EPA-E3D/1-74-D57
OCTOBER 1974
              ECONOMIC ANALYSIS
                       OF
       PROPOSED EFFLUENT GUIDELINES

    WOODEN FURNITURE &  FIXTURE MANUFACTURING
 SEGMENT OF TIMBER  PRODUCTS PROCESSING INDUSTRY
                     PHASE II
                     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, Washinglon,
D.C. 20460

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

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EPA-230/1-74-057
                          ECONOMIC ANALYSIS

                                 OF

                     PROPOSED EFFLUENT GUIDELINES
               WOODEN FURNITURE & FIXTURE MANUFACTURING
                             SEGMENT OF
               THE TIMBER PRODUCTS PROCESSING INDUSTRY
                              PHASE II
                              Report to

               U.S.  Environmental Protection Agency
                Office of Planning and Evaluation
                      Washington, B.C. 20460
                            October 1974
                                  U.S.  Environmental Protection Agency
                                  Region V, Library
                                  230 South Dearborn Street
                                       100  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 Environ-
mental Protection Agency, nor does
mention of trade names or commercial
products constitute endorsement or
recommendation for use.
                  ii

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

     The study supplements the technical study ("EPA Development Document")
supporting the issuance of proposed regulations under Sections 304(b) and
306.  The Development Document surveys existing and potential waste treat-
ment control methods and technology within particular industrial source
categories and supports proposal of certain effluent limitation guide-
lines and standards of performance based upon an analysis of the feasibility
of these guidelines and standards in accordar ce 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
technologies.  This study investigates the effect of alternative approaches
in terms of product price increases, effects upon employment and the
continued viability of affected plants, effects upon foreign trade and
other competitive effects.

     The study has been prepared with the supervision and review of the
Office of Planning and Evaluation of EPA.  This report was submitted in
fulfillment of Task Order No.  17, Contract 68-01-1541 by Arthur D.  Little,
Inc.  Work was completed as of October 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, refer-
enced, or represented in any respect in any such proceeding as a state-
ment of EPA's views regarding  the subject industry.
                                   iii

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                            TABLE OF CONTENTS

                                                                      Page

  List of Tables                                                       vi


  I.  EXECUTIVE SUMMARY                                                1

      A.  SCOPE OF WORK                                                1

      B.  CONCLUSIONS                                                  1

          1.  Industry Segments                                        1
          2.  Financial Profiles                                       2
          3.  Pricing                                                  2
          4.  Methodology                                              3
          5.  Costs of Compliance                                      5
          6.  Economic Impact Analysis                                 5
          7.  Limits of the Analysis                                   7

 II.  INDUSTRY SEGMENTS                                                8

      A.  OVERVIEW OF THE FURNITURE INDUSTRY                           8

      B.  SEGMENTATION   .                                             12

      C.  NON-UPHOLSTERED FURNITURE                                   16

          1.  Types of Firms                                          29
          2.  Types of Plants                                         30
          3.  Financial Profiles                                      32
          4.  Pricing                                                 32

      D.  UPHOLSTERED FURNITURE                                       35

          1.  Type of Firm                                            37
          2.  Types of Plants                                         37
          3.  Financial Profiles                                      40
          4.  Pricing                                                 40

III.  METHODOLOGY                                                     42

      A.  DATA GATHERING                                              42

      B.  PRICE EFFECTS                                               43

      C.  PLANT CLOSURE EFFECTS                                       45

      D.  SEGMENTATION                                                47
                                     iv

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                           TABLE OF CONTENTS (Cont.)

                                                                      Page

IV.  COSTS OF COMPLIANCE                                               48

     A.  MODEL PLANTS                                                  48

     B.  ALTERNATIVE CONTROL METHODS                                   49

     C.  OPERATING AND INVESTMENT COSTS USING BPT                      49

     D.  COST IMPACT                                                   49

 V.  ECONOMIC IMPACT ANALYSIS                                          51

     A.  INTRODUCTION                                                  51

         1.  Industry Segments                                         51
         2.  Number of Plants Affected                                 54
         3.  Minimizing Impact                                         54

     B.  PRICE EFFECTS                                                 54

     C.  FINANCIAL EFFECTS                                             58

     D.  SENSITIVITY ANALYSIS                                          58

         1.  Large Plants                                              59
         2.  Medium Plants                                             59
         3.  Small Plants                                              66
         4.  Sensitivity - Conclusion                                  66

     E.  PRODUCTION EFFECTS                                       .     72

     F.  EMPLOYMENT EFFECTS                                            72

     G.  REGIONAL EFFECTS                                              72

     H.  BALANCE OF TRADE EFFECTS                                      72

     I.  INDUSTRY GROWTH EFFECTS                                       72

VI.  LIMITS OF THE ANALYSIS                                            73

     A.  DATA LIMITATIONS                                              73

     B.  NATURE OF THE INDUSTRIES                                      74

     C.  MOST SENSITIVE ISSUES                                         74

 APPENDIX                                                              76

                                    v

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                        LIST OF TABLES (Cont.)

Table No.

   V.D.4     Financial Impact - Medium-Size Non-Upholstered
               Furniture Plants With Water Wash Spray
               Booths                                                63
   V.D.5     Financial Impact - Medium-Size Upholstered
               Furniture Plants - Laundry Facilities                 64
   V.D.6     Financial Impact - Medium-Size Non-Upholstered
               Furniture Plants                                      65
   V.D.7     Financial Impact - Small Non-Upholstered Furniture
               Plants - Laundry Facilities                           67
   V.D.8     Financial Impact - Small Non-Upholstered Furniture
               Plants                                                68
   V.D.8a.   Financial Impact - Small Upholstered Furniture
               Plants                                                69
   V.D.Sb.   Financial Impact - Small Upholstered Furniture
               Plants                                                70
   V.D.9     Sensitivity Analysis - Conclusion Matrix                71

  VI.C.I     Most Sensitive Issues                                   75

     A-l     Industry Summary: Non-Upholstered Wood Furniture
               Manufacturers ,                                        77
     A-2     Industry Summary: Upholstered Wood Furniture
               Manufacturers                                         78
                                   vi

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                        I.  EXECUTIVE SUMMARY
     This report presents the contractor's final analysis of the
 economic  impact on wood furniture manufacturers to meet  1977 and  1983
 proposed  effluent guidelines and new source performance  standards.

 A.   SCOPE OF WORK

     The  industry sectors analyzed are:  wood household  furniture -

     .  SIC-2511 - Wood household furniture;  includes two newly
                   established sectors, SIC-2517 - TV, radio, etc.,
                   cabinets, and 2534 - kitchen cabinets.

        SIC-2512 - Upholstered wood household furniture;

     .  SIC-2521 - Wood office furniture;

     .  SIC-2531 - Public building furniture;

        SIC-2541 - Wood partitions and fixtures.

     To accomplish the economic impact analysis we have  developed data
 on the structure of these industry sectors and an analytical model to
 focus on  the central issues.

 B.   CONCLUSIONS

     1.  Industry Segments

     The objective of segmenting the industry was to group plants into
 categories which would be affected similarly by effluent control require-
 ments.   For this industry, the costs of compliance and technologies to
 comply can be directly related to the type of process performed.  Pro-
 cesses  performed within plants vary by product mix only to the extent
 that upholstered furniture manufacturers  do far less finishing and
 thereby generate less effluent than do non-upholstered manufacturers.
Therefore, the costs  of compliance will fall  differently upon plants
 in each of these two  major categories.  Thus,  upholstered and non-
upholstered manufacturing operations were grouped into separate primary
 segments.

     Within each of these two major segments  the ability to bear these
costs is directly related to the  size of  plant.   There are many very
small plants in this  industry;  i.e.,  more than 6070 of the plants have
less than 20 employees  and generate less  than $500,000 in annual sales

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revenues.  Such plants are sensitive to small cost increments.  Thus,
plant size is the second important criterion used to segment the
industry.

     Product mix differences do not imply effluent differences.
A small plant manufacturing either TV cabinets (SIC-2517) or kitchen
cabinets  (SIC-2534) or case goods (SIC-2511) will have essentially the
same effluent load; the unit manufacturing operations of assembling,
gluing, and finishing are common to each of the plants.  Scale (size
of plant) is the primary determinant of effluent load.

     2.  Financial Profiles

     The representative model small plants within the manufacturing
segment have the following characteristics:

                                Upholstered      Non-up>holstered

     Annual sales                 $530,000           $390,000

     After-tax net income            9,000              5,000

     Cash flow                      16,000             13,000

     Net assets                    140,000             95,000

     Number of employees                25                 20


These are small plants with modest cash flows and asset bases.

     3.  Pricing

     The success of a piece of furniture is primarily dependent upon
the aesthetic attraction of the piece;  that is, consumers are relatively
insensitive to price, within a range of plus/minus 5%, and select a
piece of furniture because of its design,  color,  etc., rather than
strictly on the basis of price.

     Furniture prices vary widely.  Consumers shop within fairly broad
bands of prices.  For example,  the price of a sofa might fall within
the following price ranges:

        Low price:    $200;

     .   Middle level:  $200-400;

     .   High price:    $400.

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     The price sensitivity within the low price category is likely to
be somewhat greater than for the higher price categories.  Nonetheless,
aesthetics represent a strong influencing factor in all categories.

     This relative price insensitivity is a key factor in determining
if cost increases due to pollution control can be passed on to the
consumer.

     4.  Methodology

     Since there are many small, privately held firms in this industry
which do not generally publish financial data or other statistics on their
operations, data had to be developed on the various industry segments
through Department of Commerce information, surveys of firms in the
industry, surveys of industry associations and others knowledgeable of
industry practice and background data which we have accumulated over
time.

     To accomplish the economic impact analysis, tha data on the
structure of this industry was used to develop industry segments of
groups of firms which would be similarly affected by guidelines and
costs, and was applied to an analytical model with the focus on the
following critical issues:

        The probability that costs of compliance will be able to be
        passed on to consumers via increases in product prices or
        will have to be absorbed by operators, resulting in a lower
        level of profitability;

        If costs cannot be passed through,  the extent to which the
        resultant effect on financial condition will cause plant
        closures, unemployment, and community impacts, and restrict
        industry growth; and,

     .  The extent to which capital availability will be limited for
        the numerous small operators, also causing plant closures,
        unemployment, and community impacts, and restricting industry
        growth.

     The analysis of whether prices are likely (or not likely) to be
able to be passed on is a relatively straightforward economic analysis.
Table I.B.I presents the price increase analysis matrix which we used
to derive price increase conclusions.

     However, even if prices are not likely to be increased, and costs
are absorbed with relatively well documented financial effects, it is
far more difficult to reach conclusions regarding plant closures.  The
plant closure analysis matrix which was used to focus upon the central

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                    TABLE I.B.I
Factor
PRICE INCREASE ANALYSIS MATRIX

  Price Increase Constraints

                     Condition for
                       Constraint
Ratio of Before Tax Treatment
Cost to Selling Price
         00

Substitute Products

Capacity Utilization

Captive Usage

Demand Growth

Foreign Competition

Abatement Cost
Differences

Price Elasticity
of Demand

Basis for Competition

Market Share Distribution

Number of Producers
                          High



                     High occurrence

                          Low

                          Low

                          Low

                          High

                         Unequal


                          High


                         Price

                     Fragmented

                          Many
 Source:  Arthur D. Little, Inc.,  estimates.
                                                             TABLE I.B.2
                                                              PLANT CLOSURE ANALYSIS MATRIX
                                                                 Plant Shutdown Decision
Factor

Ratio of After Tax Treatment
Cost at After Tax Net
Income (%)

Cash Flow (Including
Treatment Costs)

Ratio of Investment in
Treatment Facilities to
Net Fixed Investment (%)

Integration

Multi-Plant Complex

Other Environmental
Problems (Including OSHA)

Emotional Commitment

Ownership
  Condition for
    Shutdown

     High
   Negative


     High



     Low

  Isolated Plant

   Multiple


 Indifference

 Large, Multi-
Industry Company

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issues in these decisions is presented as Table I.E.2.  The analysis
is complicated by the fact that small, family-owned and operated, one-
plant firms, tend to show remarkable "staying power" even in the face
of extremely low rates of profitability and other burdens.  The extent
of subjective commitment to the business, beyond the point at which
standard financial analysis would suggest shutdown, is an extremely
difficult factor to measure and assess.  Thus, subjective e3emev.es must
be used to supplement the objective analysis.

     5.  Cost of Compliance

         Table I.E.3 estimates the costs of compliance for the various
industry sectors.  For these firms, the costs represent the probable
technologies firms will elect to institute to comply with 1977 effluent
guidelines.  Each subcategory should be able to meet the effluent
limitations with anyone of four technologies:  landfill, incineration,
evaporation with spray, arid irrigation.  It was assumed for each seg-
ment and subcategory that, at most, the second least expensive option
would be selected.  Since these costs were developed for large plants,
the costs for smaller plants are overstated.  Even so, no closures are
expected for any segment.

     6.  Economic Impact Analysis

.,     Large firms in this industry will feel no noticeable effect due to
effluent guidelines.  Costs of compliance to these firms are insignifi-
cant (less than 0.2% added annual cost burden, capital investment less
than 0.2% net fixed assets).  Medium-sized plants will also generally
not face significant impact.  Again, costs are moderate (less than 1.0%
added annual cost burden, capital investment less ,than 1.5% of
net fixed assets).

     Small firms, in both sectors, will face a noticeable effect on
operations; however, even these small firms will not be impacted signi-
ficantly since:

        They should be able to pass on any increased costs to consumers
        via increased prices of their products, thereby maintaining
        profits.

        There are technological options available which will allow
        almost all firms to avoid the maximum expenditure and enable
        them to reach compliance at a modest level of investment.

     Finally, more than 90% of the plants in the industry (iicluding
small plants) already meet BPT guidelines; less than 10% of all plants
will be required to make any new investment for abatement.

     Thus, while some small firms (2% of industry) may have to change
operations and to raise prices, no closures are expected and there will
be no other noticeable effect on the industry due to the proposed
effluent guidelines.  Further, probable costs of abatement c.an be
financed out of cash flow.  Capital availability is not a problem.

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                                             TABLE  I.E.3
Segment
Non-upholstered mfrs.
Large Plants
Medium Plants
Small Plants
subtotal
Upholstered mfrs.
Large Plants
Medium Plants
Small Plants
subtotal
COSTS OF
Total
Plants

552
1191
2853
4596

233
563
705
1501
COMPLIANCE* -
Number
of Plants
Affected

55
119
285
459

23
56
70
149
FURNITURE
Probable
Capital
Cost

$4,500
4,500
3,200

$3,200
3,200
3,200
MANUFACTURERS
% Probable
Net " Annual
Assets Cost

0.2% $9,300
1.5 9,300
3.4 6,680

.13% $6,680
.9 6,680
2.3 6,680
% Sales

0.15%
0.8
1.7

.1%
.5
i-3
Total                       6097         608
*BPT, BAT, NSPS on  proposed Guidelines.
Note:  Based on 1972 estimated cost and profit profiles.

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     7.  Limits of the Analysis

     The analysis of economic impact is complicated by:

        A limited availability of data - the small, privately-held
        firms do not publish detailed operating and financial data;
        and,

        The nature of the industry - the typical, privately-held firm
        views a plant closure decision more subjectively than does a
        publicly-held firm, requiring that financial analysis of closure
        be augmented by subjective considerations.

     We dealt with the data limitation problem by developing our own
data through surveys of the industry, collecting information on the
view of the industry as a whole,  but focusing on the operations of
those firms and plants most likely to be impacted, i.e., the small
operators.  Due to the large number of plants involved (approximately
6000), it was necessary to collect data by representative samples
(a 1% sample size of firms, plus  interviews with persons knowledgeable
of the industry, e.g., trade associations) rather than through com-
prehensive (1007») sampling.  The  consistency of the data suggests that
the analysis is built upon a sound data base.

     The second issue, the nature of the industry, makes it difficult
to project plant closures (see I.B.4 above).  Since 90% of the firms
in the industry already meet 1977 guidelines and the remaining firms
have low cost compliance options  available and can pass on to consumers
any increased cost burden, the problem of projecting plant closures is
ameliorated, the conclusion of no impact is clear.  However, if dif-
ferent guidelines were introduced, with attendant higher costs, and
those costs could not be passed on,  capital would become limited and
the plant closure decision would  be a more sensitive issue.

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                        II.  INDUSTRY SEGMENTS

     The following chapter is intended to give a broad perspective on
the dynamics of the wood furniture industry, in addition to providing
detail on individual segments.   It contains the following parts:

     a) general review of industry dynamics

     b) industry segmentation and rationale

     c) non-upholstered furniture manufacturing segment:

        - overview (basic data for all four component sectors)

        - types of firms

        - types of plants

        - financial profiles

        - pricing

     d) upholstered furniture manufacturing (single sector)

        - overview
                                                  (
        - types of firms

        - types of plants

        - financial profile

        - pricing

A.  OVERVIEW OF THE FURNITURE INDUSTRY

     Of the more than 6,000 firms which produce furniture only about
250 can be considered major factors in the industry, with no single
company accounting for more than 3% of industry sales.  The 10 largest
producers represent about 207, of industry volume; the top 25 firms
account for less than 30% of industry sales, while the 3,600 smallest
firms (under 20 employees) account for about 8% of industry sales.

     Furniture is manufactured in virtually every state, but the prin-
cipal producing areas are the South Atlantic, the Great Lakes, Califor-
nia, New England,, and the Middle Atlantic States.  North Carolina is
the leading furniture producing state, accounting for about 22% of the

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 industry shipments  of all  household furniture;  Virginia (10%),  Cali-
 fornia (8%),  Indiana  (77,),  and Tennessee  (6%)  follow.   The production
 of metal office  furniture  is  highly concentrated (80%)  in the Great
 Lakes area.   Wood office  furniture  is  manufactured principally in
 North Carolina,  Virginia,  Michigan, and New York—for  the most part
 by the same  firms that produce household  furniture.

      In the  South Atlantic states,  primarily North Carolina and Virginia,
 furniture manufacturing has grown as a result  of both  lower labor costs
 and widely available  raw materials. Production in these states is
 principally  a veneer  construction and  includes  all levels of quality.

      The Great Lakes  states (Illinois,  Michigan and Indiana) are major
 producers of dinette  furniture and kitchen cabinets,  although they also
 manufacture  case  goods and  some upholstered furniture.   On the  West
 Coast,  Los Angeles  is the  largest furniture manufacturing area,  pro-
 ducing principally  upholstered and  case goods.   Because of the  high
 labor cost on the West Coast,  most  case goods are  aimed at the  lower-
 priced furniture  markets where competition  from North Carolina  and
 Virginia is  not strong due  to  freight  costs.  The  furniture  manufactur-
 ers  on the West Coast  are generally small compared to those  on  the East
 Coast,  with  few companies having  more  than  $6 million in annual  sales
 and  only two  more than $12  million.  New England and the Middle  Atlantic
 States  concentrate  principally on the  production of solid wood  furni-
 ture  in the Early American  design.   The plants here are  typically  older,
 frequently finding  it  difficult to  compete  with the more modern  pro-
 ducing  facilities of  the South.

      Labor accounts for as  much as  35%  of the sales dollar in the  fur-
 niture  industry.  High-quality  furniture (most expensive  10%) generally
 requires  even greater  labor input.   The supply of  labor  in the major
 manufacturing areas has become  limited, and wages  in the  household
 furniture  industry have grown  faster than those of  all manufacturing
 in the major  furniture manufacturing states.  In 1970 employment in
 the furniture industry declined by  15,000 workers  to 300,000 as  the
 industry's shipments dropped along with the general downturn of  the
 economy  in that year.  By 1973, employment  rose to  350,000.  With  the
 upturn  in  demand  for furniture  in 1971, vocational  training programs
 supported  by  furniture firms were instituted in high schools to  train
 future  industry workers.

     The  furniture manufacturers make very  small capital  expenditures
 in proportion to  their total sales,   often less than 1% or 2% of  sales.
 Indeed,  in 1960 and 1961,  the   industry's depreciation exceeded irs
 capital expenditure programs.   Our surveys  of the  industry suggest
 that the  industry is currently spending double its depreciation account
 for capital expenditure programs.   Since capital requirements of the
household  furniture industry have  traditionally been met out of current
cash flow, the industry has little debt.

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     Table II.A.I compares employee productivity (expressed as $ Value
Added/Production Worker and $ Value of Shipments/Production Worker)
among the various furniture sectors covered by this analysis and, as a
point of reference, compares furniture to two capital intensive indus-
try sectors, wood pulp manufacture and petroleum refining.  The table
demonstrates that furniture manufacturing sectors are very labor-inten-
sive ($10.9-17.7K Value Added/Production Worker) as contrasted with
wood pulp ($33.3K Value Added) and petroleum refining ($65.2K Value
Added), which are more capital intensive.

     Another measure of capital intensitivity is the amount of invest-
ment required to generate a dollar of sales revenue.  The ratio of $
total assets to $ total sales revenues ($A/$S) approximates this measure.
The higher the $A/$S ratio, the more capital intensive the business.
Our model wood furniture plant (small size) (see Section II.C.3 and
II.D.3 for details) has the following capital intensivity ratio:

                        "Furniture"  $A/$S: 0.25

     In contrast is the same ratio for the following two major manu-
facturers in capital intensive businesses:

                        Exxon $A/$S = 0.971

                        U.S.Steel $A/$S = 0.9952

     Differences in the profitability of large and small firms are
explained by the nature of the industry.   There are some economies of
scale in production, distribution and sales of furniture to favor
larger companies.  But the actual profitability among smaller firms
is not always apparent.  Many small-to-medium size companies which are
family-owned report low net incomes, though their gross profit is in
many cases equal to or higher than that of the larger firms.  These
smaller companies often prefer to take "profits" in the form of salaries
and fringe benefits rather than as corporate income.

     The household furniture industry spends about 42% of its sales
dollar for materials.  Wood's workability, structural integrity, and
functionality have made it the material of choice for furniture pro-
duction.  Currently, wood and wood products account for 3070 of materials
purchased; plastic and plastic products,  about half of that.  Increased
1Source:  Forbes, May 15, 1974, p. 178.

2Ibid., p. 200.
                                  10

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                              TABLE II-A-f

                      EMPLOYEE PRODUCTIVITY,  1972  ($)
SIC                       Value Added                 Value of Shipments
                        Per Production Worker     Per Production Worker

2511
2512
2517
2531
2541
2611
2911
1972
13,832
13,992
10,886
14,927
17,765
33,274
65.176
1967 % Chg 1972
n.a. 25,905
10,344 35.3% 26,738
n.a. 20,316
12,869 15.9% 25,843
13,749 29.2% 32,103
33,049 .7% 82,309
62,765 3.8% 364,554
1967
n.a.
19,543,
n.a.
22,942
24,087
59,877
268,438
% Chg

36.8%

12.6%
33.3%
37.5%
35.8
 (Petroleum Refining)
 Source:  1972 Preliminary Census of Manufactures.

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capital intensiveness will require the use of more homogeneous materials,
of which plastic and reconstituted wood products are the prime choices.
A most critical problem for the furniture industry is the tight market
and higher cost for furniture (hardwood species) woods.  Demand for
hardwood lumber from its major consumers--the furniture, hardwood floor-
ing and materials handling (pallets) industries--increased sharply in
1972 and continued at a high level in 1973.   Plastics such as high-pres-
sure laminates, coated fabrics,  and polyurethane cushioning have reached
positions as accepted materials for construction in the furniture
industry.  The use of molded components and vinyl veneers will contri-
bute new growth to the use of plastics in this industry.  The transition
to a greater use of plastics will require additional capital because of
the greater cost of equipment to manufacture plastic furniture.  A
typical injection molding machine costs approximately five times as
much as a comparable wood manufacturing machine.

     Increasing use of plastic in furniture  is likely.   The use of
plastic has improved productivity and had a  restraining effect on
prices.  For example, from 1967  to 1971 the  value added per production
worker man-hour in the household furniture industry increased 28%
while wholesale furniture prices rose only 15%.  At least part of this
increase in production efficiency can be attributed to the use of plas-
tics.

     Foreign trade in household furniture was not significant until the
late sixties, when imports began to grow at  a rapid pace and now
account for nearly 3% of domestic consumption.  Imports for 1973 are
estimated at approximately $240 million, up 18% from the $204 million
of 1972.  Major sources of imports include Canada, Italy, Japan, Den-
mark, Yugoslavia and Taiwan.  While the large increase in 1972 may be
due more to recent currency realignments, exports should continue to
expand.  Exports for 1973 are estimated at $40 million compared with
$23 million in 1972.  Although imports are still considerably greater
than exports, U.S. furniture products are becoming more competitive
with those of foreign countries, primarily aided by dollar devaluation.
About 75% of U.S. exports goes to Canada, Mexico and the Bahamas.

B.  SEGMENTATION

     Our objective was to segment the furniture industry into groups
of plants that would be impacted similarly by pollution abatement guide-
lines.   This was done to allow us to analyze each distinct segment in
terms of economic impact and to focus our efforts on those particular
segments that were likely to be  most severely affected.

     The Development Document subcategorizes the industry for the pur-
pose of developing Effluent Guidelines based on water usage.  Other
factors such as process variation,  plant size and age,  plant location,
and land availability were determined to be  of secondary importance.
                                  12

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Four model plants were developed for each of the technological  segments
as  follows:

      .  Model  1  - Contains only dry booths  (for wood  finishing);  no
        laundry  facilities and two glue spreaders.

      .  Model  2  - Contains dry booths, laundry facilities, and  two
        glue spreaders.

      .  Model  3  - Contains water wash  (wet  finishing), no laundry,
        two glue spreaders.

      .  Model  4  - Contains both water wash, spray booths, and laundry
        facilities and two glue spreaders.

     This segmentation by unit process performed allows development of
levels of compliance and costs.  These variations among models  are based
on  the particular mix of operations performed, but are not primarily
related to product mix.

     Our surveys and analyses have also demonstrated  that various unit
operations can be performed by any furniture manufacturing plant with
any product mix, with the exception of manufacturers  of upholstered
furniture.  Upholstered manufacturers do not utilize water wash spray
booths, since  they do not perform enough finishing to justify the
capital investment.   Rather they generally hand finish or use other
low-cost methods to finish what little exposed wood appears on an
upholstered furniture piece.

     Thus, upholstered furniture manufacturers can be segmented and
studied as a separate group.   All of these manufacturers will fit within
technological models 1 and 2.

     Within these models, the differences in cost of compliance will
not be related to product mix or other factors;  rather, plant size will
be the measure of the ability to bear costs, not product mix.  Economic
impact assessment will thus be based on differential  impacts depending
upon size of operation.

     The rest of the industry cannot be subsegmented by product mix or
other process-related variations.  The key to further segmentation is,
again, plant size.   For example, small plants in the  industry do not
use the water wash spray booths; 50-607, of the largest group of plants
use water wash spray booths.   The capital investment required makes it
necessary to process a relatively high volume to justify the investment.
                                 13

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     Table II.B.I compares the remaining non-upholstered furniture
industry sectors on various economic characteristics related to plant
size.  As the table indicates, the mean values and distribution of the
various indices for the various plant size categories is quite consis-
tent among the four sectors.  For sector 2541, the average plant size
is smaller, and a larger proportion of plants are contained in the
smallest plant size category.  However, this further exemplifies the
importance of considering small plants and segmenting to test economic
impact on small operations.

     As a point of contrast, similar data are presented for two other
industry sectors, namely, petroleum refining (SIC-2911) and wood pulp
manufacture (SIC-2611).  In the case of petroleum refining, the average
plant is more than five times the mean plant size in the furniture in-
dustry sectors; the average plant size for wood pulp manufacture is
about three times larger.  These latter two sectors are typified by
large plants, highly capital intensive, with a great deal of automation
and much less reliance on labor.  Reliance on labor and lack of auto-
mation more typify the furniture industry,,

     Although the data is not as readily available, our review of major
issues with the industry indicate that the sectors are also essentially
homogeneous with respect to:

        Price elasticity - See Section II.C.4 for analysis;

        Costs - Cost/profit data collected correlates well with plant
        size variations;

        Profitability - Cost/profit data collected correlates well with
        plant size variations;

        Capital availability - In this industry and others we have
        analyzed (e.g., Economic Analysis of Proposed Effluent Guide-
        lines - The Timber Products Processing Indus try.  Phase II;
        report to EPA,  August 1974 -;,-:EPA-230/2-74-029),  small firms
        have the least  leverage in capital markets.  The  availability
        of capital to the small firms is an extremely important issue.

     Thus,  the segments which can be analyzed chosen to assess economic
impact are two major segments, namely:

     .  Upholstered furniture manufacturers, and

     .  All other furniture manufacturers.

     Within each of these larger segments the key variable is plant
size, which is used to  develop operating and financial profiles for
various plant size categories.
                                   14

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                            TABLE  II.B.I
                    INDUSTRY  SECTOR COMPARISON,  1971
     Shipments/
     Production
     Worker	
      (1000)
$ Fixed   $ Fixed  Capital        Average Plant Size
Assets/   Assets/  Expend.  Mean    (//  of  Employees)
$ Sales   Employ.  /Plant   Size  1-19  20-99  100+
2511   22.1
  .348     5,561    25,718   61   60.9  25.1   14.0
2521   23.9
  .304     6,625    13,191   58   56.6    - 43.4 -
2531   28.9
  .228     5,762    21,359   57   54.9    - 45.1 -
2541   31.0
  .181     4,654     7,594   22   72.8    - 27.1 -
Ave.   26.2
  .312     5,160    16,877
59.9    - 40.1 -
2911  330.9          .579   149,038 3,899,683  318   13.6
(petroleum resining)
                                          - 86.4 -
2611   92.0
(wood pulp
 manufacturing)
  .355    23,346 2,263,793  181   43.2    - 56.8 -
Source:   Census  of  Manufactures.
                                  15

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C.   NON-UPHOLSTERED FURNITURE

     The  ten-year growth  in value of shipments for the SIC categories
included  in  this sector is presented in Table II.C.I.  That these are
growth areas  is demonstrated by the average annual increase in value
of  shipments  of nearly 10%, approximately double the U.S. all manufac-
turing industries average and GNP growth rate.

     The  Wood Household Furniture Industry (SIC-2511), as defined by
the  U.S.  Department of Commerce, includes establishments primarily
engaged in manufacturing wood household furniture commonly used in
dwellings.  The sector includes the manufacture of infants' and child-
ren's wood furniture and wood outdoor furniture.

     Table II.C,2 presents basic data for the sector.  Two segments have
been separated from 2511 in 1972:   establishments primarily engaged in
manufacturing kitchen cabinets are now classified under SIC-2434; and
wood T.V., radio,  phonograph and sewing machine cabinets also previously
in this industry are now classified in industry 2517.  Information for
2517 and 2434 is also included for comparison.

     In household furniture manufacture, goods are generally more
amenable to storage than in the upholstered (2512) furniture manufac-
ture.  Inventories of raw materials, primarily wood, are important and  the
production process is longer than in the upholstered segment.  This
segment represents a production process that requires at present little
fixed outlay compared with that found in most industries.  As suggested
earlier in II.A.,  the introduction of plastics will change this aspect.

     In 1972 the value of products shipped of establishments classified
in the Wood Household Furniture Industry amounted to $3,127 million.
In 1967 the value of products shipped was $2,439 million and in 1963
$1,858 million.  A comparable figure for 1972; that is, including 2517
and 2434, is $4,267 million, a real increase in this industry of 36.57,,.
Table II-C.3 displays the change in value of shipments and employment
by geographic area between 1967 and 1972.  The South Atlantic Region
has come  in 1972 to hold 507, of the U.S. industry, as compared to 387=
in 1967 when the figure included the additional industries of 2517,
2434.  line West South Central, Mountain and South Atlantic Regions have
experienced the largest average annual change in value of shipments,
though changes in employment ai-e not nearly so great.  At the same time,
the Middle Atlantic,  East North Central and East South Central Regions
have averaged a negative average annual change in both shipments and
employment.
                                  16

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                                               TABLE II-C-l

                                        VALUE OF SHIPMENTS, TOTAL U.S.
                                                 1963-1972
                                               ($ Millions)                    N
                                                                                        Average
                                                                                        Annual Change  Av Yr
          1263    1964    1965    1966    1967    1968    1969    1970    1971    1972     63-70      Chg 70-72


  2511*  1858.0  2013.7. 2201.1  2423.4  2438.9  2659.5  2862.6  2684.4  3029.7  3126.8      6.4        8.3
  2517***



  2521    101.5   109.3   122.9   136.4   158.3   173.9   212.7   197.8   174.8   248.1     13.6       12.7


  2531    268.6   284.4   312.8   343.5   421.2   432.3   468.5   562.6   471.8   522.1     10.3        6.4


  2541    389.6   389.6   426.6   462.0   498.6   524.7   642.3   622.6   645.3   780.1      8.5       10.7


  *Includes SIC 2434 & 2517 in 1963-1971.
 **Includes SIC 2426 in 1963-1971
***Part of 2511, 1963-1971.


  2434
                                                                                  319.6


  2426                                                                            558.2


  Source:   Census  of Manufactures.

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                                      TABLE II.C.2

                   EMPLOYEES AND VALUE OF SHIPMENTS BY GEOGRAPHICAL
                                    REGION, SIC-2511*
                                   No.  of Employees      Value of Shipments
                                       (1000)                 ($ Million)        % of
                                   1967   1972  % Chg.   1967  1972   % Chg.   Industry
         Total U.S.                 151.4  195.7  29.3%  2438.9 4267.4  75.0%

         Northeast                  27.1   28.8   6.3%   434.0  631.1  45.4%     14.8%

         North Central              30.4   33.8  11.2%   489.6  817    66.9%     19.1%

         South                      88.0  107.4  22.0%  1318.2 2370.4  79.8%     55.5%

         West                        11.8   25.7 117.8%   197.1  448.9 127.8%     10.6%
        *1972  data  includes SIC-2517  and  2434,  so  the  values  are comparable for a
          real  % of  change.  The  values below  represent 2511 in 1972 without 2517 and
          2434.
        Total U.S. -                151.4   139.6  -11.3%  2438.9  3126.8  28.2%
        Source: 1972 Preliminary  Census of Manufacturers.
                                        18
ADl-l16-1173

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                                   TABLE  II.C.3
                          1972 EMPLOYMENT  PROFILE. SIC-2511
                             WOOD HOUSEHOLD FURNITURE
                % of
              Value of Ship.
U.S.

North Carolina    23.4
South Carolina     1.5
Virginia          13.0
Tennessee          4.2
Indiana            3.9
California         6.6
 % of
Empl. in 2511
Total fl
of Units
  2714
% Units/State: Employee Size
  1-19     20-99     100+
                                60.9
            25.1
14
21.7
12.5
10.3
7.1
7.0
5.8
170
412
65
81
114
392
35.2
54.9
38.3
90.1
42.7
67.5
24.7
— 45.1
16.8
— 9.9
29.7
26.3
40.1
—
44.9
—
27.6
6.2
Source:  1972 Census of  Manufactures.

-------
     The Wood TV and Radio Cabinets Sector (SIC-2517) includes estab-
lishments primarily engaged in manufacturing wood radio, phonograph,
hi-fi, and television cabinets.  This industry also includes establish-
ments primarily engaged in manufacturing sewing machine cabinets.  This
industry is included for the first time in the 1972 Census of Manufac-
tures and so no comparable figures are available for 1967.  In 1972
the value of shipments for this industry was $321 million; average
employment, 18,000.  Cost of materials was $155 million, 42% of which
accounted for wood costs.  Tables II.C.4 and II.C.5 show that the
North Central and South Regions hold over 8070 of the industry's value
of shipments and slightly more of the employment.  60% of the plants
in the U.S. have more than 20 employees, the highest concentration of
those plants in the North Central, 56% of the above 20-employee plant
sites are located here.  The West, on the other hand, has 35% of the
U.S. total of under 20-employee size plants; and 77% of its own plants
are under 20 employees.

     The Wood Office Furniture Sector (SIC-2521) includes establishments
primarily engaged in manufacturing wood office furniture, whether
padded, upholstered, or plain.  In 1972 the value of shipments of this
industry amounted to $248 million, a 57% increase over 1967; value
added by manufacture was 61% above 1967, at $143 million in 1972.
Average employment increased by 39% with 11,400 employees in 1972.
Table II.C.6 shows the percentage of industry in each region (the South
holding 42%) and the percentage change from 1967 in shipments and
employment for each region.  The West shows the greatest relative change,
with employment up 100% and a 161% increase in the value of shipments,
though actual change was greatest in the South with a 827, increase in
employment to 4.9 thousand employees, and a 113% increase in value of
shipments to $106 million.  The employment size unit is fairly evenly
divided in the industry between plants with less than, and those with
greater than, 20 employees (Table II.C.8).  Only the West shows a
disproportion with 70% of the smaller size unit.

     The wood office furniture industry is about 87= of the size of the
wood non-upholstered furniture industry and 5% of the total household
furniture industry.  While the household furniture industry has grown
in value of sales, 41% from 1967, the wood office furniture industry,
however, has grown 57% and the metal office furniture industry, 36.6%.

     The other industries under study here have shown fairly similar
increases in value added/production worker and value of shipments/
production worker (Table II.A.2), only wood office furniture shows a
markedly smaller increase.  While wood household furniture represents
over 86% of the household furniture industry, wood office furniture
represents about 267., of the total office furniture industry; the bulk
of this industry is metal, with plastics holding a small percentage.
Metal's advantages over wood in office furniture are durability, lower
maintenance cost and the possibility of using modular concepts for
replacement in an easier and more precise manner than can be done with
wood.


                                   20

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                               TABLE II.C.4



                     EMPLOYEES AND VALUE OF SHIPMENTS


                     BY GEOGRAPHICAL REGIONS, SIC-2517



                        WOODEN TV AND RADIO CABINETS
                          No of Employees (1000)        Value of Shipments
                                                            ($ Million;

                          1972          % of Ind        1972         2 of Ind




U.S.                      18.2                          321.0




Northeast                  2.2              12.1         52.2          16.3




North Central              7.0              38.5        137.8          42.9




South                      8.5              46.7        122.8          33.3




West                       0.5               2.7          8.3           2.6





  Source:  Census of Manufactures.
                                     21

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                                    TABLE II.C.5
                                1972 EMPLOYMENT  PROFILE
. % of U.S.
Val. Ship.
U.S.
Northeast 16.3
North Central 42.9
South 38.3
West 2.6
SIC-2517
% of U.S. Total #
Empl. in 2517 Units
94
12.1 27
38.5 38
46.7 12
2.7 17
% Reporting
Units/State
Employee
1-19
39.4
48.1
15.8
41.7
76.5
Size
20+
60.6
51.9
94.2
58.3
23.5
     Source:   1972 Census of Manufactures.
                                            22
ADL-116-lin

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                                                TABLE  II.C.6
                    U.S.
                    Northeast
NJ
                    North Central
                    South
                    West
SIC-2521
No. of Employees (1000) Value & Shipments $ Mil
1967 1972 % Chg 1967 1972 % Chg % of
8.2 11.4 39.0 158.3 248.1
2.3 2.3 0 47.9 49.3
2.8 3.0 7.1 49.5 61.2
2.6 4.9 82.1 49.8 106.2
0.6 1.2 100 11.1 29.0
56.7
2.9 19.9
23.6 24.7
113.3 42.8
161.3 11.7
                    Source:  1972 Census of Manufactures.

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                                      TA8LR II.C.7
    U.S.
    Northwest
    North Central
    South
    West
                                1972 EMPLOYMENT PROFILE t
                                 WOOD OFFICE FURNITURE


                        % of U.S.      % of U.S.   Total  //
                       Val. of Ship. Empl. in 2521  Units
                          235
19.9


24.7


42.8


11.7
20.2
26.3
43.0
10.5
58


45


68


64
                                        7,  Reporting
                                        Units/State:
                                        Empl.   Size
                                    1-19        20+
56.6


56.9


54.6


44.1


70.3
43.4


43.1


44.4


55.9


29.7
    Source:  1972 Census of Manufactures
                                           24
ADI-II4-II73

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     Growth of office furniture market depends upon new office con-
struction, replacement demand and style.  The market growth has paral-
leled the recent rapid growth in new office construction and numbers
of white collar workers.

     The Public Building and Related Furniture Sector (SIC-2531)
includes establishments primarily engaged in manufacturing furniture
for schools, theaters, assembly halls, churches and libraries.  Those
establishments primarily engaged in manufacturing seats for public
conveyances, as well as seats for automobiles and aircraft are also
included.

     In 1972 the Value of Shipments for this industry was $522.1
million, a 24% increase over 1967.  Value added by manufacture also
increased 24% to $289 million, while employment decreased 8% to
approximately 21 thousand employees.  Table II.C.8 shows that the
greatest concentration of this industry is in the East North Central,
and the South as a whole is again a major region with 27% of the in-
dustry as compared to 43% for the North Central.  Table II.C.9 shows
a profile of the employment and unit-size, the industry favoring the
smaller unit a bit, though in the areas of greatest concentration.
There is a fairly even split between large and small size units.

     Many comments applicable to office furniture apply here  but
school seating is estimated to be the most important sector of this
market, accounting for about half of total sales.  Future growth in
this market, however, is small (2%) with molded plastics the principal
material used.  Our surveys show 60% of total classroom seatings are
now made of thermoformed plastic, -15% are fiber glass, 10% are solid
plastic, and about 15% of wood and steel.  Only 17% of the materials
consumed were of wood in 1972, 18% of wood in 1967.

     The Wood Partitions and Fixtures Sector (SIC-2541) includes estab-
lishments primarily engaged in manufacturing wood shelving,  lockers,
office and store fixtures,  prefabricated partitions and related fabri-
cated products.

     In 1972 the value of products shipped in this industry was $780
million,an increase of 56% compared with 1967.  Value added by manu-
facture at $432 million was 52% above 1967, and average employment
showed an increase of 2078.

     Table II.C.10 shows that though the concentration of the industry,
close to 60%, is in the Northeast and North Central states,  the great-
est increases between 1967  and 1972 have taken place in the South
Atlantic and East South Central States.  This industry leans heavily
toward the smaller size plants (Table II.C.ll) with close to 75% of
the industry units having under 20 employees.
                                  25

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                                                 TABLE II.C.8

                               EMPLOYEES AND VALUE  OF  SHIPMENTS BY  GEOGRAPHICAL
                                               REGION,  SIC-2531~~
                                       No.  of Employees (1,000)      Val. of  Shipments  ($ Mil)
                                       1967
        1972    % chg.
                     1967
                     1972    % chg.    % of Ind.
                     U.S.
22.6
20.7
-8.4
421.2   522.1
                                                                                    24.0
K)
                     New England        1.0       .8    -20
                     Middle Atlantic     2.4      1.9    -20.3
                             18.2
                             48.8
                             21.8
                             51.2
                             19.8
                              7.0
                             4.2
                             9.8
                     East  North Central  6.9     7.1     2.9
                     West  North Central  1.0     1.2    20.0
                            136.1
                             19.2
                            194.2
                             31.8
                             42.7
                             65.6
                            37.2
                             6.1
                     South Atlantic     2.3
                     East South  Central   .9
                     West South  Central 3.7
1.5
1.4
3.5
-34.8
55.6
-5.4
30.3
16.2
64.2
28.8
35.7
76.9
-5.0
120.4
51.1
5.5
6.8
14.7
                    Mountain
                    Pacific
  .2      .4    100.0
 4.2     2.9     31.0
                      4.3
                    '83.9
                      7.7
                     74.0
                 79.1
                -11.8
 1.5
14.2
                    Source:  1972 Census of Manufactures.

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                                 TABLE II.C.9

                       1972 EMPLOYMENT PROFILE. SIC-2531

                   % of U.S.        % of U.S.        Total #        % Units/Stats: Empl.
                 Value of Ship   Empl. in 2531      Units          Site  1-19 20 +

U.S.                                                 412           54.9    45.1


Northeast           14.0              13.0           78            60.3    39.7
North Central       43.3              40.1          133            51.9    48.1
South               27.1              30.9          124            48.4    51.6
West                15.6              15.9           77            64.9    35.1
Source;  1972 Census of Manufactures.

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                             TABLE II.C.10
*
EMPLOYEE'S AND' VALUE OF SHIPMENTS BY GEOGRAPHICAL

REGION^
No. of Employees
1967
U.S. 25.3
New England 1.6
Middle Atlantic 6.4
East North Central 6.2
West North Central 1.3
South Atlantic 2.9
East South Central .9
West South Central 1.9
West 4.0
1972 %
30.4
1.6
7.2
6.9
1.7
4.5
1.4
2.1
5.0
SIC-2541
(1,000)
chg.
20.2
0
12.5
11.3
30.8
55.2
55.6
10.5
25.0
Value
1967
498.6
30.5
129.1
131.2
25.9
48.6
17.8
30.7
84.9
of Shipments ($ M )
1972 % chg.
780.1 56.5
46.0 50.8 5.9
179.9 39.3 23.1
184.3 40.5 23.6
44.5 63.1 5.7
97.2 100.0 12.5
37.0 107.9 4.7
48.9 58.9 6.3
142.3 67.6 18.2
TABLE II.C.ll
1972 EMPLOYMENT
% of U.S.
Val. of Ship
U.S.
Northeast 29.0
North Central 29.3
South 23.5
West 18.2
% of
Empl .

28
28
26
6
PROFILE
U.S.
in 2541

.9
.3
,3
.0
SIC-2541
Total #
Units
1488
403
401
328
356
%Units/States: Empl. Size
1-19 20+
72.8 27.1
69.7 30.3
74.5 25.4
70.8 29.2
76.4 23.6
Source;  Census of Manufactures.
                                       28

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      1.   Types  of  Firms

      As  demonstrated  in  Section  II.A  (Overview),  the  furniture manu-
 facturing industry is  comprised  of firms which  are  generally small and
 privately controlled.  No  single manufacturer controls more  than 37» of
 the  total market.   This  is  true historically and  pertains  today,
 although there  have been acquisitions  of large, independent  furniture
 manufacturers by multi-industry  firms, e.g., Champion International
 (Drexel  and Heritage)  and Armstrong Cork (Thomasville).  The lack of
 concentration in the  industry  is indicated by the following  table:

              No.  of Firms             % of Total  Industry  Sales

           10 largest producers            Less  than 20%

           25 largest producers            25%

           3,600 smallest producers        Less  than 10%


      Backward vertical integration of  firms in  these  sectors is  possible
 only  for the largest manufacturers.  The firms  generally do  not  own
 their own woodlands; rather, they purchase logs and process  them for
 their own use.  Many firms  also do not have cutting facilities;  rather,
 they  buy wood and  wood products in "cut-to-size"  configurations  for
 assembly and finishing in-house.

      Forward vertical  integration into the marketplace is  also limited.
 Firms generally do not own  distribution outlets.  Rather,  they sell
 through  independent or franchised, local businesses to consumers.

      Integration into  complementary home furnishings, such as  lamps,
 draperies, carpets, and  other household accessories,  is a  major  goal
 for large  firms in the furniture industry.   Such  integration is  intended
 to improve the  marketing effectiveness of such  firms  as well as  to
 yield additional avenues for growth.   Many acquisitions of furniture
 companies have  been based on the objective to be a  full line home  fur-
 nishings  supplier.  However, again, this option is  only viable  for the
 largest  25-50 firms.

      Although the  industry  is fragmented,  the large companies  do have
 the greatest influence on   the marketplace.   The small,  individually
 owned and operated firms concentrate  on specialty markets  or become
 supporting suppliers for the largest  companies.   Other smaller manu-
 facturers are considering mergers with other small  companies or joint
ventures to insure adequate raw material supplies and to gain greater
market control.   As large retail chains capable of merchandising a
broad line of home furnishings through franchise programs  gain share
of market, pressures for consolidation will  increase.
                                  29

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      2.  Types  of Plants

      Plants within the non-upholstered manufacturing  sector  are  quite
 small.  Table II.C.12 demonstrates that  for the entire  sector, 607, of
 the plants have less than  19 employees.  Additionally,  approximately
 20-257, of the plants have  20-99 employees, indicating that 80-85% of
 the plants have fewer than 100 employees.  At an average value of
 $26,000 per production worker, this suggests that  in  60% of  the  industry
 the average plant generates less than $500,000 annual sales.

      The plant  size pattern is consistent for each of the individual
 subsectors covered under Non-upholstered Furniture, with the exception
 of SIC-2541, which is represented by even smaller plants.  However,
 2541  is not a major subsector and only reinforces the fact that  the
 plants in this  industry are indeed small.

      The small  manufacturer uses the same production  process as  its
 larger counterpart, although it substitutes labor  for capital equipment.
 Further, while  the small manufacturer buys raw materials from the  same
 suppliers as the larger companies,  it may have to sacrifice small
 quality increments in order to compensate for the extra cost of  small
 orders.   By doLng this,  the small manufacturer is able  to main its cost
 of gpods sold at approximately the same ratio to sales as for the
 larger manufacturers,  even though the small manufacturer does not
 obtain quantity discounts.

     As  noted above in Section II.B,  our survey of the  industry  indi-
 cates that water wash spray booths  are only found in  large plants.
 During the past 10-15 years the use of water wash spray booths has
 increased rapidly; we estimate that about 50-6070 of the larger non-
 upholstered furniture plants in the U.S. use this device.   However,
 due to the relatively high investment costs and relatively low through-
 put,   such equipment is not  generally found in medium-sized plants; it
 is never found  in small-sized plants.   The technological alternatives
 to water wash spray booths  are hand rubbing or use of filter booths.

     Laundry operations  are found in all sizes of furniture plants.
 However, during the last ten years  plants have not expanded laundry
 facilities as operations expanded.   Rather,  they have reduced the
 scope of laundry operations or eliminated in-plant laundry facilities
 completely.   An in-plant laundry represents additional  labor charges
 and labor recruitment.   The cost of and difficulty to find labor has
 led companies to contract with suppliers of  laundry service to either
 supply rags  or to launder the firm's rags.  The trend away from  in-plant
 laundries is definitive  and will continue, now spurred by the need to
 control  (laundry) effluent.  Our studies have not identified any firms
unable to close in-plant laundries  due to unavailability of local
 laundry  services.
                                  30

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                                    TABLE II.C. 12




                               PLANT SIZE DISTRIBUTION -




                       NONUPHOLSTERED FURNITURE MANUFACTURING
 SIC









2511




2521




2531




2541







All Sectors
Plant Size - # of Employees
Mean
61
58
57
22

1-19
60.9
56.6
54.9
72.8
59.9
20-99
.25.1
v 	 -" ""NX"-—"
^»
43.4
45.1
27.1
40.1
100+
14 .JV




Source;  1972 Preliminary  Census of Manufactures.

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      3.  Financial Profiles

      Table II.C.13 develops model plants for the non-upholstered
 furniture manufacturers.  These model plants are intended to  focus
 upon  the sectors of the industry most likely to be affected.  That
 is, the small-sized plant (eighteen employees, $391,000 annual sales)
 is a  very small plant; even our medium-sized plant (53 employees,
 $1.175 million annual sales) is considered a small plant in the
 industry.  However, since it is the small plants which are most sensi-
 tive  to small cost increments and thus are most likely to be  affected
 by costs to comply with effluent regulations, it is necessary to
 emphasize the smaller plants.

      The financial condition of the small- and medium-sized plants  is
 less  favorable than that of our large-model plant.  Some of this  is
 due to the effects of economies of scale and forward integration  (the
 greater ability to control the marketplace on the part of the large
 manufacturers).  In addition, the net profit figure is reduced further
 since the smaller, privately-held firms tend to take income in the
 form  of salaries and fringe benefits, rather than show the income on
 the "bottom line."  Nonetheless, our model small firm is not  in a
 strong positicn, with an annual cash flow of $13,300.

      While the financial profiles indicate a slightly higher  profit
 margin for meoium-sized plants than small-sized plants (2.6%  sales
 before tax v. 2.2%), and a slightly lower return on net assets (5.0%
 x 5.2%), these differences are not significant.  Higher profitability
 occurs at a much larger size level ($5-6 million sales) as evidenced
 by the fact that the large model firm has nearly double the financial
 performance (pretax margin 7.37,, return on net assets 9.470) than  either
 other model plant.  Further, capital productivity ($ asset:s/$ sales)
 is essentially the same for small and medium plants (0.24, 0.256),
 but is much higher (0.374) for the large plant.

     A.  Pricing

     The demand for furniture is relatively inelastic and depends to a
 great extent on trends in consumer disposable income, family  formations,
 population growth and new housing starts.  Demand for new furniture
arises primarily from new family formations (which dictate initial pur-
chases); from changes in residence,  including moves into newly built
homes; and from wearing-out or style obsolescence of existing furniture.
New family formations account for as much as one-third of the total
demand for new home furnishings, of which furniture is the most impor-
 tant single purchase.  Some advance in household formations (both
 through marriages and the trend to second homes) is expected  over the
next few years.  Furthermore, with the trend to later marriages and
higher incomes of the new households, furniture purchases per family
 can be expected to be at slightly higher levels during the 1970's than
 previous decades.
                                  32

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                                TABLE II.C.13
                      FINANCIAL PROFILE FOR NONUPHOLSTERED
                              FURNITURE MANUFACTURE
                                  Small
Net Sales

Cost of Sales

  SG&A

Income Before Tax

Net Income



Net Assets

Net Fixed Assets

Return on Net Assets

Cash Flow

# of Employees

$ Assets
$ Sales
     $         %
391,000    100.0

299,000     76.6

 83,000     21.2

 10,000      2.2

  5,000      1.1



 94,000

 34,000
 13,300
             5.2%"
         18


       0.240
Medium
$ %
1,175,000 100.0
952,000 81.0
193,000 16.4
30,000 2.6
15,000 1.3
300,000
125,000
Large
$ %
6,274,000 100.0
4,605,000 73.5
230,000 19.2
439,000 7.3
220,000 3.7
2,350,000
930,000
40,500
            5.0%
354,500
            9.4
        53
      0.256
        295
       0.374
Source:  Arthur D. Little, Inc., estimates.

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     The household furniture industry has traditionally used a two-
level marketing system: an exhibit system or "market" to bring together
manufacturers and retailers, and independent retailers to sell the
finished product to consumers.  The manufacturers exhibit their offer-
ings to buyers at semi-annual shows in various regions throughout the
United States.  This system has done much to foster the inward orienta-
tion of the furniture manufacturers, as the retail store buyers insulate
the manufacturers from the consumer.  In their desire to bring new and
exciting products to the retail market, the buyers often demand style,
design, and product changes that result in substantial manufacturing
diseconomies.  Although both furniture manufacturers and retailers agree
that too many shows are being held, they demonstrate little inclination
to reduce the number of shows.

     Up to this point, while the industry has been comprised of many
small manufacturers and retailers, the exhibit system has been the best
vehicle for their interaction.  Now, however, with the evolution of
large furniture marketers (e.g., Wickes) capable of supporting the
direct sales costs of franchise programs or retail outlet ownership,
we expect changes in marketing patterns.  Warehouse-showroom retailing
offers large in-depth inventories that permit immediate carry-out or
delivery at substantially reduced prices from normal retail furniture
outlets (10-25%).

     Price leadership on an industry-wide bf.sis is not present in the
furniture industry.   And,although firms directly competitive watch each
other's prices closely, there is no consistent practice of following one
or a few price leaders.  Great variation in the quality levels of the
product, styles and promotional efforts make direct price comparisons
difficult for the majority of firms in the industry.  IndLvidual firms
may adopt a policy of following the price pattern of a close competitor,
but there is no industry-wide following of a price leader or leaders
as it occurs in some other industries.

     At the consumer level, prices are exceedingly difficult to com-
pare.  As noted above, there are nearly an infinite number of varia-
tions in styles,  colors, wood used, etc., which virtually eliminates
the ability to make direct price comparisons.  A consumer generally
chooses a piece of furniture because it is within his price range,
and is of a style and color to match well with other articles of
furnishings in the home or apartment.  A price range in which the
consumer is relatively insensitive to price may be as wide as 5-10%,
that is, a consumer will choose one item over another, even though
it may be 107, more expensive, simply because he likes it.  A consumer
does not generally buy a cheaper, less attractive item simply to save
5%.  A consumer may defer the purchase until a later time, to await a
period of greater financial capacity, or may wait for the item to go
on sale.  However, the consumer will usually not trade-off one piece
                                  34

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 of  furniture versus another strictly based on a  5-10%  lower  price.
 While  this conclusion of relative price  insensitivity  is an  important
 characteristic of the industry,  it  is not the critical  factor under-
 pinning  the economic impact analysis (Section V).  Rather, such  factors
 PS  levels of costs associated with  proposed Guidelines  and the avail-
 ability  of capital and lower-cost compliance technologies are more important.

     Prices of wood furniture in general have risen about 3%/year over
 the past decade.  Furniture prices  rose between  December 1972 and
 December 1973, 5.2 percent at the retail level and 7.3  percent at the
 producer level.  In addition to the influence of strong consumer demand,
 which was spurred by increases in disposable income and home construc-
 tion, rising costs for wages and materials exerted persistent upward
 pressure on prices.  Raw materials  and wage costs are  likely to rise
 and contribute to upward operating  costs and higher prices during the
 year.

 D.  UPHOLSTERED FURNITURE

     The Upholstered Household Furniture Sector  includes establishments
 primarily engaged in manufacturing  upholster 3d furniture on wood frames.
 Those establishments primarily engaged in manufacturing wood frames
 for upholstered furniture have been separated from 2512 for  1972 data
 and are  included under SIC-24266.

     To  a large extent the small-scale upholstered furniture manufac-
 turer performs an assembly type operation.  Wood frames, springs, glue,
 cotton and fabrics are purchased only as needed.  Some  capital outlay
 is required for factory space, fabric cutting hand tools and a few
 small assembly tools.  And even the smallest manufacturers carry some
 inventory in materials,  especially  fabrics and frames.  Because uphol-
 stered goods are manufactured largely to order,  inventories and finished
 products are virtually nonexistent.   Naturally,  as output expands, the
 desirability of carrying inventories of raw materials and finished
 goods increases,  and working capital becomes increasingly important.

     The value of shipments of establishments classified under 2512
amounted to $2.1  billion,  an increase of 667° compared with 1967.  With
the inclusion of  24266,  for comparative reasons,  the figure is $2181MM,
an increase of 72%.   While average employment in wood household
furniture,  2511,  was  down 11% from 1967,  in the upholstered furniture
industry employment  showed an increase  of 23% to 92,000 employees in
1972.   The  industry  more than doubled its value of shipments, from 1967
to 1972,  in the West  North Central and  East South Central Region, while
the South Atlantic and West South Central had over 807=,  increases
(Table  II.D.I).  The  South Atlantic, as in sector 2511, holds the
greatest  part of  the  industry shipments,  35%,  but this  industry is not
                                  35

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                                                   TABLE II.D.I
u>
                 Total U.S.

                 New England
                 Middle Atlantic
                 South Atlantic
                 Mountain
                 Pacific
EMPLOYEES AND
VALUE OF SHIPMENTS
BY GEOGRAPHICAL REGION
SIC-2S12
No. of
1967
75.2
3.0
:ic 7.6
^ntral 11.0
sntral 1.9
.c 25.3
sntral 12.5
:ntral 5.4
.7
7.8
Employees
1972 %
92.2'
2.6
6.6
10.5
3.0
32.6
18.8
6.7
1.2
10.2
(1000)
Change
22.6
-13.3
-13.2
-4.5
57.9
28.9
50.4
24.1
71.4
30.8
Value of
1967
1266.4
46.4
132.7
216.5
35.4
416.8
183.4
76.5
12.4
146.2
Shipments
1972 5
2104.3
55.0
151.0
243.1
77.5
751.7
423.9
138.8
20.9
242.4

($ million)
I Change
66.2
18.5
13.8
12.3
118.9
80.4
131.1
81.4
68.5
65.8

% of
Industry
2.6
7.2
11.6
3.9
35.7
20.1
6.6
1.0
11.5
                 Total U.S.
NA
52.4
76.9
                                                                                      46.8
       Source:   1972 Preliminary  Source of Manufactures,

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quite as unevenly distributed over the states.  Table II.D.2 shows
the states which account for over 50% of the employment, with North
Carolina holding the lion's share, 26%, and California and Tennessee
vying for second at 9%.

     1.  Type of Firm

     The fragmentation of this industry sector parallels that of  the
non-upholstered sector, described in Section II.C.I.  In fact,  since
many of the firms manufacture both upholstered and non-upholstered
furniture, it is not always possible to separate  the firms' activities  into
those two categories.  It is only the small firms which specialize entirely  to
the extent of being in only one or the other of the businesses.   In
fact, many manufacturers of upholstered furniture are major merchandi-
sers which purchase fabric, backing, frames, and produce on a custom
basis a particular chair or sofa to meet a customer order.

     2.  Type of Plants

     As is the case for non-upholstered furniture manufacturers,  and
as presented in Table II.D.3, this is an industry of small plants,
i.e., 58% of the plants have 99 or fewer employees and, therefore,
have less than $1.5 million worth of annual sales revenues.

     Very few upholstered furniture manufacturers have in-plant
laundry facilities.  The cost of the facilities is simply not justified
by the little amount of hand finishing and, therefore,  the little
amount of cloths which are needed.

     Companies maintain a small inventory of sprung frames and a very
large inventory of fabrics.  Most of the business is custom, made-to-
order business.

     Typically, the small manufacturer will buy a few standard makeup
frames and will spring them according to standard industry techniques.

     The small manufacturer buys cotton backing and foam from the same
suppliers as the larger companies but may sacrifice small quality incre-
ments in order to compensate for the extra cost of small orders.
Manufacturers are able to offer a very large number of patterns and
colors of cloth, perhaps as many as 500 for even a small operation
through the use of "books" supplied by fabric jobbers.   By sacrificing
some quality and having the inventory carried by a fabric jobber  and
spread over a number of accounts, the small manufacturer is able  to
maintain a cost of goods sold at approximately the same percentage of
net sales as that of a large manufacturer.
                                  37

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                                                    TABLE II.D.2
U)
oo
U.S.



North Carolina


California


Tennessee


Mississippi
19 72' EMPLOYMENT PROtlLE. SIC-2512
% of U.S. Volume
of Shipments


26.2
10.3
8.1
10.2
% of U.S. Total #
Empl. in 2512 Units

1501
26.6 286
9.3 259
9.2 94
7.3 38
% Reporting Units/State:
Employee Size
1-19 20-99 100+
47.0 37.5 15.5
36.6 38.2 22.2
56.7 37.1 6.2
38.3 	 61.7 	
29.0 29.0 42.0
                Source:  Preliminary Census of Manufactures.

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                                                    TABLE II.P.?

                                         TYPICAL PLANTS  FOR INDUSTRY.  SIC 2512
                                               #  of Employees     Sales  (Million $)     Plants
                                               Ave. Total    %     Ave.   Total   %     #     %
LJ
                           Small

                           Medium

                           Large
  8.3  5863

 48.2 27164

258.7 60282
 .187   132.2

1.087   623.8

5.834  1359.4
705   47.0%

563 .  37.5%

233   15.5%
                      *Percentage of  Total  Industry  in  this  Sector,
                       Source;   1972  Preliminary Census of Manufactures.

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     3.  Financial Profiles

     Table II.D.4 presents the financial profiles for small, medium,
and large-sized companies in this industry sector.  Again, we have
stressed smaller plants since they are the most likely to be affected
by abatement costs.

     Again, as with non-upholstered plants, profitability is essentially
identical for small- and medium-sized plants, with large plants subr
stantially more profitable.

     4.  Pricing

     The pricing dynamics in the furniture industry are analogous for
either upholstered or non-upholstered household furniture.  Thus, the
discussion in Section II.C.4 is relevant for this discussion of uphol-
stered furniture as well.
                                   40

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                               TABLE  II.D.4

                 FINANCIAL PROFILE  FOR MODEL  COMPANIES. SIC 2512
                           Small
                      Medium
                      Large
Net Sales

Cost of Sales



Income Before Tax

Net Income

Net Assets

Net Fixed Assets

Return on Net Assets

Cash Flow

# of Employees
$ y
9 _
532,000 100.0
514,000 96.5
18,000 3.5
9,000 1.8
138,000
26,000
$ %
1,386,000 100.0
1,339,000 96.6
45,000 3.4
82,500 1.7
360,000
116,000
i
7,033,000
6,590,000
443,000
221,500
2,415,000
990,000
1
100.0
93.5
6.5
3.3


          6.4
16,200
      24
          6.2
36,700
       61
           9.2
312,963
        312
  $ Assets
  $ Sales
 0.258
 0.260
  0.348
  Source;  Arthur D.  Little,  Inc.,  estimates.

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                            Ill.   METHODOLOGY
     Since there are many small, privately held firms in this industry,
which do not generally publish financial or other statistics on their
operations, data had to be developed on the various industry segments
through Department of Commerce information, surveys of firms in the in^
dustry, surveys of industry associations and others knowledgeable of
industry practice and background data which we have accumulated over time,
             /
     To accomplish the Economic Impact Analysis, the data on the struc-
ture of this industry was used to develop industry segments of groups of
firms which would be differentially affected by guidelines and costs,
and was applied to an analytical model with the focus on the following
critical issues.

         The probability that cost of compliance will be able
         to be passed on to consumers via increase in product
         cost or will have to be absorbed by operators, result-
         ing in a lower level of profitability; and,

         If costs cannot be passed through, the extent to which
         the resultant effect on financial condition and capital
         availability will cause plant closures, unemployment,
         community impacts, and restrict industry growth.

         The extent to which capital availability will be limited for
         the numerous small operators, also causing plant closures,
         unemployment, and community impacts, and restricting industry
         growth.

A.   DATA GATHERING

     Data available on firms within this industry is fragmented and in-
complete.  The Department of Commerce, through its Census of "Manufactures
and other like information, represents a general body of macroeconomic
information applicable to this industry.  However, since so many of
these firms are privately held and therefore do not disclose financial or
other operating information in any detail, that information and other
similar publicly-available information represents only a general and
incomplete description of this industry.

     Thus, we developed new data which we believe to be an adequate base
for the analysis on industry practices and representative financial data
through:

         Interviews of individual companies;

         Interviews with trade associations and others knowledgeable
         in the industry and;

         Reliance on the assignment team's own knowledge of the
         industry and relevant experience of colleagues.
                                   42

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 B.    PRICE  EFFECTS

      The  analysis of whether  prices  are  likely  (or  not  likely)  to  be
 able  to be  passed on is  a  relatively straightforward  economic analysis.
 Table III.B.l^presents the price  increase  analysis  matrix which we used
 to  derive price  increase conclusions.

      If the annual  treatment  cost (before  tax)  represents a  significant
 percentage  of  the selling  price,  it  will be difficult to pass this on to
 consumers.   This is particularly  true  in an industry  which is character-
 ized  by a high level of  price elasticity of demand.   In price insensitive
 industries, a  5% price  increase  can be  readily passed  on.   In  other  Timber
 Products  Processing Industry  sectors,  a  before  tax  treatment cost  greater
 than  10%  of selling price  seriously  hampers the ability to pass the cost
 increase  on to consumers.


       A high occurrence  of readily-substituted  products will limit the
 ability to  pass  on  cost  increases through  increased prices.  Similarly,
 if  demand is elastic  (sensitive to price), the  ability  to pass  on  price
 increases is limited.

      A uniformly low operating  rate within the  industry would also  con-
 strain such increases.   Companies with low operating  rates are more
 likely to absorb cost increases in an attempt to maintain or increase
 present operating rates  rather  than attempting  to pass  through  cost
 increases.
                                                    /

      Typically, a critical factor to analyze is the extent to which plants
 within the  industry have to absorb comparable abatement costs.   If  costs
 are unequally  distributed  throughout an  industry, producers which  do not
 have  to make an  investment or can make less of  an investment obtain a
 strategic cost advantage.  A  low-cost producer will tend to.  absorb
 abatement costs, particularly if  the abatement  costs  to the  low-cost
 producer are smaller than  for the industry as a whole,  to put the  other
 plants in the  industry at  a cost disadvantage.

      If products are sold within an industry on the basis of price
 rather than quality, service, etc., then cost increases are  likely  to be
 absorbed rather  than passed through.   Similarly, if market shares  are
 generally small  for any  individual firm or plant, then price competition
 is likely to be severe and cost increases are likely  to be absorbed.

     Table  III.B.I and the underlying analysis  is applicable to the
 furniture industry as a whole.  However large firms, while not able to
 influence the market and prices dramatically,  do have more leverage than
do small firms.  Thus,  the larger the firm (and the higher its share-of-
market), the greater its ability to pass on cost increases.

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                     TABLE III.B.I
             PRICE INCREASE ANALYSIS MATRIX
               Price Increase Constraints
Factor


Ratio of Before Tax Treatment Cost
To Selling Price (%)

Substitute Products

Capacity Utilization

Captive Usage

Demand Growth

Foreign Competition

Abatement Cost Differences

Price Elasticity of Demand

Basis for Competition

Market Share Distribution

Number of Producers
 Condition for
  Constraint
     High


High Occurrence

     Low

     Low

     Low

     High

    Unequal

     High

     Price

   Fragmented

     Many
                          44

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C.   PLANT CLOSURE EFFECTS

     Even if prices are not likely to be increased, and costs are absorbed
with relatively well-documented financial effects, it is difficult to
reach conclusions regarding plant closures.  The plant closure analysis
matrix which was used to focus upon the central issues in these decisions
is presented as Table III.C.I.  The analysis is complicated by the fact
that small, family-owned and operated, one-plant firms tend to show
remarkable "staying power" in the face of extremely low rates of profit^
ability and other burdens.  The extent of subjective commitment to the
business beyond the point at which standard financial analysis would
suggest shutdown is an extremely difficult factor to measure and assess.
Nonetheless, subjective elements must be necessarily used to supplement
the objective analysis, since objective economic analysis would tend to
overstate the extent of plant closures.

     The three fundamental issues to focus upon are:

         Extent of integration - If a plant is  part of an extensive manu-
         facturing operation,  it is likely to be kept open even if
         financial impacts are relatively severe.   For example, an
         insulation board manufacturing plant can be an efficient
         consumer of otherwise low-value waste  product (sawdust,
         shavings, etc.)  from a sawmill or planing mill located on
         a common site.

         Other facilities on a common site - An isolated plant is
         most vulnerable  for the reasons described in the inte-
         gration discussion above.

         Ownership - A large,  multi-industry firm would tend to
         make a shutdown  decision based on "rational" business
         analysis, such as effects  on profitability.   Such a
         firm would likely have specific criteria for each of its
         operating facilities  to meet.   However, a private owner
         tends to have greater "staying power," a greater sub-
         jective   commitment  to staying in business even if
         profitability is substantially reduced.  This is true
         for such reasons as the fact that the  plant
         has been in the  family for generations, but also such
         specific economic reasons  as the fact  that this may
         be a particular  family's sole or primary source of income.
                                   45

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             TABLE III.C.I
      PLANT CLOSURE ANALYSIS MATRIX
         Plant Shutdown Decision
Factor
Condition for
 Shutdown
Ration of After Tax Treatment
Cost at After Tax Net Income (%)    High
Cash Flow (Including Treat-
ment Costs)                       Negative
Ratio of Investment in Treat-
ment Facilities to Net Fixed
Investment (%)
    Low
Integration
    Low
Multi-Plant Complex
Isolated Plant
Other Environmental Problems
(Including OSHA)                  Multiple
Emotional Commitment
Indifference
Ownership
Large, Multi-
Industry Company

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D.   SEGMENTATION

     The objective of segmenting the industry was to group plants into
categories which might be affected similarly by pollution control require-
ments.  For this industry, the costs of compliance and technologies to
comply can be directly related to the type of process performed.  Pro-
cesses performed within plants vary by product mix only to the extent
that upholstered furniture manufacturers do far less finishing and
generate less effluent than do non-upholstered manufacturers.  Thus, the
cost of compliance will fall differently upon plants in each of these
two primary categories.

     Within each of these two primary segments, effects are directly related
to the size of plant.  There are many very small plants in this industry;
i.e., more than 60% of the plants have less than 20 employees and generate
less than $500,000 in annual sales revenues.  Such plants are quite
sensitive to cost increments which may be small in an absolute sense
($5,000-$10,000) but which represent a relatively large ratio to present
costs (10-20% of revenues).  Thus, plant size is the second important
criterion used to segment the industry.
                                   47

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                         IV.   COSTS  OF  COMPLIANCE
      The Development  Document  concludes  that  subcategorization  of  the
 furniture industry  for  developing  effluent  guidelines  and  standards
 should  be based  on  water  usage.  Other factors such as  process  variation,
 nature  of raw  materials,  plant  size and  age,  nature of  water supply,
 plant location and  land availability were determined to be of secondary
 importance.  The volume of waste water generated by the furniture  in-
 dustry  is not  very  large, although increased  usage is  shown by  plants
 which have water wash spray booths and in-plant laundry facilities.  Wet
 scrubbers as emission control devices in some plants are also a source
 of water pollution.

      Costs of  compliance  as reported in  the Development Document are based
 on the  effluent  loads of  large  plants.   Thus, those costs  overstate the
 burden  small plants would face.  However, since we have no estimates of
 the effect of  scale,  we used these costs and, thus, performed a "worst
 case" analysis.*

 A.  MODEL PLANTS

     Model plants were  formulated  in the Development Document on the
 basis of  presence of water wash spray booths  and in-plant  laundry  facil-
 ities,  the two major  contributors  to wastewaier volume.  All plants were
 assumed  to have  two glue  spreaders which generate a wastewater volume
 from cleanup operations.

          Model 1 - Contains only dry booths, no laundry facilities,
          two glue spreaders.

          Model 2 - Contains dry booths,  laundry facilities, two
          glue spreaders.

         Model 3 - Contains water wash (wet) spray booths, no
          laundry, two glue spreaders.

         Model 4 - Contains both water wash booths and  laundry
          facilities, two glue spreaders.

The volume of plant wastewater depends on the size and number of water
wash spray booths and the  number of loads of laundry washed each day.
The wastewater from these  two sources  is  generally very concentrated,
alkaline, highly-colored,  and with high  levels of BOD and COD.   At
present,  these streams may or may nor,  be  discharged from a given plant.
*Note:  A small plant (less than 20 employees) probably generates less
        than 500 gallons of effluent process water daily and as much
        as 500-1000 gallons of sanitary waste water daily.

-------
In order to develop investment and operating costs for the model plants,
certain assumptions were necessary regarding the volume of wastewater to
be treated; these were:

         Model 1 - 200 gallons/day for glue spreader clean-up.

         Model 2 - 1200 gallons/day for clean-up and laundry.

         Model 3 - 680 gallons/day for clean-up and water wash
         spray booths.

         Model 4 - 1680 gallons/day for clean-up, laundry and
         water wash spray booths.

B.  ALTERNATIVE CONTROL METHODS

     The following treatment technologies were considered applicable for
furniture plant effluents:

         Alternative B - Trucking from plant to landfill area.

         Alternative C - Incineration via spraying on hog fuel.

         Alternative D - Evaporation from shallow ponds using
         mechanical spray units in some areas where precipi-
         tation exceeds evaporation (e.g., North Carolina  New
         England, Michigan).

         Alternative E - Aeration ponds combined with spray
         irrigation of settled skimmed and treated wastewater.
         This is judged applicable only to Models 2 and 4 which
         have laundry facilities.

C.  OPERATING AND INVESTMENT COSTS USING BPT

     The Development Document concludes that zero discharge for furniture
plants is possible using any of the alternative control technologies.
Table IV.C.I summarizes the estimated investment and operating costs for
BPT.  Alternative D includes costs for both shallow ponds and ponds
combined with mechanical spray units.

D.  COST IMPACT

     Table IV.D.I estimates the costs of compliance for the various  in-
dustry sectors.  For these firms,  the costs represent the probable
technologies firms will elect to institute to comply with 1977 Guidelines.
The small- and medium-sized firms generate less effluent and can more
easily opt for lower cost methods of abatement.  All firms are assumed to
choose the land fill alternative.
                                    49

-------
                                             TABLE IV.D.I
                           COSTS OF COMPLIANCE* - FURNITURE MANUFACTURERS
Segment

Non-upholstered mfrs.

    Large Plants

    Medium Plants

    Small Plants

       subtotal
Total
Plants
   552

  1191

  2853

  4596
Number of   Probable               Probable
 Plants      Capital     % Net      Annual
Affected      Cost       Assets      Cost
   55

  119

  285

  459
$ 4,500       0.2%     $ 9,300

  4,500       1.5        9,300

  3,200       3.4        6,680
% Sales



 0.15%

 0.8

 1.7
Upholstered mfrs.

    Large Plants

    Medium Plants

    Small Plants

       subtotal
233
563
705
1501
23
56
._7Q
149
                          3,200       0.13

                          3,200       0.9

                          3,200       2.3
6,680
6,680
6,680
0.1
0.5
1.3
Total                      6097         608
*BPT, BAT, NSPS on proposed  Guidelines.
         Arthur D. Little, Inc. Estimates:   Development Document

-------
                      V.  ECONOMIC IMPACT ANALYSIS
A.  INTRODUCTION

     This section assesses the economic impact on the furniture industry
to comply with proposed Effluent Guidelines.  The investment and operat-
ing costs for the alternative methods of treating plant effluents used
in our analysis are taken from the Development Document.

     1.  Industry Segments

     The furniture industry has many small operations, e.g., about 60%
of the total number of plants have less than 100 employees; many are
privately owned.  The ability of the small producer to cope with pollu-*-
tion abatement costs is the central issue to analyze in assessing the
economic impact on the industry.  Plants with less than 100 employees are
most vulnerable.

     The volume of wood finishing associated with upholstered furniture
plants is very small relative to non-upholstered establishments.  The
potential for water pollution by producers in the categories is different.
Thus, they were analyzed separately, i.e., companies in SIC-2512 (upholstered
furniture) were separated from the rest of the industry.  Table V.A.I
shows the number of plants and number of employees in these two major
segments of the industry.

     It is possible to relate plant size to the use of water wash spray
booths (for wood finishing), which is a significant source of effluent.
In the past 10-15 years the use of water wash spray booths has increased
rapidly; our surveys indicate they are found in about 50-60% of the
larger non-upholstered furniture plants in the U.S.  They are not
generally found in medium-sized plants and essentially never in small
plants, because of the relatively high investment cost; there are less
expensive and adequate alternatives available such as hand rubbing or
the use of filter booths.  Upholstered furniture plants, with the
exception of a few specialized situations, do not have water wash spray
booths.

     Any size plant may have in-plant laundry facilities.  There are
fewer laundries in the upholstered furniture segment of the industry
because there are fewer  wood finishing operations.  Thus, it is not
feasible to relate plant size to laundry facilities.

     Thus,  the economic impact analysis can be accomplished based on the
operating and investment costs from the Development Document by allocat-
ing small,  medium, and large size plants to their treatment model plants
as shown in Table V.A.2.
                                   51

-------
                          TABLE V.A.I
     .  NUMBER OF  PLANTS AND  EMPLOYEES FOR VARIOUS SIZE FURNITURE PLANTS
   SIC No.   -  2511,  2517
   2521,  2531,  2541  (non-upholstered)
 Total
No. Plants
   Total
No. Employees
                Small
   2853
  20,280
                Medium
   1191
  50,570
                Large
                                   total
   _5J!_
  4,596
 151.713
 222,563
   SIC No.   - 2512 (Upholstered)
                Small
                Medium
                Large
                                    total
                              GRAND TOTAL
705
563
233
1,501
6,097
5,863
27,164
60,282
93,309
315,872
Source: U.S.  Dcpt.  o£ Commerce  and Arthur  D.  Little,  Inc.,  estimates,
                                      52

-------
                                 TABLE V.A.2

                          NUMBER OF PLANTS AFFECTED BY
                EFFLUENT GUIDELINES - WOOD FURNITURE MANUFACTURING
Non-upholstered


      Small


      Medium


      Large
                        Laundry
                        Facilities    Water Wash Booths
Yes - 50%


Yes - 50%


Yes - 50%
No .
                                    Plants/Model (% of

                                        total)
                                         Model
                                   1234
50  50
Yes - 10%   45  45   5   5
Yes - 50%   25  25  25  25
Upholstered


      Small


      Medium


      Large
Yes - 50%
Yes - 50%
Yes - 50%
No
No
No
50  50


50  50


50  50
Source;  Arthur  D. Little, Inc., estimates.
                                       53

-------
      2.   Number  of  Plants Affected

      Wastewater  is  not  a major  problem  in  the  furniture  industry.  The
 Development  Document  reports  that an estimated  95%  of all  furniture
 factories either discharge  their wastewaters to municipal  sewerage
 systems,  contract them  to be  hauled away by commercial disposal  companies,
 or  use a  combination  of these disposal  methods  and  thus  are not  affected
 by  these  Effluent Guidelines.   In our analysis we assumed  that 10% of
 the furniture  plants  would  have to face the additional cost of implement-
 ing pollution  controls.*  Table  V.A.3  summarizes the number of plants and
 number of employees which could be affected by  the  cost  of compliance.
 Assignment to  the various model plant sectors  is based on  the percentages
 shown in  Table V.A.2.

      3.   Minimizing  Impact

      While certain  effluent abatement technologies  presented in  the
 Development  Document  are relatively expensive  for the small plant, there
 are abatement  options available which are  lower cost and will cause no
 impact.   The alternatives available as  control measures  (with the
 exception of spray  irrigation)  can be used by all types  of plants.  In
 addition,  there  are also changes which  can be made  in the plant  to
 reduce the volume of wastewater (for example, eliminating laundry facil-
 ities).   Finally, pricing strategy can  be utilized  to pass pollution
 costs on  to  consumers.

 B.   PRICE EFFECTS

      Costs of  compliance will be passed on through  increased end product
 prices.   However, since the necessary price increase at maximum  is so
 small  (1.7%)^ and since not all firms in the industry will be required to
 make  an investment  (2.2% of sales volume), this price increase will not
 have  a noticeable aggregate effect on the furniture industry or  on its
 prices.

     Table V.B.I analyzes the likelihood of a price increase.   The
 rationale is the same for both upholstered and non-upholstered furniture
manufacturers.

     The key issues as identified in the matrix are that:

         The ratio of before tax treatment cost to selling price
          is very low; a maximum of 1.7%.

         Price  elasticity of demand  is very low; the consumer
         is essentially price insensitive within a band of
         +/- 5%  (see Sections II.C.A and II.D.4 above).
*This yields a somewhat conservative or "worst case" analysis.  Thus, a
 conclusion of significant impact under the "worst case" assumption would
 overstate impact,

                                    54

-------
                                             TABLE V.A.3
NUMBER PLANTS AND
(Present Situation Assumes 90%
Do Not Require
Pollution Controls
Model 1
Type of # // // I
Plant Plants Employ. Plants Employ.
EMPLOYEES IN MODEL PLANTS
Have Disposal Contractor or Are on Sewer)
Require Pollution Controls
Model 2 Model 3 Model 4 Total
***fffff
Plants Employ. Plants Employ. Plants Employ. Plants Employ
Non- Upholstered
Small 2
Medium 1
Large
Total 4
Upholstered
Small
Medium
Large
,568
,072
497
,137

634
507
210
18,252
45,513
136,542
200,307

5,277
24,448
54,254
142
54
14

35
28
12
1,014
2,276
3,793

293
1,358
3,014
142
54
14

35
28
12
1,014
2,276
3,793

293
1,358
3,014
285
6 253 6 253 119
14 3,793 14 3,793 55
459

70
56
23
2,028
5,057
15,171
22,256

586
2,716
6,028
Total
1,351   83,979
149   9,330
Source;  Arthur D. Little, Inc., estimates.

-------
                                   TABLE V.B.I
 PRICE  INCREASE  CONSTRAINTS
                    Condition for
  Factor             Constraint
Ratio of Before Tax     High
Treat. Cost to Selling
Price (%)
Substitute Prod.
Cap. Utilization
Captive Usage
Demand Growth
Foreign Compet.
Abatement Cost
Differences
Price Elasticity
of Demand
Basis for Compet.
Market Share Dist.
Number of Products
High Occurrence
     Low
     Low
     Low
     High
   Unequal
     High

    Price
  Fragmented
    Many
                NON-UPHOLSTERED
                   FURNITURE
 Low,<0.8%*

   Little
  Moderate
    Low
  Moderate
    Low
  Unequal
Low-Moderate

 Style, Quality
 Fragmented
    Many
                               UPHOLSTERED
                                FURNITURE
 Low, 
-------
     The table also indicates that abatement costs are spread unequally
across the industry.  However, in the furniture industry since the
consumer is relatively price insensitive at least within the bounds of
the necessary price increase, the unequal distribution of costs of com-
pliance is not a significant factor.


     Specifically,  price increases for manufacturers of wood furniture
will be implemented within the following ranges:

                                   Non-Upholstered   Upholstered

            Small Plant               0-1.7%            0-1.3%

            Medium Plant              0-0.8%            0-0.5%

            Large Plant               < 0.2%            0-<0.1%

     These are the price increases necessary for  these plants to maintain
the present level of profit generation.   For example, the small non-
upholstered furniture manufacturing plant will have to increase its
selling price by 1.7% to maintain its net income  after tax.

     The aggregate effect on industry prices if the affected plants im-
plemented price increases to cover fully costs of effluent abatement is
small.   For example, the share of market of affected upholstered furniture
plants  is 2.2%; it  is 2.1% for non-upholstered plants.  (Only small- and
medium-sized plants would increase prices;  abatement costs for large
model plants represent less than 0.1% of the sales revenues, an insignif-
icant effect.)  The aggregate effect on industry  prices is:

         Upholstered Furniture:       0.04% Increase

         Non-upholstered Furniture:   0.03% Increase

     Small companies can find ways to limit the effect of additional higher
operating costs.   For example,  most  of them will  opt for process changes
to give up in-plant laundry facilities and avoid  that particular abatement
cost.   In addition, alert management could  manage the impact of compliance
in several ways,  including:

         Effective  pricing strategy  to pass on costs of compliance
         selectively;

         Reducing materials costs by modestly  sacrificing quality
         to achieve lower prices;
                                    57

-------
         Maintaining good plant housekeeping to reduce wastewater,
         including recycling of in-plant and clean-up water;

         Selection of the least expensive  most compatible method
         of wastewater disposable, including analysis of oppor-
         tunities for cooperative facilities.

     This does not suggest that small plants will not be affected by
these Guidelines.  Rather, they have numerous compliance options avail-
able to avoid serious impact and effects on operations.

C.  FINANCIAL EFFECTS

     Since abatement will be passed through, profitability will be
maintained and financial condition will be unaffected.

     Capital availability is not a significant problem.  The amount of
capital required is modest, even for the medium- and small-sized plants,
e.g. :
                                         Abatement Investment
                                         Net         Cash
         Segment                        Assets       Flow
     Non-upholstered Furniture
         Large Plant                     0.2          1. 3
         Medium Plant                    i-5         11.1
         Small Plant                     3-4         24.0

     Upholstered Furniture
         Large Plant                     0.1          1.0
         Medium Plant                    0.9          8.7
         Small Plant                     2.3         19.8

     Further, management will not have to resort to equity or debt mar-
kets for capital, since these investment levels can be accomplished out
of cash flow.

D.   SENSITIVITY ANALYSIS

     Although we conclude that abatement costs will be passed on through
price increases, this section tests the effect on the industry of cost
absorption.  In essence, it is a test of the sensitivity of our analysis
to the "cost-pass-through" conclusion.

     This analysis concludes:

         Large firms would not be affected by full absorption of cost;

         Small- and medium-sized firms face potentially severe
         effects at maximum levels of cost, but can comply at
         lower, manageable levels of cost.

                                   58

-------
     Thus, even if costs were absorbed there would be no effect on the
 industry.

     1.  Large Plants

     Large plants would not be seriously impacted by the absorption of
 the cost of compliance.  Tables V.D.I and V.D.2 summarize the financial
 impact due to absorption of cost of compliance for large plants with
 maximum cost burdens.  For example, the net profit margin (net after
 tax income - % net sales) decreases by only 0.1% to absorb the maximum
 cost burden.  Similarly, profitability expressed as return on net assets
 decreases by only 0.3% to go from no cost to maximum cost.  Treatment
 cost represents only a small percentage of net after tax income, 5.4%
 as a maximum.  Cash flow remains about $354,500 a year for non-upholstered
 and $310,000 for upholstered firms.  Capital investment in pollution
 control facilities is only a small percentage of net fixed assets, 3.5%
 at a maximum.

     Thus, there would be no financial impact on large furniture producers,
 either upholstered or non-upholstered, even if full absorption of costs
 occurred.

     2.  Medium Plants

     Tables V.D.3 and V.D.4 show the financial impact of pollution abate-
 ment costs on different models within this size range.  The net profit
 margin (net after tax income - % net sales) decreases from 1.3% to 0.8%
 to absorb the maximum cost.  Profitability expressed as return on net
 assets is reduced from 4.2% to 2.6% to go from no cost to maximum cost.
 Treatment cost represents a fairly high percentage of net income after
 taxes, 79% as a maximum.  Cash flow is reduced from $40 500 to about
 $34,500 to absorb maximum cost by non-upholstered plants and from about
 $36,700 to $30,900 by upholstered plants.  Capital investment in pollution
 control facilities is 24% of net assets at the maximum.    The maximum
 cost burden is shown to be for plants with laundry facilities and wet
 spray booths (Model 4) which elect to install aeration ponds with equip-
 ment for spray irrigation.  However, a significant reduction in the
 financial impact can be achieved if the laundry facilities are eliminated
 (Model 3).  The most expensive control measures then result in a decrease
 in net profit margin of only 0.2%; profitability as a percent of net
 assets decreases by 0.6% for maximum cost; maximum treatment cost as a
 percent of net income is 31% and cash flow is reduced from a level of
 $40,500 to $38,200 to absorb maximum cost for non-upholstered firms; and
 capital investment in pollution control facilities is a maximum 17% of
 net fixed assets.

     Tables V.D.5 and V.D.6 summarize the financial impact for plants
 having no water wash spray booths, and with and without in-plant laundry
 facilities (Models 1 and 2).   Profitability is lower for plants with
 laundry facilities;  the effect is somewhat greater than shown for plants
with water wash spray booths but no laundry.   Plants without laundry


                                   59

-------
                                            TABLE  V.D.I
FINANCIAL IMPACT
LARGE NON-UPHOLSTERED PLANTS WITH WATER WASH SPRAY BOTTLES & LAUNDRY FACILITIES (Model 4)
No Treatment Landfill
(Total all Models)
#
#
$
$
$
$
$
%
%
%
%

%

$
Plants 50
Employees 136,342
Net Sales 6.27MM
Net Assets 2.34MM
Net Fixed Assets 934K
Total Invested Poll. Control
annual Cost for Poll. Control
Net Income Sales
Return on Net Assets
Return on Fixed Assets
Treatment Invested Fixed
Assets
Annual Treatment Cost
Net Income
Cash Flow
3.5
9.4
23.5



	
354.481
4,500
9,300
3.4
/\ <•*
s * *~
23.0

0.5

4.2
349,831
Burn with
Hog Fuel
3,600
580
3.5
9.4
23.5

0.4

0.3
354,771
Evap. Ponds
with Spray
14
3793
26,200
7,930
3.4
9.2
23.1

2.8

3.6
350,516
Aeration Sewer
Irrigation
32,700
12,030
3.4
9.1
22.9

3.5

5.4
348,466
0
300
3.5
9.4
23.5

	

' 0.2
354,331
Source:  Arthur D. Little, Inc., estimates;  costs  from Development Document.

-------
                                             TABLE V.D.2
#  Plants
#  Employees

$  Net Sales
$  Net Assets
$  Net Fixed Assets

$  Total Invested Poll. Control
$  Annual Cost for Poll. Control

%  Net Income Sales
%  Return on Net Assets
%  Return on Fixed Assets
%  Treatment Invested Fixed
     Assets
%  Annual Treatment Cost
     Net Income
$  Cash Flow
FINANCIAL
RED FURNITURE PLANTS
No Treatment
(Total all Models)
210
54,254
7.03MM
2.41MM
990K
0
1 0
3.2
9.2
22.4
-
312,963
IMPACT
WITH LAUNDRY
Landfill


3,200
6,680
3.1
9.1
22.0
0.32
3.0
309,623

FACILITIES
Burn with
Hog Fuel


3,400
540
3.2
9.2
22.3
0.34
0.2
312,693

(Model 2)
Evap . Ponds
with Spray


24,500
6,410
3.1
9.1
22.0
2.5
2.9
309,757


Aeration
Irrigation


28,300
11,630
3.1
8.9
21.8
2.9
5.2
307,147


Sewer


0
300
3.2
9.2
22.3

0.1
312,813
 Source;   Arthur D.  Little,  Inc.,  estimates.

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                                                      TABLE  V.D.3
NJ
9  Plants
#  Employees

$  Net Sales
$  Net Assets
$  Net Fixed Assets

$  Total Invested Poll. Control
$  Annual Cost for Poll. Control

%  Net Income Sales
%  Return on Net Assets
%  Treatment Invested Fixed
     Assets
%  Annual Treatment Cost
     Net Income
$  Cash Flow
FINANCIAL
IMPACT



NITURE PLANTS-WATER WASH SPRAY BOOTHS & LAUNDRY FACILITIES (Model 4)
No Treatment
(Total all Models)
1072
45,513
1.17MM
300K
125K
»1 0
rol 0
1.3
4.2
11.3
40,530
Landfill Burn with
Hog Fuel


9,300 580
4,500 3,600
0.9 1.3
3.0 4.2
7.9 11.1
3.3 2.7
60.9 3.8
Evap. Ponds
with Spray
6
253

7,930
26,200
1.0
3.2
8.4
0.2
51.9
Aeration
Irrigation


12,030
32,700
0.8
2.6
6.9
24.3
78.8
Sewer


300
1.2
3.8
10.2
2.0
          Source;  Arthur D. Little, Inc., estimates;  costs from Development Document.

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                                           TABLE V.D.4

                                         FINANCIAL IMPACT

         MEDIUM-SIZE NON-UPHOLSTERED FURNITURE PLANTS WITH WATER WASH SPRAY BOOTHS (Model 3)
   No Treatment
(Total all Models)
                                                     Landfill    Burn with   Evap. Ponds   Aeration      Sewer
                                                                 Hog Fuel    with Spray    Irrigation
#  Plants
#  Employees

$  Net Sales
$  Net Assets
$  Net Fixed Assets

$  Total Invested Poll. Control
$  Annual Cost for Poll. Control

%  Net Income Sales
%  Return on net Assets
%  Return on Fixed Assets
%  Treatment Invested Fixed
     Assets
%  Annual Treatment Cost
     Net Income
$  Cash Flow
1072
45,513
1.17MM
300K
125K
.1 - 3,600
•ol - 4,040
1.3 1.1
4.2 3.7
11.3 9.8
2.7
26.4
40,530 38,510
6
253

3,200
510
1.3
4.2
11.1
2.4
3.3
40,276


22,700
4,740
1.1
3.6
9.6
16.9
31.0
38,160


0
300
1.3
4.2
11.2

2.0
40,380
Source;  Arthur D. Little, Inc., estimates; costs from Development Document,

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                                          TABLE V.D.5


FINANCIAL
IMPACT
MEDIUM-SIZE UPHOLSTERED FURNITURE PLANTS-LAUNDRY


#
//
$
$
$
<;
$
%
%
%
%

%

$


Plants
Employees
Net Sales
Net Assets
Net Fixed Assets
Total Invested Poll. Control
No Treatment
(Total all Models)
507
24,448
1.39MM
300K
116K
0
Annual Cost for Poll. Control 0
Net Income Sales
Return on Net Assets
Return on Fixed Assets
Treatment Invested Fixed
Assets
Annual Treatment Cost
Net Income
Cash Flow
1.4
4.7
16.0

-

-
36,729
Landfill






3,200
6,680
1.1
3.9
13.1

2.7

35.7
33,389




FACILITIES (Model 2)
•
Burn with
Hog Fuel





3,400
540
1.3
4.7
15.8

2.9

2.9
36,459
Evap . Ponds
with Spray
28
1358



24,500
6,410
1.1
3.9
13.3

21.0

34.3
33,524
Aeration
Irrigation





28,300
11,630
0.9
3.3
11.0

24.2

62.2
30,914
Sewer






0
300
1.3
4.7
15.9

— -

1.6
36,579
Source:  Arthur D. Little, Inc., estimates;  costs from Development Document.

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                                            TABLE V.D.6


FINANCIAL
IMPACT



MEDIUM SIZE NON-UPHOLSTERED FURNITURE PLANTS - (Model 1)


*
#
$
$
$
$
$
%
%
%
%

%

$


Plants
Employees
Net Sales
Net Assets
Net Fixed Assets
Total Invested Poll. Control
No Treatment
(Total all Models)
1072
45,513
1.17MM
300K
125K
0
Annual Cost for Poll. Control 0
Net Income Sales
Return on Net Assets
Return on Fixed Assets
Treatment Invested Fixed
Assets
Annual Treatment Cost
Net Income
Cash Flow
1.3
4.2
11.3

—


40,530
Landfill






3,200
. 1,520
1.2
4.0
10.8

2.3

10.0
39,770
Burn with
Hog Fuel
54
2,276



2,300
380
1.3
4.2
11.2

1.7

2.5
40,340
Evap. Ponds
with Spray





20,900
3,330
1.2
3.8
10.1

15.5

21.8
38,866
Aeration Sewer
Irrigation





0
300
1.3
4.2
11.2

- -

2.0
40,380
Source;  Arthur D. Little,  Inc.,  estimates;  costs from Development Document.

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facilities  or water wash spray booths  show no significant change  in
profitability.   These plants would not  he  affected.

Thus, medium-sized  furniture producers  are not expected to close  even if
they absorb the  costs of compliance,

     3.  Small Plants
     Sma 11 - s i 2 £« p 1 f> •-. t
absorption of  tru  coat c
the financial  cr it-
negative prof:, tab:
following fJnnPc^ •,
upholstered  p,fcdr,., .
would decrease1-  ftr-
net assets from 5.?t
very high percentage
reduced from  $13,000
control facilities Is,
upholstered  furniture
                            :oupi
                      or ne
                      i:.' •- v i ^
                       731 '
                       pi an I
ov
     The maximum cost for compl innrp
ities.  There  Is le.-;K serious f
when there  are no laundry f nci i
large volume of wastcwatex ( ro;r.
ing the costs  for i''ioclei.,v 1 and
volume of wastewatsr troin ,'J"'e I
from glue spreader .: " car,- \t\: .
     For  th^  ui-'a-i/
from 1.2  to 0.8% t
absorb maxirauic, cos
furniture  planes .t
V.D.Sa. and V. 0,8h
plants.  The  sccc-n
on upholstered p
sales) would  decre
return on  net asser. •• •;
(after tax) rcpra.^ tr
this systEm.   Cod!; '. .--
ment in pol Lutio •  , •. .1
maximum cos t.
     If COfitJ w€J,r"s L',-.
lower-cost cc<.-p) iatio.-,
otherwise.   Aga: n . v ;.
lower  cost options ar,

     4.   Sensitl11 u-;> -
I.e. most  severely  affected by the
...e.  lab Los V.D.7 and V.D.8 summarize
.'  ^eti'od  >ilh maximum cost results  in
i  ' :'.f;;.est.  e-^st  alternative had the
 jr.l.p; dL?rc-a producers.  For non-
:.  ii.jri-ii;  (r;et income as a % sales)
pj-:f Ltabij Lty expressed as return on
; f-j.fiit cos*: (after tax) represents  a
,  ..l}"i nor  this  system.   Cash flow is
r,r -jipi.'.ai investment in pollution
:-'c.; .issets; for maximum cost.  Small
   Imilar  pattern.
                                          tor pJants with laundry facil-
     Table  V.L',9
strates ,  or! ,  SIT-
The primary cor-: •
needed.
                                    c in]  effect on the small  producer
                                    c ,   The cost of treating  the  relatively
                                    i'dr/ "acilities is apparent by compar-
                                     f i  Li interesting to note that the
                                        fc'eilicies .is five  times the volume
                                                profit margin is reduced
                                               , becomes negative to
                                                 Small upholstered
                                               '^iis severe  impact.   Tables
                                               ffects on these furniture
                                               had the following effects
                                               gin (aet income as a %
                                               itability expressed as
                                               r-,^%.  T:eaiT-ient cost
                                                • f .-c-1- Income, 69% for
                                               1.0  ijK, and capital invest-
                                               '; .1-. r.  n---ad assets for
                             --' ".'      "'' n  --''."n'r would  have to elect the
                             i.';   >     .-•-J  •.-ff'-i,': •-.".,.'d  be. quite severe
                             :  plar : .   r- ;>e aole to  '.onir-iy through these
                             i 3  u-..c,    ..   '  result.
                                             ,.aiy,;is-   As the 'able demon-
                                                :  - "?••.••„  '-»f cos'., iacrease/
                                                  • •'.->•   .:, r?:i3e capital  if

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                                             TABLE V.D.7
                                          FINANCIAL IMPACT
# Plants
// Employees

$ Net Sales
$ Net Assets
$ Net Fixed Assets

$ Total Invested Poll. Control
$ Annual Cost for Poll. Control

% Net Income Sales
% Return on Net Assets
% Return on Fixed Assets
% Treatment Invested Fixed
   Assets
% Annual Treatment Cost
  Net Income
$ Cash Flow
ID FURNITURE PLANTS -
No
(Total
2
18




13
Treatment
all Models)
,568
,252
391K
94K
34K

1.2
5.2
14.6
- -
,304
LAUNDRY FACILITIES (Model 2")
Landfill


3,200
6,680
0.4
1.6
4.6
9.5
69.1
9,964
Burn with
Hog Fuel


3,400
540
1.2
4.9
13.8
10.1
5.8
13,034
^»
Evap . Ponds
with Spray


24,500
6,410
0.4
1.8
5.0
73.1
68.3
10,099
Aeration Sewer
Irrigation


28,300 0
11,640 300
neg 1 . 2
5.0
14.1
6.1
3.2
— 13,154
 Source:  Arthur D. Little, Inc.,  estimates;  costs from Development Document.

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                                                      TABLE V.D.8
oo
//  Plants
#  Employees

$  Net Sales
$  Net Assets
$  Net Fixed Assets

$  Total Invested Poll. Control
$  Annual Cost for Poll. Control

%  Net Income Sales
%  Return on New Assets
%  Return on Fixed Assets
%  Treatment Invested Fixed
     Assets
%  Annual Treatment Cost
     Net Income
$  Cash Flow
FINANCIAL IMPACT
LL NON-UPHOLSTERED
No Treatment
(Total all Models)
2,568
18,252
391K
94K
34K
L 0
Jl 0
1.2
5.2
14.6
	
13 , 304
FURNITURE PLANTS
Landfill


3,200
1,520
1.0
4.4
12.3
9.5
16.2
12,544
(Model 1)
Burn with
Hog Fuel
142
1014

2,300
380
1.2
5.0
14.0
6.9
4.0
13,114
Evap . Ponds
with Spray


20,900
3,330
0.8
3.4
9.6
62.2
37.6
11 , 639
Aeration Sewer
Irrigation


0
300
1.2
5.0
14.1
	
3.2
13,154
           Source:   Arthur D. Little, Inc., estimates;  costs from Development Document,

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                                            TABLE V.D. 8a
#  Plants
#  Employees

$  Net Sales
$  Net Assets
$  Net Fixed Assets

$  Total Invested Poll. Control
$  Annual Cost for Poll. Control

%  Net Income Sales
%  Return on New Assets
%  Return on Fixed Assets
%  Treatment Invested Fixed
     Assets
%  Annual Treatment Cost
     Net Income
$  Cash Flow

FINANCIAL
IMPACT



1ALL UPHOLSTERED FURNITURE PLANTS (Model 1)
No
(Total


d
ol


Treatment
all Models)
634
5,277
532K
138K
26K
0
0
1.7
6.5
34.6
	
16,200
Landfill


3,200
1,520
1.6
5.8
31.7
12.3
18.5
15,500
Burn with
Hog Fuel


2,300
380
1.7
6.3
33.9
8.9
4.3
16,000
Evap . Ponds
with Spray


20,900
3,330
1.4
4.6
28.2
80.4
45.4
14,500
Aeration
and Sewer
Irrigation


0
300
1.7
6.6
34.6
	
3.4
16,100
Source:  Arthur D. Little, Inc.,  estimates;  costs from Development Document.

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                                          TABLE V.D. 8b
#  Plants
#  Employees

$  Net Sales
$  Net Assets
   Net Fixed Assets

   Total Invested Poll. Control
   Annual Cost for Poll. Control
%  Net Income Sales
%  Return on Net Assets
%  Return on Fixed Assets
%  Treatment Invested Fixed
     Assets
%  Annual Treatment Cost
     Net Income
$  Cash Flow

FINANCIAL
IMPACT




'ERED FURNITURE PLANTS - LAUNDRY FACILITIES (Model 2)
No
(Total


ol
rol


Treatment
all Models)
634
5,277
532K
138K
26K

1.7
6.5
34.6
	
16,200
Landfill


3,200
6,680
1.1
4.0
21.8
12.3
118.0
12,900
Burn with
Hog Fuel


3,400
540
1.6
6.2
33.6
13.1
6.2
15,900
Evap . Ponds
with Spray


24,500
6,410
1.1
3.6
22.3
94.2
110.6
13,000
Aeration
and
Irrigation


28,300
11,640
6.0
1.9
12.2
108.9
366.0
10,400
Sewer


0
300
1.7
6.4
34.0
—
3.4
16,100
Source:  Arthur D. Little, Inc.,  estimates;  costs  from Development Document.

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                                        TABLE V.D.9
                          SENSITIVITY ANALYSIS - CONCLUSION MATRIX
Price Result
                                                    Type of Plant - Extent of Effect
                                                                           Upholstered
   Non-Upholstered	
Small  Medium  Large    Small  Medium  Large
   Price Increase:
   - Probable Tech.
   - Highest Cost Tech.
None
None
None
None
None
None
None
None
None
None
None
None
   No Price Increase:
   -  Probable Tech.
   -  Highest Cost Tech.
Moder. Minor   None
High*  llinor   None
                 Moder. Minor   None
                 High*  ilinor   None
  *Due to Limited Availability  of  Capital.

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E.  PRODUCTION EFFECTS

     Based on our preceding analyses which indicate that costs will be
passed on and that companies can elect technological and strategic
options to avoid significant impact, we do not expect any plant closures
to result from the implementation of these effluent guidelines.  We only
temper this analysis with the comment that at higher levels of capital
and/or operating costs, the analysis would change.  For example, if small
companies were to make capital investments in the §10-15,000 range, and
to bear operating costs in the$10-15,000 range, our analysis would
indicate a significant number of plant closures.

F.  EMPLOYMENT EFFECTS

     Since no plant closures will result, there will be no attendant un-
employment .

G.  REGIONAL EFFECTS

     There will be no regional effects resulting from these guidelines.

H.  BALANCE OF TRADE EFFECTS

     The modest aggregate cost increases we foresee being added onto
furniture prices (*0.05%)wiii not significantly alter the competitive
position of United States furniture in foreign markets, neither will it
cause a dramatic influx of imported furniture.  Both Imports and exports
will be influenced more by other factors, such as style changes or raw
material costs and availability.

I.  INDUSTRY GROWTH EFFECTS

     Industry growth will not be affected by the proposed effluent
guidelines.  New plants in this industry tend to be larger than our
model small plant, the only sector of operations at all likely to be
affected.  Further, the modest price increases likely to be implemented
will have no effect on furniture purchases in any important market seg-
ment.
                                    72

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                       VI.  LIMITS OF THE ANALYSIS
     The two central problems limiting the accuracy of the present
analysis are:

         A limited availability of data in suitable form; and,

         The nature of the industry segments.

A.  DATA LIMITATIONS

     Data on these industry sectors is generally present only in a broad,
descriptive format.  What information is available of a detailed nature
tends to focus on the operations and characteristics of larger firms and
their large plants.  However, these industry sectors are typified by
small, privately-owned firms which are more likely to be affected by
effluent guidelines than their larger counterparts.  Thus, as noted in
Section III on Methodology, it was necessary to gather new data through
a series of interviews to collect information on the industry as a
whole and to focus on the operations of those firms and plants most
likely to be impacted, i.e., the small operators.  Due to the large number
of plants involved (approximately 6,000), it was necessary to collect
data by representative samples rather than through comprehensive (100%)
sampling.  The consistency of the data suggests that the analysis is
built upon a sound data base.

     Excepting the large manufacturers which tend to be publicly-held
corporations, these industries are composed of many small, privately-held
family-managed firms which is an additional data limitation.  Due to the
fragmented nature of the industry and the fact that privately-held firms
do not publish as much data as do publicly-held firms, it is difficult
to get accurate financial data.   Even where financial data is available,
that data is not always directly comparable to similar data from publicly-
held firms, since-a small firm may choose to pay its principals higher
salaries and fringe benefits, rather than reporting such earnings as net
income, which is the more standard practice for a publicly-held corpora-
tion.  As such, net income and,  more importantly, annual cash flow may be
understated for these firms.

     However, the costs of compliance are relatively modest and the
technological alternatives relatively straightforward.  Further, the
consistency of our data within the various industry sectors gives us
confidence that is indeed representative.  Thus, the analysis can be
used to judge the economic impact of proposed effluent guidelines on
the industry.
                                    73

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B.  NATURE OF THE INDUSTRIES

     The meat difficult ieaue to analyse in these sectors is the likeli-
hood of plant closure.  A large, muLti-JndusCry, publicly-held firm
tends to make a shutdown decision based on objective business analysis,
such as effects on profitability or importance of a product line to
overall corporate strategy.  Such a firm would lively have specific
criteria for each of its operating facilities to paet.

     However, a private ow>dr tends to have A greater subjective commit-
ment to staying in business even if profitability is substantially
reduced.  This is true for such factors as copraitjnant to a facility which
has been operated by the family for generations arvd for such specifically
economic reasons as the fact that this may be a particular family's  sole
or primary source of income.  Further, the privately-held firm considers
the magnitude of cash flow as the important issue, rather than profit-
ability ration„  The management of such firms is not likely to perform a
discounted cash flow analysis as part of its shutdovm decision-making.

     Thus, the factors l.istt.fi in the plant closure analysis matrices
(see Table III.C.I)  can be used as a guide and to highlight the central
issues related to plant closure, but must be assigned different weights
when analyzing the. decision-making process and the likelihood of closure
for a publicly-held firm versus a private enterprise.  Where costs approach
a leve.1  of significance, such as for small non-upholstered furniture
plants,  the rlam c^oauro analyst? becomes more suggestive than definitive.
On balance,  however, the costs of compliance are relatively modest,  not
relatively high, and the plant, closure decision is ,more straightforward.

C.  M0S1_

     Tbft ir.ost TCTisi^ive issues of {.his analysis are listed in Table VI-C.I.
In essence, {.he k,vy i.-.auep are the facts that small firms, which arc
numerous In wood furniture rr
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                                         TABLE VI.C.I

                                     MOST  SENSITIVE  ISSUES
       Issue
Effect on Present Analysis
        Condition
To Cause Significant Effect
 Price Increase Analysis
 Capital Availability
 Plant Closure Analysis
         Moderate
         Minimal
         Minimal
Higher costs (capital: $5-10,000), and
Larger // of plants affected

Inability to implement low capital
compliance technologies

Higher costs and
Larger # of plants affected
Source:  Arthur D. Little,  Inc.,  estimates.

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Appendix

Industry
 Impac t
Summaries
    76

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                                 TABLE A-l

                              INDUSTRY SUMMARY
Industry;   Non-Upholstered  Wood Furniture  Manufacturers

No. of Plants in Segment                                        4,596
Percent Total Plants in Industry                                    100%

No. of Plants Direct Discharging                                     459
Percent Total Plants in Segment                                     10%
                                                                                    BPT,  BAT
No. of Plants with BPT Treatment in Place                                                    4,137
Percent Total Plants in Segment                                                               90%
Cost of Pollution Abatement                                                            BPT, BAT

  Capital Costs for Segment
  Total Capital Cost                                                               $1,200,000
  Total Capital Expenditures as Percent of Average Annual                                       i. 1%
    Investment
  Total Capital Expenditures as Percent of Total Capital                                      
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                                 TABLE A-2

                              INDUSTRY SUMMARY

Industry;   Upholstered  Wood Furniture Manufacturers
No. of Plants in Segment                                    1,500
Percent Total Plants in Industry                                100%

No. of Plants Direct Discharging                                 149
Percent Total Plants in Segment                  •               10%
                                                                                BPT,  BAT
No. of Plants with BPT Treatment in Place                                              1,351
Percent Total Plants in Segment                   '                                       90%
Cost of Pollution Abatement                                                        BPT,  BAT

  Capital Costs for Segment
  Total Capital Cost                                                           $   500,000
  Total Capital Expenditures as Percent of Average Annual                                  ^-1%
    Investment
  Total Capital Expenditures as Percent of Total Capital                                  < 0.1%
    In Place
  Annualized Costs for Segment
  Total Incremental Increase Including Capital Charges                              1,000,000 '
  Total Incremental Increase Excluding Capital Charges                              1,000,000
  Total Incremental Increase Including Capital Charges                                 ^0.05%
    as Percent of Sales

Expected Price Increase

   Expected Increase Due to Pollution Control

Plant Closures

  Total Closures Anticipated                                                             ~
  Percent  Reduction of  Segment Capacity Due to Closures

Employment

  Total Number of Employees Affected                                                   ~
   Percent  of Total Employees in Segment                                                  ~

Community Effects

Impact on  Industry Growth

Balance-of-Trade Effects
                                                   78

-------