SC10079
Memorandum
To:
Lynne
Tudor,
Debbi
Hart,
Deborah
Nagle,
and
Tom
Wall,
U.
S.
EPA
From:
Bob
Raucher,
Dave
Cacela,
and
Marca
Hagenstad,
Stratus
Consulting
Inc.

Date:
July
16,
2002
Subject:
Responses
to
Riverkeeper
Questions
on
§
316(
b)
Phase
II
Case
Study
Benefits
Analyses
Tufts
First
Questions
for
EPA:

Q1.
Flow
data:
are
you
able
to
provide
information
on:
a)
water
flow
at
each
of
the
case
study
facilities
and/
or
b)
total
flow
at
all
of
the
facilities
in
each
of
the
five
categories
EPA
uses
in
its
extrapolations
(
non­
gulf
estuary,
gulf
estuary,
rivers,
ocean,
great
lakes)?

Answer:

Sum
of
Operational
Flows
Per
Waterbody
Type
(
MGD)
Estuary/
Tidal
River
(
Non­
Gulf)
39,183
Estuary/
Tidal
River
(
Gulf)
13,793
Freshwater
Systems
144,764
Great
Lakes
4,617
Oceans
13,457
Q2.
Percent
of
losses
valued
in
each
case
study:

a)
In
all
the
case
studies
where
commercial
or
recreational
losses
are
taken
into
account
in
the
final
analysis,
we
would
like
to
know
what
percentage
of
the
age
1
equivalent
fish
lost
to
I&
E
were
assigned
a
monetary
value.
Often
it
seems
that
only
the
fraction
that
would
have
been
caught
by
commercial
or
recreational
fishing
are
valued.
In
some
cases,
this
percentage
is
clear
from
the
information
provided.
In
other
cases,
it
is
ambiguous.

Can
you
tell
us
the
percentage
of
I&
E
losses
that
were
valued
at
each
site?

Answer:
The
following
text
gives
the
percentages
or
references
to
the
§
316(
b)
Phase
II
Case
Study
Document
(
DCN
4­
0003):
°
For
the
Delaware
case
study
analysis,
this
information
is
provided
on
pages
B6­
3
and
B6­
4.
°
For
the
Ohio
River
case
study
analysis,
the
distribution
of
entrainment
losses
by
species
category
are:
forage
fish:
84.21%;
commercial
and
recreational
fish
valued:
0.22%;
and
commercial
and
recreational
fish
unvalued:
15.57%.
The
distribution
of
impingement
Stratus
Consulting
Memorandum
(
7/
3/
2002)

Page
2
SC10079
losses
by
species
category
are:
forage
fish:
97.67%;
commercial
and
recreational
fish
valued:
0.01%;
and
commercial
and
recreational
fish
unvalued:
2.24
%.
°
For
the
Tampa
Bay
case
study
analysis,
this
information
is
provided
on
pages
D6­
3
and
D6­
4.
°
For
the
San
Francisco
Bay
case
study
analysis,
the
distribution
of
impingement
losses
by
species
category
are:
recreational
fish
valued:
8.34%;
recreational
fish
unvalued:
79.53%;
and
special
status
species:
12.13%.
The
distribution
of
entrainment
losses
by
species
category
are:
recreational
fish
valued:
4.72%;
recreational
fish
unvalued:
70.14%;
and
special
status
species
25.14%.
°
For
the
Brayton
Point
Station
case
study
analysis,
this
information
is
provided
on
pages
F6­
4
and
F6­
5.
°
For
the
Seabrook
case
study
analysis,
this
information
is
provided
on
pages
G6­
3
and
G6­
4.
°
For
the
Pilgrim
case
study
analysis,
this
information
is
provided
on
pages
G6­
6
and
G6­
7.
°
For
the
J.
R.
Whiting
case
study
analysis,
this
information
is
provided
on
pages
H6­
3
and
H6­
4.
°
For
the
Monroe
case
study
analysis,
this
information
is
provided
on
pages
I6­
3
and
I6­
4.

b)
In
the
Ohio
River
and
the
Big
Bend
case
studies,
EPA
provides
values
for
"
pounds
of
production
foregone"
and
"
pounds
of
fishery
yield
lost."
Can
you
define
these
terms?
Does
"
pounds
of
production
foregone"
refer
to
the
weight
of
the
total
number
of
year
1
equivalent
fish
lost
through
I&
E,
or
does
it
refer
to
something
else?
Does
"
pounds
of
fishery
yield
lost"
refer
to
the
fraction
of
the
total
losses
to
which
EPA
is
assigning
a
monetary
value?

Answer:
Foregone
production
and
foregone
fishery
yield
are
both
derived
measures
of
resources
that
are
unavailable
due
to
the
fact
that
impingement
or
entrainment
occurred.
In
contrast
to
actual
I&
E
rates,
which
are
direct
measures,
foregone
production
and
foregone
fishery
yield
cannot
be
literally
measured.
Instead,
they
are
derived
from
actual
I&
E
using
modeling
procedures
that
reflect
biological
processes
such
as
growth
and
mortality.

Briefly,
foregone
production
is
the
total
biomass
(
expressed
as
pounds)
that
a
fish
killed
by
I&
E
would
have
produced
in
its
subsequent
lifetime,
had
it
not
been
killed.
The
model
used
to
calculate
foregone
production
includes
consideration
of
both
growth
and
mortality
during
all
life
stages.
Conceptually,
the
biomass
that
is
considered
is
accumulated
at
all
life
stages
subsequent
to
the
time
of
death.

Briefly,
foregone
fishery
yield
is
an
estimate
of
fish
harvest
(
expressed
in
pounds
of
as
numbers
of
individuals)
that
would
have
occurred
at
some
time
in
the
future,
had
I&
E
not
occurred.
The
model
used
to
calculate
foregone
fishery
yield
considers
natural
(
non­
fishing)
mortality
rates,
fishing
mortality
rates,
and
the
weight
(
as
pounds)
of
harvested
fish.
Stratus
Consulting
Memorandum
(
7/
3/
2002)

Page
3
SC10079
The
metric
"
age
1
equivalent"
is
also
a
derived
measure
of
fish
that
are
"
absent"
at
a
future
time
due
to
the
fact
that
impingement
or
entrainment
occurred.
As
a
general
rule,
most
fish
killed
by
I&
E
are
less
than
1
year
old.
The
metric
age
1
equivalent
depicts
the
numbers
of
fish
killed
by
I&
E
that
would
have
survived
until
they
reached
age
1
by
considering
mortality
rates
of
young
fish.
The
metric
is
in
terms
of
numbers
of
fish
(
not
pounds).

Although
these
three
metrics
share
some
conceptual
similarities,
they
are
not
strictly
dependent
on
each
other.
In
particular,
neither
foregone
production
nor
foregone
fishery
yield
is
derived
from
the
estimate
of
age
1
equivalent
losses.

Age
1
equivalents,
foregone
production
and
foregone
fishery
yield
are
all
formally
defined
in
Chapter
A5
of
the
Case
Study
Document
(
docket
number
DCN4
­
0003).
Please
refer
to
this
chapter
for
a
more
complete
discussion.

EPA's
monetary
valuation
of
losses
involves
consideration
of
foregone
fishery
yield,
which
is
the
major
driving
factor
for
scaling
the
economic
losses.
All
of
the
losses
that
EPA
has
quantified
flow
from
the
estimates
of
foregone
fishery
yield,
but
the
economic
benefits
include
disparate
kinds
of
economic
benefits
such
as
the
dockside
value
of
commercially
harvested
fish,
the
revealed
value
recreation
fishing
experiences,
consumer
surplus
derived
from
fishing
activities,
and
non­
use
values.

c)
On
p.
D4­
4,
tables
D4­
5
and
D4­
6,
EPA
lists
losses
in
pounds,
then
multiplies
these
losses
by
a
value
per
fish
to
obtain
total
valued
losses.
There
appears
to
be
an
error
in
these
tables,
perhaps
only
in
labelling:
either
the
losses
are
actually
numbers
of
fish
(
not
pounds),
or
the
values
are
actually
values
per
pound
(
not
per
fish).
If
the
figures
in
both
of
these
columns
are
correct,
then
the
figures
in
the
final
column
are
wrong,
because
they
are
the
product
of
"
pounds
of
fish"
multiplied
by
"
value
per
fish."
Can
you
clarify
the
calculations
in
these
tables?

Answer:
The
relevant
column
heading
in
Tables
D4­
5
and
D4­
6
should
read
"
Commercial
Value/
lb"
instead
of
"
Commercial
Value/
Fish."

d)
Also
on
p.
D4­
4,
in
a
footnote
to
table
D4­
6,
EPA
notes
that
the
value
of
black
drum
entrainment
losses
is
capped
at
$
137,756,
a
small
fraction
of
the
value
that
would
be
calculated
without
the
cap.
What
is
the
rationale
for
setting
a
cap
on
this
number?
Were
similar
caps
applied
to
calculated
values
elsewhere
in
the
analysis
of
this
or
other
case
studies?

Answer:
To
represent
realistic
losses
to
the
commercial
fishery,
it
was
decided
to
cap
the
losses
of
black
drum
at
double
the
landings
when
the
black
drum
fishery
was
healthy.
This
was
the
only
case
in
which
estimated
impingement
and
entrainment
losses
appeared
unreasonably
high,
and
therefore
this
was
not
done
in
other
case
studies.
This
step
was
taken
in
the
Tampa
Bay
case
study
because
of
the
unique
features
we
noticed
in
the
Tampa
Bay
fish
community.
Stratus
Consulting
Memorandum
(
7/
3/
2002)

Page
4
SC10079
Q3.
Values
chosen
as
"
baseline"
for
extrapolations:

What
is
the
rationale
for
using
HRC
values
as
the
basis
for
extrapolations
for
the
ocean
and
great
lake
categories,
while
using
the
midpoint
between
the
high
and
low
cost
estimates
for
other
categories
where
HRC
analysis
was
conducted?
Why
were
HRC
figures
not
used
in
all
cases
where
they
were
available,
if
EPA
considers
them
more
indicative
of
true
costs
than
the
figures
obtained
through
other
methodologies?

Answer:
See
Federal
Register
Tuesday,
April
9,
2002
/
Vol.
67,
No.
68
/
page
17205,
for
explanation.
The
following
paragraph
is
an
excerpt
from
this
citatation:
"
For
oceans
and
the
Great
Lakes,
EPA
developed
national­
scale
estimates
using
its
HRC­
based
loss
estimates,
because
EPA
was
able
to
develop
HRC
estimates
for
these
sites,
and
because
these
HRC
values
are
more
comprehensive
than
the
values
derived
using
the
more
traditional
benefits
transfer
approach.
The
HRC
estimates
cover
losses
for
a
much
larger
percentage
of
fish
lost
due
to
impingement
and
entrainment,
whereas
the
benefits
transfer
approach
addressed
losses
only
for
a
small
share
of
the
impacted
fish.
Since
recreational
fish
impacts
were
an
extremely
small
share
of
the
total
fish
impacts
at
these
sites,
EPA
extrapolated
the
HRC
findings
using
only
the
MGD­
based
index
(
i.
e.,
the
angler­
based
index
was
not
relevant)."
