-------
                                    IV-22
                                  EXHIBIT 33
             EMPLOYMENT POTENTIALLY RELOCATED:  1976-1985
                                    Scenario 1
Scenario 2
9
New Britain
Hartford
Stamford
Waterbury
Ansonia
Middletown
Number
of Years*
10
8
8
8
6
1
Number
of Jobs
995
1,310
770
1,480
105
40
Incremental
Unemployment
2.3%
1 .4%
1 .3%
2.8%
1 .3%
0.2%
Number
of Jobs I
2,030
2,775
1,945
2,330
615
135
In ere met
Jnemploy
' 2.4%
1 .3%
1 .3%
3.4%
2.1%
0.3%
'Number of years from date of first permit denial to  1985. Number of jobs and incre-
 mental unemployment are cumulated over this period.
Source:   Harbridge t-Touse,  Inc.  (1976). Incremental  unemployment estimation based on
         OBERS-E population projections  allocated according to 1973  distribution by
         town and 1973 labor force participation rate by Labor Market Area.

-------
                                                  EXHIBIT 34
                                 ESTIMATED INCREMENTAL UNEMPLOYMENT
                                    IN COMPARISON TO HISTORICAL RATES
                                                   Estimated Unemployment by Labor Market Area*

New Britain
Hartford
Stamford
Waterbury
Ansonia
Middletown
Statewide
incremental
Unemployment
per Year*
.2%
.2
.2
.4
.2 to .4
.2 to .3
0
Annual Averages
June 1975
13.5%
8.8
7.8
12.6
16.1
11.1
10.7
Jan. 1975
14.4%
7.5
6.3
10.2
9.2
9.4
9.0
1974
6.7%
5.4
5.3
6.3
7.3
6.7
6.1
1973
7.3%
5.6
6.0
6.2
6.8
6.6
6.3
1972
10.6%
7.8
6.6
9.4
9.9
8.4
8.6
1971
1 1 .6%
7.2
5.7
10.1
10.0
8.2
8.4
1970
7.1%
4.7
4.1
7.9
6.0
5.3
5.7
 *Attributable to permit denials. Range indicates low and high impact scenarios when there is a differential. Note that no
  incremental unemployment is expected statewide.
**Labor Market Areas do not correspond directly with airsheds. Major cities in the LMA are matched with the major cities
  in the airsheds in the figures presented here.

Source: Connecticut Department of Labor.

-------
                                       IV-24
unemployment caused by the permit denials will probably have a relatively  more severe
impact than indicated by the 0.2 percent rate.

         To understand the employment impact of permit denials it is important to realize
that the incremental unemployment and figures on jobs foregone represent a limited view of
the potential situation in the major city or airshed. The jobs are not actually  lost, but are
relocated in areas where permit approval  can be obtained. To the extent that the firms
relocate in  the vicinity of the airsheds and employees are willing to commute, adverse
employment implications  for  the  individual towns  and airsheds  will be  substantially
mitigated. Moreover, incremental unemployment resulting from the permit denials will have
only a short-term, transitional impact. In fact, it may have significance only when compared
with population/labor force trends  that would likely  occur in the absence of the  permit
denials (as in the analysis above).

         To help determine  any employment shifts that may take place,  it was assumed
that manufacturing industries serving local or regional markets, as indicated  by LQ's less
than one, would relocate in the vicinity  of the airsheds, while those  industries serving
national markets  would do one of two things: (i) all would locate outside  the commuting
radius  of the  major airshed  towns or (ii) only nondurable manufacturers would locate
outside the commuting radius because of their greater  need for proximity to concentrated
development. 1  Exhibit 35 shows the  results  of these calculations.  Based  on  the  first
assumption (Case 1), from 50 to 75 percent of future employment subject to permit denials
will shift to other areas in Connecticut. Assuming that only the nondurable manufacturers
with nationwide market orientation (Case 2) relocate outside the commuting radius, from 0
to 50 percent of the  respective airshed's foregone employment may shift to other areas.
(Note that  0 and 50  percent are  extremes and that the range  of 5 to 20 percent is more
representative.) The magnitude of these  numbers indicates that the transitional unemploy-
ment situation may be relatively acute in all the airsheds. However, even in the case of the
greatest employment shift  the incremental unemployment figures cited previously (100 per-
cent employment shift) will be from 25 to 50 percent lower based on this analysis.2

         Using wage levels as an indication of skill levels, under the Case 1 assumption (in
which all industries serving national markets seek locations some distance from  the affected
airsheds) roughly  80 percent of the more highly skilled employment that was forecast to  be
generated from 1976  to 1985 in  the airsheds or major cities  would  shift  away from the
original airshed locations. Similarly, about 80 percent of  the forecasted  average  skilled
employment subject to permit denials and  nearly 90 percent of the growth  in lower skilled
employment will be affected by shifting industrial locations. Alternatively, under the Case 2
assumption  (in  which  only  nondurable  manufacturers serving  national  markets seek
locations some distance from the  affected airsheds), about 20 percent of the growth  in
*Here  it is assumed that the required  density and concentration would not be  available
 within the commuting radius, thereby necessitating a move to another population center.
^The   calculation  of incremental  unemployment  assumed that  100 percent  of the
 employment subject to permit denials would shift away from the area. Since it has been
 estimated that at most 50 to  75 percent would actually move from affected airsheds or
 major towns, the incremental unemployment is expected to be at least 25 to 50 percent
 lower than previously calculated.

-------
                                    IV-25
                                 EXHIBIT 35
                POTENTIAL EXTENT OF EMPLOYMENT SHIFTS
                 BASED ON TWO ALTERNATIVE ASSUMPTIONS
Case 1: Assuming All Manufacturers Serving National Markets Relocate Away from Airshed

                          Scenario 1                          Scenario 2

New Britain
Hartford
Stamford
Waterbury
Ansonia
Middletown
Employment
Shift
465
655
575
905
65
20
Percent
of Total*
49%
50
75
61
62
50
Employment
Shift
990
1,315
1,335
1,450
415
95
Percent
of Total*
49%
47
69
62
67
70
Case 2: Assuming Only Nondurable Manufacturers Serving National Markets Relocate Away
       from Airshed

                          Scenario 1                          Scenario 2

New Britain
Hartford
Stamford
Waterbury
Ansonia
Middletown
Employment
Shift
55
185
135
195
0
20
Percent
of Total*
6%
14
18
13
0
50
Employment
Shift
105
255
305
300
75
20
Percent
of Total*
5%
9
16
13
12
15
*Percent of Total indicates the percent of total employment subject to permit denials that
 is likely to shift to another area.

Source: Harbridge House, Inc. (1976).

-------
                                        IV-26
 higher skilled employment, 35 percent of the growth in lower skilled employment, and none
 of the forecast growth in average skilled employment in the airsheds and major cities would
 be shifted to other areas of the state.

          b.   Population  Distribution. As employment opportunities shift to other areas,
 the  population projections  require  modification  to  reflect changing  employment and
 residential patterns within  the state. It has been assumed that those industries relocating in
 the  vicinity of the affected  airsheds will not cause population  shifts. This assumption is
 based on the consideration that 15 or 20 miles added to daily commuting distances will not
 provide sufficient  motivation for changing place of residence.  There is no known empirical
 evidence to support (or refute) this assumption. However, a nationwide transportation study
 found that from  15  to 20 percent  of home-to-work trips made by private transportation
 were for distances of 15 miles or more.l On  this basis, the two cases evaluated above are
.used here to indicate a reasonable range of population shifts.

          An indication of the extent of changes in population distribution can be obtained
 by assuming that the labor force participation rate in each of the airsheds remains constant
 through  1985. This implies that such demographic  features as age and income distribution
 also remain fairly stable throughout the  10-year period. Exhibit 36 depicts  the potential
 population shifts away from  airsheds and  major  cities by 1985 for Scenarios  1 and 2. Only
 in Waterbury is as  much as 2  percent of the 1985 population potentially affected. Moreover,
 evaluation of the income distribution impact of  the population shifts, based on the average
 wage levels in the  industries  relocating to  other areas, shows no  change in the proportional
 representation of income levels within each airshed or major city.

          c.   Development  Patterns.  The foregoing evaluation of the extent  of any
 modifications in employment and population  trends by geographic area has indicated that
 the  incremental shifts likely  to occur by  1985 are  not of significant magnitude. However,
 over the longer term, the shifts will be cumulative such  that permit denial in the six airsheds
 will  effect a change in the  orientation of development patterns. To some extent this change
 is expected to reinforce new  trends in Connecticut  development  patterns. For example, the
 Danbury area (Housatonic Valley RPA) is one of the fastest growing regions in the state and
 is also a  likely candidate for relocation by firms that may be  denied permits  in the six
 airsheds. Similarly, areas of concentrated development  such as New Haven, Bridgeport, and
 Bristol will probably have incrementally increased growth as a result of permit denials.

          The major change in  development patterns, however, is  likely to  occur in the
 vicinity of the six airsheds.  Firms  with local  or regional market orientations are likely to
 seek alternate locations in  the vicinity of  the airshed in which permit denials are effected.
 Thus, the dispersion of development is likely to occur at an unprecedented rate, particularly
 under the Scenario 2 assumptions in which permit  denials are  required in all towns in each
 affected  airshed. Because of the relatively higher growth originally forecast  for  the Hartford,
 New Britain, Waterbury,  and Stamford areas, the impact  on  development  patterns will
 probably be greatest in the vicinity of these airsheds.
 ^U.S.  Department of Transportation, Nationwide Personal  Transportation Study, Report
  No. 8, August 1973, p. 31.

-------
Case 1
                                     IV-27
                                  EXHIBIT 36
                 POTENTIAL POPULATION SHIFTS AWAY FROM
                    AIRSHEDS AND MAJOR CITIES BY 1985
                         Scenario 1
Scenario 2

New Britain
Hartford
Stamford
Waterbury
Ansonia
Middletown
Case 2
New Britain
Hartford
Stamford
Waterbury
Ansonia
Middletown
Population
Shift
970
1,200
1,150
2,080
190
50

110
340
270
450
0
50
Percent
of Total*
1%
1
1
2
1
#*

* *
**
#*
»*
0
**
Population
Shift
2,060
2,400
2,670
3,330
1,240
230

220
470
610
690
220
50
Percent
of Total*
1%
1
1
2
1
##

**
**
**
**
*#
* *
 * Indicates original forecast population.
* indicates percentage is less than 0.5.

Source:  Harbridge House, Inc. (1976). (See text for explanation of Cases and Scenarios.)

-------
                                        IV-28
          d.   State  and  Local Taxes.  Since  no alteration  in  statewide growth or
development is  expected to result from  permit denials, corporate income  tax revenues
should not be significantly affected by the null strategy.  On the other hand, local property
tax  and  user  charge revenues may  become redistributed in  response  to changes in
development patterns. Depending on the speed with which such  changes occur, there may
be an adverse impact  on  the revenues and expenditure requirements of some communities.
For example, if development shifts rapidly to areas of relatively slow growth,  the increased
revenues may  not be  sufficient  to cover the sudden rises in capital spending required for
such things as schools, sewer extensions, local roads, and so forth. Conversely, a rapid
reduction in development concentration within the airsheds may  result  in insufficient
revenue to cover debt  and financing expenses from prior investment programs. In either case
the tax rate will have  to be increased or the assessment ratio altered to balance  revenues and
expenditures over the short term.  These tax changes,  however, are likely  to be  only
temporary measures. Further, they are highly dependent on the extent of and rate at which
population and employment shift.

          e.   Interaction with Other Programs and Policies. The denial of permits suggests
several conflicting and complementary areas vis-a-vis other programs in Connecticut. These
areas are summarized below.

          •    Within   the  commercial and  institutional  sectors, in particular, denial of
              permits is  likely  to  increase  design changes to accommodate use  of the
              resource recovery plants (rather  than on-site incineration)  and/or use of
              all-electric power  (rather than on-site power generation). In most cases these
              changes will result in more efficient use of resources, thereby complementing
              the objectives of  both the Resource Recovery Authority and the Connecti-
              cut Department of Planning and Energy Policy. There may, however, be an
              air quality trade-off in a case of wholesale conversion to electrical power.
              For example,  conversions may necessitate construction of new generating
              capacity. If such new capacity is nuclear, the net air quality impact would be
              positive. However,  with  additional  fossil-generating  capacity, emissions
              would  be  more  spatially  concentrated, producing an adverse air quality
              impact. The DEP may want to  further  evaluate pollution  control  and
              fuel-type implications of conversions and the net impact on  air quality.

          ••    Dispersion  of development as  a  result of  permit  denials suggests potential
              conflict with the  federal policy of nonsignificant deterioration of clean air.
              However,  under  both the  House and Senate versions of the Clean Air Act
              Amendments as  well  as  the  EPA's version of applicable  regulations, it is
              unlikely that pristine area  designations would apply to any facility siting in
              Connecticut. Moreover, facilities which may be denied permits  are expected
              to relocate primarily within the AQMA. Consequently, no conflict in policies
              or objectives is expected.

          •    In Chapter III the permit program was characterized as a mediating force
              between the employment/economic  and environmental objectives of  local
              development agencies. Under the null strategy,  however,  the balance is
              slanted toward environmental objectives, with little flexibility for mediation
              of local economic  goals.  Consequently,  local decision-making power is
              effectively  usurped by state/federal air quality  requirements. The result is

-------
                                        IV-29
              that substantial conflict with objectives  of local development agencies is
              likely.

         •    The Connecticut Plan of Conservation and Development (State of Connecti-
              cut, September 1974) is not an officially sanctioned land use plan for the
              state,  but it does represent a major step toward development of a consensus
              on  land use policy. Accordingly, evaluation of the interaction between the
              null strategy and  the land use policies proposed in the Plan was undertaken.
              Three policies, summarized below, indicate potential for  conflict.

                — Policy No. 5: Direct urban development to those areas identified as
                   "Suitable for Urban Development," preferably close  to existing urban,
                   commercial, and employment centers.

                — Policy No. 6: Encourage urban development to be at sufficient densities
                   for the economical provision of services.

                — Policy No.  7: Promote staged, contiguous  development within areas
                   "Suitable for Urban Development."

         The major point of conflict arises in Policy No. 5, which calls for high priority to
be given to revitalization of the physical, social, and economic structure  of the central cities.
Although some development can  and will continue to take place in  the central cities where
permits are subject  to  denial, substantial potential for development will be foreclosed.
Under such circumstances, revitalization  may  be significantly  more  difficult to achieve.
Moreover,  an  implicit objective in all three of these policies is toward concentration of
development rather than  the limited dispersion necessitated by the null strategy.

         f.   Social  Weil-Being Several  components  of social well-being were considered
with regard to the null strategy impact. Each of these is discussed below:

         •    Urban/Rural  Mix:  Prior  evaluation of the  alternative siting  decisions of
              facilities  subject to permit denials  and the potential changes  in population
              distribution and  development patterns indicated that  a  limited degree of
              dispersion from  urbanized  areas  would result  from  the null  strategy.
              However, most shifts were expected to take place within the AQMA, which
              is characterized for the most part by urban as opposed to rural development.
              The small pockets of what may be considered rural development are unlikely
              to be significantly affected by the null strategy. Consequently, no change in
              the existing mix  between urban and  rural development levels is expected.
              Nevertheless, within the predominantly urbanized areas, there is likely to be
              a shift toward greater development of the less developed areas, particularly
              in the vicinity  of the six airsheds.  Because of the general reinforcement of
              trends in development patterns, however, no  significant impact on social
              well-being is expected.

         •    Flexibility for Long-Range Response:  This  component of social well-being
              may be  a significant factor in  areas subject to permit denials. As noted
              above, substantial  potential for development will be foreclosed as a result of
              permit denials. Future improvement in the efficiency  of pollution control

-------
                                        IV-30
              equipment may increase the types  and sizes of facilities that can meet air
              quality limitations. However, over the study period, the range of options for
              economic development in  areas  subject to permit denials is limited. This
              situation has potential for creating a sense of stagnation in the affected areas,
              thereby  causing  uncertainty  about  the  future  for cultural  and  social
              institutions. The  strength and adaptability of local and regional planning
              efforts can be important factors in determining the extent to which permit
              denials affect the stability of basic community institutions.

         •    Local Autonomy: The null strategy usurps local decision-making power with
              regard to balancing environmental and economic objectives.

         •    Income  Distribution:  Calculations  based  on  median  wage  levels  and
              employment  by industry indicate that no significant change in the income
              distribution within  the affected  areas would occur as  a result of permit
              denials required by Scenario  1 or Scenario 2.

         ••    Recreational  Opportunities: No evidence  of any signficant  impact on the
              supply and range of recreational activities was found.

         •    Population and Employment Mobility:  In  evaluating the ease of access in
              terms of transportation and economic means  it appears that no significant
              constraints are imposed by permit denials; however, commuting times may
              be somewhat increased in the vicinity of the airsheds because of changes in
              employment locations.

         •    Institutional  Relationships:  There  is  no  evidence that any  traditional
              authority relationships within community structures would be undermined
              as a result of the null strategy.

     2.   Benefits

         The air quality benefits experienced from permit  program  implementation are
likely to be even more strongly experienced under the null strategy because of the danger of
standard violation. Unfortunately, data relating the level of beneficial impact to air quality
are  limited to  the  extent that any assessment of the  incremental order of magnitude is
impossible at this time. (For a discussion of attractiveness and efficient use of resources,
refer to Chapter III and Appendix L.)

D.   Summary

         The  null  strategy  assessment  has  addressed  the  potential  impacts of  the
constraints imposed by  the air quality impact criteria of the new source review procedure.
Estimates of  potential primary standard violations  for TSP and SC>2 were provided by the
DEP for the  period  from 1975  to  1985. Violations are estimated in six towns within the
AQMA as shown below:

-------
                                       IV-31


              New Britain:       TSP (1975),  SO2 (1978)

              Hartford:          TSP(1978),  509(1985)

              Waterbury:        TSP (1978),  SO? (1978)

              Stamford:         502(1978)

              Ansonia:          TSP (1980)

              Middletown:       502(1985)


         Evaluation of the  strategy focused on the incremental impacts over and above
those incurred by the permit program BACT requirement (see Chapter III). Two scenarios
were developed to determine the low and high ends of the potential impact range. Scenario
1 assumes that only those facilities forecast 1 to locate in the town where standard violations
are expected would be subject to  permit denials  (low  impact). Scenario 2 assumes that
permit denials would be required for all facilities forecast to locate in the entire airshed in
which  the town potentially  violating the standards is located  (high  impact).2 The actual
impact of the null strategy is likely  to fall between  these extremes because DEP assesses the
need to deny permits on a case by case basis.

         Under Scenario 1, 3 percent of the state's land area and  16 percent of the
projected  1985 population is potentially affected.  Under Scenario 2, about  11  percent of
the state's land area and 35 percent of the projected 1985 population is potentially affected.

         Both  direct  and  indirect costs and benefits  of the null strategy  have  been
evaluated  either quantitatively  or qualitatively. Results of this analysis are summarized
below and in Exhibits 37 and 38.

     1.   Direct Costs

         •    Opportunity costs may be incurred as a result of the null strategy when (if) a
              firm subject  to permit  denial  is operating  so close to  the margin that
              expansion is  economically feasible only at the preferred site (where permit
              denial would prohibit such expansion).

         •    Costs may  also be  incurred as a result  of dislocation, including such
              components as additional site selection expenditures,  possible land holding
              and resale expenses, and, in some cases, loss of economies of scale.

         •    Costs resulting from  location  at a less than optimal site involve the net cost
              increase resulting  from changes in the  price of the following locational
              requirements: land,  labor,  transportation, customer contact,  and business
              services.


 Facility forecasts  in  Chapter  II were  allocated by  town  according to an  employment
 distribution function (manufacturing) and a population distribution function (commercial).
-The DEP specified airshed towns.

-------
                                           IV-32
                                        EXHIBITS?
                 DIRECT IMPACT SUMMARY:  THE NULL STRATEGY
Economic Sectors
All Manufacturing
20 Food
22 Textiles
23 Apparel
24, 25 Lumber, Furniture
26 Paper
27 Printing, Publishing
28 Chemicals )
30 Rubber, Plastics )
29 Petroleum/Asphalt
33 Primary Metals
34 Fabricated Metals
35 Machinery
36 Electrical Machinery
37 Transportation Equip.
31 Leather
32 Stone, Clay, Glass
38 Instruments
39 Miscellaneous
All Commercial**
50-59
60-69
70-89**
All InstitOtipna!**
All Municipal Waste
Sewage Sludge
Municipal - Refuse-
Electric Utilities
AQMA Emissions*
TSP
% of 1975
24.6
0.4
0.7
0.1
0.03
1.6
0.1
3.1
0.2
2.5
2.5
1.8
1.2
6.4

4.0

6.5
0.6
1.6
4.3

34.6
0.3
34.3
24.7
% of Gross
Increase
1975 - 1985
40.2
0.5
0.4
0.1
0.1
1.0
0.2
8.0
0.9
1.9
6.8
1.3
3.1
9.5

.6.4

34.5
2.0
8.0
. 24.5

1.2
1.2
reduction
Zero
SO2
%of 1975
16.1
0.3
0.7
0.06
0.06
1.1
0.1
. 2.3
0.2
2.1
2.0
1.2
1.1
3.1

1.8

8.1
0.7.
1.8
5.S

2.1
0.02
2.1
71.4
% of Gross
Increase
1975 - 1985
37.7
0.6
reduction
0.1
0.2
1.4
0.5
8.5
0.8
reduction
6.9
1.5
5.2
7,7

4.3

54.0
2.5
11.0
40.5

0.1
0.1
reduction
Zero
Direct Impact
Cost
Forecast
. Growth -
I
(6)
(6)
(6)
(4)
(6)
(2)
(6)
(3)
(7)
(1)
(1)
-------
                                                                           EXHIBIT 38
                                                 INDIRECT IMPACT* SUMMARY:  THE MULL STRATEGY

All Six Regions
New Britain
Hartford
Waterbury
Stamford
Ansonia
Middletown
"~ 	 Costs
Incremen-
tal Unem-
ployment
•
13)
ID
14)
(1)
(4)
(2)
Populati'M*
Shift
1
<2)
(2)
(3) '
(21
(21
111
Develop-
ment
Patterns
M
(2)
, (2)
: (2)
< (21
ID
ID
Local
Taxes
1
1 (21
(2)
(2)
(2)
ID
ID
Ot(l8f Programs"
K6f>
M+
(3)
(3)
(3)
(2)
(2)
ID
fjconomic
Develop-
ment
M-
(3)
(3)
(3)
(3)
(2)
(11
Land
Use
(Vi-
la)
(2)
(2)
12)
ID
(1)
Social Well Being
Urban/
Rural
.
I"
(1)
(1)
ID
ID
(1)
Planning
Options
M
16)
(4)
IS)
(3)
(2)
ID
Local
Decision-
Making
Power
M
(6)
(4)
(SI
(3)
(2)
111
Income
Distribution
1
ID
(D
ID
(11
ID
(1)
Recreation
1
(D
(D
(D
(D
(D
(D
Mobility
1
(D
ID
(D
(D
(D
(D
Com-
munity
Structure
1
ID
ID
ID
ID
ID
ID
Benefits
Attractive-
ness
M
12)
(3)
121
13)
ID
ID
Resource
Use
Efficiency
M
(3)
13)
13)
12)
12)
ID
                                                                                                                                                              <
                                                                                                                                                              co
 * Indirect impacts classified as costs or benefits according to their source in
  either direct costs or direct benefits.
'•Indicates conflicting (-) or complementary (+).
Source:  Harbridge House, Inc. (1976).
                           KEY
I   = Insignificant impact.
M  = Moderate impact.
S  = Significant impact.
(  )= Relative rankings  among regions based on impact analysis,
     number and timing of permit denials, proportion of commer-
     cial versus industrial permits denied, and population density.
     (1) represents least relative impact. When all rank (1), indi-
     cates no difference.
-------
                                        IV-34
          •••   Within the manufacturing sector, 166 firms (17 percent of the forecasted
              AQMA expansion) are affected under Scenario 1 (low impact) and 365 firms
              (36 percent of forecast expansion in the AQMA) are affected under Scenario
              2 (high impact).

                 — Under both scenarios, SIC's 27, 34, and 35 are most impacted in terms
                   of the number of facilities affected.

                 - With regard to the forecasted AQMA growth subject to permit denials,
                   SIC's 20, 28, and 39 are also relatively more affected.

                 - The impact on  the  forecasted growth of  these industries within the
                   AQMA is likely to be insignificant.

          •-   Within  the   commercial  sector,  from  154  to  297  establishments  are
              potentially affected by the two scenarios; about half of these establishments
              are in the retail trade group. This represents,  at most, 3 percent of forecasted
              AQMA expansion. No impact  on the forecasted growth of these facilities is
              expected.

          •    Within the institutional sector, from zero to  five nursing  homes and from
              three to  six veterinary clinics are potentially subject  to  permit  denials. No
              impact on growth is expected.

          •-    No impact on the forecasted growth of municipal waste disposal facilities is
              expected.

          •    No significant impact  on  the  three to five apartment complexes subject to
              permit denials is expected.

     2.    Direct Benefits

          The potential for  violation of  the  standards in the six areas indicates that the
health and welfare  benefits  of the null strategy are significant. Data and methodological
constraints do not permit quantification of the order of magnitude of  these benefits.

     3.    Indirect Costs

          In  terms of the number of facilities subject to permit denials, Hartford is most
affected under  both scenarios. New Britain, Stamford, and Waterbury also show relatively
more facilities affected; Ansonia and Middletown are expected to have relatively few permit
denials.

          •'    The following impact on employment opportunities within the areas subject
              to permit denials was estimated as follows:

                 - Scenario  1: About 4,700 jobs potentially affected.

                 — Scenario 2: About 9,800 jobs potentially affected.
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                                   IV-35
            — At least 25 percent to 50 percent of these affected jobs will be shifted
              to areas within  the  commuting radius  of  the  affected towns.  The
              remainder will be relocated to other areas of the AQMA.

            - On an  annual  basis,  the transitional  unemployment  in  the  airsheds
              resulting from  the null strategy represents, at  most, from 0.1 to 0.4
              percent.

     •    Potential shifts in population affect the Waterbury area relatively more than
         the other  areas,  representing a reduction  of 2 percent (at  most) of the
         projected 1985 population.

     •    Changes in development patterns are expected to primarily reinforce current
         trends. However, unprecedented dispersion of development in the vicinity of
         the six airsheds is likely.

     •    Temporary imbalances in the revenue and expenditures of local governments
         may occur. No impact on state revenues/expenditures is expected.

     •    The null strategy is expected to complement  the goals of efficient  resource
         use set by  the Connecticut  Department of Planning  and Energy Policy. But
         in so doing, it may create adverse air quality impacts.

     •    Conflict with  objectives  of local economic  development  agencies  and
         statewide land use policies is expected.

     •    The range of options for future planning consideration as well as the degree
         of  authority at the local level  will be reduced in areas subject to permit
         denial.

     •    No significant impact on other indicators of social well-being is expected.

4.   Indirect Benefits

     •    The null  strategy will effect enhanced  attractiveness  of airshed areas for
         nonpolluting industries as well as improved quality of life for residents.

     •    Greater efficiency in the use of resources is expected to result from the null
         strategy.
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          CHAPTER V: IMPACT ASSESSMENT - THE SULFUR STRATEGY
A.   Background and Approach

         A statewide regulation limiting the sulfur content in fuel to 0.5 percent has been
in effect since  1973.  The strategy evaluated here differs  from  that regulation in two
respects:  (i) the sulfur content limitation is reduced to 0.3 percent and (ii) application of
this  reduction is  considered to affect  only fossil  fuel users in  the seven  towns of the
Naugatuck  Valley. 1 Consequently, it is  the incremental impact of this strategy - over and
above the impact of the existing statewide 0.5 percent sulfur limitation — that  represents
the focus of this evaluation.

         Although both coal and oil products are subject to the limitation,  use of coal in
Connecticut is currently negligible (see  Exhibit 39). There are, however, four Connecticut
power plants  on FEA's list for conversion from oil  to coal firing under the Energy Supply
and  Environmental  Coordination Act of 1974 (ESECA). Although none of these plants is
located in the Naugatuck Valley, a brief examination of the potential impact of ESECA has
been included at the request of Region I, EPA.

B.   Direct Costs

     1.   Public

         Since 1973, the increased public  cost incurred by the 0.5 percent limitation on
sulfur content of fuel has  been directly related to the sampling program carried out by the
Connecticut  DEP. The total  annual expenditures  for  the sulfur  sampling  program as it
currently exists are  estimated  at SI5,700. This represents less than 2 percent of the state's
budgetary expenditures for the Air Unit of the  DEP. A breakdown of the expenditures
incurred  from the implementation of the sulfur sampling system is shown in  Exhibit 40.
Approximately 200 samples are taken in each year yielding an estimated cost of $78.50 per
sample.2

         It has been assumed that  the sampling program will continue to operate  at the
present  rate  into the future  since  the  number of samples  taken  and the  extent of the
sampling program is not expected to change.3 The  total present value of the  program costs
over the  next 10 years — determined using a 6 percent rate of interest which  represents the
^Waterbury, Naugatuck, Beacon Falls, Seymour, Ansonia, Shelton, and Derby. These towns
 comprise the entire Valley RPA and part of the Central Naugatuck Valley RPA.
^Robert Sargis, Department of Environmental Protection, Telephone interview 30 October
 1975.
      source of potential change in future costs, which cannot be evaluated quantitatively,
 involves  litigation  that  may result  from application of this strategy  to  the Naugatuck
 Valley, alone.
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                                     V-2
                                 EXHIBIT 39
                   SOURCES AND DISPOSITION OF ENERGY
                       IN CONNECTICUT AND THE U.S.
                                   (1975)
Sources of Energy

    Petroleum Products

    Natural Gas

    Coal

    Nuclear

    Hydroelectric

    TOTAL
Connecticut

    78%

     9

     0

    12

   	1_

   100%
U.S.

 45%

 32

 18

  1

  4

100%
Disposition of Energy

    Residential                               19.5%

    Commercial                              14.0

    Industrial                                12.5

    Transportation                            26.0

    Miscellaneous and Electric Generating         28.0

    TOTAL                                100.0%
                               24%


                               28

                               25

                               23

                              1.00%
Source:  Ed McDonald, Connecticut Department of Planning and Energy Policy (1975).
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                                    V-3
                                EXHIBIT 40
                    ESTIMATED CURRENT ANNUAL COSTS
                        OF THE SAMPLING PROGRAM
Labor                                            Costs/Year

    1 principal engineer (part-time)                    $1,500

    1 engineer (part-time)                             6,300

    1 engineer intern (part-time)                          900

    1 inspector (part-time)                             4,500

    1 secretary (part-time)                               100

    TOTAL LABOR COSTS                                           $13,300


Equipment (sample cleaning equipment, etc.)                                  400

Supplies                                                                100

Laboratory                                                              400

Transportation (car)         .                                             1,500

    TOTAL COST OF SAMPLING PROGRAM                            $15,700
Source:  Robert Sargis, Department of Environmental Protection, telephone interview 30
        October 1975.
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                                         V-4
current  long-term  lending rate  for  Connecticut  bondsl.-is  about  SI 15,600.  This
expenditure does not represent  any increased costs  to DEP as a result of sulfur strategy
implementation.

     2.    Private

          The economic implications of this strategy are related primarily to two issues: the
availability of low sulfur fuel and the differential cost between 0.5 percent and 0.3 percent
sulfur fuel.  Residual oil has been  the  primary  focus of this part of the study for several
reasons: (i) residual oil contains  more sulfur than distillate oil because of the nature of the
refining process;2 (ii) distillate is subject to availability problems not associated with sulfur
content; and (iii) coal is discussed under Section  E, "Impact of ESECA," below.

          a.   Availability. The issue of availability  has been approached in the context of a
recent  study for  EPA regarding the supply  and demand for low sulfur oils.3 This study
evaluated  the 1975 demand for residual fuel by sulfur content in the Petroleum Allocation
District (PAD) I,  which is comprised  of the New England, Central Atlantic, and Lower
Atlantic states. Because imports  into PAD I are  largely from U.S.-dedicated refineries in the
Caribbean, the study modeled  the  1975  potential Caribbean  refinery output by sulfur
content. Then,  based on 1973  supply shares, the potential Caribbean supply was allocated
among the regional markets within PAD I. The results of the market allocation are shown in
Exhibit 41. It can be concluded  from the data that although sufficient supplies of the lower
sulfur residual are  available from Caribbean sources to satisfy the aggregate demand of  PAD
I, the regional  demand (in New England) cannot be satisfied  if supplies are allocated in
historical patterns.4

          This conclusion  must  be  tempered with  consideration of  the current low sulfur
fuel use in Connecticut. In particular, the study estimated a 1975 potential supply shortage
of less than 0.5 percent sulfur residual in New England. Yet  the DEP estimates that the
sulfur content  of fuel currently used in  Connecticut is averaging between 0.4 and 0.5
percent.5  Some users are, in fact,  currently  burning 0.3 percent sulfur fuel.6 Moreover,


 A 6 percent rate was assumed based on telephone interviews, conducted in December 1975
 with municipal bond officers. The First National Bank of Boston  estimated  a long-term
 lending rate for a Connecticut state bond at between 5.0 percent  and 5.5 percent.  First
 National City Bank of New York estimated a long-term lending rate for a Connecticut state
 bond at between 6 and 7 percent. See Appendix H.
-Low sulfur supply problems do  not pose a threat for distillate. Only  volume problems exist
 for  this fuel, without regard  to sulfur content. Source: ICF Incorporated. Forecast and
 Analysis of Supply and Demand for Low Sulfur Fuels, for EPA,  May 1975, p. 12.
3Ibid.
 The report also points out that FEA allocation regulations are  based  on historical shares.
 Ibid.,  p. 97.
-'Greg  Wight, Air Compliance,  Connecticut Department  of  Environmental  Protection,
 November 1975.
°The Federal Power Commission, Monthly Fuel Cost and Quality Information (November
 1975)  indicated  that  0.3 percent has recently been received by  a  Connecticut utility.
 Without knowledge of the power plant location, no adjustment can be  made to  account for
 this in the impact assessment.
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                                    V-5
                                EXHIBIT 41
                SUMMARY OF REGIONAL MARKET BALANCE:
            IMPORT REQUIREMENT/CARIBBEAN SUPPLY BALANCE
                              (million bbl/day)
Sulfur Content

New England

    Caribbean Supply*

    Average Annual Import
    Requirement

Central Atlantic

    Caribbean Supply*

    Average Annual Import
    Requirement

Lower Atlantic

    Caribbean Supply*

    Average Annual Import
    Requirement
Less
than 0.5 0.51-1.0
193.9 106.9
195.0** 124.6**
714.2 95.3
572.0
7.4 109.3
244.0**
Greater
than 1.0
133.3
39.3
400.9
177.0
586.3
246.0
Total
434.1
358.9
1,210.4
749.0
703.0
490.0
 *Based on 1973 supply shares.
**Potential supply shortage.

Source: ICF Incorporated, Forecast and Analysis of Supply and Demand for Low Sulfur
       Oils, for EPA, May 1975.
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                                         V-6
residual shortages are  not  evident in Connecticut. 1  Consequently, the potential supply of
0.3 percent sulfur fuel in Connecticut may not be as constrained as that study suggests.

          Harbridge House conducted  interviews with representatives of major oil com-
panies and petroleum  product specialists in order to assess their perspective on the future
availability of 0.3 percent sulfur residual. Both the editor of Platt's Oilgram and the Heavy
Fuel Oil Coordinator for Exxon Oil Co. foresaw sufficient availability of 0.3 percent sulfur
fuel.2  Several  of  the  interviewees  pointed  out   that  with the  construction of  new
desulfurizing refineries in the United States, there is a growing capacity to produce lower
sulfur  fuel oil. The  Caribbean, which is the primary  source of fuel  oil for the northeast
coast, also has sufficient desulfurizing refinery capacity.3

          A shortage of low sulfur fuel oil  could  occur as the  result  of extraordinary
circumstances (for example, the  OPEC embargo) affecting the basic supply and demand
distribution of all types of  fuel  oil.4 Such an extraordinary circumstance is usually not
foreseeable and when it does  occur, it affects all grades of fuel oil from low to high sulfur. If
such an extraordinary shortage occurs, however, the  oil  companies  may tend to produce
only high sulfur fuel because it is easier and faster to produce in greater quantities than the
low sulfur fuel.5  Nevertheless, based on a normal  balance of supply and  demand, there
should be a general availability of the 0.3 percent sulfur fuel oil.

          b.   Price. Estimates of the price differential between 0.5 percent and 0.3 percent
sulfur  fuel oil vary significantly.  Platt's  Oilgram shows a  SO.74 to SO.92 per barrel price
differential, or a 6 to  8 percent  higher  price for the lower sulfur fuel, as of 3 December
1975.6 EPA's general rule of thumb for sulfur content price differential is SO.66 per barrel
more  (a 5 percent increase) for the 0.3 percent sulfur fuel. 1 Recent studies for EPA indicate
differentials of SO. 15 per barrel^ and SO.25 per barrel (about a 1 to 2 percent increase).


iThe  variance  applied for by a  Connecticut  utility  was not based on any difficulty in
 obtaining sufficient supplies of 0.5 percent sulfur residual. Ibid. March 1976.
2Mr.  McClelland,  editor, Platt's  Oilgram and  Price  Service,  publication  of McGraw-Hill,
 telephone interview, 3 December 1975.
3Mr.  LeCates,  Heavy  Fuel Oil Coordinator,  Exxon Oil  Co., Houston, Texas, telephone
 interview, 4 December 1975.
^Interviews with Mr. McClelland and Mr. LeCates.
5Interview with Mr. McClelland.
6Platt's Oilgram Price Service, December 4, 1975. Price differential for New York City and
 Philadelphia  from  $0.87  to SO.92;  New  Haven  Harbor estimated at  S0.74 by  Mr.
 McClelland, editor. (Prices are for No. 6 residual.)
^Cheryl Wasserman, Policy Planning Division, U.S. EPA; January 1976 [Differential equals
 S13-3 (log % sulfur)].
^Energy  and Environmental Analysis,  Inc.,  The Costs of Sulfur Oxide Controls to Oil
 Burning Power Plants in 1980 for U.S. EPA, September 4, 1975. (Based on the differential
 in direct desulfurization costs of crude Arabian light oil in 1973. Cost adjustment for 1974
 is suggested at 28 percent. 10 percent increase used to adjust to 1975.)
^Environmental Protection Agency, Implications  of Alternative  Policies for  the  Use of
 Permanent Controls and Supplemental Control Systems, Office  of  Planning and Evalua-
 tion,  July 7, 1975. (Estimates are  for delivered price of residual fuel by state and sulfur
 content in 1980. Converted from cents per million Jtu to cents per barrel using factor of
 6.3 x 106 Btu per barrel.)
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                                         V-7
         These  differences probably result from variations in the source of the crude
petroleum, in the  type of refining  and  desulfurization used, and  in  the  grade  of oil
produced. For example, No. 4 grade oil (classified as a residual by the DEP) is a blend of the
lighter No. 2 grade (distillate) and the  heavier No. 5 (residual). Distillates do not usually
require desulfurization because the refining process removes most of the  sulfur impurities.
However, residuals do require the extra cost of desulfurization in order to be  classified  as
low sulfur fuels. Moreover, higher sulfur crude has higher refining costs.

         Because  of  these considerations, it appeared most reasonable  to assume  a  cost
differential  based  on  the  prices  quoted for New  Haven Harbor  by  Platt's  Oilgram.
Presumably, these costs would reflect the  composition of crudes, processes, and fuels used
in Connecticut. However, because  the SO.74 per barrel (6 percent) price differential between
0.3 percent and 0.5 percent sulfur oil is higher than most other estimates, it should probably
be considered to bracket the high-impact case.

              (1)   Impact on Manufacturing. Exhibit 42 shows residual oil intensity-of-use
ratios for the Connecticut manufacturing sector. The ratios represent the  barrels of oil used
in 1971 to produce $1,000 in value added (1967 S). Ratios are also shown which indicate
the cost  of residual  oil in 1971  (1967  S) per  SI,000  in value  added. Industries with
relatively greater intensity-of-use  ratios  can be assumed to  be  relatively  more sensitive  to
increases in residual oil prices.

         As shown in Exhibit 42, SIC 26 (paper) is most sensitive to increased fuel prices.
In  1971,  fuel  costs  represented  about  0.03  percent of value  added  in that industry.
Assuming  that the ratios remain constant  over time, a 6 percent (or high range) increase in
fuel oil prices would, at most, increase the cost of operations by 0.2 percent. 1

         Fuel price increases that have occurred since 1973 provide an indication of the
impact of these increased costs. In 1972, the delivered price of residual oil  to industrial users
was about S4.30 per barrel.2 The  1975 price of SI 1.76 per barrel (Platt's Oilgram)  indicates
a 273 percent price increase. Again, based on the 1971 intensity-of-use  ratio this residual
fuel price increase can be estimated to have increased the  cost of operations in SIC 26 by
7.9 percent.

         An evaluation conducted by the First National Bank of Boston during the spring
and fall of 1974 provides some insight into how New England manufacturers responded to
these drastic price increases.3 A  brief summary of relevant  data and conclusions  is  shown
below:

         •    From September 1973 to March 1974 the median increase  in energy costs to
              manufacturers was 34  percent.  For the one-year period through September
 This is calculated by multiplying the fuel cost as a percent of value added (28.95 x
 times 6 percent.
-Connecticut's Energy Outlook,  p. A-29. Adjusted to 1972 S.
^First  National  Bank of Boston. A Special Evaluation of Energy Cost Impacts on New
 England  Economic Development (undated). (Of the  255 and 275 firms surveyed in  the
 spring and fall of 1974, 49 and 52 firms, respectively, were in Connecticut.)
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                                        V-8
                                    EXHIBIT 42
                      1971 RESIDUAL OIL INTENSITY-OF-USE
                           RATIOS FOR CONNECTICUT
     SIC
     26
     22
     28
     32
     24
     33
     39
     31
     25
     34
     30
     37
     20
     38
     35
     29
     23
     36
     27
 Barrels/103
$ Value Added
    7.66
    4.23
    4.04
    3.05
    2.69
    2.53
    2.05
    1.38
    0.99
    0.94
    0.88
    0.81
    0.59
    0.58
    0.40
    0.38
    0.35
    0.22
    0.12
  $ Fuel/103
$ Value Added
    28.95
    15.99
    15.27
    11.53
    10.17
     8.88
     7.75
     5.22
     3.74
     3.55
     3.33
     3.06
     2.23
     2.19
     1.51
     1.44
     1.32
     0.83
     0.45
Source:   Based on residual fuel use data in Connecticut's Energy Outlook 1975-1994 and
         Energy Emergency Plan for CofJnecticut and Census of Manufactures value added
         (deflated to  1967 constant dollars). Distribution  based on DEP listing of major
         residual  fuel  burners in the Naugatuck Valley. 1971 delivered price of residual to
         industrial users in Connecticut was $3.78 per barrel (1967 $) (Connecticut Energy
         Outlook).
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                                         V-9
              1974, the median increase was 50 percent.  In  both surveys the range was
              from 0 to over 400 percent.

         •    In the spring survey, the percentage increase in total manufacturing costs
              because of higher energy costs averaged 2.2 percent, with a  range from 0.1
              percent to 8.7 percent. In  the fall survey, the average was 3.2 percent while
              the range was from 0.9 percent to 5.9 percent. (Ranges given by SIC.)

         •    Of the firms surveyed, 84.3 percent (spring) and  82.9 percent (fall) indicated
              that increased energy prices had not affected capital spending plans; 5.1 per-
              cent (spring  and fall) indicated an increase in capital spending; 4.7 percent
              (spring) and 7.3 percent (fall) indicated a decrease in capital spending as a re-
              sult of increased energy prices.

Based on the limited change in capital spending plans resulting from significant increases in
energy costs experienced by the firms surveyed, it appears  very unlikely that the minimal
price increase caused by the  sulfur strategy will have any substantial effect on the forecasted
industrial growth in the Naugatuck Valley.

         The greatest growth in the  Valley RPA was projected in SIC's 30,  33, 34, and 35,
while the Central Naugatuck Valley RPA was forecasted to experience substantial growth in
SIC's 28 and 38. Exhibit 43 summarizes the spring and fall survey results regarding increased
manufacturing costs for these  industries  as a result  of the  1973-74 price  increases. Also
shown are  the calculated percentage increases in operating costs for  the 6 percent price
increase resulting from the  sulfur strategy. It is not presumed  that  the  1973-74 price
increases were easily absorbed  or that they  did not, of themselves, precipitate a long-term
impact on the competitive advantage of the firms most heavily affected. Nevertheless, in the
context of  such recent  significant price  changes, the  incremental impact  of a 6 percent
increase (at most) in residual  fuel prices is not expected to have any substantial effect  on the
competitive position of the industries in the Naugatuck Valley.

              (2)  Impact on  the Commercial Sector. 1 The commercial sector is the other
major user  of residual oil in  Connecticut (about 30 percent of residual oil use). Within this
sector, residual oil  users are generally large energy users —  thus, they are also  likely to be
sensitive to  increased fuel prices.2 However, the proportion of fuel costs to total operating
costs within the commercial sector is usually significantly smaller than in  the manufacturing
sector.3

         SIC's 23, 36, 27 are at bottom of the residual oil intensity-of-use ratios calculated
for manufacturing.  In estimating space heating and lighting requirements versus production
requirements for  fossil  fuels,  the  Connecticut  Energy Agency used these industries  as
 As opposed to earlier analysis, the commercial sector in this part of the study is considered
 to include educational and health services (institutional) because of the aggregation of fuel
 use data.
-}
-Connecticut's Energy Outlook, p. c-68.
 In manufacturing fuel is required in production processes as well as for comfort purposes.
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                                    V-10
                                 EXHIBIT 43
                PERCENTAGE INCREASE IN MANUFACTURING
                COSTS AS A RESULT OF HIGHER ENERGY COST
                                                              Estimated %
                  	Survey Results	t               Result from
SIC               Spring 1974            Fall 1974              Sulfur Strategy

28                   1.3%                 3.5%                   .09%

30                   4.2                   4.1                     .02

33                   2.4                   5.7                     .05

34                   2.7                   2.5                     .02

35                   2.1                   2.3                     .009

38                   2.9                   3.4                     .01
Source:  Survey Results from A Special Evaluation of Energy Cost Impacts on New Eng-
        land Economic Development.  Estimated impact from sulfur strategy described in
        text.
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                                        V-ll
representative of 100 percent heating and lighting.  From  this,  the  Agency estimated the
energy use components in other manufacturing industries. 1

         It appears  to be reasonable to approximate the impact of  increased fuel oil costs
in the commercial sector on the basis of the lowest use ratios in Exhibit 42. Assuming again
that a  6 percent increase in  residual oil costs represents  the  upper impact level of sulfur
strategy  implementation, the resulting incremental  increase in  costs  of operation to the
commercial  sector ranges  from .003 to  .008 percent.  No impact  on  the  growth or
competitive  advantage of industry groups within the sector is  expected to  result  from this
minimal cost increase.

              (3)  Impact on Electricity Generation. A  6 percent increase  in  price of
residual oil may have a significant impact on the cost of electricity in Connecticut because
of the fuel  adjustment  clauses which allow  utilities  to  pass increased fuel costs on to
consumers. In a state  where  about 40 percent of the electricity generated is from nuclear
sources,  the cost of fossil  fuels currently represents 36.2 percent of each  dollar of utility
revenue.- Consequently, a 6 percent increase in price of fuel oil  would result  in  a 2.2
percent increase in the cost of electricity to households served by utilities in the Naugatuck
Valley.

C.   Direct Benefits

         Implementation of the sulfur  strategy  would result in  as much as a 2  percent
decrease  in the sulfur available for emission to the ambient air during  fuel combustion in the
Naugatuck Valley. Over time, the reduced amount of sulfur in fuel would decrease the rate
of air quality degradation. The populations  of the seven towns in the Naugatuck Valley as
well as in some adjacent communities will experience a reduction (absolute and relative) in
the costs associated with air pollution damage. As described in Appendices L and M and in
Chapter III,  these benefits are likely to be substantial.

         Within the seven towns in the Naugatuck Valley,  11 percent of the population is
over 65 years of age, compared with a statewide average of 9.5 percent.3 Since older persons
are more affected by  the health dangers of air pollution, benefits  from decreasing sulfur
oxide emissions and stemming future growth in emissions will probably be comparatively
greater in the Naugatuck Valley than in the state as a whole.

D.   Indirect Costs

         Because  of the limited direct cost impact,  as  discussed above, there is little basis
for assessing the  indirect cost implications of the  sulfur strategy. Socioeconomic  variables
such as  employment, population, distribution, development patterns, taxes, and social
well-being were considered and  no evidence  of adverse impact was found. There is one
aspect  of implementation, however, that may indirectly result  in increased  costs:  fuel
dealers  will  have  to store the  0.3  percent  sulfur fuel  oil  for  Naugatuck Valley  users
 Energy Emergency Plan for Connecticut, p. A-81.
T
^Fred Sutton, Senior Rate Research Analyst, Northeast Utilities, March 1975.
^Connecticut Market Data Book, based on 1970 census figures.
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                                         V-12
separately  from the 0.5 percent sulfur oil distributed to other areas of Connecticut. This
may require construction  of additional facilities as well as underutilization of existing
facilities. If so, there will be a situation of inefficient resource utilization and increased costs
for the dealers.

E.   Indirect Benefits

         As described  in Chapter  III and Appendix L, there is evidence of a demand for
locations away  from  air pollution.  Because  of this, the  improved  air quality in  the
Naugatuck  Valley that results from  implementation  of  the sulfur strategy  will provide
residents with an  improved  quality  of life  and may incrementally improve  the  area's
attractiveness  for business  location  (see discussion of  attractiveness  in Chapter III).
Moreover, by decreasing the sulfur  oxides emitted into the atmosphere, more  development
can be accommodated within the air quality standards (see the orderly growth  discussion in
Chapter  III).  As with  the  permit  program, then,  the  sulfur strategy mediates local
government's pollution concerns and the desire for economic development.

         Increased energy conservation may also result from the sulfur strategy. As prices
rise, users may become  more sensitive to unnecessary consumption  of both electricity and
fuel oil. The First National Bank of Boston study on the 1973-74 energy crunch provides a
parallel  for this consideration. The  study noted that private discussions with several of New
England's large utilities indicated reductions in the use of electricity of up to 15 percent.
Results  of the fall survey of manufacturers showed that all industry groups were responding
to increased energy prices by decreasing consumption. The mean percentage decrease among
the industry groups ranged from 4 to 10  percent. Within industry groups, however, as many
as two  thirds of  the respondents  reported no decrease  in energy consumption. Conse-
quently, from the point of view of only a 6 percent increase in the price of  fuel oil, it
appears  that minimal (if any) increased  conservation could be expected for the  industrial
sector.

F.   Impact of ESECA

         The Energy  Supply and  Environmental Coordination Act of  1974 directs  the
Federal  Energy Administration (FEA) to order conversion to  coal  of any oil or gas-fired
electric  power plant (or other major fuel-burning installation) provided that the plant (i) has
equipment  to  burn coal; (ii) has access to adequate coal supplies; and (iii) can meet other
criteria, most  of  which are  environmental. The Act represents  a compromise designed to
postpone  conflict  over pressures  to ease air  quality  standards  until  sulfur  removal
technology  is perfected.  It  is intended as a  stopgap  measure to  deal  with foreign oil
embargoes. 1  All  plants  ordered to  convert  must be able  to  meet primary air quality
standards at the time of conversion, but  could receive a variance from secondary standards
provided EPA certified that the converting utility had a compliance plan that would enable
it to meet all clean air requirements  by 1 January 1977.2
* Easing air quality standards would stimulate  the use of the nation's vast deposits of high
 sulfur coal, which cannot be burned under current federal air quality standards.
•^
 James  G. Phillips,  Energy  Report:  Unexpected  Obstacles Hinder Ford Plan for  Coal
 Conversion.  National Journal Reports, May 31, 1975, p. 816.
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                                        V-13
         FEA developed a list of 80 plants for potential conversion, four of which are in
Connecticut.  Of the 80 plants, however, EPA has estimated that the  Act's environmental
criteria would permit only about 23 to convert. 1 Implementation problems encompass two
major controversies: the availability and cost of low sulfur coal, and the cost of pollution
control equipment  where  cleaner burning coal is not available.2 In addition to  these key
problems, there  are  others that may also present substantial obstacles to implementation.
These are summarized below:

         •    Manpower requirements for engineering, design, and water quality control to
              convert plants scheduled to go on line before 1980.

         •    Financial liabilities under contracts for oil supplies.

         •    Electrical reliability while units are removed from service for conversion to
              coal  firing. Includes lead time to provide the replacement generating capacity
              to assure continued reliability of service.

         •    Interface with  Federal Power Commission gas  curtailment  orders  which
              directed plants  to switch from gas to oil. (Some consumers may have to bear
              the costs of yet another switch, this time from oil to coal.)

         •    Installation of  new equipment in plants that may otherwise have relatively
              short economic life remaining — indicating a potential  for economic  waste.

         •    Availability of  the  quantity of new boilers required for conversion under the
              Act's requirements.

         •    Adequacy of the transportation system for coal delivery.

         •    Long-term  effectiveness of an  oil   conservation  effort aimed at  coal
              conversion  versus nuclear energy and at electric  generation as opposed to
              transportation (gasoline consumption).

         The low sulfur-coal/scrubber controversy is based on the contention that the costs
of acquiring low  sulfur coal or scrubbers on the one hand, and the environmental cost of not
acquiring either  on  the  other  hand,  do not outweigh the benefits of oil savings resulting
from  conversion to coal.  FEA has  contended  that there will be considerable  economic
savings from  the conversions in addition to national security benefits.  Arguing that savings
of S2.19 per  barrel  of oil will  result, FEA assumes continuation  of S12 per barrel price for
oil and S40 per  ton  for coal, a S60 per kilowatt cost  for scrubbers installed  in new plants,
and  an  $80  per kilowatt cost  for  modifications  of existing plants to  accommodate
scrubbers.3
1 Phillips, op. dr.. p. 816.
•^
-One EPA study estimated that 26 of the 80 conversion candidates would need stack gas
 scrubbers if EPA's estimates of low sulfur coal availability were accurate. Ibid., p. 817.
3Ibid., p. 818.
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                                        V-14
          On the utility side, it is argued that the price of coal will eventually escalate to the
level of oil prices,  with the net result that excessive costs will be imposed upon utilities at a
time when they are experiencing a capital crunch. It has also been suggested that because of
the utilities' relative  insensitivity to fuel prices (the result of fuel adjustment clauses), there
is  a disincentive to undertake capital spending (which takes much longer to recoup) as  an
alternative to high  fuel oil costs.

          The foregoing arguments represent only  the tip of the iceberg in a drawn out and
very cost-specific controversy. In order to assess the potential impact of ESECA on the four
Connecticut plants!  on FEA's list  of conversion  candidates, data are summarized below
concerning the cost of scrubbers and the availability and cost of low sulfur coal.

     1.    Availability and Cost of Low Sulfur Coal

          ESECA  provides  for issuance of variances from secondary standard compliance.
However,  it also imposes a "regional limitation," whereby secondary standards must be met
in  air quality regions where  the primary standard is violated (although not by the converted
plant  itself)- [Since  Guidance for Regional  Limitation  Determinations  Under ESECA
recommends that air quality data be treated literally (in most cases), it is likely that regional
limitation would apply  to the  Connecticut Utilities.2] Consequently, substantial pressure is
being placed on the already tight supply of low sulfur coal, particularly in the East where air
quality standards are relatively stiff and much of the low sulfur coal is committed to steel
making.

          FEA  has estimated  that  the nation's annual demand for coal will increase by
about 41  million  tons by   1980 as a result of conversion of the 80  potential candidate
facilities.3 To meet this demand new  mines will have to be opened. Yet the  coal industry is
demanding that utilities put up the tremendous advance investment capital for them and, in
some  cases, contract for the mine's entire output.  Moreover, the lead time  required (from
two to five years) to bring new mines to production necessitates quick action.

          Both  FEA  and EPA have estimated the extent of a clean fuels (coal) deficit over
time.  Taking into  account  increased supplies of low sulfur coal and  the use of stack gas
scrubbers, the 1975  deficit  was  estimated  at about 225 million  tons by  both agencies.  In
 The four plants on FEA's list are:
           Company                     Plant        Unit Numbers      Capacity
  Connecticut Light and Power         Montville            5               75
                                       Devon           3,7,8            273
                                   Norwalk Harbor       1,2             326
  Hartford Electric Light              Middletown         1,2,3            422
 The  Montville plant  would  need  a new precipitator;  EPA would require the other three
 plants to install scrubbers. (Source: Phillips, op. cit., p. 821.)

2U.S. EPA Guidance for Regional Limitation Determinations  Under ESECA. OAQPS No.
 1.2-033. (July 1975).
^National Journal Reports. May 31, 1975.
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                                        V-15
1977  EPA estimated a deficit of 100 million tons, while FEA estimated 175 million tons.
By  1980 EPA's estimate is only 25 million tons, FEA's, 100 million tons.l Overall, EPA
expects that in the post-1980 period there will be more than adequate supplies of low sulfur
coal.2

         Clearly, though, through 1980 there  will be a premium on low  sulfur coal. In
1973, the differential price between high and low sulfur coal was S3 per ton; it is expected
to rise to S4 per ton (1974 S) in the future.3 Moreover, the rapid increase in coal prices over
the last few years coupled with the pressure for increased production requiring large capital
outlays suggests price increases  for all types of coal.

     2.   Cost of Scrubbers

         The scrubber debate is closely linked to  the availability and cost of low sulfur
coal, as shown by the inclusion of scrubbers in calculation of clean fuels deficits by EPA  and
FEA.  However,   the  question of scrubber  availability  and  reliability  has declined in
significance,  compared  to  the issues  of installation costs and their relationship  to  the
economic practicality  guideline  written into ESECA. A sample of the pollution control
estimates originating from different sources is shown in Exhibit 44. Totaled over one plant
or several plants  of one company, these costs  can  reach large  proportions. For example,
Bertram D. Moll, vice president for inter-utility operations of New York City's Consolidated
Edison Company has said that the cost of scrubbers alone would run S278 million for three
Con Ed plants regarded by FEA as leading candidates for conversion.4

          Using the FEA cost estimates and applying them to the  capacities  of the four
Connecticut plants, the following pollution control costs are estimated:

         •    Montville plant: S300,000 (precipitator).

         •    Devon plant:  521,840,000 (scrubber retrofit).

         •    Middletown plant: S33,760,000 (scrubber retrofit).

         •    Norwalk Harbor plant: 526,080,000 (scrubber retrofit).

Total costs  for pollution control equipment alone would be nearly 582 million. Assuming
that all of the increased cost is passed on to the consumers, electricity rates  in Connecticut
l"How the  Clean  Air Act Clogs Clean Fuels Development," in Mining Engineering.  May
  1975.
-Letter to Senator Robert Morgan from Roger Strelow, Assistant Administrator for Air and
 Waste Management, EPA, December 1975.
•'EPA. Implications  of  Alternative Policies for  the Use  of Permanent Controls and
 Supplemental Control Systems (SCS), July 7, 1975, p. A-l 5.
"* As reported in NationalJournal Reports.  December 14, 1975, p. 1867.
-------
                                      V-16
                                  EXHIBIT 44
               ALTERNATE ESTIMATES OF POLLUTION CONTROL
                       COSTS REQUIRED UNDER ESECA
                         ($ per kilowatt of plant capacity)
FEA*

Utility Officials'


EPA Panel***

CACC1
Upgrading TSP
   Control
  Equipment

     $4

  $13-522
New Scrubber
 Installation

    $60
PEDCO
       t
                       $60
                      (1974$)

                       $60
 Scrubber
  Retrofit

   $80

   $100
(minimum)

 $50 - $65

   $80
 (1974$)

   $65
  *"Unexpected Obstacles Hinder Plan for Coal Conversion," National Journal Reports,
   31 May 1975, p. 818.
 ^"Utility  Executives Attack Ford Coal Conversion Proposal," National Journal Reports,
   14 December 1974, p. 1867.
 '*"Great Scrubber Debate Pits Utilities  Against Electric Utilities," National Journal Re-
   ports, 27 July 1974,  p. 1107.
  'Clean Air Coordinating Committee and Redco, Inc. (for EPA), surveys as cited in The
   Costs of Reducing SO2 Emissions from Generating Plants by NERA, Inc., for Electric
    Utility Industry Clean Air Coordinating Committee, June 1975.
-------
                                        V-17
will increase about S27 per household. 1 This represents about an 8 percent increase over the
average household's 1975 electricity bill.2

         With regard to benefits, consideration may be given to the stimulation in demand
for air pollution control equipment. Based on  1975 nationwide control equipment market
estimates of S310 million to S850 million (see  Chapter III), the ESECA expenditures in
Connecticut represent from  10 to 26  percent  of current national air pollution  control
equipment demand. Manufacturers will clearly benefit from this increased demand.

G.   Summary

         Evaluation of the sulfur strategy focused on the impacts of reducing the sulfur
content limitation in fuel from 0.5 percent to 0.3 percent and applying this reduction to the
seven towns in the Naugatuck Valley. Emphasis was placed on residual oil fuel users because
(i) currently, use of coal in Connecticut is negligible, and (ii) distillate oil is generally not
subject  to  availability and cost constraints related  to sulfur content. At  the request of
Region  I,  EPA,  the impact of the Energy Supply and Environmental Coordination Act of
1974 (ESECA) was evaluated separately. The results of this analysis are summarized below
and in Exhibits 45 and 46.

         Direct Costs

         •    The economic implications of the sulfur strategy are primarily related to the
              price and availability of low sulfur fuel.

         •    Analysis indicates that sufficient quantities of 0.3 percent sulfur residual oil
              will be available for users in the  Naugatuck Valley.

         ••    At most, a 6 percent increase in the price of residual oil is estimated to result
              from strategy implementation.

         •    For major manufacturing users of residual oil in the  Naugatuck Valley, the
              percentage increase in manufacturing costs  as a result of the sulfur strategy
              ranges from 0.01 to 0.09 percent. In light of the 2.0 to 6.0 percent increases
              in manufacturing  costs  for  these industries that  resulted  from  the energy
              price increases of 1973 to 1974, no significant impact on the forecast growth
              or competitive advantage within this sector is expected.
*A recent report for the electric utility industry by NERA, Inc. An Analysis of the Costs to
 the Electric  Utility  Industry  of House and Senate Significant Deterioration Proposals
 (December 12. 1975),  also assumed that all costs (including capital costs) would be passed
 on to households.  Note  that  no amortization,  energy,  labor,  etc.,  costs have  been
 estimated.  Households in Connecticut in  1974 from Homer Siler and George Associates,
 Connecticut Housing Market Analysis.
2Average household bill in June 1975 was S25.75;in December 1975, it was $31.46. Using
 the average of  these two monthly bills, the annual 1975  electricity bill was S343.26.
 Source: Fred Sutton, Senior Rate  Research Analyst, Northeast Utilities, March 15, 1976.
-------
                                      V-18


                                  EXHIBIT 45
                          DIRECT IMPACT SUMMARY:
                      THE SULFUR STRATEGY AND ESECA
Economic Sectors
• Sulfur Strategy
All Manufacturing (SIC)
20 Food
22 Textiles
23 Apparel
24 Wood )
25 Furniture j
26 Paper
27 Printing, Publishing
28 Chemicals |
30 Rubber, Plastics J
29 Petroleum/Asphalt
33 Primary Metals
34 Fabricated Metals
35 Machinery
36 Electrical Machinery
37 Transportation Equipment
38 Instruments
31 Leather
32 Stone, Clay, Glass
39 Miscellaneous
All Commercial/Institutional
Electric Utilities
(price of electricity)
• ESECA
Electric Utilities
(price of electricity)
SO2 Emissions*
Percent
of 1975
14.50
0.20
0.70
0.06
0.07
0.70
0.08
3.40
0.20
3.40
1.70
0.40
0.10
1.20

2.30

7.10
76.00


Percent of
Gross
1 ncrease
197S1985
38.4
0.6
1.2
0.1
0.3
2.7
0.6
12.2
1.1
Reduction
6.7
0.60
2.2
3.5

6.6

56.4
0.0


Direct Impact
Costs
Economic
Growth
I
(2)
(7)
(1)
(6)
(4)
(8)
(1)
(7)
(3)
(1)
(6)
(4)
(2)
(1)
(3)
(2)
(5)
(6)
(5)
I
I
M

I
S
Benefits
Health
and
Welfare
M
(1)
(2)
(D
(D
(2)
(1)
(5)
(2)
(2)
(4)
(1)
(2)
(3)

(4)

M
M

I
Demand
Stimula-
tion
NA














v

NA
NA

S
* Emissions represent S02 emissions from point source fuel  combustion in New Haven
 County, which includes the Naugatuck Valley.
                                     KEY
  NA =  Not Applicable                               M=  Moderate Impact
  I    =  Insignificant Impact                           S =  Significant Impact
  (  )  =  Relative  rankings  within major sectors.  (1) represents least relative impact.
         Impact on growth based on intensity-of-use ratios. Impact on health and wel-
         fare based on emissions.
Source:  Emissions from the DEP; Economic Analysis by Harbridge House, Inc. (1976).
-------
                                              EXHIBIT 46
                                      INDIRECT IMPACT SUMMARY:
                                   THE SULFUR STRATEGY AND ESECA

Region

(strategy)
Naugatuck Valley
(sulfur strategy)
Connecticut
(ESECA)
Costs


Fuel
Dealers
M

NA



Other
1

NA

Benefits



Attractiveness
M

NA


Orderly
Growth
M

NA


Efficient Use
of Resources
1

M

Source: Harbridge House, Inc. (1976).
        KEY
I    = Insignificant Impact
M   = Moderate Impact
S   = Significant Impact
NA = Not Applicable
-------
                               V-20
••   Increased costs to  the  commercial  sectors  range  from  0.003  to  0.008
     percent. No significant impact is expected.
                                                       I
•    The  cost of electricity to households in the  Naugatuck Valley is likely to
     increase by 2.2 percent as a result of the sulfur strategy.

Direct Benefits

•    Both absolute and  relative  reductions in damage from air  pollution are
     expected in the Naugatuck Valley.  Health benefits may be particularly great
     because of the higher  than  average  (for the  state) proportion of elderly
     persons in the  Naugatuck Valley.

Indirect Costs                     :

•    Fuel oil dealers will  bear increased  costs in storing 0.3  percent sulfur fuel in
     addition to the 0.5 percent sulfur  fuel.

Indirect Benefits

•    Naugatuck Valley residents will experience improved quality of life. There is
     potential for increased attractiveness of the towns for business locations.

•    More development will  be  accommodated  within the limits of NAAQS,
     thereby promoting orderly growth.

•    Minimal increases in energy conservation practices are expected.

Impact of ESECA

•    Four Connecticut power plants are  on FEA's list of potential candidates for
     conversion from oil to coal.

•    Major costs likely to be incurred by these plants include  costs relating to
     obtaining low sulfur coal and/or scrubbers.

•    Increased  costs of pollution  control equipment associated with conversion
     are estimated  to increase the average household's annual electricity bill by
     about 8 percent.

•    The  required air pollution  control  equipment  expenditures represent  from
     10 to.26 percent of the 1975  market for control devices.
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     APPENDIX A
THE OBERS PROJECTIONS
-------
                            THE OBERS PROJECTIONS
         The  1972 OBERS Series E economic activity projections were used as a basis for
the AQMA designation and subsequent AQMP tasks, including this study. These projections
have been  developed  by the Bureau of  Economic  Analysis of  the U.S. Department  of
Commerce  and the Economic Research Service of the U.S. Department of Agriculture. The
OBERS Series E projections at this time constitute the  most complete econometric data
analysis available for the state of Connecticut. OBERS-E  economic activity projections are
available for the state as a whole, SMSA's, and BEA economic areas from 1970 to 2020.

         Population projections cited in the 1972 OBERS Series E are derived from 1972
U.S. Bureau of the Census Series E population estimates  and a cohort fertility rate of 2.1.
These projections also assume some migration into the state following the historical pattern
developed in the 1950's and  1960's. Recent population estimates indicate that the OBERS
Series  E population projections  are high, and the  state's population has not grown as
anticipated. Thus,  current population estimates indicate that Connecticut's fertility rate is
less than the established 2.1 rate  and that some out-migration of population from the state
has occurred.

         OBERS Series E economic projections are based upon a shift-sharing technique
between the region  and the nation. National projections of employment and earnings have
been based upon the assumption  of a fixed 4  percent unemployment rate and do not take
into consideration cyclical  changes  in  the. economy. The OBERS-E  forecasts  only total
employment, projecting a 21.5 percent increase in Connecticut's total employment between
1970 and  1980.  Industry earnings are projected on a  two-digit SIC level. Increases in
earnings  are attributable  to  increases  in  employment and  productivity  (output  per
man-hour). A  2.9 percent annual rate of increase in productivity has been assumed in the
projections. Based on  forecasted  national earnings  and  shift-share analysis, the  OBERS
projects a 2.7 percent annual growth in manufacturing earnings for Connecticut.

         An in-house  document  prepared  by the  Connecticut  Department of Environ-
mental  Protection  compared  the  OBERS Series  E projections to  other  estimates  of
individual demographic and economic components, concluding that OBERS can reasonably
be considered with a ±10 percent margin of error for the year 1977, with the degree of error
likely to increase beyond that point. Without attempting to refute this carefully prepared
comparison, Harbridge House  would like to  note that in  development of basic data for this
study  there were  considerable indications  that the OBERS Series  E is skewed toward
optimistic projections, particularly over  relatively short time periods (such as 10 years). In
particular,  the deliberate ignorance of cyclical relationships within the economy does not
appear to reflect economic constraints over the period from 1975 to  1985.  It is believed,
nevertheless, that consideration of cyclical phenomena should  be appropriately tempered
with a longer term (contingency type) outlook. As a result, it is suggested that interim
updating of a reliable  data  base be used in  conjunction with,  or in place  of, long-term
statistically  derived forecasts. The sensitivity of the AQMP  procedure to the growth
assumptions utilized  indicates  that  a fairly detailed-and-current-data  base  should  be
developed.
-------
       APPENDIX B
PERMIT EXEMPTION CRITERIA
-------
                          PERMIT EXEMPTION CRITERIA
A.   Permits are not required for:

         (i)   Mobile sources.

         (ii)   Equipment  used in  a manufacturing  process involving  surface  coating
              (including,  but  not  limited to, spray and dip  painting,  roller coating,
              electrostatic depositing, or spray cleaning) and in which the total quantity of
              coating material and solvents used is less than 30 pounds in any one hour.

        (iii)   Equipment used in a manufacturing process involving metal cleaning and/or
              surface  preparation,  and  which  is  connected  to a  ventilation  system
              controlling escape  of air pollutants or contaminants  to  the workroom air,
              such manufacturing process including, but not limited  to, etching, pickling,
              or plating when the total capacity of such equipment is 1,000 gallons or less;
              or any solvent degreasing units  with a total capacity of 1,000 gallons or less.

        (iv)   Equipment  used in  a manufacturing process,  other than as set forth in
              subsections  (A) (i), (ii), (iii), (v), (vi), or (vii) herein, in which the combined
              weight of all materials introduced, excluding air and water, does not exceed
              either 2,000 pounds in any  one hour or 16,000 pounds in  any one day.

         (v)   Any liquid storage tank, reservoir, or container, used for the storage of acids,
              volatile organic compounds, solvents, dilutants or thinners, inks, colorants,
              lacquers, enamels,  varnishes, liquid resins,  and  having a  capacity less than
              40,000 gallons.

        (vi)   Fuel-burning equipment in  which the  maximum rated fuel-burning capacity
              is  less  than  five million Btu per hour, unless the  source is burning coal or
              residual oil.

        (vii)   Sources used as incinerators in dwellings containing six or  fewer family units.

       (viii)   Any other  process,  operation, equipment, or activity, except those  types
              specified in  subsection (A)  (i) through (vii) herein, which emits or causes to
              be  emitted  a  total of eight tons per year or  less of any  air pollutant or
              combination of air pollutants.

B.   Notwithstanding any provision of subsection  (A) above, permits shall be required for
     all new  stationary industrial pneumatic  solid material handling or  conveying systems
     and all industrial flares for the disposal of waste or excess process gases.
Source:  Connecticut  Department of Environmental  Protection,  Administrative  Regula-
         tions, Abatement of Air Pollution, p. D-3.
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             APPENDIX C
      SUMMARY OF DATA BASE AND
RATIONALE FOR ASSUMED MANUFACTURING
          PROJECTIONS BY SIC
-------
                   SUMMARY OF DATA BASE AND RATIONALE
             FOR ASSUMED MANUFACTURING PROJECTIONS BY SIC
A.   Introduction

         As described  in Chapter II, supplementary data were used to refine and modify
the manufacturing forecasts calculated on the basis of linear regressions. This information is
described below along  with the  limitation  which should be recognized in  its use. The
description  is followed by  SIC summary sheets indicating the rationale for  any forecast
modifications.

         •    Actual Number of Expansions (1963-1972): These data concern only new
             construction whether it takes place at an existing plant or at a new location.
             It  appears   that   the  addition  of  a warehouse  or  office  space to  a
             manufacturing  establishment is  classified as a new facility  although  no
             increase in output may result. 1

         •    Actual Number of Expansions (1973, 1974): These  data  have the same
             limitations as the  1963-1972 figure above. In addition, there may be some
             overlap between the two years as a result of facilities planned in 1973  and
             then completed in  1974.2

         •    Expansions  from  Press Releases  (1974, 1975): This must be  considered a
             nonrepresentative  sample, since  the press releases issued by  Connecticut
             Development Authority refer only to those firms which  obtained financing
             through the Authority.

         •    Location  Quotient (1972, Two-Digit SIC):  The use  and limitations  of
             location  quotients are described in detail in Appendix K. Aggregation at the
             two-digit SIC  level can  substantially distort  the  expression  of  growth
             indicated for the component parts of the industry.
                                                                »
         •    Employment  Size  Class  of Greatest Number  of Firms  (1972):^ The
             employment size class  is indicated in this category along with the  percentage
             of total  Connecticut firms (in the industry) which falls into that size class.
             Consequently, these data represent a frequency distribution, rather than an
             average firm size.
 Connecticut Department of Commerce, Statistical Survey of New Manufacturing Firms,
 1963-1972.
•}
-Connecticut Department of Commerce, Major Industrial and Corporate Office Construc-
 tion in Connecticut, 1973, 1974.
•^U.S.  Department of Commerce,  County Business Patterns,  1972. (The 1973 County Busi-
 ness  Patterns did  not  become available until December 1975 — after completion of the
 forecasts.)
-------
                                       C-2
             Phone Interviews: The criteria for selecting interviewees were based on the
             following: location quotient  ranking at the four-digit level; lists of current
             and planned construction from the Connecticut Department  of Commerce;
             recurrence of the SIC code in the permit system history; and lists of the five
             largest manufacturing employers for towns in the AQMA. Efforts to obtain a
             representative  sample of responses by size of facility and SIC breakdown
             were limited by time constraints.

             Dodge  Bulletins: 1   Limited  data  were  obtained  from  Dodge  Bulletin
             notification  of construction  plans and are included along with telephone
             interview data. Substantially greater reliance would have been placed on this
             source had time permitted.
McGraw-Hill Information Systems, Dodge Bulletins.
-------
                                      C-3


B.  Manufacturing Forecasts by SIC



                    SIC 20:  FOOD AND KINDRED PRODUCTS

Data Base

         •   Average Annual Growth Rate (Calculated)                        3.34%

         •   Calculated  Number  of  New  and  Expanded  Facilities
             (1972-1985)                                                   59   -

         •   Actual Number of Expansions (1963-1972)                        34

         •   Actual Number of Expansions (1973)                              8

         •   Actual Number of Expansions (1974)                             11

         •   Expansion Plans from Press Releases (1974-1975)                    7

         •   Location Quotient (1972, two-digit SIC)                          0.45

         •   Employment  Size  Class with  Greatest Number  of  Firms       8-19
             (1972)                                                       (24%)

         •   Phone  Interviews:  Neither of the two  large  companies
             contacted planned  any  expansion  through 1985. Both indi-
             cated excess capacity in  current operations.

Conclusion

         It is believed that the projected  number of new and expanded facilities between
1972 and  1985  may reasonably be  expected to occur in light of historical trends in the
number of new and expanded facilities which have located in Connecticut from 1963 to the
present as  well as the predominance of small firms in this industry group. Consequently, it
has been assumed that four facilities will be constructed per year from  1975 to 1985.
-------
                                       C-4


                        SIC 22: TEXTILE MILL PRODUCTS

Data Base

         •    Average Annual Growth Rate (Calculated)                        2.34%

         •    Calculated  Number  of  New  and  Expanded  Facilities
              (1972-1985)                                                     9

         •    Actual Number of Expansions (1963-1972)                         27

         •    Actual Number of Expansions (1973)                               6

         •    Actual Number of Expansions (1974)                               7

         •    Expansion Plans from Press Releases (1974-1975)                     5

         •    Location Quotient (1972, two-digit SIC)                           0.80

         •    Employment  Size  Class with Greatest Number  of Firms       20-49
              (1972)                                                        (25%)

         •    Phone Interviews: Of the three  firms contacted,  none was
              planning either short- or long-term expansion.

Conclusion

         Based solely on historical trends (that is, new and expanded facility construction
from  1963 to the present), the number of facilities projected to locate in Connecticut
between  1972 and 1985 appears low. Therefore, expansions were recalculated assuming 90
percent capacity utilization in 1972 (instead of  80 percent). This yielded an estimate of 25
new or expanded  firms over the 13-year period. Taking into account the phone interview
results and the clustering of the frequency distribution of employment size classes in the
middle range  for Connecticut industry, it  is  believed that this projection  represents a
reasonable estimate. Consequently, it has been assumed that two firms per year will locate
or expand in Connecticut from 1975 to  1985.
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                                      C-5


              SIC 23: APPAREL AND OTHER FINISHED PRODUCTS

Data Base

         •    Average Annual Growth Rate (Calculated)                        1.39%

         •    Calculated  Number  of  New  and  Expanded  Facilities
             (1972-1985)                  '                                (10)

         •    Actual Number of Expansions (1963-1972)                        42

         •    Actual Number of Expansions (1973)                              1

         •    Actual Number of Expansions (1974)                              0

         •    Expansion Plans from Press Releases (1974-1975)                    2

         •    Location Quotient (1972, two-digit SIC)                          0.55

         •    Employment  Size  Class with  Greatest Number  of  Firms        20-49
             (1972)                                                       (31%)

         •    Phone Interviews: No firms in this industry were interviewed.

Conclusion

         The reduction in the  number of establishments  calculated from  1972 to  1985
despite a positive (but low) average annual growth rate can, perhaps,  be attributed to a
higher  capacity  utilization ratio  than  the 80 percent assumed in  the majority of the
manufacturing forecasts. Using a ratio of 90 percent, 18 firms are calculated to locate  or
expand in Connecticut over  the  13-year period. Recent expansion  plans  (from 1973  to
1975) corroborate this low annual growth in the number of establishments. In the absence
of more detailed data, it has been assumed that one firm per year will locate or expand in
Connecticut from 1975 to  1985.
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                                      C-6


                    SIC 24: LUMBER AND WOOD PRODUCTS

Data Base

         ••   Average Annual Growth Rate (Calculated)                      (1.54%)

         •   Calculated  Number  of  New  and  Expanded  Facilities
             (1972-1985)                                                  neg.

         •   Actual Number of Expansions (1963-1972)                         39

         •   Actual Number of Expansions (1973)                              0

         •   Actual Number of Expansions (1974)                              2

         •   Expansion Plans from Press Releases (1974-1975)                    1

         •   Location Quotient (1972, two-digit SIC)                          0.18

         •   Employment  Size  Class with Greatest  Number of Firms         1-3
             (1972)                                                      (34%)

         •   Phone  Interviews: No firms in this industry were interviewed.

Conclusion

         A negative  annual average growth  rate was calculated for this industry. How-
ever, 39 firms were expanded  or constructed  between 1963  and  1972. In view of the
low location quotient, it appears reasonable  to assume that not more than  two firms per
year will be constructed between 1975 and 1985.
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                                      C-7


                       SIC 25: FURNITURE AND FIXTURES

Data Base

         •   Average Annual Growth Rate (Calculated)                        4.59%

         •   Calculated  Number  of  New  and  Expanded  Facilities
             (1972-1985)                                                   46

         •   Actual Number of Expansions (1963-1972)                         47

         •   Actual Number of Expansions (1973)                               7

         •   Actual Number of Expansions (1974)                               4

         •   Expansion Plans from Press Releases (1974-1975)                    1

         •   Location Quotient (1972, two-digit SIC)                          0.59

         •   Employment Size  Class with Greatest  Number  of  Firms        20-49
             (1972)                                                       (23%)

         •   Phone Interviews: No firms in this industry were interviewed.

Conclusion

         The calculated number  of new or expanded facilities  represents an average  of
about four facilities per year over the  13-year period. This appears to be reasonable, despite
the industry's relatively  high growth rate — in light  of the size distribution of firms, past
expansion and recent plans, and the low location quotient.  In the absence  of additional
data,  it has been  assumed that four  establishments per year will  locate  or expand  in
Connecticut between 1975  and  1985.
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                                       C-8


                     SIC 26:  PAPER AND ALLIED PRODUCTS

Data Base

         •    Average Annual Growth Rate (Calculated)                        4.15%

         •    Calculated  Number  of  New  and  Expanded   Facilities
              (1972-1985)                                                   35

         •    Actual Number of Expansions (1963-1972)                         21

         •    Actual Number of Expansions (1973)                               2

         •    Actual Number of Expansions (1974)                               6

         •-    Expansion Plans from Press Releases (1974-1975)  .                   4

         •    Location Quotient (1972, two-digit SIC)                          0.68

         •    Employment Size  Class  with  Greatest Number  of Firms       50-99
              (1972)                                                       (23%)

         •    Phone Interviews: No firms in this industry were interviewed.

Conclusion

         The  calculated number of new or expanded facilities  represents an average of
three facilities  per year over the next 13 years. This appears to be a reasonable estimate of
future  expansion. In the  absence of  additional  data, it  has been assumed that three
establishments  will locate or expand in Connecticut per year from 1975 to 1985.
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                                       C-9


                      SIC 27: PRINTING AND PUBLISHING

Data Base

         •   Average Annual Growth Rate (Calculated)                        2.48%

         •   Calculated   Number  of  New   and  Expanded  Facilities
             (1972-1985)                                                    59

         •   Actual Number of Expansions (1963-1972)                        201

         •   Actual Number of Expansions (1973)                              16

         •   Actual Number of Expansions (1974)                              13

         •   Expansion Plans from Press Releases (1974-1975)                    5

         •   Location Quotient (1972, two-digit SIC)                          1.06

         •   Employment Size  Class  with Greatest  Number of Firms        1-3
             (1972)                                                        31%

         •   Phone Interviews: No firms in this industry were interviewed.

Conclusion

         The large number of expansions from 1963 to 1972 as compared to the relatively
small  number  of calculated  new  or expanded facilities indicates that the  method  of
conversion from value added to number of establishments is in error for this manufacturing
group. Assuming that the capacity utilization ratio in 1972 was 90 percent (instead of 80
percent), expanded facilities would number 139. Since the distribution of 1972 establish-
ments is markedly skewed toward small facilities and the location quotient was calculated to
be greater than one, it appears reasonable that this larger number of expansions may occur.
Consequently,  it has been assumed that  11  firms  per  year will locate  or  expand in
Connecticut between 1975 and 1985.
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                                      C-10


                  SIC 28: CHEMICALS AND ALLIED PRODUCTS

Data Base

         •    Average Annual Growth Rate (Calculated)                        4.59%

         •    Calculated   Number  of   New  and  Expanded  Facilities
              (1972-1985)                                                   66

         ••    Actual Number of Expansions (1963-1972)                         45

         •    Actual Number of Expansions (1973)                              11

         •    Actual Number of Expansions (1974)                              19

         •    Expansion Plans from Press Releases (1974-1975)                     7

         •    Location Quotient (1972,  two-digit SIC)                         0.85

         •    Employment Size  Class  with  Greatest Number  of Firms       8-19
              (1972)                                                       (23%)

         •    Phone Interviews: Of  the three  large firms responding, two
              plan to expand prior to 1985.

Conclusion

         The calculated number of new or expanded facilities averages five per year over
the 13-year period. Based on the actual number of expansions between 1963 and 1972 and
the location quotient of less than  one, the calculated  number appears  to represent a
reasonable estimate. It should be noted, however, that the distribution of establishments by
employment size is skewed toward small-sized facilities  and  that recent (1973 to  1975)
indications of expansion in the industry are  higher than during the pre-1972 period. In the
absence of additional data, it has been assumed that five establishments per year will expand
or locate in Connecticut between 1975 and 1985.
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                                      C-ll


                   SIC 29:  PETROLEUM AND COAL PRODUCTS

Data Base

        •    Average Annual Growth Rate (Calculated)                        8.83%

         •    Calculated  Number  of   New  and  Expanded  Facilities
             (1972-1985)                                                    41

         •    Actual Number of Expansions (1963-1972)                          4

         •    Actual Number of Expansions (1973)                               1

         •    Actual Number of Expansions (1974)                               0

         •    Expansion Plans from Press Releases (1974-1975)                    0

         •    Location Quotient (1972,  two-digit SIC)                           . 13

         •    Employment  Size  Class  with  Greatest  Number  of Firms        8-19
             (1972)                                                       (35%)

         •    Phone Interviews: No firms in this industry were interviewed.

Conclusion

         There were only  17 firms in this industry in Connecticut in 1972, most of which
were manufacturers of paving and roofing material. The  location quotient is quite low and
only four facilities were constructed between  1963 and  1972. Consequently, it is expected
that the calculated number of new or expanded facilities, which averages three per year, is
extremely high. It has been assumed that one plant every two years goes on line between
1975 and 1985. This estimate is  considered reasonable, especially in light of this sector's
expansion trend since 1963.
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                                      C-12


           SIC 30:  RUBBER AND MISCELLANEOUS PLASTIC PRODUCTS

Data Base

         •    Average Annual Growth Rate (Calculated)                       4.59%

         •    Calculated   Number  of  New  and  Expanded  Facilities
              (1972-1985)                                                   77

         •    Actual Number of Expansions (1963-1972)                        80

         •    Actual Number of Expansions (1973)                              5

         •    Actual Number of Expansions (1974)                              8

         •    Expansion Plans from Press Releases (1974-1975)                    7

         •    Location Quotient (1972, two-digit SIC)                          1.60

         •    Employment Size  Class with  Greatest  Number of  Firms        8-19
              (1972)                                                      (23%)

         •    Phone Interviews: The single large firm  responding did not
              anticipate expansion before 1985.

Conclusion

         The projected number of expansions per year through 1985 represents a lower
rate of growth than that of the 1963 to 1972 period. This divergence indicates that the
methodology for conversion of projected value added to the number of establishments is
not appropriate for this manufacturing group. In view of the high  location quotient, it
appeared reasonable  to assume that the industry averaged 90 percent capacity utilization in
1972. Calculated  on this  basis,  a  total  of 108 firms can  be expected  to  expand in
Connecticut from  1972 to 1985.  Consequently, it was assumed that eight  firms per year
would locate or expand in Connecticut between 1975 and 1985.
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                                     C-13


                  SIC 31: LEATHER AND LEATHER PRODUCTS

Data Base

         •    Average Annual Growth Rate (Calculated)                       (0.83%)

         ••.    Calculated  Number  of  New   and  Expanded  Facilities
             (1972-1985)                                                 neg.

         •    Actual Number of Expansions (1963-1972)                         4

         •    Actual Number of Expansions (1973)                              0

         •    Actual Number of Expansions (1974)                              0

         •    Expansion Plans from Press Releases (1974-1975)                    0

         •    Location Quotient (1972, two-digit SIC)                         0.36

         •    Employment  Size  Class with Greatest  Number  of Firms       20-49
             (1972)                                                      (23%)

         •    Phone Interviews: No firms in this industry were interviewed.

Conclusion

         A  negative growth rate  was calculated. Expansion in this industry has been
minimal since 1963. It has been assumed that not more than one firm every other year is
expanded or built in Connecticut.
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                                       C-14


                  SIC 32:  STONE, CLAY, AND GLASS PRODUCTS

Data Base

         •    Average Annual Growth Rate (Calculated)                        1.47%

         •    Calculated  Number  of  New  and  Expanded  Facilities
              (1972-1985)                                                     (6)

         •    Actual Number of Expansions (1963-1972)                        29

         •    Actual Number of Expansions (1973)                               7

         •    Actual Number of Expansions (1974)                               6

         •    Expansion Plans from Press Releases (1974-1975)                    0

         •    Location Quotient (1972, two-digit SIC)                          0.73

         •    Employment  Size Class with  Greatest Number of  Firms       8-19
              (1972).                                                       (29%)

         •    Phone Interviews: No firms in this industry were interviewed.

Conclusion

         Based on 80 percent capacity utilization, the number of firms in this industry was
calculated to decrease between 1972  and 1985 despite  a positive (although low) growth
rate. However,  the actual number of expansions  of the past  11  years indicates that the
number of firms could be expected to increase gradually over the next 10 years. Assuming a
90 percent capacity utilization rate in  1972, 16 new firms could be expected to come on
line over the next 13 years, or an average of one firm per year. Again, this figure seems low,
particularly in light of the relatively small size of establishments in the industry. Overall, it is
believed  that the  growth rate, which  was  calculated on the basis of value added in the
absence of a more  appropriate  indicator,  does not reasonably reflect significant future
growth in the industry. It has been assumed that three establishments per year will locate or
expand in Connecticut  betwen 1975 and 1978, based on  the average  between 1963 and
1972.
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                                      C-15


                     SIC 33: PRIMARY METAL INDUSTRIES

Data Base

         •    Average Annual Growth Rate (Calculated)                        3.73%

         •    Calculated  Number  of  New  and  Expanded  Facilities
             (1972-1985)                                                    59

         •    Actual Number of Expansions (1963-1972)                         32

         •    Actual Number of Expansions (1973)                               7

         •    Actual Number of Expansions (1974)                              12

         •    Expansion Plans from Press Releases (1974-1975)                    5

         •    Location Quotient (1972, two-digit SIC)                          1.12

         •    Employment   Size  Class with  Greatest  Number of Firms       20-49
             (1972)                                                       (20%)

         •    Phone Interviews: Of the eight firms responding, two planned
             to expand between 1975 and  1978, and two between 1978
             and  1985. One firm,  however,  specifically  indicated  that
             Connecticut was not attractive  for expansion because of high
             labor costs, high taxes, and a high unemployment compensa-
             tion rate. Four of the  firms (all  large ones)  noted that the
             metal  business is  currently  in a depressed state and  that
             efforts were geared toward regaining profitability.

Conclusion

         The calculated number  of new  or expanded  firms appears to  be somewhat
optimistic in light of the interview responses and  the growth in establishments from 1963 to
1972. However, no reasonable alternative pattern for future expansion and construction can
be ascertained from available  data. Consequently, it has been assumed that an average of
four establishments per year will come on line between 1975 and 1985.
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                                       C-16


                     SIC 34:  FABRICATED METAL PRODUCTS

Data Base

         •    Average Annual Growth Rate (Calculated)                        3.73%

         •    Calculated  Number  of  New  and   Expanded  Facilities
              (1972-1985)                                                   205

         •    Actual Number of Expansions (1963-1972)                        232

         •    Actual Number of Expansions (1973)                              44

         •    Actual Number of Expansions (1974)                              33

         •    Expansion Plans from Press Releases (1974-1975)                    21

         •    Location Quotient (1972, two-digit SIC)                          1.86

         •    Employment  Size  Class with  Greatest Number  of Firms        8-19
              (1972)                                                        (26%)

         •    Phone Interviews: Of the seven relatively large firms respond-
              ing, two indicated expansion plans between 1975 and 1985.
              However,  three firms expressed uncertainty about expansion
              in  Connecticut  even  if the  economy takes a  turn  for the
              better. They cited taxes, labor rates, and market saturation as
              reasons.

Conclusion

         The calculated number of new and expanded facilities appears low in light of the
high location quotient, past growth trends,  and the  relatively small size of most firms.
Consequently, it has been assumed that a 90 percent capacity utilization rate would be more
representative of industry operating characteristics during 1972. The new calculation yields
an average of 18 establishments per year (total of 240 over 13 years), which is considered a
reasonable estimate of facility increases  from  1975 to  1978. In light of the telephone
interview responses, it is  likely that small  firms will compose  the major portion of these
expansions.
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                                      C-17


                   SIC 35: MACHINERY, EXCEPT ELECTRICAL

Data Base

         ••   Average Annual Growth Rate (Calculated)                        3.73%

         ••   Calculated  Number   of   New  and  Expanded  Facilities
             (1972-1985)                                                   334

         •   Actual Number of Expansions (1963-1972)                        422

         •   Actual Number of Expansions (1973)                              15

         •   Actual Number of Expansions (1974)                              18

         •   Expansion Plans from Press Releases (1974-1975)                    14

         •   Location Quotient (1972, two-digit SIC)                           1.82

         •   Employment  Size  Class with  Greatest Number  of Firms        8-19
             (1972)                                                       (27%)

         •   Phone Interviews:  Of the seven  firms responding,  three
             anticipate expansion  between  1978 and 1985. Most of the
             other respondents  cited current economic conditions and
             Connecticut's tax structure  as deterrents to expansion.

Conclusion

         The calculated number  of new  and expanded firms averages about 26 establish-
ments per year.  Although this is significantly lower than the  1963 to  1972 average, it does
represent an increase over the number of establishments expanding during the 1973 to 1975
period. Because  of the economic  downturn in the last few years and the indications that
health  may  be  slowly returning  to  the  national  economy, the calculated increases  are
expected to be representative of future growth in this capital investment-oriented industry.
Consequently, it has been assumed  that 26 new or expanded establishments per year will
come on line between 1975 and 1985.
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                                      C-18


                       SIC 36: ELECTRICAL MACHINERY

Data Base

         ••   Average Annual Growth Rate (Calculated)                       3.73%

         •   Calculated  Number  of  New  and  Expanded   Facilities
             (1972-1985)                                                  104

         •   Actual Number of Expansions (1963-1972)                        169

         •   Actual Number of Expansions (1973)                              10

         •   Actual Number of Expansions (1974)                              13

         •   Expansion Plans from Press Releases (1974-1975)                    5

         •   Location Quotient (1972, two-digit SIC)                          1.36

         •   Employment  Size  Class with  Greatest  Number  of Firms       20-49
             (1972)                                                      (19%)

         •   Phone  Interviews: Of the  eight large firms responding, only
             one anticipated expansion prior to 1985.

Conclusion

         The calculated number of new and expanded establishments represents an average
of eight  per year for the  13-year  period.  This  estimate  appears to be  reasonable.
Consequently, it has  been assumed that  eight establishments  will come on line per year
between 1975 and 1985.
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                                     C-19


                    SIC 37: TRANSPORTATION EQUIPMENT

Data Base

         •    Average Annual Growth Rate (Calculated)                        3.31%

         •    Calculated  Number  of  New  and  Expanded  Facilities
             (1972-1985)                                                   29

         •    Actual Number of Expansions (1963-1972)                         69

         «    Actual Number of Expansions (1973)                               3

         •    Actual Number of Expansions (1974)                               4

         •    Expansion Plans from Press Releases (1974-1975)                    4

         •    Location  Quotient (1972, two-digit SIC)                          2.49

         •    Employment  Size  Class with Greatest  Number of Firms        8-19
             (1972)                                                      (19%)

         •    Phone Interviews: Of the  five large  firms responding, none
             had plans for expansion prior to 1985, although one firm had
             a S10 million plant under construction.

Conclusion

         Although the calculated number of new or expanded firms represents a significant
decrease from  the  1963 to  1972 level of facility expansion,  the estimate is considered
reasonable in light of the post-Vietnam economy and the responses of firms interviewed.
Consequently, an average of two new or  expanded  facilities  per year has been assumed to
come on line between 1975 and 1985.
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                                      C-20


                SIC 38: INSTRUMENTS AND RELATED PRODUCTS

Data Base

         •   Average Annual Growth Rate (Calculated)                       3.38%

         •   Calculated   Number   of   New  and  Expanded  Facilities
             (1972-1985)                                                   34

         •   Actual Number of Expansions (1963-1972)                        25

         •   Actual Number of Expansions (1973)                              6

         •   Actual Number of Expansions (1974)     '                        11

         •   Expansion Plans from Press Releases (1974-1975)                    8

         •   Location Quotient (1972, two-digit SIC)                          2.63

         •   Employment Size  Class with  Greatest  Number of  Firms       20-49
             (1972)                                                      (19%)

         •   Phone Interviews: Of  the three large firms responding, only
             one anticipates expansion (between 1978  and 1985).

Conclusion

         The calculated number of new and expanded facilities represents about three
establishments per year over the 13-year period. This estimate is considered to be somewhat
low in light of the high location quotient and the active solicitation of firms in this industry
by at least one economic development agency. It has been assumed that four establishments
per year between 1975 and 1985 is a more representative estimate.
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                                     C-21


            SIC 39: MISCELLANEOUS MANUFACTURING INDUSTRIES

Data Base

         •    Average Annual Growth Rate (Calculated)                       4.59%

         •    Calculated  Number  of New  and  Expanded  Facilities
             (1972-1985)                                                 93

         •    Actual Number of Expansions (1963-1972)                       98

         •    Actual Number of Expansions (1973)                              6

         •    Actual Number of Expansions (1974)                              6

         •    Expansion Plans from Press Releases (1974-1975)                    2

         •    Location Quotient (1972, two-digit SIC)                          1.83

         •    Employment  Size  Class  with  Greatest Number of Firms     1-3 & 8-19
             (1972)                                                   (14% each)

         •    Phone Interviews: Of the three large firms responding, none
             had plans for expansion through 1985.

Conclusion

         The calculated number of new and expanded establishments is considered to be a
reasonable estimate of future growth in the number of firms. Consequently, it has  been
assumed that an average of seven facilities come on line per year between 1975 and 1985.
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             APPENDIX D
 HOSPITAL, MENTAL HEALTH FACILITY, AND
MENTAL RETARDATION FACILITY FORECASTS
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                   HOSPITAL, MENTAL HEALTH FACILITY, AND
                  MENTAL RETARDATION FACILITY FORECASTS
          As indicated in Chapter II, telephone interviews indicated that no source growth
in hospitals, mental health facilities, or mental retardation facilities would occur during the
study period. Background data providing the basis for this conclusion are provided here.

 I.   Hospitals

          Connecticut  currently  has  a  surplus  of hospital  beds,  according  to  state
Department  of  Health sources. Further, two  basic  health care trends are  expected  to
contribute to a reduced need  for hospital beds in the future. First, doctors are tending to
increasingly rely on  out-patient care rather than inpatient confinement. Second, increased
patient turnover rates have caused greater utilization of existing bed capacity. Consequently,
construction of  additional hospital  capacity is  highly unlikely during the  period 1975 to
1985. This conclusion is  corroborated by  the  Chief  of Health  Facility Construction,
Department of Health. 1  Replacement construction over the  next 10 years is expected to
occur in  roughly the same  areas  where current facilities  exist, neither increasing  or
decreasing the size  of individual facilities.

II.   Mental Health Facilities

          Projected growth of mental health care facilities in  the  state from 1975 to 1985
may differ substantially in character from traditional growth  patterns. Future expansion is
expected  to  be non-space related. Space needs will, in fact, probably be  reduced.2

          Currently,  85 percent of  the  total volume served by  state mental health care
facilities is represented by  hospital in-patient care.  If  present  plans are  met, by  1978
in-patient and out-patient care  would be equally divided.

          Mental health care  replacement facilities  will reflect  the   current  trend  in
treatment  away from  patient confinement toward assimilation into  society.  As a result,
expected construction  of new  facilities is minimal. Maximum use  of existing structures will
be made as follows:

          (i)  Local hospitals  will provide partial (less than 24-hour) hospitalization.

         (ii)  Church basements will provide less intensive day treatment programs.
^Thomas  Redding, Chief  of Health Facility  Construction,  Hospital  and Medical Care
 Division, Department of Health, State of Connecticut. Telephone interview 21 November
 1975.
2Dr. Mark,  Department of Mental  Health, State of Connecticut. Telephone  interviews,
 November  1975.
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                                          D-2
         (iii)   Existing  structures will  provide halfway  houses where patients  will ex-
               perience  sheltered living and work  environments.

         (iv)   24-hour emergency phone services will be implemented locally.

          Presently,  the state provides mental health care  to 2  percent  of the  total
 population. However, it is anticipated that the  trends toward diversification and dispersion
 of services  will result in care being extended to 6 to  7 percent of the  total population by
 1985. In summary,  the long-term consequence of these  mental health care trends  will
 probably yield an overall reduction of space, minimal construction, and increased efficiency
 of service.

III.   Mental Retardation Facilities

          Telephone   interviews   and  correspondence  with officials at the  Connecticut
 Department of Mental Retardation indicate that no new construction of either public or
 private mental retardation facilities will take place through 1985.1  At present, there is a
 regional center under construction in Norwalk. In  addition, 16  new cottages  in Mansfield
 Depot are being constructed to replace antiquated  facilities. However, ground has already
 been broken on both of these projects.

          Growth in  facility requirements is expected to  be  accommodated  through the
 purchase or lease of community-based residences. It  is anticipated  that 25 such facilities
 may  be  opened  over  the next 10 years, with a total bed capacity of approximately 300.2
 This  type of expansion, however, is not  relevant  to evaluation of the strategies under
 consideration. Consequently, no growth in  mental retardation facilities has been assumed.
 1 Arthur, L. DuBrow,  Director  of  Administrative Services, Department of Mental Retar-
  dation, State of Connecticut, letter dated 28 October 1975.
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      APPENDIX E
EDUCATIONAL FACILITIES
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                            EDUCATIONAL FACILITIES
         The  short-term forecast in Chapter II was  based  on the planned public school
construction projects shown in Exhibit E-l.

         The  long-term  forecast of school  facilities was based on  the indices  of school
needs, as follows: 1

                Index                              Population Age 0-5
                      Lower Schools =              Population Age 6-1
                Index                              Population Age 6-11
                      Upper Schools =              D ......   7   ,0 ,-
                       rr                         Population Age 12-17
Based on some simplifying assumptions,  the index measures the degree  to which changes
will occur in the demand for school facilities over the  next five to six years. To the extent
that  the younger age  group is larger than the older, future  need for school facilities will
increase. Similarly, if the younger group is smaller than the older, school facility needs will
decrease. A measure of .85 or lower on the index is an indication that classroom space will
be freed over the next five to six years, while a measure of 1.20 or higher indicates the need
for additional classroom space.2

         The required assumptions are:

         ••    That mortality rates among the population under age 18 remain constant.

         •    That the net migration rates of the population under age  18 remain constant.

         •    That the "dropout"  rate  remains low  among those students who are not
              compelled by law to attend school (16 and 17 years old).

         •    That during  the  time periods under  consideration, school facilities and
              school policies remain unchanged.

In utilizing the index, regional  differences in population age groups were not taken into
account because the data required for such specificity were not available. Consequently, it is
implicitly  assumed  that the age  distribution of the  Connecticut  population is  uniform
throughout the  regions.
lHadden, Kenneth; William Groff; Rosemary  Campiformio; and Lakshmi Murty, School
 Enrollment in Connecticut:  Past  Trends and Future Prospects, Bulletin 427, College of
 Agriculture and Natural Resources, the University of Connecticut, Storrs, March 1974.
2/6/rf.
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                                                          EXHIBIT E-1
                                          SELECTED PUBLIC SCHOOL PROJECTS*

Town
Bridgeport





Easton
Ellington



Fairfield




Wolcott
She 1 ton
Avon
New Haven

Level
Elem.
Elem.
Elem.
Elem.
Elem.
Elem.
Middle
H.S.
J.H.S.
Elem.
Elem.
J.-S.H.S.
Elem.
Elem.
Elem.
Elem.
H.S.
Elem.
Elem.
Middle

Type
New
New
New
New
New
New
Ext!-Alt.
Ext.-Alt.
Ext.
Ext.
Ext.
Ext.-Alt.
Ext.
Ext.
Ext.
Ext.
Ext.-Alt.
Ext.
Ext.
New
Cost
(millions $)
6
6
6
6
6
6
N.A.
2.9
0.7
0.8
0.2
3.8
0.6
0.7
0.6
0.6
5.8
0.1
0.4
8.4
                                                                                           Description
                                                                                           Additional core facilities.

                                                                                           Alleviation of overcrowding.


                                                                                           Satisfaction of long-term need.

                                                                                           Libraries, gymnasiums, cafeterias.
                                                                                           Satisfaction of future needs of community.


                                                                                           Alleviation of overcrowding.

                                                                                           Portable structures; alleviation of overcrowding.

                                                                                           Gymnasium to meet present needs.

                                                                                           Part of New Haven middle school concept.
m
*New facilities, extensions (Ext.) and extension-alterations (Ext.-Alt.) within the AQMA selected from Project Resume, Connecticut School Building
 Unit, September 1975.
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EXHIBIT E-1 (Cont'd)
Town
Hartford
Darien
Maryborough
Norwalk
Ridgefield
Tolland
Waterbury
Wethersfield
Windsor
West Hartford
Level

J.H.S.
Elem.
Elem.
Elem.
Elem.
Elem.
Elem.
Middle
H.S.
H.S.
Middle & H.S.
Elem.
H.S.
J.H.S.
Elem.
Elem.
Elem.
H.S.
H.S.
Type
New
Ext.-Alt.
Ext.-Alt.
Ext.-Alt.
Ext. Alt.
Ext.-Alt.
Ext.-Alt.
New
Ext.-Alt.
Ext.
Ext.
New
Ext.-Alt.
Ext.
Ext.-Alt.
Ext.-Alt.
Ext.-Alt.
Ext.-Alt.
Ext.-Alt.
Ext.-Alt.
Cost
(millions $)
3.2
1.4
0.6
0.4
0.3
0.3
0.1
3.0
1.8
0.1
0.1
22.8
2.1
0.9
0.5
2.5
1.3
1.3
1.3
1.3
                                       Description

                                       Part of Hartford Redevelopment Area; commu-
                                       nity educational facilities scattered throughout.
                                       Consistent with code and growing need.
                                       Core facilities: labs, classrooms, music and art rooms.

                                       Power mechanisms building.

                                       Music facilities.




                                       Demolition of one wing; addition to existing wing.

                                       Industrial arts and office facilities.

                                       Replacement of existing structure.


                                       Media center and  additional core facilities.

                                       Swimming pool.
m
OJ
-------
                                        E-4
         The calculated indices of school needs are shown in Exhibit E-2. According to the
criteria previously established, it may be concluded that no additions to school capacity are
required through  1985.  There may, however, be  some replacement construction. Although
such construction would be subject to permit approval, the extent of such activity could not
be assessed  within  the  scope of this study. Moreover, the net change in emissions from
replacement construction would be negligible. For this analysis, then,  it has been assumed
that no new school construction is undertaken from 1978 through 1985.

         As noted  in Chapter II no forecast was made of growth in private and post-high
school educational facilities. A list of the existing  schools is shown in Exhibit E-3  in order to
give an indication  of the extent of the omission.
-------
                                  EXHIBIT E-2
                           INDICES OF SCHOOL NEED
Index for:
Based on Data for:
Upper School
Lower School
1975-1976
1970
1.04
.86
1980-1981
1975
.89
.82
1985-1986
1980
.82
.71
                                                                                                       m
Source:   Harbridge House, Inc. Indices for 1975-1976 from School Enrollment in Connect-
         icut: Past Trends and Future Prospects.
-------
                            E-6
                        EXHIBIT E-3
               PRIVATE AND POST-HIGH SCHOOL
         EDUCATIONAL FACILITIES IN CONNECTICUT
                            1975
                                                     Number of
Type of School                                         Schools

Elementary and Middle                                    200

Secondary and Preparatory                                  88

Post-Secondary                                           59

Vocational Training (Secondary Level)                        16

Technical Colleges                                           4

Colleges and Universities:

    - Public                                             22

    - Private                                            25
Source:   Connecticut Department of Commerce. Connecticut Educa-
         tional Systems, 1975.
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      APPENDIX F
RESOURCE RECOVERY PLAN
-------
                           RESOURCE RECOVERY PLAN
         There are currently 22 municipal incinerators operating in Connecticut. Several of
them  appear  to  be  out  of compliance  with air  quality  regulations,  and substantial
expenditures   will be  required  to  bring  them  into  compliance.  In  addition,  several
municipalities  use landfills to dispose of solid wastes. Many of these landfills represent water
quality hazards, and land available for extension and upgrading of landfills is quite limited in
certain areas of the state.

         To  implement  a statewide  plan  for managing  solid  waste,  Connecticut has
organized a Resource Recovery  Authority. A solid waste management plan,  developed in
1973, has been established  to maximize resource recovery from solid waste, to  minimize
adverse  environmental  impacts, and  to provide maximum benefits at least user  cost. The
plan calls for construction of 10 plants, using advanced methods of resource recovery from
solid  wastes.  These  plants will  be capable of processing all  wastes  except hazardous
chemicals and  demolition wastes.

         It is estimated that by 1985 or 1986, the system will be processing approximately
84 percent of  the state's waste from 133 of the 169 towns. The remaining 36 towns, which
are  mainly  in the  lightly populated northeast, northwest, and estuary regions generally, are
expected to join  the system during  the 1986 to 1994  period using the existing resource
recovery plants.  By 1994, the  entire state  is expected to  be participating in resource
recovery.

         The  relative cost advantages of such widespread participation are documented in
the Plan Summary. 1  Installation of a  new  municipal incinerator  meeting air  quality
standards is estimated  to  cost about S17  to  S25 per ton,  and new  properly engineered
landfills cost about S5  to  S7 per ton. The estimated net total costs of  the new Resource
Recovery Plan will be about S10 per ton, with the actual cost varying somewhat by region.
When the municipalities are confronted with  the extremely  high cost of installing a new
municipal incinerator or of upgrading their present facility to meet air quality standards, it
is expected that they will choose to participate in the less costly Resource Recovery Plan.

         The  proposed schedule for plant construction  is shown in Exhibit F-l. The years
indicated on the  chart as the  earliest  dates  on line  are under reassement.  Currently,  it
appears that plans are six  months to a year behind schedule.2 However,  it is expected that
the municipalities will  be able  to extend the use of their present disposal facilities during
this delay.3 It is anticipated that as the Plan  progresses, changes may be  made in  facility
1/4  Proposed Plan for Solid Waste Management for Connecticut — Summary. Prepared by
 General Electric Corporate Research and  Development, and  Connecticut Department of
 Environmental Protection, 1973.
2Richard Chase, President, Resource Recovery Authority, telephone interview 25 November
 1975.
3/fe/d.
-------
                                  F-2
                              EXHIBIT F-1
                     CONSTRUCTION SCHEDULE FOR
                      RESOURCE RECOVERY PLANTS
Location
Greater Bridgeport
New Haven Area
Hartford Area
New Britain-Berlin
Southwestern Region
Montville*
Waterbury
Valley Region
Danbury
East Windsor
Earliest Date
on Line
Mid 1976
1977
1978
Mid 1979
to 1980
1980
1981
1981
1982
1983
1984
Type of
Plant
Dry Fuel
Gas Pyrolysis
Oil Pyrolysis
Dry Fuel or
Gas Pyroiysis
Gas Pyrolysis
or Dry Fuel
Pyrolysis
Pyrolysis
Dry Fuel or
Pyrolysis
Pyrolysis
Pyrolysis
1985 Tonnage
(tons/day)
1,814
1,694
2,185
1,915
1,821
1,325
1,621
785
953
1,806
*Montviile plant is not in the AQMA.

Source: A Proposed Plan for Solid Waste Management for Connecticut.
-------
                                        F-3
siting and scheduling.  For example, a few of the 10 orginally  planned plants  may be
combined, resulting in  construction of only seven plants. Depending on how  the system
functions in operation  and the level of demand placed on individual facilities, the Greater
Bridgeport and Southwestern plants may be combined and the New Haven, Hartford, and
New Britain facilities may be integrated into one structure.!

         In  order  to  provide a  check on individual  and  combined plant  capacities,
Harbridge  House estimated solid waste generation for each of the 133 towns in  the state
which are expected to  be  participating in the Resource Recovery System by 1980 and by
1985. The projections were based upon DEP estimates of waste per capita per day  for each
town and disaggregation of the 1980  and 1985  population projections by town. It was
assumed  that  the  1973 town population,  as  a proportion of Regional Planning Agency
population, would remain  constant. The DEP waste estimates represent the amount of solid
waste ultimately disposed  of at municipal  facilities,  including the following  categories:
residential, commercial, non-problem industrial, bulky combustible, bulky non-combustible,
and  non-urban renewal demolition wastes.  The total solid waste  to be  processed at each
plant was a summation of the  wastes  of the towns  serviced by the respective resource
recovery  plants.

         These calculations indicated that more than sufficient capacity would be available
at each of the 10 planned regional  plants.  However, it appeared that combining the plants
into seven facilities instead of 10  would require  greater  than the  1,800 tons  per day of
planned capacity at the  combined plants.
\Ibid., 11 November, 1975.
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      APPENDIX G
PLANNED SEWAGE SLUDGE
 INCINERATOR CAPACITY
-------
                     PLANNED SEWAGE SLUDGE INCINERATOR CAPACITY
Start-Up
  Date

  1976

  1976

  1976

  1976

  1977

  1978
Plant/Location

New Haven Boulevard

NewMilford**

Windsor Locks

Middletown

Vernon

New Haven East Shore
 Start-Up
Capacity*

 78,800

  N.A.

  N.A.

  N.A.

  N.A.

  N.A.
  Final
Capacity  (Year)

226.000  (2010)

  17,100  (1996)

  N.A.   (1996)

  44,000  (1996)

  65,350  (1997)

308,500  (2010)
   *Capacity in terms of equivalent population served.
 **Notin AQMA.

 N.A. =  Not available.

 Note:  These  facilities were used as the basis of the DEP emission projections.

 Source:   Air  Compliance Section, Department of Environmental  Protection. (Based  on estimate received
          from Water Compliance.)
-------
         APPENDIX H
DISCOUNTING TO PRESENT VALUE
-------
                        DISCOUNTING TO PRESENT VALUE
A.   Background

         In some cases the interest rate used in discounting dollars to present value can
have substantial effect on the valuation of net benefits or costs. 1 The interest rates used in
this  analysis  were based on  interviews with banking  officials  in which information  was
requested regarding the long-term rate for Connecticut  bonds (public discounting) and the
current  prime lending rate  (private sector).2 The rationale for using these interest rates in
discounting was based on a  pragmatic view of the role of present  value, assuming that such a
calculation should consider  rates for loans should they be required.

         Alternatively,  the Office of Management  and Budget (OMB)  requests that  any
study done for them include discounting at 10 percent (although other rates may also be
used). This rate,  according to a source  at OMB,3  theoretically represents the real rate of
return earned in the private sector and is supposed to reflect opportunity cost. As such, it is
contended the rate does not fluctuate over time.

         No attempt has  been made to reconcile  these alternate views of discounting.
Instead, a sample problem illustrative of the use of two alternative rates (7 percent and 10
percent) is shown below.4

B.   Example of Present Value Calculations

         Suppose  the  local planning agency  of Anytown,  U.S.A.,  is comparing  two
different air  quality maintenance strategies. The  time period  will be  20 years,  and the
planners have decided to consider the possibilities of 7 percent and 10 percent interest. All
costs are assumed to occur on 31  December of the year in which they are incurred. (If a cost
will occur in  January or February, the Anytown planners assume that it will have occurred
the preceding year.) The data for the alternatives are:
iNote  that in this study the net impact cannot be evaluated solely on a quantitative basis
 because of the nature of certain costs and benefits.
2for the public sector, a 6 percent rate was used based on telephone interviews 1 December
 1975  with municipal bond officers. First National Bank of Boston estimated long-term rate
 for Connecticut  bonds at between 5.0 and 5.5 percent, while First National City Bank of
 New  York estimated  the rate at between 6.0 and 7.0 percent.  For the private sector, a
 prime rate of 7.25 percent  was estimated  by  the Commercial  Loan Department, First
 National Bank of Boston.
3Telephone interview with Mr. Jerry Shipley, 4 March 1976.
4EPA  Guidelines for Air Quality Maintenance  Planning  and Analysis,  Volume  2: Plan
 Preparation (EPA-450/4-74-002), July 1974.
-------
                                           H-2
          Alternative I

               Capital Costs:                 SI million in years 1, 5, 20

               Operating Costs:              S10,000 per year

          Alternative II

               Capital Costs:                 SO.5 million in year 1
                                             1.0 million in year 10
                                             2.0 million in year 20

               Operating Costs:              S50,000 per year

          The  total  undiscounted  costs  for the alternatives are  S3.2  million and S4.5
million, respectively. However, the present value  of these costs is shown in Exhibit H-l. At
an  interest rate of  7 percent,  there is  little economic advantage in either  alternative.
However, at a rate of 10 percent, Alternative II is more acceptable.
-------
           APPENDIX I
POLLUTION CONTROL COST ESTIMATES
-------
                     POLLUTION CONTROL COST ESTIMATES
A.   Background and Approach

         Several  problems were  encountered in the effort to obtain approximations of
control  costs attributable  to  permit  program implementation. The first difficulty resulted
from  the  level of source  aggregation - both by size of facility and  by  SIC - for which
estimates were required. Within a two-digit SIC group, the variation among processes and
even  products is  considerable. Consequently, emissions — and thus the level and type of
control  required - can also vary significantly. The size of each facility similarly affects the
components of a  control  cost estimate. Moreover increases in product throughput (as an
indication of size) are not directly related to increases in abatement costs; rather, it is the
level of gas throughput which serves  as the size criterion to which abatement costs are (or
should be) pegged.

         Another problem in the pollution control estimates involved determination of the
current  level of control implied  by  BACT  as well as consideration of future changes in
BACT.  For  some establishments,  for example, BACT may require  a change in production
methods, rather than the  application of end-of-pipe control equipment (see Appendix 0).
Moreover, BACT  may change over the study period such that the permit related-control
costs could increase or even decrease.

         In addition,  there was  a problem in determining the reliability and accuracy of
data.  Published studies regarding  pollution control  costs often fail to enumerate relevant
assumptions such  as interest rates used in annualized cost figures; some, in fact, do not even
give  the year  for  which data were representative.  Often,  costs attributable  to retrofitting
versus new installations could not be discerned. Compounding the problem was the nearly
universal reticence of pollution control manufacturers to  quote equipment and/or installa-
tion  prices. In fact,  sources considered most  reliable  in  the search for  representative
pollution control costs, stressed the necessity of a case-by-case evaluation.

         The raw data developed from several sources are shown in Section B, below. As is
evident  there  were not sufficient data to estimate average or overall  costs on a statistical
basis. However, in view of the above limitations, the usefulness of a statistical estimate is
questionable.  Accordingly, a rough  factoring out process was initiated, using the permit
history  to indicate the distribution of the types of control problems.  For example, in the
commercial  sector,  83 percent of the retail trade  establishments  applied  for incinerator
permits in the past;  thus, it  was  assumed that  this same percentage of retail trade permit
applicants in  the future  would  need control equipment  for incinerators.  The remaining
applicants (17 percent) were assumed  to incur control costs for fuel-burning equipment.

         A reasonable breakdown of type  of  permit applied for  could  not be obtained
within the  manufacturing  sector.  Consequently, a control  cost estimate was made directly
from  the raw data. Examination of the data and consideration of the lows and highs served
as the procedure.                                                      — •

         For the sources subject  to  New  Source  Performance  Standards (NSPS)  (see
Exhibit 1-1),  it was  assumed that  the  expenditures required for compliance  with the
nationwide program  could not be attributed to permit  program implementation by the
-------
                                                       1-2
                                                  EXHIBIT 1-1
           NEW SOURCE PERFORMANCE STANDARDS:  PROMULGATED AND PROPOSED
       Industry

Steam Generators



Municipal Incinerators
            Affected Facilities

Fossil-fuel fired, steam-generating units with
a capacity greater than 250 mm Btu per hour
heat input.

Municipal incinerators of  capacity greater
than 50 tons per day.
    Pollutants

Particulates
Sulfur Dioxide
Nitrogen Oxides

Particulates
        Date

Promulgated
23 December 1971
Promulgated
23 December 1971
Portland Cement Plants
Nitric Acid Plants
Sulfuric Acid Plants
Asphalt Concrete Plants
Petroleum Refineries
Storage Vessels for
Petroleum Liquids

Secondary Lead Smelters
and Refineries
Secondary Brass or
Bronze Ingot Produc-
tion Plants

Iron and Steel Plants
Sewage Treatment Plants
Kilns, clinker coolers, raw mill system, finish
mill  system,  raw  mill dryer,  raw material
storage, finished  product storage, conveyor
transfer points, bagging and bulk loading and
unloading systems.

"Weak  nitric acid"  (30 to 70  percent  in
strength) production facilities.

Contact-process  sulfuric acid  and  oleum
facilities.

Dryers; hot  aggregate elevators; screening
equipment; hot aggregate storage equipment;
hot aggregate weighing equipment; asphalt
concrete mixing  equipment;  mineral filler
loading,  transfer,  and  storage equipment;
loading, transfer, and storage equipment that
handles dust  collected by emission control
system.

Fluid  catalytic  cracking unit  catalyst  re-
generator.

Fluid  catalytic  cracking unit  incinerator-
waste heat boiler.

Fuel gas combustion device.

Storage vessels that have capacities )> 40,000
gal.

Blast  (cupola) and reverberatory furnaces,
pot furnaces of  more than 550 Ib. charging
capacity.

Reverberatory and electric furnaces ( )>2205
pounds production capacity), blast (continu-
ous) furnaces (^>550 Ibs. capacity).

Basic oxygen process furnaces.
Incinerators used to burn sludge generated in
the plant.
Particulates
Nitrogen Oxides
Sulfur Dioxide
Acid Mist

Particulates
Particulates and
Carbon Monoxide

Particulates
Sulfur Dioxide

Hydrocarbons


Particulates



Particulates



Particulates


Particulates
Promulgated
23 December 1971
Promulgated
23 December 1971

Promulgated
23 December 1971

Promulgated
8 May 1974
Promulgated
8 May 1974
Promulgated
8 May 1974

Promulgated
8 May 1974
Promulgated
8 May 1974
Promulgated
8 May 1974

Promulgated
8 May 1974
-------
                                                        1-3
                                              EXHIBIT 1-1 (Cont'd)
       Industry

Primary Copper Smelters




Primary Zinc Smelters




Primary Lead Smelters
                                       Affected Facilities

                           Dryer,  roaster,  smelting  furnace,  copper
                           converter.
                           Roasters, sintering machine.
                           Sintering machine discharge  end, blast fur-
                           nace, dross reverberatory furnace.

                           Sintering machine, electric smelting furnace,
                           converter.

                           Electric  arc  furnaces  and   dust-handling
                           equipment.
                           Electric submerged arc furnaces which  pro-
                           duce  silicon metal, ferrosilicon, calcium sili-
                           con,   silicomanganese  zirconium,   ferro-
                           chrome  silicon,  silvery  iron, high-carbon
                           ferrochrome, charge chrome, standard ferro-
                           manganese,   silicomanganese,   ferroman-
                           ganese-silicon, or calcium carbide; and dust-
                           handling equipment.

Phosphate Fertilizer Industry

   Wet-Process Phosphoric   Reactors, filters,  evaporators, and hotwells.
   Acid Plants
Steel Plants:  Electric
Arc Furnaces
Ferroalloy Production
Facilities
                           Evaporators, hotwells, acid sumps, and cool-
                           ing tanks.

                           Reactors,  granulators,   dryers,  coolers,
                           screens, and mills.

                           Mixers, curing belts, reactors, granulators,
                           dryers,  coolers, screens, mills, and  storage
                           facilities.

   Granular Triple Super-    Storage or curing piles, conveyors, elevators,
   phosphate Storage        screens, and mills.
   Facilities
   Superphosphoric Acid
   Plants

   Diammonium
   Phosphate Plants

   Triple Super-
   Phosphate Plants
Primary Aluminum Plants
Coal Preparation
Plants
                           Potrooms,  anode bake  plants in reduction
                           plant.

                           Thermal  dryers,  pneumatic  coal-cleaning
                           equipment,  coal  processing and  conveying
                           equipment,   screening  equipment,  coal
                           storage  and coal transfer points,  and coal
                           loading facilities.
    Pollutants

Particulates
Carbon Monoxide
Particulates
Sulfur Dioxide
Particulates


Sulfur Dioxide


Particulates
Particulates
Carbon Monoxide
Fluorides


Fluorides


Fluorides


Fluorides



Fluorides
Particulates and
Fluorides

Particulates
       Date

Proposed
16 October 1975
Promulgated
January 15 1976

Proposed
16 October 1974
Promulgated
15 January 1976

Proposed
16 October 1974
Promulgated
15 January 1976
Proposed
21 October 1974
Promulgated
23 September 1974

Proposed
21 October 1974
                                                                                               Proposed
                                                                                               22 October 1974
Proposed
23 October 1974

Proposed
24 October 1974
-------
                                         1-4
Connecticut DEP. Upon determination  that BACT required expenditures over and above
NSPS, however, the incremental costs were attributed to the permit program. In the case of
electric utilities, installation of flue gas desulfurization equipment would be required under
BACT,  but not NSPS.l Consequently, the cost of scrubbers was attributed to the permit
program.2 With regard to sewage sludge incineration and asphalt batching, no clear-cut
evidence of the need  for  control expenditures beyond NSPS was found. In both cases,
however, a minimal expenditure of SI,000 to $3,000 was attributed to the permit program
to provide some margin of safety to accommodate advances in  technology. The other
sources subject to NSPS are  aggregated  with  sources  not subject to  NSPS so that  an
industry-wide, permit-related control cost was assumed to apply.

         Because  of the problems in estimating control costs for compliance with permit
requirements,  the cost  ranges  cannot be considered  representative  of any  individual
establishment.  Instead, they should  be considered a  "best  guess" as  to the  order  of
magnitude of costs likely to be incurred by each of the source groupings.

B.   Raw Data Pertaining to Pollution
     Control Cost Estimates

         The data used in developing estimates of pollution control costs by SIC are shown
below under their respective sources. For each source, applicable material is paraphrased and
tables and charts are included.  In presenting these sources, no attempt  has been made to
reconcile conflicts or to interpret the raw data.

1.   J. Booth. "Control of Industrial Boiler Emissions," in POWER, August  1975.

     •    For a given  gas  throughput, a wet scrubber will cost 25 percent more  than a
         two-stage cyclonic separation  system, while fabric filters and precipitators will
         cost five times that of cyclones.  With regard to operating costs, precipitators are
         cheaper  by a factor of five than scrubbers  and by a factor of 10 than industrial
         fabric filters (pp. 55-58).

2.   The Economics of Clean  Air. Annual Report of the Administrator of the Environ-
     mental Protection  Agency to the Congress of the  United States, March 1972.

     •    Small incinerators, such as in an apartment building, require about $1,115 per ton
         of daily  capacity in capital investment  and $295 per ton of daily capacity for
         annual operating costs (pp. 4-6).

     •    The range of control costs incurred by small, medium, and large asphalt batching
         plants is from $23,000 in capital investment and $7,000 in annual operating costs
 EPA and FEA, An Analysis of the Impact on the Electric  Utility Industry of Alternative
 Approaches to Significant Deterioration, October 1975.
9
 EPA is currently considering more stringent provisions of the NSPS for electric utilities.
 (Interview with Barbara Brown, Office of Air and Waste Management, U.S. Environmental
 Protection  Agency, January 1976.) In  the future, therefore, scrubbers may be required
 under NSPS.
-------
                                         1-5
         to  $94,000 in capital investment and  518,000  in annual operating costs (pp.
         4-33).

     •    Very small iron foundries (with a value  of shipments less than $500,000) would
         incur control costs of SI4.60 per ton, while very large iron foundries (with value
         of shipments over S10 million) would incur control costs of S2.60 per ton (pp.
         4-67).

     •    A steel plant with total annual capacity of nine million tons and production of
         6.4 million tons of finished steel per year in 1970 (one third from basic oxygen
         furnaces and two thirds from open hearth furnaces) would incur estimated costs
         as follows: total investment, S30 million; total annual  cost, S9.8 million; annual
         cost per ton of raw steel,  S1.30; and annual cost per ton of finished steel, SI.53.
         Estimated costs for a small firm having an annual capacity of 2.24 million tons
         and production of 1.58 million tons  of  finished steel, entirely from open hearth
         furnaces, involve  an  investment requirement  of S8.4 million and a total annual
         cost of S2.9 million, or SI.83 per ton of finished steel. Similarly, a small firm
         producing 1.7 million tons of finished steel in 1967 with a capacity of 2.3 million
         tons, using only basic oxygen and  electric arc furnaces, would have an estimated
         investment of $7.0 million and an annual cost of S3.5 million, or $2.03 per ton of
         finished steel. For this firm, the high cost per ton of finished steel results from the
         use of 19 small electric furnaces (pp. 4-76).

     •    Control costs for secondary nonferrous metals range from $0.21 per short ton for
         lead to $0.59 per  short ton for zinc (pp.  4-156).

3.    Bill Judge, Air Equipment Company (subsidiary of  Duall Industries). 3 December
     1975.  Telephone Interview.

     •    On a very rough  basis, estimated foundry control costs are about $100,000 and
         estimated metal  working  control costs are about  $50,000 for New England
         manufacturers.

     •    Metal working  firms are going to several small package collector systems, each of
         which covers two or three  machines. This provides  flexibility  for relocation of
         production lines  and so  forth. At about 50,000 CFM (cubic  foot  per meter),
         economics usually dictate use of a single  collector.

4.    Beinkerhoff,  Ronald J., "Inventory of Intermediate-Size Incinerators in the United
     States - 1972." Pollution Engineering, November 1973, pp. 33-38.

     •    The average incinerator unit size in EPA, Region I is 207 Ib/hr. The average unit
         size by class of purchaser is as follows:

                  Commercial             267 Ib/hr
                  Industrial               297 Ib/hr
                  Medical                242 Ib/hr
                  High Rise               126 Ib/hr
                  Schools                183 Ib/hr
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                                        1-6
5.   Leung, Kenneth  Ch'uan-k'ai,  and Jeffrey A.  Klein, The Environmental Control In-
     dustry. An Analysis of Conditions and Prospects for the Pollution Control Equipment
     Industry. Submitted to the Council on Environmental Quality, December 1975.
         Selected Characteristics of Paniculate
         Removal Devices (p. 33)
      Device
  Electrostatic Precipitators
  Fabric Filters
  Wet Scrubbers
  Mechanical Collectors
Particle Size
 (microns)
   0.005
   0.005
.010- 1.000
   5.000
                                                     Rate
  96-99
  98-99
  70-99
  50-90
Cost per CFM*
 S4.00 - S4.50
 SI.25 -S2.00
 S5.00-S7.00
    S2.50
*CFM equals cubic foot per meter of gas flow.
         Selected Sulfur Removal Systems (p. 48)
  Process Throwaway
     Limestone Scrubbing

     Lime Scrubbing

  Recovery
     Magnesium Oxide
     Scrubbing
     Catalytic Oxidation
     Wellman Lord
    Size
   (Kw)
  115,000
  820,000
  410,000
   65,000
  100,000
  110,000
  115,000
                                                            Costs per
 Investment
    Kw
 S57 - Retro
 S43 - New
 $84 - Retro
 $57 - Retro
$70 - Retro
$73 -Retro
N.A. - Retro
  Operating
     Kwh
   2.2 mills
     N.A.
   5.8 mills
   2.5 mills
     N.A.
   4.0 mills
     N.A.
6.    Control  Techniques for  Paniculate  Air  Pollutants.  U.S.  Department  of  Health,
     Education, and  Welfare; Public  Health Service; Consumer Protection and Environ-
     mental Health Service, January 1969.
     •    For computing costs for a given system, one should consider (i) raw materials and
         fuels  used  in  the process, (ii) alterations in  process equipment, (iii)  control
         hardware and  auxiliary equipment, and (iv) disposal  of collected emissions (p.
         6-5).
     •    Efficiency of control equipment will vary with particle characteristics (wetability,
         density, shape, size distribution, etc.) (p. 6-9).
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                                      1-7
     Maintenance and operation costs are difficult to assess as individual firms may not
     break out these costs but rather include them in total operating costs.
•    Conditions Affecting Installed Cost
     of Control Devices (p. 6-17)
Cost Category
Equipment Transporta-
tion
Plant Age
Available Space
Corrosiveness of Gas
Complexity of Startup
Instrumentation
Guarantee on
Performance
Degree of Assembly
Degree of Engineering
Design
Utilities
Collected Waste
Material Handling
Labor
Low Cost
Minimum distance; simple load-
ing and unloading procedures
Hardware designed as an
integral part of new plant
Vacant area for location of con-
trol system
Noncorrosive gas
Simple startup, no extensive
adjustment required
Little required
None needed
Control hardware shipped com-
pletely assembled
Autonomous "package" con-
trol system
Electricity, water, waste dis-
posal facilities readily avail-
able
No special treatment facilities
or handling required
Low wages in geographical
area
High Cost
Long distance; complex procedure
for loading and unloading
Hardware installed into confines of
old plant requiring structural or
process modification or alteration
Little vacant space requires exten-
sive steel support construction and
site preparation
Acidic emissions requiring high alloy
accessory equipment using special
handling and construction tech-
niques
Requires extensive adjustments:
testing; considerable downtime
Complex instrumentation required
to assure reliability of control or
constant monitoring of gas stream
Required to assure designed control
efficiency
Control hardware to be assembled
and erected in the field
Control system requiring extensive
integration into process, insulation
to correct temperature problem,
noise abatement
Electrical and waste treatment
facilities must be expanded, water
supply must be developed or ex-
panded
Special treatment facilities and/or
handling required
Overtime and/or high wages in
geographical area
-------
                                          1-8
     •    Total Installation Cost for Various Types of Control Devices
          Expressed as a Percentage of Purchase Costs (p. 6-16)
Equipment Type
Gravitational
Dry Centrifugal
Wet Collector:
Low, Medium Energy
High Energy*
Electrostatic Precipitators
Fabric Filters
Afterburners
Cost, Percent
Low
33
35

50
100
40
50
10
Typical
67
50

100
200
70
75
25
High
100
100

200
400
100
100
100
Extreme High
	
400

400
500
400
400
400
""High-energy wet collectors usually require more expensive fans and motors.
7.    Background Information for Proposed New-Source Performance Standards. EPA No.
     APTD-0711.

     •    Control of particulate matter in steam  generating  plants may increase  capital
         investment requirements by 6 percent and operating costs by 4 percent (p.  15).

     •    Control of  sulfur  dioxide  by  steam generating plants may  increase  capital
         investment by 10 percent and operating costs by 7 percent to 30 percent (p. 16).

     •    Nitrogen oxide control will cause increase of up to 7 percent in capital investment
         and increases near 4 percent in operating costs (p. 16).

     •    Capital investment required for control of particulate, SO2 and NOX emissions of
         steam-electric generating plants will generally be  less than 25 percent of the total
         installed cost  of  the plant. Plants burning gaseous fuels (requiring control of NOX
         only) will experience only a 5 percent increase in installed cost (p. 15).

     •    Operating  costs  for solid- and liquid-fuel generating  units will increase by  15
         percent to 40 percent with emission controls, while plants using gaseous fuels will
         increase their operating costs by only 4 percent.

     •    Installed costs for a 100 ton-per-day refractory furnace are about SI million for
         the incinerator, including about $150,000 for high-efficiency control equipment.
         Installed costs of control equipment are therefore about 15 percent of the entire
         plant costs. For plants with a capacity of 300 tons per day, costs decrease to  13
         percent of the incinerator cost (p. 24).
         For a  100-ton-per-day water wall furnace, incinerator costs are about $1.5 million
         installed, including about  $105,000  for  the cost of  high-efficiency  control
-------
                                        1-9
8.
     equipment. Control equipment costs are therefore  about 9 percent of installed
     costs for the 100-ton-per-day  plant. This decreases  to  about 5 percent for a
     300-ton-per-day plant (p. 24).

Background Information for Proposed New Source Performance Standards, Volume 1,
Main Text. EPA No. AFTD-1352a.

•    Control Costs for Typical Asphalt Concrete Plants*


Plant Size,
Tons/Hour
(acfm)
150
(25,000)






300
(50,000)









Emission
Standard
Proposed
performance
standard =
0.031 gr/dscf
Reference
process weight
standard =
0.30 gr/dscf
Proposed
performance
standard =
0.031 gr/dscf
Reference
process weight
standard =
0.1 8 gr/dscf


Required
Control
Equipment
Fabric filter

Venturi scrubber

Low-energy
scrubber


Fabric filter

Venturi scrubber

Low-energy
scrubber




Control
Investment
(S)
63,000

56,000

44,000



92,000

95,000

75,000





Annual
Cost
(S/year)
18,000

21,000

16,000



26,000

36,000

27,000



Annual
Cost per
Unit of
Production
(S/ton)
0.16

0.19

0.14



0.12

0.16

0.12



*Model plant assumptions: (1) 1500 hours on-stream annually, (2) production averages 50
 percent of capacity, (3) 10-year straight-line depreciation, (4) 50 percent of retained fines,
 valued at S9/ton, recycled, and (5) average product price of $6/ton.
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                                         MO
          Control Costs of Meeting Performance Standard (0.022 gr/dscf)
          for Typical Secondary Lead Plants* (p. 42)


Plant Type
Blast furnace, 50 tons/
day



Reverberatory Furnace,
50 tons/day


Required
Control
Equipment
Afterburner,
U-tube cooler.
fabric filter
Afterburner,
water quench,
venturi scrubber
U-tube cooler,
fabric filter
Water quench,
venturi scrubber

Control
Investment
(S)
157,000

123,000

188,000
125,000

Annual
Cost
(S/year)
51,000

80,000

21,000
36,000
Annual Cost
per Unit of
Production
(S/ton)
4.05

6.40

1.65
2.86
*Major assumptions: (1) production rate, 4,000 Ib/hr; (2) annual production, 12,500 tons;
 (3) recoverable dust is recycled at a value of 2.25 cents/lb. except for reverberatory dust
 recovered from fabric filters at value of 4.5 cents/lb; (4) fabric filter systems depreciated
 straight-line,  15-year life;  (5) venturi scrubber systems depreciated straight-line, 10-year
 life; and (6) estimated average product price S320/ton.
         Control Costs of Meeting Performance Standard
         (0.022 gr/dscf) for Reverberatory Furnaces (p. 48)

Furnace
Capacity, Tons/Day
20
50
75

Investment
(S)
74,000
110,000
130,000

Annual Cost
(S)
13,000
20,070
34,300
Annual Cost per
Ton of Product
(S)
6.52
4.01
3.24
-------
                                        1-11
    ••    Control Costs of Meeting Performance Standard
         (0.022 gr/dscf) for Typical New Two- Vessel
         Basic Oxygen Process Furnaces* (p. 55)


Plant Size
(tons/melt)
140





250






Required
Control
Equipment
Open hood,
scrubber
Open hood,
ESP**
Closed hood,
scrubber
Open hood,
scrubber
Open hood,
'ESP
Closed hood,
scrubber

Control
Investment
(S)
5,700,000

5,900,000

6,800,000

7,400,000

8,000,000

8,400,000
*


Annual Cost
(S/yr)
1,950,000

1,500,000

2,140,000

2,750,000

2,000,000

2,800,000

Annual Cost
per Unit of
Production
(S/ton)
1.52

1.17

1.67

1.20

0.89

1.22

 *Major assumptions: (1) production of 140 tons/melt = 2,300,000 tons/yr; (2) 18-year
  straight-line depreciation.
**ESP-electrostatic precipitator.
         Control Costs of Typical Sewage
         Sludge Incinerator* (p. 61)
Plant Size,
Tons /Day
(cfm)
10
(10,000)




100
(17,800)




Emission
Standard
Performance
standard =
0.031 gr/dscf
Typical local
standard =
0.10 gr/dscf
Performance
standard =
0.031 gr/dscf
Typical local
standard =
0.10 gr/dscf
Required
Control
Equipment
Low-energy
venturi scrubber

Low-energy
impingement
scrubber
Low-energy
venturi scrubber

Low-energy
impingement
scrubber
Control
Investment
(S)
60,000


55,000


132,000


120,000


Annual
Cost
(S/year)
1 1 ,700


8,400


34,200


21,100


Annual Cost
per Person
(S)
0.12


0.08


0.03


0.02


*Model  plant  assumptions: (1) 10  tons/day — 3640 hours of  operation  per  year, 100
 tons/day — 8736  hours  of operation  per  year; (2) sinking fund depreciation  over 12.5
 years; and (3) interest at 6 percent.
-------
                                          1-12
 9.    Implications of Alternative Policies for the Use of Permanent Controls and Supple-
      mental Control Systems (SCS). EPA Office of Planning and Evaluation. 7 July 1975.

      •    Capital cost for adding a scrubber to existing plants is S90 per KW; operating and
          maintenance cost on existing plants will increase by S.I8 per million Btu with the
          addition of a scrubber (p. 8).

      •    Addition of a scrubber to plans for a new plant will increase the capital cost by
        •  S65 per KW; addition  of a scrubber will increase operating and maintenance costs
          in a new plant by S.I 1  per million Btu (p. 8).

10.    Perl, Lewis J., and Joe D. Pace,  The Costs of Reducing SO2 Emissions from Electric
      Generating Plants,  a report to  Electric Utility  Industry  Clean Air Coordinating
      Committee by National Economic Research Associates, Inc., June 1975.

      •    Clean  Air Coordinating Committee  (CACC)  survey of utilities indicated  that
          estimated capital costs of scrubbers for new  electric generating plants averaged
          S60 per kilowatt in 1974 dollars. A Pedco, Inc., study reported  similar estimates
          (p. 24).

      •    CACC survey indicated an estimated cost averaging S80 per kilowatt for installing
          scrubbers in existing plants. This estimate is SI5 per kilowatt higher than reported
          by the Pedco, Inc., survey which,  admittedly, may not  represent  "a 'typical'
          retrofit situation" (p. 24).

      •    Both of these surveys exclude the cost of precipitators. Both assume that 100
          percent of the flue gas is to be scrubbed whereas in some cases partial scrubbing
          may be adequate.

      •    Energy required to operate scrubbing equipment would average 2 percent of the
          electricity generated by unit  being scrubbed (p. 24).

      •    Two percent of the fuel otherwise used to generate electricity would be consumed
          in reheat (necessary  in order  to achieve appropriate plume height). If less than
          half the  gas  is  scrubbed,  scrubbed  and unscrubbed gases may be  mixed,
          eliminating the need for reheat (p. 25).

      •    Labor and materials costs for scrubbers average about 1.4 mills per kilowatt-hour
          scrubbed in 1974 dollars.
-------
    APPENDIX J
LIST OF INTERVIEWS
-------
       TELEPHONE INTERVIEWS WITH iMANUFACTURING FIRMS
Sterling  Alexiadis,  Comptroller and  Treasurer, Bic Pen Corporation.  Milford.
203/878-6861,31 October 1975.

Charles B. Allen, Manager of Financial Analysis, Anaconda American Brass Co.,
Waterbury, 203/757-2021, 30 October 1975.

Fred  Anderson, Plant  Engineer,  Nash  Engineering  Co.,  South  Norwalk,
203/853-3900, 18 November 1975.

J. Paul Beliveau, Plant Manager, Bridgeport Brass Co., Bridgeport, 203/366-6182,
19 November 1975.

Roy Bergstrom. President, Commercial Foundry Co., New Britain, 203/224-1794,
31 October 1975.

Helen Bolinger, Public Relations Department, American Can Corp., Greenwich,
203/552-2000, 19. November 1975.

James Brown, Corporate Purchasing Agent, Armstrong Rubber Co., New Haven,
203/562-1161, 18 November 1975.

Mr. Brunyansky, Manager of Plant Engineering, Avco Corporation, Bridgeport,
203/378-8211, 18 November 1975.

Don Buska,   Plant  Manager, Hitchiner  Manufacturing Co., Inc., Wallingford,
203/265-2331, 30 October 1975.

Doug  Button, Environmental Engineer,  Scoville Manufacturing Co., Waterbury,
203/757-6061, 17 November 1975.

J. W. Caldwell,  Manager  of Industrial   Engineering,  Dresser Industries,  Inc.,
Stratford, 203/378-8281, 31 October 1975.

Mr.  Calmyca,  Plant  Superintendent,  Napier  Co.,  Meriden,  203/237-5522,
30 October 1975.

Richard  Cannon, Public  Relations,  Olin Mathieson-Winchester Division,  New
Haven, 203/777-7911, 20 November 1975.

Charles  Dayton,  Director  of Public   Relations,  Perkin-Elmer  Corporation,
Norwalk, 203/762-1000, 18 November 1975.

Mr. DeMaria, Plant Engineer and Real Estate Coordinator, Superior Electric Co.,
Bristol, 203/582-9561, 21 November  1975.
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                                  J-2
Chester J.  Deutsch,  Senior  Vice  President of Finance,  Arnold Bakers,  Inc.,
Greenwich, 203/661-2770, 20 November 1975.

Frank   Donovan,  Connecticut  Relations,  General  Electric  Co.,  Fairfield,
203/373-2211, 28 October 1975.

Thomas Edwards, Manager of Communications, General Electric Co., Bridgeport,
203/334-1012, 31 October 1975.

John  Erickson,   Plant  Engineer,   Electrolux  Corporation,  Old  Greenwich.
203/637-1761, 20 November" 1975.

Mr. Favro,  Director of Employee Relations, Gedney Electric Co., Inc., Bristol,
203/584-0571, 20 November 1975.

Mr. Fletcher,  Engineer,  Textron,  Inc., Fafnir Bearing Division, New Britain,
203/225-5151, 21 November 1975.

Florian Galdau, Manager  of Manufacturing and Engineering, Ferite Co.. Seymour,
203/888-2591,17 November 1975.

Mr. Gerky,  Personnel Manager,  Bunker-Ramo Corporation, Amphenol  R.F.
Division, Danbury, 203/743-9272, 20 November 1975.

Robert  M.   Gordon,  President,   Raybestos-Manhattan,   Inc.,   Bridgeport,
203/371-0101, 11 November 1975.

Frank Gosselin,  Plant Controller, Ferro Corporation,  Norwalk,  203/853-2123,
30 October 1975.

Harland Graime,  Chief  Engineer.   Acme  Screw and  Fastenings Co., Bristol,
203/583-0200, 28 October 1975.

Alfred  B.  Gunthel, President, Dossert  Manufacturing  Corporation,  Waterbury,
203/757-8761, 28 October 1975.

Mr. Hagstrom,  Plant  Manager,  New  Departure Co.,  Bristol,  203/582-6371,
20 November 1975.

Carl  Hamberg, Head of Industrial  Engineering,  Marlin-Rockwell,  Division of
Thompson-Ramo-Wooldridae. Inc.,  New Britain,  203/747-2771,  19 November
1975.

Arnold Haydn, Chief Engineer, Carpenter Technology  Corporation,  Bridgeport,
203/335-0121, 28 October  1975...

Michael J.  Hutnik,   Chief  Plant  Engineer,  International  Silver,  Meriden,
203/634-2500, 28 October 1975.
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                                   J-3
Arnold Keppell,  Plant  Manager.  Automotive Controls  Corporation, Branford,
203/481-0341, 20 November 1975.

Mr. Klein, Manager of Environmental Programs, Combustion Engineering, Inc.,
Hartford, 203/688-1911, 17 November 1975.

Mr. Kochman. Comptroller, Acme  Screw and Fastenings Co., Richfield, New
Jersey, 201/941-1050, 28 October 1975.

George Krize, Plant  Engineer, Burndy  Corporation, Norwalk, 203/838-4444,
20 November  1975.

Tom  Latham, Supervisor,  Wallingford Steel  Co.,  Wallingford, 203/269-3361,
11 November 1975.

Mr.  Lemar,  Director of Communications  and Services,  Avco  Corporation,
Bridgeport, 203/378-8211, 18 November 1975.

Jack  Martin,  Plant  Facilities  Engineer,  Sargent  and   Co.,  New   Haven,
203/562-2151.

Ed   McDonough,  Assistant   Secretary,   Electrolux  Corporation,   Stamford,
203/359-3600, 20 November 1975.

Thomas McGary, Public Relations, Pitney-Bowes, Inc., Stamford, 203/356-5000,
20 November 1975.

Robert McLalland, Manager of Employee-Community Relations, General Electric
Co., Plainville, 203/747-1671, 28 October  1975.

Mr.  Meoni,  Vice President  of Finance,  Napier Co., Meriden, 203/237-5522,
30 October 1975.

Malcolm  Millar,  Manager  of  Manufacturing  Services,  Colt  Industries, Inc.,
Firearms Division, Hartford, 203/278-8550, 17 November 1975.

Neil  Morrison,  Vice President  and  General  Manager,  Farrell Co., Ansonia,
203/734-3331, 17 November 1975.

Mr. O'Dell, Vice  President of Manufacturing, Standard-Knapp Division of Emhart
Corporation, Middletown, 203/342-1100,  18 November 1975.

Mr.  Ottavio, Plant  Manager,  Barden Corporation,  Danbury, 203/744-2211,
20 November 1975.

Mr.  Pelton, Purchasing  Agent, Kimberly-Clark Corporation,  Danbury. 203/
354-4481, 20 November 1975.
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                                   J-4
Mr.  Pfeffer,  Comptroller,  National Plastics  and Plating  Supply  Co.,  Inc.,
Plymouth, 203/589-7800, 28 October 1975.

T.H.  Rosfelder,  Regional  Engineer,  Sun Oil Co., Bridgeport. 203/239-4441,
31 October 1975.

Richard   Rubenstein,   Vice   President,   Wiltshire   Industries,   Waterville,
203/756-7877, 30 October 1975.

Mr.  Rupinski, Manager of Planning, Combustion Engineering, Inc., Hartford,
203/688-1911, 17 November 1975.

Dick  Ryan, Plant Engineer,  Hamilton Standard  Division  of United  Aircraft
Corporation, Hartford, 203/623-1621, 21 November 1975.

Ken Ryder, Plant Engineer, Eyelet Specialty Co., Division of Insilco Corporation,
Wallingford, 203/269-3381,  18 November 1975.

Mr. Schiffer, North American  Director of Industrial Relations, Timex Industries,
Waterbury, 203/758-1911.

David Sidney, Comptroller, American Fabrics  Co., Bridgeport, 203/335-2151,
30 October 1975.

William  Stieg, Engineer, Pfizer, Inc., Chemical Division, Groton, 203/445-5611,
3 November 1975.  '                .

Mr. Stoloff, Plant Manager,  Veeder-Root Co., Division of Veeder Industries, Inc.,
Hartford, 203/527-7201, 30 October 1975.

Eric  Storch,  Environmental  Engineer,  Uniroyal, Inc., Naugatuck Chemical
Division, Naugatuck, 203/723-3419, 31 October  1975.

Allan Swift,  President,  M.  Swift &  Sons,  Inc.,  Hartford, 203/522-1181,
30 October 1975. i

Robert Tolles, Director of Plant Engineering Services, Stanley Works, New Britain,
203/225-5111,28 October  1975.

Wayne  Tyson,   Manager of  Community  Relations,  Clairol,  Inc.,  Stamford,
203/357-5000, 18 November 1975.

Mr. Wagner, Manager of Facilities, General Electric Credit Corporation, Stamford,
203/357-4000, 31 October  1975.

Thomas Walk, Purchasing  Agent,  Hull Dyer and Print Works, Inc.. Ansonia,
203/734-1654, 17 November 1975.
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                                  J-5
Mr.  Walker,  Environmental  Engineer.  Wallingford  Steel  Co., Wallingford,
203/269-3361, 11  November 1975.

Mr.  Weaner,  Director  of Operations.  United  Technology,   East  Hartford,
203/728-7000.

H.R.  Werley,  Director of  Engineering, Pepperidge  Farms,   Inc.,  Norwalk,
203/847-0456, 20 November 1975.
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                                  J-6
         TELEPHONE INTERVIEWS WITH PUBLIC AND PRIVATE
                       AGENCIES AND GROUPS
Harold Ames, Dept. of Planning and Energy Policy, Hartford, Personal Interview,
4 November 1975.

Mr.  Andrews, Director, South Central  RPA,  New Haven,  203/777-4795,
24 November  1975.

Jerome  Barr,  McDave  Oil  Burner Company, New York  City, 212/384-0270,
4 November 1975.

Mrs. Bernt, Fairfield School Board, 203/255-0421, 19 November 1975.

Peggy Brown,  Southwestern RPA, 203/866-5543, 21 November 1975.

George  W.  Bruno, Senior  Market Analyst,  Dept.  of Commerce, Hartford,
203/566-4587, Personal Interview, 5 November 1975.

Ed  Butler,  Economist,  Office of  Planning  and Energy  Policy, Hartford,
203/566-5803, 18 November 1975, Personal Interview, 4 November 1975.

Mr.  Cashman, Bureau  of  Grants  Management  and Information, Dept.  of
Education, Hartford, 203/566-4897, 22 October 1975.

Mr. Cerelle, Waterbury School Board, 203/757-1191, 19 November 1975.

Richard Chase,  President,  Resource  Recovery  Authority, 203/549-6390,  12
November 1975, 25 November 1975.

Connecticut Development Authority, 203/566-4320, 27 October 1975.

Tom Cooney,  Regional Planner, Central Connecticut RPA, Bristol, 203/224-9888,
21 November  1975.

Richard J. DeNoia, Executive Assistant to the Commissioner, Dept. of Commerce,
Hartford, 203/566-4094, Personal Interview, 5 November 1975.

John DiFazio, Engineer, Connecticut Dept.  of Environmental Protection, Hart-
ford, 203/566-2690, 30 October 1975.

Scott Eaton, Engineer, Connecticut Dept. of Environmental  Protection, Hartford,
203/566-2690, 30 October 1975.

Mr. Edelman,  Distribution and Engineering Department, Exxon Company, New
York City, 914/738-4700, 4 December 1975.

Shelton Edwards, Principal Air  Pollution Control Engineer, Air Compliance Unit.
Dept.  of Environmental Protection,  203/566-2690,  24  November  1975, 2
December 1975, 4 December 1975.
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                                  J-7
Mr.  Evanson,  Customer  Service,  Gulf  Oil  Company,  New  York  City,
212/343-2200, 4 December 1975.

Mark  Feinberg,  Director  of Development,  Dept. of  Commerce,  Hartford.
203/566-5546, Personal Interview, 5 November 1975.

Tom Fessinger,  Planner for Solid Waste Office, Connecticut Dept. of Environ-
mental Planning, Hartford, 203/566-5847, 12 November 1975.

Phil Florkoski, Senior Air  Pollution Engineer with  Office of Director, Dept. of
Environmental Protection, Hartford, 203/566-4030, 24 November  1975.

Daryl  Francis, Engineer,  Connecticut Dept. of Environmental Protection, Hart-
ford, 203/566-2690, 30 October 1975, 5 November 1975.

Ron Freeto, Air Compliance Control, Dept. of Environmental Protection, Hart-
ford, 203/566-2690, Personal Interview, 4 November 1975.

Lawrence Goldstein, Petroleum Industry Research Foundation, 212/867-0052,3
November 1975.

Mr. Griffin, Vice  President,  T.A.D. Jones Co..  New Haven, 203/865-6103, 31
October 1975.

Bill Harper, Senior Mineral  Specialist, Bureau of Mines, Division of Petroleum and
Natural Gas, Washington,  D.C., 202/634-1160, 3 December  1975.

Richard  L.  Higgins,  Executive  Director, State  of Connecticut Development
Authority, Hartford, 203/566-4320, Personal Interview, 5 November 1975.

Tom  Hill,  Planner,  Greater Bridgeport RPA, Trumbull, 203/268-0014,  24
November 1975.

Steven Holmes,  Midstate  RPA, Middletown, 203/347-7214, 24 November  1975.

Housatonic RPA, Danbury, 203/743-2769, 21 November 1975.

Mark  Hultman,  Engineer,  Connecticut  Dept.  of Environmental Protection,
Hartford, 203/566-2690,  30 October 1975.

Jack Keever,  Greater Hartford Chamber of Commerce, Economic Development
Department, 203/525-4451, 22 October 1975.

Charles Kurker, Principal Sanitary Engineer, Chief  of Technical  Services, Solid
Waste  Office,  Connecticut Dept.  of Environmental  Planning,  Hartford,
203/566-5847, 12 November 1975, 25 November 1975.
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                                  J-8
Mr. Le Gates, Wholesale Fuel Marketing, Heavy Fuel Oil Coordinator; Exxon Oil
Company, Houston, Texas, 713/221-3636, 4 December 1975.

Mr.  McClelland,  Editor  of Platt's Oilgram  and Price Service,  Divison  of
McGraw-Hill Co.. New York City, 212/997-2937, 3 December 1975, 4 December
1975.

Ed  McDonald, Director of Programs and Energy Operations, Dept.  of Planning
and Energy Policy, Hartford, 4 November 1975.

Joyce Morrison, Public Information, Federal Power Commission, Washington,
D.C., 202/275-4006, 3 December 1975.

Mr. Nill, President, Buckley Brothers, Inc., Bridgeport, 203/336-3541, 31 October
1975.

Kevin O'Mara, Valley  RPA, Ansonia, 203/735-8689, 21 November 1975.

Mr.  Parekh,  Department  of Environmental  Conservation, Division  of Air
Resources, Albany, New York, 518/457-5364, 3 November 1975.

Steve  Patterson, Bureau  of  Mines, Division of Fuel Data.  Washington,  D.C.,
202/634-1088, 3 December 1975.

Robert  Randall,  Business   Manager  for  Air Compliance Unit,  Hartford,
203/566-2269, 5 December 1975.

George Reister, Price Analyst, Exxon Company, New York City, 914/738-4700, 6
November 1975.

Saul Schneider, Engineer,  Connecticut  Dept.  of Environmental  Protection,
Hartford, 203/566-2690, 30 October 1975.

Mr. Shamus, Bridgeport School Board, 203/576-7301, 18 November 1975.

Steve  Soumerai, Lung Association, East  Hartford, 203/528-9437, 4  November
1975.

Dr. John D. Spengler, Department of Environmental Health,  Harvard University,
Cambridge, Massachusetts, 617/734-3300, 3 November 1975.

Mrs. Standlini, Secretary to  former Acting Director, The Highlands Apartments,
East Hartford, 203/289-5466, 18 November 1975.

Dr. Bernard V. Strauss, Chairman, Department of Psychiatry, Danbury Hospital.

Mr. Tippin, Technical Emission Advisor, New York City, EPA, 212/566-2717, 3
November 1975.

Charles  Vidich, Planner,  Central Naugautuck Valley RPA,  203/757-0535, 21
November 1975.
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                                  J-9
Dave  Waller, Economic  Development Division  of Chamber of  Commerce,
Waterbury, 203/757-0701, 22 October 1975.

Dr. O.H. Weber, D.V.M., O.H. Weber Animal Hospital, Simsbury, 203/658-5126,
18 November 1975.

Ray Weiner, Air  Bureau, Region  2  EPA,  New  York City,  212/264-9868, 3
November 1975.

Mrs.  Wilson,  Secretary  to   Principal,   Buckley  High  School.  Hartford,
203/728-3300/25 November 1975.

Mr.  Bruce   Wilson.  Connecticut  Business  and  Industry  Assoc., Hartford.
203/547-1661, 3 November 1975.

Kenneth A. Wood, Deputy Commissioner, Department of Planning and Energy
Policy, Hartford, Personal Interview, 4 November 1975.
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    APPENDIX K
LOCATION QUOTIENTS
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           APPLICATION AND LIMITATIONS OF LOCATION QUOTIENTS
         Location  quotients  (LQ's)  have been  used  as  an indication of Connecticut's
relative  attractiveness  to  and  growth  potential  for specific  industry  sectors  (both
manufacturing and non-manufacturing). The LQ calculation involves dividing the proportion
of earnings or employment attributable to an industry within the region by the proportion
of national earnings or employment accounted for by that industry. 1 A result greater than
1.0 represents relatively greater activity of the industry  within the region. This, in turn, can
be deemed an indication  of two factors: the region's relative locational advantages for the
industry and, if demand can be assumed to be uniform throughout the nation, the degree of
the industry's regional export specialization. Export industries are  generally considered to
have greater  growth potential  in that they  can  expand  faster than  the  overall regional
economy. Consequently, the  LQ can aid  in differentiation  between industries which are
relatively "footloose" with respect  to  location and those which are more  strongly tied to
location in a region and can roughly indicate industry's growth potential within a region.

         It is important to note the assumptions implicit in application of the LQ for these
purposes. In addition to the assumption that demand for an industry's product or services is
evenly distributed, the LQ approach also:

         •    Assumes no major differences in productivity throughout the nation.

         •    Assumes  no factors  such  as  brand loyalty affect  demand for generic
              products.

         •    Assumes  a  single nationwide production  function  for  the industry at
              whatever level of detail (that is. SIC) is used.

As  a result of these assumptions, the  numerical  LQ can be quite  sensitive to the level of
specificity used in industry and product categorization. Furthermore, as statistical technique
it is more reliable in evaluation of large economic areas. In general, LQ's are considered to
yield a low estimate of export specialization.
1                   Area industry as a % of total area earnings or employment
 Location Quotient = —:—	:	-—:	
                    U.S. industry as a % ot total U.S. earnings or employment
 This is equivalent to the following formula:

                          X              X
                            -j               OO
       Location Quotient =	     •    	
                          Xoj             ^o

       where         X = measure of economic activity usually earnings or employment
                     i  = ith industry
                     j  =jth region
                     o = summation.  In the left position, it is an industrial summation;
                                     in the right position, it is an area summation.
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                                        K-2
         In  determining  LQ's for Connecticut industries,  employment was  used  as  a
measure of economic activity. Comparable  employment estimates by two-, three-, and in
some cases, four-digit  SIC's for the U.S. and Connecticut,  were obtained from County
Business Patterns, 1972. The results are summarized in Exhibit K-l for those industries with
LQ's greater than or equal to 1.0.
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                                       K-3
                                  EXHIBIT K-1
                     CONNECTICUT LOCATION QUOTIENTS
                              GREATER THAN ONE
SIC                                                                           LQ

176      Roofing and Sheet Metal Work                                          1.05
179      Miscellaneous Special Trade Contractors                                  1.02
1799     Special Trade Contractors, n.e.c.                                         1.12

19       Ordnance and Accessories                                               2.00

205      Bakery Products                                                       1.27

226      Dyeing and Finishing Textiles, Except Wool and Knit Goods                1.77
228      Yarn and Thread Mills                                                  1.34
229      Miscellaneous Textile Goods                                            2.84

265      Paperboard Containers and Boxes                                        1.11

27       Printing, Publishing, and Allied Industries                                 1.06
271      Newspapers:  Publishing, Publishing and Printing                          1.12
275      Commercial Printing                                                   1.04

283      Drugs                                                                1.55
284      Soap, Detergents, and Cleaning Preparations; Perfumes, Cosmetics and
          Other Toilet Preparations                                              1.90

30       Rubber and Miscellaneous Plastics Products                               1.60
306      Fabricated Rubber Products, n.e.c.                                      1.93
307      Miscellaneous Plastics Products                                          1.27

329      Abrasive, Asbestos, and Miscellaneous Nonmetailic Mineral Products         1.57

33       Primary Metal Industries                                               1.13
335      Rolling, Drawing, and Extruding of Nonferrous Metals                     4.37
3357     Drawing and Insulating of Nonferrous Wire                               3.83

34       Fabricated Metal Products                                              1.87
342      Cutlery, Hand Tools, and General  Hardware                               5.08
345      Screw Machine Products and Bolts, Nuts, Screws, Rivets, and Washers        3.64
3451     Screw Machine Products                                                4.72
346      Metal Forgings and  Stampings                                           1.39
347      Coating, Engraving, and Allied Services                                   1.94
348      Ordnance and Accessories, Except Vehicles and Guided Missiles             2.98
349      Miscellaneous Fabricated Metal Products                                  1.77
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                                        K-4
                                 EXHIBIT K-1 (Cont'd)
SIC                                                                            LQ

35       Machinery, Except Electrical                                            1.82
354      Metalworking Machinery and Equipment                                  3.16
355      Special Industry Machinery, Except Metalworking Machinery                1.47
3559     Special Industry Machinery, n.e.c.                                        2.90
356      General Industrial Machinery and Equipment                              4.53
3561     Pumps and Pumping Equipment                                         1.88
3562     Ball and Roller Bearings                                                13.87
357      Office, Computing, and Accounting Machines                              2.27
3579     Office Machines, n.e.c.                                                 12.06
359      Miscellaneous Machinery, Except Electrical                                1.64

36       Electrical and Electronic Machinery, Equipment and Supplies                1.36
361      Electric Transmission and Distribution Equipment                          1.61
3613     Switchgear and Switchboard Apparatus                                   2.93
363      Household Appliances                                                  1.78
364      Electric Lighting and Wiring Equipment                                   2.77
366      Communications Equipment                                             1.19
3662     Radio and Television Transmitting, Signalling and Detection Equipment
          and Apparatus                                                        1.59
367      Electronic Components and Accessories                                   1.49
3679     Electronic Components, n.e.c.                         '                  2.05

37       Transportation Equipment                                               2.49
372      Aircraft and Parts                                                      6.72
3722     Aircraft Engines and Engine Parts                                       18.9

38  '     Measuring, Analyzing, and Controlling Instruments; Photographic,
          Medical, and Optical Goods; Watches and Clocks                          2.63
382      Measuring and Controlling Instruments                                   2.97
383      Optical Instruments and Lenses                                          8.86
384      Surgical, Medical, and Dental Instruments and Supplies                     2.62
387      Watches, Clocks, Clockwork-Operated Devices and Parts                    9.16
3871     Watches and Clocks                                                   10.18

39       Miscellaneous Manufacturing  Industries                                   1.83
391      Jewelry, Silverware, and Plated Wire                                      3.24
3914     Silverware, Plated Ware, and Stainless Steel Ware                          12.84
395      Pens, Pencils, and Other Office and Artist's Materials                       3.93

396      Costume Jewelry, Costume Novelties, Buttons, and Miscellaneous
          Notions,  Except Precious Metal                                         5.22
3964     Needles, Pins, Hooks and Eyes, and Similar Notions                        9.42

41       Local and  Suburban Transit and Interurban Highway Passenger
          Transportation                                                        1.12
415      School Buses                                                           3.34
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                                        K-5
                                  EXHIBIT K-1 (Cont'd)


SIC                                                                             LQ

493      Combination Electric and Gas; Other Utility Services                       1.62

5029     Chemicals and Allied Products, n.e.c.                                      1.05
5047     Meats and Meat Products                                                1.13
506      Wholesale Trade-Electrical Goods                                         1.03
5063     Wholesale Trade-Electrical Apparatus and Equipment; Wiring Supplies
          and Construction Materials                                              1.35
5095     Beer, Wine, and Distilled Beverages                                        1.15
5096     Paper and Its Products                                                   1.00

533      Retail Trade-General Merchandise                                         1.04

54       Retail Trade-Food Stores                                                1.06
541      Grocery Stores                                                         1.03
546      Retail Bakeries                                                         1.41

56       Retail Trade-Apparel and Accessory Stores                 •                1.03
565      Retail Trade-Family Clothing Stores                                       1.10

592      Liquor Stores                                                          1.04
598      Fuel and Ice Dealers                                                     2.09
5983     Fuel Oil Dealers                                                        3.58

603      Mutual Savings Banks                                                   6.04

63       Insurance                                                              2.11
631      Life Insurance                                                          2.17
633      Fire, Marine, and  Casualty Insurance                                      2.54

66       Combinations of Real Estate                                             1.40

702      Rooming and Boarding Houses                                           1.04

734      Services to Dwellings and Other Buildings                                  1.08
7349     Cleaning and Maintenance Services to Dwellings and Other Buildings, n.e.c.    1,24
739      Miscellaneous Business Services                                           1.02
7392     Management Consulting and Public Relations Services                      1.11
7393     Detective Agencies and Protective Services                                 1,21
7398     Temporary Help Supply Service                                          1.32

81       Legal  Services                                                          1,08

82       Educational Services                                                     1.50

84       Museums, Art Galleries, Botanical and Zoological Gardens                   1.74

Source:  Harbridge House,  Inc. (Based on County Business Patterns, 1972.)
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          APPENDIX L
BENEFITS OF IMPROVED AIR QUALITY
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                      BENEFITS OF IMPROVED AIR QUALITY
         Particulate matter and sulfur oxides have numerous effects on human health and
behavior, property, and the environment as  summarized  in  Exhibit L-l.  Normally, these
effects have some economic values or costs which represent beneficial gains from reducing
or stemming growth in pollution. Nevertheless, quantification  of such  benefits associated
with the strategies under consideration is constrained primarily by three factors. First, there
is  substantial  difficulty in estimating the incremental benefits accruing to the  individual
strategies  in  the  context  of  the  wide range  of  pollution  abatement  measures  and
technological innovations. Second, valuation of qualitative attributes of reduced  pollution
levels, such as improved aesthetics and health, are subject to only rough estimates based on
those aspects  of the benefits that have measurable monetary values (for example, salaries
foregone as a result of illness or premature  death). Finally, the  interaction of pollutants,
individually and synergistically,  in the environment can significantly affect the degree of
impact  that is experienced. Despite  these limitations, several efforts have  been  aimed at
determining  the  order of  magnitude of the  benefits associated  with reductions  in  air
pollution (or conversely the costs of incremental pollution  of the air). These studies are
summarized below.

A.   Human Health

         There are two  major  published studies on the health  costs associated with air
pollution. 1 Both use the same general method of estimating costs: first, estimating the total
dollar value  associated with health  losses in diseases linked to air pollution  and second,
multiplying by a coefficient determined to represent the share of this value attributable to
air pollution. Different estimates of the costs result from consideration of different diseases,
inclusion of different  types of costs  associated with morbidity and mortality,  alternate
valuations of the costs, and different  estimates of coefficients relating air pollution to health
costs. However, the major drawback  of these and other studies is that they  assume a linear
relationship between air pollution and  health even though it  is not possible to  relate health
costs to levels of pollution or to sources of pollution.2

         A comparison of the two studies is shown in Exhibit L-2. Based on evaluation of
diseases of  the respiratory  system Ridker estimated that the damage  to health from air
pollution in 1958 had  an  economic value of S360 to S400 million, or  18  to 20 percent of
the  costs of  respiratory  diseases associated  with air  pollution. The  Lave-Seskin  study
included heart  disease  and several types of cancer in its 1963 estimates  of S2.08 million in
savings  that would result  from a  50 percent  reduction  in  pollution.  Neither  study
approached the cost estimates by pollutant.
^Ridker, Ronald G.; Economic  Costs of Air Pollution; New  York, Frederick A. Praeger,
 1967;  and L.B. Lave and E.P. Seskin,  "Air Pollution and Human Health," Science  169
 (3947) August 21, 1970, as reported in Cost of Air Pollution Damage: A Status Report,
 U.S. Environmental Protection Agency. (AP-85), February 1973.
-Barrett, Larry B., and Thomas  E. Waddell, National Environmental Research Center, Cost
 of Air Pollution Damage: A  Status Report, for  U.S. Environmental Protection Agency,
 Publication AP-85  (February 1973).
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                                          L-2
                                     EXHIBIT L-1
             EFFECTS OF PARTICULATE MATTER AND SULFUR OXIDES
 Particulate Matter: Particulate matter can be
 either solid or liquid aerosols suspended in
 the atmosphere, including substances such as
 smoke,  dusts,  fumes,  and  mists.  Atmo-
 spheric  particles  can affect the climate,
 damage  and  soil  materials,  and endanger
 human health.

 •    By  scattering and absorbing sunlight as
     well as by attenuating  the light from
     objects  and   illuminating  the  air
     (thereby reducing visual contrast) par-
     ticulate matter  cuts visibility. Reduced
     visibility is not only aesthetically un-
     desirable,  it  is  also  dangerous  for
     aircraft and motor vehicles.
                                     IT

•    Reduction of   sunlight in  cities  is
     strongly  correlated  with  particulate
     emissions. In general, cities receive 15
     to 20 percent less solar radiation than
     rural  areas; the reduction  in sunlight
     can  be as high as one third  in the
     summer and two thirds in  the winter.
     Also, particles, with their  affinity for
     water  vapor,  have caused increased
     rainfall in some  industrial cities.

•    The effects of  particulate matter on
     materials  include corrosion of  metals
     when the air is humid; corrosion and
     damage   of   electrical   equipment;
     erosion and soiling of buildings, sculp-
     ture, and painted surfaces;  and soiling
     of clothing and draperies.

•    Toxic  effects of particulates on the
     respiratory  system  of  animals  and
     humans result  from the particles' in-
     trinsic toxicity  caused by its chemical
     or  physical  properties.  Many studies
     have  been carried  out which  show
     increased  mortality  and  illness  ac-
     companying higher levels of particulate
     matter.
Sulfur  Oxides:  in the  atmosphere  sulfur
oxides  go through a  series of complicated
chemical   reactions.   One  of  the  most
common reactions is  conversion to sulfuric
acid in the presence of moisture. If there are
hydrocarbons and nitrogen  oxides in  the
atmosphere,  an   aerosol made  of  sulfur
particles will  be formed. Numerous other
reactions are possible  depending on the type
of sulfur oxide and the constituents of the
atmosphere.

•    Damage from sulfur oxide emissions
     affects  materials,   vegetation,  and
     health.  The  effect on  materials and
     property  is  largely a  result of  the
     conversion to sulfuric acid. Discolora-
     tion  and  physical   deterioration  are
     produced  in  building  materials and
     sculpture.  The   corrosion  of  most
     metals is accelerated by atmospheres
     polluted with S02;  particulate matter,
    ' humidity, and elevated  temperatures
     play   important   synergistic   roles.
     Deterioration and fading are also pro-
     duced  in  fabrics, leather, and paper.
     The drying time, brittleness, gloss, and
     even  color  of  paints  may  also  be
     affected.

•    Even at very low concentrations, S02
     has been  found  to adversely affect
     vegetation. High  concentrations over
     short  periods can produce acute leaf
     injury; while chronic leaf injury, such
     as  gradual yellowing, results from low
     concentrations over long periods.

•    Respiratory irritation has been linked
     with sulfur oxide levels, although  the
     concentrations  needed  to  produce
     pathological  lung change or mortality
     in  animals  are much greater than  the
     levels  encountered  in   urban  atmo-
     spheres. Nevertheless,  a rise  in S02
     levels has  been linked with increased
     mortality  and morbidity  in  several
     cities. In all cases, elderly people with
     heart  or  lung  disorders have  been
     affected most severely.
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                                     L-3
                                 EXHIBIT L-2
                  COMPARISON OF RESULTS OF TWO STUDIES
                  ON THE HEALTH COSTS OF AIR POLLUTION
Study
         Diseases
Types of Costs
Ridker Study*

    •    Cancer of Respiratory System
    •    Chronic Bronchitis
    •    Acute Bronchitis
    •    Common Cold
    •    Pneumonia
    •    Emphysema
    •    Asthma

Lane & Seskin Study**

    •    Respiratory Diseases
         (bronchitis, other)
    •    Cancer (lung, other)
    •    Cardiovascular
Premature Death
Treatment
Absenteeism
 Share of Disease
Costs Attributable
 to Air Pollution
    18 to 20%
Premature Death
Treatment
Absenteeism
    10 to 2 5%
 * Ridker, Ronald G., op. cit.
**Lave, L.B. and E.P. Seskin, op. cit.
Source:  Barrett and Waddell, op. cit.
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          In both studies the authors consider their results to be conservative. For example,
no attempt was made to value the mental costs of death or illness. Nor were more indirect
costs, such  as  costs of  moving to  cleaner areas  for health reasons, taken into account.
Certainly, the  focus on future  earnings  foregone  places emphasis  on the people in the
working force,  thereby attributing a lower value or none at  all to the lives of homemakers,
unemployed, and retired  persons.

          Using the criteria of reasonableness, a subsequent evaluation of  the two studies
yielded  a figure of S2.08 billion savings for a 50 percent reduction in air pollution, or a
S4.16 billion total cost of air pollution. 1 This estimate includes the discounted 1963 value
of future earnings lost because of mortality as well as the costs of treatment, prevention,
and morbidity. If it can  be assumed that the relationship of the economic  loss in  1963 to
the 1963 GNP (7 percent of GNP) is  constant,  then the 1974 loss associated with health
effects of air pollution would be about S9.8 billion.2

B.   Materials

         Several studies have evaluated the costs of air pollution damage to materials. Two
early attempts focused on estimating the national cost of corrosion of metals, implicating air
pollution as  a  causal  factor  but not  specifying  the relationship  between cost  and air
pollution. The total corrosion bill in the United States in  1950 was estimated in one study3
to be S5.4 billion, and in  the other to be S7.5 billion in 1958.4

         Another study on materials damage, this one concerned with painted surfaces, is
of similarly minimal applicability because  of the  speculative nature of the assumptions
used.5 The 1967 estimate of increased  costs of painting resulting from air pollution damage
in New  York was undertaken by Hudson Painting and Decorating Company based on the
sum  grossed by paint and other products sales in New  York and New Jersey. Assuming,
among other things,  that one  third  of  the cost of painting  is attributable  to air pollution
damage, SI50 million in damages was calculated for New York in 1967.

         A more sophisticated approach was taken by  Stanford Research Institute in its
evaluation of the damage caused to electrical contacts by  air  pollution.6 In this study it was
estimated that S20 million is spent on  plating contacts with precious metals to prevent air
U974 GNP:  S1397.4 billion, as reported  in  Suney of Current Business,  Volume 55,
 Number 11, November 1975.
^Barrett and Waddell, op. cit.
3>4Ibid., p. 13.
5Ibid., p. 14.
^Stanford  Research  Institute,  Inquiry  into  the Economic Effects  of Air Pollution  on
 Electrical Contacts,  U.S.  Department of Health, Education,  and Welfare, Public Health
 Service, National Air Pollution Control Administration; April 1970.
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                                          L-5
 pollution  corrosion. The study also estimated  that  $25 million is spent annually on air
 conditioning and purification systems, with additional annual expenditures of S4 million for
 washing insulators,  S5 million for research and development, and S10 million for equipment
 failures. 1 The total annual expenditure  is about  S65 million. However, the study concluded
 that the S65 million was unnecessarily high because  two or more  individually  effective
 countermeasures  were often applied simultaneously to minimize losses. Similarly, losses will
 decrease (over time) as less expensive and more  air pollution-resistant materials are used in
 electrical contacts.

          The most comprehensive survey of the economic effects of air  pollution on
 materials was undertaken  at  Midwest  Research Institute.- The  total value of  materials
 exposed to  air pollution and the  values of interaction between the various materials and
 pollutants were  calculated and then combined to yield a figure representing the extent of
 economic damage attributable to air pollutants.  These rank orderings are shown in Exhibit
 L-3. Although the  individual material loss  estimates were made to determine relative
 importance  rather than actual value, the total figure of S3.8 billion in 1968 is thought to be
 reasonable.3

          On the basis of work done by Midwest Research Institute on zinc, the annual cost
 of  corrosion of  galvanized steel,  including prevention costs, has  been estimated at S4.5
 billion.4 Calculation of the extreme values yielded a  low  of SI.4 billion and a high of S13
' billion.  It is suggested that the minimum value of SI.4 billion reflects  the most defensible
 estimate in light of data limitations.5

          Essentially, consideration of  cost savings from reduced  air pollution damage of
 materials as a benefit only views half of the situation. Since the air pollution damage results
 in  the  need for more  replacement,  repair, and  maintenance of  materials (all usually
 considered in the costs of  air pollution  damage), it also stimulates the market for firms that
 provide these products and services. Consequently, reduction in  air pollution results in a
 benefit  to the consumer (industrial, household,  or government) but represents a loss,  or
 cost, to the firms profiting from air pollution damage. In  this case the factor which is likely
 to tip the scales in favor of air pollution reduction — the efficient use of resources — cannot
 be reasonably quantified.
 1 Barrett and Waddell, op. cit., p. 15.
 ^
 -Salmon, R.; Midwest Research Institute; Systems Analysis of the Effect of Air Pollution on
  Materials;  U.S.  Department of Health,  Education, and Welfare; Public Health Service;
  National Air Pollution Control Administration, January  1970.
 •^Barrett and Waddell, op. cit., p. 17.
 4Haynie, F.H.; Estimation  of Cost of Air Pollution as the Result of Corrosion of Galvanized
  Steel; National Environmental Research Center, Research Triangle Park, N.C.; unpublished
  report.
 ^Barrett and Waddell, op. cit., p. 21.
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                                     L-6
                                 EXHIBIT L-3
               SUMMARY AND RANKINGS OF DAMAGE FACTORS



Rank
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53




Material
Paint
Zinc
Cement and concrete materials
Nickel
Cotton (fiber)
Tin
Synthetic rubber
Aluminum
Copper
Wool (fiber)
Natural rubber
Carbon Steel
Nylon (fiber)
Cellulose ester (fiber)
Building brick
Urea and melamine (plastic)
Paper
Leather
Phenolics (plastic)
Wood
Building stone
Polyvinyl chloride (plastic)
Brass and bronze
Polyesters (plastic)
Rayon (fiber)
Magnesium
Polyethylene (plastic)
Acrylics (plastic)
Alloy steel
Polystyrene (plastic)
Acrylics (fiber)
Acetate (fiber)
Polyesters (fiber)
Polypropylene (plastic)
Acrylonitrile-butadiene-styrene (plastic)
Epoxies (plastic)
Cellulosics (plastic)
Bituminous materials
Gray iron
Nylon (plastic)
Polyolefins (fiber)
Stainless steel
Clay pipe
Acetate (plastic)
Malleable iron
Chromium
Silver
Gold
Flat glass
Lead
Molybdenum
Refractory ceramics
Carbon and graphite

Value of
Interaction
(S/year)
0.50 x 10'1
0.29 x 10'1
0.1 Ox 10-2
0.25 x 10'1
0.40 x 10-1
0.26 x 10'1
0.10x10°
0.21 x 10-2
0.20 x 10-2
0.40 x 10-'
0.10 x 10°
0.50 x 10-2
0.40 x 10'1
0.40 x 10'1
0.10 x 10-2
0.10 x 10'1
0.30 x ID'2
0.40 x 10-2
0.10 x 10'1
0.10 x ID'2
0.23x10-2
0.10 x 10'1
0.42 x 10-3
0.1 Ox 10'1
0.40 x 1 0'1
0.20 x 10-2
0.10 x 10'1
0.10 x 10'1
0.40 x TO'2
0.10 x 10"1
0.40 x 10'1
0.40 x 10'1
0.40 x 1 0'1
0.10 x 10'1
0.10 x 10"1
0.10 x 10'1
0.10 x 10'1
0.10 x TO'3
0.50x10-3
0.10 x 10'1
0.40 x 10"1
0.85X10-4
0.10 x 10-2
0.10 x 10-1
0.16 x 10-2
0.75 x 10-3
0.12 x 10-2
0.10 x 10-3
0.10 x 10"4
0.11 x 10-3
0.25 x 10-3
0.10 x 10-4
0.10 x 10-5
In-Place Value
of Materials
Exposed
IS billion)
23.90
26.83
316.21
10.40
3.80
5.53
14.00
54.08
54.88
2.48
0.54
10.76
0.95
0.82
24.15
2.27
7.53
5.15
1.98
17.61
7.65
1.54
33.12
1.37
0.33
6.50
1.17
1.00
2.18
0.85
0.19
0.19
0.16
0.64
0.61
0.47
0.40
22.45
3.86
0.17
0.04
18.90
1.44
0.12
0.58
1.08
0.57
5.80
28.59
2.18
0.51
1.93
0.30
Total

Economic
Loss
(S million)
1,195.0
778.0
316.0
260.0
152.0
144.0
140.0
114.0
110.0
99.2
54.0
53.8
38.0
32.8
24.2
22.7
22.6
20.6
19.8
17.6
17.6
15.4
13.9
13.7
13.2
13.0
11.7
10.0
8.7
8.5
7.6
7.6
6.4
6.4
6.1
4.7
4.0
2.2
1.9
1.7
1.6
1.6
1.4
1.2
0.9
0.8
0.7
0.6
0.3
0.2
0.1
0.02
0.00
3,800.00
Source:   Midwest  Research Institute.  Systems Analysis of the Effect of Air Pollution on
         Materials. 1970. As reported in Barrett and Waddell. p. 20.
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                                         L-7
C.   Vegetation

         Production  cost  increases resulting  from air pollution were estimated to be in
excess of S3.5 million through observations  and analysis  conducted in Pennsylvania in
1969.1 Indirect losses attributable to air pollution were estimated to equal an additional S8
million, of which  S7  million reflected profit losses,  SO.5 million represented reforestation
costs, and the remainder reflected costs for grower relocation. Total costs attributable to air
pollution damage  of  vegetation, therefore, equal about  Sll million annually. Although
methods of translating  physical injury into economic loss have not been standardized and
several aspects of air pollution's impact on vegetation, such  as reduction  in aesthetic values
have  not been included, the  Pennsylvania study is  considered  successful  and its results
defensible.2

D.   Soiling

         In  recent years several attempts have been made  to identify the costs of soiling
from air pollution. For  the most  part  these studies have dealt  with  the household as the
primary  unit of investigation  in  an attempt  to measure  pollution-related cleaning  and
maintenance  costs  in  certain localities. Two  towns in  the Upper Ohio  River  Valley —
Steubenville  and Uniontown  — provided a stark comparison  for one study in  1966.3
Steubenville  had  an  annual  average  participate  concentration  of  235  mg/m3  while
Uniontown had  115 mg/nP. Based on the frequency of household cleaning and the  local
market  prices for  the  household services,  calculations showed that Steubenville residents
incurred costs of S84 (per capita) more than Unionville residents.

         Validation of this study was undertaken in the Washington, D.C., area because of
the  lower particulate  concentrations and  the smaller participate increment between the
cities paired for  comparison. Again  a positive relationship was found between the frequency
of household cleaning and  the ambient  particulate concentrations. Subsequently,  the
methodology used and cleaning  frequencies determined in the Washington and Steubenville
studies were  applied to Connecticut to evaluate economic losses from soiling attributable to
air  pollution  in  Connecticut.  However, the  Connecticut  results are considered highly
questionable  because of the failure to verify the applicability  of previous study results to the
state of Connecticut.4

         Despite the differences uncovered in the household cleaning costs of Steubenville
and  Uniontown  residents,  subsequent studies  have not  borne  out the significance of
economic losses  that can be associated with soiling from air pollution.  In particular, a study
^Lacasse, Weidensaul; Carroll; Statewide Survey of Air Pollution Damage to Vegetation —
 1969:  Center  for Air Environment Studies (CAES), State College, Pa.; CAES Publication
 148-70, January 1970; as reported in Barrett and Waddell.
-Barrett and Waddell, op. cit.,  p. 29.
^Michelson and Tourin. Comparative Method for Studying Costs of Air Pollution, Public
 Health Reports, 81(6), June 1966, as reported in Barrett and Waddell.
4Barrett and Waddell, op. cit.,  p. 37.
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                                          L-8
in Philadelphia found that  some  low-cost cleaning and maintenance operations,  such  as
washing  windows,  appear to be  sensitive  to air  particulate  levels but  that  high-cost
operations, such as painting and dry cleaning, are relatively unaffected by variations in air
particulate levels. 1
         •
E.   Residential Property Values

          An  interesting  finding  in  the Philadelphia  soiling  study was that a higher
proportion of residents of high-pollution areas believed their neighborhoods  were dirtier
than residents of  low-pollution areas felt theirs to be. Since the value of residential property
is  contingent upon many  factors,  it is reasonable to assume that the quality of air would
affect residential property  values. Certainly damage through soiling and material degradation
may be expected to affect property values. However, residential property value studies go
further in their evaluation of the  impact of air pollution by building on the market  price
differentials associated with demands for relocation away from pollution.

          Ridker  and Henning made the first serious use of the housing market estimator  as
an index of the effect of air  pollution on property values.2 Using the St. Louis Standard
Metropolitan  Statistical Area  (SMSA) for the study, they  estimated  the  mean change  in
property values per 0.25 mg SOs/lOO cm^-day change in sulfation at S245, or about S100
per 0.1 mg change.

          Subsequently, Crocker  and  Anderson studied  the  covariation  of  sulfation-
suspended particulates and census tract median  property values in St. Louis; Washington,
D.C.; and Kansas  City.3 The estimates derived ranged from S300  to S700 per 0.1 mg SOs
and  10  mg/m3-day  change  in  suspended particulates. Using similar  methods,  Zerbe4
reported  a best estimate of S966 reduction in property  values for each increase of 1.0 mg
SO3/100 cm3-day,  or about SI00 per 0.1 mg SO3/100 cm2-day change. A fourth study 5
also yielded cqmparable estimates:  S663 per 0.5 mg SOs  or about SI30 per 0.1 mg $63. All
four studies cited above show that sulfation is inversely related  to median property values
and  that  the magnitude  of  the  marginal  capitalized sulfation damage  for  residential
structures, for a marginal decrease of 0.1 mg SO3/100 cm2-day, probably lies in the range of
SI00 to  S300. The uniformity  of results  for the five  metropolitan  areas  studied  is
noteworthy.
1 Barrett and Waddell, op. cit., p. 42.
^Ridker, Ronald G., and John Henning; "The Determinants of Residential Property Values
 with  Special Reference  to Air Pollution";  Review  of Economics and  Statistics,  49:
 246-257; May 1967; as reported in Barrett and Waddell.
3 Anderson and Crocker;  "Air  Pollution and  Housing: Some Findings," Paper No. 264;
 presented at Institute for Research  in  the Behavioral,  Economic,  and  Management
 Sciences, Purdue  University: Lafayette, Indiana: December  1969;  as reported in Barrett
 and Waddell.
^Zerbe, R.O., Jr.; The Economics of Air Pollution: A Cost-Benefit Approach; Report to the
 Ontario Department of Public Health, Toronto, Canada; 1969.
^Barrett and Waddell, op. cit., p. 53.
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                                        L-9
F.   Other Estimates

         Other  types of estimates also merit consideration. For example, the National
Academy of Sciences has estimated that air pollution causes 4,000 deaths and four million
days of illness every year. The  EPA has estimated that, as of 1970, the monetary cost of air
pollution in health and material  damage  probably  amounted to S12  billion annually.l
Exhibit L-4 summarizes several  national  pollution  damage  estimates. The Barrett  and
Waddell estimate, in particular, broke down the damage estimate by pollutant, concluding
that about 50  percent  of  total  costs were attributable to sulfur oxides and  36 percent
attributable to particulates.2 Overall, it is noteworthy that  a recent CEQ review of studies
on the costs of air pollution damage concluded that  when health and property damage are
considered there appears to be  an outright  economic advantage to  pollution control.3
     , Gladurin; "Air Pollution Drive Lags, but Some Gains Are Made"; New  York Times;
 May 31, 1975; pp. 1 and 15.
2.Barre.tt  and  Waddell,. op.  cit.   The  breakdown  is  as follows:  residential  property
 .values T 54% ,SO.2.,and 46% TSP; materials - 46% SO2 and  15% TSP; health - 54% SO2
 arui 46%. TSP;'vege"tation -  100% SO2 and 6% TSP.  Since  the estimates  were  based on
 prior studies  the individual pollutants considered in those studies  largely determine these
 allocations.
^Kenneth  Ch'uan-k'ai Leung  and  Jeffrey Klein, The Environmental Control Industry: An
 Analysis of Conditions and  Prospects for the Pollution Control Equipment Industry, for
 Council on Environmental Quality, December 1975.
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                                      L-10
                                   EXHIBIT L-4
                           COMPARISON OF NATIONAL
                        POLLUTION DAMAGE ESTIMATES
                                                      Base           Range
Media                                                 Year     (in billions of dollars)

Air           Ridker (1966)                            1970     $7.3-  8.9

Air           Gerhardt(1969)                          1968       6.0 - 15.2 (best 8.1)

Air           Barrett and Waddell (1973)                 1968      16.1*

Air           Babcock and Nagda (1973)                 1968      20.2**

Air           Justice,  Williams, and Clement (1973)        1970       2.0-  8.7

Air           Waddell (1974)                           1970       6.1  - 18.5 (best 12.3)

Air           National Academy of Sciences (1974)        1973      15-30 (best 20)

Air           Heintz and Hershaft (1975)                 1973       9.5 - 35.4 (best 20.2)
 *By adjusting estimate to 1975 dollars, the annual costs for 1975 air pollution damages to
  health, materials, residential properties, and vegetation are estimated at $10.1 billion,
  $7.8 billion, $8.5 billion, and $166 billion, respectively - for a total of $26.6 billion.
 'An updated study projected total annual pollution damages to be $23.5 billion in 1976,
  of which S20.9 billion represented damage from stationary sources.
Source:   The Environmental Control Industry, for CEQ. December 1975, pp. 24, 25.
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                       APPENDIX M
        HEALTH AND WELFARE EFFECTS OF POLLUTANTS
AT CONCENTRATIONS BELOW NATIONAL AIR QUALITY STANDARDS:
                  A SUMMARY OF FINDINGS
                            By
                       Richard Ayres
                  Environmental Policy Center
                      Washington, D.C.
                       January 8, 1976
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             HEALTH AND WELFARE EFFECTS OF POLLUTANTS AT
       CONCENTRATIONS BELOW NATIONAL AIR QUALITY STANDARDS:
                           A SUMMARY OF FINDINGS
HEALTH EFFECTS

         Summarizing  the results of the  Conference  on Health Effects of Air  Pollution
which was conducted under the auspices of the National Academy of Sciences - Engineering,
the NAS reporters concluded: 1

     Due to the limitations  of present knowledge, it is impossible  at this  time to
     establish an ambient air concentration of  any  pollutant - other  than  zero —
     below which it is certain that no human beings will be adversely affected.

         For example, a sulfur dioxide episode in Yokkaichi, Japan, in 1972 resulted in
817  reported illnesses from  sulfur dioxide inhalation when the pollution level reached 0.1
part  per  million (ppm). [Syrota,  M.. "Observations on the  fight against air pollution in
Japan," 15  Pollution  Atmospherique 129-151  (1973).] By comparison, the  maximum
24-hour concentration,  which is not to be exceeded more than  once per year, under the
present national standards is 0.14 ppm. During the  same episode in Japan, absenteeism
among school children  due  to respiratory  ailments tripled when  the average weekly sulfur
dioxide level exceeded 0.09 ppm. [Ibid. ]

         A recent report in  this country found:2

     The implication of daily levels of SO2  and particulates  has been studied in
     particularly vulnerable  groups  such  as  patients  with  chronic  bronchitis  and
     emphysema. Deterioration in  their respiratory well-being has resulted from daily
     concentrations of  SOo  of about 500 micrograms  per cubic meter which is not
     much above the 24-hour primary standard. A few studies have even suggested that
     deterioration in particularly vulnerable groups may occur with daily concentra-
     tions which are below this standard.

         A  classic example of the adverse effects on  health from sulfur oxide concentra-
tions below the ambient standards has recently been documented by EPA itself. Ever since
the national  sulfur dioxide standards were promulgated, increasing attention has been given
derivative  forms  of  sulfur  dioxides, namely  sulfates.  Sulfates are produced through
complex interactions of sulfur oxides with other chemical substances in the air and  with
ambient moisture. In recent years, sulfates have become increasingly regarded as being more
1 Summary of Proceedings - Conference on Health Effects of Air Pollution, Senate Public
 Works Committee, 93d Cong., IstSess. 1 (1973).
2Rall, "A Review of the Health Effects of Sulfur Oxides," National Acadamy of Sciences -
 Engineering, Air Quality and Automobile Emission Control, Vol. 2, Senate Public Works
 Committee, 93d Cong., 2d Sess. 418 (1974) (Hereafter NAS Report).
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                                        M-2
dangerous to human health and more likely to be responsible  for observed human health
effects than sulfur dioxide itself. 1 The data tentatively suggest  (1) adverse health effects
could be  ascribed  to quite low values of suspended sulfates,2  and (2)  such values exist
pervasively in the ambient air throughout the eastern United States.3

          On September 23,  1975, EPA issued  a report which, while emphasizing the need
for additional studies, stated that  its "best judgment estimates"  tied adverse effects to
sulfate concentrations at or below that found in  a 24-state region of the northeastern United
States, including rural areas. [EPA, Position Paper  on Regulation of Atmospheric Sulfates,
p. x (1975).]  Furthermore, these sulfate  concentrations were correlated to sulfur dioxide
levels at or near the primary annual standards and at or below the primary 24-hour standard.
For example, urban levels now being monitored in  the northeastern United States measured
a  range  of  sulfate concentrations  of  10 to  24  micrograms  per cubic meter  (ug/m3);
nonurban concentrations ranged from 8 to 14 ug/m3 (annual average). [Id. at x, 20.] "Best
judgment  estimates" on levels associated with adverse health effects were as low as 10 to 15
ug/m3 (annual average).  [Id. at viii, 10.]

          Despite this information, EPA has concluded that (id. at 78):

     [S]ulfate information presently available does not now permit the establishment
     of a new regulatory program.

Moreover (id. at xiv):

     development  of the  data  and information  necessary for a  sulfate  regulatory
     program would require 3 to 5 years.  In this regard, if EPA were to set a National
     Ambient Air Quality Standard  (NAAQS) for sulfates, it could not realistically be
     proposed before 1980 or 1981.

          Sulfur  dioxide  emissions  from  relatively clean air  in  rural  areas is  a chief
contributor to dangerously high urban sulfate concentrations. EPA states (id. at 35);4
ISee, e.g.,  Rail,  "A Review of the Health  Effects of Sulfur Oxides,"  8 Environmental
 Health Perspective  97-121  (1974);  EPA, Health  Consequences  of Sulfur  Oxides 7-18
 (1974).
^See, e.g.,  Chapman, et al.. Power Generation:  Conservation, Health and Fuel Supply,
 Report to the Task Force on Conservation and Fuel Supply, FPC, 1973, National Power
 Survey 24-26.
3NAS Report, supra, Vol. 1, p. 60.
^See also id. at 38, 40; Klein, "St.  Louis Study Indicates People Are Doing More About the
 Weather than Talking About It," The Wall Street Journal, Aug.  19,  1975, p. 34.. wherein
 it is reported "Pollution coming out of Chicago, St. Louis, Detroit and other Midwestern
 centers contribute to weather patterns all over  the  eastern  U.S.";  Russell,  "Smog Trail
 Tracked to Fredericksburg,"  The  Washington  Star, Oct. 3,  1975, p. 1.
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                                        M-3
    The hypothesis  that  long  range transport  of sulfates  from power plants is
    influencing urban sulfate levels is supported by the limited data on emission and
    concentration trends.... [T]he NAS [National Academy of Sciences] presents
    estimates  of the  impact  of  large  emission  sources  on   downwind  sulfate
    concentrations.  Their  analysis suggests appreciable  impacts  on sulfate levels at
    distances of 300 miles downwind ....

EPA further states (id. at 41):

    [0] nee applicable emission limits have been met by all sources in urban areas thus
    reducing locally  produced  sulfates, EPA  believes that, based on the available
    evidence concerning transport, further increases in regional and urban sulfates can
    be  expected if  nonurban S02 emissions  from  power  plants and other sources
    continue  to rise. Given the general levels of sulfates,  other fine particles,  and
    sulfur oxides in the northeast, the Agency's assessment of the preliminary health
    data suggests that such increases should be viewed with concern.

EPA concludes  that (id. at 60):

    protecting the most sensitive  portion of the population could ultimately  involve
    SC>2 control in excess of that required to meet current SC>2 standards.

         Low-level effects  of other pollutants which are not covered by EPA's significant
deterioration regulations, such as nitrogen oxides, also cause  adverse effects. 1 For example,
nitrogen dioxide concentrations of 0.1-0.3  ppm for short periods  of time may cause  visual
and olfactory effects.- It is now believed that further control of  nitrogen oxide emissions
could  inhibit the formation  of sulfates in the atmosphere.3

         Finally, there is recent evidence regarding the possible cancer causing effects of a
nitrogen dioxide derivative. The  World Health Organization estimates that eighty percent of
cancers are environmentally caused; the National Cancer Institute puts the figure at sixty to
ninety percent. The City of Baltimore, Maryland, has the highest  cancer death rate of any
city in the nation.4  Until  recently dimethyl nitrosamine (DMN), one of the  most potent
cancer-causing substances known to man,  had  never been found  anywhere in ambient air
over  the  United States, because  techniques to detect it  were  too primitive. It was,
nonetheless, theorized that  DMN could  be formed in  the atmosphere by  the reaction of
nitrogen oxides with  industrial or natural  substances called  amines.  Baltimore was among
five eastern cities recently tested  for DMN. This  time the startling evidence revealed DMN to
be present over two of the cities.  Baltimore was one; its air registered the higher  level.


iSome of  these have been noted in the Brief of Petitioners,  Nos. 74-2063,  74-2079,
 pp.  18-20.
2NAS Report,  supra,  at 37.
3Qversight  Hearings on the Clean Air Act Before the Subcomm. on Public Health and  En-
 vironment of the House Comm. on Interstate and Foreign Commerce, 93d Cong. 1st Sess.,
 Pt. 1, at 285 (1973).
4Challmes, Fairfield plant faces probe in cancer agent, The (Baltimore) Sun, September 20,
 1975, at  Bl., col. 8;  Auerback,  EPA Probes Chemical Effects, Washington Post, September
 20, 1975 at A3, col.  1.
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                                        M-4
          In  sum, the evidence is mounting that adverse effects on health and welfare are
associated with air pollution concentrations well below the present national standards. The
National Academy of Sciences - Engineering recently reported to the Congress: 1

     All of  the  panels on  health  effects addressed  themselves  to  the question of
     whether there are thresholds for the  adverse health effects of pollutants,  that is,
     some  safe  levels below  which  essentially all members of the  population are
     protected.  The  present  standards were  derived on the assumption  that such
     thresholds do exist. . . .

     However, in no case  is  there evidence that the threshold levels have  a  clear
     physiological meaning, in the sense that there are genuine adverse health effects at
     and above some level of pollution, but no effects at all below that level.  On the
     contrary, evidence indicates that the amount of health damage  varies  with the
     upward  and downward variations in the concentration of the pollutant, and with
     no sharp lower limit. 44(a).

Moreover,2

     Some persons with respiratory or cardiac disease may have so little reserve that
     the slightest increase in pollution could aggravate their condition or precipitate
     death. 44(b).

     Thus, at any concentration, no matter how small, health effects  may occur, the
     importance of which depends on  the gravity of the effect. 44(c).

         A report submitted to the Ford  Foundation in September 1974 by the American
Public Health Association, concluded that

     at  every level of pollution  and not at some defined threshold,  it appears that,
     depending upon the adaptive reserve  of the individual, someone becomes ill and
     someone's life is shortened.3

VEGETATION

         Adverse effects are also caused to vegetation by low levels of pollution. Complete
disappearance of certain lichens has occurred when winter sulfur dioxide averages reached
two-thirds of the annual standard.  [EPA, Effects of Sulfur Oxide in the Atmosphere on
Vegetation:  Revised  Chapter 5 for  Air Quality Criteria for  Sulfur Oxides, p.  19 (1973).]
Acute injury  to spruce trees has been observed when the four-month growth season average
concentration for sulfur dioxide was two-thirds the annual standard.  [Id. at 36-37.] Other
studies indicate varying adverse effects of  pollutants at levels below the  national standards
on wheat and potato yields, spinach  and  apple quality, white pine tree volume and  many
other crops. [Ibid. ]

iNAS Report, supra at 17, 58.
2/d at 18.
3Carnow, Wadden,  Scheff &  Musselman,  Health Effects of Fossil Fuel Combustion:  A
 Quantitative Approach 2  (1974), in American Public Health Association, Health Effects  of
 Energy Systems: A Quantitative Assessment (1974).
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                                       M-5
ACID RAIN

         Another effect of low-level pollution, which is closely associated with observed
ambient levels of suspended sulfates, is the phenomenon known as acid rain. [EPA, Position
Paper on  Regulation of  Atmospheric Sulfates,  supra, p. 11.]  EPA has found that  the
acidification of rainfall  can raise the acidity of soils and natural waters, cause mineral
leaching, and damage vegetation. [Ibid. ] The results can have a devastating effect on forests,
soils, plant, animal, and aquatic lifeJ A recent study suggests that acid precipitation may be
causing depletion  of fish populations in lakes in  the Adirondack Mountains of New York.2
A  Swedish study  pointed to  the increasing acidity of Swedish and Norwegian lakes and
streams, some  of which have become  so acidified that they can no longer support fish life.3

         Several groups have  warned about the  potential effect on vegetation which a rise
in  acidity may have. Sweden's researchers found  that a very small increase  in ambient
concentrations of sulfur oxides led to a drop in  the growth rate of its forests. [Id. at 44.]
The resulting acidity  was projected to result in a reduction of forest growth by as much as
10 to 15  percent by the year 2000. [Id. at 9.] Evaluating the environmental impact of
power plant development in the Southwest, a federal study group found that "the effect of
acid  rain .  . .  may be  expected  to be significant"  on vegetation as well as water quality.
[Southwest  Energy Study.  Report of [he Air Pollution Work Sub-group. App. C-l, p. 29
(1972).] An EPA panel  found that a  Christmas  tree plantation suffered significant damage
from  emissions from a  power plant, even  through  the  maximum  one-hour average  of
ambient sulfur oxides did not exceed .36 ppm during the study period,  in contrast to the
secondary 3-hour standard of .5 ppm.4

         In its comments  to EPA on the  1973 proposed regulations, the Forest Service
expressed  particular concern over reports of "substantial reduction in timber volume caused
by chronic low levels of SO2 or acid rains." The comments pointed out  that, "although
acute damage  episodes are  diminishing, we are now faced with a more serious problem -
chronic  exposure  to low levels of various air pollutants." To avoid such damage, the Forest
Service urged "a cautious approach to allowing any deterioration of air quality ... "5
     Pollution Across National Boundaries, Sweden's Case Study for the United Nations
 Conference on the Human Environment 9, 56 (1971); Likens & Bormann, Acid Rain: A
 Serious Regional Environmental Problem, Science 11, 76 (June 14, 1974); EPA. Summary
 Report on Suspended Sulfates and Sulfuric Acid Aerosols (197); EPA, Comments on the
 Study Management Team's Draft Report, Southwest Energy Study 12 (1972).
^Schofield, Lake Acidification  in the Adirondack Mountains of New York, presented at the
 1st International Symposium  on Acid Precipitation, and the Forest Ecosystem, Columbus,
 Ohio, 1975.
3Air Pollution Across National Boundaries, supra, p. 56.
4EPA, Recommendations and Summary of Mt.  Storm, West  Virginia — Gorman, Maryland
 and  Luke,  Maryland —  Keyser, West Virginia, Interstate Air Pollution Abatement Con-
 ference, Washington, D.C., October  1971.
Sporest Service Comments on Environmental Protection Agency "Proposed Rules for the
 Prevention  of  Significant Air Quality Deterioration," October  19, 1973, Attachment to
 Record No. E-3.
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                                         M-6
          Rainfall ten times more acidic than normal  has  been reported over the eastern
United States. In some remote rural areas of New England, the rains have been described to
be "as acid as pure lemon juice."!

          One especially difficult  aspect of acid rain is  that its quantity and concentration
depend upon the  total amount of pollution  in the air over a wide region rather than the
concentration in any particular place. Any increase in pollutants, even at very low levels and
even in an area  which enjoys air quality better than required by the standards, nevertheless
will  contribute  to  the overall atmospheric loading of  pollution which can result in  acid
rainfall.

VISIBILITY

          Any amount of air pollution, even at low levels, will have an impact on visibility.
If sulfur oxides are  present at a  level well below the  annual standard (60 micrograms as
opposed to the  standard of 80),  visibility will be reduced  to about 15  miles.  [EPA, Air
Quality Criteria for Sulfur Oxides, p.  14.]  If humidity is  fairly high, visibility will be
reduced even more.  For example, if humidity is  at 98 percent, with sulfur dioxide at 60
micrograms,  visibility decreases to 3 or 4 miles. [Ibid. ]  A visual range of five miles or less
requires that aircraft  operations  be  slowed and  restrictions  imposed.  [EPA, Air Quality
Criteria for Particulate Matter, p. 52.] By contrast, in large areas of the country and in
particular in those areas prized for their natural and scenic  treasures, present visibility  may
extend for 50 to 100 miles.2

          The presence of particulates also reduces visibility sharply. At what EPA terms a
"typical rural concentration" of 30 micrograms of particulates per cubic meter,.visibility is
about  25  miles.  [EPA, Air Quality Criteria for Particulate Matter, p. 60.]  At the level of the
secondary annual standard, 60 micrograms, the range is reduced about 12 miles. [Id. at  57.]
If particulates are  at the level of the primary  standard,  75 micrograms, that concentration
"might produce  a visibility of 5 miles in some instances." [Id. at 61.] And if nitrogen oxides
are present  with particulates,  visibility is reduced  even  further. [EPA, Air Quality Criteria
for Nitrogen  Oxides,  pp. 2-4, 2-6.]

SYNERGISTIC EFFECTS

          These  specific examples demonstrate that many adverse effects are  present  at
pollution  levels  below  those  set by  the  ambient  standards.  In addition,  however,
atmospheric  pollutants seldom, if ever, occur in isolation. It is  clearly established  that
pollutants  combined  together may  have a  greater  total  effect  than  the  sum  of their
individual  effects.  This  phenomenon,  called  synergism,  can result  in adverse effects
produced  by two or more pollutants  acting in combination, even though each pollutant is
present in quantities below its corresponding national standard. As the National Academy of
Sciences-Engineering has stated, the implication is that (NAS Report, supra, p. 19):

     Air quality standards that regulate individual pollutants independently can never
     fully reflect ambient pollutant concentrations and  their effects on human health.

1 Likens & Bormann, supra; Council on Municipal  Performance, "City Air," Municipal Per-
 fornamce Report 1:15, pp. 7-8 (1974).
2Southwest Energy Study, Report of the Air Pollution Work Sub-group, supra, p. 37;
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                                       M-7
         Research has increasingly  documented synergistic effects. For example,  particu-
late  matter  in  concentrations  below the  secondary 24-hour standard will  produce,  in
conjunction  with small amounts of sulfates, a decrease in the lung function of children both
at  rest and after exercise. [NAS Report, supra, p. 76.] The evidence of synergism between
sulfur dioxide and  particulates is well established. 1 EPA has concluded that  the harm from
sulfur dioxide is increased three to four times by the presence of particulates, which oxidize
sulfur dioxide  to acid aerosols. [EPA, Air  Quality Criteria for Sulfur Oxides,  p. 111.]  A
number of other studies have also demonstrated the synergistic effect of relatively low levels
of sulfur oxides in combination with particulates.2

         Synergistic  adverse  effects  upon  vegetation are  also  well  documented.  For
example, researchers "found  that a mixture of ozone and sulfur  dioxide injured  tobacco
leaves  at  concentrations  that  had  no  effects  when the two chemicals were  present
separately."  [Marx, "Air Pollution: Effects on Plants," Science 731, 733  (February 28,
1975).] Damage to  plants has been  found  at sulfur  dioxide  levels of only .001 ppm,
compared  with  the annual standard of .03 ppm, when combined with ozone.3 A later study
considered the combined effects of sulfur dioxide and nitrogen dioxide which "often occur
together because  they are  both formed  during the combustion of fossil fuels, especially
coal."4 The study found  that "the synergistic effect  was  most "marked 'at  the lower
concentrations used .  . . ."5 The concentrations ranged from .15 to .5 ppm compared with
the secondary standard for sulfur dioxide of .5 ppm.6
iNAS Report, supra, p. 73; Hodgson, "Short Term Effects of Air Pollution on Mortality in
 New York City," 4 Environmental Science and Technology 589, 590 (1970).
2See, e.g., Novakov, Chang, and Marker, "Sulfates as Pollution Particulates: Catalytic For-
 mation  on Carbon (Soot) Particles," Science 259 (October 18, 1974); Marx, "Air Pollu-
 tion: Effects on Plants," Science 731 (February 28, 1975).
3Applegate & Durrant, Synergistic Action of Ozone-Sulfur Dioxide on Peanuts, 3 Environ-
 mental Science and Technology 759 (1969).
4Marx, "Air Pollution: Effects on Plants," supra, p. 733.
SWhite,  Hill and Bennett, "Synergistic Inhibition  of  Apparent  Photosynthesis Rate  of
 Alfalfa  by  Combinations of Sulfur Dioxide and  Nitrogen Dioxide," 8 Environmental
 Science &  Technology, 574,  575  (1974).
6See also Heck, "Discussion of O.C. Taylor's  Paper: Effects of Oxidant Air Pollutants,"
 10 Journal of Occupational Medicine 485-499 (1968).
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    APPENDIX N
MULTIPLIER EFFECTS
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                              MULTIPLIER EFFECTS
A.   Background

         The  following  discussion of the  multiplier  is excerpted from  Environmental
Impact Assessment Guidelines for New Sources by EPA under the Federal Water Pollution
Control Act (August 25, 1975):

     An  estimate  induced  investment  in non-basic  industries  which will occur  as
     consequence of the  direct investment in basic industries is made on the  basis  of
     the multiplier concept.

     "The familiar multiplier concept states, in brief, that an increase in the exports  of
     a region will  lead to an  increase in  regional employment and, therefore,  to  an
     increase  in  regional income. This  increased income will, in turn, be spent and
     induce a second round of increased regional employment and income which will
     also be spent  to induce more income, and so on, to a finite limit. The calculated
     regional multiplier is an estimate of that finite limit. It is an estimate of the total
     amount of income generated by an injection of one dollar of new income  into the
     region." (Schenker,~l 970).

     A measure of the multiplier effect is the  ratio of total employment in the  affected
     region to the total employment for all basic industries . . .

     Care must be exercised in indiscriminately applying the multiplier so calculated
     because it assumes that  the proposed industry will behave indentically to  those
     basic industries already there.  This assumption  is  not valid for industries where
     the   product   being manufactured  will  be  rapidly  exported  out  of the
     region . . . that is, not permitted to stimulate growth  in "finishing" industries,
     transportation, warehousing, etc.

     By examination of the way in which the  proposed industry will be linked with the
     proposed economic  setting in comparison to the linkages between existing basic
     industries and the economic setting, a  qualitative  judgment can be made as  to
     whether the  calculated multiplier may  be  high or low, by what approximate
     amount; adjustments can then be made accordingly.

     Moreover, rapid technological changes in industry manufacturing process will alter
     traditional industry  interdependencies and  affect the validity of the results. The
     impact assessor should consider such variables before applying the technique.

B.   Derivation for Connecticut

          In this study, an export employment  multiplier was calculated for Connecticut
based on 1972 employment. All two-digit SIC's with location quotients (L.Q's) greater than
one  were considered as export industries. Total employment then represents 4.1 times the
export employment. Although the two-digit level of aggregation probably masked some
portion of the export employment, the multiplier of 4.1 does fall within the  normal range
of 1.5 to 4.5 for employment multipliers.
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                                          N-2
          In essence, what the multiplier indicates is that one job lost or gained in an export
industry  represents a total of about four jobs lost or gained in the region. Since in this study
the  region  for which the  multiplier was  calculated encompasses  the  entire  state of
Connecticut, any indirect  employment losses are not necessarily limited to  the specific area
wherein  the  export job losses occur. Moreover,  because the study addresses  the future
employment situation based on  a comparison of a forecasted  level of  growth and the
alteration in that forecast induced by alternative strategies, jobs are not really lost — instead
they are  foregone.
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               APPENDIX O
PRODUCTIVE POLLUTION CONTROL INVESTMENTS
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               PRODUCTIVE POLLUTION CONTROL INVESTMENTS
         The  following excerpt from a recent Council  on Environmental Quality (CEQ)
report  has  been  included  to introduce an  aspect of  control expenditures which  may
increasingly merit attention in evaluating the costs and benefits of control strategies.!

     Some Productive Pollution-Control Investments
     The perception of a pollution control investment as a nonproductive expenditure
     (output cost), however, may lead to a more crucial examination of the production
     process (input cost). Thus the real challenge  of pollution control is to improve
     resource allocation  or make it more efficient. A forced focus on inefficient use of
     materials   or  energy  may  result  in  modification  of existing  processes  or
     substitution of new ones that  not  only reduce  pollution, but  effect other cost
     savings as well. The  following are a few illustrations:
     1.   Dow Chemical Company installed  twenty-eight cooling towers at one plant
         for a cost of  S7.2  million to  reuse cooling water; a 10 percent return on
         investment  is  estimated as a result of better  efficiencies  and lower water
         costs. Seven pollution control projects installed in Dow's latex plants around
         the world at a capital cost of about S2 million  are expected to cut operating
         costs by almost a similar amount per year. Over a three-year period, another
         Dow division  has  saved S6 million in materials that previously  had  been
         disposed of in  sewers.
     2.   Studies undertaken  by the  CEQ  indicate  that changes in the production
         process for the typical Kraft paper  mill could have substantial cost and
         energy advantages.  Substitution  of oxygen  bleaching for chlorine  bleaching
         may  have  the advantage  of  increasing  pulp  yields and reducing chlorine
         effluents (which in  turn reduces  the need for end-of-pipe effluent treatment
         by the lime process). (Source: CEQ Tradeoff Analysis EG 4AC032.)
     3.   Anew closed-cycle system for Kraft pulp mills being installed by the Great
         Lakes Paper Company  uses a patented  salt recovery  process to separate,
         recover,  and recycle water and chemicals;  without end-of-pipe wastewater
         treatment facilities, the system will not discharge contaminated effluents and
         is estimated to use less energy,  less water, and cost less to operate than a
         conventional Kraft  pulp mill.  The estimated S8 million cost to implement
         the  closed-cycle system on a 250,000-ton-a-year  mill is  expected  to save
         approximately S4 million per year in lower costs for chemicals, water, and
         energy and  in higher pulp yields (resulting  from recovery  of fibers coupled
         with a more efficient bleaching technique).
1 Excerpted from Kenneth Ch'uan-k'ai Leung and Jeffrey Klein, The Environmental Control
 Industry: An Analysis of Conditions and Prospects for the Pollution Control Equipment
 Industry, for the Council on Environmental Quality, December 1975.
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                                     0-2
4.   In  Kraft Paper Mills, electrostatic precipitators are an  integral part of the
     recovery boiler. The cost to install per 1,000 tons of daily capacity is about
     S4.5  million. The product recovery value per year is S3.5 million in salt cake
     at  current market prices. While a precipitator is an air pollution abatement
     device, it is also a required piece of equipment in the process production
     stage.
5.   Ford Motor Company has recently announced that expanded use of catalysts
     on their 1976 models has enabled an average fuel mileage improvement of 25
     percent  over  their 1975 models. If  Ford  achieved the industry's average
     improvement  of  14 percent on their 1975 models over their 1974 models, it
     would appear that Ford has already achieved a 42.5 percent improvement on
     1974 model mileage — 2.5 percent better than the Administration requested
     by 1980.
6.   In  the early  years of electrical precipitation, the smelting industry was the
     total  market for precipitators — payout from recovered materials of 2 to 3
     years was considered common. In petroleum refining, cost of a cyclone is
     about S300,000 for recovery of S3.5 million per day of catalyst material.
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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.
  EPA-901/9-76-003
                              2.
                                                            3. RECIPIENT'S ACCESSION«NO.
4. TITLE AND SUBTITLE
  SOCIOECONOMIC IMPACT ASSESSMENT OF PROPOSED
  AIR QUALITY ATTAINMENT AND MAINTENANCE
  STRATEGIES
                                                            5. REPORT DATE
                  4 June 1976 Date of Issue
             6. PERFORMING ORGANIZATION CODE
7'AUTHOR(SI Harbridge House, Inc. (N. W, Sheldon,  S. S.
  McKittrick; S. Siegert; C. Franz-Goldman; K.  Magnuson).
                                                            8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
  Harbridge House, Inc.
  11 Arlington Street
  Boston, Massachusetts  02116
                                                            10. PROGRAM ELEMENT NO.
              11. CONTRACT/GRANT NO.
              EPA Contract No. 68-01-1561
              Task Order No. 5
12. SPONSORING AGENCY NAME AND ADDRESS
  U.S. Environmental Protection Agency
  Region I
  Boston, Massachusetts  02203
              13. TYPE OF REPORT AND PERIOD COVERED
              Final
              14. SPONSORING AGENCY CODE
 15. SUPPLEMENTARY NOTES
 16. ABSTRACT
  As part of the State of Connecticut's Air Quality Maintenance Planning (AQMP) procedure,
  this study assesses the socioeconomic impact of three strategies for attainment and short-
  term maintenance of sulfur oxide and particulate standards.

  The three strategies are as follows: (i) an emission limitation (specified as BACT) in-
  corporated in the Connecticut new source review procedure;  (ii) an air quality impact
  criterion incorporated in the Connecticut new source review procedure; and (iii) a pro-
  posed reduction in the allowable sulfur content  of fuel burned. The analysis has included
  evaluation of direct and indirect costs and benefits using quantitative as well as qualita-
  tive methods. Assessment has focused on incremental  "order of magnitude" impacts
  of strategy implementation over a  10-year time frame.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS  C.  COSATI Field/Group
 Air Pollution
 Sociology
 Economic Analysis
 Air Quality Maintenance
 Plans Connecticut
18. DISTRIBUTION STATEMENT
 Release Unlimited
19. SECURITY CLASS (This Report)
 None
21. NO. OF PAGES
  219
                                               20. SECURITY CLASS (This page)
                                                None
                                                                          22. PRICE
EPA Form 2220-1 (9-73)
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