1
CWA
SECTION
316(
b)
PHASE
II
&
III
COOLING
WATER
INTAKE
STRUCTURE
REGULATIONS
PEER
REVIEW
PLAN
October
2003
Revised
November
2004
I.
Introduction
As
required
by
a
consent
decree
in
Riverkeeper
v.
Leavitt,
EPA
is
developing
regulations
under
section
§
316(
b)
of
the
Clean
Water
Act.
Section
316(
b)
of
the
CWA
provides
that
any
standard
established
pursuant
to
section
301
or
306
of
the
CWA
and
applicable
to
a
point
source
must
require
that
the
location,
design,
construction,
and
capacity
of
cooling
water
intake
structures
reflect
the
best
technology
available
(
BTA)
for
minimizing
adverse
environmental
impact.
The
Phase
II
rule
establishes
requirements
at
existing
power
generating
facilities
that
withdraw
at
least
fifty
(
50)
MGD
of
cooling
water
from
waters
of
the
U.
S.
More
than
550
permitted
steam
electric
power
plants
that
generate
or
transmit
electric
power
use
large
volumes
of
cooling
water
from
lakes,
rivers,
estuaries,
or
oceans
to
cool
their
plants.
Phase
III
regulations
are
being
proposed
that
would
establish
requirements
at
existing
manufacturing
facilities
that
withdraw
greater
than
50
MGD
on
all
waterbodies,
200
MGD
on
all
waterbodies,
and
100
on
certain
waterbodies.
At
most,
approximately
136
manufacturing
facilities
would
be
covered
by
the
proposed
Phase
III
regulations.
The
100
MGD
on
certain
waterbodies
option
would
only
cover
19
facilities.
Cooling
water
intake
structures
cause
adverse
environmental
impact
by
pulling
large
numbers
of
fish
and
shellfish
or
their
eggs
into
a
power
plant's
or
factory's
cooling
system.
There,
the
organisms
may
be
killed
or
injured
by
heat,
physical
stress,
or
by
chemicals
used
to
clean
the
cooling
system.
Larger
organisms
may
be
killed
or
injured
when
they
are
trapped
against
screens
at
the
front
of
an
intake
structure.
EPA
published
final
regulations
for
large
existing
power
plants
on
July
9,
2004.
Proposed
regulations
are
required
to
be
signed
by
the
Administrator
by
November
1,
2004.
This
peer
review
plan
seeks
to
identify
key
scientific
and
technical
work
products
associated
with
the
Phase
II
and
Phase
III
rulemaking
efforts
and
document
the
level
of
review
and
scrutiny
that
these
products
have
undergone.
These
rules
are
being
included
under
the
cover
of
a
single
peer
review
plan
because
they
both
cover
existing
facilities
that
use
cooling
water
intake
structures.
These
cooling
water
intake
structures
are
similar
in
design
and
function
and
the
proposed
Phase
III
regulation
will
share
the
same
regulatory
framework,
as
applicable.

Legal
Authority.
The
Phase
II
rulemaking
partially
fulfills
EPA's
obligation
to
comply
with
an
Amended
Consent
Decree.
The
Amended
Consent
Decree
was
filed
on
November
22,
2000,
in
the
United
States
District
Court,
Southern
District
of
New
York,
in
Riverkeeper
Inc.,
et
al.
v.
Whitman,
No.
93
Civ
0314
(
AGS),
a
case
brought
against
EPA
by
a
coalition
of
individuals
and
environmental
groups.
The
original
Consent
Decree,
filed
on
October
10,
1995,
provided
that
EPA
was
to
propose
regulations
implementing
section
316(
b)
by
July
2,
1999,
and
take
final
action
with
respect
to
those
regulations
by
August
13,
2001.
Under
subsequent
interim
orders
and
2
the
Amended
Consent
Decree,
EPA
has
divided
the
rulemaking
into
three
phases
and
is
working
under
new
deadlines.
The
Amended
Consent
Decree
required
that
EPA
issue
a
proposed
rule
for
Phase
II
existing
facilities
by
February
28,
2002,
and
take
final
action
by
February
16,
2004.
The
final
section
316(
b)
Phase
II
rule
was
published
on
July
9,
2004
(
69
FR
41576)
and
issued
under
the
authority
of
sections
101,
301,
304,
306,
308,
316,
401,
402,
501,
and
510
of
the
Clean
Water
Act
(
CWA),
33
U.
S.
C.
1251,
1311,
1314,
1316,
1318,
1326,
1341,
1342,
1361,
and
1370.
The
Amended
Consent
Decree
required
that
EPA
issue
proposed
rule
for
Phase
III
facilities
by
November
1,
2004
and
take
final
action
by
June
1,
2006.
The
Phase
III
rule
would
be
issued
under
the
same
authorities
as
the
Phase
II
rule.

Agency
Priority.
The
Phase
II
rule
was
a
major
rulemaking
effort
anticipated
to
result
in
annual
costs
exceeding
$
100
million.
The
proposed
Phase
III
rule
was
a
major
rulemaking
effort
that
is
anticipated
to
result
in
compliance
costs
between
$
53
and
$
21
million
depending
on
the
regulatory
option.
They
are
both
classified
as
Tier
1
rules
and
as
such,
are
considered
a
priority
action
for
the
Administrator,
requiring
active
involvement
by
the
Office
of
the
Administrator
and
extensive
cross­
Agency
participation
by
other
core
EPA
offices,
including
the
Office
of
Research
and
Development
(
ORD),
Office
of
General
Counsel
(
OGC),
Office
of
Policy,
Economics,
and
Innovation
(
OPEI),
Office
of
Enforcement
and
Compliance
Assurance
(
OECA),
and
EPA
Regional
Offices
(
Regions
I,
II,
III,
IV,
V,
VI,
VII,
VIII,
and
IX..

Agency
Policies
and
Guidance
on
Information
Quality.
The
following
section
lists
three
ongoing
Agency
policies
and
guidance
related
to
standards
for
information
quality
and
describes
the
general
process
by
which
section
316(
b)
scientific
and
technical
products
were
deemed
to
be
compliant
with
these
policies
and
guidance.
In
October
2002,
the
EPA
published
"
Guidelines
for
Ensuring
and
Maximizing
the
Quality,
Objectivity,
Utility,
and
Integrity
of
Information
Disseminated
by
EPA"
(
Information
Quality
Guidelines;
IQG).
The
information
disseminated
in
conjunction
with
this
rulemaking
is
considered
"
influential"
under
the
Information
Quality
Guidelines
in
that,
because
it
supports
priority,
Tier
1
rulemakings.
In
addition,
these
rules
will
have
or
do
have
a
clear
and
substantial
impact
on
important
public
policies
or
private
sector
decisions.
According
to
the
IQG,
influential
information
should
be
subject
to
a
higher
degree
of
quality
and
the
data
and
methods
used
should
be
extremely
transparent
and
easily
reproduced
by
qualified
parties.
Section
III
(
QA
Reviews)
of
this
plan
describes
the
numerous
reviews
of
modeling
results,
costing
and
benefit
analyses,
and
other
methodologies
utilized
as
part
of
these
rulemaking
efforts
that
were
conducted
by
EPA,
other
Federal
agencies,
and
the
public.

The
EPA
Peer
Review
Handbook,
2nd
edition,
was
published
in
December
2000
as
guidance
for
implementing
the
Peer
Review
Policy
statement
issued
by
the
Administrator
in
1994.
In
essence,
the
Peer
Review
Policy
requires
that
major
scientific
and
technical
work
products
related
to
Agency
decisions
normally
should
be
peer
reviewed.
The
handbook
further
elaborates
on
the
role
of
peer
review
within
the
regulatory
development
process
and
specifies
criteria
for
determining
whether
or
not
a
scientific/
technical
work
product
is
considered
"
major."
According
to
the
Handbook,
products
that
are
used
to
support
a
regulatory
program
that
meet
one
or
more
of
the
following
criteria,
are
candidates
for
peer
review:
3
1)
Establishes
a
significant
precedent,
model,
or
methodology;
2)
Addresses
significant
controversial
issues;
3)
Focuses
on
significant
emerging
issues;
4)
Has
significant
cross­
Agency/
inter­
agency
implications;
5)
Considers
an
innovative
approach
for
a
previously
defined
problem/
process/
methodology;
or
6)
Satisfies
a
statutory
or
other
legal
mandate
for
peer
review.

Section
II
below
documents
the
decision­
making
process
for
those
major
Phase
II
and
Phase
III
work
products
that
were
or
will
be
peer
reviewed
as
well
as
the
decisions
and
rationale
for
not
peer
reviewing
other
major
products
associated
with
this
rulemaking.

The
EPA
Office
of
Water
Quality
Policy
requires
that
the
quality
of
any
environmental
data
or
information
used
by
the
Office
of
Water
must
be
assessed
(
known)
and
documented,
regardless
of
the
source.
The
policy
further
requires
that
all
environmental
decisions
made
by
the
Office
of
Water
must
be
evaluated
relative
to
the
quality
of
the
underlying
data
and
information
and
these
evaluations
must
be
documented.
Sections
III
(
QA
Reviews)
and
IV
(
Peer
Input)
document
the
quality
of
the
data
used
in
the
section
316(
b)
rulemaking
process.

II.
Decisions
and
Products
This
section
documents
decisions
made
throughout
the
Phase
II
and
Phase
III
rulemaking
process
concerning
identification
of
major
scientific/
technical
products
and
whether
or
not
those
products
merited
peer
review.
As
previously
mentioned,
the
Science
Policy
Council
Peer
Review
Handbook
(
2000)
specifies
among
other
criteria
that
major
scientific
and/
or
technical
works
that
establish
significant
precedents,
address
controversial
issues,
focus
on
significant
emerging
issues,
involve
significant
investment
of
Agency
resources,
or
consider
innovative
approaches
be
subject
to
external
peer
review.
The
Phase
II
effort
involved
development
of
technology­
based
performance
standards
that
will
minimize
the
environmental
impacts
of
cooling
water
withdrawals
from
large,
existing
power
generating
facilities.
The
intent
of
the
rule
is
to
require
that
many
of
these
large
existing
facilities
install
specified
technologies
that
will
reduce
the
number
of
impinged
or
entrained
organisms.
Technology
installation
retrofits
including
potential
re­
location
of
facility
cooling
water
intake
structures
can
be
costly
and
may
require
facility
down
time.
For
these
reasons
among
others,
the
regulated
industry
as
well
as
the
Department
of
Energy
(
DOE)
are
paying
close
attention
to
the
development
of
this
rule.
Further,
the
issuance
of
presidential
Executive
Order
13211:
Actions
that
Significantly
Affect
Energy
Supply,
Distribution,
or
Use
has
led
to
additional
scrutiny
by
the
Office
of
Management
and
Budget
(
OMB)
to
verify
that
any
regulatory
action
associated
with
the
rule
will
not
result
in
"
significant
energy
actions."
The
proposed
Phase
III
regulations
use
the
same
performance
standards
and
use
the
same
regulatory
structure
and
compliance
actions
as
the
Phase
II
regulations.
All
of
these
factors
contribute
to
the
controversial
nature
of
the
Phase
II
and
Phase
III
regulations.
Throughout
the
Phase
II
and
proposed
Phase
III
regulatory
development
process,
a
major
focus
has
been
on
determining
and
accurately
quantifying
the
costs
and
benefits
associated
with
4
the
rules.
Because
the
engineering
costing
and
economic
analysis
methodologies
are
relatively
standardized,
greater
emphasis
has
been
placed
on
examining
the
more
innovative
and
potentially
precedent­
setting
benefits
methodologies.
The
following
four
sections
identify
(
1)
a
cumulative
list
of
all
externally
peer
reviewed
products
from
1991
to
present,
(
2)
Phase
II
scientific/
technical
products
that
have
been
peer
reviewed,
(
3)
Phase
III
candidate
scientific/
technical
products
for
future
external
review,
and
(
3)
scientific
/
technical
products
for
which
a
decision
was
made
to
not
undergo
peer
review..

Cumulative
list
of
externally
peer
reviewed
products
from
1991
to
present.
The
following
describes
a
critical
benefits
model
that
was
externally
peer
reviewed
prior
to
its
use
in
the
section
316(
b)
program.
In
addition,
two
expert
panel
sessions
were
convened
during
the
development
of
the
Phase
II
section
316(
b)
regulations
to
solicit
expert
advice
on
relevant
biological
issues
and
impingement
and
entrainment
technology
costs.

°
Random
Utility
Models
(
RUM):
The
recreational
demand
model
in
a
random
utility
framework
was
used
to
derive
recreational
benefits
for
a
previous
rulemaking
effort,
the
Metal
Products
and
Machinery
(
MP&
M)
effluent
guideline.
The
RUM
used
for
MP&
M
was
peer
reviewed
because
a
RUM
had
not
been
used
previously
by
EPA
within
the
guidelines
process,
and
EPA
wanted
to
ensure
that
the
model
was
technically
rigorous
given
the
data
limitations
such
as
a
small
sample
size
and
the
paucity
of
environmental
quality
data.
The
peer
review
concluded
that
EPA
had
done
a
competent
job,
especially
given
the
available
data.
The
peer
reviewers
also
noted
that
the
methodology
of
the
linked
trip
and
site
choice
models
is
"
nearly
the
state
of
the
art
for
the
problem
of
estimating
recreational
benefits."
This
method
permits
the
inclusion
of
numerous
substitute
sites
and
borders
on
being
utility
theoretic.
"
Thus,
if
you
want
to
be
able
to
answer
the
critique
that
there
are
hundreds
of
other
sites
and
the
benefits
of
clean
up
must
account
for
this,
the
multinomial
logit
model
for
site
selection
does
this
best."
The
reviewers
also
noted
that
the
revealed
preference
actual
behavior
base
is
solid
and
avoids
many
concerns
associated
with
contingent
valuation.
For
detail
see
"
Summary
Report:
Peer
Review
of
Application
of
the
Random
Utility
Model
to
Recreational
Benefit
Assessment
for
EPA's
Effluent
Guidelines
Program"
(
Versar
Inc.,
2001).

Additional
external
peer
review
for
the
316(
b)
rule
was
not
undertaken
because:
(
1)
the
section
316(
b)
models
relied
on
the
same
methodology
as
MP&
M
analysis
(
i.
e.,
the
linked
or
combined
site
choice
and
trip
frequency
models);
(
2)
the
section
316(
b)
models
are
built
upon
the
existing
National
Marine
Fishery
Service
models
of
recreational
fishing
behavior,
(
3)
the
combined
site
choice
and
trip
frequency
models
are
the
standard
revealed
preference
models
for
recreation
benefit
analysis
in
the
Natural
Resource
Damage
Assessment
area
as
well
as
in
the
journal
literature;
(
4)
the
section
316(
b)
models
were
reviewed
by
Peter
Feather,
an
economist
on
the
Council
of
Economic
Advisors
at
the
request
of
OMB
prior
to
proposal
of
the
Phase
II
rule;
and
(
5)
no
one
(
NCEE,
OMB,
or
the
public)
raised
significant
questions
on
the
models
used
for
the
proposed
rule
or
NODA
analyses.
The
only
significant
public
comments
received
were
that
the
models
should
be
5
expanded
to
a
larger
geographical
area.
We
addressed
this
issue
by
developing
regional
models
for
the
final
rule
analysis.

°
A
"
Technical
Experts
Panel
for
Biological
Issues
Associated
with
316(
b)
Regulations"
was
convened
in
March
2001
to
discuss
issues
pertaining
specifically
to
defining
adverse
environmental
impact
and
designing
biomonitoring
studies.
The
panel
was
comprised
of
15
state
and
Federal
experts,
primarily
biologists.
The
purpose
of
creating
and
convening
this
panel
was
to
solicit
information
and
exchange
ideas
with
a
range
of
experts
on
the
topics
of
concern.

°
A
second
expert
panel
was
convened
in
May
2001.
The
"
Invited
Technical
Experts
Meeting"
was
comprised
of
16
experts
from
industry,
states,
academia,
and
the
private
sector.
The
purpose
of
this
meeting
was
to
elicit
individual
comments
from
the
technical
experts
regarding
the
Agency's
preliminary
data
on
cooling
water
intake
structure
technologies
that
are
in
place
at
existing
facilities
and
the
costs
associated
with
the
use
of
available
technologies
for
reducing
impingement
and
entrainment
of
aquatic
organisms.
The
experts
represented
a
balanced
mix
of
individuals
recommended
by
or
associated
with
industry
and
public
interest
groups,
with
additional
representation
from
two
or
three
States
and
one
academic
institution.
The
public
was
invited
to
attend
the
panel
discussion
and
had
an
opportunity
to
express
their
views
at
the
end
of
the
meeting.

Phase
II
projects
that
have
been
peer
reviewed.
Three
major
scientific/
technical
products
underwent
external
peer
review
for
the
Phase
II
rulemaking:
(
1)
Chapter
A7
of
the
benefits
technical
support
document
"
Entrainment
Survival,"
(
2)
Chapter
A5
of
the
benefits
technical
support
document
"
Methods
Used
to
Evaluate
Impingement
&
Entrainment,"
and
(
3)
Chapter
A15:
Non­
use
Meta­
Analysis
Methodology.
Copies
of
the
reports
from
these
peer
reviews
can
be
found
in
the
record
for
the
Phase
II
rulemaking
at
DCN
6­
5007A,
6­
5007B,
and
6­
2500,
respectively.
These
products
were
important
to
the
underpinnings
of
the
rule
framework
because
they
have
a
significant
bearing
on
the
use
and
non­
use
benefits
calculated
for
the
rule.
As
mentioned
earlier,
the
costs
and
benefits
of
the
Phase
II
rule
are
a
major
focus.
In
contrast
to
the
costing
methodology
used
for
Phase
II,
some
of
the
benefits
analyses
are
potentially
precedentsetting
and
somewhat
controversial.
Chapter
A7:
Entrainment
Survival
provides
a
review
of
the
available
literature
documenting
entrainment
survival
studies
and
associated
estimates
of
entrainment
survival
at
specific
facilities.
The
chapter
evaluates
each
of
these
studies
and
its
merits,
ultimately
concluding
that
for
the
purposes
of
the
rule,
entrainment
survival
should
be
considered
0%.
Because
substantially
more
organisms
affected
by
cooling
water
intakes
are
entrained
rather
than
impinged,
the
conclusion
of
0%
survival
is
controversial,
and
the
assumption
of
0%
entrainment
survival
dramatically
affects
the
losses
associated
with
intake
withdrawals
and
therefore
calculated
benefits,
this
chapter
merits
external
peer
review.
Chapter
A5:
Methods
Used
to
Evaluate
Impingement
&
Entrainment
describes
the
process
used
to
translate
raw
impingement
and
entrainment
data
into
adult
equivalent
losses,
which
in
turn
can
be
used
to
calculate
monetized
benefits
associated
with
minimizing
losses
of
impinged
and
6
entrained
fish
and
shellfish.
Chapter
A12:
Non­
use
Meta­
Analysis
Methodology
focuses
on
addressing
a
significant
emerging
issue:
quantifying
and
monetizing
ecological
benefits.
The
chapter
develops
a
benefits
transfer
approach
to
valuing
non­
use
benefits
for
the
rule
based
on
meta­
analysis/
synthesis
of
existing
surface
water
valuation
studies.
Meta­
analysis
involves
statistically
summarizing
the
relationships
between
benefit
measures
and
the
quantifiable
characteristics
of
studies
(
Rosenberger
and
Loomis
2001).
This
chapter
also
provides
detail
on
compiling
meta­
data
for
the
analysis.
The
data
used
for
a
meta­
analysis
typically
are
summary
statistics
from
site
reports
that
include
quantified
characteristics
of
the
user
population,
environmental
resources
at
the
study
site,
and
the
valuation
methodology
used.
The
purpose
of
the
peer
review
is
to
evaluate
the
meta­
analysis
model
specifications,
nonuse
benefit
estimates,
and
source
data
from
two
meta
regressions
that
are
to
be
used
in
partial
support
of
the
proposed
Phase
II
rulemaking.
These
meta
regressions
are
designed
to
statistically
summarize
the
relationship
between
benefit
measures
and
a
set
of
characteristics
compiled
from
original
primary
study
sources.
Selected
peer
reviewers
will
evaluate
the
source
data
set
utilized
in
the
estimation
of
the
models
that
was
compiled
from
the
primary
studies.
The
reviewers
will
make
comment
on
the
functional
form
that
each
of
the
two
models
utilize
(
i.
e.,
semi­
log
and
loglog
and
their
inherent
assumptions,
constraints,
and
usefulness.
As
the
final
phase
of
the
peer
review,
correct
implementation
of
these
models
should
be
confirmed.
This
should
include
a
discussion
comparing
the
two
EPA
meta
regressions
to
current
relevant
literature
and
their
findings.
Over
90%
of
the
impingement
and
entrainment
losses
nationally
that
are
attributable
to
cooling
water
intakes
are
forage
(
non­
use)
species.
Given
the
predominance
of
forage
species
and
the
relatively
limited
state
of
the
science
for
evaluating
and
quantifying
non­
use
impacts,
the
metaanalysis
has
the
potential
to
be
precedent­
setting.
Further,
based
on
comments
received
on
all
previously
proposed
non­
use
methodologies
undertaken
as
part
of
this
rulemaking
effort,
quantifying
ecological
benefits
is
a
highly
controversial
topic.

Phase
III
Candidate
projects
for
future
peer
review.
Three
major
scientific/
technical
products
are
expected
to
undergo
external
peer
review
for
the
Phase
III
rulemaking:
(
1)
the
Nonuse
Meta­
Analysis,
(
2)
the
Non­
use
Stated
Preference
Survey,
and
(
3)
a
Leslie­
Matrix
type
fish
population
model
under
development
by
NCEE
to
estimate
the
impacts
of
impingement
and
entrainment
reduction
on
fish
population
and
harvest
levels.
Non­
use
Meta­
Analysis
Framework:
The
non­
use
meta­
analysis
model
that
was
initially
developed
as
part
of
the
316(
b)
Phase
II
quantification
and
monetization
of
ecological
benefits
was
revised
in
response
to
comment
from
the
peer
review
that
was
conducted
under
the
316(
b)
Phase
II
Peer
Review
Plan.
This
updated
meta­
analysis
model
was
applied
to
the
316(
b)
Phase
III
impingement
and
entrainment
data.
The
product,
to
be
peer
review
externally
with
funding
and
direction
provided
by
NCEE
in
consultation
with
the
rulemaking
team,
describes
how
non­
use
benefits
were
estimated
through
the
meta­
analysis
benefits
transfer
approach.
This
analysis
involves
statistically
summarizing
the
relationships
between
the
benefits
estimates
and
study
characteristics
of
a
set
of
existing
surface
water
valuation
studies.
The
product
to
be
peer
reviewed
will
also
provide
details
on
meta­
data
used
in
the
analysis
which
is
usually
comprised
of
7
the
benefits
estimates,
and
source
study
site,
policy,
and
methodological
variables.
External
reviewers
will
be
asked
to
evaluate
the
appropriateness
of
the
source
meta­
data
and
benefits
transfer
technique
for
the
estimation
of
non­
use
benefits
under
the
316(
b)
rulemaking
effort,
as
well
as,
the
correctness
of
the
estimated
model
and
non­
use
values.
Non­
use
Stated
Preference
Survey:
EPA
is
planning
to
develop
and
implement
a
contingent
valuation
stated
preference
survey
as
a
means
of
estimating
non­
use
benefits
for
the
final
316(
b)
Phase
III
rulemaking.
The
survey
will
be
designed
to
elicit
willingness­
to­
pay
values
from
individuals
for
varying
increases
in
the
number
of
fish
across
many
species
both
commercial,
recreational,
and
forage.
These
stated
values
will
then
be
use
in
an
econometric
model
to
estimate
the
non­
use
value
of
the
decreased
impingement
and
entrainment
produced
by
316(
b)
Phase
III.
Because
this
is
a
survey
of
the
public
it
will
be
subject
to
the
Information
Collection
Request
(
ICR)
process
through
which
the
public
will
have
the
opportunity
to
comment
on
the
survey
instrument
and
the
planned
implementation
process.
At
this
time
EPA
will
also
conduct
an
external
professional
peer
review
of
the
survey
instrument
and
the
implementation
plan
as
part
of
the
preparation
for
OMB
review
of
the
ICR.
After
the
survey
is
conducted
and
the
non­
use
values
have
been
estimated
an
external
peer
review
of
the
entire
process
including
the
instrument,
implementation,
and
the
estimation
of
non­
use
values
will
be
conducted.
Leslie­
Matrix
type
fish
population
model:
The
fish
population
model
under
development
by
NCEE
would
utilize
raw
impingement
and
entrainment
data
to
calculate
baseline
levels
and
changes
in
fish
population
and
harvest
levels
as
a
result
of
policy­
driven
reductions
in
impingement
and
entrainment
levels.
It
is
a
single
species,
discrete­
time,
age­
structured
model
that
includes
a
density­
dependent
survival
dynamic
for
fish
life
stages
after
the
egg
stage.
The
model
uses
information
from
the
literature
on
natural
mortality
rates,
fishing
mortality
rates,
growth
rates
at
low
population
sizes,
and
weights
at
various
ages
and
life
stages.
This
approach
to
calculating
the
ecological
benefits
of
reducing
impingement
and
entrainment
could
potentially
provide
insights
into
those
benefits
beyond
those
provided
by
the
models
used
in
the
Phase
II
rule.
population
model
to
define
when
nonuse
benefits
exist.
These
products
are
important
to
the
underpinnings
of
the
Phase
III
rule
framework
because
they
have
a
significant
bearing
on
the
use
and
non­
use
benefits
calculated
for
the
rule.
As
mentioned
earlier,
the
costs
and
benefits
of
the
Phase
II
and
Phase
III
rules
are
a
major
focus
An
external
peer
review
panel
will
be
formed
consisting
of
academic
economists
and
ecologists
with
expertise
in
ecosystem
valuation
and
fish
population
modeling.
They
will
be
charged
with
reviewing
the
meta
analysis
to
estimate
the
non­
use
benefits
of
decreased
fish
mortality
in
the
area
of
cooling
water
intake
structures.
They
will
also
review
the
methods
used
for
estimation
of
fish
population
changes
that
were
generated
for
the
benefit
estimation
and
they
will
review
the
new
fish
population
modeling
methods
that
are
currently
being
developed
by
EPA.

Products
for
which
a
decision
has
been
made
not
to
conduct
peer
review.
The
engineering
costing
analyses
for
Phase
II
were
performed
according
to
the
standardized
process
used
historically
in
regulatory
development
efforts
for
all
effluent
guidelines.
Costing
analyses
for
Phase
III
facilities
followed
the
same
process.
Because
the
costing
methodologies
are
standardized,
they
do
not
meet
the
established
criteria
for
requiring
peer
review.
Due
to
significant
data
differences
among
the
regions
used
to
calculate
national
benefits,
8
benefit
extrapolations
for
the
Phase
II
and
III
regulations
were
performed
within
National
Marine
Fisheries
Service
(
NMFS)
established
fishing
regions
or
within
the
Great
Lakes
or
Inland
regions.
To
obtain
regional
impingement
and
entrainment
estimates,
EPA
extrapolated
losses
from
facilities
with
impingement
and
entrainment
data
to
facilities
within
the
same
region
without
data.
Impingement
and
entrainment
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.
Operational
flow
at
each
facility
was
re­
scaled
using
factors
reflecting
the
relative
effectiveness
of
currently
in­
place
technologies
for
reducing
impingement
and
entrainment.
Regional
impingement
and
entrainment
estimates
are
based
on
as
many
new
facilities
in
different
locations
as
possible.
The
monetary
value
of
benefits
from
reduced
impingement
and
entrainment
is
estimated
based
on
regional
models
and
thus
no
extrapolation
was
necessary.
The
only
exception
was
Hawaii.
For
the
three
Hawaii
facilities,
EPA
used
the
extrapolation
methodology
described
in
the
Phase
II
proposed
rule.
Specifically,
EPA
extrapolated
the
estimated
monetary
value
of
benefits
for
other
coastal
regions
on
the
basis
of
operational
flow,
in
millions
of
gallons
per
day
(
MGD)
for
the
Hawaii
facilities.
An
electricity
market
model,
the
Integrated
Planning
Model
2000
(
IPM
®
2000),
was
used
to
identify
potential
economic
and
operational
impacts
of
various
regulatory
options
for
Phase
II.
This
model
is
routinely
used
by
the
EPA
Office
of
Air
and
Radiation
to
evaluate
potential
economic
impacts
from
regulatory
actions
and
thus
was
not
subjected
to
the
peer
review
process.

III.
QA
Reviews
A
quality
assurance
project
plan
(
QAPP)
was
prepared
in
2002
that
evaluated
the
quality
of
all
data
used
as
part
of
the
316(
b)
rulemaking
effort
to
determine
the
best
technology
available
to
minimize
adverse
environmental
impacts
from
cooling
water
intakes.
The
316(
b)
QAPP
was
prepared
according
to
guidance
provided
in
"
EPA
Requirements
for
Quality
Assurance
Project
Plans"
(
EPA
QA/
R­
5,
EPA/
240/
B­
01/
003;
March
2001)
to
ensure
that
environmental
and
related
data
collected,
compiled,
and/
or
generated
for
the
project
were
complete,
accurate,
and
of
the
type,
quantity,
and
quality
related
required
for
their
intended
use.
The
QAPP
specifically
addresses
(
1)
development
of
a
316(
b)
database
evaluation
checklist,
(
2)
development
of
a
technology
efficacy
database,
and
(
3)
analysis
of
results
from
data
quality
evaluations.
Much
of
the
data
used
in
the
Phase
II
and
Phase
III
rulemaking
processes
are
secondary
and
have
undergone
some
level
of
review.
Assessment
factors
for
evaluating
data
from
external
sources
including
soundness,
applicability
and
utility,
clarity
and
completeness,
uncertainty
and
variability,
and
evaluation
and
review
are
critical
elements
of
the
review
process.
In
all
cases,
intra­
and
inter­
agency
reviews
of
Phase
II
and
Phase
III
data
used
for
modeling
results
and
cost/
benefit
analyses
were
conducted,
which
often
involved
sharing
data
and
the
detailed
methodologies
used
in
the
analyses
so
that
specific
results
could
be
reproduced
by
others.
The
data
utilized
and
analyses
conducted
as
part
of
this
regulatory
development
process
conform
with
the
requirements
specified
in
the
EPA
Information
Quality
Guidelines
and
the
OW
Quality
Policy.
Following
are
several
additional
examples
of
data
QA
reviews
for
critical
components
of
this
rulemaking
effort.
The
Technology
Efficacy
Database
was
developed
to
document
and
further
assess
the
9
performance
of
various
technologies
and
operational
measures
designed
to
minimize
the
impacts
of
cooling
water
withdrawals.
The
database
is
comprised
of
documents
that
analyze
the
efficacy
of
a
specific
technology
or
suite
of
technologies
and
contains
materials
that
range
from
brief
journal
articles
to
more
intensive
analyses
found
in
historical
section
316(
b)
demonstration
reports
and
technology
evaluations.
Information
entered
into
the
database
includes
some
notation
of
the
limitations
the
individual
studies
may
have
for
use
in
further
analyses
(
e.
g.,
no
biological
data
or
conclusions).
One
of
the
primary
purposes
of
this
database
is
to
demonstrate
that
the
technologies
chosen
as
compliance
technologies
for
costing
purposes
are
reasonable
and
can
meet
the
performance
standards.
EPA
evaluated
the
technology
efficacy
data
against
objective
criteria
in
order
to
assess
the
general
quality
and
thoroughness
of
each
study.
Basic
information
from
each
document
is
recorded
in
the
database
(
e.
g.,
type
of
technology
evaluated,
facility
at
which
it
was
tested,
etc.)
Each
document
is
reviewed
according
to
five
areas
of
data
quality
where
possible:
1)
applicability
and
utility,
2)
soundness,
3)
clarity
and
completeness,
4)
uncertainty
and
variability,
and
5)
evaluation
and
review.
Because
the
literature
in
question
comes
from
many
different
sources
and
was
developed
under
widely
varying
standards,
EPA
was
not
able
to
evaluate
all
of
these
criteria
for
all
documents
contained
in
the
database.
Biological
data
used
in
the
benefits
analyses
in
both
Phase
II
and
Phase
III
are
from
secondary
sources
only.
Data
evaluated
include
(
1)
impingement
and
entrainment
data
collected
by
CWIS
facilities;
(
2)
fish
life
history
data
from
the
peer­
reviewed
literature,
unpublished
documents
and
reports,
and
personal
communications
with
fishery
experts;
and
(
3)
recreational
and
commercial
fisheries
data.
Data
assembly
includes
accuracy
checks,
consistency
checks,
and
reasonableness
checks
to
ensure
data
validity.
The
objective
of
the
first
of
these
checks
is
to
identify
transcription
errors.
The
goal
of
the
last
two
types
of
checks
is
to
identify
potential
errors
in
the
underlying
data.
Accuracy
checks
are
performed
twice
during
the
data
assembly
step.
First,
all
data
entries
are
checked
at
the
time
of
entry
by
the
technical
person
assembling
the
database.
At
the
completion
of
the
data
entry,
another
person
verifies
the
data
entry
and
compares
data
records
to
the
source
documents
to
check
the
accuracy
of
the
interpretation
and
manipulation
of
the
data.
Checks
of
the
accuracy
of
data
assembly
are
facilitated
by
preparing
standardized
input
spreadsheets.
The
objective
of
this
standardization
is
to
ensure
that
data
in
import
files
are
structured
correctly
and
meet
all
data
quality
requirements
for
entry
into
a
project
database.
To
check
consistency
and
reasonableness
of
the
data,
senior
scientists
check
results
of
the
preliminary
data
assembly.
To
facilitate
the
understanding
of
the
distribution
of
the
data
sets
and
to
identify
outliers,
graphical
displays
of
the
assembled
data
are
produced.
Any
data
that
appear
to
be
suspect
are
rechecked
and
eliminated
or
replaced
as
needed.
In
addition
to
these
procedures
for
assembly
input
data,
several
methods
are
used
to
evaluate
data
output,
including
reasonableness
checks,
sample
calculations,
and
computerized
checks.
All
biological
data
are
maintained
in
a
data
archiving
system
designed
to
protect
and
index
databases,
documents,
figures,
and
computer
program
scripts.
Prior
to
investing
time
or
resources
into
new
non­
use
benefit
studies,
EPA
conducted
preliminary
reviews
of
studies
that
appeared
to
be
applicable
to
the
section
316(
b)
regulations.
The
Peconic
non­
use
study
and
a
method
for
using
the
information
from
this
study
to
estimate
non­
use
values
for
impinged
and
entrained
fish
was
evaluated
by
economists
with
expertise
in
the
10
valuation
of
natural
resources,
who
in
turn
made
recommendations
for
improving
the
methodology.
This
included
the
use
of
information
from
a
related
wetland
study
to
estimate
the
proportion
of
wetland
value
associated
with
fish
and
shellfish
habitat.
To
support
the
development
of
Phase
III
regulations,
EPA
performed
a
small
entrainment
sampling
study.
The
purpose
of
this
study
was
to
gather
information
about
the
entrainment
impacts
of
cooling
water
intake
at
facilities
with
cooling
water
intake
structure
design
intake
flows
below
50
million
gallons
per
day.
The
study
obtained
quantitative
entrainment
data
during
the
period
of
heightened
spawning
activity
and
ichthyoplankton
abundance.
The
target
organism
assemblages
were
both
the
entrained
and
nearfield
early
life
stages
of
fish
and
shellfish
(
i.
e.,
eggs
and
larvae).
The
study
did
not
attempt
to
obtain
quantitative
impingement
data
from
these
small
facilities
as
rates
of
organism
impingement
at
cooling
water
intake
structures
are
highly
variable
over
time.
In
performing
this
study,
EPA
and
its
contractor
developed
a
Quality
Assurance
Project
Plan
(
QAPP)
(
see
attached)
that
was
approved
by
the
EPA/
OST/
EAD
Quality
Assurance
Manager.
The
QAPP
contained
Standard
Operating
Procedures
(
SOPs)
for
all
field
and
laboratory
activities
associated
with
the
study
including:
entrainment
sampling;
nearfield
ichthyoplankton
sampling;
completion
of
chain­
of­
custody
forms;
water
quality
meter
operation;
laboratory
sorting
of
ichthyoplankton;
and
ichthyoplankton
taxonomy.
Field
sampling
was
conducted
by
personnel
experienced
in
collecting
entrainment
samples,
and
each
field
team
was
audited
by
the
EPA
QC
Officer
to
assess
compliance
with
the
QAPP
and
SOPs.
All
samples
were
shipped
under
chain­
of­
custody
to
designated
biology
laboratories
that
had
been
predetermined
to
have
expertise
in
the
taxonomic
identification
of
ichthyoplankton.
Laboratory
results
included
taxonomic
identification
and
taxon­
by­
taxon
enumeration
for
all
samples.
Ten
percent
of
all
samples
were
re­
identified
by
a
second/
independent
taxonomist,
and
taxonomic
precision
was
calculated
as
Percent
Taxonomic
Disagreement
(
PTD).
A
PTD
goal
of
less
than
or
equal
to
15%
was
targeted.
The
QAPP
specified
that
if
the
goal
was
not
attained,
taxonomist
interaction
would
be
used
to
determine
problem
areas,
identify
consistent
disagreements,
and
define
corrective
actions;
however,
no
corrective
actions
were
necessary
since
the
goal
was
attained.
A
project
database
was
developed
to
store
sampling
data,
laboratory
enumeration
data,
and
taxonomic
data
for
all
sampling
locations.
Data
tables
contained
raw
data
from
field
forms
and
laboratory
bench
sheets.
All
data
were
double­
entered,
i.
e.,
each
data
point
was
entered
into
the
database
by
two
independent
entry
clerks.
The
database
compared
the
independent
entries
and
identified
any
discrepancies.
All
discrepancies
were
reconciled
by
consulting
original
field/
laboratory
paperwork,
and
were
corrected
in
the
database.
The
final
database
was
used
to
generate
a
data
report
for
the
study
that
presented
and
summarized
the
data.
To
better
profile
the
universe
of
facilities
potentially
subject
to
all
phases
of
the
section
316(
b)
rule,
EPA
distributed
surveys
to
over
1,400
facilities.
Some
facilities
received
a
detailed
industry
survey
while
others
received
a
short
technical
questionnaire.
The
selection
of
the
sample
frame
is
detailed
in
the
EPA
report
entitled,
Statistical
Summary
for
Cooling
Water
Intake
Structure
Surveys
(
DCN
3­
3077
in
Docket
W­
00­
03).
Several
levels
of
quality
assurance
were
conducted
for
this
activity.
All
surveys
returned
were
photocopied
to
create
working
files.
The
surveys
were
then
subjected
to
a
review
for
completeness
and
a
separate
engineering
review.
The
engineering
review
examined
the
survey
responses
for
internal
consistency,
reported
units,
and
the
method
for
presenting
and
computing
reported
monthly
and
annual
values
for
compliance
with
11
survey
requirements.
Any
discrepancies
or
omissions
were
added
as
corrections
on
working
copies
and
a
change
log
was
created
for
the
facility
and
placed
into
the
survey
folder.
The
change
log
contained
a
description
of
the
change,
a
reason
for
the
change,
the
original
information
provided,
and
the
corrected
information.
The
surveys
and
change
log
were
then
sent
to
a
contractor
for
data
entry.
During
the
data
entry
process,
additional
data
discrepancies
and/
or
omissions
were
identified
and
then
reconciled
through
a
telephone
call
to
the
facility.
Again,
change
logs
were
generated
and
placed
into
the
working
file
for
the
facility.
A
master
database
file
was
created
and
a
statistical/
mathematical
review
of
survey
data
was
conducted
to
identify
outstanding
discrepancies
and
outliers.
This
statistical/
mathematical
review
included,
among
other
data
elements,
reviews
of
1996,
1997,
and
1998
annual
flow
data.
These
annual
flow
data
were
checked
to
see
if
they
satisfied
the
logical
relationship
"
minimum
<
average
<
maximum".
Surveys
that
did
not
satisfy
this
logical
relationship
were
identified
for
engineering
review.
To
verify
source
waterbody
categories,
geocoding
was
performed
to
identify
facility
state
locations
using
the
respondents
latitude/
longitude
information
(
respondents
were
required
to
report
their
mailing
addresses
in
the
surveys,
not
their
physical
locations).
Again,
discrepancies
and
illogical
results
were
identified
(
for
example,
some
facilities
reported
latitudes/
longitudes
that
were
outside
the
U.
S.).
Additional
telephone
calls
were
made
to
the
facilities
to
reconcile
data
issues
and
were
described
in
the
change
log.
Some
of
the
information
was
confidential
business
information
(
CBI),
so
those
data
were
contained
in
the
CBI
database
and
documented
in
CBI
change
logs.
Engineering
staff
and
contractors
reviewed
all
inconsistencies
identified
in
the
statistical/
mathematical
review
and
reconciled
the
data
through
examination
of
other
responses
and/
or
a
telephone
call
to
the
facility.
Change
logs
were
prepared
and
included
in
the
survey
file.
The
Phase
II
and
proposed
Phase
III
rules
require
biological
monitoring
for
both
freshwater
and
marine
environments.
The
ICR
costs
for
biological
monitoring
were
carefully
reviewed
by
a
senior
biologist
with
over
20
years
of
experience
to
ensure
consistency
with
acceptable
sampling/
laboratory
practices
and
to
confirm
the
appropriate
level
of
staff
required
to
be
involved
with
the
effort.
The
senior
biologist
reviewed
labor
categories,
labor
rates,
and
the
specific
monitoring
components
required
by
the
rules.

IV.
Peer
Input
Tier
1
regulation
development
requires
peer
input
at
multiple
intervals
throughout
the
process.
Entire
proposal
packages
(
proposed
rule,
preamble,
and
all
supporting
documents)
are
reviewed
internally
and
by
other
Federal
and
State
agency
experts.
Notices
of
Data
Availability
(
NODA)
which
document
any
new
data
sources
and
methodology
changes
are
subjected
to
a
similar
review
process.
Final
rule
package
receive
even
greater
review
and
scrutiny
before
they
are
issued.
Preliminary
reviews
of
major
Phase
II
and
Phase
III
work
products
were
also
a
source
of
peer
input.
These
reviews
were
conducted
by
contractors
who
had
no
involvement
in
developing
the
analysis
under
review.
Preliminary
reviews
of
the
following
studies
or
methodologies
were
conducted
as
part
of
the
Phase
II
and
Phase
III
efforts:
12
°
Chapter
C6,
Habitat­
Based
Analysis,
was
reviewed
by
outside
economists
with
expertise
in
Natural
Resource
Damage
Assessment.
Analyses
presented
in
Chapters
C6
use
the
value
for
fish
habitat
as
an
indirect
basis
for
valuing
the
fish
that
are
supported
by
the
habitat.
Existing
wetland
valuation
studies
found
that
members
of
the
general
public
are
aware
of
the
fish
production
services
provided
by
eelgrass
(
submerged
aquatic
vegetation,
SAV)
and
wetlands,
and
that
they
express
support
for
steps
that
include
increasing
SAV
and
wetland
areas
to
restore
reduced
fish
and
shellfish
populations.
EPA
used
values
from
two
studies
of
public
values
for
wetlands
and
eelgrass:
a
study
of
the
Peconic
Estuary,
located
on
the
East
End
of
Long
Island,
New
York
(
Johnston
et
al.,
2001a,
2001b;
Opaluch
et
al.,
1998;
1995;
Mazzotta,
1996);
and
a
stated
preference
study
from
Narragansett
Bay,
Rhode
Island
(
Johnston
et
al.,
2002).
Outside
reviewers
assessed
appropriateness
of
using
these
two
studies
for
valuing
restoration
of
wetlands
and
SAV
in
the
North
Atlantic
region
and
for
valuing
benefits
of
the
316(
b)
regulation.
The
reviewers
noted
that
although
these
studies
provide
a
close
match
to
the
restoration
scenarios
considered
in
the
analysis
of
the
316(
b
benefits,
the
habitat­
based
approach
does
not
provide
a
direct
measure
of
benefits
from
reduced
impingement
and
entrainment
of
aquatic
organisms.
Therefore,
EPA
did
not
present
the
results
of
the
habitat­
based
analysis
in
its
benefits
cost
analysis.
Instead,
the
Agency
presents
this
information
as
"
other
important
considerations"
that
need
to
be
taken
into
account
in
decision
making.


The
population
model
developed
by
NCEE
was
reviewed
by
fisheries/
statistical
experts
under
contract
to
EPA.
Two
separate
reviews
were
conducted
(
see
Stratus
Consulting
report
dated
7/
01/
03,
"
Assessment
of
OPEI
alternative
fishery
model
of
I&
E
impacts"
and
file
notes
of
verbal
report
by
Sidina
Dedah
to
John
Fox
on
May
16,
2003).
The
Stratus
Consulting
staff
reviewers
are
expert
in
fisheries
science
and
population
modeling.
Dr.
Dedah
of
SAIC
has
a
PhD
in
oceanography
and
MS
statistics
and
has
published
work
in
peer
reviewed
journals
on
the
modeling
of
fisheries
dynamics
and
the
fitting
of
stockrecruitment
models.
Results
of
these
reviews
were
considered
by
EPA
in
revising
and
finalizing
the
fish
population
model.

Prior
to
revising
our
benefits
analysis
in
the
NODA
for
Phase
II,
the
316(
b)
Task
Force
convened
a
meeting
with
OPEI
and
ORD
to
discuss
an
approach
to
strengthening
the
benefits
analysis.
Peer
input
was
received
during
these
meeting
discussions,
particularly
discussions
pertaining
to
any
potential
shortcomings
of
the
approach.
In
addition,
economists
from
NCEE
worked
very
closely
with
OST
to
finalize
the
meta­
analysis
approach
to
valuing
non­
use
benefits.
In
the
development
of
the
Phase
III
regulations,
EAD
staff
have
met
and
continue
to
work
closely
with
NCEE
on
a
model
for
calculating
impingement
and
entrainment
impacts
on
fish
populations
and
harvests
that
incorporates
additional
fish
population
dynamics.

V.
Time
Lines
for
Future
Peer
Review
Products
There
are
3
major
scientific/
technical
products
that
are
anticipated
to
undergo
or
are
currently
undergoing
external
peer
review
are
as
follows:
(
1)
Non­
use
Stated
Preference
Survey,
(
2)
Non­
use
Meta­
Analysis
Framework,
and
(
3)
population
model
that
defines
when
nonuse
13
benefits
exist.
The
schedule
for
peer
review
completion
is
provide
below.


Non­
use
Stated
Preference
Survey
instrument
and
implementation
plans
 
be
available
for
public
comment
as
part
of
the
Information
Collection
Request
process
for
60
days
starting
in
February
2005
with
Federal
Register
notification.
A
second
public
comment
period
will
start
with
a
Federal
Register
Notice
in
May
2005.
An
external
peer
review
of
the
survey
instrument
and
implementation
plan
as
well
as
OMB
review
will
also
begin
in
May
2005.
The
final
external
peer
review
of
the
completed
survey,
estimated
econometric
model,
and
non­
use
results
is
planned
to
begin
November
2005.


Non­
use
Meta­
Analysis
Framework
and
Population
Modeling
 
The
external
peer
review
panel
comprised
of
academic
economists
and
ecologists
with
expertise
in
ecosystem
valuation
and
fish
population
modeling
is
scheduled
for
completion
by
April
30,
2005.

Literature
Cited
Johnston,
R.
J.,
G.
Magnusson,
M.
Mazzotta
and
J.
J.
Opaluch.
2002b.
Combining
Economic
and
Ecological
Indicators
to
Prioritize
Salt
Marsh
Restoration
Actions.
American
Journal
of
Agricultural
Economics
84(
5):
1362­
1370.

Opaluch,
James
J.,
Thomas
Grigalunas,
Marisa
J.
Mazzotta,
Jerry
Diamantides,
and
Robert
Johnston.
1998.
"
Recreational
and
Resource
Economic
Values
for
the
Peconic
Estuary,"
Report
prepared
for
Peconic
Estuary
Program,
Suffolk
County
Department
of
Health
Services,
Riverhead,
NY,
by
Economic
Analysis,
Inc.,
Peace
Dale,
Rhode
Island.

Mazzotta,
Marisa
J.
1996.
Measuring
Public
Values
and
Priorities
for
Natural
Resources:
An
Application
to
the
Peconic
Estuary
System.
Doctoral
Dissertation,
University
of
Rhode
Island.

USEPA.
2000.
Peer
Review
Handbook,
2nd
Edition.
Prepared
by
the
U.
S.
EPA
Science
Policy
Council;
EPA
100­
B­
00­
001.

Rosenberger,
R.
S.
and
J.
B.
Loomis.
2001.
Benefit
Transfer
of
Outdoor
Recreation
Use
Values.
USDA
Forest
Service
Gen.
Tech.
Rep.
RMRS­
GTR­
72.

USEPA.
2002.
Quality
Assurance
Project
Plan
for
Technical
Support
for
Section
316(
b)
Regulatory
Development
and
Implementation
Initiatives.
Prepared
by
Tetra
Tech
for
USEPA
under
contract
number
68­
C­
02­
1063.
