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

Date:
July
3,
2002
Subject:
Responses
to
Riverkeeper
Questions
on
§
316(
b)
Phase
II
Case
Study
Benefits
Analyses
Tufts
Questions
for
EPA:

Q1.
The
costs
and
benefits
of
the
policy
options
presented
on
p.
D1­
4
of
the
EBA
do
not
correspond
to
the
costs
and
benefits
of
the
options
described
in
the
Federal
Register.
Please
provide
an
explanation
of
the
conversion
of
EBA
options
and
their
costs
and
benefits
into
the
options,
and
costs
and
benefits,
cited
in
the
Federal
Register.

Answer:
The
benefits
differ
between
the
Preamble
and
the
EBA
because
the
benefits
in
the
Preamble
were
not
sample
weighted
in
the
same
manner
as
the
costs
were.
The
benefits
in
the
Preamble
are
for
539
in­
scope
facilities,
while
the
corrected
benefits
in
the
EBA
are
for
550
inscope
facilities.

The
costs
of
the
policy
options
presented
in
the
Preamble
are
total
private
(
post­
tax)
costs.
They
correspond
to
the
costs
presented
in
Part
B
of
the
EBA.
The
costs
presented
on
page
D1­
4
of
the
EBA
are
total
social
(
pre­
tax)
costs.
Table
D1­
2
on
page
D1­
3
presents
a
comparison
between
the
total
private
(
post­
tax)
costs
and
the
total
social
(
pre­
tax)
costs
of
the
different
policy
options
analyzed.

Q2.
Please
provide
a
summary
of
the
facilities
that
replied
to
the
questionnaire,
showing
which
facilities
have
provided
flow
data
that
is
not
confidential.

Answer:

Q3.
Provide
total
flow
data
for
all
in­
scope
facilities
on
each
water
body
type.

Answer:

Q4.
Provide
a
sensitivity
analysis
showing
the
results
if
all
impinged
and
entrained
fish
were
valued,
rather
than
just
those
that
would
have
been
landed.
Please
provide
electronic
copies
of
the
spreadsheets
used
for
this
analysis.

Answer:
Stratus
Consulting
Memorandum
(
7/
3/
2002)

Page
2
SC10079
Q5.
Provide
information
on
the
percentage
of
impinged
and
entrained
fish
that
were
valued
in
the
Ohio
River
case
study,
comparable
to
the
information
provided
for
other
case
studies.

Answer:
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
losses
by
species
category
are:
forage
fish:
97.67%;
commercial
and
recreational
fish
valued:
0.01%;
and
commercial
and
recreational
fish
unvalued:
2.24
%.

Q6.
The
two
San
Francisco
area
case
studies
valued
only
striped
bass
and
special
status
(
threatened
and
endangered)
species.
Were
there
other
species
for
which
the
data
allowed
valuation
at
either
Pittsburg
or
Contra
Costa?
If
so,
please
list
the
species
and
provide
summary
data
on
these
species.

Answer:
Records
of
impingement
and
entrainment
losses
at
Contra
Costa
and
Pittsburg
were
reported
in
Ecological
Analysts,
Inc.
(
1981a
and
1981b)
and
Southern
Energy
Delta,
LLC
(
2000).
EPA's
analysis
focused
on
losses
of
striped
bass
and
special
status
species,
because
the
losses
of
the
other
species
were
only
a
small
fraction
of
the
total
losses.
Tables
1
through
4
present
all
the
records
of
the
losses
available
in
these
documents.

Q7.
On
p.
D4­
4
of
the
case
studies,
Tables
D4­
5
and
D4­
6,
EPA
lists
losses
in
pounds,
then
multiplies
these
losses
by
a
value
per
fish
(
rather
than
per
pound)
to
obtain
total
valued
losses.
Please
clarify
the
error
involved
and
provide
a
correctly
labeled
version
of
these
tables.

Answer:
The
relevant
column
heading
in
Tables
D4­
5
and
D4­
6
should
read
"
Commercial
Value/
lb"
instead
of
"
Commercial
Value/
Fish."
Stratus
Consulting
Memorandum
(
7/
3/
2002)

Page
3
SC10079
Table
1.
Facility
estimates
of
annual
impingement
(
numbers
of
organisms)
at
the
Pittsburg
facility.

Year
Chinook
salmon
Delta
smelt
Green
sturgeon
Longfin
smelt
Sacramento
splittail
Starry
flounder
Steelhead
Striped
bass
Threadfin
shad
Unidentifi
ed
Yellowfin
goby
1978­
1979
808
14,107
0
137,261
8,732
11,856
0
111,299
88,865
12,278
31,519
Avg.
1987­
1990
106
283
0
12,677
212
NA
0
NA
NA
NA
NA
Mean
457
7,195
0
74,969
4,472
11,856
0
111,299
88,865
12,278
31,519
Minimum
106
283
0
12,677
212
11,856
0
111,299
88,865
12,278
31,519
Maximum
808
14,107
0
137,261
8,732
11,856
0
111,299
88,865
12,278
31,519
SD
496
9,775
0
88,094
6,025
NA
0
NA
NA
NA
NA
Total
914
14,390
0
149,938
8,944
11,856
0
111,299
88,865
12,278
31,519
Table
2.
Facility
estimates
of
annual
entrainment
(
numbers
of
organisms)
at
the
Pittsburg
facility.

Year
American
shad
Chinook
salmon
Cyprinidae
Delta
smelt
Gobiidae
Green
sturgeon
Longfin
smelt
Northern
anchovy
Pacific
herring
1978­
1979
170,000
23,598
30,000
65,839,484
4,070,000
0
190,229
5,200,000
22,110,000
Avg.
1987­
1990
NA
0
NA
1,680,187
NA
0
232,641
NA
NA
Mean
170,000
11,799
30,000
33,759,836
4,070,000
0
211,435
5,200,000
22,110,000
Minimum
170,000
0
30,000
1,680,187
4,070,000
0
190,229
5,200,000
22,110,000
Maximum
170,000
23,598
30,000
65,839,484
4,070,000
0
232,641
5,200,000
22,110,000
SD
NA
16,686
NA
45,367,474
NA
0
29,990
NA
NA
Total
170,000
23,598
30,000
67,519,671
4,070,000
0
422,870
5,200,000
22,110,000
Table
2.
Facility
estimates
of
annual
entrainment
(
numbers
of
organisms)
at
the
Pittsburg
facility
(
cont.).

Year
Prickly
sculpin
Sacramento
splittail
Starry
flounder
Steelhead
Striped
bass
Threadfin
shad
Unidentified
Yellowfin
goby
Stratus
Consulting
Memorandum
(
7/
3/
2002)

Page
4
SC10079
1978­
1979
29,610,000
155,289
0
0
284,370,000
670,000
66,811,113
6,070,000
Avg.
1987­

1990
NA
336,037
NA
0
NA
NA
NA
NA
Mean
29,610,000
245,663
0
0
284,370,000
670,000
66,811,113
6,070,000
Minimum
29,610,000
155,289
0
0
284,370,000
670,000
66,811,113
6,070,000
Maximum
29,610,000
336,037
0
0
284,370,000
670,000
66,811,113
6,070,000
SD
NA
127,808
NA
0
NA
NA
NA
NA
Total
29,610,000
491,326
0
0
284,370,000
670,000
66,811,113
6,070,000
Table
3.
Facility
estimates
of
annual
entrainment
(
numbers
of
organisms)
at
the
Contra
Costa
facility.

Year
American
shad
Bigscale
logperch
Catfish
family
Chinook
salmon
Delta
smelt
Gobiidae
Green
sturgeon
Hitch
Longfin
smelt
Northern
anchovy
Pacific
herring
Prickly
sculpin
1978­
1979
75,000
295,000
80,000
10,318
21,755,741
230,000
0
110,000
0
31,400
170,000
24,800,000
Avg.
1987­

1990
NA
NA
NA
0
1,565,933
NA
0
NA
71,179
NA
NA
NA
Mean
75,000
295,000
80,000
5,159
11,660,837
230,000
0
110,000
35,590
31,400
170,000
24,800,000
Minimum
75,000
295,000
80,000
0
1,565,933
230,000
0
110,000
0
31,400
170,000
24,800,000
Maximum
75,000
295,000
80,000
10,318
21,755,741
230,000
0
110,000
71,179
31,400
170,000
24,800,000
SD
NA
NA
NA
7,296
14,276,350
NA
0
NA
50,331
NA
NA
NA
Total
75,000
295,000
80,000
10,318
23,321,674
230,000
0
110,000
71,179
31,400
170,000
24,800,000
Stratus
Consulting
Memorandum
(
7/
3/
2002)

Page
5
SC10079
Table
3.
Facility
estimates
of
annual
entrainment
(
numbers
of
organisms)
at
the
Contra
Costa
facility
(
cont.).

Year
Sacramento
splittail
Starry
flounder
Steelhead
Striped
bass
Sunfish
family
Threadfin
shad
Unidentified
White
catfish
Yellowfin
goby
1978­
1979
189,659
630,000
0
81,000,000
240,000
17,660,000
27,543,623
440,000
6,170,000
Avg.
1987­
1990
94,905
NA
0
NA
NA
NA
NA
NA
NA
Mean
142,282
630,000
0
81,000,000
240,000
17,660,000
27,543,623
440,000
6,170,000
Minimum
94,905
630,000
0
81,000,000
240,000
17,660,000
27,543,623
440,000
6,170,000
Maximum
189,659
630,000
0
81,000,000
240,000
17,660,000
27,543,623
440,000
6,170,000
SD
67,001
NA
0
NA
NA
NA
NA
NA
NA
Total
284,564
630,000
0
81,000,000
240,000
17,660,000
27,543,623
440,000
6,170,000
Table
4.
Facility
estimates
of
annual
impingement
(
numbers
of
organisms)
at
the
Contra
Costa
facility.

Year
American
shad
Chinook
salmon
Delta
smelt
Green
sturgeon
Longfin
smelt
Sacramento
splittail
Steelhead
Striped
bass
Threadfin
shad
Unidentified
White
catfish
Yellowfin
goby
1978­
1979
19,602
1,083
8,253
0
19,475
12,455
38
136,149
107,228
9,376
5,868
14,830
Avg.
1987­

1990
NA
0
942
0
336
889
0
NA
NA
NA
NA
NA
Mean
19,602
542
4,598
0
9,906
6,672
19
136,149
107,228
9,376
5,868
14,830
Minimum
19,602
0
942
0
336
889
0
136,149
107,228
9,376
5,868
14,830
Maximum
19,602
1,083
8,253
0
19,475
12,455
38
136,149
107,228
9,376
5,868
14,830
SD
NA
766
5,170
0
13,533
8,178
27
NA
NA
NA
NA
NA
Total
19,602
1,083
9,195
0
19,811
13,344
38
136,149
107,228
9,376
5,868
14,830
Stratus
Consulting
Memorandum
(
7/
3/
2002)

Page
6
SC10079
Q8.
The
calculation
for
black
drum
on
case
study
p.
D4­
4,
footnote
to
Table
D4­
6,
rejects
the
reported
data
and
substitutes
a
much
lower
judgmental
alternative.
Please
provide
a
narrative
explanation
of
the
basis
for
this
alternative.
Were
similar
alternatives
used
in
place
of
observed
data
at
any
other
points
in
the
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.

Q9.
Please
provide
any
recent
studies
of
nonuse
values
that
support
or
conflict
with
the
50%
rule
used
to
estimate
these
values
in
the
EBA.

Answer:
Brown.
T.
1993.
"
Measuring
Non­
use
Value:
A
Comparison
of
Recent
Contingent
Valuation
Studies."
In
Bergstrom
J.
C.,
Benefits
and
Costs
Transfer
in
Natural
Resource
Planning.
Sixth
Interim
Report,
University
of
Georgia,
Department
of
Agricultural
and
Applied
Economics;
Athens,
GA.

Q10.
Describe
any
alternative
approaches
to
nonuse
values
that
were
considered
in
the
preparation
of
the
EBA,
and
explain
why
these
approaches
were
rejected.

Answer:
In
the
absence
of
empirical
data,
one
approach
is
to
describe
the
nonuse
values
qualitatively,
and
not
include
a
quantitative
value.
Another
option
that
is
often
used
to
value
nonuse
changes
is
to
apply
willingness­
to­
pay
(
WTP)
values
by
household.
However,
it
would
be
difficult
to
find
studies
or
to
conduct
original
research
to
estimate
a
household
WTP
for
reductions
in
impingement
and
entrainment.
It
would
also
be
difficult
to
determine
the
number
of
households
in
the
relevant
market
to
apply
the
WTP
amounts
to.
We
believe
the
50%
rule
provides
an
acceptable
though
very
conservative
estimate
of
nonuse
value,
which
probably
understates
true
values.

Q11.
Regarding
the
flow
chart
summarizing
Pittsburg/
Contra
Costa
case
study
data,
p.
E6­
2,
please
clarify
the
apparent
transposition
of
impingement
vs.
entrainment
data
between
boxes
3
and
4,
and
between
boxes
2
and
5.
Did
this
error
affect
any
later
calculations?
Please
provide
corrected
versions
of
the
flow
chart
and
any
other
calculations
affected
by
this
error.

Answer:
In
boxes
4
and
5
of
Figure
E6­
1,
the
impingement
and
entrainment
numbers
are
switched
due
to
a
clerical
error.
Box
4
should
read
"
I:
27,200
(
11,600
lb)"
and
"
E:
185,100
(
79,000
lb).
Box
5
should
read
"
I:
145,00
fish"
and
"
E:
145,000
fish."
The
dollar
values
stated
in
the
boxes
are
correct
as
they
read.
This
clerical
error
did
not
affect
any
calculations.
Stratus
Consulting
Memorandum
(
7/
3/
2002)

Page
7
SC10079
Q12.
The
value
of
forage
fish
(
per
fish)
in
the
Monroe
case
study
appears
to
be
orders
of
magnitude
larger
than
in
other
case
studies.
Please
explain
the
difference.
Are
there
other
case
studies
or
plants
where
the
higher
forage
value
seen
at
Monroe
would
be
appropriate?

Answer:
The
value
of
entrained
forage
fish
from
the
Monroe
case
study
was
estimated
to
average
$
2.00
per
fish,
using
the
methods
presented
in
Section
A5­
3
of
Chapter
A5
of
Part
A
of
the
§
316(
b)
Phase
II
Case
Study
Document
(
DCN
4­
0003).
This
is
much
higher
than
the
per
fish
values
obtained
for
impinged
fish
at
Monroe
and
for
both
impinged
and
entrained
fish
in
the
other
case
studies.
We
will
look
into
the
cause
for
this
difference.

Q13.
Entrainment
kills
many
more
fish
than
impingement
at
most
case
study
facilities,
but
the
reverse
is
true
(
that
is,
impingement
kills
more
year
1
equivalent
fish
than
entrainment)
at
Monroe
and
Whiting.
What
accounts
for
this
difference?

Answer:
EPA
does
not
consider
question
#
13
to
be
a
question
about
methodology,
and
therefore
does
not
respond
here.

Q14.
Please
provide
a
list
of
all
the
endangered
species
known
to
be
affected
by
each
of
the
case
study
facilities,
and
describe
any
attempts
EPA
made
to
calculate
the
value
of
losses
of
these
species.

Answer:
EPA
does
not
have
a
list
of
endangered
species
known
to
be
affected
at
each
of
the
case
study
facilities.
This
information
is
not
readily
available.

Literature
Cited
Southern
Energy
Delta,
LLC.
2000.
Multispecies
Habitat
Conservation
Plan,
Pittsburg
and
Contra
Costa
Power
Plants.
Draft­
Revision
5,
June
30,
2000.
Prepared
for
the
U.
S.
Fish
&
Wildlife
Service,
Sacramento,
CA,
and
the
National
Marine
Fisheries
Service,
Santa
Rosa,
CA.

Ecological
Analysts,
Inc.
1981b.
Pittsburg
Power
Plant
Cooling
Water
Intake
Structures
316b
Demonstration.
Prepared
for
PG&
E.

Ecological
Analysts,
Inc.
1981a.
Contra
Costa
Power
Plant
Cooling
Water
Intake
Structures
316b
Demonstration.
Prepared
for
PG&
E.
