111 •
  irST 1974
           ECONOMIC ANALYSIS

                    OF

      PROPOSED EFFLUENT GUIDELINES


          PRINTING  INDUSTRY
                   QUANTITY
      U.S. ENVIRONMENTAL PROTECTION AGENCY

          Office of Planning and Evaluation

             Washington, D.C. 2O46O
                  I
                       o

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  Ihis document is available in limited quantities through tlic
L'. S. Environmental Protection Agency, Information Center,
Room W-327 Waterside Mall, Washington, D. C. 20460.
  The document will subsequently be  available  through the
Naiion.il Technical Information Service, Springfield, Virginia
22151.

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EPA-230/1-74-053
                      ECONOMIC ANALYSIS
                              OF
                PROPOSED EFFLUENT GUIDELINES

                      PRINTING INDUSTRY
                          August 1974
                       Contract 68-01-1541
                  Office of Planning and Evaluation
                  Environmental Protection Agency
                      Washington, D.C. 20460
                                     on
                230 South Dearbo^ Street
               Chicago, Hiinois  6060*

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         This report has been reviewed by the Office of Planning and
         Evaluation, EPA, and approved for publication. Approval
         does not  signify  that the contents necessarily  reflect the
         views and policies of the Environmental Protection Agency,
         nor does mention  of trade names or commercial products
         constitute endorsement or recommendation for use.
MVIEOKUEHTAL PROTECTION AGEU6Y

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                                    PREFACE

     The attached document is a contractors' study prepared for the Office of Planning and
Evaluation of the Environmental Protection Agency ("EPA"). The purpose of the study is
to analyze  the economic  impact which could result from  the application of alternative
effluent limitation guidelines and standards of performance to be established under Sections
304(b) and 306 of the Federal Water Pollution Control Act, as amended.

     The study supplements  the technical study ("EPA Development Document") support-
ing the issuance of proposed regulations under Sections 304(b) and 306. The Development
Document surveys existing and potential waste treatment control  methods and technology
within particular industrial  source categories and supports proposal of certain  effluent
limitation guidelines and standards of performance based upon an  analysis of the feasibility
of these  guidelines and standards in accordance  with the requirements of Sections 304(b)
and  306 of the Act. Presented in the  Development  Document are the  investment and
operating costs associated with various alternative control and treatment technologies. The
attached document supplements this  analysis by estimating the broader economic effects
which  might  result  from  the  required application of various control methods and tech-
nologies. This  study  investigates the effect of alternative  approaches in terms of product
price increases, effects upon employment  and the continued viability of  affected plants,
effects upon foreign trade and other competitive effects.

     The study has been prepared with the supervision and review  of the Office of Planning
and Evaluation of EPA. This report was submitted  in fulfillment of Task Order No. 23,
Contract 68-01-1541 by Arthur D. Little, Inc. Work was completed as of August 1974.

     This report  is being released and circulated  at  approximately the same time as
publication in  the Federal  Register  of  a notice of proposed  rule making under Sec-
tions 304(b) and 306 of the  Act for the  subject  point source category. The study is not an
official EPA publication. It will be  considered along  with the information contained in the
Development  Document and any comments received  by EPA on either document before or
during proposed rule making proceedings  necessary  to establish final regulations. Prior to
final promulgation of regulations, the accompanying  study shall have standing in any EPA
proceeding  or court  proceeding only to the extent that  it represents the views of the
contractor who studied the subject industry. It cannot be  cited, referenced, or represented
in any respect in any such proceeding as a statement of EPA's views regarding the subject
industry.
                                        in

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                   TABLE OF CONTENTS

                                                    Page

List of Tables                                             ix

EXECUTIVE SUMMARY                                    xi

 I. INTRODUCTION                                      1

 II. WATER USE IN THE PRINTING INDUSTRY                   3

   A.  CHARACTERIZATION OF THE INDUSTRY                3

   B.  WATER USE REQUIREMENTS                         7

   C.  WATER POLLUTION CONTROL                        9

III. INDUSTRY SEGMENTS                                 11

   A.  TYPES OF FIRMS                                  11

   B.  TYPES OF PLANTS                                 25

   C.  INDUSTRY SUBSEGMENTATION                       33

   D.  SUBSEGMENTATION SUMMARY                       42

IV. FINANCIAL PROFILE OF THE INDUSTRY                   43

   A.  SALES                                          44

   B.  EARNINGS                                       44

   C.  CASH FLOW                                      45

   D.  NEW CAPITAL INVESTMENT                         45

   E.  MISCELLANEOUS FINANCIAL INFORMATION            45

 V. MODEL PLANTS                                      49

   A.  SIC 2711 NEWSPAPERS                              49

   B.  SIC 2721 PERIODICALS AND SIC 2741 MISCELLANEOUS
       PUBLISHING                                     49

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                TABLE OF CONTENTS (Continued)




                                                      Page




 V. MODEL PLANTS (Continued)




    C.  SIC 2751 COMMERCIAL PRINTING, LETTERPRESS         52




    D.  SIC 2754 COMMERCIAL PRINTING, GRAVURE            52




    E.  SIC 2793 PHOTOENGRAVING                         53




 VI. ECONOMIC IMPACT ANALYSIS METHODOLOGY              55




    A.  FUNDAMENTAL METHODOLOGY                      55




    B.  PRICE EFFECTS                                   56




    C.  FINANCIAL EFFECTS                               56




    D.  PRODUCTION EFFECTS AND INDUSTRY GROWTH         57





    E.  EMPLOYMENT EFFECTS                            57




    F.  COMMUNITY EFFECTS                              57




    G.  INTERNATIONAL TRADE EFFECTS                    57




 VII. EFFLUENT CONTROL COSTS                            59




VIII. IMPACT ANALYSIS                                    67




    A.  PROFITABILITY  AND CAPITAL AVAILABILITY EFFECTS   67




    B.  PRICE AND SECONDARY EFFECTS                    69




    C.  SENSITIVITY ANALYSIS                            69




     D.  PRICE EFFECTS                                   71




     E.  PRODUCTION EFFECTS                             73




     F.  EMPLOYMENT EFFECTS                            73
                             VI

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                   TABLE OF CONTENTS

                                                    Page

List of Tables                                             i*

EXECUTIVE SUMMARY                                     xi

 I. INTRODUCTION                                      1

 II. WATER USE IN THE PRINTING INDUSTRY                   3

   A.  CHARACTERIZATION OF THE INDUSTRY                3

   B.  WATER USE REQUIREMENTS                         7

   C.  WATER POLLUTION CONTROL                        9

III. INDUSTRY SEGMENTS                                 11

   A.  TYPES OF FIRMS                                  11

   B.  TYPES OF PLANTS                                 25

   C.  INDUSTRY SUBSEGMENTATION                       33

   D.  SUBSEGMENTATION SUMMARY                       42

IV. FINANCIAL PROFILE OF THE INDUSTRY                   43

   A.  SALES                                          44

   B.  EARNINGS                                       44

   C.  CASH FLOW                                      45

   D.  NEW CAPITAL INVESTMENT                         45

   E.  MISCELLANEOUS FINANCIAL INFORMATION            45

 V. MODEL PLANTS                                      49

   A.  SIC 2711 NEWSPAPERS                              49

   B.  SIC 2721 PERIODICALS AND SIC 2741 MISCELLANEOUS
       PUBLISHING                                     49

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                TABLE OF CONTENTS (Continued)




                                                      Page




  V.  MODEL PLANTS (Continued)




     C.  SIC 2751 COMMERCIAL PRINTING, LETTERPRESS         52




     D.  SIC 2754 COMMERCIAL PRINTING, GRAVURE            52




     E.  SIC 2793 PHOTOENGRAVING                         53




 VI.  ECONOMIC IMPACT ANALYSIS METHODOLOGY              55




     A.  FUNDAMENTAL METHODOLOGY                      55




     B.  PRICE EFFECTS                                   56




     C.  FINANCIAL EFFECTS                               56




     D.  PRODUCTION EFFECTS AND INDUSTRY GROWTH         57




     E.  EMPLOYMENT EFFECTS                             57




     F.  COMMUNITY EFFECTS                             57




     G.  INTERNATIONAL TRADE EFFECTS                    57




 VII.  EFFLUENT CONTROL COSTS                             59




VIII.  IMPACT ANALYSIS                                    67




     A.  PROFITABILITY AND CAPITAL AVAILABILITY EFFECTS   67




     B.  PRICE AND SECONDARY EFFECTS                    69




     C.  SENSITIVITY ANALYSIS                             69




     D.  PRICE EFFECTS                                   71




     E.  PRODUCTION EFFECTS                             73




     F.  EMPLOYMENT EFFECTS                            73
                             VI

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                TABLE OF CONTENTS (Continued)

                                                       Page

VIII.  IMPACT ANALYSIS (Continued)

     G.  COMMUNITY EFFECTS                              73

     H.  INDUSTRY GROWTH                               73

     I.   INTERNATIONAL TRADE                           73

     J.   COMPETITION WITHIN THE INDUSTRY                 73

     K.  ECONOMIC IMPACT OF NSPS                         74

APPENDIX - DERIVATION OF SENSITIVITY ANALYSIS
          FORMULA                                      75
                             VII

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                            LIST OF TABLES

Table No.                                                            Page

  111-1     Distribution by Number of Establishments                    12

  III-2     Distribution by Number of Employees                        14

  III-3     Sales Concentration in Selected Segments of the Printing
           and Publishing Industry                                     15

  III-4     Average Annual Value of Shipments Per Establishment          16

  111-5     Number of Establishments and Annual Value of Shipments
           by Size of Establishment                                    17

  111-6     Industry Segment Concentration and Average Annual Value
           of Shipments by Size of Company                            20

  111-7     Printing Industry Products                                  23

  II1-8     Geographic Distribution of Printing Industry by Employees
           and Annual Value of Shipments                              28

  111-9     Geographic Concentration of Establishments in the Printing
           Industry                                                  29

  111-10    Geographic Concentration of Employees in the Printing
           Industry                                                  30

  111-11    Printing Distribution by Cities                               31

  III-12    Subsegmentation Summary                                  34

  IV-1     Printing Industry Revenues                                  44

  IV-2     Annual Capital Investment                                  46

  IV-3     Financial Profiles of Selected Industry Segments               47

   V-1     Financial Profile of Model Plants                             50

   V-2     Characteristics of Medium- and Large-Circulation
           Newspaper Plants             '                              51
                                   IX

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                        EXECUTIVE SUMMARY

     It is the purpose of this study to analyze the economic impact of the cost of
proposed Effluent Limitation Guidelines and New Source Performance Standards
on the printing and publishing industry pursuant to  the Federal Water Pollution
Control Act, as amended (1972).

     This report deals with those segments of Major Group 27 that are concerned
with printing, and printing and publishing, and those establishments that perform
platemaking services for the printing trade. Specifically, it includes the following
industry segments:

     SIC Code                    Industry
       2711       Newspapers: Publishing, Publishing and Printing.
       2721       Periodicals: Publishing, Publishing and Printing.
       2731       Books: Publishing, Publishing and Printing.
       2732       Book Printing.
       2741       Miscellaneous Publishing (but not micropublishing).
       2751       Commercial Printing, Letterpress and Screen.
       2752       Commercial Printing, Lithographic.
       2753       Engraving and Plate Printing.
       2754       Commercial Printing, Gravure.
       2761       Manifold Business Forms.
       2771       Greeting Card Publishing.
       2793       Photoengraving.
       2794       Electrotyping and Stereotyping.
       2795       Lithographic Platemaking and Related Services.

                          Industry Characteristics

     The printing industry is composed  of a heterogeneous collection of over
30,000 companies that range in size from  a few employees  to  several thousand.
Each of these businesses  performs one or more of the steps necessary to the
bulk-production  of printed materials: the publication function, typesetting, plate-
making, printing, binding, etc.

     Some  companies are  organized to provide all of the services required for a
given product (e.g.,  newspapers and some  periodicals) or for several product
categories  (commercial printers). The industry, however, tends to specialize in
that  some companies produce only newspapers; others produce only periodicals,
or books, or manifold business forms, etc. Even within the corporate framework
of the larger printing companies one finds plants dedicated to printing books,
other plants  that  print only  periodicals  and still  others that do  commercial
printing. This specialization in product follows  directly from the fact that the
                                     XI

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 SIC Code          Industry                 Size          Number of Plants
   2711       Newpapers                  Large                400
   2721       Periodicals                  Large                  4
   2741       Miscellaneous Publishing      Large                  4
   2751       Commercial Printing,
              Letterpress                  Large                  4
   2751       Commercial Printing,
              Gravure (Roll making)        Medium                8
                      (Printing)            Large                 34
   2793       Photoengraving              Large                 17

     It  is interesting  that  in all  industries  where process  wastewater is  being
generated it  is being generated mainly by  the  large companies.  In those few
instances in which small companies are producing waste that is not compatible
with municipal treatment systems, the volumes involved are small and there are
more economic alternatives for disposal than those supplied in the  Development
Document.

                          Industry Financial Profile

     Many of the companies in the printing and publishing industry are closely-
held corporations. As a result, financial information is considered proprietary and
is generally difficult to obtain. However, many companies in the industry belong
to trade associations and participate annually in association-sponsored financial
studies of the various industry segments. In many cases the results of these studies
are sold to help defray the cost of the study. In other  cases the results are
sometimes available from participating companies. The largest trade association in
the industry is  Printing Industries  of  America,  Inc. Its membership represents
firms which account for more than 80% of all the printing produced  in the United
States.

     Clearly, most segments in the printing and publishing industry are strong and
healthy.  They are able to finance new investments, to take advantage of new
technology and to remain competitive and look optimistically to the  future as one
of expanding markets  and growth opportunities. The exception is the Electro-
typing and Stereotyping Industry (SIC 2794) which is a dying industry  and is
expected to be extinct by 1980.

     The printing and publishing industry  generally  does  not  publish data on
earnings. The best source of such information is  the Ratio Studies,  e.g., the PIA
Ratio Studies and similar studies carried out by other industry segments.

     Although the investment in  each of the segments for new capital improve-
ments  w,ll vary  from  year to year by industry needs and new technological
                                   xni

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developments, the data reflect an industry whose plants are attempting to main-
tain  their competitive position vis-a-vis other plants and other  communication
industries and this trend is expected to continue.

                                Model Plants

     Financial models of representative plants studied for possible impact were
constructed for  the Newspapers;  Periodicals; Miscellaneous Publishing; Commer-
cial  Printing, Letterpress; Commercial Printing,  Gravure and  Photoengraving
industries.  In all cases the models were for large plants, i.e., those having more
than 100 employees, because they are the principal  sources of significant amounts
of process contact effluent in their platemaking  operations.  Small and medium
printing  plants generally rely upon purchased services for their  plates and thus
avoid such problems.  Moreover, the small and medium plants that may be etching
metal for platemaking purposes have the option of disposing of their relatively
small amounts  of waste  by  means  that  do  not require  significant  capital
investments.

                   Economic Impact Analysis Methodology

     In our determination of the impact of pollution control costs on the printing
industry, the principal  considerations were  the effects of  the  costs on profit
margins  and  the determination of whether  the costs could  be passed on in the
form of higher prices for printed product. However, a host of secondary effects
were also  considered. These included possible  effects on level of production,
employment, growth of the company, ability of the company to raise new capital,
hardships on the community, and international trade.

     The economic analysis was concentrated on those segments of the printing
industry which use technology that causes significant water pollution. The frame-
work for the analysis  was the model plants defined  for each of the segments
studied.  The feasibility of investing capital  to control pollution  was assessed on
the basis of the effect of the increased cost  on profitability, a comparison of the
required  capital expenditure for pollution control  with annual new  capital
expenditures  for each  of the models, and estimates of the revenue or  price
increases necessary to recover the additional expense and provide the same retun)
on assets with the expanded asset base. The data was also analyzed to determi  :
the probable effect of BPT and BAT standards on plant closures directly related
to pollution  control requirements. The sensitivity of the analysis under different
conditions, such as those  that would  obtain because  a printing plant did not
conform exactly to a  model plant, was also considered.
                                     xiv

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                            Effluent Control Costs

     The control COMS  used  in this analysis  are those presented in the Develop-
v.-ivrti Document for Proposed Effluent Limitations Guidelines.

     The BPT requirements for the printing and publishing industry  have been
determined to ho a combination of flow equalization and reduction of pollutants.
" >s  BAT requirements  for this industry include a further reduction of pollutants
to specifi-d levels.

     Wastes from  the Hat-bed letterpress, offset and screen  printing operations
will be required to meet only the limitations for BODS, pH, phenols, TSS, oil and
grease,  and organic  solvents for  BPT,  BAT  and  NSPS  treatment levels.  No
p.-etreatment is required.

     Wastes from  gnmir".  flexography and rotary letu  press operations will  be
required to meet all  limitations specified. NSPS requ'.rcr.iems aix identical to the
SAT  icquirements. Pretreatment  requirements for new sources are  the same as the
3AT requirements.

                              Impact Analysis

     This industry is unusual in  that the main source of pollution is the larger
companies. Furthermore, the polluting processes themselves are concentrated in
one part cf the operation,  platemaking, and in particular, those steps that involve
etching metal with acid. Although some small photoengravers still etch metal, the
volume of acid waste generated is easily disposed of by drumming without adding
significantly  to  the  cost  of the plates.  The large  companies continue to  use
DoUuting technology because of their large investments in printing equipment, the
need  for duplicate  plates, the  demand  for top-quality printing for long-run
•-."'.ional ads, and the cost of conversion to non-polluting printing methods. Thus
"- c analysis focuses on  the profitability, captial availability and price effects for
 '•'•- i.?irse irodel plants.

     "?as.ic to our analysis is the creation of a hypothetical model  plant for each
segment with prototypical financial data. Because our decision of no impact is
b?:ed  on an  analysis   of  these hypothetical plants,  a  sensitivity analysis was
j : ."formed to determine how different from the prototype a plant can be before
the cost of the water pollution control system has significant impact. Thus three
sectors  were  analyzed — Newspapers; Commercial Printing, Gravure; and Photo-
engraving —  because  each  contained plants  of  widely varying financial perfor-
:**< -ic;.  Since the ability  of a company to  afford  the water pollution control.
syslem  is a function in part of its size, revenue  and net assets were used  as
appropriate measures of size.  The sensitivity analysis was designed to determine
                                    xv

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the minimum-sized company able to afford the specified effluent control systems.
It demonstrates that not only is the model company within a sector unaffected by
the standards, but that no company in the sector would be impacted. The loss in
after tax ROI for all segments falls in the range of 0.06 to 0.92 percent for BAT
control  costs. The annual costs  as a percent of sales for all segments fall in the
range of 0.06 to 1.94.

     The impact  analysis indicates that the amount of investment  required for
control  of water pollution in the industry is such that no price increase would be
anticipated.  Duiing the past year the overall increases in the cost of paper, plates,
labor, and equipment have  overshadowed the small effect of the cost of pollution
control  on  the cost of the  preparation of plates.  The average  cost  of the
platemaking service is 2 to  5% of the cost of the  printing. If the total burden of
the water pollution  control investment had to be borne  by the cost center
represented  by the platemaking  operation in the printing plant and if the  com-
pany were making a  minimum of 100 plates a day (5000 plates per year), the
annual cost  would be $15,000  or about $3 per plate. Such an increase in the price
of plates would be very small in  comparison with other price increases that have
been affecting  this industry. Moreover, the  increase will be  distributed over the
total number o" impressions being printed, so the overall effect will be even  more
miniscule. Thus, no significant price increases are expected as a direct result of the
cost of  pollution  control equipment except in those service industries where the
total amount of the  cost of pollution  control is directly attributable to the plate,
since this is  the product that is being sold. It is expected, however, that this price
increase can  be readily passed on  to the printer.

     For industry suppliers and consumers the competition between  the different
types of printing  is expected to continue. In the past ten years offset printing has
been making inroads into letterpress  "territory" at higher and higher levels of
printing impressions  per run or  per job order. It  is  expected that this trend will
continue. In recent  years there  has been an increasing use of plastic plates to
replace  metal plates  in the  letterpress  industry and it is expected  that this trend
will  continue.  Insofar as the  need for water pollution control  equipment and
associated costs could be a factor, they would promote decisions  favoring either
offset printing or a  change to  plastic plates in  letterpress  operations, but the
incremental  effect of the cost  of water pollution control on the decision that has
already  been made by the industry is expected to be very small.

     The new source performance standards will not affect the growth  of any
segment of  the printing industry. No effect  on prices is  anticipated because of
new source  performance standards and new  plant locations probably will not be
affected either. The  trend  in recent years for the larger plants to build in  more
rural areas where they have access to land and good transportation will continue
independent of the  requirements for  water pollution control. The decision to
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build domestic plants versus foreign plants will not be influenced by the proposed
guidelines. Our analysis shows the balance of payments will not affect location or
dollar volume of printing. In all cases pretreatment  costs are less than BAT costs
and since no  impacts were  found for BAT  costs no  separate analyses were
conducted for pretreatment costs. In addition to the lack of impact noted above
there will also be no adverse effects on production, employment, communities,
industry growth or international trade.
                                   xvu

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build domestic plants versus foreign plants will not be influenced by the proposed
guidelines. Our analysis shows the balance of payments will not affect location or
dollar volume of printing. In all cases pretreatment  costs are less than BAT costs
and since no  impacts were  found for BAT  costs no  separate analyses were
conducted for pretreatment costs. In addition to the lack of impact noted above
there will also be no adverse effects on production, employment, communities,
industry growth or international trade.
                                   xvu

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                    \
                            I.  INTRODUCTION
     The purpose of this study is to analyze the economic impact of the cost of
 the  proposed  Effluent Limitations Guidelines and  New Source  Performance
 Standards on the printing and publishing industry. These requirements are being
 developed  by  EPA in response to the Federal Water Pollution Control Act,
 Amendments of 1972.

     For purposes  of this analysis, four levels of effluent  limitations will  be
 considered for each segment:

     (1) Best  practicable control technology (BPT) currently available - to
         be met by industrial dischargers by July 1 , 1 977.
                   »
     (2) Best  available technology (BAT) economically achievable — to be
         met by all {industrial dischargers by July 1 , 1 983.

     (3) New source performance standards (NSPS) - to be applied !o all
         new  facilities (that  discharge directly into navigable waters) con-
         structed after the promulgation of these guidelines (approximately
         November1!, 1974).

     (4) New source pretreatment standards - to be applied to all facilities
         (that discharge  to municipal systems) constructed  after the pro-
         mulgation 'of these guidelines (approximately November 1, 1974).

     The major constituents of concern in  the printing and publishing industry
 are the  metal salts generated in the etching of plates used for printing. The metals
 involved include aluminum, chromium, copper, magnesium, and  zinc. All of the
 organic  materials present  in wastes from this  industry are believed to be easily
 biodegradable and to present no problem in setting effluent limitations.

     The BPT Standards for one subcategory - consisting of flat-bed letterpress,
 offset and  screen printing - have  been defined in the proposed Effluent Limita-
 tions Guidelines Development Document, as normal biological waste treatment
 with the costs of achieving the BPT Standards in these segments being essentially
zero. Such  plants that discharge to surface waters must provide normal biological
 treatment for  the sanitary wastes originating in the plants. Because the sanitary
waste flows will far exceed the process wastewajtejr flow, the marginal cost of the
biological treatment system has been assigned to the requirement to treat sanitary
wastes and  not  the BPT requirement to treat process water. Some metal salts are
generated in the etching of  bimetallic  and  trimetallic offset printing  plates.
However, the amount of metal removed in the developing step is small compared
to, for example, < photoen,;|raving prepared for letterpress  use. Accordingly, it is

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believed that the use of these plates will not constitute a significant source of
pollution in the limited applications in which they are used.

     Treatment levels for BAT and NSPS for flat-bed letterpress, offset and screen
printing are equivalent  to that of BPT.  The cost  of achieving BAT and NSPS
Standards is, therfore, also zero, no treatment being required for new sources. No
cost data are provided for these standards; thus no impact analysis has been made
on these segments of the printing industry.

     This report deals with  those segments of Major Group 27  that are concerned
with printing, printing  and  publishing and those  establishments that perform
platemaking services for the  printing trade. Specifically, it includes the following
industry segments:

     SIC Code                    Industry
       2711        Newspapers: Publishing, Publishing and Printing.
       2721        Periodicals: Publishing, Publishing and Printing.
       2731        Books: Publishing, Publishing and Printing.
       2732        Book Printing
       2741        Miscellaneous Publishing (but not micropublishing).
       2751        Commercial Printing, Letterpress and Screen.
       2752        Commercial Printing, Lithographic.
       2753        Engraving and Plate Printing.
       2754        Commercial Printing. Gravure.
       2761        Manifold Business Forms.
       2771        Greeting Card Publishing.
       2793        Photoengraving.
       2794        Electrotyping and Stereotyping.
       2795        Lithographic Platemaking and Related Services.

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              II.  WATER USE IN THE PRINTING INDUSTRY

     The following sections provide an overview of the printing industry, with
comments  on pertinent  trends and emphasis on  water use requirements  and
sources of water pollution.

A. CHARACTERIZATION OF THE INDUSTRY

     The printing and publishing  industry is composed  of a heterogeneous col-
lection of over 38,000 companies that range in size from a few  employees to
several thousand.  In total it employs  about one million people and has sales of
over $28 billion per year. Each of these businesses performs  one or more of the
steps necessary to the  bulk-production  of printed  materials:  the publication
function, typesetting, platemaking, printing, binding, etc.

     Some companies are organized to provide all  of the services  required for a
given product (e.g., newspapers and  some periodicals)  or for several product
categories (commercial printers).  The industry, however, tends to specialize in
that some companies produce  only newspapers; others produce only periodicals,
or books, or manifold business forms, etc. Even within the corporate framework
of the larger printing companies  one  finds plants  dedicated to printing books,
other  plants that print  only periodicals and still  others that do commercial
printing. This specialization in product follows directly from the fact that the
specialized equipment needed  for  economical production of one type of product
frequently is neither optimum nor competitive for another product.

     Printing itself is intrinsically non-polluting; that is, the process  of transferring
ink from a printing plate to paper in no way involves contact process water and
does not  in  itself cause  water pollution. The potential of any segment of the
industry to cause water pollution  is in general only indirectly associated with the
type of printing  process used. It is  related  most directly  to  the platemaking
operation.  Only  those platemaking operations  that involve metal etching or
electroplating steps are possible significant sources of pollution. The pollutants
are usually  strong  mineral acids  and  salts of  such metals as copper,  zinc, and
magnesium in the case of metal etching and salts of copper and chromium from
electroplating processes.

     Recent developments in printing plate technology offer alternatives to metal
processing in the form of  organic photopolymer materials.  These materials can
sometimes be etched with compressed air, water or detergent  solutions to provide
either  satisfactory engravings or complete printing plates. While such plate ma-
terials  are  not completely satisfactory for all  applications, they are  being im-
proved and their use is  growing. The waste  materials  from such platemaking
processes  are biodegradable and compatible with municipal treatment systems.

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Still other  letterpress plate materials are etched  with organic solvents. The
solvents are usually reclaimed  by distillation and the polymer either reused or
introduced into the solid waste  stream.

     The  great majority of printing companies and the industries that service
them are  located in urban  areas and are believed to discharge their effluents to
municipal systems. According to the Guidelines Document a review of permit files
as of September 1973 showed that 33 applications had been received from the
printing industry. Of  this total, 22 were for permits to discharge  non-contact
cooling water and/or boiler blow-down, water. We believe  that  a negligible
percentage of printing or platemaking companies discharge process waste waters
to navigable streams.

1. Printing Methods

     The most widely used printing techniques are letterpress, offset lithography
(offset) and gravure. Other processes such as screen printing and intaglio (steel
plate printing) are more highly specialized.

     a. Letterpress

     In this process ink is applied directly  from a relief printing plate to  the
surface to be printed. Relief plates are made by:

     (1)   setting or casting type (flat-bed letterpress)

     (2)   molding a duplicate  plate from an  original (stereotype, as in the
          newspaper industry)

     (3)   electroplating a conductive base molded from an original (electro-
          type for magazine ads)

     (4)   etching a metal or photopolymer (plastic) plate

Processes (1) and (2) and the photopolymer portion of process (4) are not sources
of water  pollution. Spent liquors  from process (3) and  the  metal  portion  of
process (4)  consist of highly acid metal salts  which are potential  sources  o,
pollution.

     The letterpress process is the oldest printing process in the industry and one
where little growth is expected.

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              II. WATER USE IN THE PRINTING INDUSTRY

     The following sections provide an overview of the printing industry, with
comments  on pertinent  trends and  emphasis on  water  use  requirements and
sources of water pollution.

A. CHARACTERIZATION OF THE INDUSTRY

     The printing and publishing industry is composed of a heterogeneous col-
lection of over 38,000 companies  that range in size from a few employees  to
several thousand.  In  total it employs  about one million people and has sales of
over $28 billion per year. Each of these businesses performs one or more of the
steps necessary to  the  bulk-production  of printed  materials: the publication
function, typesetting, platemaking, printing, binding, etc.

     Some companies are organized to provide all  of the services required  for a
given product (e.g.,  newspapers and  some periodicals)  or  for several  product
categories (commercial printers). The industry, however, tends to  specialize in
that some companies produce only newspapers; others produce only periodicals,
or books, or manifold business forms, etc. Even within the corporate framework
of the larger printing companies one  finds plants  dedicated to printing books,
other plants that print  only periodicals and still  others that do commercial
printing. This specialization in product follows directly from the fact that the
specialized equipment needed for economical production of one type of product
frequently is neither optimum nor competitive for another product.

     Printing itself is intrinsically non-polluting; that is, the process of transferring
ink from a printing plate to paper in no way involves contact process water and
does not  in itself cause  water pollution.  The potential of any segment of the
industry to  cause water pollution is in general only indirectly associated with the
type of printing  process used. It  is  related  most directly to the platemaking
operation.  Only  those platemaking  operations  that involve metal etching or
electroplating  steps are possible significant sources of pollution.  The pollutants
are  usually  strong mineral acids and  salts of  such metals as copper, zinc, and
magnesium in  the case of metal etching and salts of copper and chromium  from
electroplating processes.

     Recent developments in printing plate technology offer alternatives to metal
processing in the form of  organic  photopolymer materials. These materials can
sometimes be etched with compressed air, water or detergent solutions to provide
either satisfactory engravings or  complete printing plates. While  such plate ma-
terials are  not completely satisfactory for all  applications,  they are being im-
proved  and their use is  growing.  The waste  materials  from such platemaking
processes  are biodegradable and compatible with municipal  treatment systems.

-------
Still other letterpress plate materials are etched  with organic solvents. The
solvents are usually  reclaimed by distillation  and the polymer either reused or
introduced into the solid waste stream.

     The great majority of printing companies and the industries that service
them are located in urban areas and are believed to discharge their effluents to
municipal systems. According to the Guidelines Document a review of permit files
as of September 1973 showed that 33 applications had been received from the
printing industry.  Of  this total, 22 were for permits to discharge non-contact
cooling water and/or boiler  blow-down, water. We believe  that a negligible
percentage  of printing or platemaking companies discharge process waste waters
to navigable streams.

1. Printing Methods

     The most widely used printing techniques are letterpress, offset lithography
(offset) and gravure. Other processes  such as screen printing and intaglio (steel
plate printing) are more highly specialized.

     a. Letterpress

     In this process ink is applied  directly  from a relief printing plate to the
surface to be printed. Relief plates are made by:

     (1)  setting or casting type (flat-bed letterpress)

     (2)  molding a duplicate plate from  an  original (stereotype, as in the
         newspaper industry)

     (3)  electroplating a conductive base molded from an original (elecjro-
         type for magazine ads)

     (4)  etching a metal or photopolymer (plastic) plate

Processes (1) and (2) and the photopolymer portion of process (4) are not sources
of water pollution.  Spent liquors  from  process (3) and the  metal portipri of
process (4) consist  of highly acid metal  salts  which are potential  sources o<
pollution.

     The letterpress  process is the oldest printing process in the industry and one
where little growth is expected.

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     b.  Offset Lithography,

     Offset lithography consists of printing from a plane surface, as opposed to
printing from a relief surface. It is based on the principle that oil (ink) and water
(aqueous fountain solution) do not mix. When the moistening rolls and the inking
rolls on the press contact the printing plate in sequence, the former applies a small
amount of aqueous  fountain  solution to the non-image areas (which are chem-
ically different from the image areas) and the inking rolls apply ink to the image
areas while maintaining a sharp interface between the two.

     Instead of the  printing plate contacting the surface to be printed, as is the
case with  letterpress printing, the printing plate offsets the  ink  onto a rubber
blanket roll which, in turn,  contacts the paper to be printed and transfers the ink
to it. This  printing process is non-water-polluting. Preparation of the plate surface
is essentially a photographic process.

     There are two  major types  of  offset printing — sheet-fed printing and web
printing -  and each  has quite different technical and economic requirements and
characteristics. As the names imply,  sheets of paper are used in one case and rolls
of paper in  the  other. Offset has  been  the most rapidly growing  method of
printing in this country,  partly because of its compatibility  with photocompo-
sition. Web offset is  the faster growing segment of offset printing and is expected
to continue to be so.

     c.  Gravure
                         i
                  i
     Gravure printing is the opposite of relief printing in that the image is formed
by depressions in the printing plate.  In use, these depressions  are filled with ink;
the surface of the plate is wiped clean with  a doctor blade; and  the ink is
transferred, by intimate contact, to the surface to be printed.

     In  preparing a gravure cylinder, one etches the metal, usually copper, in the
desired  pattern either chemically or mechanically. There is also the requirement
of electroplating  gravure cylinders  with copper and  chromium. Electroplating
with copper provides the basic plate surface: chromium plating provides improved
gravure  cylinders  for  long runs. Because chemical etching  and metal plating
involve the use of strong acid salts and other metal salts are  by-products, there are
sources  of  water  pollution in gravure  cylinder preparation. The printing process
itself, however, does not contribute to water pollution.

     d.  Intaglio Printing

     The intaglio  printing process, a  variation  of gravure printing, is used mainly
to print currency, stamps, and stock  certificates.  In the preparation of intaglio

-------
plates the original engraving is usually made mechanically. Duplicate plates are
made by a process quite similar to that used for electrotypes; i.e., electroplating
on a conductive base molded from the original. The water pollution potential of
this process is similar to that of the electrotype process.

     e.  Screen Printing

     This method of printing utilizes a fine-coated silk, nylon or metal screen that
carries an image prepared by selectively removing portions of the coating. In use,
a squeegee forces the ink through the screen to form an image on a substrate that
is in intimate contact with the second side of the screen.

     Screen printing is used in those applications where conventional  printing
would not be possible or convenient because of size or shape or surface texture of
the material  on which  the printing is to be done.  It is also used in applications
where only  a few impressions  are required or where special  artistic effects are
desired.

     The process of making the screen can be either mechanical or photographic.
In the former case no  water pollution should  be associated with "plate" prepa-
ration. In the latter  case pollution would be similar to that of other photographic
operations. The printing operation itself is non-water-polluting.

2. Photography

     Three types of photographic operations are commonly employed in printing
and platemaking plants: film developing, plate developing (e.g., offset plates), and
photoengraving (e.g., surfaces of letterpress plates or gravure cylinders).

     Conventional photography, in which page-sized  silver-base positive  or nega-
tive film is developed, is typical of the operations in the photographic industry. In
operations of any size - e.g., a large newspaper — the silver from the developing
bath is reclaimed, mainly for economic reasons. The remainder of the process uses
a large amount of water relative to the small amount of material that is removed
from the photographic  film. The organic materials that enter the waste stream are
compatible with typical municipal treatment processes.

     In  the  usual offset platemaking operations, a light-sensitive coating on the
plate  is exposed  to  light through film. The areas struck by the light are insolu-
bilized and become  the image on the plate while the  unexposed portions remain
soluble  and  are removed in the developing step by washing. The coating is usually
water soluble, in which case the  plate is developed  with water, but  oil-soluble
coatings may also be used.

-------
     The preparation of photoengravings or entire letterpress printing plates by
etching  metal  with  strong acids is a source of water pollution.  In areas of the
printing industry where these processes are widely used (e.g., newspaper printing),
there has been a trend to the use of photopolymer materials. The main attraction
of the  photopolymers is that they can be etched with  water, and in  some cases
with compressed air. The materials removed during the  etching process are either
disposed of in  the solid waste stream or discharged with the waste water. They are
biodegradable  and compatible with municipal treatment systems. In recent years
much attention  has been devoted  to research and development on letterpress
plates that can be processed in  ways that completely avoid the problem of water
pollution.

B. WATER USE REQUIREMENTS

1. Cool ing Water

     None of the three basic printing processes has any unusual requirements for
non-contact cooling water. Screen printing and sheet printing processes in general
do not require cooling water.

     In the preparation  of printing plates  by mechanical engraving or  by hot
metal casting, some non-contact cooling water may be  used but there should  be
no  associated  pollution, nor should there be any significant rise in the  tempera-
ture of the water because of the relatively small volumes of cooling water that are
involved.

     Some of  the moving parts  of printing presses are water cooled, but the water
does not  come  in  contact  with  the printed product and is  not contaminated.
Water is used in chill rolls that  cool the printed paper as it emerges from drying
ovens in heat-set printing operations.

     None of  this water is subject to contamination and many plants refrigerate
and recycle their cooling  water. In solvent recovery operations, such as those
required in the  gravure printing industry,  considerable cooling water  could  be
used, the temperature of which  might be raised significantly.

2.  Process Water

     Letterpress printers who prepare their own plates use water in the photo-
graphic department, where  material to  be  printed is prepared, and the develop-
ment of  most metal and plastic plates requires water. The principal difficulty
derives  from the etching of metal plates in  strongly acidic baths. Water is used in
these baths and additional  water is used to rinse  the  plates. Zinc, copper, and
magnesium metal ions are typical pollutants.

-------
                            The offset printing process uses water in the photographic department, in
                       the development  of plates for lithographic printing,  and in preparing plates for
1                       reuse after storage. In so doing, small amounts of normally biodegradable material
'                       are introduced into  the  wash water but this  material does  not represent  a
|j                       significant source of pollution. Some lithographic plate developers are emulsions
i                       that contain phosphoric acid,  gum arabic, reinforcing resins and solvents. The use
f                       of these materials also represents small additions to the wash water. There are also
                       bimetallic and trimetallic offset plates whose development involves the etching of
,                       thin layers of metal. These plates represent a small percentage of the total offset
                       plates  used.  Their use does  not appear to represent a significant source  of
                       pollution in a typical offset printing plant.
i-
                            Water is used  in the printing operation to  moisten the non-image areas of
                       offset plates before the  plates  are inked, but this water dissipates into the printed
                       product.  In  some  printing- e.g., offset printing— alkali, alcohol and/or phos-
                       phoric  acid may be added to the fountain solution, but these also end up in the
                       product.

                            In the preparation of gravure  cylinders,  water is  used in  the photographic
                       department and in the preparation of the gravure rolls if the acid etching process
                       is  used. An  acid etch (iron chloride) introduces  copper into the bath and these
                       metal ions (iron and copper) are a source of pollution. Some gravure processes use
                       water-thinnable inks, but these represent a pollution hazard principally  during
                       clean-up operations.

                            The screen printing process uses water in the photographic department and
                       in  the preparation of the screen for printing. This technology resembles that used
                       in  preparing  lithographic plates, and introduces a small amount  of essentially
                       biodegradeable  material into the water.  Some of the smaller shops still use  silk
                       screen  coatings that contain sodium or potassium dichromate but these  should
                       not produce a significant level of pollution.

                            In any  of the printing plants that include bindery operations, water dilutable
                       adhesives might be used, and some of these materials would in all probability be
                       introduced into  the waste stream during clean-up. Most are biodegradable.  In
                       general, however, water-base adhesives end up in  the product. Many binderies usr
                       hot melt adhesives which, of course, are non-water-polluting.

                       3.  Clean-Up Water

                            The possibility of water pollution from  press clean-up  operations is minor
                       because the  oils and pigments used in  printing inks normally  are not water
                       soluble. Organic  solvents,  therefore, are  used in the  clean-up operations. The
                       normal procedure is  to wipe  printing plates and press parts with  rags wet with
                       organic solvents, with the rags frequently being recovered by commercial cleaning.

                                                            8

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    In gravure and flexographic printing some water-based inks are now in use
and there is a hazard of water contamination during the clean-up operations. The
gravure process, however, is usually used for long-run printing jobs, so the amount
of clean-up required does not represent a heavy load on the waste system. When
solvent-based inks are used in this printing process the waste is usually collected in
a drum and  similar procedures  could  be followed  with the waste from the
water-based inks.

C. WATER POLLUTION CONTROL

    No unusual difficulties are anticipated in controlling water pollution levels.
In acid etching operations the concentration  of metals can be high but the total
volume of water used is frequently small. The problem should yield to established
techniques  for removing any oily materials from the surface of the bath: precipita-
tion of the metals, sedimentation or filtration, and control of pH in the effluent
water.  Alternatively, with the  small amounts  of contaminated  water  that are
anticipated in  the shops of small photoengravers, and platemakers, it would not
be unusual to have the contents of the bath neutralized, drummed, and taken to a
sanitary land-fill operation. Rinse water is frequently very small in volume and is
sometimes used as make-up water in etching and plating baths.

    The Development Document For Proposed Effluent Limitations Guidelines
and New Source Performance Standards for the printing  and publishing industry
describes the recommended  technology  for achieving the guidelines and will  be
published  as a separate report by EPA. The reader is, therefore, referred to that
document  for technical descriptions of proposed BPT,   BAT, NSPS,  and  new
source pretreatment standards.

-------
                       III. INDUSTRY SEGMENTS

     The purpose of this chapter is to provide a screening of the industry as a
basis for narrowing the study so as to focus primarily on those segments that are
likely to be impacted.

     Because  of  the general relationship between the printing process used and
the water pollution potential, the economic impact analysis would be simplified
by segmenting the industry by printing process. Moreover, the technical  Con-
tractor segmented the industry in that manner and it would  be  convenient to
adopt the same  segmentation. Many companies, however, use more than one
printing process and  do not report  sales and earnings separately. Moreover,
company operations overall tend to follow SIC code categories. Consequently, the
segmentation  of  the industry must be product oriented and hence follows the SIC
codes. In  a number of cases, however,  subsegmentation by printing process is
useful and therefore has been used as  a means of grouping those  parts of an
industry that are similarly impacted.

     A structural characterization of the industry is provided showing the types
of companies, types  of  establishments, number of establishments and their em-
ployment  by  segment.  Each segment is  analyzed and subsegmented where indi-
cated, and those segments and subsegments that are most likely to be impacted
are identified. Included also is a discussion  of the trends taking place in each
segment, since some of these trends represent switches in technology that will be
accompanied by  a reduction in pollution potential.

A. TYPES OF FIRMS

     In the opening paragraph of his book,  The Printing Industry, * Victor Strauss
states, "The printing industry is a collective name for a  wide variety of different
industries, crafts, and trades which belong  together because they all  serve funda-
mentally similar and related purposes within our  modern communications sys-
tem." According to the Census of Manufactures, preliminary 1972  data, there are
38,288 establishments and 969,900 employees in  the segments covered by this
study.

1. Number of Plants

     Table III-l  shows the distribution by number of establishments and number
of employees in  the various industry segments with which this study is concerned.
Of the  14 segments  included, only five  represent more  than 5% of the industry
total, measured either as establishments or by employment.
  Published by Printing Industries of America, 1967.


                                    11

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                                              TABLE IM-1

                               DISTRIBUTION BY NUMBER OF ESTABLISHMENTS
SIC
CODE
2711
2721
2731
2732
2741
2751
2752
2753
2754
2761
2771
2793
2794
2795
INDUSTRY
Newspapers
Periodicals
Book Publishing
Book Printing
Misc. Publishing
Comm. Print., L.P.
Comm. Print., Litho
Engraving and Plate Print.
Comm. Print., Gravure
Manifold Bus. Forms
Greeting Card Publishing
Photoengraving
Electrotyping and Stereotyping
Litho Platemaking Services
NUMBER OF
ESTABLISHMENTS*
8,022**
2,510
1,186
685
2,000
13,086
8,304
553
127
658
195
584
80
298
PERCENT
OF TOTAL
20.95
6.56
3.10
1.79
5.22
34.18
21.69
1.44
0.33
1.72
0.51
1.53
0.21
0.78
NUMBER OF
EMPLOYEES (M)
347.8
66.4
57.0
41.2
37.5
128.4
183.2
9.4
19.5
38.4
23.2
9.2
1.6
7.1
PERCENT
OF TOTAL
35.86
6.85
5.88
4.25
3.87
13.24
18.89
0.97
2.01
3.96
2.39
0.95
0.16
0.73
                                            38,288
100.01
969.9
100.01
 *The numbers given include all establishments which fall within a given SIC code, in some instances in-
  cluding establi.   ents which publish only and do not have printing operations. See Table 111-12 for
  the number of e tablishments in each SIC code that perform printing operations.

**This number is believed to omit some plants with less than 10 employees and therefore to understate the
  actual total. A more accurate count is believed to be 9402. See Industry Subsegmentation.

SOURCE:  Census of Manufacturers, Preliminary 1972.

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     The industry is  composed of a large number of small companies. This is
shown in Table III-2, which lists by industry segment the  number of establish-
ments having less than 20 employees. Overall, about 80% of the establishments in
the printing and publishing industry have less than 20 employees.

     Sales concentration in  the printing industry  tends to follow  the  pattern
established  in many manufacturing industries; that is, the more concentrated the
industry, the higher the average annual net sales per company within the industry.
On the basis of available information, the Greeting Card  Publishing industry has
the highest concentration of sales, with the four largest companies representing
67% of industry sales and the  50 largest  companies representing 95% in  1967
(Table III-3).  In  1972 the 195  establishments in the Greeting Card Publishing
industry had the  high  average  value of shipments per  establishment of $3.9
million. This value, as shown in Table III-4, was exceeded only by the Commercial
Printing,  Gravure industry whose 127  establishments had an average value of
shipments per establishment of  $5.3 million in 1972. Unfortunately, the Com-
mercial Printing, Gravure  segment is new and such historical data as is available
does not appear to be consistent.

     Two exceptions  to the correlation between  sales  concentration and high
average value  of shipments  per establishment are  the Miscellaneous Publishing
industry  and the Electrotyping  and Stereotyping industry.  Both are highly con-
centrated but have relatively low average values of shipments per establishment:
$521,000 for Miscellaneous  Publishing, and  $455,000  for Electrotyping and
Stereotyping.

     A breakdown of selected industry segments, based on number of employees,
is presented in Table III-5. Included are two relatively stable industries - News-
papers and Commercial Printing, Letterpress — and two  that are changing with
respect to the number of their constituent plants —  Greeting Card Publishing, and
Electrotyping and Stereotyping.

     In Greeting Card Publishing, there is a trend to larger plants and those plants
are producing a higher percentage of the value of shipments. In 1963, only 6.2%
of the establishments had over 100 employees but by  1967  that number had
increased to  17.6%. Although the total  value of shipments increased during this
period there were 35 (14%)  fewer establishments  at the end of 1967 than four
years earlier. There was also a substantial decrease in the number of Electrotyping
and Stereotyping plants during the same period (51, or 28%) but the decline also
was accompanied by a reduction in total value of shipments. While greeting card
publishing is a growing industry, electrotyping is a dying industry.

     The Commercial Printing, Letterpress segment was remarkably static in all
respects. The newspaper industry showed no dramatic change during the period
covered by the data.

                                    13

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                                                        TABLE III-2

                                           DISTRIBUTION BY NUMBER  OF EMPLOYEES

                                            ESTABLISHMENTS WITH  LESS
                                               THAN 20 EMPLOYEES
ESTABLISHMENTS WITH 20
  OR MORE EMPLOYEES
SIC
CODE
2711
2721
2731
2732
2741
2751
2752
2753
2754
2761
2771
2793
2794
2795
INDUSTRY
Newspapers
Periodicals
Book Publishing
Book Printing
Misc. Publishing
Conm. Print., L.P.
Comft. Print., Litho
Engraving and Plate Print.
Conn. Print., Gravure
Manifold Bus. Forms
Greeting Card Publishing
Photoengraving
Electrotyping and Stereotyping
Litho Platemaking Services
NUMBER OF
ESTABLISHMENTS
5,951*
2,063
886
409
1,745
11,951
6,193
427
45
290
116
455
56
200
PERCENT
74
82
75
60
87
91
75
77
35
44
59
78
70
67
NUMBER OF
ESTABLISHMENTS
2,071
447
300
276
255
1,135
2,111
126
82
368
79
129
24
98
PERCENT
26
18
25
40
13
9
25
23
65
56
41
22
30
33
TOTAL
ESTABLISHMl
8,022
2,510
1,186
685
2,000
13,086
8,304
553
127
658
195
584
80
298
                                               30,787

 This total is believed tt  .nit some plants  with less than 10 employees.

Source:  Census of Manufactures, Preliminary 1972
                                 38,288
                                                                                        Arthur D. Little, Inc.

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                                                            TABLE III-3

                          SALES CONCENTRATION IN SELECTED SEGMENTS OF THE PRINTING AND PUBLISHING INDUSTRY
                                                                 ANNUAL VALUE OF SHIPMENTS-PERCENT ACCOUNTED FOR BY
                          INDUSTRY AND YEAR
    2771
Greeting Card Publishing
     1970
     1967
     1966
     1963
                                        4 LARGEST
                                        COMPANIES
                                                             75
                                                             67
                                                             64
                                                             57
                 8 LARGEST
                 COMPANIES
                    85
                    79
                    76
                    71
                 20 LARGEST
                 COMPANIES
                   n.a.
                    88
                   n.a.
                    82
                 50 LARGEST
                 COMPANIES
                   n.a.
                    95
                   n.a.
                    92
    2794
C/l
Electrotyping and Stereotyping
     1970
     1967
     1966
     1963
n.a.
 34
n.a.
 31
n.a.
 45
n.a.
 39
n.a.
 63
n.a.
 57
n.a.
 87
n.a.
 80
                         n.a.-Not available
                         SOURCE:   Quarterly  Industry Report, January  1973, U.S.  Department  of Commerce

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                                                         TABLE 111-4




                                   AVERAGE ANNUAL VALUE OF SHIPMENTS PER ESTABLISHMENT
SIC
CODE
2711
2721
2731
2732
2741
2751
2752
2753
2754
2761
2771
2793
2794
2795
INDUSTRY
Newspapers
Periodicals
Book Publishing
Sook Printing
Misc. ^ubli'-liing
Conn. Irint., L.P.
Conon. Print., Litho
Engraving and Plate Print.
Conm. Print., Gravure
Manifold Bus . Forms
Greeting Card Publishing
Photoengraving
Electrotyping and Stereotyping
Litho Platemaking Services
NUMBER OF
ESTABLISHMENTS
8,022
2,510
1,186
685
2,000
13,086
8,304
553
127
658
195
584
80
298
VALUE OF
SHIPMENTS ($MM)
8,271.5
3,506.3
2,861.3
929.3
1,042.6
3,242.6
5,110.8
197.1
674.0
1,421.5
766.1
215.4
36.4
201.8
AVERAGE VALUE OF
SHIPMENTS PER ESTABLISHMENT ($M)
1,031
1.397
2,413
1,357
521
248
615
356
5,307
2,160
3,929
369
455
677
TOTAL
                                              38,288
28,476.7
Source:  Cens-is of Manufactures, Preliminary 1972
                                                                                        Arthur D.  Little.  Inc.

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                                  TABLE 111-5




NUMBER OF ESTABLISHMENTS AND ANNUAL VALUE OF SHIPMENTS BY SIZE OF ESTABLISHMENT
SIC CODE
YEAR SIZE OF PLANT
2711 Newspapers
1963 Small
Medium
Large
1967 Small
Medium
Large
2751 Comm. Print., L.P.
1963 Small
Medium
Large
1967 Small
Medium
Large
2771 Greeting Card Publishing
1963 Small
Medium
Large
1967 Small
Medium
Large
NUMBER OF
ESTABLISHMENTS

6466
1346
519 •'- 8,331
6065
1453
576 8,094

10,705
1,174
230 12,109
10,659
1,198
241 12,098

164
77
16 257
130
53
39 222
PERCENT OF
TOTAL

77.6
16.2
6.2
74.9
18.0
7.1

88.4
9.7
1.9
88.1
9.9
2.0

63.8
30.0
6.2
58.5
23.9
17.6
VALUE OF PERCENT OF
SHIPMENTS ($M) TOTAL

346 , 508
573,947
3,563,137
369,500
712,900
4,674,700

658,824
696,544
1,289,680
762,700
863,800
1,628,800

20,266
39,668
286,027
16,000
45,500
456,400

7.7
12.8
4,483,592 79.5
6.4
12.4
5,757,100 81.2

24.9
26.3
2,645,048 48.8
23.4
26.6
3,255,300 50.0

5.8
11.5
345,961 82.7
3.1
8.8
517,900 88.1
                                                                 Arthur D. Little,  Inc.

-------
                                                           TABLE I!!-1? Continued)

                              NUMBER OF ESTABLISHMENTS AND ANNUAL VALUE OF SHIPMENTS BY SIZE OF ESTABLISHMENT
SIC CODE

YEAR SIZE OF PLANT
2794 Electrotyping
1963


1967


and Stereotyping
Small
Medium
Large
Small
Medium
Large
NUMBER OF
ESTABLISHMENTS
104
72
8
184 s
76
51
6 133
PERCENT OF
TOTAL
56.6
39.1
4.3

57.1
38.3
4.6
VALUE OF
SHIPMENTS ($M)
10,754
44,123
21,191
w 76,068
9,100
35,000
18,100 62,200
PERCENT OF
TOTAL
14.1
58.0
27.9

14.6
56.3
29.1
00
                       Small - 1 to 19 employees
                       Medium - 20 to 99 employees
                       Large - 100 or more employees


                       Source:  Census of Manufactures, U.S. Department of Commerce,  Bureau of Census 1963 and 1966

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2. Size of Firms

     Establishments in the printing and publishing industry range in size  from
very small (e.g., less than 5 employees) to large (e.g., 10,000 to 12,000). Many of
the small companies specialize in providing a single product or  service to the
industry  and are generally privately owned. The large firms include multimillion
dollar corporations that produce a range of printed products and frequently use
several printing processes.

     The range of size and the degree of concentration as indicated  by the average
value of  shipments by size of company are shown in Table III-6 for the various
segments. This table is adapted from  1967 data for percent value of shipments
accounted for by the largest companies and applied to  1972 data  for number of
establishments and value of shipments.  In only four of the fourteen industries
included  in this study  is 60% or  more of the industry's value  of shipments
accounted for by the 20  largest companies: Greeting Card Publishing, Manifold
Business  Forms, Miscellaneous Publishing, and Electrotyping and Stereotyping.

     Commercial Printing, Letterpress, is the largest single segment with about
13,000  establishments.  The  average  value of shipments for the 61% of this
industry  remaining after subtracting the value of shipments attributable to the 50
largest companies amounts to only $152,000.

     Much of the statistical information used  in  this study was obtained from
Department of Commerce Publications. Some of the data from different publica-
tions appears to be  inconsistent, probably  because  of different definitions,
changes in reporting, non-reporting, and the number of  manufacturing firms with
less than 10 employees that were excused from filing reports in the 1972 Census.
These last may be important  statistically because so large a percentage of the
printing  and publishing  industry  is  comprised of firms  having  less  than 20
employees, but is probably insignificant from an impact  point of view because the
small companies are not sources of pollution. Moreover, these inconsistencies are
relatively minor and do not affect the overall conclusions reached in this study.

3.  Level  of Integration

     The printing  and publishing industry is  not a significantly integrated in-
dustry.  Most  printing companies  either carry  out all  of the steps involved  in
producing a book, magazine or other  printed items or perform a single step and
transfer the partially completed work  to another non-affiliated company. Rarely
is a printing company integrated back to papermaking and woodlands or forward
to retail  stores. There are, however, several instances of common ownership  of
large newspapers  and newsprint manufacturers, most of  whom would  also own
woodlands.  These are non-typical situations and  play  no particular role in this
study. Over  80% of  the  establishments in the industry  have less than 20 em-
ployees and several segments show even higher percentages, e.g.,  91% for Com-
mercial Printing, Letterpress.

                                     19

-------
                                                          TABLE 111-6
                                        INDUSTRY SEGMENT CONCENTRATION AND AVERAGE
                                        ANNUAL VALUE OF SHIPMENTS BY SIZE OF COMPANY
                                        (Percent of total) and average value of shipments per company($M)
SIC
CODE

2711

2721

2731

2732

2741

2751

2752

2753


2754

2761

2771


2793

2794

2795
              INDUSTRY
         Newspapers

         Periodicals

         Book Publishing

         Rook Printing

         Misc. Publishing

         Comm. Print., L.P.

         Coma. Print., Litho

         Engraving and Plate
         Print.

         Goran. Print., Gravure

         Manifold Bus. Forms

         Greeting Card Pub-
         lishing

         Photoengraving

         Electrotyping and
         Stereotyping
         Litho Platemaking
         Services
REMAIN-
ING
ESTABLISH-
4 LARGEST
(16) 330
(24) 210
(?Q) 143
(21) 48
(29) 75
(14) 113
(05) 63
(21) 10
,900
,400
,100
,800
,600
,500
,900
,300
8 LARGEST
(25)
(37)
(32)
(30)
(46)
(21)
(08)
(28)
258
162
114
34
59
85
51
6
,500
,200
S500
,800
,900
,100
,100
,900
20 LARGEST
(40)
(56)
(57)
(48)
(64)
(29)
(15)
(38)
165
98
81
22
33
47
,400
,200
,600
,300
,400
,000
38,300
3
,700
50 LARGEST
(56)
(72)
C/7)
(64)
(75)
(39)
(25)
(52)
92,600
50 , 500
44,100
11,900
15,600
25,300
25,600
2,000
MENTS
(44)
(28)
(23)
(36)
(25)
(61)
(75)
(48)
457
399
579
52 /
134
152
464
188
(47) 167,000   (57) 101,300    (69)   49,000   (81)  23,000    (19) 444

(67) 128,300   (79)  75,600    (88)   33,700   (95)  14,600    (05) 264


(10)   5,400   (16)   4,300    (27)   2,900   (44)   1,900    (56) 226

(34)   3,100   (45)   2,000    (63)   1,100   (87)     633    (13) 158
Sources: Census of Manufactures,  Preliminary 1972
         Quarterly Industry Report,  January  1973,  U.S.  Department of Commerce

-------
     By far the  largest commercial  printer is R.R. Donnelley & Sons Co., with
 1972 sales  of over $353 million. This represents slightly over \% of total industry
 receipts. The revenues for the various segments of Donnelley's business, shown as
 a percent of the total revenues, are:

                Magazines                             35.5%
                Catalogs                              26.4
                Hardbound Books                      19.4
                Telephone Directories                  11.0
                Other Printing                          7.7
                                                     100.0

     Donnelley is a horizontally integrated company in the sense that it provides a
 complete range of automated  composition, printing, binding, and shipping ser-
 vices  to its customers. Donnelley's  two largest competitors are Arcat;>. National
 Corp. with printing revenues of $159 million  and  McCall Corp. with estimated
 printing revenues slightly less than Arcata's. Other  major competitors include
 Cuneo Press, Inc., W.F. Hall Printing Co., W.A. Krueger Co., Meredith Corp. and a
 number of other companies with sales ranging down to perhaps $5 million. Many
 of these companies provide services  to their customers similar to those provided
 by Donnelley and are active  in up to five SIC code industries. A large number of
 the smaller establishments frequently do only one type of printing, offer a limited
 range of services to their customers, and are listed under one SIC code.

     During the  1950's and  1960's  a  number  of acquisitions took place in the
 printing industry. These  were largely in the book,  magazine  and commercial
 printing segments and appear to have been prompted by a variety of reasons; e.g.,
 the original owner reaching retirement age, the need for major capital investment,
 or the desire of the  owner to diversify  his investments. This period, which was
 associated with growth of the printing industry in general and growth of web-
 offset printing in particular, saw major growth by several of today's large printing
 companies  as they acquired  subsidiaries. Such concentration does not appear to
 be taking  place at present to any significant degree.  Other major printing  com-
 panies increased in size as a result of internal growth.

     Integration, in the sense of a company's being both publisher and printer, is
 not very prevalent in the industry. Meredith  Corp.  and  McCall Corp. in the
 periodical  segment and Doubleday & Company, Inc., and Western Publishing Co.,
 in the book segment arc examples  of companies that are both publishers and
 printers. These are exceptions, however; the two functions generally are performed
 by separate companies.  However, integration is  common in the newspaper . -
 dustry where the publishers of almost  all daily newspapers and maa;,  weekly-
newspapers own  a plant dedicated to printing the newspaper  This is believed to
 be a neci ssity i i order to control the late closing of news pages and to  meet
 delivery schedule s.
                                    21

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4.  Number of Products

     In  general, the names of the various segments are descriptive of the  main
product each produces, although some secondary products are not apparent  from
the code name and several of the segments do overlap. Table 111-7 lists the major
products produced in each of the segments.

5.  Level of Diversification

     Most of the segments of the printing industry are rather specialized despite
the number of products  listed in Table III-7. The Census of Manufactures  mea-
sures this degree  of specialization with its "specialization ratio," which is defined
as  the  ratio of industry  shipments of primary  products to total manufactured
industry shipments of primary and secondary products.

     The primary product specialization ratios are as follows:
     SIC
     Code              Industry

     2711       Newspapers
     2721       Periodicals
     2731       Book Publishing
     2732       Book Printing
     2741       Miscellaneous Publishing
     2751       Comm. Print., L.P.
     2752       Comm. Print., Litho
     2753       Engraving and Plate Print.
     275-4       Comm. Print., Gravure
     2761       Manifold Bus. Forms
     2771       Greeting Card Publishing
     2793       Ph 0:0en graving
     2794       Electrotyping and Stereotyping
     2795       Litho Platemaking Services
Specialization Ratio

       0.96
       0.89
       0.91
       0.88
       0.95
       0.86
       0.86
       0.92
       0.88
       0.92
       0.76
       0.86
     Source:  (     ^c  Manufactures, Preliminary \9~/l
                                    22

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                            TABLE III-7

                   PRINTING INDUSTRY PRODUCTS
SIC
CODE

2711
2721
      INDUSTRY
Newspapers
Periodicals
2731
2732
Book Publishing)
Book Printing   r
2741
Misc. Publishing
2751
Comm. Print., L.P.
             MAJOR PRODUCTS
Daily and Sunday newspaper
Weekly newspapers

Farm Periodicals
Specialized Business and Professional
   Periodicals
General Interest Periodicals

Elementary and high school text books
Technical, scientific, business and
professional books and college text books
General consumer and trade books
Subscription reference books, encycloped-
   ias, and religious subscription books
Pamphlets,workbooks and objective teats

Catalogs and directories
Business service publications
   Newsletters
   Government regulations
Miscellaneous products
   Post cards
   Sheet music
   Maps, charts
   Patterns
   Racing forms
   Shopping news

Magazines and periodicals
Labels for packaging purposes
   sheets, rolls
Catalogs and directories
Financial and legal printing
   SEC prospectuses
   Annual reports
   Insurance forms
   Bank printing
Advertising printing
   Direct mail
   Display advertising
   Preprinted newspaper inserts
Scientific and technical recording charts
Trading stanps
Newspapers
Tickets and coupons
                                   23

-------
                         TABLE 111-7 (Continued)
SIC
CODE

2752
         IMHJSTRY
Goran. Print., Litho
           MAJOR PRODUCTS
Same as Comm. Print., L.P.
2753
Engraving and Plate Print.
2754


2761
2771
2793
2794
2795
Comm. Print., Gravure
Manifold Bus. Forms
Greeting Card Publishing
Phot oengraving
Electrotyping and Ster-
eotyping
Litho Platemaking Ser-
vices
Securities
Social printing
Commercial printing
Intaglio printing plates
Duplicate rubber letterpress print ing
   plates

Same as Comm. Print., L.P.
Unit set  forms
Sales and other manifold books
Custom continuous  forms
Stock continuous forms

Christmas cards
Valentine cards
Seasonal cards

Photoengraving plates
   Zinc
   Copper
   Magnesium

Electrotype duplicate plates
Stereotype duplicate plates
Matrices

Lithographic plates
   Diazo  type
   Wipe-on type
   Deep-etch type
   Multi-metal type
Color corrected process film
     Source:  Census of Manufactures, Preliminary 1972
                                    24

-------
                            TABLE III-7

                   PRINTING INDUSTRY PRODUCTS
SIC
CODE

2711
2721
      INDUSTRY
Newspapers


Periodicals
2731
2732
Book Publishing)
Book Printing  j
2741
Misc. Publishing
2751
Comm. Print., L.P.
             MAJOR PRODUCTS
Daily and Sunday newspaper
Weekly newspapers

Farm Periodicals
Specialized Business and Professional
   Periodicals
General Interest Periodicals

Elementary and high school text books
Technical, scientific, business and
professional books and college text books
General consumer and trade books
Subscription reference books, encycloped-
   ias, and religious subscription books
Pamphlets,workbooks and objective tests

Catalogs and directories
Business service publications
   Newsletters
   Government regulations
Miscellaneous products
   Post cards
   Sheet music
   Maps, charts
   Patterns
   Racing forms
   Shopping news

Magazines and periodicals
Labels for packaging purposes
   sheets, rolls
Catalogs and directories
Financial and legal printing
   SEC prospectuses
   Annual reports
   Insurance forms
   Bank printing
Advertising printing
   Direct mail
   Display advertising
   Preprinted newspaper inserts
Scientific and technical recording charts
Trading stamps
Newspapers
Tickets and coupons
                                   23

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                         TABLE 111-7 (Continued)
SIC
CODE

2752
         INDUSTRY
Goran. Print., Litho
           MAJOR PRODUCTS
Same as Conm. Print., L.P.
2753
Engraving and Plate Print,
2754


2761
2771
2793
Coram. Print., Gravure
Manifold Bus. Forms
2794
2795
Greeting Card Publishing
Photoengraving
Electrotyping and Ster-
eotyping
Litho Platemaking Ser-
vices
Securities
Social printing
Commercial printing
Intaglio printing plates
Duplicate rubber letterpress prirt ing
   plates

Same as Comm. Print., L.P.
Unit set  forms
Sales and other manifold books
Custom continuous  forms
Stock continuous forms

Christmas cards
Valentine cards
Seasonal cards

Photoengraving plates
   Zinc
   Copper
   Magnesium

Electrotype duplicate plates
Stereotype duplicate platee
Matrices

Lithographic plates
   Diazo  type
   Wipe-on type
   Deep-etch type
   Multi-metal type
Color corrected process fil».
     Source:  Census of Manufactures, Preliminary 1972
                                    24

-------
     The  major industry segments  have shown little change in their degree of
specialization  during  the last 20 years. The  Greeting Card Publishing industry
(2771), however, has shown a steady but slow decline over this period, from 0.93
in 1954 to 0.76 in 1972. The Photoengraving industry (2793) has shown a more
rapid decrease in specialization since 1967, 0.94 vs 0.86.  The Electrotyping and
Stereotyping industry (2794) has shown a similar reduction over the same period,
0.89  to  0.82.  Both  of the latter two industries are experiencing decreasing
demands for their primary  products even though a substantial number of plants
are closing each year.  The decline in specialization ratio suggests that companies
in these industries are diversifying into other more viable product lines,  such as
lithographic printing plates.

B. TYPES OF PLANTS

     There is  great diversity among the plants that  comprise the  printing  and
publishing industry. Even within a given segment plants vary in size, in the range
of services they provide to a customer, in their degree of sophistication, and in the
product mix they are  equipped to manufacture. The types of plants are described
in the following paragraphs  with respect  to their size,  age, location, level of
technology, efficiency and level  of integration.

1. Size of Plants

     The Census of Manufactures reports plant size by average employment size.
For purposes of this report plant size is defined as follows:

                  Small Plants —    1  to 19 employees
                  Medium Plants — 20 to 99 employees
                  Large Plants -    100 or more employees

Approximately three  years are required for publication of the  detailed census
information. Only preliminary information on establishments by employment size
is available for 1972 and this is limited to total plants and to those plants with 20
employees or  more.  After  eliminating the two  new segments -  Commercial
Printing,  Gravure (2754) and Litho Platemaking Services (2795) -  for which
comparable data are not available for previous years it is possible to compare the
number of small plants as a percentage of the total. This data  for the  periods
1963, 1967, and 1972 shows the following:

                   No. of Plants With        Total No.          Percent
                 Less Than 20 Employees      of Plants           of Total

       1963             28,884              35,348             81.7
       1967             27,849              34,992             79.5
       1972             30,542              37,863             80.6
                                    25

-------
                          The  plant size  distribution in  the  printing industry has  been remarkably
•                      stable  with  an  average of about 80% of the establishments having less than 20
                      employees. A comparison of the data, segment by segment, for the three periods
                      shows that the  percentage of small plants to the total remains essentially constant
1                      even though a  significant increase in some of the segments has taken place over
|                      some of the periods for which data are available.
i
!                          In 12 of the 14 segments  covered by this report, comparable information is
!                      available from which plant size distribution can be  calculated for the years 1963
;                      and 1967. The  data for 1967 show a reduction of about  1% in the total number
1                      of establishments in the printing industry compared to 1963. Six of the segments
j                      showed a decrease in the number of plants, four  showed an increase and two
                      segments remained essentially unchanged. For three of the segments the increases
                      amounted to about  8%.  The  Greeting Card Publishing, Photoengraving, and
                      Electrotyping and Stereotyping industries showed decreases in  the total number
                      of plants  amounting  to  13.6, 16.8, and 27.7%, respectively, for the period. There
                      was, however, no discernible overall change in the average plant-size distribution
                      from that existing in  1963. The Greeting Card Publishing and  Manifold  Business
                      Forms industries in 1967 had about 5% fewer plants with less than 20 employees
                      and about the  same  increase in number of plants with 100 or more employees.
                      Engraving and  Plate  Printing showed a decrease of about 5% in the number of
                      small plants but no change in the percent of large  plants.

                          Limited data are available for 1972 except  for number of plants having less
                      than 20 employees and total number of plants by segment. There was an increase
                      of 9.4% in the total number  of plants  for  the 12 segments  covered  for 1972
                      compared to 1967. Some of the highlights for individual  segments are worthy of
                      note and are as follows:

                             PERCENT CHANGE IN NUMBER OF PLANTS,  1972 VS 1967

                                                                                Change In
                      SIC                                   Change In         Total With Less
                      Code             Industry           Total Number     Than 20 Employees

                      2721   Periodicals                         +16                   0
                      2741   Miscellaneous Publishing             +34                 +1
                      2751   Comm. Print., L.P.                  +8                 +3
                      2752   Comm. Print., Litho                 +22                  -1
                      2753   Engraving and Plate Print.            -4                  -1
                      2761   Manifold Bus. Forms                +21                  -2
                      2771   Greeting Card Publishing            -12                   0
                      2793   Photoengraving                     -20                 +4
                      2794   Electrotyping and Stereotyping       -40                +13
                                                         26

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                             TABLE 111-8
            GEOGRAPHIC DISTRIBUTION OF PRINTING INDUSTRY
            BY EMPLOYEES AND ANNUAL VALUE Of SHIPMENTS
AREA
 HO.

  1.
                                            EMPLOYEES
           AREA

   New England
      (Me., N.H., Vt., Mass., Conn., R.I.)

2. Middle Atlantic
       (N.Y., N.J., Pa.}

3. East North Central
      (Wise., Ill, Ind., Ohio, Mich.)

4. West North Central
      (N. Dak., S. Dak., Nefcr., Kans.,.
       Mo., Iowa, Minn.)

5. South Atlantic
      (W. Va., Va., Md., Del., D.C.,
       N. Car., Sa. Car.r Ga., Fla.)

6> East South Central
      (Ky., Tenn., Ala., Miss.)

7. West South Central
      (Okla., Tex., La., Ark.)
8. Mountain
      (Ida., Nev., Utah, Ariz.,
       Colo., Wyo., Mont.)

9. Pacific
      (Wash., Ore., Calif.)
 76.2


269.2


258.2


 QO* t



116.7



 42.0
 26.31
105^6
                   VALUE
                OF INDUSTRY
                 SHIPMENTS
1,712,5


8,427,6


6,612.8


2,228.0



2f54$.2



  961*5
                                                                  5S3.S
                                                                2,643^2
Source:  Annual Survey of Manufactures,
                                28

-------
to
                                                                 TABLE 111-9

                                    GEOGRAPHIC CONCENTRATION OF ESTABLISHMENTS IN THE PRINTING INDUSTRY
SIC
CODE
2711
2721
2731
2732
27A1
2751
2752
2753
2754
2761
2771
2793
2794
2795
NUMBER OF ESTABLISHMENTS
INDUSTRY
Newspapers
Periodicals
Book Publishing
Book Printing
Mlsc- Publishing
Comm. Print., L.P.
Comm. Print., litho
Engraving and Plate Print.
Conur,. Print., Gravure
Manifold Bus. Forms
Greeting Card Publishing
Photoengraving
Electrotyping and Stereotyping
Liuiu Plateraaking Services
TOTAL
8,022*
2,510
1,186
685
2,000
13,086
8,304
553
127
658
195
584
80
298
AREA 1
401
904
96
57
106
877
546
36,0
12
35.0
26
54
8
23
AREA 2
1,008
732
458
254
600
3,014
1,914
171
39
146
73
137
23
74
AREA 3
1,470
467
197
104
348
2,575
(2,499)
115
(45)
130
(45)
(139)
(32)
(118)
AREA 4 AREA 5
1,429 975
189 298
58 112
44 85
141 196
966 1,747
971
29 (83)

53 87
13
71


AREA 6
527
73
30
24
(86)
553
258


25

19
4
(56)
AREA 7
969
157
41
37
(7)
1,063
606
38
20
64

40


AREA 8 AREA 9
427 816
74 348
29 165
28 52
44 357
446 1,850
285 1,225
(81)
(ID
20 98

(124)

(21)
         *This number is believed to omit some plants with less than 10 employees and therefore  to  understate  the  actual  total.

                (   )  denotes lumping of data for this and adjacent area or areas where blanks exist in the same SIC code.
          Sources:   Census of Manufactures, Preliminary 1972
                    Annual Survey of Manufactures,  1971
Arthur D. Little,  Inc.

-------
                                                 TABLE III }0

                        GEOGRAPHIC CONCENTRATION OF EMPLOYEES IN THE PRINTING INDUSTRY
INDUSTRY
Newspapers
Periodicals
Book Publishing
Book Printing
Misc. Publishing
Coram. Print., L. P.
Coram. Print., Litho
Engraving and Plate Print.
Comm. Print., Gravure
Manifold Bus. Forms
Greeting Cards
Photoengraving
Electrotyping and Stereotyping
Litho Plateraaking Services
TOTAL
347.8
66.4
57.0
41.2
37.5
128.4
183.2
9.4
19.5
38.4
23.2
9.2
1.6
7.1
AREA 1
25
2
3
6
1
8
13
1
0
2
3
0
0
0
.4
.9
.8
.4
.5
.3
.8
.0
.8
.7
.9
.8
.1
.4
AREA 2
67.3
31.2
26.8
9.3
13.2
31.4
43.4
3.0
4.3
6.8
2.6
3.7
0.6
2.1
AREA
3 AREA 4
72.4 29.0
11.
13.
9.
10.
37.
(68.
1.
(8.
9.
(136)
(2.
(0.
(3.
5 6.0
4 4.8
7 2.0
7 2.9
4 8.0
9)
6 0.4
8)
2 3.2

1)
8)
1)
AREA 5
49.6
6.1
1.5
5.4
2.9
14.2
19.7
(1.8)

4.8
0.4
0.6


AREA 6
15.1
2.6
1.1
4.2
(0.5)
4.3
5.9


1.2

0.2
0.1
(1.0)
AREA 7
29.3
1.3
0.6
2.0
(0.1)
6.8
10.0
0.5
4.7
5.0

0.5


AREA
14.
0.
0.
0.
0.
3.
3.
(1.
(0.
0.

(1.

(0.
8 AREA 9
4 45.3
8 4.1
5 4.5
7 1.4
8 3.8
7 14.3
6 17.9
2)
9)
9 4.5

3)

5)
           (   ) denotes lumping of data for this and adjacent area or areas where blanks exist in the  same  SIC  code.

Source:  Annual Survey of Manufactures, 1971
                                                                                       Arthur D. Little,  Inc,

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                                                        TABLE MI-9


                            GEOGRAPHIC CONCENTRATION OF ESTABLISHMENTS IN THE PRINTING INDUSTRY
SIC
CODE
2711
2721
2731
2732
27A1
2751
2752
2753
K)
2754
2761
2771
2793
2794
2795
INDUSTRY
Newspapers
Periodicals
Book Publishing
Book Printing
Misc. Publishing
Comm. Print., L.P.
Comm. Print. , litho
Engraving and Plato Print.
Goran. Print., Gravure
Manifold Bus. Forms
Greeting Card Publishing
Photoengraving
Electrotyping and Stereotyping
Liuiu Platemaking Services
NUMBER OF ESTABLISHMENTS
TOTAL
8,022*
2,510
1,186
685
2,000
13,086
8,304
553
127
658
195
584
80
298
AREA 1
401
904
96
57
106
877
546
36.0
12
35.0
26
54
8
23
AREA 2
1,008
732
458
254
600
3,014
1,914
171
39
146
73
137
23
74
AREA 3
1,470
467
197
104
348
2,575
(2,499)
115
(45)
130
(45)
(139)
(32)
(118)
AREA 4 AREA 5
1,429 975
189 298
58 112
44 85
141 196
966 1S747
971
29 (83)

53 87
13
71


AREA 6
527
73
30
24
(86)
553
258


25

19
4
(56)
AREA 7
969
157
41
37
(7)
1,063
606
38
20
64

40


AREA 8 AREA 9
427 816
74 348
29 165
28 52
44 357
446 1,850
285 1,225
(81)
(ID
20 98

(124)

(21)
*This number is believed to omit some plants with less than 10 employees and therefore to understate  the  actual  total.

       (    )  denotes lumping of data for  this  and adjacent area or areas where blanks exist in the same SIC code.

 Sources:   Census  of Manufactures,  Preliminary 1972                                   Arthur D. Little  Inc
           Annual  Survey of Manufactures,  1971

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                                                 TABLE III 10

                        GEOGRAPHIC CONCENTRATION OF EMPLOYEES IN THE PRINTING INDUSTRY


                                                                    NUMBER OF AMFLOYEES  (M)
INDUSTRY
Newspapers
Periodicals
Book Publishing
Book Printing
Misc. Publishing
Coram. Print., L. P.
Coram. Print., Litho
Engraving and Plate Print.
Comm. Print., Gravure
Manifold Bus. Forms
Greeting Cards
Photoengraving
Electrotyping and Stereotyping
Litho Plateraaking Services
TOTAL
347.8
66.4
57.0
41.2
37.5
128.4
183.2
9.4
19.5
38.4
23.2
9.2
1.6
7.1
AREA I
25.4
2.9
3.8
6.4
1.5
8.3
13.8
1.0
0.8
2.7
3.9
0.8
0.1
0.4
ARIA
67.
31.
26.
9.
13,
31.
43.
3.
4.
6.
2.
3.
0.
2.
2
3
2
8
3
2
4
4
0
3
8
6
7
6
1
AREA
72.
11.
13.
9.
10.
37.
(68.
1.
(8.
9.
(136)
(2.
(0.
(3.
3 AREA 4
4 29.0
5 6.0
4 4.8
7 2.0
7 2.9
4 8.0
9)
6 0.4
8)
2 3.2

1)
8)
1)
AREA 5
49.6
6.1
1.5
5.4
2.9
14.2
19.7
(1.8)

4.8
0.4
0.6


AREA 6
15.1
2.6
1.1
4.2
(0.5)
4.3
5.9


1.2

0.2
0.1
(1.0)
AREA 7
29.3
1.3
0.6
2.0
(0.1)
6.8
10.0
0.5
4.7
5.0

0.5


AREA
14,
0.
0.
0.
0.
3.
3.
(1.
(0.
0.

(1.

(0.
8 AREA 9
4 45.3
8 4.1
5 4.5
7 1.4
8 3.8
7 14.3
6 17.9
2)
9)
9 4.5

3)

5)
           (   ) denotes lumping of data for this and adjacent area or areas where blanks exist in the same SIC code.

Source:  Annual Survey of Manufactures, 1971
                                                                                       Arthur D. Little, Inc,

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                              TABLE 111-11




                    PRINTING DISTRIBUTION BY CITIES
New York, N. Y.




Chicago, 111.




Los Angeles, Cal.




Philadelphia, Pa.




Washington, D. C.




Minneapolis, Minn.




Detroit, Mich.




St. Louis, Mo.




San Francisco, Cal.




Cleveland, Ohio




Cincinnati, Ohio




Paterson, Clifton, Passaic, N.J.




Milwaukee, Wise.




Dallas, Texas




Newark, N.J.




Dayton, Ohio




Buffalo, N.Y.




Nashville, Tenn.




Atlanta, Ga.




Indianapolis, Ind.




SOURCE:  Annual Survey of Manufactures, 1971.
EMPLOYEES
(M)
138.3
84.5
39.6
32.5
20.1
18.3
15.8
15.7
15.4
13.6
13.1
12.5
10.3
9.9
9.1
9.1
8.5
8.5
8.3
8.0
ANNUAL
VALUE
OF INDUSTRY
SHIPMENTS
($MM)
5, -352. 3
2,489.5
1,003.7
877.7
564.0
461.2
417.5
367.7 ,
442.1
364.9
328.6
272.7
242.5
248.4
251.1
238.9
182.6
167.4
232.2
185.2
                                  31

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4.  Level of Technology

    Prior to about  1950 the  printing and publishing industry  was very  much
craft oriented.  Only in the  last  10 to 15 years has there been any significant
infusion of  new technology. Photocomposition, stimulated by the opportunity to
reduce labor costs, made the first inroad into traditional methods of typesetting.
While photocomposition is applicable to all methods of  printing, it found im-
mediate application in offset printing, stimulating the growth of that process and
of the related supplies and equipment.

    A number of other significant technological developments have now been
adopted by the printing industry, including:

    •   Automated computer-assisted composition

    •   High-speed full page metal engravings

    •   Advances in high-speed photography

    •   Improvements in color separations

    •   Photopolymer printing plate developments

    •   Improvements in offset plates

    •   Photomechanical (electronic) engraving methods for gravure cylin-
         der preparation

     •   Advances in automatic press controls

    The larger printers, who compete on a national basis, have adopted most of
the important technical developments that relate to their areas  of activity. The
adoption of new  technology is usually judged  in terms of savings  in costs and
time.  In a broader context, these large printing companies must also invest in cost
and time saving  technology  to meet  the competition from other communication
services.

     Many  small printing companies  still derive business from local sources and
are operating the same  equipment  in the same  manner now as many years ago.
While  it is  unlikely that these  companies have either the  inclination or the
resources to change, the new technical-economical thrust of the larger and more
aggressive printing companies will gain these larger companies a  greater share of
the printing dollar. The small printing companies may not be able to base their
competitive posture on amortized plants indefinitely.
                                    32

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C. INDUSTRY SUBSEGMENTATION

     Each of the 14 industry segments was subsegmented into small, medium and
large plants. Decisions were then made with respect to how many of the plants in
each segment should be selected for study for possible impact on the basis of their
use of  effluent  producing processes. The  results of the subsegmentation are
presented in Table 111-12.

     In those instances of possible impact when a single plant was found in more
than one industry  the plant  was included in the  first industry in  which it
appeared, taking the industries in numerical order. The exception was  a gravure
printing plant that first appeared under SIC 2721, Periodicals, which was listed
under SIC 2754, Commercial Printing, Gravure, where it could be treated  with
similar plants.

1. SIC 2711 Newspapers

     At the end  of 1973 the newspaper industry  was composed of weekly and
daily newspapers according to the following distribution:

       Weekly newspapers   7641  Establishments      Source:  NNA

       Daily newspapers    1761  Establishments      Source:  ANPA
         Total             9402

The total number is not in good agreement  with the  data provided in the Census
of Manufactures, Preliminary 1972 report,  and  used in several of our statistical
tables. The above data are believed to be the more reliable, however, and are used
in the remainder of the report.

     The weekly newspapers are generally composed of establishments having less
than 20 employees. Approximately  2641  weeklies  are  publishers only; their
newspapers are printed by commercial printers or in other newspaper plants. The
5000 weekly newspaper printing plants are divided into about 4250 offset plants
and 750 letterpress plants.  The offset plants represent the more profitable and
growth segment  of the  business. Most of the letterpress plants use either direct
printing-photopolymer  plates or flatbed presses, and  do no chemical engraving.
The few  weekly newspapers that may be etching direct printing-metal plates have
the option  of disposing economically of  the small amount of spent etching
solution they generate or of adopting the use of a precoated direct printing-photo-
polymer plate. The weekly newspapers are not sources of pollution.

     Some of the  1761 daily newspapers share printing facilities, so only 1560
printing plants are required. These plants print by  the stereo, direct printing and
offset processes. The direct printing process uses both metal and photopolymer
plates.  The offset and direct printing-photopolymer processes produce no process
contact effluent.  The  direct printing-metal and stereo processes require  metal

                                     33

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                               TABLE 111-12

                      SUBSEGMENTATION SUMMARY
                                     Number
                                     of Plants
                                                             Impact
Potsible*
None
2711 NEWSPAPERS
     Publishing and Printing
       Small Plants                     4,731
       Medium Plants                   1,353
       Large Plants                      476

            Total                     6,560

2721 PERIODICALS
     Publishing and Printing
       Small Plants                      231
       Medium Plants                     63
       Large Plants                       30

            Total                      324

2731 BOOK PUBLISHING
     Publishing and Printing
       Small Plants                      111
       Medium Plants                     36
       Large Plants                     	23

            Total                      170

2732 BOOK PRINTING
       Small Plants                      409
       Medium Plants                    200
       Large Plants                     	76
            Total                      685

2741 MISCELLANEOUS PUBLISHING
     Publishing and Printing
       Small Plants                      200
       Medium Plants                     40
       Large Plants                    	22

            Total                      262
 400

 400
  _4

   4
  _4
   4
2751 COMMERCIAL PRINTING, LETTERPRESS
       Small Plants                    11,951
       Medium Plants                    932
       Large Plants                      203             	4

             Total                    13,086               4
'Plants using processes that produce significant amounts of effluent.
6,160
 320
                111
                 36
                 23
                170
                409
                200
                 76
                686
  200
   40
   18
  258
              13,082
                                    34

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                         TABLE 111-12 (Continued)
                                    Number
                                    of Plants

2752 COMMERCIAL PRINTING, LITHOGRAPHIC
       Small Plants                    6,193
       Medium Plants                  1,781
       Large Plants                     330
                                                           Impact
                Possible*
            Total
8,304
2753 ENGRAVING AND PLATE PRINTING
       Small Plants                     427
       Medium Plants                   117
       Large Plants                   	9

            Total                      553

2754 COMMERCIAL PRINTING, GRAVURE
       Small Plants                      45
       Medium Plants                    41
       Large Plants                      41
            Total

2761 MANIFOLD BUSINESS FORMS
       Small Plants
       Medium Plants
       Large Plants

            Total

2771 GREETING CARD PUBLISHING
       Small Plants
       Medium Plants
       Large Plants

            Total

2793 PHOTOENGRAVING
       Small Plants
       Medium Plants
       Large Plants
            Total
  127
  290
  223
  145
  658
  116
   40
   39

  195
  455
  112
   17

  584
2794 ELECTROTYPING AND STEREOTYPING
       Small Plants                      56
       Medium Plants                    21
       Large Plants                       3
            Total
   80
 8
34

42
17
17
2795 LITHOGRAPHIC PLATEMAKING SERVICES
       Small Plants                     200
       Medium Plants                    68
       Large Plants                    	30

            Total                      298

'Plants using processes that produce significant amounts of effluent.
            None
            6,193
            1,781
              330

            8,304
                               427
                               117
                              	9

                               553
 45
 33
_7

 85
              290
              223
              145

              658
              116
               40
               39

              195
455
112

567
               56
               21
              _3

               80
                               200
                                68
                                30

                               298
                                  35

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 etching and are sources of metal  contamination. It  is estimated that plants using
 these processes number 40 and 360, respectively, as shown in Table 1II-12.

     A summary of the newspaper industry, including those establishments which
 publish only, and the types of printing processes used by the weekly and daily
 newspapers, is as follows:
       Weekly
         Publishing Only                                  2641
         Offset Plants                                     4250
         Flatbed Letterpress Plants                           750
                                                          7641
       Daily
         Publishing Only                                    201
         Offset Plants                                       900
         Direct Printing-Photopolymer Plants                  260
         Direct Printing-Metal Plants (Large)                   40
         Stereo Plants (Large)                                360
                                                           1761
                                      Total                9402
     The newspaper industry  is working  strenuously  to reduce its production
costs and modernize its operations by adopting new technology and by adapting
old technology to new uses. This has resulted in a proliferation of new alternatives
in the area of printing. While the traditional printing method in this industry has
been  stereo, there are now several alternatives. Offset newspaper printing is
growing rapidly, with over half of the daily newspapers now being printed by this
process. Direct printing, which bridges the gap  between photocomposition and
letterpress  equipment,  is  also growing rapidly.  Both  photopolymer and  metal
plates are used in this method of printing, with the photopolymer variety showing
a strong growth  trend.  Finally, photopolymer plates are being investigated for use
in the pattern plate process. This last process, a variation of the stereo process,
takes advantage  of photocomposition but allows the conventional  stereo  plate-
making process to continue to be used. Eventually there will be no metal etchim
in the newspaper industry.

     Most newspapers are aware of the need to control the metal contamination
from  their effluents and  many have either installed the appropriate treatment
equipment  or are studying the costs and  alternatives of doing so. The need to
control contamination has also encouraged a number of newspapers to switch to
non-polluting platemaking processes or to offset printing.
                                     36

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                         TABLE 111-12 (Continued)
                                    Number
                                    of Plants

2752 COMMERCIAL PRINTING, LITHOGRAPHIC
       Small Plants                    6,193
       Medium Plants                  1,781
       Large Plants                     330

            Total                     8,304

2753 ENGRAVING AND PLATE PRINTING
       Small Plants                     427
       Medium Plants                   117
       Large Plants                    	9

            Total                      553
                                                            Impact
              Possible*
            None
                            6,193
                            1,781
                              330

                            8,304
                              427
                              117
                             	9

                              553
2754 COMMERCIAL PRINTING, GRAVURE
       Small Plants                      45
       Medium Plants                    41
       Large Plants                      41
            Total

2761 MANIFOLD BUSINESS FORMS
       Small Plants
       Medium Plants
       Large Plants

            Total

2771 GREETING CARD PUBLISHING
       Small Plants
       Medium Plants
       Large Plants

            Total

2793 PHOTOENGRAVING
       Small Plants
       Medium Plants
       Large Plants
            Total
127
290
223
145
658
116
 40
 39

195
455
112
 17

584
 8
34

42
 45
 33
__7

 85
              290
              223
              145

              658
17
17
195


455
112

567
2794 ELECTROTYPING AND STEREOTYPING
       Small Plants                       56
       Medium Plants                     21
       Large Plants                        3
            Total
 80
               56
               21
              _3

               80
2795 LITHOGRAPHIC PLATEMAKING SERVICES
       Small Plants                      200
       Medium Plants                     68
       Large Plants                    	30

            Total                       298

"Plants using processes that produce significant amounts of effluent.
                              200
                               68
                               30

                              298
                                  35

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etching and are sources of metal contamination. It is estimated that plants using
these processes number 40 and 360, respectively, as shown in Table 111-12.

     A summary of the newspaper industry, including those establishments which
publish only,  and  the  types of printing processes used by  the weekly  and daily
newspapers, is as follows:
       Weekly

         Publishing Only                                   2641
         Offset Plants                                     4250
         Flatbed Letterpress Plants                          750
                                                          7641

       Daily

         Publishing Only                                    201
         Offset Plants                                      900
         Direct Printing-Photopolymer Plants                 260
         Direct Printing-Metal Plants (Large)                   40
         Stereo Plants (Large)                               360
                                                          1761
                                      Total               9402
     The newspaper  industry  is working  strenuously to reduce its production
costs and modernize  its operations by adopting new technology and by adapting
old technology to new uses. This has resulted in a proliferation of new alternatives
in the area of printing. While the traditional printing method in this industry has
been stereo,  there are now several alternatives. Offset newspaper  printing is
growing rapidly, with over half of the daily newspapers now being printed by this
process. Direct  printing, which bridges the gap between photocomposition and
letterpress  equipment, is also growing rapidly. Both photopolymer and  metal
plates are used in this method of printing, with the photopolymer variety showing
a strong growth trend. Finally, photopolymer plates are being investigated for use
in the  pattern plate  process. This  last process, a variation of the stereo process,
takes advantage of photocomposition but allows  the conventional stereo  plate-
making process to continue  to be used. Eventually there will be no metal etchiru,
in the newspaper industry.

     Most newspapers are aware of the need to control the metal contamination
from their effluents and many have either installed the appropriate treatment
equipment  or are  studying the costs and  alternatives of doing so. The need to
control contamination has also  encouraged a number of newspapers to switch to
non-polluting platemaking processes or to offset printing.
                                     36

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2.  SIC 2721 Periodicals

     Tliis industry is composed largely of establishments that are engaged primar-
ily in publishing activities. Of the 2510 establishments included in the industry,
2186 are publishers only,  with the remaining 324 engaged in both publishing and
printing.

     Subsegmenting the latter into small, medium, and large plants, based on the
average size of employment, indicates that not over 30 establishments have the
potential to pollute  by virtue of being large enough to justify their  own rotary
letterpress or gravure platemaking activities. A careful analysis of this group shows
that  only five plants actually engrave metal and have platemaking facilities. One
of these uses the gravure process and is more appropriately dealt with under SIC
2754 Commercial Printing, Gravure. Thus  the proposed guidelines might have an
impact on only four plants under this category.

3.  SIC 2731 Book Publishing

     The book publishing industry includes establishments engaged primarily in
publishing books and pamphlets. Of the 1186 establishments that comprised this
industry at the end of 1972, 1016 performed publishing functions only, with the
remaining 170 engaged in both publishing and printing.

     An estimated 80% of all new books are printed by the offset process, which
is non-polluting. Some reprints of older books are still printed by the letterpress
process. However, letterpress is used because the printing plates already exist,
having  been  saved from  the printing of previous editions, and no significant
number of new plates is  required.  Those that are required  to  replace lost or
broken plates or  to accommodate revisions in the text are prepared by a plate-
making shop.

     A relatively new development in the  book industry  that is enjoying increas-
ing popularity is  the  single-book  press. This is  a printing press that prints a
complete book on a web  of paper, accordian folds the web into the desired final
form and feeds it into a bindery line where it is automatically bound and cased.
The  printing  plates are mounted on an  endless flexible belt and  are  usually
non-polluting photopolymer plastic plates.

     Some  books are still being  printed by rotary letterpress, using rubber plates.
In this operation, type is set by the hot metal technique and  a plastic matrix is
prepared from  the hot type.  The rubber plate is prepared by molding a sheet of
rubber  against the matrix in a  hot  press. The technique is non-polluting. This
industry is not a source of water pollution.
                                     37

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4. SIC 2732 Book Printing

     The book printing industry is primarily engaged in printing books. At the
end of 1972 the industry consisted  of 685 plants. All of the comment and process
descriptions that  appear in the previous segment, apply to this segment. This
industry is not a source of water pollution.

5. SIC 2741 Miscellaneous Publishing

     This  industry  includes establishments engaged  primarily in miscellaneous
publishing activities not elsewhere  classified, whether or not they are engaged in
printing. This segment is comprised of about 2000 establishments.

     Separating these establishments into small, medium and large plants shows
that 1745 are small, 200 are of medium size and 55  are large. An analysis of the
large plants showed that 33 are publishers only and  that 22 are both publishers
and  printers. Further analysis of the 22 plants shows that only 7 are  actually
engaged in metal etching and  platemaking activities and  therefore subject  to
possible impact.  Three of these plants are  also included under the periodicals
segment. Thus the  effluent guidelines might have an  impact on only four plants
under this category, that are not covered elsewhere.

     Data are not available for the number of plants in the medium and small
plant categories that are publishers only. While the lack of this information in no
way influences the conclusions of the study we have estimated and entered in
Table III-l 2 only  those plants that are engaged in both printing and publishing.

6. SIC 2751 Commercial Printing,  Letterpress

     The Commercial Printing, Letterpress industry is comprised of 13,086 plants
that are engaged primarily in  commercial or  job printing using letterpress or
screen printing methods. Some of the more important products include maga-
zines, newspapers, periodicals, catalogues, and directories.

     A large percentage of these plants, many of which use flat-bed equipment
and are non-polluting, have less than 20 employees. Subsegmentation into small,
medium,  and large plants shows that 203 plants fall in the large category. O*
these, only nine are engaged  in metal etching and platemaking activities and five
of these nine were included in earlier segments. Thus the effluent guidelines might
have an impact on only four plants under this segment.
                                     38

-------
7. SIC 2752 Commercial Printing, Lithographic

     The Commercial Printing, Lithographic  industry is composed primarily of
plants engaged in commercial printing, using the offset process. Segmenting the
8,304 establishments involved into small, medium, and large plants indicates that
330 are  large, 1781 are medium, and 6193 are small.  All are non-polluting.

8. SIC 2753 Engraving and Plate Printing

     This industry is engaged primarily  in engraving  steel, copper, wood  and
rubber plates; in using the plates to print stationary and various types of cards,
invitations, etc.; and  in  making  wood-cuts for use in printing illustrations. It
consists of 553 plants, all of which are non-polluting. Subsegmentation shows that
9 are  large plants, 117 medium, and 427 small.

9. SIC 2754 Commercial Printing, Gravure

     The Commercial Printing, Gravure industry includes plants that are engaged
primarily in gravure  printing and plants engaged in preparing gravure plates and
cylinders for use by gravure printers. The Commercial Printing, Gravure industry
was included as a separate entity in the Census of Manufactures, for the  first time
in  1972.  Prior  to  that  time data  for gravure printing was  segregated under
Commercial Printing, Letterpress but the data for past years are  quite variable and
do  not  parallel the growth of gravure  printing in the United States. We  believe
that a  number  of plants  listed under  this  category may be included more
appropriately under another industry.

     The gravure printing industry is composed of about 22 large plants. Because
of the large size of the presses and of the gravure cylinders used, each printer must
engrave  the cylinders he uses in his own plant. Accordingly all 22 plants are
potential sources of pollution, although some of the newer  plants have  undoubt-
edly installed pollution control equipment.

     That portion of the industry  which  is  engaged  in small gravure cylinder
preparation for gravure printers who use smaller presses numbers about 20 plants.
Many of these engrave the printing rolls both chemically and mechanically,  and
some  make other types of rolls that are used by the printing industry,  all in the
same plant. We have estimated that 12 of the plants fall in the large-plant category
and 8 in the medium. The decision  was based entirely on the estimated revenues
from  the  chemical  etching  part of the business  (ignoring  revenues from other
operations carried on in the same plant),  because the cylinder preparation activi-
ties of some are very small and typical  of other plants in that industry segment,
even though the plants themselves are very large.
                                    39

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     The discrepancy between the number of plants included in the Census of
Manufactures, Preliminary 1972 report, and the number of large gravure printers
and gravure cylinder plants, we have been able to identify is not readily explained.
We believe that  some plants included in the census do gravure printing, do not
etch their own  cylinders,  and probably  are  also listed in an entirely different
industry. Examples of such plants could be ones that print on paper and foil in
connection with  the manufacture of various building products and packaging
materials.

     Subsegmentation of the 127 plants that make up this industry show 41 to be
large, 41 to be medium, and 45 to be small. Those plants that might be impacted
by pollution control requirement? consist of 34 large ones and 8 medium ones.

10. SIC 2761  Manifold Business Forms

     This industry includes  establishments engaged primarily in designing and
printing special forms for use in operation of a business. These may be in single or
multiple sets, including  carbonized or interleaved with carbon or otherwise
processed for multiple reproduction. There are 658 establishments: 145 large, 223
medium, and 290 small.

     In addition  to printing presses, the forms industry has need for specialized
equipment such as collators, folders, gluers, etc., used to combine rolls of paper
and carbon paper into a multiple layer suitable for the final product. The need for
large capital  equipment expenditures has tended to concentrate the industry; in
1973 the three largest companies had 50 plants, and these accounted  for 42% of
the industry's shipments.

     The manifold business forms industry uses both offset and letterpress equip-
ment. The ratio is approximately 80 to 85% for offset and 15 to 20% for printing
by letterpress. However, the letterpress operations  use rubber plates to produce
the impression and the preparation of these plates is non-polluting. This industry
is essentially non-polluting.

11.  SIC 2771 Greeting Card Publishing

     The greeting card publishing segment includes 39 large, 40 medium, and 116
small  plants  for a total of 195. The Census data indicate that in 1970 the eight
largest companies accounted for 85% of the value of industry shipments.

     Among  the large plants are  some  that  do  most of their own printing
(primarily offset) but the  more usual  practice in  the industry is to purchase
printing services. Most greeting cards are designed well in advance of the occasion
for their sale  so the publisher can negotiate prices for printing based on the use of
                                      40

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the presses in non-critical times. The medium-sized companies rely heavily on the
commercial printing segments for their production.  Small business may print their
own cards, but they would be using non-polluting printing technology —  silk
screen, offset, flat bed letterpress. Letterpress is used  by many small shops for
imprinting the names of the sender. Plates for engraved cards are usually prepared
by a mechanical process.

     Although this industry utilizes all of the printing methods, the big operations
are primarily  offset, and  where letterpress is used, it is not based on etched metal
plates. This industry is non-polluting.

12. SIC 2793 Photoengraving

     The  photoengraving industry includes establishments engaged  primarily in
preparing photoengraving plates. Much of this work is performed for advertising
agencies, platemakers  and printers. Most of the companies in this industry also
make color separations and more recently have diversified into the preparation of
offset printing plates.

     The  engraving operations of these companies  result in zinc, copper, magne-
sium, and other metal salts being accumulated in the acid etching baths they use.
The quantity  of the waste from  these  operations is  not large for a small or
medium-sized  company.  The effluent is  frequently placed in plastic drums and
removed to land fill. Sometimes it is neutralized, the solids allowed to settle and
the solids then removed via  the solid waste stream. Only the large plants generate
any significant amount of waste.

     Subsegmentation of the 584 plants making up this industry shows that  17
are large, 112 medium, and 455 are  small plants. The 17 large plants  warrant
further study, because they are a significant source of pollution.

     The  total  revenues for the photoengraving  industry have been declining in
recent years as has the number of plants that make up the industry. There will be
base line closures of about 35 plants per year through 1980 with total revenues at
that time amounting to only  $110 million. This is half the revenues for  the
industry for the year 1972.

13. SIC 2794 Electrotyping and Sterotyping

     This industry includes establishments engaged  primarily in preparing electro-
type and stereotype plates for the printing industry. Subsegmentation by size of
the 80 plants that comprise the industry shows that there are 3 large plants, 21
medium plants, and 56 small plants.
                                     41

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    The number of plants and the value of shipments in the industry have been
decreasing steadily for a number of years. The estimated value of shipments for
1974, for example, is expected to be only one-third  of what it was in 1972.  A
corresponding reduction is taking place in the number of plants. This is clearly a
dying industry and it is expected to be extinct by 1980.

14. SIC 2795 Lithographic Platemaking Services

    This industry is engaged primarily in manufacturing lithographic plates for
use by offset printing establishments. It is a healthy  and growing industry. The
298 plants which make up the industry can be  subsegmented into 30 large, 68
medium, and 200 small plants. The industry is non-polluting.

D. SUBSEGMENTATION SUMMARY

    The analysis  of the 14 major segments carried out above has resulted in each
segment being subsegmented into small, medium, and  large plants. Each of these
subsegments has been examined for possible impact as a result of the pollution
control standards. The results of our analyses are summarized in Table 111-12. All
of the plants included in the summary are either printers or  platemakers for the
printing trade regardless of what other activities the plant might perform.

    It is interesting that in all industries  where process waste water is  being
generated it is  being generated mainly by the large companies. In those few
instances in which small companies are producing waste that is not compatible
with municipal  treatment systems, the volumes  involved are small and there are
more economic alternatives for disposal than those supplied in the Development
Document.
                                     42

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                IV. FINANCIAL PROFILE OF THE INDUSTRY

       Many of the companies in the printing and publishing industry are closely-
  held corporations. As a result, financial information is considered proprietary and
  is generally difficult to obtain. However, many companies in the industry belong
  to trade associations and participate  annually in association-sponsored financial
  studies  of the various industry segments.  In many cases the  results of these
  studies are sold to help defray the cost of the study. In other cases the results are
  sometimes available from participating companies.

       The  largest  trade  association  in the industry is Printing Industries  of
  America, Inc. Its membership represents firms which account for more than 80%
  of all the  printing  produced in the  United States.  The general well-being and
  future of  the printing industry was  discussed in an address by its  president,
  Rodney L. Borum, at the annual meeting of the National Association of Printing
  Ink  Manufacturers on March 28, 1974. The  following are excerpts from Mr.
  Borum's speech, "The Printing Industry - Its Growth and Future."

       "The  printing  and publishing industries continue to mirror the nation's
  economic and demographic trends. Demand for printed products is stimulated  by
  a combination of population  growth, rising  school enrollment, higher income
  levels and expanded business activity. The printing and  publishing industries will
  always be characterized by steady growth, stable employment, higher wages and a
  large number of small establishments.

       For  1973, total receipts for the printing, publishing and allied industries*
  amount  to approximately  $34 billion. Growth  through 1974 is expected  to
  continue, and the dollar volume will  approximate $37 billion — almost 9% above
  the 1973 level."

       In presenting detailed industry statistics for 1973 and forecasts for 1974 and
  1980, Mr. Borum  refrained  from commenting on the newspaper publishing,
  periodicals publishing, book publishing and  miscellaneous publishing segments of
  the industry. Those industry segments which were included in both his speech and
  this study are listed in Table IV-1, which shows estimated revenues by segment
  for the years 1973, 1974, and 1980.

       Clearly, most segments in the printing and publishing industry are strong and
  healthy. They are able to  finance new investments, to take  advantage of new
  technology and to remain competitive and look optimistically to the future as
  one of expanding markets and growth opportunities.
"The 17 segments in Major Group 27
                                     43

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                                TABLE IV-1

                       PRINTING INDUSTRY REVENUES
                                 ($ millions)
                                         1973
               1974
               1980
Book Printing
Commercial Printing, Letterpress
Commercial Printing, Lithographic
Engraving and Plate Printing
Commercial Printing, Gravure
Manifold Business Forms
Greeting Cards
Photoengraving
Electrotyping and Stereotyping
Lithographic Platemaking Services
 1,045
 4,500
 5,500
  210
  825
 1,510
  585
  200
   20
  260

14,655
 1,108
 5,000
 6,000
  225
  920
 1,650
  615
  185
    12
  280

15,995
 1,600
 7,100
10,500
  350
 1,800
 2,800
  815
  110

  470

25,545
A.  SALES

     Total values of shipments for the  14 segments included in this study were
$28.5 billion in 1972, as shown in Table III-4. Table III-4 also shows the average
value of shipments per establishment for all segments. Table IV-1 suggests that the
overall average growth in revenues for the industry through 1980 might approxi-
mate 10% per year. The two segments in which contraction rather than growth
will take place — Photoengraving and Electrotyping, and Stereotyping — together
represent less than 1% of the printing and publishing industry. Many companies in
these two segments have been consolidating and diversifying into trades that are
more in demand.

     Table III-5 showed the number of plants and the value of shipments by plant
size for  selected segments of the industry. Table III-6 provided information on
industry concentration by  showing the percent of the total and the average value
of shipments per plant for the 4, 8, 20, and 50 largest companies in each industry
segment.  Similar  data are provided for the  average remaining plants in each
industry after deducting the total value of shipments attributable to the 50  largest
plants.

B.  EARNINGS

     The printing and publishing industry generally  does not  publish data on
earnings. The best source of  such  information is the Ratio Studies,  e.g., the PIA
Ratio Studies  referred to  in  Chapter V and similar studies carried out by other
industry segments.
                                     44

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                IV. FINANCIAL PROFILE OF THE INDUSTRY

       Many of the companies in the printing and publishing industry are closely-
  held corporations. As a result, financial information is considered proprietary and
  is generally difficult to obtain. However, many companies in the industry belong
  to trade associations and participate  annually in association-sponsored financial
  studies  of the various industry segments.  In many cases the  results of these
  studies are sold to help defray the cost of the study. In other cases the results are
  sometimes available from participating companies.

       The  largest  trade  association  in  the industry is Printing Industries  of
  America, Inc. Its membership represents firms which account for more than 80%
  of all the  printing  produced in the  United States.  The general well-being and
  future of  the printing industry was  discussed in an address by its  president,
  Rodney L. Borum, at the annual meeting of the National Association of Printing
  Ink  Manufacturers on March 28, 1974. The  following are excerpts from Mr.
  Borum's speech, "The Printing Industry - Its Growth and Future."

       "The  printing  and publishing industries continue to mirror the nation's
  economic and demographic trends. Demand for printed products is stimulated  by
  a combination of population growth, rising  school enrollment, higher income
  levels and expanded business activity. The printing and  publishing industries will
  always be characterized by steady growth, stable employment, higher wages and a
  large number of small establishments.

       For  1973, total receipts for the printing, publishing and allied industries*
  amount  to approximately   $34 billion. Growth  through 1974 is expected  to
  continue, and the dollar volume will  approximate $37 billion — almost 9% above
  the 1973 level."

       In presenting detailed industry statistics for 1973 and forecasts for 1974 and
  1980, Mr. Borum  refrained from  commenting on the newspaper publishing,
  periodicals publishing, book publishing and  miscellaneous publishing segments of
  the industry. Those industry segments which were included in both his speech and
  this study are listed in Table IV-1, which shows estimated revenues by segment
  for the years 1973, 1974, and 1980.

       Clearly, most segments  in the printing and publishing industry are strong and
  healthy. They  are able to  finance new investments, to take  advantage  of new
  technology and to remain competitive  and look optimistically to the future as
  one of expanding markets and growth opportunities.
*The 17 segments in Major Group 27
                                     43

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                                TABLE IV-1

                       PRINTING INDUSTRY REVENUES
                                 ($ millions)
                                          1973
               1974
               1980
Book Printing
Commercial Printing, Letterpress
Commercial Printing, Lithographic
Engraving and Plate Printing
Commercial Printing, Gravure
Manifold Business Forms
Greeting Cards
Photoengraving
Electrotyping and Stereotyping
Lithographic Platemaking Services
 1,045
 4,500
 5,500
  210
  825
 1,510
  585
  200
   20
  260

14,655
 1,108
 5,000
 6,000
  225
  920
 1,650
  615
  185
    12
  280
15,995
 1,600
 7,100
10,500
  350
 1,800
 2,800
  815
  110

  470
25,545
A. SALES

     Total values of shipments for  the  14 segments included in this study were
$28.5 billion in 1972, as shown in  Table III-4. Table III-4 also shows the average
value of shipments per establishment for all segments. Table IV-1 suggests that the
overall average growth in revenues for the industry through 1980 might approxi-
mate 10% per year. The two segments in which contraction rather than growth
will  take place - Photoengraving and Electrotyping, and Stereotyping - together
represent  less than 1% of the printing and publishing industry. Many companies in
these two segments have been consolidating and diversifying into trades that are
more in demand.

     Table III-5 showed the number of plants and the value of shipments by plant
size  for selected segments of the industry. Table IH-6 provided information on
industry concentration by  showing  the percent of the  total and the average value
of shipments per plant for the 4, 8, 20, and 50 largest companies in each industry
segment.  Similar  data are provided for the average  remaining plants in each
industry after deducting the total value of shipments attributable to the 50 largest
plants.

B. EARNINGS

     The  printing and publishing  industry generally  does not publish data  on
earnings. The best source of such information is the Ratio Studies, e.g., the PIA
Ratio Studies referred to  in Chapter V and  similar studies carried out by other
industry segments.
                                     44

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C. CASH FLOW

    This information, like that for earnings, is best obtained from PIA and other
Ratio  Studies. Cash flow data is presented in Table V-l.

D. NEW CAPITAL INVESTMENT

    Data on new capital  investment are  included in the Census of Manufactures
reports prepared by the U.S. Department of Commerce. Table IV-2 lists the new
investment data for the various segments for the years 1963, 1967, and 1972. It is
clear from these data that substantial new investment is made each year by the
various  industry segments  and  that the amount is increasing  year by year.
Between 1963 and  1967  the average new capital investment increase was about
17% per year compared to that of 1963. Between 1967 and 1972 that increase
averaged about 7% per year compared to 1967.

    Although the  investment in each  of the segments for new capital improve-
ments will  vary from  year  to year by  industry needs and new technological
developments,  these data reflect  an industry whose plants are attempting to
maintain their competitive position vis-a-vis other plants and other communica-
tion industries and it is expected that this trend will continue.

E. MISCELLANEOUS FINANCIAL INFORMATION

    Selected financial informaticn is tabulated in Table 1V-3 for the six industry
segments studied for possible impact. These data are almost exclusively for large
plants. The  values given  are estimated values for  1972 constructed  from the
detailed information available from the 1967 Census of Manufactures as applied
to the available  preliminary  1972 data. There will be discrepancies between the
data in this table and other average values presented throughout the report. These
values are based on the largest subsegments in each industry  segment and should
typify those plants studied for impact.
                                     45

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                                    TABLE IV-2

                          ANNUAL CAPITAL INVESTMENT


SIC                                             New Capital Expenditures ($MM)
Code              Industry                  1963           1967            1972


2711   Newspapers                          135.2           246.7           360.0
2721   Periodicals                            33.8            58.0            54.9
2731   Book Publishing                       25.4            55.1             49.0
2732   Book Printing                         24.9            45.9            34.0
2741   Misc. Publishing                        7.1            10.0            23.4
2751   Comm. Print.. L.P.                     89.0           120.4           126.1
2752   Comm. Print., Litho                    76.9           125.6           220.4
2753   Engraving and Plate Print.                3.8             3.8            4.3
2754   Comm. Print., Gravure                  10.2            22.6            207
2761   Manifold Bus. Forms                   23.1            39.8            45.5
2771   Greeting Card Publishing                 6.8            14.9            45.2
2793   Photoengraving                         5.7             6.3             4.9
2794   Electrotyping and Stereotyping           1.0             0.7             0 4
2795   Litho Platemaking Services               -              _              s.5

             Total                           442.9           749.8           998.8

Source:  Census of Manufactures, 1963, 1967 and preliminary 1972.
                                        46

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SIC Code
                                                        TABLE IV-3




                                  FINANCIAL PROFILES OF SELECTED INDUSTRY SEGMENTS
Industry
2711
2721
2741
2751
2754

Newspapers
Periodicals
Misc. Publishing
Comm. Printing, L.P.
Comm. Printing, Gravure

Large
Large
Large
Large
Large
Printer
Medium
Roll Maker
                                                                                    Average Per Plant
  2793
Photoengraving
Size of Plant
Large
Large
Large
Large
Large
Printer
Medium
Roll Maker
Large
Employees
462
389
475
272
456
47
107
Annual
Value of Shipments ($M| New Investment ($M)
12,330
12,122
13,300
6,979
15,867
1,611
3.109
520
312
281
292
511
29
68
Sources: Census of Manufactures, 1967 and preliminary 1972; ADL estimates.

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                           V. MODEL PLANTS

     Financial models of representative  plants studied for possible impact were
constructed for the Newspaper; Periodicals; Miscellaneous Publishing; Commercial
Printing, Letterpress; Commercial Printing, Gravure and Photoengraving  indus-
tries. In all cases the models were for large plants, i.e., those having more than 100
employees, because they  are the  principal sources of  significant amounts of
process contact effluent in  their  platemaking operations. Small and  medium
printing plants  generally rely upon  purchased  services for their plates and thus
avoid such problems. Moreover, the small and medium plants that may be etching
metal for platemaking  purposes have the option of disposing of their relatively
small amounts of waste by means that  do not require significant capital invest-
ments.

A. SIC 2711  NEWSPAPERS

     American  Newspapers Publishers Association, Research Institute data show
that  the largest group of newspaper plants is the  25,000-100,000 circulation
category and that many of these plants are engraving metal. Smaller plants are
predominantly  offset  and  therefore, non-polluting. Larger plants are engaged
principally  in metal engraving because of their duplicate plate requirements and
are contributors to pollution.

     We  have  selected  two  models as representative of newspaper plants  that
contribute  to pollution. Financial profiles of both are shown in Table V-l. The
first  plant is a medium circulation plant typical of the largest group of newspapers
and  characterized as a small  city  daily.  It has an average circulation of 57,000.
Our  model (Table V-2) conforms  to a survey  made in  1973 of about 50 news-
paper  plants of this approximate  size.  The second plant is a larger (167,000
circulation) newspaper plant characteristic of an urban paper publishing both
morning and evening editions. The  model is derived on the basis of data for 25
plants of similar size described in  the same survey. Table V-2 includes only the
basic economic data necessary to make a preliminary judgment of the  fit of our
model into industry averages. The range, which shows a spread of values for the
plants within a similar size group, is compared to the ADL model. This approach
also has been used for the other printing industry segments.

B. SIC 2721 PERIODICALS AND SIC 2741 MISCELLANEOUS PUBLISHING

     From  a review of the  Standard  &  Poors  listing of plants in  these  two
classifications and ADL's experience with this industry  we identified a limited
number of plants large enough to  engrave metal and contribute  to pollution. We
contacted most of  these plants to confirm their engraving activities.  Both SIC
2721 and 2741 are  included as identical models because  of overlapping activities
and  size. Our information indicates that a typical plant  for these two classifica-
tions would have the financial profile shown in Table V-l.

                                    49

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                                                      TABLE V-1

                                          FINANCIAL PROFILE OF MODEL PLANTS
                                                       ($000*s)
                           2711
2721
2741
2751                2754
2793
Newspapers
Miscellaneous
Periodicals Publishing
Medium Large
Circulation Circulation
Plant Plant
Sales 6,600
Expenses
PBT
PAT
Depreciation
Cash Flow
Net Assets
Number of Employees
Return on Assets (%)
5,600
1,000
500
178
678
3,384
298
14.80
23,400
20,300
3,100
1,550
565
2,115
15,200
1,006
10.28
30,000
27,150
2,850
1,425
881
2,306
17,625
1,175
8.08
30,000
27,150
2,850
1,425
881
2,306
17,652
1,175
8.08
Commercial Printing
Letterpress
Directory
Printing
Plant
15,470
14,743
727
363
557
920
10,400
650
3.49
Catalog
Printing
Plant
10,530
9,993
537
269
310
579
7,410
390
3.63
Commercial Printing
Gravure
Printing
Plant
10,600
9,752
848
424
564
988
9,540
425
4.44
Rollmaking
Plant
1,000
890
110
55
65
120
1,000
50
5.50
Photoengra
3,775
3,419
356
178
74
252
2,085
150
8.53
(after taxes)

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                                 TABLE V-2
Sales   ($000)

PBT
(7, of Sales)

Depreciation
(% of Sales)

Net Assets
(7» of Sales)
                      CHARACTERISTICS OF MEDIUM- AND
                    LARGE CIRCULATION NEWSPAPER PLANTS


                           Medium Circulation
                                Plant
                     Range

                  4,200-7,700


                   11.7-20.2


                    2.7-4.5


                     39-6J
 ADL
Model

6,600
15.2
 2.7
 51
                                                        Large Circulation
                                                            Plant
    Range

9,700-25,000


  10.3-19.2


   2.3-2.9


    52-78
 ADL
Model

23,400
 13.3
  2.4
  65
                                 TABLE V-3

                    CHARACTERISTICS OF PERIODICALS AND
                      MISCELLANEOUS PUBLISHING PLANTS
                              Industry Range
       Sales ($000)

       PBT
       (% of Sales)

       Depreciation
       (7, of Sales)

       Net Assets
       (7o of Sales)
                        22,000-30,000


                           2.8-9.7


                           3.1-5.0
                            52-60

Source: Printing Industries of America, Ratio Study, 1973.
                   ADL Model


                   30,000


                      9.5


                      2.9


                       59
                                     51

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   C. SIC 2751 COMMERCIAL PRINTING, LETTERPRESS

        A commercial letterpress printer large enough to justify internal platemaking
   and  therefore, a potential polluter, would  be oriented primarily to rotary letter-
   press. Our experience and public information indicate that such a printer would
   be expected to have a sales volume of at least $8-20 million.

        We have constructed two models for this classification; their financial profile
   is shown  in  Table V-l. The first  model is a web printer primarily engaged in
   directory  printing. The second  is a printer primarily engaged in catalog printing.
   Two models were selected because there are differences in the markets, technol-
   ogy  and profits for the two products. Our selection of model plants was based on
   data abstracted from a  1972 industry survey by PIA (Table V-4).

                                    TABLE V-4

         CHARACTERISTICS OF DIRECTORY AND CATALOG PRINTING PLANTS


                       	Directory Printing Plant         	Catalog Printing Plant
                            Range         ADL Model           Range          ADL Model

Sales  ($000)          8,000-20,000       15,470       9,000-21,000        10,530

PBT
(% Sales)               3.0-9.0            4.7            4.0-10.0             5.1

Depreciation
(% Sales)               2.7-3.0            3.6            2.7-3.0              2.9

Assets
(% Sales)                 59-84               67            59-84               70

   Source: Printing Industries of America, Ratio Study, 1973

    D.  SIC 2754 COMMERCIAL PRINTING, GRAVURE

        There is essentially no  public information regarding the financial profile of
   plants engaged in gravure printing or gravure roll preparation. Most of these plant
   are  privately owned  and highly  competitive and  the firms are  quite secretive
   concerning financial data. In fact, one contact reported, "In this industry one
   comptroller does not even recognize the comptroller of a competitive firm." As a
   result we have constructed our models on the basis of  in-house knowledge but
   these have been confirmed  in  principal with private conversations with several
   financial  people in the industry. Our gravure printing plant model  prepares its
   own chemically engraved rolls  and is therefore a potential source  of pollution.
                                        52

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      The model  gravure rollmaking  plant is only partially engaged in  chemical en-
      graving but must  be  considered a potential source  of pollution. The financial
      profiles of both models are described in Table V-l.

           Our choice of models was based on our best estimation of the range of values
      to be expected in this industry (Table V-5).

                                      TABLE V-5

                CHARACTERISTICS OF PRINTING AND ROLLMAKING PLANTS


                             Printing  Plant                 Rollmaking Plant
                         Range         ADL Model       Range            ADL Model
Sales  ($000)          6,000-20,000       10,600       300-1,600           1,000

PBT
(7. Sales)               3.0-11.0          8.0          8.0-14.0             11.0

Depreciation
(?„ Sales)               2.0-6.0           5.3          2.0-8.0                6.3

Assets
(% Sales)                70-100             90           50-100                 100


       Source:  Arthur D. Little, Inc., estimates.

       E.  SIC 2793 PHOTOENGRAVING

           Photoengraving, as a primary source of income, is a dying business as shown
       by most information that  is available  publicly or from  industry contacts. The
       main reasons are  the decline of letterpress printing and the growth of competitive
       plastic plate systems. Those firms that survive will be supplying  mainly services,
       such as offset plates and color separations, for use in other printing processes. The
       more  successful firms still engaged in a reasonable amount of photoengraving are
       closely associated with  advertising agencies or publishers. The rationale  behind
       their success is their ability  to supply the offset and gravure printing industry with
       photographic  preparatory copy that  closely simulates letterpress copy found in
       national ads.

           We have  constructed  a  model of a large photoengraver, and the financial
       profile is shown in  Table V-l. It should be kept in mind  that photoengraving, as
       such,  is ;>n  esse itial but minor part  of the overall business of this model. Our
                                            53

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model  is based on  data abstracted from  1972 PIA  studies  supplemented by
individual industry contacts (Table V-6).

                               TABLE V-6

              CHARACTERISTICS OF PHOTOENGRAVING PLANTS

                                Range                       ADL Model
Sales ($000)
PBT
(7, Sales)
Depreciation
(% Sales)
Net Assets
(% Sales)
3,500-4,000
7.4-12.0
1.0-5.0
40-60
3,775
9.4
2.0
55
Sources:  Printing Industries of America, Ratio Study, 1973, and Industry Contacts.
                                    54

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           VI. ECONOMIC IMPACT ANALYSIS METHODOLOGY

     In our determination of the impact of pollution control costs on the printing
industry, the principal considerations were the effects of the costs on profit
margins and the determination of whether the costs could be passed on in the
form of higher prices for printed  product. However, a host of secondary effects
were also considered. These  included possible effects on  level of production,
employment, growth of the company, ability of the company to raise new capital,
hardships on the community, and international trade.

     The economic analysis was concentrated on those segments of the printing
industry which use technology that causes significant water pollution. The frame-
work for  the  analysis was the model plants defined  for each of the segments
studied. The feasibility of  investing capital to control pollution was assessed on
the basis of the effect of the  increased cost on profitability, a comparison of the
required capital expenditure for pollution control with annual new capital expen-
ditures for each of the models, and estimates of the revenue or price increases
necessary to recover  the additional expense and provide the same return on assets
with the expanded  asset base. The data was also analyzed to determine the
probable effect of BPT and BAT standards on plant closures directly related to
pollution  control requirements. The sensitivity of the analysis under different
conditions, such as  those  that would  obtain  because a printing plant did not
conform exactly to a model plant,  was also considered.

A.  FUNDAMENTAL METHODOLOGY

     The development of model plants in the previous chapter shows representa-
tive values for profit after taxes, depreciation, cash flow and net assets for each of
the segments studied. The primary factors in assessing the  financial and produc-
tion impact of pollution control costs are the changes in profitability as a result of
adding the incremental costs  to the financial models  and  the ability to recover
these costs and maintain profitability levels through higher prices. A number of
factors will, of course, influence closure decisions but these two measures offer an
acceptable guide to the financial analyst.

     One  other factor that might influence closure decisions importantly, and
that is a most  important variable in this analysis, is the nature of  the polluting
operation, e.g., whether it  is a division of a large printing  company, or whether
the principal business of the company is supplying  printing plates to the printing
trade.

     The first object of the analysis was to determine  the extent of the financial
impact.  Subsequently, any  areas that would suffer significant impact were ana-
lyzed for closure decision based on cash flow. If the water pollution control costs
                                   55

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reduced profits or were small relative to annual depreciation expenses, there was
no necessity for a detailed cash flow analysis.

B. PRICE EFFECTS

     Calculation of the price increase necessary to offset lower profitability took
into consideration  the  expanded asset base resulting from  the  addition of the
water pollution  control  equipment  as well as the associated annual costs. We
computed the return  on assets before the new investment is  made. We then
determined the expanded asset base by adding to the present total assets the cost
of water pollution control equipment. Multiplying the total  asset base by return
on assets, we determined the new profit before taxes that is needed to provide the
same return  being  made before the pollution control  equipment was installed.
This approach  does not jeopardize or weaken the competitive  position of the
affected plant.

     Because this is a sales price increase,  the additional revenue received will be
additional profits before tax and there is no incremental cost of goods sold to be
subtracted. Our actual volume of sales does not increase, only the revenues. The
difference between necessary  new profits computed on the  expanded asset base
and  the previous  profit earned  equals the  necessary increase in revenues. Accord-
ingly, this increase in revenues divided by the previous  revenue level defines the
percentage revenue increase equal to the  percentage price increase. This then is
the price effect brought about  by passing  along, completely to the consumer, the
cost of installation of a water pollution control system.

     In the  printing industry there would  appear to be  two  areas for application
of price increases to be imposed on a product though  in reality there should be
only one. For a company in a service industry or for a company in the roll-making
portion  of  the  Commercial Printing, Gravure  segment,  the cost  of pollution
control would affect  the  price of the product, that  is, the printing  plate or
cylinder.  This  price increase would  have to include  allowance for profit and
depreciation. In  an integrated plant where the platemaking operation is part of
the  whole printing service, the incremental cost from pollution control might not
be seen  as directly applicable  to the cost of preparing the plates although this
would be a reasonable method of cost  accounting.  The latter  plant might take
the  alternate view of spreading the cost of the plate over the cost of the amount
of printed material that the plate would produce, in which case the apparent cost
per  unit of printing would be a function  of the length of the run, and thus dilute
the  burden of the increase.

C.  FINANCIAL  EFFECTS

      The financial  characteristics of the model plants were used as  the reference
base for the analysis of the financial effects  of the added costs  due to pollution
                                     56

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control. The measures of profitability used were Return on Assets and after-tax
profit as a percent of sales. The  resulting ability of the industry to finance the
required  pollution control  expenditures will  vary  from one segment of the
industry to another, so capital availability and cost were examined for each model
plant in the segments studied.

D. PRODUCTION EFFECTS AND INDUSTRY GROWTH

    Production effects are related to price increases and profitability insofar as
they influence  sales  volume  and plant closures or adversely  affect industry
growth. In  this industry there is a history of change and adaptation, and the
current situation is one  of rapid  change in technology. We relied principally on
our background in and experience with this industry to assess the impact of the
costs of pollution control on production curtailment and industry growth.

E. EMPLOYMENT EFFECTS

    Employment effects were estimated from the potential plant closures. Where
curtailment in production or slowdown of industry growth was anticipated the
effect on employment was estimated on the basis of the extent of the change
expected in the segment of the industry affected.

F. COMMUNITY EFFECTS

    Community effects, direct and indirect, were considered on the basis of the
segments shown by the analysis to be adversely affected. Significant factors would
be the loss of revenue to employees, loss of employment, the loss of taxes to the
community, and the size  of the printing industry in the community.

G.  INTERNATIONAL TRADE EFFECTS

    There is some international  trade traffic in raw materials (paper, ink, etc.),
and in finished products (books,  magazines, etc.), both import and export. This
traffic is variable and  influenced by many considerations. These were evaluated to
determine whether any major production or price effects would have an impact
on this trade.
                                   57

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                    VII. EFFLUENT CONTROL COSTS

     The control costs used in this analysis are those presented in the Develop-
 ment Document for Proposed Effluent Limitations Guidelines.

     The BPT requirements for the printing and publishing industry have been
 determined to be a combination of flow equalization and reduction of pollutants
 to the levels shown in Table VIM. The BAT requirements for this industry are
 the reduction of pollutants to  the levels shown in Table VII-2. (All tables in this
 chapter except Table VII-7 are  taken from the Development Document.)

                                TABLE VIM

                   CONCENTRATION LIMITATIONS FOR BPT

                                                             Limitation
         Parameter                                             (mg/1)

Biochemical Oxygen Demand  (20°C,  BOD  )                        30     ,
Hydrogen Ion  (pH)                                           6.0-9.05-'
Phenols                                                          0.1
Total  Suspended  Solids                                          30
Oil  and  Grease                                                  ^-^v,/
Organic  Solvents                                             None—
a/ Expressed  as standard units.
b_/ Maximum in-plant control to prevent discharge.
      Wastes from the flat-bed letterpress, offset and screen printing operations
 will be required to meet only the limitations shown in Table VIM. Treatment
 levels for BAT and NSPS are equivalent to those for BPT. No pretreatment is
 required.

      Wastes from gravure, flexography  and  rotary letterpress operations will be
 required to meet all limitations in Table VII-2 to satisfy the requirements for BAT
 and NSPS.

      The Development Document indicates that the cost of achieving BPT, BAT,
 and NSPS requirements for flat-bed letterpress, offset, and screen printing is zero
 and that the cost of pretreatment is also zero.

      The Development Document estimated  costs of  the  different  levels of
 pollution control for the gravure, flexography  and rotary letterpress facilities are
                                    59

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 reproduced in Tables VII-3 through VII-6. These cost data are summarized in
 Table VI1-7 for each of the model plants studied in the impact  analysis. The
 Development  Document estimated  the cost for plants of three sizes. Since the
 largest plant in existence is only about 5000 gpd (process waste),  only this size
 was considered in the analysis.

                                TABLE VII-2

                   CONCENTRATION LIMITATIONS FOR BAT
        Parameter

Aluminum

Biochemical  Oxygen Demand  (20°C,  BOD,.)

Chromium,  Total

Copper

Hydrogen  Ion (pH)

Iron - Total

Lead

Magnesium

Manganese

Phenols

Total Suspended Solids

Zinc

Oil and Grease

Organic Solvents
Limitation
  (mg/1)

   0.5

    *J

   0.5

   0.5

6.0-9.0^

   i.o

   0.05

   100

   1.0

   0.1

    a/

   0.5

    10

  None5-/
a/  These concentration levels will be the same  as  those to be defined
    as  best practicable control technology currently available for
    publicly-owned treatment works.
b_/  Expressed as standard units.
c/  Maximum in-plant control to prevent discharge.
                                  60

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                                TABLE VII-3

                      ESTIMATED COST OF BPT GRAVURE,
               FLEXOGRAPHY AND ROTARY LETTERPRESS FACILITIES
                                           FACILITY SIZE
                                   33                1
                               19 m /day     95 m /day       190 m /day
                              (5.000 gpd)   (25.000 gpd)    (50.000 gpd)

INVESTMENT COSTS:
   Neutralization and flow      $10,000       $20,000          $30,000
     equalization including
     automatic pH probe
     and chemical storage
     and feed

   Package biological treat-     15,000        40,000           55,000
     ment plant

   Pipes and pumps
          TOTAL COST
ANNUAL COSTS:
   Chemicals                    $   300       $ 1,300          $ 2,500
   Sludge removal                   100           500            1,000
   Operation & Management         1,000         3,000            4,500
   Capital                        2,600         6,200            8,800
   Depreciation                   2,600         6,200            8,800

          TOTAL ANNUAL COSTS    $ 6,600       $17,200          $25,600
               (less power)

Power                           $   500       $ 1,500          $ 2.500

          TOTAL ANNUAL COSTS    $ 7,100       $18,700          $28,100
(sq ft)

1,000
(200)
$26,000
2,000
(600)
$62,000
3,000
(1,000)
$88,000
                                   61

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                                TABLE VII-4

            ESTIMATED INCREMENTAL COSTS OF BAT ABOVE BPT GRAVURE,
                FLEXOGRAPHY AND ROTARY LETTERPRESS FACILITIES
                                           FACILITY SIZE
INVESTMENT COSTS:
   Chemical feed, mix tank
   Sedimentation tank

          TOTAL COST
ANNUAL COSTS:
   Chemicals
   Sludge removal
   Operation & maintenance

          SUBTOTAL
Power
Depreciation
Capital

       TOTAL ANNUAL COSTS
19 m3/day
(5,000 gpd)
$ 3,500
3,000
$ 6,500
$4,000
2,500
500
$ 7,000
650
650
95 m3/day
(25,000 gpd)
$ 4,000
8,000
$12,000
$20,000
12,500
1,000
$33,500
negligible
1,200
1,200
190 m3/day
(50,000 gpd)
$ 4,500
15,000
$19,500
$40,000
25,000
1,500
$66,500
1,950
1,950
                                 $8,300
$35,900
$70,400
                                    62

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                                 TABLE VI1-5

                      ESTIMATED COSTS OF NSPS GRAVURE,
                FLEXOGRAPHY AND ROTARY LETTERPRESS FACILITIES
                                           FACILITY SIZE
                               19 m3/day     95 m3/day       190 m3/day
                              (5.000 gpd)   (25.000 gpd)     (50.000 gpd)

INVESTMENT COSTS:
   BPT Investment               $26,000       $62,000          $88,000
   Costs
   (Table VII-3)

   Incremental BAT                6,500        12,000           19,500
   Investment Costs
   (Table VII-4)

ANNUAL COSTS:
   BPT                            6,600        17,200           25,600
   (Table VII-3)

   Incremental BAT
   (Table VII-4)                  8.300        35,900           70,400

          TOTAL ANNUAL COST     $14,900       $53,100          $96,000
          (less power)

   Power                            500         1.500             2.500

          TOTAL ANNUAL COST     $15,400       $54,600          $98,500
                                    63

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                               TABLE VII-6

         ESTIMATED COSTS OF PRETREATMENT FOR NEW SOURCES GRAVURE,
              FLEXOGRAPHY AND ROTARY LETTERPRESS FACILITIES
                                           FACILITY SIZE
                               19 m3/day     95  m3/day        190 m3/day
                              (5,000 gpd)    (25,000 spd)     (50.000  gpd)

INVESTMENT COSTS:
   Existing Source              $10,750       $21,500           $32,500
   Investment Costs
   Incremental BAT                6,500        12,000           19,500
   Investment Costs
   (Table VII-4)

          TOTAL COST            $17,250       $33,500          $52,000
ANNUAL COSTS:
   Existing Source              $ 2,850       $ 6,950          $10,750
   Incremental BAT                8.300        35.900           70.400
   (Table VII-4)

          TOTAL ANNUAL COSTS    $11,150       $42,850          $81,150
                                    64

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2793
                                                       TABLE VII-7




                                  COST OF PROPOSED EFFLUENT GUIDELINES FOR MODEL PLANTS
                                                                  BPT COSTS  ($M)
                                                                             BAT OR NSPS  COSTS  ($M)
                                                FACILITY
SIC CODE
2711


2721
2741
2751


2754

INDUSTRY
Newspapers
Med. Cir^,
Lge, Clr.* -
Periodicals *,
Miec. Publishing -
-------
                         VIM.  IMPACT ANALYSIS

     As indicated  earlier, this industry  is unusual in that the main source of
pollution is the larger companies. Furthermore, the polluting processes themselves
are concentrated in one part of the  operation, platemaking,  and in particular,
those steps that involve etching metal with acid. Although some small photo-
engravers still etch metal, the volume of acid waste generated is easily disposed of
by drumming  without adding significantly to the cost  of the  plates. The large
companies continue to use polluting technology because of their large  investments
in printing  equipment, the need for duplicate plates, the demand for top-quality
printing for long-run national ads,  and the cost of conversion to non-polluting
printing methods.  Thus the analysis focuses  on  the  profitability, capital  avail-
ability and  price effects for the large model plants.

A. PROFITABILITY AND CAPITAL AVAILABILITY EFFECTS

     Capital availability can  be affected on either the cash outflow or inflow side.
On the  outflow side, if  the  necessary investment in the water  pollution control
system  is a large  percentage of the  total funds  available, capital  will not be
available for investment elsewhere.

     Table  V-l  contains financial data of the model plants who use  polluting
technology. The models are  large companies because polluting technology is used
almost exclusively  by large printers. The level  of investment necessary to comply
with the BPT and  BAT guidelines is shown in Table VIII-1 to be small, especially
with respect to the size (assets, sales, etc.) of these large companies. Our approach
begins with an  analysis  of  the size  of  the company relative  to  the necessary
investment.

     In  Table VIII-1 we compare the  investment cost of BPT and BAT standards
with annual depreciation. Faced  with inflation and advances in technology, the
larger printing companies are probably now investing more in new  fixed  assets
than their depreciation allowances suggest. By using depreciation, we err on the
conservative side, showing a higher percentage of capital investment to be invested
in water pollution control equipment.

     Our second comparison is sales revenue with the annual operating costs of
these systems.  Again,  Table VIII-1  shows  the amount  to be  insignificant. We
conclude that the capital outflow will not be increased greatly by installation and
operation of water pollution control systems.

     On the inflow  side, capital  availability is affected  as investors perceive the
potential worth  of a company.  Money market conditions being otherwise con-
stant, the amount  and trend of earnings will affect the price the  investor is willing
to pay for the company's securities, the price/earnings ratio, or  bond  rating. This
in turn, affects availability of capital.
                                    67

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                                                                    TABLE VIII-1
                                       POLLUTION CONTROL INVESTMENT AND OPERATING COSTS IN RELATION TO
                                                  CURRENT FIXED INVESTMENT AND ANNUAL SALES
Os
oo
            BPT           - investment = $26,000
            Incremental BAT - investment = $ 6,500
            NSPS          — investment * $32,500
BPT Annual operating costs        =$7,100
NSPS or BAT Annual operating costs = $15,400
       Depreciation
         (SOOO's)
       BPT Investment
         (as % of Depreciation)
       Incremental BAT Investment
         (as % of Depreciation)
       NSPS Investment
         (as % of Depreciation)

       Sales Revenue
         ($000's)
       BPT Annual Operating Costs
         (as % of Sales)
       NSPS or BAT Annual Operatii j
         Costs (as % of Sales)
2711 2721 2741 2751 2754
Miscellaneous Commercial Printing Commercial Printing
Newspapers Periodicals Publishing Letterpress Gravure
Medium Large Directory Catalog
Circulation Circulation Printing Printing Printing Rollmaking
Plant Plant Plant Plant Plant Plant
178 565 881 881 557 310 564 65
14.60 4.60 2.95 2.95 4.66 8.38 4.60 40.00
3.65 1.15 0.74 0.74 1.17 2.10 1.15 10.00
18.25 5.75 3.69 3.69 5.83 10.48 5.76 50.00
6.601 23,453 30,000 30,000 15.470 10,530 10,600 1,000
0.10 0.03 0.02 0.02 0.04 0.06 0.06 0.71
0.23 0.06 0.05 0.05 0.09 0.14 0.14 1.54
2793
Photoengraving
74
35.13
8.78
43.91
3,775
0.40
0.40

-------
     Profitability can be measured by return on assets or return on investment.
For purposes of this study, the investment is defined as total net assets; therefore,
return on assets equals return on investment.

     In  analyzing return on assets we assume it is not possible  to pass on the
increase in expenses to the customer. The results, presented in Table VIII-2, Case
A, show a very small change in return on assets. The reduction in return on assets
amounts to only a fraction of a percent. A correlation can be found between the
size of the company and the amount of reduction in return on assets. The larger
the company,  the smaller the reduction in return on assets. Attention is called to
the rollmaking gravure  segment where the company size is  relatively small and a
decrease in return on assets of 0.5 to almost 1% is experienced. We conclude that
neither  profitability nor capital availability on the  inflow side will be affected by
installation of a water pollution control system.

B. PRICE AND  SECONDARY EFFECTS

     Should profitability  be affected adversely by an  investment in water pollu-
tion control  equipment,  as is true  to  some  extent  in  the  rollmaking  gravure
segment, a predictable remedy would be to raise  product prices to pass on the
additional expenses to  the customer. Decreased demand,  product substitution,
etc., could be secondary effects of a price increase.

     Case B in Table VIII-2 demonstrates the alternative analysis of assuming that
costs can be passed on to the customer. Case B demonstrates that only a 1% to 2%
increase in sales price  is necessary to maintain present return  on assets for the
rollmaking gravure segment. A 1% to 2% price increase for rolls is negligible to the
printer  who has seen a much higher price increase for paper in the recent past.
Case B  further  demonstrates  that in  other segments the necessary sales price
increase is negligible for  companies this size.  Because the price effect  is so
negligible in all segments, we conclude that there are no secondary effects.

     The variability of water pollution control effects  on prices between the
largest and smallest plants in a segment may be reflected in reduced profits for the
smaller  of the plants if the prices of rolls are highly competitive which we do not
believe. However, the analysis  indicates that the effect on profitability would not
result in a closure decision.

C. SENSITIVKTY ANALYSIS

     Basic to our analysis is the creation of a hypothetical  model plant for each
segment with  prototypal financial data.  Because  our decision  of no impact  is
based on an analysis of these hypothetical  plants, a sensitivity analysis must be
                                    69

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                                                                      TABLE VI11-2

                                                PROFITABILITY AND PRICE EFFECTS OF POLLUTION CONTROL
                                                                          CASE A

                   Assumption:   Additional expenses incurred due  to water pollution control equipment cannot be passed on to customer.
                   Before  Pollution Controls:  After tax return on net  assets  before pollution control system is installed.
                                ABPT:  Effect on ROA of BPT system.
                                ABAT:  Effect on ROA of BAT system.
                                       2711
                                          2721
                                                                                                                            2793
Newspapers Periodicals
RETURN ON ASSETS
Before Pollution
Controls
ABPT
ABAT
Medium
Circulation
Plant
14.80
(0.21)
(0.37)
Large
Circulation
Plant
10.28 8.08
(0.04) (0.03)
(0.08) (0.06)
MisceTTaneous Commercial Printing
Publishing Letterpress
Directory
Printing
Plant
8.08 3.49
(0.03) (0.05)
(0.06) (0.09)
Catalog
Printing
Plant
3.63
(0.07)
(0.12)
Commercial Printing
Gravure Photoengraving
Printing
Plant
4.44
(0.05)
(0.10)
Rollmaking
Plant
5.50
(0.49)
(0.92)
8.53
(0.27)
(0.49)
i
u
                                                                          CASE B

                   Assumption:   Additional  expenses can be passed on to the customer.                                                f
                                What revenue  or price increase is necessary to recover the additional expense and provide the same return
                                on assets with the expanded asset base?
                                    Newspapers
                                                   Miscellaneous    Commercial Printing  Commercial Printing
                                       Periodicals  Publishing         Letterpress      	Gravure	   Photoengraving
% INCREASE IN REVE*  i

BPT

BAT
Medium
•culatior
Plant
0.28
0.48
Large
i Circulation
Plant
0.06 0.03
0.12 0.06
Directory
Printing
Plant
0.03 0.05
0.06 0.10
Catalog
Printing
Plant
0.09
0.17
Printing
Plant
0.07
0.16
Rollmaking
Plant
1.01
1.94
0.29
0.54

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performed to determine how different  from the prototype a plant can be before
the cost of the water pollution control system has significant impact. Analysis was
conducted on  those three sectors which contained enough  plants to have  a
likelihood of widely varying financial performance:  newspapers, commercial gra-
vure printing, and photoengraving. Results are shown in Table V1II-3. The ability
of a company to afford the water pollution control system is a function in part of
its size. Revenue  and net  assets were used as appropriate measures of size. Table
VIII-3 shows the minimum-sized company able to afford this system.

     The assumption is made in Case A that return  on sales and return on assets
are identical to those of the model plant, but allows a 5% price increase to pass
along  cost  to the  customer.  Calculations demonstrate how much  larger than
"necessary" these model plants are.

     Case B looks at the  other end of the curve by assuming a sick company
earning only half the return  of the model plai.t. Furthermore,  it assumes the
pollution  control standards  will require  investment costs  equivalent to  the
50,000-gallon-per-day system.  The calculation is then  performed to answer the
question, "How large must the asset and revenue base be under these conditions if
the 5% price increase can  be  passed along to customers?" Case B demonstrates
that even  assuming a very  bad  "worst case," all of these model companies are two
to  ten times  larger than  the critical  threshold for companies that would be
impacted under these conditions.

     The sensitivity  analysis demonstrates that not only is the model company
within a sector unaffected by the standards,  but that no company in the sector
would be  impacted. Companies of the size suggested  in Table VIII-3 will probably
be  using  different (non-polluting)  printing technologies. None of the gravure
printers is small enough to fit the lower values calculated.

D.  PRICE EFFECTS

     The impact  analysis  indicates that the amount of investment required for
control of water pollution in the industry is such that no price increase would be
anticipated.  During the past year the overall increases in the cost of paper, plates,
labor, and equipment have overshadowed the  small effect of the cost of pollution
control on  the  cost of  the  preparation of  plates.  The average  cost of the
platemaking service is 2 to 5% of the cost of the printing. If the total burden of
the water  pollution  control investment had  to be borne by  the cost  center
represented  by the platemaking operation in the printing plant and if the com-
pany  were making a  minimum of 100 plates  a  clay (5000 plates per year), the
annual cost  would be SI5,000  or about S3 per plate.  Such an increase in the price
of plates would be very small in comp. rison with other price increases that have
been affecting this industry. Moreover, the increase will be distributed  over the
                                     71

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                                                      TABLE VIII-3

                                                  SENSITIVITY ANALYSIS
                                                         ($000's)

                                        2711                                     2754                            2793
                                      Newspapers
                              Medium             Large
                             Circulation          Circulation
 Sample Companies         '      Plant              Plant                  Commercial Printing Gravure                Photoengraving

 Revenue                      6,601             23,453                       10,600                           3,775

 Assets                       3,384             15,200                        9,540                           2,085


                                                        CASE A

   Assumption:  Maximum sales  price increase of 5%
   Derivation:  The  minimum revenue and asset base  to support the  incremental expenses of the  BPT  system (5,000  gpd),

                             	Newspapers	
                               Medium             Large

                                                                       Commercial Printing Gravure                Photoengraving
Revenue                        219                195                          165                             186

Assets                          112                127                          149                             103


                                                       CASE B

  Assumption:  Worst  possible case.  Returns on sales  and assets half  that of the  sample company.   Standards and
                expenses of BAT system  equivalent to those of 50,000-gpd plant, allowing a 5% sales  increase.
  Derivation:  Minimum revenue and asset  base to support the incremental expenses  of  the BPT system.

                                     Newspapers
                              Plant I             Plant II                   Commercial Printing Gravure               Photoengraving

Revenue                      1,970              2,081                         2,018                           2,062

Assets                       1-.009              1,348                         1,818                           1,140

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total number of impressions being printed, so the overall effect will be even more
miniscule. Thus, no significant price increases are expected as a direct result of the
cost of pollution control equipment except in those service industries where the
total amount of the cost of pollution control is directly attributable to the plate,
since this is the product that is being sold. It is expected, however, that this price
increase can be readily passed on to the printer.

E. PRODUCTION EFFECTS

    No production curtailments or plant shutdowns are anticipated as a result of
the water pollution control guidelines.

F. EMPLOYMENT  EFFECTS

    No adverse employment effects are anticipated  as a result of these  water
pollution control regulations on the printing industry.

G. COMMUNITY EFFECTS

    No community effects on  either plant  growth, industry growth, or side
effects are anticipated.

H. INDUSTRY GROWTH

    Capital availability and profitability will not be obstacles to industry growth.

I. INTERNATIONAL TRADE

    No international  trade effects are expected as a result of these costs because
no general price increases or production curtailments  are expected to result from
these guidelines.

J. COMPETITION WITHIN THE INDUSTRY

    For industry suppliers and consumers the competition between the different
types of printing outlined previously is expected to continue. In the past ten years
offset printing has been making inroads into letterpress "territory"  at higher and
higher levels of printing impressions per run or per job order. It is expected that
this trend will continue. In recent years there has been an increasing  use of plastic
plates to replace  metal plates  in the letterpress industry and it is expected that
this trend will continue.  Insofar as the need  for water pollution control equip-
ment  and associated  costs could  be  a factor, they would  promote  decisions
favoring either offset  printing or a change to  plastic plates in letterpress opera-
tions, but the incremental  effect of the  cost  of water pollution control on the
decision that has already been made by the industry is expected to be very small.

                                     73

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K. ECONOMIC IMPACT OF NSPS

    Neither the new source performance standards nor the new source pretreat-
ment standards will affect the growth of any segment of the printing industry. No
effect on prices is anticipated because of new source performance standards and
new plant locations probably will not be affected either. The trend in recent years
for the larger plants to build in more rural areas where they have access to land
and access to good transportation will continue independent of the requirements
for water pollution control. The decision to build domestic plants versus foreign
plants will not be influenced by the proposed guidelines. Our analysis shows the
balance  of payments will not affect location or dollar volume of printing. In all
cases pretreatment costs are less than BAT costs and since no impacts were found
for the BAT costs no separate analyses were conducted for pretreatment costs.
                                     74

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                                APPtNDIX

           DERIVATION OF SENSITIVITY ANALYSIS FORMULA

     The derivation  of  the  formulas used  for sensitivity analysis  begins with a
definition of return on sales and return on assets. A textbook definition of return
is the profit after taxes divided by revenues (Equation  1) or assets  (Equation  2).

     If assets are going  to increase and revenues will  be affected  or necessarily
incremented, we should  be able  to derive a new formula which will take this into
account.  Equation 4 does this. Note that the incremental revenue (I) is only for a
sales price increase. If it were an increase in volume, we would necessarily have to
compute contribution andXwould have to be multiplied by the return on sales.

     The annual operating  expense of this  system is subtracted  to reduce  the
profit appropriately. The left side  of the equation has an expanded asset base
against which the return on assets constant is multiplied  to  arrive  at  the new
profit level. Substituting return on assets  times assets or return  on sales times
revenue in Equation 4  produces a simplified equality - both sides are equal to
profit.  The incremental revenue is defined as 5% of previous revenue. Substituting
this definition for J_ we are able  to solve  for the revenue base, having been given
only the original investment cost and annual operating expense. We  can use  the
ratio of return on sales  and return  on assets defined in the initial  description of
the company to solve for the net asset base.
                    ROS-P/R                                         (1)

                   ROA =  P/A                                         (2)

             :. A • ROA =  R • ROS                                     (3)

          ROA • [A + C] =  ROS • R - E + I                             (4)

     ROA -A + ROA -O  ROA-A -E +  1                              (5)

                ROA -C=  I-E                                        (6)

                       1=  .05R                                        (7)

                    .'. R=  20CROA-C + E)

 P = Profit Before Tax               C = Investment Cost of WPC  System
 R = Sales Revenue (Before WPC)    E = Annual Operating Expense of
 A = Total Net Assets*                   WPC System
 ROA = Return on Assets            I = Sales Price Revenue Increase
 ROS = Return on Sales

 "Total Assets less depreciation on Fixed Assets, Amortization of lease holds and patents, and
  bad debt allowance of accounts receivables.

                                     75

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II < IIM< \l Kl I'OR'I
   l> \ I \ I'AU
1                           Report No
                            EPA-230/1-74-053
        Economic Analysis of Proposed Effluent Guidelines:
        Printing Industry
     ":""'s)  J.  J. Clancy,  J. W.  Rafferty,  L.  B. Wheeler
            and R. S.  Brenneman
    r 111 in-, uif OiiMiu/.tlioiv N.I me am!
           Arthur D. Little, Inc.
           Acorn Park
           Cambridge,  Massachusetts 02140
           ^ (>ri;jni/.itioii Name and Addiess
            Economic Analysis Division
            Environmental Protection Agency
            Washington,  D. C. 20460
3. Recipient's Accessionj No.
                                                                    5. Report Date
                                                                      August 1974
6.
8. Performing Organization Kept  No.
  C-75923
                                                                     10. Projcct/Task/Work Unit No.
                                                                      Task Order No.  23
11. Contract/Grant No.

  68-01-1541
13. Type of Report & Period Covered
   Final
14
           nl.iry Notes
  It  \hslr.nls
'           An analysis  of the  economic  impact on  all printing and plate-making seg-
  ments of the printing and publishing  industry (Standard Industrial  Classification
  Major Group 27) of  1977 and  1983 effluent guidelines.  No significant impact was
  found on profitability, capital availability, price, production,  employment,
  community,  international trade or competition.
  17. Ke\ Words and Document Analysis.  I7a. Descriptors   t

        Effluent Abatement
        Economic Impact Analysis--Printing
  17b.  Identifiers/Open-Knded Terms
  17,. COSAIl I iold/r.roup
IS  AvjiLilulity Statement
   Availability through U.S.  Environmental
   Protection Agency  Information Center;  Rm.
   W327, Waterside Mall, Washington, D.C. 20460
                                                        19. Security Class 
              USCOMM-IH'  I49SM'7.'

                      ''! '1

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