SEPTEMBER 1974
           ECONOMIC ANALYSIS
                    OF
      PROPOSED EFFLUENT GUIDELINES

  PAVING AND ROOFING MATERIALS
           (Tars and Asphalt)
                  QUANTITY
      U.S. ENVIRONMENTAL PROTECTION AGENCY
          Office of Planning and Evaluation
             Washington, D.C. 20460


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     This document is available in limited quantities through
Ruth Brown at the U.S. Environmental Protection Agency,
Information Center, Room W-327 Waterside Mall, Washington,
D.C. 20460

     The document will subsequently be available through the
National Technical Information Service, Springfield, Virginia
22151.

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          ECONOMIC ANALYSIS
                  OF
    PROPOSED EFFLUENT GUIDELINES
   PAVING AND ROOFING MATERIALS
           (Tars and Asphalt)
U.S. ENVIRONMENTAL PROTECTION AGENCY
      Office of Planning and Evaluation
         Washington, D.C. 20460
           EPA-230/1-74-055
            September 1974
                 U.S. Environmental Protection Agency,
                 Region V, L'brary
                 230 South  Dearborn  Street .x"'
                 Chicago, Illinois  60604  "         ,,-<-,

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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.

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                                    PREFACE

     The attached document is a contractor's 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  Contract
No. 68-01-1541, Task Order No. 28 by Arthur D. Little, Inc. Work  was completed as of
September 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  sections
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                                                   vii
List of Figures                          -                        ix

EXECUTIVE SUMMARY                                           1

    BACKGROUND AND OBJECTIVES                              1

    CONCLUSIONS                                              1

    PAVING MIXTURES AND BLOCKS (SIC 2951)                     2

        1.   Asphalt Concrete                                      2
        2.   Asphalt Emulsions                                     4

    ASPHALT FELTS AND COATINGS (SIC 2952)                     5

    ASPHALT BASED FLOORING PRODUCTS (SIC 3996)               7

METHODOLOGY                                                 9

PART I:  ASPHALT PAVING MIXTURES AND BLOCKS
        (SIC 2951)                                              11

    A.  INDUSTRY STRUCTURE                                 11

        1.   Products and Demand                                 11
        2.   Manufacturing and Ownership Profile                     21
        3.   Financial Profile                                     30
        4.   Prices and Price Setting                                34

    B.  PROPOSED EFFLUENT LIMITATIONS, TECHNOLOGIES
        AND COSTS                                            41

    C.  ECONOMIC  IMPACT ANALYSIS                           45

        1.   Price Effects                                        45
        2.   Financial Effects                                     48
        3.   Production Effects                                    49
        4.   Employment Effects                                  49
        5.   Community Effects                                   49
        6.   Balance of Trade Effects                               49

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                  TABLE OF CONTENTS (Continued)

                                                            Page

 PART II: ASPHALT FELTS AND COATINGS
        (SIC 2952)                                            51

     A.  INDUSTRY STRUCTURE                                51

        1.  Products and Demand                                51
        2.  Manufacturing and Ownership Profile                    56
        3.  Financial Profile                                    64
        4.  Prices and Price Setting                               66

     B.  PROPOSED EFFLUENT LIMITATIONS, TECHNOLOGIES
        AND COSTS                                           67

     C.  ECONOMIC IMPACT ANALYSIS                          68

        1.  Price Effects                                       68
        2.  Financial Effects                                    70
        3.  Production Effects                                  72
        4.  Employment Effects                                72
        5.  Community Effects                                 72
        6.  Balance of Trade Effects                             72

PART III: ASPHALT-FELT BASE FLOOR COVERINGS
        (SIC 3996)                                            73

     A.  INDUSTRY STRUCTURE                                73

        1.  Products and Demand                                73
        2.  Manufacturing Profile                                75
        3.  Prices and Price Setting                               77

     B.  PROPOSED EFFLUENT LIMITATIONS, TECH-
        NOLOGIES AND COSTS                                77

     C.  ECONOMIC IMPACT ANALYSIS                          78

 LIMITS OF THE ANALYSES                                     79
                                VI

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                            LIST OF TABLES

Table No.                                                            Page

  1-1          Shipments of Petroleum Asphalt for Paving by Product        12
  I-2         Sales of Petroleum-Asphalt Paving Products for Con-
              sumption in the United States by P.A.D. Districts and
              States                                                   13
  I-3         Shipments of Asphalt Concrete                             14
  I-4         Asphalt Paving Materials — Value of Shipments               15
  I-5         Value of Shipments of Asphalt Paving Mixtures and
              Emulsions (SIC 2951)                                     16
  I-6         Estimated Cost of Construction Materials and Supplies
              Used for Interstate and Federally-Aided Primary
              Highways, and All Public Highways for Selected Years        17
  I-7         Distribution of 1972 Production                            20
  I-8         Integration of Company Operations                         22
  I-9         End Uses of Emulsified Asphalts                            22
  1-10        Number of Hot Mix Asphalt Plants by Size of Mixer          23
  1-11         Existing Asphalt Hot Mix Plants in the United States
              by Region (January 1974)                                 24
  1-12        General Statistics by Geographic Area (1967)                26
  1-13        SIC 2951 General Statistics, by Employment Size
              of Establishment (1967)                                   27
  1-14        Concentration Ratios:  Percent of Total Business
              (SIC 2951)                                               28
  1-15        Hot-Mix Asphalt Production of Reporting Companies
              Grouped by Volume of Production                         29
  1-16        SIC 2951 Selected Statistics for Operating Manufacturing
              Establishments, by Type of Operation and Legal Form
              of Organization for Major Industry Groups and Industries      31
  1-17        Selected Statistics SIC 2951 (1963-1971)                    32
  1-18        Selected Operating Ratios SIC 2951 (1963-1971)             33
  1-19        Financial Profile - SIC 2951                               34
  I-20        Average Operating Statement for Asphalt Hot Mix
              Plants (1972)                                             36
  1-21         Average Operating Statement for Asphalt Emulsion
              Plants (1972)                                             37
  I-22        Average Bid Price Trends on Federal Aid Highway
              Contracts                                                37
  I-23        Asphalt Concrete Prices                                   39
  I-24        Materials Consumed by the Asphalt Paving Industry (1967)    39
  I-25        Relative Average Prices (Asphalt Concrete)                  40
  I-26        Relative Average Prices (Emulsions)                         41
                                   Vll

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                      LIST OF TABLES (Continued)

Table No.                                                             Page

  1-27        Effluent Limitations for Asphalt Emulsion Plants             42
  1-28        Effluent Limitations for Asphalt Concrete Plants             42
  1-29        Treatment Costs for Asphalt Emulsion Plants                44
  1-30        Treatment Costs for Asphalt Concrete Plants                44
  11-1         Total Shipments of Asphalt Felts & Coatings:
              1963-1972                                               53
  II-2        Shipments of Asphalt Felts and Coatings by Product
              Type, 1967-1972                                         54
  II-3        Shipments of Asphalt and Tar Roofing and Siding
              Products, 1972                                           54
  II-4        SIC 2952-Industry Operating Profile                      57
  II-5        General Statistics, by Geographic Areas:  1967               60
  II-6        General Statistics, by Geographic Areas:  1972               61
  II  7        Materials Consumed in the Manufacture of Asphalt
              Felts and Coatings, 1967                                  62
  II-8        Materials Consumed in the Manufacture of Asphalt
              Felts and Coatings, 1972                                  62
  11-9        Selected Statistics for Operating Manufacturing
              Establishments, by Type of Operation and Legal Form
              of Organization for Major Industry Groups and Industries:
              1967                                                    63
  11-10       Income Statement-Typical Plant, 1973                   65
  11-11       Wholesale Price Index for Prepared Asphalt Roofing          66
  II-12       Effluent Limitations for Asphalt Roofing Plants             67
  11-13       Treatment Costs - Asphalt Roofing Plants (Small)           69
  11-14       Treatment Costs - Asphalt Roofing Plants (Typical)          70
  11-15       Treatment Costs — Asphalt Roofing Plants (Large)           71
  111-1        Value of Shipments of Hard Surface Floor Coverings         74
  III-2       SIC 3996-Industry Operating Profile                      76
  III-3       Effluent Limitations for Linoleum and Asphalt
              Printed Felt Plants                                        77
  III-4       Treatment Costs - Linoleum and Asphalt Felt Plants         78
                                   via

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                          LIST OF FIGURES

Figure No.                                                            Page

  1-1          Estimated Cost of Construction Materials and Supplies
              Used for Interstate and Federally-Aided Primary Highways,
              and All Public Highways for Selected Years                  18

  1-2          Selected Statistics SIC 2951 (1963-1971)                   35

  11-1         SIC 2952 - Industry Operating Profile                      58
                                    IX

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                              EXECUTIVE SUMMARY

BACKGROUND AND OBJECTIVES

     The purpose of this report is to present an analysis of the potential economic impact
on the asphalt roofing and paving industries of pollution abatement requirements under the
Federal Water Pollution Control Amendments of 1972 for each of three levels of effluent
treatment:

     •   Proposed best practicable control technology currently available (BPT).
     •   Proposed best available technology economically achievable (BAT).
     •   Proposed new source performance standards (NSPS).

     The segments  of  the asphalt  paving  and roofing  materials  industries are contained
within:
         SIC 2951  — paving mixtures and blocks
         SIC 2952 - asphalt felts and coatings
         SIC 3996 — asphalt-felt-base floor coverings
     Mobile  and  stationary  asphalt  paving plants operated  by  highway  contractors
(SIC 1611) are also discussed with SIC 2951.

     The report is presented in two principal parts for each SIC category. The first part is a
characterization of the industrial category based on the U.S. Bureau of the Census statistics,
on trade association and other industry data, and on other primary and secondary sources
investigated by the contractor. The second  part analyzes the probable economic impact on
the industries arising from the promulgation of the effluent treatment Guidelines.1

CONCLUSIONS

     The proposed effluent Guidelines will not have a significant impact on the  economic
performance of the asphalt paving, roofing and flooring industries.

     Of the 4750 plants operating in  the asphalt concrete sector of the paving industry,
approximately  500  (10.5%) must meet Guidelines. Of these latter, 10-15 plants will
probably choose  to  close  as a direct result of the Guidelines. The remainder of the 500
plants will  pass on the incremental costs of pollution control, representing a maximum price
1.   As detailed in Development Document for Proposed Effluent Limitations Guidelines and New Source
    Performance Standards for Paving & Roofing Materials (Tars and Asphalt). The report was prepared by
    the National Field Investigations Center — Cincinnati, U.S. Environmental Protection Agency, August,
    1974.

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increase of about 1%. Closure of the 10-15  plants will affect about 50 employees in urban
areas where alternative employment opportunities exist.

     Full cost pass through, with no other economic impact, is anticipated in the asphalt
emulsion sector of the paving industry and in the asphalt roofing industry. Price increases to
meet BAT requirements will be a maximum of  1.2^ per ton on a 1973 average selling price
of $63.45 per ton for asphalt emulsions, and 46$ per ton (0.58%) for asphalt roofing.

     Baseline closures are anticipated in  the asphalt-based flooring products sector so the
industry will probably not be in existence  by 1977.

     More specific conclusions are summarized in the following paragraphs.

PAVING MIXTURES AND BLOCKS (SIC 2951)

     Approximately  4,800  plants  in  the  United States  produce  asphalt-based  paving
mixtures. The great  majority of these  plants (4,750) produce asphalt concrete, while the
remainder produce asphalt emulsions.

1. Asphalt Concrete

     Industry Characterization

     The asphalt concrete segment has  grown steadily over the past few decades, reflecting
largely the increased levels of federal, state, and local funding for the expansion of roadways
in the United States.  In 1973, this segment of  the industry reached  a record  level of
production of 358 million short tons, but a  16% decline is anticipated in 1974. It is unlikely
that the 1973 level of production will be equalled before  1980, primarily because of a
decline in new road construction as the Federal Interstate and Defense highway system is
completed  and as Trust Fund monies are diverted to other forms of transit. Although
maintenance expenditures will allow modest growth at 2% per year from 1974 to 1980, it is
likely that  up to  500 marginal asphalt paving plants will be forced to close over this period
as the industry continues its trend toward greater concentration.

     Plants in this segment of the industry may  range in capacity from 50 to 500 short tons
per hour. The average sized existing plant  has  a capacity of approximately  150 tons per
hour, while the  average  new plant  is closer to 300  tons per hour. Asphalt plants operate
intermittently, producing only for specific demand.
     The substantial costs (13tf/ ton/mile) of shipping asphalt from the plant to the job site
 mitigate against interregional or international  shipments of the product. There is some
 regional differentiation in regard to the length of the production year. (Plants in the South

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are able to operate year round, while northern plants are forced  to  close in the winter
months.) U.S. production averages 35-40% of rated capacity.

     Of the 4,750 plants in the asphalt concrete segment, 25%, or 1,200, are estimated to be
"mobile" plants, which serve temporary market areas, and are moved to  other sites upon the
completion of specific projects. While the remainder, or "fixed" plants may be dismantled
and moved, it is a costly process; so such moves are undertaken only when the market area
that the plant was set up to serve has deteriorated significantly.

     The pattern of ownership of plants in this industry ranges from one-plant, privately-
owned operations, to firms which own in excess of 100 plants throughout the country, and
operate as  subsidiaries of major corporations, often in the oil industry. Over the past decade
these larger firms have increased their market share, often by acquiring  the assets of smaller
companies. Despite  this trend,  however, the  industry is characterized by a low  level of
concentration.

     The median profitability of asphalt concrete plants is 4% on sales,  and  10% on owners'
equity, slightly below the national average of  10.6% for all manufacturing concerns. Plants
in the industry range from marginally profitable installations, to some which have returns on
owners' equity approaching 25%. Recently margins have been  adversely affected by  the
rapid  increases in  the cost of asphalt cement, which comprises a major proportion of the
cost of asphalt concrete. Asphalt concrete is sold largely on a bid basis for specific projects.
Because the  larger of these  projects may  run longer than a  year, increases  in  cost of
production over the period of the contract may not be recovered.

     Competition  within the  industry and between  the  industry and  Portland  cement
concrete may be  severe but is generally  mitigated by economic factors. Over the years,
asphalt  concrete has maintained  a  first-cost advantage vis-a-vis Portland  cement concrete,
although average  annual costs  of maintenance and  resurfacing  are  higher. Within  the
industry the high costs of shipping  the product tend to limit encroachments of market area
by competing plants.

     Effluent Limitations, Technologies and Costs

     For the asphalt concrete  sector  BPT  and BAT  requirements are  considered to be
equivalent; both are due to be achieved by 1977. Each calls for the installation of an earthen
settling  basin for  effluents resulting from wet process particulate control process equip-
ment, and for the  recycling of the  water which  has  been settled.  The costs  for  the
installation of  this technology range from  $4,600 for  a  small plant (1,000-ton-per-day
capacity) to $6,400 for  a large plant (2,500-ton-per-day capacity).  Annual costs, including
operating expenses, energy, and amortization  of capital,  range from 11.3^  per ton for the
small plants to  8.1(^ per ton for the larger plants. This  compares to  an  average 1973 selling
price for the product of  $8.00 per ton.

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     Economic Impact

     The proposed  effluent Guidelines will not have a significant economic impact on the
industry. Of the 4,750 asphalt concrete plants, approximately 1,200 are equipped with dry
process particulate control equipment and are therefore not subject to the Guidelines; of the
remaining plants, about 3,100 are already in compliance. The approximately 500 plants that
must meet the Guidelines  (10.5%) are located primarily in rural  areas, without significant
inter-,  or intra-industry competition. The effects of high transportation costs historically
have enabled asphalt  concrete plants to increase prices without prejudice  to their market
position. Most will,  therefore, pass on the incremental costs of pollution control, represent-
ing a maximum price increase of  1%.

     Baseline closures are anticipated in about 500 cases before 1980 and it is possible that
a very small  proportion  (estimated at  10-15) of these 500 plants affected will choose to
close by 1977 as a direct result  of the  Guidelines. It is estimated that  50 employees will be
affected  by  their closure.  Because  these plants will be located in urban  areas where
alternative  employment opportunities exist, community effects will be  negligible. Because
the industry operates currently at 35-40% of capacity, these closures  will have no measur-
able  effect  on production levels. As a result of high transportation costs, international trade
in asphalt  concrete does not exist,  and therefore, there  will  be  no balance of payments
effects.

2. Asphalt Emulsions

     Industry Characterization

     The level of production of  asphalt emulsions for paving purposes has remained steady
over the last decade.  While some emulsions  are used  for roofing and for industrial uses,
paving is by far the predominant  use.

     Although production in 1974 is expected to drop 15-20% from the levels achieved in
1973, the outlook for this  segment is favorable through 1980. A 4%/yr rate of growth from
1974 to 1980 is anticipated, primarily because of the  attractiveness of emulsions as a
substitute for asphalt cutbacks, which are expected to  be phased  out  for reasons of energy
conservation, and the growing need for emulsions as a road base stabilizing ingredient.

     Emulsion plants are distributed nationally, but a large proportion are located in the
Midwest, where the  quality  of the naturally occurring aggregates for road base often requires
the use of  emulsions as a stabilizing  agent, and where the markets for the industrial uses of
the product are most concentrated.

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     Emulsion  plants are believed  to  be slightly  more profitable  than  concrete  plants,
although little published data exists to  support this conclusion. They are a complementary,
rather  than a competing  product to asphalt  concrete, and, as a result, 15-20%  of the
companies in the asphalt concrete business also distribute or produce emulsions.

     Effluent Limitations, Technologies and Costs

     BPT requirements for the emulsions sector consist of dikes to control the runoff of
process wastes which have settled around the plant site, and the removal of oil and grease
through a separator.  BAT calls for the construction of a sedimentation basin to supplement
this system. The costs for the installation of such a system for an average sized plant (6,000
short tons per day) is $73,290 for BPT and $80,790 for BAT. The annual operating costs
are 1.1^ per ton for BPT and 1.2$ per ton for BAT. This compares to an average 1973 selling
price of $63.45 per ton.

     Economic Impact

     Given  the proportion these incremental costs bear to the average selling price of asphalt
emulsions it is concluded that the costs can easily be passed on by the  industry. No major
difficulty is expected in raising the capital for these processes. The  economic impact will,
therefore, be negligible.

ASPHALT FELTS AND COATINGS (SIC 2952}

     Industry Characterization

     SIC 2952 includes a variety of products, all employing asphalt as one ingredient, used
to waterproof the exterior of a building structure: asphalt saturated felts, roofing asphalts
and pitches, strip shingles, and many others. The saturated felt products can be classified as
either prepared roofings or built-up roofings. Both types are basically  similar, each being
made of a  structural felt  or fabric framework, a soft asphalt saturant for the felt, and a
relatively hard coating on the surface of the felt.

     Shipments of asphalt felts and coatings have shown steady and almost uninterrupted
growth  over the past decade, increasing from  $459.5 million in 1963 to $877.1 million in
1972, an annual rate  of better than 7%. The principal products shipped each year are  asphalt
and tar roofings and sidings, which represent 75% of all group shipments.  These products are
used throughout the United States in relation to the volume of new building construction
and of existing stock. Imports and exports have been and remain at a  very low  level.

     Roofing plants  are  located close  to or in heavily populated  areas and thus manu-
facturers' warehouses remote  from  the  plants are seldom  used  for distribution.  Manu-
facturers tend to specialize in prepared or in  built-up roofing  and brand identification is

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prevalent in the former. Roofing has a relatively low value per unit weight; thus freight can
make shipment uneconomic in competition with other plant locations.

     It is estimated that  30% of all  roofing products in this industry sector is used for
non-residential  building construction, with  the  remainder used  for  residential roofing.
Reroofing of residential structures is an extremely important segment of the market, ranging
from  approximately  50% of all residential  roofing in a  good year for new residential
construction, to 75%  in an off-year. Reroofing also represents about 65% of all roofing sales
to the non-residential building sector. The overall growth of the  roofing industry will be
close to 4%/year on a  weighted basis to 1980.  As the industry is now operating at or close to
the maximum effective capacity, new plants or expansions of  existing ones are a necessity.

     The industry  is comprised of approximately 233 manufacturing establishments, about
108 of which produce dry and saturated roofing felts whereas the remainder concentrate on
asphalts, coatings and cements. Roofing plants in this industry range in size from 25,000 to
200,000 short tons per year, with the average at about 80,000 tons per year.

     Manufacturing plants in  this industry also vary significantly  by net asset value. The
oldest operating facility (built 80 years ago) has a  net asset value considerably less than $1
million; newer facilities have assets as high as $6 million and the average book value for all
108 plants is about $2.2 million.  A typical plant, with a daily capacity of 500 tons and net
assets of about $2.5  million, will produce an average of 120,000 tons  of roofing products
each year.  Such a plant will average  a return of 5% or better on sales and 15-20% on net
assets invested.

     Of the 226 establishments operating in 1967, 153 were multi-unit companies and 192
were  public corporations.  The  industry has traditionally  been characterized  as one of
family-owned  companies with regional concentrations,  but a considerable number of acqui-
sitions and  mergers over the  past decade has consolidated U.S. production. Despite these
changes in  industry  structure, the concentration ratios have  varied little  over the past
decade.  Currently, the  four largest companies  share  approximately  38%  of industry
shipments and the eight largest, 65%.

     Manufacturers publish regional  dealer price  lists; basic list prices  have been revised
frequently over the past year as manufacturers have attempted to maintain margins in the
face of considerable  price increases for basic raw materials, especially  asphalt. As a result,
average prices could increase as much as 15% during 1974.

     Effluent Limitations, Technologies and Costs

     The Development Document has proposed effluent limitations for a  typical plant using
 150,000 gallons of process water per day and producing 500 short tons of product per day.
Investment and operating, maintenance and energy costs have been estimated  for this level
of production and also for smaller and larger facilities producing 200 short tons and 700

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short tons per day, respectively. The majority of asphalt roofing plants are already removing
part  of the suspended solids from their waste water before discharging it; the proposed best
practicable control  technology currently available (BPT) requires that all plants employ
primary settling for this purpose. The proposed best available technology economically
achievable (BAT) further requires that coagulants be used  to settle  out  more suspended
solids. While it is assumed that either an earthen stilling basin or a  steel or concrete settling
tank will be used to achieve BPT, the settling tank  is the  more  likely solution  for BAT
requirements to allow for continuous sludge removal.

     Investment costs for BPT will range from $3,500 to $30,000 depending on the size of
plant and treatment technology used. For BAT they  will range from  $37,000 to  $67,500.
Incremental costs per short ton will range from 24 to 10
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     The market for asphalt-based flooring products derives from a very limited demand for
an extremely low  cost product that has a relatively short life expectancy. This demand is
expected to become non-existent within about three years as consumer preference for vinyl
and vinyl asbestos flooring increases. Lower costs resulting from economies of scale and
technical innovations for  competing products will help to eliminate  demand for  asphalt-
based floorings. Furthermore, the price  of refined asphalt feedstock has increased consider-
ably recently and the feedstock is in short  supply, thus increasing the relative cost of asphalt
flooring. Consequently, asphalt's single market advantage, low cost, is rapidly disappearing
and with it the only justification for continued significant production of the product. Thus
baseline closures are anticipated  so the industry  will probably not be in existence by 1977.

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                                   METHODOLOGY

     The  methodology  used to  determine the economic  impact of effluent  treatment
guidelines1  on operating plants in each sector included a comparison of the estimated
capital  and total yearly costs  of controls with  the estimated profitability  and average
product prices for typically sized plants in each  sector. Short tons is the unit of weight
employed throughout this analysis because  this reflects the economic measure used by the
industries under consideration.

     For the purposes of this analysis, the annuity method of calculating total yearly costs
has been  used. Operating, maintenance, energy and capital costs were amortized at a 15%
discount rate over  10 years. While this approach differs from that used in the Development
Document it  more accurately  reflects typical corporate policies and,  at  the  same time,
results in similar total yearly costs to those in the Development Document.

     Potential price effects were measured by assessing the  average price increases that
would be required  to  absorb  fully the incremental annual operating costs for pollution
controls, assuming  that the  same level of profits by operating units were maintained. In the
case of asphalt  roofing and asphalt concrete plants, three sizes of operating units  were
assumed for each sector in order to assess the potential economies of scale that might result.
Price  increases might range from full pass-through.of incremental costs to full absorption,
depending on the specific technology already in effect, the market and competitive environ-
ment  and the current levels of  profitability for individual facilities. Judgment was used in
estimating the number  of facilities  that would be able  to pass costs on fully, or have to
absorb them partially or completely.

    Depending  on the degree to which costs pass-through can be achieved,  further eco-
nomic effects can result on operating units in each  sector. The primary economic effect
could be  a  reduction  in, or elimination of operating profitability if prices could not be
increased. The analysis examines this effect for the full spectrum of price increases and also
assesses the availability of capital required to implement the control technologies. Finally, in
the cases where cost absorption results in a severely reduced level of operating profitability,
the possibility of  plant  shutdowns, resulting production, employment, community and
balance of trade effects  is examined judgmentally to obtain  an appreciation of the  full
economic  impact that could  result from implementing the  effluent guidelines.
1.   As deta iled in Development Document for Proposed Effluent Limitations Guidelines and New Source
    Performance Standards for Paving & Roofing Materials (Tars and Asphalt). The report was prepared by
    the National Field Investigations Center - Cincinnati, U.S. Environmental Protection Agency August
    1974.

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PART I: ASPHALT PAVING MIXTURES AND BLOCKS
                (SIC 2951)

-------
                PART I: ASPHALT PAVING MIXTURES AND BLOCKS
                                     (SIC 2951)

A.  INDUSTRY STRUCTURE

1. Products and Demand

     a.  Products

     The  asphalt paving industry in the United States has developed from the need to
construct  and maintain durable roadways for the use of automotive traffic. Dependent in its
early life  on the limited supply of naturally occurring asphalt  deposits, the industry grew
dramatically  with the discovery of petroleum derivative asphalt. In recent years, growth has
continued at a steady rate, reflecting the continued federal and state sponsorship of major
highway construction.

     The asphalt paving industry is included both in Standard Industrial Classification (SIC)
2951, Paving Mixtures and  Blocks, and in SIC  1611, Highway  Construction. Those plants
included in the former classification derive the major portion of their revenues from the sale
of paving mixtures to third parties. Those in the latter classification derive the major portion
of their revenues from the application of their asphalt products by their own construction
crews.  Our  analysis of this SIC relates only to the mobile and  stationary  asphalt plants
operated by  highway contractors. SIC 2951  also includes such products as  asphalt paving
blocks,  creosoted  wood paving  blocks,  composition paving  blocks, mastic  floor com-
positions,  and coal tar paving materials. These products are relatively insignificant in sales
and declining in use. Effluent guidelines were not defined for these miscellaneous categories,
so this analysis will not consider them in any further detail.

     The two main products within the asphalt  paving industry are asphalt  emulsions and
asphalt  concrete. Emulsions are a combination of asphalt cement  and water  whose natural
immiscibility has been mitigated by an emulsifying agent. Their primary use in paving is in
the repair and maintenance of existing roadways. Asphalt emulsions are  also used in very
small amounts in the roofing sector. Asphalt concrete* is a heated and compacted mixture of
asphalt  cement and well-graded aggregates. Its primary uses are the construction of roads
and highways, airport runways, driveways, and parking lots. It  has a variety of other uses
including tennis  courts, swimming pools, playgrounds, feedlots, and industrial floors. Cut-
backs, asphalt cement liquefied by the addition of higher distillates, are also used for paving
but  they  are produced  primarily  at  petroleum refineries, and  not by asphalt  paving
producers,  although they may  be  marketed and distributed by the latter. Since these
industries  are not  involved  in  the manufacturing processes,  these  products  have been
eliminated from consideration in this analysis.
"often referred to as "hot-mix" asphalt
                                         11

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     b.  Manufacturing Processes

     The manufacturing processes are discussed in  detail  in the Development Document.
Approximately 8% of the plants that produce asphalt concrete utilize continuous mixing
processes rather than  the batch process described in the document. There are no significant
process differences among emulsion plants.

     c. Production and Shipments

     Production figures for  the asphalt paving industry may be most closely derived from
data compiled by the  Department  of  the Interior,  Bureau of Mines,  on shipments  of
petroleum  asphalt to the asphalt paving industry. Shipments have increased from  16.9
million short tons in 1963 to 24.1 million short tons in 1972. This increase has been steady,
with a slight drop shown only in one year (1967).  Shipments in 1972 were at an all  time
peak. Table 1-1  lists  these shipments in total from  1963, and by product  from 1968.
Shipments  of cement, used for the production of asphalt concrete, have increased at a more
substantial  rate,  while  shipments of emulsions and  cutbacks have remained relatively
constant over the last six years. Table 1-2 lists the regional breakdown of these shipments for
1971 and 1972.
                                      TABLE 1-1

              SHIPMENTS OF PETROLEUM ASPHALT FOR PAVING BY PRODUCT
                                 (Millions of Short Tons)

               Year    Asphalt Cement    Emulsions    Cutbacks     Total*

               1963         N/A           N/A        N/A        16.9
               1964         N/A           N/A        N/A        17.4
               1965         N/A           N/A        N/A        18.3
               1966         N/A           N/A        N/A        19.6
               1967         12.7           N/A        N/A        18.9
               1968         14.2           2.2        4.3        20.7
               1969         15.2           2.1        4.1        21.3
               1970         17.2           2.3        4.1        23.6
               1971         17.6           2.3        3.9        23.8
               1972         18.1           2.2        3.9        24.1

               *Totals may not add due to rounding.
               N/A - Not Available

               Source: Mineral Industry Surveys, U.S. Dept. of the Interior, Bureau
                      of Mines  1963-1972.
                                          12

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                                      TABLE 1-2

       SALES OF PETROLEUM-ASPHALT PAVING PRODUCTS FOR CONSUMPTION IN THE
                     UNITED STATES BY P.A.D. DISTRICTS AND STATES
District and State
District 1:




Maryland & District of Columbia ....


New York 	





Virginia . , . 	
West Virginia 	
District I, total 	
District II:







Nebraska 	






District II, total 	
District III:




Texas 	
District III, total 	
District IV:
Idaho 	

U tab 	
Wyoming 	
District IV, total 	
District V:
Alaska

California 	
Hawa i i 	



District V, total 	


Asphalt cements
1972
222,878
27,763
62 U, 760
1*89,81*8
95,91*5
31*1*. 363
21*5,826
75,620
51*9,997
69!* ,121
501,682
71*3,879
129,896
229,527
12,166
338,112
72,826
5,399,209
687,356
590,571
1*27,607
239,511*
39!*, 931*
578,923
586,31*3
1*22,150
121,1*27
98,996
710,273
1*86,710
133,937
1*61,273
1*59,830
6,399,841*
290,570
192,212
178,172
1*71,718
129,1*26
1,285,221
2,51*7,319
331,735
123,501
181*. 728
235,076
121*. 1*1*7
999,1*87
1*2,675
1*99,1*1*7
1,268,671*
1*8,732
110,623
366,160
379,137
2J15j'*'*8
18,061,307
19711
18U.676
51,065
61*1*, 207
1*22,765
86,535
321*, 829
307,61*2
58,31*6
1*72,1*51
699,369
1*75,581*
701,868
181*, 872
220,163
37,280
329,068
72, 271*
5,272,991*
830,389
722,1*35
1*39,121*
21*9,606
1*28,1*68
1*87,81*1
1*71*. 062
1*02 , 799
155,275
85,31*8
71*6,011
537,127
128,813
1*06,988
1*89,1*20
6,583,706
283,361
170, 8oq
155,595
1*08,1*75
100,11*9
1,325,1*1*7
2, 1*1*3, 836
356,322
83,277
160,862
169,150
125,605
895,216
1*1,205
1*06,596
1,266,826
1*2,251
73,838
292,073
293,625
2,1*16,1*11*
17,612,166
Cutback Asphalts
1972
16,598
1,758
58,892
70,ll*7
31,121
5U, 785
21,008
31,1*21*
76,909
133,621
50,576
205,823
87
17,831
615
77,551
J31j30l*
880,050
295,651
132,913
72,986
128,253
51,512
59,507
178,681
393,020
21,527
1*6,623
322,025
181*, 81*1
1*5,297
23,518
105,807
2,062,161
51*, 367
71,739
12,901
8,1*19
33,765
208,712
389,903
17,881
1*2,302
55,093
3U, 01*6
23,958
173,280
7,081*
68,860
131,290
3,327
23,561*
1*0,653
79,922
351*, 700
3,860,09!*
19711
17,1*03
2,871
6U.721
59,51*8
30,760
56,1*35
22,1*60
30,71*8
77,339
128,805
51,386
207,700
568
18,856
6,868
87,502
28,356
892,326
339,31*1*
155,601
86,280
160,206
50,396
1*9,155
159,792
1*53,866
22,876
59,1*01
220,230
203,993
1*2,596
30,369
111*, 571
2,11*8,676
31,006
67,123
17,173
7,863
33,117
221,031*
377,316
27,1*79
1*1,081*
61,391*
29,779
30,333
190,07!*
l*,008
55,1*33
133,598
2,7l*2
20,637
1*6,532
62,301
325,251
3,933,61*3
Emulsified Asphalts
1972
U.232
2,125
31,869
52,930
8,293
78,327
3,186
5,230
37,11*1*
160,766
97,192
56,292
303
73,108
1,075
81*, 199
52,591*
71*8,865
1*7,772
175,779
29,099
3!*, 908
75,538
26,103
19,199
9,815
7,063
13,971
175,"*36
ll*,088
3,209
111*, 538
«,062
779, 5BO
79,100
33,325
38,227
31,617
10,532
90,981
283,782
3,1*38
12,879
7,773
18,000
3,122
1*5,212
1*, 1*1*9
81* ,516
122,130
318
"*,871
77,1*83
27,583
321,350
2,178,789
19711
2,335
3,019
27,977
1*9,579
16,737
75,312
1,751*
9,191*
1*3,938
171,081
97,290
69,298
361*
65,162
536
86,921*
Vt.558
765,058
60,795
228,1*27
22,057
32,315
63,510
20,871
20,702
8,376
7,51*8
1*0,609
178,073
22 , 169
1,1*51
11*3,513
1*9,226
899,61*2
63,032
1*2,610
31,760
27,718
12,199
89,272
271,591
3,9i+i*
9,621
3,659
16,022
5,152
1*3 , 390
5,063
68,161
126,998
51*5
l*,9Ul
6U, 188
25,522
225j.li 18
2,275,107
Total
1972
21*3,708
31,6U6
715,521
612,925
135,359
1*77,1*75
270,020
112,271*
66U, 050
988 , 508
61*9,1*50
1,005,99!*
no, 286
3EO.U66
13,856
1*99,862
156,721*
7,028,121*
1,030,779
899,263
529,692
1*02,675
52 1,981*
661*, 533
78"+, 223
821*, 985
150,017
159,590
1,207,73!*
685,639
182,1*1*3
599,329
598,699
9,21*1,585
1,21*, 037
297,276
229,300
511,751*
173,723
1,581*, 911*
3,221,001*
353,051*
178,682
21*7,591*
287,122
151,527
1,217,979
51*, 208
652,823
1,522,091*
52,377
139,058
1*81*, 296
1*86,61*2
3,391,1*98
2U,100,190
19711
20U, 1*11*
56,955
736,905
531,892
131*, 032
1*56,576
331,856
98,233
593,728
399,255
62 1*, 260
973,366
135,801,
301*. 181
1.1*, 681*
503,1.91.
11*5,183
6,930,373
1,230,523
1,106,1*63
51*7,1*61
1*1*2,127
51,2,37!*
557,367
651*, 556
865,01,1
185,699
135,353
1,11.1*, 311*
763,259
172,360
580,370
653,217
9,632,021
382 , 39-3
280,51*2
20U.523
1*1*1*, 056
11*5,1*65
1,635,753
3,092,71*3
387,71.5
133, 9»2
230,915
211*, 951
161,095
1,123,688
50,276
530,190
1,527,1*22
1*5,538
99,1.16
1*02,793
'Sl.UltS
i 3,037,033
23,320,916
Source:  Mineral Industry Surveys, U.S. Dept. of the Interior, Bureau of Mines.
                                              13

-------
     The  total production  of  asphalt  concrete  may  be estimated by multiplying the
shipments of asphalt cement by 18. (Asphalt cement constitutes approximately 1/18 of the
weight of asphalt concrete.) Table 1-3 lists this derived production from 1967. Emulsions
and cutbacks used for paving purposes are not further processed within the asphalt concrete
segment and the figures in Table 1-1 accurately reflect their total production.

                                      TABLE 1-3

                          SHIPMENTS OF ASPHALT CONCRETE
                                 (Millions of Short Tons)

                                 Year    Production
1967
1968
1969
1970
1971
1972
228.6
255.6
273.6
309.6
316.8
325.8
                           Source: Contractor Estimates, based on
                                  18 tons of asphalt concrete pro-
                                  duced per ton of asphalt cement
                                  used for this purpose.

     The value of shipments has  risen  at  a somewhat greater  rate than the volume of
production, from $1,350 million in 1968 to $2,038 million in 1972. Table 1-4 lists the value
of shipments for plants in SIC 2951 from  1963,  and an estimated value of total industry
shipments from  1968.  Table 1-5 lists the value of shipments  by product for  SIC 2951 in
1972, 1967 and 1963. The unit price of asphalt concrete rose from $5.38 per ton in 1968 to
$6.27 per ton in 1972  (17%). This increase was not as large as that registered by the general
construction cost index which, as reported by Engineering News  Record, rose  by 26% over
the same period.  This  is due, probably, to the relatively low  labor content of the asphalt
concrete manufacturing process.

     Asphalt paving materials must be shipped in  heated form directly to the job site. With
trucking costs currently at  13^ per mile, the effective shipping radius is very small, varying
from  10 to  30 miles. As a result, no imports or exports are  listed by the Department of
Commerce  for the industry. One may therefore  assume that domestic  consumption  and
shipments are equivalent.

     d.  Markets and Future Growth

     The primary competition for asphalt paving materials is Portland cement concrete; in
some rural areas there  also may be competition  from  gravel  and other natural road base
materials.  Table 1-6 shows the relative use of asphaltic and concrete paving for new public
                                        14

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                                       TABLE 1-4

                  ASPHALT PAVING MATERIALS - VALUE OF SHIPMENTS
                                   (Millions of Dollars)

                  Year   SIC 2951   +    Other*  =    Total Asphalt Concrete

                  1963     402.9          N/A               N/A
                  1964     402.1          N/A               N/A
                  1965     423.6          N/A               N/A
                  1966     465.7          N/A               N/A
                  1967     529.6          N/A               N/A
                  1968     568.1         781.9              1,350.0
                  1969     609.8          N/A               N/A
                  1970     671.5         1118.5             1,790.0
                  1971     747.5         1189.5             1,937.0
                  1972     840.9         1197.1             2,038.0

                  *Expecially from SIC 1611

                  Sources:  Preliminary Census of Manufactures, U.S. Bureau of
                         the Census, 1972, Hot Mix Asphalt, Plant & Production
                         Facts, National Asphalt Paving Association, 1970, 1971
                         1972.
highway construction in  selected years  from 1964 to 1972; Figure I-1 displays the data
graphically. These figures  indicate that while both markets have shown healthy growth over
the last  decade,  asphalt has increased its market share at  the expense of concrete. This
growth  may have  been  due to  a number of factors, including:  (1) market  growth in
geographical areas where frequent changes in temperature above and below 32° resulting in
freeze-thaw damage, require the use of asphalt, and (2) the lower first-installed cost per mile
of asphalt, which can be especially attractive in periods of inflationary pressures.

     Approximately  15% of all producers of asphalt concrete also produce Portland cement
concrete paving. In fact, the largest producer of asphalt, Warren Brothers Co., is also one of
the two largest producers of Portland cement concrete used for highway construction.

     Future demand for asphalt paving depends to a degree on the  levels of new highway
construction and, in turn, upon the levels of state and federal support for these programs.
Two factors tend to forecast a longer-term decline in federal highway spending. First, the
42,500-mile National  System of Interstate and Defense Highways is nearing completion. As
of March 31, 1973, approximately 81% of this system had been completed, while another
16% was in either the construction or the planning stages. Second, the recent energy crisis
can be expected to increase demands that portions of the Federal Highway  Trust Fund be
diverted  to other transportation modes  as specified in the  Federal  Aid Highways Act of
1973, primarily rapid transit systems. In  fact, the  City of Boston has recently applied for a
diversion of $600 million of such funds for intercity rail improvements.
                                         15

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                                                 TABLE 1-5

             VALUE OF SHIPMENTS OF ASPHALT PAVING MIXTURES AND EMULSIONS (SIC 2951)

                                                                Total Shipments
                                                           Including Interplant Transfers
                                  	1972	
            Product
Paving Mixtures & Blocks (Total)
Paving Mixtures & Blocks:
   Liquid Asphalt & Tar Paving
   Materials:
      Emulsified Asphalt, In-
      cluding Liquid Additives
      Other Liquid Asphalt &
      Tar Paving Materials, In-
      cluding Cutbacks
Asphalt & Tar Paving Mixtures &
Blocks, Including Bituminous  or
Asphaltic Concrete, and Asphaltic
Paving Cements
Other Paving Mixtures & Blocks,
Except Brick, Concrete, or Stone
Paving Mixtures & Blocks, other

 'Millions of Dollars.
**Millions of Barrels
Source: U.S.  Census of Manufactures 1967.
1972
Quantity** Value*
N/A 840.9
11.4 68.2
8.1 49.1
N/A 590.2
N/A 11.2
N/A 122.2
1967
Quantity** Value*
N/A 529.6
16.3 71.2
5.7 22.9
N/A 365.8
N/A 9.4
N/A 60.3
1963
Quantity** Value*
N/A 402.8
12.9 48.6
7.7 33.5
N/A 294.2
N/A 8.8
N/A 17.7

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                                                   TABLE 1-6

                      ESTIMATED COST OF CONSTRUCTION MATERIALS AND SUPPLIES USED FOR
                INTERSTATE AND FEDERALLY-AIDED PRIMARY HIGHWAYS, AND ALL PUBLIC HIGHWAYS*
                                              FOR SELECTED YEARS
                                                (Millions of Dollars)
                             1964
1967
                                                                           19VO
                                                                                                   1972
Material
Premixed Bituminous
Paving Materials**
Cement
Ready -Mixed
Concrete
Federally-
Aided
Highways
131.6
199.7
213.3
All
Public
Highways
188.2
285.5
304.9
Federally-
Aided
Highways
205.2
246.3
251.4
All
Public
Highways
301.2
361.5
369.0
Federally-
Aided
Highways
268.3
237.1
305.7
All
Public
Highways
395.4
349.4
450.6
Federally-
Aided
Highways
249.3
194.6
273.6
All
Public
Highways
402.9
314.4
442.2
 *Does not include maintenance and repair of highways nor construction of private roads, airport runways, etc.

**Asphalt Concrete

Source: U.S. Department of Commerce, Construction Review, August 1973

-------
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-------
     Future demand many also be affected by the future price and supply of asphalt and
competing materials. The price of asphalt paving materials has risen dramatically in the last
few  months, reflecting the  skyrocketing price of asphalt cement, a petroleum derivative
product.  Availability has also been a problem, because  refineries  have concentrated their
production on gasoline and fuel oil at the expense of liquid asphalt. However, the shortages
of liquid asphalt have occurred during the winter when the majority of asphalt plants in the
country are routinely shut down.  Thus, the long-term effect of the energy crisis on both
asphalt supply and demand is as yet uncertain.

     A recent trend, which may mitigate the potential negative effects mentioned above, is
the increasing use of full-depth asphalt pavements and deep-lift asphalt construction tech-
niques. These procedures call for the substitution  of asphalt for other base course materials,
and have the effect of increasing the use of asphalt per mile of road constructed. It is also
important to understand that in the asphalt paving industry, repaying and maintenance of
existing roads has traditionally accounted  for nearly 50% of the market. These markets
constitute a steady outlet for the production of the industry, and are little affected by most
of the factors mentioned above.  Table 1-7 shows the relative importance of the various
markets for asphaltic concrete and the relationship between repaving and new construction
for 1972.

     Predictions as to future production are difficult because of the present uncertainty as
to the availability and supply of asphalt cement. Also, the  stabilizing of gasoline consump-
tion and therefore, tax monies used for highway construction, because of unavailability and
voluntary restraint,  will inhibit future growth in demand  for state and federal highway
construction. As a result  of these two  factors, the industry is predicting a 16% decline in
production of asphalt concrete in 1974 from the  estimated record high level of production
of 358 million tons in 1973. Because of the factors mentioned above, the production level
achieved in  1973 is  unlikely to be equalled through 1980. However, with the constant
demand  for  resurfacing  and maintenance  and the continued strength in the private and
commercial markets, the  National Asphalt Paving Association (NAPA) projects that total
demand will  grow from the  300 million ton level of 1974 at a rate of 2% per year through
1980.

     The demand for asphalt emulsions for paving purposes is currently very strong. The
product  is used  increasingly  as a stabilizing  agent for the base courses of  new highway
construction. By applying a coat of asphalt emulsion to the base aggregates prior to laying
the asphalt  concrete above, road contractors  are  able to reduce the required depth of the
base material. The emulsion also provides an effective water barrier between the  road
material  and the base. These properties have  increased  the demand for emulsions in areas
where the available supply of adequate base materials has been declining.
                                          19

-------
                                       TABLE 1-7

                          DISTRIBUTION OF 1972 PRODUCTION

                                                          Percent
                      Type of Market:
                         Interstate Highways                     16
                         State Highways (Excluding Interstate)      30
                         Municipal and County Roads              21
                         Airports                               3
                         Private and Commercial                  28
                         Other                                 2
                                                            100

                      End Use:
                         Surface and Binder                     67
                         Hot Mix Base                          28
                         Patching                               4
                         Other                                 1
                                                            100

                      Type of Construction:
                         New Construction                      55
                         Resurfacing and Maintenance             45
                                                            100

                      Source: Hot Mix Asphalt, Plant & Production Facts,
                             1972, National Asphalt Paving Association.

     The recent energy crisis has also increased the demand for asphalt emulsions for paving.
Emulsions  are  the primary alternative  product for asphalt  cutbacks. When cutbacks are
applied to road surfaces, the higher distillates which have  been used to liquefy the asphalt
cement evaporate, leaving the cement as  a binder. This method has been recognized recently
by the  industry and  the  government as a needless  waste of the higher  distillates. Conse-
quently, cutbacks are being phased out rapidly, and  emulsions can be expected to pick up
the majority of their market share.

     The asphalt concrete industry also is studying closely the feasibility of  substituting
emulsions for  asphalt cement  in their  production  process. The reasons  for this are  self-
evident; the lesser amount of asphalt cement per volume in the emulsions would enable the
asphalt concrete producers to reduce the effect of the price and availability problems  they
have been having with their raw materials.

     Despite  these demand factors,  the industry has estimated a 15-20% decline  in the
production of  emulsions  in 1974 from the estimated 1973 level of 14 million barrels  (2.6
million short  tons).  This decline is due,  as  with  the  hot-mix industry,  to the lower
                                          20

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availability of raw materials (asphalt cement), and especially the expected decline in demand
in 1974 for all paving products. However, shipments of emulsions are expected to grow over
the next  six years faster than  asphalt concrete,  at about 4% per year, because of the
favorable demand factors mentioned above.

     e. Marketing and Distribution

     The  maximum effective shipping radius for asphalt paving materials is approximately
30  miles.  Much shorter distances are preferred to  maximize the efficiency of the trucking
fleet used to transport the mix from the plant to the job site. The potential market area for
each stationary plant, therefore, is readily defined. Certain asphalt plants, called "mobile"
or "nomad" plants, are designed with the capability of moving from market area to market
area as conditions demand.  This flexibility enables producers  to supply remote temporary
market areas, such as sites of new federal interstate highways,  without having to depreciate
their equipment over  an artificially short time. Although it is  rare, so-called "fixed" plants
may also be moved if the equipment is in good shape, and the  market area which they have
been set up to serve has reduced in potential.

     Asphalt paving materials generally are  sold on a bid basis for specific projects. If the
producer is also the contractor, he may have the flexibility to adjust his asphalt price in the
bid in conjunction with the placing labor involved to reflect his bidding strategy. Contrac-
tors who are not producers  must solicit bids from the producers in the area much as they do
from other commodity suppliers. The advantage to the producer/contractor inherent in this
situation explains the  significant level of vertical integration within the paving industry as
demonstrated in Table 1-8. There is a trend, however, for producer/contractors to regard  their
plants as profit centers. This tends to mitigate the advantages mentioned above.

2. Manufacturing and Ownership Profile

     a. Plant Characteristics

     There are  approximately 4,800 asphalt paving  plants in  the United States. Fifty of
these produce asphalt emulsions. The remainder produce asphalt concrete. Of the 4,750
plants producing asphalt concrete,  872 are classified in SIC 2951.  Virtually all plants in
SIC 2951  are fixed. Plants  in  SIC 1611 may  be  fixed or mobile.  Of the 4,750 asphalt
concrete plants, an estimated 25%, or 1,200,  are mobile plants.

     The primary segmentation in the asphalt paving industry is between those plants which
produce asphaltic concrete  and those which  produce asphalt emulsions. The differences
between these two types of plants are discussed in depth in the Development Document.

     Very little information is available on asphalt emulsion plants. The Bureau  of Census
data listed in Table 1-5, and  the Bureau of Mines data in Table I-l are the extent of the data
published  on this segment by the government.
                                         21

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                                        TABLE 1-8

                         INTEGRATION OF COMPANY OPERATIONS

                                                    Number of Companies
                                                       1972     1971

               Produces Hot Mix Asphalt                   382      336
               Places (Lays) Hot Mix Asphalt Produced
                  by Another Company                     346      310
               Owns Gravel Pit or Quarry                   182      176
               Produces Portland Cement Concrete            57       56
               Company is a Contractor  For:
                  Road Construction                       316      302
                  Other Types of Construction               187      180
               Distributes Asphalt Emulsion                  64       52
               Distributes Liquid Asphalt                    71       55

               Source: Hot Mix Asphalt, Plant & Production Facts, 1972, National
                      Asphalt Paving Association.


     Table 1-5 showed the relative importance of emulsions within the industry. Emulsion
plants are generally larger than asphalt concrete plants.  In  1967, the average volume of
emulsion  plants was approximately $ 1.4 million per year. While these plants are dispersed
nationally, they  are heavily concentrated  in the Midwest,  where  the  quality of natural
aggregates imposes  a greater need for emulsions  as road base sealers, and the markets for
their  miscellaneous  uses  (primarily industrial) are greatest.  Table 1-9 lists the relative  im-
portance of the end  uses for the product.


                                        TABLE 1-9

                            END USES OF EMULSIFIED ASPHALTS
                                   (Millions of Short Tons)

                       Year   Paving      Roofing   Other      Total
1968
1969
1970
1971
1972
2.184
2.057
2.341
2.275
2.179
0.007
0.026
0.014
0.017
0.014
0.078
0.075
0.286
0.331
0.343
2.269
2.158
2.641
2.623
2.536
                       Source: Mineral Industry Surveys, U.S. Dept. of the
                              Interior, Bureau of Mines 1968-1972.
                                           22

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     Table I-10 lists plant characteristics for 1,081 of the 4,750 plants from a survey by the
 National  Asphalt Paving Association for 1971  and  1972. This table indicates that most
 plants use batch mixers, as opposed to continuous mixers. The great majority of all plants
 use mixers with a capacity of 4,000-7,999 pounds. Of these plants 119, or 11%, have mixers
 of less than 4,000 pounds capacity, or under 960 tons per day, presuming  480 batches  per
 day. There  is  an increasing  use  of automated plants.  Mobile plants, as discussed above,
 constitute approximately 25% of all plants. There is no  differentiation, in product,  process,
 or treatment technology between mobile and fixed plants.
                                       TABLE 1-10

                NUMBER OF ASPHALT CONCRETE PLANTS BY SIZE OF MIXER

                                                        Number
                                                       of Plants

                                      Mixer Size        1972    1971
                                  Under 4,000 Ibs.       119    133
                      Stationary   4,000 to 7,999 Ibs.     543    434
                         Plants     8,000 to 9,999 Ibs.      81     74
                                  10,000 Ibs. or more     63     33
                                  Continuous Mixer       17     22

                                  Under 4,000 Ibs.        25     40
                      Portable     4,000 to 7,999 Ibs.     110    101
                         Plants     8,000 to 9,999 Ibs.      27     33
                                  10,000 Ibs. or more     33     34
                                  Continuous Mixer       63     62
                      Number of Automated Plants        608    441
                      Number of Employees Per Plant      3.2    3.9

                      Source: Hot Mix Asphalt, Plant and Production Facts,
                              1972, National Asphalt Paving Association.

     Asphalt concrete plants operate intermittently, rarely reaching their rated capacity for
more than a short time. While the average capacity of the plants in this segment is estimated
to be 1,600 short tons per day, the average production  is  closer to 600 short tons per day,
although  the ratio between capacity and production  may vary significantly over time and
between plants, depending on  market conditions.

     Because the asphalt paving industry is national  in scope, and  the product such that
plants  must be located  very  close to the  markets, geographical segmentation  of asphalt
concrete plants is negligible. Table 1-11 lists the location by state of the 4,002 asphalt paving
plants  identified  by  the National Asphalt  Paving  Association. Regional differences  are
determined  solely by the levels of road and highway construction activity in each region.
Rural regions tend to have a higher proportion of mobile plants than urban regions. There
are  price  differences between regions, because of variations in the availability and cost of
                                          23

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                          TABLE 1-11

EXISTING ASPHALT CONCRETE PLANTS IN THE UNITED STATES BY
                   REGION (JANUARY 1974)
      Region I
 Region II
 Region III
              172

      Region V

  Ind.         130
  Mich.        147
  Ohio        287
              564
       665

 Region VI

Ky.    128
Tenn.  105
W. Va.   44
        277
 Region VII
Ark.
La.
Miss.
 38
 66
 91
195
        Region IV
Conn.
Maine
Mass.
N. Hamp.
R.I.
Vt.
50
28
50
20
12
12
D.C.
Del.
Md.
N.J.
N.Y.
Pa.
4
8
66
117
212
258
N.C.
S.C.
Va.
116
58
106
280
Ala.
Fla.
Ga.
P.R.
82
115
83
13
293
        Region VI11
Iowa
Mo.
202
 68
153_
423
      Region IX
  Region X
 Region XI
        Region XII
N. Mex.
Ok la.
Texas


31
57
96
1RA
lo4*
Minn.
N. Dak.
S. Dak.
Wise.

114
19
31
135
ir\r\
Colo.
Kansas
Nebr.
Wyo.

38
61
37
24
ten
Ariz.
Calif.
Hawaii
Nev.
Utah
12
228
10
8
18
                                                          276
                          Region XIII
                         Alaska
                         Idaho
                         Mont.
                         Oreg.
                         Wash.
             30
             27
             31
             55
             71
             214
  Source:  Unpublished data, National Asphalt Paving Association.
                              24

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asphalt cement; however, they are not important because the short required shipping radius
makes interregional  trade  in the industry impossible.  Table I-12  lists  certain  regional
characteristics for the plants located in SIC 2951.

     Of the 872 establishments included in SIC 2951 for 1967, only 64, or 7%, had more
than 50  employees.  The great majority of these larger establishments are believed to be
asphalt emulsion  facilities.  Table I-13 describes the industry  according  to the number of
employees per establishment. This table indicates an average of approximately 10 produc-
tion workers per establishment.  For the asphalt concrete  paving  industry (excluding
emulsions),  the  National Asphalt Paving  Association  has  estimated an  average of 3.2
production workers per plant in 1972, a figure which has been steadily  declining with the
increased use of automated  asphalt concrete plants.

     These plants may be segmented for the purposes of this report by plant size and by the
type of technology used to control particulate emissions. Those using dry processes are, of
course, in compliance with  the proposed EPA guidelines on effluent control. According to
industry  estimates, approximately 25% of existing plants are equipped  with dry process
control equipment, or "baghouses."

     b. Firm Characteristics

     There are approximately 1,350 firms in the asphalt paving industry. These firms range
from  small one-plant operations to large multi-plant firms serving many  regional markets.
The two  largest  companies,  Warren Brothers and  Industrial  Asphalt, are wholly-owned
subsidiaries of major oil  corporations — Warren, of Ashland Oil and Refining, and Industrial,
of Gulf Oil. Each operates in excess of 100 plants. Companies in the 50-plant range include
Interstate Amiesite,  Peter  Kiewit and Sons, and General Crushed  Stone. None of these
companies, however, has nationwide coverage.

     In general,  the industry is characterized by a low  relative degree  of concentration.
Concentration ratios of  plants in SIC 2951 are shown in Table 1-14. These ratios are among
the lowest of all  industries included in the Census of  Manufactures.  Ratios for the entire
industry closely follow those for SIC 2951.

     The  National Asphalt Paving Association has compiled  statistics  within the paving
industry  about firm characteristics by size.  These statistics,  summarized on Table 1-15,
suggest that the larger firms (those having in excess of 200,000 tons of annual production)
are growing at the expense of the smaller firms. Some of this growth has clearly been by the
merger route, as the larger multiregional companies have been purchasing  smaller companies
to increase their market share within certain regions, but has also resulted from production
and managerial efficiencies and a more sophisticated market approach.
                                        25

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                                               TABLE 1-12
                             GENERAL STATISTICS BY GEOGRAPHIC AREA (1967)
                                                (SIC 2951)
Establishments


Geographic Area
United States
Northeast
North Central
South
West
to
ON


Total
872
284
220
241
127
With 20
Employees
or More
155
44
42
43
26
Total
Number of
Employees*
12.2
3.7
3.4
3.5
1.6
Total
Number of
Production
Workers*
8.5
2.6
2.3
2.8
0.9
Value Added
By
Manufacture**
234.7
79.5
59.2
59.7
36.3

Value of
Shipments**
584.6
198.9
149.0
152.4
84.2
Capital
Expenditures,
New**
23.8
9.9
6.2
4.3
3.4
 "Thousands
**Millions of Dollars
Source:  1967 Census of Manufactures; U.S. Department of Commerce, Bureau of the Census.

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                                                                  TABLE 1-13

                                 SIC 2951 GENERAL STATISTICS, BY EMPLOYMENT SIZE OF ESTABLISHMENT (1967)
to
Establishments (Total)

Establishments With
  An Average Of:

  1 to  4 Employees
  5 to  9 Employees
 10 to  19 Employees
 20 to  99 Employees
100 to 499 Employees

 ^Thousands.
"Millions of Dollars.
                                          Number of
                                        Establishments

                                            872
   Total
Number of
Employees*

   12.2
  Total
Number of
Production
 Workers*

   8.5
 Value Added
     By
Manufacture**

    234.7
  Value of
Shipments**

   584.6
   Capital
Expenditures,
   New**

    23.8
306
255
156
142
13
0.7
1.7
2.1
5.5
2.2
0.6
1.2
1.5
3.7
1.5
22.7
42.4
48.7
94.1
26.8
63.6
130.9
123.6
207.3
59.3
1.7
5.5
4.9
10.1
1.7
               Source: 7567 Census of Manufactures; U.S. Department of Commerce, Bureau of the Census.

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                                      TABLE 1-14

                CONCENTRATION RATIOS: PERCENT OF TOTAL BUSINESS
                                      (SIC 2951)

        Year   4 Largest Firms    8 Largest Firms    20 Largest Firms   50 Largest Firms

        1963         15              21               35               51
        1966         15              23               N/A             N/A
        1967         14              22               35               51
        1970         16              24               N/A             N/A

        Source: Bureau of the Census 1971 Survey of Manufactures,


     Table 1-15 also shows that the larger firms:

     •    are more active in state and interstate highway work while doing less private
          and commercial business;

     •    tend to  derive a  smaller portion of their revenues from  resurfacing and
          maintenance work;

     •    realize lower prices for their material, emphasizing their efficiencies and level
          of vertical integration; and

     •    are able,  therefore,  to  increase their market  share  through competitive
          pricing.

     There are essentially three patterns of ownership and management in the industry. At
the highest level of sophistication are the major companies who operate as wholly-owned
subsidiaries of major corporations. Employees of these firms  have no direct equity interest
in their  corporation,  although they may have  a  minor equity interest  in  their parent
company. Their plants are managed on  a highly professional basis, under the strict financial
control of both the subsidiary and the parent corporation.

     At the second level are the publicly held corporations whose primary' business is in the
industry. These firms are few in the  asphalt paving industry, and their stock may be closely
held by the founders  or their families. They are distinguished from the smaller closely-held
concerns  in their  scope of operation,  which is multi-plant, and  subject to professional
management  and control. Plant managers for these  firms will be unlikely to have a major
equity interest in the corporation.

     The third level is the small owner-managed firms. The majority of these firms may be
incorporated,  but the stock of the corporation will be closely held. They will operate one
                                         28

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                                                                     TABLE  1-15

                         HOT-MIX ASPHALT PRODUCTION OF REPORTING COMPANIES GROUPED BY VOLUME OF PRODUCTION
to
        Hot Mix Asphalt
           Production
           Value and
            Change
        Distribution
          of 1972
         Production
        Number of
        Companies
        and Plants
Reported Total Production (million tons)
Reported Total Value (million dollars)
Average Value Per Ton FOB Plant
Change in Production 1971 - 1972
               Interstate Highways
               State Highways
               Municipal and County Roads
               Airports
               Private and Commercial
               Other
                             Markets
                             End
                             Uses
                             Type of
                             Construction
               Surface and Binder
               Hot mix base
               Patching
               Other

               New Construction
               Resurfacing and Maintenance
Number of Reporting Companies
Number of Stationary Plants Covered
Number of Portable Plants Covered
Group 1
Under
100,000
tons
9
$58
$6.76
-7%
1%
28%
29%
2%
38%
2%
75%
17%
5%
3%
51%
49%
155
154
57
Group II
100,000-
199,999
tons
13
$91
$6.89
0
6%
29%
26%
3%
33%
3%
68%
26%
5%
1%
51%
49%
95
133
44
Group III
200,000-
499,999
tons
30
$183
$6.13
+9%
18%
32%
19%
3%
27%
1%
70%
27%
2%
1%
55%
45%
97
241
78
Group IV
500,000
and
Over
38
$229
$5.99
+5%
20%
30%
20%
3%
25%
2%
62%
33%
4%
1%
57%
43%
41
295
79



Total*
90
$562
$6.27
+5%
16%
30%
21%
3%
28%
2%
67%
28%
4%
1%
55%
45%
388
823
258
         "Totals may not add due to rounding.

         Source: Hot Mix Asphalt, Plant and Production Facts, 1972, National Asphalt Paving Association.

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plant or a small number of plants, in a very limited geographical region. Plant management,
which will often be  the  same as the  firm management,  will generally have a significant
equity interest in the operations. Table 1-16 lists selected  statistics on plant ownership for
SIC 2951.

     The pattern of ownership may have a direct bearing on the response of the firm to the
economic impact of pollution control.  In general, closely held firms will be less likely to be
able to raise capital  externally if such  is  required to install pollution control equipment.
Also, the potential of closure to them would have a much  greater personal significance than
to the professional managers of a corporate  subsidiary.

     Companies also  differ as to  degree of integration in the entire paving process. Although
some companies (SIC 2951)  are  primarily  producers of asphalt paving materials, the great
majority of the 4,800 companies in the  industry also engage in contract work. Nearly half of
the  companies have  integrated   backwards into controlling sources of gravel and other
aggregates. A growing proportion of  the  companies in  the  asphalt paving business also
distribute asphalt emulsions  and other liquid asphalt products.  Table 1-8 has detailed certain
statistics  on integration compiled by the National Asphalt Paving Association for the 388
companies covered in its annual survey.

     c. Industry Segmentation

     Segmentation within the asphalt  concrete  and  emulsion industries,  except  for plant
size,  is insignificant  for the purposes  of  this economic impact  analysis. In the asphalt
concrete  industry, there is some geographic segmentation  as to production period; plants in
the northern regions  are generally shut down during the winter months, because it is not
feasible to lay hot-mix asphalt  in cold temperatures. Plants in the  South and Southwest
normally  operate year-round. As inter-regional shipment is unlikely, this segmentation has
no effect on the industry as a whole.

3.  Financial  Profile

     Because  of the  large number of  privately held  firms and  the significant  degree of
vertical integration within the asphalt paving industry, little data has been published on the
financial  characteristics of asphaltic concrete and emulsion plants.  The  figures  presented
here  are  a combination of total industry  data derived from the Bureau of the Census  for
SIC 2951 and data obtained from industry sources.

     Tables 1-17 and 1-18 give selected financial statistics  and  operating ratios for SIC 2951
from 1963 to 1972. They show a healthy  growing industry characterized by the following
trends:

     •    A steady increase in dollar volume of shipments.
     •    Commensurate growth in capital expenditures.
                                          30

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                                     TABLE I-16

 SIC 2951 SELECTED STATISTICS FOR OPERATING MANUFACTURING ESTABLISHMENTS, BY
TYPE OF OPERATION AND LEGAL FORM OF ORGANIZATION FOR MAJOR INDUSTRY GROUPS
                               AND INDUSTRIES (1967)



Item
Total SIC 2951
Type of Operation:
Total Multiunit Companies
Total Single Unit Companies
Legal Form of Organization:
Corporate
Total Noncorporate


Number of
Establishments
872

461
286

689
58

Total
Number of
Employees*
12.2

6.6
5.2

11.3
0.5
Total
Number of
Production
Workers*
8.5

4.5
3.7

7.8
0.4

Value Added
By
Manufacture**
234.7

140.4
88.1

219.9
8.5


Value of
Shipments**
584.6

366.7
202.5

549.5
19.7

Capital
Expenditures,
New**
23.8

14.3
8.8

22.5
0.6
                                               0.3
Establishments Covered by
  Administrative Records***         125              0.3

   * Thousand
 ** Millions of Dollars.
*** No Data on type of operation or legal form of ownership.

Source: 7972 Census of Manufactures, U.S. Department of Commerce, Bureau of the Census.
6.2
15.3
0.7

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                                                            TABLE 1-17

                                            SELECTED STATISTICS SIC 2951 (1963-1971)
Production
Year
1963
1964
1965
1966
1967
1968
1969
oo 1970
1971
1972
All
Employees
Number* Payroll**
9.7
9.9
10.1
10.4
12.2
11.6
11.6
12.9
12.4
13.4
62.1
64.2
67.5
70.5
90.0
89.4
97.0
117.2
126.2
142.6

Workers
Number* Wages**
6.7
6.8
7.4
7.7
8.5
8.2
7.9
8.8
7.9
9.7
40.0
41.3
44.7
46.9
58.4
58.3
64.1
72.3
75.7
97.6
Value
Added**
165.6
160.7
183.6
185.9
234.7
243.8
260.9
320.4
345.2
388.1
Cost of
Materials**
261.8
283.8
279.6
293.6
350.1
370.5
380.2
417.8
464.6
502.3
Value of
Shipments**
427.5
442.7
461.9
479.2
584.6
610.9
641.5
738.4
803.6
883.0
Capital
Expenditures**
15.1
13.5
19.9
20.1
23.8
23.0
27.9
30.4
35.3
54.0
End-of Year
Inventories**
12.1
13.4
14.7
14.5
19.7
22.9
22.7
27.4
30.4
37.4
 * Thousands.
"Millions of Dollars.
Source:  7972 Preliminary Census and 1971 Survey of Manufactures, U.S. Department of Commerce, Bureau of the Census.

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OJ
                                                                 TABLE 1-18




                                              SELECTED OPERATING RATIOS SIC 2951 (1963-1971)



Year

1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
Ratio of
Value
Added to
Shipments

0.387
0.363
0.397
0.388
0.401
0.399
0.407
0.434
0.430
0.440

Ratio of
Inventories
to Shipments

0.028
0.030
0.032
0.030
0.034
0.037
0.035
0.037
0.038
0.042
Ratio of
Payroll
to
Value
Added

0.375
0.400
0.368
0.379
0.383
0.367
0.375
0.366
0.366
0.367
Wage Per
Production
Worker
Manhour
<$)
2.649
2.735
2.811
3.148
3.244
3.470
3.601
3.866
4.588
4.692
Value
Added Per
Production
Worker
Manhour
($)
10.97
10.64
11.55
12.48
13.04
14.51
14.66
17.13
20.92
18.66


Index of
Employment
(1967=100)
79.51
81.15
82.79
85.25
100.00
95.08
95.08
105.74
101.64
109.84



Value Added
(1967=100)
70.56
68.47
78.23
79.21
100.00
103.88
111.16
136.51
147.08
165.36


1 ndex of
Shipments
(1967=100)
73.13
75.73
79.01
81.97
100.00
104.50
109.73
126.31
137.46
151.04
                 Source:  7372 Preliminary Census of Manufactures, and 1971 Survey of Manufactures, U.S. Department of Commerce, Bureau of the Census

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     •    Increasing wages and productivity.
     •    Value added growing faster than sales volume.

Figure 1-2 graphically displays selected features of the operating profile. The statistics on the
larger industry (including SIC 1611) listed in Table 1-4 indicate that these positive trends are
also typical of that sector.

     Table 1-19 demonstrates the steady improvement in gross profit margins which the
industry has experienced over the decade. There is evidence, however, that these margins
have  slipped in the  last year, for reasons which are  discussed  in detail  in the following
section.

                                        TABLE 1-19

                              FINANCIAL PROFILE -2951

                            1971*     Percent    1967*     Percent    1963*   Percent

        Sales                 803.6     100.0    584.6      100.0     427.5     100.0
        Cost of Goods Sold:
           Materials          464.6      57.8    350.1        59.9     261.8     61.2
           Labor             75.7       9.4      58.4       10.0      40.0      9.4
        Total Cost of
           Production        540.3      67.2    408.5       69.9     301.8      70.6
        Operating Profit       263.3      32.8    176.1       30.1     125.7      29.4

        *Millions of Dollars.

        Source: Annual Survey of Manufactures, 1971, U.S. Bureau of Census.
     From the above data and data gleaned from interviews with industry sources, a typical
operating statement  for an asphalt concrete plant  has  been prepared  and  is shown  in
Table 1-20. Profit levels in the industry, both as a percentage of sales and as a percentage of
owner's equity or net assets are somewhat below the national averages of 4.3% and 10.6%,
respectively, for all manufacturing companies.

     Published data on emulsion plants, unfortunately, are not available. However, industry
estimates suggest a financial profile in line with that presented in Table 1-21.

4. Prices and Price Setting

     An  important factor in determining the ability of an industry to  mitigate the effect of
incremental costs for pollution control is its  flexibility in  raising prices  to cover  these
incremental costs. This section analyzes historical trends in prices of asphalt paving products
and  examines  the  pricing  practices in the industry  to  provide a basis for  assessing  the
economic impact on the industry of the proposed effluent limitation Guidelines.

                                          34

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"5
D
c
o
   1,000
    900  -
    800  -
    700  -
    600  -
    500  -
    400  -
    300  -
    200  ~
    100  -
                                                                        Years
         Source: 1972 Preliminary Census and 1971 Survey of Manufactures,

                U.S. Department of Commerce, Bureau of the Census.
                                               FIGURE 1-2   SELECTED STATISTICS SIC 2951 (1963-1971)

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                                        TABLE 1-20

          AVERAGE OPERATING STATEMENT FOR ASPHALT CONCRETE PLANTS (1972)

                                                          Percent of Sales

                  Net Sales, After Discounts, etc.                     100.0

                  Direct Manufacturing Costs
                     Aggregates                             31.0
                     Asphalt Cement                        24.0
                     Other                                  3.0
                     Labor & Operating Expenses               9.0    67.0

                  Indirect Manufacturing Costs                        13.0
                  Gross Profit                                      20.0

                  Selling, General & Administrative Expenses            13.0

                  Profit Before Tax                                   7.0

                  Net Profit After Tax                                4.0

                  Return On Net Assets                               8.0
                  Return On Owners Equity                          10.0

                  Note: These historical relationships have been altered to a degree
                        in recent months, because producers have had difficulty in
                        passing  on the increased cost of their raw materials. However,
                        as this situation stabilizes, profit levels should return to the
                        range indicated above.

                  Source: Contractor estimates.


     As with most materials, the prices of asphalt concrete and emulsions are determined by
cost of production and  the prices  of substitute  products.  The production factor which
historically  has had the greatest  effect on asphalt paving materials  is the cost of asphalt
cement. The primary competing material which has served to control increases in the prices
of asphalt concrete and emulsions in  Portland cement concrete.

     Table 1-22 shows the historical relationship between the price of asphalt concrete and
Portland cement concrete  installed  on federal-aid  highway programs. The third column in
the table demonstrates that  the  relationship between the price of these  two materials has
remained remarkably constant  over the 18-year price history  covered. These prices, it is
important to note, include shipping costs from the plant  to  the job site, and the labor and
machinery required to install the material at the job site.
                                             36

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                               TABLE 1-21

AVERAGE OPERATING STATEMENT FOR ASPHALT EMULSION PLANTS (1972)

                                                Percent of Sales

         Net Sales, after discounts, etc.                       1000

         Direct Manufacturing Costs
           Asphalt Cement                         39.0
           Other Materials                         14.0
           Direct Labor                           12.0    65.0

         Indirect Manufacturing Costs                        13.0

         Gross Profit                                       22.0

         G, S&A                                          13.0

         Profit before Tax                                   9.0

         Net Profit After Tax                                 5.0

         Return of Net Assets                               12.0

         Return on Equity                                  15.0

         Source:  Contractor Estimates.



                               TABLE 1-22

  AVERAGE BID PRICE TRENDS ON FEDERAL AID HIGHWAY CONTRACTS
                          (Dollars per Short Ton)


Year
1955
1960
1965
1967
1970
1971
1972
1973

Asphalt
Concrete
6.07
6.37
6.50
6.47
8.04
8.54
9.22
9.99

Portland Cement
Concrete
3.96
4.33
4.34
4.43
5.42
6.06
6.25
6.87
Ratio of
Portland Cement Concrete
to Asphalt Concrete
0.65
0.68
0.67
0.68
0.67
0.71
0.68
0.69
      Source: Engineering News Record, Various issues.
                                   37

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     On a per-mile-of-highway-installed basis, asphalt concrete generally has a lower first
cost than Portland cement concrete.  A study done  in  1961 by  the  Stanford  Research
Institute, indicated that the cost of a heavy-duty asphalt surface averaged $60,000 per mile
of construction,  while  a  similar Portland  cement concrete surface averaged $80,000 per
mile. While Portland cement concrete  is generally  cheaper on a per ton basis, as  shown in
Table 1-22, a greater depth is required  for  Portland  cement concrete (4"-6" vs. 3" for
asphalt  concrete). As  the specific  gravities  of the  materials are roughly equivalent, the
material cost advantage is largely offset.  Portland cement  concrete  thus requires from 33%
to 100% more product per mile than asphalt concrete. This difference was offset to a degree
by the longer life of a concrete surface, 26 years versus 18 years for asphalt.

     Since the price relationship of the raw  materials has remained constant over the past 18
years, as demonstrated in Table 1-22, and the other factors of installed cost are  either
common to both systems (road base), or have risen in cost concomitantly (rebar), one can
assume  that this  first-cost relationship has  remained  at least constant over the last decade.
The decision to purchase asphalt or concrete, therefore, depends on the discount rate used
to evaluate the  longer-term savings of concrete in terms of lesser frequency of resurfacing. In
recent years, as interest rates have risen,  the  competitiveness of asphalt can be said to have
increased. This may explain, to a large  degree, the increase in market share  of asphalt on
federal-aid highway programs mentioned previously.

     Table 1-23  compares  the price  of asphalt concrete, FOB plant, and installed for
1970-1972.  This  table suggests  that recent price  increases  have  been caused  more  by
increases in the cost of installation than in the cost of the asphalt concrete FOB plant.

     The two primary cost of production factors which  have a  significant bearing on the
price of asphalt concrete are aggregates and asphalt cement. Table 1-20 gave an indication of
the relative importance of these  two  materials in the cost structure of asphalt  concrete.
Table 1-24  gives an indication of materials usage within SIC 2951.  For emulsions,  asphalt
cement is the primary cost factor.

     While the importance of  aggregates and asphalt cement historically have been of equal
importance in the cost of asphalt concrete, asphalt cement has been the major factor in the
price increases of the  past few years. One reason for this, as shown in Table 1-8, is that  a
good proportion of companies in the asphalt concrete business control their own quarries,
and therefore,  the price of aggregates can be controlled concomitantly. Despite the presence
of major oil companies in the industry, the price of asphalt cement to the paving companies
is largely out of the control of the asphalt producers.

     Table 1-25 lists the relationship between the price of asphalt cement and the price of
asphalt concrete  for the past three years. It illustrates that in recent years other elements of
cost (primarily labor) have played a larger role in the price increases, as reported in Table
1-22. Recently, this trend has been reversed.  Current prices for asphalt cement have reached
as high as $81  per short ton.  Such an increase of  $50 in  the price of asphalt cement from
                                          38

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                                  TABLE 1-23

                         ASPHALT CONCRETE PRICES
                             (Dollars per Short Ton)
      Year   Material, FOB Plant    Installed
      1970
      1971
      1972
5.79
6.08
6.27
8.04
8.54
9.22
Material Proportion of Cost

           72%
           71%
           68%
     Sources:  National Asphalt Paving Association and Engineering News Record,
              various issues.
                                  TABLE 1-24

     MATERIALS CONSUMED BY THE ASPHALT PAVING INDUSTRY (1967)
        Material

Total Materials, Containers,
   and Supplies

Asphalt:
   Less than 200 Penetration
   200 and Over Penetration

Sand and Gravel

All Other Materials, and
   Components, Parts,
   Containers, and Supplies
   Consumed

Materials, Containers and
   Supplies, other

'Millions of Dollars.
         Unit of Measure
         1,000 Short Tons
         Million bbls.

         1,000 Short Tons
              Quantity


                N/A
               4,761.4
                N/A

              35,354.6
                                N/A
                                N/A
               Delivered Cost*
                                              301.9
                   104.5
                    11.0

                    59.9
                               61.9
                               64.6
Source:  7367 Census of Manufactures, U.S. Department of Commerce, Bureau of the
        Census.
                                     39

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$31 in 1972 (Table 1-25) can be expected to increase the cost of asphalt concrete by $50/18
or $2.78 per short ton. Fortunately for the industry, the price of Portland cement concrete
has also been severely affected by the  energy  crisis,  not  through raw material  costs, but
through production costs, because the cement industry is highly energy intensive; a modern
facility incurs 35% of its manufacturing cost  on fuel and power. (The cement industry,  of
course, has also been burdened with considerable emission control costs  that have sharply
increased total costs or made plants obsolescent.)


                                       TABLE 1-25

                        RELATIVE AVERAGE PRICES (Asphalt Concrete)
                                  (Dollars Per Short Ton)

                                                                   A
                                                                Asphalt
                                                                Cement

                                                                   18
Year
1968
1970
1971
1972
Asphalt
Concrete
5.38
5.79
6.08
6.27
Asphalt
Cement
23.10*
29.08
30.48
31.02
Asphalt
Cement
18
1.28
1.62
1.69
1.72
A
Asphalt
Concrete

0.41
0.29
0.19
                                                                  0.34
                                                                  0.07
                                                                  0.03
                '1969
               Sources: National Asphalt Paving Association and Engineering News
                       Record, various issues.
     An  indication of the rapidity  of recent  price increases  in asphalt cement can be
obtained from Engineering News Record. On December 6,  1973, the average price reported
for asphalt cement of 85/100 penetration was $32.78. A more recent average price, is about
$60  in July 1974 although prices may vary from $45-80, depending on contract commit-
ment and location. The emulsions sector, whose primary raw material is asphalt cement, has
seen more dramatic price rises than the asphalt  concrete  sector.  However, its primary
competing material, cutbacks, are  similarly  dependent  upon asphalt cement as a raw
material, so  its relative market position has not been severely affected. Table 1-26 shows the
average prices of  emulsions and cutbacks for selected dates from January  1972  to the
present.

     As mentioned previously, asphalt paving products are sold  primarily on a bid basis for
specific projects. Because of the relatively stable price history of asphalt products until the
past  few years, contractors and producers  were willing to submit firm bids for  projects such
as state  and  federal  highway contracts  which might commence  a  year or 18  months
                                         40

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Date Asphalt Emulsions
January 1972
July 1973
December 1973
March 1974
August 1974
0.157
0.173
0.195
0.247
0.332
                                       TABLE 1-26

                          RELATIVE AVERAGE PRICES (Emulsions)
                                    (Dollars per Gallon)

                                                     Asphalt Cutbacks

                                                         0.143
                                                         0.148
                                                         0.167
                                                         0.236
                                                         0.322

                    Source: Engineering News Record, various issues.

subsequent  to the establishing of the  bid  price. This practice has recently caused severe
difficulties for the industry; companies are forced in many cases to supply their product at a
price  determined on the basis of an asphalt cement price of  $30 per short ton, although
their current costs for the asphalt cement may be $50-70 per ton.

     There is a growing movement in  the industry  to introduce  escalation  clauses  in their
long-term contracts which will protect them against future price increases in the costs of its
raw materials. Opposition to this idea is expected  from the governmental  agencies which
would be forced to pay the increased costs under such a contract.

     Complexities in the current pricing guidelines for the oil industry have also disturbed
the traditional pricing practices of the  industry.  Because of the supply problems in the oil
industry, suppliers of asphalt cement in several locations are refusing to take  new customers.
Under current pricing guidelines the cost of asphalt cement at  the  refinery may  vary as
much as  $20 per ton between suppliers.  The  paving plants which have  been supplied
traditionally by the refineries whose prices are currently high are unable to buy  the product
from  the  lower-cost refineries. Consequently,  they are  at a  severe pricing disadvantage
vis-a-vis the producer  who may  continue to   purchase  his  asphalt cement  from  these
lower-cost refineries.

B. PROPOSED EFFLUENT LIMITATIONS, TECHNOLOGIES AND COSTS

     The  proposed  effluent  limitations for  the asphalt paving  industry   are  detailed  in
Tables 1-27 and 1-28 and have been described by the Guidelines contractor as  follows:

     "Asphalt Emulsion Plants.

     "Best Practicable Control Technology Currently Avaiable.
                                          41

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                                   TABLE 1-27

            EFFLUENT LIMITATIONS FOR ASPHALT EMULSION PLANTS
                                (6000 tons per day)
Best Practicable Control
Technology Currently
   Available

Best Available Technology
Economically Achievable

Standards of Performance
for New Sources
    Suspended Solids*
   30-Day      Maximum
   Average        Daily
  lbs/1000     lbs/1000
     gal           gal
    0.125
    0.125
0.188
0.188
                                                                Oils and Grease*
                                                                        Maximum
                                                                          Daily
                                                                        lbs/1000
                                                                           gal
not regulated  not regulated    0.125
0.083
0.083
                          0.167
0.125
                          0.125
Note: pH within the Range of 6.0-9.0

*Data based on containment of runoff from an average plant site of 10 acres with an average
 rainfall of 3 inches per day, or 0.800 MGD. The limits are also based on weight of pollutant
 per volume of runoff water.

Source:  Development Document.
                                    TABLE 1-28

            EFFLUENT LIMITATIONS FOR ASPHALT CONCRETE PLANTS
           (Capacity 1600 short tons/day; Production 600 tons/day for 188 days)

                                                         Suspended Solids
   Best Practicable Control
   Technology Currently Available

   Best Available Technology
   Economically Achievable

   Standards of Performance
   for New Sources
   Note:  recycle is equivalent to no discharge.

   Source: Development Document.
                                                 30-Day Average
                                                     Ib/ton
                      Recycle
                                    Maximum Daily
                                         Ib/ton
                       Recycle
                                                     Recycle
                                        Recycle
                                        42

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     "All runoff from the plant production area should be collected and treated.  Installa-
tion and operating costs that would be incurred at a typical size plant, one having a 6,000
short ton per day capacity, are presented in Table 11.*  The production area is assumed to
cover 10 acres. The production area is defined As that area in which the oxidized asphalt and
asphalt emulsions are produced and from which they are shipped. It was also assumed that
the most rain that would fall during a 24-hour period is three inches. It was further assumed
that a peripheral collection system is necessary and  that a gravity separator  is needed to
treat the runoff.

     "Best Available  Technology Economically Achievable.

     "BATEA for the  asphalt emulsion  plant  consists of a sedimentation  basin where
additional removal of oils and suspended solids can be  achieved.  The incremental  costs of
achieving BATEA are shown in the second column of Table 11."

     Pretreatment standards for new emulsion  plants would be similar in technology and
cost to BPT standards  for oil and grease; those for existing  sources,  if they were to  be
proposed, would be considerably less stringent.

     "Asphalt Concrete Plants

     "Best Practicable Control Technology Currently Achievable (BPCTCA).

     "BPCTCA (identical to BATEA) calls for settling the wastewaters in an earthen stilling
basin, removal  and  disposal  of the settled solids and subsequent recycling of the water.
Typical costs are presented in Table 12."

     The proposed Guidelines will apply only to those existing plants that have elected to use
wet processes in the  control of particulate emissions, or those new plants which  choose to
do so. As mentioned earlier, approximately 25% of the existing plants use a dry process for
particulate control, and  therefore will not be affected by the proposed effluent Guidelines.
It  is projected that virtually all new plants will use the dry, or "baghouse," process for
particulate control.  The primary  concern  in this impact  analysis, therefore, will be the
approximately 3,600 plants which are equipped with wet process control equipment.
    Tables 11 and 12 (as revised) are contained in the Development Document and are reproduced here in
    Tables I-29 and I-30.
                                         43

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                                      TABLE 1-29

                 TREATMENT COSTS FOR ASPHALT EMULSION PLANTS
                             (6,000 short tons x 250 days/year)

                                                 	Technology Level
                      Type of Cost                 BPT      BAT*      NSPS

          Total Investment                         $73,290   $80,790   $72,000
          Total Operating Maintenance and Energy      1,440     2,165      1,440
          Total Annual**                           16,098    18,323     15,840

          Cost Per Short Ton                         0.011     0.012      0.011

           * Cumulative costs incurred after BPT has been achieved.

             Includes operation and maintenance, energy, and capital cost amortized at
             15% discount rate over 10 years (factor of 0.2). 15% was chosen as a cur-
             rent cost of capital for the industry, although it may vary significantly by
             plant depending on ownership pattern. The effect of any change in the
             rate is insignificant for this analysis.

          Source:  Development Document.
                                     TABLE 1-30

               TREATMENT COSTS FOR ASPHALT CONCRETE PLANTS
                                (BPT, BAT and NSPS)

     Type of Cost                                   Plant Size*
                                 Small               Average               Large
                          (1000 short tons/day)  (1600 short tons/day)  (2500 short tons/day)

Investment                       $4,600              $ 5,550               $  6,400

Total Operating, Main-
tenance and Energy                7,075                9,365                12,925

Annual Cost                      7,995               10,475                14,205

Cost per Short Ton**              0.113                0.093                 0.081

 * Annual production assumed at 188 days/year, 3 hours/day.
**Includes operation and maintenance, energy, and capital cost amortized at 15% discount rate
  over 10 years (factor of 0.2). 15% was  chosen as a current cost of capital for the industry,
  although  it may vary significantly by plant depending on ownership pattern.  The effect of
  any change in the rate is insignificant for this analysis.

Source:  Development Document.
                                        44

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C.  ECONOMIC IMPACT ANALYSIS

1.  Price Effects

     a.  Emulsions

     Presuming  that the incremental costs of meeting proposed effluent limitation Guide-
lines are passed through directly to the customers of this  sector of the industry, with a
markup on the increment sufficient  for the sector to retain its historic level of profitability,
the effect of BPT Guidelines will be to increase the selling price of asphalt emulsions by
0.03% for the average sized plant. This increase is based on a current selling price of $63.45
per short ton (based on 250 gallons/ton) and an incremental annual cost of approximately
2i per ton. This percentage will not vary significantly by size of plant. It is felt that such a
minimal pass-through of costs will be easily accomplished in this sector, and that, therefore,
the economic impact will be negligible.

     b.  Asphalt Concrete

     Presuming  the  same pass-through  of costs and retention of current returns on net
assets, the effect of BPT Guidelines  will be to increase the selling price of asphalt concrete
by  1.2% for the average sized plant. For the smaller plants (1,000-short-ton-per-day capacity
or less) the increase will  be slightly higher,  or  1.5%.  These percentages are based on an
average selling price of $8.00 per short  ton, and incremental costs of 9.3^ per ton  for the
average sized plant and 11.3^ per ton for the smaller plants (Table 1-30).

     Such price increases could have two types of economic impact on the asphalt concrete
sector. For  the  sector as  a  whole, any price  increases could place its product at a relative
disadvantage with  competing paving materials (primarily concrete).  Within the sector, the
higher relative costs to the smaller plants could  make their  products less competitive with
those of larger plants which serve the same market area.

     The first  type of impact, a possible shift in  market share between asphalt concrete and
Portland cement concrete, should be minimal for a  number of reasons. First, the wearing
course material of a road or highway is only one component of the total installed cost of the
surfacing. A 1% increase in the cost  of asphalt concrete would increase the installed cost of
asphalt  concrete paving  by  approximately 0.4% because the  base  course cost  and labor
content of the finished surface would not be affected.  Thus,  the maximum shift in the
installed cost of an asphalt concrete  surface under the proposed Guidelines for a 1,000-ton-
per-day plant (11% of the industry as demonstrated in Table 1-10) would be 0.6%. Second,
as discussed previously, the effect of current high interest rates is to mitigate the longer term
benefits of PCC. Furthermore, the surfacing material for a highway is chosen primarily on
the basis of product preference and materials availability rather than price.
                                         45

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     Hence, it is  felt that such an increase in relative price will not cause any shift in the
market  shares  of asphalt  concrete  and  Portland  cement  concrete. Moreover,  Portland
cement concrete plants also have air and water pollution problems, the incremental cost of
control  tending to mitigate any effect of  the proposed Guidelines on the asphalt concrete
industry. Air emission control costs alone  have added an estimated 4% to the average selling
price of cement. Finally, the cement industry, perhaps one of the most adversely affected
by the price and wage controls, has increased  selling prices by an average of 23% since the
controls were lifted  in November, 1973,  to August, 1974, in an  attempt to improve their
profits.

     The second type of impact, a shift in prices within the industry vis-a-vis the larger and
smaller plants,  will have some significance. While,  because of the effect of transportation
costs, smaller plants located  in remote  market areas are not likely  to be impacted, plants
located in metropolitan areas which may be served by a number of establishments will be. In
areas where contractors have a number of sources of supply, price competition within the
sector may be severe. The effect of the proposed Guidelines will  be to make certain plants
(those not using baghouses and especially  the  smaller plants not so equipped) less competi-
tive. However, again  because  of the effect of transportation costs, which limit  potential
market encroachments,  this shift in relative prices  will be mitigated. A small  number of
marginal plants (10-15) may be forced to  close as a result of the  proposed  Guidelines, but
the more  prevalent effect will be  to  reduce slightly the effective market  radius of those
plants most affected.  In those market areas where a  number of competitors exist, therefore,
there could conceivably be some shift in market share from those smaller plants which must
meet the Guidelines, to the larger plants.

     The potential magnitude of this effect can be estimated as follows. Of the 4,750 plants
in this  sector, approximately 25% are  equipped  with  dry process particulate control
procedures, and therefore, will  not be economically affected by the Guidelines. Of the
remaining  3,600 plants,  the NAPA  estimates  that  all  are equipped with wet control
processes. Of these, 85%, or 3,100 plants, already settle and recycle  their process water and
are, therefore, in compliance with  the Guidelines. Of the remaining 500 plants that will be
affected by the Guidelines, the NAPA estimates the great majority are in non-urban  areas;
most plants in metropolitan areas find it necessary (and in some cases economic) to recycle
their process water to meet  local  standards of effluent control and to reduce  the cost of
process water to them. There is no available data on the size distribution of the 500 plants
which do not currently meet the proposed  standards.

     Plants in  non-metropolitan areas can be expected  to be far less impacted by the
Guidelines because of the relative lack of intra-industry competition in their market  areas.
The minority of plants in metropolitan areas that do not recycle their process Water may be
affected, but this effect is not expected to be major. As discussed previously, the maximum
effect on  prices of the Guidelines is expected to be slightly over 1% of average selling prices,
or 11.3^ per short ton. With shipping costs averaging 13^ per ton per mile, the reduction in
                                         46

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effective market radius in the worst case would be less than one mile. The theoretical effect
on these smaller plants may be estimated as follows. If the incremental costs were passed on,
the effective theoretical reduction in market radius of a small plant with an initial market
radius of 10 miles would be 16.7%, presuming market conditions of perfect equilibrium and
constant geographic density.

     In  the extreme case, where this might have an effect, a small plant could absorb the
1.4% cost, and operate at a reduced level of profitability, for those specific projects, without
endangering the firm's existence. Under the theoretical small plant described above, with an
effective market radius of 10 miles and operating under a state of perfect equilibrium, this
1.4% absorbtion of costs would  occur only at the limit of its effective market radius. In the
inner 83.3% of its market, where the effect of transportation costs are such that it  may pass
on the incremental costs without loss of market share, there would be no economic impact.
In the outer 16.7% the amount  of costs needed to be absorbed would  range from 100% at
the perimenter of the marketing radius to 0% at  the point where transportation costs and
incremental price are equivalent. A simplifying assumption would be that over this range the
plant, on average,  would have to absorb 50% of the  incremental cost. The overall  effect on
profitability would therefore be slightly more than .1% of sales (a reduction of 1.4% x 50%
for 16.7% of the market area).

     Under this theoretical analysis, it would be reasonable to assume that there would be
no measurable economic impact on the asphalt concrete industry as a result of the proposed
guidelines.  However,  there  are  likely  to  be exceptions to this theoretical model.  Small
metropolitan plants which must meet the  guidelines, and whose effective market areas may
include  important segments at  the  perimeter  of the radius,  will probably be subject to
intense competition from one or more other plants. In such cases, the effective market share
lost  if costs are passed  on, or the effective  loss of profits  if costs  are absorbed may  be
substantial.  In  some cases, historical  links between suppliers and customers may override
purely economic  factors. While  lack of  precise  data on each of the 4,750 plants makes it
impossible  to determine what number of plants might fall  in  this  category, it  is highly
unlikely that there would be more than 10-15.

     A possible determinant as to which plants may  close would be the ownership pattern
of the plant. Owner-operated plants, with  less access to  capital, might close for this reason,
although the  psychological involvement  of the owners will  resist such  closure.  Plants
attached to large diversified corporations,  while having greater access to capital, will also be
more inclined to view  the closure situation  in purely economic terms.

     The secondary price effects of the incremental cost of the proposed Guidelines will not
be significant. Just as asphalt concrete  and emulsions are only a portion  of the installed
costs of a  paving  surface, so  the paving  surface  is only a portion of  the  total cost of a
highway, road, runway, parking  lot, etc.  The percentage increase in the total cost of any
such project occasioned by the increased costs of the proposed Guidelines will in all cases be
far less than 1%.
                                         47

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2.  Financial Effects

     If, as has been concluded in the previous section, the incremental costs are passed on as
price increases while current returns on net assets are maintained, there will, by definition,
be no effect on profitability of the plants in the industry. If, such cost pass-through is not
possible, however, or it cannot be done in full, the theoretical impact of cost absorption on
profits should be evaluated.

     The asphalt paving industry operates at a relatively low level of profitability. Although
the average  plant  is estimated to earn 4% after tax  on net sales and  8% on net assets, the
levels of profitability for  individual  plants  may range  from 10 to  15%  for the most
profitable, to breakeven or loss situations for some  establishments. For a small plant  with
average profitability, the theoretical 0.12% increase in costs calculated  above would reduce
the level of after-tax profitability by a minimal amount (2.3%) to a level (3.9% on sales) the
effect of which is  not measurable. Those  plants operating at marginal levels, and that might
suffer an effect greater than that of the theoretical plant,  such as increase in costs without
corresponding price increases, might be forced to close prematurely.

     Industry projections are  that the next  decade will see a shakeout  of the  marginal
plants, which  have been able to survive only because of the continually expanding nature of
the paving business.  As the  interstate highway system  nears  completion,  and  the  total
volume of the industry stabilizes below recent high levels, it has been projected that as many
as 500 plants will cease operation,  for  reasons  totally  unrelated  to  the costs  of water
pollution control.  The effect, therefore, of the proposed Guidelines may be to cause 10-15
plants  to close by 1977. Plants which are  now marginal  and foresee  closure in  the  near
future  for market  or other reasons may close prematurely, rather than invest the effort and
capital for effluent treatment and control. In summary, while the industry as a  whole should
have little difficulty in passing on the  costs of pollution control, a small number  of plants
may choose the route of closure, within the next two years, prior to the establishment of
the Guidelines.

     A  second concern in this area is the ability of the industry to raise capital for  general
purposes over the long term, and,  in  the short  term,  for purposes directly related to the
installation of effluent control processes.  For the asphalt concrete segment, the incremental
cost of meeting the guidelines is so minor (see Table 1-30) that most firms will be  able to
fund the improvements from internally generated cash. As mentioned above, however, some
marginal firms in  the industry, foreseeing a decline  in their business, may choose to cease
operations at certain locations rather  than  expend  even  the  $7,000 required for effluent
control. As it is assumed that virtually all firms will be able to recover the incremental  costs
of meeting the guidelines, there should be little impairment of the industry's ability to raise
capital for general  purposes.
                                          48

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     In the emulsions sector, the initial capital required to meet the proposed guidelines is
proportionately  higher. However, given the bright outlook for this segment, discussed
earlier, and the ability of the sector to increase its prices to cover the amortization of the
initial capital  and annual operating costs, it is felt that  the effluent control procedures
required by the guidelines will be financed without difficulty.

3.  Production Effects

     Because  the  costs of  implementing  the proposed  guidelines are not  expected to
occasion any significant shift in the market share of asphalt paving  products, there will be
no resulting effect on industry production. As mentioned  previously, however, the costs in
the asphalt concrete  sector may  accelerate the trend towards slightly greater concentration
in  a highly unconcentrated  industry. Finally, because the industry  currently operates at a
low  level  of  capacity utilization (35-40%), no effective  loss  of  supply  will occur.  No
production effects will occur in the emulsion sector.

4.  Employment Effects

     The direct effects on total employment in the asphalt paving industry from implement-
ing the Guidelines will be minor, with  a maximum of 50 employees affected (based on 15
plants, 3.2 employees/plant). Because the closures will be exclusively in metropolitan areas,
no  community impact is anticipated, and affected  employees should easily be reabsorbed
into the labor force. In general,  however, employment in  the industry can be expected to
decline over the next decade, primarily because of the increasing  use of automated plants,
and little or no market growth.

5.  Community Effects

     No community  effects are  anticipated since very  few employees will be affected  and
they can readily be absorbed into the work force.

6.  Balance of Trade Effects

     The international trade in asphalt paving products is precluded  by transportation costs
and technical feasibility. Consequently, there will be no effect on the U.S. balance of trade
from the proposed guidelines.
                                         49

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PART II: ASPHALT FELTS AND COATINGS
             (SIC 2952)

-------
                    PART II: ASPHALT FELTS AND COATINGS
                                     (SIC 2952)

A. INDUSTRY STRUCTURE

1. Products and Demand

     a. Products

     SIC 2952 includes a variety of products, all employing asphalt as one ingredient, used
to waterproof the exterior of a building structure: asphalt saturated felts, roofing asphalts
and pitches, strip  shingles, coatings, pitches, cements, and many others. Tar products are
now almost non-existent.

     The saturated felt products are used as a water barrier and can be classified as either
prepared roofings or built-up roofings. Both types are basically similar, each being made of a
structural felt or fabric framework, a soft asphalt saturant for the felt, and a relatively hard
coating on the surface  of the felt.  The felt is normally an organic fiber, although the use of
glass fibers is increasing.  Dry felt manufacture  takes place at  a  location that can eco-
nomically serve a number of strategically located  roofing plants, or that is located close to
or at an asphalt roofing plant itself. In the latter case, the plant's capacity is often related to
that of the roofing plant.

     Prepared  roofings are prefabricated  in roll,  strip,  or individual shingle  form and
represent  a complete  system, including  a colored  mineral  aggregate surface,  that can
normally  be applied  by  nailing  directly  to  the building's roof without the need for
additional materials or procedures. Built-up roofing consists of the saturated felt only, laid
in overlapping layers on the roof (with or without an emulsion  coat between layers) and
then covered with mineral aggregates. Prepared  roofings are  invariably on pitched roofs
while built-up roofings  are used on flat surfaces.

     Although the proposed effluent limitations Guidelines apply only to the roofing felts
and impregnated roofing felts  (and hence the economic impact analysis will concentrate  on
this segment), this SIC  category also includes a wide variety of other asphalt felt and coating
products that are made by the  same manufacturers, often in  the same facilities.  These
products principally include:

     •    Roofing asphalts  and pitches,  coatings, and cements; used in conjunction
          with built-up roofing as an adhesive between layers or as an adherent surface
          for the mineral aggregates.

     •    Smooth or mineral-surfaced roll roofing and cap sheets; employed at pro-
          trusions, junctions, edges and other non-standard locations on the roof.
                                         51

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     •   Asphalt building sidings; either in roll, shingle or board form.

     b.  Manufacturing Processes

     The manufacturing processes for the roofing felts and impregnated roofing felts have
been fully described in the Development Document. While it is not necessary to  duplicate
the description contained in that document, some general comparisons of the differences in
process economics will be useful.

     Four principal differences can be identified:

     1.   The dry felt used to manufacture asphalt roofing is sometimes produced in a
         mill located close to or at the same location as the roofing plant. These felt
         mills may  serve a specific roofing plant  exclusively, serve a number  of
         regional roofing plants owned  by the same company, or produce  felt on a
         merchant basis for general sale. When the felt mill  is located next  to the
         roofing plant (this  occurs  in about 40%  of the  cases)  the production
         processes  and physical location of the equipment are entirely separate but
         the  two operations may expel their process water into  the same effluent
         stream.

     2.   After  the  felt  sheet has been saturated, coated, and the mineral surface
         applied, it will pass through a looper whose function it is to cool the sheet to
         a point where it can be cut and packed without damage to the material. The
         hot  sheet is cooled either by splashing water or by spraying a fine water jet
         on it. The  amount of water used in this cooling procedure can  thus  vary
         from .03 to 10.1 gallons per square foot of sheet surface.

     3.   Depending  on whether shingles or roll  roofing are being made, the  cooled
         material is fed from the finish looper either to the shingle cutting machine or
         to the roll roofing winder for further processing before packaging.

     4.   Some roofing plants, especially the more recently equipped ones, Will them-
         selves oxidize the  residues from the crude petroleum distillates to manu-
         facture the asphalt used in the roofing production process.

     c.  Production  and Shipments

     Shipments of  asphalt felts  and  coatings in SIC 2952 have shown steady and almost
uninterrupted growth over the  past  decade,  increasing from  $459.5 million in 1963 to
$877.1  million in 1972, an annual rate of better than 7% (Table II-l).  Of the totals, a small
amount  of  annual  sales represented  products that could  not reasonably be  classified as
asphalt  felts and coatings. For example, secondary sales of $104.8 million in 1967 were
                                         52

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included in the  aggregate  sales for SIC  2952  ($597.8 million)  and resulted  from the
distribution of asbestos and from other miscellaneous income. On the other hand, other SIC
categories,  principally the paint industry, also manufactured and sold  $26.6 million of
roofing felts and coatings in 1967.

                                     TABLE 11-1

             TOTAL SHIPMENTS OF ASPHALT FELTS & COATINGS: 1963-1972
                                  (Millions of Dollars)

                               Felts and     Secondary    SIC 2952
                                Coatings       Sales*       Total

                        1963    459.5         68.1        527.6
                        1964    495.9         77.5       573.4
                        1965    511.1         73.9       585.0
                        1966    506.1         83.3       589.4
                        1967    519.4         78.4       597.8
                        1968    543.7         89.7       633.4
                        1969    589.9         64.8       654.7
                        1970    626.4         64.8       691.2
                        1971    825.9         53.9       879.8
                        1972    877.1        127.4      1004.5

                        *For example, asbestos products.

                        Source:  Bureau of Census, Annual Surveys and 1972
                                Preliminary Census of Manufactures.

     The principal products shipped  each year are asphalt and tar roofings  and sidings.
These  products represent roughly 75% of all group shipments each year and totalled $668.0
million in  1972 (Table II-2). The second most important category -  roofing asphalts and
pitches, coatings and cements- totalled  $153  million in that year, with the  remaining
products representing only $52 million. The value of shipments of asphalt roofings (not
including sidings) is  available  only  for  Census  years  but  totalled $312.1  million in
1967 - 60% of SIC 2952 felts and coatings - and $582.6 million in  1972 (66%).

     In quantitative terms, roofings and  sidings are shown either in short  tons or in squares
(100 square feet). Because the average weight per  square foot can vary from year to year
and  between products, the most equitable basis of comparison is  weight. Asphalt roofing
tonnage shipments totalled  89.7% of all  asphalt and tar roofing and siding products shipped
in 1972 (Table II-3),  with saturated felts  a further 9.6%  and asphalt siding and insulated
siding  less than  1%. Sales of asphalt roofing have grown at 6.2% per year on a tonnage basis
from 1963  to  1972. Shipments by geographic area in 1972 were as follows:
                                         53

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                       TABLE 11-2

      SHIPMENTS OF ASPHALT FELTS AND COATINGS
               BY PRODUCT TYPE, 1967-1972
                    (Millions of Dollars)
                 1967      1968     1969      1970     1971   1972
Asphalt and tar saturated felts
and boards for nonbuilding use 27.5 34.2
Roofing asphalts and pitches,
coatings, and cements 101.4 121.9
Asphalt and tar roofing and
siding products 375.2 385.8
Asphalt felts and coatings,
n.s.k. 15.3
Total 519.4 543.7
*Standard error of estimate greater than 20%
Source: Bureau of Census, Annual Surveys and Census
TABLE 11-3
39.1
142.4
406.8
1.6
589.9

17.2* 19.8 32
133.0 153.7 152,
464.6 638.5 668,
11.6* 13.9 23,
626.4 825.9 877.

.9
.7
.0
.3
,1

of Manufactures.



SHIPMENTS OF ASPHALT AND TAR ROOFING AND SIDING PRODUCTS, 1972
(Thousands)
United States, Total
Asphalt roofing, total
Smooth-surfaced roll roofing and cap
sheet
Mineral-surfaced roll roofing and cap
sheet
Strip shingles
Self-sealing
Standard or regular, total
Individual shingles
Asphalt sidings
Insulated sidings, all types and finishes
Saturated felts, total
Asphalt
Tar
No. of
Squares
99,094
97,696
22,274
13,193
59,295
52,117
7,178
2,935
136
367
895
859
36
Short tons
9,357
8,390
585
579
6,918
6,055
863
308
7
66
895
859
36













Source: U.S. Department of Commerce, Current Industrial Reports
       MA-29A(72)-1
                           54

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                       Northeast                      18.9%
                       North Central                  30.2
                       South                         37.9
                       West                          13.0

     Imports and exports have been at a very low level. Exports have ranged from $3.12
million to $5.76  million in the  period  1970-1972; imports,  from $0.63 million to $4.77
million. In each case, the proportion is less than 0.6% of domestic shipments. The nature of
the product  and the low value-to-weight ratio make it uneconomic to ship roofing products
over long distances and most trade has been with Canada.

     d. Markets and Future Growth

     Apart from about 2.5% of industry sales going to nonbuilding, principally automotive,
applications,  and a further 5% being used for building sheathings and sidings, the bulk of
industry shipments find an end market in roofing applications. It is estimated that 30% of
all roofing products in this industry sector is used for non-residential building construction,
with the remainder for residential roofing. Re-roofing of residential structures is an ex-
tremely important  segment  of  the market and has represented a load-leveling base for
industry  sales in  years when new  housing starts have been relatively low. Residential
re-roofing thus ranges from approximately 55% of all residential  roofing, in a good year for
new residential construction, to 75% in  an off year. While the variations are not quite so
dramatic in non-residential roofing, re-roofing  also represents about 65% of all roofing sales
to the non-residential segment.

     Companies manufacturing asphalt roofings find intra-industry competition more severe
than that with other materials. In residential construction, the only other significant roofing
material is that of wood  shingles  and  shakes, possibly  representing 10%  of all  residential
roofing sales and now enjoying a modest comeback as an architectural style with mansard
designs. Competition  for  asphalt roofings in non-residential  construction  includes a very
small amount (less than 5%) of hypalon and other rubber/plastic compounds, as well as a far
larger proportion of metal  roofs in farm and rural areas.

     Real growth of residential roofing products in the  period 1972-1980 will be affected
only moderately by the  small  increase  in  new housing starts anticipated over the same
period. Re-roofing of existing structures will allow the industry to maintain an annual rate
of growth of at least 3.5% over the remainder of the decade. Shipments of roofing products
to the  non-residential building sector will enjoy a faster rate of growth, approximately 4.5%
per  year, which  in part  is  a reflection of the better opportunities anticipated in new
non-residential construction.  Thus, overall growth of this industry sector should be close to
4% on a  weighted basis  to  1980. As  the  industry is now operating  at  or close to the
maximum effective capacity,  new plants or expansions of existing ones are a necessity.
                                         55

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     e.  Marketing and Distribution

     Roofing materials  are promoted through manufacturers' salesmen who serve whole-
salers in principal cities throughout  the  United States. Little or no marketing effort is
expended on direct  sales to  the architect, roofing contractor or homebuilder although all
three will rate  special attention on major projects and will be reached through advertising
campaigns, mailings,  trade shows and  specialist publications. Manufacturers tend to special-
ize  in prepared or in built-up roofing, and brand identification is prevalent in the former.
Purchasers of built-up  roofing  are relatively more price  conscious than those of prepared
shingles as the product is a true commodity and competition between contractors for new
or replacement work is strong.

     Roofing plants  are located close to or in heavily populated areas of the country and
thus manufacturers'  warehouses remote from  the plant  are seldom used for distribution.
Wholesalers and a few of the very large retail  dealers will handle an inventory but most
roofing  contractors  will purchase  on  a  project-by-project basis and  not invest in stock.
Manufacturing plants will serve a radius of 200-300 miles by truck in populated areas but
distances can be  greater than that  in less populated  regions. Roofing has a relatively low
value per unit weight and thus freight can make the  shipment uneconomic in competition
with other plant locations.  Published dealer price lists include an allowance for freight cost
but freight equalization takes place  when delivered price is quoted.

2.  Manufacturing and Ownership Profile

     a.  Plant Characteristics

     The  industry  is  comprised  of  approximately  233  manufacturing  establishments
throughout the United States, about 108 of which produce dry and saturated roofing felts
whereas  the remainder  concentrate on asphalts, coatings and cements.  Detailed data on
these facilities,  showing  typical  characteristics of  employment,  value added, cost of
materials, capital expenditures, etc., are shown in Table II-4 for 1963  to  1972. Figure II-1
graphically displays selected data from the operating profile. Some highlights of these data
include:

     •   Production workers represent about 72% of total employment.

     •   The average number  of employees per establishment was 67 in  1972; the
         ratio would be about 50% higher if only felt saturating plants were included.

     •   The value  added per man-hour of  production worker  has been  steadily
         increasing and totalled $16.64 in 1972, 72% higher than in  1967.

     •   The number  of man-hours worked remained fairly  constant at about 23.5
         million to 1971 but increased to 26.4 million in 1972.
                                        56

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                                                          TABLE 11-4

                                            SIC 2952 - INDUSTRY OPERATING PROFILE
Year
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
All Employees Production Workers
Year
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
Ratio
of Value
Added to
Shipments

.360
.361
.374
.384
.370
.381
.381
.370
.427
.437
Number
(000)
14.6
14.6
14.7
14.7
14.4
14.0
13.8
14.2
14.4
15.6
Ratio of
Inventories
to
Shipments

.082
.077
.073
.082
.071
.073
.073
.072
.062
.065
Payroll Number Man-Hours Wages
($Mil.) (000) ($Mil.) ($Mil.)
82.5 10.9
87.1 10.9
89.2 11.0
91.3 10.7
96.3 10.4
102.8 10.1
109.5 9.9
114.8 10.2
127.8 10.4
147.6 11.2
Ratio of
Payroll
to
Value Added

.434
.420
.407
.403
.436
.426
.439
.442
.340
.336
23.0
23.8
23.5
23.0
22.9
22.9
23.3
23.0
23.7
26.4
Value of
Shipments
Per Prod.
Worker
($000)
48.4
52.6
53.2
55.1
57.5
62.7
66.1
67.8
84.6
89.7
57.3
61.3
65.3
65.8
66.2
70.8
75.5
78.3
87.3
102.6
Man-Hours
Per
Production
Worker
(000)
2.110
2.183
2.136
2.150
2.202
2.267
2.354
2.255
2.279
2.357
Value
Added
($Mil.)
190.0
207.2
219.0
226.3
221.1
241.5
249.2
259.9
376.1
439.4
Wage Per
Production
Worker
Man-Hour
($)
2.491
2.576
2.779
2.861
2.891
3.092
3.240
3.404
3.694
3.886
Cost of Value of Capital End-of-Year
Materials Shipments Expenditures Inventories
($Mil.) ($Mil.) ($Mil.) (SMil.)
339.0
364.7
364.3
366.1
373.8
394.3
404.7
431.5
508.0
571.0
527
573
.6 7.0
.4 8.7
585.0 10.9
589
597
633
654
691
.4 9.6
.8 8.8
.4 13.1
.7 8.8
.2 11.8
879.8 15.8
1004
.5 20.4
43.0
44.3
42.6
48.5
42.4
46.2
47.6
50.1
54.8
64.8










Value Added
Per

Prod. Worker
Man-Hour
($)
8.26
8.71
9.32
9.84
9.66
10.55
10.70
11.30
15.87
16.64












Index
of
Employment
(1967=100)
101.39
101.39
102.08
102.08
100.00
97.22
95.83
98.61
100.00
108.33
Index
of
Value Added
(1967=100)
85.93
93.71
99.05
102.35
100.00
109.23
112.71
117.65
170.10
198.73
Index
of
Shipments
(1967=100)
88.26
95.92
97.86
98.59
100.00
105.96
109.52
115.62
147.17
168.03
Source:  Bureau of Census, 1971 Survey and 1972 Preliminary Census of Manufactures.

-------
                                                              Millions of Dollars

                CD
                CO
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                              o
                                  NJ
                                  o
                                  o
o
o
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o
o
o
00
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       CD
       c
       c

       o_

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       CO
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                en
O
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                ro
                en
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-------
     •   The ratio of inventory to shipments has been decreasing.

     •   Capital expenditures totalled $20.4 million in 1972 (up from  $15.8 million
         in 1971), equivalent to $1 of added investment for $50 of shipments.

     Tables II-5 and II-6 show the general industry  statistics on a four-regional basis for
1967 and 1972. The North Central region, with 39% of total industry shipments, was the
most significant in 1967, but a larger proportion of facilities (33%) is located in the South
than in any  other  region,  and  that  region  represented the largest proportion (35%) of
industry shipments by 1972. Establishments were distributed as follows in 1967 by average
number of employees:

         9 employees or less - 55
         10-19 employees — 33
         20-49 employees — 46
         50-99 employees - 44
         100-249 employees - 42
         250 employees and over — 6

     In 1967, materials  and supplies  consumed by  the asphalt, felts and coatings industry
totalled $317.3 million, increasing to $495.4 million in 1972 (Tables II-7 and II-8).

     Roofing plants in this industry range  in size from 25,000 to 200,000 tons/year, with
the average at about 80,000 tons/year.

     b. Firm Characteristics

     Of the 226 establishments operating in 1967*  153 were multi-unit companies and 192
were public  corporations (Table II-9). The industry has traditionally been characterized as
one of family-owned companies with regional concentrations but a considerable number of
acquisitions and mergers have taken place over the past decade. For example, Bird & Son
acquired the West Coast facilities of Fiberboard Inc. in  1968; Jim Walter Corporation now
owns and operates  the five  roofing plants and associated  dry  felt  facilities of the Phillip
Carey Manufacturing Company, as well as the nine roofing plants and six dry felt plants that
were once part of the Barrett Company and itself is now a part of the Celotex Corporation;
Certain-teed Products Corporation operates nine roofing plants, including that of the B.F.
Nelson Company;  and  the GAF Corporation owns and  operates the previous Ruberoid
facilities.  The number of operating companies has decreased from 126 in 1963, to 115 in
1967 and about 100 today.
    1972 Census data on these characteristics are, as yet, unavailable.
                                         59

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                                                       TABLE 11-5

                                   GENERAL STATISTICS, BY GEOGRAPHIC AREAS:  1967
Establishments





ON
0



United States
Region
Northeast
North Central
South
West


Total
226

44
65
75
42
With 20
employ-
ees
or more
138

27
42
49
20
All Employees


Number*
14.4

2.6
5.6
4.7
1.5

Pay-
roll**
96.3

18.7
39.9
27.6
10.1
 'Thousands
**Millions of dollars
+Millions
                                                                Production Workers
                                                        Number*     Manhours+

                                                          10.4         22.9


                                                           2.0          4.4
                                                           4.4          9.7
                                                           3.0          6.6
                                                           1.0          2.2
          Value
          added by
          manufac-
Wages**    ture**
  66.2


  13.4
  29.2
  16.8
   6.9
221.1


 41.7
 89.1
 69.3
 21.0
Cost of
mate-
rials*^

373.8
  79.1
 139.8
 110.6
  44.2
Value of
  Ship-
ments*^

  597.8
  120.6
  230.8
  179.9
   66.5
 Capital
expendi-
 tures,
 New**

   8.8
   1.9
   3.2
   2.0
   1.7
Source:  Bureau of Census, 1967 Census of Manufactures

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                                                             TABLE 11-6
                                       GENERAL STATISTICS, BY GEOGRAPHIC AREAS:  1972
Establishments
United States
Region
Northeast
North Central
South
West
Total
233

41
67
80
45
With 20
employ-
ees
or more
139

20
44
54
21
All Employees
Number*
15.6

2.6
5.6
5.6
1.8
Pay-
roll**
147.6

26.6
54.2
48.2
18.6
                                                                Production Workers
                                                        Number*     Manhours+    Wages**
                                                          11.2         26.4        102.6

                                                            1.7          4.8         19.4
                                                            4.3          9.7         40.1
                                                            3.9          9.0         30.3
                                                            1.3          2.9         12.8
Value
added by
manufac-
 ture**
  439.4
   76.5
  149.5
  154.1
   59.3
Cost of
 mate-
rials*^
 571.0
 110.0
 193.4
 194.1
  73.5
Value of
  Ship-
ments*^
  1004.5
   185.6
   339.8
   347.2
   131.9
 Capital
expendi-
 tures,
 New**
  20.4
   3.9
   9.0
   5.4
   2.1
 * Thousands
**Millions of dollars
+Millions
Source:  Bureau of Census, 1972 Preliminary Census of Manufactures.

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                                  TAB LEI I-7

    MATERIALS CONSUMED IN THE MANUFACTURE OF ASPHALT FELTS AND
                               COATINGS, 1967
Material
Asphalt
Less than 200 penetration
200 and over penetration
Unsaturated roofing felts, other
construction paper and insulating board
Roofing granules
Sand and Gravel
All other
Total
Unit
1000 short tons
million barrels
1000 short tons
1000 short tons
1000 short tons
-

Quantity
3213.6
9.1
1535.3
1895.9
578.4
-
_
Delivered
Value*
64.5
27.6
81.9
47.9
3.1
92.3
317.3
*Millions of dollars

Source: Bureau of Census, 1967 Census of Manufactures.

                                  TABLE 11-8

     MATERIALS CONSUMED IN THE MANUFACTURE OF ASPHALT FELTS AND
                                COATINGS, 1972


                                                                      Delivered
             Material                          Unit         Quantity       Value*

Asphalt
   Less than 200 penetration                1000 short tons     4281.0        122.8
   200 and over penetration                 million barrels         12.8         41.1

Unsaturated roofing felts, other
construction paper and insulating board       1000 short tons     1524.3        124.6

Roofing granules                          1000 short tons     2730.8         77.0

Sand and Gravel                           1000 short tons      771.4          6.7

All other                                      -             -          123.2

     Total                                    -             -          495.4

'Millions of Dollars

Source: Bureau of Census, 1972 Preliminary Census of Manufactures.

                                     62

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                                                              TABLE 11-9

                           SELECTED STATISTICS FOR OPERATING MANUFACTURING ESTABLISHMENTS, BY TYPE OF
                            OPERATION AND LEGAL FORM OF ORGANIZATION FOR MAJOR INDUSTRY GROUPS AND
                                                          INDUSTRIES: 1967
O\




Asphalt felts &
coatings
Total
Multiunit
companies
Total
Single unit
companies
Total
Corporate
Noncorporate
Total
Establishments All Err
With 20
employ-
ees Num-
Total or more her*


226 138 14.4


153 114 12.4


45 24 1.9
192 136 14.2

6 2 .1
iployees Production Workers

Pay- Num- Man-
roll** her* hours* Wages**


96.3 10.4 22.0 66.2


84.4 9.2 20.3 59.6


11.4 1.2 2.6 6.3
95.2 10.3 22.7 65.5

.6 .1 .1 .4
Value
added by
manu- Cost of Value of
fac- mate- Ship-
ture** rials** ments**


221.1 373.8 597.8


192.5 336.3 532.0


27.5 35.6 62.9
218.6 370.3 591.9

1.4 1.7 3.0

Capital
expendi-
tures.
New**


8.8


7.8


(D)
(D)

(D)
         * Thousands
        **Millions of Dollars
         +Millions
        (D) Not Disclosed
        Source:  Bureau of Census, 1967 Census of Manufactures.

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     Despite these changes in industry structure, the concentration ratios have varied little
over the past decade. Currently,  the four largest companies  share approximately  38% of
industry shipments and the eight largest, 65%. About the same ratios existed in  1963 and
1967, with about 86% of shipments coming from the 20 largest companies and 97% from
the 50 largest.  Currently, the company with the largest total number of facilities in the
industry,  and  also  one  of  the larger  in  terms of market share, is  an independent,
privately-owned corporation,  the Lloyd A. Fry Roofing Company of Summit, Illinois. In
addition, a large number  of privately owned and operated companies are  still significant
factors in the industry in both the felts and coatings segments.

     c.  Industry Segmentation

     Plants manufacturing roofing felts and impregnated roofing felts utilize process water;
those producing roofing asphalts, pitches and cements do not. According to the Develop-
ment Document, the amount of water used does not depend on the size or age of the plant
but  on  the  type  of process employed  to  cool the saturated asphalt roofing felts. A
splash-type cooling process uses 250,000 gallons of water per day for an average production
of 500  short tons, as compared to 100,000  gallons per day  for a fine spray or  mist-type
cooling system.

     Treatment of the types of waste water generated at all these plants will apparently be
independent  of age  and geographic  location  but economies of scale are  a factor when
considering waste water quantities. Thus, smaller plants will face greater relative investment
and  operating costs for treatment technology; the Development Document has taken this
fact  into account in defining three different levels of operation (200, 500 and 700 tons/day)
in estimating these costs.

     Further differences in the investment and operating cost  structure occur in the roofing
industry depending on the existence, or not, of oxidation towers and on the  product mix at
a particular location. In the former case, the current value of assets could be higher; in the
latter, unit operating costs and selling prices are higher for prepared  roofing than for roll
roofing.

3. Financial Profile

     Manufacturing plants in  this industry vary considerably by size but even more signifi-
cantly by net asset value.  The oldest operating facility was built about 80 years ago and is
currently operated with  equipment at  least 30 years  old. Its  net  asset value  is thus
considerably  less than  $1 million; newer facilities have assets of up  to $6 million. The
average book  value for all 108  plants is about  $2.2 million. The construction  of a new
150,000-ton/year plant in 1974 would cost  less  than $3 million for a basic facility and as
much as $3.5-4 million for a plant without oxidation equipment, and $6 million  for one
that included oxidation  equipment, pollution control and rail facilities.
                                         64

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     The  income statement  for a  typical  plant  would  be  similar to  that  shown in
Table 11-10. A typical plant, with a daily capacity of 500 tons and net assets of about $2.5
million, will produce an average of 120,000 tons of roofing products each year. The average
net price  in  1973, after discounts and freight, was $80 per ton; the average for 1974 is
expected to be at least $90. In terms of both net profit after tax and returns on net assets, a
roofing plant is  a relatively  profitable  operation. A smaller plant concentrating  in the
production of roll roofing could achieve net returns on sales as high  as 10% as significant
operating efficiencies and a minimum of product spoilage is achieved. However, it should be
pointed out that on a discounted cash flow basis the return on investment for a new mill
will be considerably lower than the 15-20% for an existing facility and could be 10-12% at
today's cost of capital.

                                      TABLE 11-10

                      INCOME STATEMENT - TYPICAL PLANT, 1973*

                                                      %       $MM

                  Net Sales                              100       9.6
                    Cost of Goods Sold                    75       7.2
                    Operating Profit                       25       2.4
                    General, Sales and Admin. Expenses       15       1.4
                  Net Profit Before Tax                     10       1.0
                  Net Profit After Tax                       5       0.5
                  Return on Net Assets                   15-20       -

                  *Net Assets $2.5-3.0 million.

                  Source: Contractor Estimates.
     Consequently, risk  capital for a new mill is a serious problem for roofing companies.
Moderate capital requirements to improve existing facilities by modernization or by adding
environmental control equipment is highly likely but the expansion of existing facilities is a
much more complex question that involves the availability of dry felt, land utilization in
what normally is a constricted site,  regional competition, etc. If the  industry continues to
grow as anticipated, new facilities will be needed in the near future for the rapidly growing
regions of the United States, such as the South and Southwest. However, there is a definite
reluctance at this time to commit the required investments and the current shortages of roof-
ing materials may continue until the anticipated return on investment for a  new facility is
attractive enough.

     The time that this  will occur is difficult to assess because so many factors — prices,
demand, manufacturing  costs  and capital  costs— are  extremely volatile in  1974. Price
controls  have, in fact, created an artificial  situation in the industry. At  a time of strong
                                         65

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demand, prices were  not permitted to respond freely to market pressures and returns on
investment were less than might have otherwise been the case. As capacity utilization rates
now  reach  a maximum,  the  prospect of  the  current short-term  shortages'  becoming
extended  is a distinct possibility because the industry  has  not enjoyed sufficiently high
returns on new investment to attract new capacity. However, prices have increased rapidly
since  the  beginning of  1974 and, as long as costs exhibit  a  slower rate of increase and
demand remains high, those companies with  a favorable  debt-equity ratio are likely to add
capacity.

4. Prices and Price Setting

     Wholesale prices for prepared asphalt roofings, the only product for which such indices
are available, are  shown  in Table 11-11.  Actual prices have increased by a total of 40% from
1963  to 1972, and by 12% relative to the All Commodities Price Index (all this real increase
occurring in 1971-72). It  is notable that, despite the small proportion total consumption of
prepared asphalt  roofing represented by new residential roofing, the years of low housing
starts  1964,  1967 and  1970) depressed the price index, suggesting  that the new housing
increment is a significant marginal contributor to profit.
                                       TABLE 11-11

                 WHOLESALE PRICE INDEX FOR PREPARED ASPHALT ROOFING
                                        (1967=100)

                                        Actual    Relative*
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
94.9
93.7
98.0
102.6
100.0
104.0
105.8
101.8
126.5
133.4
138.3
100.4
98.9
101.4
102.8
100.0
101.5
99.3
92.2
111.1
112.0
_
                                 * Relative to the All-Commodities
                                  Price Index.

                                 Source:  U.S. Department of Commerce,
                                        Construction Review, April 1974
     Historically, the price for built-up  roofing (used principally on non-residential con-
struction) probably has been more stable than that for prepared asphalt roofing; although
the products are genetically similar, built-up roofing does not have the variations of color,
style, brand, etc., that is apparent with residential roofing materials.
                                         66

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     Manufacturers publish dealer price lists on a three-region basis — West, Mountain and
east  of the Rockies. These price  lists may contain 10 to 30 different  items  and will be
quoted on a per-square or per-roll  basis. Truckload or carload lots are usually shipped at full
list prices to dealer categories, such as cash-and-carry, building materials yards,  and some
contractors who carry  stock, but there is room for negotiation.  Wholesalers are eligible for
discounts of 5% plus 5% for the West and  Mountain regions and 7% plus 7% for east of the
Rockies. Individual manufacturers set their  own prices but with the severe intra-regional
competition, price lists are frequently similar and quotations can be equalized.

     Over the past year, manufacturers have been faced with considerable price increases for
basic raw  materials and have  had to revise price lists frequently.  For example,  recent
increases in the price of asphalt, from  $25 per ton in October 1973 to the current price of
nearly $80, have resulted in as many as three revised price bulletins in the same period and
all in compliance with Phase IV Wage and Price Control regulations.

B. PROPOSED EFFLUENT LIMITATIONS,  TECHNOLOGIES AND COSTS

     The Development Document has proposed effluent limitations for a typical plant using
150,000 gallons of process water per day and producing 500 short tons of product per day
(Table II-12).
                                       TABLE 11-12

                  EFFLUENT LIMITATIONS FOR ASPHALT ROOFING PLANTS
                                      (500 Tons/Day)
                                                        Suspended Solids*
         Best Practicable Control
         Technology Currently Available
         (1977)
         Best Available Technology
         Economically Achievable (1983)
         Standards of Performance
         for New Sources
                                                30-day Average     Maximum Daily
                                                 (lb/1000 Ib)       (lb/1000 Ib)
.038
.019
                                                    .019
.056
                 .028
                                                                     .028
         Note: pH within the range of 6.0 to 9.0
         * Limits are based on weight of pollutant per weight of product produced.

         Source:  Development Document.
                                         67

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     The majority of asphalt roofing plants are already removing part of the suspended
solids from their waste water before discharging it, or are discharging into municipal systems.
It is estimated that about 60% of facilities use municipal systems, 5% require BAT only, and
a further 35% require both BPT and  BAT. According to  the Development Document, per-
formance standards for new sources (PSNS) are the same as the pollution reduction achieved
by applying BAT technology and the costs are identical. The Guidelines contractor has thus
estimated the investment and annual operating costs for BPT and BAT conditions:

     •   At the majority of plants, large suspended materials are  settled in a pre-
         treatment type  pond or detention sump before the  effluent is discharged.
         BPT requires that all  plants employ primary settling.  The costs of BPT have
         been  developed for  situations in which either an earthern stilling basin is
         installed or a steel or concrete settling tank is used. It is assumed that both
         are cleaned monthly  by manual methods. It is also assumed that sprays or
         mists are installed to reduce the volume of waste water.

     •   BAT  requires that coagulants be used to settle out more suspended solids.
         Because larger quantities are settled out, the costs of applying BAT allow for
         expenses incurred in  having the resulting sludge removed continuously  and
         mechanically. It is assumed, therefore, that the earthen stilling basin which is
         acceptable under BPT is replaced by a settling tank.

     The treatment  costs  associated with  both systems for the average,  small and large
plants are shown in Tables 11-13, -14,  and -15.

C.  ECONOMIC IMPACT ANALYSIS

1. Price Effects

     Assuming  an average base  selling price  of  $80 per short ton of shipments,  the
incremental price increase that  would be required to maintain curent returns on net assets
and, at  the same  time, pass on  the costs of meeting BPT Guidelines would be equivalent to
the following:

                                            Earthen Stilling Basin        Tank
                                                     (%)                 (%)
     Small Plant (200 Tons/day)                        .06                 .23
     Average Plant (500 Tons/day)                      .04                 .11
     Large Plant (700 Tons/day)                        .04                 .10
                                         68

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                                        TABLE 11-13

                     TREATMENT COSTS - ASPHALT ROOFING PLANTS
                          (Small Plant - 200 tons/day x 250 days/year)

                         Type of Cost               BPT      BAT*      NSPS
                                                   (1977)    (1983)
                                                   (Earthen Stilling Basin Solution)
              Total Investment                      $ 3,500   $40,500    $N.A.
              Total Operating, Maintenance & Energy     1,075     7,750     N.A.
              Total Yearly**                         1,775     15,850     N.A.
              Cost/Short Ton                           0.04       0.32     N.A.

                                                        (Tank Solution)
              Total Investment                       20,000    37,000    37,000
              Total Operating, Maintenance & Energy     1,100     5,250     5,250
              Total Yearly**                         5,100     12,650     12,650
              Cost/Short Ton                           0.10       0.25      0.25

       'Cumulative costs incurred after BPT has been achieved.
      **lncludes operation and maintenance, energy, and capital cost amortized at 15% discount
         rate over 10 years (factor of 0.2). 15% was chosen as a current cost of capital for the in-
         dustry, although it may vary significantly by plant depending on ownership pattern. The
         effect of any change in the rate is insignificant for this analysis.

      N.A. — Not applicable

      Source:  Development Document and Guidelines Contractor
     The equivalent selling price increases to meet BAT and NSPS treatment requirements
would be:

                                               Earthen Stilling Basin         Tank
     Small Plant (200 Tons/day)                          .58                   .49
     Average Plant (5 00 Tons/day)                        .33                   .30
     Large Plant (700 Tons/day)                          .30                   .26

     These  price  increases,  due solely  to  the effects of achieving effluent  limitations by
1983,  must be evaluated against price increases for asphalt roofing materials that averaged
4% in  1973 and up  to 10% in the first five months of 1974. While  a plant can obviously
choose to absorb  some or all of the incremental costs, it is concluded that full costs will be
passed through and that the  resulting price increases will be achieved by an industry that has
                                            69

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                                        TABLE 11-14

                      TREATMENT COSTS - ASPHALT ROOFING PLANTS
                          (Typical Plant — 500 tons/day x 250 days/year)

                         Type of Cost                BPT      BAT*     NSPS
                                                   (1977)    (1983)
                                                   (Earthen Stilling Basin Solution)
              Total Investment                      $. 5,125   $55,125    $ N.A.
              Total Operating, Maintenance & Energy     1,700    12,075      N.A.
              Total Annual**                         2,725    23,100      N.A.
              Cost/Short Ton                          0.02      0.18      N.A.
                                                         (Tank Solution)
              Total Investment                       24,000    53,500     53,500
              Total Operating, Maintenance & Energy     1,910     9,690      9,690
              Total Annual**                         6,710    20,390     20,390
              Cost/Short Ton                          0.05      0.16       0.16

        *Cumulative costs incurred after BPT has been achieved.
       **lncludes operation and maintenance, energy, and capital cost amortized at 15% discount
         rate over 10 years (factor of 0.2). 15% was chosen as a current cost of capital for the in-
         dustry, although it may vary significantly by plant depending on ownership pattern. The
         effect of any change in the rate is insignificant for this analysis.

       N.A. — Not applicable

       Source: Development Document.
enjoyed favorable returns on current net assets and a steady increase in market growth over
the past few years. In addition, the short-term capacity shortage situation and concomitant
price increases will reinforce the industry's ability to pass on BPT costs. Even allowing for
the  normal economies  of scale in treatment costs that work to the advantage  of larger
plants, the price  impact  on the smaller facilities  will still be relatively insignificant and
passed on, along with other cost increases.

2.  Financial Effects

     Although it is a very unlikely possibility, one  can assume that prices are not increased
and  that  the incremental  costs of effluent pollution control,  rather  than  being passed
through, are absorbed. The  resulting effect on profitability would be a maximum reduction
in  net profit after tax of $23,100 (average plant; earthen stilling basin solution; BAT) on an
average profit of $500,000 for the typical plant. In other words, the maximum reduction in
the return on current net assets would be about 0.8% on a base of 15-20%.
                                            70

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                                        TABLE 11-15

                      TREATMENT COSTS - ASPHALT ROOFING PLANTS
                           (Large Plant - 700 tons/day x 250 days/year)

                         Type of Cost                BPT      BAT*     NSPS
                                                   (1977)     (1983)
                                                   (Earthen Stilling Basin Solution)
              Total Investment                      $ 7,500    $67,500    $  N.A.
              Total Operating, Maintenance & Energy      2,125     16,625      N.A.
              Total Yearly**                          3,625     30,125      N.A.
              Cost/Short Ton                          0.02       0.17      N.A.
                                                        (Tank Solution)
              Total Investment                       30,000     62,000    62,000
              Total Operating, Maintenance & Energy      2,750     12,100    12,100
              Total Yearly**                          8,750     24,500    24,500
              Cost/Short Ton                          0.05       0.14       0.14

               'Cumulative costs incurred after BPT has been achieved.
              **Includes operation and maintenance, energy, and capital cost amortized at
                15% discount rate over 10 years (factor of 0.2). 15% was chosen as a cur-
                rent cost of capital for the  industry, although it may vary significantly by
                plant depending on ownership pattern. The effect of any change in the rate
                is insignificant for this analysis.

              N.A. — Not applicable

              Source:  Development  Document  and  Guidelines  Contractor
     Capital availability to meet the effluent control requirements should also present no
problem.  The total cumulative investment  required  by the average-sized roofing plant by
1983 is $55,000, equivalent to about 2.5%  of the net asset value for the average plant, and
that for the largest sized plant, $67,500. By  way of comparison, annual capital expenditures
by  the industry over  the past five  years  averaged  $14.5  million ($135,000/plant)  and
totalled $20.4 million in 1972. For the 108 plants in the United States that produce dry and
saturated  roofing  felts,  the  total  capital investment required  by  1983  aggregates to
approximately  $3.5 million, in comparison to the initial capital investment of $6 million
required  to construct a 600-ton-per-day plant equipped  with oxidation, pollution control
and rail facilities.

     It  is  concluded  that the  capital requirements to  implement  the effluent control
regulations  are entirely reasonable and well within the capabilities of the industry and its
individual companies to provide. No economic impact is anticipated as a result.
                                            71

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3.  Production Effects

     The current level of production and the future rate of growth of the asphalt roofing
industry  probably will  not  be affected by the implementation of the proposed effluent
control Guidelines.  No  plants will be forced to close or to reduce their current  level of
operation.

4.  Employment Effects

     No  employment effects will result from the proposed effluent limitations Guidelines.

5.  Community Effects

     No  community effects are anticipated from the proposed effluent limitations Guide-
lines.

6.  Balance of Trade Effects

     The current relationships between export and import of asphalt roofing materials will
not be altered as a result of implementing the proposed effluent limitations guidelines.
                                         72

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PART III: ASPHALT-FELT BASE FLOOR COVERINGS
                (SIC 3996)

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               PART III:  ASPHALT-FELT BASE FLOOR COVERINGS
                                     (SIC 3996)

A.  INDUSTRY STRUCTURE

1. Products and Demand

     a.  Products

     The generic description of SIC 3996 products is "Linoleum, Asphalted Felt-Base, and
Other Hard Surface  Floor  Coverings, Not Elsewhere Classified."  Included within the full
classification are the following products:

     •   Carpets, asphalted-felt-base (linoleum).
     •   Floor coverings, asphalted-felt-base (linoleum).
     •   Hard surface floor coverings, expect rubber and cork.
     •   Linoleum
     •   Tile, floor: supported plastic

     This floor covering product mix may be divided into three major categories: tile, inlaid
sheet, and  non-permanent  sheet. While the first two were traditionally installed  with an
adhesive, a study of the market indicates that almost all asphalt-based floor products are
considered  by consumers to  be "temporary flooring" and  are not affixed by  a mastic or
adhesive. This attitude may  be associated with the relative short product life expectancy and
low product price.

    Tile is usually supplied in squares of specific sizes (usually in 9" x 9" to 12" by 12");however
rectangular and diamond patterns are available in the market in small amounts. Linoleum
and rolled goods are  available in 6', 9', and 12' widths. Some linoleum and rolled products
are manufactured with a border on two sides, while others have no border.

     This analysis is concerned solely with plants engaged in the production of linoleum and
asphalt  printed felt floor coverings,  since  effluent limitations guidelines are being written
solely for those segments of SIC 3996.

     Linoleum may be characterized by a relatively thick wearing surface, extending to a
backing of burlap, cotton  fabric, or felt. Although  there are many chemical compound
matrixes, only printed asphalt felt material has been analyzed.

     Asphalt printed  felts are not considered true linoleums by manufacturers, but are sold
under the generic name of linoleum. Substitute  inlaid  sheet products which  have almost
completely  replaced  the asphalt felt-based "linoleum"  are  solid vinyl (PVC polyvinyl
chloride sheet) and cushioned-back solid vinyl (not permanently affixed by adhesive).
                                        73

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     b.  Manufacturing Processes

     The manufacturing processes have been described in the Development Document and
no further treatment will be given here.

     c.  Production and Shipments

     Shipments of  all products in  SIC 3996 (Table III-1)  have increased moderately in
recent years at about 2%/year in current dollars, 1958-1971, and with an additional 32%
increase  to  1972.  Research  suggests that there has been a  dramatic decrease in the
production of the asphalt-based floor products under consideration and a commensurate
increase in shipments  of other products, such as supported plastic tile, included within the
sector.

                                     TABLE 111-1

              VALUE OF SHIPMENTS OF HARD SURFACE FLOOR COVERINGS
                                 (millions of dollars)
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
181.6
206.5
183.8
179.7
191.3
204.1
217.6
227.8
230.3
221.7
230.3
235.1
232.6
258.8
341.5
                Source:  U.S. Bureau of Census; Annual Surveys and Censuses of Manufactures.


     According to Poor's Register, 13 manufacturing companies are listed under SIC 3996
with the Census Bureau identifying 18 establishments operating in  1972. However, inquiries
revealed  that most smaller companies have discontinued manufacturing asphalt-based floor-
ing or have been acquired by larger multi-line flooring manufacturers. Research indicates
that only one manufacturing facility (that of Armstrong Cork) manufactures asphalt-based
linoleum flooring and this plant is gradually being phased out of production and converted
to vinyl flooring production. A similar reduction  in production is apparent for asphalt
printed felts, with only two companies (Carthage Mills, Cincinnati, Ohio and Mannington
Mills, Salem, New Jersey)  still in production. Shipments of asphalt-felt-base and linoleum
floor coverings declined from $30.8 million in 1967, to $15.1 million in 1972.

                                          74

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     d.  Markets and Future Growth

     The market for asphalt-based flooring products derives from a very limited demand for
an extremely  low-cost product  having  short  life  expectancy.  This mass market may  be
characterized as the "bottom of the line" segment and  represents a very minor (2-3%)
portion of the total flooring market. Apparent historic demand has come from economically
deprived areas (rural,  especially in the Southeast) and from  inexpensive second home
dwellings, etc. This demand is expected  to become non-existent  within about three years as
consumer acceptance of vinyl and vinyl asbestos flooring increases. Lower costs resulting
from economies of scale  and technical innovations for competing products will help  to
eliminate demand  for  asphalt-based flooring.  Furthermore, the price of refined  asphalt
feedstock has increased considerably recently and the feedstock  is in short supply, thus
increasing the  relative cost  of  asphalt  flooring.  Consequently,  asphalt's single  market
advantage, low cost, is  rapidly disappearing and with it the only justification for continued
significant production of the product.

     e.  Marketing and Distribution

     The product is not marketed aggressively and no significant  advertising or promotion is
discernible, except as a  store attraction.

     Distribution patterns, where demand exists, are dictated by analogous product flow.
Batch-run quantities produced by local  asphalt specialities manufacturers are warehoused
and  shipped (usually locally) when demand  requires. The product  is  marketed  mainly
through  retail  outlets  as  a  "bottom-of-line"  commodity. Since  consumers identify  the
product as  a "temporary" flooring product,  it is being  replaced gradually by low-cost
carpeting.

2.  Manufacturing Profile

     a.  Firm Characteristics

     Inquiries  revealed that  very  few  companies still manufacture linoleum or  asphalt
felt-based floorings. It appears that only one company — Armstrong Cork — is still produc-
ing linoleum, and  it will cease this production in the very near future. Only  two manu-
facturers still produce  felt based products, after New London  Mills ceased production in
July  1973.

     b.  Plant Characteristics

     No published plant data is available on the specific products under consideration but
Table III-2  summarizes information on the total SIC sector. These  data indicate a drop in
total employment from 8000 workers in 1958 to 5200 in  1971  — equivalent to a decrease
of 3.3%/year — with a slight increase in  1972.  Capital expenditures per dollar of shipments
have been relatively low and were only 4.1^ in 1972.

                                         75

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                                                        TABLE 1112




                                         SIC 3996 - INDUSTRY OPERATING PROFILE
All Employees
Year
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
Number
(000)
8.0
8.0
7.1
6.6
6.4
6.2
6.3
6.2
6.3
6.0
5.8
5.5
5.4
5.2
5.8
Payroll
41.9
44.8
39.7
38.2
39.4
39.0
42.3
42.3
44.8
43.5
43.9
45.6
46.5
48.6
59.4
Production Workers
Number
(000)
6.7
6.8
5.8
5.3
5.3
5,0
5.1
5.0
5.1
4.9
4.6
4.4
4.2
4.1
4.5
Man-Hours
14.0
14.3
11.8
10.8
11.0
10.1
10.7
10.4
10.8
10.1
9.4
9.1
9.0
8.6
9.7
Wages
34.1
36.3
31.1
29.4
30.6
29.5
32.3
32.4
34.4
33.2
33.1
34.4
35.0
36.2
44.7
Value
Added
93.1
110.9
96.1
96.9
110.7
115.8
132.5
139.2
135.2
133.4
140.2
132.7
139.5
159.1
211.5
Cost of
Materials
(SMil.)
87.1
97.5
83.9
79.5
82.8
80.7
86.4
89.2
100.8
90.4
90.6
101.7
97.9
100.5
134.9
Value of
Shipments
(SMil.)
181.6
206.5
183.8
179.7
191.3
204.1
217.7
227.8
230.3
221.7
230.3
235.1
232.6
258.8
341.5
Capital
Expenditures
(SMil.)
5.4
9.5
7.8
5.7
5.0
4.4
6.8
10.0
9.3
20.6
7.7
10.5
14.5
20.7
14.0
Source: Bureau of Census, 1971 Survey and 1972 Preliminary Census of Manufactures.

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3.  Prices and Price Setting

     FOB prices for felt-based floor coverings range from 5i to \0i per square foot; that for
linoleum averages  about  304.  Assuming a felt-based density of 130 Ib/cubic foot, the job
selling price  averages about $110/short ton. Price  setting recognizes the "bottom-of-the-
line"  image of the products and the relatively poor performance compared to  more recent
innovations. The products are sometimes used as promotional specials, or traffic builders by
discount stores, advertised prices being extremely low and apparently attractive.

B. PROPOSED EFFLUENT LIMITATIONS, TECHNOLOGIES AND  COSTS

     The Development Document has proposed effluent limitations for a typical linoleum
and asphalt-printed felt plant with a daily capacity  of 30 short tons and a waste water flow
of 6,000 gallons per day (Table III-3).
                                     TABLE 111-3

                      EFFLUENT LIMITATIONS FOR LINOLEUM AND
                            ASPHALT PRINTED FELT PLANTS
                                   (30 short tons/day)
                                                        Suspended Solids*
     Best Practicable Control
     Technology Currently Available

     Best Available Technology
     Economically Achievable

     Standards of Performance for
     New Sources
                                             30-day Average
                                              (lb/1000 Ib)
0.025
0.013
0.013
                   Maximum Daily
                     (lb/1000 Ib)
0.038
0.019
0.019
     Note:  pH within the range 6.0 to 9.0
     *Limits are based on weight of pollutant per weight of product produced.

     Source: Development Document.

     BPT requires that suspended solids be settled out of the waste water prior to discharge.
 The cost estimates (Table III-4) assume  that a settling tank is installed and that the sludge is
 manually removed  from it  at recurring intervals. BAT requires that coagulants be used to
 increase the amount of suspended materials removed. The costs, also shown in Table III-4,
 reflect  the additional investment and  operating expenses that would  be  incurred. NSPS
 requirements and their associated costs are identical to BAT technology.
                                         77

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                                      TABLE II1-4

              TREATMENT COSTS - LINOLEUM AND ASPHALT FELT PLANTS
                        (Typical Plant - 30 tons/day x 250 days/year)

    TYPE OF COST                             BPT          BAT*          NSPS
                                             (1977)         (1983)

    Total Investment                          $3600          $6100         $6100

    Total Operating Maintenance and Energy          725          2595           2570

    Total Annual                               1445          3815           3790

    Cost/Short Ton                             0.19           0.51           0.51


     * Cumulative costs incurred after BPT has been achieved.

    ** Includes operation and maintenance, energy, and capital cost amortized at 15% discount rate
       over 10 years (factor of 0.2). Fifteen percent was chosen as a current cost of capital for the
       industry, although it may vary significantly by plant depending on ownership pattern. The
       effect of any change in the rate is insignificant for this analysis.


    Source:  Development Document.


C. ECONOMIC IMPACT ANALYSIS

     It  is anticipated  that base  line closures in  this sector, independent of the potential
economic impact of effluent control Guidelines, will cause this industry to cease production
within about two years, and certainly prior to 1977.

     Consequently, the examination  of the potential economic impact  is not meaningful
except as a theoretical analysis. The incremental costs of achieving BPT effluent limitations
are equivalent to 0.17% of  selling prices; the  costs for achieving BAT are approximately
0.47%. In the remote  possibility that  some plants are  still in operation in 1983, such price
increases are certainly modest enough to be passed through in full with no noticeable effect
on the market for the industry's products.
                                          78

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                             LIMITS OF THE ANALYSES

     This assessment of the potential  economic  impact of the BPT and  BAT effluent
guidelines on the asphalt paving and roofing manufacturing industry has been based on the
assumption that the unit operations and corresponding typical plant capital investment and
annual treatment costs suggested by the Development Document are truly applicable to the
effluents generated by the appropriate  industry categories. As such, the economic impact
conclusions rest on the accuracy of these cost data and treatment schemes.

     The  evaluation of  the  economic  impact of additional  water treatment  costs, and
particularly  the  determination of specific plant costs as a proportion of annual sales, is a
function of at least three estimated quantities — "annualized" water treatment costs, typical
annual production rates, and representative unit sales values of products. Thus, any gross
errors in any of these quantities affect the accuracy of the  impact parameter. To minimize
such errors,  careful judgment has been exercised in the estimates and they are believed to be
reasonably reflective of actual data.

     It needs to  be indicated  that while  the present analysis has identified plants that may
be potentially vulnerable as a result of the effluent guidelines,  the decision to curtail or
discontinue operations at a given plant is governed by a number of interacting factors; while
waste water  treatment costs may  appear unacceptably high at a threatened  plant,  the
decision  to continue or terminate  operations is a function of corporate goals, present and
future  market  conditions, etc.  For  example, with  4,800 plants in  the asphalt  paving
industry, it has been necessary to generalize the potential impact on an industry-wide basis.
The vulnerability of a specific plant will depend on whether it has a baghouse, is located in a
competitive urban location, has good highway  access, etc.

     Finally, the  interpretation of the potential impact of the proposed effluent guidelines
has not taken into account the concurrent and reinforcing effects of other future legislations
and governmental controls which, with the additional water  control  costs, may create  a
"last-straw"  effect, on  the sectors under consideration, even though the effluent treatment
costs may by themselves be negligible.
                                        79

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I I.CIINICAL RlTORT
   DA I A PAGI
- 74 - 055
                                                                 3. Recipient's Accession No.
4 Title mill Subtitle
        Economic Analysis of Proposed Effluent Guidelines
        Paving and Roofing Materials  Industries.
        (Tars & Asphalt)	
                               5. Report Date
                                 August,  1974
                               6.
7 Aiiiiu.i(s)   Richard F. Goodale
           Ronald Levy
                                                                 8. Perfor
                                          organization Rept. No.
9. IVrliirininn Organization Name and Address
        Arthur D. Little, Inc.
        Acorn Park
        Cambridge, Massachusetts   02140
                               10. Project/Task/WorkUnitNo.
                                   Task Order No.  28
                               11. Contract/Grant No.
                                   68-01-1541
I 2. Sponsoring Organization Name and Address
        Office of  Planning and Evaluation
        Environmental  Protection Agency
        Washington,  D.  C.   20460
                               13. Type of Report & Period Covered
                                   Final
                               14
   Supplementary Notes
16. Abstracts
     An analysis of  the economic  impact of proposed water effluent Guidelines upon various
     asphalt and tar using industries was performed based on water treatment  cost data
     supplied by the EPA.  The asphalt using industries included paving,  roofing and
     flooring.  A methodology was developed to  systematically  judge the broader economi
     effects on these materials,  resulting from the application of water  effluent
     control, first  by assessing  the likelihood that treatment costs would  be defrayed
     through price increases, and secondly, if  price increases were not likely, the
     extent to which profits would be impacted  and/or the likelihood that plant shutdowns
     would occur.  Based on this  approach and using the treatment costs supplied, it
     was concluded that a limited number of plant shutdowns would occur in  the asphalt
     paving sector  if best practicable technology standards were imposed  on that indust
                                                           ry,
 17. Key Words and Document Analysis.   17a. Descriptors

     Economic Analysis
     Effluent Guidelines
     Development Document
     Asphalt Concrete
     Asphalt Emulsions
     Asphalt Paving  Industry
     Asphalt Roofing Industry
     Asphalt Flooring Industry
 17b. Identifiers/Open-Ended Terms
 17c COSATI Held/Group
 IK. Availability Statement
     Limited availability through U.S.
     Environmental Protection Agency Information
     Center; Room  W327, Waterside Mall, Wash.D.C.
                   19. Security Class (This
                      Report)
                       UNCl.ASSI! II D
                   20. Security ( lass ( This
                      Paw-)
                       UNTLASSII II'D
21. No. of Paces
       90
                                        22  Price
I OKM NTIS-35 (RTV. 3-72)
                                              20460
                                                                              USCOMM-DC 149S2-P72

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