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Description

The purpose of the Ocean Dumping Permit Fee Regulations (Site Monitoring) under paragraph 19.1(a) of the Financial Administration Act (FAA), is to introduce a requirement upon publication in the Canada Gazette Part II, for permittees who dispose of dredged or excavated material at sea to pay fees of $470 per thousand cubic meters authorized under the permit for ocean dump site monitoring. The Department of the Environment (Department) originally intended to use disposal at sea regulations under a revised Canadian Environmental Protection Act (CEPA) for this new fee (Monitoring Fee). A delay in the promulgation of the new CEPA caused the Department to pursue the Monitoring Fee under the FAA in order to bring the program into compliance with the Treasury Board policy on cost recovery, without delay.

The Department regulates disposal at sea and meets its international obligations on the prevention of marine pollution by dumping (London Convention 1972, and 1996 Protocol) by means of the CEPA Part VI and the Ocean Dumping Regulations (ODR). Under this legislation, those wishing to dispose of wastes at sea must submit a permit application, with the required information and a $2,500 application fee. Cost recovery for permit application assessment and publication services was put in place in 1993 under ODR. For this fee, the Department assesses the application and sets permit conditions. More than 90% of the total quantity of waste disposed at sea is from dredged sediments and excavation material. Other wastes include fisheries wastes, old vessels and scrap metal. Permits are valid for up to one year.

At present, the Department only conducts dump site monitoring at representative sites receiving dredged and excavated materials. The monitoring allows clients continued access to suitable dump sites by helping to ensure that the permit conditions were met and verifying that assumptions made during the permit review and site selection process were correct and sufficient to protect the environment and human health. Annual monitoring reports are produced for client use and review by all interested parties. In addition to the monitoring performed, regional and headquarters staff provide technical assistance to the clients, including the selection of dump sites, advice on monitoring issues and day-to-day responses to client requests.

It is the policy of the Government of Canada to recover costs for government activities that have resulted in specific benefits received by identifiable clients. The Treasury Board Cost Recovery and Charging Policy allows federal departments, where a specific service, or right or privilege is provided, to fairly charge clients or beneficiaries who benefit beyond what is enjoyed by the general public. The intention to implement cost recovery was announced in the 1995 Government Response to the Recommendations of the Parliamentary Standing Committee on Environment and Sustainable Development on the review of the Canadian Environmental Protection Act (CEPA). Clients were also advised of the proposed monitoring fee during consultations as early as 1994.

The rationale for implementation of cost recovery is based on the Department's ability to adhere to the following principles found in recent Treasury Board policy:

• Equity: User fees directly target those clients benefiting from the access to suitable, monitored disposal sites, rather than having program costs funded by general tax revenues.
• Right and Privilege: By using a permit and accessing certain sites, dredging and excavation clients create the need for dump site monitoring. It is fair that, the cost of monitoring is borne by those creating that environmental/public risk thus earning a fair return for the Canadian public. This is in keeping with Canadian and international user pay and precautionary principles.
• Efficiency: Market analysis suggests that the fee will not significantly effect the demand for permits/disposal. The 2-7% reduction in projected quantity disposed is largely a reflection of cumulative impacts from other cost recovery and restructuring (see Impact Assessment below).
• Accountability: The Department has committed to providing its paying clients with detailed monitoring plans, with yearly consultative and planning meetings to allow for input and adjustments, and with annual reports of how and where the fees were spent. A three-year review of the regional equity of the fees has been promised.
• Partnership: Extensive consultation beginning in 1994, encompassing the entire client base, other government departments, the provinces and interested industry and environmental groups has included two discussion papers with follow-up reports on client comments and three impact assessments, one internal and two by independent contractors. Clients accept the principal of cost recovery for monitoring, but continue to lobby for regional fees (see Consultations). The Department's commitment to re-examine the equity of its national fees in three years may reduce resistance.
• Cumulative Impact: The Department has taken into account the effects on direct and indirect clients and has looked at the incremental and cumulative impacts. This fee represents only 1% of cumulative impacts (see Impact Assessment).
• Mediation: A dispute resolution/appeals mechanism is being developed by the Department.

Public Good/Private Benefit

The public good and private benefit elements are delineated by the Department as follows; the costs to be recovered in this regulation are about 45% of the total costs of the disposal at sea program and represent a specific benefit to an identifiable client. A further 15% is cost recovered for the permit application assessment service. Other elements including enforcement, research, policy and international negotiations are considered public benefit and are not subject to cost recovery. Clients have not contested the split, except that they maintained that no indirect costs should be charged as they are not part of the private benefit. The Department re-evaluated the overhead and adjusted it (see Fee Structure for additional detail). Some indirect costs are associated with the delivery of the monitoring and will be charged to the client.

Given that the impact on clients has been evaluated as about a 5% increase in specific project costs¹ , and represents only 1% of the cumulative costs of restructuring and cost recovery initiatives on the marine sector, it was proposed to recover the full costs of the monitoring portion of the program, rather than partial costs.

Description of the Monitoring Program - What the Fees Will Pay For

The monitoring program, delivered to clients on an annual basis involves:

• a consultation service to allow client input when setting yearly monitoring plans;
• where necessary, adjusting the monitoring program with respect to potential environmental, economic or public concerns on certain dump sites raised during the consultations;
• selecting representative sites (two major, five minor per year);
• assessing movement of the material on the sea floor (e.g. is it staying at the site or moving towards a sensitive area?);
• assessing physical, chemical and biological properties over time (e.g. is there chemical contamination, toxicity or bioaccumulation?);
• taking appropriate management action, to keep the site operational, to modify its use or, in an extreme case, to close a site;
• producing a monitoring report.

Overall, monitoring provides a determination of whether dump sites are still suitable for use by clients and to what extent. It helps satisfy Canadian waste management and pollution prevention objectives for ocean disposal and meet international treaty obligations. The assessment outcome is made available to clients in report format. The use of revenue from Monitoring Fees will also be reported here.

Client Profile

The current client profile suggests 50-70 clients will be affected by the fee, of which almost 70% are from other federal governments; primarily the Department of Public Works and Government Services, the Department of Transport, and the Department of Fisheries and Oceans (Canadian Coast Guard and Small Craft Harbours). Non-government clients include Port or Harbour Authorities (or Commissions or Corporations), private dredging companies, marinas and construction companies. This fee will affect all those who provide dredging services for disposal at sea in Canada and the ports and marinas which commission the dredging, usually to maintain navigable waters. Clients disposing (or commissioning the disposal) of dredged material, are generally responsible for about 90% of the total volume disposed, which will be subject to the fees. The remaining 10% will be disposed by construction companies needing to dispose of clean excavation material. The number of excavation clients increased in 1996, which may be related to increased costs for landfill or ground transportation. Dredged material clients are in transition. It is expected that between 1997 and 2008, the private sector component will increase as the Canadian Coast Guard withdraws from dredging and as the Department of Transport and the Department of Fisheries and Oceans (Small Craft Harbours) reform the port and harbour systems. About 80% of all clients are small volume users who dispose of less than 25 000 cubic metres under a permit.

The client base likely to be affected by the Fee is not expected to be affected directly by the other major marine initiatives set forth in the National Marine Policy such as; the Marine Navigation Services Fees, the Ice Breaking Fees, the St. Lawrence Ship Channel Maintenance Dredging Service Fees, the reform of pilotage or the initiation of emergency response. Other federal initiatives such as the Department of Agriculture and Agri-Food inspection fees will also not impact directly on this client base. The marine community at large, however (e.g. vessels, port users etc.) may be affected indirectly through increases in harbour dues or other charges.

Alternatives

In 1994, the Department examined the pricing strategies of disposal at sea programs in England, France and two jurisdictions in the United States as shown in Table 1. Fees for alternative disposal at landfill sites were also examined.

Table 1 - Fees From Other Jurisdictions

After initial client consultations, two options for fee calculation were developed by the Department and presented to clients in discussion paper.

• Option 1 - A charge per cubic metre of dredged and excavation material disposed. In terms of financial implications, based on 1995 client surveys, this approach would have produced an average increase in project costs of 5.2%. High and medium volume disposal operations would have been most affected with an average cost increase of about 7.3%. Small volume operations (less than 25 000 cubic metres per year), would have been less affected (4.7%). (This was the formula that was chosen based upon lower impacts to most clients and preferences expressed during consultations - the actual fee/impacts are lower based on a revised recovery target).
• Option 2 - provided a formula for the fee which more closely reflected the reality that the cost of dump site monitoring increases with volume but on a diminishing basis. Option 2 would charge clients a fee that becomes smaller on a cubic meter basis as volume increases. Here, large volume clients would have been affected less (6.0% increase in disposal project costs), but small and medium sized clients would have faced a greater average increase in project costs (15.4%). This option was not selected based on greater overall impact to most clients and as many clients expressed a preference for option 1.

Table 2 shows several alternatives suggested by clients over the course of consultations, which after consideration, were not acted upon.

Table 2 - Alternative Suggestions by Clients

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Benefits and Costs

Client Benefits

Clients benefit from the continued use of suitable disposal sites under an ocean disposal permit as it is generally cheaper than land based disposal, and is usually the environmentally preferable and practical alternative for disposal of dredged or excavated material. For these materials, the act of disposal at sea, however, creates the need to monitor the sites for long term effects, in order to safely allow continued access to these sites and meet national and international reporting requirements. Imposing a fee, based on monitoring costs, for the right or privilege of using an ocean dump site under a permit is a fair allocation of costs to a beneficiary. The benefits include:

• Greater client input to the planning and delivery of monitoring through annual regional meetings and follow-up monitoring report.
• Clients are allowed continued access to suitable dump sites.
• Annual monitoring reports for client use and review by all interested parties increases transparency and accountability; clients may use them to promote refinements/efficiencies in the monitoring, as a marketing tool to show good environmental citizenship or for addressing environmental risks.
• Regional and headquarters staff provide technical assistance to the clients, including the selection of dump sites, advice on monitoring issues and day-to-day responses to client requests.

The Full Cost to the Government

The Department referred to Environment Canada (1996) Draft Guidelines to the National Policy Framework for Commercialisation in Environment Canada and to Treasury Board guidelines in the determination of costs. The fair market value of the right or privilege of permitting access to suitable disposal sites, was estimated as being approximately equal to the Department's cost of maintaining that right or privilege through disposal site monitoring at representative sites. Where no monitoring is provided (e.g. for fisheries waste or vessels) site access can be maintained at no additional costs. Costing for dredged or excavation material was based on the minimum annual activity level recommended for monitoring requirements (according to National Guidelines for Monitoring at Ocean Disposal Sites). This would cover two major sites and five minor sites each year. Unit costing for a representative array of types of sites (e.g. shallow vs. deep) was carried out using regional office expenditure information and recent contract bids for similar work. A 41.8% factor was then applied to reflect indirect costs. This resulted in a total annual cost for the monitoring program of $1,248,000 as described in Table 3.

Table 3 - Costs of the Operation of the Dump Site Monitoring Program based on Recommended Minimum Guideline Levels

Fee Structure

Ensuring that costs are equitably attributed to the users was the key consideration in the establishment of the fee structure. The pricing of the permit fee was directly linked to the cost of monitoring. Where no costs were likely to be incurred, no fee was assessed (e.g. fisheries waste). The calculation of the fee was based on costs to provide monitoring at representative dump sites on a per thousand m 3 basis, assuming an average quantity disposed of about 2.1 million m3 of material per year. The average quantity was estimated using historical data from 1991-1995, and future projections provided through client consultations. Costs, discussed below, included total direct costs and indirect costs. Indirect costs, (overhead) include such things as indirect labour, legal and other government supplied services, rent, heat, maintenance, light, power, depreciation, taxes, and insurance. As a result of consultations, it was agreed that, as the majority of clients are other government departments, in particular the Department of Public Works and Government Services, who already pay a portion of these costs, such as heat, rent and OGD services, that they should not pay twice. Therefore, to avoid "double billing", the indirect costs were reduced by about 30% to remove duplicative elements. As there is only a small non-government client base (15-20 clients), this adjustment has been applied to all clients, for reasons of administrative simplicity and cost effectiveness. This revises the applicable cost to about $1 million.

This Regulation proposes a fee of $470 per thousand cubic meters of dredged or excavated material, disposed at sea, pursuant to an ocean disposal permit. To obtain a permit, permittees will pay at least 50% of the estimated Monitoring Fee before disposal operations begin and the remaining 50%, half way through the permit term.

Payments will be made to the Receiver General. The Program will recover monitoring costs. The use of credit cards will not be accepted. Fees will be applied to disposal activity taking place on or after publication of the Regulation in the Canada Gazette Part II.

Revenue Forecasts

Given that clients are well aware of the upcoming fees, it is likely that in the first year, most will apply for their permits before the implementation date. This will result in a greatly reduced income for the first year of cost recovery. Revenues in the neighbourhood of $200,000 to $600,000 are projected for 1998-99. A conservative estimate of revenues for years two to five is in the range of $600,000 to $800,000. In future years, factors such as natural dredging cycles (-12% to +9% since 1988) in addition to factors assessed during the impact assessment such as harbour reorganisation, other fees and taxes and general economic market factors which are not known at this time, may reduce the amount of disposal and the revenue.

Plans for Review of Fees

An accounting of revenues and expenditures will be provided to clients as part of the annual monitoring report. Review of yearly monitoring priorities will be done with client input at the planning phase each year. Clients were informed that it is the intention of the program to review the fees after a five-year period. Following consultations, it was agreed to review after three years, particularly on the issue of regional equity.

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Additional Costs Engendered by the Cost Recovery Regulation

Costs to the Government

Impact assessment estimates a 2-7% reduction in disposal activity following implementation of this fee. Further reductions are possible, as stated above under Revenue Projections. These reductions should not result in a need for additional resources beyond those already in place for this activity, but may reduce monitoring levels, corresponding to disposal levels. Enforcement costs are not anticipated to increase due to cost recovery, but the focus should be on potential illegal disposal, particularly in the first years.

Costs to the Industry

Based on the historical data in Table 4, approximately 7% of clients will bear 73% of the cost of dump site monitoring. Federal Government clients account for the majority of this.

Table 4 - Where the money will come from and example fees (based on 1991-1995 data)

Impact Assessment

An initial impact assessment began in 1995, with preliminary client consultations and a user survey, requesting costing information on a permit-specific basis to gauge worst case impacts at the project level. A 1996-97 Discussion Paper on Ocean Disposal and Cost Recovery, (and follow-up meetings) by the Department, reported on the results of the analysis and offered clients further opportunity for input. Comparison to the Business Impact Test, often recommended by the Treasury Board Secretariat, was undertaken by an independent consultant in: A Review of Business Impact Analyses of Cost Recovery Initiatives at Environment Canada by BCI Regulatory Policy Inc. (1997). The Department's process was found to be equivalent to the BIT process.

A follow-up analysis in 1997 looked at cumulative impacts of other marine initiatives, at competitiveness impacts and at potential reduction in disposal at sea, as a result of the Monitoring Fee and other fees. A second client survey was distributed at this time. The report: Impact of Cost Recovery of Ocean Disposal Monitoring, by CPCS Transcom Ltd. (1997) was concluded in October 1997. CPCS Transcom Ltd. (formally Hickling Corporation) was also the consultant responsible for the 1996 analysis of cumulative impacts of seven major Marine Initiatives under the National Marine Policy. The 1997 contract thus had the advantage of their databases on marine traffic and the thresholds for significant competitive impacts set in consultation with industry. The above documents provide a detailed assessment of the impacts. What follows is a brief summary of the results.

Incremental Impacts as a Result of the Monitoring Fee

1. An average 5% cost increase on a per permit basis - It is estimated that, given the fee of $470 per 1 000 cubic metres, client project costs will increase on average by 4.7%. For the smaller dredgers/users, costs could increase by an average of 4.2% while costs for large and medium volume dredgers/users will increase by 6.6%. Impacts will be equal to or more likely less, as clients will generally be able to spread these costs over a much broader budget base.
2. No diversion of port business or closure of ports, dredgers will pass costs on - The Monitoring Fee alone will not have a significant effect on competitiveness of most clients, meaning that disruption of activity or diversion of business would not be likely to occur. Dredgers indicated they would generally pass on the cost. Proponents (those commissioning disposal) would neither be forced to close operations, nor was diversion of their business to other ports (including US and freshwater ports in Canada) expected. Increased costs per tonne of commercial cargo were estimated at less than $0.02 in a typical port on the east coast and less than $0.01 in a typical port on the west coast. Some port clients did indicate they may have short term difficulty passing the costs on to indirect users (port/harbour users, traffic) due to existing contracts. Long term impediments are unlikely.
3. No significant shift to land disposal - The significant use of other disposal alternatives (land disposal), was not expected, except where land disposal is already in use on the East coast. Clients indicated through the 1997 survey that unless the fee was to have the effect of increasing the project cost by 50% or more, ocean disposal would continue to be more attractive financially. Some excavators and small harbour operators indicated they would go to land disposal, but generally did not support the claim with costing information.
4. No differential regional impacts - On a regional basis, no significant competitive impacts are anticipated and increases to client project costs are expected to be similar in all marine regions based on 1995 survey responses, as seen in Table 5.

   Table 5 - Average projected increase in cost of disposal operations by region, as a result of the proposed fee (based on 1995 survey)

   % Increase in Project Cost	Atlantic	Pacific & Yukon	Quebec
   REGIONAL MEAN	4.32%	4.40%	5.08%

   Some clients suggested a competitive advantage would be given to those conducting operations in fresh water (such as the St. Lawrence or Great Lakes). Freshwater disposal is already under a different regulatory and cost regime and may have different competitive advantages or disadvantages. For example, the new Maintenance Dredging Services Fee could impose similar costs on vessel traffic moving through the St. Lawrence region.

5. Projected 2% reduction in disposal activity from this fee alone - Based on 1997 survey data, for a fee at about this level.

Cumulative Impacts

Three other major initiatives may impact on this client base directly:

1. Port Reform should be neutral - (Department of Transport ) -Eight of the 18 ports slated for transition to Port Authorities are traditional ocean disposal clients. Initial assessment by Hickling Corporation Ltd., in 1996, assumes the impact of port reform will be neutral in most cases. More detailed impact analysis is planned for 1997-98 by each port.
2. Withdrawal of the Coast Guard funding from dredging will increase port costs, but Monitoring Fee is incrementally small - (Department of Fisheries and Oceans) - The Port of Saint John, New Brunswick, and dredging in the Fraser River will be subject to the new Monitoring Fee and to increased dredging costs. The Miramichi River, has reduced its disposal activity and the Monitoring Fee will not apply to fresh water ports. A case study in Saint John (assumed to be typical) looked at the extra dredging costs ($1.8 million), and cost recovery from other Marine Initiatives affecting port clients ($8.46 million). These increases in port related costs are significant. The Monitoring Fee however represents only 2.4% of the total cost recovery fees.
3. Restructuring Small Craft Harbours will have limited effect on direct clients as dredging of active fishing harbours will remain a priority for Small Craft Harbours. Impacts after 2001 may need reassessment - A report provided by Small Craft Harbours indicates that the proposed Monitoring Fee would result in a 3% increase in dredging and disposal costs and the cancellation of one dredging project per year.
4. An additional reduction in disposal of 5% is forecast, for a total of 7% as a result of cumulative impacts. These results are based on the 1997 survey results and the above summary information. A number of clients, particularly public sector clients who operate with fixed budgets, indicated that an increase in total dredging costs due to the Department's cost recovery fee and other initiatives would have to be offset by a reduction in activity. Clients would likely achieve this by reviewing requirements, prolonging the period between scheduled maintenance dredging, or cutting back on some projects. In the short term, this figure is likely to be much higher, due to clients undertaking additional disposal before the introduction of the new fees.

Indirect Client Impacts

1. Cumulative impacts of major Marine Initiatives on indirect clients (vessels, marine community) is moderate. The Monitoring Fee is only about 1% of the cost. As the costs of the Monitoring Fees will need to be passed on, to indirect clients including vessels and port users, the Department examined, on a gross basis, the total amount of the monitoring fee in relation to cost recovery fees or costing of services that the federal government will no longer be providing as a result of the National Marine Policy. There are seven major Marine Initiatives (MI), which according to the 1996 study by Hickling Corporation will cost the marine industry, on an aggregate basis about $75 million in 1997-98 and was assessed as having a "moderate" impact. This compares to the Department's cost recovery target of $1 million, which was assessed to have no significant competitive impacts. Overall, the cost of the Department's program represents just about 1% of the cumulative costs that have been identified. In assessing this information however, it should be noted that MI fees apply to a broader client base as they include the St. Lawrence and the Great Lakes.
2. Indirect clients on the west coast will proportionately pay less than other regions for marine initiatives, including Monitoring Fees - According to the 1996 Hickling Corporation report, the average MI cost per tonne will be $.30/tonne. It is highest in PEI, at $1.30, and lowest for BC at $.093/tonne. The analysis also showed that as a percentage of total transport costs, the Atlantic provinces will bear the highest cost of the Marine Initiatives. British Columbia will experience the lowest impact on transport costs. The Monitoring Fee was estimated at an additional cost of less than $0.02 for cargo moving through a typical east coast port and less than $0.01 for cargo moving through a typical west coast port⁴.

Other Risks

With the introduction of the Monitoring Fee, some clients may choose to avoid payment of the fee through illegal disposal of material. The risk may be greater where the client base is in transition. New clients may not be aware of, or experienced with, the regulations/fees, in which case there may be potential for strong opposition and circumvention of the fee through illegal dumping.

Over the short term, some clients may have difficulty in passing off costs to indirect clients because of existing contracts.

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Consultation

Extensive consultations have been undertaken. All stakeholders (ALL) includes the affected client base (AC), and other interested parties including all other clients (OC), other government departments (OGDs), the provinces (FPAC), Native groups (N) industry (I), consulting (C), environmental groups (ENGOs) and the interested public (Pub). Affected clients are further broken down into dredging (Dredge) and excavation (Excav) clients, small (Sm) and large (Lg) volume and federal government (Govt) and private sector (Priv) clients.

Table 6 shows the schedule of consultations, number of organisations/ individuals sent the documentation or the invitations, the response rate and the "representativeness" of the response.

Stakeholders were informed of the intent to proceed with Monitoring Fees in 1994-95 during consultations on regulatory issues. A user's survey was conducted in 1995-96 to gauge client impacts and solicit opinions on options for the cost recovery fee for dump site monitoring. Details and results of that survey are presented above under Impact Assessment.

In 1996, a discussion paper was distributed to approximately 1,000 individuals and organisations who had expressed an interest in ocean disposal issues. Meetings were held in all regions of the country in January 1997. Approximately 110 people or organisations participated. Two additional meetings were held in June and July 1997 with major clients, to further discuss specific issues. A second survey was circulated, following consultations in 1997, to selected consultation participants to gather further information on the issues of competitiveness, potential for reduced disposal, and on incremental and cumulative impacts. Results of this analysis are discussed under Impact Assessment. It is assumed, that both surveys adequately represent all clients affected by the fee, as they included different size operations, clients from all marine regions (except the north), and government and non-government clients. Overall response was about 50%. It should be noted however, that response from the private sector was limited and excavation clients provided comments but no costing information. Provincial government departments were invited to comment through the Federal-Provincial Advisory Committee. No comments were received. In addition, the Pacific Ocean Disposal Group, which acts as a focal point for input from many west coast clients, elected not to complete the 1997 survey, but provided additional comments. The primary reason given, was a refusal by the Department to negotiate fees on a regional, rather than national basis.

Table 6 - Summary of Consultation Efforts

In general, there was little opposition to the concept of a Monitoring Fee, per se. However, a number of issues were raised during the consultations which are summarised in the following documents: 1996-97 Discussion Paper on Ocean Disposal and Cost Recovery; and 1997 Report on Consultations by the Marine Environment Division, Environment Canada, Ottawa. Major issues and responses are shown in Table 7. It should be noted that some additional issues, such as fee options and the reduction of overhead have been discussed previously (Table 2) and are not repeated here.

Table 7 - Major Consultation Issues

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Compliance and Enforcement

The possible effect of fees on compliance with regulatory requirements will be evaluated on an on-going basis to ensure that cost recovery does not lead to illegal dumping. Training sessions on the regulatory and fee requirements for disposal at sea will be provided on an as needed basis, to encourage compliance.

Compliance mechanisms are provided through the application of the Financial Administration Act and the Canadian Environmental Protection Act and its Regulations.

Appeals/Inquiry Process

A Departmental cost recovery appeals process is being developed.

Communications Strategy

Copies of the Regulations as well as an implementation guide will be sent to all recent and current clients as well as to relevant non-government associations. The Department's Internet home page may be used to announce the introduction of the Regulations and for the distribution of pertinent information.

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Contacts

(819) 953-2265
Email: jim.osborne@ec.gc.ca

Footnotes:

1. Impacts were estimated based on cost increase with respect to individual permits. This is thought to be a worst case scenario as there is usually a broader base upon which to spread the costs - e.g. a government dredging budget, or a port's general operating budget.
2. This assumes 0.7645 cubic yards in a cubic metre and a 1998 US exchange rate of $1.48.
3. This assumes a density of 1.3 tonnes per cubic meter. e.g. value of $33 per tonne.
4. The Vancouver estimate was made using historical data on quantities disposed, estimating the monitoring fee and dividing by the tonnage moving through the port. Saint John was estimated as per the case study presented in the CPCS Transcom Ltd. 1997 report.

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