Proposal
Option 4
Final
Rule
Proposal
Option 2
Forgone Fishery Yield (lbs)
2.44
2.69
3.78
4.14
Forgone Commercial Catch (lbs)
FI2
1.24
1.70
1.84
Forgone Recreational Catch (fish)
1.33
1.47
2.04
2.23
Production Forgone (lbs)
30.67
33.79
55.61
63.28
Source: U.S. EPA analysis for this report
Raw numbers of IM&E in the Great Lakes region can be found in Appendix Table C-12.
3.3.7 Inland Region
Table 3-13 and Table 3-14 present estimated baseline IM&E and reductions in IM&E under the final rule
and other options considered. Estimated total baseline IM&E in the Inland region is 755.97 million AlEs
per year, including 599.13 million A1E of forage fish. Approximately 1.6 percent of total baseline A1E
mortality is assigned a direct use value from recreational or commercial fishing (Table 3-13). Table 13 of
Appendix C presents species-specific data on impingement and entrainment under the baseline conditions
and estimated reductions under all options. Briefly, the majority (63.0 percent) of all A1E mortality in the
Inland region occur as a consequence of impingement mortality (Appendix Table C-13). Notably, the
IM&E of sunfish account for 78.4 percent of the IM&E of recreationally-harvested species.
The final rule and Proposal Option 4 are projected to reduce baseline A IE mortality by 47.8 percent
(361.55/755.97) and 46.0 percent (348.12/755.97), respectively (Table 3-13). The installation of closed-
cycle recirculating systems under Proposal Option 2 reduces A1E mortality by 83.6 percent
(632.19/755.97), providing a benefit more than 70 percent larger than the benefits of the final rule or
Proposal Option 4 (Table 3-13).
Table 3-13: Baseline IM&E and IM&E Reductions at All Regulated Facilities
(Manufacturing and Generating) in the Inland Region, and Reductions Under the
Final Rule and Other Options Considered
IM&E Loss Metric (per year)
Reductions in Losses
Baseline
Losses
Proposal
Option 4
Final
Rule
Proposal
Option 2
All Species (million AI F)
348.12
36F55
632.19
755.97
Forage Species (million AI F)
324.34
336.25
507.31
599.13
Commercial & Recreational Species (million AI F)
23.79
25.31
124.88
156.84
Commercial & Recreational Harvest (million fish)
3.57
3.73
9.70
11.90
A1E Losses with Direct Use Value (%)
1.0%
1.0%
1.5%
1.6%
Source: U.S. EPA analysis for this report
The decrease in production due to baseline IM&E is estimated to be 384.55 million pounds of fish,
leading to a decrease in fishery yield of 10.41 million pounds per year (Table 3-14). The final rule will
result in increased fishery yields of 3.25 million pounds per year. Increases in fishery yield under other
options considered range from 3.11 million pounds per year under Proposal Option 4 to 8.48 million
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 3: Assessment of IM&E
pounds per year under Proposal Option 2. Estimated increases in fishery yields under Proposal Option 2
are over two times greater than under the final rule and Proposal Option 4 (Table 3-14).
Table 3-14: Baseline Losses in Fishery Yield, Catch, and Production
Forgone as a Consequence of IM&E at All Regulated Facilities
(Manufacturing and Generating) in the Inland Region, and Reductions
Under the Final Rule and Other Options Considered
Reductions in Losses
Baseline
Losses
IM&E Loss Metric (million per year)
Proposal
Option 4
Final
Rule
Proposal
Option 2
Forgone Fishery Yield (lbs)
3.1 I
3.25
8.48
10.41
Forgone Commercial Catch (lbs)
<0.01
<0.01
<0.01
<0.01
Forgone Recreational Catch (fish)
3.57
3.73
9.70
1 1.90
Production Forgone (lbs)
84.97
89.40
309.65
384.55
Source: U.S. EPA analysis for this report
Raw numbers of IM&E in the Inland region can be found in Appendix Table C-14.
3.3.8 National Estimates
Table 3-15 and Table 3-16 present estimated baseline IM&E and reductions in IM&E under the final rule
and other options considered. Estimated total baseline IM&E nationally is 1,930.97 million AlEs per
year, including 1,459.70 million A1E of forage fish. Approximately 2.8 percent of total baseline A1E
mortality is assigned a direct use value from recreational or commercial fishing (Table 3-15). Table 15 of
Appendix C presents species-specific data on impingement and entrainment under the baseline conditions
and estimated reductions under all options. Briefly, the majority (57.3 percent) of all A1E mortality
nationally occur as a consequence of entrainment mortality (Appendix Table C-15).
The final rule and Proposal Option 4 are projected to reduce baseline A IE mortality by 33.8 percent
(652.00/1,930.97) and 31.8 percent (614.16/1,930.97), respectively (Table 3-15). The installation of
closed-cycle recirculating systems under Proposal Option 2 reduces A IE mortality by 84.8 percent
(1,637.49/1,930.97), providing a benefit more than twice as large as the benefits of the final rule or
Proposal Option 4 (Table 3-15).
Table 3-15: Baseline IM&E and IM&E Reductions at All Regulated Facilities
(Manufacturing and Generating) Nationally, and Reductions Under the Final Rule
and Other Options Considered
Reductions in Losses
Baseline
Losses
IM&E Loss Metric (per year)
Proposal
Option 4
Final
Rule
Proposal
Option 2
All Species (million A1E)
614.16
652.00
1637.49
1930.97
Forage Species (million A1E)
528.22
560.80
1258.67
1459.70
Commercial & Recreational Species (million A1E)
85.94
91.20
378.82
471.28
Commercial & Recreational Harvest (million fish)
16.13
17.11
44.66
54.02
A1E Losses with Direct Use Value (%)
2.6%
2.6%
2.7%
2.8%
Source: U.S. EPA analysis for this report
The decrease in production due to baseline IM&E is estimated to be 626.60 million pounds of fish,
leading to a decrease in fishery yield of 69.76 million pounds per year (Table 3-16). The final rule is
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 3: Assessment of IM&E
estimated to result in an increased fishery yield 13.42 million pounds per year. Increases in fishery yields
under other options considered range from 12.63 million pounds per year under Proposal Option 4 to
51.11 million pounds per year under Proposal Option 2. Estimated increases in fishery yields under
Proposal Option 2 are nearly four times greater than under than final rule or Proposal Option 4 (Table
3-16).
Table 3-16: Baseline Losses in Fishery Yield, Catch, and Production
Forgone as a Consequence of IM&E at All Regulated Facilities
(Manufacturing and Generating) Nationally, and Reductions Under the
Final Rule and Other Options Considered
Reductions in Losses
Baseline
Losses
IM&E Loss Metric (million per year)
Proposal
Option 4
Final
Rule
Proposal
Option 2
Forgone Fishery Yield (lbs)
12.63
13.42
51.11
69.76
Forgone Commercial Catch (lbs)
5.68
6.07
14.72
18.32
Forgone Recreational Catch (fish)
6.13
6.50
20.53
25.31
Production Forgone (lbs)
130.25
138.89
494.17
626.60
Source: U.S. EPA analysis for this report
Raw numbers of national IM&E can be found in Appendix Table C-16.
3.4 Limitations and Uncertainties
Four major kinds of uncertainty may lead to imprecision and bias in EPA's IM&E analysis: data,
structural, statistical, and engineering uncertainty. Data limitations and uncertainty refers to uncertainty
and inconsistency in sampling methodologies used in facility-specific IM&E studies. Structural
uncertainty reflects the simplification built into any model of a complex natural system. Parameter
uncertainty refers to uncertainty in the numeric estimates of model parameters. Finally, engineering
uncertainty refers to the fact that facilities do not operate in the exact same manner on an annual basis.
3.4.1 Data Limitation and Uncertainty
EPA based its quantification of regional and national IM&E on cumulative data generated by collection at
individual facilities. In turn, these data are heterogeneous products of location-specific investigations set
in differing geographic and ecological provinces. Interpretation of the significance and trends of IM&E at
regional and national scales (and of the accompanying ecological benefits upon mitigation) must consider
the strengths and weaknesses of this data.
The IM&E data from model facilities constitute a heterogeneous composite of results from many facility-
specific studies. Sampling effort and data quality control vary tremendously among IM&E studies and
baseline source water characterization programs. There is little uniformity among studies as to the
intensity, frequency and duration of data collection as well as the scope of target biota collected,
identified, and enumerated. Sampling regimes may be properly adjusted to ensure that changes in local
biotic activity associated with diurnal, tidal, and lunar cycles are incorporated; or may reflect regularly
spaced sampling points with little concern paid to capturing environmental variability.
In addition to the differences in environmental scope, sampling methods are not uniform among studies
with regard to the types and meshes of sampling nets, deployment location of sampling nets (e.g., outside
or within the intake structure), length and weight measurements, observations of field conditions,
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 3: Assessment of IM&E
characterization of reference areas, etc. In addition to different sampling methods and timing, some
sampling programs are designed primarily to estimate IM&E for a select suite of recreational or
commercially important aquatic organisms. Studies differ in their taxonomic sorting classes and
specificity of identification of impinged and entrained organisms (e.g., eggs, ichthyoplankton,
zooplankton, etc.). Thus, many IM&E studies are poorly suited to provide insight into the direct and
indirect impacts to forage fish species, non-vertebrate organisms (zooplankton, tunicates, algae, worms,
etc.), or community/ecosystem impacts. For older facilities, sampling data commonly lack pre-operational
(i.e., baseline) samples or community surveys to compare to the results of more-current IM&E data.
Finally, few IM&E studies are designed to allow evaluation of community impacts or ecosystem effects
(Section 2.4).
Within regions, studies of IM&E from model facilities are typically composed of data from a relatively
limited number of facilities. Most facility-specific IM&E studies are limited to one or two years, and are
rarely replicated within a time period that allows direct comparison of trends without historical
complications due to fishery stock trends, climatic changes, or shifts in collection methods or water
quality. Thus, studies within a regional database may not accurately represent average climatic and
oceanographic conditions (e.g., El Nino years). Additionally, studies within the database may include
historical (>20 years ago) and recent data, thus incorporating considerable uncertainty due to the annual
variability of highly dynamic fish stocks. Thus, extrapolation from regional collections of facility-specific
studies may not provide a true regional estimate because the available data may or may not be fully
representative of regional trends and/or of associated ecological benefits derived from mitigating IM&E
impacts.
3.4.2 Structural Uncertainty
The models EPA used to evaluate IM&E simplify complex processes. The degree of simplification is
substantial, but necessary, because of limited data availability and the need to generate estimates on a
national scale. Simplification occurs with respect to many processes within the model, to ensure
computational tractability and national applicability (Table 3-17).
While EPA recognizes these uncertainties, addressing each of these uncertainties in a defensible way
would require data that does not currently exist (see Section 3.2.4.2), would be time-consuming and
resource-intensive to develop, and could lead to greater parameter uncertainty (Section 3.4.3).
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 3: Assessment of IM&E
Table 3-17: Structural Uncertainties
Aspect of Model
General Description
Specific Treatment in Model
Biological
submodels
Life history traits are fixed
Life history parameters in the models (i.e., growth, survival) are constant
through time and are thus independent of biological conditions (e.g., fish
densities, seasonality, weather, recruitment variability, food availability,
fisheries pressure, etc.).
No trophic effects
Indirect food web effects such as trophic cascades, growth and population
limitations due to a lack of food, etc., are not considered. Trophic transfer
is treated simplistically.
Outside impacts not addressed
IM&E loss rates are affected by a variety of outside influences not included
in the model (e.g., fisheries pressure, pollution, future development,
invasive species, climate change, etc.).
Valuation
structure
National nonuse benefits
Fish species grouped into two categories: harvested or not harvested (i.e.,
forage for harvested species). Harvested fish are assigned use values within
the national analysis. EPA used benefit transfer to estimate nonuse values
for the North Atlantic and Mid-Atlantic regions (Chapter 8). Nonuse values
for other regions are not included in the comparison of benefits and costs
for the final rule. EPA also conducted a stated preference survey to assess
total values (Chapter 10). EPA, however, did not include survey estimates
in its benefits totals for the rule but the estimates illustrate the potential
magnitude of total values.
Fishing pressure constant
The valuation procedure assumes that fisheries harvests will increase
proportionately to decreases in IM&E, independent of Federal and State
policies on commercial and recreational fishing (i.e., fisheries quotas,
closures, bag limits, etc.).
3.4.3 Parameter Uncertainty
Parameter uncertainty refers to variability in the value of parameters used in biological and economic
modeling. EPA must estimate all parameters from sampling studies that cannot identify the true values of
interest due to statistical and logistical limitations. These limitations are broadly driven by three
processes, including parameter fluctuation through time, geographic location, and sampling.
The true value of many biological parameters fluctuates on an annual basis, due to changes in weather,
food availability, indirect food-web effects, and compensatory population dynamics. Consequently,
parameter values used within biological submodels, despite being based upon the best available data
obtained from the scientific literature, cannot be without error due to annual variability in fish growth and
(natural and fisheries) mortality rates. Similarly, because IM&E rates are driven by a combination of
intake flow and the presence of vulnerable fish, actual IM&E cannot remain constant through time.
True values of biological parameters and facility IM&E vary geographically. Biological parameters may
vary substantially within regions due to changes in substrate, water temperature and salinity, etc., while
facility IM&E data may be strongly connected to local substrates, distance from shore, depth, etc. It
follows, then, that using biological data and extrapolating facility-specific IM&E rates to the regional
scale will result in parameter variability based solely on geographic considerations.
Finally, all model parameters contain uncertainty because they are small samples taken from a much
larger dataset. Biological parameters such as mortality rates must be estimated using incomplete sampling
data. Facility-reported IM&E studies necessarily subsample cooling water, and often do not take replicate
samples across tidal periods, seasons, time of day, and between years. Moreover, these studies often
present IM&E with limited taxonomic detail (i.e., the identification of eggs, larvae, and juveniles is not
species-specific), and do not have standard methodologies. As is the case with retrospective data, these
studies also reflect the biological and physical state of the waterbody when studies were conducted. In
some cases, the state of the waterbody itself has changed substantially since sampling was conducted.
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EPA recognizes many sources of parameter uncertainty in its models (Table 3-18), all of which lead to
uncertainty in point estimates of IM&E. The nature of these uncertainties, however, does not inherently
bias the point estimate. EPA reported all biological and physical parameters in good faith, and as such,
parameter estimates are unlikely to be biased in aggregate, but distributed both above and below true
parameter values. Thus, parameter uncertainty has resulted in imprecision rather than inaccuracy in model
output.12
3.4.4 Engineering Uncertainty
EPA's evaluation of IM&E was also affected by uncertainty about the engineering and operating
characteristics of the study facilities. It is unlikely that facility operating characteristics (e.g., seasonal,
diurnal, or intermittent changes in intake water flow rates) are constant throughout any particular year. As
such, the timing of sampling, and the annual repeatability of IM&E, may be biased by facility operating
conditions. EPA assumed that the facilities" loss estimates were provided in good faith and did not
include any biases or omissions that significantly modified loss estimates.
12
"* Accuracy refers to the degree of closeness of model results to the actual value. Precision refers to the reproducibility of model
output, or the degree to which repeated measurements (or samples, for example from different model facilities) under similar
conditions will result in the same model output.
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Table 3-18: Parameters Included in EPA's IM&E Analysis Subject to Uncertainty
Model Aspect
Parameter
Description
IM&E monitoring
/loss rate estimates
Sampling regimes
Sampling regimes are subject to numerous facility-specific details. No
established guidelines or performance standards for how to design and conduct
sampling regimes. Not all sampling studies measured both impingement and
entrainment mortality.
Extrapolation
assumptions
Extrapolation of monitoring data to annual IM&E rates assumes sampling
occurred under average conditions, and that diurnal/seasonal/annual cycles in
fish presence and vulnerability and various technical factors (e.g., net
collection efficiency; hydrological factors affecting IM&E rates) do not play a
substantial role in the accuracy of extrapolation. No established guidelines or
consistency in sampling regimes.
Species selection
Criteria for the selection of species evaluated in IM&E studies are neither
well-defined nor uniform across facilities. At many facilities, IM&E data was
collected for only a subset of species, usually only fish and shellfish.
Sensitivity of fish to
IM&E
Entrainment mortality was assumed by EPA to be 100 percent. Back-
calculations were done in cases where facilities reported entrainment rates that
assumed <100 percent mortality. These calculations were limited by data
reporting (i.e., species-specific survival rates were not always provided).
Impingement survival was included if presented in facility documents.
Biological/life
history
Natural mortality rates
Natural mortality rates (M) difficult to estimate, and vary with time and
geography. Model results are highly sensitive to M.
Growth rates
Simple exponential growth rates or simple size-at-age parameters used, and
assumed constant across all locations and years.
Geographic
considerations
Migration patterns; IM&E occurring during spawning runs or larval out-
migration; location of harvestable adults; intermingling with other stocks.
Forage valuation
Harvested species assumed to be food limited; trophic transfer efficiency to
harvested species estimated by EPA based on general models; no consideration
of trophic transfer to species not impinged and enframed.
Fish stock
characteristics
Fishery yield
For most harvested species, only one species-specific value for fishing
mortality rate (F) was used for all stages subject to harvest. Used stage-specific
constants for fraction vulnerable to fishery.
Harvest behavior
No assumed dynamics among harvesters to alter fishing rates or preferences in
response to changes in stock size. Recreational access assumed constant (no
changes in angler preferences or effort).
Stock interactions
IM&E assumed to be part of reported fishery yield rates on a statewide basis.
No consideration of possible substock harvest rates or interactions, no
unreported catch.
Ecological
system
Fish community
Long-term trends in fish community composition or abundance were not
considered (general food webs assumed to be static), nor were indirect trophic
interactions. Used constant value for trophic transfer efficiency, and specific
trophic interactions were not considered. Trophic transfer to organisms not
impinged and entrained is not considered.
Spawning dynamics
Sampled years assumed to be typical with respect to choice of spawning areas
and timing of migrations that could affect vulnerability to IM&E
(e.g., presence of larvae in vicinity of intake structure).
Hydrology
Sampled years assumed to be typical with respect to flow regimes and tidal
cycles that could affect vulnerability to IM&E (e.g., presence of larvae in
vicinity of CWIS).
Meteorology
Sampled years assumed to be typical with respect to vulnerability to IM&E
(e.g., presence of larvae in vicinity of intake structure).
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Chapter 4: Economic Benefit Categories
4 Economic Benefit Categories
Changes in CWIS design or operations resulting from the final section 316(b) rule for regulated facilities
are expected to reduce IM&E of fish, shellfish, and other aquatic organisms, thereby increasing the
numbers of aquatic organisms and local and regional fishery populations.
The aquatic organisms affected by CWIS provide a wide range of ecosystem services. Ecosystem services
are the physical, chemical, and biological functions performed by natural resources and the human
benefits derived from those functions, including both ecological and human use services (Daily 1997;
Daily et al. 1997). Scientific and public interest in protecting ecosystem services is increasing with the
recognition that these services are vulnerable to a wide range of human activities and are difficult, if not
impossible, to replace with human technologies (Meffe 1992).
In addition to their importance in providing food and other goods of direct use to humans, the organisms
lost to IM&E are critical to the continued functioning of the ecosystems of which they are a part. Fish are
essential for energy transfer in aquatic food webs, regulation of food web structure, nutrient cycling,
maintenance of sediment processes, redistribution of bottom substrates, the regulation of carbon fluxes
from water to the atmosphere, and the maintenance of aquatic biodiversity (Holmlund and Hammer 1999;
Peterson and Lubchenco 1997; Postel and Carpenter 1997; Wilson and Carpenter 1999). Many of these
ecosystem services can be maintained only by the continued presence of all life stages of fish and other
aquatic species in their natural habitats. Section 2.3 provides detail on potential CWIS impacts on aquatic
ecosystems, but because of inadequate data, EPA could not evaluate or monetize many of these impacts.
In addition to economic benefits categories associated with the reductions in IM&E, EPA also assessed
benefits associated with changes in carbon dioxide (C02) emissions. EPA monetized these benefits based
on the social cost of carbon. Social cost of carbon is an "estimate of the monetized damages associated
with an incremental increase in carbon emissions in a given year" and it "is intended to include (but is not
limited to) changes in net agricultural productivity, human health, property damages from increased flood
risk, and the value of ecosystem services due to climate change" (Interagency Working Group 2010, p.l).
The following sub-sections focus on benefits categories associated with IM&E reductions. See Chapter 9
for additional discussion of benefits from changes in emissions based on the social cost of carbon.
4.1 Economic Benefit Categories of the Rule
The economic benefits of reducing IM&E at regulated facilities stem from both market and nonmarket
goods and services that the affected resources provide. These benefits can be divided into the following
categories (Table 4-1, below).
> Market benefits: Market benefits are positive welfare impacts that can be quantified using
money-denominated measures of consumer and producer surplus. The most obvious example of
market benefits from reduced IM&E is benefits to commercial fisheries. Changes in IM&E will
directly affect the price, quantity, and/or quality of fish harvests. The monetary value of the
changes can be measured directly through market measures of consumer and producer behavior.
Market benefits may be further categorized in terms of direct and indirect benefits. By definition,
all market benefits are use benefits, as they involve either direct or indirect uses of goods or
services.
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¦ Market direct use benefits: These benefits are related to goods directly used, and bought
and sold in markets; for example, fish caught for sale to consumers.
¦ Market indirect use benefits: These benefits occur through indirect or secondary effects on
marketed goods and contribute indirectly to an increase in welfare for users of the resource.
For example, an increase in the number of forage fish may increase the population of
commercially valuable species, which are marketed to consumers. Thus, reducing IM&E of
forage species can result in indirect welfare gains for commercial fishers and consumers who
purchase fish.
> Nonmarket benefits: Nonmarket benefits consist of goods and services that are not traded in the
marketplace, but are nonetheless positively affected by reduced IM&E. Higher catch rates for
recreational fishing are a nonmarket benefit. Anglers place a high value on catching fish during
their fishing trips, so higher catch rates from reduced IM&E will translate directly to greater
utility from participation in recreational fishing. Because the monetary value of these
improvements cannot be established by observing market transactions, nonmarket valuation
techniques must be employed to estimate such benefits. Nonmarket benefits may be further
categorized in terms of direct and indirect use benefits, and nonuse benefits.
¦ Nonmarket direct use benefits: These benefits consist of goods and services that have direct
uses, but are not traded in the marketplace. Higher catch rates for recreational fishing provide
a typical nonmarket direct use benefit.
¦ Nonmarket indirect use benefits: These benefits contribute indirectly to an increase the
welfare of those who engage in nonmarketed uses of a resource. For example, positive
impacts on local fisheries may generate an improvement in the population levels and diversity
of fish-eating bird species. In turn, bird watchers might obtain greater enjoyment from their
outings, as they are more likely to see a wider mix or greater numbers of birds. The increased
welfare of the bird watchers is thus an indirect consequence of the initial impact on fish.
¦ Nonuse benefits: These benefits occur when individuals value improved environmental
quality without any past, present, or anticipated future use of the resource in question.
Individuals may gain utility simply from knowing that a particular good exists (existence
value), or from knowing that a good is available for others to use now and in the future
(bequest value). Nonuse, or passive, benefits of reduced IM&E may include increased
biodiversity, improved conditions for the recovery of T&E species that have no direct or
indirect uses and welfare gains to nonusers when reduced IM&E to forage species improve
overall ecosystem function.
Table 4-1 presents the benefit categories EPA considered for regulated facilities. The table also presents
the various data needs, data sources, and estimation approaches associated with each category. A
complete list of the ecosystem services potentially affected by reduction in IM&E is presented in Chapter
2 (Table 2-4).
In addition the approaches presented in Table 4-1, EPA developed and implemented an original stated
preference (SP) study to estimate the total monetary value (use plus nonuse value) of aquatic resource
improvements from the 316(b) rule.13 EPA has not accounted for values estimated from the survey in the
quantitative comparison of costs and benefits. EPA plans to obtain Science Advisory Board (SAB) review
13 SP surveys, in general, ask questions that elicit individuals' values for carefully specified changes in an environmental
amenity (Freeman III 2003)
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Chapter 4: Economic Benefit Categories
of the SP survey, and considers the inclusion of benefits based on the survey to be premature prior to the
completion of the SAB review. Chapter 11 presents preliminary survey results to illustrate the potential
magnitude of benefits.
Table 4-1: Summary of Benefit Categories, Data Needs, Potential Data Sources, Approaches,
and Analyses Completed
Benefit Category
Basic Data Needs
Potential Data Sources/
Approaches/Analyses Completed
Market Goods, Direct Use
> Increased commercial landings
> Estimated change in landings of
specific species
> Estimated change in total economic
impact
> Based on facility-specific IM&E data
and ecological modeling.
> Changes in commercial fishery
landings estimated using a market-
based approach.
> Indirect economic impacts not
estimated due to data constraints.
Market Goods, Indirect Use
Increase in:
> Equipment sales, rental, and repair
> Bait and tackle sales
> Consumer market choices
> Choices in restaurant meals
> Property values near the water
> Ecotourism (charter trips, festivals,
other organized activities with fees,
such as riverwalks)
> Estimated change in landings of
specific species
> Relationship between increased
fish/shellfish landings and secondary
markets
> Local activities and participation
fees
> Estimated numbers of participating
individuals
> Indirect market impacts not estimated
due to data constraints such as lack of
information on the relationship
between increased fish/shellfish yield
and secondary impacts.
Nonmarket Goods, Direct Use
> Improved value of a recreational
fishing trip due to increased catch of
targeted/preferred species and
incidental catch
> Improved value of subsistence
fishing
> Value of additional recreational
participation and additional fishing
trips
> Value of an improvement in catch
rate
> Estimated number of affected
anglers or estimate of potential
anglers
> Value of a fishing day
> Changes in the value of a recreational
fishing trip estimated based on benefit
transfer (including recreational use
values of selected T&E species).
> Changes in the value of subsistence
fishing not estimated.
> Number of affected anglers and
increase in trips not estimated due to
data constraints.
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Table 4-1: Summary of Benefit Categories, Data Needs, Potential Data Sources, Approaches,
and Analyses Completed
Benefit Category
Basic Data Needs
Potential Data Sources/
Approaches/Analyses Completed
Nonmarket Goods, Indirect Use
> Increase in value of boating, scuba-
diving, and near-water recreational
experience from observing fish
while boating, scuba-diving, hiking,
or picnicking, and watching aquatic
birds fish or catch aquatic
invertebrates
> Increase in boating, scuba-diving,
and near-water recreation
participation
> Estimated number of affected near-
water recreationists, divers, and
boaters
> Value of boating, scuba-diving, and
near-water recreation experience
> Value of a recreation day
> Increased trip value not estimated due
to data constraints such as number of
affected recreational users.
> Changes in recreational participation
were not estimated. They are
expected to be negligible at the
regional level because fishery yield
impacts are generally small.
Nonuse Goods
Increase in nonuse values such as:
> Existence (stewardship)
> Altruism (interpersonal concerns)
> Bequest (interpersonal and
intergenerational equity) motives
> Appreciation of the importance of
ecological services apart from human
uses or motives (Table 2-4)
> IM&E estimates
> Primary valuation research using
stated preference approach
> Applicable studies upon which to
conduct benefit transfer
> Location of CWIS and T&E species
ranges
> Estimate nonuse values for an
increase in relative fish abundance
within two benefits regions using
benefit transfer. Not estimated for
other regions due to a lack of
applicable studies.
> Used geographic information system
(GIS) data to identify T&E species
potentially impacted by CWIS based
on the overlap of CWIS locations and
T&E species ranges.
> EPA used the results of the 316(b)
stated preference survey to illustrate
total values for the 316(b) rule,
including nonuse values. However,
did not include estimates based on the
316(b) SP survey in its comparison of
costs and benefits of the rule.
4.2 Market and Nonmarket Direct and Indirect Use Benefits from Reduced IM&E
Direct use benefits from reduced IM&E are the simplest to envision. The welfare of commercial,
recreational, and subsistence fishers is improved when fish stocks increase, and catch rates rise or effort
decreases. Higher catch rates increase the revenue and growth of commercial fisheries, the enjoyment of
recreational fishing trips, and the availability of food for subsistence fishers—all of which are quantifiable
benefits arising directly from changes in IM&E. Methodologies for estimating use values for recreational
and commercial species are well developed, and some of the species affected by IM&E have been studied
extensively. As a result, estimation of associated use values is often straightforward.
Indirect use benefits refer to welfare improvements for those individuals whose activities are enhanced as
an indirect consequence of fishery or habitat improvements. For example, an improvement in the
population of a forage fish species may be of no direct consequence to recreational or commercial fishers.
However, the increased presence of forage fish will have an indirect effect on commercial and
recreational fishing values if it increases food supplies for commercial and recreational predatory species.
Thus, improvements in forage species populations can result in a greater number (and/or greater
individual size) of those fish that are targeted directly by recreational or commercial fishers. In such an
instance, the incremental increase in recreational and commercial fishing benefits would be an indirect
consequence of the effect on forage fish populations.
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Chapter 4: Economic Benefit Categories
The following sections discuss the benefits estimates presented in each chapter of this report, and
techniques for estimating benefits of reduced IM&E for each category of benefits.
4.2.1 Commercial Fisheries
Commercial fishing benefits include both direct and indirect market use values. The social benefits
derived from increased landings by commercial fishers can be valued by examining the markets through
which the landed fish are sold. The first step of the analysis involves a fishery-based assessment of
IM&E-related changes in commercial landings (pounds of commercial species as sold dockside by
commercial harvesters). The changes in landings are then valued according to market data from relevant
fish markets (dollars per pound) to derive an estimate of the change in gross revenue to commercial
fishers. The final steps entail converting the IM&E-related changes in gross revenues into estimates of
social benefits. These social benefits consist of the sum of the producers" and consumers" surpluses that
are derived as the changes in commercial landings work their way through the multi-market commercial
fishery sector.
Indirect use values in markets occur through increases in commercial species caused by increased
numbers of forage fish. An improvement in the population of a forage fish species may be of no direct
consequence to commercial fishers. However, the increased presence of forage fish will have an indirect
effect on commercial fishing values if it increases food supplies for commercial predatory species. Thus,
improvements in forage species populations can result in a greater number (and/or greater individual size)
of those fish that are targeted directly by commercial fishers. In such an instance, the incremental increase
in commercial fishing benefits would be an indirect consequence of the final rule's effect on forage fish
populations. See Chapter 3 for a discussion on the indirect influence of forage fish on abundance of
commercial and recreational species.
Chapter 6 provides more detail on EPA's analysis of commercial fishing benefits from reducing IM&E at
the regulated facilities" cooling water intakes.
4.2.2 Recreational Fisheries
Recreational fishing benefits include both direct and indirect nonmarket use values. Recreational use
benefits cannot be tracked in the market because much of the recreational activity associated with these
fisheries occurs as nonmarket events. However, a variety of nonmarket valuation methods exist for
estimating use value, including both "revealed" and "stated" preference methods (Freeman III 2003).
These methods use other observable behavior to infer users" value for environmental goods and services.
Examples of revealed preference methods include travel cost, hedonic pricing, and random utility models.
Compared to nonuse values, nonmarket use values are often considered relatively easy to estimate, due to
their relationship to observable behavior, the variety of revealed preference methods available, and public
familiarity with the recreational services that surface waterbodies provide.
To evaluate the recreational benefits of the regulatory options for regulated facilities, EPA developed a
benefit transfer approach based on a meta-analysis of recreational fishing valuation studies. The analysis
was designed to measure the various factors that determine WTP for catching an additional fish per trip.
14 Many of the fish species affected by IM&E at CWIS sites are harvested both recreationally and commercially. To avoid
double-counting the economic impacts of IM&E of these species, EPA determined, based on historic NMFS landings data,
the proportions of total species landings attributable to recreational and commercial fishing, and applied these proportions to
the total number of affected fish.
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The estimated meta-model allows EPA to calculate the marginal value per fish for different species, based
on resource and policy context characteristics.
Indirect use values for forage species occur through increases in recreational species caused by increased
numbers of forage fish. An improvement in the population of a forage fish species may be of no direct
consequence to recreational anglers. However, the increased presence of forage fish will have an indirect
effect on recreational fishing values if it increases food supplies for recreational predatory species. Thus,
improvements in forage species populations can result in a greater number (and/or greater individual size)
of those fish that are targeted directly by recreational anglers. In such an instance, the incremental
increase in recreational fishing benefits would be an indirect consequence of the effect on forage fish
populations. See Chapter 3 for a discussion on the indirect influence of forage fish on abundance of
commercial and recreational species.
Chapter 7 provides detail on the application of the meta-regression model EPA used to estimate
recreational fishing benefits of the final rule and regulatory options it considered.
4.2.3 Subsistence Fishers
Subsistence fisheries benefits include both direct and indirect nonmarket use values. Subsistence use of
fishery resources can be important in areas where socioeconomic conditions (e.g., the number of low-
income households) or the mix of ethnic backgrounds make such fishing economically or culturally
significant to a component of the community. In cases of Native American use of affected fisheries, the
value of an improvement can sometimes be inferred from settlements in legal cases, e.g., compensation
agreements between affected tribes and various government or other institutions in cases of resource
acquisitions or resource use restrictions. For the general population, the value of improved subsistence
fisheries may be estimated from the costs saved in acquiring alternative food sources. This method may
underestimate the value of a subsistence fishery meal to the extent that the store-bought foods may be less
preferred by some individuals than consuming a fresh-caught fish. Subsistence fishery benefits are not
included in EPA's benefits regional analyses. Impacts on subsistence fishers may constitute an important
environmental justice consideration, which could result in EPA underestimating the total benefits of the
final rule and regulatory options it considered. EPA's Environmental Justice analysis is presented in
Chapter 12 of the economic analysis of the final 316(b) rule (USEPA 2014a).
4.2.4 Benefits from Improved Protection to T&E Species
T&E and other special status species can be adversely affected in several ways by CWIS. T&E species
can suffer direct harm from IM&E; they can suffer indirect impacts if IM&E at CWIS adversely affects
another species upon which the T&E species relies within the aquatic ecosystem (e.g., as a food source);
or they can suffer impacts if the CWIS disrupts their habitat (e.g., via thermal discharges). The loss of
individuals of listed species from IM&E at CWIS is particularly important because, by definition, these
species are already rare and at risk of irreversible decline because of other stressors.
Benefits from improved protection of T&E species can include both direct and indirect nonmarket use
values, as well as nonuse values. EPA identified nine special status fish species, six in California and
three in the Inland region, for which IM&E data were available. Due to their special status as well as the
fact that most of these species have either very limited or no direct uses, the major portions of the value
for T&E species are nonuse values. However, some of these species have potentially significant
recreational and commercial use values, for example, sturgeon and paddlefish. EPA applied benefit
transfer to estimate recreational use values for a subset of T&E species for which limited catch and
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Chapter 4: Economic Benefit Categories
release fisheries exist. EPA did not estimate potential commercial use values of these species due to the
lack of market data.
Chapter 5 provides more detail on EPA's analysis of T&E species benefits from reducing IM&E at CWIS
of regulated facilities.
4.3 Nonuse Benefits from Reduced IM&E
Comprehensive estimates of total resource value include both use and nonuse values, such that the
resulting total value estimates may be compared to total social cost. Recent economic literature provides
substantial support for the hypothesis that nonuse values, such as option and existence values, are greater
than zero. In fact, small per capita nonuse values held by a substantial fraction of the population can be
very large in the aggregate. "Nonuse values, like use values, have their basis in the theory of individual
preferences and the measurement of welfare changes. According to theory, use values and nonuse values
are additive" (Freeman III 1993).15 Consequently, both EPA's own Guidelines for Preparing Economic
Analysis and the Office of Management and Budget's (OMB) Circular A-4 governing regulatory analysis,
support the need to assess nonuse values (USEPA 2010a; USOMB 2003). Excluding nonuse values from
consideration is likely to understate substantially total social values.
Reducing IM&E of fish and shellfish may result in both use and nonuse benefits. Of the organisms that
EPA anticipates will be protected by the section 316(b), only about 3 percent of A1E will eventually be
harvested by commercial and recreational fishers, and therefore can be valued with direct use valuation
techniques. The remainder, which were not assigned direct use value in this analysis, constitute the
majority—97 percent—of the total estimated reductions in IM&E. Table 4-2 summarizes baseline IM&E
and reductions in IM&E by four loss categories: all species, forage species, total commercial and
recreational species, and harvested commercial and recreational species. Although unlanded forage fish
contribute to the yield of harvested fish and therefore have an indirect use value that is captured by the
direct use value of the commercial species, this indirect use value represents only a portion of the total
value of unlanded fish. Society also values both landed and unlanded fish for reasons unrelated to use—
for example, individual welfare may be affected simply by knowing these fish exist. Additionally, nonuse
values are likely to be substantial because fish and other species found within aquatic habitats impacted
directly and indirectly by CWIS provide other valuable ecosystem goods and services. These include
nutrient cycling and ecosystem stability. Therefore, a comprehensive estimate of the welfare gain from
reducing IM&E must include an estimate of nonuse benefits.
In contrast to direct and indirect use values, nonuse values are oftenmore difficult to estimate. SP
methods, or benefit transfer based on SP studies, are the generally accepted techniques for estimating
these values (USEPA 2010a; USOMB 2003). SP methods rely on carefully designed surveys, which
either ask individuals about their WTP for particular ecological improvements, such as increased
protection of aquatic species or habitats with particular attributes, or to choose among competing
hypothetical "packages" of ecological improvements and household cost in which the choice implies
WTP. In either case, values are estimated by statistical analysis of survey responses.
15 This additive property holds under traditional conditions related to resource levels and prices for substitute goods in the
household production model (Freeman III 1993).
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Table 4-2: Summary of Baseline National IM&E and Reductions in IM&E, for the
Final Rule and Other Options Considered
IM&E Loss Metric (per year)
Reductions in Losses
Baseline
Losses
Proposal
Option 4
Final
Rule
Proposal
Option 2
All Species (million A1E)
614.16
652.00
1637.49
1930.97
Forage Species (million A1E)
528.22
560.80
1258.67
1459.70
Commercial & Recreational Species (million A1E)
85.94
91.20
378.82
471.28
Commercial & Recreational Harvest (million fish)
16.13
17.11
44.66
54.02
A1E Losses with Direct Use Value (%)
2.6%
2.6%
2.7%
2.8%
Source: U.S. EPA analysis for this report
Nonuse values may be more difficult to assess than use values for several reasons. First, nonuse values
are not associated with easily observable behavior. Second, nonuse values may be held by both users and
nonusers of a resource. Because nonusers may be less familiar with particular services provided by a
resource, they may value the resource differently compared to users of the same resource. Third, the
development of a defensible SP survey is often a time- and re source-intensive process. Fourth, even
carefully designed surveys may be subject to certain biases associated with the hypothetical nature of
survey responses (Mitchell and Carson 1989). Finally, efforts to disaggregate total WTP into its use and
nonuse components have proved troublesome (Carson et al. 1999).
Although EPA is not always able to estimate changes in nonuse values as part of regulatory development,
an extensive body of environmental economics literature demonstrates that the public holds significant
value for service flows from natural resources well beyond those associated with direct uses (Boyd et al.
2001; Fischman 2001; Heal et al. 2001; Herman et al. 2001; Ruhl and Gregg 2001; Salzman et al. 2001;
Wainger et al. 2001). Studies have documented public values for the services provided by a variety of
natural resources potentially affected by environmental impacts, including fish and wildlife (Loomis et al.
2000; Stevens et al. 1991); wetlands (Woodward and Wui 2001); wilderness (Walsh et al. 1984); critical
habitat for T&E species (Hagen et al. 1992; Loomis and Ekstrand 1997; Whitehead and Blomquist 1991);
shoreline quality (Grigalunas et al. 1988); and beaches, shorebirds, and marine mammals (Rowe et al.
1992), among others. However, given EPA's regulatory schedule, developing and implementing SP
surveys to elicit total value (i.e., nonuse and use) of environmental quality changes resulting from
environmental regulations is often not feasible. In this case, EPA designed and implemented an original
SP survey to estimate total monetary value (including use and nonuse value) of potential aquatic resource
improvements that might occur as a result of the final 316(b) rule. As described in Section 4.1, EPA does
not include the benefits it estimated based on the survey in the comparison of costs and benefits for the
final rule. Chapter 11 provides additional details on the survey, implementation, and presents preliminary
benefits estimates to illustrate the potential of magnitude of total benefits. EPA also developed a benefit
transfer based on another existing SP survey to estimate nonuse benefits resulting from the final 316(b)
rule for the North and Mid-Atlantic regions. The benefit transfer is described in Chapter 8.
Existing SP studies suggest that nonuse benefits of aquatic habitat improvements may be significant. For
example, results from a study of public values of migratory fish restoration projects in Rhode Island
showed that nonuse motives such as existence and bequest were rated as "important" or "very important"
by 62 and 76 percent of survey respondents, respectively. Use motives such as commercial and
recreational fishing, on the other hand, were rated as "important" or "very important" by only 38 and 43
percent of the survey respondents, respectively (Johnston et al. 2012, unpublished data). Additional detail
regarding the Rhode Island study is provided in Chapter 8, Section 8.3.1.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 4: Economic Benefit Categories
Many ecosystems affected by CWIS provide goods and services that contribute to societal well-being (see
Chapter 2), but may be generally unrecognized because of the indirect nature of the effect. As such, even
valuations based on SP approaches are unlikely to capture the full economic value of the affected
ecosystem services (Costanza and Folke 1997). Despite these limitations, benefit transfer based on SP
studies is the generally accepted techniquefor estimating total (use and nonuse) values. EPA was able to
identify a single existing study that could be used to estimates total values (nonuse and use values) for
reductions in IM&E in some regions. Chapter 8 provides more detail on EPA's quantitative analysis of
nonuse benefits from reducing IM&E at the CWIS of regulated facilities.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 5: Impacts and Benefits on T&E Species
5 Impacts and Benefits on Threatened and Endangered Species
5.1 Introduction
T&E species are species vulnerable to future extinction or at risk of extinction in the near future,
respectively. These designations may be made because of low or rapidly declining population levels, loss
of essential habitat, or life history stages that are particularly vulnerable to environmental alteration,
disturbance, or other human impacts.
The withdrawal of cooling water from streams, rivers, estuaries and coastal marine waters leads to IM&E
of a large number of aquatic organisms. For species vulnerable to future extinction, IM&E from CWIS
may represent a substantial portion of annual reproduction. Consequently, IM&E may either lengthen
recovery time, or hasten the demise of these species. For these reasons, the population-level and social
values of T&E losses are likely to be disproportionately higher than the absolute number of losses that
occur.
Adverse effects of CWIS on T&E species may occur in several ways:
> Populations of T&E species may suffer direct harm as a consequence of IM&E. This direct
loss of individuals may be particularly important because T&E species have severely
depressed population levels that are approaching local, national, or global extinction.
> T&E species may suffer indirect harm if the CWIS substantially alters the food web in which
these species interact. This might occur as a result of altered populations of predator or prey
species, the removal of foundation species, or (for species with parasitic life history stages)
the loss of a host species.
> CWIS may alter habitat that is critical to the long-term survival of T&E species. This might
occur as a consequence of changes in the thermal characteristics of local waterbodies, altered
flow regimes, turbidity, or changes in substrate characteristics as a consequence of any of
these changes (Chapter 2).
By definition, T&E species are characterized by low population levels. As such, it is unlikely that these
species will be recorded in IM&E monitoring studies due to the logistical limitations of sampling and
identification effort, time of day, season, and year. For T&E species to be recorded in monitoring studies,
1) an individual of a T&E species must be captured during the (often short) sampling window, and 2) the
organism must be identifiable. Thus, despite the fact that the population impacts of IM&E on T&E
species may be high, the effects are difficult to ascertain and quantify within a framework designed for
common, more-abundant species. Thus, EPA identifies spatial overlap between CWIS and T&E species
habitat ranges to estimate the potential for adverse IM&E impacts.
As noted, T&E species affected by CWIS may have both use and nonuse values. However, despite the
existence of T&E species with potentially high use values (e.g., Pacific salmonids), the majority of T&E
species affected by IM&E are relatively unknown, and those that are unidentifiable may not have any
direct use values (e.g., delta smelt). Given that protecting of T&E species implies value, and that the
majority of T&E species may not have direct use value, the majority of the economic value for T&E
species must come from nonuse values. Species-specific estimates of nonuse values held for the
protection of T&E species can be derived only by primary research using stated preference techniques.
However, EPA did not have the resources necessary to develop such estimates for T&E species for this
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 5: Impacts and Benefits on T&E Species
rulemaking. As an alternative, EPA used a benefit transfer approach that relies on information from
existing studies (USEPA 2010a).
EPA was able to use a benefit transfer approach to estimate changes in recreational use values for a subset
of T&E species that are highly valued by recreational anglers (i.e., paddlefish16 and sturgeon).
Commercial and nonuse values are not monetized for any of the affected species. Therefore, benefit
estimates presented in this chapter are incomplete and highly conservative (i.e., low).
In this chapter, EPA explores the extent to which CWIS may affect species protected by the Endangered
Species Act on national and regional scales (Section 5.2), documents the value society places on the
protection of T&E species (Section 5.3), and applies economic valuation studies of T&E species to case
studies of sea turtles and finfish in the Inland region (Section 5.4).
5.2 T&E Species Affected by CWIS
To assess the potential impacts of CWIS on T&E species, EPA constructed a database that identifies
spatial overlap between CWIS and vulnerable life history stages of all aquatic T&E species for which data
are available. The database allowed EPA to estimate the potential for adverse IM&E impacts on T&E
species.
5.2.1 T&E Species Identification and Data Collection
First, all species currently listed under the Endangered Species Act (as of August 6, 2012) with aquatic
life history stages were identified using the US Fish and Wildlife Service Environmental Conservation
Online System (USFWS 2012a). This primary list of all T&E species was filtered to include only species
with life history stages vulnerable to CWIS mortality according to life history data. Examples of
vulnerable stages include planktonic egg stages occurring near- or in-shore (e.g., marine species spawning
offshore were excluded unless other vulnerable stages are found near- or in-shore), free-swimming larval
stages residing near- or in-shore, and adult life history stages that occur near- or in-shore. Life history
data used to exclude species from further consideration was obtained from a wide variety of sources
(AFSC 2010; ASMFC 2012; Froese and Pauly 2009; NatureServe 2012; NEFSC 2010; PIFSC 2010a;
PIFSC 2010b; SEFSC 2010; SWFSC 2010; USFWS 2012a). After filtering by life history data, the list of
T&E species potentially affected by IM&E contained 287 species.
Whenever possible, EPA obtained the geographical distribution of T&E species susceptible to IM&E in
geographic information system (GIS) format as polygon (shape) files, line files (for inhabitants of small
creeks and rivers) and as a subset of geodatabase files. Data sources include the US Fish and Wildlife
Service (USFWS 2010a), including shapefiles for critical habitat designated under the Endangered
Species Act, NOAA's Office of Response and Restoration (NOAA 2010), NatureServe (NatureServe
2012), and NOAA NMFS (NMFS 2010a; NMFS 2010b; NMFS 2010c). For several freshwater species,
geographic ranges were available only as 6-digit hydrologic unit codes (HUC) (NatureServe 2012;
USFWS 2010a). For these species, GIS data layers were generated using a GIS HUC database obtained
from the USGS (Steeves and Nebert 1994). For several species, no GIS data could be acquired. For these
species, species distribution descriptions were compared with mapped CWIS, and inspected for
geographic overlap. In all such cases (e.g., the "inarticulated brachiopod." Lingida reevii, endemic to
10 Note: the American Paddlefish is listed on T&E species lists for many states, but is not currently protected nationally under
the US Endangered Species Act. A review of the species' status in 1992 revealed that although the species did not then meet
the requirements to be listed as threatened at the federal level, the US Fish and Wildlife Service expressed its concern for the
future of the species.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 5: Impacts and Benefits on T&E Species
Kaneohe Bay, HI) no regulated facilities were located within 10 kilometers, and further inspection was
not warranted.
5.2.2 Number of T&E Species Affected per Facility
To investigate the potential for individual facilities to affect a wide variety of T&E species, EPA
calculated the number of T&E species affected on a per-facility basis. This calculation allowed EPA to
assess the magnitude of differences between regions of CWIS effects on T&E species.
Nationally, 99 of the 287 aquatic T&E species (34 percent) had vulnerable life history stages that either
overlapped with CWIS, or records of IM&E (Table 5-1). These species overlapped with 523 of 738
regulated facilities (71 percent) (Figure 5-1). Among facilities, the variability in the number of T&E
species potentially affected ranges between 0 and 32 species (Table 5-1), with more than 90 percent of
facilities affecting fewer than 7 T&E species, and more than 99 percent of facilities affecting fewer than
12 species (Figure 5-2).
Excluding facilities whose CWIS that do not overlap with at least one T&E species, the average number
of species per facility is 4.13 (minimum 1, maximum 32) (Table 5-1). Sea turtles, snails and freshwater
mussels had the highest overlap rate on a per-facility basis, averaging 4.7, 4.1 and 3.7 species per facility,
respectively. Anadromous and freshwater fish had lower overlap rates with CWIS, averaging slightly
higher than one species per interacting facility (Table 5-1).
Driven by the high number of IM&E freshwater mussels overlapping with facility CWIS, the majority of
all species by facility interactions occur in the inland region. However, the shape of cumulative
distribution plots is similar among regions after accounting for sample size, suggesting that the overall
probability of a facility affecting one or more T&E species is not a function of geographic region (Figure
5-3).
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 5: Impacts and Benefits on T&E Species
V o
&QP $ <
r # j\ f t
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Figure 5-1: Map of overlap of CWA section 316(b) existing facilities and T&E species habitat ranges (all circles, 523
facilities) or overlapping with critical habitat (orange circles, 27 facilities). Because critical habitat is a subset of total T&E
species habitat, a total of 523 facilities overlap the habitat of one or more T&E species.
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 5: Impacts and Benefits on T&E Species
Table 5-1: Number of T&E Species with Geographical Distributions
Overlapping Regulated Facilities, on a Per-facility Basis
T&E Species per Facility0
Subset of Affected Species3
# Species
All Facilities
Interacting Facilities1'
Avg
Max
Avg
Max
All T&E Species
99
2.9
32
4.1
32
T&E Freshwater Mussels
53
1.9
22
3.7
22
T&E Anadromous Fish
12
0.3
5
1 .2
5
T&E Freshwater Fish
21
0.1
4
1.4
4
T&E Snails
7
0.3
7
4.1
7
T&E Sea Turtles
6
3.8
5
4.7
5
a T&E species include species listed as threatened or endangered by the US Fish and Wildlife Service (fresh
water) or NOAA National Marine Fisheries Service (marine)
b Interacting Facilities = all facilities with CWIS inside the range of at least one T&E species
c Avg = Average, Max = Maximum
Source: U.S. EPA analysis for this report
Species per Facility
Figure 5-2: Empirical cumulative distribution function plot of the number of T&E species
potentially affected on a per-facility basis by regulated facilities nationwide. Sample size is 738.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 5: Impacts and Benefits on T&E Species
California (21)
North Atlantic (21)
o
00
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Mid-Atlantic (46)
South Atlantic (12)
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00
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Gulf of Mexico (22)
Great Lakes (50)
Inland* (566)
o
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d
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o
0
2
4
6
8
0
2
4
6
8
0 5 10 15 20 25 30
Species per Facility
Figure 5-3: Cumulative distribution plot of the number of T&E species potentially affected on a
per-facility basis by regulated facilities nationwide. Sample sizes (i.e., number of regulated
facilities) are noted in parentheses. The horizontal axis is equivalent in all plots, with the
exception of the Inland region (noted with an asterisk *).
5.2.3 Number of Facilities Affecting Individual T&E Species
To investigate the cumulative potential for CWIS to affect individual T&E species, EPA calculated the
number of facilities affecting each T&E species. There are 2,158 examples of overlaps between species
and facilities across 99 T&E species nationally, resulting in an average of 21.8 facilities per species
(Table 5-2). Consequently, many T&E species are likely to be affected by a large number of facilities.
Thus, even if individual facilities have low IM&E of T&E species, the cumulative effect of regulated
facilities on these populations may be substantial. The variation among species was large and ranged
between 1 and 103 facilities per species (Table 5-2). Overall, 10 percent of species are affected by 1
facility, 53 percent of species are affected by up to 6 facilities 73 percent of species are affected by up to
25 facilities, and 92 percent are affected by up to 74 facilities (Figure 5-4).
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 5: Impacts and Benefits on T&E Species
Table 5-2: Number of Facilities with CWIS Within the Geographical Distribution of
T&E Species, on a Per-species Basis
Subset of Affected Species3
Species
Overlaps
Facilities per T&E Species
Average
Maximum
All T&E Species
99
2158
21.8
103
T&E Freshwater Mussels
53
1176
21.8
103
T&F Anadromous Fish
12
235
19.6
101
T&F Freshwater Fish
21
65
3.1
7
T&]! Snails
7
199
28.4
49
Sea Turtles
6
483
80.5
102
a T&E species included species listed as threatened or endangered by the US Fish and Wildlife Service (fresh water) or
NOAA National Marine Fisheries Service (marine).
Source: U.S. EPA analysis for this report
When subsets of related species were assessed, sea turtles had the highest average number of overlapping
facilities (80.5) (Table 5-2), a value skewed by these species" extensive ranges (i.e., entire Atlantic, Gulf
of Mexico, and/or Pacific coast), and the potential for IM&E impacts at all life stages. Following sea
turtles, snails and freshwater mussels had the highest average number of overlapping facilities (28.4 and
21.8 facilities per species, respectively). Excepting turtles, freshwater mussels accounted for 8 of the top
10 species sorted by the count of CWIS overlap (Figure 5-5). Following freshwater mussels, anadromous
fish species were most likely to be affected, with an average of 19.6 facilities per species (Table 5-2).
This average, however, is highly skewed by two species of fish (the pallid sturgeon, Scaphirhynchns
ctlbus and the shortnose sturgeon, Acipenser brevirostmm) which accounted for 70 percent of all overlap
between facilities and anadromous fish species (Figure 5-5). Finally, freshwater fish species averaged 3.1
facilities with potential IM&E per species (Table 5-2, Figure 5-5).
X
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e
G
e
o
c.
CL
0)
>
(N
3
20
80
60
0
40
100
Facilities per Impacted Species
Figure 5-4: Empirical cumulative distribution function plot of the number of facilities that overlap
geographically with vulnerable life history stages of T&E species. Species represented on the plot
are those that overlap with a minimum of one regulated facility. Sample size is 99.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 5: Impacts and Benefits on T&E Species
0 20 40 60 SO 100 0 20 40 60 SO IO(l
Freshwater Mussels (53)
Anadromous Fish (12)
Q
00
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4) CI
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Sea Turtles (6)
Freshwater Fish* (21)
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80
100 0
20
40
100
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Facilities per Species
Figure 5-5: Cumulative distribution plots of the number of facilities likely to affect individual
threatened or endangered species, grouped by species life history trait. Sample sizes (species per
life history trait) are in parentheses, and represent those species potentially affected by a
minimum of one regulated facility. The horizontal axis is equivalent in all plots, with the exception
of Freshwater Fish (noted with an asterisk *).
5.2.4 Summary of Overlap between Cooling Water Intake Structures and T&E Species
Nationally, 34 percent of T&E species with vulnerable life history stages overlap with a minimum of one
CWIS (Table 5-1), and 71 percent of CWIS overlap with at least one T&E species. This suggests a high
probability that T&E populations are affected by IM&E. The potential for these impacts is widespread:
T&E species overlap CWIS in all geographical regions of the country (Figure 5-3), in all waterbody
types, and across multiple life histories (Figure 5-5). Finally, EPA's analysis includes only federally listed
T&E species. Thus, the number of T&E species (including those species defined as threatened or
endangered under state law) affected by IM&E is likely understated.
5.2.5 Summary of Overlap between Cooling Water Intake Structures and Critical Habitat
At some point following the listing of a species under the ESA, the US Fish and Wildlife Service or
NOAA will designate critical habitat. Critical habitat is defined as areas occupied by the species at the
time of listing which either 1) contain physical or biological features essential to conservation which
require special management considerations or protection, or 2) is essential for conservation.
To investigate the impact of regulated facilities on critical habitat, EPA assessed the number of facilities
with CWIS located within critical habitat. Overall, 27 facilities overlapped with critical habitats
designated for 21 species protected by the ESA (Figure 5-1). Of these 27 facilities, 14 overlapped with
critical habit for only one species; no facility overlapped with more than 8 species.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 5: Impacts and Benefits on T&E Species
5.2.6 Effect of the Final Rule on Facilities Overlapping T&E Species Habitat
To estimate the potential effect of the final rule on T&E species, EPA estimated the number of regulated
facilities overlapping the habitat of one or more T&E species. Based upon data from the 316(b) industry
survey (USEPA 2000), EPA estimates there are 143 facilities likely to be in compliance with the final rule
(final determination of compliance will be based on site-specific determination of BTA for entrainment),
and that a minimum of 192 facilities will be required to implement measures to reduce IM&E. There was
insufficient data for EPA to estimate compliance status for the remaining 188 facilities (Figure 5-6).
5.2.7 Species with Documented IM&E
Although difficult to observe and quantify, EPA identified 14 T&E species with documented IM&E from
facility IM&E studies (Table 5-3). Notably, several of these IM&E studies were conducted prior to the
listing of some of the T&E species identified (i.e., delta smelt, longfin smelt). Therefore, current annual
IM&E may be lower for these species, particularly if species" populations have decreased or if facilities
have been required to install additional technologies during the permitting process. Alternatively, IM&E
may be similar in magnitude at facilities whose operating permits have been administratively continued
while these new species were listed.
In addition to identifying T&E species reported in IM&E studies, EPA also identified taxa in these studies
not identified by species but whose genus matched T&E species overlapping with the reporting facility
location (Table 5-3). Although these instances are not confirmed IM&E of T&E species, they provide
evidence that additional T&E species are likely to be directly affected by IM&E.
Including only individuals identified by species, EPA identified more than 95,000 baseline losses of T&E
species (Table 5-3). However, for several reasons, T&E species suffering IM&E are likely to be
underreported. First, T&E species are found at low population densities, and the volume of water sampled
by facility-level impingement and entrainment studies is low. Thus, it is likely that many T&E species
suffered IM&E outside of sampling periods and were never recorded. Second, because a high proportion
of all IM&E occurs during early life history stages (i.e., egg, larvae) when species identification is more
challenging, T&E species may not be recognized during sampling. For example, endangered species of
darter, including the Cherokee and duskytail darters, may be reported as "darter," or "unidentified darter".
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 5: impacts and Benefits on T&E Species
Hawaii
Figure 5-6: Map of 316(b) existing facilities with CWIS overlapping the habitat of one or more T&E species, and these
facilities' compliance with the final rule. Overall, EPA estimates that 143 facilities are likely to be in compliance with the
final rule (green circles), 192 facilities are not yet in compliance with the final rule (red circles), and there is insufficient
data for EPA to estimate compliance status for the remaining 188 facilities (orange circles).
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 5: Impacts and Benefits on T&E Species
Table 5-3: Documented IM&E of T&E Species3
Resolution
Common Name
Latin Name
Baseline IM&E
Qualitativeb
Not Extrapolated
Extrapolated
Estimated
IM&EC
Species
Atlantic Salmon
Salmo salar
S
-
Chinook Salmon
Oncorhynchus tshawvtscha
C
~
5,470
Coho Salmon
Oncorhynchus kisutch
S
~
~
-
I )elta Smelt
/lypomesus iranspacificus
62.526
Green Sea Turtle
('helonia mvdas
s
-
I Iawksbill Sea Turtle
1 irelmochelvs imhricala
s
-
Kemp's Ridley Sea Turtle
Lepidochelys kempii
s
~
~
-
Leatherback Sea Turtle
Dermochelys coriacea
s
~
~
-
Loggerhead Sea Turtle
('arena carella
5-50
Longfin Smelt
Spirinclms lhaleichlhys
24.919
Olive Ridley Sea Turtle
Lepidochelys olivacea
s
~
~
-
Pallid Sturgeon
Scaphirhynchus albus
c
~
50
Steelhead Trout
Oncorhynchus nivkiss
c
S
~
5
Topeka Shiner
Xolropis lopeka
S
15
Genus
Alabama Sturgeon
Scaphirhynchus suttkusi
S
8,174
Atlantic Sturgeon
Acipenser oxyrinchus oxyrinchus
c
~
785.667
Blackside Dace
Phoxinus cumherlandensis
c
~
10
Chum Salmon
Oncorhynchus keta
c
~
S
22
Green Sturgeon
Acipenser mediroslris
S
785,667
Gulf Sturgeon
Acipenser oxyrinchus desotoi
S
785,667
Shortnose Sturgeon
Acipenser brevirostrum
c
~
S
785,667
a Species listed as threatened or endangered under state laws, such as the American Paddlefish (Polyodon spathnla), are not included in this list.
b "Qualitative" indicates the species is reported by name from a minimum of one facility, but no loss estimates are provided.
c Baseline IM&E reported for genera reflect IM&E for all species within the genus. Losses are likely dominated by more-common congeners.
Source: U.S. EPA analysis for this report
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Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 5: Impacts and Benefits on T&E Species
5.3 Societal Values for Preservation of T&E Species Affected by IM&E
This section examines governmental spending, policy decisions, and private donations associated
with the preservation and restoration of T&E species. This section provides evidence of societal
preferences for T&E preservation and spending related to ensuring sustainability of T&E species.
The U.S. Fish and Wildlife Service (FWS) reports annual expenditures for the conservation of
T&E species. Using the report for fiscal year 2011 (USFWS 2012b) EPA calculated total
government (federal and state) expenditures for the 99 federally listed T&E species with
vulnerable life history stages that overlap CWIS (Table 5-4). Excluding expenditures on T&E
species (and distinct population segments) not subject to IM&E, federal and state expenditures on
T&E species potentially affected by CWIS exceeded $593.2 million during FY 2011, and
accounted for 68 percent of all governmental spending on fish, marine reptiles, crustaceans,
corals, clams, aquatic snails and marine mammals listed under the ESA (USFWS 2012b).
Table 5-4: Federal and State Expenditures for
T&E Species Overlapping with CWIS
Species Group
Expenditure
(2011$,
millions)
Anadromous Fish
$483.4
Freshwater Fish
$57.6
Freshwater Mussels
$13.0
Snails
$0.1
Sea Turtles
$39.1
All Species Overlapping CWIS
$593.2
All Fish. Marine Reptile. Crustaceans. Coral.
Marine Mammal, Aquatic Snail and Clam
Species
$869.1
Source: USFWS (2012b)
In addition to direct governmental spending associated with the protection of T&E species that
overlap with CWIS, the presence of these species often guides policy discussions, and may
require the installation of abatement technologies that reduce T&E species mortality and allow
these species to migrate. For example, the life history of the American paddlefish (Polyodon
spathulci) (listed on many state T&E species lists, but not protected under the ESA) is
occasionally discussed during Federal Energy Regulatory Commission relicensing of dams,
because of the animal's highly migratory life history. In the Wisconsin River, for example,
Alliant Energy has been required to install a multi-million dollar fishway at the Prairie du Sac
dam, primarily to allow the passage of paddlefish and lake sturgeon (WPLC v. FERC 2004).
Considerations for T&E species have also been responsible for changes in water diversions on the
San Joaquin-Sacramento River delta, limiting water for downstream users. Under current
regulations, the volume of water removed from the San-Joaquin-Sacramento River at the Banks
Pumping Plant is limited from December to June, to protect delta smelt (NRDC v. Kempthorne
2007). This restriction limits the volume of water available for consumption as drinking water
and for use in large-scale irrigation projects. Water restrictions attributable due to the potential for
negative effects on delta smelt populations, have been estimated to result in the loss of 21,100
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Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 5: Impacts and Benefits on T&E Species
farm-related jobs and $703 million in agricultural revenue in 2009 alone (Boxall 2010; Howitt et
al. 2009).17
Although government spending and policy decisions made to protect or enhance stocks of T&E
species are not direct indications of economic benefits, they indicate that society does place a
significant value on protecting and restoring species at risk of extinction.
5.4 Assessment of Benefits to T&E Species
5.4.1 Economic Valuation Methods
Estimating the benefits of preserving T&E species by reducing IM&E is difficult for several
reasons. First, the contribution to ecosystem stability, ecosystem function, and life history remain
relatively unknown for many T&E species. Second, because much of the wildlife economic
literature focuses on commercial and recreational benefits that are not relevant for many protected
species (i.e., use values), a paucity of economic data focuses on the benefits of preserving T&E
species. Consequently, nonuse values comprise the principal source of benefit estimates for most
T&E species.
To obtain an accurate estimate of the nonuse values of T&E species affected by IM&E, first,
quantitative IM&E impacts, and the benefits of policy options, must be estimated for T&E
species. Second, an economic value must be obtained for the value of reducing IM&E as a
consequence of increased population sizes, extinction avoidance, and, for certain species (e.g.,
Salmonids), the potential for re-establishment of a commercial fishery.
Benefit transfer involves extrapolating existing estimates of nonmarket values to geographic
locations or species that differ from the original analytical situation. Thus, the approach transfers
estimates of values for preserving T&E species in one region to another region, or to a similar
species. Ideally, the resource (i.e. species), policy variable (e.g., change in species status,
recovery interval, population size, etc.), and the benefitting population (i.e., defined human
population) are identical. Such a match rarely occurs. Despite discrepancies in these variables,
however, a benefit transfer approach can provide useful insights into the social benefits gained by
reducing IM&E of T&E species.18
5.4.2 Case Studies
EPA attempted to estimate the benefits of the final rule for all T&E species with documented and
quantified IM&E at CWIS. In most cases, EPA was unable to locate or calculate key components
of the analysis necessary to apply a benefit transfer approach. However, EPA was able to obtain
sufficient data to estimate the economic benefits to two categories of T&E species: a subset of
T&E fish species in the Inland region, and loggerhead sea turtles. The case studies of potential
economic benefits from a decrease in T&E mortality are discussed below.
17 Water diversion in the San Joaquin-Sacramento River is currently undergoing active litigation. See San Luis &
Delta-Mendota Water Authority, etal. v. Salazar, etal., USDC Case No. l:09-CV-407 OWW GSA, and
consolidated cases.
18 Types of benefit transfer studies are discussed at length in U.S. EPA (2010).
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5.4.2.1 Inland Region
Baseline IM&E of Special Status Species and Reductions in IM&E Under the Final Rule and
Options Considered
EPA estimated IM&E for three T&E species in the Inland region: pallid sturgeon, American
paddlefish, and Topeka shiner. However, sufficient data were available to estimate the benefits of
the final rule for only the pallid sturgeon (Scaphirhynchus ctlbus) and the American paddlefish
(Polyodon spathida). As such, benefits estimates address only 73 to 83 percent of estimated T&E
A1E losses in the Inland region (Table 5-5).
The pallid sturgeon is listed as an endangered species under the ESA; the American paddlefish is
not listed federally. In the early 1990s, the U.S. FWS conducted a review of the paddlefish for
threatened status, but ultimately did not list the species (Allardyce 1991). However, the review
noted that immediate efforts were needed to restore stocks and degraded habitats (Allardyce
1991). Although not currently protected federally, paddlefish are protected by 11 states.
The American paddlefish is a large species (85 inches length and more than 220 lbs) with roe
suitable for caviar. The species once supported a large commercial fishery in the Mississippi
Valley, and currently supports a limited recreational fishery in some states. Likewise, the pallid
sturgeon is one of the largest (30 to 60 inches) fish found in the Missouri-Mississippi River
drainage, with specimens weighing up to 85 pounds. Because their large size makes them a
desirable commercial and trophy sport fish, and because they have roe suitable for caviar, both
pallid sturgeon and American paddlefish have potentially significant direct use values. All
extractive uses of the pallid sturgeon, however, are prohibited under the ESA.
To estimate total baseline IM&E, EPA used the EAM to model AlEs for each of the three T&E
species (Chapter 3).19 The choice of facilities used to extrapolate IM&E from model facilities was
based on species" historic ranges and current distributions. In addition to baseline estimates of
IM&E for pallid sturgeon, paddlefish, and Topeka shiner, EPA calculated reductions in IM&E
under the final rule and Proposal Options 2 and 4 (Table 5-5).
Table 5-5: Annual Baseline IM&E and Reductions in Baseline IM&E of
T&E Species at Regulated facilities in the Inland Region, by Regulatory
Option (A1E)
T&E Species
Proposal
Option 4
Final
Rule
Proposal
Option 2
Baseline
Paddlefish
7,930
8,245
15,660
18,841
Pallid Sturgeon
65
68
78
90
Topeka Shiner
2,911
3,010
3,472
3,985
Total
10,906
11,323
19,210
22,916
a The IM&E data used to develop regional estimates are from sampling at the Wabash and Cayuga
facilites in 1976, the only year of sampling data for these facilities.
Source: U.S. EPA analysis for this report
IM&E of Paddlefish and pallid sturgeon as observed at nine and two model facilities, respectively.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 5: Impacts and Benefits on T&E Species
Benefit Transfer Approach: Estimated WTP for Protection of Inland T&E Species
Nonuse Values
EPA identified two studies that estimated both nonuse and use values for sturgeon. One study
found that citizens of Maine are willing to pay $38.87 (2011$) as a one-time tax to create a self-
sustaining population of shortnose sturgeon (Kotchen and Reiling 2000), a species listed as
endangered under the ESA (NMFS 2004). A separate study found that lake sturgeon is a popular
wildlife-viewing species in Wisconsin, and that viewers place a substantial value on protection of
lake sturgeon populations. The average viewer's WTP to maintain the current sturgeon
population of Wisconsin's Lake Winnebago system was $127.37 (2011$). With an estimated
3,1761 sturgeon viewers in 2002, total WTP for sturgeon-viewing opportunities in the Winnebago
system was $0.41 million (2011$). Together, the results of these studies indicate that nonuse
values for preservation of sturgeon are likely to be significant. However, EPA was unable to
monetize total nonuse benefits from reduced IM&E because reliable population estimates needed
to transfer the values were unavailable.
Use Values
• Pallid sturgeon and paddlefish have potentially high commercial use values as
sources of roe. This value has increased dramatically owing to the collapse of
Caspian Sea sturgeon populations (Speer et al. 2000). Paddlefish roe have been
reported to sell for more than $300 per pound, and as much as three pounds of roe
may be harvested from a large female (McKean 2007). Despite these reports, EPA
was unable to reliably quantify total commercial values for these species due to a
lack of market data.
• Recreational use values for sturgeon and paddlefish caught in inland waters or
paddlefish were not available. Based on a review of literature describing these
species, EPA determined that sturgeon species (including white, green, and pallid
sturgeons) and paddlefish share many characteristics, including roe suitable for caviar
and their value as game fish. Consequently, WTP values for sturgeon obtained in
California were used to value recreational use of these species in the Inland region. A
limited recreational fishery (mostly catch and release) exists for paddlefish in several
states; although harvesting pallid sturgeon is illegal, the species is sometimes caught
by recreational anglers.
To estimate recreational use values for paddlefish and pallid sturgeon, EPA applied estimates
from a random utility model (RUM) analysis conducted to evaluate recreational fishing benefits
of the 2004 Section 316(b) Phase II Final Rule. Model results indicate that California anglers
were willing to pay $73.27 (2011$) to catch a sturgeon (USEPA 2004a), a value transferred to
anglers for pallid sturgeon and paddlefish in the Inland region (Table 5-6).20
The recreational use value from eliminating baseline IM&E of pallid sturgeon and paddlefish is
approximately $1.2 million using a 3 percent discount rate and $1.1 million using a 7 percent
discount rate. Annualized benefits for the final rule will be $415,000 using a 3 percent discount
rate and $320,000 using a 7 percent discount rate. Annualized benefits for other options
considered range from $399,000 to $664,000 using a 3 percent discount rate and $307,000 to
20 The Phase II analysis did not estimating WTP for catching a sturgeon in other states. Given similarity in species
characteristics, EPA used WTP for sturgeon caught in California to value sturgeon and paddlefish species in the
Inland region.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 5: Impacts and Benefits on T&E Species
$460,000 using a 7 percent discount rate. EPA notes that these are underestimates of the total
values of reducing IM&E to T&E species in the Inland region because both nonuse and
commercial values, which are likely to be substantial, are not incorporated.
Table 5-6: Estimated Annual WTP for Eliminating or Reducing IM&E of Special Status
Fish Species at Regulated facilities in the Inland Region, for the Final Rule and Other
Options Considered (2011$)a
T&E Species
Annualized Benefits (2011$, 1,000s)
Proposal Option 4
Final Rule
Proposal Option 2
Baseline
Paddlefish
$581.0
$604.1
$1,147.4
$1,380.5
Pallid Sturgeon
$4.8
$5.0
$5.7
$6.6
Total Undiscounted
$585.8
$609.1
$1,153.1
$1,387.0
3% Discount Rate
Annualized Value
$399.1
$415.0
$663.9
$1,210.7
7% Discount Rate
Annualized Value
$307.2
$319.5
$460.1
$1,116.7
a The IM&E data used to develop regional estimates are from sampling at the Wabash and Cayuga facilities
of sampling data for these facilities.
Source: U.S. EPA analysis for this report
n 1976, the only year
5.4.2.2 Potential Nonuse Values for T&E Species in the Inland Region
To illustrate the potential magnitude of nonuse values for T&E species affected by IM&E in the
Inland region, EPA applied a WTP meta-analytical model (Richardson and Loomis 2009) to
hypothetical scenarios. Because EPA currently does not have region-wide IM&E for all T&E
species, nor population models to estimate the effect of IM&E on population size, EPA presents
estimates only to assess the range of benefits potentially resulting from the final rule and other
options considered. The modeled scenarios estimate the WTP for 0.25 percent and 0.5 percent
increases for all T&E fish populations in the Inland region.
The model EPA used to estimate nonuse values using benefit transfer is a double log specification
(Model 4 from Richardson and Loomis (2009)), where:
In WTP (2006$) = -153.231 + 0.870 In CHANGESIZE + 1.256 VISITOR + 1.020 FISH + 0.772
MARINE + 0.826 BIRD - 0.603 In RESPONSERATE+ 2.767 CONJOINT + 1.024
CHARISMATIC - 0.903 MAIL + 0.078 STUDYYEAR
Model variables are described in Table 5-7. Excepting all policy-relevant variables, EPA used the
mean values for all model parameters, and converted estimates to 2011$ using the consumer price
index (USBLS 2011).
For a 0.25 percent change in T&E fish population size, projected WTP per household per year is
$1.07. With 59.9 million households21, total WTP for T&E fish in the Inland region is $63.1
million. For a 0.5 percent change in T&E fish populations, WTP per household is $1.94 per year,
resulting in WTP values of $114.3 million in the Inland region (all values 2011$).
21 Household number in the Inland region is calculated for states where at least one T&E species affected by IM&E
is found.
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Table 5-7: Variables in the Richardson and Loomis (2008) Meta-Analysis Model and
Values Used in EPA's Application
Variable Name
Description
Value Used in EPA's Application
InWTP
Natural log of willingness to pay
Estimated by model
hi CHANGESIZE
Natural log of the percentage change in
the population of the species of interest
Log of percentage change in fish
population: ln(.25) and ln(.5)
VISITOR
= 1 if survey respondents are visitors
rather than full-time residents
0.0
FISH
= 1 for lisli species
1.0
MAR
= 1 for marine mammals
0.0
BIRD
= 1 for bird species
OD
hi RESPONSERATE
Natural log of the survey response rate
4.0
CONK >l\ I
= 1 for conjoint method surveys
OD
CHARISMATIC
= 1 for charismatic species
0.0
MAIL
Indicates mail surveys
0.9
study yt:ar
Year of study
2007
Sources: Richardson and Loomis (2008), U.S. EPA analysis for this report
5.4.2.3 Sea Turtles
Six species of sea turtles live in U.S. waters: green (Chelonia mvdcts), hawksbill (Eretmochelys
imbricata), Kemp's Ridley (Lepidochelvs kempii), leatherback (Dermochelys coriacea),
loggerhead (Caretta caretta), and Olive Ridley (Lepidochelvs olivacea) sea turtles. All have
extensive ranges, migrate long distances during their lifetime, and are listed as either threatened
or endangered (T&E) under the ESA. Because of these large ranges, substantial overlap exists
between sea turtle habitat and CWIS for regulated power generating and manufacturing facilities.
Additionally, because individuals of all ages and sizes are susceptible to impingement and
entrainment (Norem 2005), more than 730 potential interactions between species and CWIS may
result in the injury or death of these T&E species (Table 5-1, details in Appendix F, Section 1).
Evidence for Public Values for Sea Turtles
In addition to research sponsored by the National Science Foundation and various private
philanthropic organizations, federal and state governmental spending on sea turtle protection
under the ESA totaled $33.8 million in FY2008 (Table 5-4). Moreover, dozens of academic,
nonprofit, and ecotourism organizations recruit thousands of volunteers every year to participate
in sea turtle conservation and research projects (Appendix Table F-2). Volunteers are often
required to undergo substantial training at their own expense and commit to spend long hours
working, often during the night. For example, the nonprofit organization Earthwatch matches
volunteers with academic researchers working at field stations around the world. By paying to
spend time working with scientists on research projects, volunteers support sea turtle research and
conservation both financially and logistically, and gain first-hand experience of conservation
issues. Trips may last from days to several weeks, and often require a commitment of 10 or more
hours per day. For example, on one 10-day volunteer trip with a cost of $2,450 (plus airfare),
volunteers spend time tagging, measuring, and weighing leatherback seat turtles in Trinidad,
patrolling beaches from sundown to the early hours of the morning (Earthwatch Institute 2010).
Baseline IM&E of Special Status Species and Potential IM&E Reductions Under the Final
Rule and Options Considered
Several passive-use (e.g., wildlife viewing and photography) and nonuse values are associated
with U.S. sea turtle populations. Many households express passive use value by participating in
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ecotourism activities, such as visiting sea turtle nesting areas, or by participating in sea turtle
conservation activities (Frazer 2005). Additionally, a high proportion of governmental
expenditures on T&E species are for turtle species (Table 5-4), suggesting that the public values
the preservation of sea turtle populations.
Electric generating facilities are known to impinge and entrain all six species of sea turtles found
in U.S. waters (Norem 2005), with more than 730 occurrences of overlap between species ranges
and CWIS (Table 5-1). Incidences of mortality have been reported at facilities in California,
Texas, Florida, South Carolina, North Carolina, and New Jersey (National Research Council
1990; Plotkin 1995). These facilities span a wide range of intake flows (less than 30 mgd to more
than 1,400 mgd AIF), suggesting that sea turtle mortality is not limited to large intakes. Although
quantitative reports are available from a few power stations, high-quality data is available from
only one source, the St. Lucie Nuclear Power Plant, at Hutchinson Island, FL, where annual
capture rates range from 350 to 1,000 turtles (Appendix Table F-l). Despite estimates of
mortality rates due to entrainment of less than 3 percent, approximately 85 percent of entrained
organisms show evidence of injury as a result of entrainment (Norem 2005). As such, true
mortality rates from CWIS may be higher than reported, particularly for individuals captured
repeatedly (37 percent of green and 13 percent of loggerhead sea turtles entrained between May
and December 2000 were recaptured individuals) (Norem 2005).
Although the magnitude of IM&E is small relative to fishing-related mortality, the cumulative
impact of IM&E is unclear. The only study presenting a quantitative estimate of annual IM&E
estimated mortality rates to be between 5 and 50 individuals per year (Plotkin 1995).
Consequently, sufficient data does not exist to estimate baseline sea turtle mortality due to
entrainment and impingement at regional or national scales. However, the lower population sizes,
long life-span, and high reproductive potential of adult turtles (Crouse et al. 1987), mean the final
existing facilities rule is likely to have only a small effect on the long-term viability of turtle
populations.
Potential Benefits of Protecting Sea Turtle Species
Per-household WTP
EPA identified a study that used a stated preference valuation approach to estimate the total
economic value (i.e., use and nonuse values) of a management program designed to reduce the
risk of extinction for loggerhead sea turtles (Whitehead 1993). The mail survey asked North
Carolina households whether they were willing to pay for a management program that reduces the
probability that loggerhead sea turtles will be extinct in 25 years. EPA used Whitehead (1993) to
assess the range of benefits potentially resulting from the final rule and Proposal Options 2 and 4
(detailed methodology in Appendix F, Section 2). EPA included the resulting benefits estimates
here as an illustrative example and did not include them its national benefit totals for the final rule
and options considered.
EPA reviewed the available data sources and biological models to assess the potential impact of
baseline IM&E and reductions in IM&E on the probability of sea turtle extinction in 25 years.
Although analyses of sea turtle extinction risk have been conducted (e.g., Conant et al. 2009),
EPA was unable to identify an existing model or analysis that could be readily used in
conjunction with available mortality data to estimate the marginal impacts of CWIS on sea turtle
extinction risk. Estimates from the literature suggest that IM&E is of relatively low importance
compared to other human-induced mortality such as shrimp trawling and other fisheries (Plotkin
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Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 5: Impacts and Benefits on T&E Species
1995). However, Crouse et al. (1987) found that mortality at juvenile and subadult life stages can
have a substantial effect on population growth, which suggests that small changes in survival at
these age classes could have a measurable impact on extinction risk. For this illustrative example,
EPA assumed a marginal change in extinction probability of loggerhead sea turtles due to the
final rule is of 0.01 (i.e., a 1 percent decrease in the probability of extinction in 25 years). EPA
bases this assessment upon reports that IM&E may result in the loss of more than 100 turtles per
year (Appendix Table E-l), and because turtle population growth rates are known to be sensitive
to changes in juvenile and subadult mortality (Crouse et al. 1987).
EPA used a value of 0.01 within Whitehead's (1993) modeling framework to estimate household
values for changes in extinction risk for loggerhead sea turtles as a consequence of the final rule
(details of this calculation are in Appendix Section F-2). Although EPA did not base this
assessment on formal quantitative analysis of extinction risk, it illustrates the magnitude of
potential benefits associated with reductions in sea turtle IM&E. Using the published mean values
for all other model parameters, EPA calculated an annual household value of $0.37 (2011$).
Estimates were converted to 201 ldollars using the consumer price index (USBLS 2011).
Total WTP for all Households
Whitehead's (1993) study for loggerhead sea turtle management activities was based on a state-
wide survey of North Carolina residents. However, the large geographic range of sea turtles
suggests that households of many coastal states through their U.S. range would value activities
that decrease their extinction risk. There is also the potential for differential values within and
across states. Households farther away from the resource may value sea turtle survival less than
households near the ocean because they are less likely to participate in passive uses of the
resource. Although EPA recognizes that the application of the benefit transfer may overestimate
household values for states with population centers far from sea turtle habitat, evidence from the
literature suggests that households may value changes in environmental resource that are
occurring at great distances. For example, Pate and Loomis (1997) found that respondents were
willing to ascribe stated preference values to environmental amenity changes in other states. As
such, by focusing on residents of coastal states only, estimated benefits may undervalue national
willingness to pay for the preservation of loggerhead sea turtles.
As noted above, EPA includes its calculations for the benefits of protecting sea turtles here as an
illustrative example. For this example, EPA focused solely on impacts to loggerhead sea turtles
(one of six T&E sea turtle species in the United States). By focusing only on loggerhead sea
turtles, EPA notes that estimated benefits are likely to be lower than those held by individuals for
all T&E turtle species. EPA chose this species of turtles because they are late-maturing, have an
existing population model (Crouse et al. 1987), an existing valuation study (Whitehead 1993),
and are the most commonly affected species of turtle (Appendix F). The U.S. range of loggerhead
sea turtles includes the Gulf of Mexico, South Atlantic, Mid-Atlantic, and North Atlantic 316(b)
regions (USFWS 2010b). Assuming affected populations include all households within states
with regulated facilities that potentially have an impact on loggerhead sea turtles, 54.83 million
households would be willing to pay for improved protection of this species (Table 5-8). EPA
applied the mean household WTP of $0.37 (2011$) to all four regions because the Whitehead
(1993) function does not include income or other demographic variables that allow estimation of
state-specific WTP. The total annual WTP for a 1 percent increase in the survival probability of
loggerhead sea turtles annualized at a 3 percent discount rate is $19.3 million. Annualized
benefits for each region are presented in Table 5-8, assuming that benefits begin to accrue in 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 5: Impacts and Benefits on T&E Species
and continue throughout the compliance period. Because EPA does not currently have accurate
national estimates of IM&E for turtle species, nor are population models available that estimate
the effect of the existing facilities rule on population size and extinction risk, EPA is presenting
these estimates only to assess the potential range of benefits, and is not including them in national
benefits totals for the final rule and options considered. Actual benefits may be higher or lower
than these estimates, with Proposal Option 2 likely to provide substantially greater benefits than
the final rule and Proposal Option 4.
Table 5-8: Benefits of a 1 Percent Increase in the Probability that Loggerhead Sea
Turtles Will Not Be Extinct in 25 Years
Region
States Included
Number of
Households
(millions)
Annualized Benefits
(2011$, millions)
3% Discount Rate
7% Discount Rate
North Atlantic
CT, MA, ME,
NH,RI
5.41
$1.90
$1.86
Mid-Atlantic
DE, MD, N.T,
NY. PA. VA
21.11
$7.41
$7.25
South Atlantic
l-'LliA. NC. SC
12.06
$4.24
$4.14
Gulf of Mexico3
I I . I.A. MS. I X
16.26
$5.71
$5.59
Total
-
54.83
$19.26
$18.84
a Florida households are included in both the South Atlantic and Gulf of Mexico regions. To prevent double-counting,
Florida households were apportioned between these regions based on relative AIF.
Note: Because of uncertainty in estimates of increased survival probability, and because benefits were not calculated for
options, these values are not included in national totals.
Source: U.S. EPA analysis for this report
5.4.3 Limitation and Uncertainties
Table 5-9 summarizes the caveats, omissions, biases, and uncertainties known to affect the
estimated benefits for sea turtles (Section 5.4.2.3), and T&E finfish in the Inland region (Section
5.4.2.1).
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Table 5-9: Caveats, Omissions, Biases, and Uncertainties in the T&E Species Benefits
Estimates
Issue
Impact on Benefits
Estimate
Comments
Change in T&E populations
due to IM&E is uncertain
Estimates
understated
Projected changes in number of fish affected may be
underestimated because neither cumulative impacts of
IM&E over time nor interactions with other stressors are
considered.
IM&E effects are not
estimated for all T&E species
and all regions
Estimates
understated
EPA was unable to estimate IM&E of T&E species for
all regions due to lack of data. The large amount of
overlap between T&E ranges and CWIS suggests that
many affected species are likely to be missing from
IM&E reports.
Benefit estimates include
only a subset of species
identified as affected
Estimates
understated
EPA was unable to apply benefit transfer of values for
all affected species. Benefits estimates address 80 to 84
percent of documented T&E A1E losses in the Inland
region.
Benefit estimates used in
benefit cost analysis include
only recreational use values
Estimates
understated
EPA applied recreational use values to estimate benefits
for the species included in the analysis. Values held for
T&E species are primarily nonuse values, which were
not monetized. In addition, some of the affected species
have commercial use values, which were not estimated.
Benefit transfer introduces
uncertainties
Uncertain
EPA applied a recreational use value for sturgeon in
California to value sturgeon and paddlefish in the Inland
region. This value may over- or understate recreational
values of sturgeon and paddlefish in the Inland region.
Ecological consequences of
reduced numbers of T&E
species
Estimates
understated
WTP values are unlikely to include damage to food-
webs and ecosystem stability as a consequence of the
removal or restoration of T&E species.
Effects of thermal impacts
fromCWIS on T&E
populations is uncertain
Uncertain
EPA has few data on the effect of thermal discharge on
T&E species.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 6: Commercial Fishing Benefits
6 Commercial Fishing Benefits
Commercial fisheries can be adversely affected by IM&E in addition to many other stressors.
Commercially landed fish are exchanged in markets with observable prices and quantities;
however, estimating the change in economic surplus from increases in the number of
commercially landed fish requires consideration of various conceptual and empirical issues. This
chapter provides an overview of these issues, and presents how EPA estimated the change in
commercial fisheries-related economic surplus associated with the elimination of, and reduction
in, baseline IM&E under the final rule and regulatory options it considered.
This chapter includes a review of the concept of economic surplus, and describes economic
theory and empirical evidence regarding the relationship between readily observable dockside
prices and quantities and the economic welfare measures of producer and consumer surplus that
are suitable for benefit-cost estimation.
Section 6.1 describes the methodology used to estimate the commercial fisheries-related benefits,
including conceptual and empirical discussions of producer and consumer surplus. Section 6.2
presents the commercial fisheries-related benefits by region, and Section 6.3 presents the
limitations and uncertainties associated with EPA's analysis.
6.1 Methodology
The methodology EPA employed to estimate the commercial fishing benefits associated with the
regulatory options for the final rule closely follows the analysis EPA conducted for the Section
316(b) Phase III Final Rule (USEPA 2006b). Changes from that analysis include updated
estimates of baseline IM&E and IM&E reductions, and updated dockside prices. EPA estimated
dockside prices based on the five-year average price between 2007 and 2011, from commercial
fishing landings data obtained from the National Oceanic and Atmospheric Administration's
National Marine Fisheries Service (NMFS) (NMFS 2012a).
EPA measured commercial fishing benefits as changes in producer surplus. Estimated benefits for
each region are presented in Section 6.2. EPA also considered potential consumer surplus values
associated with IM&E, but did not estimate changes in consumer surplus for the final rule and
options considered because it found that dockside prices would not change enough to produce
measurable shifts in consumer surplus. Appendix H presents the details of EPA's assessment of
consumer surplus.
6.1.1 Estimating Consumer and Producer Surplus
The total loss to the economy from IM&E impacts on commercially harvested fish species is
determined by the sum of changes in both producer and consumer surplus (Hoagland and Jin
2006). EPA modeled IM&E using the methods presented in Chapter 3. EPA assumed a linear
relationship between stock and harvest. That is, if 10 percent of the current commercially targeted
stock were harvested, EPA assumed that 10 percent of any increase in that species due to lower
IM&E would be harvested. Thus, EPA assumed that the percentage increase in harvest is the
same as the percentage increase in the fish population. The percentage of fish harvested is based
on historical fishing mortality rates. EPA used historical NMFS landings data on commercial and
recreational catch to determine the proportions of total species landings attributable to
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Chapter 6: Commercial Fishing Benefits
recreational and commercial fishing. EPA applied these proportions to the estimated total change
in harvest to distribute benefits between commercial and recreational fisheries.
Producer surplus provides an estimate of the economic benefits to commercial fishers. Welfare
changes can also be expected to accrue to final consumers of fish and to commercial consumers,
including processors, wholesalers, retailers, and middlemen, if the projected increase in catch due
to the rule is accompanied by a decrease in price. These impacts can be expected to flow through
the tiered commercial fishery market (as described in Holt and Bishop (2002)).
Holt and Bishop (2002) used a fishery market model to estimate changes in welfare as a result of
changes in the level of the commercial fishing harvest. The market model takes as inputs the
expected change in harvest and baseline gross revenues, and provides as outputs the expected
change in producer and consumer surplus. In general, the analysis of market impacts involves the
following steps (Bishop and Holt (2003)):
1. Assessing the net welfare changes for fish consumers due to changes in fish harvest and
the corresponding change in fish price.
2. Assessing net welfare changes for fish harvesters due to the change in total revenue,
which could be positive or negative.
3. Calculating the change in net social benefits when the fish harvest changes.
Figure 6-1 illustrates a simplified fishery market model as shown in Bishop and Holt (2003). For
simplicity, the authors assume that the fishery is managed on quota basis with the baseline quota
shown as F1 and baseline dockside or ex-vessel price as I'1. They use an inverse demand function,
1'(!•'). because fish are perishable, with the quantity harvested driving price in the short run.
Price $
P(F)
Quantity
Figure 6-1: Fishery Market Model, reproduced from Bishop and Holt (2003)
6.1.1.1 Step 1: Assessing Benefits to Consumers
The downward sloping line labeled l'(b'), depicted in Figure 6-1, represents a general equilibrium
demand function that accounts for markets downstream of commercial fishers. As described
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 6: Commercial Fishing Benefits
above, the vertical curve F1 is the quantity of fish supplied to the market by commercial fishers
under the baseline conditions. Equilibrium is attained at the point where P(F) equals F. The
intersection of these two lines gives the price P1 at which quantity F1 is sold. In this case the total
amount paid by consumers for fish is equal to P1 x F1, which is equal to the area of the boxes U +
V + Win the graph. The consumer surplus, or benefit to consumers, is equal to the area of the
triangle T.
The measurement of the benefits from reducing IM&E relies on the assumption that a decrease in
mortality of fish, larvae, and eggs under a scenario of reduced IM&E would increase fish
populations and the quantity of fish supplied to consumers (i.e., an increase from F1 to F2). If the
quantity of fish available to the market increases from F1 to F2, this in turn would result in a lower
market price for fish (i.e., P2). The total amount paid by consumers changes to P2 x F2, which is
equal to the area of the boxes V + W + Y + Z. This area may be smaller or larger than area U + V
+ W, but unequivocally increases the consumer surplus so that it is equal to the area of the
triangle T + U + X. The difference in consumer surplus between the reduced IM&E scenario and
the current baseline scenario (i.e., U + X) is the measure of benefits to consumers from reducing
IM&E.
Estimating the change in the price of fish from changes in commercial fish harvest requires the
following input data: (1) an estimate of the baseline prices and quantities of the commercial
fishing harvest, (2) the estimated change in the commercial fishing harvest under the reduced
IM&E scenario, and (3) an understanding of the price elasticity of demand for fish. The price
elasticity of demand for fish measures the percentage change in demand in response to a
percentage point change in fish price. Thus, the inverse elasticity, or price flexibility, measures
the percent change in price for a given percent change in quantity.
To properly estimate price changes, it is necessary to consider the contribution of the species to
the overall market. Because individual demand functions incorporating substitutes are not
available for most species, EPA estimated price changes in the following way.
The Agency estimated the total baseline harvest for relevant species (commercial species of
similar types to those affected by IM&E) using NMFS landings data from 2007 to 201 lin three
categories: finfish, shrimp, and crabs.22 EPA aggregated the species to account for substitution.
The totals for finfish were summed for the East Coast and Gulf, and for the West Coast, while
totals for shrimp and crabs were summed across all coastal regions.23 EPA summed estimated
harvest increases from the elimination of baseline IM&E according to the same species and
regional categories (column 3 in Table 6-1).
EPA estimated price elasticity of demand based on a review of the economics literature (Asche et
al. 2005; Capps Jr. and Labregts 1991; Cheng and Capps Jr. 1988; Davis et al. 2007; Lin et al.
1988; Tsoa et al. 1982) (column 6 in Table 6-1) . The percentage change in price was calculated
by dividing percentage change in harvest by elasticity. As shown in Table 6-1, the expected price
changes resulting from eliminating baseline levels of IM&E are very small, ranging from 0.21
percent to 2.5 percent. EPA expects that price changes would be substantially less for the final
rule due to much lower reductions in IM&E. Appendix H of this document presents the detailed
calculations and results.
22 For example, offshore species such as tuna and swordfish, baitfish species, and shellfish were not included.
23 Harvests for Alaska and Hawaii were not included in the totals.
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Chapter 6: Commercial Fishing Benefits
Table 6-1: Estimated Average Percentage Change in Ex-Vessel Price by Region and
Species Group from the Elimination of Baseline IM&E
Region
Species
Group
Increase in Harvest
from Elimination of
Baseline IM&Ea
(lbs)
Total Average
Annual Harvest3
Percentage
Change in
Harvest
Elasticity
Percentage
Change in
Priceb
California
Fin fish
1,920,625
489,705,990
0.39%
-1.89
-0.21%
East Coast
and Gulf
Fin fish
12,548,060
265,617,830
4.72%
-1.89
-2.50%
All Regions
Crabs
1,373,553
258,973,619
0.53%
-1.31
-0.40%
All Regions
Shrimp
369,750
279,365,691
0.13%
-0.63
-0.21%
a Sum of total landings for all relevant species.
b Percentage changes in price reflect the average across all species within the species group and region.
Sources: U.S. EPA analysis for this report, NMFS (2012a)
EPA did not include estimates of changes in consumer surplus for commercial species. Prices
must change in order for consumer surplus to change. Most species of fish have numerous close
substitutes. The literature suggests that when there are plentiful substitute fish products, numerous
fishers, and a strong ex-vessel market, individual fishers are generally price takers. Although
there are exceptions, fisheries economics studies often make these assumptions in analyzing
regional effects from harvest changes (e.g., Herrmann 1996; Thunberg et al. 1995) and
international markets (e.g., Clarke et al. 1992). Consumer surplus measures that NMFS has
estimated for past environmental impact statements tend to be quite low. NMFS fisheries analyses
incorporate price changes for large changes in regional or national harvest, such as stock
rebuilding. However, for small changes in landings, such as those EPA expects under the final
rule, it is standard to assume that prices are fixed.24
6.1.1.2 Step 2: Assessing Producer Surplus
In an unregulated fishery, the long-run change in producer surplus due to an increase in fish
stocks will be zero percent of the change in gross revenues because in open access fisheries,
excess profits are always driven to zero at the margin. Most fisheries are, however, regulated with
quotas or restrictive permits to prevent overfishing. Thus, lasting economic benefits accrue to
commercial fishers from reductions in IM&E and the subsequent increase in harvest. Fishery
regulations seek to create sustainable harvests that maximize resource rents.25 In a regulated
fishery, IM&E impacts reduce the number of fish available to harvest. This reduction may lead to
more-stringent regulations and decreases in harvest. In this case, the change in producer surplus
can be related to the change in harvest and the resulting gross revenue.
In Figure 6-1, the line C represents the cost to the producer of supplying a pound of fish. The
model assumes that average cost is equal to marginal cost, that is, C is constant for all pounds
produced.26 When the supply of fish is equal to F1, the commercial fishers sell F1 pounds of fish
at a price of P1 and earn revenues equal to U + V + W. The area between P1 and C is the producer
24 Personal communications with NMFS economists Cindy Thomson (2008), Eric Thunberg (2008), Steve Freese
(2008), and Sabrina Lovell (2013).
25 In addition, even in open access fisheries, intramarginal rents are earned by at least some boats (Thunberg 2008).
20 If marginal costs increase as harvest increases, some of the producer surplus per unit will be lost due to the
increased costs.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 6: Commercial Fishing Benefits
surplus that accrues to producers for each pound of fish. Total producer surplus realized by
producers is equal to (P -C) x F. In the example, this producer surplus is equal to the area of U
+ V. The area W is the amount that producers pay for capital and labor and to suppliers if the
harvest equals F1 (e.g., fishing gear and the costs of operating in the market).
When supply increases to F2, the producers sell impounds of fish at a price of P2. The total cost to
produce F2 increases from W to W Z The total producer surplus changes from IJ Fto V Y.
This change may be either positive or negative, depending on the relative elasticity of demand,
which changes the relative sizes of areas U and Y.
In theory, producer surplus is equal to normal profits (total revenue minus fixed and variable
costs), minus the opportunity cost of capital. The fixed costs and inputs are incurred
independently of the expected marginal changes in the level of fish landings (Squires et al. 1998;
Thunberg and Squires 2005). Total variable costs including labor, fuel, ice, and other supplies,
however, vary directly with the level of landings. Furthermore, because EPA estimated the
opportunity cost of capital to be only about 0.4 to 2.6 percent of producer surplus, EPA assumed
that normal profits are a sufficient proxy for producer surplus (USEPA 2004a). As a result, EPA's
assessment of producer surplus is a relatively straightforward calculation in which the change in
producer surplus is calculated as a species- and region-specific fraction of the change in gross
revenue due to increased landings.
The change in producer surplus, captured by "normal profits," is assumed to be equivalent to a
fixed proportion of the change in gross revenues. EPA estimated gross revenue change from the
change in the commercial harvest due to reducing IM&E, and the change in prices associated
with the increased commercial harvest. As discussed above, EPA estimated price changes to be
negligible, and therefore did not include price changes in the model. EPA estimated species- and
region-specific Net Benefits Ratios, which represent the fractional share of gross revenue
associated with net benefits. EPA's approach for estimating Net Benefits Ratios using available
data on variable costs from sources such as the NMFS is described in more detail in
Section A4-10 of US EPA (2006). EPA then applied the Net Benefits Ratio to the estimated
change in gross revenue under the 316(b) final rule and regulatory options EPA considered to
estimate the increase in producer surplus.
Table 6-2 to Table 6-7 present the Net Benefit Ratios, which range from 0.15 to 0.85, by regions
and species.27'28 See Chapter 1, Section 1.2 for descriptions of the seven study regions. EPA
excluded the Inland region from the analysis because of a negligible commercial fishing harvest
in this region. EPA notes that this approach yields an estimate of benefits to commercial
fisherman, not benefits to society as a whole because changes in consumer surplus are not
captured, and because people may also have nonmarket values for commercial fish (e.g.,
recreational and existence values). As described in Section 6.1.1.1, EPA did not estimate changes
in consumer surplus because the expected changes in consumer surplus due to the final rule will
27 Positive Net Benefits Ratios reflect the assumption that commercial fishers will accrue rents (profits) in regulated
fisheries. When calculating the Net Benefits Ratios, EPA assumed that the predicted changes in harvest are such
that fixed costs and variable costs per ton will not change. If costs remain constant, a marginal change in harvest is
more likely to result in increases in profit and positive producer surplus.
28 In the case of species aggregates (e.g., forage species), EPA assumed that the net benefit ratio is equal to the
simple average of all empirically estimated net benefit ratios in the region. Species aggregates are listed as "Other"
in Table 6-2 to Table 6-7.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 6: Commercial Fishing Benefits
be minor. EPA's analysis of nonmarket benefits for fisheries improvements is presented in
Chapter 8.
Table 6-2: California Region, Management Method, Gear Type, Status of Stock, and Net
Benefits Ratio, by Species
Species
Main Management
Method
Main Gear
Type
Status of Stock3
Net Benefits
Ratio
Anchovies
Annual landings
Roundhaul
Not subject to
overfishing
0.64
Cabezon
Total allowable catch
Hook-and-line
Not overfished or subject
to overfishing
0.52
Crabs
Seasonal closures
Pots and traps
Undefined
0.74
Drum and Croaker
Permits
Nets
Unknown
0.42
Dungeness Crab
Size, no females, closed
during molting season
Traps
Unknown
0.74
Flounders
Quotas
Bottom trawl
Not overfished or subject
to overfishing
0.64
California Halibut
Total allowable catch
Longline
Unknown
0.58
Other
N/A
N/A
N/A
0.53
Rockfish
Quotas
Trawls
Not overfished or subject
to overfishing15
0.62
California
Scorpionlish
Quotas
Otter trawl
Not overfished
0.47
Sculpin
Nonrestnctive permits
Trawls
Unknown
0.64
Sea Bass
Season, si/.e. gear
restrictions
Gillnets
Unknown
0.66
Shad. American
None
Nets
Unknown
0
Shrimp
Seasonal closures
Trawl
Unknown
0.15
Smelt
Seasonal closures
Nets
Unknown
0.66
Surfperch
Quotas
Handlines
Overfished but not
subject to overfishingb'c'd
0.37
N/A = not applicable
"Status of stock designations based on data from the NMFS, Summary of Stock Status, 2ntl Quarter 2012 (NMFS 2012b).
b Species group consists of many individual component species with conflicting stock status. The most common stock status
among the component species was designated the Status of Stock for the species group.
c "Perch" species were used as a proxy for surfperch.
11 "Overfished but not subject to overfishing" means that the fish stock is at a low level but is expected to rebuild given
current rates of commercial fishing.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 6: Commercial Fishing Benefits
Table 6-3: North Atlantic Region, Management Method, Gear Type, Status of Stock, and
Net Benefits Ratio, by Species
Species
Main Management
Method
Main Gear Type
Status of Stock3
Net Benefits
Ratio
Bluefish
Quotas
Gillnets
Not overfished or subject
to overfishing
0.63
Butteriish
Quotas
NA
Not subject to overfishing
0.64
Atlantic Cod
Time/area closures
Otter trawl
Overfished or subject to
overfishing
0.66
Crab
Size, sex, season
Traps
Unknown
0.57
American Plaice
Size
Otter trawl
Not overfished or subject
to overfishing
0.63
Windowpane
Time/area closures
Bottom trawl
Overfished but not subject
to overfishingb'°
0.63
Winter Flounder
Quotas
Otter trawls
Overfished but not subject
to overfishing15
0.64
Flounder
Total allowable landing
Bottom trawl
Overfished or subject to
overfishing15
0.63
Red Hake
Quotas
Otter trawls
Not overfished or subject
to overfishing
0.62
Silver Hake
Quotas
Otter trawls
Not overfished or subject
to overfishing
0.63
Atlantic Herring
Total allowable catch
Purse seine
Not overfished or subject
to overfishing
0.76
Atlantic
Mackerel
Annual quota
Unknown
Not overfished or subject
to overfishing
0.77
Atlantic
Menhaden
Not reg. In this area
Unknown
Subject to overfishing but
not overfished
0.68
Other
N/A
N/A
N/A
0.57
White Perch
Size limits
Unknown
Unknown
0.82
Pollock
Time/area closures
Bottom trawl
Not overfished or subject
to overfishing
0.71
Sculpin
Open access
Unknown
Unknown
0
Scup
Quotas
Otter trawls
Not overfished or subject
to overfishing
0.69
Searobin
Open access (by catch)
Unknown
Unknown
0
Shad. American
Mortality taraets
Unknown
Overfished
0.6
Skate
Catch limits
Otter trawl
Not overfished or subject
to overfishing15
0.68
Tautog
Possession limits
Otter trawl
Unknown
0.46
Weakfish
Size limits
Trawls
Overfished but not subject
to overfishing
0.76
N/A = not applicable
'Status of stock designations based on data from the National Marine Fisheries Service, Summary of Stock Status, 2ntl Quarter 2012
(NMFS 2012b). Supplemental stock status designations based on data from the Atlantic States Marine Fisheries Commission
(ASMFC 2012).
b Species group consists of many individual component species with conflicting stock status. The most common stock status among
the component species was designated the Status of Stock for the species group.
c "Overfished but not subject to overfishing" means that the fish stock is at a low level but is expected to rebuild given current rates
of commercial fishing.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 6: Commercial Fishing Benefits
Table 6-4: Mid-Atlantic Region, Management Method, Gear Type, Status of Stock, and
Net Benefits Ratio, by Species
Species
Main Management
Method
Main Gear Type
Status of Stock3
Net Benefits
Ratio
Alewife
Bans, species of concern
Fish weirs
Overfished
0.85
American Shad
Chesapeake fishery
closed
Unknown
Overfished
0.84
Atlantic Croaker
Gear restrictions
Gillnets
Not overfished or subject to
overfishing
0.74
Atlantic
Menhaden
Open access
Purse seine, otter
trawl, gill net
Not overfished or subject to
overfishing
0.67
Black Drum
Quotas
Unknown
Unknown
0.7
Blue Crab
Limits on female crabs,
size
Pots
Unknown
0.57
Bluefish
Quotas
Gillnets
Not overfished or subject to
overfishing
0.63
Butterfish
Quotas
Unknown
Not subject to overfishing
0.64
Crab
Season, size
Unknown
Unknown
0.57
Drum and
Croaker
Gear restrictions, quotas
Nets
Not subject to overfishing
0.74
Flounder
Quotas
Bottom trawl
Not overfished or subject to
overfishing
0.65
Other
N/A
N/A
N/A
0.73
Red Hake
Quotas
Otter trawls
Not overfished or subject to
overfishingb
0.62
Scup
Quotas
Otter trawls
Not overfished or subject to
overfishing
0.69
Searobin
Open access
Unknown
Unknown
0
Silver Hake
Quotas
Otter trawls
Not overfished or subject to
overfishingb
0.63
Spot
License
Haul seines
Unknown
0.84
Striped Bass
Quotas
Gill nets
Not overfished or subject to
overlishinsi
0.67
Striped Mullet
Gear restrictions
Cast nets
Unknown
0.7
Tautog
Possession limits
Otter trawl
Overfished and subject to
overfishing
0.46
Weakfish
Size limits
Trawls
Overfished but not subject
to overfishingc
0.76
White Perch
Size limits
Unknown
Unknown
0.82
N/A = not applicable
' Status of stock designations based on data from the NMFS, Summary of Stock Status, 2ntl Quarter 2012 (NMFS 2012b).
Supplemental stock status designations based on data from the Atlantic States Marine Fisheries Commission (ASMFC 2012).
b Estimates from the North Atlantic region are presented because red and silver hake stocks were not reported in the Mid-Atlantic
region.
c "Overfished but not subject to overfishing" means that the fish stock is at a low level but is expected to rebuild given current rates
of commercial fishing.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 6: Commercial Fishing Benefits
Table 6-5: South Atlantic Region, Management Method, Gear Type, Status of Stock, and
Net Benefits Ratio, by Species
Species
Main Management
Method
Main Gear Type
Status of Stock3
Net Benefits
Ratio
Blue Crab
Size limits
Pots
Unknown
0.57
Crab
Size, sex, season limits
Traps
Unknown
0.57
Drum and
Croaker
Open access (by catch)
Otter trawl bottom,
gill nets
Not subject to overfishing
0.54
Atlantic
Menhaden
Five year annual cap on
reduction fishery in
Chesapeake
Unknown
Subject to overfishing but
not overfished
0.76
Other
N/A
N/A
N/A
0.59
Spot
License
I laul seines
Unknown
0.7
Stone Crab
Si/.e limits
Traps
Unknown
0.58
Weakfish
Size limits
Trawls
Overfished but not subject
to overfishingb
0.64
"Status of stock designations based on data from the NMFS, Summary of Stock Status, 2ntl Quarter 2012 (NMFS 2012b).
Supplemental stock status designations based on data from the Atlantic States Marine Fisheries Commission (ASMFC 2012).
b "Overfished but not subject to overfishing" means that the fish stock is at a low level but is expected to rebuild given current rates
of commercial fishing.
Table 6-6: Gulf of Mexico Region, Management Method, Gear Type, Status of Stock, and
Net Benefits Ratio, by Species
Species
Main Management
Method
Main Gear Type
Status of Stock3
Net Benefits
Ratio
Blue Crab
Limited entry, pot limits
Pots
Unknown
0.72
Black Drum
Limited access permits
Hand lines, gill nets
Unknown
0.69
Leatherjacket
N/A
Rod/reel, hand and
long lines, pots and
traps
Unknown
0
Mackerels
Quotas
Hook-and-line
Not overfished or subject to
overlishinsi
0.75
Menhaden
Seasonal/area closures
Purse seines
Unknown
0.76
Other
N/A
N/A
N/A
0.46
Sea 1 kisses
Quotas
Traps
Unknown
0.72
Sheepshead
Si/.e
Cast net
Unknown
0.84
Shrimp
Same as pink shrimp
Unknown
Not overfished or subject to
overfishingb
0.43
Spot
License
I laul seines
Unknown
0.54
Stone Crab
Si/.e
Traps
Not subject to overfishing
0.71
Striped Mullet
Gear restrictions
Strike nets
Unknown
0.79
Striped Mullet
Gear restrictions
Strike nets
Unknown
0.79
"Status of stock designations based on data from the NMFS, Summary of Stock Status, 2ntl Quarter 2012 (NMFS 2012b).
b Species group consists of many individual component species with conflicting stock status. The most common stock status among
the component species was designated the Status of Stock for the species group.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 6: Commercial Fishing Benefits
Table 6-7: Great Lakes Region, Management Method, Gear Type, Status of Stock, and
Net Benefits Ratio, by Species
Species
Main Management
Method
Main Gear Type
Status of Stock
Net Benefits Ratio
Bullhead
State specific
Gill and trap nets
Unknown
0.29
Freshwater Drum
State specific
Gill and trap nets
Unknown
0.29
()ther
State specilie-
Gill and trap nets
Unknown
0.29
Smelt
State specific
Gill and trap nets
Unknown
0.29
White Bass
State specilic-
Gill and trap nets
Unknown
0.29
Whitelish
State specilic-
Gill and trap nets
Unknown
0.29
Yellow Perch
State specilic-
Gill and trap nets
Unknown
0.29
6.1.1.3 Step 3: Estimating Net Social Benefits When the Fishing Harvest Increases
EPA estimated the change in net social benefits when the commercial fishing harvest increases
from F1 to F2 by adding the results from Steps 1 and 2. Because area U is a transfer from
commercial fishers to consumers, it does not affect social benefits. Therefore, the change in net
social benefits is areaX + Y (see Figure 6-1). However, if demand elasticity is such that changes
in price are negligible, as EPA expects (Section 6.1.1.1), area X will be negligible relative to Y,
and total social benefits will be measured by area Y.
6.2 Benefits Estimates for Regional Commercial Fishing
The first step of the analysis of commercial fishing benefits involves a fishery-based assessment
of IM&E-related changes in harvested species landings. Many of the fish species affected by
IM&E at CWIS sites are harvested both recreationally and commercially. As described in Section
6.1.1, EPA assumed a linear relationship between stock and harvest and used historical NMFS
landings data on commercial and recreational catch to determine the proportions of total species
harvest attributable to recreational and commercial fishing. EPA applied these proportions to the
estimated total change in harvest to distribute benefits between commercial and recreational
fisheries. EPA then used the estimated change in commercial fishery harvest as a basis for
estimating changes in producer surplus in the commercial fishing industry.
EPA assessed whether potential harvest increases under the final rule and options considered are
reasonable when compared to historic harvest data. For this assessment, EPA compared estimated
increases in commercial yield from the elimination of baseline IM&E for each species to average
regional commercial harvest from 2007 to 2011. Table 6-8 summarizes baseline IM&E and
harvest data for fourteen species for which the potential increase in commercial yield from the
elimination of baseline IM&E exceeds 10 percent of regional harvest.
Notably, none of the species identified include major fisheries: many are infrequently targeted,
and several have historical commercial harvests which vary widely on an annual basis. In many
cases, the species identified are not subject to a federal fisheries management plan, and the
overall status of stock is unknown. These uncertainties may increase the error associated with the
regional-scale effects occurring as a consequence of the extrapolation of IM&E. Moreover, it is
possible that the regional extrapolation of species-specific results may be biased because
available IM&E studies are old (and therefore reflect IM&E under substantially different
populations), or because particularly high IM&E counts at one or more facilities measured during
an anomalous year may result in erroneous estimates of IM&E.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 6: Commercial Fishing Benefits
The sixteen species for which the potential increase in commercial yield from the elimination of
baseline IM&E exceeds 10 percent of regional harvest include cabezon, California halibut,
rockfish, and sculpin in the California region; sculpin in the North Atlantic region; spot, and
weakfish in the Mid-Atlantic region; black drum, drum and croaker, leatheijacket, spot, and
striped mullet in the Gulf of Mexico region; and freshwater drum, smelt, and white bass in the
Great Lakes region. No increases exceeding 10 percent were found in the South Atlantic region.
Among these fourteen species, the potential harvest increases range from 12 percent for striped
mullet in the Gulf of Mexico to 1,512 percent for sculpin in the North Atlantic.
EPA used harvest and fisheries data to develop reasonable caps on increases in commercial
harvest from the elimination of baseline IM&E and IM&E reductions under the final rule and
options considered. Economists and biologists with NMFS recommended using either maximum
sustainable yield (MSY) or historical harvest to assign reasonable caps on projected total harvest
under the post-compliance scenario.29 NMFS biologists provided MSY for three species groups:
California cabezon, California sculpin, and West Coast rockfishes.30 While there is no stock
assessment for halibut, NMFS biologists suggested averaging the most recent four peaks in
harvest. For other species lacking MSY data, EPA capped post-compliance harvest at the 90th
percentile of annual harvest from 1982 to 2011. This follows recommendations from NMFS
scientists to use harvest data for 25 years or more.31
North Atlantic sculpin. Mid-Atlantic spot, and Great Lakes freshwater drum and white bass were
the only four species estimated to reach these caps within EPA's analysis. Caps for these four
species are shown in bold type in Table 6-8. Notably, historical commercial catch of both North
Atlantic sculpin and Mid-Atlantic spot are widely variable. For example, between 1995 and 2011,
there were several years with no commercial catch of sculpin reported. For spot, commercial
harvests changed by more than 2 million pounds per year (alternating between increases and
decreases) for each year between 2006 and 2011. For Northeast Atlantic sculpin and Mid-Atlantic
spot, these data suggest that commercial catch may not be limited by fish population, and that a
large and sustained increase in commercial landings beyond the cap due to the reduction of
IM&E is unreasonable.
The following sections present estimated benefits from commercial harvest changes in six of the
seven study regions and the total for the six regions. The Inland region is excluded from the
analysis due to a negligible commercial fishing harvest in this region.
29 Cindy Thomson, NMFS, personal communication (2008).
30 NMFS biologists suggested that sculpin in California be evaluated in combination with scorpionfish, as these
species are grouped when determining the MSY.
31 Many fish populations peaked more than 25 years ago, when virgin, non-exploited populations existed and
maximum harvests were achievable.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 6: Commercial Fishing Benefits
Table 6-8: Potential Harvest Increase from Eliminating IM&E as a Percentage of Total
Harvest and Potential Harvest Capping Rules Used in EPA's Analysis
Region and
Species
Baseline
Harvest
2007-2011
(1,000 lbs.)
Baseline
IM&E
(1,000 lbs.)
Potential
%
Increase
in
Harvest
Maximum
Harvest
1982-2011
(1,000 lbs.)
90th
Percentile
of Max.
Harvest
(1,000 lbs.)
MSY or
Other
Capping
Rule
(1,000 lbs.)
Cap Used
(1,000
lbs.)
California
Cabezon
53.7
76.1
142%
374.2
261.2
207.2a
No Cape
California Halibut
495.5
176.9
36%
1,337.1
1.238.4
982. lb
No Cap
California Dram
and Croaker
53.8
6.9
13%
1,491.5
1,288.6
No Cap
California
Rockfish
2,741.3
1,634.5
60%
58,286.7
42.942.2
77,161.8C
No Cap
California Sculpin
3.8
3.7
97%
19.5
7.6
482.8 d
No Cap
North Atlantic
Sculpins
1.6
24.2
1,512%
4.8
4.8
4.8
Mid-Atlantic Spot
3.478.4
1.303.1
37%
4.784.6
4.543.0
4,543.0
Mid-Atlantic
Weakfish
267.4
503.7
188%
7,023.5
6,714.1
No Cap
Gulf of Mexico
Black Dram
4,621.9
1,945.0
42%
10,644.4
7,314.6
No Cap
Gulf of Mexico
Drum and
Croaker
111.8
47.8
43%
2,934.7
663.8
No Cap
Gulf of Mexico
Leatherjacket
61.0
107.1
176%
519.7
447.4
No Cap
Gulf of Mexico
Spot
16.9
46.3
274%
473.4
356.4
No Cap
Gulf of Mexico
Striped Mullet
10,800.3
1,343.6
12%
30,433.6
27,789.7
No Cap
Great Lakes
Freshwater Dram
585.9
248.8
42%
905.1
795.0
209.1
795.0
Great Lakes
Smelt
380.5
92.9
24%
4,105.0
3,672.0
No Cap
Great Lakes
White Bass
523.6
916.5
175%
1,332.0
771.7
248.1
771.7
a MSY (maximum sustainable yield).
b Average of most recent four peaks in harvest.
' MSY for rockfishes for the West Coast.
11 MSY for all scorpionfish and sculpins.
e "No Cap" indicates that no cap was used during benefit estimation because increases did not result in exceedance of the 90th
percentile of maximum harvest, MSY, or other capping rule.
Sources: U.S. EPA analysis for this report; NMFS data on baseline han'est, historical landings, and MSY.
6.2.1 California Region
Baseline levels of IM&E account for 1.9 million pounds of commercial fishing losses annually in
the California region, as shown in Table 6-9. Rockfish account for the major portion of overall
losses in this region. EPA estimated the annual undiscounted commercial fishing benefits of
eliminating baseline IM&E to be approximately $2.0 million, as shown in Table 6-9. Applying a
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 6: Commercial Fishing Benefits
3 percent discount rate, EPA estimates the annualized benefits of eliminating baseline IM&E to
be $1.7 million. Applying a 7 percent rate, these annualized benefits are approximately $1.5
million.
As shown in Table 6-9, EPA estimates that annual commercial harvest will increase by
approximately 7,000 pounds under the final rule. Annualized benefits to commercial fishers under
the file rule will be about $3,000 using a 3 percent discount rate and $2,000 using a 7 percent
discount rate. For other options considered, the annual increase is commercial harvest would
range from about 7,000 pounds under Proposal Option 4 to 1.2 million pounds under Proposal
Option 2. The associated annual benefits under other options considered would range from about
$3,000 to $651,000 using a 3 percent discount rate and $2,000 to $422,000 using a 7 percent
discount rate (Table 6-9). Appendix H presents species-specific results for the estimated annual
increase in harvest and monetary benefits to commercial fishers.
Table 6-9: Commercial Fishing Benefits from Eliminating or Reducing Baseline
IM&E Mortality Losses at Regulated Facilities in the California Region, for the
Final Rule and Options Considered (2011$)
Regulatory Option
Annual Increase in
Commercial
Harvest
(1,000 lbs)
Annualized Benefits from Increase in Commercial
Harvest
(2011$, 1,000s)
Undiscounted
3% Discount
Rate
7% Discount
Rate
Proposal Option 4
7
$5
$3
$2
Final Rule
7
$5
$3
$2
Proposal Option 2
LI 77
$1,236
$651
$422
Baseline
1,929
$2,025
$1,698
$1,519
Source: U.S. EPA analysis for this report
6.2.2 North Atlantic Region
Baseline levels of IM&E account for 414,000 pounds of annual commercial fishing losses in the
North Atlantic region, as shown in Table 6-10, with flounder playing a particularly important
role. EPA estimated the annual undiscounted benefits to commercial fishers from eliminating
baseline IM&E to be approximately $476,000, as shown in Table 6-10. EPA estimates the total
annualized benefits from eliminating baseline IM&E, applying a 3 percent discount rate, to be
$399,000. Applying a 7 percent rate, these annualized benefits are approximately $357,000.
As shown in Table 6-10, annual commercial harvest will increase by approximately 7,000 pounds
under the final rule. Annualized benefits to commercial fishers under the final rule will be about
$4,000 using 3 percent discount rates and $3,000 using 7 percent discount rates. For other options
considered, the annual increase in commercial harvest ranges from about 3,000 pounds under
Proposal Option 4 to 318,000 pounds under Proposal Option 2. The associated annual benefits
under other options considered range from about $1,000 to $202,000 using a 3 percent discount
rate and $1,000 to $136,000 using a 7 percent discount rate (Table 6-10). Appendix H presents
species-specific results for the estimated annual increase in harvest and monetary benefits to
commercial fishers.
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Chapter 6: Commercial Fishing Benefits
Table 6-10: Commercial Fishing Benefits from Eliminating or Reducing
Baseline IM&E Mortality Losses at Regulated Facilities in the North Atlantic
Region, for the Final Rule and Options Considered (2011$)
Regulatory Option
Annual Increase in
Commercial
Harvest
(1,000 lbs)
Annualized Benefits from Increase in Commercial
Harvest
(2011$, 1,000s)
Undiscounted
3% Discount
Rate
7% Discount
Rate
Proposal Option 4
3
$2
$1
$1
Final Rule
7
$6
$4
$3
Proposal Option 2
318
$365
$202
$136
Baseline
414
$476
$399
$357
Source: U.S. EPA analysis for this report
6.2.3 Mid-Atlantic Region
Baseline levels of IM&E account for approximately 7.8 million pounds of commercial fishing
losses annually in the Mid-Atlantic region, as shown in Table 6-11. Atlantic menhaden, blue crab,
drum and croaker, spot, weakfish, and "other" species32 are the primary drivers of IM&E in the
Mid-Atlantic region. EPA estimated the annual undiscounted benefits to commercial fishers from
eliminating baseline IM&E to be $2.6 million, as shown in Table 6-11. Applying a 3 percent
discount rate, annualized benefits from eliminating baseline IM&E are estimated to be $2.2
million. Applying a 7 percent rate, these annualized benefits are approximately $1.9 million.
As shown in Table 6-11, EPA estimates that annual commercial harvest will increase by
approximately 3.1 million pounds under the final rule. Annualized benefits to commercial fishers
under the final rule will be about $260,000 using a 3 percent discount rate and $190,000 using a 7
percent discount rate. For other options considered, the annual increase in commercial harvest
ranges from 2.9 million pounds under Proposal Option 4 to 7.1 million pounds under Proposal
Option 2. The associated annual benefits under other options considered range from about
$242,000 to $1.2 million using a 3 percent discount rate and $177,000 to $770,000 using a 7
percent discount rate (Table 6-11). Appendix H presents species-specific results for the estimated
annual increase in harvest and monetary benefits to commercial fishers.
32 The "other" species category includes losses which could not be assigned to a specific species group.
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Chapter 6: Commercial Fishing Benefits
Table 6-11: Commercial Fishing Benefits from Eliminating or Reducing
Baseline IM&E Mortality Losses at Regulated Facilities in the Mid-Atlantic
Region, for the Final Rule and Options Considered (2011$)
Regulatory Option
Annual Increase in
Commercial
Harvest
(1,000 lbs)
Annualized Benefits from Increase in Commercial
Harvest
(2011$, 1,000s)
Undiscounted
3% Discount
Rate
7% Discount
Rate
Proposal Option 4
2.873
$383
$242
$177
Final Rule
3.072
$411
$260
$190
Proposal Option 2
7.000
$2,373
$1,206
$770
Baseline
7.758
$2,586
$2,169
$1,939
Source: U.S. EPA analysis for this report
6.2.4 South Atlantic Region
Baseline levels of IM&E account for 78,000 pounds of commercial fishing losses in the South
Atlantic region, as shown in Table 6-12. The estimated undiscounted annual commercial fishing
benefits of eliminating baseline IM&E are driven primarily by Atlantic menhaden, spot, and drum
and croaker and total $20,000, as shown in Table 6-12. Applying a 3 percent discount rate, the
annualized benefits of eliminating baseline IM&E are estimated to be $17,000. Applying a 7
percent rate, these annualized benefits are $15,000.
As shown in Table 6-12, EPA estimates that annual commercial harvest will increase by
approximately 41,000 pounds under the final rule. Annualized benefits to commercial fishers
under the final rule will be about $6,000 using 3 percent discount rates and $5,000 using 7
percent discount rates. For other options considered, the annual increase in commercial harvest
ranges from 37,000 pounds under Proposal Option 4 to 76,000 pounds under Proposal Option 2.
The associated annual benefits under other options considered range from $6,000 to $10,000
using a 3 percent discount rate and $4,000 to $7,000 using a 7 percent discount rate (Table 6-12).
Appendix H presents species-specific results for the estimated annual increase in harvest and
monetary benefits to commercial fishers.
Table 6-12: Commercial Fishing Benefits from Eliminating or Reducing
Baseline IM&E Mortality Losses at Regulated Facilities in the South Atlantic
Region, for the Final Rule and Options Considered (2011$)
Regulatory Option
Annual Increase in
Commercial
Harvest
(1,000 lbs)
Annualized Benefits from Increase in Commercial
Harvest
(2011$, 1,000s)
Undiscounted
3% Discount
Rate
7% Discount
Rate
Proposal Option 4
37
$9
$6
$4
Final Rule
41
$10
$6
$5
Proposal Option 2
76
$19
$10
$7
Baseline
78
$20
$17
$15
Source: U.S. EPA analysis for this report
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 6: Commercial Fishing Benefits
6.2.5 Gulf of Mexico Region
Baseline levels of IM&E account for more than 6.0 million pounds of commercial fishing losses
in the Gulf of Mexico region annually, as shown in Table 6-13. These losses are driven by black
drum, striped mullet, and Atlantic menhaden. The estimated undiscounted annual commercial
fishing benefits from eliminating baseline IM&E are approximately $3.9 million, as shown in
Table 6-13. Applying a 3 percent discount rate, estimated commercial fishing benefits from
eliminating baseline IM&E are estimated to be $3.4 million. Applying a 7 percent rate, these
annualized losses are approximately $3.2 million.
As shown in Table 6-13, EPA estimates that annual commercial harvest will increase by
approximately 1.7 million pounds under the final rule. Annualized benefits to commercial fishers
under the file rule will be about $515,000 using a 3 percent discount rate and $379,000 using a 7
percent discount rate. For other options considered, the annual increase in commercial harvest
ranges from 1.6 million pounds under Proposal Option 4 to 4.3 million pounds under Proposal
Option 2. The associated annual benefits under other options considered range from $497,000 to
$1.7 million using a 3 percent discount rate and $365,000 to $1.3 million using a 7 percent
discount rate (Table 6-13). Appendix H presents species-specific results for the estimated annual
increase in harvest and monetary benefits to commercial fishers.
Table 6-13: Commercial Fishing Benefits from Eliminating or Reducing
Baseline IM&E Mortality Losses at Regulated Facilities in the Gulf of Mexico
Region, for the Final Rule and Options Considered (2011$)
Regulatory Option
Annual Increase in
Commercial
Harvest
(1,000 lbs)
Annualized Benefits from Increase in Commercial
Harvest
(2011$, 1,000s)
Undiscounted
3% Discount
Rate
7% Discount
Rate
Proposal Option 4
1.642
$779
$497
$365
Final Rule
1.704
$808
$515
$379
Proposal Option 2
4.265
$2.651
$1,702
$1,256
Baseline
6.033
$3,926
$3,427
$3,161
Source: U.S. EPA analysis for this report
6.2.6 Great Lakes Region
Baseline levels of IM&E account for more than 1.1 million pounds of commercial fishing losses
in the Great Lakes region annually, as shown in Table 6-14. These losses are driven by the white
bass, freshwater drum, and "other" species. EPA estimated the annual undiscounted commercial
fishing benefits from eliminating baseline IM&E in this region to be approximately $279,000, as
shown in Table 6-14. Total annualized commercial benefits from eliminating baseline IM&E,
applying a 3 percent discount rate, are estimated to be $244,000. Applying a 7 percent rate, these
annualized losses are $225,000.
As shown in Table 6-14, EPA estimates that annual commercial harvest will increase by 838,000
pounds under the final rule. Annualized benefits to commercial fishers under the final rule will be
about $145,000 using a 3 percent discount rate and $110,000 using a 7 percent discount rate. For
other options considered, the annual increase in commercial harvest ranges from 784,000 pounds
under Proposal Option 4 to 1.1 million pounds under Proposal Option 2. The associated annual
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 6: Commercial Fishing Benefits
benefits under other options considered range from $135,000 to $162,000 using a 3 percent
discount rate and $102,000 to $116,000 using a 7 percent discount rate (Table 6-14). Appendix H
presents species-specific results for the estimated annual increase in harvest and monetary
benefits to commercial fishers.
Table 6-14: Commercial Fishing Benefits from Eliminating or Reducing
Baseline IM&E Mortality Losses at Regulated Facilities in the Great Lakes
Region, for the Final Rule and Options Considered (2011$)
Regulatory Option
Annual Increase in
Commercial
Harvest
(1,000 lbs)
Annualized Benefits from Increase in Commercial
Harvest
(2011$, 1,000s)
Undiscounted
3% Discount
Rate
7% Discount
Rate
Proposal Option 4
784
$202
$135
$102
Final Rule
838
$217
$145
$1 10
Proposal Option 2
1.092
$266
$162
$1 16
Baseline
1.137
$279
$244
$225
Source: U.S. EPA analysis for this report
6.2.7 National Estimates
Nationally, baseline levels of IM&E account for more than 17.3 million pounds of commercial
fishing losses annually, as shown in Table 6-15. EPA estimated the annual undiscounted
commercial fishing benefits from eliminating baseline IM&E to be approximately $9.3 million, as
shown in Table 6-15. Total annualized commercial benefits from eliminating baseline IM&E,
applying a 3 percent discount rate, are estimated to be $8.0 million. Applying a 7 percent rate,
these annualized losses are $7.2 million.
As shown in Table 6-15, EPA estimates that annual commercial harvest will increase by 5.7
million pounds under the final rule. Annualized benefits to commercial fishers under the final rule
will be about $0.9 million using a 3 percent discount rate and $0.7 million using a 7 percent
discount rate. For other options considered, the annual increase in commercial harvest ranges
from 5.3 million pounds under Proposal Option 4 to 14.0 million pounds under Proposal Option
2. The associated annual benefits under other options considered range from $0.9 to $3.9 million
using a 3 percent discount rate and $0.7 to $2.7 million using a 7 percent discount rate (Table 6-
15). Appendix H presents species-specific results for the estimated annual increase in harvest and
monetary benefits to commercial fishers for each region.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 6: Commercial Fishing Benefits
Table 6-15: National Commercial Fishing Benefits from Eliminating or Reducing
Baseline IM&E Mortality Losses at Regulated Facilities, for the Final Rule and
Options Considered (2011$)
Regulatory Option
Annual Increase in
Commercial
Harvest
(1,000 lbs)
Annualized Benefits from Increase in Commercial
Harvest
(2011$, 1,000s)
Undiscounted
3% Discount
Rate
7% Discount
Rate
Proposal Option 4
5,345
$1,379
$883
$652
Filial Rule
5,669
$1,457
$934
$689
Proposal Option 2
14,019
$6,910
$3,935
$2,707
Baseline
17,349
$9,312
$7,953
$7,215
Source: U.S. EPA analysis for this report
6.3 Limitations and Uncertainties
Table 6-16 summarizes the caveats, omissions, biases, and uncertainties known to affect the
estimates that EPA developed for the benefits analysis.
Table 6-16: Caveats, Omissions, Biases, and Uncertainties in the Commercial Benefits
Estimates
Issue
Impact on Benefits
Estimate
Comments
Change in commercial landings due
to IM&E is uncertain
Uncertain
Projected changes in harvest may be underestimated
because cumulative impacts of IM&E over time,
interactions with other stressors, and population
changes, are not considered.
Some estimates of commercial
harvest losses due to IM&E under
current conditions are not
region/species-specific
Uncertain
EPA estimated the impact of IM&E in the case
study analyses based on the most current data
available data provided by the facilities. However,
in some cases these data are 20 years old or older.
Thus, they may not reflect current fish stock and
waterbody conditions.
Effect of change in stocks on
landings is not considered
Uncertain
EPA assumed a linear stock to harvest relationship,
so that a 10 percent change in stock would have a
10 percent change in landings; this may be low or
high, depending on the condition of the stocks.
Region-specific fisheries regulations also will affect
the validity of the linear assumption.
Effect of uncertainty in estimates of
commercial landings and prices is
unknown
Uncertain
EPA assumed that NMFS landings data are accurate
and complete. In some cases prices and/or
quantities may be reported incorrectly.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 7: Recreational Fishing Benefits
7 Recreational Fishing Benefits
7.1 Introduction
This chapter presents the estimated benefits to recreational anglers from improved recreational
fishing opportunities due to reductions in IM&E under the final rule and regulatory options EPA
considered for section 316(b). EPA used a benefit transfer approach based on a meta-analysis of
economic studies of recreational fishing benefits from improved catch rates. Benefit transfer
involves adapting research conducted for another purpose to address the policy questions at hand
(Bergstrom and De Civita 1999). Benefit-cost analysis of environmental regulations rarely affords
sufficient time to conduct original stated or revealed preference studies specific to policy effects.
Benefit transfer is a widely used approach which provides information to inform policy decisions
in benefit-cost analysis of environmental regulations. EPA notes that Smith et cil. (2002, p. 134)
state that. .nearly all benefit cost analyses rely on benefit transfers..."
Boyle and Bergstrom (1992) define benefit transfer as "the transfer of existing estimates of
nonmarket values to a new study which is different from the study for which the values were
originally estimated." There are four types of benefit transfer studies: point estimate, benefit
function, meta-analysis, and Bayesian techniques (USEPA 2010a). These types may be
categorized into three fundamental classes: (1) transfer of an unadjusted fixed value estimate
generated from a single study site; (2) the use of expert judgment to aggregate or otherwise alter
benefits to be transferred from a site or set of sites; and (3) estimation of a value estimator model
derived from study site data, often from multiple sites (Bergstrom and De Civita 1999). Recent
studies have shown little support for the accuracy or validity of the first method, leading to
increased attention to, and use of, adjusted values estimated by one of the remaining two
approaches (Bergstrom and De Civita 1999). The third class of benefit transfer approaches
includes meta-analysis techniques, which economists have explored increasingly as a potential
basis of policy analysis conducted by various government agencies charged with the stewardship
of natural resources.33
Section 7.2 provides a brief overview of the benefit transfer methodology EPA used for
estimating the recreational fishing benefits. Chapter A5 of EPA's Regional Benefits Analysis of
the Final Section 316(b) Phase III Existing Facilities Rule (USEPA 2006b) provides a detailed
description of the benefit transfer methodology that EPA employed in this analysis. Section 7.2
also highlights updates to the Phase III methodology. Section 7.3 presents the recreational fishing
benefits by region, and Section 7.4 summarizes the limitations and uncertainties inherent in
EPA's analysis of recreational fishing benefits.
7.2 Methodology
EPA's analysis of recreational fishing benefits from reducing IM&E at CWIS at regulated
facilities includes the following general steps:
Meta-analysis is "the statistical analysis of a large collection of results from individual studies for the purposes of
integrating the findings" (Glass 1976).
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Chapter 7: Recreational Fishing Benefits
1. Estimate the forgone catch of recreational fish (in number of fish) due to baseline
IM&E and increases in recreational harvest under regulatory options. EPA modeled
these losses using the methods presented in Chapter 3. EPA's estimates of recreational
fish losses are expressed as the number of harvestable adults because this is the measure
to which recreational values are attributed/4 Many of the fish species affected by IM&E
at CWIS sites are harvested both recreationally and commercially. EPA used the
proportion of total species landings attributable to recreational fishing to estimate
baseline losses in recreational harvest due to baseline (current) levels of IM&E and
reductions in recreational harvest losses under the final rule and other options considered.
2. Estimate the marginal value per fish. EPA used the estimated meta-regression
described in Chapter A5 of Regional Benefits Analysis of the Final Section 316(b) Phase
III Rule (USEPA 2006b) to estimate marginal values per fish for the species affected by
IM&E at all regulated existing facilities. To calculate the marginal value per fish for the
affected species, EPA chose input values for the independent variables based on the
affected species characteristics, study regions, and demographic characteristics of the
affected angling populations. The study design variables were selected based on current
economic literature. This step is described in more detail in Section 7.2.1.
3. Estimate the value of forgone recreational catch lost to baseline IM&E benefits
under regulatory options. EPA multiplied the marginal value per fish by the number of
recreational fish currently lost to baseline IM&E that would otherwise be caught by
recreational anglers and increases in recreational fishing harvest under policy options,
respectively.
7.2.1 Estimating Marginal Value per Fish
EPA used a benefit transfer function based on meta-analysis of recreational fishing studies from
the Section 316(b) Phase III Final Rule to estimate marginal values per fish for the species
affected by IM&E at regulated facilities. The general approach follows standard methods
illustrated by Johnston et cil. (2006) and Shrestha el al. (2007), among many others (e.g.,
Rosenberger and Phipps 2007). This function allows EPA to forecast willingness to pay (WTP)
based on assigned values for model variables, chosen to best represent a resource change in the
316(b) policy context. EPA's meta-analysis results imply a simple benefit function of the
following general form:
ln(WTP) = intercept + ^coefficient,)(Independent Variable Values,) (7-1)
Here, In (WTP) is the dependent variable in the meta-analysis—the natural log of WTP for
catching an additional fish. The independent variables included in the meta-analysis characterize
the species being valued, study location, baseline catch rate, elicitation and survey methods,
demographics of survey respondents, and other specific characteristics of each study.
To calculate the marginal value per fish for the species affected by regulated facilities, EPA chose
input values for the independent variables based on the characteristics of the affected species,
study regions, and demographic characteristics of the affected angling populations. The study
design variables were selected based on current economic literature. Table 7-1 provides the
34 Adult fish of harvestable age means that they are the age at which they can legally be harvested.
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Chapter 7: Recreational Fishing Benefits
independent variable names, the estimated variable coefficients (coefficient,-), and the assigned
input values for each of the independent variables in the model.
EPA followed Johnston et al. (2006) in assigning values for methodological attributes (i.e.,
variables characterizing the study methodology used in the original source studies), which are set
at mean values from the metadata except in cases where theoretical considerations dictate
particular assignments. This approach follows general guidance from Bergstrom and Taylor
(2006) that meta-analysis benefit transfer should incorporate theoretical expectations and
structures, at least in a weak form. In this instance, two of the methodology variables, RUM nest
and high_resp_rate, are included with an assigned value of one. RUM year represents the year in
which the study was conducted, converted to an index by subtracting 1976. It was given the value
of 9.37, corresponding to average study year of 1985, because there was no clear justification for
selecting a specific year based on the meta-data. In their detailed analysis of methodological
variable specifications for this meta-analysis model, Stapler and Johnston (2009) found that "the
additional error associated with an empirical, mean value treatment of methodological covariates
is relatively modest, on average."
EPA decided not to include the error term when using the regression equation to predict marginal
values per fish. Bockstael and Strand (1987) argue that if the econometric error in an equation is
due primarily to omitted variables, the error term should be included, but if the error is due
primarily to random preferences or measurement error, it should be excluded. Because the error
term is positive, the empirical effect of including this term is to increase the predicted marginal
values. The authors warned against the practice of assuming that all error is associated with
omitted variables. If the error is due to random preferences or measurement errors, the estimated
WTP values are likely to be upward biased if the error term is included. EPA decided not to
include the error term in the estimation of WTP per fish because the source of error in the
underlying meta-data is unknown. EPA notes that when the error term is excluded, the values
predicted by the regression equation are more consistent with those from the underlying studies.
Table 7-2 presents region- and species-specific values for the input variables that vary across
regions. Table 7-3 presents the estimated marginal value per fish for all species affected by IM&E
in each region.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 7: Recreational Fishing Benefits
Table 7-1: Independent Variable Assignments for Regression Equation
Variable
Coefficient
Assigned Value
Explanation
Intercept
-1.4568
1
Hie equation intercept was set to one by
default.
SP_conjoint
-1.1672
0
Binary variables denoting the type of stated
preference, travel cost, or random utility used
tor the study. Current academic literature
suggests that nested RUM models produce
the most accurate valuation results, so
RUM nest was set to one, and the other
study methodology variables were set to
zero.
SP_dichot
-0.9958
0
TC_individual
1.1091
0
TC_/onal
2.0480
0
RWMjiest
1.3324
1
RUM_nomiest
1.7892
0
SP_year
0.08754
0
Variables denoting the year that the study
was conducted by study type (stated
preference, travel cost, or random utility
model). SPjyear and TCjyear were set to
zero because EPA selected RUM, above.
RUM_vear was set equal to the average
value across the studies in the analysis, 9.37.
TC_year
-0.03965
0
RUM_year
-0.00291
9.37
Sl'jnail
0.5440
0
Spjnail and sp_phone correspond to mail
and phone survey methods l'or stated
preference studies, Since RUM nest was the
model specified above rather than stated
preference (i.e, SP conjoint, SP dichot),
SP wail and SP_phone were set to zero.
SP_phone
1.0859
0
high_resp_rate
-0.6539
1
Binary variable indicating that the survey
response rate exceeded 50 percent. EPA set
high response rate to one because high
response rates may provide more accurate
estimates.
inc_thou
0.003872
Varies
Household income of survey respondents in
thousands of dollars. Inc thou was set to the
median household income for each study
region evaluated, based on U.S. Census data.
age42_down
0.9206
0.0972
Binary variables indicating whether the
average age of respondents was less than 43
or 43 and greater. Age42 down and
age43 up were set to their sample means.
age43_up
1.2221
0.2711
tnpsl 9_do\\n
0.8392
0.1100
Miliary variables indicating whether the mean
number of fishing trips taken each year by
sample respondents was less than 20 or 20
and greater. Tripsl9 down and trips20 up
were set to their sample means.
trips20_up
-1.0112
0.3350
Binary variable indicating that respondents
in the sample were not local residents.
nonlocal
3.2355
0
Because the default (zero) value for the
nonlocal dummy variable represents a
combination of local and nonlocal anglers,
nonlocal was set to zero.
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 7: Recreational Fishing Benefits
Table 7-1: Independent Variable Assignments for Regression Equation
Variable
Coefficient
Assigned Value
Explanation
big_game_pac
2.2530
Varies
Biliary variables indicating the targeted
species. Species-targeted variables were
assigned input values based on
characteristics of the species affected by
IM&E and the study region. In general, the
big_game_natl
1.5323
Varies
big_game_satl
2.3821
Varies
small_game_pac
1.6227
Vanes
small_game_atl
1.4099
Varies
flatfish_pac
1.8909
Varies
llatlish_atl
1.3797
Vanes
other_sw
0.7339
Vanes
musky
3.8671
Varies
pike_\\ alley e
1.0412
Vanes
bassj'w
1.7780
Vanes
match between the allected species and the
variables in the meta-analysis equation was
good.
trout_CiI.
1.8723
Vanes
trout_nonGL
0.8632
Varies
salmon_pacific
2.3570
Varies
salmon_atl_morey
5.2689
Vanes
salmon_liI,
2.2135
Vanes
steelhead_pac
2.1904
Vanes
steelhead_GL
2.3393
Varies
crjionyear
-0.08135
Vanes
Variables describing catch rates. Cr nonyecir
indicates the catch rate for studies presenting
catch rate per hour, per day, or per trip. It
was assigned species and region-specific
values for the coastal and Great Lakes
regions based on catch rates data provided by
the National Marine Fisheries Service
(NMFS 2002, 2003) and the Michigan
Department of Natural Resources (MDNR
2002). For the Inland region, EPA assigned
values to the cr nonyecir variable based on
the average values for each species from the
studies. Spec cr is a binary variable
indicating that the study presents information
on the baseline catch rate. EPA set spec cr
to one. Catch_v ear is a binary variable
indicating that the study presented catch rates
on a per year basis and crjyecir is the annual
catch rate from the study. Crjyecir and
catch vear were set to zero because catch
per trip and catch per day are more common
measures of angling quality.
cr_year
-0.05208
0
catch_year
1.2693
0
spec_cr
0.6862
1
shore
-0.1129
Varies
cr_year
-0.05208
0
catch_year
1.2693
0
spec_cr
0.6862
1
shore
-0.1129
Varies
Binary variable indicating that all
respondents in the sample fished from shore.
Shore was assigned values based on NMFS
(2002,2003) and U.S. Fish and Wildlife
Service (USDOI and USDOC 2002) survey
data indicating the average percentage of
anglers who fish from shore in each region.
Source: U.S. EPA (2006)
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 7: Recreational Fishing Benefits
Table 7-2: Region- and Species-specific Variable Assignments for the Regression
Equation3
Variable
Region
California
North
Atlantic
Mid-
Atlantic
South
Atlantic
Gulf of
Mexico
Great
Lakes
Inland
inc thou
54.385
55.000
51.846
40.730
36.641
44.519
58.240
Shore
24.0
24.0
23.1
30.0
25.0
48.0
57.0
Speciesb
Species Type
Dummy
Variable0
Baseline Catch Rate, Expressed in Fish per Day (cr_nonyear)A
Small game6
small game atl,
small game_pac
2.7
1.6
1.6
2.2
2.2
2.1
Flatfisl/
flatfish atl,
flatfish _pac
1.3
1.0
1.0
1.5
Other
saltwater
other sm'
1.7
1.7
1.7
1.7
1.7
Salmon
Salmon GL
0.2
0.2
Walleye/pike
pike walleye
0.8
0.8
Bass
bassJw
0.2
0.2
Panlish"
4.7
4.7
4.7
Trout
3.2
3.2
Unidentified
1.7
1.7
1.7
1.7
1.9
1.9
3.8
a See Table 7-1 for information regarding the specification of variables that EPA held fixed across regions.
b The table is restricted to species groups which correspond to species impacted by IM&E at regulated facilities.
c This column indicates which species type dummy variable was set to one to represent each species.
11 Blank cells indicate that IM&E losses are not estimated for the species in that benefits region.
e For "small game" fish in the North Atlantic, Mid-Atlantic, South Atlantic, Gulf of Mexico, and Inland regions, small_game atl was
set to one. For "small game" fish in the California region, small_game_pac was set to one.
f For "flatfish" in the North Atlantic, Mid-Atlantic, South Atlantic, Gulf of Mexico, Great Lakes, and Inland regions, flatfish atl was
set to one. For flatfish in the California region, flatfish_pac was set to one.
s To indicate that the target species was "panflsh," all species type dummy variables were set to zero.
Source: U.S. EPA (2006)
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 7: Recreational Fishing Benefits
Table 7-3: Marginal Recreational Value per Fish, by Region and Species (2011$)a
Species
California
North
Atlantic
Mid-
Atlantic
South
Atlantic
Gulf of
Mexico
Great
Lakes
Inland
Small game
$7.60
$6.22
$6.17
$5.99
$5.89
$5.61
Flatfish
$10.21
$6.24
$5.88
$5.87
Other saltwater
$3.09
$3.12
$3.05
$2.98
$2.91
Salmon
$13.88
$13.88
Walleye/pike
$4.30
$4.29
Bass
$8.95
$9.43
Panlish
$1.11
$1.39
$14 1
Trout
$9.87
$2.96
Unidentified
$3.25
$3.15
$3.39
$2.99
$3.83
$6.51
$2.33
a Blank cells indicate that recreational value per fish was not estimated because zero IM&E losses are estimated for the
species in that benefits region.
Source: U.S. EPA (2006), converted to 2011$ using the Consumer Price Index (USBLS 2011)
7.2.2 Calculating Recreational Fishing Benefits
EPA estimated the recreational welfare gain from eliminating current IM&E and the recreational
welfare gain from the final rule and other options considered by combining estimates of the
marginal value per fish with the estimated recreational fishing losses under the baseline level of
IM&E, and the reduction in recreational fishing losses attributable to the final rule and other
options considered. To calculate the recreational welfare gain from eliminating baseline IM&E,
EPA multiplied the marginal value per fish by the number of fish that are lost due to baseline
IM&E that would otherwise be caught by recreational anglers. To calculate the recreational
welfare gain from the final rule and other options considered, EPA multiplied the marginal value
per fish by the estimated additional number of fish caught by recreational anglers that would have
been impinged or entrained in the absence of the regulation. As explained in Chapter 3, these
calculations express recreational fish losses as the number of harvestable adults.
7.2.3 Sensitivity Analysis Based on the Krinsky and Robb (1986) Approach
The meta-analysis model briefly described above can be used to predict mean WTP for catching
an additional fish. However, estimates derived from regression models are subject to some degree
of error and uncertainty. To better characterize the uncertainty or error bounds around predicted
WTP, EPA adopted the statistical procedure described by Krinsky and Robb in their 1986 Review
of Economics and Statistics paper, "Approximating the Statistical Property of Elasticities." The
procedure involves sampling from the variance-covariance matrix and means of the estimated
coefficients. WTP values are then calculated for each drawing from the variance covariance
matrix, and constructing an empirical distribution of WTP values. By varying the number of
drawings, it is possible to generate an empirical distribution with a desired degree of accuracy
(Krinsky and Robb 1986). The lower or upper bound of WTP values can then be identified based
on the 5th and 95th percentile of WTP values from the empirical distribution. These bounds may
help decision-makers understand the uncertainty associated with the benefit results.
The results of EPA's calculations are shown in Table 7-4. The table presents 95th percentile upper
confidence bounds and 5th percentile lower confidence bounds for the marginal value per fish for
each species in each region. These bounds can be used to estimate upper and lower confidence
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 7: Recreational Fishing Benefits
bounds for the WTP for improvements in recreational catch rates from eliminating baseline
IM&E or reducing IM&E under the final rule and other options considered. Refer to EPA (2006)
for more detail on the specific calculations. The 5th percentile values shown in Table 7-4 show
that, with the exception of panfish, even the lowest estimates of recreational value are well above
$1.00 per fish. Certainly, all are above zero.
Table 7-4: Confidence Bounds on Marginal Recreational Value per Fish, Based
on the Krinsky and Robb Approach (2011$)a
Species
California
North
Atlantic
Mid-
Atlantic
South
Atlantic
Gulf of
Mexico
Great
Lakes
Inland
5th Percentile Lower Confidence Boundsb
Small game
$4.40
$2.23
$2.37
$2.84
$3.00
$1.68
Flatfish
$5.35
$3.98
$3.92
$4.05
Other saltwater
$1 87
$1 87
$1.94
$2 24
$2.23
Salmon
$8.53
$8.53
Walleve/pike
$2.28
$2.07
I kiss
$4.63
$4.48
Panlish
$0.55
$0.73
$0.55
Trout
$6.39
$1.59
Unidentified
$1.95
$1.88
$2.00
$2.25
$2.47
$3.49
$1.13
95th Percentile Upper Confidence Bounds
Small »ame
$13.01
$17.53
$16.23
$12.59
$1.55
$18.90
Flatfish
$1949
$9 86
$8.92
$8 66
Other saltwater
$5.1 1
$5 20
$4.82
$^ 95
$3.78
Salmon
$22.61
$22.61
Walleve/pike
$8.16
$8.92
I kiss
$17.38
$19.96
Panlish
$2.20
$2.61
$2.20
Trout
$15.34
$5.53
Unidentified
$5.42
$5.26
$6.00
$3.99
$6.18
$12.25
$4.81
a Blank cells indicate that recreational value per fish was not estimated because IM&E losses are not estimated for the
species in that benefits region.
b Upper and lower confidence bounds based on results of the Krinsky and Robb (1986) approach.
Source: U.S. EPA (2006), converted to 20011$ using the Consumer Price Index (USBLS 2011).
7.3 Benefits Estimates for Recreational Fishing by Region
7.3.1 California Region
Table 7-5 presents the estimated increase in recreational fishing harvest and associated welfare
gains from the elimination of baseline IM&E in the California region. EPA estimates an annual
harvest increase of 1.4 million fish from the elimination of baseline IM&E, the majority
attributable to reduced entrainment of rockfish and sea bass. The associated mean annual welfare
gain is $4.0 million and $3.6 million, evaluated at 3 percent and 7 percent discount rates,
respectively. The majority of the monetized recreational benefits from eliminating baseline IM&E
is attributable to entrainment of "other saltwater" fish/5
35 The "other saltwater" species group includes banded drum, black drum, chubby, cod family, cow cod, croaker,
grouper, granion, grunt, high-hat, kingfish, lingcod, other drum, perch, porgy, rockfish, sablefish, sand drum,
sculpin, sea bass, smelt, snapper, spot, spotted drum, star drum, white sea bass, wreckfish, other bottom species,
other coastal pelagics, and "no target" saltwater species.
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 7: Recreational Fishing Benefits
Table 7-5 also presents the annual recreational harvest increases and welfare gains to California
anglers under the final rule and other options considered. EPA estimates that the final rule will
increase annual harvest by 0.04 million fish. The mean annualized welfare gain under final rule
will be less than $0.1 million using both 3 percent and 7 percent discount rates. Annual harvest
increases under other options considered range from 0.04 million fish under Proposal Option 4 to
0.88 million fish under Proposal Option 2. Mean annualized benefits under other options
considered range from less than $0.1 to $1.5 million using a 3 percent discount rate and less than
$0.1 to $1.0 million using a 7 percent discount rate. Appendix I presents additional species-
specific results for final file rule, other options considered, and the elimination of baseline IM&E.
Table 7-5: Recreational Fishing Benefits from Eliminating or Reducing Baseline IM&E
at Regulated Facilities in the California Region, for the Final Rule and Options
Considered (2011$)
Regulatory Option
Annual Increase in
Recreational
Harvest
(harvestable adult
fish)
Annualized Benefits from Increase in Recreational
Harvest
(2011$, l,000s)a
3 % Discount Rate
7 % Discount Rate
5th
Mean
95th
5th
Mean
95th
Proposal Option 4
35.420
$42
$69
$114
$30
$50
$83
Final Rule
38.159
$45
$74
$123
$33
$54
$89
Proposal Option 2
877.174
$919
$1,543
$2,595
$592
$994
$1,673
Baseline
1.43 I.I 70
$2,408
$4,044
$6,803
$2,153
$3,616
$6,084
a 5th and 95th are the 5th and 95th percentiles based on the results of the Krinsky and Robb (1986) approach.
Source: U.S. EPA analysis for this report
7.3.2 North Atlantic Region
Table 7-6 presents the estimated increase in recreational fishing harvest and associated welfare
gains from the elimination of baseline IM&E in the North Atlantic region. EPA estimates an
annual harvest increase of 0.73 million fish from the elimination of baseline IM&E, the majority
attributable to reduced entrainment of winter flounder, cunner, and sculpin. The associated mean
annual welfare gain is $2.7 million and $2.4 million, evaluated at 3 percent and 7 percent
discount rates, respectively. The majority of the monetized recreational benefits from eliminating
baseline IM&E is attributable to entrainment of "flatfish" and "other saltwater" fish/6
Table 7-6 also presents the annual recreational harvest increases and welfare gains to North
Atlantic anglers under the final rule and other options considered. EPA estimates that the final
rule will increase annual harvest by less than 0.01 million. The mean annualized welfare gain
under final rule will be less than $0.1 million using both 3 percent and 7 percent discount rates.
Annual harvest increases under other options considered range from less than 0.01 million fish
under Proposal Option 4 to 0.56 million fish under Proposal Option 2. Mean annualized benefits
under other options considered range from less than $0.1 to $1.4 million using a 3 percent
discount rate and from less than $0.1 to $0.9 million using a 7 percent discount rate. Appendix I
30 The "other saltwater" species group includes banded drum, black drum, chubby, cod family, cow cod, croaker,
grouper, granion, grunt, high-hat, kingfish, lingcod, other drum, perch, porgy, rockfish, sablefish, sand drum,
sculpin, sea bass, smelt, snapper, spot, spotted drum, star drum, white sea bass, wreckfish, other bottom species,
other coastal pelagics, and "no target" saltwater species.
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 7: Recreational Fishing Benefits
presents additional species-specific results for final file rule, other options considered, and the
elimination of baseline IM&E.
Table 7-6: Recreational Fishing Benefits from Eliminating or Reducing Baseline IM&E
at Regulated Facilities in the North Atlantic Region, for the Final Rule and Options
Considered (2011$)
Annual Increase in
Annualized Benefits from Increase in Recreational
Recreational
Harvest
Regulatory Option
Harvest
(2011$, l,000s)a
(harvestable adult
fish)
3 % Discount Rate
7 % Discount Rate
5th
Mean
95th
5th
Mean
95th
Proposal Option 4
1,367
$3
$4
$7
$2
$3
$5
Filial Rule
7,975
$14
$23
$36
$10
$16
$27
Proposal Option 2
562,305
$852
$1,371
$2,219
$573
$921
$1,491
Baseline
733,985
$1,682
$2,705
$4,380
$1,504
$2,419
$3,917
a 5th and 95th are the 5th and 95th percentiles based on the results of the Krinsky and Robb (1986) approach.
Source: U.S. EPA analysis for this report
7.3.3 Mid-Atlantic Region
Table 7-7 presents the estimated increase in recreational fishing harvest and associated welfare
gains from the elimination of baseline IM&E in the Mid-Atlantic region. EPA estimates an
annual harvest increase of 5.82 million fish from the elimination of baseline IM&E, the majority
attributable to reduced IM&E of spot and Atlantic croaker. The associated mean annual welfare
gain is $16.2 million and $14.5 million, evaluated at 3 percent and 7 percent discount rates,
respectively. The majority of the monetized recreational benefits from eliminating baseline IM&E
is attributable to the entrainment of "other saltwater" fish.
Table 7-7 also presents the annual recreational harvest increases and welfare gains to Mid-
Atlantic anglers under the final rule and other options considered. EPA estimates that the final
rule will increase annual harvest by 0.46 million fish. The mean annualized welfare gain under
final rule will be $1.1 million using a 3 percent rate and $0.8 million using a 7 percent discount
rate. Annual harvest increases under other options considered range from 0.43 million fish under
Proposal Option 4 to 5.10 million fish under Proposal Option 2. Mean annualized benefits under
other options considered range from $1.0 to $8.6 million using a 3 percent discount rate and from
$0.7 to $5.5 million using a 7 percent discount rate. Appendix I presents additional species-
specific results for final file rule, other options considered, and the elimination of baseline IM&E.
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 7: Recreational Fishing Benefits
Table 7-7: Recreational Fishing Benefits from Eliminating or Reducing Baseline IM&E
at Regulated Facilities in the Mid-Atlantic Region, for the Final Rule and Options
Considered (2011$)
Regulatory Option
Annual Increase in
Recreational
Harvest
(harvestable adult
fish)
Annualized Benefits from Increase in Recreational
Harvest
(201 IS, l,000s):l
3 % Discount Rate
7 % Discount Rate
5th
Mean
95'"
5"'
Mean
95'"
Proposal Option 4
427,924
$531
$988
$1,961
$376
$700
$1,389
Filial Rule
460,839
$572
$1,063
$2,108
$405
$753
$1,493
Proposal Option 2
5,103,595
$5,132
$8,634
$15,072
$3,273
$5,506
$9,612
Baseline
5,823,189
$9,665
$16,249
$28,341
$8,643
$14,531
$25,343
a 5th and 95th are the 5th and 95th percentiles based on the results of the Krinsky and Robb (1986) approach.
Source: U.S. EPA analysis for this report
7.3.4 South Atlantic Region
Table 7-8 presents the estimated increase in recreational fishing harvest and associated welfare
gains from the elimination of baseline IM&E in the South Atlantic region. EPA estimates an
annual harvest increase of 0.11 million fish from the elimination of baseline IM&E, the majority
attributable to reduced IM&E of "other saltwater" fish, especially spot and croakers. The
associated mean annual welfare gain is $0.3 million evaluated at both 3 percent and 7 percent
discount rates. The majority of the monetized recreational benefits from eliminating baseline
IM&E is attributable to entrainment of "other saltwater" fish.
Table 7-8 also presents the annual recreational harvest increases and welfare gains to South
Atlantic anglers under the final rule and other options considered. EPA estimates that the final
rule will increase annual harvest by 0.02 million fish. The mean annualized welfare gain under
final rule will be less than $0.1 million using both 3 percent and 7 percent discount rates. Annual
harvest increases under other options considered range from 0.01 million fish under Proposal
Option 4 to 0.10 million fish under Proposal Option 2. Mean annualized benefits under other
options considered range from less than $0.1 to $0.2 million using a 3 percent discount rate and
from less than $0.1 to $0.1 million using a 7 percent discount rate. Appendix I presents additional
species-specific results for final file rule, other options considered, and the elimination of baseline
IM&E.
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 7: Recreational Fishing Benefits
Table 7-8: Recreational Fishing Benefits from Eliminating or Reducing Baseline IM&E
at Regulated Facilities in the South Atlantic Region, for the Final Rule and Options
Considered (2011$)
Regulatory Option
Annual Increase in
Recreational
Harvest
(harvestable adult
fish)
Annualized Benefits from Increase in Recreational
Harvest
(201 IS, l,000s):l
3 % Discount Rate
7 % Discount Rate
5th
Mean
95'"
5"'
Mean
95'"
Proposal Option 4
12,983
$18
$24
$33
$13
$17
$23
Filial Rule
18,725
$26
$35
$47
$18
$24
$33
Proposal Option 2
104,943
$129
$173
$234
$86
$115
$156
Baseline
111,075
$211
$284
$385
$189
$254
$344
a 5th and 95th are the 5th and 95th percentiles based on the results of the Krinsky and Robb (1986) approach.
Source: U.S. EPA analysis for this report
7.3.5 Gulf of Mexico Region
Table 7-9 presents the estimated increase in recreational fishing harvest and associated welfare
gains from the elimination of baseline IM&E in the Gulf of Mexico region. EPA estimates an
annual harvest increase of 3.08 million fish from the elimination of baseline IM&E, the majority
attributable the impingement of spotted seatrout and the entrainment of black drum and pinfish.
The associated mean annual welfare gain is $9.6 million and $8.8 million, evaluated at 3 percent
and 7 percent discount rates, respectively. The majority of the monetized recreational benefits
from eliminating baseline IM&E is attributable to both the impingement of "small game" fish and
the entrainment of "other saltwater" species.
Table 7-9 also presents the annual recreational harvest increases and welfare gains to Gulf of
Mexico anglers under the final rule and other options considered. EPA estimates that the final
rule will increase annual harvest by 0.78 million fish. The mean annualized welfare gain under
final rule will be $2.3 million using a 3 percent discount rate and $1.6 million using a 7 percent
discount rate. Annual harvest increases under other options considered range from 0.75 million
fish under Proposal Option 4 to 2.14 million fish under Proposal Option 2. Mean annualized
benefits under other options considered range from $2.2 to $5.1 million using a 3 percent
discount rate and from $1.6 to $3.8 million using a 7 percent discount rate. Appendix I presents
additional species-specific results for final file rule, other options considered, and the elimination
of baseline IM&E.
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 7: Recreational Fishing Benefits
Table 7-9: Recreational Fishing Benefits from Eliminating or Reducing Baseline IM&E
at Regulated Facilities in the Gulf of Mexico Region, for the Final Rule and Options
Considered (2011$)
Regulatory Option
Annual Increase in
Recreational
Harvest
(harvestable adult
fish)
Annualized Benefits from Increase in Recreational
Harvest
(201 IS, l,000s):l
3 % Discount Rate
7 % Discount Rate
5th
Mean
95'"
5"'
Mean
95'"
Proposal Option 4
749,144
$1,260
$2,183
$3,904
$914
$1,583
$2,831
Filial Rule
777,488
$1,308
$2,265
$4,051
$948
$1,643
$2,938
Proposal Option 2
2,137,861
$3,357
$5,116
$8,122
$2,476
$3,774
$5,991
Baseline
3,077,617
$6,457
$9,575
$14,756
$5,955
$8,831
$13,610
a 5th and 95th are the 5th and 95th percentiles based on the results of the Krinsky and Robb (1986) approach.
Source: U.S. EPA analysis for this report
7.3.6 Great Lakes Region
Table 7-10 presents the estimated increase in recreational fishing harvest and associated welfare
gains from the elimination of baseline IM&E in the Great Lakes region. EPA estimates an annual
harvest increase of 2.23 million fish from the elimination of baseline IM&E, the majority
attributable to IM&E of white bass and "unidentified" species. The associated mean annual
welfare gain is $13.8 million and $12.8 million, evaluated at 3 percent and 7 percent discount
rates, respectively. The majority of the monetized recreational benefits from eliminating baseline
IM&E is attributable to the impingement of bass and "unidentified" fish.
Table 7-10 also presents the annual recreational harvest increases and welfare gains to Great
Lakes anglers under the final rule and other options considered. EPA estimates that the final rule
will increase annual harvest by 1.47 million fish. The mean annualized welfare gain under final
rule will be $7.2 million using a 3 percent discount rate and $5.3 million using a 7 percent
discount rate. Annual harvest increases under other options considered range from 1.33 million
fish under Proposal Option 4 to 2.04 million fish under Proposal Option 2. Mean annualized
benefits under other options considered range from $6.5 to $8.9 million using a 3 percent
discount rate and from $4.8 to $6.4 million using a 7 percent discount rate. Appendix I presents
additional species-specific results for final file rule, other options considered, and the elimination
of baseline IM&E.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 7: Recreational Fishing Benefits
Table 7-10: Recreational Fishing Benefits from Eliminating or Reducing Baseline
IM&E at Regulated Facilities in the Great Lakes Region, for the Final Rule and
Options Considered (2011$)
Regulatory Option
Annual Increase in
Recreational
Harvest
(harvestable adult
fish)
Annualized Benefits from Increase in Recreational
Harvest
(201 IS, l,000s):l
3 % Discount Rate
7 % Discount Rate
5th
Mean
95'"
5"'
Mean
95'"
Proposal Option 4
1,331,956
$3,446
$6,509
$12,385
$2,562
$4,839
$9,208
Filial Rule
1,466,650
$3,793
$7,166
$13,636
$2,820
$5,328
$10,138
Proposal Option 2
2,044,018
$4,717
$8,922
$16,993
$3,359
$6,354
$12,102
Baseline
2,232,409
$7,306
$13,825
$26,338
$6,738
$12,751
$24,292
a 5th and 95th are the 5th and 95th percentiles based on the results of the Krinsky and Robb (1986) approach.
Source: U.S. EPA analysis for this report
7.3.7 Inland Region
Table 7-11 presents the estimated increase in recreational fishing harvest and associated welfare
gains from the elimination of baseline IM&E in the Inland region. EPA estimates an annual
harvest increase of 11.90 million fish from the elimination of baseline IM&E, the majority
attributable to IM&E of "bass," ""panfish." and "unidentified" species groups. The associated
mean annual welfare gain is $32.1 million and $29.6 million, evaluated at 3 percent and 7 percent
discount rates, respectively. The majority of the monetized recreational benefits from eliminating
baseline IM&E is attributable to IM&E of "bass," "panfish," and "unidentified" fish.
Table 7-11 also presents the annual recreational harvest increases and welfare gains to Inland
anglers under the final rule and other options considered. EPA estimates the final rule will
increase annual harvest by 3.73 million fish. The mean annualized welfare gain under the final
rule will be $7.6 million using a 3 percent discount rate and $5.7 million using a 7 percent
discount rate. Annual harvest increases under other options considered range from 3.57 million
fish under Proposal Option 4 to 9.70 million fish under Proposal Option 2. Mean annualized
benefits under other options considered range from $7.3 to $17.2 million using a 3 percent
discount rate and $5.4 to $11.9 million using a 7 percent discount rate. Appendix I presents
additional species-specific results for final file rule, other options considered, and the elimination
of baseline IM&E.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 7: Recreational Fishing Benefits
Table 7-11: Recreational Fishing Benefits from Eliminating or Reducing Baseline IM&E
at Regulated Facilities in the Inland Region, for the Final Rule and Options Considered
(2011$)
Regulatory Option
Annual Increase in
Recreational Harvest
(harvestable adult
fish)
Annualized Benefits from Increase in Recreational Harvest
(2011$, l,000s)a
3 % Discount Rate
7 % Discount Rate
5"'
Mean
95'"
5"'
Mean
95th
Proposal Option 4
3,570,053
$3,503
$7,284
$15,231
$2,616
$5,440
$11,375
Filial Rule
3,731,608
$3,661
$7,613
$15,918
$2,735
$5,686
$11,889
Proposal Option 2
9,704,334
$8,290
$17,204
$35,865
$5,726
$11,883
$24,773
Baseline
11,900,351
$15,471
$32,105
$66,919
$14,270
$29,611
$61,722
a 5th and 95th are the 5th and 95th percentiles based on the results of the Krinsky and Robb (1986) approach.
Source: U.S. EPA analysis for this report
7.3.8 National Estimates
Table 7-12 presents the estimated national increase in recreational fishing harvest and associated
welfare gains to anglers from eliminating baseline IM&E. EPA estimates an annual harvest
increase of 25.31 million fish from eliminating baseline IM&E. The associated mean annual
welfare gain is $78.8 million and $72.0 million, evaluated at 3 percent and 7 percent discount
rates, respectively.
Table 7-12 also presents the national recreational harvest increases and welfare gains to anglers
under the final rule and other options considered. EPA estimates the final rule will increase
annual harvest by 6.50 million fish. The mean annualized welfare gain under final rule will be
$18.2 million using a 3 percent discount rate and $13.5 million using a 7 percent discount rate.
Annual harvest increases under other options considered range from 6.13 million fish under
Proposal Option 4 to 20.53 million fish under Proposal Option 2. Mean annualized benefits under
other options considered range from $17.1 to $43.0 million using a 3 percent discount rate and
$12.6 to $29.5 million using a 7 percent discount rate. Appendix I presents additional species-
specific results for the final rule, other options considered, and the elimination of baseline IM&E.
Table 7-12: National Recreational Fishing Benefits from Eliminating or Reducing
Baseline IM&E at Regulated Facilities, for the Final Rule and Options Considered (2011$)
Regulatory Option
Annual Increase in
Recreational Harvest
(harvestable adult
fish)
Annualized Benefits from Increase in Recreational Harvest
(2011$, l,000s)a
3 % Discount Rate
7 % Discount Rate
5th
Mean
95th
5"'
Mean
95th
Proposal Option 4
6,128,847
$8,803
$17,061
$33,635
$6,513
$12,632
$24,914
Final Rule
6.501.444
$9,419
$18,239
$35,919
$6,969
$13,504
$26,607
Proposal Option 2
20.534.230
$23,396
$42,963
$81,100
$16,085
$29,547
$55,798
Baseline
25.309.796
$43,200
$78,787
$147,922
$39,452
$72,013
$135,312
a 5th and 95th are the 5th and 95th percentiles based on the results of the Krinsky and Robb (1986) approach.
Source: U.S. EPA analysis for this report
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 7: Recreational Fishing Benefits
7.4 Limitations and Uncertainties
A number of limitations and uncertainties are common in application of benefit transfer
approaches to valuing benefits of environmental policies and programs. To better characterize the
uncertainty or error bounds around predicted WTP, EPA adopted the statistical procedure
described by Krinsky and Robb in their 1986 Review of Economics and Statistics paper
"Approximating the Statistical Property of Elasticities," to generate lower and upper bound WTP
values identified as the 5th and 95th percentile of values from the empirical distribution.
Additional detail regarding the Krinsky and Robb approach is provided in Section 7.2.3. These
bounds may help decision-makers understand the uncertainty associated with the benefit results
for eliminating baseline IM&E and the 316(b) final rule and regulatory options considered.
Specific limitations and uncertainties associated with the estimated regression model and the
underlying studies are discussed in Section A5-3.3e of EPA (2006). Additional limitations and
uncertainties associated with the calculation of per-fish values from the model, and with the use
of those values to estimate the welfare gain resulting from the final section 316(b) regulation and
regulatory options considered, are addressed below in Table 7-13.
Table 7-13: Other Caveats, Omissions, Biases, and Uncertainties in the Recreational
Benefits Estimates
Issue
Impact on
Benefits
Estimate
Comments
Exclusion of error term
from regression
equation to predict
marginal values
Estimates
understated
Because the source of error in the underlying meta-data is unknown EPA
decided not to include the error term in estimating marginal values per
fish. EPA notes that if the source of error is due primarily to the omitted
variables the estimated WTP may be biased downward. See Section 7.2.1
for more a detailed discussion regarding EPA's treatment of the error
term.
Validity and reliability
of benefit transfer
Uncertain
Hie validity and reliability of benefit transfer—including that based on
meta-analysis—depend on a variety of factors. While benefit transfer can
provide valid measures of use benefits, tests of its performance have had
mixed results (e.g. Desvousges et al. 1998; Smith et al. 2002; Vandenberg
et al. 2001). Nonetheless, benefit transfers are increasingly applied as a
core component of benefit-cost analyses conducted by EPA and other
government agencies (Bergstrom and De Civita 1999; Griffiths undated).
Smith et al. (2002, p. 134) state that "nearly all benefit cost analyses rely
on benefit transfers, whether they acknowledge it or not." An important
factor in any benefit transfer is the ability of the study site or estimated
valuation equation to approximate the resource and context for which
benefit estimates are desired. As is common, the meta-analysis model
presented here provides a close but not perfect match to the context in
which values are desired.
IM&E estimates
Uncertain
Recreational losses due to IM&E may be higher or lower than expected
for a number of reasons. Projected changes in recreational catch may be
underestimated because cumulative impacts of IM&E over time are not
considered. In particular, IM&E estimates include only individuals
directly lost to IM&E, not their progeny. Additionally, the interaction of
IM&E with other stressors may have either a positive or negative effect
on recreational catch. Finally, in estimating recreational fishing losses,
EPA used the most current IM&E data available provided by facilities,
which in some cases may not reflect current conditions.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 8: Nonuse Benefit Transfer Approach
8 Nonuse Benefit Transfer Approach
8.1 Introduction
Comprehensive estimates of total social value include both use and nonuse values, and may be compared
to total social cost. "Non-use values, like use values, have their basis in the theory of individual
preferences and the measurement of welfare changes. According to theory, use values and non-use values
are additive" (Freeman III 1993). Consequently, excluding nonuse values from consideration is likely to
substantially understate total social values. Recent economic literature provides strong support for the
hypothesis that nonuse values are greater than zero for many types of environmental improvements.
Moreover, when a substantial fraction of the population holds even small per capita nonuse values, these
nonuse values can be very large in the aggregate. As stated by Freeman (1993), "there is a real possibility
that ignoring non-use values could result in serious misallocation of resources." Both EPA's own
Guidelines for Preparing Economic Analysis and OMB's Circular A-4, governing regulatory analysis,
support the need to assess nonuse values (USEPA 2010a; USOMB 2003).
The vast majority (97 percent) of current (i.e., baseline) IM&E at CWIS consist of forage species and
unlanded individuals of recreational and commercial species (Chapter 3). Although these forage and
unlanded fish do not have direct use values, they may be valued by nonusers of fisheries resources (whose
value for such fish is by definition a nonuse value) and by users separate from their use value. The nonuse
values are likely to be substantial because fish and other species found within aquatic habitats impacted
directly and indirectly by CWIS provide other valuable ecosystem goods and services, including nutrient
cycling and ecosystem stability. Therefore, a comprehensive estimate of the welfare gain from reducing
IM&E must include an estimate of nonuse benefits. The following sections present EPA's qualitative
assessment of nonuse benefits and partial monetized nonuse benefits based on benefit transfer from an
existing stated preference study. EPA evaluated the public's nonuse values for aquatic habitats
qualitatively by considering evidence from existing aquatic restoration and protection programs (Section
8.2). EPA also provides a quantitative estimate of the numbers of A1E whose benefits are likely to be
mainly associated with nonuse (Table 3-15; reproduced as Table 8-1). Finally, EPA used benefit transfer
to generate a partially monetized estimate of nonuse benefits associated with reductions in IM&E of fish,
shellfish, and other aquatic organisms under the final rule and other options considered in the North
Atlantic and Mid-Atlantic Regions. The methodology is described in Section 8.3 and Section 8.4 presents
the results.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 8: Nonuse Benefit Transfer Approach
Table 8-1: Baseline IM&E and IM&E Reductions at All Regulated Facilities
(Manufacturing and Generating) Nationally, and Reductions under the Final Rule
and Other Options Considered
Reductions in Losses
Baseline
Losses
IM&E Loss Metric (per year)
Proposal
Option 4
Final
Rule
Proposal
Option 2
All Species (million AI F)
614.16
652.00
1637.49
1930.97
Forage Species (million AI F)
528.22
560.80
1258.67
1459.70
Commercial & Recreational Species (million AI F)
85.94
91.20
378.82
471.28
Commercial & Recreational Harvest (million fish)
16.13
17.11
44.66
54.02
A1E Losses with Direct Use Value (%)
2.6%
2.6%
2.7%
2.8%
Source: U.S. EPA analysis for this report
8.2 Public Policy Significance of Ecological Improvements from the Final Rule
EPA expects that changes to CWIS design and operation resulting from the final existing facilities rule
will reduce IM&E of fish, shellfish, and other aquatic organisms and lead to increases in local and
regional fishery populations and ecosystem stability. In addition to those direct effects, many indirect
ecosystem goods and services are affected by IM&E, thermal effects, and flow alteration. Due to the
wide-ranging nature of these indirect effects, the existing facilities rule is likely to enhance the value of
ecosystem goods and services provided by aquatic habitats, and will help reduce the overall impact of
anthropogenic effects on aquatic systems affected by CWIS. Chapter 2 provides a detailed list of
ecosystem services potentially affected by the rule.
EPA assessed the potential magnitude of nonuse benefits using information regarding government
spending on the protection, restoration, and regulation of various aquatic habitats. These habitats include
Marine Protected Areas (Section 8.2.2) and a subset of freshwater ecosystems undergoing large-scale
restoration efforts (Section 8.2.3). Although not estimates of benefits of improving aquatic ecosystems,
these expenditures are still an indication of significant social values for the protection of aquatic
resources.
8.2.1 Effects on Depleted Fish Populations
Reducing IM&E will contribute to the health and sustainability of the affected fish populations by
lowering the overall level of mortality for these populations. Fish populations suffer from numerous
sources of mortality, both natural and anthropogenic. Natural sources include weather, predation by other
fish, and the availability of food. Human activities besides IM&E include fishing, pollution, and habitat
alteration. Fish populations decline when they are unable to compensate sufficiently for their overall level
of mortality. Although it is difficult to measure, the compensatory ability of an aquatic population—the
capacity for a species to increase survival, growth, or reproduction rates in response to decreased
population —is likely compromised by IM&E and the cumulative impact of other stressors in the
environment over extended periods of time (USEPA 2006a).
Lowering the overall mortality level increases the probability that a population will be able to
compensate for mortality at a level sufficient to maintain long-term health. In some cases, impingement
and entrainment may be significant source of mortality to already-depleted stocks of commercially
targeted species (see Chapter 2). Depleted saltwater fish stocks affected by IM&E include winter
flounder, Atlantic Cod, and rockfish, for example (NMFS 2012). As discussed in Chapter 2, IM&E also
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 8: Nonuse Benefit Transfer Approach
increases the pressure on freshwater species native to the Great Lakes, such as lake whitefish and yellow
perch, the populations of which have declined dramatically in recent years (USDOI2008; Wisconsin
DNR2003).
The federal government and the states have recognized the public importance of maintaining sustainable
fisheries, achieving recovery of depleted fish stocks, and ensuring that functioning ecosystems are passed
to future generations. Federal and state government actions have included buying fishing licenses and
fishing vessels from individual fishers when stocks appear depressed, imposing restrictions on
commercial and recreational harvests, conducting large-scale ecosystem restoration projects (USDOI
2008), and President George W. Bush's executive order creating a national system of marine protected
areas (Executive Order No. 13158 2001).Together, these governmental actions suggest that the public
holds substantial nonuse values for aquatic habitats.
8.2.2 Marine Protected Areas
A Marine Protected Area (MPA) is "any area of the marine environment that has been reserved by
federal, state, tribal, territorial, or local laws or regulations to provide lasting protection for part or all of
the natural and cultural resources therein" (Executive Order No. 13158 2001). In some states, the majority
of coastal waters are found within MPAs (e.g., Massachusetts, Hawaii). The ecological importance of
MPAs varies widely because of the broad focus on the preservation and maintenance of cultural and
natural resources, and/or sustainable production (NMPAC 2006). Consequently, evaluating the impact of
CWIS on the entire universe of MPAs may overstate the nonuse values for the ecological benefits
associated with reductions in IM&E: because some MPAs are focused on the preservation of cultural
resources (including historic shipwrecks, aircraft and other structures, submerged prehistoric remains, and
sites with traditional cultural properties), they are likely to be less ecologically important than others.
For this reason, EPA focused on facilities in MPAs within the National Estuary Program (NEP). The NEP
was established in the 1987 amendments to the CWA because the "Nation's estuaries are of great
importance to fish and wildlife resources and recreation and economic opportunity [and because
maintaining] the health and ecological integrity of these estuaries is in the national interest" (Water
Quality Act 1987). In addition to the 28 estuaries designated under the NEP (USEPA 2010b), EPA
included facilities found in Chesapeake Bay (which is protected by the Chesapeake Bay Program [CBP]).
Substantial federal and state resources have been directed to the NEP and CBP to enhance conservation of
and knowledge about estuaries. Including funds received from federal, state, local and private sources,
from 2005 to 2013, the NEP spent $3.5 billion to protect and restore aquatic habitat, support land
acquisitions, conduct outreach and research, upgrade wastewater and stormwater infrastructure, and
implement other priority actions to benefit the health of the 28 estuaries designated under the NEP.
Approximately 11.1 percent, or $389 million, was designated for restoration programs (USEPA 2014).
Between fiscal years 1995 and 2004, direct funding by federal and State governments to restore the
Chesapeake Bay averaged $366 million annually (GAO 2005), with an additional $131 million in direct
spending fiscal year 2005 (CBP 2007).. Moreover, recent governmental action is likely to increase
restoration efforts in the future (Executive Order No. 13508 2009), These expenditures reflect high public
values for restoring (or protecting) the biological integrity of these ecosystems.
A total of 44 regulated facilities are located on 32 waterbodies within MPAs designed to preserve natural
resources and/or to ensure sustainable production (NOAA 2012) (Figure 8-1; Table 8-2). Although these
facilities are located in fresh, brackish, and marine waters, the vast majority located within MPAs are in
coastal waters and are most highly concentrated in the Northeastern U.S. (i.e. both coastal and inland
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 8: Nonuse Benefit Transfer Approach
facilities) (Figure 8-1; Table 8-2). Under the final rule, EPA estimates that 60 percent of regulated
facilities (15 out of 25 facilities for which data are available) found within MPAs obtain reductions in
impingement mortality. This estimate is based upon facilities for which sufficient data exist for EPA to
estimate technology currently in-place. Additionally, although entrainment may be reduced at some
facilities as a consequence of the final rule, EPA was not able to estimate reductions in entrainment likely
to occur due to site-specific determination of entrainment BTA for facilities with CWIS inside of MPAs.
te
Facilities with CWIS
O Coastal
~ Inland
Regions
California Region
Y/// - Great Lakes Region
/\ Gulf of Mexico Region
Inland Region
RKP3 Mid-Atlantic Region
J North Atlantic Region
j\] South Atlantic Region
Figure 8-1: Regulated Facilities with CWIS Located in Marine Protected Areas
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 8: Nonuse Benefit Transfer Approach
Table 8-2: 316(b) Facilities in Marine Protected Areas and Improvements in IM&E Tech for
the Final Rule and Other Options Considered
Number of Facilities with Improved
Technologies by Optiona'b
Baseline
Region
Proposal
Option 4
Final Rule
Proposal
Option 2
IM
E
IM
E
IM
E
Number of
Facilities
Affected
Waterbodies
Facilities With
Tech Datab
California
1
0
1
0
1
1
2
2
1
North Atlantic
2
0
2
0
2
2
7
6
6
Mid-Atlantic
8
0
8
0
8
6
24
15
12
South Atlantic
0
0
0
0
0
0
2
1
1
liulf of Mexico
2
0
2
0
3
3
3
3
Great Lakes
0
0
0
0
0
0
0
0
0
Inland
2
0
2
0
2
2
6
5
2
Total
15
0
15
0
16
14
44
32
25
a IM is impingement mortality and E is entrainment.
b EPA does not have adequate data for all facilities to estimate current compliance with, or the number of facilities installing improved
technologies because of the final rule.
Source: U.S. EPA analysis for this report
8.2.3 Restoration of Freshwater Ecosystems
Reducing the effect of CWIS at regulated facilities is likely to benefit aquatic ecosystems nationwide.
Due to a high density of facilities, and the potential for cumulative impacts associated with facilities in
close proximity to each other (see Chapter 2 for additional details), the greatest improvements may occur
in areas of the Great Lakes Basin and Mississippi River. There are large-scale ecosystem restoration
efforts for these freshwater bodies that indicate public support for restoring the ecological health of these
ecosystems (Northeast Midwest Institute 2010; USDOI2008; USFWS 2011; Upper Mississippi River
Basin Association 2004).
Nationally, ecosystem restoration efforts focus on many issues, including coastal habitat restoration,
protection of fish species, and conservation of migratory birds. For example, the federal government
provided in excess of $1.7 billion for sport fish restoration between fiscal years 2005 and 2009 (USFWS
2010c), and has initiated a 5-year multi-agency initiative to restore the ecosystems of the Great Lakes, for
which $1.05 billion of federal funds were appropriated in fiscal years 2010 through 2012 (Great Lakes
Restoration Initiative 2012). Additionally, the restoration of major inland river ecosystems has been
recognized as a worthwhile goal, with more than $100 million spent on restoring ecosystems along the
Mississippi River (Brescia 2002; USEPA 2004b).
Overall, the federal government spent more than $600 million on major restoration projects in aquatic
ecosystems in FY2012 (Behrens 2012; USACE 2013). These projects include, but are not limited to, the
construction of fish ladders, restoration of wetland nursery habitat, and the reduction of pollution. These
expenditures indicate a high value placed on the maintenance and restoration of ecosystem function and
the integrity of freshwater ecosystems.
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Chapter 8: Nonuse Benefit Transfer Approach
8.2.4 Summary of Evidence for Nonuse Values of Ecosystems Affected by CWIS
Overall, the public appears to hold substantial nonuse values for ecosystems and species impacted by
CWIS. For example, governments at various levels have committed to the designation of MPAs covering
large areas. Governments also have committed substantial resources to the restoration of degraded aquatic
ecosystems.
EPA notes that funding amounts for the protection and restoration of aquatic ecosystems is not an
appropriate measure of benefits (i.e., willingness to pay (WTP)). As described by Brown (1993)
"economic efficiency involves a balance between demand and supply, whereas restoration cost has
nothing to do with demand or value" (p.88). Moreover, these costs do not necessarily reflect a cost-
effective allocation of resources (Kopp and Smith 1993). High costs of restoration or protection may
overstate benefits, and likewise, while low costs may under-state benefits.
Although not estimates of benefits of improving aquatic ecosystems, these expenditures are still an
indication of significant social values for the protection and resource of aquatic resources affected under
the final rule and options considered. Chapter 2 provides additional qualitative discussion of adverse
environmental impacts from regulated facilities for which society is like to hold significant nonuse values.
8.3 Benefit Transfer for Nonuse Values in the North Atlantic and Mid-Atlantic
Regions
Stated preference (SP) methods and benefit transfers based on SP studies are the generally accepted
techniques for estimating total social values (including use and nonuse) values. SP methods rely on
surveys that ask people to state their WTP for particular ecological improvements, such as increased
protection of aquatic species or habitats with particular attributes. EPA searched the literature for SP
studies that estimated WTP for ecological improvements similar to those impacted by CWIS of regulated
facilities. EPA identified a SP survey of Rhode Island residents that is a relatively good match to the
316(b) policy context and used this study to develop a benefit transfer approach to estimate nonuse
benefits associated with reduction in IM&E under the final rule and other options considered. EPA was
only able to use this approach for the North Atlantic and Mid-Atlantic regions.
The study developed a Bioindicator-Based Stated Preference Valuation (BSPV) method specifically for
applications to ecological systems/7 and used it to address Rhode Island residents" preferences for the
restoration of migratory fish passage over dams in a watershed within Rhode Island (Johnston et al.
2012). The study results have been published in multiple scientific journals and books including Johnston
et al. (2012), Johnston et al. (201 la), Johnston et al. (201 lb), and Zhao et al. (2013). EPA applied a model
presented by Zhao et al. (2013).
Similar to the 316(b) regulatory context, the study addressed policy changes affecting individuals of
forage species but for which ultimate population effects are unknown. The authors estimated total values
by asking respondents to consider changes in ecological indicators reflecting quantity of habitat,
abundance of wildlife, ecological condition, and abundance of migratory fish species. The study's choice
experiment allows direct estimation of households" WTP for policies that increase the number of fish in
watersheds. The benefits transfer involves a translation from reintroducing fish to aquatic habitats to
reducing IM&E. Within the benefit transfer application, EPA is able to focus on nonuse values by holding
constant all effects related to identifiable human uses.
37 The stated preference survey was funded by the EPA's Science to Achieve Results (STAR) competitive grant program.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 8: Nonuse Benefit Transfer Approach
Section 8.3.1 describes the transfer study and BSPV methods in greater detail. This is followed by a
description of EPA's benefit transfer methods (Section 8.3.2) and estimated benefits for the 316(b) final
rule and other options considered in Section 8.4. EPA also developed an original SP survey to assess
public values for reductions in IM&E and ecosystem improvements under the final rule. The 316(b) SP
survey is discussed separately in Chapter 11. However, EPA notes that it would be inappropriate to add
the benefits from the benefits transfer approach to benefits based on the SP survey, as this would result in
double-counting of benefits.
8.3.1 Description of the Benefit Transfer Study and BSPV Methods
As described by Johnston et al. (2012), the Rhode Island study developed the BSPV method to promote
ecological clarity, and closer integration of ecological and economic information within SP studies. The
study focus on improved ecological valuation is an EPA priority as described in findings of EPA's
Science Advisory Board's Committee on Valuing the Protection of Ecological System and Services
(USEPA 2009b). In contrast to traditional SP valuation, BSPV employs a more structured and formal use
of ecological indicators to characterize and communicate welfare-relevant changes. The method begins
with a formal basis in ecological science, and extends to relationships between attributes in respondents'
preference functions and those used to characterize policy outcomes.
Specific BSPV guidelines ensure that survey scenarios and resulting welfare estimates are characterized
by (1) a formal basis in established and measurable ecological indicators, (2) a clear structure linking
these indicators to attributes influencing individuals' well-being, (3) consistent and meaningful
interpretation of ecological information, and (4) a consequent ability to link welfare measures to
measurable and unambiguous policy outcomes. The welfare measures provided by the BSPV method can
be linked unambiguously to models and indicators of ecosystem function, are based on measurable
ecological outcomes, and are more easily incorporated into benefit-cost analysis than traditional SP
valuation studies. The BSPV method also provides a means to estimate values for ecological outcomes
that individuals might value, even though they may not fully understand all relevant ecological science.
The study developed the BSPV methods for a case study addressing public preferences for the restoration
of migratory fish passage in the Pawtuxet Watershed. The BSPV survey (Rhode Island River: Migratory
Fishes and Dams) was designed to estimate WTP of Rhode Island residents for options that would
provide fish passage over dams, and access to between 225 and 900 acres of historical habitat within the
Pawtuxet Watershed for which there is currently no fish passage (Johnston et al. 201 la; Johnston et al.
201 lb; Johnston et al. 2012; Zhao et al. 2013). The watershed currently provides no spawning habitat for
migratory fish; access to all 4,347 acres of potential habitat is blocked by 22 dams and other obstructions
(Erkan 2002).
The survey was developed and tested over 2Vi years through a collaborative process involving
interactions of economists and ecologists; meetings with resource managers, natural scientists, and
stakeholder groups. This included 12 focus groups with 105 total participants. In addition to survey
development and testing in focus groups, individual interviews were conducted with both ecological
experts and non-experts. Tests included cognitive interviews (Kaplowitz et al. 2004), verbal protocols
(Schkade and Payne 1994), and other pretests in order to gain additional insight into respondents'
understanding and interpretation of the survey. Careful attention to development and testing helped ensure
that the survey language and format would be easily understood by respondents, that respondents would
have similar interpretations of survey terminology and scenarios, and that the survey scenarios captured
restoration outcomes viewed as relevant and realistic by both respondents and natural scientists. In all
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cases, the authors paid particular attention to the use and interpretation of ecological indicators and related
information in the survey.
The choice scenarios and restoration options presented within the survey were informed in part by data
and restoration priorities in the Strategic Plan for the Restoration ofAnadromous Fishes to Rhode Island
Coastal Streams (Erkan 2002). The study authors drew additional information from the ecological
literature on fish passage restoration, interviews with ecologists and policy experts, and other sources
described below. Consistent with the strategic plan, the choice experiment within the survey addressed
restoration methods that neither require dam removal nor would cause appreciable changes in river flows;
considered options included fish ladders, bypass channels, and fish lifts. The choice experiment addresses
forage species such as alewife and blueback herring that are neither subject to current recreational or
commercial harvest in Rhode Island nor are charismatic species. Hence, the species affected are a close
analog to the forage fish affected in the 316(b) policy context. Moreover, the study's policy context
involves changes to technologies used within in-water structures (i.e., the use of fish ladders or fish lifts at
dams), providing another parallel to the 316(b) context, which also involves the use of new technologies
within in-water structures to mitigate harm to aquatic organisms.
The choice experiment asked respondents to consider alternative options for the restoration of migratory
fish passage in the Pawtuxet Watershed. Respondents were provided with two multi-attribute restoration
options, "Restoration Project A" and "Restoration Project B," as well as a status quo option that would
result in no policy change and zero household cost. An example of a choice question is presented in
Figure 8-2. Prior to administration of the choice experiment questions, the survey provided information
that: (1) described the current status of Rhode Island river ecology and migratory fish compared to
historical baselines, (2) characterized affected ecological systems and linkages, (3) described the methods
and details of fish passage restoration, and (4) provided the definitions, derivations, and interpretations of
ecological indicators used in the survey scenarios, including the reason for their inclusion. All survey
language and graphics were pretested carefully to ensure respondent comprehension.
Within each choice experiment question, the restoration options are characterized by seven attributes,
including five ecological indicators, one attribute characterizing public access, and one attribute
characterizing unavoidable household cost. The study fielded multiple versions of the survey, including
variations in the definition or set of included ecological indicators. The versions differ in the metric used
to characterize the impacts of restoration on migratory fish.
The first uses a Population Viability Analysis (PVA) score that indicates "the probability (in percentage
terms) that migratory species will still migrate the river in 50 years, as calculated by scientists" (Zhao et
al. 2013, p. 10). The second, uses a migratory fish score, migrants, that indicates "the expected number of
adults fish that will swim upstream each year", "[presented as a percentage of the reference values for the
watershed" (Zhao e 1. 2013, p. 10). Respondents were either sent the PVA or migrants version. The other
four ecological indicators presented include (1) the quantity of river habitat accessible to migratory fishes
{acres), (2) the abundance of fish suitable for recreational harvest {catch), (4) the abundance of fish-
dependent wildlife {wildlife), and (4) overall ecological condition measured by an index of biotic integrity
score {IBI). EPA used a model variant published by Zhao et al. (2013) which was estimated based on
combined responses to both survey versions {PVA and migrants). The model specification allows EPA to
isolate WTP for migrants, which provides a good match to the policy variable (i.e., the number of fish
saved).
EPA estimated the number of fish saved under the final rule and other options considered using the
methods described in Chapter 3. Although the PVA score is likely to be affected by the number of fish
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saved, estimating expected changes in population viability in the 316(b) context is not feasible due to the
lack of data allowing EPA to relate changes in individual species losses to populations, which is
particularly the case for forage species.
8.3.2 Benefit Transfer Methodology
The following subsections describe EPA's benefit transfer methods using the BSPV study. Section 8.3.2.1
describes the estimation ofWTP for a percentage increase in fish numbers and Section 8.3.2.2 describes
the application of BSPV WTP values to IM&E reductions under the final rule and other options
considered.
8.3.2.1 Estimating WTP for a Percentage Increase in Fish Numbers
Figure 8-2 is a sample choice experiment question from the migrants version of the study as presented in
Zhao et al. (2013).,s The five ecological attributes (migrants, acres, catch, wildlife, and IB I) are expressed
as a percentage relative to upper and lower reference conditions (i.e., best and worst possible in the
Pawtuxet) as defined in the survey information. Relative scores represent percent progress towards the
upper reference condition (100 percent), starting from the lower reference condition (0 percent). This
implies bounds on the potential attribute levels that might occur in the choice questions, following
guidance in the literature to provide visible choice sets (Bateman et al. 2004). Because the survey used
lower and upper bounds on a percentage point scale, it can be used for benefits transfer if IM&E
reductions can be translated to the same scale. Hence, EPA based its benefit transfer on estimated WTP
per percentage increase in fish numbers {migrants, "migratory fish" in Figure 8-2) relative to reference
conditions.
EPA notes that the choice experiment question in the survey instrument also presented the increased
number of fish and the total possible increase in the number of fish (the upper reference condition)
directly below the percent improvement in migratory fish,. The number of fish affected by the existing
facilities rule is many times larger than the number of fish corresponding to the maximum reference
condition within the survey materials, because the Rhode Island survey covers a single watershed, rather
than a large region. Because of this difference in scale, directly applying values per fish from the study to
the 316(b) fish reduction estimates would likely overstate benefits of the final rule. Basing the benefit
transfer on percentage improvement ameliorates this difference in scale, at least partially, because
improvements are bounded by the 100 percent upper reference condition in all cases. The remainder of
this section describes EPA's approach for using the implicit price, or WTP per percentage improvement,
in migratory fish based on the Rhode Island study. Additional discussion of scale of fisheries
improvements and the affected population is provided in Section 8.6.
38 In the PVA version, the "migratory fish" (i.e., migrants,) attribute is replaced with the PVA attribute.
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Question 6. Projects A and B are possible restoration projects for the Pawtuxet
River, and the Current Situation is the status quo with no restoration. Given a
choice between the three, how would you vote?
Effect of
Restoration
Fish Habitat
Migratory Fish
Catchable Fish
Abundance
Fish-Dependent
Wildlife
Aquatic Ecological
Condition Score
Public Access
$
Cost to your
Household per Year
HOW WOULD YOU
VOTE?
(CHOOSE ONE
ONLY)
Current
Situation
(no restoration)
Restoration
Project A
Restoration
Project B
0%
0 of 4347 river acres
accessible to fish
10%
450 of 4347 river acres
accessible to fish
5%
225 of 4347 river acres
accessible to fish
0%
0 out of 1.2 million
possible
33%
395,000 out of 1.2
million possible
20%
245,000 out of 1.2
million possible
80%
116 fish/hour found out
of 145 possible
80%
116 fish/hour found out
of 145 possible
70%
102 fish/hour found out
of 145 possible
55%
20 of 36 species native
to Rl are common
80%
28 of 36 species native
to Rl are common
65%
24 of 36 species native
to Rl are common
65%
Natural condition out of
100% maximum
80%
Natural condition out of
100% maximum
70%
Natural condition out of
100% maximum
Public CANNOT walk
and fish in area
Public CANNOT walk
and fish in area
Public CAN walk and
fish in area
$0
Increase in Annual
Taxes and Fees
$5
Increase in Annual
Taxes and Fees
$5
Increase in Annual
Taxes and Fees
~
I vote for NO
RESTORATION
~
I vote for
PROJECT A
~
I vote for
PROJECT B
Figure 8-2: Example Choice Experiment Question from the Zhao et a). (2013) Study including the
Migratory Fish Score
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Zhao et al. (2013) estimated a random utility model using simulated likelihood mixed logit accounting for
correlations in choices from the same respondent.39 Zhao et al. (2013) specified coefficients on all non-
cost attributes, except catch, as random with a normal distribution within the mixed logit model. The
study specified the coefficient on annual household cost (cost) with sign-reversed as random with a
bounded triangular distribution. This cost specification ensures positive marginal utility of income. The
likelihood simulations use Halton draws, or "intelligent draws", from the parameter distributions during
model estimation. Halton draws are "generated number theoretically rather than randomly and so
successive points at any stage 'know' how to fill in the gaps left by earlier points" (Bhat 2001, p. 684).
This can improve model estimation compared to using purely random draws.
Table 8-3 presents the Zhao et al. (2013) unrestricted mixed logit model. The model was estimated based
on both the PVA and migrants choice experiments including multiplicative interactions between each
non-cost attribute and djnig, a dummy variable identifying observations from the migrants choice
experiment.40 The model is significant at p<0.0001 with a pseudo-R2 of 0.31. The coefficients of all
environmental attributes, expect catch, are significant at p<0.01. The interactions allow for coefficient
estimates to vary systematically between the PVA and migrants choice experiments. Using this
specification, the marginal utility of non-cost attribute k is given by (/?/£|U + Pkxdmig,u) f°r t'lc migrants
choice experiment.
39 Mixed logit is an approach for modeling discrete choices subject to preference heterogeneity, based on the assumption that
individual's preferences are randomly distributed and that heterogeneity in population preferences can be captured by
estimating the mean and variance of the random parameter distributions (Holmes & Adamowicz 2003). As described by
Hensher and Greene (2003, p. 170), "the mixed logit model offers an extended framework within which to capture a greater
amount of behavioral choice making. Broadly speaking, the mixed logit model aligns itself much more with reality than
most discrete choice models with every individual having their own inter-related systematic and random components for
each alternative in their perceptual choice set(s)."
40 Zhao et al. (2013) present an additional pooled model without interactions. That model is not presented here because it does
allow for the isolation of WTP for changes in migrants and thus not well suited for benefits transfer to the 316(b) context.
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Table 8-3: Results of the Unrestricted Model from Zhao et al. (2013)
Variable
Coefficient
Standard Error
Random Parameters
acres
0.0463***
0.01 17
fish (I'l M and migrants pooled)
0.0169***
0.0043
IBI
0.0497***
0.0168
access
1 |577***
0.2056
wildlife
0.0267***
0.0083
neither
-4.2235***
0.4522
cost (bounded triangular, sign reversed)
0.0533***
0.0058
Non-random Parameters
catch
0.0011
0.0082
acres x d mig
0.0010
0.0161
fish x d mig
0.0093
0.0087
IBI x d mig
-0.0345
0.0229
access x d mig
0.2170
0.2643
wildlife x d mig
-0.0038
0.01 13
neither x d mig
-0.1865
0.8233
catch x d mig
-0.0052
0.01 14
Random Parameter Distributions
std. dev. acres
0.0679***
0.0216
std. dev. fish
0.0154
0.01 15
>./(/. dev. IBI
0.0816***
0.0294
std. dev. access
I 5873***
0.2544
std. dev. wildlife
0.0174
0.0257
std. dev. neither
4.8330***
0.7627
spread cost (bounded triangular)
0.0533***
0.0058
Model Statistics
-2 Log likelihood %
1.127.26***
-
Pseudo-R2
0.31
-
Observations (N)
1.634
-
Notes:
***, **, * indicates significance at 1".., 5%, 10% levels, respectively.
Parameter Descriptions:
acres - The number of acres of river habitat accessible to migratory fish.
fish - Variable that pools observations on PVA and migrants across the two choice experiments.
PVA - Population viability analysis (PVA) score. This was described to respondents as "the probability (in percentage terms)
that migratory species will still migrate the river in 50 years, as calculated by scientists."
migrants - The percentage point increase in the number of migratory fish able to reach watershed habitat.
catch - The number of catchable-size fish in restored areas.
wildlife - Number of fish-eating wildlife species that are common in restored areas.
IBI - Index of biotic integrity (IBI) score reflecting the similarity of the restored area to the most undisturbed watershed in
Rhode Island.
access - Indicates whether the restored area is accessible to the public for walking and fishing.
cost - The household annual cost required to implement the restoration program.
neither - Alternative specific constant (ASC) associated with the status quo, or a choice of neither plan.
d-mig - Binary (dummy) variable identifying observations from the choice experiment including migrants to represent effects
on migratory fish.
Sources: U.S. EPA Analysis for this report, Zhao et al. (2013)
Implicit prices for each attribute are calculated based on the ratio of marginal utility and cost as
(yPk.u + Pkxdmig,u)/Pcost,u- Because the betas are random for some attributes, simulations are used to
estimate WTP per percentage improvement for each of the environmental attributes. Zhao et al. (2013)
estimated WTP using the welfare simulation approach of Johnston and Duke (2007) following Hensher
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and Greene (2003). "The procedure begins with a parameter simulation following the parametric
bootstrap of Krinsky and Robb (1986), with R= 1000 random draws taken from the mean parameter vector
and associated covariance matrix. For each draw, the resulting parameters are used to characterize
asymptotically normal empirical densities for fixed and random coefficients. For each of these R draws, a
coefficient simulation is then conducted for each random coefficient, with S= 1000 draws taken from
simulated empirical densities (either normal or bounded triangular, depending on the distribution for each
coefficient). Welfare measures are calculated for each draw, resulting in a combined empirical
distribution of Rx-S observations from which summary statistics are derived" (Zhao et al. 2013, p. 17-18).
The resulting empirical distributions accommodate both the sampling variance of parameter estimates and
the estimated distribution of random parameters.
The welfare simulation approach provides a mean WTP estimate of $0.69 per percentage point increase in
migratory fish in 2008$ (('j3fishiU + Pfishxdmig,v)/Pcost.v), and $0.72 when adjusted to 2011$ 41 Results
for total household WTP for a series of percentage improvements in fish numbers are shown below in
Table 8-4. A zero percent improvement would mean no additional fish and 100 percent represents the
maximum possible number of fish that may be supported by the ecosystem.42 These percentage
improvements do not represent population increases; rather, they reflect new fish within a specific habitat
area that may be counted. In context of the 316(b) benefit transfer, the new fish are A1E saved under
regulatory options.
EPA transferred the estimate of $0.72 per percentage improvement to estimate nonuse benefits of 316(b)
regulatory options as described in the next section. The model makes it possible to distinguish benefits
associated with resource uses from those associated primarily with nonuse motives. Because EPA used
the implicit price for migratory fish changes for the benefit transfer application, WTP is estimated for
increases in non-harvested fish alone. The transfer holds constant all effects related to identifiable human
uses (e.g., effects on catchable fish, public access, observable wildlife, etc.). The remaining welfare
effects—derived purely from effects on fish with little or no direct human use—may therefore be most
accurately characterized as a nonuse benefit realized by households for the protection of all fish (
including forage fish).
Table 8-4: WTP per Percentage Increase in the Number of Fish (2011$)
Percentage Point Increase
in Number of Fish
WTP per % Increase in the
Number of Fish
Total WTP per Household
I
$0.72
$0.72
12
$0.72
$1.44
20
$0.72
$14.41
33
$0.72
$23.78
100
$0.72
$72.06
Source: U.S. EPA analysis for this report
41 Within the Pawtuxet Watershed study area (the original study location), each percentage point increase in is equivalent to
12,250 individual fish migrating upstream.
42 EPA converted the implicit price from 2008$ to 2011$ using the consumer price index.
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8.3.2.2 Estimating Total WTP for Eliminating or Reducing IM&E
The BSPV study was developed as a case study for a watershed-level policy in Rhode Island. While it
provides parameterized benefit functions that require the fewest assumptions to implement for
extrapolation to the 316(b) case, estimates are more likely to be representative of nonuse values held by
individuals residing in the Northeast United States. EPA expects that it would provide less accurate
estimates of nonuse values for residents of other U.S. regions outside the Northeast. EPA was unable to
identify existing valuation studies conducted in other regions that would provide benefit functions of
comparable quality and applicability to the 316(b) regulatory context. Although other studies in the
literature value changes in aquatic resources, they do not provide a good match to the 316(b) policy
scenario in terms of the expected resource change. The large number of assumptions required for
developing benefit transfer based on these studies would result in greater uncertainties compared to
application of the BSPV study. Therefore, EPA restricted the benefit transfer to the North Atlantic and
Mid-Atlantic EPA 316(b) study regions.
The structure of the transfer study dictates that WTP should be evaluated based on the single species that
would experience the greatest relative increase in abundance from restoration and that WTP estimates
from multiple species impacted by IM&E should not be treated as strictly additive. This is related to the
issue of independent valuation and summation. Species likely act as substitutes in people's utility. That is,
if one species population has increased, WTP to increase a second species may be lower if the species are
viewed as substitutes. If one values a set of species independently through separate application of the
valuation function, then the individual species estimates do not account for substitution among the species
in people's preferences and their summation could lead to misleading results. Johnston et al. (2002a)
discusses this issue in the context of environmental management and states that "If interactions among
multiple elements of environmental management programs exist, the use of survey methods such as
contingent valuation to value single dimensions of these programs in isolation (i.e., relative to the same
'initial state of the world') may provide misleading results" (p. 4-1).
To match the original valuation scenario to the 316(b) policy scenario, EPA selected the single species in
the Northeast United States that is most impacted among those species with sufficient stock information
to conduct the analysis. The selected species is most likely to be a commercially or recreationally
harvested species because of the availability of stock information. However, as discussed in the previous
section, EPA is able to focus on nonuse values by using migrants attribute for the benefit transfer. The
total baseline IM&E in the North-Atlantic and Mid-Atlantic regions were evaluated together to represent
the Northeast United States, for consistency with the available stock assessments, which include waters
from Maine to North Carolina. EPA selected winter flounder43 as the species for the benefit transfer after
considering multiple criteria:
> Stock Assessment Data - EPA defines biomass at maximum sustainable yield (BMsy) as the
baseline when estimating the percentage increase in fish abundance under the 316(b) regulatory
options. An estimate of BMsy must be available from a recent stock assessment. BMsy was
available for winter flounder from a recent stock assessment.
> Current Stock Size - Current biomass of the stock must be less than BMsy; otherwise, a percent
improvement is not calculable. For example, striped bass and croaker stocks exceed BMSY and
were removed based on this criterion. The current biomass of winter flounder is less than BMSY.
43 Winter flounder are harvested commercially; however fish of commercial species may be forage during early life-stages and
have nonuse values.
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> Magnitude oflM&E - EPA selected the species with the highest relative magnitude of baseline
IM&E on a percentage basis when compared to total age-one fish in the stock and BMSY. Baseline
IM&E for winter flounder (6.2 million) is high when compared total age-one fish in the winter
flounder stock and BMSY 44 Various other species, such as butterfish and bluefish, suffer much
lower baseline IM&E.
Winter flounder is the only species for which EPA conducts the benefits transfer, due to stock data
availability and the aforementioned issues related independent valuation, summation, and substitution.
EPA notes that baseline IM&E of winter flounder represents less than one percent of total baseline
IM&E. It is difficult to ascertain the upper bound of nonuse benefits if the transfer were able to account
for multiple species.
EPA expects that decreasing IM&E will lead to increased fish abundance in affected waterbodies. EPA
assumed that the total number of fish introduced to local habitats throughout the Northeast under the final
rule and regulatory options considered would be equivalent to the sum of A IE reductions for the North
Atlantic and Mid-Atlantic regions. Application of the BSPV model results requires that the increases be
expressed as a percentage increase over current conditions relative to a maximum number of fish that
could be supported by the ecosystem. For the benefit transfer, EPA measured IM&E on a normalized
yardstick based on fishery managed to the maximum sustainable yield. This measure should not be
interpreted as a population impact.
To calculate improvements under the final rule and regulatory options considered, EPA compared the
reduction in A1E lost to IM&E to an estimate of the number of age-1 fish in the winter flounder
population at BMsy- Available fish stock assessments of winter flounder did not estimate the number of
eggs or larvae in the population; instead, the youngest fish modeled were of age 1. Additionally, EPA
used the number of age-1 fish in the population as the basis for comparison in recognition of the fact that
winter flounder adults migrate seasonally from estuaries to offshore shelf areas. Accordingly, adults are
less likely to suffer IM&E than young fish. The most recent stock assessment for the Southern New
England winter flounder conducted by the Northeast Fisheries Science Center (NEFSC 2011) indicates
that spawning stock biomass (SSBMsy45) at maximum sustainable yield is 43,661 metric tons. EPA
calculated the approximate number of age-1 fish per metric ton of spawning stock biomass to be 2,624
using age-class data for 2005 (NEFSC 2008).46 EPA multiplied the current SSBMsy of 43,661 metric tons
by 2,624 to generate an estimate a maximum of 114.6 million age-one fish at maximum sustainable
yield.47
44 EPA used the estimated number of age-one fish in the Southern New England winter flounder stock from Terceiro (2008).
The most recent stock assessment, released in 2011 (NEFSC 2011), did not provide an estimate of the number of age-one
fish.
45 SSBmsy is the standard measure of biomass used by fisheries biologists to set fishing quotas. It includes only fish capable of
reproduction: for winter flounder, this includes fish age 3 or greater. Accordingly, winter flounder SSBmsy will always be
lower than BMSY because it excludes fish younger than age 3.
46 This is based on 8.8 million age-one fish for 3,368 metric tons of spawning stock biomass.
47 EPA analysis used data for the Southeast New England winter flounder stock. The Gulf of Maine (GOM) winter flounder
stock is also within the North Atlantic region, however, estimates of BMSY for the GOM stock are highly variable and a
consensus estimate is not provided by NMFC. The effect on estimated benefits is relatively minor because the range of BMSY
indicates that the stock would be relatively small (around 10 percent) compared to the Southern New England stock at
maximum sustainable yield.
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EPA's calculation of nonuse values from eliminating or reducing IM&E for each regulatory option
involved the following steps:
1. Calculate the percent increase of winter flounder relative to total age-1 winter flounder at
maximum sustainable yield in the Northeast U.S. (the North Atlantic and Mid-Atlantic regions
combined) by comparing A IE reductions under each regulatory option relative to a baseline of
114.6 million fish.
2. Multiply the percentage point change by the household WTP of $0.72 per percentage point
improvement (Table 8-4) to calculate the WTP per household per year for the relative increase in
winter flounder resulting from the regulatory option.
3. Calculate annual regional WTP for each regulatory option by multiplying WTP per household per
year by the total number of households within the North Atlantic and Mid-Atlantic regions,
respectively.
The results from implementing these steps for the final rule and the other options considered are described
in Section 8.4. Discussion of geographic scale and other uncertainties are provided in Section 8.6.
8.4 Benefit Transfer Results for the Final Rule and Options Considered
Table 8-5 summarizes EPA's estimates of WTP for increased fish numbers resulting from the 316(b) final
rule and options considered in the North Atlantic and Mid-Atlantic regions. EPA estimated that
elimination of all baseline IM&E would increase the number of winter flounder in the Northeast United
States by more than 6.2 million fish. This is equivalent to a 5.4 percentage point increase relative to a
maximum of 114.6 million fish (i.e., 6.2 million divided by 114.6 million). Multiplying the 5.4 percent
increase by a value of $0.72 per percentage point increase (as presented in Table 8-4) yields a household
WTP of $3.92 per year. Applying the household WTP values to the number of households in each region
results in annualized WTP values of $20.2 million and $78.9 million for the North Atlantic and Mid-
Atlantic regions, respectively, using a discount rate of 3 percent. Annualized WTP values are $19.8
million for the North Atlantic and $77.2 million for the Mid-Atlantic using a discount rate of 7 percent.
These numbers represent the nonuse value of eliminating all baseline losses of IM&E based on the benefit
transfer using the BSPV study. These are thus the maximum possible nonuse values based on this benefits
transfer covering these two regions.
EPA estimated that the final rule will increase winter flounder numbers by 0.07 percent in the North
Atlantic and Mid-Atlantic waters. Applying per household WTP to this percent increase in the number of
winter flounder ($0.05) and to the number of households in each region yields the total WTP for
improvements in winter flounder abundance. The estimated annualized WTP for the final rule in the
North Atlantic region will be about $0.2 million using both 3 percent and 7 percent discount rates. For the
Mid-Atlantic, annualized WTP will be $0.8 million using a 3 percent discount rate and $0.7 million using
a 7 percent discount rate. Table 8-5 also presents household WTP and annualized WTP for Proposal
Option 4 and Proposal Option 2.
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Table 8-5: Nonuse Value of Eliminating or Reducing Baseline IM&E for the Final
Rule and Options Considered for Regulated Facilities in the North Atlantic and
Mid-Atlantic Regions
Step
Proposal
Option 4
Final
Rule
Proposal
Option 2
Baseline
Reduction in Northeast IM&E (millions of A1E)
0.03
0.08
4.78
6.23
Percentage increase in age-1 fish in Northeast waters
relative to age-1 stock at MSY
0.02%
0.07%
4.18%
5.44%
Household WTP per Household (2011$)
$0.02
$0.05
$3.01
$3.92
North Atlantic3
Annual WTP (millions of 2011$)
$0.09
$0.28
$16.35
$21.29
Annualized WTP (3% discount rate; millions of
2011$)
$0.06
$0.21
$10.43
$20.21
Annualized WTP (7% discount rate; millions of
2011$)
$0.05
$0.17
$7.61
$19.77
Mid-Atlanticb
Annual WTP (millions of 2011$)
$0.34
$1.09
$63.80
$83.10
Annualized WTP (3% discount rate; millions of
2011$)
$0.25
$0.81
$40.70
$78.89
Annualized WTP (7% discount rate; millions of
2011$)
$0.20
$0.65
$29.69
$77.17
Total Northeast (North Atlantic plus Mid-Atlantic)
Annual WTP (millions of 2011$)
$0.42
$1.37
$80.14
$104.39
Annualized WTP (3% discount rate; millions of
2011$)
$0.31
$1.01
$51.13
$99.10
Annualized WTP (7% discount rate; millions of
2011$)
$0.25
$0.82
$37.30
$96.95
a Based on 5.41 million households.
b Based on 21.11 million households.
Source: U.S. EPA analysis for this report
8.5 Habitat-Based Methodology for Estimating Nonuse Values for Fish
Production Lost to IM&E
EPA also developed a habitat-based method for estimating nonuse values for fish lost to IM&E for the
proposed rule (USEPA 201 lb)48 The purpose of the method was to estimate the value of fish losses due
to IM&E by approximating the area of habitat required to produce and support the number of organisms
lost to IM&E. Provision of fish habitat and nursery for aquatic species is one of the ecosystem services
provided by wetlands and submerged aquatic vegetation (SAV). Thus, WTP for fish production services
associated with wetlands and SAV can provide an indirect basis for estimating the nonuse values of
increased number of fish. These values may be transferred from available wetlands and SAV valuation
studies.49 These studies found that survey respondents were aware of the fish production services
provided by eelgrass (submerged aquatic vegetation, SAV) and wetlands; individuals expressed support
48 EPAfocused on nonuse value of fish production services because use values were estimated using other valuation methods
described in Chapter 5 through 7.Hie nonuse values are estimated as the total WTP for fish production services by nonusers
of these resources.
49 Refer to Chapter 9 of the Environmental and Economic Benefits Analysis (EEBA) for the proposed rule for the list of
valuation studies used in EPA's analysis (USEPA 201 lb).
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for programs that include increasing SAV and wetland areas with the expressed goal of restoring depleted
fish and shellfish populations (Johnston et al. 2002b; Mazzotta 1996; Opaluch et al. 1995; 1998). EPA's
habitat-based approach involved estimating the area of habitat required to replace fish and shellfish lost to
IM&E and calculating public WTP for the estimated habitat area. When combined, these data yield an
estimate of household values for an increase in fish and shellfish abundance which in turn provides an
indirect estimate of the benefits of reducing or eliminating IM&E.
The habitat-based benefit transfer approach for the proposed rule involved four general steps:
1. Estimate the area of habitat necessary to produce and support the number of organisms lost to
IM&E.
2. Develop per acre WTP values for fish production services that support fish species affected by
IM&E (i.e., SAV and wetlands).
3. Estimate the total nonuse value of baseline IM&E by multiplying WTP values for fish and
shellfish services by the estimated area of habitat required to offset baseline IM&E.
4. Estimate the nonuse benefits of reduced IM&E by multiplying WTP values for fish and shellfish
services by the area of habitat required to offset IM&E reduced by regulatory options.
The WTP values used for fish and shellfish habitat services were based on an in-depth search of the
economic literature to identify valuation studies that estimate WTP for aquatic habitat services using
methods which are inclusive of nonuse values (e.g., contingent values, conjoint analysis). EPA used
additional information to isolate the proportion of WTP associated with fish habitat services from other
services such as bird habitat and mosquito control. The habitat-based benefit transfer method estimates
only those values related to IM&E of organisms, not any indirect ecosystem effects of IM&E, or chemical
effects of CWIS (Chapter 2).
For the proposed rule, EPA estimated national WTP to compensate for baseline IM&E losses under the
habitat-based approach to be about $3.6 billion and $3.7 billion using 3 percent and 7 percent discount
rates, respectively. For Proposal Option 1, EPA estimated total national WTP of $513.3 million using a 3
percent discount rate and $477.2 million using a 7 percent discount rate. National WTP for Proposal
Options 4 and 2 ranged from $509.9 million to $2.1 billion using a 3 percent discount rate and $474.0
million to $ 1.5 billion using a 7 percent discount rate. Refer to Chapter 9 of the EEBA for the proposed
rule (USEPA 201 lb) for additional detail on the habitat-based benefit transfer method, results for the
proposed regulatory options, and limitations and uncertainties associated with the approach.
EPA did not consider the habitat-based approach appropriate for primary analysis of nonuse benefits and
thus did not include habitat-based estimates in the total benefits of eliminating or reducing IM&E under
the proposed regulatory options. Likewise, EPA does not re-estimate the habitat-based approach for the
final rule or include benefits based on the habitat-based approach within the comparison of benefits and
costs for the final rule. Since the proposed rule, EPA has revised its estimates of baseline IM&E, IM&E
reductions under regulatory options, and revised the compliance schedule. However, if EPA were to re-
estimate the habitat-based analysis for the final rule, EPA expects that the results for the final rule would
generally be similar to results described above for Proposal Option l.50 The habitat-based approach helps
to illustrate the potential magnitude of nonuse values from the final rule, and provides additional support
50 As described in the Chapter 1, the final rule is Option 1 from EPA's analysis for the proposed rule (U.S. EPA 2011) with
some modifications. Proposal Options 4 and Proposal Option 2 correspond to Options 4 and 2 from EPA's analysis for the
proposed rule (U.S. EPA 2011) with some modifications.
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for the benefit transfer results presented in Section 8.4, and the results of EPA's SP survey described in
Chapter 10.
8.6 Limitations and Uncertainties
By designing a survey instrument directly for the context at hand, EPA could use the stated preference
survey results without the need to transfer benefits. However, EPA did not complete its stated preference
study in time to have it fully peer reviewed for this analysis. Thus, EPA is relying on this benefits
transfer to estimate, in part, nonuse values.
A number of issues are common to all benefit transfers. The technique involves adapting research found
in the available literature and conducted for one purpose, to another purpose, to address the policy
questions at hand. Some of the limitations and uncertainties associated with implementing a benefit
transfer using Johnston et al.(2012) are addressed below. Broader limitations and uncertainties associated
with benefit transfer in general are discussed by Johnston and Rosenberger (2010).
8.6.1 Scale of Fishery Improvements
Given the scope of the survey upon which benefit transfer results are based (Johnston et al. 2012; Zhao et
al. 2013), the most reliable results apply within the range of the attributes presented to the respondents in
the choice experiment. As shown in Figure 8-2, the percentage point increases in the number of fish for
all analyzed 316(b) regulatory options are less than 33 percent, which is within the range of the fish
migrants attribute changes presented in the survey instrument. ).
8.6.2 Scale and Characteristics of the Affected Population
The results of the Rhode Island study (Johnston et al. 2012; Zhao et al. 2013) reflect WTP for
improvements in nearby watersheds. WTP may decline as policy areas become more distant. The most
reliable application of these results would be to calculate WTP for IM&E reductions in a single local
watershed. However, the final rule will reduce IM&E and improve fish populations in multiple
watersheds within some states. Although it is not unreasonable that households would hold values for
multiple watersheds, this is a departure from the transfer study context. As noted, EPA assumed that
households have consistent values for improvements in multiple watersheds within their state or region.
Moreover, for transfers based on absolute fish numbers, EPA assumed that the per household WTP for
changes in the numbers of fish for all watersheds located within the state, including watersheds that are
shared by multiple States, would be at least equal to the WTP value for improvements in a single
watershed. Hence, EPA estimated per household WTP based on the average watershed improvement
within the state. The transfer study context was a single watershed in Rhode Island (Johnston et al. 2012;
Zhao et al. 2013). Using the benefit transfer approaches outlined here, the benefit function is applied to all
states in the North Atlantic and Mid-Atlantic regions without adjustment, based on mean household
income or local watershed characteristics. Some heterogeneity in WTP would be expected across states
and regions due to diversity in species and public values. EPA did not extend the benefit transfer beyond
the North Atlantic and Mid-Atlantic regions because of the potential for substantial differences in
preferences, demographics, and species characteristics in other regions compared to the original context
of the transfer study. This likely results in the underestimation of nonuse benefits.
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8.6.3 Fish Population Size, Type and Improvement from the Elimination of IM&E
To conduct the benefit transfer, EPA assumed that the gain in fish abundance would be equal to IM&E
reductions under the final rule and options considered. These gains are not intended to represent changes
in fish population, but are merely normalized as percentages of age-one fish at maximum sustainable
yield.
While both the transfer study and policy contexts involve forage fish, the specific species compositions
involved differ between transfer study (Johnston et al. 2012; Zhao et al. 2013) and the 316(b) context. For
example, most of the fish affected within the transfer study are migratory fish such as river herring, while
such species may account for a smaller proportion of those affected by CWIS subject to the final rule. If
WTP is sensitive to the specific type of forage fish involved, this could be a potential source of
generalization error.
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Chapter 9: Assessment of Social Cost of Carbon
9 Assessment of Social Cost of Carbon
Benefits of regulatory actions include potential effects from estimated changes in greenhouse gas (GHG)
emissions associated with energy requirements of compliance technology and installation downtime
under the final rule and other options considered. Decreases in GHG emissions, measured as C02
equivalents, may reduce the burden of global climate change to society in future years, and thus may
create a positive benefit to society, while increases in GHG emissions can impose a negative benefit, or
cost, to society. EPA refers to the costs from increased emissions as the social cost of carbon (SCC). EPA
estimated the benefit, or cost, to society from changes in GHG emissions expected to result from the final
rule and other options considered. EPA based this estimate on the SCC concept, which reflects the cost
(or benefit) to society associated with an incremental change in C02-equivalent emissions in a given year.
This chapter presents EPA's analysis for existing units at Electric Generators and Manufacturers (Section
9.1). See Chapter 12 for EPA's analysis for new units.
EPA estimated the change in C02 emissions resulting from the energy penalty associated with closed-
cycle recirculating system technology, auxiliary energy requirements for operating compliance
technology, and technology installation downtime for Electric Generators. Energy penalty effects result
from reduced energy conversion efficiency of the power generating system. EPA estimated the change in
C02 emissions resulting only from the energy penalty and increase in the auxiliary energy requirement for
Manufacturers. EPA assumed no change in C02 emissions for compliance technology installation
downtime at Manufacturers because the short-term replacement of energy by electric power generating
facilities that would otherwise be produced at Manufacturers could either increase or decrease emissions.
Refer to Appendix I of the Economic Analysis (EA) for the final rule (USEPA 2014a) for additional
detail on compliance technology effects that impose costs via impact on revenue or energy requirements.
9.1 Analysis Approach and Data Inputs
9.1.1 Electric Generators
As discussed in Chapter 3 and Appendix I of the EA, EPA expects Electric Generators to temporarily
suspend electricity generation activities to install compliance technology, and to incur annual generation
losses due to energy penalty and auxiliary energy requirements. In the case of downtime, other electric
power facilities will have to compensate for these generation losses by generating more electricity to meet
electricity demand. This may require an increased or decreased energy input, which may lead to increased
or decreased C02 emissions, depending on the energy input and generation profile of the generating units
used to compensate for the generation losses. In the case of the energy penalty and auxiliary energy
requirements, either the affected Electric Generators or other electric power facilities or both will have to
compensate for these generation losses by generating more electricity to meet electricity demand. As
with downtime, this may require an increased or decreased energy input, which may lead to increased or
decreased C02 emissions..
EPA estimated the potential increase in C02 emissions, based on results from the electricity market
analysis using the Integrated Planning Model (IPM®). For the existing unit provision of the final rule,
EPA used results for the Electricity Market Analysis - Final Rule option from the IPM analysis (for
details on that analysis, see Chapter 6 of the EA for the final rule) to estimate changes in C02 emissions.
As discussed in Chapter 6 of the EA for the final rule, the IPM analysis accounted only partially for the
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Chapter 9: Assessment of Social Cost of Carbon
new unit provision of the final rule. Consequently, to avoid underestimating the effect on C02 emissions,
EPA assumed that the IPM-based C02 emissions effects of the final rule reflect the existing unit provision
only, and assessed the impact on C02 emissions from the new unit provision of the final rule in a separate
analysis discussed in Chapter 12. To the extent that changes in C02 emissions estimated in IPM also
reflect the impact of the new unit provision of the final rule, the estimated reductions in C02 effects and
associated SCC benefit, which are assigned to the existing unit provision of the final rule, may be under-
estimated.
As described in Chapter 6 of the EA for the final rule, EPA did not conduct a separate electricity market
analysis to assess the regulatory impacts of Proposal Option 2 as analyzed in support of the final rule.
Instead, the Agency used results from the IPM analysis of Proposal Option 2 (referred to as Market Model
Analysis Option 2 in the context of IPM analysis) conducted in support of the proposed rule. As described
in the Chapter 6 of the Economic and Benefits Analysis (EBA) for the proposed rule, that IPM analysis
used an older IPM platform - IPM V3.02 EISA.51 For details on that analysis, see the EBA for the
proposed rule.
EPA calculated the difference in C02 emissions reported in the baseline (i.e., pre-policy) case and policy
case of the IPM analysis. Because EPA did not analyze Proposal Option 4 in IPM in support of either the
proposed rule or the final rule, EPA could not estimate C02 emissions specifically for that option.
However, Proposal Option 4 is similar to the existing unit provision of the final rule in that both set
performance standards based on IM technology. Moreover, compliance costs for Proposal Option 4 are
slightly lower than those of the existing unit provision of the final rule (see Chapter 3 of the EA for the
final rule). Therefore, the change in C02 emissions for Proposal Option 4 is likely to be no larger than the
emission changes calculated for the Electricity Market Analysis - Final Rule.
To estimate the change in C02 emissions for the 46-year analysis period of 2014 through 2059, EPA first
calculated the change in C02 emissions from baseline to policy option, as estimated in the IPM electricity
market analyses. As described in Chapter 6 of the EA for the final rule, the IPM V4.10_MATS platform
embeds three run years - 2015, 2020, and 2030. These run years represent multiple years and specific
technology-installation years as shown in Table 9-1.
Table 9-1: IPM V4.10_MATS Run-Year Specification - Final Rule3'"
Run Year
Represented Years
Regulatory Effects Captured - Final Rule
2015
2014-2016
Operations and financial changes in anticipation of future compliance'1
2020
2017-2024
IM technolosiv installation
2030
2025-2034
Steady-state post-compliance period: captures potential permanent
changes.
a As discussed in Appendix P of the EA for the final rale, IPM reflects an assumption of perfect foresight.
b V4.10 MATS is the IPM version that EPA used to analyze the Final Mercury and Air Toxics Standards (MATS).
51 Although Proposal Option 2 analyzed in support of the final rule set impingement mortality and entrainment performance
standards similar to those analyzed under Market Model Analysis Option 2, the expected compliance responses differ in
terms of technologies that some facilities will install and the associated costs. In addition, administrative requirements
considered for Proposal Option 2 differ from those analyzed in IPM for the proposed rule. Also, the current universe of
regulated facilities is slightly smaller than the universe of regulated facilities analyzed for the proposed rule. Finally,
compared to Market Model Analysis Option 2, Proposal Option 2 provides facilities with more flexibility and a longer
window to comply with the regulatory requirements. EPA judges that despite these differences, the electricity market
analysis results from the proposed rule are sufficient to assess the change in C02 emissions under Proposal Option 2.
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Chapter 9: Assessment of Social Cost of Carbon
As described in Chapter 6 of the economic and benefits analysis for the proposed rule (USEPA 201 la),
EPA specified four run years for the IPM analysis in accordance with the compliance-technology
installation schedule considered at that time: 2015, 2020, 2025, and 2028. These run years represent
multiple years and specific technology-installation years as follows:
Table 9-2: IPM V3.02_EISA Run-Year Specification - Proposal Option 2a
Run Year
Represented Years
Regulatory Effects Captured - Proposed Rule
2015
2013-2017
IM technolosiv installation
2020
2018-2022
Kntrainment control technolosiv installation - non-nuclear facilities
2025
2023-2027
Kntrainment control technolosiv installation - nuclear facilities
2028
2028
Steady-state post-compliance period: captures potential permanent
changes.
a V3.02 EISA is the IPM version that EPA used to model electric generation for the proposed Transport Rule.
EPA assumed that any observed changes in C02 emissions between the baseline case and the policy case
are attributable to the analyzed 316(b) regulatory requirements. For the final rule, EPA assumed that the
difference in C02 emissions reported for 2015 is the same as the difference in the other three years
represented by 2015, i.e., 2014 through 2016. EPA applied the same methodology to the remaining two
run years, thereby generating the change in C02 emissions for the 21-year period of 2014 through 2034.52
EPA used the same methodology for Proposal Option 2, generating a time profile of changes in C02
emissions for the 16-year period of 2013 through 2028.
In reviewing the estimated changes in C02 emissions from the IPM runs, EPA observed that for some
regulatory options and some analysis years, C02 emissions decline even though EPA would expect the
options to have effects of replacing and/or providing additional electricity generation, as described above.
On closer inspection, in these cases, the generation mix between the baseline and the regulatory option
case changes in such a way that a C02 emissions decrease is plausible - e.g., increased generation from
nuclear facilities (which are non-C02 emitting) and reduced generation from coal or other fossil fuel
facilities.
The run-year configuration embedded in the IPM V4.10MATS platform used for the analysis of the final
rule was set independent of the 316(b) compliance and technology installation schedule. Unlike the case
with the IPM analysis done in support of the proposed rule, EPA did not change this configuration to
better reflect the final rule requirements. EPA expects all regulated facilities to install compliance
technologies during the 5-year period of 2018 through 2022, which is within the range of years
represented by the 2020 IPM run year. To align year-specific changes in C02 emissions estimated for the
Electricity Market Analysis - Final Rule as part of the IPM analysis with technology-installation schedule
of the final rule and consequently, Proposal Option 4, EPA made the following assumptions:
> As discussed in Chapter 6 of the EA for the final rule, the three years (2014 through 2016)
represented by the 2015 IPM run year, have the same characteristics as the 2015 year. These three
years immediately precede the technology-installation period assumed in the IPM analysis. EPA
assumed that the year-specific changes in C02 emissions estimated for Electricity Market
52 Even though no compliance technology is installed during the 3-year period represented by the 2015 IPM run year, any
changes in the market behavior resulting in changes in C02 emissions are due to anticipated compliance with the 316(b)
requirements. As discussed in Appendix P of the Final Rule EA report, IPM reflects an assumption of perfect foresight,
which means that market players have complete knowledge of the nature and timing of the constraints, including those
created by regulatory requirements that will be imposed in future years during the analysis period, and make decisions based
on this knowledge.
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Analysis - Final Rule for 2014 through 2016 are the same as those that will occur during 2015
through 2017, i.e., the 3-year period immediately preceding the technology-installation period
anticipated under the final rule.
> Similar to the 2015 IPM run year , the eight years (2017 through 2024) that are represented by the
2020 IPM run year have the same characteristics as the 2020 run year. As a result, in the IPM
analysis, downtime was applied as a single value for each of the eight years. EPA assumed that
the resulting total difference in C02 emissions for this eight-year period (C02 emissions reported
for the 2020 IPM run year times eight - the number of years that the 2020 run year represents) is
the same as the total difference in C02 emissions that would have resulted if all facilities were to
install IM technologies during the five-year period, 2018 through 2022, when compliance
technology will be installed under the final rule. EPA converted the eight-year total of C02
emissions change to a yearly value for each of the five years, 2018 and 2022, by simply dividing
the total emissions change over the eight years by five.
> Finally, using the same approach as that used for the 2015 IPM run year, EPA assumed that the
year-specific changes in C02 emissions estimated for the 2030 IPM run year and consequently,
for each of the 10 years it represents - 2025 through 2034 - are the same as those that would
occur during the 10-year period of 2023 through 2032. In other words, the Agency "moved" the
emissions changes in the 10-year IPM-analysis period of 2025 through 2034 to the 10-year period
of 2023-2032, the years following expected completion of technology installation under the final
rule. The change in C02 emissions reported for the final rule in 2030 is negative (i.e., C02
emissions in that year decline from the baseline to the policy case). To avoid understating the
potential effect of regulatory requirements on C02 emissions, EPA applied this decrease only to
the 10 years represented by 2030 and assumed zero change in C02 emissions during the
remaining years in the social-cost analysis period, i.e., 2033 through 2059.
The technology-installation schedules EPA assumed for the IPM analysis in support of the proposed rule
differ from those assumed for Proposal Option 2 analyzed in support of the final rule. As shown in Table
9-2, for the proposed rule, EPA assumed that facilities would install IM technologies during a 5-year
window of 2013 through 2017. Further, EPA assumed that non-nuclear and nuclear facilities would install
entrainment control technologies during 2018 through 2022, and 2023 through 2027, respectively. As
discussed earlier in this chapter, for the existing unit provision of the final rule, these technology-
installation periods are 2018 to 2022, 2021 to 2025, and 2026 to 2030, respectively. To align year-specific
changes in C02 emissions estimated for Market Model Analysis Option 2 with technology-installation
schedules EPA assumed for Proposal Option 2 analyzed in support of the final rule, EPA made the
following assumptions:
> Proposal Option 2 and Market Model Analysis Option 2 require both IM and entrainment control
technologies. To capture differences in energy requirements to install and operate these two sets
of technologies, EPA aligned year-specific changes in C02 emissions estimated for Market
Model Analysis Options 2 with technology-specific installation schedules currently assumed for
Proposal Option 2. To capture changes in emissions associated with IM technology, EPA
assumed that the year-specific changes in C02 emissions estimated for Market Model Analysis
Option 2 during 2013 through 2017 are the same as those that EPA would have estimated for
2018 through 2022. For entrainment-control technology installation at non-nuclear facilities, the
Agency assumed that the changes in emissions it estimated for 2018 through 2022 are the same as
those it would have estimated for 2021 through 2025. For installation of entrainment control
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technology at non-nuclear facilities, the Agency assumed that the changes in emissions estimated
for 2023 through 2027 are the same as those that EPA would have estimated for 2026 through
2030. Unlike the case of Electricity Market Analysis - Final Rule, under Market Model Analysis
Option 2, the change in C02 emissions reported for the steady-state year (2028) is positive (i.e.,
C02 emissions in that year increase from the baseline to the post-policy case). To avoid
understating the potential effect of regulatory requirements on C02 emissions, EPA applied this
increase in emissions over the remaining years in the social-cost analysis period, i.e., 2031
through 2059.
To estimate the benefits of changes in C02 emissions due to the existing unit provision of the final rule
and Proposal Option 2, EPA used SCC values from Technical Support Document: Technical Update of
the Social Cost of Carbon for Regulatory Impact Analysis-Under Executive Order 12866 developed by
the United States Government Interagency Working Group on Social Cost of Carbon, 2013 (Interagency
Working Group 2013). The Working Group estimated annual unit SCC values ($ per metric ton) for 2010
through 2050 (Table 9-3). Three of these four sets are based on the average unit SCC values across
models, and socio-economic and emissions scenarios, for each of three SCC discount rates: 5.0, 3.0, and
2.5 percent. The Work Group developed a fourth set of unit SCC values as the 95th percentile value of the
3 percent discount rate-based SCC values; these values represent the potential for higher-than-expected
impacts from temperature change farther out in the tails of the SCC distribution.53
Table 9-3: Unit Social Cost of Carbon, 2010-2050 ($ per metric ton of C02;
2011 $)a
Year
Discount Rates
2.5%
3.0%
5.0%
Average SCC
Value
Average SCC
Value
High SCC Value
Average SCC
Value
20I0
$55.42
$34.15
$94.98
$1 1.74
$0.83
$39 48
$116 32
2020
$68.30
9
$136.59
1
2025
$73 63
$50 16
$152 60
4
2030
$80 04
$55 49
$169.68
7
$85 37
$59 76
$186 75
$20 28
2040
$91 77
$65 10
$203.82
$22 41
2045
$98 18
$70 43
$219 83
$25 61
2050
$103.51
$75.77
$234.77
$27.75
a SCC values were calculated for 2010 through 2050 and vary by year; this table reports SCC values only for
every fifth year.
Sources: Interagency Working Group, 2013; updated to 2011$ for this analysis using the GDP
deflator.
These unit SCC values represent the present value of the future stream of costs to society from a change
in GHG emissions in a given year, recognizing that the impact of changes in C02 in the atmosphere
occurs not only in the year in which the emissions are generated, but extends over a substantial period
into the future.54 In the 2013 Technical Support Document (TSD) (Interagency Working Group 2013),
53 For more information on the assumptions and methodology used to develop these SCC values see the 2013
TSD(Interagency Working Group 2013) available online at:
http://www.whitehouse.gov/sites/default/files/omb/inforeg/social_cost_of_carbon_for_ria_2013_update.pdf.
54 The unit SCC values reported in the 2013 TSD and used in the current analysis are global SCC values. Hie Interagency
Working Group determined that the use of global measures of benefits for greenhouse gas reductions is preferable to
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these values are in 2007 dollars; EPA restated these values in 2011 dollars using the GDP deflator series.
The SCC values published by the Working Group increase in real economic terms from year to year,
reflecting the increasing marginal cost to society of additional GHG emissions and increasing cumulative
burden of climate change over time. Because the Working Group published unit SCC values only through
2050, EPA extended the unit SCC values from 2050 to 2059, assuming that the annual real rate of change
in the future SCC values remained the same as in the period 2049 to 2050.
EPA calculated the benefits of the year-to-year changes in C02 emissions as a product of the year-by-year
unit SCC values and the estimated year-by-year changes in C02 emissions. The Agency then discounted
the resulting year-by-year benefit values, summed the discounted values, and annualized them using
discounts rate of 3 percent and 7 percent.55
9.1.2 Manufacturers
To estimate the change in C02 emissions due to compliance for Manufacturers, EPA estimated the
replacement energy required during downtime and as a result of the energy penalty and auxiliary energy
requirements. For downtime, electricity otherwise produced by Manufacturers will instead be produced
by the electric power industry. Therefore, electricity generation and associated C02 emissions of
Manufacturers decrease during downtime while generation and emissions from the electric power
industry increase. Depending upon the carbon intensity of generation by the electric power industry
relative to that of generation by Manufacturers, C02 emissions may increase or decrease during
downtime. Given this uncertainty, EPA assumed no net change in C02 emissions during downtime. If the
carbon intensity of generation for the electric power industry is greater than that for Manufacturers", this
assumption will underestimate the increase in C02 emissions, and vice versa.
For a given quantity of energy input56, energy penalty and auxiliary energy requirements reduce the
amount of electricity that is available to the facility to meet baseline consumption needs and/or for sale.57
EPA assumed that Manufacturers will not be able to increase energy input to offset this loss, with the net
effect that a facility will need to purchase more electricity from other electric power generators or will
deliver less electricity for external consumption. EPA assumed that these electricity losses, whether due to
energy penalty or to auxiliary energy requirements, will be replaced by the electric power industry. This
means that the facility's own C02 emissions will be unchanged but that C02 emissions may increase as
other electric power generators make up this loss. EPA calculated the increase in C02 emissions from the
generation of replacement electricity by the power industry based on the average C02 emissions intensity
for United States.
EPA first calculated the replacement electricity required to offset the electricity loss from energy penalty
and auxiliary energy requirements, assuming Manufacturers would incur the these effects from 2010
domestic measures. Refer to the 2013 TSD (Interagency Working Group 2013), and the earlier 2010 TSD (Interagency
Working Group 2010) for additional discussion of global versus domestic measures.
55 This discounting approach diverges from the discount rate concepts used to develop the SCC values. However, the 3 percent
and 7 percent discount rates are appropriate given that the alternative year-by-year SCC values reflect a range of factors
including not only discount rates, but also different impact/socio-economic evolution scenarios, modeling
approach/framework, and damage functions.
50 The energy that is consumed to generate electricity.
57 See Appendix I of the EA for detailed discussion of how energy penalty and auxiliary energy requirements affect electric
power generation and the supply of electricity otherwise available for consumption at facilities installing compliance
technology.
May 2014
9-6
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 9: Assessment of Social Cost of Carbon
through 2059 (see Appendix I of the EA for the final rule). EPA then calculated the C02 emissions
intensity based on projected total electricity generation (USDOE 2013b) and associated C02 emissions
(USDOE 2013a) by year. EIA projects these values only to 2040, so EPA assumed no change in carbon
intensity beyond 2040. EPA multiplied the carbon intensity in each year by the replacement electricity
required in that year to calculate the C02 emissions due to the energy penalty of Manufacturers. EPA
multiplied the estimated C02 emission values, by year, by the same unit SCC values as those used for
Electric Generators (Table 9-3).
9.2 Key Findings for Regulatory Options
9.2.1 Electric Generators
Table 9-3 presents the total reduction in C02 emissions and associated values of SCC in 2013 for Electric
Generators, by option and discount rate. The SCC values reported for Proposal Option 4 are the same as
those reported for existing unit provision of the final rule because EPA assumed that C02 emissions for
Proposal Option 4 would be the same as those calculated in the IPM analysis for Market Model Analysis
1, which aligns most closely with the existing unit provision of the final rule. To the extent that Proposal
Option 4 is less stringent than Market Model Analysis 1 or the existing unit provision of the final rule, the
SCC values reported for Proposal Option 4 are overstated.
As reported in Table 9-4, EPA estimates that the existing unit provision of the final rule (and Proposal
Option 4) will result in a total reduction of 9.6 million tons of C02 equivalents (tC02eq). As discussed
above, EPA assesses that this reduction is likely the result of changes in generation mix that lead to more
electricity generated by facilities with lower carbon emissions or none at all, such as nuclear facilities, and
less electricity generated by coal or other fossil fuel facilities. Using the average SCC values calculated at
a 3 percent discount rate, EPA estimates that this reduction in carbon emissions will result in average
annual benefits of $12.4 million at the 3 percent discount rate and $13.4 million at the 7 percent discount
rate. EPA estimates that under Proposal Option 4, total carbon emissions would increase by 1,471.9
million of tC02eq. Using the average SCC values calculated at a 3 percent discount rate, EPA estimates
the average annual (negative) benefit associated with this increase in carbon emissions to be -$1,613.6
million at the 3 percent discount rate and -$1,197.9 million at the 7 percent discount rate.
May 2014
9-7
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 9: Assessment of Social Cost of Carbon
Table 9-4: Total Reduction in Carbon Emissions and Associated Benefits Under the Final Rule
and Other Options Considered - Electric Generators (SCC Values in 2013; 2011$, millions)
Total Reduction in
Emissions
(tC02eq, millions)
Discount Rate for Calculating SCC Unit Values
Option
2.5%
3.0%
5.0%
Average SCC
Value
Average SCC
Value
High SCC
Value
Average SCC
Value
3% Discount Rate for Annualizing Benefits
Proposal Option 4a
9.6
$18.1
$12.4
$37.7
$3.8
Filial Rule - Existing Units5
9.6
$18.1
$12.4
$37.7
$3.8
Proposal Option 2
-1,471.9
-$2,281.0
-$1,613.6
-$4,988.0
-$536.2
7% Discount Rate for Annualizing Benefits
Proposal Option 4a
9.6
$19.6
$13.4
$40.7
$4.1
Final Rule - Existing Units5
9.6
$19 6
$13.4
$40.7
$4.1
Proposal Option 2
-1.471.9
-$1,714.4
-$1,197.9
-$3,693.7
-$388.9
a To the extent that EPA used IPM results for Electricity Market Analysis - Final Rule as a proxy for Proposal Option 4, benefits for Proposal
Option 4 are likely to be over-stated.
b To the extent that the change in C02 emissions estimated for the existing unit provision of the final rule partially accounts for the change in
C02 emissions due to the new unit provision of the final rule, benefits reported for the existing unit provision of the final rule may be
overstated.
Source: U.S. EPA analysis for this report
9.2.2 Manufacturers
Table 9-5 presents the total reduction in C02 emissions and associated benefit values for Manufacturers
by option. Under the final rule and Proposal Option 4, EPA assessed no reduction in C02 emissions.
Under Proposal Option 2, EPA calculated an increase of 25.4 million in tC02eq. Using the average SCC
values calculated at a 3 percent discount rate, EPA estimates the benefits associated with the estimated
increase C02-equivalent emissions to be -$27.8 million at the 3 percent discount rate and $20.3 million at
the 7 percent discount rate.
Table 9-5: Total Reduction in Carbon Emissions and Associated Benefits Under the Final Rule
and Other Options Considered - Manufacturers (SCC Values in 2013; $2011, millions)
Discount Rate for Calculating SCC Unit Values
Option
Total Emissions
2.5%
3.0%
5.0%
(tC02eq, millions)
Average SCC
Value
Average SCC
Value
High SCC
Value
Average SCC
Value
3% Discount Rate for Annualizing Benefits
Proposal Option 4a
0.0
$0.0
$0.0
$0.0
$0.0
Final Rule - Existing Units
0.0
$0.0
$0.0
$0.0
$0.0
Proposal Option 2
-25.4
-$39.2
-$27.8
-$85.8
-$9.6
7% Discount Rate for Annualizing Benefits
Proposal Option 4a
0.0
$0.0
$0.0
$0.0
$0.0
Final Rule - Existing Units
0.0
$0.0
$0.0
$0.0
$0.0
Proposal Option 2
-25.4
-$29.1
-$20.3
-$62.7
-$6.7
a To the extent that EPA used IPM results for Market Model Analysis 1 as a proxy for Proposal Option 4, benefits for Proposal Option 4 are
likely to be over-stated.
Source: U.S. EPA analysis for this report
Table 9-6, Table 9-7, and Table 9-8 present the change in C02 emissions and associated undiscounted
benefits for existing units for Electric Generators and Manufacturers by year for Proposal Option 4, the
final rule, and Proposal Option 2, respectively.
May 2014
9-8
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 9: Assessment of Social Cost of Carbon
Table 9-6: Social Cost of Carbon by Year for Electric Generators and Manufacturers -
Proposal Option 4 ($2011, millions)
Year
Emissions
(tC02eq, millions)
Discount Rate for Calculating SCC Unit Values
2.5%
3.0%
5.0%
Average SCC
Value
Average SCC
Value
High SCC Value
Average SCC
Value
2013
0.0
$0.0
$0.0
$0.0
$0.0
2014
0.0
$0.0
$0.0
$0 0
$0.0
2015
0.2
$13.3
$8.6
$25.5
$2 6
2016
0.2
.8
$8 9
$26.2
$2 8
20I7
0.2
$14.0
$9 1
$27.1
$2 8
2018
0.0
-$2 8
-$5 6
-$0 6
2019
0.0
-$2 9
-$0 6
2020
0.0
-$3 0
-$2 0
-$5 9
-SO 6
2021
0.0
-$3 0
-$2.0
-$6 1
-$0.6
2022
0.0
-$3 1
-$2 0
-$6 2
-$0.6
2023
0.9
$65.5
.0
2024
0.9
$66.5
$45 0
$137.0
2025
0.9
$67.5
$46.0
$139.9
$13.7
2026
0.9
$68.5
$47.0
$142.8
$14.7
2027
0.9
$69.5
$47.9
$145.8
$14.7
2028
0.9
$70.4
$48.9
$148.7
$14.7
2029
0.9
$71.4
$49.9
$151.6
$15.7
2030
0.9
$73.4
$50.9
$155.5
$15.7
2031
0.9
$74.3
$50.9
$158.5
$16.6
2032
0.9
$75.3
$51.8
$16.6
2033
0.0
$0.0
$0.0
$0.0
$0.0
2034
0.0
$0 0
$0.0
$0 0
$0 0
2035
0 0
$0 0
$0.0
$0 0
$0 0
2036
0 0
$0 0
$0.0
$0 0
$0 0
2037
0 0
$0 0
$0.0
$0 0
$0 0
2038
0 0
$0 0
$0.0
$0 0
$0 0
2039
0 0
$0 0
$0 0
$0 0
$0 0
2040
0 0
$0 0
$0 0
$0 0
$0 0
2041
0 0
$0 0
$0 0
$0 0
$0 0
2042
0 0
$0 0
$0 0
$0 0
$0 0
2043
0.0
$0 0
$0 0
$0 0
$0 0
2044
0.0
$0 0
$0 0
$0 0
$0 0
2045
0.0
$0 0
$0.0
$0.0
$0.0
2046
0.0
$0 0
$0 0
$0 0
$0 0
2047
0 0
$0 0
$0 0
$0 0
$0 0
2048
0 0
$0 0
$0 0
$0 0
$0 0
2049
0 0
$0.0
$0.0
$0 0
$0 0
2050
0 0
$0.0
$0.0
$0 0
$0 0
2051
0 0
$0 0
$0.0
$0 0
$0 0
2052
0 0
$0.0
$0.0
$0 0
$0 0
2053
0 0
$0 0
$0.0
$0 0
$0 0
2054
0 0
$0 0
$0.0
$0 0
$0 0
2055
0.0
$0 0
$0.0
$0 0
$0.0
2056
0.0
$0 0
$0.0
$0 0
$0.0
2057
0.0
$0 0
$0.0
$0.0
$0.0
2058
0.0
$0.0
$0.0
$0 0
$0 0
2059
0 0
$0 0
$0.0
$0 0
$0 0
2060
0 0
$0 0
$0.0
$0 0
$0 0
2061
0 0
$0 0
$0.0
$0 0
$0 0
2062
0 0
$0.0
$0.0
$0 0
$0 0
2063
0.0
$0 0
$0.0
$0 0
$0.0
2064
0.0
$0.0
$0.0
$0.0
$0.0
Present Value 3%
$483.1
$330.3
$1,007.6
$101.7
Annualized, 3%
-
$18.1
$12.4
$37.7
$3.8
Present Value 7%
-
$290.4
$198.0
$603.0
$60.8
Annualized 7%
-
$19.6
$13.4
$40.7
$4.1
Source: U.S. EPA analysis for this report
May 2014
9-9
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 9: Assessment of Social Cost of Carbon
Table 9-7: Social Cost of Carbon by Year for Electric Generators and Manufacturers - Final
Rule-Existing Units ($2011, millions)
Emissions
(tC02eq,
millions)
Discount Rate for Calculating SCC Unit Values
Year
2.5%
3.0%
5.0%
Average SCC
Value
Average SCC
Value
High SCC Value
Average SCC
Value
2013
0.0
$0.0
$0.0
$0.0
$0.0
2014
0.0
$0 0
$0 0
$0.0
$0.0
2015
0.2
$13 3
$8 6
$25.5
$2.6
2016
0.2
$13 8
$8 9
$26 2
$2 8
20I7
0.2
$14.0
$9 1
$27 1
$2 8
2018
0.0
-$2 8
-$1.9
-$0 6
2019
0.0
-$2 9
-$1.9
-$0 6
2020
0.0
-$3 0
-$2 0
-$0 6
2021
0.0
-$3.0
-$2.0
-$6.1
-$0.6
2022
0.0
-$3 1
-$2 0
-$6 2
-$0 6
2023
0.9
$65 5
$44.0
2024
0.9
$66.5
$45.0
$137.0
202 5
0.9
$67.5
$46.0
$139.9
2026
0.9
$68.5
$47.0
$142.8
$14.7
2027
0.9
$69.5
$47.9
$145.8
$14.7
2028
0.9
$70.4
$48.9
$148.7
$14.7
2029
0.9
$71.4
$49.9
$151.6
$15.7
2030
0.9
$73.4
$50.9
$ 155.5
$15.7
2031
0.9
$74.3
$50.9
$158.5
$16.6
2032
0.9
$75.3
$51.8
$161.4
$16.6
2033
0.0
$0.0
$0.0
$0.0
$0.0
2034
0.0
$0 0
$0 0
$0.0
$0.0
2035
0.0
$0 0
$0 0
$0.0
$0.0
2036
0.0
$0 0
$0 0
$0.0
$0.0
2037
0.0
$0 0
$0 0
$0.0
$0.0
2038
0.0
$0 0
$0 0
$0.0
$0.0
2039
0.0
$0 0
$0 0
$0 0
$0 0
2040
0.0
$0 0
$0 0
$0 0
$0 0
2041
0.0
$0 0
$0 0
$0 0
$0 0
2042
0.0
$0 0
$0 0
$0 0
$0 0
2043
0.0
$0 0
$0 0
$0 0
$0 0
2044
0.0
$0 0
$0 0
$0 0
$0 0
2045
0.0
$0.0
$0.0
$0.0
$0.0
2046
0.0
$0 0
$0 0
$0 0
$0 0
2047
0.0
$0 0
$0 0
$0 0
$0 0
2048
0.0
$0 0
$0 0
$0 0
$0 0
2049
0.0
$0 0
$0 0
$0.0
$0.0
2050
0.0
$0 0
$0 0
$0.0
$0.0
2051
0.0
$0 0
$0 0
$0.0
$0.0
2052
0.0
$0 0
$0 0
$0.0
$0.0
2053
0.0
$0 0
$0 0
$0.0
$0.0
2054
0.0
$0 0
$0 0
$0.0
$0.0
2055
0.0
$0 0
$0 0
$0.0
$0.0
2056
0.0
$0 0
$0 0
$0.0
$0.0
2057
0.0
$0.0
$0.0
$0.0
$0.0
2058
0.0
$0 0
$0 0
$0.0
$0.0
2059
0.0
$0 0
$0 0
$0.0
$0.0
2060
0.0
$0 0
$0 0
$0.0
$0.0
2061
0.0
$0 0
$0 0
$0.0
$0.0
2062
0.0
$0 0
$0 0
$0.0
$0.0
2063
0.0
$0 0
$0 0
$0.0
$0.0
2064
0.0
$0.0
$0.0
$0.0
$0.0
Present Value 3%
-
$483.1
$330.3
$1,007.6
$101.7
Annualized, 3%
-
$18.1
$12.4
$37.7
$3.8
Present Value 7%
-
$290.4
$198.0
$603.0
$60.8
Annualized 7%
-
$19.6
$13.4
$40.7
$4.1
Source: U.S. EPA analysis for this report
May 2014
9-10
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 9: Assessment of Social Cost of Carbon
Table 9-8: Social Cost of Carbon by Year for Electric Generators and Manufacturers - Proposal
Option 2 ($2011, millions)
Year
Emissions
(tC02eq, millions)
Discount Rate for Calculating SCC Unit Values
2.5%
3.0%
5.0%
Average SCC
Value
Average SCC
Value
High SCC Value
Average SCC
Value
2013
().()
$0.0
$0.0
$0.0
$0.0
20I4
0 0
$0.0
$0.0
$0.0
$0 0
2015
0 0
$0.0
$0.0
$0 0
$0 0
2016
0 0
$0 0
$0 0
$0 0
$0 0
20I7
().()
$0 0
$0 0
$0 0
$0 0
2018
3 2
$210 3
$1379
$41.4
2019
3.2
$213 7
$427 5
2020
3.2
$220.6
$148.2
$441.3
2021
-27.7
-$1,924.4
-$1,273.1
-$3,878.4
-$355.3
2022
-27.8
56.4
04.3
-$3,972 1
-$ i85 4
2023
-31.2
-$2,230.3
-$1.497 9
-$4.560 4
-$4 i2 7
2024
-31.3
-$2,273 4
-$1,537.9
-$4,680.5
-$468.1
2025
-31.3
-$2,307.6
-$1,571.9
-$4,782 4
-$468.2
2026
-51.5
-$3,845 3
-$2,636.8
-$8,020.2
-$824.0
2027
-51.5
-$3,900.1
-$2,691.6
-$8,184 7
-$824.0
2028
-51.5
-$3,954 9
-$2,746.5
-$8,349.3
-$823.9
2029
-51.5
-$4,009.8
-$2,801.4
-$8,514.0
-$878.9
2030
-51.5
-$4.l 19.7
-$2,856.3
-$8,733.7
-$878.9
2031
-38.0
-$3,078.4
-$2,106.3
-$6,561.8
-$688.6
2032
-38.0
-$3.l 18.9
-$2,146.7
-$6,683.3
-$688.6
2033
2034
-38.0
-$3,159.3
-$2,187.2
-$6,804.6
-$729.1
-38.0
-$3,199.8
-$2,227.7
-$6,966 6
-$729.1
2035
-38.0
-$3,240.2
-$2,268.2
-$7,088.0
-$769.6
2036
-38.0
-$3,280.6
-$2,308.6
-$7,209 3
-$769 5
2037
-37.9
-$3,361.3
-$2,348.9
-$7,330.0
-$809 9
2038
-37.9
-$3,401.5
-$2.389.1
-$7,491 4
-$809.9
2039
-37.9
-$3,441.5
-$2,429.3
-$7.61 1.7
-$850.2
2040
-37.9
-$3,481.4
-$2 469.4
-$7 732.0
-$850 1
2041
-37.9
-$3,521.9
-$2 509.9
-$7 853.5
-$890 6
2042
-37.9
-$3,562.4
-$2 550.3
-$7 <>74.9
-$890 6
2043
-37.9
-$3,602.9
-$2,590.8
-$8 096.3
-$931 1
2044
-37.9
-$3,643.4
-$2,631.3
-$8 217.8
-$931 1
2045
-37.9
-$3,724.3
-$2,671.8
-$8,339.2
-$971.6
2046
-37.9
-$3,764.8
-$2,712 3
-$8,460 7
-$971.6
2047
-37.9
-$3,805.3
-$2,752.8
-$8 541.6
-$1,012.0
2048
-37.9
-$3,845 8
-$2,793.2
-$8.663.1
-$1,012.0
2049
-37.9
-$3,886.2
-$2,833.7
-$8,784 5
-$1,052.5
2050
-37.9
-$3,926.7
-$2,874.2
-$8,906.0
-$1,052.5
2051
-37.9
-$3,967 6
-$2,915.3
-$9,029.1
-$1,053.3
2052
-37.9
-$4,009.0
-$2,956.9
-$9,154.0
-$1,054.0
2053
-37.9
-$4,050 7
-$2,999.2
-$9,280.6
-$1,054.8
2054
-37.9
-$4,092.9
-$3,042.0
-$9,408.9
-$1,055.7
2055
-37.9
-$4,135.6
-$3,085.5
-$9,539.0
-$1,056.5
2056
-37.9
-$4,178.7
-$3,129.6
-$9,670.9
-$1,057.4
2057
-37.9
-$4,222.2
-$3,174.3
-$9,804.7
-$1,058.3
2058
-37.9
-$4,266.2
-$3,219.7
-$9,940.2
-$1,059 3
2059
-37.9
-$4.310 6
-$3,265.7
-$10,077.7
-$1,060 3
2060
0.0
$0.0
$0.0
$0.0
$0 0
2061
0 0
$0.0
$0.0
$0.0
$0 0
2062
0 0
$0.0
$0.0
$0.0
$0 0
2063
0.0
$0.0
$0.0
$0.0
$0.0
2064
0.0
$0.0
$0.0
$0.0
$0.0
Present Value 3%
-
-$62,019.1
-$43,872.4
-$135,622.3
-$14,589.0
Annualized, 3%
-
-$2,320.2
-$1,641.3
-$5,073.8
-$545.8
Present Value 7%
-
-$25,804.9
-$18,030.6
-$55,597.3
-$5,855.4
Annualized 7%
-
-$1,743.5
-$1,218.2
-$3,756.4
-$395.6
Source: U.S. EPA analysis for this report.
May 2014
9-11
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 10: Summary for Existing Units
10 Summary of Monetized Benefits for Existing Units
10.1 Introduction
This chapter presents a summary of the monetized benefits for existing units under the final rule and
options considered. Chapters 5 through 9 describe the methods and data EPA used to monetize benefits.
Refer to Chapter 1 for a description of the requirements of the final rule and other options considered. The
national benefits estimates presented in this chapter do not include benefits estimated using EPA's SP
survey. Refer to Chapter 11 for detail on the SP survey and results.
10.2 Summary of Methods and Limitations
EPA based its estimates of national monetized benefits for IM&E reductions under the final rule and
options considered on its regional estimates of monetized benefits by summing over the seven study
regions. EPA estimated mean national use values, as well as values that include the 5th percentile lower
bound and 95th percentile upper bound of the recreational benefits estimates.58 EPA's estimates of
changes in GHG emissions and associated benefits are at the national level. Monetizing the benefits
resulting from IM&E reductions and GHG emissions reductions under the final rule and options
considered is challenging. The preceding chapters discuss specific limitations and uncertainties associated
with estimating reductions in IM&E and monetized benefits. The national benefits estimates presented in
Section 10.3 are subject to the same uncertainties inherent in the valuation approaches EPA used for
assessing regional benefits described in Chapter 5 through 9. The combined effect on estimated use values
(threatened and endangered species, commercial fishing, and recreational fishing) is of unknown
magnitude and direction (i.e., the estimates may over- or understate the anticipated national level of use
benefits). Nevertheless, EPA has no data to indicate that the results for estimated use benefits are atypical
or unreasonable. EPA was unable to estimate monetized nonuse benefits for IM&E in all regions using
the benefit transfer approach described in Chapter 8. Therefore, the monetized benefits estimates
presented in this section do not reflect total benefits associated with reducing IM&E at existing units at
regulated facilities, and overall national benefits may accordingly be higher.
10.3 Summary of Baseline Losses and Monetized Benefits for the Final Rule and
Options Considered for Existing Units
Table 10-1 shows that the total annual national value of IM&E losses due to CWIS at existing units of
regulated facilities. Neither the final rule nor other options considered would eliminate all baseline IM&E
losses. EPA presents the baseline values for illustration purposes. EPA did not estimate baseline impacts
related to GHG emissions or associated values.
> Discounted at 3 percent, the total value of baseline IM&E losses is $187.1 million per year
including $78.8 million in recreational fishing losses, $8.0 million in commercial fishing losses,
$1.2 million in T&E species losses, and $99.1 million in forgone nonuse benefits. The total value
58 The lower estimates of value presented in this chapter are measured by the sum of the 5 th percentile lower bound estimates
of recreational values plus the mean value estimates for all other categories of value. The higher estimates of value presented
in this chapter are measured by the sum of the 95th percentile upper bound estimates of recreational values plus the mean
value estimates for all other categories of value.
May 2014
10-1
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 10: Summary for Existing Units
of these fishery losses ranges from $151.5 million and $256.2 million based on the 5th percentile
lower bound and 95th percentile upper bound for recreational values, respectively.
> Discounted at 7 percent, the total value of baseline IM&E losses is $177.3 million per year
including $72.0 million in recreational fishing losses, $7.2 million in commercial fishing losses,
$1.1 million in T&E species losses, and $96.9 million in forgone nonuse benefits. The total value
of these fishery losses ranges from $144.7 million and $240.6 million based on the 5th percentile
lower bound and 95th percentile upper bound for recreational values, respectively.
More detailed discussions of the valuation of impacts under the baseline conditions in each region are
provided in Chapters 5 through 8.
Table 10-2, Table 10-3, and Table 10-4 present EPA's estimates of benefits of reducing IM&E under the
final rule and each of the regulatory options EPA considered for existing units (2011$, discounted at 3
percent and 7 percent). Table 10-5 provides a summary of benefits including the avoided SCC. Monetized
benefits of reductions in IM&E and reduction in GHG emissions based on 3 percent average SCC values,
evaluated at a 3 percent discount rate, are as follows:
> Proposal Option 4 results in benefits of $31.0 million per year, with estimates based on the 5th
percentile lower bound and 95th percentile upper bound for recreational values, totaling $22.8
million and $47.6 million.
> The final rule results in benefits of $33.0 million per year, with estimates based on the 5th
percentile lower bound and 95th percentile upper bound for recreational values, totaling $24.1
million and $50.6 million.
> Proposal Option 2 results in benefits of -$1,542.6 million per year, with estimates based on the
5th percentile lower bound and 95th percentile upper bound for recreational values, totaling -
$l,562.2million and -$1,504.5 million.
Evaluated at a 7 percent discount rate, the monetized benefits of the regulatory analysis options are
somewhat smaller for Proposal Option 4 and the final rule, and greater for Proposal Option 2:
> Proposal Option 4 results in benefits of $27.2 million per year, with estimates based on the 5th
percentile lower bound and 95th percentile upper bound for recreational values, totaling $21.1
million and $39.5 million.
> The final rule results in benefits of $28.7 million per year, with estimates based on the 5th
percentile lower bound and 95th percentile upper bound for recreational values, totaling $22.2
million and $41.8 million.
> Proposal Option 2 results in benefits of -$1,148.2 million per year, with estimates based on the
5th percentile lower bound and 95th percentile upper bound for recreational values, totaling -
$1,161.7 million and -$1,122.0 million.
More detailed discussions of benefits under each option are provided in Chapters 5 through 9.
May 2014
10-2
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 10: Summary for Existing Units
Table 10-1: Summary of Annualized Benefits from the Elimination of Baseline IM&E at Existing Units of Regulated Facilities
(2011$, millions)3
Recreational Fishing Benefits
Commercial
T&E
Nonuse
Benefits
Total Benefitsb
Region
Low
Mean
High
Fishing
Benefits0
Species
Benefits d'e
Low
Mean
High
3% Discount Rate
California
$2.4
$4.0
$6.8
$1.7
-
-
$4.1
$5.7
$8.5
North Atlantic
$1.7
$2.7
$4.4
$0.4
-
$20.2
$22.3
$23.3
$25.0
Mid-Atlantic
$9.7
$16.2
$28.3
$2.2
-
$78.9
$90.7
$97.3
$109.4
South Atlantic
$0.2
$0 3
$0.4
$0.0
-
-
$0.2
$0.3
$0.4
liulf of Mexico
$6.5
$9.6
$14.8
$3.4
-
-
$9.9
$no
$18.2
Great Lakes
$7.3
$13.8
$26.3
$0.2
-
-
$7.5
$14.1
$26.6
Inland
$15.5
$32.1
$66.9
-
$1.2
-
$16.7
$33.3
$68.1
Total
$43.2
$78.8
$147.9
$8.0
$1.2
$99.1
$151.5
$187.1
$256.2
7% Discount Rate
California
$2.2
$3.6
$6.1
$1.5
-
-
$3.7
$5.1
$7.6
North Atlantic
$1.5
$2.4
$3.9
$0.4
-
$19.8
$21.6
$22.6
$24.0
Mid-Atlantic
$8.6
$14.5
$25.3
$1.9
-
$77.2
$87.8
$93.6
$104.5
South Atlantic
$0.2
$0 3
$0.3
$0.0
-
-
$0.2
$0.3
$0.4
Gulf of Mexico
$6.0
$8.8
$13.6
$3.2
-
-
$9.1
$12.0
$16.8
Great Lakes
$6.7
$12.8
$24.3
$0.2
-
-
$7.0
$13.0
$24.5
Inland
$14.3
$29.6
$61.7
-
$1.1
-
$15.4
$30.7
$62.8
Total
$39.5
$72.0
$135.3
$7.2
$1.1
$96.9
$144.7
$177.3
$240.6
= not estimated
a All benefits presented in this table are annualized, i.e., represent the sum of the discounted stream of benefits annualized over 51 years (2014 to 2064). See Appendix D for detail.
b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value per fish predicted by the
meta-analysis. Commercial fishing benefits are computed based on a
region-and species-specific range of gross revenue, as
explained in Chapter 6 of this report. EPA estimated
recreational use benefits for some T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commercial fishing benefits
and T&E species benefits are added to the respective low, mean, and high values for recreational fishing benefits.
c No significant commercial fishing takes place in the Inland region. Thus, this region is excluded from the commercial fishing analysis.
11 Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon). See Chapter 5 of this report
for more detail on EPA's analysis of T&E benefits.
e Zeros represent values less than 1,000.
Source: U.S. EPA analysis for this report.
May 2014
10-3
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 10: Summary for Existing Units
Table 10-2: Summary of Annualized Benefits Associated with IM&E Reductions under Proposal Option 4 (2011$, millions)3
Region
Recreational Fishing Benefits
Commercial
Fishing
Benefits0
T&E
Species
Benefits d'e
Nonuse
Benefits
Total Benefitsb
Low
Mean
High
Low
Mean
High
3% Discount Rate
California
$0.0
$0.1
$0.1
$0.0
-
-
$0.0
$0.1
$0.1
North Atlantic
$0.0
$0.0
$0.0
$0.0
-
$0.1
$0.1
$0.1
$0.1
Mid-Atlantic
$0.5
$1.0
$2.0
$0.2
-
$0.2
$1.0
$1.5
$2.5
South Atlantic
$0.0
$0.0
$0.0
$0.0
-
-
$0.0
$0.0
$0.0
Gulf of Mexico
$1.3
$2.2
$3.9
$0.5
-
-
$1.8
$2.7
$4.4
Great Lakes
$3.4
$6.5
$12.4
$0.1
-
-
J'6
$6.6
$12.5
Inland
$3.5
$7.3
$15.2
-
$0.4
-
$3.9
$7.7
$15.6
Total
$8.8
$17.1
$33.6
$0.9
$0.4
$0.3
$10.4
$18.7
$35.2
7% Discount Rate
California
$0.0
$0.1
$0.1
$0.0
-
-
$0.0
$0.1
$0.1
North Atlantic
$0.0
$0.0
$0.0
$0.0
-
$0.1
$0.1
$0.1
$0.1
Mid-Atlantic
$0.4
$0.7
$1.4
$0.2
-
$0.2
$0.8
$1.1
$1.8
South Atlantic
$0.0
$0.0
$0.0
$0.0
-
-
$0.0
$0.0
$0.0
liulf of Mexico
$0.9
$1.6
$2.8
$0.4
-
-
$1.3
$1.9
$3.2
Great Lakes
$2.6
| oc
1 -r
1 ^
$9.2
$0.1
-
-
$2.7
$4.9
$9.3
Inland
$2.6
$5.4
$11.4
-
$0.3
-
$2.9
$5.7
$11.7
Total
$6.5
$12.6
$24.9
$0.7
$0.3
$0.3
$7.7
$13.8
$26.1
= not estimated
a All benefits presented in this table are annualized, i.e., represent the sum of the discounted stream of benefits annualized over 51 years (2014 to 2064). See Appendix D for detail.
b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value per fish predicted by the
meta-analysis. Commercial fishing benefits are computed based on a region-and species-specific range of gross revenue, as explained in Chapter 6 of this report. EPA estimated
recreational use benefits for some T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commercial fishing benefits
and T&E species benefits are added to the respective low, mean, and high values for recreational fishing benefits.
c No significant commercial fishing takes place in the Inland region. Thus, this region is excluded from the commercial fishing analysis.
11 Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon). See Chapter 5 of this report
for more detail on EPA's analysis of T&E benefits.
e Zeros represent values less than 1,000.
Source: U.S. EPA analysis for this report.
May 2014
10-4
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 10: Summary for Existing Units
Table 10-3: Summary of Annualized Benefits Associated with IM&E Reductions under the Final Rule for Existing Units (2011$,
millions)3
Recreational Fishing Benefits
Commercial
T&E
Nonuse
Benefits
Total Benefitsb
Region
Low
Mean
High
Fishing
Benefits0
Species
Benefits d'e
Low
Mean
High
3% Discount Rate
California
$0.0
$0.1
$0.1
$0.0
-
-
$0.0
$0.1
$0.1
North Atlantic
$0.0
$0.0
$0.0
$0.0
-
$0.2
$0.2
$0.2
$0.2
Mid-Atlantic
$0.6
$1.1
$2.1
$0.3
-
$0.8
$1.6
$2.1
$3.2
South Atlantic
$0.0
$0.0
$0.0
$0.0
-
-
$0.0
$0.0
$0.1
liulf of Mexico
$1.3
$2 3
$4.1
$0.5
-
-
$1.8
$2.8
$4.6
Great Lakes
$3.8
$7.2
$13.6
$0.1
-
-
$3.9
$7.3
$13.8
Inland
$3.7
$7.6
$15.9
-
$0.4
-
$4.1
$8.0
$16.3
Total
$9.4
$18.2
$35.9
$0.9
$0.4
$1.0
$11.8
$20.6
$38.3
7% Discount Rate
California
$0.0
$0.1
$0.1
$0.0
-
-
$0.0
$0.1
$0.1
North Atlantic
$0.0
$0.0
$0.0
$0.0
-
$0.2
$0.2
$0.2
$0.2
Mid-Atlantic
$0.4
$0.8
$1.5
$0.2
-
$0.7
$1.2
$1.6
$2.3
South Atlantic
$0.0
$0.0
$0.0
$0.0
-
-
$0.0
$0.0
$0.0
Gulf of Mexico
$0.9
$1.6
$2.9
$0.4
-
-
$1.3
$2.0
$3.3
Great Lakes
$2.8
$5.3
$10.1
$0.1
-
-
$2.9
$5.4
$10.2
Inland
$2.7
$5.7
$11.9
-
$0.3
-
$3.1
$6.0
$12.2
Total
$7.0
$13.5
$26.6
$0.7
$0.3
$0.8
$8.8
$15.3
$28.4
= not estimated
a All benefits presented in this table are annualized, i.e., represent the sum of the discounted stream of benefits annualized over 51 years (2014 to 2064). See Appendix D for detail.
b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value per fish predicted by the
meta-analysis. Commercial fishing benefits are computed based on a region-and species-specific range of gross revenue, as explained in Chapter 6 of this report. EPA estimated
recreational use benefits for some T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commercial fishing benefits
and T&E species benefits are added to the respective low, mean, and high values for recreational fishing benefits.
c No significant commercial fishing takes place in the Inland region. Thus, this region is excluded from the commercial fishing analysis.
11 Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon). See Chapter 5 of this report
for more detail on EPA's analysis of T&E benefits.
e Zeros represent values less than 1,000.
Source: U.S. EPA analysis for this report.
May 2014
10-5
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 10: Summary for Existing Units
Table 10-4: Summary of Annualized Benefits Associated with IM&E Reductions under Proposal Option 2 (2011$, millions)3
Region
Recreational Fishing Benefits
Commercial
Fishing
Benefits0
T&E
Species
Benefits de
Nonuse
Benefits
Total Benefitsb
Low
Mean
High
Low
Mean
High
3% Discount Rate
California
$0.9
$1.5
$2.6
$0.7
-
-
$1.6
$2.2
$3.2
North Atlantic
$0.9
$1.4
$2.2
$0.2
-
$10.4
$11.5
$12.0
$12.9
Mid-Atlantic
$5.1
$8.6
$15.1
$1.2
-
$40.7
$47.0
$50.5
$57.0
South Atlantic
$0.1
$0.2
$0.2
$0.0
-
-
$0.1
$0.2
$0.2
Gulf of Mexico
$3.4
$5.1
$8.1
$1.7
-
-
$5.1
| OC
! o
! ^
$9.8
Great Lakes
$4.7
$8.9
$17.0
$0.2
-
-
$4.9
$9.1
$17.2
Inland
$8.3
$17.2
$35.9
-
$0.7
-
$9.0
$17.9
$36.5
Total
$23.4
$43.0
$81.1
$3.9
$0.7
$51.1
$79.1
$98.7
$136.8
7% Discount Rate
California
$0.6
$1.0
$1.7
$0.4
-
-
$1.0
$1.4
$2.1
North Atlantic
$0.6
$0.9
$1.5
$0.1
-
$7.6
$8.3
$8.7
$9.2
Mid-Atlantic
$3 3
$5.5
$9.6
$0.8
-
$29.7
$33.7
$36.0
$40.1
South Atlantic
$0.1
$0.1
$0.2
$0.0
-
-
$0.1
$0.1
$0.2
liulf of Mexico
$2.5
$3 8
$6.0
$1.3
-
-
$3 7
$5.0
$7.2
Great Lakes
$3.4
$6.4
$12.1
$0.1
-
-
$3.5
$6.5
$12.2
Inland
$5.7
$11.9
$24.8
-
$0.5
-
$6.2
$12.3
$25.2
Total
$16.1
$29.5
$55.8
$2.7
$0.5
$37.3
$56.6
$70.0
$96.3
= not estimated
a All benefits presented in this table are annualized, i.e., represent the sum of the discounted stream of benefits annualized over 51 years (2014 to 2064). See Appendix D for detail.
b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value per fish predicted by the
meta-analysis. Commercial fishing benefits are computed based on a region-and species-specific range of gross revenue, as explained in Chapter 6 of this report. EPA estimated
recreational use benefits for some T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commercial fishing benefits
and T&E species benefits are added to the respective low, mean, and high values for recreational fishing benefits.
c No significant commercial fishing takes place in the Inland region. Thus, this region is excluded from the commercial fishing analysis.
11 Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon). See Chapter 5 of this report
for more detail on EPA's analysis of T&E benefits.
e Zeros represent values less than 1,000.
Source: U.S. EPA analysis for this report.
May 2014
10-6
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 10: Summary for Existing Units
Table 10-5: Summary of Annualized Benefits by Regulatory Option for Existing Units (2011$, millions)3
Regulatory
Option
Recreational Fishing Benefits
Commercial
Fishing
Benefits0
T&E Species
Benefits"'
Nonuse
Benefits
scce
Total Benefits
Low
Mean
High
Low
Mean
High
3% Discount Rate
Proposal Option 4
OO
OO
$17.1
$33.6
$0.9
$0.4
$0.3
$12.4
$22.8
$31.0
$47.6
Filial Rule
$9.4
$18.2
$35.9
$0.9
$0.4
$1.0
$12.4
$24.1
$33.0
$50.6
Proposal Option 2
$23.4
$43.0
$81.1
$3.9
$0.7
$51.1
-$1,641.3
-$1,562.2
-$1,542.6
-$1,504.5
7% Discount Rate
Proposal Option 4
$6.5
$12.6
$24.9
$0.7
$0.3
$0.3
$13.4
$21.1
$27.2
$39.5
Final Rule
$7.0
$13.5
$26.6
$0.7
$0.3
$0.8
$13.4
$22.2
$28.7
$41.8
Proposal Option 2
$16.1
$29.5
$55.8
$2.7
$0.5
$37.3
-$1,218.2
-$1,161.7
-$1,148.2
-$1,122.0
a All benefits presented in this table are annualized, i.e., represent the sum of the discounted stream of benefits annualized over 51 years (2014 to 2064). See Appendix D for detail.
b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value per fish predicted by the meta-
analysis. Commercial fishing benefits are computed based on a region- and species-specific range of gross revenue, as explained in Chapter 6 of this report. EPA estimated recreational use
benefits for some T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commercial fishing benefits and T&E species benefits
are added to the respective low, mean, and high values for recreational fishing benefits.
c No significant commercial fishing takes place in the Inland region. Thus, this region is excluded from the commercial fishing analysis.
11 Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon).
See Chapter 5 of this report for more detail on EPA's analysis of T&E benefits.
e SCC results presented here are based on 3 percent average SCC values.
Source: U.S. EPA analysis for this report
May 2014
10-7
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 11: Stated Preference Survey
11 Stated Preference Survey
11.1 Introduction
EPA developed a stated preference survey to estimate total values (use plus nonuse) for
improvements to fishery resources and ecosystems affected by IM&E from regulated facilities.59
Understanding total public WTP for resulting changes in fishery resources, including the more
difficult to estimate nonuse values, is necessary to determine the full range of benefits associated
with reductions in IM&E, and simplifies the determination of whether the benefits of government
action to reduce IM&E at existing facilities are commensurate with the costs of such actions.
Because potential nonuse values may be substantial, failure to recognize such values may lead to
improper inferences regarding benefits and costs, and an inefficient allocation of society's
resources. As discussed in Chapter 8, EPA was able to generate only a partial estimate of nonuse
benefits using benefit transfer with existing SP data. Moreover, estimates from high quality
primary valuation studies are generally considered superior to those from benefit transfer
(Johnston & Rosenberger 2010) because primary studies are designed for the specific context of
the policy case, whereas transferring results from other studies may require assumptions to
facilitate transfer that may not be completely accurate. EPA developed and implemented the SP
survey to fill this gap by providing data which could be used to estimate total benefits for all U.S.
regions.
EPA plans to obtain SAB review of the SP survey EPA conducted. The SAB review would be in
addition to the external peer review EPA already conducted on the survey. SAB review will
provide high caliber, independent professional judgment concerning the quality of the survey
done to date, including possible improvements EPA could make to the analysis. EPA also plans
to seek SAB input on whether, how and in what circumstances this or similar surveys could be
used as support for national rulemakings or 316(b) NPDES permitting. EPA expects that while
this process will add time (it may take a year or more), given the importance of this issue for the
evaluation of ecological benefits generally, it is worth taking the time to seek this additional
input. Given the planned SAB review, using the SP survey results prior to completion of the
review would be premature. EPA is committed to working with the states to support their site-
specific permitting decisions with the benefit of the SAB review once it is completed.
EPA has not accounted for values estimated from the survey in the comparison of monetized
costs and benefits. This chapter describes the design of the SP survey and presents current, but
not necessarily final, model estimation results. EPA also describes a method for monetizing
benefits for the final rule and presents a preliminary estimate of benefits for the final rule and
options considered to illustrate the potential magnitude of regulatory benefits and demonstrate
progress towards this effort. Discussion of peer reviewer comments related to their confidence in
the study results and limitations for policy analysis is presented in Section 11.10.
59 As discussed in Chapter 8, nonuse values are values people may hold for an environmental improvement that are
not associated with use (e.g., recreation) of the resource.
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11.2 Survey Design
SP surveys, in general, ask questions that elicit individuals" stated values for carefully specified
changes in an environmental amenity. This value is typically estimated in terms of WTP, defined
as the maximum amount of money (or some other commodity) that an individual or household
would be willing to give up in exchange for a specified environmental change, rather than go
without that change. EPA designed the SP survey as a choice experiment. Choice experiments,
also called choice models, are an SP technique in which individuals" values are estimated based
on their choices over a set of hypothetical but realistic multi-attribute policy options designed to
mimic the consumer decision-making that occurs in actual markets, and span the range of
possible policy options.6" Choice experiments have been applied in many past studies to assess
WTP for ecological resource improvements, which is also the context of the main improvement
in the 316(b) policy case (e.g., Bennett and Blarney 2001; Hanley et al. 2006; Hoehn et al. 2004;
Johnston et al. 2002a; Johnston et al. 201 lb; Johnston et al. 2012; Milon and Scrogin 2006;
Morrison et al. 2002; Morrison and Bennett 2004; Opaluch et al. 1999).
Advantages of these choice-based methods include similarity to familiar referenda or market
choice contexts, in which individuals choose among alternative bundles of attributes or
commodities (for example, attributes of consumer electronics) at different costs (Freeman 2003).
Among other advantages, such methods are intended to reduce strategic and other survey biases
that can be associated with alternative ways of using survey questions to elicit values, versus
assessing WTP through market transactions or referenda. For example, some types of SP surveys
ask respondents to express their WTP using open-ended questions, payment cards, or bidding
games. Increasingly, however, these types of SP surveys have been replaced in the literature by
choice-based methods.61
Choice experiments also allow survey respondents to express WTP for a wide range of different
potential outcomes, differentiated by their attributes. This enables EPA to isolate the marginal
effects of different potential policy outcomes on stated choices and hence, on estimated WTP.
EPA can thereby estimate benefits for a wider range of potential policy outcomes than would be
possible with alternative SP methods. This is a primary factor distinguishing choice experiments
from older forms of SP analysis, in which stated WTP is typically contingent upon a single
specification of ecological and other policy effects.
11.2.1 Survey Format
EPA followed established choice experiment methodology in the developing the format of the
316(b) SP survey (Adamowicz et al. 1998; Bateman et al. 2002; Bennett and Blarney 2001;
Louviere et al. 2000). Respondents are presented with two alternative hypothetical policy options
00 In addition to choice experiments, stated preference techniques include as contingent valuation (CV). CV surveys
typically ask respondents, "What are you willing to pay?" for a particular environmental improvement, or in a
dichotomous choice form as "are you willing to pay $X?" for a particular environmental improvement. In general,
CV surveys focus on a comparison between the status quo and a particular environmental improvement (akin to a
one-time offer). This is different from the consumer decision-making that occurs in actual markets and involves
comparing status quo to multiple environmental outcomes. Therefore, EPA relied on the choice experiment
technique that mimics common market situations in its study design.
01 Choice-based methods are also increasingly employed in the marketing research literature to analyze consumer
preferences. In particular, choice based experiments are a popular in modeling brand choice (Erdem and Keane
1996) and demand for new products (Brownstone and Train 1996).
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described by multiple attributes. They are asked to choose (or vote for) the policy they prefer,
much as one would choose a preferred option in a public referendum. Respondents may also
choose to reject both policies and retain the status quo. The underpinning theoretical model is
adapted from a standard random utility specification in which household h chooses among three
choice options (J=A,B,N), including two multi-attribute policy options (A, B) and a fixed "No
Policy" (the status quo) (N) that includes no policy changes and zero cost to the household. Each
choice option reflects a hypothetical but feasible outcome under various 316(b) regulatory
alternatives.
The effects of the policy options are described in terms of a household cost and four
environmental endpoints, or attributes: (a) commercial fish populations, (b) fish populations (all
fish), (c) fish saved per year, and (d) condition of aquatic ecosystems. The definition of each
attribute is presented in Table 11-1. Ecological attributes are expressed relative to upper and
lower reference conditions; i.e., best and worst possible conditions of the attribute, as defined in
survey informational materials. Respondents were asked to evaluate changes in fish saved per
year as a percentage of current estimated mortality, but those changes were also illustrated in
terms of numbers of A1E fish.62 Relative scores represent percent progress towards the upper
reference condition (100 percent), starting from the lower reference condition (0 percent), both
keyed to readily understood conditions. Presentation of all ecological attributes was informed by
input from focus groups and cognitive interviews (Johnston et al. 1995; Kaplowitz et al. 2004)
used to pretest the survey instrument.
Values for "fish saved" in the referendum questions are based on EPA's estimate of A1E losses
due to CWIS at baseline. Refer to Chapter 3 for additional description of the A1E metric.
Introductory materials in the survey describe the age classes impacted due to cooling water
intakes and the "fish saved" metric as "young adult fish (the equivalent of one year old)." Pre-
testing during focus groups and cognitive interviews suggested that participants understood the
"fish saved" attribute and the concept of "young fish" as reflecting initial IM&E of eggs and other
juvenile life stages expressed as in terms of the A1E metric. Page three of the survey booklet
includes introductory materials that specify the proportion of "fish saved" that are and are not
commercial or recreational species.
Values are reflected in the survey by individuals' willingness to "vote" for policies that would
result in an increase in their cost of living, in exchange for specified changes in the four
environmental attributes. Other questions in the survey elicit information including whether the
respondent is a user of the affected aquatic resources, household income, and other respondent
demographics.63
62 A1E, in addition to providing a way to standardize organisms lost to IM&E so that it could be compared among
species, years, facilities, and regions, is a convenient way to express losses of all life stages, including fish eggs
and larvae, as numbers of individual age-one equivalent fish.
63 The four environmental attributes were designed based on the Johnston et al. (201 la; 201 lb; 2012) Bioindicator-
Based Stated Preference Valuation (BSPV) method which was developed to promote ecological clarity and closer
integration of ecological and economic information within SP studies. This methodology was developed in part to
address the EPA Science Advisory Board's call, in its May 2009 report, Valuing the Protection of Ecological
Systems and Services: A Report of the EPA Science Advisory Board (USEPA 2009b), for improved quantitative
linkages between ecological services and economic valuation of those services.
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Table 11-1: Definitions of Policy Attributes and Baseline (No Policy) Values
Attribute
Definition
Commercial Fish
Populations
A score between 0 and 100 percent showing the overall health of commercial and
recreational fishing populations. High scores mean more fish and greater fishing potential.
A score of 100 means that these fish populations are at a size that maximizes long-term
harvest: 0 means no harvest.
Fish Populations
(All Fish)
A score between 0 and 100 percent showing the estimated size of all fish populations
compared to natural levels without human influence. A score of 100 means that
populations are the largest natural size possible; 0 means no fish.
Fish Saved (per
Year)
A score between 0 and 100 percent showing the reduction in young fish lost compared to
current levels. A score of 100 would mean that no fish are lost in cooling water intakes (all
fish would be saved because of the new policy).
Condition of
Aquatic
Ecosystems
A score between 0 and 100 percent showing the ecological condition of affected areas,
compared to the most natural waters in the region. The score is determined by many
factors including water quality and temperature, the health of aquatic species, and habitat
conditions.
Cost per Year
How much the policy will cost your household, in unavoidable ongoing price increases for
products and services you buy, including electricity and common household products.
Source: U.S. EPA analysis for this report
11.2.2 Experimental Design
The experimental design is the plan for varying attribute levels across questions within a survey
and across survey versions, so that aggregated responses will provide enough data for efficient
estimation of model parameters and WTP. Respondents were presented with three separate policy
questions in the survey, each with a specific combination of policy options. The experimental
design specifies how these attribute levels were "mixed and matched" within choice questions,
thereby developing an empirical data framework with appropriate statistical properties to allow
for analysis of respondent's choices (Louviere et al. 2000). It generates multiple unique
combinations of policy options for different respondents to compare.
Table 11-2 presents the set of attribute levels that are used across the option pairs. Following
guidance from the literature, EPA designed the attribute levels to illustrate realistic policy
scenarios that "span the range over which we expect respondents to have preferences, and/or are
practically achievable" (Bateman et al. 2002, p. 259; USEPA 2012a; USEPA 2012b).
In interpreting the results, it is useful to keep in mind that three of the attributes spanned a
relatively narrow range of percentage values reflecting realistic ecological expectations (e.g.,
commercial fish populations differing by no more than six percentage points from the baseline),
while the "fish saved per year" attribute, which was ultimately used to estimate household WTP
for the policy options, spanned a much larger range (i.e., up to 95 percentage points). This reflects
the expected range of potential reductions based on the performance of the technologies consider
for the regulatory options. Given this realistic distinction in attribute spread, EPA expects that the
WTP per percentage point will be lower for fish saved than for other attributes because
respondents "see" most of the possible ranges of fish saved. Allowing the range of variables to
vary according to realistic ecological and technological expectations is recommended practice in
SP design (Bateman et al. 2002).
EPA applied a fractional factorial experimental design representing a subset of all possible
combinations of environmental attributes and household cost. This allows efficient estimation of
particular effects of interest with a relatively small number of choice questions (Louviere et al.
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2000), thereby reducing the cognitive burden faced by respondents (i.e., by reducing the number
of questions that each respondent must answer; Holmes and Adamowicz 2003). EPA generated
the design using a D-efficiency criterion for main effects estimation (Kuhfeld and Tobias 2005;
Kuhfeld 2010). This design enables model coefficients, and hence, estimated WTP, to be
estimated with greater precision, i.e., lower standard errors or variability, for any given number of
observations. It also minimizes correlation between attributes across survey questions (i.e.,
attributes do not "move together" across different survey questions), so that the unique effect of
each attribute on respondents' choices, and ultimately, values, can be isolated.64
The experimental design for the 316(b) survey is characterized by 72 unique Option A vs. Option
B pairs, each corresponding to a choice question defined by an orthogonal (independent) array of
attribute levels for the two policy options. It is standard practice to include more than one choice
question in each survey, thus increasing the information obtained from each respondent (Layton
2000; Poe et al. 1997). EPA randomly assigned the 72 option pairs to 24 distinct versions for each
of the four regional surveys and the national survey, with three option pairs (i.e., choice
questions) per survey booklet. See the ICR supporting statement (USEPA 2011C) for additional
detail on the experimental design.
64 EPA removed dominated pairs where one option is superior to the other in all attributes. Allowing such pairs
would effectively limit respondents to selecting between the dominant choice option and the No Policy option.
Focus groups showed that respondents react negatively and often protest when offered dominated pairs. Given that
such choices provide negligible statistical information compared to choices involving non-dominated pairs, they
are typically avoided in choice experiment statistical designs.
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Table 11-2: Attribute Levels Assigned Across Policy Options and Survey Versions
Attribute
Baseline (No
Policy)3
Max
Change
Assigned
Attribute Levels Assigned to Option A vs. Option B Pairs
1
2
3
4
5
6
Commercial Fish Populations (Score showing the overall health of commercial and recreational fish populations)
Northeast
42%
6%
43%
45%
48%
-
-
-
Southeast
39%
6%
40%
42%
45%
-
-
-
Pacific
56%
6%
57%
59%
62%
-
-
-
Inland
39%
6%
40%
42%
45%
-
-
-
National
51%
6%
52%
54%
57%
-
-
-
Fish Populations (all fish) (Score showing the estimated size of all fish populations compared to natural levels
without human influence)
Northeast
26%
4%
27%
28%
30%
-
-
-
Southeast
24%
4%
25%
26%
28%
-
-
-
Pacific
32%
4%
33%
34%
36%
-
-
-
Inland
33%
4%
34%
35%
37%
-
-
-
National
30%
4%
31%
32%
34%
-
-
-
Fish Saved per Year (Score showing the reduction in young fish lost compared to current levels)
Northeast
0%
95%
5%
50%
95%
-
-
-
Southeast
0%
90%
25%
55%
90%
-
-
-
Pacific
0%
95%
2%
50%
95%
-
-
-
Inland
0%
95%
55%
75%
95%
-
-
-
National
0%
95%
25%
55%
95%
-
-
-
Aquatic Ecosystem Condition (Score showing the ecological condition of affected areas, compared to the most
natural waters in the region)
Northeast
50%
4%
51%
52%
54%
-
-
-
Southeast
68%
4%
69%
70%
12%
-
-
-
Pacific
51%
4%
52%
53%
55%
-
-
-
Inland
42%
4%
43%
44%
46%
-
-
-
National
53%
4%
54%
55%
57%
-
-
-
Household Costs (Hie increase in annual household cost, in unavoidable price increases)
Northeast
$0
$72
$12
$24
$36
$48
$60
$72
Southeast
$0
$72
$12
$24
$36
$48
$60
$72
Pacific
$0
$72
$12
$24
$36
$48
$60
$72
Inland
$0
$72
$12
$24
$36
$48
$60
$72
National
$0
$72
$12
$24
$36
$48
$60
$72
a Each question includes a "no policy" option, characterized by the baseline levels for each attribute and a household cost of $0.
Source: U.S. EPA analysis for this report
11.2.3 Pre-Tests
Following recommended methods for SP survey design, EPA used focus groups and cognitive
interviews to test wording and attribute selection and ensure that respondents understand and are
not cognitively burdened by the question format (cf. Arrow et al. 1993; Bateman et al. 2002;
Bennett and Blarney 2001; Kaplowitz et al. 2004; Powe 2007). The survey instrument was pre-
tested extensively in six focus groups, with eight to ten participants each, and a set of eight one-
on-one cognitive interviews (USEPA 2010d). Each cognitive interview included only one
participant. This allowed in-depth exploration of the cognitive processes respondents used to
answer survey questions, without the potential for interpersonal dynamics to sway respondents"
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comments (Kaplowitz et al. 2004). These focus groups and cognitive interviews were in addition
to ten focus groups and two series of cognitive interviews that were conducted previously by EPA
in 2004 and 2005 to test an earlier version of the survey developed in anticipation of the Phase III
benefits analysis. Focus groups and cognitive interviews also included questions following the
verbal protocol format suggested by Schkade and Payne (1994), in which respondents were asked
to talk through the process used to answer choice questions. Within focus group and cognitive
interviews, the moderator first asked the participants to complete a draft survey questionnaire.
The moderator then led a general conversation which led the group/individual through a series of
debriefing questions. During debriefing, the moderator asked focus group and cognitive interview
participants about their reactions to the survey format and content, their interpretations of survey
materials (including questions and the information provided), whether the survey questions were
clear, whether the background information presented in the survey or introductory materials was
sufficient, whether respondents felt like the questions were leading, what went through
participants' minds when they read survey information and questions, and response motivations.
Debriefing questions also explored whether responses were influenced by hypothetical, strategic,
symbolic and other biases noted in the stated preference literature.
The participants' comments and feedback provided important information on such concerns as
whether (1) questions and survey information were readily understood, (2) respondents were
interpreting questions similarly to how EPA interprets them, (3) responses or survey
interpretations showed any evidence of heuristics or survey biases, including hypothetical bias,
(4) respondents were addressing choice questions in a manner commensurate with utility
maximization and neoclassical WTP estimation, and (5) respondents were following instructions
provided in the survey instrument and responding to questions accordingly. Focus group
participants' responses to the survey choice questions could not be included in model estimation
because the draft surveys completed during pre-testing represent evolving versions and differed
somewhat from the final survey. EPA modified the survey several times based on the results of
these pre-tests to help minimize potential biases and ensure shared and accurate interpretation of
survey language by the respondents. The amount of pre-testing conducted for SP surveys varies
within the literature and tends to be related to the complexity of the survey instrument. However,
the amount of time and number of focus groups the Agency used is significantly greater than
many academic studies and matches the practice in developing SP surveys for natural resource
damage assessments.
11.3 Sampling Frame
The sampling frame is the population from which the potential respondents are selected, in this
case, at random. EPA designed the 316(b) SP study as a household mail survey, because the
household is the fundamental economic decision-making unit for WTP studies. The mail survey
approach avoids potential sampling biases in telephone surveys associated with the incomplete
coverage of landline and cellphone databases. The mail address sample of households in the
continental U.S. was from drawn from a database which covers 97 percent of residences in the
United States including city-style addresses and PO boxes, and covers single-unit, multi-unit, and
other types of housing structures.
EPA stratified households based on the geographic boundaries of four regions: Northeast,
Southeast, Inland, and Pacific. The SP regions are based on state boundaries and include both
coastal and freshwater facilities in the Northeast, Southeast, and Pacific regions. These regions
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differ from the 316(b) benefits regions used elsewhere in this Benefits Analysis which separate
coastal and freshwater resources. During survey pretesting, EPA found that respondents more
easily understood regional boundaries based on states than boundaries that distinguished between
coastal and freshwater facilities.
Table 11-3 presents the States included in each SP region, the total number of households in each
region, the target number of completed surveys, and the number of surveyed households for each
survey region. EPA developed target sample sizes for each region to provide statistically robust
results while minimizing the cost and burden of the survey to individual respondents.65 The target
sample sizes refer to completed mail surveys. A larger number of households must be mailed
surveys because only a portion of households that receive a survey complete and return it.
EPA selected a total target sample of 2,000 completed surveys across all four regional surveys to
provide estimates of population percentages with a margin of error ranging from 3.6 to 5.8
percentage points at the 95 percent confidence level.66 These 2,000 surveys were allocated across
the four regions based on the number of households in each region relative to the total number of
household in the continental United States. In addition, a minimum number of completed surveys
were required for each region to enable model estimation. Monte Carlo experiments indicate that
approximately 6 to 12 completed responses are required for each profile (unique set of choice
options) in order to achieve large sample statistical properties for choice experiments (Louviere et
al. 2000, p. 104, citing Bunch and Batsell 1989). As described previously, the experimental
design includes 72 option profiles. Following this guidance, the experiment design requires 12
completed surveys for each of the 72 profiles, for a total of 864 profile responses per region
(72/12=864). A minimum of 288 completed surveys were hence required for each region
because each survey version includes three profiles (864-^3=288).
The allocation of the 2,000 completed surveys across the four regions resulted in target sample
sizes of 417 forthe Northeast region, 562 for the Southeast region, 289 forthe Pacific region, and
732 for the Inland region. EPA also conducted a national mail survey with a target sample size of
288 completed surveys. EPA mailed the survey to 7,840 households in total, anticipating a
response rate of 30 percent. EPA assumed that it would take respondents an average of 30
minutes to complete and mail back the questionnaire.
65 EPA included three choice questions within each survey, to increase information obtained from each respondent.
It is standard practice within choice experiment and dichotomous choice contingent valuation surveys to include
more than one choice question in each survey (Layton 2000; Poe et al. 1997). Including more than three choice
questions may have negatively affected the response rate by increasing burden on respondents and including fewer
would have increased survey costs by requiring additional households to be sampled.
66 Margin of error was calculated assuming that the population percentage selecting a specific answer (e.g., "yes") in
a binary question is 50 percent (i.e., worst case scenario). This is the worst case scenario because it indicates that
there is disagreement among people regarding the correct response (i.e., 50 percent select "yes" and 50 percent
select "no") and the standard error of the proportion is large (Orme 2010). The range of the margin of error (3.6 to
5.8 percent) is based on the sample sizes for each region. For example, the sample percentage selecting a specific
response to a binary question based on a sample of 732 households has a margin of error of plus or minus 3.6
percent at a 95 percent confidence level whereas the sample percentage selecting a specific response based on a
sample of 288 households will have a margin of error of plus or minus 5.8 percent.
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Table 11-3: Target Sample Sizes and Number of Mailed Surveys by Survey Region
Survey Region
State Included
Number of
Households3
Target Sample
Sizebc
Number of
Surveyed
Households'*
Northeast
CT, DC, DE, MA, MD, ME,
NH, N.T, NY, PA, RI, VT
23,281,296
417
1,440
Southeast
AL, FL, GA, LA, MS,NC,
SC. TX. VA
31,378,122
562
1,920
l'ac ilk-
CA.OR. WA
40.852.983
289
1.040
Inland
AR. A/. CO. II). IA. II.. IN.
KS, KY, MI, MN, MO, MT,
ND, NE, NM,NV,
OH,OK,SD,TN, UT, WI,
WV, WY
16,158,206
732
2,480
Total for Regional
Surveys
U.S. (excluding AK and HI)
111,670,607
2,000
6,880
National Survey
U.S. (excluding AK and HI)
111,670,607
288
960
a The number of households in each region was obtained based on the estimated population size and average household size from
the 2006-2008 American Community Survey (U.S. Census Bureau 2009).
b Target sample sizes presented here refer to completed mail surveys.
c The sample is allocated to each region in proportion to the total number of households in that region, with at least 288 completed
surveys required for each region to estimate the main effects and interactions under an experimental design model.
11 The number of intended completed questionnaires for each survey region was rounded up so that the same number of households
received each of the 24 survey versions.
Source: U.S. EPA analysis for this report
EPA used multiple preview and reminder mailings to promote a high response rate and minimize
the potential for non-response bias. This approach follows Dillman et al. (2009), which is among
the most commonly cited sources for survey logistics management. Households were selected
from the U.S. Postal Service Digital Sequence File (DSF) of residences which, in total, covers 97
percent of residences in the United States. EPA also conducted a follow-up study of households
that did not return a completed mail survey to determine whether survey non-respondents are
fundamentally different than survey respondents. The follow-up survey included demographic
and attitudinal questions.
11.4 Mail Survey Responses
Published guidance for SP survey design recommends conducting a pilot study to inform
potential changes to other survey versions (Arrow et al. 1993; Bateman et al. 2002). Following
this guidance, EPA undertook the Northeast region of the survey in advance of the other regions
and national survey, as described in the ICR for the 316(b) SP survey (USEPA 201 lc). After
review of the Northeast survey responses, EPA received approval from the Office of Management
and Budget (OMB) to implement the remaining survey regions (Inland, Southeast, and Pacific)
and the national survey. EPA fielded the remaining survey versions in October 2011. EPA
received a total of 2,313 completed mail surveys. Table 11-4 summarizes the number of
completed surveys received and the response rate (responses as a percentage of mailed surveys
minus undeliverable surveys). The average response rate was 32 percent. This response rate is
comparable to various other recent mail surveys in the SP literature (e.g., Boyle and Ozdemir
2009; Hanley et al. 2006; Johnston and Duke 2009; Johnston and Bergstrom 2011)
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Table 11-4: Completed Survey Received and Response Rates by Survey Version
Survey Region
Households
Surveyed
Completed Surveys
Received
Response Rate3
Northeast
1,440
421
31%
Southeast
1,920
506
29%
Pacific
1.040
311
32%
Inland
2.480
787
35%
National Survey
960
288
34%
Total
7,840
2,313
32%
a The number of undeliverable surveys was subtracted from surveys mailed when calculating the response rate for each
survey region. Undeliverable surveys are those surveys that were returned to sender.
Source: U.S. EPA analysis for this report
Analysis of the survey data across all four regions and the national survey indicates that
respondents appear to have been evaluating tradeoffs between costs and benefits of policy options
presented to them, and that WTP is responsive to scope (i.e., the quantity of environmental
improvements across different attributes). Respondents appear to have understood and
distinguished between different types of outcomes from 316(b) regulation. About 90 percent of
respondents answered the choice experiment questions (questions 4, 5, and 6). Question 8 asked
respondents to rate the statement that the survey material was easy to understand. Only 14 percent
disagreed with that statement (see Figure 11-1). Seventy-one percent of respondents strongly
agreed or agreed when asked in a 5-level Likert scale question whether they were confident in
their responses to the survey questions. The vast majority indicated that they would answer the
same way if parallel questions were asked in a binding referendum, with less than three percent of
respondents indicating otherwise (see Figure 11-2).
About 75 percent of mail survey respondents were under age 65 and the majority of those
completing the survey (63 percent) were male. About 87 percent of respondents selected "white"
for racial category. For additional information on the demographic characteristics of respondents
see EPA's survey analysis memo to the 316(b) rulemaking record (USEPA 2012).
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"Information in the survey was easy for me to
understand"
50%
40%
30%
20%
10%
0%
43.7%
22.4%
9.7%
3.9%
¦
20.3%
Strongly Neutral Strongly Agree
Disagree
Figure 11-1: Summary of Responses to Regarding Respondent
Understanding across All Surveys
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"I feel confident about my answers"
50%
40%
30%
20%
10%
0%
46.5%
26.5%
21.7%
1.2%
4.2%
Strongly
Disagree
Neutral
Strongly Agree
"I would vote the same way in an actual public vote"
50%
40%
30%
20%
10%
0%
45.0%
18.8%
0.9%
1.8%
33.4%
Strongly
Disagree
Neutral
Strongly Agree
Figure 11-2: Summary of Responses Regarding Respondent Confidence
across All Surveys
11.5 Non-Response Study
EPA conducted a follow-up study of households that did not return a completed mail survey to
identify whether survey non-respondents are fundamentally different than survey respondents in
certain attributes. The follow-up study included a set of key attitudinal questions and socio-
demographic variables that are most likely to be associated with WTP for reducing fish mortality
from CWISs and improvements in fish populations and conditions in the affected aquatic
ecosystems. Section 11.5.1 describes the non-response sample and Section 11.5.2 describes
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statistical tests that EPA conducted comparing the main mail survey sample and the non-response
sample.
11.5.1 Non-Response Sample
EPA implemented the follow-up study using two subsamples: the first subsample received a
paper questionnaire via U.S. Postal Service Priority Mail®), and the second subsample was
surveyed by telephone. Both non-response subsamples were asked the same set of attitudinal and
demographic questions. It took participants approximately five minutes to complete the follow-up
study.
EPA's target sample across all regions for the non-response study was 600 completed non-
response surveys. This is the sample size required for a two-sided test showing a difference of 12
percentage points to be rejected with statistical power of 80 percent. In total, EPA planned to
achieve 400 completed surveys in the Priority Mail subsample and 200 completed questionnaires
in the telephone subsample. EPA allocated the initial target non-response completed surveys to
each survey region in proportion to the mail survey sample size of each region. The priority mail
subsample was conducted in advance of the telephone subsample. EPA conducted additional
telephone calls to ensure that it reached targets for the total number of complete non-response
surveys in each region, if the priority mail response fell short of the target. The number of
completed non-response surveys is summarized in Table 11-5 by subsample. Overall response
rates for the non-response study ranged from about 21.5 percent in the Southeast to 29.5 percent
for the national survey.
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Table 11-5: Completed Non-Response Surveys Received and Response Rates by
Survey Region and Survey Mode
Survey Subsample/Survey Region
Sample Size
Completed Surveys
Response Rate
Priority Mail Subsample
Northeast
146
48
32.9%
Southeast
297
71
23.9%
Inland
389
127
32.6%
Pacific
159
58
36.5%
National Survey
146
58
39.7%
Telephone Subsample
Northeast
331
63
19.0%
Southeast
410
81
19.8%
Inland
356
71
19.9%
Pacific
160
20
12.5%
National Survey
125
22
17.6%
Total Non-Response Sample
Northeast3
426
111
26.1%
Southeast
707
152
21.5%
Inland
745
198
26.6%
Pacific
319
78
24.5%
National Survey
271
80
29.5%
a For the Northeast region, EPA included 51 households which did not return the Priority Mail questionnaire within the
telephone subsample in order to achieve the target number of completes. As a result, the total sample size for the
Northeast is less than the sum of the Priority Mail and telephone subsamples.
Source: U.S. EPA analysis for this report
11.5.2 Statistical Testing of Mail Survey and Non-Response Data
EPA compared the respondent and non-respondent samples statistically according to eight
characteristics to evaluate potential for non-response bias:
1. Age : age of the household member completing the survey
2. Gender, gender of the household member completing the survey
3. Education: highest level of education completed by the household member completing
the survey
4. Employment: whether the survey participant is currently employed (yes/no)
5. Hispanic or Latino origin: whether the participant is of Hispanic or Latino ethnicity
(yes/no)
6. Race: racial category of the participant
7. Income: annual household income
8. Importance of protecting aquatic ecosystems: attitudinal question asking the participant
to rate how important he or she considers the protection of aquatic ecosystems.
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Table 11-6 summarizes the characteristics of the respondents to the main surveys and non-
response surveys.
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Table 11-6: Characteristics of the Main and Non-Response Samples by Survey Region3
Statistic
Northeast
Southeast
Inland
Pacific
National Survey
Main
Non-Response
Main
Non-
Response
Main
Non-
Response
Main
Non-
Response
Main
Non-
Response
Age
Average age
54.6
53.7
54.3
56.6
53.7
56.1
52.8
49.7
54.2
53.2
Percent under 65
74.6%
73.9%
74.1%
68.9%
76.3%
67.4%
76.1%
89.6%
72.7%
70.0%
Gender
Percent male respondents
63.9%
44.5%
62.3%
46.7%
64.6%
51.3%
62.7%
55.1%
60.4%
45.6%
Employment
Percent currently employed
63.6%
62.7%
59.2%
57.9%
64.4%
54.4%
65.0%
68.4%
60.2%
57.0%
Percent employed under age
65
76.9%
79.3%
75.0%
79.4%
76.9%
73.8%
80.3%
74.6%
72.5%
72.7%
Educational Attainment b
Bachelor's Degree or
Higher
45.9%
46.4%
44.1%
34.0%
43.1%
30.1%
50.8%
44.2%
46.9%
39.3%
Race and Ethnicity c
Percent white respondents
86.6%
85.7%
82.3%
78.8%
91.0%
93.0%
84.7%
75.7%
83.4%
80.8%
Percent Hispanic or Latino
Origin
5.1%
5.6%
9.9%
9.9%
3.4%
5.2%
13.3%
13.3%
7.0%
11.4%
Total Household Income d
Average
$88,880
$81,480
$75,588
$74,179
$73,567
$59,598
$96,144
$79,306
$79,496
$63,681
Standard Deviation
$69,309
$68,486
$62,618
$66,760
$57,261
$54,966
$71,282
$67,757
$60,972
$57,415
Percent >$60,000
55.7%
49.0%
48.1%
44.8%
48.1%
31.0%
57.2%
50.0%
51.9%
37.5%
Importance of Aquatic Ecosystems e
Average Ranking
4.0
4.0
3.9
4.0
3.8
3.9
4.0
4.1
3.9
3.9
a Respondents who did not answer a given demographic question were excluded when calculating percentages.
b The surveys included six categories for educational attainment: (1) less than high school, (2) high school or equivalent, (3) high school + technical school, (4) one or more years of college, (5)
bachelor's degree, and (6) graduate degree.
c The surveys include six categories for education attainment: (1) American Indian or Alaskan Native, (2) Black or African American, (3) Native Hawaiian or Other Pacific Islander, (4) Asian, (5)
White, and (6) Other. Respondents could select more than one racial category. The "Percent white respondents" presented above includes respondents that selected other racial categories in addition
to white.
11 The survey asked respondents to select one of eight categories for annual household income. The average and standard deviation reported here were calculated using the midpoint of each range.
Hie amount of $250,000 was used for the highest income category included in the survey ("$250,000 or more").
e Respondents were asked to rate the "importance of protecting aquatic ecosystems" on a scale of 1 to 5, 1 being "not important" and 5 being "very important".
Source: U.S. EPA analysis for this report
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For categorical or ordinal variables (i.e., all variables except age), EPA tested for statistical
differences between respondents and non-respondents using both the Mann-Whitney U Test and
X2Test of Proportions. EPA used the Student's /-test for age, the only cardinal variable in the
group. EPA considered a variable to be statistically different across the two populations if the null
hypothesis of equality could be rejected at /K0.10. Table 11-7 presents the variables which were
found to be statistically different for each survey region and the national survey.
Table 11-7: Variables Found to be Statistically Different Across Respondent and
Non-Respondent Samples
Survey Region
Variables
Northeast
Gender, education
Southeast
Gender, education
Pacific
Importance of aquatic ecosystems, race
Inland
Age, gender, education, employment3, and income
National Survey
Gender, income
a Employment was not statistically different for respondents under the age of 65.
Source: U.S. EPA analysis for this report
In general, attitudes towards the protection of aquatic ecosystems tended to be similar across
samples for most survey regions, with a large majority of respondent rating it as important. No
statistical difference was found in rating the protection of aquatic ecosystems among respondents
and non-respondents, the only exception being the Pacific region. The average ranking was
slightly higher for non-respondents than respondents in the Pacific region. The vast majority of
participants in the non-response study also indicated that government should be at least somewhat
involved in environmental protection.67
EPA developed for the weights for those demographic variables which were found to be
statistically different in each region to account for over- and under- represented groups in the mail
survey dataset used for model estimation. Section 11.6.3 describes weight development.
11.6 Random Utility Model
EPA's analysis of the 316(b) survey data is grounded in the random utility model presented by
Hanemann (1984) and McConnell (1990). The use of the random utility model is standard in the
SP literature for attribute-based SP data, such as that provided by choice experiments (Bateman et
al. 2002; Bennett and Blarney 2001). Under the model, "utility is the sum of systematic [or
observed] and random [or unobserved] components" (Holmes and Adamowicz 2003, p. 189). The
individual choices are systematic (i.e., deterministic) from the perspective of the individual, while
the random component reflects preferences which are unobservable to the researcher, among
other things(Holmes and Adamowicz 2003). The model is applied extensively within SP research,
and allows for the calculation of well-defined welfare measures (i.e., WTP) from choice
experiment models (Bennett and Blarney 2001; Louviere et al. 2000). This section describes
07 Multiple questions in the main mail survey asked respondents about their views toward government and
environmental protection (e.g., questions 1-5 and 1-6 on page 3 of the mail survey). However, the wording of
these questions differed from the question included in the non-response survey, such that they are not directly
comparable.
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EPA's model specification (Section 11.6.1), model estimation (Section 11.6.2), approach for
estimating weights (Section 11.6.3), and model results (Section 11.6.4).
11.6.1 Model Specification
Table 11-8 lists and defines the variables included in the random utility models. For each choice
option, the respondent may choose Option A, Option B, or No Policy, where No Policy is
characterized by zero change in all attributes.
Table 11-8: Summary of Variables Included in the Random Utility Models for the
Regional and National Surveys
Variable
Variable Definition
CONSTANT
Alternative specific constant (ASC) associated with No Policy, or choice of neither
plan.
COM_FISH
Score showing the overall health of commercial and recreational fish populations.
FISH_POP
Score showing the estimated size of all fish populations compared to natural levels
without human influence.
FISH_SAV
Score showing the percentage point reduction in young fish lost compared to current
levels.
AQUATIC
Score showing the ecological condition of affected areas, compared to the most natural
waters in the region.
COST
The increase in annual household cost, in unavoidable price increases for products and
services, including electricity and common household products.
Source: U.S. EPA analysis for this report
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The linear econometric specification of the model of the observable component of utility appears
as:
v(-) = p0 + fii(Afish_sciv) + p2(Accw7 Jish) + p3(A//s/7 _pop) (11-1)
+ p4(Aaquatic) + p5(cos7)
This specification allows EPA to estimate the relative linear "main effects" of the four
environmental attributes on utility. The estimated constant (p0) represents utility associated with
the relevant ASC (alternative specific constant). This is a fixed coefficient estimated within
choice experiments that is designed to capture "systematic but unobserved information about why
respondents chose a particular option (that is, unrelated to choice set attributes)" (Bennett and
Blarney 2001). ASCs become statistically significant in choice experiment models when elements
other than the independent variables, or choice attributes, in the model influence respondents"
choices (Kerr and Sharp 2006). Here, EPA included an ASC for No Policy; this variable takes a
value of 1 for the No Policy option and a value of 0 for either of the two available policy options.
Hence, p0 in this model represents the fixed utility associated with No Policy (maintaining the
status quo), holding all other attribute changes at zero.
Economic theory provides guidance regarding some, but not all, aspects of model specification
for mixed logit models within SP choice experiments. For example, the parameter on program
cost is expected to have a negative sign, reflecting a positive marginal utility of income.
Comparison of model output suggested that the greatest robustness of results is achieved when
cost is modeled as fixed rather than random. This specification also avoids well-known
challenges for welfare estimation associated with the specification of a random coefficient on
program cost (Hensher and Greene 2003; Scarpa et al. 2008; Train and Weeks 2005). Coefficients
on all variables except that on program cost (cost) are specified as random with a normal
distribution.
11.6.2 Model Estimation
EPA estimated the random utility models for all four regions and the national survey using
maximum likelihood mixed logit with Halton draws. As described in Chapter 8, Halton draws, or
"intelligent draws", are "generated number theoretically rather than randomly and so successive
points at any stage 'know" how to fill in the gaps left by earlier points" (Bhat 2001, p. 684). The
mixed logit model is an approach for modeling preference heterogeneity based on the assumption
that individuals" preferences are randomly distributed and that heterogeneity in population
preferences can be captured by estimating the mean and variance of the random parameter
distributions (Holmes and Adamowicz 2003). As described by Henscher and Greene (2003), "the
mixed logit model offers an extended framework within which to capture a greater amount of
behavioral choice making. Broadly speaking, the mixed logit model aligns itself much more
closely with reality than most discrete choice models. This is because every individual has their
own inter-related systematic and random components for each alternative in their perceptual
choice set(s)" (p. 170). It is a highly flexible model that "obviates the three limitations of
standard logit by allowing for random taste variation, unrestricted substitution patterns, and
correlation in unobserved factors overtime" (Train 2009, p. 134).
The mixed logit model allows for the possibility of preference heterogeneity but cannot attach
specific parameter values to particular individuals. That is, the model relaxes the assumption of
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respondents being identical, which is required for multinomial logit estimation, and replaces it
with a less restrictive assumption that respondents" preferences follow distribution. The theory
and methods of mixed logit modeling are well-established (Train 2009), and it has now become
standard practice in many areas of research (Hensher and Greene 2003). These models allow for
coefficients on attributes to be distributed across sampled individuals according to a set of
estimated coefficients and researcher-imposed restrictions. The models are evaluated numerically
using random draws because choice probabilities take the form of an integral over a mixing
distribution that does not have a closed form (Train 2009). The likelihood simulation for the
models estimated by EPA used 300 Halton (random) draws.68 Coefficients on all variables except
that on program cost (cost) are specified as random with a normal distribution. As discussed in
the previous section, the greatest model robustness was achieved when cost was specified as
fixed.
11.6.3 Approach for Estimating Weights
EPA developed weights for each region to account for the over- and under-representation of
demographic groups in the mail survey data for each region. As described in Section 11.5.2, EPA
statistically compared a set of key demographic characteristics across respondent and non-
respondent samples. For those characteristics which were statistically different, EPA developed
weights such that the weight given to particular subgroup of individuals within the analyzed
sample (sample proportion) matches the weight for the same subgroup in the overall (population
proportion).69 EPA used data from Census 2010 and the American Community Survey (ACS) as
the target for the desired population.
EPA applied one of two approaches to calculate the weights assigned to each respondent in the
mail survey dataset: (1) subgroup weighting and (2) raking. The combination of demographic
characteristics dictated which approach was applied for a given region:
> Subgroup weighting - Applied if the population proportions for each subgroup could be
calculated directly based on data from ACS and Census 2010. For example, the 2010
ACS reports educational attainment by gender, the two characteristics which were
statistically different in the Northeast and Southeast survey regions. Because separate
proportions for males and females for educational attainment were available according to
gender, EPA could calculate population proportions directly from the data for these
regions. EPA also used subgroup weighting for race in the Pacific region.
> Raking - Used when the number and combination of variables are such that EPA could
not calculate the grid of sample and population proportions directly using Census or ACS
data. Raking uses an iterative process to match the subpopulations weights to the
population statistics, using targets for the individual demographic characteristics of
interest. Additional detail on raking is provided by (Izrael et al. 2004) This approach was
EPA also rail the models with 200, 400, and 500 Halton draw to assess model robustness. They indicate that the
models are relatively robust (stable) across different numbers of draws, for the "fish saved" attribute in particular.
09 EPA could not develop weights for the importance of aquatic ecosystems in the Pacific region because a statistical
target (e.g., Census for ACS data) was unavailable (adjusting would have increased WTP). EPA did not weight
based on employment in the Inland region because employment was not statistically different for respondents
under the age of 65 and EPA weighted for age.
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used to weight for age, gender, education, and income in the Inland region and for gender
and income for the national survey.
11.6.4 Model Results
Mixed logit model statistics suggest good statistical fit across the regional survey versions. Table
11-9 presents results for both linear and weighted linear models for each survey region. The
following discussion, however, focuses on the weighted model since this model allows to correct
for differences in demographic characteristics of respondents and general population. For the
weighted linear models, the %2 values ranged from 483.07 to 1,119.22 (all with d.f. = 21,
p<0.0001) and pseudo-R2 ranged from 0.23 to 0.31 for the regional surveys. The national
weighed linear model has a %2 value of 394.0 (d.f. = 21, p<0.0001) and pseudo-R2 of 0.23.
The variable for fish saved {fish sav) is significant in all four regional weighted linear models,
commercial fish populations {com fish) is significant in two of the four regional models, and
aquatic ecological condition {aquatic) is statistically significant in two of the four regional
models. The significance of these attributes suggests positive implicit prices; that is, positive
WTP for changes in individual attributes. Analogous outcomes are common in choice
experiments across the literature addressing aquatic ecological improvements, with the substantial
majority of choice attributes found to have statistically significant impacts (Carlsson et al. 2003;
Do and Bennett 2009; Johnston et al. 201 la; Johnston et al. 201 lb). The ASC was significant in
three of the five models.
As noted above, all variables except cost represent percent progress toward the upper ecological
reference condition (100 percent). Hence, these coefficients may be directly interpreted as the
relative marginal utility derived from a one percentage point change in each ecological attribute.
In the estimated Southeast weighted linear model, for example, marginal utility is greatest (per
percentage point) for increases in commercial fish populations {com fish), with lower (but still
statistically significant) impacts associated with changes in the number of fish saved {fish sav).
The percentage differences in environmental attributes across the options presented were much
larger for the number of fish saved {fish sav) than for the other variables. Therefore, the
coefficients on fish sav tend to be lower than on other environmental attributes. Following
recommended practice in SP valuation, these variations correspond with realistic ecological and
policy expectations for regulatory outcomes (Bateman et al. 2002). The lack of significance of
com fish, all fish and aquatic in some models may be related to the relatively small changes in
these attributes included in the survey, relative to effects on fish saved, which were much larger.
There are only two coefficients of unexpected sign and neither is significant.
Direct comparisons of statistical fit measures across different choice experiments in the literature
can be misleading and should be viewed with extreme caution. Many measures of model fit are
not directly comparable across different datasets or models. Nonetheless, the overall statistical fit
of the model appears broadly similar to choice experiments found in the published literature
addressing environmental improvements both worldwide and in the United States. Johnston et al.
(201 la,b), in a similar survey of ecological improvements, report a pseudo-R2 of 0.30. By
comparison, using a commonly reported measure of model fit (pseudo- or McFadden R2),
Campbell et al. (2009) report a pseudo-R2 of 0.20; Carlsson et al. (2003) report pseudo-R2 values
between 0.12 and 0.27; Do and Bennett (2009) report pseudo-R2 between 0.07 and 0.18; and
Colombo and Hanley (2008) report values between 0.16 and 0.36. Other measures of fit are also
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similar, although again, caution must be exercised when drawing conclusions from any such
comparisons across models.
EPA also tested alternative models and conducted various validity tests using the survey data and
model results. This included investigation of non-linear functional forms, including stepwise
models and inverse hyperbolic sine (IHS) models, as it is possible that there is diminishing
marginal WTP for fish saved. However, EPA found that model results did not improve under
non-linear specifications. For the stepwise models, EPA coded fish saved as a set of binary
(dummy) variables instead of a continuous variable for each survey region and results are
intuitive. Resulting WTP across steps seems to suggest a generally linear relationship. EPA
designed the IHS model for each survey region to capture potential nonlinearities in WTP for fish
saved. Review of IHS results indicate that the fit and intuitiveness varies somewhat across
models, but in general, models do not improve upon linear specification. Results for these
alternative models are included in the 316(b) rulemaking docket. Based on these results, EPA
used the weighted linear specification as its primary models in this report for preliminary
assessment of WTP. The Agency also notes that with only three attribute levels (per region), it
would be difficult to capture non-linearities in the fish saved attribute.
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Table 11-9: Linear and Weighted Linear Model Results
Coefficient a'b
(Standard Error)
Variable
Northeast
Southeast
Inland
Pacific
National
Linear
Weighted
Linear
Linear
Weighted
Linear
Linear
Weighted
Linear
Linear
Weighted
Linear
Linear
Weighted
Linear
Random parameters in utility functions
CONSTANT
-0.56919
-0.52259
-0.19920
-1.63728***
-3.56478***
-3.53149***
0.18220
0.18797
-2.09328***
-1.49361***
(0.42972)
(0.37095)
(0.30806)
(0.33244)
(0.58123)
(0.56418)
(0.45022)
(0.49719)
(0.45875)
(0.48000)
COMFISH
0.13145*
0 21316***
0.12662***
0.08871*
0.06082**
0.02335
0.15056**
0.11072
0.08925
0.07350
(0.06765)
(0.05180)
(0.04660)
(0.04991)
(0.02946)
(0.02773)
(0.07282)
(0.08606)
(0.06077)
(0.06015)
FISHPOP
0.13602
0.06502
0.14670**
-0.02800
0.02175
0.01007
0.21176*
0.16039
0.02838
0.19524*
(0.10508)
(0.09369)
(0.06364)
(0.07830)
(0.04405)
(0.04182)
(0.11078)
(0.12739)
(0.10735)
(0.11069)
FISHSAV
0.02852***
0.02900***
0.02183***
0.02596***
0.01483***
0.01597***
0.04389***
0.03645***
0.02241***
0.02116***
(0.00537)
(0.00464)
(0.00462)
(0.00507)
(0.00439)
(0.00393)
(0.00698)
(0.00683)
(0.00585)
(0.00665)
AQUATIC
0.17102
0.20135*
0.24591***
0.06163
0.04630
0.04864
0 34i7i***
0.31963**
-0.12105
-0.10694
(0.10955)
(0.10306)
(0.07741)
(0.08284)
(0.05036)
(0.04478)
(0.11007)
(0.13338)
(0.11085)
(0.17007)
Non-random parameters in utility functions
COST
-0.02677***
-0.02106***
-0.03868***
-0.04209***
-0.03356***
-0.03280***
-0.02756***
-0.02177
-0.03739***
-0.03294***
(0.00513)
(0.00453)
(0.00417)
(0.00502)
(0.00298)
(0.00284)
(0.00518)
(0.00534)
(0.00520)
(0.00578)
Derived standard deviations for parameter distributions
sdCONSTANT
0.37257
0.19465
0.00256
0.29835
5 91389***
5.18984***
0.09866
0.01702
0.18221
0.08915
(1.01103)
(1.01704)
(4.10600)
(1.20020)
(0.97758)
(0.89828)
(1.0278)
(6.00963)
(2.51713)
(1.29659)
sdCOMFISH
043573***
0.13635
0.26774***
0.17567
0.12217*
0.12565**
0.30101
0.32221*
0.27147
0.30494*
(0.12740)
(0.16831)
(0.09727)
(0.12699)
(0.06487)
(0.06115)
(0.30183)
(0.18467)
(0.41960)
(0.17425)
sdFISHPOP
0.51160**
0.58902***
0.04792
0.34982
0.07409
0.12423
0.22539
0.23578
0.54531
0.64049**
(0.21996)
(0.18116)
(0.39545)
(0.21724)
(0.07769)
(0.08723)
(0.41340)
(0.25612)
(1.33621)
(0.30347)
sdFISHSAV
0.05755**
0.04375***
0.05697***
0.06335**
0.04838***
0.04359***
0.05362
0.05332***
0.05514***
0.08467***
(0.02241)
(0.01269)
(0.01339)
(0.02852)
(0.00615)
(0.00554)
(0.04330)
(0.01546)
(0.01773)
(0.02698)
sdAQUATIC
0.61933***
0.64976
0.45656***
0.77220
0.44593***
0.33881***
0.35905
0.29608
0.81244
1.19443*
(0.22791)
(0.44299)
(0.12343)
(0.60628)
(0.08826)
(0.08224)
(0.57884)
(0.26966)
(0.53981)
(0.72258)
Model significance
582.48
538.59
741.92
700.17
1.191.94
1.119.22
578.74
483.07
413.53
394.00
Model X
(d.f. =21.
p<0.0001)
(d.f. =21.
p<0.0001)
(d.f. =21.
p<0.0001)
(d.f. =21.
p<0.0001)
(d.f. =21.
p<0.0001)
(d.f. =21.
p<0.0001)
(d.f. =21.
p<0.0001)
(d.f. =21.
p<0.0001)
(d.f. =21.
p<0.0001)
(d.f. =21.
p<0.0001)
Pseudo-R2
0.24
0.23
0.24
0.24
0.25
0.24
0.32
0.31
0.24
0.23
a For random parameters in utility functions, coefficients represent the estimated means of random parameter distributions,
b * indicates significance at I".., 5".., 10% levels, respectively.
Source: U.S. EPA analysis for this report
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 11: Stated Preference Survey
11.6.5 Validity Tests
Generally accepted economic thinking maintains that obtaining greater quantities of a desired
economic good will lead to higher levels of consumer utility (Heberlein et al. 2005). A scope test
looks at whether respondents' WTP is greater for (or not less than) a good that is somehow larger,
either in a quantitative or qualitative sense. There are two types of scope tests. An internal scope
(or within-sample) test involves comparing multiple WTP estimates from SP responses collected
from the same respondents" while an external scope test "employs split-sample designs to
compare WTP estimates across samples from the sample population" (Lew and Wallmo 2011). A
major criticism of stated preference studies had been that this relationship - consumers preferring
greater quantities of a good over lesser quantities of that same good- is sometimes violated when
valuating environmental amenities. Evidence provided by these early findings prompted the 1993
NOAA Panel on Contingent Valuation to regard surveys that exhibit insensitivity to scope as
"unreliable" (Arrow et al. 1993). Compared to tests of scope in contingent valuation, the role of
external scope tests within choice modeling has received much less attention in the literature (cf.,
Heberlein et al. 2005).
Unlike open-ended contingent valuation questions, choice experiments provide a direct
mechanism for respondents to react to the scope and scale of resource changes, by enabling
respondents to compare policy options with different levels for each attribute. As noted by
Bennett and Blarney (2001, p. 231), "internal scope tests are automatically available from the
results of a [choice modeling] exercise." That is, choice experiments already include "internal"
scope tests because respondents compare levels across Options A and B. Respondents express
WTP for incremental improvements in environmental attributes through their selection of No
Policy, Option A, or Option B within the choice questions and model results indicate that WTP is
higher for an option with a greater level of goods. Within a choice modeling context, external
scope tests may also be confounded by differences in the implied choice frame (Bennett and
Blarney 2001). These caveats aside, an external scope test can provide some additional insight
into response patterns, and some researchers view these tests as a "stronger" form of validation
than internal scope tests. EPA therefore implemented a form of external scope tests to evaluate
this form of validity using the mail survey data for each survey region. As the experimental
design was not originally conceived to allow formal tests of external scope, the following test is
illustrated as an alternative approach that is possible given the current experimental design and
available data.70
EPA used a split sample to look at respondents' selections for Options A and B separately and
obtain a more "external" perspective based on the concept that, if all else is orthogonal
(effectively equal), a choice option with more fish saved should be chosen more often than a
choice option with fewer fish saved. Splitting out Options A and B provides a more convincing
test, because it shows that the same patterns apply to both Options A and B. EPA limited the test
to the fish saved attribute because fish saved is the only attribute that EPA is using at this time to
estimate WTP for regulatory options. To distinguish this test from the "internal" scope tests
automatically performed by choice experiments, it is implemented using a split sample of choice
options viewed in isolation. To implement the test, EPA first created a dataset only of
70 External scope tests were recommended for contingent valuation studies (Arrow et al. 1993). Because scope tests
are automatically available from the results of a choice modeling exercise (Bennett and Blarney (2001, p. 231),
accounting for external scope tests in the experimental design was not necessary.
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 11: Stated Preference Survey
observations on Option A for all survey responses, along with a dummy (0-1) variable indicating
whether that option was chosen.71 EPA then further split this sample into three sub-samples based
on the three levels of fish saved assigned to each region within the experimental design. Using the
Pacific region as an example, the three sub-samples are: (1) observations on Option A when
percent fish saved = 95 percent, (2) observations on Option A when percent fish saved = 50
percent, and (3) observations on Option A when percent fish saved =2 percent. Because of the
near orthogonal nature of the experimental design, all other attribute levels should be
approximately equal across each of these three sub-samples. Given this split sample, EPA
expected to observe the greatest proportion of respondents choosing Option A in sub-sample (1),
followed by sub-sample (2) and then (3). This order would establish external sensitivity to scope.
EPA then repeated the same test for Option B.
The results of the scope sensitivity test are presented in Table 11-10. The results tables illustrate
means and standard deviations for respondent choices for each observation of Option A and
Option B. The external scope tests for split samples of both Options A and B demonstrate scope
sensitivity for all survey regions, as indicated by economic theory. The values of other choice
attributes (com Jish,fish_pop, aquatic, and cost) are approximately equal over the split samples,
as one would expect given the experimental design. The proportion of respondents choosing
Option A declines as the percentage of fish declines for all survey regions. Using the Inland
region as an example, the proportion of respondents choosing Option A declines from 0.42 to
0.39 to 0.37 as the percentage of fish saved declines from 95 percent to 75 percent to 55 percent.
Option B exhibits a similar decline in respondent choice with fish saved all survey regions. EPA
used the % test of proportions to examine whether the proportions were statistically different
across levels of fish saved for a given option. The null hypothesis of equality in proportions is
rejected atp<0.10 for all regions and options. This shows that respondent choices were
statistically different across levels of fish saved.
EPA also conducted further testing with the responses split by survey question as well as option
to respond to the external peer review. Using this approach, each question/option sample includes
only one choice from each respondent. The null hypothesis of equality in proportion is rejected at
p<0,10 or better for 22 of the 30 cases (5 survey versions x 3 questions x 2 options = 30). EPA
did not generate the survey experimental design with such tests in mind, so the combination of
other choice attributes (com Jish,fish_pop, aquatic, and cost) vary somewhat across cases when
split by question and option, which would affect the results of this scope test in a systematic
fashion. Overall, results indicate sensitivity to scope for fish saved.
71 Thus, each respondent is represented up to three times, once for each choice question in their survey booklet.
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 11: Stated Preference Survey
Table 11-10: Results of the Split-Sample External Validity Test for Each Survey Region
Region/ Percent Fish Saved
Option A
Option B
Mean
Std. Dev.
Mean
Std. Dev.
Northeast
95%
0.4617
0.4992
0.4861
0.5004
50%
0.4274
0.4954
0.4415
0.4973
5%
0.2473
0.4320
0.2345
0.4243
X Test of Proportions3
42.43
(d.f.=2; p<0.001)
58.81
(d.f.=2;p<0.001)
Southeast
90%
0.4796
0.5001
0.4000
0.4904
55%
0.3593
0.4803
0.2939
0.4560
25%
0.2922
0.4553
0.2602
0.4392
X Test of Proportions3
35.58
(d.f.=2; p<0.001)
23.29
(d.f.=2;p<0.001)
Inland
95%
0.4225
0.4943
0.3679
0.4825
75%
0.3897
0.4880
0.3234
0.4681
55%
0.3652
0.4818
0.2712
0.4449
X Test of Proportions3
5.00
(d.f.=2; p<0.082)
15.77
(d.f.=2;p<0.001)
Pacific
95%
0.4929
0.5008
0.5993
0.4909
50%
0.3722
0.4843
0.4118
0.4931
2%
0.1932
0.3955
0.2333
0.4237
X Test of Proportions3
53.89
(d.f.=2;p<0.001)
76.63
(d.f.=2;p<0.001)
National
95%
0.4753
0.5003
0.4604
0.4994
55%
0.3571
0.4801
0.3013
0.4598
25%
0.3269
0.4700
0.2737
0.4466
X Test of Proportions3
13.60
(d.f.=2;p<0.001)
24.06
(d.f.=2;p<0.001)
a The null hypothesis is that the proportion of respondents choosing an option is equal for all percentage fish saved.
Source: U.S. EPA analysis for this report
11.7 Estimation of Implicit Prices and WTP
EPA used the results of the random utility models presented in Table 11-9 to estimate the implicit
price or marginal annual WTP for a one percentage point change in each of the four
environmental attributes within each survey region. This represents WTP per household, per year,
for a one percentage point change in the corresponding choice model attribute. For example, one
could calculate the marginal WTP for each additional percentage increase in fish saved, holding
all else constant. If utility is modeled as a linear function of attributes, implicit prices may be
calculated as IPa = Pa/Pn- where fJ>„ is the estimated coefficient on an environmental attribute
(e.g., change in fish saved), and fJ>„ is the coefficient on program cost. Assuming a linear
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 11: Stated Preference Survey
preference function as estimated above, compensating surplus (or household WTP) for any given
policy option may be calculated as:72
WTP = (lPCOmfish * Acomjish) + (lPfishpop * A fish_pop) (H-2)
QPfish_sav * Afish_SO,V) + (/Paquatic * A&QU&tic)
where the delta (A) represents a change in the attribute in question. That is, total WTP for a policy
change is calculated as the sum of the product of implicit prices and corresponding attribute
changes. Once a preference function is estimated, the decision to include or exclude the ASC
(constant) in subsequent welfare estimation must be made on a case-by-case basis; economic
theory alone is insufficient to determine this choice.73 In this case, EPA excludes the ASC when
calculating compensating surplus, because by definition it reflects anticipated utility change
unrelated to the included model attributes. Section 11.8 includes additional discussion of EPA's
treatment of the ASC when analyzing regulatory benefits.
EPA notes that ecological systems are typically characterized by correlation among many
processes and outcomes. In the context of IM&E, for example, a reduction in A1E losses
(fishsav) may be correlated with changes in fish populations {fish_pop), aquatic ecosystem
condition (aquatic), and commercial fish populations (com Jish). It would have been difficult to
determine which attribute(s) caused respondents to choose one scenario over another had the SP
survey scenarios incorporated the same correlations. For example, if it were the case that large
reductions in IM&E always accompany large positive effects on fish populations and large
positive effects on ecosystem condition and these correlations were embedded within survey
scenarios, it would have been difficult to estimate the specific influence of each attribute on
respondents' choices.
The experimental design used in the SP survey breaks this correlation and allows different survey
attributes to vary independently. This enables different respondents to view many different
possible policy outcomes, each with different combinations offish_sav,fish_pop, aquatic and
com Jish. While some of the resulting scenarios might be unlikely in actual aquatic systems, they
are not ecologically impossible. For example, the experimental design allows respondents to
consider scenarios in which large reductions in fish losses accompany very small changes in fish
populations and aquatic condition (positive changes in fishsav in some questions are also paired
with no change in the population or aquatic condition metrics). Because attributes vary
independently across the 72 different choice questions presented to respondents in each survey
region and national survey, it is possible to estimate the unique effects of each attribute on
individuals' choices and therefore, values. By breaking the correlation between these attributes
present in ecosystems, the choice experiment design allows estimation of the independent effect
of each attribute on choices and WTP. The environmental attributes have almost zero correlation
in the resulting experimental design. This allows WTP for each ecological effect to be estimated,
independent from all other effects. Based on recommendations from external peer reviewers, EPA
is currently conducting additional analysis to assess the robustness of fish saved under alternative
treatments of the other environmental attributes.
72 EPA excluded the ASC when estimating the benefits of regulatory options because there is no clear theoretical
reason for inclusion. The magnitude and sign of the coefficient on ASC varies across regions.
73 The treatment of the ASC is discussed by Adamowicz et al. (1998) and Morrison et al. (2002), among others.
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 11: Stated Preference Survey
Because the mixed logit model includes random coefficients, EPA estimates implicit prices using
the welfare simulation approach of Johnston and Duke (2007; 2009) following the framework
outlined by Hensher and Greene (2003). The procedure begins with a parameter simulation
following the parametric bootstrap of Krinsky and Robb (1986), with i?=l,000 draws taken from
the mean parameter vector and associated covariance matrix. For each draw, the resulting
parameters are used to characterize asymptotically normal empirical densities for fixed and
random coefficients. For each of these R draws, a coefficient simulation is then conducted for
each random coefficient, with ,S'=1 000 draws taken from simulated empirical densities. Here, all
coefficient simulations draw from a normal distribution except for that on cost, which is fixed.
EPA calculated WTP measures for each draw, resulting in a combined empirical distribution of
Rx-S observations from which summary statistics were derived. All implicit prices are modeled as
the WTP for a one percentage point change in the ecological attribute, all else being constant.
The resulting mean implicit prices and 90 percent confidence intervals for the ASC (constant) and
environmental attributes in each region are presented in Table 11-11. The point estimates for
implicit prices tend to be larger for commercial fish populations, fish populations (all fish), and
aquatic ecosystem condition than for fish saved, although the statistical significance of these point
estimates varies. This is not surprising given the relatively narrow range over which these
attributes vary. Hence, some point estimates that appear large may not be statistically significant,
and vice versa. In the Pacific for example, households value a one percentage point increase in
commercial fish populations or aquatic ecosystem condition about three or eight times,
respectively, the value of a one percentage point increase in fish saved. The mean implicit prices
for a 1 percent improvement in fish saved under the regional weighted linear models range from
$0.50 in the Inland region to $1.77 in the Pacific region. The mean implicit price based on the
national survey is $0.66. Peer reviewers indicated that EPA should focus on the regional over the
national survey results because of concerns regarding the smaller size and representativeness of
the national sample. EPA included implicit prices based on the national survey for illustrative
purposes.
EPA did not use the national survey results in its analysis of regulatory options. EPA found that
the implicit price for fish saved was relatively robust (stable) across mixed logit models with 200,
400, and 500 Halton draws. These additional model results are included in the 316(b) rulemaking
docket. Although the discussion in this section refers to WTP for a percentage point increase in
fish saved, it is important to note that this variable represents a one percentage point reduction
relative to the level of baseline mortality (e.g., the Northeast survey booklet indicated a baseline
loss of 1.1 billion fish). This relationship between the percentage point reduction and cardinal fish
losses was specified clearly in survey questions, and the same relationship was maintained
throughout each survey . WTP per percentage point reduction reflects a specific quantity of fish
saved, rather than a general relative reduction of one percent from an unspecified level of IM&E.
The regional and national surveys have different baseline fish losses. EPA expected survey
responses to vary across the regions, because residents might have different values and baseline
losses differ.
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 11: Stated Preference Survey
Table 11-11: Estimated Implicit Prices for a Once Percentage Point Change in Each
Attribute, WTP per Household, per Year (2011 $)a
Survey Version and Environmental
Attribute
5th
Mean
95th
Northeast
Commercial Fish Populations (COM FISH)
$6.45
$10.30
$14.86
Fish Populations (all fish) (FISH POP)
-$4.53
$3.09
$10.89
Fish Saved (FISH_SAl~)
$0.95
$1.44
$2.07
Aquatic Ecosystem condition (AQUATIC)
$1.44
$9.76
$19.01
Southeast
Commercial Fish Populations (COM FISH)
$0.16
$2.10
$4.11
Fish Populations (all fish) (FISH POP)
-$3.81
-$0.69
$2.48
Fish Saved (FISH_SAl~)
$0.42
$0.62
$0.83
Aquatic Ecosystem condition (AQUATIC)
-$2.01
$1.43
$4.75
Inland
Commercial Fish Populations (COM FISH)
-$0.67
$0.69
$2.08
Fish Populations (all fish) (FISH POP)
-$1.83
$0.28
$2.48
Fish Saved (FISH_SAl~)
$0.28
$0.50
$0.70
Aquatic Ecosystem condition {AQUATIC)
-$0.78
$1.47
$3.68
Pacific
Commercial Fish Populations (COM FISH)
-$1.37
$5.37
$13.60
Fish Populations (all fish) (FISH POP)
-$2.32
$7.71
$18.53
Fish Saved (FISH_SAl~)
$1.07
$1.77
$2.62
Aquatic Ecosystem condition {AQUATIC)
$5.01
$15.32
$27.48
National
Commercial Fish Populations (COM FISH)
-$0.81
$2.22
$5.50
Fish Populations (all fish) (FISH POP)
$0.41
$5.82
$11.28
Fish Saved (FISH_SAl~)
$0.28
$0.66
$1.07
Aquatic Ecosystem condition {AQUATIC)
-$12.30
-$3.52
$5.20
' The implicit prices are per percentage point increase from the specified baseline (reference) levels for each survey.
Source: U.S. EPA analysis for this report
While 95 percent confidence intervals are rather large for com fish, fish_pop, and aquatic, and
sometimes include zero in the range, the confidence intervals are rather narrow for fish saved and
do not include zero within the 95 percent confidence interval. This highlights a very specific
result of the stated preference survey, which is that the WTP to protect fish and shellfish from
impingement and entrainment, even when there are no effects on the other attributes, is greater
than zero. This is the case despite the vociferous objections of some commenters opposed to the
stated preference survey. To be clear, these benefit estimates represent an average WTP for
protecting fish and shellfish from impingement and entrainment and incorporate the responses of
all respondents, including those who expressed zero WTP ,74
11.8 Method for Estimating Regional Benefits
EPA used the implicit prices, or WTP per percentage point change, for fish saved (fish sav) to
estimate annual monetized benefits for each survey region under the final rule and regulatory
options considered. EPA did not estimate changes or potential benefits associated with changes in
the other three environmental attributes. EPA's focus on the fish saved attribute for benefits
estimation is consistent with recommendations from external peer reviewers. Peer reviewers
74 About 17 percent of survey respondents selected No Policy (i.e., zero WTP) for all three choice questions.
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 11: Stated Preference Survey
indicated that using fish saved exclusively for benefits estimation helps to alleviate concerns
regarding overlaps in the definitions of environmental attributes and potential interactions
between environmental attributes which are not accounted for in the main effects experimental
design. It also allays concerns with the degree of ecological uncertainty involved in the modeling
and prediction of effects on fish populations and aquatic ecosystems.
For each survey region, EPA calculated annual household WTP under regulatory options by
multiplying the estimating percentage change in fish saved by the regional implicit price for fish
saved from Table 11-11. As noted above, EPA did not include the implicit price on the ASC
within the benefits calculation. Once a preference function is estimated, the decision to include or
exclude the ASC in subsequent welfare estimation must be made on a case-by-case basis;
economic theory alone is insufficient to determine this choice (Adamowicz et al. 1998; Morrison
et al. 2002). By excluding the ASC here (and other ecological attributes), EPA is presenting a
clean estimate of WTP for fish saved alone, without other actual or possibly speculated benefits
associated with reductions in IM&E. This approach is consistent with peer review comment that
the exclusion of the ASC "... is not a problem for the annual household WTP estimated provided
in the report for the regulatory options since these are calculated using only the marginal WTP for
a one unit change in fish saved" (Applied Planning Corporation 2012, p. 34).
Total annual WTP for fish saved under each regulatory option is calculated by multiplying annual
household WTP by the number of household in the region from Census 2010. EPA then
discounted and annualized regional WTP using discount rates of 3 and 7 percent. Refer to
Appendix D for additional regarding discounting and the compliance schedule. As stated
previously, the boundaries of the SP survey regions differ slightly from the proposed rule regions.
Because regional IM&E is a function of operational intake flow, EPA accounted for differences
in regional boundaries by adjusting the proposed rule compliance schedule based on state-level
AIF data by waterbody type (i.e., coastal/estuarine or freshwater).
11.9 Results for the Final Rule and Regulatory Options Considered
As noted previously, EPA considers it premature to include the SP survey results in the
quantitative comparison of costs and benefits prior to completion of the SAB review. This section
presents preliminary benefits for the final rule and options considered to illustrate the potential
magnitude of regulatory benefits and demonstrate progress towards this effort.
Table 11-12 presents IM&E, percent fish saved, and WTP per household by regulatory option.
Percent fish saved and mean household WTP for the final rule vary across regions, from less than
one percent and less than $1 in the Pacific region to 56 percent and $28 in the Inland region.
Percent fish saved and WTP per household are lower than the final rule under Proposal Option 4
and greater under Proposal Option 2.
Table 11-13 presents annualized benefits by regulatory option using both 3 percent and 7 percent
discount rates. Total benefits under the final rule for all survey regions are $ 1.4 billion using a 3
percent discount rate and $1.1 billion using a 7 percent discount rate. Around half of the total
benefits under the final rule are from the Inland Survey region. Total benefits under Proposal
Option 4 are slightly less than the final rule using both 3 percent and 7 percent discount rates.
Total benefits for Proposal Option 2 are $3.4 billion and $2.3 billion using 3 percent and 7
percent discount rates, respectively, and are greater than benefits under both Proposal Option 4
and the final rule.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 11: Stated Preference Survey
Table 11-12: Reduction in A1E Losses, Percent Fish Saved and WTP per Household
(2011$) by Survey Region for the Final Rule and Options Considered
Survey Version and
Regulatory Option
IM&E
WTP per Household
Reduction in
A1E Losses
(in millions)
Fish Saved
(%)a
5th
Mean
95th
Northeast
Proposal Option 4
45.45
5.61%
$5.31
$8.06
$11.62
Filial Rule
48.86
6.03%
$5.71
$8.66
$12.49
Proposal Option 2
512.53
63.23%
$59.91
$90.89
$130.99
Eliminating Baseline IM&Eb
594.73
73.37%
$69.51
$105.47
$152.00
Southeast
Proposal Option 4
218.96
29.92%
$12.49
$18.69
$24.96
Final Rule
228.54
31.23%
$ 13.04
$19.51
$26.06
Proposal Option 2
544.48
74.41%
$31.06
$46.47
$62.08
Eliminating Baseline IM&Eb
663.79
90.72%
$37.87
$56.66
$75.68
Inland
Proposal Option 4
348.47
51.98%
$14.53
$25.74
$36.46
Final Rule
373.25
55.68%
$15.56
$27.57
$39.05
Proposal Option 2
547.85
81.72%
$22.85
$40.46
$57.31
Eliminating Baseline IM&Eb
619.58
92.42%
$25.84
$45.76
$64.82
Pacific0
Proposal Option 4
1.28
0.37%
$0.40
$0.66
$0.97
Filial Rule
1.36
0.39%
$0.42
$0.69
$1.03
Proposal Option 2
32.63
9.40%
$10.03
$16.65
$24.59
Eliminating Baseline IM&Eb
52.87
15.23%
$16.25
$26.97
$39.84
a When calculating percent fish saved, EPA used a baseline which reflected current technology at regulated facilities
including those facilities in CA and NY that are subject to state regulations. This differs from the rest of the benefits
analysis, where EPA assigns these facilities baseline IM&E reductions commensurate with technologies required by the
state regulations. This approach is consistent with the survey materials which were based on total IM&E. Fish saved under
the elimination of baseline IM&E can be less than 100 percent because EPA does attribute IM&E reductions at facilities
subject to state regulations to the existing facilities rule.
b This hypothetical scenario reflects the benefits that would be achieved if all IM&E were eliminated.
c The calculation of Fish Saved (%) for the Pacific survey region includes reductions in A1E losses at Hawaii facilities.
Source: U.S. EPA analysis for this report
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Benefits Analysis for the Final 316(b) Existing Facilities Rule Chapter 11: Stated Preference Survey
Table 11-13: Annualized Monetized Benefits (millions of 2011$)
Survey Version and
Regulatory Option
3 % Discount Rate
7 % Discount Rate
5th
Mean
95th
5th
Mean
95th
Northeast
Proposal Option 4
$90.6
$137.4
$198.1
$69.8
$105.9
$152.7
Filial Rule
$97.4
$147.8
$212.9
$75.0
$113.9
$164.1
Proposal Option 2
$824.0
$1,250.1
$1,801.7
$535.6
$812.7
$1,171.2
Eliminating Baseline
IM&Ea
$1,545.1
$2,344.2
$3,378.6
$1,537.4
$2,332.5
$3,361.7
Southeast
Proposal Option 4
$297.1
$444.5
$593.7
$229.6
$343.6
$458.9
Final Rule
$310.2
$464.0
$619.8
$239.7
$358.7
$479.1
Proposal Option 2
$634.4
$949.1
$1,267.8
$422.9
$632.8
$845.2
Eliminating Baseline
IM&Ea
$1,167.4
$1,746.6
$2,333.0
$1,161.6
$1,737.8
$2,321.3
Inland
Proposal Option 4
$436.7
$773.4
$1,095.6
$339.5
$601.2
$851.7
Final Rule
$468.0
$828.8
$1,174.0
$363.8
$644.2
$912.6
Proposal Option 2
$603.1
$1,068.2
$1,513.1
$414.3
$733.7
$1,039.3
Eliminating Baseline
IM&Ea
$1,006.9
$1,783.3
$2,526.1
$1,001.9
$1,774.3
$2,513.5
Pacificb
Proposal Option 4
$4.7
$7.8
$11.5
$3.7
$6.1
$9.0
Final Rule
$5.0
$8.2
$12.1
$3.9
$6.5
$9.5
Proposal Option 2
$98.3
$163.2
$241.0
$69.5
$115.4
$170.4
Eliminating Baseline
IM&Ea
$251.8
$418.0
$617.3
$250.6
$415.9
$614.2
Total for Regional Surveys
Proposal Option 4
$829.1
$1,363.1
$1,898.8
$642.6
$1,056.8
$1,472.2
Final Rule
$880.5
$1,448.8
$2,019.0
$682.5
$1,123.2
$1,565.3
Proposal Option 2
$2,159.9
$ i.4 i(l.7
$4,823.7
$1,442.4
$2,294.5
$3.226.1
Eliminating Baseline
IM&Ea
$3,971.3
$6,292.0
$8,854.9
$3,951.4
$6,260.5
$8,810.6
a This hypothetical scenario reflects the benefits that would be achieved if all IM&E were to be eliminated.
b The calculation of benefits for the Pacific survey region excludes households in Hawaii because Hawaii households were not
included in the mail survey sample.
Source: U.S. EPA analysis for this report
11.10 Uncertainties
SP methods have "... been tested and validated through years of research and are widely accepted
by ... government agencies and the U.S. courts as reliable techniques for estimating non-market
values" (Bergstrom and Ready 2009, p. 26). OMB's Circular A-4 notes that SP results "have also
been widely used in regulatory analyses by Federal agencies" (USOMB 2003, p. 22). EPA's own
peer-reviewed Guidelines for Preparing Economic Analysis (USEPA 2010a) indicate that the use
of SP study data, when the study is conducted properly in accord with best current practices, is
the only potential method for monetizing non-use values. However, EPA recognizes that
controversy remains over the use of stated preference results in benefit-cost analysis for
rulemaking, at least in this particular instance. Consistent with established best practices for SP
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 11: Stated Preference Survey
surveys, EPA has sought to minimize possible biases by careful and thorough construction and
testing of the survey instrument.
While in EPA's view, the study incorporates current best professional practice in the conduct of
SP studies, EPA acknowledges that the results of any empirical study depend on the methodology
applied. The Agency recognizes that potential biases may still remain and may influence the
results of the study. The magnitude and direction of any effects on benefits estimates is unknown.
Refer to the "Peer Review Report - 316(b) Stated Preference Survey Report Document (Final
Submission)" (Applied Planning Corporation 2012) in the 316(b) rulemaking docket for
additional detail on the external peer review process and peer reviewer comments. EPA notes that
its analysis of the survey data and models is ongoing. EPA plans to obtain SAB review of the SP
survey EPA conducted. SAB review will provide additional high caliber, independent
professional judgment concerning the quality of the survey done to date, including possible
improvements EPA could make. EPA is also seeking SAB input on whether, how, and in what
circumstances this or similar surveys could be used, as support for national rulemakings or 316(b)
NPDES.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 12: Analysis of New Units
12 Analysis of New Units at Existing Facilities
12.1 Introduction
In addition to the analysis presented in the preceding chapters for existing units at regulated
facilities, EPA analyzed benefits for new units at existing facilities. The new unit provision of the
final rule applies to newly constructed electric power generating units at existing facilities and
repowering of existing generating units where the turbine and condenser are replaced. Unlike the
case for the existing unit provision, EPA cannot predict the facilities at which such new or
repowered units will be constructed, or the number and size of new or repowered units that will
be constructed. Instead, EPA estimated the potential coverage of the new unit provision of the
final rule based on the quantity of electric power generating capacity that will be installed and
subject to the new unit provision in future years. In addition, EPA considered a range of options
for the final rule's new unit provision, each of which would cover a different quantity of new
units capacity.
> Option A: Entrainment performance requirements for all stand-alone new units and all
types of repowered units.
> Option B: Entrainment performance requirements for all stand-alone new units, and
replaced or repowered units in which turbine or condenser are newly built or replaced.
> Option C: Entrainment performance requirements for all stand-alone new units, and
repowered new units where the turbine and condenser are newly built or replaced, but
excluding high efficiency systems.
> Final Rule - New Units (Option D): Entrainment performance requirements for all
stand-alone new units only.
This chapter presents EPA's benefits analysis under the final rule and options considered for new
units. Section 12.2 presents EPA's analysis of IM&E reductions and associated benefits. Section
12.3 presents EPA's analysis of GHG emissions reductions and associated benefits. Section 12.3
summarizes monetized benefits for new units including benefits associated with IM&E reductions
and GHG emissions reductions. Refer to Chapter 8 of the Technical Development Document
(TDD) for additional information on the engineering analysis for new units.
12.2 Analysis Approach and Benefits for IM&E Reductions at New Units
EPA's methodology for estimating IM&E reductions at existing units involves extrapolating
facility-specific data to other existing facilities within the same region. EPA could not apply the
existing units methodology directly to new units because facility-specific information is
unavailable for new units. Instead, EPA estimated per mgd IM&E reductions and the monetary
value of benefits for new units based on the analysis of existing units.
12.2.1 Flow Reductions at New Units
The engineering analysis provided the annual reduction in intake flow at CWIS nationally under
the final rule and options considered for new units. The annual flow reductions are cumulative
over the analysis period. For example, an annual flow reduction of 10 mgd would mean a
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 12: Analysis of New Units
reduction of 10 mgd in year 1, 20 mgd (10 mgd x 2) by year 2, 30 mgd (10 mgd x 3) by year 3,
and so on. The flow reductions are projected to begin in 2014 and end in 2059, the final year of
the compliance period. The peak, or maximum, flow reduction is the flow reduction achieved in
2059. EPA included a declining profile at the end of the compliance period for recreational and
commercial fishing, nonuse, and T&E species benefits consistent with the analyses for existing
units.
Table 12-1 presents the estimated annual and peak flow reductions at new units under the final
rule and options considered for new units. The final rule will result in an annual flow reduction of
68 mgd, with a total peak flow reduction of 3,128 mgd nationally in 2059. Refer to Appendix D
for additional discussion of the compliance schedule.
Table 12-1: Flow Reductions for New Units Under the Final Rule for New Units and
Options Considered (mgd)
Option
Annual Flow Reduction
Peak Flow Reduction
Option A
1,282
58,972
Option I '>
462
21.252
Option C
68
3.128
Final Rule - New Units
7
322
Source: U.S. EPA analysis for this report
12.2.2 IM&E Reductions and Associated Benefits per MGD
EPA calculated the reduction in IM&E per mgd of flow reduction nationally by dividing
estimated baseline IM&E losses at existing facilities by baseline weighted AIF (in mgd). EPA
also calculated bene fits per mgd by dividing the monetized value of baseline IM&E losses by
baseline weighted AIF (in mgd). EPA calculated separate per mgd values by loss mode
(impingement mortality versus entrainment) in order to account for differences in baseline IM
technology across new and existing units. EPA assumed that, in the absence of the rule for new
units, baseline best professional judgment requirements imposed by permitting authorities for
once-through cooling would be equivalent to modified Ristroph screens or intake velocity of 0.5
feet per second.
Table 12-2 presents the annual IM&E reductions per mgd and Table 12-3 presents annual benefits
per mgd, both by loss mode. The benefits values underlying Table 11-3 are based on benefits
estimation methods described in the Chapter 5 through 8. EPA notes that these are partial benefits
estimates for the final rule and options considered because EPA was unable to estimate nonuse
benefits for five of seven regions using the benefits transfer approach described in Chapter 8.
Table 12-4 presents annual benefits per mgd by loss mode based on EPA's SP survey.75 As
discussed in Chapter 11, EPA does not include benefits estimates based on the SP survey in its
quantitative comparison of benefits and costs for the final rule. The survey values are presented
here for illustrative purposes. EPA also notes the SP survey was designed to assess existing,
rather than new units. All values and maps presented in the survey reflected only existing units.
75 Per mgd values for the SP survey were calculated using the sum of regional survey versions.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 12: Analysis of New Units
EPA calculated IM&E reductions and benefits for each year of the analysis period by multiplying
the IM flow reduction and E flow reduction in that year by the respective "per mgd" values. EPA
summed across loss modes to generate total IM&E reductions and benefits for each year. EPA
discounted and annualized benefits using 3 percent and 7 percent discount rates.
Table 12-2: Annual IM&E Reductions per MGD of Flow Reduction for New Units
by Loss Mode3
IM&E
Loss Mode
A1E per mgd
Commercial and
Forage Species
Commercial and
Recreational Species
All Species
Recreational Harvest
(fish per mgd)
IM
4,340
712
5,052
133
E
4,069
1,922
5,991
175
Notes:
IM = impingement mortality; E = entrainment; A1E = age-one equivalent; mgd = millions of gallons per day
aEPA calculated the reduction in IM&E per mgd of flow reduction nationally by dividing estimated baseline IM&E
losses at existing facilities by baseline weighted AIF (in mgd).
Source: U.S. EPA analysis for this report
Table 12-3: Annual Benefits per MGD of Flow Reduction for New Units by Loss Mode
(2011$)a
IM&E Loss
Mode
Recreational
Commercial
T&E
Nonuse
Low
Mean
High
IM
$112
$216
$426
$11
$5
$4
E
$173
$304
$551
$41
$3
$562
Notes:
IM = impingement mortality; E = entrainment
a EPA calculated benefits per mgd by dividing the monetized value of baseline IM&E losses at existing facilities by baseline
weighted AIF (in mgd).
b Benefits presented in this table do not include benefits associated with changes in greenhouse gas emissions.
Source: U.S. EPA analysis for this report
Table 12-4: Annual Benefits per MGD of Flow Reduction for New Units
by Loss Mode based on the SP Survey (2011$)a
IM&E Loss
Mode
5th Percentile
Mean
95th Percentile
IM
$9,117
$15,042
$20,950
E
$15,142
$23,464
$33,214
Notes:
IM = impingement mortality; E = entrainment
a EPA calculated benefits per mgd based on the SP survey by dividing the estimated value of baseline
IM&E losses at existing facilities by baseline weighted AIF (in mgd).
Source: U.S. EPA analysis for this report
12.2.3 IM&E Reductions and Associated Benefits under the final Rule and Options
Considered for New Units
Table 12-5 summarizes national IM&E reductions under the final rule for new units and options
considered. IM&E reductions will increase throughout the compliance period. The values
presented in Table 12-5 reflect the peak reduction achieved in 2059, the final year of the
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 12: Analysis of New Units
compliance period. The final rule for new units will result in a peak reduction of about 2.3 million
A1E.
Table 12-5: National IM&E Reductions under the Final Rule and Options Considered for
New Units3
Regulatory
Option
A1E (in millions)
Commercial and
Recreational Harvest
(millions of fish)
Forage Species
Commercial and
Recreational Species
All Species
Option A
303.94
123.86
427.81
12.28
Option B
109.53
44.64
154.17
4.43
Option C
16.12
6.57
22.69
0.65
Final Rule -
New Units
1.66
0.68
2.34
0.07
Notes:
A1E = age-one equivalent
a The IM&E reductions presented in this table reflect the peak reduction achieved in 2059, the final year of the compliance period.
Source: U.S. EPA analysis for this report
Table 12-6 presents national annualized benefits under the final rule and options considered for
new units based on the benefits estimation methods described in Chapters 5 through 8. Mean
annualized benefits under the final rule for new units will be $0.1 million using a 3 percent
discount rate and less than $0.1 million using a 7 percent discount rate. Annualized benefits under
other options considered for new units range from $ 1.1 to $21.4 million using a 3 percent
discount rate and $0.8 to $14.5 million using a 7 percent discount rate.
Table 12-7 presents national benefits for new units based on the results of the SP survey. Using
the SP survey, mean annualized benefits under the final rule for new units would be$3.3 million
using a 3 percent discount rate and $2.3 million using a 7 percent discount rate. Mean annualized
benefits under other options considered for new units range from $31.6 to $596.7 million using a
3 percent discount rate and from $22.4 to $423.1 million using a 7 percent discount rate. As noted
above, EPA has presented benefits estimates based the SP survey for illustrative purposes and
does not include values based on the SP survey in its quantitative comparison of costs and
benefits for the rule.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Chapter 12: Analysis of New Units
Table 12-6: National Annualized Benefits for IM&E Reductions under the Final Rule and Options Considered for
New Units (2011$, 1,000s)
Regulatory Option
Recreational
Commercial
T&E
Nonuse
Total Benefits
Low
Mean
High
Low
Mean
High
3 % Discount Rate
Option A
$4,138.2
$7,370.2
$13,553.0
$893.6
$90.7
$13,077.4
$18,199.9
$21,431.9
$27,614.7
Option B
$1,491.3
$2,656.0
$4,884.1
$322.0
$32.7
$4,712.8
$6,558.8
$7,723.5
$9,951.6
Option C
$219.5
$390.9
$718.9
$47.4
OO
$693.7
$965.4
$1,136.8
$1,464.7
Final Rule-New Units
$22.6
$40.2
$74.0
$4.9
$0.5
$71.4
$99.4
$117.0
$150.8
7%Discount Rate
Option A
$2,722.0
$4,848.0
$8,914.9
$587.8
$59.7
$8,958.6
$12,328.0
$14,454.0
$18,520.9
Option B
$980.9
$1,747.1
$3,212.7
$211.8
$21.5
$3,228.4
$4,442.7
$5,208.9
$6,674.5
Option C
$144.4
$257.1
$472.9
$31.2
$3.2
$475.2
$653.9
$766.7
$982.4
Final Rule-New Units
$14.9
$26.5
$48.7
$3.2
$0.3
$48.9
$67.3
$78.9
$101.1
Source: U.S. EPA analysis for this report
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Benefits Analysis for the Final 316(b) Existing Facilities
Chapter 12: Analysis of New Units
Table 12-7: National Annualized Benefits for IM&E Reductions
under the Final Rule and Options Considered for New Units
based on the SP Survey (2011$, millions)
Regulatory Option
5th Percentile
Mean
95th Percentile
3 % Discount Rate
Option A
$381.8
$596.7
$842.7
Option B
$137.6
$215.0
$303.7
Option C
$20.3
$31.6
$44.7
Final Rule-New Units
$2.1
$3.3
$4.6
7 % Discount Rate
Option A
$270.7
$423.1
$597.5
Option B
$97.6
$152.5
$215.3
Option C
$14.4
$22.4
$31.7
Final Rule-New Units
$1.5
$2.3
$3.3
Source: U.S. EPA analysis for this report
12.2.4 Limitations and Uncertainties for the Analysis of IM&E Reductions and
Associated Benefits for New Units
EPA's methodology for analyzing benefits from reducing IM&E at new units relies on the
estimated IM&E reductions and monetary benefits from the analysis of existing units. Thus, it is
subject to limitations and uncertainties inherent in the EPA's methodology for existing units.
Refer to Section 3.4 for a discussion of limitations and uncertainties in EPA's analysis of IM&E
for existing units and Chapters 5 through 8 for monetary benefits, and Chapter 11 for the SP
survey. Additional limitations and uncertainties specific to EPA's analysis of new units also
apply. These are addressed below in Table 12-8.
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Benefits Analysis for the Final 316(b) Existing Facilities Chapter 12: Analysis of New Units
Table 12-8: Limitations and Uncertainties in EPA's Analysis of IM&E Reductions and
Associated Benefits at New Units
Issue
Impact on
Benefits
Estimate
Comments
National rather than
regional flow reductions
Uncertain
EPA's analysis for existing units examined IM&E and the economic
benefits of reducing these losses at a regional scale. To obtain regional
IM&E estimates, EPA extrapolated losses observed at model facilities
to existing units at regulated facilities within the same region. Regional
flow reductions were unavailable for new units; therefore, EPA
extrapolated per mgd benefits to new units based on national benefits
and national weighted flow from the analysis for existing units. This
assumption could lead to the over- or under-estimation of benefits for
new units depending on their ultimate regional distribution.
Timing of flow
reductions
Uncertain
The annual flow reduction for new units is constant with the total flow
reduction increasing linearly over the compliance period. As a result,
peak IM&E is not achieved until the 2059, the final year of the
compliance period. This assumption would tend to under-estimate
annualized benefits if the new units come into operation sooner than
projected and over-estimate benefits if they come into operation later
than projected.
Engineering uncertainty
Uncertain
EPA's evaluation of IM&E was also affected by uncertainty about the
engineering and operating characteristics of the new units. Units
defined as "new" under the rule would be required to meet equivalent
performance to closed-cycle recirculating systems. EPA expects that
most new units will install wet cooling towers. EPA may over- or
under-estimate benefits for new units if the flow at new units and
percentage flow reduction due to the rule deviate from EPA's
assumptions. Refer to Chapter 8 of the TDD for additional information
on the engineering analysis for new units and potential uncertainties.
12.3 Analysis of Social Cost of Carbon for New Units
Because EPA does not expect Electric Generators to shut down to install cooling towers at new
units, for new units, EPA estimated the change in C02 resulting from the energy penalty only.
Energy penalty effects result from reduced energy conversion efficiency of the power generating
system. Refer to Appendix I of the economic analysis for the final rule (USEPA 2014) for
additional detail on compliance technology effects that impose costs via impact on revenue or
energy requirements.
12.3.1 Analysis Approach and Data Inputs
EPA estimated the monetary value of higher C02 emissions resulting from auxiliary energy
requirements associated with operating cooling towers as follows:
> EPA first calculated the amount of additional electricity (in MWh) required to operate
cooling towers at new units, assuming Electric Generators would incur this additional
energy requirement beginning in the first year any new generating unit would begin to
operate a cooling tower, i.e., 2017, through 2059.76
70 As discussed in Chapter 3 of the Economic Analysis, EPA estimates that facilities will require four years to install
cooling towers. EPA assumed that 2014 will be the first year when any Electric Generator will begin installation
of its cooling tower according to the new unit provision of the final rule.
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Benefits Analysis for the Final 316(b) Existing Facilities
Chapter 12: Analysis of New Units
> EPA next estimated the amount of fuel required to generate this additional electricity (in
BTUs). The Agency assumed that existing facilities will be able to generate additional
electricity onsite, i.e., at new units at those facilities. EPA estimated additional fuel
requirement for coal and combined cycle natural gas units by multiplying the additional
energy requirement by heat rates for coal and combined cycle natural gas electric
generating units, respectively.77
> The Agency then multiplied the resulting fuel usage values by coal or natural gas carbon
dioxide emissions coefficients published by EIA (USDOE 2013c), depending on the new
unit type, to estimate an increase in C02 emissions due to the energy penalty.78
> Finally, EPA multiplied the estimated C02 emission values, by year, by the same unit
SCC values as those used for Electric Generators (Table 9-3).
12.3.2 Key Findings for Regulatory Options
Table 12-9 presents the total reduction in C02 emissions and associated SCC values in 2013 for
new units at Electric Generators, by option and discount rate. EPA estimates that the new unit
provision of the final rule will result in a total increase of 0.3 million of tC02eq. Using the 3
percent average SCC values, EPA estimates the average annual benefit associated with this
increase in carbon emissions to be -$0.3 million at the 3 percent discount rate and -$0.2 million at
the 7 percent discount rate. EPA estimates that under the other new units options considered -
Options A, B, and C -total carbon emissions would increase by 22.0, 8.9, and 2.0 million of
tC02eq, respectively. Using the 3 percent average SCC values, EPA estimates the average
annual, benefit associated with these increases in carbon emissions to be -$22.5 million, -$9.1
million, and -$2.1 million at the 3 percent discount rate and -$13.8 million, -$5.6 million, and
-$1.3 million at the 7 percent discount rate, respectively.
Table 12-9: Reduction in Carbon Emissions and Associated Average Annual Benefits -
New Units (SCC Values in 2013; 2
>2011, millions]
Discount Rate for Calculating SCC Unit Values
Option
Total Emissions
2.5%
3%
5%
(Millions; tC02eq)
Average SCC
Value
Average SCC
Value
High SCC Value
Average SCC
Value
3% Discount Rate for Annualizing Benefits
Option A
-22.0
-$31.3
-$22.5
-$69.7
-$7.7
Option I '>
-8.9
.
-$9 1
-$28 1
-$3 1
Option C
-2.0
-$2 <»
-$2.l
-$6.4
-$0 7
Final Rule - New
Units
-0.3
-$0.4
-$0.3
-$0.9
-$0.1
7% Discount Rate for Annualizing Benefits
Option A
-22.0
-$19.5
-$13.8
-$42.8
-$4.6
Option I '>
-8.9
-$7<>
-$5 6
Option C
-2.0
;
-$1.3
-$ i 9
-$0 4
Final Rule - New
Units
-0.3
-$0.3
-$0.2
-$0.6
-$0.1
Source: U.S. EPA analysis for this report
77 EPA used heat rates based on higher heating values (HHV) of fuel.
78 For details see Carbon Dioxide Emissions Coefficients by Fuel published on February 14, 2013 available online at
http://www.eia.gov/environinent/eniissions/co2_vol_mass.cfm.
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Benefits Analysis for the Final 316(b) Existing Facilities
Chapter 12: Analysis of New Units
12.4 Monetized Benefits for New Units
Table 12-10 summarizes the annual monetized benefits associated with IM&E reductions and
changes in GHG emissions for new units. Using 3 percent average SCC values, mean annualized
benefits for the final rule for new units are -$0.2 million using a 3 percent discount rate and -$0.1
million using a 7 percent discount rate. Benefits for other options considered for new units range
from -$0.9 to -$1.1 million using a 3 percent discount rate and -$0.5 to $0.6 million using a 7
percent discount rate.
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Benefits Analysis for the Final 316(b) Existing Facilities
Chapter 12: Analysis of New Units
Table 12-10: National Annualized Benefits under the Final Rule and Options Considered for New Units (2011$,
millions)
Regulatory Option
Recreational
Commercial
T&E
Nonuse
Total Benefits
Low
Mean
High
Low
Mean
High
3 % Discount Rate
Option A
$4,138.2
$7,370.2
$13,553.0
$893.6
$90.7
$13,077.4
$18,199.9
$21,431.9
$27,614.7
Option B
$1,491.3
$2,656.0
$4,884.1
$322.0
$32.7
$4,712.8
$6,558.8
$7,723.5
$9,951.6
Option C
$219.5
$390.9
$718.9
$47.4
OO
$693.7
$965.4
$1,136.8
$1,464.7
Final Rule-New Units
$22.6
$40.2
$74.0
$4.9
$0.5
$71.4
$99.4
$117.0
$150.8
7%Discount Rate
Option A
$2,722.0
$4,848.0
$8,914.9
$587.8
$59.7
$8,958.6
$12,328.0
$14,454.0
$18,520.9
Option B
$980.9
$1,747.1
$3,212.7
$211.8
$21.5
$3,228.4
$4,442.7
$5,208.9
$6,674.5
Option C
$144.4
$257.1
$472.9
$31.2
$3.2
$475.2
$653.9
$766.7
$982.4
Final Rule-New Units
$14.9
$26.5
$48.7
$3.2
$0.3
$48.9
$67.3
$78.9
$101.1
Source: U.S. EPA analysis for this report
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Benefits Analysis for the Final 316(b) Existing Facilities
Chapter 13: National Summary
13 Summary of National IM&E Reductions and Benefits for Existing
and New Units
13.1 Introduction
This chapter summarizes the results of the seven regional analyses, and presents EPA's estimates of the
national benefits of the final rule and options considered for new and existing units at regulated facilities.
As described in Chapter 1, EPA considered three options for the existing units based on two technologies:
> Proposal Option 4: IM for Facilities > 50 mgd. Establish impingement mortality controls at
all existing facilities that withdraw over 50 mgd; determine entrainment controls for facilities
greater than 2 mgd DIF on a site-specific basis.
> Final Rule - Existing Units: IM Everywhere. Establish impingement mortality controls at all
existing facilities that withdraw over 2 mgd; determine entrainment controls for facilities
greater than 2 mgd DIF on a site-specific basis.
> Proposal Option 2: IM Everywhere and E for Facilities > 125 mgd. Establish impingement
mortality controls at all existing facilities that withdraw over 2 mgd DIF; require flow reduction
commensurate with closed-cycle recirculating system for entrainment control by facilities
greater than 125 mgd DIF.
The final rule will establish entrainment controls for facility greater than 2 mgd DIF on a site-specific
basis, as would Proposal Option 4. EPA did not analyze entrainment benefits under the final rule or
Proposal Option 4 because entrainment requirements are site specific.
EPA considered four regulatory options for new units at existing facilities:
> Option A: Entrainment performance requirements for all stand-alone new units and all types of
repowered units.
> Option B: Entrainment performance requirements for all stand-alone new units, and replaced
or repowered units in which the turbine or condenser are newly built or replaced.
> Option C: Entrainment performance requirements for all stand-alone new units, and repowered
new units where the turbine and condenser are newly built or replaced, but excluding high
efficiency systems.
> Final Rule - New Units (Option D): Entrainment performance requirements for all stand-
alone new units only.
Refer to Section VI of the preamble for additional description of the final rule and other options
considered for existing and new units.
Section 13.2 describes EPA's methodology for aggregating benefits at the national level; Section 13.3
summarizes baseline IM&E and estimated reductions in IM&E under the final rule and options
considered; Section 13.4 presents national benefits; and Section 13.5 summarizes results of the SP survey,
and Section 13.6 discusses nonuse benefits and presents a break-even analysis.
13.2 Summary of Limitations and Uncertainties
EPA notes that quantifying and monetizing the benefits that result from reductions in IM&E and GHG
emissions under the final rule and options considered for the existing facilities rule is challenging. The
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities
Chapter 13: National Summary
preceding sections discuss specific limitations and uncertainties associated with estimating reductions in
IM&E and monetized benefits. EPA estimated national-level benefits associated with IM&E reductions
by summing benefit estimates over the seven study regions. Thus, national benefit estimates are subject to
the same uncertainties inherent in the valuation approaches EPA used for assessing each of the four
benefit categories associated with IM&E reductions (threatened and endangered species, commercial
fishing, recreational fishing, and nonuse values). The combined effect of these uncertainties is of
unknown magnitude and direction (i.e., the estimates may over- or understate the anticipated national
level of use benefits). Nevertheless, EPA has no data to indicate that the results for any of the benefit
categories are atypical or unreasonable. EPA's analysis of changes in GHG emissions and associated
benefits was conducted at the national level, regional benefits were not estimated. EPA calculated
national benefits based on the SP survey estimates by summing results for the four SP survey regions. As
noted above, estimates based on EPA's SP survey are included to illustrate the potential magnitude of
total values of ecological improvements resulting from the final rule.
13.3 Summary of Baseline IM&E Losses and IM&E Reductions
Based on the results of the regional analyses, EPA calculated total IM&E under baseline (i.e., pre-
regulatory) conditions and the total amount by which losses would be reduced under the final rule and
options considered. The number of fish lost at regulated facilities is presented in terms of A1E losses (i.e.,
the number of individual fish of different ages impinged and entrained by facility intakes, expressed as
A1E).
Table 13-1 presents baseline impingement, entrainment, and total IM&E for existing units. The table
shows that total national annual losses for all regulated facilities are 1.9 billion fish in terms of A1E. EPA
notes that the count of total lost organisms is larger than values expressed in A1E. This table shows that
about 39 percent, or 0.8 billion fish of all A IE losses, occur in the Inland region, followed by the Mid-
Atlantic region with 0.6 billion fish lost. Chapter 3 provides a more detailed discussion of IM&E in each
region.
Table 13-1: Baseline National A1E Losses at All Regulated Facilities (millions of
A1E)
Region
IM
E
IM&E
California
1.1
50.4
51.5
North Atlantic
0.6
57.2
57.9
Mid-Atlantic
39.1
591.9
631.0
South Atlantic
17.1
9.2
26.4
liulf of Mexico
53.5
93.5
147.0
Great Lakes
236.7
24.6
261.3
Inland
476.0
279.9
756.0
Total
824.2
1,106.7
1,931.0
Notes:
A1E = age-one equivalent; IM = impingement mortality; E = entrainment; IM&E = impingement mortality and entrainment
Source: U.S. EPA analysis for this report
EPA also calculated the total national IM&E avoided based on the expected reductions in IM&E at each
facility due to technology installation required by the final rule and under each option considered. Table
13-2 through Table 13-4 present expected annual reductions at existing units, expressed as A1E, by
region. The final rule will reduce annual A1E losses by 0.7 billion fish existing units. In comparison,
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities
Chapter 13: National Summary
Proposal Option 4 would reduce A1E losses by 0.6 billion fish and Proposal Option 2 would reduce
annual A1E losses by 1.6 billion fish. Table 13-5 presents reductions in A1E losses for the final rule and
options considered for new units. The final rule, including both new and existing units, will reduce A1E
losses by 0.7 billion fish (Table 13-6).
Table 13-2: Reductions in National A1E Losses for All Regulated Facilities (millions
of A1E) under Proposal Option 4
Region
IM
E
IM&E
California
0.7
<0.01
0.7
North Atlantic
0.4
<0.01
0.4
Mid-Atlantic
29.6
0.93
30.5
South Atlantic
11.6
<0.01
11.6
Gulf of Mexico
38.7
0.08
38.8
Great Lakes
184.0
0.02
184.0
Inland
347.7
0.39
348.1
Total
612.8
1.41
614.2
Notes:
A1E = age-one equivalent; IM = impingement mortality; E = entrainment; IM&E = impingement mortality and entrainment
Source: U.S. EPA analysis for this report
Table 13-3: Reductions in National A1E Losses for All Regulated Facilities (millions
of A1E) under the Final Rule
Region
IM
E
IM&E
California
0.7
<0.01
0.7
North Atlantic
0.4
0.51
0.9
Mid-Atlantic
31.6
1.40
33.0
South Atlantic
12.4
0.48
12.9
Gulf of Mexico
40.2
0.08
40.3
Great Lakes
202.5
0.06
202.6
Inland
359.6
2.00
361.6
Total
647.5
4.53
652.0
Notes:
A1E = age-one equivalent; IM = impingement mortality; E = entrainment; IM&E = impingement mortality and entrainment
Source: U.S. EPA analysis for this report
Table 13-4: Reductions in National A1E Losses for All Regulated Facilities (millions
of A1E) under Proposal Option 2
Region
IM
E
IM&E
California
0.8
30.8
31.5
North Atlantic
0.6
43.8
44.4
Mid-Atlantic
36.1
515.8
551.9
South Atlantic
17.0
8.6
25.6
Gulf of Mexico
48.2
55.2
103.4
Great Lakes
230.8
17.7
248.5
Inland
414.7
217.4
632.2
Total
748.2
889.3
1,637.5
Notes:
A1E = age-one equivalent; IM = impingement mortality; E = entrainment; IM&E = impingement mortality and entrainment
Source: U.S. EPA analysis for this report
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities
Chapter 13: National Summary
Table 13-5: Reductions in National A1E Reductions under the Final Rule and Options
Considered for New Units (millions of A1E)
Regulatory Option
IM
E
IM&E
Option A
74.5
353.3
427.8
Option B
26.8
127.3
154.2
Option C
4.0
18.7
22.7
Final Rule - New Units
0.4
1.9
2.3
Notes:
A1E = age-one equivalent; IM = impingement mortality; E = entrainment; IM&E = impingement mortality and entrainment
Source: U.S. EPA analysis for this report
Table 13-6: Reductions in National A1E Reductions under the Final Rule - Existing
and New Units (millions of A1E)
Regulatory Option
IM
E
IM&E
Final Rule-Existing Units
647.5
4.5
652.0
Final Rule-New Units
0.4
1.9
2.3
Final Rule-Existing and
New Untis
647.9
6.5
654.3
Notes:
A1E = age-one equivalent; IM
= impingement mortality; E = entrainment; IM&E = impingement mortality and entrainment
Source: U.S. EPA analysis for this report
Table 13-7 presents EPA's estimates of the current level of total annual IM&E and the reduction in total
annual IM&E for the baseline, final rule and other options considered for existing units using the three
metrics presented in Section 3.2.2. The final rule will provide greater IM&E reductions at existing units
than Proposal Option 4, but lesser IM&E reductions than Proposal Option 2. Table 13-8 presents IM&E
reductions under the final rule and other options considered for new units according to the same metrics
as Table 13-7. The final rule, including both new and existing units, will reduce annual foregone fishery
yield by 13.5 million pounds and annual biomass prodution foregone by 139.8 million pounds (Table
13-9).
Table 13-7: Baseline National IM&E and IM&E Reductions for Regulated Facilities for
the Final Rule and Options Considered
Regulatory Option
Millions of A1E
Foregone Fishery
Yield
(million lbs)a
Biomass Production Forgone
(million lbs)
Proposal Option 4
614.2
12.6
130.3
Final Rule-Existing
Units
652.0
13.4
138.9
Proposal Option 2
1.637.5
51.1
494.2
Baseline
1.931.0
69.8
626.6
Notes:
A1E = age-one equivalents
a The reductions in foregone fishery yield presented here are equal to increases in commercial and recreational harvest. Refer to
Chapter 3 for additional detail regarding the calculation of foregone fishery yield and biomass production forgone.
Source: U.S. EPA analysis for this report
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities
Chapter 13: National Summary
Table 13-8: Reductions in IM&E under the Final Rule and Options Considered for New
Units
Regulatory Option
Millions of A1E
Foregone Fishery
Yield
(million lbs)a
Biomass Production Forgone
(million lbs)
Option A
427.8
18.4
160.0
Option I '>
154.2
6.6
57.7
Option C
111
l.o
8.5
Final Rule-New Units
2.3
0.1
0.9
Notes:
A1E = age-one equivalents
a The reductions in foregone fishery yield presented here are equal to increases in commercial and recreational harvest. Refer to
Chapter 3 for additional detail regarding the calculation of foregone fishery yield and biomass production forgone.
Source: U.S. EPA analysis for this report
Table 13-9: Reductions in IM&E under the Final Rule - Existing and New Units
Regulatory Option
Millions of A1E
Foregone Fishery
Yield
(million lbs)a
Biomass Production Forgone
(million lbs)
Final Rule-Existing
Units
652.0
13.4
138.9
Final Rule-New Units
2.3
0.1
0.9
Final Rule-Existing and
New Units
654.3
13.5
139.8
Notes:
A1E = age-one equivalents
a The reductions in foregone fishery yield presented here are equal to increases in commercial and recreational harvest. Refer to
Chapter 3 for additional detail regarding the calculation of foregone fishery yield and biomass production forgone.
Source: U.S. EPA analysis for this report
As shown for all regions in Table 13-10, Table 13-11, Table 13-12, and by region in Chapter 3, the
harvested commercial and recreational fish species that have direct use values comprise between 1 and 9
percent of baseline IM&E in each region, resulting in a national average of only 3 percent of IM&E for
which EPA monetized value based on direct use. The remaining 97 percent of IM&E includes
unharvested recreational and commercial fish and forage fish which are not associated with direct use.
EPA's nonuse benefit transfer was limited to two of the seven benefits regions, and EPA did not include
nonuse values for unharvested fish in its primary benefits analysis for the remaining five regions. Thus,
EPA has likely understated the total benefits significantly due to the regional limitations of its nonuse
analysis and the relatively large fraction of IM&E reductions which are not commercially or
recreationally harvested.
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Benefits Analysis for the Final 316(b) Existing Facilities
Chapter 13: National Summary
Table 13-10: Distribution of National IM&E Reduction for Existing Units for All
Regulated Facilities for the Final Rule and Other Regulatory Options Considered
Regulatory Option
All
Species
(millions
of A1E)
Forage
Species
(millions of
A1E)
Commercial
and
Recreational
Species
(millions of
A1E)
Commercial
and
Recreational
Harvest
(millions of fish
harvested)
Percent of Fish
with Monetized
Use Value3
Proposal Option 4
614.2
528.2
85.9
16.1
2.6%
Filial Rule - Existing
Units
652.0
560.8
91.2
17.1
2.6%
Proposal Option 2
1,637.5
1,258.7
378.8
44.7
2.7%
Baseline
1,931.0
1,459.7
471.3
54.0
2.8%
Notes:
A1E = age-one equivalent
a "Percent of fish with monetized use value" is equal to "commercial and recreational harvest (millions of fish harvested)" divided
by "all species (millions of A1E)."
Source: U.S. EPA Analysis for this report
Table 13-11: Distribution of National IM&E Reductions under the Final Rule and Options
Considered for New Units
Regulatory Option
All
Species
(millions
of A1E)
Forage
Species
(millions of
A1E)
Commercial
and
Recreational
Species
(millions of
A1E)
Commercial
and
Recreational
Harvest
(millions of fish
harvested)
Percent of Fish
with Monetized
Use Value3
Option A
427.8
303.9
123.9
12.3
2.9%
Option B
154.2
109.5
44.6
4.4
2.9%
Option C
111
16.1
6.6
0.7
2.9%
Final Rule - New Units
2.3
1.7
0.7
0.1
2.9%
Notes:
A1E = age-one equivalent
a "Percent of fish with monetized use value" is equal to "commercial and recreational harvest (millions of fish harvested)" divided
by "all species (millions of A1E)."
Source: U.S. EPA Analysis for this report
Table 13-12: Distribution of National IM&E Reductions under the Final Rule
and New Units
- Existing
Regulatory Option
All
Species
(millions
of A1E)
Forage
Species
(millions of
A1E)
Commercial
and
Recreational
Species
(millions of
A1E)
Commercial
and
Recreational
Harvest
(millions of fish
harvested)
Percent of Fish
with Monetized
Use Value3
Final Rule-Existing
Units
652.0
560.8
91.2
17.1
2.6%
Final Rule-New Units
2.3
1.7
0.7
0.1
2.9%
Final Rule-Existing and
New Units
654.3
562.5
91.9
17.2
2.9%
Notes:
A1E = age-one equivalent
a "Percent of fish with monetized use value" is equal to "commercial and recreational harvest (millions of fish harvested)" divided
by "all species (millions of A1E)."
Source: U.S. EPA Analysis for this report
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Benefits Analysis for the Final 316(b) Existing Facilities
Chapter 13: National Summary
13.4 Summary of National Monetized Benefits
EPA based its estimates of total national baseline losses and total national benefits associated with IM&E
reductions under the final rule and options considered on its estimates of regional monetized baseline
losses and final rule and regulatory option benefits. To address the differences in the timing of benefits
and costs, EPA developed a time profile of total benefits from all regulated facilities that reflects when
benefits from compliance-related changes at each facility will be realized. EPA then discounted and
annualized benefits using 3 percent and 7 percent discount rates.79 Appendix D of this report provides
detail on EPA's development of the timeline of benefits.
EPA estimated mean national use values, as well as values that include the 5th percentile lower bound and
95th percentile upper bound of the recreational benefit estimates.80 Table 13-13 and Table 13-14 present
these results for each region and for the nation as a whole. The national benefit estimates do not include
benefits based on EPA's SP survey presented in Chapter 11.
Table 13-13 summarizes EPA's estimates of the regional and national annualized benefits of reducing
IM&E and GHG emissions under the final rule and each of the regulatory options EPA considered for
existing units (discounted at 3 percent and 7 percent). Table 13-14 presents the sum of benefits for the
final rule for existing units and new units. Refer to Chapter 10 for additional detail regarding benefits for
existing units and Chapter 12 for additional detail regarding benefits for new units. The national value of
these reductions in IM&E and GHG emissions, evaluated at a 3 percent discount rate, is as follows:
> Proposal Option 4 results in national benefits of $31.0 million per year, with estimates based on
the 5th percentile lower bound and 95th percentile upper bound for recreational values, totaling
$22.8 million and $47.6 million (Table 13-13).
> The final rule for existing units results in national benefits of $33.0 million per year, with
estimates based on the 5th percentile lower bound and 95th percentile upper bound for
recreational values, totaling $24.1 million and $50.6 million (Table 13-13). Including
requirements for new units, the final rule results in national benefits of $32.8 million per year,
with estimates based on the 5th percentile lower bound and 95th percentile upper bound for
recreational values, totaling $23.9 million and $50.5 million (Table 13-14).
> Proposal Option 2 results in national benefits of -$1,542.6 million per year, with estimates
based on the 5th percentile lower bound and 95th percentile upper bound for recreational values,
totaling -$l,562.2million and -$1,504.5 million (Table 13-13).
Evaluated at a 7 percent discount rate, the national use benefits of the regulatory analysis options are
somewhat smaller for the final rule and Proposal Option 4, and greater for Proposal Option 2:
> Proposal Option 4 results in national benefits of $27.2 million per year, with estimates based on
the 5th percentile lower bound and 95th percentile upper bound for recreational values, totaling
$21.1 million and $39.5 million (Table 13-13).
79 The 3 percent rate represents a reasonable estimate of the social rate of time preference. The 7 percent rate represents an
alternative discount rate, recommended by the Office of Management and Budget (OMB) that reflects an estimated
opportunity cost of capital.
80 The lower estimates of value presented in this chapter are measured by the sum of the 5th percentile lower bound estimates
of recreational values plus the mean value estimates for all other categories of value. The higher estimates of value presented
in this chapter are measured by the sum of the 95th percentile upper bound estimates of recreational values plus the mean
value estimates for all other categories of value.
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities
Chapter 13: National Summary
> The final rule for existing units results in national benefits of $28.7 million per year, with
estimates based on the 5th percentile lower bound and 95th percentile upper bound for
recreational values, totaling $22.2 million and $41.8 million (Table 13-13). Including
requirements for new units, the final rule results in national benefits of $28.6 million per year,
with estimates based on the 5th percentile lower bound and 95th percentile upper bound for
recreational values, totaling $22.1 million and $41.7 million (Table 13-14).
> Proposal Option 2 results in national use benefits of -$1,148.2 million per year, with estimates
based on the 5th percentile lower bound and 95th percentile upper bound for recreational values,
totaling -$1,161.7 million and -$1,122.0 million (Table 13-13).
More detailed discussions of benefits under each option are provided in Chapters 5 through 9. National
benefits for new units are discussed in Chapter 12.
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities
Chapter 13: National Summary
Table 13-13: Summary of National Annualized Benefits for Existing Units for All Regulated Facilities ((2011$, millions)3
Regulatory
Option
Recreational Fishing Benefits
Commercial
Fishing
Benefits0
T&E Species
Benefits"'
Nonuse
Benefits
scce
Total Benefits
Low
Mean
High
Low
Mean
High
3% Discount Rate
Proposal Option 4
00
OO
ee
$17.1
$33.6
$0.9
$0.4
$0.3
$12.4
$22.8
$31.0
$47.6
Filial Rule
$9.4
$18.2
$35.9
$0.9
$0.4
$1.0
$12.4
$24.1
$33.0
$50.6
Proposal Option 2
$23.4
$43.0
$81.1
$3.9
$0.7
$51.1
-$1,641.3
-$1,562.2
-$1,542.6
-$1,504.5
7% Discount Rate
Proposal Option 4
$6.5
$12.6
$24.9
$0.7
$0.3
$0.3
$13.4
$21.1
$27.2
$39.5
Final Rule
$7.0
$13.5
$26.6
$0.7
$0.3
$0.8
$13.4
$22.2
$28.7
$41.8
Proposal Option 2
$16.1
$29.5
$55.8
$2.7
$0.5
$37.3
-$1,218.2
-$1,161.7
-$1,148.2
-$1,122.0
a All benefits presented in this table are annualized, i.e., represent the sum of the discounted stream of benefits annualized over 51 years (2014 to 2064). See Appendix D for detail.
b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value per fish predicted by the meta-
analysis. Commercial fishing benefits are computed based on a region- and species-specific range of gross revenue, as explained in Chapter 6 of this report. EPA estimated recreational use
benefits for some T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commercial fishing benefits and T&E species benefits
are added to the respective low, mean, and high values for recreational fishing benefits.
c No significant commercial fishing takes place in the Inland region. Thus, this region is excluded from the commercial fishing analysis.
11 Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon).
See Chapter 5 of this report for more detail on EPA's analysis of T&E benefits.
e SCC results presented here are based on 3 percent average SCC values.
Source: U.S. EPA analysis for this report
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities
Chapter 13: National Summary
Table 13-14: Summary of National Annualized Benefits for the Final Rule for Existing Units and New Units (2011$, millions)3
Regulatory
Option
Recreational Fishing Benefits
Commercial
Fishing Benefits0
T&E Species
Benefits'1'6
Nonuse
Benefits
SCC
Total Benefits
Low
Mean
High
Low
Mean
High
3% Discount Rate
Final Rule -
Existing Units
$9.4
$18.2
$35.9
$0.9
$0.4
$1.0
$12.4
$24.1
$33.0
$50.6
Final Rule - New
Units
$0.0
$0.0
$0.1
$0.0
$0.0
$0.1
-$0.3
-$0.2
-$0.2
-$0.1
Final Rule -
Existing Units +
New Units
$9.4
$18.3
$36.0
$0.9
$0.4
$1.1
$12.1
$23.9
$32.8
$50.5
7% Discount Rate
Final Rule -
Existing Units
$7.0
$13.5
$26.6
$0.7
$0.3
$0.8
$13.4
$22.2
$28.7
$41.8
Final Rule - New
Units
$0.0
$0.0
$0.0
$0.0
$0.0
$0.0
-$0.2
-$0.1
-$0.1
-$0.1
Final Rule -
Existing Units +
New Units
$7.0
$13.5
$26.7
$0.7
$0.3
$0.9
$13.2
$22.1
$28.6
$41.7
a All benefits presented in this table are annualized, i.e., represent the sum of the discounted stream of benefits annualized over 51 years (2014 to 2064). See Appendix D for detail.
b A range of recreational fishing benefits is provided, based on the Krinsky and Robb technique, to estimate the 5th and 95th percentile limits on the marginal value per fish predicted by the meta-
analysis. Commercial fishing benefits are computed based on a region- and species-specific range of gross revenue, as explained in Chapter 6 of this report. EPA estimated recreational use
benefits for some T&E species, as explained in Chapter 5. To calculate the total monetizable value columns (low, mean, high), the values for commercial fishing benefits and T&E species benefits
are added to the respective low, mean, and high values for recreational fishing benefits.
c No significant commercial fishing takes place in the Inland region. Thus, this region is excluded from the commercial fishing analysis.
11 Recreational use benefits from increased abundance of T&E species with potentially high recreational use values (e.g., paddlefish and sturgeon).
See Chapter 5 of this report for more detail on EPA's analysis of T&E benefits.
e SCC results presented here are based on 3 percent average SCC values.
Source: U.S. EPA analysis for this report.
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities
Chapter 13: National Summary
13.5 Results based on the SP Survey
Table 13-15 and Table 13-16 summarize national benefit estimates for the final rule and options
considered for existing and new units based on EPA's SP survey. The national totals are based on
the sum of estimates for each survey region. As described in Chapter 12, EPA does not include
benefit estimates based on the survey in its comparison of benefits and costs for the final rule and
options considered. However, the magnitude of benefits estimated based on the survey results
illustrate that total values of ecological improvements may be substantially greater than the partial
monetized benefits used for the benefit cost comparison (Table 13-13 and Table 13-14).
Table 13-15: Summary of National Benefits for the Final Rule and Options Considered for
Existing Units based on the SP Survey (2011$, millions)
Regulatory Option
3 % Discount Rate
7 % Discount Rate
5th
Mean
95th
5th
Mean
95th
Proposal Option 4
$829.1
$1,363.1
$1,898.8
$642.6
$1,056.8
$1,472.2
Filial Rule - Existing Units
$880.5
$1,448.8
$2,019.0
$682.5
$1,123.2
$1,565.3
Proposal Option 2
$2,159.9
$3,430.7
$4,823.7
$1,442.4
$2,294.5
$3,226.1
Source: U.S. EPA analysis for this report
Table 13-16: Summary of National Benefits for the Final Rule for Existing and New Units
based on the SP Survey (2011$, millions)
Regulatory Option
3 % Discount Rate
7 % Discount Rate
5th
Mean
95th
5th
Mean
95th
Final Rule - Kxisting Units
$880.5
$1,448.8
$2,019.0
$682.5
$1,123.2
$1,565.3
Final Rule - New Units
$2.1
$3.3
$4.6
$1.5
$2.3
$3.3
Final Rule - Kxisting and
New Units
$882.6
$1,452.1
$2,023.6
$683.9
$1,125.5
$1,568.6
Source: U.S. EPA analysis for this report
13.6 Break-Even Analysis
Comprehensive estimates of total resource value include both use and nonuse values and may be
compared to total social cost. Recent economic literature provides strong support for the
hypothesis that mean nonuse values are greater than zero. This is supported by the results of
EPA's stated preference survey as described in Section 13.5. The per-capita nonuse values need
not be large to result in substantial benefits for the final rule. When small per-capita nonuse
values are held by a substantial fraction of the population, the aggregate value can be very large.
However, in this specific context, EPA included nonuse values for only two of the seven benefits
regions within its primary estimates of national benefits for the final rule and other options
considered. EPA did include benefit estimates based on the SP survey in its comparison of
benefits and costs for the final rule and options considered.
As shown in Table 13-12 above, nearly all—97 percent—IM&E at cooling water intake
structures under current conditions (the baseline scenario) consist of either forage species or
unlanded recreational and commercial species that are not harvested and thus not reflected in
EPA's estimated direct use values. Although individuals do not use these resources directly, they
may value changes in the status or quality of these resources. EPA did not include nonuse values
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Benefits Analysis for the Final 316(b) Existing Facilities
Chapter 13: National Summary
for forage and unlanded species occurring in five of the seven benefits regions. Due to the
uncertainties of providing estimates of the magnitude of nonuse values associated with the
regulatory options for all regions, this section provides an alternative approach. EPA used an
alternative "break-even" analysis approach for evaluating the potential relationship between costs
and benefits associated with IM&E reductions. This approach identifies what the unmonetized
nonuse values would have to be in order for the benefits of the proposed options to equal costs.
To calculate a break-even value, EPA subtracted its estimates of monetized commercial and
recreational use benefits for the final rule and regulatory options considered from the estimated
annual compliance costs incurred by facilities subject to the final rule. The resulting "net cost"
enabled EPA to work backwards to estimate what the nonuse values would need to be (in terms
of WTP per household per year) in order for total annualized benefits to equal annualized costs.
Table 13-17 provides this assessment for the final rule and options considered. The table shows
benefit values using a 3 percent or 7 percent discount rate, respectively.
As shown in Table 13-17, for total annualized benefits to equal total annualized costs, nonuse
values per household would have to be at least $2.27 for the final rule using a 3 percent discount
rate and $2.59 using a 7 percent discount rate.
Table 13-17: Implicit Nonuse Value—Break-Even Analysis (2011$)
Use
Number of
Annual
Benefits of
Annual
Annual Nonuse
Households in
Break-Even
Regulatory
IM&E
Social Cost
Benefits Necessary
States with
Nonuse
Option3
Reductions
(2011$,
millions)3
(2011$,
millions)b
to Break Even
(2011$)c
Regulated
Facilities
(millions)d
WTP per
Household
(2011$)e
3% Discount Rate
Proposal Option 4
$19.6
$251.8
$232.2
114.9
$2.02
Filial Rule -
Existing and New
$14.5
$274.9
$260.4
114.9
$2.27
Units
Proposal Option 2
$0.0
$3,643.2
$3,643.2
114.9
$31.72
7% Discount Rate
Proposal Option 4
$14.5
$272.1
$257.6
114.9
$2.24
Final Rule -
Existing and New
$0.0
$297.3
$297.3
114.9
$2.59
Units
Proposal Option 2
$0.0
$3,583.0
$3,583.0
114.9
$31.19
a Benefits are discounted using a 3% or 7% discount rate, respectively. Use benefits include estimated commercial fishing benefits.
recreational fishing benefits, and use benefits for T&E species.
b The total social cost of the final rule includes facility compliance costs and administrative costs.
c Annualized compliance costs minus annualized use benefits.
11 Includes households in states with at least one surveyed facility. Household counts are based on Census 2010 (U.S. Census Bureau
2010).
e Dollars per household per year that, when added to use benefits, would yield a total annualized benefit (use plus nonuse) equal to
the annualized costs.
Source: U.S. EPA analysis for this report; U.S. Census Bureau, 2010
While this approach of backing out the "break-even" nonuse value per household does not answer
the question of what nonuse values might actually be for the final rule and regulatory options
considered, these results do frame what the unknown values would have to be in order for
benefits to equal or exceed costs. The break-even approach poses the question: "Is the true per-
household WTP for the nonuse amenities (existence and bequest) associated with an option likely
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Benefits Analysis for the Final 316(b) Existing Facilities
Chapter 13: National Summary
to be greater or less than the 'break-even' benefit levels displayed in Table 13-17?" The results of
EPA's SP survey (Chapter 11) illustrate the potential magnitude of nonuse and total values for
316(b) regulatory options and suggest that household values may exceed the break-even point for
the final rule. Mean household WTP for the final rule based on the survey ranges from $0.69 in
the Pacific region to $27.57 in the Inland region.
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Chapter 14: References
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Appendix A: Extrapolation Methods
Appendix A: Extrapolation Methods
A.1 Introduction
This appendix provides detail on estimating facility-level weights used in estimating benefits at a
regional level. EPA built its weighting approach on the sample weights developed for
manufacturing facilities and electric power generating facilities in the analysis of 316(b) Phase II
and Phase III regulations (USEPA 2004a; USEPA 2006b). EPA expanded on the existing
approach by developing new facility-level weights that account for differences between electric
power facilities that received the Detailed Questionnaire (DQ) and those that received the Short
Technical Questionnaire (STQ), and to account for facility location, a key parameter in the
benefits analysis. EPA used this new set of "benefits weights" to estimate baseline IM&E losses
and reductions in IM&E losses under the final rule and other options considered and to adjust for
the timing of these reductions and associated benefits.
A.2 Manufacturing Facilities
The current analysis of manufacturing facilities incorporates a set of weights that EPA developed
for the 2006 Final Phase III Rule, which EPA refers to as technical weights. The technical
weights are based on engineering information obtained from the 316(b) Manufacturers
Questionnaire. The technical weights account for the number of affected facilities and the cost of
installing new technology, but do not account for facility location or intake flow at a regional
level. EPA developed additional adjustments to the technical weights because IM&E losses are a
function of facility location and intake flow. The purpose of the additional adjustments is to
ensure thatweighted regional mean operational, or actual, intake flow (AIF)for survey facilities is
consistent with EPA's best estimates for all regulated manufacturing facilities in each of eight
regions: North Atlantic, Mid-Atlantic, South Atlantic, Gulf of Mexico, California, Pacific
Northwest,81 Great Lakes, and Inland regions.82
EPA developed the weight adjustments separately for traditional manufacturers (MN facilities)
and non-utility manufacturers (MU facilities).83 Data was not available for total regional intake
flow for MN and MU facilities. Thus, rather than calibrating the weights based on flow, EPA
calibrated them based on facility counts such that the weighted number of surveyed facilities in
each region equals the total number of facilities in that region. This approach assumes that the
flow characteristics of the non-surveyed facilities, which are represented by weights, are the same
as surveyed facilities (DQ facilities).
81 The Pacific Northwest region ultimately is excluded from the benefits analysis because it includes a single DQ
facility which is projected to close as baseline.
82 See Chapter 1 for additional information regarding regional definitions.
83 MN facilities include aluminum, steel, chemical, pulp and paper, and petroleum refining manufacturing industries.
Note that Food and Kindred Products is not included in this list of industries for two reasons: a) this industry was
not included in the original stratification of manufacturers, and b) all facilities later identified to be in the Food and
Kindred Product industries were part of the MU universe.
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix A: Extrapolation Methods
The following two sections describe development of weight adjustment factors for MN and MU
facilities, respectively.
A.2.1 Traditional Manufacturers (MN Facilities)
EPA stratified the universe of MN facilities by region and industry category.84 EPA first
determined the distribution of regulated facilities by study region, and then calculated adjusted
benefits weights based on this distribution.
A.2.1.1 Determining the Distribution of Regulated Facilities by Study Region
The industry survey requested that responding facilities provide Standard Industrial Classification
(SIC) codes.85 EPA used PCS (Permit Compliance System) and ICIS-NPDES (Integrated
Compliance Information System- NPDES) to obtain latitude-longitude coordinates (lat-long) for
all facilities in relevant SIC codes. Facilities within relevant SIC codes were assigned to a study
region using lat-long. A map of RF1 reacheswas also used to indicate whether the facility location
is coastal/estuarine or inland.86 Table A-l presents the distribution of the facility universe
according to region and industry based on the PCS/ICIS data.
The sample frame for the survey screener of manufacturing facilities did not include all facilities
in the relevant SIC codes. Information on which facilities were included is not available.
Therefore, EPA used two simplifying assumptions to develop weight adjustment factors: (1) the
total number regulated facilities in any single industry equals the sum of technical weights,87 and
(2) the geographic distribution of NPDES permitted facilities in the relevant SIC codes is
representative of the geographic distribution of regulated facilities.
For each industry, EPA assumed that the geographic distribution of facilities included in the EPA
PCS/ICIS database is equivalent to the geographic distribution of the DQ sample frame. To
implement this assumption, EPA redistributed the weights of DQ facilities in each study region to
match the geographic distribution of facilities in the PCS/ICIS database. The second and third
columns in Table A-l present the estimated distribution of regulated MN facilities based on
PCS/ICIS data.88
A.2.1.2 Calculating Adjusted Weights for the Benefits Analysis
EPA first compared the regional distribution of DQ facilities to the distribution of facilities
present in the PCS/ICIS universe. Table A-l presents the distribution of DQ facilities based on
technical weights, the weight adjustment factors for MN facilities, and the expected number of
84 EPA did not adjust weights for petroleum refineries because survey screeners were sent to the entire universe and
DQs were sent to all regulated facilities. EPA assigned a weight of 1 to facilities determined to be in other
industries after receipt of the DQ. No adjustment was made to these weights.
85 The SIC code describes the primary activity of the facility. EPA did not convert SIC codes to North American
Industry Classification codes (NAICS) when developing benefits weights because the industry survey used SIC
codes and relevant databases were searchable by SIC code.
80 EPA's reach file (RF1) is a database of interconnected steam segments of "reaches" that comprise the surface
water drainage system for the United States.
87 As noted in Section A.2, the technical weights account for the number of affected facilities.
88 EPA used the following databases to obtain information on the number of facilities in each SIC code: FRS
(Federal Registry System), PCS (Permit Compliance System), ICIS-NPDES (Integrated Compliance Information
System- NPDES) and TRI (Toxics Release Inventory). None of these databases contains intake flow.
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix A: Extrapolation Methods
DQ facilities for all regions. EPA re-estimated the number of DQ facilities in each region using
the PCS/ICIS distribution of facilities in that region. This adjustment factor was defined as the
quotient of the number of DQ facilities within a region and industry divided by the original
number of weighted DQ facilities assigned to the same stratum. If the PCS/ICIS facilities
universe indicated that a region had a small number of facilities within a single industry and did
not have DQ facilities (e.g., the North Atlantic region for the Aluminum sector), EPA assumed
that no regulated facilities exist within the stratum.
Because regions without DQ facilities comprised a small fraction of the PCS/ICIS facility
universe, this assumption is likely to introduce negligible error. If the adjusted weight for a
sample DQ facility was less than one, EPA used a weight of one to fully count the flow. In the
economic analysis, EPA estimated that 20 MN facilities will close under baseline conditions.
Accordingly, EPA excluded these facilities from the weights readjustment and benefits analysis.
The final two columns of Table A-l present estimated total flow for each sector and region when
both original DQ and adjusted weights have been applied. In the paper and steel sectors, adjusted-
weighted AIF is slightly smaller due to the lack of DQ facilities for those combinations of sector
and region. Conversely, adjusted-weighted AIF in the chemical sector increases slightly due to
good coverage of DQ facilities, which shifted weights to facilities with above-average flow.
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix A: Extrapolation Methods
Table A-1: MN DQ Distribution and Calculation of Weight Adjustment Factors
Benefits
Region
Distribution of
Facilities in
PCS/ISIS
DQ-
weighted
Facility
Count3
Adjustment
Facto rb
Adjusted
Weight
Facility
Count
DQ-
weighted
AIF
Adjusted-
Weighted
AIF
Number
%
Aluminum
North Atlantic
7
6%
oc
0
0
0
Mid-Atlantic
I I
9%
0
0
0
0
South Atlantic
I
1%
0
0
0
0
Great Lakes
2
2%
3
0.09
0
0
0
Gulf of Mexico
I
1%
0
0
0
0
Pacific
Northwest
0
0%
0
0
0
0
California
0
0%
0
0
0
0
Inland
95
81%
13
1.01
13
87
88.3
Total
117
100%
16
13
87
88.3
Chemical
North Atlantic
16
1%
0
0
0
0
Mid-Atlantic
75
6%
4
2.14
9
28.7
61 3
South Atlantic
9
1%
4
0.26
1
56.4
14.5
Great Lakes
32
3%
17
0.23
2
80.5
18.7
Gulf of Mexico
100
8%
4
2.85
12
283.9
809.8
Pacific
Northwest
4
0%
0
0
0
0
California
5
0%
4
0.14
1
1.5
0.4
Inland
951
80%
1 12
1.04
117
1.782.8
1.860.0
Total
1,192
100%
146
142
2,233.8
2,764.8
Paper
North Atlantic
2
1%
0
0
0
0
Mid-Atlantic
7
2%
0
0
0
0
South Atlantic
8
2%
0
0
0
0
Great Lakes
19
5%
3
1.68
5
6.7
1 1.2
Gulf of Mexico
1%
0
0
0
0
Pacific
Northwest
3
1%
0
0
0
0
California3
0
0%
3
1
3
32.2
32.2
Inland
354
90%
91
0.95
84
1,193.3
1,134.30
Total
395
100%
96
91
1,232.2
1,177.7
Steel
North Atlantic
3
1%
0
0
0
0
Mid-Atlantic
5
2%
0
0
0
0
South Atlantic
1
0%
0
0
0
0
Great Lakes
25
10%
6
0.54
3
2,054.3
I.I 12.1
Gulf of Mexico
3
1%
0
0
0
0
Pacific
Northwest
1
0%
0
0
0
0
California
2
1%
0
0
0
0
Inland
214
84%
28
1.03
29
519.6
Total
254
100%
34
32
2,573.9
1,647.1
Petroleum
North Atlantic
0
0%
0
0
0
0
Mid-Atlantic
2
11%
2
1
2
203.4
203.4
South Atlantic
0
0%
0
0
0
0
Great Lakes
0
0%
()-'
0
0
0
Gulf of Mexico
1
5%
1
1
1
42.6
42.6
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix A: Extrapolation Methods
Table A-1: MN DQ Distribution and Calculation of Weight Adjustment Factors
Benefits
Region
Distribution of
Facilities in
PCS/ISIS
DQ-
weighted
Facility
Count3
Adjustment
Facto rb
Adjusted
Weight
Facility
Count
DQ-
weighted
AIF
Adjusted-
Weighted
AIF
Number
%
Pacific
Northwest
0
0%
0
0
0
0
California
1
5%
1
1
31.8
31.8
Inland
16
79%
16
1
1
391.2
391.2
Total
20
100%
20
20
668.9
668.9
Other
Inland
2
100%
2
1
2
4.6
4.6
Total
2
100%
2
2
4.6
4.6
Total for All Industries
North Atlantic
28
1%
0
0
0
0
Mid-Atlantic
100
5%
6
1 1
232
264.7
South Atlantic
19
1%
4
1
56.4
14.5
Great Lakes
78
4%
29
10
2.141.4
1.142.0
Ciulf of Mexico
107
5%
5
13
326.5
852.4
Pacific
Northwest
8
0%
0
0
0
0
California
8
0%
8
5
65.5
64.4
Inland
1,632
82%
261
260
3,978.5
4,013.4
Total
1,980
100%
314
300
6,800.4
6,351.4
a EPA did not adjust weights for petroleum refineries or facilities in "other industries" because they are not in the five SIC codes
for which EPA developed weights. EPA assumed that these facilities do not represent any other facilities.
b Blank cells indicate that an adjustment factor was not estimated.
c Though these regions account for more than 5 percent of aluminum manufacturers, the average flow for aluminum manufacturers
is less than 10 mgd. Potential benefits associated with these facilities would be relatively minor.
11 Although the PCS/ICIS data did not identify any paper facilities in the California region, there is 1 facility in this region that
received a DQ with a weight of 3. This weight was not adjusted.
e There was 1 refinery in the Great Lakes region that received a DQ. However, this facility was assessed as a baseline closure in the
economic analysis, and thus receives an adjustment factor of 0, and excluded from the benefits analysis.
Sources: U.S. EPA PCS and ICIS-NPDES databases, U.S. EPA analysis for this report
A.2.2 Non-Utility Manufacturers (MU Facilities)
EPA accounted for the geographic distribution of MU facilities using a methodology similar to
that used for MN facilities. EPA adjusted the weights so that the distribution of the weighted
number of DQ facilities matched the actual geographic distribution of the facility universe. Under
this approach, EPA first determined the distribution of regulated facility by study region, and then
calculated adjusted weights for use in the benefits analysis.
A.2.2.1 Determining the Distribution of Regulated Facilities by Study Region
The entire universe of MU facilities was known based on the survey screener, and the EPA used
the Online Tracking Information System (OTIS) facility-finder tool was used to obtain facility
location data.89 EPA distributed the universe of facilities among study regions based on the
regional distribution of MU facilities with location data from OTIS Facility-finder.
89 While the survey screener asked for facilities' flow, EPA was unable to develop adjustment factors using total
flow as a control variable.
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix A: Extrapolation Methods
A.2.2.2 Calculating Adjusted Weights for the Benefits Analysis
For each study region, EPA compared the estimated number of MU facilities with the DQ-
weighted number of facilities in the region. An adjustment factor was calculated as the quotient of
the estimated number of facilities in each region divided by the DQ-weighted number of facilities
in each region. If the adjusted weight for a facility was less than one, EPA assigned a weight of
one to account fully for the flow of the sampled facility. Accordingly, EPA excluded 9 baseline
closures from the benefits analysis and weights readjustment.9" Adjustment factors and adjusted
flow by benefits region are presented in Table A-2.
Table A-2: MU Adjustment Factors and Adjusted Flow by Benefits Region
Benefits Region
Facility
Distribution
from OTIS
DQ-
weighted
Facilities
Adjustment
Factor3
Total Original
Weighted Flow
(mgd)
Total Adjusted
Weighted Flow
(mgd)
MU Facilities
North Atlantic
6
5
1.2
220.9
275.3
Mid-Atlantic
4
7
0.5
474.5
384.9
South Atlantic
2
0
No DQs
0.0
Great Lakes
14
12
1.2
1.186.4
1.500.0
Ciulf of Mexico
8
6
1.3
577.0
744.0
Pacific Northwest
0
I
0.0
0
0.0
California
2
I
2.0
3.6
7.3
Inland
164
175
0.9
6.841.7
6.615.2
Total
2(H)
207
9,303.7
9,526.7
Non-Utility (NU) Facilities Determined to be Manufacturers'"
Inland
N/A
12
1.0
386.7
386.7
Total
Grand Total
N/A
219
-
9,690.4
9,913.3
Notes:
DQ = detailed questionnaire; mgd = millions of gallons per day; MU = Non-utility manufacturers
'Blank cells indicate that an adjustment factor was not estimated.
b Two facilities that were surveyed as non-utilities were later determined to be non-utility manufacturers, and are analyzed as such
in the economic and benefits analyses. Their weights were not adjusted because they were not part of the original MU facility
universe and are both in the inland region. Given that the majority of MU facilities are located in the Inland region, the use of
original weights is unlikely to bias regional benefit results.
Source: U.S. EPA analysis for this report
A.3 Electric Power Generating Facilities
The benefits analysis for electric power generating facilities uses a combination of weights from
the 316(b) Phase II and Phase III analyses and new sample weights. Weights from Phase II and
Phase III accounted for non-sampled facilities and non-respondents to industry surveys and are
referred to as the original survey weights.91
When estimating national-level benefits, use of only survey weights based on facility-specific
(e.g., size and engineering) characteristics can lead to conditional bias. In particular, the original
survey weights do not not consider factors influencing the occurrence and size of benefits, such as
90 This total includes one facility that would be subject to the New York state regulation of CWIS.
91 In general, the original survey weights are numerically very low, as EPA had either DQ or STQ information for
621 of the 634 regulated electric generating facilities. For more information on EPA's Section 316(b) Industry
Surveys, refer to the Information Collection Request (USEPA 2000).
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix A: Extrapolation Methods
the location of facilities subject to the final rule and regulatory options, AIF, similarities among
aquatic species affected by these facilities, and characteristics of commercial and recreational
fishing activities in the area. EPA used a post-stratification weight adjustment to calculate
benefits weights that account for data dimensions not included in the original sample design.
These benefits weights re-scale DQ-based weights using additional information from the STQ so
that total regional flows represented by both weighting systems are equivalent.
The remainder of this appendix describes the post-stratification weight adjustment for electric
power generating facilities. Section A.3.1 describes how the strata were defined. Section A.3.2
presents and discusses the estimates resulting from the post-stratified weighting schemes and
compares these to the original DQ weights.
A.3.1 Defining the Strata and Control Variables
EPA included six study regions when developing benefits weights for electric power generating
facilities: North Atlantic, Mid-Atlantic, South Atlantic, Gulf of Mexico, Great Lakes, Inland, and
California regions. Strata characteristics used to adjust weights are presented in Table A-3.
IM&E is largely a function of mean AIF and characteristics of local fishery resources. Therefore,
regional, non-recirculated AIF is the most important factor in defining strata for the benefits
estimation. It is more important to group estimated total benefits by non-recirculated intake flow
in a study region than by number of facilities. When calculating weights, EPA included a strata
based on a 125 mgd DIF so that benefit estimates accurately reflect changes in technology under
the final rule and other options considered under the regulation.
Table A-3: Matrix of Strata and Control Variables for Adjusting DQ Weights for
Electric Generating Facilities
AIF (mgd)
Strata
Recirculating Facilities3
Non-Recirculating Facilities'"
DIF <125 mgd
DIF > 125 mgd
DIF <125 mgd
DIF > 125 mgd
North Atlantic
0
0
238
6.259
Mid-Atlantic
68
0
257
24.203
South Atlantic
46
0
0
5.943
Gulf of Mexico
0
46
0
9,347
Great Lakes
57
181
255
14.774
Inland
1.397
16.060
1.753
98.653
California0
0
0
62
1 1.249
Total
1,569
16,286
2,564
170,428
Notes:
DQ = detailed questionnaire; AIF = actual intake flow. DIF = design intake flow, mgd = millions of gallons per day
a Recirculating facilities
are facilities with closed-cycle recirculating systems or impoundments that qualify as closed-
cycle recirculating systems.
b Non-recirculating facilities includes facilities with CWIS classified as once-through.
c The California region includes three facilities in Hawaii.
Source: U.S. EPA analysis for this report
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix A: Extrapolation Methods
A.3.2 Comparison of Results of the Detailed Questionnaire and Post-Stratified
Weighting Schemes
EPA assigned post-stratification weights so that tabulations of total mean AIF for each region and
DIF threshold correspond to the best estimates of AIF. The best estimates, or control totals, for
each region are calculated using AIF data from the DQ and STQ, and facility-level sample
weights that account for non-sampled facilities and non-respondents. The DQ total is the total
AIF of facilities to which weights adjustments are applied. Table A-4 summarizes DQ and control
totals by region, DIF threshold, and baseline recirculating technology. By design, the post-
stratification estimate of mean AIF equals the control total estimate (i.e., benefits weights are the
quotient of the control total divided by the DQ total).
AIF is the most important factor in determining benefits. Therefore,, accounting for flow while
minimizing the variance of the weights is the best approach. This is accomplished by assigning an
equal weight to all facilities within a given stratum. One alternative would be to adjust the
original DQ weight, but that would increase the variance of new weights. The additional variance
is not likely to reflect the characteristics on which the estimates depend, and therefore these
weights would be inferior.
Table A-4: Comparison of Results of the DQ and Post-Stratified Weighting Schemes3
AIF for Recirculating Facilities'"
AIF for Non-Recirculating Facilities0
DIF <125 mgd
DIF > 125 mgd
DIF < 125 mgd
DIF > 125 mgd
Region
DQ
Total
(mgd)
Control
Total
(mgd)d
DQ
Total
(mgd)
Control
Total
(mgd)d
DQ
Total
(mgd)
Control
Total
(mgd)d
DQ
Total
(mgd)
Control
Total
(mgd)d
North Atlantic
0
0
0
0
209
238
3,163
6,259
Mid-Atlantic
58
68
0
0
231
257
7,649
24,203
South Atlantic
0
46
0
0
0
0
2,391
5,943
Gulf of Mexico
0
0
46
46
0
0
5,963
9,347
Great Lakes
0
57
0
181
66
255
4,002
14,774
Inland
615
1,397
3,223
16,060
1,036
1,753
46,235
98.653
California6
0
0
0
0
62
62
1,205
11,249
Total
673
1,569
3,269
16,286
1,604
2,564
70,609
170,428
Notes:
DQ = detailed questionnaire; AIF= actual intake flow; DIF = design intake flow, mgd = millions of gallons per day
a A limited number of total STQ facilities did not have a DQ facility to represent them within the technology class (recirculating
versus non-recirculating), region, and DIF strata. Their flow was added to the respective totals for the other technology class when
calculating benefits weights, and is assigned the same benefits weights as the other technology class within the same region and
DIF stata.
b Recirculating facilities are facilities with closed-cycle recirculating systems or impoundments that qualify as closed-cycle
recirculating systems.
c Non-recirculating facilities include facilities with CWIS classified as once-through.
11 The control totals are the best estimates for each region are calculated using operational flow data from DQ and STQ, and facility-
level sample weights that account for non-sampled facilities and non-respondents.
e The California region includes three facilities in Hawaii.
Source: U.S. EPA analysis for this report
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix A: Extrapolation Methods
A.4 Adjustment for State Regulations of CWIS
EPA also included an adjustment to account for the California and New York state regulations of
CWIS. The California state regulation requires closed-cycle recirculating systems for coastal
electric generating facilities and the New York state regulation requires closed-cycle recirculating
systems for all in-state facilities with DIF greater than or equal to 20 mgd. Fourteen surveyed
facilities fall within the scope of the California state regulation and 32 surveyed facilities fall
within the scope of the New York state regulation. EPA's benefits analysis assigns these facilities
baseline IM&E commensurate with compliance with the state regulations.
EPA included a weight adjustment to account for the state regulations because the assumed
technology (i.e., closed-cycle recirculating system) at facilities which are within the scope of the
state regulations does not accurately represent technology at facilities which are not within the
scope of the state regulations. Failing to account for state regulations would result in the
underestimation of baseline IM&E losses and IM&E reductions under the final rule and options
considered.
EPA calculated the best estimate of flow for facilities subject to state regulations (i.e., control
flow) based on the difference between total DQ-weighted flow in each region with these facilities
included and excluded from the weighting analysis. Table A-5 presents the regional DQ-weighted
AIF and control AIF totals for facilities subject to state regulations. EPA adjusted the DQ-
weighted total for each region upward to match the respective control total. In the California
region, EPA only adjusted weights for coastal generators within the state of California; it did not
adjust weights for California manufacturing facilities and Hawaii facilities which are not subject
to the state regulation. The Mid-Atlantic, Great Lakes, and Inland regions all include facilities
which are subject to the New York state regulation. For these regions, EPA grouped generators
and manufacturers when estimating adjustment factors to ensure that each region had at least one
DQ facility to represent facilities within the region subject to the New York state regulation.
May 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix A: Extrapolation Methods
Table A-5: Matrix of Strata and Control Variables for Facilities Subject to State
Regulations for CWIS
Region
Weighted AIF
Including Facilities
Subject to State
Regulations (mgd)
(a)
Weighted AIF
Excluding Facilities
Subject to State
Regulations (mgd)
(b)
DQ Total
(mgd)
Control Total
(mgd)
(a-b)
North Atlantic
6,772
6,772
0
0
Mid-Atlantic
25,199
16,862
1,043
8,337
South Atlantic3
5,943
5,943
0
0
Gulf of Mexico
10,989
10,989
0
0
Great Lakes
17,639
13,840
281
3,799
Inland
131,291
127,730
3,351
3,561
California -
Coastal Generators
10,175
0
895
10,175
California -
Manufacturers and
Hawaii Facilities
1,221
1,221
0
0
Total
209,230
183,357
5,569
25,872
Notes:
AIF = actual intake flow; DQ = detailed questionnaire; mgd = millions of gallons per day
Source: U.S. EPA analysis for this report
May 2014
A-10
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix B: Thermal Discharges
Appendix B: Consideration of Potential Effects due to Thermal
Discharges
B.1 Introduction
Impacts of thermal discharges, along with other stressors, are a relevant consideration when
assessing the potential impacts of electric power facility cooling water intakes and associated
discharges. Several studies have demonstrated the adverse effects that increased temperatures or
altered seasonal thermal regimes have on local biota and fauna. In some cases, studies have
indicated little or no apparent harm is caused by the thermal discharges. This emphasizes the need
for NPDES permit writers to consider site-specific factors when assessing the potential ecological
effects due to thermal discharges.
This appendix provides information on the general effects of thermal discharges on aquatic biota
and ecosystems, considers the influence of site-specific factors and environmental settings on
determining the level (if any) of ecological impacts, and discusses limitation and uncertainty
associated with thermal studies. This appendix also presents three case studies from power
facilities in different environmental settings (Brayton Point Station, Quad Cities Nuclear Station,
and Point Beach Nuclear Plant) which underwent detailed thermal studies under CWA section
316(a) provisions, and which show the importance of site-specific factors in determining the
potential for appreciable harm. The section 316(a) demonstrations described in the three case
studies represent unusually complete and thorough investigations of thermal impacts to receiving
aquatic ecosystems. Thermal investigations at other power facilities are highly site specific, but
typically have a much reduced scope and effort compared to those portrayed by the case studies.
It should be noted that even at power facilities where demonstrations of no appreciable harm have
been made to regulatory authorities under section 316(a), supporting thermal studies nonetheless
often show periods during which thermal limits are exceeded. Impacts of thermal discharges
should therefore be revisited on a case-by-case basis as conditions change, for example (i) if
facilities increase their power capacity (i.e., ""uprate") and increase thermal loads to the receiving
waterbody; (ii) if the thermal assimilative capacity of the receiving waterbody is otherwise
compromised; or (iii) in the face of new evidence that cooling water discharges are causing
appreciable harm to the balanced, indigenous population/community of shellfish, fish, and
wildlife or fail to ensure the protection or propagation of the population. Such assessments need
to consider the extent, duration, timing, and frequency of adverse thermal impacts, the target
threshold temperature for each species, the potential for adverse temperature effects on larger
ecological processes, and other relevant site-specific factors.
B.2 General Effects of Thermal Discharges on Aquatic Biota and
Ecosystems
Thermal discharges affect aquatic organisms by elevating water temperatures or altering seasonal
patterns of temperature change. Temperature is a vitally important variable for aquatic
ecosystems, affecting virtually all biota and biologically mediated processes, chemical reactions,
as well as structuring the physical environment of the water column. There is a well-established
scientific literature cataloguing the impacts of elevated or variable temperature on a wide
May 2014
B-1
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix B: Thermal Discharges
spectrum of aquatic life, including numerous species-specific determinations of thermal tolerance
limits for growth, survival, reproduction, and behavior (e.g., Beitinger et al. 2000; Leffler 1972;
McMahon 1975).
Much of the relevant primary research on power plant thermal discharges dates from the 1970's-
1980's; typically based on laboratory studies, field investigations, or environmental impact
assessments associated with the siting, permitting, and/or operation of power facilities with
significant thermal plumes (e.g., Barnett 1972; Coles 1984; Hillman et al. 1977; Langford 1990
(for review); Squires et al. 1979). These studies found that the thermal discharges may affect
aquatic species growth, survival, and reproduction, alter community diversity and density, and
may have led to shifts in ecological habitat. The character and magnitude of the observed impacts
varies among the studies, however.
Interest in this topic and relevant studies have also re-emerged in the last decade as part of a
greater effort associated with the assessment and characterization of potential effects of global
climate change (e.g., Schiel et al. 2004). The material below provides a representative, exemplary
mix of studies on thermal effects for organisms and communities in a range of trophic levels or
ecosystems with some emphasis on more recent research. The majority of the cited studies were
identified from internet searches and cross-referencing appropriate permitting databases.92
B.2.1 Primary Producers
Thermal discharges affect aquatic primary production through direct effects on photosynthetic
activity and selection of temperature-tolerant species in phytoplankton, periphyton, macroalgae
and submerged aquatic vegetation (SAV), and indirectly through temperature-related changes in
nutrient availability and grazer activities. Several studies reported that thermal discharges
substantially altered the local abundance and structure of the aquatic community, particularly
benthos and periphyton (e.g., Chuang et al. 2009; Martinez-Arroyo et al. 2000; Schiel et al. 2004;
Squires et al. 1979). Studies by Mallin et al. (1994) suggest that indirect effects of discharge
altered the phytoplankton community taxonomic structure near the outfall and in general, support
different communities of algae than those present in the background waters. Several authors
suggest that residual chlorine (anti-fouling agent) may also influence these patterns (Choi et al.
2002; Moss Landing Marine Laboratories 2006; Poornima et al. 2005).
B.2.2 Primary Heterotrophs
The bacterial and microbial components of aquatic ecosystems generally have a positive response
to increasing water temperature - growth rates and bacterially mediated processes are enhanced
until temperature tolerance limits are approached. Most studies found that the growth rates of
bacteria and water temperatures are positively correlated. In contrast, Choi et al. (2002) found
lower rates of bacteria production near outfalls but attributes this effect to residual chlorine in the
discharge water rather than temperature alone.
92 Abt Associates used several general search engines for preliminary searches for scientific and grey literature
including Scirus: http://www.scirus.com/; Google Scholar: http://scholar.google.coin/; and Dogpile:
http://www.dogpile.coin/, as well as publicly available information fromNPDES permits and related section
316a/316b studies.
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B.2.3 Zooplankton
Zooplankton and other pelagic macroinvertebrates typically increase their grazing activities and
growth rate in response to increased temperature. Marasse et al. (1992) observed a higher rate of
bacteria consumption (i.e., bacterivory) by samples of plankton that were incubated at higher
temperatures. Jiang et al. (2009) suggests that copepod species with larger body sizes are more
sensitive to thermal increases, and that this water temperature increase induces mortalities of
copepods. As noted for other organisms, estuarine copepods have more tolerance to thermal stress
than those from more stenothermal, deepwater environments.
B.2.4 Benthic Community
Benthic species and communities are often particularly vulnerable to thermal discharge due to
association with the substrate and limited ability to migrate from impacted areas. Growth rates
and spawning times are usually accelerated by increased temperature (Barnett 1972). McMahon
(1975) and Leffler (1972) found that snails and blue crabs, respectively, exhibit more rapid
growth at higher temperatures, but both studies also observe greater species mortality. The study
by Coles (1984) found a positive effect with the thermal effluent as both the number of organisms
and the colonization by coral reef propagules near the outfall were significantly greater than
background areas. A recent study of benthic communities and associated biota near a nuclear
power plant discharge show that the thermal pollution alters composition and decreases richness
in benthic cover (Teixeira et al. 2009).
B.2.5 Fish
Fish are extremely well-studied with regard to temperature tolerance and thermal limits in both
the laboratory and field. The thermal habitat requirements of coldwater, coolwater, and
warmwater fish species are well-characterized (e.g., Beitinger et al. 2000; Sullivan et al. 2000),
and these may be the basis for regulatory sub-classification of water bodies. Thermal discharges
can influence the spatial distribution of fish due to direct responses to altered temperature (i.e.,
attraction, avoidance), effect on dissolved oxygen concentrations, and impacts to prey and habitat
availability (Cooke et al. 2004; Sullivan et al. 2000). Rapid fluctuations and decreases in water
temperature, usually associated with steep thermal gradients in temperate winter waters, can lead
to "cold shock" with reduced survival (Ash et al. 1974; Deacutis 1978).
Smythe and Sawyko (2000) evaluated the effect of "cold shock" on fish and found no effect on
larger predator species, though a forage species (gizzard shad) had lower survival rates. Some
studies of thermal discharges have not observed significant effects in local fish communities.
Hillman et al. (1977) and Krishnamoorthy et al. (2008) found that impacts on shore-zone fish and
fingerlings from power station discharges were minimal. A study of salmonids by Sullivan et al.
(2000) maintains that direct mortality from temperature is unlikely since acute lethal temperatures
are rarely, if ever, observed in the field. Specifically, this study suggests that there is little or no
risk of mortality if the annual maximum temperature is less than 26°C, but suggests a site-specific
analysis when annual maximum temperatures exceed 24°C.
B.2.6 Ecosystem Functions and Services
In addition to the species-specific impacts, investigators have looked at the effects of thermal
discharges on the structuring of species assemblages and communities, as well as secondary
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ecosystem function and services. Thermal discharges may have both detrimental and beneficial
effects. For example, the bleaching and destruction of coral reefs by elevated thermal discharges
is well documented, but Coles (1984) in the Moss Landing study found that the thermal effluent
may have some beneficial effects, such as enhancing new coral regrowth or providing preferred
water temperatures for avian birds and mammals.
Work in seven Southeastern U.S. cooling reservoirs indicated that direct thermal effects on
phytoplankton communities were generally minimal, but that the smaller reservoirs were more
prone to algal blooms due to nutrient trapping and elevated temperatures (Mallin et al. 1994).
Indirect effects of excessive thermal loads in these reservoirs caused ecosystem-wide alterations
arising from both top-down (higher trophic consumers) and bottom-up (primary producers)
effects. Martinez-Arroyo et al. (2000) found that phytoplankton subjected to elevated water
temperature exhibited lowered photosynthetic capacity and light harvesting efficiency, and
required more light to reach a net oxygen production. Thus, primary production and oxygen
levels, both critical ecosystem functions, may be decreased as a result of elevated temperatures.
Teixeira et al. (2009) evaluated the effect of thermal discharge on fish communities and habitat
structure in rocky substrates near a nuclear power plant in southeastern Brazil. Their studies
indicate the heated effluents affected habitat structure as well as fish community structure and its
eco-spatial distribution. Lowered fish species richness was observed in the impacted area,
attributed to a reduction in benthic cover of a habitat-forming species (Sargassum sp.).
B.3 Influence of Site-Specific Factors and Environmental Setting on
Thermal Effects
As noted above, the environmental setting (i.e., the nature of the receiving waters) can have a
pronounced influence on the potential for and the magnitude of adverse thermal impacts on biota.
While physical features near the discharge and temporal climatic patterns usually dictate the
observed level of thermal deviations for any given discharge, several environmental factors may
be important in determining the magnitude of potential impacts, including: geographic location,
marine vs. freshwater environments, volume of receiving water, rate of water exchange, other
heat loads, and local habitats.
B.3.1 Geographic Location
Geographic location determines the duration and intensity of annual solar heating and usually
dictates the resulting maximum ambient temperatures for the receiving waters. The more
southerly the facility, the higher the seasonal temperature maxima is likely to be, increasing the
possibility of reaching upper thermal temperature limits for sensitive organisms. Despite
acclimation, relatively few North American aquatic organisms will tolerate chronic water
temperatures in excess of 35-40°C (Brock 1985).
Northerly receiving waters will have lower maximum ambient temperatures in summer, but will
also exhibit greater seasonal variation; with a more extreme temperature gradient between
discharge and surface water during winter. Conversely, sub-tropical water temperatures have less
seasonal variation, and a more consistent thermal gradient is maintained between discharge and
ambient conditions. Adverse effects to aquatic organisms are generally most pronounced at the
acute and chronic high lethal temperatures and/or due to rapid fluctuations (e.g., "cold shock").
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B.3.2 Marine vs. Freshwater Receiving Waters
Adverse thermal impacts have been documented in both freshwater and marine ecosystems, but
the likelihood of impacts may be considered slightly greater in freshwaters simply due to the
presumption that marine waters constitute a greater thermal reservoir due to larger volume and
tidal flushing. However, as noted above, site-specific features will dictate the effective volume
and the flushing rate, which are likely to be the key to vulnerability of receiving water ecosystem
to thermal impacts. Clearly, the magnitude of thermal impacts also depends on the composition of
the local biota and whether such organisms are temperature-sensitive. The sensitivity of
coldwater freshwater fish (e.g., trout, salmonids, darters) to increased water temperature and
associated lowering of available dissolved oxygen has been well characterized (Beitinger et al.
2000; Sullivan et al. 2000). There is less temperature-sensitivity in marine estuarine fish, which
are often more tolerant than offshore fish, since estuarine fish are subject to regular
environmental fluctuations.
B.3.3 Receiving Water Volume
The volume of the receiving water is a critical factor since it determines the total amount of heat
that can be absorbed by a water body while still remaining at an acceptable temperature. The
effective volume subject to the thermal discharge may be significantly less than that of the entire
water body if it is constrained physically (e.g., narrow discharge channel, small coastal
embayment) or can vary in the short term (e.g., low tide, hydropower releases), seasonally (e.g.,
thermally stratified lakes, salinity stratified estuary), or longer (e.g., multi-year droughts). Due to
the buoyant properties of warm water, the effective mixed volume can be reduced even further if
the thermal plume is not effectively or rapidly mixed into the receiving waters.
B.3.4 Rate of Water Exchange
The rate of water exchange is another factor which can compensate for a small effective volume.
A short hydraulic residence time (HRT) (i.e., rapid flushing) of the receiving water at the point of
the thermal discharge can rapidly dissipate a high heat load. Large fast rivers, open ocean outfalls,
and coastal embayments with sweeping longshore currents, etc. can generally better tolerate
thermal discharges and have limited or highly localized impacts to biota. Poorly flushed systems,
those with seasonal flow minima, or episodic hydrologic inputs, are more likely to experience
widespread or persistent thermal impacts. In some cases, the flow or volume of the thermal
discharge may be very much greater than the receiving water.
B.3.5 Local Land Use
Local land uses may also be influential in that they can provide additional thermal loads to the
water body independent of the thermal discharge. Developed urban watersheds with large
percentages of impervious cover may produce large storm water flows with temperatures that are
well above ambient temperatures in the receiving waters. Agricultural lands and irrigation return
water may also increase local thermal loading. Channelization and removal of riparian buffer
vegetation can increase water temperature through lack of shading, reflective artificial substrates,
and removal of deep pool habitats.
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B.3.6 Local Habitats
Benthic biota and/or habitats (e.g., oyster reefs, eelgrass, and mussel beds) found in nearshore
environments are often subject to greater impact since these largely sessile communities are
affixed to the substrate. On the other hand, mobile aquatic organisms can track temperature
change and fine-tune their temporal and spatial distribution (Cooke et al. 2004). Biota can
sometimes avoid adverse thermal impacts by seeking out localized areas of cooler or better
aerated waters (e.g., deep pool, tributary stream, bottom waters) for short-term or seasonal
residence. These areas provide habitat that may allow the temperature-sensitive organisms to
persist and emigrate back into the affected water body once the thermal stress is reduced. Thermal
effects could be more severe in homogenous environments (e.g., open water column, unstratified
reservoir) where the biota does not have access to these refugia. Thermal displacements from
spawning habitat due to dam construction and operation (e.g., bottom water releases) has also
been a concern in western rivers and elsewhere (Bartholow et al. 2004; Hayes et al. 2006).
B.4 Uncertainties and Limitations of Assessing Thermal Impacts
One of the major difficulties in accurately characterizing the influence of thermal discharges on
aquatic communities is the uncertainty due to the potential influence of other abiotic water quality
factors. Thermal discharges from power plant cooling systems often contain elevated levels of
additional constituents including, but not restricted to: residual chlorine, total suspended solids,
total dissolved solids, cleaning agents and surfactants, metals, and nutrients. The presence of
these constituents may complicate the interpretation of the environmental factor(s) that are
responsible for observed changes in biotic communities.
For example, several of our studies on thermal effects on primary producers noted that residual
chlorine in the discharge may be responsible for some of the observed effects (Chuang et al.
2009; Poornima et al. 2005). Interaction of thermal effects and heavy metals was responsible for
some phytoplankton taxonomic changes in one reservoir investigated by Mallin et al. (1994).
Looking at the behavior of smallmouth bass, Cooke et al (2004) found that a majority of a local
radio-tagged population overwintered in the warmest portions of a thermal discharge to Lake
Erie. However, this area also was high in habitat complexity, had adequate flow velocity refuges,
and abundant forage, so selection for this habitat may not be a simple thermal preference.
Adverse temperature effects may also be more pronounced in aquatic ecosystems which are
already subject to other environmental stressors such as high biochemical oxygen demand (BOD)
levels, sediment contamination, or pathogens. Thermal discharges may have indirect effects on
fish and other vertebrate populations through increasing pathogen growth and infection rates.
Langford (1990) reviewed several studies on disease incidence and temperature, and while he
found no simple, causal relationship between the two, he did note that it was clear that warmer
water enhances the growth rates and survival of pathogens, and that infection rates tended to be
lower in cooler waters.
B.5 Case Studies
Three case studies were selected for large power generating stations from which thermal
discharges may have a potential impact to the local aquatic community/ecosystem. These three
case studies provide examples of investigations of thermal impacts in different environmental
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settings (marine coastal embayment, coastal Great Lake, and freshwater river), and at differing
spatial scales (community, habitat, ecosystem).
B.5.1 Brayton Point Station
Brayton Point Station (BPS) is a 1538 megawatt (MW) coal and oil-fired electrical generating
station located in Somerset, MA. This facility takes cooling water from and discharges heated
effluent to Mount Hope Bay (MHB), a large coastal embayment within Massachusetts and Rhode
Island. Generation Unit 1 began operating in 1963, Unit 2 in 1964, Unit 3 in 1969, and Unit 4 in
1974 (Dominion 2011).
One of the most thorough examinations of the individual and cumulative effects of a power plant
thermal discharge was conducted as part of the regulatory review of the CWA section 316(a)
variance request application submitted in May 2001 as part of the NPDES discharge permit
(Permit No. MA 003654) renewal for BPS. The permitee's 316(a) variance request application
sought to keep the existing permit temperature criteria (maximum temperature of 95 °F; delta
(departure from ambient) temperature of 22° F), and to reduce the total heat load from the existing
permit limits. However, these thermal criteria were still less stringent than what would be
required by either technology-based or water quality-based discharge limits.
CWA 316(a) authorizes alternative thermal discharge limits when it is demonstrable that the
proposed thermal limits "will assure the protection and propagation of a balanced indigenous
population (BIP) of shellfish, fish, and wildlife in and on that body of water." To evaluate
whether the thermal limits proposed in the May 2001 316(a) variance request application would
meet this protective criterion, EPA, in accordance with the 316(a) Technical Guidance Manual
(USEPA 1977), conducted a review of the historical and current conditions of MHB biota on a
community-by-community evaluation, and considered potential thermal impacts to
phytoplankton, zooplankton, habitat formers, shellfish, finfish, and other vertebrate (i.e., sea
turtles and mammalian) wildlife. The findings of the community impact analyses are contained in
the "Clean Water Act NPDES Permitting Determinations for Thermal Discharge and Cooling
Water Intake from Brayton Point Station in Somerset, MA" (USEPA 2002a) dated July 22, 2002
(hereafter "Determinations'') and summarized below.
For each of the community types, the Determinations provides a preliminary consideration of
whether the community's nature, estuarine setting, and water column distribution within MHB
relative to the location and magnitude of the BPS thermal discharge would result in a finding of
"low potential impact areas" and lessened environmental concerns for the granting of the 316(a)
variance. For those communities in MHB for which a "low potential impact" conclusion was not
possible, the severity of the thermal effect was gauged by comparison to a list of a priori decision
criteria for each community.
EPA judged that MBH was not a low potential impact area for phytoplankton. As seagrasses and
salt marshes have historically declined in importance in MHB, the phytoplankton community is
the dominant primary producer (USEPA 2002a). The recent (2001) occurrence of a nuisance
blue-green algal bloom (dominated by the cyanophyte Anacystis aeruginosa) in MHB near BPS
may be due to the high nutrients and warm water temperatures which favor formation of such
bloom. It was considered likely that thermal plume from BPS was a contributing factor.
Perhaps of greater importance is the finding that the MHB phytoplankton community does not
undergo the typical winter-spring phytoplankton bloom cycle (Keller et al. 1999). Extensive work
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was conducted on plankton communities in experimental mesocosms where temperature was
shifted to mimic the expected thermal conditions in MHB surface waters. Extrapolating these
changes seen in the mesocosms, such changes in phytoplankton population dynamics could very
likely lead to significant impacts within the trophic dynamics of the MHB food web. Redirecting
carbon away from benthic consumers and into pelagic food webs could represent a reduction in
prey species for benthic-feeding finfish such as winter flounder, windowpane flounder,
hogchoker, and tautog.
EPA judged that MHB was not a low potential impact area for zooplankton since it is an estuary
that serves as a spawning site for numerous fish and invertebrate species (USEPA 2002a). The
most noticeable thermal effect in this community is the recent increase in abundance of the
ctenophore Mneimiopsis leidyi, and increased overwintering in MHB for this formerly seasonal
resident. Dramatic increases in comb jellies (i.e., ctenophores) are usually indicative of stressed
ecosystems with symptoms of increased water temperatures, increased nutrient levels, and
depleted fish stocks (Pohl 2002). Since M. leidyi is a voracious consumer of pelagic fish eggs as
well as zooplankton by which it competes with young-of-year winter flounder, it was concluded
that BPS was significantly contributing to thermal increases in MHB, and facilitating expansion
of the range and time of year distribution of the comb jellies.
Eelgrass is a coldwater plant that ranges from North Carolina to Canada and grows well in soft-
bottom, low energy environments. Despite the current lack of eelgrass, the EPA judged that MBH
was not a low potential impact area for habitat formers since the historic presence of extensive
eelgrass meadows shows that it is capable of supporting this habitat type (USEPA 2002a).
Experimental work has shown that optimal temperature ranges for photosynthesis decrease with
increasing turbidity (Bulthuis 1987) so that in turbid waters, eelgrass growth decreases with
increased temperature, because photosynthetic rates decrease and respiration rates increase. Based
on the current lack of eelgrass, it was concluded that the combination of poor water quality and
increased water temperature result in an "exclusion zone" for eelgrass growth in MHB (USEPA
2002a). Since BPS helps to elevate the water temperature over significant portions of the bay, it is
considered a contributory cause to this exclusion.
EPA judged that MBH was not a low potential impact area for shellfish and macroinvertebrates
due to the presence of commercially important species, the "substantial" densities of these
species, the spawning and nursery areas in MHB, and the important role in ecosystem function
that this community provides (USEPA 2002a). Benthic sampling indicated that there have been
no significant changes in the benthic community between the 1970's and mid-1990's or over the
span of time when BPS has been active and the annual heat flux was increased. The sampling also
indicates a strong representation in the benthic community of the amphipod Ampelisca which is a
preferred prey item for juvenile winter flounder. Overall, EPA found no substantial evidence of
harm to shellfish and macroinvertebrates from the current thermal discharge, and any alternative
which reduces the thermal discharge would be acceptable.
EPA judged that MHB was not a low potential impact area for finfish due to the presence of
numerous recreational and commercially important species, the important spawning and nursery
areas, and the potential for blockage of fish migration (USEPA 2002a). The analysis for finfish
was specifically targeted at determining the appropriate thermal discharge limits for BPS in order
to protect finfish populations, and included a retrospective examination of total finfish abundance
trends in relation to plant operations. The analysis determined an acceptable annual flux of heat
into MHB that is protective of finfish populations, based on the temperature thresholds for acute
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and chronic mortality as well as for several sub-lethal effects for some representative important
species (RIS).
The finfish stocks in MHB have declined precipitously since 1984-1985, a period which marked
the shift of Unit 4 at BPS from closed-cycle recirculating to once-through cooling operations.
Further, work by Gibson (2002) suggests that winter flounder have been declining since at least
the initiation of sampling in 1972. Although BPS had been operational for 9 years at that point,
no fishery data are available to estimate what the finfish community was like prior to 1972.
Comparison of the record of annual heat flux to MHB over that last 28 year period to records of
finfish abundance led EPA to conclude that an annual heat flux of 28 trillion British thermal units
(tBTU) to MHB, as proposed in the 316(a) variance request application, would be unable to stop
or reverse a decline in fish populations, and thus would not be protective of the finfish
community.
The temperature tolerance limits of 16 RIS were reviewed to establish temperature thresholds for
the more sensitive of these species (winter flounder, striped bass). These thresholds were used to
establish critical temperatures for three target depth strata (surface, middle, and bottom waters) at
two key seasonal periods (winter, summer). Winter corresponds to the period (March 1 -31) of
active winter flounder spawning, and when large numbers of larval planktonic winter flounder are
present in MHB. The summer index period (July 15 - August 15) corresponds to the warmest
time of the year.
Predictive hydrothermal models (CORMIX for near-field effects; WQMAP for far-field effects)
of MHB provided a means of evaluating the potential thermal impacts caused by the current (i.e.,
existing permit), the proposed (i.e., the requested 316(a) variance), and two alternative reduced
heat flux options for BPS operations, as well as a "no-plant" condition. During warm summer
conditions, the proposed operational heat flux would impact 62 percent of the bottom water strata
as compared to 4 percent under a no-plant scenario, while other alternative operating options
would have reduced impact proportional to their proposed total heat fluxes. Using this method, it
is possible to show impacts to all target depth strata during summer conditions and impacts to the
bottom strata during winter.
The study also considered other heat effects on finfish caused by the thermal discharge. The first
involved the attractive nuisance nature of the thermal plume (USEPA 2002a). The plume acts as
an attractant for large numbers of striped bass and bluefish in the fall and winter, and disrupts the
seasonal migration of these species. The crowding of large numbers of these species into a
restricted area increases the potential for weakening or disease since the warm temperatures
increase the metabolism of these fish at the same time there is reduced feeding due to a lack of
prey.
Similarly, the trapping of Atlantic menhaden in the thermal plume affects the migration of this
species, and likely increases impingement mortality and entrainment (IM&E) due to longer
periods spent in proximity to intake structures, which has been evidenced by several recent large
winter impingement loss events. Another effect noted was the establishment in MHB of
smallmouth flounder (Etropus microstomus) which is at the northern limit of its geographic
distribution range. It is important to note that an increased abundance or distribution shift to a
warm water species is not indicative of protection of a BIP.
EPA judged that MBH is a low potential impact area for other vertebrate life since it is not a
significant habitat for marine mammals or sea turtles (USEPA 2002a). Overall, there is no
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potential for harm from the current thermal discharge, and any alternative which reduces the
thermal discharge would be acceptable.
A summary of current ecosystem thermal effects and predicted impacts associated with the
proposed thermal flux was prepared (USEPA 2002a). The current thermal effects for which there
appears to be no disagreement include:
> Appearance of nuisance algal blooms;
> Absence of normal winter-spring phytoplankton bloom;
> Overwintering of the ctenophore Mneimiopsis leidyi;
> Overwintering of striped bass and bluefish in discharge canal;
> Increased abundance of smallmouth flounder in MHB;
> Thermal avoidance of most of MHB by adult winter flounder; and
> Multiple fish kills as a result of large impingement events in the winter.
Evaluating the proposed 316(a) variance request, EPA predicted that, under the proposed thermal
discharge under the 316(a) variance request, the following would occur:
> Large areas of MHB would be avoided by juvenile winter flounder and striped bass
during warm summer months;
> Extensive areas of MHB would experience water temperatures resulting in chronic
toxicity to juvenile winter flounder;
> Reduced winter flounder egg hatching success for the entire MHB for the warmest winter
months;
> Increased predation on winter flounder eggs and larvae by sand shrimp; and
> Potential exclusion of eelgrass.
EPA also considered potential impacts from other stressors that could be responsible for mortality
of finfish in MHB; including overfishing, predators, water quality, brown tides, and IM&E
(USEPA 2002a). Each of these stressors was examined for its potential role in causing or
contributing to the finfish collapse. Analyses of these other potential stressors indicated that while
possibly contributory, the adverse effects of each were generally exacerbated by the thermal
conditions caused by the BPS plume.
Based on the hydrothermal and ecological analyses conducted and documented in the
Determinations document, EPA concluded that a BIP has not been maintained in MHB, and that
the current BPS thermal discharge is a significant contributor to this problem (USEPA 2002a).
Further, the proposed thermal reductions in annual heat flux contained in the 316(a) variance
request application would not allow for the recovery of the winter flounder or the wider balanced
indigenous ecosystem. Accordingly, EPA denied the permitee's variance request, and reissued the
NPDES permit in 2003 with the provision for installing closed-cycle recirculating systems in all
four of the power units.
B.5.2 Quad Cities Nuclear Station
Quad Cities Nuclear Station (QCNS) is a dual-unit nuclear fueled steam electric generating
facility (SIC 4911) located on a 765-acre site along the Mississippi River in Cordova, Illinois.
QCNS Units I (866 net megawatts (MW)) and 2 (871 net MW) began commercial production of
electricity in 1973. QCNS withdraws water from the Mississippi River for non-contact condenser
cooling and various service water uses. After passing through the condensers, the cooling water
from Units 1 and 2 mixes and then exits to the River via a discharge canal. QCNS is located on
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Pool 14 of the Mississippi River, at approximate River Mile 506.5 above the confluence of the
Ohio River.
The thermal discharge is authorized under the Station's NPDES Permit, issued by the Illinois
EPA (ILEPA). Thermal limits in the NPDES Permit are based on Illinois environmental
regulations, and studies and Demonstrations related to the thermal plume are performed under
CWA section 316(a). During the latest NDPES permit renewal cycle, QCNS requested issuance
of a 316(a) variance for a proposed alternative thermal standard, specifically relaxation of a
maximum thermal excursion temperature limits by 2°F during late summer months (July-
September), which would increase the predicted frequency of expected thermal excursions from 1
percent to 3 percent. This variance request was based on a demonstration that future operations
of QCNS would assure the protection and propagation of a balanced indigenous community
(BIC) of fish, wildlife, and shellfish, particularly within Pool 14.
To evaluate the potential thermal impacts of QCNS' discharge on Pool 14, a number of
comprehensive studies were conducted (including thermal plume modeling and field surveys,
review of current ("prospective analysis") and historic ("retrospective demonstration") biota
monitoring, and water quality assessment. The thermal plume modeling is contained in "River
temperature predictions downstream of Quad Cities Nuclear Generating Station" (Holly Jr.
et al. 2004). The elements and findings of the biological and water quality assessments are
contained in the "Quad Cities Nuclear Station Adjusted Thermal Standard CWA 316(a)
Demonstration, Final Draff' (HDR 2009) dated November 2009 (hereafter "Demonstration") and
summarized below.
The thermal plume model study was able to successfully reproduce temperature field data
(collected September 2003) without any adjustment of non-physical parameters (Holly Jr. et al.
2004). The model was used to show compliance of the thermal plume with the proposed
alternative standard. The model validation revealed the importance of including site-specific
river-entraining structures such as wing dams and chute closure dams in the model, as these have
an important influence on the thermal flow patterns in the vicinity of the QCNS and local
Steamboat Island (Holly Jr. et al. 2004).
Current and past monitoring efforts have collected data on a variety of aquatic communities,
including phytoplankton, zooplankton, benthic macroinvertebrates (including freshwater
mussels), ichthyoplankton, and finfish, which are summarized in the Demonstration (HDR 2009).
For the prospective assessment, QCNS conducted comprehensive literature surveys, analyzed
field data, and followed EPA approved protocols for assessing potential thermal impacts on RIS
of fish. RIS species selected for the QCNS Demonstration included largemouth bass, channel
catfish, spotfin shiner, and walleye. River and plant operating conditions were selected to provide
a conservative assessment of potential power plant-related biological effects (i.e., the biothermal
assessment focused on the months of June, July, August, and September). The results indicate
that the proposed alternative thermal standard would have a negligible impact on largemouth
bass, channel catfish, and a slightly positive one for spotfin shiner (i.e., increased growth) (HDR
2009). Walleye chronic mortality could be increased by 8.5 percent immediately downstream of
the mixing zone, but placed in the areal relationship of the discharge to Pool 14, this would
translate to a <1 percent effect on the walleye population in the pool (HDR 2009).
The retrospective assessment indicated some changes in the upper trophic levels (i.e., finfish) in
Pool 14 since the Station began operating, but concluded that those changes are not attributable to
the thermal input from QCNS (HDR 2009). In addition, the overall stability and health of upper
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trophic levels over the length of the monitoring period suggests that lower trophic levels (i.e.,
zooplankton, phytoplankton) have remained stable and abundant, providing an adequate food
supply to allow and sustain growth of the finfish and mussel populations. The retrospective
assessment also found that neither nuisance species (e.g., zebra mussel) nor heat tolerant species
of fish have come to predominate in Pool 14 due to QCNS operations (HDR 2009).
In addition, the Demonstration examined the potential for harmful interactions between the
QCNS thermal discharge and other pollutants, including dissolved organic carbon, total
phosphorus, total nitrogen, biocides (i.e., anti-fouling chemicals), heavy metals, and other thermal
discharges located upstream. This analysis indicated that there was no evidence to suggest that
the small amount of additional heat that would be permitted to be discharged to Pool 14 under the
proposed alternative standard would have an adverse synergistic effect with other pollutants
(HDR 2009).
QCNS, based on their interpretation of EPA guidance documents and 316(a) Demonstrations for
other facilities, maintained that the overall standard of compliance (i.e., protection of the BIC)
would be demonstrated by meeting a series of functional criteria. Because this is a request for a
change in the thermal standard, the Demonstration needed to show that these conditions will be
satisfied in the future if the proposed standard was adopted:
> No substantial increase in abundance or distribution of any nuisance species or heat
tolerant community;
> No substantial decreases in formerly abundant indigenous species or community structure
to resemble a simpler successional stage than is natural for the locality and season, other
than nuisance species;
> No unaesthetic appearance, odor, or taste of the water;
> No elimination of an established or potential economic or recreational use of the waters;
> No reduction in the successful completion of life cycles of indigenous species, including
those of migratory species;
> No substantial reduction of community heterogeneity or trophic structure;
> No adverse impact on threatened or endangered species;
> No destruction of unique or rare habitat, without a detailed and convincing justification of
why the destruction should not constitute a basis of denial; and
> No detrimental interaction with other pollutants, discharges, or water-use activities.
Based on the results of the thermal plume modeling study, the prospective analysis, the
retrospective assessment, and the successful meeting of the criteria listed above, QCNS
concluded that past or future operations have not caused appreciable harm to the BIC.
B.5.3 Point Beach Nuclear Station
Point Beach Nuclear Plant (PBNP) is located on the western shore of Lake Michigan in Two
Rivers, Manitowoc County, WI. The facility consists of two nuclear powered steam electric
generating units with a total net capacity of 1,540 megawatts thermal (MWt) each. Generation
Unit 1 began commercial operation in December 1970 and Unit 2 in October 1972 (EA 2008).
The units operate with a once-through cooling water system (EA 2008). Cooling water is
withdrawn from a deep intake (22 ft. contour) in Lake Michigan, and current pumping capacity is
estimated to be 680,000 gallons per minute. Each unit discharges the non-contact cooling water to
Lake Michigan via its own outfall located at a mean temperature increase of 11.5°C (20.7°F)
above the intake water temperature at the maximum flow rate (EA 2008).
May 2014
B-12
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix B: Thermal Discharges
PBNP planned to implement an extended power uprate (EPU) at both units in the 2010/2011 time
frame that was expected to increase the existing plant output by approximately 17 percent. The
proposed EPU does not result in an increase in water being withdrawn from Lake Michigan, nor
will it result in an increase in the amount of water discharged to Lake Michigan (NRC 2010).
However, EPU did require modification of the facility's Wisconsin Discharge Elimination
System (WPDES) permit for the discharge of a pollutant from a point source into waters of the
state (which includes the addition of heat from a point source). According to a modeling study
performed by PBNP in 2008, the temperature of the discharge water was expected to increase by
a maximum of 3.6 °F (2.0 °C), and the thermal plume expand as a result of the proposed EPU
(NRC 2010).
In support of the permit modification request, PBNP prepared an assessment of the potential
impacts of the thermal discharge from the planned EPU (i.e., the "Planned Change"). This
assessment is summarized in "Point Beach Nuclear Plant Evaluation of the Thermal Effects Due
to a Planned Extended Power Uprate" (EA 2008). Since there currently are no temperature
limits in the PBNP WPDES permit or thermal water quality standards for Lake Michigan, this
assessment represented a "good faith effort" by PBNP to demonstrate that the impacts of the EPU
would not have a significant effect on the fish or shellfish communities in Lake Michigan (EA
2008).
Evaluation of the potential effects on the Lake Michigan aquatic community in the vicinity of the
PBNP post-EPU discharge was based on a review of historical and current monitoring data
collected in the vicinity of the facility and other power facilities that utilize Lake Michigan water
for once-through cooling (EA 2008). Those study results were compared to expected responses of
16 Wisconsin Department of Natural Resource (WDNR) selected Representative Important
Species (RIS) to the projected higher discharge temperatures and larger thermal plume that will
result from the planned EPU. The evaluation placed emphasis on the RIS, and whether or not the
BIC in the vicinity of the PBNP discharge would continue to be protected.
The assessment relied heavily on the findings of the Type I CWA section 316(a) Demonstration
conducted by the facility in the 1970s as well as the 1976 finding by WDNR that no appreciable
harm had occurred to the local BIC due to facility operations (EA 2008). The studies involved
investigations of primary and secondary trophic levels from phytoplankton through fish in both
reference and thermally affected areas (EA Engineering 2008; Limnetics 1974, as cited in EA
2008).
Recent entrainment and impingement monitoring studies at PBNP indicate that the same species
that were common in the vicinity of the facility during the Type I Demonstration remain common
near the facility despite lake-wide changes in the Lake Michigan fish community (Kitchell 2007,
as cited in EA 2008). Recent fisheries data collected from both PBNP and the Kewaunee Nuclear
Power Plant (KNPP), which is located only five miles north of PBNP, show that the same species
seasonally occur in nearshore areas in the vicinity of the shoreline discharge structures. These
findings indicate that the BIC is protected under similar operating conditions as have occurred
historically at PBNP.
Evaluation of the modeled discharge temperatures and plume configurations under the planned
EPU indicates that the predicted area, volume, and behavior of the plume will not be substantially
different than under current PBNP operating conditions and similar to those evaluated during the
Type 1 Demonstration (EA 2008). Based on the thermal model results using a 0.2 ft./sec along-
shore current, the planned EPU would expand the surface area of the 6.0°C contour from 27 to 39
May 2014
B-13
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix B: Thermal Discharges
acres; the 4.0°C contour would increase from 79 to 105 acres; and the 2.0°C contour would
increase from 315 to 390 acres (EA 2008). These projected increases in plume size are relatively
small compared to the surface area available for mixing. Under critical summer conditions the
buoyant plume provides an area of safety as well as a zone of passage when discharge
temperatures approach or exceed upper avoidance temperatures of the RIS fish.
The RIS evaluation showed that the predicted impact of the warmer and larger thermal plume as a
result of the EPU at PBNP will be negligible (EA 2008). Thermal criteria for some of the 12 RIS
fish species would be exceeded in the plume, but mainly at the point of discharge or in small
areas for relatively brief periods of time. Fish readily move into and out of thermal discharge
plumes, depending on their thermal requirements and the thermal regime of the plume at any
given time. Cool and coldwater fish species would be somewhat restricted with regard to use of
the plume area, especially during summer, but these species generally spend the summer well
offshore. In addition, the warmwater RIS could slightly benefit from the warmer temperatures.
Combining these observations with the size of the PBNP plume relative to available lake habitat,
it was concluded that the larger and warmer thermal plume resulting from the planned EPU
would have a minimal and insignificant impact on the fish community in Lake Michigan (EA
2008). Similar conclusions were reached for the four invertebrate RIS (shellfish and opossum
shrimp).
Overall, the assessment concluded that the increased heat load to the discharge would not
endanger the protection and propagation of a BIC of shellfish, fish, and wildlife in and on Lake
Michigan. This conclusion was based on several lines of evidence including:
> The PBNP Type I Demonstration established that the original thermal plume did not
cause "prior appreciable harm;"
> The PBNP thermal plumes resulting from the planned EPU will not be substantially
larger than the original/existing plumes;
> There have been no changes in the aquatic community attributable to operation of the
facility that would preclude reliance on the results of the Type I Demonstration for
PBNP;
> The changes to the Lake Michigan fish community that have occurred during the past 50
years have occurred on a lake-wide basis;
> The impacts on RIS will be negligible; and
> The conclusion with respect to the effect of the planned EPU is consistent with
assessments undertaken at other power facilities on Lake Michigan.
While the cooling water thermal plume of PBNP was expected to be larger as a result of the
proposed EPU, it was not expected to disrupt the local BIC or have a significant impact on RIS of
Lake Michigan (EA 2008). Recently, as part of the facilities' operating license renewal, the
Nuclear Regulatory Commission developed a draft Environmental Assessment (EA) for the
power uprate. The draft EA was issued in December 2010 with a finding of no significant impact
(NRC2010).
May 2014
B-14
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
Appendix C: Details of Regional IM&E
C.1 California Region
Table C-1: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the California Region (million A1Es
per year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
All forage species
0.I7
0.18
0.20
0.29
<0.01
<0.01
14.81
24.28
0.17
0.18
15.00
24.56
All harvested species
0.50
0.54
0.58
0.85
<0.01
<0.01
15.94
26.14
0.50
0.54
16.52
26.98
American shad
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Cabezon
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.05
0.08
<0.01
<0.01
0.05
0.08
California halibut
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.20
0 V,
<0.01
<0.01
0.20
0 V,
California scorpionlish
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Crabs ( other I
0.02
0.02
0.02
0 03
<0.01
<0.01
6.65
10.91
0.02
0.02
6 68
10.94
Sea Basses
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
2.42
3.96
<0.01
<0.01
<0.01
3.96
Shrimp (other)
<0.01
<0.01
<0.01
0.01
<0.01
<0.01
0.53
0.88
<0.01
<0.01
0.54
0.89
I )rums and croakers
0.04
0.04
0.04
0.07
<0.01
<0.01
0 19
0.32
0.04
0.04
0.24
0.38
I)un»enesscrab
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.01
<0.01
<0.01
<0.01
0.01
Flounders
<0.01
<0.01
0.01
0.02
<0.01
<0.01
0.08
0 13
<0.01
<0.01
0.09
0.15
Fish (otl
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.01
<0.01
<0.01
<0.01
0.02
Northern anchovy
0 29
0 32
0 33
0 49
<0.01
<0.01
0 03
0.04
0.29
0.32
0 36
0.54
Rockiishes
0.01
0.01
0.02
0.02
<0.01
<0.01
5 40
8.85
0.01
0.01
^42
8.88
Salmon
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Sculpins
0.01
0.01
0.01
0.02
<0.01
<0.01
0.36
0.60
0.01
0.01
0.38
0.62
Smelts
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Striped bass
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.01
0.02
<0.01
<0.01
0.01
0.02
Sunlish
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Surl perches
0.10
0.1 1
0.1 1
0.16
<0.01
<0.01
<0.01
<0.01
0.10
0.11
0.11
0.16
Total (all species)
0.68
0.73
0.77
1.13
<0.01
<0.01
30.75
50.42
0.68
0.73
31.52
51.55
Notes:
P4 = Proposal Option 4; F = Final Rule - Existing Units; P2 = Proposal Option 2; and B = Baseline
Source: U.S. EPA analysis for this report
May 2014
C-1
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
Table C-2: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the California Region (million individuals per
year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
American shad
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Blennies
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
390.33
639.92
<0.01
<0.01
390.33
639.92
Bluegill
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0 01
<0.01
<0.01
<0 01
<0.01
<0.01
Brown bullhead
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Cabezon
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
2.84
4 65
<0.01
<0.01
2.84
4.65
California halibut
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
3.29
5.40
<0.01
<0.01
3.29
5.40
California scorpionfish
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Chinook salmon
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Crabs (other)
0.02
0.02
0.03
0.04
<0.01
<0.01
3.088.48
5.063.36
0.02
0.02
3.088.51
5.063.39
Delta smelt
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.01
<0.01
<0.01
<0.01
0.01
I )rums and croakers
0 IS
0 |y
0 20
0 30
<0.01
<0.01
390.48
640.16
0 18
0 19
390.68
640.46
I )un»eness crab
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.04
0.06
<0.01
<0.01
0.04
0.06
Fish ( other I
0.04
0.04
0.04
0.06
<0.01
<0.01
554.48
909.03
0.04
0.04
554.52
909.10
Flounders
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
136.20
223 29
<0.01
<0.01
136.20
223.30
Gobies
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
673.78
1.104.62
<0.01
<0.01
673.78
1.104.62
I lerrnms
0.02
0.03
0.03
0.04
<0.01
<0.01
11.19
18 35
0.02
0.03
1 1.22
18.39
Foimlin smelt
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Northern anchovy
0 37
0 39
0 42
0 61
<0.01
<0.01
352.68
578.20
0 37
0 39
353 10
578.81
Pacific herriim
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
15.43
25.30
<0.01
<0.01
15.43
25.30
Rocklishes
0.01
0.01
0.01
0.02
<0.01
<0.01
27.29
44.74
0.01
0.01
27.30
44.76
Sacramento splittail
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Salmon
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Sculpins
<0.01
<0.01
<0.01
0.01
<0.01
<0.01
20.45
33.53
<0.01
<0.01
20.46
33.54
Sea Basses
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
5.65
9 26
<0.01
<0.01
5.65
9.26
Shrimp (other)
0.01
0.02
0.02
0.02
<0.01
<0.01
183.13
300.24
0.01
0.02
183.15
300.26
Silversides
0.05
0.05
0.05
0.08
<0.01
<0.01
51.98
85 22
0.05
0.05
52.04
85.30
Smallmouth bass
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Smelts
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
1.55
2.54
<0.01
<0.01
1.55
2.54
Striped bass
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
4.82
7.91
<0.01
<0.01
4.82
7.91
Sun lish
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Surfperches
0.06
0.06
0.06
0.09
<0.01
<0.01
<0.01
<0.01
0.06
0.06
0.06
0.09
Total (all species)
0.77
0.83
0.88
1.30
<0.01
<0.01
5,914.12
9,695.80
0.77
0.83
5,915.00
9,697.09
Notes:
P4 = Proposal Option 4; F = Final Rule - Existing Units; P2 = Proposal Option 2; and B = Baseline
Source: U.S. EPA analysis for this report
May 2014
C-2
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
C.2 North Atlantic Region
Table C-3: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the North Atlantic (million A1Es per year), and
Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
All forage species
0.35
0.37
0.50
0.53
<0.01
0.40
34.30
44.80
0.35
0.77
34.80
45.34
All harvested species
0.05
0.05
0.07
0.08
<0.01
0.1 1
9.52
12.44
0.05
0.16
9.60
12.52
American plaice
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
American shad
<0.01
<0 01
<0.01
<0 01
<0.01
<0.01
<0.01
<0.01
<0.01
<0 01
<0.01
<0.01
Atlantic cod
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.01
<0.01
<0.01
0.01
0.01
Atlantic herriim
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.09
0.12
<0.01
<0.01
0.09
0.12
Atlantic mackerel
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.02
0.02
<0.01
<0.01
0.02
0.02
Atlantic menhaden
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.03
0.04
<0.01
<0.01
0.03
0.04
Bl uc fish
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Butterlish
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Crabs ( other)
0.02
0.02
0.03
0.03
<0.01
<0.01
<0.01
<0.01
0.02
0.02
0.03
0.03
C miner
<0.01
<0.01
<0.01
<0.01
<0.01
0.04
3.14
4.10
<0.01
0.04
3.14
4.11
l- ish (other I
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Pollock
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Red hake
<0 01
<0 01
<0 01
<0 01
<0.01
<0.01
<0.01
<0.01
<0.01
<0 01
<0.01
<0.01
Sculpins
<0.01
<0.01
<0.01
<0.01
<0.01
0.02
1.43
1.87
<0.01
0.02
1.44
1.87
Scup
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Searobin
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.01
<0.01
<0.01
<0.01
0.01
Silver hake
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Skates
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Striped bass
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Tautosi
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.08
0.1 1
<0.01
<0.01
0.08
0.1 1
\\ eaklish
<0.01
<0 01
<0.01
<0 01
<0.01
<0.01
<0.01
<0.01
<0.01
<0 01
<0.01
<0.01
White perch
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Window pane
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.02
0.02
<0.01
<0.01
0.02
0.02
Winter iloimder
0.02
0.02
0.02
0.02
<0.01
0.05
4.69
6.13
0.02
0.07
4.71
6.15
Total (all species)
0.40
0.42
0.57
0.61
<0.01
0.51
43.83
57.24
0.40
0.93
44.40
57.86
Notes:
P4 = Proposal Option 4; F = Final Rule - Existing Units; P2 = Proposal Option 2; and B = Baseline
Source: U.S. EPA analysis for this report
May 2014
C-3
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
Table C-4: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the North Atlantic (million individuals per
year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
Alewife
0.02
0.02
0.02
0.03
<0.01
0.02
2.13
2.78
0.02
0.04
2.15
2.80
American plaice
<0.01
<0.01
<0.01
<0.01
<0.01
0.86
73.53
96.04
<0.01
0.86
73.53
96.04
American sand lance
0.05
0.05
0.07
0.08
<0.01
6.31
542.26
708.25
0.05
6.36
542.33
708.33
American shad
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Atlantic cod
<0.01
<0.01
<0.01
<0.01
<0.01
0.50
43 33
56.59
<0.01
0.50
43.33
56.59
Atlantic herring
<0.01
<0.01
0.01
0.01
<0.01
0 i7
32.23
42.09
<0.01
0 18
32 24
42.1 1
Atlantic mackerel
<0 01
<0.01
<0 01
<0.01
<0.01
id "O
2.608.87
3.407.48
<0.01
id "O
2.608.87
3.407.48
Atlantic menhaden
<0.01
<0.01
<0.01
<0.01
<0.01
18.06
1.552.60
2.027.86
<0.01
18.07
1.552.60
2.027.87
Atlantic silverside
0.04
0.05
0.06
0.07
<0.01
0.41
35.65
4.56
0.04
0.46
35.71
46.63
Atlantic tomcod
<0.01
<0.01
<0.01
<0.01
<0.01
0.03
2.32
3.03
<0.01
0.03
2.32
3.03
Ba\ audiovv
<0.01
0.01
0.01
0.01
<0.01
239.73
20.604.68
26.912.03
<0.01
239.74
20.604.69
26.912.04
Blueback herriim
<0.01
<0.01
<0.01
<0.01
<0.01
<0 01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Bluelish
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.02
0.03
<0.01
<0.01
0.02
0.03
Buttertish
<0.01
<0.01
<0.01
<0.01
<0.01
0.05
4.48
5.86
<0.01
0.05
4.49
5.86
Crabs (other)
001
0.01
0 02
0.02
<0.01
<0.01
<0.01
<0.01
0.01
0.01
0.02
0.02
C Miner
<0.01
<0.01
<0.01
<0.01
<0.01
125.28
10.767.77
14.063.92
<0.01
125.28
10.767.78
14,063.92
Fish (other)
0.02
0.02
0.03
0.03
<0.01
2.24
192.48
251.40
0.02
2.26
192.51
251.43
Fourbeard rockliim
<0.01
<0.01
<0.01
<0.01
<0.01
1.99
171.36
223.81
<0.01
1.99
171.36
223.81
Grubby
<0.01
<0.01
0.01
0.01
<0.01
1.85
159.12
207.83
<0.01
1.86
159.13
207.84
I losichoker
0.01
0.01
0.02
0.02
<0.01
2.36
202.71
264.77
0.01
2.37
202.73
264.79
Fumpfish
<0.01
<0.01
<0.01
<0.01
<0.01
0.19
16.57
21.64
<0.01
0.19
16.57
21.64
Northern pipefish
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.42
0.55
<0.01
<0.01
0.43
0.56
Pollock
<0 01
<0 01
<0 01
<0.01
<0.01
0.01
1.28
1.67
<0 01
0.02
1.28
1.67
Radiated sliannv
<0.01
<0.01
<0.01
<0.01
<0.01
0.47
40.74
53.21
<0.01
0.47
40.74
53.21
Rainbow smelt
0.02
0.02
0.02
0.02
<0.01
0.08
6.51
8.51
0.02
0.09
6.54
8.53
Red hake
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Rock sumnel
<0.01
<0.01
<0.01
<0.01
<0.01
1.70
146.13
190.86
<0.01
1.70
146.13
190.86
Sculpins
<0.01
<0.01
<0.01
<0.01
<0.01
0.94
80.72
105.42
<0.01
0.94
80.72
105.43
Scup
<0.01
<0.01
<0.01
<0.01
<0.01
0.07
6.14
8.02
<0.01
0.07
6.14
8.03
Seaboard »obv
<0.01
<0.01
<0.01
<0.01
<0.01
10.22
878.37
1.147.25
<0.01
1022
878.37
1.147.25
Searobin
<0.01
<0.01
<0.01
<0.01
<0.01
0.05
4.24
5.53
<0.01
0.05
4.24
5.53
Silver hake
0.01
0.01
0.02
0.02
<0.01
2.44
209.93
274.19
0.01
2.45
209.94
274.20
Skates
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Striped bass
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Striped killiiish
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.02
0.03
<0.01
<0.01
0.02
0.03
Tautosi
<0.01
<0.01
<0.01
<0.01
<0.01
125.83
10.815.39
14.126.1 1
<0.01
125.84
10.815.39
14.126.11
Ihreespine stickleback
<0.01
<0.01
0.01
0.01
<0.01
<0.01
0.03
0.04
<0.01
<0.01
0.04
0.06
Weaklish
<0.01
<0.01
<0.01
<0.01
<0.01
1.47
126.32
164.99
<0.01
1.47
126.32
164.99
May 2014
C-4
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
Table C-4: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the North Atlantic (million individuals per
year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
White perch
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.10
0.14
<0.01
<0.01
0.11
0.14
Window pane
<0.01
<0.01
<0.01
<0.01
<0.01
iac 1
[3C j
\oc\
762.82
996.32
<0.01
8.88
762.82
996.33
Winter flounder
0.03
0.03
0.04
0.04
<0.01
28.72
2.468.75
3.224.46
0 03
28.75
2,468.79
3,224.51
Total (all species)
0.28
0.30
0.40
0.44
<0.01
611.52
52,560.02
68,649.28
0.28
611.82
52,560.42
68,649.72
Notes:
P4 = Proposal Option 4; F = Final Rule - Existing Units; P2
Source: U.S. EPA analysis for this report
Proposal Option 2; and B = Baseline
May 2014
C-5
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
C.3 Mid-Atlantic Region
Table C-5: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Mid-Atlantic (million A1Es per year), and
Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
All forage species
10.91
1 1.65
13.32
14.42
0.72
1.09
402.14
461.47
1 1.63
12.75
415.46
475.89
All harvested species
18766
17*94
22.79
2AW
alii
(771
71377*
13612
I7.8T*
2(725
I3(vl4
1557)8
Alewil'e
(71)2
(77)3
(77)3
(77)3
(7(11
olll
<671
(761
67)2
(767"
67)3
7)7)4
American shad
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
Table C-5: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Mid-Atlantic (million A1Es per year), and
Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
Spotted seatrout
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Striped bass
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.76
0.88
<0.01
<0.01
0.77
0.88
Striped mullet
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Summer flounder
0.01
0.01
0.02
0.02
<0.01
<0.01
<0.01
<0.01
0.01
0.01
0.02
0.02
Sunlish
0.01
0.01
0.01
0.01
<0.01
<0.01
<0.01
<0.01
0.01
0.01
0.01
0.01
Tautog
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Weaklish
0.84
0.89
1.02
I.I 1
<0.01
<0.01
1.49
1.70
0.84
0.90
2.51
2.81
White perch
1.55
1.66
1.89
2.05
0.02
0.04
13.11
15.04
1.57
1.69
15.00
17.09
Whitefish
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Window pane
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Winter llounder
<0.01
0.01
0.01
0.01
<0.01
<0.01
0.06
0.07
<0.01
0.01
0.07
0.08
Total (all species)
29.57
31.60
36.11
39.08
0.93
1.40
515.78
591.89
30.50
32.99
551.90
630.97
Notes:
P4 = Proposal Option 4; F = Final Rule - Existing Units; P2 = Proposal Option 2; and B = Baseline
Source: U.S. EPA analysis for this report
May 2014
C-7
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
Table C-6: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Mid-Atlantic (million individuals per year),
and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
Alewife
0.10
0.10
0.12
0.13
<0.01
<0.01
1.68
1.92
0.10
0.11
1.80
2.05
American shad
0.02
0.02
0.02
0.02
0.03
0.05
18.41
21.13
0.05
0.07
18.43
21.15
Atlantic croaker
0.66
0.71
0.81
0.88
0.34
0.51
189.17
217.08
1.01
1.22
1 89.98
217.96
Atlantic herring
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Atlantic menhaden
20.54
21.95
25.08
27.15
0.06
0.09
33 65
38.62
20.60
22 04
58.74
65.77
Atlantic silverside
0.41
0.44
0.50
0.54
0.05
0.08
30.24
34.70
0.46
0.52
30.74
35.24
Atlantic tomcod
0.04
0.04
0.05
0.05
<0.01
<0.01
<0.01
<0.01
0.04
0.04
0.05
0.05
Ba\ anchovv
4.02
4.29
4.91
5 ^
48.59
73.22
26.996.1 5
30.979.52
52.60
77.51
27,001.05
30,984.82
Black crappie
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Black drum
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Blue crab
0.84
0.89
1 02
FI0
1.68
2.53
932.50
1.070.10
2.51
933 53
1.071.20
Blueback herring
0.37
0.39
0.45
0.49
0.01
0.02
6.66
i
0.38
0.41
8.13
Bluefish
<0.01
<0.01
0.01
0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.01
0.01
Bluegill
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Bluntnose minnow
<0 01
<0.01
<0 01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0 01
<0.01
<0.01
Brown bullhead
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.03
0.03
<0.01
<0.01
0.03
0.04
Bullheads
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Butteriish
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Carp
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Chain pipefish
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Channel cattish
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Crabs (other)
0.01
0.01
0.01
0.01
<0.01
<0.01
<0.01
<0.01
0.01
0.01
0.01
0.01
Crappie
<0 01
<0 01
<0 01
<0.01
<0.01
<0.01
<0.01
<0.01
<0 01
<0 01
<0.01
<0.01
C unner
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
I )arters
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Fish (other)
1.56
1.66
1.90
2.06
1.88
2.83
1.044.61
1,198.74
3.44
4.50
1,046.51
1,200.80
Freshwater drum
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0 01
Cii/./ard shad
0.10
0.11
0 12
0.13
<0.01
<0.01
<0.01
<0.01
0.10
0.1 1
0.12
0 13
Gobies
<0.01
<0.01
<0.01
<0.01
0.07
0.1 1
39 50
45.33
0.07
0.1 1
39.50
45.33
Grubby
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
I lerriims
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
I Iosichokcr
0.15
0.16
0.19
0.20
12.83
19.34
7.129.97
8.182.02
12.99
19.50
7.130.16
8.182.22
Menhadens
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.03
0.03
<0.01
<0.01
0.03
0.03
Muskelluime
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Northern pipefish
<0.01
0.01
0.01
0.01
<0.01
<0.01
2.92
3.35
0.01
0.02
2.93
3.37
Rainbow smelt
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Red drum
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Red hake
0.02
0.02
0.03
0.03
<0.01
<0.01
<0.01
<0.01
0.02
0.02
0.03
0.03
May 2014
C-8
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
Table C-6: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Mid-Atlantic (million individuals per year),
and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
Scup
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Seaboard goby
<0.01
<0.01
<0.01
<0.01
6.76
10.20
3,758.88
4,313.52
6.77
10.20
3,758.89
4,313.52
Searobin
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
C.4 South Atlantic Region
Table C-7: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the South Atlantic (million A1Es per year), and
Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
All forage species
10.98
1 1.77
16.05
16.21
<0.01
0.44
7.86
8.41
10.98
12.21
23.91
24.61
All harvested species
0 63
0.68
0.92
0.93
<0.01
0.04
0.76
0.82
0.63
0.72
1.69
1.75
Atlantic menhaden
O.I 3
0.14
0.19
0.19
<0.01
<0.01
0.02
0.03
0.13
0.14
0.21
0.22
Blue crab
0.23
0.25
0 i4
0 i4
<0.01
<0.01
<0 01
<0.01
0.23
0.25
0.34
0.34
Crabs ( other)
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.02
0.02
<0.01
<0.01
0.02
0.02
I )rums and croakers
0.01
0.01
0.02
0.02
<0.01
0.04
0.63
0.68
0.01
0.05
0.65
0.70
Flounders
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Fish ( other I
<0.01
<0.01
0.01
0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.01
Pinlish
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Silver perch
0.14
0.15
0.21
0.21
<0.01
<0.01
<0.01
<0.01
0.14
0.15
0.21
0.21
Spot
0.10
0.1 1
0.15
0.15
<0.01
<0.01
0.08
0.08
0.10
0.1 1
0.23
0.23
Spotted seatrout
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Stone crab
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Weaklish
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Total (all species)
11.61
12.44
16.97
17.14
<0.01
0.48
8.62
9.22
11.61
12.93
25.60
26.36
Notes:
P4 = Proposal Option 4; F = Final Rule - Existing Units; P2 = Proposal Option 2; and B = Baseline
Source: U.S. EPA analysis for this report
May 2014
C-10
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
Table C-8: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the South Atlantic (million individuals per
year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
Atlantic menhaden
0.21
0.23
0.31
0.31
<0.01
3.48
62.28
66.59
0.21
3.71
62.59
66.90
Atlantic silverside
0.03
0.03
0.05
0.05
<0.01
<0.01
<0.01
<0.01
0.03
0.03
0.05
0.05
Ba\ audiovv
6.59
7.06
9.63
9.73
<0.01
53.13
949.88
1.015.58
6.59
60.19
959.52
1.025.31
Blue crab
0.23
0.25
0.34
0.34
<0.01
<0.01
<0.01
<0.01
0.23
0.25
0.34
0.34
Crabs ( other I
<0.01
<0.01
<0.01
<0.01
<0.01
14.77
264.07
282.33
<0.01
14.77
264.07
282.33
I )rums and croakers
0.06
0.06
0.08
0.08
<0.01
52.55
939.64
1.004.62
0.06
52.61
939.72
1.004.70
Fish ( other I
0.43
0 46
0 61
0 64
<0.01
6.04
107.92
1 15.39
0.43
6.50
108.55
1 16 02
Flounders
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Gobies
<0.01
<0.01
<0.01
<0.01
<0.01
79.08
1,413.86
F511.63
<0.01
79 08
1.413.86
F51 1.63
I lerrnms
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
I'm fish
<0.01
<0.01
<0.01
<0.01
<0.01
1.58
28.20
30 15
<0.01
28.20
30 15
Scaled sardine
<0.01
<0.01
0.01
0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.01
0.01
Shrimp (other)
2.30
2.46
3.36
3 39
<0.01
23.01
411.34
439.78
2.30
25.47
414.69
443.17
Silver perch
0.12
0.12
0.17
0.17
<0.01
<0.01
<0.01
<0.01
0.12
0.12
0.17
0.17
Spot
0.18
0.20
0.27
0.27
<0.01
47.60
851.08
909.94
0.18
47.80
851.35
910.21
Spotted sea trout
<0.01
<0.01
<0.01
<0.01
<0.01
0.78
1 i 96
14.92
<0.01
0.78
13.96
14.92
Stone crab
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Weak lish
0.01
0.01
0.02
0.02
<0.01
2.23
39 93
42.69
0.01
2.25
39.94
42.70
Total (all species)
10.17
10.90
14.87
15.02
<0.01
284.24
5,082.16
5,433.62
10.17
295.15
5,097.03
5,448.64
Notes:
P4 = Proposal Option 4; F = Final Rule - Existing Units; P2 = Proposal Option 2; and B = Baseline
Source: U.S. EPA analysis for this report
May 2014
C-11
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
C.5 Gulf of Mexico Region
Table C-9: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Gulf of Mexico (million A1Es per year), and
Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
All forage species
4 84
5.03
6.03
6.70
0.04
0.04
25.66
43.45
4.88
5.06
31.69
50.15
All harvested species
33.90
"o 18
42.20
46.85
0.04
0.04
29.53
50.01
33.94
35.22
71.73
96.86
Atlantic croaker
1.42
1.48
1.77
1.96
<0.01
<0.01
<0.01
<0.01
1.42
1.48
1.77
1.97
Black drum
0.0I
0.01
0.01
0.02
<0.01
<0.01
3.61
6.12
0.02
0.02
3.62
6.13
Blue crab
4 86
5.05
6.06
6.72
0.02
0.02
11.59
19.63
4.88
5.06
17.65
26.35
I .eatherjacket
0.59
0.62
0.74
0.82
<0.01
<0.01
0.02
0.03
0.59
0.62
0.76
0.85
Mackerels
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Menhadens
4.26
4.42
5 30
5.89
<0.01
<0.01
0.03
0.05
4.26
4.42
5.33
5.94
Fish ( other I
1.28
1 i2
1.59
1.76
<0.01
<0.01
0.10
0.16
1.28
0.97
1.18
1.93
Pinlish
0.02
0.03
0.03
0.03
<0.01
<0.01
0.65
1.11
0.03
0.03
0.68
1.14
Pink shrimp
18.44
19 14
22 95
25 48
0.01
0.01
8.17
13.83
18.45
19 15
31.12
39.31
Red drum
0.07
0.07
0.09
0.10
<0.01
<0.01
<0.01
0.01
0.07
0.07
0.10
0.1 1
Sea basses
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Searobin
0.80
0.83
1.00
<0.01
<0.01
0 22
0.38
0.80
0 84
1.22
1.49
Sheepshead
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.02
0.04
<0.01
<0.01
0.02
0.04
Silver perch
0.24
0.25
0 30
0 33
<0.01
<0.01
5.28
0.25
0.26
3.42
5.61
Spot
0.33
0.34
0.41
0.45
<0.01
<0.01
0.05
0.09
0.33
0.34
0.46
0.54
Spotted seatrout
1.08
1.12
1 "O
1.50
<0.01
<0.01
0.09
0.15
1.08
1.12
1.44
1.65
Stone crab
0.16
0.17
0.20
0.22
<0.01
<0.01
0.25
0.43
0.16
0.17
0.45
0.65
Striped mullet
0.32
0.33
0.40
0.44
<0.01
<0.01
1.59
2.70
0.32
0.33
1.99
3.14
Total (all species)
38.74
40.21
48.23
53.55
0.08
0.08
55.19
93.46
38.82
40.29
103.42
147.01
Notes:
P4 = Proposal Option 4; F = Final Rule - Existing Units; P2 = Proposal Option 2; and B = Baseline
Source: U.S. EPA analysis for this report
May 2014
C-12
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
Table C-10: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Gulf of Mexico (million individuals per
year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
Atlantic croaker
664
6.90
8.27
9.18
0.07
0.07
49.45
83.75
6.71
6.96
57.73
92.93
Ba\ anchovv
1.86
1.93
2 i2
2.57
126.59
126.59
91.714.39
155,318.87
128.45
128.52
91,716.71
155,321.44
Black drum
0.0I
0.01
0.01
0.01
40.50
40.50
29.342.08
49,690.98
40.51
40.51
29,342.09
49,691.00
Blue crab
4.84
5.03
6.03
6.69
0.12
0.12
85.58
144.93
4.96
5.14
91.61
151.63
Chain pipefish
0.03
0.03
0.04
0.04
<0.01
<0.01
0.65
FI0
0.03
0.03
0.68
F14
Fish (other I
3.32
^ 98
4.42
4.11
4.1 1
2.980.35
5.047.23
7.31
7.43
2.984.32
5.05 F65
Gobies
0.06
0.06
0.07
0.08
1.43
1.43
1.038.00
1.757.86
1.49
1.49
1.038.07
1.757.94
(iulf kilhlish
0.02
0.02
0.02
0.02
<0.01
<0.01
<0 01
<0.01
0.02
0.02
0 02
0.02
I Io»choker
0.06
0.06
0.08
0.09
0.08
0.08
60.53
102.51
0.15
0.15
60.61
102.60
Featherjacket
0.41
0.42
0.51
0.56
0.33
0.33
241.86
409.59
0.74
0.76
242.37
410.16
Mackerels
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Menhadens
6.91
7.17
8.60
9.54
0.1 1
0.1 1
81.98
138.83
7.02
7.28
90.58
148.37
Pinlish
0.05
0.05
0.06
0.07
0.05
0.05
32.83
55.60
0.10
0.10
32.90
55.68
Pink shrimp
18.80
19.51
2 i 41
25.98
0.05
0.05
38.48
65.16
18.85
19.57
61.88
91.15
Red drum
0.07
0.07
0.08
0.09
<0.01
<0.01
0.33
0.57
0.07
0.07
0.42
0.66
Scaled sardine
0.14
0.14
0.17
0.19
1.25
1.25
902.35
1.528.14
1.38
1 i9
902.52
1.528.33
Sea basses
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Searobin
0.51
0.52
0.63
0.70
0.03
0.03
20.96
35.50
0.53
0.55
21.59
36.20
Sheepshead
<0.01
<0.01
<0.01
<0.01
0.16
0.16
1 16.63
197.51
0.16
0.16
1 16.63
197.51
Silver perch
0.20
0.20
0.24
0.27
37.41
37.41
27.105.51
45.903.34
37.61
37.62
27.105.75
45,903.61
Spot
0.60
0.62
0.74
0.82
0.01
0.01
10.59
17.93
0.61
0.63
11.33
18.75
Spotted seatrout
0.52
0.54
0.64
0.71
2.24
2.24
1.625.98
2.753.61
2.76
2.78
1.626.63
2.754.33
Stone crab
0.12
0.12
0.15
0.16
12.07
12.07
8.745.52
14.810.59
12.19
12.19
8.745.67
14.810.76
Striped mullet
0.19
0.20
0.24
0.27
<0.01
<0.01
4.62
7.82
0.20
0.21
4.86
8.09
Tidewater
silverside
0.13
0.13
0.16
0.18
0.01
0.01
10.47
17.73
0.14
0.15
10.63
17.90
Total (all species)
45.35
47.07
56.46
62.68
226.65
226.65
164,209.14
278,089.16
272.00
273.72
164,265.60
278,151.84
Notes:
P4 = Proposal Option 4; F = Final Rule - Existing Units; P2 = Proposal Option 2; and B = Baseline
Source: U.S. EPA analysis for this report
May 2014
C-13
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
C.6 Great Lakes Region
Table C-11: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Great Lakes (million A1Es per
year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
All forage species
175.87
193.55
220.56
226.20
0.01
0.03
9.94
13.81
175.88
193.58
230.50
240.01
All harvested species
8J5
8797
1(722
1(7.49
(7771
0 03
77*75
1(776
87177
9.(7*0
1 **77*7***
21*72*5
I Muck bullhead
<()T)i
(7oi
(7oi
(7771
(7771
(7771
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
Table C-12: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Great Lakes (million individuals per
year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
Alewife
9.70
10.68
12.17
12.48
10.31
32.56
10,003.26
3,898.65
20.02
43.24
10,015.44
13,911.13
Black bullhead
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Black crappie
<001
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Blueback herring
7i*8****
2.1**3
77i
fjggo'f
167771*
Gizzard shad
2*8*71*
31781
36.2**5
37718
1*7*6*4
3****2**9
1*7)69:94
77*10723***
*2**9.95
*3**5**7(7*
17(71(726
771671*
Golden redhorse
<(77)1
*6761
*6**77*1
*6*771
676*1
*6761*
*6*76*1
*6*76*1
676*1
6*76*1
*6*761
*6*761
Herrings
<(77)1
*6**77*1
*6**77*1
*6*771
676*1
*6761*
*2.9*3
7*6*7***
<0.01
<0.01
7*93
4.67
Logperch
0 27
0 30
0 34
0 35
*6*76*3
*671*6
3**1*7*55
*47*8**7*
67*3*6
67*6****
71*7*8**8*
*44.7*8
Muskellunge
(777i
*6**77*1
*6**77*1
*67)1*
6761*
*6761*
*67*3*2
771
676*1
*67*6*1*
67*3*2
674*4
Rainbow smelt
0 24
0 27
0 31
0 31
6****72
2***2*8
1)729
77*738***
677***
:
77F776
7777)
Salmon
<(77)1
*6**77*1
*6**77*1
*6*771
676*1
*6761*
1*72
2.25
676*1
6*76*1
7(7*2
2.25
Sanger
<(77)1
*6**77*1
*6**77*1
*6*771
676*1
*6761*
*6*76*1
*6*76*1
676*1
6*76*1
*6*761
*6*761
Sculpins
(777i
*6**77*1
*6**77*1
*67)1*
6761*
*6761*
*67*9*2
72**8***
676*1
*67*6*1*
67*9*2
72**8*
Shiners
0.70
0.77
0.88
0.90
0.04
0.13
39.21
54.47
0.74
0.90
40.08
55.37
Silversides
(77)4
*6**777
67)5
*6*7)5
676*1
*6761*
*6*76*1
*6*76*1
0.04
0.04
*6*76**5
*6*76*5
Smallmouth bass
(7771
'
0.02
7)7)2
*
*67)2
676*1
*6761*
*6*76*1
*6*76*1
676*1
67*6*2
*
*6*76**2
*6*76*2
Smelts
173*6*
1 52
676*4
*671**3
3*7*56
5*7**97***
72*2*
4T7o4
56.49
Spotted sucker
(777i
<6'.oi
*6**77*1
*67)1*
6761*
*6761*
*6*76*1
*6*76*1
676*1
*67*6*1*
*67*61
*6*761
Striped killitish
(777i
<6'.oi
*6**77*1
*67)1*
6761*
*6761*
*6*76*1
*6*76*1
676*1
*67*6*1*
*67*61
*6*761
Suckers
<(77)1
<6767
*6**77*1
*6*771
6*76*3
(716
71*7*48
*47*74***
676*4
671**1
7779
437*7*5
Sun lish
o771
*6*7)1*
*6*77*1
*6*771
676*1
*6761*
2.54
7**5*7***
676*1
76*2
2.55
771*
Threespine
stickleback
0.02
0.02
0.03
0.03
<0.01
<0.01
0.18
0.25
0.02
0.02
0.21
0.28
Walleye
(7oy
671*6
*67*1**1
*67*1**1*
6761*
*676*3
*7*2**5*
1*277***
6**7*6
*6**73
7*3(7
*1*7**9*7*
White bass
244
2***3*5
2.68
2***7*5
676(7
*6*7*9
5771*7
7744***
2*72*6
771
57*86
87**1*9
May 2014
C-15
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
Table C-12: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Great Lakes (million individuals per
year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
White perch
9.14
10.06
11.46
11.76
0.25
0.80
245.11
340.56
9.39
10.86
256.57
352.31
Whitefish
0.03
0.03
0.04
0.04
<0.01
<0.01
0.08
0.11
0.03
0.03
0.12
0.15
Yellow perch
0.74
0.82
0.93
0.96
0.02
0.05
14.81
20.58
0.76
0.87
15.75
21.54
Total (all species)
80.58
88.68
101.05
103.64
26.28
82.96
25,489.28
35,415.10
106.85
171.64
25,590.33
35,518.74
Notes:
P4 = Proposal Option 4; F = Final Rule - Existing Units; P2 = Proposal Option 2; and B =
Source: U.S. EPA analysis for this report
3aseline
May 2014
C-16
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
C.7 Inland Region
Table C-13: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Inland Region (million A1Es
per year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
All forage species
324.12
335.14
386.58
443.70
0.21
1.11
120.73
155.43
324.34
336.25
507.31
599.13
All harvested species
23.61
24.42
28.16
32.33
0.17
0.89
96.71
124.51
23.79
25.31
124.88
156.84
American shad
0.04
0.04
0.04
0.05
<0.01
<0.01
<0.01
<0.01
0.04
0.04
0.04
0.05
I Mack bullhead
0 13
0 13
0 15
0.17
<0.01
<0.01
<0.01
<0.01
0 13
0 13
0.15
0 18
Black crappie
0.05
0.05
0.05
0.06
<0.01
<0.01
0 37
0.48
0.05
0.05
0.42
0.54
Bluesiill
1 46
1.74
2.00
<0.01
<0.01
o n
0.17
1 46
1
1.87
2.17
Brown bullhead
0.02
0.02
0.02
0.03
<0.01
<0.01
0.03
0.04
0.02
0.02
0.05
0.07
Bullheads
0.02
0.02
0.02
0.02
<0.01
<0.01
<0.01
<0.01
0.02
0.02
0 03
0 03
Channel cattish
1.16
1 34
1.54
<0.01
<0.01
0.74
0.95
1.17
2.08
2 50
Crappie
0.08
0.08
0.09
0.1 1
<0.01
<0 01
1.03
1.32
0.08
0.09
1.12
1.43
Freshwater drum
0.82
0.85
0.98
1.13
<0.01
0.04
4.64
5.97
0.83
0.89
5.62
7.10
Menhadens
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Muskellunge
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Fish (other)
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.05
0.06
<0.01
<0.01
0.05
0.07
Rainbow smelt
0.10
0.10
0 1 1
0.13
<0.01
<0.01
0.15
0.20
0.10
0.10
0.27
0 3 3
Salmon
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Sauger
0.07
0.07
0.08
0.09
<0.01
0.01
1.29
1.65
0.07
0.08
1 36
1.74
Smallmouth bass
0 16
0.17
0 19
0.22
<0.01
0 03
2.72
3 50
0.17
0 19
2.92
Smelts
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Striped bass
0 11
0 11
0 13
0 15
<0.01
<0.01
<0.01
<0.01
0 1 1
0 1 1
0 13
0.15
Stumeons
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.02
0.02
<0.01
<0.01
0.02
0.02
Sunlish
1 3 76
14 23
1641
18.84
0 14
0 75
80.88
104.13
13 91
14.98
97.30
122.97
Walleye
0.04
0.04
0.05
0.05
<0.01
<0.01
0.50
0.65
0.04
0.04
0.55
0.70
White bass
1.62
1.68
1 94
2.22
<0.01
0.02
1.96
2.52
1 63
1.70
3.89
4.74
White perch
1.78
1.84
2.12
2.44
<0.01
<0.01
0.41
0.52
1.78
1.85
2.53
2.96
Whiteiish
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Yellow perch
2.24
2.31
2.67
3.06
<0.01
0.02
1.79
2.31
2.24
2.33
4.46
5.37
Total (all species)
347.74
359.55
414.75
476.03
0.39
2.00
217.45
279.94
348.12
361.55
632.19
755.97
Notes:
P4 = Proposal Option 4; F = Final Rule - Existing Units; P2 = Proposal Option 2; and B = Baseline
Source: U.S. EPA analysis for this report
May 2014
C-17
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
Table C-14: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Inland Region (million individuals per
year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
Alewife
14.78
15.29
17.63
20.24
<0.01
<0.01
0.47
0.61
14.78
15.29
18.10
20.85
American shad
6.58
6.80
7.84
9.00
<0.01
<0.01
<0.01
<0.01
6.58
6.80
7.84
9.00
Bay anchovy
0.01
0.01
0.01
0.01
<0.01
<0.01
<0.01
<0.01
0.01
0.01
0.01
0.01
Bigmouth buffalo
(To i
o7ii
(7)2
67)2
<67)T
67)2
F98
2.55
0.02
0.03
F99
*7*777
Black bullhead
(771*2
0.12
044
'6716
<67)T
<6771
662
*6762*****
67*1**2
(7*7*12
*(771***6
*6*71**8
Black crappie
(771*2
0.12
044
'6716
6.62
67)8
7**1**2*
1*7*74***
67*1**4
(77**2*1
7*2**6
779*6*
Blue crab
(uTi
<0.7)1
<0.7)1
<6771
6.61
<6771
6761
(7761
<6761
(77**6*1*
*6**7*61
*6**7*61
Blueback herring
6X16
66.34
76.52
7777
144
7*92
7176(7
82T87"
7777)
*72.**2*6*****
'719758
915776
Bluegill
1*7729
12.71
14.66
1(782
6763
(716
17.(75
22**7*2****
1**2.32*
1**2.8**7***
37771
39755
Bluntnose minnow
(77)5
0.7)5
*6*7*6(7
67)7
3.2I
16765
rso^si*
172(7(77*
7772*6
1**776****
f'g073i
7327777
Brown bullhead
(77)2
0.7)2
67)2
67)2
6771
<6771
*64***3
*6**.7*7***
676*2
(77**672
*(771**75*
*6*71**9
Bullheads
(77)2
0.7)2
67)2
67)2
<67)1
(7771
1*7*35
1*7*74***
0.02
0.03
77*7
F76
Burbot
<(777i
<0.771
<67)1
<67'6i
(7771
(77)5
789
7.59
676*1
67*6(7****
7*96
7*5**9
Carp
(773
an
6.75
6718
2.74
11725
771(7(7)
799**17)8****
2.8*7***
14 18
7771*775
Channel cattish
(770
0.73
6.84
(7%
674
(TYi
77.67
97*2**2*****
67**8*4
771
777*91*
*7)6*77*9
Crappie
(721
0.21
0.24
(728
6771
(723
24.87
327677*
6725
6771
72*7*1***2*
'32776
I )arters
(777*1
(77(7
0.41
(747
6.71
(755
59*43
76.71
671*5
67*9*6****
*5*7*8*4*
76798
I Emerald shiner
1 18
r.42
r.64
1789
6777*
271*5
726777
71794
*1**7*8*75*
^ 88
2687*6*3
7177*8*3
Fish (other)
2875
29.73
34.29
39736
71739
23(7**44
2761*7*58
*3721)77*1
77*71
7
25764788
3277177-
Freshwater drum
7:5*8
r.63
r.89
27177
r.96
1**6*4*9
[710(7*1*2
1 424 00
3.54
1 1.83
*1*77*6*7*66
klTTr*!**"
Gizzard shad
17)749
771.74
128.2(7
1477175
12.43
64.55
"76*6^**61
7626.77
1*1**9793
17577(7
7435.21
7*177-7*8*9
Gobies
77)7)7
(7771
<67)1
<6771
(7765
*6***2*7
29.82
37*39****
67*6*75*
6**7*27***
2*7*82
3*7*3*9
Golden redhorse
002
002
0 03
0 03
<6.61
*6*771
r.**(**)**5*
1*7*3*7***
676*2
6*7*63
76*8
777*8*
I losichoker
77)7)7
<0.7)1
67)1
6771
<6.61
*6*771
6761
6761
67*6*1
(77**6*1
*67*6*1
*67*6*1
I .ogperch
0 34
0 36
041
0 47
6762
*671***1
1*17*87
*1**7*28***
6*.37"*
0 47
*1***7*2**8*
*1***7775*
Menhadens
<(777i
(7771
<67)1
<6771
6.61
*6*771
*676*1
(7761
<6761
67*6*1*
*6**7*61
*6**7*61
Muskel lunge
<0.01
<0.01
<0.01
0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.01
0.01
Rainbow smelt
(77)7
0.07
67)8
67)9
6771
*6***2*6
*21*7*76
5767***
0.11
0 27
777i
72*7*1***1
River carpsucker
(7771
0.01
67)1
67)2
<6.61
(77)2
1*7*89
*2.4*4***
676*1
*(**)**.**(**)3
*77i*
771*5
Salmon
<(777i
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
Table C-14: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) in the Inland Region (million individuals per
year), and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
Striped killifish
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Sturgeons
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.54
0.69
<0.01
<0.01
0.54
0.69
Slickers
0.06
0.06
0.07
0.08
2.83
14.70
1.595.57
2.054.12
2.89
14.76
1.595.63
2.054.19
Sunfish
2.21
2.28
2.63
3.02
0.42
2.19
238.12
306.55
2.63
4.47
240.75
309.57
Threespine
stickleback
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Walleve
0.05
0.05
0.06
0.07
0.11
0.57
62.39
80.32
0.16
0.63
62.45
80.39
White bass
0.91
0.94
1.08
1.24
0.70
3.61
392.34
505.10
1.60
4.55
393.42
506.34
White perch
1
1 38
1.60
1.83
0.43
2.24
242.75
312.51
1.77
3 62
244.34
314.34
White lish
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.28
0.36
<0.01
<0.01
0.28
0.36
Yellow perch
3 07
3 66
4.20
0.72
3.72
404.19
520.35
3.78
6.89
407.85
524.55
Total (all species)
249.27
257.74
297.30
341.23
72.49
376.37
40,852.60
52,593.18
321.76
634.10
41,149.89
52,934.41
Notes:
P4 = Proposal Option 4; F = Final Rule - Existing Units; P2 = Proposal Option 2; and B = Baseline
Source: U.S. EPA analysis for this report
May 2014
C-19
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
C.8 National Estimates
Table C-15: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) Nationally (million A1Es per year),
and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
All forage species
527.24
557.69
643.23
708.05
0.98
3.11
615.44
751.65
528.22
560.80
1258.67
1459.70
All harvested species
85.51
89.79
104.95
116.18
0.42
1.42
273.87
355.09
85.94
91.20
378.82
471.28
Alewilc
0.02
0.03
0.03
0.03
<0.01
<0.01
<0.01
<0.01
0.02
0.03
0.03
0.04
American plaice
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
American shad
0.04
0.04
0.04
0.05
<0.01
<0.01
<0.01
<0.01
0.04
0.04
0.05
0.05
Atlantic cod
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.01
<0.01
<0.01
0.01
0.01
Atlantic croaker
1 60
1 67
1 99
221
0.02
0 03
1 1 86
13 61
1 63
1 70
13.85
15.81
Atlantic lierrnm
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.09
0.12
<0.01
<0.01
0.10
0.12
Atlantic mackerel
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.02
0.02
<0.01
<0.01
0.02
0.02
Atlantic menhaden
12.80
1 3 67
15.66
16.93
<0.01
<0 01
1 79
2 05
12.80
13.68
17.44
18.99
Black bullhead
0.13
0.13
0.15
0.17
<0.01
<0.01
<0.01
<0.01
0.13
0.13
0.16
0.18
Black crappie
0.05
0.05
0.05
0.06
<0.01
<0.01
0 37
0.48
0.05
0.05
0.42
0.54
Black drum
0.01
0.01
0.01
0.02
<0.01
<0.01
i 61
6.12
0.02
0.02
3.63
6.13
Blue crab
5 94
6 20
7 42
8 18
0 12
0 18
70.99
87.79
6 06
6 i7
78.41
95.97
Blueiish
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Bluesiill
1.46
1.51
1.75
2.00
<0.01
<0.01
0.13
0.17
1.46
1.51
1.88
2.17
Brown bullhead
0.04
0.04
0.04
0.05
<0.01
<0.01
0.04
0.05
0.04
0.04
0.08
0.10
Bullheads
0.02
0.02
0 0i
0
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
Table C-15: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) Nationally (million A1Es per year),
and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
I .eatheijacket
0.59
0.62
0.74
0.82
<0.01
<0.01
0.02
0.03
0.59
0.62
0.76
0.85
Mackerels
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Menhadens
4.26
4.42
5.30
5.89
<0.01
<0.01
0.03
0.05
4.26
4.42
5.34
5.94
Muskellunge
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Fish (other)
2.08
2.19
2.58
2.83
0.01
0.02
6.08
7.04
2.09
1.21
1.53
9.87
Northern anchovy
0.29
0.32
0.33
0.49
<0.01
<0.01
0.03
0.04
0.29
0.32
0.36
0.54
Pinfish
0.02
0.03
0.03
0.03
<0.01
<0.01
0.66
I.I 1
0.03
0.03
0.69
1.15
Pink shrimp
18.44
19.14
22.95
25.48
0.01
0.01
8.17
13.83
18.45
19.15
31.12
39.31
Pollock
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
Rainbow smelt
0.44
0.48
0.55
0.58
<0.01
0.02
5.48
7.60
0.45
0.50
6.0.3
8.18
Red drum
0.08
0.08
0.09
0.10
<0.01
<0.01
<0.01
0.01
0.08
0.08
0.10
0.12
Red hake
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
Table C-15: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) Nationally (million A1Es per year),
and Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
Walleye
0.10
0.11
0.13
0.13
<0.01
<0.01
0.74
0.97
0.10
0.11
0.86
1.11
Weaklish
0.84
0.90
1.02
I.I 1
<0.01
<0.01
1.49
1.71
0.84
0.90
2.51
2.81
White bass
5.45
5.89
6.74
7.15
<0.01
0.02
2.72
3.58
5.46
5.91
9.46
10.72
White perch
3.33
3.50
4.02
4.49
0.02
0.04
13.52
15.57
3.36
3.54
17.53
20.06
Whitelish
0.14
0.15
0.17
0.17
<0.01
<0.01
<0.01
<0.01
0.14
0.15
0.17
0.17
Windowpane
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
Table C-16: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) Nationally (million individuals per year), and
Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
Alewilc
2460
26.09
29.95
32.87
10.32
32.59
10,007.54
13.903.96
34.92
58.68
10.037.49
13.936.83
American plaice
<(77)1
*(777*1
<7)7) i
<7)7) i
77777
("786
73.53
96.777
777771
77786
77.53
9(77777
American sand lance
(77)5
o*7)5
7)7)7
777)8
77777
6 31
7712(7
77725
7777)5
6776
71777
77777
American shad
-
s
T86
9 03
0 03
(77)5
18.42
7717
6 63
"787
777.28
3(7717
Atlantic cod
<(7771
*(777*1
'(77)1
<7)7) i
77777
0 so
7733
5759
77771
"(777(7
7777
567759
Atlantic croaker
7 31
*"(7*1*
7777s
77)7)6
77 77
0 58
238772
307783
772
8 19
247771
7177789
Atlantic herring
(7777
(77)7
'(77)2
777)2
77777
(737
32.23
177)9
777771
"(779
3771
42711
Atlantic mackerel
(7777
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
Table C-16: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) Nationally (million individuals per year), and
Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
Delta smelt
<0.01
<0.01
<0.01
<0.01
<0.01
0.01
<0.01
0.01
<0.01
<0.01
<0.01
0.01
I )rums and croakers
775!
0"25
(75 s
(lis
lull
52.55
1.330 12
illlls
(Ill
15180
lllliii
i'llTni
I )un»eness crab
<001
lllli
<77cil
(Ill
lull
lull
(1.7)4
0.06
Till
lull
0 04
7)77)77
I Emerald shiner
27/71
30.40
'3466
3575
(ill
2I7
1(1517
'39349
5155
1517
llli!
151751
Fish (other)
!Tl7
35775
Till
4679
6111
2 S1.13
ll^SSil
iriiiii
9578
17155
1182911
li^lil'"!'
Flounders
lull
11111
lull
11)1
lull
lull
736.20
55159
Till
lull
11157)
223.30
Fourbeard rockling
<001
<001
117)1
(1)1
(Ill
lull
ill
759.11
5(117
Till
!s6
illil
207785
Gull'kilhfish
0.02
(17)2
(1)2
(1)2
lull
lull
llli
lull
7)1)5
71115
(7715
7)7715
Herrings
0 01
001
0 01
Full
lull
lull
115
5511
001
77711
i7.11
557777
Fiogchoker
7751
0 25
0 10
0 12
i5!5
2I7S
"I'll!
s!i!59
HI5
22.03
TllTi
S7541775
Leatherjacket
oil
7715
0 51
(756
(ill
(Ill
Iil7s77
loll!
(Ill
7776
215717
717)71
I .ogperch
(Tm
(ill
075
(115
0 05
(751
1111
59.71
7117
7117
77.177
59.1!
Foimlin smelt
<001
lull
11)1
11)1
lull
lull
llli
<(77)1
77711
lull
illil
<7)77)1
Fumplish
<001
lull
11)1
11)1
lull
0 19
1II7
5111
77711
0 19
il.57
51177
Mackerels
lull
lull
11)1
11)1
lull
lull
llli
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
Table C-16: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) Nationally (million individuals per year), and
Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
Scaled sardine
O.I 5
0.15
0.18
0.20
1.25
1.25
902.3 5
1.528.14
1.39
1.40
902.54
1.528.34
Sailpins
oToi
(77771*
(7771
*(**7*0*2*
(7771
*(**7*9*7*
17)2*7)9
17777
*(**7(71
(77*9*5
10277(7
77(777
Scup
oToi
<07*01
<(7771
(77*71
(7771
<77)7
(777
8.02
*(**7(71
7*07
*7*1***7*
7(77
Sea I kisses
<0 01
<(77)1
<0 01
<0.01
(7771
(77*71
5****65
777
*(**7(71
(77(71
*7*75
*7*7
Seaboard goby
7(7777
<(777i
<(7771
<(7771
"
2(7**4*7
4^63T25
77(7777
*7*7*7
2(7177
7*773*7(7
77777"
Searobin
oil
0 53
0 63
(7*7(7
(7777
o*7i*8
2*7*2(7
41.04
*(*777
(77(7*0
27*8**3
7777*
Sheepshead
<001
<(777i
<(7771
(77*71
0 16
0 16
1**1777
197.51
*(771***6
0 16
1**1***7*6*3*
197.51
Shiners
*7*7*8*8*
i7*9
2*28
*2*3**1*
(7*2*7
1****7*7
1*78***4**2*
1*97(74
*7*1***1*
3**71***2*
1**5(77*77
7*9*7*5**5*
Shrimp (other)
2 3|
lis
(7771
27*771
*594*4*7
*7i**(7**.**(7**2*
2 31
2*7*4**8*
*59*7*84*
7777
Silver hake
1)1)2
(77)2
(77)2
*(**7*0*2*
(7771
*2**4**4
2(77*9*7
2*7*1*9
0*7*02
*7*4*6
2(77*9*5*
7*4*7*2*1
Silver perch
0 3|
0 3 3
(742
(7**4**4
*3*7**71
*77***4**1*
2^7(77*51
7*7w771*
37.73
*3 77*74
771737*972
7*7777
Silversides
oTTo
(771
(712
*(**7*1***5*
0 03
(7**1***6
6*7*8*5*
*1**0*7*7*2*
0 13
*727
*6*7*9*7*
77777
Skates
<001
<(777i
(7771
(77*71
(7771
(7771
77**771*
o7ol
*(**7(71
(77(71
(77771
(77(71
Skipjack herring
0 53
(754
0 63
0 72
(7771
(7771
*(7****2(7
(7.25
0 53
(*7**5*5
*0*7**83
0.77
Smallmouth bass
(77(76
(77)7
(77)8
0*77*9
77777
(77*8
20.03
*2*5.7*9
*(*7717**)
(7775
*777777*1
77*8**7
Smelts
1.18
1 30
1.48
1 S2
0.04
0.1.3
41.11
57.51
1.22
1.43
42.59
59.03
Spot
3 45
3.07
428
777*3
0 13
4*7***7*9
*9*2*7*5**7*
i*77ori77
7*5**8*
7*1**7*4**6
*929.8*1
7*777777
Spotted seatrout
(152
(77*54
(7777
(7*72
2****24
7(7*2
7*77*7*71
777*53
*2*7*7*6
3 56
1*7(71(77*58
7777
Spotted sucker
<001
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix C: Details of Regional IM&E
Table C-16: Baseline IM&E at All Regulated Facilities (Manufacturing and Generating) Nationally (million individuals per year), and
Reductions in IM&E for Option Scenarios Estimated for All Sources of Mortality
Species
Impingement
Entrainment
IM&E
P4
F
P2
B
P4
F
P2
B
P4
F
P2
B
Whitelish
0.03
0.03
0.04
0.04
<0.01
<0.01
0.36
0.47
0.03
0.04
0.39
0.51
Windowpane
<0.01
<0.01
<0.01
0.01
<0.01
8.88
762.82
996.32
<0.01
8.88
762.83
996.33
Winter flounder
0.05
0.05
0.06
0.07
0.05
28.79
2.494.01
3.253.45
0.09
28.84
2.494.07
3.253.52
Yellow perch
^ SI
i 99
4 Sy
5.15
0 71
3.77
419.01
540.94
4 S4
7.76
423.60
546.09
Total (all species)
419.91
441.30
511.87
568.56
399.82
1,693.86
335,447.57
497,316.28
819.74
2,135.17
335,959.44
497,884.85
Notes:
P4 = Proposal Option 4; F = Final Rule - Existing Units; P2 = Proposal Option 2; and B = Baseline
Source: U.S. EPA analysis for this report
May 2014
C-26
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix D: Discounting Benefits
Appendix D: Discounting Benefits
D.1 Introduction
Discounting refers to the economic conversion of future benefits and costs to present values, accounting
for the fact that individuals tend to value future outcomes less than comparable near-term outcomes.
Annualization refers to the conversion of a series of annual costs or benefits of differing amounts to an
equivalent annual series of constant costs or benefits. Discounting and annualization are important
techniques which allow the comparison of benefits and/or costs that occur in different time periods.
EPA's discounting and annualization methodology for the benefits analysis of the final rule and options
considered, included three steps. First, EPA developed a time profile of benefits to show when benefits
occur. Second, the Agency calculated the total discounted present value of the benefits as of the year
2013. Finally, EPA annualized the benefits of the final rule and other options considered, over a 51-year
time span. The following sections explain these steps in detail.
D.2 Timing of Benefits
To calculate the annualized value of the potential welfare gains, EPA first calculated the undiscounted
welfare gain from the expected annual regional reductions in IM&E under the final rule and other options
considered assuming all facilities have installed required technology. Then, EPA created a time profile of
benefits that takes into account the regulatory and biological time lags between the potential promulgation
of the final rule and each regulatory option considered, and the realization of benefits.
EPA assigned each facility a technology installation year which varies across facilities and regulatory
options based on facility characteristics and type of technology being installed. Facilities installing
impingement only technology have technology installation years ranging from 2018 to 2022, non-nuclear
electric generating facilities and manufacturing facilities installing towers have technology installation
years ranging from 2020 to 2024, and nuclear generating facilities installing towers have technology
installation years ranging from 2026 to 2030. EPA estimates that a small number of manufacturers could
be required to install both IM&E technology and towers. EPA assumed that these facilities would install
both technologies at the same time, during the 5-year window of 2021 through 2025. Compliance is
assumed to continue until the year 2059 for all facilities. See Chapter 3 of the EA report for more detail.
A biological time lag occurs between installation of technologies to reduce IM&E and realization of
commercial and recreational angling benefits because these fish may require several years to grow and
mature before commercial and recreational anglers can harvest them. For example, a larval fish spared
from entrainment (in effect, at age zero) may be caught by a recreational angler at age three. A three-year
time lag then arises between the installation of technologies to reduce IM&E and the realization of the
estimated recreational benefit. Likewise, if a one-year-old fish is spared from impingement and is then
harvested by a commercial fisherman at age two, there is a one-year lag between the installation of
technologies to reduce IM&E and the subsequent commercial fishery benefit. In general, there will be
relatively short time lags between implementation of technologies to reduce IM&E and the subsequent
timing of changes in catch for fish that tend to be harvested at young ages. In contrast, for long-lived fish
that tend to be caught at relatively older ages, there would be longer time lags and, hence, the effects of
discounting would be larger, resulting in lower present values.
July 8, 2014
D-1
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix D: Discounting Benefits
To model the biological time lags, EPA collected species-specific information on ages of fish at harvest to
estimate the average time required for a fish spared from IM&E, to reach a harvestable age. The estimated
time lags vary, depending on the life history of each fish species affected. EPA used this information,
along with information about the estimated age and species composition of IM&E in each study region, to
develop a benefits schedule for facilities in each region.93 EPA used these lags in analyses for both
existing and new units.
EPA assumes that once facilities have installed technology, commercial and recreational fishing benefits
from facilities in most regions (the California, North Atlantic, Mid-Atlantic, and South Atlantic regions)
increase over a seven-year period to a long-term, steady-state average. This average is equal to the
approximated per-facility benefit value discussed above, according to a numerical profile of <0.0, 0.1,
0.2, 0.8, 0.9, 0.95, 1.0>. This profile is the fraction of the steady-state benefit value (i.e., the percentage of
commercial and recreational fish spared from IM&E that reach a harvestable age) that is realized in each
of the first seven years following a facility installing technology.
For regions with a relatively high contribution of impingement to total IM&E (the Inland, Great Lakes,
and Gulf of Mexico regions), EPA used an adjusted profile of <0.1, 0.2, 0.8, 0.9, 0.95, 1.0> for
commercial and recreational fishing benefits. This adjusted profile reflects the fact that impinged fish are
usually larger and older than entrained fish, and thus benefits will be realized sooner in these three
regions. These profile values are approximations based on a review of the age-specific fishing mortality
rates that EPA used in the IM&E analysis and best professional judgment.94
In all regions, this fraction remains 1.0 until the final year of compliance, 2059. The commercial and
recreational fishing benefits profile declines at the end of the compliance period in the same fashion that it
increases after technology installation. This reflects the fact that the fish saved by technology would
survive and could still be harvested beyond the end of the compliance period. Specifically, at the end of
the compliance period, benefit values decline following a profile of <0.9, 0.8, 0.2, 0.1, 0.05, 0.0>, with
the last benefits occurring in 2064. Therefore, the benefits analysis encompasses a 51-year period from
rule promulgation and first incidence of compliance-related costs in 2014, until the final benefits are
realized in 2064. The number of years when benefits do not equal zero varies among the regulated
facilities, depending on the year that it installs technology.
EPA assumes no initial biological lag for nonuse benefits (including benefit transfer and preliminary
benefits based on the 316(b) SP survey) at the start of the compliance period because nonuse benefits are
not based on the harvest of fish spared from IM&E. EPA assumes that benefits begin accruing
immediately when a facility installs technology, and continue being generated in full until the year 2059.
The nonuse benefit transfer includes a linear decline in benefits starting at the end of the compliance
period following a profile of <1.0, 0.82, 0.62, 0.37, 0.20, 0.06, 0.0> with the last benefits occurring in
2064. This profile reflects NMFS estimates of age-specific and fisheries-related mortality. For the
analysis for the 316(b) SP survey, EPA assumes that benefits end in 2059, the final year of the
compliance period, and does not include a declining profile beyond this year. This is consistent with the
definition of the fish saved attribute which was used to generate preliminary benefits estimates based on
93 The benefits profile aggregated across all facilities in a region or nationwide was calculated using facility-level sample
weights. These facility-level sample weights were designed so that the weighted actual regional intake flow for the sample
facilities is the same as the estimated actual regional intake flow for the entire universe of facilities. These sample weights
are described in more detail in Appendix A.
94 EPA applied biological lags consistent with the Inland, Great Lakes, and Gulf Mexico regions when estimating commercial,
recreational, and T&E species benefits for new units because these regions account for the majority of national benefits for
these categories.
July 8, 2014
D-2
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix D: Discounting Benefits
the 316(b) SP survey. EPA does not include any lags in its analysis of benefits associated with changes in
GHG emissions.
D.3 Discounting and Annualization
Using the time profile of benefits discussed above, EPA discounted the total benefits generated in each
year of the analysis to 2013 using the following formula:
^ Benefits,
Present Value = V —— (D-l)
T (1 + >*)
where:
Benefits, = benefits in year t
r = discount rate (3 percent and 7 percent)
t = year in which benefits are incurred
After calculating the present value (PV) of these benefit streams, EPA calculated a constant annual
equivalent value (annualized value) using the annualization formula presented below, again using two
discount rates, 3 percent and 7 percent.95 Although the analysis period extends further, EPA annualized
benefits over the assumed period of compliance for regulated facilities. EPA followed this same
annualization concept and period of annualization in the cost analysis, although the time horizon for
calculating the present value is shorter than for benefits. Using the same annualization period for both
benefits and social costs allows EPA to compare constant annual equivalent values of benefits and costs
that have been calculated on a mathematically consistent basis. The annualization formula is as follows:
Annualized Benefit = PV of Benefit
where:
r*(l + r)"
(1 + r)" -1
(D-2)
r = discount rate (3 percent and 7 percent)
n = annualization period, 51 years for the benefits analysis
Table D-l presents a summary of the time profile of benefits discounted at the 3 percent and 7 percent
rates for the final rule and the regulatory options considered, on the national scale. The table also presents
the total and annualized values that are equivalent to this stream of benefits.
95 The three percent rate represents an estimate of the social rate of time preference.
July 8, 2014
D-3
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix D: Discounting Benefits
Table D-1: Time Profile of Disco
Discount Rates (2011$, millions
unted National Mean Benefits at Regulated Facilities by Regulatory Option using 3% and 7%
a
Year
Proposal Option 4
Final Rule - Existing Units
Proposal Option 2
Final Rule -New Units
Final Rule -Existing Units
and New Units
3%
7%
3%
7%
3%
7%
3%
7%
3%
7%
2013
$0,000
$0,000
$0,000
$0,000
$0,000
$0,000
$0,000
$0,000
$0,000
$0,000
2014
$0,000
$0,000
$0,000
$0,000
$0,000
$0,000
$0,004
$0,004
$0,004
$0,004
2015
$8447
$7,550
$8,147
$7,550
$0,000
$0,000
$0,008
$0,008
$8 1 56
$7,557
2016
$84 24
$7,246
$8,124
$7,246
$0,000
$0,000
$0,014
$0,012
$8.138
$7,259
2017
$8,095
$6,951
$8,095
$6,951
$0,000
$0,000
$0,008
$0,007
$8,103
$6,957
2018
-$1,517
-$1,254
-$1,334
-$1,103
$1 18.959
$98,325
$0,002
$0,002
-$1,332
-$1,101
2019
-$1,488
-$1,184
-$1,302
-$1,036
$121,271
$96,489
-$0,005
-$0,004
-$1,307
-$1,040
2020
-$0,670
-$0,513
-$0,158
-$0,121
$121,582
$93,120
-$0,011
-$0,009
-$0,170
-$0,130
2021
$0,542
$0,399
$1,236
$0.91 1
-$999,546
-$736,937
-$0,017
-$0,012
9
$0,899
2022
$5,572
$3,955
$6,772
$4,806
-$974,242
-$691,429
-$0,023
-$0,016
$6,749
$4,790
2023
>50
$29,958
$45,283
$30 936
-$l 079.21 1
-$737,294
-$0,029
-$0,020
$45 253
$30 916
2024
$49,786
$32,741
$51.603
$33,936
-$1,052,143
-$691,931
-$0,036
-$0,024
$51,567
$33,913
2025
$51,111
$32 356
$5 i 031
$3 3 571
-$1.031.582
-$653,048
-$0,043
-$0,027
$52,988
$33,544
2026
$51,040
$31,103
$52,955
$32,270
-$1,709,258
-$1,041,604
-$0,049
-$0,030
$52,905
$32,240
2027
$50,690
$29,735
$52,582
$30 845
-$l 689.775
-$991,236
-$0,056
-$0,033
$52,526
$30 812
2028
$49,896
$28,175
$51,737
$29,215
-$1,671,154
-$943,666
-$0,063
-$0,035
$51.675
$29,180
2029
$49,052
$26,663
$50,840
$27,635
-$l 651.425
-$897,664
-$0,069
-$0,038
$50 771
$27,597
2030
$48.215
$25,229
$49,951
$26,137
-$1,634,747
-$855,380
-$0,076
-$0,040
$49,875
$26,097
2031
$46.81 1
$23 578
$48,496
$24,427
3.475
-$575,955
-$0,079
-$0,040
$48417
$24,387
2032
$46,005
$22,306
$47,642
$23,099
-$1,131,655
-$548,693
-$0,086
-$0,042
$47,556
$23,058
20 V,
$15,959
$7,448
$17,547
$8,190
:>.74l
-$523,087
-$0,092
-$0,043
$17,455
$8,147
2034
$15,494
$6,961
$17,036
$7,654
-$1,109,610
-$498,532
-$0,098
-$0,044
$16,938
$7,610
2035
$15,043
$6,506
$16,540
$7.153
-$l 098.347
-$475,024
-$0,104
-$0,045
$ 16 436
$7,108
2036
$14,604
$6,080
$16,058
$6,685
-$1,086,843
-$452,477
-$0,110
-$0,046
$15,948
$6,640
2037
$14,179
$5,682
$15,591
$6,248
-$1,074,992
-$430,812
-$0.1 16
-$0,046
$15,475
$6,202
2038
'66
$5.31 1
$15,136
$5,839
-$l 062.923
-$410,051
-$0,122
-$0,047
$15,015
$5,792
2039
$13,365
$4,963
$14,696
$5,457
-$1,050,571
-$390.135
-$0,127
-$0,047
$14,568
$5,410
2040
$12,976
$4,639
$14,268
$5,100
-$1,038,033
-$371,068
-$0,133
-$0,047
15
$5,053
2041
$12,598
$4,335
$13,852
$4,767
-$1,025,492
-$352,881
-$0,138
-$0,047
$13 714
$4,719
2042
$12,231
$4,051
49
$4,455
-$1,012,802
-$335 486
-$0,143
-$0,047
$13 3(15
$4,407
2043
$1 1.875
$3,786
$13,057
$4,163
-$999,981
-$318.856
-$0,148
-$0,047
$12,909
$4,116
2044
$1 1.529
$3 5 i9
$12,677
$3,891
-$987,047
-$302,967
-$0,153
-$0,047
$12 524
$3,844
2045
$1 1.193
$3,307
$12,307
$3,636
-$974,019
-$287,791
-$0,158
-$0,047
$12,150
$3,590
2046
$10,867
$i 091
$1 1.949
$3,399
-$960,912
-$273,305
-$0,162
-$0,046
\1
$3,352
2047
$10,551
$2,889
$1 1.601
$3,176
-$947,742
-$259,482
-$0,167
-$0,046
$1 1.434
$3,131
July 8, 2014
D-4
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix D: Discounting Benefits
Table D-1: Time Profile of Disco
Discount Rates (2011$, millions
unted National Mean Benefits at Regulated Facilities by Regulatory Option using 3% and 7%
.a
Year
Proposal Option 4
Final Rule - Existing Units
Proposal Option 2
Final Rule -New Units
Final Rule -Existing Units
and New Units
3%
7%
3%
7%
3%
7%
3%
7%
3%
7%
2048
$10,243
$2,700
$11,263
$2,968
-$934,525
-$246,298
-$0,171
-$0,045
$11,092
$2,923
2049
$9,945
$2,523
$10,935
$2,774
-$921,273
-$233,729
-$0,175
-$0,044
$10,760
$2,730
2050
$9,655
$2,358
$10,616
$2,593
-$908,001
-$221,750
-$0,179
-$0,044
$10,438
$2,549
2051
$9,374
$2,204
$10,307
$2,423
-$894.91 1
-$210,383
-$0,182
-$0,043
$10,125
$2,380
2052
$9,101
$2,060
$10,007
$2,265
-$881,999
-$199,596
-$0,186
-$0,042
$9,821
$2,222
2053
$8,836
$1,925
$9,715
$2.1 16
-$869,263
-$189,360
-$0,190
-$0,041
$9,526
$2,075
2054
$8,579
$1,799
$9,433
$1,978
-$856,700
-$179,647
-$0,193
-$0,040
$9 240
$1,937
2055
$8,329
$1,681
$9.158
$1,849
-$844,308
-$170,430
-$0,196
-$0,040
$8,961
$1,809
2056
$8,086
$1,571
$8,891
$1,728
-$832,085
-$161,684
-$0,200
-$0,039
$8 6'>2
$1,689
2057
$7,851
$1,468
$8,632
$1,615
-$820,030
-$153,385
-$0,203
-$0,038
$8,429
$1,577
2058
$7,622
$1,372
$8,381
$1,509
-$808,141
-$145,510
-$0,206
-$0,037
$8 175
$1,472
2059
$7,400
$1,283
$8.137
$1,410
-$796,414
-$138,038
-$0,209
-$0,036
$7,928
$1,374
2060
$6,459
$1,078
$7,086
$1,182
$35,306
$5,891
$0,065
$0.01 1
$1,193
2061
$5,567
$0,894
$6,093
$0,979
$29.154
$4,682
$0,054
$0,009
$6,146
$0,987
2062
$1,384
$0,214
$1,586
$0,245
$13 337
$2 062
$0,027
$0,004
$1,613
$0,249
2063
$0,680
$0,101
$0,795
$0,118
$7,937
$1,181
$0,016
$0,002
$0,811
$0,121
2064
$0,330
$0,047
$0,387
$0,055
$3,942
$0,565
$0,008
$0,001
$0,395
$0,057
Total Present Valueb
-
$828,931
$402,860
$880,882
$424,898
-$41,234,429
-$16,994,287
-$4,694
-$1,492
$876,188
$423,406
Annualized Value0
-
$31,012
$27,219
$32,955
$28,708
-$1,542,641
-$1,148,205
-$0,176
-$0,101
$32,779
$28,607
a Values presented here are based on 3 percent average SCC values.
b The total present value is equal to the sum of the values of the benefits realized in all years of the analysis, discounted to 2013.
c The annualized value represents the total present value of the benefits of the rule, distributed over a 51-year period.
Source: U.S. EPA analysis for this report.
July 8, 2014
D-5
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix E: List of T&E Species Overlapping CWIS
Appendix E: List of T&E Species Overlapping CWIS
Table E-1: List of 99 T&E Species Overlapping One or More Regulated CWIS
Latin Name
Common Name
Acipenser brevirostrum
Shortnose Sturgeon
Acipenser medirostris
Green Sturgeon
Acipenser oxvrinchus desotoi
Gulf Sturgeon
Acipenser oxyrinchus oxvrinchus
Atlantic Sturgeon
Alasmidonta helerodon
I )w arf Wedgemussel
Amblema neislerii
Fat Threeridge
Amblyopsis rosae
Ozark Cavefish
Arkansia wheeleri
Ouachita Rock l'ocketbook
Alheaniia anthonyi
Anthony's Riversnail
('ampeloma decampi
Slender Cainpeloma
Caretta caretta
Loggerhead Sea Turtle
Chelonia mydas
Green Sea Turtle
('onus Paulus
Pygmy Sculpin
('yprinella caenilea
Blue Shiner
('vprogenia stegaria
l'anshell
Dermochelys coriacea
Leatherback Sea Turtle
Dromus dromas
I )romedary Pearly'mussel
1 illiplio chipolaensis
Chipola Slabshell
Ulliptio spinosa
Altamaha Spinymussel
Elliptio steinstansana
Tar River Spinymussel
Elliptoideus sloatianus
Purple Bankclimber
Epioblasma brevidens
Cumberlandian Combshell
Epioblasma capsaefomris
Oyster Mussel
Epioblasma florentina florentina
Yellow (Pearlymussel) Blossom
1 ipioblasma florentina walkeri
Ian Ril'lleshell
Epioblasma obliijuata obliijuala
Catspaw (Purple Cat's Paw Pearlymussel)
Epioblasma obliijuata perobliijua
White (Pearlymussel) Catspaw
Epioblasma torulosa gubeniaciiliim
Green (Pearlymussel) Blossom
Epioblasma torulosa rangiana
Northern Riffleshell
Epioblasma torulosa torulosa
Tubercled (Pearlymussel) Blossom
1 ipioblasma turgidula
Turgid (Pearlymussel) Blossom
Eretmochelys imbricata
I lawksbill Sea Turtle
Etheostoma etowahae
Etowah Darter
Etheosloma percnurum
Duskytail Darter
Etheostoma scotti
Cherokee I )arter
Etheostoma wapiti
Boulder Darter
Fusconaia cor
Shiny Pigtoe
I' usconaia cuneolus
l'inerayed Pigtoe
(iasterosteus aculeatus uilliamsoni
IJnarmored ITireespine Stickleback
Gila bicolor mohavensis
Mohave Tui Chub
Hemistena lata
Cracking Pearlymussel
Hypomesus transpacijicus
Delta Smelt
Lampsilis abnipta
Pink (Pearlymussel) Mucket
July 8, 2014
E-1
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix E: List of T&E Species Overlapping CWIS
Table E-1: List of 99 T&E Species Overlapping One or More Regulated CWIS
Latin Name
Common Name
Lampsilis higginsii
Higgins Eye (Pearlymussel)
Lampsilis powellii
Arkansas Fatmucket
Lampsilis subangiilata
Shinyrayed Pocketbook
Lampsilis virescens
Alabama Lampmussel
1.epidochelvs kempii
Kemp's Ridley Sea Turtle
1.epidochelvs olivacea
Olive Ridley Sea Turtle
Leptodea leptodon
Scaleshell Mussel
Leptoxis ampla
Round Rocksnail
l.eploxis foreman
Interrupted (Georgia) Rocksnail
Leptoxis plicala
Plicate Rocksnail
Leptoxis taeniata
Painted Rocksnail
Margaritifera hembeli
Louisiana Pearlshell
A tedionidus penicillatus
Gulf Moccasinshell
A tedionidus simpsonianus
()chlockonee Moixasinshell
Sotropis alhizonatus
Pale/one Shiner
Notunis placidus
Neosho Madtom
Xolunts slanauli
Pygmy Madtom
Ohovaria relusa
Ring Pink (Mussel)
Oncorhynchus clarki slomias
Greenback Cutthroat
Oncorhynchus keta
Chum Salmon
Oncorhynchus kisutch
Coho Salmon
Oncorhynchus mvkiss
Steelhead Trout
Oncorhynchus ishauylscha
Chinook Salmon
Oregonichthys crameri
Oregon Chub
Pegias fabida
Littlewing Pearlymussel
Percina rex
Roanoke I .ogperch
Percina lanasi
Snail Darter
Phoxinus cumberlandensis
Blackside Dace
Plethobasus cicatricosus
White (Pearlymussel) Wartyback
Plelhobasus cooperianus
Orangeibot (Pearlymussel) Pimpleback
Pleurobema clava
Clubshell
Pleurobema collina
James Spinymussel
Pleurobema curtum
Black Clubshell
Pleurobema hanleyianum
Georgia Pigtoe
Pleurobema marshal!i
1 Tat Pigtoe
Pleurobema plenum
Rough Pigtoe
Pleurobema pyrifotme
Oval Pigtoe
Pleurobema taitianum
Heavy Pigtoe
Pleurocera foremani
Rough I lornsnail
Polamilus capax
l;at Pocketbook
Potamilus inflatus
Alabama (Inflated) Heelsplitter
Ptychocheilus lucius
Colorado Pikeminnow (Squawfish)
Ouadrula cylindrica slrigillala
Rough Rabbitslbot
Ouadrula fragosa
Winged Mapleleal'
Ouadntla intermedia
Cumberland (Pearlymussel) Monkeyface
Ouadntla sparsa
Appalachian (Pearlymussel) Monkeyface
Ouadntla stapes
Stirrapshell
July 8, 2014
E-2
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix E: List of T&E Species Overlapping CWIS
Table E-1: List of 99 T&E Species Overlapping One or More Regulated CWIS
Latin Name
Common Name
Salmo salar
Atlantic Salmon
Salvelimis confluentus
Bull Trout
Scaphirhvnchiis albus
Pallid Sturgeon
Scaphirhvnchiis suttkusi
Alabama Sturgeon
Speoplalyrhinus poulsoni
Alabama Cavelish
Toxolasma cylindrellus
Pale (Pearlvmussel) I.illiput
Villosa perpurpurea
Purple Bean
Villosa trabalis
Cumberland (Pearlymussel) Bean
Xyrauchen texamis
Razorback Sucker
Source: U.S. EPA analysis for this report
July 8, 2014
E-3
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix F: Methods for T&E Species Benefits
Appendix F: Detailed Methodologies for Estimating Benefits to
Threatened and Endangered Species
F.1 IM&E of Sea Turtles
Six species of sea turtles are found in waters of the United States: Green, Hawksbill, Kemp's Ridley,
Leatherback, Loggerhead, and Olive Ridley sea turtles. All have extensive ranges, migrate long distances
during their lifetime, and are listed as either T&E under the ESA. Because of these large ranges, there is
substantial overlap between sea turtle habitat and CWIS for regulated facilities. Moreover, because
individuals of all ages and sizes are susceptible to impingement and entrainment (Norem 2005), there are
more than 730 locations of potential interactions between species ranges and CWIS that may result in the
injury or death of these T&E species.
Power plants are known to entrain and impinge all species of sea turtles, with individual incidences of
mortality reported from California, Texas, Florida, South Carolina, North Carolina, and New Jersey
(Plotkin 1995). Although the cumulative impact of this mortality is unclear, it may be relatively small
compared to fishing mortality. Although quantitative reports are available from a few power stations
(Table F-l), high-quality data is available from only one source, the St. Lucie Nuclear Power Plant, at
Hutchinson Island, Florida, where annual capture rates range from 350 to 1,000 turtles. Although
estimated mortality rates due to entrainment are < 3 percent, approximately 85 percent of entrained
organisms show evidence of injury as a result of entrainment (Norem 2005). As such, true mortality rates
from CWIS may be higher than reported, particularly for individuals who are recaptured repeatedly (37
percent of Green and 13 percent of Loggerhead sea turtles entrained between May and December 2000
were recaptured individuals) (Norem 2005).
In addition to research sponsored by the National Science Foundation, federal and state governmental
spending on sea turtles under the ESA totaled $33.8 million in FY2008 (USFWS 2009). Moreover, the
number of volunteer organizations dedicated to sea turtle recovery (Table F-2) provides further evidence
of the high nonuse values placed upon the survival of these animals by the public.
July 8, 2014
F-1
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix F: Methods forT&E Species Benefits
Table F-1: Reported Numbers of Sea Turtle Entrainment Incidences
Facility(s)
Species
Takes
Dates
Takes / yr
Source
Non-lethal
Lethal
Non-lethal
Lethal
Crystal River, FL
Kemp's Ridley, Loggerhead
40
5
1998
40
5
TEWG (2000)
Brunswick, NC
Loggerhead, Kemp's Ridley, Green
50
11
2000
50
11
NMFS (2001)
Oyster Creek, N.T; Salem, N.T;
and Hope, N.T
Loggerhead
40
8
1999
40
8
Kemp's Ridley
7
3
1999
7
3
NMFS (2001)
Green
8
2
1999
8
2
Salem, N.T
Loggerhead. Kemp's Ridley. Green
23
2
1991
23
2
Eggers (2001)
Salem, N.T
Loggerhead
18
8
1980-1988
2.25
1
Eggers (1989)
Salem. N.I
Kemp's Ridley
6
6
1980-1988
0.75
0.75
St. Lucie. FL
I .oggerhead
6313
169
1976-2005
225.5
6
NMFS (2009)
San Diego, Edison
Olive Ridley
OR
OR
QR
QR
QR
(NMFS and IJSFWS
1998b)
San Diego, Encina, Edison
Green
QR
QR
QR
QR
QR
(NMFS and USFWS
1998a)
St. Lucie, FL
Leatherback
20
1976-1998
0.95
Bresette et al (1998)
St. Lucie. FL
I lawksbill
19
1976-1998
0.90
Bresette et al (1998)
St. Lucie. FL
Green
2297
1976-1998
109.38
Ernest et al (1988)
St. Lucie. FL
Kemp's Ridley
34
1976-1998
1.62
Bresette et al (1998)
All US Waters
Loggerhead
-
5-50
Annual
Estimate
-
5-50
Plotkin (1995)
Notes:
QR = qualitative resports only
= value not available
July 8, 2014
F-2
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix F: Methods for T&E Species Benefits
Table F-2: Subset of Nongovernmental Organizations Based in the United States Dedicated to
Sea Turtle Research and Conservation
Name
Group Type
Web Address
Amelia Island Sea Turtle Watch, Inc.
Volunteer
www.ameliaislandseaturtlewatch.com/
Archie Carr Center for Sea Turtle Research
Academic
accstr.ufl.edu/
Bald Head Island Conservancy
Volunteer
www. bhic. org/STPP. shtml
California Turtle & Tortoise Club
Volunteer
www. tortoise, org/
Caribbean Conservation Corporation
Nonprofit
w w w helpingseaturtles.org/
Chelonian Research Foundation
Academic
www.chelonian.org/
Clearwater Marine Aquarium
Nonprofit/V olunteer
www.seewinter.com/what-we-do/nesting
Coastal Research and Education Society of
Long Island, Inc., New York State Sea
Nonprofit/V olunteer
www. cresli. org/cresli/turtles/turtpage.html
Turtle Program
Conservation International Sea Turtle
Flagship Program
Nonprofit
www. conservation, org/disco ver/centers_programs
/sea_turtles/Pages/ seaturtles. aspx
Farthwatch
N onpro ii t/l xoto un sm
w w w. earth w atch.org
Gulf Coast Turtle and Tortoise Society
Volunteer
www.gctts.org/
Hawksbill Sea Turtle Recovery Project
Go vernment/V olunteer
www.fpir.noaa.gov/PRD/prd_volunteer_opps.html
Malama na Honu
N onpro ii t/Vol unteer
malamanahonu.org/
Marine Turtle Specialist Group
Academic
www.iucn-mtsg.org/
Maryland Marine Mammal and Sea Turtle
Go vernment/V olunteer
w w w .dnr.state.md.us/!isheries/o\ford/research/fw
Stranding Network
h/ strandingprogram. html
National Aquarium in Baltimore, Marine
Animal Rescue Program
Nonprofit/V olunteer
www. aqua. org/oceanhealth_marp.html
National Save the Sea Turtle Foundation
Nonprofit
savetheseaturtle. org/
Network for I Endangered Seaturtles
Volunteer
www. nestonline. org/
Ocean Conservancy
Nonprofit
www. oceanconservancy .org/
Riverhead Foundation for Marine Research
and Preservation
Nonprofit/V olunteer
www.riverheadfoundation.org/index.asp
Sanibel-Captiva Conservation Foundation
N onpro ii t/V ol unteer
www.sccf.org/
Sea Turtle Restoration Project
Nonprofit
www. seaturtles. org
Share the Beach, Sea Turtle Volunteering
Program
Volunteer
www.alabamaseaturtles.com/
The Featherback Trust
Nonprofit
leatherback.org/
The Turtle Foundation
Nonprofit
w w w .turtle-lbundation.org
Source: U.S. EPA analysis for this report
F.2 Application of Whitehead's (1993) Benefit Transfer Approach for Estimating
WTP for T&E Sea Turtle Species
EPA identified a study that used a stated preference valuation approach to estimate the total economic
value (i.e. use and nonuse values) of a management program designed to reduce the risk of extinction for
loggerhead sea turtles (Whitehead 1993). The mail survey asked North Carolina households whether they
were willing to pay a bid amount for a management program which reduces the probability that
loggerhead sea turtles would be extinct in 25 years. Within the model framework, the baseline extinction
risk and change from the management program are expressed in terms of a supply probability. Supply
probability reflects the probability that "the wildlife resource will continue to exist so it can be enjoyed by
recreational users and nonusers (p. 121)" (Whitehead 1993).
July 8, 2014
F-3
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix F: Methods for T&E Species Benefits
The household value is expressed as the option price, or WTP to pay under conditions of future supply
and demand uncertainty. The option price is estimated by solving for the dollar amount which would
make the respondent indifferent to utility with and without the management program. The function used
to estimate the option price (Model B from Whitehead (1993)) is:
OP (1991$) = 1.272 [p2(r2-q2)] / 0.029 Equation F-l
Variable definitions for the parameters in the function are described in Table F-3.
EPA used Whitehead (1993) to assess the range of benefits potentially resulting from the final rule and
regulatory options considered. EPA reviewed available data sources and biological models to assess the
potential impact of baseline losses and reductions on sea turtle supply probability (r2-q2). While analyses
of sea turtle extinction risk have been conducted (e.g., Conant et al. 2009), EPA was unable to identify an
existing model or analysis which could be readily used in conjunction with available mortality data to
estimate the marginal impacts of CWIS on sea turtle extinction risk.
Estimates from the literature suggest that IM&E is of relatively low importance compared to other
human-induced mortality such as shrimp trawling and other fisheries (Plotkin 1995). However, Crouse et
al. (1987) found that mortality at juvenile and subadult life stages can have a substantial effect on
population growth, suggesting that small changes in survival at these age classes could have a measurable
impact on extinction risk. As such, the marginal change in supply probability of loggerhead sea turtles
due to the final rule and proposed options is unlikely to be lower than 0.01 (i.e., a 1 percent decrease in
the probability of extinction over 25 years).
EPA specified a marginal improvement of 0.01 within Whitehead's (1993) modeling framework to bound
household values for changes in extinction risk for loggerhead sea turtles as a consequence of the final
rule. Although this assessment is not based on formal quantitative analysis of extinction risk, EPA intends
it to illustrate the range of potential benefits associated with reductions in sea turtle losses. Using the
author's mean values for demand probability (p2) and supply probability without the management
program (q2) (Table F-3), EPA calculated an annual household value of $0.37 (2011$). Estimates were
converted to 2011 dollars using the consumer price index (USBLS 2011).
July 8, 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule Appendix F: Methods for T&E Species Benefits
Table F-3: Variable Descriptions and Values used for EPA's Benefits Transfer Application
Variable
Description
Value Used in EPA's
Application
OP
Option Price - the amount a household would be willing to pay
under conditions of supply and demand uncertainty.
Estimated by the model
P2
Demand Probability - for wildlife users, demand uncertainty
occurs when it is indeterminate whether recreational use of the
wildlife resource will be pursued because of uncertain travel
costs, income, and tastes. For nonusers, demand uncertainty
depends on uncertain tastes.
0.51
q2a
Supply Probability without the Management Program -
probability that the resource will continue to exist in 25 years
without implementation of the management program.
0.43
r2
Supply Probability with the Management Program - probability
that the resource will continue to exist in 25 years with
implementation of the management program.
0.44
(r2-q2)b
Marginal increase in supply probability resulting from the
management program.
0.01
a The model results are linear for marginal improvements in supply probability.
b EPA notes that a marginal change in supply probability of 0.01 is substantially less than changes used by Whitehead (1993) for model
estimation. Whitehead (1993) estimated an annual household willingness to pay value of $10.98 (1991$) for a mean increase in supply
probability of 0.47 in 25 years.
Sources: Whitehead (1993), U.S. EPA analysis for this report
July 8, 2014
F-5
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix G: Consumer Surplus
Appendix G: Estimation of Price Changes for Consumer Surplus
G.1 Introduction
EPA considered estimating consumer surplus values associated with reductions in IM&E, but found that
dockside prices would change too little to produce measurable shifts in consumer surplus. This Appendix
presents the details of this analysis and the estimated price changes by region and species.
G.2 Methodology and Results
To properly estimate price changes, it is necessary to consider the contribution of the species to the
overall market. Because individual demand functions incorporating substitutes are not available for most
species, EPA estimated price changes in the following way. . The Agency estimated the total baseline
harvest for relevant species (commercial species of similar types to those affected by IM&E) using
National Marine Fisheries Service (NMFS) landings data from 2007 to 2011(NMFS 2012) in three
categories: finfish, shrimp, and crabs.96' The totals for finfish were summed for the East Coast and Gulf,
and for the West Coast, while totals for shrimp and crabs were summed across all coastal regions.97 EPA
summed estimated harvest increases from the elimination of baseline IM&E according to the same
species and regional categories. Next, EPA calculated the percentage change in harvest if baseline IM&E
were to be eliminated, by dividing the total increase in harvest from elimination of baseline IM&E, by the
total harvest. EPA then estimated the percentage change in price for each region and species by dividing
the percentage change in harvest by the elasticity for the species group (finfish, shrimp, or crabs).
This last step requires estimates of elasticities. The price elasticity of demand for fish measures the
percentage change in demand in response to a percentage change in fish price. Thus, the inverse elasticity,
or price flexibility, measures the percentage change in price for a given percentage change in quantity.
EPA's review of the economics literature identified several potentially relevant studies, including Asche,
Bjorndal, and Gordon (2005); Capps and Lambrgets (1991); Cheng and Capps (1988); Tsoa, Schrank, and
Roy (1982); Davis, Yen, and Hwan-Lin (2007); and Lin, Richards, and Terry (1988).
Table G-l presents the own-price elasticities identified in the literature review for those commercial
species where IM&E was estimated. Because elasticities can vary by species, the Agency grouped the
own-price elasticities found in the literature review into three categories: (1) saltwater fish, (2) shrimp,
and (3) crabs. The median elasticities within each of these groups, presented in the fourth column of
Table G-l, are the elasticities used in this analysis. Table G-l shows that there is a substantial amount of
variation in the elasticity estimates, so by selecting the median elasticity rather than taking an average, the
influence of the more extreme estimates is reduced.98
90 For example, offshore species such as tuna and swordfish, baitfish species, and shellfish were not included.
97 Harvests for Alaska and Hawaii were not included in the totals.
98 Only two studies were available for crabs, so EPA used the mean elasticity for crabs. The Agency did not distinguish
between finfish elasticities for the East and West Coast, because some sources provide elasticities based on models that
include both regions.
July 8, 2014
G-1
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix G: Consumer Surplus
Table G-1: Own-Price Elasticity Estimates from Literature Review
Species
Group
Species
Study
Elasticity
Median Species
Group Elasticity
Study
Notes
Saltwater
Cod
-0.54
-1.89
Cheng and Capps (1988)
Saltwater
Cod
-3.15
-1.89
Bell (1986) as cited in Asche,
Bjomdal and Gordon (2005)
Saltwater
Cod(Blocks)
-3.16
-1.89
Mazany, Roy and Schrank (1996) as
cited in Asche, Bjomdal and Gordon
(2005)
Saltwater
Cod(Fillets)
-0.46
-1.89
Tsoa, Schrank and Roy (1982)
Long run estimate.
Saltwater
Cod(Fillets)
-1.89
-1.89
Asche, Bjomdal and Gordon (2005)
Saltwater
Flounder
-1.63
-1.89
Mazany, Roy and Schrank (1996) as
cited in Asche, Bjomdal and Gordon
(2005)
Saltwater
Flounder/Sole
-0.45
-1.89
Cheng and Capps (1988)
Saltwater
Flounder/Sole
-1.04
-1.89
'I'soa. Schrank and Roy (1982)
I ,ong run estimate.
Saltwater
Halibut
-5.56
-1.89
Lin, Richards and Terry (1988) as
cited in Asche, Bjomdal and Gordon
(2005)
Saltwater
Perch
-0.70
-1.89
Cheng and Capps (1988)
Saltwater
Perch
-3.09
-1.89
Capps and I .ambrgets (1991)
Saltwater
Perch
-0.60
-1.89
I'soa. Schrank and Roy (1982 1
I ,ong run estimate.
Saltwater
Perch
-215.00
-1.89
Bell (1986) as cited in Asche,
Bjomdal and Gordon (2005)
Saltwater
Rockfish
-3.55
-1.89
Capps and I .ambrgets (1991)
Saltwater
Whitetish
-5.24
-1.89
Capps and I .ambrgets (1991)
Shrimp
Shrimp
-0.70
-0.63
Cheng and Capps (1988)
Shrimp
Shrimp
-1.08
-0.63
Davis. Yen and I Iwan-I.in (2007)
I ,ow income estimate.
Shrimp
Shrimp
-0.30
-0.63
Davis, Yen and Hwan-Lin (2007)
High income estimate.
Shrimp
Shrimp
-2.84
-0.63
Capps and Lambrgets (1991)
Shrimp
Shrimp
-0.63
-0.63
Doll (1972) as cited in Cheng and
Capps (1988)
Shrimp
Shrimp
0.28
-0.63
Cleary (1969) as cited in Cheng and
Capps (1988)
Shrimp
Shrimp
-0.57
-0.63
Sun (1995) as cited in Asche,
Bjomdal and Gordon (2005)
Crabs
Crabs
-0.77
-1.31
Cheng and Capps (1988)
Crabs
Crabs
-1.84
-1.31
Capps and I .ambrgets (1991)
Table G-2 shows the results of the calculations of percentage changes in price. EPA applied these
percentage changes to the baseline prices to develop estimates of prices for the increased harvests that
would result from eliminating baseline IM&E. For example, the table shows that a 0.39 percent change in
total harvest in California is predicted to lead to a 0.21 percent change in finfish prices. These prices
changes translate into very small changes (generally one to two cents) in ex-vessel prices per pound for
the species affected by IM&E. Tables G-3 to G-7 show the projected prices after eliminating baseline
IM&E.
EPA did not include estimates of changes in consumer surplus for commercial species. Prices must
change in order for consumer surplus to change. Most species of fish have numerous close substitutes.
The literature suggests that when there are plentiful substitute fish products, lots of fishers, and a strong
ex-vessel market, individual fishers are generally price takers. Although there are exceptions, fisheries
economics studies often make these assumptions in analyzing regional effects from harvest changes (e.g.,
Herrmann 1996; Thunberg et al. 1995) and international markets (e.g., Clarke et al. 1992) . Consumer
July 8, 2014
G-2
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix G: Consumer Surplus
surplus measures that have been estimated by NMFS for past environmental impact statements tend to be
quite low. NMFS fisheries analyses incorporate price changes for large changes in regional or national
harvest, such as stock rebuilding. However, for small changes in landings, such as those expected under
the final rule, it is standard to assume that prices are fixed.99
Table G-2: Estimated Average Percentage Change in Ex-Vessel Price by Region and
Species Group from the Elimination of Baseline IM&E
Region
Species
Group
Increase in Harvest
from Elimination of
Baseline IM&Ea
(lbs)
Total Average
Annual Harvest3
Percentage
Change in
Harvest
Elasticity
Percentage
Change in
Priceb
California
Finfish
1,920,625
489,705,990
0.39%
-1.89
-0.21%
East Coast
and Gulf
Finfish
12,548,060
265,617,830
4.72%
-1.89
-2.50%
All Regions
Crabs
1,373,553
258,973,619
0.53%
-1.31
-0.40%
All Regions
Shrimp
369,750
279,365,691
0.13%
-0.63
-0.21%
a Sum of total landings for all relevant species.
b Percentage changes in price reflect the average across all species within the species group and region.
Sources: U.S. EPA analysis for this report, NMFS (2012a)
Table G-3: Estimated Price Changes for the California Region
Species
Average Annual
Harvest 2007-
2011 (thousand
lbs)
Price Per
Pound
(2011$)
Increase in Harvest
from Elimination of
Baseline IM&E
(thousand lbs)"
Percentage
Change in
Price
New Price
Per Pound
(2011$)
American Shad
57.9
$1.07
0.0
-0.21%
$1.07
Anchovies
13,637.3
$0.06
0.9
-0.21%
$0.06
Cabe/on
53.7
$5.89
76.1
-0.21%
$5.88
California I lalibut
495.5
$4 73
176.9
-0.21%
$4.72
California Scorpionlish
7.9
$3 83
0.0
-0.21%
$^ 82
Commercial Crabs
1,386.3
$1.37
2.2
-0.40%
$1.36
Commercial Shrimp
4,272.1
$1.40
0.0
-0.21%
$1.39
I )rums and Croakers
53.8
$0.56
6.9
-0.21%
$0.55
I )un»eness Crabs
15,495.5
$2 31
6.1
-0.40%
$2.30
Flounders
381.3
$0.42
14.2
-0.21%
$0.42
Other
47,410.9
$1.16
6.6
-0.21%
$1.16
Rocklishes
2,741.3
$1.25
1.634.5
-0.21%
$1.25
Sculpins
3.8
$3 53
3.7
-0.21%
$3.52
Sea Basses
6.4
$2.76
0.0
-0.21%
$2.75
Smelts
323.0
$0.41
0.2
-0.21%
$0.41
Surfperches
17.5
$1.90
0.7
-0.21%
$1.90
Total
86,344.2
1,928.9
a Values of 0.0 for increased harvest from elimination of baseline IM&E may include increases less than 0.1 thousand lbs.
Sources: U.S. EPA analysis for this report, NMFS (2012c)
99 Personal communications with NMFS economists Cindy Thomson (2008), Eric Thimberg (2008), Steve Freese (2008), and
Sabrina Lovell (2013).
July 8, 2014
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix G: Consumer Surplus
Table G-4: Estimated Price Changes for the North Atlantic Region
Species
Average Annual
Harvest 2007-
2011 (thousand
lbs)
Price Per
Pound
(2011$)
Increase in Harvest
from Elimination of
Baseline IM&E
(thousand lbs)"
Percentage
Change in
Price
New Price
Per Pound
(2011$)
American Shad
30.3
$0.86
0.0
-2.50%
$0.84
Atlantic Cod
18,152.5
$1.64
2.3
-2.50%
$1.60
Atlantic I lerrmg
168,023.6
$0.13
17.4
-2.50%
$0.13
Atlantic Menhaden
7,346.1
$0.12
4.8
-2.50%
$0.12
Bluefish
1,038.3
$0.57
0.0
-2.50%
$0.56
Butterfish
784.5
$0.68
0.2
-2.50%
$0.66
Commercial Crabs
16,083.4
$0.62
0.3
-2.50%
$0.61
Flounders
16,026.1
$1.95
373.1
-2.50%
$1.91
Mackerels
29.268.6
$0.17
2.2
-0.40%
$0.16
Other
332.156.1
$0.42
3.8
-2.50%
$0.41
Pollock
16.818.4
$0.64
0.0
-2.50%
$0.62
Red I lake
926.7
$0 39
0.0
-2.50%
$0 38
Sculpins
1.0
$0.11
3.2
-2.50%
$0.11
Scup
5,362.2
$0.75
0.1
-2.50%
$0.73
Searobin
53.3
$0.17
0.1
-2.50%
$0.16
Silver I lake
11,108.1
$0.59
0.6
-2.50%
$0.58
Skate Species
35,198.9
$0.22
0.5
-2.50%
$0.21
Tautog
142.6
$2 43
4.7
-2.50%
$2 37
Weaklish
1 I.I
$1.67
0.2
-2.50%
$1.63
White Perch
4.8
$1.20
0.0
-2.50%
$1.17
Total
658,536.4
413.6
a Values of 0.0 for increased harvest from elimination of baseline IM&E may include increases less than 0.1 thousand lbs.
Sources: U.S. EPA analysis for this report, NMFS (2012c)
July 8, 2014
G-4
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix G: Consumer Surplus
Table G-5: Estimated Price Changes for the Mid-Atlantic Region
Species
Average Annual
Harvest 2007-
2011 (thousand
lbs)
Price Per
Pound
(2011$)
Increase in Harvest
from Elimination of
Baseline IM&E
(thousand lbs)"
Percentage
Change in
Price
New Price
Per Pound
(2011$)
Alewilc
343.8
$0.29
0.3
-2.50%
$0.28
American Shad
57.5
$0.83
0.9
-2.50%
$0.81
Atlantic I lerrmg
6.658.6
$0.12
0.1
-2.50%
$0.1 1
Atlantic Menhaden
452,353.9
$0.07
3,700.8
-2.50%
$0.07
Black Drum
89.8
$2.20
0.2
-2.50%
$2.14
Blue Crab
85.836.4
$1.11
640.9
-0.40%
$1.10
Bluelish
2.996.3
$0.49
0.1
-2.50%
$0.48
Butterfish
494.1
$0.84
0.0
-2.50%
$0.82
Commercial Crabs
2.490.9
$0.54
0.3
-0.40%
$0.54
I )rums and Croakers
10.159.5
$0.64
960.3
-2.50%
$0.63
Flounders
6.308.5
$2.08
6.1
-2.50%
$2.03
()ther
602.868.9
$0 31
820.1
-2.50%
$0 M)
Red Hake
360.0
$0.46
0.6
-2.50%
$0.44
Scup
4,121.8
$0.81
0.0
-2.50%
$0.79
Searobin
37.3
$0.21
0.0
-2.50%
$0.21
Silver I lake
4,877.3
$0.64
0.1
-2.50%
$0.63
Spot
3,478.4
$0.85
1,064.6
-2.50%
$0.82
Striped Bass
5.609.6
$2.12
55.9
-2.50%
$2.07
Striped Mullet
26.2
$0.45
0.2
-2.50%
$0.44
Tautog
135.3
$2.98
0.0
-2.50%
$2.90
Weakfish
267.4
$1.32
503.7
-2.50%
$1.29
White Perch
1,588.5
$0.79
2.6
-2.50%
$0.77
Total
1,191,159.9
7,757.9
a Values of 0.0 for increased harvest from elimination of baseline IM&E may include increases less than 0.1 thousand lbs.
Sources: U.S. EPA analysis for this report, NMFS (2012c)
Table G-6: Estimated Price Changes for the South Atlantic Region
Species
Average Annual
Harvest 2007-
2011 (thousand
lbs)
Price Per
Pound
(2011$)
Increase in Harvest
from Elimination of
Baseline IM&E
(thousand lbs)"
Percentage
Change in
Price
New Price
Per Pound
(2011$)
Atlantic Menhaden
1,828.1
$0.12
42.9
-2.50%
$0.11
Blue Crab
39,786.5
$0.95
3.2
-0.40%
$0.95
Commercial Crabs
583.7
$1.65
0.0
-0.40%
$1.65
1 )rums and Croakers
6,347.6
$0.51
12.5
-2.50%
$0.50
()ther
94,277.5
$1.28
2.3
-2.50%
$1.25
Spot
854.3
$0.70
16.1
-2.50%
$0.68
Stone Crab
145.2
$4.01
0.4
-0.40%
$^ 99
Weaklish
144.6
$1.02
0.6
-2.50%
$0.99
Total
143,967.5
78.1
a Values of 0.0 for increased harvest from elimination of baseline IM&E may include increases less than 0.1 thousand lbs.
Sources: U.S. EPA analysis for this report, NMFS (2012c)
July 8, 2014
G-5
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix G: Consumer Surplus
Table G-7: Estimated Price Changes for the Gulf of Mexico Region
Species
Average Annual
Harvest 2007-
2011 (thousand
lbs)
Price Per
Pound
(2011$)
Increase in Harvest
from Elimination of
Baseline IM&E
(thousand lbs)"
Percentage
Change in
Price
New Price
Per Pound
(2011$)
Atlantic Menhaden
1.088.022.8
$0.07
1.173.2
-2.50%
$0.07
I Mack Drum
4.621.9
SO 83
1.945.0
-2.50%
$0.81
Blue Crab
53.055.9
$0.87
244.0
-0.40%
$0.87
Drums and Croakers
111.8
$5.19
47.8
-2.50%
$5.06
Leatheijacket
61.0
$1.51
107.1
-2.50%
$1.47
Mackerels
3.898.1
$1.16
0.4
-2.50%
$1.13
Other
1.384.185.9
$0
281.9
-2.50%
$0.38
Pink Shrimp
6.973.0
$2.00
369.7
-0.21%
$2.00
Sea Basses
179.4
$0.97
0.0
-2.50%
$0.95
Sheepshead
1,393.0
$0.44
0.0
-2.50%
$0.43
Spot
16.9
$0.51
46.3
-2.50%
$0.50
Stone Crab
5,587.9
$4.13
474.4
-0.40%
$4.11
Striped Mullet
10,800.3
$0.64
1,343.6
-2.50%
$0.62
Total
2,558,908.0
6,033.5
a Values of 0.0 for increased harvest from elimination of baseline IM&E may include increases less than 0.1 thousand lbs.
Sources: U.S. EPA analysis for this report, NMFS (2012c)
July 8, 2014
G-6
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Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix H: Details of Commercial Fishing Benefits
Appendix H: Details of Regional Commercial Fishing Benefits
Table H-1: Commercial Fishing Benefits from Eliminating or Reducing Baseline IM&E at Regulated Facilities in the
California Region, by Species and Regulatory Option (2011$)
Species Name
Average
Annual
Harvest
2007-2011
(1,000 lbs)
Price
per
Pound
Annual Increase in Commercial Harvest
(1,000 lbs)
Annual Benefits from Increase in
Commercial Harvest
(2011$, 1,000s)
Proposal
Option 4
Final
Rule
Proposal
Option 2
Baseline
Proposal
Option 4
Final
Rule
Proposal
Option 2
Baseline
American Shad
57.9
$1.07
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Anchovies
13,637.3
$0.06
0.5
0.5
0.6
0.9
0.0
0.0
0.0
0.0
Cabezon
53.7
$5.89
0.1
0.1
46.4
76.1
0.2
0.3
143.6
235.4
California I lalibut
495.5
$4.73
0.2
0.2
107.9
176.9
0.6
0.7
297.2
487.1
California Scorpionfish
7.9
$3.83
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.1
Commercial Crabs
1,386.3
$1.37
0.0
0.0
1.3
2.2
0.0
0.0
1.4
2.2
Commercial Shrimp
4,272.1
$1.40
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Drums and Croakers
53.8
$0.56
0.7
0.8
4.3
6.9
0.2
0.2
1.0
1.6
Dungeness Crabs
15,495.5
$2.31
0.4
0.4
3.8
6.1
0.6
0.7
6.4
10.3
Flounders
381.3
$0.42
0.9
0.9
8.7
14.2
0.2
0.2
2.3
3.8
Other
47,410.9
$1.16
0.6
0.7
4.1
6.6
0.4
0.4
2.5
4.0
Rockiishes
2,741.3
$1.25
2.5
2.7
997.3
1.634.5
2.0
2.1
775.9
1.271.7
Sculpins
3.8
$3.53
0.1
0.1
2.2
3.7
0.2
0.2
5.1
8.3
Sea Basses
6.4
$2.76
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Smelts
323.0
$0.41
0.1
0.1
0.1
0.2
0.0
0.0
0.0
0.1
Surfperches
17.5
$1.90
0.4
0.5
0.5
0.7
0.3
0.3
0.4
0.5
Total (Undiscountcd)
86,344.2
6.5
7.0
1,177.4
1,928.9
4.8
5.2
1,235.8
2,025.1
Total (3% Discount Rate)
3.0
3.3
650.8
1,698.4
Total (7% Discount Rate)
2.2
2.4
422.5
1,518.8
Source: U.S. EPA analysis for this report.
July 8, 2014
H-1
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix H: Details of Commercial Fishing Benefits
Table H-2: Commercial Fishing Benefits from Eliminating or Reducing Baseline IM&E at Regulated Facilities in the
North Atlantic Region, by Species and Regulatory Option (2011$)
Species Name
Average
Annual
Harvest
2007-2011
(1,000 lbs)
Price
per
Pound
Annual Increase in Commercial Harvest
(1,000 lbs)
Annual Benefits from Increase in
Commercial Harvest
(2011$, 1,000s)
Proposal
Option 4
Final
Rule
Proposal
Option 2
Baseline
Proposal
Option 4
Final
Rule
Proposal
Option 2
Baseline
American Shad
30.3
$0.86
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Atlantic Cod
18.152.5
$1.64
0.1
0.1
1.8
2.3
0.1
0.1
2.0
2.5
Atlantic I Icrrinsi
168.023.6
$0.13
0.4
0.5
13.4
17.4
0.0
0.1
1.4
1.8
Atlantic Menhaden
7.346.1
$0.12
0.0
0.1
3.7
4.8
0.0
0.0
0.3
0.4
I
1.038.3
$0.57
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Butterfish
784.5
$0.68
0.1
0.1
0.2
0.2
0.0
0.0
0.1
0.1
Commercial Crabs
16.083.4
$0.62
0.2
0.2
0.3
0.3
0.1
0.1
0.1
0.1
Flounders
16.026.1
$1.95
1.2
4.6
286.0
373.1
1.5
5.7
355.5
463.8
Mackerels
29.268.6
$0.17
0.0
0.0
1.7
2.2
0.0
0.0
0.2
0.3
Other
332,156.1
$0.42
0.2
0.2
2.9
3.8
0.0
0.1
0.7
0.9
l
16.818.4
$0.64
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Red I lake
926.7
$0.39
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Sculpins
1.0
$0.1 1
0.0
0.2
3.2
3.2
0.0
0.0
0.0
0.0
Scup
5.362.2
$0.75
0.0
0.0
0.1
0.1
0.0
0.0
0.1
0.1
Searobin
53.3
$0.17
0.0
0.0
0.1
0.1
0.0
0.0
0.0
0.0
Silver I lake
1 1.108.1
$0.59
0.1
0.1
0.5
0.6
0.0
0.1
0.2
0.2
Skate Species
35,198.9
$0.22
0.3
0.3
0.5
0.5
0.0
0.1
0.1
0.1
Tautosi
142.6
$2.43
0.0
0.0
3.6
4.7
0.0
0.1
4.0
5.2
Weaklish
1 I.I
$1.67
0.0
0.0
0.2
0.2
0.0
0.0
0.2
0.3
White Perch
4.8
$1.20
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Total (Undiscounted)
658,536.4
2.7
6.7
318.0
413.6
1.9
6.2
364.7
475.8
Total (3% Discount Rate)
1.2
4.0
202.3
399.0
Total (7% Discount Rate)
0.9
3.0
135.9
356.8
Source: U.S. EPA analysis for this report.
July 8, 2014
H-2
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix H: Details of Commercial Fishing Benefits
Table H-3: Commercial Fishing Benefits from Eliminating or Reducing Baseline IM&E at Regulated Facilities in the Mid-
Atlantic Region, by Species and Regulatory Option (2011$)
Species Name
Average
Annual
Harvest
2007-2011
(1,000 lbs)
Price
per
Pound
Annual Increase in Commercial Harvest
(1,000 lbs)
Annual Benefits from Increase in
Commercial Harvest
(2011$, 1,000s)
Proposal
Option 4
Final
Rule
Proposal
Option 2
Baseline
Proposal
Option 4
Final
Rule
Proposal
Option 2
Baseline
Alewife
343.8
$0.29
0.2
0.2
0.3
0.3
0.1
0.1
0.1
0.1
American Shad
57.5
$0.83
0.0
0.0
0.8
0.9
0.0
0.0
0.6
0.6
Atlantic Herring
6,658.6
$0.12
0.1
0.1
0.1
0.1
0.0
0.0
0.0
0.0
Atlantic Menhaden
452,353.9
$0.07
2,503.2
2.674.8
3.398.8
3.700.8
126.4
135.0
I7F6
1 86.8
Black Drum
89.8
$2.20
0.2
0.2
0.2
0.2
0.3
0.3
0.3
0.4
Ml ue Crab
85,836.4
$1.11
8.8
9.8
559.0
640.9
5.6
6.2
354.4
406.3
Bluelish
2,996.3
$0.49
0.1
0.1
0.1
0.1
0.0
0.0
0.0
0.0
Butterfish
494.1
$0.84
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Commercial Crabs
2,490.9
$0.54
0.2
0.2
0.3
0.3
0.1
0.1
0.1
0.1
I )rums and Croakers
10,159.5
$0.64
14.1
15.7
837.7
960.3
6.7
7.5
398.8
457.1
Flounders
6,308.5
$2.08
2.6
2.8
5.5
6.1
3.6
3.8
7.8
8.6
Other
602,868.9
$0.31
98.1
105.3
72 F4
820.1
21.9
23.5
160.7
182.7
Red I lake
360.0
$0.46
0.5
0.5
0.6
0.6
0.1
0.1
0.2
0.2
Scup
4.I2F8
$0.81
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Searobin
37.3
$0.21
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Silver Hake
4,877.3
$0.64
0.1
0.1
0.1
0.1
0.0
0.0
0.0
0.0
Spot
3.478.4
$0.85
93.6
100.8
1,064.6
1.064.6
66.5
7F7
756.9
756.9
Striped Bass
5.609.6
$2.12
0.4
0.5
48.7
55.9
0.6
0.7
DC
00
78.9
Striped Mullet
26.2
$0.45
0.2
0.2
0.2
0.2
0.1
0.1
o.l
0.1
Tautosi
135.3
$2.98
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Weaklish
267.4
$1.32
150.4
160.9
449.3
503.7
150.9
I6F4
450.8
505.3
While Perch
1.588.5
$0.79
0.2
0.3
2.2
2.6
0.2
0.2
F5
1.7
Total (Undiscounted)
1,191,159.9
2,872.9
3,072.5
7,090.1
7,757.9
382.9
410.7
2,372.6
2,586.0
Total (3% Discount Rate)
242.1
259.7
1,206.2
2,168.8
Total (7% Discount Rate)
177.1
190.1
769.7
1,939.4
Source: U.S. EPA analysis for this report.
July 8, 2014
H-3
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix H: Details of Commercial Fishing Benefits
Table H-4: Commercial Fishing Benefits from Eliminating or Reducing Baseline IM&E at Regulated Facilities in the
South Atlantic Region, by Species and Regulatory Option (2011$)
Species Name
Average
Annual
Harvest
2007-2011
(1,000 lbs)
Price
per
Pound
Annual Increase in Commercial Harvest
(1,000 lbs)
Annual Benefits from Increase in
Commercial Harvest
(2011$, 1,000s)
Proposal
Option 4
Final
Rule
Proposal
Option 2
Baseline
Proposal
Option 4
Final
Rule
Proposal
Option 2
Baseline
Atlantic Menhaden
1,828.1
$0.12
25.7
27.5
42.2
42.9
2.2
2.4
3.7
3.8
Blue Crab
39.786.5
$0.95
2.2
2.3
3.2
3.2
1.2
1.3
1.7
1.7
Commercial Crabs
583.7
$1.65
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
I )rums and Croakers
6.347.6
$0.51
0.2
0.2
1 1.7
12.5
0.1
0.2
3.2
3.4
Other
94,277.5
$1.28
1.3
1.3
2.3
2.3
1.0
1.0
1.7
1.8
Spot
854.3
$0.70
7.0
7.5
15.6
16.1
3.4
3.8
7.6
7.9
Stone Crab
145.2
$4.01
0.3
0.3
0.4
0.4
0.6
0.7
0.9
1.0
Weakfish
144.6
$1.02
0.3
0.3
0.6
0.6
0.2
0.2
0.4
0.4
Total (Undiscounted)
143,967.5
36.9
39.6
76.0
78.1
8.7
9.7
19.3
19.9
Total (3% Discount Rate)
5.8
6.4
10.4
16.7
Total (7% Discount Rate)
4.4
4.9
7.0
14.9
Source: U.S. EPA analysis for this report.
July 8, 2014
H-4
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix H: Details of Commercial Fishing Benefits
Table H-5: Commercial Fishing Benefits from Eliminating or Reducing Baseline IM&E at Regulated Facilities in the Gulf
of Mexico Region, by Species and Regulatory Option (2011$)
Species Name
Average
Annual
Harvest
Price
per
Annual Increase in Commercial Harvest
(1,000 lbs)
Annual Benefits from Increase in
Commercial Harvest
(2011$, 1,000s)
2007-2011
(1,000 lbs)
Pound
Proposal
Option 4
Final
Rule
Proposal
Option 2
Baseline
Proposal
Option 4
Final
Rule
Proposal
Option 2
Baseline
Atlantic Menhaden
1,088,022.8
$0.07
841.3
873.2
1,053.6
1,173.2
44.7
46.3
55.9
62.3
I Mack Drum
4,621.9
$0.83
5.1
5.2
1,150.0
1.945.0
2.9
3.0
662.9
1.121.1
Blue Crab
53,055.9
$0.87
45.3
47.0
163.4
244.0
28.1
29.2
101.6
151.7
Drums and Croakers
111.8
$5.19
34.6
35.9
43.1
47.8
97.0
100.7
120.8
134.2
Leatheijacket
61.0
$1.51
74.3
77.2
95.1
107.1
0.0
0.0
0.0
0.0
Mackerels
3,898.1
$1.16
0.3
0.3
0.3
0.4
0.2
0.2
0.3
0.3
Other
1,384,185.9
$0.39
185.1
192.1
245.8
281.9
33.6
34.9
44.6
51.2
Pink Shrimp
6,973.0
$2.00
173.5
180.1
292.7
369.7
150.7
156.4
254.2
321.1
Sea Basses
179.4
$0.97
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Sheepshead
1.393.0
$0.44
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Spot
16.9
$0.51
27.8
28.9
39.3
46.3
7.7
7.9
10.8
12.7
Stone Crab
5,587.9
$4.13
117.2
121.6
330.2
474.4
344.9
358.0
972.0
1,396.2
Striped Mullet
10,800.3
$0.64
137.3
142.5
851.9
1,343.6
69.0
71.6
428.1
675.3
Total (Undiscounted)
2,558,908.0
1,641.8
1,704.0
4,265.5
6,033.5
778.9
808.3
2,651.3
3,926.1
Total (3% Discount Rate)
496.8
515.5
1,702.5
3,426.9
Total (7% Discount Rate)
365.2
378.9
1,255.7
3,160.8
Source: U.S. EPA analysis for this report.
July 8, 2014
H-5
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix H: Details of Commercial Fishing Benefits
Table H-6: Commercial Fishing Benefits from Eliminating or Reducing Baseline IM&E at Regulated Facilities in the
Great Lakes Region, by Species and Regulatory Option (2011$)
Species Name
Average
Annual
Harvest
2007-2011
(1,000 lbs)
Price
per
Pound
Annual Increase in Commercial Harvest
(1,000 lbs)
Annual Benefits from Increase in
Commercial Harvest
(2011$, 1,000s)
Proposal
Option 4
Final
Rule
Proposal
Option 2
Baseline
Proposal
Option 4
Final
Rule
Proposal
Option 2
Baseline
Bullhead
679.1
$0.40
17.9
19.7
22.8
23.5
2.1
2.3
2.6
2.7
Freshwater Drum
585.9
$0.18
73.8
81.4
203.3
209.1
3.9
4.3
10.8
1 F2
Other
14.356.7
$1.03
320.0
352.2
451.4
481.3
95.8
105.5
135.2
144.1
Sculpins
14.356.7
$1.03
0.0
0.0
0.1
0.1
0.0
0.0
0.0
0.0
Smelts
380.5
$1.60
61.3
67.5
87.0
92.9
28.4
31.3
40.4
43.1
White Bass
523.6
$0.73
248.1
248.1
248.1
248.1
52.6
52.6
52.6
52.6
Whitelish
9,785.3
$0.99
59.4
65.4
74.5
76.4
17.1
18.8
21.4
22.0
Yellow Perch
1.543.6
$2.14
3.8
4.1
5.2
5.5
2.3
2.6
3.2
3.4
Total (Undiscountcd)
42,211.3
784.2
838.5
1,092.4
1,136.9
202.2
217.3
266.2
279.0
Total (3% Discount Rate)
134.6
144.9
162.5
243.6
Total (7% Discount Rate)
101.9
109.8
116.2
224.6
Source: U.S. EPA analysis for this report.
July 8, 2014
H-6
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Appendix I: Details of Regional Recreational Fishing Benefits
1.1 California Region
Table 1-1: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities
under Proposal Option 4 in the California Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(201 IS, thousands)
5th
Mean
95th
5th
Mean
95th
California halibut
69.0
$5.35
$10.21
$19.49
0.0
0.8
1.5
Flounders
21.0
$5.35
$10.21
$19.49
0.0
0.2
0.5
Total (Flatfish)
90.0
S5.35
S10.21
S19.49
0.0
1.0
2.0
Striped bass
0.0
$4.40
$7.60
$13.01
0.0
0.0
0.0
Total (Small Game)
0.0
S4.40
S7.60
S13.01
0.0
0.0
0.0
Cabezon
10.0
$1.87
$i 09
$5 1 1
0.0
0.0
0.1
California scoqiionlish
49.0
$1.87
$i 09
$5 1 1
0.1
0.2
0.3
Croakers
4.564.0
$1.87
$3.09
$5 1 1
8.5
14.1
23.4
Rocklish
618.0
$1.87
$3.09
$5 1 1
1.2
1.9
3.2
Sculpin
3.192.0
$1.87
$3.09
$5 1 1
5.9
9.8
16.3
Sea bass
276.0
$1.87
$3.09
$5 1 1
0.5
0.9
1.4
Smelts
16.0
$1.87
$3.09
$5 1 1
0.0
0.0
0.1
Sunfish
1.0
$1.87
$3.09
$5 1 1
0.0
0.0
0.0
Surlperch
25.654.0
$1.87
$3.09
$5 1 1
47.8
79.1
131.3
Total (Other Saltwater)
34,381.0
SI.87
S3.09
S5.ll
64.0
106.0
176.0
Total (Unidentified)
949.0
SI.95
S3.25
S5.42
2.0
3.0
5.0
Total (Undiscounted)
35,420.0
67.0
110.0
183.0
Total (3% discount rate)
42.0
69.0
114.0
Total (7% discount rate)
30.0
50.0
83.0
Source: U.S. EPA analysis for this report.
July 8, 2014
1-1
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Table I-2: Recreational Fishing Benefits from Reducing at Regulated Facilities under
the Final Rule in the California Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(201 IS, thousands)
5th
Mean
95th
5th
Mean
95th
California halibut
74.0
$5.35
$10.21
$19.49
0.8
0.8
1.5
Flounders
23.0
$5.35
$10.21
$19.49
0.2
0.2
0.5
Total (Flatfish)
97.0
S5.35
S10.21
SI 9.49
1.0
1.0
2.0
Striped bass
0.0
$4.40
$7.60
$ 13.01
0.0
0.0
0.0
Total (Small Game)
().()
S4.40
S7.60
S13.01
0.0
0.0
0.0
Cabezon
1 1.0
$1.87
$i 09
$5.1 1
0.0
0.0
0.1
California scoqiionlish
53.0
$1.87
$3.09
$5 1 1
0.1
0.2
0.3
Croakers
4.917.0
$1.87
$i 09
$5.1 1
9.2
15.3
25.1
Rocklish
665.0
$1.87
$3.09
$5 1 1
1.2
2.1
3.4
Sculpin
3.439.0
$1.87
$i 09
$5.1 1
6.4
10.7
17.5
Sea bass
297.0
$1.87
$3.09
$5 1 1
0.6
0.9
F5
Smelts
18.0
$1.87
$i 09
$5.1 1
0.0
0.1
0.1
S
1.0
$1.87
$3.09
$5 1 1
0.0
0.0
0.0
Surlperch
27.638.0
$1.87
$i 09
$5.1 1
51.5
85.8
141.0
Total (Other Saltwater)
37,040.0
SI.87
S3.09
S5.ll
69.0
115.0
189.0
Total (Unidentified)
1,022.0
SI.95
S3.25
S5.42
2.0
3.0
6.0
Total (Undiscounted)
38,159.0
72.0
119.0
197.0
Total (3% discount rate)
45.0
74.0
123.0
Total (7% discount rate)
33.0
54.0
89.0
Source: U.S. EPA analysis for this report.
July 8, 2014
I-2
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Table I-3: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities
under Proposal Option 2 in the California Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(201 IS, thousands)
5th
Mean
95th
5th
Mean
95th
California halibut
32,791.0
$5.35
$10.21
$19.49
175.9
334.8
638.9
Flounders
213.0
$5.35
$10.21
$19.49
I.I
2.2
4.1
Total (Flatfish)
33,004.0
S5.35
S10.21
SI 9.49
177.0
337.0
643.0
Striped bass
1.032.0
$4.40
$7.60
$ 13.01
5.0
8.0
13.0
Total (Small Game)
1,032.0
S4.40
S7.60
S13.01
5.0
8.0
13.0
Cabezon
6.1 10.0
$1.87
$3 09
$5.1 1
1 1.4
18.9
31.3
California su>rpionlish
56.0
$1.87
$3.09
$5 1 1
0.1
0.2
0.3
Croakers
28.043.0
$1.87
$3 m
$5.1 1
52.5
| OC |
1 oc I
143.4
Rocklish
243.212.0
$1.87
$3.09
$5 1 1
455.2
752.6
1.244.0
Sculpin
95.822.0
$1.87
$3 09
$5.1 1
179.3
296.5
490.1
Sea bass
437.354.0
$1.87
$3.09
$5 1 1
818.6
1.353.3
2.237.0
Smelts
20.0
$1.87
$3 09
$5.1 1
0.0
0.1
0.1
S
12.0
$1.87
$3.09
$5 1 1
0.0
0.0
0.1
Surlperch
29.282.0
$1.87
$3 09
$5.1 1
54.8
90.6
149.8
Total (Other Saltwater)
839,911.0
SI.87
S3.09
S5.ll
1,572.0
2,599.0
4,296.0
Total (Unidentified)
3,227.0
SI.95
S3.25
S5.42
6.0
10.0
17.0
Total (Undiscounted)
877,174.0
1,759.0
2,954.0
4,970.0
Total (3% discount rate)
919.0
1,543.0
2,595.0
Total (7% discount rate)
592.0
994.0
1,673.0
Source: U.S. EPA analysis for this report.
July 8, 2014
I-3
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Table I-4: Recreational Fishing Benefits from Eliminating Baseline IM&E at Regulated
Facilities in the California Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(201 IS, thousands)
5th
Mean
95th
5th
Mean
95th
California halibut
53,746.0
$5.35
$10.21
$19.49
287.2
548.5
1,047.3
Flounders
345.0
$5.35
$10.21
$19.49
1.8
3.5
6.7
Total (Flatfish)
54,091.0
S5.35
S10.21
SI 9.49
289.0
552.0
1,054.0
Striped bass
1.692.0
$4.40
$7.60
$ 13.01
7.0
13.0
22.0
Total (Small Game)
1,692.0
S4.40
S7.60
S13.01
7.0
13.0
22.0
Cabezon
10.015.0
$1.87
$3 09
$5.1 1
18.7
31.0
51.2
California scoqiionlish
82.0
$1.87
$3.09
$5 1 1
0.2
0.3
0.4
Croakers
45.086.0
$1.87
$3 09
$5.1 1
84.4
139.5
230.6
Rocklish
398.609.0
$1.87
$3.09
$5 1 1
745.9
1.233.4
2.038.6
Sculpin
156.471.0
$1.87
$3 09
$5.1 1
292.8
484.2
800.2
Sea bass
716.959.0
$1.87
$3.09
$5 1 1
1.341.5
2,218.5
3.666.7
Smelts
30.0
$1.87
$3 09
$5.1 1
0.1
0.1
0.2
S
19.0
$1.87
$3.09
$5 1 1
0.0
0.1
0.1
Surlperch
43.01 1.0
$1.87
$3 09
$5.1 1
80.5
133.1
220.0
Total (Other Saltwater)
1,370,282.0
SI.87
S3.09
S5.ll
2,564.0
4,240.0
7,008.0
Total (Unidentified)
5,106.0
SI.95
S3.25
S5.42
10.0
17.0
28.0
Total (Undiscounted)
1,431,170.0
2,871.0
4,822.0
8,112.0
Total (3% discount rate)
2,408.0
4,044.0
6,803.0
Total (7% discount rate)
2,153.0
3,616.0
6,084.0
Source: U.S. EPA analysis for this report.
July 8, 2014
I-4
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
1.2 North Atlantic Region
Table I-5: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities
under Proposal Option 4 in the North Atlantic Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(201 IS, thousands)
5th
Mean
95th
5th
Mean
95th
Winter flounder
765.0
$3.98
$6.24
$9.86
3.0
5.0
8.0
Total (flatfish)
765.0
S3.98
S6.24
S9.86
3.0
5.0
8.0
Atlantic mackerel
().()
$2.23
$6.22
$17.53
0.0
0.0
0.0
Bluefish
1.0
$2.23
$6.22
$17.53
0.0
0.0
0.0
Striped bass
().()
$2.23
$6.22
$17.53
0.0
0.0
0.0
Weaklish
().()
$2.23
$6 22
$17.53
0.0
0.0
0.0
Total (small game)
1.0
S2.23
S6.22
SI 7.53
0.0
0.0
0.0
Atlantic Cod
37.0
$1.87
$^ 12
$5 20
0.1
0.1
0.2
C miner
18.0
$1.87
$^ 12
$5 20
0.0
0.0
0.1
Pollock
1.0
$1.87
$^ 12
$5 20
0.0
0.0
0.0
Sculpin
316.0
$1.87
$^ 12
$5 20
0.7
0.7
1.4
Scup
8.0
$1.87
$^ 12
$5 20
0.0
0.0
0.0
Searobin
41.0
$1.87
$^ 12
$5 20
0.1
0.1
0.2
Tautosi
15.0
$1.87
$^ 12
$5 20
0.0
0.0
0.1
White Perch
0.0
$1.87
$^ 12
$5 20
0.0
0.0
0.0
Total (other saltwater)
436.0
SI.87
S3.12
S5.20
1.0
1.0
2.0
Total (unidentified)
166.0
SI.88
S3.15
S5.26
0.0
1.0
1.0
Total (Uiidiscowited)
1,367.0
4.0
7.0
11.0
Total (3% discount rate)
3.0
4.0
7.0
Total (7% discount rate)
2.0
3.0
5.0
Source: U.S. EPA analysis for this report.
July 8, 2014
I-5
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Table I-6: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities
under the Final Rule in the North Atlantic Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(201 IS, thousands)
5th
Mean
95th
5th
Mean
95th
Winter flounder
3.471.0
$3.98
$6.24
$9.86
14.0
22.0
34.0
Total (flatfish)
3,471.0
S3.98
S6.24
S9.86
14.0
22.0
34.0
Atlantic mackerel
8.0
$2.23
$6.22
$17.53
0.0
0.0
0.0
Bluelish
1.0
$2.23
$6 22
$17.53
0.0
0.0
0.0
Striped bass
0.0
$2.23
$6.22
$17.53
0.0
0.0
0.0
Weaklish
0.0
$2.23
$6 22
$17.53
0.0
0.0
0.0
Total (small «ame)
9.0
S2.23
S6.22
SI 7.53
0.0
0.0
0.0
Atlantic Cod
50.0
$1.87
$^ 12
$5.20
0.1
0.2
0.3
Cunner
941.0
$1.87
$^ 12
$5.20
1.8
2.8
4.8
Pollock
1.0
$1.87
$3.12
$5.20
0.0
0.0
0.0
Sculpin
3.107.0
$1.87
$^ 12
$5.20
5.8
9.4
15.9
Scup
9.0
$1.87
$^ 12
$5.20
0.0
0.0
0.0
Searobin
51.0
$1.87
$^ 12
$5.20
0.1
0.2
0.3
Tautosi
139.0
$1.87
$^ 12
$5 20
0.3
0.4
0.7
White Perch
0.0
$1.87
$^ 12
$5.20
0.0
0.0
0.0
Total (other saltwater)
4,298.0
SI.87
S3.12
S5.20
8.0
13.0
22.0
Total (unidentified)
198.0
SI.88
S3.15
S5.26
0.0
1.0
1.0
Total (Undiscounted)
7,975.0
22.0
36.0
58.0
Total (3% discount rate)
14.0
23.0
36.0
Total (7% discount rate)
10.0
16.0
27.0
Source: U.S. EPA analysis for this report.
July 8, 2014
I-6
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Table I-7: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities
under Proposal Option 2 in the North Atlantic Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(201 IS, thousands)
5th
Mean
95th
5th
Mean
95th
Winter flounder
229.386.0
$3.98
$6.24
$9.86
914.0
1.430.0
2,261.0
Total (flatfish)
229,386.0
S3.98
S6.24
S9.86
914.0
1,430.0
2,261.0
Atlantic mackerel
666.0
$2.23
$6.22
$17.53
1.9
3.8
1 1.5
Bluelish
l.o
$2.23
$6 22
$17.53
0.0
0.0
0.0
Striped bass
0.0
$2.23
$6.22
$17.53
0.0
0.0
0.0
Weaklish
25.0
$2.23
$6 22
$17.53
0.1
0.1
0.4
Total (small «ame)
692.0
S2.23
S6.22
SI 7.53
2.0
4.0
12.0
Atlantic Cod
955.0
$1.87
$^ 12
$5.20
1.8
3.0
5.0
Cunner
79.272.0
$1.87
$^ 12
$5.20
148.2
247.3
412.3
Pollock
3.0
$1.87
$3.12
$5.20
0.0
0.0
0.0
Sculpin
238.602.0
$1.87
$^ 12
$5.20
445.9
744.4
1.241.0
Scup
96.0
$1.87
$^ 12
$5.20
0.2
0.3
0.5
Searobin
618.0
$1.87
$^ 12
$5.20
1.2
1.9
3.2
Tautosi
10.583.0
$1.87
$^ 12
$5 20
19.8
33.0
55.0
White Perch
0.0
$1.87
$^ 12
$5.20
0.0
0.0
0.0
Total (other saltwater)
330,130.0
SI.87
S3.12
S5.20
617.0
1,030.0
1,717.0
Total (unidentified)
2,098.0
SI.88
S3.15
S5.26
4.0
7.0
11.0
Total (Undiscounted)
562,305.0
1,537.0
2,471.0
4,001.0
Total (3% discount rate)
852.0
1,371.0
2,219.0
Total (7% discount rate)
573.0
921.0
1,491.0
Source: U.S. EPA analysis for this report.
July 8, 2014
I-7
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Table I-8: Recreational Fishing Benefits from Eliminating Baseline IM&E at Regulated
Facilities in the North Atlantic Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(201 IS, thousands)
5th
Mean
95th
5th
Mean
95th
Winter flounder
299.3520
$3.98
$6.24
$9.86
1.192.0
1.867.0
2,951.0
Total (flatfish)
299,352.0
S3.98
S6.24
S9.86
1,192.0
1,867.0
2,951.0
Atlantic mackerel
870.0
$2.23
$6.22
$17.53
1.9
5.8
15.4
Bluelish
l.o
$2.23
$6 22
$17.53
0.0
0.0
0.0
Striped bass
0.0
$2.23
$6.22
$17.53
0.0
0.0
0.0
Weaklish
32.0
$2.23
$6 22
$17.53
0.1
0.2
0.6
Total (small «ame)
903.0
S2.23
S6.22
SI 7.53
2.0
6.0
16.0
Atlantic Cod
1.235.0
$1.87
$^ 12
$5.20
2.3
3.9
6.4
Cunner
103.533.0
$1.87
$^ 12
$5.20
193.6
323.1
538.5
Pollock
4.0
$1.87
$3.12
$5.20
0.0
0.0
0.0
Sculpin
31 1.537.0
$1.87
$^ 12
$5.20
582.5
972.1
1.620.4
Scup
123.0
$1.87
$^ 12
$5.20
0.2
0.4
0.6
Searobin
794.0
$1.87
$^ 12
$5.20
1.5
2.5
4.1
Tautosi
13.817.0
$1.87
$^ 12
$5 20
25.8
43.1
71.9
White Perch
0.0
$1.87
$^ 12
$5.20
0.0
0.0
0.0
Total (other saltwater)
431,044.0
SI.87
S3.12
S5.20
806.0
1,345.0
2,242.0
Total (unidentified)
2,686.0
SI.88
S3.15
S5.26
5.0
8.0
14.0
Total (Undiscounted)
733,985.0
2,006.0
3,226.0
5,223.0
Total (3% discount rate)
1,682.0
2,705.0
4,380.0
Total (7% discount rate)
1,504.0
2,419.0
3,917.0
Source: U.S. EPA analysis for this report.
July 8, 2014
I-8
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
1.3 Mid-Atlantic Region
Table I-9: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities
under Proposal Option 4 in the Mid-Atlantic Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(2011$, thousands)
5th
Mean
95th
5th
Mean
95th
Summer Flounder
3,096.0
$3.92
$5.88
$8.92
12.4
17.8
27.6
Winter Flounder
386.0
$3.92
$5.88
$8 92
1.6
2.2
3.4
Total (Flatfish)
1,482.0
Sl92
S5C88
S8.92
iiir
20.0
3DF
I Muck Cnippie
2.0
$(755
sT7il
$2 20
ad
(77)
ad
Bluegili
;7.o
$(755
$770
$2 20
(77)
0.7)
ad
Brown bullhead
NMli
$(715
slTi
$2 20
(73
0.7
F3
Buiihead
6.7)
$(755
sT7il
$2.20
ad
(77)
ad
Channel cattish
F(>S(7(i
$(755
sT7il
$2.20
()7T
2.7
73
Crappie
no
$(755
s77il
$2.20
ad
(77)
ad
Menhaden
l7o
$(755
$770
$2 20
(77)
(7.7)
ad
Sun lish
129.7)
$(755
$7TI
$2 20
(77
0.2
(73
Total (Panfish)
2,4387«
S(l55
sTJi
*S*I*2(**F*
i7o
3.0
sir
Bluelish
74.7)
$23*7
$6 17
$76.23
(73
(777
F3
Red drum
1.555.0
$2.37
$6 17
$16.23
3.7
9.6
25.2
Spotted seatrout
F7i3i7o
$237
$6 17
$16"23
277
i77
I7777
Striped bass
773.7)
$237
$6 17
$16"23
F*8
778
1376
Weakfish
9^19(7(1
$23*7
$6 17
SI.03
22(79
575.8
73733
___
Total (Small Game)
%,6287(1
Sl37
s6.r
SUk23
229JF*
597.(i
Atlantic croaker
SF94
$3 05
$4 82
3277
50.6
793
Atlantic herring
33.7)
SF94
$3 05
$4 82
(77
o7l
(73
Black drum
149.7)
SF94
$3 05
$4 82
(73
(777
aT*
C miner
0.0
$1.94
$3 05
$4 82
0.0
0.0
00
Scup
r.7)
SF94
$3.05
$4 82
ad
o7)
ad
Searobin
4.7)
SF94
$3 05
$4 82
ad
o.7)
ad
Silver perch
rii
SF94
$3 05
$4 82
o7d
o.7)
o7d
Smallmouth bass
34.7)
SF94
$3 05
$4 82
(77
o7
(73
Spot
2487)397)
SF94
$3 05
$4 82
48777
757.9
17794 3
Striped mullet
7.7)
SF94
$3 05
$4 82
ad
(77(7
o7d
i'autog
(77)
SF94
$3 05
$4 82
ad
(77)
o7d
White perch
iTrlo
SF94
$3 05
$4 82
378
6.7)
93
Whitelish
248.7)
SF94
$3 05
$4 82
(73
(778
f3
Total (Other Saltwater)
2^^^
sIm
Sl«5
Sl82
518J
816.0
i^286lF
Total (Unidentified)
58j277(i
slim
*S*I*3*9
s
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Table 1-10: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities
under the Final Rule in the Mid-Atlantic Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(201 IS, thousands)
5th
Mean
95th
5th
Mean
95th
Summer Flounder
3,308.0
$3.92
$5.88
$8.92
13.3
19.5
29.3
Winter Flounder
414.0
$3.92
$5.88
$8.92
1.7
2.4
3.7
Total (Flatfish)
3,723.0
S3.92
S5.88
S8.92
15.0
22.0
33.0
I Muck Cnippie
2.0
$0.55
$1.11
$2.20
0.0
0.0
0.0
Bluesiill
10.0
$0.55
$1.11
$2.20
0.0
0.0
0.0
Brown bullhead
647.0
$0.55
$1.11
$2 20
0.2
0.7
1.5
Bullhead
7.0
$0.55
$1.11
$2.20
0.0
0.0
0.0
Channel catfish
1.801.0
$0.55
$1.11
$2.20
0.7
2.1
4.1
Cnippie
1.0
$0.55
$1.11
$2.20
0.0
0.0
0.0
Menhaden
1.0
$0.55
$1.11
$2.20
0.0
0.0
0.0
S
138.0
$0.55
$1.11
$2 20
0.1
0.2
0.3
Total (Panfish)
2,607.0
S0.55
SI.11
S2.20
1.0
3.0
6.0
Blueiish
79.0
$2.37
$6.17
$16.23
0.2
0.5
1.3
Red drum
1.661.0
$2.37
$6.17
$16.23
3.9
10.3
27.0
Spotted sea trout
1.101.0
$2.37
$6 17
$16.23
2.6
6.8
17.9
Striped bass
897.0
$2.37
$6.17
$16.23
2.1
5.5
14.6
Weaklish
99.705.0
$2.37
$6 17
$16.23
236.1
615.9
1.618.3
Total (Small Game)
103,444.0
S2.37
S6.17
SI 6.23
245.0
639.0
1,679.0
Atlantic croaker
18.458.0
$1.94
$3.05
$4.82
35.8
56.3
88.9
Atlantic herring
35.0
$1.94
$i 05
$4.82
0.1
0.1
0.2
Black drum
159.0
$1.94
$i 05
$4 82
0.3
0.5
0.8
Cunner
0.0
$1.94
$i 05
$4.82
0.0
0.0
0.0
Scup
1.0
$1.94
$i 05
$4 82
0.0
0.0
0.0
Searobin
4.0
$1.94
$i 05
$4.82
0.0
0.0
0.0
Silver perch
1.0
$1.94
$i 05
$4 82
0.0
0.0
0.0
Smallmouth bass
36.0
$1.94
$i 05
$4.82
0.1
0.1
0.2
Spot
267.172.0
$1.94
$i 05
$4 82
518.1
815.6
1.286.5
Striped mullet
8.0
$1.94
$i 05
$4.82
0.0
0.0
0.0
Tautosi
0.0
$1.94
$i 05
$4 82
0.0
0.0
0.0
White perch
2.1 19.0
$1.94
$i 05
$4.82
4.1
6.5
10.2
Whitefish
265.0
$1.94
$i 05
$4 82
0.5
0.8
1.3
Total (Other Saltwater)
288,258.0
SI.94
S3.05
S4.82
559.0
880.0
1,388.0
Total (Unidentified)
62,808.0
S2.00
S3.39
S6.00
126.0
213.0
377.0
Total (Undiscounted)
460,839.0
945.0
1,757.0
3,483.0
Total (3% discount rate)
572.0
1,063.0
2,108.0
Total (7% discount rate)
405.0
753.0
1,493.0
Source: U.S. EPA analysis for this report.
July 8, 2014
1-10
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Table 1-11: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities
under Proposal Option 2 in the Mid-Atlantic Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(2011S, thousands)
5th
Mean
95th
5th
Mean
95th
Summer Flounder
3,781.0
$3.92
$5.88
$8.92
14.9
22.3
33.8
Winter Flounder
2,823.0
$3.92
$5.88
$8.92
11.1
16.7
25.2
Total (Flatfish)
6,604.0
S3.92
S5.88
S8.92
26.0
39.0
59.0
Black Crappie
2.0
$0.55
$1.11
$2.20
0.0
0.0
0.0
Bluesiill
1 1.0
$0.55
$1.11
$2.20
0.0
0.0
0.0
Brown bullhead
2.281.0
$0.55
$1.11
$2 20
1.4
2.7
5.0
Bullhead
8.0
$0.55
$1.11
$2.20
0.0
0.0
0.0
Channel catfish
2,059.0
$0.55
$1.11
$2.20
1.2
2.4
4.5
Crappie
1.0
$0.55
$1.11
$2.20
0.0
0.0
0.0
Menhaden
530.0
$0.55
$1.11
$2.20
0.3
0.6
1.2
157.0
$0.55
$1.11
$2 20
0.1
0.2
0.3
Total (PanMsli)
5,049.0
S0.55
SI.11
S2.20
3.0
6.0
11.0
Blue fish
90.0
$2.37
$6.17
$16.23
0.2
0.6
1.5
Red drum
1.899.0
$2.37
$6.17
$16.23
4.5
1 1.7
30.8
Spotted seatrout
1.259.0
$2.37
$6 17
$16.23
3.0
7.8
20.4
Striped bass
91.823.0
$2.37
$6.17
$16.23
217.3
566.9
1.490.6
Weaklish
278.408.0
$2.37
$6 17
$16.23
659.0
1.719.0
4.519.6
Total (Small Game)
373,479.0
S2.37
S6.17
SI 6.23
884.0
2,306.0
6,063.0
Atlantic croaker
983.158.0
$1.94
$3.05
$4.82
1.906.3
3.003.0
4.733.8
Atlantic herring
40.0
$1.94
$3 05
$4.82
0.1
0.1
0.2
Black drum
182.0
$1.94
$3 05
$4 82
0.4
0.6
0.9
C miner
0.0
$1.94
$3 05
$4.82
0.0
0.0
0.0
Scup
1.0
$1.94
$3 05
$4 82
0.0
0.0
0.0
Searobin
5.0
$1.94
$3 05
$4.82
0.0
0.0
0.0
Silver perch
1.0
$1.94
$3 05
$4 82
0.0
0.0
0.0
Smallmouth bass
41.0
$1.94
$3 05
$4.82
0.1
0.1
0.2
Spot
3.026.406.0
$1.94
$3 05
$4 82
5.868.1
9.243.9
14.571.9
Striped mullet
9.0
$1.94
$3 05
$4.82
0.0
0.0
0.0
Tautosi
0.0
$1.94
$3 05
$4 82
0.0
0.0
0.0
White perch
18.793.0
$1.94
$3 05
$4.82
36.4
57.4
90.5
Whiteiish
303.0
$1.94
$3 05
$4 82
0.6
0.9
1.5
Total (Other Saltwater)
4,028,939.0
SI.94
S3.05
S4.82
7,812.0
12,306.0
19,399.0
Total (Unidentified)
689,524.0
S2.00
S3.39
S6.00
1,378.0
2,340.0
4,138.0
Total (Undiscounted)
5,103,595.0
10,102.0
16,996.0
29,670.0
Total (3% discount rate)
5,132.0
8,634.0
15,072.0
Total (7% discount rate)
3,273.0
5,506.0
9,612.0
Source: U.S. EPA analysis for this report.
July 8, 2014
1-11
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Table 1-12: Recreational Fishing Benefits from Eliminating Baseline IM&E at Regulated
Facilities in the Mid-Atlantic Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(2011S, thousands)
5th
Mean
95th
5th
Mean
95th
Summer Flounder
4,092.0
$3.92
$5.88
$8.92
16.3
24.1
36.4
Winter Flounder
3,209.0
$3.92
$5.88
$8.92
12.7
18.9
28.6
Total (Flatfish)
7,301.0
S3.92
S5.88
S8.92
29.0
43.0
65.0
Black Crappie
3.0
$0.55
$1.11
$2.20
0.0
0.0
0.0
Bluesiill
12.0
$0.55
$1.11
$2.20
0.0
0.0
0.0
Brown bullhead
2.569.0
$0.55
$1.11
$2 20
1.4
2.8
5.5
Bullhead
8.0
$0.55
$1.11
$2.20
0.0
0.0
0.0
Channel catfish
2.228.0
$0.55
$1.11
$2.20
1.2
2.4
4.8
Crappie
1.0
$0.55
$1.11
$2.20
0.0
0.0
0.0
Menhaden
609.0
$0.55
$1.11
$2.20
0.3
0.7
1.3
170.0
$0.55
$1.11
$2 20
0.1
0.2
0.4
Total (PanMsli)
5,600.0
S0.55
SI.11
S2.20
3.0
6.0
12.0
Blue fish
97.0
$2.37
$6.17
$16.23
0.2
0.6
1.6
Red drum
2.055.0
$2.37
$6.17
$16.23
4.9
12.7
33.4
Spotted seatrout
1.362.0
$2.37
$6 17
$16.23
3.2
8.4
22.1
Striped bass
105.323.0
$2.37
$6.17
$16.23
249.2
650.3
1.709.8
Weaklish
312.082.0
$2.37
$6 17
$16.23
738.5
1.927.0
5.066.2
Total (Small Game)
420,920.0
S2.37
S6.17
SI 6.23
996.0
2,599.0
6,833.0
Atlantic croaker
1.127.044.0
$1.94
$3.05
$4.82
2.185.2
3.442.4
5.426.8
Atlantic herring
44.0
$1.94
$3 05
$4.82
0.1
0.1
0.2
Black drum
197.0
$1.94
$3 05
$4 82
0.4
0.6
0.9
C miner
0.0
$1.94
$3 05
$4.82
0.0
0.0
0.0
Scup
1.0
$1.94
$3 05
$4 82
0.0
0.0
0.0
Searobin
6.0
$1.94
$3 05
$4.82
0.0
0.0
0.0
Silver perch
1.0
$1.94
$3 05
$4 82
0.0
0.0
0.0
Smallmouth bass
44.0
$1.94
$3 05
$4.82
0.1
0.1
0.2
Spot
3.453.578.0
$1.94
$3 05
$4 82
6.696.1
10.548.3
16.629.1
Striped mullet
9.0
$1.94
$3 05
$4.82
0.0
0.0
0.0
Tautosi
0.0
$1.94
$3 05
$4 82
0.0
0.0
0.0
White perch
21.41 1.0
$1.94
$3 05
$4.82
41.5
65.4
103.1
Whiteiish
328.0
$1.94
$3 05
$4 82
0.6
1.0
1.6
Total (Other Saltwater)
4,602,664.0
SI.94
S3.05
S4.82
8,924.0
14,058.0
22,162.0
Total (Unidentified)
786,704.0
S2.00
S3.39
S6.00
1,573.0
2,669.0
4,721.0
Total (Undiscounted)
5,823,189.0
11,524.0
19,375.0
33,793.0
Total (3% discount rate)
9,665.0
16,249.0
28,341.0
Total (7% discount rate)
8,643.0
14,531.0
25,343.0
Source: U.S. EPA analysis for this report.
July 8, 2014
1-12
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
I.4 South Atlantic Region
Table 1-13: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities
under Proposal Option 4 in the South Atlantic Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(2011$, thousands)
5th
Mean
95th
5th
Mean
95th
Flounders
402.0
$4.05
$5.87
$8.66
2.0
2.0
3.0
Total (Flatfish)
402.0
$4.05
S5.87
S8.66
2.0
2.0
3.0
Spotted sea trout
().()
$2.84
$5 99
$12.59
0.0
0.0
0.0
Weaktish
183.0
$2.84
$5 99
$12.59
1.0
1.0
2.0
Total (Small Game)
183.0
S2.84
S5.99
SI 2.59
1.0
1.0
2.0
Croakers
1.440.0
$2.24
$2 98
$^ 95
3.3
4.2
5.7
l'mlish
0.0
$2.24
$2 98
$T 95
0.0
0.0
0.0
Silver perch
39.0
$2.24
$2 98
$T 95
0.1
0.1
0.2
Spot
10.409.0
$2.24
$2 98
$T 95
23.6
30.6
41.2
Total (Other Saltwater)
ll.xss.o
$2.24
S2.98
S3.95
27.0
35.0
47.0
Total (Unidentified)
510.0
S2.25
S2.99
S3.99
1.0
2.0
2.0
Total (Uiidiscowited)
12,983.0
30.0
40.0
55.0
Total (3% discount rate)
18.0
24.0
33.0
Total (7% discount rate)
13.0
17.0
23.0
Source: U.S. EPA analysis for this report.
Table 1-14: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities
under the Final Rule (IM Everywhere) in the South Atlantic Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(2011$, thousands)
5th
Mean
95th
5th
Mean
95th
Flounders
430.0
$4.05
$5.87
$8.66
2.0
3.0
4.0
Total (Flatfish)
430.0
$4.05
S5.87
S8.66
2.0
3.0
4.0
Spotted seatrout
84.0
$2.84
$5.99
$12.59
0.3
0.6
1.2
Weakfish
201.0
$2.84
$5.99
$12.59
0.7
1.4
2.8
Total (Small Game)
284.0
S2.84
S5.99
SI 2.59
1.0
2.0
4.0
Croakers
5.705.0
$2.24
$2.98
$^ 95
12.8
17.0
22.6
Pintish
67.0
$2.24
$2.98
$T 95
0.1
0.2
0.3
Silver perch
42.0
$2.24
$2.98
$T 95
0.1
0.1
0.2
Spot
1 1.607.0
$2.24
$2.98
$T 95
26.0
34.6
46.0
Total (Other Saltwater)
17,421.0
$2.24
S2.98
S3.95
39.0
52.0
69.0
Total (Unidentified)
589.0
S2.25
S2.99
S3.99
1.0
2.0
2.0
Total (Undiscounted)
18,725.0
43.0
58.0
78.0
Total (3% discount rate)
26.0
35.0
47.0
Total (7% discount rate)
18.0
24.0
33.0
Source: U.S. EPA analysis for this report.
July 8, 2014
1-13
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Table 1-15: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities
under Proposal Option 2 in the South Atlantic Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(2011$, thousands)
5th
Mean
95th
5th
Mean
95th
Flounders
587.0
$4.05
$5.87
$8.66
2.0
3.0
5.0
Total (Flatfish)
587.0
S4.05
S5.87
S8.66
2.0
3.0
5.0
Spotted sea trout
1.501.0
$2.84
$5.99
$12.59
4.1
8.9
18.7
Weaklish
347.0
$2.84
$5.99
$12.59
0.9
2.1
4.3
Total (Small Game)
1,848.0
$2.84
S5.99
SI 2.59
5.0
11.0
23.0
Croakers
76.510.0
$2.24
$2.98
$^ 95
171.9
228.0
302.2
l
1.200.0
$2.24
$2.98
$^ 95
2.7
3.6
4.7
Silver perch
58.0
$2.24
$2.98
$^ 95
0.1
0.2
0.2
Spot
23.237.0
$2.24
$2.98
$^ 95
52.2
69.2
91.8
Total (Other Saltwater)
101,006.0
S2.24
S2.98
S3.95
227.0
301.0
399.0
Total (Unidentified)
1,502.0
S2.25
S2.99
S3.99
3.0
4.0
6.0
Total (Undiscounted)
104,943.0
238.0
320.0
433.0
Total (3% discount rate)
129.0
173.0
234.0
Total (7% discount rate)
86.0
115.0
156.0
Source: U.S. EPA analysis for this report.
Table 1-16: Recreational Fishing Benefits from Eliminating Baseline IM&E at Regulated
Facilities in the South Atlantic Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(2011$, thousands)
5th
Mean
95th
5th
Mean
95th
Flounders
593.0
$4.05
$5.87
$8.66
2.0
3.0
5.0
Total (Flatfish)
593.0
$4.05
$5.87
$8.66
2.0
3.0
5.0
Spotted sea trout
1.604.0
$2.84
$5.99
$12.59
4.9
9.8
20.5
Weaklish
355.0
$2.84
$5.99
$12.59
I.I
2.2
4.5
Total (Small Game)
1,960.0
S2.84
S5.99
SI 2.59
6.0
12.0
25.0
Croakers
81.677.0
$2.24
$2.98
$^ 95
183.3
243.6
323.0
Pinlish
1.283.0
$2.24
$2.98
$^ 95
2.9
3.8
5.1
Silver perch
58.0
$2.24
$2.98
$^ 95
0.1
0.2
0.2
Spot
23.943.0
$2.24
$2.98
$^ 95
53.7
71.4
94.7
Total (Other Saltwater)
106,961.0
S2.24
S2.98
S3.95
240.0
319.0
423.0
Total (Unidentified)
1,562.0
S2.25
S2.99
S3.99
4.0
5.0
6.0
Total (I ndiscounted)
111,075.0
251.0
338.0
459.0
Total (3% discount rate)
211.0
284.0
385.0
Total (7% discount rate)
189.0
254.0
344.0
Source: U.S. EPA analysis for this report.
July 8, 2014
1-14
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
1.5 Gulf of Mexico Region
Table 1-17: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities
under Proposal Option 4 in the Gulf of Mexico Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(201 IS, thousands)
5th
Mean
95th
5th
Mean
95th
Mackerels
994.0
$3.00
$5.89
$11.55
3.0
5.9
11.5
Red dram
19,500.0
$3.00
$5.89
$11.55
58.6
114.9
225.2
Spotted sea trout
394.7800
$3.00
$5.89
$1 1.55
1.185.5
2,325.3
4.558.4
Total (Small Game)
415,274.0
S3.00
S5.89
SI 1.55
1,247.0
2,446.0
4,795.0
Atlantic croaker
153.81 1.0
$2.23
$2 91
$^ 78
343.5
446.7
581.4
I Mack drum
4.185.0
$2.23
$2 91
$^ 78
9.3
12.2
15.8
Pmlish
6.006.0
$2.23
$2 91
$^ 78
13.4
17.4
22.7
Sea bass
103 0
$2.23
$2 91
$^ 78
0.2
0.3
0.4
Searobin
73.120 0
$2.23
$2 91
$^ 78
163.3
212.4
276.4
Sheepshead
1.0
$2.23
$2 91
$^ 78
0.0
0.0
0.0
Silver perch
67.0
$2.23
$2 91
$^ 78
0.1
0.2
0.3
Spot
21.098.0
$2.23
$2 91
$^ 78
47.1
61.3
79.8
Striped mullet
5.350.0
$2.23
$2 91
$^ 78
1 1.9
15.5
20.2
Total (Other Saltwater)
263,742.0
S2.23
S2.91
S3.78
589.0
"66 0
997.0
Total (Unidentified)
70,129.0
S2.47
S3.83
S6.18
173.0
269.0
434.0
Total (Uiidiscowited)
749,144.0
2,009.0
3,481.0
6,225.0
Total (3% discount rate)
1,260.0
2,183.0
3,904.0
Total (7% discount rate)
914.0
1,583.0
2,831.0
Source: U.S. EPA analysis for this report.
July 8, 2014
1-15
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Table 1-18: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities
under the Final Rule in the Gulf of Mexico Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(201 IS, thousands)
5th
Mean
95th
5th
Mean
95th
Mackerels
1.032.0
$3.00
$5.89
$1 1.55
3.1
6.1
11.9
Red drum
20.239.0
$3.00
$5.89
$1 1.55
60.8
119.2
233.7
Spotted sea trout
409.748.0
$3.00
$5.89
$1 1.55
1.230.1
2,413.7
4,731.4
Total (Small Game)
431,019.0
S3.00
S5.89
SI 1.55
1,294.0
2,539.0
4,977.0
Atlantic croaker
159.643.0
$2.23
$2.91
$^ 78
356.4
463.7
603.1
Black drum
4.295.0
$2.23
$2 91
$^ 78
9.6
12.5
16.2
Pinlish
6.226.0
$2.23
$2.91
$^ 78
13.9
18.1
23.5
Sea bass
107.0
$2.23
$2 91
$^ 78
0.2
0.3
0.4
Searobin
75.892.0
$2.23
$2.91
$^ 78
169.4
220.5
286.7
Sheepshead
1.0
$2.23
$2.91
$^ 78
0.0
0.0
0.0
Silver perch
70.0
$2.23
$2 91
$^ 78
0.2
0.2
0.3
Spot
21.898.0
$2.23
$2.91
$^ 78
48.9
63.6
82.7
Striped mullet
5,552.0
$2.23
$2.91
$3.78
12.4
16.1
21.0
Total (Other Saltwater)
273,683.0
S2.23
S2.91
S3.78
611.0
795.0
1,034.0
Total (Unidentified)
72,787.0
S2.47
S3.83
S6.18
180.0
279.0
450.0
Total (Undiscounted)
777,488.0
2,085.0
3,613.0
6,461.0
Total (3% discount rate)
1,308.0
2,265.0
4,051.0
Total (7% discount rate)
948.0
1,643.0
2,938.0
Source: U.S. EPA analysis for this report.
July 8, 2014
1-16
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Table 1-19: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities
under Proposal Option 2 in the Gulf of Mexico Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(201 IS, thousands)
5th
Mean
95th
5th
Mean
95th
Mackerels
1.237.0
$3.00
$5.89
$1 1.55
3.7
7.3
14.3
Red drum
26.734.0
$3.00
$5.89
$1 1.55
80.3
157.5
308.7
Spotted sea trout
524.007.0
$3.00
$5.89
$1 1.55
1.573.0
3,086.3
6,050.1
Total (Small Game)
551,978.0
S3.00
S5.89
SI 1.55
1,657.0
3,251.0
6,373.0
Atlantic croaker
191.598.0
$2.23
$2.91
$^ 78
428.1
556.8
723.9
Black drum
941.083.0
$2.23
$2 91
$^ 78
2.102.6
2.734.6
3.555.8
Pinlish
160.133.0
$2.23
$2.91
$^ 78
357.8
465.3
605.0
Sea bass
128.0
$2.23
$2 91
$^ 78
0.3
0.4
0.5
Searobin
1 1 1.200.0
$2.23
$2.91
$^ 78
248.4
323.1
420.2
Sheepshead
28.0
$2.23
$2.91
$^ 78
0.1
0.1
0.1
Silver perch
933.0
$2.23
$2 91
$^ 78
2.1
2.7
3.5
Spot
29.782.0
$2.23
$2.91
$^ 78
66.5
86.5
1 12.5
Striped mullet
33,192.0
$2.23
$2.91
$3.78
74.2
96.5
125.4
Total (Other Saltwater)
1,468,076.0
S2.23
S2.91
S3.78
3,280.0
4,266.0
5,547.0
Total (Unidentified)
117,807.0
S2.47
S3.83
S6.18
291.0
451.0
729.0
Total (Undiscounted)
2,137,861.0
5,228.0
7,968.0
12,649.0
Total (3% discount rate)
3,357.0
5,116.0
8,122.0
Total (7% discount rate)
2,476.0
3,774.0
5,991.0
Source: U.S. EPA analysis for this report.
July 8, 2014
1-17
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Table I-20: Recreational Fishing Benefits from Eliminating Baseline IM&E at Regulated
Facilities in the Gulf of Mexico Region, by Species (2011 $)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(2011S, thousands)
5th
Mean
95th
5th
Mean
95th
Mackerels
1.374.0
$3.00
$5.89
$1 1.55
4.1
8.1
15.9
Red drum
31.1 14.0
$3.00
$5.89
$1 1.55
9 i 4
183.2
359.3
Spotted seatrout
600.729.0
$3.00
$5.89
$1 1.55
1.80^ 5
3,537.7
6.936.8
Total (Small Game)
633,217.0
S3.00
S5.89
SI 1.55
1,901.0
3,729.0
7,312.0
Atlantic croaker
212.766.0
$2.23
$2.91
$^ 78
475 ^
618.2
804.0
Black drum
1.591.629.0
$2.23
$2 91
$^ 78
3.555.8
4.624.9
6.014.2
Pinlish
266.978.0
$2.23
$2.91
$^ 78
596.5
775.8
1.008.8
Sea bass
142.0
$2.23
$2 91
$^ 78
0.3
0.4
0.5
Searobin
135.234.0
$2.23
$2.91
$^ 78
M)2 1
393.0
51 1.0
Sheepshead
47.0
$2.23
$2.91
$^ 78
0.1
0.1
0.2
Silver perch
1.532.0
$2.23
$2 91
$^ 78
3.4
4.5
5.8
Spot
35.1 16.0
$2.23
$2.91
$^ 78
78.5
102.0
132.7
Striped mullet
52,351.0
$2.23
$2.91
$3.78
117.0
152.1
197.8
Total (Other Saltwater)
2,295,795.0
S2.23
S2.91
S3.78
5,129.0
6,671.0
8,675.0
Total (Unidentified)
148,605.0
S2.47
S3.83
S6.18
367.0
569.0
919.0
Total (Undiscounted)
3,077,617.0
7,397.0
10,969.0
16,905.0
Total (3% discount rate)
6,457.0
9,575.0
14,756.0
Total (7% discount rate)
5,955.0
8,831.0
13,610.0
Source: U.S. EPA analysis for this report.
July 8, 2014
1-18
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
1.6 Great Lakes Region
Table 1-21: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities
under Proposal Option 4 in the Great Lakes Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(2011$, thousands)
5th
Mean
95th
5th
Mean
95th
Smallmouth bass
2,314.0
$4.63
$8.95
$17.38
16.7
8,870.0
17,216.0
White bass
632.325.0
$4.63
$8 95
$17.38
4,567.3
8,870.0
17.216.0
Total (liass)
634,639.0
$4.63
S8.95
$17.38
4,584.0
8,870.0
17,216.0
Whitelish
40.464.0
$6.39
$9.87
$15.34
332.0
514.0
799.0
Total (Other Trout)
40,464.0
$6.39
S9.87
$15.34
332.0
514.0
799.0
I Mack crappie
107.0
$0.73
$1 39
$2 61
0.3
0.5
1.0
Bluesiill
1.010.0
$0.73
$1 39
$2 61
2.6
4.9
9.2
Channel cattish
12.995.0
$0.73
$1 39
$2 61
32.9
62.7
1 17.9
Crappie
321.0
$0.73
$1 39
$2 61
0.8
1.5
2.9
Rainbow smelt
4.722.0
$0.73
$1 39
$2 61
12.0
22.8
42.8
Sculpin
197.0
$0.73
$1 39
$2 61
0.5
1.0
1.8
Smelts
8.453.0
$0.73
$1 39
$2 61
21.4
40.8
76.7
Sunlish
676.0
$0.73
$1 39
$2 61
1.7
3.3
6.1
Yellow perch
29.926.0
$0.73
$1 39
$2 61
75.8
144 5
271.6
Total (Panl'Mi)
58,408.0
SO. 73
SI.39
S2.61
148.0
282.0
530.0
Salmon
609.0
$8.53
$13.88
$22.61
8.0
14.0
22.0
Total (Salmon)
609.0
S8.53
S13.88
S22.61
8.0
14.0
22.0
Northern Pike
3.0
$2.28
$4 30
$8 16
0.0
0.0
0.0
Walleve
18.082.0
$2.28
$4 30
$8 16
264.0
497.9
945.8
Total (Walleye/Pike)
18,085.0
S2.28
S4.30
S8.16
264.0
498.0
946.0
Total (Unidentified)
579,751.0
S3.49
S6.51
SI 2.25
3,032.0
5,661.0
10,661.0
Total (Undiscounted)
1,331,956.0
8,370.0
15,838.0
30,174.0
Total (3% discount rate)
7,306.0
13,825.0
26,338.0
Total (7% discount rate)
6,738.0
12,751.0
24,292.0
Source: U.S. EPA analysis for this report.
July 8, 2014
1-19
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Table I-22: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities
under the Final Rule in the Great Lakes Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(2011$, thousands)
5th
Mean
95th
5"'
Mean
95th
Smallmouth buss
2.546.0
$4.63
$8.95
$17.38
1 1.8
6.257.0
12,144.0
White buss
6%. 159.0
$4.63
$8.95
$17.38
3.222.2
6.257.0
12,144.0
Total (liass)
698,705.0
S4.63
S8.95
SI 7.38
3,234.0
6,257.0
12,144.0
Wlutefish
44,532.0
$6.39
$9.87
$15.34
284.0
440.0
683.0
Total (Other Trout)
44,532.0
S6.39
S9.87
$15.34
284.0
440.0
683.0
Black crappie
I I 8.0
$0.73
$1 i9
$2.61
0.1
0.2
0.3
Bluesiill
I.I I2.0
$0.73
$1 i9
$2.61
0.8
1.6
2.9
Channel cattish
14.302.0
$0.73
$1 i9
$2 61
10.4
20.0
37.3
Crappie
362.0
$0.73
$1 i9
$2.61
0.3
0.5
0.9
Rainbow smelt
5.347.0
$0.73
$1 i9
$2 61
3.9
7.5
13.9
Sculpin
224.0
$0.73
$1 i9
$2.61
0.2
0.3
0.6
Smelts
9.303.0
$0.73
$1 i9
$2 61
6.8
13.0
24.2
Sunlish
766.0
$0.73
$1 i9
$2.61
0.6
I.I
2.0
Yellow perch
32.942.0
$0.73
$1 i9
$2 61
24.0
46.0
85.8
Total (Pan fish)
64,475.0
$0.73
SI.39
S2.61
47.0
90.0
168.0
Salmon
67 ID
$8.53
$13.88
$22.61
6.0
9.0
15.0
Total (Salmon)
671.0
S8.53
S13.88
S22.61
6.0
9.0
15.0
Northern Pike
3.0
$2.28
$4 M)
$8.16
0.0
0.0
0.0
Walleye
20.041.0
$2.28
$4 M)
$8.16
46.0
86.0
164.0
Total (Walleye/Pike)
20,044.0
S2.28
S4.30
S8.16
46.0
86.0
164.0
Total (Unidentified)
638,223.0
S3.49
S6.51
SI 2.25
2,224.0
4,153.0
7,821.0
Total (Undiscounted)
1,466,650.0
5,841.0
11,034.0
20,995.0
Total (3% discount rate)
3,793.0
7,166.0
13,636.0
Total (7% discount rate)
2,820.0
5,328.0
10,138.0
Source: U.S. EPA analysis for this report.
July 8, 2014
I-20
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Table I-23: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities
under Proposal Option 2 in the Great Lakes Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(2011$, thousands)
5th
Mean
95th
5"'
Mean
95th
Smallmouth buss
2.902.0
$4.63
$8.95
$17.38
13.4
8.250.0
16,013.0
White buss
918.361 O
$4.63
$8.95
$17.38
4.250.6
8.250.0
16,013.0
Total (liass)
921,263.0
S4.63
S8.95
SI 7.38
4,264.0
8,250.0
16,013.0
Wlutefish
50,757.0
$6.39
$9.87
$15.34
324.0
501.0
779.0
Total (Other Trout)
50,757.0
S6.39
S9.87
$15.34
324.0
501.0
779.0
Black crappie
135.0
$0.73
$1 i9
$2.61
0.1
0.2
0.4
Bluesiill
1.334.0
$0.73
$1 i9
$2.61
1.0
1.8
3.5
Channel cattish
16.552.0
$0.73
$1 i9
$2 61
12.1
22.9
43.3
Crappie
4.373.0
$0.73
$1 i9
$2.61
3.2
6.1
1 1.4
Rainbow smelt
76.779.0
$0.73
$1 i9
$2 61
56.2
106.4
200.7
Sculpin
3.489.0
$0.73
$1 i9
$2.61
2.6
4.8
9.1
Smelts
10.636.0
$0.73
$1 i9
$2 61
7.8
14.7
27.8
Sunlish
10.788.0
$0.73
$1 i9
$2.61
7.9
15.0
28.2
Yellow perch
41.148.0
$0.73
$1 i9
$2 61
30.1
57.0
107.6
Total (Pan fish)
165,234.0
$0.73
SI.39
S2.61
121.0
229.0
432.0
Salmon
910.0
$8.53
$13.88
$22.61
8.0
13.0
21.0
Total (Salmon)
910.0
S8.53
S13.88
S22.61
8.0
13.0
21.0
Northern Pike
5.0
$2.28
$4 M)
$8.16
0.0
0.0
0.0
Walleye
89.320.0
$2.28
$4 M)
$8.16
204.0
384.0
729.0
Total (Walleye/Pike)
89,325.0
S2.28
S4.30
S8.16
204.0
384.0
729.0
Total (Unidentified)
816,530.0
S3.49
S6.51
SI 2.25
2,846.0
5,313.0
10,006.0
Total (Undiscounted)
2,044,018.0
7,766.0
14,690.0
27,978.0
Total (3% discount rate)
4,717.0
8,922.0
16,993.0
Total (7% discount rate)
3,359.0
6,354.0
12,102.0
Source: U.S. EPA analysis for this report.
July 8, 2014
1-21
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Table I-24: Recreational Fishing Benefits from Eliminating Baseline IM&E at Regulated
Facilities in the Great Lakes Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(2011S, thousands)
5th
Mean
95th
5"'
Mean
95th
Smallmouth buss
2.976.0
$4.63
$8.95
$17.38
13.8
8.870.0
17,216.0
White buss
987.522.0
$4.63
$8.95
$17.38
4.570.2
8.870.0
17,216.0
Total (liass)
990,498.0
S4.63
S8.95
SI 7.38
4,584.0
8,870.0
17,216.0
Wlutefish
52,059.0
$6.39
$9.87
$15.34
332.0
514.0
799.0
Total (Other Trout)
52,059.0
S6.39
S9.87
S15.34
332.0
514.0
799.0
Black crappie
138.0
$0.73
$1 i9
$2.61
0.1
0.2
0.4
Bluesiill
1.393.0
$0.73
$1 i9
$2.61
1.0
1.9
3.6
Channel cattish
17.068.0
$0.73
$1 i9
$2 61
12.4
23.7
44.6
Crappie
5.932.0
$0.73
$1 i9
$2.61
4.3
8.2
15.5
Rainbow smelt
104.556.0
$0.73
$1 i9
$2 61
76.2
145.3
273.0
Sculpin
4.759.0
$0.73
$1 i9
$2.61
3.5
6.6
12.4
Smelts
10.921.0
$0.73
$1 i9
$2 61
8.0
15.2
28.5
Sunlish
14.686.0
$0.73
$1 i9
$2.61
10.7
20.4
38.3
Yellow perch
43.518.0
$0.73
$1 i9
$2 61
31.7
60.5
1 13.6
Total (Pan fish)
202,970.0
SO. 73
SI.39
S2.61
148.0
282.0
530.0
Salmon
986.0
$8.53
$13.88
$22.61
8.0
14.0
22.0
Total (Salmon)
986.0
S8.53
S13.88
S22.61
8.0
14.0
22.0
Northern Pike
5.0
$2.28
$4 M)
$8.16
0.0
0.0
0.0
Walleye
I 15.883.0
$2.28
$4 M)
$8.16
264.0
498.0
946.0
Total (Walleye/Pike)
115,889.0
S2.28
S4.30
S8.16
264.0
498.0
946.0
Total (Unidentified)
870,008.0
S3.49
S6.51
SI 2.25
3,032.0
5,661.0
10,661.0
Total (Undiscounted)
2,232,409.0
8,370.0
15,838.0
30,174.0
Total (3% discount rate)
7,306.0
13,825.0
26,338.0
Total (7% discount rate)
6,738.0
12,751.0
24,292.0
Source: U.S. EPA analysis for this report.
July 8, 2014
I-22
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
1.7 Inland Region
Table I-25: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities
under Proposal Option 4 in the Inland Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(2011$, thousands)
5th
Mean
95th
5th
Mean
95th
Smallmouth buss
8.142.0
$4.48
$9.43
$19.96
36.5
76.8
162.5
White buss
5377T2J)
$448
$9 4 1
SFoTh
27070
KiriO
pB
Totai (liass)
545,853.0
S4.48
SlA43
sT'1%
274477F
*5**,**i**4*77(*r*
Whitelisii
ST75*9
$2.96
$5 5^
2.7)
77(7
7*7)
Total (Other Trout)
f,155.0
Sf59
sl%
$5153
w
lo
7*77***
Black bullhead
Htw)
$(05
sTTi
$2720
IT5
23*77*
*4*5****8
Black crappie
rr^oji
$(05
$T7il
sI3()
6.5
13 0
2*5****9
Bluegiii
276i)TFii
$(05
$T7il
$2 20
152.5
305*3
60774
Brown bullhead
I'FJIS
$(05
sTTi
$2 20
2.2
4***4
8*7***
Bullhead
I(>8l(i
$(05
$rrn
$2 20
iO
3*7)*****
5****9
Channel catfish
fxs5>8ji
$(05
$rrn
$2 20
1(74.3
2087s
475****4
Crappie
2Ji7Ii7)7)
$(05
$T7il
$2*20
i773
22.6
*4*4***9
Menhaden
21X0
$(05
sTTi
$2 20
*0.1
0**2
*(*o*
Rainbow smelt
$(05
$rrn
$2 20
1**71*
2.8
5.6
Smelts
FT)
$(05
$rrn
$2 20
*(**)**.**(**)
(77(7
777)
fM3l87i
$(05
sTTi
$2*2()
*8*9***4*
1***787*9****
*3**5*5****9
White Perch
jjuw
$055
$T7il
$2 20
1*7*9
37*7****
7***4
Yellow perch
247.054/)
$055
$T7il
$2 20
1**3(7*5
27*37*3
*5*4*3*76
Total (Pa nll-.ii)
y3y 3y(,
S(l55
sTTi
sl2(i
5mr
U)397f
2,(16777
Salmon
4.0
$8.53
$13.88
$22.61
0.0
0.0
0.0
Total (Salmon)
4.0
S8I53
Sll88
S22.M
0.0
(U)
(777***
American shad
2J22li
$17*6*8
$5 61
$18791)
*3**.**6
1*77*8****
4(7*2
Striped bass
$168
$5 61
$18791)
2*371
76.3
*2**5*8***9
Sturgeon
1547)
$1*768
$5 61
$18791)
(7.3
(7.9
2****9
Total (Small Game)
15^57^
Sl/)8
sIm
sis/Jo
277(7***
*8*97(*r*
30277
Northern pike
25.7)
$27)7
$4 29
$8 92
*(**)**.***i
0*7
(7**2
Saimer
6.672.0
$27)7
$4 29
$8 92
*1*3****9
28.5
*5*9*7;
Walle\e
1 I.I 16.0
$2.07
$4 29
$8 92
23.1
47.4
99.2
Total (Walleye/Pike)
*sXo*7
Sl29
S8/J2
*3*77(7***
*7*670*
1**5*9*77***
Total (Unidentified)
2 ^2^0
sin
S2JI3
slsi
*2,3*1^7***
*4**,*78*I(*r*
9,861(7
Total (i ndiscounteit)
3^571(^0510
*5,*^*777***
row
*212*95*7*)*****
Total (3% discount rate)
3,503.0
7,284.0
15,231.0
Total (7% discount rate)
2,616.0
5,440.0
11,375.0
Source: U.S. EPA analysis for this report.
July 8, 2014
I-23
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Table I-26: Recreational Fishing Benefits from Reducing IM&
under the Final Rule in the Inland Region, by Species (2011$
E at Regulated Facilities
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(2011$, thousands)
5th
Mean
95th
5th
Mean
95th
Smallmouth bass
9,392.0
$4.48
$9.43
$19.96
42.1
88.6
187.4
White bass
560.751.0
$4.48
$9 4 i
$19.96
2.513.9
5.287.5
1 1.191.6
Total (liass)
570,143.0
S4.48
S9.43
SI 9.96
2,556.0
5,376.0
11,379.0
Whilelish
1.401.0
$1.59
$2.96
$5 5^
2.0
4.0
8.0
Total (Other Trout)
1,401.0
$1.59
S2.96
S5.53
2.0
4.0
8.0
Black bullhead
21,509.0
$0.55
$1.11
$2.20
11.9
23.8
47.3
Black crappie
12.888.0
$0.55
$1.11
$2.20
7.1
14.2
28.4
Bluegill
285.614.0
$0.55
$1.11
$2.20
158.0
315.7
628.4
Brown bullhead
4.136.0
$0.55
$1.11
$2.20
2.3
4.6
9.1
Bullhead
2.781.0
$0.55
$1.11
$2.20
1.5
3.1
6.1
Channel catfish
196,096.0
$0.55
$1.11
$2.20
108.5
216.7
431.5
Crappie
23,044.0
$0.55
$1.11
$2.20
12.7
25.5
50.7
Menhaden
220.0
$0.55
$1.11
$2.20
0.1
0.2
0.5
Rainbow smelt
2.683.0
$0.55
$1.11
$2.20
1.5
3.0
5.9
Smelts
1.0
$0.55
$1.11
$2.20
0.0
0.0
0.0
Sunlish
174.183.0
$0.55
$1.11
$2.20
96.3
192.5
383.2
White Perch
3.477.0
$0.55
$1.11
$2.20
1.9
3.8
7.7
Yellow perch
256.905.0
$0.55
$1.11
$2.20
142.1
283.9
565.2
Total (PanMsli)
983,538.0
S0.55
SI.11
S2.20
544.0
1,087.0
2,164.0
Salmon
4.0
$8.53
$13.88
$22.61
0.0
0.0
0.0
Total (Salmon)
4.0
S8.53
S13.88
S22.61
0.0
0.0
0.0
American shad
2.194.0
$1.68
$5.61
$18.90
3.7
12.4
41.5
Striped bass
14.146.0
$1.68
$5.61
$18.90
24.0
79.7
267.4
Sturaeon
167.0
$1.68
$5 61
$18.90
0.3
0.9
3.2
Total (Small Game)
16,507.0
SI.68
S5.61
SI 8.90
28.0
93.0
312.0
Northern pike
26.0
$2.07
$4.29
$8.92
0.1
0.1
0.2
Saimer
7.825.0
$2.07
$4.29
$8.92
16.1
33.8
69.8
Walleve
12.546.0
$2.07
$4 29
$8.92
25.8
54.1
112.0
Total (Walleve/Pike)
20,396.0
S2.07
S4.29
S8.92
42.0
88.0
182.0
Total (Unidentified)
2,139,619.0
SI.13
$2.33
$4.81
2,427.0
4,994.0
10,298.0
Total (Undiscounted)
3,731,608.0
5,599.0
11,642.0
24,343.0
Total (3% discount rate)
3,661.0
7,613.0
15,918.0
Total (7% discount rate)
2,735.0
5,686.0
11,889.0
Source: U.S. EPA analysis for this report.
July 8, 2014
I-24
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Table I-27: Recreational Fishing Benefits from Reducing IM&E at Regulated Facilities
under Proposal Option 2 in the Inland Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(2011S, thousands)
5th
Mean
95th
5th
Mean
95th
Smallmouth bass
141,379.0
$4.48
$9.43
$19.96
633.7
633.7
633.7
White bass
1.286.644.0
$4.48
$9 4 i
$19.96
5.767.3
12.132.1
5.767.3
Total (liass)
1,428,023.0
S4.48
S9.43
SI 9.96
6,401.0
6,401.0
6,401.0
Wluldish
1.688.0
$1.59
$2.96
$5 5^
3.0
3.0
3.0
Total (Other Trout)
1,688.0
SI.59
S2.96
S5.53
3.0
3.0
3.0
Black bullhead
25,487.0
$0.55
$1.11
$2.20
14.1
14.1
14.1
Black crappie
108.409.0
$0.55
$1.11
$2.20
59.9
59.9
59.9
Bluegill
354.207.0
$0.55
$1.11
$2.20
195.8
195.8
195.8
Brown bullhead
1 1.390.0
$0.55
$1.11
$2.20
6.3
6.3
6.3
Bullhead
4.307.0
$0.55
$1.11
$2.20
2.4
2.4
2.4
Channel catfish
348,937.0
$0.55
$1.11
$2.20
192.9
192.9
192.9
Crappie
286,830.0
$0.55
$1.11
$2.20
158.6
158.6
158.6
Menhaden
254.0
$0.55
$1.11
$2.20
0.1
0.1
0.1
Rainbow smelt
7.121.0
$0.55
$1.11
$2.20
3.9
3.9
3.9
Smelts
1.0
$0.55
$1.11
$2.20
0.0
0.0
0.0
Sunlish
I.I 31.661.0
$0.55
$1.11
$2.20
625.6
625.6
625.6
White Perch
4.461.0
$0.55
$1.11
$2.20
2.5
2.5
2.5
Yellow perch
491.893.0
$0.55
$1.11
$2.20
271.9
271.9
271.9
Total (PanMsli)
2,774,958.0
S0.55
SI.11
S2.20
1,534.0
1,534.0
1,534.0
Salmon
4.0
$8.53
$13.88
$22.61
0.0
0.0
0.0
Total (Salmon)
4.0
S8.53
S13.88
S22.61
0.0
0.0
0.0
American shad
2.531.0
$1.68
$5.61
$18.90
4.3
14.2
47.9
Striped bass
16.318.0
$1.68
$5.61
$18.90
27.5
91.5
308.7
Sturaeon
1.294.0
$1.68
$5 61
$18.90
2.2
7.3
24.5
Total (Small Game)
20,143.0
SI.68
S5.61
SI 8.90
34.0
113.0
381.0
Northern pike
29.0
$2.07
$4.29
$8.92
0.1
0.1
0.3
Saimer
133.280.0
$2.07
$4.29
$8.92
276.3
572.0
1,188.8
Walleve
155.606.0
$2.07
$4 29
$8.92
322.6
667.8
1,387.9
Total (Walleve/Pike)
288,916.0
S2.07
S4.29
S8.92
599.0
1,240.0
2,577.0
Total (Unidentified)
5,190,603.0
SI.13
S2.33
S4.81
5,889.0
12,116.0
24,981.0
Total (Undiscounted)
9,704,334.0
14,459.0
30,007.0
62,557.0
Total (3% discount rate)
8,290.0
17,204.0
35,865.0
Total (7% discount rate)
5,726.0
11,883.0
24,773.0
Source: U.S. EPA analysis for this report.
July 8, 2014
I-25
-------
Benefits Analysis for the Final 316(b) Existing Facilities Rule
Appendix I: Details of Recreational Fishing Benefits
Table I-28: Recreational Fishing Benefits from Eliminating Baseline IM&E at Regulated
Facilities in the Inland Region, by Species (2011$)
Species
Annual
Increase in
Recreational
Harvest
(harvestable
adult fish)
Value per Fish
Annual Benefits from Increase
in Recreational Harvest
(2011$, thousands)
5th
Mean
95th
5th
Mean
95th
Smallmouth bass
180,693.0
$4.48
$9.43
$19.96
810.0
1,703.8
3,606.4
White bass
1.567.0580
$4.48
$9 4 i
$19.96
7.025.0
14.776.2
31.276.6
Total (liass)
1,747,751.0
S4.48
S9.43
SI 9.96
7,835.0
16,480.0
34,883.0
Whilelish
1.947.0
$1.59
$2.96
$5 5^
3.0
6.0
1 1.0
Total (Other Trout)
1,947.0
$1.59
S2.96
S5.53
3.0
6.0
11.0
Black bullhead
29,349.0
$0.55
$1.11
$2.20
16.2
32.4
64.6
Black crappie
137.629.0
$0.55
$1.11
$2.20
76.1
152.2
302.9
Bluegill
410.040.0
$0.55
$1.11
$2.20
226.7
453.3
902.4
Brown bullhead
14.007.0
$0.55
$1.11
$2.20
7.7
15.5
30.8
Bullhead
5.099.0
$0.55
$1.11
$2.20
2.8
5.6
1 1.2
Channel catfish
417,819.0
$0.55
$1.11
$2.20
231.0
461.9
919.5
Crappie
365,941.0
$0.55
$1.11
$2.20
202.3
404.6
805.4
Menhaden
291.0
$0.55
$1.11
$2.20
0.2
0.3
0.6
Rainbow smelt
8.741.0
$0.55
$1.11
$2.20
4.8
9.7
19.2
Smelts
1.0
$0.55
$1.11
$2.20
0.0
0.0
0.0
Sunlish
1.430.230.0
$0.55
$1.11
$2.20
790.8
1.581.1
3.147.6
White Perch
5.183.0
$0.55
$1.11
$2.20
2.9
5.7
1 1.4
Yellow perch
592.175.0
$0.55
$1.11
$2.20
327.4
654.7
1.303.3
Total (PanMsli)
3,416,505.0
S0.55
SI.11
S2.20
1,889.0
3,777.0
7,519.0
Salmon
5.0
$8.53
$13.88
$22.61
0.0
0.0
0.0
Total (Salmon)
5.0
S8.53
S13.88
S22.61
0.0
0.0
0.0
American shad
2.905.0
$1.68
$5.61
$18.90
4.9
16.2
54.9
Striped bass
18.729.0
$1.68
$5.61
$18.90
31.4
104.6
354.1
Sturaeon
1.640.0
$1.68
$5 61
$18.90
2.7
9.2
31.0
Total (Small Game)
23,274.0
SI.68
S5.61
SI 8.90
39.0
130.0
440.0
Northern pike
34.0
$2.07
$4.29
$8.92
0.1
0.1
0.3
Saimer
170.509.0
$2.07
$4.29
$8.92
353.4
731.8
1,520.9
Walleve
198.517.0
$2.07
$4 29
$8.92
41 1.5
852.0
1,770.8
Total (Walleve/Pike)
369,060.0
S2.07
S4.29
S8.92
765.0
1,584.0
3,292.0
Total (Unidentified)
6,341,808.0
SI.13
$2.33
$4.81
7,195.0
14,803.0
30,522.0
Total (Undiscounted)
11,900,351.0
17,725.0
36,781.0
76,666.0
Total (3% discount rate)
15,471.0
32,105.0
66,919.0
Total (7% discount rate)
14,270.0
29,611.0
61,722.0
Source: U.S. EPA analysis for this report.
July 8, 2014
I-26
------- |