Veritas’ 316(b) expertise developed by commenting with the Utility Water Act Group during the Phase II rule’s creation. Our comments encompassed all methodological aspects of 316(b)-related economic valuation (recreational, commercial, and nonuse values) as well as the application of these concepts under the regulatory construct (e.g., the role of baseline in benefits assessment for compliance purposes). Veritas’ staff have then used this expertise to evaluate, interpret, and apply the Phase II Rule in complex settings throughout the U.S.
Specifically, Veritas’ 316(b) compliance experience consists of providing cost-benefit based Strategic Assessments of potential compliance options as well as Comprehensive Demonstration Study (CDS) work, including project management, developing Proposals for Information Collection (PIC), Benefits Valuation Studies (BVS), Site-Specific Restoration Plans, and CDS submittals. As part of this work, Veritas’ staff have assessed strategic compliance decisions, estimated site-specific economic benefits associated with meeting the performance standards at an individual plant, and developed the required regulatory submissions to support a specific compliance option.
- Assisting 10 Utilities in 15 states to develop Strategic Assessments, Proposals for Information Collection (PIC), Benefits Valuation Studies (BVS), or Comprehensive Demonstration Studies (CDS)
- Conducting plant-level strategic assessments to evaluate potential compliance options.
- Statistically modeling sampled impingement and entrainment (I&E) data to calculate annual and interannual estimates.
- Incorporated strategic assessment recommendations into PICs for submission in 11 states and developed numerous PICs that emphasize the use of benefit-cost analysis as a potential or the relevant compliance alternative.