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and Paperwork costs associated with compliance across the board for the VGP. Not all of these costs are associated with ballast water, but it is safe to assume signi? cant portions are attributable to the VGPs ballast water requirements. ASSUMPTIONS & DEADLINES: NOT ALWAYS ONE IN THE SAMEIn estimating the total cost, USCG assumed that ves- sels would be in full compliance with the requirement by 2018. The BWTS equipment installation requirements are phased-in for existing vessels over the 2014 through 2016 period. All newly built vessels constructed on or after December 1, 2013 will have to comply with the discharge standards upon their delivery, while vessels constructed before De- cember 1, 2013 will have to comply with the discharge standards as early as their ? rst drydocking after January 1, 2014 or January 1, 2016, depending on their ballast water capacity. Although EPA was unable to evaluate the expected ben- e? ts of the permit in dollar terms due to data limitations, the EPA collected and considered relevant information to enable qualitative consideration of ecological bene? ts and to assess the importance of the ecological gains from the revisions. The EPA expects that reductions in vessel dis- charges will bene? t society in two broad categories: (1.) enhanced water quality from reduced pollutant discharges and (2.) reduced risk of invasive species introduction and dispersal. Table 2: Ballast Water Treatment Sensitivity Analysis Vessel TypeTotal Annual Cost Low End EstimateTotal Annual Cost High End EstimateTreatment Cost Commercial Fishing Freight Barge Freight Ships Passenger Vessel Tank Barge Tank Ships $1,911,104 Utility Vessel Sub Total $1,911,104 BWTS Monitoring Commercial Fish- ing$2,579$3,855 Freight Barge Freight Ships$12,445$18,668 Passenger Vessel$4,258$6,387 Tank Barge Tank Ships$2,001$3,001 Utility Vessel$24,756$37,135 Sub Total$46,039$69,045 Sampling & Test- ing (biological)Commercial Fishing $16,699$26,148 Freight Barge Freight Ships$80,866$126,624 Passenger Vessel$27,668$43,324 Vessel TypeTotal Annual Cost Low End EstimateTotal Annual Cost High End EstimateTank Barge Tank Ships$12,999$20,355 Utility Vessel$160,862$251,886 Sub Total$299,096$468,338 Sampling & Test- ing (biocides)Commercial Fishing $9,368$39,898 Freight Barge Freight Ships$45,366$193,208 Passenger Vessel$15,522$66,106 Tank Barge Tank Ships$7,293$31,058 Utility Vessel$40,518$384,336 Sub Total$167,792$714,606 Great Lakes Requirements Commercial Fishing Freight Barge Freight Ships $82,888$165,777Passenger Vessel$31,593 $63,187Tank Barge Tank Ships $14,843$29,687Utility Vessel $24,825$49,651Sub Total $154,151$308,301Total $667,068$3,471,394 July 201330 MNMN July2013 Layout 18-31.indd 306/27/2013 1:03:34 PM
